1. The purpose for recording the IP address and for processing the data from the File Records and the Obligatory Cookie is the function of our Website as well as dealing with possible technical problems and protecting our Website from potential malicious or illegal use (e.g. via the record of IP addresses). The legal basis for the above processing is our legitimate interest to protect the security and integrity of our Website.

1. The processing of the data from the Voluntary Cookies aims at handling, analyzing and updating the Website through the extraction and analysis of statistical data which refer to the number of our visitors, the number of times each visitor visits us, their geographical origin, the language they prefer seeing on our Website, which pages they visit more often with a view to assess the user’s behavior (e.g. for the purpose of behavioral advertisement). The processing in question is based on your consent i.e. the activation of each cookie when you enter our Website, which you can withdraw at any time in the same manner, by deactivating the cookies you wish.

The Website refers to third parties’ websites which may perform further processing of the data of their visitors/users, use different cookies etc.  Vidavo bears no responsibility regarding those websites and for any relevant matter you will have to contact the relevant owners.

Prior to any potential change of processing of personal data via the Website, we will amend the present Policy accordingly and will display it in order for you to receive the relevant information and be able to exercise your rights effectively.

Policy Summary: VIDAVO S.A. is committed to conducting its business in accordance with the highest ethical standards and prohibits all forms of bribery and corruption. This Anti-Bribery Policy prohibits the bribery of government officials as well as private sector bribery, including the offer, promise, authorization or provision of anything of value to any customer, business partner, vendor or other third party in order to induce or reward improper performance of an activity related to our business. Violation of this Policy could result in disciplinary action, including, but not limited to, termination of employment. It is crucial that you not only understand and appreciate the importance of this Policy, but that you comply with it in your daily work. If you have any questions about this Policy or applicable anti-bribery laws in general, please contact the Anti-Bribery System Manager at compliance@vidavo.eu.

In conjunction with this Policy, please refer to the Anti-Bribery Procedure Documents for additional information and details.

1. Purpose and objectives of the policy: This Policy is intended to describe the Company's risks related to bribery and corruption, to highlight your responsibilities under relevant anti-corruption laws and Company policies, and to provide you with the tools and support necessary to identify and combat these anti-corruption risks.
   
   
2. Risks and/or consequences of non-compliance: Violation of relevant anti-corruption laws may result in severe civil and criminal penalties and damage to our Company's reputation. Company employees who violate these laws may also face severe civil and criminal penalties, including jail time. A violation of this Policy could result in disciplinary action, including, but not limited to, termination of employment.
   
   
3. Scope and range of application: The Company expects all employees, officers, directors and third parties working on its behalf to refrain from any form of bribery or corruption, regardless of nationality, residence or location. In addition to this general prohibition against bribery and corruption, this Policy and Procedure Documents set out several policy and procedural requirements that apply to all its employees.
   
   
4. Policy details:

4.1 Applicable laws: Company employees must comply with all applicable anti-bribery laws. Such laws generally prohibit both bribery of government officials and private sector bribery.

4.2 Prohibition of bribery:

4.2.1 Government bribery: The Company and its employees are prohibited from giving, promising, offering or authorizing payment of anything of value to any government official to obtain or retain business, secure any other improper advantage, or improperly influence the actions of a government official. In addition, Company associates should also avoid inappropriate interactions with government officials.

4.2.2 Commercial Bribery: In addition to the prohibitions on bribery of government officials discussed above, the Company prohibits employees from offering or providing payments and other benefits to or accepting the same from private persons and entities. Such payments constitute commercial bribery and are often referred to as "kickbacks."

4.2.3. Facilitation payments: The Company's prohibition on bribery applies to all improper payments regardless of size or purpose, including "facilitating" (or expediting) payments. Facilitation payments refer to small payments to government officials to expedite or facilitate actions or services, such as obtaining a license, processing government documents such as visas, clearing customs, providing telephone, electricity or water service, or loading or unloading cargo. Generally, facilitation payments are prohibited by this Policy.

4.3 Provision of items of value to government officials

4.3.1 Government transaction approval tool: Before providing an item of value to any government official or entity, employees must first obtain written approval from the Company's legal counsel.

4.3.2 Gifts, Meals, Travel and Entertainment: No gifts, meals, travel or entertainment may be given to anyone (government officials or business partners) in exchange for any improper favor or benefit. In addition, gifts of cash or cash equivalents, such as gift cards, are not permitted.

4.3.3 Gifts: No gift may be given to improperly influence a government official or in exchange for any improper favor or benefit. It may, however, be permissible to make donations directly to a government agency (rather than to an individual government official) as part of a charitable effort.

