p. 7-8, 15

 "Group activities’’, p. 7-9

 p. 165

 p. 36-43, 149-152, 152-154, 159-161, 165

 p. 15, 61-63

 “Internal Audit and Risk Management”, p. 23

For main impacts, risks and opportunities (due to climate change): see indicator G4-EC2.

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 storage capacity of 550,000m3 (white products) has commenced operations. The new Petrolina terminal (local oil company – 80,000m3 in storage capacity) is also operational. 120,000m3 of Cyprus strategic reserves have been relocated from Larnaca to VTTV. The four LNG companies in Larnaca conducted a feasibility study on the construction and operation of a new LPG terminal in Vasiliko, which was submitted to the government. In addition, the four companies have set up a JV and are awaiting approval from the Competition Commission.

The government is also pushing for the relocation of the fuels terminal; and has set a deadline for the end of 2017. The options for relocation are either VTTV or Petrolina stations or the company’s facilities. HPC initially submitted plans for the new terminal in Vasiliko.

Opportunities:

- Further development of the COMO Network

- Introducing Loyalty programs

- Strengthening brand awareness through marketing activities and marketing the EKO new product line (EKO Racing 98, AVIO diesel etc)

- Optimizing petrol stations network

- Operations growing in the event that the embargo comes due to the resolution of the political problem in Cyprus

Risks:

- Establishment of independent petrol stations and the competition expanding via new petrol stations

- The new VTTV terminal at Vassiliko could potentially supply products to the local market

- In the event that trade barriers are lifted, competitiveness possibly arising

- The introduction of Autogas having unforeseeable effect on automotive fuels

ΟΚΤΑ

OKTA covers about 69% of the domestic market’s fuel needs. In addition, its significant storage capacity serves as a safety mechanism ensuring that there is always an uninterrupted fuel supply into the markets where it operates. At the same time, OKTA is a major exporter/employer in transport, logistics and engineering services.

Its sustainable profitability depends on its ability to remain competitive in a market where entry barriers are low while managing its facilities as efficiently as possible in order to maintain its role as a secure supplier.

The company has the potential to increase its market share by harnessing its infrastructure and the competitive conditions it has with its suppliers.

OKTA is seeking to increase its profitability via a series of transformation projects that have already been launched and affect its activities and organizational structure.

OKTA’s transformation into a marketing company highlights just how important its commercial goals are in terms of its strategy.

In this context, the commercial targets for 2016 were to further increase market share and secure the leading position in the domestic market, coupled with maintaining profit margins, boosting competitiveness, training and staff development, and re-acquiring a share of independent petrol stations. Additional targets for OKTA’s retail business were to increase profitability from the retail network and explore potential synergies with other EKO networks.

Short-term opportunities:

- Pipeline utilization and supply chain improvement

- Further rationalization of the organization of the company

- Legal affairs management

- Increase in the country’s strategic reserves and introduction of storage fees

- Use of OKTA’s storage and loading facilities

- Building access to the retail market through organic growth (DODO-> COMO, retail know-how and EKO offers)

- Searching for alternative energy sources

Short-term risks:

- Full or partial loss of its largest customer

- Awakening strong competition in the wholesale market

- Cheap products relaunching from a competitive refinery

- Oversupply in the area

- Lack of control in both markets where the company operates (Macedonia and Kosovo)

- Limited growth of the economy

- Long-lasting political crisis

- Personnel surplus

- Transport restrictions from the Thessaloniki refinery

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):

- Political instability in Bulgaria and fragile international environment (Brexit, refugee crisis, situation in Greece)

- Loss of profitability due to increased regional price competition

- Lost opportunities due to lack of storage capacity

- Loss of market share in wholesale because of competitors’ aggressive strategy

Opportunities (short and long-term):

- Further penetration of high quality products

- Reduction of fuel smuggling through government policies

- Further development of NFR’s activities

- Further development of C & I businesses

- Upgrading the storage installation and converting it into a fully functional LPG storage facility

- Light fuels storage in privately owned or rented properties

- To further consolidate the market

EKO Serbia

Short-term opportunities:

- Continuing and strengthening the lubricants industry

- Expanding high-margin products’ penetration into the market (fuels and NFR)

- Reducing operating costs

- Increasing other revenue (services, rents, cross-business)

Long-term opportunities:

- Expanding the petrol stations network

- Increase brand value through dynamic marketing activities

- Exploiting opportunities related to new supply lines, wholesalers warehouses

Short-term risks:

- Supply dependence on NIS

- Ability to remain competitive in the wholesale industry

- Strong competition

- Increased Capex due to aging network

Long-term risks:

- Macroeconomic deterioration

- Application of aggressive network expansion plans

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

HELLENIC PETROLEUM Group

 p. 87 and front cover

 “Contact” p. 75

 “Customers –Products”, p. 39

 p. 145-149

 p. 31-47

8A Chimarras str., 151 25 Maroussi, Greece

 p. 87 and front cover

 “Report’s Boundaries” p. 67

      “Customers-Products” p. 39

 p. 11, 39

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

HELLENIC PETROLEUM Group

HELLENIC PETROLEUM SA

 p. 17-19

 p. 172

Major shareholders (>2%)

 p. 11, 39

 “Report’s Boundaries” p. 67

      “Customers and Products” p. 39

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

Sales breakdown by customer type

 p. 10-11

“Financial Performance” p. 44-45

  “Human Capital” –Tables depicting Employee Breakdowns, p. 26-35

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. Any contractors’ employees (with or without supervision) are presented in the tables below. There are no self-employed employees at the Group.

GROUP (Workforce breakdown by gender & employment contract):

Breakdowns by gender & 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

 “Human Rights-Equal Opportunities Policy” p. 27

Percentage of employees covered by collective bargaining agreements:

 p. 35

 “Supply Chain/Responsible Procurements’’ p. 37

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  "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. 67

On November 30, 2016 the Hellenic Republic Asset Development Fund S.A. (HRADF) and HELLENIC PETROLEUM S.A. received a letter from SOCAR, the Azerbaijani state oil and gas company, in which it announced its decision to not extend the Expiry Date until the three above mentioned companies, SOCAR as buyer, and HRADF and HELPE as sellers, had determined through the 21.12.2013 DESFA S.A. transaction agreement, as amended, a time limit for the filling of the peculiarities of the above transaction. The most recent Expiry Date was November 30, 2016, which expired without all the above-mentioned conditions being met.

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 G4-2.

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.

See also G4-14

 p. 65

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 G4 indicators) 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. 175-177

 “Report’s Boundaries” p. 67

 “Materiality Assessment” p. 17

“Limits and Administrative Practices for Essential Issues” at http://sustainabilityreport2016.helpe.gr/operational-efficiency-performance/GRI-G4-point

See also: http://sustainabilityreport2015.helpe.gr/userfiles/6ffd2fe2-e2bc-4741-906d-a48900e96f28/materiality%20assessment%20methodology%20(short).pdf

 “Materiality Assessment” p. 17

“Limits and Administrative Practices for Essential Issues” at http://sustainabilityreport2016.helpe.gr/operational-efficiencyperformance/GRI-G4-point

 “Materiality Assessment” p. 17

All material issues mentioned in this report (Table "Material Aspects" and Aspect Boundaries) at http://sustainabilityreport2016.helpe.gr/operational-efficiency-performance/GRI-G4-point/ apply equally to all operations and entities as shown in G4-6.

Additionally, the same Table shows whether the material issues are material within and/or outside the Group.

 “Materiality Assessment” p. 17

All material issues mentioned in this report (Table "Material Aspects and Aspect Boundaries") at http://sustainabilityreport2016.helpe.gr/operational-efficiencyperformance/GRI-G4-point/ apply equally to all operations and entities as shown in G4-6.

