www.thracegroup.gr
24
General Commerce Reg. No. 12512246000
Domicile: Magiko, Municipality of Avdira, Xanthi Greece
Offices: 20 Marinou Antypa Str., 174 55 Alimos, Attica Greece
ANNUAL
FINANCIAL
REPORT
01.0131.12.2024
THRACE PLASTICS CO S.A.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 2 of 370
The Group
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 3 of 370
Comprises of
14 companies
worldwide engaged in
active operations
Employs
2,197 employees
including joint ventures
Operates in
9 countries
with production, marketing, and
distribution companies
Operates
12.8 MW
photovoltaic
net metering systems
Utilizes
13,000 MT
of recycled material from
production residues and external
sources
Engages in
3 business units
Technical Fabrics
Packaging Solutions
Hydroponic agriculture
Covers
25 market
segments
with products and solutions
Develops a sales
network in
80 countries
Group’s net sales
amount to
€370 mil.
Processes over
120,000 MT
of raw materials from
polypropylene and polyethylene
Reuses up to
100%
of internally generated
production waste
Implements
28 technologies
in production processes
Supports circular economy
principles with
120 product groups
Granted
493,920€
for social support through the
Social Center
Stavros Chalioris
Produces up to
100%
recyclable products
100%
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 4 of 370
Vision
Το be the most valuable partner for our customers and suppliers
and to consistently increase shareholders’ value while ensuring a
prosperous future for all individuals working in Thrace Group.
Mission
• Adhering closely to our Group core
values: integrity, focus on results, in-
novation, flexibility, responsiveness,
cooperation, leadership.
• Investing in our people, by encourag-
ing lifelong learning, individuality, per-
sonal initiatives and self-achievement.
• Creating new business standards
through innovation and smart think-
ing, aiding our customers’ leadership
in their markets.
• Providing not just products but com-
plete & innovative solutions, tai-
lor-made upon our customers’ specific
requirements and needs.
• Acting local – being global, serving
thousands of companies worldwide
through strategic geographic disper-
sion.
• Pursuing profitability through organic
growth and strategic acquisitions.
• Achieving competitive prices through
economies of scale, vertical integra-
tion and internal synergies.
• Combining diverse high-end technol-
ogies with a long know-how and an
extensive experience in the markets
we operate.
• Respecting our global environment
and the societies where we work and
live.
• Adapting to the ever-changing market
environment and promptly adjusting
our practices to successfully meet the
global trends that will shape the future
of business, economy and society.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 5 of 370
History
1977
In 1977, Stavros Halioris founded
the company Thrace Plastics SA
in Xanthi
1995
In 1995, the company was listed
on the Athens Stock Exchange
1997 - 2014
From 1997 to 2014, companies
that now constitute the Thrace
Group were established or ac-
quired, with active commercial
and/or production activities in
the technical fabrics and packag-
ing sectors: Thrace Nonwovens &
Geosynthetics SA, Thrace Poly-
films SA, Thrace Eurobent SA (as
a joint venture), Thrace Pack SA,
Don & Low Ltd (Scotland), Thra-
ce Synthetic Packaging Ltd (Ire-
land), Thrace Ipoma SA (Bulgaria),
Thrace Greiner Packaging SRL (as
a joint venture, Romania), Thra-
ce Polybulk AB (Sweden), Thrace
Polybulk AS (Norway), Thrace
Plastics Packaging DOO (Serbia),
Lumite Inc (as a joint venture,
USA)
2013
In 2013, in collaboration with
Elastron SA, Thrace Greenhouses
were founded, utilizing the geo-
thermal fields of Xanthi
2017
From 2017, following internal re-
structuring, the company Thrace
Plastics SA continued to operate
as Thrace Plastics Holding SA
2021
From 2021, commencement of an
investment plan in photovoltaic
systems
2022
From 2022, a central recycling
line has been in operation
2023
An expansion is carried out with
a new production line for paper
packaging in Ioannina
Flexibility Responsiveness
Integrity Innovation
Collaboration Leadership Eectiveness
Values
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 6 of 370
The Group consists of 14 companies engaged in commercial and/or manufacturing ac-
tivities.
Companies Headquarters
Thrace Plastics Company SA Xanthi, Greece
Thrace Nonwovens & Geosynthetics SA Xanthi, Greece
Thrace Polyfilms SA Xanthi, Greece
Thrace Eurobent SA Xanthi, Greece
Thrace Pack SA Ioannina/Xanthi, Greece
Thrace Greenhouses SA Xanthi, Greece
Don & Low Ltd Forfar, Scotland
Thrace Synthetic Packaging Ltd Clara, Ireland
Thrace Ipoma SA Sofia, Bulgaria
Thrace Greiner Packaging SRL Sibiu, Romania
Lumite Inc Georgia, USA
Thrace Polybulk AB Köping, Sweden
Thrace Polybulk AS Brevik, Norway
Thrace Plastics Packaging DOO Nova Pazova, Serbia
Domestic and international presence
The companies Thrace Eurobent SA, Thrace Greenhouses S.A., Thrace Greiner Packaging
SRL, and Lumite Inc are joint ventures of the Group. Nevertheless, their overall data is pre-
sented in separate tables under the European Sustainability Reporting Standards (ESRS),
as they follow the same core sustainability principles as the Group.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 7 of 370
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 8 of 370
• Production and trade of synthetic
fabrics for industrial and technical
uses.
• Broad and diversified product
portfolio.
• Europe-based production with a
global footprint.
• Extensive sales network, mainly in
Europe and America.
GREECE SCOTLAND
Business sectors of activity
TECHNICAL FABRICS SECTOR
CONSTRUCTION
ROAD
CONSTRUCTION
LANDSCAPE &
GARDENING
MEDICAL &
HYGIENE
AUTOMOTIVE
DRAINAGE &
EROSION CONTROL
Applications
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 9 of 370
NORWAY & SWEDENIRELAND USA
FURNITURE &
BEDDING
SPORT & LEISURE
AGRI- / HORTI- &
AQUACULTURE
ADVANCED USE
FILTRATION
FLOOR
COVERING
INDUSTRIAL USE
Geotextiles
(woven, nonwoven)
Geogrids
Geocomposites
Fabrics
Membranes
Film
Nets
Strapes
Ropes
Yarns
Fibres
Product Families
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 10 of 370
• Production and trade of food and
industrial product packaging.
• Pioneer in the South East European
market.
• Europe-based production.
• Extensive sales network with
continuous volume growth on an
annual basis.
Business sectors of activity
PACKAGING SECTOR
INDUSTRIAL USE
(RAW MATERIALS,
CHEMICALS)
TRANSPORTATION
AGRICULTURAL USE
(FERTILIZERS)
CONSTRUCTION
PAINT INDUSTRY
FOOD
Applications
HOUSEHOLD
PRODUCTS
HORECA
HOTEL, RESTAURANT &
CATERING INDUSTRY
BULGARIA
GREECE & SERBIA GREECE
IRELAND
ROMANIA
FIBC / filling
solutions
Bags / FFS film
Packaging / pallet
covering film
Container liners /
cargo protection
Packaging fabrics
Buckets / pails /
containers
Thermoforming
cups
Crates
Bag in box
Garbage
bags
Twines
Product Families
MARKET
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 11 of 370
• The largest hydroponic greenhouses
in South East Europe.
• The only greenhouses in the world
heated exclusively by geothermal
energy.
• Greek vegetables with almost zero
CO
2
footprint.
• Cultivation based on the highest
standards.
Business sectors of activity
AGRICULTURAL SECTOR
HYDROPONIC
CULTIVATION
GEOTHERMAL ENERGY
CULTIVATION
CARE
POST-HARVEST
CARE
PACKAGING
DISTRIBUTION
Applications
PRODUCT
ON THE SHELF
Cluster
Tomato
Mini
Cucumber
Eggplant
Mini Tomato
500gr
Beef
Tomato
Cucumber
Mini Cucumber
600gr
Mini Cucumber
750gr
Product Families
MARKET
www.thracegroup.gr
ANNUAL
FINANCIAL REPORT
1st January - 31st December 2024
THRACE PLASTICS CO S.A.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 14 of 370
Information regarding the preparation
of the Annual Financial Report
for the period from January 1
st
to December 31
st
2024
The present Financial Report, which concerns the period 01.01.2024 to 31.12.2024, was
prepared in accordance with the provisions of article 4 of Law 3556/2007 (Government
Gazette 91A’/30-04-2017), Law 4548/2018 and the relevant decisions issued by the Board
of Directors of the Hellenic Capital Market Commission under Reg. No. 8/754/14-4-2016
as amended by the decisions 12A/889/31-08-2020 and 10B/1038/30, as well as by the Cir-
cular under the protocol no. 62784/06-06-2017 of the Division of Enterprises and GEMI
of the Ministry of Finance, Development and Tourism. The present Report was approved
unanimously by the Board of Directors of “THRACE PLASTICS CO S.A.” (“Company”) on
April 24, 2025, has been posted on the Company’s website www.thracegroup.gr where
such will remain available to investors for a period of at least (10) ten years from the pub-
lication date and includes:
CONTENTS
Ι. STATEMENTS BY REPRESENTATIVES OF THE BOARD OF DIRECTORS 15
ΙΙ. ANNUAL REPORT BY THE BOARD OF DIRECTORS OF THRACE PLASTICS CO S.A.
ON THE FINANCIAL STATEMENTS OF THE YEAR FROM 01012024 TO 31122024 16
ΙΙΙ. AUDIT REPORTS BY INDEPENDENT CERTIFIED AUDITOR 263
IV. ANNUAL FINANCIAL STATEMENTS FOR THE PERIOD 1.1.2024  31.12.2024 275
V. ONLINE AVAILABILITY ON THE INTERNET 367
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 15 of 370
THE UNDERSIGNED:
I. STATEMENTS BY REPRESENTATIVES OF THE
BOARD OF DIRECTORS
(according to article 4 par. 2 of L 3556/2007)
The Chairman of
the Board of Directors
The Chief Executive Officer
& Executive Member of
the Board of Directors
The Non-Executive
Member of the Board of
Directors
Konstantinos St. Chalioris Dimitris P. Malamos Vasileios S. Zairopoulos
We, the representatives of the Board of Directors, hereby state and confirm that to our
knowledge:
(a) The Annual Financial Statements (Stand-alone and Consolidated) of the Company,
which concern the period from January 1st 2024 to December 31st 2024, were pre-
pared in accordance with the International Financial Reporting Standards as adopted
by the European Union, accurately and fairly present the Assets and Liabilities, Equity
and Financial Results of the Year of the Company, as well as those of the consolidated
companies and considered aggregately as a whole, and
(b) The Annual Management Report of the Board of Directors accurately and fairly pre-
sents the development, performance and position of the Company as well as of the
companies included in the consolidation and considered aggregately as a whole, in-
cluding the respective description of the main risks and uncertainties. The Report
was prepared in accordance with the Sustainability Reporting standards presented
in the article 154A of Law 4548/2018 and pursuant to paragraph 4 of article 8 of Regu-
lation (EU) 2020/852 of the European Parliament and of the Council as at 18 June
2020, concerning the establishment of a framework for facilitating sustainable invest-
ment and for amending the Regulation (EU) 2019/2088.
Xanthi, 24 April 2025
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 16 of 370
II. ANNUAL REPORT BY THE BOARD OF
DIRECTORS OF THRACE PLASTICS CO S.A.
ON THE FINANCIAL STATEMENTS OF THE
YEAR FROM 01-01-2024 to 31-12-2024
INTRODUCTION
The present Annual Report by the Board
of Directors (hereinafter called as “Re-
port”) refers to the fiscal year 2024
(01.01.2024 – 31.12.2024). The Report was
prepared in accordance with the relevant
provisions of Law 4548/2018 (GOV. GAZ.
104A΄/13.06.2018) as currently in force
and of Law 3556/2007 as in effect follow-
ing its amendment from Law 4374/2016
and 5164/2024, as well as the relevant
executive decisions issued by the Board
of Directors of the Hellenic Capital Mar-
ket Commission, and especially the deci-
sions with number 1/434/03.07.2007 and
8/754/14.04.2016, as the latter is valid after
its amendment by the decision with num-
ber 12A/889/31.08.2020 and 10B/1038/30
of the Board of Directors of Hellenic Capi-
tal Market Commission and decisions
434/24.02.2025 & 506/07.03.2025.
The Report includes the total required by
law information (financial and non-finan-
cial information) with a concise as well as
comprehensive, objective and adequate
manner and with the principle of provid-
ing the complete and substantial informa-
tion with regards to the issues included in
such.
Given the fact that the Company pre-
pares consolidated and non-consolidated
(stand-alone) financial statements, the
present Report constitutes a single report
referring mainly to the consolidated fi-
nancial data of the Company and its sub-
sidiaries or affiliates. Any reference to non-
consolidated financial data takes place in
certain areas, which have been deemed
as necessary by the Board of Directors of
the Company for the better understanding
of the contents of the report and towards
providing investors with the most com-
plete information.
It is noted that the present Report includes,
along with the 2024 financial statements,
the required by law data and statements
in the Annual Financial Report, which con-
cern the financial year ended on 31 De-
cember 2024.
The sections of the present Report and the
contents of such are in particularly as fol-
lows:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 17 of 370
SECTION 1: Significant events that took place during the financial year 2024
Below, the most significant events that took place during the fiscal year 2024 are pre-
sented:
Macroeconomic Environment, Performance and Prospects of the
Group, Climate Issues and Expected Credit Losses
2024 was another year in which European
economies exhibited very low or even
negative growth rates. Both unfavorable
macroeconomic conditions (inflation, in-
creased interest rates, high prices) and ge-
opolitical factors persisted throughout the
year. Generally, demand did not improve
and remained weak, particularly in the
second half of the year and especially in
the technical fabrics segment, resulting in
the compression of average selling prices.
In terms of costs, raw material prices in-
creased for most months, with mild fluc-
tuations, which contrasted with the de-
clining demand that drove average selling
prices lower. Additionally, in all European
countries, including Greece, labor costs
have been rising, while energy costs sig-
nificantly increased in the second half of
the year, particularly in Greece, despite
the substantial contribution of Renewable
Energy Sources, creating an unexpected
market condition. Lastly, transportation
costs also increased, although this phe-
nomenon was short-term. These factors
have been and continue to be characteris-
tic of European economies, where overall,
both current conditions and European Un-
ion policies and regulatory requirements
burden European industries and ultimate-
ly reduce their competitiveness.
Regarding the primary markets to which
the Group’s products are mainly directed,
the construction sector in Europe persists
in operating at depressed levels, except for
Greece. However, the current demand for
new homes in Central Europe and the Unit-
ed Kingdom remains exceptionally high,
so the sector is expected to recover sig-
nificantly in the coming years. The large-
scale projects sector remains stable, while
the agricultural sector, after three years
of recession, showed signs of recovery in
2024, although it has not yet returned to
pre-recession levels. The industrial sector
in Europe, which is a key target sector for
the Group’s products, is subject to consid-
erable pressure and in conjunction with
elevated cost structures, resulted in the
compression of profit margins, while the
automotive industry within Europe contin-
ues to be in a state of recession.
With regard to the Group’s areas of activ-
ity, low demand persisted in the Technical
Fabrics segment during the fourth quarter
of the year, affecting the average selling
prices across most product categories.
Conversely, the Packaging segment main-
tained a consistently elevated level of de-
mand.
I. Group’s performance during the
fourth quarter of 2024
In particular, during the fourth quarter of
2024, the following were observed:
• Consistently weak demand for prod-
ucts in the construction sector, yet an
increase in the Group’s sales volumes,
resulting in an augmented market
share.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 18 of 370
• Satisfactory demand for products re-
lated to the infrastructure sector and
to the large-scale construction pro-
jects, albeit lower than anticipated
during the latter half of the fiscal year.
• Increased demand for products per-
taining to the agricultural segment
in comparison to the preceding fiscal
year, albeit at generally depressed lev-
els.
• Increased demand for products relat-
ed to food packaging sector.
• Consistent demand for products re-
lated to paint packaging sector.
• Increase in raw material costs, com-
pared to selling prices.
• Increased energy costs across the ma-
jority of operating countries, with a
particularly pronounced increase in
Greece during the final fiscal quarter
of the year.
• Increased transportation costs, with
improvements in delivery times.
• Stabilization of the cost of auxiliary
raw materials and packaging materi-
als.
• Decreasing borrowing interest rates,
as reductions by the ECB continued.
From a financial perspective, Turnover
amounted to €370.4 million in 2024, com-
pared to €345.4 million in the previous
year, posting an increase of 7.2%. This sig-
nificant increase was essentially the result
of increased sales volumes, which reached
120.7 thousand tons in 2024, compared
to 109.7 thousand tons in 2023, marking
a 10% increase. The increase in volumes
was a key target for 2024, and its achieve-
ment demonstrates the Group’s ability to
expand its market shares in its operating
markets, notwithstanding the particularly
low rates of economic expansion observed
across the respective national economies.
Simultaneously, the significant increase in
sales volume is the result of the continu-
ously improved product portfolio, based
on new investments made, allowing ac-
cess to new markets, geographical areas
and product categories, while creating
conditions for a higher quality and more
sustainable production process.
It should be noted that weak demand in
markets and significantly troubled Eu-
ropean economies did not allow the in-
creased costs to be passed on to selling
prices, especially in the second half of the
year. It is emphasized that the increase
in industry costs (e.g. labor costs, energy
costs) is mainly caused by external factors,
which to some extent distort the market
and compress the profitability of Europe-
an industries.
Under these conditions, the Management
of Thrace Group took a series of actions in
2024, successfully maintaining the Group’s
competitiveness to the highest possi-
ble degree, continuously gaining greater
market share, managing to increase the
Group’s sales reaching approximately 121
thousand tons, mitigating the impact of
the aforementioned circumstances on its
operating profitability. Specifically: (a) it
continues implementing its strategy of fo-
cusing on secondary conversion to gradu-
ally increase “value-adding” products, (b)
it invests in new technologies, in order
to reduce production costs, increase pro-
duction capacity but mostly to improve
its production capabilities, both in manu-
facturing techniques (e.g. new secondary
conversion technologies) and in product
portfolio expansion (e.g. a new line for
packaging films), (c) it invests in energy
self-production, improving costs (as much
as possible) and reducing its environmen-
tal footprint, (d) it consistently expands
into new markets, both in terms of new
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 19 of 370
product portfolio offered and geographi-
cally, (e) it reevaluates its activities and pro-
duction processes, making corrective ac-
tions where necessary, such as ceasing the
artificial grass production at its subsidiary
in Scotland, resulting in a short-term nega-
tive impact on the year’s financial results
but yielding long-term benefits.
However, in terms of operating profitabil-
ity, the Group was unable to maintain the
same levels compared to the previous year,
as the adjusted EBITDA amounted to €42.3
million, compared to €44 million in 2023,
showing a decrease of 4%. The mismatch
between raw material costs and average
selling prices, combined with the burden
on the industry’s cost base (inflation, labor
costs, energy costs), observed throughout
the European Union, as expected, signifi-
cantly impacted the Cost of Sales and had
a negative effect on the Group’s operating
profitability. Consequently, the Group’s
operating profitability displayed similar
characteristics to those of the majority of
European industries. However, the Group
experienced only a marginal decline, as,
during 2024 and the first months of 2025,
European industries continued to struggle
with high costs, companies or plants in Eu-
rope cease operations, causing a new mar-
ket condition (re-balancing), within which
Thrace Group is adapting and continuous-
ly strengthening itself.
It must be noted that one of the primary
factors influencing the performance of the
financial results was the Group’s subsidi-
ary, Don & Low, which significantly under-
performed in comparison to the preceding
year, a consequence of particularly weak
demand in the United Kingdom and el-
evated production costs. The Group, com-
mencing from the end of 2024, is imple-
menting a comprehensive restructuring
plan for the company with the objective of
substantially improving its trajectory. This
plan encompasses the consolidation of the
management of individual operations with
Greek subsidiary, a revised approach to the
UK market, measures to reduce operating
costs, and, as previously mentioned, the
cessation of artificial grass production.
It should also be clearly noted that, in any
case, despite the negative conditions, in
absolute terms, the Group remains sig-
nificantly profitable and strong, gaining
increasing market shares in its operating
countries, strengthening its commercial
position.
Regarding the Group’s liquidity levels and
the transactional cycle of its subsidiaries,
there was no negative impact or change
during the fourth quarter of the year. Spe-
cifically, the Group’s Net Debt amounted
to €34.4 million. The significantly low level
of Net Debt demonstrates the Group’s
strong financial position, the quality of its
customer portfolio, which allow it to invest
and distribute dividends, while maintain-
ing low Net Debt levels.
At the same time, as previously mentioned,
the investment plan for the year was com-
pleted, while during the second half of
the year, the implementation of the 2025
investment plan, amounting to €30 million
on a cash basis, was studied and initiated.
These investments are being made in the
Group’s facilities in Greece and abroad,
across both business segments.
II. Prospects of the Group
Starting the new year, markets and econ-
omies continue to exhibit comparable
characteristics to the second half of 2024.
Inflation persists at the European level,
raw material prices show upward trends
but with signs of easing by the end of the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 20 of 370
first quarter of 2025, while energy and pay-
roll costs remain high, with new increases
in the minimum wage in several European
countries, including Greece.
At the same time, geopolitical challenges
persist, although efforts are being made
to mitigate them. Finally, the change in po-
litical leadership in the USA is shaping new
geopolitical conditions on a global scale,
while recent fluctuations regarding the
imposition of tariffs by the United States
have engendered instability in global com-
merce. This practice, apart from uncertain-
ty, may potentially create new opportuni-
ties for European industry, provided that
appropriate countermeasures are chosen
to improve market conditions.
For the first quarter of 2025, the Group’s
operating profitability (EBITDA) will show
a shortfall, initially estimated at the level of
20%-25%, compared to the first quarter of
2024, which is essentially expected, as both
raw materials and especially energy costs
are at significantly higher levels, while the
first quarter of 2024 was at much lower lev-
els. (in the first quarter of 2025 the energy
cost demonstrated an increase at the level
of €2.5 mil. compared to the correspond-
ing period of 2024).
Regarding 2025, the uncertainty that has
developed, as well as the new market con-
ditions following the recent imposition of
tariffs by the USA, make it very difficult
to estimate the Group’s annual operating
profitability (EBITDA). However, based on
the annual planning, if current conditions
remain unchanged, it is estimated that
overall the Group’s operating profitability
will exceed the levels of 2024.
The Group’s Management is monitoring
market developments to be able to im-
plement the necessary actions to stay on
track with its plan. In any case, the Group
remains financially strong and capable of
both facing any adverse market conditions
with minimal impact and implementing its
long-term strategic plan aiming at further
growth, while Management remains opti-
mistic about the Group’s trajectory in the
coming months and overall for the year.
III. Climate issues
All information regarding climate-related
issues concerning the Group is detailed
in the Group’s Sustainability Statement
in Section 2. Environmental Information,
Chapter ESRS E1. Climate Change. (see
section 8 of this report).
IV. Expected credit losses
There are no expected important credit
losses as a result of the current conditions
and circumstances. In any case, according
to the established policy, a big part of the
companies’ sales remains insured, while
additional measures have been taken to
ensure the Group carries out transactions
with reliable customers (credit risk
assessment, credit scoring, advances,
etc.). More information on credit risk can
be found in note 3.16.3 of the financial
statements.
Direct Impact from Geopolitical Conditions
The crisis in the Middle East has created
geopolitical instability and, in any case,
uncertainty regarding potential macro-
economic consequences. The Group does
not have significant direct business ac-
tivities in the affected regions, specifically
areas directly impacted by the conflicts.
The overall exposure to Israel, Iran and
Palestine is minimal, as, based on the 2024
figures, sales in these countries accounted
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 21 of 370
for 0.26% of the Group’s total sales. At the
same time, the ongoing military conflict
following the Russian invasion of Ukraine
continues to create geopolitical instabil-
ity with adverse macroeconomic conse-
quences, which the company faces on a
day-to-day basis and are mainly related
to increase in a series of raw materials and
products. The above conditions create an
environment of great uncertainty affect-
ing the level of demand especially in Eu-
rope. The Group does not have significant
direct business activities in Ukraine and
in Russia, i.e. in the areas directly affected
by the war. Furthermore, the overall ex-
posure to Ukraine and Russia is minimal.
Based on the financial results of 2024, sales
in these two countries stood at 0.81% of
the Group’s total turnover (for 2023, corre-
sponding sales had stood at 0.55% of total
Group sales).
Therefore, no immediate significant im-
pact on the Group’s financial performance
is expected due to the aforementioned ge-
opolitical developments concerning sales
to customers. However, the negative and
long-lasting evolution of the conflict along
with the wider and unfavorable macro-
economic repercussions might potentially
have a negative effect on the activities of
all businesses and companies operating
in Europe and therefore on the business
activities of the Group. The Group’s Man-
agement closely monitors the relevant de-
velopments and if needed will undertake
a series of actions to weather any negative
consequences, should they arise.
Announcement of Market Maker
The Listings and Market Operations Com-
mittee of the Athens Stock Exchange,
based on its respective decision that was
recorded during the meeting of 21st March
2024, approved the appointment of the
Member of Athens Exchange “LEON DEPO-
LAS INVESTMENT SERVICES S.A.” as Market
Maker of the Company’s shares in an effort
to boost their liquidity and marketability.
At the same time, the Athens Exchange set
Thursday, 28 March 2024, as the date for the
beginning of the market making activity.
The Company has signed, according to the
provisions of articles 1.3 and 2.4 of the Ath-
ens Exchange Regulation, a contract with
LEON DEPOLAS INVESTMENT SERVICES
S.A. concerning the market making activ-
ity under the following major terms:
1. LEON DEPOLAS INVESTMENT SERVIC-
ES S.A. will transmit into the Transac-
tions System of the Athens Exchange
market making related orders (mean-
ing simultaneous buy and sell orders)
for own account and on the Compa-
ny’s shares, according to the specific
provisions of the Greek legislation.
There will be a payment to LEON DE-
POLAS INVESTMENT SERVICES S.A. for
this service from the Issuer.
2. The contract concerning the market
making activity will have duration of
one (1) year.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 22 of 370
Dividend for the Year 2023
The Board of Directors of the Company,
by its decision dated April 22, 2024, unani-
mously decided to propose to the Annual
Ordinary General Meeting of shareholders
the approval of the distribution (payment)
of the profits of the fiscal year that ended
on 31.12.2023 and in particular to propose
the distribution (payment) to the share-
holders of a dividend of a total amount
of 10,250,000.00 Euros (gross amount),
i.e. 0.2343314986 Euros per share (gross
amount) from the profits of the fiscal year
2023 (01.01.2023-31.12.2023), but also from
profits of previous years.
Given that the Company, pursuant to the
relevant decision of the Board of Directors
dated September 25, 2023, has already dis-
tributed to the shareholders the interim
dividend for the fiscal year 2023 of a to-
tal amount of 3,000,000.00 Euros (gross
amount), i.e. 0.0685848289 Euros per share
(gross amount), the Board of Directors sub-
sequently proposed to the Annual Ordi-
nary General Meeting of shareholders the
distribution of the remaining amount of
the dividend, and in particular the amount
of 7,250,000.00 Euros (gross amount),
i.e. 0.1657466698 Euros per share (gross
amount), which gross amount per share
was increased by the amount correspond-
ing to the treasury shares that the Com-
pany hold on the dividend cut-off date as
treasury shares are not entitled to the pay-
ment of the dividend, by the provisions of
article 50 of Law 4548/2018, as applicable.
The Ordinary General Meeting of share-
holders, as the sole competent body, made
the final decision on the aforementioned
proposal-recommendation of the Board of
Directors.
Annual Ordinary General Meeting of the Company’s shareholders
The Annual Ordinary General Meeting of
the Company’s shareholders, which took
place on May 29, 2024 remotely in real time
via videoconference, approved the follow-
ing among others:
On the 1st item, the Annual Financial
Statements (corporate and consolidat-
ed) for the fiscal year 2023 (01.01.2023-
31.12.2023) were approved by majority,
along with the Annual Report of the Board
of Directors dated April 22, 2024, and the
Report of the Company’s Certified Auditor
Accountant dated April 23, 2024.
On the 2nd item, the Annual Report of
the Audit Committee for the fiscal year
2023 (01.01.2023-31.12.2023) was submit-
ted to the body of shareholders and was
also read during the meeting, in accord-
ance with the provisions of article 44, par.
1, sect. h’ of Law 4449/2017.
On the 3rd item, the shareholders ap-
proved unanimously the allocation (distri-
bution) of the earnings for the fiscal year
2023 (01.01.2023-31.12.2023) and specifi-
cally they approved the distribution (pay-
ment) of a total dividend amounting to
10,250,000.00 Euros (gross amount) to the
shareholders of the Company from the
earnings of the fiscal year ended Decem-
ber 31, 2023, but also from previous years
profits.
On the 4th item, the shareholders ap-
proved by majority the distribution of fis-
cal year 2023 portion of profits (01.01.2023-
31.12.2023) to the Executive Members of
the Board of Directors, to Senior Manage-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 23 of 370
ment and to Administrative Officers of the
Company, as a reward for their short-term
performance based on the set perfor-
mance targets, following relevant evalu-
ation and in accordance with the specific
provisions included in the Remuneration
Policy, as in force. Finally, the Board of Di-
rectors is authorized to determine and
specify the exact amount of the remunera-
tion (per Executive Member of the Board
of Directors, per Director and per Adminis-
trative Officer).
On the 5th item, the shareholders ap-
proved by majority the overall manage-
ment of the Company for the fiscal year
ended December 31, 2023, along with the
discharge of the Certified Auditors-Ac-
countants of the Company from any liabil-
ity for compensation regarding the actions
and the overall management for the fiscal
year 2023 (01.01.2023-31.12.2023).
On the 6th item, the shareholders ap-
proved unanimously, following the rel-
evant proposal by the Company’s Audit
Committee, the election of the Audit
Company under the trade name “ERNST
& YOUNG CERTIFIED AUDITORS S.A.” (reg-
istered in the Public Records of the article
14 of Law 4449/2017) for the regular audit
of the annual and semi-annual Financial
Statements of the Company (stand-alone
and consolidated) for the current fiscal
year 2024 (01/01/2024-31/12/2024).
On the 7th item, the shareholders ap-
proved by majority the fees, salaries, com-
pensation, and other benefits, paid to the
members of the Board of Directors for the
services provided to the Company during
the fiscal year 2023 (01.01.2023-31.12.2023).
On the 8th item, the shareholders voted
by majority positively the Remuneration
Report of fiscal year 2023, which was pre-
pared in accordance with the provisions
of article 112 of L. 4548/2018, including a
comprehensive overview of the total re-
muneration of the Members of the Board
of Directors (executive and non-executive)
and explaining how the Remuneration
Policy of the Company was implemented
for the immediately preceding fiscal year.
On the 9th item, the shareholders ap-
proved by majority the fees, salaries,
compensation and other benefits, which
will be paid to the members of the Board
of Directors during the current fiscal year
2024 (01.01.2024-31.12.2024) and provided
the relevant authorization for the advance
payment of the said remuneration for the
period until the next Annual Ordinary
General Meeting.
On the 10th item, the shareholders ap-
proved unanimously, pursuant to the pro-
visions of article 98, par. 1 of Law 4548/2018
as in force, the granting of the permission
and authorization to the Members of the
Board of Directors, the Directors and the
Managers of the Company, for their par-
ticipation in the Board of Directors and the
management of Company’s subsidiaries
and/or affiliated companies (existing or
new).
On the 11th item, the Report of the Inde-
pendent Non-Executive Members of the
Board of Directors for the fiscal year 2023
(01.01.2023-31.12.2023) was submitted to
the body of shareholders, in accordance
with the provisions of article 9, par. 5 of
Law 4706/2020.
The decisions of the General Meeting of
Shareholders are posted on the Compa-
ny’s website at the link https://www.thrace-
group.com/gr/en/general-meetings/.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 24 of 370
The Annual Ordinary General Meeting of
Shareholders, that took place on May 29,
2024, approved unanimously the distribu-
tion (payment) of dividend to Company’s
Shareholders, from the profits of the fiscal
year 2023 (01.01.2023-31.12.2023) and from
previous fiscal years, and in particular, ap-
proved the payment (distribution) of the
total amount of 10,250,000.00 Euro (gross
amount), i.e 0.2343314986 Euros per share
(gross amount).
It is noted that the Company pursuant to
the relevant decision of the Board of Di-
rectors dated September 25, 2023, had
already made the allocation (distribution)
to the shareholders of an interim dividend
for the fiscal year 2023, on December 6th,
2023, of a total amount of 3,000,000.00 Eu-
ros (gross amount), i.e. 0.0685848289 Euros
per share (gross amount), which with the
corresponding increased of the 798,549
treasury shares, which were held by the
Company and were excluded by law from
the interim dividend distribution, amount-
ed to 0.0698602048 Euros per share (gross
amount).
After that, the remaining amount of the
dividend was 7,250,000.00 Euros (gross
amount), from the profits of the fis-
cal year 2023 (01.01.2023-31.12.2023)
i.e. 0.1657466698 Euros per share (gross
amount), which after the increase corre-
sponding to 815,776 treasury shares, which
were held by the Company and were
excluded from the dividend payment,
amounted to 0.1688965830 Euro per share
(gross amount).
The above amount of the dividend is
subject to 5% withholding tax, in accord-
ance with articles 40 par. 1 and 64 par. 1
of Law 4172/2013 (Government Gazette A΄
167/23.07.2013), as in force after its amend-
ment of par. 24 of Law 4646/2019 (Govern-
ment Gazette A΄ 201/12.12.2019).
Therefore, the final payable amount of
dividend was 0.1604517539 Euro per share
(net amount).
The cut-off (ex-dividend) date of the divi-
dend was set for Monday, 3 June 2024.
Beneficiaries of the remaining dividend for
fiscal year 2023 were shareholders regis-
tered in the Company’s records in the De-
materialized Securities System on Tuesday,
4 June 2024 (Record Date).
The distribution (payment) of the above
remaining dividend commenced on Fri-
day, 7 June 2024 and was paid through the
paying Bank “PIRAEUS BANK S.A.”
Announcement of ex-dividend date / Payment of remaining dividend
for the Year 2023
Announcement of the new formation of the Remuneration and Nomi-
nations Committee
The Company’s Board of Directors, ac-
cording to its decision dated 30.08.2024,
appointed Mrs. Myrto Papathanou, inde-
pendent non-executive member of the
Board of Directors, as a member of the
Company’s Remuneration and Nomina-
tions Committee, replacing Mr. Nikitas Gly-
kas, who has resigned as a member of the
Committee.
Subsequently, on the same day 30.08.2024
and following the above decision, a meet-
ing of the Remuneration and Nominations
Committee took place, under its new com-
position and after a voting process among
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 25 of 370
its members, it reconstituted itself as fol-
lows:
1. Theodoros Kitsos of Konstantinos, In-
dependent Non-Executive Member
of the Board of Directors, Chairman of
the Remuneration and Nominations
Committee
2. Myrto Papathanou of Christos, Inde-
pendent Non-Executive Member of
the Board of Directors, Member of the
Remuneration and Nominations Com-
mittee
3. Vasileios Zairopoulos of Stylianos,
Non-Executive Member of the Board
of Directors, Member of the Remuner-
ation and Nominations Committee.
Non-replacement of a member of the Board of Directors
On October 30, 2024, Mr. Christos-Alexis
Komninos, son of Konstantinos, Non-Ex-
ecutive Member of the Board of Directors,
passed away.
The Board of Directors of the Company,
in its meeting on 05.11.2024, unanimously
decided, following the relevant recom-
mendation of the Remuneration and Nom-
ination Committee, the non-replacement
of the deceased non-executive member
of the Board of Directors, Christos-Alexis
Komninos and the continuation of the
management and representation of the
Company by the remaining ten (10) mem-
bers of the Board of Directors of the Com-
pany, in accordance to article 82 par. 2 of
Law 4548/2018 and article 11 par. 2 of the
Company’s Articles of Association, for the
remaining of its term. In particular, the ten-
member composition of the Company’s
Board of Directors is as follows:
1 Konstantinos Chalioris Chairman, Executive Member
2 Theodoros Kitsos
Vice Chairman, Independent Non-Executive member
3 Dimitrios Malamos
Chief Executive Officer (Group CEO), Executive member
4 Vasileios Zairopoulos Non-Executive member
5 Christos Shiatis Non-Executive member
6 Athanasios Dimiou Non-Executive member
8 Georgios Samothrakis Independent Non-Executive member
8 Myrto Papathanou Independent Non-Executive member
9 Spyridoula Maltezou Independent Non-Executive member
10 Nikitas Glykas Independent Non-Executive member
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 26 of 370
The Board of Directors of the Company,
in its meeting of November 14, 2024, ap-
proved the distribution (payment) to the
shareholders of the Company of an interim
dividend from the current fiscal year 2024
earnings, of a total amount of 3,000,000.00
Euros (gross amount), corresponding
to 0.0685848289 Euros per share (gross
amount).
The Company with a later announcement
provided further information regarding
the exact amount of the interim dividend
paid per share, including the increase,
which would correspond to the treasury
shares that the Company would hold at
the interim dividend cut-off date.
The Board of Directors of the Company
with a later decision decided on: (a) the
cut-off date of the relevant right to the div-
idend distribution, (b) the date of identifi-
cation of beneficiaries (record date) of the
interim dividend, and (c) the date of pay-
ment of the interim dividend to the benefi-
ciaries, as well as the paying bank, through
which the interim dividend would be paid
to the beneficiaries. The relevant new an-
nouncement, containing all above infor-
mation, would be published immediately
(after the finalization of the information in-
cluded), in accordance with the provisions
of the current Athens Exchange Rulebook.
Issuance of Tax Certificates for the Fiscal Year 2023
Following the completion of the tax audits
for the financial year 2023 (fiscal year 2023),
which were carried out by the tax auditors
of the Company, in accordance with the
provisions of article 65A law 4174/2013,
both for the Company and its subsidiar-
ies and affiliated companies “Thrace Non-
wovens & Geosynthetics S.A.”, “Thrace
Polyfilms S.A.”, “Thrace Plastics Pack S.A.”,
“Thrace Eurobent S.A.” and “Thrace Green-
houses S.A.”, the relevant tax certificates
were issued with an “unmodified opinion”.
Write-off of Dividend for the Financial Year 2018
The five-year period for the collection of
the dividend for the fiscal year 2018, ex-
pired on December 31, 2024. Following
this date, dividends not collected from en-
titled parties were written off, in favor of
the Greek State.
Announcement of the Decision to Distribute an
Interim Dividend the 2024
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 27 of 370
SECTION 2: Main Risks and Uncertainties
Financial Risk Management
The financial assets used by the Group,
mainly consist of bank deposits, bank
overdrafts, receivable accounts, payable
accounts and loans.
The Group’s activities, in general, create
several financial risks. Such risks include
market risk (foreign exchange risk and
risk from changes of raw materials prices),
credit risk, liquidity risk and interest rate
risk.
Risk from fluctuation of prices of raw
materials
The Group is exposed to fluctuations in
the price of polypropylene (represents
46% approximately of the cost of sales),
which are mainly faced by a similar change
in the selling price of the final product. The
possibility that the increase in the price of
polypropylene cannot be fully passed on
to the selling price, causes unavoidably
the compression of margins. For this rea-
son, the Group accordingly adjusts, to the
extent it is feasible, its inventory policy as
well as its commercial policy in general.
Hence, in any case, the particular risk is
deemed as relatively controlled.
Credit Risk
The credit risk to which the Group and the
Company are exposed is the likelihood
that a counterparty will cause financial loss
to the Group and the Company as a result
of the breach of its contractual liabilities.
The maximum credit risk to which the
Group and the Company are exposed at
the date of preparation of the financial
statements is the book value of their fi-
nancial assets. In order to address credit
risk, the Group consistently applies a clear
credit policy, which is monitored and
evaluated on an ongoing basis so that the
credit granted does not exceed the credit
limit per customer. Furthermore, client
sales insurance policies are also concluded
per customer and no tangible guarantees
on the assets of clients are required.
In order to monitor credit risk, customers
are grouped according to the category
they belong to, their credit risk character-
istics, the maturity of their receivables and
any previous receivables that they have
caused, taking into account future factors
related to the customers and the econom-
ic environment.
Impairment
The Group and the Company, in the finan-
cial assets that are subject to the model of
expected credit losses, include receivables
from customers and other financial assets.
The Group and the Company recognize
provisions for impairment with regard
to the expected credit losses of all finan-
cial assets. The expected credit losses
are based on the difference between the
contractual cash flows and the entire cash
flows, which the Group (or the Company)
anticipates to receive. The difference is
discounted by using an estimate concern-
ing the initial effective interest rate of the
financial asset. For the trade receivables,
the Group and the Company applied the
simplified approach of the accounting
standard and calculated the expected
credit losses based on the expected credit
losses for the entire lifetime of these items.
Regarding the remaining financial assets,
the expected credit losses are being calcu-
lated according to the losses of the next 12
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 28 of 370
months. The expected credit losses of the
following 12 months are part of the antici-
pated credit losses for the entire life of the
financial assets, which emanates from the
probability of a default in the payment of
the contractual obligations within the next
12-month period starting from the report-
ing date. In case of a significant increase in
credit risk since the initial recognition, the
provision for impairment will be based on
the expected credit losses of the entire life
of the asset.
For the assessment of the increase in credit
risk, the Group and the Company evalu-
ate the creditworthiness of the counter-
party in comparison to the corresponding
creditworthiness at initial recognition, as
well as the probability of default within
the next 12 months, relative to the corre-
sponding probability at initial recognition.
The Group and the Company consider
a financial asset to be non-performing
when internal or external information in-
dicates that the Group or the Company is
unlikely to recover the relevant contractual
amounts. Furthermore, the Group and the
Company derecognize a financial asset
when they assess that there is no reasona-
ble expectation of recovering the relevant
contractual cash flows.
At the date of the preparation of the fi-
nancial statements, impairment of trade
receivables and other financial assets was
made on the basis of the above.
The following table presents an analysis
of the maturity of Trade Receivables’ bal-
ances at 31.12.2024.
Maturity of Trade Receivables’
balances at 31.12.2024
Group
01 – 30 days 23,348
31 – 90 days 39,765
91 – 180 days 9,604
180 days and over 7,176
Subtotal 79,893
Provisions for doubtful
receivables
(6,742)
Total 73,151
The analysis of provision is presented in
below table:
Analysis of
provision
Expected
Credit Losses
Expected
Credit Losses
%
01 – 30 days
5 0.02%
31 – 90 days
12 0.03%
91 – 180 days
307 3.20%
180 days and over
6,418 89.44%
Total 6,742
The analysis of not past due and overdue
receivables as of December 31, 2024, is pre-
sented in the table below:
Analysis of not past due/overdue
Trade receivables at 31.12.2024
Group
Receivables not past due 57,146
Overdue receivables
1 – 30 days
10,978
Overdue receivables
31 – 90 days
3,290
Overdue receivables above
91 days
8,479
Subtotal 79,893
Provisions for doubtful
receivables
(6,742)
Total 73,151
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 29 of 370
With regard to uninsured receivables over-
due more than 90 days, which the Group
has classified as doubtful, relevant provi-
sions have been made which are deemed
as sufficient.
Correspondingly, the amounts of maturity
and past due for the financial year 2023 are
presented in the following tables:
Maturity of Trade Receivables’
balances at 31.12.2023
Group
01 – 30 days 18,385
31 – 90 days 35,046
91 – 180 days 8,876
180 days and over 7,324
Subtotal 69,631
Provisions for doubtful re-
ceivables
(7,452)
Total 62,179
Analysis of not past due/overdue
Trade receivables at 31.12.2023
Group
Receivables not past due 46,545
Overdue receivables 1 – 30
days
11, 856
Overdue receivables 31 – 90
days
3,765
Analysis of not past due/overdue
Trade receivables at 31.12.2023
Group
Overdue receivables above 91
days
7,4 65
Subtotal 69,631
Provisions for doubtful re-
ceivables
(7,452)
Total 62,179
Liquidity Risk
Liquidity risk monitoring focuses on the
management of cash inflows and outflows
on a consistent basis, so that the Group has
the ability to meet its cash liabilities and re-
tain the cash reserves required for its opera-
tions. Liquidity is managed by maintaining
cash and approved bank credit lines. At the
date of preparation of the financial state-
ments, unused approved bank credits were
available to the Group, which are consid-
ered sufficient to handle any possible short-
age of cash in the future.
Short-term bank liabilities are renewed at
maturity, as they are part of the approved
bank credit lines.
The following table presents the liabilities –
disbursements according to their maturity
dates.
Group 31.12.2024
Up to 1
month
1-6
months
6-12
months
1-5
Years
Over 5
years
Total
Trade payables
20,746 34,718 36 - - 55,500
Other short-term liabilities
17, 651 8,964 325 - - 26,940
Short-term debt
504 9,406 21,821 - - 31,731
Liabilities from leasing
(short-term portion)
88 431 763 - - 1,282
Long-term debt
- - - 32,755 493 33,248
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 30 of 370
The Group is exposed to foreign exchange
risks arising from existing or expected cash
flows in foreign currency and investments
that have been made in countries outside
Greece. The Group uses financial deriva-
tives, mainly forward foreign exchange
contracts, to hedge the risks arising from
changes in foreign exchange rates.
Sensitivity analysis of the effect of ex-
change rate changes is depicted in the ta-
ble below.
Foreign Currency
2024 2023
Change of foreign currency
against Euro
Profit before tax
USD GBP Other USD GBP Other
+5%
(238) (24) (4) (155) (53) -
-5%
262 27 4 172 58 -
Equity
+5%
(13) (899) (269) (58) (438) (319)
-5%
15 994 297 64 484 352
Group 31.12.2024
Up to 1
month
1-6
months
6-12
months
1-5
Years
Over 5
years
Total
Liabilities from leasing
(long-term portion)
- - - 1,619 - 1,619
Other long-term liabilities
- - - 403 - 403
Total 31.12.2024 38,989 53,519 22,945 34,777 493 150,723
Group 31.12.2023
Up to 1
month
1-6
months
6-12
months
1-5
Years
Over 5
years
Total
Trade payables
17,088 21,284 90 - - 38,462
Other short-term liabilities
11, 611 9,695 72 - - 21,378
Short-term debt
4,881 16,776 4,898 - - 26,555
Liabilities from leasing
(short-term portion)
85 444 611 - - 1,140
Long-term debt
- - - 26,713 1,077 27, 790
Liabilities from leasing
(long-term portion)
- - - 1,885 - 1,885
Other long-term liabilities
- - - 518 - 518
Total 31.12.2023 33,665 48,199 5,671 29,116 1,077 117,728
Foreign Exchange Risk
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 31 of 370
Interest Rate Risk
The long-term loans of the Group have
been granted by Greek and foreign banks
and are mainly in Euro. Their repayment
time varies, depending on the loan agree-
ment and they are usually linked to Euribor
plus spread. The Group’s short-term loans
have been granted by various banks, main-
ly with Euribor interest rate plus spread or
Libor interest rate plus spread.
The Group’s Management is closely moni-
toring developments regarding inter-
est rate fluctuations and is taking action,
within the realm of feasibility, to contain or
limit margins. Simultaneously, efforts are
being made to manage available liquidity
effectively, aiming to establish a rational
volume of loans in comparison to sales vol-
ume, profitability levels and the Group’s
investment magnitude.
It is estimated that a change in the average
annual interest rate by 1% will result in a
(charge) / improvement of Earnings before
Tax as follows:
Possible Interest Rate
Change
Effect on Earnings before Tax
Group
2024 2023
Interest rate increase 1% (679) (573)
Interest rate decrease 1% 679 573
Capital Adequacy Risk
The Group monitors capital adequacy us-
ing the Net Debt to Equity ratio and the
Net Debt to EBITDA ratio. The Group’s ob-
jective in relation to capital management
is to ensure the ability for its smooth op-
eration in the future, while providing ra-
tional returns to shareholders and benefits
to other parties, as well as to maintain an
adequate capital structure, in order to en-
sure a low cost of capital. For this purpose,
it systematically monitors working capital,
in order to maintain the normal level of ex-
ternal financing.
Capital Adequacy Risk Group
2024 2023
Long-term debt
33,248 27,79 0
Long-term debt from leases
1,619 1,885
Short-term debt
31,731 26,555
Short-term debt from leases
1,282 1,140
Total Debt
67,880 57,370
Minus cash & cash equivalents
33,456 27,801
Net Debt*
34,424 29,569
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 32 of 370
All information regarding climate change
risks concerning the Group is disclosed in
detail in the Group’s Sustainability State-
ment, Section 8. General Information,
Chapter IRO-1. The description of the
processes for identifying and assessing
material impacts, risks and opportuni-
ties in the Double Materiality Analysis is
provided in Paragraph D. Identification of
Risks and Opportunities (See Section 8 of
this report).
SECTION 3: Significant Transactions with Related Parties
The most significant transactions between
the Company and its related parties, as de-
fined by International Accounting Stand-
ard 24, are described below.
The most significant transactions between
the Company and its affiliated companies
and individuals (related parties), as defined
by International Accounting Standard 24,
are described below.
It should be noted that the reference to
the particular transactions includes the fol-
lowing data:
a) the amount of the most significant
transactions for the year 2024
b) their unpaid balance at the end of the
year (31.12.2024)
c) the nature of relation between the re-
lated party and the Company, as well
as
d) any information concerning the trans-
actions, which is necessary for the un-
derstanding of the Company’s finan-
cial position, only to the extent that
these transactions are material.
Company’s Revenues from Related
Parties
The following table includes the Compa-
ny’s most significant revenues (including
Turnover and other income) from related
parties, i.e. from Company’s subsidiaries:
Capital Adequacy Risk Group
EBITDA
41,361 44,017
NET DEBT / EBITDA
0.83
0.67
EQUITY 275,169 277,054
NET DEBT / EQUITY 0.13 0.11
* The cash and cash equivalents for the fiscal year 2023, and consequently the net debt, do not include an
amount of €13,269 related to time deposits that were concluded in the previous fiscal year with a duration of
more than three months. This amount was transferred to other receivables.
Climate Change Risk
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 33 of 370
Income
Thrace Nonwovens & Geo-
synthetics Single Person SA
1,644
Don & Low LTD 1,143
Thrace Plastics Pack SA 980
Thrace Polyfilms Single
Person SA
385
Thrace Ipoma A.D. 294
Synthetic Holdings LTD 450
Thrace Polybulk AB 266
Thrace Synthetic Packaging
LTD
221
Thrace Polybulk AS 213
Thrace Linq Inc 176
Total 5,772
In summary, there were no changes in
transactions between the Company and
its related parties that could have a mate-
rial impact on the Company’s financial po-
sition and performance for the fiscal year
2024.
All transactions described above were con-
ducted under normal market conditions
and do not contain any exceptional or indi-
vidualized features that would have made
compulsory the further analysis on a per-
related-party basis.
Short-term Liabilities of the Company to
Related Parties
There are no significant short-term liabili-
ties of the Company to related parties.
Remuneration to the members of the Board
of Directors
The remuneration granted to the mem-
bers of the Company’s Board of Directors
amounted to €1,628 in 2024 against €1,571
in 2023. The remuneration of the members
of the Board of Directors for the Group
amounted to €4,340 in 2024 versus €4,436
in 2023 and relate to the Boards of Direc-
tors of 18 companies and to 30 people
that participate in these BoDs, including
salaries of the executive members of the
Boards, other remuneration and benefits
of both the executive and the non-execu-
tive members.
Bank guarantees and grants in favor of its
subsidiaries
Bank guarantees issued by banks on behalf
of the Company against third parties (State
owned companies, Suppliers, Customers)
amount to €834.
The Company has granted guarantees to
banks against long-term loans of its sub-
sidiaries. On December 31, 2024, the out-
standing amount for which the Company
had provided guarantee settled at €53,283
and is analyzed as follows:
Guarantees for
Subsidiaries
2024
Thrace Nonwovens & Geo-
synthetics Single Person SA
23,405
Thrace Plastics Pack S.A. 23,887
Thrace Polyfilms Single
Person SA
5,991
Total 53,283
Statutory external auditors’ fees
During the financial year 2024, the total
fees paid for services provided by audit-
ing firms, amounted to € 568 for the Group
and to €112 for the Company.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 34 of 370
SECTION 4: Analytical Information according to Article 4 par. 7 and 8 of Law
3556/2007, as currently in effect
The Company, according to article 4 par. 7
and 8 of L. 3556/2007 is required to include
in the present Report, analytical informa-
tion regarding a series of issues, as follows:
1. Structure of Company’s share
capital
The Company’s share capital on 31.12.2024
amounted to twenty eight million eight
hundred sixty nine thousand, three hun-
dred fifty eight Euros and thirty two cents
(€28,869,358.32) and was divided into
forty three million seven hundred forty
one thousand, four hundred fifty two
(43,741,452) common registered shares,
with a nominal value of sixty six cents
(€0.66) each. All Company shares are com-
mon, registered, with voting rights (with
the exception of any treasury shares held
by the Company), and are listed on the
organized Market of the Athens Stock Ex-
change and specifically in the Main Mar-
ket under the Chemicals – Specialized
Chemicals sector. The structure and the
formation of the Company’s share capital
are presented in detail in article 5 of the
Company’s Articles of Association. The
Company’s shares were listed on the Ath-
ens Exchange on 26 June 1995 and are
being traded on this market up until to-
day, without any interruption. From each
share, all rights and obligations stipulated
by the law and the Company’s Articles of
Association emanate. The possession of
each share results automatically into the
full and with no reservations acceptance
of the Company’s Articles of Association
and the decisions that have been made by
the pertinent bodies of the Company in
accordance with the law and the Articles
of Association. Each share provides for one
(1) voting right.
2. Limitations to the transfer of
Company shares
The transfer of Company shares takes
place as stipulated by the Law and there
are no limitations regarding such transfers
in relation to its Articles of Association or
other special agreements or other regula-
tory provisions.
3. Significant direct or indirect
shareholdings according to the
definition of Law 3556/2007
With regards to significant shareholdings
in the share capital and voting rights of the
Company, according to the definition of
provisions of articles 9 to 11 of L. 3556/2007,
the Company’s shareholders, with equity
stake above 5%, as of 31.12.2024 were the
following:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 35 of 370
LAST NAME NAME
SHARES
IN “JOINT
INVESTMENT
SHARES”
SHARES NOT
IN “JOINT
INVESTMENT
SHARES”*
TOTAL
SHARES
VOTING
RIGHTS
Chalioris Konstantinos 41.15% 2.13% 43.29% 43.29%
Chaliori Effimia - 20.85% 20.85% 20.85%
Chalioris Alexandros 20.58% 0.48% 21.06% 0.48%
Chalioris Stavros 20.58% 0.48% 21.06% 0.48%
* η σχετική ανακοίνωση αναρτήθηκε στην ιστοσελίδα της Εταιρείας στις 10 Μαρτίου 2023 και αναφέρει:
Ο κ. Κωνσταντίνος Χαλιορής, μέτοχος και Πρόεδρος
του Διοικητικού Συμβουλίου της Εταιρείας,
μετέφερε σε δύο Κοινές Επενδυτικές Μερίδες (ΚΕΜ)
που δημιούργησε, την μεν πρώτη από κοινού με
το τέκνο του Αλέξανδρο Χαλιορή, τη δε δεύτερη
από κοινού με το τέκνο του Σταύρο Χαλιορή (και με
πρώτο τη τάξει δικαιούχο σε αμφότερες τις Κοινές
Επενδυτικές Μερίδες τον ίδιο), από την ατομική του
μερίδα συνολικά 18.000.983 κοινές, ονομαστικές
μετά ψήφου μετοχές, δηλαδή ποσοστό 41,153%
επί συνόλου 43.741.452 κοινών, ονομαστικών μετά
ψήφου μετοχών της Εταιρείας.
Με τις παραπάνω μεταφορές δεν επήλθε καμία
απολύτως μεταβολή στον αριθμό και το ποσοστό
μετοχών και δικαιωμάτων ψήφου που ελέγχει ο κ.
Κωνσταντίνος Χαλιορής, ο οποίος κατέχει 18.936.558
εν συνόλω κοινές, ονομαστικές μετά ψήφου μετοχές
της Εταιρείας (και ισάριθμα δικαιώματα ψήφου) και
ποσοστό 43,292% και πιο συγκεκριμένα 18.000.983
κοινές, ονομαστικές μετά ψήφου μετοχές (ποσοστό
41,153%) μέσω των ως άνω δύο Κοινών Επενδυτικών
Μερίδων και 935.575 κοινές, ονομαστικές μετά
ψήφου μετοχές (ποσοστό 2,139%) στην ατομική του
μερίδα.
Ο κ. Σταύρος Χαλιορής του Κωνσταντίνου, λόγω
της συμμετοχής του στην ως άνω Κοινή Επενδυτική
Μερίδα (που διατηρεί κατά τα άνω από κοινού με
τον Κωνσταντίνο Χαλιορή), κατέχει 9.000.491 κοινές,
ονομαστικές μετά ψήφου μετοχές της Εταιρείας
(ποσοστό 20,577%), ενώ ήδη κατέχει 212.071 κοινές,
ονομαστικές μετά ψήφου μετοχές (ποσοστό 0,484%)
στην ατομική του μερίδα και τέλος
Ο κ. Αλέξανδρος Χαλιορής του Κωνσταντίνου, λόγω
της συμμετοχής του στην ως άνω Κοινή Επενδυτική
Μερίδα (που διατηρεί κατά τα άνω από κοινού με
τον Κωνσταντίνο Χαλιορή), κατέχει 9.000.492 κοινές,
ονομαστικές μετά ψήφου μετοχές της Εταιρείας
(ποσοστό 20,577%), ενώ ήδη κατέχει 212.071 κοινές,
ονομαστικές μετά ψήφου μετοχές (ποσοστό 0,484%)
στην ατομική του μερίδα.
No other person or legal entity owns a per-
centage over 5% of the share capital. The
data regarding the number of shares and
voting rights held by individuals with sig-
nificant shareholdings have been derived
from the Shareholder Registry kept by
the Company and from disclosures by the
shareholders provided to the Company ac-
cording to Law (and MAR).
4. Shares incorporating special
control rights
There are no Company shares that provide
special control rights to owners.
5. Limitations on voting rights
According to the Company’s Articles of As-
sociation, there are no limitations on vot-
ing rights.
6. Agreements of Company
shareholders
To the knowledge of the Company, there
are no shareholder agreements, which re-
sult in limitations on the transfer of shares
or limitations on the exercise of voting
rights that emanate from its shares.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 36 of 370
7. Rules for appointment and
replacement of Board members
and the amendment of the Articles
of Association, which deviate from
the provisions of C.L. 4548/2018
The rules stated by the Company’s Arti-
cles of Association regarding the appoint-
ment and replacement of its Board of Di-
rectors’ members and the amendment of
the provisions of its Articles of Association,
do not differ from those stipulated by
C.L.4548/2018 as it is in effect.
8. Responsibility of the Board
of Directors or specific Board
members for the issuance of new
shares or the purchase of treasury
shares.
There is no special and permanent compe-
tence of the Board of Directors or some of
its members for the issuance of new shares
or the purchase of treasury shares accord-
ing to article 49 of law 4548/2018.
The relevant power and responsibility is
given to the Company’s Board of Directors
by virtue of a relevant decision of the Gen-
eral Meeting of its shareholders.
9. Significant agreements made by
the Company and put into effect,
amended or terminated in case of
a change in the Company’s control
following a tender offer.
There are no such agreements, which are
put into effect, amended or terminated, in
case of a change in the Company’s control
following a tender offer.
10. Significant agreements made by
the Company with Board members
or the Company’s personnel
There are no agreements of the Company
with the members of its Board of Directors
or its personnel, which provide for the pay-
ment of indemnity specifically in case of
resignation or termination of employment
without reasonable cause, or of the termi-
nation of their term or employment due to
a public offering.
SECTION 5: Treasury Shares
The Extraordinary General Meeting of
the Company’s shareholders on Febru-
ary 2, 2017 decided, inter alia, to approve
the purchase of treasury shares through
the Athens Stock Exchange under the
provisions of the pre-existing article 16
of Codified Law 2190/1920, which expired
on 02.02.2019. Under the aforementioned
plan and until its expiration, the Company
acquired 4,324 treasury shares.
The Extraordinary General Meeting of
the Company’s shareholders on March
19, 2019 decided, inter alia, to approve
the acquisition of treasury shares through
the Athens Stock Exchange in accordance
with the provisions of article 49 of law
4548/2018 as currently in force, which ex-
pired on 19.03.2021. Under the above plan
and until its completion, the Company
acquired 318,364 treasury shares, with an
average purchase price of 2.4373 Euros per
share, which correspond to a percentage
of 0.728% of the share capital.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 37 of 370
The Annual General Meeting of the Com-
pany’s shareholders of May 21, 2021 de-
cided, inter alia, to approve the acquisi-
tion of treasury shares through the Athens
Stock Exchange in accordance with the
provisions of article 49 of law 4548/2018
as currently in force, which expired on
21.05.2023. Under the above plan and un-
til its completion, the Company acquired
428,708 treasury shares, with an average
purchase price of 5.89 Euros per share,
which correspond to a percentage of
0.98% of the share capital.
The Annual General Meeting of the Com-
pany’s shareholders of May 25, 2023 de-
cided to approve by unanimously approval
the Company’s treasury shares buyback
plan in accordance with the provisions of
article 49 of Law 4548/2018, as in force, and
in particular the purchase within a period
of twenty-four (24) months from the date
of this decision, i.e. until 24.05.2025, of a
maximum number of 4,341,876 common
registered shares (with the total treasury
shares already owned by the Company,
from a previous share buy-back plan, in-
cluded and aggregated in relation to the
above limit), with a purchase price range
between fifty cents of Euro (€0.50) (mini-
mum) per share and ten Euro (€10) (maxi-
mum) per share.
During the execution of the above share
buy-back program and in execution-
implementation of the above decision
of the General Meeting of Shareholders,
the Company proceeded, in accordance
with the provisions of Regulation (EU)
596/2014 of the European Parliament and
of the Council as of 16 April 2014 and of
the Commission’s Delegated Regulation
(EU) 2016/1052 as of 8 March 2016, with
the purchase of a total of 112,400 common
registered shares carrying voting rights in
2023 and 2024, based on an average price
of EUR 4.39 per share, corresponding to
0.26% of the equity.
The Company held on 31.12.2024 a total of
863,796 treasury shares, which correspond
to a percentage of 1.98% of the share
capital.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 38 of 370
1. Group Financial Results
The following table depicts the Group’s financial results for the year 2024 compared to
the year 2023:
Financial Results of Year 2024
(amounts in thousand Euro)
Year 2024 Year 2023
Change %
Turnover 370,368 345,373 7.2%
Gross Profit 77,14 0 77,0 69 0.1%
Gross Profit Margin 20.8% 22.3%
EBIT 15,658 20,663 -24.2%
EBIT Margin 4.2% 6.0%
EBITDA* 41,361 44,017 -6.0%
EBITDA Margin 11. 2% 12.7%
Adjusted EBITDA 42,256 44,017 -4.0%
Adjusted EBITDA Margin 11.4% 12.7%
Earnings before Taxes (EBT) 13,735 21,336 -35.6%
EBT Margin 3.7% 6.2%
Earnings after Taxes (EAT) 11,0 0 4 18,326 -40.0%
EAT Margin 3.0% 5.3%
Total EATAM 10,363 17,767 -41.7%
EATAM Margin 2.8% 5.1%
Earnings per Share (in euro) 0.2415 0.4134 -41.6%
Note: The alternative performance measures are presented and described analytically in the section 7 of the
present Report.
SECTION 6: Review of material financial figures of 2024
Below, an analysis of the changes ob-
served in key financial figures of the finan-
cial results compared to the previous year
is included.
It is noted that the Adjusted EBITDA does
not include non-recurring expenses
amounting to €895, related to the discon-
tinuation of artificial grass production,
an activity that the Group’s Management
decided to discontinue. These expenses
mainly concern impairments of finished
product inventories, based on relevant ac-
counting policies. However, the Group’s
Management is working on utilizing these
inventories in the future.
* EBITDA is defined as operating results
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 39 of 370
before taxes, interest, depreciation, im-
pairment, financing and investing results.
The figure of EBITDA is not precisely de-
fined under the International Financial Re-
porting Standards (IFRS) as adopted by the
European Union. The calculation of EBITDA
is performed as follows:
“Operating profit / (loss) before taxes, cash
and investment results” plus “Deprecia-
tion”, where:
- Operating profit / (loss) before taxes,
finance and investment results (EBIT)
(see “Information by Segment, State-
ment of Results for the Period” note
3.2): €15,658.
- Depreciation (see “Information by
Segment, Statement of Results for the
Period” note 3.2): €25,703.
In addition, Adjusted EBITDA is calculated
as EBITDA, minus extraordinary, non-re-
curring profits or expenses, where for the
period 01/01/2024 – 31/12/2024 amount to
€895 and relate to the discontinuation of
artificial grass production.
Turnover
€ 370,368
(7. 2%)
An increase in consolidated turnover by
7.2%, compared to the previous year, while
the volume (in tons) of consolidated sales
increased by 10%, demonstrating a signifi-
cant increase in the Group’s market share
despite weak demand and multiple geo-
political challenges.
Specifically, the Packaging segment dem-
onstrated a 16% increase in sales volume,
and the Technical Fabrics segment re-
corded a 6% increase in sales volume com-
pared to the fiscal year 2023. Therefore,
the Group is strengthening its commercial
position in both main segments of activity.
Gross Profit
€77,140 (0.1%)
Gross profits amounted to €77,140, remain-
ing at the same level as the previous year
despite the increase in sales. This is due to
the significant burden on the cost base of
the industrial sector in general, which also
affected the Group’s results. Specifically,
the reduction in the average cost of raw
materials was not proportional to the weak
demand and the resulting drop in average
selling prices. Additionally, there was a
significant increase in labor costs (+12.6%)
and energy costs (+10.8%, particularly in
the second half of the year) compared to
previous year.
The gross profit margin settled at 20.8%
compared to 22.3% in 2023.
EBIT
€ 15,658 (-24.2%)
Earnings before financial and investment
activities and taxes amounted to €15,658,
marking a decrease of 24.2% compared to
the previous year. This decline is attributed
to the significant burden on EBITDA, com-
bined with a 9% increase in depreciation
due to the heightened investments made
during the year.
Accordingly, the EBIT margin stood at 4.2%
compared to 6.0% in 2023.
EBITDA
€41,361 (-6.0%)
Earnings before financial and investment
activities, depreciation, impairments and
taxes amounted to €41,361, marking a de-
crease of 6.0% compared to the previous
year. This decline is attributed to the in-
crease in distribution expenses, primarily
due to higher personnel and transporta-
tion costs, combined with an impairment
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 40 of 370
of €895 due to the discontinuation of artifi-
cial grass production.
Accordingly, the EBITDA margin settled at
11.4% compared to 12.7% during the previ-
ous year.
Earnings before Taxes (EBT)
€13,735 (-35.6%)
In 2024, Earnings before taxes amounted to
€13,735, compared to Profit before Taxes of
€21,336 in 2023, for the reasons mentioned
above. Additionally, in terms of financial
costs, 2023 benefited from the reversal of
the discounting of a long-term receivable
from OAED amounting to €1,088.
Accordingly, the EBT margin settled at
3.7% compared to 6.2% during the previ-
ous year.
Earnings after Taxes (EAT)
€11,004 (-40%)
Earnings after taxes amounted to €11,004,
posting a reduction of 40% compared to
the previous year.
The profit margin after taxes settled at 3%
compared to 5.3% in the previous year.
Earnings after Taxes excluding Non-
Controlling Interests (EATAM)
€ 10,363 (-41.7%)
Earnings after Taxes excluding non-con-
trolling Interests amounted to €10,363,
posting a decrease of 41.7% compared to
the previous year.
Respectively, the profit margin after taxes
excluding non-controlling interests stood
at 2.8% in 2024 compared to 5.1% in 2023.
2. Parent Company’s Financial
Results
The Company’s business purpose, apart
from being a holding company, relates also
to the provision of support services to its
subsidiaries. Specifically, the Company’s in-
come is generated from the provision of ad-
ministrative, operating and organizational
support services, financial and tax services,
IT and consulting services in the areas of
marketing and sales, the preparation of fi-
nancial feasibility studies and the general
provision of consulting services which en-
sure the proper operation of subsidiaries at
all levels.
Specifically for the year 2024, the Turnover
of the Company concerning the provision
of the above services amounted to €5,772
against €5,600 in 2023, therefore remaining
essentially at the same levels. The Losses
before Taxes, Financial and Investment Re-
sults amounted to €494 in 2024 compared
to a loss of €515 in 2023. Earnings before
taxes for the year 2024 amounted to €8,563
compared to €12,364 in 2023, posting a de-
crease of 30.74%. Finally, Earnings after tax-
es in 2024 amounted to €8,348 compared
to €11,070 in 2023, recording a decrease of
24.59%.
3. Financial Results of the Group per
Business Segment
The operating segments are based on the
different product category, the structure
of the Group’s management and the inter-
nal reporting system. Using the criteria, as
defined in the accounting standards and
based on the different activities of the
Group, the business activity of the Group is
divided into two business segments, name-
ly “Technical Fabrics” and “Packaging”. The
information about the segments of activity,
which are not reported as separate ones,
has been collected and presented in the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 41 of 370
Technical Fabrics Packaging Other
Production and trade
of technical fabrics for
industrial and technical
use.
Production and trade of
packaging products, plastic
bags, plastic boxes for
packaging of food and paints
and other packaging materials
for agricultural use.
It includes the Agricultural segment
and the business activity of the
Parent company, which apart from
the investing activities provides
also Administrative – Financial – IT
services to its subsidiaries.
The table below summarizes the perfor-
mance of the individual segments in which
the Group operates during the fiscal year
2024, where annual operating and pre-tax
profitability (EBITDA and EBT) is compared
with the corresponding profitability of the
previous year.
FINANCIAL RESULTS PER SEGMENT
Segment Technical Fabrics Packaging Other
Intra-
Segment
Eliminations
Group
12M 2024 12M 2023
% Ch.
12M 2024 12M 2023
% Ch.
12M 2024 12M 2023 12M 2024 12M 2023 12M 2024 12M 2023
Turnover
240,180
230,755
4.1% 141,893
125,202
13.33% 5,772 5,600 -17,477
-16,184
370,368
345,373
Gross
Profit
44,025 47,555 -7.4% 32,641 28,875 13.04% 458 266 16 373 77,140 77,069
Gross
Profit
Margin
18.3% 20.6% 23.0% 23.1% 7.9% 4.8% - 20.8% 22.3%
EBITDA
18,669 24,635 -24.2% 22,969 19,655 16.86% -236 -263 -41 -10 41,361 44,017
EBITDA
Margin
7.8% 10.7% 16.2% 15.7% -4.1 -4.7% - 11.2% 12.7%
GROUP
370,368
77,140
41,361
Turnover
12M 2024
EBITDA
GROSS PROFIT
EBITDA
240,180
44,025
18,669
12M 2024
GROSS PROFIT
141,893
12M 2024
EBITDA
32,641
22,969
GROSS PROFIT
12M 2024
EBITDA
-236
458
GROSS PROFIT
PACKAGING
OTHER
TECHNICAL TEXTILES
Turnover
Turnover
Turnover
category “Other”, which includes the agri-
cultural segment as well as the activities of
the Parent Company.
The description and financial results of the
Group’s operating segments are presented
as follows:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 42 of 370
4. Group Consolidated Statement of Financial Position
The following table summarizes the basic financial figures of the Group’s statement of
financial position as of 31.12.2024 and 31.12.2023:
(amounts in thousand Euro)
31.12.2024 31.12.2023 Change %
Property, Plant & Equipment 193,529 177,670 8.9%
Rights-of-use assets 3,065 3,154 -2.8%
Investment Property 113 113 0.0%
Intangible Assets 10,226 10,316 -0.9%
Investments in Joint Ventures 20,430 20,475 -0.2%
Net benefit from funded defined benefit plans 5,980 9,533 -37. 3%
Other Long-term Receivables 158 138 14.5%
Deferred Tax Assets 815 326 150.0%
Total Fixed Assets 234,316 221,725 5.68%
Inventories 85,105 72,003 18.2%
Income Tax Prepaid 954 956 -0.2%
Trade Receivables 73,151 62,179 17.6%
Other Receivables 7,166 21,523 -66.7%
Derivative Financial Products - 77 -100.0%
Non-current assets held for sale 1,698 - -
Cash & Cash Equivalents 33,456 27, 801 20.3%
Total Current Assets 201,530 184,539 9.21%
TOTAL ASSETS 435,846 406,264 7.3%
TOTAL EQUITY 275,169 277,054 -0.7%
Long-term Borrowings 33,248 27,79 0 19.6%
Liabilities from Leases 1,619 1,885 -14.1%
Provisions for Employee Benefits 1,907 1,658 15.0%
Deferred Tax Liabilities 5,507 7,910 -30.4%
Other Long-term Liabilities 403 518 -22.2%
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 43 of 370
(amounts in thousand Euro)
31.12.2024 31.12.2023 Change %
Total Long-term Liabilities 42,684 39,761 7.4%
Short-term Borrowings 31,731 26,555 19.5%
Liabilities from Leases 1,282 1,140 12.5%
Income Tax 2,414 1,914 26.1%
Trade payables 55,500 38,462 44.3%
Other Short-term Liabilities 26,940 21,378 26.0%
Derivative Financial Products 126 - -
Total Short-term Liabilities 117,9 93 89,449 31.9%
TOTAL LIABILITIES 160,677 129,210 24.4%
TOTAL EQUITY & LIABILITIES 435,846 406,264 7.3%
Fixed Assets
€ 234,316 (+5.68%)
The increase is mainly a result of the im-
plementation of new investments (fixed
asset’s additions) during the year, which
are significantly greater compared to the
depreciation for the year, resulting in an
increase in the value of non-current assets
by €15,860.
Current Assets
€201,530 (9.21%)
The increase in current assets by 9.21% is
primarily attributed to the increase in in-
ventories (mainly due to the increase in
the volume of raw materials in stock) and
receivables compared to the previous year,
as a result of the heightened activity and
the increase in sold volumes, which sub-
sequently led to higher annual sales. It is
noted that, as stated below, the turnover
days of trade receivables have remained
unchanged, while the inventory turnover
days have slightly decreased.
Inventories:
€ 85,105 (18.2%)
The increase in Inventories is mainly due
to increased activity, combined with high-
er volumes of raw materials remained in
stock, compared to the previous year.
The Average Inventory Turnover Days
stood at 98 days compared to 101 days in
2023.
The Average Trade Receivables Turnover
Days remained the same (67 days) com-
pared to 2023.
Equity
€ 275,169 (-0.7%)
Equity amounted to €275,169, remaining
almost unchanged compared to Decem-
ber 31, 2023.
Provisions for Employee Benefits
(Net Asset)
€ 5,980
This current asset derives from the valua-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 44 of 370
tions of the relevant assets using the up-
dated discount rates. The largest share in
the actuarial surplus of the Group comes
from Don & Low LTD and the details of its
plan are analyzed below.
31.12.2024 31.12.2023
Present Value of
Liabilities
(100,096)
(102,405)
Present Value of
Fixed Assets
106,006 111, 8 4 0
Net Asset 5,910 9,435
The asset allocation of the plan is as follows:
Asset allocation 31.12.2024 31.12.2023
Mutual Funds (Stock Market) 71,943 78,793
Mutual Funds (Bond Market) 11,143 13,971
Mutual Funds (Diversified Growth Funds) 14,357 13,997
Other 8,563 5,079
Total
106,006 111,8 40
The assets of the plan are measured at fair
value and consist of Mutual Funds of Baillie
Gifford, Legal & General Investment Man-
agement as well as Ninety One plc.
Net Debt
€ 34,424
Net debt settled at €34,424, while on
31.12.2023 amounted to €29,569. The
Net Debt / Equity ratio stood at 0.13x on
31.12.2024 versus 0.11x on 31.12.2023. The
Group’s Net Debt / EBITDA ratio for the pe-
riod under consideration settled at 0.83x. It
is noted that on 31.12.2023 the above ratio
stood at 0.67x.
Cash and cash equivalents, and conse-
quently net debt for 2023, do not include
an amount of €13,269 related to time de-
posits, which were concluded in the previ-
ous fiscal year, with a duration of more than
three months and the relevant amount
was transferred to other receivables.
Short-term Liabilities
€ 117,993 (31.9%)
Short-term liabilities amounted to €117,993,
compared to €89,449 on December 31,
2023, showing an increase of 31.9%, which
is primarily due to the increase in suppliers
and the rise in short-term borrowings.
Trade payables
€ 55,500 (44.3%)
The average Suppliers Turnover Ratio set-
tled at 58 days versus 54 days in 2023.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 45 of 370
5. Financial Ratios
Following the above analysis, some basic Financial Ratios of the Group based on the Total
Operations are presented below:
Ratios Calculation 2024 2024 2023 Calculation 2023 Explanation
Capital Structure Ratios
Total
Liabilities/
Equity
Total Liabilities: 160,667/
Equity: 275,169
0.6 0.5
Total Liabilities: 129,210/
Equity: 277,054
Relation between
Liabilities and Equity
Net Debt/
Equity
Net Debt: 34,424/
Equity: 275,169
0.13 0.11
Net Debt: 29,569/
Equity: 277,054
Relation between Debt
and Equity
Net Debt/
EBITDA
Net Debt: 34,424/
EBITDA: 41,361
0.83 0.67
Net Debt: 29,569/
EBITDA: 44,017
Relation between
Debt and Earnings
before Interest, Taxes,
Depreciation and
Amortization
Fixed Assets/
Total Assets
Fixed Assets:
234,316/
Total Assets: 435,846
0.5 0.5
Fixed Assets: 221,725/
Total Assets: 406,264
Asset Allocation
between Current and
Non-current Assets
Current Assets/
Total Assets
Current Assets:
201,530/
Total Assets 435,846
0.5 0.5
Current Assets:
184,539/
Total Assets:
406,264
Equity/Net
Fixed Assets
Equity:
275,169 / Property, Plant
& Equipment:
193,529 +
Right-of-use Assets:
3,065
1.4 1.5
Equity:
277,054 / Property, Plant
& Equipment:
177,670+
Right-of-use Assets:
3,154
The level of financing of
the Tangible Assets from
the Equity
Leverage Ratios
Equity/Total
Assets
Equity: 275,169/
Total Assets:
435,846
0.6 0.7
Equity: 277,054/
Total Assets:
406,264
Relation between Equity
and Total Assets
Interest
Coverage
EBIT:
15,658/
Interest & related
(Expense)/Income:
2,671
5.9 8.1
EBIT:
20,663/
Interest & related
(Expense)/Income:
2,550
Interest Income-Interest
Expense Coverage from
Operating Earnings
(EBIT)
Liquidity Ratios
Current Ratio
Total Current Assets:
201,530/
Total Short-term
Liabilities: 117,993
1.7 2.1
Total Current Assets:
184,539/
Total Short-term
Liabilities: 89,449
Total Current Assets/Total
Short-term Liabilities
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 46 of 370
Ratios Calculation 2024 2024 2023 Calculation 2023 Explanation
Acid Test Ratio
Total Current Assets:
201,530
-
Inventories: 85,105/
Total Short-term
Liabilities: 117,993
1.0 1.3
Total Current Assets:
184,539- Inventories:
72,003/
Total Short-term
Liabilities: 89,449
(Total Current Assets -
Inventories)/Total Short-
term Liabilities
Profit Margins (%)
Gross Profit
Gross Profit: 77,140/
Total Turnover 370,368
20.8% 22.3%
Gross Profit: 77,069/
Total Turnover 345,373
Gross Profit/
Total Turnover
EBITDA
EBITDA 41,361/
Total Turnover 370,368
11.2% 12.7%
EBITDA 44,017/
Total Turnover 345,373
EBITDA/
Total Turnover
Adjusted
EBITDA
Adjusted EBITDA
42,256/
Total Turnover 370,368
11.4% 12.7%
Adjusted EBITDA
44,017/
Total Turnover 345,373
Adjusted EBITDA/
Total Turnover
Earnings before
Taxes
Earnings before Taxes:
13,735/
Total Turnover 370,368
3.7% 6.2%
Earnings before Taxes:
21,336/
Total Turnover 345,373
Earnings before Taxes/
Total Turnover
Earnings after
Taxes and Non-
Controlling
Interests
Earnings after Taxes
and Non-Controlling
Interests:
10,363/
Total Turnover: 370,368
2.8% 5.1%
Earnings after Taxes
and Non-Controlling
Interests:
17,767/
Total Turnover: 345,373
Earnings after Taxes
and Non-Controlling
Interests/
Total Turnover
Receivables and Payables (in days)
Average
Receivable
Days
[(Receivables: 2024
73,151+
Receivables: 2023
62,179)/2]
/
Turnover: 2024
370,368
*365 days
67 67
[(Receivables: 2023
62,179+
Receivables: 2022
64,769)/2]
/
Turnover: 2023
345,373*365 days
[(Receivables 2024
+
Receivables 2023)/2]
/
Turnover 2024*365 days
Average
Inventory Days
[(Inventories: 2024
85,105
+
Inventories: 2023
72,003)/2]
/
Cost of Sales 2024:
293,228 *365 days
98 101
[(Inventories: 2023
72,003
+
Inventories: 2022
76,415)/2]
/
Cost of Sales 2023:
268,304 *365 days
[(Inventories 2024
+
Inventories 2023)/2]
/
Cost of Sales 2024*365
days
Average
Suppliers Days
[(Suppliers 2024:
55,500+
Suppliers 2023:
38,642)/2]
/
Cost of Sales 2024:
293,228 *365 days
58 54
[(Suppliers 2023:
38,462+
Suppliers 2022:
40,630)/2]
/
Cost of Sales 2023:
268,304 *365 days
[(Suppliers 2024
+
Suppliers 2023)/2]
/
Cost of Sales 2024*365
days
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 47 of 370
Consolidated Statement of Cash Flows
In terms of consolidated cash flows, the Group recorded cash and cash equivalents of
€33,456 on 31/12/2024 compared to €27,801 on 31/12/2023.
CASH FLOWS 31.12.2024 31.12.2023
EBITDA
41,361 44,017
Non cash and non-operating movements
934 (752)
Change in working capital 5,503 7,759
Cash Flows from Operating Activities
47,798 51,024
Interest, Income Taxes & other financial expenses paid
(6,833) (4,426)
Total inflows/(outflows) from operating activities
40,965 46,598
Investing activities
(37,168) (26,670)
Financing activities
1,284 (32,190)
Net increase/(decrease) in cash and cash equivalents
5,081 (12,262)
Cash and cash equivalents at beginning of period
27, 801 39,610
Effect from changes in foreign exchange rates on cash
reserves
574 453
Cash and cash equivalents at end of period
33,456 27,801
Cash and cash equivalents, and consequently net debt for 2023, do not include an amount
of €13,269 related to time deposits, which were concluded in the previous fiscal year, with
a duration of more than three months and the relevant amount was transferred to other
receivables.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 48 of 370
In the context of its decision making con-
cerning the financial, operating and strate-
gic planning as well as the evaluation of its
performance, the Group utilizes Alterna-
tive Performance Measures (APM). These
indicators are considered by Management
to serve the better understanding of the fi-
nancial and operating results of the Group,
its financial position as well as its cash flow
statement. The Alternative Performance
Measures (APM) should be always taken
into account in line with the published an-
nual financial statements which have been
prepared according to the International
Financial Reporting Standards and in no
case the APM replace the above.
Alternative Performance Measures
In the analysis of the developments and
the performance of the Group, ratios such
as the EBIT and the EBITDA are utilized,
which are not precisely defined under the
International Financial Reporting Stand-
ards (IFRS) as adopted by the European
Union.
SECTION 7: Definition and Reconciliation of Alternative Performance Measures (APM)
ΕΒΙΤ
(The indicator of earn-
ings before financial and
investing activities as
well as taxes)
The EBIT serves the better analysis of the Group’s operating results
and is calculated as follows: Turnover minus Cost of Sales plus other
operating income minus the total operating expenses, before the fi
-
nancial and investing activities and taxes. The EBIT margin (%) is cal-
culated by dividing the EBIT by the total turnover.
EBITDA
(The indicator of operat-
ing earnings before
financial and investing
activities as well as de-
preciation, impairment
and taxes)
The EBITDA serves the better analysis of the Group’s operating re-
sults and is calculated as follows: Turnover minus Cost of Sales plus
other operating income minus the total operating expenses before
the depreciation of tangible assets, the amortization of grants and
the impairments, as well as before the financial and investing activi
-
ties and taxes. The EBITDA margin (%) is calculated by dividing the
EBITDA by the Turnover.
Adjusted EBITDA
(The adjusted indicator
of operating earnings
before financial and in-
vesting activities as well
as depreciation, impair-
ment and taxes).
The Adjusted EBITDA is the EBITDA less any restructuring, acquisi-
tion, merger, and other non-recurring expenses that may be realized
within the period / year, as well as any non-recurring gains (e.g. gain
from the sale of property, plant and equipment).
Net Debt
It is calculated as the sum of long-term loans plus long-term lease
liabilities plus short-term liabilities plus short-term lease liabilities mi
-
nus the balance of cash & cash equivalents.
Net Debt / Equity
It is calculated as the ratio of Net Debt (see above) to Total Equity.
Net Debt / EBITDA
It is calculated as the ratio of Net Debt (see above) to EBITDA.
Sustainability
Statement
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 50 of 370
Section 8: Sustainability Statement
INTRODUCTION
For Thrace Group, sustainable develop-
ment is achieved through measurable
results and implemented through innova-
tive practices. This is precisely what this
Sustainability Statement sets out to pre-
sent, by focusing on and diving deeper
into the Sustainable Development Goals
where the Group has the greatest impact,
as highlighted by the double materiality
assessment. Climate change adaptation
and mitigation, the principles of circular
economy, proper waste and microplastic
management, social issues concerning our
workforce, and business conduct have al-
ways and continue to form the core of the
Group’s culture.
This report has been prepared using the
method of full consolidation. Regarding
the double materiality analysis for iden-
tifying impacts, risks, and opportunities,
the Group has considered the entire scope
of the value chain (upstream, own opera-
tions, downstream), which is discussed in
detail in chapter IRO-1, subsection 1: Value
Chain Mapping. The disclosed policies,
actions, objectives, and data refer to the
Group’s own production operations.
In relation to the materiality analysis, the
Group discloses information related to:
ESRS 2, E1, E2, E5, S1, G1. Additional infor-
mation is published regarding the support
of local communities as a separate chapter.
The structure of the Group is as follows:
• Thrace Plastics Co S.A. (Xanthi,
Greece) – Parent company
The following subsidiaries are consolidat-
ed using the method of full consolidation:
• Don & Low LTD (Forfar, Scotland)
• Thrace Nonwovens & Geosynthetics
Single Member S.A. (Xanthi, Greece)
• Thrace Pack S.A. (Ioannina, Greece)
• Thrace Polyfilms S.A. (Xanthi,
Greece)
• Thrace Packaging DOO (Nova Pazo-
va, Serbia)
• Thrace Ipoma AD (Sofia, Bulgaria)
• Thrace Synthetic Packaging LTD
(Clara, Ireland)
• Thrace Polybulk AB (Köping, Swe-
den)
• Thrace Polybulk AS (Brevik, Norway)
The following joint ventures (JVs), where
management is shared with the other
shareholder, are consolidated using the
equity method:
• Thrace Eurobent S.A. (Xanthi,
Greece)
• Lumite Inc. (Georgia, USA)
• Thrace Greenhouses S.A. (Xanthi,
Greece)
• ThraceGreiner Packaging SRL (Sibiu,
Romania)
Regarding the financial statements, the
following companies are also fully consoli-
dated, though their size is insignificant and
8.1 General Information
BP-1 – General basis for the preparation of sustainability statements
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 51 of 370
they do not impact the sustainability mat-
ters identified through the double materi-
ality assessment:
• Thrace Protect P.C. (Xanthi, Greece)
• Trierina Trading LTD (Nicosia, Cyprus)
• Synthetic Holdings LTD (Belfast,
Northern Ireland)
• Arno LTD (Dublin, Ireland)
• Synthetic Textiles LTD (Belfast,
Northern Ireland)
• Adfirmate LTD (Nicosia, Cyprus)
• Pareen LTD (Nicosia, Cyprus)
BP-2 – Disclosures in relation to specific circumstances
Changes in preparation or
presentation of sustainability
information
For the current reporting period, signifi-
cant changes have been made in the col-
lection and presentation of sustainability
data. The main change is the transition
from the GRI standards to compliance
with the requirements set out by the Cor-
porate Sustainability Reporting Directive
(CSRD) and the European Sustainability
Reporting Standards (ESRS). This transition
also reflects the Group’s commitment to
meeting the new regulatory requirements
and aligning with them over the upcom-
ing medium-term period. To support this
transition, a centralized data collection
platform has been utilized, consolidating
all necessary sustainability-related data
in one system. This platform enhances
data integrity, effectiveness, and trans-
parency, while ensuring compliance with
the new requirements. As part of this
change, and since this platform was also
used to calculate and convert data related
to greenhouse gas emissions, there have
been changes in the methodology and
approach used to assess the Group’s envi-
ronmental footprint compared to previous
reporting years. Since this is the first re-
porting year under the ESRS standards, no
data from previous years will be used, and
any presentation of differences between
old and possibly revised data will be pro-
vided in the next report.
Data related to the value chain is taken into
account in the calculation of indirect car-
bon emissions (Scope 3). In previous years,
limited assurance was applied to the data.
The conversion of data into carbon dioxide
equivalents was based on reliable interna-
tional databases. For less significant prima-
ry data, where direct measurements were
unavailable, a spend-based approach was
applied (e.g. for business travel, end-of-
life product management, and employee
commuting).
Sustainability impacts and financial effects
are analyzed across three time horizons, as
outlined in the Group’s Risk Management
Framework, which also describes the likeli-
hood of a risk occurring:
1. Short-term: Corresponds to the pe-
riod covered by the financial state-
ments, starting from the end of the re-
porting period. It is classified as “very
likely or expected” on the risk occur-
rence probability scale.
2. Medium-term: Covers the period
from the end of the short-term hori-
zon up to 5 years, and is classified as
“likely”.
3. Long-term: Covers periods beyond 5
years and is classified as “unexpected
or rare”.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 52 of 370
Disclosure Requirements / Specific Data Points
Information regarding revenue by segment is provided in the
corresponding chapter of the Financial Statement.
Page 306
Information regarding the number of employees is included in the relevant
chapter of the Financial Statement.
Page 312
GOV1  THE ROLE OF THE ADMINISTRATIVE, MANAGEMENT, AND SUPERVISORY
BODIES
The Board of Directors (BoD) ensures that
the Group’s values and strategic planning
are aligned with its corporate culture. It also
guarantees that these values and purpose
are translated into practice and effectively
influence policies, procedures, and behav-
iors across all levels of the organization. The
BoD and senior management set the tone
for the characteristics and behaviors that
shape the corporate culture, serving as role
models in its implementation.
Board of Directors
The Board of Directors, consisting of 11
members with a five-year term, is respon-
sible for developing and monitoring the
effectiveness of corporate governance
principles and for ensuring business ethics
and compliance. There is no employee rep-
resentation on the BoD.
Konstantinos Chalioris Chairman of the BoD
Theodoros Kitsos
Vice-Chairman, Independent
Non-Executive Member
Dimitrios Malamos CEO, Executive Member
Vasileios Zairopoulos Non-Executive Member
Christos Siatis Non-Executive Member
Athanasios Dimiou Non-Executive Member
Christos-Alexis Komninos† Non-Executive Member
Georgios Samothrakis Independent Non-Executive Member
Myrto Papathanou Independent Non-Executive Member
Spyridoula Maltezou Independent Non-Executive Member
Nikitas Glykas Independent Non-Executive Member
BoD composition breakdown:
Executive Members 18.2%
Non-Executive Members 36.4%
Independent Non-Executive Members 45.4%
Female representation on the BoD* 18.2%
* (Meets the gender representation requirement set forth in Article 3 of Law 4706/2020)
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 53 of 370
Committees
All Committees operate under an approved Charter issued by the BoD, clearly defining
their role and responsibilities.
Audit Committee
Georgios Samothrakis Independent Non-Executive BoD Member - Chairman
Konstantinos Kotsilinis External (non-BoD) Member - Member
Sofia Manesi External (non-BoD) Member - Member
As outlined in its Charter, the Committee monitors the effectiveness of internal control
systems, ensures the quality of financial and non-financial reporting, oversees risk man-
agement and compliance, and supervises financial statement audits.
Remuneration and Nomination Committee
Theodoros Kitsos Chairman, Independent Non-Executive BoD Member
Nikitas Glykas Member, Independent Non-Executive BoD Member
Vasileios Zairopoulos, Member, Non-Executive BoD Member
Strategy and Investment Committee
Konstantinos Chalioris Chairman, Executive BoD Member
Dimitrios Malamos Member, Executive BoD Member
Vasileios Zairopoulos Member, Non-Executive BoD Member
Sustainability Committee
Theodoros Kitsos Chairman, Independent Non-Executive BoD Member
Konstantinos Chalioris Member, Executive BoD Member
Dimitrios Malamos Member, Executive BoD Member
Spyridoula Maltezou Member, Independent Non-Executive BoD Member
As outlined in its Charter, the Sustainabil-
ity Committee is responsible for the timely
identification of risks and opportunities
and for submitting relevant proposals to
the BoD.
The BoD has, indicatively and not exhaus-
tively, the following responsibilities in rela-
tion to sustainability matters: approval of
the Group’s long-term strategy and opera-
tional goals; assessment and prioritization
of key business risks and opportunities and
defining actions to mitigate threats and
capitalize on opportunities; responsibility
for making relevant decisions and moni-
toring the effectiveness of the manage-
ment system, including decision-making
procedures and delegation of authority
and responsibilities; commitment to and
monitoring of Management in matters
related to new technologies and environ-
mental issues; ensuring that key stakehold-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 54 of 370
ers are identified and that their collective
interests and expectations regarding cor-
porate responsibility and sustainability are
understood through established commu-
nication channels.
The members of the BoD cover a wide age
range, which combines dynamism and
experience. Most of them hold university
degrees and postgraduate qualifications
from both domestic and foreign universi-
ties and have worked in senior positions
at major companies in Greece and abroad,
operating in various sectors. Moreover,
they have served as top-level executives in
large organizations, resulting in significant
international business experience and the
ability to actively and substantially contrib-
ute to the Group’s growth prospects. They
also meet the suitability requirements and
criteria for the effective staffing and func-
tioning of the Group.
Regarding collective suitability, the com-
position of the BoD must ensure effective
governance and balanced decision-mak-
ing, with members who have complemen-
tary competencies and skills that remain
fully aligned with the Group’s current
strategies. The required criteria include
diversity, broad representation (from dif-
ferent fields of activity and a wide range
of knowledge and skills), adequate gender
representation as per the law, and repre-
sentation without any exclusion due to
any form of discrimination (gender, race,
religion or beliefs, etc.). At the same time,
care is taken to ensure that members are
able to actively and effectively participate
in strategic planning, identify and manage
potential risks, and ultimately fully under-
stand corporate governance issues and
related legislation, financial reporting, and
technological activities.
Regarding risk management, the Audit
Committee, in accordance with its Rules
of Procedure, reviews the management of
the Group’s principal risks and uncertain-
ties and their periodic reassessment. In this
context, it evaluates the methods used to
identify and monitor risks, the handling of
major risks through the internal control
system and the Internal Audit Department,
as well as the proper disclosure of these
risks in the published financial informa-
tion. Additionally, it assesses reports on
risk management at both corporate and
Group levels and informs the BoD of its
findings and submits improvement pro-
posals where necessary.
The Group CEO is responsible for imple-
menting the decisions of the BoD regard-
ing the Risk Management Framework. As
part of his responsibilities, the CEO ensures
its effective implementation, monitors key
risk indicators on a quarterly basis, and
presents the main findings to the BoD. At
the same time, a Risk Management Func-
tion Officer has been appointed to support
the CEO and the BoD in the development,
consistent implementation, and review of
the Risk Management Framework. This of-
ficer prepares the Annual Risk Report and
its management and submits it to the Au-
dit Committee and the CEO for review and
approval.
Through the Strategic Plan of each sub-
sidiary company, the goals and actions re-
lated to risks and opportunities described
within the Risk Management Framework
are defined.
As the BoD constitutes the Group’s high-
est governing body, responsible for safe-
guarding the overall corporate interest,
formulating strategy and development
policy, and enhancing its long-term eco-
nomic value, it is absolutely necessary
that this body, in terms of its composition,
possesses a diversity of skills, perspec-
tives, and competencies that effectively
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 55 of 370
contribute to the achievement of corpo-
rate objectives. In particular, individual
suitability is assessed based on specific
criteria, including the adequacy of knowl-
edge and skills/competencies in specific
areas such as knowledge of environmental
issues, contribution to improving sustain-
ability, adoption of corporate culture, and
the ability to identify and focus on key fac-
tors that drive the Group’s sustainability
and prosperity.
