ΜΟΤΟΡ ΟΙΛ

ORGANIZATION NAME:	ΜΟΤΟΡ ΟΙΛ
SECTOR:	Petroleum & Gas
ORGANIZATION TYPE:	500+
ANNUAL TURNOVER:	Πάνω από 50 εκ. ευρώ
COMPANY INTRO:
CONTACT DETAILS:	Ηρώδου Αττικού 12A 15 1 24, Μαρούσι Τ +30 210 8094000

STRATEGY

1. Strategic, Analysis & Action

ADMINISTRATIVE PRACTICES

The business mission of MOTOR OIL Group is to engage efficiently, responsibly, and profitably in the oil and gas and other selected businesses and to invest in alternative sources of energy, to meet evolving customer needs and the region’s power demand.

Our vision is to become a leading sustainable energy corporation in Greece and the wider region, fulfilling our business objectives:

Conducting sustainable business operations to ensure long-term profitability and continued growth for the benefit of all stakeholders.
Offer cleaner and high-quality energy products.
Contributing to sustainable development by integrating Economic, Environmental, and Social considerations into business decision – making.

2021 was the year that the global economy recovered strongly, supported by unprecedented fiscal and monetary stimulus in major economies, pent-up demand and increased public and private investments. The large-scale vaccination campaigns that took place during the year put pandemic in relative check since new variants forced governments, on several occasions, to implement restrictive measures to limit contagion. Furthermore, early 2022 brought new uncertainties and challenges: The dramatic Russian - Ukraine conflict, apart from leading to intolerable loss of human life, has put the world in a significant risk of energy crisis and associated economic costs. Indeed, the energy crisis has curbed some of the momentum behind sustainability in the interest of energy security but the direction for Motor Oil Group remains the same: As the world faces new challenges, we must not lose sight of the significance of taking clear action on climate change and designing a sustainable energy transition.

Potential risks

An indicative list of the risk areas which constitute the subject of audits is presented hereunder:

Business Strategy & Operational
Organizational, People, Reputational
Information Technology (Cyber Security, Technology, Data & Systems)
External events
Compliance
Financial, Commercial, Treasury
ESG (Environmental, Social, Governance) | QHSS (Quality, Health & Safety, Security

Our risk management system and policy provide a consistent and clear framework for managing and reporting risks.

Climate Risks

The Group supports the recommendations of the Task Force on Climate related Financial Disclosures (TCFD) to improve the reporting of climate related risks and opportunities. The TCFD recommendations are structured around four thematic areas: Governance, Strategy, Risk Management, Metrics and Targets.

See more in our Corporate Sustainability Report, p. 53, 162

In response to challenges and potential risks, the Group builds a long-term strategy, ensuring a sustainable transition, while targeting a net zero future.

Sustainability strategy

MOTOR OIL Group has developed an effective strategy, to support a sustainable development in accordance with the European Green Deal, the Paris agreement and the UN Sustainable Development Goals. The Group’s sustainability strategy is aiming to satisfy investors, who want to better understand the risks and opportunities that ESG issues pose to their investments. The Group implements a holistic approach to sustainable development, with specific target, goals, action plans, goal alignments and related impacts.

Our Long-Term Goals, guide our strategic priorities

Goals

Priorities

· Facilitate Energy Transition

· Secure Energy Supply

· Drive Sustainable Shareholder Returns

Committed to Acting Responsibly
Enhance Energy Efficiency
Provide Energy and Mobility Solutions to Customers
Accelerate Renewable Energy Growth
Invest in New Technologies

Our sustainability strategy addresses our material ESG issues related to our Group activities and sustainable development, aiming to a continuous improvement of our ESG performance. The Group’s Sustainability Strategy incorporates the following areas:

Decarbonization and energy transition
Stakeholder engagement & Materiality
ESG impact assessment and Taxonomy alignment
ESG Policies & Procedures
Corporate Governance
Targets and KPIs monitoring
ESG/Climate risk management
Transparency, Reporting and Communication

Our Energy Transition Strategic Plan

MOTOR OIL Group recognizes the need to get to net zero and builds a holistic energy transition strategy with a diversify multi energy portfolio based on four pillars.

Refinery continuous maintenance and improvement

In addition to investing in new and more advanced products, significant refinery projects have been implemented to improve energy efficiency and electricity autonomy. MOTOR OIL is one of the largest industrial units that installs batteries in its facilities to support energy needs. Moreover, projects related to digital transformation are implemented at the refinery and other activities of the Company, while projects related to decarbonization such as carbon capture and storage are under assessment.

e-Mobility and Retail

E-mobility constitutes a top priority for MOTOR OIL Group which aims to be at the forefront of the electric vehicle rollout in Greece by utilizing an integrated solution across the value chain in EV charging. In the light of it, the Group has been developing partnerships and equipping its retail gas stations with EV charging points in order to take advantage of this expanding market segment. Aiming to enhance customer experience, the Group designed the “gas station of the future”, a project concept, which among other things, will include advanced nonfuel services, low carbon fuels and hydrogen.

Non-Fuel Retail Initiatives:

- Convenience retail
- Care express
- Coffee
- Lubricants
- Car wash & Detailing
- Delivery
- EV Chargers
- Loyalty
- e-shop
- IT projects
- Smart lockers
- E-pass

Renewable Energy

The Group is becoming significant player in the RES market. Growing demand projections, improvements in technology, cost reduction in renewable energy projects and decommissioning of conventional generation units, such as lignite, will significantly increase the requirement for additional renewable energy capacity, batteries and storage facilities. The Group aims to continue building its power generation capacity and investing in renewable projects to be in position to capture such projected increased demand.

Alternative fuels & Circular Economy

The Group is working to enhance its value proposition by expanding its product offering and manufacturing processes into the area of alternative fuel sources, including biofuel and Hydrogen. Following acquisition activities, Motor Oil Group is paving the way in investing and operating in renewable and alternative fuels sector and circular economy through the utilization of bio-based products, and waste products to produce energy and more environmentally friendly fuels. In the field of natural gas and while the commercial activity continues, the Group examines the construction of a floating storage and regasification unit (FSRU), aiming at supporting the Greek natural gas network. The Group is also significantly active in the field of circular economy and waste management; its subsidiary LPC operates the largest and most advanced lubricants and regeneration plant in Europe.

Business Model

See more in our Corporate Sustainability Report, p. 23, 28-31

EU taxonomy alignment

While a percentage of Group’s activities and investments is already eligible and aligned with EU Taxonomy, the Group aims at further increasing those activities and investments in the future. Taxonomy eligible activities for the Group are mainly considered: a. Electricity generation using solar photovoltaic technology, b. Electricity generation from wind power. Following the latest Taxonomy Complementary Climate Delegated Act on climate change mitigation and adaptation covering certain gas and nuclear activities, the Group considered certain gas related activities: a. Electricity generation from fossil gaseous fuels, b. High-efficiency co-generation of heat/cool and power from fossil gaseous fuels, c. Production of heat/cool from fossil gaseous fuels in an efficient district heating and cooling system. The Group monitors closely any changes might occur in the EU Taxonomy since the legislation is still under development. The Group is committed to implementing best practices in sustainability and to regularly review its ESG.

In 2021, the Group’s Sustainable Development Policy was communicated to the Audit Committee. Particularly, information about the following actions: (a) The assessment of the sustainable development risks was integrated into the risk management system; (b) A 6-member strong Sustainability Committee was created, comprised of five (5) Board members and the General Manager of the Refinery; (c) The annual Sustainability Report was prepared by the ESG, Sustainability & Climate Change Unit and was audited by a third party agency; and (d) The Company’s Sustainability Committee approved the Sustainable Development Policy.

Sustainability initiatives

European Green Deal
Paris agreement
UN Sustainable Development Goals

Also, the Group responds to all ESG requests and various independent assessments from stakeholders and ESG rating agencies.

MSCI
S&P Global Rating
ISS ESG
SUSTAINALYTICS
FTSE4Good
Athens Stock Exchange (the “ATHEX”)
Ecovadis

Our Corporate Sustainability Report 2021 is published on Motor Oil’s website ESG και Βιωσιμότητα – Motor Oil (moh.gr), based on the following reporting standards:

GRI
SASB
CDP
TCFD
UN Global Compact
Greek Sustainability Code
Athens Stock Exchange (the “ATHEX”) ESG Reporting Guide
AA1000AP (2018)

See more in our Corporate Sustainability Report, p. 184, 187-232 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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2. Materiality

ADMINISTRATIVE PRACTICES

Analyzing and properly addressing all the material ESG issues in relation to the Group’s activities through the lens of sustainable development is an important tool towards the continuous improvement of our ESG performance.

The Group proceeds frequently with a materiality exercise (typically on bi-annual basis), while this report is based on the materiality assessment performed during the previous year. The assessment was performed with a strong participation of employees, consumers, shareholders & investors, business partners & vendors, local communities, government & regulatory authorities, media, industry associations, and other stakeholders, in order to define the most significant ESG issues related to its operations.

The Group has assigned the ESG priorities by engaging the management, the Group’s Sustainability Working Team and the Sustainability Committee. The results of the materiality assessment influence Group’s sustainability approach, strategy, as well as the reporting process. The materiality assessment (performed in 2020) took under consideration both the impact and the risk perspectives (GRI Standards and SASB standards/Oil & Gas - Refining and Marketing Standard).

More specifically, the process that was applied in order to define the Group’s material issues, engaged 400 representatives from the Reporting Group’s key stakeholder groups through a materiality questionnaire, which included 23 issues categorized into three basic pillars: Environmental, Social & Labour, Economic, Governance and other issues. The issues mentioned in the materiality questionnaire were specified by reviewing peers’ practices, while taking into account issues of importance for the industry, as well as issues that were considered crucial by the Group’s management. Reporting Group’s stakeholders were asked to rate the level of materiality of the aforementioned issues for the Group, through the completion of the materiality questionnaire. Following the evaluation of the issues by the Reporting Group’s management and stakeholders, 17 out of 23 issues were identified as material. The Group proceeded with a materiality reassessment as part of the preparation of this report and no change in material issues list occurred.

The Group’s material issues are categorized into the following three categories:

Environmental,
Social & Labour,
Economic, Governance and other issues, while the top 17 of them with the greatest importance for the Group and its stakeholders are those in the upper right corner.

See more in our Corporate Sustainability Report, p. 233-234

Decarbonization and energy transition
Stakeholder engagement & Materiality
ESG impact assessment and Taxonomy alignment
ESG Policies & Procedures
Corporate Governance
Targets and KPIs monitoring
ESG/Climate risk management
Transparency, Reporting and Communication

We are at the final planning stage for the construction of the Floating Storage and Regasification Unit (FSRU). Dioriga Gas will significantly enhance the security of Greek and European supply, consolidating Greece as an energy hub in the wider region. We are developing a state-of-the-art natural gas-fired Combined Cycle Gas Turbine Power plant, in cooperation with GEK TERNA, in the Industrial Area of Komotini. We are committed to create a large portfolio of Renewable Energy Sources. We are systematically building the program for production and provision of hydrogen with a low or zero carbon footprint, which will enter our lives within the next five years. Having established the largest network of electric car chargers in Greece, we are now in the process of adding 2,000 additional charging stations. We are implementing innovative solutions and digitising our operations and applications, starting from the refinery and extending to every area of our services and business activities. We are targeting more operations in the field of circular economy. LPC, our subsidiary, already operates one of the largest and most technologically advanced lubricant regeneration refineries in Europe. At the same time, we are developing plans in order to become more active in the collection, treatment and utilization of waste from various activities. From the outset our core focus has always been anthropocentric. Our actions always encompass our employees and their safety, local communities and their empowerment, the financially and socially vulnerable. We are committed to continuously endorsing the ten principles of the UN Global Compact and embedding them into our business, strategy and operations.

The Board and the management play a significant role in promoting the long-term success of the business strategy while considering climate related risks which can have an impact on the operations and shareholders’ value. The Group has established a sustainability committee with the objective to approve and oversee the Group’s Sustainable Development Policy and Strategy including the Environmental, Social and Governance aspects that could affect the overall strategy, investment plan, risk management, sales performance, M&A or other major capital expenditures, as well as to monitor performance against set targets and decide on corrective actions in relation to the opportunities or risks that arise.

Risks and Opportunities due to Climate Change

The transition to net zero is a big challenge, however, can be a massive opportunity for growth, employment, technological advancement and social inclusion. The Group constantly examines economically and technological feasible transition opportunities as the cost of the low carbon technologies declines allowing decarbonization to proceed at a faster pace. In order to benefit fully from all the opportunities emerged from the energy transition and the climate change, the group applies two different business models: First by making direct investments to clean energy, EV charging, energy efficiency, carbon storage and recycle technologies and second by acquiring assets and majority stakes from companies with great experience in the renewable and circular economy area. On the risk side the transition will require increase in capital. Significantly more financing will be needed. This could come from both traditional financial instruments and products such as green bonds. The use of voluntary carbon credits could also play a role in financing the Group’s transition. Investing in R& D can also help bring down technology costs. The Group also anticipates future competitive dynamics and adjusting the business portfolio to identify new areas of opportunity from a net-zero economy.

Moreover, every subsidiary company considers risks and opportunities to regulations and stakeholders’ requirements and plans accordingly. For example, in 2021 Coral and Avin Oil invested in EV chargers and in various nonfuel retail initiatives. Coral Gas developed new businesses in LNG & CNG fuels market. These new gas fuels are both environmentally beneficial both in the B2B (industry) segment, as well as in the automotive sector. The EU is pushing the member states to adopt policies referring to the lubricant oil State Public Tenders stating that at least 25% of the total quantity should consist of re-refined lubricant oil, thus creating a great opportunity for LPC. Customers & Users switch to lower carbon footprint products due to levies and/or pure environmental consciousness, thus LPC has a great opportunity to provide the best relevant product offerings due to its re-refining process which significantly reduces the carbon impact of the production of the raw material, the lubricant oil. Synthetic Low Viscosity products providing lower fuel consumption, plus longer drain intervals, set a stage in which LPC can contribute and become part of this premium priced segment. Due to high Volumes, lubricant oils create a significant amount of packaging waste affecting GHG emissions, although most of it is recyclable. For LPC this is a high priority matter and it therefore treats more as an opportunity rather than a risk, working intensively so that our brands are in place to bring significant innovation to the marketplace. Another risk could be the decrease of the collection of waste lube oils collected. It is a long-run threat which might lead to reorganization of waste lube oil collection systems world-wide. All business consequences due to climate change are to be researched, analyzed and gradually embodied in the Group’s future business model.

The Group has developed a Climate Risk Management framework as part of an Integrated Risk management model which includes policies, procedures, and tools to identify, assess and manage climate related risks. The framework is designed based on TCFD and SASB guidelines for the Oil & Gas sector and applies to investments, operations, and supply chain activities.

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3. Objectives

ADMINISTRATIVE PRACTICES

At Motor Oil Group, we remained staunchly committed to achieving a gradual transition to the new energy environment, setting dynamic goals:

We are investing in large-scale projects, with a clear vision and responsibility.
We are driving the transition to new forms of energy.
We are expanding in the field of circular economy.

Operating with environmental and social sensitivity, we are furthering our investment and development plan.

The Group implements a holistic approach to sustainable development, with specific target, goals, action plans, goal alignments and related impacts.

Our Long-Term Goals...

Facilitate Energy Transition
Secure Energy Supply
Drive Sustainable Shareholder Returns

Our sustainability strategy addresses our material ESG issues related to our Group activities and sustainable development, aiming to a continuous improvement of our ESG performance.

Goals, Targets and Progress

Motor Oil Group has responsibly adopted a series of short, medium and long-term ESG goals and monitors progress on an annual basis.

The Group has established a sustainability committee with the objective to approve and oversee the Group’s Sustainable Development Policy and Strategy including the Environmental, Social and Governance aspects that could affect the overall strategy, investment plan, risk management, sales performance, M&A or other major capital expenditures, as well as to monitor performance against set targets and decide on corrective actions in relation to the opportunities or risks that arise.

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4. Management of Value Chain

ADMINISTRATIVE PRACTICES

Motor Oil Group is a 50-year-old energy group with 92 companies covering a broad range of refining, distribution and other activities in the wider energy sector spectrum. The Group is engaged in the sale of petroleum products both in the wholesale market and directly to final consumers through Coral, Coral Gas and Avin Oil. It is also active in the production and sale of lubricants through LPC; the sale of electricity and natural gas through NRG; the electricity production from wind and solar energy through MORE; the supply of aviation fuel and the provision of storage and aircraft refuel services through OFC.

1 Oil refinery
92 companies
~1500 Fuel Stations in Greece and abroad
13 distribution facilities
2,990 employees
1 lubricants’ plant Europe’s largest & most advanced regeneration plant
Exports to more than 70 countries
65 PV Assets
15 Wind Farms
Presence in 8 countries

Value creation

MOTOR OIL Group, during all the years of its operation as an oil refinery and oil products marketing company, functions with a strong sense of corporate responsibility by aiming at sustainable profitability and development, in a socially responsible manner.

Value Chain

Motor Oil’s operations expand across an extensive value chain network and contributes towards strengthening our economy at national level and beyond.

Together with our stakeholders, we succeed at creating value by distributing our social product throughout our area of influence for sustainable development.

The Group implements a holistic approach to sustainable development, with specific target, goals, action plans, goal alignments and related impacts.

Sustainable Supply Chain

Constant aim of the Group is to implement the principles of sustainable development not just in the context of its operation, but also in the sphere of its influence, including its partners and suppliers. A sustainable supply chain not only minimizes social and environmental risks, but also serves as an example of values and success for the industry and the community. For that reason, MOTOR OIL Group assesses its potential suppliers not solely based on the cost, quality, delivery, and their economic viability, but also on QHSSE and ESG criteria.

The Group collaborates with a large number of suppliers both locally and at international level. The main categories of suppliers that the company engages with, fall under the following broad categories: raw materials, contractors, service providers, equipment and infrastructure.

Strong suppliers’ partnerships are very crucial for our sustainable development. We recognize the importance of working with suppliers and contractors that respect the same values as we do. In that context, suppliers are asked to complete specific questionnaires/forms detailing their ability to safeguard the quality of products and services provided, as well as the environmental impact of their activities and the health and safety systems they follow. We expect our suppliers to follow similar ESG objectives across their activities and operations to maximize impact and meet our sustainability goals.

Stakeholder

How we engage

Key issues of interest

How we respond

Business Partners and Vendors

10,193 suppliers

• Collaborating closely with our contractors and suppliers to ensure high level of safety, efficiency and quality

• Collecting information through survey regarding ESG material issues

• Conducting Internal and External audits

•Health & Safety

•GHG reduction

• Business ethics

• Human rights

•Training programs on health, safety and environmental protection issues •Supplier Code of Conduct information guide

See more in our Corporate Sustainability Report, p. 15-16, 24, 28, 35-37, 167-168 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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PROCEDURES

5. Responsibility

ADMINISTRATIVE PRACTICES

Corporate Governance

The BoD

The Board of Directors is responsible for determining the values and the strategic orientation of the company, as well as the continuous monitoring of their compliance. At the same time, it remains responsible for the approval of the strategy and the business plan of the company, as well as for the continuous monitoring of their implementation. The Board of Directors shall also regularly review the opportunities and risks in relation to the defined strategy, as well as the relevant measures taken to address them.

