Transparency

In its Compliance Policy, Sunlight Group considers compliance with the applicable legal and regulatory framework to be one of the main principles and values, integrated to Group’s vision and strategy.  To this aim, Sunlight Group has designated the Compliance Committee and the Compliance Function as the main guardians and interpreters of the Compliance Program into Group’s activities.

Our Code of Conduct reflects our commitment to operating in full transparency and compliance with applicable legislation, rules, and regulations. This commitment permeates all our facilities and subsidiaries, and governs our relations with customers, investors, partners, suppliers, employees, regulators, and authorities. The Code of Conduct document is structured around our shared values: Innovation, Agility, Integrity, Value Creation, and Data-driven. It is based on the principles of respect for human rights, transparency, accountability, and accuracy. And it guides the entire Sunlight Ecosystem in protecting the company’s reputation, assets, and brand. Sunlight Group’s Code of Conduct describes how we operate, ethically and transparently, to achieve our goals purpose. Because for us, the way we achieve results is just as important as results themselves.

Through this policy, Sunlight Group seeks to ensure that all employees, as well as third parties, with which it conducts business, comply with the main anti-bribery regulations and legislations applicable to the different jurisdictions where they are operating. Establishing appropriate rules and processes to prevent corruption and facilitation payments and raising awareness to its personnel in such matters is of outmost importance for Sunlight Group for safeguarding a transparent working environment. The policy, the basic principles of which are included in the company’s Code of Conduct (Chapter 5- Individual Conduct), endorses the basic principles set in international standard ISO 37001, on Anti-Bribery Management System.

Sunlight Group develops a proactive and ongoing strategy to support the needs of the communities it lives and thrives in. In this context, it annually grants donations and sponsorships to entities, for the purposes of improving the quality of life of local communities, supporting education and training activities or  environmental initiatives and enhancing health, emergency and rescue services.

Sunlight Group recognizes that gifts and hospitality can be important for developing business relationships with customers, suppliers, and other third parties. However, they may often raise suggestions of impropriety. Therefore, it is important that employees are able to assess whether a gift and hospitality received or offered is accepted or prohibited. If not prohibited, employees need to ensure that the internal gifts and hospitality procedure is followed.

This policy provides guidelines for the appropriateness of different kinds of gift and hospitality and sets specific procedures to be implemented when offering or receiving such items during business dealings.

Target of this policy is to promote diversity and inclusion and ensure a working environment with zero tolerance to violence, bullying, discrimination and harassment, based on the principles of mutual respect, human dignity, cooperation, mutual assistance and the protection of human existence and human rights.

Sunlight Group adopts appropriate measures to prevent and combat any kind of violence and harassment, expressly including sexual harassment, at work, and establishes effective and confidential internal reporting mechanisms to encourage all employees to speak up, without the fear of victimization or retaliation.

Through this policy, Sunlight Group commits to comply with the rules of Greek and European Union competition law, as well as those of the national competition laws of the countries within which it operates. As some agreements with customers, suppliers, competitors or other business partners can potentially limit free and open competition, it is important to make sure that all employees involved in commercial activities and conducting discussions and negotiations with third parties know how to apply antitrust rules and to avoid even the appearance of unfair restriction of the competitive freedom.

This Policy enhances employees’ awareness about competition best practices and rules, defines and prevents prohibited agreements and establishes measures appropriate for preventing abuse of dominant position, promoting a healthy and fair competition with other industries activated in our area of specialization.

The present policy outlines the controls and procedures required to be in place in order to ensure that Sunlight Group complies with all applicable economic, trade and financial sanctions laws and regulations. It addresses the risk of Sunlight Group entering into a transaction with a sanctioned entity in breach of sanctions legislation, which could potentially result in reputational damage, large fines or criminal penalties for individuals, restrictions on the ability of the Group to engage in international business transactions or even termination of the Group’s financing arrangements.

