Policies

The primary concern for our company is the provision of products and services which serve the needs and meet the expectations of our customers.

The fulfilment of this basic principle is implemented via the organisation and operations of an Integrated Management System having simultaneously all the necessary means in both infrastructure and human resources. At the same time, we support the effort to achieve the company goals and we are committed towards:

• continuous improvement of our performance and the quality of our products;
• full satisfaction of our customers' demands;
• compliance with the legal infrastructure, the standards and other regulatory provisions governing our products and our production processes;
• continuous staff training on issues affecting quality;
• full implementation of the Quality Policy in all our business and production activities, with the ultimate goal of the continuous - steady development of our business activity and our unwavering commitment to the company principles and values.

Creating conditions to ensure Health and Safety in the workplace is always our top priority, and our main goals are ZERO ACCIDENTS and ZERO OCCUPATIONAL DISEASES.

In a constantly changing and highly demanding environment, TCK - CHEMICALS S.A. has laid the foundations for the continuous improvement of the Health and Safety system, always acting towards eliminating occupational risks. The pillars on which we base our operational and production strategy are:

• Unhindered respect for the employees and their working conditions.
• Compliance with the legislative requirements as well as the company internal regulations.
• Risk identification and assessment and taking immediate action when necessary.
• The unrestricted expression and communication regarding issues related to Health and Safety in the workplace.
• The systematic measurement and evaluation of all harmful factors and effort to eliminate them.
• • The management and staff of the company understand the importance of Health and Safety in the workplace and have set it as top priority.

SAFETY IS EVERYONE’S RESPONSIBILITY

Recognizing the need for continuous improvement of our environmental performance as well as for the minimization of the environmental impact of our company activities, we have developed and are implementing within the framework of the Integrated Management System, the Environmental Management System that is fully harmonized with the requirements of the EN ISO 14001 standard.

The basic principles of our Environmental Policy that governs the entire structure of the company are the following:

• Full compliance with the applicable legislation and the rest regulatory provisions, our customer requirements, the expectations of the local community and other people of interest, considering the overall impact resulting from the analysis of the life cycle of our products and from the operation of the business on the environment, people, and society.
• Production of quality environmentally friendly and cost-effective products using as sustainable raw materials as possible, efficient energy systems and pioneering production and disposal technologies which ultimately result in the reduction of the carbon footprint and water footprint of our products and production processes.
• Continuous effort to reduce the waste produced from the overall operation of the company, recycling, and rational management of it for biodiversity protection and the environmental protection.
• Commitment of the top management for the unhindered allocation of necessary resources as well as human resources towards the continuous improvement of the environmental as well as the energy performance of our company.
• Continuous training and briefing of our employees on environmental and energy issues. Each employee ought to be fully aware of the overall environmental impact per his/her position and act with sensitivity and awareness accordingly.
• Continuous monitoring of defined environmental and energy vectors, the establishment of relevant targets and their continuous review to reduce as much as possible the environmental impact of the company's production activities both at a local and a wider level.
• Regular and targeted information and communication of the company's environmental and energy performance to all interested parties, including the local community.
• Continuous and full information of our customers and our supply chain in general regarding the safe use of our products and their appropriate management after the end of their life cycle, to ensure the maximum level of protection of people and the environment.

The Management and the employees of the company work intensively to fulfil all the goals above that contribute to the sustainable growth of the company, following the principles of Responsible Care of the Global Chemical Industry and the UN Sustainable Development Goals.

We are committed to adhering to internationally accepted human rights and employment practices for all our activities.

