2.
Strict
observance
of
the
legal
framework
that
governs
the
issues
of
corruption
and
bribery
in
the
activities
of the Group.
3.
Strict adherence to the legal framework governing the issues of money laundering and terrorist financing.
4.
Employee
awareness
in
matters
of
regulatory
compliance,
corruption,
and
bribery
but
also
of
the
Code
of
Ethics
and
Conduct,
to
create
a
strong
culture
of
compliance
within
the
Group
and
compliance
with
the
policies, procedures of the Management System.
5.
Identification
and
management
of
regulatory
compliance
and
corruption-bribery
risks.
This
includes
identifying
and
assessing
the
risks
associated
with
the
regulatory
corruption
and
bribery
framework
to
take
appropriate measures to reduce them.
6.
Communication
of
compliance
obligations,
including
risks,
management
procedures,
non-compliances
as
well as improvement actions and the results of controls / inspections to all parties involved.
7.
Creation
of
the
appropriate
control
mechanism
and
prevention
measures
to
detect
and
prevent
issues
such
as
bribery,
corruption,
money
laundering
and
bribery
financing,
conflict
of
interest,
general
regulatory
compliance issues. Prevention mechanisms and measures include the following:
o
Clear
definition
of
the
principles
that
govern
the
Group
for
these
issues
through
the
Code
of
Ethics
and
Conduct and the applicable Policies.
o
Clear definition of responsibilities through the Internal Rules of Operation.
o
Different
levels
of
approval
clearly
defined
in
the
Internal
Rules
of
Operation
and
in
the
decisions
of
the
Board of Directors.
o
Application of the four-eye principle and double signatures in the Group's procedures.
o
Continuous training and awareness of staff.
o
Due diligence actions in the selection of partners, suppliers, staff, customers.
o
Scheduled and extraordinary audits by the Internal Audit Unit.
o
Scheduled and extraordinary internal inspections by the Head of Regulatory Compliance.
To achieve the above objectives, the Group is committed to the following:
1.
Continuous training and staff awareness.
2.
Reporting and Managing Complaints.
3.
Independence of the Regulatory Officer.
4.
Implementation of procedures for managing conflicts of interest.
5.
Continuous improvement of Management System efficiency.
6.
Operation of a Mechanism for the evaluation of cases of nonperformance of obligations.
7.
Drafting
and
implementation
of
Policies
specializing
in
regulatory
compliance,
corruption
and
bribery
issues,
such
as
unhealthy
competition
policy,
travel
and
accommodation
policy,
gift
policy,
sponsorship
and
donation policy.
3.2
Results of the above policies and non‐financial performance indicators
Since
2019,
TERNA
ENERGY
Group
has
been
certified
according
to
the
ISO
37001
standard
for
the
fight
against
corruption,
which
covers
all
its
activities
and
will
be
valid
until
July
2022,
when
the
re-certification
audit
will
take
place.
GRI 205‐3: Confirmed incidents of corruption and actions taken
During
2021,
there
was
no
confirmed
case
of
corruption,
either
through
complaints
or
through
audits
carried
out
by
the
Group
in
the
context
of
preventing
and
combating
any
incidents
of
corruption.
Under
the
Code
of
Conduct
and
Ethics,
all
employees
can
report
any
corruption
incident
to
the
email
compliance@terna-
energy.com.
In
addition,
corruption
cases
can
reported
to
the
Group's
grievance
and
complaint
mechanism
which is available at the following link:
https://www.terna-energy.com/epikinonia/
.