Report - COP Prototype

2022 Communication on Progress

ALPHA TRUST HOLDINGS

Published date

July 30, 2022

No. of questions

Supplemental files

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

Optional comment

Founded in 1987, ALPHA TRUST is the oldest and largest independent asset manager of private and institutional investors, domiciled in Greece. ALPHA TRUST is devoted to the achievement of the objectives and aspirations of our investors while delivering value to our shareholders and society at large. We act consistently in the best interests of investors and society as is our duty. We aim to deliver long-term value and have a positive impact for the people and the planet. It is our belief that material Environmental, Social and Governance (ESG) factors contribute to the long-term investment performance from both the opportunity and risk mitigation. Therefore, in addition to and alongside traditional financial analysis, we consider ESG factors in our investment analysis and decisions. Engagement with companies is also key part of our investment process. The scope is to better understand and assess their business model, strategy, quality of management, material risks and opportunities including those ESG related, companies and industries facing. Through dialogue with company management via visits, regular meetings, and conference calls, we encourage them to disclose information on ESG topics, to improve their performance, reduce their risk profile or develop more sustainable business practices. We collaborate with industry peers to support the wider acceptance and implementation of ESG investing.

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

Optional comment

ALPHA TRUST, recognizing the importance of responsible investment decisions based on ESG criteria, joined the "Principles for Responsible Investment" (PRI) initiative as "Investment Manager Signatory" in 2020 . Furthermore, ALPHA TRUST participates and gradually implements standards, frameworks and principles related to Sustainable Development, including: 1. Net Zero Asset Managers Initiative 2. Τask Force on Climate-related Financial Disclosures (TCFD) 3. UN Global Compact 4. Global Compact Network Hellas (GCNH). ALPHA TRUST in the context of its commitment to corporate sustainability has also taken the following actions: * Promoted its sustainability transparency in its Annual Report 2021. Included material ESG information of the year 2020, with the adoption of the “ATHEX ESG Reporting Guide 2019” developed by the Athens Stock Exchange *Is currently developing its first Sustainability Report of the year 2021, according to the Global Reporting Initiative (GRI) and *Became Early Adopter of UN Global Compact in 2022. 2. To promote among other characteristics, environmental or social characteristics, or a combination provided that the companies in which the investments are made follow good governance practices, the ALPHA TRUST GLOBAL LEADERS ESG FOREIGN EQUITY FUND (HCMC’s License: 134th/4.8.1999/6) amended its regulation and name, (based on sub-no. 408 / 25-2-2022 of the approval decision of the Hellenic Capital Market Commission) and categorised according to article 8 of the SFDR . Further on the human rights, Labour rights/Decent work, Environment and on anticorruption commitment is stand alone or part of ALPHA TRUST broader policies. https://www.alphatrust.gr/en/sustainability/ https://www.alphatrust.gr/etaireia/i-etaireia/etairiki-diakuvernisi/kodikes-kanonismoi-kai-politikes www.alphatrust.gr/files/παραρτημα_4_anti_fraud_and_anti_corruption_policy_and_procedures.pdf

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

Optional comment

More information available on the ALPHA TRUST website https://www.alphatrust.gr/en/sustainability/ https://www.alphatrust.gr/etaireia/i-etaireia/etairiki-diakuvernisi/kodikes-kanonismoi-kai-politikes www.alphatrust.gr/files/παραρτημα_4_anti_fraud_and_anti_corruption_policy_and_procedures.pdf

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

Optional comment

Established ESG Committee to support and guide the company towards the integration of ESG considerations in the operation and the investment processes, in July 2020. Further on the Anti-Corruption has stand alone policy with processes and audit committee. www.alphatrust.gr/files/παραρτημα_4_anti_fraud_and_anti_corruption_policy_and_procedures.pdf

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

Optional comment

ESG committee members are appointed by the Board of directors. Two of them are Board Members, and 4 are also members of the executive committee.

