HELLENIC PETROLEUM Group

p. 96 and front  over

“Contact” p. 86

Α) “Group Activities” p. 15-17, “Product Accessibility” p. 51-53

     p. 156-161

     p. 30-45

B) No such cases. 

8A Chimarras str., 151 25 Maroussi, Greece 

p. 96 and front  over

“Contact” p. 86

“Report’s Boundaries” p. 4, “Product Accessibility” p. 51-53

p. 36-37

The Group’s companies included in this Report and countries with significant operations are as follows:

1. HELLENIC PETROLEUM S.A.
   ΕΚΟ ΑΒΕΕ
   ASPROFOS S.A.
   DIAXON ΑΒΕΕ
2. ΟΚΤΑ AD SKOPJE
3. JUGOPETROL AD
4. HELLENIC PETROLEUM CYPRUS LTD
5. EKO BULGARIA EAD
6. EKO SERBIA A.D.

HELLENIC PETROLEUM S.A.

HELLENIC PETROLEUM Group

p. 47-49

p.189

p. 36-37

“Report’s Boundaries” p.  4, “Product Accessibility” p. 51-53

The following Table, indicatively for 3 companies, presents the sales breakdown per type of customer:

p. 10-11

«Financial Review 2017» p. 10-11, 26-27

“The Group at a Glance” p. 12-13

“Employment”- Tables depicting Employee Breakdowns, p. 34-35

Normally there are no seasonal workers, with the exception of EKO, as there are staff seasonal changes (fixed term contracts) at the airports. Usually however, there are no seasonal employees. There are no self-employed employees at the Group. 

GROUP

BREAKDOWN BY GENDER AND EMPLOYMENT PER COMPANY

In order to meet the specific needs of the Group's companies, specific administrative, financial or technical support is provided through third-party companies.
Indicative activities - such as the following - are assigned to contract/self-employed workers:

• Ancillary and support work related to packaging
• Industrial facilities cleaning
• Utility maintenance
• Secretarial support
• Office cleaning
• Security services
• Gardening
• IT support, electrical issues etc.

p. 33

“Responsible Procurement” p. 53-54

As an Energy Group, our supply chain consists of thousands of suppliers. These suppliers provide the products and services required for running our industrial facilities and serve our customers in a variety of operational environments. We maintain a complex influx of materials, equipment, services, transport, communications & IT and other technology support systems, and are furthermore trying to expand our interaction with local suppliers (see CSR Report:  "Local Communities", p. 62). Typical partners in our supply chain include suppliers of raw materials (crude oil, chemicals), industrial equipment & materials, IT equipment & services, local media, industrial services, general goods and services, land/sea transportation services.

“Methodology” p. 4-5

With decision no. 51 reached on March 1, 2017 by the Governmental Council for Economic Policy (KYSOIP), the Hellenic State decided to (a) terminate the procedure for the sale of 66% of the shares of DESFA S.A. (DESFA), launched under the 29 February 2012 Submission for Expressions of Interest, (b) launch a new tender procedure for the same percentage (66%) of DESFA shares, i.e. 31% of the 65% of the shares owned by HRADF S.A. (HRADF), in combination with 35% of the shares held by HELPE S.A. (c) return the remaining 34% of DESFA shares to the Greek State, (d) authorize the Minister of Finance to sign a Memorandum of Understanding between the Greek State, HELPE S.A. and the HRADF, and (e) for the Board of Directors of the HRADF to draft, decide upon and implement the tender procedure for the sale of DESFA’s shares.

In accordance with the aforementioned KYSOIP decision, the HRADF addressed Hellenic Petroleum, via correspondence ref. no. 30187 dated 29.3.2017, which called on our company to begin "negotiations regarding the conclusion of a Memorandum of Understanding (MoU) for the joint disposal of 66% of the shares of DESFA” with HRADF’S proposing that the MoU not differ from the memorandum signed between the two companies on 16.02.2012.

Article 103 of Law 4472/2017 "Government Pension Provisions and Amendment to the provisions of Law 4387/2016, Measures for the Implementation of Budgetary Targets and Reforms, Social Support Measures and Employment Reforms, Medium-term Financial Strategy Framework 2018-2021 and other provisions" foresees that by December 31, 2017, 66% of the shares owned by DEPA S.A. under the share capital of DESFA S.A. will be sold and transferred through an international tender procedure to be carried out by the HRADF with the balance transferred to the Greek State.

The sold 66% will comprise - after the transfer of the shares owned by DEPA S.A. in the share capital of DESFA S.A. to its shareholders, 35% of the shares corresponding to the participation of HELPE S.A. in the share capital of DESFA S.A. and 31% of the shares that will correspond to the participation of HRADF S.A. in the share capital of DESFA S.A.

In particular, it was provisioned that at the end of the tender, DESFA should be a Separate Natural Gas Transmission System Operator in accordance with the provisions of articles 62 and 63 of Law 4001/2011 as in force, and be certified as such in accordance with the provisions of Articles 9 and 10 of European Directive 2009/73/EC (Full Ownership Unbundled System Operator (FOU).

The Memorandum of Understanding between Hellenic Petroleum and the HRADF was signed on 26.6.2017, and approved by decision no. 1295 dated 12.6.2017 approved by the decision of the Extraordinary General Meeting of the Shareholders dated 06.7.2017.

On 26/6/2017, the HRADF announced a call for non-binding expressions of interest. Four potential investors expressed interest, of which, on 22/9/2017, two were preselected by the Sellers (HRADF & HELPE) to participate in the next phases of the tender, namely the consortium between SNAM S.p.A., FLUXYS S.A., Enagas Internacional SLU, N.V. Nederlandse GASUNIES and the Spanish company Regasificadora del Noroeste S.A., which subsequently cooperated with the Romanian company TRANSGAS, and the European Bank for Regional Development (EBRD). These two pre-selected bidders, in response to the 10/10/18 Invitation to Bid, submitted their bids on 16/02/2018, which are under evaluation.

OKTA
The refining operation stopped in January 2013. The company now operates as an importer and trader of fuels and is listed on the Macedonian Stock Exchange (MSE). Pucko Petrol v. Plasnica acquired 10.84% of OKTA's shares in January 2013, previously held by PIOM, plus an additional 0.03% of OKTA's shares in December 2013.

EKO Bulgaria
There are no significant changes, apart from working with a new local supplier in December 2013.

EKO Serbia
No major change, apart from the opening of 3 new COMO petrol stations.

Certification of Group industrial facilities, storage facilities and service stations, in accordance with internationally recognized standards (first year of certification).

Also see the indicator 102-15

EKO Bulgaria
In-progress approaches (such as training, competitive pricing and promotion initiatives) which ensure that our partners comply with our corporate policy and regulations confirm customer loyalty and improve sales methods. Regular fuels testing performed by independent laboratories, confirms the quality of the products. Regular weekly employee training for dealing with emergencies.

HP Cyprus
With the adoption of international standards/management systems (CYS EN ISO 9001: 2008, CYS EN ISO 14001: 2004 & OSHAS 18001: 2007, on 8/4/2005) HPC ensured for safe and professional behaviour in all its operations. Risk assessments were carried out for all major operations, facilities and petrol stations.

OKTA
The harmonization of HSE with mandatory statutory requirements established by government authorities and voluntary requirements by standardization bodies and corporate requirements have obliged OKTA to provide a number of activities related to environmental protection as well as safety and health at work.

• Waste Management Programme 2016-2018 submitted to relevant Authorities
• Continuous monitoring of air emissions 
• Monitoring the quality of underground waters and water management plan (in progress) 
• Management of PCB from transformer oils
• Revision of risk assessment re. job positions
• Health preventive medical check-ups (periodical and systematic) according to job positions’ risk assessment
• Steady organization adaptation and education of personnel in order to attain maximum effect in HSE through monthly drills in accordance with different fire scenarios in cooperation with the Directorate for protection and rescue
• Risk assessment for natural disasters and other accidents
• Qualitative and quantitative analysis of data and possible risks of natural disasters and other accidents, prediction of further development of events and consequences
• Plan for safety and rescue based on the risk assessment for natural disasters, current, operational and technological risks, safety risks including Incident management team and respond forces
• Rulebook for safety in regards to fire and explosions
• Seveso Study 
• Cleaning of sludge pools

Furthermore, HR applies the “precautionary principle” in all its areas of operation (HR planning, selection and recruitment, training & development, succession planning, evaluation, reward) to prevent any risks in its areas of operation.

As a precautionary measure, all employees performing any kind of work (including inspection) in explosive atmospheres were trained according to EN 60079 – 17 “Explosive atmospheres, Equipment repair, overhaul and reclamation”. 

In the area of procurement, “the precautionary principle” is one of the basic principles of operations and has been included in the formulation of the specific procurement strategy, which pays particular attention to ensuring for smooth and uninterrupted supply under the best economic conditions and always in accordance with the approved procurement manual.

p. 64-65

“A few words about the Report” p. 4-5, “Corporate Governance and Regulatory Compliance” p. 24-31

See also indicator 102-11

The adoption and implementation of international standards, codes and best practices is a dynamic approach to studying potential risks. These standards, codes and practices, which are fully in line with the Group's strategic goals, are committed to implementing, diffusing and integrating them into all of our operations and policies. Indicatively, these standards and codes include:

Mandatory commitments:

• ETS (EU ETS) (Protocol of Kyoto, 1997 - in force since 2005), only to the Group’s refineries in Greece

Voluntary initiatives:

• "SustainableGreece2020’’ Initiative - Charter for Sustainable Greece Signed on 29.04.2014 (www.sustainablegreece2020. com). The initiative (which is under the auspices of the Greek Ministry of Development & Competitiveness as well as the Greek Ministry of Environment, Energy and Climate Change) was developed with the cooperation of 33 Business Associations, 120 Companies, 17 Local Authorities and 43 Organizations. It is furthermore endorsed by International Organizations such as the European Commission, the German Sustainability Council, the World Business Council for Sustainable Development and the EIRIS. The Group participates in the Initiative as a SUSTAINABILITY AMBASSADOR, http://www.sustainablegreece2020.com/gr/ ambassador/ellhnika-petrelaia.152.html The participation in the initiative includes the adoption of the Greek Sustainability Code, http://greekcode.sustainablegreece2020.com/ as well as the promotion of good sustainable development practices in observing Sustainability: http://observatory.sustainablegreece2020.com/
• Global Reporting Initiative (GRI Standards) as well as the specific Oil & Gas Sector Supplement. Adopted by the Group in 2008.
• United Nations’ Global Compact (UNGC) principles & criteria. Adopted by the Group in 2007.

