POLYECO S.A.

1. Strategic, Analysis & Action

ADMINISTRATIVE PRACTICES

Being by definition a company having sustainability at the heart of our business and servicing blue chip clients, NGO’s, UNIDO, UNEP, UNPD and the World Bank, Polyeco’s main focus is in leveraging the dynamics and structured synergies between the affiliated companies of our group to persevere the promotion and implementation of a management approach coherent with all the UN Global Compact principles.

Our company’s sustainable development strategy is guided by a continuous performance improvement plan. The plan defines yearly priorities and objectives whose progress is regularly monitored and evaluated. This plan plays a key role in determining and validating Polyeco’s commitments with regard to social responsibility, environmental management, governance, human rights, labour and ethics.

Our company's strategy is also based on the EU Action Plan for the Circular Economy adopted from the European Commission, as an industrial economy that is not producing waste and pollution, which includes revised legislative proposals on waste to stimulate Europe's transition towards zero waste generation, and measures covering the whole cycle from production and consumption to waste management and the market for secondary fuels and secondary raw materials. So, the high priority’s objective of our policy is ‘’Making More from Waste: Recovery/Recycling/Reuse’’ . At our main hazardous waste treatment facility we treat hazardous waste preventing their release into the environment and provide environmentally friendly methods of managing hazardous materials according to the Circular Economy Principles. Moreover, one of the biggest business

themes in a global economy geared towards the Global Goals is the minimization of waste, through resource saving and energy recovery.

In order to ensure its sustainable development, Polyeco implements programs, initiatives and practices that reflect its values and define its Corporate Social

Responsibility (CSR), voluntarily incorporating social and environmentally friendly targets in everyday business activities,both in Greece and the countries across the globe where the company implements waste management projects.

Polyeco is a founding member of the Hellenic Foundation of Enterprises Board for Sustainable Development and has committed to implementing the “Code of Sustainable Development Principles” and to integrate those principles in the decision making procedure. Polyeco is also a member of the United Nations Global Compact, the greatest global initiative on Corporate Responsibility. As a member of the UN Global Compact our company has committed to align its principles with ten globally approved principles in the field of human rights, labor, environment and fighting corruption.

PERFORMANCE INDICATORS

Reporting on social and environmental performance is based in an integrated internal system developed and updated by Polyeco which facilitates the process of collecting, compiling, reporting its non-financial performance throughout the Company plants, in accordance to Polyeco’s sustainability strategy and commitments and more specifically to UNGC COP criteria and WBCSD- World Business Council for Sustainable Development/ CSI-Corporate Social Investment Guidelines.

Polyeco’s Quality Management System is in full compliance with the requirements of ISO 9001: 2015, Regulation 1221/2009 / EC (EMAS) and ISO 14001: 2015.

Polyeco is certified according to:

• Quality Management System certified as per EN ISO 9001
• Environmental Management System verified according to EMAS III (EU Regulation 1221)
• Occupational Health & Safety Management System certified as per OHSAS 18001
• Quality Control Laboratory accredited under the terms of ELOT EN ISO/IEC 17025
• Security Management System for the supply chain certified as per EN ISO 28000

2. Materiality

ADMINISTRATIVE PRACTICES

In Polyeco, we assess our corporate responsibility by analyzing our impact on the SDG’s through the materiality analysis.

Materiality is about identifying the most critical economic, environmental and social issues, related to Polyeco’s activities, which may reflect a significant impact, positive or negative, on the company’s business performance and influence the decision-making of our stakeholders.

The Materiality process is the backbone of our report. It is implemented within the company on an annual basis and involves reaching out to internal and external stakeholders to get their input.

PERFORMANCE INDICATORS

The 2018 Sustainability Report (https://polyeco.gr/wp-content/uploads/2019/10/Global-Compact_2018_POLYECO-SA-1.pdf) refers to the Sustainable Development Topics, emerged from the process as most critical:

3. Objectives

ADMINISTRATIVE PRACTICES

The main objective of our policy is to prevent accidents or the creation of environmental problems, to the extent possible, by reducing any potential risk that could lead to environment pollution, through our Environmental Management System, continuous improvements, and the active participation of all our employees.

We intend to stabilize carbon emissions and environmental footprint from our operations, to the lowest possible level through renewable energy investments.

The other high priority’s objective of our policy is ‘’Making More from Waste: Recovery/Recycling/Reuse’’. At our main hazardous waste treatment facility we treat hazardous waste preventing their release into the environment and provide environmentally friendly methods of managing hazardous materials in accordance with the circular economy principles.

