
Anti-Bribery Policy
Integrity, Transparency & Zero Tolerance for Bribery
The integrity of our employees and business partners is fundamental to the success and sustainable growth of our company. Bribery has serious consequences that affect both organizations and individuals.
This policy has been established to reinforce Management’s commitment to a zero-tolerance approach to bribery by providing a clear framework of responsibilities, principles, and guidelines for its prevention, detection, and elimination.
Purpose of the Policy
- Compliance with all applicable anti-bribery laws and regulations.
- Fulfilment of the requirements of ISO 37001:2016.
- Identification and management of existing and potential bribery risks.
- Continuous improvement of the Anti-Bribery Management System.
- Encouraging the confidential reporting of any bribery incident or suspicion.
- Raising awareness among employees and business partners to recognize bribery-related risks.
- Protecting the company’s reputation and legitimate interests.
Scope
This policy is binding on Management, executives, employees, and any individual or organization acting on behalf of the company, without exception.
Where the company participates in joint ventures without having full control, it encourages its business partners to comply with the requirements of this policy.

Definition of Bribery
Bribery is the direct or indirect offering, giving, promising, or authorizing of anything of value or any form of advantage with the intention of improperly influencing a person’s decisions, actions, or official duties.
Bribery may result in both civil and criminal liability under applicable legislation. Both active and passive bribery are strictly prohibited, meaning that both offering and accepting a bribe constitute prohibited conduct.
Forms of Bribery
- Gifts, hospitality, travel, entertainment, or special expenses intended to influence decisions.
- Commissions or kickbacks provided to obtain an improper business advantage.
- Facilitation payments made to accelerate or secure routine procedures.
- Donations, sponsorships, or contributions intended to obtain preferential treatment.
- Conflicts of interest that may compromise impartial decision-making.
Gifts, Hospitality & Business Expenses
Gifts and hospitality are permitted only when they are lawful, reasonable in value, appropriate for the circumstances, and do not create the appearance of improper influence or an exchange of favors.
Cash, cash equivalents, or benefits intended to obtain an unfair advantage, influence business decisions, or secure preferential treatment must never be offered or accepted.
Conflict of Interest
The company is committed to preventing conflicts of interest. Employees and business partners who become aware of any actual or potential conflict of interest must promptly report it to their manager or the Compliance Team.
Record Keeping
The company maintains accurate financial records, registers, and appropriate internal controls to document the legitimate business purpose of all payments made to third parties. All related documentation must be complete, accurate, and properly maintained.
Training & Communication
Training on this policy forms part of the induction process for all new personnel. Employees whose responsibilities expose them to a higher risk of bribery receive additional specialized training.
Our zero-tolerance approach to bribery is communicated to suppliers, contractors, and business partners from the beginning of every business relationship.
Reporting Concerns
Any concern, suspicion, or potential incident of bribery should be reported promptly. No employee will suffer retaliation for reporting, in good faith, an actual or suspected violation of this policy.
- By email to info@eccike.com.
- By post to: 9th km Thessaloniki–Thermi Road, P.C. 57001, Pylaia, Thessaloniki, THERMI 1 Building – B13, attention: Management Systems Representative.
- Through the anonymous reporting channel established by the company.
Sanctions
Any employee found to have violated this policy may be subject to disciplinary action, including termination of employment, and may also be referred to the competent authorities where appropriate.
Monitoring & Review
The Management Systems Representative is responsible for maintaining this policy and providing guidance and support during its implementation. The Anti-Bribery Policy is mandatory for all employees and business partners.
This policy has been approved by the company’s Management, is updated whenever changes occur in the company’s operating environment, and is reviewed as part of every Management System review.
01.01.2021
