Code of Conduct

Code Of Conduct


Dear Colleague,

Our Company, during the last three decades, has been expanded via employments and collaborations in more than 30 countries; What makes us work as one, are the basic values that are alive and guide us under constantly changing conditions. Continuing our journey, it is imperative to provide people clear guidelines on good business conduct and ethics to be followed by the daily exercise of their duties.

Our values require us to be open, fair, and honest and to act with integrity. We want to create a safe and positive working environment. We compete vigorously to win in the marketplace, but we always are honest, lawful, and fair I n our dealings with everyone. We care as much about how our results are achieved as we do about the results themselves.

The Code of Conduct and Ethics sets clear expectations on our business conduct and provides useful guidance for the management of critical risk areas such as privacy, conflicts of interest, improper payments, environmental impacts, and others. The Code cannot cover every possible situation, but it provides the basic legal guidelines and essential ethical behavioral standards that will help us make the right business decisions.

Our values and behaviors are the foundation for our Code. They define how each of us must act to ensure that our Company sustains its reputation and continues to earn the trust that allows us to prosper as a company.

Apostolos Korres
President of the BoD
and Managing Counsel

Purpose of Code of Conduct and Ethics

The Code of Conduct and Ethics sets out the Company’s commitment to conducting business in accordance with our values, all applicable laws and regulations and industry standards. It provides guidance on what is expected of each of us and references other Company policies and guidelines. The Code explains employee responsibilities and the obligation to report any potential violations and cooperate in any investigation that may follow. Failure to comply with the Code or any Company policy is treated very seriously and may result in disciplinary action.

Employee Responsibilities

• Read and be familiar with the information in our Code.
• Act in a manner that is safe, ethical, and consistent with applicable laws and regulations.
• Raise questions and concerns if you become aware of possible violations of laws, regulations, or our Code.
• Co-operate fully when responding to an investigation.

Interaction with the Authorities and Improper Payments

KORRES policy is to deal honestly and fairly with government authorities and to comply with valid governmental requests and processes. Payments made to any foreign agent or government ocial must be lawful under the laws of Greece and the foreign country. Payments by or on behalf of KORRES SA to foreign agents or government ocials should always be strictly for services rendered and should be reasonable in amount given the nature of those services. It is against KORRES SA policy (and may be a breach of law) to oer or make a payment or gift of any kind in order to facilitate a local process or to influence a local government ocial. Under no circumstances may a partner make payments in violation of the law or to induce a government ocial to do business with KORRES SA.

If you are contacted by a government or regulatory representative and asked to provide information or submit to an inspection, you should inform your manager or Internal Audit immediately. We must be truthful and straightforward in our dealings with the government and may not direct or encourage another partner or anyone else to provide false or misleading information to any government ocial or representative. Partners must not direct or encourage anyone to destroy records relevant to an investigation.

What we need to know

• An improper payment involves any transfer of value that is unlawful under applicable law or not permitted by customer rules or the Company’s policies.
• Never give – or authorize a third party to give – a gratuity to a government ocial to expedite a service or to influence the outcome of an investigation. Same rules apply when receiving a payment.
• Improper payments can expose you and the Company to criminal prosecution and other similar risks. Always seek advice to Internal Audit or Legal department if you are uncertain about the legitimacy of any payments.

Q: During a bidding process for a new vendor, one of the vendors gives money to the employee of Procurement department in order the latest to choose him out of the other candidates. Is this potential transaction a breach of the Code?
Α: Yes, this payment is considered a bribery and is prohibited by the Code

Conflict of Interest

Conflict of interest arises when the personal interest of an employee can potentially aect his ability to make objective decisions for the Company.

What we need to know

• We need to be sure that we have fully understood the dierent ways a conflict of interest can arise.
• A conflict of interest that was notified but not disclosed in order to be managed can cause the integrity of the employee to be questioned.
• A conflict of interest can also arise between the interest of the company and the members of our family or close friends.
• Never use your position within the Company for personal benefit or to benefit a family member. Avoid personal financial transactions with customers and suppliers that may influence your ability to perform your job.

Q: I work for Procurement department and I need to select asupplier for the Company. One of the suppliers being consideredis a company owned by my spouse. Do I need to take anyprecautions?

A: While your interest in your spouse’s business conflicts –or atleast appears to conflict– with your responsibility to select thebest supplier for the Company, you should communicate the caseand ask for advice. The best course of action is for your spouse’sbusiness to be eliminated from consideration.Health and Safety

Health and Safety

Nothing is more important for us than the healthand the safety of our people. Thus, we must be vigilantand disciplined as far as the safety regulations areconcerned. Each one of us must be a role model for thesafety inside the company

What we need to know

• We do not undertake any work that we are not qualified to perform.
• The consumption of alcohol, drugs or any other substance that can put in risk the safety of the personnel is strictly prohibited.
• We speak up immediately in case of an unsafe condition. We should never assume that someone else has reported or will report a risk or concern.
• We make sure that we know the procedure that needs to be followed in case of an emergency (i.e., evacuation of the premises).

