213800T9Y5XCOVRZ4Y57-2022-12-31-en.xhtml

PUBLIC POWER CORPORATION S.A.

FINANCIAL REPORT

(January 1

2022– December 31

2022)

(Translated from the Greek Original)

The attached Financial Report of the fiscal year 2022, has been prepared according to article

4 of Law 3556/2007 and the executive Decisions of the Board of the Hellenic Capital

Market Commission, has been approved by the Board of Directors of “Public Power

Corporation S.A.” on March 23 2023, and is available for the investors, on the internet, at the

web site address www.dei.gr.

Public Power Corporation S.A.

General Commercial Registry: 786301000

Chalkokondyli 30 - 104 32 Athens

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PUBLIC POWER CORPORATION S.A.

ANNUAL FINANCIAL REPORT

INDEX

A. STATEMENT OF MEMBERS OF THE BOARD OF DIRECTORS .......................................................................................... 4

B. EXECUTIVE SUMMARY OF THE BOARD OF DIRECTORS ................................................................................................. 7

MAJOR RISKS - UNCERTAINTIES .......................................................................................................................................... 25

NON-FINANCIAL REPORT ...................................................................................................................................................... 39

STATEMENT OF CORPORATE GOVERNANCE ..................................................................................................................... 95

C. AUDITOR’S REPORT......................................................................................................................................................... 175

D. NOTES ΤΟ THE FINANCIAL STATEMENTS ..................................................................................................................... 195

1. CORPORATE INFORMATION ...................................................................................................................................... 196

2. LEGAL FRAMEWORK .................................................................................................................................................. 197

3. SIGNIFICANT EVENTS ................................................................................................................................................. 204

4. BASIS OF PREPARATION AND PRINCIPAL ACCOUNTING POLICIES ..................................................................... 209

4.1. BASIS OF PREPARATION ........................................................................................................................................... 209

4.2. CHANGES IN ACCOUNTING POLICIES AND DISCLOSURES ................................................................................... 210

4.3. SIGNIFICANT ACCOUNTING JUDGMENTS AND ESTIMATES ................................................................................... 213

4.4. PRINCIPAL ACCOUNTING POLICIES ......................................................................................................................... 216

5. DISCONTINUED OPERATIONS (DISTRIBUTION NETWORK) .................................................................................... 232

5.1 ABSORPTION OF LIGNITE SUBSIDIARIES .................................................................................................................... 234

5.2 ASSETS HELD FOR SALE (POST-LIGNITE EXPLOITATION OF THE CORE LIGNITE PHASE-OUT ZONES) ............. 235

6. REVENUES ................................................................................................................................................................... 236

7. PAYROLL COST ........................................................................................................................................................... 237

8. ENERGY PURCHASES AND RELATED FEES ............................................................................................................ 238

9. DEPRECIATION AND AMORTISATION ....................................................................................................................... 239

10. EMISSION ALLOWANCES (CO

) ................................................................................................................................. 239

11. FINANCIAL EXPENSES ................................................................................................................................................ 240

12. FINANCIAL INCOME ..................................................................................................................................................... 240

13. OTHER (INCOME)/ EXPENSE, NET ............................................................................................................................. 240

14. INCOME TAXES (CURRENT AND DEFERRED) .......................................................................................................... 241

15. PROPERTY, PLANT AND EQUIPMENT, NET .............................................................................................................. 246

16. INTANGIBLE ASSETS, NET ......................................................................................................................................... 252

17. INVESTMENTS IN SUBSIDIARIES ............................................................................................................................... 253

18. INVESTMENTS IN ASSOCIATES ..................................................................................................................................... 256

19. BALANCES AND TRANSACTIONS WITH RELATED PARTIES ..................................................................................... 260

20. INVENTORIES .................................................................................................................................................................. 265

21. TRADE RECEIVABLES, NET ........................................................................................................................................... 265

22. CONTRACT ASSETS ....................................................................................................................................................... 267

23. OTHER RECEIVABLES, NET ....................................................................................................................................... 268

24. FINANCIAL ASSETS MEASURED AT FAIR VALUE THROUGH OTHER COMPREHENSIVE INCOME ..................... 269

25. CASH AND CASH EQUIVALENTS ................................................................................................................................... 270

26. SHARE CAPITAL AND SHARE PREMIUM ...................................................................................................................... 270

27. LEGAL RESERVE ............................................................................................................................................................ 271

28. OTHER RESERVE ............................................................................................................................................................ 272

29. DIVIDENDS ................................................................................................................................................................... 274

30. LONG-TERM BORROWING .......................................................................................................................................... 275

31. POST-RETIREMENT BENEFITS ................................................................................................................................... 280

32. PROVISIONS ................................................................................................................................................................. 283

33. SUBSIDIES .................................................................................................................................................................... 287

34. LONG-TERM CONTRACT LIABILITIES ........................................................................................................................ 287

35. IMPAIRMENT LOSS ON ASSETS .................................................................................................................................... 288

36. TRADE AND OTHER PAYABLES................................................................................................................................. 288

37. SHORT-TERM BORROWINGS ..................................................................................................................................... 288

38. SHORT-TERM CONTRACT LIABILITIES ..................................................................................................................... 289

39. ACCRUED AND OTHER CURRENT LIABILITIES ........................................................................................................ 289

40. COMMITMENTS, CONTINGENCIES AND LITIGATION ............................................................................................... 290

41. FINANCIAL INSTRUMENTS AND FINANCIAL RISK MANAGEMENT ......................................................................... 310

42. LEASES ............................................................................................................................................................................ 314

43. DERIVATIVE FINANCIAL INSTRUMENTS ....................................................................................................................... 317

44. SECURITIZATION OF TRADE RECEIVABLES FROM ELECTRICITY SALES ............................................................ 321

45. SUBSEQUENT EVENTS ............................................................................................................................................... 322

E. APPENDIX I -UNBUNDLED FINANCIAL STATEMENTS .................................................................................................. 323

F. REPORT ON THE USE OF PROCEEDS ............................................................................................................................ 339

A. STATEMENT OF MEMBERS OF THE BOARD OF

DIRECTORS

STATEMENT OF MEMBERS OF THE BOARD OF DIRECTORS

(According to article 4, par.2 of Law 3556/2007)

1. Georgios Stassis, Chairman and C.E.O. of P.P.C. S.A.

2. Maria Psillaki, Member of the Board of Directors,

3. Stefanos Kardamakis, Member of the Board of Directors

hereby

WE DECLARE

that, to the best of our knowledge:

a) the accompanying Financial Statements of the Parent Company and the Group, for the year ended

December 31

2022, which were prepared according to the International Accounting Standards –

currently in effect- as adopted by the European Union, truthfully depict assets, liabilities, equity and

the statement of income of Public Power Corporation S.A., as well as the companies included in the

consolidation, according to the provisions of article 4 of Law 3556/2007 and,

b) the accompanying Board of Directors’ Report truthfully depicts the evolution, performance and

position of “Public Power Corporation S.A.” and the companies included in the consolidation, as well

as a description of the major risks and uncertainties they face.

Athens March 23

2023

Chairman and C.E.O.

Member of the Board.

Georgios Stassis

Maria Psillaki

Stefanos Kardamakis

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B. EXECUTIVE SUMMARY OF THE BOARD OF DIRECTORS

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PUBLIC POWER CORPORATION S.A.

EXECUTIVE SUMMARY OF THE BOARD OF DIRECTORS

FOR THE FISCAL YEAR 2022

Dear Shareholders,

Following the end of the Public Power Corporation’s twentieth first fiscal year as a Societe Anonyme, we

have the honor to submit for approval, according to the Company’s statutes, the financial statements for

the year ended December 31

2022, as well as, our comments on the respective statements.

Furthermore, we submit for approval the unbundled financial statements for the year 2022 (Appendix I of

the Annual Financial Statements) according to the provisions of L. 4001/2011 art. 141 and the approved

by the Regulatory Authority of Energy, methodology of accounting unbundling.

The Group’s subsidiaries which are consolidated in the Group’s financial statements are the following:

“PPC Renewables S.A.”, “HEDNO S.A.”, “ Arkadian Sun 1 Sole Shareholder S.A.”, “Arkadian Sun 2 Sole

Shareholder S.A”, “Solar Arrow 1 Sole Shareholder S.A.”, “Amalthia Energy Sole Shareholder S.A”,

“SOLARLAB Sole Shareholder S.A.”, “Solar parks Western Makedonia 1 Sole Shareholder S.A.”, “Solar

parks Western Makedonia 2 Sole Shareholder S.A.”, “AIOLIKO PARKO K-R Sole Shareholder S.A.”,

“AIOLIKO PARKO LYKOVOUNI Sole Shareholder S.A.”, ‘AIOLIKO PARKO DOUKAS Sole Shareholder

S.A.”, “AIOLIKO PARKO KOUKOULI Sole Shareholder S.A.”, “HELIOFANEIA Sole Shareholder S.A.”

“CARGE S.A.”, “Alexandroupolis Electricity Production Sole Shareholder S.A.”, “DEI Optikes

Epikoinonies Single member S.A.”, “PPC FINANCE PLC”, “PPC Bulgaria JSCo”, “PPC Elektrik Tedarik

Ve Ticaret A.S.”, “PHOIBE Energiaki S.A.”, “PPC ALBANIA”, “Energeiakos Stochos Sole Shareholder

S.A.», “Windarrow Energiaki Sole Shareholder S.A.”, “EDS AD Skopje”, “EDS DOO Belgrade”, “EDS

International SK SRO” and “EDS International KS LLC”.

Based on L. 4548/2018, as applies, PPC S.A. prepared the financial statements for the year ended

December 31

2022 (twentieth fiscal year), in accordance with the International Financial Reporting

Standards (IFRS), as endorsed by the European Union.

This report also refers to Alternative Performance Measures. For details on the purpose and calculations

refer to ANNEX - Definitions and reconciliations of Alternative Performance Measures (“APMs”)

The annual Report of the main Subsidiaries for the year 2022, are available on the internet at the following

web site addresses:

HEDNO S.A.

http://www.deddie.gr

PPC RENEWABLES S.A.

http://www.ppcr.gr

Amendments in the current legal framework during 2022

All detailed amendments in the current legal framework are presented in Note 2 to the Financial

Statements.

PPC Group 2022 financial results

Key Group Financial Results

2022 2021

Δ (% )

Q 4 2022 Q 4 2021

Δ (% )

(1)

11,253.1 5,706.4 97.2% 2,690.4 2,008.8 33.9%

(2)

10,299.4 4,834.7 113.0% 2,380.9 1,763.6 35.0%

(3)=(1)-(2)

953.7 871.7

9.4%

309.4 245.3

26.2%

(4)=(3)/(1)

8.5% 15.3% 11.5% 12.2%

302.4 50.6 26.3 1.1

(6)=(3)-(5)

651.3 821.1

-20.7%

283.1 244.2

15.9%

(7)=(6)/(1)

5.8% 14.4% 10.5% 12.2%

(8)

875.0 863.3 1.4% 213.6 233.3 -8.4%

(9)

-197.7 107.6 -283.8% -55.6 75.8 -173.4%

(10)=(6)-(8)-(9)

-26.0 -149.8

-82.6%

125.1 -64.8

-292.9%

(11)

-8.9 -18.4 -51.5% 160.9 23.8 575.1%

Im pairm ent loss

Pre-tax profits/(Losses)

N et incom e / (Loss)

Depreciation, total net financial expenses and

share of profits/(losses) in associated

com panies and JVs

EBITD A m argin

EBITD A

O ne-offs

EBITD A recurring

EBITD A m argin recurring

(5)

(in € m )

Turnover

O perating expenses

Evolution of key Group figures (€ million)

Profitability evolution

Increased operational profitability in 2022, despite the large increase in operating expenses, mainly in the

expenses for energy purchases and for natural gas. Specifically, EBITDA on a recurring basis amounted

to € 953.7 m increased by €82 m (9.4%) compared to 2021.

As far as Q4 2022 is concerned, EBITDA on a recurring basis amounted to € 309.4 m compared to €

245.3 m in Q4 2021.

It is noted that 2022 EBITDA has been impacted by the extraordinary contribution imposed on electricity

generators for the period October 2021 – June 2022 and which for PPC was calculated at € 245.3 m

following the final settlement, by the provision for personnel’s severance payment of € 50.5 m, as well as

by the retroactive charge of €6.6 m for special allowances from the implementation of the Collective Labor

Agreement for the period 2021 -2024.

Pre-tax losses amounted to € 26 m compared to pre-tax losses of €149.8 m in 2021.

Pre-tax results for 2022 include a positive impact of €177.5m due to a reversal of the impairment of the

investment in the new Ptolemaida V lignite unit. The reversal is due to the fact that lignite generation is no

longer loss making due to the energy crisis and the associated high prices in the wholesale market.

Net losses of €8.9 m were recorded in 2022 compared to net losses of €18.4 m in 2021.

Analysis of Revenues & Operating Expenses of PPC Group

Revenues

Turnover for 2022, increased by €5,546.7 m or 97.2% due to the increase of the average revenue, as a

result of the high increase of wholesale prices. Specifically, in Q4 2022 turnover amounted to € 2,690.4

m marking an increase of 33.9% compared to the respective period of 2021.

Operating Expenses

Operating expenses before depreciation, excluding the extraordinary contribution of €245.3m, the

provision for personnel’s severance payment of € 50.5 m and the retroactive charge for special

allowances from the implementation of the Collective Labor Agreement for the period 2021 -2024 of €

6.6 m, increased in 2022 by €5,464.7 m (or by 113%) to €10,299.4 m compared to €4,834.7 m in 2021,

mainly as a result of the particularly high expenses for fuel cost, energy purchases and CO2 emission

allowances while there was also a negative effect from the provisions for expected credit losses.

Operating expenses before depreciation for 2021 do not include the one-off impact from the retroactive

charge for special allowances from the implementation of the Collective Labour Agreement for the period

2021-2024 and the provision for personnel's severance payment.

Operating figures (generation – imports- exports)

In terms of domestic demand (excluding exports) a reduction of 3% was recorded for the 2022 (to 55,389

GWh compared to 57,074 GWh) while for Q4 2022 the reduction was 8.3%, as a result of the decrease

in demand by consumers due to the energy crisis and the incentives provided by the State for energy

saving as well as the fact that the weather conditions in Q4 2022 were more favourable than those in the

corresponding period of 2021. Total electricity demand (including exports) marked a decrease by 1.6%

in 2022 and a decrease by 9.2% in Q4 2022.

PPC’s average retail market share in the country, declined to 62.4% in 2022, compared to 64.3% in 2021.

Specifically, the average retail market share in the Interconnected System decreased to 63.3% in

December 2022 (from 64.2% in December 2021), while PPC’s average market share, per voltage, was

88.3% in High Voltage, 44.2% in Medium Voltage and 63.7% in Low Voltage compared to 87.8%, 44.0%

and 65.0% in 2021, respectively.

PPC’s electricity generation and imports covered 37.2% of total demand in 2022 (33.2% in the

Interconnected System), while the corresponding percentage in 2021 was 43.7% (40.3% in the

Interconnected System).

Specifically, generation from large hydro power plants decreased by 1,289 GWh and amounted to 4,005

GWh, which is close to the average of the last five years. Nonetheless, large hydro power plants

generation is lower by 24.3% compared to 2021 when hydrological conditions were excellent.

Generation from PPC's natural gas fired units decreased by 2,364 GWh, while lignite fired generation

increased by 119 GWh.

At country level, there was an increase in RES electricity generation (including large hydro power plants)

by 6.2% or 1,382 GWh. In addition, electricity imports increased by 7.3% or 618 GWh.

Energy mix expenditure

Expenditure for liquid fuel, natural gas, CO2, lignite and energy purchases increased by €4,911 m

(141.4%) compared to 2021.

In detail:

- Liquid fuel expense in 2022 increased by 58.9% compared to 2021 to €853.2 m, mainly due to the

increase in the prices of fuel oil (by 48.4%) and diesel (by 65.8%).

- Natural gas expense increased significantly by 93.2% to €1,758.2 m from €910.1 m due to the

large increase of natural gas price by 146.9% despite the lower natural gas fired generation by

21.4%.

- Energy purchases expense increased by €3,433.3 m (266.8%) due to the increase of the Market

Clearing Price (MCP) (from €116.4/MWh in 2021 to €280/MWh in 2022) and the increased volume

of energy purchases.

- Expenditure for CO2 emission rights increased to €1,037.5 m in 2022 from €699.2 m in 2021, due

to the increase of the CO2 emission rights average price to €72.7/tn from €44.9/tn despite the

decrease in CO2 quantities by 6.3% to 14.8 m tn

Payroll cost

Total payroll cost excluding the impact of one-off items, increased by € 31.8 m in 2022 to € 711.5 m from

€ 679.7 m in 2021 due to the abolition of the ceiling on the payroll of the Group's personnel as well as the

reinstatement of Christmas and Easter bonuses.

The Group’s personnel decreased by 154 employees (from 12,909 at the end of 2021 to 12,755 at the

end of 2022).

Provisions

In 2022, bad debt provisions increased by € 207.5 m compared to a reversal of bad debt provisions of €

59.7 m in 2021.

One off items impacting EBITDA

EBITDA in 2022 has been negatively affected by

1. the extraordinary contribution imposed on electricity generators for the period October 2021 –

June 2022 and which for PPC was originally calculated at € 276 m and following the final

settlement decreased to €245.3 m.

2. the provision for personnel’s severance payment of €50.5 m which was recorded in Q4 2022, as

well as

3. the retroactive charge of €6.6 m for special allowances from the implementation of the Collective

Labor Agreement for the period 2021 -2024.

Respectively, EBITDA in 2021, w.as negatively impacted by

1. the €34.6 m expense for the retroactive charge for special allowances from the implementation

of the Collective Labour Agreement for the period 2021-2024 and

2. the provision for personnel's severance payment of €16.1 m.

Capex

Capital expenditure amounted to €686.2 m in 2022 compared to €437.9 m in 2021. As shown in the table

below, most of the increase is attributed to higher investments in RES projects as well as in the Distribution

network.

The composition of main capex is as follows:

emissions for 2022 are based on temporary data and do not include the CO2 emissions of the thermal units of 0.05 m

tonnes that do not participate to the Emissions Trading System

(in € m )

2022 2021

Δ Δ (% )

Conventional G eneration (*) 176.5 166.4 10.1 6.1%

RES projects (**) 174.7 36.4 138.2 379.5%

Distribution netw ork 312.3 221.5 90.8 41.0%

O ther 22.8 13.5 9.3 68.7%

Total 686.2 437.9

248.4 56.7%

(*) Includ ing M ines capex

(**) Includ ing ca pex for hydro p ow er plants

Net Debt

Net debt stood at €1,388.1 m on 31.12.2022, decreased by €501.7 m compared to 31.12.2021 (€1,889.8

m). Net debt calculation takes into account the €1,323.3 m paid by Macquarie Asset Management in Q1

2022 for the acquisition of 49% of the share capital of HEDNO.

Net Debt evolution is shown below:

(in € m )

31.12.2022 31.12.2021

G ross Debt (1) 4,598.7 4,775.8

Cash and cash equiva lents / Restricted ca sh*/ O ther

financial assets (2)

3,210.6 2,886.0

N et Debt (3) = (1) - (2) 1,388.1 1,889.8

(*) For the calculation of net debt, restricted cash related to debt has been deducted

Capital Expenditure Program of Business Units

Total capital expenditure for the Parent Company amounted to € 206.1 million and was allocated as

follows: € 30.8 mil to Mines, € 152.5 million to Generation, € 2.6 mil. to Commercial and € 20.1 million to

activities of the Administrative Divisions. Capital expenditure for the Parent Company for the year 2022

has increased by € 22.4 million, compared to 2021, representing an increase of 12% (without taking into

account for 2021 the spin-off activity of the Distribution Network sector, whose investments amounted to

170.4 million).

Total capital expenditure for the Group for 2022 amounted to € 686.2 million and includes besides the

Parent Company’ capital expenditure, also those of PPC RENEWABLES S.A. amounting to € 167.8

million and of HEDNO S.A. amounting to € 312.3 million. Capital expenditure for the Group for the year

2022 increased by € 248.4 million, compared to 2021, representing an increase of 57%.

Mines Business Unit

Capital expenditure of the Mines Business Unit for 2022 amounted to approximately €30,8 million and is

related to projects in Western Macedonia Lignite Center (WMLC). A breakdown of the capital expenditure

amount spent during 2022 is presented below:

1. €8.0 mil. were spent on land expropriations of which €3,6 million on land acquisition in the region

“ΟDPK1”, €3.9 mil. in the region of “ONP7.”.

2. €15.0 mil. were spent on related to the Ptolemais V unit construction works.

3. €6.4 mil. were spent on electromechanical works of which €2.2 million on belt conveyor’s extensions,

and the rest on equipment upgrades and reconstructions.

4. € 0.7 mil. were spent on civil engineering works and other technical projects (berm floor construction,

road asphalting).

5. € 0.7 mil. were spent on environmental projects and commotments to third parties (national road and

railway relocation, waste management projects, fences construction etc)

Total excavations in the Mines amounted to 55.9 million cubic meters and lignite production to 13.4 million

Tones

Generation Business Units

Exploitation:

• During 2022 the total net production of the General Division of Lignite Generation (GDLG) and General

Division of Thermo- and Hydro-electrical Generation (GDTHG) power stations (including the

subsidiaries Lignitiki Megalopolis S.A., Lignitiki Melitis S.A. and excluding PPC Renewables S.A.)

amounted to 18.1 TWh, decreased by 19.34% compared to 2021 (21.6 TWh).

• The lignite fired generation (excluding the subsidiaries’) was 5.4 TWh increased by 1.89% compared

to 2021 (5.3 TWh). The lignite Units’ availability factor was 77.1%, increased by 10.86 p.c. units

compared to 2021. The load factor of lignite fired units reached 32.24%, as opposed to 27.61% in

2021. The utilization factor reached 41.93% in 2022 from 44.5% in 2021. Furthermore, in 2021 Units

III and IV of Kardia Lignite Power Plant were decommissioned.

SES Ptolemaida 5 produced 0,124 TWh in December 2022, during its hot-commissioning period,

which is not included in the total energy production as well as in the above indices.

• In 2022 the hydroelectric generation reached 4.0 TWh, decreased by 1.3 TWh or 24.53% compared

to 2021 (5.3 TWh).

• Natural gas based generation in 2022 reached 8.7 TWh, 2.3 TWh less than in 2021, which is a 20.9%

decrease. The Units’ load factor reached 37.68% in 2022, a reduction of 10.86 p.c. units compared to

2021. The availability factor in 2022 was 81.45%, decreased by 3.12 p.c. units compared to 84.57%

in 2021. The utilization factor decreased by 10.34 p.c. units reaching 46.27% in 2022 from 56.61% in

2021.

• In view of the increased load demand placed on Crete’s and the Other NII systems during 2022, extra

173 MW of non-permanent capacity were used.

Investments:

Total Investments of the General Division of Lignite Generation and the General Division of Thermo- and

Hydro-electrical Generation during 2022 amounted to €152.5 mil. (excluding the Mines Business Unit

referred above).

In the context of PPC S.A.’s Strategic Priorities Plan, the GDTHG and the GDLG have undertaken the

implementation of Investment Projects in order to replace obsolete Units with new, environmentally

friendly ones, of modern technology and higher performance. Concerning the progress of the Projects

during 2022 it is noted that:

Thermal Units

Steam Electric Unit V, of Ptolemaida Station, of 660 MW (+ 140 MWth for District Heating)

installed capacity, using pulverized lignite fuel:

During 2022: Unit’s systems erection works were completed, and the main and auxiliary equipment

had their operational tests started as to carry out their final adjustments.

Milestones include the boiler operation with lignite fuel, the first synchronization of the Unit to the grid

and the operation of the Unit at the full load of 660MW.

In summary, at the end of 2022 and in terms of budgetary cost, the civil work progress reached 99.3%

and the electromechanical erection reached to 98.5%.

The expenditure for the project during the fiscal year 2022 amounted to € 111.3 mil.

Within 2023: The Unit will start its commercial operation and its performance tests will be carried out,

while in parallel additional works that will allow Unit to provide up to 140MWth of thermal capacity to

the district heating network of the city of Ptolemaida are expected to be finalized.

Hydroelectric Units

Mesochora Hydro-Electric Project (HEP) (160+1.6 MW):

The Council of the State, with its Decision 2230/2020 published in Dec. 2020, cancelled the project’s

Approval Decision of Environmental Terms and Conditions. PPC has submiitted a new Environmental

Impact Study and has obtained a new Approval Decision of Environmental Terms and Conditions,

issued on 21.12.2021.

There are under way the procedures to incorporate the new terms in order to announce tenders for

completing the remaining works for the project and for the ground stabilization of Sector D of the

Mesochora village while the contract procedure for the inspection of the electromechanical equipment

with the company that had supplied and installed it has already been singed.

Metsovitiko HEP (29 MW):

The construction is ongoing according to the new time schedule, after the issuance of building permits,

in December 2020, for its commercial operation at the beginning of 2024. During 2022 construction

and other Civil Engineering works took place, as well as studies and approvals for the manufacturing

and installation of electromechanical equipment.

The procurement and installation of the received electromechanical equipment as well as the civil

works are in progress. The expenditure for the project in fiscal year 2022 amounted to 3.0 mil.

Non-Interconnected Islands (Rhodes, Other NII

New South Rhodes Station, of 115.4 MW net capacity, consisting of seven similar generating

sets (G/S) with four – stroke Diesel engines:

The project has been finalized since the 8

of July 2021 according to the approved Temporary and

Final Acceptance Protocol. The new Power Station Operation License has been issued according to

decision ΥΠΕΝ/ΔΗΕ/122314/2180/17-12-2021.

The total investment expenditure for the Island of Rhodes and the Other NII for fiscal year 2022

amounted to € 8.2 mil.

Environmental Management / Health and Safety

Environmental Management:

During 2022 and towards the improvement of the environmental behavior of the Power Generation Units

of GDLG and GDTHG:

- Environmental Management Systems (EMS) certified according to ISO 14001:2015 of twenty-two (22)

PPCs' Steam and Hydro Electric Stations and the Lignite Center of Western Macedonia were re-

certificated by independent Certification Bodies, after surveillance audits.

- A new EMS according to ISO 14001:2015 for SES South Rhodes (SES Kattavia) was certificated.

- The process for a new EMS according to ISO 14001:2015 for HPS N. Plastira continued.

- The tender aiming at developing, applying and certificated the Thermal and Hydroelectric Power

Plants (4 Natural Gas, P.P., 3 Hydro Complexes και 1 Οil P.P.) according to ISO 50001:2018 has been

completed.

- Energy Management System (EMS) according to ISO 50001 of the Lignite Center of Western

Macedonia was re-certificated by independent Certification Bodies, after surveillance audit. The

Lignite Center was certified according to ISO 50001:2018, for the first time in 2019.

- In collaboration with the Recruitment, Development & Training Director of PPC, the following training

courses were carried out:

✓ ISO 14001:2015 Environmental Management System Lead Auditor (IRCA Certified)

✓ ISO 14001:2015 Environmental Management System Internal Auditor (IRCA Certified)

- Environmental Management Systems (AMS) according to ISO 14001:2015, of Autonomous Power

Stations of Milos, Thira, Lesvos, Paros and Ikaria, was certificated by independent Certification Bodies,

after surveillance audits.

- A new environmental policy was issued (Board Decision 88/12.07.2022)

Health and Safety:

During 2022, towards the improvement of the Occupational Health & Safety (OHS) record of the Power

Generation Units of GDLG and GDTHG:

- The existing Occupational Health & Safety Management Systems (OHSMS) compliant to ISO

45001:2018, of twelve (12) Thermal Power Plants (TPPs), as well as of the Megalopolis Lignite

Center and the Skyros Local Power Plant (LPP) were successfully audited or recertified by

independent certified auditors. The above includes the two (2) TPPs (Meliti TPP, Megalopolis

TPP) that belonged to the subsidiaries Ligntiki Melitis S.A. and Lignitiki Megalopolis S.A. and

have since 1.6.2022 been re-integrated to PPC S.A.

- The transition was completed from the standard OHSAS 18001:2007 (ΕΛΟΤ 1801), to the new

standard ISO 45001:2018, after successful field audits by independent auditors, for the OHSMS

of the Main Field Mine and the Exploitation and Operational Support units of the West Macedonia

Lignite Center. Thus, the transition process from the old to the new standard is now complete for

all OHSMS, and the work of the relevant joint committee is over.

- The development of OHSMS compliant to ISO 45001:2018 at all the Hydroelectric Power Plants

(HPPs) pf PPC S.A. has started.

- In collaboration with the Recruitment, Development & Training Department, the following training courses

were organized:

✓ Introductory quick course for new Safety Engineers, given by the OHS Department

✓ ISO 45001:2018 OHS Management System Lead Auditor, given by external partner (IRCA Certified)

- Joint Inspection Committees were assigned, consisting of members from the OHS

Department and the Generation Departments of GDTHG, with the aim to schedule and

perform regular third-level inspections at the corresponding generation units.

- The drafting of a directive on protection measures against any possible presence of hexavalent

chromium in gas turbines at PPC power plants has been completed and broadcast to all

generation Units. Thus, the work of the relevant joint committee is over.

Commercial Business Unit

The investments of Commercial Activities in 2022 amounted to € 2.6m and relate mainly to the renovation

of stores & offices (€ 0.9m) with corresponding IT equipment & furniture (€ 0.4m). Also, software costs

amounted to € 1.5 million, relating to tools that aim to improve the services provided to customers, by

redesigning the web site and mobile app, as well as software that will enhance the customers’ data base

and will help forecast electricity demand in the future.

PPC in an effort to contain rising energy costs and offset their impact on customer tariffs, maintained

energy discounts on contracts with floating tariffs until July 2022, while fully implementing supporting

measures introduced by the State, incorporating the subsidies to beneficiary customers in both electricity

and natural gas bills.

In April 2022, PPC’s tarrifs were adjusted incorporating high energy costs prevailing at the time, for fixed

tariff electricity products (as well as to the product portfolio of Natural gas products as a whole), however,

only affecting new contracts and maintaining lower electricity bills for customers who had chosen in

previous months one of these products.

In the context of its corporate operation, the Company has been developing and has implemented action

programs for a long time, with the main objective of improving collections and at the same time providing

integrated solutions to its customers in terms of servicing their overdue bills. More specificcaly, it improves

its credit policy in accordance with the Electricity Supply Code by creating scalable actions for information

and collections, which are constantly evolving, while their effectiveness is contantly monitored.

At the same time, it continues its cooperation with a company that provides specialized support services

in the context of the securitization of the company's trade receivables aiming to reduce overdue debts and

prevent the creation of new ones, driven by the critical conditions that prevel in the Energy sector. The

Company also applies a new debt settlement policy for its entire customer base providing flexible

settlement programs and personalized solutions according to the needs of its customers.

PPC also established new electronic and telephone bill collection services. Finally, in the new PPC store,

apart from energy products (electricity & natural gas), there is a special area for the sale of smart products

incorporating the latest technology.

With Law 4951/2022, from August 1, 2022, the adjustment clause in electricity supply tariffs is abolished.

Instead, Suppliers in the case of floating tariffs announce in advance the prices that will apply for each

month. PPC, in applying the Law, has proceed with the relevant announcements (Note 2), announcing

electricity tariffs on the 20

of every month.

In November 2022 PPC updated its natural gas product portfolio, eliminating fixed rate products and

adjusted tariffs for variable rate products of natural gas.

DEI OPTIKES EPIKOINONIES S.A (distinctive title: FIBERGRID)

Summary of scope of works

PPC is entering a new phase during which it plans to transform itself into a modern, strongly outward-

looking and efficient European utility facing a challenging economic and regulatory environment.

Within this framework, at the end of December 2022, PPC officially established a pure wholesale Fiber-

To-The-Home (FTTH) operator company, DEI OPTIKES EPIKOINONIES S.A to ensure a step-change in

the Greek ultra-broadband market, offering performance up to 10 Gbps, in line with EU targets on Gigabit

Society.

FIBERGRID’s ambitious plan is to cover approximately 3Mln households with FTTH technology over the

next 5 years in the most attractive areas of Greece (approx. 100 municipalities).

The total investment planned to finance the project amounts to ca. €900m.

Project progress 2022

PPC’s Board of Directors approved the launch of a Pilot project with the aim of testing the chosen fiber

network architecture, different deployment techniques and fine-tuning processes with OLOs.

In order to proceed with the deployment of the pilot project, it was necessary to regulate the access to the

HEDNO electricity infrastructure (since any network operator must grant access to its physical

infrastructure to allow third-party fiber rollout, under fair and reasonable terms and conditions). The

agreement between the parties established that PPC is the owner of the right for re-use HEDNO

infrastructure, while HEDNO constitutes the grid assets owner and operator.

