the greek sustainability code

QNF - RNE 1

The Greek Sustainability Code

Information material February 2016

QNF - RNE 2

The Greek Sustainability Code has been created in view of becoming a practical tool of transparency

and commitment to the issues of Sustainable Development and Corporate Responsibility for all

Companies and Organisations active in Greece, regardless of their size or legal status. The Greek

Code attempts to give guidance to the Organisations on how to integrate the Sustainable

Development and Corporate Responsibility principles in their business operation.

The Greek Sustainability Code is a result of the QualityNet Foundation (QNF) cooperation with the

German Council for Sustainable Development (RNE) in the context of the “Sustainable Greece

2020” Initiative.

The “Sustainable Greece 2020” initiative aspires to create a new model of development for Greece

that not only will lead the way out of the crisis but it will also lay down the basis for a Sustainable

Economy and Society. An Economy that will ensure Social Cohesion through the equal development

of each side of the Economy – Society - Environment triangle. The Initiative by way of a wide

dialogue and consultation process aims at contributing in the promotion of the Sustainable

Development and supporting the organisations, the institutions and authorities of our country with

practical tools and methodologies for the creation of Sustainable Development Strategies and

Policies. The Greek Sustainability Code is one of these tools.

The Paper of the Consultation Process of the Greek Sustainability code is the result of the work of the

members of the Committee for the Development of the Greek Sustainability Code consisting of

representatives of business associations and state institutions. It is also the work of a team of

technical consultants.

The members of the Committee for the Development of the Greek Sustainability Code are the

following (in alphabetical order):

Mr. Gerasimos Georgopoulos, Head of the Department of Institutional regulations and of the

General Electronic Commercial Registry, Ministry of Development

Mrs. Nafsika Zevgoli, Head of the Department of Sustainable Development and Social Contribution,

VODAFONE

Mr. Ioannis Karavas, Head of Communication and Public Relations, Alouminion AE

Mr. Alexandros Katsiaboulas, Director of the Environment, TITAN Group

Mr. Alexandros Koulidis, Counsellor, Secretary General, Ministry of Environment and Energy

Mrs. Pinelopi Pagoni, Director of Health, Safety, Environment and Sustainable Development, Hellenic

Petroleum group

Mrs. Eleni Styliani Starra, Head of the European Affairs Department, Athens Chamber of Commerce

and Industry

Mrs. Rena Sota, procurement, Security & CR Managers, TNT

Technical Consultants:

Mrs. Tina Passalari, Sustainable Development and Management Consultant

Mr. Spyros Kontos, Management and Operational Systems Consultant

QNF - RNE 3

Contents

1 Preamble

5

2 Towards a European Platform of Sustainable Development – The Sustainability Code 2.1 The 20 Criteria of the Greek Sustainability Code 2.2 Levels of Participation in the Greek Sustainability Code 2.3 How to complete the Greek Code Sustainability Code 2.4 Declaration of Conformity to the Greek Sustainability Code 2.5 Compatibility version of the Declaration of Conformity with the Greek Sustainability Code

6 7

11 12 13 15

2.6 Performance Indicators 16 3 Answers to frequently asked questions 22

QNF - RNE 4

What is sustainability?

“Sustainable development is development that meets the needs of the present without

compromising the ability of future generations to meet their own needs. […] In essence, sustainable

development is a process of change in which the exploitation of resources, the direction of

investments, the orientation of technological development, and institutional change are all in

harmony and enhance both current and future potential to meet human needs and aspirations.”

Brundtland-Commission 1987

QNF - RNE 5

1. Preamble

The Greek Sustainability Code has been created in the context of “Sustainable Greece 2020”

Initiative in view of becoming a practical tool of transparency and commitment to the issues of

Sustainable Development and Corporate Responsibility for all Companies and Organisations active in

Greece, regardless of their size or legal status. The Greek Code attempts to give guidance to the

Organisations on how to integrate Sustainable Development and Corporate Responsibility principles

in their business operation.

The Greek Sustainability Code:

is in line with the dictates of the Directive of the European Commission for the disclosure of non-

financial data,

it is based on international standards (such as the Global Reporting Initiative, United Nations

Global Compact, OECD Directives for multi-national companies, ISO 26000, EFFAS, EMAS,

ISO 14001, ISO 5001, ISO 5002, ISO 9001, SA 8000 etc.),

it draws know-how from the respective Sustainability Code developed by the German Council for

Sustainable Development (RNE),

it is linked with the creation of a European Platform on Sustainable Development “The

Sustainability Code”,

it takes into consideration the particularities of the Greek market, the size of the Organizations

as well as their degree of maturity.

Benefits of participating in the Greek Sustainability Code:

It promotes and supports the linkage of the Organizations with the issues of Sustainable

Development and Corporate Responsibility using a common, well-established and

comprehensive international methodology in the form of user-friendly and practical framework

the Organizations can use to report on Sustainable Development and Corporate Responsibility

management systems.