Inside Trading

Inside Trading is any non-public information regarding the Company or the plans of the Company which, if disclosed, would likely have an unfair advantage for the person that will make the trading (i.e., stock trading). Company also respects the privacy of all its employees, business partners and consumers. That is why their personal data are handled responsibly and in compliance with all applicable privacy laws.

What we need to know

• Inside trading is highly prohibited to any of the employees that have access to confidential information.

• The use and trading of confidential information is illegal.

Q: I was informed that the Company is going to acquire a small,publicly traded company. Can I acquire the stock of this companyin anticipation of the acquisition?

Α: No. Trading on material nonpublic information is illegal and aviolation of the Code, whether you are trading in the stockof the Company or the stock of another company.

Q: An employee from Sales department is preparing apresentation on a new product. She is excited about that andwants to discussit with a friend outside the Company. She is not sure if that wouldbe a Code violation, so she checks with Internal Auditdepartment. Can she discuss it with her friend?

Α: It was the right action to discuss it with the internal auditor aseven if the recipient does not work for a competitor, customer,or supplier, sharing nonpublic information is a Code violation.

Gifts, Meals, and Entertainment

It is a common practice to exchange gifts and entertainment with customers and suppliers. The important thing in such exchanges is to maintain an arm’s-length relationship. Avoid excessive or lavish gifts, meals or entertainment that may give the appearance of undue influence. Always consider whether the gift, meal, or entertainment you plan to give or receive could be regarded as excessive or inappropriate, could lead to or imply any obligation, or could be interpreted as a bribe.

What we need to know

• Do not accept gifts, meals or entertainment, cash, or cash equivalents in exchange for doing, or promising to do, anything for a customer or supplier.
• This is an area in which your judgment is critical. For instance, a modest gift from a supplier in accordance with local custom, and for purposes of enhancing the goodwill of a legitimate business relationship, is usually fine. But an expensive weekend trip may not be. It is sometimes dicult to define excessive, yet in certain occasions, individual modest gifts could be deemed excessive because of their aggregate value and relevant circumstances (an expensive bottle of wine). Same rules apply for gifts for customers, potential customers, and suppliers. If you are uncertain, seek prior advice from the Internal Audit department.

Q: A supplier with whom you are seeking to improve yourrelationship invites you and your spouse to a Greek island for acouple of days. Travel and five-star hotel accommodation are paidby the host. Can you accept the invitation?
A: Because a business agenda seems to be absent in thisextravagant event, you should politely decline the invitation.However, if the event does have substantial business content thatis valuable to the Company, you may accept the invitation if youreceive advance written approval and the Company pays for yourtravel and expenses. Travel and expenses for your spouse willhave to be paid by you.

Human rights, working conditions and discrimination

Our culture is established on the belief that the basichuman decency should be the cornerstone of everythingwe do. Ethics and integrity are fundamental to ourinteractions with our people, customers, and our partners.At Korres, we are committed in oering the best possibleworking conditions, ensuring the wellbeing, physical andmental of each one of our team members. We encouragea culture of respect, dignity, honesty, care, immediacyin communication, equal access to information andopportunities. We respect the right of individuals toachieve professional and personal balance in their lives.In addition, we ensure that at any stage of our operation,we follow the internationally recognized human rightsprinciples as depicted by the United Nations’ InternationalDeclaration of Human Rights and InternationalConventions on child labor. Not only we comply with allapplicable laws but we aim to promote respect for humanrights within areas of our influence, including ourinvestment / partnership decisions.

Reasonable working conditions

All employees are provided with a binding employmentcontract describing the key conditions of theiremployment, e.g., working hours, pay and benefits,overtime pay, holidays, parent leave, breaks, access tocompany facilities, etc. Health and Safety is a priority atKorres. As such we organize training sessions on a regularbasis for emergency case management and first aid whileat the same time, we have ensured the appointment ofemergency project team at all our venues.

Forced and child labor

We operate in a diverse world in culture and workplaceand as such we embrace diering viewpoints, ourcollective strength, which bring value to our business.Yet, we dissociate ourselves from all forms of forced labor,slavery, torture, cruel, inhuman, or degrading treatment,retainment of identification papers, tracking of humanbeings or repayment of debt through work and any otherform of working conditions that may pose a threat to life orhealth as well as child labor. We employ only people whohave completed the legal work age limit and as such nochildren are allowed to work at our premises or participatein the production of our products. Our plant and logisticcenter are regularly audited for conformance to thesestandards. In addition, we do not tolerate forced andcompulsory labor practices in our workplace. We treat oursuppliers and business partners with fairness and integrityand we build long term relationships with those whocomply with the above-mentioned standards. We ensurethe compliance by monitoring the operation of ourcontractors at any stage of the production. Ouryear-to-year performance about all these areas willcontinue to be described in our Consciousness Report.