As described in the Internal Rules of Op-
eration, the Sustainable Development
Department is responsible for implement-
ing actions and initiatives that promote
sustainable development and create value
for stakeholders, the market, and society,
in accordance with the Sustainable Devel-
opment Policy and strategy established by
the Group.
The key responsibilities of the Sustain-
able Development Department include,
among others:
• Supporting the formulation of the
Group’s Sustainable Development
Strategy (which includes actions and
targets) and Policy, as well as the im-
plementation of related actions and
initiatives.
• Identifying and assessing Sustainable
Development risks and submitting
proposals to Management and the
Sustainability Committee to mitigate/
eliminate them.
• Communicating with stakeholders
and collecting data, as well as liaising
with relevant departments and ex-
ecutives to compile the sustainability
statement.
• Conducting awareness programs for
employees and other stakeholders on
Sustainable Development issues.
• Monitoring performance in environ-
mental, social, and governance mat-
ters.
The Sustainability Committee and the ex-
ecutives of the Sustainable Development
Department have participated in special-
ized training programs on sustainability
matters and have access to experts who
have attended Committee meetings.
GOV2  INFORMATION PROVIDED AND SUSTAINABILITY MATTERS ADDRESSED BY
THE ADMINISTRATIVE, MANAGEMENT, AND SUPERVISORY BODIES OF THE
UNDERTAKING
The Audit Committee, in accordance with
its Rules of Operation, reviews the man-
agement of the main risks and uncertain-
ties of the Group and their periodic reas-
sessment. In this context, it evaluates the
methods used for the identification and
monitoring of risks, the response to major
risks through the internal control system
and the Internal Audit Department, as well
as their proper disclosure in the published
financial information. In addition, it as-
sesses reports regarding risk management
at the corporate and Group level and in-
forms the Board of Directors of its findings,
submitting improvement proposals where
necessary. Furthermore, in a dedicated
meeting, it validated the material topics
for the Group related to the Governance
area and monitors their progress through
its regular annual meetings, based on its
Rules of Operation.
At the same time, the Sustainability Com-
mittee validated the material topics re-
lated to the Environment and Society pil-
lars and monitors their progress through
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Amounts in thousand Euro, unless stated otherwise
Page 56 of 370
its meetings in accordance with its Rules
of Operation, which is published on the
company’s website. In this way, the Sus-
tainability Committee monitors these top-
ics during its regular quarterly meetings or
more frequently if required. In all regular
meetings of the Sustainability Committee,
sustainability-related items are included
on the agenda, particularly those required
by the new directive, as evidenced by the
meeting minutes.
The main topics discussed in the Commit-
tee’s meetings include: approval of the
Non-Financial Information Report and the
Sustainability Statement draft, review of
the Sustainability Policy and Strategy, ap-
proval of sustainability training material,
updates on the data collection platform,
validation of material topics, and progress
updates regarding the CSRD directive.
Regarding risk management, the semi-an-
nual and annual risk and risk management
reports are sent by the responsible Direc-
tor (risk manager) to the Audit Committee
and the CEO for approval.
Topics related to material issues, risks,
and opportunities are primarily handled
by the Sustainability Committee, as well
as by the strategic plans of the Group’s
subsidiaries. These topics mainly include:
climate change, microplastics, recycling,
continuous investments in renewable
energy sources, reduction of energy con-
sumption in production processes, carbon
emissions, development of products with
a low environmental footprint through the
application of circular economy principles,
and providing solutions to customers that
improve their sustainability assessment.
Special training sessions are also organ-
ized for targeted groups on these topics.
Additionally, social topics are discussed,
such as safe employment, wages, social
protection, equality, health and safety
issues, human rights, the availability of
workers in local markets, as well as system-
atic employee training.
Relevant reference to the material impacts,
risks, and opportunities (IROs) is provided
in Chapter IRO-1: Subchapter VI. Connec-
tion between material IROs and ESRS top-
ics.
GOV3  INTEGRATION OF SUSTAINABILITYRELATED PERFORMANCE INTO INCENTIVE
SCHEMES
The Performance Evaluation Process cov-
ers all managerial job positions, ensuring
alignment with the Group’s strategic pri-
orities and objectives. Through the Sen-
ior Management Performance Evaluation
process, the aim is to link individual con-
tribution to the Group’s corporate goals,
using measurable and effective evaluation
criteria.
Annual objectives (and the corresponding
KPIs) are defined according to the strategic
plan and the priorities of the year and are
allocated per Division.
Climate-related factors serve as evalua-
tion and reward criteria for specific roles
that are critical to achieving the Group’s
sustainability objectives. These include, in
specific cases, the Directors of the facilities
as well as the Group’s Sustainability De-
partment.
This percentage, which refers to direct Sus-
tainability objectives (excluding produc-
tion targets, energy, health, and safety), in
relation to the total number of Directors,
is currently non-measurable. In the future,
the Group aims to better map and catego-
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Page 57 of 370
rize these objectives, as well as expand
them to more sustainability categories for
a more accurate representation of this per-
centage.
The incentive structure for these roles is
designed to reflect both the overall per-
formance of the Group and the individual
contribution to the achievement of cli-
mate-related goals.
More specifically:
• Group Performance: A percentage of
the incentives is linked to the Group’s
performance, as defined by the im-
plementation of strategic priorities in-
cluding climate-related initiatives.
• Individual Performance: The remain-
ing percentage is based on individual
performance, as assessed through
specific Performance Indicators (KPIs)
defined annually and directly linked to
the Group’s climate goals.
The indicators used to evaluate climate-
related performance include, but are not
limited to:
1. Carbon Emissions Management: Cal-
culation and monitoring of the Group’s
Carbon Emissions (Scope 1, 2, 3).
2. Achievement of Sustainability Indica-
tors: Progress against the Group’s de-
fined Sustainability KPIs, such as waste
reduction.
3. Sustainability Reports: Ensuring accu-
rate, transparent, and complete sus-
tainability reporting aligned with reg-
ulatory requirements and stakeholder
expectations.
At the beginning of each year, the Group’s
business objectives are analyzed within
the framework of the strategic plan, the
annual budget, and the sustainability-
related goals. Monitoring of goal achieve-
ment is carried out through management
reports. For the Sustainability Depart-
ment, incentives are closely linked to the
successful implementation of the Group’s
Sustainability Strategic Plan.
GOV4  DUE DILIGENCE STATEMENT
The Group places importance on and uti-
lizes the due diligence method in two key
pillars in relation to the sustainability state-
ment.
Firstly, during the double materiality pro-
cess, where the final findings and proposed
material topics were discussed in the two
relevant Committees, namely the Sustain-
ability Committee for environmental and
social issues and the Audit Committee for
governance issues. Furthermore, these
Committees examined and approved the
content of the report regarding the topics
within their jurisdiction.
The second important pillar is the identi-
fication of potential negative impacts on
the environment and society. Identified
fields include waste management, as well
as microplastic management. In both cas-
es, targeted projects have been developed
to minimize the environmental impact on
these issues. These projects lead to the
implementation of measures to prevent
or mitigate identified risks. Furthermore,
corresponding fields in the social pillar
concern human rights and the health and
safety of employees.
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Page 58 of 370
Key Elements of Due Diligence
Key Elements of Due Diligence Chapetrs
Integration of due diligence into governance, strategy, and
business model
ESRS 2 [GOV-2]
ESRS 2 [GOV-3]
ESRS 2 [SBM-3]
Interaction with stakeholders at all key steps of due diligence
ESRS 2 [GOV-2]
ESRS 2 [SBM-2)
ESRS 2 [IRO-1]
ESRS 2 MDR-P
Identification and assessment of negative impacts on people and
the environment
ESRS 2 [IRO-1]
ESRS 2 [SBM-3]
Taking action to address negative impacts on people and the
environment
ESRS 2 MDR-A
Monitoring the effectiveness of these efforts
ESRS 2 MDR-M
ESRS 2 MDR-T
GOV5  RISK MANAGEMENT AND INTERNAL CONTROLS IN SUSTAINABILITY
REPORTING
The Group has established a Non-Financial
Information Development Process, which
refers to the development of the Sustain-
ability Statement included in the Manage-
ment Report and contains information,
to the extent required for understanding
the evolution, performance, position, and
impact of its activities in relation to envi-
ronmental, social, labor issues, respect for
human rights, the fight against corruption,
bribery issues, and governance matters.
For the reporting year, the process for
communication with responsible execu-
tives and the collection of non-financial in-
formation has been followed. This process
will be further adjusted according to the
new CSRD directive, while it is currently
being implemented with the aim of estab-
lishing a unified corporate communication
framework through the adherence to com-
mon principles and rules aligned with the
Group’s strategy. The goal is to develop a
complete and integrated process by 2025.
Significant actions identified in the non-
financial information process, which are
also followed in the implementation of the
new CSRD directive, are as follows:
• Regular monitoring of the legislative
and regulatory framework as well as
best practices regarding Sustainability
Reporting.
• Definition of sustainable develop-
ment elements (ESG metrics) to be
disclosed.
• Collection of data from responsible
executives, with the identified risk of
failure to collect data on time.
• Data processing and status review.
• Draft documentation.
• Approval of the draft by the responsi-
ble Committees.
• Integration of the status in the annual
financial statement.
Additionally, the following internal risk
has been identified based on the Group’s
Risk Management System, as described
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Page 59 of 370
in: Chapter IRO-1, Subchapter D. Identifi-
cation of Risks and Opportunities: Non-
compliance with sustainability reporting
directives (CSRD, Taxonomy, CSDDD, etc.).
This identification was made as part of the
risk assessment carried out by all subsidiar-
ies of the Group. At the control level, the
corresponding departments of the subsid-
iaries, responsible for the required infor-
mation per the directive, are staffed and
trained to reduce the associated risk.
The Sustainability Committee, according
to its Rules of Operation and to address
the non-compliance risk, studies and pre-
approves the Double Materiality Assess-
ment, the annual Sustainability Statement
(ESRS), and disclosures according to the
European Taxonomy, which are part of
the annual financial statements, as well as
texts for other disclosures or evaluations
(CDP, ATHEX ESG, etc.), submitting relevant
recommendations to the Board of Direc-
tors for approval.
Furthermore, in the study for the imple-
mentation of the platform used by the
Group for the collection, consolidation,
and verification of data, the operation
method and responsibilities of each role
(data owner, data manager, verifier) are
defined, with a predefined flowchart that
depicts the functionality of all user groups
and their interaction.
In addition to the numerical data, which is
the responsibility of each subsidiary with
coordination from the Group’s side, there
is also qualitative data. Its completion is
coordinated by the Group’s Sustainable
Development Department with the assis-
tance of the HR and Risk & Compliance De-
partments. In this way, all significant areas
(ESG) are covered, and coordination with
senior management is carried out, mainly
for the actions that need to be planned
and implemented.
SBM1  STRATEGY, BUSINESS MODEL, AND VALUE CHAIN
With sustainability and innovation embed-
ded in all practices and investments con-
tinuing dynamically, the Group’s strategy
continues to deliver steady results. The
Group’s ongoing goal is to increase value
across its entire ecosystem: its employees,
its customers and supplier-partners, the
investment and consumer public, and so-
ciety at large.
Information regarding revenues and
employees
Information on employees can be found
in section S1_6 Employee Characteristics,
while information on revenues by sector is
found in the corresponding chapter of the
financial report.
Business Sectors
Technical Fabrics Sector
• Production and trade of synthetic fab-
rics for industrial and technical uses
• A broad and well-diversified product
portfolio
• Production based in Europe with a
global footprint
• Extensive sales network primarily in
Europe and the Americas
Product families contributing significant-
ly to climate change adaptation actions,
while there are no products banned in cer-
tain markets:
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Page 60 of 370
Applications:
• Construction
• Roadworks
• Greenery and gardening works
• Hospital hygiene products
• Automotive industry
• Drainage and erosion control
• Furniture, mattress
makιng
• Carpeting
• Sports, recreation
• Agriculture, horticulture, aquaculture
• Specialized uses
• Filters
• Industrial use
Packaging Sector
• Production and trade of packaging for
food and industrial products
• Market leader in Southeastern Europe
• Production based in Europe
• Extensive sales network with continu-
ous volume increases annually
Product families contributing significantly
to circular economy principles, while there
are no products banned in certain mar-
kets:
Geotextiles
(woven, nonwoven)
Geogrids
Geocomposites
Fabrics
Membranes
Film
Nets
Strapes
Ropes
Yarns
Fibres
Product Families
FIBC / filling
solutions
Bags / FFS film
Packaging / pallet
covering film
Container liners /
cargo protection
Packaging fabrics
Buckets / pails /
containers
Thermoforming
cups
Crates
Bag in box
Garbage
bags
Twines
Product Families
Applications:
• Industrial use (raw materials, chemi-
cals)
• Transportation
• Agricultural use (fertilizers)
• Construction
• Paint industry
• Food industry
• Household products
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Page 61 of 370
Agricultural Sector
• The largest hydroponic greenhouses
in Southeastern Europe
• Exclusively using geothermal energy
for heating
• Greek vegetables with almost zero
CO2 production footprint
• Cultivation based on the highest
standards
Product families:
• Cluster Tomatoes
• Beef Tomatoes
• Cherry Tomatoes
• Cucumbers
• Mini Cucumbers
• Eggplants
The operational sectors are based on the
different product groups, the Group’s
management structure, and the internal
reporting system. Using criteria as defined
by accounting standards and based on the
Group’s different activities, the Group’s
activities are divided into two sectors:
“Technical Fabrics” and “Packaging.” Infor-
mation from sectors that do not constitute
separate reporting segments is grouped
and depicted under “Others,” which in-
cludes the agricultural sector and the Par-
ent Company’s activities.
The description and financial results of the
Group’s operational sectors are as follows:
Cluster
Tomato
Mini
Cucumber
Eggplant
Mini Tomato
500gr
Beef
Tomato
Cucumber
Mini Cucumber
600gr
Mini Cucumber
750gr
Product Families
Technical Fabrics Packaging Other
Production and trade
of synthetic fabrics for
industrial and technical
uses.
Production and trade of
packaging items, plastic
bags, plastic containers for
food and paint packaging,
and other packaging
materials for agricultural
use.
Ιncludes the Agricultural sector
and Parent Company’s activities,
which, apart from investment
activities, provide Administrative
– Financial – IT services to its
subsidiaries.
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Page 62 of 370
Approach to Sustainable Development
The Group, responding to modern chal-
lenges, remains committed to its long-
standing dedication to sustainability goals
and the substantial contribution of its
business activities to a sustainable future.
This commitment is upheld by the Sustain-
able Development Department, together
with all the Group’s executives, aiming
for continuous improvement. The Group’s
goal, through the principles, policies, and
strategy for sustainable development, is to
grow with respect for society and the envi-
ronment, creating solutions for a sustain-
able future, thus remaining a reliable social
partner.
The Sustainable Development, Environ-
mental, and Social Responsibility Policy
is part of the strategy of Thrace Group. It
governs and is integrated into all process-
es and business activities, binding all the
Group’s companies.
The Group recognizes sustainable devel-
opment as one of the key challenges of
today to secure the present and future,
addressing the sustainable development
goals, the principles of the circular econ-
omy, the mitigation of the impacts of cli-
mate change, and social responsibility as
important parameters for its operations. It
is committed to monitoring and continu-
ously improving its performance using ap-
propriate indicators.
At the core of all the Group’s business prac-
tices, through the sustainable develop-
ment strategy, is the creation of value for
society and the environment, operating
based on a strong corporate governance
framework, and the Group’s pursuit of de-
veloping with respect for society and the
environment, creating solutions for a sus-
tainable future, thus remaining a reliable
social partner.
The approach to sustainable development
is based on six principles:
• application of the circular economy
• addressing climate change
• strengthening human resources
• contributing to society
• operating with integrity
• ensuring business continuity
The oversight of Sustainable Development
is carried out as follows according to the
Internal Rules of Operation:
Sustainability Committee
It is composed of executive and non-exec-
utive members of the Board of Directors,
and its primary purpose is, according to
its Rules of Operation, to study, pre-ap-
prove, and advise the Board of Directors
on the strategy, management, and moni-
toring of environmental and social sustain-
ability performance. Sustainability issues
are discussed in the Sustainability Com-
mittee based on the information received
from the Director of Sustainable Develop-
ment, who acts as Secretary, so that priori-
ties, corresponding objectives, timelines,
and monitoring of their implementation
progress can be determined. The Sustain-
ability Committee is responsible for in-
forming the other members of the Board
of Directors.
Audit Committee
According to the Rules of Operation of
the Audit Committee, it is responsible
for the management and monitoring of
corporate governance issues, in addition
to supporting the Board of Directors in
its duties concerning financial reporting
processes, internal control systems, risk
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Page 63 of 370
management, and regulatory compliance.
It is also responsible for overseeing the in-
ternal audit department and the manda-
tory audit of the annual and consolidated
financial statements.
Sustainable Development Department
Its objective is to implement actions and
initiatives that promote sustainable devel-
opment and create value for stakeholders,
society, and the environment, in accord-
ance with the policy and strategic plan for
Sustainable Development established by
the Group. The Internal Rules of Opera-
tion describe its key responsibilities.
The Sustainable Development Depart-
ment has developed the 2022-2026 Sus-
tainable Development Strategic Plan,
which has been approved by the Sus-
tainability Committee and the Board of
Directors. The Strategic Plan is based on
the following strategic axes, in line with
the related policy, each of which is bro-
ken down into specific actions, activities,
and goals. The Strategic Plan outlines the
action framework that concerns the key
product and service groups, as described
in this chapter, without excluding specific
markets or geographical areas. The main
partners of the Group in the value chain
are as follows: suppliers of raw and auxil-
iary materials (upstream) and transporta-
tion service partners (upstream and down-
stream), who have been considered during
the value chain mapping in the double
materiality analysis. Regarding the down-
stream value chain, the key partners are
the customers and end-users, who have
also been taken into account.
A detailed reference to the value chain has
been made in chapter IRO-1 – Description
of the procedures for identifying and as-
sessing significant impacts, risks, and op-
portunities, in subsection 1. Value Chain
Mapping.
Value Chain
UPSTREAM
Extraction of Raw
Materials
Manufacturing
of primary and
secondary materials
Manufacturing of raw materials (primary sources)
Manufacturing of raw materials (secondary sources)
Manufacturing of packaging
Manufacturing of secondary materials
Services
Energy & Utilities Services
Other services
Distribution
Road
Sea
OWN
OPERATIONS
Technical Fabrics
Packaging Solutions
Geothermal Hydroponic Greenhouses
DOWN-
STREAM
Distribution
Road
Sea
End Users
Technical Fabrics
Packaging
Food
Agriculture
Product End of Life
Construction Materials
Packaging Materials
Food Waste
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Page 64 of 370
The products are continuously evaluated
to align with the goals of the strategic plan
as well as the criteria of EU Taxonomy.
1. Reduction of greenhouse gas
emissions in all processes
Actions include continuously increasing
the use of recycled raw materials, reduc-
ing waste from production processes, re-
ducing energy consumption, investing in
renewable energy sources, and reducing
waste.
2. Improvement of the environmental
impact of products
Actions include sustainable product de-
sign, reducing average weight, and devel-
oping new reusable solutions.
3. Implementation of circular
economy projects
Actions include enhancing collaboration
with existing and new partners (custom-
ers, suppliers, or end users) based on cir-
cular economy initiatives and reducing
the environmental impact of the supply
chain. Such actions include entering into
long-term agreements with existing/new
customers to ensure the supply of waste
materials, developing closed/controlled
loop business models with existing/new
customers, identifying markets where
low emissions and the use of recycled raw
materials add value to the customer, or re-
ducing the environmental footprint of the
supply chain through collaboration with
partners in emission reduction initiatives.
4. Improvement of social issues
affecting stakeholders
Actions include establishing a framework
for collaboration with suppliers based on
environmental and social criteria, devel-
oping and training employees focused
on skill improvement, health and safety
issues, and the technical characteristics of
products and applications, ensuring em-
ployee health and safety, and supporting
local communities.
5. Ensuring responsible corporate
governance
Actions include raising awareness on sus-
tainable development issues, updating on
corporate governance legislation guide-
lines, ensuring proper implementation,
and integrating best practices.
6. Enhancing awareness and
obtaining appropriate
certifications
Actions include strengthening the sustain-
ability communication strategy, life cycle
analysis studies, and environmental foot-
print for each product group, acquiring
appropriate certifications, and participat-
ing in international evaluation initiatives.
This plan outlines specific goals and ac-
tions that will contribute to their achieve-
ment and applies to all the products of
the Group, which fall under the two main
sectors of its activity, namely the technical
fabrics sector and the packaging solutions
sector. At the same time, significant future
challenges are related to the new legisla-
tive framework, which mainly concerns
packaging solutions, such as the Packaging
and Packaging Waste Directive, extended
producer responsibility in categories other
than packaging, such as agricultural tech-
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Page 65 of 370
nical fabrics, or the establishment of a
framework for setting eco-design require-
ments for sustainable products.
Furthermore, future challenges concern-
ing social issues mainly relate to identify-
ing, training, and developing specialized
personnel, as well as developing supplier
monitoring mechanisms based on sustain-
ability criteria.
The Group’s main raw materials include
primary or recycled polypropylene or
polyethylene granules. For the manage-
ment of raw materials, the Group has es-
tablished the Procurement and Accounts
Payable Policy, which applies to all Group
companies and provides guidance regard-
ing the principles and basic rules set by
the Group’s Management in these areas.
In practice, the Policy aims to establish
a uniform approach to issues related to
purchasing materials, goods, and services
from suppliers, specifying all parameters
to be followed at a minimum by all com-
panies, achieving alignment with the strat-
egy, objectives, and nature of the Group’s
operations.
The key outputs relate to final products
in the technical fabrics and packaging
solutions sectors, which, through the cir-
cular economy actions described in ESRS
5, incorporate sustainability characteris-
tics (lighter, recyclable, reusable, use of
recycled raw materials, etc.) designed to
add value to the customer, the end user,
and the environment. All products of the
Group follow the guidelines and require-
ments of national and international stand-
ards and laws.
This report will not refer to disclosure re-
quirements that may not be published
during the initial phase.
SBM-2 – Stakeholder Interests and Perspectives
Establishing Dialogue with Stakeholders
Stakeholders are defined as those enti-
ties that either have a direct or indirect
impact on the Group and its activities or,
conversely, are recipients of the direct or
indirect impact resulting from its activities.
The Group maps the stakeholder groups
whose decisions affect its ability to imple-
ment its strategy and achieve its objec-
tives. For the Group, establishing dialogue
is crucial as it contributes to its effective
operation through understanding market
conditions and mitigating potential risks.
The Group has established a Corporate
Communication Policy to define a uni-
fied framework for managing corporate
communication through adherence to
common principles and rules aligned with
the Group’s strategy. The policy applies to
all companies within the Group. Through
this policy, the main stakeholder groups
and the way of approaching them have
been defined. These main groups are: (i)
Investment Community/Investors, Finan-
cial Press, Analysts, and Regulatory Au-
thorities, (ii) other entities for commercial,
marketing, conference/seminar participa-
tion, (iii) Local Communities. Communica-
tion with the Investment Community is the
exclusive responsibility of the Chief Finan-
cial Officer and the Investor Relations and
Shareholder Communications Officer. Any
other form of communication, other than
Investor Relations, such as for commercial,
marketing, seminar, conference partici-
pation, etc., requires approval from local
management and should be communi-
cated early to the Group Management and
external corporate communication advi-
sors. Finally, considering that a primary
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Page 66 of 370
goal of the Group is to engage companies
as members of local communities (in areas
such as education, culture, cooperation
with local suppliers, etc.), any significant
issue that may disrupt this relationship is
immediately communicated to the Sen-
ior Management. Regular discussions on
these matters take place at the Board of
Directors and the Sustainability and Audit
Committees.
Additionally, the Group has established a
Critical Internal and External Commu-
nication Process aimed at describing the
management of corporate communica-
tion through adherence to common prin-
ciples and rules, aligned with the vision
and values upheld by the Group, contrib-
uting to shaping the corporate culture.
This process defines communication with
external stakeholders, such as the follow-
ing: (i) Shareholders, (ii) Customers, (iii)
Investors, (iv) Suppliers/Partners, (v) Gov-
ernment and Local Authorities, (vi) Local
and Broader Communities. The process
includes sufficient and effective commu-
nication mechanisms with stakeholders
to facilitate the exercise of their rights, as
well as active dialogue with them and with
employees, as well as between employee
groups and organizational units, aiming at
a systematic and bidirectional communi-
cation approach.
The Group, aiming at the development
and awareness of its personnel, at shaping
a unified culture and establishing common
goals, communicates ethical and compli-
ance matters, legislative updates, and in-
formation about the Group’s actions and
progress to its staff. Predefined internal
communication channels with personnel
include intranet, email communication,
newsletters, and training programs.
Furthermore, the due diligence process re-
garding stakeholder interests and perspec-
tives during the double materiality process
is critical to forming a complete approach.
For this reason, the framework and scope
were initially defined with a clear identifi-
cation of regulatory requirements. Further,
when mapping and prioritizing impacts,
risks, and opportunities, stakeholder in-
terests are considered through internal
representatives in each group. This pro-
cess involves committees and operational
teams related to external stakeholders
(such as sales teams, procurement depart-
ments, investor relations, human resources
representatives, individuals related to local
communities, etc.). The entire double ma-
teriality process will be further developed
with the development of internal policies
and communication mechanisms.
SBM-3 – Material impacts, risks and
opportunities and their interaction
with strategy and business model
Through the double materiality assess-
ment, the following issues emerged as
significant for the Group (Impacts, Risks,
Opportunities – IRO):
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 67 of 370
Impact table as sources of risks/opportunities
Upstream Ows Operations Downstream Upst r e am Ows Operations Downstream
E1
Climate change
adaptation
Climate Ch an ge
Climate change
mitigation
Energy
Pollution of air
ü
Pollution of air
ü ü ü
E2 Pollution of air
Pollution of water
ü ü ü
Pollution Pollution of water
Pollution of land
ü ü ü
Pollution of land
ü ü ü
Pollution of soil
Microplastics
ü ü
Microplastics
ü ü ü
Microplastics
E3
Water an d
marine
reso u rces
E4 Cl imate Ch ange
Bio d iv ers ity and
ecosy stems
Land-use change
Direct exp l o itation
Inv asive alien species
intro duction
ü ü
Inv asive alien species
E5
Resources inflows,
including reso urce
use
Circu l ar
economy
Resource outflows
related to products
and services
Waste
ü ü
Waste
ü ü ü
Waste
S1
Own wo rkfo rce
S2
Wo rkers in the
value chain
S4 S o cial inclusio n o f
Consumers and
end-u sers
consum ers and/or
endu sers
Equality & justice Equality & justice S1
Equal treatment
and
Measures against
viol ence and
(Gender equ ality,
Ethnic/Racial
(Gender equ ality,
Ethnic/Racial
Own wo rkfo rce
opportunities for
all
harassment in the
workpl ace /
equal ity, Age
discriminatio n , Oth er
vulnerable groups)
equal ity, Age
discriminatio n , Oth er
vulnerable groups)
Co llective bargaining
S2
Equal treatment
and
Gender equ ality and
equal pay fo r
Wo rkers in the
value chain
opportunities for
all
work o f equ al value /
Div ersity /
Co llective bargaining
S1
Own wo rkfo rce
S2
Wo rkers in the
value chain
S4 Info rmation-related
Access to (qu ality)
info rm ation /
Consumers and
end-u sers
impacts fo r
consum ers
Health and safety
and/or end-users
Human rights Human rights S1
Equal treatment
and
Training and skills
devel o pment /
(Privacy, Forced labour,
Child labour)
(Privacy, Forced labour,
Child labour)
Own wo rkfo rce
opportunities for
all
Gender equ ality and
equal pay fo r
work o f equ al value
S2
Wo rkers in the
value chain
S3
Co m m u n ities’
econo mic,
Affected
communities
so cial and cultural
righ ts
S3
Affected
communities
S1
Equal treatment
and
Own wo rkfo rce
opportunities for
all
S2
Equal treatment
and
Wo rkers in the
value chain
opportunities for
all
S1
Own wo rkfo rce
S4 Info rmation-related
Consumers and
end-u sers
impacts fo r
consum ers
and/or end-users
S3
Affected
communities
Cu ltu ral rights
Mo d erate
Mo d erate
Secure
empl oyment/Adequate
wages
High
High
Access to (qu ality)
info rm ation
Low
Low
Access to Information /
Co n nectivity
ü
ü
Wo rking conditions
Cu ltu re an d heritage
ü
Rights of
indigen ou s
peop les
Educatio n
ü
ü
ü
Water an d sanitation /
Security -related imp acts
Mo d erate
High
Access to Food
ü
ü
Co m m u n ities’
econo mic, social
and cultural rights
Adequate food
High
Other work-related
righ ts
Child labour/Forced
Labour
Low
Low
Availability, Accessibility,
Affordability & Quality of
Resources & Services
Access to Water
ü
Training and skills
devel o pment
High
High
Training and skills
devel o pment
Mo d erate
High
Low
Low
Access to Edu cation
ü
Integrity & Securi ty of pe rson
ü
ü
ü
ü
ü
High
ü
ü
Wo rking conditions
Health and safety
High
Wo rking conditions
Health and safety
Mo d erate
He alt h & Safe ty
Health, Safety &
Wellbeing
ü
ü
ü
Health, Safety & Wellbein g
ü
Low
Low
High
Mo d erate
Equality & Justice
ü
ü
ü
ü
ü
High
High
Mo d erate
Mo d erate
Livelihood
Liv elih oo d
(empl oyment, wages,
social protection)
ü
ü
ü
High
High
Wo rking conditions
Ad equate wages /
Co llective bargaining
Mo d erate
Mo d erate
Livelihood
(employment, wages,
social protection)
ü
ü
ü
Wo rking conditions
Secure
empl oyment/Adequate
wages
Respo n sibl e marketin g
practices
Low
Mo d erate
Mo d erate
Circular Economy
Resource u se
ü
ü
Resource u se
ü
N/A
Mo d erate
Mo d erate
Mo d erate
Biodiversity and ecosystems
Land use change
ü
Land use change
ü
ü
ü
ü
ü
ü
Water
Water consumption
Low
Water and marine resources
Water replenishment
ü
Water use
Direct im pact
drivers o f
biodiversity loss
Low
ü
N/A
High
High
Pollution
N/A
Mo d erate
Mo d erate
Actual level of
Impact
Potential
level of
Impact
Climate change
Climate change
ü
ü
ü
Climate change
ü
ü
IROs
Positive Impacts
Ne gative Impact s
ESRS topic
ESRS sub-topic
ESRS sub-sub-topic
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 68 of 370
In Chapter IRO-1 – Description of the Pro-
cedures for Identifying and Assessing
Significant Impacts, Risks, and Opportuni-
ties in the Double Materiality Assessment
(DMA), in subsection Z. Validation of Re-
sults, the process followed regarding sig-
nificant issues in G1 is described.
More information is provided in the table
of Chapter IRO-1. The time horizons for
risks/opportunities are listed in the Risk-
Opportunity Table in subsection E. Prioriti-
zation of Risks and Opportunities.
These issues have been considered in the
Sustainable Development Policy, Environ-
mental and Social Responsibility, and pri-
marily in the Group’s Sustainable Develop-
ment Strategic Plan, where specific actions
and goals are described, analyzed in the
individual strategic plans of the subsidiar-
ies. In this way, all required actions are de-
fined and monitored to ensure progress in
all significant areas for the Group.
Thus, the Group capitalizes on sustainabil-
ity opportunities through the following
actions:
• Reduction of greenhouse gas emis-
sions across all processes, with key ac-
tions including increasing the use of
recycled materials, reducing energy
consumption, replacing electricity
from fossil fuels with renewable sourc-
es, reducing waste sent to landfills,
reducing packaging use, and reducing
water consumption.
• Improvement of the environmental
footprint of products, with key actions
including optimizing product design
(100% recyclable, monomaterial), re-
ducing average product weight, and
developing new reusable products.
• Implementation of circular economy
projects, with key actions including es-
tablishing long-term agreements with
Identified
Impacts Risks and Opportunities (IROs)*
Positive
Impact
Negative
Impact
Financially
Mate rial
(to people
and/or
nature)
(to people
and/or
nature)
ESG
Opportuniti
es
Climate change YES YES YES YES YES ESRS E1; Climate change
Climate change adaptation
Climate change mitigation
Energy
Pollution of water (Microplastics) YES YES YES ESRS E2; Pollution Microplastics
Res ource us e/Replenis hment YES YES YES YES YES ESRS E5; Circular economy
Resources inflows, including
res ou rc e us e
Resource outflows related to products
and services
Was te
Livelihood (employment, wages, social protection) YES YES YES YES ESRS S1; Own workforce
Secure employment
Adequate wages
Collective bargaining
Health and Safety YES YES YES YES ESRS S1; Own workforce Health and safety
Corruption and bribery Prevention and detection including training
Protection of whistle-blowers,
Corporate culture
Management of relationships with
suppliers, including payment practices
ESRS G1; Business Conduct
Corporate culture
YES
YES
Gender equality and equal pay for work
of equal value
Training and skills development
Measures against violence and harassment in
the workplace
Whistle-blowers, Corruption & Bribery
YES
YES
ESRS G1; Business Conduct
Working conditions
Equality & justice (Gender equality, Ethnic/Racial equality, Age
discrimination, Other vulnerable groups)
YES
YES
YES
YES
ESRS S1; Own workforce
Equal treatment and opportunities for all
Double Materiality Assessment for Actual Impacts and Current Financial Effects (2024)
Impact Materiality
Financial Materiality
Double
Materiality
of IROs
Material ESRS Topics for
Disclosure
Material ESRS Sub-Topics for Disclosure
Material ESRS Sub-sub-Topics for Disclosure
Financially
Mate rial ESG
Ris ks
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 69 of 370
customers to secure waste supply as
raw materials or reducing the environ-
mental footprint of the supply chain
through emission reduction initiatives.
• Improvement of social aspects affect-
ing all stakeholders, with key actions
including developing a Supplier Code
of Ethics and incorporating ESG criteria
in their evaluation, developing an ESG
manual for each company, continuous
training and development of employ-
ees, ensuring employee health, safety,
and well-being, and supporting local
communities.
• Ensuring responsible corporate gov-
ernance, with key actions including
organizing educational seminars, in-
forming all management teams about
corporate governance legislation
guidelines, ensuring proper applica-
tion of corporate governance legisla-
tion, and integrating best corporate
governance practices.
One of the most important factors affect-
ing the Group’s strategy is the increasing
consumer demand for sustainable and
circular products, which has led to a re-
design of product design (lighter weight,
use of a single material for a recyclable
final product, use of recycled raw materi-
als), while investments have been made to
enable the creation of recycled raw mate-
rials within the Group with the contribu-
tion of the environmental platform IN THE
LOOP. This pursuit and initiative of creating
closed-loop advanced recycling systems
has strengthened the Group’s cooperation
with suppliers and customers, thus ensur-
ing a sustainable supply chain.
To meet regulatory and market demands,
the Group has redesigned products and
expanded its product portfolio to include
reusable packaging, addressing the need
for durable, low environmental footprint
solutions. To support these strategic
changes, a series of improvements have
been implemented in production pro-
cesses. A key priority is energy efficiency,
with upgrades to production equipment
to reduce energy consumption per kilo-
gram of material produced and the grad-
ual replacement of fossil fuel-based elec-
tricity with renewable sources. Another
significant priority is the management of
solid waste. The Group has adopted waste
reduction strategies, prioritizing internal
recycling, reducing waste sent to landfills,
and material recovery.
To reduce long-term variability in energy
costs, the Group is investing in and gradu-
ally increasing the use of renewable en-
ergy sources through photovoltaic panels.
Investments in energy-efficient produc-
tion technologies and alternative energy
sources contribute to strengthening busi-
ness resilience against fluctuations in fossil
fuel prices and carbon regulatory burdens.
At the same time, recognizing the medi-
um-term risks associated with raw material
shortages, the Group has strengthened
collaborations concerning the procure-
ment of raw materials from recycled ma-
terials or post-consumer materials that are
utilized within the Group as secondary raw
materials.
Furthermore, due to increasing difficulties
in attracting specialized labor, the Group
has systematically introduced training
programs. These focus on automation,
sustainability specialization, and safety
measures, improving employee retention
and increasing long-term operational ef-
ficiency. At the same time, it strengthens
supplier monitoring mechanisms to miti-
gate risks related to their compliance with
social and environmental indicators.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 70 of 370
IRO-1 – Description of Procedures for
Identifying and Evaluating
Significant Impacts, Risks, and
Opportunities in the Double
Materiality Assessment (DMA)
The Group has adopted the Double Mate-
riality Assessment (DMA) process, which
ensures alignment with the European Cor-
porate Sustainability Reporting Directive
(CSRD) and the European Sustainability
Reporting Standards (ESRS). This process
evaluates the impacts of the Group’s activ-
ities on the environment and society, rec-
ognizing the interaction between sustain-
able practices and business development.
• Impact Materiality: This dimension
assesses the positive or negative im-
pacts of the Group’s activities on soci-
ety and the environment. It focuses on
how the Group’s operations, products,
and services contribute to or miti-
gate sustainability issues such as cli-
mate change, resource use, and social
well-being.
• Financial Materiality: This dimension
evaluates how sustainability-related
factors affect the Group’s ability to
create value. It includes the assess-
ment of the financial impacts of risks
and opportunities related to sustain-
ability, such as the effect on financial
performance, position, cash flows, ac-
cess to funding, and cost of capital in
the short, medium, and long term.
The combination of Impact Materiality and
Financial Materiality allows for the identifi-
cation of the most significant issues for the
Group.
A. Double Materiality Assessment
1. Value Chain Mapping
The first phase of the process involves
mapping the Group’s value chain, covering
all phases from the extraction of raw mate-
rials to the end-of-life of the products. This
analysis includes the following stages:
• Upstream:
> Extraction and production of raw
materials (suppliers)
> Provision of energy and services
(suppliers)
> Distribution and transportation
(distributors)
• Own Operations:
> Technical Fabrics (company
employees)
> Packaging (company employees)
> Hydroponic Greenhouses (company
employees)
> Local communities
• Downstream:
> Distribution and transportation
(distributors)
> Final use (customers, end users)
> End-of-life of products
Understanding this value chain allows
the Group to identify both positive and
negative impacts on the environment and
society.
2. Defining the Time Horizon
Sustainability impacts and financial im-
pacts are analyzed in three time horizons:
1. Short-term: Corresponds to the du-
ration of the reporting period in the
company’s financial statements
2. Medium-term: Covers the period from
the end of the short-term horizon to 5
years
3. Long-term: Includes periods beyond 5
years
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 71 of 370
3. Defining the Scoring Methodology
A scoring system is applied to assess mate-
riality based on criteria such as:
• Scale
• Scope
• Difficulty of correction
• Likelihood of occurrence
The Scoring Methodology defines a rating
system for determining the significance of
environmental and social impacts, based
on specific criteria such as scale, scope,
difficulty of correction, and likelihood of
occurrence. The scale is rated from 1 to
5, with 1 corresponding to very limited
impacts and 5 to very significant positive
or negative impacts. The scope of the im-
pacts ranges from the company’s facilities
to a global level, while the difficulty of
correction is calculated based on the time
required for restoration, ranging from im-
mediate correction to more than 30 years.
The likelihood of occurrence is classified
into five levels, from very low to very high.
The combination of these criteria results in
the determination of the severity or mate-
riality of impacts, categorized as very low,
low, moderate, high, and very high, based
on the type (Scale × Scope × Difficulty of
Correction × Likelihood of Occurrence).
At the same time, boundaries and signifi-
cant thresholds have been defined, based
on which the significant issues will emerge.
The boundaries are set as follows: low = 1,
medium = 2, high = 3+ which also defines
the significant hierarchy.
The methodology does not use specific as-
sumptions for identifying the IROs, while
risks are mentioned at the Group level
without specialization or exceptions. All
geographical areas and all sectors of oper-
ation have been considered. Furthermore,
opportunities are identified and discussed
during the annual update of the strategic
plans of the subsidiaries and are taken into
account.
B. Identification of Positive and
Negative Impacts on Nature and
People
For the analysis of the issues to be evaluat-
ed, the Group relied on international stand-
ards and guidelines such as the Taskforce
on Nature-related Financial Disclosures
(TNFD) and the United Nations Environ-
ment Programme Finance Initiative (UNEP
FI). The thematic areas that were examined
were shaped according to the guidelines
of these organizations and include:
Social Issues
• Livelihood (safe employment, wages,
social protection)
• Equality & justice
• Health, safety & well-being
• Human rights
• Access to water
• Access to food
• Access to energy
• Access to housing
• Access to education
• Access to information/connectivity
• Culture and cultural heritage
Environmental Issues
• Climate change
• Land use change
• Freshwater use changes
• Ocean use changes
• Air pollution
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 72 of 370
• Water pollution (microplastics)
• Soil pollution
• Water replenishment
• Invasive species removal
• Resource use and replenishment
The impacts identified through the value
chain mapping are classified as positive or
negative. These impacts are assessed ac-
cording to the likelihood of affecting the
environment and society, both as actual
and potential impacts, at all stages of the
value chain.
B1. Positive Environmental Impacts
Across the Value Chain
Climate Change
At the core of the Group’s activities, renew-
able energy sources represent 10% of the
total energy consumed, and this percent-
age is increasing over time. Suppliers have
adopted reuse and recyclability practices,
contributing to resource efficiency and the
principles of the circular economy, while
minimizing soil and air pollution. In pro-
duction units, production processes have
been optimized, and older machines have
been replaced with more energy-efficient
options, significantly reducing energy con-
sumption and greenhouse gas emissions.
Packaging solutions have been redesigned
to be more sustainable. Emphasis is placed
on reducing product weight and prioritiz-
ing biodegradable or recyclable materi-
als where possible. Similarly, hydroponic
greenhouses use geothermal energy,
achieving nearly zero energy footprint.
The goal for 2025 is to invest in photovol-
taic panels and green certificates, aiming
to generate 10% of energy consumption
from self-produced renewable energy. By
2030, the aim is to adopt advanced trans-
port practices, selecting routes and meth-
ods with the lowest environmental impact.
Land Use Change
The positive contribution to land use is
reflected in 2024 through the installation
of photovoltaic panels where possible. In
greenhouses, through optimal agricultural
practices, production per square meter is
maximized while maintaining excellent
quality. These methods represent a con-
trolled and sustainable approach to land
use.
Pollution and Waste Management
Addressing pollution is at the center of the
Group’s sustainability strategy and is re-
flected through the “Zero Pellet Loss” and
“Zero Waste to Landfill” initiatives in all
production facilities to prevent the release
of microplastics into the environment and
ensure optimal waste management. Waste
management practices ensure that 67.5%
of waste is recycled internally or through
licensed recyclers, while 6.6% is recovered
for energy, and two facilities have already
received zero waste to landfill certification.
In greenhouses, integrated pest manage-
ment minimizes the use of plant protec-
tion products, reducing soil and ground-
water pollution. Plant residues are used
as animal feed for local farmers, avoiding
burning or disposal into the environment.
For 2025, the Group aims to further im-
prove internal processes, reducing waste
sent to landfills through effective manage-
ment and recycling. By 2030, the goal is to
increase the number of facilities with zero
waste to landfill certification and move to-
wards a goal of eliminating plastic pellet
losses entirely.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 73 of 370
Freshwater Conservation
Through hydroponic farming methods, up
to 60% more water is saved compared to
conventional agriculture and up to 90%
more compared to traditional methods.
These practices highlight the Group’s com-
mitment to water efficiency. The aim is to
enhance water monitoring systems for
further reduction in consumption in other
facilities.
Resource Use and Circular Economy
The circular economy is at the heart of
the Group’s product development. Most
products are fully recyclable with a low
environmental footprint. The goal is to de-
velop circular solutions that will improve
the sustainable profile of partners. Over
the long term, beyond 2030, the goal is the
maximum use of recycled and recyclable
materials in all products and processes.
Pollution Reduction and Air Quality
Improvement
The facilities have a minor positive contri-
bution to air quality through practices such
as tree planting and natural carbon diox-
ide absorption at greenhouse facilities.
B2. Negative Environmental Impacts
Across the Value Chain
Climate Change
The production of raw materials, especially
from non-renewable sources, causes high
greenhouse gas emissions due to the com-
bustion of fossil fuels, such as natural gas
and oil, during production. This contrib-
utes to increased CO₂ emissions, with raw
material purchases accounting for 2/3 of
the Group’s total emissions. Continued re-
liance on non-renewable energy sources is
expected to continue having negative ef-
fects on climate change in the future.
Land Use Change
The construction of production facilities
and other infrastructure leads to signifi-
cant land use changes, such as deforesta-
tion and the conversion of natural areas for
the extraction of raw materials.
Air and Water Pollution (Microplastics)
Production processes emit very low pol-
lutants into the air, while raw material pro-
duction can cause water pollution due to
discharges containing microplastics. If this
pollution increases and is not addressed
or reduced, it will result in the dangerous
accumulation of microplastics in aquatic
ecosystems, which may have serious envi-
ronmental and health consequences.
Soil Pollution
Waste production during manufactur-
ing leads to soil pollution, as significant
amounts of waste end up in landfills. This
situation is expected to worsen if waste
management practices are not improved.
Water Consumption
Production requires quantities of water,
which can lead to increased pressure on lo-
cal water resources, especially as manufac-
turing processes expand. Excessive water
consumption, if not addressed, may cause
water scarcity in certain areas and limit the
long-term viability of our operations.
Resource Use and Recycling
The Group actively aims to increase re-
source efficiency and reduce dependence
on primary resources through recycling
and the use of secondary raw materials.
Despite progress, continued reliance on
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 74 of 370
raw materials and limited recycling in some
cases may reduce the effectiveness of ef-
forts to lower the environmental footprint.
B3. Positive Social Impacts Across the
Value Chain
Safe Employment, Wages, and Social
Protection
The Group ensures the creation of jobs
for more than 2,000 employees, offering
a high percentage of full-time and perma-
nent positions. Wages and benefits are ne-
gotiated annually with employee unions,
while employees enjoy health care for
themselves and their families, 24/7 medi-
cal services, and access to a medical net-
work. Meal vouchers are also included in
the benefits.
Equality and Fairness
The Group follows a policy that ensures
equality without discrimination based on
gender, age, or national origin. It supports
the employment of minorities, with 1/3 of
the workforce in the technical fabrics and
packaging sector and 50% in greenhouses.
No incidents of discrimination have been
reported.
Health, Safety, and Well-being
The Group implements health and safety
procedures for all employees, providing
specialized safety personnel, safety train-
ing programs, security, and continuous
workplace monitoring to reduce accidents.
Human Rights
The Human Rights Policy prohibits child la-
bor and slavery throughout the company’s
value chain. The hiring process is transpar-
ent, and all employees are over 18 years of
age. In parallel, regulations are followed
to protect personal data, and a whistle-
blowing system is in place for reporting
violations.
Access to Water
Workplaces provide water filters or bot-
tled water to employees to safeguard their
health.
Access to Food
The Group promotes social responsibility
by periodically providing food produced
in its own greenhouses to employees. It
also participates in social initiatives against
food waste and supports food dona-
tions in Greece through the organization
“Boroume.”
Access to Housing
The Group supports local communities by
ensuring, through salary levels, that em-
ployees can afford housing.
Access to Education
The Group offers training programs for
employees’ professional development.
Additionally, through the Social Center
(https://kksxalioris.gr/), access to educa-
tion and cultural development is provided
to the local community.
Access to Information and Connectivity
Employees have full access to information
through internal communication systems
and Wi-Fi to carry out their duties. The
Social Center also offers access to various
cultural and educational resources to the
local community.
Cultural Heritage
The Group actively participates in the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 75 of 370
promotion of cultural heritage through
the Social Center, offering educational and
cultural programs to the local community.
B4. Negative Social Impacts Along the
Value Chain
Secure Employment, Wages and Social
Protection
The lack of monitoring mechanisms up-
stream may lead to insufficient wages
or lack of social protection for work-
ers in the upper value chains. If work-
ing conditions among suppliers are not
properly monitored, the Group may face
complaints and social backlash, reducing
local employment and causing employee
dissatisfaction.
Equality and Justice
Inadequate monitoring of equality within
the Group may lead to discrimination, par-
ticularly regarding gender, age, or origin.
The absence of clear policies may result
in limited inclusion of women in technical
positions, as well as fairness issues in the
recruitment process, which may impact
the Group’s image and lead to negative
social response or legal consequences if
timely measures are not taken.
Health, Safety and Well-being
The lack of strict procedures for workplace
safety and health may lead to increased ac-
cidents and injuries, affecting employees’
well-being and the Group’s productivity.
Failure to identify hazardous conditions
can have serious consequences for work-
ers’ health and the company’s reputation,
with potential legal repercussions and
social pressure that could harm its public
image.
Human Rights
Failure to respect human rights in the sup-
ply chain can result in serious violations,
such as the use of child or forced labor.
Lack of transparency and inability to im-
plement the human rights policy may lead
to legal consequences and damage corpo-
rate reputation, creating trust issues with
employees, customers, and shareholders.
Access to Water
Lack of monitoring measures for access
to water in workplaces may create health
problems for employees and affect their
well-being. If proper hygiene is not en-
sured for all, the Group may face health
issues among its employees and incur in-
creased healthcare costs, impacting rela-
tionships with local communities and the
Group’s social acceptance.
Access to Food
The absence of a mechanism for monitor-
ing food production and social food con-
tribution may reduce the company’s social
responsibility and lead to food waste. With-
out a strategy to support local initiatives
and reduce food waste, the Group may
face negative publicity and social pressure,
affecting its reputation and relationships
with local organizations and communities.
C. Prioritization of Significant Impacts
The Group applies a structured method-
ology for prioritizing both existing and
potential environmental impacts arising
from its activities. This comprehensive ap-
proach ensures that current challenges are
addressed immediately, while also prepar-
ing for the achievement of future sustain-
ability goals.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 76 of 370
C1. Actual
This section focuses on existing (current)
positive and negative environmental im-
pacts resulting from the Group’s opera-
tions. It serves as a framework for clarify-
ing and optimizing the analysis of these
impacts.
• For negative impacts, the Group eval-
uates the criteria of Scale, Scope, and
Remediability to determine the sever-
ity and potential for mitigation.
• For positive impacts, the criteria of
Scale and Scope are assessed to esti-
mate their significance.
• Based on these evaluations, a Final As-
sessment is conducted, providing a
clear picture of the Group’s current en-
vironmental performance and guiding
necessary improvement actions.
C2. Potential
This section addresses the potential posi-
tive and negative environmental impacts
that may arise in the short term (1 year),
medium term (5 years), and long term (10
years). Through this proactive approach,
the Group ensures that it plans ahead for
future risks and opportunities.
• For negative impacts, the project team
assesses the criteria of Scale, Scope,
Remediability, and Likelihood in order
to prioritize actions that reduce harm.
• For positive impacts, the criteria of
Scale, Scope, and Likelihood are as-
sessed with the aim of maximizing
benefits.
• These assessments result in a Final As-
sessment, which supports the Group
in identifying priorities and aligning
its strategic initiatives with long-term
sustainability goals.
D. Identification of Risks and
Opportunities
Risks and opportunities are identified
for both nature and people, taking into
account their potential impact on the
Group’s sustainability performance. The
analysis includes factors such as economic
viability, regulatory constraints, and tech-
nological innovation. Based on the assess-
ment of risks and opportunities, the Group
prioritizes actions aimed at reducing risks
and exploiting opportunities that promote
sustainability, such as reducing dependen-
cy on raw materials and optimizing energy
use.
The Group has adopted a Risk Manage-
ment Framework, which aims at the ef-
fective management of risks through the
implementation of the Risk Management
System and incorporates the Risk Manage-
ment Policy and Procedures. The purpose
of the Framework is to promote a unified
approach to risk management for all com-
panies within the Group and to define
roles and responsibilities regarding their
management.
The Risk Management System adopted by
the Group includes all the procedures ap-
plied by the Group’s companies to identify
and manage events that may positively
or negatively affect the achievement of
their key objectives. The implementation
process of the Risk Management System
includes the methodology for managing
risks, which consists of the following stag-
es: Identification, Assessment, Monitoring,
Communication.
A Double Materiality Analysis (DMA) was
conducted within the Group to identify
the most significant sustainability risks
and opportunities that affect strategy, fi-
nancial performance, and stakeholders.
In the Risk-Opportunity table that follows,
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 77 of 370
the key impacts are presented, catego-
rized based on time horizon and their fi-
nancial effects.
Ε. Prioritization of Risks and
Opportunities
As part of the process, the economic im-
pacts of each identified sustainability risk
and opportunity are evaluated and scored
based on a specific scoring methodology.
In this way, the financial dimensions are
integrated into sustainability risks and op-
portunities, ensuring a more holistic analy-
sis for prioritizing strategic actions. The as-
sessment is based on two key parameters:
the Likelihood and the Magnitude of the
impact, which determine the Significance
of each risk and opportunity.
The magnitude of the economic impacts
is classified by category and based on a
scoring scale ranging from “Limited” to
“Significant.” Specifically, for each risk or
opportunity, the impacts on Financial Per-
formance, Cash Flows, Financial Position,
Cost of Capital, Access to Finance, and De-
velopment are analyzed.
The COSO ERM Framework methodol-
ogy, which is globally recognized, states
that the financial impact scale is defined
as significant for values over 20% of the
average of the financial variable selected
for the exercise, high for values between
10–20%, moderate for values between
5–10%, low for values between 1–5%, and
limited for values below 1%. Based on the
above variables per company, and based
on the average of the above variables for
2022 and 2023 and the respective percent-
ages, the Group defined the thresholds
per company.
A significant impact scale is defined for
values over €7,500,000, high for values
between €3,700,000 and €7,500,000,
moderate for values from €1,850,000 to
€3,700,000, low for €450,000 to €1,850,000,
and limited for values below €450,000.
The definition of these parameters ensures
an accurate assessment of the financial di-
mensions and allows for the effective pri-
oritization of the actions to be taken. The
final thresholds for the exercise represent
the sum of the corresponding amounts
per company.
Based on the specific evaluation meth-
odology and the thresholds defined for
the significance of each risk and oppor-
tunity, only those risks and opportunities
whose sum of “Likelihood * Magnitude
of Economic Impact” is significant,
high, or moderate were identified as
significant.
The application of these thresholds al-
lowed a focus on the most important
parameters affecting sustainability and
financial performance. As a result, the fol-
lowing risks and opportunities were rec-
ognized as significant:
Risks
1. Inability to manage situations related
to extreme weather events as a result
of climate change.
2. Incomplete utilization of renewable
energy sources (expansion, mainte-
nance, long-term reliability) and re-
duction of energy consumption in
production processes.
3. Lack of availability of recycled raw
materials/materials that do not com-
ply with quality and environmental
standards.
4. Lack of availability of talent in local
markets willing to work in rotating
shifts, especially experienced techni-
cal staff and workers. This may limit
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 78 of 370
recruitment effectiveness, lead to tal-
ent gaps, loss of productivity, and
higher recruitment and labor costs.
Opportunities
1. Contribution to the reduction of
Scope 3 CO2 emissions in the supply
chain through collaboration with sup-
pliers and customers.
2. Development of products with a low
environmental footprint through the
application of circular economy princi-
ples and provision of solutions to our
customers that will improve their sus-
tainability assessment.
The prioritization of risks and opportuni-
ties based on the defined thresholds en-
sures that the sustainability strategy ena-
bles the targeted development of actions
for risk management and opportunity
exploitation.
Risk – Opportunity Table
FINANCIAL EFFECT DESCRIPTION TYPE MAGNITUDE LIKEL IHOOD
Climate Change
Risk 1: Inability to manage situations associated with extreme climate-related events and
disasters.
Long-term
Increased frequency of exreme weather events
could disrupt supply chains and increase costs
Financial
Performan
ce
High Likely
Climate Change
Risk 2: Failure to fully optimize renewable energy (expansion, maintenance, long-term
reliability)
Medium-term Decrease in revenue due to increased energy costs
Financial
Performan
ce
Medium Very Likely
Climate Change
Opportunity 1: Contribute to the reduction of Scope 3 CO2 emissions in the supply chain by
collaborating with suppliers and customers.
Short-term
Increase in revenue through strengthening
collaboration with customers
Financial
Performan
ce
Medium L ikely
Dependency on resource use
(raw materials)
Risk 3: Lack of availability of recycled raw materials / materials not in compliance with
quality and environmental standards.
Medium-term
Decrease in revenue due to high raw material
costs/production difficulties
Cash Flow Medium L ikely
Resource use (water)
Risk 4: Scarcity of potable and industrial water / contamination of available water. Long-term
Problems in the production process due to a lack of
resources
Cash Flow Medium Not expected
Water/Land Pollution
Opportunity 2: Develop products with low environmental impact by applying the principles
of the circular economy and offer to our customers solutions which will improve their
sustainability rating.
Current
Increase in revenue through strengthening
collaboration with customers
Financial
Performan
ce
High Expected
Own Workforce
Working conditions
Risk: Talent availability in the local markets, w illing to work in rotating 4 shifts, especially
experienced technical staff and workers. This may limit recruitment effectiveness, lead to
talent gaps, productivity loss and higher recruitment and labor cost.
Medium-term
Finnancial effect on company's productivity and
increased operational cost
Financial
Performan
ce
High Expected
Own Workforce
Working Conditi ons
Health and Safety
Risk: Accidents risk may impact the plant productivity, increase labor cost, recruitment
cost and impact employee wellbeing.
Short-term
Financial effect on cash flow from reduced
operating costs
Financial
Performan
ce
High Likely
Own Workforce
Equal treatment and opportunities for all
Training & Skills development
Opportunity: Systematically train and upskill employees in new production technologies,
management skills and soft skills that are essencial to the business.
Current
Financial impact on the company's reputation and
future growth potential, among with high operational
costs related to upskilling the w orkforce.
Cash Flow Medium L ikely
Upstream workers in the value chain
Risk: L ack of monitoring mechanism to ensure key suppliers Social practices inherits
potential risk.
Current
Financial impact on the company's reputation due
to the potential workers's malpractices
Financial
Performan
ce
Significant Likely
Busi ness Conduct Protection of whistle-
blowers, Avoidi ng corrupti on and bribery
Risk: Violations of anti-bribery and corruption law s and regulations (including whistleblower
lawsuits) can undermine the integrity and effectiveness of internal controls and governance
structures, erode public trust, distort decision-making processes, and result in
inefficiencies, regulatory penalties, and costly litigation
Short-term
Long-term
Medium-term
Financially, this could lead to substantial regulatory
fines, legal fees, and increased compliance costs. It
may also cause revenue loss due to reputational
damage and potentially raise the company’s cost of
capital.
Financial
Performan
ce
Significant Likely
Busi ness Conduct, Corporate culture,
Management of relationships with
suppli ers, including payment practices
Opportunity: Integrating ESG practices into the corporate culture presents significant
opportunities for the organization, enhancing employee satisfaction and retention, which in
turn drives business performance, operational efficiency, and strengthens brand
image—positioning the company as a preferred insurer. A strong corporate culture serves as
a critical pillar in the company’s transformation, fostering the adoption of values and
principles that reinforce compliance with the regulatory framework
Short-term
Long-term
Medium-term
Financially, this can result in cost savings through
improved employee retention, increased revenue
from enhanced brand loyalty, greater operational
efficiency, and better access to ESG-linked
financing at lower rates.
Financial
Performan
ce
Significant Likely
IDENTIFIED IMPACTS A S SOURCES OF
RISKS/OPPORTUNITIES
IDENTIFIED RISKS AND OPPORTUNITIES
FINANCIAL EFFECT
TIME HORIZON
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 79 of 370
F. Link Between the Material IROs
and ESRS Topics
The final step in the DMA methodology
is establishing a link between the identi-
fied material issues, risks, and opportuni-
ties (IROs) and the corresponding topics
in the European Sustainability Reporting
Standards (ESRS). This ensures that the
Group’s sustainability strategy is aligned
with European regulations and addresses
key sustainability issues in a comprehen-
sive manner.
The Material IROs emerged from the prior-
itization of impacts (Step C), as well as the
prioritization of risks and opportunities
(Step E):
• Inability to manage situations related
to extreme weather events as a result
of climate change.
• Incomplete utilization of renewable
energy sources (expansion, mainte-
nance, long-term reliability) and re-
duction of energy consumption in
production processes.
• Contribution to the reduction of Scope
3 CO2 emissions in the supply chain
through collaboration with suppliers
and customers.
• Lack of availability of recycled raw
materials/materials that do not com-
ply with quality and environmental
standards.
• Development of products with a low
environmental footprint through the
application of circular economy princi-
ples and provision of solutions to our
customers that will improve their sus-
tainability assessment.
• Reduction of microplastic pollution.
• Reduction of waste sent to landfill and
not recovered.
• Lack of availability of workers in local
markets willing to work in rotating
shifts, especially experienced techni-
cal staff and workers. This may limit re-
cruitment effectiveness, lead to talent
gaps, loss of productivity, and higher
recruitment and labor costs.
• Accident risk may affect factory pro-
ductivity, increase labor and recruit-
ment costs, and impact employee
well-being.
• Systematic training and upskilling of
employees in new production tech-
nologies, management skills, and soft
skills essential to the business.
• Lack of a monitoring mechanism to
ensure that key suppliers’ social prac-
tices meet required standards poses a
potential risk.
• Employment, wages, and social pro-
tection of employees.
• Equality & fairness based on non-dis-
crimination, respect for human rights.
In this context, the following ESRS themat-
ic areas have been identified as material:
E1: Climate Change
• Climate change adaptation
• Climate change mitigation
• Energy
E2: Pollution
• Microplastics
E5: Circular Economy
• Resource inflows, including resource
use
• Resource outflows related to products
and services
• Waste
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 80 of 370
S1: Workforce
• Working conditions
• Equal treatment and opportunities for
all
G1: Governance
• Corporate culture
• Whistleblower protection
• Governance and relationships with
suppliers, including payment practices
• Corruption and bribery
Z. Validation of the Results
A meeting of the Audit Committee was
held to validate the Group’s material top-
ics based on standard G1 within the frame-
work of the new European CSRD directive.
The exercise for the Thrace Group was
completed internally based on the Double
Materiality Analysis Methodology based
on the ESRS, and out of the 6 topics, the
exercise highlighted the following as ma-
terial: Corporate culture, Whistleblower
protection, Management and relation-
ships with suppliers, including payment
practices, as well as Corruption and brib-
ery. Animal welfare was assessed as out
of scope, while Political engagement and
lobbying activities were not considered
material for the Group.
Since the area of Corporate Governance
(G) falls under the responsibilities of the
Audit Committee, the material topics con-
cerning this pillar were presented to the
Audit Committee for evaluation and ap-
proval. The Audit Committee unanimously
approved the above topics as material for
the Thrace Group.
At the same time, the Sustainability Com-
mittee convened to validate the material
topics as they emerged in accordance with
the methodology of the European CSRD
Directive regarding the Environment and
Society. Initially, the steps followed were
presented, namely the value chain map-
ping, the identification of actual and po-
tential, positive and negative impacts on
nature and people, the identification of
risks and opportunities, the prioritization
of impacts, and the alignment of impacts
with the ESRS Standards topics. Then, a
discussion was held on the material top-
ics related to the Environment and Society,
and these topics were validated by the
Committee.
IRO-2 – Disclosure requirements in the ESRS covered by the company’s
sustainability statement
The boundaries and the materiality thresh-
olds have been defined in the scoring
methodology of the double materiality
analysis (chapter IRO-1 E. Risk and Oppor-
tunity Prioritization).
ESRS DR Name of DR Page
1. General information
ESRS 2 BP-1 General basis for preparation of sustainability statements 50
ESRS 2 BP-2 Disclosures in relation to specific circumstances 51
ESRS 2 GOV-1
The role of the administrative, management and supervisory
bodies
52
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Amounts in thousand Euro, unless stated otherwise
Page 81 of 370
ESRS DR Name of DR Page
ESRS 2 GOV-2
Information provided to and sustainability matters ad-
dressed by the undertaking’s administrative, management
and supervisory bodies
55
ESRS 2 GOV-3
Integration of sustainability-related performance in incentive
schemes
56
ESRS 2 GOV-4 Statement on due diligence 57
ESRS 2 GOV-5
Risk management and internal controls over sustainability
reporting
58
ESRS 2 SBM-1 Strategy, business model and value chain 59
ESRS 2 SBM-2 Interests and views of stakeholders 65
ESRS 2 SBM-3
Material impacts, risks and opportunities and their interac-
tion with strategy and business model
66
ESRS 2 IRO-1
Description of the processes to identify and assess material
impacts, risks and opportunities
70
ESRS 2 IRO-2
Disclosure requirements in ESRS covered by the undertak-
ing’s sustainability statement
80
2. Environmental information
ESRS E1 N/A EU Taxonomy 84
ESRS E1 GOV-3
Integration of sustainability-related performance in incentive
schemes
56
ESRS E1 E1-1 Transition plan for climate change mitigation 99
ESRS E1 SBM-3
Material impacts, risks and opportunities and their interac-
tion with strategy and business model
66
ESRS E1 IRO-1
Description of the processes to identify and assess material
climate-related impacts, risks and opportunities
101
ESRS E1 E1-2 Policies related to climate change mitigation and adaptation 101
ESRS E1 E1-3 Actions and resources in relation to climate change policies 103
ESRS E1 E1-4 Targets related to climate change mitigation and adaptation 105
ESRS E1 E1-5 Energy consumption and mix 105
ESRS E1 E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions 106
ESRS E1 E1-7
GHG removals and GHG mitigation projects financed
through carbon credits
-
ESRS E1 E1-8 Internal carbon pricing -
ESRS E1 E1-9
Anticipated financial effects from material physical and tran-
sition risks and potential climate-related opportunities
-
ESRS E2 IRO-1
Description of the processes to identify and assess material
pollution-related impacts, risks and opportunities
110
ESRS E2 E2-1 Policies related to pollution 111
ESRS E2 E2-2 Actions and resources related to pollution 111
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Amounts in thousand Euro, unless stated otherwise
Page 82 of 370
ESRS DR Name of DR Page
ESRS E2 E2-3 Targets related to pollution 113
ESRS E2 E2-4 Pollution of air, water and soil 114
ESRS E2 E2-5 Substances of concern and substances of very high concern -
ESRS E2 E2-6
Anticipated financial effects from pollution-related impacts,
risks and opportunities
-
ESRS E5 IRO-1
Description of the processes to identify and assess material
re-source use and circular economy-related impacts, risks
and oppor-tunities
114
ESRS E5 E5-1 Policies related to resource use and circular economy 115
ESRS E5 E5-2
Actions and resources related to resource use and circular
economy
117
ESRS E5 E5-3 Targets related to resource use and circular economy 121
ESRS E5 E5-4 Resource inflows 122
ESRS E5 E5-5 Resource outflows 123
ESRS E5 E5-6
Anticipated financial effects from resource use and circular
economy-related impacts, risks and opportunities
-
3. Social information
ESRS S1 SBM-2 Interests and views of stakeholders 125
ESRS S1 SBM-3
Material impacts, risks and opportunities and their interac-
tion with strategy and business model
125
ESRS S1 S1-1 Policies related to own workforce 126
ESRS S1 S1-2
Processes for engaging with own workers and workers’ rep-
resentatives about impacts
128
ESRS S1 S1-3
Processes to remediate negative impacts and channels for
own workers to raise concerns
128
ESRS S1 S1-4
Taking action on material impacts on own workforce,
and approaches to mitigating material risks and pursuing
material opportunities related to own workforce, and
effectiveness of those actions
130
ESRS S1 S1-5
Targets related to managing material negative impacts,
advancing positive impacts, and managing material risks and
opportunities
132
ESRS S1 S1-6 Characteristics of the undertaking’s employees 133
ESRS S1 S1-7
Characteristics of non-employee workers in the undertak-
ing’s own workforce
136
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Amounts in thousand Euro, unless stated otherwise
Page 83 of 370
ESRS DR Name of DR Page
ESRS S1 S1-8 Collective bargaining coverage and social dialogue 136
ESRS S1 S1-9 Diversity metrics 138
ESRS S1 S1-10 Adequate wages 139
ESRS S1 S1-11 Social protection 140
ESRS S1 S1-12 Persons with disabilities 140
ESRS S1 S1-13 Training and skills development metrics 140
ESRS S1 S1-14 Health and safety metrics 140
ESRS S1 S1-15 Work-life balance metrics -
ESRS S1 S1-16 Compensation metrics (pay gap and total compensation) 141
ESRS S1 S1-17 Incidents, complaints and severe human rights impacts 141
4. Governance information
ESRS G1
GOV-1
The role of the administrative, supervisory and management
bodies
52
ESRS G1
IRO-1
Description of the processes to identify and assess material
impacts, risks and opportunities
70
ESRS G1
G1-1
Corporate culture and business conduct policies and corpo-
rate culture
145
ESRS G1
G1-2 Management of relationships with suppliers 157
ESRS G1
G1-3 Prevention and detection of corruption and bribery 158
ESRS G1
G1-4 Confirmed incidents of corruption or bribery 164
ESRS G1
G1-5 Political influence and lobbying activities -
ESRS G1
G1-6 Payment practices 166
The Disclosure Requirement and related
data point table is included in Annex 1 at
the end of the Sustainability Statement.
Support to local communities
The Group acknowledges the influence
and opportunities that its activities create
in local communities, committing to pro-
mote their prosperity and development.
It remains constantly informed about the
needs of the citizens and communities in
which it operates and aims to respond ef-
fectively to their real and essential needs.
For this reason, it focuses on actions that
offer immediate and tangible benefits.
The Group addresses social issues
with responsibility and sensitivity and
supports the communities in which it
operates:
• Contributes to the work of organiza-
tions with recognized activity in ad-
dressing social problems by support-
ing social solidarity and education
programs
• Makes donations to support vulner-
able social groups
• Has supported 16 children in need
since 2016 through the ActionAid
sponsorship program
• Develops initiatives to reduce food
waste by participating in the “Food
Rescue and Offering Network”
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 84 of 370
through the non-profit organization
“Boroume,” supporting food-aid chari-
ties throughout Greece
• Supports the operation of the Stavros
Chalioris Social Center
Stavros Chalioris Social Center
• Is a Civil Non-Profit Company based
in the Local Community of Magiko
in Xanthi, operating since 2010 and
named after the late Stavros Chalio-
ris, founder and Chairman of Thrace
Group
• Its operation aims to contribute tan-
gibly to society through actions and
activities of educational, cultural, rec-
reational, and social content
• Its actions include the support of
initiatives by the Employees’ Associa-
tion of Thrace Group, the granting of
scholarships and financial aid to local
children who wish to study but cannot
afford their education costs, as well
as financial support and coverage of
treatment/hospitalization expenses
for impoverished patients in the area
• The premises include a medical clinic
offering primary healthcare to resi-
dents of the wider area and host the
meetings of the Magiko Senior Citi-
zens Center (KAPI)
• The contemporary impacts of climate
change have led to the selection of
actions aimed at raising awareness
among local communities and chil-
dren on topics such as ecology, renew-
able energy sources, and biodiversity
preservation
Social support through the Stavros
Chalioris Social Center
2024: €493,920
2023: €410,131
2022: €412,621
8.2 Environmental Information
EU Taxonomy
I. Introduction
The EU Taxonomy Regulation is the key
tool for the “Sustainable Finance Action
Plan,” classifying environmentally sustain-
able economic activities under the follow-
ing environmental objectives:
1. Climate Change Mitigation
2. Climate Change Adaptation
3. Sustainable Use and Protection of Wa-
ter and Marine Resources
4. Transition to a Circular Economy
5. Pollution Prevention and Control
6. Protection and Restoration of Biodi-
versity and Ecosystems
The assessment is conducted based on the
established Technical Screening Criteria
(TSC) set out in the Delegated Regulations
(EU) 2021/2139, 2023/2485, and 2023/2486
of the Commission.
An economic activity is considered Eligi-
ble under the Taxonomy if it is included in
the delegated acts supplementing the Tax-
onomy Regulation, regardless of whether
it meets some or all of the TSC set forth in
these acts.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 85 of 370
An economic activity is considered
Aligned with the Taxonomy if it meets the
TSC mentioned in the Delegated Acts and
is carried out in accordance with the mini-
mum safeguards concerning the protec-
tion of human rights and consumers, the
fight against corruption and bribery, taxa-
tion, and fair competition.
Taking into account how they contribute
to or support the environmental objec-
tives, economic activities are classified as:
• Substantial Contribution Activities,
which directly contribute significantly
to one of the six environmental objec-
tives
• Transitional Activities, which support
the transition to a climate-neutral
economy
1
• Enabling Activities, which indirectly
facilitate substantial contribution ac-
tivities
2
All economic activities conducted by the
Group were examined in order to de-
termine which of them are eligible and
aligned according to the delegated acts
of the Taxonomy Regulation for climate
and environment. For this assessment,
the technical screening criteria were taken
into account.
In the assessment conducted for the
Group, the following economic activities
were examined:
3.6 Manufacture of other low carbon
technologies
For the environmental objectives of cli-
mate change mitigation and adaptation,
description 3.6 includes the manufacture
1 As referred to in Article 10(2) of Regulation (EU) 2020/852
2 As referred to in Article 10(1), point (i), of Regulation (EU) 2020/852
of technologies aimed at significantly re-
ducing greenhouse gas emissions in other
sectors of the economy not covered in sec-
tions 3.1 to 3.5 of Annex I and Annex II of
the respective delegated act on climate.
1.1 Manufacture of plastic packaging
goods
For the environmental objective of transi-
tioning to a circular economy, description
1.1 includes the manufacture of plastic
packaging goods.
II. Eligibility – Alignment with the
Taxonomy
(a) Eligibility check of the Group’s eco-
nomic activities
The table below presents the Group’s tax-
onomy-eligible economic activities and
the environmental objectives to which
they significantly contribute.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 86 of 370
Economic
Activity Based
on the EU Tax-
onomy
Activity Description
of the Group
NACE
code
Environmen-
tal Objective
Companies
3.6 Manufac-
ture of oth-er
low carbon
technolo-
gies (Del
-
egated
Reg. EU
2021/2139)
Manufacture (and sale)
of technical fabrics
(production of non-
natural fibers, weaving
of textile materials,
manufacture of nonwo-
ven items and products
from nonwoven items,
excluding clothing)
20.60
13.20
13.95
Climate
Change
Mitigation
Climate
Change
Adaptation
Thrace Nonwovens
& Geosynthetics SA
(Xanthi, Greece)
Don & Low LTD (For-
far, Scotland)
Thrace Synthetic
Packaging LTD (Clara,
Ireland)
1.1 Manu-
facture of
plastic pack-
aging goods
(Delegated
Reg. EU
2023/2486)
Manufacture of plastic
packaging goods
22.22
Transition
to a Circular
Economy
Thrace Polyfilms SA
(Xanthi, Greece)
Thrace Pack SA (Ioan-
nina, Greece)
Thrace Ipoma AD
(Sofia, Boulgaria)
3.6 Production of Other Low Carbon
Emission Technologies
According to Delegated Regulation (EU)
2021/2139, economic activity 3.6 can be
linked to the Group’s activity related to the
production of Technical Fabrics (geosyn-
thetic fabrics and nonwovens, geogrids,
insulation membranes, concrete reinforce-
ment fibers) and is considered eligible, as
technical fabrics, through their properties,
extend the life cycle of a construction or
infrastructure, are used for erosion control
and soil protection, are utilized as insula-
tion or air filters, contribute to improved
energy efficiency of buildings, and mini-
mize heat loss. Additionally, a range of
products have an Environmental Product
Declaration (EPD), which presents infor-
mation on greenhouse gas emissions
during their life cycle. All these applica-
tions of technical fabrics, membranes and
concrete fibres have a positive impact by
reducing the environmental footprint in
other sectors of the economy.
Economic activity 3.6 is identified as an En-
abling Activity and is a supportive activity
for the goal of mitigating climate change,
as it meets the Technical Screening Crite-
ria defined in the corresponding section
of the Delegated Regulation for Climate,
as applicable. At the same time, the eco-
nomic activity is considered as contribut-
ing significantly to climate change miti-
gation because it includes solutions that
significantly help prevent or reduce the
risk of negative impacts from existing and
expected future climatic conditions on
people, natural resources, or assets, while
contributing to stabilizing greenhouse gas
concentrations in the atmosphere.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 87 of 370
1.1 Production of Plastic Packaging
Goods
According to Delegated Regulation (EU)
2023/2486, economic activity 1.1 can be
linked to the Group’s NACE activity code
22.22, which refers to the manufacture of
plastic packaging items, as clearly stated
in the description of the Delegated Regu-
lation and therefore classified as eligible.
Economic activity 1.1 is identified as a Core
Activity as the production of plastic pack-
aging items significantly contributes to the
transition to a circular economy.
(b) Alignment Check of the Group’s
Eligible Economic Activities
Next, the alignment of the Group’s eligible
activities identified in the previous stage is
evaluated.
3.6 Production of Other Low Carbon
Emission Technologies
The Group’s economic activity related to
the production of Technical Fabrics sig-
nificantly contributes to the environmen-
tal goal of Mitigation of Climate Change,
as these achieve significant reductions in
greenhouse gas emissions during their life
cycle compared to alternative products/
solutions available in the market in the
construction sector.
A significant percentage of the Technical
Fabrics produced by the Group are cat-
egorized as Construction Materials and
are intended for civil engineering projects
and applications. On the one hand, Geo-
synthetics have been designed and used
either for the substantial reduction of soil
and natural resource use in infrastructure
projects or for improving the soils used
in infrastructure projects, significantly
extending the lifespan of these projects.
Recent studies have highlighted the envi-
ronmental benefit of using Geosynthetics
in infrastructure projects compared to ei-
ther conventional construction methods
(without the reduction of soil and natural
resource use) or alternative construction
methods (incorporating cement and lime-
stone products), which can reduce green-
house gas emissions by up to 90%.
On the other hand, Roof and Wall Mem-
branes (permeable and non-permeable)
contribute to improving the energy ef-
ficiency of buildings by significantly re-
ducing heating and cooling requirements
through controlling air flow, while simulta-
neously eliminating moisture leakage and
condensation phenomena. The aforemen-
tioned product families significantly con-
tribute to preventing or reducing the risk
of negative impacts from existing and ex-
pected future climatic conditions on peo-
ple, nature, and assets, without increasing
the risk of other negative effects.
Similarly, concrete reinforcement fibers
enhance the mechanical strength of the
material and significantly contribute to
extending the lifespan of infrastructure
projects, reducing the need for frequent
repairs or replacements. This results in
the reduction of raw material and energy
consumption, as well as the correspond-
ing CO₂ emissions throughout the con-
struction’s life cycle, thus contributing to
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 88 of 370
climate change mitigation
3
.
Compliance with the “Do No Significant
Harm” criteria for economic activity 3.6 is
analyzed in the following paragraphs.
The criteria for the environmental goal of
Climate Change Adaptation include the
assessment of the exposure of the eco-
nomic activity to physical climate risks,
the evaluation of impacts, and the adop-
tion of necessary mitigation measures.
Flood, heatwave, heavy snowfall/icing,
stormy winds, storms, and fire risks have
been assessed within the context of the
Emergency Response Plans of the plastic
packaging production units, and the nec-
essary mitigation measures have been
adopted. However, as a climate risk assess-
ment has not been conducted according
to the Taxonomy criteria, the Group is not
considered aligned with this specific envi-
ronmental goal.
The criteria for the environmental goal
on the Use and Protection of Water and
Marine Resources relate to risks of envi-
ronmental degradation regarding water
quality preservation and avoiding water
resource stress. The identification and
handling of these are carried out through
3 P. Stolz & R. Frischnecht, 2020: “Summary - Comparative Life Cycle Assessment of Geosynthetics
versus Conventional Construction Materials”, (https://www.eagm.eu/_files/ugd/e700f9_ba39a8ff53e-
94568a5667bf458f7fd8d.pdf)
R. Frischnecht et al., 2013: “Comparative Life Cycle Assessment of Geosynthetics versus Conventional filter
layer”, (https://www.eagm.eu/_files/ugd/345956_161b59b16ef541b6a84abe14ec944128.pdf)
C. Elsing et al., 2012: “Comparative Life Cycle Assessment of Geosynthetics versus Conventional Con-
struction Materials; Case 2: Foundation Stabilization”, (https://www.eagm.eu/_files/ugd/345956_
ffa94b70142b40969c2891771c1c555b.pdf)
K. Werth et al., 2012: “Comparative Life Cycle Assessment of Geosynthetics versus Conventional Construction
Materials; Case 3: Landfill Construction Drainage Layer”, (https://www.eagm.eu/_files/ugd/345956_c6a4d-
5f495814bf4800a2d7cfd5a7f49.pdf)
https://www.structuraltimber.co.uk/timber-systems/sustainability/
https://sta.tworadar.theweborchard.com/timber-systems/why-structural-timber/
https://www.structuraltimber.co.uk/news/construction-membranes-deliver-hidden-protection-and-ther-
mal-efficiency-benefits/
https://www.sciencedirect.com/science/article/pii/S2214509520301017
https://link.springer.com/chapter/10.1007/978-3-031-69626-8_31
the achievement of good water status and
good ecological potential, in accordance
with Directive 2000/60/EC. The Group has
adopted numerous procedures in this re-
gard and applies a series of measures such
as: i) monitoring of water consumption, ii)
integrated preventive maintenance sys-
tem to address potential leaks, iii) water
collection and recycling systems, iv) auto-
matic shut-off valves at drinking water us-
age points, etc.
The criteria for the environmental goal of
Circular Economy check the alignment
of the activity, where applicable, as well as
the technical adaptations, design for high
durability and recyclability, and waste
management that promotes recycling in-
stead of final disposal. The production of
Technical Fabrics and membranes in the
Group’s companies aims both at maxi-
mum reuse as well as the highest recycling
percentage of the produced waste. The
primary focus remains on their high dura-
bility, as demonstrated in the references,
and for this reason, their contribution to a
waste-free circular economy.
For compliance with the criteria for the
Protection and Restoration of Biodiver-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 89 of 370
sity and Ecosystems, the Group’s facili-
ties have an active environmental permit
for their operation. Additionally, the loca-
tions of the Group’s European production
units are not within or near sensitive areas
for biodiversity, including the Natura 2000
network, as well as other protected areas,
as shown on the map of the Group’s facili-
ties in Europe.
The criteria for the environmental goal of
Pollution Prevention and Control in-
clude the avoidance of the preparation
and market disposal or use of various haz-
ardous substances. The Group does not
use chemicals or other hazardous sub-
stances that fall under national or interna-
tional restrictions.
1.1 Production of Plastic Packaging
Items
The production of plastic packaging items
(NACE 22.22) is an eligible activity for
which its alignment has been assessed.
The Group’s economic activity in the pro-
duction of plastic packaging products
significantly contributes to the environ-
mental goal of transitioning to a circular
economy, as it includes groups of products
that meet the technical criteria for control,
i.e., they use circular raw materials accord-
ing to the criteria of paragraph 1.1.1.1.a),
the packaging unit is made from the same
material (single material solution), and in
any case, the materials contained are com-
patible with the existing recycling streams
and sorting processes. Additionally, no
substances with hazardous properties, as
described in paragraph 1.1.1.3, are added
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 90 of 370
to the raw material during the production
of the packaging material.
The compliance with the “do no signifi-
cant harm” criteria for the economic ac-
tivity 1.1 is discussed in the following para-
graphs.
The criteria for the environmental goal of
Mitigation of Climate Change include
the assessment of greenhouse gas emis-
sions throughout the life cycle of the man-
ufactured plastic. This assessment is com-
pared with the emissions of equivalent
materials, considering factors such as the
origin of raw materials (primary or recy-
cled), the energy efficiency of the produc-
tion process, and the recyclability or reuse
potential.
The criteria for the environmental goal of
Climate Change Adaptation include the
assessment of the exposure of the eco-
nomic activity to physical climate risks, the
evaluation of impacts, and the implemen-
tation of necessary mitigation measures.
Flood risks, heatwaves, heavy snowfall/ice,
stormy winds, storms, and fires have been
assessed within the Emergency Response
Plans of the plastic packaging production
units, and the necessary mitigation meas-
ures have been adopted. However, since
no climate risk assessment has been con-
ducted according to the criteria of the Tax-
onomy, the Group is not considered aligned
with this specific environmental goal.
The criteria for the environmental goal
of Sustainable Use and Protection of
Water and Marine Resources are re-
lated to environmental risks concerning
the preservation of water quality and the
avoidance of water resource depletion.
Their identification and management are
achieved by ensuring good water status
and good ecological potential, in accord-
ance with Directive 2000/60/EC. In the
framework of the valid environmental per-
mit of the production facilities, potential
risks in this category have been identified
and are monitored.
The criteria for the environmental goal of
Pollution Prevention and Control in-
clude the avoidance of the preparation
and market disposal or use of various haz-
ardous substances. The Group does not
use chemicals or other hazardous sub-
stances that fall under national or interna-
tional restrictions.
For compliance with the criteria for the
Protection and Restoration of Biodiver-
sity and Ecosystems, the Group’s facilities
have an active environmental permit for
their operation.
(c) Minimum Safeguards
The Group places great emphasis on labor
issues, such as employees’ rights, ensuring
health and safety in the workplace, train-
ing, and education for employees. It also
acknowledges the impact it has and the
opportunities created for local communi-
ties through its activities. The Group’s over-
all approach to the above issues makes its
economic activities aligned with the Tax-
onomy Regulation, as compliance with the
Minimum Safeguards (MS) requirements
of the Regulation is achieved.
The Group’s economic activities are car-
ried out in accordance with the OECD
Guidelines for Multinational Enterprises
(OECD Guidelines for Multinational En-
terprises), the UN Guiding Principles on
Business and Human Rights, including the
principles and rights outlined in the eight
core conventions defined in the Interna-
tional Labour Organization’s Declaration
on Fundamental Principles and Rights at
Work and the Universal Declaration of Hu-
man Rights.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 91 of 370
The MS aim to cover the following four ar-
eas: Human Rights (including labor rights
and consumer rights), Anti-corruption and
bribery, Taxation, Fair competition.
Human Rights (including labor rights
and consumer rights)
The Group’s Code of Ethical Conduct re-
fers to various international standards and
initiatives that it is committed to follow-
ing through its implementation. Regard-
ing human rights and labor relations, the
Group is committed to respecting human
rights and promoting diversity and equal
representation, following international
guidelines and standards.
The Group has established a Human Rights
Policy, which shows zero tolerance for har-
assment in the workplace, any form of
discrimination based on race, gender, re-
ligion, nationality, age, disability, orienta-
tion, etc., forced and child labor, both with-
in the Group’s companies and throughout
its supply chain. The policy is based on
the commitment to uphold Human Rights
as defined by internationally recognized
standards and guidelines such as the Uni-
versal Declaration of Human Rights of the
United Nations, the United Nations Global
Compact Principles, the ILO Declaration
on Fundamental Principles and Rights at
Work, and the OECD Guidelines for Multi-
national Enterprises.
Additionally, the Group is committed to
strengthening mechanisms and processes
for preventing and addressing violence
and harassment, and has implemented a
Policy for the Prevention and Combat of
Workplace Violence and Harassment. Fur-
thermore, it has established a Sustainable
Development, Environmental, and Social
Responsibility Policy, through which the
Group makes corporate social responsibil-
ity part of its strategy and addresses social
issues with foresight and sensitivity.
Moreover, the Group has incorporated
these issues into the criteria for selecting
partners (corresponding section in G1-2),
and these issues are analyzed in the chap-
ter on policies related to its own workforce,
specifically addressing human trafficking,
forced or compulsory labor, and child la-
bor in section S1.
Additionally, regarding human rights,
based on the Code of Ethical Conduct and
Professionalism, the Group shows zero tol-
erance for harassment in the workplace,
for any form of discrimination based on
race, gender, religion, nationality, age, dis-
ability, orientation, etc., and for forced and
child labor, both within the Group’s com-
panies and across its entire supply chain.
The Group applies criteria for selecting and
evaluating partners to avoid engaging in
labor relationships with entities at high risk
of human rights violations and is commit-
ted to continuously improving actions and
controls regarding human rights in its in-
teractions with suppliers and partners. The
Group is committed to recognizing, evalu-
ating, preventing, and eliminating the risks
of human rights violations, applying due
diligence and taking immediate corrective
actions to address any incidents. Specifi-
cally, it is committed to raising employee
awareness through information and train-
ing, promoting respect for and the protec-
tion of human rights across all activities,
as well as promptly addressing incidents
through the violation reporting mecha-
nism, enabling employees to express their
concerns and report human rights viola-
tions. At the same time, it is committed to
investigating and addressing employee
concerns and resolving complaints by tak-
ing corrective actions.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 92 of 370
Taxation
The Group produces and distributes,
through its business activities and the
achievement of high performance, both
directly and indirectly, economic value to
the social community in which it operates,
with particular emphasis on: (a) strength-
ening the economies of the countries in
which it operates, through the cash flows
it creates towards stakeholders, specifi-
cally tax payments, payments to suppliers,
salary payments to employees, dividends
to shareholders, and investments in local
communities, (b) meeting the needs of the
communities surrounding the Group and
affected by its activities, and (c) creating
employment opportunities through the
direct and indirect creation and mainte-
nance of jobs.
Combating Corruption and Bribery
The Group is committed to zero toler-
ance regarding corruption and bribery. To
achieve this, it has adopted a comprehen-
sive framework of principles and policies
that ensure transparency and responsible
operation, conducts annual updates and
audits through the Internal Audit Depart-
ment, has established disciplinary meas-
ures, and has formed an Audit Committee.
Furthermore, the Group has established
an Anti-Fraud Policy. In order to prevent
incidents of corruption and bribery, it op-
erates proactively, conducting annual up-
dates and audits through the Internal Au-
dit Department, and disciplinary measures
have been established.
Fair Competition
The Group’s firm commitment is to con-
duct its business activity with integrity, in
accordance with the highest ethical stand-
ards, and by applying applicable laws. The
Group’s Code of Ethical Conduct and Pro-
fessionalism sets out the behavioral stand-
ards required from employees.
(d) Eligibility and Alignment with the
Taxonomy
Both economic activity 3.6 and economic
activity 1.1 are eligible but not aligned
with the taxonomy, as they relate to the
following three criteria:
• Contribute significantly to Mitigat-
ing Climate Change (3.6) and to the
Transition to a Circular Economy (1.1),
based on the Technical Screening Cri-
teria.
• Do not significantly harm (DNSH)
the other four environmental objec-
tives, except for Climate Change Ad-
aptation.
• Meet the minimum safeguards (MS),
as outlined in the Taxonomy Regula-
tion.
III. Key Performance Indicators (KPIs)
The KPI of Revenue, as stated in the EU
Taxonomy Regulation, is defined as the
net revenues according to IFRS, as pre-
sented in the consolidated financial state-
ments, and pertains to fully consolidated
subsidiaries.
Considering that the Group does not en-
gage in any activities related to natural gas
and nuclear energy (activities 4.26-4.31),
the specific standards introduced by the
Complementary delegated regulation
concerning activities in certain energy sec-
tors are not applied.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 93 of 370
Based on point 1.2.3 of paragraph 1 of Del-
egated Regulation (EU) 2021/2178, the Key
Performance Indicators (KPIs) of joint ven-
tures will not be presented in this report.
The ratio of economic activities aligned
with the Taxonomy to total turnover is cal-
culated as the part of net turnover derived
from products and services related to eco-
nomic activities aligned with the Taxono-
my (numerator) divided by total turnover
(denominator) for the relevant financial
year.
The numerator of the KPI of turnover is
defined as the net turnover derived from
products and services related to econom-
ic activities aligned with the Taxonomy.
The denominator of the KPI of turnover is
based on the consolidated net turnover
according to paragraph 82(a) of IAS.
The KPI of Capital Expenditures (CapEx),
as referred to in the Taxonomy Regulation,
is calculated on a gross basis, meaning that
remeasurements, depreciation, or impair-
ment losses are not accounted for. CapEx
includes investments in non-current intan-
gible assets and tangible fixed assets as
presented in the consolidated statement
of financial position. It is defined as the
Activities related to nuclear energy and natural gas
Activities related to nuclear energy
1. The company carries out, funds, or is exposed to research, development,
demonstration, and implementation of innovative power generation
plants that produce energy from nuclear processes with minimal waste
from the fuel cycle.
No
2. The company carries out, funds, or is exposed to the construction and
safe operation of new nuclear facilities for electricity generation or ther-
mal processing, including facilities for district heating or industrial pro-
cesses such as hydrogen production, as well as their safety upgrades,
using the best available technologies.
No
3. The company carries out, funds, or is exposed to the safe operation of
existing nuclear facilities that generate electricity or thermal process-
ing, including facilities for district heating or industrial processes such
as hydrogen production from nuclear energy, as well as their safety
upgrades.
No
Activities related to natural gas
4. The company carries out, funds, or is exposed to the construction or
operation of power generation plants that use fossil gas fuels.
No
5. The company carries out, funds, or is exposed to the construction,
renovation, and operation of cogeneration heat/cooling and electricity
generation plants that use fossil gas fuels.
No
6. The company carries out, funds, or is exposed to the construction, reno-
vation, and operation of heat/cooling generation plants that use fossil
gas fuels.
No
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 94 of 370
fraction of Taxonomy-aligned CapEx (nu-
merator) divided by total CapEx (denomi-
nator).
Total Capital Expenditures consist of ad-
ditions to tangible and intangible fixed
assets during the period, before deprecia-
tion and any remeasurements, including
those arising from adjustments and im-
pairments, as well as exceptions for chang-
es in fair value. It also includes acquisitions
of tangible fixed assets (IAS 16), intangible
assets (IAS 38), right-of-use assets (IFRS 16),
and investments in real estate (IAS 40). Ad-
ditions arising from business combinations
are also included. Goodwill is not included
in CapEx, as it is not defined as an intangi-
ble asset under IAS 38.
The numerator consists of the following
categories of CapEx that are eligible:
a) CapEx related to assets or processes
related to economic activities aligned
with the Taxonomy (“category a”):
CapEx invested in buildings, equip-
ment, machinery, intangible assets is
considered.
b) CapEx that is part of a plan to upgrade
an economic activity that is eligible for
the Taxonomy to become aligned with
the Taxonomy or to expand an eco-
nomic activity aligned with the Tax-
onomy (“category b”): The Group does
not have any CapEx in this category.
c) CapEx related to the purchase of
production from economic activities
aligned with the Taxonomy and indi-
vidual measures that enable certain
target activities to become low-car-
bon or lead to reductions in Green-
house Gas emissions (“category c”):
The Group does not have any CapEx in
this category.
The Group’s CapEx agrees with the Annual
Financial Statements. It is the total move-
ment types (acquisition and production
cost): additions and additions from busi-
ness combinations for intangible assets,
right-of-use assets, tangible fixed assets,
and investments in real estate.
For the calculations of CapEx and OpEx re-
lated to economic activities aligned with
the Taxonomy, double counting is avoid-
ed. To achieve this, only one measurement
of CapEx (and corresponding OpEx) of re-
lated purchases and individual measures
related to assets or processes concerning
Taxonomy-aligned economic activities
was measured once. These include pro-
duction buildings and mechanical equip-
ment. Each time a single investment is
considered aligned with the Taxonomy,
the relevant proportion of CapEx is not
recorded again in a (partially) Taxonomy-
aligned economic activity to avoid double
counting.
The KPI of Operating Expenses (OpEx),
as stated in the Taxonomy Regulation,
includes non-capitalizable expenses pre-
sented in the consolidated income state-
ment, such as research and development
expenses, building renovation measures,
short-term leases, maintenance and re-
pairs, and all other direct expenses arising
from the maintenance of assets, facilities,
and equipment to ensure the operational
capacity of assets eligible for the Taxono-
my. It is defined as the fraction of Taxon-
omy-aligned OpEx (numerator) divided by
the total OpEx (denominator).
The total OpEx consists of direct non-cap-
italized expenses related to research and
development, building renovation meas-
ures, short-term leases, as well as all forms
of maintenance and repair. Specifically:
• Research and development expenses
recognized as expenses during the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 95 of 370
reporting period in the income state-
ment.
• Maintenance and repair expenses in-
curred at the Group’s facilities.
• The volume of non-capitalized leases
was determined according to IFRS
16 and includes expenses for short-
term leases and leases of low value, as
shown in the Annual Financial State-
ments.
Detailed Information
KPI of Operating Expenses – Quantita-
tive Analysis of the Numerator
The following table presents the quantita-
tive breakdown of the numerator for the
BDE of Operating Expenses.
Quantitative Breakdown / Numerator
of BDE Operating Expenses
Turnover
(in million €)
Customer Contracts 125.92
Other Revenues 0
Total 125.92
BDE of Capital Expenditures (CapEx)
– Quantitative Analysis at the Consoli-
dated Activity Level
The next table includes an analysis of the
amounts included in the numerator.
Quantitative Breakdown / Numerator
of BDE CapEx
CapEx
(in million €)
Additions to Materials 10.90
Intangible Assets 0.01
Right-of-Use Assets 0.27
Total 11.18
Upgrade and Expansion Plan
The Group’s facilities are continuously up-
graded to remain safe and operational,
while also meeting the needs of the Group
due to ongoing investments in mechanical
equipment and photovoltaic panels.
