PREMIA PROPERTIES

1. Strategic, Analysis & Action

ADMINISTRATIVE PRACTICES

Premia Properties Group (hereinafter, the “Company”) is active in the real estate development and management sector and aspires to be among the leaders in Sustainability and Responsible Entrepreneurship in Greece. As a leading real estate company, we are committed to sustainability as an employer, a business partner, a community member that aims in creating value for its shareholders. By acting Sustainably, the Company’s focus is to deliver professional service to its tenants as well as create robust financial results, and thus position itself in solid future growth.

The Company’s priority is to invest in and actively manage high quality assets in order to ensure their optimum return for all stakeholders. The Company is exposed to risks relating to Sustainable Development, as well as those originating from the uncertainty that characterizes assessments of precise market indicators and their future development.  Other risks include market risk, liquidity risk, credit risk and risk related to environmental and employment issues. Premia’s active risk management policy seeks to minimize the potential negative effect on the Company’s returns.

Adhering to the principle of going concern the Company purports the key factors that create uncertainty.

The real estate industry has been significantly affected by current macroeconomic developments, including the Coronavirus pandemic (COVID-19) and the measures imposed nationwide.

In the event of further deterioration of the socioeconomic climate due to the occurrence of a new wave of the pandemic and the uncertainty related to its duration and extent, unemployment, consumer expenditure and demand levels are expected to be fundamentally and adversely affected, which will impact the areas of operation in which both the Company and its tenants are active. Additionally, the Company’s capacity to mobilize capital for the implementation of future investments is significantly affected by prevailing macroeconomic conditions, changes in the financial system and the Greek stock market, among other things. So far, revenue has not been significantly affected by recent developments associated with the Coronavirus pandemic. Given the Company’s area of scope, it does not particularly burden the environment and it monitors any environmental impact its activity might have to achieve balanced financial growth in harmony with the protection of the environment.

The Company seeks to promote sustainable investment opportunities that will benefit the environment, its employees and society, and that will potentially produce high investment returns. It acknowledges the value of a corporate culture based on the following pillars of corporate responsibility: robust corporate governance, optimum quality of services, employee well-being, environmental protection, and social contribution.

Sustainable Development is the way in which the Company has opted to manage and operate its business to best serve its customers, care for the environment, create a suitable working environment for the continuous care of its employees’ and associates’ well-being, secure profits through optimal management of its asset portfolio, and achieve long-term prosperity.

The Sustainable Development Policy, which is published on the Company’s website and is communicated to all employees and direct associates, defines the principles and priorities that the Company adheres to in the above sectors.

At the same time, the Company implements and is harmonised with,

• The 17 Sustainable Development Goals of the UN,
• The Athens Stock Exchange Regulations Code,
• The Hellenic Corporate Governance Code,
• The ATHEX ESG Reporting Guide,
• Existing provisions and legislation,

while, starting this year, the above operating practices have been supplemented by the Greek Sustainability Code, i.e. the Greek adaptation of “The Sustainability Code”, which is the recognized European framework for ESG Reporting.

2. Materiality

ADMINISTRATIVE PRACTICES

Due to the nature of its activity, the Company is exposed to the fluctuations of the overall state of the Greek market.

The real estate market involves risk related to such factors as the location and marketability of properties, the overall commercial activity of the area and the type of use in relation to future developments and trends. These factors, both individually and combined, can lead to the commercial upgrading or downgrading of an area and of a property, with a direct effect on its value. The Company focuses its investment activity on areas and property sectors (i.e. commercial properties and logistics centres) which indicate future demand and marketability, according to current data and forecasts. In addition, the Company’s policy dictates that its investment properties are being appraised every six months by Independent Valuers and that required inspections and appraisals are carried out on every property it seeks to acquire.

At the same time, the protracted duration of the COVID-19 pandemic and the potential of further restrictive measures being imposed to stop its spread, have had a fundamental and adverse effect on the operations of basic sectors of the Greek economy.  The real estate industry has been effected by the macroeconomic conditions at supply/demand level, the effect it has on tenants’ obligations as well as the discount rate and how these affect a property’s fair value. However, it must be noted that this has not affected all sectors of the real estate industry to the same degree, as operations relating to the supply chain (logistics), which is the Company’s main sector of investment, have been affected less than other sectors.

