ΟΠΑΠ Α.Ε.

1. Στρατηγική, Ανάλυση & Δράση

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Our business model is the blueprint of what we do. It sets the foundation for our actions, our decisions and our operations. It also outlines how we create value for our stakeholders, achieve our business goals, foster employee engagement, maintain strong working relationships with our retail network and fulfil our corporate responsibility mandate.

Our vision to provide World Class Gaming Entertainment to our customers in retail and online continues to strengthen and ensure the company’s growth, the expansion of its operations and profit generation.

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

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

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

In 2021, Gross Gaming Revenues (GGR) from regulated operators in Greece approximately amounted to an estimated € 1.86 billion and the Greek gaming sector accounted for 1.05% of the country’s Gross Domestic Product (GDP).

According to H2 Gambling Capital (the leading source of data on the global gambling industry), Greece ranks 2nd among the 27 EU countries, in GGR as a % of GDP. In the same category, Cyprus ranks 3rd and well above average among the 27 EU countries. Based on the 2021 data for Greece, OPAP held a 58.2% GGR market share, which decreased compared to previous years due to the unique impact of the COVID-19 pandemic. OPAP’s performance in 2021 was driven by solid online dynamics along with gradual retail recovery as stores reopened.

Our world is constantly evolving as technology and digitalization have opened new opportunities and customers seek grand experiences, with their expectations evolving faster than ever. By building strong relationships and taking into consideration the needs of all our key stakeholders, we aim to successfully create value in a sustainable way.

With our customer-centric mindset we remain committed to our vision of delivering best-in-class entertainment in a safe and responsible way, generating sustainable value for all stakeholders and giving back to society. Our Fast Forward Strategy pushes us forward into 2022 and sets a clear direction for OPAP’s long-term success focusing on the following six areas of our strategy: Customer, Brand, Online, Retail, Technology, People.

Along with the six key focus areas of our strategy, we continue to strengthen and leverage our number one position in corporate responsibility, which is an integral part of our DNA and positions OPAP as a CSR leader in Greece. Our commitment to sustainable growth and ESG principles is recognized by the investment community and leading institutions.

Specifically, with respect to environmental, social and Governance principles we identify the
following guidelines in alignment with our business:

Environment – mitigating our impact:

Conscious of environmental issues, we all in OPAP work systematically towards minimizing our
potential negative footprint

Social – supporting our employees and the community:

OPAP creates a working environment that aligns People’s needs with company’s ambitions.
Our Corporate Responsibility strategy aims to cater significant social needs and create a better
future for youth. The key pillars of our CSR strategy are health, employment, sports, sensitive
social groups and social aid.

Governance:

Robust, transparent and fair Corporate Governance framework – fair, reliable and safe gaming
experience to all our customers, through our Responsible Gaming Strategy.

Acknowledgement of our sustainability performance

We communicate our corporate sustainability strategy and performance and respond to investors and ESG analysts’ requests for information.

OPAP has been included, for the fifth consecutive year, in the Financial Times Stock Exchange 4Good (FTSE4Good) Emerging Index, which assesses listed companies in emerging markets with positive financial, environmental and social performance, based on a range of corporate social responsibility criteria.

Its inclusion in the FTSE4Good index demonstrates OPAP’s commitment to building a comprehensive sustainability strategy by embedding sustainable ESG practices into its business management.
OPAP has also been upgraded to AA rating from A in 2019 and from the B and C ratings prior to 2018 by the MSCI ACWI Index, MSCI’s flagship global equity index. The index is designed to assess the performance of large- and mid-cap stocks across 23 developed and 27 emerging markets. OPAP’s AA rating classifies the company as a leader its industry with respect to managing the most
significant ESG risks and opportunities.

OPAP has been included the Athens Stock Exchange’s ESG Index, since its launch in 2021. The Index monitors the stock market performance of listed companies that adopt and promote ESG practices in accordance with the ATHEX ESG Reporting Guide.

Our Corporate Sustainability Strategy

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

Internal Operation

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

Financial Results

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

Player Protection

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

Network Enhancement

Recognizing that we operate in a highly challenging economic environment, we dedicate our efforts to the development of our sales network and the creation of more job openings. Our aim is to make our customers a top priority and provide our partners the necessary resources to improve our network operations at every level, in order to help them unlock the full potential of their stores.

People Development

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

Society Support

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

Risk strategy and framework

As part of the ongoing risk management and control process, the senior management has established the Group’s risk management framework, which describes the fundamental principles and the methodology for the assessment and management of risks in OPAP, while determining the acceptable level of risk in the Company. Furthermore, the Audit Committee and relevant stakeholders are informed of the significant risks, which might affect the achievement of OPAP’s corporate objectives.

Responsible Gaming

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

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

• In 2021, we refreshed the Responsible Gaming Strategy for OPAP, ensuring that it is fully aligned with the European and International Responsible Gaming Standards, as well as with the Greek legal and regulatory framework.
• Hellenic Lotteries has a Responsible Gaming Policy in place. This strategy defines all the necessary measures that companies are advised to take in order to minimize the potential negative impact from participation in games of chance.

The policies address three main target groups:

• Employees
• Agents and PLAY stores venue managers/points of sale and their employees
• Players

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

Certifications
These leading distinctions are both effective until 2024 and tangibly reflect OPAP’s commitment to Responsible Gaming principles, acknowledging our comprehensive strategy in this area, which focuses on creating a safe environment for our customers, protecting minors, implementing best practices, and educating the wider public, among other things.

“Level 4” Certification of the World Lottery Association (WLA)

• European Lotteries Certification of Alignment with Responsible Gaming Standard

TCFD
In accordance with the recommendations of the Task Force on Climate-related Disclosures (TCFD), OPAP has begun the gradual implementation of comprehensive measures and procedures for addressing climate change impacts. The Health, Safety, Environment and Energy Management Committee review covers amongst other issues like business context, risks and opportunities, environmental programs and targets, findings from external and internal assessments, as well as environmental and energy legal compliance.

See more: OPAP’s integrated report 2021, p. 3, 16-17, 53, 55, 62-63, 73, 92, 112

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf 

Συννημένα Αρχεία: Λήψη principles

2. Ουσιαστικότητα

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

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

As the largest gaming company in Greece, we acknowledge the sheer size of our business operations and the subsequent impacts it can incur on the economy, the environment and society. Therefore, we identify the issues that are most material to our sustainable development and our stakeholders. In early 2021, we identified and prioritized these issues through a 4-phase methodology, as follows:

 
Phase 1: Sustainability Context

Potential material issues were identified by evaluating OPAP’s operation and strategy, the guidelines of international and domestic sustainability frameworks, future trends and current global industrial practices.

Through this process, we identified the following 19 material issues:

1.Societal Support
2. Responsible Gaming
3. Network Support
4. Customer Satisfaction
5. Human Rights and Diversity
6. Employee Engagement and Development
7. Employee Health, Safety and Wellbeing
8. Technology Innovation
9. Cyber and Data Security
10. Draw Credibility
11. Responsible Procurement
12. Energy Management & Carbon Emissions
13. Waste and Water Management
14. Corporate Governance
15. Business Ethics and Compliance
16. Risk Management and Business Continuity
17. Anti-Money Laundering
18. Illegal Gambling
19. Financial Performance

Phase 2: Materiality Analysis by OPAP Management

OPAP’s Senior Management prioritized the issues by taking into consideration their impact on OPAP’s operations, as well as the impact that OPAP’s actions in these issues have in the overall economy, society and environment.

Phase 3: Stakeholder Engagement

To assess stakeholders’ expectations and interests, we created an online questionnaire and invited all stakeholder groups to participate.

Phase 4: Prioritization

By analyzing the outcomes of each phase, we identified the issues that are prioritized as most significant for both OPAP’s Senior Management and our stakeholders.

OPAP’s main uncertainties and principal risks are set out on pages 15 to 21 of the 2021
Annual Financial Report.

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

Response to COVID-19 Pandemic

During 2021, the COVID-19 pandemic brought several challenges, which OPAP had to manage both proactively and reactively, to deal with the consequences of the pandemic. Leveraging the learnings deriving from COVID-related developments in 2020, OPAP implemented a specific business continuity plan, with the aim to minimize the impact of extraordinary developments, such as the suspension of its commercial network’s operations or the imposition of strict restrictive measures upon reopening. OPAP in 2021 promoted initiatives for the financial, commercial, and operational support of its partners’ network across Greece. The measures were discussed with the institutional bodies representing OPAP’s partners and were designed based on a targeted and tailor-made approach, considering their proposals.

See more: OPAP’s integrated report 2021, p. 2, 75, 77

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

3. Στοχοθέτηση

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Delivering value for our stakeholders, over time, is the key objective of our business model.

Key Targets for 2022

The targets are aligned with the material issues that were aroused by the business and social environment that we operate.

Facilitating a sustainable business

• Increase online penetration and revenue stream from online channel.
• Increase retail revenues, following the normalization of conditions post COVID-19.
• Retain focus on cost optimization considering developments on the macro front.
• Enhancing shareholders remuneration continuously delivering generous rewards.

Establishing a safe gaming experience

• Launch new Responsible Gaming campaign in May 2022.
• Provide consultation and support to the Network via planned visits of the Responsible Gaming team.
• Launch online Responsible Gaming Week 2022 (awareness campaign, trainings, etc)

Achieving common goals

• Increase turnover generated digitally by up to 10% through Opapbet terminals and OPAP store app.
• Use in-store promotions as a vehicle to enhance entertainment and socializing, while supporting product awareness and performance through the implementation of up to 4,000 promotions per month.
• Increase digital interaction with partners and enhance partners’ engagement.

A great place to work

• Enhance our digital training footprint and enrich our online courses utilizing new innovative learning techniques for reskilling and upskilling our people.
• Move forward with the establishment of a solid and inspiring leadership team by developing their skills and transforming their mindset in line with our new leadership model.
• Acquire, develop and retain talent, including Gen Z, providing a unique working experience
• Increase the recruitment of women professionals by 5% within the next 3 years

Striving for a better future

• Complete the Children Hospitals renovation project.
• Recruit 10 new SMEs in the “OPAP Forward” program.
• Continue to support local communities through the “OPAP in the Neighborhood” program

See more: OPAP’s integrated report 2021, p. 190-195

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Internal Control

We have established a System of Internal Controls, which is based on best international practices and is designed to assure:

• Efficiency and effectiveness of the company’s operations
• Reliability and completeness of financial, non-financial and management reporting
• Compliance with the applicable legal and regulatory framework

We apply extensive internal controls and risk management systems. Internal controls are built in the design of processes by various teams of the company. Internal audits are planned based on identified risks and the results of the internal audits are fed back to the risk management process.

See also: OPAP’s integrated report 2021, p. 73, 95, 128, 148, 165

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

4. Διαχείριση της Αλυσίδας Αξίας (value chain)

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Our games portfolio is divided into fixed odds betting games and mutual betting games. To deliver our products and services, we utilize a series of resources from our suppliers (materials, equipment, services, and know-how), which reinforce our own operations.

All our products and services are available throughout our sales network, which includes OPAP agencies, street vendors and other various retailers, as well as the horseracing venue in Markopoulo. Players can also place their bets through our online platforms.

Our Business Model

Our business model is the blueprint of what we do. It sets the foundation for our actions, our decisions and our operations. It also outlines how we create value for our stakeholders, achieve our business goals, foster employee engagement, maintain strong working relationships with our retail network and fulfil our corporate responsibility mandate.

How we create value

Delivering value for our stakeholders, over time, is the key objective of our business model. In the following chart, we outline how each form of input is utilized and subsequently transformed through
our business activities into output.

Supply Chain

Supplier diversity and equality are integral components in our effort to build a sustainable
supply chain. Our approach to supplier partnerships is founded on transparency, trust and
equal opportunities for all. Therefore, we capitalize on our outreach and size to support local
economies across the country, by collaborating with local suppliers for locally produced products
and services.

More specifically, in 2021 we:

• Collaborated with 2,781 suppliers in Greece and abroad, of which approximately 92% were
  local suppliers (2,565 local suppliers).
• Spent 52% of our total procurement budget on purchases from local suppliers.

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

Suppliers are expected to operate according to the respective legal provisions. Therefore, all our
formal tenders and agreements for “Significant Suppliers” with an annual budget above € 50,000,
include a clause that specifically states the requirement to comply with labor, environmental
and occupational health and safety laws and regulations.