Additionally, the same Table shows whether the material issues are material within and/or outside the Group.

 “Methodology” p. 17

• Merger of marketing companies ( “Group Activities” p. 12)

• Operations in Egypt on hold

• New procurement regulation (See also G4-HR1)

 “Methodology” p. 17

No significant change, apart from the merger, by absorption, of EKO by HELLENIC FUELS (all trademarks maintained).

 “Our Stakeholders” p. 16-17

Presents the social partners participating in the 2015 Materiality Assessment Analysis, and interfacing approaches with stakeholder groups.

 “Our Stakeholders” p. 16-17

 “Our Stakeholders” p. 16-17

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

1. Written communication to all employees takes place through emails along with posting on notice boards

2. As per purchasing procedures, every year all suppliers/vendors are re-evaluated

EKO Bulgaria

Costumers' communication takes place through qualitative and quantitative surveys, such as Brand Vitality tracking, loyalty driving assessments etc.

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

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

The key topics that stakeholders raised are reflected in the material issues we have chosen to report this year, (see also  G4-19).

 “Our Stakeholders” p. 16-17

 January - December.

 “A few words about the Report and our Approach” p. 67

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

 "A few words about the Report and our Approach” p. 67

Annual (01.01-31.12)

 “A few words about the Report and our Approach” p. 67

Ms Rania Soulaki, Group CSR Director

E-mail: rsoulaki@helpe.gr

Tel: +30 210 6302894

Fax: +30 210 6302573

 “Contact” p. 75

In accordance with the G4 Comprehensive Option

 “Independent Certification Body” p. 70-73

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.

 “Independent Certification Body” p. 70-73

 p. 65-75

 p. 156-158, 161-165

 “Corporate Governance and Regulatory Compliance” p. 20-25

In addition to the BoD committees, advisory and coordinating committees have been set up and operate at HELPE, made up of senior company and Group executives, the main ones being the following:

I. Group Coordination Committee

II. Industrial Activities Committee

III. Trade Committee

IV. Other Energy Activities Committee

V. Group Human Resources Committee

VI. Group Credit Committee

VII. Investment Evaluation Committee - Commercial Agreements

See also Indicator G4-49

The management of subsidiary companies refers to the relevant Corporate Group Directorates and, ultimately, HELPE’s CEO.

The Group’s Corporate Relations Division reports to HELPE’s CEO.

The CFO reports to the CEO.

The Corporate HSEQ Director reports to HELPE’s CEO.

The Group’s Coordinating Committee has advisory and advisory responsibilities towards HELPE’s Management on Sustainable Development issues.

Meetings with senior management are used to define sustainability issues and to reach agreement on prioritising objectives, monitoring activities and reporting results. Sustainability is part of how managers and employees do their day-to-day jobs. It is addressed, for example, at regular work discussions and performance reviews. In this way, implementing sustainability is shared across all levels of the Group, from BoD to local level.

Sustainability issues are submitted to the Board in 2 steps: (a) the responsible General Director submits a memorandum to the CEO, (b) the CEO makes recommendations to the Board accordingly. The issue is discussed in the relevant Committee, which also makes recommendations to the Board.

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

The CFO Director is an executive member of the Board.

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

The Group’s Corporate Relations Division reports to the Group’s CEO.

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 https://www.helpe.gr/en/media-center/company-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.

 “Employee Suggestion Program” p. 17

Other Actions:

• Quarterly group executive meetings (from department head level and above) for the presentation, analysis and discussion of theGroup’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. 65-75
 

  p. 161-163

The company’s Articles of Association provide that 2 Board Members represent employees and 2 Board Members represent minority shareholders.

The following table shows the allocations pertaining to the 72 members of the BoDs spread across the Group’s companies included in this Report:

Breakdown of the 72 BoD members, 9 companies:

% of women holding senior management positions: Group average 18.35%, (HELPE 22.22%, ΕΚΟ 22.09%, ASPROFOS 1.75%, JUGOPETROL 33.33%, EKO SERBIA 0%, HP CYPRUS 0%, EKO BULGARIA 25%, OKTA 16.67%, DIAXON 0%).

The Chairman of the BoD is also an executive member.

  p. 65

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

Based on HELPE’s share composition, specific rules for the appointment and replacement of members of the BoD, which are explicitly mentioned in the Company’s Articles of Association, have been developed. The Greek State appoints seven (7) members out of a total of thirteen (13) members of the BoD if it holds, directly or indirectly, through the Hellenic Republic Asset Development Fund (HRADF) at least 35% of the shares. The shareholder Paneuropean Oil and Industrial Holdings SA and its affiliated companies appoint two (2) members of the BoD provided that they own at least 16.654% of the total of the Company’s voting shares. Two (2) members of the Company’s Board of Directors are employee representatives elected by the Company’s employees while a further two (2) members represent minority shareholders elected by the Extraordinary General Meeting of minority shareholders (except Paneuropean Oil and Industrial Holdings SA or its affiliates).

Currently, there is no institutionalized nomination procedure for the members of the Board of Directors elected by the Special Shareholders’ Meeting of minority shareholders. The members of the Audit Committee are elected by the Ordinary General Meeting of Shareholders pursuant to Law 3693/2008 and are all independent non-executive members. The Chairman and one member of the Committee have a great deal of knowledge and experience in accounting and auditing as required by Law 4449/2017.

  p.  11

  p. 158

  p. 65-66

 “Corporate Governance and Regulatory Compliance” p. 20-25

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—rom 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. 178-181

  p. 70-75

The risk management system (see and G4-2) 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.  157

 “Corporate Governance Performance” p. 24

See also indicators G4-40, G4-51

Apart from the BOD’s evaluation, the Board monitors and reviews the implementation of its decisions on an annual basis. Moreover, the introduction of an evaluation system for the members of the BoD and its committees is under consideration, in the context of the aforementioned Code of Corporate Governance of the Hellenic Corporate Governance Council (HCGC), at: http://www.sev.org.gr/Uploads/pdf/kodikas_etairikis_diakivernisis_GR_OCT2013.pdf

During 2017, consideration is being given to the possibility of establishing a common evaluation procedure for all members of the Board of Directors.

The following relevant Committees also support the BoD:

1. Audit Committee (Article 37 Law 3693/2008)

2. Committee on Finance and Economic Planning, which, among other things, “is informed by the CEO, the General Directorate of Finance and auditors about significant risks or exposures and assesses the measures taken or to be taken to minimize risks.”

3. For further information about the BoD Committees, go to: http://www.hellenic-petroleum.gr/Uploads/pdf/FINAL%20GR%20DIGITAL%20FROM%20ACCESS.pdf (p. 21)

The drafting of the Corporate Crisis Management Plan has been implemented.

2 members of the Board are elected by employees and two members are appointed by the Special General Meeting of minority shareholders.

The BoD approves the reports & budgets for the Companies and the Group, as well as the 3-month, 6-month and annual reports and Group announcements. The Executive Committee approves Divisional and Departmental reports & budgets on a monthly and quarterly basis.

  p. 67

The BoD approves the reports & budgets for the Companies and the Group, as well as the 3-month, 6-month and annual reports and Group announcements.

The Executive Committee approves Divisional and Departmental reports & budgets.

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. 75.

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 G4-37.

The critical issues presented to the Board refer to the material aspects that were recorded and evaluated through the “Materiality Analysis 2015”.

  p. 158

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 nonexecutive) 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.

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. 158

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

1. Personnel are covered by a collective agreement – salary scales (collective agreement ) as per position

2. 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 acollective 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 in  “Report’s Boundaries”, p. 67

Countries where there is significant activity are shown in “Report’s Boundaries”, p. 67

  p. 11-12

  “Vision-Strategy-Principles” p. 18-19

       “Internal Regulatory Framework” p. 23

  Internal Labour Regulation

See also indicator G4-14.