In the context of its operation and the implementation of its CSR strategy, the Group   cooperates with its stakeholders through participating in organizations, associations, institutions, etc. The Group also funds and/or participates in the administrative bodies of these associations and organisations. See: http://sustainabilityreport2016.helpe.gr/userfiles/6ffd2fe2-e2bc-4741-906d-a48900e96f28/symmetoxes%20gr.pdf

HELPE considers its active participation in the following organizations as part of its strategy for sustainable development:

Environmental and Sustainability Organizations:

• CONCAWE (scientific section of the European Refineries Organization FuelsEurope)
• the HFE’s Council for Sustainable Development
• the HFE’s Committees on HSE

Industry Organizations:

• FuelsEurope
• Hellenic Association of Chemical Industries (participates in the BoD)
• EPSC (European Process Safety Center)

The Group has no additional financial participation in these organizations, apart from annual membership dues.

p. 7-9, 15-18

“Message from the Chairman of the BoD and Chief Executive Officer”, p. 8-11

p. 179

The Group’s long-term opportunities and risks are as follows:

p. 44-47, 160-164, 164-165, 171-173, 179

p. 15-18, 78-81

“Internal Audit and Risk Management”, p. 28

For main impacts, risks and opportunities (due to climate change): see indicator 201-2.

The Group’s companies (locally) evaluate opportunities and risks as follows: 

ΕΚΟ
Short-term risks:

• Instability of the economic environment
• Market risk (foreign exchange risk, product price fluctuation risk, cash flow risk and fair value risk due to changes in interest rates, credit risk, liquidity risk)

Long-term risks:

• Differentiation in the energy mix
• Technological developments and consumer behaviour

Short-term opportunities:

• Opportunities created by smaller Marketing Companies being forced to exit the market, due to particular market conditions in recent years having either interrupted or significantly reduced their activity. This will result in the growth of the larger Groups.

HP Cyprus
The new VTTV terminal at Vasiliko (on the south coast between Larnaca and Limassol) with a capacity of 550,000m3 of white products is operational. The new Petrolina terminal (local oil company – 80,000m3) is also operational for storage. Works in progress for building of new small storage tanks and truck loading facilities. These are expected to be finished before end of 2019 120,000m3 of Cyprus strategic reserves have been relocated from Larnaca to VTTV.

In addition  the government is stepping up the pressure for the relocation of the LPG terminals from Larnaca. The four LPG companies with terminals at Larnaca have conducted and submitted to the government a feasibility study regarding the construction and operation of a new LPG terminal facility at Vasiliko. Furthermore,  the four LPG  companies have proceeded to the formation of a JV company and are waiting the approval from  the Competition  Committee.

HPC has taken the strategic decision to move away from the LPG JV and proceed to construct its own terminal. The same stands for the construction of a new storage facility for the other fuels.

Opportunities:

• Further development of COMO Network.
• Introduction of Loyalty programs.
• Strengthening the brand awareness through marketing activities and enhancement of EKO  premium products portfolio (EKO Racing 98, EKO Racing 100 & Diesel Avio Double Filtered).
• Optimization of petrol stations network.
• Expansion in case of lifting of trade boundaries  as  a result of the  Cyprus political problem resolution

Risks:

• The White Flag Petrol Stations in the market and the expansion of competition in building new Petrol Stations is a threat in  diluting margins and ATPs.
• In case where trade barriers are lifted as a result of resolution of the political problem,  there might be  threats   to competitiveness.
• The new VTTV  terminal at Vassiliko might be one more option for product supply to the local market
• The introductions of Autogas might have  unforeseeable effects on the automotive fuels margin

ΟΚΤΑ
OKTA supplies approximately 78% of the fuel needs of the domestic market. In addition, its significant storage capacity serves as a safety mechanism for the uninterrupted supply of fuel in the markets where it operates. At the same time, it is a major exporter and a significant employer of transportation, logistics and engineering services.

OKTA’s sustainable profitability depends on its ability to remain competitive in a market where barriers to entry are low, while at the same time it manages its facilities and installations as efficiently as possible, in order to safeguard its role as a secure supplier. OKTA has the opportunity to maintain its market share by exploiting its logistics infrastructure and the competitive terms it has with its supplier. Additionally, OKTA seeks to strengthen its profitability by completing a number of transformation projects already launched, affecting its operations and its organizational structure.

OKTA’s transformation to a trading company has emphasized the importance of the commercial targets in its strategy. In that context the objectives set for 2017 were further increase of market share and secureness of the 1st position in the domestic market, coupled with preservation of margins, enhancement of competitiveness, training and development of the personnel, as well as recapturing share of independent PS networks. In addition to this profitability augmentation from the retail network and exploration of possible synergies with other EKO networks were the goals for OKTA’s retail activities.

The short term opportunities for OKTA are:

• Pipeline utilization launch and optimization of the Supply Chain
• Further rationalization of the company’s organization
• Management of Legal cases
• Strategic reserves supply and storage fee introduction
• Leverage OKTA’s Storage and Loading installations
• Creating access to retail market through organic growth (DODO->COMO, retail know how and EKO offerings)
• Focus on efficiency
• Searching for alternative sources of energy

The short term challenges for OKTA are:

• Full or partial loss of the biggest customer
• Waking up of strong competition in the wholesale market
• Re-emergence of cheap product from competitive refinery
• Oversupplied region
• Limited growth of the economy
• Long lasting political crisis

EKO Bulgaria
There have been no significant changes in the legal and economic environment that could affect the viability of the company and its stakeholders. The political environment is stable while macroeconomic indicators were correctly forecasted.

There have been no significant changes to local legislation, international standards or business rules.

Risks (short and long-term):

• Remain at existing market position due to heavy competition and RomPetrol’s takeover appetite.
• Profitability loss due to increased regional price competition.
• Profitability loss due to increased product competition (LPG).
• Operational complications that may arise with legislation H-18.

Opportunities (short and long-term):

• Expansion of PS network based on favorable outlook on consumer spending.
• Invest in quality Brand name and new loyalty scheme.
• Capitalizing on AVIO Diesel, EKO Racing and EKO Guarantee.
• Opportunities for collaborations (e.g. supermarkets) related with distribution.
• Contribution of NFR to total gross margin.
• EKO intragroup loyalty card.
• H-18 may reduce WF competition.

EKO Serbia
Short term opportunities:

• Further exploit of lubricant business
• Expand penetration of high margin products (fuel and NFR)
• Reduction of OPEX (via procurement)
• Increase of other income (services, rent, cross business)

Long term opportunities:

• New RVI implementation
• Network expansion
• Increase brand value through dynamic marketing activities
• Exploit opportunities related to new supply routes, depots for w/s business
• further development of loyalty program

Short term risks:

• %  of  Supply dependence on NIS
• Ability to remain competitive in w/s business
• Strong competition actions (discount)
• Increase of Capex due to network aging

Long term risks:

• Macroeconomic deterioration
• Implementing aggressive network expansion plan

EKO Serbia still has the potential to grow, increase its market share, increase profit margins in fuel sales, and become no. 3 through the expansion of the distribution network.

JUGOPETROL
Short-term risks:

• The retail market is largely regulated; almost all petrol stations offer the same prices. A number of independent petrol stations have tried to offer lower prices but the main competitors do not follow their example.

Short-term opportunities:

• Our active participation in actions, an area in which our competition is lagging behind.

Long-term risks: 

• Strong competition (INA, Petrol, Lukoil)

Long-term opportunities:

• Easy to strengthen our position in the northern and southern regions where we are by far the strongest competitor
• Expansion of our network in Podgorica, where we have a strong influence
• Promotion of our brand name as the high-end quality brand in the market where the price is unanimous and regulated.

p. 11-12

(in its entirety)

“Vision-Strategy-Principles” p. 14, “Internal Regulatory Framework of the Group” p. 28-29

See also the indicator 102-11

The Code of Conduct was approved and notified in 2011 (in Greek and English) and was fully implemented throughout the Group as well as extended to its external partners.

The Competition Policy - as to the competition legislation -  was approved by decision of the Board of Directors 1316/6 / 22.3.2018.

A list of procedures for Health, Safety, Quality and the Environment - according to international standards - and corresponding policies are available on the corporate network, intranet and internet. They are applied throughout the Group while continuous training ensures awareness and thorough application.

The Group’s values – which have been adhered to - are applied across the Group, and address all employees at all Group’s subsidiaries in Greece and abroad.

The statements, codes or policies concerning procurement activities fall under the existing Purchasing Regulations, paying special attention to cooperation with suppliers.

Α) We are committed to being a responsible Group. This means that we conduct our activities in accordance with relevant ethical, professional and legal standards. We consider corruption, bribery and unfair competition to be unacceptable.

Sustainability related risks, such as employees, safety, the environment, ethics and supply chain management, are an integral part of Group Risk Management. For each of the risk categories, related to the Group and each company, a risk assessment takes place together with the determining potential for improvement.