Customers

In 2021, we expanded our customer approach beyond measuring customer satisfaction. Better customer understanding has been established as a new key pillar in OPAP’s strategy, highlighting the importance of adopting a customer-centric mindset across the organization throughout everything we do. To this end, we implement a series of initiatives which are based on customer needs and insights with the aim of improving our customers’ overall level of satisfaction both with OPAP as a company, as well as with our products and services.

Our Customer Circle framework describes our approach to systematically manage and engage with
our customers through four comprehensive and efficiently managed focus areas:

• Collecting data
• Understanding our customers
• Reflecting on our actions
• Measuring the impact of our actions

Survey results

• 91% (improved from 81% in 2020) of our customers claim that their experience with OPAP was either as expected or better, exceeding their expectations.
• 74% (improved from 52% in 2020) of those surveyed agree/strongly agree with the statement that OPAP guarantees the right to operation of games.

See also: OPAP’s integrated report 2021, p. 52-53, 64-65, 80-85

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Λήψη Business model Λήψη Suppliers Λήψη Value

5. Υπευθυνότητα

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

OPAP adopts a holistic approach to corporate responsibility, where the accountability for responsible operation lies within each department and each employee.

To assure the holistic and responsible management of our operational issues, we have established the appropriate organizational structures as follows.

At Board level, our corporate responsibility agenda is driven by the Chief Executive Officer. The Board oversees OPAP’s performance and strategy in various areas of our sustainability strategy, such as internal operation, people development and network enhancement issues that could have an effect on the overall reputation and financial performance of the company. The Board approves any larger social programs and initiatives and stays informed about OPAP’s corporate responsibility performance.

At organizational level, the Deputy CEO is responsible for identifying the strategic risks, setting standards and targets and reviewing the company’s Corporate Responsibility performance. At operational level, the Corporate Communications & Corporate Responsibility Director, is responsible for cooperating with other departments in order to appropriately allocate responsibilities and disseminate policies and practices. The Corporate Communications & Corporate Responsibility Director has established a close collaboration with the Quality Systems Management Team.

Συννημένα Αρχεία: Λήψη Corporate Responsibility Management

6. Κανόνες & Διαδικασίες

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

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

Compliance
We closely monitor the regulatory and legal framework related to our activities in order to apply all relevant provisions. It must be noted that in 2021, there were no penalties imposed regarding compliance issues by competent regulatory authorities, such as the Hellenic Gaming Commission.

Adhering and Following Fair Competition Rules

According to the legal framework and Law 4002/2011 there is no “numerus clausus” for licenses. As long as all statutory conditions are met, every company can acquire a license for providing online gaming services to customers, ensuring that the online gaming market stays open for responsible competition.
We recognize our responsibility to follow fair competition practices and refrain from engaging in any activities non-compliant with competition law. Indicatively, within this context we:

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

Integrated Management System

At OPAP SA, we implement an Integrated Management System (IMS) in accordance with international standards. Each management system takes into consideration the structure and requirements of the other systems. Within the context of our IMS, we maintain the following ISO certifications:

• ISO 9001 Quality Management System

Certified by Lloyd’s Register Quality Assurance, since 2004

• ISO 14001 Environmental Management System

Certified by Bureau Veritas, since 2004

• ISO 50001 Energy Management System

Certified by Bureau Veritas, since 2018

• ISO 45001 Occupational Health and Safety System

Certified by Bureau Veritas, since 2020

• ISO 19600 Compliance Management System

Certified by Lloyd’s Register Quality Assurance since 2021

It must be noted that within 2021, we:

• Successfully implemented and certified our ISO19600 Compliance Management System (audited in October 2021).
• Trained 184 new employees on our Management Systems through the Corporate Induction program.

Management Systems Committees

The Management Systems Committees, namely the Quality Management Committee and the Environment, Energy and Health and Safety Committee, are responsible for the following:

• Reviewing the implementation of Management Systems (internal assessments, systems KPI’s, documentation and awareness issues, etc.).
• Reviewing the external audits management and results (preparation and findings management).
• Reviewing the status of Company ISO certifications (adequacy & relevance to business context and strategic priorities).
• Discussing relevant projects or initiatives relevant to the continuous suitability and improvement of certified Management Systems.

Anti-Money Laundering

We comply with the standing legal framework and the Hellenic Gaming Commission’s Decision no. 554/5/15.04.2021, as currently in force, which introduces measures to prevent money laundering and terrorist financing in the gaming sector.

In order to achieve compliance and thus prevent, detect and deter money laundering and terrorist financing, we have put in place a comprehensive Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) compliance program which consists of the following basic pillars:

• A system of internal policies, procedures and controls.
• A designated compliance function with a compliance officer.
• An ongoing employee/agent training program.
• An independent audit function to test the overall effectiveness of the AML program.
  
  

Policy and Procedures

An internal “Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) Policy” is in place for OPAP SA, Hellenic Lotteries SA and Horse Races SA, which applies to all employees, agents of the land-based sales network and their staff. The Policy is established and approved by the Board of Directors, thus setting the “tone from the top” within the organization. It incorporates a high-level set of principles and serves as the basis for procedures and controls, which provide details as to how all lines of business can achieve compliance with laws and regulations and with the organization’s respective standards and goals.

Anti-Fraudulent Activity

The Antifraud Team has been operational within the Group since 2014. Its scope of responsibilities includes the detection and prevention of fraudulent activities that could negatively affect the business goals of OPAP and its subsidiaries.

Addressing Illegal Gaming

OPAP, in order to protect its business, its customer base and respective revenues, monitors closely the gaming market, focusing in particular on illegal gaming activities, both online and offline. Furthermore, in the context of its Responsible Gaming Strategy, OPAP seeks to make gaming safer for all players so that everyone can enjoy the fun of playing. To that end, OPAP reports any findings to the competent authorities.

Response to COVID-19 Pandemic

During 2021, the COVID-19 pandemic brought several challenges, which OPAP had to manage both proactively and reactively, to deal with the consequences of the pandemic.

In 2021, OPAP’s commercial network was forced to cease operations for an almost double number of days compared to 2020. Additionally, varying restrictive measures and healthcare rules were in force throughout the year and across different parts of the country, even OPAP’s retail network was operating. Besides, OPAP’s operations also had to adapt to a series of measures, including rules for the use and control of COVID-19 vaccination/ recovery certifications, remote working policies etc.

Throughout 2021, OPAP closely monitored and adopted all necessary COVID-19 measures, remaining committed to protecting the health and safety of its customers, employees, and partners, as well as to safeguarding the continuity of its business activities in Greece and Cyprus. At the same time, OPAP undertook various initiatives to safeguard its financial position and ensure a quick ramp-up of its business upon the loosening or lifting of COVID-19 restrictions.

Leveraging the learnings deriving from COVID-related developments in 2020, OPAP implemented a specific business continuity plan, with the aim to minimize the impact of extraordinary developments, such as the suspension of its commercial network’s operations or the imposition of strict restrictive measures upon reopening.

Following up on the support measures implemented in 2020, OPAP once more promoted initiatives for the financial, commercial, and operational support of its partners’ network across Greece. The measures were discussed with the institutional bodies representing OPAP’s partners and were designed based on a targeted and tailor-made approach, considering their proposals

Ensuring Information Security

We implement several security controls in order to prevent security breaches, such as unauthorized data retrieval, storage and accidental or intentional destruction of information. Our purpose is to ensure confidentiality, integrity and availability of information, games’ operation and customer service provision.
Due to the criticality of our operations, we apply a wide set of controls and practices to ensure information security. Within 2021, all security operations were performed successfully against our performance indicators regarding service downtimes, security testing, security incident service level agreements and security awareness. Our Information Security Management System has been certified in accordance with ISO 27001: 2013 Standard and WLA Security Control Standard: 2016 (WLA-SCS:2016), making OPAP the only Greek company that holds this certification. The certifications cover the design, development, operation, management and security requirements for lotteries, fixed odds, mutual betting, numerical lotteries, sport betting and VLT operations.

Protecting Personal Data

The issue of personal data privacy is particularly important for delivering our products and services to our users. For this reason, in 2021, we performed several actions, such as:

• Implemented an annual compliance program to achieve effective monitoring of compliance with the applicable legal framework for data protection and internal policies (such as the Data Protection and Privacy by Design Policies) in line with the Information Security Management System adopted and monitored by the Information Security Office.
• Provided support on pending items, in the context of our continuous compliance monitoring, to ensure timely implementation of required actions and changes.
• Implemented appropriate technical and organizational measures to comply with the Legal Framework for Data Protection.
• Conducted training of staff and key management personnel, focusing on call center personnel, due to their increasing interaction with customers.
• Applied all necessary measures to protect players’ personal data in the context of high winnings payment and issuance of winning certificates.
• Handled, in a timely and efficient manner, a high number of data subject requests due to the increased number of online players and users of OPAP mobile applications.
• Conducted risk assessments and audits, on a regular basis, in order to identify and prioritize data security vulnerabilities and define appropriate risk treatment plans. OPAP did not incur any data breaches in 2021.
• Identified high risk areas and performed data protection impact assessments and impact analysis for international transfers, focusing on OPAP’s mobile applications.
• Executed data processing agreements with all suppliers who act as data processors and several controller-to-controller agreements in cases where disclosure of personal data to/from
  business partners is required.

System of Internal Controls

We have established a System of Internal Controls, which is based on best international practices and is designed to assure:

• Efficiency and effectiveness of the company’s operations
• Reliability and completeness of financial, non-financial and management reporting
• Compliance with the applicable legal and regulatory framework

We apply extensive internal controls and risk management systems. Internal controls are built in the design of processes by various teams of the company. Internal audits are planned based on identified risks and the results of the internal audits are fed back to the risk management process.

Internal Audit

In 2021, OPAP’s Internal Audit Team made significant progress towards achieving its main priorities. The most important activities of the Internal Audit Team are summarized below:

• Continued providing assurance services according to the approved Internal Audit plan.
• Coordinated OPAP agents, external audit and consulting resources of EY and PwC teams, as part of the SOX project, for the documentation and inspection of significant business cycles processes and controls as designed and operated in FY21.
• Further developed continuous auditing and monitoring by leveraging data analytics.
• Participated in monthly internal meetings regarding information security for external assessment of IT/Info security perimeter.

The Internal Audit team uses the MetricStream integrated GRC solution for internal audit management, risk management, compliance management, and issue management. Following the results of internal audits conducted within 2021, the company’s management considered all findings and decided upon the design and implementation of corrective measures

Monitoring Our Points of Sale

For the past 5 years an internal Mystery Shopping process has been implemented in order to ensure optimized monitoring of our network. Furthermore, this process ensures that the Regulatory Compliance and Responsible Gaming principles are followed to throughout OPAP’s retail network.

Monitoring our Customer Service Performance

We monitor our customer service performance, aiming for continuous improvement. Our monitoring processes utilize post-contact satisfaction surveys for both our partners and customers, which collect feedback on their satisfaction from the service provided. We also conduct monthly market research to measure our agents’ and customers’ satisfaction from our contact center. Furthermore, during 2021, we regularly conducted technical support focus groups with our partners, aiming to dive deep into their perceptions and views of OPAP’s technical support.

See also: OPAP’s integrated report 2021, p. 49, 66-76, 84, 122-126, 131, 143

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Λήψη Legal, Regulatory and Compliance Team

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS-102-16 

Code of Conduct

Our Code of Conduct outlines the main principles and behavioral rules and provides guidance to all members (i.e. Board of Directors, Chief Officers, managers and employees) on issues that may arise within OPAP. The code covers the following thematic areas:

• Governing principles and company values
• Operational framework
• Personal and business integrity
• Protection of OPAP group assets and customers
• Respect for people, equal opportunities, and diversity
• Whistleblowing complaints policy
• Ensuring stakeholders’ awareness

Internal Rules and Regulations

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

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

Our Regulatory Framework

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

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

Activities of the HGC are conducted within a series of regulations that either refer to the overall gaming sector (e.g. Decision no. 554/5/15.04.2021 and Law no. 4557/2018, as modified by Law no. 4734/2020, concerning tackling money laundering and terrorism financing) or that relate to specific games or gaming categories.

OPAP is also supervised by a three-member Supervisory Committee, which is established by the provisions of Article 28, paragraph 3A of Law no. 4002/2011, as currently in force. The Committee ensures that OPAP and its agents comply with the applicable legislation and act in line with OPAP’s contractual obligations towards the Hellenic Republic.