KPI of Operating Expenses (OpEx) –
Quantitative Analysis of the Numerator
The following table shows the breakdown
of the numerator of the BDE OpEx into its
components based on the definition of
OpEx under the disclosure law. Note that
compared to 2022, the cost of salaries for
maintenance and repairs has also been in-
cluded:
Quantitative Breakdown / Numerator
of BDE OpEx
OpEx
(in million €)
R&D Costs 1.07
Maintenance and
Repairs
2.35
Maintenance and
Repairs Salaries
2.45
Leases 0.20
Total 6.07
Percentage of Turnover / Total Turnover
Alignment with the Taxonomy by Goal
Eligibility with the Taxonomy by Goal
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 96 of 370
% of Turnover / Total % of CapEx / Total CapEx % of OpEx / Total OpEx
Taxonomy
Alignment
per Objective
Taxonomy
Eligibility per
Objective
Taxonomy
Alignment
per Objective
Taxonomy
Eligibility per
Objective
Taxonomy
Alignment
per Objective
Taxonomy
Eligibility per
Objective
CCM - 32.0% - 22.1% - 34.4%
CCA - - - - - -
PW - - - - - -
CE - 2.0% - 4.9% - 2.3%
PPC - - - - - -
BIO - - - - - -
Financial Year 2024
Economic Activities (1)
Code (2)
Turnover, mil. € (3)
Proportion of Turnover, year 2024 (4)
Climate Change Mitigation (5)
Climate Change Adaptation (6)
Water (7)
Pollution (8)
Circular Economy (9)
Biodiversity (10)
Climate Change Mitigation (11)
Climate Change Adaptation (12)
Water (13)
Pollution (14)
Circular Economy (15)
Biodiversity (16)
Minimum Safeguards (17)
Proportion of Taxonomy- aligned (A.1.) or -eligible (A.2.)
turnover, year 2022 (18)
Category enabling activity (19)
Category transitional activity (20)
Text Currency %
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y/N Y/N Y/N Y/N Y/N Y/N Y/N % Ε T
Manufacture of other low carbon technologies
CCM 3.6 0 0% Y N N N N N 39.3 Ε
Manufacture of plastic packaging goods
CE 1.1 0 0% N N N N Y N -
Turnover of environmentally sustainable activities (Taxonomy-
aligned) (A.1)
0 0% 39.3
Of which enabling
0 0% 39.3 E
Of which transitional 0%
T
Turnover of Taxonomy- eligible but not environmentally
sustainable activities (not Taxonomy-aligned activities) (Α.2)
Manufacture of other low carbon technologies
CCM 3.6 118.65 32.0%
Manufacture of plastic packaging goods
CE 1.1 7.27 2.0%
Α. Turnover of Taxonomy-eligible activities (Α.1 + Α.2)
125.92 34.0%
Turnover of Taxonomy- non-eligible activities 244.45 66.0%
TOTAL
370.37 100%
Α.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
Proportion of Turnover from products or services associated with Taxonomy-aligned economic activities - disclosure covering year 2024
Year Substantial contribution criteria
DNSH criteria (“Does Not
Significantly Harm”)
Α. TAXONOMY-ELIGIBLE ACTIVITIES
Α.1 Environmentally sustainable activities (Taxonomy-aligned)
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 97 of 370
Financial Year 2024
Economic Activities (1)
Code (2)
CapEx, mil. € (3)
Proportion of Turnover, year 2024 (4)
Climate Change Mitigation (5)
Climate Change Adaptation (6)
Water (7)
Pollution (8)
Circular Economy (9)
Biodiversity (10)
Climate Change Mitigation (11)
Climate Change Adaptation (12)
Water (13)
Pollution (14)
Circular Economy (15)
Biodiversity (16)
Minimum Safeguards (17)
Proportion of Taxonomy- aligned (A.1.) or -eligible (A.2.)
turnover, year 2022 (18)
Category enabling activity (19)
Category transitional activity (20)
Text
Currency %
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y/N Y/N Y/N Y/N Y/N Y/N Y/N % Ε T
Manufacture of other low carbon technologies
CCM 3.6 0 0% Y N N N N N 32.0 Ε
Manufacture of plastic packaging goods
CE 1.1 0 0% N N N N Y N -
CapEx of environmentally sustainable activities (Taxonomy-
aligned) (A.1)
0 0% 32.0
Of which enabling
0 0% 32.0 Ε
Of which transitional 0%
T
CapEx of Taxonomy- eligible but not environmentally
sustainable activities (not Taxonomy-aligned activities) (Α.2)
Manufacture of other low carbon technologies
CCM 3.6 9.15 22.1%
Manufacture of plastic packaging goods
CE 1.1 2.03 4.9%
Α. CapEx of Taxonomy-eligible activities (Α.1 + Α.2)
11.18 27.0%
CapEx of Taxonomy- non-eligible activities 30.25 73.0%
TOTAL
41.43 100%
Α.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
Proportion of CapEx from products or services associated with Taxonomy-aligned economic activities - disclosure covering year 2024
Year Substantial contribution criteria
DNSH criteria (“Does Not
Significantly Harm”)
Α. TAXONOMY-ELIGIBLE ACTIVITIES
Α.1 Environmentally sustainable activities (Taxonomy-aligned)
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 98 of 370
Financial Year 2024
Economic Activities (1)
Code (2)
OpEx, mil. € (3)
Proportion of Turnover, year 2024 (4)
Climate Change Mitigation (5)
Climate Change Adaptation (6)
Water (7)
Pollution (8)
Circular Economy (9)
Biodiversity (10)
Climate Change Mitigation (11)
Climate Change Adaptation (12)
Water (13)
Pollution (14)
Circular Economy (15)
Biodiversity (16)
Minimum Safeguards (17)
Proportion of Taxonomy- aligned (A.1.) or -eligible (A.2.) turnover,
year 2022 (18)
Category enabling activity (19)
Category transitional activity (20)
Text Currency %
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y; N;
N/ΕL
Y/N Y/N Y/N Y/N Y/N Y/N Y/N
% ΕT
Manufacture of other low carbon technologies
CCM 3.6 0 0% Y N N N N N 44.5 Ε
Manufacture of plastic packaging goods
CE 1.1 0 0% N N N N Y N -
OpEx of environmentally sustainable activities (Taxonomy-
aligned) (A.1)
0 0% 44.5
Of which enabling
0 0% 44.5 Ε
Of which transitional 0%
T
OpEx of Taxonomy- eligible but not environmentally
sustainable activities (not Taxonomy-aligned activities) (Α.2)
Manufacture of other low carbon technologies
CCM 3.6 5.69 34.4%
Manufacture of plastic packaging goods
CE 1.1 0.38 2.3%
Α. OpEx of Taxonomy-eligible activities (Α.1 + Α.2)
6.07 36.7%
OpEx of Taxonomy- non-eligible activities 10.45 63.3%
TOTAL
16.52 100%
Α.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
Proportion of OpEx from products or services associated with Taxonomy-aligned economic activities - disclosure covering year 2024
Year Substantial contribution criteria
DNSH criteria (“Does Not
Significantly Harm”)
Α. TAXONOMY-ELIGIBLE ACTIVITIES
Α.1 Environmentally sustainable activities (Taxonomy-aligned)
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 99 of 370
ESRS E1 Climate Change
E1-1: Transition Plan for Climate
Change Mitigation
The Group, taking into account the targets
set for the use of energy from renewable
sources and the continuous effort to re-
duce energy consumption in production
processes as well as the ongoing improve-
ment of the measurement and reporting of
carbon emissions across all companies and
their entire scope (scope 1, 2, 3), has laid
the foundations for developing a compre-
hensive transition plan for climate change
mitigation. This plan will include detailed
information about the greenhouse gas
emission reduction targets, explaining
their alignment with limiting global warm-
ing to 1.5°C, in accordance with the Paris
Agreement. It will also describe the decar-
bonization mechanisms and actions re-
quired to achieve these targets.
The Group continuously adapts its busi-
ness model to reduce its carbon footprint.
Thus, it has already established solid foun-
dations to develop a mature and realistic
transition plan that will define the reduc-
tion targets for the period 2026-2030. Hav-
ing recognized both physical and transi-
tion risks, it is evolving this approach and
aligning the priorities of all companies
within the Group.
Furthermore, the Group’s carbon footprint
has been calculated over several years for
all areas, i.e., scope 1, 2, 3. This enables the
assessment of all emission categories and
the identification of key actions that must
be taken to reduce emissions representing
the highest proportion, namely energy,
materials, and transportation.
The key actions being considered are as
follows:
• Reduction of energy consumption
• Optimization of the use of renewable
energy sources
• Investment in renewable energy
sources
• Use of recycled raw materials
• Use of raw materials with a low envi-
ronmental impact
• Improvement of packaging impact
• Improvement of transportation
impact
• Optimization of waste management
These actions are directly linked to the
Group’s strategic plan regarding sustain-
able development, and for many of them,
improvement targets and actions have al-
ready been set to achieve these goals.
Additionally, the required synergies across
the entire value chain are being explored
to enable any reductions sought, with
priority given to those that significantly
contribute to our overall emissions. In fact,
opportunities in the value chain have been
identified, such as dialogue with selected
suppliers to explore joint sustainability
improvement opportunities, as well as en-
couraging suppliers to provide Environ-
mental Product Declarations (EPDs) and
other sustainability-related information.
E1-1_16
The plan will be completed within 2026
and will refer to the period 2026–2030,
contributing to the alignment of the
company’s strategy with environmental
objectives.
ESRS2: SBM3 Material impacts, risks
and opportunities and their
interaction with strategy and
the business model
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 100 of 370
E1.SBM-3_01
Climate change and the energy transition
clearly affect the Group’s activities and are
issues that are monitored and taken into
account in the Group’s Strategic Plan. At
the same time, they create significant op-
portunities, either through the optimiza-
tion of energy consumption in production
processes, or through the principles of
the circular economy—namely increas-
ing the use of recycled raw materials or
developing sustainable products—as well
as through investments in and utilization
of renewable energy sources, mainly geo-
thermal energy and photovoltaics. The
Group recognizes the risks that may arise
in its business operations due to climate
change, such as the inability to manage
situations related to extreme weather
events and disasters (climate-related
physical risk), or the suboptimal utiliza-
tion of renewable energy sources, includ-
ing expansion, maintenance, and long-
term reliability (climate-related transition
risk). To mitigate risks and avoid negative
socio-economic and environmental im-
pacts, the Group continuously updates
its knowledge, monitors international
developments, and adjusts its business
model, having recognized both the risks
associated with climate change and the
opportunities for transitioning to a low-
carbon business model with an emphasis
on innovation.
Resilience Analysis
E1.SBM-3_02-07
Regarding the resilience of its strategy and
business model to climate change, in or-
der to define the scope of the analysis, the
Group has initially focused on the produc-
tion units of its key subsidiary companies.
Emergency response studies have been
carried out to identify climate-related risks
and to document ways to address them.
The purpose of each plan is to define and
provide guidelines to minimize losses, in-
juries, or damage resulting from major in-
cidents, both to personnel and to the en-
vironment. The objectives are summarized
as ensuring that preventive measures have
been taken to minimize the risk of major
incidents, as well as appropriate measures
to minimize the impacts in the event of
major incidents, with clear guidance on
the responsibilities and procedures to be
followed in the event of a serious incident.
The plan relates to risks associated with
the operation of the facilities, as well as
potential emergencies and consequences
related to extreme natural phenomena
(heatwaves, severe weather conditions,
frost-snowfall, earthquakes). In this way, it
will be possible to subsequently conduct
a study that considers climate scenarios,
in which different time horizons will be
examined.
This analysis, which will be completed
within the next two years, will also be
linked with the transition plan in order to
take into account the targets that will be
set for emission reduction, thereby en-
suring consistency in the Group’s overall
strategy.
At the same time, the Group’s ability to
adapt its strategy and business model to
changes must be assessed. Therefore, the
connection between the strategy and the
investment plan should be strengthened.
Obviously, this plan will also include the
training of personnel, which is already be-
ing conducted on sustainability, circular
economy, and climate change issues, and
should be intensified so that the staff can
meet the demands arising from climate
challenges.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 101 of 370
ESRS2: IRO-1 Description of the
processes for identifying and
assessing material climate-
related impacts, risks, and
opportunities
E1.IRO-1_03_05
A significant risk that has been identified
relates to the inability to manage situations
associated with extreme climate events
and disasters (long-term physical risk re-
lated to climate). Obviously, to address this
risk and ensure the Group is as prepared
as possible, Emergency Response Plans
(ERPs) have been developed at the most
important facilities. These plans include
potential emergency incidents and con-
sequences in relation to extreme natural
phenomena such as heatwaves, severe
weather events, frost, snowfall, earth-
quakes, and include all required actions to
be taken in order to mitigate the risk.
Another significant risk that could cause
failures in the use of renewable energy
sources (RES) is the suboptimal utilization
of RES, including expansion, maintenance,
and long-term reliability (medium-term
transition risk related to climate). At the
same time, the increase in energy costs
and electricity prices remains a significant
risk, which the Group addresses through
continuous actions to reduce energy con-
sumption across all production process-
es—something that has been identified as
an opportunity as described below.
An important opportunity lies in the con-
tribution to the reduction of Scope 3 CO2
emissions in the supply chain through col-
laboration with suppliers and customers.
Since Scope 3 accounts for a large portion
of the Group’s emissions, it is important to
seek collaborations in the value chain to
reduce emissions in this area.
Another opportunity is the ongoing effort
to reduce energy consumption in produc-
tion processes. The Group acknowledges
the risks related to the fact that the tran-
sition to a low-carbon economy poses re-
quirements in terms of adapting produc-
tion processes. For this reason, it monitors
technological developments that may
enhance innovation and optimize pro-
duction processes and identifies potential
risks in its internal operations regarding
the need to modernize production equip-
ment, so that it can timely proceed with
new investments and thus turn the risk
into an opportunity.
The risks and opportunities described in
this chapter arose from the double materi-
ality assessment process. They do not take
into account climate scenarios or mate-
rial climate-related matters (as per TCFD),
something that will be carried out within
the next two years.
E1-2 Policies related to climate
change mitigation and
adaptation
E1.MDR-P_01-06
As stated in the Code of Ethical Conduct,
to mitigate the risks arising from climate
change, the Group adapts its business
model in order to reduce its carbon foot-
print and energy consumption, ensuring
full compliance with environmental leg-
islation and contributing to the achieve-
ment of the Sustainable Development
Goals where it has the greatest impact.
The Sustainable Development, Environ-
mental and Social Responsibility Policy is
part of the Group’s strategy and is pub-
lished on the Group’s Website to be dis-
closed to stakeholders, whose interests
were taken into account during the draft-
ing of the Policy, although no consultation
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 102 of 370
was conducted with them. Within the
framework of the Policy, the Group is com-
mitted to full compliance with legislation
and thus indirectly respects international
standards and initiatives that are aligned
with applicable legislation.
It governs and is integrated into all pro-
cesses and business activities and binds
all Group companies. The scope of the
policy does not exclude any of its activi-
ties. During its implementation, the Group
companies must appoint employees with
clear responsibilities for coordinating the
relevant matters.
Monitoring the implementation of the
Policy is the responsibility of the Sustain-
able Development Department, with the
support of the Human Resources Depart-
ment regarding social issues, under the su-
pervision of the Sustainability Committee
concerning environmental and social mat-
ters, and the support of the Internal Audit
Department under the supervision of the
Audit Committee regarding governance
issues. During its implementation, the
Group companies must appoint employ-
ees with clear responsibilities for coordi-
nating the relevant matters.
The Group recognizes sustainable devel-
opment as one of the main challenges of
our time for ensuring the present and the
future. It addresses the sustainable devel-
opment goals, the principles of the circular
economy, the mitigation of climate change
impacts, and social responsibility as sig-
nificant parameters for its operation and
is committed to monitoring and continu-
ously improving its performance through
the use of appropriate indicators. At its
core lies the Group’s pursuit to grow with
respect for society and the environment,
creating solutions for a sustainable future,
thereby remaining a reliable social partner.
The approach to sustainable development
is based on six principles: Implementa-
tion of circular economy, tackling climate
change, empowerment of human resourc-
es, contribution to society, operating with
integrity, ensuring business continuity.
Within the framework of the Policy, the
Group is committed to:
• Providing all means for full compliance
with legislation and other require-
ments governing its operation.
• Identifying and systematically assess-
ing the impacts of its operations.
• Recognizing and managing risks, op-
portunities, and good practices.
• Providing appropriate training and
awareness to employees to promote a
responsible culture.
• Periodically reviewing and revising its
objectives.
• Improving its performance.
• Monitoring corporate performance
indicators through the measurement
of annual performance and the estab-
lishment of annual targets.
• Disclosing this Policy to employees
and partners (contractors, suppliers,
customers) and to the broader soci-
ety within which it operates to en-
hance their environmental and social
awareness and to promote synergies
through its publication on the Group’s
Website.
E1-2_01
Furthermore, during the implementation
of the Sustainable Development, Environ-
mental and Social Responsibility Policy, it
is stated that the Group’s companies must
ensure the following:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 103 of 370
• Optimization of energy efficiency
through the recording of energy con-
sumption and the undertaking of spe-
cific measures and actions aimed at
achieving the best possible efficiency
(energy efficiency).
• Consistent orientation towards the
use of energy from renewable sources,
namely solar, geothermal, and hydro-
electric (development of renewable
energy sources).
• Reduction of direct and indirect
greenhouse gas emissions through
the monitoring of data for each cat-
egory (scope 1, 2, 3) in accordance
with the GHG Protocol methodology
and ISO 14064-3 and the identification
of significant points for improvement
(adaptation to climate change).
These policies are implemented through
the Group’s defined 5-year strategic sus-
tainable development plan which sets
clear priorities, actions, and targets.
E1-3: Actions and resources related to
climate change policies
E1.MDR-A_01-07&09-12, E1-3_01, E1-3_03-08
The Group has defined specific actions in
its Sustainable Strategic Plan 2022-2026
aimed at reducing greenhouse gas emis-
sions across all processes.
This is achieved primarily through three
main voluntary pillars on which the Group
builds its production model, in line with
the purpose of the respective policy: (a)
improving energy efficiency in production
processes, (b) increasing the consumption
of energy from renewable sources, and (c)
optimal utilization of natural resources.
Relevant progress data for these actions,
expressed in terms of greenhouse gas
emissions, is not yet available.
The Group has incorporated into its strate-
gic plan the improvement of data collec-
tion processes for the accurate calculation
and measurement of emissions. At the
same time, it participates in the interna-
tional organization CDP, through which
the management of the environmental im-
pacts of its activities and its contribution to
climate change adaptation are assessed.
In the most recent evaluation, the Group
received a B rating, confirming its commit-
ment to transparency and continuous im-
provement. Participation in the CDP initia-
tive serves not only as an evaluation tool
but also as a means of understanding and
improving climate change-related issues.
The ability to implement the action pri-
marily depends on securing the relevant
licensing for the use of renewable energy
sources and secondarily on the availability
and allocation of corresponding resources.
The increase in the percentage of energy
use from renewable sources obviously
leads to a corresponding reduction in
greenhouse gas emissions, which, how-
ever, has not been quantified in this report
and will be included in the next one. Simi-
larly, regarding actions to reduce energy
consumption in production processes,
these are carried out mainly through the
optimization of machinery and production
processes.
In conclusion, there is no significant Capex-
Opex that has been allocated exclusively
for climate change-related actions in the
current report. For the current reporting
period, the Group is not in a position to
provide a detailed analysis of Capex and
Opex for each specific action, as capital
and operating expenses have not yet been
categorized at such a detailed level. How-
ever, the Group acknowledges the impor-
tance of this information and is actively
working on improving internal processes,
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 104 of 370
aiming for a more accurate categorization
of Capex and Opex so that this information
can be included in next year’s report.
In conclusion, the Group’s activities and
actions do not have any material negative
impacts on local communities.
(a) Improvement of energy efficiency
during the production process
The Group continuously monitors energy
consumption in production processes
aiming for optimal efficiency through the
implementation of energy-saving meas-
ures. As a result, energy consumption is re-
corded using modern monitoring systems,
and efforts are made to reduce consump-
tion through the energy efficiency project
by implementing specific measures and
actions. At the same time, the Group in-
vests in mechanical modernization aimed
at energy savings, such as replacing ener-
gy-intensive equipment with alternatives
that have lower energy requirements or
upgrading electromechanical equipment.
Continuous training and awareness-rais-
ing of employees on these matters is also
carried out. This action concerns all facili-
ties and its progress depends mainly on
the participation and engagement of all
employees rather than on any potential re-
allocation of resources.
Scope of application: Group production
facilities
Time horizon: Ongoing actions, monitored
on a monthly basis, evaluated on an an-
nual basis
(b) Investment in and utilization of
renewable energy sources
The use of renewable energy sources and
the improvement of energy efficiency are
key pillars for meeting climate goals and
the European Union’s long-term strategy.
In fact, the European Green Deal focuses,
in terms of the transition to clean energy,
on promoting energy efficiency and de-
veloping an energy production sector
largely based on renewable energy sourc-
es. The investment in and utilization of RES
contribute to the reduction of greenhouse
gas emissions.
Scope of application: Group production
facilities
Time horizon: Ongoing actions, monitored
on a monthly basis, evaluated on an an-
nual basis
(c) Optimal utilization of natural
resources
The Group, through life cycle assessments
of its products, as well as those of the raw
materials it procures, aims to reduce its
carbon footprint related to indirect emis-
sions in the value chain (Scope 3). Par-
ticular emphasis is placed on improving
indirect emissions, as purchased raw ma-
terials and services constitute the largest
contributor to the Group’s total emissions.
At the same time, it has been recognized
that strengthening collaboration with sup-
pliers aligned with sustainability principles
is a key driver for improving emissions. The
Group has initiated synergies with its part-
ners concerning Environmental Product
Declarations (EPD), leveraging transparent
and documented data to reduce emissions
throughout the value chain.
Scope of application: Group production
facilities
Interested parties in the value chain: Raw
material suppliers
Time horizon: Ongoing actions, monitored
on a monthly basis, evaluated on an an-
nual basis
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 105 of 370
E1-4: Targets for climate change
mitigation and adaptation
MDR-T_14-15
The Group’s objective is to achieve ener-
gy consumption from renewable sources
through self-generation at a rate of 10%
by 2025, based on current productivity
levels. This percentage has already been
approached, as shown in table E1-5 En-
ergy Consumption, and will contribute
to the emission reduction targets. In rela-
tion to and with reference to the areas of
action mentioned above, and always in
connection with energy efficiency in pro-
duction processes and the use of renew-
able energy sources, the Group monitors
progress in monthly meetings with all its
subsidiaries. At present, there is no spe-
cific emission reduction target in place.
The Group monitors the progress of re-
ductions in specific areas (scope 2/energy,
scope 3/raw materials, transport), and spe-
cific greenhouse gas emission reduction
targets will be set. There are no further
specific or quantified means of monitor-
ing the actions described in the previous
section. The transition plan for climate
change mitigation (E1-1) will be completed
in 2026 and will refer to the period 2026–
2030, contributing to aligning the business
strategy with environmental objectives.
Following this plan, the Group will set rel-
evant targets.
E1-5: Energy consumption
E1-5_01-21
The Group invests in the use of energy
from renewable sources and utilizes solar,
geothermal, and hydroelectric energy to
cover part of its energy needs. The data re-
lated to energy consumption has not been
externally verified.
Energy consumption and mix (MWh) Excluding JVs JVs
(1) Fuel consumption from coal and coal products 0 0
(2) Fuel consumption from crude oil and petroleum prod-
ucts
0 0
(3) Fuel consumption from natural gas 0 0
(4) Fuel consumption from other fossil sources 0 0
(5) Consumption of purchased or acquired electricity, heat,
steam, and cooling from fossil sources (MWh)
165,314.52 21,882.40
(6a) Total fossil energy consumption (calculated as the sum
of lines 1 to 5)
165,314.52 21,882.40
(6b) Share of fossil sources in total energy consumption (%) 90% 88%
(7a) Consumption from nuclear sources 0 0
(7b) Share of consumption from nuclear sources in total
energy consumption (%)
0 0
(8) Fuel consumption for renewable sources, including
biomass (also comprising industrial and municipal
waste of biologic origin, biogas, renewable hydrogen,
etc.)
0 0
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 106 of 370
Energy intensity per
turnover
0.495
Formula: total energy consumption
(183,365 MWh) / turnover (370,368 thou-
sand euros)
Total energy consumption and consump-
tion from activities in sectors with high
climate impact coincide, as all activities
fall within corresponding sectors, as de-
fined in Annex I of Regulation (EC) No
1893/2006. The turnover figure is reported
in the statement of comprehensive in-
come of the annual financial statement.
E1-6: Direct and Indirect Emissions
E1-6_01-05, E1-6_07-19, E1-6_21-35
The Group recognizes the importance
of recording, monitoring, and reducing
direct and indirect greenhouse gas emis-
sions. For this reason, it uses a specialized
Carbon Footprint Calculation Platform,
which aligns with the internationally es-
tablished GHG Protocol methodology and
ISO 14064-3. In 2021, the Group began
recording direct and indirect emissions
(scope 1 and 2) for the previous year and
determined the carbon footprint of the
three most significant subsidiaries. Since
2022, for the 2021 data, the Group records
the full scope of direct and indirect emis-
sions (scope 1, 2, and 3) and determines
the carbon footprint of all subsidiaries,
with external verification for the years
2021 and 2022. Through the specialized
platform, the required data for each cat-
egory (scope 1, 2, 3) is collected, the data
is converted into CO2 emissions, signifi-
cant areas for improvement are identified,
measures for emission reduction are tak-
en, and progress is monitored. In 2026, and
in conjunction with the Transition Plan, the
Group will set specific targets regarding
the reduction of carbon emissions.
For the recording of its carbon footprint,
the Group followed the operational con-
trol approach based on the GHG Protocol
standard, calculating 100% of greenhouse
gas emissions from sources (facilities, ac-
tivities, etc.) over which it exercises opera-
tional control. This includes all offices and
production units controlled operationally
Energy consumption and mix (MWh) Excluding JVs JVs
(9) Consumption of purchased or acquired electricity, heat,
steam, and cooling from renewable sources
0 0
(10) The consumption of self-generated non-fuel renew-
able energy (MWh)
18,050.36 3,004.77
(11a) Total renewable energy consumption (calculated as
the sum of lines 8 to 10)
18,050.36 3,004.77
(11b) Share of renewable sources in total energy consump-
tion (%)
10% 12%
(12) Total energy consumption (calculated as the sum of
lines 6, and 11)
183,364.88 24,8 87.17
Production of Non-renewable Energy 0 0
Production of Renewable Energy 18,050.36 3,004.77
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 107 of 370
by the Group, including the central offices
and any auxiliary facilities.
The emission factors are sourced from the
official factors of the UK BEIS (Department
for Business, Energy & Industrial Strategy),
the Carbon Base managed by ADEME, and
the EXIOBASE database.
There were no material changes to the def-
inition of the entity or the value chain that
would affect the comparability of green-
house gas emissions from year to year.
The share of biogenic emissions for scopes
1, 2, and 3 is zero.
No certificates of origin or other relevant
documentation were submitted.
For the accounting of its indirect emissions
(scope 3), the Group has taken into ac-
count the following categories: 1 to 9 and
12. The remaining categories (10-11, 13-15)
have not been included, as sufficient data
for their full assessment is not available.
Regarding scope 3, the percentages are
calculated as follows: primary data 6.46%,
secondary data 93.54%.
The Group is committed to improving the
share of primary data and including addi-
tional categories of scope 3.
The Group calculated the greenhouse gas
emissions for each of the following scope
3 categories, based on the Greenhouse
Gas Protocol, applying the appropriate cal-
culation methods according to data avail-
ability. It is noted that data was not avail-
able for all categories and for each of the
Group’s subsidiaries, so the calculations
were made only where substantial and
documented data was available. No sig-
nificant changes were made to the defini-
tion of the business and the value chain or
events with significant impacts. Also, there
were no biogenic CO2 emissions from the
combustion or biodegradation of biomass.
Purchased goods and services: The
Group tracked total expenditures by cat-
egory of goods and services and esti-
mated the related greenhouse gas emis-
sions by applying the expenditure-based
methodology*.
Capital goods: The Group tracked ex-
penditures for long-term assets, such as
machinery, buildings, and vehicles, and es-
timated the related greenhouse gas emis-
sions by applying the expenditure-based
methodology*.
Fuel- and energy-related activities (not
included in Scope 1 or Scope 2): This
includes emissions resulting from the ex-
traction, processing, transportation, and
distribution of fuels before they reach
the Group’s facilities. The Group tracked
fuel and energy consumption that is not
included in Scope 1 or Scope 2 and cal-
culated the related greenhouse gas emis-
sions by applying the average data-based
methodology***.
Upstream transportation and distri-
bution: This category involves emissions
from the transportation and distribution
of products to the organization, starting
from the exit of the products from the final
supplier to their receipt by the Group. The
transportation is carried out by means that
are not owned or controlled by the Group,
and the Group makes direct payments to
third-party transportation service provid-
ers. In cases where data was available for
the volume of transported cargo (in tons)
and transport distances (in kilometers), the
distance-based methodology** was ap-
plied. In cases where transportation activi-
ty data was not available, the expenditure-
based methodology* was applied.
Waste from operations: The Group cal-
culated greenhouse gas emissions from
waste management by tracking the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 108 of 370
weight, type of waste, and disposal meth-
ods, applying the methodology by waste
type. Emission factors from the UK Depart-
ment for Energy Security and Net Zero
(DESNZ), as published in the official docu-
ment “Greenhouse Gas Reporting: Con-
version Factors 2024,” were used for the
calculation.
Business travel: This category includes
employee travel using transportation
means not owned or controlled by the
Group, as well as related overnight stays.
In cases where data was available for travel
distances and modes of transport (e.g., air-
plane, train, car), the distance-based meth-
odology** was applied. In cases where
travel activity data was not available, the
expenditure-based methodology* was
applied.
Downstream transportation and distri-
bution: This category involves emissions
arising from the transportation and dis-
tribution of products from the Group to
customers or end-users, after the produc-
tion or storage stage. The transportation is
carried out by means that are not owned
or controlled by the Group, and related
transportation services are paid to third-
party providers. In cases where data was
available for the volume of transported
cargo (in tons) and transport distances (in
kilometers), the distance-based methodol-
ogy** was applied. In cases where trans-
portation activity data was not available,
the expenditure-based methodology*
was applied.
End-of-life of sold products: The Group
estimated greenhouse gas emissions re-
lated to the end-of-life of sold products
and their packaging, based on the weight
or volume of these materials and their
corresponding disposal methods. For this
purpose, the methodology by waste type
was applied, considering the type of each
waste and its management method. Emis-
sion factors from the “Base Carbone v23.3”
database published by ADEME were used
for the calculation. These factors are avail-
able through the Climatiq platform. Due
to the use of Average end-of-life factors
from the Base Carbone v23.3 database of
ADEME, no application of percentages for
waste disposal methods has been made,
as these have already been taken into
account in the calculation of the aver-
age emission factor. The factors include a
weighted, average distribution of disposal
methods.
*Where the spend-based methodology was used, emission factors from the Climatiq platform were used
for calculating emissions, based on the international EXIOBASE database (version 3.8.2, 2019). These factors
express emissions in CO₂e per euro (€) spent on goods or services and are adjusted according to the country
in which the expenditure occurs. The emissions reflect the overall carbon footprint, including emissions from
production, transportation, and intermediate stages in the global supply chain, while the impacts of interna-
tional trade are incorporated into the calculations.
**Where the distance-based methodology was used, emission factors were used based on the type of trans-
port, from the UK Department for Energy Security and Net Zero (DESNZ), as published in the official docu-
ment Greenhouse Gas Reporting: Conversion Factors 2024.
***Where the average data methodology was used, emission factors were used from the UK Department
for Energy Security and Net Zero (DESNZ), as published in the official document Greenhouse Gas Reporting:
Conversion Factors 2024.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 109 of 370
Direct & Indirect Emissions Table
Direct & Indirect Emissions Excluding JVs JVs
Scope 1 GHG emissions 1,355.52 289.05
Percentage of Scope 1 GHG emissions from regulated
emission trading schemes (%)
Scope 2 GHG emissions
Gross location-based Scope 2 GHG emissions 56,784.60 6,634.72
Gross market-based Scope 2 GHG emissions 45,562.80 6,650.74
Significant scope 3 GHG emissions
1 Purchased goods and services 166,094.64 17,962.73
2 Capital goods 28,219.72 7,743.49
3 Fuel and energy-related activities 29.09 -
4 Upstream transportation and distribution 4,340.08 2.91
5 Waste generated in operations 36.53 155.86
6 Business traveling 1,078.55 3.88
7 Employee commuting 5.16 -
8 Upstream leased assets - -
9 Downstream transportation 17,150.10 7, 212.03
12 End-of-life treatment of sold products 14,298.88 -
Total Scope 3 emissions 231,252.75 33,080.90
Total GHG emissions (location-based) (tCO2eq) 289,392.87 40,004.67
Total GHG emissions (market-based) (tCO2eq) 278,171.08 40,020.69
Excluding JVs GREECE
SCOT-
LAND
BOUL-
GARIA
SERBIA IRE-LAND
SWEDEN/
NORWAY
Scope 1 GHG
emissions
414.08 827. 34 114.11 - - -
Scope 2 location-
based
46,266.97 5,944.02 4,176.10 - 394.55 2.96
Scope 2 market-
based
33,891.88 7,119.91 4,188.39 - 362.63 -
Scope 3 GHG
emissions
169,436.54 1,520.17 40,783.92 3,971.31 4,214.32
11, 326.49
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 110 of 370
Emission Intensity
Emission Intensity per Revenue
(Location-based) 0.78
(Market-based) 0.75
Formula: Total emissions (t 289,393
CO2e) / Revenue (370,368 thousand EUR)
Location-based
Formula: Total emissions (t 278,171
CO2e) / Revenue (370,368 thousand EUR)
Market-based
The revenue figure refers to the in-
come statement in the annual financial
statement.
ESRS E2 Pollution (Microplastics)
E2 IRO-1 Description of the processes
to identify and assess
material impacts, risks and
opportunities related to
pollution
E2.IRO-1_03
The Group has identified, through the dou-
ble materiality assessment it conducted,
the negative environmental impacts that
may arise from the improper management
of microplastics at its production facilities.
Furthermore, microplastics management
at the production sites is critical for reduc-
ing pollution and the environmental bur-
den. For this reason, the Group has includ-
ed their proper management both in its
Sustainable Development, Environmental
and Social Responsibility Policy and in its
strategy. In addition, the Zero Pellet Loss
project is active across all sites, based on a
specific methodology and aiming at tangi-
ble results. Through this project, the Group
follows best practices to address the issue
and drive improvement at all levels.
This issue also emerged as significant for
the Group through the mapping carried
out at the production sites to identify po-
tential leakage points.
The Zero Pellet Loss project focuses exclu-
sively on the Group’s production facilities,
as these are the only ones handling micro-
plastics, and no facility has been identified
as having an increased risk. Prevention and
control procedures are applied uniformly
across all production units. Moreover, the
Zero Pellet Loss project currently does not
extend beyond the facilities, except for
communication with raw material suppli-
ers regarding proper packaging, transpor-
tation, and unloading of materials. Never-
theless, the Group promotes prudent and
responsible handling of all materials and
encourages safe practices throughout its
supply chain.
JVs GREECE USA ROMANIA
Scope 1 GHG emissions 125.03 66.1 97.92
Scope 2 location-based 1,808.11 3,513.78 1,312.84
Scope 2 market-based 1,319.84 3,903.52 1,427. 38
Scope 3 GHG emissions 15,087. 38 5,079.98 12,913.54
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 111 of 370
E2.IRO-1_02
There have been no confirmed incidents
of non-compliance with regulations, and
accordingly, no financial penalties or com-
plaints of any violations that could poten-
tially result in environmental fines have
arisen. As a result, there is no requirement
for public consultation.
The Group remains committed to continu-
ously implementing improvement meas-
ures and controls, thus ensuring the best
possible environmental footprint.
As part of the Zero Pellet Loss project, the
Group is already implementing a series of
measures at its facilities to prevent pellet
leakage into the environment:
•
Perimeter protection with Silt Fence
fabric to prevent pellet escape in the
event of leakage.
•
Retention systems in stormwater net-
works using metal meshes to trap and
prevent pellet leakage into the envi-
ronment.
•
Containment curbs in pallet storage
areas, and in the event of a spill, op-
erators are required to collect material
at a designated spot (Zero Pellet Loss
Point).
•
Retention manholes in storage areas
with drainage tanks equipped with
pellet retention screens.
E2-1 Policies related to pollution
E2.MDR-P_01-06
The Sustainable Development, Environ-
mental and Social Responsibility Policy is
part of the Group’s strategy. It governs and
is integrated into all processes and busi-
ness activities and binds all Group compa-
nies.
In implementing the Policy, Group compa-
nies must designate employees with clear
responsibilities for coordinating relevant
matters. The core principles of the policy
are outlined in the corresponding section
of chapter E1.
When executing the Policy, Group com-
panies must ensure the protection and
preservation of biodiversity and address
atmospheric and environmental pollution
by implementing appropriate measure-
ments and measures to prevent microplas-
tics dispersion into the environment, in ac-
cordance with the guidelines of Operation
Clean Sweep (OCS) and the EU Zero Pollu-
tion Action Plan for water, air, and soil.
Additionally, the Group is committed to
the proper use and management of chem-
icals, complying with all necessary meas-
ures during temporary storage and coop-
erating with licensed waste managers for
safe disposal.
Regarding the loading and unloading
procedures of primary and secondary raw
materials, due diligence processes are fol-
lowed to minimize the risk of microplastic
loss during transport.
Furthermore, the Group applies and fol-
lows internationally recognized standards
and initiatives, such as:
•
Operation Clean Sweep (OCS) to pre-
vent microplastic leakage,
•
ISO Standards for managing environ-
mental performance.
E2-2 – Actions and Resources Re-
lated to Pollution
E2.MDR-A_01-12 & E2-2_04
For the Group, preventing pellet loss is a
key pillar of the Zero Pellet Loss initiative,
which is part of the broader sustainability
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 112 of 370
strategy. This initiative directly addresses
the need to prevent microplastic disper-
sion into the environment and aligns with
the principles of the circular economy.
The Group’s approach, which applies ex-
clusively to its production facilities, is
based on a comprehensive action frame-
work following the Operation Clean Sweep
(OCS) guidelines. It focuses on employee
training for prevention, containment,
cleanup, and proper disposal of spills, as
well as ensuring personal accountability. It
also includes the creation and publication
of internal procedures, implementation of
preventive measures—such as improving
workspace layouts to prevent and manage
spills—and the continuous improvement
of processes. Regular performance audits
are carried out. The initiative is supervised
weekly by plant managers, monthly with
the Sustainability Department, and peri-
odically reviewed by top management.
Each facility has designated individuals
responsible for monitoring implementa-
tion. The Zero Pellet Loss project is an on-
going initiative, continuously applied and
improved across all production sites of the
Group. The goal of achieving zero pellet
loss outside production facilities, which
will be more formally defined and support-
ed by data in the coming years, is an an-
nual and continuous target for the Group.
In the coming years, the program will be
gradually extended across the entire value
chain, integrating suppliers, partners, and
customers, aiming for an overall reduction
of microplastic losses at all stages of pro-
duction and distribution.
The methodology followed at each pro-
duction site includes the following key
steps:
Facility Mapping and Identification of
Pellet Loss Points
The first step in preventing microplastic
loss begins with the detailed mapping of
all internal and external areas of the fa-
cilities. This process includes identifying
high-risk points across the production
chain, including raw material unloading
areas, production lines, material handling
zones, storage areas, and recycling units.
Each risk zone is carefully assessed, and
based on the findings, customized action
plans are developed. These plans include
clear instructions for loss prevention, ma-
terial collection, and proper management
of spills to ensure effective handling of
each challenge.
Implementation of Loss Reduction
Measures
After mapping and identifying critical
points, actions are prioritized based on
their expected impact. Each action is ac-
companied by a specific plan and timeline,
defined by the facility manager. In collabo-
ration with the manager, corrective actions
are identified, priorities are set, timelines
are determined, and responsibilities are
assigned for implementation.
Progress is not monitored through quan-
titative indicators but rather through the
resolution of open issues. Measures are
implemented to minimize the likelihood
of microplastic loss, such as installing col-
lection devices (e.g., metal trays) at mate-
rial handling points and strategically plac-
ing bins in critical zones. Specialized tools
such as vacuum cleaners are used for spill
collection and removal. In recycling areas,
secure storage using Big Bags is applied to
minimize loss during material handling.
Moreover, strict criteria guide the handling
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 113 of 370
and storage of materials. Materials must
be stored in designated areas for primary
and secondary raw materials, pallets are
inspected and repaired if damaged, and
specialized containers, sacks, and bins are
used to prevent spills. All pallets stored
outdoors are covered with film to protect
against sun exposure. The implementation
of these measures is supported by strict
procedures, ensuring both the safety and
effectiveness of the program.
Regular Cleaning, Inspections, and
Maintenance
Maintaining clean facilities and regular
maintenance are fundamental steps in
preventing microplastic spills. Loading and
unloading zones are thoroughly cleaned
before and after each use, and packaging is
inspected for potential damage or leaks. If
problems are detected, corrective actions
are taken immediately, such as repairing
packaging or removing spills. Additionally,
filters are installed on stormwater grates to
prevent pellets from entering the drainage
system. At the same time, pipelines, hoses,
and equipment are regularly maintained
to ensure system integrity and proper pro-
duction operation.
Inspection and Enhancement of Proce-
dures
During daily operations, regular weekly
and monthly inspections are conducted,
and data is collected to monitor losses at
specific facilities rather than across the
Group as a whole. Material spills are re-
corded and weighed to identify critical
points requiring further improvement. Al-
though no quantitative data is published
for the reporting year, improvements have
been observed at intervention points. Ma-
terials that cannot be reused are sent to
licensed recyclers, ensuring proper envi-
ronmental management.
The systematic recording and analysis
of data provide the basis for informed
decision-making aimed at continuous
improvement. The final phase focuses
on regular inspections and ongoing en-
hancement of procedures. Through the
use of special checklists, compliance with
best practices is ensured, while training
programs inform employees and provide
them with the necessary tools and knowl-
edge to prevent losses.
While no quantitative data is available at
Group level, the Group is committed to
developing a dedicated monitoring and
improvement system for the initiative over
the next two years. Lastly, for the reporting
year, no specific financial resources (CAPEX
or OPEX) have been allocated to the initia-
tive.
E2-3 Pollution-related targets
E2. MDR-T_14
The prevention of plastic pellet loss into
the environment (zero-pellet loss) is a key
voluntary short-term target of the Group,
which is committed to implementing all
necessary actions to achieve it. At present,
in terms of scope, the program is exclu-
sively focused on the production facilities,
and initial steps have been defined so that,
within the next two years, specific targets
can be set based on historical data and the
adopted methodology, with the strategic
goal of expanding the program through-
out the value chain in the coming years.
To achieve this objective, the Group must
strengthen its collaboration with raw ma-
terial suppliers, ensuring, through due
diligence procedures, the best possible
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 114 of 370
upstream transfer to its facilities.
At the same time, many efforts are being
made to improve the internal manage-
ment of microplastics within the facilities,
with a continuous effort to reduce pellet
loss at every stage. For this reason, resi-
dues that cannot be reused (sweepings)
are collected separately and processed
through approved recyclers.
To date, there are no available historical
performance data for the entire Group, as
this is a new project and its foundational
structure is still under development. The
Group is currently focused on implement-
ing corrective actions and improving pro-
cesses, aiming to establish a reliable re-
cording and monitoring mechanism.
The Group has already received Zero Pellet
Loss certification from OCS Clean Sweep
for one facility and is laying the ground-
work for further certifications. Part of the
strategy is to expand certification to more
facilities, enhancing consistency and the
effectiveness of the actions. This certifica-
tion concerns in-facility actions and does
not cover the value chain.
This initiative represents an ongoing goal,
aiming at the continuous improvement of
processes and systematic monitoring of
the Group’s progress. In the future, as the
implementation of the program evolves,
the initiative will incorporate other critical
stakeholders from the value chain, shap-
ing an integrated framework for the pre-
vention and management of microplastic
losses at all stages of production, transpor-
tation, and use of our products.
E2-4 Air, water, and soil pollution
E2-4_06
There is no available information for the
reference year for all facilities. However,
the Group is in the process of develop-
ing a monitoring system that will allow it
to track progress, as well as establishing a
unified procedure across all its facilities.
ESRS E5 Resource use and circular
economy
IRO-1 Description of processes
for identifying and assess-
ing material impacts, risks,
and opportunities related to
resource use and the circular
economy
E5.IRO-1_01
The Group has identified impacts arising
from ongoing changes in European and
national regulatory frameworks, which
create intense future requirements. For
this reason, it closely monitors national
and international regulations concerning
the packaging solutions sector.
For the Group, priority in design and pro-
duction lies in low environmental foot-
print, minimal weight while maintaining
strength, reusability, high recyclability,
use of mono-materials, incorporation of
natural materials, and the use of recycled
material up to 100%. It also closely moni-
tors anything related to waste manage-
ment, recycling, the use of secondary raw
materials, sustainable product features in
line with the EU Taxonomy or eco-design
requirements, and other aspects relevant
to the circular economy.
Additionally, potential impacts have been
identified concerning shifts in consumer
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 115 of 370
preferences. For this reason, the Group
prioritizes the development of sustain-
able products and solutions with a proven
positive environmental footprint, as docu-
mented by life cycle assessments (LCA) and
environmental product declarations (EPD),
prioritizing specific product categories.
Regarding recycling, key risks include the
lack of availability of recycled raw materials,
as well as the use of materials that do not
fully comply with quality or environmental
standards or emerging requirements such
as mandatory recycled content. The Group
addresses these risks through a series of
actions, as described below.
E5.IRO-1_02
Alongside the identified risks, opportuni-
ties arise from the transformation of ex-
isting markets toward new sustainable
products and processes, where the use of
recycled or reusable materials adds value
to the customer. This presents a significant
opportunity for the development of sus-
tainable products and solutions based on
the circular economy that create value for
customers. Partnerships and communica-
tion with customers on circular economy
issues are a priority for the Group in devel-
oping innovative sustainable products.
To respond to new market conditions and
leverage opportunities, the Group has de-
veloped, through the IN THE LOOP plat-
form, specialized upcycling systems that
enable tracking and certification of recy-
cled content or reuse systems that track
and certify the number of uses. At the
same time, it applies the circular economy
model in practice through specific actions
such as organizing closed-loop recycling
systems for new product production or
designing and manufacturing reusable
products, aiming to lead new markets of
innovative, eco-designed products.
Further opportunities relate to resource
efficiency during the production process,
such as continuous efforts to reduce scrap,
minimize waste, and pellet loss, as well as
increasing the use of recycled raw materi-
als. To seize these opportunities and ad-
dress related challenges, the Group carries
out targeted projects, such as reducing
waste (zero waste to landfill) and reusing
scrap generated in production processes.
At the same time, it prioritizes replacing
virgin raw materials with recycled ones,
fostering collaborations with suppliers or
customers to create a sustainable supply
chain, and reducing product packaging
where feasible.
In conclusion, through the development of
low environmental impact products by ap-
plying circular economy principles, and by
offering solutions to customers that help
improve their sustainability metrics, the
Group aims to capitalize on the opportuni-
ties arising from promoting circular econo-
my principles.
E5-1 Policies related to resource use
and circular economy
E5.MDR-P_01-06
As stated in the Code of Ethics and Con-
duct, the Group places particular emphasis
on applying circular economy principles,
responsible waste management, reducing
energy consumption, and limiting green-
house gas emissions related to its opera-
tions. Specifically, it has adopted circular
economy principles from raw material pro-
curement and product design, incorporat-
ing practices based on reduce, reuse, and
recycle principles, throughout the entire
product life cycle.
The Group has a Sustainable Development,
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 116 of 370
Environmental and Social Responsibil-
ity Policy, which is complemented by the
Health, Safety and Environmental Policy to
provide a unified approach, raise aware-
ness, and improve the culture concerning
the general principles and core rules out-
lined in the Code of Ethics and Conduct.
These concern safety and health, environ-
mental protection, circular economy, and
climate change. The key principles of this
policy are analyzed in the corresponding
section of chapter E1.
Regarding the Sustainable Development,
Environmental and Social Responsibility
Policy, priority is given to improving the
environmental impacts resulting from the
Group’s operations, with particular focus
on applying circular economy principles,
responsible waste management, increas-
ing the use of recycled raw materials, re-
ducing energy consumption, investing in
renewable energy sources, and reducing
greenhouse gas emissions associated with
its activities.
E5-1_01-04
Specifically, the Group has adopted the
principles of the circular economy (reduce,
reuse, recycle) from the procurement of
raw materials and product design to the
entire life cycle of its products.
The Group respects the waste manage-
ment hierarchy and the principles of the
circular economy, and for this reason it pri-
oritizes, through the durability of its prod-
ucts, reduction and reuse, while through
the use of recycled raw materials it contrib-
utes to the reduction of natural resource
consumption.
In implementing the Policy, the Group
companies must ensure the following:
•
The adoption of practices in line with
the principles of the circular economy
to ensure the efficient use of natural
resources and raw materials, including
the use of recycled raw materials de-
pending on technical specifications,
as well as reliable information regard-
ing traceability and recycled content
through appropriate certifications.
•
Research and innovation consistently
oriented towards the development of
sustainable products with character-
istics such as the use of recycled raw
materials, recyclability, and the poten-
tial for reuse. To ensure the sustainable
features of the products, certifications
that guarantee traceability and Envi-
ronmental Product Declarations (EPD)
based on Life Cycle Assessments (LCA)
may be used for representative prod-
uct types.
•
The best possible management of sol-
id waste through stream-specific sep-
aration aiming at its reuse or recycling,
and collaboration with licensed waste
managers for optimal treatment.
•
The proper use and management of
chemical substances, adhering to all
necessary measures during tempo-
rary storage and cooperating with a
licensed manager for their safe dis-
posal.
•
The optimization of resource efficien-
cy in production units by reducing
production residues (scrap) through
appropriate actions in production pro-
cesses and their optimal reuse.
At the same time, the Group implements
the Health, Safety, and Environmental Pol-
icy, which essentially includes the follow-
ing: Providing guidance and a unified ap-
proach concerning the general principles
and key rules set by the Group’s Manage-
ment, raising employee awareness on en-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 117 of 370
vironmental issues, using environmentally
friendly production methods and protect-
ing the environment, and improving the
Group’s culture. One of the key areas of
implementation concerns the efficient use
of resources, aiming at the continuous im-
provement of the efficiency of natural re-
source use, with the objective of environ-
mental protection and the minimization
of operational residues and waste, while
simultaneously maximizing reprocessing
or recycling, targeting the continuous im-
provement of input-output performance.
E5-2 Actions and Resources Related
to Resource Use and Circular
Economy
E5.MDR-A _01-12
The Group’s Framework and Consistent
Commitment to the Principles of Circular
Economy
The European Green Deal lays the founda-
tion for a new plastics economy, in which
the design and production of plastic prod-
ucts are carried out with full respect for
the environment through the use of fewer
natural resources and the increase of recy-
cling. The Group fully embraces this strate-
gy, turning today’s challenges into growth
opportunities with the aim of strengthen-
ing a sustainable competitive advantage.
Within this context, the Group has adopt-
ed the principles of the circular economy
throughout the entire lifecycle of its prod-
ucts, incorporating practices based on the
principles of reduction, reuse, and recy-
cling by setting the following priorities:
•
Raw materials: Ensuring the effi-
cient use of natural resources and
evaluating raw materials based on
the required technical specifications
& deliberate non-use during the pro-
duction process of the 27 critical raw
materials identified by the European
Commission as having a high risk of
supply chain disruption.
•
Design: Reducing the average prod-
uct weight while maintaining the same
technical characteristics & designing
innovative and sustainable products
with a low environmental footprint.
•
Production: Investing in more ener-
gy-efficient production machinery
and continuous monitoring and re-
duction of energy consumption & us-
ing recycled raw materials at very high
rates depending on the application.
•
Distribution / Transport: Synergies
among the Group’s companies to opti-
mize delivery routes and prioritize the
procurement of raw materials from
industries located in the same geo-
graphical area & collaborating with
customers to reduce the use of sec-
ondary packaging.
•
Reuse: Saving raw materials through
the reuse of internal waste & produc-
ing reusable products with high dura-
bility, aiming to maximize their lifecy-
cle.
•
Collection: Storing production resi-
dues in appropriate temporary stor-
age stations to optimize their utiliza-
tion & collecting recyclable materials
through closed-loop systems for the
purpose of upcycling.
•
Recycling: Voluntary commitment to
the Circular Plastics Alliance (CPA) ini-
tiative to replace virgin raw materials
with recycled ones by 2025 & provid-
ing reliable traceability and recycled
content information through certifica-
tions such as RecyClass, EuCertPlast,
and TUV OK Recycled.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 118 of 370
•
Disposal: Recycling non-reusable raw
materials through licensed partners
& continuously reducing the disposal
of non-hazardous waste to landfill
through source separation initiatives.
Actions Related to Resource Use and
the Circular Economy
The Group embraces the principles of the
circular economy as a vital opportunity to
reduce its environmental footprint, pro-
mote sustainable development, and pro-
tect the environment. Recognizing the
significant benefits of transitioning to a
circular economy, it actively focuses on
ensuring that its operations not only mini-
mize waste but also promote the continu-
ous reuse of resources, thereby contribut-
ing to a more sustainable future. Through
specific strategic actions, the Group prior-
itizes the reduction, reuse, and recycling of
materials across its operations and entire
value chain. This approach is a key ele-
ment of the Group’s sustainability strategy,
aiming to reduce environmental impact,
strengthen innovation, and create value
for all stakeholders.
The Group’s circular economy actions re-
COLLECTION
RECYCLING
DESIGN
RAW MATERIALS
WASTE
REMAINS
PRODUCTION,
PROCESSING
DISTRIBUTION
USE, R E-USE, REPAIR
CIRCULAR
ECONOMY
late to three specific pillars:
(a) the design and production of sustain-
able products,
(b) the use of secondary raw materials, and
(c) the management and reduction of
waste generated during production
processes as well as indirectly through
recycling and the use of secondary raw
materials.
These actions are supported by (d) the IN
THE LOOP circular economy platform, an
initiative of the Group.
All actions are annually integrated into the
companies’ strategic planning, and their
progress is monitored monthly. These ac-
tions relate to the Group’s strategic pillars
and are continuous. They are not limited
by timeframes, as the business model is
built upon them. In fact, the Group contin-
uously monitors these issues and prioritiz-
es the use of secondary raw materials and
the reduction of waste sent to landfill, as
defined in the Sustainability, Environmen-
tal and Social Responsibility Policy.
Finally, for the reporting year, no specific
financial resources (CAPEX or OPEX) were
allocated to these actions.
(a) Design and Production of
Sustainable Products
E5-2_03-04
With its high level of vertically integrated
production and the adoption of 28 ad-
vanced production technologies, the
Group specializes in the development of
innovative, sustainable products that are
lightweight and durable, reusable, recy-
clable, made from recycled raw materials,
and manufactured using alternative raw
materials (biodegradable packaging). This
approach ensures that each product is
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 119 of 370
designed with consideration for its entire
lifecycle, from sourcing and production to
end-of-life management.
A core element of the Group’s strategy is
the commitment of its Research and De-
velopment (R&D) departments to creating
solutions that offer maximum functionali-
ty with a low environmental footprint. This
includes investments in advanced tech-
nologies that reduce energy consump-
tion, emissions, and material waste during
production. These efforts are fully aligned
with the European plastics strategy in
the circular economy, demonstrating the
Group’s active role in supporting sustain-
able development goals.
Many of the Group’s products are certified
under international initiatives that pro-
mote the recyclability of plastic packaging
and ensure traceability and transparency,
such as RecyClass and TUV OK Recycling.
The Group has also conducted EPD® (En-
vironmental Product Declaration) assess-
ments for specific product groups, based
on corresponding Life Cycle Assessment
(LCA) studies certified by independent au-
ditors for their validity, and published in
the international database of EPD Interna-
tional AB.
In line with the principles of the Circular
Economy, the Group prioritizes the design
and production of products with sustaina-
ble characteristics in order to offer value to
the customer through its sustainable prod-
ucts. No packaging contains hazardous
chemicals listed in the REACH 1907/2006
database, while the Group also aims to use
chemically recycled PP, which can be used
in food-contact packaging.
Furthermore, the Group is developing
various digitalization options for reusable
packaging products, including QR codes,
digital watermarks, and other features re-
lated to the Digital Product Passport.
The production of plastic packaging items
is the Group’s main economic activity fall-
ing under the EU Taxonomy category with
a significant contribution to the transition
to a circular economy. Continuous efforts
are being made to align all products in this
sector with technical screening criteria,
such as the use of circular raw materials or
design for reuse.
(b) Use of Secondary Raw Materials
E5-2_01-02
The Group is firmly committed to the use
of secondary raw materials in order to
enhance the sustainable character of its
products. To further support these efforts,
the Group utilizes a central recycling unit,
which functions as a hub for processing
recycled materials. In addition, most of the
Group’s production facilities are equipped
with specialized recycling machinery that
manages their production waste.
This initiative aligns with the requirements
of the EU Taxonomy, specifically under the
Circular Economy pillar, while also serving
the Group’s voluntary commitment to the
Circular Plastics Alliance, made in 2018,
which refers to the replacement of 8,500
tons of virgin raw material with recycled
material by 2025.
The Group constantly seeks to increase the
use of recycled raw materials, significantly
reduce waste, and lower greenhouse gas
emissions through its production process-
es. Its circular economy-oriented strategy
aims to keep materials in the economic
cycle for as long as possible through reuse
or recycling and certainly away from the
environment, landfills, and oceans—thus
mitigating negative impacts on biodiver-
sity across the value chain.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 120 of 370
(c) Solid Waste Management
E5-2_05-06
The Group fully complies with legal re-
quirements regarding waste manage-
ment. Within this framework, an environ-
mental impact study has been conducted,
primarily focused on the optimal way to
manage waste, while also complying with
contractual obligations. The Group imple-
ments internal procedures such as compil-
ing reports on the types and quantities of
waste produced, while efforts are made
to reduce waste at the plants through the
method of source separation. To achieve
this, the Group follows due diligence pro-
cedures and regularly monitors waste
management activities.
It is also ensured that companies receiving
waste for final processing or disposal pos-
sess the necessary and valid operational
permits.
Moreover, due to the nature of its activi-
ties, the Group uses a range of chemical
substances, and effective management of
potential environmental risks is a top pri-
ority. The Group fully complies with legal
requirements for the temporary storage
and use of chemicals, informs and trains
employees on their safe use, and does not
use any chemical or other hazardous sub-
stances subject to national or international
bans. Additionally, all chemicals are placed
on metal bases, and any small leaks are
collected in special containment units. All
chemical substances are stored in desig-
nated areas with appropriate signage, and
access is permitted only to authorized per-
sonnel who are thoroughly familiar with
safety regulations.
As part of the “Zero Waste to Landfill” ini-
tiative, the Group has appointed respon-
sible personnel to continuously monitor
and improve resource use. This is achieved
through regular meetings and progress
monitoring indicators. One of the key ac-
tions is the implementation of compre-
hensive flowchart mapping of facilities,
which includes the analysis of material,
energy, and waste flows. This mapping
process enables the Group to identify ar-
eas with opportunities for waste reduction
and to apply targeted solutions. Further-
more, through separate waste streams, the
Group seeks to continuously reduce waste
sent to landfill. Through the “Zero Waste
to Landfill” initiative, the Group has begun
unifying signage across all facilities with
distinct colors per waste stream, matched
with containers or large outdoor collection
bins. A core and ongoing objective is the
gradual reduction of mixed waste streams
within facilities and the improved utiliza-
tion of other streams sent for recycling via
licensed recycling partners.
(d) Circular Economy Platform “In the
Loop”
E5-2_07-10
The environmentally targeted circular
economy platform IN THE LOOP of the
Group is based on the three pillars of cir-
cular economy: REDUCE | REUSE | RECYCLE,
and connects companies, brands, public
institutions, and consumers—now num-
bering more than 200 participating mem-
bers—contributing to the reduction of
environmental footprint across the entire
value chain. It reflects the Group’s approach
regarding the environmental impacts of
packaging materials and the avoidance of
their disposal into the environment.
The platform designs specialized reuse sys-
tems that enable the recording and certifi-
cation of usage cycles, as well as specialized
closed/controlled-loop recycling systems.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 121 of 370
Benefits of using the platform include:
•
Implementation
of the transition
from linear to
circular economy
•
Reduction of the
environmental
footprint of
products
•
Conservation of natural resources
•
Reduction of plastic waste
•
Feasibility of reuse
•
Production of more products from
recycled raw materials
For the responsible management of waste,
cooperation is essential among all stake-
holders in the plastic value chain: retail
companies, producers, recyclers, recycling
systems, public authorities, local com-
munities, and end-users—so that plastic
can be collected and sorted in the most
proper and sustainable way. This ensures
the availability of high-quality material for
recycling, which will be used to produce
plastic products of equal or greater value.
E 5-3 Goals Related to Resource Use
and Circular Economy
E5-3_01-09 & E5-3_13
Based on the Group’s sustainable devel-
opment strategic plan and the strategic
priorities that have been set, two specific
short-term goals have been established
within the framework of the circular econ-
omy. These goals are not a mandatory re-
quirement under the legal framework, but
are voluntary. These goals were set with a
base year of 2021, when the Group began
to have data on carbon emissions, and it
was a goal to set common base years as
much as possible. Furthermore, both goals
are medium-term and cover a five-year
period. They were set based on historical
data and in the context of the require-
ments of the European Taxonomy as well
as national legislation. The approach for
their determination was through internal
processes, and their scope includes all pro-
duction facilities. The scenario used was
the Group’s progress in recent years on
these issues (use of recycled raw materi-
als and waste management), the matura-
tion of the people at the facilities through
the experience they had gained, and the
Group’s business plan.
The involvement of stakeholders in the
goal-setting process and generally in ac-
tions related to the principles of the circular
economy is shaped through a diverse par-
ticipatory process. The Group, through fre-
quent communication with the local com-
munity (Municipality, Region, universities,
social organizations via the Social Center),
understands and records their needs and
expectations regarding the circular econ-
omy. Through meetings and participation
in conferences, discussions are held on re-
cyclable materials, eco-design of products,
and waste management, while the social
dimension of the goals is also considered.
Through structured meetings, initially
with subsidiary companies, the goals are
defined, based on real data, and regular
updates on their progress are carried out.
Both goals concern the Group’s production
facilities and contribute to the fulfillment
of the Sustainable Development, Environ-
mental, and Social Responsibility Policy,
which describes the priority on optimal
management of solid waste, resource ef-
ficiency optimization in production units,
and the adoption of practices in line with
the principles of the circular economy to
ensure the efficient use of natural resourc-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 122 of 370
es and raw materials through the use of
recycled raw materials. Furthermore, both
goals were implemented with a five-year
time horizon and a base year of 2021. They
are not based on scientific data but take
into account the guidelines of national and
European legislative frameworks. In deter-
mining the goals, there was collaboration
and coordination with the Group’s produc-
tion facilities, but not with other external
stakeholders.
GOAL 2025:
30%
INCREASE IN THE
USE OF RECYCLED
RAW MATERIALS
COMPARED TO
2021
E5-3_03
A primary goal of the Group is the use of
recycled raw materials with the main pur-
pose of optimizing their use, without neg-
atively affecting the technical characteris-
tics of the products, or increasing energy
consumption and scrap production in the
manufacturing processes. Once these con-
ditions are met, the Group has set specific
targets regarding the increase in recycled
raw materials in its products. This goal
contributes to the increase in the circular-
ity of products and the reduction in the
use of primary raw materials.
GOAL 2025:
40%
REDUCTION IN
SOLID WASTE
SENT TO LANDFILL
COMPARED TO
2021
The Group aims to reduce the weight of
solid waste sent to landfill. This is linked
to the waste hierarchy, where landfilling is
the last step. Through actions being taken,
waste reduction and the reuse of residues
in manufacturing processes are prioritized.
Then, efforts are made to optimize the
separate waste streams. Energy recovery
is included in the Group’s medium-term
goals and is initially explored to determine
whether the conditions mature, so the
Group is ready to meet the requirements
and make energy recovery a reality.
E5-4 Resource Inputs
The Group recognizes the importance
of transparency regarding the flow of re-
sources in its activities. The resource in-
puts of the Group include raw materials
such as polypropylene (PP), polyethylene
(PE), polyester (PET), and paper, as well as
secondary materials such as additives, UV
stabilizers, pigments, plastic and paper
packaging materials, and pallets. These
materials are key elements of the manu-
facturing process and are used in all the
Group’s production units. Specifically, the
total weight of the products and techni-
cal and biological materials used during
the reporting period pertains solely to the
Group’s raw materials. As for secondary re-
usable or recycled components, interme-
diate products, and materials used in the
production of products and services (in-
cluding packaging), they refer to all other
materials used in the Group’s production
processes.
There is no overlap or double-counting
of materials between the subsidiaries. In
cases where subsidiary companies sup-
ply other subsidiaries of the Group, these
materials are counted only once, i.e., they
are counted as materials exiting the Group
and are not considered as intra-company
transactions.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 123 of 370
E5-4_06
The data used comes from direct measurements, and care is taken to ensure that any
transactions between the Group’s subsidiaries are not double-counted.
excl. JVs
JVs
Total weight of products and technical and biological
materials used during the reporting period.
108,678,452.74 10,741,884.78
Percentage of sustainably sourced biological materi-
als (and biofuels for non-energy use), with reference
to the relevant certification scheme and the applica-
tion of the cascading principle. (%)
0.0043 0
Secondary reusable or recycled components, inter-
mediate products and materials used in the produc-
tion of goods and services (including packaging), in
kilograms.
13,506,999.00 1,975,820.89
Percentage of the above secondary materials in rela-
tion to the total resources used.
12% 18%
E5-5 Resource Outputs
Regarding outputs, the Group produces
and provides a wide range of final prod-
ucts, such as technical fabrics, rigid and
flexible packaging solutions, as well as ag-
ricultural products. More detailed informa-
tion regarding product groups by sector
can be found in the section General Infor-
mation, Chapter SBM-1 Strategy, Business
Model, and Value Chain.
Regarding the waste generated at the
Group’s facilities, most of it consists of in-
dustrial waste. A very small portion is pro-
duction plastic waste, while the majority
consists of packaging materials.
These include plastic materials (such as
polypropylene, polyethylene, and PET),
plastic and paper packaging materials
(such as cardboard boxes and other boxes,
packaging film, tubes, and other auxiliary
materials, etc.), wood (mainly pallets), met-
als from construction and machinery, as
well as oils from mechanical equipment.
E5-5_02
The expected lifespan of products placed
on the market by the Group varies depend-
ing on the application, meaning the lifes-
pan of a technical fabric intended for use
in the construction industry differs from a
packaging solution. In all cases, the Group’s
products comply with the requirements of
the required standards. The Group con-
ducts continuous checks through special-
ized quality control departments.
E5-5_06
Through the technical characteristics of
the products and the standards followed,
it appears that the product design follows
the principles of the circular economy and
the requirements of the legislative frame-
work for product durability, reusability, re-
cyclability, or the content of recycled raw
material, depending on the application.
E5-5_16
The Group does not produce radioactive
waste.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 124 of 370
E5-5_17
For the calculation of data concerning waste, these are derived from direct measure-
ments through the Group’s cooperation with licensed waste management systems for
all separate waste streams.
E5-5 – Resource Outflows excl. JVs JVs
Total amount of waste generated 4,997, 514 1,588,672
Total amount (by weight) of waste diverted from dis-
posal (Non-hazardous waste)
3,946,188 961,331
i. Preparation for reuse 1,998,715 337,496
ii. Recycling 1,946,593 623,835
iii. Other recovery operations 880 0
Total amount (by weight) of waste diverted from dis-
posal (Hazardous waste)
75,287 133,266
i. Preparation for reuse 0 0
ii. Recycling 75,287 7,123
iii. Other recovery operations 0 126,143
Total amount (by weight) of waste directed to disposal
(Non-hazardous waste)
976,039 456,657
i. Incineration 31,350 0
ii. Landfilling 792,489 456,657
iii. Other disposal operations 152,200 0
Total amount (by weight) of waste directed to disposal
(Hazardous waste)
0 37,418
i. Incineration 0 37,418
ii. Landfilling 0 0
iii. Other disposal operations 0 0
Total amount of non-recycled waste 976,039 494,075
Percentage of non-recycled waste 19.5% 31.1%
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 125 of 370
S1.SBM-2
The Group’s workforce constitutes the
primary internal stakeholder regarding
its activities. In a Group with a family-ori-
ented culture, respect for human rights
and contribution to local communities are
fundamental priorities. This contribution is
embodied by the “Stavros Chalioris Social
Center,” which offers educational, cultural,
and community support initiatives. This
Civil Non-Profit Organization operates as
a hub for educational, cultural, and social
actions that align with the Group’s values
of inclusion and sustainability. Through
charitable initiatives and health services,
the Social Center provides direct support
to employees, their families, and local
citizens regardless of any connection to
the Group. At the same time, it strength-
ens the Group’s relationship with the local
community, leaving a positive footprint
and promoting environmental awareness
and sustainable education.
Material Impacts, Risks and
Opportunities, and Their Interaction
with Strategy and the Business Model
S1.SBM-3.01-12
Workplace safety is a strategic priority for
the industry, and the Group systematically
works to create a culture of safety. From
employee clothing and factory signage to
investment design and strategic priorities,
the mindset “Safety Above All” is embed-
ded across the Group. Safety specifications
are considered in both day-to-day opera-
tions and in the design of any new expan-
sion, influencing how projects and strat-
egy are implemented.
The Group employs more than 2,000 peo-
ple in 9 countries, and the entire workforce
is included in this report. Employees hold
permanent and fixed-term contracts, in
both full-time and part-time formats, de-
pending on business needs. The majority
of employment contracts are full-time and
permanent.
The Group maintains internal monitoring
and compliance mechanisms, such as the
whistleblowing policy and ongoing em-
ployee communication, ensuring fair treat-
ment and early identification and manage-
ment of potential adverse impacts.
The Group does not operate in countries
or regions with a high risk of human rights
violations, including child or forced labor.
Its facilities are located in countries gov-
erned by European legislation.
Significant negative impacts on the work-
force primarily relate to the risk of work-
place accidents, particularly in factories
due to the industrial environment, contin-
uous operations, and use of complex ma-
chinery. The Group recognizes that spe-
cific employee groups, such as new hires
and those performing specialized tech-
nical tasks, may face higher injury risks.
Therefore, new employees are thoroughly
trained on factory processes and health
and safety protocols, while targeted train-
ing programs and strict safety procedures
are in place.
Additionally, the difficulty in sourcing
available skilled technical personnel cre-
ates risks in filling positions and ensuring
smooth plant operations. Most jobs are
offered in regional towns, outside major
urban centers. The Group supports job
8.3 Social Information
ESRS S1 – Own Workforce
Interests and Views of Affected Stakeholders
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 126 of 370
preservation through strategic develop-
ment investments, offers sustainable wag-
es and benefits to all staff, and promotes
stable employment and career develop-
ment in local communities. It provides
opportunities for hiring from local popula-
tions in a work environment that promotes
respect, equality, and safety, with training
opportunities that prepare employees to
meet job demands.
The Group has not identified significant
negative workforce impacts resulting from
its transition strategies toward greener
and more climate-neutral operations. Its
factories already adopt circular economy
principles (reuse–reduce–recycle) and
have made recycling investments. On the
contrary, the Group’s green investments
create new employment opportunities
due to growing needs and help develop
skills related to sustainable resource man-
agement, advanced recycling technolo-
gies, and circular economy practices in
production.
MDR-P_01-06
The Group implements policies to manage
key workforce issues, such as the Human
Rights Policy, Sustainable Development
and Environmental and Social Responsi-
bility Policy, Prevention of Violence and
Harassment Policy, and the Health, Safety,
Environment Policy. These policies apply
across all companies and employees. The
General Manager, representing top man-
agement, is responsible for implementa-
tion, and the policies are accessible to staff
through the corporate learning platform
and internal digital channels.
The Human Rights Policy is aligned with
the 10 principles of the UN Global Compact
and establishes zero tolerance for human
rights violations. The policy universally
commits the Group to respecting human
rights and combating forced labor, child
labor, and any form of discrimination. The
Group is committed to implementing cor-
rective actions in cases of harm, although
the monitoring plan for remediation is not
specified.
In 2024, the Group began implementing its
Supplier Code of Conduct in Greek compa-
nies for key suppliers of materials and ser-
vices. The framework complies with the 10
UNGC principles and European legislation
requirements.
S1-1 – Policies Related to Own
Workforce
The Group is committed to maintaining
a work environment based on trust, re-
spect, and open communication, while
safeguarding employee well-being and
work-life balance. It ensures decent work-
ing conditions and fair remuneration in
compliance with applicable labor laws and
standards (working hours, leave, overtime,
etc.). The Group also guarantees freedom
of expression without fear of retaliation
or negative consequences. There is zero
tolerance for offensive or inappropriate
behavior, unfair treatment, or retaliation of
any kind.
According to the Code of Ethical Conduct
and Internal Work Regulations, any form of
physical or verbal harassment — including
sexual, racial, or defamatory — is prohib-
ited both within the workplace and in all
activities related to the Group, regardless
of location. The Group is committed to op-
erating inclusively and to eliminating all
employment-related discrimination, pro-
moting equal pay for equal work, profes-
sional training, and equal opportunity in
decision-making processes.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 127 of 370
Employees receive training on corporate
policies, including human rights, to raise
awareness and foster understanding of the
Group’s governance framework.
The Group is dedicated to identifying, as-
sessing, preventing, and eliminating hu-
man rights violations by applying due dili-
gence based on the Human Rights Policy
and implementing immediate corrective
actions in case of incidents. Specifically,
it is committed to employee awareness
through education, promoting respect
and protection of human rights across all
operations, and responding to incidents
through a whistleblowing mechanism that
allows employees to report concerns and
violations. It is also committed to investi-
gating and resolving employee concerns
and complaints through corrective meas-
ures. Finally, the policy explicitly prohibits
all forms of child labor, forced labor, and
human trafficking.
S1-1.09
The Group implements a Health, Safety,
Environment Policy across all companies to
prevent potential damage to property and
personnel. The policy aligns with interna-
tional ISO standards for risk prevention
and accident minimization. Continuous
risk assessments are carried out by accred-
ited external bodies as well as internally
by Safety Engineers and the Occupational
Physician. Safety measures are applied at
the facilities, and corrective actions are im-
plemented when necessary.
S1-1.10
The Group is committed, through its Hu-
man Rights Policy and its Code of Ethical
Conduct and Integrity, to a zero-tolerance
approach toward workplace harassment
and any form of discrimination based on
race, gender, religion, nationality, age,
disability, orientation, and other grounds.
It is also committed to providing equal
opportunities, operating in an inclusive
manner, and taking appropriate measures
to eliminate all forms of discrimination in
employment, equal pay for equal work,
professional training and education, and
in decision-making processes.
In its policy for the prevention and com-
batting of violence and harassment, the
Group is committed to strengthening
mechanisms and procedures to prevent
and address violence and harassment and
to promoting a safe and inclusive work
environment.
The Group prohibits any form of discrimi-
nation. The procedures for recruiting and
hiring personnel, access to education and
training, performance evaluation, remu-
neration, and the overall professional ex-
perience of employees are protected from
discrimination on the grounds of race,
gender, color, national or social origin, re-
ligion, age, disability, sexual orientation, or
political beliefs.
In its policy for the prevention and com-
batting of violence and harassment, the
Group is committed to ensuring the pro-
tection of vulnerable groups among its
personnel and to allocating resources for
their support. It also commits to acting as
an ally to employees who are victims of do-
mestic violence, supporting them, show-
ing leniency in work-related matters, and
providing access to resources that help re-
solve and restore the situation.
The policy and procedure for handling
reports outlines the official reporting
channels: the company’s postal address,
the telephone complaint line, and the
digital reporting platform, as well as the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 128 of 370
procedure for receipt, investigation, and
assessment of reports by the designated
Report Intake and Monitoring Officers (RI-
MOs). The goal of all these mechanisms is to
ensure an inclusive working environment
free from discrimination, which is also pro-
moted through training of employees and
management staff in understanding zero-
tolerance policies on discrimination and
harassment, and in utilizing the available
reporting mechanisms.
S1-2 – Processes for engaging
with employees and their
representatives regarding
impacts from material
matters
S1-2.01-06
The Group’s management collaborates
with employee unions on an annual basis
or more frequently and is informed about
significant employee-related issues. Em-
ployee unions are formed through formal
electoral processes organized every three
years, and elected members represent the
views and concerns of the workforce to
management. The framework for coopera-
tion between management and employ-
ees is defined by the Internal Labor Regu-
lation and the Company-Level Collective
Labor Agreement.
Although these two documents do not ex-
plicitly reference the obligation to respect
human rights, this obligation is clearly de-
fined by the Group’s Human Rights Policy
and the Code of Ethics and Conduct, which
are binding for all employees.
Following consultations between the par-
ties, a Company-Level Collective Labor
Agreement is concluded, covering institu-
tional, salary, and non-salary conditions.
The Group’s management and appointed
executives hold discussions with union
representatives where unions exist, or di-
rectly with employees in countries where
no elected representatives are in place.
Consultation with the union is the respon-
sibility of the CEO or the appointed Manag-
ing Director of each subsidiary. In Greece,
the Group has concluded, through consul-
tation with unions, an Internal Labor Regu-
lation, which is registered on the ERGANI
platform and serves as the main set of la-
bor rules. Similarly, the major subsidiaries
have manuals that describe the framework
of acceptable behaviors, always in line
with the Code of Ethics and Conduct.
The Group does not implement a formal
process for evaluating the effectiveness of
collaboration with employee representa-
tives or its workforce. The presence of in-
dustrial peace and the absence of strong
reactions, such as work stoppages and
strikes, serve as the primary indicators of
employee and representative satisfac-
tion and are considered clear evaluation
criteria. Feedback between the parties
is ongoing and based on direct verbal
communication.
S1-2.07
Similarly, the Group does not implement a
specific procedure for obtaining the views
of vulnerable employee groups, nor does
it have a specialized process for engage-
ment with the workforce.
S1-3 – Procedures for the
remediation of negative
impacts and mechanisms for
workers to raise concerns
S1-3.01-07
The Group operates official channels for
both identified and anonymous reports
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 129 of 370
in line with its whistleblowing policy and
procedure. Reports can be submitted ei-
ther anonymously or with personal iden-
tification via letter to the company’s ad-
dress, through a dedicated telephone line,
or through the digital whistleblowing plat-
form. Report management is handled by
appointed Whistleblowing Officers, who
are registered in the ERGANI system for all
Group companies, and act in accordance
with principles of confidentiality, due dili-
gence, and integrity.
The whistleblowing policy and procedure
do not provide specific processes for re-
mediation in case of significant negative
impacts on workers, nor do they indicate
how the effectiveness of remediation is
evaluated.
The contact details of the Whistleblow-
ing Officers are posted on notice boards
and annual reminder communications
are sent to the workforce. Training on re-
porting procedures is provided both dur-
ing onboarding and on a recurring basis.
The whistleblowing phone line and digital
platform are operated by third-party, in-
dependent service providers. The report-
ing channels are permanently posted on
notice boards, sent via email reminders to
all personnel, and made available in the of-
ficial languages of the countries in which
the Group operates.
The Group maintains an official telephone
line and digital platform for identified
and anonymous reporting. Designated
Whistleblowing Officers are appointed.
These reporting channels are available
24/7, and the Officers receive real-time
notifications of new reports via dedicat-
ed applications and alerts from the ser-
vice providers. Reports are logged in real
time. Each case is monitored until its in-
vestigation is completed and archived on
the electronic platform managed by the
Group’s independent service provider.
S1-3.08-11
The whistleblowing policy states that un-
der the principle of confidentiality, the
identity of the whistleblower is protected
and no adverse consequences are permit-
ted as a result of the report. The policy
against violence and harassment explicitly
guarantees the protection of employees
and ensures that no retaliation is taken
against whistleblowers. The Group has
created conditions that foster employee
trust in the official reporting channels.
Employees have direct access to the con-
tact details of the Whistleblowing Officers
and to the digital reporting tools, which are
posted on notice boards and also distrib-
uted to them individually. Whistleblowers
can maintain anonymity and report inap-
propriate behavior without revealing their
identity.
The Whistleblowing Officers are inde-
pendent from the company, ensuring free-
dom of action, and the operators of the
telephone line and platform are also inde-
pendent service providers.
S1.MDR-A
Health and safety actions are coordinated
by the Safety Technicians and Occupa-
tional Physicians of the facilities, and the
implementation of improvements is ap-
proved by the General Managers. Actions
are reviewed monthly during safety meet-
ings at the factories, with participation
from senior management, employees, and
union representatives. During these meet-
ings, arising issues are examined, decisions
are made and approved by senior man-
agement, and actions are implemented.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 130 of 370
Training, development, and talent acquisi-
tion efforts are coordinated by the Human
Resources Department in collaboration
with Factory and Company Directors.
To attract employees, the Group’s HR
Department uses reputable job posting
platforms and maintains close collabora-
tion with educational institutions, such as
secondary schools and universities. The
Group participates in career days host-
ed by academic and public institutions
(e.g., Democritus University Career Days,
TedxDUTH, Public Employment Service
Career Days) and supports initiatives for
educational engagement.
Training needs are reviewed annually, ap-
proved by senior management, and im-
plemented with the support of the HR
Department.
S1-4 – Actions to address significant
impacts on the workforce,
ways to mitigate major risks
and seize key opportunities,
and the effectiveness of those
actions
S1-4.01-04
In the area of health and safety, the Group
adheres to due diligence principles by
providing the necessary equipment and
protective gear required at each job posi-
tion, enabling employees to carry out their
tasks safely. The goal is to cultivate a safety
culture and continuously reduce incidents
and accidents.
To reinforce the safety culture, the Group
organizes internal training sessions on
health and safety topics such as introduc-
tory training, fire safety, forklift operation,
safe execution of hot works, and more.
Safety signage is prominently displayed in
work areas, and educational messages are
shown on factory screens.
Factories monitor incidents daily and track
lost work time due to accidents. On a
monthly basis, the Group consolidates and
reviews overall results. During monthly
safety meetings, incidents, impacts, and
corrective actions are analyzed with the
participation of senior management.
Each factory employs a full-time Safety
Technician responsible for occupational
safety, and each company employs an Oc-
cupational Physician responsible for em-
ployee health.
Regarding recruitment and employee de-
velopment, the HR Department organizes
initiatives to connect Group companies
with local educational institutions and
participate in their activities. These in-
clude visits from educational institutions,
student tours, and presentations at voca-
tional high schools to introduce youth to
the Group and promote internship and ap-
prenticeship opportunities.
The Group allocates resources for salaries,
benefits, and employee training. For hard-
to-find specialties, the Group funds the
education of employees or their children
and ensures continued employment after
the completion of studies.
The Group raises employee awareness
through trainings and informational ses-
sions, with particular emphasis on Health
& Safety and prevention of violence and
harassment incidents. These trainings are
repeated annually to ensure vigilance.
For health and safety, the Group provides
personal protective equipment as required
by safety standards to both personnel and
equipment. Injuries are monitored by Oc-
cupational Physicians, and counseling
and access to resources are provided for
optimal outcomes. The Group also offers
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 131 of 370
medical care coverage through its health
insurance program.
Monthly safety meetings are held where
safety officers discuss incidents and moni-
tor their resolution.
The Group implements a remuneration
policy for the workforce and ensures full
compliance with labor laws. It offers life,
health, and medical insurance coverage to
all employees, with the option to extend
coverage to family members. Training
is provided on health and safety issues,
along with all necessary personal protec-
tive equipment. Additionally, a digital plat-
form with training material is available,
and both internal and external training
programs are funded to enhance employ-
ee skills and knowledge in line with busi-
ness needs.
The Group respects trade union rights and
provides resources for the exercise of such
rights. Lastly, the Group is committed to its
Human Rights Policy to prevent discrimi-
nation and ensure equal opportunities
and pay regardless of gender.
The effectiveness of these benefits is
discussed annually with employee rep-
resentatives, and decisions are made for
corrective actions. Equal pay and bridging
the gender pay gap are considered by the
CEO and General Managers during salary
review processes, in line with the Group’s
remuneration policy.
S1-4.05
There is no documented procedure for
monitoring the actions required to ad-
dress actual or potential adverse impacts
on staff. General Managers assess the situ-
ation and approve corrective actions pro-
posed by Safety Technicians and Occupa-
tional Physicians.
S1-4.06–07
To mitigate significant risks, the Group
conducts an annual risk and hazard as-
sessment under the responsibility of the
Regulatory Compliance Department and
the General Managers of each company.
Regarding Health & Safety issues, an Oc-
cupational Risk Assessment Study has
been carried out, and Personal Protective
Equipment is provided at workstations
where required. Periodic inspections are
carried out by accredited external bodies,
which identify risk areas and recommend
improvements. The certifications of ma-
chines (CE marking) are also monitored
as required by law, and staff training is
conducted.
To ensure facility security, a surveillance
system and security personnel are in place
at the Group’s larger facilities.
An annual internal training plan is devel-
oped for Health & Safety topics, while ex-
ternal training is provided to enhance em-
ployee skills.
To attract personnel, job advertisements
are posted in local media and through
organizations such as the Public Employ-
ment Service (DYPA) or educational insti-
tutions. Employees and trade unions are
also informed through announcements
about open job positions to encourage
referrals.
S1-4.08–09
The Group applies a GDPR policy for data
protection, and the Regulatory Compli-
ance and Risk Management Department
conducts periodic audits to ensure the
proper use of data.
The Procurement Department imple-
ments the Group’s procurement policy,
and the Sales Department follows the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 132 of 370
Group’s sales policy to minimize any ad-
verse effects on personnel.
The Group monitors progress on Health
& Safety issues with the goal of eliminat-
ing accidents through the performance
targets set for Plant Managers and Safety
Technicians. Lost working hours and acci-
dents are recorded and monitored to veri-
fy a reduction over time and to identify risk
areas in need of improvement.
In terms of training, both internal and ex-
ternal training hours are recorded and
monitored, although no specific imple-
mentation targets have yet been set per
employee.
To manage significant impacts, the Group
employs Safety Technicians at its plants to
handle Health & Safety matters, monitor
legislation, continually assess risks, and ini-
tiate improvements upon management’s
decision.
At the Group level, a Regulatory Compli-
ance and Risk Management Department
and an Internal Audit Department con-
duct periodic audits and provide informa-
tion to management for implementing
improvements.
S1-4.19
Employee representatives engage in con-
sultations with management to sign the
Company-Level Collective Labor Agree-
ment and to implement improvements
in remuneration, benefits, and non-wage
measures to benefit staff.
To mitigate negative impacts on the work-
force due to the transition to a greener and
climate-neutral economy, the Group offers
training programs to empower employees
and invests in recycling lines and systems.
In case of job cuts, the Group first considers
the possibility of transferring employees
to other facilities. Subsequently, requests
for early retirement, fixed-term contracts,
and seasonal employment are evaluated.
In the event of layoffs or dismissals, the
Group provides, beyond the legally re-
quired severance pay, a reemployment
program with certified counselors.
In managing significant impacts, the
Group’s Top Management or the General
Management of each company is involved,
with the support of the Human Resources
Department and, as needed, external con-
sultants. For risk management involving
the Group’s Senior Executives, the Remu-
neration and Nomination Committee of
the Board of Directors provides advisory
support.
As part of cultivating a safety culture, the
Group has systematically approached
Health & Safety issues in the workplace by
identifying risks, providing training, and
developing control and improvement in-
frastructure. Measurable targets have not
yet been set, but are expected in the me-
dium term. The long-term safety goal re-
mains the elimination of accidents.
No targets have been set yet for training
either, although the Group aims to in-
crease the number of training hours per
employee. Targets are expected to be es-
tablished in the medium term.
S1-5 – Targets for managing
material negative impacts,
advancing positive impacts,
and managing material risks
and opportunities
S1-5.01
Corporate targets are set on an annual
basis and derive from each company’s
Strategic Plan. For General Managers and
Senior Executives, the annual targets are
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 133 of 370
discussed between the executive and the
CEO, and the final targets are approved by
the Remuneration and Nomination Com-
mittee (RNC) and ultimately the Board of
Directors. General Managers are respon-
sible for cascading the strategic targets
within the organization they manage,
following discussions with department
heads. Employees propose their individual
targets to their direct supervisor and joint-
ly agree on the final objectives.
The primary objective of the Group is the
achievement of the annual budget. The
company’s financial results are monitored
and discussed in a dedicated meeting on
a monthly basis. Department heads are in-
formed and can track the company’s per-
formance against the targets. During the
monthly results review meeting, improve-
ments and lessons learned from the previ-
ous month are discussed with department
heads.
S1-MDR-T_14
The Group has prioritized, within its stra-
tegic plan, the improvement of safety
culture and the elimination of workplace
accidents. Progress is monitored monthly
through Health & Safety meetings, dur-
ing which incidents, improvements, and
areas for correction are recorded. Results
are compared to the previous year, and
conclusions are drawn regarding progress
at each facility. Improvement measures are
then taken to achieve the ultimate goal of
eliminating workplace accidents.
The Group’s aspiration is zero accidents.
The next report will include a more de-
tailed description of the target-setting
process for material social topics.
S1-MDR-M
The Group collected all relevant data con-
cerning its workforce, which are analyzed
in the following sections based on the
number of employees at the end of the
reporting period, as well as the average
number of employees during the year. No
assumptions were used in compiling the
data.
The data exclusively concern individuals
classified as employees, according to the
Group’s internal definition and the rel-
evant reporting standards. The relevant
information and employee categories are
aligned with internal Human Resources
records. All data are fully aligned with the
requirements of the Corporate Sustainabil-
ity Reporting Directive (CSRD) and the Eu-
ropean Sustainability Reporting Standards
(ESRS).
S1-6 – Characteristics of the
undertaking’s employees
S1-6.1 Information on the Number of
Employees by Gender
Gender
Number of
employees
(Head Count) -
Excluding joint
ventures (JVs)
JVs
Men 1,452 315
Women 292 351
Other
Not disclosed
Total employees 1,744 666
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 134 of 370
S1-6.2 Number of Employees in
Countries with at Least 50
Employees Representing
at Least 10% of the Total
Number of Employees
Country
Number of employees
(Head Count) - Excluding
joint ventures (JVs)
JVs
Greece 1,172 401
Scot-
land
345 0
S1-6.3 Information on employees by
type of contract, classified by
gender (Head Count / FTE)
Excluding joint ventures (JVs)
Category Women Men Total
Total number of em-
ployees
292 1,452 1,744
Permanent employ-
ees
274 1,332 1,606
Temporary employees 18 120 138
Employees without
guaranteed hours
Full-time employees 1,727
Part-time employees 17
JVs
Category Women Men Total
Total number of employees 351 315 666
Permanent employees 126 232 358
Temporary employees 225 83 308
Employees without guaranteed hours
Full-time employees 664
Part-time employees 2
S1-6.4 Information on Employees by Type of Contract and Region (Head Count /
FTE)
Excluding Joint Ventures (JVs)
Category
Greece
Scot-land
Bul-garia
Ser-bia
Ire-land
Swe-den/
Norway
United
States
Roma-nia
Total employees 1,172 345 150 9 53 15
Permanent employ-
ees
1,045 337 150 7 52 15
Temporary employees 127 8 0 2 1 0
Employees without
guaranteed hours
Full-time employees 1,172 333 149 9 50 14
Part-time employees 0 12 1 0 3 1
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 135 of 370
JVs
Category
Greece
Scot-land
Bul-garia
Ser-bia
Ire-land
Swe-den/
Norway
United
States
Roma-nia
Total employees 401 160 105
Permanent employ-
ees
106 147 105
Temporary employees 295 13 0
Employees without
guaranteed hours
Full-time employees 401 158 105
Part-time employees 0 2 0
Number of employees who have left
the company
Thrace Plastics Co 3
Thrace Nonwovens & Geosyn-
thetics SA
78
Thrace Polyfilms SA 26
Thrace Pack SA 54
Don & Low Ltd 56
Thrace Synthetic Packaging Ltd 13
Thrace Ipoma SA 31
Thrace Polybulk AS 0
Thrace Polybulk AB 0
Thrace Plastics Packaging DOO 2
Number of employees who have left
the com-pany (JVs)
Thrace Eurobent SA
2
Thrace Greenhouses SA 282
Thrace Greiner Packaging SRL 50
Lumite Inc 31
employee turnover rate %
Thrace Plastics Co SA 12.0
Thrace Nonwovens & Geosyn-
thetics SA
11. 6
Thrace Polyfilms SA 20.0
Thrace Pack SA 15.3
Thrace Ipoma SA 1.7
Don & Low Ltd 16.2
Thrace Synthetic Packaging Ltd 28.0
Thrace Polybulk AS 0
Thrace Polybulk AB 0
Thrace Plastics Packaging DOO 22.0
employee turnover rate (JVs) %
Thrace Eurobent SA 25.0
Thrace Greenhouses SA 71.5
Thrace Greiner Packaging SRL 33.1
Lumite Inc 21.0
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 136 of 370
Excluding joint
ven-tures (JVs)
Thrace
Plastics Co
SA
Thrace
Nonwovens
& Geosyn-
thetics SA
Thrace
Polyfilms SA
Thrace
Pack SA
Don & Low
Ltd
Thrace
Synthetic
Packag-
ing Ltd
Thrace
Ipoma
SA
Thrace
Poly-
bulk AS
Thrace
Poly-
bulk AB
Thrace
Plastics
Packag-
ing DOO
Average num-
ber of employ-
ees
25 651 123 352 345 53 150 11 4 9
JVs
Thrace
Eurobent SA
Thrace
Green-
houses SA
Thrace
Greiner
Packaging
SRL
Lumite
Inc
Average
number of
employees
8 394 105 160
S1-6_17
The information presented in this section
is compared with the corresponding fig-
ures in the financial statements.
S1-7 – Characteristics of non-em-
ployees in the undertaking’s
workforce
Non-employee workers are defined as
individuals who provide services to the
Group through third parties or external
partners and are not part of the Group’s
permanent workforce.
The Group does not collect the required
information from all subsidiaries at this
stage and, for this reason, will disclose the
exact data in the next report by making
use of the phased-in application option.
S1-8 – Coverage by Collective Bargaining and Social Dialogue
S1-8_01
Excluding joint ventures (JVs)
Percentage of employees
covered by collective
bargaining agreements (%)
Thrace Plastics Co SA 0
Thrace Nonwovens & Geosynthetics SA 100
Thrace Polyfilms SA 100
Thrace Pack SA 100
Thrace Ipoma SA 0
Thrace Greiner Packaging SRL 100
Don & Low Ltd 71
Thrace Polybulk AS 0
Thrace Polybulk AB 0
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 137 of 370
In cases where the percentage is not
100%, employees are covered by indi-
vidual contracts.
S1-8_02-03
Percentage of employees covered by
collective labor agreements within and
outside the EEA (for each country with >
50 employees out of the total workforce,
representing > 10% of the total number of
employees).
Excluding joint ventures (JVs)
Percentage of employees
covered by collective
bargaining agreements (%)
Thrace Plastics Packaging DOO 0
JVs
Thrace Eurobent SA 100
Thrace Greenhouses SA 100
Lumite Inc 0
Thrace Synthetic Packaging Ltd 0
Percentage of employees covered by collective
bargaining agreements overall for the Group
80%
Coverage
Percentage
Employees – EEA (for coun-
tries with >50 employees
representing >10% of the
total employees)
Employees – Non-EEA
(estimated for areas with >50
employees representing >10%
of the total employees)
Workplace representation (only
for the EEA) (for countries with
>50 employees representing
>10% of the total employees)
0-19%
20-39%
40-59%
60-79%
Scotland (Don & Low
Ltd)
Thrace Nonwovens
& Geosynthetics
SA, Thrace Pack SA,
Thrace Greenhouses
SA (JV)
Thrace Nonwovens
& Geosynthetics SA,
Thrace Pack SA, Thrace
Greenhouses SA (JV)
80-100%
(In the cases of
companies in
this category,
the percentage
is 100%)
Thrace Nonwovens
& Geosynthetics
SA, Thrace Pack SA,
Thrace Greenhouses
SA (JV)
Thrace Nonwovens
& Geosynthetics SA,
Thrace Pack SA, Thrace
Greenhouses SA (JV)
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 138 of 370
S1-8.04-05
Business Collective Labor Agreements
Where applicable, business collective la-
bor agreements cover all employees of
the company, and their terms apply uni-
versally. For non-salaried employees, the
provisions of labor law and the minimum
legislated wages are applied.
