STAR BALLS & TOYS S.A. has recognized that corruption and bribery constitute significant threats not only to society but also to the company itself, its partners, employees, and associates.

We have a duty to society, our employees, our partners, and the entities comprising the Public Administration to operate with integrity across all our activities and to communicate our expectations for reducing the risk of corruption and bribery.

Our adopted policy is one of “zero tolerance” toward corruption and bribery, and we are committed to operating in compliance with applicable legislation and best competitive practices.

Specifically, the company explicitly prohibits:

  • Bribery, whether it involves offering or accepting gifts, money, benefits, or services to influence decisions.
  • Abuse of power.
  • Any act constituting misuse of authority, embezzlement of resources, or unfair favoritism toward third parties for personal gain.
  • The use of corporate funds for improper payments to public officials or private entities to gain undue advantages.

In the event that an employee or any other stakeholder becomes aware of an incident of corruption or bribery, they are obligated to:

  • Immediately report any suspicious or illegal behavior related to corruption or bribery they may observe.
  • Cooperate with the authorities and relevant internal or external control bodies.

It is critical to understand and adhere to the principles outlined in this Policy, which define our requirements for combating corruption and bribery to:

  • Protect our reputation.
  • Act in alignment with our values and culture.
  • Comply with applicable legislation.

It is your responsibility to read and understand this Policy. Anyone who violates the requirements of the Policy and/or legislation related to corruption and bribery will be subject to appropriate disciplinary actions and/or criminal prosecution.

You are also responsible for reporting actions or incidents if you believe they violate the requirements of this Policy.

Affected Individuals – Who Is Covered?

The requirements of this Policy apply to the management of STAR BALLS & TOYS S.A. (hereinafter referred to as the “company”), employees (regardless of job position, duration, or employment relationship), collaborators, suppliers, and any other individuals (legal or natural) associated with the company.

What Is Corruption?

Corruption in companies refers to any illegal or unethical act committed by employees, managers, or associates aimed at abusing their power for personal or financial gain. Examples of corruption include:

  • Bribery: Offering, accepting, or requesting money, gifts, or other benefits to influence decisions or actions.
  • Embezzlement: Illegal exploitation or appropriation of the company’s funds or assets for personal profit.
  • Conflicts of Interest: When someone promotes personal or family interests at the expense of the company’s interests.
  • Abuse of Power: Using one’s position to gain illegal advantages or favor third parties.
  • Fraud in Procurement or Contracting Processes: Circumventing legal procedures for personal gain or to serve third-party interests.

What Is Bribery?

Bribery is the offering, promising, providing, accepting, or soliciting of an undue advantage of any value (financial or non-financial), directly or indirectly, in violation of applicable law, as an incentive or reward for a person to act or refrain from acting in relation to their duties.

Bribery also includes the request or acceptance of an undue advantage of any kind or the acceptance of the promise of such an advantage.

Bribery can take various forms, such as:

  • Cash payments or in-kind benefits.
  • Fake employment or “consulting” arrangements.
  • Political contributions, sponsorships, or donations.
  • Gifts, travel, hospitality, or expense reimbursement.

It is irrelevant whether:

  • The bribe is provided directly or through a third party.
  • It benefits the recipient or another individual.

A bribe can be financial or non-financial and may include the provision or acceptance of money, loans, contributions or donations, travel, employment offers, refunds, discounts, goods, services, or anything else that may be considered valuable. Gifts or entertainment can also be considered forms of bribery under certain circumstances. A bribe may also take the form of a “reward” and be paid after the improper performance of a relevant duty or obligation.

There must be no involvement in any case of bribery. For this reason, under no circumstances is the acceptance, offer, or promise of any item of value, financial or otherwise, to or from anyone who could influence the company’s activities acceptable. Special attention must be given in cases involving family members, relatives, or individuals connected to public officials and/or politicians.

Public Officials

Public officials are not only employees of any national, regional, local, or other government authority but also private individuals who temporarily act in a public capacity on behalf of or for any such government entity (such as an advisor to a company or agency in which the state holds an interest).

Gifts

The provision of gifts (in any form), either directly or indirectly, to a person in exchange for any advantage, influence, favorable treatment, or exertion of influence for the company’s benefit is prohibited.

Receiving gifts from a supplier is allowed only if the relationship of equal distance is maintained. Excessive or extravagant gifts that may give the impression of improper influence are not accepted. It must always be evaluated whether the gift received could be considered excessive or improper, or if it implies or entails any obligation. Gifts in the form of cash (of any value) are not permitted under any circumstances. Suppliers must never be solicited for gifts.

