1. INTRODUCTION
This Code of Ethics reflects the general principles and values that determine the responsible business behavior and the ethical rules that all employees and partners of IAMEX S.A. they are expected to follow, as well as the commitments of the Company's Management towards its people.
The Code ensures that all IAMEX activities are conducted with integrity and business ethics, thus protecting its prestige and reputation, while creating the conditions for the company's further development.
The Code is addressed to and binds all IAMEX employees, regardless of their hierarchical level (e.g. Top Management, executives and employees) as well as partners and consultants who represent or operate on behalf of IAMEX, either through external assignment of services, or any other business activity. The content of the Code includes rules of acceptable behavior of employees towards third parties, natural or legal, private or public law, domestic or foreign, while exceeding compliance with the laws in all areas of IAMEX's activity, demonstrating its commitment to operate with integrity in every case.
Management Commitment
The Management of IAMEX S.A. operates with a sense of responsibility and consistency towards its employees. Investment in human resources is an integral part of culture and strategic achievement of business goals.
The Management of IAMEX S.A.:
• It is committed to the maintenance and further development of a safe working environment that promotes mutual trust, cooperation and recognition. • It promotes equal employment opportunities, adopting recruitment practices fully in accordance with the criteria and conditions provided by the applicable legislation. These criteria are based on the abilities, educational attainment and legal employment age of each person, regardless of sex, nationality, colour, sexual orientation, national origin or physical ability.• Operates in accordance with the fundamental principles of humane rights and supports efforts to achieve work-life balance.• Committed to ensuring the highest level of ethical and professional conduct and zero tolerance for illegal or irregular actions, which harm its prestige and reputation. • Provides its services with integrity and compliance with all applicable laws and regulations. Bribery is an illegal and unethical practice that undermines trust and competition and the Company shows zero tolerance for either active or passive bribery. any act or behavior that may deviate from what is appropriate. • Protects the personal data of employees, allowing their use only by authorized persons and only in cases where this is required by law for purposes related to the operation of labor relations and the business activity of IAMEX. • Ensures a safe, healthy and well structured work environment with worker friendly facilities providing all means of protection.
2. PROFESSIONAL ETHICS
In IAMEX S.A. professional ethics is a key factor in sustainable business development. The company's culture prohibits all forms of discrimination, bullying, violence and harassment and promotes ethical values such as integrity, transparency, meritocracy, responsibility and respect.
Anti-Discrimination Principle
The Company maintains a work environment that allows all people who work for it to develop their full potential, regardless of race, gender, marital status, sexual orientation, disability, age, political views, religious beliefs, nationality or nationality. Employees are required to treat all persons working or otherwise associated with IAMEX with care and respect. This means, among other things, that employees must refrain from any form of discriminatory behavior. In the event that an employee becomes aware of any conduct by another person working for IAMEX that violates this principle, they are required to report such conduct to the Compliance Officer.
Prohibition of violence in the workplace
Employee safety is our clear priority. IAMEX strictly prohibits its employees from making threats or participating in violent actions against their partners or any other person working with the Company. Any act of violence or threat in the workplace by or against any employee is prohibited. Employees are prohibited from carrying a weapon or any other object or substance that could cause harm to the workplace or company premises.
Anti-Harassment and Bullying Principle
IAMEX supports and promotes a work environment that respects, promotes and ensures human dignity and the right of every person to a working world free of violence and harassment. IAMEX will not tolerate offensive or abusive behavior in the workplace that creates an intimidating or hostile environment. Moreover the Company will not show any tolerance towards harassment of any person for any reason. In particular, IAMEX strictly prohibits sexual harassment, including unsolicited sexual proposals, requests for sexual favors and other verbal or physical behaviors that imply sexual discrimination.
IAMEX SA implements a Bribery Management System according to the ISO 37001:2016 standard. For more information, see the relevant Policy: P.30.7 Anti-Violence and Harassment Policy
3. MANAGEMENT OF INFORMATION
Management of Confidential Information
IAMEX employees must always make efforts to protect and preserve the Company's assets from theft, loss, destruction, neglect, waste and abuse. This category also includes confidential information, whether it is in oral, printed or electronic form. Confidential information may include, but is not limited to:
-All information relating to employees, including pay or benefits, personnel file and other personal information
-Company policies, procedures, mandates and work standards -Partnership and product launch timelines -Information about the product market, customers, prices, contractual terms and sales or marketing strategies -Information about the our suppliers and competitive activities-Confidential financial information of the Company and information of transactions with customers, financial service providers, or mergers and acquisitions.
