ΟΡΓΑΝΙΣΜΟΣ ΠΡΟΓΝΩΣΤΙΚΩΝ ΠΟΔΟΣΦΑΙΡΟΥ Α.Ε. (ΟΠΑΠ Α.Ε.)

1. Strategic, Analysis & Action

ADMINISTRATIVE PRACTICES

Οur business model lays out the key decision-making foundations that govern our actions and initiatives in order to achieve our business goals, delivering top-quality products and services, fostering employee training and development, maintaining strong communication channels with our agents and suppliers and fulfilling our corporate responsibility mandate. OPA operates in one of the most well established and dynamic business sectors, the Greek gaming sector. It consists of the following six main subsectors:

• Numerical games.
• Sports betting and horseracing mutual betting.
• Video Lottery Terminals (VLTs).
• Instant and passive lotteries.
• Casinos (includes all games played within casinos).
• Online offshore.

In 2018, Gross Gaming Revenues (GGR) from regulated operators in Greece were estimated to be approximately €2.1 billion and the Greek gaming sector accounted for 1.14% of the country’s GDP (Gross Domestic Product). According to H2 Gambling Capital (H2GC, the leading source of data regarding the global gambling industry), Greece ranks 2nd, among the 28 EU countries, in GGR as a % of GDP. In the same category, Cyprus ranks above average among the 28 EU countries. According to H2GC 2018 numbers for Greece, OPAP held a 70% GGR market share, mainly due to the success of higher VLTs contribution and improved KINO performance.

In this context, our vision is to establish OPAP as a world class gaming entertainment company and ensure the company’s growth, expansion of operations and profit generation. The foundation of the 2020 vision is underpinned by our 4-core values (Fun, Dynamic, Passionate and Fair). These values sustain our workfriendly working environment and motivate our employees throughout the Group. We have established a set of 8 strategic priorities that will help us generate, capture and sustain value for the company and all our stakeholders, both in the short and long term, and at the same time safeguard OPAP’s future success.

We operate under the World Lottery Association (WLA) and responsible gaming standards and strive to transform our business excellence into social contribution through an integrated corporate responsibility strategy.

Our corporate sustainability comprises of 6 key focus areas. These focus areas reflect our mandate to achieve financial prosperity and create value for both society and the environment.

Internal Operation

We aim to operate in a responsible manner by embedding responsibility into our business, and at the same time, improve our competitiveness and create value for all our stakeholders.

Financial Results

We seek to align our continuous support to society with healthy financial results, in order to facilitate a sustainable business. Therefore, we built our long-term corporate strategy in a transparent way that satisfies the needs of shareholders and the investment community, creates value for all stakeholder groups, contributes to the country’s development and economic sustainability, while at the same time strengthens our presence in the gaming industry.

Player Protection

We understand that the responsible management of our business is imperative, due to the possible risks and consequences that might arise from excessive participation in games of chance. Therefore, we seek to establish an environment, in which a fair, reliable and safe gaming experience is provided to those who choose to use the products and services offered by our Company, for their own entertainment.

Network Enhancement

Recognizing that we operate in a highly challenging economic situation, we dedicate our efforts to the development of our sales network and the creation of more work positions. Our aim is to place our customers as our top priority and provide the resources to improve our network partners’ operations at every level.

People Development

Our People are at the heart of everything we do, bringing value and contributing to the success of our long-term strategic objectives, which lead us towards our 2020 Vision. We are committed to create a unique experience for all OPAP People; one that reflects our high performing culture and our values. We focus on being a great place to work by placing our People at the center of our strategy.

Society Support

We believe that our role in society transcends our business activities and we have the responsibility to support social growth and prosperity. Thus, we are committed to support and benefit different stakeholders and underprivileged social groups, facilitate our supply chain’s growth and responsible operation, as well as safeguard the environment and reduce our potential impact on climate change and resource use.

ACKNOWLEDGEMENT OF OUR

Sustainability Initiatives that we follow:

• FTSE4Good
• Global Reporting Initiative

We communicate our corporate sustainability strategy and performance via our integrated report, and respond to investors and ESG analysts’ requests for information. OPAP has been included in the Financial Times Stock Exchange 4Good (FTSE4Good) Emerging Index, which assesses listed companies in emerging markets with a positive financial, environmental and social performance, based on a range of corporate social responsibility criteria. Its inclusion in the FTSE4Good index demonstrates OPAP’s commitment to build a comprehensive sustainability strategy by embedding sustainable ESG practices into business management.

Risk Management

We follow a comprehensive annual enterprise wide and systematic approach to identify, measure and prioritize key risks that may affect the achievement of our strategic objectives.

The risk registry incorporates elements of the Internal Controls – Integrated framework (COSO model 2013). We have identified 10 major risk categories, each of which comprises of relevant subsequent risks. These risks are identified through workshops and one-on-one interviews with all Chief Officers. Each Chief Officer evaluates the likelihood and the severity of the risks relevant to his/ her department and provides information on the corresponding mitigation and control measures. The Chief Officers are required to evaluate both the inherent and residual impacts of each risk.

To evaluate the scoring provided by the Chief Executives, OPAP also calculates the residual impacts, taking into consideration the inherent impacts and the effectiveness of existing actions and controls, based on the findings of internal audits. If major differences are observed between the results of the 2 methods followed to identify the residual impact, additional meetings are organized with the Chief Executives to identify the reasons of differences and reach to a scoring verified by both methods.

In 2018, the Executive Committee evaluated the risk registry and the assessment results against OPAP’s strategic objectives. The results were reviewed by the Audit Committee and the CEO. The main risks and measures identified for 2019 are presented in the following table.

See more OPAP’s integrated report (p.65-66) https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf 

Responsible Gaming

Our Responsible Gaming Framework is based on the World Lottery Association’s (WLA) framework and consists of activities that aim to ensure responsible and sustainable growth. Within this Framework, we have developed Responsible Gaming Policies, as follows:

• OPAP / Hellenic Lotteries Employee Policy on Responsible Gaming.
• OPAP Agents / Hellenic Lotteries Points of Sale Network Policy on Responsible Gaming.
• OPAP / Hellenic Lotteries Communication and Advertising Policy on Responsible Gaming.
• OPAP Play Gaming Hall Network Policy on Responsible Gaming.

These policies define all the necessary measures companies are advised to take in order to minimize the potential negative impact from participation in games of chance. The policies address three main target groups:

• Employees
• Agents and Play stores venue managers / Points of Sale

and their employees

• Players

Expanding our responsibility practices into our sphere of influence, we require from all our agencies neither to employ any person below the legal work age limit, nor to tolerate or disregard potential physical or other illegal harassment of any kind or forced and coercive labor in any of their facilities.

See more OPAP’s integrated report (p.102-111) https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf 

Memberships

OPAP Group companies participate in a number of organizations and committees, relevant to their operation.

Organizations

• World Lottery Association (WLA)
• European Lotteries Association (EL)
• Hellenic Federation of Enterprises (SEV)
• Hellenic Network for Corporate Social Responsibility
• European Pari Mutuel Association (EPMA) (Horse Races)
• Global Lottery Monitoring System (GLMS)
• Hellenic Institute of Customer Service
• Hellenic Institute for Entrepreneurship & Sustainable Development

Working Groups

• World Lottery Association Security and Risk Management Working Group
• European Lotteries Public Affairs Coordination Working Group (ELPAC)
• European Lotteries Sport Working Group (EL Sport)
• European Lotteries Security and Integrity Working Group

2. Materiality

ADMINISTRATIVE PRACTICES

OPAP is continuously informed about the global economic, environmental and social issues that are surrounding the business community and strives to ensure that these global issues are taken into consideration during the development of its sustainability strategy.

As the leading gaming Company in Greece we acknowledge the sheer size of our business operations and the subsequent impacts it can incur on the economy, the environment and society. Therefore, we identify the issues that are most material for our sustainable development and our stakeholders. In 2017, we identified and prioritized these issues through a 4-phase methodology, as follows:

The main challenges occur by the environment that we operate are:

https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf 

3. Objectives

ADMINISTRATIVE PRACTICES

Our long-term goal is to continue pursuing robust financial results and delivering on the highest standards of corporate governance, ethical leadership and corporate citizenship. Combining business excellence with a high sense of social responsibility will serve as our guide for a strong future.

At OPAP we focus on our exciting present and promising future. Therefore, we have set a set of targets that pursues systematically based on our integrated management system:

The targets are identified according to the axis below and are aligned with the material issues that were aroused by the business and social environment that we operate:

1. Games portfolio
2. Operating responsibly
3. Protecting our players
4. Enhancing our network
5. Developing our people
6. Supporting our society

We have disclosed our performance against our 2018 targets, and we have presented the 2019 targets in our Sustainability Report (p. 168-174) https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf 

Internal Controls and Audits

We have established a System of Internal Controls based on best international practices, designed to assure we will achieve:

• Efficiency and effectiveness of the work.
• Reliability and completeness of the financial and management reporting.
• Compliance with the applicable legal and regulatory framework.

Following the results of internal audits conducted within 2018, all findings were taken into consideration and the appropriate teams decided upon the design and implementation of corrective measures.

4. Management of Value Chain

ADMINISTRATIVE PRACTICES

Being one of the largest companies in Greece, our size has created the moral obligation to systematically disseminate, deploy and promote the principles of corporate responsibility throughout our value chain.

Through our business model we create our top-market products and services and support our mandate of creating sustainable value for our stakeholders. Illustrated below is the value creation process of our business. It outlines how each form of capital is utilized and subsequently transformed through our business activities enabling the creation of value for OPAP and our stakeholders.

Our Operations

We create value

Influencing Positively our Supply Chain

Suppliers are expected to operate according to the respective legislative provisions. Therefore, we have included a clause in all formal tenders and agreements with our significant suppliers with an annual spending of over €50,000, which specifically states the requirement to comply with labor, environmental and occupational health and safety laws and regulations. In 2018, OPAP issued a new Supplier Code of Conduct. The new Code was communicated and signed by all suppliers who signed contracts or participated in tenders with an annual budget over €100,000. We maintain a registry of our active suppliers with updated financial and business data on an annual basis, including potential certifications according to ISO 9001, ISO 14001, ISO 27001, SA 8000, OHSAS 18001 and/or other standards. Becoming more conscious of the environmental and social impact of products acquired, we utilize the registry information mainly regarding suppliers providing products and services with increased environmental and societal impact, such as cleaning and security services.

https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf

5. Responsibility

ADMINISTRATIVE PRACTICES

OPAP adopts a holistic approach to corporate responsibility, where the accountability for responsible operation lies within each department and each employee. To assure the holistic and responsible management of our operational issues, we have established the appropriate organizational structures, as follows.

• At Board level, our corporate responsibility agenda is driven by the Chief Executive Officer.
• At organizational level the Chief Corporate and Regulatory Affairs Officer is responsible for identifying the strategic risks, setting standards and targets and reviewing the performance regarding corporate responsibility.

• At operational level, the Corporate Responsibility and Public Relations Director is responsible for cooperating with other departments in order to diffuse responsibilities, policies and practices, and has established a close collaboration with the Quality Systems Management Department.

We have also appointed specific executives who are responsible for mitigating risks as well as defining and sustaining the strategies that reflect our corporate responsibility objective, by coordinating and implementing relevant programs and activities.

See also https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf (p. 47)

6. Rules & Processes

ADMINISTRATIVE PRACTICES

We recognize that in order to increase our performance in market we ought to have a decisive, disciplined and transparent working environment. Our objective is to set the correct guiding principles and ensure that our mission and values are sufficiently communicated among employees. Sound guiding principles can help OPAP serve the public interest and prevent the intangible value of its reputation from declining. Therefore, we have firmly established a range of standards and mechanisms that allow us to fulfill our objective and operate responsibly.