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 - is in the process of being approved by the BoD.

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.

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.

Risks related to sustainability such as personnel, safety, the environment, business conduct and supply chain management form an intrinsic part of the Group’s Risk Management. For each of the risk categories within all operating companies as well as at group level a risk assessment is conducted together with determining improvement potential, used in turn, as a tool for improving the Group’s day to day operational activities.

In the Code of Conduct, HELLENIC PETROLEUM stipulates that every employee must behave honestly, transparently and responsibly towards customers, business partners, shareholders, and colleagues. The Code also provides the opportunity for ethical and lawful conduct counselling; as well as for anonymous reports to make their way to the Compliance Office.

In order to further ensure that our business integrity policy is actively and properly implemented, Compliance Services have been established within the framework of the Code of Conduct. Employees can contact the Compliance Office with any questions about integrity or reports of alleged wrongdoing, with absolute confidentiality and discretion. The Code of Conduct has been translated into all of the languages of the countries where the Group operates.

 “24 hour service” p. 41

ΟΚΤΑ

We have implemented a mechanism to protect 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 operational.

HP Cyprus

The Group’ Code of Conduct has been implemented since 2012. The code handles all aspects and has been communicated to all employees, suppliers and customers and makes up part of the contracts.

EKO Bulgaria

Reporting mechanisms and overall reporting responsibility procedures are established by the Group’s Code of Ethics provisions.

The observance obligation for the Group’s Code of Conduct is included in each partner’s agreement. Concerns are treated confidentially. The Company has a non-retaliation policy. Cases of concerns have not been raised for the reporting period.

EKO Serbia

In cooperation with an outsourced agency an open line (email and toll-free phone number) 24/7 is in operation. Depending on the communication issue, staff in charge conduct an investigation and prepare a final response. According to local legislation, all forms of communication which are officially received have to be resolved within 15 days.

Hazardous Waste/ Effluent Handling, G4-ΕΝ22, G4-ΕΝ23, G4-ΕΝ25

It refers to the collection, transfer, recycling or disposal, managing and monitoring of waste that are either hazardous or non dangerous to both public health and environment.

Includes also the disposal of liquid waste and/or effluent into surface waters, which causes water pollution.

The Group’s approach is presented in detail in the ‘’Sustainable Development & Corporate Responsibility Report 2016’’, Chapter ‘’Environment, Energy and Climate Change’’, Section ‘Air Emissions and Waste’.

Use of Renewable Energy Sources, G4-EN3, G4-EN4, G4-EN5, G4-EN6, G4-EN7

It refers to the use of renewable energy sources (RES), such as solar, hydro, geothermal and wind energy.

The Group’s approach is presented in detail in the ‘’ Sustainable Development & Corporate Responsibility Report 2016’’, Chapter ‘’Corporate Identity, Shareholders and Business Activities’’, Section ‘’ RES’’ and Chapter ‘’Environment, Energy and Climate Change’’ , Section ‘’ Biofuels and Renewable Energy Sources’. Further information provided through OG-2 and OG-3 indicators.

Use of Non-Renewable Energy Sources, G4-EN3, G4-EN4, G4-EN5, G4-EN6, G4-EN7

This refers to the use of non-renewable energy sources, such as fossil fuels and electricity consumption from the public power corporation.

Our energy consumption contributes to a significant amount of our costs and is an indicator of the efficiency of our processes. As a large company in an industry sector with relatively high energy consumption, our energy usage has a great impact on society. We have set targets for relative reduction in energy usage; and we monitor and benchmark progress on these targets.

All the Group’s refineries are energy optimized and feature cogeneration CHP units, which cover about 37% of the electric energy needs of the Group. Due to the operation of these units the emission of 312 thousand tones of CO2 in 2014 was avoided (based on PPC’s weighted average emission factor of 1.11 kg CO2/kWh for 2013), significantly contributing to the reduction of nation-wide levels of greenhouse gases emissions.

The Group’s approach is presented in detail in the ‘’ Sustainable Development & Corporate Responsibility Report 2016’’, Chapter ‘’Environment, Energy and Climate Change’’, Section ‘’ Energy and Climate Change’’.

GHG Emissions (CO₂, SO_2, NOx, Particulate Matter & VOC emissions), G4-EN15, G4-EN16, G4-EN17, G4-EN18, G4-EN19, G4-EN20, G4-EN21

This refers to the overall GHG emissions (both direct and indirect, mainly CO₂) due to Group’s operations.

Τhe Group’s strategy is to reduce greenhouse gas emissions through increased energy efficiency and investments in renewable energy projects.

At all Group’s refineries cogeneration units (Combined Heat and Power or CHP) are in operation; which contribute to the avoidance of a significant proportion of CO₂ emissions that would be emitted if the self-produced electricity came from a provider (such as PPC) with a different fuel mix.

Regarding monitoring and reporting of emissions, the HELLENIC PETROLEUM Group systematically monitors both the direct CO₂ emissions (Scope 1) and the indirect emissions (Scope 2 and 3), to the maximum extent of its activities. Indicatively, the estimated CO₂ emissions from sea transport of raw materials and products as well as the estimated carbon footprint (carbon footprint project) of all activities in the Group’s office buildings (headquarters and refineries of Aspropyrgos, Elefsina and Thessaloniki) are presented; (certification MyClimate).

The Group’s refineries participate in the Emissions Trading Scheme (EU ETS) since its establishment; whereas, since 2013, follow all procedures relevant to monitoring, calculation and verification of emissions; according to the 3rd phase regulations of the EU ETS 2013-2020.

The Group’s approach is presented in detail in the ‘’ Sustainable Development & Corporate Responsibility Report 2016’’, Chapter ‘’Environment, Energy and Climate Change’’, Sections ‘’ Air Emissions and Waste’’ and ‘’GHG Emissions’’.

Water Consumption, G4-ΕΝ8, G4-ΕΝ9, G4-ΕΝ10

This refers to the total amount of water used by the Group in conducting its operations and activities.

The Group’s approach is presented in detail in the ‘’ Sustainable Development & Corporate Responsibility Report 2016’’, Chapter ‘’Environment, Energy and Climate Change’’, Section ‘’ Water Management & Other Resources ‘’. In the Section’s relevant tables and diagrams the origin of the water used in production processes as well as recycled and reused quantities are presented.

Biodiversity (Oil Spills & Leakages), G4-EN24, G4-EN26, G4-EN27

Refers to oil spills to the environment during the production processes or during transport of the product.

The Group follows a strategy for further development of its activities and the continuation of existing operations with respect to the natural environment.

It is underlined that none of the Group’s industrial complexes is near protected areas (NATURA, RAMSAR). All complexes are at established industrial areas.

The Group has developed protection and enhancement actions of the natural environment and ecosystems as a priority and a fundamental pillar of its sustainable development strategy (see the ‘’ Sustainable Development & Corporate Responsibility Report 2016’’, Chapter ‘’Environment, Energy and Climate Change’’, Section ‘’Ecosystems and Biodiversity’’).

HELLENIC PETROLEUM follow closely developments concerning effective implementation of the national strategy for biodiversity while they are at the disposal of the national authorities for cooperation in this direction.

Maritime transport fuels are made with modern technology ships inspected regularly by shipping registers in accordance with international standards. The Group’s privatelyowned and chartered vessels meet all of the applicable MARPOL regulations and conventions (International Convention for the Prevention of Pollution from Ships), EU regulations and ISGOTT & ISM (International Safety Guide for Oil Tankers and Terminals and International Safety Management Code) international standards. The vessels are also covered (by P & I clubs) for pollution incidents. In the discharging / loading areas there are means of protection and restriction of pollution whereas frequent drills (in collaboration with authorities like the Fire Department, Port Police & Hellenic Police) ensure the readiness of human resources.

