ΕΛΛΗΝΙΚΟΣ ΧΡΥΣΟΣ

1. Strategic, Analysis & Action

ADMINISTRATIVE PRACTICES

At Hellas Gold we recognize that corporate responsibility is a continuous effort that can enable significant developmental opportunities and benefits to our local communities, Greek society and the economy. It is an operating philosophy that must be actively and carefully managed to limit our social and environmental impacts, while maintaining consistent growth of our projects.

The three pillars forming the foundation of Hellas Gold’s corporate responsibility strategy are: a) environmental protection, b) support to local communities and the economy, and c) upholding the interests of our employees. In the environmental realm, we have developed one of the most integrated and comprehensive environmental monitoring systems in Europe, measuring numerous parameters across all our projects, including soil, water and air quality, greenhouse gas emissions, noise and vibration. This monitoring system enables Hellas Gold to take an integrated approach towards environmental management and protection.

Our commitment to environmental protection is demonstrated by the reclamation of old tailings at Olympiada; one of the largest environmental reclamation projects ever undertaken in Greece. This is testament to the environmental awareness and responsibility that characterizes Hellas Gold. Moreover, we are truly proud of the Olympiada plant nursery, which began as a value-add initiative for the reclaimed tailings area, and evolved into one of the largest plant nurseries in Greece. It is an example of a leading, alternative development practice for the area, which supports
the reclamation and restoration of old mining areas.

To encourage broader economic development of the Aristotelis Municipality, we have prioritized the repair of local infrastructure and monuments with the aim of increasing tourism in the region. Concurrently, in close cooperation with the Mount Athos Area Organization, we have actively contributed towards advertising and promoting the region as an area of international interest at tourism events in Greece and abroad. The economic development of the region plays an important role for the future and long-term success of our employees, the majority of whom originate and permanently reside within the Aristotelis Municipality. Young engineers and scientists are now pursuing successful careers close to their homes and families, something not possible before the  development of our mines and projects. Beyond our own employees, the indirect employment opportunities generated for local contractors and suppliers
are significant, with petrol stations, catering services, hotels and others all benefiting from our investment. We have seen the creation of new jobs and local companies related to our mining activities. These facilitate the continuous growth and prosperity of local industry and the economy.

It is important to highlight the numerous initiatives and investments we make to support and enhance the quality of life for residents of the Mademohoria region. These include improving local roads and infrastructure, and providing support to the medical center of Palaiohori. Additionally, during the summer of 2015 we invited 350 students from the Aristotelis Municipality to participate in the Hellas Gold summer internships program, providing them with invaluable professional work experience prior to graduating and entering the Greek labor market. Annually, we also provide awards and cash prizes to newly admitted
university students from the Aristotelis Municipality to further support their studies. Ensuring our people return home safely every day is paramount,
and we are committed to the highest Health and Safety standards. All European Union (EU) regulations are meticulously adhered to and our Occupational Health and Safety Management System is certified under OHSAS 18001. Our investment plans are significantly contributing to the development of the region, and reinforce Hellas Gold’s commitment to the region, our people and our country. Hellas Gold is part of Greece. We produce and create value for our country, and will continue to do so through responsible operations; protecting the environment, supporting our employees, and generating prosperity
for our communities.

Attached Files: Download Sustainable Development Report 2015

PERFORMANCE INDICATORS

Our performance had been highlighted through a variety of competitions and processes, indicatively:

Hellenic Value” of Northern Greece 2015 Award

On December 11th 2015, the 2015 award ceremony for the “Hellenic Value” of Northern Greece institution, took place at “The Met Hotel”. The thematic awards were concluded with three companies receiving awards that recognize the realization of successful Corporate Responsibility actions during the previous years.

“Winner” and “Gold” Health and Safety Awards

Hellas Gold received the highest distinction for its Health and Safety policy and philosophy, receiving the “Winner” and “Gold” awards at the Health and Safety Awards, taking place in Athens on September 29th 2015. This distinction recognizes Hellas Gold’s Health and Safety policy and philosophy, and acknowledges the Company’s adherence to the highest and strictest standards by awarding Hellas Gold first place in the field of health and safety for the mining industry sector, and the gold medal in the field of emergency readiness and management.

Human Resources Distinctions

Hellas Gold received  considerable distinctions for its Human Resources policy and practices, by being honored at the HR awards ceremony that took place in Athens on October 1st 2015, attended by many prominent companies and organizations. Hellas Gold, participating for the first time in the awards ceremony, received an honorable distinction in the following categories:
1. Excellence in Workplace Well-being
2. Excellence in Performance Management Strategy
3. Best Performance Management Tools / Practices
4. Best Local Recruitment Practices

Corporate Responsibility Institute (CRI) “SilverAward”

Hellas Gold received the “Silver Award” from the Corporate Responsibility Institute (CRI) as a distinction and reward for its actions towards Corporate Responsibility over the past three years.

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2. Materiality

ADMINISTRATIVE PRACTICES

In May 2016 Hellas Gold finalized a materiality analysis involving internal and external stakeholders, to help determine the material sustainability aspects and content for inclusion within the 2015 Report. Material Issues are those that reflect Hellas Gold’s significant economic, environmental and social impacts or substantively influence the assessments and decisions of its stakeholders. The materiality analysis will also be used by Hellas Gold to revise and enhance its broader sustainable development strategy. The analysis was conducted in accordance with the GRI G4 Sustainability Reporting Guidelines. Changes from previous reporting periods in the Scope and Aspect Boundaries relate to a broader approach during the materiality analysis identification phase, as well as different use of criteria and stakeholder engagement methods during the prioritization phase.

Attached Files: Download Hellas Gold sustainability report pages 18-20

PERFORMANCE INDICATORS

Phase 1
Identification of relevant issues
During the first phase of the analysis, Hellas Gold considered the GRI G4 Principles of Stakeholder Inclusiveness and Sustainability Context, and identified topics relevant to the Company’s mining activities and stakeholders. Findings were based on review of the following:
• internal documentation related to policies, procedures, and strategies and existing stakeholder engagement feedback (e.g. opinion surveys).
• Media and press clippings of 2015 concerning mining and Hellas Gold.
• Eldorado Gold’s 2014 Sustainability and 2015 Year In Review reports.
• peer mining companies’ Sustainability Reports, both in Greece and abroad.
• the new United Nations Sustainable Development Goals.
• GRI’s publications concerning the mining sector.
• leading global frameworks and sustainability guidelines,
both for the mining sector and broader industry.

Phase 2
Prioritization of issues
For Phase 2, the Company considered the GRI G4 Principles of Materiality and Stakeholder Inclusiveness, and prioritized the topics identified in phase 1 against two criteria:
• Significance of the issues to the long-term goals and strategy of the Company.
• Importance of the issues to Hellas Gold’s internal and external stakeholders.
For the first criterion, the Company organized dedicated focus groups to prioritize the identified topics, with participation of Hellas Gold management in Athens and Halkidiki.
For the second criterion, focus groups and electronic surveys were conducted with stakeholders. Specifically, three focus groups were organized with representatives from local communities, local government and employee unions. In those focus groups, the identified topics from Phase 1 were discussed and then prioritized by participants. The results enabled a qualitative analysis of the Company’s material issues and helped Hellas Gold to better understand our stakeholders’ expectations and concerns. In addition, using the electronic survey, the Company was able to engage with a larger sample of participants
and identify the opinions of broader stakeholder groups. The results of the analysis are presented in the materiality map.