Best ethical practice and internationally accepted human rights principles are always respected, subject only to national laws. The management of the company's human rights issues is based on all our efforts, as the company is committed to the highest standards of business integrity, ethical values, and professionalism in all our activities. The guidelines we follow are:

o   We integrate values and policies into all our business processes.

o   We are committed to protecting employees’ rights and to always respecting their dignity.

o   Working conditions and practices do not violate the inherent dignity of employees.

o   We condemn harassment of all kinds, with no discrimination.

o   We prevent any manifestation of forms of harassment, whether expressed verbally, in gestures or behaviourally.

o   We value the freedom and safety of the individual.

o   We do not encourage, tolerate, or advocate inhumane, degrading treatment or punishment, coercion and/or abuse.

o   We condemn any unfair discrimination in employment on the grounds of race, gender, pregnancy, marital status, ethnic or social origin, colour, sexual orientation, age, disability, religion, conscience, belief, culture, language, national extraction, political views.

o   We are developing and will provide training on procedures ensuring best recruitment practices and our adherence to this policy. Employees are constantly trained to allow them to perform their duties according to our standards, values, and principles.

o   Employees and employers are free to form and participate in associations for the protection of their interests and to negotiate collectively within the framework of the applicable legislation.

o   We do not impose forced labour on our employees.

o   We accept internationally recognised practices and principles relating to youth employment imposed by law. We do not employ any under-18 staff. Our employees have reasonable freedom of movement. Any termination of an employee's employment complies with the requirements of the law.

o   We offer equal opportunities to all our executives regarding employment and career development without any discrimination.

o   We support working women who become mothers to maintain their work-life balance and to ensure equal career opportunities.

These guidelines and this policy strengthen all existing policies, processes and activities and they support our values and commitment on human rights, work relations, corporate governance, ethical behaviour, and social responsibility.

The Management and our company's employees are committed to the implementation of this policy and its integration in all performed processes.

The Code of Conduct defines the framework within which the operation and activity of our business is set, always guided by the principles of ethics, honesty, integrity, and transparency.

We always respect and abide by the laws of the country in which we operate, having as our values:

• Meritocracy: We evaluate on merit the people who work for our company, based on their performance, their consistency, and the dedication they show daily to the company goals and policies.
• Team spirit: We promote team spirit. The employees of our company are members of a large and close-knit team in which they excel first individually and then as a unit. We take advantage of the skills and abilities of each member of this team to achieve the best possible result of the whole. We actively promote the development of the personal and professional skills of our staff and their advancement in the company. We encourage our employees to put their personal stamp on the various processes that comprise the operation of the business.
• Corporate responsibility: We respect the laws and operate safely and responsibly. We care about the local community, and we constantly support them within the company's corporate social responsibility, contributing to the protection of the environment, the quality of life of both people and sustainable development.
• Commitment to quality & innovation: We are committed to creating quality products and services that are friendlier to the environment, while we build on strong relationships with our customers and suppliers, on which we place our effort for continuous development and innovation.
• Healthy competition: We reject the use of any means and methods that may circumvent the rules of healthy competition throughout the spectrum of our business activity, including the responsible promotion - advertising of our products.
• We prohibit κany attempt towards affecting our professional integrity whereas any misconduct is rejected; we guarantee the full compliance with the relevant legislation on money laundering and reject any activity related to it.

Through specific Integrated Management System Procedures, we ensure that this Code of Conduct is followed to by all those involved in the operation of our business, such as our employees, suppliers, contractors, and external partners.

CONFLICT OF INTEREST POLICY

Our company's conflict of interest policy refers to any case where the personal interest of an employee may conflict with the interest of the company for which s/he works.

This policy applies to the Management, all existing and future company employees, as well as independent contractors and any person acting on behalf of the company.

The relationships that govern our company are based on mutual trust, as the company is committed to maintaining the interests of the individuals under our employment and expects them to act in favour of common company interests.

This Policy covers the following conflicts of interest:

• Actual conflict of interest: a conflict between professional duties and private interests, in which the worker has private interests that could unfairly influence the exercise of his professional obligations and duties.
• Apparent conflict of interest: there can be an apparent conflict of interest in cases where it is assumed that the private interests of an employee could unfairly influence the performance of his duties, but this is not the case.
• Potential conflict of interest: a potential conflict of interest arises when an employee has such private interests that a conflict of interest would arise if the employee were to take on relevant (i.e., conflicting) professional duties in the future.