In addition, actions such as the training of tanker drivers in defensive driving minimize risks of road accidents.

Product Impact, G4-PR1 to G4-PR7

Refers to product consumption by the end consumer and its impact on the environment mainly in terms of air emissions.

In the context of our Quality Policy and care for our customers, the Group is committed to supply products and services which fully comply and / or are better than the agreed specifications, to provide complete technical data on the quality of products / services to all concerned and to offer its customers, partners and staff the opportunity to evaluate and contribute to the further improvement of the quality of products and services.

Increasingly stringent fuel specifications (zero sulphur fuels), for the fuel supplied to the final consumer, contribute to the reduction of gaseous emissions such as sulphur dioxide (SO₂) and particulate matters.

Best available techniques, such as the LDAR program, are also applied to the storage and distribution of products in order to reduce VOC emissions. These include: installation of secondary barriers in the floating roof tanks, painting tanks storing volatile products in white (high reflectivity), bottom-loading of tank-trucks and vapour recovery systems at the fuel loading facilities.

Moreover, all of the Group’s installations use vapour recovery systems when loading gasoline, according to the relevant legislation.

EKO’s and HF’s petrol stations are also equipped with vapour recovery systems, used when receiving gasoline from tank-trucks (stage I).

EKO has progressed with the gradual introduction of vapour recovery systems when cars are fuelled with gasoline (stage II) at EKO’s fuel stations (company owned and renovated company controlled stations).

Environmental Protection Investments, G4-EN31

The Group’s approach is presented in detail in the ‘’ Sustainable Development & Corporate Responsibility Report 2016’’, Chapter ‘’Environment, Energy and Climate Change’’, section ‘’ Strategy ‘’.

Analytically the 2016 environmental investments are presented in G4- EN31.

Corporate Governance, G4-EN34 to G4-EN55

Refers to the rules, policies, practices and procedures implemented by the Group to determine functions and responsibilities (of management, committees, executives, etc) and the rules and procedures for decision-making and balancing stakeholders’ interests.

The Group’s approach is analytically presented in ‘ Sustainable Development & Corporate Responsibility Report 2016’, Chapter ‘’Corporate Governance and Regulatory Compliance’’.

Supply Security, G4-12

This refers to oil & gas availability and the potential impact this could have in the long term business model, strategy and operations of the Group.

The crude oil supplies are coordinated centrally by the Group and are covered by frame agreements (term-contracts) and with spot-contracts. The Group procures crude oil primarily from Russia , the Middle East and North Africa. Political instability in the Middle East and North Africa varies the last 50 years and depends on various factors, such as frequent change of governments, military regimes, social disruptions, sanctions from other states or terrorist actions. The political unrest in these areas are able to disrupt the smooth supply of the Group with crude oil. Also, in Russia, possible structural changes in the oil sector, tax and legislative changes, political unrest and problems of transporting crude from Russian terminals can affect crude supply.・・

The accessibility and flexibility of the Group’s refineries to process a wide variety of crude, are key competitive advantages, which are particularly important for both profitability and responsiveness at steep supply reductions of specific crude types, thus ensuring smooth supply of markets where the Group operates.

The Group has adjusted accordingly (see G4-12) the 2015 mixture of oil supplies.

Operational Continuity, G4-2

This refers to planning and establishing procedures which are intended to ensure that critical business functions will either continue to operate in case of serious incidents or disasters or will be recovered to an operational state within a reasonably short period, such as accident plans to ensure continuation of operations.

The activities and results of the Group may be affected by supply disruptions, a variety of external or internal factors (such as military actions in supplying countries), emergency downtime into production units, shutdowns for maintenance etc. The number of Group’s facilities and their geographic dispersion impart considerable flexibility in emergency situations. In addition, the Group has developed considerable expertise and experience of successfully handling logistics crises, such as the events in Libya, the embargo on Iran and shutdowns at different units. In all cases, contingency supply plans were prepared and immediately carried, thus minimizing any operational impact.

Supplier Assessment, G4-12, G4-EN32, G4-EN33, G4-LA14, G4-LA15, G4-HR4-6, G4-HR10, G4-HR11, G4-SO9, G4-SO10

The Group’s Procurement Division. has primary responsibility for coordinating the evaluation of suppliers (of materials and services) in accordance with the procedures of the Group and the Procurement Manual.

To develop our supply chain and incorporate our values and principle we seek added value, long term, mutually preferred relationships with partners who can help us to improve the total performance and sustainable development of the Group . In addition, labour practices of our suppliers affect not only our financial performance, but also our relationships with other social partners. For the above reasons, their evaluation is based on business criteria (safety issues, performance, compliance with contractual agreements etc) and also criteria for sustainable development. Ensuring that Group’s suppliers properly manage issues such as human rights, labour practices and the impact of their activities on society and environment is among the suppliers’ evaluation criteria.

The evaluation of suppliers (and new suppliers) is complimented by questionnaires which include relevant questions. No significant findings in 2016.

ln late 2015 the integration of a ‘’suppliers compliance clause’’was launched, into new contracts and purchase orders, regarding adaptation of the principles of the UN Global Compact (in the areas of human rights, labor, environment and anti-corruption).

Responsible Buying & Operational Support, G4-EC9, Code of Conduct link: http://www.helpe.gr/uploads/coc_2013_EN/index.html

The policy and procedures concerning the procurement of materials and services and the contracts are described in the Group Procurement Regulations and include:

• Roles and responsibilities of the buyers
• The suppliers cooperation framework (in line with the principles of the Code of Conduct)
• Cooperation with the Group’s Divisions involved in order to meet their needs

Interaction with suppliers and issues such as compliance with contractual terms are covered by the procurement rules, the Code of Conduct, the Project Execution Regulation and

the Internal Labor Regulations. Information provided to the suppliers is clear, transparent, respectful of competitiveness and of equal opportunities.

Adherence to the policies, processes and principles of the Group that affect the framework of cooperation with its suppliers is controlled by the Internal Audit of the Group.

Responsible procurement policy includes topics such as:

• Supporting the local market and local contractors, with the prerequisite that the criteria for selecting partners (such as safety, quality, competitiveness) are not affected. The purchases from local suppliers amount to 13% in HELPE & DIAXON (industrial companies) and 96% in commercial companies. Local suppliers are defined as those operating in neighboring municipalities with the industrial facilities of the Group, for the Group companies that have industrial production (ELPE & DIAXON). For commercial companies (EKO, EKO, BULGARIA, OKTA, HP CYPRUS, EKO SERBIA, JPK MONTENEGRO), local suppliers are defined as domestic suppliers.
• Transparency with suppliers: The Group’s Code of Conduct and Internal Working Regulations cover issues such as conflict of interest, gifts, employee-to-supplier relationships etc.
• Environment-friendly procurement: Suppliers are also assessed on criteria that are relevant to their environmental performance

Job Position Security, G4-LA1

Refers to the level of security of present and the estimation of future job positions within the Group taking into account the volatile economic situations.

The Group designs and implements strategies and adopt modern policies of Human Resources. In this way it seeks to be ・・an employer of choice and employees the competitive advantage’’, to achieve the business objectives and confirm the values & principles.

The Group places particular attention in shaping a dynamic policy framework, for the management of human resources, in order to best meet business objectives while meeting the goals and expectations of employees.

The Group’s approach is analytically presented in ‘ Sustainable Development & Corporate Responsibility Report 2016’, Chapter ‘’The Human Capital’’.