Meals, Hospitality, Travel, Entertainment

Meals and entertainment activities provided by suppliers are permitted only if the relationship of equal distance is maintained. It must always be assessed whether the meal or entertainment could be considered excessive or inappropriate, or if it implies or entails any obligation. Under no circumstances are meals or entertainment benefits to be requested.

Providing meals and hospitality to third parties by the company is permitted only if it occurs on a non-regular basis and solely in appropriate circumstances. In any case, their value must be reasonable and serve only legitimate purposes.
Proof of payment for meals and hospitality is governed by the company’s operational expense management rules. These payments will be made directly to the supplier.

The company will under no circumstances pay for or reimburse travel expenses for individuals where such a benefit could be considered bribery.


Charitable Donations, Sponsorships, Grants

The company may make charitable donations, sponsorships, and grants to local or regional organizations/associations, public or private entities, for support or assistance when required.

Under no circumstances will an organization or entity be supported if:

  • The organization/association lacks financial transparency.
  • The support could be diverted to an inappropriate recipient and linked to a benefit sought through the donation/sponsorship.

It must be clear that the proposed support is not a concealed way of providing personal benefit to a public official or political figure. Acceptable support may be deemed unacceptable if it is provided or agreed upon during a time when the company is seeking to undertake a project or generally gain a benefit from a public authority linked to the request.

In all cases, sponsorships and donations to public entities will comply with the requirements of applicable legislation, and the company will not seek any return benefit from the recipient of the sponsorship or donation.

Political Donations

Donations to political parties are not permitted.


Cooperation with Third Parties

The company may be held accountable for acts of bribery committed by third parties acting on its behalf or by employees or other individuals providing services for the company.
It must never be permitted or requested for any third party to bribe anyone, nor to accept a bribe from anyone. Additionally, third-party processes that may conflict with this Policy must not be overlooked.


Suppliers, Partners (Third Parties)

Third parties are strictly prohibited from carrying out, promising, or authorizing, directly or indirectly, the improper payment of money or the provision of any valuable item to public officials to induce them to take any action or make any decision to gain an advantage.

While conducting activities related to the company, third parties must understand and comply with anti-bribery legislation requirements.

If a third party or someone acting on their behalf in connection with work for the company receives or perceives a request or demand for a bribe related to work for the company, they must report it immediately to the company’s management before taking any further action.

When entering into business agreements with third parties, the company ensures the following regarding anti-bribery measures:

  • Compliance with the requirements of this Policy.
  • The third party has no convictions for bribery or corruption cases.
  • The establishment of a process for monitoring transactions.
  • The third party has a good reputation in relation to their business activities.

Cases Where:

  • The third party is recommended to the company by public officials or political figures.
  • The third party has relatives or commercial ties with public officials or political figures.
  • The third party requests unusual payment terms, such as payments to an account that is not in their name or payments to a country other than the one where they are based.
  • The third party is reputed to bypass standard business channels, particularly for activities related to public sector dealings.

Such cases must be thoroughly examined, and if collaboration is decided, additional measures should be implemented to safeguard the company against bribery incidents.

The nature, type, and scope of due diligence conducted on the company’s suppliers and partners before entering agreements depend on the risk level of potential bribery.

The selection process for suppliers/partners, contract signing, and performance monitoring are governed by the company’s internal procedures as they apply at any given time.


Participation in Tenders

The company aims to secure and execute as many public and private contracts as possible, in alignment with its available resources, to complete projects according to specified requirements. To achieve this goal, the company adheres to the following principles:

  • Full compliance with the applicable laws governing tender participation.
  • No effort to obtain privileged information from public officials for its advantage in relation to the tender. Communication is conducted in accordance with applicable legislation.
  • The company will never collude with other industry competitors to set the offered prices in tenders.

If an ethical, professional, legal, or any other type of issue arises that undermines the integrity and dignity of the company and its employees, the company’s management must be informed immediately.


Recruitment of Personnel

Due diligence will be conducted during the recruitment of new employees to determine, as far as possible, whether the individual may be susceptible to offering or accepting bribes. Under no circumstances should new personnel be hired if there is suspicion that the individual might attempt to engage in bribery.