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

Optional comment

ALPHA TRUST provides summary supervisory information related to its capital adequacy and risk management which it undertakes in the context of its operation. The disclosure is notified to the Capital Market Commission and posted on the company's website. https://www.alphatrust.gr/files/risk_management_report_2021.pdf

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

https://www.alphatrust.gr/files/risk_management_report_2021.pdf

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

Optional comment

anti_fraud_and_anti_corruption_policy_and_procedures public available on ALPHA TRUST website: www.alphatrust.gr/files/παραρτημα_4_anti_fraud_and_anti_corruption_policy_and_procedures.pdf

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
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

Optional comment

All employed persons have the right to report cases where it appears that the content of the Code of Conduct and Business Ethics of the Company is violated. In the event that there are indications of such cases, the employed persons must to inform without delay the Investigation Team as provided in the Policy internal reports-disclosures (whistleblowing policy). Reports will be considered, and where corrective and remedial action will be taken if required. The above notification can also be made anonymously and the persons reporting them violations are effectively protected from potential retaliation. www.alphatrust.gr/files/κωδικασ_δεοντολογιασ_και_επιχειρηματικησ_ηθικησ.pdf

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)

Optional comment

www.alphatrust.gr/files/περιληψη_εσωτ_κανονισμου_λειτουργιασ.pdf

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

Optional comment

www.alphatrust.gr/files/περιληψη_εσωτ_κανονισμου_λειτουργιασ.pdf

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

Optional comment

www.alphatrust.gr/files/κωδικασ_δεοντολογιασ_και_επιχειρηματικησ_ηθικησ.pdf

Executive Pay

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

Optional comment

The remuneration policy applied by the ALPHA TRUST is based on parameters designed to optimize its smooth, effective, substantive, and lawful operation, while remaining competitive in terms of fee levels, especially as regards its executives. At the same time, it aims at eliminating the exposure to risks that have been deemed undesirable or the mitigation thereof to acceptable and safe frameworks where risk taking is allowed, as well as at the avoidance of conflicts of interest. It mainly concerns senior Management members, risk-takers in business units, staff responsible for internal control and any employee receiving total remuneration that takes them into the same remuneration bracket as senior management and risk takers. Furthermore, the remuneration policy is consistent with and promotes sound and effective risk management – explicitly including sustainability risk as defined in the Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector – and does not encourage excessive risk‐taking and/or risk-taking which is inconsistent with the risk profiles, funds’ rules or instruments of incorporation of the UCITS and AIFs that the company manages, while it provides for the link of the remuneration structure – in particular for the risk-takers – to the risk-adjusted performance. www.alphatrust.gr/files/remuneration_policy_10_03_2021.pdf

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 (#)	7
Male (%)	71.43
Female (%)	28.57
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	14.29
Above 50 years old (%)	85.71
From minority or vulnerable groups (%)	0
Executive (%)	42.86
Independent (%)	28.57

Optional comment

www.alphatrust.gr/etaireia/oi-anthropoi/partners/

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

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Members of ESG committee, legal/compliance reviewed the information disclosed

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2022
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
2018
Access to water and sanitation

Optional comment

www.alphatrust.gr/files/περιληψη_εσωτ_κανονισμου_λειτουργιασ.pdf www.alphatrust.gr/en/privacy-protection-policy/

2.1. For each human rights policy, is it:

	Aligned with international human rights 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 human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human 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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human 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 to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human 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.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human 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)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

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.

ALPHA TRUST is committed to strengthening and refining its approach towards corporate sustainability. This commitment includes enhancing the dialogue with industry peers on ESG issues, enhancing our ESG related reporting and research process and communicating with all stakeholders. Moreover, given the rapid changes in the regulatory framework, the science and academic literature related to sustainability issues, we expect to further enrich the processes as we accumulate knowledge and experience.

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
Forced labour
2022
Child labour
2022
Non-discrimination in respect of employment and occupation
2022
Occupational safety and health
2022
Working conditions (wages, working hours)
2022

Optional comment

ALPHA TRUST occupies 49 people. Due to size and sector the association is not a high relevance/importance. However this approach is regularly reviewed, in the light of the broader developments. www.alphatrust.gr/files/κωδικασ_δεοντολογιασ_και_επιχειρηματικησ_ηθικησ.pdf

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)

Optional comment

www.alphatrust.gr/files/κωδικασ_δεοντολογιασ_και_επιχειρηματικησ_ηθικησ.pdf

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)

Optional comment

In the course of the reporting period, the company has no affected stakeholders or their legitimate representatives in relation to the above topics, thus no engagement took place.

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
Review on relevance and broader developments
Forced labour
Reviewed and updated polices
Child labour
Reviewed and updated polices
Non-discrimination in respect of employment and occupation
Reviewed and updated polices
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Reviewed and updated polices

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)

Optional comment

ALPHA TRUST occupies 49 people. Due to size and sector the association is not a high relevance/importance. However this approach is regularly reviewed, in the light of the broader developments.

