HYPERSYSTEMS SA, hereinafter referred to as “COMPANY”, throughout its business activities, since its establishment in 1985, has implemented business practices governed by integrity, reliability, fairness, transparency, fair dealing and full compliance with applicable law. .

This Code of Conduct, hereinafter referred to as “the Code”, expresses its commitment to continue to apply the general principles and rules that must govern its administration to those who deal with it, and in particular to employees, partners, suppliers and customers. of the company, society and environment, as well as the legal and ethical obligations that must characterize the professional conduct of all employees of the company.

The Code addresses, engages and engages both existing employees of the company as well as new recruits who recognize and accept the Code, and defines the scope of the company’s partnership with existing and future customers, suppliers and other affiliates.

The Code is approved by the Company’s Board of Directors and is revised whenever appropriate. The Code is posted on the Company’s website. In its review, the Company considers relevant amendments to laws, regulations, best international corporate governance practices, as applicable, as well as any recommendations by competent authorities.


Business ethics is not just about adhering to legal, regulatory, professional and business standards, but, above all, developing business action within rules of fairness, integrity, honesty and respect. All employees must demonstrate appropriate professional and ethical conduct to their colleagues and associates in accordance with corporate values. At the same time, they must contribute to maintaining social cohesion and prosperity in order to achieve long-term and sustainable business.


Compliance and compliance with either national or EU legislation in any field of activity is a fundamental principle and obligation for all employees. The Code is based on international and domestic best practices and is compatible with the laws and regulations, as applicable, with respect to Greek public interest entities.

Employees are not required to know in detail every applicable law and regulation. It is, however, important to be aware of this information that will lead them to seek guidance from their supervisors and in any case a competent body of the Company.Employees of the Company are obliged to act ethically in every aspect of their business and must maintain high standards of honesty, honesty, honesty, credibility and integrity. In addition, they must adhere to the statutory rules of procedure and the statutory standards, which may lay down stricter requirements than required by law.


“Conflict of Interest” exists when the personal interest of an employee interferes or interferes in any way or appears to interfere with or interfere with the Company’s interests. Every employee must promote his / her corporate interest, and not prefer personal, private or external interest and benefit in the performance of his / her duties, as such conduct constitutes an unacceptable conflict of interest. In this context, it shall avoid any activity of its own financial interests or other personal benefits in the performance of its duties, including direct partnerships with relatives or partnerships with customers and suppliers with a parallel professional activity.


All employees must conduct fair, honest transactions with customers, suppliers and competitors, conduct themselves in a fair and honest manner and always in line with fair competition rules, avoiding any unethical or illegal business practices. It is prohibited to steal proprietary information or to circulate business secret information obtained without the consent of the owner, or to cause such disclosures, both by current employees and employees of the Company and by former employees of the Company. Employees of the Company may not be unfairly exploited in any way, either by manipulating, concealing or exploiting privileged information, or distorting facts, or through other illegal business practices. An employee of the Company is not permitted to engage in price negotiation, bid rigging, agreements on sales shares and market or customer sharing, and generally on any unlawful activity or unethical practices that impede healthy competition.


Throughout its range of activities, the Company ensures, among other things, the principles of transparency, trust, honesty and integrity. Thus, it ensures that its financial data and reports are accurately, accurately and comprehensively maintained. Its financial statements are prepared and published in accordance with the relevant legal framework. In its relationships with its suppliers, partners and customers, it ensures that it maintains transparent transactions and makes decisions based on objective criteria such as the quality of the products and services provided, good and immediate customer service, financial solvency, timeliness consistency in the delivery of products and services, compliance with the basic environmental and safety principles, the existence of appropriate technological infrastructure according to the Company’s needs, and the experienceand the integrity of a supplier. It is self-evident and non-negotiable that the Company discontinues any trading relationship if it finds that any of its suppliers or subcontractors practices illegal or non-competitive practices. In the context of its cooperation with the State, the Company applies the same principles accordingly.The main purpose of transparency is strictly prohibited from providing or receiving any illegal commissions, bribes, or similar payments of any kind, as well as the personal facilities of any public or government official.


The Company condemns and shows zero tolerance for any kind of corruption or corruption that takes place within the scope of its employees’ professional activity.In this context, it is prohibited to provide or receive illegal commissions, bribes or the like of any kind and any employee must refrain from any act, which may even be considered subject to the circumstances mentioned herein. It is also forbidden to adopt, reinforce or disguise corruption, sabotage and complicity behaviors. Not

anyone acting on behalf of the Company is permitted to offer or provide (directly or indirectly), any form of unfair advantage or other advantage to a natural or legal person in the Private or Public Sector for the sole purpose of securing, maintaining or expands business. It must therefore refrain from accepting any such advantage in exchange for any preferential treatment associated with it. Inappropriate benefits include gifts, payments, favorable treatment or treatment, or other benefits to the recipient, including employment contracts or consulting contracts with persons or partners in a close family or friendly environment. Any case of breach of these obligations does not merely constitute a breach of Company policy terms, but entails civil and disciplinary sanctions, and may result in civil or criminal action under national and EU law.


The Company maintains records in which all information created and used is kept and stored within and for the purposes of its business. At the same time it maintains records containing personal data of its customers, employees and associates. All non-public (not known to the public) information concerning the Company, the Company’s customers or its affiliates and suppliers is called “inside information” and is protected by confidentiality and confidentiality as an asset of the Company. The Company commits itself to the safe and lawful management of its records, to safeguarding them by applying the necessary technical and organizational security measures in compliance with the applicable legislation, to keep them accurate, timely and minimized to the extent required by its contractual or legal framework. relationship with the person concerned, and not to make or disclose confidential or confidential information to the general public. The company shares the sensitivity and needs of its customers to safeguard their data and places a high priority on protecting their personal and financial information. It thus safeguards strictly any security or confidentiality of any information provided by customers and protects this information by applying procedures and systems that prevent any leakage.