We closely monitor the regulatory and legal framework related to our activities, in order to apply its relevant provisions.

 Code of Conduct

Our Code of Conduct outlines the main principles and behavioral rules, as well as provides guidance to all members (i.e. Board of Directors, Chief Officers, managers and employees) on issues that may arise within OPAP. The Code was updated in 2018 and was communicated to all employees in early 2019. All employees were asked to acknowledge and accept its guiding principles and provisions.

The code covers the following theme areas:

• governing principles and company values,
• operational framework,
• personal and business integrity,
• the resources of OPAP Group and its customers,
• people: respect for the individual, equal opportunities, diversity,
• whistleblowing: implementation - violations, whistleblowing complaints, and
• ensuring stakeholders’ awareness.

The Code of Conduct strictly prohibits all employees to offer, solicit or accept gifts, donations, in cash or in any other form, and any benefit related to the performance of their duties. They may only be allowed to accept or offer non-cash gifts/hospitality of value not more than €150 arising out of customary business practices. In this case, pre-approval must be received from the immediate manager and the fact that a gift was offered or received must be reported to the Regulatory and Compliance Officer, who maintains a gifts and hospitality registry. Gifts should be transparent, infrequent and should not be offered or accepted during contractual negotiations, tender processes or if aware that one is imminent with a supplier. Offering hospitality/tickets to events should be solely for the purpose of OPAP Group employees building business relationships. It is important that gifts or hospitality never influence business decisionmaking processes, or cause others to perceive an influence. OPAP Group is committed to maintaining the highest standards of ethics and integrity in the way it does business in Greece and Cyprus. Fraud, bribery and corruption in all forms are illegal and unacceptable. It must be noted that in 2018 there were:

• No confirmed incidents of corruption or pending lawsuits related to corruption or relevant sanctions imposed by respective authorities.
• No legal accusations of corruption filed against the company or pending accusations of corruption or legal fines imposed on grounds of corruption against the company.

Internal Rules and Regulations

Our Internal Rules and Regulations are prepared in compliance with the applicable legislative framework, based on the company’s Articles of Association. They describe the way we regulate the organization and functioning of the company in order to ensure:

• Business integrity.
• Transparency of business activities.
• Control over management and how management decisions are made.
• Compliance with legislation and the Concession Agreement’s obligations.

In 2018, following significant changes of the provisions of Law 4548/2018, OPAP proceeded with the update of its Internal Rules and Regulations, which are expected to be finalized within 2019. However, the Policy on the handling of inside information and the prevention of market abuse, which constitutes part of the Internal Rules and Regulations, has been updated and approved.

Adhering and Following Fair Competition Rules

We recognize our responsibility to follow fair competition practices and refrain from engaging in any activities non-compliant with competition law. Indicatively, within this context we:

• Comply with the relevant competition laws and legislation.
• Do not adopt illegal or unethical business practices.
• Do not allow our employees to share confidential information with third parties.
• Enable all our employees to seek guidance or advice from the Regulatory and Compliance Officer regarding activities which could potentially breach competition law.

In 2018, OPAP did not receive any antitrust complaint or complaint regarding anti-competitive behavior or monopoly practices, as well as any fines or non-monetary sanctions on these issues.

Anti-Money laundering

We comply with applicable framework and the Hellenic Gaming Commission’s Decision no. 129/2/2014, as currently in force, which introduced measures to prevent money laundering and terrorist financing in the gaming sector.

OPAP has a “Policy on the prevention of the use of OPAP gaming products for the purpose of money laundering and terrorism financing” in place for OPAP S.A., Hellenic Lotteries S.A., and Horse Races S.A. which applies to all employees, agents and salesmen of OPAP products. The AML/CTF Policy describes a set of principles and procedures to minimize the risk of using OPAP’s products for money laundering and terrorism financing.

As mandated by the Policy, the AML Compliance Officer, who is appointed by the Board of Directors and notified to the Hellenic Gaming Commission, is responsible to continuously assess AML risks and submit recommendations to the Board of Directors, in order to effectively mitigate those risks. The Board of Directors also receives and assesses an AML semi-annual Report with the actions and the measures taken to prevent money laundering and terrorism financing.

Integrated management system

At OPAP S.A. we implement an Integrated Management System (IMS) in accordance to international standards. Each of the four sub-systems takes into consideration the structure and requirements of the other systems. Within the context of our IMS, we operate the following systems:

• ISO 9001 Quality Management System certified by Lloyd’s Register Quality.
• ISO 14001 Environmental Management System certified by Bureau Veritas.
• ISO 50001 Energy Management System, certified by Bureau Veritas.
• OHSAS 18001 Occupational Health and Safety System certified by Bureau Veritas.

It must be noted that within 2018, we:

• Implemented a certified Energy Management System according to ISO 50001.
• Trained new employees on our Management Systems through the Corporate Induction program

Audits

OPAP conducts regular audits to internal stakeholders and its network, in order to ensure their compliance with the Policy and the AML requirements. During these audits, we review the following:

• Compliance with procedures to collect, update and maintain players’ data.
• Proper implementation of the Know your Customer (KYC) procedure for new and existing players.
• Compliance with procedures to identify and report suspicious transactions.
• Proper record keeping.
• Review of player behavior in order to provide winning certificates to players.

Furthermore, we have introduced a digital platform (winningscerificates.opap.gr), which enhanced our KYC and AML procedures with regards to issuing winnings certificates and significantly improved the efficiency of the issuing process. As a result of the above-mentioned practices, within 2018, we:

• Performed AML audits to our whole network.
• Imposed monetary fines to agents regarding identified violations of procedures
• Imposed fines regarding non-compliance with law and regulations to our agencies.
• Submitted reports to the Hellenic Financial Intelligence Unit pursuant to applicable legal framework.
• Issued 19 written warnings to specific agencies due to violations of gaming regulations related to financial transactions.

In 2018, no legal actions regarding incidents of money laundering and terrorism financing were taken against OPAP and no fines or sanctions were imposed to OPAP for AML/CTF issues. We had no incidents of contract termination or no renewal due to money laundering violations.

 Trainings

We provide continuous training on AML/ CTF issues for our employees and agents and we inform and notify them in case there are changes in the regulatory framework.

Within 2018:

• The AML Team attended a series of training courses.
• We organized a mandatory AML e-training course for the whole network that started in 2018 and is expected to be concluded in 2019.
• We communicated messages to the entire retail network to inform them about their key obligations under the AML Regulation and our relevant AML Policy.

Addressing Illegal Gaming

Acknowledging our role as the leading gaming company in Greece, we strive to address the issue of illegal gambling in the market. Illegal gambling practices not only endanger the industry’s reputation but also more importantly, the players’ wellbeing. Therefore, we make every effort to support the authorities in their battle against the illegal gambling phenomenon, either online or offline, and at the same time work towards establishing a fair and accessible-to-all gaming environment that offers entertainment to the general public.

See more https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf (p. 62-64)

PERFORMANCE INDICATORS

GRI SRS 102-16

In addition to what described above:

Regulatory Framework

Τhe Greek gaming sector is regulated and controlled by an independent administrative authority, the Hellenic Gaming Commission (HGC). Activities of HGC are conducted within a series of regulations that either refer to the overall gaming sector (e.g. Decision no. 129/2/07.11.2014, as currently in force, Decisions no. 155/6/24.04.2015, 163/6/09.07.2015, 166/5/23.07.2015 in accordance with Law no. 4557/2018, as amended by Law no. 3932/2011, concerning tackling money laundering and terrorism financing), or relate to specific games or gaming category.

 Our Strategic Priorities

Guided by our 2020 vision to establish OPAP as a world-class gaming entertainment company, we have established our strategic framework, which is driven by 8 strategic priorities.

• EMBEDDING CUSTOMER OBSESSION
• BUILDING A WORLD CLASS PORTFOLIO
• OF PRODUCTS AND SERVICES
• REBUILDING HEALTHY RELATIONSHIPS
• WITH THE STATE, REGULATOR AND
• OTHER BODIES
• INVESTING IN OUR NETWORK
• LEVERAGING THE LATEST DIGITAL AND
• TECHNOLOGY CAPABILITIES
• COMMITING TO OUR COMMUNITIES
• DEVELOPING OUR PEOPLE
• EXPANDING THE POWER OF OUR BRAND

See more https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf (p.52)

Our Values

FUN

“Fun is at the heart of everything we do”

DYNAMIC

“Evolution, Game changer”

PASSIONATE

“We are passionate in everything we do”

FAIR

“Fairplay”

See more https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf (p. 54)

7. Monitoring

ADMINISTRATIVE PRACTICES

At OPAP we have committed to present our progress systematically and outline our key achievements at a business, operational and sustainability level, giving insight into all the issues of material importance to OPAP, as well as our forward-looking strategy.

OPAP issues an integrated report aims to provide a balanced and integrated depiction of OPAP’s value creation process using both financial and nonfinancial material, serving as a platform of accountability and engagement with our stakeholders.

This report covers all activities of OPAP Group Companies operating in Greece, namely OPAP S.A. and its subsidiaries

The last Report covers the financial year from January 1 to December 31, 2018 and it’s OPAP’s 3rd Integrated Report. There are no significant changes from previous reporting period in the scope, boundary or measurement methods applied in this Report.

The report has been restructured in line with the guidelines provided by the International Integrated Reporting Council’s <IR> Framework. The social and environmental data and information are according to the new Global Reporting Initiative’s Sustainability Reporting Guidelines. The separate and consolidated Financial Statements of OPAP are in accordance with International Financial Reporting Standards (IFRS) as issued by the International Accounting Standards Board (IASB) and interpretations issued by the IFRS Interpretations Committee, as adopted by the European Union and are effective as of 1 January 2018.

In our continuous effort to improve our performance and ensure that we meet the expectations of our stakeholders, we have set a set of performance targets, which are depicted in our Report.

See our results against targets on pages 168-174.

Also see the GRI Content Index 175-182

https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf

Ensuring Business Continuity

In order to ensure our uninterrupted operation, we:

• Have included our information security requirements, related to continuity, in our Business Continuity Management Policy.
• Have identified, classified and rated processes and information assets for their required recovery time and point objective, during our Data Asset inventory’s development.
• Have developed disaster recovery plans for critical and essential information systems and infrastructure and have established alternative sites/facilities to support recovery of business operations and IT systems at any time.
• Follow specific backup policies for information and information systems.
• Use systems that guarantee high availability for critical business applications related to games’ operations and availability.

Monitoring closely our network’s performance regarding Responsible Gaming practices

Indicating our commitment to ensure proper compliance with the Responsible Gaming rules and principles, we monitor our agencies’ and Play stores’ compliance with the basic rules of Responsible Gaming. Compliance with the Responsible Gaming rules is assessed through the FOT’s Mystery Shopping visits (see section E.3.4 Addressing Illegal Gaming), where the following aspects, among others, are inspected:

• Entry of minors in agencies and under 21-years of age in Play stores.
• Minors’ participation in games of chance (under 21 years of age for Play games).
• Presence of Responsible Gaming mandatory materials.

In case agents are identified as being non-compliant with their obligations in the above areas, OPAP reserves the right to terminate their agreement.

During 2018, we performed 3,771 unique shop visits to our network (approximately 90% of our network), where 122 cases of high severity violations on behalf of our agents regarding their responsible operation were reported, which led to a total of 192 actions from OPAP, including monetary fines.

Monitoring our Customer Service Performance

We monitor or customer service performance aiming to continuous improvement.