Therefore the Hellenic Petroleum Group’s Code of Ethics explicitly provides that each employee must comply with the law and behave honestly, transparently and responsibly towards clients, associates, shareholders, and social partners in general. It provides the possibility for counselling on ethical and legal behaviour issues as well as providing the opportunity for employees to submit anonymous related reports to the Regulatory Compliance Office.

Since June 2017, Hellenic Petroleum has been a member of the Business Integrity Forum of the Hellenic Office of the INTERNATIONAL TRANSPARENCY organization, where, in cooperation with other major companies operating in Greece, exchanges knowledge and best practices for dealing with corruption.

B) In order to further ensure that our business integrity policy is properly designed and implemented, the Regulatory Compliance Office operates under the Code of Conduct. Employees may submit any questions about the integrity or references to suspected violations to the Regulatory Compliance Office in full confidentiality.

The Code of Conduct has been translated into all the languages of the countries where the Group operates and is also applied there.

ΟΚΤΑ
We have implemented a mechanism for the protection of workers' rights, in accordance with the Law.
We have developed measures and procedures to protect against harassment in the workplace. An independent internal audit service is also operational.

HPC
The Group's Code of Conduct was implemented in 2012. The Code manages all of these aspects and has been communicated to all employees, suppliers and customers, and also constitutes part of all of our contracts.

EKO Bulgaria
The reporting mechanisms and associated procedures are described in the Code of Conduct. The obligation to comply with the Code of Conduct is included in the agreement with each partner. Concerns are treated confidentially. The Company does not follow a retaliation policy. No concerns have been raised.

EKO Serbia
The Group’s Code of Conduct is in place and has been outsourced to an external partner (email, free 24/7 helpline). Depending on the type of complaint (concern), appropriate staff investigate the matter at hand and prepares the final response. According to the law all complaints that are recorded are to be resolved within 15 days.

In 2017, the internal evaluation of the first four years of the Code of Conduct and the functioning of the Regulatory Compliance Service (2013-2016) was completed, while the external evaluation of the Code is expected to be completed in 2018. Any amendments to the Code will be submitted to Management and subsequently to the Board, which will use the above-mentioned four-year experience as well as legislative changes that have taken place in the meantime.

At the meeting on 22/3/2018, the Company’s BoD approved the Group’s Competition Policy and Compliance Program.

At the initiative of the Directorate-General for Legal Services, the process of adapting to the European General Personal Data Protection Regulation (GDPR - Regulation (EU) 679/2016), was implemented on 25/5/2018. A detailed Gap Analysis was also conducted which was completed on 16/11/2017, while a Civil Data Protection Policy project was presented at the Executive Committee meeting on 13/3/2018. It is expected that this Policy draft will be submitted for approval to the Board of Directors by April 2018.

According to Chapter 6 of the Code of Conduct, a conflict of interest arises when personal relationships, external activities or interests in other businesses affect or could affect any employee's decisions in the performance of his/her duties. When these situations occur they are a matter of fact and must be treated on a case-by-case basis.

This type of conflict of interests that arises between a person or member of an employee’s family and the interests of the Group is often not easily understood, as there are cases that create confusion and doubt. During 2018, a draft concerning the Group’s Policy concerning the Avoidance of Conflicts of Interests will be prepared in compliance with the above section of the Code.

p. 64-77

p. 168-171, 174-179

https://www.helpe.gr/the-group/group-management/management-structure/

NOTE: For the BoD and the Committees, appropriate reporting is that contained in Section D.7 "Composition and Operation of the Board of Directors, Supervisory Bodies and Company Committees" in the Annual Report.

In addition to the BoD committees, the following have also been established and are operational:

• The Group Executive Committee which is advisory and executive insofar as it is given specific executive powers by the Board of Directors.
• Advisory and coordinating committees comprised of high-level executives from the company and the Group that are created with the purpose of assisting executive functions, the main ones being the following:

            I.    Committee for Electricity, Natural Gas and RES Activities
            ΙΙ.   Industrial Activities Committee
            III.  Retail Committee
            ΙV.  Group Credit Committee
            V.   Investment Evaluation Committee

The Company proceeded with allocating administrative responsibilities between the Executive Chairman, the CEO and Deputy CEO as follows:

The Chairman, in addition to responsibilities regarding convening, chairing, conducting meetings, observing meetings’ minutes and signing the relevant decisions, and the general functioning of the BoD provided for by the Company's Articles of Association and the law, is also responsible for:

• The Group’s Legal Services Division
• The Group's Corporate Relations General Directorate

The Group's Internal Audit Directorate reports to the Chairman.

The CEO is the legal representative of the Company and is responsible for:

• The Group's Oil Supply, Refining and Sales General Directorate
• The Group’s Human Resources & Administrative Services General Division
• The Department for Hygiene, Safety, Environment and Sustainable Development
• International Retail Division

The Chairman of the Board of Directors and the Chief Executive Officer of ASPROFOS S.A. report to the CEO.

The Deputy CEO replaces the CEO in cases of absence or impediment and is responsible for:

• The Group's Financial Services General Directorate which includes the Financial Directorates of the Group's companies
• The Group’s Strategic Planning and Joint Ventures General Directorate
• The Group’s Procurement Directorate

The Group Executive Committee is advisory, recommendatory and executive, to the extent that it is given specific executive powers by the Board of Directors. It processes and defines strategic issues in all of the Group's business areas and the Group’s subsidiaries domestically and abroad.

Senior executive meetings define sustainable development issues and agree on the hierarchy of objectives, subsequent activities and reporting of results. Sustainability represents a percentage of executives and employees’ daily activities; for example, it is used as a parameter in regular working discussions and performance assessments, thereby making its implementation a shared responsibility across all levels of the Group's hierarchy.

The submission of sustainable development issues to the Board of Directors takes place when the relevant memorandum drafted by the relevant General Division Manager is submitted to the Chairman of the Board, the CEO or Deputy CEO, as is deemed appropriate, so that such issues can be proposed accordingly to the Board of Directors. If the matter falls within the competence of one of the Committees, it is examined by the Committees, which make the relevant suggestion to the Board of Directors.

The Group CSR Director and Corporate HSEQ Director have responsibilities and responsibilities in regards to planning, recommendations and implementation.

The CFO Director is also Deputy Executive Officer (Executive Board Member).

The Corporate HSEQ Director reports to the Group’s CEO.

The Group's Corporate Relations Division reports to the Chairman of BoD.

HELPE annually compiles and publishes - in print and electronic formats - reports and presentations covering all of the company's activities and performance in these areas. This information and all company editions are posted on the corporate website www.helpe.gr/ Corporate Publications.

There are many mechanisms that facilitate two-way communication between management and shareholders – employees, and include the General Assembly, employee representatives and representatives of minority shareholders on the Board, the investors & shareholders information office and employee unions.

The Committees who deal with Personnel Issues (Hiring Committee, Health & Safety and Industrial Affairs Committee) are defined in chapter 1 of the Internal Labour Code. Occupational Health and Safety (E.Y.A.E.) is also established at each facility.

All these committees contribute to the exchange of views between employees and management.

“Stakeholders” και “Employee Suggestion Box” p. 19

Other Actions:

• Quarterly group executive meetings (from department head level and above) for the presentation, analysis and discussion of the Group’s financial and operating results.
• Roadshows/participation in conferences, quarterly meetings with analysts, meetings with institutional investors, refinery field trips - financial analysts & institutional investors, ensuring for 2-way communication with the investment community.
• Information meetings - discussions with engineers from the industrial plants.
• Regular meetings with elected union representatives.

p. 64-77

p. 174-179

Based on Hellenic Petroleum’s shareholder composition, specific rules concerning the appointment and replacement of members of the Board of Directors have been developed, which are explicitly mentioned in the Company's Articles of Association. The Greek State appoints seven (7) members out of a total of thirteen (13) BoD members if it holds, directly or indirectly, at least 35% of the shares through the HRADF. Paneuropean Oil and Industrial Holdings S.A. and its affiliated companies appoint two (2) members of the BoD provided that they hold at least 16.654% of the total of the Company's voting shares. Two (2) members of the Board of Directors are comprised of employee representatives elected by employees of the Company and two (2) members represent the minority shareholders, elected by the Extraordinary General Meeting of the remaining minority shareholders (asides from the Greek State and Paneuropean Oil and Industrial Holdings S.A. or its affiliates).

The following table shows the allocations pertaining to the 67 members of the BoDs spread across the Group’s companies included in this Report:

% of women holding senior management positions: about 10%.

The Chairman of the BoD is also an executive member.

p. 66

In addition, the Chairman’s role, functions and related responsibilities are outlined in the Bylaws of the Company, which are approved by the Board, and are in full coherency with the applicable provisions of company law 2190/1920, as amended, and applicable.

p. 157, 163-164

There is currently no institutionalized nomination procedure for the members of the Board of Directors elected by the Special Shareholders' Meeting of minority shareholders.

The composition of the BoD committees is based on the competencies, qualifications and experience of the BoD members involved in each committee.

The members of the Audit Committee are elected by the Ordinary General Meeting of Shareholders further to the proposal made by the Remuneration and Succession Planning Committee to the Chairman of the BoD, they are all non-executive members and the majority of them are independent members. Members of the Audit Committee should have administrative experience and sufficient knowledge in the field of energy and at least one member of the Commission should have sufficient accounting and/or audit experience. The Chairman of the Committee is appointed by its members or elected by the General Meeting of Shareholders, and if he or she is a member of the Board of Directors, he or she should be an independent non-executive member and should have the necessary knowledge and experience to supervise audit procedures and issues of concern to the Committee.

p. 11

“Corporate Governance and Regulatory Compliance” p. 24-31

p. 64-65

p. 170-171

The current ratio between executive and non-executive members of the Board of Directors, which is 4:9, ensures that any situations involving "conflicting interests" are avoided.