We have also set a goal to go beyond simple compliance by voluntarily obtaining the Social Accountability International Standard (SA8000) certification based on international human rights and labour conventions by 2018, to credibly demonstrate to all of our stakeholders and interested parties that existing company policies, procedures, and practices conform to the requirements of this standard. The success of our business depends on every employee in our global enterprise. We are committed to fostering open and inclusive workplaces that respect human and workplace rights, where all employees are valued and inspired to be the best they can be.

PERFORMANCE INDICATORS

The foundation of our approach lies in two key documents: our Code of Ethics and Business Conduct an our Workplace Policy Handbook. Both are influenced by the United Nations (UN) and International Labour Organization (ILO) declarations. Together, they describe our high standards and expectations, addressing such subjects as child labour, forced labour, freedom of association, discrimination, health and safety, hours of work and Human Rights.

Our Code of Ethics and Business Conduct and our Workplace Policy Handbook, apply to all entities in

which Polyeco S.A. owns a majority of interests.

Implementing the United Nations Guiding Principles on Business, labour and human rights in our corporate context we use three primary components:

a.Our Code of Ethics and Business Conduct a key document used as a framework for respecting

human rights in our business context influenced by UN A/RES/3/217 Universal Declaration.

b.Our Workplace Policy Handbook influenced by the Greek Labour legislation, the UN A/RES/3/217

Universal Declaration of Human Rights and International Labour Organization (ILO) declarations

c.A due diligence process to identify, prevent, mitigate and be accountable for labour and human

rights abuses. We keep our processes and services as “clean” as possible, this means that all our facilities are already certified under the EMAS environmental management standard. The continuous improvement of our services is translated into direct benefits for the environment.

4. Management of Value Chain

ADMINISTRATIVE PRACTICES

“We aim to create maximum positive impact, focusing on the protection of the environment along our value chain.”

When we talk about our value chain, we mean the full range of activities it takes for us to provide our services to the market – from waste collection and treatment to final disposal.

Polyeco is a modern and dynamic enterprise providing integrated sound waste management, with products and services that relate to protection of the environment addressed to various business sectors and industries. The overall activity of the company is to identify and understand the hazards inherent to the activities we undertake and effectively assess, control and manage those risks. We also provide on-site hazardous and non-hazardous integrated waste management solutions, decontamination and site remediation, to client’s facilities.

Our value chain is connected to a variety of companies, people, communities, ecosystems and other businesses around the world. Through its operations POLYECO S.A. promotes environmental protection, conserves natural resources, fauna and flora, public health and public interests. We take reasonable steps to preserve the environment through responsible practices to minimize the environmental impact of our operations by complying with all applicable laws, guidelines and waste management industry standards. 

The infographic below shows an overview of the different stages of our value chain:

PERFORMANCE INDICATORS

SUSTAINABILITY AND CORPORATE RESPONSIBILITY REPORT 2018 

Sustainability Management (Pages 17- 26)

5. Responsibility

ADMINISTRATIVE PRACTICES

6. Rules & Processes

ADMINISTRATIVE PRACTICES

Our company operates in full compliance with the European and Greek Law regarding human rights, Labour, Environment, Health and Safety and the operation (permissions etc) of the plants and generally in full compliance with the legislation on all of its activities, as well as the local laws and legislations of all other countries in which we operate.

POLYECO S.A. policies, procedures and protocols are accessible on the POLYECO S.A. Intranet and some of them are also publicized on its website and in COP REPORT.

The umbrella principles set forth in our Code of Ethics and Business Conduct and in our Workplace Policy Handbook. Both are influenced by the United Nations (UN) and International Labour Organization (ILO) declarations. Together, they describe our high standards and expectations, addressing such subjects as child labour, forced labour, freedom of association, discrimination, health and safety, hours of work and Human Rights, and they are supported by policies applying to both the general conduct of POLYECO S.A. and the individual conduct of each employee.

PERFORMANCE INDICATORS

The subjects covered by Code of Ethics and Business Conduct and in our Workplace Policy Handbook include compliance with laws and regulations, workplace safety and health, protection of environment and human rights, relations with local communities and trade unions, diversity and equality, confidentiality, conflicts of interest, prevention of fraud or corruption, insider trading, protection of the assets, transparency, fair competition, and integrity. The Code and the related policies take into account changes and developments in applicable international regulations, as well as best practices implemented by POLYECO S.A. The enforcement of the Code and the relevant policies and protocols is supported with appropriate organization and review, training and communication and reporting, and control tools.

There are more information about our business behaviors and ethics in COP REPORT.