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 (%)	98

Optional comment

www.alphatrust.gr/files/alpha_trust_fs__31_12_2021_final.pdf (page 16)

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 (%)
ALPHA TRUST occupies 49 people. Due to size and sector the association is not a high relevance/importance. However this approach is regularly reviewed, in the light of the broader developments.

Optional comment

www.alphatrust.gr/files/alpha_trust_fs__31_12_2021_final.pdf

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

	Percent of women (%)	Unknown
Senior leadership level position	20
Non-executive board	50

Optional comment

www.alphatrust.gr/files/alpha_trust_fs__31_12_2021_final.pdf (PAGE 16)

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 (%)	46

Optional comment

the above ratio is calculated as follows: the average gender pay gap in yearly salaries as a percentage of men’s pay. https://www.athexgroup.gr/documents/10180/6599246/ESG+Reporting+Guide+2022-2202.pdf/d5fe6a40-c493-46a7-b307-37494b6ca49d www.alphatrust.gr/files/alpha_trust_fs__31_12_2021_final.pdf (PAGE 16) https://www.alphatrust.gr/files/alpha_trust_anual_report_2020.pdf

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

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

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
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
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.

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
2022
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
2022
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use
2022

Optional comment

ALPHA TRUST is active in the services sector. It is considered that the environment is not heavily affected by our operations and at the same time our actions are considered to limit our environmental footprint. www.alphatrust.gr/files/alpha_trust_anual_report_2020.pdf

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

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

Optional comment

No engagement as there no affected stakeholders during the reporting period.

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
follow and review the evolving framework
Oceans
follow and review the evolving framework
Forests / Biodiversity / Land Use
follow and review the evolving framework
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
follow and review the evolving framework
Energy & Resource Use

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

ALPHA TRUST follows and reviews the evolving framework

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)

9.51

Scope 2 Emissions

Full

None

Emissions (tCO2e)

29.6

Scope 3 Emissions

Full

Partial

None

Scope 3 emission not available

Emissions (tCO2e)

Optional comment

www.alphatrust.gr/files/alpha_trust_fs__31_12_2021_final.pdf (page 14) www.alphatrust.gr/files/alpha_trust_anual_report_2020.pdf (page 24)

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 (%)

Unknown

Not applicable (Please provide additional information)

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

ALPHA TRUST through its investments finances climate change adaptation and resilience initiatives and projects. Furthermore has taken actions towards Environmental footprint reduction in its operations.

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

25.86

Unknown

Optional comment

www.alphatrust.gr/files/alpha_trust_fs__31_12_2021_final.pdf (page 14)

Technology

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

Percent of total revenue (%)

To promote among other characteristics, environmental or social characteristics, or a combination provided that the companies in which the investments are made follow good governance practices, the ALPHA TRUST GLOBAL LEADERS ESG FOREIGN EQUITY FUND (HCMC’s License: 134th/4.8.1999/6) amended its regulation and name, (based on sub-no. 408 / 25-2-2022 of the approval decision of the Hellenic Capital Market Commission) and categorised according to article 8 of the SFDR, during 2022

Unknown

Not applicable (Please provide additional information)

Optional comment

www.alphatrust.gr/files/alpha_trust_fs__31_12_2021_final.pdf

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.

Environmental footprint reduction actions: Office lighting with economy lamps, Minimize outdoor lighting with a combination of economy lamps, timers and photocells, Burner maintenance and configuration optimization, Recyclable consumables, Limited use of plastic, Battery Recycling, Replacing corporate cars with electric or hybrid reduced emission technology, Design an online platform for a complete automated transaction process with clients Digitization of paper flies. www.alphatrust.gr/files/alpha_trust_anual_report_2020.pdf

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

2019

Optional comment

www.alphatrust.gr/files/παραρτημα_4_anti_fraud_and_anti_corruption_policy_and_procedures.pdf

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

Optional comment

www.alphatrust.gr/files/περιληψη_εσωτ_κανονισμου_λειτουργιασ.pdf

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 of corruption to current or previous year
Confirmed during the current year, and related to this year	0
no incidents of corruption to current or previous year

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)

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.

ALPHA TRUST is committed to acting professionally and fairly in all transactions and its relationships, applying the highest standards of transparency and accountability and adopts a zero-tolerance approach to fraud, bribery and corruption. ALPHA TRUST promotes a culture of honesty and integrity and fully opposes any form of fraud, bribery or corruption. www.alphatrust.gr/files/παραρτημα_4_anti_fraud_and_anti_corruption_policy_and_procedures.pdf