The Board of Directors has endorsed the principles and best practice provisions of the “HGC’s Code of Corporate Governance”, (http://www.sev.org.gr/Uploads/pdf/kodikas_etairikis_diakivernisis_GR_OCT2013.pdf).

The Code of Conduct also includes a specific provision preventing conflicts of interest, with an indicative list of cases constituting such a conflict while there is also a reporting obligation to the Compliance Office for financial transactions conducted by members’ spouses or second degree relatives.

Additional indicative "tools" used to avoid/manage a potential conflict of interest include the list of approved suppliers and their relationship with executives, as well as the corporate governance statement.

The Group aspires to be open and transparent as to how it operates in order to win and maintain the trust of its customers, employees, shareholders and other important social partners. Reporting and the governance structure are an integral part of this commitment.

HELPE’s corporate responsibility performance is dependent on all employees—from Chairman and CEO to the staff in each business unit, subsidiary, industrial facility and research laboratory. All of us at HELPE are aware of our corporate responsibilities through the Group’s Code of Conduct, but we also recognize that a central coordinating function is necessary in order to ensure that we have a comprehensive approach to corporate responsibility. The GCAD coordinates the development, implementation and communication of our global corporate responsibility approach and, with the strategic guidance of the Executive Committee, is responsible for reporting on the Group’s corporate responsibility performance. To support the Group’s strategy, Key Performance Indicators (KPIs) for sustainable development have been developed and implemented.

The Executive Committee defines the Group’s Sustainability Policy. The GCAD & GHSESD recommend the approval of sustainable development issues and are responsible for their implementation. The definition of sustainability issues, prioritisation of objectives, monitoring of activities and reporting results are discussed in senior management meetings. 

In addition to the Executive Committee, other Board Committees oversee issues related to corporate responsibility, such as audit and compliance, fees, remuneration etc. (http://www.helpe.gr/the-group/group-management/).

p. 72-77

p. 194-197

The risk management system (see indicator 102-15) provides a platform for sharing knowledge and expertise in a structured manner, making risk management a key enabler in achieving the strategic objectives.

The Group's Steering Committee formulates the Group's Sustainable Development Policy. The CSR & HSEQ Directorates recommend sustainable development issues for endorsement and are furthermore responsible for their implementation. Senior management meetings define sustainability issues and prioritize objectives, while making sure that control and reporting activities are complied with.

p. 169

“Corporate Governance Performance” p. 29

See Indicators 102-24, 102-35

In addition to the Board's assessment, through the Annual General Shareholders Meeting, the Board of Directors regularly monitors and evaluates its effectiveness in the performance of its duties as well as that of the committees that it has established.

To date, this assessment is collective of the Board of Directors as a Company body and the committees that the Board has set up in the previous period. The Chairman presides over this evaluation, and the results are discussed at a Board meeting; the Chairman is responsible for taking measures to address the weaknesses resulting from the evaluation. In addition to the above, the introduction of a system whereby the BoD and each member thereof are separately evaluated by an external expert-consultant is being considered.

The Board’s Audit Committee possesses the following responsibilities:

• It monitors the process and the implementation of the statutory audit of the Company's individual and consolidated financial statements.
• It monitors, reviews and evaluates the process of preparing financial information, i.e. the mechanisms and systems, flow and dissemination of financial information produced by the Company's organizational units involved in the preparation of financial information.
• It monitors, examines and evaluates the adequacy and effectiveness of the Company's overall policies, procedures and safeguards regarding both the internal audit system and risk assessment and management in relation to financial reporting.
• With regards to the internal audit function, the Audit Committee monitors and insures the proper functioning of the Group Internal Audit Directorate and evaluates its work, adequacy and effectiveness, without, however, affecting its independence. It also reviews internal audit disclosures and the Company's main risks and uncertainties with respect to financial reporting.
• It reviews and monitors the independence of statutory auditors or audit firms and is responsible for the selection process of statutory auditors or audit firms and proposes statutory auditors or audit firms to be appointed by resolution of the General Meeting.

The Financial and Financial Planning Committee examines, in cooperation with the Group Financial Directorate General, issues that mainly concern:

•  the individual and consolidated financial statements and related appendices, as well as the quarterly and half-yearly statements, when deemed necessary, before their submission to the Board
•  insurance coverage
•  the Company’s financial planning
•  any other matter considered as important to the Company and which affect its financial performance and growth

The Corporate Crisis Management Plan has been completed, is now in place and is being enforced.

The Board of Directors approves the 3-month, 6-month, 9-month and annual financial statements for Hellenic Petroleum and the Group as well as Group announcements and other publications. The Group's Executive Committee monitors, inter alia, the financial results of the Group on a monthly and quarterly basis, budget execution and financial management.

p. 67

p. 156-190

The Board of Directors approves the 3-month, 6-month, 9-month and annual financial statements for Hellenic Petroleum and the Group as well as Group announcements and other publications. The Group's Executive Committee monitors, inter alia, the financial results of the Group on a monthly and quarterly basis, budget execution and financial management.

The GHSED submits a report on the environment, health and safety issues to the BoD at least twice a year.

The Chairman of the BoD and the CEO approve and sign this Sustainable Development and CSR Report.

The Group CSR Director is authorized to ensure that all material aspects are presented with clarity and objectivity.

The Executive Committee defines the Group’s Sustainability Policy. The GCAD & GHSED recommend the approval of sustainable development issues and are responsible for their implementation.

The GCAD works with business units and functional areas to integrate HELPE’s corporate responsibility principles into business policies, strategies and practices, and brings the voice of external stakeholders into decision-making processes.

The GCAD is accountable for producing an annual corporate responsibility report. To contact members of the Division, please see p. 86.

The Corporate Responsibility Report Working Group
Representatives from business units and functional areas make up the members of the Corporate Responsibility Report Working Group, whose function is to promote the further integration of corporate responsibility into the business. Individual members have been chosen to be active advocates for corporate responsibility within their respective areas. In addition, the members of the working group, who are a diverse selection of employees from all divisions of the company, serve as content experts in their respective areas and work with the GCAD to help set goals and develop metrics that support and measure the Group’s overall corporate responsibility strategy and objectives.

Meetings with senior management are used to define sustainability issues and reach agreement on prioritising objectives, monitoring activities and reporting results. 

The Divisions, as appropriate, inform the CEO or Chairman of the Board on critical issues, on a case by case basis, as soon as they are identified. The CEO then makes recommendations to the BoD. Moreover, critical issues are communicated through the Board's deliberations with social partners.

Also see Indicator 102-21.

The critical issues presented to the Board refer to the material aspects that were recorded and evaluated through the “Materiality Assessment 2017” (see p. 20-23).

p. 170

The Board of Directors’ Remuneration and Succession Planning Committee makes recommendations - to the Board of Directors – regarding the remuneration, benefits and financial incentive policy for the executive members of the Board of Directors (HELPE and Group level), in line with market conditions and with the aim of attracting and keeping appropriate executives.

The Annual Ordinary General Meeting approves the total remuneration for members of the Board of Directors (executive and non-executive) for their participation on the Board as well as to the Board’s Committees after being proposed to the Board of Directors with the agreement of the Board’s Remuneration and Planning Committee.

For senior level executives, the assessment is conducted annually based on KPIs which links the company’s goals and performance to the executives’ goals on issues such as sustainable development (safety, environment, etc) with a 20% weighting factor.

A percentage of executives’ remuneration also concerns health, safety and environmental issues (depending on the area of employment).

Regarding the members of Diaxon's Board of Directors (including the CEO), seven of the 5 members are HELPE executives, and are remunerated based on HELPE Group’s relevant policy.

The Chairman of the BoD is not a senior executive of HELPE and is remunerated on the basis of the relative contract between the company and the Chairman. One BoD member does not work at HELPE and is remunerated in the same way as the members of the Board working at HELPE.

With regard to Diaxon’s executives: 
HELPE BoD members (CEO included) are senior management staff of HELPE and their remuneration is in accordance with the relevant policy of the Group.

ASPROFOS
The remuneration of the members of the Board of Directors is determined by the General Meeting of Shareholders.
Senior executives are paid a fixed monthly salary and their performance is rated based on KPIs.

HP Cyprus
A policy is in place covering the remuneration of the senior executives concerning both fixed and variable pay. Variable pay is based on yearly objectives. Τhe executives’ individual goals include financial and operational objectives as well as goals regarding health, safety and improvement/training of personnel.

EKO Bulgaria
The remuneration policy includes both fixed and variable remuneration which is performance-based, and termination payments.

EKO Serbia
BoD members receive the compensation prescribed by the General Assembly. Senior Executives are evaluated through the Performance Management System. In the Performance Contracts and Performance Appraisals of the Company Directors, the company’s performance comprises 100% of the total result of their performance contract.

Jugopetrol
Performance-based pay. BoD members are entitled to a predefined yearly remuneration if the Company has reported a profit in the previous year.

p. 170

The remuneration policy is based on the best practices in the domestic labour market and the most important factors that affect executives’ competitiveness and motivation. The remuneration policy is continuously being updated so as to take into account new trends and conditions prevailing in the economy and society.

HP Cyprus

• Personnel are covered by a collective agreement – salary scales (collective agreement ) as per position
• Executives are remunerated according to market salary surveys

EKO Serbia
Salaries are determined via MERCER, and are compared to industry averages. Furthermore, when determining remuneration, several additional factors are taken into account such as: the position of the employee, their previous performance, experience, skills, exceptional merits (successful projects, etc.)

ASPROFOS
No consultants are involved in the remuneration process of Asprofos’ employees. Salaries are determined on the basis of a collective bargaining agreement.

EKO Bulgaria
The company strictly adheres to  the Bulgarian law, follows the Group policies and does not use external consultants.

Jugopetrol
General Assembly determines the amount of remuneration only for BoD members. Consultants are not involved in determining remuneration.

