Advanced Battery Technologies Code of Conduct
Advanced Battery Technologies conducts business on a global scale, and it strives to provide excellence in every aspect and level of its organization. Our Code of Conduct provides practical advice for our employees on laws and regulations, expectations, best practices and guidance on dealing with others. It’s a reflection of our commitment to operating with integrity, transparency, fairness and in full compliance with applicable laws and ethical principles.
Anti-bribery Policy
Through this policy, Sunlight Group seeks to ensure that all employees, as well as third parties, with which it conducts business, comply with the main anti-bribery regulations and legislations applicable to the different jurisdictions where they are operating. Establishing appropriate rules and processes to prevent corruption and facilitation payments and raising awareness to its personnel in such matters is of outmost importance for Sunlight Group for safeguarding a transparent working environment. The policy endorses the basic principles set in international standard ISO 37001, on Anti-Bribery Management System.
Donations & Sponsorships Policy
Sunlight Group develops a proactive and ongoing strategy to support the needs of the communities it lives and thrives in. In this context, it annually grants donations and sponsorships to entities, for the purposes of improving the quality of life of local communities, supporting education and training activities or environmental initiatives and enhancing health, emergency and rescue services.
The Donations & Sponsorships policy sets the specific transparent and mandatory procedures to be followed by Sunlight Group companies when assessing and granting donations or sponsorships based on the action areas defined by the Corporate Affairs & Sustainability Department’s strategy.
Gifts & Hospitality Policy
Sunlight Group recognizes that gifts and hospitality can be important for developing business relationships with customers, suppliers, and other third parties. However, they may often raise suggestions of impropriety. Therefore, it is important that employees are able to assess whether a gift and hospitality received or offered is accepted or prohibited. If not prohibited, employees need to ensure that the internal gifts and hospitality procedure is followed.
This policy provides guidelines for the appropriateness of different kinds of gift and hospitality and sets specific procedures to be implemented when offering or receiving such items during business dealings.
Policy on Preventing and Addressing Violence and Harassment at the Workplace
Target of this policy is to promote diversity and inclusion and ensure a working environment with zero tolerance to violence, bullying, discrimination and harassment, based on the principles of mutual respect, human dignity, cooperation, mutual assistance and the protection of human existence and human rights.
Sunlight Group adopts appropriate measures to prevent and combat any kind of violence and harassment, expressly including sexual harassment, at work, and establishes effective and confidential internal reporting mechanisms to encourage all employees to speak up, without the fear of victimization or retaliation.
Competition Policy
Through this policy, Sunlight Group companies commit to comply with the rules of Greek and European Union competition law, as well as those of the national competition laws of the countries within which they operate. As some agreements with customers, suppliers, competitors or other business partners can potentially limit free and open competition, it is important to make sure that all employees involved in commercial activities and conducting discussions and negotiations with third parties know how to apply antitrust rules and to avoid even the appearance of unfair restriction of the competitive freedom.
This Policy enhances employees’ awareness about competition best practices and rules, defines and prevents prohibited agreements and establishes measures appropriate for preventing abuse of dominant position, promoting a healthy and fair competition with other industries activated in our area of specialization.
Sanctions Policy
The present policy outlines the controls and procedures required to be in place in order to ensure that Sunlight Group companies comply with all applicable economic, trade and financial sanctions laws and regulations. It addresses the risk of Sunlight Group companies entering into a transaction with a sanctioned entity in breach of sanctions legislation, which could potentially result in reputational damage, large fines or criminal penalties for individuals, restrictions on the ability of the Group to engage in international business transactions or even termination of the Group’s financing arrangements.
Third Parties’ Due Diligence Policy
The cooperation of Sunlight Group with suppliers, customers, agents and other business partners is assessed in accordance with approved (qualitative and quantitative) criteria. The Third Parties Due Diligence Policy describes in detail the above criteria and the exact steps of the due diligence process, that Sunlight Group companies need to perform prior to establishing relationship with any third party, as well as on a regular basis during their collaboration, with the objective to identify the level of compliance of business partners with applicable laws and regulations, corporate best practices and main values and principles, as endorsed in the Group’s Code of Conduct.
Conflict of Interest Policy
Although Sunlight Group respects its employees’ right to privacy in their personal affairs and activities, it implements all measures and procedures required to effectively identify and then manage any case where the personal or family activities of the latter raise or may raise an actual or potential conflict with their duty of loyalty to the Group.
The present policy aims to prevent, detect and manage the conflicts of interest that may arise between Sunlight Group and its workforce. Through ensuring employees’ objective judgement and commitment to the business goals, we protect the integrity of the decision-making process and thus the Group’s reputation and stakeholders’ trust.
Whistleblowing Policy
In order to enhance transparency and integrity, Sunlight Group has established appropriate internal channels for handling and investigating reports and complaints. Whistleblowing Policy informs employees and third parties about the available mechanisms for reporting any unethical and questionable practices, illegal behavior, serious irregularities, violations of internal policies and procedures, as well as any reasonable suspicions which have come to their notice and are related to Sunlight Group’s companies.
It also sets the process which needs to be followed for the investigation and management for each report, defining the responsible for such matters internal bodies and implements the necessary measures for the protection of confidentiality and anonymity of the whistleblowers. Raising awareness and encouraging everyone to voice their concerns, without fear of retaliation is of outmost importance, for the benefit of both individuals’ and Group’s interests.
