Report - COP Prototype

2022 Communication on Progress

HELLENiQ ENERGY Holdings S.A.

Published date

May 31, 2022

No. of questions

Supplemental files

Assurance Statement_ELPE2021_GRI-ST_En.pdf HSESD Policy-signed by ANS.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	11
Male (%)	81.8
Female (%)	18.2
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	0
Above 50 years old (%)	100
From minority or vulnerable groups (%)	0
Executive (%)	18.2
Independent (%)	36.3

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Assurance statement by

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

HELLENIC PETROLEUM Group's Sustainability Report will be published soon on the webpage https://sustainabilityreport2021.helpe.gr/

Human Rights
Materiality / Saliency
1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?
Freedom of association and the effective recognition of the right to collective bargaining
Child labour
Forced labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)
Freedom of expression
Access to culture
Access to water and sanitation
Digital security / privacy
Rights of women and/or girls
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Other
Response
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
The Group promotes Health, Safety and Wellness in the workplace by: a) Strengthening risk prevention and mitigation measures. In particular, due to the COVID-19 pandemic, for all our activities and all relevant risks were addressed through collective and individual actions, safeguarding the health of our employees – our top priority – without interrupting our business continuity. b) Being committed to providing the resources needed to meet the Health and Safety goals and to continually improving the Health and Safety Management System. c) Ensuring consultation with all stakeholders and meeting the needs of society. These three principles are clearly stated in the company’s Policy and constitute a commitment of the company realized through strong Leadership (leading by example). “Risk Assessment”, which lies at the core of the Health and Safety Management System, is supported and reinforced through procedures, inspections and safety training. The Group upholds that ‘Safety concerns everyone’; it urges employees to report and investigate incidents, near misses and unsafe situations, and rewards the employees’ successful intervention on safety issues. All Group facilities set objectives in order to review and improve their performance on Health and Safety issues, with reporting and appraisal carried out periodically. Objectives on specific safety indicators are set and monitored based on, among others, the proposals by the scientific division of the European Petroleum Refiners Association (CONCAWE). At the same time, we extend the application of our Holistic Safety Management System to the rest of our activities, apart from Refining, in order to consolidate our safety culture and improve our performance.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
2020
Forced labour
2017
Child labour
Non-discrimination in respect of employment and occupation
2012
Occupational safety and health
2019
Working conditions (wages, working hours)

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
HELPE Group (in cooperation with the employees union, if required) monitor such phenomena and act accordingly. A compliance clause of our suppliers with the principles of the UN Global Compact has been incorporated in all new contracts and purchase orders for materials or services.
Child labour
The Group’s recruitment policy states that no employees under the age of 18 can be employed. HELPE Group - in cooperation with the employees union, if required - monitors such phenomena and act accordingly. A compliance clause of our suppliers with the principles of the UN Global Compact has been incorporated in all new contracts and purchase orders for materials or services.
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	73.1

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	72.7

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	21.7
Non-executive board	100

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	18.24

Optional comment

It concerns the Group's employees (excluding people in managerial position).

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0.00000377

Optional comment

We measure this indicator as AIF based on CONCAWE's reporting methodology (in million hours) for our industry and we use it for benchmarking purposes. Within our Sustainability Report, this indicator (AIF) is presented for every subsidiary company separately.

