Code of Business Conduct and Ethics

We, in BEVALDIA, perform our operations in honesty and morality in any place of the world in which we are operational.
We constantly improve the quality of services, products and operations and we maintain our fame, honesty, fairness, respect, responsibility, integrity, trust and our good business judgment.
There is no illegal or unethical conduct on behalf of either the directors or the employees or the branches that is to the benefit of the company.
We, in BEVALDIA, will not jeopardize our principles for the short term benefit. The moral performance of our company is the sum of the morality of the men and women working here.

Our professional ethics is to have the courage to say and do the right thing. To have the integrity to deal with others with respect. To avoid conflict of interest between personal and professional relationships.
The entire staff of BEVALDIA has an ethical behavior, thus contributing to the high esteem the company has gained.
Respectable working environment .
BEVALDIA provides services in more than 23 countries.
We all have our part in ensuring that our workplace is respected and professional. We are all expected to:
- Promote a working environment without discrimination or harassment due to race, color, religion, sex, nationality, disability or any other factor.
- Perform our operations in full compliance with the international standards of environmental practice.
Anti Bribery Policy
BEVALDIA, located at 124 Kifisias Avenue, Marousi, operates in the Diving Services & Consulting sector. Top Management is fully committed to the establishment, implementation, maintenance, and continual improvement of BEVALDIA’s Anti-Bribery Management System (ABMS), as well as to meeting all applicable anti-bribery management system requirements and legal obligations. This Policy aligns with the company’s core purpose and operational activities.
BEVALDIA upholds the highest standards of ethical behavior, requiring Top Management, personnel, business associates, and all stakeholders to adhere strictly to this Policy without exception. All employees, including Top Management, receive dedicated training regarding these anti-bribery principles.
Core Principles & Prohibitions
Prohibition of Bribery: BEVALDIA strictly prohibits bribery, corruption, and any form of illegal conduct. Non-compliance may result in severe disciplinary action, including summary dismissal or termination of commercial relationships, in accordance with applicable law and contractual agreements.
Facilitation Payments: Bribes and facilitation payments are strictly prohibited across all operations, even if locally tolerated in jurisdictions where business is conducted.
Gifts & Hospitality: Giving or receiving gifts and hospitality is permissible only when reasonable, proportionate, and tied to legitimate business relations. Any gesture that risks influencing decision-making is strictly forbidden.
Donations & Conflicts of Interest: Political and charitable donations are prohibited without the prior written authorization of the General Manager. Personnel and business associates must promptly declare any actual or potential conflicts of interest, and employees may not engage in outside business activities without explicit written approval.
Business Relationships & Due Diligence
BEVALDIA will not enter into or continue business relationships involving corrupt practices. Where legal or commercial environments differ internationally, the General Manager determines the appropriate due diligence procedures prior to engagement.
Agents, contractors, and third parties representing or acting on behalf of BEVALDIA are required—through contracts, formal terms of engagement, or accepted codes of conduct—to comply with the principles of this Policy. All remuneration and expense reimbursements must be lawful, reasonable, justified, and supported by full documentary evidence.
Governance, Reporting & Compliance
Anti-Bribery Function: Designated with operational independence and authority, the Anti-Bribery Compliance Function provides guidance, oversees ABMS implementation, investigates concerns, and maintains direct, unrestricted access to Top Management.
Reporting & Non-Retaliation: BEVALDIA encourages personnel and external partners to report suspected breaches in good faith or on the basis of a reasonable belief through confidential reporting channels. Retaliation against anyone raising concerns is strictly prohibited, and failure by management to address reported concerns constitutes a serious disciplinary offense.
Continual Improvement & Objectives: This Policy provides the framework for setting, monitoring, and reviewing anti-bribery objectives. Top Management and the Compliance Function review the system at least annually, maintaining an explicit commitment to the continual improvement of the ABMS to ensure ongoing effectiveness in mitigating risk.
Communication & Accessibility
The General Manager ensures this Policy is maintained as documented information, communicated and understood across all operational levels, and provided to business associates posing more than a low risk of bribery. This Policy is accessible to all employees, clients, suppliers, and interested parties.
Any observations or concerns must be reported immediately to: [email protected]
THE GENERAL MANAGER
01/09/2026