The Board of Directors operates efficiently to contribute to the achievement of the following:

Creating an effective and productive relationship between key shareholders and stakeholders 2.Defining strategic priorities, policies and committees

3.Fostering values and ethics, quality improvement, innovation and sustainable development

Committees and Policies

The Group’s Sustainability Committee approves the long term targets and sustainability agenda and regularly reviews the ESG performance. It consists of five board members (two women and three men) with executive, independent and non-executive identities and one member from the management.

MOTOR OIL Group aims to strengthen its performance on ESG issues, thus has developed and implemented several policies covering a wide range of ESG issues. Additionally, the Group appointed a Compliance Officer to ensure corporate compliance with laws, regulations and internal policies and evaluate business activities to assess compliance risk while cultivating a compliance culture within the company. Moreover, the role covers the development and revision of policies, and procedures and provides respective recommendations to the BoD and relevant Committees.

Climate Risk Governance

See more in our Corporate Sustainability Report, p. 50, 156-160 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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6. Rules & Processes

ADMINISTRATIVE PRACTICES

MOTOR OIL Group’s management and control are based in modern and commonly accepted principles of good corporate governance, as prescribed by legislation and the relevant regulations, as well as other international practices and auditing standards. Corporate governance determines the Group’s daily operations on a variety of issues such as:

the Board of Directors’ structure
the equal treatment and protection of the interests and rights of all shareholders
the compliance with legal and regulatory provisions
the transparency in the decision-making process
the reliability and adequacy of all disseminated information, regarding the Group’s strategy and financial results, or its financial transactions
the management of personnel and remuneration matters
the identification, reporting and control of all inherent risks

More information about our Corporate Governance Management approach can be found in: https://www.moh.gr/en/investor-relations/corporate-governance/introduction/.

Internal Audit, Risk Management & Compliance

The company’s control environment includes all the structures, policies and procedures that provide the basis for the development of an effective Internal Control System (ICS) for financial and non-financial information, as it provides the framework and structure for achieving the fundamental objectives of the ICS. Our risk management system and policy provide a consistent and clear framework for managing and reporting risks. The Board of Directors performs on a regular basis a review of the way we identify, evaluate and manage risks. We have developed a risk management framework by embedding policies, procedures, standards, and codes of conduct into a robust control system. Motor Oil Group’s risk team analyses the group’s risk profile and supervises the risk management system. The Group’s Internal Audit Unit submits independent audit report to the Board and Audit Committee and to the C level Management on the operability of the Group’s internal control system and its responsiveness to the risks that are significant to the Motor Oil Group. The Group objective is to also monitor and ensure corporate compliance with laws, regulations and internal policies, to evaluate business activities and assess compliance risk through a regulatory compliance framework.

Data Security

The Motor Oil Group developed a dedicated Protection of Personal and Privacy policy covering how to handle, collect, use, disclose and process personal data of employees and customers, as well as a Data Privacy Policy describing the operational framework of the Group for planning and conducting audits on data security based on international standards (ISO 27001) and best practices.

Tax Governance

As part of its commitment to better sustainability performance, Motor Oil Group embraces responsible tax policies and practices, which provide its commitment to ensuring that:

Comply with all the tax laws and regulations in the countries in which the company operates.
The overall strategy and objectives of the wider group comply with the tax and custom legislation where the Group operates, i.e. primarily in Greece, where the parent company has its registered seat, as well to other jurisdictions where the Group creates value.
The Group’s tax policy and strategy are overseen and approved by the parent company’s management (Board of Directors), which is responsible for putting tax and audit mechanisms in place guaranteeing adherence with laws, regulations, requirements governing international and local tax and customs legislation.
The Group comply with their tax, audit and reporting obligations and are committed in paying the right amount of tax at the right time in Greece and in jurisdictions where they operate.
All transactions have a business purpose or commercial rational and fit into the wider group tax strategy. The Group is not engaged in aggressive tax planning schemes and does not seek to apply abusive tax practices.
The Group act with integrity and maintain transparent, open and cooperative relationships with the tax authorities of all jurisdictions where they operate, establishing the company’s reputation as a good-faith taxpayer.
The Group utilize tax incentives offered by the jurisdictions where they operate with transparency and consistency and in line with the applicable legal framework.
Advice is sought by external independent advisors where necessary and appropriate for ensuring tax and custom compliance with applicable legislation and securing staying update on changes and recement developments in the Greek and international tax legislation.
The Group participate and contribute by giving constructive input in public committees to support the development of effective tax legislation and administration.

Transparency and Business Ethics

The Group’s vision, ethics and corporate values comprise the cornerstones of its business activity and function. MOTOR OIL Group operates with integrity and respect towards laws and regulations, while it has adopted ethical business practices and corporate governance principles. As a result, our Group’s human resources share the very same values and qualities and enjoy a safe and rewarding workplace, where trust is a common denominator in every relation. Furthermore, the Group maintains honest relationships with all interested parties, characterized by fair treatment, respect, dignity and open communication. In that context, all MOTOR OIL Group’s policies, practices, strategies and operations across its entire value chain are governed by transparency and are communicated explicitly to all interested parties. The Group aims at achieving its business goals effectively by demonstrating strict professionalism, maximizing value for its shareholders and efficiently serving the needs of its customers. Lastly, as MOTOR OIL Group has embraced socially responsible attitude towards its operations, it meticulously assesses the environmental and social impact of its business activities, sets targets and applies standards to continuously improve its performance and to enhance the local communities.

Whistleblowing and Grievance Mechanism

The Group adopted a Whistleblowing policy to strengthen the values of corporate integrity, transparency and accountability, to apply the appropriate corrective measures (strengthen the internal control system) and to protect the employees and the company`s interests. The Group encourages the submission of confidential or anonymous reports through the existing reporting channels about illegal activities that may take place in the organization. The management and investigation of these reports is conducted objectively, independently and with respect to all implicated parties. The Group assures that those who report shall be protected against retaliation and that the personal data of all parties involved are protected.

Product Quality and Customer Health & Safety

MOTOR OIL Group is strongly committed to providing both safe and high-quality products & services, making this a material issue, and therefore a fundamental element of its existence and strategy. As a result, the Group identifies risks and deals with their impacts across all of its value chain affected. The Group’s quality policy is summed up in two key principles, to which both management and employees are fully committed:

To produce and sell products that satisfy its customers, always taking into account all stakeholders’ interests.
To explore and evaluate customers’ needs, in order to produce high-quality products accordingly. Product quality and customer health & safety are top priorities of MOTOR OIL Group.

It should be noted that Motor Oil Group carefully assesses all the risks associated with production and explicitly designs its response plans to potential emergencies, in order to timely and effectively provide all the necessary mitigation actions. Concerning the health & safety regulations that should be met when processing the products, the flammable products of the Group require continuous and systematic control at all stages of their production (from refinery to facilities and finally, to the end customers). More explicitly, with the support of specialized laboratories and purpose-designed quality control mobile units (vans), both quality and quantity checks on the products, as well as inspections in the retail stations are taking place, not only for the product quality to be ensured, but also for customers’ health and safety.

Quality Customer Service

Our approach In MOTOR OIL Group, we strive to serve the needs of our customers and provide them with a unique customer service experience. MOTOR OIL’s refinery has established an assessment process of the customer service provided, in order to promptly identify any wrong acts and consequently, improve its performance and ensure clients’ satisfaction. Under this framework, the Group:

Conducts quantitative & qualitative customer satisfaction surveys
Identifies and evaluates its strengths and weaknesses
Manages the identified flaws
Improves its tactics and performance This whole process aims to the minimization of complaints relevant to our products.

Privacy Protection

MOTOR OIL Group is deeply committed to respect and protect the privacy of all interested parties, as privacy protection is essential for the smooth collaboration and for developing mutual respect. In that context, the Group complies with all regulations that are relevant to the subject. MOTOR OIL Group is bound to GDPR requirements, hence, obliged to protect data of employees and consumers, plus it has in place internal controls and regulations for that purpose. LPC, for business interactions with Single Member legal entities or single persons, before proceeding to any input of data in LPC’s ERP system & collection of Credit data, a signed Customer confirmation from the respective party needs to be provided to the Accounting team. NRG has in place specific policies for external colleagues regarding the processing of personal data, such as the Confidentiality acts with employees, Data Processing Acts with all data processors and Privacy Policy, plus that internal regulations are followed concerning customer data.

In 2021 no incidents concerning breaches of customer or employee privacy have been identified across Motor Oil Group.

Security and Emergency Preparedness & Response

Security and Emergency preparedness & response are an important issue for us as an oil and gas company. Our various functions demand readiness and immediate response to emergencies. To this extend, we ensure security, continuity of operations and to effectively limit the potential social consequences for our employees, local communities, the environment, our reputation, as well as our financial results across MOTOR OIL Group. As a result, we have taken all necessary measures to ensure maximum security and emergency preparedness & response and comply fully to the provisions of the relevant national and European legislation and regulations. For instance, MOTOR OIL complies with the Seveso-III-Directive (2012/18/EU), which aims at the prevention of major accidents involving dangerous substances. However, as accidents may nevertheless occur, it also considers limiting the consequences of such accidents not only for human health but also for the environment. According to the Directive, operators are obliged to take all necessary measures to prevent major accidents and to limit their consequences for human health and the environment. The requirements include:

Notification of all concerned establishments;
Deploying a major accident prevention policy;
Producing a safety report for upper tier establishments;
Producing internal emergency plans for upper tier establishments;
Providing information in case of accidents. Moreover, the Group implements a Business Continuity Management System (BCMS) to manage disruptions due to unexpected events, extraordinary events and /or crises, to ensure the resilience of processes, resources & infrastructure and to achieve timely recovery of procedures, resources & infrastructure.
Security & Resilience

To demonstrate and improve security in operations, MOTOR OIL designed a framework (certified in accordance with ISO 18788) for establishing, implementing, operating, monitoring, reviewing, maintaining and improving a Security Operations Management System. The framework aims to safeguard the respect for human rights, the national and international laws and the fundamental freedoms by meeting the Guiding Principles on Business and Human Rights of the United Nations “Protect, Respect and Remedy” framework policy 2011. In 2021, the Group started the design of a business continuity management system (BCMS) that develops business continuity appropriate to the amount and type of impact that the Group may or may not accept following a disruption. The purpose of a BCMS is to prepare for, provide and maintain controls and capabilities for managing the group’s overall ability to continue to operate during disruptions. The system fulfils the requirements of the ISO 22301 in order to: a) implement, maintain and improve a BCMS; b) ensure conformity with stated business continuity policy; c) continue to deliver products and services at an acceptable predefined capacity during a disruption; d) enhance business resilience through the effective application of the BCMS.

Environment

Our Energy Management Policy

We implement a certified environmental and energy management system. Key component in successfully delivering the sought results is the implementation of a certified environmental and energy management system in accordance with ISO 14001 and ISO 50001. Furthermore, Motor Oil is certified by the voluntary scheme 2BS, which provides accurate and reliable information regarding the origin of the biomass and biofuel utilized.

Environmental Risk Management

The Group implements an Environmental Risk Management system in order to identify and manage environmental risks related to its activities. Disclosing the risks associated with MOTOR OIL Group’s management of material issues, offers an insight into the presence of potential problems, opening the way for solutions. The environmental risks identified below are managed in the best possible manner and are indicative of the attention MOTOR OIL Group is giving to eliminate any negative effects its operation may have on the environment through the selected material issues.

Environmental compliance

The Group’s legal department is responsible for the alignment with the applicable legal requirements aiming to achieve the goal of “Zero fines”. To achieve the goals set, cooperation between different departments is required, and compliance is achieved with the proper monitoring of the amendments in the legislations and timely notification of those that are responsible to take necessary action. During the reporting year, no fines were imposed on the Group regarding environmental violations or other inconsistencies with respect to the environmental legislation.

H&S

Hazard Identification, Risk Assessment, and Incident Investigation

Frequent hazard identification, the assessment and control of risks as well as the thorough investigation of incidents are key elements of the Reporting Group’s QHSSE management system and performance. Hazard identification involves the identification of potential incidents (not just actual incidents or near misses) and their reporting, whilst incident reporting is mandatory and fully encouraged. That is an important process of the QHSSE system encouraging all staff, as well as contractors and business partners, to stay alert and report anything that could be a potential hazard. The QHSSE management system has a specific procedure in place that enables potential issues to be reported by employees and contractors through a digital tracking tool, allowing for supervisors in charge and QHSSE internal advisors to track reports for potential issues. In cases where a potential issue is considered significant, or an incident/near miss happens, an in-depth investigation process is being initiated. Subject matter experts and QHSSE team advisors investigate the place where the incident happened, within one month. Employees reporting potential incidents are positively contributing to the Group’s QHSSE performance and receive QHSSE awards as a recognition of their efforts.

Working with our Business Partners and Suppliers on Health and Safety Impacts

The Reporting Group’s Health and Safety rules are extended also to business partners and suppliers. There is continuous collaboration and constant improvement with actions that include:

Safety observations, whereby contractor companies receive feedback on a daily basis, with a view to monitor their performance on safety issues, reward good practice, and immediately implement corrective actions.
Workshops aimed at raising contractor awareness and actively involve them in safety issues.
Meetings prior to critical projects, whereby all contractors’ safety engineers and technicians participate in order to receive information on safety issues.

The QHSSE Management system and policies apply to the Reporting Groups’ day-to-day operations and the entire Supply Chain including suppliers, contractors, or business partners. Specifically, the QHSSE policies are part of the business contracts along with the requirement of ISO 9001, 14001 and ISO 4500: 2018 certifications and training/drills. There is frequent cooperation with Health and Safety experts for regular audits on business partners’ facilities and premises. Furthermore, all our products and materials are accompanied by Material Safety Data Sheets, to ensure that our staff, contractors, and business partners are aware of their validity.

Road safety

Ensuring enhanced road safety is a matter of high priority for us, since million liters of liquid fuels and tones of liquid gas (LPG) are transported across Greece and the Balkans on daily basis. Every year our drivers cover more than 28 million kilometers to transport fuels within Greece and abroad, with no accidents or injuries concerning the drivers or any other people being reported. During 2021, training programs were also delivered to numerous drivers of privately and publicly owned vehicles on subjects relevant to their activities. Fuels are classified as dangerous goods, therefore in order to be safely transported measures need to be taken at three levels/tiers: • Ensuring technical adequacy of the transporting equipment, i.e., the tank trucks. • Establishing strict procedures and continuous monitoring of their implementation. • Training of the drivers and keeping them updated on a continual basis.

Management Systems

We implement a series of certified management systems and international, such as:

ISO9001:2015
ISO14001:2015
ISO50001
ISO14064-1
ISO45001:2018
ISO27001
EMAS
ISO18788

The Group is committed to implementing best practices in sustainability and to regularly review its ESG performance. The Group is developing a centralized ESG management system to streamline the data collection process with a Structured, Systematic, Trustful and Auditable monitoring of our performance and targets. The implementation will secure multiple benefits in ESG KPIs reporting such as time reduction, efficiency in collection and calculation, compliance, effective monitoring, transparency and verification. Moreover, the ESG platform will play a catalytic role in the monitoring of climate risk analysis for the Group’s decarbonization and energy transition strategy.

See more in our Corporate Sustainability Report, p. 33, 55, 76, 114, 125, 127, 157, 162, 164-166, 169 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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PERFORMANCE INDICATORS

SRS-102-16: Αξίες, αρχές, πρότυπα και κανόνες συμπεριφοράς ενός Οργανισμού.

Business Principles

We operate based on our principles and values, by maintaining the highest standards of business ethics.

The vision of MOTOR OIL Group is to become a leading sustainable energy corporation in Greece and the wider region.

The business objectives of MOTOR OIL Group are:

Conducting sustainable business operations to ensure long-term profitability and continued growth for the benefit of all stakeholders.
Offer cleaner and high-quality energy products.
Contributing to sustainable development by integrating Economic, Environmental, and Social considerations into business decision – making.

Motor Oil Group embraces the following values and business principles as the foundation of the Group’s Code of Conduct:

Professionalism & Effectiveness

We want to achieve our business goals effectively, in order to maximize value for our shareholders. We focus on our trustworthiness, capable workforce, quality products and excellent services to serve the needs of our customers.

Integrity & Respect

Motor Oil Group companies conduct their activities with honesty, integrity and fairness and expect the some standards from all their partners and suppliers.

Business Ethics

Transparency and ethics, anti-corruption and anti-competitive practices are embedded in our corporate governance, and we have zero tolerance in any unethical incident.

Health & Safety
Health & Safety is of utmost importance of the Group. Our aim is to provide a safe and fair working environment, by setting a permanent objective of zero accidents and promoting employee’s wellbeing. Positive Impact

We assess the Environmental and Social impact of our business activities carefully, set targets and standards to achieve continuous performance improvement and we ensure that our actions benefit our country and the local communities.

Code of Conduct

Corporate Governance Code

Corporate governance involves a set of relationships among a company’s management, its shareholders, employees and other stakeholders; and aims to create, sustain and develop strong and competitive companies. Motor Oil Group compiled its Corporate Governance Statement in accordance with the provisions of article 152 of the Law 4548/2018 (Government Gazette A’ 104/ 13.06. 2018) and of articles 9, 14 and 18 of the Law 4706/2020 (Government Gazette A’ 136/17.07.2020). The Company is subject to the Hellenic Corporate Governance Code which was compiled and published by the Hellenic Corporate Governance Council in June 2021, and is available on the corporate website: https://www.moh.gr/en/investor-relations/corporate-governance/ policies/ .

Policies

In 2021 the Group further developed and enhanced policies regarding certain areas such as:

Nomination and remuneration
Compliance,
Risk management
Whistleblowing
Conflict of interest
Sustainability
Training and performance review
Code of Conducts and Corporate Governance,
Anti-bribery and anticorruption
Human Rights
Anti-competition policy,
Sanctions and export controls.

All the policies are included in the internal operating rules, which describe how Motor Oil Group is managed, the responsibilities of the Board members, the structure and the objective of certain key Divisions, the procedures of recruitment and evaluation of the executives. The current version of the Internal Operating Rules was approved by the board and is compliant with the Law 4706/2020.

See more in our Corporate Sustainability Report, p. 21, 135, 158, 161 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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7. Monitoring

ADMINISTRATIVE PRACTICES

The Group aims to provide value to all stakeholders and minimize the actual or potential negative impact of its activities for society and environment. Based on that, ESG impact assessments are actively carried out at the major investments, to better identify opportunities and manage issues that could cause business risks. Such assessments include sustainability impacts occurring along the entire life cycle of the Group’s products and services, i.e. during resource extraction, supply chains, production, product usage and disposal. To measure ESG impacts, the Group uses indicators derived from industry specific sustainability issues, weighted according to their importance in Groups’ sustainability goals.

