CODE OF CONDUCT

GEK TERNA’s principles, beliefs, corporate culture, business ethics and primarily its voluntary ethical commitments are crucial pillars of the group’s operations and remain unchanged over time.

The group’s Code of Conduct, along with the corporate governance rules and the policies that we apply, define the framework of its business operation.

These rules and policies describe the behavior we anticipate from our people, as well as the way we conduct our business with our customers, suppliers and other partners.

In this context, the company follows the following policies, which ensure the desired agreed and transparent operating framework:

• Regulatory Compliance and Corruption and Bribery Control Policy
• Policy for Addressing Unhealthy Competition
• Conflict of Interest Policy
• Policy of Compliance of Violence and Harassment at work
• Whistleblowing Policy
• Travel and Hospitality Expenses Policy
  This Policy sets out the limits and expenses that Company and Group personnel are allowed to make when conducting business trips or hosting partners and clients of the Company.
  At the same time, the approval flows followed for the submission and approval of these expenses are described.
• Gift Policy
  This Policy specifies what is allowed and what is not allowed regarding business gifts sent or sent by employees of the Company and the Group. It sets out the conditions, limits and rules that must be followed in order for a gift to be considered acceptable.
  In addition, it describes the procedure for updating and approving in case these limits are exceeded.

For information, please contact the Compliance Officer: compliance@gekterna.com

Code of Conduct

Reporting - Complaints’ System’s communication channels

In the context of the correct use of the GEK TERNA Group’s Code of Conduct, you are kindly requested to use one of the following communication channels with the Regulatory Compliance Officer designated as the Person Responsible for the Receipt and Follow-up of Reports (P.R.R.F.R) for reporting any cases of fraud, corruption, bribery, conflict of interests, harassment at work and in general deviations from the Code of Conduct.

You can contact either anonymously or by name through:

• E-mail to the electronic address compliance@gekterna.com
• The platform https://gekterna.integrityline.com/frontpage
• A letter addressed to: "GEK TERNA S.A.” 85, Mesogeion Αve., Athens 115 26, Greece, for the attention of the “Person Responsible for the Receipt and Follow-up of Reports” of the Company, with the indication "Confidential".
• Orally after a meeting with the Person Responsible for the Receipt and Follow-up of Reports.