1. Introductory Statement
This Anti-Bribery & Anti-Corruption Policy applies to Zepos & Yannopoulos Law firm (“ZEYA”), an incorporated partnership of Lawyers regulated by Greek Presidential Decree 81/2005 (re: regulation of Law Firms) and Law 4194/2013 (re: Greek code of Lawyers) as currently in force and to our affiliate company, “ZEYA ACCOUNTING Société Anonyme accounting and tax services” (“ZEYA Accounting”). Any reference to “Our Organisation”, “we” and/or “us” in this Policy applies jointly to Zepos & Yannopoulos Law firm and ZEYA Accounting. Our Organisation is committed to achieving the highest standards of ethical conduct and professional integrity and to ensuring that the Organisation, its lawyers, its employees and third parties who may provide professional services on its behalf, act in compliance with all applicable Greek Anti-Bribery & Anti-Corruption laws. In addition, we take pride in being the corresponding firm in Greece for TRACE (Transparent Agents and Contracting Agencies), a non-profit association providing anti-bribery support and certifications.
To ensure compliance with these laws, we have adopted the following rules which, subject to and in accordance with any applicable local law and regulatory requirements, apply to all fee earners (i.e., our partners and associates), as well as to all other employees of our Organisation and to any agent, representative, consultant, and independent contractor acting on behalf of our Organisation or retained by us in order to provide services to a client.
Any breaches or alleged breaches of this policy will be investigated by the Compliance department of our Organisation and will be directly reported to the Executive Committee thereof to take the appropriate disciplinary actions.
2. Anti-Bribery & Anti-Corruption
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We do not tolerate any form of bribery or corruption and it is a requirement of this Policy that all employees and lawyers of our Organisation comply with all relevant Greek anti-bribery and anti-corruption laws and with this Policy. Every new employee and/or lawyer of our Organisation is required to acknowledge receipt and acceptance of this Policy in writing during the process of induction. Anti-bribery and anti-corruption trainings to all staff of our Organisation are set to take place on a regular basis. The Anti-bribery & Anti-Corruption education and awareness is crucial for our understanding of this Policy’s provisions, which are frequently updated. We all receive training on a regular basis, as our Organisation is committed to ongoing Anti-bribery & Anti‐corruption education and awareness, including the applicable policies and the detection of possible bribery or corruption indicators in the course of our work.
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Active bribery: We do not give bribes. We will never provide, offer or promise to provide or authorise or solicit anyone to provide, directly or indirectly, benefits of any nature to any individual (who works either in the public or the private sector) in order for such individual to proceed, in violation of his or her duties, to an act or omission (with the purpose to obtain or retain business or a business advantage).
We are also required not to confer any benefits on a third person, if we know or reasonably suspect that such person will offer such benefits as bribes. In any event, we do not consent to the commission of any of the above and we shall not provide assistance or counsel or mediation thereto.
In particular, we are extremely careful in our dealings with the public sector and the justice system. We are particularly mindful of the regulations regarding bribery to political persons/ Government Officials and we abstain from any kind of promising or offering directly or indirectly of any undue advantage to any person holding a political position as well as Judges and Arbitrators and all “public servants” as these are defined by law. We believe in achieving goals and winning cases for our clients through cooperation with the relevant public authorities and the justice enforcement system; to this effect, we never offer gifts or benefits to public officials or judges. -
Passive bribery: We do not accept bribes and we are diligently mindful in our interaction with public officials. We will never demand or accept, directly or indirectly, for ourselves or for a third party, benefits of any nature or the promise thereof by any party either in the private sector or in the public sector, in order to induce or reward improper performance in the form of an act or omission which arises from or conflicts with a person’s duties.
Furthermore, we assume an active role in supporting and promoting initiatives which enhance transparency and integrity in the public sector; we also oppose all forms of corruption of persons involved in the administration of public affairs and justice, particularly of judges and other adjudicators, members of the parliament, local representatives and politicians in general, and other relevant domestic or foreign officials within or outside the Greek jurisdiction. -
Facilitation payments: We will never accept, solicit, agree to receive, promise, offer or give any facilitation payment, in order to ensure or to expedite the performance of routine government actions or services.