Responsible Gaming

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

• In 2021, we refreshed the Responsible Gaming Strategy for OPAP, ensuring that it is fully aligned with the European and International Responsible Gaming Standards, as well as with the Greek legal and regulatory framework.
• Hellenic Lotteries has a Responsible Gaming Policy in place. This strategy defines all the necessary measures that companies are advised to take in order to minimize the potential negative impact from participation in games of chance.

The policies address three main target groups:

• Employees
• Agents and PLAY stores venue managers/points of sale and their employees
• Players

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

Responsible Gaming principles

• Creatinga safeenvironment
• Protecting minors
• Implementing best practices
• Educating the wider public

Values & Key Focus Areas

Our vision to provide World Class Gaming Entertainment to our customers in retail and online continues to strengthen and ensure the company’s growth, the expansion of its operations and profit generation. The foundation of our vision is underpinned by our 4 core values. These values sustain our work-friendly working environment and motivate our employees throughout the Group.
We have established a set of six strategic key focus areas that will help us generate, capture and sustain value for the company and our stakeholders, both in the short and in the long term, and at the same time safeguard OPAP’s future success.

Our Values

FUN: “Fun is at the heart of everything we do

DYNAMIC: “Evolution, Game changer”

PASSIONATE: “We are passionate in everything we do”

FAIR: “Fairplay”

Key Focus Areas

• Put customer at the centre
• Enhance and strengthen our brand
• Become top tier online player
• Maintain our strong positionin the Retail World
• Explore technology
• Engage our People

See also: OPAP’s integrated report 2021, p. 12, 53-54, 112-121

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

7. Καταγραφή και παρακολούθηση (monitoring)

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

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

At OPAP we have issued the 6th Integrated Report, covering the financial year from January 1 to December 31, 2021 (unless otherwise indicated). Our Integrated Report aims to provide a balanced and integrated depiction of OPAP’s value creation process using both financial and non-financial material.
The report covers all activities of the OPAP Group, including data for all OPAP Group companies, and presenting no significant changes from the previous reporting period regarding the methodologies applied throughout the report.

The 2021 report has been prepared in line with the guidelines provided by the International Integrated Reporting Council’s <IR> Framework. The social and environmental data and information included in this report have been prepared according to the new Global Reporting Initiative’s Sustainability Reporting Guidelines (i.e. GRI Standards) and the ATHEX ESG Reporting Guide.

The separate and consolidated Financial Statements of OPAP have been prepared in accordance with International Financial Reporting Standards (IFRS) issued by the International Accounting Standards Board (IASB) as adopted by the European Union and interpretations issued by the IFRS Interpretations Committee and are effective as of 1 January 2021.

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

See Our Performance in 2021 and 2022 Targets, p. 190-195

See GRI Index, p. 196-204

See ATHEX ESG Reporting Guide Index, 205-206

See Independent Auditor’s Report, p. 207-215

Also, indicators related to operating responsively are followed and monitored in the context of the implementation of the international standards, such as the ISO 9001 Quality Management System, ISO 14001 Environmental Management System, ISO 50001 Energy Management System, ISO 45001 Occupational Health and Safety System, etc.

Ensuring Information Security

Due to the criticality of our operations, we apply a wide set of controls and practices to ensure information security. Within 2021, all security operations were performed successfully against our performance indicators regarding service downtimes, security testing, security incident service level agreements and security awareness. Our Information Security Management System has been certified in accordance with ISO 27001: 2013 Standard and WLA Security Control Standard: 2016 (WLA-SCS:2016).

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

8. Πολιτικές Αμοιβών και κίνητρα για τη Βιώσιμη Ανάπτυξη

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

The remuneration framework of the BoD seeks to create long-term corporate value by confirming that the incentive structure strikes a balance between the long-term and short-term performance of Board members as well as promoting meritocracy, so that the company attracts talents which will effectively manage it.

The Remuneration and Nomination Committee (RNC) is governed by its Charter which was approved by the Board of Directors on 16/07/2021. The Charter guides the Committee in terms of its objective and its responsibilities assigned by the Board of Directors. The RNC consists of 3 non-executive members of the Board, in full compliance with the requirements of Law 4706/2020.

Long-term Incentive Scheme

The Board of Directors, following a recommendation of the Company’s Remuneration and Nomination Committee, decided the enactment of a new long term incentive scheme for the years 2020 to 2022 with distribution of part of the Company’s net profits to Executive Members of the Board of Directors and other Key Management Personnel of the Company.

Offering Additional Benefits to our People

We offer our employees a range of benefits, which are continuously improved upon.
Specifically:

• Benefits relevant to business needs (i.e. mobile phones, laptops, corporate cars, fuel cards).
• Numerous internal and external parking spots for our employees in headquarters, as well as
  parking spots for all employees in Thessaloniki.

Especially in the area of health insurance, we cooperate with a leading insurance company to offer additional services to our employees. In 2021, the total amount of investment in private medical and life insurance plans for OPAP employees exceeded € 1,046,912. This medical and life insurance plan covers 99% of all our active employees (employees with permanent employment contracts and temporary employment contracts over one year of OPAP SA, Hellenic Lotteries SA, Horse Races SA, Tora Direct SA and Tora Wallet SA). It offers employees an annual checkup through the health insurance scheme, including digital mammography.

People engagement

OPAP acknowledges that effective internal communication and employee engagement go hand-in-hand. When people communicate and work more efficiently, there is more room for innovation and growth.

We ensure that through internal engagement initiatives, we inform our people about product launches and other key initiatives. OPAP employees had the chance to be the first to try the new OPAP store app prior to its official rollout and get to know the most advanced betting method offered by OPAP so far.
Regarding employee engagement with our products, we prepared “OPAP PRO GAME”, an engaging simulation of the Champions League coupon, based on the way it is played in pamestoixima.gr, designed for internal use. Through the unique internal contest, “OPAP PRO GAME”, more the 400 loyal employees were engaged and claimed reward gifts!

After a pause during the lockdown era, the OPAP Running Team - with more than 380 employee members - participated once again in the 38th Athens Marathon.

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

See also: OPAP’s integrated report 2021, p. 45-46, 153, 155

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS-102-35a

Remuneration Regime

With respect to the Remuneration regime, bonus schemes were adopted that build incentives via specific KPIs. Established criteria include quantitative benchmarking based on the overall Company performance, taking into account key profitability metrics.

Qualitative criteria also apply, focusing on managerial skills, training and development of the working teams, project deliveries, external communication etc.

The Remuneration Policy of the Company applies to the remuneration of all members of the Board of Directors. It is designed to reflect fairness in the context of pay conditions to all employees and align Board remuneration with the interests of our shareholders. The objective of the Remuneration Policy is therefore to meet market practice, to serve the Company’s strategic vision, its shareholders, clients and wider stakeholders.

The revised remuneration policy was approved by the shareholders of the Company at the 2021 Annual General Meeting.

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

9. Διάλογος με τα Ενδιαφερόμενα Μέρη

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Stakeholders are defined as anyone who influences or is influenced by our operations, throughout our value chain and across our operations. It is of paramount importance for OPAP to conduct a systematic and regular dialogue with such stakeholders, in order to respond to their needs and expectations, in an
effort to improve ourselves, both in the short, medium, and long term.
The stakeholders recognized by OPAP are:

• Employees (including employees, Board of Directors, management team and interns)
• Players and Non-Players
• Sales and Distribution Network (including agents, street vendors, retailers)
• Shareholders, Investors and Analysts (including shareholders, bondholders, private investors, institutional investors, funds and asset managers, analyst organizations and associations and rating agencies)
• Society (including non-governmental and academic organizations, state, government authorities and local communities, European Lottery Association, World Lottery Association, NGOs, institutions, academic organizations, treatment providers association, media, suppliers, industry members and associations).

Through our engagement with our stakeholders, we utilize a range of methods for engagement in order
to better understand their main issues of interest.

Employees
Our employees are our most valuable asset. Through our employee survey, we gain a deeper knowledge of our employees and better understand their attitudes, motivation and satisfaction. We actively communicate with our employees, using internal communication means such as regular e-mail announcements and internal newsletters. Promoting our values to our employees is also a very important part of our approach. Therefore, we organize internal awareness campaigns, corporate and social events and encourage our employees to participate.

Players and Non-Players

We firmly abide by our mandate of promoting responsible gaming and responsible communication by using various means of communication. We communicate the principles of responsible gaming to our players and the general public through awareness campaigns as well as frequent social media posts, press releases and articles. In addition, we carry out annual satisfaction surveys, via our contact center, to learn more about our players’ experiences with our products and services.

Shareholders, Investors and Analysts

OPAP aims to create value for its shareholders and investors. OPAP publishes its annual and quarterly financial performance. Together with annual and quarterly reports, we publish our environmental and social performance in our Annual Integrated Report, assisting analysts in producing credible valuations for our organization. We also organize and participate in press conferences, roadshows, investors meetings and special events.

Sales / Distribution Network

OPAP’s agents, street vendors and retailers are the immediate providers of our products and services.

We place great importance on their work and thus continuously communicate with them, to help them develop their capabilities. We organize one-to-one meetings, awareness campaigns and offer training schemes regarding responsible gaming and new products and services.

Society

We partner with local and international NGOs, academic organizations, associations, media, industries, and suppliers to create a positive impact and offer significant public contribution. Additionally, we deeply value and consistently seek to improve our relationships with the State, government authorities and local communities in the areas we operate in. We engage with these partners through formal communication channels, meetings, special events and collaborations, aiming to strengthen relationships and preserve our reputation as the leading gaming company in Greece and Cyprus.

Working with all Stakeholders on Promoting Responsible Gaming

We constantly promote dialogue and seek to build consensus with key stakeholders, to ensure that the general public is accurately and appropriately made aware of the principles of Responsible Gaming. Ιn 2021, we presented our Responsible Gaming Report and action plan to the Hellenic Gaming Commission for both OPAP SA and Hellenic Lotteries SA.

We collaborated with various stakeholders, including:

• The World Lottery Association (WLA)
• The European Lotteries (EL)
• Various academic institutions, such as the Athens University of Economics and Business
• The Therapy Center for Dependent Individuals (KETHEA)

We participated in a jointly organized two-day “Responsible Gaming” seminar by the World Lottery and European Lotteries Associations, during which we advanced our knowledge and skills related to Responsible Gaming and exchanged ideas and good practices with other members from around the world.
OPAP is a founding and currently active member of the European Lotteries (umbrella organization of National Lotteries operating games of chance for the public benefit in Europe) and the World Lottery Association, which are earnest advocates of the Macolin Convention, which stands as a historic milestone for fair play and integrity in sport. The Convention serves as the only legally binding international treaty promoting global co-operation to tackle the manipulation of sports competitions. The Convention covers all topics relative to the fight against match-fixing including national and international cooperation, the sharing of information, national platforms, criminal provisions, whistle-blowers protection, education and prevention, conflicts of interest, and measures against illegal sports betting.

The European Lotteries Association continues supporting important partnerships with organizations such as the European Non-Governmental Sports Organization (ENGSO) which initiate various efforts including the EU Commission-led initiative, European Week of Sport in 2021.

OPAP is a founding and currently active member of the Global Lottery Monitoring System (GLMS) which is a key partner of the IntegriSport Erasmus+, IntegriSport Next (2021-2022), IntegriBall, and FLAGS projects.

Within 2021, OPAP focused on one key Responsible Gaming activity with significant impact, The Helpline 1114 by KETHEA-ALFA

See also: OPAP’s integrated report 2021, p. 78-79, 121

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS-102-44

Main concerns raised by our stakeholders:

Employees

Our employees are mainly concerned with health and safety, equality and fairness, labor practices and the compliance code.

Players and Non-Players

Our engagement practices with our players and the general public have revealed highly interesting insights and show that the key issues that concern them are players’ privacy, the company’s donations and societal support activities as well as our business activities.

Shareholders, Investors and Analysts

The key issues for our shareholders, investors and analysts include, but are not limited to, financial and operational performance, strategy, governance, anti-corruption, public involvement, corporate responsibility, donations and social support.

Sales / Distribution Network

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

Society

Making an impact through our societal support programs is an integral part of our DNA, hence we remain committed to working with social stakeholders and consistently communicate and collaborate on topics that are of concern to them.

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

10. Προϊοντική Υπευθυνότητα και Καινοτομία

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Technology continues to support our mission representing an important enabler to deliver better customer solutions and improve our productivity and efficiency. We will fully utilize technology to drive the following four key strategic areas:

Gaming

Replacement or introduction of platforms and systems in the gaming domain (Sportsbook platform, Horse Racing platform) and internal development for gaming modules.