The cooperation of Sunlight Group with suppliers, customers, agents and other business partners is assessed in accordance with approved (qualitative and quantitative) criteria. The Third Parties Due Diligence Policy describes in detail the above criteria and the exact steps of the due diligence process, that Sunlight Group needs to perform prior to establishing relationship with any third party, as well as on a regular basis during their collaboration, with the objective to identify the level of compliance of business partners with applicable laws and regulations, corporate best practices and main values and principles, as endorsed in the Group’s Code of Conduct.

Although Sunlight Group respects its employees’ right to privacy in their personal affairs and activities, it implements all measures and procedures required to effectively identify and then manage any case where the personal or family activities of the latters raise or may raise an actual or potential conflict with their duty of loyalty to the Group.

The present policy aims to prevent, detect and manage the conflicts of interest that may arise between Sunlight Group and its workforce. Through ensuring employees’ objective judgement and commitment to the business goals, we protect the integrity of the decision-making process and thus the Group’s reputation and stakeholders’ trust.

This policy addresses the risk of significant adverse impact which may be associated with trading, handling, importing and exporting 3TGs (tin, tantalum, tungsten and gold) from conflict-affected and high-risk areas. It outlines the controls required to ensure that Sunlight Group meets the legal disclosure requirements and supply chain due diligence obligations set out in applicable European and international legislation, with regard to the need to manage Conflict Minerals in procured products.

In order to enhance transparency and integrity, Sunlight Group has established appropriate internal channels for handling and investigating reports and complaints.

Sunlight Group has set several policy rules, procedural and technical controls to create a framework and protect personal data that collects, maintains and processes, in compliance with General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable national and international privacy legislation.

Sunlight Group Data Protection Policy sets the standards of personal data processing across the companies of Sunlight Group and establishes the main requirements for the lawful Personal Data Protection implementation and management.

In order to submit any privacy-related request to Sunlight Group of companies or exercise your rights as data subjects under GDPR, please reach out Omnitrack GDPR portal available here. The above platform provides an online, internal corporate channel for direct communication with our Data Protection Officer (DPO). This ensures prompt response and confidentiality, enabling you, in the capacity of employee, candidate, customer, or other third party, collaborating with Sunlight Group, to effectively exercise your rights under GDPR, including but not limited to:

• Being informed on whether and under which conditions your personal data are processed by the company.

• Access to your personal data held by the company.

• Rectification of your inaccurate or incomplete data.

• Erasure of your personal data.

• Restriction of the processing of your personal data.

• Objection to the processing of your personal data.

• Recalling your consent to the processing of your personal data.

• An electronic copy of your data kept by the company or their direct transfer to another data controller.

• Objection to automated processing of your personal data

Your request will be duly processed and addressed, as required by applicable legislation.

Sunlight Group is committed to providing products and services that meet or exceed our customers' expectations. Sunlight Group has processes in place to identify and ensure compliance with compliance obligations. This Policy is documented in accordance with the ISO 9001:2015 requirements.

Sunlight Group is committed to protecting the environment, minimizing our ecological footprint, and promoting sustainability in all aspects of our operations. Our Environmental Policy is a cornerstone of our Group Integrated Management System (IMS) and adheres to the principles and requirements of ISO 14001:2015.

Sunlight Group is committed to providing a safe, healthy, and supportive working environment for all employees, contractors, and stakeholders. This Health and Safety Policy is a cornerstone of our Group Integrated Management System (IMS) and adheres to the principles and requirements of ISO 45001:2018.

This policy outlines the principles and measures Sunlight Group applies to safeguard its information assets, ensuring the confidentiality, integrity, and availability of data across all business operations. It defines the responsibilities of employees and partners in protecting systems against threats, complying with applicable legal and regulatory requirements, and supporting secure business processes.

The policy can be shared upon request by emailing infosec-team@sunlight-group.com. We will respond promptly and provide the requested policy documents, subject to the necessary confidentiality, access controls, and the need-to-know principle.