Phase 3
Validation of results
In the final phase of the analysis, Hellas Gold validated the results of Phase 2 with members of the Company’s senior management team. This process took into consideration the GRI G4 Principle of Completeness and Stakeholder Inclusiveness. Through this analysis, eight material issues were determined
and selected for reporting in our 2015 Report, which are presented in table 3, along with their internal and external boundaries. The materiality map on the next page also outlines the top 26 sustainability topics identified during our materiality analysis in order of stakeholder influence and their significance to Hellas Gold.

Attached Files: Download Materiality Map, Hellas Gold Sustainability Report 2015 pages 20-21

3. Objectives

ADMINISTRATIVE PRACTICES

Hellas Gold targets are analyzed per department on the pages 37, 39, 44, 49, 54-55, 59, 62, 63, 64, 68 of our sustainability report

                Hellas Gold Targets for 2016

1. Increase local economic development through the increasing tourism in the area. Promote the region as an area of international interest at tourism events in Greece and abroad. (Page 6-50)
2. Finalizing and publishing our comprehensive environmental monitoring system across all our operations, which will be made publically available and enable our communities and stakeholders to monitor our performance in real-time. (Page 7-60)
3. Complete our renovation of the Olympiada flotation plant by March 2017 (Page 7)
4. Achieve production in Skouries during 2019. (Page 7)
5. Increase the percentage of local suppliers or the spending on local suppliers (Implied in page 17-50)
6. Reinforce the cooperation with government to further licensing the company’s projects. (Page 28)
7. Respond immediately to any changes in the law and in any identified regulatory compliance issue (Page 28)
8. Improve departments’ financial performance against budget (page 32).
9. Increase the percentage of the locals that work for the company in Kassandra mines, the percentage for 2015 was 87% and the target is 90% or more. (Page 37-49)
10. Promote a common culture for all Hellas Gold employees no matter their age, years of experience, education level and seniority (Page 37).
11. Further train and educate our personnel (Page 37)
12. Specifically, increase the hours of training in Health and Safety issues (Page 39)
13. Employment targets;
    1. Increase employment in the area,
    2. maintain current personnel, (low turnover)
    3. Increase employee satisfaction,
    4. decrease lost working hours,
    5. Ensure balance between men and women recruited. (Page 39).
14. Improve all Health and safety numbers (Page 45).
15. Increase the percentage of Hellas Gold managers that are coming from Aristoteles Municipality (Page 49).
16. Improve local infrastructure (Page 51). Improve infrastructure for public healthcare in the area (Page 53)
17. Further support education programs for the local community, further enhance the cooperation with universities (Pages 52-53).
18. Increase the participants of the informational visits in Hellas Gold sites, supporting an open door communication approach. (page 52)
19. Maintain the perfect record of compliance with the environmental laws and regulations (Page 60)
20. Minimize the total extracted materials deposited as solid mine waste (Page 61).
21. In addition, during 2016 our goal is to reuse all waste rock from Olympiada and Stratoni, so that no solid waste remains. This goal goes beyond legislation, and is another example of our voluntary efforts to minimize our environmental impact. (Page 62)
22. Improve the numbers of total water discharge (Page 63)
23. Our production process to use 100% recycled water (Page 64).
24. Increase the reclamation of the land (pages 66-69):
25. Stratoni old arsenopyrite deposits
26. Olympiada’s old tailings deposit area
27. Olympiada’s old arsenopyrite piles
28. Implement the Experimental cultivation of aromatic and medicinal herbs in Stratoniki (Page 71)

Attached Files: Download Hellas Gold sustainability report pages 37, 39, 44, 49, 54-55, 59, 62, 63, 64, 68

PERFORMANCE INDICATORS

We are certified and we are in the processs of re- certification for several business processes with the following certifications:

1. OHSAS 18001
2. ISO 14001
3. ISO 50001
4. ISO 39001
5. SA 8000
6. ISO 14064
7. ISO 9001

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4. Management of Value Chain

ADMINISTRATIVE PRACTICES

Hellas Gold’s supply chain is designed and actively managed to enhance local procurement and lower costs. It is integrated across our business units and mining activities and extends throughout the operation lifecycle; across planning, construction, mining, and reclamation activities.

The geographical location of our mines and our proximity to commercial business centers significantly influences our supply network. The management of local suppliers, the optimization of existing transport networks, the combination and merging of shipments, and the use of transit stations, are all key factors in the design and function of our supply chain. The supply chain is managed by Hellas Gold’s Purchasing department, located in Stratoni.

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PERFORMANCE INDICATORS

In HG suppliers/contractors (S/C) are categorized based on the following definitions:

Local  S/Cs  are those based on the Municipality of Aristotle only ( H.G. s.a. basis of activities) (see map page 6)

Regional S/Cs are those based in the neighboring municipality of Volvi and the rest of Chalkidiki Prefecture.( see map page 10)

National S/Cs are those based in the rest of Greece

International S/Cs are those based outside of the country

Identification and prioritization of local S/Cs  is based in the

• Identification of goods and services by listing potential groups of such goods and services available in the local market.   
• Segmentation and short-listing  of opportunities according to the level of risk/difficulty to procure.
• Prioritization of procurement opportunities in a short, medium and long term.
• Monitoring of procurement activity on a yearly basis.  ( For  more detail see section  2)

1. Are there set targets for local suppliers/contractors?

 Maintain the business with LS/Cs as long as they remain active as taxable entities (do not stop their business due to tax/ country economical situation, reasons). Below is the number of LS/Cs who did business with H.G.s.a. the last 5 years:

                        2012 – 204

                        2013 – 222

                        2014 – 264

                        2015 – 245

                        2016 - 280

• Increase cooperation with existing LS/Cs
• Involve more LS/Cs in doing business with H.G.s.a.
• Develop existing suppliers.

1. What are the efforts to develop the capacity of local s/c in order to increase the amount of goods and services that can be procured locally?

First of all, access to Procurement function is unlimited to LS/Cs.

Meetings are set whenever requested from LS/Cs, for letting H.G.s.a.  know of the extension of their business, to a wider area of commercial activities.

S/Cs with a known activity, are informed if new products are required by HG and their active business is similar so they can procure it.

Second, brand representations in the country, of foreign brands specialized in the mining activity, can easily be based in the municipality boundaries if LS/Cs are willing to have a realistic approach to the nature of the business. In such cases we promote the creation of such business by informing suppliers of such opportunity.

Rarely though, we have offered payment terms in favor of a local S/Cs whom a contract was awarded, in order to facilitate with facing a costly maintenance in order to increase the good condition and  availability of their equipment for the specific work or to add to their capital to purchase more equipment and enhance their businesses.