Climate-related metrics

Climate-related metrics highly considered in the Group’s governance, strategy, and risk management processes and create a feedback loop over time in the same way that other key performance indicators and key risk indicators are used to inform business management processes. Climate-related metrics also help the group understand potential impacts of climate-related risks and opportunities over a specified time period, including financial impacts and operational consequences. The metrics are clear and reliable, consistent over time and forward-looking using targets, scenarios, projects planning and transition plan. Specifically, the Group includes metrics on climate-related risks associated with water, energy, land use, and waste management where relevant and applicable (see ESG table), including:

Proportion of executive management remuneration linked to climate issues.
Amount of capital expenditure, financing, or investment deployed toward climate related risks and opportunities.
GHG Emissions Absolute Scope 1, Scope 2, and Scope 3; emissions intensity.
Total fresh water withdrawn; total fresh water consumed.
Proportion of revenue, assets, or other business activities aligned with climate-related opportunities.
Internal carbon pricing.

Also, the company’s control environment includes all the structures, policies and procedures that provide the basis for the development of an effective Internal Control System (ICS) for financial and non-financial information, as it provides the framework and structure for achieving the fundamental objectives of the ICS. Also, the company follows the ISO 27001 international standard concerning data security issues. To demonstrate and improve security in operations, MOTOR OIL designed a framework (certified in accordance with ISO 18788) for establishing, implementing, operating, monitoring, reviewing, maintaining and improving a Security Operations Management System. In 2021, the Group started the design of a business continuity system of the ISO 22301, appropriate to the amount and type of impact that the Group may or may not accept following a disruption.

The MOTOR OIL Group understands the importance of reporting in a transparent manner and publishes annually a very comprehensive report with independent limited assurance in accordance with the international standards, maintaining a comprehensive system of quality control including documented policies and procedures regarding compliance with ethical, professional standards, and applicable legal and regulatory requirements.

Our Sustainability Report 2021 presents Motor Oil Group’s twentieth such record of disclosing information regarding our sustainability performance at an annual reporting cycle. Its purpose is to communicate to all our stakeholders our activities and performance regarding environmental, social and governance issues.

This Report has been prepared in accordance with the GRI Standards: Core option. Furthermore, additional GRI Standards disclosures have been also included beyond the minimum required for core option, as well as the majority of the GRI 11 Oil & Gas Sector Standards requirements. Moreover, information from other standards and guidelines such as the SASB standards for the oil & gas industry, the TCFD recommendations, the Greek Sustainability Code and the Athens Stock Exchange (the “ATHEX”) ESG Reporting Guide have also been taken into consideration. The latter is a guide developed by the Athens Stock Exchange to promote and enhance the ESG reporting practices of Greek-listed companies (https:// www.athexgroup.gr/esg-reporting-guide). In addition, the Report adheres to the four Accountability Principles (Inclusivity, Materiality, Responsiveness, Impact) stated in AA1000AP (2018). Moreover, as our Group is an endorser of the United Nations Global Compact (UNGC), this report serves also as a Communication on Progress report regarding UNGC. Finally, Motor Oil Group has also submitted a questionnaire to the CDP (Carbon Disclosure Project) and is currently waiting for the relevant evaluation. The were no significant restatements of information from previous reporting.

See all metrics in the ESG Performance Index of our Corporate Sustainability Report, p. 187-195

Also, you can see all KPIs used to specific indexes, p. 196-232 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

We recognize the added value of external assurance of disclosures and performance indicators (KPIs) contained in our reports and believe that this process enhances the quality and accuracy of our disclosures. Consequently, this report has been audited by an external verification body, regarding the compliance with GRI “Core option” requirements only for the following companies:

Motor Oil Hellas Corinth Refineries S.A. (Motor Oil S.A. or Motor Oil)
Avin Oil Single Member S.A. (Avin Oil S.A. or Avin Oil)
Coral Single Member S.A. Oil and Chemicals Company (Coral S.A. or Coral)
Coral Commercial and Industrial Gas Company S.A (Coral Gas S.A. or Coral Gas)
L.P.C Single Member S.A. Processing & Trading of Lubricants & Petroleum Products (LPC S.A. or LPC)
NRG Supply and Trading Single Member Energy S.A (NRG S.A. or NRG)
OFC Aviation Fuel Services S.A. (OFC S.A. or OFC)

External assurance has been provided also for a set of GRI disclosures, as presented in the assurance statement and the GRI Content Index. It should be noted however that further assurance of the data is conducted in additional ways, since independent auditors provide external validation and assurance regarding the Group’s financial data (as presented in the relative Financial Statement). Finally, assurance has been provided for adherence with the requirements of AA1000AP (2018).

ESG Highlights 2021

€ 152m Environmental investments
363 MW RES capacity* added to Motor Oil’s portfolio
Granted 335,000 Guarantees of Origin (GO) to customers
100% of water used in the refinery comes from the sea
360K Tonnes of CO2 e avoidance
1 TJ / kMT energy saving in Corinth refinery
4% total energy consumed from renewable energy sources in Group subsidiaries
Innovative ultra-low carbon hydrogen technologies
Motor Oil planted 14,000 trees
0 total accidents in Retail business activities
43,696 hrs of training in 2021
€ 18m for innovation and digital investments
56% waste reused or recycled out of total solid waste production for 2021
6,223 employees and contractors trained on Health & Safety (H&S) management
139,080 MT CO2 annual savings in production
€ 3.5m spent for responding to the Covid-19 pandemic
€ 2.3m in community contributions
€ 636m social product
96% percentage of employees received performance evaluation review
MSCI rating: A

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8. Incentive and reward systems for Sustainable Development

ADMINISTRATIVE PRACTICES

MOTOR OIL has adopted a modern, fully integrated Human Resources Management System, designed to allow proper management of the Group’s human resources, coupled with continuous development of its employees. The system is driven by the Group’s principles, values, vision and strategic objectives, with particular emphasis -among others- in:

Providing a fair and competitive remuneration system linked to employee performance and consistent with prevailing market conditions.
Offering pay and benefits exceeding those provided for by law and by collective labor agreements.

Remuneration system

Having as our target to advance employee satisfaction levels, work-life balance and low employee turnover rates, we offer a competitive remuneration scheme and additional benefits.

To achieve this, we use a concise and transparent system enabling us to set, manage and review salary levels in compliance with current company and sector specific agreements. Negotiations covering collective agreements on salary adjustments are in line with sector practices that are applied at national level.

The factors determining wage levels are mainly the employee’s grade and performance, the responsibilities and accountabilities of the position held, the educational level and the seniority.

Motor Oil Group’s total expenditure on wages and benefits for its employees in 2021 amounted to 152.4 million euros. This includes pay for regular and overtime work, mandatory employer contributions to social security funds and other additional allowances over and above those laid down in either labour legislation or collective agreements. These additional, non-statutory allowances are discretionary payments to employees intended to reward productivity and acknowledge the contribution of individuals to the Group’s performance.

Volunteerism

The voluntary blood donation of motor oil group staff has become an institution, having completed more than 30 years of constant contribution. It is carried out in collaboration with the General Hospital of Corinth for the refinery and with the Special Cancer Hospital “Metaxa” for the headquarters of MOTOR OIL. The resulting blood bank covers the needs of volunteer blood donors, their close relatives, but also other fellow human beings in emergency cases. In 2021, gradually recovering from Covid-19 restrictions, we managed to collect 52 units of blood, while in total over 4,000 units have been collected over the years.

The Suitability and Evaluation of the Board

The evaluation of the suitability of the Board members is conducted annually during the nomination of the members for election by the Annual Ordinary General Assembly.

The first level of evaluation is carried out by the Remuneration & Nomination Committee. After the evaluation, the Committee briefs the Board of Directors which deals with the second level of evaluation. In case of differences of opinion, the evaluation of the suitability of the Board is assigned to external consultants. The annual evaluation of the Suitability of the Company’s Board focuses the following:

The structure, size and composition of the Board
The knowledge, skills and experience of Director as well as of the Board as a whole
Comprehensive review for the detection of possible cases of conflict of interest
Comprehensive review whether the composition of the Board meets the requirements of the Law
Governance and ESG understanding

It is pointed out that the evaluation of the Company’s Board is completed prior to the annual ordinary General Assembly of each year. The Committee members (Audit and Remuneration & Nomination) who discharge duties of Chair are responsible for organizing the evaluation of the performance and the proper functioning of their committees. The evaluation is carried out annually since the term of office of the said Committees is for one year. The performance evaluation of the Directors as well as of the Board collectively is carried out annually and consists of financial and non-financial criteria. The Chair of the Board oversees the process in collaboration with the Remuneration & Nominations Committee.

The Remuneration & Nomination Committee of the Company is comprised of three (3) non-Executive members of the Board the majority of whom are independent. It deals with issues of nominating individuals suitable to become members of the Company’s Board according to the factors and criteria determined by the Company in accordance with the Directors’ Suitability Policy approved by the General Assembly, as well as with matters related to the Remuneration Policy submitted to the General Assembly for approval. Moreover, the Committee submits to the Company Board proposals regarding the amount and the individual components of the total remuneration of the persons that fall within the scope of the Remuneration Policy, and of the Company executives.

In 2021, the Group revised the Director’s Remuneration Policy that was prepared in accordance with the provisions of the article 111 of the Law 4548/2018 and was approved for the first time by the Annual Ordinary General Assembly of the Company Shareholders of June 5th, 2019. Additionally, the Group adopted a Director’s Suitability Policy compiled in accordance with the provisions of article 3 of the Law 4706/2020 as well as the decision of the Board of Directors of the Hellenic Capital Market Commission 890-1Β- 60 / 18.09.2020.

All the policies, comprised the Nomination and remuneration policy, are included in the internal operating rules, which among other describe the procedures of the evaluation of the executives.

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PERFORMANCE INDICATORS

SRS-102-35a: Πολιτική αποδοχών

The Remuneration Policy of the Board of Directors of MOTOR OIL (HELLAS) CORINTH REFINERIES S.A. was prepared in accordance with the provisions of the article 111 of the Law 4548/2018 and was approved for the first time by the Annual Ordinary General Assembly of the Company Shareholders of June 5th, 2019. Since then, it was revised, and the current Policy was approved by the Annual Ordinary General Assembly of June 30rd, 2022. According to article 110 of the Law 4548/2018, its validity period cannot exceed four (4) years from its approval by the General Assembly.

See the Director’s Remuneration Policy

SRS-102-38: Συνολικές αποζημιώσεις ετησίως

CEO pay ratio in 2021: 6.31

Also,

Motor Oil Group’s total expenditure on wages and benefits for its employees in 2021 amounted to 152.4 million euros.
For 2021 the gender pay gap averaged 11% across the different levels of seniority.

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9. Stakeholder Engagement

ADMINISTRATIVE PRACTICES

At Motor Oil Group, engaging with our stakeholders is a constant process that fosters trust and results in mutual benefits. We consider as stakeholders all social groups, partners and/or individuals that affect or are affected by our activities. Engagement with our stakeholders is constant throughout the course of the year and is conducted through many functions of the Group mainly at Group level. Motor Oil Group companies highly value all stakeholder groups with which they engage, hence maintain excellent relationship with them through regular and constructive dialogue. The Group is also committed to reporting its performance, with the exception of potential -business related- confidential issues.

Key stakeholder	How we engage
Employees ~3,000 Group Employees	Performance evaluation, training and people development Employee engagement through Continuous listening and employee feedback and discussions Systematic support for health, safety and wellbeing through Health and Safety committee. Effective communication, dialogue and cooperation with internal stakeholders, including employees, line managers, employee’s union Employees are encouraged to submit their individual proposals for improvements in working conditions. Grievance mechanism
Consumers Served by 1500 stations	Loyalty programmes Consumer market research survey Grievance mechanism
Customers B2B Exports to over 70 countries	Long standing, close relationship with customers Organize Customers events Arrange Refinery site visits Developing joint communication initiatives Perform Satisfaction surveys
Shareholders & Investors €1.7bn total dividends (2001-2021)	Attendance at investment conferences (6-7 times per year) an Annual Analysts’ Briefing once a year 4 quarterly teleconferences with financial analysts; company’s website press releases and regulatory announcements; the Annual Financial Report and Sustainability Report one to one communication
Business Partners and Vendors 10,193 suppliers	Collaborating closely with our contractors and suppliers to ensure high level of safety, efficiency and quality Collecting information through survey regarding ESG material issues Conducting Internal and External audits
Local Communities €2.3 m community contribution	Continuous communication and interaction with local authorities Grievance mechanism
Government, regulation and Industry associations €56m income tax for 2021	Sharing views on policies, laws and regulations with officials and legislators through public consultations, meetings and stakeholder dialogue with policymakers and industry associations. The Group is in close interaction with the Government and creates revenues through the payment of taxes.
Media 15 press releases & articles issued	Ongoing communication with media sharing releases & articles Arranging interviews and media events Actively responding to media inquiries

Also, in order to define the Group’s material issues, the company engaged 400 representatives from the Reporting Group’s key stakeholder groups through a materiality questionnaire, which included 23 issues categorized into three basic pillars. Reporting Group’s stakeholders were asked to rate the level of materiality of the aforementioned issues for the Group, through the completion of the materiality questionnaire.

Stakeholder engagement is a very important tool through which potential risks and opportunities can be identified as far as Biodiversity and Ecosystem Services is concerned. Moreover, stakeholders can fully comprehend the company’s efforts to meet their expectations.

See more in our Corporate Sustainability Report, p. 34-37 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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PERFORMANCE INDICATORS

SRS-102-44: Σημαντικά θέματα και προβληματισμοί που προέκυψαν.

Key stakeholder	Key issues of interest	How we respond
Employees ~3,000 Group Employees	Energy transition, Sustainability impact and efforts Climate commitments, Health & safety Wellbeing, upskilling & development Business ethics Recognition and incentives Decision making Social responsibility	We launched a new learning and development platform We analyzed the employees’ feedback and we developed action plan to improve areas of concern Performance evaluation and compensation policy based on financial and nonfinancial criteria We strengthen our internal policies & procedures
Consumers Served by 1500 stations	Product/service quality Health & Safety Social responsibility Economic value generated and distributed Energy pricing	Analyze the results of surveys to benchmark performance and improve customer experience Active communication, responding to queries via customer support desk
Customers B2B Exports to over 70 countries	Product/service quality Experience & Reliability Health & Safety Sustainability Innovation & Research	Support with products requests Co- creating new services Encourage to reduce carbon footprint Participation invite to Groups’ sustainability actions Enhancement in customer service department
Shareholders & Investors €1.7bn total dividends (2001-2021)	Group’s decarbonization strategy and climate change, ESG rating performance, Corporate Governance Diversity ESG risks and opportunities	Setting GHG ambitious targets Developing and communicating energy transition plan Reporting risks and opportunities Improving ESG scores Align with international standards and regulations
Business Partners and Vendors 10,193 suppliers	Health & Safety GHG reduction Business ethics Human rights	Training programs on health, safety and environmental protection issues Supplier Code of Conduct information guide
Local Communities €2.3 m community contribution	Employment opportunities Health, safety and environmental concerns Investments and Impacts on local communities	Acting sustainably Identifyissues early in the Project cycle that may pose a risk to the local community; Financial and in-kind contribution to local communities Ongoing engagement and reporting Responding to local community requirements through platform
Government, regulation and Industry associations €56m income tax for 2021	Climate change Renewable fuels, RES Sustainable Finance Circular economy	Replying to public consultations and providing insights and analysis to policymakers Participating in workshops of industry associations
Media 15 press releases & articles issued	Results Announcements M&A and other investments Community contribution stories Research and development Energy pricing	Media coverage for specific events Sending Press releases and information materials Responding to media inquiries

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10. Product Responsibility and Innovation

ADMINISTRATIVE PRACTICES

The Group is working to enhance its value proposition by expanding its product offering and manufacturing processes into the area of alternative energy sources where we invest in the field of natural gas, with the construction of a CCGT plant in Komotini and we continue with the development of a floating storage and regasification unit (FSRU). Furthermore, Motor Oil Group is paving the way in investing and operating in renewable and alternative fuels sector and circular economy through the utilization of bio-based products, and waste products to produce energy and more environmentally friendly fuels. Moreover, we are planning an integrated large-scale hydrogen project while we will establish the Hellenic Hydrogen SA, (JV with PPC) with main objective the production and storage of green Hydrogen.

Product Quality and Customer Health & Safety

Our extensive experience and a high level of know-how, together with consistent quality, guarantee that customers always receive the product they need, with the appropriate quality and safety specifications. MOTOR OIL Group is strongly committed to providing both safe and high-quality products & services, making this a material issue, and therefore a fundamental element of its existence and strategy. As a result, the Group identifies risks and deals with their impacts across all of its value chain affected. The Group’s quality policy is summed up in two key principles, to which both management and employees are fully committed:

To produce and sell products that satisfy its customers, always taking into account all stakeholders’ interests.
To explore and evaluate customers’ needs, in order to produce high-quality products accordingly.

The Group adheres to several longstanding Policies, such as the Policy & Commitment in Quality, Health, Safety, Security and Environment, the Policy on Driving and the Policy on Product Stewardship to deliver a differentiated fuel products mix of highest quality, environment-friendly through lower GHG emissions due to Biofuels content, LPG, CNG, Electricity and specialized additives for improved efficiency, that are safe to be used. Additionally, the Group complies with the strictest specifications of Greek and international legislation. Innovative programs and integrated safety, quality and quantity controls are implemented at all stages of the production. The policies employed focus on: i. developing products which satisfy customers and existing specifications ii. utilizing materials and energy in an efficient way iii. audits and certificates according to international standards (ISO 9001, 14001 and 45001) iv. operating a 24x7 Customer Service to ensure customer satisfaction regarding services provided, safety and operations’ integrity.

Low carbon products

MOTOR OIL Group shows its commitment towards fighting climate change, through the development of low carbon footprint products.

The Group identifies opportunities for low carbon processes and relevant products looking at the:

utilization of renewable energy and biofuels,
charging of Electric Vehicles,
supply of sustainable fuels,
replacement of brown processes with green ones.

In 2021 LPC continued its activities towards the realization of the project for utilizing Hydrogen produced by renewable energy. An additional activity with regards to the development of low carbon products is the refinery’s ongoing design of a new process for producing/co-processing renewable diesel from biomass (e.g. used cooking oils).

Avin Oil promotes the product ‘Autogas’, a type of LPG for cars. Also, in cooperation with NRG and under the brand name incharge, Avin Oil added electric charging for electric vehicles in its service stations network. The company aims to have the energy supplied to the charging stations come from RES with low or zero carbon footprint. Coral also continued the development of the charger network at service stations, in collaboration with NRG and incharge service. In 2021, 59 new points of this service were added, reaching 69 in total, making the journey of electrification a reality. Over 30% of the chargers are DC quick chargers up to 60kw and the plan to install 30 superchargers up to 360kw has already progressed, a plan that will be implemented within 2022, making the experience of owning an electric car even better. The necessary infrastructure works have also been completed to increase the network of gas stations providing CNG (Compressed Natural Gas) from 1 gas station to 4, which will become operational within 2022. Finally, the company’s initiative to install AdBlue bulk sales units led, for 2021 alone, to the avoidance of 67,000 10-liter plastic packages. NRG offers two low carbon products to customers. In the first case, the ‘NRG Green Subscription’ enables customers who select the GREEN POWER CURRENT for their home, to actively contribute to the protection of the environment by using green energy produced 100% by Renewable Energy Sources (RES) and/ or High-Performance Heat Cogeneration Systems (CHP). This is proven by a Guarantee of Origin (GO) that NRG can grant to customers upon request. In 2021 NRG granted over 335,000 GOs to customers. Another product offered by NRG on a similar direction, is the ‘NRG OnTheGo plan, which is designed specifically for customers who own an electric or plug-in hybrid vehicle, offering them numerous privileges (e.g. competitive electricity consumption rates) and innovative services. Additionally, NRG is constantly investing in electromobility and the development of the desired infrastructure and services. NRG started developing one of the largest network of fast charging stations in the country, counting so far 146 stations. The EV charging stations are also installed in fuel stations on highways and cover a large part of the road network in Greece. What is more, the energy supplied in NRG’s network of standard charging stations comes from almost 100% renewable energy sources.

