WHISTLEBLOWING MECHANISM

ALG Manousakis Law Firm, (“ALG” or “we”), is committed to conducting our business with honesty and integrity and we expect all staff to maintain high ethical and professional standards. Any suspected wrongdoing should be reported as soon as possible.

To this extent, ALG provides an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace (“Whistleblowing Mechanism”) in compliance with Greek Law 4990/2022 on Whistleblowing implementing Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.

The Whistleblowing Mechanism aims to encourage individuals, to submit named or anonymous reports of violations that they may perceive in the context of or in connection with their professional relationship with ALG, under the conditions that are defined in this letter and ALG’s internal Whistleblowing Policy.

Who can submit a report:

A report can be submitted by all persons with a professional connection to ALG, including but not limited to the following:

  • All former, current and future employees including partners, lawyers and trainees
  • Self-employed individuals, including contractors and consultants, volunteers, casual workers and agency workers
  • Other individuals with a professional connection to ALG including but not limited to: vendors, service providers, and suppliers
  • Third-party legal and natural persons connected to the above (e.g. witnesses, relatives etc.), who potentially may face repercussions in connection with a submitted report

Who can report a concern:

A report may concern any wrongdoing in relation to the following:

  • any kind of criminal activity
  • failure to comply with any legal obligations
  • public procurement
  • money laundering, bribery and financial fraud
  • environmental damage
  • consumer rights
  • privacy, confidentiality and security
  • danger to health and safety
  • facilitating tax evasion
  • breach of our internal policies and procedures
  • conduct likely to damage our reputation or financial wellbeing
  • unauthorized disclosure of confidential information
  • the deliberate concealment of any of the above matters

How can a report be submitted:

The above concerns can be reported by reaching out to our Whistleblowing Officer:

  • via phone (+30 2107232761), or
  • via email (compliance@alg.gr), or
  • via post (16, Laodikias Str.| 11528 | Athens), or
  • orally at a personal meeting with our Whistleblowing Officer (16, Laodikias Str. | 11528 | Athens)

All reports will be treated with objectivity and confidentiality. ALG ensures that access to received reports is restricted to authorized individuals only.

Can a report be submitted anonymously?

If you do not feel comfortable revealing your identity while submitting a report, you can always submit a report anonymously via mail or telephone. Nevertheless, you should be aware that a proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible.

What to keep in mind while submitting a report?

The information included in the report about the reporting and the reported individuals may result in decisions that affect others. Therefore, all reporters must:

  • have reasonable grounds to believe that the report falls within the scope of the law and is true at the time of reporting, and
  • provide full and clear details and, where possible, supporting evidence to demonstrate sufficient grounds for concern

How will ALG process your report?

Following the submission of the report, the reporting person:

  • will receive an acknowledgement of receipt within 7 working days
  • may be offered the opportunity to provide further information and if necessary, attend an assessment meeting. Reporters who have elected to remain anonymous may decline this offer
  • will be informed of the outcome of the investigation within a reasonable timeframe, not exceeding three (3) months from the confirmation of the receipt of the report or, if no confirmation has been sent, within three (3) months from the end of the 7-day period after the submission of the report

After that, the Whistleblowing Officer will document the report.

ALG is committed to impartially investigating all reports in accordance with the applicable laws and to protecting the reporting individuals from any detrimental treatment. Anyone engaging in retaliation against a reporter is in violation of our policies and may face disciplinary action, up to and including dismissal.

Can you submit your reports to an external body?

The law recognizes that in some circumstances, especially when you assess that your report has not been effectively addressed, it may be appropriate for you to report your concerns to an external body such as the National Transparency Authority (NTA). We strongly encourage you to seek advice before reporting a concern to anyone external.

Such report is filed either in writing or through the online platform (accessible also to persons with disabilities) as follows:

  • via online form available at: https://aead.gr/submit-complaint/
  • via email: kataggelies@aead.gr
  • via mail: 195, Lenormann & Amfiaraou St., GR – 104 42, Athens
  • orally at a personal meeting: 195, Lenormann & Amfiaraou St., GR – 104 42, Athens

How is your data processed?

In the context of the Whistleblowing Mechanism, all relevant personal data collected and associated with a report will be processed in compliance with the applicable privacy and personal data protection laws to:

  • Receive and process the reports
  • Conduct internal investigations and
  • Document the reports

Most commonly, the legal grounds will be the following:

  • Consent – the processing is initiated based on the authorization of the reporting individual through the filing of the report
  • Legal obligation – the processing is necessary to comply with legal or regulatory requirements
  • Legitimate interests – the processing is necessary for our legitimate interests or the legitimate interests of a third party, e.g., to promote workplace safety, employee well-being, upholding ALG’s ethical values, and preventing misconduct

For the purpose of investigating your report and subject to the provisions of local law, the personal data collected and associated with a report may be accessed, processed and used on a “need to know” basis by the relevant personnel within ALG and may also be transferred to competent supervisory and judicial authorities in the context of their investigations.

Depending on your jurisdiction and to the extent permissible by the applicable privacy and data protection laws, you may have certain rights in relation to the personal data that ALG processes about you. For example, you might have the right to:

  • Request access to your personal data
  • Request correction of the personal data that we hold about you
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request the restriction of processing of your personal data
  • Request the transfer of your personal data to another party

For more information on how your personal data might be processed by ALG, please consult our Privacy Policy and/or our data protection team by sending an email at: dataprivacy@alg.gr