Considering the environment in which it operates, the Company systematically identifies and defines key sustainability issues that relate both to its responsible operation and its balanced relationship with its stakeholders.

The process of recognizing essential issues involves:

• identifying and defining key issues pertaining to the real estate industry in Greece, and to the Company, in particular
• communicating in-house with individuals and teams, as well as with associates that have the appropriate “know-how”
• investigating and prioritizing key issues, identifying those that require immediate attention and submitting them for approval to the Company’s management

The main issues that evolved through the above mentioned process were:

1. Protecting the rights of the Company’s shareholders and stakeholders
2. Financial performance
3. Sustainable investments
4. Transparency in managing corporate matters
5. Ethical business practices
6. Strong corporate governance
7. “Creation” of the product (real estate) based on ESG criteria
8. Serving customers/tenants
9. Reliable commissions policy
10. Environmental performance
11. Social contribution
12. Employee well-being
13. Excellent working environment

3. Objectives

ADMINISTRATIVE PRACTICES

The Company’s growth is based on creating a property portfolio with added value and minimum investment risk by investing and managing specific asset sectors, such as investment properties and social impact real estate (i.e. schools). The possibilities relating to the alternative use and/or selling of properties will also be examined based on their long-term benefits to the Company and its shareholders. The Company aims in high-level performances in areas pertaining to Governance, Society, and the Environment, incorporating the ESG metrics of the Athens Stock Exchange Guide wherever applicable.

The Company seeks to invest in a well-balanced, high-quality, and highly diversified portfolio, with an emphasis on logistics, big-box and social impact real estate.

The Company’s ultimate goal is to invest in properties that generate a yield above 7%, by,

• Seeking investment opportunities
• Exploring strategic alliances
• Developing the Company’s investment base
• Effectively managing its capital structure
• Effectively managing properties and establishing long-term relationships with tenants
• Commitment to and support of local communities through provision of benefits
• Cooperating with tenants on the continuous rationalization of the properties’ use of energy in order to improve their efficiency, save on cost and reduce their environmental impact.

Specifically, over the next three years the Company will be aligned with a well-structured ESG Strategy that will strengthen its position in the new business model that will also be based on sustainability principles and will aim at:

• maintaining zero incidents of legal non-compliance,
• absolute integrity of everyone involved
• stable model corporate governance
• continual forecasting and sound risk management
• increase of profitability
• systematic publishing of ESG Reports
• investing according to ESG criteria
• retaining existing staff and integrating new executives into the Company’s workforce, always in line with equal-opportunities principles
• continual investment in employee training and development and employee benefits
• reducing its environmental footprint
• collaborating with socially and environmentally responsible suppliers
• instituting society-oriented corporate responsibility actions

The Company’s plan for the next 4-8 years aims at the transition of part and/or all of its assets to energy-efficient and sustainable buildings, i.e. “Green Buildings”. The Company is also orientating towards systematic ESG Reporting or Sustainable Development Reporting, which will cover its current and previous performances.

Target-setting and the specifics of the action-implementation of each goal will be defined by Premia’s management team and approved by its Board of Directors.

4. Management of Value Chain

ADMINISTRATIVE PRACTICES

One of the Company’s long-standing priorities is to create added value for its shareholders, its customers/tenants and its associates.

The Company seeks to sustain its executives’ accumulated know-how and expertise and based on that to continue to expand its network of customers and associates, reinforcing its operations in the real estate industry. It is also committed to act in a responsible manner towards its customers/tenants and to meet their needs and expectations, strengthening relationships with both existing and potential customers who may be a valued addition to its portfolio.

The Company’s adaptation to both national and international Sustainable Development standards, its acknowledgment of key issues, as well as its active interaction with its stakeholders, help to assess their requirements and expectations according to its business strategy.

Seeking to ensure its responsible operation the Company has drawn up and implements a Code of Conduct, which outlines the Company’s expectations of its employees and associates (suppliers and customers/tenants).

Its aim is to highlight the Company’s values, to describe the principles of business ethics and conduct by which the Company operates and to act as a point of reference for the daily professional conduct of its employees and associates. The Code is available on the corporate website (http://www.premia.gr/). Monitoring compliance with the Code is the responsibility of the Company’s executive team, the Internal Audit Unit and the Compliance Unit.

The Company has also instituted a sustainable development policy, which is available on its corporate website for the employee’s and associate’s reference. Employees and close associates are also notified by e-mail or circular about any changes that may arise.