As stated above, in 2018 we launched the Post Contact Satisfaction Survey for anonymous and registered customers to track their satisfaction from the service provided and collect their respective feedback. We also conducted monthly market research to measure our agents’ and customers’ satisfaction from our Contact Center.

Support through the Contact Center in 2018

8. Incentive and reward systems for Sustainable Development

ADMINISTRATIVE PRACTICES

The Remuneration and Nomination Committee, as it was renamed by the 26.05.2016 Board of Directors’ decision, consists of three non-executive members, is responsible for deciding on the fees that encourage good customer service, are fair to all our employees and are aligned with the interests of all of our shareholders.

Major Duties of the Remuneration and Nomination Committee

• Ensure that there are adequate procedures for the evaluation of the Chairman’s, non-executive Board Members’, executive Board Members’, and key personnel’s (reporting directly to the CEO) remuneration, as well as Board and Board Committees remuneration.
• Ensure that the Company adopts, monitors and implements appropriate policies and remuneration procedures.
• Ensure that disclosures regarding remunerations meet the disclosure objectives of the Board of Directors and of all relevant legal requirements.
• Review the Board’s executive members’ and executive officers’ succession plans on a regular basis to maintain an appropriate balance of skills, experience, expertise and diversity in the management of the Company, providing advice to the Board accordingly.
• Evaluate candidates and propose new members for the Board of Directors.

Long-term Incentive Scheme

The Board of Directors of the Company, following a recommendation of the Remuneration and Nomination Committee, on 28.3.2017, approved a 3-year long-term incentive scheme, that would run from 2017 to 2019. The scheme involved the distribution of part of the Company’s net profits to Executive Members of the BoD and other Key Management Personnel of the Company, excluding the CEO. The agreed performance targets relate to the profitability of the Company for the 3-year period mentioned above and the Company’s share price increase in Athens Exchange. The maximum amount to be distributed to up to 30 beneficiaries is € 7,000,000.

PERFORMANCE INDICATORS

GRI SRS 102-35a

Remuneration Regime

Bonus schemes were adopted that build incentives via specific KPIs. Established criteria include quantitative benchmarking based on the overall Company performance, taking into account key profitability metrics Qualitative criteria also apply, focusing on managerial skills, training and development of the working teams, project deliveries, external communication etc.

Bonuses and other variable remuneration arrangements are common practice for companies listed in the FTSE100 index. Research has shown that 99% of executives working in the FTSE100 companies at the Executive Committee level and above have a ratio of variable to fixed remuneration in excess of 1:1. At OPAP, this ratio of variable to fixed remuneration is only applicable to the Chairman of the Board and the Chief Executive Officer.

We have clearly defined our Board Members’ responsibilities to facilitate adhering to good Corporate Governance practices. The Remuneration Policy of the company applies to the remuneration of all Board members. It is designed to reflect fair payment conditions for all employees and align the Board’s remuneration with the interests of our shareholders. The objective of the Remuneration Policy is therefore to meet market practice, to serve the Company’s strategic vision, its shareholders, clients and wider stakeholders.

It is expected that the detailed remuneration policy will come for shareholders’ approval at the 2019 Annual General Meeting.

9. Stakeholder Engagement

ADMINISTRATIVE PRACTICES

It is of paramount importance for OPAP to conduct a systematic and regular dialogue with its stakeholders, in order to respond to their needs and expectations, in an effort to improve ourselves, both in the short and long term.

Stakeholders are defined as anyone who influences or is influenced by our operations, throughout our value chain and across our operations. In 2018, we reviewed our stakeholder groups and decided to reconfigure them, by merging some of the initial groups to new ones. This will enable us to improve our stakeholder engagement process.

The stakeholders recognized by OPAP are: Employees, Industry members & associations, Media, Non-Governmental & Academic Organizations, Players & Prospective Players, Suppliers, State, Government Authorities and Local Communities, Shareholders, Investors and Analysts, Sales / Distribution Network.

Through our engagement with our stakeholders we utilize a range of methods of interaction to understand their main issues of interest.

Employees

Our employees are our most valuable asset. To understand our employees, we conduct an annual employee survey to gain feedback on our employees’ attitude, motivation and satisfaction with regards to our operations. We actively communicate with our employees, on a daily basis, using internal communication means such as regular e-mail announcements

and monthly internal newsletters. Promoting our values to our employees is also a very important part of our ethos. Therefore, we organize internal awareness campaigns, on a semimonthly basis, corporate and social events and encourage our employees to participate in them.

Players and Prospective Players

We firmly abide to our mandate of promoting responsible gaming and responsible communication by using various means of communication. We communicate the principles of responsible gaming to our customers and the general public by posting regular

posts on social media, organizing awareness campaigns and by publishing press releases and articles on our website. In addition, we carry out annual customer satisfaction surveys, via our contact center, to learn more about our customers’ experiences with our products and services.

State, Government Authorities and Local Communities

We heavily invest in our relationships with the State, Government Authorities and the Local Communities in the areas we operate. Our engagement practices with this group of stakeholders involve regular face-to-face meetings, presentations and the publication of corporate reports.

Industry Members and Associations

OPAP is an active and devoted member of the European Lottery Association and the World Lottery Association. We adhere and abide to the established regulations and standards and promote responsible gaming practices. We actively engage with these bodies by

arranging meetings and establishing formal communication channels.

Shareholders, Investors and Analysts

We heavily invest in our relationships with the State, Government Authorities and the Local Communities in the areas we operate. Our engagement practices with this group of stakeholders involve regular face-to-face meetings, presentations and the publication of corporate reports.

Media

OPAP’s most valuable intangible asset is its brand’s reputation and the subsequent value of its products and assets. Therefore, we work on preserving our reputation as the leading gaming company in Greece and Cyprus by actively communicating with journalists

and the public media. We communicate our work through regular press releases, articles press conferences and by organizing special events and meetings.

Non-Governmental and Academic Organizations

Supporting our work to create a positive impact on the society, are our partnerships with local and international NGOs, institutions, academic organizations and treatment providers. OPAP through its partnerships delivers societal support programs and provides

financial support. We engage with these organizations by organizing meetings and collaborations. We also promote OPAP’s and the organizations’ societal work by updating our website and posting relevant posts on social media.

The key issues that concern the non-governmental and academic organization we work with, include but are not limited to anticorruption, public involvement, corporate responsibility, responsible gaming, waste handling and equality and fairness.

Sales / Distribution Network

OPAP’s licensed agents, street vendors and retailers are the immediate administrators of our products and services. We place great importance on their work and thus continuously communicate with them to help them develop their capabilities. We organize oneto-

one meetings, awareness campaigns and offer training schemes to disseminate material regarding responsible gaming and new products and services.

Suppliers

Creating value through our products and services requires an effective and responsible supply chain. We actively engage with our suppliers through transparent and objective interactions. Each year, we carry out our annual supplier evaluation survey to evaluate

and approve potential suppliers for future partnerships.

Aside from the quantitative assessment of our suppliers, the supplier evaluation survey, together with one-on-one meeting, allows us to identify the key issues that concern our suppliers.

Working with all Stakeholders on Promoting Responsible Gaming

We constantly promote dialogue and seek to build consensus together with key stakeholders, to ensure that the principles of Responsible Gaming are disseminated to the general public.

Ιn 2018, we presented our Responsible Gaming strategy to the Hellenic Gaming Commission and engaged and collaborated with various stakeholders, who included among others:

• The World Lottery Association (WLA).
• The European Lotteries Association (ELA).
• Various academic institutions, such as the National and Kapodistrian University of Athens.
• The Therapy Center for Dependent Individuals (KETHEA).

We participated in a jointly organized two-day CSR-Responsible Gaming seminar by the World Lottery and European Lotteries Associations, during which we advanced our knowledge and skills related to Responsible Gaming and exchanged ideas and good practices with lottery members from around the world.

OPAP is a founding member of the European Lotteries Association (umbrella organization of National Lotteries operating games of chance for the public benefit in Europe) and the World Lottery Association, which participated and financially supported the Council of Europe’s and European Union’s Joint Project ‘Keep Crime out of Sport’ + (KCOOS+). The aim of the project is to support EU countries to implement the Macolin Convention’s key provisions (convention on the manipulation of sports competitions to safeguard the sports integrity and ethics), set up national platforms, facilitate information sharing among key stakeholders and develop education and prevention initiatives.

The European Lotteries Association supported the ASPIRE (Activity, Sport, Play for the Inclusion of Refugees in Europe) project, led by ENGSO, which is an international project that focuses on the social inclusion of refugees. ASPIRE seeks to establish methods on how sports clubs can better support the social inclusion of migrants and refugees, capitalizing on the wide popularity of sports and other forms of physical activity.

Last but not least, OPAP is a founding Member of the Global Lottery Monitoring System (GLMS) which is a key partner of the KCOOS + project and the IntegriSport project. The IntegriSport project, which is co-funded by the EU ERASMUS+ program, will seek to raise awareness among law enforcement authorities across Europe on risks related to match fixing and other criminal activities endangering sport throughout Europe. The project comprises of two phases, the research phase and the awareness raising phase and is run by CSCF (Counter Sports Corruption Foundation for Sport Integrity), together with 8 law enforcement and judiciary authorities from 7 countries and the Global Lottery Monitoring System. The Project is co-funded by the European Union and supported by Council of Europe.

Within 2018, OPAP supported 4 Responsible Gaming activities, as follows:

• The Helpline 1114 by KETHEA-ALFA.
• The ‘11th State of the Art Adolescent Medicine Course’ conference, organized by the Adolescent Health Unit of the Children’s Hospital ‘Panagioti & Aglaias Kyriakou’ and the Hellenic Association for Adolescent Medicine.
• The educational program ‘Mental Health and Internet – Dysfunctional Behaviors Online – Ways of Intervention and Prevention’, implemented by the National and Kapodistrian University of Athens.
• The Youth Power intervention program of the Adolescent Health Unit.

See more https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf (p. 70-73)

PERFORMANCE INDICATORS

GRI SRS 102-44

Employees

We have found that the main issues of concern for our employees are the issues of code compliance, health and safety, equality and fairness and labor practices.

 Players and Prospective Players

Our engagement practices with our customers and the general public have revealed highly instructive results and show that the key issues that concern them are customers’ privacy, the company’s donations and societal support activities and its business entrepreneurship activities.

 State, Government Authorities and Local Communities

Τhe key concerns raised by these stakeholders include but are not limited to: corporate governance, anti-corruption, network compliance, responsible gaming, donation and support and environmental compliance.

 Industry Members and Associations

The issues that are of great concern for these bodies are: compliance with competition law, customer privacy, money laundering, network compliance, responsible gaming and responsible communication.

 Shareholders, Investors and Analysts

Τhe key concerns raised by these stakeholders include but are not limited to: corporate governance, anticorruption, network compliance, responsible gaming, donation and support and environmental compliance.

 Media

We work on preserving our reputation as the leading gaming company in Greece and Cyprus by actively communicating with journalists and the public media on topics that reflect company’s performance across the board.

 Non-Governmental and Academic Organizations

The key issues that concern the non-governmental and academic organization we work with, include but are not limited to anticorruption, public involvement, corporate responsibility, responsible gaming, waste handling and equality and fairness.

 Sales / Distribution Network

From our continuous communication we have found that the issues that concern our partners in our sales network include, but not are not limited to, customer satisfaction, customer privacy, money laundering, network compliance, responsible gaming, responsible communication and economic transparency.

 Suppliers

The issues are namely: supplier assessment and practices on health, safety, environmental and quality issues, operational support, responsible buying and economic transparency.

