Communication on Engagement (COE) Hellenic Anti-Corruption Organization / Civil Society Non Profit

Period covered by this Communication on Engagement

From: December 1, 2016 To: November 30, 2018

Part I. Statement of Continued Support by the Chief Executive or Equivalent

November 30, 2018

To our stakeholders:

I am pleased to confirm that Hellenic Anti-Corruption Organization reaffirms its support to the United Nations Global Compact and its Ten Principles in the areas of Human Rights, Labor, Environment and Anti-Corruption. This is our Communication on Engagement with the United Nations Global Compact. We welcome feedback on its contents.

In this Communication of Engagement, we describe the actions that our organization has taken to support the UN Global Compact and its Principles as suggested for an organization like ours. We also commit to sharing this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Ioannis Kousoulos President of Hellenic Anti-Corruption Organization

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Part II. Description of Actions

Hellenic Anti-Corruption Organization (H.AC.O) under its commitment to promote the Ten Principles of UN Global Compact has taken the following actions:

1st Action On December 9, 2016 , at the premises of Technical Chamber of in , H.AC.O participated in UN International Ant-Corruption day of December 09 event by successfully organizing its first Conference. On that day, H.AC.O was publicly introduced to the Global Compact Local Network as well as to renown personalities of the business community, the law society, the pharmaceutical and medical industry, the Athens International Community and to numerous friends and received the blessings of the Church. On this occasion, H.AC.O’s Statement of Purpose as well as the Package Codes of Conduct, Internal Regulation, Ethical Behavior & Internal Whistleblower Policy of the Organization were publicly signed by the Board and the Directors. The founding officers stressed the importance of the Ten Principles of UN Global Compact and the necessity in implementing and following them in the Organization’s daily functions.

2nd Action

On November 16, 2017, H.AC.O officially delivers to the Office of the Minister of Justice of the Hellenic Republic its proposal for a Law on Whistleblower Protection in Greece, as an indispensable tool in order to promote and implement the Ten Principles in the country. The proposal law, which is drafted in English language, is the outcome of elaboration of the International – European and National Legislation in order to have it codified and duly transposed in articles, reflects the actual needs of the Greek Society as experienced by the Organization’s founding officers. Whistleblower protection is crucial and vital in the fight against corruption, especially in Greece where corruption is wide-spread and whistleblowing has been misrepresented for historical and cultural reasons. The protection of whistleblowers is rooted in the three categories of the Ten Principles of Global Compact: Human Rights – Labor – Anti-Corruption. Employees in Greece are intimidated in revealing wrongdoings at workplace because of the aftermath retaliatory practices. In most of the cases, they lose their estate, their jobs, their family. 2

HACO’s proposal law on whistleblower protection is aiming in the codification and implementation of the provisions stipulated by UN Convention Against Corruption (UNCAC), the Criminal & Civil Convention against Corruption by the Council of Europe, the guidelines and recommendations from OECD – World Bank – Council of Europe. The Greek Government issued under pressure Law N. 4254/2014 on the protection of reporting persons, however, it neglected to incorporate the intent of the aforementioned international legal framework, which in turn resulted in a sorely lacking protection system for those reporting in good faith. HACO’s expertise on the topic emanates from the fact that its cofounder is the first ever recognized as whistleblower in Greece, assigned on April 21, 2015 by the competent Prosecutor for Anti-Corruption of the Supreme Court of Greece (Areios Pagos). The assignment was granted by virtue of UNCAC, the Criminal & Civil Convention against Corruption by the Council of Europe, the guidelines and recommendations from OECD – World Bank – Council of Europe. This assignment was however partially revoked latter by breaching of the legislative normative and the procedures set by Law N. 4254/2014, having as a result the worker’s dismissal following the fifth consecutive disciplinary proceeding in a period of three years, while it was pending and it is still pending till today a response from the Supreme Court of Greece in his inquiry on reporting violation of the International Conventions Against Corruption and disregard of his Constitutional – Labor – Human Rights. The proposal Law on Whistleblower Protection in Greece has been communicated to the Council of Europe – GRECO. No reply whatsoever has been provided as yet by the Greece’s Ministry of Justice as regards the H.AC.O’s proposal for a Law on Whistleblower Protection.

3rd Action The founding officers of H.AC.O have designed an innovative proposal for crises stricken Greece to overcome. This innovative proposal consists in creating H.AC.O Anti-Corruption Smart Park. H.AC.O will be the operator of the Park, and will act as command and control unit, in order to promote and implement the ten principles of UN Global Compact towards all stakeholders that will function within the borders of the park. This Park will be divided in six zones of designated functions: 1) Public Services – ECO Transportations – Hospital – Police Unit , 2) Academies – Schools- Theatres – Museums – Courts – Entrepreneurial sector , 3) Low environmental impact industrial zone ( artisanship - recycling area – solid waste incineration plant ) , 4) Thematic 3

Zone (Botanic Garden – hospitality center for abused children and women – farm – simulating forest - equestrian club ) , 5) Entertainment zone & 6) Research and Development zone. This area will be characterized as special economic zone. European Economic Investment Groupings will be established to run the business within the Park, in order to add further legislative and economic flexibility. The main philosophy is to create new governing models based on the good practice and the international standards, which afterwards may get extended and implemented in the rest of the country. Concluding, Hellenic Anti-Corruption Smart Park will disseminate the 17 Goals of SDG when established and operate. In August 2017, the project outline was presented in a public tender, in order to be funded by Siemens within Greece’s Anti-corruption Initiative. This project is currently on hold because of lack of funding.