Company suppliers mainly derive from sectors of electricity, consumable office supplies, leasing of executive cars, management of its facilities/premises, consultant and legal services, as well as receiving provided services, i.e. recruiting competent managers.

Associates and suppliers of the Company in 2020 derived , among the supply of office equipment, the employee health programme, the provision of data-processing services, the recruitment of executives in the Company, financial and legal consultants, and D&O insurance coverage.

5. Responsibility

ADMINISTRATIVE PRACTICES

The Board of Directors is responsible for outlining the Company’s investment strategy, as well as issues of Sustainable Development.  It oversees and regularly re-examines the opportunities and risks pertaining to the Company’s Sustainable Development policy, as well as the relevant measures that have been taken for dealing with them.

The ESG team is comprised of Company executives and assists the Board of Directors in the planning and implementation of its Sustainable Development plan, with the additional involvement of the following departments:

• Risk Management Unit
• Internal Audit Unit
• Regulatory Compliance Unit
• Finance and Investment Services Management
• Property Investment Management
• Operations and Asset Management

6. Rules & Processes

ADMINISTRATIVE PRACTICES

Oriented towards quality and the creation of added value, the Company systematically structures its processes to meet the expectations of its shareholders, employees, associates and other stakeholders.

The Company is listed on the Athens Stock Exchange and therefore complies with the ATHEX Regulations Code and the legislation governing Sociétés Anonymes, as well as the relevant laws and decisions of the Hellenic Capital Market Commission (HCMC).  In addition, it is governed and operates according to its own Internal Regulation Code , which outlines the Company’s regulations, policies, and processes and establishes and implements principles of corporate governance to ensure:

• The overall best-interest of the company.
• Transparency in corporate matters.
• The protection of shareholder and stakeholder rights.
• The adequacy and effectiveness of the internal control and operations assessment system.
• Continual compliance with the legislation as currently in force, which regulates its organization and operations.

To ensure the smooth implementation of its strategies and business goals, as well as its sustainable development policy, the Company has also adopted and implemented the following internal policies and procedures:

1) Procedure for hiring senior executives and evaluating their performance

2) Procedure for ensuring the compliance of those liable with the provisions of Article 19 of the Regulations

3) Procedure for revealing the potential existence of relationships of dependency of independent non-executive members of the Board of Directors and persons with close connections to them.

4) Procedure for ensuring compliance with the obligations deriving from Articles 99 to 101 of Law 4548/2018, on transactions with associated parties

5) Prevention and contingency policy and procedure for handling cases of conflict of interest

6) Regulatory Compliance Policy

7) Regulatory Compliance Procedures

8) Company procedure for managing privileged information and the proper information of the public, according to the provisions of Regulation (EU) 596/2014

9) Policy for the periodic assessment of the Internal Control System

10) Procedure for the periodic assessment of the Internal Control System

11) Policy for the training of members of the Board of Directors and Senior Management

12) Sustainable Development Policy

13) Policy and procedure, with adequate and effective mechanisms, for communicating with shareholders, aimed at enabling them to exercise their rights and laying the ground for an active dialogue with them.  

The Internal Audit system comprises the whole set of internal control mechanisms and procedures, policies, rules and codes, including those pertaining to risk management, internal audit and regulatory compliance, which covers all activities on a continual basis and contributes to its safe and effective operation.

The Company has established an Audit Committee that is responsible for the effective operation of the Internal Control System and the risk management system, as well as for supervising and monitoring the regular audit and issues pertaining to the objectivity and independence of the Chartered Accountants.

The assessment of the adequacy and effectiveness of the Company’s Internal Control System is carried out on a continual basis by the Internal Audit Department and on an annual basis by the Board of Director’s Audit Committee, based on the relevant data and the information provided by the Internal Audit Department. The Internal Audit Department audits the Company’s entire performance in order to ensure its effective operation and reliability.

The Company is committed to adopting necessary technical and organizational measures to protect and safeguard personal data and confidential information. Compliant with the applicable law and regulations the Company treats all information as confidential and implements the relevant processes.  Every employee must abide by  these processes and not disclose confidential information to third parties or entities. To this end, the Company’s information technology systems are equipped with the following safeguards:

• A dedicated firewall for the Company
• All computers are protected by a centrally managed anti-virus program
• Daily backup of user/company data in a dedicated external storage unit

Finally, the Company is examining the possibility of receiving certification in the next three years for its procedures on matters relating to quality and the environment in line with international standards ISO 9001:2015 and potentially ISO 14001:2015.