Pilot construction works began in early January 2022, providing FTTH services to the municipality of

Peristeri, that account for a total of 15k HHs. At the end of December 2022, the pilot project was

successfully completed: 15k HHs were passed, deploying a total of ca. 130km of cables.

FIBERGRID is now entering the first phase of its deployment plan, corresponding to 2023 scope, aiming

at covering approx. 440k households at 13 municipalities in the greater area of Attica. The company has

already completed the necessary procurement activities for construction and materials while

procurement activities for other services, systems and tools are ongoing.

PPC e-Mobility

In 2022, PPC e-Mobility brand “DEI blue” has been the largest network of publicly accessible charging

stations for electric vehicles in Greece. In 2022, PPC e-Mobility installed a significant number of publicly

accessible Chargers throughout the country, having installed a total of more than 1,000 Publicly

accessible Chargers by the end of 2022, thanks also to the agreement and implementation of important

partnerships with businesses in Retail and in other sectors. In addition, in 2022, PPC e-Mobility proceeded

to acquire the electric mobility service provider Carge. The Carge company, one of the most dynamically

developed start-ups in its field, specializes in the development of innovative software for e-Mobility

applications which, among other things, enable the EV drivers to navigate through a digital map arriving

at the charging station from the best and fastest route by charging in the extensive Network of PPC e-

Mobility public chargers throughout the country.

HEDNO S.A.

Development & Operation of Networks

In 2022, distribution facilities were expanded by 1,019 km in the medium voltage (MV) networks and by

627 km in the low voltage (LV) networks, while at the same time an additional 602 Low/Medium

transformers were installed and 2,516 switching systems became operational. Thus the MV network now

extends over 115,299 km and the LV network has reached 129,497 km in length, while the number of

transformers installed in the network amounts to 166,762. The active users of the distribution networks

amounted to 7,671,479, of which 15,786 are MV users.

Turnaround Times of New Connections

The average service time (studies and construction installation works) for ordinary new user connections

was 28 working days, while for connections requiring network intervention works it is 59.1 working days,

and for alternative network change requests it is 33 working days.

Environmental Issues

The Company takes due care to improve its environmental performance. In this regard, the Carbon

Footprint of direct (Scope 1) and indirect (Scope 2) emissions was calculated in 2022, while the calculation

of other indirect emissions (Scope 3) was performed for the first time, covering the period 01/01/2021 -

31/12/2021, with this data being used for the PPC Group's 2nd Sustainable Development Report. In

general, the project involves the design and development of a methodology for HEDNO SA's Carbon

Footprint, with the objective of identifying and calculating the Company's greenhouse gas emissions, both

direct and indirect emissions, that result from combustion in stationary and mobile equipment, electricity

consumption, electricity losses in the network, procurement of goods and services, and waste

management. The provision of services with an expert consultant to assist the Company in the verification

of its Carbon Footprint emissions data in accordance with ISO 14064-1:2018 for the year 2021 was

approved in December 2022, as part of the formal validation of the PPP Group's Sustainable Development

in Science Based Targets Initiative (SBTi) and more generally for the adoption of an integrated system of

recording, calculation, monitoring and disclosure of the Carbon Footprint, in compliance with ISO

14064:2018, on an annual recurring basis.

At the same time, it takes steps to conserve natural resources, such as tree pruning and ground vegetation

clearance aimed at forest preservation. Another key aim is aesthetic improvement of the environment,

with priority given to underground networks and the replacement of bare Low Voltage (LV) conductors

with twisted cables in traditional communities and special interest settlements (in terms of culture or

tourism). Indicatively, 1,140.28 km of bare Low Voltage cables were dismantled within 2022, while

1,845.43 km of twisted cables were installed in the network, with numerous environmental benefits such

as birdlife conservation and aesthetic enhancements, as well as improved network exploitation and loss

reduction.

A key component of the company's environmental strategy is preventing the loss of biodiversity and

protecting and preventing endangered species. It continues to take steps for improving networks in

locations where rare bird species live, including significant interventions with new technologies (e.g., it

participates in the program LIFE17 NAT/GR/000514 – LIFE Bonelli eastMed, for the conservation and

management of the Bonelli's eagle population in the Eastern Mediterranean, which provides for the

placement of special insulating covers at selected locations of the Medium Voltage (MV) overhead

network), in collaboration with competent bodies and organisations. The insulating covers were received

and passed quality control by the HEDNO SA's Monitoring and Acceptance Committee in 2022, with tests

at the Surveys and Standards Centre, before being sent to the Heraklion warehouse for installation in

Crete this year. In addition, it ensures the safe passage and stay of migratory species in our country and

cooperates with NGOs to protect our country's wildlife. HEDNO SA placed stork nests and assisted with

the maintenance of nests, as well as ringing Storks (Banding) in many places of Greece in 2022, in

collaboration with NGOs. In this regard, an agreement was reached in 2022 between the Ministry of

Environment and Energy, the Natural Environment and Climate Change Organization, and HEDNO SA,

and the signing of the Memorandum of Cooperation for the Support of Conservation and Conservation

Actions of Avifauna in Greek Protected Areas is expected. The MoU specifically addresses the

coordination, exchange of information and cooperation required to carry out the measures and actions

envisioned to prevent and combat potential threats to protected species of avifauna within protected areas

as a result of the development of the HEDNO SA networks. To that end, they have designated

conservation actions in eight NATURA 2000 network areas (Special Protection Areas - SPAs) as a shared

priority until 2023. The Cooperating Parties intend to establish and implement a coherent and effective

system for monitoring the mortality of protected bird species, and additional targeted actions, such as the

installation of appropriate covers on topside structures on localised electricity distribution poles, are

planned.

Finally, in 2022, it began receiving water-soluble preservative-impregnated hardwood poles, in

implementation of 2021 contracts, for installation in new overhead networks, in order to assess the

widespread use of poles free of creosote and composed of more environmentally friendly materials. In

this regard, the company signed a contract with a specialised consultant in 2022 to review the legal

framework governing the overall management of poles and to develop a plan of action based on best

practises at all stages of their life cycle in HEDNO SA networks and associated facilities, with a view to

employee safety and environmental protection.

PPC Renewables

Generation

Electricity generation in the year 2022 was 392,074MWh compared to 373,776MWh in 2022.

Investment activity

Wind Parks

The construction works of the Wind Park at the locations of “Aeras” of the Municipality of Mouzaki and

“Afentiko” of the Municipality of Argithea, of 27,6 MW, are on a full scale and are expected to be completed

by May 2023. Commencement of semi-commercial operation is planned for the third quarter of 2023.

Commencement of the semi-commercial operation is planned for the third quarter of 2023.

Construction works for the Doukas Wind Park, by the 100% subsidiary of PPC Renewables, “DOUKAS

AIOLIKO PARKO SOLE SHAREHOLDER s.a.”, with a capacity of 26MW, a total budget of €28 mil., in

the “DOUKAS” location of the St. Anargyroi, Kleisoura and Lehovo locations of the Municipalities of

Kastoria and Amyntaio, of the prefectures of Kastoria and Florina in the Region of Western Macedonia,

started in September 2022. Construction works are expected to be completed in December 2023.

Construction works for the Koukouli Wind Park, by the 100% subsidiary of PPC Renewables, “KOUKOULI

AIOLIKO PARKO SOLE SHAREHOLDER S.A.”, with a capacity of 13.2MW, a total budget of €14.6 mil.,

in the “Koukouli-Grivas” location in Shiatista of the Municipality of Voi, of the Kozani prefecture in the

Region of Western Macedonia, started in September 2022. Construction work is expected to be completed

in December 2023.

Small Hydro Plants

The commercial operation of the Small Hydropower Plant Louros (3X2.9 MW) was completed on

09.11.2021 (12-month warranty period). The adjacent Louros Substation final acceptance from HEDNO

– IPTO, with power increase at 40/50MVA, and new infrastructure is expected to take place during the 1st

quarter of 2023

The construction of the Smokovo II SHPP (3.2MW) is almost complete (project progress 99%) and the

Project has already been electrified. The operation of the SHPP depends on the release of sufficient

irrigation water. The Civil Works have been completed (building, intake pipe F1800, adjustment hopper,

etc.), while the Electromechanical Equipment of the Project has been fully installed and the

Interconnection Network has been completed by HEDNO S.A.

The construction of the Makrochori II SHPP (5MW) is in full progress (project progress 79%). Works for

the concreting of the powerhouse, the Forebay Canal and the Tailrace are underway. The project is

expected to be electrified in the 2nd quarter of 2023.

Photovoltaic Stations

Construction works from the 100% subsidiary of PPC Renewables “ILIAKA PARKA DYTIKIS

MAKEDONIAS ENA SINGLE-MEMBER S.A.” for the PV Plant of 14.99MW capacity, of a total budget of

€ 9.8 million at “Paliampela” plot, in the regional unit of Kozani have been completed and the PV station

was electrified on 03.07.2022.

Construction works from the 100% subsidiary of PPC Renewables “ILIAKA PARKA DYTIKIS

MAKEDONIAS DYO SINGLE-MEMBER S.A.”, for the PV Plant of 14.99MW capacity, of a total budget of

€ 11.8 million at “Xiropotamos” plot, in the regional unit of Kozani, have been completed and the PV station

was electrified on 31.07.2022.

Construction works from the 100% subsidiary of PPC Renewables “SOLAR ARROW ENA SINGLE-

MEMBER S.A.”, for the PV Plant of 200MW capacity, of a total budget of € 100.0 million at the “Lignitiko

Kentro Dytikis Makedonias” area, in the regional unit of Kozani, began in June 2021. It is expected that

the construction works will have been completed by March 2023.

Construction works of the PV Plants of 39MW and 11MW capacity, from the 100% subsidiaries of PPCR

“ARKADIAN SUN I SINGLE-MEMBER S.A.” and “ARKADIAN SUN II SINGLE-MEMBER S.A.”

respectively, with horizontal single-axis trackers, and a 33/150kV Substation, of a total budget of € 23.9

million, at “Megales Lakkes” plot, in the regional unit of Arcadia, began in September 2021. It is expected

that the construction works will have been completed by February 2023.

Construction works of the “Agios Christoforos 1" PV Plant of 64,983MW capacity with fixed tilt mounting

structure and the expansion works of the 150kV “Agios Christoforos” Substation through the addition of a

new 33/150kV transformer, of a total budget of € 31.8 million at “Agios Christoforos” plot, in the

Municipality of Eordea, Kozani Regional Unit, began in May 2022. It is expected that construction works

will be completed by July 2023.

Construction works of “Pteleonas 1”, “Pteleonas 2”, “Charavgi 1” and “Charavgi 5” PV Plants of

94.98122MW capacity, with horizontal single-axis trackers and bifacial PV modules and the extension of

the “Charavgy” 150kV substation, of a total budget of € 62.34 million, in the Municipalities of Eordea and

Kozani, at Kozani Regional Unit, began in September 2022. It is expected that by November 2023 all

works will have been completed.

With respect to the 550MW “Orychio DEI Ptolemaida” PV Plant, with horizontal single-axis trackers and

bifacial PV modules, and the necessary grid connection works, of an indicative total budget of € 216

million, in the Municipalities of Eordea and Kozani, at Kozani Regional Unit, the tender process has

proceeded with 6 participants and the Contractor is to be finalized. The signing of the Contract is expected

to take place within the 1st trimester of 2023.

Moreover, the joint tender process with the parent company DEI S.A. for the joint interconnection

substation (SPP Kardia) for PV Plants, Battery Systems and CHP with the 400kV EHV System (Kardia

Center) is to be completed within January 2023.

Cooperation with other Groups for the joint development of RES Projects

In January 2022 the process for the establishment of METON ENERGY SA (METON) was completed.

PPC Renewables contributed in kind nine (9) 100% subsidiaries (companies " Amyntaio ") and acquired

a 49% stake, while RWER contributed cash and acquired 51% stake in METON. The Amyntaio companies

develop photovoltaic projects of 940 MW capacity within the boundaries of ex Amyntaio lignite mine. . In

October 2022, following the agreement with PPC Renewables, RWER granted METON a call option to

acquire a portfolio of PV projects with a total capacity of about 710 MW under development in Central

Macedonia, which was exercised by METON.

Local agreements on the acquisition of RES projects

In June 2022, PPC Renewables purchased a portfolio of renewable energy sources (RES) projects with

a total capacity of 112MW from Volterra, a 100% subsidiary of AVAX.

More specifically, PPC Renewables acquired 55% of the shares of Volterra K-R SA and Volterra

Lykovouni SA, in which PPC Renewables had a 45% stake since 2019. Volterra K-R SA and Volterra

Lykovouni SA own Wind Parks with a total capacity of 69.7MW in Etoloakarnania and Viotia in Central

Greece. PPC Renewables also acquired 100% of Heliofaneia SA, which owns a 2,7 MW solar park in

Viotia, as well as Volterra Doukas SA and Volterra Koukouli SA, which own installation licenses for Wind

Parks with a total capacity of 39.5MW in Kozani and Kastoria in the Region of Western Macedonia (Note

3).

In December 2022, PPC Renewables purchased a renewable energy assets portfolio in operation with a

total capacity of 46MW from Piraeus Equity Partners, the investment arm of Piraeus Bank Group. PPC

Renewables acquired the shares of companies owning Wind Parks with an installed capacity of 44MW

located in the Peloponnese Region and a 2MW PV Plant in Thessaly.

International agreements on theacquisition of RES projects

As part of the Group's expansion in the Balkan region, PPC Renewables has signed an in-principle

agreement with MYTILINEOS in December 2022, for the development, construction and purchase of a

solar power portfolio of about 210MW located in Romania. The portfolio consists of two PV Plants of

130MW and 80MW respectively, which are expected to be in commercial operation during 2024. Both

projects have been developed by MYTILINEOS, who will also undertake construction scheduled to start

within 2023.

Significant events for the period January 1

2021 – December 31

2022

Significant events for the year 2022 are presented in detail in Note 3 of the Financial Statements.

Effects of the COVID-19 Pandemic

The COVID-19 pandemic continues in year 2022 to affect the global social and economic life. In Greece,

after the resumption of the restrictive measures from October 2020 until approximately the end of March

2021, from mid-April 2021 the restrictive measures gradually began to be lifted, as a result of the program

of massive vaccination applied, while there was an almost complete liberalization of the operation of

stores.

Due to the fact that the majority of the impacts mainly comes from the measures taken, both worldwide

and in Greece since mid-March 2020 to reduce the spread of the pandemic and to mitigate the economic

impact on businesses and individuals, the Group’s and the Parent Company’s operation has been

affected, initially causing short-term positive effects on their financial position, operating results and cash

flows, mainly due to the considerable decrease in oil and natural gas prices in 2020. In the medium to

long term, the pandemic has resulted in the delay or freezing of new energy investments, which at least

partially corresponds to the high prices of energy products (electricity, natural gas, oil, CO2 emission

allowances etc.), observed in 2021 and in 2022, combined with the strong global recovery in demand for

these energy products during 2021 and until mid 2022, as well as with the geopolitical frictions and the

Russia-Ukraine war (below section) that created nervousness in the energy markets and strong upward

trends in the prices of all energy products. In particular in Greece, after the recovery of electricity demand

observed in 2021 in the Interconnected System and continued in the first half of 2022, a significant

increase in electricity prices in the Day-ahead Market was observed, which in combination with the

increase in prices for emission allowances CO2 and natural gas, contributed to the increase of the energy

balance cost of both Greece and PPC for this period. It is noted that from July 2022 until today, a significant

decrease in electricity demand in the Interconnected System has been observed, which is related on the

one hand to the prevailing mild weather conditions and on the other hand to the reasonable reaction of

consumers to the very high prices of electricity.

The Group and the Parent Company implemented a series of actions aimed at informing employees,

raising their awareness of prevention and protection measures, providing them with appropriate Personal

Protection Measures (PPE), protecting both them and their families and at the same time ensuring the

smooth operation of their activities. They also took emergency measures to energy consumers due to the

pandemic, as mentioned in the Commercial Policy section in Note 3 of the financial statements.

However in any case, the Group’s and the Parent Company’s Management monitors constantly the

developments of the COVID-19 pandemic and evaluates any possible further effects on the operation,

financial position and results of the Group and the Parent Company, being alert to take further appropriate

precautionary measures to safeguard the Group’s and the Parent Company’s liquidity and business

activities.

War Russia-Ukraine

The current geopolitical crisis in Ukraine, combined with the economic sanctions imposed on Russia by

the European Union and the United States of America, have created conditions of uncertainty in the

economic environment at European and global level.

PPC Group does not have a relevant commercial presence in Russia and Ukraine and as a result there

is no direct effect on its activities, but the indirect effect, as it develops, is particularly important.

The increased costs in the wholesale electricity market due to the unprecedented increase in the price of

natural gas is a development that indirectly affects the activities of the Group, which is, however, largely

protected by the vertically integrated nature of its activities, due to its presence in both generation and

supply of electricity. The aforementioned protection of the Group due to its vertically integrated nature is

mitigated to some extent, as a consequence of the Temporary Mechanism of Law 4971/2022 (Article 122)

for Returning Part of Income of the Next Day Energy Market. Based on this Mechanism, which is valid

during the period 8/7/2022-1/6/2023, the power generation units of the Interconnected System (except

Crete) is compensated in the Day-Ahead Market based on regulated prices as defined by Ministerial

Decision (practical part of their income from the Day-Ahead Market is withheld, with which the special

account "Energy Transition Fund" is financed). With the above Mechanism, the income of Generation in

the Day-Ahead Market arises based on the variable cost of the units (cost plus), while the costs of Supply

in the same Market arise based on the Clearing Price of this Market.

As an emergency measure to strengthen the energy sufficiency of the country and reduce the supply of

natural gas from Russia, the PPC Group launched within 2022 the increase of lignite production,

contributing to the adequacy of the country's electrical system for the period of the energy crisis, through

a review of the mining planning and by changing the estimated withdrawal plan of the lignite units, with a

slight extension of it, depending on the market conditions.

In addition, indirect effects may arise due to the consequent reduction of our customers' disposable

income, as a result of increased energy costs and the intensification of inflationary pressures. As

mentioned, already in the previous paragraph, there is a significant decrease in electricity demand during

the second half of 2022, which is partly attributed to the increased energy costs.

MAJOR RISKS - UNCERTAINTIES

The Group’s and the Parent Company’s activities are subject to various risks. Any of the following risks

could have a material adverse effect on the Group’s and the Parent Company’s business, financial

position or results. The risks described below are not the only risks that the Group and the Parent

Company face. Additional risks and uncertainties not currently known to the Group and the Parent

Company or that are currently deemed to be immaterial may also materially adversely affect in the future

their business, financial position, results and cash flows. The order in which the risks are presented does

not necessarily reflect the likelihood of their occurrence or the magnitude of their potential impact.

-Market risk

The Group and the Parent Company participate in the Greek energy wholesale market both as producer

and as supplier of electricity, which exposes them to market price risk stemming from fluctuations in the

prices of natural gas, oil and CO2 emission rights, which are traded in international commodity markets,

as well as to the fluctuations of the electric power prices, which is traded in the Greek market. Significant

fluctuations in the prices or quantities of electricity, natural gas, fuels and CO2 emission rights affect,

directly or indirectly through the effect on the price of the Greek wholesale energy market, the financial

position, results and cash flows of the Group and the Parent Company as well as their business activities

and prospects.

For the period until June 2023, according to Law 4951/2022, the clearing of the wholesale energy market

was changed with the establishment of a "Temporary Mechanism for the Return of Part of Producers'

Revenues in the Day Ahead Market". The mechanism was then extended into the Intra-Day Market.

Energy producers are compensated at a price that cannot exceed a regulatory cap (regulated price) for

each class of power generation units, which is calculated on a monthly basis by the Day Ahead Market

Clearing Agency. This regulatory cap is such that in most cases the power generation units are

compensated based on it and not according to the Day Ahead Market Clearing Price. The regulated price

for Large Hydroelectric Power Plants (HPP) and Renewable Energy Sources (RES) Portfolios has been

set fixed, while the regulated price for thermal units reflects the variable production cost of these units.

For the same period, also in accordance with Law 4951/2022, Suppliers are not allowed to apply clauses

linked to the fluctuation of wholesale market sizes and are obliged to announce their energy supply price

list on a monthly basis, while at the same time customers have the possibility to freely choose and change

free of charge their Supplier and/or the type of supply tariff.

In order to limit the Group and Parent Company’s exposure to market risk, they have adopted risk

management policies for the management of price risk in line with limits and targets assigned by the senior

management. Hedging activities typically entail the use of derivatives instruments to reduce the risk.

Nevertheless, their exposure to these risks has not been eliminated and they may not manage to

adequately hedge against volatility in commodity prices and volatility in wholesale power market prices,

either because of low liquidity in the Forward Electricity Market, or because of other reasons. Moreover,

the execution of hedging activities through their participation in organised commodity exchanges is

creating new needs for credit and cash settlement requirements, as well as for cash margining to cover

adverse price movements or stop-loss procedures, which could result in significant liquidity needs.

-External environment risks

Macroeconomic conditions in Greece

Substantially all of the Group and Parent Company’s assets and operations are in Greece and thus

Greece’s economic situation is anticipated to be reflected in the Group and Parent Company’s business.

The Group and Parent Company’s business activities and results of operations are highly dependent on

residential and business demand for electricity in Greece, as well as their customers’ ability to pay their

electricity bills in a timely manner. Electricity consumption in Greece is heavily dependent on levels of

disposable income, spending capacity and employment trends, as well as the availability and cost of

funding for their industrial and commercial customers.

Any potential future deterioration in economic activity in Greece could result in a decrease in demand for

the electricity the Group and Parent Company’s supply and/or generate an increase in unpaid and overdue

bills and provisions for expected credit losses, which could adversely affect the Group and Parent

Company’s business, financial condition and results of operations.

European economic and political developments

In the ordinary course of the Group and Parent Company’s business, they are exposed to the risk of a

reduction in demand for electricity, which may occur as a result of global financial and economic

uncertainty. The COVID-19 pandemic, the energy crisis and the war in Ukraine have adversely affected

economic activity. The imposition of sanctions, due to the war between Russia and Ukraine, has a

negative impact on both energy and financial markets due to the impact on quantities and prices of energy

goods, mainly electricity and gas. Any changes in global commodity prices, available cross-border

capacities, material changes in electricity demand in Europe or a possible disruption of natural gas supply,

could have an impact on electricity prices and a material adverse effect on the Group and Parent

Company’s business.

Supply chain risk

The Group and Parent Company face risks relating to the construction of their electricity generation units,

including risks relating to the availability of equipment from suppliers, availability of building materials and

key components, availability of key and qualified engineering personnel, delays in construction timetables

and completion of the projects within budget and to required specifications. Additionally, adverse

macroeconomic developments, as well as financial and/or operating problems of key suppliers and

contractors may have a negative impact on the Group and Parent Company’s ability to purchase liquid

fuels, spare parts and materials and may increase their operating expenses.

Assumptions and hypotheses risk

The Group and Parent Company have established targets for medium- and long-term financial

performance, all of which assume, inter alia, the successful and timely execution of the transformation

strategy and five- year business plan. The management of the Group and the Parent Company has based

these targets on a number of assumptions and hypotheses that are inherently subject to significant

business, operational, economic, financial and other risks, many of which are outside of the Group and

Parent Company’s control. Should one or more of the assumptions underlying the targets for financial

performance change or prove to be incorrect, the Group and Parent Company’s actual medium- to long-

term financial performance could differ materially from the targeted medium- to long-term financial

performance.

-Regulatory & legislative developments, political and tax risk

The Group and Parent Company’s operations are subject to extensive and complex regulation, which

impacts many areas of their business, including the sources of their power generation activity, the overall

energy market structure, the construction and operation of electricity generation facilities, the trading of

commodities and financial derivatives, market behaviour rules, present or prospective wholesale or retail

competition and general health and safety and environmental matters. These rules and policies have

affected and may continue to affect the Group and Parent Company’s business, and any changes in law

or regulation, or decisions by governmental bodies or regulators, could negatively affect their business

and performance. Accordingly, the Parent Company closely monitors legislative and regulatory

developments, such as:

• The revision of the European Target Model, which may cause a significant structural reform of

the existing organization system of the wholesale electricity market.

• The procedures for obtaining and/or renewing licenses necessary for the operation of the Parent

Company and the Group (indicatively, mining, production, distribution and trading of electric

energy)

• Regulatory changes by the Hellenic State or the Regulatory Authority for Energy (RAE) (e.g.

those concerning pricing policies of energy suppliers).

• Regulatory changes by the European Commission and other EU institutions (e.g. European rules

on competition and environment, promotion of the integration of European electricity markets,

development of renewable energy sources and promotion of sustainable energy investments.

etc.).

• Environmental regulations based on provisions in accordance with Greek legislation, including

laws issued for the implementation of EU Directives and international agreements (e.g.

regulations for exhaust emissions, mine rehabilitation, waste disposal, management and

remediation of water pollution incidents).

• The tax regime (e.g. imposition of any new taxes, fees or contributions or the change in the

interpretation or application of tax provisions by the tax authorities), as well as the harmonization

of Greek and European tax legislation.

There are also an inherent risk that governmental or regulatory authorities will interpret or apply laws and

regulations in a manner the Group and Parent Company do not expect or agree with. The Group and

Parent Company have in the past disputed adverse or unfavourable decisions of administrative, regulatory

and judicial authorities, and similar matters may become subject to disputes with competent authorities in

the future. Adverse regulatory decisions, interpretations or administrative actions, as well as institutional

resistance, could have uncertain and unexpected consequences on the Group and Parent Company’s

business and operations, which, in turn, could have a material adverse effect on their financial condition.

In order to manage the legal and regulatory risks, the Parent Company has strengthened its relations with

national and local Authorities and regulatory bodies, adopting a transparent and cooperative approach to

address and eliminate sources of instability in legislative and regulatory framework. However, the Parent

Company cannot provide any assurance that it will always be in a position to fully and timely satisfy the

regulatory, environmental, financial and any other requirements imposed, which could have a significant

adverse effect on the Group and Parent Company’s business, financial position and operating results.

Licensing risk

The Group and the Parent Company’s mining, generation, distribution and supply of electricity operations

require various administrative authorisations at local, regional and national levels, that can be protracted,

complex and not entirely predictable. Additionally, any failure to obtain or renew the necessary licences

and permits might result in interruptions to some of the Group and the Parent Company’s operations,

including their ability to obtain funding for their activities. Delays, high costs or the suspension of the Group

and the Parent Company’s industrial activities due to their inability to obtain, maintain, or renew

authorisations, may also have a negative impact on their business activities and profitability.

For the Group’s renewable energy projects any failure or delay to obtain or delay in obtaining the

necessary authorisations, permits or licences, or to enter into the procurement or construction agreements

or delays in establishing the connection with the Distribution Network could materially affect the timeline

for increased renewable energy generation capacity and have an adverse impact on the Group and Parent

Company’s business, operations, prospects, financial condition and results of operations.

-Cybersecurity and information technology risk

A large portion of the Group and Parent Company’s operations is based on IT systems and they are

exposed to risks such as non- availability of systems, data integrity corruption, power disruptions,

malicious cyber-attacks and unauthorised access to these systems. The frequency, sophistication,

success rate and magnitude of cyber-attacks against critical infrastructure organisations worldwide

continued to increase during 2022 and especially since the Ukranian-Russian crisis began.

In order to minimise these risks, the Group and Parent Company take measures for the enhancement of

their IT security, such as defining and continuously updating their IT security policies and standards and

covering their IT systems by maintenance contracts. As a possible incident in the Company's cyber space

could impact both the business continuity of the organization and the wider energy market of the country,

the Parent Company treats cybersecurity as a priority corporate risk and continuously invests in

safeguarding both its informational and operational technological environments. In this context, the Parent

Company has completed an extended cybersecurity transformation program which has enabled the

organization to integrate cybersecurity into its strategy, structure and operation, from the development of

new digital products and services to the protection of personal data and information and operational

systems.

The Group and Parent Company believe that they currently have adequate security policies in place to

cover risks associated with the operation and maintenance of their IT infrastructure and perform regular

audits of the security of their systems. However, there can be no assurances that they will be able to

prevent technology failures, IT security breaches or malicious cyber-attacks in a timely manner or continue

to have adequate insurance coverage to compensate for related losses (including litigation claims, liability

and data loss), which could disrupt their operations or harm their reputation and have a materially adverse

effect their business.

-Social pressure due to increased energy prices

The Parent Company’s ability to formulate its tariffs is limited by (i) current socioeconomic conditions in

Greece, (ii) the ability of its customers to cope with new tariffs and pay their bills, (iii) decisions of RAE

and/or strategic initiatives of the Greek government and especially (iv) the form and the size of consumer

support measures by the State. If any new proposed tariff structures are not well received and accepted

by customers, changes in their ability or willingness to pay their electricity bills may be negatively

impacted, which could in turn negatively affect the collectability of the Parent Company’s bills.

Furthermore, a significant part of the Group and Parent Company’s revenue depends on regulated

charges. Such regulated charges are set by RAE and reviewed periodically every four years. The Greek

government and/or RAE may decide to limit or reject increases in regulated charges or may change the

conditions of access to such regulated charges. Despite having adequate visibility over RAE’s changes

in regulated charges with respect to RAE's changes in regulated charges, any changes in regulated

charges that may affect electricity distribution revenues could have a material adverse effect on the

financial position of the Group and the Parent Company, as well as hinder their ability to raise equity or

loan funds to finance their investment projects.

-Financial risks

The Group's and the Parent's future operating performance and ability to generate cash from operations,

to make payments on and refinance their indebtedness and to fund working capital expenditure and other

expenses is affected, in large part, by general economic, competitive, legislative and regulatory factors

and other factors that are beyond their control. Any refinancing of the Group and the Parent Company’s

indebtedness could be at higher interest rates than their current debt and it may be required to comply

with more onerous financial and other covenants, which could further restrict their business operations

and may have a material adverse effect on their business, financial condition, results of operations and

prospects.

Implementation of Investment Plan

The Group and Parent Company have significant construction and capital investment requirements. A

significant increase in the costs of or delays in executing their investment plan, occurring before and/or

after capital has been committed, could have a material adverse effect on the Group and Parent

Company’s ability to achieve their growth targets, their business, financial condition, prospects or results

of operations.

Working Capital

The Group and the Parent Company face working capital risk, due to the nature of the energy market

(price volatility, customer trading behavior) which may lead to additional liquidity requirements. The Group

and the Parent Company may also face, following decisions by the Regulator, increased working capital

requirements in relation to their payments to and from other market operators and increased capital

expenditure, that could have a significant effect on their liquidity.

Credit Risk

On the date of publication of these financial statements, the Group and the Parent Company have a credit

rating of BB- with stable outlook by Standard & Poor’s, ΒB- from ICAP and BB- with a stable outlook by

Fitch Ratings Inc. Their ratings reflect the respective rating agencies’ opinions of their financial strength,

operating performance and ability to meet their debt obligations as they become due.

Interest Rate Fluctuation

The Group and the Parent Company’s debt obligations consist of bank loans, bonds and overdrafts. It is

their policy to have a balanced distribution of the loan portfolio between fixed and variable interest rates

according to the prevailing conditions and to hedge on a case-by-case basis through derivatives, solely

to mitigate risk, against the fluctuation of floating interest. All of their indebtedness is denominated in euro.

Exchange Rate

The fluctuation of the euro against U.S. dollar exchange rate may adversely impact the prices of the Parent

Company’s liquid fuel purchases (diesel and heavy fuel oil) and the price of natural gas purchases. As oil

prices are denominated in U.S. dollars, the Parent Company is exposed to foreign currency risk in the

event of an appreciation of the U.S. dollar against the euro. In order to mitigate the foreign currency risk

arising from liquid fuel purchases, the Parent Company examines the possibility of undertaking hedging

transactions for this risk. There is no assurance that such undertaken hedging transactions will provide

full or adequate protection against these risks.

Loan Covenants

Certain agreements governing the Group and the Parent Company’s existing indebtedness contain

covenants that impose restrictions on the way they can operate and require the achievement -

maintenance of specific financial indicators. These covenants could limit the Group and the Parent

Company’s ability to finance future operations and capital needs and their ability to pursue acquisitions

and other business activities that may be in their interest. The Group and the Parent Company’s ability to

comply with these covenants and restrictions may be affected by events beyond their control, such as

prevailing economic, financial and business conditions.

-Local community reaction

The Group and Parent Company may experience local opposition, which they may not be able to

overcome on a timely basis, if at all, in order to obtain the necessary licences, permits and financing for

the execution of new projects. Various groups may publicly oppose certain development projects. This

opposition, along with political developments, could hinder or prevent the development of such projects,

which could have an adverse effect on the Group and Parent Company’s business, financial condition

and results of operations.

