We, in ARTHROSIS SA, having a high sense of responsibility towards those who use our products and services, have recognized that bribery, not only in the health sector in which we operate, but in all aspects of our business life, is a significant risk, both for society as a whole but also for ourselves, its partners, employees and collaborators.

Therefore, we considers we have an obligation towards society, our employees and partners (suppliers and customers, partners, public organizations and hospitals and the public sector in general) to operate with integrity throughout the range of our activities and to communicate our expectations for reducing the risk of bribery, with the aim of eliminating it.

For this reason, we have implemented an Anti-Bribery Management System, according to the ISO 37001 standard, with the Head of Management Systems & Compliance in charge of implementation, and have raised awareness and activated our people, who daily take care of company’s proper operation, through educational trainings and notifications.

The Anti-Bribery Policy applied by ARTHROSIS focuses on: Ø  The adoption of ZERO TOLERANCE in matters of bribery and the commitment to operate in accordance with the requirements of the applicable legislation and the requirements of the Anti-Bribery Management System according to the ELOT EN ISO 37001 standard.

For this reason, we, in ARTHROSIS SA:

• Select our staff, associates, suppliers and other business partners not only based on the quality of the items/goods and services they provide or the product prices, but also based on their ethics and the integrity of their corporate and personal character.
• Condemn the acceptance of favorable terms on services, partnerships and products in exchange for business decisions.
• Do not engage in monopolistic or price-manipulating practices (agreements of any kind with competitors or suppliers to fix or control prices in violation of antitrust laws, agreements with competitors, to exclude customers or suppliers with the aim of fixing purchase prices).
• Consider bribes and gifts by the staff and by anyone working on behalf of ARTHROSIS SA during cooperation or negotiation with interested parties (partners, suppliers, customers, banks, government representatives, public authorities), illegal and we exclude them from our operational activities.
• Keep accurate financial records, available for any inspection, including in details all cases in which an item of value has been given to employees of public organizations and/or hospitals or someone in the public sector in general.
• Do not allow “facilitation payments” – small payments, in cash or in kind – to expedite an action that is part of the normal business of a public official, customer or supplier
• Monitor and adhere to applicable relevant National and European legislation, jurisprudence and regulations,  international standards and good practices
• Inform all interested parties about this Anti-Bribery Policy, partners and their representatives, employees (regardless of position, employment duration and employment relationship, partners/suppliers and any other person (legal or natural) related to the company, who are committed to following it.

We, in ARTHROSIS SA, are committed to providing all the required resources for the development, maintenance and improvement of the Anti-Bribery System, by:

• Selecting competent and qualified personnel, specialized to perform their activities transparently and ensuring that the personnel is fully aware of the importance of their activities and the way they contribute to the achievement of Anti-Bribery objectives.
• Providing repetitive Anti-Bribery training so as to achieve and maintain personnel’s competence for performing daily work activities transparently.
• Evaluating the effectiveness of ARTHROSIS operational procedures and the implemented Anti-bribery Compliance System
• Complying with the applicable National and European Laws and Regulations on Anti-Bribery matters.
• Providing the necessary infrastructure and communication channels for reporting suspicions and Combating Bribery (e.g. hardware and software), as well as ensuring confidentiality, without the fear of retaliation.