PERFORMANCE INDICATORS

The Company operates with integrity, and is fully compliant with laws and regulations pertaining to its activities. It continuously monitors developments and responds accordingly as required.

Consequently, the Company’s employees are expected to act in conformity with its values and principles and to comply with applicable laws and regulations.

With a view to Sustainable Development, Premia operates in accordance with the following principles, which are communicated to all working in or for the Company:

Integrity: responsibility is embedded in the Company’s business conduct and applies to all its employees and associates. Every collaboration, transaction or interaction is conducted with integrity, fairness and respect.

Recognition: Continuous employee training and an efficient management team combining experience and know-how are core requirements for the Company’s success.

Prevention: The Company operates in accordance with the Principle of Prevention in all its activities, rigorously applying the Risk Management Code to ensure the timely identification and assessment of potential business risks and thus limit its exposure to them.

Environmental and Social Responsibility: Contributing to society and adopting best environmental practices in its activities are fundamental values for the Company. Amongst other, the Company aims to minimize its environmental impact and to promote environmentally beneficial investments.

Compliance: The Company adheres to and complies with all applicable laws and regulations, which in conjunction with its excellent Corporate Governance and the Audit Committee, constitute the basis of its operations.

The Company has devised and implements a Code of Conduct, which presents the set of principles and rules that govern its operation and outlines the behavior the Company expects from employees and associates (suppliers and customers). It presents Premia’s commitments and requirements regarding ethical business practices and describes the broader framework that the Company has defined to co-operate with its customers, its suppliers, its executives and its employees.

The Company also adheres to the Hellenic Corporate Governance Code developed by the Hellenic Corporate Governance Council (HCGC).

With regards to the security of personal data and the confidentiality of information, there have been no complaints regarding loss of information or personal data breaches during the applicable period.

7. Monitoring

ADMINISTRATIVE PRACTICES

The Company sets, monitors and as of this year publishes indicators pertaining to relevant ESG issues. More specifically, the Company records and measures indicators pertaining to:

• Its environmental performance (total energy consumption, electricity consumption, transport fuel consumption, water consumption, quantity of consumed and recycled office supplies).
• Its social performance on issues pertaining to equal opportunities and health and safety in the workplace (accident incidents, training hours, diversity among executives and among employees).
• Its performance in governance issues (legal compliance, corruption incidents, harmonization with the Company’s policies and values.)

All the above indicators are monitored on an annual basis and are redefined at the end of each year based on the annual performance of each indicator compared to the original set target, with the final approval deriving from the Board of Directors.

The Internal Audit Unit along with the Risk Management Unit are examining the adoption of a programme for the recording and reporting of information via automated reporting and/or through a software programme with regular information updates, so as to permit systematic monitoring and auditing.  

In addition, as of this year the Company has adopted and implements the Greek Sustainability Code, by meeting the requirements of the 20 criteria and the performance indicators of the Global Reporting Initiative (GRI standards) outlined, as well as those outlined by the Athens Stock Exchange ESG Reporting Guide.

8. Incentive and reward systems for Sustainable Development

ADMINISTRATIVE PRACTICES

The Company recognises that human resource management is a fundamental aspect of the Company’s overall operation, its sustainable development, and its integration with the relevant parameters over the entire spectrum of ESG. Proper, lawful and fair human resource management ensures the optimum efficiency of the Company’s executives and a fair reward for their contribution.

The Company’s Senior Management, namely its Board of Directors, are subject to the Suitability Policy, which is included in the Company’s Corporate Governance System and aims to attract and retain efficient individuals who will be sure to exercise proper and effective management to the overall benefit of the Company and its stakeholders and achieve its strategic goals. The Suitability Policy is harmonized with existing legislation and ensures that members of the Board of Directors have the professional qualifications, knowledge, skills, independent judgment, reputation, and expertise to exercise their duties in a healthy and consistent environment, on top of proper character, ethics, reputation, reliability and integrity that outlines them.