-Risks related to the position and market share of PPC in the energy market

Over the last decade the Group and Parent Company have been subject to regulatory interventions and/or

proceedings initiated by European authorities (e.g. European Commission) and/or the Greek government

with respect to, among others, the reduction of the Group and Parent Company’s market share in the

wholesale and supply electricity market and its position as the only vertically integrated electricity producer

and supplier with exclusive access to certain types of power generation, such as lignite.

Such measures or reforms, the introduction of new laws and/or regulatory mechanisms in the electricity

market or other adverse changes in the competitive landscape in the supply market and/or production,

may have a negative impact on results of operation and cash flows. The reduction of the Parent

Company’s supply market share in conjunction with the absence of conditions for effective competition

and the potentially imbalanced participation of suppliers in the market may also have a negative impact

on the Groups and Parent Company’s results of operation and financial condition in future periods.

The European Commission has acknowledged, in Greece’s increased surveillance report of November

2020, a continued downward trend of the Parent's share of electricity supply which was 62.29% in the

Interconnected System on 31 December 2022. The Group and Parent Company may be made subject to

further structural, financial or other measures if they were to be found to have failed in reducing the supply

market share. If any such circumstance was to occur, the Group and Parent Company’s financial condition

could be adversely affected.

There have been several regulatory interventions with respect to Parent Company’s exclusive access to

lignite. As a result of Greece’s conviction regarding the lignite power exclusivity (the “Anti-Trust Case”),

an EU Decision was finally issued (10.9.2021), according to which a new mechanism was implemented

for the next three years during which the Parent Company must obtain the position of electricity power

seller position in the Forward Market of the Hellenic Energy Exchange and/or the European Energy

Exchange.

The remedies will lapse when existing lignite plants stop operating at the latest, by 31 December 2024.

The above remediating measures may have a material adverse effect on the financial position of the

Group and the Parent Company.

In February 2017, an investigation for possible abuse of the Parent Company’s position in the wholesale

power market was initiated by DG Competition under Article 102 TFEU and is currently under way. There

has been no definitive indication as to the timing of this investigation and there is no guarantee about the

outcome of this investigation and/or the possibility of extending the scope of this investigation to other

market segments. In case DG Competition decides that the Parent Company has breached competition

law, then penalties and/ or remedies may be imposed on it, which may have an adverse impact on its

business, financial condition and results of operations.

-Impairments, provisions and accounting assumptions risk

The Group and the Parent Company are exposed to risks that affect the value of their assets, such as in

particular their receivables, fixed assets or their participation in the share capital of subsidiaries and

related companies. In the future, the value of the Group's and the Parent Company's property, plant and

equipment and their participation in the share capital of subsidiaries and related companies may be

significantly impaired due to the early withdrawal of units, the obligation to maintain units in cold or

strategic reserve without adequate compensation or the loss competitiveness due to legislative or

regulatory changes or other circumstances beyond their control. In addition, changes in International

Financial Reporting Standards (IFRS) or their application may significantly affect the value of their assets

or liabilities.

-Insufficient compensation for the provision of Public Service Obligations

The companies of the Group and the Parent Company, which provide Public Service Obligations (PSOs)

according to the definitions of no. PD5/IL/B/Φ1B/12924 of the decision of the Minister of Development

"Determination of Public Service Obligations" (OG B' 1040/25.06.2007), as amended and in force, are

entitled, as are all others Electricity suppliers who are obliged to provide said services, to receive

compensation to cover the costs of providing these services. In accordance with the current regulatory

framework, this compensation is based on the cost of providing the above PSOs borne by the service

providers and is calculated according to the methodology established by RAE decisions. Possible

amendments in the right to receive compensation for the existing provision obligations of PSOs or

changes in the approved methodology for calculating the compensation for the provision of the above

PSOs or raising of objections by the European Commission regarding the hedging measure for the

provision of PSOs in the Non-Interconnected Islands for the period from 17.02.2019 onwards, in

accordance with the EU rules on state aid, which may lead to under recovery of their costs or to the non-

recognition of the right to receive compensation for the provision of PSOs for previous years or potential

introduction of new PSOs for which may not be entitled to full recovery of the relevant costs, may have

negative effects on the costs, financial position, results of operations and cash flows of the Group

companies and the Parent Company.

-Risks related to the lignite phase-out process

The Group and the Parent Company may incur increased costs in relation to the decommissioning of

power plants and the closure and reclamation of their mines, the rehabilitation of any damages related to

the operation or their plants or mines and the decommissioning of their equipment and facilities. Since

they are involved in open pit mining operations, they are required by Greek law to remediate land affected

by their mining operations and, further, to have in place cash reserves for works relating to open pit mine

reclamation. Furthermore, as an owner and operator of electricity generation and distribution facilities,

they may incur in the future significant costs and expenses in connection with the decommissioning of

such facilities, which could have a material adverse effect on the Group and the Parent Company’s

business, results of operations, financial condition and cash flows.

-Health and safety risks

The Group and Parent Company’s operations are susceptible to industrial accidents, and employees or

third parties may suffer bodily injury or death as a result of such accidents. In particular, while the Group

and Parent Company believe that their equipment has been well designed and manufactured and is

subject to rigorous quality and assurance control tests, and that its operation and maintenance are in

compliance with applicable health and safety standards and regulation, there can be no assurance that

accidents will not result during the installation maintenance and operation of this equipment.

-Business interruption risk

Power plants, facilities, distribution infrastructure and the information systems controlling these facilities

are subject to failure, breakdowns, unplanned outages, capacity limitations, system loss, security

breaches or physical damage due to natural disasters (such as storms, floods, fires, explosions,

landslides, slope ruptures or earthquakes), sabotage, terrorism, human error, strikes, catastrophic

accidents, IT viruses, fuel supply interruptions, problems in the transmission and distribution networks of

electric energy of natural gas, criminal acts, wars and other catastrophic events.

The occurrence of any of the above is likely to shut down the operation of electricity generation or

distribution infrastructure, in the Interconnected System or the Non-Interconnected Islands, which may

have a direct adverse impact on the profitability of the Group and Parent Company’s activities, as a loss

of revenue, high remediation cost and/or obligation to indemnify third parties.

-Environmental risks

The nature of the activities of the Group and the Parent Company may affect the natural and man-made

environment of their installation/operation area and are thus subject to environmental licensing. Decisions

Approving Environmental Conditions (DAEC) are issued by the competent public authorities, are renewed

or amended periodically and contain conditions for the systematic monitoring of their observance.

In addition, technological and scientific advancements bring changes in the legislative and regulatory

framework and, therefore, impose the technical adaptation of the power generation infrastructure to them

and affect the strategic, business and financial planning of the Group and the Parent Company.

Compliance with environmental legislation may burden the Group and the Parent Company with additional

costs, especially when it is necessary to implement preventive or remedial measures. In some cases,

environmental reasons may require the limitation or even termination of existing activities or projects. In

addition, in the normal course of carrying out their business activity, the Group and the Parent Company

are exposed to legal disputes with an environmental starting point.

Non-compliance with the legislative and regulatory environmental framework or non-compliance with the

conditions of environmental licenses entails the imposition of administrative sanctions (which can range

from the imposition of a monetary fine to the revocation of the license to operate a power generation

infrastructure), the raising of civil claims and the attribution of criminal liability to the Group and Parent

Company and expose them to negative publicity and significant damage to their reputation.

-Transformation risks

The Group and the Parent Company have committed to implement one of the largest investment plans in

Greece, including investments in RES with a total capacity of approximately 10.0 GW. The Group and

Parent Company expect to finance a substantial part of these capital investments out of the cash flows

from operating activities as well as the increase of the Parent Company’s Share Capital in 2021. However,

if these sources are insufficient, additional external sources of funding may need to be sought. Although

the Group and Parent Company have entered into long-term financing agreements for major projects and,

historically, the European Investment Bank has financed a major part of generation and Distribution

Network projects, no assurance can be given that they will be able to raise the financing required for the

planned capital investments on acceptable terms or at all. In such a case, they may have to reduce their

planned capital investments.

Τhe Group and Parent Company face risks that are associated with expanding their operations, integrating

newly acquired subsidiaries or participating in joint venture projects where they have granted protective

rights to minority shareholders or which they do not manage or otherwise control. Acquisitions and

participations in joint ventures may subject them to liabilities of which they are unaware of or have not

correctly assessed or against which they have not obtained full legal protection. While the Group and

Parent Company intend to undertake due diligence reviews in relation to acquisitions and joint ventures,

such reviews may not reveal all existing or potential risks and liabilities. In addition, as a result of the

above acquisitions, mergers and participations, a new business structure will emerge, with an expanded

scope of work compared to the past, the effective management of which will require the transformation of

the current administrative structures, corporate governance processes, business processes (e.g.

procurement processes, customer management, etc.) and information systems, which has significant

financial and human capital requirements.

In order to maintain and expand the Group and Parent Company’s business, they need to train, retain and

recruit executive management and qualified technical personnel. In cases where employees, with

specilialised skills and experience, leave the Group and the Parent Company, they may have difficulty in

replacing them. Any difficulties in retaining or recruiting a sufficient number of experienced, capable and

reliable personnel with appropriate professional qualifications, especially in senior and middle

management positions, or in finding qualified professional and technical staff, could limit or delay efforts

to develop and affect the business activities of the Group and the Parent Company.

Sustainability targets and obligations:

Group and Parent Company’s strategy is in line with the European Union’s and Greece’s ambitious

medium- and long-term objectives for climate neutrality by 2050, including the new and most immediate

target for reducing greenhouse gas (“GHG”) emissions and increasing RES capacity and use by 2030. To

this end, the Group and Parent Company support the “Green Deal” in power generation, via the

acceleration of the decommissioning of all their lignite units and respective mines, expanding and

establishing RES as their dominant energy generation technology and assisting in the advancement of

electromobility in Greece.

Although, the Group and Parent Company target increasing the proportion of their total installed capacity

generated by renewable sources and intend to satisfy the Sustainability Performance Target in respect of

the year ended 31 December 2023, there can be no assurance of the extent to which the will be successful

in doing so or that any future investments they make in furtherance of this target will meet investor

expectations or any binding or non-binding legal standards regarding sustainability performance. Adverse

environmental or social impacts may occur during the design, construction and operation of any

investments the Group and Parent Company make in furtherance of this target or such investments may

be criticised by activist groups or other stakeholders, which may cause harm to their reputation.

In addition, meeting the Group and Parent Company’s sustainability targets may limit the options available

to them operationally and commercially, as not all potential courses of action in relation to investments

and business opportunities will be in alignment with such targets.

If the Group and Parent Company fail to meet their sustainability targets, which may coincide with

regulatory requirements, they may be exposed to sanctions, it may harm their relationship with their

existing shareholders and bondholders, as well as discourage new investors, customers and potential

business partners. Moreover, given that an increasing number of financiers incorporate sustainability-

linked requirements in their financing arrangements, the Group and Parent Company’s inability or failure

to meet such requirements could make it more difficult for them to obtain financing on favourable terms

or trigger contingent obligations in any such financing arrangement, which they may enter into in the

future.

In light of the above, being subject to sustainability-related obligations may carry consequences, which

could, have an impact on the Group and Parent Company’s business, financial position and results of

operations.

-Climate change risk

Climate change and the societal and political response to it may have a significant impact on the Group

and Parent Company’s activities. According to the guidance issued by the “Task Force on Climate-related

Financial Disclosures” (TCFD), the Group and Parent Company classify climate-related risks into two

major categories: risks related to the transition to a lower-carbon economy and risks related to the physical

impacts of climate change.

Risks related to the transition to a net-zero GHG emission economy include risks related to the adoption

of strategies and decisions to prevent and mitigate the effect of climate change (such as the introduction

of regulatory incentives and penalties, carbon pricing systems, energy efficiency solutions and low carbon

products and services). The implementation of policies to promote carbon reduction may significantly

impact the operations and value of the Group’s thermal plants. While the Group is actively implementing

its decarbonisation strategy and the adjustment, in scientific terms, with the target of the Paris Treaty

(1.5˚C temperature increase compared to pre-industrial levels), the Group remains dependent on its

conventional generation units for the bulk of its electricity production. If the Group and Parent Company

are not successful in the rollout of their renewable pipeline, which is included in their portfolio, they will

face challenges from the anticipated hostile regulatory environment and strong competition from greener

and more modern electricity producers.

Risks related to the physical impacts of climate change include risks that are triggered by changes in

mean temperatures, changes in wind, rainfall and solar radiation patterns as well as increase of the sea

level. The extreme weather events caused by climate change could also significantly affect the

consumption of energy, the conventional and renewable generation, as well as the resilience and

performance of the Distribution Network.

The revenues of the Group and the Parent Company reflect the seasonality of electricity demand and may

be adversely affected by significant fluctuations in climatic conditions. In addition, changes in hydrological

conditions may lead the Group and the Parent Company to make up for the reduced electricity produced

by their hydroelectric plants, especially during periods of increased demand, by using other means of

energy production at a higher cost or by resorting to the wholesale market at higher prices.

While the Group and Parent Company follow and regularly assess such risks and their response to them

at both management and Board of Directors level, they may not be able to predict, mitigate or adapt to

the medium or long-term physical changes associated with some climate change risks.

-Legal and regulatory risks

General Data Protection Regulation

The General Data Protection Regulation (“GDPR”) implements stringent operational requirements for

processors and controllers of personal data. The Group and the Parent Company operate in an sector in

which they process a considerable amount of personal data and therefore are inevitably exposed to the

risk of non-compliance. Any inability to adequately address data protection and/or privacy concerns, even

if unfounded, or comply with applicable privacy or data protection laws, regulations and policies, could

result in additional cost and liability to the Group and the Parent Company, damage their reputation, and

adversely affect their business.

Litigation risk

The Group and the Parent Company are defendants in a significant number of legal proceedings arising

from their operations which, if determined unfavorably, could have a material adverse effect on their

business, financial position and results, or reputation. In addition, the Group and the Parent Company are

one of the largest listed industrial groups in Greece, with complex activities and operations across the

country in heavily regulated industry sectors. Violations of such legislations, including rules and

regulations of regulatory authorities, entail, among others, administrative fines and criminal sanctions for

the Board of Directors, employees and utilities that are subject to those rules.

-Counterparty risk

The Group and Parent Company are exposed to the risk that counterparties that owe them financial

instruments, energy or other commodities as a result of market transactions will not fulfil their obligations.

The Group and Parent Company also face the risk of potential default or delay by their counterparties,

which include their partners, contractors, subcontractors and suppliers.

Furthermore, the Parent Company may experience difficulties or delays in collecting outstanding debt

from Low, Medium and High Voltage customers. The inability of customers to pay in full and timely

amounts billed in relation to their electricity consumption, the increased availability of competitors’ offers,

or the outcome of negotiations with Medium and High Voltage industrial customers in key economic

sectors in Greece on financial and other terms for extending their contracts, may have an adverse effect

on the Group and Parent Company’s business, financial condition and results of operations.

Any default by their counterparties may affect Group and Parent Company’s financial results, the cost and

completion of their projects, the quality of their services, or expose them to reputational risk, business

continuity risk and the risk of loss of important contracts, as well as to substantial additional costs,

particularly in cases where they would have to pay contractual penalties, to enter into alternative hedging

arrangements or honour the underlying commitment at then-current market prices, to find alternative

counterparties or complete the respective projects by their own means.

-Asset protection risks

The Group and the Parent Company have an extensive network of facilities (mining facilities, power plants,

distribution infrastructure, administrative buildings), that cover a large area and are geographically

dispersed. The Group and Parent Company’s physical assets are vulnerable to a range of threats such

as theft, vandalism, security breaches, sabotage and terrorism. The above threats can lead to significant

financial losses as well as risks to the safety and operation of the Group and the Parent Company. The

Parent Company implements a comprehensive physical security program that includes relevant policies

and procedures, monitoring systems, regularly trained security personnel, and emergency response

procedures to minimize the risk of loss or damage to its physical assets.

-Risk from potential undertaking of social security liabilities

Despite the fact that the Group and the Parent Company estimate that they have no obligation under

existing laws to cover any potential future differences between the total income of EFKA and the payment

obligations assumed by the Hellenic State relating to the Group and the Parent Company’s retired

personnel, there can be no assurance that the existing social security laws will not change, or that the

Group and the Parent Company will not be required in the future, by law or otherwise, to contribute or

provide significant additional funds or assets to EFKA.

Balances and Transactions With Related Parties

PPC balances with its subsidiaries as of December 31

, 2022 and December 31

, 2021 are as follows:

December 31, 2022

Amounts in ‘000€

December 31, 2021

Amounts in ‘000€

Receivables

(Payables)

Receivables

(Payables)

Subsidiaries

PPC Renewables S.A.

2,879

(92)

1,814

(399)

HEDNO S.A.

140,193

(248,802)

221,202

(380,849)

LIGNITIKI MEGALOPOLIS Sole Shareholder S.A.

25,885

(684)

LIGNITIKI MELITIS Sole Shareholder S.A.

20,999

ILIAKA PARKA ENA S.A

ILIAKA PARKA DIO S.A

SOLAR ARROW ENA S.A

143

ARKADIAN SUN ENA S.A

ARKADIAN SUN DIO S.A

AMYNTAIO PV Park ONE Sole Shareholder S.A.

AMYNTAIO PV Park TWO Sole Shareholder S.A.

AMYNTAIO PV Park THREE Sole Shareholder S.A.

AMYNTAIO PV Park FOUR Sole Shareholder S.A.

AMYNTAIO PV Park FIVE Sole Shareholder SA.

AMYNTAIO PV Park SIX Sole Shareholder S.A.

AMYNTAIO PV Park SEVEN Sole Shareholder S.A.

AMYNTAIO PV Park EIGHT Sole Shareholder S.A.

AMYNTAIO PV Park NINE Sole Shareholder S.A.

CARGE S.A

711

PPC Finance Plc.

(118)

(71)

PPC Elektrik

151

110

PPC Bulgaria JSCO

(374)

PPC Albania

EDS AD Skopje

54,115

20,026

Total

198,123

(249,012)

290,277

(382,377)

As of December 31, 2021, the Parent company had a claim from the subsidiary HEDNO SA amounting to

€ 43.4 million due to repayment of loans on behalf of the subsidiary, which were contributed to it due to

the spin-off of the Distribution Network from PPC S.A. to HEDNO SA.

Within the first half of 2022, a dividend of €85 million was approved by the subsidiary company HEDNO

S.A. of which € 41.65 million was attributable to the minority shareholders for the year ended December

31, 2021. The dividend attributable to the Parent amounting to € 43.35 million was collected within the

third quarter of 2022.

Respectively, within the first half of 2021, a dividend of € 6.7 million was approved by the subsidiary

HEDNO SA. from profits for the year ended December 31, 2020, which was paid to the Parent Company

on September 6, 2021.

On December 31

, 2021, the Parent Company recognized a provision of expected credit losses on trade

receivables and other accrued income for the subsidiaries “Lignitiki Megalopolis S.A.” and “Lignitiki Melitis

S.A.” amounting to €25.2 million and €20.9 million respectively.

Due to the absorption of the lignite subsidiaries Lignitiki Megalopolis S.A. and Lignitiki Melitis S.A. from

the Parent company on June 1, 2022, on December 31, 2022 there are no receivables and payables with

the Parent company.

On December 24, 2021, EDS received a temporary cash facility of € 4.8 million from the Parent Company,

which was returned on February 23, 2022.

The Transactions of the Parent Company with subsidiaries for the year ended December 31, 2022 and

December 31, 2021 are as follows:

December 31, 2022

Amounts in ‘000€

December 31, 2021

Amounts in ‘000€

Invoiced to

Invoiced from

Invoiced to

Invoiced from

Subsidiaries

PPC Renewables S.A.

4,565

(3,044)

2,998

(380)

HEDNO S.A.

975,558

(1,374,825)

1,567,808

(1,653,766)

LIGNITIKI MEGALOPOLIS S.A.

52,002

(363)

98,775

(928)

LIGNITIKI MELITIS S.A.

31,647

42,176

ILIAKA PARKA ENA S.A

ILIAKA PARKA DIO S.A

SOLAR ARROW ENA S.A

508

138

ARKADIAN SUN ENA S.A

ARKADIAN SUN DIO S.A

AMYNTAIO PV Park ONE Sole Shareholder S.A.

AMYNTAIO PV Park TWO Sole Shareholder S.A.

AMYNTAIO PV Park THREE Sole Shareholder S.A.

AMYNTAIO PV Park FOUR Sole Shareholder S.A.

AMYNTAIO PV Park FIVE Sole Shareholder SA.

AMYNTAIO PV Park SIX Sole Shareholder S.A.

AMYNTAIO PV Park SEVEN Sole Shareholder S.A.

AMYNTAIO PV Park EIGHT Sole Shareholder S.A.

AMYNTAIO PV Park NINE Sole Shareholder S.A.

CARGE S.A

PPC Finance Plc.

(47)

(62)

PPC Elektrik

(178)

(3,097)

PPC Bulgaria JSCO

115

(19,262)

PPC Albania

(216)

EDS AD Skopje

41,398

(1,700)

12,751

(350)

Total

1,105,839

(1,380,373)

1,724,897

(1,677,845)

Guarantee in favour of the subsidiaries

As of 31.12.2022, the Parent Company has provided a guarantee to its subsidiary PPC Renewables S.A.

for a total credit line of up to € 8.0 million, through overdraft facilities, out of which PPC Renewables S.A.

has used an amount of € 418 thousands relating to letters of guarantee.

As of 31.12.2022, the Parent Company is a guarantor in loans of the subsidiary company Energy Delivery

Solutions EDS AD (EDS) for working capital of € 32 million, of which € 5.7 million has been drawn for

working capital purposes, while € 4.4 million has been used to issue letters of guarantee.

As of 31.12.2022, the Parent Company provided a corporate guarantee to EDS for the electricity supplier

Energy Financing Team AG - St Gallen amounting of up to € 1.5 million and for the electricity supplier

Alpiq Energija amounting of up to € 1.5 million.

On February 21, 2022, bank deposits of €21 million (Note 23) of the Parent Company were pledged on

behalf of a loan of the subsidiary EDS.

Significant Transactions and balances with other companies in which the Greek State participates

The following table presents the transactions and balances with the companies Hellenic Petroleum

("ELPE") and Public Gas Company ("DEPA") which are suppliers of liquid fuels and natural gas,

respectively, and in which the Greek State participates. In addition, the transactions and the rest with

DAPEEP SA are presented. EXE SA, ENEXCLEAR A.E., IPTO SA and LARCO GMME. The below tables

include also accrued receivables and payables and accrued income and expenses.

1.1.2022– 31.12.2022

Amounts in ‘000€

1.1.2021 – 31.12.2021

Amounts in ‘000€

Invoiced to

Invoiced from

Invoiced to

Invoiced from

ELPE

316,838

25,572

(98,978)

DEPA

1,556,387

(672,967)

DAPEEP S.A.

4,883,984

(347,250)

254,107

(359,949)

HEnEx S.A.

(2,678)

(3,384)

IPTO S.A

59,245

(111,139)

43,624

(128,795)

ENEXCLEAR S.A.

6,039,054

(10,457,909)

3,179,247

(4,610,117)

LARCO S.A.

27,322

26,951

December 31, 2022

Amounts in ‘000€

December 31, 2021

Amounts in ‘000€

Receivables

(Payables)

Receivables

(Payables)

ELPE

(88,134)

(18,064)

DEPA

(119,977)

(91,447)

DAPEEP S.A.

474,910

(59,134)

31,704

(68,889)

HEnEx S.A.

(7)

(8)

IPTO S.A.

14,625

(18,629)

4,754

ENEXCLEAR S.A.

43,693

(61,345)

34,111

(40,178)

LARCO S.A.

367,542

369,093

PPC’s total receivables from LARCO S.A., relating to electricity bills, are fully covered by a provision.

In addition to the above mentioned, PPC enters into commercial transactions with many state-owned

entities, both profit and non for profit, within its normal course of business (sale of electricity, services

received, etc.). All transactions with state-owned entities are performed at arm’s length terms and are not

disclosed, with the exception of transactions that the Group and the Parent Company enter into with the

Hellenic Corporation of Assets and Participations S.A. (HCAP S.A.) and the companies in which HCAP

S.A. participates.The balances and transactions as of December 31, 2022 and December 31, 2021 with

HCAP S.A. and the companies, in which HCAP S.A. participates, are presented below:

GROUP

PARENT COMPANY

December 31, 2022

Amounts in ‘000€

December 31, 2022

Amounts in ‘000€

Receivables

(Payables)

Receivables

(Payables)

ATHENS INTERNATIONAL AIRPORT S.A.

1,683

(11)

1,642

(11)

ELTA S.A.

983

(3,148)

(3,041)

ELTA COURIER S.A.

(343)

(293)

EYDAP S.A.

10,843

(54)

10,843

(12)

ETVA INDUSTRIAL PARKS S.A.

803

(27)

803

(21)

ODIKES SYNGKOINONIES S.A.

10,311

PUBLIC PROPERTIES COMPANY S.A.

6,699

URBAN RAIL TRANSPORT S.A.

19,224

C.M.F.O. S.A.

137

Ο.Α.S.Α. S.A.

Ε.Υ.Α.TH. S.A

7,029

7,028

GEA OSE S.A

(1)

AEDIK

HELLENIC SALTWORKS S.A.

(1)

TOTAL

57,728

(3,585)

56,701

(3,379)

GROUP

PARENT COMPANY

December 31, 2021

Amounts in ‘000€

December 31, 2021

Amounts in ‘000€

Receivables

(Payables)

Receivables

(Payables)

ΗCAP S.A

(1)

ATHENS INTERNATIONAL AIRPORT S.A.

632

(12)

591

(12)

ELTA S.A.

1,486

(6,888)

(6,809)

ELTA COURIER S.A.

(98)

(72)

EYDAP S.A.

5,756

(30)

5,756

(19)

ETVA INDUSTRIAL PARKS S.A.

232

(21)

232

(16)

THESSALONIKI INTERNATIONAL FAIR S.A.

138

ODIKES SYNGKOINONIES S.A.

11,616

PUBLIC PROPERTIES COMPANY S.A.

5,207

URBAN RAIL TRANSPORT S.A.

34,963

C.M.F.O. S.A.

190

Ο.Α.S.Α. S.A.

Ε.Υ.Α.TH. S.A

3,988

(1)

3,987

(1)

GEA OSE S.A

(1)

MANAGEMENT INDUSTR.PARK KASTORIA

(1)

AEDIK

MARINA ZEAS

HELLENIC SALTWORKS S.A.

(11)

TOTAL

64,217

(7,064)

62,688

(6,943)

The transactions made by the Group and the Parent company with HCAP S.A. and the companies in

which participates for the years ended December 31

2022 and December 31

2021 are as follows:

GROUP

PARENT COMPANY

1.1.2022 – 31.12.2022

Amounts in ‘000€

1.1.2022 – 31.12.2022

Amounts in ‘000€

Invoiced to

Invoiced

from

Invoiced

from

HCAP S.A.

ATHENS INTERNATIONAL AIRPORT S.A.

1,811

(106)

1,590

(106)

ELTA S.A.

8,561

(11,589)

(11,538)

ELTA COURIER S.A.

(353)

(318)

EYDAP S.A.

64,006

(219)

63,917

(167)

ETVA INDUSTRIAL PARKS S.A.

3,221

(58)

3,221

(53)

THESSALONIKI INTERNATIONAL FAIR S.A.

2,945

(91)

2,945

(81)

ODIKES SYNGKOINONIES S.A.

10,923

(10)

10,922

PUBLIC PROPERTIES COMPANY S.A.

4,701

(2)

4,701

(2)

URBAN RAIL TRANSPORT S.A.

72,010

(2)

72,007

C.M.F.O. S.A.

3,758

Ο.Α.S.Α. S.A.

120

CENTRAL THESSALONIKI MARKET S.A.

588

Ε.Υ.Α.TH. S.A.

44,113

(6)

44,108

(1)

HELLENIC SALTWORKS S.A.

674

MANAGEMENT OF INDUSTRIAL PARK OF

KASTORIA

GAIA- OSE S.A.

A.E.DI.K

TOTAL

217,593

(12,436)

208,721

(12,266)

GROUP

PARENT COMPANY

1.1.2021 – 31.12.2021

Amounts in ‘000€

1.1.2021 – 31.12.2021

Amounts in ‘000€

Invoiced to

Invoiced

from

Invoiced

from

HCAP S.A.

ATHENS INTERNATIONAL AIRPORT S.A.

4,494

(102)

4,258

(102)

ELTA S.A.

17,256

(17,207)

(12,588)

ELTA COURIER S.A.

(236)

(181)

EYDAP S.A.

20,999

(163)

20,886

(127)

ETVA INDUSTRIAL PARKS S.A.

1,186

(44)

1,185

(38)

THESSALONIKI INTERNATIONAL FAIR

S.A.

902

(71)

902

(70)

ODIKES SYNGKOINONIES S.A.

3,536

(8)

3,536

PUBLIC PROPERTIES COMPANY S.A.

1,783

(28)

1,704

(2)

URBAN RAIL TRANSPORT S.A.

22,328

(1)

22,328

C.M.F.O. S.A.

1,272

Ο.Α.S.Α. S.A.

Ε.Υ.Α.TH. S.A.

14,220

(7)

14,214

(1)

HELLENIC SALTWORKS S.A.

263

MANAGEMENT OF INDUSTRIAL PARK

OF KASTORIA

GAIA- OSE S.A.

A.E.DI.K

TOTAL

88,352

(17,867)

70,665

(13,109)

Management remuneration

Management Members remuneration (Board of Directors and General Managers) for the year ended

December 31

, 2022 and December 31

, 2021 is as follows:

GROUP

Amounts in ‘000€

COMPANY

Amounts in ‘000€

2022

2021

2022

2021

Remuneration of the Board of Directors’

members

- Remuneration of executive members

989

1,254

580

677

- Remuneration of non-executive members

235

326

- Compensation / Extraordinary fees and

other benefits

594

375

500

211

- Employer’s Social Contributions

184

238

2,002

2,193

1,176

971

Remuneration of the Deputy Chief

Executive Officers and General Managers

- Regular remuneration

2,698

2,175

1,814

1,468

- Employer’s Social Contributions

414

346

304

254

-Compensation / Extraordinary fees

1,380

1,001

922

573

4,492

3,522

3,040

2,295

Total

6,494

5,715

4,216

3,266

Remuneration to members of the Board of Directors does not include standard salaries and employer’s

social contribution, relating to the representatives of employees that participate in the Parent Company’s

Board of Directors. It also does not include the benefit of the electricity supply based on the PPC personnel

tariff to the executive members of the Board of Directors, the Deputy Chief Executive Officers and the

General Managers.

It was also approved to provide additional incentive in the form of equity settled stock awards. As to date

the key Efficiency Ratios for this benefit have not been defined, it is not possible at present to determine

the fair value of rights of free shares (Note 7).

Non-financial Report

Introduction

The present Non-Financial Information Report (hereafter "NFR") contains information on the management

and performance of PPC Group in the thematic sections as these are defined in the provisions of EU

Directive 201/95/EU and Law 4548/2018 (articles 151 and 154).

In particular, the Group's NFR includes information, to the extent that it is required for understanding the

development, performance, position, and impact of its activities, in relation to:

• Environmental issues

• Social and labour issues

• Respect for human rights

• Fight against corruption, issues relating to bribery and

• Supply chain issues

The NFR also includes:

1. Brief description of the Company's business model

2. The major risks related to these issues and associated with the Group's activities

3. Due diligence policies and procedures and results thereof/Non-financial Performance Indicators for the

said issues. This section also includes Climate Change issues (Strategic Goals, significant impacts,

risks, and opportunities), as well as a report on the impact of the COVID-19 pandemic.

4. Purpose of the financial information provided and data quality thereof.

5. Information under Article 8 of the Regulation (EU) 2020/852 of the European Parliament and of the

Council dated June 18, 2020 establishing a framework for facilitating sustainable investments and of the

Commission Delegated Regulation (EU) 2021/2178 dated July 6, 2021 supplementing Regulation (EU)

2020/852.

The content of this NFR has been prepared taking into account the GRI Satandards, the Athens Stock

Exchange ESG Reporting Guide 2022 (https://www.athexgroup.gr/el/web/guest/esg-reporting-guide,as

well as indicators monitored by the Company internally.

It is noted that this Report concerns the financial year ended 31 December 2022 and for completeness

purposes, comparative data for the financial year ended 31 December 2021 are also presented.