The remuneration of senior management staff does not take stakeholders’ views into account.  For other employees, the terms of remuneration and employment are defined through Business Collective Labour Agreements, signed jointly by the Company and the Employees' Association through collective bargaining.

Countries where there is significant activity are presented: p. 4 (“Report’s Boundaries”).

Countries where there is significant activity are presented: p. 4 (“Report’s Boundaries”).

“Stakeholders” p. 19

Presents the social partners participating in the 2017 Materiality Assessment Analysis, and interfacing approaches with stakeholder groups.

“Human Rights-Equal Opportunities Policy” p. 34

Percentage of employees covered by collective bargaining agreements: 

“Stakeholders” p. 19

Α) “Stakeholders” p. 19

These approaches are consistently integrated into the Group’s strategy for sustainable development.

Moreover indicative approaches initiated by the Group’s companies include:

ΟΚΤΑ
With suppliers: Regular communication through personal contacts and discussions are part of the Procurement Division’s duties aimed at enhancing cooperation through constructive dialogue and exchanging information and experience.

With customers/petrol stations owners: Scheduled communication conducted by  sales consultants at least once a month, which enable identifying and resolving possible issues, thereby maintaining good cooperation. On an annual basis, station owners are rewarded especially in areas concerning image, safety, products promotion etc.

With employees: Employees are updated on a daily basis with business news related to the activities of both the company and Group via ΟΚΤΑ’s web page (employees are mainly communicated with via electronic communication). Also, the most important news & announcements are posted on bulletin boards in all company buildings

Moreover:

• There are periodic meetings with employees’ representatives
• Periodic meetings with relevant authorities (stock exchange etc.)
• Open and transparent communication with media, publishing regular press releases, interviews and PR articles on internet portals, business magazines, daily newspapers, etc.
• Online surveys are conducted in order to understand the public’s opinion about OKTA

HP CYPRUS

• Written communication to all employees takes place through emails along with posting on notice boards
• As per purchasing procedures, every year all suppliers/vendors are re-evaluated

EKO BULGARIA
Customers’ communication takes place through qualitative and quantitative surveys (such as Brand Vitality Tracking, loyalty driving assessment).

JUGOPETROL

• Quarterly reporting to the Montenegrin Stock exchange
• Engagement with customers through Loyalty Program

Market surveys (conducted by RASS Consultancy in 2016), which generally focus on drivers and more specifically on EKO station visitors
For internal stakeholders, meetings of the Board and meetings of trade unions

EKO SERBIA

• Press conferences
• Direct contact with media answering questions about fuels, products and services
• Organization of discussions with various focus groups
• Events organization
• Online, on site and 24/7 customer service helpline
• ATL, BTL and other promotion activities
• Direct communication with loyalty club members through newsletters, e-mails and SMS

Β) “Round-the-clock 24-hour service” p. 54-55

HP Cyprus

• Mystery Shopper Survey (all HPC and 30% of the competition’s petrol stations were tested 12 times a year): The total score was 77.3% for HPC and 62.8% for the competition (courtesy, service and appearance).
• The main results from the Brand Vitality Tracking survey (an annual survey, 800 interviews, percentages on age, gender, area, representative driver populations in Cyprus, regarding opinions, information and use, purchasing criteria and brand, and habits in terms of car use & fuel purchase) were:
          - The indicator “Top Of Mind” increased score from 42% for 2016 to 45%.
          - HPC has gained in main choice rate (37% vs 34%), that drives the increase of Loyalty (23% vs 20%).

EKO Bulgaria
Mystery Motorist Research: Customer satisfaction 95.5% (courtesy, service and appearance). The main results of the 5th Brand Vitality Tracking survey conducted in 2017 were:

• Indicator "Top of mind": 2 points increase
• Indicator "Main choice": 3 points increase

JUGOPETROL
From 2016 to 2017, there was an improvement in both surveys: Mystery Motorist Research and Tracking Vitality Brand. Total Brand Awareness stands at 99%.

OKTA
Nielsen annual survey organized by IMA that identifies the “Views & Attitudes”, “Awareness & Usage”, “Purchase Criteria & Brand Evaluation” and “Habits on car usage & Fuel purchases”. In 2017 OKTA has gained ground in terms of total awareness by 3%. Among consumers the brand is mainly identified and selected because of the following aspects: high fuel quality, reliable company and value for money offerings.  OKTA users evaluate the brand for its trustworthiness and CSR activities.

EKO Serbia
Customer satisfaction is key to improving brand awareness. With the aim of continuously improving it, EKO organizes monthly Mystery Motorist inspections with very strict for customer service, politeness and appearance.
RASS opinion survey results (sample from over 1,000 people irrespective of age, gender and occupation):

• EKO Serbia was recognized as one of the best brands in the market with the second lowest rejection rate.
• Taking all the criteria into account, EKO is the most recommended network in Serbia ("Main choice": 24%).
• The main products, which are mostly recognized, are our diversified fuels, such as Diesel Avio.
• The main services identified: SMILE card and service at the petrol stations. The Smile club has 450,000 registered members.
• A number of customers believe that we have chosen good locations, especially in Belgrade and the central area. The southern and northern parts of the country are recognized as areas where more petrol stations are needed.

The key topics that stakeholders raised are reflected in the material issues we have chosen to report this year, (see also indicator 102-47).

“Stakeholders & Material Topics” p. 18-23

p. 191-193

“Report’s Boundaries” p. 4

“Materiality Assessment” p. 20-23

See indicator 103-1  “Boundaries and Management approaches for Material Topics”, and  see also: http://sustainabilityreport2017.helpe.gr/en/sustainability-standards-and-verification/GRI-Standards/

“Materiality Assessment” p. 20-23

See indicator 103-1  “Boundaries and Management approaches for Material Topics”, and  see also: http://sustainabilityreport2017.helpe.gr/en/sustainability-standards-and-verification/GRI-Standards/

“Methodology” p. 4-5

• Merger of marketing companies ( “Group Activities” p.  15)
• Operations in Egypt on hold
• New procurement regulation (See also indicator 412-3)

“Methodology” p. 4-5

• Revision of Competition Policy (see also indicators 102-16, 102-17)

January – December 2017

“A few words about the Report” p. 4-5

Posted on Group’s web site in Sept. 2017, concerning the period Jan-Dec 2016). 

“A few words about the Report” p. 4-5

Annual (01.01-31.12)

“A few words about the Report” p. 4-5

“Contact” p. 86

Ms. Rania Soulaki, Group CSR Director

E-mail: rsoulaki@helpe.gr

Tel: +30 210 6302894

Fax: +30 210 6302573

In accordance with the GRI Standards Comprehensive option.

http://sustainabilityreport2017.helpe.gr/en/sustainability-standards-and-verification/GRI-Standards/

Α) «Appendix IV» p. 92-93

Β) This Report was checked and certified - as a whole and per each indicator – by an independent external certification body, prior to its publication.

The certification process involved all Divisions that provided information as well as senior Group executives, and has been signed by the Group’s Chairman of the BoD and CEO.

“Regulatory Compliance” see “Why is it material?” p. 25

“Regulatory Compliance” see “Our approach” p. 25

“Regulatory Compliance” see “Our approach (evaluating mechanisms, results)” and “Our ambition” p. 25-29

Α) No irrevocable fines in 2017.

Β) No complaints.
Personal customer data records fully comply with the relevant legislation and are fully harmonized with EU law.

“Leaks & Oil Spills” see “Why is it material?” p. 65

“Leaks & Oil Spills” see “Our approach” p. 65

“Leaks & Oil Spills” see “Our approach (evaluating mechanisms, results)” and “Our ambition” p. 65-68

“Health and Safety Indicators - Plant Performance” p. 43 and “PSER Index” p. 66

Since 2015, the Holistic Safety System has been implemented in all three refineries, which currently overseas the review of safety procedures, leadership seminars for Heads of Divisions and Departments, engineers, coordinators and foremen, and initiatives/campaigns on issues concerning good practices. In addition, all facilities are inspected by foreign experts.

Major PSE incidents during 2017 mainly concern three main categories, such as leakages due to the corrosion of equipment-pipelines, due to process violations and unit malfunctions. The corrective actions taken to deal with them and avoid their recurrence included improving personnel safety training (which is also being implemented with the appointment of engineers as focal points on safety issues), a reinforced safety inspection program for equipment, as well as a new procedure named "Reporting and Investigation of Safety and Environmental Incidents",  ΕSO Α3.0036.00, according to which the investigation of safety incidents is carried out more quickly and in depth with the "why-tree" methodology.

“Employee Health, Safety  & Welfare” see “Why is it material?” p. 39

“Employee Health, Safety  & Welfare” see “Our approach” p. 39

“Employee Health, Safety  & Welfare” see “Our approach (evaluating mechanisms, results)” and “Our ambition” p. 39-43

All staff (100%) are represented. The committees participate in regular meetings with management and make recommendations on improvements in the workplace with regards to Health and Safety.

“Health & Safety” p. 38-40

Injuries breakdown, by gender, are recorded at all facilities. The safety indicators, by gender, for the AIC, EIC & TIC complexes and the Group’s subsidiaries are presented in the two following tables. Definitions of the indicators can be found in the CSR Report’s Glossary:

Clarifications:

• The definition of the indicators is in accordance with CONCAWE’s definitions and OSHA’s “Recordkeeping guidelines”.
• The Absenteeism rate (AR) is monitored at specific facilities and only for HELPE’s personnel.
• There are no records for occupational diseases.

As far as lost work days incidents (LWI) the days of absence are calendar days. The first day of absence is deemed as the day after the accident.

In 2017, accidents were classified again according to the definitions of CONCAWE (LWI, RWI, MTC, PSE). According to CONCAWE, LWIs in 2017 were further analyzed in the following categories:

There are no workers who are involved in occupational activities who have high incidence or high risk of any disease related to their occupation.