The members of the Management of the Company and the Supervisors on a case-by-case basis are responsible for designing, establishing and managing appropriate policies for safeguarding the Company’s assets. Assets include real estate, machinery, computers, software and generally fixed equipment, company information, Company reputation, customer service, trademark and brand. All employees have an obligation to protect the Company’s assets and resources and to exercise caution when using any type of asset and to draw attention to avoiding waste, damage, destruction, or theft of Company assets. This prohibits inappropriate use of the company’s IT systems, as well as overuse for its own benefit, exchange of copyrighted material, and finally installation or download of unauthorized software.


The use of trademarks and other intellectual property or intellectual property products, and irrespective of any legal registration, which are a valuable asset of the company should always be done in an appropriate manner. Such elements include trademarks, logos, copyrights, inventions, patents, creations such as software, Company standard practices, form of official documents, and any employee work product. A third party should never be allowed to use the trademark or other intellectual property without proper authorization. In addition, the trademark must never be used in a derogatory, defamatory or offensive manner. Likewise, the Company becomes responsible for the proper use and protection of the intellectual property rights of third parties in cases where their use is granted by the Company, avoiding any use beyond their purpose.


The Company is committed to ensuring profitable, stable and long-term partnerships with its customers and suppliers based on the principles of honesty, transparency, mutual respect and impartiality. It is available to our customers by providing them with the help they need to achieve their goals, providing them with top quality products and services and in full compliance with applicable law.

Regarding its suppliers, the Company recognizes the critical role they play in their business and expects them to behave ethically. In particular, their compliance with applicable law and the observance and observance of such principles as those contained in this Code of Conduct are sought. Suppliers are selected on the basis of fair and merit-based criteria, such as the quality of the products and services provided, pricing policy, timeliness of delivery of products and services, as well as the experience and integrity of each supplier.


The Company aims to ensure and maintain a high quality of service. It is a basic commitment of the Company and therefore of all employees, satisfying the needs of the customers, providing them with quality products and services.


The Company with respect to human dignity protects the personal data of its staff and its former employees, customers, suppliers and associates as well as any natural person who deals with it. For this purpose, only the information mentioned in the CV of the personnel and associates required by the Authorities or those that contribute to the effective operation of the Company is requested and retained.Information of this nature, and in particular the personal data of the subjects, is considered confidential and only authorized personnel have access to it. The Human Resources Department maintains an individual file, which records the required data such as past service documents, identification and certificates of study, vocational training and qualification, while for each other the identifiable information necessary for the execution of the contract is maintained. fulfillment of obligations of the Contracting Parties to tax authorities, social security institutions and other public bodies on the basis of labor, insurance and tax clock legislation.The type and manner of keeping such records and records are determined by the Company’s Management and are strictly in accordance with the applicable law, and any affiliate or employee has access to their personal records and personal data.


The Company is committed to ensuring the development of working relationships that promote mutual trust, constructive cooperation, two-way communication and recognition, while promoting the fundamental principles of the International Labor Organization Declaration. It ensures equal rights and opportunities for its employees, promotes team spirit and co-operation, assigns, rewards, and rewards its employees on the basis of their formal and substantive qualifications for the needs of their work, without discrimination on grounds of race, , ethnic origin, nationality, color, gender, identity, age, nationality, sexual preference, marital status, disability, or any other characteristics protected by law. It encourages and recommends all its employees to respect the diversity of each employee or supplier or customer and not to accept any behavior that offends the dignity of the individual, discriminates in any form or results in forced labor. It prohibits the sexual or other harassment or exploitation of its employees in the workplace and generally in the workplace.


The Company recognizes that its Corporate Social Responsibility is just as important as any other aspect of the business of a modern company that is sensitive to today’s problems. For this reason, it has adopted practices in accordance with applicable laws and regulations on sustainable development. It recognizes its obligation to operate safely, protect the environment and support the local communities in which it operates. It invests and actively contributes to improving the quality of life for everyone, inside and outside the business.


The Code of Conduct is generally applicable to any person providing services to companies, without any exceptions or exceptions. It is the responsibility of all employees of the Company to read and understand the Code, to seek guidance when required and to comply with its spirit. They should not exhibit behaviors that could harm the reputation of the Company. They are required to safeguard confidential information, protect its assets and avoid conflict of interest situations.Transactions with all public authorities, customers, suppliers and investors should be integrity-based and based on honesty and honesty. Employees who, in the performance of their duties, deal with suppliers and customers, must comply with the Code and indicate their compliance with the rules, if necessary. All employees are required to report violations, or possible violations of the Code, to the Company’s Chief Executive Officer. Management members have an increased responsibility for adhering to the Code. If members know that an employee intends to take a prohibited act and fail to take action, they will be equally responsible to the employee.


The management of the Code violations is entrusted to the members of the Company’s Management. Any infringement or concealment attempt will be the subject of an investigation. The Company seeks disciplinary sanctions for any breach of the Code. Depending on the gravity of the infringement, it will take disciplinary action in accordance with applicable law, applicable rules of procedure and Company procedures.


The Code of Professional Conduct is approved by the CEO of the Company. It is the responsibility of the Company’s Management to ensure that the principles embodied in this Code are communicated, understood, and respected by all employees. Compliance with the Code is regularly monitored. The relevant findings that ensure its proper implementation and its further revision are the responsibility of the Company’s Management.