1. Introduction

Whistle blowing is defined as an intentional act of disclosure which is recorded in the NTOGIAKOS & ASSOCIATES Law Office’s (hereafter referred as “the Office”) files and is conducted by a person who is aware of either significant irregularities and omissions, or other punishable acts, actual, potential or expected within the Office, which are communicated to the competent person in order for the latter to act accordingly. The purpose of the Office’s Whistle blowing Policy is to establish the framework for the timely detections of irregularities, oversights or punishable acts during its operations. Within the framework of the Policy, Office’s associates and employees have the obligation to report serious irregularities, oversights or punishable acts which come to their notice and concern its employees or executives. The key and inviolable principle of the Whistle Blowing Policy is to protect the anonymity and the principle of confidentiality of information for individuals who submit such reports and, if they are employees of Office, to ensure that neither their present position nor their future professional career path is threatened. The reports are carried out without the obligation of a promise of payment or any exchange in return, the criterion being, complying with and abiden by the Institutional and Regulatory Framework.

2. Fields of application

Reports of an irregularity, oversight or punishable act include – but not limited –to the following:

(a) theft,
(b) fraud,
(c) corruption,
(d) violation of the attorney – client privilege
(e) misleading presentation of information,
(f) abuse of power,
(g) violation internal policies,
(h) violation of the legal framework governing the Law Office
(i) exercise of influence,
(k) bribery,
(l) other unethical behaviour.

Outside the framework of the Whistle Blowing Policy are employees’ complaints concerning interpersonal relations in the workplace, inappropriate behaviour and sexual harassment, which shall be dealt with under the existing procedures and policies regarding human resources management.

3. Whistle blowing of irregularities, omissions or acts that are punishable by law

In the event that an Office’s employee or a third party has doubts relating to the requirement of reporting an irregularity, an omission or a suspected punishable act, or requires clarifications concerning his protection or other subjects, and questions are not presently satisfied, he/she can address any enquiries to the Office’s Internal Audit Department. The Office has established procedures and makes available to the whistleblowers alternative ways of submitting their reports, either:
via mail to a post office box or
via e-mail to a specific e-mail address of the Office

4. Confidentiality/Anonymity/Protection of the Whistle Blower

The Office encourages reports under one’s own name. Anonymous reports make the work of detailed investigation extremely difficult or even impossible, due to the difficulty of obtaining data from an anonymous reporting party (e.g. discussion, meeting for the provision of clarifications during the investigation e.t.c.), and also due to the difficulty of evaluating the credibility of the report. The anonymous reports submitted are examined depending on how well-documented they are and whether it is possible to locate the illegitimate act described.
The Office is committed in protecting the anonymity of the whistle blower and does not proceed to actions which may result in revealing his/her identity. It is noted that the disclosure of the whistle blower’s identity may be required by a court or legal procedure, in the framework of the investigation of the case. The anonymity of any other persons involved in the report will be retained, subject to the above restrictions. The maintenance and processing of personal data is carried out on the basis of the stipulations in the legislation in force regarding personal data protection

5. Protection from acts of retaliation

The Office is committed to protect employees and / or associates who, in good faith, proceed to a report, from any acts of retaliation regarding their current position and their future professional career path. In case the investigation of / results from the report do not prove fraud there shall be no consequences for the person who proceeded to the report. In case the whistle blower was a participant in the reported event, reporting it does not excuse him/her from his/her responsibilities, but his/her contribution to the /detection and investigation of irregularities, oversights or punishable acts will be taken into consideration.