The NFR covers the greatest part of PPC Group's activities and includes the activities in Greece of the

Parent Company “Public Power Corporation S.A.” including the companies “HEDNO S.A.” “and PPC

RENEWABLES SINGLE MEMBER S.A.” It should be noted that for the fiscal year 2022, the companies

“Lignitiki Megalopolis Single Member S.A.” and “Lignitiki Melitis Single Member S.A.” are included in the

Parent Company's figures given that in 2022 the merger by way of absorption of the aforementioned

companies by PPC S.A. was completed. For the time being, the scope of this NFR does not include all

the Group's subsidiaries included in the Financial Information due to their small-scale activity.

1. Business Model

[ATHEX AG-1: Business Model]

PPC was established in 1950 as a public sector enterprise, tasked with the responsibility of providing

electricity to the whole country. It was subsequently transformed into a societe anonyme and listed on the

stock exchange, but the influence of the State on PPC remained significant, especially regarding its Public

Service Obligations which have been assigned to PPC. At the end of 2021, with the reduction of the

State's indirect shareholding to 34.1%, the Company ceased to be controlled by the State and therefore

to be subject to laws and regulations applicable to companies of the wider public sector.

Nevertheless, PPC, due to its engagement in the strategically important utility sector, continues to be a

company of intense public interest and its operation has a significant impact and is influenced by a number

of stakeholders.

PPC is currently a Group of Companies which consists of (a) PPC S.A. which is at its core and operates

in the Power Supply, Power Generation from conventional and hydroelectric sources of energy, Energy

Trading and E-Mobility, (b) the main subsidiaries HEDNO (Distribution) and PPC RENEWABLES, with

the latter being the main player in the transition to "green" electricity generation through Renewable

Energy Sources and Storage and (c) the subsidiaries in South-Eastern Europe which are active in

electricity supply.

The change that has taken place in recent years in the structure of the Company is in full alignment with

the changes in PPC's activities and reflects the new Strategic Plan developed in December 2019, which

is based on three pillars: the implementation of "Green deal" in electricity generation, Digitalization

& Operational Efficiency and the expansion into new value-added activities and products with a

customer-centric approach.

The rapid development of renewable energy sources (RES) and storage systems, both independently and

through partnerships and acquisitions, the implementation of energy saving solutions to the entire range

of consumers, as well as the promotion of the electrification of other energy sectors, starting with PPC

Blue E-Mobility services, constitute the main pillars for the promotion of the energy transition and at the

same time contribute to the reinforcement of socio-economic development.

Having created an integrated business model, based on the three pillars mentioned above, PPC is moving

forward dynamically in its transformation into an economically and environmentally sustainable energy

company. The Company's strategy aims to maximize its value, always taking into account its social role

in the National Economy and the impact of its activities on the environment.

More specifically, the three pillars on which PPC's business plan is based are:

1. Implementation of "Green deal" in electricity generation with the withdrawal of lignite power plants

and the corresponding mines and emphasizing in the uptake of RES as the new primary power

generation technology. The detailed plan of lignite phase-out includes the withdrawal of lignite

plants with net installed capacity approximately 3.4 GW. It is noted, however, that PPC Group has

launched in 2022, as an extraordinary measure to strengthen the country's energy adequacy and

reduce the supply of natural gas from Russia, the increase of lignite generation, contributing to the

adequacy of the country's electricity system for the period of the energy crisis, by revising the mining

planning of the mines and diversifying the lignite-fired power plants’ decommissioning programme with

an estimated short extension in line with market conditions. The de-lignitization plan is implemented

with full respect for PPC employees, local communities and the environment, as well as ensuring the

country's energy sufficiency. In this context of the just transition, the Company has already planned

and implemented a series of new development projects, but also to maintain the existing ones with

the appropriate modifications, as for example was done with the successful implementation of the

district heating project, aiming at the continuous support of the local communities.

The plan for the new PPC encompasses significant investments in RES and storage systems through

the subsidiary PPC RENEWABLES SINGLE MEMBER S.A., as well as investments in storage units

aiming at increasing installed capacity to approximately 9.5GW until 2026.

2. Digitalization and operational efficiency for the achievement of cost-reduction and revenue-

increase synergies, by applying new technologies across all sectors, such as:

• Digital development of PPC through process digitalization and automation models aiming at

simplifying existing operations and creating new digital customer channels and products.

• Digitalization of the activities and infrastructures of the electricity Distribution Network by investing in

the networks’ upgrade using tools such as smart meters, circuit breakers, GIS systems etc.

• Use of new Cloud technologies to optimize infrastructure costs and move to a data-centric operation

across the entire spectrum of business activity (from infrastructure to commercial services)

• Use of technology to ensure information and network security of the company as a Critical National

energy infrastructure, based on the best practices, safeguarding in a responsible way the natural

persons involved, such as customers and the society as a whole.

• Enhancement of PPC human resource’s digital culture, by introducing modern tools of collaboration,

communication, and interaction, creating thus a modern and technologically upgraded environment

for collaboration.

3. Expansion in new value-added activities and products with a customer-centric approach, both

in the retail electricity market and in new business sectors. The Company's strategy and philosophy

is to provide energy solutions, technology, and infrastructure in order to lead to a future ensuring

respect for the environment for a better life for all. The aim of the Company is to be transformed from

an energy supplier into an energy consultant that is next to the customers and informs - advises them

on everything related to energy saving and sustainability and at the same time educates them on key

energy issues. With a view to always creating an excellent customer experience, we aim to meet

increasingly more of our customers' needs, by providing solutions within an expanded portfolio of

services.

More in particular, priority is given by PPC to the development in the most efficient way of the necessary

infrastructure for the electrification of transport and heating. A rapid increase in the number of electric

vehicles is expected at an international level, due to the fact that their cost is expected to approach the

cost of conventional vehicles over the next few years. The Company's objective is the penetration of

publicly accessible charger installations in new market channels and the development of new value-added

e-mobility services with a customer-centric approach. PPC will contribute to the increase of electric

vehicles in our country by investing in the necessary infrastructure and more in particular in the installation

of more than 1,000 charging stations over the next few years, while the medium-term goal for PPC is to

install more than 10,000 public charging stations all over Greece.

However, by acknowledging the limitations in some sectors which cannot be electrified we acknowledge

the role that “green hydrogen” can play in a zero-emission world. This is the reason why we established

with MOH the joint venture company, Hellenic Hydrogen, engaging in the production of green hydrogen.

Moreover, in 2022 PPC focused on designing and launching value added services, as well as on designing

integrated consulting services on energy upgrading and energy saving issues in end use. Furthermore,

PPC successfully implemented the transformation of all digital service channels providing new advanced

capabilities, while the plan for the radical renewal of the Company's physical stores all over Greece is

being implemented at a rapid pace. Finally, within 2022, PPC made a systematic effort to design an

integrated service aimed at informing, promoting, and installing photovoltaic energy generation systems

on rooftops, providing an excellent solution for green and affordable energy for all customers. This service

has been available in the market from the early 2023.

In addition, PPC proceeds with the implementation of the project of constructing and operating a fibre

optic network platform at a national level to join the key high-speed broadband service providers, thus

creating a new source of revenue. After the completion of the pilot phase of the project, the full project

implementation will be launched, aiming to serve 3 million households by 2026.

In order to implement all the above, PPC proceeded during the three-year period 2020-2022 with the

creation of a strong organisational structure, adopting and implementing new policies and procedures

in line with the best international practices, creating an environment of good Corporate Governance

and ethical behaviour environment that ensures the sustainable development of the Group and the

maximisation of its value.

In this new era, the strategic philosophy of PPC is "Creating Shared Value", namely the creation and

measurement of shared value among the company, society and the environment, resulting from its

new business model, the transformation of the value chain and operation of the company, and the

shaping of a new corporate culture.

In this context, the Company seeks to develop goal setting related to ESG criteria, while placing

particular emphasis on improving ESG disclosures with the aim of improving the relevant rating by

international ESG rating agencies such as CDP, MSCI ESG ratings, Sustainalytics and Institutional

Shareholder Services (ISS).

To this end, PPC participates in and monitors important frameworks of principles, commitments and

recommendations, according to which objectives are set and action plans are prepared aimed at

contributing to the transformation of the Group (TCFD, SBTi, UN Global Compact, etc.). The

prioritization of sustainable development issues/ESG, as it results from the periodic materiality

analysis conducted by the Company, as well as the UN Sustainable Development Goals (SDGs) to

which the Group has the greatest impact, constitute the key pillars shaping the long-term sustainability

strategy of the Group.

2. Identification of Major Risks Related to Non-Financial Issues

At PPC, apart from the financial risks, we identify non-financial risks related to the environment and climate

change, the human capital and society at large, which may significantly affect the Company's reputation

and may have a significant impact on its relationships with stakeholders.

In particular, the most significant identified risks may be summarised as follows:

• Risks related to climate change.

• Risks related to extraordinary events such as natural disasters, adverse weather conditions,

pandemics, fires, wars, terrorist actions and strikes.

• Risks related to Information Systems Security Risks related to non-compliance with the EU

General Data Protection Regulation (GDPR)

• Risks related to the complex and uncertain regulatory framework in Greece and the EU.

• Risks related laws and regulations on health, safety, and the environment

• Risks related to the recruitment and retention of specialized personnel

• Risks related to the war in Ukraine

A detailed report on all risks of both the Group and the Parent Company is provided in the Annual Report

of the Board of Directors included as an integral part of the Annual Financial Report for the financial year

2022.

3. Due Diligence Policies and Processes and Results thereof/Non-Financial Performance Indicators

The Company has established Codes, Policies and Processes to address corporate risks and manage

compliance and sustainable development issues, which are subject to periodic review in order to meet the

relevant best practices.

1. Environmental issues

Issues related to Climate Change

Strategy

PPC Group is committed to developing a strategic plan in line with the objectives of the Paris Agreement

(COP21) and the Glasgow Climate Pact (COP26) concerning the limitation of the average global

temperature increase to 1.5 degrees compared to pre-industrial levels and is in line with the ambitious

medium and long-term climate neutrality goals of the European Union and Greece by 2050.

In this context, PPC Group has focused its strategy on the development of renewable energy sources

(RES), supported by the necessary storage and green hydrogen, while proceeding at the same time with

the gradual withdrawal of its lignite plants, the electrification of other energy sectors, such as transport

and buildings - starting with e-mobility and heat pumps - and investing in smart grids.

The new environmental performance that will result from the lignite phase-out, as well as from the new

low-emission production model, will form the basis for the Sustainable Development of PPC Group and

the improvement of its competitiveness.

Risks and opportunities related to Climate Change

[ATHEX A-E2: Risks and opportunities related to Climate Change]

The shaping of PPC Group's strategy is accompanied by a detailed analysis of the risks and opportunities

associated with it, including the potential impacts of climate change. Therefore, PPC Group’s strategic

planning is based on a detailed short-, medium- and long-term analysis of all risks and opportunities

arising from the development of electricity systems, including risks related to climate change.

In order to identify the opportunities related to climate change, as well as the risks related to both climate

conditions change and energy transition, PPC has adopted an approach which is in line with the

recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) of the Financial

Stability Board.

In this context, the Parent Company has developed a Corporate Risk Management Framework by defining

a systematic approach and integrating the processes of identification, analysis and mitigation of the

climate change related risk into the processes of adopting strategies and decisions for the prevention and

mitigation of the impact of climate change. In particular, responsibility for risk management and monitoring

runs through all organizational levels of the Company (three lines of defence model) with clearly defined

responsibilities for the Board of Directors, establishing the creation of specialized Risk Management

Committees with the participation of the senior management. (Audit Committee and Risk Management

Committee).

Risks and opportunities related to climate change with potential impact on the Group's and the Parent

Company's business activities are divided into 2 categories: (a) risks related to the transition to a zero

carbon footprint economy (energy transition risks) and (b) risks arising as a result of changes in climate

conditions (natural risks). These changes relate both to an increase in the frequency and intensity of

extreme weather phenomena (severe phenomena) and to longer-term changes in climate conditions

which are more gradual but structural (e.g. steady increase in temperature and/or increase in drought and

decrease in rainfall throughout the year). The natural phenomena scenarios are based on the projected

climate changes associated with the 'Representative Concentration Trajectories' (RCPs) as presented in

the 6th Assessment Report of the Intergovernmental Panel on Climate Change (IPCC).

The risks or opportunities associated with the transition to a zero-carbon economy include policy risks

(such as energy efficiency requirements, carbon pricing mechanisms, sustainable land use), legal risks

(such as climate change non-compliance/adjustment), technological, market and reputational risks. For

the analysis of the above risks, analyses and simulations were carried out in the medium and long term

with scenarios (summarised in Table 1) that take into account the evolving mix of installed capacity and

generation, the flexibility requirements of the system, the evolution and adaptation of the systems of both

the Greek and neighbouring markets, as well as market issues such as the expected evolution of

wholesale market prices, balancing markets as well as the price evolution of the various technologies

(RES, storge, etc.)

The implementation of the above policies to promote the reduction of carbon use was recognised as

having a significant impact on the operations and value of the Group's thermal power plants. To mitigate

the impact of the above risks, the transformation of the Group's portfolio is being actively implemented,

focusing on the development of renewable energy sources (RES), battery storage and green hydrogen,

while proceeding with the withdrawal of its lignite-fired power plants, the electrification of other energy

sectors - starting with electrification and heat pumps - and investing in smart grids. This strategic plan is

in line with the objectives of the Paris Agreement (COP21) and the Glasgow Climate Pact (COP26) to

limit the increase in global average temperature to 1.5 degrees compared to pre-industrial levels. The

technological diversification of PPC's portfolio limits the impact of changes to a single variable. At the

same time, the shift to clean energy helps the Group to address the challenges posed by the regulatory

environment and competition.

However, the climate change scenarios identified significant opportunities (Table 1) in new or increasingly

interesting business activities such as in the development of projects and services related to the growing

market for e-mobility, electrification of heating, increased penetration of photovoltaics to residential

consumers, demand response contribution, green hydrogen production, and technologies for providing

system flexibility and storage services.

The decisions of the Group and the Parent Company are consistent and interconnected with the above

analysis as reflected in the Group's business plan, with tangible actions - investments for the exploitation

of the changing conditions and the synchronized and smooth transformation of the Group with the energy

transition. Specifically, PPC offers e-mobility services (PPC Blue), products and services that contribute

to the efficient and economical electrification of other sectors such as heat pumps, while the establishment

of a company jointly with Motor Oil Hellas, the Hellenic Hydrogen, for the production of green hydrogen

contributes to the same direction.

In this light, related investment decisions are also being evaluated in order to strengthen the Group's

position in investing in RES and storage systems both in Greece and in the Balkan region.

Risks related to the natural impacts of climate change on the increase in extreme weather phenomena

(natural hazards) include acute natural hazard risks resulting from specific phenomena such as storms,

floods, extreme temperatures (heat waves - extreme cold waves) and the chronic natural risks, associated

with longer-term climate changes such as continued increase in average temperatures, changes in wind

patterns, increased rainfall, droughts, sea level rise and reduced water availability.

For the analysis of the above risks, PPC conducted stress test scenarios with reduced generation,

disturbances in electricity consumption for different durations and periods. (Table 1). The analysis showed

that extreme weather phenomena caused by climate change could also significantly affect power

generation from conventional or RES power plants, damage the power plants themselves as well as the

resilience and performance of the distribution network. In addition, changes in hydrological conditions may

lead the Group and the Parent Company to make up for the reduced power produced by their hydroelectric

power plants, especially in periods of increased demand, by using other means of generation at higher

costs or by resorting to the wholesale market at higher prices.

Based on the above, in order to mitigate the impacts and enhance the resilience of the power plants and

the network, the Group and the Parent Company have incorporated practices for continuous monitoring,

assessment of natural risks, procedures to increase resilience and faster restoration of damages.

Table 1: Overview of risks and opportunities

Scenario

Risk/Opportunity

Time

Frame

Impact

Management

Extreme

natural

phenomena

Risk of extreme phenomena

(heat waves, floods, fires,

etc.)

Short-term

(2022-2025)

Intense phenomena increase the risk of

prolonged asset unavailability and

infrastructure operation disruption.

The Group adopts best management practices to restore services as

quickly as possible. Moreover, it implements investments to increase

the resilience and flexibility of infrastructure.

Long-term

climate

changes

Structural changes in

weather conditions

Medium- and

long-term

(2026-2050)

Changes in climate conditions can lead to

changes in demand and electricity

generation profiles from various

technologies.

The technological diversification of the Group’s portfolio limits the

impact of changes from a single variable. In addition, in order to ensure

that activities take into account weather conditions and climate

phenomena, the Group has adopted a series of practices, such as

weather forecast, real-time monitoring of meteorological data and

analysis of long-term climate scenarios.

Energy

transition -

Market

Changes in market

conditions including:

• commodities pricing

• consumption standards

for electricity

consumption

• competition

Short,

medium and

long-term

(after 2022)

Through quantitative and qualitative

analysis and the evaluation of a series of

energy transition scenarios, the Group

assesses the impact of the following

market trends on both the energy system

and its functions:

• Competitiveness in the cost of

renewable energy sources compared

to fossil fuels

• Electrification of other energy sectors

• Consumer behaviour modelling and

adoption of technologies such as

rooftop photovoltaic systems,

batteries, electric vehicles and heat

pumps

• Competitive environment and

products

PPC maximizes the opportunities that arise by adopting a strategy

based on energy transition and focuses on rapid RES expansion in the

electricity sector and on the electrification of other energy sectors,

starting with heating and road transport.

Scenario

Risk/Opportunity

Time

Frame

Impact

Management

Energy

transition -

policies

Policies and regulatory

framework: Policies on CO

emission values and

emission limits, energy

transition incentives,

decarbonization targets,

larger targets for RES

penetration rates, flexibility,

and resilience.

Medium- and

long-term

(2026-2050)

Energy transition policies can significantly

affect the size of the decarbonization

market in terms of the installation of green

technologies and can increase the return

on investments. On the other hand, energy

transition policies will limit the

role of certain technologies which have a

significant share of the electricity market

today (such as gas-fired power plants).

PPC limits its exposure to risks by reducing emissions from

its power generation facilities. Moreover, the Group's

business plan, which focuses on investments in RES,

networks, digitization, and consumers, allows the Company

to mitigate the impact of potential risks and exploit

opportunities associated with the energy transition and

decarbonization targets. As regards currently existing

technologies in PPC's portfolio which need to change in order

to have a place in a zero carbon world (such as gas-fired

plants), PPC considers the technological solutions available

for reusing those assets (such as CCS).

Energy

transition -

technologies

New technologies, products

and services are appearing

to help achieve the

decarbonization targets.

Opportunities to increase

profit margins and for greater

room for investments thanks

to higher penetration of new

technologies both in

wholesale and retail.

From a

short-term

perspective

(after 2022)

In addition to the penetration of renewable

energy sources and storage into the

electricity market, electrification trends in

transport and household consumption will

have a potential impact on PPC's business

activities.

Thanks to its position, the Group maximizes opportunities for

new business activities and services, and power distribution.

Actions to address climate change within 2022

In the context of reducing CO

emissions from thermal power plants and addressing climate change, the Group

implements actions and programmes that include the following:

- Investments both for the replacement of old thermal power plants with new ones of modern technology and high

efficiency, as well as for the improvement of the environmental performance of the existing power plants.

- Further development of large hydroelectric and renewable energy projects.

- Ensuring energy supply by maintaining the necessary capacity of thermal power plants at the maximum degree of

operational efficiency and readiness

- Promoting energy saving actions and rational use of electricity.

- Examination of investment proposals for the development of new forms of energy generation and storage

- Participation in research projects on the application of efficient lignite technologies, CO

absorption from the

atmosphere, etc.

- Mine rehabilitation projects, experimental crops on restored land, etc.

- Investments in the E-mobility sector

- Investments in the sector of Renewable Energy Sources

In particular:

Actions of PPC S.A. within 2022

The efforts for the modernization of the generation potential of PPC S.A continued. Specifically:

- The lignite Units III and IV of the 600 MW Kardia TPP were decommissioned.

- The construction of the new modern Lignite Unit V of Ptolemaida TPP continued, the operation of which will enable

the withdrawal of more old units and ensure district heating of the city of Ptolemaida.

- Investments continued for the environmental upgrading of the Units of Ag. Dimitrios TPP in order to adapt them to

the Best Available Techniques and reduce emissions of nitrogen oxides, sulphur dioxide and dust.

- Mining (lignite extraction operations) at the Lakkia Mine was permanently suspended.

- Preparation works for post-mine uses continued at the Amyntaio Mine.

- The implementation of land rehabilitation programmes in the areas of the lignite mines continued, including tree

planting, agricultural crops, etc.

- Works continued for the construction and operation of two new hydroelectric power plants with total capacity 200

MW (Mesochora & Metsovitiko)

- In 2022, electricity consumption of the administration buildings and PPC S.A. Stores throughout the country was

covered by GreenPass Guarantees of Origin from the generation of the company's hydroelectric power plants (8.37

GWh). The GreenPass Guarantees of Origin made available by PPC to its customers in 2022 amount to 1.5 TWh

for Corporate Customers and 0.4 TWh for Residential Customers.

Greenhouse gas emissions and Lignite phase-out

According to the most recent national inventory of greenhouse gas emissions submitted by Greece to the

Secretariat of the United Nations Framework Convention on Climate Change, which was submitted in 2022 and

covers the period 1990-2020, greenhouse gas emissions from the combustion of fossil fuels by PPC’s and private

individuals’ thermal power plants of for the generation of electricity and heat in 2020 were 20.0 million tonnes of

carbon dioxide equivalent (CO

eq) and constituted approximately 26.7% of the total national emissions of 74.8

million tonnes of CO

eq.

Atmospheric Quality Measurement Stations

With a view to monitoring the atmospheric emissions, PPC operates a network of 31 Atmospheric Quality

Measurement Stations (AQMSs), which also operate for meteorological parameters' measurement, in the wider

areas of power plants and mines, which is further developed when the need arises. Within this framework, the

competent bodies are systematically informed about the atmospheric emissions in the wider area of PPC’s activity,

by submitting annual and semi-annual Atmospheric Quality Reports, pursuant to the Environmental Terms Approval

Decisions, while information is immediate (within 24 hours) in cases of exceeding air emissions, failure of the anti-

pollution equipment, failure of the analyser for measuring environmental parameters, etc.

PPC atmospheric quality measurement stations in the wider areas of Power Plants and Mines

Location

Number of

stations

Μeasured air pollutants

North System

, NO

, PM

2,5

Lavrio

, NO

, PM

Aliveri

, NO

, PM

Komotini

Chania

Linoperamata

, NO

, PM

Atherinolakkos

, NO

, PM

2,5

Rhodes

, NO

, PM

2,5

Κoς

, NO

, PM

2,5

Samos

, NO

, PM

Chios

, NO

, PM

2,5

Lesvos

, NO

, PM

2,5

Megalopoli

SO2, NOX, PM10, PM

2,5

Total

In 2022, there was no need for the Peak Environmental Issues Management Team to be convened, which consists

of members of the Lignite Generation Business Unit and the Thermal and Hydro Generation Business Unit. The

task of this team is to continuously monitor the results of air quality measurements and to continuously shape a

specific strategy to address and minimise, to the minimum possible, any exceeds of the permissible limits.

Voluntary initiatives

Among others, in 2022, voluntary actions and initiatives were undertaken and coordinated by the Sustainable

Development Department and supervised by the Sustainability Committee, in cooperation with other units of the

Company and the Group's major subsidiaries (HEDNO and PPC Renewables), which are related to the monitoring

and strengthening of the corporate transition in terms of sustainable development and based on ESG criteria, such

as:

• The PPC Group's integration in the international "Science Based Targets initiative" (SBTi) in order to develop and

validate on a scientific basis, short and long-term goals for reducing greenhouse gas (GHG) emissions and

designing a reliable roadmap for their attainment.

• Response to the initiative “ Task Force on Climate Related Financial Disclosures (TCFD)”. Based on the TCFD

recommendations, a guide for actions has already been drawn up, divided into four main thematic categories of

the framework of recommendations (Governance, Climate Strategy, Risks - Opportunities and Disclosures). The

Sustainable Development Department- in cooperation with the Investor Relations Department - coordinated the

integration of the action plan with the one adopted by the Company in the framework of its cooperation with the

EBRD, and contributes to the implementation of the integrated framework of actions resulting from the project. In

collaboration also with the Strategy Department, which is responsible for identifying and assessing the risks and

opportunities related to the climate crisis and their impact on the Group's Strategic Planning, they coordinate the

presentation of climate scenarios and analyses both internally and externally (investors, lenders, etc.).

• The Group's commitment to the ten general principles of the UN Global Compact, the largest voluntary corporate

sustainability initiative in areas related to human rights, working conditions, environmental protection, and anti-

corruption. PPC is required to respond to and progressively integrate the fundamental principles in the above areas

into its strategy, culture, and operations, and is preparing to submit its annual Communication on Progress report

for the first time in June 2023.

• Response to the global initiative CDP climate change, reporting and publishing extensive data regarding the actions

undertaken by the Group to address the climate crisis, in collaboration with the Environment Department.

• The Company's participation as a signatory (one of the 330 companies worldwide) in Business For Nature's "Make

it Mandatory" campaign, which aims to establish the mandatory assessment and disclosure of data for the

protection of nature and biodiversity by 2030, in order to pave the way for the Company to undertake relevant

actions.

• The Group's participation in the "Women's Empowerment Principles" initiative, an action by the United Nations for

the empowerment of women under the motto "Equality Means Business". By participating in this initiative, PPC

executives are already participating in a one-month international programme, so that relevant targets can be set

within 2023 and an action plan can be developed to achieve them.

• The implementation of significant corporate responsibility actions in cooperation with other institutions,

organisations etc., based on the philosophy of Creating Shared Value (CSV) between the company, society and

the environment, within the framework of the actions "PPC - I act" for the Environment, Society, Culture and

Sports.

• Permanent Participation in Working Groups of the European Federation of National Associations of Electricity

Companies (EURELECTRIC) on Climate Change and Decarbonization, Environmental Protection, Energy Uses

Electrification and Energy Efficiency Increase, E-mobility, Renewable Energy Sources and Energy Storage.

• Permanent Participation in Working Groups of the European Coal and Lignite Federation (EURACOAL).

Lignite Phase-out

The Group is committed to the withdrawal of the lignite-fired power plants and the corresponding mines through an

intensive decommissioning plan for all Lignite Units. However, there may be a diversification of the lignite plant

decommissioning programme with an estimated short extension depending also on market conditions for as long

as the energy crisis lasts.

The table below shows the lignite phase-out plan:

TPPs

Pillars

To date

Decommissioning

Decommissioning of units at Kardia Thermal Power Plant (Units 1 and 2 in 2019 and

Units 3 and 4 in 2021) and Amynteo (Units 1 and 2 in 2020) with a total capacity of

1,812 MW

Technical decommissioning of units decommissioned by neutralization and cleaning

of areas and facilities (plumbing, etc.)

Staff transfer scheme, with staff of the Thermal Power plants being transferred to

other jobs taking into account predetermined objective criteria (category/area of

specialization, evaluation, place of residence, age).

Re-training staff when needed when transferred to other jobs

Rehabilitation

~48% completion (works worth ~EUR 3.3 million) of the rehabilitation works for Liptol

NPP and ~14% completion (works worth ~EUR 2.3 million) of the rehabilitation works

for Ptolemaida TPP.

Five (5) Rehabilitation Studies have been submitted to the Environmental Licensing

Directorate in the context of compliance with the approved environmental terms and

conditions for Thermal Power plants. Up to date three (3) rehabilitation studies have

been approved.

The domestic and European market has been mobilized by fully activating the

Supplier Market Survey (RFI) for Phase I of the restoration of Thermal Power plants.

A procedure has been put in place for approving plans to disassemble Thermal Power

plants to coordinate and align the Departments involved with existing and proposed

new activities.

Mines

Pillars

To date

Decommissioning

Mining work was completed and the operation of the Kardia Field Mine at

Ptolemaida, the Amynteo Mine at Amynteo and the Achada and Kleidi Mines at

Florina was terminated,

Staff transfer scheme of the Western Macedonia Lignite Center Department, with

staff of the mines being transferred to jobs taking into account predetermined

objective criteria (category/area of specialization, evaluation, place of residence,

age).

Re-training staff where needed when transferred to other jobs

Rehabilitation

11,600 ha were rehabilitated in 2021 and 2022 at the Amynteo, Kardia, and

Mavropigi mines.

Completion of landscaping works at the Amynteo mine for soil reclamation to help

prepare sites for the installation of photovoltaic parks of ~940 MW

Ratification of the Framework Agreement of Article 155(4) of Law 4759/2020 covering

9,700 hectares to be reclaimed by PPC to the Greek State by 2025 - ~40% of the

hectares will be handed over by the first half of 2023 for new uses.

The Framework Agreement of Article 155(3) of Law 4759/2020 was signed; PPC

undertook to implement the relevant contractor selection procedures to prepare the

special urban planning schemes based on guidelines and specifications of the

Ministry of Development and Investments.

TPPs &

Mines

Pillars

To date

Utilisation of

Materials and

Equipment

From Withdrawn

Means of

Production (WMP)

The decommissioning of the equipment of each ΤPP is carried out for the whole ΤPP

and not piecemeal, resulting in the optimisation of disposal procedures and sound

environmental management and economies of scale.

The Board of Directors has approved the Management Policy, which will be further

specified through new procedures (e.g. the WMP Permanent Guidelines) for the

monitoring and mass disposal of materials and equipment in the context of the

implementation of best practices of the circular economy.

Donation of equipment to third parties or use as exhibits in PPC museums or

exhibitions of materials/equipment that may be representative of PPC's industrial

heritage – this is a key alternative.

Planning is underway for the management of the materials of the Ptolemaida, Aliveri

and Lavrion TPP depots in view of their disposal within 2023.

Research Projects of Environmental Interest in which the Group participates:

PPC S.A.

In the context of its sustainable development policy, PPC participates in a series of voluntary initiatives and research

programmes for the protection of the Εnvironment. In particular, the current research projects in which it participates

are the following:

• Scaling up of the Electrochemically enhanced catalytic hydrogenation of CO

to fuel production -- CO

TO FUELS.

• Contribution of the Tree Planted Land of West Macedonia Lignite Center to the protection of the Environment and

the mitigation of Climate Change -- COFORMIT

• Evaluation of emissions from lignite plants in bioconversion processes to fuels and fine chemicals -- BIOMEK.

• Bioconversion of CO

into High Value BioProducts through Sustainable Microalgae Cultivation Processes -- CO

BioProducts.

• Design and installation of a hybrid industrial device to collect air pollutants from lignite combustion, by recovering

and activating solid by-products and non-reactive materials of dry desulphurization -- REDESOX.

• Intelligent water treatment technologies to achieve water saving combined with simultaneous energy generation and

material recovery in energy intensive industries -- intelWATT.

• Sustainable use of mining waste discharges -- SUMAD.

• Coal-to-liquids supply chain integration in view of operational, economic, and environmental risk assessments under

unfavourable geological settings -- ODYSSEUS

• Interdisciplinary feasibility study for the conversion of coal mines into hybrid pumped-hydro power storage of excess

energy -- ATLANTIS

• Promotion of investments in fuels through an economic and energy efficient integration of energy processes in closed

facilities of coal-fired thermal power plants -- Green deal CO

• Development of an innovative and viable industrial process by creating a mobile unit for hybrid energy storage based

on CO

capture and renewable energy sources -- LIFE CO

to CH4

• Improving risk assessment and risk management of abandoned coal mines -- POMHAZ

The research programmes in which the Company participates, the integration-funding programmes and the

coordinators/partners are presented in detail on the company’s website https://www.dei.gr/el/dei-

omilos/perivallon/erevnitika-erga-perivallontikou-endiaferontos/

Environmental Management

Environmental Management Systems

PPC Group complies with the environmental law requirements, fosters the circular economy, promotes the saving of

non-renewable natural resources, adopts measures to prevent pollution and safely dispose of waste produced,

conveys the spirit of sustainability to all stakeholders (employees, associates, suppliers, contractors, etc.) and seeks

to create and maintain a constructive trust-based relationship with local communities and the general public. Aiming

to continuously improve its environmental performance, the Group implements an Environmental Management

System in all its companies.

In particular:

PPC has certified Environmental Management Systems (according to ISO 14001:2015) at the Western Macedonia

Lignite Centre and the following power plants, which generate approximately 92% of the electricity generated by

PPC.

Certified power plants with an ISO 14001:2015 Environmental Management System - Data for 2022

In the year 2022:

- The successful Surveillance Inspection of the Environmental Management Systems (EMS) of the twenty-

two (22) Thermal and Hydroelectric Power Plants of PPC S.A., as well as of the Western Macedonia Lignite Centre,

according to ISO 14001:2015 have successfully passed the Surveillance Audit by Independent Certified Bodies.