The management of confidential information is a normal practice of our daily work. Disclosure of confidential information (except as required by law or regulation) is expressly prohibited. The information obtained must never be misused for personal, non-work benefits, or the benefits of third parties throughout their working relationship with IAMEX. The obligation to maintain confidentiality also applies after the termination of employment with the Company.
IAMEX SA implements a Bribery Management System according to the ISO 37001:2016 standard. For more information, see the relevant Policy: P.30.4 Fair Competition & Information Transfer Policy
Personal Data Management
In IAMEX S.A. we undertake and guarantee that the processing of personal data of employees, external partners, investors, customers and other natural persons who communicate with the Company is carried out by legitimate means and in a way that ensures respect for privacy, personality, of their freedom and human dignity, and in accordance with the current institutional framework (General Data Protection Regulation (GDPR), L. 4624/2019 etc.)
IAMEX implements every security measure for the protection of personal data and we ensure that corresponding measures are applied by those processing personal data on behalf of the Company. We manage all personal data adopting the basic principles of legality, objectivity and transparency, purpose limitation, minimization, accuracy, storage period limitation, integrity and confidentiality, accountability and oversight. We provide the subjects of the personal data we process with sufficient and comprehensible information about the processing of their data. We examine and, if provided for by the institutional framework, we promptly satisfy the requests of the subjects concerning the right of access.
We promptly and responsibly manage any breach of personal data such as unauthorized access, modification or destruction of data. Any employee who observes or suspects that a personal data breach may have occurred must report it to the Quality Manager.
4. FAIR COMPETITION
In IAMEX S.A. we believe in dynamic and fair competition and fully comply with the legislation on the protection of free competition and all relevant provisions of the law.
Competition law contains two main prohibitions: the prohibition on collusion between two or more undertakings, and the prohibition on the abuse of a dominant position (which can apply both to unilateral conduct and through agreements where an undertaking occupies a dominant role).
Violation of national competition laws can result in fines, civil liability for damages, and even criminal liability. It is the responsibility of IAMEX and each of its employees separately to comply with these guidelines.
IAMEX employees, regardless of hierarchical level, involved in commercial activities should not discuss or participate in any of the following activities that would violate the prohibition of concerted practice regarding:
• determining market prices, including the application of price caps, discounts or any other element of pricing, even discussing prices without necessarily fixing them • segmenting the market, such as dividing customers into groups, or geographical areas between competitors, or even fraudulent offers • agreements regarding investment or the limitation or control of production • the exchange of sensitive commercial information, for example, about business plans, customer relationships, product development or display and promotion strategies, current or planned offers • joint negotiations, joint selling or joint procurement • any other agreement that restricts competition, such as, for example, collective refusal to sell, any arrangement to avoid direct competition or joint action to exclude competitors or new entrants in the field.
IAMEX SA implements a Bribery Management System according to the ISO 37001:2016 standard. For more information, see the relevant Policy: P.30.4 Fair Competition & Information Transfer Policy
5. INTEGRITY OF FINANCIAL INFORMATION
IAMEX SA applies strict standards for the accurate, correct and complete observance of its financial data and reports and ensures transparency in its financial reports. All accounting records and supporting documents of the company must be accompanied by the necessary documents to demonstrate the validity, accuracy, completeness and efficiency of the transactions carried out. Those employees, due to the nature of their work, who keep records on matters related to the financial integrity of the Company, must ensure their accuracy and completeness. Cooperation with external and internal auditors must be efficient and effective. IAMEX employees and executives must, within the scope of their duties, transmit to the auditors accurate and true information about IAMEX's finances. IAMEX is committed to providing the highest standards of financial transparency when preparing annual and other reports. We do not establish or maintain unrecorded accounts, assets or liabilities, and we are consistent with all tax and other fiscal obligations.
IAMEX does not allow: • any false or misleading entry in our books and records. • the creation of any apparent or unauthorized fund, asset or entity for any purpose; • authorizing or making any payment with the agreement or understanding that any part is to be used for any purpose other than that described in the supporting documents. • the use of funds or assets for any illegal purpose, or • any acts of coercion, manipulation, misrepresentation or fraudulent influence on the Company's independent auditors
6. PROTECTION OF THE ENVIRONMENT
IAMEX SA proves its increased sensitivity to environmental protection issues by implementing, beyond the directives and laws, those practices that result in the reduction of the use of natural resources, the proper management of waste, the minimization of air pollution and the consumption of clean water and energy. The programs and initiatives of IAMEX to minimize our impact on the environment include: • Reduction of waste resulting from the development of activities. •Rational waste management by promoting recycling and reuse. •Energy saving and energy utilization.•Ensuring the good quality of the working environment in the context of the safety and health of the workers and also in the context of the protection of the environment. • Informing, training and raising awareness of the company's human resources on environmental issues. • Selection of its suppliers and partners based on environmental criteria.
