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1 POLICY Title: Process Group: Process Owner: SUPPLIER CODE OF CONDUCT SUPPLIER / PARTNER RELATIONSHIP MANAGEMENT PROCUREMENT & LOGISTIC DIVISION Effective Date: Summary: This Supplier Code of Conduct describes the criteria that COSMOTE Romania uses to evaluate its suppliers in terms of Social Responsibility Issues. These criteria address Labor, Health and Safety, Environmental and Ethical issues. POSITION SIGNATURE Created by: Ionut Stan Process Management Manager Poly Paleogeorgou Process Management and Improvement Deputy Director Mihaela Ionita Legal Director Epameinondas Gardelis Procurement & Logistics Director Christos Christopoulos Information Technology Director Reviewed by: Costas Kapetanopoulos Marketing & Communications Director Epameinondas Karavas Human Resources Director Spyridon Spyropoulos External Business Affairs Director Nikos Choumis Sales & Customer Care Director Konstantinos Apostolou Financial Director Version: 1 Page 1 of 8

2 Approved by: Iskos Lampros Network Development & Operations Executive Director Stefanos Theocharopoulos CEO - General Director This policy has been acknowledged by the Internal Audit Department: Version: 1 Page 2 of 8

3 DOCUMENT HISTORY LOG Version Date Description of Changes Document creation & approval. Version: 1 Page 3 of 8

4 Contents 1) Scope ) Area of Application ) Access Rights ) Description ) Definitions Abbreviations ) Related Documents... 8 Version: 1 Page 4 of 8

5 1) Scope According to the «COSMOTE GROUP Code of Ethics» (Chapter 8. «Our conduct towards Suppliers & Associates» - «We respect our associates»), Cosmote states that: «We treat our associates and suppliers in all countries of operation with respect and transparency. We give potential suppliers equal opportunities to establish a professional relationship with COSMOTE by selecting them based on objective criteria. We trade in fair and reasonable terms. We expect our associates to implement best business ethics practices and not only to comply with laws and internationally established trade rules, but also to be socially and environmentally sensitive themselves.» Considering the commitment of COSMOTE Group and based on the Supplier Code of Conduct issued by COSMOTE Group, COSMOTE Romania, as part of the same Group, decides also to adopt the same set of core values and business principles for the evaluation of present and future suppliers of goods and services across the world, regarding Corporate Social Responsibility issues in the fields of Labor, Health and Safety, Environment and Ethics, as stated in this Supplier Code of Conduct. COSMOTE Romania reserves the right to reasonably change these requirements set out in this Supplier Code of Conduct. In such event, COSMOTE Romania expects its suppliers to accept those reasonable changes. The Supplier Code of Conduct is part of COSMOTE Romania supplier agreements. By signing a contract with COSMOTE Romania, a supplier agrees to comply with this Supplier Code of Conduct, as well. Furthermore, COSMOTE Romania suppliers are committed to take all necessary actions so that their sub-contractors comply with the obligations stated in this Supplier Code of Conduct. 2) Area of Application This Policy is applicable to Cosmote Romania and its Suppliers. 3) Access Rights Access to the document is public. 4) Description A. Labor Suppliers are committed to uphold the human rights of their employees and to treat them with dignity and respect, as understood by the international community. A.1 Freely Chosen Employment Suppliers shall not use any form of forced, bonded, compulsory, or prison labor. All work must be voluntary and employees are free to leave work or terminate their employment with reasonable notice. Version: 1 Page 5 of 8