The Group is developing an integrated approach across the value chain of charging.

Products performance is closely monitored by the Group’s risk management system. To minimize market risks, NRG’s Green products were developed based on market analysis results (competition, business environment, customer needs etc.). Main risks lie within the budget and the use of premature technologies which enclose a high CAPEX and therefore a high risk of failure. Following the acquisition of VERD, Motor Oil Group will pave the way in investing and operating in renewable and alternative fuels sector and circular economy through the utilization of bio-based products, and waste products to produce energy and new environmentally friendly fuels.

Moreover, the Group will be involved in the sourcing of raw material, the production and delivery of sustainable alternative fuels. The biodiesel production plant is located in Volos, with a production capacity of 80,000 m3 of biodiesel per year or 33,000 m3 UCOME capacity. In addition, VERD leads the waste cooking oil (WCO) collection industry in Greece through its subsidiary PRASINO LADI SA. (Green Oil SA.), which collects approximately 25,000 tons of used cooking oil annually to produce biofuels. The new renewable platform will enable Motor Oil to become a regional leader in the sectors of renewable fuels and circular economy. Aiming for a sustainable transportation the Group is examining the supply of sustainable fuels like Sustainable Aviation Fuel (SAF), which can be made from biomass and waste. For shipping, low-carbon solutions include hydrogen and ammonia in the long term, and LNG, biofuels and methanol in the short term. For road, Hydrogen offers the most promising solution to achieve net-zero emissions by 2050 for heavy-duty vehicles and over longer distances.

See more in our Corporate Sustainability Report, p. 44 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

Low-carbon Investments & Portfolio Climate Resilience

MOTOR OIL Group, to diversify its activities, promotes heavily low carbon investments through a series of acquisitions in RES and expanded its energy portfolio. In this context, in 2021 MORE owned a RES operating portfolio of 279MW. The total energy production from RES resulted to 585 GWh with CO2 avoidance of 360,000 tonnes of CO2e (based on the avoided emissions calculator of IRENA). In 2021 MORE’s pipeline development and construction counted on 650MW and 84 MW respectively (including the construction of 40MW wind farms in Florina). In 2022 the company expects to almost triple the size of the pipeline due to the acquisition of Ellaktor’s RES activities. In the domestic market, the green products offered by the Group’s commercial companies are considered an important measure that can address climate-change resilience.

See more in our Corporate Sustainability Report, p. 48-49 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

The Green Hydrogen project

Motor Oil aims to becoming producer of Renewable Hydrogen through an electrolysis project in the refinery, a platform that will be continuously expanded in the future to meet the goals of the emerging hydrogen market. The Group is looking to establish a scalable, reliable, replicable and low-cost value chain of Green Hydrogen in Greece, contributing to national, European and UN climate targets, as well as to the EU Hydrogen Strategy, the Energy Transition and RePowerEU initiatives. It will be the first Green Hydrogen commercial infrastructure project in the wider area of Southeast Europe, and it should be considered as part of an ambitious, innovative, and commercially viable plan to create a future-proof, supra-regional, hydrogen hub in the South-eastern EU Member States. The production and supply of renewable carbon hydrogen is a key module of the Motor Oil Group “BLUE MED” project, an integrated large-scale infrastructure project (evaluated under CEEAG - Climate Energy and Environmental Aid Guidelines - for state support) that demonstrates an industrial ecosystem of renewable and low carbon hydrogen production and supply, envisaging fast deployment to kick-start the hydrogen economy in Greece by 2026 and gradually scaleup of a wider hydrogen market.

The Green Hydrogen project will contribute to the Greek energy and climate targets by:

Kick-starting the Green Hydrogen economy in Greece by 2026 with quickly deployed hydrogen infrastructure and rapidly scaling it up.
Providing clear environmental and social benefits by shortening the time to large scale use of Green Hydrogen in Greece.
Supporting the achievement of Greece’s environmental and climate targets by providing a supply of Green Hydrogen into the national energy system, at the lowest cost.
Establishing close synergies with Greek and EU R&D Institutions and Technology providers.
Creating the necessary infrastructure to support hydrogen-fuelled buses for public transportation, in view of Greece’s ongoing program for the renovation of its bus fleet, as well as heavy duty vehicles.
Supporting the creation of a network of hydrogen-fuelling stations in Greece, to facilitate the proliferation of hydrogen-fuelled cars, trucks and buses and in line with “Fit for 55” provisions for development of hydrogen-fuelling stations network in EU member states.
Establishing the necessary hydrogen logistics infrastructure, including compression terminals and hydrogen distribution trailers, to support hydrogen applications for train and sea transport.
Readily providing adequate quantities of clean hydrogen to justify the construction of the backbone of a hydrogen transmission pipeline in Greece (working together with Hellenic Gas Transmission System Operator - DESFA), which will bring together the different producers and consumers of clean hydrogen, as well as establish Greece as a hydrogen exporter to other European countries.
Enabling the first entirely green lubricants production (from waste lube oils) in Europe and supply hydrogen to a biofuels production site for producing renewable fuels to decarbonize road transport, the maritime and the aviation sector.
Promoting job creation and economic growth through the creation of a new value chain and market and engaging the local and regional community in taking advantage of green hydrogen benefits.

See more in our Corporate Sustainability Report, p. 46-47 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

Environmental Innovation, Research & Development

Motor Oil Group determined to further enhance its performance regarding environmental protection, undertakes and participates in the design and implementation of innovative and research projects. Motor Oil Group is driven by its determination to contribute to the environmental protection and the digital transition through the participation in EU and co-funded programs. Motor Oil Group undertakes on its own or participates together with leading national and European Research Institutes, Universities, Innovation Organisations and specialized private sector entities in the preparation, submission and implementation research, innovation and demonstration projects that are aligned with the Group’s environmental and sustainable development strategic priorities. A total of 21 proposals had been submitted out of which 7 were accepted, representing a success rate of 33%.

Partnerships and Collaborations with Research and Innovation Institutions

Motor Oil, a pioneer in the energy transition of Greece to the post-lignite era, participates as a founding member in the first established in Greece Energy Competence Center, which is an initiative of the National Technical University of Athens and the Research University Institute of Communication and Computer Systems (EPISEY). The Energy Competence Center is a partnership of public and private sector entities, which in the form of a Spin-Off aims to bridge the gap between supply and demand of specialized innovation and technology transfer services in the energy and environment sectors, supported by the General Secretariat for Research & Innovation.
Motor Oil and the Foundation for Research and Technology – Hellas (FORTH) have signed a Memorandum of Cooperation that aims in the pilot application and maturation of applied research and innovation products in the fields of energy transition and digital transformation.
Motor Oil has established mutually beneficial cooperation with the Centre for Research & Technology Hellas (CERTH) as well as the National Centre for Scientific Research “Demokritos”, on the basis of the Group’s growing activities, which covers multifaceted areas of interest such as biofuels, information technology, security, emerging technologies utilisation etc.

See more in our Corporate Sustainability Report, p. 82-84 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

Innovation & Digital Transformation

The key for energy transition across the Group’s value is to steadily invest in the application of new, technologically advanced and more efficient systems. Digitalization forms the key for energy transition across the Group’s value chain and plays a significant role in optimization and intelligent plans, managing unpredictable sources, enabling flexibility and smart grids, offering personalized services and expanding on new business models. More importantly, digitization will transform the refinery, not only in terms of Predictive Maintenance, but also on environmental and H&S issues.

MOTOR OIL Group’s Digital Transformation Plan follows best practices and industry expertise to optimize PMO process through a standardized way to acquire, prioritize, and plan projects requests, monitor their progress, and deliver successful outcomes (Demand Lifecycle). The planning process aims to ensure that the portfolio is updated with specific dates for new/planned/released initiatives. In order to help meet the need for structured and systematic monitoring of the IT Project Portfolio throughout the life cycle of a project, from recording an idea for an IT project to delivery, expanding the existing Enterprise Service Management Platform of the group (ServiceNow) will be considered in 2022. For this reason, in 2021 we started an IT Project and Portfolio Management Solution, that will run in 2022, that will help meet the needs of the Group for monitoring IT projects. At the same time, it is planned to execute a pilot program for the integration of ESG information in the SAP platform of the Group. Initially it will cover key KPIs such as carbon dioxide emissions and health and safety issues. In the next phases, the project will be extended to all major ESG KPIs with the ultimate goal of being applied to all Group companies. In 2021, our annual budget for Innovation & Digital Transformation projects at Group level was approximately 11% from our total IT portfolio budget and we intend to increase this to approximately 16% for 2022.

See more in our Corporate Sustainability Report, p. 180-181 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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PERFORMANCE INDICATORS

	2020	2021
Energy savings	6,280.20 TJ	-5,806.34 TJ

Energy intensity ratio (GJ per tonne of raw materials)

Motor Oil S.A.	Avin Oil S.A.	Coral S.A	MYRTEA S.A.	ERMIS S.A.	Coral products & Trading S.A.	Coral Innovations S.A.	Coral Croatia	Coral SRB	Coral-FUELS DOEL Skopje	Coral ENERGY PRODUCTS CYPRUS LTD	SHELL & MOH AE AVIATION FUELS	Coral Gas S.A.	LPC S.A	CYTOP S.A.	OFC S.A.	NRG S.A.	Extended Reporting Group Group 2021
2.269	0.030	0.142	0.141	0.094	0.000		0.325	0.315	0.775	0.080	0.028	0.289	3.264	0.002	0.008	-	1.657

€ 152 million for environmental investments in 2021
363 MW RES added (operational & under construction) during 2021
€ 18 million for investments on innovation and digital transformation

Value creation

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ENVIRONMENT

11. Usage of Natural Resources

ADMINISTRATIVE PRACTICES

Respect and care for the environment is a common denominator in all activities of the Group, which operates as a responsible corporate organization and adopts the principles of sustainable development, based on environmental protection with respect and responsibility towards future generations.

Aiming to eliminate its environmental impacts, Motor Oil Group has developed and implements and Environmental Policy and Management System while also implements Best Available Techniques. Environmental protection is a common denominator in all activities of the Group, which operates as a responsible corporate organization and adopts the principles of sustainable development, based on environmental protection with respect and responsibility towards future generations. For these reasons, the Group continues with investments aimed at the steady improvement of its environmental performance.

Environmental and Energy Management System

Our primary goal to minimize the environmental impact and energy footprint of our operation, as part of our sustainable development strategy, is based on the Environmental and Energy Management systems, which are certified according to ISO 14001 and ISO 50001 respectively. Moreover, MOTOR OIL is certified by the voluntary scheme 2BS, which provides accurate and reliable information regarding the origin of biomass and biofuel. The environmental and energy management systems fall under the integrated management system, which has also been certified against the revised ISO 9001: 2015 standard for quality. They serve as effective management tools for implementing the company’s environmental protection policy objectives.

Environmental Risk Management

Disclosing the risks associated with MOTOR OIL Group’s management of material issues, offers an insight into the presence of potential problems, opening the way for solutions. The environmental risks identified below are managed in the best possible manner and are indicative of the attention MOTOR OIL Group is giving to eliminate any negative effects its operation may have on the environment through the selected material issues. Therefore, all environmental risks/events have been identified, recorded and evaluated. The Environmental Risk Management system responds to events such as:

Air Pollution, Subsurface and groundwater pollution, Pollution of a marine receptor, Nuisance issues, Consumption of natural resources, energy and raw materials.

Additionally, the Group’s Environmental Risk Framework includes the following criteria:

The inspection of the Refinery process units and other premises
The approach of the stages of the Life Cycle
The understanding of external and internal parameters and environmental conditions
The regular / scheduled or unscheduled (as required) internal audits
The frequency of occurrence
New compliance obligations due to changes in legislation
Climate related initiatives
Stakeholders’ expectations
Environmental policy and targets
The environmental documentation (manuals, procedures, forms and archives)
The operation of the Refinery under normal conditions, irregular conditions, and probable emergency conditions
New activities / products / services or changes
Occasions of unusual / emergency operating conditions.

Environmental compliance

Energy

Energy efficiency and related GHG are material issues for us, as an energy company. We always aim at operating as a responsible organization, adopting sustainable development principles based on environmental protection, mutual respect and a sense of duty towards future generations, as stated in the Group’s policies. For these reasons, the Group continues with investments aimed at the continuous improvement of its environmental, energy and climate performance. In 2021, the total energy consumption was 30,560 TJ.

34,4% electricity consumed from renewable energy sources in Group subsidiaries.

Water

We recognize water as a scarce and lifegiving valuable source and therefore manage it in the most responsible way throughout our activities. 100% of the water used in various parts of the refinery originates from processed sea water at its desalination units. For Motor Oil, its water footprint represents a very important indicator when it comes to responsible use of resources and environmental protection, complementing the ecological and carbon ones. The company has already covered valuable ground on that direction by using solely desalinated water for its refinery’s needs and aims to progressively incorporate in its operation ways to measure, as well as adequately manage, the volume of water used. In 2021, the total water withdrawn were 4,570.10 thousand m3.

Protection of the Marine Environment

A significant portion of our core activities such as the operation of the refinery as well as several of the facilities of the other Group companies are fully integrated in the marine environment. Considering the destructive impact of a potential pollution incident, extensive prior planning and preparation are imperative, particularly to prevent, but also to effectively respond to such events. It should be noted that no parts of the refinery or any other of our facilities are located on natural habitats or protected areas which might be affected by their operation. In the same context, Motor Oil Group:

Implements all necessary active and passive protection measures to minimize the risk of oil spills within the boundaries of the refinery. In 2020, not a single leak was reported.
Implements all necessary measures and provide all equipment for the safe sail in and sail out of tankers at their port facilities, as well as for their safe loading/unloading.
Has in place all necessary equipment to efficiently respond to a potential small or medium-scale local contamination incident (Τier-1/2). Also, a stock of oil slick dispersant is available, which can be used only following the consent of the Port Authorities.
Checks the readiness for implementing the existing anticontamination plans and maintains a high degree of readiness among staff in the use of necessary equipment, in cooperation with internationally recognized companies, such as Oil Spill Response Limited (OSRL), with an annual program of drills and training.
Has in place a reception and handling plan for ship-generated waste and cargo residues.
Is a member of international and regional organizations, whose aim is the prevention and timely response to oil spill incidents.

Rehabilitation & Biodiversity

Owing to the impacts of a potential pollution incident, extensive planning and preparation is imperative, to mostly prevent but also to effectively respond to such events. On that note, no parts of the refinery or other facilities abut on natural habitats or protected areas which might be affected by their operations. Furthermore, the Group implements all the necessary active and passive protection measures to minimize the risk of oil spills within the boundaries of the refinery and provides the necessary equipment for the safe sail in/out of tankers at their port facilities and the safe loading/unloading, while responding to a small or medium-scale local contamination incident (Τier-1/2). It also checks the readiness for implementing the existing anticontamination plans and cooperates with internationally recognized companies, such as Oil Spill Response Limited (OSRL), for an annual program of drills and training. The Group has in place a reception and handling plan for ship generated waste, as well as cargo residues, while participates in international and regional organizations, aiming to prevent and timely respond to oil spill incidents. MOTOR OIL Group recognizes the importance of biodiversity protection and takes all the necessary measures to eliminate potential negative impacts to nature and biodiversity through the spill scenarios and emergency plans that have been developed.

Air Quality

Another area of our focus is air quality at and around our facilities. Towards this direction, we take all necessary measures to ensure air quality at and around our facilities and we strive for continuous improvement, aiming at further reducing our air emissions in terms of NOx, SOx and other types of pollutants. Further to always operating within the limits required by applicable laws and regulations, we employ measures to monitor, control and reduce our emissions. The refinery implements the Best Available Techniques during the operation of its facilities aiming to improve air quality according to its environmental policy and the Environmental Conditions Decision Approval.

Noise Management

We make every possible effort to minimize environmental noise levels both the refinery and all other Group facilities. To mitigate any potential nuisance, regular measurements are made at set points on the refinery’s perimeter in parallel with the implementation of additional measures, such as the use of noise barriers or closed sound insulation systems and other technical means, where required. Noise levels are always below the maximum limits set by the environmental terms of the refinery.

Waste & Hazardous Materials

We manage waste generated during our production process in the best possible way, focusing on prevention, reduction and responsible handling. Motor Oil Group takes all necessary measures to minimize the quantity of waste and hazardous materials produced as a result of our activities, based on the precautionary principle. Waste management forms part of our group-wide certified environmental management system in accordance with the requirements of ISO14001. Motor Oil also complies with the REACH and CLP Regulations, related to the use as well as the classification, labelling and packaging of chemicals. Furthermore, in addition to undergoing external auditing on a yearly basis, we also conduct internal EHS audits to review and improve our practices regarding waste management.

Effluents Management

We take all possible measures to properly manage the liquid waste produced at our facilities whilst taking no risks when it comes to protecting the environment. Both industrial and urban liquid waste is produced as a result of the refinery’s operation. The liquid industrial waste produced by the production units of the refinery enters the liquid industrial waste treatment unit which consists of a series of successive treatment stages (API type oil separators, DAF flotation units, sand filters, biofilters, sludge treatment). Meanwhile, municipal wastewater is treated in the municipal wastewater treatment plant.

Circular Economy & Recycling Processes

We concentrate on integrating circular economy principles into our strategy, in order to preserve natural resources and minimize the waste produced during our operation. Circular economy is well integrated into the Group’s business strategy. MOTOR OIL Group uses sustainably available resources and raw materials, in order to minimize waste, pollution and carbon emissions. On that note, although the main product traded by the Group companies is fuel destined to be burned in various types of combustion engines in the plants or by the final customers/consumers, the companies strive to recover whatever feasible at the various stages of the activity.

See more in our Corporate Sustainability Report, p. 54, 63-66, 74-109 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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PERFORMANCE INDICATORS

SRS-301-1: Υλικά που χρησιμοποιούνται κατά βάρος ή όγκο.

For LPC information can be found in its environmental statement (https://www.lpc.gr/perivallongr/perivallontikes-diloseis/)

For motor oil & LPC reference in reprocessed materials can be found in the following table ( p.111 sustainability report)

SRS-302-1: Κατανάλωση ενέργειας εντός του οργανισμού

SRS-303-1: Κατανάλωση νερού

See more indicators in our Corporate Sustainability Report, ESG Performance Index, p. 187-195 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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12. Resource Management

ADMINISTRATIVE PRACTICES

Motor Oil Group aims at making optimal use of raw materials and focuses on reducing the amount of waste generated, with the emphasis in being placed on eliminating the burden both to the environment and people’s health.