Equality & Fairness, G4-EC5

We, at the Group, strive to provide a safe and motivating work environment where our employees are treated with respect and offered equal opportunities for developing their skills and advancing their career. We understand that diversity and inclusion are factors that help us improve business results, enhance our reputation and work with talented people. The relationship with our employees is based on the principle of equal treatment. Both the inclusion and the career path of each employee within the Group, are based on their qualifications, performance and ambitions, without any discrimination.

The Group’s approach is analytically presented in ‘ Sustainable Development & Corporate Responsibility Report 2016’, Chapter ‘’The Human Capital’’, Sections ‘’ Remuneration and Benefits ‘’, ‘’ Work Environment ‘’ and ‘’ Equal Opportunities - Human Rights ‘’.

Occupational Health & Safety

Refers to utilising policies, practices and initiatives on behalf of the Group, to ensure the health, safety and welfare of employees.

HELLENIC PETROLEUM feels responsible for all people involved in or affected by the activities of the Group. This includes our employees, customers, partners, suppliers, trainees, subcontractors and the general public.

Health and safety performance is a true reflection of operational excellence. Occupational health and safety contributes to the satisfaction of our employees and our reputation.

The continuous care for the health and safety of employees and the concern for their families as well as the residents of neighbouring municipalities, is a prime consideration for the Group. For this policies, actions and programs have been adopted that contribute to this direction.

The Group’s approach is analytically presented in ‘ Sustainable Development & Corporate Responsibility Report 2016’. Chapter ‘’Human Capital’’, Section ‘’Occupational Health & Safety’’ describes policies and practices used to ensure occupational health and safety. In Section “Education & Training’’ the specific training in health & safety is presented as well as emergency drills held annually in the facilities of HELPE. In Section ‘’Health & Safety Indices’’, the systematically monitored indices LWIF, AIF, LWIS and PSER (process safety index) are presented as well as the targets set.

The Group’s occupational health & safety services aim to identify, prevent, and ultimately eliminate all work-related occupational diseases or accidents at work.

To further raise awareness of employees in accident prevention and safe plant operation, the implementation of the Rewarding Policy for Safety Performance is continued, among other practices. In this context, employees’ teams that achieve safety objectives, based on working hours without lost workday accident, are rewarded.

It is our aim to provide a safe, inspiring, and flexible work environment.

Asset Integrity & Process Safety

• To ensure the reliability of the equipment - as a key element in the safe operation of facilities - several procedures have instituted and implemented by the companies’ staff.

These are:

- Management of Change

- Safe Design Committees

- HAZOP studies

• Equipment inspection and checks are made periodically by the Equipment Inspection Departments of the facilities, in accordance with their respective programs.
• Also, inspections focused on process safety are carried out weekly, by management staff, in order to identify and correct unsafe behaviours of employees and contractors’ staff.
• The monthly CCPS bulletin (Beacon), concerning process safety, is distributed to all staff.
• Procedures, especially in safety issues, are in place for the prequalification of contractors and their safety performance assessment after completion of the work.
• Any unplanned or uncontrolled leakage of substances is measured as process safety event rate, in accordance with the definition and criteria of CONCAWE.

Work Environment

The Group’s approach on a safe and satisfying work environment is presented in detail in the ‘ Sustainable Development & Corporate Responsibility Report 2015’, Chapter ‘’Human Capital’’, Sections ‘’ Work Environment ‘’ and ‘’ Harmonization of family and professional life‘’.

Community Engagement & Partnerships, G4-EC6, G4-EC7, G4-EC9, G4-SO1, G4-SO2, G4-16

Refers to the policies and practices of the Group for the understanding of the impact on local communities and the creation of partnerships with stakeholders.

The Group’s approach, towards the local communities, is presented analytically in the ‘ Sustainable Development & Corporate Responsibility Report 2016’, Chapter ‘’Society’’.

http://sustainabilityreport2016.helpe.gr/userfiles/6ffd2fe2-e2bc-4741-906d-a48900e96f28/symmetoxes%20gr.pdf

Accident Impact

This refers to actions or practices for early detecting the impact of potential accidents (e.g. explosions) near communities, which is key to encounter them successfully.

Impact assessment is carried out in accordance with the requirements of European and Greek legislation Seveso, and reported to the authorities as a safety assessment. Based on this assessment, contingency plans for the protection of local residents and employees are implemented.

Techniques and measures, above and beyond those that are imposed by the regulations and legislation, are implemented at all Group’s facilities, in order to ensure for Occupational Health and Safety.

In this context, a study to analyze operational risks (HAZOP or Hazard & Operability Study) is a prerequisite for any new facility or for the extensive modifications of existing units. The operation and maintenance of the facilities rely on well-trained and experienced personnel that comply with safe operating procedures.

Particularly important for the prevention and addressing of accidents are:

1. Issuing of work permits for all maintenance works at production facilities

2. Safety training and successful exams are prerequisite for the personnel of contractors performing maintenance works.

3. Managing changes safely.

4. Scheduled training of employees, in theory and practice, in order to be able to respond at an emergency (power failure, loss of utilities, steam, air, etc.).

5. Reporting and investigating accidents. All accidents or near misses are reported and investigated in order to plan corrective actions to prevent their reoccurrence. Accidents that are monitored include personal injury - including first aid - explosions, spills, property damage, road accidents etc. All events are statistically analyzed in order to improve safety.

6. Planned drills for different types of accidents, often in collaboration with relevant bodies such as General Secretariat for Civil Protection, Fire Brigade, Police etc.

Health Screening

This refers to actions or practices for early detecting potential health issues problems in communities, such as proactive monitoring of residence around facilities, which is key to encounter them successfully.

In this context, the Group sponsors programs providing primary care services (in collaboration with bodies such as MDM and local authorities), particularly in communities neighbouring industrial facilities.

Furthermore, in collaboration with Diagnostic Centre, preventive medical examinations to students of the first Lyceum of Aspropyrgos, who participated in school volleyball and basketball games, took place. While at the Thriasio General Hospital of Elefsina, the Group covered expenses concerning reagents purchase for the Hematology Laboratory, floor standing refrigerated centrifuge blood collection devices, other consumables and fuel for ambulances.

 p. 55

In 2016, the Group’s turnover was €6,680m (2015: €7,303m) and the social product amounted to €1.4b (2015: €1.4b) distributed as follows:

• €194m to staff (salaries and social benefits)

• €56m directly to the Greek State through direct taxes and insurance contributions, as well as €1.1b of indirect taxes (excise duties, VAT) collected and delivered to the Greek State

• €3.2m to society through Corporate Social Responsibility initiatives

Employees’ remuneration and benefits:

Group payroll €176,987,904

Payroll taxes €35,841,152

Insurance contribution €40,390,070

Employees’ insurance plan €5,056,930

Employees’ pension plan €9,524,506

Staff commuting €3,625,097

Food provisions (on-site) €4,955,605

School allowance €295,326

Employees’ university studies allowance €169,921

Support to employees’ family members with special needs €60,092

Wedding/birth/death allowance €75,745

Creche allowance €457,799

Employees’ children camping €188,335

Awards to top students €262,610

Other benefits €498,190

Vouchers/gifts for Easter & Christmas €2,286,448

Company cars €1,444,777

  “Energy and Climate Change” p. 52

The potential risks and related financial-economic impacts form an integral part of the feasibility report for each project and investment from both the response side (mitigation of) the phenomenon of climate change and in terms of the adaptation strategy to climate change impacts (e.g. in case of natural variations, estimated as significant for facilities near the coastal front of Greece).