Moreover, training is offered by H.G.s.a. to LS/Cs with stretch in the area of H&S by increasing their H/S standards to H.G.s.a.  standards which are higher than the national.

Moreover, information and training is offered by H.G.s.a. to LS/Cs in the area of environmental standards according to H.G.s.a.  Environmental policy and type of  licenses required . In this way they can apply to authorities, obtain the licenses required and participate in  tenders with environmental works. 

Finally there is a continuous contact with local s/c Associations to improve business.

1. How does Hellas Gold monitor and evaluate the effectiveness of local procurement practices to further improve management of local procurement?

Each year it is reported the value of purchases locally as far as capital spend and number of S/Cs per community of Aristotle municipality ( see  table  page 45  ). Procurement  analyzes the data collected and investigates:

• Reasons for reduction or increase of business municipality wise
• Per village
• Per group of S/Cs in municipality .
• Actions to improve bussiness
• Developing of LS/Cs

Results are evaluated and actions are planned and applied for the running of next purchasing year.

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5. Responsibility

ADMINISTRATIVE PRACTICES

Code of Business Conduct

At Hellas Gold we have prepared and adopted a Code of Business Conduct and Ethics that outlines our expectations for acting ethically in all situations and making choices that are in line with the highest standards of integrity and business conduct.

Environmental Management

We don’t believe in operating simply as mine managers or stewards of mineral resources. Rather, we are committed to operating responsibly and generating shared value through partnering and cooperating with our stakeholders. Our environmental management practices are designed to mitigate our impacts across the lifecycle of our operations, from exploration through to mine closure. We are already demonstrating this commitment through activities like the remediation and rehabilitation of old mine tailings, the use of advanced environmental monitoring systems, and rigorous employee environmental training.
Hellas Gold’s Environmental Department is one of the most staffed departments when compared to mining companies of our size in Greece, with 19 employees and 15 contractors permanently employed by our sites.

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PERFORMANCE INDICATORS

All Company employees are required to review and sign the Code of Business Conduct and Ethics on an annual basis. The Code is shared with all staff and contractors of Hellas Gold. Any infringements to the Code can lead to disciplinary measures being taken which can result in the offenders’ dismissals. New recruits are briefed on the key topics contained in the Code as part of induction training and before they sign it.

Environmental policy
 
Hellas Gold’s environmental policy is centered on:
1. Commitment to strict compliance with national and European regulatory requirements and the approved Environmental Conditions;
2. Commitment to the continuous improvement of our environmental performance;
3. The application of best available technologies and practices throughout the lifecycle of our sites;
4. Commitment to remediation and rehabilitation of all areas no longer needed for mining use.
In addition to our environmental policy, we take a precautionary approach to risk management throughout the life of our projects and mines. We recognize there are environmental and social impacts from our operations, therefore before any activities commence we assess the potential environmental and social impacts, and evaluate how to avoid, control, or mitigate these, even when impacts are not yet certain.

Establishing a culture of environmental awareness
Hellas Gold’s commitment to environmental stewardship extends beyond regulatory compliance, as we promote a culture of environmental awareness among all our employees and contractors. We invest in continuous employee training on several environmental topics in order to reinforce this message, including:
• Recycling
• Waste management
• Energy efficiency
• Resource efficiency

Environmental management system
Hellas Gold has implemented a rigorous Εnvironmental Μanagement System (“EMS”) that governs our environmental stewardship across the lifecycle of our mines. The EMS is designed in accordance with our operating licenses and permits, and is independently certified in accordance with the ISO 14001 Environmental Management System standard. Implementation of ISO 14001 was a rigorous process and involved the development of our environmental policy, operating procedures and guidelines, environmental objectives and policy commitments, and the conduct of regular audits and reporting. The scope of ISO 14001 encompasses all stages of our projects’ life cycle, including exploration for new deposits, construction of new mining facilities, operation
of our mines and processing facilities, transportation of materials, and rehabilitation of our sites. Our practices and activities are prioritized based on environmental monitoring and impact assessments that we continuously undertake. These actions - based on Greek and European legislature - are outlined in monitoring andassessment procedures that satisfy the requirements of all agencies and bodies that oversee our performance. These agencies and bodies include:
• The Ministry of the Environment
• The Environment, Construction, Energy and Mining Inspection
Body
• The Ministry of Health
• The Decentralized Administration of Macedonia-Thrace
• The Region of Central Macedonia
• The Municipality of Aristotelis
• Scientific Committee for the Compliance to Environmental
Terms
In 2016, we becamecertified under the ISO 50001 Energy Management Systems standard. This initiative will help Hellas Gold make continuous improvements to our energy use, and make it easier for the Company to integrate energy management into our broader decision making efforts. ISO 50001 is an example of a leading European standard, and in the future will help position Hellas Gold to be certified under the EU Eco-Management and Audit Scheme (EMAS); a premium management instrument developed by the European Commission for companies to evaluate, report, and improve environmental performance. We intend to apply for EMAS when all of our facilities are operational, most likely in 2019.

Investing in environmental stewardship
Hellas Gold Senior Management are actively involved in supporting our environmental stewardship commitments, and are responsible for ensuring our teams are equipped with the necessary resources, tools and infrastructure to ensure our continued environmental compliance and strong performance. The Environmental Department is responsible for identifying opportunities to improve the rigor and effectiveness of the Environmental Management System, and all of the Department’s projects and proposals are reviewed by Senior Management prior to approval and implementation. A prime example of the  investment in environmental stewardship, is Hellas Gold’s pioneering environmental monitoring program, which required significant upfront expenditure
for purchasing and installing the required equipment. During the 2014-2015 period, more than €3 million have been invested for this program’s equipment. Additionally, Hellas Gold invests in reclamation and rehabilitation projects from the preexisting mining activities both at Olympiada and at Stratoniki - Mantem Lakkos - Stratoni area. Indicatively, during the 2013-2015 period, the Company invested more than €1 million in Olympiada, and following the projects’ completion, scheduled for 2018, the cost is expected to exceed €10 million. Hellas Gold is also working with several local Universities,
whose research has helped identify new ways we can improve our environmental performance.
We have partnered with:
• The Forestry Faculty of the Aristotle University of Thessaloniki for environmental reclamation
• The School of Geology of the Aristotle University of Thessaloniki for hydrological studies
• The School of Mining and Metallurgical Engineering of the National Technical University of Athens for environmental characterization studies of solid samples (waste rock and tailings)

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6. Rules & Processes

ADMINISTRATIVE PRACTICES

The Company’s policies on financial regulatory compliance, part of which are mandated by the SOX Act, seek to ensure not just compliance with laws, directives and other legal provisions, but also to strengthen the Company’s reporting on issues of financial management and transparency at all levels.  These policies cover the whole Company and responsibility for approving them lies with Hellas Gold’s Finance Department. Adherence to these policies is tied to senior management appraisals. Our commitment to regulatory compliance in financial management and financial transparency extends beyond compliance with Greek law, as we undertake additional internal audits and quarterly reviews not prescribed by national law. Across all financial management activities, we identify key risks where internal and external due diligence is required, thereby taking an approach that seeks to prevent improper practices. Our Company is SOX-certified and regularly reviewed by independent external auditors and our own internal audit team. We aim to respond immediately to any changes in the law and in any identified regulatory compliance issues, supporting management and our parent Company during all decision-making concerning Hellas Gold.

