AT A GLANCE
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REPORT
4 | Governance & Transparency Operating within a highly regulated and controlled industry, we are obliged to comply with various laws and regulations. As a result, we adopt practices to facilitate long-term planning, decision making and risk management to conduct our business ethically.
Embedding responsibility into the way we operate Work Regulations: Our Work Regulations aim to form necessary behaviors for effective operations and include disciplinary offences on issues such as: • Breach of confidentiality or secrecy relating to our information • Failure to comply with our rules and guidelines, such as providing or accepting bribes, use of our equipment and workforce (including third parties) to carry out own work or our Health and Safety rules. In such cases, penalties imposed may include: • Oral or written reprimand • Written rebuke • Temporary suspension of up to 10 days within the entire calendar year • A fine of up to 1/25 of the salary, with the fines imposed paid into a special bank account in favour of the Hellenic Manpower Employment Organisation (OAED) or wherever else specified by law. Code of Business Conduct and Ethics: We have adopted Eldorado Gold’s Code of Business Conduct and Ethics, which defines the expected behavior from all our employees (including directors and officers), contractor employees and suppliers conducting business on our behalf. We therefore: • Brief and train all new hired employees (through their Induction Training Program) and our employees on the Code, with an obligatory training conducted during 2020 through our online platform, which was available to 100% of our employees in office and management positions
• Have established a mechanism for employees and any Stakeholder to submit their concerns regarding any actual or potential behavior concerns. Our CSR & Community Relations Department handles these concerns received either through a designated e-mail address, verbally (e.g. phone) or through designated boxes at all Kassandra Mines sites, and in most cases we inform Stakeholders who raised such concerns by name about the proposed resolution. Furthermore, we have established the EthicsPoint whistle-blowing hotline for employees and any Stakeholder to confidentially submit their concerns regarding any actual or potential behavior which violates laws, government regulations, Health and Safety principles or Code principles, with the Compliance Department and Eldorado Gold Global Compliance Director handling all grievances. During 2020, there was 1 concern submitted via email, related to subcontractors and not associated with legal compliance.
100%
of employees formally committed to accept our Code of Business Conduct and Ethics
30%
of employees trained on our Code of Business Conduct and Ethics in 2020
0
violation cases concerning our main business principles and rules
0
legal compliance concerns through the whistle-blowing mechanism
• Have posted the Code in communal work areas and on announcement boards at all sites
Besides the Code of Business Conduct and Ethics, we have adopted the following Eldorado Gold’s policies:
• Enable employees to anonymously report any violations
• Environmental Policy
• Require all department heads to communicate the Code to their employees every year, who must review and resign to accept the Code
• Health and Safety Policy
• Consider that non-compliance with laws, governmental regulations and Code principles may lead to disciplinary measures, including dismissal
• Anti-Bribery and Anti-Corruption Policy (last updated in 2020) • Human Rights Policy • Insider Trading Policy.
Sustainability Report 2019-2020
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