7. Monitoring

ADMINISTRATIVE PRACTICES

POLYECO S.A.  has established a set of key performance indicators (KPIs) in alignment with Global Compact. These data help monitor and measure Sustainable Development performance and implementation. In addition, the POLYECO S.A. employees have an active involvement in the area of Sustainable Development.

POLYECO’s Group of Companies has no track record with incidents of human rights violations. Success in this field is generally measured by the lack of reports of violations of policy or law regarding the human rights, and, to date, there have been no reported violations in Polyeco, nor within the group of our parent and sister companies nor from our contractors. Should a violation be reported, we intend to undertake a thorough investigation.

PERFORMANCE INDICATORS

POLYECO S.A. Sustainable Development strategy is guided by a continuous performance improvement plan. The plan defines yearly priorities and objectives whose progress is regularly monitored and evaluated. This plan plays a key role in determining and validating POLYECO S.A. commitments with regard to social responsibility, environmental management, governance, human rights, labour and ethics.

There are more information on POLYECO S.A. performance indicators of 2016 on Sustainable Development in COP REPORT 2016.

8. Incentive and reward systems for Sustainable Development

ADMINISTRATIVE PRACTICES

9. Stakeholder Engagement

ADMINISTRATIVE PRACTICES

Stakeholder engagement is the process of involving and interacting with people who may be affected by the decisions that the company makes or can influence the implementation of its decisions.

Polyeco recognizes that requirements, expectations, perceptions, personal agendas and concerns of its stakeholders have a direct impact and influence on the company’s sustainable development and the outcomes that can be achieved. Successful stakeholder engagement is therefore a vital requirement for the company’s professional project management.

As it is essential to keep up an open and unrestricted dialogue with stakeholders, we implement a stakeholder management system which includes a systematic identification, analysis, planning and implementation of actions designed to engage with stakeholders, such as consultation, communication, negotiation, compromise, and relationship building.

COMMUNICATION WITH STAKEHOLDERS

The sustainability management conducted by Polyeco holds up the responsibility and aims to provide desirable values to each stakeholder. For this reason, we have built up various communication channels to identify stakeholders’ interest and have made every effort to ensure the prevention of risks and creation of new opportunities.

Polyeco has identified the following stakeholders with whom it interacts in the course of its business: customers, shareholders, employees, suppliers, regulators and wider society. Polyeco’s communication channels and interaction with its stakeholders is illustrated in the table below.

PERFORMANCE INDICATORS

SUSTAINABILITY AND CORPORATE RESPONSIBILITY REPORT 2018 

Sustainability Management (Pages 17- 26)

10. Product Responsibility and Innovation

ADMINISTRATIVE PRACTICES

POLYECO S.A. is a modern and dynamic enterprise providing integrated sound waste management, with products and services that relate to the environment’s protection addressed to various business sectors and industries. The overall activity of the company is to identify and understand the hazards inherent to the activities we undertake and effectively assess control and manage those risks. Polyeco also provides on-site hazardous and non-hazardous integrated waste management solutions, decontamination, site remediation and building capacity, to its client’s facilities and by conducting client’s personnel training and assessments.

We keep our processes and services as “clean” as possible, by applying BEST AVAILABLE TECHNIQUES according to our permissions, this means that all our facilities are already certified under the EMAS environmental management standard. The continuous improvement of our services is translated into direct benefits for the environment.

PERFORMANCE INDICATORS

The above mentioned KPIs are met into the COP REPORT 2016.

11. Usage of Natural Resources

ADMINISTRATIVE PRACTICES

Polyeco is committed to continuously improving its energy and environmental performance while respecting the environment, its legality, its employees, its customers, its shareholders and society in general, with the main aim of preventing accidents and occupational hazards in the workplace and creating a safe working environment, along with the reduction of its environmental footprint and the provision of high quality products and services.

In this regard, based on its strategy and vision, Polyeco operates with the application of the Best Available Techniques in accordance with the Sustainable Development Standards, under AGENDA 2030 of the 17 UN Sustainable Development Objectives, promoting environmental investments.

Compliance with environment-related laws and regulations

Polyeco ensures that it adheres to international best practices and is focused improving  its performance and adhering to the provisions of its operational license, according to the SDG6, SDG7, SDG15, SDG17. Polyeco participates in industry bodies, in employment bodies, in thematic stakeholder forums and public events, in order to promote the compliance with International and European standards, Decisions, Directives & laws.

The Polyeco Quality Manual is under amendment, to effectively capture Polyeco’s needs to cover  the sustainability performance criteria, beyond the standard conditions of quality of products, services, environmental legislation- aspects, and legal compliance with respect to environmental protection, health and safety.

