INFORM has been built by the people employed in its companies. The focus on people is reflected in INFORM’s values, which have been fundamental to our success for many years.

While INFORM competes hard to achieve leadership and business success, it is concerned not only with results, but also with how those results are achieved. We at INFORM are aware that reputation is earned by our conduct – evident not only in what we say and, more importantly, what we do, but also in our products and services and the way we treat our customers, colleagues and the environment. Our reputation and our continued success depend on each one of us doing our part to uphold these values and the commitment to maintain the highest standards of business ethics and integrity in our everyday work.

As a business with international reach, we bear the responsibility to conduct ourselves ethically and in accordance with applicable laws and regulations wherever we do our business. Moreover, this Code of Conduct goes even beyond the compliance with applicable laws and regulations – as conscientious citizens and employees, we expect each employee to act ethically and with integrity and do what is right. We must use good judgment in deciding what course of action is most appropriate.

This Code of Conduct provides an outline of important policies, directives and guidelines for business conduct based on the values of INFORM. It is also a statement of commitment to employees that, while we value business results, we place equal value on how we achieve those results: we will not tolerate efforts or activities to achieve results through illegal or unethical dealings anywhere in the world. INFORM relies on every employee to make use of good judgment in their respective business dealings and in the everyday conduct. If you are in doubt as to the appropriate course of conduct, our senior staff and staff in charge will gladly provide advice and guidance.

Thank you for your contribution to INFORM’s dedication to compliance, integrity and ethics in our business conduct. Please remember that by acting consistently with these guidelines, we can each do our part to assure that INFORM maintains its reputation as a company which conducts its business with the utmost integrity.

Panagiotis Spyropoulos
Chief Executive Officer of INFORM

A. Responsibility
We are dedicated to meeting the highest standards of business ethics in all of our business dealings by acting responsibly. Our employees are competent, motivated, hard-working, and, most importantly, live this Code of Conduct in all of their actions and decisions.

B. Service to Customers
INFORM draws on four generations of successful printing and data processing experience and as a family organization is devoted to fulfilling the dreams and visions of its clients. We understand that the satisfaction and success of our customers is the key to our own. While we are focused on fulfilling the requests and needs of our customers, we are committed to doing so in a reliable, responsible and ethical manner. We know that we can only win our customers’ trust through the integrity of our actions.

C. Respect
The roots of our corporate culture that started in 1897 are those ideas, opinions and fundamental values that unite the members of INFORM and let them work together effectively and harmoniously. One of the most important elements of this corporate culture is respect – reflected in our conduct towards our customers and their assets, each other, INFORM’s assets.

D. Integrity
We are honest and straightforward with each other. We operate within the letter and spirit of the law. We always try to do the right thing. We defend the values and principles of INFORM in every action and decision.

E. Trust
We believe that people work best when there is trust. We have confidence in each other’s actions, capabilities and intentions. We strive to gain, maintain and preserve the trust our customers place with us.

F. Dedication to Quality & Innovation
We are dedicated to providing products and services of superior quality and value. To this end, we are constantly evaluating employed methods and new technologies, all the while focusing on innovation. We encourage and expect outstanding technical expertness and excellence.

G. Commitment to Society
Our success and prosperity allows our employees, stakeholders and the communities we live and work in to grow and prosper.

H. Commitment to the Environment
We examine and evaluate continuously and proactively the employment of new methods and technologies in our operational processes in order to minimize our impact on the environment.

A. Compliance with Applicable Laws and Regulations
INFORM and its employees are committed to complying with all applicable laws and regulations. We expect every employee to be knowledgeable of and to comply with the laws and regulations that apply to the respective employee’s business activities, wherever they are conducted. In particular, we expect the employees to comply with laws designated to protect health, safety and the environment, to obtain all required permits, to operate facilities and to conduct business activities in strict accordance with the applicable law.

In case that the business activity is not governed by any law or the applicable laws and regulations set unacceptably low standards, an employee is expected to abide by INFORM Values, to comply at least with the guidelines set out in this Code of Conduct and to conduct all actions with uncompromising honesty and integrity.