At Hellas Gold we have prepared and adopted a Code of Business Conduct and Ethics that outlines our expectations for acting ethically in all situations and making choices that are in line with the highest standards of integrity and business conduct. All Company employees are required to review and sign the Code of Business Conduct and Ethics on an annual basis. The Code is shared with all staff and contractors of Hellas Gold. Any infringements to the Code can lead to disciplinary measures being taken which can result in the offenders’ dismissals. New recruits are briefed on the key topics contained in the Code as part of induction training and before they sign it.

Our Company is committed to operating in line with the strictest international corporate responsibility standards. As part of that commitment, we comply with the corporate responsibility and business ethics codes developed by Eldorado Gold, which outline and specify acceptable forms of employee behavior at work and in dealings with third parties and companies. Eldorado Gold’s Internal Audit team provides independent assurance that Hellas

Gold are adhering to these requirements, as well that the Company’s risk management, governance and internal control processes are operating effectively. Internal Audit reports directly to the Hellas Gold’s Financial Department and Audit Committee; an independent committee of the Board whose goals are to ensure that the Company operates in a fully transparent manner and in the interests of Company stakeholders.

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PERFORMANCE INDICATORS

Our performance is regularly assessed through internal and external audits, legislative compliance reviews and auditor reports. Each review provides us with an independent assessment of our performance, and the feedback we gain is used to continuously evaluate and improve our governance and compliance. Recently we have witnessed frequent updates and developments to Greek law, therefore the reviews and audits we undertake are a key mechanism we employ to maintain compliance in an ever-changing legal and tax regime.

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7. Monitoring

ADMINISTRATIVE PRACTICES

Regulatory Compliance

Regarding the regulatory compliance, our performance is assessed through internal and external audits, legislative compliance reviews and auditor reports.
Each review provides us with an independent assessment of our performance, and the feedback we gain is used to continuously evaluate and improve our governance and compliance. Recently we have witnessed frequent updates and developments to Greek law, therefore the reviews and audits we undertake are a key mechanism we employ to maintain compliance in an ever-changing legal and tax regime.

Human Resource

Hellas Gold’s approach to Human Resource (“HR”) issues covers all facilities, projects and Company production plants. Hellas Gold’s Managing Director and HR Department, working in partnership with the parent company’s head office in Vancouver, Canada, work on HR issues and are responsible for approving all relevant policies in line with Greek labour and community law. In August 2015, according to the Productive Reconstruction, Environment and Energy Minister’s decision, the activities of the Company in Halkidiki were suspended. The Company halted its operations and the vast majority of employees were temporarily laid off for 1 ½ months.The initiative the Company took concerning the temporarylayoff of employees was to put a skeleton staff on rotating shifts to reduce the degree of which paywould be lost for as many employees as possible.

All employees, apart from interns and upper management, are eligible to receive performance bonuses based on accomplishing predetermined performance criteria, which include our target of zero days of work lost due to workplace accidents and emphasis on Health and Safety commitments. In addition to meeting statutory requirements with respect to compensation and benefits, the Company provides additional discretionary benefits to employees such as life and accident insurance, and medical and hospital coverage through a group insurance policy, as well as support for housing and transportation.

Health and Safety

Health and Safety

We are constantly evaluating our processes in order to:

• Avoid or diminish parameters that jeopardize the health and the safety of our personnel that works in our installations.
• Improve standardized functional processes
• Decrease accidents
• Evaluate annually the occupational danger.

Health and Safety committees Complying with relevant legislation (Law 3850/2010) our Company’s Health and Safety committee convenes every quarter, attended by representatives from all trade unions, the Occupational Doctor, the Safety Engineer and Kassandra’s Mine Management. The number of the committee’s members depends on the company’s number of employees and is thoroughly defined by Law 1568/85, Article 2. Health and safety issues and solutions are discussed at these meetings.

Environmental Management

Our environmental management system requires monthly, semi annual and annual reviews of our performance, which can identify early warnings and potentially lead to the prevention and mitigation of environmental hazards. Our review procedures also include updates to Senior Management on
any environmental compliance issues. Our approach to environmental compliance and performance is assessed through:
• Internal audits and controls
• Certified equipment and certified environmental measure ment procedures
• External assessments of compliance by independent environmental management certification bodies
• Continuous assessments and reviews against the requirements prescribed by the sites’ Environmental Conditions,
• Annual reviews of performance against legislative and regulatory requirements, and international standards.

Hellas Gold also considers the assessment findings of audit bodies (e.g. the Environmental Conditions monitoring committee and licensing authorities), reports and feedback from our employees and local community members, and feedback from the Scientific Committee for the Compliance with Environmental Terms - previously the Environmental Monitoring Committee - which was independently established by the State. Members of the Committee are from various local and regulatory bodies, and whose mandate is to review Hellas Gold’s compliance to the sites’ Environmental Conditions. By the end of 2016, Hellas Gold’s entire environmental monitoring system made publically available online. With true transparency, this initiative will enable anyone
who wishes to access our environmental performance across 320 environmental data measuring stations, meaning our neighbours and local communities can monitor our performance in real-time.

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PERFORMANCE INDICATORS

Regulatory Compliance

Our key success for 2015 was that despite nummerous change to taxation, capital controls and regulatory provisions, we achieved our planned economic performance in terms of budget excution and regulatory compliance.

Human Resource

Management’s approach to recruitment, employee retention and employment issues is evaluated using the following indicators:
• The number of direct and indirect jobs created.
• The employee retention rate and turnover levels .
• Employee satisfaction levels, which, in 2015, were evaluated indirectly and qualitatively, mainly through employee unions.
• Lost day rates.
• Employee and executive performance appraisals.
• The hours of employee training, especially on Health and Safety issues. In 2015, a total of 5,522 hours of training were provided to employees and contractors on Health and Safety issues.  

Health and Safety  

Our goal is to prevent or significantly mitigate factors that threaten employee Health and Safety at our facilities. We frequently revise our Standard Operating Procedures, with the aim of decreasing accidents. Every year we also carry out a quantitative occupational risk assessment. After the assessment, risk tables are prepared based on the potential frequency and severity of accidents. After the assessment, suitable mitigating measures are taken and the risk is then re-assessed. In 2015, occupational risk assessments were presented to all Company employees. During the same year, we
identified the need to accord greater weighting to employee comments about the risks they face at work. Each employee is able to record on a personalised card the main safety issues they face during a shift, while performing certain tasks, so that the next shift is aware of these hazards. The foremen and the janitors, under the guidance of the departments’ Managers, are responsible for collecting and addressing these comments. This system was designed in 2015 and is implemented in 2016. In 2015 new safety equipment was purchased for the Kassandra Mines, which included safety goggles with corrective
and anti-glare lenses for the staff and specialized Personal Protective Equipment (PPE) according to specialty (electricians, welders etc.). Following rescue team training, we also procured specialised equipment, such as breathing apparatus and fire protective suits. We also improved the conventional PPE
used by all employees on a daily basis. Employee safety outside of the workplace also concerns us. We have adopted strict rules and are carrying out
checks to ensure that speed limits and the requirements of the Greek Highway Code are being complied with for all employee-operated vehicles.                 