It is a tool for internal management improvement of an Organization in terms of its approach on

the issues of Sustainable Development and Corporate Responsibility.

It provides the investors with information and can be used as a means of assessment and

comparison of the Organizations results on non-financial data per criterion.

It is in line with the dictates of the Directive of the European Commission for the disclosure of

non-financial data.

It creates a “responsible supplies” framework through which each Organization demands a

comparative advantage on the management of its suppliers’ network.

It showcases the image of the Organization as a “responsible business civilian” vis-à-vis the

government and social institutions as well as the customers-consumers.

The Greek Sustainability Code comprises of 20 Criteria under 4 Pillars and is essentially responsive to

the need of assessment and measurement of the economic, environmental and social performance.

Taking into consideration the particularities of the Greek market with regards to the size of the

Organizations/Companies, the Greek Sustainability Code offers the Organizations the option of

QNF - RNE 6

gradually adopting its criteria. Thus, although the Greek code comprises of 20 criteria, an

Organization can selectively participate in the Code through the Electronic Platform of the Greek

Sustainability Code on annual basis, filling in on its different levels depending on the maturity of its

internal management and procedures.

2. Towards a European Platform on Sustainable Development – The Sustainability Code and the linkage with the Greek Sustainability Code

The European Platform on Sustainable Development– The Sustainability Code it is a model on the

management of Sustainable Development and Corporate Responsibility promoting the sustainable

management and operation of the Organizations in terms of transparency and self-commitment on

European level.

The Greek sustainability Code:

draws know-how from the Sustainability Code developed by the German Council for Sustainable

Development (RNE)

is part of the European Platform on Sustainable Development-The Sustainability Code

contributing to its formulation

gives added value to the participant Organizations demonstrating their level of maturity on

sustainable Development and Corporate Responsibility issues on national and European level.

Note that the European Platform on Sustainable Development– The Sustainability Code and the

Greek Sustainability Code are comprised of 4 pillars and 20 criteria that were the result of

consultation processes on European and national level with the purpose of facilitating the

participation of the Organizations on the most user-friendly and practical operational framework.

The European Platform on Sustainable Development–The Sustainability Code and the Greek

Sustainability Code will be on a constant, dynamic and open development process through

consultation and dialogue in view of becoming the fruit of wider consensus and adaptation on the

ever-changing evidence.

QNF - RNE 7

2.1 THE 20 CRITERIA OF THE GREEK SUSTAINABILITY CODE

Criteria 1–4 concerning STRATEGY

Strategic Analysis and Action

1 The company discloses how it analyzes the opportunities and risks of its major activities in the context of Sustainable Development and Corporate Responsibility. The company explains what concrete measures it is undertaking to operate in compliance with the essential and recognized sector-specific, national and international standards.

Materiality

2 The company discloses what aspects of sustainability have a significant impact on its business operations and how, in its strategy, it takes them into account and systematically addresses them.

Objectives

3 The company discloses what qualitative and/or quantitative as well as temporally defined sustainability goals are set and operationalized, and how their level of achievement is monitored.

Depth of the Value Chain

4 The company states what significance aspects of sustainability have for added value and how deep into the value-added chain the sustainability criteria are verified.

Criteria to 5–10 concerning PROCESS MANAGEMENT

Responsibility

5 Accountability in the corporate management with regard to sustainability is disclosed.

Rules and Processes

6 The company discloses how the sustainability strategy is implemented in the operational business by way of rules and processes.

QNF - RNE 8

Control

7 The company discloses how and what performance indicators on sustainability are integrated into its periodical internal planning and control and how the reliability, comparability and consistency of the data applied to internal controls and external communication are safeguarded through appropriate processes.

Incentive Schemes

8 The company discloses how target agreements and remuneration schemes for executives and employees are also geared towards the achievement of sustainability goals and how they are aligned towards long-term value creation. It discloses the extent to which the achievement of these goals forms part of the evaluation of the top managerial level (board / managing directors) conducted by the monitoring body (supervisory board / advisory board).

Stakeholder Engagement

9 The company discloses how the socially and economically relevant stakeholders are identified and integrated into the sustainability process. It is disclosed whether and how an ongoing dialogue takes place with them and how the results are integrated into the sustainability process.

Innovation & Product Management

10 The company discloses how innovations in products and services are enhanced through suitable processes which improve sustainability with respect to the company’s utilization of resources and with regard to users. Likewise, a further statement is made with regard as to how the current and future impact of the key products and services in the value chain and in the product life cycle are assessed.

Criteria 11–13 concerning ENVIRONMENT Usage of Natural Resources

11 The company discloses the extent to which natural resources are used for the company’s business activities. Possible options here are materials, the input and output of water, soil, waste, energy, emissions, land and biodiversity as well as emissions for the life cycles of products and services.

