Quality Assurance Unit(QAU)

Hellenic Mediterranean University

Responsible and Sustainable Public Procurement Policy

Purpose

The University implements this Sustainable Procurement Policy with the objective of integrating principles of environmental protection, social responsibility, and economic efficiency into all procurement procedures for goods, services, and works. Public contracts are employed as a strategic instrument for promoting sustainable development, in accordance with applicable Greek and European legislation. Through its procurement activities, the University is committed to contributing to national and European objectives relating to environmental protection, climate action, and social cohesion.

Scope of Application

This policy applies to all organizational units, services, schools, departments, and other bodies of the University involved in the planning, conduct, and execution of public procurement procedures for goods, services, and works.

Legal Framework

This Policy is founded on national and European legislation governing public procurement, together with the regulatory acts issued pursuant thereto, as currently in force, and in particular:

  • Law 4412/2016 (Government Gazette A’ 147) “Public Works, Supplies and Services Contracts (adaptation to Directives 2014/24/EU and 2014/25/EU)”;
  • The national framework for Green Public Procurement, including the approved National Action Plan for the promotion of Green Public Procurement (Government Gazette B’ 466/08-02-2021), which sets national targets for the integration of environmental criteria into public contracts for products, services, and works, as well as related policy support from the Hellenic Single Public Procurement Authority and the National Central Procurement Authority, for the implementation of green criteria;
  • The guidelines and guidance documents of the European Commission on Green and Socially Responsible Public Procurement, which, within the framework of EU legislation, provide interpretative directions and best practices for the lawful integration of environmental and social criteria into public contracts;
  • Law 4700/2020 (A’ 127) “Unified Code of Procedure for the Court of Audit, comprehensive legislative framework for ex‑ante audit, amendments to the Code of Laws on the Court of Audit, provisions for the effective administration of justice and other provisions”, and in particular Articles 324–337;
  • Law 4622/2019 (Government Gazette A’ 133) “Executive State: organisation, operation and transparency of the Government, governmental bodies and the central public administration”, and in particular Article 37;
  • Law 4601/2019 (Government Gazette A’ 44) “Corporate transformations and alignment of the legislative framework with Directive 2014/55/EU of the European Parliament and of the Council of 16 April 2014 on electronic invoicing in public procurement, and other provisions”, as amended and in force;
  • Article 11 of Law 4013/2011 (Government Gazette A’ 204) “Establishment of the Single Public Procurement Authority and the Central Electronic Public Procurement Registry…”, as amended and in force;
  • Law 3548/2007 (Government Gazette A’ 68) “Publication of notices of public sector entities in the prefectural and local press and other provisions”, as amended by Law 5005/2022 and in force;
  • Presidential Decree 39/2017 (Government Gazette A’ 64) “Regulation on the examination of pre‑contractual appeals before the Hellenic Authority for the Examination of Pre‑contractual Appeals (A.E.P.P.)”;
  • Joint Ministerial Decision No. 52445 ΕΞ2023/4‑4‑2023 of the Ministers of Finance, Development and Investments, Infrastructure and Transport, and State, entitled “Obligation for the submission of electronic invoices by economic operators” (Government Gazette B’ 2385, as corrected in Government Gazette B’ 3061);
  • Ministerial Decision No. 102080/24‑10‑2022 (Government Gazette B’ 5623/02.11.2022) of the Minister of Development and Investments, “Regulation of matters concerning the examination of remedial measures by the Committee of paragraph 9 of Article 73 of Law 4412/2016”;
  • Law 4914/2022 (Government Gazette A’ 61) “Management, control and implementation of development interventions for the Programming Period 2021–2027, establishment of the Société Anonyme ‘National Registry of Start‑Up Companies S.A.’ and other provisions”, as amended and in force;
  • Law 4727/2020 (Government Gazette A’ 184) “Digital Governance (Transposition into Greek Law of Directive (EU) 2016/2102 and Directive (EU) 2019/1024) – Electronic Communications (Transposition into Greek Law of Directive (EU) 2018/1972) and other provisions”, as amended and in force;
  • Law 4624/2019 (Government Gazette A’ 137) “Hellenic Data Protection Authority, measures for the implementation of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, and transposition into national law of Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016, and other provisions”, as amended and in force;
  • Law 4270/2014 (Government Gazette A’ 143) “Principles of fiscal management and supervision (transposition of Directive 2011/85/EU) – public accounting and other provisions”;
  • Section Z of Law 4152/2013 (Government Gazette A’ 107) “Adaptation of Greek legislation to Directive 2011/7/EU of 16 February 2011 on combating late payment in commercial transactions”, as amended and in force;
  • Law 5144/2024 “Value Added Tax Code”;
  • Law 2690/1999 (Government Gazette A’ 45) “Ratification of the Code of Administrative Procedure and other provisions”, and in particular Articles 1, 2, 7, 11 and 13 to 15, as amended and in force;
  • Law 2121/1993 (Government Gazette A’ 25) “Copyright, Related Rights and Cultural Matters”, as amended and in force;
  • Presidential Decree 80/2016 (Government Gazette A’ 145) “Assumption of obligations by Authorising Officers”, as amended and in force;
  • Presidential Decree 28/2015 (Government Gazette A’ 34) “Codification of provisions on access to public documents and information”, as amended and in force;
  • the provisions of Law 5218/2025 (Government Gazette A’ 125) “Reform of the framework for the professional training of officials handling public contracts, the framework for the preparation and award of public contracts and legal protection in the field of public procurement, the framework of national quality infrastructures, and the framework for the establishment, expansion and modernisation of manufacturing activities in the Region of Attica, and other provisions”;
  • Council Regulation (EU) 2022/576 of 8 April 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine;
  • Commission Implementing Regulation (EU) 2019/1780 of 23 September 2019 establishing standard forms for the publication of notices in the field of public procurement and repealing Implementing Regulation (EU) 2015/1986 (electronic forms) (Text with EEA relevance), OJ L 272 (the use of the standard forms under this Regulation is mandatory as of 25 October 2023);
  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance), OJ L 119;
  • Commission Implementing Regulation (EU) 2016/7 of 5 January 2016 establishing the standard form for the European Single Procurement Document (Text with EEA relevance), OJ L 3/16;
  • the provisions of Law 4957/2022 (Government Gazette A’ 141/21.07.2022) “New Horizons in Higher Education Institutions: Enhancing quality, functionality and the connection of HEIs with society, and other provisions”, as in force;
  • the provisions of Law 5094/2024 (Government Gazette A’ 39/13.03.2024) “Strengthening Public Universities – Framework for the operation of non‑profit branches of foreign universities and other provisions”;
  • the provisions of Articles 75 to 83 of Law 4727/2020 (Government Gazette A’ 184/23.09.2020) “Digital Governance (Transposition into Greek Law of Directive (EU) 2016/2102 and Directive (EU) 2019/1024) – Electronic Communications (Transposition into Greek Law of Directive (EU) 2018/1972) and other provisions”, as amended and in force;
  • Law 3310/2005 (Government Gazette A’ 30) “Measures to ensure transparency and prevent circumvention in the procedure for awarding public contracts”, Presidential Decree 82/1996 (Government Gazette A’ 66) “Nominalisation of shares of Greek sociétés anonymes participating in procedures for the award of public works or supplies of the State or legal entities of the wider public sector”, Joint Ministerial Decision No. 20977/2007 (Government Gazette B’ 1673) of the Ministers of Development and State regarding the “Supporting documents for maintaining the registers under Law 3310/2005, as amended by Law 3414/2005”, as well as the ministerial decisions issued pursuant to Article 65 of Law 4172/2013 (Government Gazette A’ 167) determining: (a) non‑cooperative tax jurisdictions, and (b) jurisdictions with preferential tax regimes. [to be included where applicable, if the contract to be awarded falls, based on its estimated value, within the scope of Law 3310/2005];
  • the provisions of Law 3863/2010 (Government Gazette A’ 115/15.07.2010) “New Social Security System and related provisions, regulations on labour relations”, as in force;
  • the entirety of the provisions of social security, labour, social, environmental and tax legislation.