- The development, implementation, and certification of new Environmental Management Systems, according

to ISO 14001:2015, of additional Autonomous Power Plants in the Non-Interconnected System (APP Milos, Thira,

Lesvos, Paros and LPP Ikaria).

- The development, implementation, and initial certification of the Environmental Management System,

according to ISO 14001:2015, at TPP South Rhodes (TPP Kattavia) .

- The annual surveillance of the ISO 50001:2018 certified Energy Management System (EMS) at the Lignite

Centre of Western Macedonia

- The development and implementation of the Environmental Management System in the HPP N. Plastira

continued.

- In the context of PPC Management’s commitment to disseminating knowledge, creating transparency,

encouraging the participation of personnel in prevention and environmental protection actions and aiming to train

and certify the Company's employees who are involved or are going to be involved in any way whatsoever in ISO

14001:2015 Environmental Management Systems (EMS), the company carried out:

✓ 3 cycles of Seminars for Environmental Management System Auditors/Lead auditors in line with ISO

14001:2015 and

✓ 4 cycles of seminars for environmental management system internal Auditors according to ISO 14001:2015.

- An open lowest tendering procedure was carried out in order to select Consultant(s) for the development,

implementation and certification of Energy Management Systems at PPC S.A.'s Power Plants, namely:

✓ Arachthos Complex

✓ Aliakmon Complex

✓ Nestos Complex

✓ TPP Komotini

✓ TPP Megalopoli V

✓ TPP Aliveri

✓ TPP Keratea-Lavrio

✓ LPP Skyros

- The revised Environmental Policy of PPC S.A. was approved (Board Decision no. 88/12.07.2022)

https://www.dei.gr/el/dei-omilos/perivallon.

Lignite plants

Natural gas plants

Oil plants

Complexes and

independent

Hydroelectric power

plants (HPP)

-Agios Dimitrios

-Meliti

-Megalopoli

-Keratea - Lavrio

-Komotini

-Aliveri

-Megalopoli V

-Atherinolakkos -

Chania

-Linoperamata

-Soroni – Rhodes

-Kattavia-Rhodes

-Lesvos

-Chios

-Limnos

-Samos

-Ikaria

-Kos

-Karpathos

-Paros

-Thira

-Milos

-Skyros

-Aliakmon

-Arachthos

-Acheloos

-Nestos

-Ladonas (HPP)

Non-Financial Performance Indicators

2022

2021

Total Number of Plants with certified

Environmental Management Systems

(Liginitiki Megalopolis and Lignitiki Melitis are

included)

Lignite centers (West Macedonia)

Thermal Power Plants (TPPs)

Hydroelectric Complexes and Independent

Hydroelectric Power Plants

4+1

Autonomous and Local Power Plants

Greenhouse gas emissions for electricity generation [CO

]

(1)

(in million tons)

2022

2021

PPC S.A.

)

14.80

15.80

Notes

(1) It concerns emissions from facilities integrated in the European Emissions Trading Scheme.

(2) The reported emissions for 2022 include the companies PPC S.A., Lignitiki Megalopolis Single Member S.A. and Lignitiki

Melitis Single Member S.A., which in 2022 merged with the parent company PPC S.A., and are based on provisional ex post

data of the Company. These emissions are expected to become final in March 2023 following the completion of the verifications.

It should be noted that the total emissions of Scope 1, Scope 2 and most of Scope 3 for PPC S.A., HEDNO S.A. & PPC

Renewables Single Member S.A. are presented in the Group's Sustainability Report for the financial year 2021. Similarly, these

figures for the financial year 2022 are expected to be presented in the 2022 Sustainability Report.

Greenhouse Gas Emissions [CO

] -KPI Syndicate Loan Bond

(in Μt)

2022

2021

PPC S.A.

14.85(

15.85

(1) The reported emissions for 2022 of PPC S.A. are based on the company's provisional ex post data and an estimate of the

direct CO2 emissions of the Power Plants that are not included in the European Emissions Trading System (EETS). It should be

noted that in 2022 the merger by absorption of the subsidiaries Lignitiki Megalopolis Single Member S.A. and Lignitiki Meliti Single

Member S.A. by the parent company PPC S.A. was completed and their data are included in the 2022 PPC S.A. data.

The table below sets outs the financial burden for compliance with the requirements of the European Emissions

Trading Scheme (surrender of emission allowances equal to verified emissions of CO2).

Greenhouse Gas Emissions Rights [CO

]

(in mil. euros)

2022

2021*

PPC S.A.

1.038

699

*In 2021 the data of the above table refer to the companies PPC S.A., Lignitiki Megalopolis Single Member S.A. and Lignitiki

Melitis Single Member S.A. which were merged within 2022 with the parent company.

HEDNO S.A.

Actions to address Climate Change

In the year 2022, in the context of its adaptation to climate change and aiming at the resilience of the network, the

Company HEDNO S.A. carried out material actions such as the updating of the Network designs based on the new

climate data, the regular inspection of the Networks and the scheduling of maintenance, as well as the selection of

appropriate and reliable materials for Networks and electricity transmission and distribution infrastructure. In

particular:

Investments in Distribution Centres and other medium and low voltage Substation projects continued.

A significant increase occurred in investment in 2022, of the order of 70% compared to 2021 for Branded Network

Projects concerning HV/MT substation projects (reinforcements and renovations – improvements) and HV and MV

cable lines, respectively. Also, a significant increase in investments in 2022, of the order of 106% compared to

2021 was recorded for Branded Network Projects (Replacements).

To name just a few, the following Projects have made remarkable progress:

- GIS Substation Skiathos: Completed in July 2022.

- GIS Substation Thira: Underway (Beginning in January 2022).

- Extension of Corfu II Substation: The extension of the Substation with two 40/50 MVA transformers in the place of

the existing 20/25 MVA transformers has been completed since June 2022.

Investments in Projects to strengthen and modernise the existing network continued.

During the year 2022, in the Distribution Network, an increase in the number of overhead and other MV/LV

Distribution Substations, an increase and expansion of both the overhead and underground MV and LV Networks

and the installation of a significant number of switchgear elements in MV, contributing to the standardization of the

Network and improving its exploitation potential.

The main elements of the Network, i.e. HV/MV substations, Medium and Low Voltage distribution lines (overhead

and underground) and MV/LV trasformers, showed a significant increase within 2022 as a result of the significantly

increased investment, especially in projects of a repetitive nature. In more detail, for the projects of a repetitive

nature, in the year 2022, the main elements of the Distribution Network changed as follows:

- Increase - extension of the MV aerial network by 702 km.

- Increase - extension of the MV underground network by 369 km.

- Increase - extension of the LV aerial network by 448 km.

- Increase - extension of the underground LV network by 195 km.

In addition, as a result of the actions to improve the characteristics of the Network aimed at strengthening the

resilience, safety and reliability, in the low voltage network within 2022:

- The LV network with bare conductors was reduced by 1,163 km

- The LV network with twisted cables was correspondingly increased by 1,605 km.

At the same time, in 2022, HEDNO S.A. carried out extensive tree pruning (tree felling) in compliance with the

prescribed safety distances from the Network, which, in combination with the clearing of vegetation alongside,

contributed to the resilience of the Network to Climate Change, in addition to forest protection.

Increased connections of Renewable Energy Sources to the Network.

In 2022, 1,097 MW of RES were installed, an increase of 37.7% compared to 2021. The total number of new RES

connections in 2022 reached 5,050, an increase of 135% compared to the previous year.

Integration of E-mobility into the Distribution Network

HEDNO S.A. supports the development of E-mobility, by ensuring access and connection to the Distribution

Network to all users, contributing to several initiatives. The optimal integration of e-mobility into the Distribution

Network and the maximization of RES use play a key role in achieving zero environmental pollution and addressing

Climate Change.

Study on strengthening resilience to climate change

In June 2022, a study on enhancing the resilience of HEDNO S.A. to climate change was elaborated by an external

consultant, which examined the best practices of large and advanced European Distribution Network Operators

and proposed actions and measures that should be included in HEDNO S.A.’s strategic plan to address climate

change, taking into account the current situation in the Company.

HEDNO S.A. participated in Research Programs of Environmental Interest

In the year 2022, the cooperation of HEDNO S.A. with the Ministry of the Environment was initiated within the

framework of the LIFE-IP project AdaptInGR -- Boosting the implementation of adaptation policy across Greece, in

order to monitor adaptation indicators to Climate Change. Given the key role of HEDNO S.A. in the adaptation of

the country's energy system to climate change, by monitoring these indicators their significance and reliability will

be investigated (e.g. measurability, appropriateness, etc.), in relation both to the available data, the existing

monitoring systems, and the real potential for further development.

In this context, HEDNO S.A. will carry out a more coordinated recording of incidents from severe weather events

and emergencies and their impact on consumers, as well as their correlation with Climate Change.

The Research and Innovation Department of HEDNO participated in 2022 in the execution of research projects,

which have at their core the decarbonisation of electricity systems and means of transport, through the use of

renewable energy sources, through the use of electricity storage technologies, through the development of

methodologies and tools for the provision of flexibility services from the part of electricity users and through the

electrification of road and maritime transportations.

All research projects of environmental interest are funded by the European Union and contribute to the EU's vision

for a net zero economy by 2050. In detail, the research projects in which HEDNO S.A. participates are the following:

X-FLEX: X-FLEX aims to develop a set of information and communication technology (ICT) tools and solutions with

the purpose of exploiting at network level the flexibility provided by energy storage systems of different

technologies, demand response, controlled RES plants and new energy market mechanisms. These tools will

contribute to the sustainability of a stable and secure electricity network with increased penetration of RES and

resilience to extreme weather phenomena.

PLATONE: The project uses blockchain technology to create a platform that meets the needs of electricity

distribution network operators, including data management. The platform is created based on the existing

regulations and will allow small electricity producers to be easily certified so that they can sell surplus energy back

to the network. This platform also incorporates an open market system for connection to traditional transmission

system operators.

PARITY: The project addresses the "structural inertia" of conventional electricity distribution networks by providing

an interactive flexibility framework that will increase the resilience and efficiency of the electricity network, while

enabling the adoption of more RES through enhanced real-time control of flexibility, combined with new Active

Network Management (ANM) functions.

IELECRIX: The IElectrix project adopts a consumer-centric approach and involvement of customers in the

electricity market through the Energy Communities. It also focuses on faster and more efficient penetration of RES

into electricity distribution networks and energy transition. Distribution network operators play a key role in ensuring

the integration of RES into the network and the transition to green energy. More specifically, in order to achieve all

the above objectives, the IElectrix considers the following innovative proposals at technical level: Mobile energy

storage systems and smart substations, Implementation of demand response programmes, Digitalization of the LV

distribution network.

COORDINET: The CoordiNet project aimed to demonstrate how Distribution and Transmission Network Operators

can act in a coordinated manner and use the same resource pool to supply network services in the most reliable

and efficient way, through the implementation of large-scale demonstrations in cooperation with electricity market

participants (and end-users).

ERIGRID 2.0: Making use of the results of the ERIGrid-1 project, the successor ERIGrid 2.0 project will extend the

research services and tools of the European research infrastructures for the validation of smart energy networks

with the electricity network as the backbone. Committed to a holistic approach to cyber-physical system-based

validation, ERIGrid 2.0 will promote system-level support and training for industrial and academic researchers in

power and energy systems research and their technology development.

ALFION: The aim of the project is to design the preliminary studies concerning the infrastructure inside the port of

Igoumenitsa for OPS/Cold ironing, RES and energy management systems. In addition, it aims to implement a

techno-economic analysis in order to further finance and implement the studies.

CENTAVROS: The aim of the project is to design the preliminary studies concerning the infrastructure inside Volos

port for OPS/Cold ironing, RES and energy management systems. Also, the implementation of a techno-economic

analysis in order to further finance and implement the studies.

CIPORT: The aim of the project is to design the preliminary studies concerning the internal infrastructure of the

port of Piraeus for OPS/Cold ironing, RES and energy management systems. In addition, it aims to implement a

techno-economic analysis for further financing and implementation of the studies.

ENFLATE: The project aims to develop a collaborative platform of tools enabling the creation of consumer-driven

business models for energy services, exploiting their flexibility potential, integrating them into other non-energy

services (multi-sector services) such as those concerning health and transportations.

EV4EU: The aim of the project is to develop innovative technologies for the smoother integration of large number

of Electric Vehicles (EVs), using smart and/or bi-directional charging, into the existing energy system infrastructure.

The tools to be developed under the project will promote coordination between electric vehicles and renewable

energy sources, reduction of greenhouse gas emissions and the decarbonization of the road transport.

ONENET: The aim of the project is to determine the design of a common electricity market for Europe. The project

is targeted at issues such as the standardisation of products and services designed for system operators and

coordination of all market actors from network operators to customers.

R2D2: R2D2 aims to improve the resilience and reliability of the current Energy Systems against an increasing

number of threats that may affect critical infrastructure, with detrimental and damaging effects on different

stakeholders and end customers. This will be achieved through the development of four tools dedicated to the

prevention, protection and recovery of the Energy System in two different independent but complementary

scenarios. The project will be based on the strong energy coordination activities in South-Eastern Europe, in line

with the EU legislation and will also be harmonized with the recent activities boosted by ENTSO-E on cyber security

in transmission systems.

SYNERGIES: The aim of the project is to develop innovative technologies for the exploitation of energy data

through the implementation of an Energy Data Space. The project promotes the creation of an ecosystem focused

on energy data while supporting the promotion of innovative applications. The applications focus on making use of

the available flexibility of consumers, optimising the operation of energy networks, maximising the integration of

RES and (auto)production, monitoring, operation, maintenance and designing of the system, as well as the TSO-

DSO collaboration to enhance system resilience, to encourage, inform autoproducers on flexibility markets, as well

as to strengthen the role of Energy Communities.

SYNERGY: The project introduces a new reference architecture and a Big Data platform that makes use of primary

and secondary data resulting from various sources (APIs, historical data, sensors/IoT, weather conditions, energy

markets and data open sources) aiming to help electricity stakeholders (Operators, RES Aggregators, Suppliers,

Producers, Building Managers) to enhance the accessibility of their data and improve the intelligence of their energy

optimization processes, leveraging innovative data exchange models (intelligence) to improve decision making. To

this end, SYNERGY will develop a Big Data and Market Analytics platform, accompanied by Big Data applications

for all electricity stakeholders.

PPC RENEWABLES SINGLE MEMBER S.A.

In the context of the Group's commitments to further reducing greenhouse gas emissions and enhancing the use

of renewable energy sources in the energy mix:

PPC RENEWABLES Single Member S.A. expanded the Group's portfolio of RES projects by acquiring 55% of the

shares of Volterra K-R S.A. and Volterra LYKOVOUNI S.A., in which it has already been a 45% shareholder in

each company since 2019. In this way, PPC RENEWABLES SINGLE MEMBER S.A. acquired 100% of three

operating wind parks of total capacity 69.7MW in Aitoloakarnania and Viotia. In addition, PPC RENEWABLES

SINGLE MEMBER S.A. acquired 100% of the company Iliofaneia S.A., which owns a 2.7 MW photovoltaic park in

operation in Viotia, as well as the companies Volterra DOUKAS S.A. and Volterra KOUKOULI S.A., which own

wind parks with a total capacity of approximately 40 MW, the construction of which has already been initiated.

During 2022, PPC RENEWABLES SINGLE MEMBER S.A. was declared as the preferred investor within the

framework of a tendering procedure carried out by Piraeus Equity Partners, through which a sale and purchase

agreement (SPA) was signed for the shares of companies that own wind parks with a total capacity of 43.8 MW

and photovoltaic parks of 2 MWp.

It is further noted that through its participation in the RAE's Joint Competitive Procedure 2/2022, the company

secured a Compensation Price for 4 PV stations with total capacity approximately 251MW, when the total capacity

of all projects that secured a compensation price in the said tender amounted to 538MW.

Moreover, the works for the construction of the AGIOS CHRISTOFOROSs 1, PTELEONAS 1, PTELEONAS 2,

CHARAVGI 1 and CHARAVGI 5 PV Stations of total capacity approximately 159MW have been initiated, while a

contractor was selected through a selection process for the Civil works and Interconnection works of the company's

PV station at "PPC Mine" in Ptolemaida, of total capacity 550MW.

In December 2022, the loan agreement for the 200MW PV station SOLAR ARROW ENA was signed, which

together with the company's two other projects in Kozani area, of total capacity 15MW each, marks the completion

of the company's flagship project concerning PV stations of total capacity 230MW. The project is co-financed by

the European Investment Bank, using funds from the Invest EU programme.

Finally, the Company is a pioneer in the development of Hybrid projects with its participation in the Competitive

Procedure 1/2022 of RAE for the implementation and operation of the Special Pilot Project in Astypalaia Island,

which will consist of new RES power plants combined with electricity storage facilities.

In general, at the end of the year 2022, PPC Renewables S.A. and by extension PPC Group, has a portfolio of

projects in operation with total capacity approximately 300MW, a portfolio of projects under construction with total

capacity approximately 700MW, while the Company's projects that are in a mature licensing stage, having received

environmental terms and/or a final connection offer, amount to approximately 4.1GW.

Research Programmes of Environmental Interest in which PPC RENEWABLES SINGLE MEMBER S.A.

participated.

Within 2022, the Company participated in the following research programmes in which PPC RENEWABLES

SINGLE MEMBER S.A. participated.

• Demonstration of a mobile unit for hybrid energy storage based on CO

capture and renewable energy sources –

CO2toCH4

• Maximizing the impact of innovative energy approaches in the EU islands – INSULAE

2. Labour Issues

Due Diligence Policies and Procedures

‘’PPC S.A.’’

PPC recognises that its human capital is the most valuable asset for the Company, to the extent that employees

deliver results and build its core competencies and competitive advantages.

It applies responsible human resources management practices and ensures the shaping of a modern work

environment of equal opportunities and mutual respect without discriminations. It is committed to safeguarding the

health and safety of its employees by implementing appropriate Occupational Health and Safety Management

Systems and carrying out relevant training programmes.

PPC Staff Regulations regulate, inter alia, the rights and obligations of employees, the terms of employment

contracts, the relationships formed during work and the implementation of disciplinary procedures.

The revised Recruitment Policy of PPC S.A. was approved by the Board of Directors' Decision No. 131/22-11-2022

as a result of article 185 of Law 4964/2022 and the fact that the Company's recruitments are no longer subject to the

legal framework of the Supreme Council for Civil Personnel Selection (ASEP). The new Recruitment Policy was

drawn up with the aim of attracting qualified and skilled candidates, capable of meeting the new challenges of the

market and supporting the Company's development goals, thus contributing to its rapid transformation. The

Recruitment Policy is aimed at filling vacant posts by external candidates who apply for jobs at personnel level with

open-ended or fixed-term agreements.

The recruitment of temporary personnel is carried out in order to meet temporary or seasonal needs upon decision

of PPC’s Chief Executive Officer. The said personnel signs fixed-term employment contractσ which may not exceed

eight (8) months within a total period of twelve (12) months.

In the light of reshaping the Personnel Recruitment Policy and in the context of the constant development and

constructive regular review of existing procedures and regulations, it was deemed appropriate to update the

Company's Executive Recruitment Policy, in compliance with the best practices of the market, with a view to

enhancing the Company's competitiveness and flexibility in attracting and selecting the appropriate executives with

the best skills for each position. In this context, the Executive Recruitment Policy was approved also by the Decision

of the Board of Directors No. 131/22-11-2022, aiming at filling vacant executive positions by external candidates who

apply for the specific positions. In accordance with the said Policy, an external candidate may fill an executive position

only in case no internal candidate with appropriate expertise, knowledge, skills, and experience qualified for the said

position. Moreover, the building blocks of PPC's Executive Recruitment Policy are to ensure equality at all levels by

avoiding any discriminatory treatment and promote diversity by respecting all internationally recognized human rights,

in order to achieve the implementation of the principles of an equal, fair and impartial recruitment process.

Moreover, provision is made for the recruitment of relatives of deceased employees (work-related fatalities), as well

as for filling vacancies by members of large families, people with disabilities and their relatives.

During the four-year period 2019-2022, 3 relatives of deceased employees in work-related accidents were hired by

the Company.

As of 31.12.2022, the number of employees with disabilities, employees who were members of large families and

relatives of persons with disabilities was 160, 213 and 76 respectively.

PPC has a Training Project Management System for the analysis and identification of training needs, the designing

of training programmes, the selection of trainees, the selection of trainers, the organisation and implementation of

training programmes and the evaluation of the training project (training cycle). The Company has an Executive

Training Policy (Board Decision No. 83/14-07-2021), which sets the framework for the training of executives at all

hierarchical levels, as well as of Specialized Executives.

The members of the Board of Directors, as well as the members of its Committees are remunerated based on the

relevant Remuneration Policy (the revised Remuneration Policy was approved by the Extraordinary General

Meeting of Shareholders dated 14.12.2022 and is posted on the Company's website).

The Company implements an Evaluation System which includes bar scales, weighting criteria, links between

assessed behaviours and the Company’s strategy and discloses to employees their assessment outcomes. In

this way, on one hand, employees clearly understand the requirements and expectations associated with their

role, and on the other, aim for optimal performance.

In addition to the above, the Company provides additional benefits to its employees, such as group health/life

insurance policy, food vouchers, loans and financial aids, special leaves apart from normal leave, a subsidy for

nursery care costs and a subsidy for further training of employees (e.g. obtaining a postgraduate degree).

HEDNO S.A.

The issues related to personnel, remuneration and the procurement policy of HEDNO S.A. are regulated according

to articles 3 to 9 of Law 4643/2019 (Government Gazette vol. A' no 193/03-12-2019).

The revised Remuneration Policy for Board Members, Committees and Executives of HEDNO,

as well as the Executive Recruitment Process were approved by resolution of the Company’s Extraordinary General

Meeting of Shareholders on 19.12.2022.

Moreover, within 2022 the Company adopted Rules of Operation, which also incorporate provisions related to

corporate governance issues.

Finally, HEDNO S.A implements an employee evaluation system based on the Special Regulation on Evaluation

Sheets, which is also posted on the company's internal intranet for the information of all employees.

PPC RENEWABLES SINGLE MEMBER S.A.

The Company has adopted a Human Resources Evaluation System since 2018 (Decision BoD/341/1/13.04.2018),

based on which the skills of its human resources are assessed in relation to the scope of work and the duties

assigned depending on the level of responsibility of each employee, the training needs are identified, and

performance is assessed and linked to remuneration and benefits. In addition, executives are evaluated based on

target setting, according to the Remuneration Policy

Finally, the remuneration of the Members of the Board of Directors is determined in the Remuneration Policy for

the Members of the Board of Directors and its Committees (Decision BoD//412/4/28.06.2021) approved by the

Ordinary General Meeting dated 28.06.2021. The Remuneration Policy was revised by the Extraordinary General

Meeting of the Shareholders on 20.12.2022.

Non-Financial Performance Indicators

[ATHEX C-S2 Female Employees]

[ATHEX C-S3 Female employees in managerial positions]

[ATHEX C-S7: Collective Labor Agreements]

[ATHEX A-S3: Pay gap between male and female employees]

[ATHEX A-S4: CEO/Employees pay ratio]

Indicator/Company

PPC S.A.

.(1)

HEDNO S.A.

.(2

)

PPC RENEWABLES S.A.(

(amounts in thousands

euros)

2022

2021

2022

2021

2022

2021

Total of employees as of

31.12

7,070

6,634

5,642

5,456

% Female employees in

the Company

27.80%

28.9%

26.07%

25.70%

31.8%

30.8

% of female employees in

managerial positions

31.7%

21.95%

32.08%

37.18%

2.3%

2.6

% of active employees

covered by Collective

Labour Agreements

97.2%

98.0%

93.65%

99.0%

79.5%

97.4%

Pay Gap between male

and female employees

(%)

3.43%

5.23%

12.63%

11.47%

25.28%

24.98%

Pay ratio of CEO

(including employer

contributions)

6.02

6.16

5.03

4.70

3.37

2.77

Pay ratio of CEO (without

employer contributions)

7.10

7.32

5.75

5.37

5.03

2.95

Notes:

PPC S.A.

-The figures of PPC S.A. also include the employees of Lignitiki Megalopolis Single Member S.A. and Lignitiki Melitis Single

Member S.A., given that the merger was completed in 2022 by way of absorption by the parent company.

-The total number of employees does not include employees with a Fixed Term Contract of up to 8 months and employees with

60 daily wages, employees who are seconded to insurance institutions and employees who are transferred to PPC

RENEWABLES S.A.

-The pay gap between male and female employees of PPC S.A. is in no case due to the discriminatory remuneration management

owing to gender. The payroll is formulated taking into account the use of allowances related to the nature of the job position which

affect the total regular remunerations e.g. positions in mines and power plants are mainly staffed by male employees.

(1) HEDNO S.A.

-For the indicators Gender Pay Gap and CEO Pay Ratio, the data based on total gross salaries of employees from the costing of

2022 only for regular personnel have been taken into account.

-With regard to the percentage of women in managerial positions, the calculation was made based on statutory positions and

relevant duties assignments (Assistant Director – Head of Unit and executives of higher level) and not according to the definition

of the indicator (i.e. 10% of employees with the highest total remunerations). If the proposed measures are implemented by

HEDNO S.A., the calculation will include not only employees in managerial positions but also many others (mainly technicians,

the majority of whom are men) who, due to the nature of their job, have increased remunerations due to overtime and increments.

The percentage of women according to the same calculation amounts to 11.17%.

(2) PPC RENEWABLES SINGLE MEMBER S.A.

-In the total number of employees as of 31.12 the following have been taken into account: for 2022, 33 employees with dependent

employment relationship and 11 employees transferred from PPC SA. and for 2021: 28 employees with dependent employment

relationship and 11 employees transferred from PPC S.A. It should also be noted that 24 employees of PPC S.A. in 2022 and 21

employees in 2021 provided support services to PPC RENEWABLES SINGLE MEMBER S.A through the new organisation

structure (matrix).

-For the indicator % of Female Employees in the Company, % of Female Employees in Managerial Positions and % of Active

Employees covered by Collective Labor Agreements, as well as the employees with dependent employment relationship of PPC

RENEWABLES SINGLE MEMBER S.A. (33) and those transferred from PPC S.A. (11) are taken into account; the employees of

the RES-related Departments of the parent PPC S.A. (24) are not taken into account

-For the indicators Gender Pay Gap and the Pay Ratio of the CEO, only the salaries of employees of PPC RENEWABLES

SINGLE MEMBER S.A. have been taken into account due to the limited access to the payroll data of the employees transferred

from PPC SA.

Occupational Health and Safety

Due Diligence Policies and Procedures

PPC S.A.

The health and safety of its employees is of top priority for PPC S.A. PPC's updated Occupational Health and

Safety Policy (which is posted on the Company's website https://www.dei.gr/el/dei-omilos/anthropino-

dynamiko/ygeia-kai-asfaleia-stin-ergasia/politiki-yae/ ) aims at taking all measures and providing all means and

necessary resources to safeguard the life as well as the physical and mental health of its personnel.

According to the policy, fostering a healthy and safe workplace for all employees, associates and visitors is at the

heart of PPC's business policy, which aims at continuously improving the work environment, the quality of work

performed, as well as the satisfaction and wellbeing of employees at all units of the Company.

The Management and all levels of hierarchy are committed to:

• Complying with the regulatory requirements of the applicable legislation on occupational health and safety,

as well with the company’s procedures and regulations.

• Preventing and eliminating occupational hazards at its source through scientific and systematic risk

assessment in workplaces.

• Ensuring health conditions and preventing occupational injuries and occupational diseases, with the aim to

eliminate accidents.

• Systematically informing workers on the risks at work and training them on the rules, regulations, and safe

working practices.

• Cultivating an internal culture, establishing safe working behavior.

• Continuously improving working methods and means to reduce hazards, by providing employees with the

most advanced personal and collective protective equipment.

• Obligating external partners to comply with the implementation of appropriate health and safety measures

and adopt a responsible policy.

• Cooperating with the relevant authorities and neighboring industries for joint health and safety measures

and procedures in order to avoid any large-scale industrial accident.

• Consulting with employees’ representatives and trade unions on the implementation of occupational health

and safety rules.

• The Occupational Health and Safety Department, which is responsible for addressing these issues, has

been awarded the ELOT EN ISO 9001 certificate for its Quality Management System. In addition, it holds a license

as an External Protection and Prevention Service Provider, capable of providing protection and prevention services

to customers inside and outside PPC Group.

• The Company employs a significant number of occupational physicians, safety technicians, nursing staff

and auditing physicians. Its priority is to cultivate a mindset focused on occupational safety. Indicatively, it is pointed

out that the company conducts personnel emergency response and preparedness training, training programs οn

safety measures, distribution of all necessary Personal Protective Equipment (PPE), measurements of harmful

factors in the Company’s workplace, as well as occupational risk assessment studies.

• The Company provides psychological and social worker services to its employees and shows great

awareness of the timely information and taking of measures in the event of epidemic viruses.

HEDNO S.A.

The company takes the required measures and has the necessary means and resources to ensure the protection

of the life and health of its personnel, the personnel of the Contractors, visitors and of all those who have access

to its units and facilities.

The scope of the Occupational Health and Safety Department (OHSD), which is responsible for the management

of OHS issues, is to ensure a safe working environment, to continuously improve working methods by providing

the necessary equipment, to prevent occupational hazards aiming at reducing work-related accidents, to safeguard

good health, as well as to systematically inform employees about the hazards at work and adequately train them

on safe working practices.

In compliance with the legislative framework, a significant number of safety technicians and occupational physicians

are employed in the OHSD to provide consulting on the implementation of safe working methods and the taking of

necessary protective means. Its priority is to shape and promote a safety culture in the Company.

PPC RENEWABLES SINGLE MEMBER S.A.

PPC Renewables S.A. is fully aligned with the Health and Safety Policy of the parent company PPC S.A., and has

adopted and fully implements the Group’s Health and Safety procedures. In addition, it has concluded an

agreement with the OHSD/PPC, the licensed External Prevention and Protection Service Provider (EPPSP), which

provides consulting on occupational health and safety issues and consistently provides support for the assessment

of occupational hazards, for the emergency response planning, legislative compliance, etc. At the same time, it

offers Occupational Physician services to PPC RENEWABLES SINGLE MEMBER S.A.

Moreover, the Company has an autonomous Occupational Health and Safety Policy and has incorporated P.10

[Occupational Health and Safety Risk Identification and Employee Safety Management Process] into the integrated

Quality, Health Safety & Environment System in accordance with ISO 9001, ISO 14001, ISO 45001 standards.

Non-Financial Performance Indicators

Indicator/Company

PPC S.A.

HEDNO S.A.

PPC

RENEWABLES

S.A.

2022

2021

2022

2021

2022

2021

Total number of employee accidents

according to ESAW

(1)

Total number of fatalities involving

employees

1**

Total number of fatalities involving

staff of contractors

3***

2****

** Death from pathological causes

*** 3 fatalities (3 deaths in total)

**** 2 group fatalities (4 deaths in total)

(1) The methodology taken into account is the “European statistics on accidents at work (ESAW) - Methodology -2001

edition” also used by EU - ΟSΗΑ and EURELECTRIC. The number of accidents includes all work-related accidents involving

regular and seasonal/temporary employees, which caused absence from work for more than three (3) calendar days. Accidents

occurring while traveling to and from work, as well as cases of sickness, which are examined separately (from a statistical

viewpoint), are not included.

(2) The companies Lignitiki Magalopolis Single Member S.A. and Lignitiki Melitis Single Member S.A., which were merged

within 2022 with PPC S.A. are included.

3. Social Issues

Due Diligence Policies and Procedures

For PPC Group, contribution to local communities is inextricably linked to its business activities as it ensures a

sustainable future for local communities and stakeholders, as well as for the Group itself.

Taking into consideration the sustainability priorities and social issues, PPC Group Companies actively respond

through their social actions, as well as through their business model and mode of operation. These actions involve,

inter alia, the development of local communities and the economy, alleviation of poverty through sponsorships and

donations, quality education and promotion of professional orientation for young people, as well as actions for the

environment aiming at improving the environment both at local and a wider level, in the light of Creating Shared

Value for all – the Society, the Environment and the Economy. It also includes activities developed over time that

take place every year or where appropriate and pertain to health, sports, culture, and education, aiming to enhance

the positive impact achieved in the long term.

The Group is also committed to constantly improving its policies and practices to create a positive impact, by

integrating frameworks, techniques, social innovation tools and ensuring their implementation, in order to optimize

and make its actions more effective. These practices include the shaping of an appropriate strategy, the planning

and implementation of actions, due diligence procedures, as well as target-setting and measurement of the

outcomes of Social Innovation, contribution and social impact initiatives and actions which are, directly and

indirectly, associated with PPC value chain.