In addition, Polyeco’s operations aim to reduce its environmental footprint, while respecting international, EU and national legislation. In order to continue its successful course at an international, European and national level, Polyeco adapts the requirements of its projects to provide innovative solutions with state-of-the-art equipment, making our company one of the largest waste management companies internationally, with hundreds  of successful projects around the world.

PERFORMANCE INDICATORS

Performance in 2018

In full compliance with EMAS Regulation, Polyeco constantly monitors the basic environmental indicators measuring: water consumption, electricity consumption, greenhouse gas emissions and total annual emissions of air pollutants (NOx, SO2, and particulate matter) that arise from the company’s activity.  Polyeco also monitors the levels of Environmental Noise within its facilities and conducts Liquid Waste Measurements.

The company has developed environmental programs, setting specific goals, invests in environmental projects and implements the best available environmental techniques and practices for achieving continuous improvement.

Indicatively, Polyeco monitors the Consumption of Resources within its facilities and takes appropriate measures in an effort to reduce the effects that arise from the use of electrical and electronic equipment, toners/inks, lamps, batteries, lubricants and packaging materials.

Environmental Key Performance Indicators (KPIs)

The calculation of key indicators of environmental & safety performance is based on consolidated data from alternative fuels & alternative raw materials production and the waste management plants and their attached facilities. Emissions and consumption of natural resources are avoided due to (1) the strict application of environmental permit measures and conditions, as well as (2) the implementation of the provisions of Directive 2010/75/EU (On Industrial Emissions - Integrated Pollution Prevention and Control).

The social performance indicators are calculated according to the integrated Polyeco data management system, which includes an internal CSR software platform for all data collection and consolidation processes, which are the basis for calculating social performance data.

More info at SUSTAINABILITY AND CORPORATE RESPONSIBILITY REPORT 2018 

Environment (Pages 69- 85)

12. Resource Management

ADMINISTRATIVE PRACTICES

In the context of the implementation of its products and services, POLYECO SA is committed to act in a way that protects the Health, Safety and well-being of its personnel, third parties, customers and people affected by its activities.

Also aware of its responsibilities and duties towards its shareholders and stakeholders, POLYECO SA is committed to internationally recognized health, safety and environmental standards. POLYECO SA will act in an ethical and socially responsible manner with ambition to avoid negative impacts, enhance positive effects and contribute to sustainable development.

This HSE policy applies to all activities of Polyeco from conceptual design to operations; its principles apply to all personnel working on behalf of Polyeco whether as employees, contractors or suppliers.

For POLYECO SA, Quality and Environmental Management, requires the following goals to be achieved:

• Ensuring the quality of its products and services through efficient planning and monitoring of its operation.
• To be recognized as a company which respects the environment
• Application and monitoring of appropriate quality and environmental practices.
• Continual service improvement and fully satisfied customers.
• Minimizing environmental and risk impacts associated to company’s operation (including stakeholder needs and expectations)

In order to achieve the above objectives, POLYECO SA is committed to:

• Implement a Quality Management System in full compliance with the requirements of ISO 9001: 2015, Regulation 1221/2009 / EC (EMAS) and ISO 14001: 2015. The Integrated System of Quality Management and Environmental Quality Management requires:
• Commitment that applies to all members of the staff, as well as Management
• Communication and feedback of experience to all company’s levels
• Provision of adequate training and guidance in general and specialized issues of quality and environmental management, to all employees.
• Defining, monitoring and reviewing measurable quality and environmental management objectives, targeting continuous improvement, minimizing risks, customer’s protection, meeting customer needs and expectations, continuously deliver compliant products and services to the customer, knowledge of the company in depth.
• Monitoring, documentation and evaluation of company performance on quality and environmental management.
• Implementation and verification of corrective actions
• Regular inspection of procedures
• Compliance with all legal and regulatory requirements that company is subject and which are related to the implementation of its services, environmental and occupational health and safety risks
• To constantly seek to exceed  customers’ expectations
• To provide the necessary means for the safe operation and continuous improvement of the Integrated System
• To constantly seek new ways to enhance business processes
• Continually improvement of company’s performance on quality and environmental management

The policy is periodically reviewed for its continuous adequacy and effectiveness, its response to customer requirements and to legislation, the orientation towards continuous company’s improvement and the general management meetings that are held at least on an annual basis. This Policy is communicated to the entire company and is strictly binding for all employees, suppliers or subcontractors.

