Code of Ethics

Objective

This text comprises Eurofilm ΜΑΝΤΖΑRIS S.A.’s Code of Ethics. This Code is notified to:

All personnel and
All interested parties,

via the website of our company.

Following are the basic operating principles of Eurofilm ΜΑΝΤΖΑRIS S.A.:

Respect for human rights
Compliance with labor legislation
Transparency against corruption in all forms of collaboration with clients/suppliers/audit entities including extortion and bribery,

Further:

Production of products with stable quality, safe for intended use

Respect for the environment

The last two principles are under warranty by the applied quality safety and environmental management systems. The policies are attached to the Annex.

Claims / complaints

Claims and/or complaints about all mentioned in this Code are placed by phone or email to [email protected].

For the company personnel, it is possible to complain and/or report (anonymously or by name) through reporting boxes in shared areas of the facility. All claims and complaints are managed with confidentiality by the management.

Principle 1 : Respect to human rights

Work of minors/children

Eurofilm ΜΑΝΤΖΑRIS S.A. employs people older than the legal requirements of the relevant legislation.

Non-discrimination

Eurofilm S.A. ensures non-discrimination on:

race,
religion,
color,
origin,
age,
disabilities and special needs,
political beliefs and,
gender or marital status.

Avoidance of harassment and violence

Eurofilm ΜΑΝΤΖΑRIS S.A. ensures that all employees are not subjected to any form of harassment or violence (physical, sexual, psychological, verbal etc.) during their work.

Principle 2: Compliance with labor legislation

Employment Relations – Employee Emoluments

Eurofilm ΜΑΝΤΖΑRIS S.A.’s relationships with employees, throughout their employment relationship from hiring (work, wage) to termination of employment (retirement, resignation, dismissal), are governed by applicable laws and the international standards of the International Labor Organization (ILO).

The selection and recruitment of employees is based on objective criteria, as well as principles and rules that ensure the transparent and objective selection of the candidate.

Employees are free to leave the company by resignation at any time, in accordance with the requirements of the applicable law.

Eurofilm ΜΑΝΤΖΑRIS S.A. complies with all applicable labor laws regarding working hours and permissions to absence (for all reasons) of employees, respecting the privacy of employees.

Payments are in respect of the job position, and always in accordance with applicable legislation.

Work shifts

Eurofilm ΜΑΝΤΖΑRIS S.A. strictly adheres to the applicable working hours legislation.

Eurofilm ΜΑΝΤΖΑRIS S.A. is opposed to all forms of forced or compulsory labor.

Safety and work performance

Eurofilm ΜΑΝΤΖΑRIS S.A. invests in improving infrastructure and working conditions, looking after the health and safety of its employees and partners at its premises, considering all applicable laws and Codes of Good Practice.

Seminars on hygiene and safety at work are provided to all personnel along with the necessary protective equipment.

The right to participate in collective actions

Eurofilm ΜΑΝΤΖΑRIS S.A. respects the freedom of association and workers’ union rights as recognition to the right of collective bargaining as defined by the applicable law.

Principle 3: Transparency against corruption in all forms of collaboration with clients/suppliers/audit entities including extortion and bribery

Suppliers

Eurofilm ΜΑΝΤΖΑRIS S.A. pursues stable partnerships with dependable suppliers based on mutual trust and compliance with the basic principles outlined in this Code.

Financial quotations are evaluated based on objective criteria. It is prohibited to provide or receive any illegal commissions, bribes or similar payments of any kind.

In such cases, the partner must inform Eurofilm.

Bribes

Eurofilm ΜΑΝΤΖΑRIS S.A. is against any form of bribery (direct or indirect) for business or financial gain. Eurofilm employees do not offer/receive any gift or payment that is or may be construed as a bribe.

In such cases, employees must immediately inform the Management.

Financial management

Eurofilm ΜΑΝΤΖΑRIS S.A.’s financial management is transparent. Personnel involved in collection, processing, and registration of the information, shall be responsible for the accuracy of the data.

Other principles

Protection of personal data

Eurofilm ΜΑΝΤΖΑRIS S.A. is particularly sensitive to personal data protection.

Processing of personal data by Eurofilm ΜΑΝΤΖΑRIS S.A. is governed by the principles of legality, objectivity and transparency, limitation of purpose, data minimization, accuracy, integrity and confidentiality of the data, as well as limitation of their storage period, subject to applicable law, including the General Regulation on the Protection of Personal Data (GDPR).

Eurofilm ΜΑΝΤΖΑRIS S.A. collects and processes personal data based on one of the following legal issues, and where appropriate:

(a) Processing is necessary due to a contract of which the subject is a party,

(b) Eurofilm ΜΑΝΤΖΑRIS S.A. is required by law to do so,

(d) Because the subject has consented to the processing of his data for a specific purpose and,

(e) For the protection and interest, essential to the life of a person.