Goals & Targets

Motor Oil Group has responsibly adopted a series of short, medium and long-term ESG goals and monitors progress on an annual basis.

Decarbonization Strategy

The Group’s decarbonization process is moving fast and is accelerating as a strategic response to global and local changes in the energy sector and the economy but also due to the pressure from the institutions, investors, society and the market. Both the investments in renewable energy sources and the ambitious strategic plan demonstrates the Group’s determination to drive the energy transition and remain a sustainable future proof energy carrier.

In response to challenges, for the coming years strategic priority is to reduce carbon emissions and to increase the portfolio of climate resilience by increasing investments in low carbon products, renewable energy, renewable and alternative fuels but also in the carbon capture and storage. In addition, driven by the latest global developments, the Group’s decarbonization strategy aims to mitigate the effects and adapt to climate change, while committed to energy transition and low-carbon economy by setting ambitious carbon reduction targets.

Our decarbonization strategy is driven by our Energy Transition Strategy and includes measures such as:

Increasing energy efficiency
Acquisitions and investments in new, low-carbon projects
On site RES and Battery storage installations
Innovative processing and digital technologies
E-mobility development with an increased number of EV charging stations
The retail station of the future
Renewable energy production with solar and wind power
Transition energy through CCGT plant and FSRU
Clean Hydrogen production
Sustainable production of E–fuels
Advanced and recycled fuels production
Carbon capture and storage projects
Offsetting Becoming Net zero requires also low carbon investments and products, from renewable electricity and EV charging to Hydrogen and biofuels.

Energy Use and Reductions

Our efforts to increase energy efficiency at our facilities during last years have resulted in improved energy performance. We remain committed to further improving our energy footprint in the years to come.

Aiming at energy efficiency improvement, the following programs have been implemented at Group level:

Upgrade of the seawater desalination units resulted to energy reduction for water production
Installation of energy meters for adequate monitoring
Assessment of high energy consumption machines (e.g., burners, motors)
Material requisition of new equipment according to Standards for energy efficiency
Addition of a new reverse osmosis unit
Replacement of equipment
Continuous training and awareness in the area of energy management and optimization
Evaluation of opportunities for energy recovery
Fine tuning burners for efficient combustion
Investigation of renewable energy sources
Upgrade of the Lubricant Vacuum Distillation Unit
Upgrade of the furnace in the Lubricant Extraction Unit with thermal efficiency reaching 90% (~ 7% benefit)
Installation of the Advanced Process Control (APC) system for the lubricant vacuum distillation unit

Continuous monitoring of environmental performance

The Group applies an integrated Environmental Management System (EMS) in accordance with the guidelines of European Regulation 1221/2009 (EMAS). The EMS records and controls the environmental parameters associated with its operation on a continuous basis, as well as it monitors a wide range of environmental indicators that reflect its environmental performance on a monthly basis. The system also identifies, records and evaluates environmental impacts at all stages of the production process, in accordance with defined criteria including the legislative requirements and the views of interested parties. Moreover, the refinery reports its annual emissions and activity level, according to Regulation 2019/1842/EU for the adjustments to free allocation of emission allowances due to activity level changes (EU ETS). MOTOR OIL refinery introduced some significant outcomes:

The installation of new continuous metering devices in the Fuels, Lubricants, MHC and in the chimney of one of the combined heat and power units is in progress to optimize the monitoring of emissions.
Upgrade of diffuse emission monitoring plan from equipment by adding the optical monitoring method.
Planning for the installation of a steam recovery unit (VRU) at port facilities is in progress.
Upgrade an existing steam recovery unit (VRU) at the tanker loading terminal.
Continuation of staff training on environmental management and energy optimization.

Rehabilitation

The Forest programme: In the context of its sustainable transition, in 2021 MOTOR OIL Group designed the “Forests programme”. The programme is aligned with the United Nations 2030 Sustainable Development Goals and is part of the Group’s commitment to support the European Green Deal, concerning the protection of biodiversity and ecosystem, aiming at sustainable development. The “Forestry programme” significantly contributes to the following:

Preservation and protection of the natural environment
Restoration of degraded ecosystems and creation of natural value
Combating Climate Change
Promotion of research, technology and creation of social value

The programme holistically addresses forest ecosystems by considering all phases of their lifecycle and strengthening the different levels of biodiversity. It incorporates a wide range of environmental activities, including but not limited to, sustainable reforestation initiatives, environmental research and collaboration with stakeholders for environmental purposes. At the same time, through these initiatives, MOTOR OIL Group aims at raising society’s awareness on environmental issues. As part of the “Forests programme”, MOTOR OIL Group has completed the following actions so far:

Reforestation of 10 ha in Kineta’s Panorama 3 of Megara municipality
Reforestation of 3 ha implemented by drones, in collaboration with the Forest Research Institute and Agricultural University of Athens
Adoption of the National Warehouse of Forest Seeds (Amygdaleza ginning plant).

Water management

In order to reduce its water consumption, MOTOR OIL Group consistently implements measures to efficiently manage water use at the refinery. To this extent the refinery operates a desalinization unit which allows it to cover 100% of its water needs by sea water. Furthermore, the refinery processes acidic water generated in different phases of the production process, recycling a large portion of the flow where possible. As a result of these measures, impacts to water and the natural environment are eliminated to the lowest degree possible.

All MOTOR OIL Group companies whose operation involves water consumption, implement policies and practices targeting the efficient management of water usage. The following measures are part of the due diligence process:

Identification of water utilization and consumption based on measurements and other data, in order to identify and evaluate past and current use and consumption.
Identification of factors that significantly affect water consumption.
Determining the current performance in facilities and the processes related to significant water consumption.
Estimation of projected future water consumption.
Identification and evaluation of opportunities to improve water efficiency.
Minimizing the produced wastewater.
Maximizing the reuse of water by the utilization of treated wastewater.
Controlling wastewater treatment, in order to meet the disposal requirements raised by operation terms and Regulations.
Use of groundwater for sprinkling tanks (during deliveries of fire drills) and disposal of water used in the production process (following oil segregation).

More specifically, Coral monitors the water consumption per depot, while LPC has identified two significant risks; relating to contaminants in waste oil, such as antifreeze, brake fluids and other (soil, diluters, fuel etc.), which can result to heavy organic load in wastewater and problems in process equipment (corrosion, fouling etc.), prohibiting in that way the re-use of treated water. Another risk factor may lie in the wastewater treatment (WWTU) unit’s capacity to accommodate heavy rain, creating problems in that way to its smooth operation. To cope with this possibility, the WWTU’s capacity is much higher than the normal requirements (6x), whilst additional preventive and corrective actions are implemented.

Waste Management at the Refinery

Motor Oil manages solid waste produced at the refinery by applying an integrated process which transcends all stages involved, starting from its collection and continuing to packaging, labelling, transportation, processing (where applicable), temporary storage, and finally further utilization or disposal through one of the methods below:

re-processing within the refinery and re-use
recycling outside the refinery,
recovery inside/outside the refinery,
final disposal outside the refinery.

Transportation, further treatment and final disposal of solid waste produced at our facilities is handled in different ways, depending on its type. Special types of solid waste such as for example empty containers (from hazardous substances), waste packaging, old electrical and electronic equipment, used batteries and accumulators, as well as used vehicle tires, and vehicles at the end of their life are being managed by appropriately licensed contractors. The same applies for used catalysts, which depending on the case may be classified as hazardous solid waste and are disposed in a number of ways (either exported, or regenerated for re-use by specialized firms abroad, or used in manufacturing of cement). Moreover, the refinery is already implementing biopiling, a bioremediation technology in which excavated soils are piled in a treatment area that consists of a leachate collection and aeration system. It is commonly applied to reduce concentrations of petroleum components in soils through utilizing the process of biodegradation. Additionally, the Group is going to proceed with the construction of a waste treatment plant, and a landfill meant for congregating hazardous waste produced by the refinery.

Waste Management at our Subsidiaries

LPC’s primary function is to recover and up-cycle waste lube oils, dangerous wastes which can be found in big quantities close to public, contributing in that way in the protection of both human life and the environment. Similarly, Avin Oil takes all necessary measures to minimize the amount of waste and hazardous materials used in the various stages of production as well as in service stations and offices. In this context, the company ensures the integrated management for lubricants and empty packaging, through contracts with licensed companies that specialize in the management of packaging materials and any hazardous waste that arises. Coral on the other hand provides a life cycle analysis which forms part of its Electronic Waste Register (EWR). Respectively, Coral Gas implements recycling of scrapped metal, used lubricants, used rags, lighting bulbs, as well as batteries by appropriately licensed, specialized companies. OFC also manages the waste (solid and liquid, hazardous and non-hazardous) produced, (e.g. in accordance with specific measures described through the IMS). Moreover, OFC collects and recycles materials (from used cans and bulbs, to car filters, Shell detectors, used tires, hoses etc.).

LPC’s leading role in circular economy

LPC plays an important role in the region’s circular economy. Today, LPC has a re-refining capacity which is twice the available Greek WLO. The company collects WLO and/or supports the collection of WLO from other countries around Mediterranean Sea and produces high quality lubricants, covering about 30% of Greek market and exporting to about 50 countries. The company produces high quality regenerated lubricants and greases operating one of the largest and most technologically advanced plants for used lubricants refining across Europe. LPC demonstrates best practice in the field of waste lubricating oils management and is considered a pioneer at a European level. The Collective System of Alternative Management of Waste Lubricating Oils of ENDIALE SA, is the body that coordinates all the stages of waste management (collection, transport, temporary storage and utilization), by recording the data of each stage, in order to keep track of the specific waste management procedure. After many years of operation, ENDIALE has developed a full range of activity throughout Greece, operating 8 collection centers, resulting in Greece being the leader in regenerated lubricants within the EU. 100% of collected WLO are led to refining which is a unique achievement of circular economy in the world. In addition, LPC is an active member of several European organizations and associations (SEPAN, UEIL, GEIR) that work for the promotion of circular economy in terms of European and National legislation, dissemination activities, Life Cycle Assessments etc. Through its subsidiary CYTOP, promotes the principles of sustainable development and helps protect the environment through the collection of hazardous and non-hazardous waste and its disposal in appropriate management facilities. Part of this waste comprises of waste lubricants oils (WLO) and petroleum residues (PR), which can be further directed for recovery / regeneration and reuse, thus preventing them from being incinerated and releasing hazardous substances or ending up on land or in water with serious consequences for both human health and environment. Each year, LPC makes an environmental statement covering the previous year. A key element of this study is the assessment of risks and opportunities as well as the environmental impacts arising from the individual activities of the company. Based on market trends for environmentally friendly and less expensive products, LPC launches products such as:

lubricants for low fuel consumption and lower pollution,
lubricants for long change intervals and lower waste produced.

Given the expected growth of industries that support circular economy, LPC has great potential for growth as refining lubricating waste is one of its core functions. Lastly, the company also offers courses and seminars on circular economy. LPCs performance in terms of materials’ recovery for the last three years is shown on the diagram that follows. The recovery of base oils has been reduced progressively from 36,847 tonnes in 2019, to 36,018 tonnes in 2020, to 33,179 during 2021.

See more in our Corporate Sustainability Report, p. 38, 40, 55-59, 63-66, 74-109 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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PERFORMANCE INDICATORS

SRS-302-4

	2020	2021
Energy saving	6,280.20 TJ	5,806.34 TJ

SRS-306-2: Συνολικό βάρος των αποβλήτων, με βάση τον τύπο και τη μέθοδο διάθεσης.

See more in our Corporate Sustainability Report, p. 102, 189 ESG και Βιωσιμότητα – Motor Oil (moh.gr).

Other relative Indicators reported

See more indicators in our Corporate Sustainability Report, ESG Performance Index, p. 187-195 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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13. Climate-relevant emissions

ADMINISTRATIVE PRACTICES

Our energy transition strategy is based on resilience and sustainable growth. We continue to operate our refinery while making investments aiming to improve operational efficiency and flexibility as we implement digital transformation projects and assess carbon capture and storage investments. We continue to invest in E-Mobility by developing strategic partnerships and equipping our retail gas stations with EV charging points - we expect almost 1,000 EV charging points by 2023 and 4,000 in the longer term. We continue to diversify in Renewable Energy Sector through a series of acquisitions in RES leading to an expanded energy portfolio. In this context, in 2021 MORE owned a RES operating portfolio of 279MW. The total energy production from RES resulted to 585 GWh with CO2 avoidance of 360,000 tonnes of CO2e while our portfolio in 2030 is expected to exceed 2GW. Finally, the Group is working to enhance its value proposition by expanding its product offering and manufacturing processes into the area of alternative energy sources where we invest in the field of natural gas, with the construction of a CCGT plant in Komotini and we continue with the development of a floating storage and regasification unit (FSRU). Furthermore, Motor Oil Group is paving the way in investing and operating in renewable and alternative fuels sector and circular economy through the utilization of bio-based products, and waste products to produce energy and more environmentally friendly fuels. Moreover, we are planning an integrated large-scale hydrogen project while we will establish the Hellenic Hydrogen SA, (JV with PPC) with main objective the production and storage of green Hydrogen. Our energy transition strategy, as briefly described above, is inextricably linked with our decarbonization targets which aim to absolute GHG emissions reduction (Scope 1&2) by 2030 and supporting a net zero target by 2050 (vs. 2021).

Our Energy Transition Strategic Plan

MOTOR OIL Group recognizes the need to get to net zero and builds a holistic energy transition strategy with a diversify multi energy portfolio based on four pillars.

Renewable Energy

Key milestones

2.3 GW Pipeline of projects in various stages of development
~780 MW RES operating capacity by 2022
~100% Long-term contracted revenues
~2,000 MW RES operating capacity by 2030

EU taxonomy alignment

In order to direct investments towards sustainable projects and activities, European Union introduced the EU Taxonomy (Taxonomy Regulation (EU) 2020/852), a classification system, establishing a list of environmentally sustainable economic activities. Αn economic activity has to meet the below conditions to be recognized as Taxonomy aligned: 1. Making a substantial contribution to at least one environmental objective. (The objectives are: Climate change mitigation, climate change adaptation, sustainability and protection of water and marine resources, transition to a circular economy, pollution prevention and control, protection and restoration of biodiversity and ecosystems.) 2.Doing no significant harm to any other environmental objectives. 3.Complying with minimum social safeguards. While a percentage of Group’s activities and investments is already eligible and aligned with EU Taxonomy, the Group aims at further increasing those activities and investments in the future. Taxonomy eligible activities for the Group are mainly considered: a. Electricity generation using solar photovoltaic technology, b. Electricity generation from wind power. Following the latest Taxonomy Complementary Climate Delegated Act on climate change mitigation and adaptation covering certain gas and nuclear activities, the Group considered certain gas related activities: a. Electricity generation from fossil gaseous fuels, b. High-efficiency co-generation of heat/cool and power from fossil gaseous fuels, c. Production of heat/cool from fossil gaseous fuels in an efficient district heating and cooling system. The Group monitors closely any changes might occur in the EU Taxonomy since the legislation is still under development.

Decarbonization Strategy

Decarbonization and Energy Transition is the foundation of the Motor Oil Group’s strategic plan with the aim of becoming an Integrated Energy company trusted by its stakeholders. In response to challenges, for the coming years strategic priority is to reduce carbon emissions and to increase the portfolio of climate resilience by increasing investments in low carbon products, renewable energy, renewable and alternative fuels but also in the carbon capture and storage. In addition, driven by the latest global developments, the Group’s decarbonization strategy aims to mitigate the effects and adapt to climate change, while committed to energy transition and low-carbon economy by setting ambitious carbon reduction targets. The Group is committed to absolute GHG emissions reduction targets by 2030: Scope 1+2 GHG by 30 percent and Scope 3 by 25 percent from 2021 base year while supporting a net zero target by 2050 compared to 2021 levels. The targets are set, and the economic impact is assessed based on IPCC climate scenarios and under the Science Based Targets Initiative (SBTi)3. The targets will be examined every year to consider any climate related risks or new developments.

Managing Climate Risk

TCFD categorizes climate related as Transition Risks (regulatory, technology, market and reputation) as well as Physical Risks (acute and chronic). Due to the nature of the business and the current developments, the Group has identified these risks over short (to 2025) medium (to 2030) and long term (to 2050). These are comprehensive and holistic scenarios analyzing how the world might develop, and the corresponding business impacts that these pathways have on average global temperature and resultant climate change.

Energy Efficiency & GHG Emissions

Our approach Energy efficiency and related GHG are material issues for us, as an energy company. We always aim at operating as a responsible organization, adopting sustainable development principles based on environmental protection, mutual respect and a sense of duty towards future generations, as stated in the Group’s policies. For these reasons, the Group continues with investments aimed at the continuous improvement of its environmental, energy and climate performance. To this extent:

We measure and improve our performance on a continuous basis, regarding energy use and aim at the reduction of carbon dioxide emissions.
We invest in the application of economically feasible technologies that contribute to the reduction of emissions and cooperate with the competent state authorities and other agencies in planning and implementing technologically feasible and financially viable environmental protection policies.
We report our actions and results to our stakeholders

To aid energy efficiency efforts, the Group actively seeks appropriate best practices and develops technological innovations to reduce energy use in all operations and facilities.

CO2 Emissions

Driven by our will to excel, our sustainability approach and the applicable legislation we adopt adopted practices with the aim to reduce CO2 emissions both in our operations and transportation of fuels and at our customers, according to Greek law 4342/2015, articles 9 and 10, 4546/2018, 4062/2012, as well as the respective EU directives such as article 7 of the 2012 EED (2012/27). In order to comply with these requirements, Motor Oil implements the following:

Utilizes the appropriate methodology to monitor CO2 emissions from its facilities, based on flow analysis measurements and fuel quality analyses.
Evaluates with its refinery’s laboratory – certified to ΕΝ 17025:2005 standards – the quantity of carbon contained in the fuel produced, using the gas chromatography method.
Submits to the competent authorities annual reports on CO2 emissions, verified in terms of their reliability and validity by a certified external agency.

Participating in European Trading System (ETS) Motor Oil’s refinery participates in the European Trading System (ETS), in line with the provisions of Directive 2003/87/EE. ETS represents the cornerstone of EU’s policy to combat climate change and it is key for reducing greenhouse gas emissions in a cost-effective manner. Under these legislative provisions, the refinery is obliged to report its annual CO2 emissions, according to an approved by the competent authorities monitoring plan. Monitoring plan sets the framework of the CO2 emissions calculations for every process, aiming at the most accurate depiction of the emission. Within this framework, the refinery:

- reports its annual emissions which are being verified by a certified third party, and
- uses calculation methodology based either on European standards or on analysis per formed by the re finery’s certified to ISO 17025:2005 laboratory.

Further than reporting its emissions, this year the refinery was faced with the challenge to design its strategy for the next decade, when Europe has set a plan to significantly reduce emissions by at least 55%, until 2030. In order to achieve this goal, all legislative framework has been modified to allow for the reduction of free allowances for the list of facilities that experience carbon leakage and funding innovating low carbon technologies.

