Business Ethics & Transparency

The Code guides our daily business conduct. It clearly sets out the ethical principles and values, as well as the internal rules of conduct and ethics that must be followed by everyone who has a working relationship or collaboration with Growthfund. Compliance and commitment to the values, principles, and rules of the Code is a collective responsibility that we all share.

Our principles and values

To achieve Growthfund’s mission and vision, a framework of principles and values is required, which govern our daily conduct and practices, and determine our responsibilities while we exercise our duties.

Public interest

We commit to better management and development of public property, aiming at creating long-term value, increasing revenues for the state, and providing better services to citizens.

Integrity

We act with integrity, honesty, and diligence in all our activities, defending the Company and the public interest, beyond any personal or other private gain. We behave in an objective manner, not permitting conflicts of interest, and third-party influence of our professional judgement.

Transparency, accountability, and consultation

We operate with transparency, accountability, and open communication, information, and consulted with all stakeholders. We aim to build and strengthen trust with citizens in the procedures and operation of HCAP and its subsidiaries.

Effectiveness and innovation

We promote efficiency and innovation in all our activities. We aim to soundly and swiftly implement the strategy and decisions. We encourage the development of new solutions and ideas that add value and improve the quality of services to citizens.

Meritocracy and social responsibility

We act based on merit, promoting diversity, and ensuring equal treatment and opportunities in the workplace, while not allowing prejudices.

• Code of Ethics and Professional Conduct

Business Ethics Program

We are committed to a high level of integrity, which is expected from every employee across all the companies in our portfolio, and we enforce a zero-tolerance policy for irregularities or inappropriate behavior. We have developed and implemented an innovative business ethics and integrity program aimed at raising employee awareness, preventing, identifying, and resolving potential issues.

This program is based on policies, procedures, and modern tools and mechanisms for risk prevention and management, and is applicable to Growthfund and its subsidiaries.

Prevention of Conflict of Interest Situations

We act with integrity, honesty, and diligence in all our activities, safeguarding Growthfund and the public interest above any personal or private gain. We behave objectively, ensuring that conflicts of interest are avoided and that our professional judgment is not influenced by third parties.

Anti-Corruption and Bribery process

We do not tolerate any form of corruption or bribery, nor behaviours, actions, or omissions that could expose Growthfund to risk or even raise mere suspicion of corruption or bribery. Recognizing the importance of combating corruption and bribery and wanting to demonstrate the Management’s unwavering commitment to zero tolerance for such phenomena, we have established a series of policies, procedures, and control mechanisms that are applied both at the Growthfund and its subsidiaries.

• Anti-Corruption and Bribery Policy
• Corporate Social Responsibility Policy
• Whistleblowing Policy
• Policy on personal data processing & Protection and use of communication means

Our Company applies high standards of transparency and integrity across the entire organization (including its subsidiaries) and expects all third parties with whom it conducts business to fully adhere to its principles and values, as well as to demonstrate professional and ethical behaviour. The relationships of the Company with the third parties with whom it conducts business must be governed by transparency, integrity, trust, respect, and sincerity, in order to ensure both effectiveness of the cooperation and the Company’s reputation and reliability.

We expect that the people that we work with, particularly our suppliers and representatives, not only uphold our values and standards but also share in the responsibility, complying with laws and sustainability principles and policies.

In this context, before the commencement of any business relationship with third parties, the relevant due diligence procedure must be applied as described in the Third Party Due Diligence Policy.

For more information, refer to our Policy and Process on Third Party Due Diligence.

Growthfund’s business ethics training program places particular emphasis on the training and awareness of all employees and partners across all companies in our portfolio. Our goal is to ensure that employees have all the necessary tools to be both effective in their roles and to further develop themselves.

Face to face training 

We believe that face-to-face training is highly effective and ensures deeper engagement. Therefore, all employees are required to attend training sessions on Compliance and Business Ethics.

E-learning

Through Growthfund’s Business Ethics Training Platform, an accessible platform offering courses on compliance and business ethics, employees can explore our focus areas outlined in the Code of Conduct and specific policies and procedures on Business Ethics through interactive content.

Access the portal here.

We are creating an open and productive work environment where employees act responsibly and feel they have the opportunity to participate actively and take initiatives.

Growthfund’s key priority is the promotion and upholding of diversity and equal opportunities in the workplace within its subsidiaries. We place increased emphasis on social inclusion and promote the establishment of a holistically inclusive work environment across our portfolio companies.

• Equal Opportunities and Diversity Policy
• Anti-Harassment in the Workplace Policy
• Workplace Sexual Harassment Prevention Manual

Growthfund adopts and promotes a new culture of zero tolerance for irregularities or inappropriate behaviour, encouraging their resolution through modern approaches. To this end, a whistleblowing system has been established for reporting irregularities and inappropriate conduct, which plays a crucial role in informing and preventing such incidents. This is an international best practice, involving effective and secure reporting channels for Growthufnd and its subsidiaries.

To this end, SAFEVOICE platform has been developed and is available 24/7.