In cases of serious disease or loss of a family member, the company provides support from a psychologist or social worker.

At the facilities’ infirmaries, the physicians and other external experts train the shift working employees on First Aid provision, handling of respirators (recovery from major accidents), means of rescue from confined workplaces, etc.

The Group’s companies inform their employees in case of any diseases or whenever a seasonal viral outbreak is observed (via emails, bulletin boards, announcements on notice boards, etc). 

See also Certification Index (indicator 102-11), OHSAS 18001/ΕΛΟΤ 1801 certification.

Health and Safety issues, agreed in collective agreements with employees’ unions, refer to the Internal Labour Regulations, which is accessible on the corporate intranet.

An agreement is signed among the Group’s companies and the relevant employee unions concerning safety personnel in the case of a strike.

• Internal Protection and Prevention Service (ESYPP) operates under PD95/1999; aiming at employees’ occupational health monitoring and taking protective measures to avoid accidents.
• Occupational Health and Safety Committee in each facility, consisting of elected employee representatives, in accordance with Law 3850/2010, representing all employees. Any employee (100%) may participate in the elections for EYAE at the facility where he/she is working. The committees participate in periodic meetings with the facility management making suggestions for Health and Safety improvements in their workplace.  Minutes of the meetings are published, including the progress of implementation of the agreed ones. The dates of the meetings are included in the annual report of the ESYPP to the Ministry of Labor, Social Security and Social Solidarity.

Relevant reports on Health and Safety at work are:

• HELPE’s Internal Regulation (Articles 8, 24, 40, 45)
• EKO’s Internal Regulation (Articles 9, 12, 23, 28) and
• Group’s Code of Conduct (chapter 7.1).

Outsourced Protection & Prevention Services (ΕXYPP): Where appropriate (e.g. during periods of general maintenance), an additional properly qualified external partner is mobilised in order to monitor occupational H & S activities. Relevant indicators are monitored and the relevant labour legislation is applied.

Health  and Safety issues are covered 100% by local agreements or regulations or official procedures, the Health and Safety employees’ commission, with the participation of a Safety Technician and Occupational Physician, at periodic H & S meetings with colleagues at other Group’s facilities, also as part of ESYPP activities.

There are also formal agreements in place covering issues such as the:

• Provision and use of personal protection equipment
• Participation of employee representatives in inspections
• Education and information on Health & Safety
• Submission of complaints
• Right to refuse performing dangerous work

There are two safety committees in HP Cyprus, their constitution and their role is governed by legislation. Every three years the members are elected by the staff. Members of the two security committees (one for Nicosia and one for Larnaca) represent workers on all health and safety issues.

In OKTA, local agreements cover issues such as: Personal protective equipment; Participation of employee representatives in health and safety inspections, audits, and accident investigations; Training and education; Right to refuse unsafe work; Periodic inspections.

“Air Quality” see “Why is it material?” p. 62

“Air Quality” see “Our approach” p. 62

“Air Quality” see “Our approach (evaluating mechanisms, results)” and “Our ambition” p. 62-64

The supply of “cleaner” fuels (zero sulfur), the addition of bio-diesel to fuels, the use of cleaner self-consumption fuels, are presented below, (actual values less < or much less << than the specifications):

Reduction of fuels sulfur content

• Gasoline & diesel <0.001% by weight
• Aviation fuel <<0.30% by weight
• Gas oil (heating) <0.1% by weight

 “Fighting Corruption & Business Ethics” see “Why is it material?” p. 30

“Fighting Corruption & Business Ethics” see “Our approach” p. 30

“Fighting Corruption & Business Ethics” see “Our approach (evaluating mechanisms, results)” and “Our ambition” p. 30-31

Business units are audited for risks associated with corruption, following standard internal auditing procedure. The procedure is consistent with the Group’s Code of Conduct.

No relevant report or complaint took place in 2017.

In 2017, the Internal Audit examined the following issues:

• Refineries’ and Marketing Companies’ supply chain Issues
• Health, Safety and Environmental issues concerning the refineries
• Issues on the proper implementation of the Procurement Manual procedures

These issues are significant according to the Materiality Assessment.

Group - Internal Auditing KPIs:

 “Code of Conduct - Ethics and Transparency” p. 30-31

100% of employees have received information on anticorruption policies and procedures through the Internal Labour Regulation and the Code of Conduct.

Moreover, all employees (100%) are aware of the Group’s commitment to UNGC principles, as well as corporate policy and values through the Group’s annual Corporate Responsibility & Sustainability Report (all reports are posted on the Group’s site and intranet).

Three senior management members have been involved in Internet Security Training (the percentage of the total corresponds to 18.8%).

In total, 136 employees from HELPE and EKO (such as Code of Conduct, Internet Security) participated in anti-corruption training (percentage of all employees: 5.56%).

Analytically by company:

In Cyprus, the Code of Conduct was communicated to contractors and customers.

Business partners’ relevant communication is ensured by integrating a clause on the compliance with the principles of the UN Global Compact in the cooperation contracts.

No actions addressing incidents of corruption took place in 2017 as no incident was reported to the relevant committee, the companies’ BoDs or the employees’ union representatives.

Corruption incidents can also be reported to the Compliance Office.

In any case, there are also administrative and legal measures (in accordance with the Internal Labour Regulation) while regular audits are performed by the relevant auditing departments.

 “Energy & Climate Change” see “Why is it material?” p. 57

“Energy & Climate Change” see “Our approach” p. 57

“Energy & Climate Change” see “Our approach (evaluating mechanisms, results)” and “Our ambition” p. 57-61

“Energy and Climate Change” p. 60

Significant and direct financial impacts concern the costs associated with the projected greenhouse gas emission allowance as the Group’s three refineries in Greece participate in the European Greenhouse Gas Emissions Trading Scheme. It is noted that the implementation of HELLENIC PETROLEUM's main strategy for increasing energy efficiency and energy saving projects has already led its refineries (2 out of 3) to EU European benchmarking and the deficit is mainly due to the cross sectorial correction CSCF Factor implemented pursuant to Article 10a (5) of Directive 2003/87/EC (EU ETS). Annual compliance costs are estimated to range from €12 to €16 million, depending on the EUAs.

The end products (fuels) of the commercial company EKO contribute significantly to lower emissions and reduced fuel consumption. EKO’s gasoline ‘95 Ekonomy’ assures fuel economy up to 2% and EKO’s diesel Ekonomy assures up to 4% less fuel consumption. Moreover, gasoline ‘EKO Racing 100’ reduces emissions, cleans and protects the engine and fuel circuit, and significantly reduces friction, achieves up to 4% higher engine performance. Also, EKO Diesel Avio assures zero engine power loss throughout the engine’s operation over the whole range of engine’s revs (according to the motor test CEC F-98-08, which is standard for the modern common rail diesel engines) as well as fuel economy, ranging from 0.17 to 3.84%, depending on the engine type and / or capacity. Additionally, the BP’s gasoline Ultimate 95 achieves an average of an additional 12 kilometers per gas fill compared to conventional fuel; while BP’s Ultimate Diesel assures up to 42 extra kilometers per gas fill compared to conventional fuel. Finally, the improved BP’s heating oil ‘BP Super Heat’ has unique characteristics that contribute to environmental protection. More information on standards, assumptions and calculation methodologies are available at the official site of the brand names EKO & BP, at http://www.eko.gr & www.bpfuels.gr.

• P/V stations’ investment amounting to € 6.2 mil. (100% capital expenditure)
• Investments in research on first generation and advanced biofuels: € 100 thousand

In 2017, electricity produced by wind farms amounted to 73 GWh and by P/V stations amounted to 11 GWh.

 “Waste & Circular Economy” see “Why is it material?” p. 69

“Waste & Circular Economy” see “Our approach” p. 69

“Waste & Circular Economy” see “Our approach (evaluating mechanisms, results)” and “Our ambition” p. 69-72

It is not applicable for refinery products. Packaging materials are not used since fuels are transported via pipelines, tank trucks and ships.

There are no affected habitats (See also 304-1, 304-3).

 “Employment” see “Why is it material?” p. 33

“Employment” see “Our approach” p. 33

“Employment” see “Our approach (evaluating mechanisms, results)” and “Our ambition” p. 33-37

“Employment” p. 32-37

Percentage of employees in the Group that does not include volunteers::

HELPE 94,91%

EKO 92,91%

DIAXON 98,97%

ΑSPROFOS 98,73%

HP Cyprus 96,43%

ΕΚΟ Bulgaria 89,29%

ΕΚΟ Serbia 100%

JUGOPETROL 94,44%

ΟΚΤΑ 98,14%

HELPE - ΕΚΟ
The benefits provided in Collective Agreements and Internal Labour Regulations concern employees with an indefinite time contract and not employees under fixed-term contract - full or part-time regardless of where they work.

Furthermore:

ASPROFOS
Company benefits are provided to all employees 

DIAXON
Benefits to indefinite contract employees (discount vouchers are also provided to temporary employees and partially to students trainees) include: summer camps, childcare allowance, loans, school allowance, students’ allowance, award to employees’ children for excelling at school or university, financial support for foreign languages learning, wedding/birth/death allowance, financial support for employees with a large number of children/children with special needs, rent subsidies, mortgage loan subsidies, Christmas and Easter allowances.

JUGOPETROL
Full-time and part-time workers have the same rights. In addition, we provide all our employees with private health insurance. Depending on their job, we offer: free business accommodation, laptops, corporate mobile phones, cars, credit cards for business trips, fuel.

EKO Serbia
We provide all of our employees with private health insurance. Depending on their job, we also offer: laptops, corporate mobile phones, cars, credit cards for business trips, EKO discount cards.

HP Cyprus
Medical, pension and life insurance program given to all employees.