B. Improper Business Dealings
• Money Laundering

All INFORM employees are strictly prohibited from participating in or contributing to, directly or indirectly, any activity which might be deemed as money laundering.

• Commercial Bribery

INFORM competition for business is conducted fairly and on the merits of our products and services.

Any payment, bribe or the offering of a benefit to individuals employed by customers, consultants, suppliers or other collaborators of INFORM, or receipt of payment, bribe or benefit by any INFORM employee is strictly prohibited. Therefore, INFORM employees must not offer, make, facilitate, seek or accept, directly or indirectly, any gifts, payment, bribe, bonus, benefit, entertainment or other services to or from actual or potential business partners which might reasonably be believed to influence business transactions and which are not within the bounds of customary business hospitality or which are prohibited by applicable law.

• Improper Benefits to Government Officials

The granting of an improper benefit to a public official for the dutiful performance of their office responsibilities is an offence if it aims at influencing the official’s activity. Such public officials include not only public servants, but employees of companies owned indirectly or immediately by the state, province or municipality.

It is strictly prohibited to grant improper benefits to a public official. In dealing with public officials, INFORM employees must neither offer, promise nor give any improper benefits or other advantages, whether directly or through intermediaries, to obtain or retain business or any improper advantage in the conduct of business.

• Securities Trading

To ensure fairness and integrity in financial markets, INFORM employees do not trade in INFORM securities or those of any other company on the basis of non-public information acquired through employment.

• Conflict of Interest

All employees are obligated to act at all times solely in the best interest of INFORM. A conflict of interest arises when an employee has a personal relationship or financial or other interest that could interfere with this obligation, or when the employee uses its position for personal gain. All INFORM employees must disclose all potential conflicts of interest and must take appropriate actions to eliminate the conflict when they are requested to do so.

• Antitrust Policy and Fair Competition

All employees must strictly comply with all anti-trust/competition laws as well as anti-monopoly laws of all countries in which they conduct business.

We believe in competing fairly because we all benefit from fair, free and open markets. We compete strictly on the merits of our products and services and make no attempts to restrain or limit trade.

C. Fair Dealing with Suppliers and Customers
The sustainable success of INFORM depends on building productive relationships with our suppliers and customers based on integrity, ethical behavior and mutual trust.

• Treating Suppliers Appropriately

Our suppliers are valued partners in the success of our business. We expect fair competition in the market and apply the same standard in dealing with suppliers – our relationship with them is characterized by honesty and fairness. An employee dealing with suppliers is expected not to show any favor or preference to any person or business based on anything other than INFORM’s best interest. The business dealings on behalf of INFORM must not be influenced by personal interests.

• Treating Customers Appropriately

INFORM recognizes that our customers have individual needs and expectations representing unique opportunities for mutual success. We strive to enable our customers to gain competitive advantage by adding value through the quality of our products and services and to gain our customers’ trust by acting honestly and with integrity.

• The Government as a Customer

INFORM products are often purchased by governments. In this case, all INFORM employees are expected to strictly obey by the laws and regulations which govern the acquisition of goods and services by governmental entities or entities close to the government. All statements and representation to government procurement officials must be accurate and truthful, including costs and other financial data.

D. Employment
INFORM will consider all candidates for employment opportunities on the basis of merit, as measured against objective job requirements.

INFORM expects each employee to support the INFORM’s commitment and continuing efforts toward equal employment opportunity for all. INFORM is committed to compliance with all applicable laws and regulations relating to equal employment opportunity, non-discrimination and similar employee-related matters.

E. Our Work Environment
• Respect in the Workplace

A fundamental INFORM policy is that we treat all of our INFORM colleagues with respect. We at INFORM recognize the power and potential that comes from people of diverse backgrounds and experiences. Our policy forbids any discrimination, harassment or intimidation on the basis of race, color, religion, gender, age, national origin, citizenship, sexual orientation or disability.

• Employee Privacy

INFORM respects employee privacy and dignity. We will only collect and retain personal information of employees that is required for the effective operation of INFORM or as required by law. We will keep such information confidential and release it only to those who have a legitimate need to know.