Digital
Develop new digital assets and optimize brand, retail and online platforms for players and retailers as well as evolve the digital workspace and promote adoption through the introduction of a “Digital Ambassador” for our people.

CRM and Analytics

Salesforce CRM evolution in marketing and customer service, advanced data analytics with data governance, cloud DW, AI and money-laundering technology, and a fully redesigned experience for OPAP Rewards using an optimized infrastructure.

Operational Excellence

Raise customer and agent experience via improvements in monitoring systems and operating procedures, store infrastructure and datacenter upgrades (equipment and telecoms).

Our Technology Capabilities

In 2021, OPAP made significant headway towards the achievement of the technology and digital
strategic objectives within the Fast Forward strategy.

A new front-end software development team has been established which has already started delivering front-ends internally and will continue to do so both for digital (online websites, mobile applications and a content management system) and retail (retailer terminal applications, self-service betting terminals and digital signage content screens) platforms. The first front-end entirely delivered internally was the brand-new casino website launched in November 2021, which capitalized on our strategic orientation towards open gaming ecosystems.

The strategic pursuit of open gaming ecosystems has also been achieved through re-platforming initiatives which started in 2021 for major lines of business, and which we will continue developing in 2022 and beyond.
We have also enhanced our capabilities in terms of the cross over between physical and digital worlds. We prepared a new “phygital” ecosystem to enable mobile gaming in OPAP stores, with our new flagship offering of the OPAP store application. The ecosystem consists of the mobile application itself along with a wide network of device tracking sensors (also known as beacons). It constitutes as one of the largest installations of “Internet of Things” (IoT) devices in the gaming industry internationally, enabling device-to-device communication and making it possible for players to play OPAP games in-store on their smartphones.

The new OPAP store app was successfully tested across network at the end of 2021 and was officially launched in early 2022, aspiring to further digitalize the retail customer experience.
Currently the app offers transactional play for PAME STOIXIMA, Virtual Sports and KINO, while during 2022 it will be further enhanced with the OPAP Rewards program as well as more games for transactional play and an informational section for the rest of our retail products.

In the domain of 360° CRM (Customer Relationship Management) we launched a new loyalty proposition (OPAP Rewards) as well as several new CRM capabilities. With the new loyalty proposition, we can now reward gaming activity through the retail application OPAPP. At the same time, we deployed a wide portfolio of enhancements in Salesforce CRM for both our agents and players.
We also completed groundwork for innovative enterprise solutions such as the new SAP S/4 HANA ERP. This new state-of-the-art cloud-based ERP system shall enable further digitalization of financial processes and improved standardized financial reporting. SAP S/4 HANA can support real-time analytics on very large amounts of transactional data and real-time simulation of business scenarios whilst in parallel contributing towards OPAP’s cloud-adoption strategy.

Looking ahead to 2022

The key nexus of our strategic objectives for 2022 is to build upon our know-how and internal development capabilities aiming to achieve greater agility for in-house technology delivery, better connecting us with our players. Such capabilities include front-ends, CRM and loyalty propositions, data analytics, and player account management (PAM) functions. Furthermore, we aim to ensure the stability of the core back-end platforms such as gaming engines which can be best achieved if provided by our strategic vendors.

When comparing our strategic orientation for 2022 to that of 2021, our course of direction remains the same as we are adhering to a long-term strategic approach for the development of new technology and digital capabilities. More specifically, our four key strategic areas are:

1. Gaming:
   We shall proceed with the replacement or introduction of platforms and systems in the gaming domain while also continuing with the internal development of gaming modules.
2. Digital:
   We have a solid roadmap to develop new and optimize existing digital assets for players and retailers across the brand, retail and online domains. Also, internally for our people, we shall enhance our digital workplace and support the adoption of new practices in the post-COVID era.
3. CRM & Analytics:
   We shall further develop our Salesforce platform in both marketing and customer service, employ advanced data analytics with data governance on a cloud-based Data Warehouse as well as apply Artificial Intelligence and Machine Learning techniques.
4. Operational Excellence:
   We aim to elevate customer and agent experience through improvements in monitoring systems and operating procedures as well as deploying upgrades in store infrastructure and data centers (equipment and telecoms).

See also: OPAP’s integrated report 2021, p. 24-25, 60

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS-302-1: Energy Consumption

OPAP’s overall energy footprint in 2021 was reduced by approximately 2.2% from 2020.

Environmental guidelines for our network

As part of our effort to engage with our stores and subsequently protect the environment and
ensure a sustainable business operation, we keep our network informed about practices for sound environmental operations, by including specific recommendations in our store development guidelines.
These recommendations include actions such as:

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

Συννημένα Αρχεία: Λήψη Energy Consumption

11. Χρήση Φυσικών Πόρων

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

We are conscious of global environmental issues and systematically work towards minimizing our potential negative impact throughout our operations, by complying with current environmental legislation and relevant provisions, as well as conducting all necessary environmental impact assessments.

Managing Systematically our Environmental Impact

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

As part of our ISO 14001 certified Environmental Management System, we effectively manage the environmental footprint of our operations by systematically identifying and evaluating the environmental impact of our activities, as well as our main suppliers’ activities.

In this context, we systematically identify and evaluate the environmental impact of our activities.
As a result, in 2021 we identified the following environmental aspects as the most important:

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

To further improve our approach, since 2018 we have implemented an Energy Management System certified in accordance with ISO 50001. Moreover, an energy management application is implemented at OPAP SA enabling our Building Facilities Team to effectively monitor electricity consumptions at our main buildings and investigate any unusual patterns.

OPAP acting as a responsible citizen

We are proud to report that, in 2021, OPAP SA had:

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

Energy

We use:

• Diesel for vehicle fleet
• Gasoline for vehicle fleet
• Diesel for heating
• Diesel for generating sets
• Electricity

OPAP’s overall energy footprint in 2021 was reduced by approximately 2.2% from 2020. OPAP

maintained relatively low consumption of vehicle fuels and electricity in 2021 compared to pre-pandemic years which can largely be attributed to the continuation of a hybrid work- from-home model for OPAP Group employees implemented due to COVID-19 restrictions. The subsidiary Horse Races SA, remains the one of the largest consumers of electricity amongst OPAP Group since 2019 (approximately 33% of total electricity consumption), due to its energy intensive activities at the stables and the racetrack.

Paper Consumption

As part of our efforts to reduce the amount of paper consumed throughout our premises, we strive to monitor and report our paper purchases. In 2021, we consumed around 8 tons of paper.

Water consumption

Water consumption disclosed in 2021 includes data from all OPAP Group companies. Water consumption per employee was significantly lower than last year, as the majority of OPAP Group employees worked remotely from home. Yet, the large amount of water consumed was attributed to the high irrigation and hygiene requirements of the Horse Races SA subsidiary.

Συννημένα Αρχεία: Λήψη Identification

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS-301-1

1 Data refers to the recycling performance of OPAP Group excluding Neurosoft SA.
2 The significant change in this data from previous years is attributed to the recycling of material from our warehouses.
3 The non-hazardous waste recycled particularly pertained to effluent and manure (including spoiled straw) from the
subsidiary Horse Races SA. The waste was collected separately and treated off-site by a licensed company.
4 The hazardous waste recycled pertained to biological waste from the veterinary clinic of the subsidiary Horse Races SA.
The waste was collected and managed by a licensed company.

SRS-302-1

Energy Consumption

SRS-303-1

Water Consumption

Συννημένα Αρχεία: Λήψη Energy Consumption Λήψη Materials Λήψη Water Consumption

12. Διαχείριση Πόρων

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

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

2021 Environmental Targets

2022 Targets

• Continue the implementation of environmental and energy management programs
• Maintain environmental and energy certifications, achieving zero non-conformances
• Design a strategy to reduce OPAP’s CO2 emissions by 2030

Energy Consumption

Recognizing the risks and opportunities associated with climate change, we seek to reduce our energy consumption and improve overall energy efficiency. To achieve this objective, we apply targeted initiatives to reduce our environmental and energy footprint.

Life-cycle Management of Hazardous Materials

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

• Monitor the use of materials
• Reduce the use of materials
• Recycle materials through licensed sub-contractors
• Properly dispose hazardous materials

OPAP SA performed a number of actions with the aim of improving its waste management
performance, as outlined below:

• Recycling programs, focusing on the collection of paper, cartridges/toners, light bulbs, domestic batteries, aluminum and plastic caps from beverages and bottled water, are implemented by providing the appropriate recycling bins in our facilities, as well as marked bins for the collection of normal waste.
• All potentially hazardous waste (i.e. toners, electrical equipment, light bulbs and domestic batteries) is appropriately discharged through licensed contractors.
• A licensed recycling partner directly delivers our recyclable waste to specialized recycling management facilities, instead of municipal recycling bins.
• Appropriate recycling bins for aluminum and plastic are placed in kitchen and office areas to encourage employees to separate their waste.
• All single-use plastic cutlery, spoons, straws and stirrers have been replaced with environmentally friendly alternatives.

Water consumption

Water shortage is an increasingly prevalent issue, with many regions and countries around the world particularly burdened, highlighting the need for urgent action. Being conscious of the increasing pressure to contribute towards the mitigation of water scarcity, our responsible approach has led us to:
• Monitor water consumption throughout our facilities and take further action where needed such as using specialized water gauges in key buildings or garden areas (such as in Horse Races SA facilities).
• Control and mitigate water leakages or discharges. In 2021, no significant water leakages and
discharges occurred.

Refrigerants
Acknowledging that refrigerants have a detrimental effect on the ozone layer and damage our environment, we use only environmental-friendly refrigerants in our air-conditioning systems.

In 2021 there were zero refrigerant gases discharged by OPAP SA.

Biodiversity
We are aware of the alarming rate of biodiversity loss that has taken place over the last couple of decades, due to unsustainable human activity, and we acknowledge that our lives largely depend on the variety of species and ecosystems found on our planet. We note that we do not operate currently in or adjacent to any biodiversity sensitive areas.

Environmental guidelines for our network

As part of our effort to engage with our stores and subsequently protect the environment and ensure a sustainable business operation, we keep our network informed about practices for sound environmental operations, by including specific recommendations in our store development guidelines.
These recommendations include actions such as:

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

Environmental Trainings

To drive improvement on our climate change impact, OPAP continued to carry out actions and programs aiming to further improve our environmental performance.

Indicatively, OPAP achieved the following in 2021:

• 255 employees trained on environmental issues
• 184 new employees trained on environmental and occupational health & safety issues through 12 corporate induction sessions.
• Organization of one e-learning session regarding energy andenvironmental issues, with 28 participants.

See also: OPAP’s integrated report 2021, p. 182-188, 195

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS-302-4

1The data has been recalculated based on updated factors
2 Vehicle fuel consumption has not been included.

SRS-306-2

1 Data refers to the recycling performance of OPAP Group excluding Neurosoft SA.
2 The significant change in this data from previous years is attributed to the recycling of material from our warehouses.
3 The non-hazardous waste recycled particularly pertained to effluent and manure (including spoiled straw) from the
subsidiary Horse Races SA. The waste was collected separately and treated off-site by a licensed company.
4 The hazardous waste recycled pertained to biological waste from the veterinary clinic of the subsidiary Horse Races SA.
The waste was collected and managed by a licensed company.

Συννημένα Αρχεία: Λήψη Energy Consumption Λήψη Materials

13. Εκπομπές αερίων και Κλιματική Αλλαγή

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

OPAP SA is recognizing that climate change may create significant risks and opportunities for its business in the upcoming years. Therefore, it implements comprehensive measures and procedures for addressing climate change impacts by integrating gradually recommendations of Task Force on Climate-related Disclosures (TCFD).

More specifically, all aspects of the Environmental Management System including climate-related issues are reviewed with all involved Management at least annually, through the Health, Safety, Environment and Energy Management Committee.

The Committee review covers amongst other issues like business context, risks and opportunities, environmental programs and targets, findings from external and internal assessments, as well as environmental and energy legal compliance.

In addition, on a regular basis a risk assessment is conducted by OPAP’s risk department to identify potential climate-related risks that might affect its operations. For those identified as highly material OPAP defines specific strategy and implements relevant environmental programs to manage and monitor potential negative impacts.

These risks and/or opportunities are linked to specific climate-related KPIs which are monitored and reported on a regular basis in order to track progress against the defined climate-related targets.

Environmental Trainings

To drive improvement on our climate change impact, OPAP continued to carry out actions and programs aiming to further improve our environmental performance.

Indicatively, OPAP achieved the following in 2021:

• 255 employees trained on environmental issues
• 184 new employees trained on environmental and occupational health & safety issues through 12 corporate induction sessions.
• Organization of one e-learning session regarding energy andenvironmental issues, with 28 participants.