QNF - RNE 9

Resource Management

12 The company discloses what qualitative and quantitative goals it has set itself with regard to its resource efficiency, its use of renewables, the increase in raw material productivity and the reduction in the usage of ecosystem services, and how these goals have been met or will be met in the future.

Climate-relevant emissions

13 The company discloses the GHG emissions in accordance with the Greenhouse Gas (GHG) Protocol or standards based on it and states the goals it has set itself to reduce emissions.

Criteria 14–20 concerning SOCIETY Employment Rights

14 The company reports on how it complies with the employment rights of both nationally and internationally recognized standards and how it promotes employee involvement in sustainability management.

Equal Opportunities

15 The company discloses in what way it has implemented national and international processes and what goals it has to promote equal opportunities and diversity, occupational health and safety, the integration of migrants and people with disabilities, fair pay as well as a work-life balance.

Qualifications/ Employability

16 The company discloses what goals it has set and what measures it has taken to promote the employability of all employees, i.e. the ability of all employees to participate in the working and professional world, and to adapt it to demographic change.

Human Rights

17 The company discloses what measures it takes for the supply chain with the aim of ensuring that human rights are respected globally and that forced and child labour as well as all forms of exploitation are prevented.

QNF - RNE 10

Corporate Citizenship

18 The company discloses how it contributes to corporate citizenship in the regions in which it conducts its core business activities. (This criterion relates to the commitment of the Organization that surpasses Sustainable Development and Corporate Responsibility limits relevant to its operation, and covers also sponsorships, charities and volunteer work of the employees).

Political Influence

19 All significant input relating to legislative procedures, all entries in lobby lists, all significant payments of membership fees, all contributions to governments as well as all donations to political parties and politicians should also be disclosed by country in a differentiated way.

Conduct that Complies with the Law and Policy

20 The company discloses which measures, standards, systems and processes are in place to prevent unlawful conduct and, in particular, corruption, and how they are verified. The company depicts how corruption and other contraventions in the company are prevented and exposed and what sanctions are imposed.

QNF - RNE 11

2.2 LEVELS OF PARTICIPATION IN THE GREEK SUSTAINABILITY CODE

Implementing step-by-step the criteria of the Greek Code

The Greek Sustainability Code adapts to the particularities of the Greek market in terms of

the size of the Organizations/Companies by using successive levels. Thus, each Organization

that desires to be linked with Sustainable Development and Corporate Responsibility issues

can participate in the Greek platform of sustainability by completing the different levels of

the Greek Sustainability Code depending on the degree of maturity of its internal

management and procedures. For this reason, we invite all the Organizations no matter of

their size to get linked with the issues of Sustainable Development and Corporate

Responsibility through a systematic approach and procedures that each Organization already

implements and can vary depending on the legal or regulative context applied.

Level 1: It is intended for Organizations/ Companies that do not have a systematic approach on the issues of Sustainable Development and Corporate Responsibility. These are usually, but not always, very small Organizations/ Companies. On this level the Organizations can be linked to the Greek Sustainability Platform. Level 2: It is intended for Organizations/ Companies that do or not have a systematic approach on the issues of Sustainable Development and Corporate Responsibility. These are usually, but not always, small and medium Organizations / Companies. On this level the Organizations can be linked to the Greek Sustainability Platform. Level 3: It is intended for Organizations/ Companies that do or not have a systematic approach on the issues of Sustainable Development and Corporate Responsibility. These are usually, but not always, medium and large Organizations/ Companies. On this level the Organizations can be linked to the European Sustainability Platform. Level 4: It is intended for Organizations/ Companies that do have a systematic approach on the issues of Sustainable Development and Corporate Responsibility. These are usually, but not always, medium and large Organizations/ Companies. On this level the Organizations can be linked to the European Sustainability Platform. *Level 1 and 2 – it may not use the “explain/reasoning” approach for more than 1 criterion *Level 3 and 4 – it may not use the “explain/reasoning” approach for more than 2 criteria

No matter of its size ,each Organization can choose its preferable level of conformity and each

consecutive year depending on its development it can move on to an upgraded level of

conformity.

QNF - RNE 12

In this way the Greek Sustainability Code offers guidance to the Organizations in the

development of a systematic approach on the issues of Sustainable Development and

Corporate Responsibility and in parallel helps smaller and less mature Organizations on the

issues of sustainability Organizations to present their progress on the Electronic Platform of

the Greek Sustainability Code.

On an annual basis, each Organization that wants to adopt policies or Strategy on Sustainable

Development and Corporate Responsibility issues, is called upon to declare its conformity to

the criteria of the Code (to the 5, 10, 15 or 20 depending on the level of its maturity on

sustainability issues) and present on the Electronic Platform of the Greek Sustainability

Code its activities showing compliance to each criterion or to explain the reasons why it

cannot conform to a certain criterion.

For each criterion that the Organization conforms with, it is called upon to present its

approach, its annual performance and the credibility of the information it provides.

