Anti-Corruption and Bribery Policy
Introduction & to whom it applies
UpcoMinds maintains a zero-tolerance stance on corrupt practices. This policy applies to all employees, directors, subcontractors, affiliates, and joint ventures working on behalf of the company.
Our commitment
The organization prohibits bribery in all forms - whether monetary or non-monetary. The offer, payment, authorization, solicitation and acceptance of bribes and other improper advantages is unacceptable. Bribes may include payments, gifts, entertainment, loans on non-commercial terms, political contributions, or employment offers.
The company expects business partners to share this commitment and prohibits third parties from engaging in corruption on UpcoMinds' behalf. Employees are encouraged to report concerns through management channels, with zero tolerance for retaliation against good-faith reporters.
Consequences for breaches range from warnings to termination.
Dealing with Third Parties
All third-party agreements must be written and require compliance with anti-corruption laws. The company acknowledges potential liability if third parties act improperly on its behalf.
Sustainability Policy
UpcoMinds is Committed to
- Promoting sustainability
- Complying with relevant legislation
- Preventing pollution
- Pursuing continuous improvement
Guiding Principles
The organization integrates sustainability into business decisions, ensures staff awareness and commitment, and minimizes impact from office and transportation activities.
Practical Steps
Travel and Meetings: The company encourages walking and public transport use, promotes teleconferencing alternatives, and supports teleworking arrangements.
Purchase of Equipment: UpcoMinds minimizes paper use through double-sided printing and digital document distribution. The company recycles equipment and office waste while purchasing energy-efficient products.
Working Practices: All personnel consider sustainability in client advice, include the policy in proposals, and receive training on sustainability topics.
Quality Policy
For UPCOM, quality means services in software development, customization, installation, and support that fully satisfy customer needs per agreed specifications.
Management Commitment
Management commits to the Quality Policy, communicates it throughout the organization, and provides necessary resources for adherence. The company ensures compliance with Greek and European legislation and reviews policy objectives annually.
Quality Objectives
- High customer satisfaction
- Financial development
- Consistency in product quality and project execution
- Company promotion
- Employee development and effective human resource management
- Continuous organizational improvement aligned with Quality Management System standards
Implementation Principles
Management provides pleasant working conditions and emphasizes legislative compliance. The organization conducts training programs, cooperates with approved suppliers, and ensures each employee owns their work quality. Department managers oversee departmental quality; a Management Representative (Quality Manager) ensures ISO 9001:2015 compliance.
The company documents audit information for continuous improvement and takes immediate corrective and preventive action on deviations.
Business Continuity Policy
Upcom considers business continuity assurance strategically significant across all activities and commits to continuous system improvement based on ISO 22301:2019 standards.
Key Objectives
- Clear identification of customer and stakeholder requirements with resource assurance
- Documented investigation of problems and weaknesses for corrective action implementation
- Risk analysis and effectiveness control
- Legislative and regulatory compliance with systematic monitoring
- Continuous improvement of products, services, and the overall system
- Employee adequacy through continuous training
- Clear, measurable objectives with performance evaluation toward continuous improvement in unexpected event preparedness and uninterrupted service/product delivery
The company ensures system effectiveness through operational process procedures, supplier-partner controls, and periodic management reviews. The policy is communicated to all employees and collaborators and reviewed annually.
Information Security Policy
UPCOM commits to developing and implementing information protection policies against internal and external threats through multiple measures.
Physical and Access Security
- Building facility security policies prevent unauthorized physical access
- Personnel and equipment protection from physical disasters
- Logical access control policies restrict unauthorized electronic file access
- Mobile media usage policies reduce data loss, leakage, and unauthorized access risks
Data Protection and Compliance
- Confidentiality policies manage personal, sensitive, and corporate data appropriately
- Intellectual property rights policies are adopted and implemented
- Backup and recovery policies ensure information security and integrity
- Network usage and internet/email policies prevent malicious network breaches
- Clean desk policies prevent information leakage
- Third-party and supplier controls ensure their activities don't affect information availability, integrity, and confidentiality
- Software installation policies prevent compromise of information security
- Full compliance with applicable legal, regulatory, contractual, and information security requirements
Governance and Continuous Improvement
The company reviews security policies and strategies annually, identifies and manages ongoing threats through continuous mechanisms, confirms data confidentiality, develops and tests disaster recovery and business continuity plans, and creates mechanisms for recognizing and reviewing security breach risks and impacts.
UPCOM communicates information security policies to employees, customers, suppliers, collaborators, and all stakeholders. The organization commits to the policy throughout its workforce, fostering collective security effort while providing necessary resources to maintain and continuously improve information confidentiality, integrity, reliability, and availability.