Corruption hinders economic growth as it can undermine fair competition and destroy trust in a company or an individual. At HOUTOS CATERING S.A. the fight against all forms of corruption is a priority, which is why the company decided to design and install an Anti-Bribery Management System in accordance with the requirements of the International Standard ISO 37001:2016. The company’s Anti-Bribery Management System covers all of the company’s activities regarding the preparation & distribution of ready meals – catering items – packaged sandwiches and croissants, provision of cook and banker services and was designed in accordance with the needs and aspirations of the Company and the Legal and Regulatory Requirements of the applicable Greek and Community Legislation.

Promoting a culture of ethics and integrity is a key factor in maintaining the trust of customers, stakeholders and society. The company is committed to promoting a culture of integrity throughout its operations and communicating its expectations for reducing the risk of corruption.

The company’s general goal is to satisfy the needs and expectations of its customers to the maximum extent possible and to reduce the risk of corruption. It therefore establishes measurable anti-corruption targets aiming to:

  • Improvement of the organizational structure, through the clear definition of powers and responsibilities.
  • Compliance with the legislative and regulatory provisions related to its activity either directly (production activity) or indirectly (production houses / suppliers).
  • Improvement of Internal Communication, through the determination of the interaction and interdependence of the Company’s processes.
  • Continuous improvement of the Anti-Bribery Management System and the operation of the Company with the effective use of the following tools:
  • Setting and reviewing anti-bribery targets.
  • Management Review
  • Internal Inspections
  • Corrective actions
  • Systematic analysis of data resulting from the Archives.

The company aims to prevent bribery and corruption through:

  • the prohibition of facilitating payments, even when permitted by law.
  • compliance with all anti-bribery and anti-corruption laws applicable in each country where the company operates, as well as the same requirement from contractors
  • compliance with all global policies aimed at preventing, directly or indirectly, a risk of corruption
  • conducting risk-based anti-bribery due diligence on third parties before they become involved in the company’s business. To promote a culture of ethics and integrity, as well as to comply with all applicable anti-corruption and anti-bribery laws and regulations, the company implements a comprehensive set of policies and standards that set out clear rules to which all employees must comply and, as the case may be, third parties. In addition to putting the company at risk, corrupt employees may be personally subject to civil and criminal penalties, including heavy fines and imprisonment. In addition to:

Company employees are prohibited from:

  • give, promise to give or offer anything of value to any person for the purpose of influencing any action or decision, especially when interacting with government officials. This prohibition also applies to indirect corruption, i.e. actions carried out by third parties in the name or on behalf of the company. Items of value may include, but are not limited to: money, gifts, entertainment, hospitality and meals;
    travel expenses, services, offers of employment, loans, donations or contributions, any transfer of value, even symbolic,
  • to receive remuneration from a provider or customer of the company,
  • maintain a financial interest or relationship with a competitor, customer or supplier of the company, or another third party that does business with the company,
  • to participate in the direct or indirect acquisition or possession of any interests in the form of real estate or assets of any kind for the purpose of selling or renting it to the company,
    engage in any outside activity to such an extent as to raise questions about their ability to devote adequate time and attention to their duties;
  • to interact with a relative who works for or has applied for work at the company, a competitor, supplier or customer of the company,
  • make purchases of goods or services on behalf of the company from a relative or a company in which a relative has interests,
  • to receive items of value. Accepting a gift may cause a sense of obligation to the recipient, possibly undermining the objectivity of his decisions, and may be perceived as a gift with the intention of corrupting himself or another employee of the company.

Employees owe the company:

  • disclose any actual or potential conflict of interest before engaging in the transaction, activity or relationship that leads to the circumstance referred to;
  • disclose actual or potential conflicts of interest as part of the recruitment process;
  • disclose any actual or potential conflict of interest annually, in the event that they belong to High Risk Employees, i.e. front-line managers and all company employees who are regularly involved in the creation of contracts, the purchase, sale or rental of services, materials , real estate or products,
  • refrain from participating in the board of directors of any client, supplier or competitor of the company. Participation in external boards of directors, outside of the professional duties of the company’s employees, is permitted, upon approval, only for the members of the Executive Committee and must be limited to the provision of services consistent with their duties in the company,
  • ask the respective Head of Department or System Manager how to handle a conflict of interest, rather than relying solely on their interpretation and personal judgment.
    Each employee is responsible for his own work and is required to contribute to the anti-bribery management and the achievement of the set goals. For this reason all employees, depending on their responsibilities, are informed about the Anti-Bribery Management System and demonstrably act in accordance with the established rules.

Processes, flows and actions, which do not guarantee the fulfillment of the objectives set, are stopped immediately by those responsible, cause analyzes are carried out and the required improvement measures are defined.
This Anti-Bribery Policy is communicated to staff, is available to all interested parties and is periodically reviewed by Company Management.

Thessaloniki, 01/02/2021
Edition 1/01/02/2021


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