Conflict of interest might arise whenever an employee's interest in a particular issue might lead them to actions, activities or relationships that undermine the company and might put it at a disadvantage. This condition can take on many different forms including:

o   Ability of employees to use their position in the company to their personal advantage.

o   Employees engaged in activities that will bring direct or indirect profit to a competitor or employees who hold shares in competitors.

o   Employees who use connections acquired through the company for their own private purposes.

o   Employees who use corporate equipment or means to support an outside business.

o   Employees who act in ways that may compromise the legality of the company (e.g., bribery or bribery of representatives of legal authorities).

In these cases, and based on the legislation in force (art. 97 of Law 4548/2018 as in force), the principles set out in the above law are fully applicable, namely:

(a) in any case, the interest in the company takes precedence over the individual interest;

(b) the obligation to disclose the conflict of interest by each member of the management and employee and to inform compliance shall apply;

(c) the prohibition of voting for the members of the Board of Directors or a member of any Committee of the Company.

Furthermore, the issue of conflict of interest is specifically regulated in the case of transactions between members of the Management and the Company (Law 4548/2018), as well as in the case of inside information exploitation.

The likelihood of a conflict of interest arising shall be addressed and resolved before the actual damage occurs. Therefore, when a member of our company realizes or suspects that there may be a conflict of interest, s/he brings this matter to the attention of the Management so that the necessary corrective actions can be taken.

The responsibility for resolving a conflict of interest begins with the Heads of Departments and can reach the senior managers.

All conflicts of interest shall be resolved as fairly as possible. The top management is responsible for the final decision when no solution can be found.

Employees are encouraged to refrain from protecting personal and/or financial interests and external activities that run counter to the fundamental interests of the company.

The same principles apply to the company as far as our customers are concerned.

TCK creates chemicals for a sustainable future, combining social responsibility and environmental protection in all our business activities while allowing our customers to meet the current and future needs of society.

We take advantage of the opportunities offered by sustainable development through our effort to connect our strengths with the capabilities of our suppliers and customers alike. This means that we expect our suppliers, as well as their suppliers and subcontractors, to fully comply with applicable legislation and adhere to internationally recognized environmental, social, and corporate governance standards (ESG).

We expect each of our suppliers to actively support and implement the ESG standards based on the principles of the Global Compact initiative of the United Nations Global Compact and the Responsible Care program of the Global Chemical Industry which are summarised as follows:

Environment

Compliance with all applicable regulations on environment, health and safety.

Promotion of safe and environmentally sound development, manufacturing, transport, use and disposal of products.

Protecting the lives and health of employees and social groups affecting and affected by the company's activities, as well as the public, from inherent risks posed by production processes and products.

Resources efficient use, integration of energy-efficient and environmentally friendly technologies to minimise as much as possible the emissions and impact on air, soil, aquatic ecosystems, minimising the impact on biodiversity, climate change and water shortage.

Society

Supporting internationally proclaimed human rights, including minimum wages, and working hours rights.

Combating forced labour, child labour and any discrimination in the workplace.

Defending the freedom of association.

  Governance

Compliance with all applicable national and international antitrust and commercial control regulations. 

Rejection of any kind of corruption, including bribery and ensuring that personal relationships do not affect business activities.

Refraining from any money laundering activity.

Our relationship with our suppliers is based on mutual trust and respect.

Proof of our suppliers' commitment to these principles may be done through the adoption of a code of conduct or policies that espouse these principles.

Based on the principles of risk, risk assessment and the effort to eliminate it, our company may ask our suppliers to verify their compliance with these ESG standards and take corrective action if there is cause for concern, through:

Self-evaluations: questionnaires on compliance with ESG standards. 

Third-party office information assessments by another third party, e.g., a data provider, on compliance and performance with respect to ESG standards.

Certifications/Declarations: certification or declaration confirming compliance with ESG standards.

On-site inspections: our company executives or authorized third-party personnel acting on our behalf may visit our suppliers' premises to verify compliance with ESG standards.

Ensuring the principles of sustainable development in our supply chain is our main priority.

TCK relies on the commitment of our suppliers to sustainable development and sustainability!