Energy Consumption

Recognizing the risks and opportunities associated with climate change, we seek to reduce our energy consumption and improve overall energy efficiency. To achieve this objective, we apply targeted initiatives to reduce our environmental and energy footprint.

Furthermore, we systematically quantify direct and indirect greenhouse gas emissions from our operations, which primarily result from electricity consumption in our buildings and secondarily from fuel consumption for heating and our vehicle fleet.

OPAP’s overall energy footprint in 2021 was reduced by approximately 2.2% from 2020. OPAP maintained relatively low consumption of vehicle fuels and electricity in 2021 compared to pre-pandemic years which can largely be attributed to the continuation of a hybrid work-from-home model for OPAP Group employees implemented due to COVID-19 restrictions. The subsidiary Horse Races SA, remains the one of the largest consumers of electricity amongst OPAP Group since 2019 (approximately 33% of total electricity consumption), due to its energy intensive activities at the stables and the racetrack.

Emissions
We calculate our greenhouse gas (GHG) emissions, using available data. We use the emission coefficients of the Greenhouse Gas Protocol to calculate the emissions deriving from the consumption of gasoline for vehicles and diesel for heating, vehicles and generating sets.

The emissions from electricity consumption are calculated based on Eurostat’s data for national
gross electricity production and the data from the national reports submitted to the Secretariat
of the United Nations Framework Convention on Climate Change (UNFCCC).
Conversion factors for CH4 and N2O emissions are based on the global warming potential values over a 100-year period as described by the UNFCCC.

Air Pollutants

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

Among our 2022 targets are to design a strategy to reduce OPAP’s CO2 emissions by 2030, as well as to proceed with a market-based energy report.

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS-305-1: Άμεσες εκπομπές αερίων του θερμοκηπίου

SRS-305-2: Ενεργειακές έμμεσες εκπομπές αερίων του θερμοκηπίου

SRS-305-3: Άλλες έμμεσες εκπομπές αερίων του θερμοκηπίου

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

See also: OPAP’s integrated report 2021, p. 181-185

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Λήψη Εκπομπές αερίων Λήψη Εκπομπές αερίων2 Λήψη Εκπομπές αερίων3

14. Εργασιακά Δικαιώματα

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

At OPAP, we aim to move forward in building an agile and modern organization, transforming the mindset, culture and way of work, with the help of our new leadership model regarding the behaviors and actions of our people.

Engaging our people through inspiring leadership and a strong vision underline the following key priorities:

• Talent development aiming to build new skills and capabilities leveraging the OPAP Academy eLearning Hub.
• Leadership development supported by 360 feedback.
• Implementation of HR business partners and revamp of internal communication.
• Enablement of fairness and equality in career advancement recognizing both managerial and technical expertise.

Not Tolerating Child, Forced and Abusive Labor under any Circumstances

We fully and strictly follow the internationally recognized human rights principles, as described within the UN Universal Declaration of Human Rights. Through our policies, which have been internally communicated and implemented, we commit ourselves to not encourage or tolerate any coercive or abusive labor practices in any of our premises. Also, we are committed to employ individuals, who are above the legal work age limit (as defined by the Greek legislation). As a result of our commitments, in 2021:

• Four operationswere subject to humanrights reviews (100% oftotal operations).
• No operationswere identified as havingsignificant risk forincidents of child labor orforced / abusive labor.

Enhancing Employee Relations with Collective Bargaining Agreements

In accordance with internationally recognized human rights standards, as described within the UN Universal Declaration of Human Rights and the ten Principles of the UN Global Compact, our employees are covered by the Greek National Collective Bargaining Agreement. In February 2021, the new collective labour agreement, which covers all employees of OPAP SA until the end of 2021, was signed with a retroactive effect from 01.01.2021. The main elements of the agreement include basic salary, allowances, annual leave, etc

Respecting the Right of our Employees to Participate in Employee Unions

Adhering to internationally recognized principles of human rights, we respect the right of employees to participate in employee unions and discuss topics of reciprocal interest through representatives, as well as to openly and freely express their opinion, either individually or in groups. Indicatively, in 2021, for OPAP Group operations:

• 20% of our employees participated in employee unions.
• No operations were identified in which the right to exercise freedom of association and collective bargaining may be at significant risk.
• Less than 1.64% of our employees participated in two national general strikes within 2021, organized by the General Confederation of Greek Workers (GSEE).
• The total amount of time lost due to strikes was 20 man-days, accounting for less than 0.6% of the total working time.
• For major operational changes, we follow, as a minimum, the relevant regulatory requirements for notifying our employees.

Health & Safety

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

Training

Our objective is to reskill and upskill our people on traits and technical knowledge that are linked to their personal development, through various means such as classroom trainings, e-learning trainings, conferences, coaching and on-the-job training by managers.

Embracing the “PeopleOnline” platform

In 2021, we continued the application of our digital human resources platform “PeopleOnline”, to further enhance our people management processes, improving the experience of all employees. The platform includes a range of modules, such as:

• Performance management and development module.
• Employee central module (leaves applications, organizational structure, employee profile).
• Recruiting module.
• Careers module.

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

Promoting Effective Internal Communications and People Engagement

OPAP acknowledges that effective internal communication and employee engagement go hand-in-hand. When people communicate and work more efficiently, there is more room for innovation and growth.
Our key objective is to boost two-way communication, fostering open dialogue, and utilize numerous touchpoints to maintain ongoing and effective communication.

In 2021, it remained essential to keep people informed and connected during the pandemic through internal communication channels. Effective teleworking and cross-departmental collaboration ensured open communication between our employees via a set of digital solutions. At the same time, we empowered and engaged OPAP employees, offering a safe, responsible and caring employee experience. Through our corporate intranet Opapopen, we updated employees on corporate news, the measures implemented by the company with respect to the pandemic, important initiatives and achievements, benefits and policies, as well as internal activities and initiatives, reaching almost 40,000 monthly page views.

In 2021 we sent over 200 informative e-mail announcements with engaging content from all teams of the organization. In addition, we remain active on our social media accounts (i.e. LinkedIn, Facebook and Instagram), sharing unique employee experiences through our internal engagement initiatives, wellness activities and employees’ success stories.

We ensure that through internal engagement initiatives, we inform our people about product launches and other key initiatives. OPAP employees had the chance to be the first to try the new OPAP store app prior to its official rollout and get to know the most advanced betting method offered by OPAP so far.
Regarding employee engagement with our products, we prepared “OPAP PRO GAME”, an engaging simulation of the Champions League coupon, based on the way it is played in pamestoixima.gr, designed for internal use. Through the unique internal contest, “OPAP PRO GAME”, more the 400 loyal employees were engaged and claimed reward gifts!

After a pause during the lockdown era, the OPAP Running Team - with more than 380 employee members - participated once again in the 38th Athens Marathon. Our employees also engage in volunteering activities, such as participation in blood donations and fundraising events.

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS 405-01

Employees

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

• An average employee age of 41 years.
• 38 foreign employees working in OPAP Group.
• 11 employees with disabilities working in OPAP Group.

BoD

We are proud to have a Board of Directors whose members have strong academic and professional backgrounds and diverse skillsets. The majority of our board members have had numerous years of international experience in commercial and investment banking. Also, the majority of our members have held high ranking positions in gaming and betting companies and therefore possess extensive market knowledge, helping OPAP to deliver key strategic decisions to become a world class gaming entertainment company.

See also: OPAP’s integrated report 2021, p. 35, 150

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Λήψη Employee Breakdown Λήψη Gender - age - experience Λήψη member nationalities

15. Ίσες Ευκαιρίες

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

We do not tolerate discrimination and treat all employees equally. Integrating the concepts of diversity, inclusivity and fairness within our core values, we establish a positive work environment, which facilitates a performance-driven culture. Consequently, we have developed a policy that condemns all forms of discrimination, such as discrimination against race, gender, marital status, political beliefs, religion, origin, sexual orientation, age and disability, regarding work issues, such as recruitment and selection, salaries, promotions and career development.

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

Committed to diversity and inclusion, OPAP strives to bridge the gap between men and women in top management levels. We encourage female employees to reach out for higher management positions and provide support throughout their professional development.

We are proud to announce that 25% and 24% of Directors and Top Management members were
respectively women in 2021.

Fostering Work-life Balance for our People

We systematically work to ensure that all employees can achieve a good work-life balance, as we recognize that balancing professional and personal life results in higher levels of employee engagement and performance. Our specific initiatives are:

• Definition of clear daily working hours and time schedules for all employees.
• Compliance with relevant legislation defining intervals between the end of a shift and commencement of the next shift for applicable employees.
• Compliance with the legislation on the annual overtime per employee (120 hours).
• Intolerance to employees working overtime under the threat of any sanction (e.g. salary reduction or dismissal).
• Compensation and rewards for employees’ overtime (e.g. the first and second hour working after the completion of the legal time schedule).
• Assurance that employees receive and utilize their entitled leaves (such as paid leaves).
• Granting special leave to eligible employees when required (e.g. parental leave to new parents, breast feeding and childcare leave to employees, leave for single parent families and student leave).

Health & Safety

We focus on following health and safety regulations, which ensure suitable and safe work conditions, through a number of systemically implemented practices. Indicatively we:

• Enforce our Occupation Health and Safety Policy to illustrate our commitment to promoting a preventive culture for health and safety at work, which has been communicated to all employees and outlines our activities to continuously improve our workplace.
• Maintain a Health and Safety Management System certified according to the ISO 45001 standard for occupational health and safety.
• Perform audits on health and safety practices, within the scope of our Integrated Management System and ISO certifications.
• Systemically identify and monitor occupational and work conditions risks in written Occupational Risk Assessment Studies.
• Operate a Security Operations Center to monitor security and facilitate communication during emergency events 24 hours a day, 7 days a week.
• Communicate detailed instructions for emergency response and evacuation to all employees.
• Conduct regular company-wide evacuation exercises, in which all employees participated. Such exercises were conducted for all of our facilities in October 2021.
• Improve the building facility services provided and upgrade existing infrastructure where needed.
• Improve the air quality of our offices by upgrading relevant systems, to optimize their efficiency.

Response to COVID-19 Pandemic - Initiatives for the support of the employees

In 2021, OPAP remained focused on protecting its employees’ health, safety, and well-being, through a series of measures and dedicated policies. The company fully complied with the mandatory decisions and guidelines on remote working and leveraged the teleworking scheme that was successfully launched in 2020. In fact, during periods of major COVID-19 outbreaks, OPAP decided to move a higher percentage of its staff to remote working status than was required by the applicable national legislation, in order to better safeguard their health and safety.

In this context, in 2021, OPAP did not suspend employment contracts for any of its employees, despite the relevant provisions of legislations promoted by the State for the support of businesses affected by the pandemic.

Besides, the company implemented actions for its employees’ health and safety. Among other things, these included the development and the provision of specific instructions and informative material on the pandemic via internal channels (e.g. intranet, internal digital signage system, yammer, etc.), the collaboration with diagnostic centers for COVID-19 tests etc. Finally, OPAP also focused on the personal development and wellbeing of its employees through additional initiatives, such as the expansion of its e-learning platform.

Wellness and Supportive Initiatives

The Health, Safety and Wellbeing Team (OPAPWellness Team) was established in 2018 and continued its activities in 2021, with the aim to raise awareness and implement initiatives that support health, safety and wellbeing for all. The team comprises of members from the people team, the quality management systems team, external partners, and other OPAP employees.

• OPAP Employee Assistance Program

In 2021, OPAP continued the supportive OPAP Employee Assistance Program for its employees and their family members in collaboration with a specialized and experienced partner. The program took place via “Cyber Talk” format, using online training solutions. During 2021, 23 “Cyber Talk” sessions took place, with the participation of 445 employees, focusing on mental health and wellbeing. Specifically, we focused on topics like nutrition tips, growth mindset, working in virtual teams, stress management as well as an introduction to mindfulness. Employees and their family members were also provided the opportunity to seek assistance regarding personal matters and relationships through a dedicated support line, which operated 24 hours a day, 7 days a week.

• EAP Wellbeing Series

In 2021, we introduced a series of online trainings on our eLearning Hub, that aimed to further raise awareness and provide information on issues regarding mental health and wellbeing, including fatigue, stress, panic attacks, empowerment during Covid and more.