Customer-centric approach - Care for vulnerable customers

PPC S.A.

PPC is tuned with the needs of our time and is continuously developing its services in order to provide immediate

and effective customer service. In 2022, PPC's second pilot store opened in Kallithea, with an emphasis on

designing digital solutions that further improve customer experience, both by designing different service zones to

meet customer needs and by installing bill payment systems that reduce time for payment processing. In addition,

MyEnergy Coaches in the majority of PPC Stores are available to give customers personalised advice on energy

saving in their households. Finally, the new Satellite Store at Metro Mall is the first fully digitalized self-service PPC

Store.

PPC's products were further enhanced through the launching of a new range of add-on services, such as FixIt,

FixIt Dual & FixIt Pro, which provide direct technical assistance to residential and business customers.

PPC's activities were further reinforced through strategic partnerships and continuous communication based on

the pillars of sustainability and customer service. Specifically, consulting became a key strategic pillar through PPC

myEnergy communication platform that includes advice on energy and sustainability issues, as well as digital

energy saving tools such as PPC myEnergyCoach, while we focused on actions that promote new customer

services that facilitate access and simplify processes such as myDEI and E-contract.

Moreover, taking into account that the accessibility to PPC's services with no exclusions constitutes a moral and

social obligation, the Company has extended its customer service to people with hearing impairments. More

specifically, customer service can take place via video call with the simultaneous presence of a service

representative and a sign language interpreter. In addition, real-time subtitles are available.

Finally, acknowledging the difficulties faced by its consumers due to the energy crisis, PPC fully implemented the

State's support measures, incorporating subsidies to eligible customers in both electricity and natural gas, while

offering favorable solutions for bill payment with interest-free installments through credit cards and favorable

settlement programmes for customers facing severe economic difficulties.

Non-Financial Performance Indicators

The table below depicts the amounts allocated to donations and sponsorships, support to local communities and

bodies/organisations for the financial year 2022:

Indicator/Company

PPC S.A.

HEDNO S.A.

(3)

PPC RENEWABLES S.A.

(amounts in thousands

euros)

2022

(2)

2021

2022

2021

2022

2021

Social Contribution-

Amounts

(1)

allocated to

donations and

sponsorships, support

to local communities

and

bodies/organisations

6,441.5

5,368.7

874.7

446.7

149.06

43.2

(1) Amounts relating to donations-sponsorships and entered in the accounts from 01-01 to 31.12.2022

(2) Including the companies Lignitiki Megalopolis Single Member S.A. and Lignitiki Melitis Single Member S.A. since they were

merged with the parent company PPC S.A. within 2022.

(3) Including sponsorships with 2% promotion fee

The table below depicts the frequency of service interruptions for the year 2022 according to the data provided by

HEDNO S.A:

Index/Financial year

2022

2021

(1)

System Average

Interruption Frequency

Index (SAIFI) (number of

interruptions per

customer)

1.81

interruptions/customer

2.0

interruptions/customer

System Average

Interruption Duration

Index (SAIDI) (annual

interruption time in

minutes per customer)

137.99

minutes/customer

144.5

minutes/customer

(1) Final data of service quality report 2021

4.Combatting Corruption and issues relating to bribery

[ATHEX SS-G1: Business Ethics Violation]

Due Diligence Policies and Procedures

PPC S.A.

It is crucial for the Company to comply with the law and respect the principles οf its Regulations and Policies. In

order to ensure control and compliance with the above, PPC has established internal procedures and organizational

structures such as the Internal Audit Department (IAD), the Compliance Department (CD) and the Risk Management

Department (RMD), all of which constitute a fully organized corporate Internal Audit System.

Furthermore, the Company, through the Compliance Department (CD), adopted by Board Decision

No.71/09.06.2022, the Anti-Corruption and Bribery Policy, the implementation of which will strengthen, in

combination with the already existing internal regulatory framework of the Company, the prevention and effective

fight against bribery and corruption incidents within the Company.

The said Policy is integrated into the "Ethical and Business Conduct Programme" Project, in the context of which

ethical rules were redefined in line with the international best practices and new Regulations, Policies and

Procedures were drafted or existing ones were revised, the adoption of which was completed within 2022. The said

Policies, along with the revised Code of Conduct, contribute to the promotion of transparency and integrity within

the Company and establish a culture of ethics and conduct.

Specifically, by Board Decision No. 82/14.07.21, the Conflict of Interest Policy has been approved since 2021,

aiming not only to eliminate and properly manage conflict of interest situations, but mainly to create a business

culture that will prevent such phenomena. Moreover, by Board Decision No. 30/06.04.21, the Anti- Money

Laundering and Counter-Terrorism Financing Policy was approved, which is applicable to wholesale

transactions and futures/option contracts, provided however that the value of the above transactions amounts to at

least ten thousand (10,000) euros, regardless of whether they are carried out in a single operation or in several

operations which appear to be linked. Furthermore, in order to meet the specific needs of the Energy Management

& Trading Business Unit (EMT/BU), a position of Energy Transactions Compliance Director has already been

established as of September 2021, entrusted with the task of continuous monitoring the institutional framework

governing energy transactions and the implementation of the Energy Transactions Compliance Programme, which

is part of the Corporate Compliance and Business Ethics Programme.

Subsequently, within 2022, the following were approved by relevant Board Decisions.

• Revised Code of Conduct (No. 72/09.06.2022), which is a mandatory standard of conduct for all

employees that must always be applied strictly and without deviations, while it defines and discloses to the related

third parties the requirements of the Company towards them in the context of their cooperation,

• The Policy against Violence and Harassment at Work (Νο. 18/1-03-2022) by virtue of Law 4808/2021,

• The Enforcement Policy & Report/Complaint Handling Procedure (No. 19/01.03.2022) which aims to

ensure that all violations of the Compliance and Business Conduct Programme, including the Company's Code of

Conduct, shall be investigated and examined in a fair and consistent manner, while protecting the rights of all

parties, thus contributing to proactively addressing phenomena that may affect the Company's reputation and

credibility.

The Company, in any incident of corruption that comes to its attention, either after a complaint or after an audit

conducted by a Head of Unit and/or the Internal Audit Department, and following thorough investigation, initiates

disciplinary proceedings for the employees involved, in accordance with the provisions of Chapter F of PPC’s Staff

Regulations. For the most part and given the seriousness of the misconducts performed by the employees involved

in such cases, such disciplinary proceedings shall be reported by the CEO to the Primary Disciplinary Board, which

may impose any of the sanctions designated in the Staff Regulations (Articles 26 and 32 of the Staff Regulations).

Incidents of misconduct which constitute criminal offences shall be reported to the competent judicial authorities. It

is noted that the provisions of the Enforcement Policy & Report/Complaint Handling Procedure supplement the

above procedure with new provisions (proportionately to those under the Staff Regulations) in order to deal

correspondingly with potential violations by employees/executives whose contracts are not subject to PPC’s Staff

Regulations.

Pursuant to the Enforcement Policy & Report/Complaint Handling Procedure an executive of the CD was appointed

as the Company's Whistleblowing Officer, entrusted with the task of handling the report/complaint channel

(whistleblowing channel), ensuring their proper handling and maintaining communication with the complainant,

while three (3) channels for the submission of Reports and Complaints within the Company have been in operation.

Τhe CD handled fifteen (15) cases under the Enforcement Policy & Report/Complaint Handling Procedure during

2022.

Τhe Company also takes the appropriate measures, in accordance with the provisions of Law 4557/2018, as

applicable, with regard to the prevention and suppression of money laundering and terrorism financing. During

2022, under the Company's Anti-Money Laundering Policy, the Compliance Department drafted implementation

instructions, conducted a training seminar for the competent executives and carried out a spot check.

It has also introduced in its internal regulatory framework of operation (Code of Conduct, Model Documents for

contract awards, etc.) and implements provisions concerning:

• transparency (Code of Conduct: § 9).

• corruption (Code of Conduct: § 10, Articles 26 and 32 of the Staff Regulations).

• fraud (Code of Conduct: § 12).

• special provisions in the Regulation on Works, Supplies & Services concerning compliance with the Policies of the

"Ethical and Business Conduct" Programme. By way of example, the signing of a Certificate of Acceptance of the

Company's Code of Conduct by contracting parties, KYC form and an absence of conflict of interest form at all

stages of the tendering procedure, the exclusion from its contracts of economic operators who have either been

convicted by an irrevocable decision for any of the offences of corruption-bribery, participation in a criminal

organisation, committing terrorist acts, child labour, money laundering and fraud, or have been sanctioned for

violations of labour law (Decision of PPC’s CEO No. 70/2022: "Approval of Model Documents for the conclusion of

contracts for Works, Supplies and Services), article 4 of the Regulation on Works, Supplies and Services (Exclusion

of Economic Operator): PPC’s Board Decision 4/09.02.2022 "Approval of PPC S.A. Regulation on Works, Supplies

and Services and 3.4.3 in PPC S.A. Procurement Manual (PPC’s Board Decision 58/06.06.2022).

Moreover, pursuant to the Conflict of Interest Policy of PPC S.A., through which the Company provides support,

information and guidance to the entire personnel at all levels regarding the principles and rules for the prevention

or management of conflict of interest situations and the way to implement them, the following are underway:

• It is the practice of the Board of Directors, at the beginning of each meeting, to submit a declaration of absence of

conflict of interest

• Signing of a declaration of non-conflict of interest at all stages of the tendering procedure in which the participants

declare that there is no conflict of interest

• Declaration of absence of conflict of interest in the recruitment process

• Establishment of an annual register of declarations of absence of conflict of interest during the performance of their

duties by all the Company's executives.

In addition, within 2022, spot checks were carried out in operational areas of "high" risk for the implementation of

the Programme's Policies (ongoing monitoring), which will be intensified in 2023.

The actions of the CD to further deepen the Programme Policies and integrate them into the Company's Business

Operations, as well as the collaborations with external operators will continue in 2023, with the aim to improve the

efficiency of the actions to enhance integrity and transparency, fight corruption and raise awareness among

employees/partners.

HEDNO S.A.

The Company implements a Code of Conduct, which in especially in Article 11 (on bribery issues) and more in

particular in Articles 3, 8, 9, 10, 16, 18 and 20 thereof (on business ethics in general), contains provisions on the

issues of combating bribery and business ethics in general. Moreover, the recently adopted (August 2022) Rules of

Operation of HEDNO S.A. contain important provisions regarding business ethics and anti-bribery issues, such as

in Articles 21 - 24 on the Internal Audit System of the company, Article 26 on Conflict of Interest and Article 27 on

Abti-Money Laundering and Countr-Terrorist Financing. According to the opinion of the Legal Department, there are

currently no individual - separate policies - codes of conduct or anti-bribery policy in the company.

PPC RENEWABLES SINGLE MEMBER S.A.

PPC RENEWABLES SINGLE MEMBER S.A. has a Code of Conduct and in 2022, by BoD Decision No.

436/2/04.08.2022, the Company adopted the Anti-Corruption and Anti-Bribery Policy. Moreover, the following

policies were adopted by the same decision:

• - Anti-Corruption and Anti-Bribery Policy,

• - Policy against Violence and Harassment at Work,

• - Human Rights Policy,

• - Enforcement Policy & Report/Complaint Handling Procedure and

• - Revision of the Code of Conduct of PPC RENEWABLES S.A.

Non_Financial Performance Indicators

Indicator/Company

PPC S.A.

HEDNO S.A.

PPC RENEWABLES

S.A.

2022

(3)

2021

2022

2021

2022

2021

Criminal court convictions for matters

falling under the criminal offences of

corruption, abuse of power,

embezzlement, theft, fraud, bribery,

accepting bribery, fraud, forgery, false

certification or falsification of

documents, use of false certification and

official secrecy violation (number of

court decisions

(1)

Employees on whom the Company has

imposed disciplinary sanctions in

relation to offences of corruption, abuse

of power, embezzlement, theft, breach

of trust, bribery, accepting bribery,

fraud, forgery, false testimony or

falsification of documents, use of false

certification and official secrecy violation

(number of employees) (2)

(1) These are final judgments of criminal courts. The indicator concerns employees while performing duties as employees of the

Company. The indicator refers to regular, temporary or seasonal personnel excluding seconded staff, contractors and their

personnel.

(2) The disciplinary sanctions imposed in 2022 concern employees who did not hold a managerial position of any hierarchical level.

In 2021, six (6) cases involved employees with no assignment of duties of any hierarchical level and one (1) case involved an

employee who, at the time the misconduct occurred, was serving as Head of Section and whose duties were revoked after the

misconduct was identified.

(3) Including the companies Lignitiki Megalopolis Single Member S.A. and Lignitiki Melitis Single Member S.A. which within 2022

merged with the parent company PPC S.A.

5. Respect for Human Rights

[ATHEX C-S6 Human Rights Policy]

[ATHEX C-G6 Data Security Policy]

Due Diligence Policies and Procedures

PPC S.A.

PPC respects and defends the protection of human rights and strictly condemns child labour, forced and compulsory

labour, as well as all forms of discrimination. The respect and protection of human rights in the workplace primarily

concerns:

• Providing equal opportunities in the recruitment, placement, training, remuneration, and promotion process within the

Company (Code of Conduct § 1 and 2).

• Ensuring the health and safety of its employees (PPC Health and Safety at Work Policy and Code of Conduct § 3) and

its contractors’ employees (Management Decisions).

• Compliance with applicable legislation on remuneration, working hours, overtime and allowances for PPC’s

management, executives and staff (Remuneration Policy of Board Members and its Committees, and the Recruitment

and Remuneration Policy of Corporate Executives, PPC Staff Regulations, PPC enterprise-specific collective labour

agreement, etc.).

• Freedom of association and collective bargaining (collective labour agreements, etc.).

• Refraining from employing individuals under 18 years of age.

• Condemning discrimination, harassment, offensive or inappropriate behaviour, unfair treatment or reprisals of all kinds

(PPC Staff Regulations, Chapter D, article 19 and article 26 par.3 Code of Conduct§ 13).: The Company has in place

a Policy against Violence and Harassment at Work, in compliance with Law 4808/2021 for labour protection, which was

approved by the Board of Directors' Decision No18/01.03.2022

• Ensuring a work-life balance for its employees (PPC Staff Regulations, Collective Labour Agreements, Management

Decisions, etc.).

• Providing incentives to stimulate enhanced employee performance, increase productivity and reduce absenteeism

(CEO Decision).

Board of Directors decision No 54/6.6.2022 established the Company’s Human Rights Policyhttps://www.dei.gr/el/dei-

omilos/i-dei/etairiki-diakivernisi/kodikes-kanonismoi-kai-politikes/

The Policy establishes a framework for the respect and protection of Human Rights, both within the Company and in

its sphere of influence.

The Policy expresses the intention of PPC S.A. to show zero tolerance for the violation of Human Rights, by avoiding

both such violations by persons falling within the scope of the Policy, and transactions with third parties that may have

demonstrably (at least through the issuance of a first instance court judgement) caused violations of these rights.

Furthermore, the purpose of the Policy is to raise the awareness of employees and all parties involved regarding the

respect and protection of Human Rights in all aspects of the Company’s business activities, including its subsidiaries.

The Policy is binding for:

(i) The members of the BoD

(ii) The executives; and

(iii) Employees with dependent employment contracts, service providers under salaried or non-salary contracts,

project contracts, independent services and temporary employment contracts, trainees, interns and volunteers,

and employees of third-party service providers.

PPC S.A. ensures that it cooperates with suppliers and other third parties who adopt similar policies in their

business.

Within its field of action, PPC S.A. acts proactively and strongly supports, respects and protects human rights:

➢ Life, Health and Safety at work

➢ Appropriate working conditions

➢ Freedom of association and collective bargaining

➢ Prohibition of Discrimination/Violence and Harassment at work

➢ Child Labour

➢ Slavery, forced labour and human trafficking

➢ Personal Data Protection

➢ Anti-corruption

➢ Protection of the Environment

➢ Local Community Rights

➢ Disciplinary practices

Employees are responsible for compliance with the principles and rules set out in the Policy.

Violation of the Policy is not tolerated and may result in the sanctions prescribed by the regulatory and legislative

framework in force from time to time.

Each employee who becomes aware of a breach of this Policy by another employee shall report it, in accordance

with the provisions of the Company’s “Sanctions and Whistleblowing Policy”.

With regard to non-discrimination when promoting employees, it is noted that:

• in 2014, women held 17% of the Company's managerial positions, while in 2022 they held 32% – an increase of

88.2%.

• in 2014, women represented 31.5% of middle managers, while in 2022 the corresponding percentage amounted to

45%, representing an increase of 42.9%

• the percentage of women among all graduates from which the Company's managers are selected, was

approximately 35% in 2020, compared to 36% in 2021 and 37% in 2022.

Data security policy

In 2022, the Company, through an extensive cybersecurity transformation programme, ensured its integration into

the broader corporate strategy, from the development of new digital products and services to ensuring the

confidentiality, integrity and availability of information and data of both the Information Technology (IT) and

Operational Technology (OT) environments.

In the broader context of the transformation, the already existing Framework of Information Systems Security (FISS)

has been updated, describing the basic security requirements in terms of:

• risk assessment;

• supply chain risk management;

• identity management and access control;

• system and application security throughout their life cycle;

• threat detection and response to vulnerabilities and risks;

• management of security incidents;

• awareness-raising and training of its personnel and partners regarding information security;

Personal Data Protection

PPC attaches great importance to privacy and the protection of personal data of both employees and other

stakeholders. In compliance with the provisions of the General Data Protection Regulation (GDPR) EU 2016/679,

as well as with L. 4624/2019, the Company has adopted a series of Policies and Procedures aimed at the high

level and effective protection of the personal data of its employees, customers and partners. Specifically:

• By Decision No 147/23-11-2021, the Board of Directors approved the updated Personal Data Protection Policy.

• A series of communication and training activities has been carried out to raise awareness of data protection issues.

• Guidelines for the preparation of a Data Protection Impact Assessment (DPIA) on critical business processes were

issued

• A special procedure for the drawing up of a Data Processing Agreement (DPA) has been included in the Regulations

on Works, Procurements and Services.

Freedom of Association

PPC supports the freedom of association of its staff. The employees participate in various labour unions with which

there is a two-way communication with the Management of the Company. Basic human resources arrangements

are the primary concern of consultations between the Company's Management and the unions. Within the Company

there are two Federations (General Federation of PPC Electricity Sector Personnel and Electricity Industry Workers’

Federation) and 29 first level unions.

Trade unionists among employees are protected under relevant legislation (with regards to transfers and

dismissals).

Trade union activity is facilitated through appropriate leaves, in addition to those provided for in the relevant

legislation, in accordance with the Collective Labor Agreement.

Enterprise-specific collective labour agreements are signed, usually with a 3-year duration, following collective

bargaining (in effect from 24.3.2021 with a 3-year duration).

HEDNO S.A.

HEDNO S.A. has a Code of Conduct which includes provisions for the protection of human rights, and in particular

Articles 2, 3, 8, 13 and 14 thereof. Provisions on this matter are also included in Articles 29 and 30 of the recently

adopted (August 2022) HEDNO S.A. Regulations on training of the Company’s executives and on sustainable

development. According to the legal department, at this time in there are no distinct policies in the field of human

rights at HEDNO S.A., although significant additional regulations in these fields are expected to be included in the

new and reformed Code of Conduct for HEDNO S.A., which is being prepared.

Personal Data Protection

HEDNO S.A. has a Data Security Policy (https://deddie.gr/el/oroi-xrisis-asfaleia/politiki-prostasias-prosopikon-dedomenon/)

The main data protection standards which the Company recognizes and/or commits to are:

• GDPR,

• NIS,

• ISO 27001:2013 (The Directorate of Informatics and Digitisation) has already been certified according to ISO 27001

from December 2019 to this day) and,

• National Cyber Security Strategy (2020-2025).

PPC Renewables S.A.

Within 2022, with Decision No ΔΑ/ΔΣ/436/2/04.08.2022 the Company adopted the Human Rights Policy.

Regarding data security, the Company has a backup policy for digital data and the notification of interested parties

on the processing of personal data.

Non-Financial Performance Indicators

Indicator/Company

PPC S.A.

HEDNO S.A.

PPC

RENEWABLES

S.A.

(amounts in thousand

euros)

2022

(2)

2021

2022

2021

2022

2021

Court convictions on

incidents of human rights

violations in the

workplace (number of

incidents)

(1)

Employees subject to

disciplinary penalties by

the Company for

incidents of human rights

violations in the

workplace (number of

employees)

(1) The indicator is related to final judgements in criminal courts and concerns employees of the Company in the context of exercising

their duties by virtue of their status as employees of the Company.

(2) This includes the companies Lignitiki Megalopolis Single-Member S.A. and Lignitiki Meliti Single-Member S.A. which in 2022

merged with the parent company PPC S.A.

Responsible Supply Chain

Due Diligence Policies and Procedures

PPC S.A.

In order to meet its needs in materials and services, as well as to carry out technical works, PPC S.A. enters into

agreements/contracts with suppliers, giving priority, where feasible, to local suppliers, with the aim of supporting

and developing local economies.

After the completion of the Company’s Share Capital Increase on 16.11.2021 and the subsequent change in the

composition of its Share Capital, where the participation of the Greek State stands at 34.12%, PPC no longer falls

under the subjective scope of a number of provisions, among which is Directive 2014/25 and Law 4412/2016, as

amended, while the provision of Article 9(4) of Law 4643/2019, according to which the contracts for works,

procurements and services of PPC S.A. are awarded in accordance with the Company's “Regulations on Works,

Procurements and Services” remains in effect. As a result of the above, the procedures for awarding procurements,

services and works in 2022 are now carried out according to the provisions of the Regulations on Works,

Procurements and Services of PPC (Decision no. 4/09.02.2022 of the Board of Directors of PPC), the Procurement

Manual (Decision No. 58/06.06.2022 of the Board of Directors of PPC) and the Template Contract Documents

(Decision number 70/2022 of PPC’s CEO), which constitute the internal framework for the conclusion of PPC

contracts. The full text of the Regulations on Works, Procurements and Services of the Company governing the

awarding procedures is posted on the Company's website (https://eprocurement.dei.gr/pages/information/).

The procedures for selecting contractors are divided into: Single-Stage Selection Procedures and Multi-Stage

Selection Procedures.

The Company is in constant communication with key suppliers to exchange views on the behaviour of the

equipment supplied and to transfer know-how to them. The main categories of procurement include materials -

spare parts, fixed support equipment, services, works, liquid fuels, lignite (by third parties), natural gas, procurement

of electricity and greenhouse gas emission rights.

In order to ensure that contractors and any subcontractors comply with labour and insurance legislation for their

staff, depending on the type of service provided, PPC includes a general clause in all contracts it enters into, which

provides for the termination of the contract and exclusion of the contractor from future tender procedures in the

event of repeated non-compliance. For each payment to a contractor (for the above cases provided for in the

contract), PPC requires evidence that the contractor has fulfilled its labour obligations towards its staff and paid the

corresponding employer's contributions. In this way, the Company ensures that it concludes contracts with

contractors who comply with labour law and have their staff insured as provided for in the relevant legislation.

HEDNO S.A.

The procedures for the procurement of materials, works and services shall be carried out in accordance with the

Regulations on Works, Procurements and Services of HEDNO S.A., as amended and in force as of August 2022,

ensuring that transparency and objectivity are complied with.

Tender processes with a budget above €60,000 are carried out electronically via the sourceONE platform of

cosmoONE, which is the e-Tender System used by the Company.

Selection procedures provided for by the Regulations of 2022 include the Open Procedure, the Restricted

Procedure, the Negotiated Procedure, the Competitive Dialogue, the Innovation Partnership. Moreover, regarding

special economic operator selection systems, starting in 2021, the procedure of the call for the inclusion of

economic operators in prequalification systems for categories of materials such as Centrifugal Concrete Poles, MV

Measurement Transformers and Synthetic Insulators was launched.

The implementation of the digital signature, electronic distribution and approval of tender procedures via an

application, etc., as well as the introduction of tools, such as e-auctions, which enable the achievement of highly

competitive prices, are illustrative examples of the company's consistent commitment to the digitalisation of

procurement procedures. Furthermore, the use of Business Intelligence tools for the analysis of expenses and the

monitoring of performance indicators on the progress of the tender and purchasing procedures contribute to the

identification of points for improvement, reduction of time and cost parameters, and overall rationalisation and

optimisation of procedures.

The Company's cooperation with contractors is governed by strict compliance with the provisions of labour and

insurance legislation for employees, which is ensured by the terms of the contracts concluded.

The major changes during 2022 relating to the operation and optimisation of the supply chain, include the full

implementation of a Telematics System on the Company’s vehicle fleet (full logging of routes, traffic parameters

and preventive vehicle inspection data and interconnection with existing systems), as well as the long-term lease

of two hundred and ninety-two (292) electric vans, aiming at the electrification of the Company’s fleet to be

implemented within 2023.

PPC Renewables S.A.

The procedures based on which the Company selected contracting parties for Works, Procurements and Services

contracts in 2021-2022 were based on the Regulation on Works, Procurements and Services of PPC Renewables

S.A. (its latest version was adopted by decision of the Company’s BoD in February 2022 and can be found on the

Company’s website https://ppcr.gr/images/eprocurement_v2_final.pdf).

The subject of the Regulations in question are the Procedures prior to the conclusion of contracts for works,

procurements and services of the Company, irrespective of the amount, by which the Company will select its

contractors. These Procedures may be conducted in one or more Stages, in accordance with the provisions of the

Regulations and the relevant documents, while the relevant Calls for the initiation of the Procedures may be

published or sent to selected Interested Parties.

Selection Procedures are implemented in compliance with the principles of transparency, equal treatment and non-

discrimination of the interested parties, protection of fair and free competition, protection of the environment and

sustainable development, taking care to ensure the efficiency of the procurement procedures.

Results of Policies/Non-Financial Performance Indicators

For PPC S.A., in 2022, there were no incidents of labour law violations by contractors, and specifically:

With regard to contracts handled by the Supply Chain & Corporate/Commercial Operations’ Procurement

Department of the Company, there was no labour law violation by contractors for 2022. The same applies for the

Production Operations Procurement Division. With regard to the projects under the responsibility of the

Hydroelectric Engineering and Construction Division, there were also no incidents of labour law violations in 2022

by the cooperating Contractors. The same also applies for the Division of the Lignite Centre of Western Macedonia

, the Division of the Lignite Center of Megalopolis and the Thermal Projects Engineering and Construction

Department.

Similarly, for subsidiaries HEDNO S.A. and PPC Renewables S.A., there was no notification/ascertainment of an

incident of labour law violations by contractors in 2022.

4. Purpose of the non-financial information provided and its data quality.

Further to the recommendation of the European Securities Markets and Authority (ESMA) and of the Hellenic

Capital Market Commission Letter 2708/9-11-2022, the Non-Financial Report of FY2022 should include information

on the purpose of non-financial reporting (value chains) and the quality of its data.

The Company integrates the impact of the value chain into its performance in two ways:

1. Regarding its carbon footprint, PPC includes in its own performance the performance of its supply chain through

the calculation, monitoring and preparation of actions to improve its Corporate Carbon Footprint. The Company’s

Corporate Carbon Footprint is the sum of direct (Scope 1) and indirect (Scope 2 and 3) greenhouse gas (GHG)

emissions resulting from its activities. In particular, regarding indirect GHG emissions, selected subcategories that

depend directly on the operation of the supply chain (type, intensity and characteristics of supplies) are calculated

separately and appropriately evaluated. In fact, following the recent adoption and formalisation of a carbon footprint

calculation process which also includes external verification, PPC will further improve supply chain performance

with focused actions derived from monitoring the historical evolution as well as changes in the relevant figures.

2. Incorporation into the Company's Regulations on Works, Procurements and Services of aspects of its Code of

Conduct, and in particular in the revised Regulations and specifically articles 4 and 13, as well as the Procurement

Manual (Chapter 2 “Procurement Procedures Framework” and Chapter 3.4 "Grounds for exclusion"). More

specifically, the Company may exclude suppliers from the selection procedures if reasons are ascertained that cast

doubt on their integrity and reliability, including non-compliance with labour and environmental legislation,

corruption and bribery, child labour, etc.

With respect to the quality of the data of the Non-Financial Report, the NFR is prepared based on a comprehensive

and strict data and information collection process implemented by the Sustainable Development Division using

various IT systems, applications, files and institutionalized/established policies as well as the preparation of

controls . This data and the information collected and calculated from the databases kept at PPC's central services,

as well as at its individual Divisions / Departments, are also taken into account in the annual Sustainability Report.

The Sustainability Report is approved by the Sustainability Committee and its content is brought to the attention of

the Company's Audit Committee, as well as to the attention of the Board of Directors of PPC SA. and the important

subsidiaries of HEDNO S.A. and PPC RENEWABLES S.A. In addition, the Sustainability Report is subject to

external assurance by an independent body, in accordance with the ISAE 3000 International Standard for

Assurance Engagements.

5. Information of Article 8 of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18

June 2020 on the establishment of a framework to facilitate sustainable investment, as well as of Delegated

Regulation (EU) 2021/2178 of the Commission of 6 July 2021 supplementing Regulation (EU) 2020/852

The EU Taxonomy Regulation (2020/852/EU) is one of the tools established based on the European Green Deal,

which aims to the transformation of the European Union, in a fair manner, into a modern, efficient, competitive and

climate-neutral economy by 2050.

The Regulation establishes the technical criteria for determining whether an economic activity qualifies as

environmentally sustainable. Consequently, the Regulation sets a common classification system that investors can

use, when investing in economic activities that have a significant positive impact on the climate, the environment

and the society.

For an economic activity to qualify as environmentally sustainable i.e., Taxonomy-aligned, the activity is required to

meet all the following requirements:

• Be Taxonomy-eligible, which means to be recognized (based on its NACE code) that it could potentially have a

substantial contribution to one or more of the six (6) environmental objectives set by the Regulation

• Contributes substantially to one, or more, of the six (6) environmental objectives set by the Regulation

• Do not significantly harm any of the other five (5) environmental objectives

• Comply with the minimum social safeguards

• Comply with the technical screening criteria as set by the Commission

The six environmental objectives set by EU Taxonomy Regulation are the following:

• Climate change mitigation

• Climate change adaptation

• Sustainable use and protection of water and marine resources

• Transition to a circular economy

• Pollution prevention and control

• Protection and restoration of biodiversity and ecosystems

Currently, according to the Delegated Acts 2021/2139 and 2022/1214, there are available technical screening

criteria only for the two (2) of the six (6) environmental objectives, and specifically for:

• climate change mitigation and

• climate change adaptation.

Disclosure requirements of EU Taxonomy Regulation

According to Article 8, paragraph 1, of EU Taxonomy Regulation (2020/852/EU), any undertaking that is subject to

an obligation to publish non-financial information (according to article 19a and 29a of Directive 2013/34/EU), shall

include in its non-financial statement or consolidated non-financial statement information on how and to what extent

the undertaking’s activities are associated with economic activities that qualify as environmentally sustainable.

Specifically, for disclosures that are published during 2023, concerning the financial year 2022, the non-financial

undertakings should disclose the following key performance indicators (KPI):

• the proportion of their turnover («Turnover») derived from products or services associated with economic activities

that qualify as environmentally sustainable

• the proportion of their capital expenditure («CapEx») related to assets or processes associated with economic

activities that qualify as environmentally sustainable.

• the proportion of their operating expenditure («OpEx») related to assets or processes associated with economic

activities that qualify as environmentally sustainable.

For reports published during 2022, concerning the financial year 2021, the non-financial undertakings had to

disclose the above-mentioned key performance indicators concerning only Taxonomy-eligible and Taxonomy-non

eligible economic activities.

EU Taxonomy Reporting

The methodology for the determination of the key performance indicators of PPC Group, was as follows:

1. Identification of the Taxonomy-eligible economic activities

2. Assessment to determine alignment of the Taxonomy-eligible economic activities based on the below:

2.1 Substantial contribution to the climate change mitigation and climate change adaptation environmental objectives

2.2 Do no significant harm (DNSH)

2.3 Compliance with the minimum social safeguards, at Group level

3. Calculation of the key performance indicators

The methodology was based on the EU Taxonomy Regulation (2020/852), its Delegated Acts as well as any

additional guidance released:

• The Climate Delegated Acts 2021/2139 and 2022/1214: These Delegated Acts establish the technical screening

criteria (TSC) for determining the conditions under which an economic activity qualifies as contributing substantially

to climate change mitigation and/or climate change adaptation environmental objectives, as well as for determining

whether that economic activity does not significantly harm any of the other environmental objectives.

• The Disclosure Delegated Act 2021/2178: This Delegated Act specifies the content and presentation of information

to be reported, concerning environmentally sustainable economic activities.

