doValue Greece

Whistleblowing and Conflict of Interest

17 June 2021

We encourage our employees, associates, clients, debtors or other persons to report any case of misconduct or conflict of interest they may identify. We immediately investigate these reports with discreetness and confidentiality.

Our standards and principles

We are committed to meeting high standards and going about our business with professional integrity, honesty and transparency. Compliance with these standards and principles is monitored by the Regulatory Compliance Unit.

Zero tolerance

At doValue Greece we do not tolerate:

  • Fraud
  • Corruption
  • Violations of legislation
  • Money laundering
  • Actions that damage our company and the doValue Group

Role of the Regulatory Compliance Unit

doValue Greece’s Regulatory Compliance Unit:

  • Monitors the application of the Code of Conduct of doValue.
  • Identifies cases of potential conflict of interest, corruption, bribery or other unusual transactions.
  • Discloses and reviews cases.

In case of questions or doubts about handling such a situation or deciding on whether conflict of interest exists or not, a relevant request is submitted to Regulatory Compliance.

Regulatory Compliance rules on the case and issues an opinion on the existence or not of conflict of interest.

What constitutes misconduct

Incidents or cases that constitute misconduct or conflict of interest include:

Violations

  • Violation of the legislation or other regulation
  • Violation of the Code of Conduct of doValue

Illegalities, irregularities or unethical conduct

Forms of illegal, irregular, dishonest, unprofessional or unethical conduct, such as:

  • Theft
  • Embezzlement
  • Bribery and corruption
  • Conflict of interest
  • Money laundering
  • Misuse / destruction of assets
  • Misuse of confidential information
  • Moral / psychological / physical / sexual harassment
  • Attempt to commit fraud
  • Transactions or types of conduct that can be seen as indications of fraud or attempt to commit fraud

In case of questions or doubts

In case of questions or doubts about handling such a situation, a relevant request is submitted to Regulatory Compliance.

When there is conflict of interest

Our employees and associates must know, identify, manage and avoid situations that might give rise to conflict of interest. For example:

Personal, professional or financial interests

Conflict of interest may arise when personal, professional or financial interests of a staff member oppose:

  • the interests of our company or
  • the interests of key stakeholders, e.g. clients, debtors, shareholders, external associates, suppliers etc.

Such situations mainly occur:

  • when carrying out usual company activities
  • when employees make personal transactions

In case of questions or doubts

In case of questions or doubts about the existence or not of conflict of interest, a relevant request is submitted to Regulatory Compliance.

How we handle misconduct and conflict of interest reports

We investigate all the reports submitted to us with no exception. We strive to respond immediately to your concerns with transparency and confidentiality.

Named or anonymous reporting

Submit a report to the competent bodies of doValue, with or without your name:

doValue Greece, Attention: Head of Regulatory Compliance
27 Kyprou and Archimidous Streets
18346 Moschato, Attica

Discreet investigation

Every report we receive, either named or anonymous, is assigned to dedicated officers of the Regulatory Compliance Unit:

  • They examine all the information discreetly.
  • They assess the information on the basis of policies in effect.
  • They decide to take appropriate action whenever required.
  • They immediately notify interested parties about decisions that concern them.
  • They ensure proper compliance with decisions.

Confidentiality and privacy

We have processes in place to ensure the confidentiality and privacy of the reports we receive. We systematically monitor their proper application.

The identity of anyone who discloses information they consider accurate and true is kept secret. We ensure full protection against retaliation.

However, malicious reports constitute unethical conduct and do not enjoy protection and confidentiality.