INTEGRITY & COMPLIANCE

CODE OF CONDUCT OF L.NEMITSAS LTD

Introduction

In order to safeguard the long term prosperity of our Company and consequently the interests of all stakeholders we consider our Name, Behavior, Quality and Reputation as the key factors of our success. Throughout our more than 100 years of operation in the Cyprus and Overseas markets, we are proud to say that we have gained the trust and confidence of our business partners by providing them with products and services of very high quality meeting their expectations and by enforcing the highest standards of Integrity, Transparency and Compliance.

Code of Conduct/Main Principles

The Company’s code of conduct is very clear and binding and is enforced by its entire staff at all levels of our activities. All of us are well trained and are continuously kept informed on any developments on such issues. Hence, our code of conduct became a second nature to all of us.

• All our partners are treated honestly, equally and fairly.

• We adopt the principles of open market and fair competition and we do not adopt any illegal
business practices.

• We have zero-tolerance against any form of racism, bribery, corruption and tax evasion and we
do not make facilitation payments.

• We maintain complete and accurate accounting records of all our business transactions.

• Any potential conflicts of interest are immediately disclosed and are immediately resolved.

• We may make donations but only for philanthropic purposes.

• We may offer gifts and hospitality which are not illegal, in an open and transparent way and
subject to the set limits and only with the prior consent of our M.D.

• We never disclose confidential information which is made available to us by other stakeholders’
and we never use information that we should not have.

• We abide by all relevant National and/or EU regulations and laws as well by the Code of Conduct
of all our collaborators. We only cooperate with other stakeholders who meet our standards and
conduct.

• Any issues relating to Integrity, Compliance and Transparency can be reported to the Managing
Director of our Company at the confidential email: louisa.nemitsas@nemitsas.eu