Reduction of air emissions

Driven by the aim to further improve its environmental performance Motor Oil continuously implements new programs and actions whilst setting new goals. As a result, the refinery plans to reduce its air emissions (SO2, NOX, suspended particles, CO) per MT of input by 25% until 2022, and cut SO2 and NOX emissions by 10% and 19% respectively, until 2023. Leak detection and repair system Modern refineries are comprised of many different types of installed equipment, through which large quantities of raw materials circulate, as well as intermediates and final products, putting them at a higher risk of hydrocarbons being accidentally released into the atmosphere. In order to check and limit fugitive emissions from the equipment, a program has been implemented featuring regular controls at selected points (better known as LDAR – Leak Detection and Repair) in order to identify and repair possible leaks. Clean fuel by Coral Gas Liquified petroleum gas (LPG) represents a “clean” fuel, since it is a co-product of natural gas during the oil refining process and thus is considered to be resource efficient by its very nature. In the event of a leak, LPG does not contaminate the soil or aquifers and does not need a large-scale infrastructure of pipelines to support and to supply it, hence it is less vulnerable to natural disasters, has a very long shelf life. Moreover, it produces 96% less NOx emissions compared to diesel and 68% less NOx emissions compared to petrol. It is a reliable source of energy that can provide intense constant and healthy heat, minimizing significant health impacts and carbon monoxide emissions, compared to wood and coal.

Volatile Organic Compounds at the refinery (VOCs)

The diffuse emissions of volatile organic compounds (Volatile Organic Compounds, VOCs) are characteristic of all chemical and petroleum industry facilities and apart from being an additional source of air pollution, they also result to a significant cost due to lost products and, by extension, profit. Therefore, the goal of reducing this type of emissions is therefore twofold and involves: a) antipollution measures applied during product design as well as handling and storage equipment, b) regular inspections and maintenance of all equipment. In order to reduce emissions during the loading of tanker vehicles, a gasoline vapor recovery unit has been installed, in accordance with current legislation, which is internationally the most suitable means for reducing emissions of this type. Also, as part of continuous improvement, the new VRU vapor recovery unit at the loading port is under implementation.

See more in our Corporate Sustainability Report, p. 6, 42-71 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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PERFORMANCE INDICATORS

SRS-305-1: Άμεσες εκπομπές αερίων του θερμοκηπίου (GHG) (Πεδίο εφαρμογής 1).

SRS-305-2: Ενεργειακές έμμεσες εκπομπές αερίων του θερμοκηπίου (GHG) (Πεδίο Εφαρμογής 2).

SRS-305-3: Άλλες έμμεσες εκπομπές αερίων του θερμοκηπίου (GHG) (Πεδίο Εφαρμογής 3).

SRS-305-5: Μείωση (GHG) των εκπομπών αερίων του θερμοκηπίου.

See all indicators in our Corporate Sustainability Report, ESG Performance Index, p. 187-195 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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SOCIETY

14. Employment Rights

ADMINISTRATIVE PRACTICES

Aiming to be a responsible employer we provide a working environment where everyone can thrive, and we cultivate a culture of excellence, respect and trust, where every employee feels valued and supported. Creating a proper work environment is the basis for the development, empowerment and prosperity of the people, whilst creating a positive impact also on the partners, customers and the local communities the Group operates

Respect for Human Rights

Fair treatment, equal opportunities, and diversity are highly valued at MOTOR OIL Group’s inclusive workplace. In that context, the Group ensures that:

the Group’s talent acquisition process is impartial and transparent,
the composition of management reflects the composition of workforce,
incidents concerning violations of human rights, such as bullying, harassment and discrimination are of zero tolerance and are immediately condemned

We conduct our business as a responsible corporate member of our society whilst complying with all applicable laws and regulations. Motor Oil Group respects the fundamental human rights and makes every effort to safeguard health & safety, security and environmental protection. MOTOR OIL fully respects and abides to the United Nations Declaration of Human Rights, while is a signatory to the UN Global Compact’s ten principles. Moreover, in all countries where the Group operates, it is fully compliant with the national legislation on child and forced labor. There have been no cases of forced or child labor anywhere in the Group’s activities, nor would they be acceptable. Furthermore, since respect of human rights is a fundamental element of its organizational culture and vital for the sustainable operation of its business, the Group is currently developing its Human Rights Policy consisting of 30 articles.

Human Resources Management

Compliance with applicable legislation and universally accepted principles of human and labor rights.
Fairness and meritocracy in employee relations.
Attracting competent young people with a professional approach to work, who share our values: reliability, dedication, integrity and personal responsibility.
Ensuring equal opportunities for the professional and personal development of employees.
Providing a fair and competitive remuneration system linked to employee performance and consistent with prevailing market conditions.
Offering pay and benefits exceeding those provided for by law and by collective labor agreements.
Designing a programme of targeted education and training, covering subjects relevant to the Group’s strategic development goals, while aiming at the effective and safe discharge of duties.
Fostering corporate culture and corporate values.

Code of Conduct

Aiming to provide support and guidance to its staff regarding their behavior and actions during day-to-day activities, MOTOR OIL Group has developed and implements a Code of Conduct. This Code of Conduct reflects its philosophy and corporate values and provides guidance to employees, concerning their expected behavior. It covers a wide range of issues tightly related to the appropriate personal and professional behavior of employees, their ethics and values, compliance with applicable laws, leadership, health and safety at work, environmental policies, as well as company’s property. Specifically, employees are expected to show diligence, conscientiousness, integrity and honesty during their work and also, embrace the vision and goals of the company. For the Group, high ethical standards are crucial assets for employees, as such characteristics contribute to the smooth operation of the company, its excellence in terms of performing, as well as the increase of its competitiveness. Additionally, employees are required to fully comply with all laws and regulations that Group is subject to, and more importantly, behave in a way that reflects a positive image of the Group. Moreover, employees, as valued members of Group, should protect its assets and not disclose confidential information and protected data. Great importance is being given by the Group to maintaining the health and safety throughout its activities. Consequently, the Group takes all the necessary measures to protect its employees and expects the appropriate behavior of the latter in every aspect concerning safety and protection of the work environment and the people.

Labor Relations and Trade Unions

At MOTOR OIL Group we fully respect and support employees’ right for freedom of association and collective bargaining and comply with the Employment Regulation which has been put in force since 1974.

This is very important to our Group – and particularly to the refinery due to the complex nature of the work it entails – that employees can join unions and professional associations freely. Refinery employees are represented through their trade union and the Health and Safety Committee. The union has had a Collective Labor Agreement with the Hellenic Federation of Enterprises since 1986. This agreement describes the terms of employment and pay levels at the refinery. Additionally, a Collective Labor Agreement has been into force for MOTOR OIL Group, since 2006, between the Company and the union, which is renewed every year and is submitted to the Corinth Labor Inspection service and the Ministry of Labor. Aiming to achieve further improvements in working conditions and develop mutually beneficial relations, the management holds regular meetings with union representatives.

Remuneration System & Additional Benefits

Having as our target to advance employee satisfaction levels, work-life balance and low employee turnover rates, we offer a competitive remuneration scheme and additional benefits. To achieve this, we use a concise and transparent system enabling us to set, manage and review salary levels in compliance with current company and sector specific agreements. Negotiations covering collective agreements on salary adjustments are in line with sector practices that are applied at national level.

Training and Development

Training and development of our people is crucial for our success. In this context we are determined to offer our own staff as well as our contractors’ a wide spectrum of training and development programs which promote their personal and professional growth and improved performance. A key element in the process of aligning our employees’ skills with the Group objectives and ambitions, is investing in their continuous training and development. Given the importance of the oil refining industry for the domestic and regional economy, MOTOR OIL Group designs and implements every year, a comprehensive development program, including training for the improvement of technical skills and the development of interpersonal characteristics (soft skills) of employees, in the context of a holistic, in-house training.

Training Management System

In a volatile and uncertain business environment, MOTOR OIL Group, has planned to invest in continuous learning, by introducing a cutting-edge Learning Management System, to our employees, under the brand My Learning Path. The system uses SAP SuccessFactors platform and is equipped with content of more than 9,000 courses, from leading global training institutions including Linkedin learning and Harvard. Our My Learning Path strategy is intended to roll out in four phases:

Build Awareness: Focused on information, continuous reminders and presentations regarding the “what is in it for me” possibilities of the new model.
Contextualize: Building Learning plans around key business functions needs like Finance, Sales & Strategy and business calendar like budgeting and performance management.
Build Engagement: Start building excitement around timely topics (i.e. digital disruption and change management) and creating focus groups to empower “strong” learners.
Develop a Learner Driven Culture: One that employees drive their learning within the strategic frame work of the Group that is provided by Management and is communicated by HR.

Health & Safety

At Motor Oil Group we take all necessary measures to protect the Health and Safety of our people as well as our partners, as this consists one of our top priorities. The nature of the Group’s business operations - refining, storage, distribution and marketing of petrochemical products (i.e. fuels and lubricants), to businesses and end consumers- combined with its corporate principles and values, constitutes occupational health and safety a material sustainability issue and to this extent our Group is committed to ensure high health and safety standards for both our staff and partners. In addition, provision of continuous training of the Group’s employees creates a high level of safety awareness and together with the technical and organizational measures, form the essential pillars for accident prevention and the maintenance of a safe work environment. On top of that, the contractors’ employees are kept aware of health and safety issues, with the emphasis given on general principles of accident prevention and the Group’s procedures for ensuring safe execution of all activities. In terms of visitors, they are provided with safety instructions (in the form of a special leaflet and a short film), upon their entry to the refinery facilities.

Ensuring maximum protection of Health and Safety at our facilities: “Goal Zero”

For this purpose, we have set a permanent objective of zero accidents, namely “Goal Zero”, at workplace. The “Goal Zero” objective refers to “no harm to people, no loss of human life, no significant incidents to the environment and company’s reputation”.

Our policy framework regarding safety, social and labor issues:

The Group has adopted the following policies regarding safety, as well as social and labor issues:

Safety policy concerning the protection of people, assets, information, and reputation in cases that may pose a threat for the companies of our Group.
Driving policy for the prevention of road accidents, aiming at the reduction of risks and improvement of our health and safety performance in this area.
Drugs and alcohol policy, which aims to prevent, avoid, and control any drugs and alcohol use in the workplace.
Product stewardship policy which safeguards the health and safety of both employees and third parties who may be affected by the company’s activities and products, whilst ensuring protection of the environment and avoidance of any material damage and/or loss.
Non-smoking policy, which aims to support a healthy working environment, ensuring that smoking is not permitted at all companies’ facilities, with the exception of designated areas.
Major accident prevention policy (MAPP), in accordance with the European Directive 2012/18/EU requirements and the relevant laws at national level, which addresses the risks of major accidents related to dangerous substances with the aim to prevent them. Overall, our primary concern is to take all possible measures, and implement programs, to ensure we attain our long-served objective for Health and Safety in the workplace. To achieve this, we implement the following actions:
Reduce the risk of major technological accidents to the lowest possible level.
Eliminate occupational accidents though our “Goal Zero” philosophy.
Continuously monitor and upgrade the quality of equipment used in order to ensure that conditions conducive to safe working operations are constantly improved.
Successfully protect people (personnel, contractors, neighbors, associates and site-visitors), the environment and our facilities, from the hazards that may arise as a result of the company’s activities.
Continuously train our personnel and contractors on Quality, Health, Safety, Security and Environment (QHSSE) issues in order to prevent accidents and occupational health problems.
Ensure full compliance with regulatory requirements.
Promote active involvement of all employees in finding acceptable and effective solutions for protection and safety, closely following regulations, identifying hazards and assessing risks involved in their day-to-day activities.
Enable communication between employees and management regarding health and safety issues. The delivery of this commitment relies on the smooth operation of the integrated QHSSE Management System

Health & Safety System

To achieve continuous improvement over its performance on safety issues, Motor Oil Group has incorporated a QHSSE management system which is constantly updated with respect to changes made in the organizational chart and human resources. Moreover, a dedicated QHSSE department has been established with a mandate to support the Commercial Companies on issues related to Health and Safety, while working closely with the other Group companies in order to share best practices. There are also two statutory committees which hold meetings every 3 months: 1) A Safety and Environment Committee: consists of the refinery’s head and managers, representing the entire workforce. 2) A five-member Employee Health and Safety Committee: represents exclusively employees and its elected members are appointed every two years by the refinery employees. The Committees’ role is to ensure that health and safety requirements are met and make recommendations for improvements, if necessary.

Security and Emergency Preparedness & Response

Participation and Consultation on Health and Safety

All staff are actively encouraged and incentivized, through annual recognition awards for their continuous efforts, to identify, intervene and report potential hazards, through a digital tracking tool. In that way, a full assessment of the event is carried out by line managers and safety officers and a final response is communicated back to them. The continuous inspections by the personnel result in raising awareness of all risks inherent in operations and in the enhancement of the health & safety culture. More importantly, the staff is properly trained to recognize dangerous situations and remove themselves and others from such cases to maintain their safety and the safety of operations. There are Emergency Response Plans that explicitly describe the actions required in case of a fire or spill, as well as the Emergency Team’s duties and also include instructions for the bystanders (e.g., proceed to gathering points, immediately evacuate, etc.). It should be noted that employees who remove/disengage themselves from work situations that were deemed dangerous for their health and safety, are protected against reprisals by Motor Oil Group. Local Safety Committee is a joint committee that represents all workers and contractors and comprises of the Reporting Group’s management and staff representatives. The Committee’s role is to organize meetings (at least 4 times per year) at various locations (offices, depots, drivers etc.), in order to discuss, assess and control health and safety hazards. As soon as the risks are identified and evaluated, a mitigation process is being initiated according to the Manual of Authorities (MoA). The decision-making is regulated both by MoA and organizational arrangements. The Local Safety Committee’s meetings are organized by the Local Manager. In such meetings, there is strong participation of QHSSE Advisors, Technical Inspectors, Occupational Hygienists and a Safety Technician. Local Safety Committee meetings are part of the annual QHSSE plans. Finally, it should be highlighted that full cooperation exists between staff unions and representatives regarding Health and Safety issues.

Employee satisfaction survey

During 2021 Motor Oil conducted an employee satisfaction survey aiming to identify its employees’ satisfaction levels and identify potential areas of further improvement. The results, available to all staff at the company’s intranet were positive, since 9 out of 10 Motor Oil employees declared to be proud for their job. The same applies also to their perception regarding the company’s performance in terms of social responsibility, as well as health and safety. At Motor Oil Group we will continue investing in our people, our most valuable asset.

See more in our Corporate Sustainability Report, p. 114-115, 120-122, 131-133, 134-135, 144, 146, 147-148, 152-153 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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PERFORMANCE INDICATORS

SRS 405-01: Δείκτες διαφορετικότητας στα διοικητικά όργανα και στους εργαζόμενους

In 2021, senior managers comprised approximately 3.5% of the total personnel of the Extended Reporting Group, while technicians-operators and administrative personnel accounted for 96.5%.

See more, p. 136-141. See all indicators in our Corporate Sustainability Report, ESG Performance Index, p. 187-195 ESG και Βιωσιμότητα – Motor Oil (moh.gr).

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15. Equal Opportunities

ADMINISTRATIVE PRACTICES

Ensuring Equal Opportunities and Encouraging Diversity

At MOTOR OIL Group, we believe everyone should be treated equally, regardless of their gender, race, age, nationality, sexual orientation or any other characteristic of diversity. As a result, we ensure fairness, by providing the same work opportunities to employees and job applicants alike. More importantly, it supports people from every background, and envisages a diverse society free of exclusions, in which people with disabilities can be productively integrated into the community.

To this extent, recruitment, transfers, promotions, benefits, education and training, etc., are all governed by the principles of our equal opportunities policy, the avoidance of any form of discrimination, and respect for employees’ dignity. Valuable tool for providing support and guidance to its staff regarding their behaviour and actions during day-to-day activities, is the Code of Conduct that is applied at Group level. During 2021, 1 person with disabilities, was employed at Motor Oil Group, while no incidents of discrimination were reported. When it comes to gender equality specifically, the Group successfully promotes equal opportunities to women by prioritizing women’s advancement, safety and gender equality in the workplace. The Group promotes a fair, gender equal workplace, where no special privileges depend on gender, hiring practices are unbiased and there is zero tolerance on sexual harassment and discrimination against women. While an equal opportunity policy applies across all our activities, the nature of the work at the refinery and the required skills, result to a low percentage of women in our workforce. Thus, in the Reporting Group, in 2021, 20% of all employees were female, while at the Reporting Group’s headquarters, the women represent 38% of the total headcount. When it comes to management positions, 11% were covered by women. On the other hand, in some companies of the Group such as NRG, the percentage of women is much higher, where 52% of the total workforce are women. Recently the Group appointed a Diversity & Inclusion manager to ensure that Group’s policies and procedures reinforce diversity in the workplace, address all kinds of complains and protect minority groups, women and human rights. The role also covers employees training and the monitoring of relevant KPIs for annually improvement.

Equal payment

The structure of the remuneration system ensures equal pay for men and women doing the same work and rules out any other form of discrimination. A demonstration of this lies with the graph that follows, which shows that for 2021 the gender pay gap averaged 11% across the different levels of seniority. The following figures provide the ratio of the basic salary and remuneration of women to men for each employee category, by significant locations of operation, for the Extended Reporting Group.

The factors determining wage levels are mainly the employee’s grade and performance, the responsibilities and accountabilities of the position held, the educational level and the seniority.

Talent Acquisition

MOTOR OIL is an equal opportunity employer and selects candidates only on the basis of their suitability for a particular position, and in accordance with their specific qualifications and abilities, rather than on any diversity characteristic such as gender, nationality, age, family status, disability, or any other characteristic of diversity.

Health & Safety

All of the Group’s companies regularly report, record, investigate and analyze incidents (fires, accidents, near misses) using internationally recognized indicators in order to take the appropriate corrective and preventive measures. More specifically, both employees’ and contractors’ exposure hours are recorded and monitored on an 8-hour workday basis, including any additional working hours (e.g., overtime) in the final calculation. As a Group, we enhance our experience by monitoring investigations of serious accidents at comparable facilities of our peers and incorporating their findings into our own practices. During 2021, as far as employees are concerned, 9 recordable work-related injuries, were recorded at the facilities of the Extended Reporting Group, whilst only 2 recordable work-related injuries were tracked for contractors. Specifically, 4 out of 9 occurred at the Motor Oil refinery, 4 at LPC and 1 at Cyclon Lubricants Beogrand, while throughout all activities and facilities of Avin Oil, Coral, Coral Gas, NRG and OFC, ZERO accidents were reported in 2021. The table below summarizes some of the most important indicators used by the Extended Reporting Group to measure its H&S performance.

At Motor Oil Group we have developed the golden rules for Health and Safety, which all employees, management, contractors and visitors are expected to comply with. They have been developed both by taking into consideration international safety guidelines and internal review of incidents/accidents that have occurred in the past. As a result, everyone involved, carries the responsibility of abiding with the specific set of rules.

Enhancing our Safety Culture Through Training and Communications

Enhanced safety culture is crucial for safeguarding health and safety. To this extent, and in order to ensure continuous improvement and a strong awareness for employees, contractors, business partners and other stakeholders in safety issues, the Reporting Group has designed and implements a comprehensive QHSSE training program on annual basis, including drills, safety meetings, conferences, topic specific courses and lessons from Incidents (LFIs), as well as relevant internal communication campaigns and publications.