The Group’s participation in committees & actions with other companies in the sector, (see http://sustainabilityreport2016.helpe.gr/userfiles/6ffd2fe2-e2bc-4741-906d-a48900e96f28/symmetoxes%20gr.pdf) facilitates the monitoring of forthcoming regulatory changes.

Moreover, participation in research programs, mainly in those concerning the adaptation and resilience of critical energy infrastructures to the impacts of climate change (including related indicators and adjustment costs), is evaluated.

Financial impacts as well as other possible risks and opportunities related to climate change are included in any feasibility study for future investments. The company’s strategy with which to tackle climate change is energy saving, both in its production activity and administrative functions.

The obvious financial impacts which have a knock on effect on costs are associated with the projected deficit of the rights concerning greenhouse gas emissions (GHG), as the three refineries in Greece participate in the European Emissions GHG Trading Scheme. Any developments concerning the relevant Directive 2003/87/EC are monitored at European level for the sector (participation in FuelsEurope) while impacts are evaluated at country and company level.

For the period 2013-2020 (third phase), during which the rules of rights allocation are changing and only 50% of total allowances will be freely distributed while the remaining 50% is auctioned - because of the refining industry’s exposure to the significant risk of ‘’carbon leakage’’ - the refineries will receive 100% free allocation of allowances derived on the basis of the price benchmark resulting from the average of the 10% of the most efficient installations in the oil sector (in the years 2007-2008 ), which is 29.5 kg CO2/CWT. This leads the industry benchmark at European level to reductions of 23%, which is a higher percentage than the EU target of 21% applicable to other industry sectors.

HELLENIC PETROLEUM, for the period 2013-2020, has an additional burden as a result of the EU’s decision, deeming it subsequently necessary to implement a cross-sectoral correction factor (CSCF), which resulted in a significant increase in the rights deficit (about 30%) and as a result, associated operating costs. It is noted that the implementation of HELPE’s main strategy for increasing energy efficiency has already contributed to a reduction in the deficit, while it is estimated on average to amount to approximately 25% (with estimated annual compliance costs of €-14 m, depending on the price of emission allowances - EUAs).

Additionally, based on recent EU decisions regarding the implementation of a mechanism concerning the Market Stability Reserve and the expected structural restructuring of ETS, a significant increase in the rights price (€ton) is expected which will directly affect the cost of compliance.

Given that the technical options available for the effective reduction of CO2 emissions are limited at existing facilities - because refineries have a high degree of energy optimization by having implemented energy saving projects for many years - there will be costs involved in purchasing the required emission allowances from 2013.

It is also noted that because power generation activities are not allocated free allowances (since 2013), refineries incur additional increased costs concerning electricity purchases; as the cost of buying allowances for electricity is partially passed on to consumers.

Other potential risks include increased costs for fuel and raw materials, reduced demand for energy-intensive products as well as additional measures to control and reduce GHG, which are related to the sector at European level.

The evaluation of potential opportunities for natural gas & advanced biofuels is ongoing. Moreover, investments are being implemented in regards to improving energy efficiency and in the field of RES.

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 G4-EC1.

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 2016, “newly” insured employees: employer contribution 0.5%, employee contribution 0.5%-5%. Employees insured before 1993: employer contribution 2.5 or 6.5%, employee contribution 1.5%- 5%.

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 5%.

For employees insured after 1/1/1993 (new) the rate is from 0.5% to 5%.

ASPROFOS

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 2016 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 €235, newcomer’s salary €500.

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: 2.70%

ΕΚΟ: 2.86%

ASPROFOS: 0%

DIAXON: 33.33%

ΕΚΟ Bulgaria: 50%

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. 56-65

A 2nd survey on Materiality Analysis & Stakeholders engagement was conducted in 2015 (see  Chapter “Our Stakeholders”, Section ‘’Materiality Analysis’’) 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:

• Donation of bitumen (€30,000) for road construction projects in the Municipality of Elefsina

• Anti-mosquito program at Ampelokipi - Menemeni Municipality (€5,000)

• Fuel donation for surveillance and fire protection needs in Thriasso (€7,000)

• Reconstruction of the gym in the Delta Municipality (€63,000)

• Donation of 3 pre-constructed facilities for sports facilities in the Elefsina Municipality

• Folding children’s beds donated to a kindergarten in the Municipality of Aspropyrgos

• Construction of a playground in the Municipality of Mandra (€20,000)

• Construction of a playground in the Municipality of Evosmos-Kordelio (€65,000)

• Cleaning up the Thermaikos Gulf (€9,000)

• Maintenance of the environmental station in the Municipality of Aspropyrgos (€11,164)

• Respiratory machinery donation for the Burns Centre at the Elefsina-Thriasio General Hospital (€31,000)

• Equipment provided to the Hellenic Rescue Team, Elefsina (€3,200)

Βulgaria:

• Construction of a children’s playground in Yambol (€1,505)

Μontenegro:

• Donation of children’s equipment for the Aikido martial art academy in Tivat (€1,000)

• Medical device donation for the early diagnosis of tuberculosis to the Brezovik hospital (€20,190)

• Medical equipment donation to the Montenegro Medical Centre (€44,000)

• Renovation of the Pamark Foundation’s facilities for Children with Disabilities (€1,000)

• Fuel donation for the vehicles and machinery that helped restore the flooded communities of Andrijevica, Petnjica and Berane (€9,000)

FYROM:

• Renovation of the hospitality centre for children with cerebral palsy of the Centre community (€15,000)

• Fuel for vehicles and machinery that helped restore the flooded areas (€1,594)

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  Chapter “Society”.

1. Economic development in areas of high poverty:

See indicator G4-EC7 for relevant projects.

In investing in Montenegro, JPK 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” for fuel donations, food vouchers and prepaid fuel cards.

4. Enhancing skills and knowledge amongst a professional community or in a geographical region:

A modern skills development program was implemented in Thessaloniki in collaboration with the Aristotle University, Thessaloniki. The program offered young people the opportunity to learn and gain valuable knowledge in areas such as Digital Marketing, Innovation and Digital Entrepreneurship as well as Social Entrepreneurship. The need for young people to respond to critical questions, through access to modern ways of thinking and information, enables them to acquire the right skills, improve their curriculum vitae and ultimately gain work in a highly competitive working environment. The program, which is provided free of charge, provides a certificate of attendance.

At HP Cyprus, students are trained at the headquarters or the storage facilities (terminal).

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”. JPK relocated its Headquarters from Kotor to Podgorica which obviously impacted the Kotor municipality, as it lost its main employer.

At OKTA:

• Local construction companies and suppliers were hired for the complete reconstruction of the energy efficient administrative building.

• 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 2nd survey on Materiality Analysis & Stakeholders engagement was conducted in 2015 (see Chapter “Our Stakeholders”, Section ‘’Materiality Analysis’’) 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. 62

Procurement from locally-based suppliers at significant locations of operation is 13% for HELPE and DIAXON (industrial facilities) and 97% for the Group’s marketing companies (EKO, EKO BULGARIA, ΟΚΤΑ, HP CYPRUS, EKO SERBIA, JUGOPETROL), presented in detail in the  Chapter “Society”.

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, 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.

¹ It includes data for Megara & Pachi facilities

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’ significantly reduces friction, achieving up to 4% higher motor efficiency. 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, with average fuel savings of 2% (measurements have recorded savings of up to 3.84%) depending on the engine type and / or capacity. Additionally, the BP’s gasoline Ultimate 95 provides up to 16 extra kilometres and on average 12 extra 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. Gasoline Ultimate 100 with active technology, launched in 2017, achieves up to 37 extra kilometres (on average 18 kilometers). 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.

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.

See also indicator G4-ΕΝ11.

There are no affected habitats. (See also ΕΝ11, ΕΝ13).