• OPAPWellness awareness sessions

In response to our people’s needs and their interest on health, safety and wellbeing, we launched the OPAPWellness awareness sessions. In 2021, doctors, scientists and academic leaders in relevant scientific fields accepted our invitation and presented awareness e-sessions for our people through Microsoft Teams on topics such as “Breast Cancer Awareness”. The level of our people’s participation was high as was the level of satisfaction, which reached 96%.

Trainings

The need to connect our people’s training and development with the organization’s strategic goals and results led to the creation of Opapacademy in 2016, through which we cultivate a single corporate culture and a customer-centric mindset. The priorities of Opapacademy are:

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

In light of the COVID-19 pandemic during 2021, OPAP’s training continued to be conducted exclusively via e-learning solutions, as the safety of our people remained our primary focus. Throughout 2021, considering the pandemic restrictions, we managed to fully digitalize the learning experience of our People. 100% of training hours were conducted via online solutions, including eCourses, Virtual Classrooms, eConferences, etc. We continued to enrich our online eLearning Hub with internally developed courses and at the same time we renewed our successful partnerships with worldwide leading educational organizations.

Induction Program Training

In order to inform and educate our employees on issues related to our teams, products, strategic priorities, core principles and values, we continue the implementation of our extensive induction program. All newly hired employees participate in the induction program, within the first month of their employment.

In 2021, the induction program was successfully conducted virtually. The two-day online induction program included a welcome message from our CEO, as well as the presence of representatives from different teams that help our new colleagues acquire an overview of our Group, products, and retail network in a fun and interactive way. The program was expanded to also include our interns who participated in the 2021 Internship Program, with 100% of them completing the program.

E-Learning Solutions

“Create a unique Learning Experience for our People, based on their specific needs and aligned with the new online reality!”

Since 2017, our Opapacademy eLearning Hub (e-learning platform) has helped our employees enhance their skills and competencies through blended learning, which includes numerous online modules both compulsory and optional. Among the lesson topics addressed are health and safety, information security, GDPR and Responsible Gaming.

• E-Learning Hub Library

During 2021, we enriched our eLearning Hub online library with new courses. This year we focused on home learning, mental health and soft skills development. The home learning category is entirely dedicated to the development of our skills within the work-from-home framework that was introduced to our people during 2020 and kept evolving with the addition of new courses in 2021. Moreover, we shared useful tips and materials that focused on our people’s mental health and wellbeing. Furthermore, we developed courses that focused on essential soft skills such as “Introduction to growth mindset”, “Effective time management & problem-solving skills essentials”, etc. Finally, we developed a new awareness course that provided all the updates and essential information on the new online regulation for the gaming industry in Greece.

• Online Development Centers

At the same time, following the successful launch of our Online Development Centers in 2018
and 2019, we continued the program and updated our libraries in 2021. The new libraries included 16 courses on a great variety of topics, promoting our efforts to enhance knowledge, and focusing on soft skills that will help us be more effective in the ever-changing environment of our new reality.

• Information Security Academy

During 2021, we introduced the Information Security Academy to our eLearning Hub which
included courses related to OPAP information and IT security, providing useful guidelines and
tips. In this context we launched a new partnership with KnowBe4, a leading company in this
field.

• Udemy for Business Partnership

Opapacademy’s places priority on creating new learning opportunities within the organization taking into consideration our people’s developmental needs. In this sense we renewed our successful partnership with Udemy for Business, through which we responded to technical training needs, as described in the individual development plans for our people.
Through this partnership, we provided access to the entire Udemy online library including more than 6,000 e-courses. This initiative has been embraced with enthusiasm from more than 520 employees with a total of 7,227 training hours, 1,265 active courses and an overall satisfaction
rate of 88%.

• Microsoft Partnership for New Technologies Trainings

During 2021, we continued our successful collaboration with Microsoft. We offered to all our people access to the Microsoft ESI platform, offering the opportunity to take advantage of this online library with courses related to Microsoft Technologies. Moreover, we provided a series of Virtual Classrooms on Microsoft Azure Technologies focusing on the developmental needs of our technology and digital team.

• Online Collaborations

We keep initiating partnerships with top external providers to cover a broad range of developmental needs through e-solutions, emphasizing on:

• Industry knowledge (iGaming Academy focusing on gaming industry related content).
• Certificates (e.g. ACCA, IFRS, Scrum).
• Conferences (e.g. SingularityU Summit 2021: Reimagine, All Things Facebook and Instagram 2021, IT Service Management 2021, Gartner Data and Analytics Summit 2021).

See also: OPAP’s integrated report 2021, p. 156 - 163

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS 403-2

• No losses of OPAP or OPAP partners’ employees.
• 611 employees were trained on health and safety issues.
• 2,531 training hours on health and safety issues.
• No high incidence or risk of disease associated with the employees’work, confirmed by the fact that no occupational diseases amongour employees occurred.
• No serious accidents involving OPAP employees took place.
• No incidents involving a female employee took place.
• No legal actions regarding health and safety issues took place.
• No fines or sanctions were imposed by the respective authorities.
• Received a Bronze Award in the “COVID-19: Resources for theworkplace" category at the 2021 Health and Safety Awards.

SRS 404-1

• 100% of OPAP SA and 87% of OPAP Group employeesreceived training.
• 713 training courses were conducted.
• The total cost of training courses was approximately € 521,240with the transition to in-house development of trainingsessions this year.

SRS 406-1

• No complaints or grievances regarding labor practices, discrimination incidents, unfair treatment or human rights violations.
• No legal actions regarding human rights issues and no fines or sanctions regarding human rights issues or labor practices were imposed by the competent authorities.
• Establishing a minimum salary, which in all cases was higher than the basic salary (or the higher collective agreement salary), as defined by local legislation.
• An almost equal ratio of salary for men and women within similar hierarchical level/area of activity/job family, with statistically insignificant variations, materializing the fact that salaries do not depend on the employees’ gender.
• 98% of OPAP Group employees are local.

Συννημένα Αρχεία: Λήψη Employee accidents Λήψη Women in positions of responsibility

16. Απασχόληση

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

We are committed to offering a great place to work, where people can feel valued and respected, to achieve personal and professional growth.

Achieving our strategic objectives requires a work environment that is engaging and empowering. OPAP is one of the largest and most successful companies in Greece and Cyprus, with 1,612 employees. In addition to direct employment, approximately 38,800 jobs are indirectly supported by our operations in Greece.

We are proud to have had:

• An average employee age of 41 years.
• An average turnover rate of 14.8%
• 19 employees who left before completing 12 months of employment.
• Average employment tenure of 9 years.

Enhancing Internal Career Development Opportunities

We aim to retain our employees and build on talent, by offering development opportunities and supporting the next steps of their professional careers within OPAP companies. The skills and

responsibilities of each employee are meant to evolve and grow in tandem with the business.
Our commitment towards developing the talent of our people is reflected in our process for Internal Career Development Opportunities, through which we channel internal recruitment with transparency and meritocracy. All employees have ample opportunities to apply for internal job openings, through the “Careers” module in OPAP’s corporate intranet. Their applications are evaluated and assessed by the OPAP People Team, which is responsible for selecting the best candidate for each position within the Group. It is not uncommon for high-performance employees to earn new responsibilities at a higher level than their current position, as they progress within the company.

In 2021, we published 59 internal job openings of all levels on our corporate intranet. The response was very positive as we received 173 applications from employees throughout the whole Group. 42 OPAP colleagues were successfully transferred or promoted to new roles internally, enhancing their career, covering 14% of the total job openings for OPAP Group.

Attracting and Identifying the Right Potential Candidates

An integral step to secure OPAP’s future growth is to work towards attracting, inspiring and retaining high-potential, talented professionals. OPAP, as an awarded employer of choice in the Greek market, offers career opportunities and a unique working experience to exceptional professionals and talented young people.

OPAP commits to hiring employees based on their personal value and criteria directly related to each role (specific qualifications and abilities), which is also confirmed in our Recruitment Policy available in our corporate intranet (OPAPopen). In addition to helping develop leaders internally, we also attract suitable candidates from the market, especially for vacancies that cannot be staffed from within the organization. All candidates are given an equal chance of being selected, with respect to diversity, inclusion and human rights, as we aim to deter any discrimination, unfavorable treatment or harassment of any kind towards candidates.

In 2021, we reviewed 6,100 applications and reached out to applicants with feedback, and also met with over 1,400 candidates in person and virtually and conducted structured interviews, according to our intensive recruitment and selection process. In 2021, we hired and welcomed 254 newcomers to various teams across the Group such as technology, online, finance and product teams.

To further enhance our recruitment efforts, we improved our digital presence. We communicate with potential candidates on a regular basis through our corporate site and social media accounts (4,300 interactions and 4.8% engagement rate on LinkedIn), share information regarding new vacancies in OPAP (in 2021 we announced 76 unique roles) and implemented other employability initiatives, such as virtual career fairs.

In 2021, the sourcing and selection process was performed exclusively online through the new “PeopleOnline” platform, offering an advanced digital (web and mobile) experience to our candidates

Investing in Youth @OPAP

Offering great opportunities to Gen Y and Z is one of our main priorities. In 2021, we e-met with over 300 young professionals, during several virtual career initiatives and events, informing them about our performance-oriented mindset and taking the time to understand their professional aspirations. Indicatively, we were present at the following initiatives:

• The ALBA Career Forum
• The Deree Career Days
• The AUEB Career Days
• The Kariera Developers Day
• The ReGeneration Program
• The HackerX Greece Full Stack Event

In 2021, following an extensive assessment process, we offered career opportunities to young professionals, targeting those with a STEM background.

Moreover, we offer young professionals the chance to kick-start their careers at a leading and reliable group, through the OPAP Internship Program “Get in the Game!” providing significant learning and development opportunities.

OPAP Internship Program “Get in the Game!”

Through our OPAP Internship Program, which was launched in 2017, we collaborate with many educational institutions, offering internships of up to 6 months to undergraduate students. The internships give students the opportunity to learn and gain professional experience in various teams and specialties.

These internships help students to develop valuable skills and advance their personal and professional skillset. Every year, we set the bar higher and gradually we enhance our collaboration with 24 prestigious educational institutions and 130 university departments across Greece.

In 2021, following a thorough assessment of 740 applicants we selected 45 young students, supported them throughout the onboarding period, shared relevant resources and material to both managers and interns, including smart and easy tips on how to have a positive remote internship experience, and helped them work remotely as OPAP interns.

It should be noted that, in the last 4 years, 288 Interns have joined OPAP Group and 24% of them, who presented exceptional performance, were hired through definite or indefinite time employee contracts. More specifically, in 2021, 16 interns were offered positions, following the completion of their internship.

Annual Performance Management and Development Process

OPAP carries out an annual performance management and development process for all its employees. The process takes place after the end of the calendar year, where the performance of employees’ individual targets for the previous year is assessed. In addition, employees’ performance targets and individual development plans are set for the following year. Key program elements include:

• Establishing a common competencies framework for all employees.
• Setting individual goals or performance standards based on each employee’s level.
• Tailored development plan for all employees.

In 2021, we continued the online implementation of our annual performance management and development process through our “PeopleOnline” platform ensuring that all employees received a formal performance review.

OPAP New Leadership Model

Consistent in the development and engagement of our people and in line with our Fast Forward Strategy, we introduced our “New Leadership Model” to OPAP’s Leaders. This model exemplifies the desired behaviours our leaders should exhibit. Specifically:

• Leading with Purpose
• Building Trust
• Customer Centricity
• Developing People
• Embracing Technology
• Innovation & Change

In this context, we created and used the “OPAP 360 Feedback” tool to empower our leaders by enabling them to recognize and further strengthen their leadership skills. “OPAP 360 Feedback” was implemented in collaboration with a leading consulting organization through its online platform, and was utilized in 2021 by the CEO, Top Management and Directors.

Offering Additional Benefits to our People

We offer our employees a range of benefits, which are continuously improved upon. Specifically:

• Benefits relevant to business needs (i.e. mobile phones, laptops, corporate cars, fuel cards)
• Numerous internal and external parking spots for our employees in headquarters, as well as parking spots for all employees in Thessaloniki.

Especially in the area of health insurance, we cooperate with a leading insurance company to offer additional services to our employees. In 2021, the total amount of investment in private medical and life insurance plans for OPAP employees exceeded € 1,046,912. This medical and life insurance plan covers 99% of all our active employees (employees with permanent employment contracts and temporary employment contracts over one year of OPAP SA, Hellenic Lotteries SA, Horse Races SA, Tora Direct SA and Tora Wallet SA). It offers employees an annual checkup through the health insurance scheme, including digital mammography.