4th Action a. H.AC.O has signed a joint venture with Anti-Bribery Academy International. A common strategic plan of actions for the year 2019 is under elaboration, within the framework of UN Global Compact principles www.antibriberyacademy.com b. H.AC.O has an ongoing contract with the Greece’s Association of Medical Laboratories Technologists http://www.petie.gr/ on supporting their dispute vs the Ministry of Education. Allegedly, the new Law 4521/2018 undermines the Association’s professional rights and breaches EU Directives. c. H.AC.O in order to promote the Ten Principles of UN Global Compact and to expand it’s business participated at the 83rd Thessaloniki International Fair, in September 2018. As an outcome, communication with a number of Private and Public entities was established and it’s on the way towards agreements for implementing transparency and anti-corruption policies in their functions. https://www.facebook.com/HellenicACO/videos/286927295456543/ https://www.linkedin.com/pulse/83rd-thessaloniki-international-fair-anti-corruption-organization/ 4

d. H.AC.O is a sponsor of “Migration and Corruption” Seminar, which will take place at the Athens Premises of European Parliament on December 04, 2018. H.AC.O’s President will provide a speech with subject: Corruption & Migration https://www.facebook.com/HellenicACO/photos/a.141583249767853/264482420811268/?type =3&theater e. H.AC.O moreover, is participating in BRAVO Sustainable Awards – Sustainable Greece 2020. The officially awarding ceremony will take place on December 11, 2018. https://www.facebook.com/HellenicACO/videos/524018131446088/?eid=ARDvAgkE3RJsLXvU bOYv3AQhZB22cBMlt3MfK-s1-d3cLIKQQwYynSqjOGr0laFIPFBuir-dDM2mSBHj

5th Action

H.AC.O has developed and drafted a prototype model applicable to all legal entities named “Implementing Transparency Systems in Private & Public Sector” This model can be duplicated in all countries that have ratified the UNCAC Convention in their National Legal System. It is based on three (3) main pillars and each of them includes some basic regulations that will be incorporated and integrated in the internal structure of the entity that is addressed to. This model will ensure a better management against bad practices, reprisals or harassment and from the other hand will enforce the ethical conduct and will cultivate a transparent attitude. The interested legal entity is required to have a contract with H.AC.O. H.AC.O will reform any existing regulations and/or will draft new ones appropriate to the legal entity, will provide qualified training through educational courses, will assess the risks and the vulnerable sectors due to corrupted practices , and will monitor and issue the evaluation reports of the program. By the successful completion of the program, a third Party may proceed to provide the entity with ISO 37001/2016 certification. The three main pillars of H.AC.O’s model are presented below:

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Pillar. N.3

PillarN.1 Ethics – Pillar N.2 preventing Preventing Accountability – Workplace hazard Corruption

Quality in Services- Code of practice Internal

Conduct prevention workplace Whistleblowing Policy

Code of Integrity harassment, Anti-Bribery and Anti-

Internal code of conduct Code of practice Corruption Code of

Code of Social preventing and conduct

Responsibility responding to workplace Anti-corruption code of

Code of ethics bullying conduct for business

Code of internal Anti-discrimination code Code of Anti-Fraud

procedures and conduct of practice for employers policy and compliance

for prevention of insider program

trading

The above configuration demonstrates that the H.AC.O’s model is the appropriate one in promoting the UN Global Compact principles to all Legal Entities, Private or Public.

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As a consequence, H.AC.O’s model implementation is by reflection proven as the proper channel for a Nation to ensure and achieve the 17 SDG.

In order to assist you in understanding this relationship, please consider that the three pillars can be expanded to other sub pillars with their own regulations. H.AC.O already contacted Ministry of Interior Affairs and presented the aforementioned model to the following local government entities, in order to implement it in their functions: Municipality of , Municipality of Maroussi, - Municipality, Municipality of Vari Voula , Municipality of Aghios Dimitrios, Municipality of Penteli, Muninipality of Marathon, Municipality of Dionysos, Markopoulo Messogaias Municipality, Municipality of , Municipality Municipality of Chalkis, Region.

H.AC.O’s proposal is under consideration by the above legal entities. Ongoing changes of the legal framework concerning the auditing and the financial management of the local government is going to enhance the services and the standing of H.AC.O as a reliable partner for transparency issues. 7

Part III. Measurement of Outcomes

H.AC.O is determined to promote UN principles by assisting Greece’s Legislative Authority in the fight against corruption.

H.AC.O’s partnerships with Anti-Bribery Academy International, UN Global Compact Network Hellas, CSR Hellas, European Business Ethics Network Greece & Athens Chamber of Commerce and Industry assisted in designing of the three pillars model “Implementing Transparency Systems in Private & Public Sector”. H.AC.O in order to improve its efficiency needs the support of UN Global Compact in applying the model “Implementing Transparency Systems in Private & Public Sector” in Greece by acknowledging it as the proper model to prevent corruption and promote transparency in all levels of social cohesion.

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