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	0.00154

Optional comment

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
HELPE Group monitors such phenomena and acts accordingly in cooperation with the employees’ unions. 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 or services.
Forced labour
HELPE Group monitors such phenomena and acts accordingly in cooperation with the employees’ unions. 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 or services.
Child labour
HELPE Group monitors such phenomena and acts accordingly in cooperation with the employees’ unions. 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 or services.
Non-discrimination in respect of employment and occupation
HELPE Group monitors such phenomena and acts accordingly in cooperation with the employees’ unions. 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 or services.
Occupational safety and health
Working conditions (wages, working hours)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Percentage of total workforce represented in formal joint management– worker health and safety committees that help monitor and advise on occupational health and safety programs: All staff (100%) are represented. The committees participate in regular meetings with management and make recommendations on improvements in the workplace with regards to Health and Safety. Health and Safety issues, agreed in collective agreements with employees’ unions, refer to the Internal Labour Regulations, which is accessible on the corporate intranet. An agreement is signed among the Group’s companies and the relevant employee unions concerning safety personnel in the case of a strike. Internal Protection and Prevention Service (ESYPP) operates under PD95/1999; aiming at employees’ occupational health monitoring and taking protective measures to avoid accidents. Occupational Health and Safety Committee in each facility, consisting of elected employee representatives, in accordance with Law 3850/2010, representing all employees. Any employee (100%) may participate in the elections for EYAE at the facility where he/she is working. The committees participate in periodic meetings with the facility management making suggestions for Health and Safety improvements in their workplace. Minutes of the meetings are published, including the progress of implementation of the agreed ones. The dates of the meetings are included in the annual report of the ESYPP to the Ministry of Labor, Social Security and Social Solidarity. Relevant reports on Health and Safety at work are: - HELPE’s Internal Regulation (Articles 8, 24, 40) - EKO’s Internal Regulation (Articles 9, 12, 23) and - Group’s Code of Conduct (chapter 7.1). Outsourced Protection & Prevention Services (ΕXYPP): Where appropriate (e.g. during periods of general maintenance), an additional properly qualified external partner is mobilised in order to monitor occupational H & S activities. Relevant indicators are monitored and the relevant labour legislation is applied. Health and Safety issues are covered 100% by local agreements or regulations or official procedures, the Health and Safety employees’ commission, with the participation of a Safety Technician and Occupational Physician, at periodic H & S meetings with colleagues at other Group’s facilities, also as part of ESYPP activities. There are also formal agreements in place covering issues such as the: - Provision and use of personal protection equipment - Participation of employee representatives in inspections - Education and information on Health & Safety - Submission of complaints - Right to refuse performing dangerous work

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2019
Water
2019
Oceans
2019
Forests / Biodiversity / Land Use
2019
Air Pollution
2019
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2019
Energy & Resource Use
2019

Optional comment

Our Health, Safety, Environment and Sustainability Policy encompasses our commitment 1) to reduce our environmental footprint by taking measures for pollution prevention, emission reduction, energy use and natural resource efficiency 2) to address climate change related risks by implementing mitigation and adaptation plans (see attached HSES Policy). * Our geographical location is not adjacent to an ocean. However we are surrounded by bodies of water (seas). We take all necessary actions during our operations to protect sea ecosystems.

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Our HSES Policy is publicly available on our company's website (https://www.helpe.gr/en/health-and-safety/). The Policy was approved / signed by the company's CEO, ie. at the most senior level of the company. The Policy's stipulated commitments are communicated to all stakeholders and apply to all company operations, employees and contractors.

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

For Climate Action in 2021, the company constructed the country's largest renewable energy investment, a 204 MW Photovoltaic park - the largest in Europe, which will produce 350 GWh/yr and ensure zero emission clean energy for 75,000 households (a yearly benefit corresponding to 320,000 tons of avoided CO2 emissions). Other smaller investments in renewable energy in 2021 consisted of a 38 MW wind farm in Evia and 2 PV parks with 16 MW total capacity in Biotia. Regarding forests in 2021, the State requested CSR aid from the company to assist in the forest restoration of the Varibobi National Park in Attica and of Schinos, Mt. Gerania within a protected NATURA 2000 area (cover in an area of 3,197,000 m2 and 17,214,000m2 respectively). The company executed a series of anticorrosion interventions and protection works to prevent the risk of flooding and soil erosion in order to allow the natural regeneration of the forests. The projects were undertaken in cooperation with the State's Reforestation Departments of Attica and Corinth as well as the Ministry of the Environment & Energy. Regarding Air Quality, a dedusting filter (air emission abatement technology) was installed at the Aspropyrgos refinery in 2021. Regarding Solid Waste, an integrated municipal solid waste management system was implemented in Elefsina Refinery in 2021 which includes all waste streams that are separated at the souce. All employees and contractors were trained inorder to actively participate in the Waste Management System. Regarding Energy Efficiency, a significantly demanding Energy Management System was implemented and certified according to ISO 50001 at all three refineries in 2021. Its implementation will allow the monitoring of energy efficiency, facilitate the drafting of energy efficiency plans according to Life Cycle Cost Analysis methodology, reduce operation and production costs by implementing these plans, reduce Scope 1 & 2 emissions and improve energy/environmental footprint.

