Governance (G)

C-G1 | Sustainability Oversight

In June 2021, following a decision made by the CEO of PPC S.A., PPC proceeded to the establishment and formation of the Sustainable Development Department, directly falling under the CEO, and a Director of the Sustainable Development Department was appointed, following a Public Vacancy Notice (July 2021).

Prior to the formal establishment of the Department, the key functions around Sustainable Development were performed by the Corporate Social Responsibility and Sustainable Development Section, part of the Corporate Affairs and Communications Department, which was primarily responsible for the CSR Annual Report and subsequent Sustainability Report. From 2020, a basic group of specialized Management Consultants began to lay the foundations for the establishment of the separate SD Department.

By decision of the Board of Directors, a Sustainability Committee has been established with representation from the top management (in the context of the TCFD action plan), which will be responsible for overseeing Sustainability and  informing the Board of Directors on Sustainability matters, aiming at further enhancing the Board oversight and awareness on such matters.

C-G2 | Business ethics policy

PPC’s Code of Conduct

C-G3 | Data security policy

Financial Report FY 2020

• Risk associated with Information Technology (IT) security,  p.24
• Risk of non-compliance with the European Union's General Data Protection Regulation ("GDPR"),  p. 29
• Safeguards for information systems, p. 50

A-G1 | Business model

Sustainable Development Report 2020

Business Model pp 57-61

A-G2 | Materiality

Sustainable Development Report 2020

The methodology and results of the materiality analysis are presented in pp105-107 in the Sustainable Development Report 2020.

A-G3 | ESG targets

Targets - Environment (Ε)

Short-Term (1-3 years)

Medium (4-7 years)

Long Term (8-10 years)

Reduction of CO2 emissions (scope 1) by 40% in 2022, by 57% in 2023 and 78% in 2024 in comparison to 2019 (base year)
 

Phase-out of existing lignite plants by 2023 and complete cessation of lignite use for energy production by 2025

Redistribution of capital in RES to shift the production mixture to sustainable sources and stable profitability while supporting the country's energy needs

Development of the Largest Public Charging Network using Green Energy (from RES) and presence throughout Greece

New energy saving solutions, such as a new platform for monitoring consumption & update of Medium Voltage Customers

All PPC Sales Stores use RES with an annual consumption of 8,500 MWh.

New energy saving solutions as well as green products and services.

More than 1,500,000 MWh of nominal Guarantees of Origin to be made available to PPC Corporate Customers

Implementation, in collaboration with the Environment Department and a specialized Consultant, of the "Design and Development of Carbon Footprint Inventory Methodology" project in order to calculate the overall footprint of the Company (Scope 1, 2 and 3 based on the terminology of the GHG Protocol). More specifically, the project’s goal is the design and development of appropriate tools and methodologies for the calculation of the Company’s carbon footprint on an annual basis and in accordance with international standards (GHG protocol and / or ISO 14064), using corporate activity data and emission sources, appropriate emission rates and relevant national and / or international best practices. The goal is the project’s completion by the end of 2021.

Conversion of the generators of the lignite plants whose operation is definitively ceased (Units III & IV of the KARDIA TPP), to Synchronous Condensers with the aim of providing auxiliary services to the network
(Balancing market):
1.Reactive power regulation
2.Voltage Support
3.Providing rotational inertia
The implementation of this project will achieve:
• Reduction of the total operating cost of the electric power system,
• Reduction of the environmental footprint in the operation of the system by avoiding the inclusion of polluting Power Plants.

Targets - Society (S)

Short-Term (1-3 years)

Medium (4-7 years)

Long Term (8-10 years)

Implementation of an annual employee engagement survey and ensure that its results are put into practice.

Renovation of 70% of customer service stores and integration of the necessary specifications for easy access and service for the disabled until 2024.

Social measures amounting to almost 100 Million Euros to support PPC customers during the pandemic, with the aim of financially facilitating households (individuals, professionals, vulnerable customers).

Wider upgrade of the branch network with the aim of immediate service, giving the opportunity to everyone to take a step forward in the future and to explore the new innovative possibilities offered by PPC.

New services for the safety of PPC customers during the pandemic through new electronic means of communication and transactions (indicatively, through Chat Bot and electronic payments), as well as a new online appointment service at PPC stores.

• New digital Ecosystem with personalized suggestions and greater ease of transactions and service requests.
• New services and products based on Consumer Profiling (person-based).

New products that meet the real needs of consumers, for stability and transparency in energy charges, as well as products for modern consumers, such as MyHome Online, a new digital electricity product.

Within 2020, education of about 8,000 young students who attend Kindergartens and Primary Schools of the Municipalities of Attica, through a program with simple tips for saving electricity.

Study, design and implementation of projects to cover the District Heating
Needs of the Municipalities of Kozani, Eordaia, Amyntaio.

Electromobility
1. Installation of Different Types of Chargers, Single (AC) & Fast Chargers (DC)depending on the charging need and the Charger’s installation location
2. Launching of the PPC blue Electromobility Platform for the interconnection of PPC
blue Public Chargers, the identification of their Location, and the charging of the
Services
3. Development of PPC blue website for informing users about electromobility and PPC blue services.

Targets  - Governance (G)

Short-Term (1-3 years)

Medium (4-7 years)

Long Term (8-10 years)

Business Ethics & Compliance:
Implementation of a program that includes the updating of existing and the development of new policies and procedures as well as guidance for their implementation (emphasis is given to whistleblowing, anti-corruption, bribery, conflict of interest and updating the Company’s Code of Conduct. It also aims at full compliance with the new legislation on Corporate Governance.