The Business Collective Labor Agreement
applies only to seasonal and permanent
employees of the Group and does not cov-
er temporary staff.
There is no agreement between the Group
and its employees regarding representa-
tion through a European Works Council
(EWC), European Company Workers’ Coun-
cil (SE), or European Cooperative Society
Workers’ Council (SCE).
S1-8.06
Percentage (%) of employees covered by
employee representatives, referred to at
the country level in which the company
has significant employment.
Greece: 82%
Scotland: 100%
S1-9 Diversity Indicators
The scope regarding senior management
includes Senior Executive Staff and
specifically:
• Individuals who exercise senior
management (e.g., CEO, executive
board members, etc.).
• Directors and other executives
referred to above, according to the
Group’s organizational structure
(staff of IT, human resources, internal
audit, shareholder services, corporate
announcements, financial accounting
departments, etc.).
• CEOs / General Directors of the
Group’s subsidiaries.
Gender distribution as a percentage of employees at the senior management
level
Excluding joint ventures (JVs) JVs
Men 81% 69%
Women 19% 31%
Thrace
Plastics
Co SA
Thrace
Nonwovens &
Geosynthetics SA
Thrace
Polyfilms
SA
Thrace
Pack SA
Don &
Low Ltd
Thrace
Synthetic
Packaging Ltd
Thrace
Ipoma
SA
Thrace
Polybulk
AS
Thrace
Polybulk
AB
Thrace Plastics
Packaging
DOO
Gender distribution in
number of employees
(head count) at top man-
agement level
Male 13 8 2 4 6 2 5 4 0 1
Female 1 - - 1 1 - 5 - 0 -
Gender distribution in
percentage of employees
at top management level
Male 93 100 100 0.8 87. 5 100 50 100 0 100
Female 7 0 0 0.2 12.5 0 50 0 0 -
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 139 of 370
Thrace
Plastics
Co SA
Thrace
Nonwovens &
Geosynthetics SA
Thrace
Polyfilms
SA
Thrace
Pack SA
Don &
Low Ltd
Thrace
Synthetic
Packaging Ltd
Thrace
Ipoma
SA
Thrace
Polybulk
AS
Thrace
Polybulk
AB
Thrace Plastics
Packaging
DOO
Distribution of employees
(head count) under 30
years old
1 133 20 33 51 7 19 0 0 0
Distribution of employees
(head count) between 30
and 50 years old
15 383 75 258 141 31 75 3 2 9
Distribution of employees
(head count) over 50 years
old
9 156 28 61 153 15 56 8 2 0
Thrace
Eurobent
SA
Thrace
Greenhouses SA
Thrace
Greiner
Packaging
SRL
Lumite
Inc
Gender distribution in number of employees
(head count) at top management level
Male 1 14 3 4
Female 0 5 3 2
Gender distribution in percentage of employees
at top management level
Male 100 74 50 67
Female 0 26 50 33
Distribution of employees (head count) under 30 years
old
1 77 19 17
Distribution of employees (head count) between 30 and
50 years old
6 269 63 64
Distribution of employees (head count) over 50 years old 0 48 23 79
Distribution of employees by age group
Excluding JVs JVs
Distribution of employees (head count) under 30 years old 264 114
Distribution of employees (head count) between 30 and 50
years old
992 402
Distribution of employees (head count) over 50 years old 488 150
S1-10 – Adequate Compensation
• All employees receive adequate compensation according to the applicable
benchmarks.
• 0% of employees are paid below the corresponding benchmark for adequate
compensation.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 140 of 370
S1-11 – Social Protection
S1.11.01-11
All employees are insured through public
organizations for income loss due to ill-
ness, unemployment, accidents, tempo-
rary incapacity to work, maternity, and
retirement. In Greece, additional care is
provided to employees through a health-
care program that offers income coverage
in cases of incapacity to work.
S1-12 – People with Disabilities
The Group does not employ individuals
with disabilities.
S1-13 – Training and skills development metrics & S1-14 – Health and
safety metrics
Thrace
Plastics
Co SA
Thrace
Nonwovens &
Geosynthe-
tics SA
Thrace
Polyfilms
SA
Thrace
Eurobent
SA
Thrace Pack SA
Thrace
Green-
houses SA
Don &
Low
Ltd
Thrace
Synthetic
Packaging
Ltd
Thrace
Ipoma
SA
Thrace
Greiner
Packa-
ging SRL
Lumite
Inc
Thrace
Polybulk
AS
Thrace
Polybulk
AB
Thrace
Plastics
Packa-
ging DOO
S1-13
Average number of
training hours by
gender (Men)
27.00 38.20 66.00 16.00
14.58
27.95 0.00 0.00 11.65 296.00 1.12 160.70
426.00
25.00 25.00 0.00
Average number of
training hours by
gender (Women)
13.00 20.07 18.00 0.00 12.95 31.33 12.75 0.07 17.71 0.00 2.03 154.00
230.00
25.00 25.00 0.00
Average number of
training hours per
person for employees
0.00 33.66 47.00 16.00 14.21
28.68
7.28 0.00 5.20 5.58 1.38 183.00 4.50 25.00 25.00 0.00
S1-14
Number of fatalities
in own workforce as
result of work-related
injuries and work-
related ill health
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Number of fatalities
as result of work-
related injuries
and work-related
ill health of other
workers working on
undertaking's sites
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Number of record-
able work-related
accidents for own
workforce
0.00 108.00 15.00 0.00 7.00 0.00 5.00 0.00 1.00 0.00 1.00 0.00 0.00 0.00
Rate of record-
able work-related
accidents for own
workforce
0.00 28.52 40.79 0.00 10.46 0.00 5.00 0.00 3.92 0.00 0.62 0.00 0.00 0.00
Number of cases of
recordable work-
related ill health of
employees
0.00 14.40 0.00 0.00 0.00 0.00 5.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Number of work days
lost due to work-
related accidents
0.00 308.00
104.00
0.00 39.00 0.00
37.0 0
0.00
17.0 0
0.00 0.00 0.00 0.00 0.00
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 141 of 370
All employees of the Group who report di-
rectly to the CEO, including all Managing
Directors and Group Heads, participated in
regular performance and professional de-
velopment evaluations during the report-
ing period.
100% of the Group’s employees are cov-
ered by a Health and Safety system.
S1-16 – Compensation Indicators (Pay
Gap and Total Compensation)
The data were collected from all subsidiar-
ies and calculated based on the standard
and the required formula.
Thrace
Plastics Co
SA
Thrace
Nonwovens
& Geosyn-
thetics SA
Thrace
Polyfilms SA
Thrace
Pack SA
Don & Low
Ltd
Thrace
Synthetic
Packaging
Ltd
Thrace
Ipoma SA
Thrace
Polybulk
AS
Thrace
Polybulk
AB
Thrace
Plastics
Packaging
DOO
Ratio of the annual
total compensation
for the highest-paid
individual to the
median annual total
compensation for all
employees
10.84 6.72 4.69 7.75 5.75 5.53 - 156.00 171.00 3.00
Gender pay gap
(%)
9.71 -7.81 18.77 1.28 9.78 21.86 17. 58 35.10 24.90 -0.42
Thrace Euro-
bent SA
Thrace
Green-
houses SA
Thrace
Greiner
Packaging
SRL
Lumite
Inc
Ratio of the annual
total compensation
for the highest-paid
individual to the
median annual total
compensation for all
employees
3.10 - 5.07 2.00
Gender pay gap
(%)
100.00 8.00 3.76 5.9
S1-17 – Incidents, Complaints, and Serious Human Rights Violations
The Group has not faced any incidents, fines, or payments related to human rights viola-
tions concerning its own workforce.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 142 of 370
GOV-1_01
Disclosure of the role of administrative,
management, and supervisory bodies
in relation to business conduct
A firm commitment of the Group is to
conduct its business activities with integ-
rity, in accordance with the highest ethical
standards and by applying all applicable
laws. The Code of Ethics and Conduct de-
fines the standards of conduct required
from the employees of the Group’s com-
panies and applies in every country where
Thrace Group operates. Through the Code,
guidelines are established that govern the
proper conduct of the Group’s personnel.
The central theme of the Code of Ethics
and Conduct can be summarized as fol-
lows: All employees, as representatives of
the Group, must act with honesty, respect,
and integrity in all matters at all times. The
Group adopts and promotes ethical val-
ues across its operations and encourages
its employees to act with honesty, sincer-
ity, impartiality, and dedication, guided by
responsibility.
The Code of Ethics and Conduct reflects
the fundamental principles of operation of
the Company and the Group and sets out
the value and behavior framework that ap-
plies to relationships with employees, cus-
tomers, suppliers, and partners. Through
the implementation of the Code, the Com-
pany’s identity, business ethics, and cul-
ture are expressed, including:
• Respect for human rights
• Diversity and equal representation
• Compliance with laws and social
norms
• Product quality
• Promotion of fair and free competition
• Avoidance of conflicts of interest
• Accuracy and completeness of finan-
cial information provided
• Protection of corporate assets
• Cooperation with public authorities
lawfully and transparently
• Execution of all transactions with in-
tegrity and combating corruption
• Protection and confidentiality of
information
• Achieving good labor relations
• Protection of the environment, safety,
and health of employees
• Implementation of circular econ-
omy principles for climate change
protection
• Social contribution
The role of the administrative, manage-
ment, and supervisory bodies related to
business conduct is critical for ensuring the
application of the Code’s principles and re-
inforcing the business culture through it.
This role is defined in the Internal Rules of
Operation, the Rules of Operation of the
Board of Directors (BoD), the Audit Com-
mittee Rules of Operation (AC), and the
Remuneration & Nomination Committee
Rules of Operation (RNC). Specifically:
Under the Internal Rules of Operation, the
Company’s administrative, management,
and supervisory bodies are connected and
8.4 Governance Information
IRO-1 – Description of the processes to identify and assess material impacts, risks
and opportunities
Detailed description in the corresponding section under ‘General Information’.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 143 of 370
collaborate, covering the following:
• The Board of Directors approves and
oversees the implementation of the
Code of Ethics and Conduct, ensuring
that its principles are adhered to at all
levels of the company.
• The Audit Committee advises on the
approval and revision of the Compa-
ny’s Rules of Operations and Corpo-
rate Governance Code and monitors
the implementation of the Code of
Ethics and Conduct.
• The Chief Executive Officer applies
and manages compliance with the
Code.
• The Internal Audit Department moni-
tors the implementation of the Code
and ensures compliance procedures
are followed.
• The Regulatory Compliance and Risk
Management Department ensures
compliance with legislative and regu-
latory provisions that align with the
Code.
• The Human Resources Department
ensures that recruitment, evaluation,
and training policies align with the
Code.
• The Sustainability Committee ensures
that sustainability actions align with
the Code.
Additionally, in the Regulation of the Board
of Directors, the role of the administrative,
management, and supervisory bodies in
relation to business conduct is defined as
follows:
• Purpose: The BoD is the highest gov-
erning body of the company and is
entrusted with the responsibilities
provided by law, the company’s Ar-
ticles of Association, and its Rules of
Operation.
• Responsibilities: The BoD is respon-
sible for the representation, govern-
ance, and management of the compa-
ny’s affairs, achieving corporate goals,
and managing corporate assets.
• Corporate Governance and Internal
Control System: The BoD defines and
oversees the implementation of the
corporate governance system as per
provisions 1 to 24 of Law 4706/2020,
monitors and evaluates its implemen-
tation and effectiveness every three
(3) financial years, and takes appropri-
ate measures to address deficiencies.
Additionally, the BoD ensures the ad-
equate and effective operation of the
Company’s internal control system.
• General Meeting of Shareholders:
The BoD ensures the effective exercise
of shareholders’ rights and their infor-
mation regarding all matters related to
participation in the General Meeting.
• Chairman of the BoD: Leads the
BoD, sets the agenda, and ensures the
proper organization of the BoD’s work.
• Vice Chairman of the BoD: Assumes
responsibilities arising from the BoD’s
formation and committee decisions
and coordinates the Independent
Board Members on the above matters.
Also chairs the annual meeting of the
Non-Executive Members.
• Chief Executive Officer: Ensures the
implementation of the Group’s strat-
egy, proposes strategies, and ensures
the preparation of annual budgets.
• Executive Members: Responsible for
implementing the strategy set by the
BoD and monitoring the company’s
day-to-day operations.
• Non-Executive Members: Monitor
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 144 of 370
and review the company’s strategy
and its implementation, as well as the
achievement of its goals.
• Independent Non-Executive Mem-
bers: Meet independence criteria and
are free from conflicts of interest.
It is noted that members of the BoD are
obligated to act in good faith towards the
company, with integrity and honesty in
the company’s interest, and to safeguard
the confidentiality of non-public infor-
mation. They must remain fully and con-
tinuously informed about the Conflict of
Interest Management Framework imple-
mented by the company, avoid any posi-
tion or activity that creates a conflict of
interest, and perform annual evaluations
of their procedures, effectiveness, and the
fulfillment of their duties, as well as those
of the Committees.
Furthermore, based on its Rules of Opera-
tion, the Audit Committee is responsible
for the selection process and supervision
of external auditors, informing the BoD on
the outcome of the statutory audit, moni-
toring the financial reporting process, in-
ternal control systems, and risk manage-
ment systems, and overseeing internal
audit, compliance, and risk management
units. Specifically:
• It is informed about the financial re-
porting process, monitors and evalu-
ates this process, and informs the BoD
of its findings.
• It is responsible for the process of se-
lecting and dismissing external audi-
tors, monitors their independence
and the performance of the statutory
audit, and informs the BoD about the
audit results.
• It monitors, examines, and evaluates
the adequacy and effectiveness of the
internal control system, quality assur-
ance, and risk management.
• It reviews the management of major
risks and uncertainties of the compa-
ny, assesses the methods for identify-
ing and monitoring risks, and informs
the BoD of its findings.
• It advises on the approval and revision
of the Company’s Rules of Operations,
monitors the effectiveness of the com-
pliance system, and reviews the find-
ings of supervisory authorities and in-
ternal/external auditors.
Finally, based on its Regulation, the Remu-
neration & Nomination Committee plays a
critical role in ensuring effective corporate
governance and shaping business culture
by defining its responsibilities. The RNC is
responsible for setting and overseeing the
remuneration system for BoD members,
its Committees, and senior executives. Its
key responsibilities include:
• Pre-approval and recommendation to
the BoD of the terms of employment
contracts of Executive BoD members.
• Determining fixed and variable remu-
neration, taking into account econom-
ic conditions and market practices.
• Ensuring clearly defined strategic ob-
jectives for Executive BoD members
and evaluating their achievement for
determining variable remuneration.
• Reviewing the Remuneration Policy
and ensuring transparency in the an-
nual Remuneration Report.
• Adjusting variable remuneration in
case of erroneous or inaccurate finan-
cial data.
The RNC also has the responsibility for the
nomination process of new BoD members
and its Committees and for the succession
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 145 of 370
planning. Its main responsibilities include:
• Defining criteria for the election of
BoD members and its Committees,
taking into account suitability, experi-
ence, and balance of skills.
• Evaluating candidates and making
recommendations to the BoD.
• Conducting the annual evaluation
of the BoD’s and its Committees’ ef-
fectiveness and drafting the BoD Ad-
equacy Report.
• Proposing policies for the training and
development of BoD members and
senior executives.
• Ensuring the independence of In-
dependent Non-Executive BoD
Members.
GOV-1_02
Disclosure of the expertise of the admin-
istrative, management, and supervisory
bodies regarding business conduct issues
The adequacy of the administrative, man-
agement, and supervisory bodies con-
cerning their knowledge in business con-
duct matters is demonstrated by the fact
that they have been trained in the relevant
policies/regulations/codes (Internal Rules
of Operation, Board of Directors Rules of
Operation, Rules of Operation of the Ex-
ecutive Committee & Senior Management,
Code of Ethics & Conduct) based on what
is defined in the Board of Directors and
Senior Executives Training Policy. Their ad-
equacy is evaluated according to the Board
of Directors & Committees Evaluation
Policy and the Senior Executives Recruit-
ment & Evaluation Process. Additionally,
the criteria for selecting Board Members
ensure that the Board, collectively, can
understand and manage issues related to
the environment, social responsibility, and
governance (ESG) within the context of its
strategy.
As thoroughly described in the Corporate
Governance Statement, which is an inte-
gral part of the annual financial statement,
the company implements a Board of Di-
rectors and Committees Evaluation Policy.
This policy covers all members of the Board
of Directors as well as third parties partici-
pating in the Committees. The suitability
criteria are defined by Law 4706/2020 and
the Suitability Policy, which is available on
the Group’s website.
The periodic re-evaluation of the Board of
Directors and Committee members is con-
ducted annually, considering their overall
and individual performance. The individ-
ual evaluation of the Board members in-
cludes their performance and contribution
to the functioning of the Board. In cases
of low ratings or suggestions for improve-
ment, individual meetings are held to ad-
dress these issues.
Apart from what is mentioned in the Cor-
porate Governance Statement of Thrace
Group, the evaluation of Board Members
for the years 2021 & 2024 was carried out
by an external consultant, while in 2022 &
2023 it was done through the self-assess-
ment of the members. The evaluation of
Senior Executives is annual and is super-
vised by the Corporate Governance and
Sustainability Committee.
G1-1 Corporate Culture and Business
Conduct and Corporate Culture
Policies
G1.MDR-P_01-06
Policies applied to manage significant im-
pacts, risks, and opportunities related to
business conduct and corporate culture
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 146 of 370
The policies applied to manage significant
impacts, risks, and opportunities related
to business conduct and corporate culture
are: 1) the Code of Ethics & Conduct, 2) the
Reporting and Whistleblowing Policy, and
3) the Anti-Fraud Policy.
1. The key points of the Group’s Code
of Ethics & Conduct are:
(a) General Objectives
o Promotion of business ethics and
integrity.
o Respect for human rights and pro-
motion of diversity.
o Compliance with laws and social
rules.
o Ensuring product quality and cus-
tomer safety.
o Promoting fair and free competition.
o Avoidance of conflicts of inter-
est and transparency in financial
transactions.
o Protection of corporate assets and
confidential information.
o Strengthening labor relations and
the health and safety of employees.
o Protection of the environment and
promotion of the circular economy.
o Social contribution and support for
vulnerable social groups.
Key Impacts, Risks, and Opportunities:
o Ethical business conduct to
safeguard the interests of all
stakeholders.
o Zero tolerance for harassment and
discrimination.
o Compliance with national laws and
adoption of international standards
for product quality and safety.
o Promotion of transparency and in-
tegrity in transactions.
o Protection of data and confidential
Group information.
Monitoring Process:
o Adoption of codes, policies, and
procedures to increase accountabil-
ity and responsibility.
o Regular quality checks to ensure
compliance with specifications.
o Reporting and handling violations
of the Code through multiple com-
munication channels.
o Enforcement of disciplinary meas-
ures and sanctions in case of
violations.
(b) Scope of the Code of Ethics &
Conduct
Activities:
o The Code applies to all business
activities of the Group, including
production, distribution, and sale of
products.
o It also covers internal procedures
and relationships with employees,
customers, suppliers, and partners.
Value Chain:
o Upstream: Covers relationships
with raw material suppliers and pro-
curement processes.
o Downstream: Includes distribution
and sales processes of final prod-
ucts to customers.
Geographical Areas:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 147 of 370
o The Code is valid in all countries
where the Thrace Group operates,
ensuring compliance with local laws
and regulations.
Affected Stakeholder Groups
o Employees: All employees of the
Group must comply with the Code
and act with integrity and respect.
o Customers and Suppliers: The
Code sets the principles for fair and
transparent transactions with cus-
tomers and suppliers.
o Society and Environment: The
Group is committed to protect-
ing the environment and making
a social contribution, positively im-
pacting the communities where it
operates.
(c) Highest Level of Responsibility:
o Board of Directors: The Board of
Directors is the highest level in the
organization responsible for imple-
menting the Code. The Board ap-
proves and reviews the Code, en-
suring its principles and values are
applied in all Group activities.
o Audit Committee: The Audit Com-
mittee is responsible for handling
reports of Code violations and im-
posing sanctions, in accordance
with the Whistleblowing Policy. The
Audit Committee informs the Board
of Directors of significant incidents.
(d) The Thrace Group Code of Ethics &
Conduct refers to various international
standards and initiatives the Group is
committed to adhering to through its
implementation.
Product Quality: The Group complies
with various international quality and safe-
ty standards (BRC, ISO 22000, ISO 9001), en-
suring the quality and safety of products in
all stages of the production process.
Business Ethics and Transparency: The
Group is committed to promoting busi-
ness ethics, transparency, and integrity in
its transactions, following internationally
recognized practices and standards.
Environmental Protection: The Group
applies the principles of the circular econ-
omy and complies with environmental
legislation, contributing to the achieve-
ment of the Sustainable Development
Goals (SDGs).
Human Rights and Labor Relations: The
Group is committed to respecting human
rights and promoting diversity and equal
representation, following international
guidelines and standards.
(e) Stakeholders and Interests
Employees:
o Commitment to providing a safe
and healthy work environment,
promoting diversity and equal
representation.
o Encouragement of lifelong learning,
professional training, and employee
well-being.
Customers:
o Commitment to product quality
and safety, complying with interna-
tional standards and regulations.
o Offering innovative and compre-
hensive solutions tailored to cus-
tomer needs.
Suppliers and Partners:
o Promoting fair and free competition,
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 148 of 370
ensuring fair and transparent
transactions.
o Collaborating with suppliers who
respect human rights and adhere to
high ethical standards.
Society and Environment:
o Commitment to environmental pro-
tection and applying the principles
of the circular economy.
o Supporting social solidarity pro-
grams and empowering vulnerable
social groups.
Shareholders:
o Ensuring accuracy and complete-
ness of financial information.
o Promoting transparency and integ-
rity in financial transactions.
(f) Availability of the Policy to
Stakeholders
Employees:
o All employees of the Group receive
a copy of the Code upon hiring.
o Employees are required to attend
the training programs on the Code
of Ethics & Conduct, relevant under-
standing tests, etc.
o In case of questions, employees
can seek guidance from their di-
rect supervisor or the Regulatory
Compliance and Risk Management
Department.
Important Partners:
o Important external partners, such
as auditors, legal advisors, and key
suppliers, also receive a copy of the
Code.
Violation Reporting Process:
o The Group has multiple communi-
cation channels for receiving com-
plaints or reports of Code violations.
o Reports can be submitted via a hot-
line, email, online platform, or post-
al address.
o The Audit Committee is responsible
for handling reports and informing
the Board of Directors of significant
incidents.
Regarding the applied Whistleblowing
Procedure, further analysis is provided in
the next paragraph.
2) The key points of the Group’s Report-
ing Policy and Procedure are:
(a) General Objectives
• Reporting Framework: Definition of
the framework for reporting wrong-
ful and abusive behaviors in relation
to the Group’s internal policies and
procedures, as well as Greek and EU
legislation.
• Protection of Whistleblowers: Com-
pliance with the requirements of Na-
tional and European Legislation for
the Protection of Personal Data and
the Protection of Whistleblowers.
Material Impacts, Risks, and
Opportunities
• Reporting Abusive Behaviors: Pro-
viding ways to report wrongful and
abusive behaviors by employees, part-
ners, and third parties.
• Report Management: Definition of
the principles and methods for han-
dling reports, ensuring confidentiality,
due diligence, and integrity.
• Obligations and Responsibilities:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 149 of 370
Definition of the obligations and
responsibilities of the Responsible
Reporting and Monitoring Officer
(R.R.M.O.).
Monitoring Procedure
• Communication Channels: Provision
of multiple communication channels
for submitting complaints, such as
phone/hotline, online platform, and
email.
• Report Management: Confirmation
of the receipt of the report within sev-
en working days and presentation of
the complaints to the Chairperson of
the Audit Committee.
• Investigation of Reports: Evaluation
and investigation of reports by the Au-
dit Committee or external collabora-
tors, as required.
• Personal Data Protection: Ensuring
compliance with personal data pro-
tection laws and maintaining the con-
fidentiality of the process.
(b) Scope of the Reporting Policy and
Procedure
Activities:
• The policy applies to all business activ-
ities of the Group, including produc-
tion, distribution, and sale of products.
• Ιt also includes internal processes and
relationships with employees, custom-
ers, suppliers, and partners.
Value Chain:
• Upstream: Covers relationships with
suppliers of raw materials and pro-
curement processes.
• Downstream: Includes distribution
and sale processes of final products to
customers.
• Geographical Areas:
• The policy applies in all countries
where the Thrace Group operates, en-
suring compliance with local laws and
regulations.
Affected Stakeholder Groups
• Employees: All employees of the
Group must comply with the policy
and act with integrity and respect.
• Customers and Suppliers: The policy
defines principles for fair and transpar-
ent transactions with customers and
suppliers.
• Society and Environment: The
Group is committed to protecting the
environment and contributing to soci-
ety, positively impacting the commu-
nities where it operates.
(c) Highest Level of Responsibility
• Board of Directors: The Board of Di-
rectors is the highest level in the or-
ganization responsible for implement-
ing the policy.
• Audit Committee: The Audit Com-
mittee is responsible for managing
reports of policy violations and en-
forcing sanctions, in accordance with
the Whistleblowing Policy. The Audit
Committee informs the Board of Di-
rectors about significant incidents
and approves and reviews the policy,
ensuring that its principles and values
are applied in all Group activities.
(d) The Group’s Whistleblowing Policy
and Procedure refers to various inter-
national standards and initiatives it is
committed to adhering to through its
implementation.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 150 of 370
• The Group complies with the re-
quirements of National and Euro-
pean Legislation for the Protection of
Personal Data and the Protection of
Whistleblowers.
• It follows best practices for the protec-
tion of whistleblowers.
• The policy incorporates principles of
transparency and integrity, as pro-
moted by international initiatives and
standards for combating corruption
and fraud.
(e) Affected Stakeholders and Interests
Employees:
• Providing a safe and confidential way
to report violations, ensuring protec-
tion from retaliation.
• Encouraging employees to report
wrongful behaviors without fear of
retaliation.
Customers and Suppliers:
• Ensuring transparency and integrity
in transactions with customers and
suppliers.
• Promoting fair and transparent prac-
tices in business relationships.
Society and Environment:
• Commitment to environmental pro-
tection and social responsibility, en-
couraging the reporting of environ-
mental violations.
• Supporting social integrity and ac-
countability through the reporting of
violations affecting society.
Shareholders:
• Ensuring the accuracy and complete-
ness of financial information.
• Promoting transparency and integrity
in financial transactions.
(f) Availability of the Policy to
Stakeholders
Employees:
• All employees of the Group receive a
copy of the policy upon hiring.
• Employees are required to acknowl-
edge in writing that they have re-
ceived and understood the policy.
• In case of doubts, employees can seek
guidance from their direct supervisor
or the Compliance Department.
Key Partners:
• Key external partners, such as audi-
tors, legal advisors, and major suppli-
ers, also receive a copy of the policy.
• Partners are required to acknowledge
in writing that they have received and
understood the policy.
Violation Reporting Procedure:
• The Group provides multiple commu-
nication channels for receiving com-
plaints or reports of policy violations.
• Reports can be submitted through
a hotline, email, online platform, or
postal address.
• The Audit Committee is responsible
for managing the reports and inform-
ing the Board of Directors of signifi-
cant incidents.
3. The key points of the Group’s
Anti-Fraud Policy are:
a) General Objectives
• Prevention and Detection of Fraud:
Creation of a framework for the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 151 of 370
prevention, detection, and manage-
ment of fraud incidents.
• Protection of Resources: Ensuring
the protection of the Group’s finan-
cial and other resources from abusive
practices.
• Enhancement of Transparency: Pro-
moting transparency and integrity in
all business activities.
Material Impacts, Risks, and
Opportunities
• Fraud Risks: Identification and assess-
ment of fraud risks across all Group
operations.
• Opportunities for Improvement:
Strengthening internal controls and
procedures to prevent and detect
fraud.
• Material Impacts: Reduction of fi-
nancial losses and protection of the
Group’s reputation through effective
management of fraud incidents.
Monitoring Process
• Internal Audits: Regular audits and
assessments to detect and prevent
fraud incidents.
• Reporting of Incidents: Establishing
procedures for reporting and investi-
gating fraud incidents.
• Training and Awareness: Training
employees to recognize and report
suspicious incidents.
• Enforcement of Sanctions: Imposing
disciplinary measures and sanctions in
cases of confirmed fraud.
b) Scope of the Anti-Fraud Policy
Activities:
• The policy applies to all business
activities of the Group, including the
production, distribution, and sale of
products.
• It also covers internal processes and
relationships with employees, custom-
ers, suppliers, and partners.
Value Chain:
• Upstream: Covers relationships with
raw material suppliers and procure-
ment processes.
• Downstream: Includes distribution
and sales processes of finished prod-
ucts to customers.
Geographical Areas:
• The policy applies in all countries
where the Thrace Group operates, en-
suring compliance with local laws and
regulations.
Affected Stakeholder Groups:
• Employees: All employees of the
Group must comply with the policy
and act with integrity and respect.
• Customers and Suppliers: The policy
sets the principles for fair and trans-
parent transactions with customers
and suppliers.
• Society and Environment: The
Group is committed to environmen-
tal protection and social contribution,
positively impacting the communities
in which it operates.
c) The Thrace Group’s Anti-
Fraud Policy establishes
that the responsibility for its
implementation lies with the
senior management of the Group,
where the provisions mentioned in
the Group’s Reporting Policy and
Procedure for the Highest Level of
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 152 of 370
Responsibility apply. It also refers
to the following:
(d) International Standards and
Initiatives,
(e) Stakeholders and Interests,
(f) Availability of the Policy to
Stakeholders, which the Group is
committed to adhering to through
its implementation in line with
the Group’s Reporting Policy and
Procedure (see above).
By applying the above policies, the Group’s
companies achieve the management of
significant impacts, risks, and opportuni-
ties related to business behavior and cor-
porate culture.
G1-1_01
Description of how the company creates,
develops, promotes, and evaluates its
business mindset (culture).
Thrace Group establishes, develops, pro-
motes, and evaluates its corporate culture
through a combination of actions, such as
the following:
• The Board of Directors ensures that
the values (integrity, efficiency, inno-
vation, flexibility, responsiveness, col-
laboration, leadership) and the stra-
tegic planning of the Company align
with the corporate culture, as well as
ensuring that values and purpose are
translated and applied in practice, in-
fluencing the practices, policies, and
behaviors within the Company at all
levels. The Board of Directors and sen-
ior management set the standard for
the characteristics and behaviors that
shape the corporate culture and serve
as an example of its application.
• The parent company communicates
its policies on business conduct is-
sues and how it creates, develops,
promotes, and nurtures its business
mindset across all the Group compa-
nies, both through the Group’s Gen-
eral Policies Manual and the Code of
Ethical Conduct & Integrity.
• Based on the Internal Rules of Opera-
tion and the Code of Ethical Conduct
& Integrity, the primary goal is to cre-
ate a climate of trust among all stake-
holders of the Group, as they serve as
a reference point, contributing sig-
nificantly to protecting the interests of
employees, customers, shareholders,
and other parties, while also enhanc-
ing and strengthening the Group’s
credibility, reliability, and reputation.
Special importance is also given to
evaluating corporate culture through
the application and supervision of
the Compliance System, which effec-
tively contributes to monitoring and
controlling adherence to applicable
legislative and regulatory provisions,
as well as internal rules, including the
compliance principles described in the
Group’s Code of Ethical Conduct & In-
tegrity and established good business
practices aimed at ensuring the integ-
rity and reputation of the Group.
G1-1_02
Description of the mechanisms for iden-
tifying, reporting, and investigating con-
cerns related to illegal behavior or behav-
ior contrary to the code of ethics or similar
internal rules.
The mechanism for identifying, reporting,
and investigating reports of illegal behav-
ior or behavior that violates the Code of
Ethical Conduct & Integrity or the internal
rules of the Group includes the following:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 153 of 370
• Reporting Mechanism: There is a
dedicated mechanism for submitting
complaints, which allows employees
and third parties to anonymously or
personally report any illegal or im-
proper behavior. The whistleblowing
platform and the complaint hotline
were upgraded in 2024 to improve
functionality and user-friendliness.
Through both the platform and the
hotline, anyone can report behaviors
and incidents that are inconsistent
with the ethics and integrity of the
Group. The management of the plat-
form and the operation of the hotline
are handled by external partners, en-
suring complete anonymity for the
whistleblower.
• Investigation Process: All complaints
are examined by the Responsible Au-
thorities for Receiving and Monitoring
Reports, who are responsible for in-
vestigating the reports with the sup-
port of the Audit Committee, which is
the competent committee.
• Protection of the Whistleblower:
The policy ensures the protection of
whistleblowers from any form of re-
taliation or intimidation.
• Training and Awareness: The com-
pany provides training and awareness
to employees regarding the complaint
process and the importance of compli-
ance with the Code of Ethical Conduct
& Integrity.
G1-1_03
The Group implements an Anti-Fraud
Policy. The existing document extensively
addresses the parameters for combating
corruption or bribery, fully covering the
disclosure requirements of G1-1_10(b) and
is fully compliant with the United Nations
Convention against Corruption.
G1-1_05
Disclosure of safeguards for reporting
violations, including the protection of
whistleblowers
The mechanism for identifying, reporting,
and investigating reports/complaints re-
lated to illegal behavior or behavior con-
trary to the code of ethics or internal rules
of Thrace Group and its subsidiaries con-
sists of the company’s and its subsidiaries’
whistleblower policy and the dedicated
mechanism for submitting complaints,
platform, and hotline, which allows em-
ployees and third parties to anonymously
or personally report any illegal or improper
behavior and includes the following main
points:
• Establishment of Internal Report-
ing Channels: The company has
established internal reporting chan-
nels for submitting complaints. These
channels allow employees to report
anonymously or personally any illegal
or improper behavior.
• Employee Awareness and Training:
The company provides information
and training to employees regard-
ing the complaint reporting process.
This includes raising awareness of the
importance of compliance with the
code of ethics and internal rules of the
Group.
• Designation and Training of Report-
ing Personnel: There is designated
personnel (Responsible for Receiving
and Monitoring Reports) who are re-
sponsible for receiving and managing
the complaints under the supervision
of the Audit Committee. This person-
nel receives appropriate training to
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 154 of 370
ensure effective and confidential han-
dling of the reports.
It also includes the following measures to
protect employees who are whistleblow-
ers, in accordance with applicable legisla-
tion (Law 4990/2022), which transposes
the EU Directive 2019/1937 of the Europe-
an Parliament and Council:
• Protection from Retaliation: The
company ensures that employees
who submit complaints will not face
retaliation, such as dismissal, demo-
tion, intimidation, or any other form of
discrimination.
• Confidentiality: All complaints
are treated with strict confidential-
ity, protecting the identity of the
whistleblower.
• Support and Counseling: Sup-
port and counseling are provided to
whistleblowers to ensure they are
aware of their rights and the proce-
dures they need to follow.
• Personnel Training: Personnel re-
sponsible for receiving and managing
complaints receives specific training
to ensure effective and fair manage-
ment of reports.
• Legal Compliance: The compa-
ny’s policy fully complies with Law
4990/2022, which transposes Direc-
tive (EU) 2019/1937, which sets mini-
mum standards for the protection of
whistleblowers in the European Union.
• More specifically, the company is com-
mitted to following the provisions
of European Directive 1937/2019 and
Greek Law 4990/2022 for the protec-
tion of public interest whistleblowers.
In this context, the company has estab-
lished a procedure for monitoring the
reports received from whistleblowers.
Within 90 days of receiving a report,
the company informs the whistle-
blower about the actions that have
been taken or will be taken.
• Additionally, the company has estab-
lished clear procedures for investi-
gating incidents related to business
conduct. Reports are evaluated by
the Audit Committee, which decides
on further investigation and the ap-
propriate actions. The investigation
may be conducted internally or with
the assistance of external consultants,
depending on the nature and serious-
ness of the report.
• Finally, the company ensures the con-
fidentiality and protection of personal
data of all parties involved throughout
the process. Reports are systemati-
cally recorded and monitored, and the
results of the investigation are com-
municated to the relevant company
bodies for the necessary corrective
actions.
G1-1_08
Commitment to Investigating Business
Behavior Incidents in a Timely,
Independent, and Objective Manner
Thrace Group’s whistleblowing policy in-
cludes the following points, demonstrat-
ing the company’s commitment to the
prompt, independent, and objective in-
vestigation of business behavior incidents:
• Prompt Investigation: The company
is committed to investigating all com-
plaints as quickly as possible, ensuring
that each case is treated with the nec-
essary attention and urgency.
• Independence: Investigations are
carried out by the responsible Inter-
nal Audit Personnel (IAP), who report
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 155 of 370
to the Audit Committee, which is an
independent committee, or external
collaborators, ensuring impartiality
and objectivity in the process.
• Objectivity: The investigation process
is based on clear and objective criteria,
aiming for an accurate and fair assess-
ment of complaints.
• Confidentiality: The company en-
sures the confidentiality of informa-
tion related to complaints, protecting
the identity of the whistleblowers and
involved parties.
• Staff Training: Personnel responsible
for managing complaints receive ap-
propriate training to ensure effective
and fair handling of cases.
G1-1_10
Training Policy Information Regarding
Business Behavior
Training within the organization on busi-
ness behavior topics is achieved through
the training of employees across the
Group’s companies, a process governed
by the following policies, regulations, and
procedures:
1. GROUP POLICIES MANUAL
The Group’s policy manual includes the
development, training, and evaluation of
staff. Each employee is evaluated annu-
ally based on goals set at the start of the
year, aiming to detect strengths and weak-
nesses and to develop a training system
for their professional and personal growth.
2. Policy on Recruitment, Training,
and Evaluation of Senior
Management Personnel
This policy includes the following:
• Objective: Effective staffing to main-
tain competitive advantage.
• Principles: Merit-based criteria, equal
opportunities, respect for diversity,
and safeguarding personal data.
• Responsibilities and Duties: The
CEO and the Remuneration & Nomi-
nation Committee are responsible for
recognizing the need for hiring and
selecting the appropriate personnel.
• Process: Recognizing needs, search-
ing for and selecting candidates, inter-
view rounds, recommendations, and
final selection.
3. Training Policy for Board
Members, Senior Management,
and Other Personnel
This policy includes:
• Objective: Continuous education and
training to upgrade knowledge and
skills.
• Scope: Board members, senior man-
agement, and other personnel.
• Training Program: Design and im-
plementation of a continuous training
program with goals such as under-
standing the company’s structure and
culture, economic and regulatory de-
velopments, and improving skills.
• Training Methods: Classroom train-
ing, virtual training, on-the-job train-
ing, mentoring, and external training
providers.
4. Employee Training Process
This process includes:
• Goal: Continuous and systematic
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 156 of 370
improvement of employees’ knowl-
edge and skills.
• Scope: Employees of the company
and its subsidiaries.
• Identification and Assessment of
Training Needs: Gathering data from
each department, analyzing business
goals, needs for new technologies,
regulatory frameworks, and organiza-
tional changes.
• Selection of Training Methods
and Providers: Classroom training,
e-learning, on-the-job training, and
choosing appropriate vendors.
• Annual Training Programs: Organi-
zation and implementation of training
sessions, evaluation of training pro-
grams, and providers.
These policies and processes ensure that
training within the organization is system-
atic, fair, and oriented towards the devel-
opment of employees’ skills and profes-
sional performance.
G1-1_11
Disclosure of the Company’s Functions
Most at Risk of Corruption and Bribery
• During the evaluation of the Internal
Control System (ICS) conducted by
PwC in 2022, the external independ-
ent evaluator identified that the pro-
curement and sales sectors are the
most at risk for incidents of conflict of
interest, corruption, and bribery. This
finding is globally accepted, as these
sectors are often involved in processes
that can lead to such practices due to
the nature of their transactions.
• The company’s Regulatory Compli-
ance and Risk Management Depart-
ment has completed the conflict of
interest audits for the 2023 and 2024
periods, where any incidents of cor-
ruption and bribery are identified.
These audits specifically included the
procurement and sales sectors, rec-
ognizing the importance of ensuring
transparency and integrity in these
critical areas.
• Additionally, corruption and bribery is-
sues are reviewed directly or indirectly
in every audit project carried out by
the Internal Audit Department, ensur-
ing that the Group’s procedures and
practices comply with anti-corruption
policies.
• Finally, during the 2023 and 2024 pe-
riods, the Regulatory Compliance and
Risk Management Department has
received and assessed conflict of inter-
est declarations from all Group com-
panies, evaluating them to identify
any cases of corruption and ensuring
that all potential issues are properly
addressed.
The completion of these audits and the col-
lection of declarations regarding potential
conflicts of interest are significant steps
towards enhancing transparency and trust
within the Group, ensuring that all busi-
ness activities are conducted with the
highest level of ethics and professionalism.
G1-1_12
The company is subject to legal re-
quirements for the protection of
whistleblowers.
The parent company of the Thrace Group,
Thrace Plastics Holdings S.A., is based in
Greece and, therefore, is subject to Law
4990/2022. Chapter Z of the law (Articles
19-22) outlines all necessary actions for the
protection of individuals who file reports
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 157 of 370
or are witnesses of public interest viola-
tions. The title of the chapter is “Protection
of persons reporting violations of Union
law – Implementation of Directive (EU)
2019/1937 of the European Parliament.”
Specifically, the law provides for:
• Free legal assistance: Individuals re-
porting violations are entitled to free
legal advice and support.
• Psychological support: Free psycho-
logical support is provided to those
who file reports.
• Protection from retaliation: Measures
are in place to protect whistleblowers
from retaliation.
Directive (EU) 2019/1937 aims to ensure the
protection of individuals reporting viola-
tions of Union law, strengthening the trust
and safety of whistleblowers.
All whistleblowers are protected based on
the Whistleblowing Policy approved by
the Labor Inspection Authority, which has
been found to be fully compliant with Law
4990.
G1-2 Management of Supplier
Relationships
G1-2_01
Description of the policy for avoiding
payment delays, especially for small
and medium-sized enterprises.
The Purchasing, Accounts Payable, and
Cash Management Policies of the Thrace
Group clearly state that all companies with-
in the Group are required to pay suppliers
according to the agreed payment terms.
This policy is applied uniformly, without
differentiation between small and large
businesses. Specifically, the Group’s policy
is the same for all suppliers, regardless of
their size or the nature of their business.
More specifically, the payment terms (pay-
ment days, payment method) for the com-
panies of the Group and all their suppliers
must be specified, supported in writing,
registered in the ERP, and fully applied.
This means that the payment terms must
be clearly defined and include all neces-
sary details, such as the payment date and
the method of payment (e.g., bank trans-
fer, check, etc.).
Furthermore, all payments to suppliers
must be made on predetermined monthly
or weekly dates. This ensures that sup-
pliers know when they will receive their
payment and can plan their own financial
obligations accordingly. Adhering to these
predetermined payment dates is critical to
maintaining good relationships with sup-
pliers and avoiding delays that could affect
the smooth operation of the supply chain.
Finally, this policy enhances the transpar-
ency and reliability of the Group, as all sup-
pliers are treated in the same manner and
according to the same terms. This creates
an environment of trust and collaboration,
which is essential for the successful opera-
tion and growth of the Group.
G1-2_02
Information on the company’s ap-
proach to its relationships with its
suppliers, considering risks related
to the supply chain and sustainability
impacts.
G1-2_03
Disclosure on whether and how social and
environmental criteria are taken into
account for the selection (of contrac-
tual partners) suppliers.
Regarding the evaluation of suppliers,
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 158 of 370
considering the risks related to the sup-
ply chain and impacts on sustainability,
the Group’s Procurement Policy includes a
documented process for selecting suppli-
ers, taking into account objective criteria
such as cost, reliability, quality, payment
terms, ownership control, audit rights, and
potential synergies. Additionally, continu-
ous monitoring and evaluation of suppliers
is foreseen, especially for critical suppliers
(e.g., high turnover, sensitive relationships,
mid-term and long-term relationships).
This ensures that the risks related to the
supply chain and impacts on sustainability
are taken into account and appropriately
addressed.
Furthermore, social and environmental
criteria are considered when selecting
suppliers. According to the sustainability
framework, all companies of the Group
are required to send a “supplier evaluation
questionnaire” to their critical/important
suppliers, asking them to describe and
support key aspects of their culture and
operations, such as:
• Compliance with local legislation
• Insurance coverage for defective
materials/products
• Quality management systems or other
standards for ensuring their activities,
in general and concerning environ-
mental, health, and safety issues
• Anti-bribery and anti-corruption
policies
• Principles and/or ethical code of con-
duct regarding human rights and
against any form of discrimination
(gender, religion, race, beliefs, etc.) or
child labor
• Safeguarding a safe working
environment
• Environmental protection practices
and carbon emission reduction
All companies of the Group, during the
process of selecting a critical/important
supplier, incorporate these social and envi-
ronmental criteria and base their decisions
on documentation of these aspects.
G1-3 Prevention and Detection of
Corruption and Bribery
G1-3_01
Information on procedures for preventing
and detecting, investigating, and address-
ing claims or incidents of corruption and
bribery.
The Group has developed a comprehen-
sive framework for reporting, investigat-
ing, and managing complaints regarding
illegal behavior or violations of the Code of
Ethics & Conduct and internal regulations.
This system is based on the following key
policies:
1. Whistleblowing Policy & Com-
plaint Management Process
• It includes reporting channels (whistle-
blowing platform, helpline, email,
postal address).
• It ensures confidentiality and protec-
tion of whistleblowers.
• It outlines specific procedures for eval-
uating, investigating, and managing
complaints, under the responsibility of
the Audit Committee.
• It complies with the requirements of
Law 4990/2022 and the European Di-
rective 1937/2019 for the protection of
public interest whistleblowers.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 159 of 370
2. Anti-Fraud Policy
• It defines the Group’s commitment to
zero tolerance towards bribery and
corruption.
• It describes measures for preventing,
detecting, and addressing fraud, in-
cluding the roles and responsibilities
of employees.
• It mandates the obligation for employ-
ees and partners to report any suspi-
cion of improper conduct.
• It complies with the United Nations
Convention Against Corruption.
3. Prevention, Detection &
Management of Incidents
• Prevention: Through clear policies,
employee training, and systematic in-
ternal controls, corruption or bribery
incidents are prevented.
• Detection: The whistleblowing sys-
tem, combined with the internal audit
department, ensures early detection
of incidents.
• Management: The Audit Committee
evaluates each report, decides on the
investigation, and recommends disci-
plinary actions or legal measures, as
needed.
These procedures ensure a safe and reli-
able work environment, enhancing the
Group’s transparency and compliance
with international and national legal
requirements.
G1-3_02
Separation of Investigators or
Investigation Committee from the
Management Chain Involved in
the Prevention and Detection of
Corruption or Bribery
According to the provisions of the Whistle-
blowing Policy and the Antifraud Policy,
the process of investigating incidents of
corruption and bribery is distinct from the
mechanisms involved in their prevention
and detection. The Group’s Audit Commit-
tee acts as the supervisory body, ensuring
transparency and objectivity throughout
the investigation process, while the pri-
mary responsibility for the investigation
lies with the Internal Audit Department,
which examines each report regardless of
its source.
Corruption & Bribery Incident
Investigation Process
• Report Submission: Reports are
made through the communication
channels specified in the Whistleblow-
ing Policy (whistleblowing platform,
hotline, email, postal address).
• Report Evaluation: The report is ini-
tially recorded and assessed by the Re-
port Reception and Monitoring Officer
(R.R.M.O).
• Referral to the Audit Committee:
If necessary, the Audit Committee
is informed and decides on further
investigation.
• Investigation by the Internal Audit
Department:
o An independent and objective
investigation is conducted.
o Confidentiality and protection of
the whistleblower are ensured.
o Evidence is analyzed, and state-
ments are taken.
• Evaluation of Findings & Actions:
o The investigation’s findings
are submitted to the Audit
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Amounts in thousand Euro, unless stated otherwise
Page 160 of 370
Committee.
o If disciplinary or legal actions are
required, management is informed,
and appropriate measures are
taken.
Distinct Roles & Independence in the
Investigation
• The Audit Committee oversees the
procedures but does not participate
directly in the investigation, maintain-
ing its role as an independent supervi-
sory body.
• The Internal Audit Department con-
ducts investigations with independ-
ence and professionalism.
• Prevention and detection mechanisms
(such as internal controls, compliance
policies, and training) operate sepa-
rately from the investigation process,
ensuring transparency. By applying
them, the Group guarantees that the
investigation of corruption or bribery
incidents is conducted with objectiv-
ity, without involving the same indi-
viduals who manage compliance and
preventive measures daily. This en-
sures the reliability of the system and
the integrity of the investigations.
G1-3_03
Information on the Reporting Process
to the Administrative, Managerial, and
Supervisory Bodies
According to the Whistleblowing Policy
and the Antifraud Policy, the primary bod-
ies that receive updates on the results of
investigations and compliance matters are:
• The Board of Directors (BoD)
• The Audit Committee (AC)
These bodies are responsible for decision-
making and supervising the internal re-
porting and compliance processes.
Reporting Process of Results
The process of reporting results from Inter-
nal Audit and Risk & Compliance Manage-
ment to the relevant bodies is as follows:
• Quarterly Report to the Board of
Directors
o The Internal Audit Service submits
reports to the BoD on a quarterly
basis, including findings from inves-
tigation reports and internal audit
conclusions.
o In case of serious issues, reports
may be made on an ad-hoc basis.
• Supervision by the Audit Committee
o The Chairperson of the Audit Com-
mittee is also a member of the BoD,
ensuring direct communication
and connection between the two
bodies.
• Board of Directors Meetings
o Every BoD meeting includes a spe-
cific agenda item where the Audit
Committee informs the BoD about
compliance matters, corruption or
bribery incidents, and the findings
of investigations.
• Relationship between the Audit
Committee and Internal Audit &
Compliance Functions
o The Internal Audit and Risk & Com-
pliance Functions report regularly
to the Audit Committee.
o This ensures that control and risk
management procedures operate
correctly and independently of dai-
ly administrative management.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 161 of 370
The results reporting system is strictly
structured to ensure the integrity, inde-
pendence, and effectiveness of compli-
ance and internal audit processes. Through
regular and transparent communication
between Internal Audit, the Audit Com-
mittee, and the Board of Directors, the
Group ensures proper oversight of proce-
dures and effective handling of corruption
or bribery cases.
G1-3_04
Disclosure of a Plan to Adopt Proce-
dures for the Prevention, Detection,
and Addressing of Corruption and Brib-
ery Claims or Incidents, in the Absence
of Procedures
The Group has already developed and
implemented a comprehensive system
of policies and procedures for managing
complaints, combating fraud, and enhanc-
ing operational transparency. This system
is based on the following key policies:
• Whistleblowing Policy & Complaint
Management Process
• Antifraud Policy
These two policies complement each
other and form a complete and functional
framework for the prevention, detection,
and addressing of corruption or bribery
incidents.
Available Reporting & Investigation
Channels
• Upgraded Whistleblowing Platform
o Allows anonymous or named
reports.
o Provides enhanced security and
protection for whistleblowers.
• Whistleblower Hotline
o Improved functionality and ease of
use for employees, partners, and
third parties.
o Direct access for submitting reports.
• Complaint Management &
Investigation
o All reports are evaluated and inves-
tigated by the Audit Committee,
which supervises the process.
o The Internal Audit Department
conducts necessary investiga-
tions, ensuring objectivity and
confidentiality.
• Compliance with Legislative & Reg-
ulatory Frameworks
o The complaint management sys-
tem complies with Law 4990/2022
and European Directive 1937/2019
for the protection of public interest
whistleblowers.
o The Antifraud Policy adheres to in-
ternational ethics and transparency
standards, such as the UN Conven-
tion against Corruption.
The Group has established, upgraded,
and functional procedures for managing
corruption or bribery incidents. There is
no need to develop new procedures, as
the existing policies ensure the preven-
tion, detection, and addressing of relevant
complaints.
G1-3_05
Information on how policies are com-
municated to those for whom it is ap-
propriate (for the prevention and detec-
tion of corruption or bribery incidents)
Effective communication of anti-corrup-
tion and anti-bribery policies is a key ele-
ment of the Group’s compliance strategy.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 162 of 370
In this context, the relevant policies are
communicated to employees through
various channels, ensuring that every-
one is aware of the procedures and their
obligations.
Communication via the New
Whistleblowing Platform
In July 2024, with the activation of the new
whistleblowing platform, extensive com-
munication was carried out to the Group’s
staff. The communication included: • An-
nouncements via corporate email to all
employees, with information on how the
platform works and its purpose.
• Posts on the Group’s internal portal,
providing the link to the new whistle-
blowing platform.
Continuous Reminder and
Communication
To ensure the reinforcement of the com-
pliance culture, the communication was
repeated in September 2024, emphasizing
the following points: • Resending informa-
tional emails with a focus on anonymous
and confidential reporting processes.
• Creation of training material, which
included instructions for using the
platform and was communicated to
employees.
The systematic update and reminder of
anti-corruption and anti-bribery preven-
tion and detection policies ensures that
employees are aware of the reporting pro-
cedures and can recognize and prevent
potential risks.
G1-3_06 & 08
Information on the nature, scope, and
depth of training programs on combating
corruption and bribery provided to em-
ployees and members of the administra-
tive, managerial, and supervisory bodies
The Group implements comprehensive
training programs on anti-corruption and
anti-bribery, ensuring that employees
understand their related obligations and
comply with applicable policies, regula-
tions, and procedures.
Nature and Scope of Training
The training programs are mandatory for
all employees in the administrative de-
partments of the Group’s companies and
include: • General training for all employ-
ees on the basic principles of combating
corruption and bribery.
• Specialized training for specific de-
partments (sales & procurement) that
are more exposed to related risks.
• Training for Board members, Com-
mittees, and Senior Executives,
which includes strategies for manag-
ing corruption risks and compliance
mechanisms.
Depth and Content of Training
The training material is based on the
Group’s policies, regulations, and proce-
dures, ensuring that: • Employees under-
stand the consequences of corruption and
bribery.
• Real-life examples and case studies
are analyzed.
• Internal reporting channels and re-
porting procedures are presented.
• Practical exercises and assess-
ments are conducted to reinforce
understanding.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 163 of 370
Compliance with anti-corruption princi-
ples is a strategic priority for the Group,
ensuring continuous training and aware-
ness among employees.
The employees of the administrative de-
partments of the companies listed in the
following tables were trained in the areas
of Whistleblowing, Code of Business Con-
duct, and Anti-Fraud as part of the 2024
training program. Specifically, in coopera-
tion with the Human Resources Depart-
ment, the training material (presentation,
Q&A, glossary of key terms, and compre-
hension questionnaire) was updated and
uploaded to the training platform—Thrace
Academy. The employees who completed
their training by December 2024 per com-
pany are as follows:
Company
Number of employees
who completed the
training
Number of employees
who completed the
training
THRACE PLASTICS CO 15 15
THRACE NG 56 98
THRACE PLASTICS PACK 10 88
THRACE POLYFILMS 5 16
THRACE EUROBENT 1 1
In 2024, the training for employees of foreign subsidiaries was also completed through
webinars. The employees trained per company are as follows:
Company
Number of employees
who completed the
training
Number of employees
who completed the
training
DON & LOW 68 68
THRACE IPOMA 110 110
THRACE GREINER 105 108
THRACE POLYBULK 13 13
THRACE SYNTHETIC PACKAGING 12 12
THRACE PLASTICS PACKAGING 8 8
Note that the training material was the same for all companies in Greece and abroad
and was prepared by the Compliance Manager in both Greek and English, covering the
nature, scope, and depth of the required training programs.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 164 of 370
G1-3_07
Percentage of positions (functions)
at risk, covered by training programs
(education)
As part of a project conducted by PWC in
2022 for the assessment of the SEU, the
operational departments (functions) that
were assessed as being most exposed to
corruption or bribery risks are procure-
ment and sales, which is globally accepted.
The employees of the procurement and
sales departments who completed their
training by December 2024 per company
are as follows:
Company
Number of
employees
who
completed
the training
Total number
of employees
in the
procurement
and sales
departments
Percentage of
employees in the
procurement and
sales departments
who completed the
training (%)
THRACE NG 16 35 46%
THRACE PLASTICS PACK 10 35 29%
THRACE POLYFILMS 3 7 43%
For Thrace Plastics Co SA, Thrace Eu-
robent, and the foreign companies, as
presented in the table above, 100% of
the employees in the procurement and
sales departments have been trained.
G1-3_09
Disclosure of the analysis of training ac-
tivities, for example, by training area or
by category of employee
The Group has established, upgraded,
and functional policies and procedures
related to the training of all employees in
the Group companies on an annual basis.
Specifically, the Board Member Training
Policy, Executive Staff Recruitment, Train-
ing, and Evaluation Policy, and the Employ-
ee Training Procedure ensure that internal
training is systematic, fair, and focused on
developing the skills and professional per-
formance of employees. As stated in the
disclosure requirements G1_G1-3_21 a,b
& c, in 2024, the employees of the Group
companies were trained on the follow-
ing topics: 1) Code of Ethical Conduct &
Ethics, 2) Whistleblowing Policy and Pro-
cedure, and 3) Antifraud Policy, either via
the Group’s training platform – THRACE
ACADEMY or through webinars (for for-
eign subsidiaries).
G1-4
Confirmed incidents of corruption or
bribery
Action plans and resources for manag-
ing significant impacts, risks, and op-
portunities related to corruption and
bribery [see ESRS 2 - MDR-A]
The action plans and resources for manag-
ing material impacts, risks, and opportuni-
ties related to corruption and bribery for
2024 include the following:
1. Upgrade of the reporting platform
(whistleblowing) and the com-
plaints hotline: The goal is to improve
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 165 of 370
functionality and user-friendliness to
facilitate the reporting of corruption
and bribery incidents.
2. Activation of the Group’s training
platform (Thrace Academy): Train-
ing on corruption and bribery issues
is mandatory for all employees to raise
awareness and knowledge on these
critical issues.
3. Completion of training for foreign
subsidiaries: The companies within
the Group located abroad completed
their training on corruption and brib-
ery issues, ensuring that all employees
are informed and compliant with the
Group’s policies.
4. Completion of internal audits by
the Group’s internal audit depart-
ment: Corruption and bribery issues
are examined directly or indirectly in
each audit, ensuring that the Group’s
processes and practices align with an-
ti-corruption policies.
These measures aim to create a transpar-
ent and trustworthy working environment
where corruption and bribery have no
place.
G1-4_01-02
The number of convictions for viola-
tions of laws related to the fight against
corruption and bribery
The amount of fines for violations of
laws related to the fight against corrup-
tion and bribery
Prevention and detection of corruption
and bribery - training table for combat-
ing corruption and bribery
• Number of convictions for violation
of anti-corruption and anti-bribery
laws: There have been no convictions
for violations of anti-corruption and
anti-bribery laws. The Group imple-
ments best practices for detecting po-
tential cases of corruption and bribery.
• Amount of fines for violation of anti-
corruption and anti-bribery laws:
There are no fines for violations of
anti-corruption and anti-bribery laws.
G1-4_04-08
• Number of confirmed incidents in
which employees were dismissed or
punished for corruption or bribery
incidents: There are no confirmed in-
cidents of corruption or bribery. There-
fore, there is no information regarding
incidents where employees were dis-
missed or penalized for corruption or
bribery incidents.
• Number of confirmed incidents
related to contracts with business
partners that were terminated or
not renewed due to violations re-
lated to corruption or bribery: There
are no confirmed incidents related to
contracts with business partners that
were terminated or not renewed due
to violations related to corruption or
bribery.
• Information regarding public le-
gal cases for corruption or bribery
brought against the business and
its employees, as well as the out-
comes of these cases: There are no
confirmed incidents of public legal
cases related to corruption or bribery
brought against the companies or em-
ployees of the Group.
For the prevention and detection of cor-
ruption and bribery cases, the Group takes
the following measures:
1. The Group’s internal audit department
regularly examines the presence of
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 166 of 370
corruption issues.
2. The Compliance Manager, based on
the requirements of Law 4706, con-
ducts audits on issues such as conflicts
of interest and the internal control
system.
Corruption and bribery violations are
reported to the Board of Directors and
the Audit Committee.
G1-6
Payment Practices
G1-6_01-03
Payment terms of companies in num-
ber of days per major category of sup-
pliers, particularly towards small and
medium-sized enterprises
• The Procurement, Accounts Payable,
and Cash Management policies of
Thrace Group clearly define that all
Group companies are required to pay
their suppliers according to the ap-
plicable payment terms. This policy
is applied uniformly, without differ-
entiation between small and large
businesses, as Thrace Group’s policy
is the same for all suppliers, regard-
less of their size or the nature of their
business.
• In implementation of these policies,
the payment terms (payment days,
method of payment) for the Group
companies and all their suppliers are
specific, supported in writing, record-
ed in the ERP, and fully implemented.
• Furthermore, all payments to sup-
pliers are made on predetermined
monthly or weekly dates, ensuring
that suppliers know when they will re-
ceive their payment and can schedule
their financial obligations accordingly.
Adherence to these predetermined
payment dates maintains good rela-
tionships with suppliers, avoiding de-
lays that could affect the smooth op-
eration of the supply chain.
• The implementation of these policies
enhances the transparency and reli-
ability of Thrace Group, as all suppliers
are treated the same and according to
the same terms. This creates an envi-
ronment of trust and collaboration,
which is essential for the successful
operation and growth of the Group.
• The Group follows the internal proce-
dures of each subsidiary without a uni-
fied determination for all companies
at the Group level. The average will
be accurately calculated at the Group
level in the next report.
G1-6_05
Payment terms of companies in num-
ber of days per major category of sup-
pliers, particularly towards small and
medium-sized enterprises
Transparency in Payment Practices
The payment terms (payment days, meth-
od of payment) of the Group companies
and all their suppliers are:
• Specific
• Supported in writing
• Recorded in the ERP
• Fully implemented
G1-6_02
All payments to suppliers are made on pre-
determined monthly or weekly dates. This
ensures that suppliers know when they
will receive their payment and can plan
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 167 of 370
their financial obligations accordingly.
Adherence to these predetermined pay-
ment dates is crucial for maintaining good
relationships with suppliers and avoid-
ing delays that could impact the smooth
operation of the supply chain. Detailed
information will be published in the next
report.
G1-6_03
The Group is unable to publish the per-
centage of payments that are aligned with
the specified terms for each subsidiary
company and supplier group, as this is not
calculated as required by the standard. The
Group will publish more detailed informa-
tion regarding the percentages of aligned
payments in the next report.
G1-6_04
There are no pending legal cases related to
delayed payments.
Appendix
List of datapoints in cross-cutting and topical standards that
derive from other EU legislation
Disclosure Requirement
and related datapoint
SFDR reference Pillar 3 reference
Benchmark Regulation
reference
EU
Climate
Law
reference
Pages
ESRS 2 GOV-1
Board's gender diversity
paragraph 21 (d)
Indicator number 13
of Table #1 of Annex 1
Commission
Delegated Regulation
(EU) 2020/1816,
Annex II
52
ESRS 2 GOV-1
Percentage of board
members who are
independent paragraph
21 (e)
Delegated Regulation
(EU) 2020/1816,
Annex II
52
ESRS 2 GOV-4
Statement on due
diligence paragraph 30
Indicator number 10
Table #3 of Annex 1
57
ESRS 2 SBM-
1 Involvement in activities
related to fossil fuel
activities paragraph 40
(d) i
Indicators number 4
Table #1 of Annex 1
Article 449a Regulation
(EU) No 575/2013;
Commission Imple-
menting Regulation
(EU) 2022/2453 (28)Table
1: Qualitative information
on Environmental risk
and Table 2: Qualitative
information on Social risk
Delegated Regulation
(EU) 2020/1816,
Annex II
-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 168 of 370
Disclosure Requirement
and related datapoint
SFDR reference Pillar 3 reference
Benchmark Regulation
reference
EU
Climate
Law
reference
Pages
ESRS 2 SBM-1
Involvement in activities
related to chemical
production paragraph
40 (d) ii
Indicator number 9
Table #2 of Annex 1
Delegated Regulation
(EU) 2020/1816,
Annex II
-
ESRS 2 SBM-1
Involvement in activities
related to controversial
weapons paragraph 40
(d) iii
Indicator number 14
Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1818 (29),
Article 12(1)
Delegated Regulation
(EU) 2020/1816,
Annex II
-
ESRS 2 SBM-1
Involvement in activities
related to cultivation and
production of tobacco
paragraph 40 (d) iv
Delegated Regulation
(EU) 2020/1818,
Article 12(1) Del-
egated Regulation
(EU) 2020/1816,
Annex II
-
ESRS E1-1
Transition plan to reach
climate neutrality by 2050
paragraph 14
Regulation
(EU)
2021/1119,
Article 2(1)
99
ESRS E1-1
Undertakings excluded
from Paris-aligned
Benchmarks paragraph
16 (g)
Article 449a
Regulation (EU)
No 575/2013;
Commission Implement-
ing Regulation
(EU) 2022/2453 Template
1: Banking book-Climate
Change transition
risk: Credit quality of
exposures by sector,
emissions and residual
maturity
Delegated Regulation
(EU) 2020/1818,
Article12.1 (d) to (g),
and Arti-cle 12.2
-
ESRS E1-4
GHG emission reduction
targets paragraph 34
Indicator number 4
Table #2 of Annex 1
Article 449a
Regulation (EU)
No 575/2013; Commission
Implementing
Regulation
(EU) 2022/2453
Tem-plate 3: Banking
book – Climate change
transition risk: align-
ment metrics
Delegated Regulation
(EU) 2020/1818,
Article 6
105
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 169 of 370
Disclosure Requirement
and related datapoint
SFDR reference Pillar 3 reference
Benchmark Regulation
reference
EU
Climate
Law
reference
Pages
ESRS E1-5
Energy consumption
from fossil sources
disaggregated by sources
(only high climate impact
sectors) paragraph 38
Indicator number 5
Table #1 and Indi-
cator n. 5 Table #2 of
Annex 1
105
ESRS E1-5
Energy consumption
from fossil sources
disaggregated by sources
(only high climate impact
sectors) paragraph 38
Indicator number 5
Table #1 and Indicator
n. 5 Table #2 of
Annex 1
105
ESRS E1-5
Energy consumption and
mix paragraph 37
Indicator number 5
Table #1 of Annex 1
105
ESRS E1-5
Energy intensity
associated with activities
in high climate impact
sectors paragraphs 40
to 43
Indicator number 6
Table #1 of Annex 1
106
ESRS E1-6
Gross Scope 1, 2, 3 and
Total GHG emissions
paragraph 44
Indicators number
1 and 2 Table #1 of
Annex 1
Article 449a; Regulation
(EU) No 575/2013;
Com-mission Implement-
ing Regulation
(EU) 2022/2453
Template 1: Banking
book – Climate change
transition risk: Credit
quality of exposures by
sector, emissions and
residual maturity
Delegated Regulation
(EU) 2020/1818,
Article 5(1), 6 and 8(1)
109
ESRS E1-6
Gross GHG emissions
intensity paragraphs 53
to 55
Indicators number 3
Table #1 of Annex 1
Article 449a Regula-
tion (EU) No 575/2013;
Com-mission Implement-
ing Regulation
(EU) 2022/2453
Tem-plate 3: Banking
book – Climate change
transition risk: align-
ment metrics
Delegated Regulation
(EU) 2020/1818,
Article 8(1)
109
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 170 of 370
Disclosure Requirement
and related datapoint
SFDR reference Pillar 3 reference
Benchmark Regulation
reference
EU
Climate
Law
reference
Pages
ESRS E1-7 GHG
removals and carbon
credits paragraph 56
Regulation
(E
U) 2021/
1119,
Article 2(1)
-
ESRS E1-9
Exposure of the
benchmark portfolio to
climate-related physical
risks paragraph 66
Delegated Regulation
(EU) 2020/1818,
Annex II Delegat-
ed Regulation
(EU) 2020/1816,
Annex II
2024:
Phase-in
provision
ESRS E1-9
Disaggregation of
monetary amounts by
acute and chronic physical
risk paragraph 66 (a)
ESRS E1-9
Location of significant
assets at material physical
risk paragraph 66 (c).
Article 449a Regula-
tion (EU) No 575/2013;
Commission
Implementing
Regulation
(EU) 2022/2453
paragraphs 46 and 47;
Template 5: Banking
book - Climate change
physical risk: Exposures
subject to physical risk.
2024:
Phase-in
provision
ESRS E1-9
Breakdown of the
carrying value of its
real estate assets by
energy-efficiency classes
paragraph 67 (c).
Article 449a Regula-tion
(EU) No 575/2013; Com-
mission Implementing
Regulation
(EU) 2022/2453
paragraph 34; Template
2:Banking book -Climate
change transition risk:
Loans collateralised by
immovable property -
Energy efficiency of the
col-lateral
2024:
Phase-in
provision
ESRS E1-9
Degree of exposure of
the portfolio to climate-
related opportunities
paragraph 69
Delegated Regulation
(EU) 2020/1818,
Annex II
2024:
Phase-in
provision
ESRS E2-4
Amount of each pollutant
listed in Annex II of
the E-PRTR Regulation
(European Pollutant
Release and Transfer
Register) emitted to air,
water and soil, paragraph
28
Indicator number 8
Table #1 of Annex 1
Indicator number 2
Ta-ble #2 of Annex 1
Indicator number 1
Table #2 of Annex 1
Indicator number 3
Ta-ble #2 of Annex 1
-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 171 of 370
Disclosure Requirement
and related datapoint
SFDR reference Pillar 3 reference
Benchmark Regulation
reference
EU
Climate
Law
reference
Pages
ESRS E3-1
Water and marine
resources paragraph 9
Indicator number 7
Table #2 of Annex 1
-
ESRS E3-1
Dedi-cated policy
paragraph 13
Indicator number 8
Table 2 of Annex 1
-
ESRS E3-1
Sustainable oceans and
seas paragraph 14
Indicator number 12
Table #2 of Annex 1
-
ESRS E3-4
Total water recycled and
reused paragraph 28 (c)
Indicator number 6.2
Table #2 of Annex 1
-
ESRS E3-4
Total water consumption
in m3 per net revenue on
own operations paragraph
29
Indicator number 6.1
Table #2 of Annex 1
-
ESRS 2- IRO 1 - E4
paragraph 16 (a) i
Indicator number 7
Table #1 of Annex 1
-
ESRS 2- IRO 1 - E4
paragraph 16 (b)
Indicator number 10
Table #2 of Annex 1
-
ESRS 2- IRO 1 - E4
paragraph 16 (c)
Indicator number 14
Table #2 of Annex 1
-
ESRS E4-2
Sustainable land /
agriculture practices or
policies paragraph 24 (b)
Indicator number 11
Table #2 of Annex 1
-
ESRS E4-2
Sustainable oceans /
seas practices or policies
paragraph 24 (c)
Indicator number 12
Table #2 of Annex 1
-
ESRS E4-2
Policies to address
deforestation paragraph
24 (d)
Indicator number 15
Table #2 of Annex 1
-
ESRS E5-5
Non-recycled waste
paragraph 37 (d)
Indicator number 13
Table #2 of Annex 1
124
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 172 of 370
Disclosure Requirement
and related datapoint
SFDR reference Pillar 3 reference
Benchmark Regulation
reference
EU
Climate
Law
reference
Pages
ESRS E5-5
Hazardous waste and
radioactive waste
paragraph 39
Indicator number 9
Table #1 of Annex 1
124
ESRS 2- SBM3 - S1
Risk of incidents of forced
labour paragraph 14 (f)
Indicator number 13
Table #3 of Annex I
-
ESRS 2- SBM3 - S1
Risk of incidents of child
labour paragraph 14 (g)
Indicator number 12
Table #3 of Annex I
-
ESRS S1-1
Human rights policy
commitments paragraph
20
Indicator number 9
Table #3 and Indicator
number 11 Table #1 of
Annex I
126
ESRS S1-1
Due diligence policies on
issues addressed by the
fundamental International
Labor Organisation
Conventions 1 to 8,
paragraph 21
Delegated Regulation
(EU) 2020/1816,
Annex II
126
ESRS S1-1
processes and measures
for preventing trafficking
in human beings
paragraph 22
Indicator number 11
Table #3 of Annex I
126
ESRS S1-1
workplace accident
prevention policy or
management system
paragraph 23
Indicator number 1
Table #3 of Annex I
126
ESRS S1-3
grievance/complaints
handling mechanisms
paragraph 32 (c)
Indicator number 5
Table #3 of Annex I
128
ESRS S1-14
Number of fatalities
and number and rate of
work-related accidents
paragraph 88 (b) and (c)
Indicator number 3
Table #3 of Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II
140
ESRS S1-14
Number of days lost
to injuries, accidents,
fatalities or illness
paragraph 88 (e)
Indicator number 3
Table #3 of Annex I
140
ESRS S1-16
Unadjusted gender pay
gap paragraph 97 (a)
Indicator number 12
Table #1 of Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II
141
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 173 of 370
Disclosure Requirement
and related datapoint
SFDR reference Pillar 3 reference
Benchmark Regulation
reference
EU
Climate
Law
reference
Pages
ESRS S1-16
Excessive CEO pay ratio
paragraph 97 (b)
Indicator number 8
Table #3 of Annex I
-
ESRS S1-17
Incidents of discrimination
paragraph 103 (a)
Indicator number 7
Table #3 of Annex I
141
ESRS S1-17
Non-respect of UNGPs
on Business and Human
Rights and OECD
paragraph 104 (a)
Indicator number 10
Table #1 and Indicator
n. 14 Table #3 of
Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II Delegat-
ed Regulation
(EU) 2020/1818 Art
12 (1)
-
ESRS 2- SBM3 – S2
Significant risk of child
labour or forced labour
in the value chain para-
graph 11 (b)
Indica-tors number 12
and n. 13 Table #3 of
Annex I
-
ESRS S2-1
Human rights policy
commitments paragraph
17
Indicator number 9
Table #3 and Indicator
n. 11 Table #1 of
Annex 1
-
ESRS S2-1
Policies related to value
chain workers paragraph
18
Indicator number 11
and n. 4 Table #3 of
Annex 1
-
ESRS S2-1
Non-respect of UNGPs
on Business and Human
Rights principles and OECD
guidelines paragraph 19
Indicator number 10
Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1816,
Annex II Delegat-
ed Regulation
(EU) 2020/1818, Art
12 (1)
-
ESRS S2-1
Due diligence policies on
issues addressed by the
fundamental International
Labor Organisation
Conventions 1 to 8,
paragraph 19
Delegated Regulation
(EU) 2020/1816,
Annex II
-
ESRS S2-4
Human rights issues and
incidents connected
to its upstream and
downstream value chain
paragraph 36
Indicator number 14
Table #3 of Annex 1
-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 174 of 370
Disclosure Requirement
and related datapoint
SFDR reference Pillar 3 reference
Benchmark Regulation
reference
EU
Climate
Law
reference
Pages
ESRS S3-1
Human rights policy
commitments paragraph
16
Indicator number 9
Table #3 of Annex 1
and Indicator number
11 Table #1 of Annex 1
-
ESRS S3-1
non-respect of UNGPs
on Business and Human
Rights, ILO principles
or and OECD guidelines
paragraph 17
Indicator number 10
Table #1 Annex 1
Delegated Regulation
(EU) 2020/1816,
Annex II Delegat-
ed Regulation
(EU) 2020/1818, Art
12 (1)
-
ESRS S3-4
Human rights issues and
incidents paragraph 36
Indicator number 14
Table #3 of Annex 1
-
ESRS S4-1
Policies related to
consumers and end-users
paragraph 16
Indicator number
9 Tab-le #3 and
Indicator number 11
Table #1 of Annex 1
-
ESRS S4-1
Non-respect of UNGPs
on Business and Human
Rights and OECD
guidelines paragraph 17
Indicator number 10
Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1816,
Annex II Delegat-
ed Regulation
(EU) 2020/1818, Art
12 (1)
-
ESRS S4-4
Human rights issues and
incidents paragraph 35
Indicator number 14
Table #3 of Annex 1
-
ESRS G1-1
United Nations Convention
against Corruption
paragraph 10 (b)
Indicator number 15
Table #3 of Annex 1
145
ESRS G1-1
Protection of
whistleblowers paragraph
10 (d)
Indicator number 6
Table #3 of Annex 1
146
ESRS G1-4
Fines for violation of
anticorruption and anti-
bribery laws paragraph
24 (a)
Indicator number 17
Table #3 of Annex 1
Delegated
Regulation
(EU)
2020/1816,
Annex II)
164
ESRS G1-4
Standards of anti-
corruption and anti-
bribery paragraph 24 (b)
Indicator number 16
Table #3 of Annex 1
164
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 175 of 370
Announcement of the exact payable amount of the interim
dividend for the fiscal year 2024
The Board of Directors of the Company,
during its meeting of November 14, 2024
approved the distribution (payment) of
interim dividend for fiscal year 2024 to
the shareholders of the Company, of a to-
tal amount of 3,000,000.00 Euros (gross
amount), corresponding to 0.0685848289
Euros per share (gross amount), which with
the increase corresponding to the 863,796
treasury shares, which are held by the
Company and in accordance with the law
are excluded from the interim dividend
distribution, will amount to 0.0699665112
Euros per share.
The above amount of the interim dividend
is subject to 5% withholding tax, in accord-
ance with articles 40 par. 1 and 64 par. 1
of Law 4172/2013 (Government Gazette A΄
167/23.07.2013), as in force after its amend-
ment by Law 4646/2019 (Government Ga-
zette A΄ 201/12.12.2019).
Therefore:
• The final payable amount of the inter-
im dividend for the fiscal year 2024 is
0.0664681856 Euro (net) per share.
• Ex-Dividend (cut-off) date for the in-
terim dividend of Year 2024, as it has
been already announced: Thursday,
January 23rd, 2025.
• Beneficiaries of the interim dividend
for fiscal year 2024 are the sharehold-
ers registered in the Company’s re-
cords in the Dematerialized Securities
System on Friday, January 24th, 2025
(Record date).
• The payment (distribution) of the in-
terim dividend will commence on
Wednesday, January 29th 2025, and
will be paid through the paying Bank
“PIRAEUS BANK S.A.” as follows:
1. Through the Participants in the Dema-
terialized Securities System (DSS) i.e.
Banks and Brokerage/Securities Com-
panies, according to the provisions of
the DSS Operation Regulation of the
Hellenic Central Securities Depository
(ATHEXCSD) and the relevant deci-
sions of ATHEXCSD.
2. Especially in cases of payment of the
interim dividend to the legal heirs
of deceased entitled shareholders,
SECTION 9: Prospects and Outlook of the Group for the Financial Year 2025
It is included in Section 1: «Significant events that took place during the financial year 2024»
of this Annual Report by the Bord of Directors, subparagraph II. «Prospects of the Group».
SECTION 10: Significant Events after the Reporting Period
Below are the significant events that took place after the end of the financial year 2024
and up to the date of issuance of this Report:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 176 of 370
whose securities are kept in the Spe-
cial Account of their S.A.T. ID in the
DSS under ATHEXCSD custody, the dis-
bursement process will be facilitated,
following completion of the inherit-
ance procedural steps, through any
branch of “PIRAEUS BANK” network.
Shareholders were reminded that the right
for the collection of the interim dividend
amount expires after a five year period
(article 250 of the Civil Code, section 15),
from the end of the fiscal year in which this
right was created (i.e. for the said interim
dividend of fiscal year 2024 the right for its
collection expires on 31.12.2030) and fol-
lowing such time period the uncollected
amounts will be irrevocably transferred to
the Hellenic State in accordance with arti-
cle 1 of legislative decree 1195/1942.
Replacement of the Officer of Investors Relation and Corporate An-
nouncements Department
The Board of Directors of the Company
decided, pursuant to relevant resolution
on the appointment of Mr. Dimitrios Frag-
kou son of Vasileios (CFO of the Company),
temporarily, as the Officer of Investors Re-
lation and Corporate Announcements De-
partment of the Company, in replacement
of the previous Head of Department, Evan-
gelia Sideri, daughter of Georgios.
Mr. Dimitrios Fragkou undertook his duties
on February 14th, 2025.
Election of new members of the Board of Directors and Reconstitution
of the Board of Directors into a body.
The Board of Directors of the Company,
during its meeting of February 28th, 2025,
and following the relevant proposal made
by the Company’s respective Remunera-
tion & Nominations Committee, in accord-
ance with the provisions of article 82 par. 1
of Law 4548/2018, articles 5 and 9 par. 4 of
Law 4706/2020, article 8 of the Company’s
Articles of Association, and in accordance
with the currently effective Policy of Suit-
ability and the best corporate governance
practices applied by the Company, unani-
mously and by acclamation elected:
(a) Ms. Fotini-Marina Niforos daughter of
George and Ms. Eleni Providi daughter
of Dimitrios, as new temporarily inde-
pendent non-executive members of
the Board of Directors, replacing the
resigned and departed (due to the ex-
piration of the term limit as per article
9 par. 4 (c) of Law 4706/2020) inde-
pendent non-executive members of
the Board, Messrs. Nikitas Glykas and
Spyridoula Maltezou.
(b) Mr. Stylianos Vitogiannis son of Kon-
stantinos, as a non-executive member
of the Board of Directors, replaced the
deceased member, Christos-Alexis
Komninos.
The aforementioned members fully meet
the criteria of individual and collective suit-
ability according to the provisions of arti-
cle 3 of Law 4706/2020, as in force, and the
approved and effective Policy of Suitabil-
ity of the Company and there is no conflict
of interest or incompatibility in relation to
their position under the applicable corpo-
rate governance legal framework, includ-
ing the Company’s Corporate Governance
Code and its Regulation of Operation.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 177 of 370
Additionally, it is noted that the newly
elected two (2) temporarily independent
non-executive members of the Board of
Directors fully meet, as confirmed by the
Board’s above decision, the conditions
and criteria of article 9 par. 1 and 2 of Law
4706/2020, specifically:
(i) they do not directly or indirectly hold
more than 0.5% of the share capital
and voting rights of the Company and
(ii) they are free from any dependency
relationships with the Company or any
related parties, as defined in par. 2 of
article 9 of Law 4706/2020, and do not
have any financial, business, family or
other relationships that could affect
their decisions or independent, objec-
tive, and impartial judgment.
It is also emphasized that in compliance
with the requirements of article 18 par. 1
of Law 4706/2020, the detailed curriculum
vitae of the new members of the Board of
Directors are posted on the Company’s
website at thracegroup.com/gr/en/board-
of-directors/, where the full proposal of
the Nomination and Remuneration Com-
mittee is also available.
This replacement and the election of both
independent non-executive members and
the non-executive member of the Board
will significantly contribute to the further
strengthening of the Board by utilizing
their academic training, professional ex-
perience, qualifications, skills, and is in
line with the Company’s decision for the
continuous and optimal adaptation of its
organization to the provisions and regu-
lations of Law 4706/2020 (Government
Gazette A’ 136/17.07.2020) on corporate
governance and respective best practices.
It is fully aligned with the provisions of
the aforementioned law concerning suit-
ability, diversity and the fulfillment of the
minimum legally required number of inde-
pendent non-executive members.
Finally, it is noted that the election of the
aforementioned new members of the
Board of Directors will be announced, in
accordance with the provisions of the law
and the Company’s Articles of Association,
at the next General Meeting of the share-
holders of the Company. Furthermore,
regarding the new independent non-
executive members, it is noted that their
designation as independent is temporary
until the next General Meeting, which is
the only competent body to decide on this
matter.
Following the above, the Board of Direc-
tors of the Company was reconstituted
into body for the remainder of its term, i.e.
until February 11, 2026, as follows:
1. Konstantinos Chalioris son of Stavros,
Chairman of the Board of Directors
(executive member).
2. Theodoros Kitsos son of Konstanti-
nos, Vice Chairman of the Board of
Directors (independent non-executive
member).
3. Dimitrios Malamos son of Petros, Chief
Executive Officer of the Company (ex-
ecutive member).
4. Athanasios Dimiou son of Georgios,
Member of the Board of Directors
(non-executive member).
5. Vasileios Zairopoulos son of Stylianos,
Member of the Board of Directors
(non-executive member).
6. Christos Shiatis son of Panagio-
tis, Member of the Board of Directors
(non-executive member).
7. Georgios Samothrakis son of Panagio-
tis, Member of the Board of Directors
(independent non-executive mem-
ber).
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 178 of 370
8. Myrto Papathanou daughter of Chris-
tos, Member of the Board of Directors
(independent non-executive mem-
ber).
9. Fotini-Marina Niforos daughter of
George, Member of the Board of Di-
rectors (independent non-executive
member).
10. Eleni Providi daughter of Dimitrios,
Member of the Board of Directors (in-
dependent non-executive member)
and
11. Stylianos Vitogiannis son of Konstanti-
nos, Member of the Board of Directors
(non-executive member).
Reconstitution of the Board of Directors into a Body
The Board of Directors of the Company,
during its meeting of April 1, 2025, follow-
ing the resignation of Mr. Theodoros Kitsos
exclusively from the capacity and office of
Vice Chairman of the Board of Directors of
the Company, retaining solely the status
of non-executive member of the Board
of Directors, due to the fulfilment of the
maximum time period of independence
provided for, in accordance with the pro-
visions of the law in article 9 par. 1 and 2
of Law 4706/2020 and following the rel-
evant proposal of the Remuneration &
Nominations Committee of the Company
and in full compliance with article 8 par.
2 of Law 4706/2020 and the Greek Corpo-
rate Governance Code (point 2.2.21) that
the Company has established and imple-
ments, unanimously and by acclamation
appointed Mr. Georgios Samothrakis, son
of Panagiotis, who already holds the status
of Independent Non-Executive Member of
the Board of Directors, as Vice Chairman of
the Board of Directors for the remainder of
his term (i.e. until February 11, 2026)
For completeness purposes, it is noted that
the fulfilment of the independence criteria
of article 9 of Law 4706/2020 in the person
of Mr. Georgios Samothrakis have already
been confirmed in this regard by the rele-
vant solemn Declaration of Independence
of a Member of the Board of Directors,
as well as in the context of the review of
the above criteria by the Remuneration &
Nominations Committee.
Following the above, the Board of Direc-
tors of the Company was reconstituted
into a body for the remainder of its term
of office, i.e. until February 11, 2026, as fol-
lows:
1. Konstantinos Chalioris son of Stavros,
Chairman of the Board of Directors
(executive member).
2. Georgios Samothrakis son of Panagio-
tis, Vice Chairman of the Board of Di-
rectors (independent non-executive
member).
3. Dimitrios Malamos son of Petros, Chief
Executive Officer of the Company (ex-
ecutive member).
4. Athanasios Dimiou son of Georgios,
Member of the Board of Directors
(non-executive member).
5. Vasileios Zairopoulos son of Stylianos,
Member of the Board of Directors
(non-executive member).
6. Christos Shiatis son of Panagio-
tis, Member of the Board of Directors
(non-executive member).
7. Theodoros Kitsos son of Konstanti-
nos, Member of the Board of Directors
(non-executive member).
8. Myrto Papathanou daughter of Chris-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 179 of 370
tos, Member of the Board of Directors
(independent non-executive mem-
ber).
9. Fotini Marina Niforos daughter of
George, Member of the Board of Di-
rectors (independent non-executive
member).
10. Eleni Providi daughter of Dimitrios,
Member of the Board of Directors (in-
dependent non-executive member),
and
11. Stylianos Vytogiannis son of Konstan-
tinos, Member of the Board of Direc-
tors (non-executive member).
Reconstitution of the Remuneration and Nominations Committee
into a body, following the replacement of one its members
The Board of Directors of the Company,
during its meeting of April 4, 2025, ap-
proved the appointment of Mrs Eleni Pro-
vidi, Independent Non-Executive Member
of the Board of Directors, as a member of
the Nominations and Remuneration Com-
mittee of the Company, replacing the re-
signed member of the Committee, Mr.
Vasileios Zairopoulos, in order to ensure
the appropriate and compliant composi-
tion of the Nominations and Remunera-
tion Committee, in accordance with Article
10 paragraph 3 of Law 4706/2020 and the
Company’s Rules of Operation and follow-
ing the loss of independence of Mr. Theo-
doros Kitsos.
On the same day and following the above
decision, i.e. on 04/04/2025, a meeting of
the Committee took place, under its new
composition. After a vote among its mem-
bers, it was reconstituted as follows:
1. Myrto Papathanou, daughter of Chris-
tos – Independent Non-Executive
Member of the Board of Directors,
Chair of the Nominations and Re-
muneration Committee
2. Theodoros Kitsos, son of Konstantinos
– Non-Executive Member of the Board
of Directors, Member of the Nomina-
tions and Remuneration Committee
3. Eleni Providi, daughter of Dimitrios –
Independent Non-Executive Member
of the Board of Directors, Member of
the Nominations and Remunera-
tion Committee
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 180 of 370
There are no other events after the reporting period that have a significant impact on
the financial statements of the Group or the Company and should be either disclosed or
result in adjustments to the line items of the published financial statements.
Proposed Dividend for the Year 2024
The Board of Directors of the Company,
with its meeting of April 24rd, 2025, unani-
mously decided to propose to the Annual
Ordinary General Meeting of shareholders
the approval of the distribution (payment)
of the profits of the fiscal year that ended
on 31.12.2024 and in particular to propose
the distribution (payment) to the share-
holders of a dividend of a total amount
of 10,250,000.00 Euros (gross amount),
i.e. 0.2343314986 Euros per share (gross
amount) from the profits of the fiscal year
2024 (01.01.2024-31.12.2024), but also from
profits of previous years.
Given that the Company, pursuant to the
relevant decision of the Board of Directors
dated November 14th, 2024, has already
distributed to the shareholders the in-
terim dividend for the fiscal year 2024 of a
total amount of 3,000,000.00 Euros (gross
amount), i.e. 0.0685848289 Euros per
share (gross amount), the Board of Direc-
tors will subsequently propose to the An-
nual Ordinary General Meeting of share-
holders the distribution of the remaining
amount of the dividend, and in particular
the amount of 7,250,000.00 Euros (gross
amount), i.e. 0.1657466698 Euros per share
(gross amount), which gross amount per
share will be increased by the amount
corresponding to the treasury shares that
the Company will hold on the dividend
cut-off date (and which treasury shares are
not entitled to the payment of the divi-
dend, by the provisions of article 50 of Law
4548/2018, as applicable).
The Annual Ordinary General Meeting of
shareholders will take the final decision
concerning the approval of the above pro-
posal.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 181 of 370
Corporate
Governance
Statement
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 182 of 370
SECTION 11: Corporate Governance Statement
The current Corporate Governance State-
ment is compiled according to the pro-
visions of articles 152 and 153 of Law
4548/2018, as amended and in force by
Law 5164/2024, and of article 18 of Law
4706/2020, as applicable at the time of
drafting of this Report, the Hellenic Corpo-
rate Governance Code, which was adopted
and applied by the Company, and finally
the executive decisions of the Hellenic
Capital Market Commission issued by au-
thorization of Law 4706/2020, constitutes
special and separate section of the Annual
Management Report of the Board of Direc-
tors and contains the entire information
required by the law.
Specifically, the structure of the present
Corporate Governance Statement (herein-
after called as “Statement” or “CGS”) is as
follows:
I. Compliance Statement with the Hel-
lenic Corporate Governance Code
II. Deviations from the Corporate Gov-
ernance Code
III. Corporate Governance Practices ap-
plied by the Company apart from
those stated by regulatory framework.
IV. Description of the internal control and
risk management system of the Com-
pany and the Group regarding the pro-
cess of preparing financial statements
and the results of its assessment.
V. Information regarding the Company’s
audit process (Information stipu-
lated by items (c), (d), (f), (h) and (i) of
paragraph 1 of article 10 of Directive
2004/25/EC of the European Parlia-
ment and of the Council of 21 April
2004.
VI. Board of Directors and Committees
VII. General Meeting and Shareholders’
Rights
VIII. Sustainable Development, Environ-
mental and Social Responsibility Policy
IX. Audit Committee Activity Report
I. COMPLIANCE STATEMENT WITH THE
CORPORATE GOVERNANCE CODE
The Company applies the principles of
corporate governance, as they are defined
in the current legislative and regulatory
framework in general. In full and effective
compliance with the provisions of article
17 of law 4706/2020 and article 4 of Deci-
sion No. 2/905/03.03.2021 of the Board of
Directors of the Hellenic Capital Market
Commission, the Company proceeded
based on the relevant decision of the
Board of Directors dated 16.07.2021 to the
adoption and implementation of the Hel-
lenic Corporate Governance Code (here-
inafter called as the “Code”), which was
drafted by the Hellenic Corporate Gov-
ernance Council in June 2021 and is avail-
able at: http://www.esed.org.gr/code-listed,
to which (Code) the Company states that
it complies without any deviations. The
Company, by taking and applying the ap-
propriate, necessary and proper decisions
and measures, proceeded to its full, effec-
tive, substantial and timely compliance
and harmonization with the provisions
of Law 4706/2020 (Government Gazette
A136/17.07.2020), as it applies today and
under which laws substantially reformed
and updated the regulatory framework
for corporate governance, by upgrading
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 183 of 370
the required organizational structures
and corporate governance processes, in-
creasing the principle of transparency and
strengthening the confidence of share-
holders and the investors community
in general, in order for societe anonyms
whose shares are listed on the regulated
market to meet the increased demands of
the modern capital markets.
ΙΙ. DEVIATIONS FROM THE CORPORATE
GOVERNANCE CODE
The Company, as mentioned above, taking
into account in each case the particulari-
ties of its organizational structure and op-
eration, decided voluntarily to adopt and
implement the Hellenic Code of Corporate
Governance. The Code is applied on the
basis of the principle “Comply or explain”,
which requires companies that comply
with the Code to either comply with all of
its provisions, or to explain substantively
the reasons for their non-compliance with
its specific practices, while the explanation
of non-compliance reasons should not be
limited to a simple reference to the prac-
tice with which the Company does not
comply, but should be justified in a specif-
ic, definite, comprehensible, meaningful,
complete and convincing manner.
The Company fully complies with all pro-
visions, specific practices and principles
defined by the Hellenic Code of Corporate
Governance. At the same time, the Com-
pany assesses on a regular basis its compli-
ance with all provisions and specific prac-
tices of the Corporate Governance Code
and proceeds with the implementation of
any appropriate, necessary mitigating ac-
tions, if this is required, in order to ensure
the full, substantial and timely compliance
and harmonization with the provisions of
the Code.
ΙΙI. CORPORATE GOVERNANCE
PRACTICES APPLIED BY THE
COMPANY APART FROM THOSE
STATED BY REGULATORY
FRAMEWORK
As regards to corporate governance is-
sues, the Company applies faithfully and
without any deviations the provisions of
laws 4548/2018, 4706/2020 and 4449/2017
as currently in force, as well as the Hellenic
Corporate Governance Code, the provi-
sions and regulations of which it has as
much as possible, incorporated in its Ar-
ticles of Association, its Internal Rules of
Operation, in the Rules of Procedure of
the Committees, in the Manual of Internal
Control and in all the individual proce-
dures and policies it has established and
implements.
At the present time this Corporate Gov-
ernance Statement was drafted, there are
no applicable practices in addition to the
provisions of the law. Moreover, the Com-
pany applies the above provisions and the
Hellenic Corporate Governance Code to
the rules of procedure of its committees,
in other regulations, codes, procedures
and policies. Finally, it is noted that the
Company is fully harmonized with the pro-
visions of the law 4706/2020 on corporate
governance.
ΙV. DESCRIPTION OF THE INTERNAL
CONTROL AND RISK MANAGEMENT
SYSTEM OF THE COMPANY AND THE
GROUP AS REGARDS TO THE PROCEDURE
OF PREPARING FINANCIAL STATEMENTS
AND ASSESSMENT RESULTS
The Internal Control System consists of
the functions established by the Group,
i.e. both the parent Company and all other
companies included in the consolidation,
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 184 of 370
in order to ensure the protection of its
assets, to identify and address the most
important risks it faces or may face in the
future, to ensure that the financial data on
the basis of which the financial statements
are prepared (separate and consolidated)
are reasonable, and also to ensure that the
laws and the applicable regulatory frame-
work are applied, as well as the principles
the procedures and the policies adopted
by the Management.
For the development of this System, the
Management of the Group, has reviewed
and implemented various Policies, Proce-
dures and Rules, which have been includ-
ed in its Internal Rules of Operation.
Its implementation covers the Manage-
ment of Potential Risks in relation to the
process of drafting Financial Statements
(separate and consolidated) in the follow-
ing three (3) areas:
1. Entity level controls applied by the
Company and each of the other com-
panies included in the consolidation
at a parent level,
2. Financial reporting process controls
implemented by both the Company
and all other companies included in
the consolidation during the process
of drafting financial statements, sepa-
rate and consolidated,
3. IT controls embedded into the infor-
mation systems applied by the Com-
pany as well as all other companies
included in the IT systems framework.
Specifically:
1) Entity level controls
Role and Responsibilities of the Board of
Directors: The Board of Directors decides
on any action that concerns management
of the Company, management of its assets
and in general on anything that relates to
the achievement of its objective and the
promotion of its business activities.
Additionally, the Board of Directors:
• Determines the main responsibilities
and the objective of each Division, so
that the CEO can then assign to each
Director the responsibility of allocat-
ing the above to his/her subordinates.