• Final Report on Minimum Safeguards: This Report, published by the Platform on Sustainable Finance, includes

guidance on the application of the minimum social safeguards.

1. Identification of the Taxonomy-eligible economic activities

The determination of the eligible economic activities of PPC Group business activities was conducted based on the

NACE codes associated with its activities, which according to the Regulation refer to financial data that are fully

consolidated.

PPC is a Group of Companies which consists of (a) PPC S.A. which is the core and has the functions of Supply,

Power Generation from conventional and hydroelectric sources of energy, Energy Trading and Electromobility, (b)

the main subsidiaries HEDNO S.A. (Distribution) and PPC Renewables S.A., with the latter being the main operator

of the transition to "green" electricity generation through Renewable Energy Sources and Storage and (c) the

subsidiaries in South East Europe which are active in the trading of electricity.

The economic activities of PPC Group for the financial year 2022 which were identified as eligible are the following:

• Activity 4.1 - Electricity generation using solar photovoltaic technology

• Activity 4.3 - Electricity generation from wind power

• Activity 4.5 - Electricity generation from hydropower

• Activity 4.6 - Electricity generation from geothermal energy

• Activity 4.8 - Electricity generation from bioenergy

• Activity 4.9 - Transmission and distribution of electricity

• Activity 4.10 - Storage of electricity

• Activity 4.29 - Electricity generation from fossil gaseous fuels

2. Eligibility Assessment

PPC Group proceeded with the assessment of the alignment of its eligible economic activities and assets, against:

• The substantial contribution technical screening criteria (TSC) in relation to at least one (1) environmental objective

• The do no significant harm technical screening criteria (TSC) in relation to the remaining five (5) environmental

objectives

• The minimum social safeguards

The purpose of this assessment was the determination of the level for alignment of the Group’s eligible economic

activities with the TSC and the requirements of Taxonomy Regulation, as well as the identification of potential gaps,

in order the Group to develop a specific action plan to align its eligible economic activities, with the Taxonomy

Regulation, in the coming years.

2.1 Substantial contribution

An assessment of each asset of the eligible economic activities was carried out against the respective climate

change mitigation or climate change adaptation TSC for substantial contribution. It was also determined whether

each activity is considered an enabling or a transitional economic activity.

Electricity generation using solar photovoltaic technology

The Group is active in the construction of photovoltaic parks, as well as in the production of electricity from

photovoltaic parks, through its 100% subsidiary PPC Renewables SA.

For 2022, the total capacity of the projects in operation is 34 MW.

Electricity generation from wind power

The Group is active in the installation of wind turbines in wind farms, as well as in the production of electricity from

wind farms, through its 100% subsidiary PPC Renewables SA.

For 2022, the total capacity of the projects in operation is 147 MW.

Electricity generation from hydropower

The Group produces electricity both through its Large Hydroelectric Power Stations of the Parent Company, and

through Small Hydroelectric Power Stations of its 100% Subsidiary PPC Renewables SA. The Large Hydroelectric

Power Stations (HPPs) are classified into 4 main river Complexes (Acheloos, Aliakmonas, Arachthos, Nestos) and

two independent HPPs (Plastiras and Ladonas). The total capacity of both Large and Small Hydroelectric Power

Stations in operation is 3.3 MW.

Electricity generation from geothermal energy

Geothermal electricity production exploits the heat from the ground. The chosen technology for the projects of PPC

Renewables S.A. is a closed-circuit binary power plant with close to zero emissions. PPC Renewables S.A., for

geothermal technology, has a strategic partner, the "Geothermal Target 2", owning the 49% of shares. The entire

development is divided into two interconnected areas. PPC Renewables S.A. reserves the exclusive right to explore

and develop the geothermal fields that it controls and manage their wastewater, while the "Geothermal Target 2"

will use the geothermal fluids that belong to PPC Renewables S.A. for energy production. According to the above,

PPC Renewables SA. incurs expenses that appear in its financial statements and for this reason the specific activity

is included in the alignment assessment.

Electricity generation from bioenergy

PPC Renewables S.A. develops electricity production projects exclusively from biomass, with a total capacity of 25

MW.

Transmission and distribution of electricity

The Group is active in the Distribution of Electricity in the Low and Medium Voltage, through its 100% subsidiary

HEDNO S.A., which also operates and develops the installation of equipment to increase the controllability and

observability of the electricity system and to enable the development and integration of renewable energy sources.

The Group is also active in the installation, maintenance and operation of electric vehicle (EV) charging stations,

supporting electric infrastructure for the electrification of transport, through DEI Blue's electromobility services.

Storage of electricity

PPC Renewables S.A. develops electrochemical energy storage projects using batteries, with a total capacity

of 1,043 MW.

Electricity generation from fossil gaseous fuels

The Group produces electricity through the steam power plants (SPP) of the Parent Company using natural gas

as fuel. The installed capacity of the Group’s gas-fired SPPs exceeds 2,650MW and includes the SPPs of

Komotini, Megalopolis, Aliveri and Lavrio - Keratea. At the end of December 2022, PPC proceeded with the

acquisition of 51% of the company's shares under the name "Alexandroupolis Monoprosopi S.A." from the

company Damco Energy. This company is planning the construction and operation of a new natural gas-fired

electricity production unit, with a nominal capacity of 840 MW, in Alexandroupolis and is expected to be

completed by the end of 2025.

2.2 Do No Significant Harm (DNSH)

An assessment of each asset of each economic activity was carried out against the DNSH technical screening

criteria of climate change adaptation, as well as for the rest four (4) of environmental objectives (the sustainable

use and protection of water and marine resources, the transition to a circular economy, the pollution prevention

and control and the protection and restoration of biodiversity and ecosystems) for the economic activities that

they are available.

2.3 Minimum Social Safeguards

PPC Group was assessed against the requirements of the minimum social safeguards as set out in Article 18

of the EU Taxonomy Regulation (2020/852/EU). The minimum social safeguards are a set of defined UN, EU

and other international human rights and code of ethics guidelines, as follows:

• The OECD Guidelines for Multinational Enterprises

• The UN Guiding Principles on Business and Human Rights

• The principles and rights set out in the eight fundamental conventions identified in the Declaration of the

International Labor Organization on Fundamental Principles and Rights at Work

• The International Bill of Human Rights

According to the Final Report on Minimum Safeguards of the Platform on Sustainable Finance, the minimum

social safeguards cover the following areas:

 Human rights, including labor rights

 Corruption/Bribery

 Taxation

 Fair Competition

3. Accounting policy for the determination of key performance indicators (KPIs)

3.1 Turnover (turnover KPI)

The proportion of turnover referred to in Article 8(2), point (a), of the Regulation (EU) 2020/852 is calculated as

the part of the net turnover derived from products or services, including intangibles, associated with Taxonomy-

aligned economic activities (numerator), divided by the net turnover (denominator) as defined in Article 2, point

(5), of Directive 2013/34/EU. The turnover covers the revenue recognized pursuant to International Accounting

Standard (IAS) 1, paragraph 82(a), as adopted by Commission Regulation (EC) No 1126/2008

To avoid double counting in the allocation in the numerator of turnover across economic activities, the figures

used have eliminated intergroup transactions.

In addition to the calculation of turnover KPI at Group level, it has been also calculated taking into account the

disaggregated data relevant to the electricity generation activity.

Commission Regulation (EC) No 1126/2008 of 3 November 2008 adopting certain international accounting standards in accordance with

Regulation (EC) No 1606/2002 of the European Parliament and of the Council (OJ L 320, 29.11.2008, p. 1).

3.2 Capital expenditure (CapEx)

The proportion of CapEx referred to in Article 8(2), point (b), of Regulation (EU) 2020/852 is calculated

as the numerator divided by the denominator as specified in points 1.1.2.1 and 1.1.2.2 of Annex I of

the delegated Regulation (EU) 2021/2178.

Denominator

The denominator covers additions to tangible and intangible assets during the financial year

considered before depreciation, amortization and any re-measurements, including those resulting

from revaluations and impairments, for the relevant financial year and excluding fair value changes.

The denominator also covers additions to tangible and intangible assets resulting from business

combinations.

For non-financial undertakings applying international financial reporting standards (IFRS) as adopted

by Regulation (EC) No 1126/2008, CapEx shall cover costs that are accounted based on:

(a) IAS 16 Property, Plant and Equipment, paragraphs 73, (e), point (i) and point (iii);

(b) IAS 38 Intangible Assets, paragraph 118, (e), point (i);

Leases that do not lead to the recognition of a right-of-use over the asset are not counted as CapEx.

Numerator

The numerator equals to the part of the capital expenditure included in the denominator that is any of

the following:

(a) related to assets or processes that are associated with Taxonomy-aligned economic activities;

(b) part of a plan to expand Taxonomy-aligned economic activities or to allow Taxonomy-eligible

economic activities to become Taxonomy-aligned (‘CapEx plan’) under the conditions specified in the

second subparagraph of point 1.1.2.2 of Annex I of the delegated Regulation 2021/2178 EU;

The CapEx plan, referred to in the first paragraph of point 1.1.2.2 of Annex I of the delegated

Regulation 2021/2178 EU, meet the following conditions:

(a) the plan aims either to expand the undertaking’s Taxonomy-eligible and Taxonomy-aligned

economic activities or to upgrade Taxonomy-eligible economic activities to render them Taxonomy-

aligned within a period of five years;

(b) the plan is disclosed at economic activity aggregated level and be approved by the management

body of non- financial undertakings either directly or by delegation.

Where the relevant technical screening criteria are amended before the completion of the CapEx plan,

non-financial undertakings shall either update the plan within two years to ensure the economic

activities referred to in point (a) are aligned with the amended technical screening criteria upon the

completion of the plan or restate the numerator of the CapEx KPI. The updating of plan shall restart

the period referred to in point (a). The period referred to point (a) of the second paragraph of this point

1.1.2.2 can exceed five years only where a longer period is objectively justified by specific features of

the economic activity and the upgrade concerned, with a maximum of 10 years. That justification shall

feature in the CapEx plan itself and in the contextual information detailed under point 1.2.3 of the

Annex I of the delegated Regulation 2021/2178 EU.

Where the CapEx plan fails to meet the conditions referred to in the second paragraph of this point

1.1.2.2, previously published KPI related to capital expenditure shall be restated.

The numerator also contains the part of the CapEx for adaptation of economic activities to climate

change in accordance with Annex II to this Climate Delegated Act. The numerator provides for a

breakdown for the part of CapEx allocated to substantial contribution to climate change adaptation.

To avoid double counting in the allocation in the numerator of CapEx across economic activities, the

figures have eliminated intergroup transactions.

3.3 Operating expenditure (OpEx)

The proportion of OpEx referred to in Article 8(2), point (b), of Regulation (EU) 2020/852 is calculated

as the numerator divided by the denominator as specified in points 1.1.3.1 and 1.1.3.2 of the Annex I

of the delegated Regulation 2021/2178 EU.

Denominator

The denominator covers direct non-capitalized costs that relate to research and development, building

renovation measures, short-term lease, maintenance and repair, and any other direct expenditures

relating to the day-to-day servicing of assets of property, plant and equipment by the undertaking or

third party to whom activities are outsourced that are necessary to ensure the continued and effective

functioning of such assets.

Numerator

The numerator equals to the part of the capital expenditure included in the denominator that is any of

the following:

a) related to assets or processes associated with Taxonomy-aligned economic activities, including

training and other human resources adaptation needs, and direct non-capitalized costs that represent

research and development;

b) part of the CapEx plan to expand Taxonomy-aligned economic activities or allow Taxonomy-eligible

economic activities to become Taxonomy-aligned within a predefined timeframe as set out in the

second paragraph of point 1.1.3.2 of the Annex I of the delegated Regulation 2021/2178 EU.

The CapEx plan, referred to in the first paragraph of point 1.1.3.2 of Annex I of the delegated

Regulation 2021/2178 EU, shall meet the conditions specified in point 1.1.2.2 of the Annex I of the

delegated Regulation 2021/2178 EU.

Research and development costs already accounted for in the CapEx KPI is not counted as OpEx.

To avoid double counting in the allocation in the numerator of OpEx across economic activities, the

figures have eliminated intergroup transactions.

3.4 Key Performance Indicators 2022

In the following tables the percentages of turnover, CapEx and OpEx of Taxonomy aligned,

Taxonomy-non-aligned and Taxonomy-non eligible economic activities for the financial year 2022,

are presented, according to the results of the alignment assessment of the economic activities of PPC

Group.

Turnover

Substantial

contribution criteria

DNSH criteria ('Does No

Significant Harm')

Economic activities

EU NACE code

Turnover

Proportion of total Turnover

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution

Biodiversity and ecosystems

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution

Biodiversity and ecosystems

Minimum safeguards

Taxonomy-

aligned

proportion

of Turnover

FY22

Taxonomy-

aligned

proportion of

Turnover FY21

Category (Enabling

activity)

Category

(Transitional

activity)

‘000€

Y/N

A. Taxonomy-Eligible Activities

A.1 Taxonomy-aligned activities

Total Turnover from taxonomy-eligible and aligned activities (A.1)

A.2 Taxonomy-non-aligned activities

Electricity generation using solar photovoltaic technology (4.1)

D35.11

1,998

0.02%

Electricity generation from wind power (4.3)

D35.11

22,392

0.20%

Electricity generation from hydropower (4.5)

D35.11

12,844

0.11%

Electricity generation from geothermal energy (4.6)

D35.11

Electricity generation from bioenergy (4.8)

D35.11

Transmission and distribution of electricity (4.9)

D35.13

395,652

3.52%

Storage of electricity (4.10)

Electricity generation from fossil gaseous fuels (4.29)

D35.11

Total Turnover from taxonomy-non-aligned activities (A.2)

432,887

3.85%

Total Taxonomy-eligible Turnover (A.1 + A.2)

432,887

3.85%

B. Taxonomy-Non-Eligible Activities

Total Turnover from Taxonomy-non-eligible activities (B)

10,820,221

96.15%

Total Turnover (A+B)

11,253,107

100%

* There was no obligation to be calculated for 2021

In the following Turnover table, only the data of the Group's Electricity Production Sector are displayed.

Turnover

Substantial

contribution criteria

DNSH criteria ('Does No

Significant Harm')

Economic activities

EU NACE code

Turnover

Proportion of total Turnover

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution

Biodiversity and ecosystems

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution

Biodiversity and ecosystems

Minimum safeguards

Taxonomy-

aligned

proportion

of Turnover

FY22

Taxonomy-

aligned

proportion of

Turnover FY21

Category (Enabling

activity)

Category

(Transitional

activity)

‘000€

Y/N

A. Taxonomy-Eligible Activities

A.1 Taxonomy-aligned activities

Total Turnover from taxonomy-eligible and aligned activities (A.1)

A.2 Taxonomy-non-aligned activities

Electricity generation using solar photovoltaic technology (4.1)

D35.11

2,089

0.04%

Electricity generation from wind power (4.3)

D35.11

32,284

0.60%

Electricity generation from hydropower (4.5)

D35.11

63,873

11.70%

Electricity generation from geothermal energy (4.6)

D35.11

Electricity generation from bioenergy (4.8)

D35.11

Electricity generation from fossil gaseous fuels (4.29)

D35.11

2,469,148

45.78%

Total Turnover from taxonomy-non-aligned activities (A.2)

3,134,395

58.12%

Total Taxonomy-eligible Turnover (A.1 + A.2)

3,134,395

58.12%

B. Taxonomy-Non-Eligible Activities

Total Turnover from Taxonomy-non-eligible activities (B)

2,258,588

41.88%

Total Turnover (A+B)

5.392.982

100%

* There was no obligation to be calculated for 2021

CapEx

Substantial

contribution criteria

DNSH criteria ('Does No

Significant Harm')

Economic activities

EU NACE code

CapEx

Proportion of total CapEx

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution

Biodiversity and ecosystems

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution

Biodiversity and ecosystems

Minimum safeguards

Taxonomy-

aligned

proportion

of CapEx

FY22

Taxonomy-

aligned

proportion of

CapEx FY21

Category (Enabling

activity)

Category

(Transitional

activity)

‘000€

Y/N

A. Taxonomy-Eligible Activities

A.1 Taxonomy-aligned activities

Total CapEx from taxonomy-eligible and aligned activities (A.1)

A.2 Taxonomy-non-aligned activities

Electricity generation using solar photovoltaic technology (4.1)

D35.11

143,580

17.02%

Electricity generation from wind power (4.3)

D35.11

95,725

11.35%

Electricity generation from hydropower (4.5)

D35.11

13,264

1.57%

Electricity generation from geothermal energy (4.6)

D35.11

0.01%

Electricity generation from bioenergy (4.8)

D35.11

<0.01%

Transmission and distribution of electricity (4.9)

D35.13

330,030

39.13%

Storage of electricity (4.10)

220

0.03%

Electricity generation from fossil gaseous fuels (4.29)

D35.11

20,038

2.38%

Total CapEx from taxonomy-non-aligned activities (A.2)

602,967

71.50%

Total Taxonomy-eligible CapEx (A.1 + A.2)

602,967

71.50%

B. Taxonomy-Non-Eligible Activities

Total CapEx from Taxonomy-non-eligible activities (B)

240,386

28.50%

Total CapEx (A+B)

843,353

100%

* There was no obligation to be calculated for 2021

OpEx

Substantial

contribution criteria

DNSH criteria ('Does No

Significant Harm')

Economic activities

EU NACE code

OpEx

Proportion of total OpEx

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution

Biodiversity and ecosystems

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution

Biodiversity and ecosystems

Minimum safeguards

Taxonomy-

aligned

proportion

of OpEx

FY22

Taxonomy-

aligned

proportion of

OpEx FY21

Category (Enabling

activity)

Category

(Transitional

activity)

‘000€

Y/N

A. Taxonomy-Eligible Activities

A.1 Taxonomy-aligned activities

Total OpEx from taxonomy-eligible and aligned activities (A.1)

A.2 Taxonomy-non-aligned activities

Electricity generation using solar photovoltaic technology (4.1)

D35.11

<0.01%

Electricity generation from wind power (4.3)

D35.11

1.601

0.31%

Electricity generation from hydropower (4.5)

D35.11

304

0.06%

Electricity generation from geothermal energy (4.6)

D35.11

Electricity generation from bioenergy (4.8)

D35.11

Transmission and distribution of electricity (4.9)

D35.13

130,906

25.66%

Storage of electricity (4.10)

Electricity generation from fossil gaseous fuels (4.29)

D35.11

29,455

5.77%

Total OpEx from taxonomy-non-aligned activities (A.2)

162,285

31.82%

Total Taxonomy-eligible OpEx (A.1 + A.2)

162,285

31.82%

B. Taxonomy-Non-Eligible Activities

Total OpEx from Taxonomy-non-eligible activities (B)

347,784

68.18%

Total OpEx (A+B)

510,069

100%

* There was no obligation to be calculated for 2021

Nuclear and fossil gas related activities

Row

Nuclear energy related activities

The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of

innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel

cycle.

The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to

produce electricity or process heat, including for the purposes of district heating or industrial processes such as

hydrogen production, as well as their safety upgrades, using best available technologies.

The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce

electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen

production from nuclear energy, as well as their safety upgrades.

Fossil gas related activities

The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that

produce electricity using fossil gaseous fuels.

YES

The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool

and power generation facilities using fossil gaseous fuels.

The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation

facilities that produce heat/cool using fossil gaseous fuels.

Taxonomy-aligned economic activities (denominator) - Turnover

Amounts on ‘000€

Row

Economic activities

Amount and proportion (the information is to be presented in

monetary amounts and as percentages)

CCM + CCA

Climate change

mitigation (CCM)

Climate change

adaptation (CCA)

Amount

Amount and proportion of taxonomy- aligned

economic activity referred to in Section 4.26

of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the

applicable KPI

Amount and proportion of taxonomy- aligned

economic activity referred to in Section 4.27

of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the

applicable KPI

Amount and proportion of taxonomy- aligned

economic activity referred to in Section 4.28

of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the

applicable KPI

Amount and proportion of taxonomy- aligned

economic activity referred to in Section 4.29

of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the

applicable KPI

Amount and proportion of taxonomy- aligned

economic activity referred to in Section 4.30

of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the

applicable KPI

Amount and proportion of taxonomy- aligned

economic activity referred to in Section 4.31

of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the

applicable KPI

Amount and proportion of other

taxonomy-aligned economic activities

not referred to in rows 1 to 6 above in the

denominator of the applicable KPI

Total applicable KPI

11,253,107

100%

Taxonomy-aligned economic activities (numerator) - Turnover

Amounts on ‘000€

Row

Economic activities

Amount and proportion (the information is to be presented in

monetary amounts and as percentages)

CCM + CCA

Climate change

mitigation (CCM)

Climate change

adaptation (CCA)

Amount

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.26 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.27 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.28 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.29 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.30 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.31 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of other

taxonomy-aligned economic activities

not referred to in rows 1 to 6 above in

the numerator of the applicable KPI

Total amount and proportion of

taxonomy-aligned economic activities

in the numerator of the applicable KPI

100%

Taxonomy-eligible but not taxonomy-aligned economic activities - Turnover

Amounts on ‘000€

Row

Economic activities

Amount and proportion (the information is to be presented in

monetary amounts and as percentages)

CCM + CCA

Climate change

mitigation (CCM)

Climate change

adaptation (CCA)

Amount

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.26 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.27 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.28 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.29 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.30 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.31 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of other taxonomy-

eligible but not taxonomy-aligned

economic activities not referred to in rows

1 to 6 above in the denominator of the

applicable KPI

432,887

3.85%

Total amount and proportion of taxonomy

eligible but not taxonomy-aligned

economic activities in the denominator of

the applicable KPI

432,887

3.85%

Taxonomy non-eligible economic activities - Turnover

Amounts on ‘000€

Row

Economic activities

Amount

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.26 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.27 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.28 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.29 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.30 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.31 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of other taxonomy-non-eligible

economic activities not referred to in rows 1 to 6 above in

the denominator of the applicable KPI

10,820,221

96.15%

Total amount and proportion of taxonomy-non-eligible

economic activities in the denominator of the applicable

KPI

10,820,221

96.15%

Taxonomy-aligned economic activities (denominator) - CapEx

Amounts on ‘000€

Row

Economic activities

Amount and proportion (the information is to be presented in

monetary amounts and as percentages)

CCM + CCA

Climate change

mitigation (CCM)

Climate change

adaptation (CCA)

Amount

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.26 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.27 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.28 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.29 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.30 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.31 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of other

taxonomy-aligned economic activities

not referred to in rows 1 to 6 above in

the denominator of the applicable KPI

Total applicable KPI

843,353

100%

Taxonomy-aligned economic activities (numerator) - CapEx

Amounts on ‘000€

Row

Economic activities

Amount and proportion (the information is to be presented in

monetary amounts and as percentages)

CCM + CCA

Climate change

mitigation (CCM)

Climate change

adaptation (CCA)

Amount

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.26 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.27 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.28 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.29 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.30 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.31 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of other

taxonomy-aligned economic activities

not referred to in rows 1 to 6 above in

the numerator of the applicable KPI

Total amount and proportion of

taxonomy-aligned economic activities

in the numerator of the applicable KPI

100%

Taxonomy-eligible but not taxonomy-aligned economic activities - CapEx

Amounts on ‘000€

Row

Economic activities

Amount and proportion (the information is to be presented in monetary amounts

and as percentages)

CCM + CCA

Climate change

mitigation (CCM)

Climate change

adaptation (CCA)

Amount

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.26 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.27 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.28 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.29 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

20,038

2.38%

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.30 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activity

referred to in Section 4.31 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of other

taxonomy-eligible but not taxonomy-

aligned economic activities not referred to

in rows 1 to 6 above in the denominator of

the applicable KPI

582,929

69.12%

Total amount and proportion of taxonomy

eligible but not taxonomy-aligned

economic activities in the denominator of

the applicable KPI

602,967

71.50%

Taxonomy non-eligible economic activities - CapEx

Amounts on ‘000€

Row

Economic activities

Amount

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.26 of Annexes I and II to Delegated

Regulation 2021/2139 in the denominator of the applicable

KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.27 of Annexes I and II to Delegated

Regulation 2021/2139 in the denominator of the applicable

KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.28 of Annexes I and II to Delegated

Regulation 2021/2139 in the denominator of the applicable

KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.29 of Annexes I and II to Delegated

Regulation 2021/2139 in the denominator of the applicable

KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.30 of Annexes I and II to Delegated

Regulation 2021/2139 in the denominator of the applicable

KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.31 of Annexes I and II to Delegated

Regulation 2021/2139 in the denominator of the applicable

KPI

Amount and proportion of other taxonomy-non-eligible

economic activities not referred to in rows 1 to 6 above

in the denominator of the applicable KPI

240,386

28.50%

Total amount and proportion of taxonomy-non-eligible

economic activities in the denominator of the applicable

KPI

240,386

28.50%

Taxonomy-aligned economic activities (denominator) - OpEx

Amounts on ‘000€

Row

Economic activities

Amount and proportion (the information is to be presented in

monetary amounts and as percentages)

CCM + CCA

Climate change

mitigation (CCM)

Climate change

adaptation (CCA)

Amount

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.26 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.27 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.28 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.29 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.30 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.31 of Annexes I and II to

Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of other

taxonomy-aligned economic activities

not referred to in rows 1 to 6 above in

the denominator of the applicable KPI

Total applicable KPI

510,069

100%

Taxonomy-aligned economic activities (numerator) - OpEx

Amounts on ‘000€

Row

Economic activities

Amount and proportion (the information is to be presented in

monetary amounts and as percentages)

CCM + CCA

Climate change

mitigation (CCM)

Climate change

adaptation (CCA)

Amount

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.26 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.27 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.28 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.29 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.30 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of taxonomy-

aligned economic activity referred to in

Section 4.31 of Annexes I and II to

Delegated Regulation 2021/2139 in the

numerator of the applicable KPI

Amount and proportion of other

taxonomy-aligned economic activities

not referred to in rows 1 to 6 above in

the numerator of the applicable KPI

Total amount and proportion of

taxonomy-aligned economic activities

in the numerator of the applicable KPI

100%

Taxonomy-eligible but not taxonomy-aligned economic activities - OpEx

Amounts on ‘000€

Row

Economic activities

Amount and proportion (the information is to be presented in monetary amounts

and as percentages)

CCM + CCA

Climate change

mitigation (CCM)

Climate change

adaptation (CCA)

Amount

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity

referred to in Section 4.26 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity

referred to in Section 4.27 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity

referred to in Section 4.28 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity

referred to in Section 4.29 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

29,455

5.77%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity

referred to in Section 4.30 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity

referred to in Section 4.31 of Annexes I and II

to Delegated Regulation 2021/2139 in the

denominator of the applicable KPI

Amount and proportion of other taxonomy-

eligible but not taxonomy-aligned economic

activities not referred to in rows 1 to 6 above

in the denominator of the applicable KPI

132,830

26.05%

Total amount and proportion of taxonomy

eligible but not taxonomy-aligned economic

activities in the denominator of the

applicable KPI

162,285

31.82%

Taxonomy non-eligible economic activities - OpEx

Amounts on ‘000€

Row

Economic activities

Amount

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.26 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.27 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.28 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.29 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.30 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of economic activity referred to in row

1 of Template 1 that is taxonomy-non-eligible in accordance

with Section 4.31 of Annexes I and II to Delegated Regulation

2021/2139 in the denominator of the applicable KPI

Amount and proportion of other taxonomy-non-eligible

economic activities not referred to in rows 1 to 6 above

in the denominator of the applicable KPI

347,784

68.18%

Total amount and proportion of taxonomy-non-eligible

economic activities in the denominator of the applicable

KPI

347,784

68.18%

Statement of Corporate Governance

Introduction

Corporate governance is the system of management and control of societes anonymes. It is a set of

structures, principles, rules, procedures and practices through which the continuous improvement of the

efficient operation of the company is sought for the benefit of its shareholders and those with a legitimate

interest in its operation, the enhancement of the long-term economic value of the Company and the

protection of the general corporate interest.

The implementation and adherence to best corporate governance practices is a key commitment and

priority for "Public Power Corporation S.A." [hereinafter, "PPC" or "the Company"] due to its significant

role in the Greek economy and the public benefit nature of the services it provides. An indication of the

importance that PPC gives to corporate governance is the establishment of the Legal Affairs & Corporate

Governance Division ("LACGD"), which is charged with the introduction of new and the update of existing

corporate governance practices that will keep the Company aligned with international best practices.

Already from the year 2021 the Company, in full compliance with Law 4706/2020, has harmonized all the

provisions of its Articles of Incorporation and adopted a series of Policies and Regulations that ensure

transparent and effective governance and has established the necessary organizational structures for

their fuller adoption and implementation.

The Company continues to update the existing and develop new Policies and Regulations, due to the

constantly changing environment in which it operates and the consequent need to continuously adapt

both the organizational structure and the practices it adopts and applies, taking into account in particular

the provisions of the Hellenic Corporate Governance Code of the Hellenic Corporate Governance Council,

which the Company has adopted and applies, and the relevant Decisions of the Board of Directors of the

Hellenic Capital Market Commission.

In this context, in 2022, the Company revised its Articles of Incorporation and its Rules of Operation,

aiming to highlight the strategic and supervisory role of the Board of Directors, as well as the proper and

effective operation of its corporate bodies.

Furthermore, and in compliance with the relevant provision of the Hellenic Corporate Governance Code,

the role of the Independent Non-Executive Vice-Chairman of the Board of Directors of the Company, who

also chairs the Company's Nomination Remuneration and Recruitment Committee, has been

strengthened.

In addition, aiming at strengthening the role of the Audit Committee so as to be consistent with the

expansion of the scope of PPC's business activities as a Group, the Extraordinary General Meeting of the

Company's shareholders dated 14.12.2022 approved the increase of the number of its members from five

(5) to six (6) with the election of an additional member.

In consequence of the above and given that the evaluation of the Board of Directors is part of the

Company's Corporate Governance System, the Policy and Procedure for the Evaluation of the Suitability

and effectiveness of the Board of Directors and its Committees was approved (BoD Decision No. 45/10-

05-2022), based on which the first internal evaluation of the Board of Directors and its Committees was

carried out in 2022 and the areas that need further improvement were identified.

In accordance with article 14 of Law 4706/2020, the Company has ensured the adoption of Corporate

Governance policies by its major subsidiaries, PPC Renewables Single Member S.A. and HEDNO S.A.

Specifically, PPC Renewables Single Member S.A. already has Rules of Operation, a Code of Conduct

and has adopted and applies eight (8) Policies and Regulations in accordance with the guidelines of the

parent company and the Regulations and Policies adopted by PPC S.A. Moreover, HEDNO S.A. has

already initiated the relevant adjustment by adopting similar Policies and Regulations, which is currently

underway.

In addition, the Company, through the Compliance Department, continued and completed during 2022

the adoption of new Regulations, Policies and Procedures within the framework of the Ethical and

Business Conduct Program, which had already started in 2021, in line with international best practices In

particular, in 2022 the following were approved: a) the Revised Code of Conduct (BoD Decision No.

72/09.06.2022), which is a mandatory standard of conduct for all employees that must always be applied

strictly and without deviations, while it defines and discloses to the related third parties the requirements

of the Company towards it, in the context of their cooperation; b) the Policy against Violence and

Harassment at Work (BoD Decision no. 18/1-03-2022) in application of Law 4808/2021, c) the Anti-

Corruption and Bribery Policy (BoD Decision No. 71/09.06.2022), and d) the Enforcement Policy &

Report/Complaint Handling Procedure (BoD Decision No. 19/01.03.2022).

The Company has already committed itself, taking into account global trends in Corporate Governance,

to move towards the adoption of Environmental, Social, Governance (ESG) practices. This commitment

also stems from the conviction that, for a modern company, creating value for its stakeholders

(shareholders, employees, investors, suppliers, customers and civil society at large) is not only achieved

through the achievement of strong financial performance but mainly through good Governance and the

impact of the Company's activities on Society and the Environment. In this context, the revised

Sustainable Development Policy was approved, as well as the revised Environmental Policy of PPC S.A.,

as an integral part thereof (BoD Decision No. 88/12-07-2022), which defines the basic framework of the

Company's commitment to the threefold of Environment, Society, Corporate Governance.

All this framework of the Corporate Governance System, the Sustainable Development Policy and the

Corporate Social Responsibility constitute the axis of the Company's operation and aim to ensure

sustainable development and maximize its value.

It should be noted that with the limitation of the indirect participation of the Greek State, through HCAP,

to 34.12% at the end of 2021, the Company ceased to be subject to specific laws and regulations and to

the restrictions provided for in special laws applicable to public enterprises, thus expanding its operational

flexibility and facilitating the implementation of the relevant best practices of Corporate Governance.