The responsibility of all employees involved in the operation of the Quality Management and Environmental Management System, starting with Company’s Administration, is not only to comply with the Integrated System, but also to actively contribute to the improvement of the implemented procedures.

Objectives/ GOALS  & programs of environmental management

Environmental objectives result from the analysis following the identification and assessment of the environmental impacts. These objectives are defined in such a way in order to minimize or even eliminate the conditions which contribute to the occurrence of environmental problems.

Environmental Goals are described as defined and quantitative indicators which shall be implemented within specific time limits so as to achieve the respective Environmental Objectives. Identification of the Environmental Goals is based on the requirements which have been linked with the Environmental objectives.

For each environmental Objective and Goal the corresponding Environmental Management Plan is established which specifies how the goals will be achieved, who is responsible for each of the required actions as well the cost and time horizon for their implementation.  

The following table presents the Environmental Objectives and Goals set by POLYECO for the management of significant environmental issues, as well as the environmental plans that have been implemented for the year 2018 in order POLYECO achieve the respective goals.

PERFORMANCE INDICATORS

SUSTAINABILITY AND CORPORATE RESPONSIBILITY REPORT 2018 

Environment (Pages 69- 85)

13. Climate-relevant emissions

ADMINISTRATIVE PRACTICES

Furthermore, Polyeco is implementing measures and actions in order to reduce greenhouse gas emissions, the main cause of climate change. Except for the use of energy efficient products, POLYECO S.A.  has established a solar power station at its facilities in Aspropyrgos. We are also conducting efforts in order to reduce water usage by establishing monitoring and targeting system. It should be mentioned that for the achievement of the targets set in the field of environmental protection the company strongly encourages the participation of the employees and ensures their constant education on the practices that can be applied for the conservation of resources. The training programs are conducted by external partners or by the company’s executives. The educational themes cover all the aspects of environmental management of the existing Quality and Environmental Management System. The employees are informed about the environmental policy applied by the company, the environmental goals and targets the applied environmental programs as well as the environmental effects of the company’s operation.

PERFORMANCE INDICATORS

In full compliance with EMAS Regulation, POLYECO S.A. constantly monitors the basic environmental indicators measuring: water consumption, electricity consumption, greenhouse gas emissions and total annual emissions of air pollutants (NOx, SO2, and particulate matter) that arise from the company’s activity.

The above mentioned KPIs are met into the COP REPORT 2016.

14. Employment Rights

ADMINISTRATIVE PRACTICES

At Polyeco, we value the relationship we have with our employees. The success of our business depends on every employee in our global enterprise. We are committed to fostering open and inclusive workplaces that respect human and workplace rights, where all employees are valued and inspired to be the best they can be.

To meet this demand, we employ dynamic individuals, with credible experience and passion. Over the years, we have been fortunate to attract some of the most talented professionals in our industry. Our dedicated and highly educated personnel is our competitive advantage, the most valuable asset for achieving management initiatives and corporate growth.

How we conduct business is fundamental to our success and achieving our results. We believe ethics and compliance is our shared responsibility. A commitment to integrity and ethical behavior is a critical factor in our decisions regarding professional advancement and compensation. The foundation of our approach lies in two key documents: our Code of Ethics and Business Conduct and our Workplace Policy Handbook. Both are in full compliance with the UN Global Compact principles and International Labour Organization (ILO) declarations.

Disclosure Management Approach

The foundation of our approach lies in two key documents: our Code of Ethics and Business Conduct and our Workplace Policy Handbook. Both are influenced by the United Nations (UN) and International Labour Organization (ILO) declarations.

Together, they describe our high standards and expectations, addressing such subjects as child labour, forced labour, freedom of association, discrimination, health and safety, hours of work and Human Rights.

Our Code of Ethics and Business Conduct and our Workplace Policy Handbook, apply to all entities in which Polyeco owns a majority of interests. Implementing the United Nations Guiding Principles on Business, labour and human rights in our corporate context we use three primary components:

1. Our Code of Ethics and Business Conduct, a key document used as a framework for respecting human rights in our business context influenced by UN A/RES/3/217 Universal Declaration.
2. Our Workplace Policy Handbook, influenced by the Greek Labour legislation, the UN A/RES/3/217 Universal Declaration of Human Rights and International Labour Organization (ILO) declarations.
3. A due diligence process to identify, prevent, mitigate and be accountable for labour and human rights abuses.

Our company complies with the Greek Labour Legislation in all of its activities, as well as the local laws and legislations of all the countries in which we operate. Among other regulations, these forbid all forms of forced and compulsory labour, give to employees the freedom and the right to resign from their work voluntarily and reward extra hours of work with additional payment.