4.3.4 Promotion, demonstration or explanation of products: No advertising expenses or activities may be directed to a government official to improperly influence him or her or in return for any improper favor or benefit. In certain circumstances, however, it may be appropriate to direct such expenditures to a government official or entity in order to promote, demonstrate or explain the Company's products and services.

4.3.5 Hiring or Employment of Government Officials: no government official or members of his/her immediate family may be hired or employed to improperly influence the employee or in return for any improper favor or benefit. Please note that before hiring a government official (or his/her relative), the Company's associates must first obtain legal approval.

4.3.6 Political Contributions: No political contributions may be made to improperly influence a government official or in exchange for any improper favor or benefit.

4.4 Third Party Management:

4.4.1 Applicability to third parties: Third party agents, consultants, distributors or any other third party representatives acting for or on behalf of the Company (collectively, "Third Parties") are prohibited from making Corruption Payments on behalf of the Company. This prohibition also applies to subcontractors hired by third parties to perform work on behalf of the Company.

Any and all payments made to third parties, including commissions, reimbursements, refunds, must be customary and reasonable in relation to the services provided and must be accurately documented in the books and records of the Company. No such payment shall be made in cash or to bank accounts that are not in the name of the third party.

4.4.2 Due Diligence: Any and all third parties who will interact with government officials or entities on behalf of the Company must complete the Company's due diligence process before they begin working on behalf of the Company. The Procedure Documents provide a detailed overview of the third-party due diligence process.

Any red flags raised during a vendor due diligence audit should be addressed to the satisfaction of the Company's Legal Counsel prior to entering into a relationship with the third party and any remedial action implemented should be documented in the due diligence tool. The Procedural Documents contain additional information regarding common third party red flags. Importantly, due diligence should be renewed to active suppliers every three years.

All agreements with third parties interacting with government agencies or officials must be in writing and include appropriate anti-bribery language. The company's legal counsel will determine the appropriate contractual language.

Once a third party agent or consultant is acquired by the Company, the activities and expenses of the third party must be monitored by the relevant Company official to ensure continued compliance with applicable anti-corruption laws and Company policies.

4.5. Education: The Company requires all directors and all employees to complete anti-bribery training every two years. 

Required anti-bribery training may include in-person or online training, a web-based anti-bribery training course, or instructor-led training programs. If a Company associate is assigned a web-based training course, he or she must complete that web-based course regardless of whether he or she has also received in-person training.

4.7 Audit: Company employees will conduct periodic internal audits of the Company's relevant operations to ensure the Company's continued compliance with applicable anti-bribery laws and this Policy. It is the duty of all employees to cooperate with - and never interfere with or obstruct - such audit activities or investigations of the Company. The Company's auditors are expected to act independently and to contact the Company's Legal Counsel for clarification of any questions regarding the application of this Policy.

VIDAVO S.A., responding to the requirements of modern business reality and aiming at the protection of the information it manages, always aiming at the uninterrupted and exemplary service to its Clients through the maintenance of confidentiality, availability and integrity of information, decided to design and install an Information Security Management System in accordance with the requirements of the International Standard ISO 27001:2022.

The Company's Information Security Management System covers:

• Design, development and production of software for receiving, processing and transmitting medical signals and information
• Training in the use of software for receiving, processing and transmitting medical signals and information.
• Technical support of software for receiving, processing and transmitting medical signals and information.
• Distribution of medical devices for monitoring and measuring physiological parameters, and their consumables.              

The main objectives, as expressed within the procedures of the company's Information Security Management System, are:

• To ensure the confidentiality, integrity and availability of the information managed, including personal data.
• Ensuring the proper functioning of the information systems.
• The timely response to incidents that may jeopardize its business operations.
• Meeting legislative and regulatory requirements.
• The continuous improvement of the level of Information Security.

The company's system is regularly reviewed by the Μanagement in order to adapt it to new needs and developments in the market, to legislative requirements, and to achieve the company's information security objective.

The Management is committed to providing the infrastructure and equipment deemed necessary for the implementation of its work. Each employee is responsible for meeting, assimilating and implementing the procedures required by the Information Security Management System through their daily activities. For this reason, all employees, depending on their responsibilities, are informed about the System and operate demonstrably in accordance with the established rules.

The Information Security Policy is communicated, understood and applied by all human resources, with the ultimate goal of continuous, stable development of its business activity, with unwavering commitment to its principles and the constant offer to its customers of products and services of excellent quality. It is reviewed at regular intervals in order to ensure that it is constantly in line with market conditions, technological developments and legislation in force.

Operations, processes, flows and activities that do not guarantee the fulfilment of the objectives set are immediately interrupted by the responsible persons, root cause analyses are carried out and the required improvement measures are defined.