10. Product Responsibility and Innovation

ADMINISTRATIVE PRACTICES

OPAP Group designs the gaming and betting software within its premises or procures it from external providers and redesigns them to match its client base profile and preferences. OPAP is the sole provider of the betting and gaming terminals to its OPAP and Play stores.

The transformation of the role of Digital & Technology within the Group consists one of our objectives; we continue to invest in modern solutions, which will provide an improved level of control and flexibility to the ongoing delivery and improvement of OPAP’s products for the customers, setting at the same time the basis for future strategy.

Technology is at the core of OPAP’s products and defines our customers’ physical and gaming experience. The completion of OPAP’s technology transformation program in 2018 was an important achievement, delivering strategic benefits to the organization and supporting the achievement of our 2020 vision. The technology transformation program has been implemented for more than two years and included a € 100 million investment in the technologies in use throughout our network. This investment was capitalized and resulted in the roll-out of 9,300 new terminals in Greece and Cyprus, 12,000 new digital signage players in shops, 8,000 new satellite receivers and the installation of more than 400 virtual servers.

In 2018, new internal technology capabilities were established, which enabled OPAP to accelerate its innovation process, delivering new solutions at a fraction of the cost and time, compared to the previous outsourced model, where certain functions, such as the business operation of the numerics central platform and the retail terminal support were outsourced to a third-party organization. Additionally, OPAP gained greater direct control of the technology architecture landscape by reducing the number of external vendors it collaborates with, assuming responsibility for key software system components, such as the Player Account Management (PAM) system, and by providing ongoing support services for its network’s retail equipment – for example, the new terminals and digital players signage hardware and software are now centrally supported by the newly established retail equipment support team.

Building upon the foundation laid out by the technology transformation program, OPAP will continue to accelerate the delivery of new products and solutions and work towards achieving its 2020 vision. Our aim is to offer a broad range of attractive, new and improved products and services for our customers and our network, researching ideas from around the global gaming world.

Environmental guidelines for our network

In our effort to engage with our stores and subsequently protect the environment and ensure a sustainable business operation, we introduce our network to sound environmental operations by including specific recommendations in our store development guidelines.

These recommendations include actions such as:

• Replacement of old lighting units with new LED lighting units.
• Rational use of lights and electrical equipment.
• Use of high energy efficiency equipment.
• Recycling of materials (paper, plastic, batteries, TVs, electrical equipment etc.).

11. Usage of Natural Resources

ADMINISTRATIVE PRACTICES

OPAP, through its Environmental and Energy Policy, is committed to conducting business in an environmentally responsible way, acknowledging that protection of the environment, energy saving and conservation of natural resources, as well as the active contribution against climate change are integral parts of responsible and sustainable business development.

As part of our certified Environmental Management System according to ISO14001:2015, we apply best practices to manage our operations in a way that prevents environmental pollution, regarding both our own operations, as well as our main suppliers’ operations, through specific provisions in RFPs, awards and contracts.

In this context, we systematically identify and evaluate the environmental impact of our activities. As a result, in 2018, we identified the following environmental aspects as the most important:

• Energy consumption
• Paper consumption
• Life-cycle management of hazardous materials (e.g. electrical equipment, toners, light bulbs).

To further improve our approach, we developed an Energy Management System, which was certified according to ISO 50001, in 2018. The system assures

our compliance to the energy management law.

OPAP ACTING AS A “RESPONSIBLE CITIZEN”

We are proud to report that, in 2018, we had:

• No environmental incidents of any kind.
• No complaints or accusations of violating any environmental
• No written notices or legal actions by the respective authorities regarding environmental issues.
• No relevant fines or other sanctions imposed, during the scheduled and ad-hoc audits conducted by the respective authorities.

12. Resource Management

ADMINISTRATIVE PRACTICES

At OPAP in order to achieve our environmental objectives, we identify the sources we can apply targeted initiatives to reduce our environmental footprint.

Therefore, in 2018, we reviewed and improved our environmental monitoring mechanisms and recalculated the 2017 data.

Our 2018 targets concerning resources management were:

Next year’s targets

Paper Consumption

In our efforts to reduce the amount of paper we use, we monitor and report on our paper consumption, based on our purchasing records. In 2018, we consumed around 16 tons of paper. OPAP S.A.’s consumption was reduced by almost 8% within the last year.

At the beginning of 2018, we initiated the “Zero Paper” project across OPAP S.A. The objective of the project was to substantially decrease paper consumption by fully exploiting existing digital solutions and improving defected digital processes. From the outset, the project’s results were promising, and therefore we decided to broaden the project’s scope by including additional objectives, focusing on utilizing the project’s results as input for the company’s digital strategy and introducing a new continuous way of thinking across the company. The implementation of the project offered additional benefits to the company by reducing costs and processing time.

Energy

To drive improvement on our climate change impact, we continued to engage into actions and programs aiming to further improve our environmental performance within 2018, mainly through the following initiatives:

• Acquired 23 new Euro 6.2 cars which is approximately 8% of our total fleet (leased and owned vehicles).
• Trained 134 new employees on environmental and occupational health and safety issues through 7 corporate induction sessions.
• Included six articles in relation to environmental issues in our corporate newsletter.
• Conducted two e-learning sessions regarding occupational health and safety and environmental issues, with 684 and 110 participants respectively.
• Implemented an integrated energy management software, as well as energy consumption meters to improve energy monitoring and consumption.
• Installed motion detectors in kitchens and meeting rooms to reduce energy consumption and minimize maintenance costs.
• Installed LED lighting units at staircase areas to reduce energy consumption and minimize maintenance costs.
• Installed solar panels to produce hot water and minimize our energy consumption and environmental footprint.

Life-cycle Management of Hazardous Materials

We recognize the importance of protecting natural resources and therefore operate in a responsible manner, striving to reduce waste and increase our efficiency. Consequently, we:

• Monitor the use of materials.
• Reduce the use of materials.
• Reuse materials.
• Recycle materials through licensed sub-contractors.

• Properly dispose hazardous materials.

In 2018, following our technology transformation program, we replaced a large number of IT hardware and equipment both in our premises and network. Consequently, we replaced the paper material (coupons, playslips, thermal rolls) used in our network, and collected the outdated material for recycling.

There was an extensive effort to improve efficiency of recycling programmes for domestic batteries and plastics in Thessaloniki. Thus, we managed to increase the total quantities recycled compared to 2017. Moreover, the aluminium recycling initiative, running for the first time all year round, resulted in positive recycling rates.

We perform a number of actions aiming at improving our waste management performance, as outlined below.

• Recycling programs focusing on the collection of paper, cartridges – toners, light bulbs, domestic batteries, aluminum and plastic caps from beverages, and bottled water are implemented by placing appropriate bins in our facilities, as well as marked bins for the collection of organic waste (e.g. food residues) and food packaging.

• All potentially hazardous waste (i.e. toners, electrical equipment, light bulbs and domestic batteries) is appropriately discharged through licensed contractors.

• A licensed recycling partner directly delivers our recyclable waste to specialized recycling management facilities, instead of municipal recycling bins.

• Appropriate bins for aluminum are placed in kitchens and office areas.
• Appropriate labelling is used for separation of waste by employees.
• All used cartridges-toners (434 units) were sent for recycling.
• All plastic cutlery, spoons and straws were replaced with biodegradable ones.
• The plastic stirrers were replaced by wooden ones.

Refrigerants

Acknowledging that refrigerants have a detrimental effect on the ozone layer and damage our environment, we use only environmental-friendly refrigerants in our air-conditioning systems. In 2018, no additional refrigerants were added.

Biodiversity

We are aware of the alarming rate of biodiversity loss that has taken place over the last decades, due to unsustainable human-induced activities, and we acknowledge that our lives largely depend on the variety of species and ecosystems found on our planet. Taking this important environmental issue into consideration, we are proud to report that all our offices and buildings are located within urban environment without any adjacent protected areas and, therefore, are not subject to any specific biodiversity protection regulations and safeguarding measures.

Environmental guidelines for our network

In our effort to engage with our stores and subsequently protect the environment and

ensure a sustainable business operation, we introduce our network to sound environmental

operations by including specific recommendations in our store development guidelines.

These recommendations include actions such as:

• Replacement of old lighting units with new LED lighting units.
• Rational use of lights and electrical equipment.
• Use of high energy efficiency equipment.
• Recycling of materials (paper, plastic, batteries, TVs, electrical equipment etc.).

PERFORMANCE INDICATORS

GRI SRS-302-4:

In 2018, although our energy consumption was increased, energy consumption per employee was decreased. This reflects OPAP’s commitment to minimize its environmental footprint and promote sustainable growth.

GRI SRS-306-2:

13. Climate-relevant emissions

ADMINISTRATIVE PRACTICES

Recognizing the risks and opportunities associated with climate change, we seek to reduce our energy consumption and improve overall energy efficiency. To achieve this objective, we identify the sources we can apply targeted initiatives to reduce our environmental footprint. Furthermore, we systematically quantify direct and indirect greenhouse gas emissions from our operations, which primarily result from electricity consumption in our buildings and secondarily from fuel consumption for heating and our vehicle fleet. In 2018, although our energy consumption was increased, energy consumption per employee was decreased. This reflects OPAP’s commitment to minimize its environmental footprint and promote sustainable growth.

To drive improvement on our climate change impact, we continued to engage into actions and programs aiming to further improve our environmental performance within 2018, mainly through the following initiatives:

• Acquired 23 new Euro 6.2 cars which is approximately 8% of our total fleet (leased and owned vehicles).
• Trained 134 new employees on environmental and occupational health and safety issues through 7 corporate induction sessions.
• Included six articles in relation to environmental issues in our corporate newsletter.
• Conducted two e-learning sessions regarding occupational health and safety and environmental issues, with 684 and 110 participants respectively.
• Implemented an integrated energy management software, as well as energy consumption meters to improve energy monitoring and consumption.
• Installed motion detectors in kitchens and meeting rooms to reduce energy consumption and minimize maintenance costs.
• Installed LED lighting units at staircase areas to reduce energy consumption and minimize maintenance costs.
• Installed solar panels to produce hot water and minimize our energy consumption and environmental footprint.

PERFORMANCE INDICATORS

GRI SRS-305-1 SRS-305-2: SRS-305-5:

We calculate our greenhouse gas (GHG) emissions, using the best available data. We use the emission coefficients of the Greenhouse Gas Protocol to calculate the emissions deriving from the consumption of gasoline for vehicles and diesel for heating, vehicles and generating sets. The emissions from electricity consumption are calculated based on Eurostat’s data for national gross electricity production and the data from the national reports submitted to the Secretariat of the United Nations Framework Convention on Climate Change (UNFCCC). Conversion factors for CH4 and N2O emissions are based on the global warming potential values over a 100-year period as described by the UNFCCC.

GRI SRS-305-3:

Operating in a non-energy intensive industry, our impact related to other greenhouse gas emissions (NOx, SOx, VOC, PM10) is limited. However, we recognize the importance of this issue at a global scale and we therefore monitor our respective impact through our direct energy consumption.

14. Employment Rights

ADMINISTRATIVE PRACTICES

Our People are at the heart of everything we do, bringing value and contributing to the success of our long-term strategic objectives, which lead us towards our 2020 Vision. We are committed to create a unique experience for all OPAP People.

Integrating the notions of diversity, inclusivity and fairness within our core values, we establish a positive work environment which facilitates a performance driven culture. we have developed a policy that condemns all forms of discrimination, such as discrimination against race, gender, marital status, political beliefs, religion, origin, sexual orientation, age and disabilities, regarding work issues, such as recruitment and selection, salaries, promotions and career development.

