ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
The company ” «Florios Real Estate SINGLE MEMBER PRIVATE COMPANY» ” which owns the website ” https://mykonosvillasflorios.com ” is committed to carry out its activities lawfully and always according to high ethical standards.
This statement of our anti-corruption policy was drafted while taking into account the company’s obligation to clarify its position on bribery and corruption issues and to provide information and guidance regarding the combat of such phenomena.
- The company applies a policy of zero tolerance towards bribery and corruption and is committed to act professionally, lawfully and with integrity in all its business transactions and relationships wherever it exercises them. The company is also committed to implementing and enforcing effective anti-corruption systems; in accordance with all the relevant Greek laws (such as the Laws 2656/1998, 2802/2000, 2803/2000, 2957/2001, 3560/2007 and 3666/2008 – as amended by Law 4254/2014 – of the European Union as well as the Conventions and Regulations of the United Nations), as well as the laws in force in the foreign countries where the company operates to the extent that these laws are applicable.
- The company does not tolerate any form of bribery or corruption. The company shall not provide, offer, or offer to provide, approve or request someone to provide, directly or indirectly, benefits of any kind to persons in any form so that such persons may proceed, in violation of their duties, to an act or omission. The company will never seek or accept, directly or indirectly, benefits of any kind or the promise thereof, to provoke or reward inappropriate behavior in the form of acts or omissions arising out of or conflicting with one’s duties.
- In this Policy Statement, “third party” is considered any natural person or employee of an organization who, in the performance of their duties, contacts the company. This includes current and potential customers, consumers, suppliers, distributors, business contacts, agents, consultants as well as governmental and public organizations, including its consultants, representatives and CEOs, politicians and political parties.
WHO IS COVERED BY THE POLICY
The company operates according to the fundamental standards of that always remain unchanged, regardless of where it carries out its activities or with whom it cooperates.
This Policy applies to all persons regardless of the level at which they work and the qualification/grade they hold, including senior management, senior officials, directors, members of the Executive Committees and Boards of Directors, employees (permanent, on a fixed-term contract or temporary), consultants, contractors, trainees, employees, employees, volunteers, trainees, agents, sponsors and any other person associated with the company with any of its subsidiaries or employees, wherever their registered office is located (together referred to as “personnel” for the purposes of this Policy).
This Policy sets a standard that all staff members must adhere to, regardless if local laws, customs or customs stipulate otherwise.
Non-compliance with this standard, intentionally or unintentionally, may lead to disciplinary proceedings which may result in dismissal due to serious misconduct as well as the criminal prosecution of the person involved, based on the relevant Greek laws.
The staff will be asked to confirm that they have read and understood this Policy and that they will comply with its content.
This Policy is not part of any staff employment contract and can be amended at any time.
WHAT IS BRIBERY?
Bribery includes the following:
- When an economic or other advantage is offered, or advocated to, another person, with the intention to get them enticed or rewarded in order to perform their duties improperly, or
- When a financial or other advantage is required, it is agreed to be taken or accepted by another person to perform their duties in an improper manner.
It is unimportant whether the bribery:
- It is given directly or through a third party, or
- It is given for the benefit of the recipient or another person.
GIFTS AND HOSPITALITY
The company acknowledges that in many occasions gift offering is considered a typical way of forming closer according to this Policy, the company is particularly careful with offering or receiving gifts.
While typical gifts are usually considered acceptable, gifts that are considered excessive, luxurious or in any way inappropriate will not be offered or received. In any case, the intention behind the gift offer will be taken into account. Money or other similar offers will not be accepted as gifts.
MONEY LAUNDERING
The company actively complies with all laws and regulations relating to the combat of money laundering and terrorism incidents and recognizes that it has the responsibility to report to the Greek Authorities any behavior considered suspicious.
UNACCOUNTED PAYMENTS FOR FAVORS
Unaccounted payments are considered all payments, regardless of the amount they are, given to employees or executives to accelerate the pace of their duties.
In general, any unaccounted payment is strictly prohibited. However, in exceptional circumstances, where such payment is absolutely unavoidable, such offers will be made after consultation with the company and the authorities will be notified.
DONATIONS
The company does not contribute to any political party. Charity sponsorships will not be given for the purpose of gaining a commercial advantage.
TRANSACTIONS WITH PUBLIC OFFICIALS
Despite the fact that this Policy is applicable to both the public and private sectors, dealings with public officials carry a great risk of bribery and corruption, due to the strict rules and regulations.
Public officials are considered those who work in departments of the public sector but also those who work in commercial enterprises, international organizations, political parties and also political candidates, who are controlled or belong to the State.
The provision of money or any other benefit with economic value, regardless of its amount, to any public official for the purpose of exercising influence from their position, is prohibited.
KEEPING RECORDS
The company maintains financial records and implements an appropriate internal control system, to justify each payment to third parties. All accounts, invoices and other documents and records relating to transactions with third parties must be completed and maintained with strict accuracy and completeness. No account should be kept outside the books to facilitate or conceal improper payments.
RAISING CONCERNS
The staff will be encouraged to report concerns about any issue or suspected offence as soon as possible. No employee will suffer any harm because they raised genuine concerns regarding bribery, corruption, money laundering, improper donations and unaccounted payments for favors.
MONITORING AND REVIEW
The effectiveness of the implementation of this Policy will be regularly monitored and evaluated, regarding its suitability and its effectiveness. The improvements deemed necessary will be implemented as soon as possible. The factors responsible for the internal control systems and the procedures made will be subject to regular inspections to ensure their effectiveness in tackling bribery and corruption.
All staff members are responsible for the success of this Policy and should commit to applying it to uncover potential risks or offenses.
Staff will be asked to comment on this Policy and suggest ways to improve it. Comments, suggestions and questions should be addressed to the representatives of the legal department of the company.
