Code of Professional Conduct

Introduction

The Code of Professional Conduct (hereinafter referred to as the "Code") is designed to reflect the principles and rules governing Management’s commitment to employees and stakeholders. The Code sets the behavior of BoD members and employees and recommends rules of acceptable behavior between them and to interested parties. The Code applies to Aegean Airlines SA and develops issues related to:

Human rights,
Health and safety,
Employees’ skills,
Principles of professional conduct,
Relations with interested parties (stakeholders),
Confidentiality.

Criteria for the development of the Code are the business activity of the company and the consequent services provided, as well as the current legislative framework.

Basic principles of code of conduct of BoD

The Board of Directors is the public face of the company and therefore its behavior, as well as that of the board members, must be exemplary.
The issue of ethical behavior inside and outside the company, as well as the values that frame the Board of Directors’ code of conduct, is of utmost importance. The values of the board of directors’ code of conduct concern the following:

Self-lessness: Board Members must make decisions based on the company’s best interests and not obtain financial or other material benefits for themselves, their families and close associates.
Integrity: Board Members should not be subject to any financial or other obligation to third parties or organizations that could influence them in the performance of their duties.
Objectivity: When conducting transactions and awarding contracts or hiring executives to fill organizational positions, selections should be based on criteria of merit and transparency.
Responsibility: Board Members are accountable for their decisions and actions.

Transparency: Board Members must be transparent about all decisions and actions they take.

Integrity: Board Members have a duty to declare any private interest related to their duties and to take steps to resolve any conflicts of interest.

Leadership: Board Members must promote and support these principles at all levels of the management hierarchy.

Human Rights

The company's management operates with a sense of responsibility and consistency towards the employees. It is its continuous effort to develop and maintain a working environment, which promotes recognition, meritocracy and mutual trust. In this context:

Every employee is treated with respect and dignity. All kinds of discrimination regarding the opportunity of recruitment, employment, payroll, promotion, termination of employment, indemnity, retirement, nationality, race, religion, gender, age, age, physical and mental capacity, genetic orientation, political beliefs.
Every employee is treated with respect and dignity. Any form of abuse (physical-psychological and intimidation) is explicitly prohibited, as well as any form of sexual or other kind of harassment.
Diversity must be respected and any behavior that affects the dignity of the individual and discriminates in any form is rejected.
Only practices that comply with the applicable labor laws are followed.

Health and Safety

Where a privacy data breach is known to have occurred (or is suspected) any member of Aegean staff who becomes aware of this must, within 24 hours, alert the Data Protection Officer in the first instance.
Health and Safety at work defines all the conditions and factors that affect the psychosomatic condition of employees and includes every possible activity of protecting and preventing them from occupational dangers.
Management is commitment to protecting and safeguarding Health and Safety of employees through its Health and Safety Policy, which is not limited to fully compliance with the current legislative requirements in the conduct of any corporate activity, but extends to the adoption of best practices as well as to educational and awareness – raising actions on health and safety issues. This policy refers to:

The commitment to compliance with the health and safety regulatory requirements.
The implementation of procedures aimed at reducing risks and minimizing accidents.
The assurance on the provision of training and necessary information related to health and safety issues as well as of the allocation of the necessary resources for the implementation of the Health and Safety Management System.
The assurance on cleanliness of the workplaces.
The obligation to preserve the good condition of the means provided by the company for the execution of duties.
The employees’ compliance with Management’s written and oral instructions on safety and hygiene conditions.

Employees’ skills

Employees are required to comply with the Internal Labor Code, as well as circulars and management instructions.

Regardless of the sector and the tasks, employees must demonstrate their abilities and skills to achieve the objectives set related to the:

Achievement of results.
Proper execution of the duties assigned to them.
Proper planning and organizing work execution, within predefined deadlines.
Making proper and timely decisions.
Encouragement of a spirit of cooperation and teamwork through efficient communication and collaboration.
Demonstration of good ethical and professional behavior towards colleagues and stakeholders based on corporate values.

Principles of Professional Conduct

All employees must faithfully fulfill their duties towards the company and defend its interests with legitimate means. In this context:

Entrepreneurial ethics and entrepreneurial activity must be performed based on integrity, respect and justice.
All employees must contribute to the maintenance of business ethics, as a basic requirement for sustainable entrepreneurship and added value creation.
Fair trading with customers and suppliers.
Behave based on fair competition and meritocratic behavior.
Ensure compliance with applicable legislation.
Avoid activities and actions that constitute a conflict of interest by pursuing personal interest and benefits against the company’s.
vCorporate assets / corporate resources must be safeguarded and protected from all employees, against waste, damage, destruction and theft.
The high quality of the products and services provided must be ensured and maintained.
Preservation of professional and service confidentiality for all business affairs.

Relations with interested parties

Shareholders and investors It is the company’s concern to provide reliable and equitable information to shareholders and investors. Finally, the relevant departments will ensure that all necessary information is provided.
Governmental authorities The Company's management is committed to maintaining transparency throughout its range of activities. It imposes procedures that exclude all forms of corruption and prohibits the bribery and facilitation of any public or governmental executive.
Society It is the aim of the network to ensure the linking of all regions of the country to each other and to the outside world, which supports local communities, contributes to economic growth, to the promotion of cities and regions, and offers secure and affordable transport systems for more people.
Customers and suppliers Relationships with customers and suppliers are governed by transparency, respect, honesty and integrity.
The treatment of suppliers is equitable and impartial. The company has drafted a Code of Conduct for suppliers, which sets out the minimum standards of ethical and responsible conduct to be respected by cooperating vendors.
The relevant Code is based on the principles of the UN Global Compact, as well as relevant international standards, including the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, Children's Rights and Business Principles, the International Labor Organization (ILO) conventions, the OECD Guidelines for Multinational Enterprises, and related environmental practices.
Confidentiality Confidential information is either not disclosed or unavailable to the public. Examples include financial data, contracts, employees’ personal data, information about company development and strategy, information related to copyrights, research, customer / supplier lists, etc.
Every employee, both in the performance of his duties and in his dealings or relationships with third parties, is obliged to preserve the confidentiality of the information, as well as to prevent their disclosure to third parties.

Compliance and Validity of the Code

Compliance with the Code is the responsibility of all employees.
If an employee knows that a colleague intends to make a non-compliant act in accordance with the principles of the Code and does not act, he / she is equally responsible.
Management of violations of the Code is assigned to the relevant committee, which consists of the Managing Director, the Chief Human Resources & Corporate Affairs and the relevant Division Director.
The Code of Business Conduct is approved by the Board of Directors.
Compliance with the code is monitored regularly. It is the responsibility of the Chief Human Resources & Corporate Affairs to review and update the Code, whenever necessary. The Code of Conduct is monitored through internal reporting mechanisms.