Promoting our values to our employees is also a very important part of our ethos. Therefore, we organize internal awareness campaigns, on a semimonthly basis, corporate and social events and encourage our employees to participate in them.

Our policies & procedures

Not Tolerating Child, Forced and Abusive Labor under any Circumstances

We fully and strictly follow the internationally recognized human rights principles, as described within the UN Universal Declaration of Human Rights.

Through our policies, which have been internally communicated and implemented, we commit ourselves to not encourage and tolerate any coercive or abusive labor in any of our premises. Also, we are committed to employ individuals, who are above the legal work age limit (as defined by the Greek legislation). As a result of our commitments, in 2018:

• Four operations were subject to human rights reviews (100% of total operations).
• No operations were identified as having significant risk for incidents of child labor or forced and abusive labor.

Respecting the Right of our Employees to Participate in Employee Unions

Adhering to internationally recognized principles of human rights, we respect the right of

employees to participate in employee unions and discuss topics of reciprocal interest through representatives, as well as express openly and freely their opinion, either individually or in groups. In practice, in 2018:

• 28% of our employees participated in Employee Unions.
• All our employees were covered by the Greek National Collective Bargaining Agreement.
• No operations were identified in which the right to exercise freedom of association and collective bargaining may be at significant risk.

• 56 of our employees participated in four National General Strikes within 2018, organized by the General Confederation of Greek Workers (GSEE), due to governmental policies regarding the National Insurance System and employment-related legislation.
• The total amount of time lost due to strikes was 29 man-days, accounting for 0.0076% of the total working time.

• 167 labor disputes for OPAP S.A. and 7 labor disputes for OPAP Services S.A. with former employees regarding non severe labor issues.

For major operational changes, we follow, as a minimum, the relevant regulatory requirements for notifying our employees.

Health & Safety

We believe that ensuring the health and safety of our employees is of the outmost importance, as it is a non-negotiable prerequisite for our employees’ well-being and OPAP’s successful operation. We focus on health and safety regulations which ensure suitable and safe work conditions, through a number of systemically implemented practices.

Training

Our objective is to train our employees on issues and skills that are linked to their personal development, through various means such as classroom trainings, e-learning trainings, conferences and on-the-job training with their supervisors’ coaching.

Promoting Effective Internal Communications and People Engagement

The main driver of our commitment towards our employees is to engage and motivate employees to utilize their professional passion and sense of belonging within a fast-paced industry. By helping every employee to achieve their full capability, we recognize the importance of two-way communication to foster an open dialogue culture and utilize numerous touch-points to maintain an on-going and effective communication.

We enhance our employees’ engagement, integrating our core values, though various activities. Notable activities include the “Happy Fridays” initiative (where we meet with each other and celebrate achievements), the bring-your-child-to-work day as well as the “Lunch with chiefs” and the “Breakfast with the CEO” (where employees interact with Top Management representatives, strengthening communication and sharing information and ideas). In the beginning of 2018, we launched the recognition initiative “Star Team” and “Star of the Month”. Every month all Group employees and all Teams have the opportunity to be nominated by the Senior Management Team in the respective categories and

be awarded for their personal and team achievements by the CEO. We also host a number of internal social events such as a Christmas corporate event, employees’ children parties and events at the Horse Races venue in Markopoulo, as well as events to celebrate our achievements. At the same time we ensure that through internal activations, we inform our People about product launches and other key Group initiatives. In 2018, we launched the

recognition event “OPAP Annual People Awards 2018” at our anniversary “60 years Christmas together” party, where 9 employees received recognition awards for their work at OPAP. We send out regular posts in the renewed corporate intranet (OPAPopen) to inform our employees about corporate news, important initiatives and achievements, benefits and policies, as well as internal events, registering 85,400 monthly pageviews. In 2018, we sent out 200 mass e-mail announcements and 11 monthly OPAPulse newsletters. Though our internal social platform “Yammer”, hosting 1,000 members, over 200 posts were sent out to promote and enhance collaboration, share company updates and celebrate achievements. In addition, we remain active on our social medial accounts (i.e. LinkedIn, Facebook and Instagram), sharing our internal engagement initiatives and employees’ success stories. Lastly in 2018, we circulated 14 internal communication announcements regarding Corporate Responsibility issues.

Our employees also engage in volunteering activities, such as participation in blood donations and fundraising running events.

Teambuilding days

This initiative started in the end of 2017, aiming at the Management Team’s members. In 2018, we expanded the initiative for all Group employees, who in turn had the chance to participate in numerous entertaining games designed to build team spirit amongst them, at an offsite location.

Embracing the new “PeopleOnline” platform

In 2018, we launched the new, integrated, electronic human resources platform “PeopleOnline”, to automate, further enhance and digitalize the human resources management processes, improving the experience of all employees. The platform includes a range of modules, such as:

• Performance Management and Development module.
• Employee Central module (Leaves application, Organizational structure, Employee profile).
• Recruiting module.
• Careers module.

“PeopleOnline”, is available through all corporate devices (fixed and portable equipment) and mobile phones, making the platform modules more accessible.

Annual Survey

Our employees are our most valuable asset. To understand our employees, we conduct an annual employee survey to gain feedback on our employees’ attitude, motivation and satisfaction with regards to our operations. We have found that the main issues of concern for our employees are the issues of code compliance, health and safety, equality and fairness and labor practices. We actively communicate with our employees, on a daily basis, using internal communication means such as regular e-mail announcements and monthly internal newsletters.

• 87% of eligible employees participated in the 2018 employee survey (compared to 82% in 2017).
• 72% in employee engagement was achieved, reflecting our strong relationship with our employees and our objective to create and enhance a positive work environment. The areas with the highest scores include Social Responsibility, Environment, Quality and Customer Focus, Trust in Top Management, Confidence in the Clear and Promising Company’s Direction.

PERFORMANCE INDICATORS

GRI SRS 405-01

A high percentage of Greeks in management and top management positions, being 97.42% and 33.33% (compared to 92.8% and 42.86% in 2017) respectively, while the percentage of Greeks in the BoD was 33.33%, compared to 42.85% in 2017.

 40% women in total workforce

• 78% employees between 30 and 50 years old
• 97% employees with full-time contracts
• 66% employees with TEI / University education
• 98% employees in Greece
• 171 new employees hired
• 31% employee turnover
• 1,493 employees

The BoD composition is considered diverse, competent and experienced since it is comprised in its majority of Non-Executive Members from various industries, nationalities and age groups. We are proud to have a Board of Directors whose members have strong academic and professional backgrounds and diverse skillsets. Majority of our board members have had numerous years of international experience in commercial and investment banking. Also, majority of our members have held high ranking positions in gaming and betting companies and therefore possess very good knowledge around the gaming and betting market, helping OPAP to deliver key strategic decisions to become a world class gaming entertainment company.

Initial selection of BoD Members is conducted by the BoD itself, which delegates the screening process involved to the Remuneration and Nomination Committee. The criteria that are taken into account are their professional experience and expertise and are further defined by the Remuneration and Nomination Committee while, at the moment, there is no separate consideration of gender diversity during their selection. The company measures year-on-year progress to ensure improving diversity balance.

See more https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf (p. 30 & p. 132-133)

15. Equal Opportunities

ADMINISTRATIVE PRACTICES

Equality & Fairness

We focus on being a great place to work by placing our People at the center of our strategy.

OPAP’s positive work environment fosters the development and professional advancement of our employees, depending on their actual performance, their abilities to deliver and OPAP’s success, rather than through prejudgment and prejudiced criteria.

OPAP, as a fair and equal organization, strives to bridge the gap between men and women in top management levels. We aim to foster a working environment with an open-minded company culture that sets diversity as a top priority. We encourage female employees to reach out for higher management positions and provide support throughout their professional development. We are proud to announce that, in 2018, 28% of directors and 17% of top management members were women.

Fostering Work-life Balance for our People

We shed great importance to our employees’ dedication towards OPAP. We recognize that balancing professional and personal life, results in higher levels of employee engagement and performance. Therefore, we systematically work to ensure that all employees are able to achieve work-life balance and thus:

• Define clear daily working hours and time schedules for all employees.
• Comply with relevant legislation defining intervals between end of a shift and commencement of the next shift for applicable employees.
• Comply with the legislation on the annual overtime per employee being 120 hours.
• Do not tolerate employees working overtime, under the threat of any sanction (e.g. salary reduction or dismissal).
• Compensate and reward employees for their overwork (i.e. the first hour after the completion of the legal time schedule) and overtime (i.e. the first and second hour after overwork).
• Ensure that employees receive and utilize their entitled leaves (such as paid leaves).
• Grant special leaves to eligible employees when required (e.g. parental leave to new parents, breast feeding and child care leave to employees, leave for single parent families and student leave).

2018 Highlights

• No employees exceeded the annual maximum overtime limit and all overtimes were fully paid

• 51 female employees requested and were granted parental leave.
• 1 female employee was granted reduced working hours because of parenthood.
• 25 female employees who had received their parental leave returned to the company.

• No employee left the company within 12 months of returning from parental leave
• 19 employees (15 female and 4 male) were granted student leaves as part of their undergraduate or postgraduate studies.

Health & Safety at OPAP

In 2018 we:

• Developed an Occupational Health and Safety Policy to illustrate our commitment to shape a preventive culture for health and safety at work, which has been communicated to all employees and outlines our activities to continuously improve our workplace.
• Implement a Health and Safety Management System based on the OHSAS 18001:2007 standard for Occupational Health and Safety.
• Perform audits on health and safety practices, within the scope of our Integrated Management System.
• Systemically identify occupational and work conditions risks in written Occupational Risk Assessment Studies, for both OPAP S.A. and OPAP Services S.A.
• Have established a Security Operations Center to monitor security and facilitates communication during emergency events 24 hours a day, 7 days a week.
• Have communicated detailed instructions for emergency evacuations, fire incidents and earthquakes to all employees.
• Conduct regular company-wide evacuation exercises, with two exercises conducted in our premises in Athens and Thessaloniki during 2018, where all employees participated.
• Upgraded our Building Management System (BMS) to improve and effectively monitor our cooling, heating and ventilation systems, as well as ensure prompt response to potential failures.
• Improved the air quality of our offices by adding humidifiers in the air-conditioning system and modifying their systems, to optimize their efficiency.
• Monitor the health and safety practices of contractors’ employees working in our premises, as well as the safe completion of their activities.

Wellness and Supportive Initiatives

Aiming to develop our employees, we continue offering high-level benefits and organizing actions that further improve our work experience. Within this context, the Health, Safety and Wellbeing Team (OPAPWellness Team) has been established to implement awareness and action initiatives that foster and support health, safety and wellbeing for all. The team comprises of members of the People Team and the Quality Management Systems Team, external partners, and also employees of the Group. In 2018, OPAP ran the supportive OPAP Employee Assistance Program for all its employees and their family members in collaboration with a specialized and experienced provider. The program supported 335 employees and family members through 24 informative and interactive workshops and sessions in Athens and Thessaloniki in order to help our employees define, address and resolve key issues that affect them (such as nutrition, stress management, working relations crisis/conflicts management and parental and maternity issues). Employees and their family members may seek assistance in relation to personal matters and relationships, through a dedicated support line, 24 hours a day, 7 days a week. At the same time, personal safety and self-defense lessons were offered to our employees. They were provided with safety tips and attended demonstrations of basic self-defense exercises to enable them to prevent potential risks and be able to protect themselves under any situation. Lastly, we developed, in collaboration with the Red Cross a two-day First Aid seminar where our employees acquired useful knowledge on basic First Aid practices, learning how to act and what to avoid in a case of emergency.