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

For Energy efficiency & Resource Use we currently follow an Energy Management System according to ISO 50001 and continuously increase the utilization rate of materials and natural resources throughout their life cycle by recycling and reusing them in our production process, however specific targets have not been set. For water and air quality the company follows national and EU regulations which are clearly stipulated and adhered to as per the EIA permit of each facility.

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	Targets are set for 50% reduction in CO2 by 2030 and net zero by 2050. Scope 1 emissions are certified externally by an accredited auditor. Reduction of CO2 emissions are on track.
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	The target for solid waste is to reduce the amount of municipal waste ending up in landfills to 15% or less of the total amount of municipal waste generated BY 2030 (by weight). Waste management is tracked and monitored internally and reported to the State on an annual basis.
Oceans

Optional comment

Since 2019, 2 educational suitcases, named “EARTH 2030”, “travel” to primary and secondary schools in Greek islands, in collaboration with the non-profit civil company “Agoni Grammi Gonimi”.This interactive game created by specialized teachers with appropriate educational material and aims to inform and raise awareness of the 17 Sustainable Development Goals.

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

3766691.12

Scope 2 Emissions

Full

None

Emissions (tCO2e)

438516.56

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

567628

Optional comment

Above Scope 1 emissions includes all direct GHG emissions from our refineries and subsidiaries. Verified CO2 emissions for the 3 refineries participating in the EU ETS amounts to 3,737,477.12 t CO2e. Scope 2 emissions are calculated in Greece from electricity provider invoices and their respective emission factors (market based) and for the subsidiaries from electricity invoices and country emission factors derived from the 2022 report EIB Project Carbon Footprint Methodologies.

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

0.01

Unknown

Not applicable (Please provide additional information)

Optional comment

Includes only R&D programs in cooperation with universities and research institutes.

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Optional comment

We have undertaken projects for forest reforestation and flooding containment, i.e. in 2021, the company executed a series of anticorrosion interventions and protection works to prevent the risk of flooding and soil erosion in order to allow the natural regeneration of the forests in the areas of Varibobi National Park in Attica and of Schinos, Mt. Gerania within a protected NATURA 2000 area (cover in an area of 3,197,000 m2 and 17,214,000m2 respectively). In addition, we are currently studying the effects of various climate change scenarios on our company's infrastructure in collaboration in the framework of a funded PhD study (University of Patras and NCSR Demokritos).

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

1.62

Unknown

Optional comment

Renewable Energy Consumption amounted to 917,738 GJ whereas the total energy consumption (including fossil fuels) amounted to 56,615,524.53 GJ. Instead, renewable energy consumption as a percentage of total electricity consumption (4,694,053.31 GJ) amounts to 19,6% (see GRI 302-1).

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

0.06

As per the EU Commission Delegated Regulation 2021/2178, the EU Taxonomy eligible activities are electricity generation using solar PV technology (activity number 4.1) and electricity generation from wind power (activity number 4.3). Please refer to the calculation methodology specified in the Annual Financial Report for Fiscal Year 2021 (https://www.helpe.gr/userfiles/8ea1f0cb-9e62-48e4-b947-a27b00fb14bb/BoD%20Report%20EN%202021.pdf). The RES investments mentioned above will be operational in 2022.

Unknown

Not applicable (Please provide additional information)

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	13581.99
Groundwater:	300.58
Surface water:	76.9
Rainwater:	0
Wastewater:	0
Percentage of water withdrawn in regions with high or extremely high water stress (%)	0

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	6441.07
Groundwater:	0
Surface water:	0
Rainwater:	0
Wastewater:	0
Percentage of water consumed in regions with high or extremely high water stress (%)	0

Optional comment

Total water withdrawal from utility services= 11,470.39 ML and from sea water =1,734.11 ML. Total water consumption is according to the definition stipulated in GRI 303-5. None of our facilities or operations are located in regions with high or extremely high water stress.

