Code of Business Conduct

The business conduct principles and rules set out in this policy are provided as the governing standards to ensure that we promote Aegean’s mission and meet our targets in an ethical, honest and legal manner.


Business Behaviour

The Company conducts its business with honesty and integrity. The Company competes fairly and ethically within the framework of applicable competition laws.


Laws and Regulations

The Company complies with the applicable laws and regulations of the countries in which the Company operates or under which the Company has any contractual association. We are responsible for understanding these laws and regulations as they apply to our jobs and for preventing, detecting and reporting instances of non-compliance to Aegean’s Quality & Safety Department.


There are no circumstances at Aegean that would allow us to disregard any law or regulatory requirement in the conduct of our business and no such activity will be tolerated.


Confidentiality of Company Information

All Personnel must not, directly or indirectly, use, disclose, reproduce or make available in any form any confidential Company information. This applies to internal Company matters, as well as industry information other than that which is generally available to the public and extends beyond the termination of employment / contractual relationship.


Conflict of Interest

All Personnel must pay particular attention to conflict of interest issues. If an employee is faced with a situation in which his or her personal financial, or other interests, or those of the individuals or entities close to them, may conflict with that of the Company, the employee must report it immediately to his or her Management.


The following activities are prohibited:


  • Owning, operating, or being employed by any business that competes, directly or indirectly, with Aegean.
  • Engaging in a business transaction with Aegean except in connection with our regular employee programs.
  • Having a direct or indirect personal financial relationship with a competitor , customer , or supplier (this does not include the purchase of publicly traded shares unless a controlling or significantly influential interest is acquired.
  • On Aegean’s behalf, awarding a contract or entering into any other financial transaction with a former employee or family member.
  • Engaging in any other employment or extensive personal projects during work hours, or using Aegean property in other employment.
  • Soliciting or entering into any business or financial transaction with an employee you supervise, either directly or indirectly.
  • Solicitation and distribution of materials by a third party to Aegean employees on company property, without previous authorization from a senior manager of the department / division.
  • In this respect, no Personnel should acquire an interest or accept a position as consultant or part-time employee with a competitor, a supplier or a customer without prior written agreement of his or her Management.


Proper Accounting and Record Keeping

All transactions on behalf of the Company's entities must be appropriately described in the records of the Company and accounted for in accordance with the Management System and may be subject to audit. No secret or unrecorded fund of money or other assets is to be established or maintained.


Code of Ethics for Financial Officers

The Company promotes honest and ethical conduct throughout the Finance function and adopts relevant policies that mandate full, fair, accurate, timely, and understandable disclosure in the periodic reports as well as strict compliance with applicable governmental rules and regulations. This policy constitutes the "Code of Ethics For Financial Officers."


Internal Control System

Management is committed to establish, maintain, and regularly evaluate the effectiveness of a business-wide internal control system including, but not limited to, detailed procedures for purchasing and sales functions, inventory control, accounting, financial reporting and disclosure. Appropriate guidelines for the internal control structure and the disclosure controls and procedures are defined within the relevant policies and work instructions.


Relationships with Government Officials, Customers, Suppliers and Partners

These relationships should be conducted ethically and in compliance with local and international statutory requirements and standards applicable to local subsidiaries as well as to the Company's parent company. Gifts within the context of business relationships or activities should not be given, directly or indirectly, or accepted, directly or indirectly, if they could be considered extravagant. Similarly, entertainment should not be extended or received if it could be seen as extravagant or unduly frequent.


Communities and Political Activity

The Company respects and promotes a harmonious working relationship with the local communities in which it operates. The Company acts in accordance with appropriate national laws in a socially responsible manner and refrains from participation in party politics.


Commissions, Fees & Similar Payments

All Commissions, consultants' fees, retainers or similar payments should be clearly related to, and commensurate with, the services being performed.


Joint Ventures

When participating in joint ventures, the Company promotes the application of the above principles and rules in the management of the joint venture operation.


Applicability & Enforcement

The Company's policy on business conduct is applicable to all permanent and temporary members of staff, contractors and consultants (hereinafter the "Personnel") and should be complied with at all times. In line with the principles of this policy, all Personnel are expected to carry out their duties and maintain their internal and external relationships in a professional manner with utmost integrity while avoiding any conflict of interest. The Company will not tolerate any breach of this policy. Individuals found to be in breach of the rules of conduct will be subject to disciplinary action up to and including termination of service.


All incidents involving a breach of this policy must be reported immediately to the head of Quality & Safety department. In the event that reporting a specific breach of this policy to Quality & Safety department is deemed inappropriate, the incident must be reported directly to the CEO. For the purpose of this policy, any incident of fraud is considered a major incident and reported as such.


No employee may be discharged, demoted, suspended, threatened, harassed, or in any other manner discriminated against as a result of reporting a breach of this, or any other Company's policies or procedures.