Training

The need to connect our people’s training and development with the strategic goals and results of the Group led to the creation of OPAPacademy in 2016, through which the development of a common communication language, a single Corporate Culture is being cultivated and an integrated customer-centric approach towards the internal and external customer. The strategic priorities of Opapacademy are:

• Developing a culture of continuous learning and evolution.
• Creating and maintaining a high-performance mindset.
• Empowering the leadership team.
• Talent development.

Our objective is to train our employees on issues and skills that are linked to their personal development, through various means such as classroom trainings, e-learning trainings, conferences and on-the-job training with their supervisors’ coaching. Since 2017, our groundbreaking Opapacademy Online Development Center (eLearning platform) has helped our employees to enhance their skills and competencies through blended learning, which includes numerous online modules both compulsory and optional. Among the lessons that took place there were lessons on health and safety, Microsoft Office and organizing effective meetings. In 2018, approximately 16% of total OPAP employees training hours were carried out through e-learning training courses.

A great initiative regarding our online development center was the launch of two new “libraries” that included 45 new courses on a great variety of soft skills, promoting our efforts to enhance knowledge, skills and competencies. More specifically:

• 30 lessons for all OPAP’s Professionals focusing on the development of team-building and working skills.
• 15 lessons as part of a demanding training program adapted to meet the needs and demands of our Management Team.

We conduct the majority of our training courses in-house, at our two state-of-the-art training centers located in our headquarters in Athens and our building in Thessaloniki, which house 100 and 40 seats respectively.

In 2018, we implemented a broad range of training programs emphasizing on:

• Soft skills (e.g. Management, Leadership, Negotiation, Time Management, Presentation Skills, Interviewing Skills, Customer Service Skills, Working in Teams).
• Technical skills (e.g. Finance for non-Financials, General Data Protection Regulation – GDPR, OHSAS 18001, Accounting, Procurement).
• Certificates (e.g. Red Hat, PMP, IFRS, ISTQB, PMP).
• Information Security Awareness Sessions: weekly informative sessions with rich themes in the context of information protection, aiming to increase the preparedness and vigilance against dangers of the digital age, with online simultaneously participation of our Team in Thessaloniki.

Induction Program Training

In order to inform and educate our employees on issues related to our Group’s Teams, Products, Strategic Priorities, Core Principles and Values, we continue the implementation of our extensive Induction Program. All newly hired employees participate in the Induction Program, within the first month of their employment, which specifically addresses the following:

• Company overview and history.
• Vision and Values.
• Company strategic priorities.
• Product knowledge.
• Code of Conduct.
• Health and safety.
• Awareness programs on Responsible Gaming, Information Security and the Integrated Management System.
• Teams mapping and team activities.
• Field visits, including two-day visits to OPAP agencies, PLAY Gaming Halls and the Protypo Store.

In 2018, the induction program was successfully completed for 96% of newly hired employees. The program was expanded to include our interns who participated in our 2018 internship program, with 100% of them completing the program.

PERFORMANCE INDICATORS

GRI SRS 403-2:

2018 Highlights

• No losses of OPAP or OPAP partners’ employees.
• 766 employees were trained on health and safety issues.
• 2,337 training hours on health and safety issues.
• No high incidence or risk of disease associated with the employees’ work. This was confirmed by the fact that no occupational diseases among our employees occurred.

• No serious accidents involving OPAP employees took place.
• No incidents involving a female employee took place
• No legal actions regarding health and safety issues were imposed.
• No fines or sanctions were imposed by the respective authorities.
• Received the Gold Award for the “Healthy and Pleasant Workplace” category at the Boussias Communication 2018 Health and Safety awards.

GRI SRS 404-1:

2018 Highlights

• 99% of our employees received training
• 244 training courses were conducted
• 65% of our employees were trained to develop long-term competencies, on skills such as Management Negotiation Skills, Finance for non- Financials and PMP Time Management.
• 90% Opapacademy participants’ feedback satisfaction rate
• €370.000 was the total cost of training courses, compared to €240,700 in 2017.

GRI SRS 406-1:

2018 Highlights

• No complaints or grievances regarding labor practices or discrimination incidents or unfair treatment or human rights violation.
• No legal actions regarding human rights issues and no fines or sanctions regarding human rights issues or labor practices were imposed by the respective authorities.
• Establishing a minimum salary, which in all cases was higher than the legal basic salary (or the higher collective agreement salary), as defined by local legislation.
• An almost equal ratio of salary for men and women within similar hierarchical level/area of activity/job family, with statistically insignificant variations, materializing the fact that salaries do not depend on the employees’ gender.

16. Qualifications

ADMINISTRATIVE PRACTICES

Achieving our strategic objectives and sustaining our growth, requires the establishment of an engaging work environment. OPAP, as one of the largest and most successful companies in Greece, employs 1,262 (Data refer to the companies OPAP S.A., HELLENIC LOTTERIES S.A., OPAP SERVICES S.A., TORA DIRECT S.A., HORSE RACES S.A. and TORA WALLET S.A..) employees; a number that can be deemed rather large, considering the economic challenges that the Greek society faces.

In addition to direct employment, we further leverage the creation of additional work positions all over Greece, with approximately 38,300 positions indirectly generated by our operations.

We are committed towards creating a positive, supportive, and dynamic work environment and therefore proud to have had:

• No variations in employment numbers due to seasonality.
• An average employee age of 39 years.
• 35 foreign and 8 handicapped employees working in OPAP.
• An average turnover rate of 4.3% (4.2 % of employees voluntary resigned, while 0.2% were dismissed).
• One employee who left before completing 12 months of employment (0.1% of total workforce).
• Average employment tenure of 5 years.
• 51 external partners working with OPAP during 2018, who focused on the construction, maintenance and development of our network.

Identifying the Right Potential Candidates

An integral step to secure OPAP’s future growth is to work towards attracting, inspiring and retaining high potential, talented professionals. In 2018, we met with over 1,200 candidates during several career initiatives and events, informing them about our performance-oriented mindset and took the time to understand their professional aspirations. Indicatively we took part in:

• The AUEB Career Fair
• The ALBA Career Forum
• The Deree Career Days
• The Kariera Career Days
• The UNIPI Career Days
• The Kariera Developers Day
• The ReGeneration Program

Furthermore, through our “OPAP Internship Program”, we collaborated with many educational institutions, offering 6-month internship programs to undergraduate students. The internships gave students the opportunity to learn and gain professional experience in various teams and specialties (e.g. Marketing, HR, Network Development, Retail Marketing, Sales, Finance and Legal) within our Group.

In 2018, we offered internship opportunities to 61 students. These internships helped the students to develop valuable skills and advance their personal and professional development. 15 interns were offered positions within the Group following the completion of their internship. The “OPAP Internship Program” received very positive feedback from both managers and interns. 91% of managers stated they would recommend the intern for a future collaboration and 92% of the interns would suggest the program to a fellow student.

Finally, we conducted over 1,120 structured interviews throughout our intensive recruitment process and responded to all 9,000 applicants who sent us their Curricula Vitae.

Offering Additional Benefits to our People

We offer to our employees a range of benefits. Aiming to continuously improve our benefits, we cooperate with a leading insurance company to offer additional services to our employees. In 2018, the total amount of investment in the private Medical and Life Insurance Plan exceeded €955,000. This Medical and Life Insurance Plan covers 95% of all our active employees (employees with permanent employment contracts and temporary employment contracts for over one year of OPAP S.A., OPAP Services S.A., Hellenic Lotteries S.A., Horse Races S.A., Tora Direct S.A. and Tora Wallet S.A.), with an annual checkup offered through the health insurance scheme, including digital mammography. Moreover, in 2018 we updated part of our policies (corporate cars policy, mobile and laptops policy).

Furthermore, we offer:

• Benefits relevant to business need (i.e. mobile phones, laptops, corporate cars, gas cards).
• Numerous internal and external parking spots for our employees in headquarters, as well as parking spots for all employees in Thessaloniki.
• Participation in the OPAP Employee Assistance Program.

Annual Performance Management and Development Process

The OPAP Group carries out an annual performance management and development procedure for all its employees. The process takes place at the end of the calendar year, where the performance of employees’ individual targets for the previous year is assessed. In addition, employees’ performance targets for next year and individual development plans were set. Key Program elements are:

• Establishing a Common Competencies Framework for all employees
• All employees to have Individual Goals or Performance Standards based on their hierarchical level
• All employees to have Development Plans.

In 2018, the annual performance management and development process was performed online for the first time, through the new “PeopleOnline” platform. All employees received a formal performance review.

Launch of Internal Career Development Opportunities Process

In 2018, by establishing the Internal Career Development Opportunities Process, the People Team committed to give priority to the existing human resources of the Group for internal staffing, through transparent and meritocratic processes.

We aim to retain our employees, offering them with development opportunities and supporting them in their professional career’s next steps in the Group’s companies. Therefore, our people are able to utilize their skills and gain new knowledge, develop new professional skills and have a career within the Group and further understand the Group’s operations.

The talent acquisition team investigates the staffing options, making use of its existing database and by announcing job openings through OPAP’s corporate intranet, calling the interested persons to apply. In 2018, we published 41 internal job postings on our corporate intranet and managed to cover 27% of permanent job openings by internal candidates, compared to 12% in 2017.

Academies focusing on individual development

In 2018, we run three major programs focusing on individual development.

Leadership pathways academy

This 5-month development program is aimed at Group Directors to help them develop their leadership and people management skills.

Regional and account managers development program

This 5-month development program is aimed at the Regional and Account Managers of the Retail Team. The program consists of personalized programs designed to prepare and develop the participants for their roles’ tasks. Topics included: “Excelling as Regional Manager”, “Meet the Account Manager Role”, “Presenting with Impact”, “Advancing your Presentation Skills”, “Finance for Non- Financials” and “Effective Negotiation Skills”.

17. Human Rights in the supply chain

ADMINISTRATIVE PRACTICES

Our Network

Our distribution network is one of the largest exclusive commercial networks in Greece, as we offer our games and services through 3,910 dedicated and branded agencies throughout the country, while a further 8,503 points of sale and street vendors are utilized to distribute SCRATCH tickets and passive lotteries. In addition, our network includes 351 Play stores in Greece and 201 agencies in Cyprus.

OPAP continued to support its partners’ performance through performance management and bonus scheme. Also, we provide various training programs to our agents through our sales training team, either at our premises or in broader areas of their agencies, depending on our training plan, in order to ensure their smooth operation.

Our suppliers

We fully acknowledge that our suppliers’ activities and actions can influence our own responsible operation and therefore strive to build a sustainable supply chain. We interact with our suppliers in a transparent and objective manner and offer equal opportunities to all. Our list of suppliers includes suppliers who offer sales and marketing services, office consumables, retail agency consumables, IT infrastructures and applications, telecommunication services, facility services and logistic services.

We utilize our outreach and size to support the local economy in the areas we operate, by collaborating with local suppliers and purchasing locally produced products and supplies. In order to enhance national and local development, in 2018 we:

• Collaborated with 2,643 suppliers throughout Greece and abroad, with approximately 94% of them being local suppliers (2,483 local suppliers), compared to 93% in 2017.

• Spend 66% of our total procurement budget to local suppliers, compared to 72% in 2017.

At the same time, we aim to treat our suppliers fairly and adjust our payment terms and bank guarantees to market conditions, by taking into consideration the current financial situation in the Greek market. The payment time of contracts is performed according to the contractual terms within 60 days from invoicing.