Respectively, for each criterion the Organization does not conform with, it has to present its

approach on why it could not conform to a certain criterion and its possible commitment to

conform with in the future as well as the credibility of the information it provides.

QNF - RNE 13

2.3 HOW TO COMPLETE THE GREEK SUSTAINABILITY CODE

The information required per criterion is presented on the following figure.

Given the fact that the majority of Organizations in Greece and in international level also that

present annual reports of Sustainable Development and Corporate Responsibility follow the

guidelines of the Global Reporting Initiative, in the unit “Performance Indicators” that follows

relevant performance indicators according to GRI/G4 are presented in order to facilitate the

Organizations that already uses or advise these indicators. It is underlined that the indicators

are indicative and that the full conformity of an Organization with a certain indicator does

not ensures the conformity to the best to degree with regards to the demands of each

criterion of the Greek Sustainability Code.

For a more complete substantiation of the criteria on the Sustainable Development that are

given by an Organization, more sector-specific indicators relating to the special

characteristics of the business activity of each Organization can be used.

2.4 DECLARATION OF CONFORMITY TO THE GREEK SUSTAINAILITY

CODE

The Declaration of Conformity to the Greek sustainability Code is the annual report of each

Organization presenting its degree of conformity to the criteria of the Greek Code. The

Conformity Declaration is submitted electronically via the Electronic Platform of the Greek

sustainability Code.

The Declaration of Conformity includes descriptive texts and performance indicators that are

accompanied by numbers. The Declaration of Compliance follows the principle “comply or

explain” as follows: the Organizations choose the Level of implementation they desire to

QNF - RNE 14

respond and be linked with. Then, the Organizations post their conformity or explain every

deviation from the criteria of the Greek Code in the case they do not have at their disposal

the collective data or information required to complete each criterion per level.

The Declaration of Conformity has to be so long as necessary and so small so as the readers

focus on the essential parts.

The indicative indicators drawn from a wide range of indicators of the international standard

GRI/G4 and the additional indicators per business sector are the key to understand each

business area as well as the exceptional challenges of the Sustainable Development.

For each criterion the Organization complies with, it is called to present its action in a form

with 3 fields as follows. The content of each field is presented on the figure under paragraph

2.3.

Approach

Performance

Credibility

For each criterion the Organization does not comply with, it is called to submit its method on a form with two fields as follows.

QNF - RNE 15

Approach

Credibility

In case the Organization publishes other relevant reports or annual reports on Sustainable Development and Corporate Responsibility, it can opt to include in the forms references to specific points of those reports. However, it is not suggested to include data from already published Annual Reports on Sustainable Development because in this way the added value of the Declaration of Conformity is annulled.

The Declaration of Compliance is a unified and structured documentation text on Sustainable Development and Corporate Responsibility issues addressed to the Social Stakeholders.

Each Organization can retrieve the total of information that it has filled in the forms of the

Electronic Platform of the Greek Sustainability Code in a pdf format file that is the annual

Declaration of Conformity in the Greek Sustainability Code and can be used as an

independent annual report on Sustainable Development and Corporate Responsibility

proving its level of sustainability to each interest party.

QNF - RNE 16

2.5 Compatibility version of the Declaration of Conformity with the Greek

Sustainability Code

The Compatibility of the Declaration of Conformity with the Greek Sustainability Code allows to

Organizations that already publish annual reports according to the GRI/G4 or other standards to

submit the Declaration of Conformity in the Greek Code with the minimum effort.

The Organizations have the option to note in each field that they publish the required data on other

official reports and make a relevant reference (for example specific pages of the other reports,

electronic links etc).Such references may include files/publications/information that involve the

following:

Global Reporting Initiative, GRI/G4

UN Global Compact - Communication on Progress

OECD Guidelines for Multinational Enterprises, Revision 2011

ISO 26000

Eco-Management and Audit Scheme, EMAS (EU Regulation 1221/2009)

CDP (former Carbon Disclosure Project)

International Integrated Reporting Framework, IIRC (integrated reporting)

Sustainability Accounting Standards Board, SASB

Greek Code of Corporate Governance (Law 3873/2010, Greek Council on Corporate Governance,

October 2013)

With the purpose of increasing the legibility and comparability of the Declarations of Conformity, it is

suggested that the Organizations make a briefing of the main points in order to ensure focus on the

substantial issues and the transparency of the Declaration of Conformity.

In case the Organization publishes other relevant reports or annual reports on Sustainable Development and Corporate Responsibility, it can opt to include in the forms references on specific points of those reports. However, it is not suggested to include data from already published Annual Reports on Sustainable Development because in this way the added value of the Declaration of Conformity is annulled.

The Declaration of Compliance is a unified and structured documentation text on Sustainable Development and Corporate Responsibility issues addressed to the Social Stakeholders.

The other way round, it is advised that the Organizations include in their Sustainable Development and Corporate Responsibility Annual Reports a correlation index/table of conformity to the criteria of the Greek Sustainability Code using as a model the correlation index/table GRI/GR4 of the UN Global Compact.