7. ANTI-BRIBERY POLICY
IAMEX SA fully complies with anti-bribery laws and regulations and implements an Anti-Bribery Management System based on the ISO 37001:2016 Standard with detailed Policies-Procedures, measures and controls to prevent, detect and deal with bribery.
In particular, the Anti-Bribery Management System aims at the following:
-Compliance with the applicable legal and regulatory framework for combating bribery-Understanding the definition of bribery and its forms-Encouraging the reporting of any incident or suspicion of bribery through a complaint and report system-Awareness of employees and partners to recognize actions that linked to bribery-Protection of the company's reputation.
In this context, the employees of IAMEX S.A. owe:
- Not to offer or accept Bribery - To be transparent about their actions and interactions - To actively participate in maintaining a healthy and intact work environment - Not to promote personal interests and unfair advantages - Not to create or participate in conflicts of interest - Not to influence the wider professional environment for their own benefit - To make sure that all their actions cannot be misinterpreted, in the event that make public - Immediately report any violation or suspected violation of this Anti-Bribery Policy
For more information see P.30.1 Anti-Bribery Policy
8. CONFLICT OF INTEREST
A conflict of interest exists when the personal interest of an employee and/or partner hinders or opposes in any way, direct or indirect, the interests of the Company or appears to hinder or oppose its interests. duties of both the employees and partners as well as the executives of the Company, which affects their loyalty and integrity towards the Company or towards third parties, constitutes a conflict of interest. A case of this type of conflict may arise when an employee or partner of the Company has interests of a personal nature that make it difficult both his objective judgment and the efficient and "integrity" performance of his duties, or when an employee, partner and/or relative obtains inappropriate personal benefits due to the position held by the employee, partner in the Company.
Any action that may bring about a conflict between the employee's personal interests and those of the Company is prohibited by company policy. The Company requires its employees, partners, staff members to notify their supervisor or manager of any situation that could reasonably lead to the creation of a conflict of interest, in order to resolve it in a fair and transparent manner. Any action that may bring about a conflict between the personal interests of the employee - partner and those of the Company, is prohibited by corporate policy as it is contrary to the business values and principles it adopts.
IAMEX SA implements a Bribery Management System according to the ISO 37001:2016 standard. For more information, see the relevant Policy: P.30.6 Conflict of Interest Policy
9. TRANSACTIONS WITH HEALTH PROFESSIONALS - SPONSORSHIPS - GIFTS - DONATIONS
IAMEX SA fully complies with all regulations regarding its contacts and dealings with Healthcare Professionals including doctors, nursing staff, hospitals or medical center managers and any person who may procure, purchase, manage, recommend or use products that is traded by IAMEX S.A. The ultimate purpose of IAMEX S.A.'s interactions with Healthcare Professionals is to provide quality care products and services to patients and improve public health. There are many forms of transactions between the employees of IAMEX SA. and Healthcare Professionals, who advance medical science or improve patient care, including the following:
- Advancement of medical technology - Safe and Effective use of Medical Technology - Research and education
The laws and regulations governing contacts with Healthcare Professionals strictly dictate what constitutes acceptable contact, while the rules regarding financial support, payments and gifts in the context of professional conduct to Healthcare Professionals are particularly strict. IAMEX strictly adheres to the above regulations and additionally applies a strict and clear policy for any type of transaction with Healthcare Professionals.
IAMEX SA implements a Bribery Management System according to the ISO 37001:2016 standard. For more information, please refer to the relevant Policy: P.30.2 Policy for Transactions with Healthcare Professionals
Corporate Events
IAMEX SA can invite Health Professionals to its Corporate Events such as:
■Product and Process Specialization and Training Events
■Sales, Promotion and other Business Meetings
Corporate Events should comply with the principles as stated in the aforementioned Policy and the general criteria for events.
Product and Process Specialization and Training Events
Where deemed appropriate, in order to ensure the safe and effective use of medical technologies, treatments and/or services, IAMEX S.A. should provide training in the form of specialization in products and training in technical procedures to Healthcare Professionals. The Company should ensure that personnel participating in Specialization and Training Events in products and procedures have the appropriate expertise to conduct such trainings.