Environmental Management 

The Company has been exonerated from all petitions and litigations raised to-date. Currently there are no penalties, or outstanding decisions to be made
against Hellas Gold.                                                                                                 

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8. Incentive and reward systems for Sustainable Development

ADMINISTRATIVE PRACTICES

We also want to ensure that our employees enjoy an environment where everyone knows their rights and obligations. That’s why all work standards have been set out in Hellas Gold’s Work Rules and given to all employees. The Rules regulate labour relations at Hellas Gold, putting the individual at the heart of our day-to-day operations, setting out principles and forms of behaviour required to effectively participate in collective decision-making processes, and establishing values that promote personal and social responsibility. The Work Rules have been signed by the trade unions and are distributed
to all new recruits along with their employment contract. Our employees are notified about any change in the terms of their employment contracts one month before those changes take effect. The percentage of employees covered by collective labour agreements was 66% in 2015. Our Company also has two active trade unions, which ensure that employees maintain adequate contact with management. These trade unions are:
• Agia Varvara’ Labourers & Employees Union
• Association of Underground Miners – Kassandra Mines Halkidiki.

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PERFORMANCE INDICATORS

All employees, apart from interns and upper management, are eligible to receive performance bonuses based on accomplishing predetermined performance criteria, which include our target of zero days of work lost due to workplace accidents and emphasis on Health and Safety commitments. In addition to meeting statutory requirements with respect to compensation and benefits, the Company provides additional discretionary benefits to employees such as life and accident insurance, and medical and hospital coverage through a group insurance policy, as well as support for housing and transportation. Despite Greece’s economic situation, Hellas Gold has continued to maintain salaries unchanged and also offers all employees additional paid days off work.

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9. Stakeholder Engagement

ADMINISTRATIVE PRACTICES

Hellas Gold identifies its stakeholders as those who are influenced by its activities and those whose actions influence the
Company’s long-term sustainability. The following table includes information on the Company’s stakeholders and the
methods of engagement with them. The way that Hellas Gold addresses stakeholders’ concerns regarding the most material
of the below issues is described throughout this Report.

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PERFORMANCE INDICATORS

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10. Product Responsibility and Innovation

ADMINISTRATIVE PRACTICES

We don’t believe in operating simply as mine managers or stewards of mineral resources. Rather, we are committed to operating responsibly and generating shared value through partnering and cooperating with our stakeholders. Our environmental management practices are designed to mitigate our impacts across the lifecycle of our operations, from exploration through to mine closure. We are already demonstrating this commitment through activities like the remediation and rehabilitation of old mine tailings, the use of advanced environmental monitoring systems, and rigorous employee environmental training.
Hellas Gold’s Environmental Department is one of the most staffed departments when compared to mining companies of our size in Greece, with 19 employees and 15 contractors permanently employed by our sites. Environmental management system Hellas Gold has implemented a rigorous Εnvironmental Μanagement System (“EMS”) that governs our environmental stewardship across the lifecycle of our mines. The EMS is designed in accordance with our operating licenses and permits, and is independently certified in accordance with the ISO 14001 Environmental Management System standard. Implementation of ISO 14001 was a rigorous process and involved the development of our environmental policy, operating
procedures and guidelines, environmental objectives and policy commitments, and the conduct of regular audits and reporting. The scope of ISO 14001 encompasses all stages of our projects’ life cycle, including exploration for new deposits, construction of new mining facilities, operation of our mines and processing facilities, transportation of materials, and rehabilitation of our sites. Our practices and activities are prioritized based on environmental monitoring and impact assessments that we continuously undertake. These actions - based on Greek and European legislature - are outlined in monitoring and assessment procedures that satisfy the requirements of all agencies and bodies that oversee our performance.
These agencies and bodies include:
• The Ministry of the Environment
• The Environment, Construction, Energy and Mining Inspection Body
• The Ministry of Health
• The Decentralized Administration of Macedonia-Thrace
• The Region of Central Macedonia
• The Municipality of Aristotelis
• Scientific Committee for the Compliance to Environmental Terms In 2016, we aim to become certified under the ISO 50001 Energy Management Systems standard. This initiative will help Hellas Gold make continuous improvements to our energy use, and make it easier for the Company to integrate energy management into our broader decision making efforts. ISO 50001 is an example of a leading European standard, and in the future will help position Hellas Gold to be certified under the EU Eco-Management and Audit Scheme (EMAS); a premium management instrument developed by the European Commission for companies to evaluate, report, and improve environmental performance. We intend to apply for EMAS when all of our facilities are operational, most likely in 2019.

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PERFORMANCE INDICATORS

Hellas Gold Senior Management are actively involved in supporting our environmental stewardship commitments,
and are responsible for ensuring our teams are equipped with the necessary resources, tools and infrastructure to ensure our continued environmental compliance and strong performance. The Environmental Department is responsible for identifying opportunities to improve the rigor and effectiveness of the Environmental Management System, and all of the Department’s projects and proposals are reviewed by Senior Management prior to approval and implementation. A prime example of the investment in environmental stewardship is Hellas Gold’s pioneering environmental monitoring
program, which required significant upfront expenditure for purchasing and installing the required equipment. During the 2014-2015 period, more than €3 million have been invested for this program’s equipment. Additionally, Hellas Gold invests in reclamation and rehabilitation projects from the preexisting mining activities both at Olympiada and at Stratoniki - Mantem Lakkos - Stratoni area. Indicatively, during the 2013-2015 period, the Company invested more than €1 million in Olympiada, and following the projects’ completion, scheduled for 2018, the cost is expected to exceed €10 million. Hellas Gold is also working with several local Universities, whose research has helped identify new ways we can improve our environmental performance.
We have partnered with:
• The Forestry Faculty of the Aristotle University of Thessaloniki for environmental reclamation
• The School of Geology of the Aristotle University of Thessaloniki for hydrological studies
• The School of Mining and Metallurgical Engineering of the National Technical University of Athens for environmental characterization studies of solid samples (waste rock and tailings)

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11. Usage of Natural Resources

ADMINISTRATIVE PRACTICES

Hellas Gold obtained its mining license subject to two key requirements; the development of the Kassandra mines and the prioritized remediation and rehabilitation of existing mine projects. Since the beginning of its operation, Hellas Gold has worked towards completing all remediation activities associated with these historic mining areas, even before construction and development of the Kassandra mines. This demonstrates our commitment to operating responsibly with respect for the local environment. Our rehabilitation of old tailings demonstrates that mining can leave behind clean water, rehabilitated landscapes and healthy ecosystems. Our investment in the Kassandra Mines is constantly guided by our efforts to protect the environment. Backfilling mine waste, the dry disposal of tailings, and our mine remediation of disturbed soils from former mining activities are just a few examples of the approach we take towards protecting the environment and are embedded in our mine design throughout the project’s lifecycle. The reclamation of the area in parallel with the development of our projects is a core value and the foremost parameter in our project design. This means once we complete mining an area, we concurrently complete its rehabilitation.

