Kyriakides Georgopoulos Law Firm is a law firm incorporated in Greece as a partnership pursuant to Greek legislation, registered under the Athens Bar Association number 080009 and with head offices at 28 Dimitriou Soutsou Str., GR-11521 Athens, Greece (hereinafter referred to as “KG”).
This Whistleblowing Policy (the “Policy”) sets out the procedures for reporting concerns, violations or suspected violations (hereinafter referred to as “Report” or “Reports”) within KG and is in line with the principles and requirements provided for by Directive (EU) 2019/1937 of the EU regarding the protection of persons reporting violations of Union law, as incorporated in Greece by Law 4990/2022, hereinafter called the “Law”.
By complying with the Policy
- The integrity, transparency, accountability and detection of potential violations of KG’s Regulatory Framework are strengthened.
- Appropriate and necessary measures are adopted to prevent and/or deal with potential incidents, hence protecting KG’s prestige and reputation and its associate lawyers and employees.
The purpose of this Policy is to encourage individuals, through rules that facilitate the submission of named or anonymous Reports of violations that they may perceive in the context of or in connection with their professional relationship with KG, under the conditions that are defined in this Policy.
In addition, it provides instructions on how to file a Report and sets out the corresponding procedures for receiving and reviewing Reports.
Reports within the framework of this Policy can be submitted by individuals who have acquired information or observed violations in specific areas of the EU law, as mentioned in Article 5 below, during their collaboration with KG or on the occasion of it:
- All lawyers of KG, including, but not limited to, Partners, Of Counsels, Advisors, Associates, Trainees and Apprentice Lawyers,
- All employees, whether full or part-time under open-ended or fixed-term employment contracts, former employees, retirees, those working with KG as freelancers, prospective employees,
- All suppliers providing services to KG,
- Third-party legal and natural persons connected to the above (e.g. witnesses, relatives etc.), who potentially may face repercussions in connection with a submitted Report,
hereinafter referred to exclusively for the purposes of this Policy as “Whistleblowers” or “reporters”.
4. Named or Anonymous Report
KG has established internal communication channels, as stipulated in Article 6 of this Policy, so that potential Whistleblowers can submit their Reports either named or anonymously.
However, KG encourages reporters to submit named Reports, as this enables the process of informing the Whistleblower about the progress of their Report.
Whistleblowers, who initially reported anonymously, but were later identified, are protected from retaliatory measures, provided they meet the conditions specified in Article 11 of this Policy.
5. Categories of Violations
The Report should be submitted for the sake of the public interest and fall within the scope of the Law, specifically in one of the following areas:
aa) Public procurement,
ab) Financial services, products, and markets, as well as the prevention of money laundering and terrorism financing,
ac) Product safety and compliance,
ad) Transportation safety,
ae) Environmental protection,
af) Protection from radiation and nuclear safety,
ag) Food and feed safety, as well as animal health and welfare,
ah) Public health,
ai) Consumer protection,
aj) Protection of privacy and personal data, as well as the security of network and information systems,
b) Violations affecting the financial interests of the Union (Article 325 of the Treaty on the Functioning of the European Union (TFEU)),
c) Violations related to the internal market (Article 26(2) of the TFEU), competition rules, state aid, or ensuring tax advantages,
d) Violations of all internal KG Policies as well as of Policies that will be adopted by KG in the future,
e) Violations of the KG Suppliers Code of Conduct.
6. Submission of Reports
6.1 In order to facilitate the proper examination and evaluation of submitted Reports, KG establishes an internal channel for the submission of Reports and appoints Mr. Nikos Parthenios, Operations Manager, as the Whistleblower Investigation Officer, responsible for receiving and monitoring the Reports, hereinafter referred to as “WIO”.
6.2 Whistleblowers are encouraged to provide all available information, including the events that prompted the Report, specifying the date and nature of the incident, the name(s) of the involved party (-ies), potential witnesses, or other supporting evidence, including documents and locations.
6.3 Reports can be submitted as follows:
- Through the Company’s website at https://kglawfirm.gr/
- Via email to the WIO at firstname.lastname@example.org
- By mail to KG’s address 28, Dimitriou Soutsou Str., 115 21 Athens, to the attention of the WIO with the indication “Confidential”.
- In writing or orally directly to the WIO
· Through External Reports as described in article 10 of this Policy
A meeting with the WIO could also be scheduled in person, upon the request of the Whistleblower and within a reasonable timeframe (The meeting with the WIO is mandated by Law if this is the Whistleblower’s request).