The Remuneration Policy for members of the Board of Directors, which has been approved by the Shareholders General Assembly, takes into account the relevant best practices for listed companies, the provisions of the Company’s Articles of Association and the Corporate Governance Code. It includes fixed, variable or other remuneration, which can be expressed in cash, shares, stock options or other benefits. A reasonable level of fixed remuneration is provided depending on the area of expertise and responsibilities of each person. Variable remuneration relates to individual performance and is paid for reaching specific objectives. It is directly related to the performance and development of the individuals concerned and to the Company’s financial results, internal value, portfolio value, as well as overall financial position. The Company may grant additional benefits at its discretion and reserves the right to modify and/or revoke them whenever necessary.

The Company has set up a unified Remuneration and Nomination Committee, which is responsible for locating and proposing to the Board of Directors suitable individuals for BoD membership and for formulating proposals to the Board of Directors regarding the Company’s Remuneration Policy. Among other things, the Committee’s duties include regular evaluation of the Board of Directors’ performance and the submission of proposals for its improvement.

At the same time, the Company seeks to attract competent executives and to create a mutual relationship based on trust. Therefore, beyond the legal requirements pertaining to remuneration, the Company has also established a unified payroll system based on its employees’ position and responsibilities, regardless of their gender, age or personal choices. It should be noted that the Company’s number of employees doubled in 2020 and within the framework of additional benefits provided by the Company all employees are entitled to private insurance coverage. The Company is examining ways to ensure that employees at all levels participate directly and actively in Sustainable Development issues, so that it will very soon be able to achieve its objectives to the fullest possible degree.

PERFORMANCE INDICATORS

The indicators that the Company monitor and relate to the remuneration are described below.

9. Stakeholder Engagement

ADMINISTRATIVE PRACTICES

The Company is committed to open communication with all relevant parties in order to record their requirements and expectations and to make every effort to respond accordingly. As a result, the Company will be in a position to continually improve its performance and services, as well as its performance in ESG metrics.

The Company identifies basic stakeholders as individuals and/or legal entities which affect and are directly affected by its operations, and which contribute to its future growth. These include: its shareholders, employees, customers/tenants, associates/suppliers, the Athens Stock Exchange, the Hellenic Capital Market Commission, and the local communities in which it operates.

PERFORMANCE INDICATORS

The table below presents the main stakeholders, the means of communication with them, and the results that emerged.

10. Product Responsibility and Innovation

ADMINISTRATIVE PRACTICES

Sustainable investments are directly linked to the real estate industry’s responsibility to achieve environmental objectives in relation to climate change. As most land plots are situated within the urban zones the real estate industry has substantial prospects for growth. Guided by the objectives to sustain real estate assets and reducing greenhouse gas emissions, the Company’s main objective is to act in a manner that will lead to a well-balanced sustainable growth.

Through its operations the Company also contributes to quality property development, as it seeks to invest in properties with prone energy and environmental characteristics that will satisfy tenant requirements to the greatest possible extent. The Company, therefore, promotes the Global Sustainable Development Goals (SDGs) as it contributes to the improvement of the quality of city life as well as the quality of those who live and work in the buildings that it owns.

Over the next 4-8 years the Company aims to add to its portfolio properties with high environmental performance and low environmental impact. Until then, it has no income from sustainable products. It is also examining the prospect of co-operating with external organizations and applying for LEED, WELL, etc. certification on its properties where  applicable.

Finally, its goal in the immediate future is for every new investment to have an “ESG report”, and an “ESG CapEx and investment return analysis”.

11. Usage of Natural Resources

ADMINISTRATIVE PRACTICES

Premia acknowledges that each stage of its operational development affects and is affected by the natural environment, given (the land-use change) the use and consumption of natural resources.

The asset management industry “exploits” the land plots where its assets are located and therefore any environmental degradation automatically leads to the degradation of the corresponding “product”, since the asset cannot be moved. As a result, environmental risks may have a major impact on real estate assets, which may affect everything from their fair value to their sustainable development. Conversely, the assets themselves also affect the natural environment, with their water resources and energy consumption, greenhouse gas emissions, and consumption of natural resources (e.g. paper and transport fuel for the transportation of persons and merchandise).

Although the Company owns premises and manages properties, it has no production activity. It is, nonetheless, examining the prospect of setting up and implementing a certified Environmental Management system to record its environmental performance directly and effectively. It already measures and traces its environmental footprint and the impact of its operations on the environment by recording its energy consumption, water consumption and use of printing paper on an annual basis, while it also records the use of transport fuel for its executive cars, all of which are hybrids in order to minimize emissions of air pollutants.