Key Principles of Sustainable Procurement

Environmental Protection

The University seeks to:

  • Procure goods and services with a reduced environmental footprint.
  • Promote energy efficiency, the use of recyclable materials, and the reduction of waste.
  • Take environmental parameters into account throughout the entire life cycle of products.

Social Responsibility

Procurement procedures:

  • Respect and promote fundamental labor rights.
  • Ensure accessibility and uphold the principles of equal treatment and non‑discrimination.
  • Encourage the participation of small and medium-sized enterprises.

Economic Efficiency

The University:

  • Ensures the optimal and efficient use of public resources.

Transparency and Legality

All procedures are conducted:

  • In full compliance with the applicable legal and regulatory framework.
  • On the basis of objective, transparent, and duly substantiated criteria.
  • With strict adherence to the principles of equal treatment and non‑discrimination among economic operators.

Implementation of the Policy

  • The University’s services integrate, where appropriate and in accordance with the applicable legal framework, environmental and social criteria into technical specifications, award criteria, and contract performance conditions, and shall provide the necessary guidance for their application.
  • Academic and Administrative Units take sustainability considerations into account when planning and defining their needs.
  • The competent University services ensure the training of procurement personnel and their continuous updating on best practices and developments at national and European level.
  • The University’s Governing Bodies monitor the implementation of this Policy and adopt the necessary directions for its effective application.