Whistle blowing policy

Introduction

The Company "Aegean Airlines SA" (hereinafter the "Company") establishes, maintains and applies basic principles and rules regarding the management of whistleblowing. 
The Whistleblowing Policy is revised upon approval by the Company’s Board of Directors.

Purpose

The Policy sets out the principles and framework through which the Company (and its material subsidiaries) receives, evaluates and investigates anonymous and non-anonymous reports related to serious omissions, irregularities and offenses brought to the attention of its employees and partners.

Management is committed to: 

• Zero tolerance for illegal and irregular transactions, as well as for transactions that have a negative impact on the brand and credibility of the Company, 
• Maintaining the highest level of ethics and professional conduct.

Legal framework 

The Whistleblowing Policy complies with the European Directive 2019/1937. 

Definitions

• Notification / whistleblowing: Disclosure in favor of the public interest. 
• Malpractice: May be inappropriate, illegal or negligent conduct by anyone inside or outside the Company. 

Scope of whistleblowing and obligation

The Whistleblowing procedure refers to all employees, customers and suppliers of the Company.
Anonymous and non-anonymous whistleblowing is valid for the following persons related to the Company: 

• Members of the Board of Directors. 
• Directors and Heads of Departments. 
• Company consultants. 
• Permanent and seasonal Staff. 
• Suppliers. 
• Customers. 
• Every third party has evidence and information about irregular / illegal acts that have already been committed or are about to be committed in the Company.

General principles

The policy is the means for ensuring the integrity, brand and reputation of the Company. It actively contributes to: 

• Risk Identification, 
• The adoption of appropriate corrective measures, 
• Maintenance of an environment characterized by integrity, trust and security for the employees and associates of the Company, 
• Transparency enhancement, 
• Revealing of incidents that raise suspicions of fraud, corruption, coercion or other violations. 

It is the non - negotiable principle of the Policy: 

• The protection of the anonymity and confidentiality of the personal data of the people submitting such reports, 
• The maintenance of the position or the future development of the existing employees of the Company. 

Field of application

A Whistleblow must be made on the condition of a firm and reasonable belief that an offense or misdemeanor has been or may be committed. The employees and partners of the Company are encouraged to disclose: 

• Offenses, 
• Cases of suspected illegal or irregular behavior, 
• Incidents of mismanagement, 
• Serious irregularities, 
• Omissions or violations in relation to the Company's regulations, policies and procedures, 
• Acts or omissions involving gross negligence, possible fraud or corruption, 
• Acts or omissions that affect the purpose and reputation of the Company, 
• Acts or omissions that conflict with corporate interests, 
• Violations or omissions that may lead to financial loss, 
• Acts or omissions that are contrary to the Company’s Code of Conduct, 
• Acts or omissions that endanger the safety of employees, 
• Acts or omissions of offering and accepting bribes, 
• Acts or omissions that are not in favor of environmental protection. 

Customer / passenger complaints are handled by the relevant department and are not included in this Policy. 

Anonymity protection

Anonymous notifications can be made through the respective electronic platform whose link is posted on the corporate website (https://app.incy.io/aegean-airlines/links/whistleblowing). 
In any case, the notifications are protected from any retaliatory actions, as is the identity of the complainant. 
The disclosures are communicated only to authorized executives, who are deemed necessary for the investigation of the respective cases and who will act within the limits of discretion and confidentiality. 
In any case, it is ensured that the person who notifies of any violation is protected from possible negative effects. Similarly, it is ensured that the people notified are protected from possible adverse effects if no breach is proven. Furthermore, in the event of a proven breach, people are protected against unintended adverse effects beyond the measures taken by competent bodies. 

Whistleblowing procedure

Notifications / whistle blows should include the following: 

• Events that raise suspicions / concerns with reference to names, dates, documents and locations. 
• Information that will help investigate the case. 

The written notification is sent for purposes of independence, to the Head of Risk Management and Regulatory Compliance, who is responsible for informing the members of the Whistleblowing Committee. 
Notifications must be made: 

• Via e-mail at whistleblowing@aegeanair.com, 
• Through the corresponding electronic platform, the link of which is posted on the corporate website. 

The Whistleblowing Committee is informed immediately of all notifications submitted by the Risk Manager and Regulatory Compliance department.
The Whistleblowing Committee makes an initial evaluation of the notifications / whistle blows and then assigns to the Internal Audit Department the further investigation, while in each case the Audit Committee of the Board of Directors is informed.
The Whistleblowing Committee consists of the Head of Risk Management and Regulatory Compliance, the Head of the Legal Department, the Deputy Chief Executive Officer and the Chief of Human Resources and Corporate Affairs. If the disclosure refers to a member of the Whistleblowing Committee, the member will be absent from the meeting and will be replaced.
The Whistleblowing Committee decides whether the notifications involve serious irregularities, omissions or offenses.
The Whistleblowing Committee minutes and the results of the initial and final investigation are submitted to the Audit Committee of the Board of Directors. 

Responsibilities 

Chief Executive Officer 
The Chief Executive Officer is responsible for ensuring that all notifications are dealt with fairly, objectively, independently, thoroughly and in accordance with the policy. 
Directors 
All Directors are responsible for ensuring that employees are aware of the policy and its implementation, but also for creating an environment in which employees can express their concerns, freely and free from the fear of retaliation. 
Employees 
Employees have the responsibility of notifying / reporting as well as raising concerns provided there is a reasonable belief that a malpractice and / or offense has occurred.