Anti-Bribery & Anti-Corruption Policy

Introductory Statement

This Anti-Bribery & Anti-Corruption Policy applies to Zepos & Yannopoulos (“ZEYA”), an incorporated partnership of Lawyers regulated by Greek Presidential Decree 81/2005 and Law 4194/2013 as currently in force and to our affiliate company, “ZEYA ACCOUNTING Société Anonyme accounting and tax services”, (“ZEYA Accounting”). Any reference to “Our organisation”, “we” and/or “us” in the present Policy applies jointly to ZEYA and ZEYA Accounting. Our organisation is committed to achieving the highest standards of ethical conduct and professional integrity and to ensuring that it, its lawyers, economists, employees and third parties who may provide professional services on its behalf, act in compliance with all applicable laws of Greece and the laws of the various jurisdictions where our organisation’s services are rendered, that apply in Greece to the extent that such laws do not conflict with Greek Anti-Bribery & Anti-Corruption laws. In addition, we take pride in being the corresponding firm in Greece for TRACE (Transparent Agents and Contracting Agencies), a non-profit association providing anti-bribery support and certifications.

To ensure compliance with these laws, we have adopted the following rules which, subject to and in accordance with any applicable local law and regulatory requirements, apply to all fee earners (i.e., our partners and associates), as well as to the other employees of ZEYA and to each agent, representative, consultant, and independent contractor acting on behalf of ZEYA or retained by ZEYA in order to provide services to a client.

Bribery & Corruption

a. We do not tolerate any form of bribery or corruption and it is a requirement of this Policy that we all comply with all relevant Greek anti-

a. We do not tolerate any form of bribery or corruption and it is a requirement of this Policy that we all comply with all relevant Greek anti-bribery and anti-corruption laws.

b. We do not give bribes: We will never provide, offer or promise to provide or authorise or solicit anyone to provide, directly or indirectly, benefits of any nature to any individual (who works either in the public or the private sector) in order for such individual to proceed, in violation of his or her duties, to an act or omission (with the purpose to obtain or retain business or a business advantage).

We are also required not to confer any benefits on a third person, if we know or reasonably suspect that such person will offer such benefits as bribes. In any event, we do not consent to the commission of any of the above and we shall not provide assistance or counsel or mediation thereto.

In particular, we are extremely careful in our dealings with the public sector and the justice system. We believe in achieving goals and winning cases for our clients through cooperation with the relevant public authorities and the justice enforcement system; to this effect, we never offer gifts or benefits to public officials or judges.

c. We do not accept bribes: We will never demand or accept, directly or indirectly, for ourselves or for a third party, benefits of any nature or the promise thereof, in order to induce or reward improper performance in the form of an act or omission which arises from or conflicts with a person’s duties.

Furthermore, we assume an active role in supporting and promoting initiatives which enhance transparency and integrity in the public sector; we also oppose all forms of corruption of persons involved in the administration of public affairs and justice, particularly of judges and other adjudicators, members of the parliament, local representatives and politicians in general, and other relevant domestic or foreign officials.

d. In addition to the above, we are familiar with the provisions of the core anti-bribery and anti-corruption legislation of the jurisdictions in which our clients are based, such as the UK Bribery Act and the Foreign Corrupt Practices Act and use our best efforts in complying with such Acts, if and to the extent that this is so required.

Anti-Money Laundering

We actively comply with anti-money laundering and anti-terrorism laws and regulations and we acknowledge that, as providers of legal services, we have a duty to report to the competent Greek authorities any behaviour that may be deemed “suspect”.

We will not assist our clients to conclude transactions which could be considered contrary to the provisions of the law. We will refuse to provide legal advice when we know or reasonably suspect that we are asked to provide such advice in order to enable or facilitate the commission of any act which is illegal, related to money-laundering, terrorism, corruption, fraud or other financial crimes.

To ensure compliance with our above duties, we have adopted and apply an internal procedure (“Know Your Client”) which enables us to perform the requisite due diligence on prospective clients and to ensure smooth cooperation from the beginning of our relationship with a client.


We acknowledge that in many jurisdictions gift giving is a customary way of building a more personal relationship or showing gratitude for a service rendered. However, in accordance with our Anti-Bribery and Anti-Corruption policy, we are extremely careful with regards to giving and receiving gifts.

Whereas customary gifts (e.g., bottles of wine, business meals and invitations to events) are usually acceptable, we avoid giving or receiving gifts that could be perceived to be extravagant, lavish or otherwise inappropriate. Cash or other equivalent instruments are never acceptable as gifts.


• We do not give or accept bribes.
• We will report suspect incidents or behaviour.
• We are extremely careful when giving or receiving gifts.
• We always comply with national and, to the extent applicable, foreign legislation.
• We are continuously conscious about maintaining our integrity; we act with responsibility, integrity and in accordance with our internal procedures.
• We are committed to this policy and expect our partners and other business associates to do the same.

For more information about our Anti-Bribery and Anti-Corruption Policy, you may contact;
Dimitris Zepos,
Stefanos Charaktiniotis,