Finally, being a small entity (according to the Greek legislation) its water consumption levels are already low, but further measures are being taken to reduce consumption through internal notification to employees concerning proper water usage.

PERFORMANCE INDICATORS

The environmental indicators monitored by the Company are presented in the table below.

* The water consumption of the properties the Company owns is not available, as it is a resource that is managed internally by each tenant and it is not forwarded to the Company.

12. Resource Management

ADMINISTRATIVE PRACTICES

The Company is committed to operate in an environmentally friendly manner and to continually reduce its environmental footprint, as the respect for the natural environment is of high priorities. As buildings in Europe account for 40% of total CO₂ emissions, the Company seeks to invest in properties that are more environmentally friendly and are now a structural element of smart cities. The Company also commits its employees and immediate associates to actively contribute to these efforts in their individual areas of competence, implementing and reinforcing processes  related to the protection of the environment.

In its strategy the Company incorporate sustainability issues and sets the following environmental goals for the next decade:

• Reducing its energy consumption and emissions of air pollutants, by increasing the use of electricity derived from renewable energy sources; by increasing the use of natural gas; by reducing executive travel and transport to and from Company headquarters; combined with the simultaneous increase in hours of working from home (an additional outcome of the COVID-19 pandemic), and by acquiring and managing low energy properties through the use of electricity from renewable energy sources.
• Responsible Consumption and Management of Natural Resources, by using recycled printing paper, duplex printing, and primarily by reducing the amount of paper consumed per employees to the greatest possible extent.
• Water Management, by recording the water consumption in leased properties and by undertaking the upgrading of water supply points.

PERFORMANCE INDICATORS

The Company is unable to present comparative results related to its performance indicators, because in 2019 it was not recording its environmental performance. These will be available for the year 2021.

Nevertheless, the Company recycled 100% of its printing paper, approximately 300 kg. Premia is also examining the possibility of assigning the official recording of paper recycling to an external associate and receiving relevant certification.

13. Climate-relevant emissions

ADMINISTRATIVE PRACTICES

The Company is aware that climate change will affect the way that both private individuals and companies choose to house their activities, particularly with regard to location. Climate change will require an increase in energy consumption while an environmentally degraded area will sustain property values to their current value. The risk is that some of the Company’s assets will not be able to meet new standards, which might lead to a possible decrease in demand and eventually their decrease in value. But this also presents the Company with an opportunity to change its business model, by acquiring certified bioclimatic buildings in both urban areas and industrial zones, a step which is among the Company’s immediate priorities.

In response to the issue of climate change, as of 2020 the Company has taken steps to reduce its energy consumption and gas emissions by ensuring that 16% of its power consumption comes from renewable energy sources, a percentage which it aims to increase in 2021 to 40%. With regard to the properties it owns, the Company is negotiating with its tenants and an electricity provider a special agreement for the provision of electricity through renewable energy sources, while in the future, new property acquisitions will be based on low energy requirements.

PERFORMANCE INDICATORS

The Company’s contribution to issues related to climate change is measured by the following indicators:

14. Employment Rights

ADMINISTRATIVE PRACTICES

Working conditions which are in breach of national and international laws and practices for the protection of human rights, particularly the UN’s Universal Declaration of Human Rights, are unacceptable to the Company. The Company is against any form of child or forced labour, and unprofessional conduct, such as sexual harassment or bullying. It also ensures that conditions throughout its operations are not conductive to human and labour rights violations.

The Company complies with Law 4808/2021 on Worker Protection. Labour relations are excellent, being grounded on respect for human rights and liberties in the workplace, on the development of a spirit of mutual understanding and cooperation, and on the adoption of human resource management policies that impartially regulate all issues pertaining to hiring, transportation, promotion, training, remuneration, additional benefits, leaves and absences. One of the Company’s immediate objectives is to draw up internal procedures detailing the courses of action relating to the hiring, termination and training of personnel.

The Company fully complies with all applicable labour laws including hygiene and safety regulations.

The Company provides continual training for its employees based on professional demands and operational and/or individual requirements.

The Company’s Code of Conduct describes the rules and principles that govern its operations and applies to all its employees.  

PERFORMANCE INDICATORS

The diversity indicators for Senior Management and for the Company in its entirety for 2020 are presented in the table below.