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

The Company, aiming at quantifying its environmental impact resulting from the transportation of its employees, studies its employees’ commuting approaches at the administration buildings in Maroussi, Aspropyrgos, Elefsina and Thessaloniki (last study was in 2015).

The study results show that approximately 33% of these employees do not use private cars but company buses and public transportation (total emissions from road transportation are 2,271 t CO₂-eq).

Based on the Euro 6 specifications, other pollutants’ emissions because of the aforementioned transportation (except for public transportation) are:

Furthermore, the Group sponsors the “Save more fuels” initiative and contributed the publication of a catalogue which contains instructions for eco-driving (http://www.savemorethanfuel.eu/).

The most significant impact from the transportation of products derives from shipping (exports). It is calculated that 3,325 TJ are consumed and 260,718 tn CO₂ are emitted due to exports.

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 2016.

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 2016.

  "Human Capital”, p. 26-28

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

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.

The area adjacent to the Group's industrial facilities is considered as an important area of ​​its activity.

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

In 2016, 44 workers (20 HELPE + 9 EKO + 5 OKTA + 1 JPK + 3 EKO Serbia + 6 EKO Bulgaria) and 2 employees (DIAXON) received parental leave.

16 employees returned from parental leave which expired in 2016, while a further 16 employees returned whose parental leave expired in 2015.

Average return to work rate for the Group, 2016 = 80%

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).

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.

 “Occupational Health and Safety” p. 29

 Table “Number of Incidents - Facilities Performance” p. 31-33

Injuries breakdown, by gender, are recorded at all facilities. The safety indicators, by gender, for the BEA, BEE & BEΘ 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:

*IR = AIF x 10-⁶

**concern only the days of absence due to accident

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. The 2016 accidents’ classification is performed in accordance with the definitions provided by CONCAWE (LWI, RWI, MTC, PSE).

According to CONCAWE, LWIs in 2016 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 G4-14

H & S 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 H & S improvements in their workplace.
• HELPE’s Internal Regulation, Articles 8, 24, 40
• EKO’s Internal Regulation, Articles 9, 12, 23
• Group’s Code of Conduct, chapter 7.1

Outsourced Protection & Prevention Services (ΕXYPP): Where appropriate (e.g. during periods of general maintenance), anadditional 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.

H&S 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 H & S
• Submission of complaints
• Right to refuse performing dangerous work

 “Education & Training” p. 33-34

      “Health & Safety Training” p. 35

      “Environmental Training” p. 34

For statistics on expenditure by type of training, education by gender and number of trainees, see  "Human Capital" Chapter, "Education and Development" Section (p. 34-35, Tables - the distribution of trainees and type of education).

The Group’s total expenditure for the above issues in 2016 amounted to €85,279 while the total number of training hours was 91,046.

Indicatively, 32,584 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 “Human Capital”, Section “Training and Education”.

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. 55 (Executive/non-executive board members of the parent company: 4/9 in 2016).

The following table presents the breakdown of the 72 members of the Group’s BoDs included in this Report

% of women in senior management: Group average Ομίλου18,35%, (HELPE 22.22%, ΕΚΟ 22.09%, ASPROFOS 1.75%, JUGOPETROL 33.33%, EKO Serbia 0%, HP Cyprus 0%, EKO Bulgaria 25%, OKTA 16.67%, DIAXON 0%).

“Human Capital” p. 26-35

In 2016, the Group employed 98 people with disabilities (permanent employees).

Employees breakdown per gender, age group, 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.

All new suppliers are evaluated during the tender process and are committed, in case of undertaking a project, to comply with the Group’s principles and policies regarding working practices. A revised procedure for the registration of new suppliers into the database that will include CSR and SD relevant criteria, is currently being developed.

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

No significant findings were found in 2016.

Answers are provided through the program.

 “Employee Suggestion Box” p. 17

There were 4 complaints in 2016 (2 regarding the then cleaning company and a further two regarding certain catering issues).

The Code of Conduct (sections 7.2 & 7.3) and the Internal Labour Regulations (article 2.3) provide guidance on the protection of human rights throughout the supply chain.

Both documents make clear references to the respect of human rights. Furthermore, all employees have been trained on both documents which are accessible to all employees through the corporate network.

With regards to the new Procurement Manual, which was completed at the end of 2016 and has been in operation since January 1, 2017, paragraphs have been added which refer to the performance of our suppliers in terms of Sustainable Development and Corporate Social Responsibility issues throughout our cooperation.

Also, 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.
    

100% of employees were trained in HR issues through the company’s Internal Labour Regulation (articles 22, 23, 26, 38 & 39) and the Code of Conduct (section 7), which all employees can access via the intranet.

The following actions are indirect ways of human rights training:

• Employee participation in awareness workshops on CSR, Sustainability Reporting, GRI certification

• Educational CSR Seminars (Edge & Edge-Commercial in Athens and Thessaloniki) for groups of employees

• The Corporate Responsibility Report Working Group (see G4-49)

No specific training was conducted in 2016.

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

No relevant reports in 2016.

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.

In 2016 there were no relevant reports.

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.

There are no armed guards on the Group’s premises.

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.

There were no reviews or assessments as no reported or related problem has arisen.

All new suppliers are evaluated during the tender process and are committed to comply with the Group’s principles and policies as regards respect for human rights. A revised process of incorporating new suppliers into the registry, which will include both CSR and Sustainable Development criteria, is being developed.

Suppliers commit to uphold the Group's principles and values concerning the respect of human rights at the time of signing the contract/purchase order for materials or services, which includes a supplier "compliance clause" with the principles of the UN Global Compact.

No significant findings were found in 2016.

The HR Division monitors phenomena of human rights violation and acts accordingly.

No grievances in 2016.

In 2013, opinion surveys were conducted concerning materiality analysis and stakeholder engagement.

In 2014, a Qualitative & Quantitative Survey (Company Reputation Monitor), in local communities, took place.

In 2015, the materiality analysis and stakeholder engagement surveys were repeated.

These surveys, regular communication and consultation are used to determine the investment in infrastructure and other actions that benefit local communities as well as understand the significant indirect effects locally.

Assessing the findings will lead to planning activities for the future. It has been recorded that local communities anticipate actions with a focus on supporting the unemployed, health services, support of the elderly and vulnerable groups in general.

 “Society” p. 56-65 actions taken in the framework of surveys, consultation and communication with local communities. Analytical presentation, by country (100% operations).

Furthermore, during the design phase of a new investment, a provision is made for direct and indirect impacts.

Moreover, the operational planning of any investment pays attention to the study of direct and indirect impacts on the local community.

By its very nature, our work has an impact on the local community and society as a whole. Community engagement affects our social license to operate. While our impact on our surroundings immediately affects our employees and local suppliers, our community engagement improves jobs and education in our environment – contributing to society as well. This requires a constant focus on everything we do to minimise our negative impact and create value for local communities.

Significant impacts may occur in the stages: beginning of a new activity, its operation or exit. Based on the Group’s strategy, only the second stage (operation) is considered as significant, for the next 5 years.

The operation of the facilities may have environmental impacts (analytically presented in  Chapter “Environment, Energy & Climate change”: Emissions, climate change, pollutants, education, investments, biodiversity protection), impacts on health and safety (Chapter “Human Capital”) or local communities (Chapter “Society”).

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 2016.

In 2016, 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.

 “Code of Conduct –Ethics and Transparency” p. 25

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 2016 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.

Zero contribution.

These contributions are prohibited by the Group’s Code of Conduct.

HP Cyprus

The Commission for the Protection of Competition (EPC), in an investigation of its own motion, is reviewing possible breaches committed by oil companies operating in Cyprus, including HP Cyprus. In this respect, the CPC has drawn up a Statement of Objections against the Companies dated 17.12.2014.