PERFORMANCE INDICATORS

SUSTAINABILITY AND CORPORATE RESPONSIBILITY REPORT 2018 

Responsibility Towards Our Employees (Pages 43- 53)

15. Equal Opportunities

ADMINISTRATIVE PRACTICES

Polyeco introduces measures to promote equality, being aware of the diversities of language, culture and family circumstances that may exist in the workforce. Managers and supervisory staff seek to develop an understanding of the different types of discrimination and how it can affect the workforce.

Polyeco treats all employees fairly, ethically, respectfully and with dignity. Polyeco offers equal employment opportunities without any distinction based on age, gender, sexual orientation, disability, race, religion, citizenship, marital status, family situation, country of origin or other factors, in accordance with the laws and regulations of each country where it operates.

The selection, recruitment and remuneration of our personnel are based on their qualifications, skills, work experience, and on personal interview without gender, age, family status or other discriminations. Wages offered by the company are equal or greater than the minimum rates applicable for each job position. It is our policy, in accordance with all applicable laws, to recruit, hire, train and promote persons in all job titles without regard to race, sex, religion age, disability, nation origin, or any other characteristic protected by applicable law.

Within company operations and cooperation with other businesses, we ensure that employment contracts are provided to all employees stating the terms and conditions of service, the voluntary nature of employment, the freedom to leave (including the appropriate procedures) and any penalties that may be associated with a departure or termination of work.

Polyeco respects the freedom of association and the right of all employers and workers to freely and voluntarily establish and join groups for the promotion and defense of their occupational interests.

PERFORMANCE INDICATORS

SUSTAINABILITY AND CORPORATE RESPONSIBILITY REPORT 2018 

Responsibility Towards Our Employees (Pages 43- 53)

16. Qualifications

ADMINISTRATIVE PRACTICES

Our primary responsibility is the protection of all our employees, their corresponding salaries and fringe benefits. We ensure that our employees are paid well, at the least legal minimum wage; sufficient to meet basic needs, have access to affordable benefits, and work in a safe environment.

Wages and benefits are clearly communicated to workers; paid in convenient manner -cash or bank deposit; overtime paid at premium rate; all employees receive a wage receipt with an analysis of their payment that include, any overtime payment, tax and social security deductions.

Employee wellbeing

The wellbeing of our employees is a key component of our corporate values and sustainability. We have strengthened and expanded support initiatives for employees offering them benefits beyond the statutory minimum, to help them cope with balancing work and family commitments. In 2018, Polyeco signed a Private healthcare and life insurance program for all its employees.

We also actively protect motherhood and parenthood in our company through flexible labour regime, without any loss of benefits, for up to 12 months, as well as to our employees caring for elderly family members or family members with serious sickness. We have also established a leave/short working hour system for employees caring for family members with special needs rated over 80%.

Occupational Health and Safety Management

We are measured by our ability to safeguard the health, safety and welfare of our people. Polyeco is committed to achieving excellence in providing a healthy and safe working environment and to supporting environmentally sound practices in the conduct of its activities.

Recognizing the social and economic dimension of the occupational accidents Polyeco has developed and applied a comprehensive and effective Safety & Health Management System according to OHSAS 18001 standard and The Health and Safety at Work etc Act 1 974 requirements.

PERFORMANCE INDICATORS

SUSTAINABILITY AND CORPORATE RESPONSIBILITY REPORT 2018 

Responsibility Towards Our Employees (Pages 43- 53)

17. Human Rights in the supply chain

ADMINISTRATIVE PRACTICES

Human Rights

Respecting human rights is a fundamental part of Polyeco’s responsibility as a company and is vital to operate our sustainable business. We are committed to respecting fundamental human rights in our operations, our value chain, and in the communities where we operate. We seek to avoid complicity in human rights abuses and to use our influence to promote the fulfillment of human rights.

Our commitment to operating with respect for human rights is reflected in all aspects of Polyeco’s business operations and is integrated in our company policies and relevant procedures. We aim to identify, assess, and manage the human rights impacts of our business activities based on the operational context, our leverage and business relationships.

In this context, Polyeco has developed and implements a human rights policy, according to which the company commits to align its operations and strategies with the universally accepted principles in the areas of human rights. Polyeco’s Human Rights Policy is integrated within the company’s standards of its Code of Ethics and Business Conduct.