At present, the Company is also fully harmonised with the legislative framework regarding adequate gender representation, and in particular with the Suitability Policy of Article 3 of Law 4706/2020.  Specifically, women account for 25% of the Board of Directors, while the Company aims to maintain and increase the above percentage in the future.

15. Equal Opportunities

ADMINISTRATIVE PRACTICES

People are the foundation of the Company’s success and their well-being is a top priority. The Company is committed to provide equal employment opportunities regardless of age, gender, race, religion, nationality, or other personal characteristics, and finds any form of discrimination or harassment unacceptable, in accordance with the current legislation. The Company condemns and does not tolerate any form of discrimination or harassment in the workplace and in the context of its operations.

The Company fosters relations based on respect and trust with its employees, while ensuring their on-going growth and development. The Company provides training and development opportunities for its employees and evaluates their performance and skills. It also ensures that employees work in a hygienic and safe environment.

The continual development and professional satisfaction of its people is the Company’s ultimate goal.

Remuneration Policy

The Company has formulated and publishes its remuneration policy pursuant to the requirements of the European law and the new law on Corporate Governance, as well as the Company’s Articles of Association and Internal Regulation Code. Premia’s executives receive fixed salaries depending on their position in the Company’s hierarchy and their years of service, as well as additional benefits such as life insurance, performance bonuses and salary increases, on a case-by-case basis.

The factors that determine remuneration are:

(a) the Company’s overall financial position,

(b) the Company’s wage practices,

(c) the market practices of other listed companies in the industry,

(d) transparency and the principles of meritocracy, justice and proportionality, depending on the individuals’ responsibilities and performance.

Employee Health and Safety

One of the Company’s major concerns is the health and safety of its people. All employees must perform their professional duties with respect to the health and safety rules applicable to their workplace and participate in relevant awareness programmes.

Along the same lines, the Company intends to adopt employee health and safety rules and to organize regular relevant seminars-workshops on first aid, proper use of office equipment, response to natural and/or man-made disasters (floods, fires, earthquakes) etc. These will take place at its offices and will be mandatory for all employees.

Due to the COVID-19 pandemic, the Company offers its employees the option of working from home. Those working in the Company’s offices must comply with all the safety measures that have been imposed to ensure that the virus does not spread.

In addition, recognising issues of workplace efficiency and ideality, the Company decided to transfer its operations to a specially designed building, with ideal natural lighting, ventilation, and internal layout.

Staff Training

Learning contributes to both the development and the satisfaction of its people and  encourages its employees to participate in training seminars organized by third parties concerning their  further professional development/ training in its area of activity.

PERFORMANCE INDICATORS

The effectiveness of these actions and initiatives is reflected in our zero workplace accidents record and the zero incidents of complaint or suspicion of discrimination or improper conduct between employees and Management.

The Company’s performance in 2020 is below.

16. Qualifications

ADMINISTRATIVE PRACTICES

The Company considers its employees a key  pillar and factor in order to achieve its business goals.

It is committed to fostering relations with its employees based on respect and trust while ensuring an environment of equal opportunities and combating discrimination in any form.

The Company systematically supports the continuous growth and development of its employees, providing them with learning and training opportunities.

The Company cares for the health and safety of its employees and associates and complies with all the health and safety regulations applicable in the workplace.

The Company systematically seeks to promote employment and doubled its head count in 2020.

Premia has doubled its workforce with no departures.

17. Human Rights in the supply chain

ADMINISTRATIVE PRACTICES

The Company has introduced self-regulating provisions to its implementation of the Corporate Governance Code. In other words, it does not limit itself to the implementation of those provisions which are mandatory by law but depends on the voluntary acceptance and implementation of regulations which the Code describes as special practices. These provisions, among other things, are the basis on which the Company forms its relations with its suppliers as well as the basis for their further assessment according to ESG criteria.

With focus on responsible suppliers, the Company has selected an electricity provider that implements the quality management certifications systems ISO 9001:2015, Environmental Management System ISO 14001:2015 and ISO 45001:2018. It selects and assesses its supplier of office material based on its social and environmental performance as portrayed in its published Sustainability Indices. Executive company cars are low-emission hybrid models. And the management of the Company’s premises is handled by an associate-supplier that complies with current labour legislation on employee rights and protection.