• Proposes to the General Meeting of
Shareholders the appointment of the
Company’s Chartered Auditors-Ac-
countants, following a proposal by the
Audit Committee, and the determina-
tion of their remuneration.
• Is responsible to prepare a report with
detailed transactions of the Company
with its related parties, which is dis-
closed to the regulatory authorities.
• Is responsible for the preparation of
the Remuneration Report according
with article 112 of Law 4548/2018.
Preparation of Budget and Monitoring
its Implementation at the Board of Di-
rectors level: The Annual Budget, which
is also a guide for the Group’s financial
development, is prepared on an annual
basis (consolidated and also per segment/
subsidiary) and is presented to the Com-
pany’s Board of Directors for approval. The
reports with the actual financial results are
issued periodically, accompanied by the
condensed reports including the expla-
nations of deviations and are discussed at
the Board level.
Internal Rules of Operation: The Com-
pany’s Internal Rules of Operation is also
the manual for its Internal Control System,
which among others includes the follow-
ing:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 185 of 370
• Description and guidance on manag-
ing the different operations
• Control points in stand-alone proce-
dures
• Delegation of responsibilities
• Authorizations and limits of expense
approvals
• Instructions for Controls on the main
sections of the Internal Control Sys-
tem.
The adequacy of the Internal Control Sys-
tem is monitored on a systematic basis
by the Audit Committee through regular
meetings that take place with the Inter-
nal Audit and the Risk and Compliance
Management Department in the context
of monitoring the Annual Audit Program
for the Company and the Group, which
is prepared based on the relevant risk as-
sessment.
2) Financial reporting process controls
In order to ensure fully and adequately
that the financial data, based on which
the financial statements of both the Com-
pany and the Group (annual and quarterly
financial statements) are reasonable, the
Company applies specific control proce-
dures that include the following:
• The postings from the Company’s ac-
counting department are performed
based on a specific process that en-
sures the authenticity and genuine-
ness of the documents (electronic and
paper) and requires all documents to
carry the respective signed approvals.
• The Company maintains a Fixed Asset
Register in the Fixed Assets sub-sys-
tem and applies depreciation rules ac-
cording to the International Financial
Reporting Standards and Tax Rules in
effect.
• The Accounting Department carries
out periodic reconciliation of balances
of payroll, customers, suppliers’ ac-
counts, VAT, etc.
• The Group prepares the consolidated
budget on an annual basis. Each sub-
sidiary prepares its corporate budget
in alignment with the objectives of the
Group. These budgets shall be sub-
mitted to the Board of Directors of the
Company for approval.
• Each month a detailed financial re-
sults presentation is prepared per
segment/subsidiary and on a consoli-
dated Group level. This presentation is
submitted to the Company’s Manage-
ment.
• Companies that constitute the Group
follow common accounting standards
and procedures in line with the Inter-
national Financial Reporting Stand-
ards (IFRS).
• At the end of each period, the ac-
counting standards of the parent and
subsidiary companies prepare their
financial statements according to
the International Financial Reporting
Standards (IFRS).
• The Statutory reporting departments
of the Group collect all the necessary
data from subsidiaries, consolidation
entries are applied, and the financial
statements of the Group are prepared
according to the International Finan-
cial Reporting Standards (IFRS).
• There are specific financial statements
closing processes, which include
deadlines for submission, responsi-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 186 of 370
bilities and update on the required ac-
tions.
• The financial statements are audited
by Chartered Auditors-Accountants
whose work is monitored by the Au-
dit Committee, which then proposes
their approval to the Company’s Board
of Directors.
• The Departments of Internal Audit
and Risk & Compliance periodically
perform audits to confirm the accu-
racy, completeness, and correctness
of financial statements.
3) IT controls
The Group IT Department is responsible
for supporting the Group’s and the Com-
pany’s IT applications. This Department
has established robust IT controls frame-
work, which ensures the support of the
short-term and also the long-term objec-
tives of the Company and the Group.
All applicable procedures are described in
detail by the Company’s Internal Rules of
Operation. It is noted that all the compa-
nies of the Group follow the Group Poli-
cies Manual and fully comply with its basic
principles, rules, and procedures, in order
to ensure the reliable and adequate imple-
mentation of the control of information
systems of all companies within the Group.
The most important of these procedures
are listed below:
• Back Up process (in Hardware): Ac-
cording to the Internal Rules of Op-
eration, the IT Service is required to
develop the appropriate infrastruc-
ture and maintain an alternative infor-
mation system to replace the system/
applications in use, in case of damage
in the Company’s and the Group’s cen-
tral IT system.
• Safekeeping (Confidential) of the
Company’s and the Group’s Electronic
Files: The IT Department applies the
appropriate systems/platforms that
ensure the “non” leakage of the Com-
pany’s and the Group’s IT data.
• Files of the Central System: Particular
emphasis is given to the access of the
data room where the Central System
is hosted, which is provided only to
IT authorized employees by the Ad-
ministrator. The access is checked ad-
equately and on a regular basis.
• In addition to the main systems/plat-
forms of the Company and the Group
(e.g., ERP-SAP, Consolidation Platform,
etc.), cloud infrastructures (Microsoft
Azure) are leased, after ensuring that
they adhere to the strictest security
protocols.
• Files –Software of the Peripheral Sys-
tems: Access to files and system soft-
ware is granted to specific individuals
with the use of personal passwords.
• Processes for Security of the Central
and Peripheral Systems: In the context
of protecting the Group’s IT system,
and taking advantage of the latest
technology available, the IT Depart-
ment applies advanced security prac-
tices, such as antivirus security soft-
ware, e-mail security, firewalls etc.
The Audit Committee of the Company
monitors continuously and systematically
the adequacy of the Company’s Internal
Control System, given that:
• It has approved the Company’s Inter-
nal Rules of Operation which has in-
corporated the appropriate Policies,
Processes and Rules that comprise the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 187 of 370
Internal Control System applied by the
Company, including Group’s Policies
Manual, which concerns the common
policies and procedures applied by
the subsidiaries.
• The members of the Company’s Audit
Committee as well as the Members of
the Board of Directors are recipients of
the reports prepared by the Compa-
ny’s Internal Audit Unit and the Regu-
latory Compliance & Risk Management
Department of the Company. In these
reports, the Company and the Group’s
operations are assessed as well as the
adequacy of Internal Control Systems
applied.
Assessment of the Internal Control
System
According to article 14 par. 3 case j of Law
4706/2020 and no. 1/891/ 30.9.2020 deci-
sion of the Board of Directors of the Hellen-
ic Capital Market Commission, as amend-
ed by no. 2/917/17.6.2021 decision of the
Board of Directors of the Hellenic Capital
Market Commission, in compliance with
the aforementioned regulatory frame-
work, a periodic assessment of the Internal
Control System of the Company took place
with a reporting date of 31.12.2022 and a
reporting period from the commence-
ment of the effectiveness of article 14 of
Law 4706/2020 (17.07.2021), particular as
to the adequacy and effectiveness of the
financial information, on an individual and
consolidated basis, in terms of risk man-
agement and regulatory compliance, in
accordance with recognized compliance
and internal control standards, as well as
the implementation of the provisions on
corporate governance of Law 4706/2020.
This assessment was carried out by an in-
dependent Chartered Auditor-Accountant
who satisfies the provisions of Law
4706/2020 and the abovementioned deci-
sion of the Hellenic Capital Market Com-
mission’s Board of Directors, in accordance
with the relevant policy / procedure, for
the periodic assessment of the Company’s
Internal Control System. In specific, the
registered in Public Registry of article 14 of
Law 4449/2017 auditing Company PRICE-
WATERHOUSECOOPERS Auditing Com-
pany SA (AM SOEL 113) was appointed
pursuant to the decision of the Board of Di-
rectors of the Company of 11.03.2022, fol-
lowing the relevant proposal of the Audit
Committee of the Company of 08.03.2022,
together with the Board of Directors’ deci-
sion dated 16.07.2021, which determined
the significant subsidiaries included in the
scope of the assessment (namely, Thrace
Nonwovens & Geosynthetics S.A, Thra-
ce Plastics Pack S.A. and Don & Low Ltd
Scotland).
The scope of the assessment, which was
decided by the Board of Directors of the
Company, includes all the topics of the
assessment as described in chapter ii.b of
the decision 1/891/30.09.2020 of the Board
of Directors of the Hellenic Capital Market
Commission. More specifically, the scope
of the assessment included the Control En-
vironment, the Risk Management frame-
work, the Control Activities, the Informa-
tion and Communication framework and
the Internal Controls System Monitoring.
The assessment of the Internal Control
System was conducted by Mr. Evangelos
Venizelos, Chartered Auditor-Accountant
(SOEL Reg.Nr.39891), in PRICEWATER-
HOUSECOOPERS Auditing Company SA,
with a reference date of 31.12.2022.
According to the “Internal Control System
Adequacy and Effectiveness Assessment
Report” dated 20.03.2023 of the afore-
mentioned Auditing Company, which was
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 188 of 370
submitted to the Company after the com-
pletion of the assessment of the Compa-
ny’s Internal Control System, based on the
work carried out, as well as the evidence
obtained, regarding the assessment of
the adequacy and effectiveness of the
Internal Control System of the Company
and its significant subsidiaries with a ref-
erence date of 31.12.2022, nothing that
could be considered a material weakness
of the Company’s Internal Control System
and its significant subsidiaries has come
to the auditing Company attention, in ac-
cordance with the Regulatory Framework
(article 14 par. 3 par. j’ and par. 4 of Law
4706/2020, Decision of the Board of Direc-
tors of the Capital Market Commission no.
1/891/30.09.2020, as amended by the deci-
sion of the Board of Directors of the Capital
Market Commission no. 2/917/17.06.2021
as in force).
Therefore, due to the absence of any mate-
rial findings, there is no need to apply the
provisions of section ii. c of the Decision
No 1/891/30.9.2020 of the Board of Direc-
tors of the Hellenic Capital Market Com-
mission, as amended by the decision No
2/917/17.6.2021 of the Board of Directors of
the Hellenic Capital Market Commission as
in force, and paragraph Α of the letter No
425/21.02.2022 of the LISTED COMPANIES
DIVISION, (Listed Companies Supervision
Department) of the Hellenic Capital Mar-
ket Commission with subject: “Highlights,
clarifications and recommendations re-
garding the actions of listed companies
in view of the publication of the Annual
Financial Reports and the implementa-
tion of Law 4706/2020 “Corporate govern-
ance of joint-stock companies, modern
capital market, incorporation into Greek
legislation of Directive (EU) 2017/828 of
European Parliament and of the Council,
measures to implement Regulation (EU)
2017/1131 and other provisions” do not
apply. Those regulations and guidelines
require that the Corporate Governance
Statement must include a response by the
Company’s Management for the signifi-
cant deficiencies, including a brief refer-
ence to the action plans and the relevant
timetable in place to resolve them, as well
as a brief reference to the actions taken by
the Company during the reporting year to
resolve the deficiencies in question, based
on the aforementioned action plan.
Assessment of the Corporate
Governance System
In accordance with article 4 par. 1 of Law
4706/2020 as currently in force, and in com-
pliance with the above regulatory frame-
work, an assessment of the Company’s
Corporate Governance System was carried
out, with a reference date of 31.12.2023
and a reference period from the entry
into force of article 4 of Law 4706/2020
(17.07.2021). The assessment was repeated
for the closing corporate fiscal year, with a
reporting date of 31.12.2024 and a report-
ing period of 01.01.-31.12.2024.
According to the detailed definition of ar-
ticle 13 of Law 4706/2020, the Corporate
Governance System includes the internal
control system, the prevention, identifica-
tion and suppression of conflict of interest
cases, mechanisms to facilitate the exer-
cise of shareholders’ rights and finally the
remuneration policy.
The following areas were examined/
assessed within the content of the as-
sessment of the Corporate Governance
System:
a) The adequacy and effectiveness of
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 189 of 370
the Internal Control System
1
(of Hold-
ing Company and its significant sub-
sidiaries), in particular with regard to
the adequacy and effectiveness of fi-
nancial reporting, on an stand-alone
and consolidated basis, in terms of risk
management and regulatory compli-
ance, in accordance with well-estab-
lished assessment and internal control
standards, as well as the application of
the corporate governance provisions
of Law 4706/2020.
The scope of the assessment, as de-
cided by the Board of Directors of the
Company, included all the areas of the
assessment, as described in chapter
ii.b of the decision 1/891/30.09.2020
of the Board of Directors of the Capital
Market Commission. More specifically,
the scope of the assessment included
the Control Environment, the Risk
Management framework, the Control
Activities, the Information and Com-
munication framework and the Inter-
nal Control System Monitoring.
b) The adequacy and effectiveness of the
procedures for the prevention, detec-
tion and suppression of situations of
conflict of interest.
c) The adequacy and effectiveness of the
communication mechanisms with the
shareholders, in order to facilitate the
exercise of their rights and the active –
constructive dialogue.
d) The remuneration policy, in order to
ascertain whether it actually serves
1 This subject area is partially covered by the assessment that took place during the previous year
by Mr. Evangelos Venizelos, Chartered Auditor-Accountant (SOEL Reg.Nr.39891), in «PRICEWATER-
HOUSECOOPERS Auditing Company SA» (SOEL Reg.Nr.113) with a reference date of December 31,
2022 and includes the significant subsidiaries of the Company.
2 The above items e) to h) are specific subject areas, not included in the narrow core of the CGS, how-
ever they are assessed as necessary in view of the formulation of a. 4 par. 1 (referring to the CGS,
provisions 1-24 of Law 4706).
the business strategy, the long-term
interests of the Company and its
sustainability.
e) The adequacy of the Company’s Oper-
ating Regulations in accordance with
article 14 of Law 4706/2020
2
.
f) Any deviations from the use of funds
raised in accordance with article 22 of
Law 4706/2020 (if applicable)
2
.
g) The disposal of any assets of the Com-
pany in accordance with article 23 of
Law 4706/20202, and finally
h) The degree of compliance of the Com-
pany with the Hellenic Corporate Gov-
ernance Code (HCGC) of the Hellenic
Corporate Governance Council adopt-
ed and applied by the Company
2
.
This assessment was carried out by the
Secretary of the Board of Directors with
the assistance of the Regulatory Compli-
ance & Risk Management Unit and the
Audit Committee, as defined by virtue of
the decision of the Board of Directors of
the Company dated 03.11.2023, follow-
ing the relevant recommendation of the
Audit Committee of the Company to the
Board of Directors dated 25.10.2023. The
results of the assessment with a reporting
date of 31.12.2023 and a reporting period
from the entry into force of article 4 of Law
4706/2020 (17.07.2021) confirmed the fact
that the Company has adopted and is im-
plementing a comprehensive, adequate
and effective Corporate Governance Sys-
tem, which includes all requirements pro-
vided for by the applicable legislation.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 190 of 370
Taking into account the notes, clarifications
and recommendations of the documents
with protocol number 604/05.03.2024 and
434/24.02.2025 of the Listed Companies
Directorate of the Hellenic Capital Mar-
ket Commission distributed to all Listed
Companies of the Athens Stock Exchange,
the Company conducted the internal as-
sessment of the Adequacy and Effective-
ness of the Corporate Governance System
for the closing fiscal year, with reference
date 31.12.2024 and a reporting period of
01.01.-31.12.2024.
The new assessment was carried out by
the Secretary of the Board of Directors
with the assistance of the Regulatory Com-
pliance & Risk Management Unit and the
Audit Committee, as defined by the deci-
sion of the Company’s Board of Directors
on 15.11.2024, following the relevant rec-
ommendation made by the Company’s
Audit Committee to the Board of Directors
on 09.09.2024.
The results of the review confirm that the
Company continues to maintain and im-
plement a comprehensive, adequate and
effective Corporate Governance System,
in full compliance with applicable regula-
tory requirements. This system takes into
account the size, nature, scope and com-
plexity of the Company’s business activi-
ties and includes all requirements provid-
ed by the applicable legislation, without
detecting any deviations from regulatory
requirements and current international
best practices. The above results are an-
other confirmation that the Company is in
continuous compliance with the current
legislative and regulatory framework that
governs its Internal Control System and
Corporate Governance System for the pur-
pose of their lawful and smooth operation.
The next assessment of the Internal Con-
trol System and Corporate Governance
System will be carried out with a report-
ing date of 31.12.2025. In this context and
from now on, the period for the two as-
sessments (Internal Control System and
Corporate Governance System) will be
aligned with what is defined in the letter
of the Hellenic Capital Market Commission
(sent to all listed entities in ATHEX) with
number 434/24.02.2025 and title “Remarks,
clarifications and recommendations regard-
ing the actions of listed companies in view
of the publication of the Annual Financial
Reports of 31.12.2024 in the context of corpo-
rate governance”.
Following the above, and after the end of
the Company’s fiscal year 2024 (01.01.2024-
31.12.2024), the Board of Directors con-
ducted an annual review of the corporate
strategy, the main business risks facing the
Company in the industry in which it oper-
ates and the internal control systems it ap-
plies, and its findings were the following:
• the Company’s strategy and the busi-
ness plan are implemented properly
and according to the planning of the
individual Divisions, in order for the
Company to continue to stand out for
the promotion of innovative products
that meet the constantly evolving and
most demanding needs of its custom-
ers, creating value for its people, con-
tributing to the local community and
building relationships of trust,
• The main business and financial risk
areas of the Company as well as the
issues that may have a significant im-
pact on the financial statements of the
Company and Group, have been re-
ported in detail in the relevant Section
of the Board of Directors Report,
• The internal audit is carried out in
accordance with the current legisla-
tive and regulatory framework and
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 191 of 370
the principles of the Code of Ethics
and covers the main activities of the
Company, in order to assess in time
any deficiencies, errors, weaknesses
and possible fraud that may result in a
misappropriation and/or loss of assets
and verify the credibility of the entity’s
financial figures.
Non-audit services provided by the
Chartered Auditor-Accountant
The Auditing Company, which is in charge
of carrying out the mandatory audit (or
review where applicable) of the annual
and semi-annual financial statements
(stand-alone and consolidated), as well
as the issuance of the tax certificate, pro-
vided to the Company the following non-
audit services during the fiscal year 2024
(01.01.2024-31.12.2024):
(a) Technical support on the compli-
ance of Thrace Polybulk A.S. with
the Norwegian tax and accounting
framework.
(b) CSRD Readiness Assessment aimed
at understanding the current status
of all procedures in relation to data
collection, measurement, integration
and indicator reporting in the context
of the Company’s preparation for the
2024 Sustainability Report.
However, the fact that the Auditing Com-
pany provided the above (non-audit) ser-
vices had no effect, direct or indirect, on
the independence, objectivity, integrity,
reliability and effectiveness of the statu-
tory audit, as the provision of the specific
services took place from a completely dif-
ferent team of the said Auditing Company
and from other persons, who have no
involvement and participation (direct or
indirect) in the process of conducting the
statutory audit of the financial statements
(annual and semi-annual, stand-alone and
consolidated) where appropriate, or were
performed under adequate safeguards
and rules and by nature these services can-
not jeopardize their independence, which
is additionally ensured by the strict inter-
nal procedures and protocols applied by
the Auditing Company itself.
All the above non-audit services were ap-
proved by the Audit Committee.
V. INFORMATION REGARDING THE
COMPANY’S CONTROL FRAMEWORK
(INFORMATION OF ITEMS (C), (D),
(F), (H) AND (I) OF PARAGRAPH 1 OF
ARTICLE 10 OF DIRECTIVE 2004/25/EC
OF THE EUROPEAN PARLIAMENT AND
THE COUNCIL, OF 21
ST
APRIL 2004.)
Significant direct or indirect sharehold-
ings (including indirect shareholdings
through pyramid structures or cross-
participation) according to the defini-
tion of article 85 of Directive 2001/34/ΕC
As regards to significant shareholdings in
the share capital and voting rights of the
Company, according to the definition of
article 85 of Directive 2001/34/EC and the
provisions of articles 9 up to 11 of Law
3556/2007, the shareholders of the Com-
pany with percentages above 5%, as of
31.12.2024, are:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 192 of 370
Mr. Konstantinos Chalioris, shareholder and
Chairman of the Board of Directors of the
Company, transferred from his individual
share, to two “Joint Investor Shares” (KEM),
the first one jointly created with his son Alex-
andros Chalioris and the second one jointly
created with his son Stavros Chalioris (him-
self being the first beneficiary in both “Joint
Investor Shares”), a total of 18,000,983 com-
mon registered shares with voting rights,
i.e. a percentage of 41.153% of a total of
43,741,452 common registered shares with
voting rights of the Company.
However, following the above, there was
absolutely no change in the number and
percentage of shares and voting rights con-
trolled by Mr. Konstantinos Chalioris, who
holds a total of 18,936,558 common regis-
tered shares with voting rights of the Com-
pany (and the same number of voting rights)
a percentage of 43.292%. More specifically,
he holds 18,000,983 common registered
shares through the aforementioned “Joint
Investor Share” and 935,575 common regis-
tered shares with voting rights (percentage
2.139%) through his individual share.
2. Mr. Stavros Chalioris, son of Konstantinos,
due to his participation in the aforemen-
tioned “Joint Investor Share” (which he holds
jointly with Konstantinos Chalioris) holds
9,000,491 common registered shares of the
Company (percentage 20.577%), while he
already holds 212,071 common registered
shares with voting rights (percentage
0.484%) in his individual share and,
3. Mr. Alexandros Chalioris, son of Konstan-
tinos, due to his participation in the afore-
mentioned “Joint Investor Share” (which he
holds jointly with Konstantinos Chalioris)
holds 9,000,492 common registered shares
of the Company (percentage 20.577%), while
he already holds 212,071 common registered
shares with voting rights (percentage of
0.484%) in his individual share.
No other individual or legal entity has
a shareholding of more than 5.00% of
the Company’s share capital and voting
rights. Data regarding the number of
shares and voting rights of individuals
owning significant shareholdings, has
been derived by the Shareholders’ registry
kept by the Company and the notifications
made to the Company by the shareholders
according to Law (and MAR).
Owners of any type of titles that provide
special control rights and description
of such rights.
There are no securities, including the
Company’s shares that provide owners
with special control rights.
Any kind of limitations on voting
rights, such as limitations on voting
rights of owners that hold a specific
percentage or number of votes, the
exercise deadlines for voting rights,
LAST NAME NAME
SHARES IN
J.I.A.*
SHARES OUT
OF J.I.A.*
TOTAL SHARES
VOTING
RIGHTS
Chalioris Konstantinos 41.15% 2.14% 43.29% 43.29%
Chaliori Effimia - 20.85% 20.85% 20.85%
Chalioris Alexandros 20.58% 0.48% 21.06% 0.48%
Chalioris Stavros 20.58% 0.48% 21.06% 0.48%
* the relevant announcement was posted on the Company’s website on March 10, 2023
and it mentions:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 193 of 370
or systems through which, with the
cooperation of the Company, financial
entitlements that derive from the titles
are distinguished from the ownership
of the titles.
The Company’s Articles of Association
provides no limitations to voting rights
deriving from its shares.
Rules governing the appointment and
replacement of the Board members as
well as the amendments of the Articles
of Association.
The rules included in the Company’s
Articles of Association, both as regards
to the appointment and the replacement
of Board Members and as regards to its
amendments, do not differ from those
stated by the L. 4548/2018 as it is in effect.
The authorities of Board members,
specifically as regards to the ability to
issue or buy-back shares.
There is no specific statutory authority
granted to the Board of Directors or some
of its members for the issuance of new
shares or the purchase of treasury shares
according to article 49 of law 4548/2018.
The relevant power and responsibility are
given to the Company’s Board of Directors
by virtue of a relevant decision of the
Shareholders General Meeting.
In accordance with this framework, the
Annual Ordinary General Meeting of the
shareholders of 24 May 2023 decided by
majority the approval of Company’s shares
buy-back program in accordance with the
provisions of article 49 of L. 4548/2018, as
in force, and in particular approved the
purchase within a period of twenty-four
(24) months from the date of adoption
of this resolution, namely no later than
24.05.2025, of a maximum of 4.341.876
common, registered shares, (including and
specifically aggregated in relation to the
above limit of the total of the Company’s
own shares already held within the
framework of previous share buy-back
programs) with a purchase price range
from fifty eurocents (€ 0.50) per share
(minimum price) to ten Euro (€ 10,00) per
share (maximum price).
VI. BOARD OF DIRECTORS AND
COMMITTEES
1) Composition of the Board of
Directors
According to article 7, paragraph 1 of its
Articles of Association, as in force after its
amendment by the Extraordinary General
Meeting of Shareholders on 19 March 2019,
for the purpose of harmonization with
the provisions of Law 4548/2018 and as
amended by the Ordinary General Meet-
ing of May 24, 2023, the Company is man-
aged by a Board of Directors (hereafter
called as “the Board of Directors”) which
consists of seven to fifteen (7-15) mem-
bers. The members of the Board of Direc-
tors are elected by the General Meeting of
shareholders, may be shareholders or not
and have a five-year term, which is extend-
ed until the expiration of the term within
which the next Ordinary General Meeting
must convene and until a relevant decision
is taken, but in any case, should not exceed
a six-year term..
• In case of resignation, death or in any
other way loss of the capacity of the
membership of one or many members
of the Board of Directors, the remain-
ing members may either elect mem-
bers of such in replacement of the
above or may continue the manage-
ment and representation of the Com-
pany without any replacement, with
the condition that the number of the
remaining members is not less than
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 194 of 370
half of the number of members during
the time such events occurred. In no
case, the Board members are allowed
to be less than three (3).
• Without prejudice to the provisions of
Corporate Governance law 4706/2020
in case of electing a replacement, the
decision for the election is subject to
the disclosure requirements of article
13 of L. 4548/2018, as currently in ef-
fect, and is announced by the Board of
Directors at the next General Meeting,
which can even replace those elected,
even if the relevant issue had not been
included in the General Meeting agen-
da.
• The actions of the elected temporary
replacement are valid even if the Gen-
eral Meeting does not validate his/her
election or even if it has elected or not
another permanent member of the
Board.
• The term of the new Board member is
terminated when and whenever the
term of the replaced member would
have been terminated.
The Extraordinary General Meeting of
Shareholders of 11 February 2021 elected
a new 11-member Board of Directors for a
5-year term, i.e. until 11/02/2026, extended
until the date of the next Ordinary Gen-
eral Meeting and until a relevant decision
is being made, consisting of the following
members:
1) Konstantinos Chalioris of Stavros, Chairman, Executive Member
2) Theodoros Kitsos of Konstantinos,
Vice Chairman, Independent non-executive
member
3) Dimitrios Malamos of Petros
Chief Executive Officer (Group CEO),
Executive member
4) Vassilios Zairopoulos of Stylianos Non-executive member
5) Christos Shiatis of Panagiotis Non-executive member
6) Christos-Alexis Komninos of
Konstnatinos
Non-executive member
7) Petros Fronistas of Christos Independent non-executive member
8) Georgios Samothrakis of Panagiotis Independent non-executive member
9) Myrto Papathanou of Christos Independent non-executive member
10) Spyridoula Maltezou of Andreas Independent non-executive member
11) Nikitas Glykas of Ioannis Independent non-executive member
Furthermore, during the Annual Ordinary
General Meeting of shareholders of May,
25, 2022, (Topic 12th) the election of Mr.
Athanasios Dimiou of Georgios, as the new
non-executive member of the Board of Di-
rectors in the position and for the remain-
ing of the term (i.e. until 11.02.2026) of the
resigned non-executive member Mr. Pet-
ros Fronistas of Christos was announced
to the body of shareholders in accordance
with the provisions of article 82 par. 1 of
law 4548/2018, as in force.
The abovementioned election took place
during the meeting of the Board of Direc-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 195 of 370
tors of the Company on July 28, 2021 and
following the relevant nomination of the
Remuneration and Nominations Commit-
tee of the Company and in full compliance
and alignment with the suitability (individ-
ual and collective) and diversity principles
and criteria adopted and implemented by
the Company. Following the above, the
Board of Directors of the Company was re-
constituted into a body for the remainder
of its term, namely until 11.02.2026.
The minutes of the Board of Directors
meeting held on 28.07.2021 with subject
the replacement of the resigned, were
registered in the General Commercial Reg-
ister (G.E.M.I.) on 03.08.2021 with Registra-
tion Code 2596045, issued with protocol
number 2415279/03.08.2021 following the
relevant announcement of the Ministry
of Development and Investment (Gen-
eral Secretariat of Commerce & Consumer
Protection, General Directorate of Market,
Directorate of Companies, Department of
Supervision of Listed SAs & Sports SA).
Subsequently, the Board of Directors
of the Company, during its meeting on
05.11.2024, unanimously decided, follow-
ing a relevant recommendation by the
Remuneration and Nominations Com-
mittee (RNC), the non-replacement of the
deceased non-executive member of the
Board of Directors, Christos - Alexis Komni-
nos, and the continuation of the manage-
ment and representation of the Company
via the remaining ten (10) members of the
Board of Directors of the Company for the
remaining term of the latter. Of the above
ten (10) members, two (2) are executive and
eight (8) are non-executive, whereas five
(5) out of the total number are independ-
ent non-executive, within the context of
article 9 of Law 4706/2020. The above was
decided in accordance with the provisions
of article 82, par. 2 of Law 4548/2018 and
article 11, par. 2 of the Company’s Articles
of Association.
The excerpt from the minutes of the Board
of Directors on 05.11.2024 regarding the
non-replacement of the above deceased
member was registered in the General
Electronic Commercial Registry (G.E.M.I.)
on 11.11.2024 with Registration Code Num-
ber 4578453, along with the issuance of
the relevant announcement under pro-
tocol number 3438320/11.11.2024 of the
Ministry of Development and Investments
(General Secretariat of Commerce & Con-
sumer Protection, General Directorate of
Market, Directorate of Companies, Depart-
ment of Listed Companies S.A.).
Subsequently, on 27.02.2025, the following
members submitted their resignations:
1. Nikitas Glykas, Independent Non-Ex-
ecutive Member of the Board of Direc-
tors, and
2. Spyridoula Maltezou, Independent
Non-Executive Member of the Board
of Directors.
Following the above, the Board of Direc-
tors of the Company at its meeting of
28.2.2025, after accepting the relevant
recommendation by the Remuneration
and Nominations Committee (RNC) of the
Company, in accordance with the provi-
sions of article 82, par. 1 of Law 4548/2018,
articles 5 and 9, par. 4 of Law 4706/2020,
article 8 of the Company’s Articles of As-
sociation and finally in accordance with
the Suitability Policy in effect and also in
line with the best corporate governance
procedures and practices applied by the
Company, unanimously elected:
(a) Ms. Fotini Marina Niforos of Georgios
and Ms. Eleni Providi of Dimitrios, as
new temporary independent non-
executive members of the Board of
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 196 of 370
Directors in replacement of the re-
signed and retired independent non-
executive members of the Board of
Directors, Mr. Nikitas Glykas and Ms.
Spyridoula Maltezou (due to the com-
pletion of the time limit of their term
as provided by the article 9 par. 4 case
“ca” of Law 4706/2020).
(b) Stylianos Vytogiannis, son of Konstan-
tinos, as non-executive member of the
Board of Directors in replacement of the
deceased Christos - Alexis Komninos.
The minutes of the Board of Directors of
the Company dated 28.02.2025 regard-
ing the replacement of the resigned inde-
pendent non-executive members and the
deceased non-executive member of the
Board of Directors were registered in the
General Electronic Commercial Registry
(G.E.M.I.) on 06.03.2025 with Registration
Code Number 5300384, along with the is-
suance of the relevant announcement un-
der protocol number 3575536/06.03.2025
of the Ministry of Development and Invest-
ments (General Secretariat of Commerce &
Consumer Protection, General Directorate
of Market, Directorate of Companies, De-
partment of Listed Companies S.A.).
Following the resignation of Mr. Theo-
doros Kitsos from the position of Inde-
pendent Non-Executive Vice Chairman,
the Board of Directors of the Company at
its meeting of 02.04.2025, after accepting
the relevant recommendation by the Re-
muneration and Nominations Committee
(RNC) of the Company, in view of the loss
of independence which occurred due to
the completion of nine (9) financial years
cumulatively from the time of their elec-
tion as member of the Board of Directors
of the Company, in accordance with the
provisions of articles 5 and 9, par. 2 “ca”) &
4 of Law 4706/2020, of article 82, par. 1 of
Law 4548/2018 and of article 8 of the Com-
pany’s Articles of Association and finally in
accordance with the Suitability Policy in
effect but also in line with the best corpo-
rate governance procedures and practices
as applied by the Company, unanimously
elected Mr. George Samothrakis to the
position of Independent Non-Executive
Vice-Chairman of the Company’s Board of
Directors.
The minutes of the Board of Directors
dated 02.04.2025 regarding the election
of Mr. Georgios Samothrakis to the posi-
tion of Independent Non-Executive Vice-
Chairman of the Board of Directors of
the Company, and in replacement of Mr.
Theodoros Kitsos, were registered in the
General Electronic Commercial Register
(G.E.M.I) on 07.04.2025 with Registration
Code Number 5345568, along with the is-
suance of the relevant announcement un-
der protocol number 3598573/07.04.2025
of the Ministry of Development and Invest-
ments (General Secretariat of Commerce &
Consumer Protection, General Directorate
of Market, Directorate of Companies, De-
partment of Listed Companies S.A.).
The above changes will be announced at
the immediately following General Meet-
ing of Shareholders pursuant to article
82, par. 1 of Law 4548/2018 as in force. It
is noted that, with regard to the new in-
dependent non-executive members, the
attribution of this capacity to these mem-
bers is temporary and lasts until the next
General Meeting of shareholders, which is
the only competent authority to decide in
this regard.
It should be underlined that at the time
of drafting this Report, the independent
non-executive members of the Company’s
Board of Directors, who were appointed
in the Extraordinary General Meeting of
Shareholders on February 11, 2021 and in
accordance with the decisions of the Com-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 197 of 370
pany’s Board of Directors on 28.02.2025
and 02.04.2025 have been formulated as
follows:
1. Georgios Samothrakis of Panagiotis,
2. Myrto Papathanou of Christos,
3. Fotini Marina Niforos of Georgios, and
4. Eleni Providi of Dimitrios.
It is noted that the above members who all
meet in their entirety the independence
requirements and criteria set forth by the
current legislative framework (article 9,
par.1 and 2 of Law 4706/2020), namely:
(a) They do not hold directly or indirectly
a percentage of voting rights greater
than 0.5% of the Company’s share cap-
ital and
(b) They are free from any dependent re-
lationship with the Company or per-
sons affiliated with it and do not main-
tain any financial, business, family, or
other relationship, which may affect
their decisions and their independent,
objective and fair judgment.
The Company has adopted and imple-
ments the Procedure for Ensuring Inde-
pendence and Disclosure of Dependent
Relationships of the Independent Non-
Executive Members of the Board of Direc-
tors in accordance with the current legal
framework. The purpose of this Procedure
is to ensure that the Independent Non-Ex-
ecutive Members of the Board of Directors
meet throughout their term the criteria
of independence and any dependent re-
lationships of themselves or persons who
have close relations with these persons are
duly and timely notified to the Company.
The Board of Directors take all the neces-
sary measures to ensure compliance with
the above Independence Criteria. The
Board of Directors with the support of
the Remuneration and Nominations Com-
mittee and the Regulatory Compliance
Department reviews the fulfilment of the
Independence Criteria of the Independent
Non-Executive Members at least annually
per financial year and before the publica-
tion of the annual Financial Report, which
includes the relevant verification. In the
event that during the audit of the fulfil-
ment of the independence criteria or in
case at any time it is ascertained that the
independence criteria have ceased to ex-
ist in the person of any Independent Non-
Executive Member or this Member makes
a relevant statement to the Company, the
Board of Directors takes the appropriate
steps to replace him/her without delay, fol-
lowing a nomination by the Remuneration
and Nominations Committee.
Each Independent Non-Executive Board of
Directors Member submits to the Remu-
neration and Nominations Committee an-
nually, an affirmation statement regarding
the fulfilment of the criteria of independ-
ence by him/her, without however the
Company being satisfied exclusively with
the submission of the declaration accord-
ing to the above.
The Board of Directors of the Company,
after a thorough examination with the as-
sistance of the Remuneration and Nomina-
tions Committee for the fulfilment by the in-
dependent non-executive members of the
independence conditions defined by article
9 par. 1 and 2, declares and confirms that
both during the fiscal year 2024 (01.01.2024-
31.12.2024) and on the approval date of the
present, the independent non-executive
members, and in particular Messrs. Theo-
doros Kitsos, Georgios Samothrakis, Myrto
Papathanou, Spyridoula Maltezou and Ni-
kitas Glykas, fully meet the criteria of inde-
pendence set by the current legislative and
regulatory framework in general.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 198 of 370
The following table presents the members of the eleven-member (11-member)
Board of Directors in effect (or B.O.D.):
Member Position in the board
Date of election/
appointment
Expiry of
tenure
Konstantinos Chalioris
Chairman of BoD, Executive
Member
11.02.2021 11.02.2026
Georgios Samothrakis
Vice Chairman, Independent
non-executive member
11.02.2021 11.02.2026
Dimitrios Malamos
Chief Executive Officer (Group
CEO), Executive member
11.02.2021 11.02.2026
Theodoros Kitsos Non-executive member 11.02.2021 11.02.2026
Vassilios Zairopoulos Non-executive member 11.02.2021 11.02.2026
Christos Shiatis Non-executive member 11.02.2021 11.02.2026
Athanasios Dimiou Non-executive member 28.07.2021 11.02.2026
Stylianos Vytogiannis Non-executive member 28.02.2025 11.02.2026
Myrto Papathanou
Independent non-executive
member
11.02.2021 11.02.2026
Foteini Marina Niforos
Independent non-executive
member
28.02.2025 11.02.2026
Eleni Providi
Independent non-executive
member
28.02.2025 11.02.2026
All members of the Board of Directors are
Greek nationals besides Mr. Christos Shiatis
who holds a Cypriot citizenship.
Particularly and in accordance with the
above, the Board of Directors of the Com-
pany consists of:
✔ 2/11 (18.18%) executive members
✔ 5/11 (45.45%) non-executive members
✔ 4/11 (36.36%) independent, non-exec-
utive members
✔ 3/11 (27.27%) women (fulfilling the re-
quirements of Article 3, of L.4706/2020,
for adequate representation per gen-
der in the Board of Directors).
It is pointed out that the current composi-
tion of the Board of Directors is fully har-
monized with the requirements, criteria
and regulations of the new law 4706/2020
on corporate governance.
Furthermore, the composition of the Board
of Directors of the Company fully covers
the proper and effective exercise of its du-
ties and responsibilities, reflects the size,
organization and type of operation of the
Company, achieves adequate staffing of
both existing and new Committees insti-
tuted to strengthen the supervisory role of
the Board of Directors, and is distinguished
for the diversity of knowledge, skills, quali-
fications and experience, elements which
can contribute decisively to the promotion
and achievement of business goals, plans
and the implementation of the Company’s
business strategy.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 199 of 370
Description of the suitability and
diversity policy with regard to the
administrative bodies of the Company
Given the fact that the Board of Directors
is the highest administrative body of the
Company, which is responsible for the
safeguarding of the general corporate in-
terest, the policy making and the growth
strategy of the Company as well as for the
strengthening of the long-term economic
value of the Company, it is very essential
for the particular body to possess, with re-
gard to its composition, a diversity of skills,
views and abilities which at the same time
respond to the need to effectively attain
corporate goals.
The Company has a Suitability Policy for
the members of the Board of Directors,
which is approved by its Board of Direc-
tors and includes at least the provision of
diversity criteria for the selection of the
members of the Board of Directors. The di-
versity policy applies both to the members
of the Board of Directors as well as to the
Executive Directors.
The Suitability Policy, which was approved
by the Annual Ordinary General Meeting
of Shareholders on May 24, 2023, is posted
on the Company’s website https://www.
thracegroup.com/ while its scope includes
the members of the Board of Directors (ex-
ecutive, non-executive, independent non-
executive) as well as the members of the
Board Committees.
The Suitability Policy aims to support
the Company’s interests, ensuring qual-
ity staffing, efficient operation, and fulfill-
ment of the role of the Board of Directors,
as a collective body.
Ι. Individual Suitability
Specifically, individual suitability is as-
sessed based on the following criteria:
Guarantees of Ethics and Reputation
- Good Reputation (Reliability and Integ-
rity, Consistency, Personal Weight)
Conflicts of Interest
- Financial interests / incentives
- Personal or professional relationships
with members of the Company
- Personal or professional relationships
with related external stakeholders (e.g.
connection with important suppliers,
consultants, etc.)
Availability of sufficient time
- Systematic participation in the Board of
Directors and Committees
- Limitation on the number of positions
held as members of the Board of Direc-
tors of listed companies, with a limit of
four (4) outside the Group
- Flexibility and adaptability to attending
special meetings
- Preparation and in-depth analysis of
topics
- Preparation of propositions and writing
presentations on Board of Directors top-
ics
In addition to the above requirements, the
criteria for individual suitability also in-
clude the following:
Adequacy of knowledge and skills/
abilities
- Teamwork and Collaboration: The abil-
ity to collaborate harmoniously, com-
plementary, actively communicating in
order to contribute to the Group's goals
achievement.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 200 of 370
Adequacy of knowledge and skills/
abilities
- Entrepreneurial thinking: Perception of
business risks and growth opportunities
that could create a competitive advan-
tage for the Group.
- Strategic thinking: Active participation in
the formulation of the Group's strategy
and monitoring of its implementation as
well as the possibility of evaluation and
active participation in the approval of
strategic plans
- Specialized know-how in specific areas
(e.g. Auditing or Accounting for the Au-
dit Committee members, environmental
issues, venture capital, and generally
pre-selected areas that need to be re-
viewed on a regular basis).
- Contribution to the sustainability im-
provement.
- Adoption of the corporate culture and
values of the Company.
- Understanding the legal framework and
corporate governance issues.
- Ability to recognize and focus on the
important factors that lead to the Com-
pany’s sustainability and prosperity.
- Innovation: The ability to think and see
things from a new and innovative per-
spective, identify and inform about new
technologies and market trends orient-
ed to the Group’s benefit.
- Flexibility and adaptability: The ability to
adapt and work effectively in a changing
environment.
Impartiality of judgment
- Objectivity, Courage, courage of dissent,
avoidance of "groupthink"
ΙΙ. Collective Suitability
Regarding the collective suitability, the
composition of the active BoD must en-
sure the effective management and bal-
anced decision-making, with members
who have complementary abilities and
skills and remain in full compliance with
the Company’s strategies. There are spe-
cific prerequisites, which are diversity,
multi-collectivity (representation from dif-
ferent fields of activity and accumulation
of a wide range of knowledge and skills),
adequate representation by gender as
stipulated by respective legislation, rep-
resentation without exclusion due to any
kind of discrimination (e.g. gender, race,
religion or belief, etc.), while at the same
time, all necessary actions are taken in
order Board of Directors members to be
able to actively and efficiently participate
in strategic planning, identify and man-
age risks and understand clearly and suf-
ficiently Corporate Governance issues and
related legislation, financial reports and
technology activities.
From the time of the Company’s establish-
ment and until today, the entire members
of the Board of Directors fulfill all necessary
conditions and have set the foundations in
order to be granted with the capacity of
the member of the Board of Directors. At
the same time, they are distinguished for
their high professional skills, outstanding
educational level, diverse knowledge, ca-
pabilities, extensive experiences, and their
organizational and administrative skills,
and at the same time they stand out for
their integrity and ethical character.
The members of the board of Directors
cover a broad range in terms of age ef-
fectively combining their dynamics and
experience (indicatively between 44 and
77 years old). The members, in their ma-
jority, are holders of graduate and post-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 201 of 370
graduate degrees of domestic as well as of
international universities, have worked in
high ranked positions of major companies
domestically and abroad, meaning com-
panies activating in a variety of business
sectors and they have served as Senior Ex-
ecutives of large organizations and as a re-
sult they possess significant international
experience in the corporate as well as the
broader social fields and are in position
to actively contribute to the growth pros-
pects of the Group in the geographical ar-
eas in which it activates. They finally fulfill
the requirements of suitability as well as
the criteria with regard to the Group’s ef-
fective staffing and operation.
The current composition of the Board of
Directors aims undoubtedly at the best
possible facilitation of corporate goals, as
it increases the pool of skills, experience,
and vision that the Company has for its
highest-ranking personnel, and conse-
quently its competitiveness, productivity
and innovation.
The current 11-member Board of Direc-
tors of the Company consists of eight (8)
men and three (3) women and was elected
in the framework of the decision of the
Company’s Management for immediate,
substantial and effective compliance and
harmonization with the provisions of the
new law 4706/2020 on corporate govern-
ance and in particular its provisions which
define suitability, diversity and, above all,
adequate representation by gender on
the Board of Directors. The presence of
three (3) women among the members of
the Board of Directors covers the statutory
percentage (25%) of adequate representa-
tion by gender (with rounding to the previ-
ous whole number, in case of a fraction, as
defined in Article 3, of Law 4706/20).
The Board of Directors
Members Gender/Age Education Nationality Independence
11
members
8
men
3
women
Specialization
10 Greek
1
Other
nationality
36.36%
Independent non-
executive members
44-77 years
The Company, in the context of the adop-
tion of the corporate governance best
practices provided by the new CCG, en-
sures the application of the diversity crite-
ria included in the current and approved
by the annual Ordinary General Meeting
of shareholders on May 24
th
, 2023, Suitabil-
ity Policy not only among the members of
its Board of Directors, but also to its senior
executives.
In particular, the Human Resources De-
partment, which aims to attract and re-
tain the appropriate human resources and
continuously increase its efficiency and
effectiveness through the implementa-
tion of modern procedures, policies and
practices of evaluation, recruitment, train-
ing and remuneration, ensures faithful and
strict application of the diversity criteria to
senior management, in order to ensure:
(a) the avoidance of outdated and
anachronistic social stereotypes in
the process of assessing the specific
qualifications and suitability of senior
management in general and
(b) the integration of innovative ap-
proaches and ideas into the selection
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 202 of 370
process of such executives.
The fundamental criteria of the intended
diversity regarding the selection and eval-
uation of senior executives are as follows:
✔ adequate gender representation of at
least 25%, to the extent, timing and
degree to which this criterion is appli-
cable and
✔ the prohibition of exclusion of a can-
didate for senior management, due to
different gender, race, color, ethnic or
social origin, religion or belief, prop-
erty, birth, disability, age or sexual
orientation.
More details regarding the diversity crite-
ria provided by the regulatory framework
are presented in the Sustainability Report
in Section S1-1 which is a special section of
the Board of Directors’ Management Re-
port of the 2024 Annual Financial Report.
The main criteria for selecting the top ex-
ecutives employed in the Company are the
adequacy of knowledge and skills, namely
the satisfactory background of theoretical
education and training, the appropriate
professional experience, the guarantees
of ethics and reputation, the integrity and
objectivity and the general skills and abili-
ties of the candidate as well as the knowl-
edge of the business model, culture and
more specific principles of the Company,
in order to form a diverse team of senior
executives with a sufficient degree of dif-
ferentiation, which will be able to take full
advantage of market opportunities and ef-
fectively manage the risks encountered or
potentially faced by the Company during
the development of its activities.
The condensed CVs of the Company’s
Board members are as follows:
Konstantinos Chalioris,
Chairman of the Board of Directors,
Executive Member
He possesses a professional experience of
44 years during which he has developed a
strong understanding of the industry and
the international market. Since 2009, he
holds the position of the Chairman of the
Board of Directors. Following the decision
of the Board of Directors as of July 28, 2021,
the date on which the Board of Directors
of the Company was reconstituted, Mr.
Chalioris remained Chairman of the Board
of Directors of the Company, while by a
previous decision of the Board of Directors
as of October 14, 2020 he assumed the po-
sition of Chief Entrepreneur. The specific
position, which was added to the organi-
zational chart of the Group aims to ensure
the continuation of the profitable growth
of the Group in areas that fall both in the
existing activities of the Group and in new
beneficial activities in the future. The crea-
tion of this position and its assumption by
Mr. Chalioris, who has a significant career
and valuable experience in “entrepreneur-
ship”, will ensure the future development
of the Group.
Georgios Samothrakis,
Vice-Chairman of the Board of Directors,
Independent Non-Executive Board
Member
He is a graduate of the Athens University
of Economics and Business (ASOEE) and a
former Chartered Public Accountant. He
specializes in tax issues and tax strategy of
Greek and multinational companies, while
has been extensively involved in regular
and extraordinary audits of commercial
and industrial enterprises. He began his ca-
reer in 1965 at the National Bank of Greece
and in 1972 moved to Coopers & Lybrand
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 203 of 370
(now PwC) to set up the Tax Services de-
partment where he remained head until
2006. For a number of years, he was also
Chairman of the Board of PwC. From 2007
to 2019 he was shareholder and chairman
of AS Network, an audit, accounting and
tax services group. He has been a consult-
ant of the Supervisory Board of the Body
of Chartered Public Accountants (SOEL),
where he was a member from 1993 until
2022. He has been actively involved in the
formation of the audit - accounting institu-
tional framework in Greece. He has been
President of the Fédération des Experts
Comptables Méditerranéens, President of
the Hellenic Institute of Economic Man-
agement (IOD), Member of Committees
of the Ministry of Economy and Finance
for the implementation of IFRS in Greece,
the simplification of the Greek Code of Ac-
counting Books and Records as well as the
integration of the new 8
th
Directive and
also a Member of the Corporate Govern-
ance Committee of the Hellenic-American
Chamber of Commerce. During the last
years he has also been the Chairman of the
Company’s Audit Committee.
Dimitrios Malamos,
Chief Executive Officer, Executive
Member
He graduated from the Athens College in
1993. He studied in Great Britain from 1993
to 1998. He holds a BA (Hons) in Business
and Financial Economics from Stafford-
shire University and a postgraduate ΜΒΑ
degree from University of Kent in Can-
terbury. From 2000 to 2007 he worked in
PricewaterhouseCoopers in the area of
Management Consulting servicing com-
panies of the private and public sector
where he gained significant experience in
the fields of budgeting and reporting, fi-
nancial analysis and internal restructuring.
During the period 2007-2009 he worked in
National Bank of Greece in the Account-
ing & Finance division and he returned
to PricewaterhouseCoopers in the area of
Management Consulting. From June 2010
to March 2020, he worked at Thrace Group
as Group CFO. From March 2020, Mr. Mala-
mos assumed the role of Deputy Group
CEO, while from October of the same year
he holds the position of CEO of the Com-
pany and the Group (Group CEO).
Theodoros Kitsos,
Non-Executive Member
He holds a BSc degree from the Economics
Department of the National and Kapodis-
trian University of Athens and an MBA de-
gree in finance from the Wagner College
of USA. He started his career in Unilever
Hellas and worked successfully in other
companies of the Group located abroad
and especially in the United Arab Emirates,
Saudi Arabia and the Netherlands. He re-
turned to Greece in 2005 where he worked
as General Manager of Human Resources
and Organization at PPC (DEI) SA. In a lat-
er stage he held the position of Deputy
General Manager of Human Resources at
Eurobank Group. By the end of the year
2007, he returned to Unilever Group based
in London undertaking the duties with re-
gard to the global organizational planning
of the Company, whereas in year 2010 he
moved to Unilever Russia, Ukraine and Be-
larus based in Moscow where he held the
position of Vice President responsible for
issues of human resources and organiza-
tion, implementing successfully the ac-
quisitions and mergers of three compa-
nies active in the production and trading
of consumer products. Since the summer
of 2015, he worked at the headquarters
of Unilever in London having assumed a
multitude of responsibilities in the areas
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 204 of 370
of Finance, Law, Technology and Support
Services on global level, up until 2020,
when he completed his collaboration.
Since 2016, he has been a member of the
Boards of Directors of various companies
in Greece.
Vasileios Zairopoulos,
Non-Executive Member
He began his career in 1983 in the apparel
and footwear sector. Soon he assumed
the position of Director of Design and Col-
lection for a leading Company in the kids
apparel market. His responsibilities were
further expanded to include planning and
coordinating production. Subsequently,
he moved into business development,
specifically focusing on expanding a large
retail store chain. In addition to these du-
ties, he assumed overall supervision of re-
tail activities, including store planning, or-
dering and replenishment, management
of the internal marketing and sales team,
budgeting, and forecasting. Before depart-
ing to establish his own consulting firm, he
engaged in a wide range of activities, such
as strategy, negotiations, marketing man-
agement, corporate budgeting, and finan-
cial planning. Over the past decade, Mr.
Zairopoulos has operated his own consult-
ing firm, providing consultancy services in
areas such as strategy, start-up ventures,
business planning, investment evaluation
and financing, international negotiations,
pricing and communication. In addition to
domestic companies, Mr. Zairopoulos has
collaborated with two American multina-
tional companies, Columbia Sportswear
and New Balance. He received an IB Diplo-
ma in 1979 from UWC Atlantic College and
a BSc in Management from Bath University
in 1983.
Christos Shiatis,
Non-Executive Member
He is an Associate Member of the Fellows
of Chartered Accountants of England and
Wales, a Chartered Public Accountant by
the Cyprus Institute of Chartered Account-
ants and Member of the Hellenic Associa-
tion of Chartered Accountants (SOEL). He
began his professional career in 1981 at
the auditing firm Kostouris - Michailidis
(Grant Thornton) in Athens. In 1993 he be-
came Managing Partner of the Greek Com-
pany and in 1997 he assumed the position
of Territory Senior Partner at the Company
that resulted from the merger of Kostouris-
Michailidis and Coopers & Lybrand. In
1998 he was elected Chairman and Chief
Executive Officer of the Company Price-
waterhouseCoopers in Greece. Alongside
his management duties in the above au-
dit firms, Mr. Shiatis has been active in the
field of consulting, providing services to
the senior management of large firms.
Athanasios Dimiou,
Non-Executive Member
He graduated from the School of Chemi-
cal Engineering of the Aristotle University
of Thessaloniki in 1986. From 1989 to 1996
he worked at the companies PLASTIKA
MAKEDONIAS SA and AG.PETZETAKIS, ini-
tially in the field of Quality Control and the
development of new products and then
his duties expanded by moving in the po-
sition of Technical Director and Director of
Technical Services. From 1996 to 1998 he
assumed the position of Plant Manager
in the shoe manufacturer trading Com-
pany MOURIADIS SA, a Company listed on
the Athens Exchange and since 1998 he
worked as Plant Manager of THRAPLAST
SA which mainly produces flexible pack-
aging products made of polyethylene
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 205 of 370
(current Thrace Polyfilms).
In 2000 he started in PLASTIKA THRAKIS
SA as a Production Manager at the group’s
facilities in Xanthi and in 2004 he took over
the duties of Plant Manager in the facilities
of Magiko complex in Xanthi, a position he
held until 2010. Since then, he has been
the Managing Director THRACE NONOWO-
VENS & GEOSYNTHETICS SA. At the same
time, he remains an active member of the
Technical Chamber of Greece (TCG), while
in the past he was a member of the Hellenic
Company of Business Administration and
the Institute of Production Management.
Stylianos Vitogiannis, ,
Non-Executive Member
Stylianos Vitogiannis completed his stud-
ies at Zanneio Experimental High School
of Piraeus (1996) and holds a degree in
economics from the University of York
(2000). He has dedicated his entire career
to the international development of the
family business Astir-Vitogiannis Bros. S.A.,
which has existed since 1955 and produces
metal caps for glass bottles of beer and
soft drinks. He joined the company since
2002 and immersed in all levels of the
production process, quickly acquires full
training in the know-how of the subject,
while in 2007, at a young age, he assumes
the duties of Vice President and General
Manager. With his catalytic interventions
in the modernization of mechanical equip-
ment, in the full automation of the produc-
tion process, in the insistence on absolute
qualitative superiority of the products pro-
duced, but also with a very well-designed
extroverted commercial strategy, he de-
veloped the family business into one of
the most recognizable companies interna-
tionally, ranking Astir-Vitogiannis Bros. S.A.
among the largest export industries of our
homeland. He has achieved double-digit
growth and profitability rates for many
consecutive years, attracting the interest
of leading multinational groups and fi-
nancial corporations. During his career, he
has successfully completed mergers and
acquisitions in Greece and abroad, part-
nerships with multinational groups of a
strategic nature, as well as their join in the
Athens Stock Exchange. Astir-Vitogiannis
Bros. S.A. exports over 90% of its annual
production capacity to multinational beer
and soft drink bottling groups, to over 70
countries, on all continents and has creat-
ed a production capacity of over 24 billion
caps per year. It has established a fully or-
ganized sales and representation network
from New Zealand to California, having in
the meantime developed new production
units in Canada, Mozambique, Egypt, and
South Africa.
Myrto Papathanou,
Independent Non-Executive Member
She studied Economics at the City Univer-
sity of London and holds a Master’s De-
gree in Economics from the Imperial Col-
lege Management School in London and
an MBA from the INSEAD Business School.
She began her financial career in London,
initially working as a Credit Risk Analyst for
Dresdner Kleinwort Wasserstein and later
as a Fixed Income Strategist for Bank of
America/Merrill Lynch. Upon returning to
Greece, she took on the role of Business
Development Manager at CPI and, since
2011, developed her own entrepreneur-
ial activities in technology as a consult-
ant and investor. From 2014 to 2018, she
served as the Chief Financial Officer and
Head of Corporate Development for the
EFA Group, which operates in Aerospace &
Defense and other high-tech sectors.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 206 of 370
In 2018, she co-founded the venture capi-
tal fund Metavallon Venture Capital, aim-
ing to invest institutional and private funds
in technology startups originating from
Greece and the diaspora. Metavallon VC
manages over €50 million, has completed
35 early-stage investments, and continues
its investment activities through Fund II.
Through Metavallon, she has served as a
board member for Think Silicon S.A and
Langaware Inc. Currently, she serves on
the boards of Ferryhopper S.A, Advantis
Medical Imaging BV, Better Origin Ltd, and
Workearly Ltd, which are active in the sec-
tors of ferry transportation, health tech-
nologies, biotechnology, and technologi-
cal education, respectively.
She is the first investor from Greece to
emerge as Kauffman Fellow (Silicon Valley),
a network that selects the best investors in
the world. She is on Fortune Greece’s list of
the 40 entrepreneurs who innovated and
excelled for 2020. She received the Leader
of the Year award from Linkage Greece
in 2016 in recognition of its outstanding
leadership ability and contribution to busi-
ness and society development.
Since 2005, she has been actively involved
in the nonprofit sector, supporting initia-
tives aimed at fostering civic engagement,
promoting economic inclusion for vulner-
able groups, and empowering women. In
Greece, she co-founded Ethelon in 2012
and secured funding for the microfinance
organization Action Finance Initiative,
where she serves as an Independent Non-
Executive Board Member. Additionally, she
participates in the Advisory Committees
of organizations such as WomenOnTop,
La French Tech, and the INSEAD Alumni
Association.
Fotini-Marina Niforos,
Independent Non-Executive Member
Fotini-Marina Niforos is an experienced
Board member, academic and strategic
advisor specializing in advanced technol-
ogy and sustainability. She is an Affiliate
Professor at HEC business school and the
founder and President of the Climate Gov-
ernance Initiative Greece, part of the glob-
al network of Directors’ associations under
the World Economic Forum (WEF) leading
actions on climate change.
A world-recognized expert on Blockchain
technology and sustainable development,
she is a member of the EU Blockchain Ob-
servatory, the lead author of the IFC-World
Bank report on Blockchain: Opportunities
for Private Enterprises in Emerging Mar-
kets, and a frequent contributor in media
(Bloomberg, FT, CoinDesk and others). She
serves as Expert jury member for the Eu-
ropean Innovation Council Accelerator, the
mechanism providing blended finance for
the scale up of European startups in deep
tech. EU Startups named Fotini-Marina
“one of five female leaders driving change
in the European blockchain ecosystem”.
Ms Niforos has served Board mandates
in both public and private companies, as
well as in non-governmental organiza-
tions, including the NGOs: the Growth-
Fund-The National Fund of Greece, the
sovereign fund of the Hellenic Republic,
Séché Environnement, a Euronext-listed
company in waste management, the Eu-
ropean Network of Women in Leadership
and the US National Commission for UN-
ESCO (appointed in 2012 by Secretary of
State H. Clinton). She is currently on the
Advisory Board of Urban Impact Fund, a
Dutch impact VC firm focusing on urban
technology.
In the past, Fotini-Marina served as CEO
of the American Chamber of Commerce
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 207 of 370
of France, Director for the Diversity Center
of Excellence at INSEAD and held senior
posts in the Pechiney Group, in corporate
venturing and corporate strategy. From
1993 to 1998, she was with the World Bank
Group, managing the country strategy and
investment portfolio for Latin American
countries. She received the World Bank
Award for Excellence by President Wolfen-
sohn for assisting Colombia with its sover-
eign debt conversion.
Ms. Niforos earned an IDP-C and an MBA
from INSEAD, a Masters in Government
Administration from the University of
Pennsylvania and a Diploma in Interna-
tional Relations from The Paul H. Nitze
School of Advanced International Studies-
Johns Hopkins University. She graduated
Phi Beta Kappa honors from Cornell Uni-
versity, with a B.A. in Government and In-
ternational Relations. She is fluent in Eng-
lish, Spanish, French, Greek and proficient
in Italian.
Eleni Providi,
Independent Non-Executive Member
Eleni Providi is a lawyer in Athens and
holds the position of VP Legal & Public Af-
fairs, Head of Corporate Communication,
Quality & Sustainability of AB Vassilopou-
los, which she joined in 2001. In 2002 she
was promoted to Head of Legal Depart-
ment and in 2010 she joined the Executive
Committee. From 2011 to 2014 she held
the position of VP Legal Affairs for South-
eastern Europe, being in charge of Greece,
Albania, Bulgaria, Serbia and Romania.
She took over Public Affairs in 2019 and by
2022 she also assumed leadership of PR/
Corporate Communication, Quality Assur-
ance and Sustainability. On January 2022
she has been elected member of the BoD
of the company and since November 2023
she holds the position of Chairman of the
BoD. She graduated from the Law School
of the University of Athens and holds a
Master Degree in Corporate Law from the
University of Heidelberg, Germany.
The condensed CVs of the top execu-
tives of the Company are as follows:
Dimitris Fragkou,
Group Chief Financial Officer (CFO) &
Secretary of the Board of Directors of
the Company
He studied Business Administration at the
Athens University of Economics and Busi-
ness (AUEB), from which he graduated in
2002. From 2006 to 2008, he studied Ac-
counting and Finance (specializing in Fi-
nance), obtaining a Master’s Degree from
the Athens University of Economics and
Business (AUEB). He is also a Certified Pub-
lic Accountant, as he became a member in
2012 of the Association of Chartered Cer-
tified Accountants - ACCA. He started his
professional career, for a short period of
time from shipping banking, while at the
end of 2003 he joined PwC. At PwC, he
worked in the Consulting Division, gain-
ing significant experience in the areas of
budgeting, financial information, financial
analysis, process optimization, transition
to new integrated information systems
and treasury operations. In 2014, he joined
the Department of Business Process Out-
sourcing, gaining experience in account-
ing procedures, tax compliance and finan-
cial reporting to the Authorities (statutory
reporting). He has worked for a number of
listed and private companies in the con-
struction, energy, shipping and industrial
sectors. From March 2020, he joined Thra-
ce Group as Chief Financial Officer.
Christina Diamanti,
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 208 of 370
Group Chief People Officer
She studied Business Administration at the
Athens University of Economics and Busi-
ness (AUEB), from which she graduated in
2001 and in 2005 she obtained a Master’s
degree specializing in Human Resource
Management from the Athens University
of Economics and Business (AUEB). Since
2000, she worked in the Human Resources
departments of a multinational food Com-
pany in Greece and the Middle East, and
also in commercial offices and production
units as well as in the regional offices of
Switzerland, where she gained significant
experience in the management of human
resources practices, organizational struc-
ture planning and change management.
In her last position, she was responsible
for the management of foreign markets,
such as the Nordic countries, Spain and
Eastern Europe. She has long experience in
team building and leadership coaching. As
of September 2022 she has joined Thrace
Group as Group HR Director.
Ioannis Sideris,
Chief Sustainability Officer
Ioannis Sideris currently holds the position
of Group Sustainability Officer at Thrace
Group. He has significant experience and
active involvement in the fields of sustain-
able development, climate change, and
circular economy since he has served as
the CEO of the Hellenic Recycling Agency
(EOAN) and the Deputy Mayor of the Envi-
ronment in the Municipality of Agia Parask-
evi. Additionally, he worked as an IT Con-
sultant at the multinational corporation
PwC. Throughout his career, he undertook
several responsibilities, including serving
as the Chairman of the Expert Committee
of the General Secretariat of Commerce,
a member of the BoD of the Public Real
Estate Company and the Association of
Sustainable Urban Development. He has
also contributed as a researcher at the
ELTRUN research center and has extensive
experience as a publisher. He is a graduate
of the Athens University of Economics and
Business with a specialization in Business
Administration and holds a master’s de-
gree in Information Systems Development
from the London School of Economics.
Lambros Apostolopoulos,
Head of Internal Audit Unit
He is a graduate of Varvakeio High School,
a graduate of the Department of Busi-
ness Administration and Management of
the Athens University of Economics and
Business (BSc) and holds a Master’s De-
gree in Finance & Business Economics
from the University of Portsmouth (MSc).
He has worked in large corporate groups
in Greece and abroad, while he has many
years of experience in internal audit and is
a certified Internal Auditor (CIA).
Michail Psarros,
Risk and Compliance Manager
He is a graduate of the Department of
Mathematics of the University of Patras
and holds a Master’s Degree in Finance
from the University of Leicester. He also
holds professional certifications as Com-
pliance Officer from TUV Austria and Risk
Management certification from the Na-
tional and Kapodistrian University of Ath-
ens. He started his professional career, for a
short period of time as an Internal Auditor
in a Company in the financial sector, while
from May 2000 he worked in the Inter-
nal Audit Department of the K. Philippou
Group of Companies. Then, in November
2005 he moved to the group Lafarge Ce-
ment / AGET IRAKLIS, where he worked
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 209 of 370
in the Internal Audit Department until
December 2010, when he joined Thrace
Group as Group Internal Auditor. During
the 21 years of his employment in the In-
ternal Audit Departments in the above
industrial groups, he has gained extensive
experience in the fields of Internal Audit,
internal control systems, risk & compliance
management.
From February 2022, Mr. Psarros took over
duties as Risk and Compliance Manager.
The following table shows the number of shares held by those who were members
of the Board of Directors and seniors executives of the Company during 2024, at
31/12/2024 as well as at the preparation time of the present Report:
BoD members
Number of shares held
directly
Percentage of
shareholding
Konstantinos Chalioris 18,936,558 43.3%
Theodoros Kitsos - 0%
Christos-Alexis Komninos 25,000 0.1%
Dimitris Malamos - 0%
Nikitas Glykas - 0%
Athanasios Dimiou - 0%
Vasileios Zairopoulos 189,223 0.4%
Spyridoula Maltezou - 0%
Myrto Papathanou - 0%
Georgios Samothrakis 27,000 0.1%
Christos Shiatis 60,000 0.1%
Eleni Providi
-
0%
Foteini Marina Niforos
-
0%
Stylianos Vytogiannis
-
0%
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 210 of 370
The following table presents the compa-
nies in which the members of the Compa-
ny’s Board of Directors participated, both
within and outside the Group, during the
year 2024, on 31.12.2024, as well as at the
time of preparation of the present Report.
The table includes the percentage of par-
ticipation and the capacity of the mem-
bers of Board of Directors:
Senior Management & Members
of Audit Committee (non
Members of BoD)
Number of shares held
directly
Percentage of
shareholding
Dimitrios Fragkou - 0%
Christina Diamanti - 0%
Ioannis Sideris 40,000 0.1%
Lambros Apostolopoulos - 0%
Michail Psarros - 0%
Konstantinos Kotsilinis, Member of
the Audit Committee
- 0%
Sophia Manesi, Member of the
Audit Committee
- 0%
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 211 of 370
BoD members
Companies in which the BoD
members participate
Group Companies in which the
BoD members participate
Equity
shareholding
Position
Konstantinos
Chalioris
Civil non-Profit Company
Stavros Chalioris
50% Vice-Chairman of BoD
Xanthi
Photovoltaic Park S.A.
50%
Chairman & Chief
Executive Officer
EYTERPI S.A. -
Chairman & Chief
Executive Officer
ERATO S.A 50%
Chairman & Chief
Executive Officer
THALEIA S.A. 50%
Chairman & Chief
Executive Officer
KLEIO TECHNICAL TOURISM
COMMERCIA S.A.
Chairman & Chief
Executive Officer
AVDIRA MCPY 99% Chairman of BoD
THRACE YAGHTING SMPC 66% Partner & Administrator
THRACE LABEA SMPC 50% Partner
THRACE NONWOVENS &
GEOSYNTHETICS SA
Chairman of BoD
DON & LOW LTD Member of BoD
ARNO LTD Chairman of BoD
THRACE PLASTICS PACK SA 4,71% Chairman of BoD
SYNTHETIC HOLDINGS LTD Chairman of BoD
THRACE SYNTHETIC PACK
-
AGING LTD
Member of BoD
THRACE GREENHOUSES SA
Chairman of BoD &
Managing Director
TRIERINA TRADING LTD Director
THRACE IPOMA AD Chairman of BoD
THRACE POLYBULK AB Chairman of BoD
THRACE POLYBULK AS Chairman of BoD
LUMITE INC Member of BoD
SYNTHETIC TEXTILES LTD Director
THRACE POLYFILMS SA Chairman of BoD
Theodoros
Kitsos
AMALTHEA SMPC 35%
Minority Shareholder
Member of BoD
COLLEGE LINK PRIVATE
COMPANY
2,1% Minority Shareholder
PROVIL S.A.
Member of BoD
Hellenic Tech Investor
Club (THETI CLUB)
Member of BoD
Health Care Group of
Companies BIOIATRIKI
Member of BoD
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 212 of 370
BoD members
Companies in which the BoD
members participate
Group Companies in which the
BoD members participate
Equity
shareholding
Position
Christos Alexis
Komninos
T.K.K. CONSULTANTS LTD 100% Director
ELVAL – HALCOR S.A. Member of BoD
Dimitrios
Malamos
DYNAMIC CONSTRUC
TIONS  V. ZARIFOPOU
LOS S.A.
Chairman of BoD
IOANNIS FILIPPAIOS S.A. Member of BoD
ΖΙΤΑ MCPY 1% Vice Chairman of BoD
THRACE GREENHOUSES SA
Member of BoD
THRACE POLYBULK AS Member of BoD
THRACE SYNTHETIC
PACKAGING LTD
Member of BoD
THRACE IPOMA AD Member of BoD
THRACE NONWOVENS &
GEOSYNTHETICS SA
Vice-Chairman of BoD
DON & LOW LTD MEMBER OF BOD
THRACE PLASTICS
PACK SA
Vice-Chairman of BoD
LUMITE INC Member of BoD
THRACE POLYBULK AB Member of BoD
THRACE LINQ INC Chairman of BoD
THRACE POLYFILMS SA Vice-Chairman of BoD
THRACE EUROBENT SA Member of BoD
SAEPE LTD Director
ADFIRMATE LTD Director
PAREEN LTD Director
Nikitas Glykas
PPC S.A.
Member of the Audit
Committee
LUXURY HOUSES IN
ATHENS MARIETTA SMPC
50% Partner
Athanasios
Dimiou
AVDIRA MCPY Vice-Chairman of BoD
CIVIL NONPROFIT
COMPANY STAVROS
CHALIORIS
Vice-Chairman of BoD
THRACE POLYFILMS SA Member of BoD
THRACE NONWOVENS &
GEOSYNTHETICS SA
Managing Director &
Member of BoD
THRACE EUROBENT SA Vice-Chairman of BoD
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 213 of 370
BoD members
Companies in which the BoD
members participate
Group Companies in which the
BoD members participate
Equity
shareholding
Position
Vasileios
Zairopoulos
V. ZAIROPOULOS & SIA LP
90%
Partner &
Administrator
ΖΙΤΑ MCPY 99% Chairman of BoD
DON & LOW LTD Chairman of BoD
SYNTHETIC HOLDINGS
LTD
Director
SYNTHETIC TEXTILES LTD Director
THRACE EUROBENT SA Member of BoD
Spyridoula
Maltezou
SUSTAIM LP 95%
Partner &
Administrator
Myrto
Papathanou
GOMMYR POWER NET-
WORKS LTD
30% Member of BoD
GOMMYR POWER SMPC 30% Partner
BANSARA TRADING LTD 30% Partner
METAFOUNDER UNIT
HOLDER SMPC
25% Partner
KARYON AGRICULTURE
SMPC
25% Partner
ENTOMICS BIOSYSTEMS
LTD
Member of BoD
FERRYHOPPER SA Member of BoD
ADVANTIS HOLDING BV Member of BoD
METAVALLON PARTNERS
AEDAKES
25%
Partner and
Member of BoD
WORKEARLY LTD
Member of BoD
ACTIVE FINANCE INITIA-
TIVE
Member of BoD
Georgios
Samothrakis
FRIGOGLASS SA
Member of BoD
Chairman of the Audit
Committee
BOARD OF CHARTERED
AUDITORS
Advisor to the
Supervisory Board
Christos Shiatis
AVAX INTERNATIONAL
LTD
Director
J&P AVAX SA
Member of BoD
Chairman of the Audit
Committee
C.P.S. FINANCIAL SOLU
TIONS LTD
99% Director
TROLID HOLDINGS LTD Director
EOTATI REAL ESTATES LTD Director
EOLACK LTD Director
TRIERINA TRADING LTD Director
Eleni Providi
Alfa Beta Vasilopoulos
Single Person S.A.
Vice-Chairman of
BoD
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 214 of 370
It is noted that none of the members of the
Board of Directors of the Company partici-
pates in the Boards of Directors of more
than five (5) listed companies.
Framework for the Management of the
Company’s Transactions with Related
Parties
The Company has adopted and imple-
ments a Framework for the Management
of its Transactions with Related Parties,
which includes the overall policy govern-
ing and the process regulating the trans-
actions with Related Parties and which has
been approved by a decision of the Board
of Directors in compliance with the obliga-
tions arising from the applicable legisla-
tive and regulatory framework. In addition
to the Framework for the Management of
its Related Party Transactions, the Compa-
ny has also adopted a Conflict-of-Interest
Management Framework, which is addi-
tionally implemented.
The policies that ensure that the Board
of Directors has sufficient information to
base its decisions regarding transactions
between related parties including the
transactions of its subsidiaries with related
parties are:
A. To define the responsibilities of
the Company and the roles of its
Divisions in the Management of
Transactions with Related Parties
In order to ensure the transparency and
proper management of the Company’s
Transactions with its related parties, the
Framework for the Management of the
transactions with Related Parties describes
the responsibilities of the Company and
provides for a clear allocation of roles be-
tween its divisions.
Specifically, the Company has undertaken
a series of actions related to the manage-
ment of transactions with Related Parties,
as follows:
• submits the Framework for the Man-
agement of its Transactions with Re-
lated Parties for approval by the Board
of Directors,
• ensures the revision of the content of
the Framework for the Management
of its transactions with Related Party,
where required,
• ensures in cooperation with the le-
gal advisors the legality of the indi-
vidual procedures, applies the criteria
mentioned in the Framework for the
Management of its transactions with
Related Parties and evaluates the af-
filiation of the transactions with Re-
lated Parties for approval by the Board
of Directors, taking into account the
BoD members
Companies in which the BoD
members participate
Group Companies in which the
BoD members participate
Equity
shareholding
Position
Foteini Marina
Niforos
CLIMATE GOVERNANCE
INITIATIVE GREECE
Chairman
URBAN IMPACT VENTURES
Shareholder &
Member of BoD
Stylianos
Vytogiannis
ASTIR Vytogiannis Bros.
Single Person S.A.
Chairman & Chief
Executive Officer
IDEAL HOLDINGS S.A.
(INTEK)
Shareholder
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 215 of 370
respective legal framework governing
these Transactions,
• takes into account the exceptions
mentioned as well as those defined by
the respective legislative framework,
• presents the information related to
the transactions with Related Parties,
pointing out the Company’s interest
for the financial advantage and the
correct application of the conditions
for the completion of the transaction,
taking into account the respective le-
gal and regulatory framework.
B. Define Related Parties
As “Related Parties” are defined the related
natural persons or legal entities included
in IAS 24, including the legal entities con-
trolled by those persons in accordance
with IAS 27.
The Group considers as related natural
persons the members of the Board of Di-
rectors, its Executive Officers, as well as the
shareholders holding more than 5% of its
share capital (including their related per-
sons). Additionally, it considers as related
companies the legal entities included in
IAS 24, including the legal entities con-
trolled by the aforementioned persons or
those over which significant influence is
exercised by natural persons controlling
the Company.
C. Locate the Related Parties
For the correct fulfillment of the legal and
regulatory obligations of the Company
and the effective implementation of the
Framework for the Management of its
Transactions with Related Parties, the trac-
ing and identification of the Related Par-
ties with the Company is carried out in the
following ways:
• taking into account the organizational
chart of the Company and the corpo-
rate hierarchy of the Group, as well as
the list of investments in other entities,
as they apply each time,
• receiving information from the Corpo-
rate Secretary of the Board of Directors
regarding changes of members of the
Board and / or its Committees,
• requesting from the Company’s exec-
utives, when assigning and perform-
ing their duties, to complete and sign
a declaration form listing their imme-
diate family members and third par-
ties not affiliated with the Company, in
which they hold or in which they exer-
cise control or joint control, as defined
in IAS 24. In this context, it is noted that
it is the responsibility of each manager
to immediately notify the Investor Re-
lations & Corporate Announcements
Department in the event of changes
to the details of its original statement.
The Investor Relations & Corporate An-
nouncements Department updates
the declaration forms on a regular ba-
sis.
D. To define the Transactions with
Related Parties
As “Transaction with Related Parties” is
defined any transfer of resources, services
or liabilities between Related Parties, in
which the Company is the one party and
its Related Party is the other, regardless
of the possible price agreed, and includes
any financial transaction, settlement or
contract.
Indicatively, and not restrictively, such
Transactions may include:
• the transfer of human resources, in-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 216 of 370
cluding their detachment,
• the signing of service contracts,
• signing receivables / debt manage-
ment contracts,
• the provision of guarantees or insur-
ances.
2) Responsibilities of the Board of
Directors
The Board of Directors is the administra-
tive body that decides on any action that
concerns the Company’s management,
the management of its assets and in gen-
eral anything that refers to promoting and
achieving its objective.
According to the Company’s Articles of As-
sociation:
• The Board of Directors is responsible
for the representation, administration
and unlimited management of cor-
porate affairs. It decides on any issue
that concerns the Company’s manage-
ment, the achievement of the Com-
pany objective and the management
of Company assets, including the issue
of ordinary and convertible bonds.
The only exceptions are the decisions
which, according to the provisions of
Law or the Articles of Association, as in
force from the Annual General Meet-
ing of May 24, 2023, are subject explic-
itly to the responsibility of the General
Meeting of shareholders.
• The Board of Directors may appoint,
for any time period and under any con-
ditions it deems necessary each time,
to exercise its representation and du-
ties in general, fully or partially to one
or more of its members or Managers
or Executives or other employees of
the Company or third parties or com-
mittees, defining however each time
their authority and the signatories that
bind the Company.
Specifically, the main responsibilities of
the Board of Directors (in the sense that
the relevant decision making requires the
prior approval of the Board of Directors
or, if necessary, ex post ratification by the
Board of Directors), should include:
• The representation, administration
and unlimited management of corpo-
rate affairs.
• The decision making for each decision
relating to the Company’s manage-
ment.
• The achievement of the corporate ob-
jective and management of corporate
assets including the issuance of ordi-
nary and convertible bonds. The only
exceptions are the decisions which, ac-
cording to the provisions of the Law or
the Articles of Association or any other
valid, binding and firm agreement, are
explicitly subject to the exclusive re-
sponsibility of the General Meeting of
Shareholders.
• The approval of the long-term strat-
egy and the operational objectives of
the Company and the Group
• The approval of the annual budget
and business plan, as well as the deci-
sion making on major capital expendi-
tures, acquisitions and divestments.
• The selection and, when necessary,
the replacement of the executive
management of the Company, as well
as the supervision of the plan of their
succession.
• The performance testing of the Senior
Management and the harmonization
of the remuneration of the executives
with the long-term interests of the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 217 of 370
Company and its shareholders.
• Ensuring the reliability of the financial
statements and data of the Company,
the financial information systems, the
Sustainability report and the data and
information disclosed to public, as well
as ensuring the sufficient and effective
operation of internal control system of
the Company.
• The vigilance regarding existing and
potential conflicts of interest of the
Company, on one side, and the Man-
agement, the members of the Board
of Directors or the major shareholders
on the other side, as well as the appro-
priate treatment of such conflicts. For
this purpose, the Board of Directors
has adopted a transactions monitor-
ing process.
• Ensuring the existence of an effective
process of regulatory compliance of
the Company.
• The responsibility for decision mak-
ing and monitoring the effectiveness
of the Company’s Corporate Govern-
ance system, including the decision-
making processes and the delegation
of authorities and duties to other em-
ployees.
• The formulation, dissemination and
application of the basic values and
principles governing the Company’s
relations with all parties, whose inter-
ests are linked to those of the Com-
pany.
• The observance of the law, the statute
and the legal decisions of the General
Assembly. They have to manage the
corporate affairs in order to promote
the corporate interest, to supervise
the execution of the decisions of the
Board of Directors and the General As-
sembly and to inform the other mem-
bers of the Board of Directors about
the corporate affairs.
• The definition and supervision of the
implementation of the corporate gov-
ernance system of provisions 1 to 24
of Law 4706/2020, the monitoring and
evaluation periodically every three (3)
financial years for its implementation
and effectiveness, taking the appropri-
ate actions for addressing deficiencies.
3) Operation of the Board of Directors
As regards to the operation of the Board
of Directors, the Company’s Articles of As-
sociation and the Internal Operation Rule-
book state the following:
Formation of the Board of Directors as a
body
• The Board of Directors, as soon as it is
elected and specifically during its first
meeting, elects from its members and
for the entire period of its term, a Vice-
Chairman and a Chairman, whereas if
the Chairman is absent or unable the
Vice-Chairman substitutes such, and if
the latter is absent or unable then the
Director that is appointed by means
of a decision by the Board of Directors
substitutes such.
• The Chairman of the Board of Direc-
tors presides over the Board meetings,
manages its activities and informs the
Board of Directors on the Company’s
operation.
• The Board of Directors may elect one
of its members as Chief Executive Of-
ficer or Executive Director, it may ap-
point responsibilities of the CEO to
the Chairman or Vice-Chairman of the
Board and it may elect the deputy CEO
or Executive Director from its mem-
bers.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 218 of 370
• The responsibilities of the CEO are de-
fined by means of a decision by the
Board.
Decision Making
• The Board of Directors is considered to
be in quorum and meets validly, given
that half (1/2) plus one (1) member are
present or represented at the meet-
ing. However, the number of members
participating in person or represented
cannot be less than three (3) in any
case. To calculate quorum, possible
fractions are omitted.
• The decisions of the Board of Direc-
tors are taken by an absolute majority
of the present and represented mem-
bers.
Representation of Board of Directors
A Board member that is absent may be rep-
resented by another member. Each Board
member may represent only one absent
member, with a written authorization.
Minutes of the Board of Directors
• Copies or excerpts of the Board of Di-
rectors’ Minutes are certified by the
Chairman or his/her legal representa-
tive or by a member of the Board of
Directors that has specifically been
authorized by a decision of the Board
of Directors.
• The preparation and signing of min-
utes by all Board members or their
representative constitutes a deci-
sion by the Board of Directors, even
if a meeting has not previously taken
place. This arrangement applies if all
the members or their representatives
agree to make a majority decision in
minutes without a meeting. The rel-
evant minutes are signed by all the
members.
• The signatures of the members or their
representatives can be exchanged by
e-mail or other electronic means.
Remuneration of Board of Directors
• The members of the Board of Direc-
tors may receive remuneration for
each participation at Board meetings
in person or through teleconference,
only if such is approved with a spe-
cial decision by the Ordinary General
Meeting.
• The members of the Board of Direc-
tors receive the fixed and variable re-
muneration as well as the other ben-
efits, fees and indemnities specified in
the Company’s current Remuneration
Policy. The fees of the members of the
Board of Directors may also consist of
a share in the profits of the year, in ac-
cordance with the provisions of Law
4548/2018. It is pointed out that by
virtue of the decision of the Ordinary
General Meeting of the Company’s
shareholders of May 24, 2023, para-
graph 2 of article 15 of the Company’s
Articles of Association was amended,
pursuant to which it was stipulated
that the fees of the members of the
Board of Directors, senior executives,
as they are defined and specified in
detail in the approved and applicable
Remuneration Policy, general manag-
ers and their deputies, as well as ad-
ministrative executives, in accordance
with their definition in International
Accounting Standard 24 par. 9, may
also consist of a share in the profits,
in accordance with the current provi-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 219 of 370
sions of Law 4548/2018.
• A fee or benefit granted to a member
of the Board of Directors that is not
regulated by law or the Statute in ef-
fect, shall be borne by the Company
only if approved by a special decision
of the General Meeting.
Remuneration Report
The Company has established and imple-
ments a Remuneration Policy, the purpose
of which is to ensure that the members of
the Board of Directors and its Committees
are remunerated based on its short-term
and long-term business plan, in order to
achieve profitable organic growth through
capacity increase, geographic expansion
and value capture as per the Company’s
strategic plan.
The current Remuneration Policy of the
Company was approved by the Annual Or-
dinary General Meeting of shareholders of
May 24, 2023, and its validity period is four
(4) years and is available on the Company’s
website https://www.thracegroup.com/
The Remuneration Report has been pre-
pared in accordance with the provisions
of article 112 of Law 4548/2018, in line with
the Guidelines of March 1, 2019, of the Eu-
ropean Commission regarding the presen-
tation of the Remuneration Report in ac-
cordance with Directive 2007/36/EC, as has
been amended by Directive (EU) 2017/828
on Shareholders’ rights. It provides an
overview of the remuneration model of
THRACE PLASTICS CO SA, as it reflects the
total remuneration of the members of the
Board of Directors, explaining the way
in which the Remuneration Policy of the
Company was implemented for the finan-
cial year 2023.
The total remuneration paid to the mem-
bers of the Board and Committees dur-
ing fiscal year 2024 (01.01.2024-31.12.2024)
is included in the Remuneration Report,
which is available on the Company’s web-
site https://www.thracegroup.com/ just be-
fore the Annual Ordinary General Meeting
of shareholders.
4) Board of Directors’ Meetings
• The Board of Directors meets at the
Company’s headquarters whenever
the Law or the Company’s Articles of
Association or its needs require so,
convened by the Chairman or his / her
deputy with an invitation to be com-
municated to members at least two (2)
working days prior to the meeting. The
Board of Directors may also meet out-
side the Company’s registered office,
but in this particular case such notice
must be communicated to its mem-
bers at least five (5) working days prior
to the meeting.
• The Board of Directors may convene
through teleconference for certain of
its members or for all of them. In this
case, the invitation towards Board
members includes all necessary infor-
mation and technical instructions for
their participation in the meeting.
• The Board meetings are presided by
the Chairman or upon absence or any
other hindrance by his/her substitute
according to the Articles of Associa-
tion.
During the closing financial year 2024
(01.01.2024-31.12.2024), 30 meetings of the
Board of Directors took place.
The frequency of participation of the
members of the Board of Directors at its
meetings in 2024 is as follows:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 220 of 370
MEMBER NAME
MEMBER TYPE FINANCIAL YEAR
PARTICIPATION
IN THE BOD
MEETINGS
PARTICIPATION
PERCENTAGE
FROM TO
Konstantinos Chalioris
Chairman, Executive
Member
01.01.2024 31.12.2024 30/30 100%
Theodoros Kitsos
Vice Chairman,
Independent non-
executive member
01.01.2024 31.12.2024 30/30 100%
Dimitrios Malamos
Chief Executive Officer,
Executive member
01.01.2024 31.12.2024 30/30 100%
Vassilios Zairopoulos
Non-executive
member
01.01.2024 31.12.2024 29/30 97%
Christos Shiatis
Non-executive
member
01.01.2024 31.12.2024 30/30 100%
Christos-Alexis
Komninos
Non-executive
member
01.01.2024 31.12.2024 22/24 92%
Athanasios Dimiou
Non-executive
member
01.01.2024 31.12.2024 30/30 100%
Georgios Samothrakis
Independent non-
executive member
01.01.2024 31.12.2024 29/30 97%
Myrto Papathanou
Independent non-
executive member
01.01.2024 31.12.2024 30/30 100%
Spyridoula Maltezou
Independent non-
executive member
01.01.2024 31.12.2024 30/30 100%
Nikitas Glykas
Independent non-
executive member
01.01.2024 31.12.2024 30/30 100%
The topics mainly discussed during the
year included:
• Briefing by the Chief Executive Officer
on issues related to the external envi-
ronment of the operating segments,
as well as on other important issues
related to the Group’s activity (such
as price increases and price manage-
ment, impact of energy costs, volume
of recycled raw material, geopolitical
developments, etc.)
• Presentation of period Financial Re-
sults for the Group and its subsidiaries,
as well as the joint ventures(JVs)
• Health and safety issues and discus-
sion in order to enhance relevant
measures and policies
• Update on current developments in
subsidiaries and joint ventures(JVs)
• Updates to the Board of Directors
Committees, Audit Committee and
their relevant recommendations.
• Evaluations of Board of Directors /
Committees
• Update on important projects of the
Company and its subsidiaries as well
as the joint ventures (JVs)
• Evaluation of previous years invest-
ments
• Other issues
5) Audit Committee
Fully in compliance with the provisions
and stipulations of the effective legislation
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 221 of 370
and in particular with the article 44, effec-
tive at the time, of L. 4449/2017, during the
Extraordinary General Meeting of share-
holders that took place on 11.02.2021, the
Company elected a new Audit Commit-
tee. Subsequently, the elected Audit Com-
mittee was redefined (type, composition,
number, status of members and term of of-
fice) by the Annual Ordinary General Meet-
ing of May 24, 2023. The Company’s Audit
Committee under its current composition
aims to support the Board of Directors in
performing its duties as regards to the pro-
cedure of financial information, supervise
the operation of the Internal Audit and
Risk and Compliance Units, the procedures
of internal control systems, the supervi-
sion of the mandatory audit of the annual
and consolidated financial statements, as
well as to inform the Board of Directors re-
garding the review of the financial reports
prior to their approval.
Under the regime of article 44 of law
4449/2017, as in force after its amendment
by article 74 of law 4706/2020), and in ac-
cordance with the notifications, clarifica-
tions and recommendations of the circular
with protocol number 1508/17.07.2020 and
427/21.02.2022 documents of the Listed
Companies Directorate of the Hellenic
Capital Market Commission, the Company
is obliged, as a public interest entity, to
have an Audit Committee which consists
of at least three (3) members and which
may comprise:
(a) A Board of Directors Committee con-
sisting of its non-executive members,
or
(b) An Independent Committee, consist-
ing of:
(i) either by non-executive members
of the Board of Directors and third
parties, or
(ii) only by third parties.
Third party means any person who is not a
member of the Board of Directors.
The members of the Audit Committee are
appointed by the Board of Directors, when
it is a Committee of the Board or by the
General Meeting of Shareholders, when
it is an Independent Committee and must
be in their majority independent of the
audited entity. This means that in a three-
member Audit Committee, at least two of
its members (and in any case its Chairman)
must either be independent non-exec-
utive members of the Board of Directors
or, in the case they are third parties, they
should meet the requirements of article 9,
par. 1 and 2 conditions of independence.
The minimum required number of the pre-
sent members in order to render a meet-
ing of the Audit Committee as a valid one
must be three (3), meaning that in case
of a three-member Audit Committee, the
presence of all members at each meeting
is required.
However, even if the Audit Committee
consists of more than three (3) mem-
bers, it is required, according to the clari-
fications granted pursuant to the no.
1302/28.04.2017 document of the Listed
Companies Division of the Hellenic Capital
Market Commission, the participation of
the entire number of its members, in per-
son, in the Committee’s meetings.
At least one (1) member of the Audit Com-
mittee must possess sufficient knowledge
and experience in auditing and account-
ing.
In any case, it is to the discretion of the
Audit Committee to invite whenever it
is deemed necessary key directors of the
Company who are involved in the latter’s
corporate governance (for example Man-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 222 of 370
aging Director, Finance Director, head of
the Internal Audit and Risk & Compliance
Manager) to attend certain meetings or
certain subjects of the daily agenda in or-
der to provide any necessary clarifications.
The Audit Committee, which now oper-
ates in accordance with the provisions of
Law 4449/2017, as in force after its amend-
ment by Law 4706/2020 has the following
duties, while the Board of Directors main-
tains full responsibility and particularly:
i) External Audit (sect. a’ of par.
3) of article 44 of Law 4449/2017
(Government Gazette A’ 7/24.01.2017)
& of article 43 of Law 5164/2024
(Government Gaze tte A’ 202/12 .12 . 2024)
The Audit Committee monitors the proce-
dure and performance of the mandatory
audit on the separate and consolidated
financial statements and, where applica-
ble, on the outcome of ensuring the sub-
mission of the Sustainability Report of the
Company and the Group. In this context
the Committee informs the Board of Di-
rectors by submitting a relevant report for
issues deriving from the mandatory audit
and by explaining analytically the follow-
ing:
a) the contribution of the mandatory au-
dit and of the final submission of the
Sustainability Report to the quality
and integrity of the financial informa-
tion, and of the content of the Sustain-
ability Report respectively, i.e. the ac-
curacy, completeness and correctness
of the published financial information
and the Sustainability Report includ-
ing the relevant disclosures which are
being approved by the Board of Direc-
tors,
b) the role of the Audit Committee in
the under (a) above-mentioned pro-
cedure, meaning the recording of the
actions taken by the Audit Committee
during the performance of the man-
datory audit of the separate and con-
solidated financial statements and the
audit of the Sustainability Report.
In the context of the above informa-
tion that is being granted to the Board
of Directors, the Audit Committee
takes into consideration the contents
of the supplementary report which
the Chartered Auditor-Accountant
prepares and submits, and which
contains the results of the mandatory
audit that was performed fulfilling at
least the requirements of article 11 of
the Regulation (EU) no. 537/2014 of the
European Parliament and the Council
of April 16
th
, 2014 as well as the entire
set of information of the sustainabil-
ity report that the Chartered Auditor-
Accountant is required to submit to
the Audit Committee based on the re-
quirements of Law 5164/2024 and the
relevant announcements of the Listed
Companies Division of the Hellenic
Capital Market Commission.
The Committee:
• Is responsible for the selection and
recall process of the Chartered Audi-
tors-Accountants or the Audit Firm
and proposes through the Board of
Directors to the General Meeting of
Shareholders, the Chartered Auditors-
Accountants or the Audit Firm to be
appointed, the terms of collaboration,
as well as their remuneration (accord-
ing to article 16 of Regulation (EU) No
537/2014, unless par. 8 of article 16 of
Regulation (EU) No 537/2014 is being
applied).
• For the financial year that com-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 223 of 370
menced within the financial year
2024 in line with the article 92 of Law
5172/29.01.2025, the limited assurance
engagement on the Sustainability Re-
port of article 7 of Law 5164/2024 (A’
202) may also be carried out by the
Chartered Auditor or the Audit Firm
that has been appointed by the Ordi-
nary General Meeting of sharehold-
ers or of the members of the audited
entity, for the mandatory audit of the
financial statements of the same fi-
nancial year (in accordance with the
EC announcement with protocol num-
ber 506/07.03.2025). Following the
above, the Audit Committee approved
the appointment of the auditing firm
to which the Certified Public Account-
ant
3 who carries out the audit of the
Financial Statements for the Fiscal
Year 2024 belongs. The auditing firm
was approved as responsible for the
Audit of the Sustainability Report of
the Fiscal Year 2024 and submitted a
relevant proposal for approval to the
Board of Directors.
• Regarding the selection of Chartered
Auditors-Accountants or the Audit
Firm, it is examined and analyzed:
o the scope of work
o the audit standard on the basis of
which this work will be performed
o the form of the deliverable
o the responsibilities of the manage-
ment and the Chartered Auditor-
Accountant respectively
• In the context of ensuring the inde-
pendence of the Chartered Auditors
Accountants or of the auditing firms,
3 The particular Chartered Auditor Accountant was appointed by the Ordinary General Meeting of
Shareholders of May 29, 2024 for the mandatory audit of the Financial Statements for the Fiscal Year
2024.
the Committee is responsible for mon-
itoring any non-audit service to be
provided by the Chartered Auditors-
Accountants or the Audit Firm to the
Company. Taking into account articles
21, 22, 23, 26 and 27, as well as Article 6
of Regulation (EU) No 537/2014) and in
particular the adequacy of the provi-
sion of non-audit services to the Com-
pany (according to article 5 of Regula-
tion (EU) no. 537/2014), the Committee
will approve or not the non-audit ser-
vice.