Women in the workforce

Polyeco looks to those human rights defined in the Universal Declaration of Human Rights and its two corresponding covenants, The International Covenant on Civil and Political Rights and The International Covenant on Economic, Social and Cultural Rights. Additionally, we also look to children’s and women’s rights as outlined in the United Nations Convention on the Rights of the Child and the United Nations Convention on the Elimination of Discrimination against Women.

Polyeco’s approach to its business operations is in compliance with the ILO International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, The Children's Rights and Business Principles, the OECD Guidelines for Multinational Enterprises and the United Nations Global Compact, to which we are signatories.

Child Labour

Child labour is an essential concern for Polyeco. In this context, we use adequate and verifiable mechanisms for age verification. We ensure the adherence of minimum age provisions of national labour laws and regulations, especially in countries with Low Human Development Index, where Polyeco executes many of its projects. We are against any form of child labour in all of our operation in Greece and abroad, and the same we require from our contractors and supply chain.

Discrimination

The workplace is a strategic entry point for freeing society from discrimination. Combating discrimination at the workplace can help reduce disadvantages, such as in education, resulting from inequity that people may have suffered at earlier stages in life. When the workplace brings together workers of different races, sexes and ages, for example, and treats them equally, it helps build a sense of common purpose. By doing so, it defuses stereotypes and prejudices that are at the heart of discrimination.

PERFORMANCE INDICATORS

SUSTAINABILITY AND CORPORATE RESPONSIBILITY REPORT 2018 

Responsibility Towards Our Employees (Pages 43- 53)

18. Corporate Citizenship

ADMINISTRATIVE PRACTICES

Corporate Social Responsibility constitutes of systematic voluntary integration of activities in a social, environmental and cultural dimension in our every-day practices which, though cannot be categorized as sheer charity or public relations, significantly contribute to sustainable development firmly founded on the principles of ecological, financial and social sustainability.

Since its foundation in 2001 Polyeco implements programs, initiatives and practices that reflect its values and define its Corporate Social Responsibility (CSR), incorporating social and environmental friendly targets in its everyday business activities. Over the years, Polyeco has been supporting both local and broader community, focusing on the following key points: SUSTAINABLE PLANET & ENVIRONMENT, CULTURE, EDUCATION, RESEARCH & INNOVATION, SPORTS & HEALTH, VULNERABLE SOCIAL GROUPS.

Highlights 2018

• Financial Support at the CRETE 2018 6th International Scientific Conference "Industrial and Hazardous Waste Management -CRETE 2018", which took placefrom 4 to 7 September 2018 in Chania.

• Sponsorship at the ECOCITY FORUM 2018 International Conference "Circular Economy In Smart Cities" held in Thessaloniki from 3 to 5 October 2018.

• Financial Support at the 6th International Conference on Sustainable Waste Management, held in Naxos on 13 - 16 June 2018, whichfocused on sustainable waste management, with emphasis on the development and implementation of effective practices and modern technologies.
• Financial support of our National Karate Team athlete Christina Kavakopoulou for her participation in the Shanghai Pre-Olympic Tournament, with the aim of qualifying her for the Tokyo Olympic Games in 2020.

• Financial support of the 'Enosi Galatsiou' Volleyball Association.
• Sponsorship of the Scouts of Greece for the organization of the Annual Panhellenic Cultural Meeting for Venture Scouts held on April 12-15, 2018, in thecity of Elefsina.

• Sponsorship for the renovation of the new building granted by the Municipality of Thessaloniki to the Federation of Industries of Northern Greece.

It is worth mentioning that the sense of high responsibility towards society that characterizes Polyeco's business ethics has gradually been incorporated into the culture of its employees. Recognizing the importance and necessity for volunteering and social solidarity, it is not uncommon for company employees to urgently develop initiatives and contribute to raising money and goods where needed, as they did for the fire-ravaged residents of deadly fire that hit the area of Mati in eastern Attica in 2018, the flood-ravaged residents of Mandra Municipality and refugees.

In our 2014 Report we had the pleasure to announce the launching of Polyeco’s ambitious Contemporary Art Initiative, PCAI, which primarily aims at raising environmental awareness through a unique art program inspired by the crucial issue of waste management, which is not only technical, but also environmental and social. Since then, Mr. Athanasios Polychronopoulos, Executive Chairman of Polyeco Group, Director of PCAI and driving force behind the company’s art initiative, decided to implement a sprinting strategy towards the implementation of PCAI’s objectives. His genuine belief that art is the best tool to stimulate dialogue about waste management was complimented by his wish to share this assumption with the company’s employees, clients and the general public.

The objective has been to create a framework that will allow Polyeco to implement its unique environmental awareness raising program. Within three years PCAI has accomplished to finalize its structure and to begin the implementation of its vision.