The data subjects (employees, customers, suppliers, users of the Eurofilm website, etc.) are adequately informed by Eurofilm ΜΑΝΤΖΑRIS S.A. of matters relating to the collection and processing of their personal data (including for the purpose of processing, the recipients of the data collected, the time of their observance, the legal basis for processing, the rights of the subjects), as the applicable law provides. The data subjects are updated when their data are first collected and subsequently whenever requested.

Eurofilm ΜΑΝΤΖΑRIS S.A. informs and trains all personnel members in order to obtain complete education regarding their personal data, and its security and protection.

Requests regarding personal data issues may be sent to Eurofilm ΜΑΝΤΖΑRIS S.A. by post at the company’s headquarters (attention to Personal Data Officer) or by email to [email protected].

Confidentiality

Eurofilm ΜΑΝΤΖΑRIS S.A. personnel commits to not disclose or make available any of Eurofilm ΜΑΝΤΖΑRIS S.A.’s information that is classified or confidential (including customer information, affiliates, etc.) in the performance of its duties and in any manner whatsoever with third parties.

Classified or confidential is all information that is not disclosed or not available to the general public (indicative, financial, technical, pricing information, customer-supplier lists, contracts, personal data, takeover or merger plans, strategic goals, information on business development, etc.).

In addition, personnel must respect confidentiality on issues considered as classified or confidential by the existing legislation.

Classified or confidential information may also be information related to Eurofilm ΜΑΝΤΖΑRIS S.A.’s copyrights or patents.

It is the responsibility of Eurofilm ΜΑΝΤΖΑRIS S.A. personnel to safeguard classified and confidential information, regardless of the manner and reason for their possession and knowledge, and not to disclose it to people outside the business, including members of their family and friendly environment. This obligation exists throughout the duration of the employment relationship and after its termination for any reason.

ANNEX

QUALITY POLICY

Our vision in Eurofilm MANTZARIS S.A. is to sustain a leading position in the Greek market, been synonymous to high quality plastic films.

The Quality Policy of Eurofilm MANTZARIS S.A. aims to the complete customer’s satisfaction in all the transactions and to the continuous improvement of product quality to entirely meet the customer’s needs.

For this purpose, Eurofilm MANTZARIS S.A. cooperates with leading companies in Greece and abroad, inspecting the incoming raw materials, while operates under ISO 9001: 2015 Quality System and BRCGS Packaging Materials Global Standard developed to its needs and goals.

All of us, management and employees of Eurofilm MANTZARIS S.A. believe in the need for continuous improvement and are committed to the following goals:

The strict implementation and continuous improvement of the Quality System and Food Safety Management System according to ISO 9001: 2015 and BRCGS Packaging Materials Global Standard,
The monitoring of all the critical control points and of the prerequisite programs on food safety in order to ensure the sanitation and safety of our products,
The exact application of ISCC PLUS requirements for the production of products with certified recycled material,
The continuous training of personnel to ensure a high level of know-how and the awareness on the critical matters regarding the product quality and the requirements resulting from our certifications.,
The continuous modernization and exploitation of technology’s potential for more efficient and effective implementation,
Operation in compliance with Greek and Community legislation regarding our products and the environment,
The reduction of non-compliant products,
The endless increment of customer satisfaction,
The continuous innovation at the development of new products,
The development of quality and safety culture for the produced materials.

The achievement of these goals will help the company make a strong impression in the market, giving us, the Management and employees of Eurofilm MANTZARIS S.A., a sense of pride and satisfaction.

Issue Date: 06/04/2023

ENVIRONMENT POLICY

Through the development of ISO 14001: 2015 environmental management system, Eurofilm MANTZARIS S.A. recognizes the responsibilities and obligations towards the environment and the people, and is committed to:

continually improve its environmental performance and environmental management system,
comply with the environmental legislation,
protect the environment and prevent pollution,
conform with all requirements arising from its licensing.

With the development of the ISO 14001 environmental management system with the following scope:

DESIGN, PRODUCTION & SALES OF PLASTIC FILMS (MADE OF CONVENTIONAL, BIOGENIC, BIODEGRADABLE RAW MATERIALS).

PRODUCTION & SALES OF FILM PROCESSING PRODUCTS.

PRODUCTION OF PE PIPES.

the company identifies all environmental parameters related to its activities and develops processes and practices to continuously improve its environmental performance. Our environmental policy focuses on:

Energy conservation by developing a monitoring system for natural resource consumption.
Effective waste management, giving priority to waste separation during collection and to recycling.
High awareness of management and employees on environmental issues.
Continuous education and training of personnel on environmental issues.

This environmental policy is published, communicated, implemented and supported by every employee in the company.

Issue Date: 18/01/2021