• Monitors the process and the per-
formance of the mandatory audit of
the separate and consolidated finan-
cial statements of the Company and,
where applicable, ensuring the sub-
mission of the annual and consoli-
dated Sustainability Report, and es-
pecially the performance of the audit,
taking into account any findings and
conclusions of the competent author-
ity (according to paragraph 6 of article
26 of Regulation (EU) no. 537/2014). In
this context, it informs the Board of
Directors by submitting a relevant re-
port on the issues that arose from the
mandatory audit explaining in detail:
(a) the contribution of the statutory
audit to the quality and integrity
of the financial information, i.e. to
the accuracy, completeness and
correctness of the financial infor-
mation, including the relevant
disclosures which are approved by
the Board of Directors and made
public,
(b) the role of the Committee in the (a)
procedure above, i.e. reporting the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 224 of 370
actions taken by the Committee
during the statutory audit process.
• It is also being informed by the Char-
tered Auditors-Accountants or the
Audit Firm on the annual statutory
audit plan before its implementation,
evaluates the specific plan and en-
sures that the annual statutory audit
will cover the most important areas
of audit, taking into account the main
business and financial risk areas of the
Company.
• Furthermore, the Committee submits
proposals on other important issues,
when it deems it appropriate or im-
posed.
ii) Procedure of financial information
(sect. b’ of par. 3) of article 44 of Law
4449/2017 (Government Gazette A’
7/24.01.2017) & of article 43 of Law
5164/2024 (Government Gazette A’
202/12.12.2024)
The Audit Committee monitors the finan-
cial reporting process and, where applica-
ble, the sustainability reporting process, in-
cluding the reports’ electronic submission
process as provided by the article 154B of
Law 4548/2018, along with the process
carried out by the Company in order to de-
termine the submitted information in ac-
cordance with the sustainability reporting
standards approved under article 154A of
Law 4548/2018, and submits recommen-
dations or proposals to ensure its integrity.
Within this context the Committee:
• Is informed about the process and
schedule of preparation of financial
information by the Management and
monitors, and where applicable of
the Sustainability Report, examines
and evaluates the process of prepara-
tion of financial information, i.e. the
mechanisms and production systems,
the flow and dissemination of financial
information produced by the involved
units of the Company.
• The above actions include other dis-
closed information in any way (e.g.
stock market announcements, press
releases, etc.) in relation to financial
information.
• Informs the Board of Directors for its
findings on essential issues in its areas
of responsibility, submits proposals to
improve the process, if deemed ap-
propriate, and monitors the response
of the Company’s Management to
these findings.
• Takes into account and examines the
most important issues and risks that
may have an impact on the Compa-
ny’s financial statements as well as the
significant judgments and estimates
of Management during their prepara-
tion.
Below are indicative issues that are exam-
ined and evaluated in detail by the Audit
Committee to the extent that they are im-
portant for the Company, mentioning spe-
cific actions on them during its reporting
and briefing to the Board of Directors:
• Evaluate the use of the assumption of
ongoing activity.
• Significant judgments, assumptions
and estimates in the preparation of
the financial statements.
• Evaluation of assets at fair value.
• Evaluation of asset recoverable value.
• Accounting treatment of acquisitions.
• Adequacy of disclosures for the signifi-
cant risks faced by the Company.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 225 of 370
• Significant transactions with related
parties.
• Significant extraordinary transactions.
The Committee’s communication with the
Chartered Auditors-Accountants in view of
the preparation of the audit report and the
latter’s supplementary report to the Com-
mittee must be substantial.
In addition, the Committee reviews the fi-
nancial reports (Annual, Semi-Annual and
Quarterly) before their approval by the
Board of Directors, in order to assess their
completeness and consistency in relation
to the information taken into account as
well as the accounting principles imple-
mented by the Company and informs the
Board of Directors accordingly.
iii) Procedures of internal control and
risk management systems and internal
audit unit (sect. c’ of par. 3) article 44 of
Law 4449/2017 (Government Gazette
A’ 7/24.01.2017) & of article 43 of Law
5164/2024 (Government Gazette A’
202/12.12.2024)
The Committee:
• Monitors, examines, and assesses the
adequacy and effectiveness of the
entire policies, procedures, and safe-
guards of the Company regarding
both the internal control system and
the quality assurance, as well as the
estimation and management of risks
in relation to the financial information.
Where applicable, it also monitors the
submission of the Company’s Sustain-
ability Report, including the relevant
electronic submission process referred
to in article 154B of Law 4548/2018,
without violating the independence
of this entity.
• Monitors the effectiveness of internal
control systems mainly through the
work of the internal audit unit, the Risk
& Compliance Department, the Sus-
tainability Department and the work
of the Chartered Auditor-Accountant.
• Examines the conflicts of interest dur-
ing the Company’s transactions with
related parties and submits to the
Board of Directors the relevant re-
ports.
• Examines the existence and content of
those procedures, according to which
the Company’s personnel will be able,
in confidentiality, to express their con-
cerns about possible illegalities and
irregularities in matters of financial
information or other issues related to
the operation of the Company. The
Commission must ensure that proce-
dures are in place to effectively and
independently investigate such issues,
as well as to address them properly.
Regarding the operation of internal audit
unit, the Committee:
• Evaluates the staffing and organiza-
tional structure of the Internal Audit
Unit and identifies any weaknesses
or deficiencies. It also monitors and
inspects the proper operation of the
Internal Audit Unit in accordance with
professional standards as well as the
current legal and regulatory frame-
work and evaluates its work, adequa-
cy and effectiveness, without however
affecting its independence. If deemed
appropriate, the Committee submits
proposals to the Board of Directors,
so that the Internal Audit Unit has
the necessary means, is adequately
staffed with personnel with sufficient
knowledge, experience and training,
there are no restrictions on its work
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 226 of 370
and has the envisaged independence.
Therefore, the appointment and dis-
missal of the head of the Internal Audit
Unit is a proposal of the Audit Com-
mittee to the Board of Directors. In
the same context, the Committee de-
termines and examines the operating
regulations of the Company’s Internal
Audit Unit.
• It is being informed on the annual or
periodic audit plan of the Internal Au-
dit Unit before its implementation and
evaluates it, accordingly, taking into
consideration the main areas of busi-
ness and financial risks as well as the
results of previous audits. The Com-
mittee may decide to configure the
annual or periodic internal audit plan,
as well as to carry out extraordinary
audits by the internal audit unit.
• As part of this briefing, the Committee
reviews if the annual or periodic audit
plan (in conjunction with any corre-
sponding medium-term plans) covers
the most important areas of control
and systems related to financial infor-
mation.
• Holds regular meetings with the Inter-
nal Auditors to discuss issues of their
responsibility, as well as problems aris-
ing from the performance of internal
audits.
• Takes knowledge of the work of the In-
ternal Audit Unit and its reports (regu-
lar and extraordinary) and monitors
the briefing of the Board of Directors
about their content, in relation to the
financial information of the Company.
• Reviews the disclosed information re-
garding internal control and the main
risks and uncertainties of the Compa-
ny, in relation to financial information.
(iv) Regulatory Compliance and Risk
Management Unit (articles 13 & 14 of
Law 4706/2020 - Government Gazette A’
136/17.07.2020)
The Committee:
• Supervises the management of the
main risks and uncertainties of the
Company and their periodic revision.
In this context, it evaluates the meth-
ods used by the Company for the iden-
tification and monitoring of risks, the
treatment of the main ones through
the internal control system and the in-
ternal audit unit as well as their proper
disclosure in the published financial
information.
• Monitors the effectiveness of the
regulatory compliance system, includ-
ing adopting and implementing ap-
propriate and up-to-date procedures,
to ensure that the Company fully and
constantly complies with the legal
and regulatory framework in force in a
timely manner and that there is, at all
times, a complete picture available of
the degree to which this objective is
attained.
• Supervises compliance with specific
governance practices such as personal
data protection, cybersecurity and in-
formation security.
• Reviews the findings from the audits
conducted by Regulatory Authorities,
Chartered Auditors-Accountants and
internal auditors, and the regulatory
compliance and risk management unit
and monitors the degree to which the
Company complies with the applica-
ble requirements.
• Follows up on cases of non-compli-
ance and review the corrective action
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 227 of 370
taken by the Management.
• Informs and is informed from manage-
ment work together with the Compa-
ny’s legal consultants on compliance
issues.
• Examines conflicts of interest during
the Company’s transactions with re-
lated parties and it submits relevant
reports to the Board of Directors.
• Look into the existence and content
of the procedures followed to allow
Company staff to express their con-
cerns confidentially about any poten-
tial illegal and irregular practices with
regard to financial reporting or other
issues which are associated with the
Company’s operation. The Committee
must ensure that the procedures are in
place for investigating such issues ef-
fectively and independently, as well as
addressing them adequately.
• Evaluate regulatory compliance and
risk management reports at Company
and group level, informs the Board of
Directors of its findings and submits
proposals where required.
The oversight of the management of key
risks and uncertainties, as well as the mon-
itoring of the effectiveness of the Com-
pany’s regulatory compliance system, is
carried out through the supervision of the
Risk Management and Regulatory Compli-
ance Unit, for which the Committee:
• Evaluates the staffing and organiza-
tional structure of the Unit and detect
any weaknesses therein. Moreover,
monitors and inspects the proper
functioning of the Risk and Compli-
ance Unit according to the profession-
al standards and the legal and regula-
tory framework in force and assesses
its work, adequacy and effectiveness.
Where appropriate, makes proposals
to the Board of Directors for the Unit
to have the necessary means and be
adequately staffed with employees
who have sufficient knowledge, expe-
rience and training etc.
• Evaluates the annual work plan of the
Unit before it is implemented taking
into account the key areas of business
and financial risk, proposes any addi-
tions or changes and finally approves it.
• Receives and evaluates the result of
the unit’s annual work plan, which is
the Annual Compliance Report and
then informs the Board of Directors
and Committees, about any instances
of non-compliance that have been re-
corded, if any, and the measures being
implemented to address potential de-
ficiencies.
• Holds regular meetings with the Risk &
Compliance Manager to discuss issues
of his/her responsibility.
For the results of all the above actions, the
Committee informs the Board of Directors
about its findings and submits proposals
for the implementation of corrective ac-
tions, if deemed appropriate.
The Committee shall have unhindered and
full access to the information, records and
data required in the exercise of its powers
and shall have the necessary resources to
carry out its work in a proper and effective
manner, including the use of external con-
sultants.
The Audit Committee archives all the nec-
essary information, including the minutes
of its meetings, in which its actions and
their results are recorded, regarding the
implementation of its work.
The Audit Committee submits reports to
the Board of Directors on its areas of re-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 228 of 370
sponsibility and also in the areas which, af-
ter the completion of its work, it considers
that there are essential issues in relation
to the provided financial information and
monitors the Management’s response to
them.
The Chairman of the Committee provides
information to the shareholders dur-
ing the annual General Meeting about
the Committee’s activities on the basis
of the above-mentioned responsibilities,
through the submission of a relevant Re-
port.
For the implementation of all the above,
the Audit Committee is expected to hold
meetings with the Management and the
competent executives during the prepara-
tion of the financial reports, as well as with
the Chartered Auditors-Accountants or the
Auditing Company during the planning
phase of the audit, during the execution
and also during the phase of preparation
of audit reports.
The existing Audit Committee, which
was elected by the Extraordinary General
Meeting of Shareholders on 11 February
2021, as it was redefined following the res-
ignation of the member of the Audit Com-
mittee, Mr. Konstantinos Gianniris, and his
replacement by Ms. Sophia Manesi, is an
Independent Committee and is consist-
ed of the following one (1) Independent
Non-Executive Member of the Company’s
Board of Directors and two (2) non-mem-
bers-third parties, namely:
Georgios
Samothrakis
Independent Non-
Executive Board
Member
Konstantinos
Kotsilinis
Non-Board Member –
third party
Sophia
Manesi
Non-Board Member –
third party
Following the replacement of the afore-
mentioned resigned member of the Audit
Committee by the Extraordinary General
Meeting of shareholders of 24 May 2023
and the appointment of Ms. Sophia Mane-
si as his replacement for the remainder of
the term, the Audit Committee, during its
meeting on May 25, 2023, was constituted,
with the term ending on February 11, 2026.
For reasons of completeness, CVs of the
members of the current Audit Committee
are presented as follows:
• Georgios Samothrakis
The CV of Mr. Georgios Samothrakis, Mem-
ber of the Board of Directors, is presented
in detail in Section VI.1 “Composition of the
Board of Directors” of the current Report.
• Konstantinos Kotsilinis
Mr. Konstantinos Kotsilinis was born in
New Zealand in 1946, studied at Victo-
ria University of Wellington and earned a
Bachelor of Commerce and Administration
degree. He began his professional career
in 1968 at Coopers & Lybrand in Welling-
ton, then transferred to the London office
in 1972 and later that year to the Greek of-
fice. From 1978 to 2003 he was head of the
audit department of Coopers & Lybrand /
PwC Greece. In his last years of service in
the Company, he served as the Chairman
of the Board of Directors of the Company.
He has also served on various Committees,
including the Supervisory Board of the
European Financial Reporting Advisory
Group (2002-2004) and the Accounting
Harmonization Committee of UNICE (2002-
2005). From 2009 to 2014, he was Vice
Chairman of the Accounting Standardiza-
tion and Auditing Committee of Greece
(ELTE) and Chairman of the Quality Control
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 229 of 370
Council (SPE). During this period he rep-
resented Greece in the relevant commit-
tees in the European Union and during the
Greek Presidency he was the Chairman of
the committee responsible for audit issues.
He is a former Member of the Institute of
Chartered Accountants of Greece as well
as of the Institute of Chartered Account-
ants of New Zealand. He is the Chairman
(since 2006) of the Board of Directors and a
member of the Audit Committee of the in-
surance Company Interasco A.E.G.A. From
2006 until today he is an External Advisor
of the Audit Committee of the National
Bank of Greece, while since 2017 until 2021
was a Member of the Audit Committee of
Mytilineos SA. From 2023 he is a member
of the Audit Committee of Frigoglass SAIC.
Since 2004 he is a Member of the Board of
Directors of “Child’s Smile” (from 2011 and
until today Vice President of the Organi-
zation) and since 2024 Chairman of the
Audit Committee. From 1991 to 2020 he
was the Honorary Consul General of New
Zealand in Greece, while he has been ap-
pointed Member (MNZM) (1998) and Of-
ficer (ONZM) (2007) of the Order of Merit
of New Zealand by the Queen of England.
• Sophia Manesi
Ms. Manesi has twenty years of experience
in Internal Audit having held senior posi-
tions at PwC, the former bank Geniki, BNP
Paribas Greece and the Hellenic Financial
Stability Fund. Her main areas of expertise
are the establishment and smooth opera-
tion of Internal Control Unit in accordance
with the International Standards for the
Professional Implementation of Internal
Control of the IIA, the risk assessment, the
evaluation of the Internal Control System
and the implementation of the best prac-
tices of Corporate Governance.
At BNP Paribas Greece and the Hellenic
Financial Stability Fund, as Director of In-
ternal Audit, she was responsible for the
development and implementation of op-
erational internal audit procedures and risk
assessment, which contributed to increas-
ing the efficiency of the units’ operation
and the achievement of specific objec-
tives that had been set by the respective
Administration.
Since 2020, she has been a regular lecturer
in the Integrated Basic Training Program
for Internal Auditors of the Hellenic Insti-
tute of Internal Auditors, and since 2023, at
the Economic Chamber of Greece in basic
training programs for Internal Auditors.
Additionally, she participates as a speaker
in events that promote knowledge and
awareness on Corporate Governance and
the Internal Control System.
She holds a bachelor’s and Master’s De-
gree in Business Administration as well
as a degree in Psychology. She holds the
Certified Internal Auditor (CIA), Certified
Fraud Examiner (CFE), COSO Internal Con-
trol Certificate and is a certified evaluator
of internal control units. She knows English
and German.
From the above it is inferred that the mem-
bers of the Audit Committee have proven
in their entirety that they possess suffi-
cient knowledge in the field in which the
Company operates, given that:
(a) Mr. George Samothrakis was already
a member of the Audit Committee of
the Company, elected by the Extraor-
dinary General Meeting of Sharehold-
ers as of March 19, 2019,
(b) Mrs. Sofia Manesi, although she has
never participated in the Board of
Directors of the Company, has many
years of professional experience, aca-
demic and technical training, factors
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 230 of 370
that make her the most suitable re-
placement for the resigned member.
(c) Mr. Konstantinos Kotsilinis, who has
never participated in the Board of Di-
rectors of the Company, knows very
well and due to his wider professional
activity the environment and the con-
ditions in which the Company devel-
ops its business activities.
The criterion of sufficient knowledge and
experience in auditing or accounting is
proven to be met in the capacities of both
Mr. Georgios Samothrakis and Mr. Kon-
stantinos Kotsilinis, who are both former
Chartered Auditors-Accountants with ex-
tensive knowledge and rich professional
experience. This in turn contributes deci-
sively and substantially in further strength-
ening the efficiency of the Audit Com-
mittee and in the implementation of its
responsibilities in the best possible way, in
order to strengthen the dynamics and the
value of the Company. Furthermore, Ms.
Sophia Manesi, possessing many years of
experience in Internal Auditing, can make
a substantial contribution to the Audit
Committee so that the latter can carry out
its work in the most effective manner and
be able to provide substantial solutions
and guidance facilitating at the same time
the economic growth of the Company and
the fulfilment of its legal obligations.
Finally, those conditions and criteria of
independence which are covered by the
current regulatory framework and in
particular by article 9 par. 1 and 2 of law
4706/2020, are met for all members of the
Audit Committee, given that the following
persons:
(a) do not hold shares greater than 0.5%
of the Company’s share capital; and
(b) do not have any dependency relation-
ship with the Company or persons
related to the Company, according to
the manner by which this dependency
relationship is specified in particular in
the provisions of the above legislation.
Frequency of Meetings and Main Topics
of Meetings’ Agenda
The Committee convenes at least four (4)
times a year. The Chairman of the Com-
mittee decides on the frequency and time
schedule of the meetings. The Chartered
Auditors-Accountants are entitled to re-
quest a meeting by the Committee if they
deem it appropriate or necessary.
During 2024, the Committee convened
eleven (11) times, and all members were
presented during the meetings, whereas
all issues mentioned in the Internal Rules
of Operation as well as in the Rules of Pro-
cedure of the Audit Committee were dis-
cussed and handled, the major of which
are as follows:
1. Supervision and approval of the Inter-
nal Audit and Risk & Compliance Unit’s
activities and briefing of the Board of
Directors about the issues arising from
both Units activities.
2. Confirmation of the exclusive em-
ployment, personal and functional
independence and objectivity in the
exercise of the duties of the head of
the Internal Audit Unit, as well as the
possession of the appropriate knowl-
edge, professional experience and the
absence of any non-comformity.
3. Monitoring the process and conduct-
ing the assessment of the Company’s
Internal Control System audit includ-
ing its significant subsidiaries and in-
forming the Board of Directors about
the issues arising from the conduct of
this specific audit.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 231 of 370
4. Monitoring the process and the per-
formance of the Company’s Corporate
Governance System for the period 1/1-
31/12/2024 with a reporting date of
31/12/2024 and drafting up a relevant
proposal to the Board of Directors for
its implementation by the Secretary of
the Board of Directors with the assis-
tance of the Regulatory Compliance &
Risk Management Unit and the Audit
Committee.
5. Monitoring of the process and the per-
formance of the Enterprise Risk Assess-
ment Project of the Company and its
subsidiaries and informing the Board
of Directors about the issues arising
from this risk assessment.
6. Providing an opinion on the selection
of the Auditing Company for the per-
formance of the mandatory audit on
the separate and consolidated finan-
cial statements of the Company for the
fiscal year 2024.
7. Carrying out an evaluation process for
the selection of the Audit Firm that will
undertake the limited assurance en-
gagement regarding the Sustainabil-
ity Report for the Fiscal Year 2024 and
submitting a proposal to the Board of
Directors so that the same Audit Firm
that undertook the mandatory audit
of the separate and consolidated fi-
nancial statements will also undertake
the limited assurance engagement re-
garding the Sustainability Report for
the Fiscal Year 2024.
8. Monitoring of the financial informa-
tion process, overview of the annual
Financial Report, the annual Financial
Statements and the semi-annual and
quarterly (interim) Financial State-
ments (stand-alone and consolidated)
and drafting up a relevant proposal
to the Board of Directors for their ap-
proval.
9. Monitoring of the process and the
performance of the mandatory audit
on the separate and consolidated fi-
nancial statements and informing of
the Board of Directors about the issues
related to the mandatory audit.
10. Completion of the information pro-
vision process by the auditing firm
to which the Chartered Auditor Ac-
countant belongs for the preparation
of the “2024 Sustainability Report” in
accordance with the CSRD directive
(Corporate Sustainability Reporting
Directive).
11. Ensuring the independence, integ-
rity, impartiality and objectivity of the
Chartered Auditors-Accountants.
12. Examination of all the services pro-
vided by the Auditing Company,
evaluation of their performance and
confirmation that no non-permissible
services have been provided, except
those required in the context of ac-
counting and tax audits.
13. Approval of the content of the infor-
mation provided to the Company’s
shareholders during the Annual Regu-
lar General Meeting regarding the ac-
tivities of the year 2023.
6) Remuneration and Nominations
Committee of Board of Directors
Members, Committees and Senior
Management
The Board of Directors of the Company for
the purpose of substantial, effective and
adequate compliance and harmonization
of the Company with the regulations of
articles 11 and 12 of Law 4706/2020 (Gov-
ernment Gazette A136/17.07.20201) and
with the parallel adoption of the corpo-
rate governance best practices, during its
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 232 of 370
meeting of 22.03.2021 decided the aboli-
tion of the existing Committee for Benefits
and Promotion of Nominations (CBPN) and
its replacement by the Remuneration and
Nominations Committee.
Following the resignation of Mr. Niki-
tas Glykas as member of the Remunera-
tion and Nominations Committee, which
was submitted to the Committee on
29.08.2024, the Board of Directors, by its
decision of 30.08.2024, elected Ms. Myrto
Papathanou, Independent Non-Executive
Member of the Board of Directors, as the
replacement of the resigned member.
Following the above decision, the Remu-
neration and Nominations Committee at
its meeting on 30 August 2024 was consti-
tuted into body, with its term expiring on
11.02.2026, as follows:
Theodoros
Kitsos
Independent Non-Executive
Member of the BoD,
Chairman of the Committee
Myrto
Papathanou
4
Independent Non-Executive
Member of the BoD,
Member of the Committee
Vasileios
Zairopoulos
Non-Executive Member of
the BoD, Member of the
Committee
The current Remuneration and Nomina-
tions Committee, as restructured follow-
ing the resignation of the member of the
Committee, Mr. Vasilios Zairopoulos, and
his replacement by Ms. Eleni Providi, con-
sists of the following Non-Executive mem-
bers of the Board of Directors, namely:
Theodoros
Kitsos
Non-Executive
Member of the BoD
4 The beginning of the term of Ms. Myrto Papathanou as member of the Committee is August 30, 2024
& as President of the Committee is April 4, 2025. The beginning of the term of Ms. Eleni Providi as
member of the Committee is April 4, 2025. ___
Myrto
Papathanou
4
Independent Non-
Executive Member of
the BoD
Eleni Providi
4
Independent Non-
Executive Member of
the BoD
Following the replacement of the above
resigned member of the Remuneration
and Nominations Committee based on the
decision taken by the Company’s Board
of Directors on 4
th
April 2025 and the ap-
pointment of Ms. Eleni Providi as replace-
ment for the remainder of term, the Re-
muneration and Nominations Committee,
at its meeting on 4 April 2025, was consti-
tuted into a body, with its term expiring on
11.02.2026, as follows:
Myrto
Papathanou
4
Independent Non-
Executive Member of
the BoD, Chairman of
the Committee
Theodoros
Kitsos
Non-Executive
Member of the BoD,
Member of the
Committee
Eleni Providi
4
Independent Non-
Executive Member of
the BoD, Member of
the Committee
It is noted that based on both the previous
and the current composition, the majority
of the members of the Remuneration and
Nominations Committee are Independent,
in order to ensure the objectivity, inde-
pendence and integrity of their judgment.
The Board of Directors is responsible for
the appointment and replacement of all
members of the Committee. The Com-
mittee elects its Chairman, who is an In-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 233 of 370
dependent Non-Executive Member and
is supported by the Secretary of the Com-
mittee. The term of office of the members
of the Committee is directly related to that
of the Board of Directors. In addition, the
Committee submits an annual progress
and activity report to the Board of Direc-
tors.
The purpose of this Committee includes at
a minimum the development and forma-
tion of all types of remuneration of execu-
tives falling within the scope of application
of the Remuneration Policy provided by
Article 110 of Law 4548/2018, the identifi-
cation and retain of the necessary execu-
tives within the headcount of the Com-
pany, who will support the Company’s
long-term success, manage the process of
nominating and succession planning for
the Board of Directors, Committees, and
senior management, in line with business
objectives, competitive practices, and all
applicable rules and regulations of the
Company and current legislation. They
will also formulate and submit relevant
proposals and recommendations on these
matters to the Board of Directors.
The operation of this Committee ensures
that both the remuneration of the Execu-
tive and Non-Executive members of the
Board of Directors and the members of its
Committees as well as the nominations for
Board of Directors members will be in line
with the corporate objectives and market
practices and, in any case, will be in full
compliance with the current legal and reg-
ulatory framework.
In terms of setting up remuneration policy,
the Committee’s responsibilities include
the following:
• The Committee examines, pre-ap-
proves and makes recommendations
to the Board of Directors annually re-
garding labor issues included in the
employment contracts of Executive
Board of Directors members and the
compliance with the internal Rule of
Procedure.
• The Committee is responsible to de-
termine the remuneration scheme of
the Board of Directors, each Commit-
tee members and Top Management
Executives and makes recommenda-
tions on the subject to the Board of
Directors which decides or makes a
suggestion to the General Meeting, as
required.
• The Committee reviews, pre-approves
and proposes annually (or whenever
deemed necessary) to the Board of
Directors, the base salary, the variable
remuneration and benefits provided
(where available) for the Board of Di-
rectors Executive and Non-Executive
members, the Board of Directors Com-
mittees members, and the Top Man-
agement Executives of the Company,
including the Head of Internal Audit
and the Head of Risk & Compliance,
taking into consideration the macroe-
conomic conditions and the remuner-
ation level of respective companies.
• Specifically for the Executive members
of the Board of Directors and based on
the approved (from the Board of Di-
rectors) Strategic Plan, the Committee
ensures the existence of approved an-
nual significant objectives (maximum
of 3) and ensures their proper reflec-
tion. After the end of the relevant pe-
riod, it examines, pre-approves, and
recommends to the Board of Directors
the amount of variable remuneration,
based on the achievement of corpo-
rate goals.
• The Committee reviews, when re-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 234 of 370
quired, the Remuneration Policy, in-
cluding the submission of proposals
for improvement or differentiation,
and examines the data included in the
final draft of the annual Remuneration
Report, providing its opinion to the
Board of Directors, before submitting
the report to the General Meeting, in
accordance with the law.
• The Committee undertakes and co-
operates with the other committees
of the Board of Directors, in order to
review the non-salary contractual ob-
ligations for Executive and Non-Ex-
ecutive Board of Directors members/
Committee members.
• If the Committee becomes aware of
a review of the financial statements
of previous years or finds incorrect,
inaccurate or incomplete information
that has an impact on the variable re-
muneration, it is obliged to inform the
Management in order to require the
readjustment and/or return of all or
part of the variable remuneration that
has been granted.
• The Committee conducts or author-
izes third parties to conduct research
or studies on matters falling within its
remit.
In the responsibilities of the Committee
regarding the promotion of the nominees
for the Board of Directors and Committees
members, the following are included:
• The Committee defines and proposes
to the Board of Directors the criteria
for the election of members of the
Board of Directors and its Committees,
in accordance with the requirements
of the law and the respective strategy
/ Suitability Policy of the Company.
• The Committee is responsible for the
preparation of the Nomination pro-
cess for members of the Board of Di-
rectors / Committees, based on prede-
fined criteria and in accordance with
the eligibility and corporate govern-
ance policies.
• The Commission evaluates candidates
of the Board of Directors and Board of
Directors Committees through inter-
views and references.
• The Committee proposes the selected
candidates for approval to the Board
of Directors and General Meeting as
required.
• The Committee determines the evalu-
ation criteria of Board of Directors
and its Committees on matters such
as size, composition, existing balance
of qualifications, gender, knowledge,
experience, skills, and overall effec-
tiveness of the Board of Directors. The
Committee is also responsible for the
annual performance evaluation of the
members of the Board of Directors/
Committees according to the crite-
ria of the Suitability Policy. Based on
evaluation results, the Committee pre-
pares and recommends to the Board
of Directors the annual Board Adequa-
cy Report which is submitted to the
General Meeting.
• The Committee determines the pa-
rameters of the succession planning of
the Board of Directors and its Commit-
tees and supervises it.
• The Committee determines the evalu-
ation criteria, supervises the annual
individual evaluations of the Executive
Board of Directors members, and sug-
gests to the Board of Directors propos-
als for their personal and professional
development, to ensure that the Com-
pany remains competent and compet-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 235 of 370
itive in the long term.
• The Committee advises the Chief Ex-
ecutive Officer in the process of nomi-
nating candidates for senior executive
positions of the Company, as well as
in creating their succession plan. The
final decision to fill the above posi-
tions belongs exclusively to the Chief
Executive Officer.
• The Committee conducts or author-
izes third parties to conduct investi-
gations or studies on matters falling
within its area of responsibility.
The Remuneration and Nominations Com-
mittee for Board of Directors Members,
Committees and Senior Management con-
vened thirteen (13) times during the year
2024 (01-01.2024-31.12.2024) in the pres-
ence of all its members. The topics that
were mainly discussed were:
• The evaluation of the management’s
proposal for the 2024 remuneration of
the Top Executives and the approval
for 2023 bonus,
• The approval of the allocation of the
2024 Bonus through Profit Distribution,
• The control of the term of members of
the Board of Directors & its Commit-
tees and the determination of a suc-
cession plan for the members of the
Board of Directors and Committees,
• The submission of a proposal not to
replace the deceased non-executive
member of the Board of Directors of
the Company, Christos-Alexis Komni-
nos,
• The confirmation regarding the non-
issuance of a final court decision for
loss-making transactions (article 3,
paragraph 4) of Law 4706/2020 for all
the members of the Board of Directors
and compliance with the Independ-
ence criteria of the Independent non-
Executive members of the Board of
Directors,
• The confirmation regarding the non-
existence of cases of conflict of inter-
ests of the members of the Board of
Directors,
• The determination of specific per-
formance criteria for the short-term
incentive program for the year 2024
for the Executive Board of Directors
Members & Executive Management
involved,
• The verification of the participation of
Board of Directors Members in Boards/
Committees outside the Group,
• The drafting of the Competency Re-
port for the Board of Directors,
• The preparation of the Remuneration
Report,
• The examination of the fulfillment
of the individual suitability and inde-
pendence criteria in the person of the
candidate for the new member of the
Audit Committee, Mr. Myrto Papatha-
nou, following the resignation of Mr.
Nikitas Glykas, previous member of
the Committee.
• The annual reassessment of the Com-
mittee’s Operating Regulations,
• The update and receipt of feedback
regarding the skills model and
• The insurance of the existence of in-
duction programs for new members
of the Board of Directors.
7) Existing committees, based on the
decisions of the Board of Directors
as at 22.03.2021 and 24.03.2022
Furthermore, the Board of Directors of the
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 236 of 370
Company at its meeting of March 22, 2021,
in order to optimally organize and operate
the most efficient framework of corporate
governance, decided the establishment of
new Committees as follows:
• Strategy and Investment Committee,
• Environmental, Social and Corporate
Governance [ESG] Committee and
• Human Resources Committee.
Following its decision of 22.3.2021, the
Company’s Board of Directors new meet-
ing that took place on 24.03.2022 decided:
• The modification in the responsibili-
ties of the Environmental, Social and
Corporate Governance (ESG) Commit-
tee, as the responsibilities related to
regulatory compliance were assigned
to the Audit Committee and conse-
quently it was decided to rename the
Committee to Sustainability Commit-
tee.
• To change the organizational posi-
tion of the Human Resources Com-
mittee and put it to report directly to
the Group CEO, in order to ensure the
most effective support and its contri-
bution to its daily work.
As a result of the above decisions and
changes that took place, the other Com-
mittees of the Company’s Board of Direc-
tors have been formed as follows:
Strategy and Investment Committee
The purpose of this specific Committee
primarily consists of providing assistance
to the Board of Directors with regard to the
development of the operational strategy,
the formulation of the investment plan of
the Company and of the Group in general,
as well as supervising and providing guid-
ance to the Board of Directors during the
implementation of the business strategy
that has been formulated, as well as the
provision of support in the formulation of
revised / updated plans and in the moni-
toring and control of the implementation
and performance of the strategic invest-
ments of the Company and the Group.
The framework of responsibilities of the
Committee includes:
• Develops and proposes to the Board
of Directors the long-term strategy of
the Group and suggests the necessary
adjustments in the short and medium
term.
• Studies and pre-approves the strate-
gic plans of the companies, ensures
that they are in line with the Group’s
strategy and makes recommendations
to the Board of Directors.
• Reviews and proposes to the Board
of Directors the investment plans and
the individual investments of the com-
panies.
• Reviews possible acquisitions, merg-
ers, divestments and Joint Ventures
and makes proposals to the Board of
Directors respectively.
• Monitors the progress and results of
all actions related to the implementa-
tion of the strategy and the progress
of investment plans and informs the
Board of Directors accordingly.
• Monitors closely international trends,
best practices, and market data, in or-
der to adapt the strategy of the Group
and the Companies and informs the
Board of Directors accordingly.
• Recognizes timely risks and opportu-
nities and prepares proposals to the
Board of Directors for the necessary
actions, including the framework that
ensures their funding.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 237 of 370
• Discusses the communication of the
Management to third parties and the
investor community, in terms of the
strategy and the investment plan of
the Group.
The Strategy and Investment Committee
consists of three (3) members of the Board
of Directors, as follows:
Konstantinos
Chalioris
Executive Member
of the BoD,
Chairman of the
Committee
Dimitrios Malamos Executive Member
of the BoD,
Member of the
Committee
Vasileios
Zairopoulos
Non-Executive
Member of the
BoD, Member of
the Committee
The Committee convened 20 times during
the fiscal year 2024 in the presence of all
its members.
The topics that were mainly discussed con-
cern the strategies of the subsidiaries, the
budgets of the subsidiaries and the Group
and the assessment of new investments.
Sustainability Committee
The purpose of this Committee is to re-
view, pre-approve and recommend to the
Board of Directors environmental and so-
cial sustainability issues through strategy
development, issue management and per-
formance monitoring. The framework of
responsibilities of the Committee includes:
Examines that the Sustainable Devel-
opment policies, strategies and objec-
tives are fully aligned with both the
Company’s vision and values, as well
as Laws and the general regulatory
framework, to ensure full compliance.
Monitors closely the development and
implementation of the Sustainable
Development goals that have been
set, based on the Materiality Analysis,
which includes the important, relevant
and critical areas that the Company
highlights as priorities and proposes
improvements to the Management
and then to the Board of Directors,
where necessary.
Monitors the progress and results of
all Sustainable Development issues
with the aim of regularly informing the
Board of Directors.
Closely monitors international trends
and best practices in order to regularly
update the Board.
Contributes to the detection and
recognition of significant risks and
opportunities for the Company to re-
view and consider during the Materi-
ality Analysis and Risk Management
processes.
Studies and pre-approves the Impact
& Financial Materiality Assessment, the
annual Sustainability Report (ESRS)
and the disclosures according to the
European Taxonomy (EU Taxonomy),
which are part of the annual financial
statements, as well as the annual Sus-
tainable Development Report (GRI), as
well as the texts of other disclosures
or assessments (CDP, ATHEX ESG, etc.),
submitting relevant recommenda-
tions to the Board of Directors for final
approval.
Acts on behalf of the Board of Direc-
tors and cooperates with the Manage-
ment of the Company ensuring the
prestige and reputation of the Compa-
ny in relation to all issues of Sustaina-
ble Development and its Public Image.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 238 of 370
Operational Framework
Environment:
The Committee evaluates the impact of
the Company’s policies and strategy in re-
lation to the following:
The impact of the Company’s footprint
to land, air, water, climate through the
use of raw materials, end products de-
sign, technology, manufacturing units,
transport etc.
The adoption of circular economy
principles throughout the life cycle of
the Company’s products, etc.
Society:
The Committee evaluates the impact of
the Company’s policies and strategy in re-
lation to the following:
The corporate culture, philosophy and
related commitments regarding issues
of diversity and inclusion criteria.
The training and development of
employees.
The improvement of employee well-
being including the issues of health
and safety.
Ensuring the proper standard of living
of employees.
The protection of human rights at
work.
The workplace environment.
The elimination of child/forced labor.
The support of local communities.
The safety of products during their
production and utilization.
The composition of the Sustainability Com-
mittee on 31.12.2024 was the following:
Theodoros Kitsos
Independent
Non-Executive
Member of the
BoD, Chairman of
the Committee
Konstantinos
Chalioris
Executive Member
of the BoD,
Member of the
Committee
Dimitrios Malamos
Executive Member
of the BoD,
Member of the
Committee
Spyridoula
Maltezou
Independent
Non-Executive
Member of the
BoD, Member of
the Committee
Following the resignations of Mr. Konstan-
tinos Chalioris from holding the capacity
of member of the Sustainability Commit-
tee and of Ms. Spyridoula Maltezou from
holding the capacity of Independent
Non-Executive Member of the Company’s
Board of Directors as well as the capacity of
member of the Sustainability Committee,
the Board of Directors decided to proceed
with changes in the composition of the
Sustainability Committee, in order for the
aforementioned Committee to continue
exercising its duties and responsibilities,
as determined by the updated Operating
Regulation, which governs its operation.
As a result of the above, the Board of Di-
rectors of the Company, at its meeting of
March 6, 2025, decided the following:
1. The immediate replacement of Ms.
Spyridoula Maltezou by Ms. Fotini-
Marina Niforos.
2. The non-replacement of the resigned
member Mr. Konstantinos Chalioris.
As a result of the above decision taken
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 239 of 370
by the Company’s Board of Directors, the
Sustainability Committee is currently com-
posed of the following three (3) members
of the Board of Directors, namely:
Theodoros Kitsos
Non-Executive
Member of the
BoD, Chairman of
the Committee
Dimitrios Malamos
Executive Member
of the BoD,
Member of the
Committee
Foteini Marina
Niforos
5
Independent
Non-Executive
Member of the
BoD, Member of
the Committee
The Committee convened 5 times during
the fiscal year 2024 in the presence of the
majority of its members.
The topics that were mainly discussed con-
cern:
Discussion and information about the
external environment in matters of
sustainable development.
Update on the project to support sus-
tainable development issues.
Discussion and comments on the draft
Non-Financial Information Report.
Update on the European Taxonomy.
Discussion on defining indicators.
Update on materiality analysis.
Discussion and comments on the draft
Supplier Assessment Process.
Discussion and comments on the draft
Sustainability Report.
Discussion on Directive (EU) 2022/2464
Corporate Sustainability Reporting
Directive.
5 Term commenced on 6 March 2025
Discussion on the preparation of the
Sustainability Report for the fiscal year
2024 and about its audit.
Discussion and comments on the draft
questionnaire for CDP assessment.
Discussion and comments on the draft
Environmental Policy.
It is pointed out that all the above Commit-
tees of the Board of Directors have drafted
- composed their Rulebooks.
8) Evaluation of Board of Directors
and Committees
The Company implements an Evaluation
Policy of the Board of Directors and Com-
mittees. The scope of the Policy includes
the executive, non-executive, independ-
ent non-executive members of the Board
of Directors of the Company, as well as
the non-members of the Board of Direc-
tors (third parties) who are members of its
Committees.
The criteria of suitability and reliability of
the Board of Directors members are de-
fined in law 4706/2020, the decisions is-
sued under its authority, as well as the
Suitability Policy of the Company, which
has been approved and implemented by
the Company. The Company Suitability
Policy is posted on the Company’s website
https://www.thracegroup.com/
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 240 of 370
Procedure for Periodic Evaluation of
Board of Directors Members
Individuals falling within the scope of the
Suitability Policy are continuously evalu-
ated based on their ability to effectively,
consistently, and efficiently fulfill their du-
ties and ensure the interests of the Com-
pany and other stakeholders, in order to
achieve prudent and sound management
of the Company by fit and proper individu-
als.
The members of the Board of Directors
and its Committees are evaluated:
• On a collective basis, which takes into
account the overall operation of the
Board of Directors and its Committees
and
• On an individual basis regarding the
assessment of each member contribu-
tion to the successful operation of the
Board of Directors.
The periodic evaluation of the Board of
Directors members and its Committees
is held on an annual basis within the first
quarter of each year, unless otherwise de-
cided by the Remuneration and Nomina-
tions Committee and concerns the period
of 12 months of the previous year.
Self-evaluation of the overall performance
of the Board of Directors and its Committees
The self-evaluation of the overall perfor-
mance of the Board of Directors and its
Committees is carried out taking into ac-
count the purposes, responsibilities, their
operation based on the Articles of Asso-
ciation, the Regulations and the legislative
and regulatory framework. Also, during
the overall evaluation, the composition,
the diversity, and the effective coopera-
tion of the members of the Board of Di-
rectors for the fulfillment of their duties
are taken into account. It is conducted on
the basis of questionnaires which are ap-
proved by the Remuneration and Nomi-
nations Committee and are completed by
the members of the Board of Directors and
the Committees. Members should answer
all the questions on the questionnaires.
The Remuneration and Nominations Com-
mittee decides on the initiation of the self-
evaluation process and decides whether it
is deemed appropriate for the annual eval-
uation to be carried out internally or with
the assistance of an independent external
consultant.
Individual Evaluation of Board of Directors
Members and its Committees
The individual evaluation of the members
of the Board of Directors concerns the
performance of each member on an in-
dividual basis and the assessment of his/
her contribution to the effective operation
and overall performance of the Board of
Directors.
Each member of the Board of Directors is
evaluated by the Chairman or the Vice-
Chairman and all the other members of
the Board of Directors, regarding the ful-
fillment of the role and the more specific
tasks assigned to him/her, as defined in
the Rulebook of the Board of Directors and
its Committees, in the Internal Regulations
of the Company, in the Corporate Govern-
ance Code as well as in law 4706/2020.
During the individual evaluation, the sta-
tus of the member is taken into account
(executive, non-executive, independent
non-executive), the participation in spe-
cial Committees, the assumption of special
responsibilities / projects, the time dedi-
cated during the fulfillment of his / her du-
ties, the behavior as well as the utilization
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 241 of 370
of theoretical knowledge and professional
experience possessed.
The evaluation is carried out on the basis
of questionnaires that are completed for
each member, while in addition, in the
context of the individual evaluation, the
Chairman or Vice-Chairman may meet
individually with the members, if this is
deemed appropriate or necessary.
In case a low score is identified or there are
suggestions for improvement for specific
members, the Chairman and/or the Vice
Chairman of the Board of Directors are in-
formed so as to consider the possibility of
an individual meeting of the Chairman and
/ or the Vice-Chairman with the member
of the Board of Directors for their update,
the discussion of the individual points that
have been recorded and the definition
of the actions that are deemed appropri-
ate to follow. Regarding the evaluation of
the Chairman, a corresponding update is
made, if necessary, to the Chairman of the
Remuneration and Nominations Commit-
tee. During the relevant briefing of the
Chairman of the Board of Directors, the
anonymity of the members who made
the evaluation is ensured and in no case
are their details disclosed to the Chairman
of the Board or to the Remuneration and
Nominations Committee.
Based on the evaluation of the Board of
Directors members and its Committees,
as described above, with reference period
the closing fiscal year 2024 (01.01.2024-
31.12.2024), no significant weaknesses
were identified. Therefore, the Board of
Directors decided not to prescribe any cor-
rective actions.
VII. GENERAL MEETING AND
SHAREHOLDERS’ RIGHTS
1. Authorities of General Meeting
• The General Meeting of the Compa-
ny’s shareholders is the highest corpo-
rate body and is entitled to decide on
any issue that concerns the Company,
while its decisions also bind share-
holders that are not present or who
disagree.
• Issues regarding invitation, convening
and conducting General Meetings of
shareholders, that are not particularly
defined by the Company’s current Ar-
ticles of Association are governed by
the relevant provisions of articles 116-
140 of Law 4548/2018, as currently in
effect.
2. Convening the General Meeting
The General Meeting convenes at the
Company’s registered offices or in a dis-
trict of another municipality within the
prefecture of its domicile or another mu-
nicipality near the domicile. The General
Meeting may also convene in the district
of the municipality, where the domicile of
the relevant organized market is located.
Remote participation in the voting at the
General Meeting of shareholders is al-
lowed, using audiovisual/electronic or oth-
er means, by postal vote, with the share-
holder’s prior dispatch of the agenda items
of the General Meeting and relevant ballot
papers or postal voting forms at least five
(5) days prior to the General Meeting. The
agenda items, ballot papers, and postal
voting forms may also be made available,
and their completion may also be done
electronically via the internet. Sharehold-
ers voting in this manner are counted to-
wards the quorum and majority, provided
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 242 of 370
that the relevant ballot papers and postal
voting forms have been received by the
Company at least one (1) full day before
the day of the General Meeting.
In this case, the Company shall take ade-
quate measures to:
(a) be able to ensure the identity of the
participant, the participation of per-
sons who are entitled to participate in
or attend the General Meeting and the
security of the electronic connection,
(b) enable the participant to monitor the
proceedings of the Meeting by elec-
tronic or audiovisual means and to ad-
dress the Meeting, verbally or in writ-
ing during the meeting, and to vote on
the items on the agenda and
(c) ensure the ability to record accurately
the participant’s remote voting.
The members of the Board of Directors, the
Chairman of Audit Committee, as well as
the Chartered Auditors-Accountants of the
Company are entitled to attend the Gener-
al Meeting. The head of the Internal Audit
Unit must attend the General Meetings of
shareholders. The Chairman of the General
Meeting may, under his/her responsibility,
allow the presence of other persons who
do not have shareholder status or are not
shareholders’ representatives, to the ex-
tent this is not contrary to the Company’s
interest. These persons are not considered
to be members of the General Meeting for
the sole reason that they have spoken on
behalf of a present shareholder or upon
the invitation of the Chairman.
3. Representation of shareholders at
the General Meeting
Shareholders that have the right to par-
ticipate in the General Meeting may be
represented in such by legally authorized
proxies.
4. Chairman of the General Meeting
The Chairman of the Board of Directors
temporarily presides over the General
Meeting. In case the Chairman is unable to
attend, the Deputy Chairman, as specified
in Article 9 of the Articles of Association,
or if both are unable to attend, the oldest
attending director assumes the role. The
duties of the Secretary are temporarily
performed by those appointed by the
Chairman.
Following the reading of the final list
of shareholders that have voting rights,
the Meeting proceeds with electing a
Chairman and a Secretary who also serves
as a vote teller.
5. Minutes
Copies or extracts from the minutes of the
General Meeting shall be ratified by the
Chairman or by his / her legal substitute or
by his / her replacement or by any person
appointed by the Board of Directors.
6. Shareholders’ Rights before the
General Meeting
• From the day of publication of the
invitation to convene the General
Meeting until the day of the meeting
itself, the Company posts on its
website the following information:
(a) the invitation to convene the
General Meeting,
(b) the total number of shares and
voting rights that the shares
incorporate at the date of the
invitation, indicating also separate
totals per share class,
(c) the forms to be used for voting by
a representative or delegate, and,
where provided for, by ballot paper
or mail vote and by electronic
means, and
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 243 of 370
(d) the documents to be submitted to
the General Meeting,
(e) a draft decision on each item of
the proposed agenda and the
draft resolutions proposed by
the shareholders pursuant to
paragraph 3 of article 141 of Law
4548/2018.
• The Company publishes the results
of voting on its website, under
the responsibility of the Board of
Directors, within five (5) days at the
latest from the date of the General
Meeting, specifying for each decision
at least the number of shares for which
valid votes were cast, the proportion
of capital represented by these votes,
the total number of valid votes, as well
as the number of votes in favor and
against each decision and the number
of abstentions.
7. Right of Participation and Voting
Each share is entitled to one (1) vote. Any
individual appearing as a shareholder
in the records of the Dematerialized
Securities System (DSS) managed by the
Hellenic Central Securities Depository
(ATHEXCSD) or identified as such based
on the relevant date through registered
intermediaries or other intermediaries
complying with the provisions of the law
(Law 4548/2018, Law 4569/2018, Law
4706/2020, and Regulation (EU) 2018/1212),
as well as the Operating Regulation of the
Hellenic Central Securities Depository
(ΦΕΚ Β΄ 1007/16.03.2021), is entitled to
participate in the General Meeting.
The status of the shareholder must exist
at the beginning of the fifth (5
th
) day
before the initial session of the General
Meeting. Proof of shareholder status can
be provided by any legal means, and, in
any case, based on information received
by the Company from the CSD, under the
condition it provides registry services or
through the participants and registered
intermediaries in the CSD in any other case.
For the Repeated General Meeting the
status of shareholder must exist at the
beginning of the fifth (5
th
) day prior to the
day of the General Meeting in accordance
with the provisions of article 124 par. 6 of
law 4548/2018, as in force today, provided
that the adjourned or repeated meeting
is not more than thirty (30) days from the
record date. If this is not the case or if a
new invitation is published in the case of
the repeated General Meeting, the General
Meeting is attended by the person who has
the shareholder status at the beginning of
the third (3
rd
) day before the postponed or
the repeated General Meeting.
Only those that have the shareholder
capacity during the respective record date
is considered by the Company to have
the right of participation and voting at
the General Meeting (initial and / or any
repeated meeting).
It is noted that the exercise of the above
rights (participation and voting) does not
require the blockage of the beneficiary’s
shares or any other relevant process, which
limits the ability to sell or transfer shares
during the time period between the record
date and the date of the General Meeting.
8. Minority Rights of Shareholders
Pursuant to article 141 of Law 4548/2018,
the shareholders have, inter alia, the
following rights:
(a) At the request of shareholders,
representing one twentieth (1/20) of
the paid-up share capital, the Board
of Directors is obliged to convene
an Extraordinary General Meeting of
Shareholders, appointing a meeting
date, which shall not be more than
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 244 of 370
forty five (45) days from the date of
submission of the application to the
Chairman of the Board of Directors.
The application contains the subject
of the agenda. If no General Meeting
is convened by the Board of Directors
within twenty (20) days from service
of the relevant application, the
convocation shall be carried out by the
applicant shareholders at the expense
of the Company, by a court order
issued during the injunctive measures
procedure. This decision defines the
place and time of the meeting as well
as the agenda. The decision is not
challenged by legal means.
(b) With the request of shareholders
that represent one twentieth (1/20)
of the paid-up share capital, the
Board of Directors of the Company
is obliged to list additional issues on
the General Meeting’s agenda, if the
relevant request is received by the
Board at least fifteen (15) days prior
to the General Meeting. The request
for the listing of additional issues on
the daily agenda is accompanied by a
justification or by a draft resolution for
approval by the General Meeting and
the revised agenda is published in the
same manner as the previous agenda,
at least thirteen (13) days prior to the
General Meeting date and at the same
time is disclosed to shareholders on
the Company’s website together with
the justification or draft resolution
submitted by the shareholders
according to those stipulated by article
123, paragraph 4 of Law 4548/2018.
If these issues are not published, the
requesting shareholders are entitled
to request the postponement of the
General Meeting and to make the
publication themselves.
(c) Shareholders representing one
twentieth (1/20) of the paid-up share
capital shall have the right to submit
draft decisions on issues included in
the original or any revised agenda. The
relevant application must reach the
Board of Directors seven (7) days prior
to the date of the General Meeting and
the draft decisions are made available
to the shareholders according to the
provisions of article 123 par. 3 of law
4548/2018 six (6) at least days prior to
the date of the General Meeting.
The Board of Directors is not obliged
to enroll issues on the agenda or to
publish or disclose them together
with justifications and draft decisions
submitted by the shareholders
according to the above paragraphs
b and c respectively, if their content
comes obviously contrary to law or
ethics.
(d) At the request of a shareholder
or shareholders representing one
twentieth (1/20) of the paid-up share
capital, the Chairman of the Meeting
is obliged to postpone the decision of
the General Meeting, either ordinary or
extraordinary, for all or certain items,
setting a day for the continuation of
the meeting to conclude with these
matters, the one specified in the
shareholders’ application, but this
cannot be more than twenty (20) days
from the date of the postponement.
The postponement of the General
Meeting is a continuation of the
previous one and no repetition of
the publication formalities of the
shareholders’ invitation is required.
New shareholders cannot participate
in it, subject to the relevant
participation formalities.
(e) Following a request of any shareholder
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 245 of 370
that is submitted to the Company
at least five (5) full days prior to the
General Meeting, the Board of Directors
is obliged to provide to the General
Meeting the specifically required
information on the Company’s affairs,
to the extent that such are useful for
the real assessment of the agenda
issues. No obligation to provide
information exists when the relevant
information is already available on
the Company’s website, especially in
the form of questions and answers.
Also, at the request of shareholders
representing one twentieth (1/20)
of the paid-up capital, the Board of
Directors is obliged to announce to the
General Meeting, if ordinary, the sums
paid over the last two years to each
member of the Board of Directors or
the directors of the Company, as well
as any benefit to such persons from
any cause or contract between the
Company and the members. In all the
above cases, the Board of Directors
may refuse to provide the information
for substantive reason, which is
recorded in the minutes. Such a reason
may be, under the circumstances,
the representation of the requesting
shareholders in the Board of Directors
in accordance with Articles 79 or 80
of Law 4548/2018. In the cases of this
paragraph, the Board of Directors
may respond in unison to shareholder
requests with the same content.
(f) Following a request by shareholders
that represent one tenth (1/10) of
the paid-up share capital, which
is submitted to the Company at
least five (5) full days prior to the
General Meeting, the Board of
Directors is obliged to provide to the
General Meeting information on the
development of corporate affairs and
the financial position of the Company.
The Board of Directors may decline
the provision of such information
for reasonable cause, which is stated
in the minutes. Such a reason may
be, according to the circumstances,
the representation of the requesting
shareholders in the Board of Directors
in accordance with Articles 79 or 80
of Law 4548/2018 or if the relevant
members of the Board of Directors
have received the relevant information
in a sufficient manner.
(g) At the request of shareholders
representing one twentieth (1/20) of
the paid-up share capital, the voting
on a subject or issues on the agenda
shall be made by open vote.
In all the cases of Article 141 of
Law 4548/2018, the requesting
shareholders are required to prove
their shareholder status and, except
in the cases of the first subparagraph
of paragraph 6 and paragraph 10,
the number of shares they hold in
exercising their rights. Demonstration
of shareholder status can be done
by any legal means, based on
information received by the Company
from the CSD, under the condition it
provides registry services or through
the participants and registered
intermediaries in the CSD in any other
case.
(h) Shareholders of the Company,
representing at least one twentieth
(1/20) of the paid-up share capital,
are entitled to request extraordinary
audit of the Company by court which
has jurisdiction in the procedure of
voluntary jurisdiction. Control shall be
ordered if acts that violate provisions
of the Company’s law or the Articles of
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 246 of 370
Association or decisions of the General
Meeting are suspected.
(i) Shareholders of the Company
representing one fifth (1/5) of the
paid-up share capital are entitled
to request the court to audit the
Company, since from the course of
the Company and on the basis of
certain indications it is believed that
the management of corporate affairs
is not exercised as required by sound
and prudent management. The court
may consider that the representation
of the requesting shareholders in the
Board of Directors in accordance with
Articles 79 or 80 does not justify the
shareholders’ request.
(j) Shareholders representing one
twentieth (1/20) of the paid-up share
capital have the right to submit a
written application to the Board of
Directors with the object of exercising
the Company’s claim pursuant to
article 103 of Law 4548/2018.
(k) Shareholder holding shares
representing 2 percent (2/100) of
the share capital may request the
annulment of a decision of the
General Meeting that took place in a
manner not consistent with the law or
the Articles of Association, if he/she
did not attend the General Meeting or
opposed the decision.
(l) At the request of a shareholder or
shareholders representing at least
one third (1/3) of the paid-up capital,
the Company may be dissolved by
a court order if there is an important
reason for doing so, which in a clear
and permanent manner proves that its
continuance is impossible.
9. Process for exercising voting rights
through a proxy
The shareholder participates in the
Extraordinary General Meeting and votes
either in person or through a proxy. Each
shareholder may appoint up to three (3)
proxies. Legal entities participate in the
General Meeting by appointing up to three
(3) persons as representatives. However,
if a shareholder owns Company shares,
which appear in more than one security
accounts, this limitation does not obstruct
the said shareholder from appointing
different proxies for the shares that appear
in each security account in relation to the
General Meeting. A proxy that acts on
behalf of more than one shareholder can
vote separately for each shareholder.
Specifically for shareholder participation
by proxy at the Annual Ordinary General
Meeting or any Repeated Meeting,
remotely in real-time by teleconference,
the shareholder or the Participant of the
Securities Account in the DSS or another
intermediary acting as custodian of the
shareholder and holding his/her shares
may appoint up to one (1) proxy.
A shareholder proxy must disclose to
the Company, prior to the beginning
of the Extraordinary General Meeting,
any specific event that may be useful to
shareholders in assessing the risk of the
proxy serving other interests than those of
the represented shareholder. There might
be conflict of interests specifically when
the proxy:
(a) is a shareholder that exercises control
on the Company or is another legal
entity controlled by the shareholder,
(b is a member of the Board of Directors
or generally the management of the
Company or of a shareholder that
exercising control on the Company, or
another legal entity that is controlled
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 247 of 370
by a shareholder who exercising
control of the Company,
(c) is an employee or Chartered Auditor-
Accountant of the Company or
shareholder that exercising control of
the Company, or another legal entity
controlled by the shareholder who
exercising control of the Company,
(d) is a spouse or first degree relative with
one of the persons mentioned above
in cases (a) through (c).
The appointment and revocation or
replacement of the representative or proxy
is applied in written or electronically and
submitted to the Company in the same
form, at least forty eight (48) hours prior to
the defined date of the General Meeting.
The Company makes available the form it
uses to appoint proxies on its website. This
form is submitted completed and signed
by the shareholder to the Company’s
Investor Relations Department or is sent
by fax to the latter at least forty eight (48)
hours prior to the date of the General
Meeting.
The beneficiary shareholder is requested
to confirm the successful dispatch and
receipt of the proxy form by the Company
by contacting the Company during
working days and hours.
10. Procedure for remotely
participating in the vote by Mail
vote.
In addition, shareholders have the option
to participate remotely, in person or by
proxy, at the vote on the item of the Annual
Ordinary General Meeting that will take
place before the General Meeting, under
the terms of article 126 of law 4548/2018
and under what it is mentioned below.
Specifically, shareholders that wish to
participate and vote remotely on the item
of the Annual General Meeting that will
take place before the General Meeting, can
complete, and submit the “Mail vote form”
which has been uploaded at the site of
the Company, signed with a dully verified
signature form or be sent digitally signed
by using a recognized digital signature
(qualified certificate) by the proxy or
shareholder through email.
11. Other Shareholders’ Rights &
Method of Exercise
The Company has issued common
registered shares listed on the Athens
Exchange and registered in immaterial
form in the records of the Dematerialized
Securities System. There are no special
rights in favor of specific shareholders.
The acquisition of Company shares implies
the full and without any reservation
acceptance of its Articles of Association
and of the legal decisions made by its
relevant bodies.
Each share provides rights corresponding
to the respective percentage of share
capital such represents. The responsibility
of shareholders is limited respectively
to the nominal value of shares owned. In
case of co-ownership of a share, the rights
of the co-beneficiaries are exercised only
by a joint representative of such. The co-
beneficiaries are responsible with solidarity
and entirely for fulfilling the obligations
that emanate from the common share.
Each Company share incorporates all the
rights and obligations defined by Law
4548/2018, as its Articles of Association
apply, and specifically:
• The right to participate and vote in the
General Meeting.
• The right to receive dividend from the
Company’s earnings.
• The right on the product of liquidation,
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 248 of 370
or respectively the capital depreciation
that corresponds to the share, given
that such is decided by the General
Meeting. The General Meeting of the
Company’s shareholders maintains all
its rights during liquidation.
• The pre-emptive right in any increase
of the Company’s share capital that
takes place by cash and through
the issue of new shares, as well as
the pre-emptive right in any issue
of convertible bonds, given that the
General Meeting that approves the
increase does not decide differently.
• The right to receive a copy of the
annual financial statements and
reports by the Chartered Auditors-
Accountants and Board of Directors of
the Company.
• The rights of minority shareholders
described above.
VIII. SUSTAINABLE DEVELOPMENT,
ENVIRONMENTAL AND SOCIAL
RESPONSIBILITY POLICY
This Sustainable Development, Environ-
mental and Social Responsibility Policy
(hereinafter referred to as “Policy”) is
part of the strategic framework of Thrace
Group. It governs and is integrated into
all processes and business activities of the
Group and is binding for all companies
within the Group.
1. SCOPE
The current Policy is implemented, main-
tained, and periodically reviewed. It has
been communicated to all companies
comprising the Group and is publicly avail-
able through the Group’s Website.
The implementation monitoring of the
Policy is the responsibility of the Sustain-
able Development Department, with the
assistance of the Human Resources De-
partment regarding social issues, under
the supervision of the Sustainability Com-
mittee for environmental and social issues,
and with the support of the Internal Audit
Department under the supervision of the
Audit Committee for governance issues.
During its implementation, the Group’s
companies must designate employees
with clear responsibilities for coordinating
relevant issues.
2. FUNDAMENTAL FRAMEWORK
The Group recognizes sustainable devel-
opment as one of the major challenges of
today’s era for securing the present and
the future, views the goals of sustainable
development, the principles of the circular
economy, the mitigation of climate change
impacts, and social responsibility as sig-
nificant parameters for its operation and
is committed to monitoring and continu-
ously improving its performance using ap-
propriate indicators.
3. PURPOSEAPPROACH
At the core of the Sustainable Develop-
ment Policy is the Group’s pursuit to grow
with respect for society and the environ-
ment, creating solutions for a sustainable
future, thereby remaining a reliable social
partner. Its approach to sustainable de-
velopment is based on six principles: Sup-
port circular economy, deal with climate
change, empower human capital, contrib-
ute to society, operate with integrity, en-
sure business continuity.
Under the framework of this Policy, the
Group is committed to:
• Providing all means for full compliance
with Legislation and other require-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 249 of 370
ments governing its operations.
• Systematically recognizing and evalu-
ating the impacts of its operations.
• Identifying and managing risks, op-
portunities, and best practices.
• Providing appropriate training and
raising awareness among employees
to promote a responsible culture.
• Periodically reviewing and revising its
goals.
• Improving its performance.
• Monitoring corporate performance in-
dicators through annual performance
measurement and the establishment
of annual goals.
• Communicating this Policy to employ-
ees, partners (contractors, suppliers,
customers), and the broader commu-
nity within which it operates to en-
hance their environmental and social
consciousness and promote synergies
by publishing it on the Group’s Web-
site.
4. STRATEGIC PLAN
The Group has adopted and follows a
5-year Strategic Sustainable Development
Plan based on the following strategic ob-
jectives, each of which is analyzed into
specific targets and actions:
• Reduce greenhouse gas emissions in
all processes
• Improve product environmental foot-
print
• Implement circular economy projects
• Improve social aspects affecting stake-
holders
• Ensure a responsible corporate gov-
ernance
• Build awareness and obtain appropri-
ate certifications
These pillars correspond to the dimensions
of society, the environment, and corporate
governance, encompassing the principles
of sustainable development upon which
the Group’s approach is based. In imple-
menting this Policy, the Group’s compa-
nies align both with the framework set by
the Group concerning Responsible Corpo-
rate Governance, Social Responsibility, and
Environmental Responsibility, as described
below, and with the targets outlined in the
Strategic Plan.
5. RESPONSIBLE CORPORATE
GOVERNANCE
The Group has adopted and follows a
comprehensive framework of principles,
procedures, and policies that ensure trans-
parency and responsible operation. More
specifically:
Combating Corruption and Bribery
The Group has implemented the Anti-
Fraud Policy and is committed to conduct-
ing its activities according to the highest
ethical standards, demonstrating zero
tolerance for all forms of corruption and
bribery.
Respect for Human Rights
The Group has implemented the Human
Rights Policy and is committed to zero tol-
erance concerning workplace harassment,
any form of discrimination based on race,
religion, gender, nationality, age, disability,
sexual orientation, etc., as well as forced
and child labor.
Supplier Ethics and Code of Conduct
The Group recognizes the necessity of ap-
plying ethical and deontological principles
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 250 of 370
in its supply chain. Therefore, there is a
continuous effort to evaluate significant
suppliers according to their social and
environmental commitments and perfor-
mance, thus ensuring the minimization
of risk from deviation from proper social
and environmental standards, including
labor practices and human rights, as well
as combating corruption.
Whistleblowing and “Anonymous Re-
porting” Policy
The Group has implemented a Whistle-
blowing and “Anonymous Reporting” Policy
and uses a Reporting Submission Platform,
through which it is possible to report ille-
gal behaviors related to corruption and
bribery, non-compliance, human rights
violations, or personal data breaches.
6. SOCIAL RESPONSIBILITY
The Group integrates social corporate re-
sponsibility into its strategy and addresses
social issues with care and sensitivity. The
responsibility demonstrated by the Group
and the implementation of good practices
in the societies where it operates affect
both its sustainability and the sustainabil-
ity of the societies it impacts on and the
employees it employs. Through its busi-
ness activities, the Group strives to achieve
high performance, thereby producing and
distributing direct or indirect economic
value to the social environment in which it
operates, with particular emphasis on:
• Strengthening the economies of the
countries in which it operates.
• Addressing the needs of the citizens
and societies that encompass the
Group and are affected by its activi-
ties.
• Employment, through the direct and
indirect creation and maintenance of
jobs throughout the value chain.
The Group recognizes its direct impact on
various stakeholder groups, primarily em-
ployees and local communities. Generally,
those affected by the Group’s socially re-
sponsible operations include:
Employees & Their Families
As an employer that continually evolves
and provides job security, the Group posi-
tively impacts its employees and their fam-
ilies by offering uninterrupted work and
stability in employment matters, main-
taining employment in the areas where
it operates, and expanding the number
of employees with every opportunity for
growth.
In addition to consistently meeting for-
mal obligations (payroll, social security
contributions, and taxes, etc.), the Group
provides additional benefits that target
the care of employees and cover essential
needs, such as private health insurance
programs and meal vouchers.
The Group also cares for the continuous
development of employees’ skills through
training and information programs and
emphasizes ensuring safety and health
in the workplace for all employees, part-
ners, and visitors, according to the Safety,
Health, and Environment Policy.
Local Communities & Authorities (local
authorities, public services, trade
unions)
The Group recognizes the particularities of
the local communities where it operates
and emphasizes the opportunities cre-
ated for local communities through their
activities, such as the cases where there is
a need for permanent or seasonal employ-
ment, and positions are communicated to
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 251 of 370
the local communities or priority is given
to local suppliers.
Additionally, it supports social solidarity
programs and actions to address recog-
nized social issues of charitable organiza-
tions and non-profit organizations with in-
dividual donations to cover specific needs
and support vulnerable social groups.
Simultaneously, it supports the “Stavros
Chalioris Social Center,” which is a Non-
Profit Urban Company operating since
2010 and aims to contribute practically to
society through educational, cultural, rec-
reational, and social content activities.
Customers & End Users of Products
The Group recognizes the importance of
the quality of products and services pro-
vided to customers and end users and en-
sures their quality by implementing mod-
ern, comprehensive, and certified Quality
Management Systems in its companies.
7. ENVIRONMENTAL RESPONSIBILITY
The Group always aims to improve the en-
vironmental impact resulting from its op-
erations, placing particular emphasis on
the application of circular economy prin-
ciples, responsible waste management,
reduction of energy consumption, and
limitation of greenhouse gas emissions
associated with its activities. Specifically,
it has adopted the principles of the circu-
lar economy (reduce, reuse, recycle) from
the sourcing of raw materials and product
design through to their entire life cycle. To
mitigate risks arising from climate change,
the Group adapts its business model to re-
duce its carbon footprint and energy con-
sumption, fully complying with environ-
mental legislation and contributing to the
achievement of the Sustainable Develop-
ment Goals it most significantly impacts.
In implementing this Policy, Group compa-
nies must ensure the following:
• The adoption of practices in accord-
ance with the principles of the circular
economy to ensure the efficient use
of natural resources and raw materials
through the use of recycled raw mate-
rial depending on the application and
reliable information on traceability
and recycled material content through
appropriate certifications.
• Research and innovation consistently
oriented towards the development
of sustainable products with features
such as the use of recycled raw materi-
als, the recyclability, and reusability. To
ensure the sustainable characteristics
of products, certifications that ensure
traceability and Environmental Prod-
uct Declarations (EPD) for representa-
tive product types based on Life Cycle
Assessments (LCA) can be used.
• The optimal management of solid
waste, through stream separation
aimed at their reuse or recycling and
cooperation with licensed waste recy-
clers for their optimal processing.
• The proper use and management of
chemicals by adhering to all neces-
sary safety measures during tempo-
rary storage and cooperation with a
licensed manager for their safe dis-
posal.
• The optimization of resource efficien-
cy in production units by reducing
production residues (scrap) through
appropriate actions in the production
processes and their optimal reuse.
• The optimization of energy efficiency
through the recording of energy con-
sumption and the implementation of
specific measures and actions aimed
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 252 of 370
at achieving the best possible effi-
ciency, as well as a consistent orienta-
tion towards the use of energy from
renewable sources (solar, geothermal,
and hydroelectric).
• The reduction of direct and indirect
greenhouse gas emissions through
the monitoring of data for each cat-
egory (scope 1, 2, 3) according to the
GHG Protocol methodology and ISO
14064-3, and the identification of sig-
nificant points for improvement.
• The protection and preservation of bi-
odiversity and addressing atmospher-
ic and environmental pollution with
appropriate measurements and tak-
ing measures to avoid the dispersion
of microplastics into the environment.
• The optimal management of water
consumption and liquid waste.
IX. AUDIT COMMITTEE ACTIVITY REPORT
1. SUMMARY FOR THE
MANAGEMENT
The Audit Committee’s Activity Report
is included in full, without alterations as
it was submitted by the Chairman of the
Committee, George Samothrakis.
“In my capacity as Chairman of the Audit
Committee of the Company, I hereby pre-
sent the summary Report of the Commit-
tee for the financial year 2024 (01.01.2024
- 31.12.2024), in order to demonstrate the
relevant actions and Committee’s essen-
tial contribution toward the Company’s
compliance with the provisions of cur-
rent legislative and regulatory framework
in an environment characterized by in-
tense and multilevel challenges as well as
uncertainties.
The Audit Committee constitutes an
Independent Committee and is consisted
of one (1) Independent Non-executive
Member of the Board of Directors of the
Company and two (2) non-members - third
parties.
The current Audit Committee was elected
by the Extraordinary General Meeting of
Shareholders on February 11th, 2021, as the
Committee was reconstituted into a body
following the resignation of the member
Mr. Konstantinos Gianniris and his replace-
ment by the new member Ms. Sophia
Manesi. Following the replacement of Mr.
Konstantinos Gianniris by the Annual Or-
dinary General Meeting of the Company’s
Shareholders on May 24
th
, 2023 and the
appointment of Ms. Sophia Manesi as new
member for the remainder of the term, the
Audit Committee during its meeting on
May 25
th
, 2023 was constituted in a body
as follows:
Georgios
Samothrakis
Independent Non-
Executive Member of
the Board – Chairman
Konstantinos
Kotsilinis
Third party – non
Board Member –
Member
Sofia Manesi Third party – non
Board Member –
Member
The members of the Audit Committee
have in their entirety sufficient knowledge
of the sector which the Committee acti-
vates in, while the total members of the
Audit Committee are independent of the
Company, as the following apply:
(a) They do not hold shares representing
an equity stake greater than 0.5% of
the Company’s share capital; and
(b) They do not have any dependency re-
lationship with the Company itself or
persons related to the Company. The
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 253 of 370
dependency relationship is specified
in particular in the provisions of article
9 par. 1 and 2 of Law 4706/2020.
Furthermore, the criterion of sufficient
knowledge and experience in the fields
of auditing or accounting is demonstrably
fulfilled both in the person of Mr. Geor-
gios Samothrakis and in the person of Mr.
Konstantinos Kotsilinis, both of whom are
former Chartered Auditors - Accountants
with a very broad background in terms of
scientific knowledge and with rich profes-
sional experience as well as prior profes-
sional service. The above decisively and
substantially contribute to the greater ef-
ficiency of the Audit Committee and assist
in the implementation of its duties in the
most appropriate manner with the aim of
strengthening the dynamics as well as the
value of the Company. Finally Ms. Sophia
Manesi, possessing many years of experi-
ence in Internal Auditing, can make a sub-
stantial contribution to the Audit Com-
mittee so that the latter can carry out its
work in the most effective manner and be
able to provide substantial solutions and
guidance facilitating at the same time the
economic growth of the Company, while
fulfilling all of its legal obligations.
The term of the Audit Committee is five
years, beginning on February 11, 2021 and
ending on February 11, 2026.
Furthermore, with regard to the Com-
mittee’s actions during the previous year
there is respective analysis in the following
paragraphs:
2. MEETINGS  FREQUENCY OF
ATTENDANCE OF EACH MEMBER
PER YEAR IN THE MEETINGS
The Committee convenes at least four (4)
times a year. The Chairman of the Commit-
tee decides on the frequency and sched-
ule of meetings. The independent Char-
tered Auditors- Accountants are entitled
to request a meeting with the Committee
if they deem it necessary.
During the year 2024, the Audit Commit-
tee convened eleven (11) times with all
its members present at all meetings and
with the Internal Auditors, the independ-
ent Chartered Auditors – Accountants, the
Head of the Regulatory Compliance and
Risk Management Unit along with the Fi-
nance Team of the Group and the Com-
pany informing the Committee on matters
related to their duties. In the majority of
meetings, and following a relevant invita-
tion made by the Committee, key execu-
tives in charge of the administration and
management of the various corporate af-
fairs and activities were also present.
The relevant minutes were kept for all
meetings of the Committee that took place
in year 2024, and were approved in the
subsequent meeting. During these meet-
ings the Committee mainly examined the
following issues according to the analysis
presented in the next paragraphs.
3. EXTERNAL AUDIT / FINANCIAL
INFORMATION PROCEDURE.
The Audit Committee was mainly con-
cerned with the following:
• The preparation process of financial
information and the assessment of the
financial statements of the Company
in terms of their accuracy, complete-
ness and consistency. In particular,
it was found that the financial state-
ments were in accordance with their
legally binding content and frame-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 254 of 370
work of preparation. At the same time,
the compliance with the respective
publicity rules was verified, as well as
the ability of investors and other us-
ers to have immediate, smooth and
uninterrupted access to the financial
information.
• The disclosures concerning the finan-
cial performance of the Company and
the careful review of the main parts of
financial statements that contain sig-
nificant judgments and estimates by
the Management.
• The provision of additional non-audit
services to the Company by the audit
firm to which the Chartered Auditor-
Accountant belongs. The selection
and determination of the terms of col-
laboration and the remuneration of
the Chartered Auditor- Accountant,
through a relevant proposal present-
ed at the Ordinary General Meeting of
the Company as well as the selection
criteria that should be applied and ul-
timately be fulfilled (provision of high
quality services, fair, reasonable and
competitive remuneration, etc.).
• The assurance of the state of inde-
pendence of the Chartered Auditor-
Accountant, of the objectivity and
efficiency of the audit process, based
on the relevant professional and reg-
ulatory requirements. In the above
context, the Chartered Auditor- Ac-
countant was summoned by the Audit
Committee and joined its meetings
two (2) times and more specifically
on April 15
th
and September 9
th
, 2024.
During the above meetings, the Char-
tered Auditor- Accountant confirmed
the independence and absence of any
external direction or directive or rec-
ommendation in the performance of
duties. Furthermore, monitoring and
ensuring the completeness, objectiv-
ity and effectiveness of the audit by
the Chartered Auditor- Accountant
constitutes a key priority of the Com-
mittee.
• The monthly review of the Finan-
cial Results of the Company and the
Group.
• The smooth transition and execu-
tion of the tasks of the new Chartered
Auditor, namely the audit firm ERNST
& YOUNG (HELLAS) CERTIFIED AUDI-
TORS ACCOUNTANTS S.A. (EY).
• The review of the separate and con-
solidated financial statements of the
Group and the Company for the first
half of 2024, the first quarter of 2024
and the 9-month period of 2024, as
well as the Company’s key operating
and financial figures, which were pub-
licly released for the respective peri-
ods.
During the mandatory audit, the analysis
of risks and the audit plan concerning the
fiscal year 2024 were discussed with the
Chartered Auditors. Specifically, among
other things, the Key Audit Matters for
the Annual Financial Report for the year
ended December 31, 2024, were discussed,
namely the impairment test of goodwill
(on a consolidated basis) and investments
in subsidiaries (on a corporate basis) and
the net benefit from funded defined ben-
efit plans (on a consolidated basis), which
mainly arises from the subsidiary Don &
Low LTD. Additionally, the main risks and
significant developments in the business
environment that could affect the results
of the fiscal year were discussed. Further-
more, issues such as the materiality thresh-
old and estimates regarding the criteria for
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 255 of 370
selecting entities subject to audit for con-
solidation purposes (scoping), the scope
and results of the audit, and any problems
that arose during the audit process due
to the complexity of the audit work were
analyzed. Following these discussions, the
correctness and completeness of the audit
procedures were confirmed, based on the
relevant regulatory provisions.
4. PROCESS OF NONFINANCIAL
INFORMATION SUSTAINABILITY
REPORT.
Thrace Group has put into effect since 2021
an official Sustainable Development, Envi-
ronmental and Social Responsibility Policy,
which was reviewed and approved in 2024
by the Audit Committee. At the same time,
the Group has adopted and is following a
5-year Strategic Plan for Sustainable Devel-
opment based on the following axes, each
of which is broken down into specific ac-
tions and goals:
• Reduction of greenhouse gas emis-
sions in all production processes;
• Improving the environmental impact
of products;
• Implementation of circular economy
related projects;
• Improving social aspects concerning
the stakeholders;
• Ensuring responsible corporate gov-
ernance;
• Awareness and certification of activi-
ties.
These axes correspond to the pillars of so-
ciety, environment and corporate govern-
ance and include the principles of sustain-
able development upon which the Group’s
approach is based.
The focus areas of the above strategy have
emerged through the recognition and
prioritization -by the Management of the
Group- of the essential issues of sustain-
able development (according to the inter-
national standards of Sustainable Devel-
opment, GRI – Global Reporting Initiative),
aiming at their timely, lawful and effective
management of those issues and the de-
livery of tangible results for the creation of
a greater value in the economy, the envi-
ronment and the society where the Group
operates.
Especially in recent years, the transition
from the model of linear economy to the
one of circular economy has been a great
challenge for the Group, as it creates op-
portunities for further growth and devel-
opment. Fully in line with the European
strategy on plastics, the Group has taken
initiatives to enter into the era of circu-
lar economy with the aim of reducing its
environmental footprint. In this context,
the Group constantly adapts its business
model in order to reduce its carbon foot-
print and focus on the development of in-
novative products and services, applying
the principles of the circular economy. The
strategy, plans, results and related com-
mitments are analyzed in the Group’s Sus-
tainability Report.
It is noted that for the financial years be-
ginning on 1.1.2024, the parent compa-
nies of large corporate groups with se-
curities traded on the Athens Exchange,
Greece, are required to publish Sustain-
ability Reports in accordance with Law
No. 5164/2024 (Government Gazette
202/12.12.2024), the CSRD (Corporate Sus-
tainability Reporting Directive) and ESRS
(European Sustainability Reporting Stand-
ards) (EC announcement with protocol
number 373/14.02.2025).
In addition, in accordance with Article 7
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 256 of 370
par. 1 of Law No. 5164/12.12.2024 the infor-
mation included in the Sustainability Re-
port must be clearly identifiable in a spe-
cial section of the Management Report of
the Board of Directors (EC announcement
with protocol number 506/07.03.2025).
It is noted that the Audit Committee, ap-
plying the provisions of Article 43 of Law
5164/2024 and the aforementioned an-
nouncements of the Listed Companies Di-
vision of the Hellenic Capital Market Com-
mission:
A) Approved the appointment of the au-
dit firm employing the Certified Public
Accountant who carries out the audit
of the Financial Statements of the Fi-
nancial Year 2024, as responsible for
the Audit of the Sustainability Report
of the Financial Year 2024 in accord-
ance with the provisions of Article 7 of
Law 5164/2024 and submitted the rel-
evant recommendation to the Board
of Directors for final approval.
B) Received information and update from
the audit firm employing the Certified
Public Accountant who conducted the
audit for the preparation of the 2024
Sustainability Report in accordance
with the CSRD directive.
It is noted that the Group’s Sustainability
Committee also received information and
update from the audit firm employing the
Certified Chartered Accountant who con-
ducted the audit of the 2024 Sustainability
Report in accordance with the CSRD direc-
tive.
5. INTERNAL CONTROL AND RISK
MANAGEMENT SYSTEM / INTERNAL
AUDIT UNIT
The Audit Committee also dealt with the
following:
• The supervision of the Company’s in-
ternal audits and monitoring the ef-
fectiveness of the Company’s internal
control and risk management systems
to ensure that the main risks (such
as risk of fluctuations in raw material
prices, credit risk, liquidity risk, foreign
exchange risk, interest rate risk, capital
adequacy risk, etc.) are properly iden-
tified, addressed and disclosed.
• Ensuring the independence of the
Internal Audit Unit, monitoring its
smooth operation in accordance with
international standards for the profes-
sional implementation of internal con-
trol procedures, but also in line with
the current legal and regulatory frame-
work (indicatively Law 4706/2020, as
currently in force).
• Informing the Audit Committee, re-
garding the work of the Internal Audit
Unit and its audit reports, the evalua-
tion of the work, the adequacy as well
as the efficiency of the unit as well as
of the Head of Internal Audit.
• The submission of the audit reports
from the Internal Audit Unit to the
Board of Directors.
• The information provided to the Board
of Directors of the Company regarding
the areas that the Audit Committee,
during the exercise of its duties, con-
siders that there are essential issues
and the monitoring of the response of
the Management on the above issues.
• Defining and reviewing the operating
regulation of the Internal Audit Unit of
the Company.
• ·The identification of possible cases of
conflict of interest during the Compa-
ny’s transactions with related parties
or any unusual transactions that have
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 257 of 370
not taken place under normal market
practices and the submission of the
relevant reports to the Board of Direc-
tors.
• Ensuring the existence of the required
procedures, according to which the
Company’s personnel will be able, in
confidentiality, to express their con-
cerns about possible illegalities and
irregularities in matters of financial
information or other issues related to
the operation of the Company, which
they should then be properly investi-
gated and addressed.
It is noted that the Audit Committee fully
complying with the key points, clarifica-
tions and recommendations as well as
the Questions and Answers (Q&As) of
the documents with protocol number
784/20.03.2023 of the Department of
Listed Companies of the Hellenic Capital
Markets Commission underlines that both
the main and the supplementary report
submitted by the regular Chartered Audi-
tor-Accountant does not include any of the
following:
o Important issues regarding financial
information and reporting, and
o Weaknesses on the level of the in-
ternal control system with regard to
the Chartered auditor-accountant’s
supplementary report to the Audit
Committee.
Additionally, as already mentioned in the
above paragraphs, the Audit Committee
during the fiscal year of 2024:
o Was informed of all the findings re-
sulting from the reports compiled
by the Internal Audit Unit,
o Submitted specific proposals in re-
lation to the above reports and find-
ings either to the Internal Audit Unit
or to the Company’s Board of Direc-
tors, and in all cases there was a cor-
responding response to all issues
that emerged.
6. REGULATORY COMPLIANCE
AND RISK MANAGEMENT /
REGULATORY COMPLIANCE AND RISK
MANAGEMENT UNIT
In the context of implementation of Law
4706/2020, the supervision of the Regula-
tory Compliance and Risk Management
Unit was included in the responsibilities
of the Audit Committee, and therefore the
Audit Committee mainly dealt with the fol-
lowing:
• Monitoring the level of compliance
with corporate governance and spe-
cific governance practices such as data
protection, cyber security and infor-
mation security.
• Ensuring that there were no cases of
conflict of interest in the Company’s
transactions with related parties and
updating the Board of Directors about
the specific issue.
• Monitoring the process and the im-
plementation of the risk assessment
exercise on the level of the Company
and its subsidiaries. The respective ex-
ercises were submitted by the External
Consultant to the Audit Committee.
• The monitoring of the process and
the implementation of assessment
of the Company’s Corporate Govern-
ance System with a reporting date of
31.12.2024 and a reporting period of
01.01-31.12.2024, as carried out by the
Secretary of the Board of Directors
with the assistance of the Regulatory
Compliance & Risk Management Unit,
following the same audit, with a re-
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 258 of 370
porting date as of 31.12.2023 and with
a reporting period from the entry into
force of article 14 of Law 4706/2020
(17.07. 2021).
• Ensuring that there are structures and
procedures, according to which the
Company’s personnel will be able, in
confidence, to express concerns about
potential illegalities and irregularities
in matters of financial information or
about other issues related to the op-
eration of the business (Whistleblow-
ing). Also ensuring the performance of
effective and independent investiga-
tion of such matters and their appro-
priate handling.
• Informing the Board of Directors
about the issues arising from the work
carried out on the above areas.
A summary of the items of the agenda of
the Audit Committee per meeting is being
attached to the current document.
Finally, it is noted that during the exercise
of our Audit Committee’s duties, we have
and continue to have unhindered and full
access to all the information we need each
time, while our Company provides the nec-
essary infrastructure and space in order to
effectively perform all our duties.
Georgios Samothrakis
Chairman of the Audit Committee of
Thrace Plastics Co S.A.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 259 of 370
8. APPENDIX  SUMMARY OF THE ITEMS OF THE AGENDA OF THE AUDIT
COMMITTEE PER MEETING
SUMMARY OF THE AUDIT COMMITTEE MEETINGS
OF THRACE PLASTICS GROUP FOR THE FINANCIAL YEAR 2024
Date of
Meeting
Items of the Meeting's Agenda
Participation
10.4.2024 1. Validation of minutes of previous meeting.
2. Review and approval of the quarterly report of the Internal
Audit Department’s activities for Q1 2024.
3. Approval of the Annual Report of the Audit Committee for
the fiscal year 2023.
4. Other matters.
Quorum
15.4.2024 1. Validation of the minutes of the previous meeting.
2. Presentation by PwC on the regular audit and conclusions.
3. Discussion on the drafts of the Financial Statements and
the Reports of the Certified Public Accountants.
4. Validation of the Memorandum of the Audit Committee
submitted to the Board of Directors
Quorum
19.4.2024
1. Validation of the minutes of the previous meeting.
2. Progress of the Internal Audit Department’s activities
(including internal audits formally distributed recently and
not yet presented to the Audit Committee).
3. Presentation of the progress of corrective actions by the
auditees on the findings of past audit reports.
4. Presentation and approval of the 2024 annual work plan of
the Internal Audit Department.
5. Progress of the Regulatory Compliance & Risk Management
Department’s activities.
6. Presentation and approval of the 2024 annual work
plan of the Regulatory Compliance & Risk Management
Department.
7. Other matters.
Quorum
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 260 of 370
Date of
Meeting
Items of the Meeting's Agenda
Participation
29.4.2024
1. Validation of minutes of previous meeting.
2. Proposal for the Election of an Auditing Company from the
Public Registry for the mandatory audit of the annual and
semi-annual Financial Statements of the current financial
year 2023 (01.01.2023-31.12.2023) and determination of its
remuneration.
3. Approval of the Audit Committee’s Memorandum to the
Board of Directors
4. Quarterly update from the Chairman of the Audit
Committee to the Board of Directors.
Quorum
27.5.2024
1. Validation of minutes of the previous meeting.
2. Approval of the financial statements for the period ending
March 31, 2024, and the related memorandum of the Audit
Committee to the Board of Directors
Quorum
20.6.2024
1. Validation of minutes of the previous meeting.
2. Review and approval of the Sustainable Development,
Environmental, and Social Responsibility Policy by
circulation.
Quorum
10.7. 2024
1. Validation of Minutes of the Previous Meeting.
2. Review and approval of the quarterly report of the Internal
Audit Department’s activities for Q2 2024.
3. Review and approval of the semi-annual report of
the Regulatory Compliance and Risk Management
Department’s activities and the semi-annual risk
management report for 2024.
4. Quarterly update from the Chairman of the Audit
Committee to the Board of Directors.
5. Other matters.
Quorum
9.9.2024
1. Validation of Minutes of Previous Meeting.
2. Update from external auditors on the semi-annual
financial statements for 2024.
3. Approval of the semi-annual financial statements for 2024
and the related memorandum of the Audit Committee to
the Board of Directors.
4. Discussion of the Audit Committee on the evaluation of
the Corporate Governance System for the current fiscal
year.
5. Quarterly update from the Chairman of the Audit
Committee to the Board of Directors.
Quorum
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 261 of 370
Date of
Meeting
Items of the Meeting's Agenda
Participation
18.9.2024
1. Validation of minutes of previous meeting.
2. Approval of the significant issues of the Group based
on the G1 standard within the framework of the new
European CSRD directive.
Quorum
15.10.2024
1. Validation of minutes of previous meeting.
2. Review and approval of the quarterly report of the Internal
Audit Department’s activities for Q3 2024.
3. Other matters.
Quorum
13.11.2024
1. Validation of minutes of previous meeting.
2. Approval of the financial statements for the period ending
September 30, 2024, and the related memorandum of the
Audit Committee to the Board of Directors.
3. Quarterly update from the Chairman of the Audit
Committee to the Board of Directors.
Quorum
Xanthi, 24 April 2025
The undersigned:
The Chairman of the
Board of Directors
The Chief Executive
Officer & Executive
Member of the Board of
Directors
The Non-Executive
Member of the Board of
Directors
Konstantinos St. Chalioris Dimitris P. Malamos Vasileios S. Zairopoulos
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 262 of 370
Audit Reports
by Independent
Certified Auditor
A member firm of Ernst & Young Global Limited
ERNST & YOUNG (HELLAS)
Certified Auditors-Accountants S.A.
8B Chimarras str., Maroussi
151 25 Athens, Greece
Tel : + 30 2 10 2886 0 0 0
ey.com
THIS REPORT IS A FREE TRANSLATION FROM THE GREEK ORIGINAL
Independent practitioner’s limited assurance report on THRACE PLASTICS Co S.A.
To the shareholders of «THRACE PLASTICS Co S.A.»
We have conducted a limited assurance engagement on the consolidated Sustainability Statement of «THRACE
Plastics CO S.A.» (hereinafter the “Company”) and its subsidiaries (collectively referred to as the “Group”), included
in section Sustainability Statement of the consolidated Board of Directors’ Report (hereinafter the “Sustainability
Statement”), for the period from 01.01.2024 to 31.12.2024.
Limited assurance conclusion
Based on the procedures we have performed, as described below in the paragraph “Scope of Work Performed”, as
well as the evidence obtained, nothing has come to our attention that causes us to believe that:
• the Sustainability Statement is not prepared, in all material respects, in accordance with article 154 of L.
4548/2018 as amended and in effect by L. 5164/2024 with which it was incorporated into Greek legislation
the article 29(a) of EU Directive 2013/34/EU;
• the Sustainability Statement does not comply with the European Sustainability Reporting Standards
(hereinafter “ESRS”), in accordance with Regulation (EU) 2023/2772 of the Commission of 31 July 2023
and Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022;
• the process carried out by the Company for the identification and assessment of material impacts, risks
and opportunities (hereinafter the "Process"), as set out in section “IRO-1 – Description of Procedures for
Identifying and Evaluating Significant Impacts, Risks, and Opportunities in the Double Materiality
Assessment (DMA)” of the Sustainability Statement, does not comply with "Requirement IRO-1-
Description of the processes to identify and assess material impacts, risks and opportunities" of ESRS 2
"General Disclosures";
• the disclosures of section “EU Taxonomy” of the Sustainability Statement do not comply with article 8 of
EU Regulation 2020/852.
This assurance report does not extend to information for previous periods.
Basis for the conclusion
The limited assurance engagement was conducted in accordance with International Standard on Assurance
Engagements (ISAE) 3000 (Revised) “Assurance Engagements Other than Audits or Reviews of Historical Financial
Information” (hereinafter “ISAE 3000”).
The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for,
a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance
engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance
engagement been performed.
Our responsibilities are further described in the “Practitioner’s Responsibilities” section.
A member firm of Ernst & Young Global Limited
Professional Ethics and Quality Management
We are independent from the Company and its consolidated subsidiaries, throughout this work and have complied
with the requirements of the Code of Ethics for Professional Accountants issued by the International Ethics
Standards Board for Accountants (IAS Code), the ethics and independence requirements of L.4449/2017 and EU
Regulation 537/2014.
Our firm applies the International Standard on Quality Management (ISQM) 1 “Quality Management for Firms that
Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services engagements”, and
consequently maintains a comprehensive quality management system, which includes documented policies and
procedures regarding compliance with ethical requirements, professional standards, and applicable legal and
regulatory requirements.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion.
Responsibilities of the Company’s Management for the Sustainability Statement
The Company’s Management is responsible for designing and implementing an appropriate process to identify the
information reported in the Sustainability Statement in accordance with the ESRS and for disclosing this Process in
section “IRO-1 – Description of Procedures for Identifying and Evaluating Significant Impacts, Risks, and
Opportunities in the Double Materiality Assessment (DMA)” of the Sustainability Statement.
More specifically, this responsibility includes:
• Understanding the context in which the Group activities and business relationships take place and developing
an understanding of its affected stakeholders;
• The identification of the actual and potential impacts (both negative and positive) related to sustainability
matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the Group’s
financial position, financial performance, cash flows, access to finance or cost of capital over the short-,
medium-, or long-term;
• The assessment of the materiality of the identified impacts, risks and opportunities related to sustainability
matters by selecting and applying appropriate thresholds; and
• Making assumptions that are reasonable in the circumstances.
The Company’s Management is further responsible for the preparation of the Sustainability Statement, in
accordance with article 154 of L. 4548/2018, as amended and in force with L. 5164/2024 by which article 29(a) of
EU Directive 2013/34 was incorporated into Greek legislation.
In this context, the Company’s Management is responsible for:
• Compliance of the Sustainability Statement with the ESRS;
• Preparing the disclosures in section “EU Taxonomy” of the Sustainability Statement, in compliance with
Article 8 of EU Regulation 2020/852;
• Designing and implementing such internal controls that management determines are necessary to enable the
preparation of the Sustainability Statement, that is free from material misstatement, whether due to fraud or
error; and
• Selecting and implementing appropriate reporting methods and making assumptions and estimates about
individual sustainability disclosures within the Sustainability Statement that are reasonable in the
circumstances.
The Company’s Audit Committee is responsible for supervising the drafting process of the Company’s Sustainability
Statement.
A member firm of Ernst & Young Global Limited
Inherent limitations in preparing the Sustainability Statement
In reporting forward-looking information in accordance with ESRS, the Company’s Management is required to
prepare the forward-looking information on the basis of disclosed assumptions, about events that may occur in the
future and possible future actions by the Group. The actual outcome is likely to be different since anticipated events
frequently do not occur, as expected.
As stated in section ESRS2: IRO-1 Description of the processes for identifying and assessing material climate-related
impacts, risks, and opportunities” of the Sustainability Statement, the information incorporated in the relevant
disclosures is based, among other things, on climate-related scenarios, which are subject to inherent uncertainty
regarding the likelihood, timing or impact of potential future natural and transient climate-related impacts.
Our work covered the items listed in the “Scope of Work Performed” section to obtain limited assurance based on
the procedures included in the Program, as this is defined in this section.
Our work does not constitute an audit or review of historical financial information, in accordance with the
applicable International Standards on Auditing or International Standards on Review Engagements, and therefore
we do not express any assurance other than those listed in the "Scope of Work Performed" section.
Practitioner’s responsibilities
This limited assurance report has been drawn up based on the provisions of Article 154C of L. 4548/2018 and Article
32A of L.4449/2017.
Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the
Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited
assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered
material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken
on the basis of the Sustainability Statement as a whole.
As part of a limited assurance engagement in accordance with ISAE 3000, we exercise professional judgement and
maintain professional skepticism throughout the engagement.
Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:
• Carrying out risk assessment procedures, including an understanding of the relevant internal control gaps, to
identify risks related to whether the Process, followed by the Group to determine the information referred to
in the Sustainability Statement does not cover the applicable requirements of the ESRS, but not for the purpose
of providing a conclusion regarding the effectiveness of the internal controls on the Process and
• Designing and carrying out procedures to assess whether the Process for identifying the information referred
to in the Sustainability Statement is consistent with the description of the Process as disclosed in section “IRO-
1 – Description of Procedures for Identifying and Evaluating Significant Impacts, Risks, and Opportunities in the
Double Materiality Assessment (DMA)” of the said Statement.
