POTAMITISVEKRIS INTERNAL REPORTING CHANNEL

What you need to know?

POTAMITISVEKRIS operates responsibly in accordance with the principles of Integrity, Transparency, Respect, Social Responsibility and Protection of the Public Interest.
In this context, and in compliance with the requirements of (i) Law 4990/2022, implementing the EU Whistleblowing Directive 2019/1937, and (ii) Law 4808/2021, POTAMITISVEKRIS has established this reporting channel.
Please note that anyone reporting through this channel must have reasonable grounds, at the time of reporting, to believe that the information about the reported violations is true and falls within the scope of the above-mentioned legislation (i) for the protection of Whistleblowers and (ii) against violence and harassment in the workplace.

POTAMITISVEKRIS takes all reports seriously, ensures the confidentiality of the report and conducts an investigation about any improper, unethical or illegal behaviour or any violation reported through this channel. It shall also take the necessary corrective measures to address the reported issue, as well as the necessary and appropriate protective measures to support the person reporting through this channel and to uphold integrity within POTAMITISVEKRIS.

Who can use the “SPEAK UP!” Integrity Line?

The “SPEAK UP! Integrity Line” is a reporting channel addressed to all personnel, employees and collaborators of POTAMITISVEKRIS, including partners, lawyers and trainees all business partners, suppliers, third-party service providers, external consultants and their employees, third parties holding information on illegal actions committed within the scope of their business relationship with POTAMITISVEKRIS. This reporting channel may also be used by persons who wish to disclose information on breaches acquired in a work-based relationship with POTAMITISVEKRIS which has since ended and persons whose work-based relationship is yet to begin in cases where information on breaches has been acquired during the recruitment process or other pre-contractual negotiations.

What can be reported through the “SPEAK UP!” Integrity Line?

(i) Violations in the following critical areas of European Union law:

  • Public procurement,
  • Financial services,
  • Products and markets,
  • Product safety and compliance,
  • Transport safety,
  • Environmental protection,
  • Radiation protection and nuclear safety,
  • Food and feed safety,
  • Animal health and welfare,
  • Public health,
  • Consumer protection,
  • Protection of privacy and personal data,
  • Network and information systems security.

(ii) Violations having an impact on the financial interests of the European Union.
(iii) Violations related to the internal market, including breaches of Union competition and State aid rules, as well as breaches relating to the internal market in relation to acts which breach the rules of corporate tax or to arrangements the purpose of which is to obtain a tax advantage that defeats the object or purpose of the applicable corporate tax law.
(iv) Violations of the national legislation (Laws, Presidential Decrees, Ministerial Decisions, Court Judgments, Decisions of National Supervisory and Regulatory Authorities, etc.) and/or POTAMITISVEKRIS’ Code of Conduct and Policies, including violations of the Policy against Violence and Harassment.

How to submit a Report?

Reports can be filed to POTAMITISVEKRIS in the following ways, in the form of named or anonymous complaints:

  • By e-mail at: whistleblowing@potamitisvekris.com, or
  • By regular mail sent or delivered to the registered seat of “POTAMITISVEKRIS”, (11, Omirou St., GR – 106 72, Athens, Greece), with the indication: “Report in accordance with Directive (EU) 2019/1937 or Law 4990/2022”, or
  • Orally, at a personal meeting with the YPPA (Person responsible for handling the report), within a reasonable period of time from the date the Reporting person’s request is filed.

The anonymous report is taken into account and leads to an investigation.  However, anonymity may, in certain situations, limit the possibility of an efficient investigation of the report. In any case, the report should include the necessary information to allow for effective investigation of the reported actions, e.g. a description of the incident, the name(s) of the person(s) who appear to be involved in the incident and the name(s) of any person(s) who witnessed the incident.

Data Protection notice

All personal data processing taking place in relation to the operation of this reporting channel shall conform to the applicable national and EU data protection laws and regulations, in particular Regulation (EU) 2016/679 [General Data Protection Regulation, “GDPR”].

The aim of the processing of personal data is the maintenance of the highest ethical standards within POTAMITISVEKRIS. The legal basis of this processing is the legal obligation of POTAMITISVEKRIS to establish a whistleblowing system in accordance with EU Directive 2019/1937 and Greek Law 4990/2022. The personal data processed are those included in the report related to the whistleblower, alleged wrongdoer (the person against whom an allegation has been made), witnesses, and informants.

Information contained in reports may be transmitted to the competent supervisory and investigation authorities and be used as evidence in any administrative, civil-law or criminal investigations and proceedings.

POTAMITISVEKRIS, as the data controller takes all necessary technical and organisational measures to ensure that, at the time a report is filed and throughout the period it is monitored, the personal data collected are those essentially required for the purposes of the operation of this reporting channel. Personal data which are manifestly not relevant for the handling of a specific report shall not be collected or, if accidentally collected, shall be deleted without undue delay.

If following an initial assessment, a reported case should not be referred to the National Transparency Authority or is not within the scope of the whistleblowing procedure, the report will be deleted without undue delay. Personal data contained in the report should be deleted promptly and generally within three (3) months of completion of the preliminary assessment. Exceptionally, if the personal data contained in the report are necessary in the context of authorities’ investigations and judicial proceedings, such data will be kept for as long as necessary until the completion of these proceedings.

The data subjects of the personal data collected via the report have the following rights under data protection law, although their ability to exercise these rights may be subject to certain conditions, as referred in the Whistleblowing Policy of POTAMITISVEKRIS:

  • the right to receive a copy of and/or access the personal data that POTAMITISVEKRIS holds about them;
  • the right to request that any inaccurate data that is held about them is corrected;
  • the right, in certain circumstances, to request that POTAMITISVEKRIS erase their personal data;
  • the right, in certain circumstances, to request that POTAMITISVEKRIS no longer process their personal data for particular purposes, or object to POTAMITISVEKRIS use of their personal data or the way in which POTAMITISVEKRIS process it;
  • the right to complain to the Hellenic Data Protection Authority if they believe that POTAMITISVEKRIS has not handled personal data in accordance with the current data protection legislation (Offices: 1-3 Kifissias Street, Post Code: 115 23, Athens, Website: www.dpa.gr, Call Center: +30-210 6475600, Fax: +30-210 6475628).

The data subjects of the personal data collected via the report may exercise their rights by contacting POTAMITISVEKRIS at privacy@potamitisverkis.com. 

External Reporting to the National Transparency Authority

In case the reporting person considers that his/her report has not been effectively addressed, he/she has a right to re-submit it directly with the National Transparency Authority (“NTA”), which forms an external communication channel.

Such report is filed either in writing or through the online platform (accessible also to persons with disabilities) as follows:

Electronically: By email to kataggelies@aead.gr or by completing an online Report Form available at: https://aead.gr/submit-complaint/.

By mail: EAD mailing address: 195, Lenormann & Amfiaraou St., GR – 104 42, Athens,

In person (or by a duly authorised representative) at the EAD headquarters: 195, Lenormann & Amfiaraou St., GR – 104 42, Athens.