6 Employees must not be required to lodge any government-issued identification, passports, work permits or deposits as a condition of employment. A.2 Child Labor Avoidance No person shall be employed, if his age is below the minimum age for an employment agreement (namely under the age of 16 years). Persons who are over 16 years old, but under the age of 18 years (hereinafter referred to as «Young Persons») shall not be employed for any hazardous work, or work that is inconsistent with their personal development, their health, safety, or moral. Young Persons shall not be employed at night. Young Persons shall not ne employed without the written agreement of the parents or, if case, of the legal tutor. Where Young Persons are employed, according to the provisions and the requirements of the relevant legislation, their best interest must be the employer s primary concern. The establishment and implementation of Policies and Programs by the Suppliers that assist in finding any child performing illegal child labor are endorsed and shall be taken into account for the purpose of their Assessment. A.3 Working Hours Studies of business practices clearly link employee strain to reduced productivity and turnover and to increased injury and illness. Working hours of employees must therefore comply with national laws and not be excessive. A.4 Terms & Payment Wages or salaries paid for a standard working week are to meet or exceed the minimum determined in national law. Wages or salaries shall not be paid in kind. Deductions from wages or salaries, as disciplinary measures, are not permitted. Fair and reasonable terms of employment are to be provided. Furthermore, employees are to be provided with understandable, written information about their employment conditions, before starting the employment. A.5 Humane Treatment Employees shall be treated with respect and dignity. Physical or verbal abuse or other harassment and any threats or other forms of intimidation are prohibited. A.6 Non-Discrimination Unlawful discrimination, including racial or sexual discrimination, is prohibited. Companies shall not engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status. A.7 Freedom of Association Suppliers must respect the right of employees to associate freely, form and join organizations of their own choice, seek representation, and bargain collectively, as permitted by and in accordance with applicable laws and regulations. However, basic employee rights to open communication, direct engagement and humane and equitable treatment must be respected even in countries where they are not given meaningful legal protection. Version: 1 Page 6 of 8

7 B. Health and Safety Suppliers recognize that the employees morale, the consistency of production and consequently the quality of products and services are enhanced by a safe and healthy work environment. Suppliers also recognize that it is imperative to identify and solve health and safety issues in the workplace. B.1 Occupational Safety Suppliers shall provide employees with a healthy and safe working environment, in accordance with international standards and national laws, including prevention and management of both employee exposure to potential safety hazards and occupational injury and illness. B.2 Facilities A healthy and safe working environment includes access to clean toilet facilities, drinkable water and, if applicable, sanitary facilities for food storage. In case Suppliers provide their employees with accommodation, it shall be clean, safe and meet the basic needs of employees. B.3 Physically Demanding Work Employee exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing and highly repetitive or forceful assembly tasks shall be identified, evaluated and controlled. B.4 Health & Safety Policy The establishment and implementation of a Health & Safety Policy by the Suppliers is endorsed and shall be taken into account for the purpose of their Assessment. C. Environment Environmental considerations are an integral part of COSMOTE Romania Corporate Social Responsibility objectives. Suppliers shall therefore recognize that environmental responsibility is requisite to supply world class products and services as well as for the society s general prosperity and adhere to national laws regarding the protection and preservation of the environment. Adverse effects on the community, environment and natural resources are to be minimized, while safeguarding the health and safety of the public. C.1 Pollution Prevention and Resource Reduction Suppliers shall persue and demonstrate continuous environmental improvements in various areas, including reduction of emissions, discharges, noise, waste, and reduction in the use of natural resources. C.2 Hazardous Substances, Wastewater and Solid Waste Emissions Suppliers shall comply with any applicable laws and regulations regarding: o prohibited or restricted substances. o the identification, monitoring and safe use, handling, transportation, storing, recycling, reuse and disposal of substances, that pose a hazard, if released to the environment. o the labeling of such hazardous substances. o the monitoring, controlling and the disposal of wastewater and solid waste generated from operations, industrial processes or sanitation facilities. Version: 1 Page 7 of 8

8 C.3 Environmental Policy The establishment and implementation of an Environmental Policy by the Suppliers, including procedures, clear targets and improvement programs regarding pollution prevention, resource reduction, safe utilization, handling, transportation, storing, recycling, re-use and disposal of hazardous substances as well as disposal of wastewater and solid waste, is endorsed and shall be taken into consideration for Supplier Assessment purposes. D. Ethics Suppliers must be committed to ethical conduct when dealing with employees, suppliers, and customers. D.1 Corruption, Extortion, or Embezzlement Corruption, extortion, and embezzlement, in any form, are strictly prohibited and may result in immediate termination of the co-operation with the specific supplier. D.2 Disclosure of Information Suppliers must disclose information regarding their business activities, structure, financial situation and performance, in accordance with applicable laws and regulations and prevailing industry practices. D.3 No Improper Advantage Suppliers shall not offer or accept bribes or other means of obtaining undue or improper advantage. D.4 Protection of Intellectual Property Suppliers shall respect intellectual property rights. Transfer of technology and know-how shall be done in a manner that protects intellectual property rights. 5) Definitions Abbreviations Word/ Phrase/ Abbreviation Definition - - 6) Related Documents Document Code Title Link Version: 1 Page 8 of 8