2.6 PERFORMANCE INDICATORS

The performance indicators are used in order to facilitate the publication The tables below present a selection of Indicators drawn from the Global Reporting Initiative – GRI/G4 that are well-established and used in practice. On the Greek Sustainability Code the participant Organizations can publish their data according to the standard of the GRI/G4 Indicators. They can also add voluntarily sector-specific indicators.

QNF - RNE 17

The definition and calculation of the indicators are explained below.

Strategy: criterion 1 Strategic Analysis & action

G4-2 Key impacts, risks and opportunities of an Organization.

Strategy: criterion 2 Materiality

G4-19 All the material Aspects identified in the process for defining report content.

G4-20 For each material Aspect, the Aspect Boundary within the organization is reported, as follows:

• Report whether the Aspect is material within the organization

• Report any specific limitation regarding the Aspect Boundary within the organization

Strategy: criterion 3 Objectives

G4-2 Key impacts, risks and opportunities of an Organization.

Strategy: criterion 4 Depth of the Value Chain

G4-12 Describe the organization’s supply chain.

G4-21 For each material Aspect, the Aspect Boundary outside the organization is reported, as follows:

• Report whether the Aspect is material outside of the organization.

• Report any specific limitation regarding the Aspect Boundary outside the organization.

Process Management: criterion 5 Responsibility

G4-56 An Organization’s values, principles, standards and norms of behaviour such as codes of conduct and codes of ethics.

Process Management: criterion 6 Rules & Processes


Process Management: criterion 7 Control


Process Management: criterion 8 Incentive Systems

G4-51a Remuneration policies for the highest governance body and senior executives.

G4-54 Ratio of the annual total compensation for the organization’s highest-paid individual in each country of significant operations to the median annual total compensation for all employees (excluding the highest-paid individual) in the same country.

QNF - RNE 18

Process Management: criterion 9 Stakeholder Engagement

G4-27 Key topics and concerns that have been raised through stakeholder engagement, and how the organization has responded to those key topics and concerns, including through its reporting. Report the stakeholder groups that raised each of the key topics and concerns.

Process Management: criterion 10 Innovation & Product Management

G4-EN5

Energy intensity.

G4-EN6 Reduction of energy consumption.

Environment: criterion 11 Usage of Natural Resources

G4-EN1 Materials used by weight or volume.

G4-EN3 Energy consumption within the organization.

G4-EN7 Reduction in energy requirements of products and services.

G4-EN8 Total water withdrawal by source.

G4-EN23 Total weight of waste by type and disposal method.

Environment: criterion 12 Resource Management

G4-EN1 Materials used by weight or volume.

G4-EN3 Energy consumption within the organization.

G4-EN7 Reduction in energy requirements of products and services.

G4-EN8 Total water withdrawal by source.

G4-EN23 Total weight of waste by type and disposal method.

Environment: criterion 13 Climate-Relevant Emissions

G4-EN15 Direct greenhouse gas (GHG) emissions (Scope 1).

G4-EN16 Energy-related indirect greenhouse gas (GHG) emissions (Scope 2).

G4-EN17 Other indirect greenhouse gas (GHG) emissions (Scope 3).

G4-EN18 Greenhouse Gas (GHG) emissions intensity.

G4-EN19 Reduction of greenhouse gas (GHG) emissions.

Society: criterion 14 Employment Rights

G4-LA6 Type of injury and rates of injury, occupational diseases, lost days and absenteeism, and total number of work-related fatalities, by region and by gender.

G4-LA8 Health and safety topics covered in formal agreements with trade unions.

G4-LA9 Average hours of training per year per employee, by gender and by employee category.

G4-LA12 Composition of governance bodies and breakdown of employees per employee category according to gender, age group, minority group membership, and other indicators of diversity.

G4-HR3 Total number of incidents of discrimination and corrective actions taken.

QNF - RNE 19

Society: criterion 15 Equal Opportunities






Society: criterion 16 Qualifications






Society: criterion 17 Human Rights

G4-HR1 Total number and percentage of significant investment agreements and contracts that include human rights clauses or that underwent human rights screening.

G4-HR9 Total number and percentage of operations that have been subject to human rights reviews or impact assessments.

G4-HR10 Percentage of new suppliers that were screened using human rights criteria.

G4-HR11 Significant actual and potential negative human rights impacts in the supply chain and actions taken.

Society: criterion 18 Corporate Citizenship

G4-EC1 Direct economic value generated and distributed.

Society: criterion 19 Political Influence

G4-SO6 Total value of (financial and in-kind) political contributions made directly and indirectly by the organization by country and recipient/beneficiary.

Society: criterion 20 Conduct that Complies with the Law and Policy

G4-SO3 Total number and percentage of operations assessed for risks related to corruption and the significant risks identified.

G4-SO5 Confirmed incidents of corruption and actions taken.