Solid and liquid waste management is governed by the following management procedures:
• Hellas Gold’s Integrated Municipal Waste Management Program
• The Non-Hazardous and Hazardous Industrial Waste
Management System, which encourages mine employees to separate industrial waste at the point of generation in order to optimize their handling and management.
1. Solid mining waste
After raw materials are processed at our crushing facilities, any solid inert mining waste from the development of the Olympiada Mine, Skouries Mine and Mavres Petres development projects, are used for construction material. In many cases, these materials are also offered for free to local communities for their own infrastructure needs. Additional solid mining waste generated by our processing plants is used after treatment either as backfill material underground, or transferred to specially licensed landfill areas located inside our mine facilities. All solid mining waste is monitored by our Environment Team as part of our site environmental inspection and assessment procedures. Finally, during the development of our mining facilities any topsoil we remove is stored and maintained, and is later used for reclamation activities and at our plant nursery in Olympiada.
2. Liquid mining waste
Olympiada, Stratoni, Madem Lakos Because our sites recycle and recirculate water, we don’t generate any liquid waste. Only a small volume of water from
the underground Olympiada Μine, approximately 5-10 m3/h (an equivalent of 2-4% of an Olympic size swimming pool) is used to replace losses that occur due to product moisture and evaporation. The flotation plant’s water treatment circuit is closed, without producing liquid waste. After we process material, and in accordance with our licensing requirements for environmental disposal, any excess water is discharged to the natural environment. Approximately 10
m3/h at Stratoni and 5-10 m3/h at Madem Lakos are used as replacement water.

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PERFORMANCE INDICATORS

In Stratoni: 11% of total extracted materials is deposited as solid mine waste 26% of extracted materials forms the concentrate that we sell 63% of material forms a byproduct that we utilize for backfilling and construction works.

In Olympiada (from treatment of historic tailings): 15% of treated tailings is sold as concentrate 85% of extracted materials forms the by-product that we use for backfilling. Νo mine waste water or industrial effluents are discharged from our sites without being processed by our water treatment plants. Furthermore, the recycling of industrial water means that our sites discharge very little water, and only groundwater from our underground mines - not waste water - which is processed and discharged by our water treatment plants in accordance with the quality thresholds prescribed by our mining license.

We monitor and measure all waste generated by our sites in order to assess how effectively we reuse and recycle waste materials, in order to limit the volume of material sent to landfill. Mine waste generated from the cleaning of old tailings in Olympiada (reprocessed tailings) is monitored on a daily basis, with 800,000 liquid tons generated in 2015, which will be used for backfilling of the historic mining areas. At the Skouries mine, solid waste from the underground mine development was used as construction material, with over 20,000m3 utilized by our construction teams. All our coarse tailings material
is monitored daily by Hellas Gold. Specifically 106,000 liquid tons of coarse tailings were produced in 2015 at Stratoni - Mavres Petres, which was used as mine backfill. Additionally, over 6,000m3 of waste was generated, which was subsequently crushed and used on the mine tunnel floors.

We constantly monitor all liquid waste generated at our sites, which almost entirely consists of processed mine water or contact water from rainfall. Continuous sampling and chemical analysis by our Environmental Department monitors water quality parameters, and the results have proven that water quality and composition at Kassandra Mines is consistent with water samples taken elsewhere in Halkidiki.

In 2015, a significant increase in mine water supply was recorded, due to numerous large rainfall events in the winter. Precipitation from these storms generated between 400m3 to 700m3 of water during each event. Water acidity (or pH) is continuously monitored at our sites to ensure water quality falls well within our operating limits, both upon entry to the treatment facilities and at the point of final runoff. In addition, we are currently designing a new water processing unit capable of handling much larger volumes of water. We have operated this equipment on a pilot scale at Olympiada, improving mine water quality to potable drinking levels. We anticipate moving from a pilot to full scale operation in 2016.
The volume of liquid waste at Stratoni increased during the first period of 2015, due to large rainfall in the winter season. Between late 2014 and early 2015, prolonged periods of intense rainfall resulted in large flows of water at the site, and drainage was observed through subsidence and cracking of the land. This drainage was caused by the combination of heavy rainfall and the residual effects of former mining practices in the area. More specifically sub level caving in the past has caused cracks in the land today. Our monitoring of water quality confirmed that pH levels remained within the established limits
both upon entry to and runoff from the the mine water treatment facilities.

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12. Resource Management

ADMINISTRATIVE PRACTICES

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13. Climate-relevant emissions

REFERENCE

In Hellas Gold we have stopped reporting our management approach and our goals for gas emissions and climate change since 2015 when this topic was not included in Hellas Gold materiality issues after the extensive materiality analysis that took place with full participation of Hellas Gold stakeholders. The company includes in the sustainability reports many environmental topics that are more relevant with the mining industry than gas emissions. In any case we are monitoring closely and with past data the air quality and climate change parameters in real time and all the relevant data is accessible online on the link below:

https://environmental.hellas-gold.com/?lang=EN

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14. Employment Rights

ADMINISTRATIVE PRACTICES

Hiring people from the local community
For Hellas Gold, the main criterion during recruitment is that new employees are hired from the local area. The vast majority (87%) of the Company’s current staff come from the wider area of the Municipality of Aristotelis. The Company’s aim is to hire employees from local communities wherever possible.

Promoting a shared culture for employees at all our workplaces

Eldorado Gold acquired Hellas Gold in February 2012, but the story of the Kassandra mines dates back to the start of the 20th century. Each of the  companies that operated in the region had their own working culture and their own procedures. Today, we want to combine that tradition and experience with new technologies and know-how, and merge the skills of the local workforce with leading international practices. To achieve that, it is vital that we
all share the same goals, so that we all perceive success and challenges in the same way. Consequently, promoting a common culture for all our employees at all our workplaces is an every-day objective we strive for. This culture is founded on a belief in environmental responsibility beyond legal compliance, the continuous improvement of occupational Health and Safety, and the elimination of all kinds of discrimination in the workplace. To achieve these objectives in human resource management, we have adopted:
• A performance appraisal system
• An HR development strategy, aligned with corporate strategy

We also want to ensure that our employees enjoy an environment where everyone knows their rights and obligations. That’s why all work standards have been set out in Hellas Gold’s Work Rules and given to all employees. The Rules regulate labour relations at Hellas Gold, putting the individual at the heart of our day-to-day operations, setting out principles and forms of behaviour required to effectively participate in collective decision-making processes, and  establishing values that promote personal and social responsibility. The Work Rules have been signed by the trade unions and are distributed to all new recruits along with their employment contract. Our employees are notified about any change in the terms of their employment contracts one month before those changes take effect. The percentage of employees covered by collective labour agreements was 66% in 2015. Our Company also has two active trade unions, which ensure that employees maintain adequate contact with management.