OKTA
Financial Aid for Students and School pupils, Christmas/Easter Gifts, Holiday Allowance.

All staff, irrespective of their gender, are entitled to maternity/paternity leave.

• In 2017, 41 workers (19 HELPE + 9 EKO + 3 OKTA + 3 JPK + 3 EKO Serbia + 2 EKO Bulgaria) and 2 employees (DIAXON) received parental leave.
• 24 employees returned from parental leave which expired in 2017, while a further 19 employees returned whose parental leave expired in 2016.
• Average return to work rate for the Group, 2017 = 29.63%

 “Product Safety, Quality & Product Affordability” see “Why is it material?” p. 49

“Product Safety, Quality & Product Affordability” see “Our approach” p. 49

“Product Safety, Quality & Product Affordability” see “Our approach (evaluating mechanisms, results)” and “Our ambition” p. 49-55

“Product Safety, Quality & Product Affordability” p. 49-55

The risk assessment is conducted for the entire life cycle of each substance and includes the exposure scenarios for every use. For this purpose, as REACH Regulation (EC 1907/2006) requires, there is continuous communication throughout the entire supply chain.

Potential risk assessment for safety, health and environment has been conducted for the substances of products of the Refineries and Chemical Plants. This assessment has been done for all product phases (production, storage, transport, distribution, use, disposal).

The aim is to assess the permissible level of dose/concentration to which humans and environment may be exposed, as well as to set the proper use and measures for risk mitigation. Products are classified and labelled for hazards, in accordance with the European CLP Regulation (1272/2008) and the adaptation regulations relevant to technical and scientific developments. The Group’s customers are provided with guidance on safe use through the extended Product Safety Data Sheets (e-SDSs).

HELPE/ HP Cyprus/ EKO Serbia/ OKTA
None. Non non-compliance incidents.

EKO Bulgaria
One incident during the reporting period relating to the periodic technical inspections of a petrol station.
There are no incidents concerning the health and safety effects of products and services.

“Product Safety, Quality & Product Affordability” p. 49-55

Copies of Product Material Safety Data Sheet are provided with packaged products such as lubricants ( Ch. “Market”, Section “Product Accessibility”, p. 51-53, the table “Precentage of the sales per product for each of the Group’s companies” presents the main products). No such requirement apply to non-packaged products.

HELPE/ ΟΚΤΑ/ HP Cyprus/ EKO Serbia/ JUGOPETROL
There are no cases of non-compliance.
There is a process for checking service stations in regards to the products (see also (Ch. «Market”, Section “Product Safety, Quality & Product Affordability” p. 49-55).

ΕΚΟ Bulgaria
Fine for liquid fuels non - compliance as per the requirements laid down by the law regarding air cleanliness and a small number of insignificant sized fines for lack of fuel control signals on pumps.
There are no incidents related to non-compliance in regards to product information and labelling.
Led to a warning.

No incidents of non compliance.
Full compliance with relevant regulations/codes (e.g. unfair competition and consumer protection).

 “Uninterrupted Operation & Being Prepared for Emergency Situations” see “Why is it material?” p. 45

“Uninterrupted Operation & Being Prepared for Emergency Situations” see “Our approach” p. 45

“Uninterrupted Operation & Being Prepared for Emergency Situations” see “Our approach (evaluating mechanisms, results)” and “Our ambition” p. 45-47

p. 58

“Value Creation” p. 13

In 2017, the Group’s turnover was €7,995 million (2016: €6,613 million) and the social product amounted to €1.7bn (2016: €1.4bn) distributed as follows:

• €224 mil. to staff (salaries and social benefits)
• €55 mil directly to the Greek State through direct taxes and insurance contributions, as well as €1.3 bn of indirect taxes (excise duties, VAT) collected and delivered to the Greek State
• €4.9 mil. to society through Corporate Social Responsibility initiatives

Employees’ remuneration and benefits:

Group payroll € 193,752,585

Payroll taxes € 40,471,309

Insurance contribution € 45,134,628

Employees’ insurance plan € 4,941,819

Employees’ pension plan € 7,012,745

Staff commuting € 5,028,043

Food provisions (on-site)  € 5,456,102

School allowance € 291,621

Employees’ university studies allowance € 184,945

Support to employees’ family members with special needs € 85,599

Wedding/birth/death allowance € 112,687

Crèche allowance € 462,544

Employees’ children camping € 251,632

Awards to top students € 293,407

Vouchers/gifts for Easter & Christmas € 2,237,333

Company cars € 2,029,381

Other benefits € 2,039,102

PAYMENTS IN COUNTRY PER COMPANY AND PAYMENT:

The Group does not use a defined benefit plan but a defined contribution plan.  The company’s obligations are covered by the company’s general resources. For total expenses see indicator 201-1.

Employees' retirement costs are borne solely by their insurance funds, as appropriate. Pension and medical insurance plans cover the following proportion of employees:

The employees participate in meeting the cost, and more specifically the health and pension plan, as follows:

HELPE-ΕΚΟ
For 2017 the following were applied

DIAXON

• Employer participation rate:
For employees insured up to 31/12/1992 (old) 6.5%
For employees insured after 1/1/1993 (new) 2.5%
In addition, for shift workers, an employer's shift payment is paid at 2.5% on the shift rate (24.5%)
• Employee participation percentage:
Employee participation rates vary as follows:
For employees insured up to 31/12/1992 (old) the rate is from 1.5% to 15%.
For employees insured after 1/1/1993 (new) the rate is from 0.5% to 15%.                                                        

ΑSPROFOS
1.5% employer & 2-6% employees. An employee has the ability to unilaterally increase the percentage to the limit, i.e. 6%. (Min: 2%)

ΗΡ Cyprus
Participation 100% which for 2017 includes: Employer: Define Benefit Plan 17.3% and Define Contribution 5%, Employee: Define Contributions 5% -15%. For newly insured employees from 2015, the Employer pays 8% for the Define Contribution while Employees pay 5-15%.

JUGOPETROL
15% employee/ 5.5% employer contribution. Retirement contributions are legal obligations, set up by State laws and regulations.

ΕΚΟ Serbia
The contributions to pension & health are in accordance with the law which defines them as 14% of gross earnings.

None.

With the assumption that “local minimum” wages are national collective bargaining agreements, HELPE’s employees are compensated over and above them, without any discrimination or differentiation. No permanent employee is remunerated at the minimum/basic salary at HELPE, EKO, DIAXON, EKO BULGARIA, EKO SERBIA or JUGOPETROL.

The industrial sites Aspropyrgos, Elefsina & Thessaloniki are deemed as HELPE’s significant locations of operations.

Indicative examples of salaries are as follows:

ΕΚΟ Bulgaria
Local minimum €261, newcomer’s salary €522.

ΕΚΟ Serbia
Local minimum €257, newcomer’s salary €457.

JUGOPETROL
Local minimum €193, newcomer’s salary €574.83.

Staff ranking higher than Assistant Director are included in the senior management category:

HELPE: 2.30%

ΕΚΟ: 2.50%

ASPROFOS: 0%

DIAXON: 33.33%

ΕΚΟ Bulgaria: 25%

ΕΚΟ Serbia: 50%

HP Cyprus: 100%

JUGOPETROL: 100%

ΟΚΤΑ: 33.33%

Moreover, in the process of recruiting staff, HELPE allocates additional merit to residents from neighbourhoods surrounding the refineries (definition of significant locations of operation).

“Society” p. 74-83

In 2017 was conducted the 3rd Materiality Assessment & Stakeholders engagement ( Ch. “Stakeholders & Material Topics” p. 18-23 following a Qualitative & Quantitative Survey (Company Reputation Monitor), in local communities, which took place in 2014. Such approaches are used to determine investments in infrastructure and other activities that benefit local communities. All projects take place in consultation with local communities.

Indicative examples include:

• Heating oil in the schools of neighboring municipalities Thriasio & West. Thessaloniki (€271,335)
• Heating oil in institutions and organizations such as "Apostoli", "Arktouros", "Children's General Hospital in Pendeli", "PEKAMEA", "Amymoni" and others. (€225,134)
• Fuels in municipalities for firefighting vehicles and in institutions for commuting, such as "Elefsina's Love Center", "PAKOE", "ELEPAP" and others. (€173,670)
• Bitumen for road construction projects in the Municipality of Elefsina (€ 30,820)
• Natural science laboratories in schools in the Municipalities of Elefsina, Aspropyrgos and Mandra (€36,500)
• Reconstruction of children's playgrounds in Municipalities: Kordelio-Evosmos, Ampelokipoi-Menemeni, Delta as well as the reconstruction of a playground and a basketball court in the Municipal Unit of Kalohori (€ 186,112)
• Support of Port Authorities: Thessaloniki (boat repairs), Piraeus (binoculars) (€ 27,112)
• Support of Firefighting Services: Karpenisi (tires), Elefsina (repair of firefighting vehicles), Thessaloniki-2nd (operational  maintenance equipment) (€ 21,613)
• Cleaning up the Thermaikos Gulf (€ 3,720)
• Other support of Municipalities: Aspropyrgos (environmental station maintenance), Kordelio-Evosmos (environmental measurement analyzer), Ampelokipoi-Menemeni (safety consumables), Elefsina (maintenance of PV stations in schools) (€ 116,652)
• Other support of Services: 3rd Thessaloniki’s customs office (stationery), Sindos Police Station (electrical equipment), 873 & 874 Army’s Fuel Depots (€ 2,009)

Bulgaria:

• Construction of a children's playground in Yambol (€ 2,885)

Montenegro:

• Construction of a children's playground in Megastill (€ 13,000)
• Support of Hospitals: Hospital “Berane” (hospital beds), Kotor’s General Hospital (hospital machinery) (€21,000)
• Fuel donation for the vehicles and machinery that helped restore the flooded communities of Petnjica and Berane (€ 2,000)
• Support of Firefighting Service and organizations for fire safety during the summer season (€2,500)

fYROM:

• Donation of 10 PCs and 10 air conditioners at the General Hospital "D-r Ferid Murad" in Gostivar (€ 6,452)
• Donation of technological equipment to Special Schools Idnina & Zlatan Sremec (€ 2,550)
• Support of Ilinden Municipality with trees for the "With Greenery against Pollution" program and with books on the "Give a book for a Easter egg" program (€1,496)

The financial crisis has escalated expectations for multinational enterprises to create more social value, beyond their compliance with regulations and philanthropy. Corporate responsibility has emerged as an important element in the private sector’s response to these expectations and demands.