G4-SO8 Monetary value of significant fines and total number of non monetary sanctions for non-compliance with laws and regulations.

QNF - RNE 20

3. ANSWERS TO FREQUENTLY ASKED QUESTIONS

1. What is the Greek Sustainability Code and its goal?

The Greek Sustainability Code aspires to be a practical tool for inclusion of the Sustainable

Development and Corporate Responsibility principles in the operation of the Organizations. Through

its structure it serves the necessity for adoption of visibility, transparency and accountability

principles, meaning showing all interest parties of an Organization (for example customers,

suppliers, employees, NGOs, institutions, business and economic analysts) of how conscious is of the

necessity for responsible management and operation.

The Greek Code uses 20 criteria to highlight the environmental, social and economical aspects of

Sustainable Development, making it a user-friendly guide for all the Organizations that are about to

start their effort to adopt the principles of Sustainable Development and Corporate Responsibility.

The Organizations through the annual reports on their performance demonstrate their approach on

the Sustainable Development and Corporate Responsibility issues. The information and data given

will be available to all interest parties in the Electronic Platform of the Greek Sustainability Code.

The Organizations that participate in the Greek Sustainability Code depending on their maturity level

they will also be linked to the European Sustainability Code.

The Greek Sustainability Code is based on international standards and draws on know-how from the

respective German Sustainability Code that has been developed by the German Council for

Sustainable Development (RNE) taking into consideration the particularities of the Greek market, the

size of the Organizations and their maturity level.

2. What are the characteristics of the Greek Sustainability Code

It supports the linkage of the Organizations with the issues of Sustainable Development and

Corporate Responsibility. It uses well-established methodology as a practical framework for

the submission of reports on Sustainable Development and Responsible Management.

It is a tool for internal management improvement of an Organization in terms of its approach

on the issues of Sustainable Development and Corporate Responsibility.

It provides the investors with information and can be used as a means of assessment and

comparison of the Organizations results taking into consideration non-financial data per

criterion.

It is in line with the dictates of the Directive of the European Commission for the disclosure

of non-financial data.

It creates a “responsible supplies” framework through which each Organization demands a

comparative advantage on the management of its suppliers’ network.

It showcases the image of the Organization as a “responsible business civilian” vis-à-vis the

government and social institutions as well as the customers-consumers.

QNF - RNE 21

3. What is the method of development of the Greek Sustainability Code?

The Greek sustainability Code is one of the main deliverables of the Sustainable Greece 2020

Initiative. Its harmonization with the Greek reality and evidence has started through a dialogue

process with the Committee for the Development of the Greek Sustainability Code which consisted

of representatives of institutions and businesses and executives of companies. The Committee

created the first edition of the Greek Sustainability Code attempting to adapt the European

methodology to the needs of the Greek market.

The fruit of this work will be put into an open consultation process in order that the Greek

sustainability Code takes its final form. The consultation and dialogue process will take place from 9th

February to 29th February, 2016.

The final edition of the Greek Sustainability Code will be presented to the Greek market on the 7th of

April, 2016.

4. What makes the Greek Sustainability Code a practical tool for the adoption of Sustainable

Development & Corporate Responsibility principles?

The Greek sustainability Code is a useful tool since, through its 4 pillars relating to the operation of all

kinds of Organizations and its 20 criteria that cover a holistic approach on sustainability, it gives

guidance to Organizations on how to approach and adopt in an easy to understand way the

Sustainable Development and Corporate Responsibility principles.

It takes into consideration the international trends on the Sustainable Development and Corporate

Responsibility issues and the operational systems adopted by the Organizations. It is structured in

way to be comprehensible to executives of Organizations, asking them to present their approach

(through policies, operational and management systems and procedures), the performance of the

Organizations and the credibility of the information they provide.

5. What are the levels of participation in the Greek Sustainability Code?

The Greek Sustainability Code adapts to the particularities of the Greek market in terms of the size of

the Organizations/Companies by using successive levels. Thus, each Organization that desires to be

linked with Sustainable Development and Corporate Responsibility issues can participate in the

Greek platform of sustainability, filling in on the different levels of the Greek Sustainability Code

depending on the degree of maturity of its internal management and procedures. For this reason, we

invite all the Organizations no matter of their size to get linked with the issues of Sustainable

Development and Corporate Responsibility through a systematic approach and procedures that each

Organization already implements and can vary depending on the legal or regulative context applied.

QNF - RNE 22

6. What are the steps of participation of an Organization in the Greek Sustainability Code?

Promoting the systematic way of participation of each Organization in the Greek Sustainability Code,

the Greek Code has taken into consideration the operational and management systems already in

use by each Organization. Consequently, the Organizations are invited to participate in the Greek

code following the 3 steps:

STEP 1: Choosing the criteria and the level of implementation which they want to respond and to be

linked with

STEP 2: Presenting the way they conform by giving information on their approach and performance

on each criterion.

STEP 3: Elaborating on the assurance procedures for the credibility of information they give on each

criterion.