A member firm of Ernst & Young Global Limited
Legal Name: ERNST & YOUNG (HELLAS) Certified Auditors-Accountants S.A.
Distinctive title: ERNST & YOUNG
Legal form: Societe Anonyme
Registered seat: Chimarras 8Β, Maroussi, 15125
General Commercial Registry No: 000710901000
Moreover, we are responsible for:
• Performing risk assessment procedures, including an understanding of the relevant internal control
mechanisms, to identify those disclosures that are likely to be materially misstated, whether due to fraud or
error, but not for the purpose of providing a conclusion on the effectiveness of the Group's internal control
mechanisms.
• Designing and carrying out procedures related to those disclosures of the consolidated Sustainability
Statement, in which a material error is likely to occur. The risk of not detecting a material misstatement arising
from fraud is higher than that arising from error, as fraud may involve collusion, forgery, intentional
omissions, misrepresentations or the circumvention of internal control barriers.
Scope of Work Performed
Our work includes performing procedures and obtaining assurance evidence for the purpose of deriving a limited
assurance conclusion and covers only the limited assurance procedures provided for in the limited assurance
program issued by ELTE's decision 22.01.2025 (hereinafter "Program"), as it was formed for the purpose of
issuing a limited assurance report on the Group's Sustainability Statement.
Our procedures were designed to obtain a limited level of assurance on which to base our conclusion and do not
provide all of the evidence that would be required to provide a reasonable level of assurance.
Athens, 25 April 2025
The Certified Auditor Accountant
Maria Chatziantoniou
SOEL R.Ν.: 25301
ERNST & YOUNG (HELLAS)
CERTIFIED AUDITORS ACCOUNTANTS S.A.
CHIMARRAS 8Β
151 25 MAROUSSI, GREECE
Company SOEL R.N.: 107
A member firm of Ernst & Young Global Limited
ERNST & YOUNG (HELLAS)
Certified Auditors-Accountants S.A.
8B Chimarras str.
, Maroussi
151 25 Athens, Greece
Tel.: 210 2886 000
Fax: 210 2886 905
ey.com
THIS REPORT HAS BEEN TRANSLATED FROM THE ORIGINAL VERSION IN GREEK
Independent Auditor’s Report
To the Shareholders of «THRACE PLASTICS Co S.A.»
Report on the Audit of the Separate and Consolidated Financial Statements
Opinion
We have audited the accompanying separate and consolidated financial statements of «THRACE PLASTICS Co S.A.» (the
“Company”), which comprise the separate and consolidated statements of financial position as at December 31, 2024,
and the separate and consolidated statements of comprehensive income, changes in equity and cash flows for the year
then ended, and notes to the financial statements, including material accounting policy information.
In our opinion, the accompanying separate and consolidated financial statements present fairly in all material respects,
the financial position of «THRACE PLASTICS Co S.A.» and its subsidiaries (“the Group”) as at December 31, 2024 and their
financial performance and their cash flows for the year then ended in accordance with International Financial Reporting
Standards (“IFRS”), as endorsed by the European Union.
Basis for Opinion
We conducted our audit in accordance with International Standards on Auditing (“ISAs”), as incorporated in Greek Law.
Our responsibilities under those standards are further described in the “Auditor’s Responsibilities for the Audit of the
Separate and Consolidated Financial Statements” section of our report. We remained independent of the Company and
the Group throughout the period of our appointment in accordance with the International Ethics Standards Board for
Accountants’ Code of Ethics for Professional Accountants (“IESBA Code”), as incorporated in Greek Law, together with
the ethical requirements that are relevant to the audit of the separate and consolidated financial statements in Greece,
and we have fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA Code. We
believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Key audit matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the
separate and consolidated financial statements of the current period. These matters and the related risks of material
misstatement were addressed in the context of our audit of the separate and consolidated financial statements as a
whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.
For each matter below, our description of how our audit addressed the matter is provided in that context.
We have fulfilled the responsibilities described in the “Auditor’s Responsibilities for the Audit of the Separate and
Consolidated Financial Statements” section of our report, including in relation to these matters. Accordingly, our audit
included the performance of procedures designed to respond to our assessment of the risks of material misstatement of
the separate and consolidated financial statements. The results of our audit procedures, including the procedures
performed to address the matters below, provide the basis for our audit opinion on the accompanying separate and
consolidated financial statements.
A member firm of Ernst & Young Global Limited
Key audit matter
How our audit addressed the key audit matter
Impairment test of goodwill (Consolidated Financial Statements) and investments in subsidiaries (Separate Financial Statements)
As of December 31, 2024, the Group has recognized goodwill of Euro
9,6 million in the consolidated Statement of financial position.
Additionally, as of December 31, 2024, the Company has recognized
investment in subsidiaries of Euro 74 million.
After initial recognition goodwill is measured by the Group at cost less
accumulated impairment losses.
In accordance with the requirements of IAS 36, Management performs
an impairment test of goodwill on an annual basis or more frequently
when there are indications of a potential impairment of the carrying
amount of goodwill in relation to its recoverable value.
Goodwill is allocated to cash-generating units (individual subsidiaries),
and Management determines their recoverable value as the higher of
their value in use and fair value less costs of disposal. In the event of
impairment, this is recognized directly as an expense in the Group's
statement of comprehensive income and cannot be reversed
subsequently.
In addition, Management examines on an annual basis whether there
are indications of impairment of its investments in subsidiaries. If
indications of impairment occur, Management evaluates the potential
impairment of the investment by calculating the impairment amount as
the difference between the recoverable value of the investment and its
carrying value. The recoverable amount is determined as the higher of
the value in use and the fair value less costs of disposal. If an
impairment is identified, it is recognized as an expense in the
Company's statement of comprehensive income.
Given that the goodwill is allocated to individual subsidiaries, if
Management identifies an indication of impairment of the Company's
investment in a subsidiary to which goodwill has been allocated, the
evaluation process for the impairment test of both the goodwill and the
investment is based on the same procedure and assumptions.
The calculation of the value in use for each cash-generating unit is
conducted by an independent appraiser and is based on Management’s
estimates and assumptions for the future performance of the cash-
generating units, such as the growth rate in perpetuity, projections of
future sales volumes and prices, gross profit margins and discount
rates.
Due to the fact that the above estimates require a significant level of
judgment by the Management and considering the significant balance
of these figures in the separate and consolidated financial statements,
we have assessed the impairment test of goodwill and investments in
subsidiaries as one of the key audit matters.
The Company’s and the Group’s disclosures regarding the accounting
policy, as well as the judgments and estimates used in the evaluation of
the impairment of goodwill and investment in subsidiaries, are included
in the notes 2.3.1.2, 2.3.1.3, 2.6.1, 3.13, and 3.28.1 of the separate and
consolidated financial statements.
With the support of our valuation specialists, among others, we
performed, the following audit procedures:
• We assessed the process followed by the Management for the
impairment test of goodwill.
• We evaluated Management’s assessment and its conclusion
regarding the existence of any indications of impairment in the
investments in subsidiaries.
• We have obtained and reviewed the reports of an independent
external appraiser used by the Management for the determination
of the recoverable amount of goodwill per cash-generating unit to
which the goodwill has been allocated.
• We evaluated the Management's analysis according to which the
recoverable amounts of the cash-generating units, as determined
within the context of the goodwill impairment test, were correlated
with the corresponding investments in subsidiary companies.
• With the support of our valuation specialists, we assessed the
appropriateness of the models used for estimating the recoverable
amount as well as the reasonableness of the significant assumptions
and estimates made by the Management, such as future cash flows,
growth rate in perpetuity, forecasts of future sales volume and
prices, gross profit margin, and discount rates.
• We assessed Management's forecasts for future cash flows by
comparing actual performance with forecasts from previous years.
• We evaluated the impact of a potential change in the key
assumptions on the recoverable amount of the cash-generating
units.
In addition, we evaluated the adequacy and consistency of the disclosures
in the relevant notes of the separate and consolidated financial
statements with respect to the requirements of the relevant accounting
standards.
A member firm of Ernst & Young Global Limited
Key audit matter
How our audit addressed the key audit matter
Net benefit from funded defined benefit plans (Consolidated Financial Statements)
As of December 31, 2024, an amount of Euro 6 million is included in the
consolidated statement of financial position, which pertains to the net
benefit from funded defined benefit plans of foreign subsidiary
companies, primarily arising from the subsidiary company Don & Low
LTD. The net benefit results from the present value of liabilities
amounting to Euro 101.4 million, reduced by the fair value of the assets
of the funded defined benefit plans amounting to Euro 107.4 million
The estimated future benefits are discounted to present value after
deducting the fair value of the assets of the funded defined benefit
plans. The present value of liabilities for post-employment benefits
depends on various factors, which are determined through an actuarial
study conducted by an independent actuary, using significant
assumptions. The fair value of the assets of the funded defined benefit
plans primarily pertains to the fair value of mutual funds.
Among the assumptions considered in the actuarial study to determine
the net benefit for post-employment benefits are the discount rate,
inflation, and the average annual salary increase. Any changes in these
assumptions may significantly impact the valuation of liabilities for
post-employment benefits, making this item volatile, taking also into
consideration the significant impact of changes in the fair value of the
assets of the funded defined benefit plans.
Due to the significance of the present value of liabilities and the fair
value of the assets of funded defined benefit plans in the consolidated
financial statements, the key assumptions and estimates used by
Management for the actuarial study, as well as the uncertainty
regarding the potential impact of legal developments in England on the
liabilities from funded defined benefit plans, we have assessed the
determination of the net benefit from funded defined benefit plans as
one of the key audit matters.
The Group's disclosures regarding the accounting policy, as well as the
judgments and estimates used in determining the net benefit from
funded defined benefit plans, are included in the notes 2.15.2 and 3.21
of the consolidated financial statements.
Among others, we have performed the following audit procedures:
• We evaluated the Group's accounting policy regarding funded
defined benefit plans and its alignment with the applicable
accounting standards.
• With the support of our specialists, we evaluated the actuarial study
prepared for calculating the present value of liabilities for post-
employment benefits to identify any potential deviations from IFRS.
In addition, we performed procedures to assess the reasonableness
of the key assumptions made by Management, that were used in the
preparation of the actuarial study.
• We assessed the methodology used for the preparation of the
actuarial study, along with the assumptions and the sources of
information determined by Management, as well as their
consistency compared to the previous fiscal year and with
observable market data.
• We evaluated the completeness and accuracy of the data used to
calculate the net benefit from funded defined benefit plans.
• We performed audit procedures regarding the evaluation of the fair
value of the assets of funded defined benefit plans. More specifically,
we obtained a complete list of the assets held within the defined
benefit plan, categorized by asset type and investment manager, and
reconciled their value with the assets included in the actuarial study,
and performed substantive audit procedures to obtain appropriate
audit evidence regarding the fair value of the assets, taking into
account the type of asset.
• We evaluated the available data and Management's assessment
regarding the uncertainty of the potential impact of legal
developments in England on the liabilities from funded defined
benefit plans, in relation to the modifications of the funded defined
benefit plan of the subsidiary company Don & Low LTD.
• We reconciled the present value of liabilities and the fair value of the
assets of funded defined benefit plans as depicted in the actuarial
study with the consolidated financial statements.
In addition, we evaluated the adequacy and consistency of the disclosures
in the relevant notes of the consolidated financial statements with
respect to the requirements of the relevant accounting standards.
A member firm of Ernst & Young Global Limited
Other matter
The separate and consolidated financial statements of the Company «THRACE PLASTICS Co S.A.» for the year ended 31
December 2023, were audited by another Certified Auditor Accountant, who expressed an unmodified opinion on those
statements on 23 April 2024.
Other information
Management is responsible for the other information in the Annual Financial Report. The other information, includes the
Board of Directors’ Report, for which reference is also made in section “Report on Other Legal and Regulatory Requirements”,
the Statements of the Members of the Board of Directors, and any other information either required by law or voluntarily
incorporated by the Company in its Annual Financial Report prepared in accordance with Law 3556/2007, but does not
include the separate and consolidated financial statements and our auditor’s report thereon.
Our opinion on the separate and consolidated financial statements does not cover the other information and we do not
express any form of assurance conclusion thereon.
In connection with our audit of the separate and consolidated financial statements, our responsibility is to read the other
information identified above and, in doing so, consider whether the other information is materially inconsistent with the
separate and consolidated financial statements, or our knowledge obtained in the audit, or otherwise appears to be
materially misstated. If, based on the work we have performed, we conclude that there is a material misstatement of this
other information, we are required to report that fact. We have nothing to report in this regard.
Responsibilities of the Management and Those Charged with Governance for the Separate and Consolidated Financial
Statements
Management is responsible for the preparation and fair presentation of the separate and consolidated financial statements
in accordance with International Financial Reporting Standards as endorsed by the European Union, and for such internal
control as management determines is necessary to enable the preparation of separate and consolidated financial statements
that are free from material misstatement, whether due to fraud or error.
In preparing the separate and consolidated financial statements, management is responsible for assessing the Company’s
and Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the
going concern basis of accounting unless management either intends to liquidate the Company and the Group or to cease
operations, or has no realistic alternative but to do so.
The Company’s Audit Committee (Article 44, Law 4449/2017) is responsible for overseeing the Company’s and the Group’s
financial reporting process.
A member firm of Ernst & Young Global Limited
Auditor’s Responsibilities for the Audit of the Separate and Consolidated Financial Statements
Our objectives are to obtain reasonable assurance about whether the separate and consolidated financial statements as a
whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our
opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with
ISAs, as incorporated in Greek Law, will always detect a material misstatement when it exists. Misstatements can arise from
fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence
the economic decisions of users taken on the basis of these separate and consolidated financial statements.
As part of an audit in accordance with ISAs, as incorporated in Greek Law, we exercise professional judgment and maintain
professional scepticism throughout the audit. We also:
• Identify and assess the risks of material misstatement of the separate and consolidated financial statements, whether
due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is
sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting
from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions,
misrepresentations, or the override of internal control.
• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate
in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Company’s and the
Group’s internal control.
• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related
disclosures made by management.
• Conclude on the appropriateness of management’s use of the going concern basis of accounting and, based on the audit
evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt
on the Company’s and the Group’s ability to continue as a going concern. If we conclude that a material uncertainty exists,
we are required to draw attention in our auditor’s report to the related disclosures in the separate and consolidated
financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit
evidence obtained up to the date of our auditor’s report. However, future events or conditions may cause the Company
and the Group to cease to continue as a going concern.
• Evaluate the overall presentation, structure and content of the separate and consolidated financial statements, including
the disclosures, and whether the separate and consolidated financial statements represent the underlying transactions
and events in a manner that achieves fair presentation.
• Plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the financial information of
the entities or business units within the Group as a basis for forming an opinion on the consolidated financial statements.
We are responsible for the direction, supervision and review of the audit work performed for the purposes of the group
audit. We remain solely responsible for our audit opinion.
We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the
audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant ethical requirements
regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought
to bear on our independence, and where applicable, related safeguards.
From the matters communicated with those charged with governance, we determine those matters that were of most
significance in the audit of the separate and consolidated financial statements of the current period and are therefore the
key audit matters.
A member firm of Ernst & Young Global Limited
Report on Other Legal and Regulatory Requirements
1. Board of Directors’ Report
Taking into consideration that management is responsible for the preparation of the Board of Directors’ Report and the
Corporate Governance Statement that is included therein, in accordance with the provisions of paragraph 1, citations aa, ab
and b, of article 154C of Law 4548/2018, which do not include the sustainability statement, on which we have issued a limited
assurance report dated 25/04/2025, based on International Standard on Assurance Engagements 3000 (Revised), we report
that:
a) The Board of Directors’ Report includes a Corporate Governance Statement that contains the information required by
article 152 of Law 4548/2018.
b) In our opinion the Board of Directors’ Report has been prepared in accordance with the legal requirements of articles
150 and 153 of Law 4548/2018, excluding the requirement of paragraph 5A of article 150 of the same law to submit a
sustainability statement, and the content of the Board of Directors’ report is consistent with the accompanying separate
and consolidated financial statements for the year ended December 31, 2024.
c) Based on the knowledge we obtained during our audit, concerning «THRACE PLASTICS Co S.A.» and its environment,
we have not identified information included in the Board of Directors’ Report that contains a material misstatement.
2. Additional Report to the Audit Committee
Our opinion on the accompanying separate and consolidated financial statements is consistent with our Additional Report to
the Audit Committee of the Company, in accordance with Article 11 of the EU Regulation 537/2014.
3. Provision of Non-audit Services
We have not provided in the Company and its subsidiaries any prohibited non-audit services per Article 5 of the EU Regulation
537/2014.
Permissible non-audit services provided by us to the Company and its subsidiaries during the year ended December 31, 2024,
are disclosed in Note 3.30 of the accompanying separate and consolidated financial statements.
4. Appointment of the Auditor
We were firstly appointed as auditors of the Company by the Shareholders’ General Assembly on 29/05/2024.
5. Rules of Procedure
The Company has in place Rules of Procedure, the context of which is in accordance with the provisions of article 14 of Law
4706/2020.
A member firm of Ernst & Young Global Limited
6. Reasonable Assurance report on the European Single Electronic Format
Subject Matter
We have been engaged to perform a reasonable assurance engagement in order to examine the digital files of «THRACE
PLASTICS Co S.A.», prepared in accordance with the European Single Electronic Format (“ESEF”), which includes the separate
and consolidated financial statements of the Company and the Group for the year ended December 31, 2024 in HXTML
format and the XBRL file «213800J1QD8BIB2ICW19-2024-12-31-el.zip» with appropriate tagging on the aforementioned
consolidated financial statements, including the explanatory notes, (the “Subject Matter”), and report about whether the
Subject Matter is prepared in accordance with the Applicable Criteria.
Applicable Criteria
The Applicable Criteria for the European Single Electronic Format (ESEF) are defined in the EU Delegated Regulation
2019/815, as amended by the EU Delegated Regulation 2020/1989 of the European Commission (the “ESEF Regulation”) and
the Interpretative Communication of the European Commission 2020/C 379/01 dated 10 November 2020, as required by Law
3556/2007 and the relevant communications of the Hellenic Capital Market Commission and the Athens Stock Exchange.
The Applicable Criteria provide, among others, the following requirements:
• all annual financial reports should be prepared in XHTML format.
• for the consolidated financial statements prepared in accordance with International Financial Reporting Standards, the
financial information included in the statement of comprehensive income, the statement of financial position, the
statement of changes in equity and the statement of cash flows, as well as the financial information included in the
explanatory notes, should be marked-up (XBRL tags and block tag), according to the Taxonomy of ESEF (ESEF Taxonomy)
as applicable. The technical specifications for ESEF, including the relevant taxonomy, are set out in the ESEF Regulatory
Technical Standards.
Responsibilities of Management and Those Charged With Governance
Management is responsible for the preparation and submission of the separate and consolidated financial statements of the
Company and the Group for the year ended December 31, 2024, in accordance with the Applicable Criteria, and for such
internal control as management determines is necessary to enable the preparation of the digital files that are free from
material misstatement, whether due to fraud or error.
Auditor’s Responsibilities
Our responsibility is to issue this report regarding the evaluation of the Subject Matter, based on the work performed, which
is described below in the section “Scope of work performed”.
We conducted our engagement in accordance with the International Standard on Assurance Engagements 3000 (Revised),
"Assurance Engagements Other Than Audits or Reviews of Historical Financial Information” (ISAE 3000).
ISAE 3000 requires that we plan and perform our engagement to obtain reasonable assurance for the evaluation of Subject
Matter in accordance with the Applicable Criteria. As part of the procedures performed, we assess the risk of material
misstatement of the information related to the Subject Matter.
We believe that the evidence we have obtained is sufficient and appropriate to provide a reasonable basis for our conclusion.
A member firm of Ernst & Young Global Limited
Legal Name: ERNST & YOUNG (HELLAS) Certified Auditors-Accountants S.A.
Distinctive title: ERNST & YOUNG
Legal form: Societe Anonyme
Registered seat: Chimarras 8Β, Maroussi, 15125
General Commercial Registry No: 000710901000
Professional ethics and quality management
We remained independent of the Company and the Group throughout the period of this assignment, and we have
complied with the requirements of International Ethics Standards Board for Accountants’ Code of Ethics for
Professional Accountants (IESBA Code), the ethical and independence requirements of Law 4449/2017 and the EU
Regulation 537/2014.
Our audit firm applies the International Standard on Quality Management (ISQM) 1, “Quality Management for Firms
that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services engagements”, which
requires that we design, implement and operate a system of quality management including policies or procedures
regarding compliance with ethical requirements, professional standards and applicable legal and regulatory
requirements.
Scope of work performed
The assurance engagement we performed is limited to the objectives included in the Decision 214/4/11-02-2022 of
the Board of Directors of the Hellenic Accounting and Auditing Standards Oversight Board and the guiding instructions
to auditors in connection with their assurance engagement on the European Single Electronic Format (ESEF) of public
issuers in regulated Greek markets, as issued by the Institute of Certified Public Accountants of Greece on 14 February
2022, in order to obtain reasonable assurance that the separate and consolidated financial statements of the Company
and the Group prepared by management comply, in all material respects, with the Applicable Criteria.
Inherent limitations
Our work is limited to the objectives mentioned in the section “Scope of work performed” for obtaining reasonable
assurance based on the procedures described. In this context, the work we performed could not guarantee that all
issues that might be considered material weaknesses would be disclosed.
Conclusion
Based on the procedures performed and the evidence obtained, we express the conclusion that the separate and
consolidated financial statements of the Company and the Group for the year ended December 31, 2024, in XHTML
file format, as well as the required XBRL file «213800J1QD8BIB2ICW19-2024-12-31-el.zip» with appropriate tagging on
the aforementioned consolidated financial statements, including the explanatory notes, have been prepared and
presented, in all material respects, in accordance with the Applicable Criteria.
Athens, 25 April 2025
The Certified Auditor Accountant
Maria Chatziantoniou
S.O.E.L. R.N.: 25301
ERNST & YOUNG (HELLAS)
CERTIFIED AUDITORS ACCOUNTANTS S.A.
CHIMARRAS 8B
151 25 MAROUSSI, GREECE
Company S.O.E.L. R.N. 107
www.thracegroup.gr
ANNUAL FINANCIAL
STATEMENTS
FOR THE PERIOD
01.01.2024 – 31.12.2024
24
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 276 of 370
IV. ANNUAL FINANCIAL STATEMENTS (SEPARATE AND CONSOLIDATED)
Contents
1. Information about the Group 283
2. Basis for the Preparation of the Financial Statements and Main Accounting Policies 285
2.1 Basis of Preparation 285
2.2 New standards, amendments to standards and interpretations 286
2.3 Significant Accounting Estimations and Judgments of the Group’s Management 290
2.4 Basis of Consolidation 292
2. 5 Tangible A ssets 294
2.6 Intangible Assets 295
2.7 Non-Current Assets Held for Sale 296
2.8 Impairments of Non-Financial Assets 296
2.9 Inventories 297
2.10 Foreign Exchange Translations 297
2.11 Acquisition of Treasury Shares 298
2.12 Income 298
2.13 Leases 299
2.14 Income Tax 300
2.15 Employee Benef its 301
2.16 Financial Assets 302
2.17 Financial Liabilities 304
2.18 Equity 304
STATEMENTS
STATEMENT OF INCOME AND OTHER COMPREHENSIVE INCOME 278
STATEMENT OF FINANCIAL POSITION 279
STATEMENT OF CHANGES IN EQUITY Group 280
STATEMENT OF CHANGES IN EQUITY Company 281
STATEMENT OF CASH FLOWS 282
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 277 of 370
3. Notes on the Financial Statements 305
3.1 Evolution and Performance of the Group 305
3.2 Segment Repor ting 306
3.3 O ther Income 309
3.4 Other Gains / (Losses) 310
3.5 Analysis of Expenses (Production-Administrative-Sales &
Distribution-Research & Development) 310
3.6 Payroll Expenses 311
3.7 Other Operating Expenses 312
3.8 Financial income/(ex penses) 313
3.9 Earnings per Share (Consolidated) 313
3.10 Income Tax 314
3.11 Property, Plant & Equipment (PP&E) 317
3.12 Right-of-Use Assets / Lease Liabilities 322
3.13 Intangible Assets 327
3.14 Other Long-Term Receivables 331
3.15 Inventories 331
3.16 Trade and other receivables 332
3.17 Cash & cash equivalents 337
3.18 Share Capital and Share Premium Reserve 338
3.19 Other Reserves 339
3.20 Bank Debt 340
3.21 Pension Liabilities 341
3.22 Deferred Taxes 346
3.23 Trade and Other Short-Term Liabilities 349
3.24 Financial Derivative Products 350
3.25 Dividend 350
3.26 Transactions with Related Parties 352
3.27 Remuneration of Board of Directors 354
3.28 Investments 354
3.29 Commitments and Contingent Liabilities 357
3.30 Fees of auditing firms 358
3.31 Financial risks 358
3.32 Significant Events 363
3.33 Significant Events after the reporting date of the Financial Statements 363
Annual Financial Report as of 31.12.2024
Contents
STATEMENT OF INCOME AND OTHER COMPREHENSIVE INCOME
Amounts in Euro thousand, unless stated otherwise
Annual Financial Report as of 31.12.2024 Page 15 from 180
STATEMENT OF INCOME AND OTHER COMPREHENSIVE INCOME
The accompanying notes that are presented in pages 152-237 form an integral part of the present Financial Statements
Note
1/1 - 31/12/2024 1/1 - 31/12/2023 1/1 - 31/12/2024 1/1 - 31/12/2023
Turnover
3.2
370,368 345,373 5,772 5,600
Cost of Sales
3.5
(293,228) (268,304) (5,314) (5,173)
Gross profit/(loss)
77,140 77,069 458 427
Other Income
3.3
Selling and Distribution Expenses
3.5
(42,977) (38,835) - -
Administrative Expenses
3.5
(17,657) (17,263) (1,045) (1,223)
Res earch and Development Expens es
3.5
(2,494) (2,506) - -
Other Expens es
3.7
(3,536) (1,860) (15) (19)
Other gain / (losses)
3.4
254 (7) (9) (39)
Financial Income
3.8
Financial Expenses
3.8
(4,770) (4,710) (17) (44)
Income from Dividends
3.8
- - 9,073 12,029
Profit / (loss) from companies consolidated with the Equity Method
3.28
1,341 2,331 - -
Profit/(loss) before Tax
13,735 21,336 8,563 12,364
Income Tax
3.10
(2,731) (3,010) (215) (1,294)
Profit/(loss) after tax (Α)
11,004 18,326 8,348 11,070
Other Comprehensive Income / (Loss)
Items that may be reclassified subsequently to profit or loss
FX differences from SOFP balances translation
3,986 1,027 - -
Items that will not be reclassified subsequently to profit or loss
Actuarial gain / (loss) aftet taxes
3.21, 3.22
(3,128) 1,345 1 (3)
Other comprehensive income after taxes (B)
858 2,372 1 (3)
Total comprehensive income / (loss) after taxes (A) + (B)
11,862 20,698 8,349 11,067
Profit / (loss) after tax
Attributed to:
Equity holders of the parent
Non-controlling interests
3.28
641 559 - -
Total comprehensive income after taxes
Attributed to:
Equity holders of the parent
11,221 20,147 - -
Non-controlling interests
3.28
641 551 - -
Profit/(loss) allocated to shareholders per share
Number of shares
42,916 42,974 - -
Earnings/(loss) per share
3.9
0.2415 0.4134 - -
10,363
17,767
-
3,052
-
1
894
Company
(494)
(515)
Operating Profit /(loss) before interest and tax
Group
1,506
339
4,928
4,065
117
15,658
20,663
Page 278 of 370
The accompanying notes that are presented in pages 283-369 form an integral part of the present Financial
Statements
Amounts in thousand Euro, unless stated otherwise
Annual Financial Report as of 31.12.2024
Contents
STATEMENT OF FINANCIAL POSITION
Amounts in Euro thousand, unless stated otherwise
Annual Financial Report as of 31.12.2024 Page 16 from 180
STATEMENT OF FINANCIAL POSITION
The accompanying notes that are presented in pages 152-237 form an integral part of the present Financial Statements
Note 31/12/2024 31/12/2023 31/12/2024 31/12/2023
ASSETS
Non-Current Assets
Property Plant and Equipment 3.11
193,529 177,670 204 230
Right-of-use assets
3.12
3,065 3,154 184 332
Investment property 113 113 -
Intangible Assets
3.13
10,226 10,316 148 87
Investments in subsidiaries
3.28
- - 73,858 73,858
Investments in joint ventures
3.28
20,430 20,475 3,819 3,819
Net benefit from defined benefit plan
3.21
5,980 9,533 - -
Other l ong term recei vabl es
3.14
158 138 35 42
Deferred tax assets
3.22
815 326 393 126
Total non-Current Assets 234,316 221,725 78,641 78,494
Current Assets
Inventories
3.15
85,105 72,003 - -
Income tax prepaid
3.10
954 956 633 866
Tra de recei vabl es
3.16
73,151 62,179 499 511
Other debtors
3.16
7,166 21,523 426 3,190
Financial derivative products
3.24
- 77 - -
Non current assets held for sale
3.11
1,698 - - -
Cash and Cash Equivalents
3.17
33,456 27,801 349 242
Total Current Assets 201,530 184,539 1,907 4,809
TOTAL ASSETS 435,846 406,264 80,548 83,303
EQUITY AND LIABILITIES
Equity
Share Capital
3.18
28,869 28,869 28,869 28,869
Sha re premi um
3.18
21,524 21,524 21,644 21,644
Other reserves
3.19
27,721 23,053 12,923 12,613
Retained earnings 192,245 199,204 11,778 17,232
Total Shareholders' equity
270,359 272,650 75,214 80,358
Non-controlling interests
3.28
4,810 4,404 - -
Total Equity 275,169 277,054 75,214 80,358
Long Term Liabilities
Long Term Borrowings
3.20
33,248 27,790 - -
Liabilities from leases
3.12
1,619 1,885 41 179
Provi s i ons for Empl oyee Benefi ts
3.21
1,907 1,658 121 99
Deferred Tax Liabilities
3.22
5,507 7,910 - -
Other Long Term Liabilities
3.20, 3.26
403 518 277 280
Total Long Term Liabilities 42,684 39,761 439 558
Short Term Liabilities
Short term borrowings
3.20
31,731 26,555 - -
Liabilities from leases
3.12
1,282 1,140 137 143
Income Tax
3.10
2,414 1,914 100 615
Trade payables
3.23
55,500 38,462 619 364
Other short-term liabilities
3.23
26,940 21,378 4,039 1,265
Financial Derivative Products
3.24
126 - - -
Total Short Term Liabilities 117,993 89,449 4,895 2,387
TOTAL LIABILITIES
TOTAL EQUITY & LIABILITIES
160,677
129,210
5,334
2,945
435,846
406,264
80,548
83,303
Company
Group
Page 279 of 370
The accompanying notes that are presented in pages 283-369 form an integral part of the present Financial
Statements
Amounts in thousand Euro, unless stated otherwise
-
Annual Financial Report as of 31.12.2024
Contents
STATEMENT OF CHANGES IN EQUITY
Group
Amounts in Euro thousand, unless stated otherwise
Annual Financial Report as of 31.12.2024 Page 17 from 180
STATEMENT OF CHANGES IN EQUITY
The accompanying notes that are presented in pages 152-237 form an integral part of the present Financial Statements
Group
Note
28,869 21,524 36,282 (3,311) (11,979) 192,355 263,740 4,121 267,861
- - - - - 17,767 17,767 559 18,326
- - - - 1,035 1,345 2,380 (8) 2,372
- - - - 1,035 19,112 20,147 551 20,698
3.19
- - 957 - - (957) - - -
3.25
- - - - - (11,300) (11,300) (268) (11,568)
Transfers
- - - - - - - - -
- - 306 - - (6) 300 - 300
3.18
- - - (237) - - (237) - (237)
- - 1,263 (237) 1,035 6,849 8,910 283 9,193
28,869 21,524 37,545 (3,548) (10,944) 199,204 272,650 4,404 277,054
28,869 21,524 37,545 (3,548) (10,944) 199,204 272,650 4,404 277,054
- - - - - 10,363 10,363 641 11,004
- - - - 3,986 (3,128) 858 - 858
- - - - 3,986 7,235 11,221 641 11,862
3.19
- - 926 -
- (926) - - -
3.25
- - - - - (13,250) (13,250) (235) (13,485)
Transfers
- - - - - - - - -
- - 15 - (16) (18) (19) - (19)
3.18
- - - (243) - - (243) - (243)
- - 941 (243) 3,970 (6,959) (2,291) 406 (1,885)
28,869 21,524 38,486 (3,791) (6,974) 192,245 270,359 4,810 275,169
Changes during the period
Balance as at 31/12/2024
Other comprehensive income
Formati on of statutory reserve
Dividends
Purchase of treasury shares
Total comprehensive
income after Tax
Other changes
Changes during the period
Balance as at 31/12/2023
Balance as at 01/01/2024
Profit / (l oss es ) for the peri od
Purchase of treasury shares
Non-controlling
interests
Total Equity
Profit / (l oss es ) for the peri od
Balance as at 01/01/2023
Total comprehensive
income after Tax
Other comprehensive income
Formati on of statutory reserve
Dividends
Other changes
Total
Attributed to the shareholders of the Parent Company
Share
Capital
Share
Premium
Other Reserves
Treasury
shares
reserves
FX translation
reserves
Retained earnings
Page 280 of 370
The accompanying notes that are presented in pages 283-369 form an integral part of the present Financial
Statements
Amounts in thousand Euro, unless stated otherwise
Annual Financial Report as of 31.12.2024
Contents
STATEMENT OF CHANGES IN EQUITY (continues from previous page)
Company
Amounts in Euro thousand, unless stated otherwise
Annual Financial Report as of 31.12.2024 Page 18 from 180
STATEMENT OF CHANGES IN EQUITY (continues from previous page)
The accompanying notes that are presented in pages 152-237 form an integral part of the present Financial Statements
Company
Note
28,869 21,644 15,586 (3,311) 16 18,024 80,828
- - - - - 11,070 11,070
- - - - - (3) (3)
- - - - - 11,067 11,067
3.19
- - 559 - - (559) -
3.25
- - - - - (11,300) (11,300)
- - - - - - -
3.18
- - - (237) - - (237)
- - 559 (237) - (792) (470)
28,869 21,644 16,145 (3,548) 16 17,232 80,358
28,869 21,644 16,145 (3,548) 16 17,232 80,358
- - - - - 8,348 8,348
- - - - - 1 1
- - - - - 8,349 8,349
3.19
- - 553 - - (553) -
3.25
- - - - - (13,250) (13,250)
- - 16 - (16) - -
3.18
- - - (243) - - (243)
- - 569 (243) (16) (5,454) (5,144)
28,869 21,644 16,714 (3,791) - 11,778
75,214
Share Capital
Share Premium
Other Reserves
Treasury shares
reserves
FX translation
reserves
Retained earnings
Purchase of treasury shares
Total comprehensive income after Tax
Total Equity
Profi t / (los s es ) for the peri od
Balance as at 01/01/2023
Other comprehensive income
Formation of s tatutory reserve
Dividends
Other changes
Purchase of treasury shares
Changes during the period
Balance as at 31/12/2023
Balance as at 01/01/2024
Total comprehensive income after Tax
Profi t / (los s es ) for the peri od
Other comprehensive income
Formation of s tatutory reserve
Dividends
Other changes
Changes during the period
Balance as at 31/12/2024
Page 281 of 370
The accompanying notes that are presented in pages 283-369 form an integral part of the present Financial
Statements
Amounts in thousand Euro, unless stated otherwise
Annual Financial Report as of 31.12.2024
Contents
Amounts in Euro thousand, unless stated otherwise
Annual Financial Report as of 31.12.2024 Page 19 from 180
STATEMENT OF CASH FLOWS
The accompanying notes that are presented in pages 152-237 form an integral part of the present Financial Statements
Note
1/1 - 31/12/2024 1/1 - 31/12/2023 1/1 - 31/12/2024 1/1 - 31/12/2023
Cash flows from Operating Activities
Profi t before Taxes
13,735 21,336 8,563 12,364
Plus / (minus) adjustments for:
Depreciati on
3.11, 3.12, 3.13
25,703 23,354 257 252
Provisions
3.15, 3.16, 3.21
731 (686) 31 48
Grants - (182) - -
FX di fferences 159 155 9 10
(Gain)/loss from sale of property, plant and equipment
3.4
44 (67) - -
Income from dividends
3.8
- - (9,073) (12,029)
Loss due to fixed asset impairment - 28 - -
Interes t & s i mi l ar (i ncome) / expenses
3.8
3,264 1,658 16 (850)
(Profit) / loss from companies consolidated with the Equity method
3.28
(1,341) (2,331) - -
Operating Profit before adjustments in working capital 42,295 43,265 (197) (205)
(Increase)/decreas e i n recei vabl es 516 7,132 (244) 1,320
(Increase)/decreas e i n i nventories (12,563) 4,161 - -
Increase/(decrease) in l iabi li ties (a pa rt from ba nks -ta xes) 17,550 (3,534) (1) (180)
Cash generated from Operating activities 47,798 51,024 (442) 935
Interes t Pa i d (2,521) (2,917) - (23)
Other financial income/(expenses) (797) 1,422 (13) 883
Taxes paid (3,515) (2,931) (465) (496)
Cash flows from operating activities (a) 40,965 46,598 (920) 1,299
Investing Activities
Proceeds from sales of property, plant and equipment and intangible
assets
168 170 - -
Interes t recei ved 983 463 1 1
Divi dends recei ved 1,899 1,171 8,800 13,057
Purchase of property, plant and equipment and intangible assets
3.11, 3.13
(40,218) (30,022) (144) (12)
Investment grants - 1,548 - -
Cash flow from investing activities (b) (37,168) (26,670) 8,657 13,046
Financing activities
Ti me deposi ts
3.16
- (13,269) - -
Proceeds from loans
3.20
25,737 9,175 - -
Purchase of treasury shares
3.8
(243) (237) (243) (237)
Repayment of loans (15,410) (12,275) - (1,000)
Payments of liabilities from leases (1,321) (1,177) (143) (153)
Dividends paid (7,479) (14,407) (7,244) (14,140)
Cash flow from financing activities (c) 1,284 (32,190) (7,630) (15,530)
Net increase /(decrease) in Cash and Cash Equivalents
5,081 (12,262) 107 (1,185)
Cash and Cash Equivalents at beginning of period
3.17
27,801 39,610 242 1,427
Effect from cha nges i n forei gn excha nge ra tes on ca s h res erves
574 453 - -
3.17
242
Cash and Cash Equivalents at end of period
Group
Company
33,456
27,801
349
STATEMENT OF CASH FLOWS
Page 282 of 370
The accompanying notes that are presented in pages 283-369 form an integral part of the present Financial
Statements
Amounts in thousand Euro, unless stated otherwise
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 283 of 370
Contents
The company THRACE PLASTICS CO S.A.
as it was renamed following the approval
and the amendment of its name on GEMI
(hereinafter the “Company”) was founded
in 1977. It is based in Magiko of municipality
of Avdira in Xanthi, Northern Greece, and
is registered in the Public Companies (S.A.)
Register under Reg. No. 11188/06/Β/86/31
and in the General Commercial Register
under GEMI Reg. No. 12512246000.
The purpose of the Company and its main
objective is to participate in the share cap-
ital of companies and to finance compa-
nies of any legal form, kind and objective,
either listed or non-listed on organized
market, as well as the provision of Ad-
ministrative - Financial - IT Services to its
Subsidiaries.
The Company is the parent of a Group
of companies (hereinafter the “Group”),
which operate mainly in two segments,
the technical fabrics segment and the
packaging segment.
The Company’s shares are listed on the
Athens Stock Exchange since June 26,
1995.
The company’s shareholders, with equity
stakes above 5%, as of 31.12.2024 and 2023
were the following:
1. Information about the Group
SHARES IN JOINT SHARES OUTSIDE TOTAL VOTING LAST NAME NAMEINVESTOR SHARES JOINT INVESTOR SHARESRIGHTS(K.E.M.)*SHARES (K.E.M.)Chalioris Konstantinos 41.15% 2.13% 43.29% 43.29%Chaliori Effimia - 20.85% 20.85% 20.85%Chalioris Alexandros 20.58% 0.48% 21.06% 0.48%Chalioris Stavros 20.58% 0.48% 21.06% 0.48%
*the relevant announcement was posted on the Company’s website on 10 March 2023 and is summarized
as follows:
Mr. Konstantinos Chalioris, shareholder and Chair-
man of the Board of Directors of the Company,
transferred from his individual Investment Account,
to two “Joint Investor Shares” (KEM), the first one
jointly created with his son Alexandros Chalioris and
the second one jointly created with his son Stavros
Chalioris (himself being the first beneficiary in both
“Joint Investor Shares”), a total of 18,000,983 com-
mon registered shares with voting rights, i.e. a per-
centage of 41.153% of a total of 43,741,452 common
registered shares with voting rights of the Company.
Following the above, there was absolutely no
change in the number and percentage of shares and
voting rights controlled by Mr. Konstantinos Chalio-
ris, who holds a total of 18,936,558 common regis-
tered shares with voting rights of the Company (and
the same number of voting rights) a percentage
of 43.292%. More specifically, he holds 18,000,983
common registered shares through the aforemen-
tioned “Joint Investor Share” and 935,575 common
registered shares with voting rights (percentage
2.139%) through his Personal Investment Account.
Mr. Stavros Chalioris, son of Konstantinos, due to his
participation in the aforementioned “Joint Inves-
tor Share” (which he holds jointly with Konstanti-
nos Chalioris) holds 9,000,491 common registered
shares of the Company (percentage 20.577%), while
he already holds 212,071 common registered shares
with voting rights (percentage 0.484%) in his Per-
sonal Investment Account and,
Mr. Alexandros Chalioris, son of Konstantinos, due
to his participation in the aforementioned “Joint In-
vestor Share” (which he holds jointly with Konstan-
tinos Chalioris) holds 9,000,492 common registered
shares of the Company (percentage 20.577%), while
he already holds 212,071 common registered shares
with voting rights (percentage of 0.484%) in his Per-
sonal Investment Account.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 284 of 370
Contents
Ownership Ownership Consolida-Company Registered OfficesPercentage of Percentage tion MethodParent Companyof GroupThrace Plastics CO S.A. GREECE-Xanthi Parent - Full Don & Low LTD SCOTLAND-Forfar 100.00% 100.00% Full Thrace Nonwovens & Geosynthetics Single Person GREECE-Xanthi 100.00% 100.00% FullS.A. Thrace Protect S.M.P.C. GREECE-Xanthi - 100.00% Full Thrace Plastics Pack S.A. GREECE-Ioannina 92.94% 92.94% Full Thrace Greiner Packaging SRLROMANIA - Sibiou - 46.47% Equity Thrace Plastics Packaging D.O.O.SERBIA-Nova Pazova - 92.94% Full Trierina Trading LTD CYPRUS-Nicosia - 92.94% Full Thrace Ipoma A.D. BULGARIA-Sofia - 92.83% Full Synthetic Holdings LTDN. IRELAND-Belfast100.00% 100.00% FullThrace Synthetic Packaging LTDIRELAND - Clara - 100.00% Full Arno LTD IRELAND -Dublin - 100.00% Full Synthetic Textiles LTD N. IRELAND-Belfast - 100.00% Full Thrace Polybulk A.B. SWEDEN -Köping - 100.00% Full Thrace Polybulk A.S. NORWAY-Brevik - 100.00% Full Lumite INC. U.S.A. - Georgia - 50.00% Equity Adfirmate LTD CYPRUS-Nicosia - 100.00% Full Pareen LTD CYPRUS-Nicosia - 100.00% Full Thrace Linq INC. U.S.A. - South Carolina - 100.00% Full Thrace Polyfilms Single Person S.A. GREECE - Xanthi 100.00% 100.00% Full Thrace Greenhouses S.A. GREECE - Xanthi 50.91% 50.91% Equity Thrace Eurobent S.A. GREECE - Xanthi 51.00% 51.00% Equity
The Group maintains production and
trade facilities in Greece, United Kingdom,
Ireland, Sweden, Norway, Serbia, Bulgaria,
U.S.A. and Romania.
The Group, including its joint ventures,
employed a total of 2,197 employees as of
December 31, 2024, of which 1,368 were
employed in Greece.
The structure of the Group as of 31st De-
cember 2024 was as follows:
* It is noted that the company SAEPE LTD, a subsidiary of Thrace Nonwovens & Geosynthetics Sin-
gle Person S.A., which had no substantial activity, was liquidated during the third quarter of the
fiscal year 2024 and has therefore is not included in the Group’s current structure. No material
changes resulted in the Group from the liquidation of the aforementioned subsidiary.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 285 of 370
Contents
2.1 Basis of Preparation
The present financial statements have
been prepared according to the Inter-
national Financial Reporting Standards
(I.F.R.S.), as such have been adopted by
the European Union and the interpreta-
tions that have been issued by the Interna-
tional Financial Reporting Interpretations
Committee (I.F.R.I.C.). The basic account-
ing principles that were applied for the
preparation of the financial statements for
the year ended on 31 December 2024 are
the same as those applied for the prepa-
ration of the financial statements for the
year ended on 31 December 2023 with
the exception of the adoption of new and
amended standards as listed below (note
2.2).
When deemed necessary, the comparative
data has been reclassified in order to con-
form to possible changes in the presenta-
tion of the data of the present year.
Differences that possibly appear between
accounts in the financial statements and
the respective accounts in the notes, are
due to rounding.
The financial statements have been pre-
pared according to the historic cost princi-
ple, as disclosed in the Company’s account-
ing principles presented below, except for
derivative financial products measured at
fair value through the results.
Moreover, the Group’s and Company’s fi-
nancial statements have been prepared
under the “going concern” principle taking
into account the significant profitability of
the Group and the Company and all mac-
roeconomic and microeconomic factors as
well as their impact on the smooth opera-
tion of the Group and the Company.
The financial statements were approved
by the Board of Directors of the Company
on April 24, 2025 and are subject to ap-
proval by the next Ordinary General Meet-
ing which will convene within the year
2025.
The financial statements of the Group
THRACE PLASTICS Co. S.A. as well as of the
parent company are posted on the inter-
net, on the website www.thracegroup.gr.
2. Basis for the Preparation of the Financial
Statements and Main Accounting Policies
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 286 of 370
Contents
Certain new standards, amendments to
standards and interpretations have been
issued that are mandatory for periods be-
ginning on or after 1 January 2024.
STANDARDS / AMENDMENTS THAT ARE
EFFECTIVE AND HAVE BEEN ENDORSED BY
THE EUROPEAN UNION
IAS 1 Presentation of Financial State-
ments: Classification of Liabilities as
Current or Non-current (Amendments)
The amendments are effective for annual
reporting periods beginning on or after
January 1, 2024, and are applied retrospec-
tively. The objective of the amendments
is to clarify the principles in IAS 1 for the
classification of liabilities as either current
or non-current. The amendments clarify
the meaning of a right to defer settlement,
the requirement for this right to exist at
the end of the reporting period, that man-
agement intent does not affect current
or non-current classification, that options
by the counterparty that could result in
settlement by the transfer of the entity’s
own equity instruments do not affect cur-
rent or non-current classification. Also, the
amendments specify that only covenants
with which an entity must comply on or
before the reporting date will affect a lia-
bility’s classification. Additional disclosures
are also required for non-current liabilities
arising from loan arrangements that are
subject to covenants to be complied within
twelve months after the reporting period.
IFRS 16 Leases: Lease Liability in a Sale
and Leaseback (Amendments)
The amendments are effective for annual
reporting periods beginning on or after
January 1, 2024. The amendments are in-
tended to improve the requirements that a
seller-lessee uses in measuring the lease li-
ability arising in a sale and leaseback trans-
action in IFRS 16, while it does not change
the accounting for leases unrelated to sale
and leaseback transactions. Under the
amendments, the seller-lessee determines
‘lease payments’ or ‘revised lease pay-
ments’ in such a way that the seller-lessee
would not recognize any amount of the
gain or loss that relates to the right of use it
retains. Applying these requirements does
not prevent the seller-lessee from recog-
nizing, in profit or loss, any gain or loss
relating to the partial or full termination of
a lease. The amendments apply retrospec-
tively to sale and leaseback transactions
entered into after the date of initial appli-
cation, being the beginning of the annual
reporting period in which an entity first
applied IFRS 16.
IAS 7 Statement of Cash Flows and
IFRS 7 Financial Instruments Disclo-
sures - Supplier Finance Arrangements
(Amendments)
The amendments are effective for annual
reporting periods beginning on or after
January 1, 2024. The amendments sup-
plement requirements already in IFRS and
require an entity to disclose the terms and
conditions of supplier finance arrange-
ments. Additionally, entities are required
to disclose at the beginning and end of
reporting period the carrying amounts of
supplier finance arrangement financial li-
abilities and the line items in which those
liabilities are presented as well as the carry-
ing amounts of financial liabilities and line
items, for which the finance providers have
already settled the corresponding trade
payables. Entities should also disclose the
type and effect of non-cash changes in the
2.2 New standards, amendments to standards and interpretations
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 287 of 370
Contents
carrying amounts of supplier finance ar-
rangement financial liabilities, which pre-
vent the carrying amounts of the financial
liabilities from being comparable. Further-
more, the amendments require an entity
to disclose at the beginning and end of the
reporting period the range of payment
due dates for financial liabilities owed to
the finance providers and for comparable
trade payables that are not part of those
arrangements.
The above mentioned amended standards
did not have significant impact on the fi-
nancial statements of the Group and the
Company.
STANDARDS ISSUED NOT EFFECTIVE
DURING THE PRESENT PERIOD BUT HAVE
BEEN ENDORSED BY THE EUROPEAN
UNION.
IAS 21 The Effects of Changes in Foreign
Exchange Rates: Lack of Exchangeabil-
ity (Amendments)
The amendments are effective for annual
reporting periods beginning on or after
January 1, 2025, with earlier application
permitted. The amendments specify how
an entity should assess whether a cur-
rency is exchangeable and how it should
determine a spot exchange rate when ex-
changeability is lacking. A currency is con-
sidered to be exchangeable into another
currency when an entity is able to obtain
the other currency within a time frame
that allows for a normal administrative
delay and through a market or exchange
mechanism in which an exchange transac-
tion would create enforceable rights and
obligations. If a currency is not exchange-
able into another currency, an entity is
required to estimate the spot exchange
rate at the measurement date. An entity’s
objective in estimating the spot exchange
rate is to reflect the rate at which an order-
ly exchange transaction would take place
at the measurement date between market
participants under prevailing economic
conditions. The amendments note that
an entity can use an observable exchange
rate without adjustment or another esti-
mation technique. The Management of
the Group and the Company estimates
that these amendments will not have a sig-
nificant impact on the financial statements
of the Group and the Company.
The amendments are effective for annual
reporting periods beginning on or after
1st January 2025, with earlier application
permitted. The amendments have not yet
been adopted by the European Union.
The Group and the Company’s Manage-
ment estimates that these amendments
will not have a material impact on the fi-
nancial statements of the Group and the
Company.
STANDARDS / AMENDMENTS THAT ARE
NOT EFFECTIVE AND HAVE NOT BEEN
ENDORSED BY THE EUROPEAN UNION
IFRS 9 Financial Instruments and IFRS
7 Financial Instruments: Disclosures -
Classification and Measurement of Fi-
nancial Instruments (Amendments)
The amendments are effective for an-
nual reporting periods beginning on or
after January 1, 2026. Early adoption of
amendments related to the classification
of financial assets and the related disclo-
sures is permitted, with the option to ap-
ply the other amendments at a later date.
The amendments clarify that a financial li-
ability is derecognized on the ‘settlement
date’, when the obligation is discharged,
cancelled, expired, or otherwise qualifies
for derecognition. They introduce an ac-
counting policy option to derecognize
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 288 of 370
Contents
liabilities settled via electronic payment
systems before the settlement date, sub-
ject to specific conditions. They also pro-
vide guidance on assessing the contractual
cash flow characteristics of financial assets
with environmental, social, and govern-
ance (ESG)-linked features or other similar
contingent features. Additionally, they clar-
ify the treatment of non-recourse assets
and contractually linked instruments and
require additional disclosures under IFRS 7
for financial assets and liabilities with con-
tingent event references (including ESG-
linked) and equity instruments classified
at fair value through other comprehensive
income. The amendments have not yet
been adopted by the European Union. The
Management of the Group and the Com-
pany estimates that these amendments
will not have a significant impact on the
financial statements of the Group and the
Company.
IFRS 9 Financial Instruments and IFRS
7 Financial Instruments: Disclosures -
Contracts Referencing Nature-depend-
ent Electricity (Amendments)
The amendments are effective for annual
reporting periods beginning on or after
January 1, 2026, with earlier application
permitted. The amendments: include (a)
clarifying the application of requirements,
regarding contracts to buy or sell non-
financial items that have been concluded
and continue to be held for the receipt or
delivery of a non-financial item in accord-
ance with the entity’s expected needs for
purchase, sale, or own use, (b) permit the
hedge accounting if the contracts within
the scope of the amendments are being
used as hedging instruments, and (c) in-
troduce new disclosure requirements to
enable investors to understand the impact
of these contracts on a company’s financial
performance and cash flows. The clarifi-
cations regarding the ‘own-use’ require-
ments must be applied retrospectively,
but the guidance permitting hedge ac-
counting have to be applied prospectively
to new hedging relationships designated
on or after the date of initial application.
The amendments have not yet been en-
dorsed by the EU. The Management of the
Group and the Company estimates that
these amendments will not have a signifi-
cant impact on the financial statements of
the Group and the Company.
IFRS 18 Presentation and Disclosure in
Financial Statements
IFRS 18 introduces new requirements
on presentation within the statement of
profit or loss. It requires an entity to clas-
sify all income and expenses within its
statement of profit or loss into one of the
five categories: operating; investing; fi-
nancing; income taxes; and discontinued
operations. These categories are comple-
mented by the requirements to present
subtotals and totals for ‘operating profit
or loss’, ‘profit or loss before financing and
income taxes’ and ‘profit or loss’. It also re-
quires disclosure of management-defined
performance measures and includes new
requirements for aggregation and disag-
gregation of financial information based
on the identified ‘roles’ of the primary fi-
nancial statements and the notes. In addi-
tion, there are consequential amendments
to other accounting standards. IFRS 18 is
effective for reporting periods beginning
on or after January 1, 2027, with earlier
application permitted. Retrospective ap-
plication is required in both annual and
interim financial statements. The standard
has not yet been endorsed by the EU. The
Management of the Group and the Com-
pany estimates that these amendments
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 289 of 370
Contents
will not have a significant impact on the
financial statements of the Group and the
Company.
IFRS 19 Subsidiaries without Public Ac-
countability: Disclosures
IFRS 19 permits subsidiaries without public
accountability to use reduced disclosure
requirements if their parent company (ei-
ther ultimate or intermediate) prepares
publicly available consolidated financial
statements in compliance with IFRS ac-
counting standards. These subsidiaries
must still apply the recognition, measure-
ment and presentation requirements in
other IFRS accounting standards. Unless
otherwise specified, eligible entities that
elect to apply IFRS 19 will not need to ap-
ply the disclosure requirements in other
IFRS accounting standards. IFRS 19 is effec-
tive for reporting periods beginning on or
after January 1, 2027, with early application
permitted. The standard has not yet been
endorsed by the EU. The Management of
the Group and the Company estimates
that these amendments will not have a sig-
nificant impact on the financial statements
of the Group and the Company.
Annual Improvements to International
Financial Reporting Standards (IFRS) –
Volume 11
The IASB’s annual improvements process
addresses non-urgent, but necessary,
clarifications and amendments to IFRS. In
July 2024, the IASB issued Annual Improve-
ments to International Financial Report-
ing Standards (IFRS) - Volume 11. An entity
must apply these amendments for annual
reporting periods beginning on or after
1 January 2026. Annual Improvements to
International Financial Reporting Stand-
ards (IFRS) - Volume 11 include amend-
ments to IFRS 1, IFRS 7, IFRS 9, IFRS 10 and
IAS 7. These amendments are intended
to clarify the context, correct minor un-
intended consequences, omissions or in-
consistencies among requirements in the
standards. . These amendments have not
been adopted by the European Union. The
Management of the Group and the Com-
pany estimates that these amendments
will not have a significant impact on the
financial statements of the Group and the
Company.
Amendment in IFRS 10 Consolidated
Financial Statements and IAS 28 Invest-
ments in Associates and Joint Ventures:
Sale or Contribution of Assets between
an Investor and its Associate or Joint
Venture
The amendments address an acknowl-
edged inconsistency between the require-
ments in IFRS 10 and those in IAS 28, in
dealing with the sale or contribution of as-
sets between an investor and its associate
or joint venture. The main consequence of
the amendments is that a full gain or loss is
recognized when a transaction involves a
business (whether it is housed in a subsidi-
ary or not). A partial gain or loss is recog-
nized when a transaction involves assets
that do not constitute a business, even if
these assets are housed in a subsidiary. In
December 2015 the IASB postponed the
effective date of this amendment indefi-
nitely pending the outcome of its research
project on the equity method of account-
ing. The amendments have not yet been
endorsed by the EU. The Management of
the Group and the Company estimates
that these amendments will not have a sig-
nificant impact on the financial statements
of the Group and the Company.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 290 of 370
Contents
2.3 Significant Accounting Estimations and Judgments of the Group’s
Management
The estimations and judgments of the
Management of the Group are constantly
assessed. They are based on historical
data and expectations for future events,
which are deemed as fair according to the
relevant provisions in effect.
2.3.1 Significant Accounting
Estimates and Assumptions
The preparation of the Financial State-
ments in accordance with IFRS requires the
management to make judgments and esti-
mates that may affect the accounting bal-
ances of assets and liabilities, the required
disclosure of contingent assets and liabili-
ties at the date of preparation of the Finan-
cial Statements, as well as the amounts of
income and expenses recognized during
the reporting financial year. The use of the
available information, which is based on
historical data and assumptions and the
implementation of an evaluation are nec-
essary items in order to conduct estimates
and apply the respective accounting poli-
cies. The actual future results may differ
from the above estimates and these differ-
ences may affect the Financial Statements.
Estimates and relative assumptions are re-
vised constantly. The revisions in account-
ing estimations are recognized in the pe-
riod they occur if the revision affects only
the specific period or in the revised period
and the future periods if the revisions af-
fect the current and the future periods.
The key estimates and assumptions that
refer to elements and data whose devel-
opment could affect the items of the Fi-
nancial Statements are as follows:
2.3.1.1 Provisions for expected credit
losses from trade and other
receivables
The Group and the Company recognize
impairment losses for expected credit
losses for all financial assets. Expected
credit losses are based on the difference
between the contractual cash flows and
all cash flows that the Group (or the Com-
pany) expects to receive. The difference is
discounted using an estimate of the initial
effective interest rate of the financial as-
set. For customer receivables, the Group
and the Company applied the simplified
approach to the standard and calculated
the expected credit losses on the basis of
the expected credit losses over the lifetime
of those items. For other financial assets,
the expected credit losses are calculated
on the basis of the losses for the next 12
months. Expected credit losses over the
next 12 months are part of the expected
credit losses over the life of the financial
assets resulting from the probability of
default of an item within 12 months of the
reporting date. If there is a significant in-
crease in credit risk from the initial recogni-
tion, the provision for impairment will be
based on the expected credit losses over
the life of the asset (see note 3.16.3).
2.3.1.2 Impairment of Investment in
Subsidiaries
Management examines on an annual ba-
sis whether there are indicators of impair-
ment of investment in subsidiaries. If such
indications exist, the Company estimates
the recoverable amount of the invest-
ment. If an investment has to be impaired,
the Company calculates the amount of the
impairment as the difference between the
recoverable amount of the investment and
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 291 of 370
Contents
its book value. Management determines
recoverable value as the greater of the
value in use and the fair value less costs
to sell in accordance with the provisions
of IAS 36. Value in use is determined by an
independent specialist based on manage-
ment’s estimates and assumptions such as
future cash flows, returns of each subsidi-
ary company, and discounted rates applied
to the projected cash flows. Moreover,
these assumptions vary due to the differ-
ent conditions prevailing in the markets of
the countries in which the Group operates
(see note 3.28).
2.3.1.3 Estimate on Impairment of
Goodwill
Goodwill is allocated to cash-generat-
ing units (CGUs) for impairment testing,
which primarily concern the subsidiaries
for which goodwill was recognized upon
acquisition. The Group assesses whether
there is impairment of goodwill at least on
an annual basis. Management identifies
the recoverable amount as the greater of
its value in use and its fair value less costs
to sell. The calculation of the value in use
of each cash-generating unit requires an
estimate by management of the assump-
tions about the future results of the cash-
generating units, such as growth rate in
perpetuity, forecasts for projected quan-
tities and sales prices, gross profit margin
and discount rates. These assumptions
vary due to different market conditions in
the countries in which the Group operates
(see note 3.13).
2.3.1.4 Provision for income tax
The provision for income tax according
to IAS 12 is calculated by estimating taxes
that will be paid to the tax authorities and
includes the current income tax for each fi-
nancial year and a provision for additional
taxes that may arise in future tax audits.
Group companies are subject to different
income tax laws and therefore significant
management assessment is required to
determine the Group’s income tax. Actual
Income tax may differ from these esti-
mates as a result of future changes in tax
legislation both in the countries in which
the Group operates and in Greece or un-
foreseen consequences from the final de-
termination of the tax liability of each use
by the tax authorities. These changes may
have a significant impact on the Group’s
and Company’s financial position in the
event that the final settlement of income
taxes deviates from the initial amounts
that have been recorded in the Group
and Company Financial Statements. These
differences will affect income tax and de-
ferred tax provisions for the year in which
the final determination is made. For more
information, see note 3.10.
2.3.1.5 Provisions for employee benefits
The present value of the liabilities for post-
employment benefits depends on a num-
ber of factors defined on actuarial basis via
the use of a significant number of assump-
tions. The assumptions used for the deter-
mination of the net cost (income) for post-
employment benefits include discount
rates, rates of wage increases, mortality
and disability rates, retirement ages and
other factors. Any changes to these under-
lying assumptions may have a significant
effect on the liability and the relative costs
of each period.
The Group defines the appropriate dis-
count rate for each reporting period. It is
the interest rate applicable for the calcula-
tion of the present value of the estimated
future payments required for the settle-
ment of the benefit liabilities. For the es-
timation of the appropriate discount rate
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Page 292 of 370
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the Group takes into consideration the
interest rates prevailing in high credit rat-
ing corporate bonds denominated in the
currency of the benefit payments and
with maturity dates similar to the ones of
the respective liabilities. Due to the long-
term nature of these defined benefit plans,
these cases are subject to a significant de-
gree of uncertainty. Further information is
provided in note 3.21.
2.3.1.6 Depreciation/amortization of
tangible and intangible assets
The Group and the Company calculate
depreciation/amortization on tangible
and intangible assets based on estimation
of the useful life of such. The residual value
and useful life of such assets are reviewed
and defined at the end of each report-
ing period of the financial statements, if
deemed necessary.
2.3.2 Significant Accounting Judg-
ments in the Application of
Accounting Principles
There are no significant estimates to be
applied in accounting policies.
2.4 Basis of Consolidation
2.4.1 Subsidiaries
Subsidiaries are all companies (includ-
ing those companies of special purpose)
which are controlled by the Group. The
Group controls a company when the
Group is exposed to or has rights in vari-
able returns from its participation in the
company and has the ability to affect
these returns through the power it pos-
sesses in the company. The subsidiaries are
consolidated with the full consolidation
method from the date at which the control
is acquired by the Group and are excluded
from consolidation from the date at which
such control does not exist.
The mergers of companies are accounted
for, from the Group based on the purchase
method. The price of the acquisition is cal-
culated as the fair value of the transferred
assets, the liabilities undertaken against
the former shareholders and the shares
issued by the Group. The price of the ac-
quisition includes the fair value of any as-
set or liability which may derive from any
potential agreement about the price. The
assets acquired and the liabilities along
with the contingent liabilities assumed
during a corporate merger are measured
initially at fair value on the date of the ac-
quisition. Depending on the acquisition
case, the Group recognizes any non-con-
trolled interest in the subsidiary either at
fair value or at the value of the stake of the
non-controlled interest in the equity of the
subsidiary. The acquisition cost less the fair
value of the individual items acquired is re-
corded as goodwill. If the total cost of the
acquisition is less than the fair value of the
individual items acquired, the difference is
immediately recognized in the results.
The expenses related to the acquisition are
recorded in the financial results.
If the corporate merger is gradually
achieved then the fair value of the partici-
pation held by the Group in the acquired
company is revalued at fair value at the
acquisition date. The profit or loss which
emerges from the revaluation is recog-
nized in the financial results.
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Any potential price that is transferred from
the Group is recognized at fair value at the
acquisition date. Any subsequent chang-
es in the fair value of the potential price,
which is considered as an asset or a liabil-
ity, are recognized according to IAS 39 in
the financial results. If the potential price
is recorded as item of the equity, then it
is not revalued until its final settlement
through the equity.
Intra-company transactions, balances and
non-realized earnings from transactions
among the companies of the Group are
excluded. The non-realized losses are also
excluded. The accounting principles that
are applied by the subsidiaries have been
adjusted wherever it was deemed neces-
sary so that they are aligned with the ones
adopted by the Group.
The Company records the investments in
subsidiaries in the separate financial state-
ments at acquisition cost minus any im-
pairment losses. Furthermore, the acquisi-
tion cost is adjusted so that it reflects the
changes in the payable price deriving from
any amendments in the potential price.
2.4.2 Transactions with owners of
non-controlled interests
The Group treats the transactions with the
owners of non-controlled interests, which
do not result into loss of control, in the
same manner with the transactions with
the major shareholders of the Group. The
difference between the price paid and the
book value of the acquired interest of the
subsidiary’s equity is recorded in the share-
holders’ funds. Earnings of losses deriving
from the sale to owners of non-controlled
interests are also recorded in shareholders’
funds.
2.4.3 Sale of Subsidiary
When the Group ceases to possess control,
the remaining percentage is measured at
fair value, whereas any potential differ-
ences that derive in comparison with the
current value are recorded in the financial
results. Following, this asset is recognized
as associate company, joint venture or fi-
nancial asset at the above fair value. Addi-
tionally, any relevant amounts which were
previously recorded in the other compre-
hensive income are accounted for, with
the same manner that would be followed
in the case of sale of these assets and liabil-
ities, meaning that they can be transferred
in the financial results.
2.4.4 Joint Arrangements
Based on IFRS 11, investments in joint ar-
rangements are classified, either as joint
activities or as joint ventures and the clas-
sification depends on the contractual
rights and the liabilities of each investor.
The Group evaluated the nature of its in-
vestments in joint arrangements and de-
cided that these constitute joint ventures.
Joint ventures are consolidated according
to the equity method.
According to the equity method, invest-
ments in joint ventures are initially recog-
nized at the acquisition cost, which in a
later stage increases or decreases via the
recognition of the Group’s share in the
earnings or losses of the joint ventures
and the changes in the other compre-
hensive income after the acquisition. In
case the share of the Group in the losses
of the joint ventures exceeds the amount
of the investment (which also includes any
long-term investment that essentially con-
stitutes part of the net investment of the
Group in the joint ventures), no additional
losses should be recognized, unless there
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Contents
have been payments or there are commit-
ments undertaken for the account of the
joint ventures.
Non-realized profit from transactions be-
tween the Group and the joint ventures
is excluded according to the percentage
of the Group’s participation in the joint
ventures. The non-realized losses are
also excluded, unless the transaction of-
fers indications of a potential impairment
of the transferred asset. The accounting
principles of the joint ventures have been
amended wherever it was deemed appro-
priate, so that they are aligned with the
ones adopted by the Group.
2.5 Tangible Assets
Tangible assets are recorded at book value,
net of any grants received, less accumu-
lated depreciation and any impairment in
value. Expenses for replacement of part of
tangible assets are included in the value of
the asset if it can be estimated accurately
that these increase the future benefits
of the Group from such. The repairs and
maintenance of tangible assets charge the
financial results, in the period when such
are realized. The acquisition cost and the
related accumulated depreciation of as-
sets retired or sold, are removed from the
accounts at the time of sale or retirement,
and any gain or loss is included in the fi-
nancial results.
Depreciation is charged in the financial
results based on the straight-line method
over the estimated useful life of tangible
assets, however, in extraordinary cases of
investments in machinery where the fi-
nancial benefits are not estimated to be
evenly distributed throughout the useful
life of the asset, the diminishing balance
method is used.
The estimated useful life of each category
of asset is presented below:
Depreciation CategoryUseful LiferateBuildings and 20 - 40 2.5% - 5%technical worksyearsMachinery 10 - 14 and technical 7% - 10%yearsinstallationsSpecialized mechanical 12% - 15% 7 - 8 yearsequipmentVehicles 10% - 20% 5 - 10 yearsFurniture and 10% - 30% 3 - 10 yearsfixture
Land and plots are not depreciated, how-
ever they are reviewed for impairment.
Residual values and useful life of tangi-
ble assets might be adjusted if necessary
at the time the Financial Statements are
prepared. Tangible assets, that have been
impaired, are adjusted to reflect their re-
coverable value (Note 3.11). The remaining
value, if not negligible, is re-estimated on
an annual basis.
Tangible assets are derecognized when
sold, or when no future economic benefits
are expected from their use. The gains and
losses arising from the sale of property,
plant and equipment are determined by
the difference between the sale proceeds
and the net book value as shown in the
books and included in the operating result.
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2.6.1 Goodwill
Goodwill is measured at cost less any ac-
cumulated impairment losses. For the pur-
poses of the impairment test, the goodwill
recognized has been allocated, from the
date of acquisition, to the Group’s cash-
generating units, which are expected to
benefit from the combination. Each unit in
which goodwill has been allocated repre-
sents the lowest level within the company
in which goodwill is monitored for internal
management purposes.
Goodwill is allocated on cash-generating
units and an impairment test is carried out
at least annually or more frequently if there
is evidence of a possible impairment in the
book value of the goodwill in relation to its
recoverable value in accordance with IAS
36. Impairment is recognized directly as an
expense in the consolidated profit or loss
and other comprehensive income and is
not subsequently reversed.
The Management determines recoverable
value as the largest amount between the
value in use and its fair value, minus any
related costs of disposal. The calculation of
the value in use of each cash-generating
unit is performed by an independent valu-
er and requires management’s estimation
of the assumptions about the future finan-
cial results of the above cash-generating
units, such as the growth rate in perpetu-
ity, forecasts of expected sales quantities
and prices, gross margin and discount
rates. These assumptions vary due to the
different market conditions in the coun-
tries in which the Group operates.
2.6.2 Other Intangible Assets
Other intangible assets mainly concern
software and industrial ownership rights
which refer to the utilization right of the
trademark TERRAHOME that has been
purchased from a third party. Their values
are stated at acquisition cost, less the accu-
mulated depreciation and any impairment
losses. Amortization of intangible assets
is recorded in the financial results, based
on the straight-line method over the esti-
mated useful life of assets. The following
table depicts the estimated useful life of
intangible assets:
Amortization CategoryUseful LifeRateIndustrial ownership 20% 5 years rights5 - 10 Software 10 - 20%years
Subsequent expenses on the capitalized
intangible assets are capitalized only when
they increase the future benefits that are
attributed to the specific asset. In a differ-
ent case, all other expenses are recorded
when they incur.
Research costs are expensed as incurred.
Development costs that do not meet the
recognition criteria as an asset are ex-
pensed as incurred.
2.6 Intangible Assets
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2.7 Non-Current Assets Held for Sale
The Group classifies a non-current asset
(or a group of assets and liabilities) as held
for sale, if its value is expected to be recov-
ered primarily through the sale of the item
at its current condition and not through its
continued use and the sale is considered
very likely. The actions required to com-
plete the sale should indicate that it is un-
likely that significant changes will be made
to the sale or that the decision to sell will
be reversed. Management must be com-
mitted to the plan to sell the asset and the
sale is expected to be completed within
one year from the date of classification.
Immediately before the initial classifica-
tion of the non-current asset (or group of
assets and liabilities) as held for sale, the
asset (or all assets and liabilities included
in the group) shall be assessed on the basis
of the applicable IFRS. Non-current assets
(or asset and liability groups) classified as
held for sale are valued at the lowest value
between their book value and their fair
value reduced by direct sales costs, and
any resulting impairment losses and then
they are recorded in the statement of com-
prehensive income. Any possible increase
in the fair value in a later valuation is re-
corded in the statement of comprehensive
income, but not for an amount greater
than the previously recorded impairment
loss. From the day on which a non-current
asset (or non-current asset included in a
group of assets and liabilities) is classified
as held for sale, no depreciation or impair-
ment is recorded.
2.8 Impairments of Non-Financial Assets
With the exception of the goodwill which
is reviewed for impairment at least on an
annual basis, the book values of other non-
financial assets are reviewed for impair-
ment when events or changes in condi-
tions indicate that the book value may not
be recoverable. When the book value of an
asset exceeds its recoverable amount, the
respective impairment loss is registered in
the statement of comprehensive income.
The recoverable amount is defined as the
largest value between the fair value less
the sale expenses and the value in use.
Net sale price is the amount that can be
received from the sale of an asset, in the
context of an arm’s length transaction in
which the parties have full knowledge and
voluntarily proceed, after the deduction of
any additional direct cost for sale of the as-
set, whereas the value in use is the present
value of estimated future cash flows ex-
pected to be realized from the continuous
use of an asset and from the revenue ex-
pected to result from its sale and the end
of its estimated useful life. For purposes
of defining impairment, the non-financial
assets are grouped at the lowest level
for which cash flows can be recognized
separately.
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2.9 Inventories
The inventories are valued at the lower of
cost (acquisition or production) and net re-
alizable value. Cost of final and semi-final
products includes all cost of purchase, cost
of materials, direct labor cost, other direct
expenses and proportionate general pro-
duction expenses. The cost of inventories
is calculated using the weighted average
method.
Net realizable value represents the esti-
mated selling price in the ordinary course
of business, less the estimated expenses
relevant to the inventory and the estimat-
ed costs required to complete the sale, if
such costs are required or applicable.
The Group’s inventories under collection,
i.e. inventories that have not been received
up until the reporting date of the financial
statements, are recognized as inventories
during the period when the risks and re-
wards have been transferred from the sup-
plier to the Group, based on the respective
contractual agreements.
2.10 Foreign Exchange Translations
2.10.1 Operating currency and
presentation currency
The data in the Financial Statements of the
Group’s companies are registered in the
currency of the primary economic environ-
ment, in which each Company operates
(“operating currency”).
The consolidated Financial Statements are
presented in Euro, which is the operating
valuation currency and presentation cur-
rency of the parent Company.
2.10.2 Transactions and balances in
foreign currencie
s
Transactions in foreign currencies are con-
verted into the operating currency based
on exchange rates effective at the date of
transaction or at the date of revaluation
if such case is required. Profits and losses
from foreign exchange differences, aris-
ing during the settlement of such transac-
tions and from the conversion of foreign
currency denominated assets and liabili-
ties based on the current exchange rates
at the reporting date, are recorded in the
financial results. Profits and losses from
foreign exchange differences related to
cash reserves and bank liabilities are re-
corded in the statement of comprehen-
sive income, under the account “Financial
income / (expenses) - Net”. All other prof-
its or losses from foreign exchange dif-
ferences are recorded in the statement of
comprehensive income, under the account
“Other profits / (losses) - Net”.
2.10.3 Group’s Companies in foreign
currency
The conversion of the Financial State-
ments of the Group’s companies (none of
which operates with a currency belong-
ing to a hyperinflation economy), which
are recorded in a currency that is different
from the one of the Group, is conducted as
follows:
• The assets and liabilities for each state-
ment of financial position are convert-
ed based on the effective exchange
rates at the reporting date of each
statement of financial position,
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2.11 Acquisition of Treasury Shares
The paid price to acquire Treasury Shares,
including the relevant expenses for their
purchase, is presented as a deduction of
Equity. Any profit or loss from the sale of
Treasury Shares, net of direct transaction
costs and taxes, is recognized directly in
Equity, in the account “Treasury Share
Reserve”.
2.12 Income
2.12.1 Income from contracts with customers
The Parent Company provides Administra-
tive, Financial, Accounting, IT Services to
the Subsidiaries of the Group. Income from
the provision of services is recognized
over time in the accounting period during
which the services were provided.
The Group recognizes income from the sale
of goods when the control of the goods is
transferred to the customer, usually upon
delivery, and there is no unfulfilled liabil-
ity that could affect the acceptance of the
goods by the customer. The main product
categories are technical fabrics (geosyn-
thetics and textiles for construction, gar-
den projects, hospital and sanitary prod-
ucts, filter industry, automotive industry,
industrial use, sports and leisure, carpet
weaving, yarn and straps) and packaging
products (Big bags, packaging film, pack-
aging fabrics, containers, cups, containers
and trays, plastic boxes, bottles, bags, gar-
bage bags, ropes and strings). The Group
accepts returns only in case of defective
products or products which do not gener-
ally meet the required specifications.
The asset (receivable) is recognized when
there is an unconditional right for the en-
tity to receive the price for the performed
liabilities of the contract to the customer.
The contractual asset is recognized when
the Group has fulfilled its liabilities to the
customer, before the customer pays or be-
fore payment becomes due. Payment be-
comes due after 30 to 90 days. The liability
from contracts with customers is recog-
nized when the Group receives a payment
from the customer (advance payment) or
when it acquires an unconditional right to
a cash amount (deferred income) before
the performance of the liabilities of the
contract and the transfer of the goods or
services. The contractual liability is recog-
nized when the liabilities of the contract
are fulfilled and the income is recorded in
the statement of comprehensive income.
2.12.2 Income from Dividends – In-
terim Dividends
Income from dividends is recognized in
the Statement of Comprehensive Income
• Revenues and expenses are converted
based on the average exchange rates
of each period (unless the average
exchange rate does not logically ap-
proach the cumulative effect of the
exchange rates that were effective at
the time of the transactions. In such
case, revenues and expenses are con-
verted based on the exchange rates
effective at the time of the relevant
transactions), and
• The extracted foreign exchange dif-
ferences are recorded in other com-
prehensive income.
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2.13 Leases
When a contract enters into force, the
Group assesses whether the contract con-
stitutes, or involves, a lease. A contract
constitutes, or involves, a lease if the con-
tract transfers the right to control the use
of a recognized asset for a specified period
of time in exchange for a consideration.
2.13.1 Leasing Accounting from Lessee
The Group applies a unified approach
to recognition and measurement for all
leases (except for short-term leases and
low-value leases). The Group recognizes
liabilities from leases for payments and as-
sets with a right of use that represent the
right to use the underlying assets.
2.13.2 Right-of-use Assets
The Group recognizes the assets with the
right of use on the date of commencement
of the lease term (i.e. the date on which the
underlying asset is available for use). As-
sets with the right to use are measured at
cost, reduced by any cumulative deprecia-
tion and impairment losses and are adjust-
ed based on any revaluation of the liability
from leases. The cost of the assets with the
right of use consists of the amount of the
liability from recognized leases, the initial
direct costs and any leases paid on the
date of commencement of the lease pe-
riod or earlier, minus any lease incentives
received. Assets with the right of use are
depreciated based on the fixed method in
the shortest period of time between the
duration of the lease and their useful life.
If the ownership of the leased asset is trans-
ferred to the Group at the end of the lease
term or if its cost reflects the exercise of a
market right, depreciation is calculated in
accordance with the estimated useful life
of the asset.
The Group has contracts for the lease of
buildings (used as offices, warehouses),
means of transport as well as other equip-
ment used in its business activities. Lease
agreements may contain lease and non-
lease information. The Group has chosen
not to separate the parts of the contract
that are not a lease from the elements of
the lease and therefore treats any element
of the lease and any related parts that do
not constitute a lease as a single lease. As-
sets with the right of use are subject to im-
pairment test.
2.13.3 Liabilities from Leases
At the date of commencement of the lease,
the Group calculates the liability from leas-
es at the present value of the leases to be
paid during the lease term. Leases consist
of fixed parts (including substantially fixed
leases) reduced by any lease incentives,
floating parts that depend on an index or
interest rate and amounts expected to be
paid on the basis of residual value guaran-
tees. Leases also include the exercise price
as income, during the date when such are
approved by the Annual General Meet-
ing of Shareholders. Interim dividends are
recognized on the date of their approval
by the General Meeting of Shareholders,
or in case a Board of Directors decision
approving their distribution precedes the
date of approval of the General Meeting,
the interim dividends will be recognized
on the date of approval by the Board of Di-
rectors, in accordance with local corporate
law.
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Page 300 of 370
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of the purchase right if it is rather certain
that the Group will exercise that right and
the payment clause that would allow to
terminate the lease if the term of the lease
reflects the exercise of the right to re-
nounce. To discount the leases, the Group
uses the incremental borrowing rate since
the implied interest rate related to the
leasing cannot be easily determined.
After the start date of the lease, the amount
of the lease liability increases based on the
interest on the liability and decreases with
the payment of the lease. In addition, the
book value of the liability from leases is
recalculated if there are reassessments or
amendments to the lease agreement.
2.13.4 The Group as Lessor
When the assets are leased in the context
of financial leasing agreements, the pre-
sent value of the leasing payments to be
collected is recognized as receivable. The
difference between the gross receivable
amount and the present value of the claim
is recognized as non-accrued financial
income.
When the assets are leased in the context
of operating leasing agreements, they are
recorded in the statement of financial po-
sition according to the nature of each as-
set. The income generated from operating
leasing agreements is recorded in the fi-
nancial results via the straight line method
over the leasing period.
2.14 Income Tax
Tax burden for the year relates to the cur-
rent and deferred taxes.
Current income taxes are payable taxes on
taxed income for the year based on effec-
tive tax rates as of the reporting date of the
financial statements, as well as additional
income taxes relating to previous years.
Deferred taxes are tax burden/exemptions
relating to current year’s profit (or losses)
that will be charged by the tax authorities
in future years. Deferred income taxes are
calculated according to tax rates effective
as of the dates they will be paid, on the dif-
ference between accounting and tax base
of individual assets and liabilities, provided
that these differences imply time devia-
tions, which will be erased in future.
Deferred tax receivables are recognized
only to the extent they imply future tax-
able income, which will be offset by these
deferred tax receivables. Deferred tax re-
ceivables might be lowered any time when
it is not evident that such future tax relaxa-
tion will be certain.
Current and deferred tax is recorded in the
results or directly in Equity, if it relates to
elements directly recognized in Equity.
The Group’s companies offset deferred
tax receivables with deferred tax liabilities,
only if:
a) It has a legal applicable right to offset
current tax receivables with current tax
liabilities.
b) The deferred tax receivables and liabili-
ties relate to income taxes imposed by
the same tax authority.
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2.15.1 Short-term liabilities
Liabilities for wages and salaries that
are expected to be fully settled within
12 months from the end of the period in
which the employees provide the relevant
service are recognized for the services
of the employees until the end of the
reporting period and are measured at
the amounts expected to be paid during
the settlement of liabilities. Liabilities are
presented in the statement of financial
position in the other liabilities.
2.15.2 Liabilities after the exit from
service
The Group has a liability in a defined
benefit plan that determines the amount
of retirement benefit that an employee will
receive upon retirement, which depends
on more than one factor such as age, years
of service and compensation.
The subsidiaries Don & Low LTD and
THRACE POLYBULK A.S. have defined
benefit pension plans for their personnel
which are funded.
The Greek companies of the Group as
well as Thrace Ipoma A.D. have unfunded
defined contribution plans.
The liability recorded in the statement of
financial position for the defined benefit
plan is the present value of the defined
benefit liability at the reporting date less
the fair value of the plan’s assets and
the distribution of benefits is performed
over the last 16 years concluding to the
employees’ retirement date, following the
scale of Law 4093/2012. The commitment
of the defined benefit is calculated
annually by an independent actuary using
the method of the projected credit unit.
The present value of the defined benefit
liability is calculated by discounting the
expected future cash outflows using
interest rates of high quality corporate
bonds denominated in Euro and having
a term approaching the maturity of the
relevant retirement liability.
The cost of current employment in the
defined benefit plan is recognized in the
statement of comprehensive income and
reflects the increase in the defined benefit
liability arising from the employment of
employees during the year.
Changes in the present value of the defined
benefit liability arising from modifications
or reductions in the plan are recognized
immediately in the financial results as prior
service cost.
The financial cost is calculated by applying
the discount rate to the balance of the
defined benefit liability. This cost is included
in the statement of comprehensive income
on employee benefits.
Actuarial gains and losses arising from
empirical adjustments and from changes
in actuarial assumptions are recognized in
other comprehensive income in the year in
which they arise. They are also included in
the results carried forward in the statement
of changes in equity.
All the above calculations are being
performed via an actuary study, conducted
by an independent actuary, whereas for
the interim periods certain estimates are
being made. The estimates which are
being utilized for the determination of the
net cost for post-employment benefits
include among other the discount rate,
the inflation and the average annual salary
increase. Any alterations in the assumptions
affect significantly the book value of the
liabilities for post-employment benefits.
The discount rate that is used derives from
the one of the long-term bonds with AA
2.15 Employee Benefits
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Amounts in thousand Euro, unless stated otherwise
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Contents
credit rating and with maturities similar to
the liabilities of the plan.
2.15.3 Benefits following
termination of employment
Termination benefits become payable
when employment ends before the normal
retirement date or when the employee
accepts voluntary retirement in exchange
for these benefits. The Group records these
benefits no earlier than the following dates:
a) when the Group can no longer withdraw
the offer for these benefits and b) when
the Group recognizes restructuring costs
that are part of the application of IAS 37
which includes the payment of termination
benefits. In case of an offer for voluntary
retirement, the termination benefits are
calculated according to the number of
employees who are expected to accept
the offer. Termination benefits which are
due 12 months after the reporting date are
discounted.
2.16 Financial Assets
2.16.1 Financ ial A ssets
Initial Measurement and Recognition
The Group and the Company measure the
financial assets initially at their fair value
by adding transaction costs. The trade
receivables initially are being measured /
valued according to the transaction price.
The financial assets with embedded deriv-
atives are being reviewed in their entirety
whenever it is examined if their cash flows
are only the payment of capital (principal)
and interest. According to the provisions
of IFRS 9, the securities are measured at a
later stage at fair value via the other com-
prehensive income or at fair value via the
financial results for the year. The classifica-
tion is based on two criteria: a) the busi-
ness model concerning the management
of financial assets and b) the conventional
cash flows of the instrument, meaning if
they represent “only payments of capital
and interest” (SPPI criterion) against the
pending balance.
Subsequent Measurement
After initial recognition, financial assets are
classified into three categories:
• at amortized cost
• at fair value through other compre-
hensive income
• at fair value through profit or loss
The Group and the Company do not have
assets that are valued at fair value through
the other comprehensive income as of 31
December 2023.
Financial assets classified at amortized
cost are subsequently measured using
the effective interest method (EIR) and are
subject to impairment testing. Profits and
losses are recognized in profit or loss when
the asset ceases to be recognized, modi-
fied or impaired.
Termination of financial asset
recognition
The Group (or Company) ceases to rec-
ognize a financial asset when and only
when the contractual rights expire on the
cash flows of the financial asset or when it
transfers the financial asset and the trans-
fer meets the conditions for write-off.
Reclassification of financial assets
Reclassification of financial assets takes
place in rare cases and is due to a decision
Annual Financial Report as of 31.12.2024
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Contents
by the Group (or Company) to modify the
business model it applies with regard to
the management of these financial assets.
Impairment
The Group and the Company recognize
provisions for impairment with regard
to the expected credit losses of all finan-
cial assets. The expected credit losses are
based on the difference between contrac-
tual cash flows and all cash flows that the
Group (or Company) expects to receive.
The difference is discounted using an es-
timate of the initial effective interest rate
of the financial asset. With regard to the
trade receivables, the Group and the Com-
pany applied the simplified approach of
IFRS 9 and estimated the expected credit
losses based on the anticipated losses for
the entire life of these assets.
Regarding the remaining financial assets,
the expected credit losses are being calcu-
lated according to the losses of the next 12
months. The expected credit losses of the
following 12 months are part of the antici-
pated credit losses for the entire life of the
financial assets, which emanate from the
probability of a default in the payment of
the contractual liabilities within the next
12-month period starting from the report-
ing date. In case of a significant increase
in credit risk since the initial recognition,
the provision for impairment will be based
on the expected credit losses of the entire
life of the asset. For the assessment of the
increase in credit risk, the Group and the
Company evaluate the creditworthiness
of the counterparty in comparison to the
corresponding creditworthiness at initial
recognition, as well as the probability of
default within the next 12 months, rela-
tive to the corresponding probability at
initial recognition. The Group and the
Company consider a financial asset to be
non-performing when internal or external
information indicates that the Group or
the Company is unlikely to recover the rel-
evant contractual amounts. Furthermore,
the Group and the Company derecognize a
financial asset when they assess that there
is no reasonable expectation of recovering
the relevant contractual cash flows.
2.16.2 Financial Derivative Products
The Group uses financial derivatives, main-
ly forward foreign exchange contracts, to
hedge risks that emanate from changes in
exchange rates.
Financial derivatives are measured at fair
value, during the reporting date of the
financial statements. The fair value of for-
ward contracts is calculated based on the
market prices of contracts with respective
maturities (valuation of 1st level of IFRS 7).
Financial derivatives of the Group do not
have the characteristics of hedging instru-
ments as defined in IAS 39 and therefore
gains and losses resulting from change in
their fair values are recorded directly in the
results of the statement of the comprehen-
sive income.
2.16.3 Accounts Receivable -
Provisions for Doubtful
Receivables
Accounts receivable are initially recorded
at their fair value, which is the transaction
value, and are subsequently measured at
amortized cost using the effective interest
rate, less the expected credit losses arising
from all possible default events through-
out expected life of a financial instrument
at each reporting date. At each financial
statement date, the recoverability of the
receivable accounts is estimated either
per customer when there is objective evi-
dence that the Group is unable to collect
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Initial Recognition and subsequent
measurement of financial liabilities
All financial liabilities are initially valued at
their fair value minus the transaction costs,
in the case of loans and liabilities. For later
measurement purposes, financial liabilities
are classified as financial liabilities at am-
ortized costs. Loans are characterized as
short-term liabilities except if the Group
has the final right to postpone repayment
for at least 12 months after the report-
ing date of the financial statements. Bank
overdrafts are included in short-term debt
in the balance sheet and in investing ac-
tivities in the statement of cash flows.
De-recognition of Financial Liabilities
A financial liability is written off when the
commitment arising from the liability is
canceled or expires. When an existing fi-
nancial liability is replaced by the same
lender but on fundamentally different
terms, or the terms of an existing liability
are significantly modified, this exchange
or amendment is treated as de-recogni-
tion of the initial liability and recognition
of a new liability. The difference in the re-
spective book values is recognized in the
statement of comprehensive income.
Offsetting between financial assets and
liabilities
Financial assets and liabilities are offset
and the net amount is reflected in the
statement of financial position only when
the Group or Company has this legal right
and intends to offset them on a net basis
or to claim the asset and settle the liabil-
ity at the same time. The legal right should
not depend on future events and should
be enforceable in the normal course of
business and in the event of a breach, in-
solvency or bankruptcy of the company or
counterparty.
2.17 Financial Liabilities
2.18 Equity
The share capital includes common shares
of the Company. The difference between
the nominal value of shares and their is-
sue price is registered in the “Share Pre-
mium” account. Direct expenses for the
issue of shares, are presented after the
deduction of the relevant income tax and
reduce the issue proceeds, namely as a de-
duction from the share premium reserve.
During the purchase of treasury shares,
the amount paid, including the relevant
expenses is recorded as a deduction from
the shareholders’ equity in the other re-
serves. No profit or loss is recognized in the
statement of comprehensive income from
the purchase, sale, issuance or cancella-
tion of treasury shares. Expenses which are
realized for the issuance of shares are re-
corded after the deduction of the relevant
income tax, as deduction from the prod-
uct of the issue.
all amounts due under the contractual
terms, either on historical trends, statistical
data and anticipated future events (for ex-
ample, taking into account macroeconom-
ic factors such as the broader economic
environment, future market conditions,
etc.) and the relevant provision for impair-
ment is formed. The provision formed is
adjusted for impairment and is included in
‘Other expenses’. Any write-offs of receiva-
bles from accounts receivable are made
through the provision made.
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3. Notes on the Financial Statements
3.1 Evolution and Performance of the Group
The following table depicts in summary the Group’s financial results from continuing
operations for the year ended 31st December 2024 and 2023:
Financial Results of Year 2024(amounts in thousand Euro)2024 2023Change %Turnover370,368 345,373 7.2%Gross Profit77,140 77,069 0.1%Gross Profit Margin20.8% 22.3% ΕΒΙΤ15,658 20,663 -24.2%EBIT Margin4.2% 6.0% EBITDA*41,361 44,017 -6.0%EBITDA Margin11. 2% 12.7% Adjusted EBITDA *42,256 44,017 -4.0%Adjusted EBITDA Margin11.4% 12.7% Earnings before Taxes (EBT)13,735 21,336 -35.6%EBT Margin3.7% 6.2% Earnings after Taxes (EAT)11,004 18,326 -40.0%EAT Margin3.0% 5.3% Total EATAM (apart from NCI)10,363 17,767 -41.7%EATAM Margin (apart from NCI)2.8% 5.1% Earnings per Share (in euro)0.2415 0.4134 -41.6%
Note: The alternative performance measures are presented and described analytically in the Section 7 of the
present Report.
It is noted that the Adjusted EBITDA does
not include non-recurring expenses of
€895, related to the termination of the pro-
duction of artificial grass, an activity that
the Group’s Management decided to dis-
continue (note 3.7). The relevant expenses
mainly concern impairment on finished
product inventories, based on the relevant
accounting policies. However, the Group’s
Management is making an effort to utilize
these inventories in the future.
* EBITDA is defined as operating results be-
fore taxes, interest, depreciation, impair-
ment, financing and investing results. The
figure of EBITDA is not precisely defined
under the International Financial Report-
ing Standards (IFRS) as adopted by the Eu-
ropean Union. The calculation of EBITDA is
performed as follows:
Annual Financial Report as of 31.12.2024
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“Operating profit / (loss) before taxes, cash
and investment results” plus “Deprecia-
tion”, where:
- Operating profit / (loss) before
taxes, finance and investment re-
sults (EBIT) (see “Segment Report-
ing, Statement of Comprehensive
Income for the Period”, note 3.2):
€15,658.
- Depreciation/Amortization (see
“Segment Reporting, Statement of
Comprehensive Income for the Pe-
riod”, note 3.2): €25,703.
Furthermore, as mentioned above, the
Adjusted EBITDA is calculated as EBITDA,
minus extraordinary, non-recurring in-
come or expenses, which for the fiscal year
01.01.2024 – 31.12.2024 amounted to € 895
and related to the termination of the pro-
duction of artificial grass.
3.2 Segment Reporting
The Group applies IFRS 8 to monitor its
business activities by segment. The areas
of activity of the Group have been defined
based on the legal structure and the busi-
ness activities of the Group. The Group
Management, being responsible for mak-
ing financial decisions, monitors the finan-
cial information separately as presented
by the parent company and by each of its
subsidiaries.
The operating segments (business units)
are based on the different product cat-
egory, the structure of the Group’s man-
agement and the internal reporting sys-
tem. Using the criteria as defined in the
accounting reporting standards and based
on the Group’s different activities, the
Group’s business activity is divided into
two segments, namely the “Technical Fab-
rics” and the “Packaging” segment.
The information related to the business ac-
tivities that do not comprise separate seg-
ments for reporting purposes, has been
aggregated and depicted in the category
“Other”, which includes the agricultural
segment and the activities of the Parent
Company.
The operating segments (business units)
of the Group are as follows:
Technical Fabrics Packaging OtherProduction and trade Production and trade of It includes the Agricultural segment of technical fabrics for packaging products, plastic and the business activity of the industrial and technical bags, plastic containers for Parent company which apart from use.packaging of food and paints the investing activities provides and other packaging materials also Administrative – Financial – IT for agricultural use.services to its subsidiaries.