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

Unknown

Not applicable (Please provide additional information)

We do not operate in regions with high or extremely high water stress.

Sector-specific: Forest, biodiversity, and land use

14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

	Number	Unknown	Not applicable (Please provide additional information)
Sites
None of the Group's facilities operate in or adjacent to protected areas (NATURA, RAMSAR) or key biodiversity areas. All company facilities are located in legally established areas / zones of industrial activity.
Hectares
None of the Group's facilities operate in or adjacent to protected areas (NATURA, RAMSAR) or key biodiversity areas. All company facilities are located in legally established areas / zones of industrial activity.

15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

Conversion of natural resources (hectares)

Unknown

Not applicable (Please provide additional information)

No area of natural ecosystems was converted during the reporting period.

16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

	No	No, but we plan to in the next 2 years	Yes
Forest ecosystem restoration
2041.1 ha
Other ecosystem restoration
Reforestation
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Other (please specify in text box)

Sector-specific: Air pollution

17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

	Emissions (tCO2e)	Unknown	Not applicable (Please provide additional information)
NOx	2696.57
SOx	3999.06
Volatile Organic Compounds (VOC)	1506.36
Hazardous air pollutants (HAP)	22.77
Particulate matter (PM10)	209.39
Persistent organic pollutants (POP)	0
Other (please specify in text box)

Optional comment

As per GRI 305-7 (2016) disclosure.

Sector-specific: Waste

18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

Waste Generated (t)

28495.88

Unknown

Not applicable (Please provide additional information)

Optional comment

As per GRI 306-3 (2020) disclosure.

19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

Hazardous Waste Ratio (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

Total Solid waste = 28495.88 tn, Hazardous waste = 12,920.74 tn

20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

Single-use plastics (tonnes)

Unknown

Not applicable (Please provide additional information)

The company does not have single use plastics along its value chain.

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

As an energy producer and consumer at the same time, the impact of our carbon footprint on climate change is one of the most significant challenges that directly affects our business activities. Our energy transformation has become first priority and is clearly defined in our business plan called "Vision 2025", which sets ambitious goals to reduce our carbon footprint by 50% by 2030 and reach net zero emissions by 2050. To this effect, we already have a RES portfolio of over 1.3 GW projects in various stages of development. Specifically in 2021, our company's commitment to our energy transition is evident through the construction of our country's largest (204 MW) photovoltaic park in Kozani, which will be fully operational in 2022. Also significant toward energy saving and efficiency in 2021 was the implementation of a rigourous Energy Management System in accordance to ISO 50001 at our three refineries. As already mentioned, its implementation will allow the monitoring of energy efficiency, facilitate the drafting of energy efficiency plans according to Life Cycle Cost Analysis methodology, reduce operation and production costs by implementing these plans, reduce Scope 1 & 2 emissions and improve the overall energy/environmental footprint. During the reporting period, in addition to the management of our industrial solid waste which is reused, recycled and recovered for the most part, our integrated municipal solid waste management plan - already installed at our Headquarters and Aspropyrgos facility - was extended to the Elefsina facility, where as many wastes streams as possible are recycled including metal, plastic, batteries, paper, food residues and common waste, which has further improved our environmental footprint.

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2012

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Prevention

3. Who receives training on anti-corruption and integrity?

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
No incidents
Confirmed during the current year, and related to this year	0
No incidents

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

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). 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.

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

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. Audits held in 2021 in administrative units, refinery installations as well as subsidiary companies based abroad did not reveal any abusive implementation of the Control Systems, Policies and Procedures. In 2021, the Internal Audit Unit examined the following issues: -Implementation of the Group Investment Manual -Implementation of the Group Procurement Manual -Health, Safety and Environment concerning the refineries -Refineries’ and Marketing Companies’ supply chain