The Statement of Objections concerns possible distortions in the petroleum sector (pricing changes from the supplier to the consumer) during the period from 1.10.2004 to 22.12.2006, in the following:

(a) horizontal partnerships (i.e. relationship between competing companies), and

(b) vertical agreements (i.e. relationship between each company and its petrol stations).

In regards to the Statement of Objections, HP Cyprus submitted a petition and made oral representations to the Commission in the last quarter of 2015. The Commission has not issued its decision which is subject to judicial appeal.

ΕΚΟ Bulgaria

The Commission for the Protection of Competition (CPC), in an investigation of its own, is examining possible infringements committed by oil companies operating in Bulgaria, including EKO Bulgaria. In this respect, the CPC has drawn up a Statement of Objections against the Companies dated 10.10.2016.

The Statement of Objections concerns possible distortions in the petroleum sector (price formation from supplier to consumer) between August 2004 and October 2016 in horizontal partnerships (i.e. relationship between competing companies).

EKO Bulgaria has submitted a petition. The procedure is in progress and the Commission has not issued its decision which is subject to a judicial appeal.

No irrevocable fines in 2016.

All new suppliers (100%) are evaluated during the tender process and are committed in case of undertaking a project to complying with the Group’s policies and principles regarding the impact on society. A revised process procedure of for the registration of incorporating new suppliers into the registry database, which that will include both CSR and SD relevant criteria, is currently being developed.

Suppliers commit to uphold the Group's policies and values concerning impact on society at the time of signing the contract/purchase order for materials or services, which includes a supplier "compliance clause" with the principles of the UN Global Compact.

No significant findings were found in 2016.

 “24 Hour Service” p. 41

Through the suggestions box, answers to questions - complaints raised by employees are provided.

EKO Bulgaria

A small number of customer complaints (59) were reported through the formal grievance mechanisms for the reporting period which were all addressed and resolved during the period of reference. No complaints about the impact on society during the reporting period.

ΟΚΤΑ

In 2016, six grievances regarding impacts on society were filed and resolved.

HP Cyprus/EKO Serbia/JUGOPETROL

No grievances have been reported during 2016.

  “Labelling of Products” p. 43

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/ JUGOPETROL

None. Non non-compliance incidents.

EKO Bulgaria

Two incidents 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.

OKTA

At the request of the Commission for the Protection of Competition, on OKTA’s fuel pricing principles, the formal response was given in March 2016. No additional information was provided by the Commission for a possible non-compliance with the competition law regulations which could lead to a warning, fine or penalty.

 “Labelling of products” p. 43

Copies of Product Material Safety Data Sheet are provided with packaged products such as lubricants: (Ch. “Business Partners”, Section “Customers –Products”, the Table “Percentage of sales by 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 Sustainable Development & Corporate Social Responsibility 2016 (ChapteR "Business Partners", Section "Quality of Products and Services").

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 labeling that led to a warning.

“24 hour service” p. 41

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 78.9% for HPC and 67.2% 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:

- HP Cyprus maintains its leading position in the Cyprus market

- The brand has improved compared to 2015

- Top of Mind indicator: +2%

EKO Bulgaria

Mystery Motorist Research: Customer satisfaction 94.9% (courtesy, service and appearance)

The main results of the 4th Brand Vitality Tracking survey conducted in 2016 were:

- "Top of mind": 7 point increase

- "Main choice": 4 point increase

- "Total awareness" remained at the same level as in 2015

JUGOPETROL

Mystery Motorist Research: Customer satisfaction 93% (courtesy, service and appearance).

The main results of the Brand Vitality Tracking were:

- Total awareness: 97%

OKTA

The results of the RASS annual survey (IMA) recorded a constant rate across all indicators (“Views & Attitudes”, “Awareness & Usage”, “Purchase Criteria & Brand Evaluation” and “Habits on car usage & Fuel purchases”).

The main results of the survey were:

- Brand Awareness Index: Increased by 4%

- Basic preferences have been highlighted: Good service, quality, reliability and implementation of the Guarantee Program

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 and consistent standards concerning customer service, courtesy and appearance (customer satisfaction 94.72% (courtesy, service and appearance).

RASS opinion survey results (sample from over 1,200 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 400,000 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.

No such cases.

No incidents of non compliance.

Full compliance with relevant regulations/ codes (eg. unfair competition and consumer protection).

No complaints.

Records of personal customer data fully comply with relevant legislation and are fully harmonized with EU law.

No complaints.

Personal customer data records fully comply with the relevant legislation and are fully harmonized with EU law.

Not applicable as hydrocarbons exploration and production activity is beyond the scope of this Report.

• RES investment amounting to €90k (100% capital expenditure)

• €90k investment in net metering

• Investments in research on first generation and advanced biofuels: €60k

In 2016, electricity produced by wind farms amounted to 14.180 MWh.

Electricity produced by P/V stations amounted to 1.905 MWh.

 “Ecosystems and Biodiversity” p. 51

The Group’s industrial facilities are not located in proximity to such areas. The Group undertakes voluntary initiatives to protect biodiversity in consultation with local communities, as well as within the context of its annual CSR activities program. None of the Group’s refineries are located in proximity to protected areas (NATURA, RAMSAR).

All facilities are located in established industrial areas.

Not applicable as hydrocarbons exploration and production activity is beyond the scope of this Report.

Gaseous fuel (hydrocarbons) which flared at the refineries, based on verified ETS reports:

Aspropyrgos refinery: 2.699.638 Νm³

Elefsina refinery: 16.010.361 Νm³

Thessaloniki refinery: 4.297.380 Νm³

Based on the GRI’s definition for vented hydrocarbons (i.e. intentional controlled release of uncombusted gases) there was no such release in 2016.

Not applicable as hydrocarbons exploration and production activity is beyond the scope of this Report.

See Indicator G4-EN27

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% w/w (2016)

Aviation fuel <<0.30% w/w (2016)

Gas oil (heating) <0.10% w/w (2016)

No Group’s operations are in or are adjacent to indigenous peoples’ communities.

Complaints about the release of odours at the Thessaloniki refinery.

The company invested in equipment, which was installed at Aristotle University of Thessaloniki to measure and investigate the origin of these odours.

None. There are also no such plans.

None.

 Table “Number of Incidents - Facilities Performance” p. 31-33

Ever since 2015, the Holistic Safety System has been implemented in the three refineries, under which the review of safety procedures, leadership seminars for Division or Department Heads, engineers, coordinators and foremen and initiatives/ campaigns on good practices, are underway.

In addition, all facilities are inspected by third-party H&S auditors.

PSEs in 2016 mainly cover three major categories: leakages due to equipment/pipeline corrosion, process violations and unit malfunctions. The corrective actions taken to deal with them and avoid their recurrence were the improved personnel safety training , the reinforced equipment inspections, as well as the introduction of a new procedure named "Procedure for the reporting and investigating safety and environmental incidents", ΕSO Α3.0039.00, according to which the investigation of safety incidents is carried out more quickly and in depth using "why-tree" methodology.

 “Biofuels” p. 54

HELPE does not choose a biofuels supplier. It is required by national legislation to receive specific quantities per supplier per month as defined by the Joint Ministerial Decision 176374/18.05.2015 (see also State Gazette, 2nd Issue, no. 911, 19.05.15) which is issued each year - subject to technical specifications. As such, one of the distribution criteria regarding supplies from various suppliers is sustainability.

On the basis of the JMD, in 2016, HELPE was supplied by third parties with 116,626 m³ of biodiesel, which corresponds to 7.1% in vol. terms to diesel.

HELPE does not produce biofuels but sources them from third party suppliers.