Συννημένα Αρχεία: Λήψη internal hires

17. Ανθρώπινα Δικαιώματα στην Προμηθευτική Αλυσίδα

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Our Network

Our distribution network is one of the largest exclusive commercial networks in Greece, through which we offer our games and services. In total, 3,628 OPAP stores, 373 PLAY stores, 10,139 independent points of sale and 1,924 street vendors that distribute SCRATCH tickets and passive lotteries, make up OPAP’s network in Greece. In Cyprus, 200 OPAP stores offer our games. In 2021, despite the continuous adverse conditions caused by the COVID-19 pandemic which affected our strategic plans for a second consecutive year, we further expanded our network by opening 46 new OPAP stores and 16 new PLAY stores and upgrading 164 stores.

We keep implementing various initiatives to upgrade our network’s reputation, improve its functionality, and enhance its infrastructure in our attempt to highlight our constantly upgraded game portfolio and generate increased player traffic. Also, OPAP continued to support its partners’ performance through performance management and bonus schemes.

Optimized monitoring of our network is achieved by uniformly implementing Network Compliance Auditing and Mystery Shopping visits across our entire network, while also intensifying the monitoring of specific points of sale for which there are indications or evidence of non-compliance.

Our Suppliers

Supplier diversity and equality are integral components in our effort to build a sustainable supply chain. Our approach to supplier partnerships is founded on transparency, trust and equal opportunities for all. Therefore, we capitalize on our outreach and size to support local economies across the country, by collaborating with local suppliers for locally produced products and services.
More specifically, in 2021 we:

• Collaborated with 2,781 suppliers in Greece and abroad, of which approximately 92% were local suppliers (2,565 local suppliers).
• Spent 52% of our total procurement budget on purchases from local suppliers

Positively Influencing our Supply Chain

Being one of the largest companies in Greece, our size comes with the moral obligation to systematically disseminate, deploy and promote the principles of corporate responsibility throughout our supply chain.
Suppliers are expected to operate according to the respective legal provisions. Therefore, all our formal tenders and agreements for “Significant Suppliers” with an annual budget above € 50,000, include a clause that specifically states the requirement to comply with labor, environmental and occupational health and safety laws and regulations.

In 2021, 100% of our significant suppliers signed contracts with contractual clauses on sustainability issues (e.g. labor practices, environmental issues, impacts on society, and human rights including any type of child, forced and compulsory labor).

In 2021, OPAP’s Supplier Code of Conduct was communicated and signed by all suppliers who signed contracts or participated in tenders with an annual budget over € 100,000. We maintain a registry of our active suppliers, which is updated annually and includes their financial and business data as well as ISO 9001, ISO 14001, ISO 27001, ISO 45001 certifications and/or other standards.

Evaluating our Suppliers

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

• Quality evaluation for all our significant suppliers, based on total turnover value and their strategic importance.
• Environmental as well as health and safety evaluation for our significant suppliers based on their field of operation. Specifically, for products and services with increased environmental and societal impact, such as hygienic and security services we select suppliers who are respectively certified.

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

Supplier Evaluation Criteria

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS 412-1

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

SRS 414-1 & SRS 414-2

• 100% of new suppliers (with contracts over € 50,000) signed that they comply with the respective environmental, societal, human rights and labor provisions according to applicable national legislations. No formal audits regarding the above issues were conducted for new
• 69 significant suppliers (with contracts over € 50,000) were assessed for environmental and
  occupational health and safety impacts, in Greece, without any further actions required.
• Zero cases of suppliers with whom our collaboration was either terminated or not initiated
  due to actual or potential compliance issues (e.g. for incidents of corruption, anti- competitive behavior, non-responsible communication or poor health and safety performance).

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

18. Ενίσχυση Τοπικών Κοινωνιών

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

We believe that our role in society transcends our business activities and we have the responsibility to support social growth and prosperity. Therefore, building trust by operating responsibly and sustainably, and addressing issues that are material for our communities are fundamental to our business strategy.

Contributing Responsibly to our Society’s Needs

After years of committing to community welfare, today our CSR strategy is considered imperative to our business imperative and integral to our corporate strategy. Our corporate responsibility initiatives and programs, that reach thousands of people, nationwide, have the common objective of catering to the needs of our society and more specifically younger generations. To accomplish this, we follow a coherent corporate responsibility strategy that is built on the pillars of health, employment, sport and sensitive social groups.

 
Taking Measures to Ensure Responsible Sponsoring

We take measures to ensure that donations and sponsorships are used responsibly, in line with the requirements for which they were provided. More specifically:

• We require the recipients of donations and sponsorships to submit sufficient evidence and documentation for their sponsored activities, before granting them any funds.
• In construction projects, we perform onsite inspections and request photographs and other related documentation to ensure that these projects have been performed as agreed.
• In sponsorships, we perform monitoring visits and require reports with photographs and video evidence, or in some cases an independent contractor reports any findings to OPAP.

Recognizing the significant positive impact of our sport sponsorship practices, both at local and national level, we apply several responsibility practices in our sponsorship contracts with sports teams, including:

• A clause to invest approximately 20% of each contract’s value towards supporting young people.
• A clause against violence (applied since 2010) to enhance the crucial component of safety and security in stadiums (e.g. installation of cameras and turnstiles), with relevant clauses being included in most of our sponsorship contracts.

Key 2021 Programs and Initiatives

Community Initiatives to Tackle the COVID-19 Pandemic

OPAP implemented a series of initiatives to address the impact of the COVID-19 pandemic in 2021. Aiming to further contribute to the national effort to combat the pandemic and support the work of the country’s hospital units, OPAP offered immediate support to the competent authorities. Some of the actions implemented include:

• Continued renovation and supportof pediatric hospitals such as the Panagiotis and Aglaias Kyriakou and Aghia Sofia Children’s hospitals.
• Provision of healthcare supplies for elderly people.OPAP provided thousands of gloves and protective masks to the Athens Nursing Home for elderly peopleenabling them to better respond to health emergencies during the pandemic.
• Support provided to the businesses of the OPAP Forward programwhich contributed to the support of preventative measures regarding COVID-19

Children Hospitals Renovation Program

OPAP began the renovation project of the Aghia Sophia and Panagiotis and Aglaia Kyriakou Children’s Hospitals in April 2014, as part of its corporate responsibility program. Both hospitals, constructed in the 1940s, were damaged and came short in fundamental operational requirements.
Since then and until the end of 2021, over 85% of the renovation project has been completed. In 2021, despite the challenges of pandemic, OPAP delivered the renovation and modernization of the neonatal ICU Unit of the “Panagiotis and Aglaia Kyriakou” Hospital, as well as the Urology-Plastic Surgery Unit of the “Aghia Sophia” Hospital.

The results of the project have completely transformed both hospitals, creating a pleasant environment for the children, their parents and the nursing and medical staff.

“OPAP in the Neighborhood” Preventive Health Checkup Program

Having acknowledged the need for health protection, OPAP implements a Medical Prevention program, along with “The Smile of the Child”. As part of the program, four fully equipped OPAP-branded mobile medical units travel to cities across Greece (including Attica), offering preventive health examinations to both adult and underage people. This initiative is part of our Corporate Responsibility program “OPAP in the Neighborhood”, which aims to respond to significant local community needs, such as the protection of adult and children’s health through preventive health checkups.

“OPAP Forward” Program

Faithful to its strategy of generating value for the Greek economy and society, OPAP continued- for a fourth consecutive year - its “OPAP Forward” program, which supports small and medium entrepreneurship and employment.

The “OPAP Forward” program is designed to offer a unique opportunity to fast growing small and medium businesses, so that through their development, these companies can unleash their full potential and generate new jobs in the Greek market.

The program offers 12 months of continuous support and expertise for each company to design and implement a holistic strategic plan that addresses different business areas significant to their development. In 2021, the program actively supported 40 companies, while 19 companies that were recruited in 2017 completed the curriculum and graduated from the program. According to data from the international non-profit organization Endeavor, the participating companies have increased their total turnover by € 242 million and created 2,260 new direct employment positions. Additionally, through the collaborations they have developed, 20,249 additional indirect jobs have been supported.

“OPAP Sports Academies” Program

Prioritizing the creation of value for younger generations, we continued the “OPAP Sports Academies”
program for the fifth year in a row, despite the adverse effects of the COVID-19 pandemic. While we did not recruit new academies in 2021 due to the pandemic, we further enriched our program’s online platform, “Sports Academies Online”, which is fully dedicated to young athletes, their parents, academy operators and coaches. The “Sports Academies Online” platform disseminated content on nutrition, psychology and general health and wellbeing of young athletes in collaboration with a dedicated scientific team as well as a group of highly respected athletes. Additionally, OPAP delivered a “social distancing” coaching equipment to the 178 academies that participate in the program, to help children train safely.

“Wishing Ornaments” Program

Since 2014, OPAP has been standing beside NGOs across Greece, which support children in need, through the “Wishing Ornaments” initiative. The aim of this initiative is to help contribute to a greater social effort, through the fulfillment of children’s wishes. At the same time, OPAP implements projects that support the operation of organizations and improve quality of life for children. In 2021, we invited children that are supported by the “Smile of the Child” and the “Ark of the World” organizations to list their wishes, so that they can be fulfilled by people invited to participate in the “Wishing Ornaments” program. Participation is carried out through the “Contribution Squad” mobile app and the opapcsr.gr website. In total, 6,780 children’s wishes were fulfilled through the program. Gifts to children were delivered during a special event, attended by celebrities and prominent athletes.

OPAP “Contribution Squad”

Aiming to engage the general public with OPAP community relations initiatives, we launched the engaging and fun mobile app “Contribution Squad” in 2014. OPAP uses the “Contribution Squad” app as a tool to communicate and engage with the general public and disseminate news about its corporate social responsibility activities and initiatives. Through the “Contribution Squad” app, public is invited to participate in fun challenges to gather points which OPAP subsequently transforms into support for welfare institutions that are active in protecting and helping children. In 2021, the app reached 320,891 total downloads and an increased engagement of users, that came as a result of the initiatives that the application promoted throughout the year. For example, in 2021, the Contribution Squad app promoted the engaging initiatives for the Children’s Hospital Renovation program and the Wishing Ornaments program.

Emergency Relief Initiatives

In April 2021, OPAP responded to a strong earthquake that impacted Elassona. Along with its local retail network, OPAP supported the local community with donations. Specifically, in Elassona, OPAP and PLAY store owners distributed essential goods to families accommodated in emergency facilities, in collaboration with regional authorities. Similarly, in October 2021, a 5.8-Richter earthquake in Heraklion caused significant damages. OPAP, along with its local retail network and local agents’ association in Heraklion distributed essential goods to the affected families that were accommodated in tents, including detergents, personal hygiene supplies, a washing machine, a clothes dryer and blankets that were essential for the affected Municipality of Minoa Pediada. Moreover, as part of OPAP’s sponsorship of OFI F.C., we financially supported a friendly match for which revenues were donated to the region of Crete for the restoration of a damaged school.

At the end of 2021, OPAP along with representatives from our retail network donated supplies to the Athens Nursing Home and the “Together for Children”, “The Smile of the Child” and “Ark of the World” organizations.

See also: OPAP’s integrated report 2021, p. 165 - 177

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

GRI SRS 201-1

We seek to create economic value not only for our shareholders, but also for our other stakeholders, as it is particularly important considering the current social and economic challenging landscape. We are committed to utilizing the positive value generated by our business to benefit different stakeholders. Therefore, our turnover exemplifies the return of significant financial resources back to society, towards our players (through pay-outs to lottery and betting winners), our network (through a commission-based agents’ agreement), our shareholders (through dividends), our suppliers (through purchases), our employees (through wages, benefits and insurance payments), providers of capital (through interest paid for loans), the Hellenic Republic (through participation in GGR, corporate taxes and other taxes and duties) and investments.

Within 2021, OPAP Group:

• Disbursed over € 5,458 million to players.
• Distributed over € 277 million to our network.
• Distributed over € 95 million to our shareholders.
• Paid over € 204 million to suppliers (excluding investments).
• Expended € 76 million for employees.
• Paid € 46 million to providers of capital.
• Paid over € 258 million to the Hellenic Republic, out of which € 124 million was attributed to GGR contribution and € 18 million to corporate taxes.
• Utilized € 43 million in investments.

An important parameter that illustrates our commitment to create economic value for our stakeholders as well as our transparent practices, is our obligation to return undistributed winnings of players (amounts from winning tickets that were never collected), along with the rounding up of winnings in every winning category, back to the Hellenic Republic.