7. To whom the Greek Sustainability Code addresses?

The Greek Sustainability Code is addressed to all Organizations of private and public sector

(Companies, public Institutions, Universities, Local Administration authorities and NGOs) of different

size that they are interested in including policies of Sustainable Development and Corporate

Responsibility in their operation and management.

The Greek Sustainability code has been developed in a way to cover all kinds of size and maturity

level Organizations. In this way, every Organization can find the level it can promptly responds to.

Then, it can aim at and put effort towards further maturity and improvement on the issues of

sustainability.

8. Why an Organization that publishes a Report on sustainability should participate in the Greek

Code?

The participation of an Organization that already reports on Sustainability is suggested for the

following reasons:

QNF - RNE 23

Simplified approach on the issues of Sustainable Development and Corporate

Responsibility. The Reports on Sustainability cover a wide range of information thus, less

readers than an Organization would desire read them. Moreover, the information provided

on those reports is not easily understood by common users.

Meet the demands of the financial market. The representatives of the capital and financial

market increasingly tend to choose performance indicators that cover criteria that clearly

and in brief present the necessary information showing the performance of an Organization

on the issues of sustainable Development and Corporate Responsibility.

Connection with the already published data. The Greek Code offers the option to

Organizations that already report on Sustainability to complete the required information for

the Declaration of Conformity providing references to already published data in order to

avoid duplication.

Connection with the European Platform for Sustainable Development. The Organizations

that already report on sustainability on the Levels 3 and 4 of the Greek Sustainability Code,

they become automatically members of the European Platform of Sustainable

Development- The Sustainability Code. In this way the Organization presents its

performance on European level reinforcing its corporate credibility and reputation.

9. Why an Organization has to report on performance relating to Sustainable Development and

Corporate Responsibility?

The Organization share common responsibility for the Sustainable Development and should

document publically on the way they meet this responsibility.

The Capital market makes more and more use of this information in order to assess the opportunities

and the risks of the investments or the loans.

Moreover, the accountability of the Organizations with regards to their performance on the issues of

Sustainable Development and their Corporate Responsibility on supply chain issues is of critical

importance for the attraction of customers, the increase of exports and the reinforcement of their

competitiveness and openness.

Furthermore, more and more consumers demand the responsible operation and management of

Organizations and responsible products/ services.

The public report on the performance of an Organization also has great impact on the Organization

itself: the redaction of a Report does not only demand the collection of information but their close

examination and analysis. In this way the flaws are revealed as well as the unexploited chances. A

very important benefit is that the human workforce is made conscious of the Sustainable

Development and Corporate Responsibility issues and is motivated to contribute towards this goal.

Finally, the Organizations present how good is their cooperation with the government and the

society towards a form of development that is sustainable as a whole. Everyone is a partner in this

mission.

QNF - RNE 24

10. Why comparability is important

Society’s interest for responsible management and operation of an Organization is constantly

increasing. However, they way the information is processed so far it makes it difficult or impossible

for a user to find out the way an Organization is operating compared to others.

In the labyrinth of frequently long reports on Sustainable Development it is usually difficult to discern

the substantial issues. This is not only a problem of the investors. Asking all the Organizations to

respond to the same 20 criteria, the readers can quickly and easily take a glance at the differences in

the quality of the given information. Consequently, the published information becomes more

transparent and reliable.

11. Reasons why an Organization should participate in the Greek Code of Sustainability while there

are already enough standards for reporting such as the OECD Guidelines, ISO 26000, the Global

Reporting Initiative, GRI/G4 and the UN Global Compact

These and other initiatives provide international standards for reporting and management. The

Greek Sustainability Code is based on these and can on its turn become a basis for others. It

downsizes the complicated demands to the essence. The Greek Code is a tool for all Organizations

revealing the degree of integration and implementation of the Sustainable Development and

Corporate Responsibility principles in their operation in a more practical and straightforward way.

The Organizations can use it to make a clear statement. Additionally, the Greek Code as a first step

can help the small and medium enterprises to report on sustainability according to the above

mentioned standards.

On the other way round, the Greek Code can be linked to all these standards.

The Greek Code offers the option for Organizations that conduct other relevant reports to complete

the required data for the Declaration of Conformity providing references to already published data

avoiding duplication. In this way, an Organization can fully cover the demands of the Greek Code.

(The present question relates both to the European Platform of Sustainable Development-The

Sustainability Code and the Greek Sustainability Code).

12. What is the relevance of the Greek Sustainability Code to UN Global Compact?

The Organizations that participate in the UN Global Compact can also use the Declaration of

Conformity of the Greek Code as a progress report on the Global Compact (COP). In order to fulfill

the minimum requirements of the Global Compact, the Declaration of Conformity has to include a

declaration from a high rank administration body of the Organization proving its constant

commitment to the Global Compact and its further efforts for the implementation and promotion of

its ten principles. (The present question relates both to the European Platform of Sustainable

Development-The Sustainability Code and the Greek Sustainability Code).