Influencing Positively our Supply Chain

Being one of the largest companies in Greece, our size has created the moral obligation to systematically disseminate, deploy and promote the principles of corporate responsibility throughout our supply chain. Suppliers are expected to operate according to the respective legislative provisions. Therefore, we have included a clause in all formal tenders and agreements with our significant suppliers with an annual spending of over €50,000, which specifically states the requirement to comply with labor, environmental and occupational health and safety laws and regulations.

In 2018, OPAP issued a new Supplier Code of Conduct. The new Code was communicated and signed by all suppliers who signed contracts or participated in tenders with an annual budget over €100,000.

We maintain a registry of our active suppliers with updated financial and business data on an annual basis, including potential certifications according to ISO 9001, ISO 14001, ISO 27001, SA 8000, OHSAS 18001 and/or other standards.

Becoming more conscious of the environmental and social impact of products acquired, we utilize the registry information mainly regarding suppliers providing products and services with increased environmental and societal impact, such as cleaning and security services.

Evaluating our Suppliers

Since 2017, we have adopted a systematic approach for our annual supplier evaluation process, which includes:

• Quality evaluation for all our significant suppliers, based on the total turnover value and their strategic importance.
• Environmental and health and safety evaluation for our significant suppliers based on their field of operation.

At the same time, we perform ad-hoc supplier evaluations in cases of specific business requirements (e.g. as part of an upcoming large tender, contract renewal or potential suppliers).

See more https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf (p. 160)

PERFORMANCE INDICATORS

GRI SRS 412-1

• Four operations were subject to human rights reviews (100% of total operations).
• No operations were identified as having significant risk for incidents of child labor or forced and abusive labor.

GRI SRS 414-1 & GRI SRS 414-2

Materializing our supply chain approach into practice within 2018:

• 100% of new suppliers (with contracts over €50,000) signed that they comply with respective environmental, labor, human rights or society legislative provisions. No formal audits for new suppliers regarding the above issues were conducted.
• 55 suppliers were assessed for environmental impacts and 45 for occupational health and safety impacts (representing 36.6% and 30% respectively of significant suppliers with an annual spending of over €50,000), without any further actions.

• There were no cases of suppliers with whom our collaboration was terminated (or not initiated) due to actual or potential compliance issues (e.g. for incidents of corruption, anti-competitive behavior, non-responsible communication or poor health and safety performance).

18. Corporate Citizenship

ADMINISTRATIVE PRACTICES

OPAP’s mission to create value for its stakeholders emanates from our formal mandate to support social growth and prosperity of our society. We contribute through our societal support programs, donations and sponsoring activities. We collaborate with numerous foundations and charitable organizations, receiving public recognitions as well as accredited certifications for our work.

Our social support initiatives focus on three main pillars, namely sports, health and employment. In addition, we continue our long-standing commitment towards responsible gaming and our work supporting sensitive social groups and communities.

Key 2018 Programs and Initiatives

• Children Hospital Renovation program

Since 2014, we have been continuing our contribution to the Health sector, by sustaining the Children Hospital Renovation program at the Children’s Hospitals ‘Aghia Sophia’ and ‘Panagioti & Aglaias Kyriakou’. Through this program OPAP aims to:

• Upgrade the hospitals’ nursing units and outpatient clinics.
• Create a pleasant therapeutic environment to accelerate children’s therapy.
• Renovate the hospitals’ premises, waiting and examination rooms.
• Improve the working conditions for the medical and nursing staff.

In 2018, both hospital buildings had 50% of their renovation completed. A total of 22 renovation works that included 15 nursing units were completed, covering a total of 9,230m2 and with a capacity of 321 beds.

• OPAP ‘Contribution Squad’

Aiming to engage the general public with the children hospitals renovation initiative,

we have launched, since 2014, the engaging OPAP ‘Contribution Squad’ initiative, inviting

people to get involved in the project through an engaging and fun mobile app, around the time of the Authentic Athens Marathon. In 2018, 276,855 people downloaded the ‘Contribution Squad’ mobile app and participated in the engaging challenges. OPAP translated a total of 3,492,539 points into actual investment for the continuation of the renovation work in both Children’s Hospitals.

• “OPAP in the Neighborhood” Preventive health examinations Program

OPAP, having acknowledged the need for health protection, implements a Medical Prevention program together with “The Smile of the Child”, offering preventive health checks to adults and children in cities across Greece. In 2018, 9,928 people, in 52 towns and cities across Greece, were examined.

• OPAP Sports Academies’ program

Having set as a priority to build solid foundations and create value for future generations, we continued the ‘OPAP Sports Academies’ program for the fourth year. Our objective is to instill the values of fair play, devotion, respect and team work in children. Since the launch of the program in 2015, we have accomplished prosperous results towards our effort to upgrade the athletic education standards. Indicatively:

• 28 Sports Academies Festivals have been organized all over Greece.
• Over 32,000 children have participated and been supported through the program’s educational initiatives, experiential activities and sports festivals.
• 475 hours of coaching and 3,000 trainings hours for parents, children and coaches have been carried out.
• Approximately 6,000 children, between the ages of 6 and 12, have been informed on healthier nutrition.
• Over 25,000 parents have been informed and supported on issues related to children’s psychology, nutrition and first aid.
• 20,000 balls, 125 sets of training equipment, 15,100 pairs of shin guards and 7,000 child-size identification markings (badges) have been distributed to the participating academies.
• Over 20,000 children and parents/guardians have participated in the several activities and sports events, organized within the context of our participation in the ‘European Sports Week #Be Active’ that ran for the fourth consecutive year. This is an initiative from European Commission that aims to promote sport and physical activity across Europe, supported and enacted by the Ministry of Culture and Sports, General Secretariat of Sports.

• ‘OPAP Forward’ program

Our overall positive impact in the Greek economy is further enhanced by our decision to support entrepreneurship, through the implementation of our integrated program ‘OPAP Forward’ under the pillar of Employment. The objective of the program is to select

and provide support to fast-growing Small and Medium Businesses and as a result foster the creation of more job opportunities and stimulate financial prosperity in the Greek economy.

OPAP collaborates with the global non-profit organization Endeavor, to ensure the program’s effective implementation. With Endeavor’s support, the selected companies will be able to grow fast, create jobs and contribute to the growth of the economy.

In 2018, the program supported 40 SMEs from various sectors and has helped the participating companies create 417 new direct working positions, and support 3,184 new indirect job positions through the establishment of new collaborations, while at the same time increase their total turnover by 20%.

• OPAP on the side of people affected from the Eastern Attica fires

From the first moment, OPAP stood by the side of the local communities affected by the Eastern Attica wildfires during August 2018. The company supported the work of the Municipality of Marathon hosting and supplying food for the people affected by the fires, as well as personal hygiene and cleaning supplies were gathered and distributed. Also, OPAP, driven by its interest in youth and in close collaboration with the local authorities, undertook the restoration of the 2 schools which suffered significant damages from the wildfires.

• Wishing Ornaments’ program

The aim of this initiative is to make everyone part of a greater effort, through the fulfillment of simple child wishes. At the same time, OPAP implements infrastructure projects for the children’s support organizations, to improve their quality of life. In 2018, we invited the children supported by “The Smile of the Child” organization to draw their wishes on a simple piece of paper. During the Christmas season, these drawings were exhibited in high traffic Athens and Thessaloniki Malls, where people could choose a child’s wish they would like to make true by buying the respective gift. Additionally, for the very first time, people across Greece had the opportunity to fulfill children’s wishes through the “Contribution Squad” mobile app.

In total, 7,517 children’s wishes came true.

• 60 years OPAP: Charity gala in support of ELEPAP and “Together for the Child” association

OPAP celebrated its 60th anniversary with a glamorous event dedicated to children. On the 18th December 2018, the company held a charity Gala in support of the Hellenic Society for the Protection and Rehabilitation of Disabled Persons (ELEPAP) and the “Together for the Child” association. The money raised in the context of OPAP’s charity gala was offered to support ELEPAP’s “Financial Adoption of Children” program, which aims at the cognitive, socioemotional, psychomotor and sensory development of children, and “Together for the Child” association’s “I contribute because I care” program, which aims at gathering basic resources to support institutions serving children and families in need.

Contributing to Cyprus’ Society

OPAP Cyprus has a strong relationship with the Cypriot society, since its first days of operation. Its core business activities are integrated with its corporate responsibility mandate, through the implementation of societal support programs, aimed at creating value for society and improving citizens’ quality of life. OPAP Cyprus’s main objective is the creation of added value to the community of Cyprus. We focus our efforts on the following 5 pillars:

• Sports
• Health
• Education
• Culture
• Environment

See more https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf (p.146-156)

PERFORMANCE INDICATORS

GRI SRS 201-1

 In OPAP, economic development is one of our primary targets since it contributes directly and indirectly to Greece’s economic prosperity.

2018 was a historic year for OPAP that was accompanied by increased financial performance. In particular:

• Gross Gaming Revenue (GGR) increased by 6.3% at €1,547.0 million (FY 2017: €1,455.5m), as a result of increased VLTs contribution, positive World Cup’s positive impact on betting activity and rejuvenation actions with new features in KINO.
• EBITDA increased to €353.6 million (FY 2017: €306.5 million), driven by top-line growth as well as effective cost containment actions.
• Net Profit stood at €143.3 million (FY 2017: €126.2 million) with a 13.7% year-on-year increase, or 20.8% rise adjusted for non-recurring one-off items.
• Strong financial position, with Net Debt at €459.0 million and Net Debt/EBITDA ratio of 1.3x.
• Dividend for the year stood at €0.70 per share, compared to €0.40 per share last year.

Within 2018, OPAP Group:

• Paid out over €2,843 million to players.
• Distributed over €380 million to its network.
• Distributed over €130 million to its shareholders.
• Paid over €282 million to suppliers (excluding investments)
• Distributed over €72.8 million for employees.
• Paid over €26 million to providers of capital.
• Paid over €723 million to the Hellenic Republic, out of which €490 million were GGR contribution and €51 million were corporate taxes.

• Utilized over €100 million in investments.

See more https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf (p.81- 98)

Contributing responsibly to our society’s needs

In recent years, we have made significant financial contributions, striving to make a difference through large-scale initiatives and thus contribute towards the development of our society, secure a better future for our youth and have a long-lasting positive impact on Greece’s economy. In 2018, we provided € 23.8 million of financial investments to materialize 368 activities. We estimate that around 1.4 million people benefited from our activities.

19. Initiatives and Political Influence

ADMINISTRATIVE PRACTICES

As one of the most well established and dynamic business sectors, the Greek gaming sector consists of the following six main subsectors:

• Numerical games.
• Sports betting and horseracing mutual betting.
• Video Lottery Terminals (VLTs).
• Instant and passive lotteries.
• Casinos (includes all games played within casinos).
• Online offshore.

Similar to most European countries, the Greek gaming sector is regulated and controlled by an independent administrative authority, the Hellenic Gaming Commission (HGC).

HGC’s objectives are to regulate and control the gaming sector and set the standards to ensure that gaming and betting within Greece are organized and conducted in a lawful, transparent and fair manner, are not subject to illegal activities or exploitation, and the interests of players and society are instead of is protected.

Activities of HGC are conducted within a series of regulations that either refer to the overall gaming sector (e.g. Decision no. 129/2/07.11.2014, as currently in force, Decisions no. 155/6/24.04.2015, 163/6/09.07.2015, 166/5/23.07.2015 in accordance with Law no. 4557/2018, as amended by Law no. 3932/2011, concerning tackling money laundering and terrorism financing), or relate to specific games or gaming category.