Annual Financial Report as of 31.12.2024
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INTRA-ELEMENTS OF STATEMENT OF TECHNICAL PACKAGING OTHERSEGMENT GROUPFINANCIAL POSITION OF 31.12.2024FABRICSELIMINATIONSTotal consolidated assets 267,868 156,470 81,944 (70,436) 435,846Total consolidated liabilities 84,772 72,731 5,335 (2,161) 160,677
INTRA-STATEMENT OF INCOME FOR THE TECHNICAL PACKAGING OTHERSEGMENT GROUPPERIOD 01.01 - 31.12.2024FABRICSELIMINATIONSTurnover 240,180 141,893 5,772 (17, 477) 370,368Cost of sales (196,155) (109,252) (5,314) 17,493 (293,228)Gross profit 44,025 32,641 458 16 77,140Other operating income 3,395 1,920 117 (504) 4,928Selling & Distribution expenses (29,221) (13,352) - (404) (42,977)Administrative expenses (12,366) (5,100) (1,045) 854 (17,657)Research and Development Expenses (2,105) (389) - - (2,494)Other operating expenses (2,023) (1,495) (15) (3) (3,536)Other Gain / (Losses) 304 (40) (10) - 254Operating profit / (loss) 2,009 14,185 (495) (41) 15,658Interest & Other related (expenses)/income (955) (2,298) (16) 5 (3,264)Income from dividends - - 9,073 (9,073) -Profit / (loss) from companies consolidated 214 1,072 55 - 1,341with the Equity methodEarnings / (losses) before taxes 1,268 12,959 8,617 (9,109) 13,735Income Tax (471) (2,319) (214) 273 (2,731)Earnings / (losses) after taxes 797 10,640 8,403 (8,836) 11,004Depreciation 16,660 8,784 259 - 25,703Earnings / (losses) before interest, tax, 18,669 22,969 (236) (41) 41,361depreciation & amortization (EBITDA)
Annual Financial Report as of 31.12.2024
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INTRA-ELEMENTS OF STATEMENT OF TECHNICAL PACKAGING OTHERSEGMENT GROUPFINANCIAL POSITION OF 31.12.2023FABRICSELIMINATIONSTotal consolidated assets 258,626 133,210 84,643 (70,215) 406,264Total consolidated liabilities 72,214 55,996 2,945 (1,945) 129,210
INTRA-STATEMENT OF INCOME FOR THE TECHNICAL PACKAGING OTHERSEGMENT GROUPPERIOD 01.01 - 31.12.2023FABRICSELIMINATIONSTurnover 230,755 125,202 5,600 (16,184) 345,373Cost of sales (183,200) (96,327) (5,334) 16,557 (268,304)Gross profit 47,555 28,875 266 373 77,069Other operating income 3,461 1,017 339 (752) 4,065Selling & Distribution expenses (26,921) (11, 583) - (331) (38,835)Administrative expenses (12,480) (4,405) (1,062) 684 (17,263)Research and Development Expenses (1,876) (630) - - (2,506)Other operating expenses (889) (969) (18) 16 (1,860)Other Gain / (Losses) 54 (21) (40) - (7)Operating profit / (loss) 8,904 12,284 (515) (10) 20,663Interest & Other related (expenses)/income (1,061) (1,463) 850 16 (1,658)Income from dividends - - 12,029 (12,029) -Profit / (loss) from companies consolidated 620 1,491 220 - 2,331with the Equity methodEarnings / (losses) before taxes 8,463 12,312 12,584 (12,023) 21,336Income Tax(435) (1,956) (1,294) 675 (3,010)Earnings / (losses) after taxes8,028 10,356 11,290 (11, 3 48) 18,326Depreciation 15,731 7, 371 252 - 23,354Earnings / (losses) before interest, tax, 24,635 19,655 (263) (10) 44,017depreciation & amortization (EBITDA)
The table below presents the breakdown of turnover by geographic area based on the
location of customers:
Annual Financial Report as of 31.12.2024
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01.01 01.01 Sales per geographic area– 31.12.2024– 31.12.2023European Union Countries 239,985 223,726United Kingdom 58,299 60,946Other European Countries* 47,421 40,356United States of America 13,730 10,188Other ** 10,933 10,157Total 370,368 345,373
(*) The following countries are included in the «Other European Countries» Category: Norway, Serbia,
Switzerland, Albania, North Macedonia, Faroe Islands, Kosovo, Bosnia, Turkey, Ukraine, Russia,
Belarus and Montenegro.
(**) The «Other» Category includes the countries of Asia, Africa, Oceania, and North & South America
(except for USA).
Group CompanyOther Income2024 2023 2024 2023Grants* 536 1,434 - 4Income from rents 72 81 - -Income from provision of services 253 210 - -Income from prototype materials 63 68 - -Income from unutilized provisions 689 234 - -(note 3.16.2, 3.16.3)Income from energy management 537 251 - -programsOther income 876 664 117 335Income from photovoltaics 1,902 1,123 - -Total 4,928 4,065 117 339
* The grants mainly include: investment grants, research and development, recruitment of junior
graduates as well as professional training of the Group’s employees.
3.3 Other Income
Annual Financial Report as of 31.12.2024
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Group CompanyOther Gains / (Losses)2024 2023 2024 2023Gains / (Losses) from sale – disposal of (44) 41 - (30)PP&EGains / (Losses) from foreign exchange 298 (48) (9) (9)differencesTotal 254 (7) (9) (39)
3.4 Other Gains / (Losses)
Analysis of ExpensesGroup Company(Production-Administrative-Sales & Distribution-Research & 2024 2023 2024 2023Development)Payroll expenses (note 3.6) 67,747 60,181 2,917 2,843Third party fees – expenses * 6,384 7,102 1,694 1,873Electricity– Natural gas 22,309 20,135 30 30Repairs / Maintenance 6,315 6,176 17 19Rental expenses (note 3.12) 1,505 1,222 19 15Insurance expenses 3,487 3,079 77 80Exhibitions / travelling expenses 2,287 2,221 98 122IT and telecom expenses 1,682 1,629 446 464Promotion and advertising expenses 781 627 250 196Transportation expenses 20,950 18,708 - -Consumables 7,077 7,039 2 3Sundry expenses / Other provisions 4,629 4,914 551 499Depreciation / Amortization (note 3.11, 25,071 22,985 258 2523.12, 3.13)Total 170,224 156,018 6,359 6,396
* Third party fees – expenses include fees paid to auditors, legal and advisory firms, as well as to the
Board of Directors (note 3.27).
3.5 Analysis of Expenses (Production-Administrative-Sales &
Distribution-Research & Development)
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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Group CompanyAnalysis of Cost of Goods Sold2024 2023 2024 2023Production expenses 107,096 97,414 5,314 5,173Cost of materials and inventory sold 186,132 170,890 - -Total 293,228 268,304 5,314 5,173
* The production expenses in the Company refer to services provided to subsidiaries.
3.6 Payroll Expenses
Payroll expenses analysis is as follows:
Group CompanyPayroll expenses2024 2023 2024 2023Salaries & Wages 55,424 49,920 2,432 2,416Employer’s contributions 9,499 8,497 405 390Provision for personnel indemnity 839 868 35 14(note 3.21)Sub-Total 65,762 59,285 2,872 2,820Other benefits & personnel expenses 1,985 896 45 23Total (note 3.5) 67,747 60,181 2,917 2,843
The number of employed staff at the Group and Company level at the end of the finan-
cial year (without including the joint ventures), was as follows:
The analysis of expenses per cost category, is as follows:
Group CompanyAnalysis of expenses2024 2023 2024 2023Production 107,096 97,414 5,314 5,173Administrative 17,657 17,263 1,045 1,223Sales & Distribution 42,977 38,835 - -Research and Development 2,494 2,506 - -Total 170,224 156,018 6,359 6,396
The analysis of cost of goods sold is presented below:
Annual Financial Report as of 31.12.2024
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Group CompanyOther Operating Expenses2024 2023 2024 2023Provisions for doubtful receivables 384 39 - -(note 3.16)Other taxes and duties non-435 166 - -incorporated in operating costDepreciation (note 3.11) 632 369 - -Additional cost of staff indemnities 349 365 12 -paidCommissions / other bank expenses 108 104 3 4Expenses for the purchase of 111 100 - -prototype materials (maquettes)Other operating expenses 622 717 - 15Sub-Total 2,641 1,860 15 19Extraordinary and non-recurring 895 - - -expenses (note 3.1)Total 3,536 1,860 15 19
The extraordinary and non-recurring ex-
penses of €895 related to the termination
of the production of artificial grass, an ac-
tivity that the Group’s Management decid-
ed to discontinue in the context of actions
performed with the aim of operations en-
hancement. The relevant expenses mainly
concern impairment on finished product
inventories, based on the relevant ac-
counting policies. However, the Group’s
Management is making an effort to utilize
the inventories in the future.
Group CompanyNumber of employees2024 2023 2024 2023Full time employees – wage based 1,800 1,684 25 25employees
3.7 Other Operating Expenses
Annual Financial Report as of 31.12.2024
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3.8 Financial income/(expenses)
3.8.1 Financial income
Group CompanyFinancial income2024 2023 2024 2023Interest income and other related 933 648 1 2incomeReversal of discounted long-term - 1,088 - 892receivable in relation to OAEDForeign exchange differences 573 1,316 - -Total 1,506 3,052 1 894Income from dividends (note 3.26) - - 9,073 12,029
3.8.2 Financial expenses
Group CompanyFinancial expenses2024 2023 2024 2023Interest expense and other related 3,601 3,197 13 20expensesForeign exchange differences 876 1,242 - 22Financial result from Pension Plans 293 271 4 2Total 4,770 4,710 17 44
Earnings after tax, per share, are calculat-
ed by dividing net earnings (after tax) al-
located to shareholders, by the weighted
average number of shares outstanding
during the respective financial year, after
the deduction of any treasury shares held.
3.9 Earnings per Share (Consolidated)
Basic earnings per share 2024 2023Earnings allocated to shareholders of the Parent Company 10,363 17,767Number of shares outstanding (weighted) 42,916 42,974Basic and adjusted earnings per share (Euro in absolute 0.2415 0.4134numbers)
On 31.12.2024 and 31.12.2023, the Company held 863,796 and 802,049 treasury shares
respectively, with the corresponding acquisition cost amounting to € 3,791 and € 3,548
respectively.
Annual Financial Report as of 31.12.2024
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The analysis of tax charged in the year’s financial results, is as follows:
Group CompanyIncome Tax2024 2023 2024 2023Current income tax (5,286)(5,426)(538) (1,299)Deferred tax (expense)/income (note 2,168 2,416 267 53.22)Unutilized tax provision 387 - 56 -Total (2,731)(3,010)(215) (1,294)
3.10 Income Tax
The income tax for the period is calculated
based on the domestically applicable tax
rates. Deferred taxes are calculated on
temporary differences using the appli-
cable tax rate in the countries where the
Group’s companies operate.
The effective tax rate of the Group differs
significantly from the nominal tax rate, as
there are tax losses in the companies of
the Group for which no deferred tax asset
is recognized as well as significant non-tax
deductible expenses.
According to Law 4799/2021, the income
tax rate of the legal entities in Greece set-
tled at 22% for the fiscal years 2024 and
2023.
The income tax (reconciliation of the ac-
tual tax rate) is as follows:
Group CompanyIncome Tax2024 2023 2024 2023Earnings / (losses) before tax13,735 21,336 8,563 12,364Income tax rate22% 22% 22% 22%Corresponding income tax(3,022)(4,694)(1,884) (2,720)Effect due to different tax rates of international 1,103 817 - -subsidiariesEffect due to non-tax-deductible expenses(780) (1,497) (59) (267)Effect due to revenues not subject to tax127 1,096 1,680 1,922Income tax differences from previous years(163) (331) (8) (229)Effect from tax losses for which no deferred tax asset (383) (101) - -has been recognizedUnutilized tax provision387 - 56 -
Annual Financial Report as of 31.12.2024
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From the fiscal year 2011 and onwards, the
Group’s Greek companies receive an “An-
nual Tax Certificate”. The “Annual Tax Cer-
tificate” is issued from the same Statutory
Certified Auditor who audits the annual
financial statements. Following the com-
pletion of the tax audit, the Statutory Cer-
tified Auditor grants the company with a
“Tax Compliance Certificate” which is later
submitted electronically to the Ministry of
Finance.
The tax audit for the year 2023 for the
Group’s Greek companies Thrace Plastics
Co. SA, Thrace Nonwovens & Geosynthet-
ics Single Person SA, Thrace Plastics Pack
SA, Thrace Polyfilms Single Person SA,
Thrace Eurobent SA, which was conducted
in accordance with the provisions of article
65a of L. 4172/2013, was completed by the
certified auditors and revealed no material
tax liabilities apart from those recorded
and depicted in the financial statements.
Annual tax certificates were issued, with
an unmodified opinion, for each of the
above companies.
For the financial year 2024, a tax audit for
the above companies is already performed
by the certified auditors in accordance with
the provisions of article 65 of L. 4172/2013.
This audit is ongoing and the relevant tax
certificate is expected to be issued fol-
lowing the release of the 2024 financial
statements. If until the completion of the
tax audit additional tax liabilities arise, the
Management of the Group estimates that
such will not have a material impact on the
financial statements.
The fiscal years for which the Group com-
panies outside Greece have not received
a tax certificate, indicating that relevant
tax audits by the respective tax authorities
may take place in the future are presented
below:
Group CompanyIncome Tax2024 2023 2024 2023Effect due to change of tax rate of companies- 1,700 - -Income Tax(2,731) (3,010) (215) (1,294)
Annual Financial Report as of 31.12.2024
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Company Tax un-audited fiscal yearsDon & Low LTD 2020-2024Synthetic Holdings LTD 2020-2024Synthetic Textiles LTD 2018-2024Thrace Synthetic Packaging LTD 2020-2024Thrace Polybulk A.B 2018-2024Thrace Polybulk A.S 2020-2024Thrace Greiner Packaging SRL. 2018-2024Trierina Trading LTD 2019-2024Thrace Ipoma A.D. 2019-2024Thrace Plastics Packaging D.O.O. 2019-2024Lumite INC 2019-2024Thrace Linq INC 2019-2024Adfirmate LTD 2019-2024Pareen LTD 2019-2024
As of 31.12.2024, the Company’s current in-
come tax of € 538 (31.12.2023: € 1,299) was
offset against an advance tax payment
and other withholding taxes, resulting in a
net income tax receivable from the Greek
State of € 633. The Company had also an
income tax liability of € 100 related to in-
come tax installments for the fiscal year
2023 (31.12.2023: income tax receivable of
€ 866 and income tax liability of € 615).
As of 31.12.2024, the Group’s current in-
come tax of € 5,286 (31.12.2023: € 5,426)
was offset against an advance tax payment
and other withholding taxes, resulting in a
net income tax receivable from the Greek
State of € 954 and an income tax liability of
€ 2,414 (31.12.2023: income tax receivable
of € 956 and income tax liability of € 1,914).
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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The Group pursues economic growth in
alignment with environmental responsibil-
ity. All investments are assessed towards
the Group’s environmental strategy with
a focus, among others, on tackling climate
change and serving the principles of the
circular economy. At the same time, the
Group constantly upgrades its PP&E, thus
improving their environmental footprint,
while it evaluates on a regular basis any evi-
dence of impairment. Technologies utilized
in the context of the investments made by
the Group in mechanical equipment, com-
prise at the same time the leading, modern
technologies of the sector on a global level.
At the same time, additional investments
are being implemented for modernization
of buildings and mechanical equipment,
wherever required, but mainly for the fur-
ther automation of production processes as
well as recycling facilities and photovoltaic
systems. Also, at the time of preparation of
the present report, there have been no laws
or regulations (on either European or global
level) that imply or have actually led to the
limitation or cessation of any production
process due to inappropriate technologies
utilized, currently or in future. On the con-
trary, the product characteristics, the new
product development, the emphasis on
mono-material production processes en-
hance significantly the ability of the Group
to recycle its products or to produce new
products with recycled materials in line
with the principle of circular economy.
(More information is included in paragraph
6 of the Sustainability Report). Therefore,
on 31.12.2024, the Group has not identified
any indications of possible impairments or
negative effects when reviewing the useful
lives of the main categories of tangible fixed
assets.
The changes in the PP&E during the year are
analyzed as follows:
3.11 Property, Plant & Equipment (PP&E)
Property, Plant & Equipment (PP&E)Tangible Buildings Fields – Means of Furniture & assets under Group 2024& technical Machinery Totalland plotsTransportfixturesconstruction or facilitiesinstallationACQUISITION COSTAcquisition cost 4,508 78,551367,3901,855 10,750 17,681 480,73501.01.2024Additions 15 3,973 17, 345 199 516 18,000 40,048Disposals - (41) (3,672) - (3) - (3,716)Impairments- - - - - (28) (28)Transfers- 2,360 13,677 23 125(16,185)-
Annual Financial Report as of 31.12.2024
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Property, Plant & Equipment (PP&E)Tangible Buildings Fields – Means of Furniture & assets under Group 2024& technical Machinery Totalland plotsTransportfixturesconstruction or facilitiesinstallationAssets held for sale- - (4,148) - --(4,148)Foreign exchange 34 1,034 5,079 (8) 153 76 6,368differencesAcquisition cost 4,557 85,877395,6712,069 11,541 19,544 519,25931.12.2024DEPRECIATIONAccumulated depreciation -(35,347) (257,862)(1,105) (8,751) -(303,065)01.01.2024Depreciation for the - (2,621) (20,881) (169) (532) - (24,203)period (note 3.5, 3.7)Disposals - 41 3,489 2 - - 3,532Impairments - - - - - - -Transfers - - - - - - -Assets held for sale - - 2,450 - - - 2,450Foreign exchange - (644) (3,583) 2 (219) - (4,444)differencesAccumulated depreciation -(38,571)(276,387)(1,270) (9,502) - (325,730)31.12.2024NET BOOK VALUE31.12.2023 4,508 43,204 109,528 750 1,999 17, 681 177, 67031.12.2024 4,557 47, 306 119,284 799 2,039 19,544 193,529
In the fiscal year 2024, the Management
of the subsidiary company Don & Low LTD
(included in technical fabrics segment)
decided the potential sale of specific me-
chanical equipment, which is expected to
be completed during the fiscal year 2025.
In this context, the Group has transferred
the net value of the equipment amounting
to € 1,698 from non-current assets to the
Group’s current assets under the line item
“non-current assets held for sale”.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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Property, Plant & Equipment (PP&E)Tangible Buildings Fields – Means of Furniture & assets under Group 2023& technical Machinery Totalland plotsTransportfixturesconstruction or facilitiesinstallationACQUISITION COSTAcquisition cost 4,333 73,339 354,058 1,399 10,307 9,682 453,11801.01.2023Additions 126 3,212 12,070 428 500 13,557 29,893Disposals - - (4,487) (109) (16) - (4,612)Impairments - - - - (178) (28) (206)Transfers 35 1,601 3,615 140 61 (5,563) (111)Foreign exchange 14 399 2,134 (3) 76 33 2,653differencesAcquisition cost 4,508 78,551367,3901,855 10,750 17,6 81 480,73531.12.2023DEPRECIATIONAccumulated depreciation -(32,835) (241,474)(1,105) (8,486) - (283,900)01.01.2023Depreciation for the - (2,262) (19,204) (112) (484) - (22,062)period (note 3.5, 3.7)Disposals - - 4,330 110 14 - 4,454Impairments - - - - 175 - 175Transfers - - (103) - 103 - -Foreign exchange - (250) (1,411) 2 (73) - (1,732)differencesAccumulated depreciation - (35,347)(257,862)(1,105) (8,751) - (303,065)31.12.2023NET BOOK VALUE31.12.2022 4,333 40,504 112, 58 4 294 1,821 9,682 169,21831.12.2023 4,508 43,204 109,528 750 1,999 17,6 81 177,670
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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Property, Plant & Equipment (PP&E)Tangible Buildings Fields – Means of Furniture & assets under Company 2024& technical Machinery Totalland plotsTransportfixturesconstruction facilitiesor installationACQUISITION COSTAcquisition cost - 392 11,124 196 1,293 - 13,00501.01.2024Additions- - - - 19 - 19Disposals / - - - - - - -ImpairmentsAcquisition cost - 392 11,124 196 1,312 - 13,02431.12.2024DEPRECIATIONAccumulated depreciation -(272) (11,124)(196) (1,183) -(12,775)01.01.2024Depreciation for the - (12) - - (33) - (45)period (note 3.5)Accumulated depreciation - (284)(11,124)(196) (1,216)(12,820)31.12.2024NET BOOK VALUE31.12.2023- 120 - - 110 - 23031.12.2024- 108 - - 96 - 204
Annual Financial Report as of 31.12.2024
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Property, Plant & Equipment (PP&E)Tangible Fields – Buildings Means of Furniture & assets under Company 2023land & technical Machinery TotalTransportfixturesconstruction plotsfacilitiesor installationACQUISITION COSTAcquisition cost - 392 11,159 196 1,281 - 13,02801.01.2023Additions - - - - 12 - 12Disposals - - (35) - - - (35)Acquisition cost - 392 11,124 196 1,293 - 13,00531.12.2023DEPRECIATIONAccumulated depreciation -(259) (11,124)(196) (1,147) -(12,726)01.01.2023Depreciation for the - (13) - - (36) - (49)period (note 3.5)Disposals - - - - - - -Accumulated depreciation - (272)(11,124)(196) (1,183) -(12,775)31.12.2023NET BOOK VALUE31.12.2022 - 133 35 - 134 - 30231.12.2023 - 120 - - 110 - 230
There are no liens and guarantees on the Company’s PP&E, while the liens on the Group’s
PP&E on 31.12.2024 amounted to € 1,744 (31.12.2023: € 2,263).
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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The right-of-use assets are analyzed as follows:
Right-of-use assetsBuildings Machinery Means of Furniture and Group 2024and technical TotalequipmenttransportfixturesfacilitiesACQUISITION COSTAcquisition cost 1,418 486 4,614 64 6,58201.01.2024Additions 13 - 1,201 - 1,214Amendment of lease - - - - -contractsDe-recognition - - (525) (47) (572)Foreign exchange (10) - 37 (1) 26differencesAcquisition cost 1,421 486 5,327 16 7,25031.12.2024DEPRECIATIONAccumulated depreciation (795)(112) (2,471) (50) (3,428)01.01.2024Depreciation for the (291) (35) (968) (4) (1,298)period (note 3.5)Amendment of lease - - - - -contractsDe-recognition - - 512 47 559Foreign exchange 5 - (24) (1) (18)differenceAccumulated depreciation (1,081)(147)(2,951) (6) (4,185)31.12.2024NET BOOK VALUE31.12.2023 623 374 2,143 14 3,15431.12.2024 340 339 2,376 10 3,065
3.12 Right-of-Use Assets / Lease Liabilities
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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Right-of-use assetsBuildings Machinery Means of Furniture and Group 2023and technical TotalequipmenttransportfixturesfacilitiesACQUISITION COSTAcquisition cost 1,260 486 3,481 62 5,28901.01.2023Additions42 - 1,297 17 1,356Amendment of lease 132 - - - 132contractsDe-recognition - - (175) (15) (190)Foreign exchange (16) - 11 - (5)differenceAcquisition cost 1,418 486 4,614 64 6,58231.12.2023DEPRECIATIONAccumulated (745)(78)(1,894) (51) (2,768)depreciation 01.01.2023Depreciation for the (275) (34) (751) (12) (1,072)period (note 3.5)Amendment of lease 220 - - - 220contractsDe-recognition - - 178 14 192Foreign exchange 5 - (4) (1) 1differenceAccumulated (795)(112)(2,471) (50) (3,428)depreciation 31.12.2023NET BOOK VALUE31.12.2022 515 408 1,587 11 2,52131.12.2023 623 374 2,143 14 3,154
Annual Financial Report as of 31.12.2024
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Right-of-use assetsBuildings and Company 2024Means of transport Totaltechnical facilitiesACQUISITION COSTAcquisition cost 01.01.2024568 236 804Additions - - -Amendment of lease contracts - - -Acquisition cost 31.12.2024568 236 804DEPRECIATIONAccumulated depreciation (351)(121) (472)01.01.2024Depreciation for the period (105) (43) (148)(note 3.5)Amendment of lease - - -contractsAccumulated depreciation (456) (164) (620)31.12.2024NET BOOK VALUE31.12.2023 217 115 33231.12.2024 112 72 184
Right-of-use assetsBuildings and Company 2023Means of transport Totaltechnical facilitiesACQUISITION COSTAcquisition cost 01.01.2023622 137 759Additions 41 99 140Amendment of lease contracts (95) - (95)Acquisition cost 31.12.2023568 236 804
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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Right-of-use assetsBuildings and Company 2023Means of transport Totaltechnical facilitiesDEPRECIATIONAccumulated depreciation (461) (76) (537)01.01.2023Depreciation for the period (97) (45) (142)(note 3.5)Amendment of lease 207 - 207contractsAccumulated depreciation (351) (121) (472)31.12.2023NET BOOK VALUE31.12.2022 161 61 22231.12.2023 217 115 332
The change of lease liabilities per year is analyzed as follows:
Lease Liabilities Group CompanyBalance as at 01.01.2023 2,437 223Additions 1,768 251Amendments - -Impairments / Write-offs - -Interest on Leases 110 13Payments (1,287) (165)Foreign Exchange Difference (3) -Balance as at 31.12.2023 3,025 322Additions 1,210 -Amendments (3) -Impairments / Write-offs (23) -
Annual Financial Report as of 31.12.2024
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The expenses related to short-term leases
of the Group amounted to € 1,505 (2023:
€ 1,222) (note 3.5) and are included in the
cost of goods sold and administrative
and sales & distribution expenses. The
expenses related to short-term leases of
the Company amounted to €19 (2023: €15)
(note 3.5) and are included in the adminis-
trative expenses.
The maturity of liabilities from leases is
analyzed in Note 3.31.
Lease Liabilities Group CompanyInterest on Leases 128 9Payments (1,449) (153)Foreign Exchange Difference 12 -Balance as at 31.12.2024 2,901 178
The consolidated and stand alone statement of financial position for the years 2024 and
2023 includes the following amounts related to lease liabilities:
Group CompanyLease Liabilities2024 2023 2024 2023Short-term liabilities 1,282 1,140 137 143Long-term liabilities 1,619 1,885 41 179Total liabilities from Leases 2,901 3,025 178 322
Annual Financial Report as of 31.12.2024
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3.13 Intangible Assets
The changes in the intangible assets during the year are analyzed as follows:
Intangible Assets Group CompanyConcessions Concessions & industrial Company Total& industrial Totalproperty goodwillproperty rightsrightsACQUISITION COSTAcquisition cost 3,496 9,672 13,168 1,589 1,58901.01.2024Additions 170 - 170 125 125Write-offs (164) - (164) - -Impairments - - - - -Foreign exchange 39 (64) (25) - -differenceAcquisition cost 3,541 9,608 13,149 1,714 1,71431.12.2024AMORTIZATIONAccumulated amortization (2,852) - (2,852) (1,502) (1,502)01.01.2024Amortization for the (202) - (202) (64) (64)period (note 3.5)Write-offs 164 - 164 - -Impairments - - - - -Foreign exchange (33) - (33) - -differenceAccumulated amortization (2,923) - (2,923) (1,566) (1,566)31.12.2024NET BOOK VALUE31.12.2023 644 9,672 10,316 87 8731.12.2024 618 9,608 10,226 148 148
Annual Financial Report as of 31.12.2024
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Intangible Assets Group CompanyConcessions Concessions & industrial Company Total& industrial Totalproperty goodwillproperty rightsrightsACQUISITION COSTAcquisition cost 3,267 9,720 12,987 1,589 1,58901.01.2023Additions 113 - 113 - -Transfers (note 3.11) 111 - 111 - -Impairments (10) - (10) - -Foreign exchange 15 (48) (33) - -differenceAcquisition cost 3,496 9,672 13,168 1,589 1,58931.12.2023AMORTIZATIONAccumulated amortization (2,631) - (2,631) (1,441) (1,441)01.01.2023Amortization for the (220) - (220) (61) (61)period (note 3.5)Impairments 10 - 10 - -Foreign exchange (11) - (11) - -differenceAccumulated amortization (2,852) - (2,852) (1,502) (1,502)31.12.2023NET BOOK VALUE31.12.2022 637 9,720 10,357 148 14831.12.2023 644 9,672 10,316 87 87
The Group reviews on an annual basis the
goodwill in relation to any evidence for im-
pairment according to the Group’s respec-
tive accounting principle (see note 2.6.1).
The goodwill included in the consolidated
Financial Statements, following an acquisi-
tion, has been allocated in the following
cash flow generating units (CFGU) per sub-
sidiary company in the fiscal years 2024
and 2023.
Annual Financial Report as of 31.12.2024
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Goodwill per 2024 2023SubsidiaryDon & Low LTD 7,490 7,490Trierina Trading LTD 798 798Thrace Polybulk AB 590 622Thrace Polybulk AS 648 680Thrace Nonwovens & Geosynthetics Single 50 50Person S.A.Other 32 32Total 9,608 9,672
Major Assumptions
The recoverable value of a cash flow gen-
erating unit is determined according to
the calculation of the value in use. This
calculation uses provisions of cash flows
before taxes, based on 5-year financial
budgets, which have been approved by the
Management and then extrapolated into
perpetuity.
Estimates of future sales are provided by the
Management and reflect Management’s
best estimates. Factors taken into account
are the following: historical trends, inflation,
competition, increases in production costs,
etc. Evolution of production cost, transport
cost and raw material cost is being deter-
mined by forecasts provided by interna-
tional agencies and institutions. In addition,
there is consideration of actions taken in or-
der to mitigate the interruption of the sup-
ply chain and limit the environmental foot-
print of the Group. As mentioned above,
there is no indication of any impairment in
the goodwill of the Group’s subsidiaries as
a result of the climate change or in the con-
text of the relevant legislative framework,
as in force.
The value in use for the cash flow generat-
ing units is being affected from basic fac-
tors such as the growth rate to perpetuity
which has been set at 0.5%, the projections
with regard to the forecasted quantities
and sales prices according to the 5-year in-
vestment plan of the group, the gross profit
margin and the discount rates.
The discount rates reflect the current esti-
mations of the market for the separate risks
of each cash flow generating unit. The cal-
culation of the discount rates is based on
the certain conditions in which the Group
operates along with its operating segments,
and is being extracted from the weighted
average cost of capital (WACC). The weight-
ed average cost of capital is based on both
the debt and the equity. The cost of equity
derives from the expected return required
by the Group’s investors for their invest-
ment. The cost of debt is based on the inter-
est rate of the Group’s loans that are being
repaid. The country’s risk premium is incor-
porated with the application of individual
beta sensitivity factors. Beta sensitivity fac-
tors (or beta coefficient) are being reviewed
annually according to the published market
data.
The above assumptions vary depending on
the different market conditions prevailing
in the countries which the Group operates
in. The Group uses the services of an in-
dependent specialist who adopts the Dis-
counted Cash Flow method and estimates
the companies’ value based on the future
cash flows in order to determine the value
in use.
The basic assumptions used are consistent
with independent external sources of in-
formation and are analyzed below per cash
flow generating unit (CFGU).
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 330 of 370
Contents
Assumptions – Don & Low LTD 2024 2023Discount rate, weighted average9.7% 8.8%Annual revenue growth rate 8.9% 14%Earnings before interest, taxes, depreciation and 8.3%10.5%–13.5%amortization (5-years)Assumptions – Trierina Trading LTD / Thrace Ipoma A.D.Discount rate, weighted average8.7% 8.2%Annual revenue growth rate 9.6% 9.8%Earnings before interest, taxes, depreciation and 21.3% 21%amortization (5-years)Assumptions – Thrace Polybulk ASDiscount rate, weighted average8.2% 7.6%Annual revenue growth rate 6.4% 7%Earnings before interest, taxes, depreciation and 12.9% 15% - 16%amortization (5-years)Assumptions – Thrace Polybulk ABDiscount rate, weighted average6.7% 6.7%Annual revenue growth rate 9.3% 7.7%Earnings before interest, taxes, depreciation and 6.2% 7% - 7.6%amortization (5-years)
Based on the results of the impairment
testing, as of December 31, 2024, no im-
pairment losses emerged in the book val-
ue of the goodwill of the above cash flow
generating units.
On December 31, 2024, the recoverable
amount for the specific cash flow gener-
ating units compared to the correspond-
ing book values, indicates that there is a
significant headroom and any substantial
change in the assumptions used would
not result in an impairment in the book
value of goodwill.
The Group analyzed the sensitivity of the
recoverable amounts of each Cash Flow
Generating Unit (CFGU) in relation to a ra-
tional and probable change in one of the
major assumptions (as an indication it is
noted the best case scenario which refers
to 5% sales growth and 2% increase of
gross profit, as well as the worst case sce-
nario which refers to the corresponding
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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Contents
3.14 Other Long-Term Receivables
opposite and unfavorable changes). In ad-
dition, sensitivity is calculated according to
a 0.5% change in the growth rate in perpe-
tuity and according to a 2% change in the
discount rate. As a result of the sensitivity
analysis, the recoverable amount for the
above cash flow generating units (CFGU)
compared to their respective book value,
indicates a sufficient headroom.
Other Long-Term Receivables are presented in the table below:
Group CompanyOther Long-Term Receivables2024 2023 2024 2023Guarantees granted and other 158 138 35 42receivablesTotal 158 138 35 42
3.15 Inventories
Group CompanyInventories2024 2023 2024 2023Merchandise 9,440 8,096 - -Finished and semi-finished 34,985 31,609 - -productsRaw & auxiliary materials 41,733 33,670 - -Spare parts – other inventory 1,608 1,462 - -Provision for impairment of (2,661) (2,834) - -inventoryTotal 85,105 72,003 - -
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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3.16 Trade and other receivables
3.16.1 Trade Receivables
Group CompanyTrade Receivables2024 2023 2024 2023Trade receivables 79,893 69,631 2,806 2,818Provisions for impairment of (6,742) (7, 452) (2,307) (2,307)receivablesTotal 73,151 62,179 499 511
Provision for Impairment of Inventory Group CompanyOpening Balance 1.1.2023 2.703 -Additional provisions 338 -Utilized provision (250)Foreign Exchange Differences 43 -Total 31.12.2023 2,834 -Additional provisions 263 -Utilized provision (546) -Foreign Exchange Differences 110 -Total 31.12.2024 2,661 -
The balance of trade receivables at the
Group level included notes and checks
overdue of € 7,523 for the year 2024 and of €
7,149 for the year 2023. The increase in trade
receivables as at 31 December 2024 is main-
ly attributable to the increase in sales vol-
ume during the last two months of the year,
compared to the last two months of 2023,
when the sales volume was lower, and the
related balances as at 31 December 2024
are primarily current. It is also noted that
the average days sales outstanding (DSO)
remains at 67 days in both 2024 and 2023.
Receivables from related parties of the
Group and the Company are disclosed in
note 3.26 of the financial statements
It is noted that, according to the European
and national legislation in effect, there are
no product categories subject to any re-
strictions, with regard to their usage and
distribution in the market place, due to
their impact on the environment, currently
or in a future time. As a result, no require-
ment for impairment has emerged.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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Classification of trade receivables
Receivables from customers consist of
the amounts due from customers from
the sale of products that occur within the
normal operation of the Group. In general,
credit terms range from 30 to 180 days and
therefore trade receivables are classified
as short-term. Receivables from customers
are initially recognized in the transaction
amount if the Group has the unconditional
right to receive the transaction price. The
Group holds the receivables from custom-
ers in order to collect the contractual cash
flows and therefore measures them at am-
ortized cost using the effective interest
rate method.
The dispersion of the Group’s sales
is deemed satisfactory. There is no
concentration of sales on a limited num-
ber of customers and therefore there is no
increased risk of income loss or increased
credit risk.
Fair value of trade receivables
Given their short-term nature, the fair
value of receivables approximates book
value.
Impairment of trade receivables
For the accounting policy on impairment
of trade receivables, see note 2.16.3.
Information regarding the maturity analy-
sis of trade receivables is presented in the
tables below.
Maturity of trade receivables’ balances 31.12.2024 Group Company01 – 30 days 23,348 631 – 90 days 39,765 -91 – 180 days 9,604 493Above 180 days 7,176 2,307Subtotal 79,893 2,806Provisions for doubtful receivables (6,742) (2,307)Total 73,151 499
The analysis of provisions is depicted in the following table:
Percentage of Expected credit Analysis of provisions - Groupexpected credit losseslosses01 – 30 days 5 0.02%31 – 90 days 12 0.03%91 – 180 days 307 3.20%Above 180 days 6,418 89.44%Total 6,742
Annual Financial Report as of 31.12.2024
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Percentage of Analysis of provisions Expected credit expected credit - Companylosseslosses01 – 30 days - -31 – 90 days - -91 – 180 days - -Above 180 days 2,307 100%Total 2,307
The analysis of the balances of the not past due and overdue trade receivables as of
31.12.2024 is presented in the table below:
Analysis of not past due and overdue trade Group Companyreceivables 31.12.2024Receivables not due 57,146 6Overdue receivables 1 – 30 days 10,978 -Overdue receivables 31 – 90 days 3,290 493Overdue receivables above 91 days 8,479 2,307Subtotal 79,893 2,806Provisions for impairment of receivables (6,742) (2,307)Total 73,151 499
With regard to uninsured receivables over-
due more than 90 days, which the Group
has classified as doubtful, relevant provi-
sions have been made which are deemed
sufficient.
Correspondingly, the maturity of receiva-
bles and past due for the financial year
2023 are presented in the following tables:
Maturity of trade receivables’ balances 31.12.2023 Group Company01 – 30 days 18,385 1831 – 90 days 35,046 48891 – 180 days 8,876 -Above 180 days 7, 324 2,312Subtotal 69,631 2,818Provisions for doubtful receivables (7,452) (2,307)Total 62,179 511
Annual Financial Report as of 31.12.2024
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Percentage of Expected credit Analysis of provisions - Groupexpected credit losseslosses01 – 30 days 3 0.02 %31 – 90 days 78 0.22 %91 – 180 days 377 4.25 %Above 180 days 6,994 95.49 %Total 7,452
Percentage of Analysis of provisions Expected credit expected credit - Companylosseslosses01 – 30 days - -31 – 90 days - -91 – 180 days - -Above 180 days 2,307 99.78%Total 2,307
Analysis of not past due and overdue trade Group Companyreceivables 31.12.2023Receivables not due 46,545 505Overdue receivables 1 – 30 days 11,856 -Overdue receivables 31 – 90 days 3,765 -Overdue receivables above 91 days 7,4 65 2,313Subtotal 69,631 2,818Provisions for doubtful customer receivables (7,452) (2,307)Total 62,179 511
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3.16.2 Other receivables
Group CompanyOther receivables2024 2023 2024 2023Debtors 1,781 1,418 13 22Investment Grants Receivable 937 987 - -Time Deposits at Bank - 13,269 - -V.A.T and Other Taxes receivables 1,324 577 111 68other than Income TaxPrepaid expenses 2,830 2,272 302 100Interim dividend - Dividends (note 294 3,000 - 3,0003.25, 3.26)Total 7,166 21,523 426 3,190
The receivable from sundry debtors is pre-
sented net of an impairment provision of €
164 as at 31.12.2024 (31.12.2023: € 17). The
provision for the year 2024 of € 160 along
with the unutilized provision of € 13 have
been recorded in the other expenses and
other income in the statement of compre-
hensive income (notes 3.3, 3.7).
The investment grant receivable concerns
a grant receivable of Law 3299/2004 of the
subsidiary company Thrace Plastics Pack
SA concerning an implemented invest-
ment and is likely to be collected in the
year 2025.
In the current fiscal year there were no
time deposits, whereas on 31.12.2023 an
amount of € 13,269 had been included in
the time deposits. The amount concerned
a bank time deposit with a duration great-
er than 3 months and as a result had not
been included in the cash and cash equiva-
lents (note 3.17).
3.16.3 Analysis of Provisions for impairment of trade receivables
Analysis of Provisions for Doubtful Receivables Group CompanyOpening balance 1.1.2023 7,690 2,307Additional Provisions (note 3.7) 70 -Unutilized provision (note 3.3) (255) -Utilized provision (52) -Foreign Exchange Differences (1) -Total 31.12.2023 7,452 2,307
Annual Financial Report as of 31.12.2024
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3.17 Cash & cash equivalents
Group CompanyCash & cash equivalents2024 2023 2024 2023Cash in hand 19 17 5 4Current and time deposits (less than 33,437 27,78 4 344 2383 months)Total 33,456 27,801 349 242
Opening balance 1.1.2024 7, 452 2,307Additional Provisions (note 3.7) 224 -Unutilized provision (note 3.3) (676) -Utilized provision (270) -Foreign Exchange Differences 12 -Total 31.12.2024 6,742 2,307
In the fiscal year 2023, Cash and Cash
Equivalents did not include an amount
of € 13,269 that concerned time deposits
which had been formed during the previ-
ous financial year with a duration of more
than three months. The relevant amount
had been reclassified to “other receiva-
bles” (note 3.16.2).
Credit rating of cash & cash
equivalents
The Group’s cash and cash equivalents are
held by 21% in Greek systemic banks with-
in the Greek territory and 79% in foreign
banks. The Group’s Management consid-
ers that there are currently no significant
risks to the security of the aforementioned
deposits, taking into account the credit-
worthiness of the banks.
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Below, cash & cash equivalents are categorized according to the credit rating of banks
(conducted by Fitch) where the relevant deposits are placed.
Group CompanyCredit rating of cash & cash equivalents2024 2023 2024 2023AA- 455 1,023--Α+ 17, 476 3,487--Α 6,765 9,632--A- 3,341 4,532--Β- - --ΒΒ- - 4,861-109BBB+ - 2,444--ΒΒ+ 1,876 -149-B - ---BΒ 3,524 1,805195129Total 33,437 27,78 4 344 238
3.18 Share Capital and Share Premium Reserve
The Company’s share capital accounted for
28,869,358.32 Euro (absolute number) on
31 December 2024 divided by 43,741,452
common registered shares with nominal
value of 0.66 Euro per share.
The treasury shares that the Company
holds are presented below. The value of
treasury shares is recorded as negative re-
serve in the Statement of Changes in Eq-
uity and is being offset against the Other
Reserves of the Group and the Company in
the Statement of Financial Position.
Treasury Shares Quantity Value (In Th. €)Opening Balance 802,049 3,548Acquired during the year 61,747 243Ending Balance 863,796 3,791
The Company’s share premium reserve
amounted to € 21,644 (31.12.2023: € 21,644)
and comprises the difference between the
issuance value of shares and their nominal
value.
The Group’s share premium reserve
amounted to € 21,524 (31.12.2023: € 21,524).
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The Company’s other reserves amounted
to € 12,923 (31.12.2023: € 12,613) include
the statutory reserve, the tax-exempt
reserves of incentive law as well as the
negative reserve in relation to the treas-
ury shares. The change in fiscal year 2024
emerged from the formation of a statutory
reserve of € 553 (31.12.2023: € 559) and an
increase in the negative reserve in relation
to the treasury shares amounting to € 243
(2023: € 237) due to a purchase of shares
during the fiscal year 2024.
The Group’s other reserves amounted to
€ 27,721 (31.12.2023: € 23,053) include the
statutory reserve of the Parent Company
and the Group’s Greek subsidiaries, the
tax-exempt reserves of incentive law of
Greek companies, reserves of foreign sub-
sidiaries formed in accordance with the
legislation of the respective countries as
well as the negative reserve in relation to
the treasury shares of the Parent Company
(note 3.18). The change in fiscal year 2024
emerged from the formation of a statu-
tory reserve of € 926 (31.12.2023: € 957), a
change in the foreign exchange reserves
through other comprehensive income of €
3,986 (2023: € 1,035) and an increase in the
negative reserve in relation to the treasury
shares amounting to € 243 (2023: € 237)
due to a purchase of shares during the fis-
cal year 2024 (note 3.18).
3.19 Other Reserves
3.19.1 Statutory Reserves
In accordance with the provisions of
Greek Law, the creation of a statutory re-
serve – by transferring to such a reserve
an amount equal to 5% of the annual after
tax profits realized – is mandatory until the
time when the reserve balance amount
to the 1/3 of the Company’s paid in share
capital. During the lifetime of the Com-
pany, the distribution of the statutory re-
serve is prohibited. The statutory reserve
can be distributed only upon the dissolu-
tion of the Company. However, it can be
used to offset accumulated losses. The
Statement of Equity of the Group and the
Company includes each year the amount
of the statutory reserve approved by the
Ordinary General Meeting of Shareholders
of each company. For the year 2024, based
on the relevant calculations, the amount
of the statutory reserve to be approved
by the Ordinary General Meeting of Share-
holders in the year 2025 amounts to € 830
and € 417 for the Group and the Company
respectively.
It concerns reserves related to a tax law
that have been formed in accordance with
the provisions of tax legislation, which ei-
ther provide the possibility of deferring
the taxation of certain income at the time
of their distribution towards the share-
holders, or provide a tax relief as incentive
to implement investments. Based on the
Greek tax legislation, these reserves are
tax-exempt, provided that they are not
distributed to the shareholders. In case of
distribution, they will be taxed at the cor-
responding tax rate applicable in the pe-
riod of their distribution.
3.19.2 Tax-exempt and Other Reserves
Annual Financial Report as of 31.12.2024
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3.20 Bank Debt
The Group’s long term loans have been
granted from Greek and international
banks. The repayment time varies, accord-
ing to the loan contract, while most loans
are linked to Euribor plus a spread.
The Group’s short term loans have been
granted from Greek and international
banks with interest rates, mainly Euribor
or Libor, plus a spread. The book value of
loans approaches their fair value at 31 De-
cember 2024.
Analytically, bank debt at the end of the
fiscal year was as follows:
Group CompanyDebt2024 2023 2024 2023Long-term debt33,248 27,790 - -Total long-term debt33,248 27,79 0 - -Short term portion of long term debt8,466 14,323 - -Short-term debt23,265 12,232 - -Total short-term debt31,731 26,555 - -Grand Total 64,979 54,345 - -
The Group proceeded in 2024 in signing
new loan agreements and collected a total
amount of €25,737, mainly for partially fi-
nancing investments in tangible assets but
also for the repayment of existing loans, at-
taining a reduction in interest rates by tak-
ing advantage of more favorable lending
terms.
The Group proceeded in 2023 in signing
loan agreement within the framework of
the National Recovery and Resiliency Plan
“Greece 2.0”, in order to partially cover its
capital needs for financing its CAPEX re-
garding the construction of “net metering”
photovoltaic systems. As a loan that is un-
der the framework of co-financing of the
systemic banks with the Recovery and Re-
silience Fund (RRF), a total amount of ap-
proximately € 4,800 was approved and as
of 31.12.2023 an amount of approximately
€ 4,040 was granted. In addition, the Group
had collected new loans totaling €5,135
million.
The Group recognized an indirect grant,
amounting to € 510, as it was calculated
from the difference between the contractu-
al co-financing rate and the RRF rate, while
on 31.12.2024 the balance of the liability
3.19.3 Foreign exchange difference reserves
These reserves are formed as a result of the
conversion into EUR of the Assets, Liabili-
ties and net income of international sub-
sidiaries with different operating currency
for each of them, based on the exchange
rate according to the accounting policies
of the Group (note 2.10.3).
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Group CompanyDebt Maturity2024 2023 2024 2023Up to 1 year31,731 26,555 - -From 1 – 5 years32,755 26,755 - -Over 5 years 493 1,036 - -Total Debt 64,979 54,346 - -
Interest rates are linked to Euribor or Libor
on a per case basis plus a spread that rang-
es from 1.20% to 2.75%.
Part of the Group’s long-term loans
amounting to € 31,276 are linked to the ful-
filment of certain financial ratios related to
EBITDA, net debt and equity (covenants),
calculated on the Group level at the end of
each fiscal year until the repayment of the
loans. As of December 31, 2024 and 2023
the above indicators were fully covered.
Group CompanyEmployee Benefits2024 2023 2024 2023Defined benefit plans – Unfunded1,907 1,658 121 99Defined benefit plans – Funded(5,980) (9,533) - -Total provision at the end of the year (4,073) (7,875) 121 99
3.21 Pension Liabilities
The liabilities of the Company and the
Group towards its employees in providing
them with certain future benefits, depend-
ing on the length of service are calculated
by an actuarial study on an annual basis,
utilizing the projected unit credit method.
The accounting treatment is made on the
basis of the accrued entitlement of each
employee, at the date of the financial
statements, that is anticipated to be paid,
discounted to its present value by refer-
ence to the anticipated time of payment.
The liability / (benefit) for the Company
and the Group, as depicted in the State-
ment of Financial Position, is analyzed as
follows:
amounted to € 392 (31.12.2023: € 459) and
is depicted in the other long-term liabilities.
In addition, short-term loans include an
amount of € 7,168 which relates to a Factor-
ing arrangement of Thrace Plastics Pack SA
with ABC Factors, which has been received
by the aforementioned subsidiary and
corresponds to receivables factored with
recourse.
The maturity of the loans is as follows:
Annual Financial Report as of 31.12.2024
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Contents
3.21.1 Defined benefit plans – Unfunded
The Greek companies of the Group as well as the subsidiary Thrace Ipoma A.D. domiciled
in Bulgaria participate in the following plan.
Group CompanyDefined benefit plans – Unfunded2024 2023 2024 2023Amounts recognized in the balance sheetPresent value of liabilities 1,907 1,658 121 99Net liability recognized in the balance 1,907 1,658 121 99sheetAmounts recognized in the financial resultsCost of current employment 223 193 16 14Net interest on the liability 66 47 4 2Ordinary expense in the Statement of 289 240 20 16Comprehensive IncomeRecognition of prior service cost 22 - 3 -Cost of curtailment / settlements / service 227 307 12 -terminationTotal expense in the Statement of 538 547 35 16Comprehensive IncomeChange in the present value of the liabilityPresent value of liability at the beginning 1,658 1,385 99 79of periodCost of current employment 22319316 14Interest cost 66 47 4 2Benefits paid from the employer (301) (366) (12) -Cost of curtailment / settlements / service 227 306 12 -terminationOther expense / (income) - 1 - -Cost of prior service during the period 22 - 3 -Actuarial loss / (profit) – financial assumptions (42) 61 - -Actuarial loss / (profit) – demographic 3 - - -assumptionsActuarial loss / (profit) – evidence from the 51 31 (1) 4periodPresent value of liability at the end of 1,907 1,658 121 99period
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Group CompanyDefined benefit plans – Unfunded2024 2023 2024 2023AdjustmentsAdjustments profit / (loss) in the liabilities due to 28 (67) 1 (4)change of assumptions Empirical adjustments profit / (loss) in (40) (25) - -liabilities Total actuarial profit / (loss) in other (12) (92) 1 (4)incomeChanges in the Net Liability recognized in the Statement of Financial Position Net liability at the beginning of year 1,658 1,385 99 79Benefits paid from the employer - Other (301)(366)(12) -Total expense recognized in the Statement of 538 547 35 16Comprehensive IncomeTotal amount recognized in other income 12 92 (1) 4Net liability at the end of year 1,907 1,658 121 99
The actuarial assumptions are presented in the following table.
Greek Companies Thrace Ipoma ADActuarial Assumptions2024 2023 2024 20232.93% 3.97% 4.00% 4.5%Discount rateInflation2.20% 2.40% 2.20% 4.7%Average annual increase of personnel 2.20% 3.40% 10% 12%salariesDuration of liabilities4.5 years 4.9 years 8.1 years 8.9 years
3.21.2 Defined benefit plans – Funded
It is noted that a change of 0.5% in the
discount rate would result in a change in
the present value of liabilities by 2.8% ap-
proximately, while a change of 0.5% in the
average annual increase of personnel sala-
ries would lead to a change in the present
value of liabilities by 2.5% approximately.
The subsidiaries Don & Low LTD and Thrace
Polybulk AS have formed Pension Plans of
defined benefits which operate as stand-
alone legal entities in the form of trusts.
Therefore the assets of the plans are not re-
lated to the assets of the companies.
The accounting treatment of the plans ac-
cording to the revised IAS 19 is as follows:
Annual Financial Report as of 31.12.2024
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GroupDefined benefit plans – Funded2024 2023Amounts recognized in the Statement of Financial PositionPresent value of liabilities 101,405 103,792Fair value of the plan’s assets (107,385)(113, 325)Net (benefit) / liability recognized in the Statement of (5,980) (9,533)Financial PositionAmounts recognized in the financial resultsCost of current employment 65 90Net interest on the liability / (asset) (473) (344)Ordinary expense in the Statement of Comprehensive (408) (254)IncomeOther expense / (income) 709 575Total expense in the Statement of Comprehensive Income 301 321Change in the present value of the liabilityPresent value of liability at the beginning of period 103,792 102,648Cost of current employment 65 87Interest cost 5,002 5,097Benefits paid from the plan (5,341) (5,403)Other expense / (income) (6) (20)Actuarial loss / (profit) – financial assumptions (6,851) 1,839Actuarial loss / (profit) – demographic assumptions (118) (2,299)Actuarial loss / (profit) – evidence from the period 148 (141)Foreign exchange differences 4,714 1,984Present value of liability at the end of period 101,405 103,792Change in the value of assetsPresent value of the plan’s assets at the beginning of period 113, 325 109,817Income from interest 5,475 5,441Return on assets (11,6 61) 739Employer’s contributions 505 604Benefits paid from the plan (5,341) (5,403)Foreign exchange differences 5,082 2,127Present value of assets at the end of period 107,385 113,325
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GroupDefined benefit plans – Funded2024 2023AdjustmentsAdjustments profit / (loss) in the liabilities due to change of 6,820 601assumptionsEmpirical adjustments profit / (loss) in assets (10,936) 1,445Total actuarial profit / (loss) in Equity (4,116) 2,046Cost recognition from previous years (23) -Total amount recognized in Equity (4,139) 2,046Asset allocation*Mutual Funds (Equities) 11, 337 14,046Mutual Funds (Bonds) 72,692 79,762Diversified Growth Funds 14,357 13,997Other 8,999 5,520Total 107,385 113, 325Changes in the Net Liability recognized in Statement of Financial PositionNet liability / (receivable) at the beginning of year (9,533) (7,169)Contributions from the employer / Other (518) (495)Total expense recognized in the Statement of Comprehensive 301 321IncomeTotal amount recognized in other income 4,139 (2,046)Foreign exchange differences (369) (144)Net liability / (asset) at the end of year (5,980) (9,533)
* The assets of the plan are measured at fair values and include mainly mutual funds of Baillie
Gifford, Legal & General Investment Management as well as Ninety One plc.
The category “Other” also includes the plan’s cash reserves.
The actuarial assumptions are presented in the following table.
Don & Low LTD Thrace Polybulk ASActuarial Assumptions2024 2023 2024 2023Discount rate5.54% 4.80% 3.90% 3.10%Inflation3.12% 3.02% 2.40% 2.25%Average annual increase of 3.12% 3.02% 4.00% 3.50%personnel salariesDuration of liabilities13 years 14 years 10 years 10 years
Annual Financial Report as of 31.12.2024
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3.22 Deferred Taxes
GROUP
It is noted that a change of 0.50% in the
discount rate would have resulted in a
change in the present value of liabilities by
5%.
It is noted that the High Court of England
has issued a judgment concerning the
case of Virgin Media v NTL Pension Trus-
tees Limited, challenging the validity of
certain rule amendments made to defined
benefit pension schemes concluded be-
tween 6 April 1997 and 5 April 2016. Cer-
tain amendments made during the above
period required confirmation by the ac-
tuary of the defined benefit scheme that
the conditions of “Reference Scheme Test”
would continue to be met. In the absence
of such confirmation, the amendment
to the scheme rules could be considered
invalid. The above judgment could have
broader implications for many UK pension
schemes and was the subject of an appeal,
which however upheld the original High
Court decision on 25 July 2024.
The funded defined benefit plan of the
subsidiary Don & Low LTD (the “Plan”) had
been concluded during the above period
and is governed by the Law of Scotland.
Following the completion of the appeal,
in accordance with a recent legal advice
provided to the management of the sub-
sidiary, the subsidiary and the administra-
tors of the funded defined benefit plan, to-
gether with expert advisors, are reviewing
the law, however a full assessment had not
been completed at the date of approval of
the financial statements. The administra-
tors of the defined benefit plan are aware
of the matter and are considering any po-
tential impact on the obligations of the
Plan. However, to date, given the ongoing
legal and regulatory uncertainty, any po-
tential impact on the Plan’s liabilities has
not yet been quantified and no additional
provision has been made for the year end-
ed on 31 December 2024.
The following amounts are recorded in the consolidated Statement of Financial
Position, after any offsetting entries wherever required:
Deferred Taxation 2024 2023Deferred tax assets 815 326Deferred tax liabilities (5,507) (7,910)Total deferred taxation (4,692) (7,584)
Annual Financial Report as of 31.12.2024
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Α. Change of deferred tax 2024 2023stAs at January 1 (7,584) (9,303)Change in the Statement of Comprehensive 2,168 2,416Income (note 3.10)Change in the Statement of Other Comprehensive 982 (535)IncomeForeign exchange differences (258) (162)stAs at December 31(4,692) (7,584)
Liabilities for Β. Deferred tax (liabilities)Amortization Other Totalemployee benefitsstAs at January 1, 2023 (1,354) (8,946) (325) (10,625)Change in the Statement of 42 1,127 1,246 2,415Comprehensive Income Change in Statement of Other Comprehensive (983) 1 - (982)IncomeForeign exchange (64) (144) 33 (175)differencesstAs at December 31, 2023 (2,359) (7,962) 954 (9,367)Change in the Statement of - 1,943 75 2,018Comprehensive Income Change in Statement of Other Comprehensive 974 - 402 1,376IncomeForeign exchange (93) (253) 80 (266)differencesstAs at December 31, 2024 (1,478) (6,272) 1,511 (6,239)
Liabilities for C. Deferred tax assetsAmortizationOther Totalemployee benefitsstAs at January 1, 2023 - 892 430 1,322Change in the Statement of 4 10 (12) 2Comprehensive IncomeChange in Statement of Other 447 - - 447Comprehensive IncomeForeign exchange differences 23 - (11) 12
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stAs at December 31, 2023 474 902 407 1,783Change in the Statement of 54 (167) 264 151Comprehensive IncomeChange in Statement of Other 8 - (402) (394)Comprehensive IncomeForeign exchange differences (4) - 11 7stAs at December 31, 2024 532 735 280 1,547
COMPANY
Α. Change of deferred tax 2024 2023stAs at January 1126 120Change in the Statement of Comprehensive 267 5Income (note 3.10)Change in Statement of Other Comprehensive - 1IncomestAs at December 31393 126
Liabilities for C. Deferred tax assetsemployee ProvisionsOther TotalbenefitsstAs at January 1, 2023 18 104 (2) 120Change in the Statement of 2 3 - 5Comprehensive IncomeChange in Statement of Other Comprehensive 1 - - 1IncomestAs at December 31, 2023 21 107 (2) 126Change in the Statement of 5 65 197 267Comprehensive IncomeChange in Statement of Other Comprehensive - - - -IncomestAs at December 31, 2024 26 172 195 393
In the Statement of Financial Position of
each Company, deferred tax assets and
liabilities are offset, while in the specific
table deferred tax assets and liabilities are
presented in detail. Therefore, any recon-
ciliation is made in the change between
assets and liabilities.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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Trade and Other Short-Term Liabilities of the Group and the Company are presented ana-
lytically in the following tables:
3.23.1 Trade Liabilities
Group CompanyTrade Liabilities2024 2023 2024 2023Suppliers55,500 38,462 619 364Total 55,500 38,462 619 364
Liabilities to related parties of the Group and the Company are disclosed in note 3.26 of
the financial statements.
3.23 Trade and Other Short-Term Liabilities
3.23.2 Other Short-Term Liabilities
Group CompanyOther Short-Term Liabilities2024 2023 2024 2023Sundry creditors5,255 4,504 14 17Liabilities from taxes and pensions 4,879 4,363 226 357Dividends payable (note 3.25) 3,139 139 3,139 139Liabilities from contracts with customers 1,791 1,387 - -Personnel salaries payable 1,639 1,360 63 65Accrued expenses – Other accounts payable10,237 9,625 597 687Total short-term liabilities 26,940 21,378 4,039 1,265
The fair value of the liabilities approaches
the book value.
Liabilities from contracts with customers
concern contractual liabilities of the Group
for the performance of the contractual
agreements and the transfer of goods and/
or services. The Group expects that the to-
tal advances will be recognized as revenue
in the financial year 2025, while the liabili-
ties from contracts dated 31.12.2023 were
recognized in the current year’s income.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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3.24 Financial Derivative Products
The Group enters into foreign exchange
futures -purchase and sale- contracts, to
cover the exchange risk from collection of
receivables and payments in foreign cur-
rency towards suppliers. These contracts
have different expiration dates, depending
on the date of each expected collection or
payment. The valuation of the Company’s
open position as of 31st December 2024
and 2023 is as follows:
Valuation Pre-purchase Pre-purchase / 2024Open Current Value / (Pre-sale) (Pre-sale) Value BalancePosition(in €)CurrencyAmount (in $)(in €)31.12.2024USD Sale 2,800 2,554 2,680 (126)Valuation Pre-purchase Pre-purchase / 2023Open Current Value / (Pre-sale) (Pre-sale) Value BalancePosition(in €)CurrencyAmount (in $)(in €)31.12.2023USD Sale 5,900 5,416 5,339 77
3.25 Dividend
3.25.1 Dividend
By the decision of 22 April 2024, the Board
of Directors of the Company unanimously
decided to propose to the Annual General
Meeting of Shareholders the allocation
(distribution) of the results of the financial
year ended on 31.12.2023 and in particular
the distribution (payment) to the share-
holders of the Company of a total dividend
amounting to 10,250,000.00 Euros (gross
amount), i.e. 0.2343314986 Euros per share
(gross amount) from the earnings of the
financial year 2023 (01.01.2023-31.12.2023)
as well as from the earnings of previous
years.
Given that the Company, pursuant to the
decision of the Board of Directors dated
25 September 2023, has already distrib-
uted (paid) to the shareholders an in-
terim dividend for the financial year 2023
amounting to 3,000,000.00 Euros (gross
amount), i.e. 0.0685848289 Euros per share
(gross amount), the Board of Directors sub-
sequently proposed to the Annual General
Meeting of Shareholders the distribution
of the balance of the dividend, and specifi-
cally of an amount of 7,250,000.00 Euros
(gross amount), i.e. 0.1657466698 Euros per
share (gross amount). The above amount
will be increased by the amount corre-
sponding to the treasury shares that the
Company held at the dividend cut-off date
and which (treasury shares) are excluded
from the distribution, according to the
provisions of article 50 of Law 4548/2018,
as in force.
Correspondingly, it is noted that the An-
nual Ordinary General Meeting of Share-
holders, that took place on May 24th
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
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Contents
2023, approved unanimously the distribu-
tion (payment) of dividend to Company’s
Shareholders, from the profits of the fiscal
year 2022 (01.01.2022-31.12.2022), and in
particular, approved the payment of the
total amount of 11.300.000.00 Euro (gross
amount), i.e. 0.2583361887 Euros per share
(gross amount).
It is noted that the Company had already
made the allocation (distribution) to the
shareholders of an interim dividend for
the fiscal year 2022, on February 3rd, 2023
(pursuant to a respective BoD decision),
of a total amount of 3,000,000.00 Euros
(gross amount), i.e. 0.0685848289 Euros
per share (gross amount), which with the
corresponding increase of the 751,396
treasury shares, which were held by the
Company and were excluded by law from
the interim dividend distribution, amount-
ed to 0.0697835797 Euros per share (gross
amount).
Following the above, the remaining
amount of the dividend was 8,300,000.00
Euros (gross amount), from the profits of
the fiscal year 2022 (01.01.2022-31.12.2022),
i.e. 0.1897513599 Euros per share (gross
amount), which after the increase corre-
sponding to 751,396 treasury (own) shares,
which were held by the Company and
were excluded from the dividend distribu-
tion, amounted to 0.1930679039 Euro per
share (gross amount).
The Company informed the investor com-
munity that the 5-year period for the col-
lection of dividend for the fiscal year 2018
expired on 31.12.2024. After the above
date, the dividends not collected by the
eligible shareholders were written off in fa-
vor of the Greek State, in accordance with
the applicable legislation.
3.25.2 Interim Dividend
The Board of Directors of the Company,
during its meeting of November 14th,
2024 approved the distribution (payment)
of an interim dividend for fiscal year 2024
to the shareholders of the Company, of a
total amount of 3,000,000.00 Euros (gross
amount), corresponding to 0.0685848289
Euros per share (gross amount) (note3.23.2).
Correspondingly it is noted that the
Board of Directors of the Company, dur-
ing its meeting of September 25th, 2023
approved the distribution (payment) of
an interim dividend for fiscal year 2023
to the shareholders of the Company, of a
total amount of 3,000,000.00 Euros (gross
amount), corresponding to 0.0685848289
Euros per share (gross amount), which with
the increase corresponding to the 798,549
treasury shares, which were held by the
Company and in accordance with the law
are excluded from the interim dividend
distribution, amounted to 0.0698602048
Euros per share.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 352 of 370
Contents
3.26 Transactions with Related Parties
Group CompanyIncome01.01 01.01 01.01 01.01 – 31.12.2024- 31.12.2023– 31.12.2024- 31.12.2023Subsidiaries -- 5,796 5,836Joint Ventures* 5,1814,747 93 98Affiliated Companies 80182 - -Total 5,261 4,929 5,889 5,934
* The Group’s revenues from joint ventures mainly refer to sales of products.
Group CompanyExpenses01.01 01.01 01.01 01.01 – 31.12.2024- 31.12.2023– 31.12.2024- 31.12.2023Subsidiaries- - 98 115Joint Ventures*979 791 - -Affiliated Companies1,243 952 510 467Total 2,222 1,743 608 582
Group CompanyTrade and other receivables31.12.2024 31.12.2023 31.12.2024 31.12.2023Subsidiaries- - 499 499Joint Ventures*954 1,276 - 6Affiliated Companies54 38 29 26Total1,008 1,314 528 531
The Group classifies as related parties the
members of the Board of Directors, the di
-
rectors of the Companies divisions as well
as the shareholders who own over 5% of
the Company’s share capital (their related
parties included).
The commercial transactions of the Group
with these related parties as well as with
the joint ventures during the fiscal year
01.01.2024 – 31.12.2024 have been con
-
ducted on an arm’s length basis and in the
context of the ordinary business activities.
The transactions with the Subsidiaries,
Joint Ventures and affiliates according to
the IFRS 24 during the fiscal year 01.01.2024
– 31.12.2024 are presented below.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 353 of 370
Contents
Group CompanySuppliers and Other Liabilities31.12.2024 31.12.2023 31.12.2024 31.12.2023Subsidiaries - - 14 17Joint Ventures* 50 59 - 3Affiliated Companies50 125 33 33Total 100 184 47 53
Group CompanyLong-term Liabilities31.12.2024 31.12.2023 31.12.2024 31.12.2023Subsidiaries - - 277 280Joint Ventures* - - - -Affiliated Companies- - - -Total - - 277 280
It is noted that the Parent Company recog-
nized in the statement of comprehensive
income for the fiscal year 2024 dividends
from subsidiaries amounting to € 9,073
(31.12.2023: € 12,029) (note 3.8). The Group
also paid dividends to non-controlling in-
terests amounting to € 235 (31.12.2023: €
268), while it has recorded a receivable of
€ 294 (31.12.2023: - ) concerning dividends
to be collected from an affiliated company
during the fiscal year 2025 (note 3.16.2).
The Group’s “subsidiaries” include all com-
panies consolidated under “Thrace Plastics
Group” with the full consolidation method.
The “Joint Ventures” include those consoli-
dated with the equity method.
The Company has granted guarantees to
banks against long-term debt of its sub-
sidiaries. On 31.12.2024 και 31.12.2023 the
outstanding amount for which the Com-
pany had provided guarantee settled at
€ 53,283 and € 42,187 respectively and is
analyzed as follows:
Guarantees for Subsidiaries 2024 2023Thrace Nonwovens & Geosynthetics Single Person 23,405 19,262S.A.Thrace Plastics Pack SA 23,887 18,425Thrace Polyfilms Single Person S.A. 5,991 4,500Total 53,283 42,187
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 354 of 370
Contents
Group CompanyBoD Fees2024 2023 2024 2023BoD Fees 4,340 4,436 1,628 1,571
3.27 Remuneration of Board of Directors
3.28 Investments
3.28.1 Investments in companies consolidated with the full consolidation
method
The remuneration concerns the Boards
of Directors of 18 companies in which 30
members participate and include salaries
of the executive members of the Boards
of Directors, other remuneration and ben-
efits of both the executive and the non-
executive directors. These expenses are
included in the administration expenses.
The value of the Company’s investments in the subsidiaries, as of 31st December 2024
and 2023, is as follows:
Companies consolidated with the full 2024 2023consolidation methodDon & Low LTD 37,495 37,495Thrace Plastics Pack SA 15,507 15,507Thrace Nonwovens & Geosynthetics Single Person SA 5,710 5,710Synthetic Holdings LTD 11,728 11,728Thrace Polyfilms Single Person SA 3,418 3,418Total 73,858 73,858
In the year 2024, the Management of the
Group assessed the existence of impair-
ment indications regarding the Parent
Company’s investments in subsidiaries
and whether there is any impairment of
the recognized goodwill by carrying out
the procedures as described in note 2.6.
Based on the assessment carried out, it
emerged that there were indications of
impairment in only one subsidiary compa-
ny. In this context, an impairment test was
performed on the investment and good-
will corresponding to this subsidiary. The
test revealed that the recoverable value of
the investment is greater than its account-
ing value and therefore no provision for
impairment of the investment and good-
will was recognized.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 355 of 370
Contents
Non-controlling interests amounted to €
4,810 as at 31.12.2024 (31.12.2023: € 4,404)
and concerned solely the percentage held
by third parties in the subsidiary company
Thrace Plastics Pack S.A. and its subsidiar-
ies as listed in note 1 presented above.
The proportion of non-controlling inter-
ests in the Group’s results for the fiscal year
2024 amounted to € 641 (31.12.2023: € 559)
while there has been no proportion in the
other comprehensive income for the fiscal
year 2024 (31.12.2023: € 8).
3.28.2 Investments in companies consolidated with the equity method
The following table presents the com-
panies in which the management of the
Company is jointly controlled with another
shareholder with the right to participate in
their net assets. The companies are con-
solidated according to the Equity method
in line with the provisions of IFRS 11. The
parent Company holds at 31/12/2024 and
31/12/2023 direct shareholding of 50.91%
in Thrace Greenhouses SA with a value of
€ 3,615 (31.12.2023 € 3,615) and of 51% in
Thrace Eurobent SA with a value of € 204
(31.12.2023 € 204). The company Thrace
Greiner Packaging SRL is 50% owned by
Thrace Plastics Pack SA whereas Lumite
INC. is 50% owned by Synthetic Holdings
LTD.
50.91%
Country of Percentage of CompanyBusiness ActivityActivitiesShareholdingThrace The company operates in the production of plastic Greiner boxes for food products and paints and belongs to Romania46.47%Packaging the packaging segment.SRLThe company’s shares are not listed.The company operates in the production of United agricultural fabrics and belongs to the technical Lumite INC50.00%Statesfabrics segment.The company’s shares are not listed.The company operates in the production of Thrace agricultural products and belongs to the agricultural Green-Greecesegment.houses SAThe company’s shares are not listed.The company operates in the manufacturing of waterproof products with the use of Geosynthetic Thrace Clay Liner – GCL, and belongs to the technical fabrics Greece51.00%Eurobent SAsegment.The company’s shares are not listed.
The change of the Group’s Investments in the companies that are consolidated with the
equity method is analyzed as follows:
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 356 of 370
Contents
THRACE THRACE Investment in companies consolidated GREINER THRACE GREENHOUSES LUMITE INCTotalwith the equity methodPACKAGING EUROBENT SASASRLBalance at beginning of year, 5,041 4,734 9,582 564 19,92101.01.2023Gain / (losses) from joint ventures 1,434 220 305 372 2,331Dividends (954) - (454) - (1,408)Foreign exchange differences and (7) - (362) - (369)other reservesBalance at end of year, 31.12.2023 5,514 4,954 9,071 936 20,475Balance at beginning of year, 01.01.2024 5,514 4,954 9,071 936 20,475Gain / (losses) from joint ventures 1,072 56 (27) 240 1,341Dividends (1,179) - (481) (306) (1,966)Foreign exchange differences and 2 - 578 - 580other reservesBalance at end of year, 31.12.2024 5,409 5,010 9,141 870 20,430
The financial statements of the companies are presented in the following tables:
THRACE GREINER THRACE STATEMENT LUMITE INC THRACE EUROBENT SAPACKAGING SRLGREENHOUSES SAOF FINANCIAL POSITION2024 2023 2024 2023 2024 2023 2024 2023% of Shareholding46.47% 46.47% 50.91% 50.91% 50% 50% 51% 51%ASSETSProperty, Plant & 8,069 7, 399 14,560 14,867 4,600 4,243 637 772EquipmentInventories 2,904 3,146 428 263 12,769 12,717 578 626Trade and other 3,631 3,470 5,552 3,203 2,530 1,729 755 1,030receivablesOther asset accounts 1 - 659 580 195 2 216 173Cash 3,149 3,879 167 363 2,977 3,856 1,081 1,057LIABILITIESBank debt 3,293 2,565 9,488 7,922 2,132 2,141 611 754Other liabilities 3,589 4,260 2,038 1,623 2,796 2,361 917 1,052EQUITY 10,872 11,069 9,840 9,731 18,143 18,045 1,739 1,852
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 357 of 370
Contents
THRACE GREINER THRACE LUMITE INC THRACE EUROBENT SASTATEMENT OF PACKAGING SRLGREENHOUSES SACOMPREHENSIVE INCOME2024 2023 2024 2023 2024 2023 2024 2023Turnover 22,873 20,900 12,021 8,795 26,523 25,517 4,281 5,933Cost of sales (17,666) (15,362) (9,794) (6,914)(23,319) (21,708)(3,138) (4,183)Gross profit 5,207 5,538 2,227 1,881 3,204 3,809 1,143 1,750Selling & Distribution (993) (978) (1,178) (816) (1,577) (1,548) (456) (731)expensesAdministrative (1,905) (1,373) (577) (503) (1,483) (1,284) (109) (94)expensesOther (expenses) / 166 69 148 176 (38) (38) 30 (47)incomeOperating profit / 2,475 3,256 620 738 106 939 608 878lossFinancial result 18 49 (606) (297) (175) (179) (20) (28)Profit/(loss) before 2,493 3,305 14 441 (69) 760 588 850TaxesTaxes (332) (432) 96 (9) (16) (246) (115) (193)Profit/(loss) after 2,161 2,873 110 432 (85) 514 473 657Taxes
3.29 Commitments and Contingent Liabilities
On 31st December 2024 there are no sig-
nificant legal issues pending that may have
a material effect on the financial position
and the financial results of the companies
in the Group.
The letters of guarantee issued by the banks
for the Company and in favor of third par-
ties (Greek State, suppliers and customers)
amount to € 834 (31.12.2023: € 834).
As at December 31, 2024, the Group had
commitments for capital expenditures
of € 9,056. The total cost of investments
amounted to € 13,642, of which € 4,586
had been recognized in tangible assets,
until December 31, 2024.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 358 of 370
Contents
The financial assets used by the Group,
mainly consist of bank deposits, bank
overdrafts, receivable accounts, payable
accounts and loans.
The Group’s activities, in general, create
several financial risks. Such risks include
market risk (foreign exchange risk and
risk from changes of raw materials prices),
credit risk, liquidity risk and interest rate
risk.
3.31 Financial risks
3.31.1 Risk of Price Fluctuations of Raw Materials
The Group is exposed to fluctuations in
the price of polypropylene (represents
46% approximately of the cost of sales),
which are mainly faced by a similar change
in the selling price of the final product. The
possibility that the increase in the price of
polypropylene cannot be fully passed on
to the selling price, causes unavoidably
the compression of margins. For this rea-
son, the Company accordingly adjusts, to
the extent it is feasible, its inventory policy
as well as its commercial policy in general.
Hence, in any case, the particular risk is
deemed as relatively controlled.
3.31.2 Credit Risks
The credit risk to which the Group and the
Company are exposed is the likelihood
that a counterparty will cause financial loss
to the Group and the Company as a result
of the breach of its contractual liabilities.
The maximum credit risk to which the
Group and the Company are exposed at
the date of preparation of the financial
statements is the book value of their finan-
cial assets (note. 3.16 and 3.17). In order to
address credit risk, the Group consistently
applies a clear credit policy, which is moni-
tored and evaluated on an ongoing basis
so that the credit granted does not exceed
the credit limit per customer. Client sales
insurance policies are also concluded per
customer and no tangible guarantees on
the assets of clients are required.
In order to monitor credit risk, customers
are grouped according to the category
they belong to, their credit risk character-
istics, the maturity of their receivables and
any previous receivables that they have
caused, taking into account future factors
as well as the economic environment.
3.30 Fees of auditing firms
During the financial years 2024 and 2023, the total fees concerning services provided by
audit firms, are analyzed as follows:
Group CompanyFees of auditing firms2024 2023 2024 2023Fees for auditing services 431 452 60 66Fees for tax certificate 119 127 38 12Fees for non-audit services18 78 14 20Total 568 657 112 98
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 359 of 370
Contents
• Impairment
The Group and the Company, in the
financial assets that are subject to the
model of expected credit losses, include
receivables from customers and other
financial assets.
The Group and the Company recognize
provisions for impairment with regard to
the expected credit losses of all financial
assets. The expected credit losses are based
on the difference between the contractual
cash flows and the entire cash flows which
the Group (or the Company) anticipates to
receive. The difference is discounted by
using an estimate concerning the initial
effective interest rate of the financial
asset. For the trade receivables, the Group
and the Company applied the simplified
approach of the accounting standard
and calculated the expected credit losses
based on the expected credit losses
for the entire lifetime of these items.
Regarding the remaining financial assets,
the expected credit losses are being
calculated according to the losses of the
next 12 months. The expected credit
losses of the following 12 months is part of
the anticipated credit losses for the entire
life of the financial assets, which emanates
from the probability of a default in the
payment of the contractual obligations
within the next 12-month period starting
from the reporting date. In case of a
significant increase in credit risk since
the initial recognition, the provision for
impairment will be based on the expected
credit losses of the entire life of the asset.
3.31.3 Liquidity risk
Liquidity risk monitoring focuses on the
management of cash inflows and outflows
on a permanent basis, so that the Group
has the ability to meet its cash liabilities
and retain the cash reserves required for
its operations. Liquidity is managed by
maintaining cash and approved bank
credit lines. At the date of preparation of
the financial statements, unused approved
bank credits were available to the Group,
which are considered sufficient to handle
any possible shortage of cash in the future.
Short-term bank liabilities are renewed at
maturity, as they are part of the approved
bank credit lines.
The following table presents the liabilities
– disbursements according to their matu-
rity dates.
Up to 1 1-6 6-12 1-5 Over 5 Group 31.12.2024TotalMonthMonthsMonthsYears YearsSuppliers 20,746 34,718 36 - - 55,500Other short-term 17, 651 8,964 325 - - 26,940liabilitiesShort-term liabilities 504 9,406 21,821 - - 31,731Liabilities from leases 88 431 763 - - 1,282(short-term portion)Long-term debt - - - 32,755 493 33,248Liabilities from leases - - - 1,619 - 1,619(long-term portion)Other long-term liabilities - - - 403 - 403Total 31.12.2024 38,989 53,519 22,945 34,777 493150,723
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 360 of 370
Contents
Up to 1 1-6 6-12 1-5 Over 5 Company 31.12.2024TotalMonthMonthsMonthsYears YearsSuppliers 397 222 - - - 619Other short-term 3,150 651 238 - - 4,039liabilitiesShort-term liabilities - - - - - -Liabilities from leases (short-11 57 69 - - 137term portion)Liabilities from leases (long-- - - 41 - 41term portion)Other long-term liabilities - - - 277 - 277Total 31.12.2024 3,558 930 307 318 -5,113
Up to 1 1-6 6-12 1-5 Over 5 Group 31.12.2023TotalMonthMonthsMonthsYears YearsSuppliers 17,088 21,284 90 - - 38,462Other short-term liabilities 11, 611 9,695 72 - - 21,378Short-term liabilities 4,881 16,776 4,898 - - 26,555Liabilities from leases 85 444 611 - - 1,140(short-term portion)Long-term debt - - - 26,713 1,077 27,790Liabilities from leases - - - 1,885 -1,885(long-term portion)Other long-term liabilities - - - 518 - 518Total 31.12.2023 33,665 48,199 5,671 29,116 1,077 117,728
Up to 1 1-6 6-12 1-5 Over 5 Company 31.12.2023TotalMonthMonthsMonthsYears YearsSuppliers 259 105 - - - 364Other short-term liabilities 342 920 3 - - 1,265Short-term liabilities - - - - - -Liabilities from leases 13 50 80 - - 143(short-term portion)Liabilities from leases - - - 179 -179(long-term portion)Other long-term liabilities - - - 280 - 280Total 31.12.2023 614 1,075 83 459 - 2,231
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 361 of 370
Contents
Foreign Currency 2024 2023Change of foreign currency USD GBP Other USD GBP Otheragainst Euro Profit before tax+5% (238) (24) (4) (155) (53) --5% 262 27 4 172 58 -Equity+5% (13) (899) (269) (58) (438) (319)-5% 15 994 297 64 484 352
3.31.5 Interest rate Risk
Possible interest rate change Effect on Earnings before TaxGroup Company2024 2023 2024 2023Interest rate increase 1%(679) (573) - -Interest rate decrease 1%679 573 - -
The long-term loans of the Group have
been granted by Greek and international
banks and are mainly in Euro. Their repay-
ment time varies, depending on the loan
agreement and they are usually linked to
Euribor plus spread. The Group’s short-
term loans have been granted by vari-
ous banks, with Euribor interest rate plus
spread as well as Libor interest rate plus
spread.
The Group Management monitors the evo-
lution of the interest rates level and initiate
actions, to the extent possible, to retain or
decrease the spreads. At the same time, ef-
fort is being placed on liquidity manage-
ment, with a target to maintain a rational
debt balance, compared with Group’s
sales volume, profitability level and its in-
vestment plans.
It is estimated that a change in the average
annual interest rate by 1% will result in a
(charge) / improvement of Earnings before
Tax as follows:
Foreign exchange risk
The Group is exposed to foreign exchange
risks arising from existing or expected cash
flows in foreign currency and investments
that have been made in countries outside
Greece. The management uses hedge
instruments, mainly foreign currency for-
ward contracts, to hedge the risks arising
from changes in foreign exchange rates.
Sensitivity analysis of the effect of exchange
rate changes is given in the table below.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 362 of 370
Contents
3.31.6 Capital Adequacy Risk
The Group monitors capital adequacy us-
ing the Net Debt to EBITDA ratio and the
Net Debt to Equity ratio. The Group’s ob-
jective in relation to capital management
is to ensure the ability for its smooth op-
eration in the future, while providing ra-
tional returns to shareholders and benefits
to other parties, as well as to maintain an
adequate capital structure so as to ensure
a low cost of capital. For this purpose, it
systematically monitors working capital in
order to maintain the normal level of ex-
ternal financing.
Group CompanyCapital Adequacy Risk2024 2023 2024 2023Long-term debt33,248 27,790 - -Long-term liabilities from leases 1,619 1,885 41 179Short-term debt31,731 26,555 - -Short-term liabilities from leases1,282 1,140 137 143Total debt67,880 57,370 178 322Minus cash & cash equivalents33,456 27, 8 01 349 242Net debt **34,424 29,569 (171) 80EBITDA41,361 44,017 (236) (263)NET DEBT / EBITDA *0,83 0,67 - -EQUITY 275,169 277,054 75,214 80,358NET DEBT / EQUITY 0.13 0.11 0.00 0.00
* Since 2018, the Company has transformed into a Holding Company and therefore the net debt to
EBITDA ratio does not reflect the actual relation between the Company’s debt and its earnings. For
this reason, going forward the Company does not monitor the particular ratio.
** The cash and cash equivalents, and therefore the net debt, do not include an amount of € 13,269
relating to time deposits, which had been concluded during the previous financial year, with a dura-
tion of more than three months. The relevant amount had been transferred to the other receivables.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 363 of 370
Contents
The significant events that took place
during the current fiscal year (01.01.2024
- 31.12.2024) are presented in detail in Sec-
tion I of the Annual Management Report
of the Board of Directors, which forms an
integral part of the Annual Financial Re-
port, and are summarized below:
Macroeconomic Environment, Performance and Prospects of the
Group, Climate Issues and Expected Credit Losses
Direct Impact from Geopolitical Conditions
Announcement of Market Maker
Dividend for the Year 2023
Annual Ordinary General Meeting of the Company’s shareholders
Announcement of ex-dividend date / Payment of remaining dividend
for the Year 2023
Announcement of the new formation of the Remuneration and
Nominations Committee
Non-replacement of a member of the Board of Directors
Announcement of the Decision to Distribute an Interim Dividend the
2024
Issuance of Tax Certificates for the Fiscal Year 2023
Write-off of Dividend for the Financial Year 2018
3.32 Significant Events
3.33 Significant Events after the reporting date of the Financial Statements
The following paragraphs present the sig-
nificant events that took place after the
end of the financial year 2024 and up to the
date of issuance of this Report:
Replacement of the Officer of Investors Relation and Corporate
Announcements Department
The Board of Directors of the Company
decided, pursuant to relevant resolution
on the appointment of Mr. Dimitrios Frag-
kou son of Vasileios (CFO of the Company),
temporarily, as the Officer of Investors
Relation and Corporate Announcements
Department of the Company, in replace-
ment of the previous Head of Department,
Evangelia Sideri, daughter of Georgios.
Mr. Dimitrios Fragkou undertook his duties
on February 14th, 2025.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 364 of 370
Contents
The Board of Directors of the Company,
during its meeting of February 28th, 2025,
and following the relevant proposal made
by the Company’s respective Remunera-
tion & Nominations Committee, in accord-
ance with the provisions of article 82 par. 1
of Law 4548/2018, articles 5 and 9 par. 4 of
Law 4706/2020, article 8 of the Company’s
Articles of Association, and in accordance
with the currently effective Policy of Suit-
ability and the best corporate governance
practices applied by the Company, unani-
mously and by acclamation elected:
(a) Ms. Fotini-Marina Niforos daughter of
George and Ms. Eleni Providi daughter
of Dimitrios, as new temporarily inde-
pendent non-executive members of
the Board of Directors, replacing the
resigned and departed (due to the ex-
piration of the term limit as per article
9 par. 4 (c) of Law 4706/2020) inde-
pendent non-executive members of
the Board, Messrs. Nikitas Glykas and
Spyridoula Maltezou.
(b) Mr. Stylianos Vitogiannis son of Kon-
stantinos, as a non-executive member
of the Board of Directors, replacing the
late Mr. Christos-Alexis Komninos.
The aforementioned members fully meet
the criteria of individual and collective suit-
ability according to the provisions of arti-
cle 3 of Law 4706/2020, as in force, and the
approved and effective Policy of Suitabil-
ity of the Company and there is no conflict
of interest or incompatibility in relation to
their position under the applicable corpo-
rate governance legal framework, includ-
ing the Company’s Corporate Governance
Code and its Regulation of Operation.
Additionally, it is noted that the newly
elected two (2) temporarily independent
non-executive members of the Board of
Directors fully meet, as confirmed by the
Board’s above decision, the conditions
and criteria of article 9 par. 1 and 2 of Law
4706/2020, specifically:
(i) they do not directly or indirectly hold
more than 0.5% of the share capital and
voting rights of the Company and (ii) they
are free from any dependency relation-
ships with the Company or any related par-
ties, as defined in par. 2 of article 9 of Law
4706/2020, and do not have any financial,
business, family or other relationships that
could affect their decisions or independ-
ent, objective, and impartial judgment.
It is also emphasized that in compliance
with the requirements of article 18 par. 1
of Law 4706/2020, the detailed curriculum
vitae of the new members of the Board of
Directors are posted on the Company’s
website at thracegroup.com/gr/en/board-
of-directors/, where the full proposal of the
Nomination and Remuneration Commit-
tee is also available.
This replacement and the election of both
independent non-executive members and
the non-executive member of the Board
will significantly contribute to the further
strengthening of the Board by utilizing
their academic training, professional ex-
perience, qualifications, skills, and is in
line with the Company’s decision for the
continuous and optimal adaptation of its
organization to the provisions and regu-
lations of Law 4706/2020 (Government
Gazette A’ 136/17.07.2020) on corporate
governance and respective best prac-
tices. It is fully aligned with the provisions
of the aforementioned law concerning
Election of new members of the Board of Directors and Reconstitution
of the Board of Directors into a body
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 365 of 370
Contents
suitability, diversity and the fulfillment of
the minimum legally required number of
independent non-executive members.
Finally, it is noted that the election of the
aforementioned new members of the
Board of Directors will be announced, in
accordance with the provisions of the law
and the Company’s Articles of Association,
at the next General Meeting of the share-
holders of the Company. Furthermore,
regarding the new independent non-
executive members, it is noted that their
designation as independent is temporary
until the next General Meeting, which is
the only competent body to decide on this
matter.
Following the above, the Board of Direc-
tors of the Company was reconstituted
into body for the remainder of its term, i.e.
until February 11, 2026, as follows:
1. Konstantinos Chalioris son of Stavros,
Chairman of the Board of Directors
(executive member).
2. Theodoros Kitsos son of Konstantinos,
Vice Chairman of the Board of Direc-
tors (independent non-executive
member).
3. Dimitrios Malamos son of Petros, Chief
Executive Officer of the Company (ex-
ecutive member).
4. Athanasios Dimiou son of Georgios,
Member of the Board of Directors
(non-executive member).
5. Vasileios Zairopoulos son of Stylianos,
Member of the Board of Directors
(non-executive member).
6. Christos Shiatis son of Panagio-
tis, Member of the Board of Directors
(non-executive member).
7. Georgios Samothrakis son of Pana-
giotis, Member of the Board of Di-
rectors (independent non-executive
member).
8. Myrto Papathanou daughter of Chris-
tos, Member of the Board of Direc-
tors (independent non-executive
member).
9. Fotini-Marina Niforos daughter of
George, Member of the Board of Di-
rectors (independent non-executive
member).
10. Eleni Providi daughter of Dimitrios,
Member of the Board of Directors (in-
dependent non-executive member)
and
11. Stylianos Vitogiannis son of Konstanti-
nos, Member of the Board of Directors
(non-executive member).
Reconstitution of the Board of Directors into a Body
The Board of Directors of the Company,
during its meeting of April 1, 2025, follow-
ing the resignation of Mr. Theodoros Kitsos
exclusively from the capacity and office of
Vice Chairman of the Board of Directors of
the Company, retaining solely the status
of non-executive member of the Board
of Directors, due to the fulfilment of the
maximum time period of independence
provided for in accordance with the provi-
sions of the law in article 9 par. 1 and 2 of
Law 4706/2020 and following the relevant
proposal of the Remuneration & Nomina-
tions Committee of the Company and in
full compliance with article 8 par. 2 of Law
4706/2020 and the Greek Corporate Gov-
ernance Code (point 2.2.21) that the Com-
pany has established and implements,
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 366 of 370
Contents
unanimously and by acclamation appoint-
ed Mr. Georgios Samothrakis, son of Pana-
giotis, who already holds the status of In-
dependent Non-Executive Member of the
Board of Directors, as Vice Chairman of the
Board of Directors for the remainder of his
term (i.e. until February 11, 2026)
For completeness purposes, it is noted that
the fulfilment of the independence criteria
of article 9 of Law 4706/2020 in the person
of Mr. Georgios Samothrakis have already
been confirmed in this regard by the rele-
vant solemn Declaration of Independence
of a Member of the Board of Directors,
as well as in the context of the review of
the above criteria by the Remuneration &
Nominations Committee.
Following the above, the Board of Direc-
tors of the Company was reconstituted
into a body for the remainder of its term
of office, i.e. until February 11, 2026, as
follows:
1. Konstantinos Chalioris son of Stavros,
Chairman of the Board of Directors
(executive member).
2. Georgios Samothrakis son of Panagio-
tis, Vice Chairman of the Board of Di-
rectors (independent non-executive
member).
3. Dimitrios Malamos son of Petros, Chief
Executive Officer of the Company (ex-
ecutive member).
4. Athanasios Dimiou son of Georgios,
Member of the Board of Directors
(non-executive member).
5. Vasileios Zairopoulos son of Stylianos,
Member of the Board of Directors
(non-executive member).
6. Christos Shiatis son of Panagio-
tis, Member of the Board of Directors
(non-executive member).
7. Theodoros Kitsos son of Konstanti-
nos, Member of the Board of Directors
(non-executive member).
8. Myrto Papathanou daughter of Chris-
tos, Member of the Board of Direc-
tors (independent non-executive
member).
9. Fotini Marina Niforos daughter of
George, Member of the Board of Di-
rectors (independent non-executive
member).
10. Eleni Providi daughter of Dimitrios,
Member of the Board of Directors (in-
dependent non-executive member),
and
11. Stylianos Vytogiannis son of Konstan-
tinos, Member of the Board of Direc-
tors (non-executive member).
Reconstitution of the Remuneration and Nominations Committee into
a body, following the replacement of one its members
The Board of Directors of the Company,
during its meeting of April 4, 2025, ap-
proved the appointment of Mrs Eleni Pro-
vidi, Independent Non-Executive Member
of the Board of Directors, as a member of
the Nominations and Remuneration Com-
mittee of the Company, replacing the re-
signed member of the Committee, Mr.
Vasileios Zairopoulos, in order to ensure
the appropriate and compliant composi-
tion of the Nominations and Remunera-
tion Committee, in accordance with Article
10 paragraph 3 of Law 4706/2020 and the
Company’s Rules of Operation and follow-
ing the loss of independence of Mr. Theo-
doros Kitsos.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 367 of 370
Contents
On the same day and following the above
decision, i.e. on 04/04/2025, a meeting of
the Committee took place, under its new
composition. After a vote among its mem-
bers, it was reconstituted as follows:
1. Myrto Papathanou, daughter of Chris-
tos – Independent Non-Executive
Member of the Board of Directors,
Chair of the Nominations and Remu-
neration Committee
2. Theodoros Kitsos, son of Konstantinos
– Non-Executive Member of the Board
of Directors, Member of the Nomina-
tions and Remuneration Committee
3. Εleni Providi, daughter of Dimitrios –
Independent Non-Executive Member
of the Board of Directors, Member of
the Nominations and Remuneration
Committee
Proposed Dividend for the Year 2024
The Board of Directors of the Company,
with its meeting of April 24rd, 2025, unani-
mously decided to propose to the Annual
Ordinary General Meeting of shareholders
the approval of the distribution (payment)
of the profits of the fiscal year that ended
on 31.12.2024 and in particular to propose
the distribution (payment) to the share-
holders of a dividend of a total amount
of 10,250,000.00 Euros (gross amount),
i.e. 0.2343314986 Euros per share (gross
amount) from the profits of the fiscal year
2024 (01.01.2024-31.12.2024), but also from
profits of previous years.
Given that the Company, pursuant to the
relevant decision of the Board of Directors
dated November 14th, 2024, has already
distributed to the shareholders the in-
terim dividend for the fiscal year 2024 of a
total amount of 3,000,000.00 Euros (gross
amount), i.e. 0.0685848289 Euros per
share (gross amount), the Board of Direc-
tors will subsequently propose to the An-
nual Ordinary General Meeting of share-
holders the distribution of the remaining
amount of the dividend, and in particular
the amount of 7,250,000.00 Euros (gross
amount), i.e. 0.1657466698 Euros per share
(gross amount), which gross amount per
share will be increased by the amount
corresponding to the treasury shares that
the Company will hold on the dividend
cut-off date (and which treasury shares
are not entitled to the payment of the divi-
dend, by the provisions of article 50 of Law
4548/2018, as applicable.)
The Annual Ordinary General Meeting of
shareholders will take the final decision
concerning the approval of the above
proposal.
Annual Financial Report as of 31.12.2024
Amounts in thousand Euro, unless stated otherwise
Page 368 of 370
Contents
V. ONLINE AVAILABILITY OF THE FINANCIAL
REPORT
The Annual financial statements of the
Company and the Group, the Audit Report
of the Independent Chartered Auditor-
Accountant and the Management Report
of the Board of Directors have been regis-
tered on the internet at www.thracegroup.
com/gr/en/financial-information/
Also, the annual financial statements of the
significant subsidiaries and the reports of
the Certified Auditors, wherever required,
which are incorporated into the consoli-
dated financial statements of the Com-
pany THRACE PLASTICS CO S.A. are posted
on the internet at www.thracegroup.com/
gr/en/financial-information/
The Chairman of
the BoD
The Chief Executive
Officer
The Chief Financial
Officer
The Chief
Accountant
KONSTANTINOS ST.
CHALIORIS
DIMITRIOS P.
MALAMOS
DIMITRIOS V.
FRAGKOU
FOTINI K.
KYRLIDOU
ID NO. AM 919476 ID NO. Α01456959 ID NO. ΑΗ 027548 ID NO. ΑΚ 104541
Accountant Lic.
Reg. No. 34806
Α’ CLASS
There are no other events subsequent to the financial statements that have a significant
effect on the financial statements of the Group or the Company and would either need to
be disclosed or would vary the amounts in the published financial statements.
The Financial Statements have been prepared in accordance with the International
Financial Reporting Standards as such have been adopted by the European Union, were
approved by the Board of Directors on 24 April 2025 and are signed by the representa-
tives of such.
General Commerce Reg. No. 12512246000
Domicile: Magiko, Municipality of Avdira, Xanthi Greece
Offices: 20 Marinou Antypa Str., 174 55 Alimos, Attica Greece
www.thracegro up.gr
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