QNF - RNE 25

13. What is the role of the Greek Sustainability Code in the context of the new demands of the EU

for reporting on non-financial data disclosure?

In the amendment of the European Commission to the Directive with regards to the reporting on

non-financial data, the Sustainability Code is referenced as a suitable model for reporting for those

Organizations the Directive is relevant. Such Organizations are the public interest entities, meaning

the listed companies in the European / national stock markets, the credit institutions, the insurance

companies etc that have a workforce of 500 persons or more (July 2014). The adoption of the

Directive from the Greek parliament is under evaluation by the relevant Committee of the

parliament. (The present question relates both to the European Platform of Sustainable Development-

The Sustainability Code and the Greek Sustainability Code).

14. Whom the Greek Sustainability Code concerns?

The Greek Sustainability Code concerns a wide range of audiences that desire to be informed and

advised on the way an Organization approaches the Sustainable Development and Corporate

Responsibility issues. The main groups that can make use of the information that are presented in

the Electronic Platform of the Greek Sustainability Code are the following:

The actors of the financial market in order to identify opportunities and risks during the

assessment procedure for investments and loans.

The customers and the suppliers that are interested in the management of Sustainable

Development issues in the value chain

Public bodies in charge of Sustainable Development policymaking

NGOs and the research community that observes the implementation of policies of Sustainable

Development by the Organizations/ Companies

The administration of an Organization/Company in order to manage the sustainable

development internally and evaluate opportunities and risks.

The current and future employees of an Organization/Company that desire to work for an

Organization that exhibits complete responsibility in its operation

The supply chain of big Organizations/Companies in order to have an easy to use tool for the

“Responsible Supplies” with which they can monitor the commitments of their partners on the

issues of Sustainable Development and Corporate Responsibility.

15. How long does it takes to complete the Declaration of Conformity of the Greek Sustainability

Code with the relevant information on the annual performance of the Organization?

This depends on the level of compliance (meaning if the Organization has to respond to 5, 10, 15 or

20 criteria), how mature it is in the management of sustainability issues, if mechanisms of retrieving

information and processing of required information exist, whether new documents have to be

written or references have to be made on already processed and published material. Even if an

Organization devotes a lot of time in these procedures, it worths the effort because the Organization

realizes which strategy has to follow with regards to the Sustainable Development, the goals it has to

set and the actions required to accomplish them.

QNF - RNE 26

16. In which way an Organization can be supported in the completion of the Greek Sustainability

Code?

An Organization can be supported in the procedure of completion of the Greek Code internally by

suitably trained managers of Operational Systems, heads of Sustainable Development, Business

Communication and Social Responsibility departments of the Organizations and externally by suitably

trained and certified Consultants.

17. How the executives of the Organizations interested in participating in the Code are trained?

The executives of the Organizations that are interested in attending a certified training seminar for

the participation in and completion of the Greek Sustainability Code can contact Certifying Bodies,

Audit Companies and Organizations, approved and evaluated by the QualityNet Foundation.

Moreover, they can contact the Centers for Lifelong Learning that have to be certified by the

National Organization for the Certification of Qualifications and Vocational Guidance. The training

has to be provided by certified trainers approved by the QualityNet Foundation and with the

exclusive and approved by the QualityNet Foundation training material.

18. With what way the data the Organization submits to the Greek Sustainability Code are verified

and how the information is assessed?

Through the monitoring and verification from third parties such as the Certifying Bodies, the Audit

Companies and Organizations cooperating with the QualityNet Foundation. The auditing procedure

will be conducted according to the standard of the Greek Sustainability Code. The Organizations will

be assessed by the cooperating Bodies on the basis of their response to the Greek Code and a

conclusion on their level of Sustainable Development and Corporate Responsibility will be drawn as

well as the points to be improved will be presented.

19. Updating parts of the Declaration of Conformity

The Declaration of Conformity of an Organization has to be posted on annual basis. The annual basis

rule has to be obeyed so as the comparability of the performance of the Organizations made

possible.

The amendment of the Declaration of Conformity is possible on a later date. However, it is not

suggested except for an emergency or an important reason for example in case new basic indicators

are introduced that they were not available during the publication of the Declaration of Conformity.

20. Publication/disclosure of the Declaration of conformity on other international platforms

The Declaration of Conformity can be retrieved from the Electronic Platform of the Greek

Sustainability Code in pdf format. Each Organization can use this pdf file of its Declaration of

Conformity as an independent report in its site or in any other communication activity. Furthermore,

QNF - RNE 27

there is the possibility to post the Declaration of Conformity on the webpage of the Global Reporting

Initiative (GRI/G4) for international visibility. On this webpage the Declaration of Conformity can be

presented as GRI/G4 report in the national language. Please see the database in the following link

http://database.globalreporting.org.

http://database.globalreporting.org/

the greek sustainability code

Documents