These trade unions are:
• Agia Varvara’ Labourers & Employees Union
• Association of Underground Miners – Kassandra Mines Halkidiki.

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PERFORMANCE INDICATORS

Management’s approach to recruitment, employee retention and employment issues is evaluated using the following indicators:
• The number of direct and indirect jobs created.
• The employee retention rate and turnover levels.
• Employee satisfaction levels, which, in 2015, were evaluated indirectly and qualitatively, mainly through employee unions.
• Lost day rates.
• Employee and executive performance appraisals.

• The hours of employee training, especially on Health and Safety issues. In 2015, a total of 5,522 hours of training were provided to employees and contractors on Health and Safety issues.
• Ensuring a balance between the number of men and women recruited. We recognise that, due to the nature of our business and the relatively limited availability of experienced female mine workers in Greece, the percentage of female employees at the Company is relatively low. However, in the Administration Sector of the Company, the percentage of women recruited is 39% of the total. Our internship, summer-term positions and scholarships continue to support women who are interested in pursuing careers in the mining sector. Human Resource challenges facing Hellas Gold are often related to licensing issues, which can cause unnecessary delays to the development of our investments. During 2015 in particular, the Company faced the major challenge of temporary layoffs following the revocation by Greece’s Ministry of Productive Reconstruction, Environment and Energy of the technical studies of its projects in Halkidiki. The HR Department’s handling of this difficult period was considered successful, with clear communication to all employees of Company actions, and a balanced  distribution of temporary layoffs among employee groups. The Human Resource department provided clear communication for the cause of suspension and negative reactions were therefore limited.

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15. Equal Opportunities

ADMINISTRATIVE PRACTICES

Providing vocational training and education to promote life-long learning
In addition to the Company’s commitment to providing competitive compensation, Hellas Gold is committed to training its employees and that is why regular training at all worksites is a continuing priority for us. Although the majority of our workforce comes from the local community and has experience in mining, the continued training and education of staff means improved productivity and employee safety. Hellas Gold also believes in contributing towards the education of the local community, and provides scholarships for high school graduates who manage to get into university. This practice means that young people can tie their studies into a professional career, returning home to work and build a life for themselves in Halkidiki. The northeast Halkidiki region is one of the few non-urban areas in Greece which today gives young people an opportunity to pursue a rewarding career, near their home town, thanks to Hellas Gold’s operations in the area. It is also worth noting that the Company holds one of the largest percentages of employed engineers in the country, and offers employment opportunities to egineers with unique specializations, such as metallurgists and environmental engineers. The Company also plans to run a career guidance program offering advice to junior high school students while also helping the Company identify potential future employees from the area. Internships and summerterm positions are already fully integrated in Hellas Gold’s human resource planning, helping to increase the number of new hires from local communities.

Ensuring equal opportunities and avoiding discrimination
We believe in equal opportunities and base all recruitment decisions on abilities and experience. Male and female employees are paid equally for equivalent positions. Our Code of Business Conduct and Ethics states that all Hellas Gold employees are responsible for ensuring a workplace free of discrimination of any type, including discrimination on grounds of race, religion, gender, age, nationality, disability or sexual orientation.

All employees, apart from interns and upper management, are eligible to receive performance bonuses based on accomplishing predetermined performance criteria, which include our target of zero days of work lost due to workplace accidents and emphasis on Health and Safety commitments. In addition to meeting statutory requirements with respect to compensation and benefits, the Company provides additional discretionary benefits to employees such as life and accident insurance, and medical and hospital coverage through a group insurance policy, as well as support for housing and transportation. Despite Greece’s economic situation, Hellas Gold has continued to maintain salaries unchanged and also offers all employees additional paid days off work. Employee benefits 66% the percentage of employees covered by collective labour agreements in 2015 Stab le pay and additional days off work

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PERFORMANCE INDICATORS

Management’s approach to recruitment, employee retention and employment issues is evaluated using the following indicators:
• The number of direct and indirect jobs created.
• The employee retention rate and turnover levels.
• Employee satisfaction levels, which, in 2015, were evaluated indirectly and qualitatively, mainly through employee unions.
• Lost day rates.
• Employee and executive performance appraisals.

• The hours of employee training, especially on Health and Safety issues. In 2015, a total of 5,522 hours of training were provided to employees and contractors on Health and Safety issues.
• Ensuring a balance between the number of men and women recruited. We recognise that, due to the nature of our business and the relatively limited availability of experienced female mine workers in Greece, the percentage of female employees at the Company is relatively low. However, in the Administration Sector of the Company, the percentage of women recruited is 39% of the total. Our internship, summer-term positions and scholarships continue to support women who are interested in pursuing careers in the mining sector. Human Resource challenges facing Hellas Gold are often related to licensing issues, which can cause unnecessary delays to the development of our investments. During 2015 in particular, the Company faced the major challenge of temporary layoffs following the revocation by Greece’s Ministry of Productive Reconstruction, Environment and Energy of the technical studies of its projects in Halkidiki. The HR Department’s handling of this difficult period was considered successful, with clear communication to all employees of Company actions, and a balanced  distribution of temporary layoffs among employee groups. The Human Resource department provided clear communication for the cause of suspension and negative reactions were therefore limited.

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16. Qualifications

ADMINISTRATIVE PRACTICES

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17. Human Rights in the supply chain

ADMINISTRATIVE PRACTICES

Mining and Quarrying Operations Regulations
All mining companies in Greece operate in strict accordance with the Mining and Quarrying Operations Regulations, which further adheres to the requirements of OHSAS 18001.

Contractor Safety Rules

Our Contractor Safety Rules are included in all tender notices and project assignments at Hellas Gold mine sites, and form an integral part of the contracts the Company signs with all suppliers. The main objective of these rules is to ensure that contractors carry out work safely to prevent accidents among their employees, Company employees or third parties, and to avoid damage or harm to the facilities and equipment belonging to the contractor, Hellas Gold or third parties. Contractors are required to train their employees on Health and Safety issues at regular intervals, and before any project commences. The Contractor Safety Rules must form part of the core training materials for the contractors’ own employees. In 2015, Hellas Gold rolled out a new Contractor Management System. This system emphasizes the Company’s prerequisites for evaluating contractors, right from submission of quotes for a project. The contractor who will implement the project under the safest conditions will be selected. In addition, contractor employees undergo regular check-ups to determine their suitability for work. The Contractor Management System (represented by the Contractor Safety Standards) is based on strict standards.

