Anti-Bribery Policy

Corruption hinders economic growth as it can undermine fair competition and damage trust in a company or individual. In KM BROKERS P.C. tackling all forms of corruption constitutes the top priority, therefore the company decided to design and implement an Anti-Bribery Management System in accordance with the requirements of the International Standard ISO 37001:2016. The Company’s Anti-Bribery Management System covers all corporate activities related to the provision of brokerage & investment consulting services and has been designed in accordance with the needs and objectives of the Company and the Legal and Regulatory Requirements of the current Greek and Community legislation.

Promoting a culture of ethics and integrity is a key factor in maintaining the trust of customers, stakeholders and society. The company is committed to promoting a culture of integrity throughout its business and to communicating its expectations to reduce the risk of corruption.

The overall objective of the company is to satisfy the needs and expectations of its customers to the maximum extent possible and to reduce the risk of corruption. It therefore establishes measurable targets for corruption, seeking to:

  • Improve the organisational structure, through the clear definition of powers and responsibilities.
  • Comply with the laws and regulations related to its activity either directly (service activity) or indirectly (producer groups/suppliers).
  • Improve Internal Communication, through the identification of the interaction and interdependence of the Company’s processes.
  • Continuously improve the Anti-Bribery Management System and the operation of the Company through the effective use of the following tools:
  • Definition and review of anti-bribery targets.
  • Administration Review
  • Internal Inspections
  • Corrective Actions
  • Systematic analysis of data from the Archives.

The company aims to prevent bribery and corruption through:

  • prohibition of facilitating payments, even when permitted by law.
  • compliance with all anti-bribery and anti-corruption laws in force in each country where the company operates, and the same requirement for contractors
  • compliance with all global policies aimed at preventing, directly or indirectly, a risk of corruption
  • conducting due diligence against risk-based bribery on third parties before they become involved in the company’s activities.

To promote a culture of ethics and integrity, as well as to comply with all applicable laws and regulations against corruption and bribery, the company applies a comprehensive set of policies and standards that set out clear rules with which all its employees and, where applicable, third parties must comply. Beyond exposing the company to risk, corrupt employees may be personally subject to civil and criminal penalties, which include heavy fines and imprisonment. In addition:

It is forbidden to the employees of the company:

  • to give, promise to give or offer anything of value to any person for the purpose of influencing any action or decision, especially when interacting with government officials. This prohibition also applies to indirect corruption, i.e.

actions taken by third parties in the name of or on behalf of the company.

Items of value may include, but are not limited to: money, gifts, entertainment, hospitality and meals, travel expenses, services, employment offers, loans, donations or contributions, any transfer of value, even symbolic;

  • receive remuneration from a provider or client of the company;
  • have a financial interest or relationship with a competitor, customer or provider of the company, or other third party engaged in business with the company;
  • participate in the direct or indirect acquisition or possession, directly or indirectly, of any interest in the form of real estate or assets of any kind with a view to selling or leasing them to the company;
  • participate in any external activity to such an extent as to raise questions about their ability to devote adequate time and attention to their duties;
  • interact with a relative who works for or has applied for a job with the company, a competitor, provider or customer of the company;
  • make purchases of goods or services on behalf of the company from a relative or a company in which a relative has an interest;
  • receive items of value. Accepting a gift may create a sense of obligation for the recipient, possibly undermining the objectivity of his or her decisions, and may be perceived as a gift with the intention of corrupting him or herself or another company employee.

Within the company, employees are required to:

  • disclose any actual or potential conflict of interest before engaging in the transaction, activity or relationship giving rise to the circumstance referred to;
  • disclose actual or potential conflicts of interest as part of the recruitment process;
  • disclose any actual or potential conflict of interest annually, in the case of High Risk Exposure Employees, i.e. front-line managers and all employees of the company who are regularly involved in the creation of contracts, purchase, sale or rental of services, materials, property or products;
  • refrain from serving on the board of directors of any customer, provider or competitor of the company. Participation on external boards, outside the professional duties of the company’s employees, is permitted, subject to approval, only for members of the Executive Committee and must be limited to the provision of services consistent with their duties to the company,
  • ask the relevant Department Head or System Manager how to handle a conflict of interest, rather than relying solely on their interpretation as their personal assessment.

Each employee is responsible for his or her own work and it is imperative to contribute to the management against bribery and the achievement of the set objectives. For this reason, all employees, depending on their responsibilities, are informed about the Anti-Bribery Management System and act demonstrably in accordance with the established rules.

Any person (employee, customer, partner) is encouraged to raise anonymous concerns about any issue of bribery or suspected unfair practices at the earliest possible stage by contacting the company at or at 30 210 36 40 100, +30 210 36 40 108 or by mail at 18 Kanari Street, 10674, Kolonaki Athens, to the attention of the Complaints Committee.

Processes, flows and actions that do not guarantee the fulfilment of the objectives set are immediately stopped by the persons responsible, root cause analyses are carried out and the required improvement measures are defined.

This Anti-Bribery Policy is communicated to staff, is available to all interested parties and is reviewed periodically by the Company’s Administration.

Athens, 01.04.2023
Version 1/ 01.04.2023