Gaming Concession

In 2000, we entered a 20-year concession agreement with the Hellenic Republic and have been granted the exclusive right to conduct, manage, organize and operate numeric, sport forecasting and betting games by any appropriate means relevant to the current technology. The agreement was extended in December 2011 and is valid until October 12, 2030 except for PAME STOIXIMA and MONITOR GAMES, for which OPAP has the exclusive right to offer

them online until October 12, 2020. Under the terms of the concession agreement and in accordance with the terms of Article 27, paragraph 9a of Law no. 2843/2000, OPAP was also granted the exclusive right to operate and manage any new sports betting games in Greece as well as a right of first refusal to operate any new games permitted by Law.

Lottery Concession

The Lottery Concession, which was ratified by Law no. 4183/2013, entitled OPAP to exclusively operate Hellenic State lotteries.

VLT License

According to the provisions of Article 39 of Law no. 4002/2011, we initially held an exclusive 10-year license to install and operate 35,000 Video Lotteries Terminals (VLTs) in Greece, out of which 16,500 would have been installed and operated directly by OPAP through its network, while 18,500 would have been operated by concessionaires, to which OPAP would have conceded, against consideration and following an international tender, the right to install and operate them. However, following an amendment on November 2017, by virtue of the provisions of Chapter A, Part B’ of Law no. 4499/2017, the number of VLTs was reduced to 25,000 self-operated machines and the VLTs license duration was extended to 18 years, starting from January 2017, while also indicating OPAP’s obligation to ensure deployment of all VLTs until 31 December 2019. The HGC issued the Decision no. 225/2/25.10.2016 (GG 3528 Β’ 01-11-2016), regarding the installation and operation of VLTs.

Horse Racing Concession

After abiding to all terms and conditions provided on the Accession Agreement between Hellas Horse Races S.A. and Hellenic Republic Asset Development Fund, the company holds the exclusive right to organize and conduct terrestrial and online horseracing mutual betting in Greece for 20 and 5 years respectively, with its horse racing operations commencing in January 2016.

Online Gaming

The gaming concession entitles OPAP to exclusively conduct online gaming in Greece. HGC has the authority to blacklist any illegal operators and ban online access through local ISPs (Internet Service Providers). The preliminary framework for online gaming licensing was set up in 2011 and does not affect the exclusive games offered by OPAP. OPAP is also supervised by a three-member Supervisory Committee, which is established by the provisions of Article 28, paragraph 3A of Law no. 4002/2011, in order to ensure that OPAP and its agents comply with the legislation in force and OPAP’s contractual obligations towards the Hellenic Republic.

The Committee specifically monitors OPAP’s conduct regarding the following topics:

• Compliance with the terms of the gaming concession, the VLTs’ license and the gaming legislation.

• Protection of consumers against excessive participation and crimes related to games of chance.

• Protection of minors and other vulnerable groups.
• Reliability of games and players’ winnings.
• Protection of personal data.
• Payment of taxes and participation of the Hellenic Republic.

OPAP Group companies participate in a number of organizations and committees, relevant to their operation.

Organizations

• World Lottery Association (WLA)
• European Lotteries Association (EL)
• Hellenic Federation of Enterprises (SEV)
• Hellenic Network for Corporate Social Responsibility
• European Pari Mutuel Association (EPMA) (Horse Races)
• Global Lottery Monitoring System (GLMS)
• Hellenic Institute of Customer Service
• Hellenic Institute for Entrepreneurship & Sustainable Development

Working Groups

• World Lottery Association Security and Risk Management Working Group
• European Lotteries Public Affairs Coordination Working Group (ELPAC)
• European Lotteries Sport Working Group (EL Sport)
• European Lotteries Security and Integrity Working Group

20. Corruption prevention and alleviation

ADMINISTRATIVE PRACTICES

The Company is committed to conduct its business with honesty, integrity and fairness and expects all stakeholders to maintain these high standards.

Our Code of Conduct outlines the main principles and behavioral rules, as well as provides guidance to all members (i.e. Board of Directors, Chief Officers, managers and employees) on issues that may arise within OPAP. The Code of Conduct strictly prohibits all employees to offer, solicit or accept gifts, donations, in cash or in any other form, and any benefit related to the performance of their duties. They may only be allowed to accept or offer non-cash gifts/hospitality of value not more than €150 arising out of customary business practices. In this case, pre-approval must be received from the immediate manager and the fact that a gift was offered or received must be reported to the Regulatory and Compliance Officer, who maintains a gifts and hospitality registry. Gifts should be transparent, infrequent and should not be offered or accepted during contractual negotiations, tender processes or if aware that one is imminent with a supplier. Offering hospitality/tickets to events should be solely for the purpose of OPAP Group employees building business relationships. It is important that gifts or hospitality never influence business decisionmaking processes, or cause others to perceive an influence. OPAP Group is committed to maintaining the highest standards of ethics and integrity in the way it does business in Greece and Cyprus. Fraud, bribery and corruption in all forms are illegal and unacceptable.

However, all organizations face the risks of things going wrong from time to time. The company has established the Whistleblowing Complaints Policy by which employees can and should report valid allegations of known or suspected improper activities, in good faith and without the fear of retaliation, to their immediate manager and the Regulatory and Compliance Officer respectively.

Any person can file a complaint or concern in one of the following ways:

• Via an electronic platform accessible to the stakeholders by sending an email to [email protected]

• By contacting the number 210 5798193
• Via a personal hearing

Complaints received under the Whistleblowing Complaints Policy will be reviewed under the oversight of the Audit Committee, by the company’s Regulatory and Compliance Officer, the Internal Audit Team, or such other persons as the Audit Committee or the Regulatory and Compliance Officer determine to be appropriate.

The above policy aims to encourage people to immediately report suspected incidents and guarantees that their concerns will be taken seriously and investigated as appropriate.

In 2018, two complaints were raised through the whistleblowing mechanism in relation to OPAP’s human resource’s policies and processes. Both complaints were dealt with and were subsequently closed.

 In 2014, we established the Antifraud team, which cooperates end-to-end with all teams across the company and is responsible for the investigation and tackling of internal and external fraudulent activities across the OPAP network and all its subsidiaries and products. Furthermore, the team cooperates and reports any findings of fraudulent nature to the authorities and responds to their inquiries.

The analytics mechanisms set up by the Antifraud team during the launch of the new Pamestoixima.gr online platform in 2018, covered 30% of the online customer data base. 92% of the financial transactions were reviewed for potential fraud, resulting to risk mitigation actions that covered over 2.6% of the customer data base. At the same time, the Antifraud team ensures that none of the benefits of the incentive schemes offered by OPAP to its customers have already or will in the future be abused or manipulated by high risk customers.

Anti-Money Laundering

We comply with applicable framework and the Hellenic Gaming Commission’s Decision no. 129/2/2014, as currently in force, which introduced measures to prevent money laundering and terrorist financing in the gaming sector.

OPAP has a “Policy on the prevention of the use of OPAP gaming products for the purpose of money laundering and terrorism financing” in place for OPAP S.A., Hellenic Lotteries S.A., and Horse Races S.A. which applies to all employees, agents and salesmen of OPAP products. The AML/CTF Policy describes a set of principles and procedures to minimize the risk of using OPAP’s products for money laundering and terrorism financing.

As mandated by the Policy, the AML Compliance Officer, who is appointed by the Board of Directors and notified to the Hellenic Gaming Commission, is responsible to continuously assess AML risks and submit recommendations to the Board of Directors, in order to effectively mitigate those risks. The Board of Directors also receives and assesses an AML semi-annual Report with the actions and the measures taken to prevent money laundering and terrorism financing.

AML/CTF Audits

OPAP conducts regular audits to internal stakeholders and its network, in order to ensure their compliance with the Policy and the AML requirements During these audits, we review the following:

• Compliance with procedures to collect, update and maintain players’ data.
• Proper implementation of the Know your Customer (KYC) procedure for new and existing players.
• Compliance with procedures to identify and report suspicious transactions.
• Proper record keeping.
• Review of player behavior in order to provide winning certificates to players.

Furthermore, we have introduced a digital platform (winningscerificates.opap.gr), which enhanced our KYC and AML procedures with regards to issuing winnings certificates and significantly improved the efficiency of the issuing process.

As a result of the above-mentioned practices, within 2018, we:

• Performed AML audits to our whole network.
• Imposed monetary fines to agents regarding identified violations of procedures
• Imposed fines regarding non-compliance with law and regulations to our agencies.
• Submitted reports to the Hellenic Financial Intelligence Unit pursuant to applicable legal framework.
• Issued 19 written warnings to specific agencies due to violations of gaming regulations related to financial transactions.

AML/CTF Trainings

We provide continuous training on AML/ CTF issues for our employees and agents and we inform and notify them in case there are changes in the regulatory framework.

Within 2018:

• The AML Team attended a series of training courses.
• We organized a mandatory AML e-training course for the whole network that started in 2018 and is expected to be concluded in 2019.
• We communicated messages to the entire retail network to inform them about their key obligations under the AML Regulation and our relevant AML Policy.

Illegal Gambling

Acknowledging our role as the leading gaming company in Greece, we strive to address the issue of illegal gambling in the market. Illegal gambling practices not only endanger the industry’s reputation but also more importantly, the players’ wellbeing. Therefore, we make every effort to support the authorities in their battle against the illegal gambling phenomenon, either online or offline, and at the same time work towards establishing a fair and accessible-to-all gaming environment that offers entertainment to the general public.

Addressing Illegal Gaming in 2018

• 178 complaints were received about potential illegal gaming locations.
• 143 confirmed unique illegal gaming / betting locations were identified.
• 109 unique illegal gaming / betting locations discontinued their operation.
• 1,661 illegal betting sites were reported to HGC and included in its Blacklist (i.e.
• in the list of websites to which access through a Greek IP is prohibited)
• 31 complaints were sent to local prosecutors or/and police authorities.
• 92 affidavits were provided by FOT.

Raising Awareness

In 2018, OPAP raised awareness about illegal gambling by:

• Conducting training sessions to all staff members of OPAP’s call centers and offering them informative leaflets.
• Participating in nationwide roadshows and informing its agents about the IGO and FOT, thus actively engaging with them in maintaining a constant flow of information on the topic and subsequently enabling OPAP to monitor the phenomenon throughout the country.
• Communicating IGO’s contact details to the entire network via OPAP network terminals.
• Informing OPAP’s Area Sales Representatives about the illegal activity in their respective areas of responsibility, while receiving valuable feedback.
• Actively participating at the first ever scientific event on the Criminal Treatment of Illegal Gambling, organized in Greece with the Security and Risk Management Team Director being one of the speakers, stating the actions and initiatives of OPAP at the field in question.

See more https://investors.opap.gr/~/media/Files/O/Opap-IR/05062019/OPAP%20Integrated%20Report%202018_v10.pdf(p. 57-64)

PERFORMANCE INDICATORS

GRI SRS-205-2

Within 2018:

• The Anti-Money Laundering (AML) Team attended a series of training courses.
• We organized a mandatory AML e-training course for the whole network that started in 2018 and is expected to be concluded in 2019.
• We communicated messages to the entire retail network to inform them about their key obligations under the AML Regulation and our relevant AML Policy.

GRI SRS-205-3

In 2018 there were:

• No confirmed incidents of corruption or pending lawsuits related to corruption or relevant sanctions imposed by respective authorities.
• No legal accusations of corruption filed against the company or pending accusations of corruption or legal fines imposed on grounds of corruption against the company.

Also, no legal actions regarding incidents of money laundering and terrorism financing were taken against OPAP and no fines or sanctions were imposed to OPAP for AML/CTF issues. We had no incidents of contract termination or no renewal due to money laundering violations.