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PERFORMANCE INDICATORS

Health and Safety targets are revised depending on the circumstances and annually attempts are made to improve year-on-year performance. External checks and inspections are also carried out regarding our compliance with OHSAS 18001 requirements, and seminars by external bodies are regularly attended by Company engineers so that they can effectively carry out Health and Safety inspections and internal audits. In 2015 we further improved the safety measures for working at height, and clamped down on unsafe driving by adopting a stricter safe driving policy. Finally, in 2015, we provided 5,522 hours of Health and Safety training to employees and contractors.

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18. Corporate Citizenship

ADMINISTRATIVE PRACTICES

Investing in local jobs
The Company is the largest employer in the Municipality of Aristotelis. We aim to recruit 90% of Company employees from the Municipality of Aristotelis. Currently, 87% of our employees are locally hired, and we continue to review our recruiting practices to enable us to meet our target. For example, we
are enhancing our search for new employees located within the Municipality, and are conducting more interviews with local candidates. This also means proactively looking for new employees from villages in the area, which have high unemployment rates. Our internship and summer-term positions programs are also great initiatives for us to identify potential future candidates. Ensuring that we provide local employment is therefore a material issue for both our
communities and the Company, particularly with regard to the need to develop local professions and our determination to invest in local recruitment, training and development. Recruiting residents from the Municipality of Aristotelis provides local students with an incentive to pursue studies related to mining. We anticipate that approximately 5,000 employee and contractor jobs will be created when all  three projects are in full swing because of the development taking place in the local area. We’ve received more than 8,200 job applications for the Kassandra Mines, which are becoming one of the largest employers in Northern Greece, 5,200 of those applications came from other municipalities. In addition, the fact that many Company executives, including
the Managing Director, originate from the area, fosters trust from local communities about the Company’s practices and plans. Being a part of the community, we regularly consult and engage on local issues concerning our neighbours, an example of which included the availability of non-manual labour roles for women interested in entering the mining industry. We take all feedback seriously and adjust recruitment practices wherever possible, such as our recent focus to recruit and train local women as security staff.

Supporting the local economy
In addition to the direct jobs we create and the jobs created by our contractors, the Company also supports other indirect and induced employment,
including local suppliers, petrol stations and fuel providers, and catering companies. We founded and support the Mount Athos Area Organization,
which aims to enhance tourism development in the region. Through its efforts, in 2015, the “Aristotelis Walk” brought 728 overnight stays in the area, and has helped extend the tourist season from 2.5 to 4 months annually. In Amouliani, room occupancy levels reached 100% in 2015, despite an overall 15% decrease nationally. In this context, new professions are emerging and supporting  sectors related to mining and the local economy are benefiting,
creating a new network of businesses that we can partner with.

Local suppliers
Company procurement policies reflect our strategy to bolster the local economy by directing employment and contracts to local suppliers. Key aspects we manage along our supply chain include local supplier management, optimising existing transport networks, combining and merging cargoes, using   transhipment centres, and ensuring our suppliers establish and adhere to safe operating procedures. Hellas Gold also collaborates with local businesses
in an effort to bolster employment levels for women. Tourism Tourism is a major industry and building block for economic development across the entire Municipality of Aristotelis. Hellas Gold supports the tourism and hotel sectors, in both the mountainous and coastal zones. Working closely with local government and competent local bodies, travel agencies and hotels, we have helped to develop major marketing campaigns aimed at developing all forms of tourism across the Municipality of Aristotelis. The results have been particularly encouraging with growth in religious tourism outside of Mt. Athos, more school trips within the Municipality, increased tourism during winter months, and the emergence of new attractions such as enotourism (wine tourism) and hiking tours.

Rural Development
To support and encourage broader economic growth in the region, we have developed partnerships with academic institutions and experts to train local  residents across a series of rural farming practices. Specifically, we are currently conducting a study into the planting and cultivation of aromatic and  medicinal herbs not previously grown in the region, which we established on Company land near Stratoniki village

Mitigating environmental impacts
As part of our consultation and Open Door Policy with the local communities, Hellas Gold frequently briefs local residents about the environmental impacts of its projects. In doing so, our Company engineers answer all questions and explain in detail any topics of interest, including the rehabilitation of old mining and tailings areas, actions to create a plant nursery, environmental monitoring and measures taken to improve the management of environmental issues.
Mitigating our environmental impacts is a key aspect of our social license to operate. Our approach is analysed in Chapter 5 of this Report and reflects the environmental awareness of Hellas Gold’s employees and local residents, and our commitment that even our smallest project will be implemented in a  responsible manner. Contributing to civil protection, infrastructure and services Projects to improve road networks, infrastructure and civil protection  services are illustrative of our efforts to improve the overall quality of life; not just for our employees, contractors and suppliers, but for all residents of the local area.
Forest protection, fire safety, support for flood protection works and environmental improvement works in the wider area, coupled with a well-trained,  volunteer rescue team are just some of the measures that demonstrate to the local community that our Company is responsible when it comes to  generating value for society as a whole. For example, on Monday, 15 June 2015 a fire protection flyover program was initiated in Halkidiki, for which Hellas Gold covered the cost of fuel in full. This fire protection flyover program lasted all summer and ran until Sunday, 13 September 2015 with Cessna aircraft from the Thessaloniki Aviation Club.
Developments and improvements to civil infrastructure are also visible throughout the area, including new water supply networks, new roads, biological treatment plants and boreholes, renovated buildings, renovated churches, and construction projects, all sponsored by Hellas Gold.

Attached Files: Download Sustainable Development Report 2015

PERFORMANCE INDICATORS

We evaluate our relationship and interaction with local communities every day in order to identify and provide meaningful and impactful contributions that generate value for society. In addition to looking at the qualitative aspects of this relationship, a key tool in evaluating our approach is research, which  includes data related to our social license to operate. It’s worth noting that many adjustments to our engagement strategy and approach have been  influenced by market research. We also monitor and record the results of our activities so as to constantly improve the positive impact we have. As an indication of that positive impact, in June 2015 we received a distinction from the Corporate Responsibility Institute in recognition of our activities and performance in the field of Corporate Responsibility.
Nevertheless, we recognise that the Company does not have a comprehensive system for responding to complaints from the local community, or a well-established method for recording its contacts with the local community. So, in 2016, the Company plans to take steps to achieve those two objectives, which will offer us more tools for evaluating how we manage and measure our social license to operate. To date, complaint management and meetings with the
local community have been handled informally as part of the Company’s community engagement activities. A key factor that contributes to our social license are the wages we pay our employees and contractors compared to other industries in the region. Mining is traditionally a competently-paying industry, and more specifically, Hellas Gold pays a minimum wage that is more than 50% higher that the statutory minimum wage. The areas around our projects have the highest reported income levels in Halkidiki. The clearest example is Olympiada where there has been a 17% demographic rise in minimum wages earned. While not explicit evidence of strong social performance, higher wages do demonstrate the positive impact our projects can have on society and an individuals’
purchasing power.

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19. Initiatives and Political Influence

ADMINISTRATIVE PRACTICES

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20. Corruption prevention and alleviation

ADMINISTRATIVE PRACTICES

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