Policy Anti-Bribery

Πολιτική Anti-Bribery

Anti-Bribery Policy

Break Even Consulting, due to the sensitive nature of its client base and its commitment to providing effective services, which requires compliance with integrity standards in the manner in which it conducts its business, implements an Anti-Bribery Management System in accordance with the requirements of the international ISO 37001:2016 Standard.

In particular, the company responds to the constantly changing global legal and business environment, which is characterized by increasing challenges in the area of corruption. To prevent such phenomena, it adopts and implements an Anti-Bribery Management System that is fully aligned with international ISO standards, and all employees and external partners are committed to acting in accordance with the highest standards of integrity, ensuring transparency and appropriate implementation of the relevant legislative framework applicable at a global level.

Through the implementation of this System, our company aims to:

  • Ensure full compliance with all legal and regulatory requirements related to combating bribery.
  • Establish a total prohibition of bribery, as well as any related illegal activity involving or potentially involving its management, employees and external partners.
  • Continuously inform and train its human resources in order to raise awareness of bribery and corruption issues.
  • Identify and promptly address potential cases of bribery or corruption.
  • Create and establish a climate of trust and transparency both within the company’s internal operations and toward its employees, as well as toward potential customers, third parties and the wider community, thereby continuously ensuring the proper improvement of its work.
  • Purpose of the Policy

The operation of our company is based on adherence to fundamental principles, including transparency, trust, integrity and respect. Bribery and any related illegal behavior, whether it concerns real transactions or attempted transactions, beyond the serious criminal and civil liabilities they may entail, are contrary to the company’s fundamental values.

This Policy:

  • Clearly and specifically describes the conduct of bribery and corruption that is strictly prohibited, as well as the potential consequences of such prohibition, which apply both to the company’s management and employees and to our external partners.
  • Informs all involved parties about the methods for identifying and avoiding behaviors related to bribery and corruption.
  • Provides information on identifying and addressing bribery and corruption issues.

The Company’s Management is committed to continuously monitoring compliance with this Policy and updating it, where necessary, in order to ensure that it remains effective. Management, employees and the company’s external partners are responsible for complying with this Policy, as it is updated and amended from time to time.

  • Scope of Application

This Anti-Bribery Policy applies to the partners, members of Management, employees and every external contractor of the company. More specifically, the Policy applies to the following categories of cooperation with the company: Consultants at all levels (supervisors, executives, managers, consultants on fixed-term or indefinite-term contracts, trainees, etc.),

  • External partners (consultants, service providers, contractors, subcontractors, etc.).
  • Any external representatives or sponsors of the company.
  • Any counterparty who intends to cooperate and/or in any way interacts with the company, wherever they operate.
  • Definitions and Types of Bribery

Bribery is defined as the request, receipt, offer, promise or provision of money or another non-financial or intangible benefit, by or to a person within the company or by/to the Public Sector, in exchange for an unfair or unlawful advantage. The recipient does not necessarily have to be the direct beneficiary of the bribe. The conduct itself is sufficient.

At national level, bribery is prohibited and punishable under the relevant provisions of the Greek Penal Code, as well as other legislation concerning the prevention of corruption and bribery. At the same time, there are European and international texts, such as the Council of Europe Convention and the OECD Convention on Combating Bribery, which impose sanctions on offenders, whether individuals or companies. Penalties provided at national and European/international level include both fines and imprisonment in cases of natural persons.

Examples of payments and activities used for bribery include:

  • Cash gifts – cash or equivalent
  • Personal favors and reciprocal benefits
  • Illegal commissions / kickbacks
  • Promises of additional business activities
  • Expensive travel, accommodation and participation in events without professional relevance
  • Individual or family expenses covered by someone else (third parties)
  • A loan from a supplier that is never repaid
  • A request from a public official to be paid in order to perform a transaction

Furthermore, bribery is distinguished into passive and active bribery, which are defined as follows:

  • Passive bribery: An employee who, in breach of their duties, requests or receives, directly or through a third party, for themselves or for another person, unlawful benefits of any kind in exchange for an act or omission relating to or contrary to their duties.
  • Active bribery: A person who promises or provides an employee, directly or through a third party, with unlawful benefits of any kind in exchange for an act or omission relating to or contrary to the employee’s duties.
  • Reporting Complaints – Anti-Bribery Committee

The company has established an Anti-Bribery Committee, which is available to any interested party and is responsible for providing clarifications/advice regarding the implementation of this policy, as well as investigating any complaints, regardless of their origin (employees, justice authorities, public bodies, suppliers and other third parties). The Committee consists of the Anti-Bribery Management System Manager and the company’s Legal Counsel.

Interested parties may contact the company via [email protected] to report any unlawful or questionable business activities involving a potential company partner. For the same reason, employees may alternatively contact the Head or a member of the Anti-Bribery Committee.