• Child Labor and Worker Exploitation Policy

INFORM does not use child or forced labor in any of its operations. We will not tolerate any working conditions or ways of treating employees that violate international agreements such as the United Nations Universal Declaration of Human.

We expect our suppliers and contractors with whom we do business to uphold the same standards and principles. Should a pattern of violation of these principles become known to the any company of INFORM and not be corrected, we will discontinue the business relationship.

• Health & Safety

INFORM is committed to having safe, healthy and incident-free operations in order to protect the life and health of its employees and the community surrounding its operations. The implementation of appropriate health and safety standards throughout INFORM sites remains a key responsibility of all our managers and employees. Each employee has a personal responsibility to other INFORM employees and to the INFORM to help eliminate actions or circumstances which undermine this environment.

• Environmental Policies

INFORM seeks to achieve clean, safe and environmentally friendly operations at all of our sites. This is assured by internally imposed standards of operations and processes, which are within the letter and the spirit of the applicable laws and regulations. We continually strive to improve the environmental quality of our products, packaging and operations.

F. INFORM’s Assets
INFORM’s physical assets, intellectual property rights, data and information are those instruments that enable the employees to perform their duties and are pre-requisite for the smooth-running of the business operations. Consequently, these instruments must be handled with special care and protected against loss, theft, damage or unauthorized disclosure. Employees must refrain from all actions which could be detrimental to INFORM’s assets.

• Company Records

INFORM’s business records are depended upon to produce reliable and accurate reports to stakeholders, management, shareholders, creditors, investors, governmental entities and others. Thus, all official records regarding INFORM’s business must be accurate and complete and above all, in accordance with accounting principles. All INFORM operations must comply with all local and national laws relating to the accurate and complete maintenance of financial books and records. Employees are expected to be honest, objective and loyal in the performance of record keeping responsibilities. False, misleading or fraudulent documentation or recording is illegal.

• Intellectual Property Rights

Intellectual property rights such as patents, trademarks, copyrights, etc., are valuable assets of INFORM . For this reason, we take special care in order to protect our intellectual property rights. On the other hand, we are mindful of the intellectual property rights of third parties.

• Confidential Information

In order to protect INFORM’s assets and interests we must protect its confidential information. Therefore, we exchange confidential information with third parties only if a confidentiality agreement has been duly executed with such third party.

Moreover, we protect confidential information received from our partners from unauthorized disclosure.

H. Reporting Non-Compliance
All INFORM employees are expected and directed to notify their direct superiors – which in turn are obligated to notify the senior management – when they believe a violation of law or INFORM policies has occurred. All employees are required to report any suspected or observed violations of the law, of this Code of Conduct and/or of company policies.

All contacts and reports will be treated confidentially and looked into carefully. Making a report will have no negative consequences for the respective employee, unless the employee deliberately makes a false accusation.

I. Violations of the Code of Conduct
Compliance with this Code of Conduct is essential and pre-requisite for ensuring INFORM reputation and sustainable success. Each employee is expected to fully comply with all applicable laws and regulations, this Code of Conduct and other INFORM policies.

INFORM will not tolerate or excuse any violation of this Code of Conduct. A violation of this Code of Conduct will lead to disciplinary measures – from a verbal warning or written reprimand up to and including dismissal.

• Community Relations

INFORM and its employees have a long-standing commitment to being good citizens and neighbors in all the places where we do business around the world. We believe we have a responsibility to society to use its resources – money, people and energy – wisely. We satisfy our commitment through financial support for a wide range of educational, health, social service, cultural, civil and environmental organizations. Through our activities, we also contribute to the economic and social well-being of a range of other stakeholders, including employees, shareholders, local communities in which we operate.

• Sustainable Development

Sustainable development, or sustainability, integrates economic progress, social responsibility and environmental concerns with the objective of improving the quality of life for everyone, now and for generations to come. Over the past several years, academics, governments and non-governmental organizations have been evolving their views of environmental quality to the broader, more holistic concept of sustainable development. While some see this as inevitably leading to restraining consumption, we view it as an opportunity and stimulus to innovate and to improve people’s lives, while also making important contributions to environmental quality, economic development and social issues.

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