Training programs on Health and Safety during 2021: Some of the training programs conducted during 2021 are summarized below:

- Training provided to the Motor Oil’s staff and collaborating contractors (over 6,223 people in total), by a competent certified training organization continued for yet another year.
- Work permit – issuers/receivers.
- Safety orientation training to new employees.
- Emergency response plan to new engineers.
- Electronic work permit issuing system to all involved supervisors, foremen, operators.
- Use of firefighting means, fire extinguishers, and breathing apparatuses to all new employees concerned.
- Firefighting crews theoretical and practical training on emergency response as well as firefighting drills.
- Safety training of contractors for refinery general rules as well as on work permit system, from a third party. The training program was offered to more than 1.000 contractors.
- Training in Protective Preventive equipment (PPE) regarding the breathing protection.

Road Safety

During 2021, training programs were also delivered to numerous drivers of privately and publicly owned vehicles on subjects relevant to their activities. Fuels are classified as dangerous goods, therefore in order to be safely transported measures need to be taken at three levels/tiers:

- Ensuring technical adequacy of the transporting equipment, i.e., the tank trucks.
- Establishing strict procedures and continuous monitoring of their implementation.
- Training of the drivers and keeping them updated on a continual basis.

Protecting Personnel’s Health

Motor Oil provides its personnel with full access to medical services. Its facilities include a central clinic with doctors and nursing personnel, equipped with all essential supplies, defibrillators, medicinal and other specialized materials (bandages for burns, neutralizing chemicals) ready to respond to emergency cases, manage chronic illnesses, provide information on health issues and organize blood donations. These services are available to all personnel during working hours not only for occupational accidents and emergency cases, but also pre-emptively. To this extent, allowance has been made for occupational physicians to prescribe screening examinations and instruct general medical procedures, for the Reporting Group. There is also a fully equipped first-aid station at the alkylation unit, with a nurse available 24-hours, as well as three properly equipped first aid stations and five ambulances.

Working with our Business Partners and Suppliers on Health and Safety Impact

The Reporting Group’s Health and Safety rules are extended also to business partners and suppliers. There is continuous collaboration and constant improvement with actions that include:

- Safety observations, whereby contractor companies receive feedback on a daily basis, with a view to monitor their performance on safety issues, reward good practice, and immediately implement corrective actions.
- Workshops aimed at raising contractor awareness and actively involve them in safety issues.
- Meetings prior to critical projects, whereby all contractors’ safety engineers and technicians participate in order to receive information on safety issues.

Safety at our Port Facilities

Ensuring maximum safety levels at our port facilities is another area of our focus. Safety measures at port facilities are of great importance, since they ensure a smooth workflow at the refinery, and marine environment’s protection from any pollution. Notably, Motor Oil Group was the first Greek company to be certified by the Ministry of Maritime Affairs for compliance with the International Ship and Port Facility Security (ISPS) Code, which is applied according to the requirements of chapter XI-2 of the International Convention for the Safety of Life at Sea (SOLAS). The accreditation is reviewed every year, in line with the existing legislative provisions.

Covid-19 Response

As the Covid-19 pandemic continued evolving also during 2021, we remined focused in protecting our staff’s health and safety, but also contractors, visitors, as well as the local communities were we operate. Moreover since 2020 and until now, the Company and all major Greek based subsidiaries of the Group utilize the new fiscal and tax policies and regulations of the state regarding the non-payment of the tax advance etc., thus securing additional liquidity. Furthermore, the subsidiaries of the Group which rent retail fuel outlets applied the relevant amendment regarding the rent reductions due to the COVID-19. It should also be noted that since the early stages of witnessing the coronavirus incidents in the domestic front, the Group set out emergency plans to ensure the continuity of its core business and the uninterrupted provision of its services. Based on the above, the Group took all the necessary measures to protect the health of all its employees and to avoid the coronavirus spread in its premises.

Emergency Response Plans

MOTOR OIL Group has developed emergency preparedness & response plans, thus ensuring maximum safety during its operation. All MOTOR OIL Group’s facilities have made emergency response arrangements based on the Emergency Response Plan, which is regularly reviewed and updated so as to take into account any changing legal requirements and revised “best practices”, resulting either from technical advancements or experience gained by peers in dealing with minor or major accidents. Moreover, we prepare and submit appropriate studies to the relevant authorities, in accordance with the EU Seveso III Directive, covering the most likely accident scenarios, as well as relative prevention and response measures. In the Emergency Response Plans, public health protection measures are described, including warnings and related advice for neighbouring communities, that would be put into effect in the event response plans are activated because of a major technological accident. These plans are drafted by the competent authorities and determine how the State might intervene in emergency situations. MOTOR OIL Group maintains an emergency response system at its facilities, which includes studies, procedures and different response plans depending on the situation (fire, earthquake, terrorist act, flood, etc.). It has also organized emergency teams (fire brigades, evacuation teams, etc.), training programs and preparedness exercises. Finally, it has a set of plans and processes (e.g., internal emergency plans, fuel shortage plan, Group emergency corporate plan, BCP, etc.) for all possible emergency situations

Training Programs and Topics

The parameters determining the planning and implementation of the training and development programs are the educational needs of the workforce as identified in the working environment each year. Generally, education and training programs cover the following areas:

Training in business and administrative skills, computer skills, as well as personal development.
Introductory training for new engineers, operators and maintenance technicians.
Skills training for technical staff relevant to their fields, as well as training for the use of safety equipment and machinery/equipment.
Training regarding Health, Safety, Environmental Protection and Quality, with an emphasis on the special features of every workplace.
Training of non-technical staff in basic Health and Safety regulations, use of fire-fighting equipment and first aid provision.
Instruction in safe driving techniques and in the procedures for the safe loading, unloading and transport of fuels.
Emergency preparedness exercises, including scheduled or unscheduled drills.

The educational and training programs are implemented through in-house seminars, by attending domestic or international seminars run by internationally recognized educational centers. On that note, the Reporting Group’s managers attend conferences both in Greece and abroad, participate in undergraduate and postgraduate courses, whilst being kept up to date through the purchase of books and subscriptions to specialist technical journals and professional associations. Additionally, Motor Oil Group can offer its employees transition assistance programs provided to facilitate continued employability, alongside training programs tailored to provide more general/soft skills in the form of lifelong learning (L&D) but also more technical disciplines. As a result, participants can improve their professional skills, (e.g., their presentation, communication, negotiation, time management and interviewing skills) as well as broader ones like business networking, well-being and mental health. In Motor Oil Group, there is no end-of-career management program, other than continuous safety insurance after retirement. Leadership academy and management training Our aim is to continually cater for our management’s training needs and thus offer them the appropriate skills development programs through cooperations with top educational institutions and bodies. Specifically, the following programs were held, with certification by Harvard University, to teach leadership skills: Leadership Academy Step 1: The objective of this training was to develop the skills necessary for all new managers to enable them to lead their teams and cultivate relationships with their colleagues and supervisors. Leadership Academy Step 2: The purpose was to further develop the skills required of every manager in order to handle a variety of business challenges that have a direct impact on the success of their work. In order to train control room operators, the refinery makes use of production unit training simulators relevant to the Hydrocracker, Fluid Catalytic Cracking and Crude Distillation Units as well as a general use simulator for the training of field operators for chamber positions, and for assisting field operators. To assist this process, there are also online educational materials (e-books, conference presentations, educational videos, etc.), whilst training manuals for technical matters are available as well. Finally, in order to further raise awareness in security issues, short videos with targeted content are systematically shown at buildings used by field operators.

Training and Development in 2021

Despite the continuation of Covid pandemic during 2021, we continued our extensive training and development program, while taking all necessary protection measures. Training hours for the Reporting Group during 2021 totaled to 43,696 hrs, while the overall cost for training amounted to 721thousand euros, with the participation of 2,214 employees (96% of the total workforce), of which 12 were managers and 2,202 other personnel. The principal subjects covered by contracted training at the refinery during 2021 are summarized below:

Operations – Training for new naphtha complex units has started in parallel with the construction works. Certifications were undertaken for crucial skills (jetty loading masters) or legislative requirements (boiler operators).
Process Safety – Includes HAZOP/LOPA trainings for new engineers, followed by workshops and practical training. There is a direct impact on overall safety level improvement.
Engineering – Process simulators training basics and reactor models. Simulators are used for process monitoring and decision making. Projects on new technologies such as hydrogen and carbon capture, always start with training.
Maintenance & Inspection – Areas are both safety and technical focused. Topics included project management, rigging operations safety, reliability improvement, damage mechanisms for materials and equipment, rotating equipment alignment tools, etc.
Occupational Safety – Safety technicians were certified as ADR consultants. All refinery personnel working at heights have been certified. New electronic work permitting system implementation started with training.
Rescue – Certification for rescue team started at IRATA/level-1, the baseline standard for working at heights.
Quality – New and existing staff went through Internal auditor training to boost quality audit competence. All engineering staff went through awareness training for management of change and quality tools.
Management & Soft skills – These focus on both executive and line staff and include long trainings (MBAs, waste management, warehouse lean management, procurement operations) and typical short seminars (time management etc). A two year program has started to refresh practical management skills for all foremen.
Digitilization – New software has been added (Microsoft 365, SAP Successfactors), older platforms were exploited (Dasault Enovia), basic technical software skills were required by more users (Autocad/Excel).

Automation systems are being upgraded and converge over time with IT systems, requiring more maintenance skills (Honeywell DCS). Also new augmented reality wearables were added as a pilot (Realwear). The contribution of the Reporting Group’s executives to the in-house training and education program was also very important. In 2021 this involvement accounted for about 8,000 hours. The table below shows the average training man-hours per gender and employee category. Based on the information presented, a total of 13.1hrs per employee were devoted to training as an average for 2021. In terms of employee categories, senior management received an average of 24.9hrs, followed by white and blue collar employees, who received an average of 19.5hrs and 11.5hrs, respectively.

Motor Oil Group considers continuous learning a key element for success in the workplace, thus in 2021 the Reporting Group facilitated 9 employees’ endeavors to achieve postgraduate qualifications and excel in their work areas, by covering their tuition fees. Moreover, in 2021, LPC developed staff training programs such as seminars, training in R&D / process workers, Hazard & Operability training (HAZOP), equipment inspection training (NDTs), weekly firefighting training, contractors, etc., lasting a total of about 800 hours.

Employees well being

MOTOR OIL Group, aiming to provide a high level of work-life balance and employee welfare, offers a wide range of additional benefits to its staff and their family members, beyond those defined by applicable law as minimum. Such employee benefits are insurance policies providing both pension and medical treatment coverage for employees, schemes helping employees with the costs of their children’s education, Christmas parties for employees’ children, long service awards, support for employees participating in sporting activities, etc. Benefits are provided to all employees in accordance with their position/rank rather than their type of employment contract (full/part time).

See more in our Corporate Sustainability Report, p. 118-133, 144-146, 149-151, 152-153 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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PERFORMANCE INDICATORS

SRS 403-2: Τύπος και ποσοστά τραυματισμών, επαγγελματικών ασθενειών, απώλειας ημερών εργασίας και απουσιών εργαζομένων και αριθμός θανατηφόρων εργατικών ατυχημάτων.

None of the accidents recorded during 2021 was high consequence or fatal. All Group companies conduct risk assessments regarding occupational hazards and have identified potential hazards, such as chemical hazards, electrical, falls from height, confined spaces or misuse of equipment. The main injuries that occurred from the incidents during 2021 were trips and falls, thermal burn, hand struck and minor scratches for employees and contractors.

SRS 403-4: Θέματα Υγείας & Ασφάλειας που καλύπτονται στις επίσημες συμβάσεις με τα συνδικάτα.

Local Safety Committee is a joint committee that represents all workers and contractors and comprises of the Reporting Group’s management and staff representatives. The Committee’s role is to organize meetings (at least 4 times per year) at various locations (offices, depots, drivers etc.), in order to discuss, assess and control health and safety hazards. As soon as the risks are identified and evaluated, a mitigation process is being initiated according to the Manual of Authorities (MoA). The decision-making is regulated both by MoA and organizational arrangements. The Local Safety Committee’s meetings are organized by the Local Manager. In such meetings, there is strong participation of QHSSE Advisors, Technical Inspectors, Occupational Hygienists and a Safety Technician. Local Safety Committee meetings are part of the annual QHSSE plans. Finally, it should be highlighted that full cooperation exists between staff unions and representatives regarding Health and Safety issues.

SRS 404-1: Μέσος όρος ωρών εκπαίδευσης ανά έτος ανά εργαζόμενο.

SRS 406-1: Περιστατικά διακρίσεων και διορθωτικές ενέργειες.

During 2021, no incidents of discrimination were reported.

See all indicators in our Corporate Sustainability Report, ESG Performance Index, p. 187-195 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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16. Qualifications

ADMINISTRATIVE PRACTICES

We cultivate an environment of excellence, respect and trust, where all employees feel empowered and truly believe in what they do. This environment sets the foundation for the development, empowerment and prosperity of our people resulting this way into a positive impact on our partners, customers and the local communities where we operate.

By the end of 2021, Motor Oil Group employed 2,990 employees in total, out of which 2,479 are employees of the Extended Reporting Group.

The permanent employees (men and women) for the Extended Reporting Group account for 94% of our total workforce, 43% of employees are based at Ag. Theodoroi, and the majority of them are employed full time. The most significant portion of the Extended Reporting Group’s activities is performed by its employees, whereas in some cases, work is also carried out by contractors. There were no significant seasonal variations in the numbers of employees, for the year 2021. During 2021, the majority of staff are on a permanent contract (76% men, 18% women), with temporary staff accommodating for only 4% (men) and 2% (women) of the total workforce.

Motor oil’s most important “Significant location of operation” is the refinery at Agioi Theodoroi, Corinth, where in 2021 1,053 people were employed. Approximately 65% of the refinery’s (full time) staff and 30% of its senior managers12, live in the greater region of Corinth, where Motor Oil is the biggest employer. All Extended Reporting Group’s staff (100%) is covered by collective bargaining agreements.

Workforce Breakdown and Professional Advancement

In 2021, senior managers comprised approximately 3.5% of the total personnel of the Extended Reporting Group, while technicians-operators and administrative personnel accounted for 96.5%. Each employee has the opportunity for promotion within the management hierarchy, according to his qualifications and performance, as the main objective is to fill vacant managerial positions from within the Motor Oil Group wherever and whenever possible. In fact, each vacancy is first advertised internally; the position becomes available for external applicants only if no suitable internal candidate can be found. During 2021, in the Extended Reporting Group, there were 15% new employee hires, while the turnover percentage was 9%. Specifically, in the table below, there is an in-detail analysis of the recruitments and turnovers in 2021 per gender, age group and region for the Extended Reporting Group. Return to work rate and employee retention rate were 100% and 88%, respectively, for the Reporting Group. The majority of field-based employees are men (94%), whereas the majority of women work as office-based personnel (35%). Agewise, 90% of the BoD are over 50, with the remaining 10% falling in the 30-50 category. Finally, the highest percentages in relation to staff under 30 years old are located in the office-based employees (11%) and the field-based employees (8%).

Talent Acquisition

Our employees are our most valuable resource, essential to the achievement of our strategic goals, to the implementation of our growth business plans and in ensuring our long-term competitiveness. For this reason, for vacancies and new positions, which need to be covered by the Group Talent Acquisition Team, internal candidates that are interested in a vacancy and who meet the essential skills and qualifications required from the jobholder, are primarily considered for the vacancy. If this case is not applicable for any reason, a search begins in the external labour market, in order to attract and hire high calibre candidates. The Group Talent Acquisition Team aims to attract, assess and hire candidates with the necessary skills and behaviours for the respective job position they cover. The Group commits, to hire its people according to their personal values, and to apply the criteria directly related to each role (specific requirements on academic background, technical skillset, working experience, competencies, business behaviours, personality traits). MOTOR OIL Group aims to effectively promote the potential of our people, motives and skills, giving them the opportunity to undertake new roles.

Employee Performance Management

At MOTOR OIL Group we believe that a company’s success is greatly determined by its talented and skilled workforce. We are therefore always aware of aligning our employees, resources and systems to our strategic objectives.

Considering that the Group has almost 2,990 employees who perform different activities under varied setups (HQ, Refinery, Commercial, Retail), the Group implemented a performance management system to ensure meritocracy and consistency, as well as to nurture a high-performance culture. MOTOR OIL Group lays the foundation for a solid succession-planning approach by setting its main functioning objectives:

To be financially healthy and performing according to expectations and set targets
To fully satisfy customers’ needs and expectations
To support the social and environmental company’s objectives
To operate in an effectively and efficient manner, based on a selected operating model and strategy
To engage and enable its people.

Our employee performance evaluation system includes objectives and KPIs related to Groups’ ESG goals and targets. Performance Standards are the important work requirements, the observance of which is mandatory for an employee in order to perform the relevant duties efficiently and effectively. Performance Standards are used to evaluate the performance of roles that have not set Objectives, due to the difficulty of setting measurable objectives for them.

Additional benefits

See more in our Corporate Sustainability Report, p. 136-143, ESG και Βιωσιμότητα – Motor Oil (moh.gr)

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17. Human Rights in the supply chain

ADMINISTRATIVE PRACTICES

Aiming to provide support and guidance to its staff regarding their behavior and actions during day-to-day activities, MOTOR OIL Group has developed and implements a Code of Conduct.

Supply chain

Motor Oil Group has incorporated a collaborative mentality that promotes mutual-win relationships. In that respect, the Group is fostering balanced relationships with its partners and suppliers, which are governed by trust, integrity and transparency. Constant aim of the Group is to implement the principles of sustainable development not just in the context of its operation, but also in the sphere of its influence, including its partners and suppliers.

A sustainable supply chain not only minimizes social and environmental risks, but also serves as an example of values and success for the industry and the community. For that reason, MOTOR OIL Group assesses its potential suppliers not solely based on the cost, quality, delivery, and their economic viability, but also on QHSSE and ESG criteria. The Group collaborates with a large number of suppliers both locally and at international level. The main categories of suppliers that the company engages with, fall under the following broad categories: raw materials, contractors, service providers, equipment and infrastructure. Strong suppliers’ partnerships are very crucial for our sustainable development. We recognize the importance of working with suppliers and contractors that respect the same values as we do. In that context, suppliers are asked to complete specific questionnaires/forms detailing their ability to safeguard the quality of products and services provided, as well as the environmental impact of their activities and the health and safety systems they follow. We expect our suppliers to follow similar ESG objectives across their activities and operations to maximize impact and meet our sustainability goals. For example, contractors working at the refinery and other installations follow a comprehensive program of safety training, with the objective to achieve “Goal Zero”, i.e., zero accidents. In 2022, Avin Oil plans to expand the questionnaire concerning the Suppliers / Contractors of the company and the integration of information regarding Sustainable Development and how the respective Supplier / Contractor implements environmentally friendly practices and Health and Safety and what actions it takes based on Sustainable Development. Thanks to the implementation of the Sustainable Supply Chain Policies, the company ensures the supply of high-quality products and services and at the same time motivates steps towards Sustainable Development at all levels through its collaborations. Similar procedures apply to Avin Oil ‘s subsidiary, Makreon.