Working hours and breaks

Work Life Balance is a priority for our people. At Korres,we ensure that working hours schedule is communicatedto all and as such any additional need for work beyondthat is announced to the Labor Authorities and iscompensated accordingly. The working schedule allowsbreaks for eating, drinking, resting without being associatedwith any form of disciplinary action.

Non-discrimination and equal opportunities

At Korres, we are committed in maintaining an inclusiveenvironment with equal opportunities oered to all.We do not engage in or support discrimination based onrace, color, sex, language, religion, political or other opinion,caste, national or social origin, property, birth, unionaliation, sexual orientation, health status, familyresponsibilities, age, and disability or other distinguishingcharacteristics. Hiring, remuneration, benefits, training,advancement, discipline, termination, retirement,or any other employment-related decisions are only basedon relevant and objective criteria linked to the role orperformance. In addition, any form of harassment ordiscrimination-based race, color, sex, sexual orientation,gender identity or expression, creed, religion, age, maritalstatus, national origin, ancestry, pregnancy, medicalcondition, veteran status, citizenship, physical or mentaldisability is not tolerated. All our premises are accessibleto people with special needs, and we have made specialarrangements for areas within them so as all requirementsare met. We also ensure that our recruitment process treatsinternal and external candidates in the same manner.

Right to privacy

We ensure the right to privacy of our employees. Theretrieval of private data about employees complies withthe legislation in force at any time and is always justifiedby a legitimate business purpose, which has been madeknown to the employee. Personal data is provided by therespective employee himself, unless the employee hasgiven his consent in writing to having a third party retrievethe information.


The Company recognizes its responsibility for theprotection of the environment and natural resources.We always operate our facilities and conduct ouroperations in compliance with all applicable environmentallaws, regulations and permits. Throughout our operations,we consider the environmental implications of thebusiness decision that we make. In doing so, we seek tosupport environmental sustainability and biodiversity.The Company continuously seeks to prevent pollutionand to reduce the environmental impacts of its productsand services during design, procurement, manufacturing,use and end-of-life. We are simply following ourconscience, a full circle, from the seed, to the extract,to the formulation, to the water purification, to theproduct, to the re-use of every component of it.

What we need to know

• By working continuously to reduce the environmental impacts of its products, the Company enables customers and users to reduce their environmental footprints.
• Be aware that non-compliance with environmental laws can lead to civil and potential criminal liability.

Fair Competition

Fair competition is intended to promote vigorouscompetition in a free market. It is in KORRES best interestto promote free and open competition. KORRES mustmake its own business decisions, free from understandingsor agreements with competitors or suppliers that restrictcompetition. We consider compliance with these laws ofvital importance.

What we need to know

When conducting KORRES business, all partners must:
• Not discuss pricing, production, or markets with competitors
• Not set resale prices with customers or suppliers
• Always present KORRES services and products in a manner consistent with our core values
• Not induce a third party to breach an existing agreement
• Never act in a manner that could be seen as an attempt to exclude present or potential competitors or to control market prices

Q: I am going to a trade show. May I go to a competitor’s booth?
A: Yes. You may go to the booth and collect any publicly distributed material. However, if you talk to anyone at the booth, identity yourself as a KORRRES partner, and avoid conversations about business.
Q: A salesperson for a competitor and I are friends. Occasionally we talk about marketing plans. Should I be concerned?
A: Yes. You are revealing confidential information that KORRES has invested time and money to develop. You also may be violating competition laws that ban discussions of marketing and pricing with competitors

Application of the Code

The Code applies to everyone working for the Companyregardless of location, role, or level of seniority. Thisincludes all Employees, Managers and Directors of theCompany.

When do I need to Speak Up?

Each one of us has the responsibility to report in case a breach (or potential breach) of the Code is noted.
There are three ways that someone can report(anonymously or not):
i. Via email at (for Code of Conduct related issues)
ii. Via email at (for Whistleblowing Policy related issues)
iii. Via email at (for Anti-Harassment Policy related issues)
iv. Via mail using the address KORRES SA, Ermou 25, Kifisia 14564, Greece, with the reference “for Internal Audit”.
v. Via personal meeting with Legal Department or the Internal Audit Department

No retaliation

The Company appreciates the contribution of employeeswho identify potential problems that need to be addressed.Any retaliation against an employee who raises an issuehonestly, is a violation of the Code. The fact that anemployee has raised a concern, or participated in aninvestigation, cannot be the basis for any adverseemployment action, including separation, demotion,suspension, loss of benefits, threats, harassment, ordiscrimination. If you believe someone has retaliatedagainst you, report the matter using one of theabove-mentioned methods.

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