At least 25% Participation of women in the BoD of PPC, in accordance with
Circular No. 60 of the Hellenic Capital Market Commission.

Α-G4 | Variable Pay

% Variable Pay

=

Amount of variable pay, in Euros

/

Total executive's remuneration, in Euros * 100

=

0

Assumptions, hypotheses, constraints used for the calculation

With regards to variable remuneration (bonuses, shares, etc.), these are paid only to the Directors, the Chief Officers, Deputy CEOs and CEO and are dependent on the achievement of the previous year's targets.

In 2020, based on the achievement of the 2019 targets, no bonus was paid.

In 2021, based on the achievement of the 2020 targets, a bonus was paid and Shares will be granted in 2022, pursuant to the Remuneration Policy .

The detailed methodology for granting variable remuneration (bonus, shares) is included in the Remuneration Policy approved by the Extraordinary General Meeting of Shareholders dated 4 June 2021 and is posted on the Company's website

remuneration-policy-2021.pdf (dei.gr)

A-G5 | External Assurance

The Report is subject to external assurance by an independent body, in accordance with the International Standard on Assurance Engagements ISAE 3000. The Assurance Statement is available on pages 387 - 392  in the Sustainable Development Report 2020

SS-G1 | Business ethics violations

The Company, in any incident of corruption that comes to its attention, either following a complaint, or following an audit conducted by a supervisor/service unit and/or the Internal Audit Department, and after a thorough investigation, shall take disciplinary action against the employees involved, in accordance with the provisions of Chapter F of the Personnel Regulations (PR/PPC).

For the most part, and given the seriousness of the disciplinary offences attributed to the employees involved in such cases, such disciplinary cases are referred by the Chief Executive to the Disciplinary Board of First Instance, which may impose any of the penalties laid down in the PR/PPC (Articles 26 and 32 of the PR/PPC).

During 2020, 4 employees were subject to disciplinary control for corruption issues. Two of them were subjected to the disciplinary penalty of permanent dismissal without compensation, the third to the penalty of temporary suspension with loss of pay and the fourth to the penalty of suspension with loss of pay.

In 2020 there was 1 final conviction by a criminal court for cases falling under the criminal offence of aggravated theft.

There was a total of 59 court cases against employees or executives of the Company of which 52 offences for breach of duty, 3 offences for breaches of environmental legislation (environmental pollution), 1 offence of obstructing the prevention of public menace, 1 offence of criminal breach of trust, 1 offence of criminal forgery, and 1 offence of fatal exposure. Of these, 29 are ongoing, while 30 have been closed either by the issuance of a judgment of acquittal or a judgement of dismissal for the defendants or the case being placed on file under Article 43 or Article 51 of the Criminal Law. Furthermore, in 2020, no fines were imposed on PPC for labour issues.

In 2020, there were no irrevocable convictions by criminal courts for cases falling under the criminal offences of extortion and breach of duty, false affidavit and misappropriation of documents and forgery.

In 2020, there were 14 appeals by tender candidates (at the pre-contractual stage) against PPC, which were examined by the competent Authority for the Examination of Preliminary Objections (AEPO). Following a decision by this Authority, in 3 of these cases the candidates appealed to the competent Administrative Courts. 9 of these cases have been resolved, 7 of them by the AEPO's decision, 2 of  them by an out-of-court settlement between the applicant and PPC, and 2 are currently in progress. It should be noted that following Law no. 4643/2019 [Government Gazette A'193/ 3-12-2019], the possibility of appeal to AEPΟ was limited, as in cases of tenders below the European thresholds, the internal procedure for objections under the PPC Regulation on Works, Supplies and Services is provided for, the decisions on which have not been challenged to date before ordinary courts.

Furthermore, a 2015 decision of the Athens Administrative Court of Appeals reduced a €4.4 million fine imposed by the Regulatory Authority for Energy (RAE) in 2013 for alleged violation by PPC of the regulatory framework in its relations with industrial customers, in particular failure to prepare individualized tariffs in a timely manner, to €880,000, resulting in a refund of €3,520,000 to PPC. Despite this, PPC filed an appeal before the CoS in 2016 in order to annul the remaining fine of €880,000, which was ultimately rejected by the CoS's decision No. 1454/15.7.2020.

Furthermore, the final decision of the Athens Multi-Membered Court of First Instance in 2014 awarded PPC damages of €4,412,018.86 against a High Voltage customer for violation of Articles 18 and 86 of Law No. 146/1914 on unfair competition. This decision was appealed by PPC in 2016 and the appeal was heard in late 2020. A decision is expected to be issued.

In 2020, no fines were imposed on PPC by the Regulatory Authority for Energy (RAE) and the Competition Commission for anti-competitive behaviour and monopoly practices. Furthermore, there is no record of incidents of non-compliance regarding the proper labelling and information of products and services, as well as the effects of the Company's products and services on the health and safety of its customers. With regards to a fine of €2.8 million imposed in 2019 on PPC for compliance issues with regulatory provisions, which was paid, we note that PPC has appealed to the administrative courts with a view to revoking the above fine; PPC's application was heard before the CoS in early January 2021.

PPC also filed appeals to the competent administrative courts for 10 cases regarding municipal fees for a total amount of €1,736,649.40 million, which were imposed in 2019 or in 2020.

Lastly, in 2020, only one minor case related to non-compliance with environmental legislation, has been recorded, for which a fine has been imposed.

No other non-monetary sanctions or cases of out-of-court dispute resolution mechanisms relating to environmental issues were recorded.