7. Investigation Process
7.1 After a Report is submitted, the WIO conducts an initial impartial assessment to determine the scope of the investigation and whether the violation falls within the scope of the Law (Article 5 of this Policy).
7.2 The WIO may close the reported case when the Report does not constitute a reportable behavior according to the terms of the Law and this Policy, or when there are no serious indications of the alleged violation, or when the Report was false, malicious, or submitted abusively.
7.3 All Reports will be treated with objectivity, integrity, and confidentiality, according to the process outlined in this Policy. KG ensures that access to received Reports is restricted to authorized individuals handling Whistleblowing Reports.
7.4 If the submitted Report formulates objections against the WIO, the WIO registers the Report in the relative file and immediately forwards it to the National Transparency Authority (NTA) (article 10) as an external reporting channel, informing the Reporter.
7.5 In the case of a named Report, the WIO confirms the receipt of the Report within seven (7) days of its submission.
7.6 The WIO is responsible for investigating and monitoring the Report, requesting further information as needed, and keeping the Whistleblower informed of the progress of the Report. The Whistleblower will be informed of the outcome of the investigation within a reasonable timeframe, not exceeding three (3) months from the confirmation of the receipt of the Report or, if no confirmation has been sent, within three (3) months from the end of the 7-day period after the submission of the Report, according to paragraph 7.5 of this Policy.
7.7 The WIO provides all available information to the Reporters regarding the submission of Reports through the external channel, in accordance with Article 10 of this Policy. A Reporter who believes that their Report was not effectively addressed internally may resubmit the Report through the external channel.
8.1 The WIO will treat all Reports as confidential during the investigation and will take all appropriate security measures. The WIO will ensure the confidentiality of personal data and any information that may lead to the identification of the Whistleblower, the concerned individual, and any third party mentioned in the Report.
8.2 Personal data and any information directly or indirectly leading to the identification of the Whistleblower are not disclosed to anyone other than authorized individuals involved in receiving or monitoring Reports unless the Whistleblower provides explicit consent.
8.3 The identity of the reporter is protected unless the disclosure of identity is required by the applicable EU or local legislation within the context of investigations by national authorities or legal proceedings. In such cases, Whistleblowers are informed before the disclosure of their identity, unless such information would jeopardize the relevant investigations or legal proceedings.
9. Personal Data
9.2 The processing of personal data carried out in the context of investigating a Report takes place on the legal basis of fulfilling KG’s lawful obligation to establish and operate internal reporting channels and to take the necessary measures to monitor Reports, solely for the purposes of such processing.
9.3 Personal data not relevant to handling a specific Report will not be collected, and if collected, must be promptly deleted without undue delay.
9.5 The WIO keeps a record of each Report received for a reasonable and necessary period until the completion of each investigation or legal process initiated as a result of the Report against any person.
9.6 KG will not disclose Reports submitted under this Policy to any third party. However, it may forward information received in Reports to the competent supervisory and investigative authorities, which may be used as evidence in administrative, civil, and criminal investigations and proceedings.
10. External Reports
In certain cases, it may be more effective for the Whistleblower to report their concerns to an external entity. The official external entity is the National Transparency Authority (NTA), and the Report can be submitted:
- Through the electronic platform of the external channel of the National Transparency Authority: https://extwhistle.aead.gr/#/,
- Via email at: email@example.com
- In a sealed envelope marked “N. 4990/2022” or “Whistleblowing,” either in person or by mail to the central offices of the NTA (Lenorman 195 & Amphiaraou 10442, Athens)
- Through a personal meeting, arranged at the request of the Whistleblower, at 213-2129870 or the email address firstname.lastname@example.org
11. Protection and Support of Whistleblowers
11.1 Whistleblowers are entitled to protection under the conditions that:
- They had reasonable grounds to believe that the information reported was true at the time of the Report,
- The reported information falls within the scope of the Law,
- They followed one of the alternative solutions provided by law to report the potential violation (i.e., internal or external Reporting, or public disclosure).
11.2 KG prohibits retaliation against Whistleblowers, including but not limited to adverse treatment, dismissal, demotion, harassment, or any form of discrimination, for submitting a Report in accordance with this Policy.
11.3 Any Report submitted with intent or purpose to cause harm will be treated as a serious matter that may lead to disciplinary actions, following the relevant KG internal policies and regulations and the applicable provisions of labor law.
Last Updated 12/1/2024