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Foreign Acts: In addition to the above, we are familiar with the provisions of the core anti-bribery and anti-corruption legislation of the jurisdictions in which many of our clients are based, such as the UK Bribery Act and the US Foreign Corrupt Practices Act, as amended and in force and use our best efforts in complying with such Acts, if and to the extent that this is so required and to the extent such provisions do not conflict with Greek laws. We participate in several seminars and practice group meetings with foreign colleagues to keep pace with global developments in the anti-bribery and anti-corruption field.
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Political influence: No directors, partners, lawyers and employees of our Organisation hold an elected position in any government department, state-owned enterprise, international institution or government agency including the armed forces and police or have decision making authority or official influence over any of the above institutions. Furthermore, none of the above mentioned persons receives an official payment for any reason from a governmental source or is an official of a political party, or is convicted of a criminal or regulatory offence related with anti-bribery and anti-corruption laws.
3. Anti-Money Laundering
We actively comply with anti-money laundering and anti-terrorism laws and regulations and we acknowledge that, as providers of legal services, tax and accounting services, we have a duty to report to the competent Greek authorities any behaviour that may be deemed “suspect”.
To this end, we do not accept cash payments and all payments are to be made by bank transfer or credit card as provided by law. We keep accurate books and records and we prohibit any kind of falsification thereof. All of our books and accounting records may provide requisite information with supporting documentation for audits and investigations by the authorities in the event of a bribery incident. In order to prevent the possibility of bribes and kickbacks being paid or accepted, all of our books and records must fairly and accurately reflect each transaction involving our business with our clients, employees, other staff and any other third party.
Secret, unrecorded or unreported transactions are prohibited. All expenses must be accurately accounted for, include appropriate supporting documentation and be promptly entered into company records before they are reimbursed. Any and all transactions of our Organisation are authorised by appropriate management in accordance with internal control procedures.
We will not assist our clients to conclude transactions which could be considered contrary to the provisions of the law. We will refuse to provide legal advice when we know or reasonably suspect that we are asked to provide such advice in order to enable or facilitate the commission of any act which is illegal, related to money-laundering, terrorism, corruption, fraud or other financial crimes.
Compliance with KYC/AML/DAC 6: Furthermore, and in accordance with applicable EU and Greek legislation we have adopted and apply internal procedures so as to be compliant with all KYC, AML and DAC-6 obligations applicable to our Organisation. In this respect, we always ensure that we are fully aware of our clients’ engagements terms, security guidelines and compliance standards.
4. Gifts/ Meals/ Hospitality
We are extremely careful with regards to giving and receiving gifts/meals and hospitality.
Whereas the acceptance of nominal or customary gifts is not prohibited (e.g. bottles of wine, business meals and invitations to events), we absolutely forbid giving or receiving gifts that could be perceived to be extravagant, lavish or otherwise inappropriate to and from parties and/or individuals in the private sector. In all circumstances, gifts shall be reasonable, proportionate, and appropriate in the context of the business occasion, offered for legitimate business purposes and not solicited. Cash or other equivalent instruments are never acceptable as gifts.
We absolutely forbid offering and/or accepting any gifts to and from parties and/or individuals in the public sector such as public officials, judicial officers and politicians.
We do not accept or give meals which could be considered as “undue”, “unfair” or unethical and a potential act of bribery.
We do not allow any discounts or write-offs of our Organisation’s fees in exchange for any gifts, meals and hospitality, entertainment, favor, forbearance, or other item having monetary value.
5. Charitable Donations
We do not undertake charitable donations to political parties and do not make political contributions disguised as charitable donations on behalf of our Organisation. We do make charitable donations to well-known associations and non-profit organisations such as Library4all, SOS Children’s villages and do our best to ensure that they may not be used as a means to improperly influence business related decisions. We always obtain supporting documentation for the donation which specifies the nature of the donation, its amount and the identity of the ultimate beneficiary.
Reasonable steps are taken to verify that any such contribution does not constitute an illegal payment to a government body or official or any individual in violation of this policy and appropriate approvals by the Executive Committee of our Organisation are required before making a donation.
For more information about our Anti-Bribery and Anti-Corruption Policy, you may contact;
Dimitris Zepos, d.zepos@zeya.com
Stefanos Charaktiniotis, s.charaktiniotis@zeya.com