For additional information about our contribution to society, please see Ch. “Society” p. 74-83 and also section “Value Creation” p. 13

1. Financial support to improve the quality of life of low-growth areas:
   See indicator 203-1 for relevant projects.
   In investing in Montenegro, JP is helping the country boost its economic output and is indirectly creating new jobs. Capex of more than 20 million is expected in the next five years.

2. Economic impact of improving or deteriorating social or environmental conditions: 
   See  Chapter “Environment, Energy & Climate Change” for actions aiming at improving environmental conditions.
3. Availability of products and services for those on low incomes: 
   See  Chapter “Society” p. 74-83, for fuel donations, food vouchers and prepaid fuel cards.

4. Enhancing skills and knowledge amongst a professional community or in a geographical region:
   More than 3,500 people visit the industrial facilities of the Group every year in Aspropyrgos, Elefsina and West Thessaloniki. Specifically, in 2017, 4,171 students and students from educational institutions of all levels were trained in our facilities and were briefed on the sectors of refining, company and employment.
   An “Open Day” for Belgrade University students was organized in HP Serbia at the headquarters of the company.
   At OKTA, internships have contributed to the exchange of knowledge and experience between students and local universities.

5. Jobs supported in the supply chain or distribution chain: 
   See  Chapter “Society”, Table “Responsible buying from local suppliers” p. 80.
   JP relocated its Headquarters from Kotor to Podgorica which obviously impacted the Kotor municipality, as it lost its main employer.
   At OKTA:
   - The company significantly improved its cash position and managed to repay all loans.
   - We are continuing with road transportation, thereby supporting the truck transportation sector.
   - We have outsourced product quality control
6. Economic impact of change in location of operations or activities: 
   In the process of staff recruitment, at HELPE, there is a procedure in place which is in favour of the permanent residents of the municipalities neighbouring our refineries.
7. Significance of the impacts in the context of stakeholder priorities:
   A 3rd survey on Materiality Assessment & Stakeholders engagement was conducted in 2017 (see  Chapter “Stakeholders &  Material Topics” p. 18-23 based on a questionnaire and interviews with stakeholders inside and outside the company, and a Qualitative & Quantitative Survey (Company Reputation Monitor), in local communities, took place in 2014.
   Such surveys, regular communication and consultation are used to determine the investment in infrastructure and other actions for the benefit of local communities and to understand the significant indirect effects locally. Assessing the findings resulted in relevant activities planning. It has been recorded that local communities anticipate actions which focus on supporting the unemployed, health services, and support of the elderly and vulnerable groups in general. Moreover, during the planning phase of new investments, care is taken in regards to the direct and indirect impacts of future actions.

“Local Communities” p. 80

Procurement from locally-based suppliers at significant locations of operation is 13,4% γ for HELPE and DIAXON (industrial facilities) and 97% for the Group’s marketing companies (EKO, HF, EKO BULGARIA, ΟΚΤΑ, HP CYPRUS, EKO SERBIA, JUGOPETROL), presented in detail in the “Sustainable Development & Corporate Responsibility Report 2017”, Chapter “Society” p. 74-83.

Local suppliers, at HELPE and DIAXON, are defined as those based in municipalities adjacent to the Group’s industrial facilities. For the Group’s marketing companies (EKO, HF, EKO BULGARIA, ΟΚΤΑ, HP CYPRUS, EKO SERBIA, JUGOPETROL), local suppliers are defined as those based in the same country.

Significant locations are defined as the municipalities neighbouring the Group’s refineries/DIAXON.

The Group’s policy is to support the local market and local contractors, always in accordance with the selection criteria that we apply to our suppliers, such as safety, quality standards, competitiveness etc. In this context, the Group (along with other large companies) is investing in properly training subcontractors so as to ensure their ability to participate in Group’s projects.

There were no court appeals concerning anti-competitive behavior, anti-trust and monopoly practices.

There are no significantly affected sources.

The Group’s refineries are not near protected areas (NATURA, RAMSAR). They are located in designated areas of industrial activity.

Significant work has been done for the minimization of the impacts to the environment and the ecosystem. The refining sector has the wider application of the Best Available Techniques for the environmental protection than any other sector in Greece. The management of wastewater and waste is based on BATs resulting in zero impact on living organisms while air emissions are controlled based on the Guidelines for air quality and therefore the effect on living organisms is estimated to be negligible.

There are no such habitats. 

All new suppliers are evaluated during tender processes and commit to uphold the Group’s values and policies when it comes to environmental management in the event that they undertake a contract. A revised procedure for the registration of new suppliers onto the database that will include CSR and SD relevant criteria is currently being developed.

No significant findings for 2017.

Suppliers commit to uphold the Group’s values and policies concerning  environmental management at the time of signing of the contract/purchase order for materials or services, which includes a supplier “compliance clause” with the principles of the UN Global Compact.

The contractors who conduct work in the refineries are evaluated after the conclusion of their work, based on their environmental management  performance.

No significant findings for 2017.

At least one month and at the latest within 3 months.

Management Announcements are issued for any changes involving groups of individuals.

Other forms of communication: personal letters, memos, notification of decisions made by the Service Council.

Any change in the terms of an individual employment contract is notified to the parties concerned in accordance with the provisions of Presidential Decree 156/94 within one month of the upcoming change.

The local law applies, where appropriate, to employment contracts in Bulgaria, and FYROM where the minimum period is 30 days, in Montenegro where it is 15-90 days depending on the type of change (30 days according to collective agreements), in Serbia it is 7 days, while in Cyprus, sufficient time and support are provided to facilitate change (as per relevant legislation).

“Education & Training”  p. 36-37, “Health & Safety Training” p. 44

Training breakdown by gender and company:

Training expenditure breakdown:       

Number of employees per type of training and company:

The Group’s total expenditure for the above issues in 2017 amounted to 885,037€ while the total number of training hours was 110,139.

Indicatively, 33,704 hours of health, safety and fire safety seminars were held within the company.

The Group’s HR Department aims to continuously improve employees’ skills by implementing long-term in-house education & training programs so as to ensure for their “continuous employment”. Topics covered by these programs include: learning English and sustainable development issues, to name but a few. Also see Chapter “Employment”, section «Education & Training” p. 36-37).

In the case of retirement, compensation is also provided to retirees wherein the age and length of service are taken into account for the calculation of their retirement allowance.

The employment relationship is terminated in accordance with the provisions of the internal labour regulations.

For senior and top management, the evaluation is made annually based on KPIs and links the company’s performance with the objectives of the staff, on issues such as sustainable development (safety, the environment, etc.).

 p. 66-67 (Executive/non-executive board members of the parent company: 5/9, in 2017).

The following table presents the breakdown of the 90 members of the Group’s BoDs included in this Report:

% of women in senior management: Group average Ομίλου 18.41%, (HELPE 22.29%, ΕΚΟ 20.65%, ASPROFOS 1.75%, JUGOPETROL 14.29%, EKO Serbia 0%, HP Cyprus 0%, EKO Bulgaria 100%, OKTA 11.11%, DIAXON 0%).

“Employment” p. 32-37

In 2017 the Group employed 49 people with disabilities (permanent employees).

Employee breakdown per age group, gender and nationality:

This is a non-material issue as the Group does not differentiate between men and women in regards to remuneration. Salaries are based on annual evaluations and follow both Greek and EU legislation on equal pay. There is no discrimination or other economic differentiations in any company based on the principle of equality.

The HR Department monitors such phenomena and acts accordingly in cooperation with the employees’ unions.

No relevant reports in 2017.

The Human Resources and Procurement Divisions monitor such phenomena and act accordingly in cooperation with employee’s representatives.

A compliance clause of our suppliers with the principles of the UN Global Compact has been incorporated in all new contracts and purchase orders for materials and services.

The HR and Procurement Divisions (in cooperation with the union of employees, if required) monitor such phenomena and act accordingly. In 2016 there were no relevant reports.

The Group’s recruitment policy states that no employees under the age of 18 can be employed.

A compliance clause of our suppliers with the principles of the UN Global Compact has been incorporated in all new contracts and purchase orders for materials and services.

The HR and Procurement Divisions (in cooperation with the employees union, if required) monitor such phenomena and act accordingly.

A compliance clause of our suppliers with the principles of the UN Global Compact has been incorporated in all new contracts and purchase orders for materials and services.

All of the Group’s security personnel (Group Security Division) are certified from the Security Studies Centre and the National Organization for the Certification of Qualifications & Vocational Guidance as qualified security personnel, and are properly trained in this respect. The certification process included a special topic concerning human rights and related issues. The other training received by security staff was Detection of Counterfeit Documents, X-RAY Training, Detecting and Checking Suspicious Items, Managing Suspicious packages - Objects & Trapped Vehicle Management,  Training in Case of Carrying a Concealed Weapon, Training for the Protection of Persons and Vulnerable Objects, Training for Quick and Safe Driving, Training for Phone Threats, ISPS Personnel Training, Political Planning of Emergency Situations (PPES) and Fire Exercises (correct use of the fire extinguisher). 

This is not a material issue as there are no such cases. No incident of rights violation has ever been reported or found.

This issue has never been investigated because no such problem has ever been reported.