Sales, Promotion and other Business MeetingsWhere appropriate, the Company may organize sales, promotion and other Business Meetings where the objective is to discuss the features and benefits of the product and related services, to conduct contract negotiations, or to discuss the terms of sales. In addition, Sales, Promotion and other Business Meetings should also comply with the following stricter requirements:
■These meetings should, as a general rule, be held at or near the Health Professional's place of business
■Financial support for travel or accommodation to Health Professionals from the Company is not allowed, except in the case where the demonstration of non-movable equipment is necessary.
Event Participation Expenses
IAMEX is allowed to cover the participation costs of Health Professionals and specifically the costs for the registration, travel, accommodation and food of the participant at reasonable levels and on the condition that the Health Professional has received the relevant educational permit from his employer.
IAMEX is not permitted to facilitate or pay for travel, accommodation, meals or other expenses for persons invited by the Healthcare Professionals, or for any other person who does not have a legitimate professional interest in the information presented at the Event.
Hospitality - Entertainment
IAMEX can provide reasonable hospitality to Health Professionals in the context of Corporate Events and Educational Events Organized by Third Parties, however any hospitality offered must be proportionate to the duration and purpose of the Event and within a reasonable cost framework.
The term "hospitality" includes meals and accommodation and it is important that the Company differentiates "hospitality" which is permitted from "Entertainment" which is not permitted.
Gifts
IAMEX S.A. may occasionally offer inexpensive items as gifts to Healthcare Professionals in accordance with national and international laws, regulations and industry and professional codes of conduct in the medical technology industry.
Gifts should be of small value, provided on an exceptional basis and either related to the Health Professional's practice or given for the benefit of patients or serve a genuine educational function. Gifts must not be given in the form of cash or cash equivalents.
Donations
IAMEX SA in the context of social responsibility actions, it can support charitable organizations through a Donation of either money or property. However, it should be ensured that donations of a charitable and social nature will be offered to recognized organizations, after relevant research and evaluation, without any expectation of obtaining any business advantage or other preferential treatment in return.
Transparency of Transactions
Every transaction between IAMEX S.A. and Healthcare Professionals/Healthcare Organisations, must be transparent and comply with national and local laws, regulations or professional codes of ethics.
In countries where specific provisions do not exist, the Company should nevertheless maintain satisfactory levels of transparency. This can be achieved by written notification prior to each transaction, which fully discloses the purpose and scope of the collaboration, to the hospital administration or any other superior competent authority to which the Health Professional is subject.
10. VIOLATION OF THE CODE OF ETHICS
Consequences of Non-Compliance
Any person who violates a provision of this Code, an applicable regulation or Company Policy, or engages in illegal or improper conduct, will be subject to disciplinary action as provided by law or referred to in individual policies or Company regulations.
In certain cases, corrective action may also include referring a matter to a regulatory authority or law enforcement. In the case of external partners, it will be investigated and the termination of cooperation may be imposed.
IAMEX has zero tolerance for retaliation against people who seek guidance, raise concerns, or cooperate with an investigation. Any person who retaliates is subject to disciplinary action.
Report a Code Violation
Raising concerns about potential violations of this Code, a Policy or a regulation is vital to protecting individual and corporate interests and upholding our commitment to act with integrity. Each of us has an obligation to report any regulatory violation that we believe has occurred or may occur.
IAMEX takes seriously all reports of possible misconduct and in any case, the confidentiality of the report is ensured and a relevant investigation is conducted in order to determine any violation. For each violation, the required corrective measures and the relevant sanctions are taken, which are determined according to the nature of the violation, the applicable law and the employment/collaboration contracts.
Violation reports may be submitted confidentially and confidentially to the department head or Quality Manager.
To file a report, not all evidence or proof that a violation has occurred is required. Rather, we must act in good faith, provide all relevant information known to us, and not misrepresent information. If we believe a breach has occurred, we must retain all documents related to the breach and hand them over to the appropriate authority investigating the matter.
Protection for complainants
Persons who report an incident of violation of the Code, provided that this is done in good faith and in accordance with the provisions of this Code, are protected from any acts of retaliation or punishment, such as indicatively: • harassment, • behaviors or actions concerning dismissal, demotion, suspension of employment contract • discrimination and criminal acts - direct or indirect - which are recommended, threatened or are brought against the complainant
All employees are expected to be familiar with all policies of IAMEX S.A. For additional information or assistance, please contact the Company's Quality Manager and/or Human Resources Manager.
The General Manager