The Company has drawn up and implements a Code of Conduct that applies to all its employees, associates, suppliers and tenants. Among other provisions it commits the Company to practices proper human rights, according to national and international law and the UN’s Universal Declaration of Human Rights.

In addition to the above, the Company plans to carry out an evaluation of suppliers based on a questionnaire containing basic ESG criteria, as an additional requirement for collaboration. Indicatively, it will include a requirement for certified Management Standards ISO 9001:2015 for Quality, ISO 45001:2018 for Health and Safety, as well as a written commitment by suppliers to comply with the above. Suppliers will be evaluated on an annual and biannual basis.

The responsibility for inspecting the relevant agreements will be assigned to a committee on which the Internal Audit Unit and/or the Regulatory Compliance Unit will have presence.

18. Corporate Citizenship

ADMINISTRATIVE PRACTICES

By investing in properties with specific energy and environmental characteristics, the Company contributes through its operations to the quality redevelopment of urban buildings. Therefore it contributes to the improvement of the quality of city life for those who live and work in the buildings it manages, while at the same time it promotes the Global Sustainable Development Goals (SDGs).

At the same time the Company seeks to support the local community where its properties and premises are located, through volunteer actions and collective efforts by its employees.

In the first half of 2020, while the Company was in the process of a Share Capital Increase, the outbreak of the COVID-19 pandemic put an end to all social actions. With the arrival of a new major shareholder the Company’s social framework was completely redesigned in the second half of that year and entered its implementation phase in the beginning of 2021.

PERFORMANCE INDICATORS

The direct financial value (in Euros) created and distributed in 2020 is shown in the following table:

19. Initiatives and Political Influence

ADMINISTRATIVE PRACTICES

As a listed company on the Athens Stock Exchange, Premia operates according to the Code of Conduct of listed companies, the ATHEX Regulations and its Internal Operating Rules and is fully harmonized with their content.

It is an active member of ATHEX and of the Union of Listed Companies, while its choice of instruments is coherent with serving the Company’s statutory objects and promoting its longevity.

PERFORMANCE INDICATORS

The Company does not finance political parties or persons and therefore it has no contribution in this category.

20. Corruption prevention and alleviation

ADMINISTRATIVE PRACTICES

The Company publishes its Code of Conduct, which presents the set of principles and rules that governs its operation and outlines the behavior it expects from employees, associates and customers/tenants. It describes the principles of business ethics and conduct by which the Company operates by and acts as a point of reference for the daily professional conduct for everyone involved.

The company is governed and operates on the basis of specific ethical and business conduct standards, which must be observed alike by its management and by all its employees and associates. These standards address all the following key issues of regulatory compliance:

Compliance with laws and regulations

The Company operates with integrity and respect for the laws and regulations and fully complies with Law 4548/2018, Law 4706/2020 and Regulation (EU) 596/2014 pertaining to its activities.

It continuously monitors developments and responds accordingly as required.

Bribery and corruption

The Company opposes and condemns any form of bribery and any corrupt or illegal business practice or activity. The Company prohibits the acceptance or offer or promise of gifts, facilities or monetary exchanges or any other benefit to individuals or legal entities, and also to public officials and civil servants with a view to achieving unfair competitive advantage. The Company’s management and all its employees are subject to this Code of Conduct, as well as all associates that have agreed to adhere to it and are committed to acting with absolute integrity and honesty within  and outside the Company, conforming to national and international anti-corruption legislation. In addition to the above, the Company absolutely prohibits any kind of activity pertaining to illegal financing or money laundering and strictly observes all relevant laws and regulations.

Fraud prevention

The Company does not tolerate any incident of fraud and is committed to the principles of transparency and integrity. The Company’s management is responsible for preventing, monitoring and taking appropriate action in the event of fraud, constantly monitoring the safety procedures and controls regarding the assessment, prevention and handling of fraud-related matters, while individuals and departments are obliged to follow them rigorously.

Conflict of interest

Management team and employees must engage to avoid situations that could lead to a conflict of interest between their personal and corporate interests and act in line with the provisions of the policy and procedure for preventing and dealing with such situations.

PERFORMANCE INDICATORS

SRS-205-3: 
Confirmed incidents of corruption and corrective actions.

At present there have been zero incidents of corruption or non-compliance with the relevant legislation. Maintaining this record is one of the Company’s standing goals for the future.

SS-G1: Violations of business ethics

There have been no monetary damages resulting from violation of business ethics.