Specifically, the undistributed winnings for 2021 (as registered in the financial statements on 31.12.2021) were € 13 million, the same amount as 2020.

Our dividend policy stands for the distributions that exceed Net Profit with a minimum of €1.00 per share, with additional special dividend distributions to be considered on an ad-hoc basis.

It must be noted that:

• The total gross dividend per share (DPS) referring to the fiscal year 2021 is € 0.60. It is noted that a capital return of € 0.90 per share will also be proposed at the AGM, scheduled for 9 June 2022.
• Earnings per share (EPS) in 2021 were approximately € 0.75, compared to approximately € 0.61 in 2020.

See also: OPAP’s integrated report 2021, p. 108-109

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Our commitment to sustainability is reflected in our respective investment. In 2021, OPAP Group invested € 26.8 million in a total of 578 sustainability initiatives and actions.

Συννημένα Αρχεία: Λήψη Societal Support program

19. Συμμετοχή σε Πρωτοβουλίες και Πολιτική Επιρροή

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Memberships
In 2021, OPAP Group companies participated in a number of organizations and committees,
relevant to their operations.

ORGANIZATIONS

• World Lottery Association (WLA)
• European Lotteries Association (EL)
• Global Lottery Monitoring System (GLMS)

WORKING GROUPS

• European Lotteries Public Affairs Coordination Working Group (EL PAC)
• European Lotteries Sport Working Group (EL Sport)

OPAP is a founding and currently active member of European and international associations, representing national lotteries, operating games of chance for the public benefit. Namely, OPAP
is a member of:

• The European Lotteries Association (EL), the European lottery and gaming sector’s largest organization, advancing the interests of national lotteries operating in more than 40 European countries – with around 50 members in all EU member states (a total of more than 70 members).
• The World Lottery Association (WLA), an international, member-based organization, serving the interests of more than 150 state-authorized lotteries worldwide.
• The Global Lottery Monitoring System (GLMS), which is the state lotteries’ mutualized monitoring system on sports betting. It aims at detecting and analyzing suspicious betting activities that could question the integrity of sport competitions, at a global level.

The aforementioned associations contributed to policymaking and stepped up their involvement in various important initiatives and projects, in 2021. Namely:

• The World Lottery Association (WLA), the European Lotteries (EL), and the Global Lottery Monitoring System (GLMS) remain earnest supporters of the Macolin Convention, since it was drafted, seven years ago. The main objectives of the Macolin Convention are to establish a legal framework for the prevention, detection, and sanctioning of the manipulation of sports competitions; and to promote the cooperation of all relevant stakeholders in this endeavor.

The Macolin Convention provides an effective means for combatting the manipulation of sports competitions. Most notably, it calls for the establishment of national platforms, which among other things, facilitates the transnational exchange of information essential to the fight against the manipulation of sports competitions and illegal betting. National platforms have already been established in several EL/WLA member states and have proven to be effective in the coordinated effort to thwart corruption in sports.

• The European Lotteries maintained and participated in important partnerships, including the European Non-Governmental Sports Organization (ENGSO), and supported the European Commission-led initiative European Week of Sport in 2021.
• GLMS continued its involvement in the IntegriSport Erasmus+, IntegriSport Next (2021-2022), IntegriBall, and FLAGS programmes/projects. Both IntegriSport projects aim to raise awareness among local law enforcement and judiciary authorities regarding all aspects of the manipulation of sports competitions, while IntegriBall is aimed at protecting grassroots footballers from match-fixing threats. Furthermore, the FLAGS project gathers the Council of Europe, GLMS, FIFA, Confederations, National Football Associations, INTERPOL, the Prosecutor’s network, and the Group of Copenhagen to combat match-fixing, with the aim to detect and stop football match-fixing early on.

OPAP Group Concession Agreements

Numeric Games and Betting

On 15 December 2000, in accordance with Article 27, paragraph 2A of Law no. 2843/2000 (GG Α’ 219/12.10.2000), we entered into a 20-year Concession Agreement with the Hellenic Republic and have been granted the exclusive right to conduct, manage, organize and operate numeric, sport forecasting and betting games by any appropriate means relevant to the current technology (offline and/online).

Passive Lotteries and Scratch Games

On 30 July 2013, Hellenic Lotteries SA (of which OPAP is a main indirect shareholder) entered into a 12-year concession agreement with the Hellenic Republic Asset Development Fund SA for the exclusive right to produce, operate, circulate, promote and manage the state lotteries. The concession agreement was ratified by the Hellenic Parliament (Law 4183/2013, GG A’ 186). The 12-year period started on 1 May 2014.

Video Lotteries Terminals (VLTs)

According to the provisions of Article 39 of Law no. 4002/2011 and following the issuance of the relevant VLTs license decision of the Minister of Finance (GG B’ 2503/4.11.2011) and the conclusion of the VLTs Agreement dated 4 November 2011 between OPAP SA and the Hellenic Republic, we initially held an exclusive 10-year license to install and operate 35,000 VLTs in Greece (16,500 VLTs would have been installed and operated directly by OPAP throughout its network, while 18,500 would have been operated by concessionaires, following an international tender). However, in November 2017, the amendment of Article 39 and 40 of Law no. 4002/2011, under the provisions of Articles 3 and 4 of Law no. 4499/2017, led to the respective amendment of the VLTs license on 17 January 2018 (GG B’ 77/22.1.2018) and the VLTs agreement on 19 January 2018. The number of VLTs covered by the agreement was reduced to 25,000 self-operated machines and the VLTs license duration was extended to 18 years (i.e. until 11.1.2035). According to the relevant legal and regulatory requirements, OPAP successfully installed 25,000 VLTs by 31 December 2019.

Mutual Betting on Horse Races

On 24 April 2015, Horse Races SA (of which OPAP is a sole shareholder) entered into a concession agreement with the Hellenic Republic Asset Development Fund SA for the exclusive right to organize and conduct mutual betting on horse races in Greece, land-based for 20 years and online for 5 years. The concession agreement was ratified by the Hellenic Parliament (Law 4338/2015, GG A’ 131) and began on 18 January 2016.

Online Gaming

Law no. 4635/2019 (Government’s Gazette A’ 167/30.10.2019), amending Law no. 4002/2011 regarding online sports betting activities and other online games defines details on the licensing of operators. On 26 March 2020, OPAP submitted two separate applications to the HGC for both licenses and on 25 May 2021, both type 1 and 2 Licenses were granted to OPAP SA by the HGC. These licenses are valid for seven years (i.e. until 25.5.2028) and are renewable, subject to fulfilment of certain conditions. The Go Live took place on 10.08.2021, following the HGC’s decision, according to the provisions of article 46 paragraph 9 of Law no. 4002/2011 and the fulfilment of the requirements set forth in article 6.1 and 6.2 of the regulation.

OPAP Group is committed to maintaining the highest standards of ethics and integrity in the way it does business in Greece and Cyprus. Fraud, bribery and corruption in all forms are illegal and unacceptable. Stakeholders of OPAP Group must not offer, provide, accept, or promise, either directly or indirectly, any undue financial or other advantage to a public and/or private official for the purpose of obtaining any favorable treatment or business advantage. Stakeholders should immediately report any concerns of fraud, bribery and corruption in accordance to the “Whistleblowing Complaints Policy”.

Additionally, it is prohibited to offer, solicit or accept gifts, donations in cash or any other form and any benefit related to the performance of the Stakeholders duties. It may only be allowed to accept or offer non-cash gifts/hospitality of value not more than € 150 arising out of customary business practices. It is important that gifts or hospitality never influence business decisionmaking processes, or cause others to perceive an influence. Where there is any uncertainty if offers, invitations or acceptance of corporate gifts or hospitality from/to third parties should be refused, or returned to the third party, Stakeholders should contact the Regulatory & Compliance Officer.

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS-415-1: Συνεισφορά σε πολιτικά κόμματα

Stakeholders of OPAP Group must not offer, provide, accept, or promise, either directly or indirectly, any undue financial or other advantage to a public and/or private official for the purpose of obtaining any favorable treatment or business advantage. Therefore, there are zero political contributions.

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

20. Πρόληψη και Καταπολέμηση της Διαφθοράς

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Code of Conduct

Our Code of Conduct outlines the main principles and behavioral rules and provides guidance to all members (i.e. Board of Directors, Chief Officers, managers and employees) on issues that may arise within OPAP. The code covers the following thematic areas:

• Governing principles and company values
  • Operational framework
  • Personal and business integrity
  • Protection of OPAP group assets and customers
  • Respect for people, equal opportunities and diversity
  • Whistleblowing complaints policy
  • Ensuring stakeholders’ awareness

The Code of Conduct strictly prohibits all employees from offering, soliciting or accepting gifts, donations and any benefit related to the performance of their duties (neither in cash nor any other form). Gifts should be transparent, infrequent and should not be offered or accepted during (or prior to) contractual negotiations and tender processes with a supplier. Offering hospitality or tickets to events should be solely for the purpose of building business relationships with OPAP Group employees. It is important that gifts or hospitality never influence business decision-making processes, or cause others to perceive an influence.

OPAP Group is committed to maintaining the highest standards of ethics and integrity in the way it does business in Greece and Cyprus. Fraud, bribery and corruption in all forms are illegal and unacceptable.

Raising Concerns and Whistleblowing

The Company is committed to conducting its business with honesty, integrity and fairness and expects all stakeholders to maintain these high standards. However, all organizations face the risk of the occasional unanticipated activities and incidents.

The company has established the Whistleblowing Complaints Policy by which employees and our network (as of 2021) can and should report valid allegations of known or suspected improper activities, in good faith and without fear of retaliation, to the responsible authority, such as an immediate manager and/or the Chief Legal, Regulatory and Compliance Officer.

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

• Via an electronic platform accessible to the stakeholders by sending an email to [email protected].
• By contacting the number (+30) 210 5798193.
• Via a personal hearing.

Complaints received under the Whistleblowing Complaints Policy will be reviewed under the oversight of the company’s Chief Legal, Regulatory and Compliance Officer, the Audit Committee or the Internal Audit Team. The Chief Legal, Regulatory and Compliance Officer, the Audit Committee or such other persons will then determine the appropriate actions needed to address such cases. The policy aims to encourage people to immediately report suspected incidents and guarantees that their concerns will be taken seriously and investigated as appropriate. In 2021, there were no raised complaints through the whistleblowing mechanism.

Anti-Money Laundering

We comply with the standing legal framework and the Hellenic Gaming Commission’s Decision no. 554/5/15.04.2021, as currently in force, which introduces measures to prevent money laundering and terrorist financing in the gaming sector.

In order to achieve compliance and thus prevent, detect and deter money laundering and terrorist financing, we have put in place a comprehensive Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) compliance program which consists of the following basic pillars:

• A system of internal policies, procedures and controls.
  • A designated compliance function with a compliance officer.
  • An ongoing employee/agent training program.
  • An independent audit function to test the overall effectiveness of the AML program.

Policy and Procedures

An internal “Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) Policy” is in place for OPAP SA, Hellenic Lotteries SA and Horse Races SA, which applies to all employees, agents of the land-based sales network and their staff. The Policy is established and approved by the Board of Directors, thus setting the “tone from the top” within the organization. It incorporates a high-level set of principles and serves as the basis for procedures and controls, which provide details as to how all lines of business can achieve compliance with laws and regulations and with the organization’s respective standards and goals.

Anti-Fraudulent Activity

The Antifraud Team has been operational within the Group since 2014. Its scope of responsibilities includes the detection and prevention of fraudulent activities that could negatively affect the business goals of OPAP and its subsidiaries.

See also: OPAP’s integrated report 2021, p. 67, 69-71

https://media.opap.gr/221464_OPAP_REPORT_22_2106_NIK.pdf

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία

ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

SRS-205-2

Ιn 2021:

• Certain members of the AML/CTF Team attended a training course on “AML in the gambling sector”.
• 72 Account Managers were trained by the AML Compliance Officer’s Team on the AML/CTF regulatory framework and relevant developments as well as major issues and declines noticed in the retail network.
• The vast majority of the agent network has been trained during 2019-2021 through the Group’s e-learning platform, the OPAP Retail Academy.
• Several communications have been delivered to the retail network to inform them about key provisions of the AML Regulation and the relevant AML Policy.

SRS-205-3

It must be noted that in 2021 there were:

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

SRS-419-1

Ιn 2021, no fines and/or non-monetary sanctions on potential competition law violations were imposed on OPAP.

Συννημένα Αρχεία: Δεν υπάρχουν αρχεία