PERFORMANCE INDICATORS

SUSTAINABILITY AND CORPORATE RESPONSIBILITY REPORT 2018 

Sustainable Development and CSR (Pages 27- 42)

19. Initiatives and Political Influence

ADMINISTRATIVE PRACTICES

Memberships in Associations & Organizations

Collaboration between different types of organizations is one of the keys for unlocking sustainability.

Polyeco takes the challenge of sustainability seriously and in this context, supports and cooperates with governments, investors, local communities, nongovernmental organizations (NGOs), local, national and international organizations and associations which cultivate dialogue and promote best business practices.

• Since 2013, Polyeco is a member of the world's largest corporate sustainability initiative, the United Nations Global Compact, actively supporting and promoting its Ten Principles on Human Rights, Labour Standards, Environment and Anti-corruption, by implementing and integrating those principles in the decision making procedure.
• Since 2014, Polyeco is an ambassador for the Sustainable Greece 2020, an Initiative that aims to create a development model that ensures a Sustainable Economy and Society.
• Polyeco is an ISWA Silver Member since 2015 and is actively involved in the Association's work and activities, thereby helping the Association to promote sustainable waste management across the world.
• European Association for Co-processing represents companies active in pre-treatment operations of (mainly) hazardous waste streams. Being involved in the waste treatment in order to transform it into waste-derived fuels, Polyeco provides a sustainable solution for the treatment of hazardous waste streams and enhances the EUCOPRO mission to promote the recovery of waste as an alternative to traditional waste disposal.
• Polyeco is a corporate member of ENA since April 2019. Consequently, Polyeco contributes but it also has access to the European expertise in the field of NORM and to the management of natural radiation sources.
• Polyeco is a member of the Hellenic Federation of Enterprises (SEV), an independent not-for-profit association that aims to advance entrepreneurship in Greece, by promoting conditions that foster entrepreneurship and the competitiveness of Greek enterprises. Mr. Athanasios Polychronopoulos, Vice President of Global Development of Polyeco S.A., is a member of the Board of the Hellenic Federation of Enterprices Council for Sustainable Development.

Polyeco also participates in the following organizations:

• The Greek Association of Environmental Protection Companies (PASEPPE)
• Hellenic Management Association (EEDE)
• Hellenic Solid Waste Management Association (HSWMA)
• Association of Greek Chemical Industries

PERFORMANCE INDICATORS

SUSTAINABILITY AND CORPORATE RESPONSIBILITY REPORT 2018 

Sustainability Management (Pages 17- 26)

Memberships in Associations & Organizations (Page 25-26)

20. Corruption prevention and alleviation

ADMINISTRATIVE PRACTICES

Polyeco applies an anti-fraud and bribery policy, which sets the company's strong commitment to preventing, deterring and detecting fraud and corruption.

It summarizes the responsibilities of the Board, management and employees, defines the fraud and corruption investigation and reporting processes, and describesrelated disciplinary actions.

All the employees have a key role to play in preventing and detecting fraud and bribery and must report their concerns promptly, using the relevant reporting channels. In an effort to increase our awareness on anti-corruption, to promote compliance, effective internal controls and ethics, we participate in anti-corruption workshops organized by OECD.

Anti-Corruption Laws

Each employee and director of Polyeco, as well as all agents and representatives, must comply with all applicable anti-corruption laws.

The laws of many other countries we operate in prohibit payments or offers to make payments of any kind, including the giving or offering of anything of value to foreign government officials, including officials of public international organizations, office seekers, political parties, or party officials to influence business in any way or obtain an improper advantage.

Polyeco performs an Evaluation of Legal Compliance for all activities placed in Foreign Countries. In each fraud alert, details are given on the proposed remedies, so that no such incidents occur. There is also a constant reminder, about the submitting updates and communication that are keys to avoiding fraud.

PERFORMANCE INDICATORS

Performance in 2018

Our HSSEQ Manager is our BIO (Business Integrity Officer) as of 2018, in order to ensure compliance and/or the Anti-bribery Company Policy.Through the internal auditing process, the BIO oversees the internal controls that have been carried out and recommends measures to improve controls and mitigate risks. The risk assessments that are performed by the internal audit lay the foundations for developing the audit plans and testing the internal controls. Internal Audits can act both as a deterrent and detection mechanism. In case possible fraud or bribery is detected through an Internal Audit, the authorized Representative should immediately notify the CEO of the suspected breaches. In 2018, no issues of fraud or corruption were identified in Polyeco.