Employee Compensation System

Employee compensation is determined through individual employment contracts. Any additional compensation provided by the company beyond the agreed amount will strictly pertain to the employee’s additional work.


Licenses and Inspections by Government Authorities

In all cases where a license is required to meet the company’s needs, all legal procedures must be followed. Any attempt to influence the result or the timeframe of the license issuance outside the legal and ethical framework is not acceptable.

Payments or any other benefits must not be provided to public officials to avoid inspections, secure the assignment of new tasks, influence the outcome of an inspection/report, or avoid fines.


Money Laundering

Money laundering activities are contrary to the principles and values that govern the company.

The company complies with all laws and regulations regarding money laundering and acknowledges its responsibility to report any suspicious behavior to the relevant Greek authorities.

Conflict of Interest

Every employee, in the context of avoiding conflict of interest situations, is required to:

  • Immediately report any personal interest or interest of a relative that could create a conflict with the company’s interests, hinder their ability to properly perform their duties, or influence their decisions.
  • Disclose any familial relationships with suppliers to prevent potential or possible conflicts of interest.
  • Avoid creating mutual or shared financial interests with the company’s suppliers, as this could result in a conflict of interest.
  • Neither lend to nor borrow money from the company’s suppliers.
  • Treat suppliers objectively, avoiding preferential treatment of certain individuals or discouraging collaboration with others without a valid objective reason.
  • Not exploit their position to secure advantages or other benefits for themselves or their relatives from suppliers.
  • Report if they have relatives or business connections with public officials related to their assigned duties or political figures.

The above disclosures/reports by the employee must be made not only upon hiring but also whenever a change occurs.


Complaints

Employees of the company are encouraged and obligated to immediately and without delay report incidents or suspicions of bribery to the Anti-Bribery Committee and/or to appropriate public authorities, such as the National Transparency Authority.

If an employee is unsure how to handle a situation that is contrary or potentially contrary to this Policy, they should always seek guidance from the Anti-Bribery Committee.

No employee will suffer harm or penalties for raising concerns about bribery or corruption or for refusing to give or receive bribes. However, they have the right and the ability to submit their complaint anonymously.

The company’s Anti-Bribery Committee is authorized and responsible for investigating all bribery-related complaints submitted to it, regardless of their source (employee, beneficiary, public authorities, suppliers, or other third parties).


Compliance with Laws

A fundamental principle of the company is compliance with and respect for the applicable laws, regulations, and provisions of Greece and the European Union. It is the individual responsibility of partners’ representatives and employees to avoid any activity that could involve the company in unlawful conduct.

The company systematically monitors legislation and modifies its related procedures and practices as required, ensuring that all involved parties (partners’ representatives, employees, and third parties) are informed accordingly.


Record Keeping

The company maintains financial records and applies appropriate internal controls that demonstrate the purpose behind each operational expense payment.

All accounts, invoices, and other documents and records related to financial transactions must be completed and maintained with strict accuracy and completeness. No account should be kept off-the-books to facilitate or conceal improper payments.


Monitoring and Review

The effectiveness of this Policy’s implementation is regularly monitored and evaluated for its appropriateness and adequacy. Any necessary improvements will be implemented as soon as possible.

To ensure compliance with this Policy, applicable laws, and the company’s guidelines, periodic audits will be conducted. These audits may be performed internally or assigned to external auditors.

Summary

The company does not tolerate any form of corruption and, under no circumstances, will it provide, offer, or agree to provide, approve, or request someone to provide, directly or indirectly, benefits of any kind to individuals, so that these individuals act or fail to act in violation of their duties. Similarly, the company will never seek or accept, directly or indirectly, benefits of any kind or their promise to provoke or reward improper behaviors in the form of acts or omissions arising from or conflicting with someone’s duties.

This Policy applies and remains unchanged, regardless of the types of partnerships developed with third parties.

The Policy establishes the framework within which all partners’ representatives and employees must comply, regardless of whether customs or practices dictate otherwise. All involved parties are responsible for understanding and adhering to the requirements of the Policy as it applies.

Deviations from the Policy, whether intentional or unintentional, may lead to disciplinary actions, which could result in dismissal for serious misconduct as well as the criminal prosecution of the person involved, in accordance with applicable law.

Compliance with the company’s Policy requirements is continuously monitored and conducted either by appropriate internal personnel or by external control entities.

The company’s Anti-Bribery Committee is available to any interested party regarding the submission of complaints or the provision of clarifications and advice concerning matters related to this Policy.