Introductory Statement

PIRAIKI METALS SA is committed to achieving the highest standards of ethical conduct and professional integrity and to ensuring that it , its employees and third parties who may provide professional services on its behalf, act in compliance with all applicable laws of Greece and of the various jurisdictions where the firm’s services are rendered, to the extent that such laws are applicable.
To ensure compliance with these laws, we have adopted the following rules

Bribery & Corruption

a. We do not tolerate any form of bribery or corruption

b. We do not give bribes: We will never provide, offer or promise to provide or authorise or solicit anyone to provide, directly or indirectly, benefits of any nature to any individual (who works either in the public or the private sector) in order for such individual to proceed, in violation of his or her duties, to an act or omission (with the purpose to obtain or retain business or a business advantage).
We are also required not to confer any benefits on a third person, if we know or reasonably suspect that such person will offer such benefits as bribes. In any event, we do not consent to the commission of any of the above and we shall not provide assistance or counsel or mediation thereto.

c. We do not accept bribes: We will never demand or accept, directly or indirectly, for ourselves or for a third party, benefits of any nature or the promise thereof, in order to induce or reward improper performance in the form of an act or omission which arises from or conflicts with a person’s duties.
Furthermore, we assume an active role in supporting and promoting initiatives which enhance transparency and integrity in the public sector; we also oppose all forms of corruption of persons involved in the administration of public affairs and justice, particularly of judges and other adjudicators, members of the parliament, local representatives and politicians in general, and other relevant domestic or foreign officials.

Anti-Money Laundering

We are committed to ensuring that our business activities comply with the spirit as well as specific provisions of all laws and regulations for anti-money laundering.
SUMMARY

• We do not give or accept bribes.
• We will report suspect incidents or behavior.
• We are extremely careful when giving or receiving gifts.
• We always comply with national and, to the extent applicable, foreign legislation.
• We are committed to this policy and expect our partners and other business associates to do the same.