Development at all levels through its collaborations. Similar procedures apply to Avin Oil ‘s subsidiary, Makreon. By creating and implementing procedures through the Group’s Purchasing Organization Coral Gas has been able to establish long periods of cooperation with zero rejections and quality suppliers. Also, LPC suppliers are assessed to provide products or services, accompanied by quality specifications by the product users. In certain occasions, raw materials suppliers’ installations may be visited for onsite inspection to check on any gaps on production/warehousing/distribution process. MORE is supporting local communities by using local contractors for all its projects. Additionally, they work with large foreign suppliers ensuring the implementation of ISO 14001 certificates in all its projects. OFC on the other hand verifies that contractors have paid their employees’ contributions. Additionally, they should follow environmental requirements for projects taking place in the company’s facilities.

LPC suppliers are assessed to provide products or services, accompanied by quality specifications by the product users. In certain occasions, raw materials suppliers’ installations may be visited for onsite inspection to check on any gaps on production/warehousing/distribution process.
Avin Oil, prior the collaboration with any new supplier, requests information that concern both the procedures that govern the operations of the prospective partner company, as well as any certificates it holds regarding Environment and Health & Safety. The evaluation is conducted through AVIN’s internal process for the inclusion of suppliers in the Approved Register of Suppliers and contractors. The criteria used include compliance with safety rules of the Refinery and construction sites in case of work at facilities or service stations. In AVIN’s annual evaluation of suppliers and contractors, possible issues of non-compliance in the protection of the environment are taken into account, and where required, prescribed penalties are imposed.
OFC on the other hand, verifies that contractors have paid their employees’ contributions. Additionally, they should follow environmental requirements for projects taking place in the company’s facilities.
During 2021, the SUPREME program was realized at Motor Oil’s refinery, which purpose was to evaluate the performance of designated contractors in Health, Safety & Environment and their accompanying management systems. The program was implemented in collaboration with DNV and serves as a security culture enhancement program including evaluation of current contractors. Upon completion, all contractors will be evaluated. The program includes 12 contractors, and so far, the evaluation has been completed in 4.

We higly value our business principles, and we seek to collaborate with suppliers that share the same values with us. For that reason, the Group is developing a Supplier Code of Conduct, incorporating certain principals, and asking the suppliers committing to these.

Working with our Business Partners and Suppliers on Health and Safety Impacts

A continuous evaluation of the contractors’ performance on safety issues is being conducted, along with specialized training on yearly basis. Specifically, during 2021, a pilot program was implemented, for the evaluation of contractors by an independent third-party that examined their health and safety management systems and safety performance. This evaluation is part of the continuous improvement aiming at surpassing the company’s requirements and standards of Health and Safety. During 2021, a total of 4,338 contractors’ employees received training on key safety issues and best international practices from trainers with extensive experience in the refinery sector. Following the end of the training, participants went through examinations, and just those who successfully completed the course received an entrance card and the right to work at the refinery.

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PERFORMANCE INDICATORS

SRS 412-3: Σημαντικές επενδυτικές συμφωνίες και συμβάσεις που περιλαμβάνουν όρους για τα ανθρώπινα δικαιώματα ή έχουν υποβληθεί σε έλεγχο σχετικά με το σεβασμό των ανθρωπίνων δικαιωμάτων.

See also in our Corporate Sustainability Report, p. 153, ESG και Βιωσιμότητα – Motor Oil (moh.gr)

See also in our Corporate Sustainability Report, p. 135, ESG και Βιωσιμότητα – Motor Oil (moh.gr)

Reference can be made to Code of Conduct https://www.moh.gr/politikes/

SRS 412-1: Λειτουργίες για τις οποίες έχουν πραγματοποιηθεί ανασκοπήσεις για τα ανθρώπινα δικαιώματα ή αξιολογήσεις επιπτώσεων.

Reference can be made to Code of Conduct https://www.moh.gr/politikes/

SRS 414-1: Νέοι προμηθευτές που έχουν υποβληθεί σε έλεγχο με βάση κοινωνικά κριτήρια.

	2020	2021
Suppliers assessed with environmental & social criteria	30	86

SRS 414-2: Αρνητικές επιπτώσεις στην εφοδιαστική αλυσίδα με βάση κοινωνικά κριτήρια και σχετικές διορθωτικές ενέργειες.

No suppliers with significant actual and potential negative social impacts have been identified.

See all indicators in our Corporate Sustainability Report, ESG Performance Index, p. 187-195 ESG και Βιωσιμότητα – Motor Oil (moh.gr)

Attached Files: There are no files

18. Corporate Citizenship

ADMINISTRATIVE PRACTICES

Another strategic objective of the Group is to always contribute to the prosperity of local communities through job creation, support of local economies, local initiatives and organizations

MOTOR OIL Group aims to expand its philanthropic footprint every year, hence pursues to build constructive relationships with the local communities in which it operates, by fostering a climate of trust and respect. More specifically, local communities are supported by the Group, through programs that enhance the economic, social, and cultural life and overall, help society thrive. MOTOR OIL Group makes direct or indirect financial contributions to a large number of businesses and families in the area, while supports local initiatives and encourages entrepreneurship, in a general effort to improve the well-being of the communities in which it operates. It should be noted that 60% of the employees at the refinery, come from neighboring municipalities. The Group’s Sustainability Strategy regarding social welfare, is driven by individuals’ needs and society’s goals, always in alignment with the 17 Sustainable Development Goals (SDGs), demonstrating a strong commitment to tackle major societal issues, as expressed by the UN Global Contact. More specifically, in 2021 the Group implemented a community contribution policy for donations and sponsorships, mainly addressed to local communities, in accordance with the SDGs, based on their potential positive impact on our four Community Contribution Pillars.

These can be described below along with some indicative actions:

Arts, Culture & Sports

The Group understand the importance of sports and culture in the local communities and annually contributes for the improvement and maintenance of the local athletic facilities but also sponsors local sports, cultural events, and local communication channels. In the field of Sports, the Group supported several sport clubs in Crete and Peloponnese in terms of infrastructure maintenance and sponsorship for the upcoming seasons. Most notably, Avin Oil, became a proud sponsor of Olympic champion, Stefanos Ntouskos highlighting the fact that sports, in the wider sense, represent values that society needs, such as hard work, perseverance, discipline, effort and above all ethos. In the field culture and arts the Group supported several environmental and cultural programs in the areas of Spetses, Hydra and Dokos while it sponsored 12th International Film Festival of Corinthia Peloponnese – ‘’GEFYRES”. It also contributed as a sponsor to music events in in the wider Athens area.

Land and Sea

In 2021 MOTOR OIL Group as part of its Forests programme, adopted the national warehouse of forest seeds, Amygdaleza (the only supplier of certified seeds for the public and private nurseries of the country) to further develop and equip with technology machinery aiming to be converted into a National Bank for the Conservation of Forest Genetic Material. Moreover, for the 2nd consecutive year, volunteer employees of the Motor Oil Group participated in a symbolic cleaning of schinias beach organized by Avinoil,under the ‘’paralies programme’’, with its ambassador, olympic gold medalist Stefanos Ntouskos, as a guest. AVIN’s actions from June to September 2022 resulted in the collection in the specially designed bins of about 1.7 tons of waste (from plastic, paper, aluminum, glass and mixed waste) an increase of 70% from last year’s toll. In fact, it is worth mentioning that almost half of the waste collected this year was plastic (~ 807kg), while in second place was glass waste (~566kg). In the same manner NRG supported Ultra-distance swimmer Spyros Chrysikopoulos, who covered a distance of 130 kilometers in 64 hours and 5 minutes swimming from Rhodes to Kastellorizo with the aim of raising public awareness about the environmental protection.

Education and Innovation

This year, Motor Oil Group supported a student from local community that excelled in the national school exams. Giannis made the path to success a reality and the Motor Oil Group, wanting to reward his effort, offers him his first car and fuel from its subsidiary Coral AE (Shell Licensee). AVIN, as part of its commitment to innovative actions that respect the environment, implemented the Plastic Free initiative in the AVIN loyalty program. Users of the AVIN loyalty program are invited to recycle their plastic card in one of the special bins located at AVIN gas stations and download the AVIN Earn app, earning an additional 150 points. The goal of the Plastic Free action is, on the one hand, for AVIN to reduce its environmental footprint, and on the other hand, to raise awareness among consumers about how our daily lives affect the environment. Furthermore, the Group cooperated with the Foundation for Research and Technology - Hellas (FORTH), with the aim of piloting the application and maturation of applied research and innovation products in the fields of energy transition, but also digital transformation.

Local Communities & Society

In 2021, the Group made a significant contribution to the village for the Earthquake victims of Archalochori in Crete. The Group recognizes the need of socially vulnerable groups and made charitable donations in value and in kind like heating oil (more than 200,000 liters in 2021) to schools, institutions, and churches. Avin Oil this year contributed motor fuels for public purposes, e.g. ITHACA, Symplefsis. At the same time, in the context of the COVID-19 pandemic, Avin Oil with a high sense of social responsibility, supported the movements of doctors and nurses who fight daily in Intensive Care Units in the fight against COVID-19. In this context, AVIN offered prepaid fuel cards to doctors and nurses who are on the front lines of Intensive Care Units in all hospitals in Greece, thus helping to cover part of their travel expenses. In total, the company offered prepaid fuel cards to more than 4,300 doctors and nurses, a donation that exceeded €300,000. In the same contexts Motor Oil donated almost €100,000 to the laboratory of hygiene-epidemiology & medical statistics laboratory of Athens Medical School for Covid-19 related research initiative. MOTOR OIL also upgraded its data center and donated to the Hellenic National Defense General Staff a significant number of outdated data center equipment including storage boxes, servers, switches, racks, cables etc.

Social Product

MOTOR OIL Group with close to 3,000 employees, generates shared value for all its stakeholders, including its customers, employees, shareholders and other providers of capital, suppliers, local communities, the state, as well as the society in general.

MOTOR OIL’s vision is to be a leading sustainable energy corporation in Greece and the wider region. To succeed in this objective, it focuses on the following three key targets:

Maximization and optimization of sales, by effectively marketing the refinery products and exploiting opportunities in the company’s’ three markets of operations (domestic, aviation/shipping, and exports), for achieving the best possible profitability.
Maximization of financial returns and the refinery’s profit margins.
Achieving the highest H&S standards, environmental protection and quality through the application of technical and operational adaptations and improvements.

The scale of the Group’s operations, combined with its consistent focus on steady growth, result in a very significant contribution to the country’s economic development. This contribution, springs from the successful outcome of its activities and is made through the value generation for its stakeholders, which includes job creation, payment of taxes and social contributions, as well as its contribution to the broader social progress.

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PERFORMANCE INDICATORS

SRS-201-1: Άμεση οικονομική αξία που δημιουργείται και διανέμεται.

Economic value distributed: 636 m €
Economic value retained: 9,680 m €
232m € operating costs
196m € in employee salaries & benefits
56m € in tax payments
152m € of payments in capital providers
2.3m € community investments

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19. Initiatives and Political Influence

ADMINISTRATIVE PRACTICES

Ratings and ESG initiatives

The Group responds to all ESG requests and various independent assessments from stakeholders and ESG rating agencies.

Participation in Organizations

Throughout 2021, as we are more concerned about climate risk and becoming an integrated energy company, we were engaged in several workshops on climate policy proposals and energy initiatives supported by various organisations:

The UN Global Compact Network.
The Hellenic Network for Corporate Social Responsibility.
The Hellenic Petroleum Marketing Companies Association (SEEPE).
Federation of Recycling and Energy Recovery Industries & Enterprises (SEPAN).
Fuels Europe, European Petroleum Refiners Association
CONCAWE (CONservation of Clean Air and Water in Europe)
Hydrogen Europe
World LPG Association.
European LPG Association.
Oil Companies International Marine Forum (OCIMF)
Mediterranean Oil Industry Group (MOIG),
The Hellenic Federation of Enterprises (SEV).
The Athens Chamber of Commerce and Industry, the Hellenic-American and Arab-Hellenic Chambers, as well as other regional Chambers.
The Hellenic Association of Independent Power Producers.
The Hellenic Association of Energy Suppliers (ESPEN).
The Union of the European Lubricants Industry (UEIL).
The European Lubricating Grease Institute (ELGI).
Biomass Biofuel Sustainability Voluntary Scheme (2BSVS).
The Union of Listed Companies, etc.

Public Policy has not come up as material issue in our materiality analysis. The Group participate and contribute by giving constructive input in public committees to support the development of effective tax legislation and administration.

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PERFORMANCE INDICATORS

SRS-415-1: Συνεισφορά σε πολιτικά κόμματα

MOTOR OIL does not make any financial or in-kind political contributions.

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20. Corruption prevention and alleviation

ADMINISTRATIVE PRACTICES

Transparency & Ethics, Anti-corruption & Anti-competitive Practices

In an effort to enhance its sustainability strategy and embrace new ways to fully support its employees and other interested parties, the Group is designing policies regarding diversity, equity & inclusion (compliant with Anti-discrimination Law), as well as anti-competitiveness, anti-corruption & anti-bribery. Furthermore, the Company is enhancing its grievance and whistleblowing policy mechanism to establish that internal reporting is functional and offers comprehensive protection and support to reporting people. At MOTOR OIL Group, business ethics are embedded in our corporate governance principles and constitute the framework of our social and environmental responsibility. MOTOR OIL Group constitutes a modern energy group that is constantly expanding and creating value with consistency and responsibility. It acknowledges that the production of trust and goodwill is essential for the Group’s sustainable development and economic growth, in order to safeguard its excellent reputation among employees, partners, investors and other interested parties. Therefore, the Group aims at conducting business in accordance with the highest ethical standards, showing zero-tolerance in all forms of bribery and corruption.

Transparency and Business Ethics

Corporate Governance Code & Policies

In 2021 the Group further developed and enhanced policies regarding certain areas such as

Whistleblowing
Anti-bribery and anticorruption

In 2021 the Group enhanced further the Anti-Bribery and Anti-Corruption Policy, committing itself with great responsibility and business integrity, to endeavor the utmost efforts for securing transparency and legitimacy. The specific policy helps outline the Group’s risks related to bribery and corruption, describes the prohibited activities and the approval processes for permissible activities, highlights the responsibilities of the respective parties under both the relevant anti-corruption laws and Group’s policies, and finally sets up the processes for the investigation of breaches and disciplinary measures in case of violations. This policy also aims at protecting the reputation of the Group’s companies and employees and helps avoid potential civil and criminal fines. The policy gets reviewed and updated by the ESG Board Committee, whilst the Company’s Compliance Office, with the support of the Legal Services, is responsible for monitoring on a regular basis, for any possible changes on the respective legal framework.

Moreover, a Group Whistleblowing Policy was approved as a Breach Reporting Policy compiled in harmonization with the provisions of the EU Directive 1937/2019 and the international best practices of corporate governance.

Anti-corruption & Anti-competitive Practices

Corruption is directly linked to environmental degradation, the infringement of human and labor rights, and the violation of laws. Preventing and combating corruption is a high priority for the whole Group and its stakeholders. Its commitment to fight against corruption is manifested in the adoption of the United Nations Global Compact, which explicitly refers to actively combating corruption (Principle 10) and in the fact that all necessary actions have been taken to prevent any such incidents from taking place. The Group’s policy concerning anti-corruption and anti-bribery is to adhere to the standards of ethics at the highest level in the conduct of its business activities and affairs. These standards can be achieved and sustained only through the full commitment of the entire staff and interested parties of the Group. It is the duty of every employee to behave in a way that ensures compliance with these standards, while indifference to the principles and procedures regarding anti-corruption and anti-bribery set out by the Group, may lead to appropriate disciplinary actions.

Our Operating Principles have been communicated to all employees and associates through the Company’s website: www.moh.gr. The Business Principles of MOTOR OIL Group, which also elaborate on ethical issues, are communicated to all interested parties through training, contracts, evaluations, etc. More specifically, managers, department heads and marketing staff, are trained on an annual basis on competition law. Anti-corruption and ethical business practices are considered as crucial by the stakeholders of the Group during our latest materiality assessment. As a Group, we work hard to ensure that all of our activities are regulated by transparency, integrity and professionalism, we have thus undertaken all necessary actions to prevent any incidents related to corruption.

Whistleblowing and Grievance Mechanism

The Group has taken care to establish multiple reporting channels. Any employee suspecting that one of the above wrongdoings is occurring, initially contacts, in person or over the telephone or through an email, her/his direct supervisor or manager. In case s/he has qualms (e.g. fears retaliation or suspects her/his supervisor’s or manager’s involvement), s/he may contact any of the three members of the Reports Management Committee. If, however, the employee continues to have qualms, s/he may report her/his suspicions and give information on the anonymous and confidential reporting electronic platform. External Partners wishing to submit a report can use the anonymous and confidential reporting platform.

Internal Audit, Risk Management & Compliance

Attached Files: There are no files

PERFORMANCE INDICATORS

SRS-205-1: Λειτουργίες που αξιολογήθηκαν για κινδύνους που σχετίζονται με τη διαφθορά.

SRS-205-3: Επιβεβαιωμένα περιστατικά διαφθοράς και διορθωτικές ενέργειες.

SRS-419-1: Μη συμμόρφωση με τη νομοθεσία και τους κανονισμούς σε κοινωνικο-οικονομικά θέματα.

This year, there were no confirmed incidents of corruption involving our employees or associates, nor were we fined or penalized for failure or inability to comply with the relevant laws and regulations. Additionally, there were no public legal cases regarding corruption brought against the organization or its employees during the reporting period.

Attached Files: There are no files

ΜΟΤΟΡ ΟΙΛ

GENERAL ΜΟΤΟΡ ΟΙΛ

Company Profile

Management Message

COMFORMITY STATEMENT ΜΟΤΟΡ ΟΙΛ

STRATEGY

1. Strategic, Analysis & Action

ADMINISTRATIVE PRACTICES

2. Materiality

ADMINISTRATIVE PRACTICES

3. Objectives

ADMINISTRATIVE PRACTICES

4. Management of Value Chain

ADMINISTRATIVE PRACTICES

PROCEDURES

5. Responsibility

ADMINISTRATIVE PRACTICES

6. Rules & Processes

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

7. Monitoring

ADMINISTRATIVE PRACTICES

8. Incentive and reward systems for Sustainable Development

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

9. Stakeholder Engagement

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

10. Product Responsibility and Innovation

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

ENVIRONMENT

11. Usage of Natural Resources

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

12. Resource Management

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

13. Climate-relevant emissions

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

SOCIETY

14. Employment Rights

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

15. Equal Opportunities

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

16. Qualifications

ADMINISTRATIVE PRACTICES

17. Human Rights in the supply chain

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

18. Corporate Citizenship

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

19. Initiatives and Political Influence

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

20. Corruption prevention and alleviation

ADMINISTRATIVE PRACTICES

PERFORMANCE INDICATORS

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Με την Συνεργασία

Με την συμμετοχή

GENERAL
ΜΟΤΟΡ ΟΙΛ

COMFORMITY STATEMENT
ΜΟΤΟΡ ΟΙΛ