Specifically, on 16.11.2021 the share capital increase of PPC was completed and on 2.3.2022 the total

number of shares in PPC owned by the HRADF (corresponding to 10.32%) was transferred from the

HRADF to HCAP, in application of article 147 of Law 4876/2021. Therefore, HCAP currently holds 34.12%

of the share capital of PPC SA.

Following the above, the shareholding composition of PPC S.A. on 31.12.2022 was as follows:

• The Hellenic Corporation of Assets and Participations S.A. (HCAP), in which the Greek State

holds 100% of the shares and voting rights, directly held 34.12% of the share capital and voting

rights of PPC,

• Selath Holdings S.à r.l. held 10% of the share capital and voting rights of PPC; and

• Institutional investors and the general investor community, holding the remaining 55.88%, which

include:

- Helikon Long Short Equity Fund Master ICAV with a total participation of 6.48% in the voting

rights of PPC (namely, the sum of voting rights attached to shares and voting rights deriving

from financial instruments), according to the announcement of Helikon Investments Limited

dated 29.9.2021, and

- Covalis Capital LLP and its ultimate controller Mr. Zilvinas Mecelis with a total shareholding

of 5.26% (namely, the sum of the voting rights attached to shares and the voting rights

deriving from financial instruments of PPC S.A.), according to the notification dated

20.10.2022 of Covalis Capital LLP.

Structure of the Corporate Governance Statement

The current Statement of Corporate Governance is prepared pursuant to the provisions of article 152 of

Law 4548/2018, article 18 of Law 4706/2020, as in force, as well as the provisions of the Hellenic

Corporate Governance Code of the Hellenic Corporate Governance Council (HCGC), which was issued

in June 2021 and has been adopted and is implemented by the Company, following the relevant approval

of its Board of Directors, and in conformance with article 17 of Law 4706/2020.

This Statement of Corporate Governance is a special part of the Annual Management Report of the Board

of Directors and contains all the information required by law. In addition, it includes the Company's

response to specific practices under the Chapters of the Hellenic Corporate Governance Code of the

HCGC, which has been adopted and is implemented.

In particular, the structure of this Statement of Corporate Governance (hereinafter referred to as

"Statement") is as follows:

I. Statement of Compliance with the Corporate Governance Code

II. Deviations from the Corporate Governance Code and Justification of Deviations

III. Corporate Governance Practices applied by the Company in addition to the provisions of

the legislation

IV. Internal Control System (ICS) - Results of the Internal Control System’s Evaluation

V. Information regarding the Company's control status (points (c), (d), (f), (h) and (i) of

paragraph 1 of Article 10 of Directive 2004/25/EC of the European Parliament and of the

Council, of 21 April 2004 on public takeover bids

VI. Composition and Functioning of the Governing Bodies

A. Board of Directors

1. Composition and functioning - term of office of each member of the Board.

2. Curriculum Vitae of the members of the Board of Directors

3. Chairman and Chief Executive Officer (hereinafter, “CEO”)

4. Appointment of non-executive members and, of these, the non-executive members that the Board of

Directors views as independent and the rationale behind this view

5. Number of meetings of the Board of Directors and the frequency of participation of each member -

issues each member dealt with

6. Reference to the Suitability Policy for the Members of the Board of Directors

7. Evaluation of the Suitability and Effectiveness of the Board of Directors and its Committees

8. Other Professional Engagements of the members of the Board of Directors

9. Number of shares held by each member of the Board and any key Executive member of the Company

10. Remuneration Policy for the Members of the Board of Directors

11. Disclosure of direct and indirect conflicts of interest

12. Verification of the fulfilment of independence criteria of the Independent Non-Executive Members of

the BoD

13. Communication with shareholders and other stakeholders

B. Audit Committee

i. Composition and functioning - term of office of members

ii. Curriculum Vitae of the members of the Audit Committee

iii. Responsibilities of the Audit Committee

iv. Frequency of Audit Committee meetings and members’ participation

v. Proceedings of the Committee for the fiscal year 2022

vi. Committee Evaluation

C. Nomination, Remuneration, and Recruitment Committee

i. Composition and functioning - term of office of members

ii. Curriculum Vitae of the members of the Nomination, Remuneration, and Recruitment Committee

iii. Responsibilities of the Nomination, Remuneration, and Recruitment Committee

iv. Frequency of meetings Nomination, Remuneration, and Recruitment Committee and members’

participation

v. Proceedings of the Nomination, Remuneration, and Recruitment Committee for the fiscal year 2022

vi. Evaluation of the Nomination, Remuneration, and Recruitment Committee

D. Other Committees

VII. Diversity Policy

VIII. Related Parties Transactions Policy

IX. General Meeting and Shareholders' Rights

X. Sustainable Development Policy

XI. Non-Financial Reporting

ANNEX

1. Curriculum Vitae of the Chief Officers of the Company

2. Shares held by the Chief Officers of the Company

I. Statement of Compliance with the Corporate Governance Code

The Company, complying with the Regulations of article 17 of Law 4706/2020 and following the

decision No. 86/14.07.21 of its Board of Directors, adopted and implements the Hellenic Corporate

Governance Code (hereinafter referred to as the "Code") of Hellenic Corporate Governance Council

(HCGC), which was published in June 2021, and is also available on the Company’s website

(https://www.dei.gr/el/dei-omilos/i-dei/etairiki-diakivernisi/kodikes-kanonismoi-kai-politikes/).

II. Deviations from the Corporate Governance Code and Justification of Deviations

The Corporate Governance Code which has been adopted and is being implemented by the

Company, establishes principles beyond the mandatory framework of Corporate Governance

legislation and is implemented based on the principle "Comply or Explain", according to which the

Company is required to explain the reasons for deviations from its specific practices.

Following the above and based on the principle "Comply or Explain", below are presented the

deviations of the Company's regulations from the said practices of the Code, always taking into

account that PPC SA. also for the fiscal year 2022 was subject to legal provisions and regulations

regarding the recruitment and remuneration process of the executives:

Hellenic Corporate Governance

Code

Explanation/Justification of deviations

Role and Competencies of the Board of

Directors (provision 1.11 of the HCGC -

definition of responsibilities of the CEO

and the Deputy Chief Executive)

In the initial Articles of Incorporation of the Company according to the issued

Presidential Decree 333/2000 (Government Gazette no 278/20.12.2000 vol. A')

which has the force of law, there is an opposite regulation. The powers and

competencies of the CEO are provided directly by the Articles of Incorporation (par.

2 and 3 of article 15)

Diversity criteria for senior managers

(provision 2.2.15 of the HCGC)

Proof of fulfilment of the diversity criteria for the executives as well, is the fact that

in 2022 the percentage of women in managerial positions in the Company rose to

32% from 17% in 2014, marking an increase of 88.2% (including the ranks starting

from Assistant Directors/Head of Units of the Company). In addition, the

percentage of women mid-level employees (including the ranks of Heads of

Section and Heads of Subsection) rose to 45% in 2022 compared to 31,5% in

2014, namely an increase of 42,9%.

Ensuring that the members of the Board

can devote sufficient time to the

performance of their duties (provisions

2.2.17 & 2.2.18 of the HCGC)

The frequency of participation of each member of the Board in the meetings that

took place during the fiscal year 2022 demonstrates that in essence there is no

question of deviation from the provisions of the Code. In addition, it is recommended

that the members of the Board of Directors, in terms of their external professional

commitments, not participate in Boards of Directors of more than five (5) companies

of different interests, and the non-executive members to not participate in Boards

of Directors of more than of (5) five listed companies.

The role of the Nomination Committee

in the process of nominating

candidates, in the preparation of the

succession plan for the Board members

and the senior executives (provision

2.3.7 of the HCGC)

The Nomination Remuneration and Recruitment Committee is responsible for

approving and recommending to the Board of Directors the Executive Recruitment

Policy. One of the criteria for the selection of executives is their potential to take up

positions at higher hierarchical levels in the future. The design of a succession and

career development plan for executives as a process will be subject to approval by

the Nomination Remuneration and Recruitment Committee.

The Remuneration Committee has the

responsibility to determine the

remuneration system for the members

of the Board and the senior executives

(provision 2.4.8 of the HCGC)

The current Remuneration Policy applies only to the members of the Board of

Directors; the determination of the remuneration system for executives is not

covered by this Policy. To date there has been no change in executive

remuneration, however, in the event of a possible future change to the executive

remuneration system, the Nomination Remuneration and Recruitment Committee

will be involved by submitting a relevant a recommendation to the Board of Directors

of the Company.

Refund of the variable remuneration of

the members of the Board of Directors

(provision 2.4.14 of the HCGC).

According to the Company's Remuneration Policy, which was approved by the

Extraordinary General Meeting of Shareholders on 14-12-2022, no provisions for

recovery of variable remuneration are foreseen. However, the degree of

achievement of the objectives of the executive members of the Board of Directors

is confirmed after the audit and final approval of the Group’s financial statements,

which means that there is no case of incorrect financial data being used to calculate

this variable remuneration.

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III. Corporate Governance Practices applied by the Company in addition to the provisions of

the legislation

For the fiscal year 2022, the Company has been applying the rules and practices apart from those

provided for or required by the standing legislation governing listed companies (Law 4548/2018, Law

4449/2017, 4706/ 2020, and Law 4972/2022). Following the reduction of the indirect participation of the

Greek State at the end of 2021, the Company has been readjusted to the common type of private sector

companies.

In particular and pursuant to the above for the financial year 2022, these practices and Regulations are

set out below:

• The powers and the competencies of the CEO, who is the highest-ranking executive officer of

the Company, are directly provided for in the Articles of Incorporation (par. 2 and 3 Article 15 of

the Articles of Incorporation of the Company, as well as section VI.A.3 below).

• The Vice Chairman of the Board of Directors in accordance with article 2 par. 1.3.7 of the Rules

of Operation has responsibilities consistent with those of the Senior Independent Director

(Provision 2.2.22 of the Hellenic Corporate Governance Code)

• Apart from the BoD and the CEO, in the Company operates a Procurement Committee (Article

18b of the Articles of Incorporation. Its composition and responsibilities are set out below in

section VI.C 'Procurement Committee'.

• There are Deputy CEOs reporting to the CEO (Article 15a of the Articles of Incorporation of the

Company, "Deputy CEOs ").

• The Board of Directors consists of eleven (11) members, out of which at least five (5) are

independent non-executive members (article 9, par. 1, case a of the Articles of Incorporation),

meaning that its composition exceeds the threshold that is set in Law 4706/2020 article 5 par. 2,

which provides that the independent non-executive members shall not be less than one third

(1/3) of the total number of its members.

• The Audit Committee of the Company, which operates pursuant to the provisions of article 44 of

Law 4449/2017 as in force, and taking into account article 9 of Law 4643/2019, consists of six

(6) members, which shall be in their totality and not in their majority, pursuant to Law,

independent from the Company, within the meaning of the provisions of article 9 of Law

4706/2020.

• The Company has established a Nomination, Remuneration & Recruitment Committee in

accordance with Articles 10, 11 and 12 of Law 4706/2020. The Nomination, Remuneration &

Recruitment Committee consists of three (3) members, which shall be in their totality and not in

their majority, as provided in Law 4706/2020, independent non-executive members of the Board

of Directors of the Company.

• In addition to the Committees under article 10 of Law 4706/2020, the Company has an Executive

Committee, a Risk Management Committee, a Hedging Committee and a Cybersecurity

Committee.

• The prohibition applied to the members of the Board of Directors, concerning the conduct of

competitive acts, is valid for a period of two years following termination for any reason

whatsoever of the term of office of the Board member or his retirement from the BoD (par.2 article

13 of the Articles of Incorporation “Prohibition of competition – Participation in the Board of

Directors of subsidiary companies”).

• The Articles of Incorporation of the Company expressly provide on one hand that the BoD may

meet by way of teleconference (par. 2 article 11) and on the other that the Shareholders are

entitled to participate in the voting of the General Meeting via distance voting, registered mail or

through electronic means (article 22 par. 4).

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IV. Internal Control System (ICS) - Results of the Internal Control System Evaluation

Internal Control System

The Company has established an Internal Control Systems (hereinafter referred to as "ICS") which

includes all the internal control mechanisms and procedures governing the Company, including Risk

Management, Internal Audit and Regulatory Compliance, in order to cover, on a continuous basis, each

of its activities and to contribute to its safe and effective operation. In particular, the Company's ICS aims

at the following:

• the consistent implementation of the business strategy, with the efficient use of the available

resources,

• the identification and management of the material risks associated with its business and

operations,

• the effective functioning of the Internal Audit Department,

• ensuring the completeness and reliability of the data and information required for the accurate

and timely determination of the Company's financial position and the preparation of reliable

financial statements, as well as its non-financial position,

• The compliance with the regulatory and legislative framework, as well as the internal regulations

governing the Company's operation.

Based on the Company's Rules of Operation, the Board of Directors ensures that the Company's ICS is

operating adequately and effectively, ensuring that the functions of the units that constitute the ICS are

independent of the business areas they control and that they have the appropriate financial and human

resources, as well as the powers for their effective operation, as required by their role. The reporting lines

and the allocation of responsibilities of the functions that make up the ICS are clear, enforceable and duly

documented.

The Audit Committee ensures the monitoring, examination and evaluation of the adequacy and effective

operation of the ICS, the evaluation of which is part of the overall evaluation of the Company's Corporate

Governance System, which is carried out by the Board of Directors on a three-year minimum basis (in

accordance with paragraph 1 of Article 4 of Law 4706/2020).

The Company has a Policy and Procedure for the Evaluation of the ICS which have been prepared in

accordance with paragraphs (3i) and (4) of Article 14 of Law 4706/2020 and the Decision 1/891/30.9.2020

of the Hellenic Capital Market Commission, as amended by the Decision 2/917/17-06-2021 of the Hellenic

Capital Market Commission. The ICS Evaluation Policy includes the general principles as to the scope

and range of evaluation of the ICS by an independent evaluator, the periodicity of the audit, the basic

principles of assigning the evaluation to an external evaluator, as well as the procedure for monitoring and

communicating the results of the evaluation to both the Company and its significant subsidiaries. The ICS

Evaluation Process describes the individual stages of the selection of the independent evaluator, who

shall conduct the evaluation of the ICS in accordance with the above.

The Company's ICS includes the functions of Internal Audit, Regulatory Compliance and Risk

Management as described below:

➢ Internal Audit

The Internal Audit, according to Law 4706/2020, as in force, is an independent organizational unit within

the Company, with the purpose of monitoring and improving the Company's operations and policies

regarding its Internal Control System.

The Internal Audit Department (IAD) reports functionally to the Audit Committee and administratively to

the CEO. The Director of the IAD is appointed by decision of the Board of Directors following a

recommendation of the Audit Committee and fulfills the requirements of functional and administrative

reporting and independence of Law 4706/2020. In order to carry out the tasks of the IAD, its Director shall

have access to any organisational unit of the Company and shall take knowledge of any information

required for the performance of his/her duties.

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The mission of the IAD under its Articles of Incorporation is to ensure adequate and valid control of the

Company in order to protect the interests of the shareholders, in accordance with the applicable

legislation, the principles of Corporate Governance and the best practices of Internal Audit, ensuring that:

• Risks are identified and managed appropriately to achieve its objectives.

• Compliance with PPC's policies and procedures, the Regulations and the applicable Legislation

is achieved.

• PPC’s resources are acquired and used in an effective and economical way.

• PPC's assets are adequately protected.

• The financial information is reliable.

For the implementation of articles 1 to 24 of Law 4706/2020, the Internal Audit Department shall monitor,

control and evaluate in particular:

• the application of the Rules of Operation and the ICS, in particular with regard to the adequacy

and correctness of the financial and non-financial information provided, the Risk Management,

the Regulatory Compliance and the Corporate Governance Code adopted by the Company,

• the quality assurance mechanisms,

• the corporate governance mechanisms; and

• the compliance with the commitments contained in the Company's prospectuses and business

plans regarding the use of funds raised on the regulated market.

The mission of the IAD, its organisation and staffing, its responsibilities, its relations with the Supervisory

Authorities, as well as the responsibilities of its head, its terms of operation and its Code of Conduct are

detailed in its Charter, which forms an integral part of the Company's Rules of Operation. The Audit

Committee proposes the IAD's Charter to the Board of Directors for approval.

The IAD's annual audit programme is prepared on the basis of the Group's operational risk

assessment.Τhe audit programme and the requirements for the necessary resources are submitted for

approval to the Board of Directors, after taking into account the opinion of the Audit Committee.

The annual audit programme of the IAD for 2022 indicatively included:

• Eleven (11) audits of the compliance with the Company's Rules of Operation and the individual

Policies and Procedures including the implementation of the Risk Management and Regulatory

Compliance System as well as of the Corporate Governance Code adopted by the Company.

• Three (3) quality assurance related audits.

• Twenty-five (25) audits of the effectiveness of the ICS in terms of the adequacy and accuracy of

the financial information provided.

• One (1) audit in relation to compliance with commitments regarding the use of funds.

• One (1) special procurement audit for the implementation of the Regulation on Works, Supplies

and Services (RWSS) and five (5) individual audits related to the overall operation of

procurement.

The IAD submitted the reports of the audits completed based on the approved audit programme (2021 -

2022) to the auditees and the competent supervisory units as well as to the Audit Committee presenting

its comments, the related risks, suggestions for improvement as well as the comments of the auditees

and the agreed actions.

The IAD also submitted to the Audit Committee summary quarterly reports on the most important issues

and its recommendations as well as the results of the auditees' response to the implementation of the

agreed actions according to the relevant time schedule. The above reports were presented to the Board

along with the comments of the Audit Committee.

The Head of the IAD shall inform the Audit Committee on the effectiveness of the IAD’s functioning, the

adequacy of resources as well as his/her access to the organisational units and the data required for the

performance of its tasks. The Head of the IAD participated in the General Meetings of the Company.

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➢ Compliance Department

The Company, recognizing the need to adapt to a new business environment, which is developing

internationally with the adoption of new necessary regulations and corporate governance codes, has

already established the Compliance Department since 2017.

The mission of the Compliance Department (CD) is, on the one hand, to monitor compliance with

applicable laws, other than the institutional and regulatory framework regarding environmental and energy

trading issues and, on the other hand, to promote ethical standards of conduct and protect the Company's

reputation through the effective identification, assessment, prevention, supervision and resolution of any

non-compliance with the Company's internal rules and ethical conduct policies, within the framework of

the Internal Control System (ICS).

Within the framework of its mission and in cooperation with the relevant Business Units, in 2022, the CD

completed the project "Ethical and Business Conduct Programme" with the development and approval of

Policies which, in combination with the revised Code of Conduct, contribute to the promotion of

transparency and integrity processes within the Company and establish a culture of ethics and conduct.

Specifically, this Programme includes the following policies: the Conflict of Interest Policy, the Anti-Money

Laundering and Counter-Terrorism Financing Policy, the Policy against Violence and Harassment at

Work, the Enforcement & Reporting/Complaint Handling Procedure, the Anti-Corruption and Bribery

Policy and the Revised Code of Conduct.

Subsequently, during 2022, actions were implemented to update and properly implement the said Policies

in the Company's Operations. Specifically:

• all employees were informed, and the said actions were posted both on the Company's website

and the intranet portal.

• Manuals - Implementation Guidelines were prepared, which include cases and examples of

implementation, clarifications and specifications of those provided for in the Policies of Conflict

of Interest, Enforcement and Anti-Corruption and Bribery, which were communicated to all

employees,

• a Conflict of Interest Register was established in application of the Conflict of Interest Policy,

conflict of interest situations were managed with the submission of recommendations by the

Compliance Department and the specific provisions of the Conflict of Interest Policy and the

other Policies were incorporated into the Regulation on Works, Supplies & Services of the

Company (DUE Diligence Third Parties)

• in application of the Enforcement Policy, an executive of the CD was appointed as the

Company's Whistleblowing Officer, entrusted with the task of handling the complaints/reports

channel (whistleblowing), ensuring their proper handling and maintaining communication with

the complainant, and three (3) channels for the submission of Reports and Complaints within

the Company were in operation.the CD handled fifteen (15) cases under the Enforcement Policy

during 2022,

• spot checks were carried out in operational areas of "high" risk for the implementation of the

Programme's Policies (ongoing monitoring),

• the staff of the CD provided continuous guidance and support to the company’s units and to

external partners for the proper implementation of the Policies. In total 163 requests were

answered,

• in the context of the parent company's supervision of the Group's major subsidiaries, Policies

and Regulations have been adopted by PPC RENEWABLES, both in compliance with Law

4706/2020 and with the "Ethical and Business Conduct" Programme, while the adoption by

HEDNO of the policies of this Programme is in progress.

• A Memorandum of Understanding was signed with the National Transparency Authority and a

series of actions will be implemented within the year 2023 to strengthen the Group's culture of

transparency and integrity,

• collaborations with external bodies and professional associations with the exchange of know-

how were carried out in order to improve the effectiveness of actions aiming to enhance integrity

and transparency, fight corruption and raise awareness among employees/partners, which will

continue in 2023,

• continuous participation of the CD executives in training programmes and issuance of

professional Certificates.

• The educational activities of the CD aiming at deepening the Program Policies and integrating

them into the Company's operations will be intensified in 2023.

104

In the context of monitoring compliance with the General Data Protection Regulation (GDPR), the office

of the Company's Data Protection Officer conducted 44 training cycles of seminars with the participation

of 487 employees from the "critical" (in terms of the volume of personal data processed) General

Directorates of the Company. Accountability Templates (DPA, DPIA, Activity Files) and the completion

instructions/manuals were prepared. Based on the above templates, the Office of the Data Protection

Officer issued an opinion on 414 DPAs and 4 impact studies (DPIAs) and verified the updating of the

Company's activity files.

In addition, and for the specific needs of the Energy Management and Trading Business Unit, a position

of Director of Energy Transactions Compliance was established in September 2021, entrusted with the

continuous monitoring of the institutional framework governing energy transactions and the

implementation of the Energy Transaction Compliance program, which is part of the corporate Compliance

and Ethical & Business Conduct Program, as well as with the drafting of internal guidelines and policies

to ensure the compliance of energy transactions. In this context, within 2022, the Compliance

Department:

• made an inventory of the specific regulatory obligations of the Energy Management and Trading

Business Unit,

• drafted guidelines aiming to avoid market manipulation, both for transactions in financial

instruments and for transactions in wholesale energy products,

• drafted implementation instructions, conducted a training seminar for the relevant executives of

the Energy Management and Trading Business Unit and carried out a sample implementation

audit, in application of the Company's Anti-Money Laundering Policy,

• prepared guidelines for the implementation of the Company's Regulation on the Handling of

Internal Information.

➢ Risk Management Department and Committee

The establishment of the Risk Management Department in 2019 and the subsequent establishment of the

Risk Management Committee in 2020, aimed at shielding the company against internal and external risks

arising from the conduct of its business activity, through the central monitoring and coordination of the

management of exposure to these risks.

The Risk Management Department is responsible for the development and implementation of an

appropriate risk management system, in line with the Company's risk management policy, which a)

assesses (identifies, quantifies and prioritizes in terms of importance) all corporate risks, b) establishes a

strategy for the Company's management of and response to these risks (acceptance or avoidance of the

risk, mitigation of the risk by modifying the related corporate action, sharing or transferring the risk), and

c) defines processes to monitor the evolution of risks by introducing appropriate procedures and control

indicators. It should be noted that the competence and responsibility for the management of individual

risks remains with the Services to which these risks pertain.

The Risk Management Committee is entrusted with the risk oversight of all the activities of the Company

and the contribution to the development of the Risk Management Corporate Framework, as well as with

the monitoring and reporting of the significant Corporate Risks.

Operating within this framework, the Company highlights its commitment to the establishment of a

business environment that not only respects and complies with the law, but also enhances the Company’s

value, thus ensuring its good reputation and credibility.

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➢ Information Systems

▪ Cybersecurity

In 2022, through an extensive cybersecurity transformation program, the Company ensured that

cybersecurity is integrated into the broader corporate strategy, from the development of new digital

products and services to ensuring the confidentiality, integrity and availability of information and data in

both the Information Technology (IT) and Operational Technology (OT) environment.

In the broader context of the transformation, the existing Framework of Information Systems Security

(FISS) was updated, which describes the basic security requirements regarding:

risk assessment,

• supply chain risk management,

• identity management and access control,

• security of systems and applications throughout their life cycle,

• detecting threats and addressing vulnerabilities and risks,

• managing security incidents,

• raising awareness and training of its staff and partners on information security

• and the general compliance of the company with the obligations arising from the regulatory -

legislative environment

In addition, the Cybersecurity Committee has been established with the main task of overseeing and

ensuring the proper management of the relevant risks and the commitment of the Board of Directors

regarding Cybersecurity.

Moreover, the Company has set up the role of Responsible for Information and Network Security (RINS),

in accordance with Law 4577/2018 (NOG vol. A' no 199) and the Ministerial Decision (MD) 1027/2019, as

applicable, which among others:

• It is the contact point and cooperates with the National CyberSecurity Authority and the relevant

CSIRT.

• Coordinates and supervises the Company with regard to the obligations arising from the relevant

law, the MD and other provisions of the European Union or the National CyberSecurity Authority

regarding the security of Information and Network Systems.

▪ Information Systems Governance

In 2022, the Company's IT department, as part of a detailed and extensive consulting project, in

collaboration with an external partner, completed the mapping of the Company's operating model, through

the mapping of processes covering the governance of Information Systems.

Specifically, the following procedures applied by the IT were mapped in detail:

• Demand Management

• Solution Design

• Change Management

• Incident Management

• Problem Management

• Development Management

• Release Management

106

At the same time, in addition to the specific advisory work, the Technology Governance & IT Projects

Department drafted the following procedures implemented by the IT:

• IT Project Management

• IT Document Management

• IT Portfolio Management

• Management of the process for the creation of RFPs (Request for Proposal) aiming to the

selection of IT external partners for the Conclusion of Partnerships with External Partners

Finally, the operation of the Change Management Committee (CMC) continued, which ensures and

approves the proper design of the Information Systems, based on the architecture standards set by the

Division.

➢ Procedure for the preparation of financial statements and financial reports

The basic areas where safeguards concerning the preparation of the Company’s financial statements and

reports are implemented are the following:

Allocation of competences

The executives involved have clearly separated roles and areas of responsibility, thus enhancing the

effectiveness of the Internal Control System.

Procedures for accounting monitoring and preparation of financial statements

- Existence of accounting principles and policies for the operation of the Accounting Services of

the Group.

- Existence of procedures in relation to the issuing of financial statements and their consolidation

at Group level.

- Regular follow-up of the International Financial Reporting Standards, as these are adopted by

the European Union, and corresponding adjustment of the accounting principles and Policies of

the Group, as required.

- A special approval by the top executives of the Company is required for the execution of

accounting entries, which concern specialized, non-recurring accounting events.

- Audits are being carried out by the Information Technology Department on the information

subsystems’ data, before being integrated into the General Accounting.

- Monthly reconciliations of the data (balances) of the information subsystems with the General

Accounting balances are carried out by the Accounting Department.

- Regular communication of the executives of the Finance Division with the Top Management and

the Audit Committee for the ratification and recording of the important events that affect the

financial statements.

- Regular communication of the Chartered Auditors with the Top Management and the Audit

Committee with regard to the progress and the results of the Company’s compulsory audit.

Asset safekeeping procedures

Implementation of safeguards for the information systems in place for managing fixed assets, reserves,

cash and cash equivalents of customers. By way of illustration, the existence of analytical procedures

and audit mechanisms for carrying out the material annual inventory.

Transaction approval limits

The operation of the Services, at all administration levels, as well as of the Company’s Bodies/Bodies of

persons is governed by the Financial and Administrative Jurisdictions System by which the jurisdictions

in matters of approvals by the Governing Bodies and the executives of the Company are defined.

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The Audit Committee monitors, on an ongoing basis, the effective operation of the Company's Internal

Control System, quality assurance and Risk Management Systems, of the Regulatory Compliance and

the Internal Audit Department, regarding the Company's financial information, without violating its

independence. The Audit Committee receives and examines the reports of the IAD as provided by article

16 of Law 4706/2020 and monitors the updating of the Board of Directors by the IAD on their content,

especially with regard to the financial information of the Company.

The Board of Directors regularly reviews the corporate strategy, the main business risks for the Company,

as well as the Internal Control System in place in order to ensure that: The Internal Control System

formulated and implemented by the Company ensures the consistent implementation of the corporate

strategy, the identification and management of material risks in accordance with the Enterprise Risk

Management Framework, the assurance of the completeness and reliability of the data and information

required for the accurate and timely determination of the Company's financial position and the preparation

of reliable financial statements, compliance with the regulatory and legislative framework, as well as the

internal Regulations governing the operation of the Company and the effective operation of the Internal

Audit Department.

The Audit Committee monitored issues related to the objectivity and independence of the Company's

Chartered Auditors. During the fiscal year 2022, projects were assigned to the firm of the Company's

Chartered Auditors. The Audit Committee consented to these engagements, after having taken into

account the submitted Declarations of Independence and the assurances of no conflict of interest in

accordance with the international practice.

Results of the Internal Control System’s evaluation process in accordance with article 1 4, par. 3

section j and par. 4 of L. 4706/2020 and the relevant decisions of the of the Capital Market

Commission’s Board of Directors.

The Company, by Decision No 154/20.12.2022 of its Board of Directors , assigned to KPMG Certified

Auditors S.A. the assessment of the adequacy and effectiveness of the Internal Control System of the

Company, the Public Power Corporation S.A., and its significant subsidiaries, the Hellenic Electricity

Distribution Network Operator S.A. and PPC RENEWABLES SINGLE MEMBER S.A., with reference date

31 December 2022, in accordance with the provisions of section j of par. 3 and par. 4 of article 14 of L.

4706/2020 and decision 1 /891 /30.09.2020 of the Hellenic Capital Market Commission’s Board of

Directors as applicable (the "Legislative Framework").

The assurance was performed in accordance with the audit program included in the decision of the

Hellenic Accounting and Auditing Standards Oversight Board (HAASOB), number 040/2022 and the

International Standard on Assurance Engagement 3000 "Assurance Engagements other than Audits or

Reviews of Historical Financial Information".

Based on the work performed by the evaluator regarding the assessment of the adequacy and

effectiveness of the Company’s Internal Control System and its significant subsidiaries, we report that no

material weaknesses were identified.

V. Information regarding the Company’s control status (Information 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,

dated 21st April 2004 on public takeover bids)

Share Capital Structure

The share capital of the Company as of 31.12.2022 amounted to nine hundred forty seven million three

hundred sixty thousand (947,360,000) euros, divided into three hundred eighty two million (382,000,000)

common registered shares, with a nominal value of two euros and forty eight cents (€ 2.48) each.

Until the preparation of this Statement, no change has occurred in the share capital of the Company.

108

Restrictions on transferring Company shares

Article 8 of PPC’s Articles of Incorporation which provided that the percentage of the Hellenic Republic in

the PPC’s share capital could not be less than 51% of the Company’s shares with voting rights following

any increase of the share capital, was abolished, pursuant to the Act of Legislative Content dated 7.9.2012

(which was ratified by article 2 of Law 4092/2012).

Significant direct or indirect participations within the meaning of articles 9 to 11 of Law 3556/2007

With regard to the significant participations (over 5%) in the share capital and voting rights of the PPC

S.A. within the meaning of the provisions of articles 9 to 11 of Law 3556/2007, as of 31.12.202:

• the Hellenic Corporation of Assets and Participations S.A. (HCAP S.A.) held 34.12% of the

shares and voting rights,

• Selath Holdings S.à r.l. held 10.0% of the shares and voting rights

• while the total participation of "Helikon Long Short Equity Fund Master ICAV" in the voting rights

(namely, the sum of voting rights attached to shares and voting rights through financial

instruments) amounted to 6.48%, according to the notification of Helikon Investments Limited

dated 29.9.2021; and

• the total participation of Covalis Capital LLP and its ultimate controller Mr. Zilvinas Mecelis in the

voting rights of PPC S.A. (namely, the sum of voting rights attached to shares and voting rights

through financial instruments) amounted to 5.26%, according to the notification dated 20.10.2022

of Covalis Capital LLP.

The relevant information on the number of shares and voting rights held by people with significant

shareholdings has been obtained from the share register maintained by the Company, which is updated

by Axialine of the Athens Stock Exchange, as well as from the notifications that have been received under

law (Market Abuse Regulation) by the Company on behalf of its shareholders.

On 2.3.2022, following a relevant OTC transaction, the ipso iure transfer of all shares in PPC owned by

the Hellenic Republic Asset Development Fund (HRADF) (corresponding to 10.32%) from the HRADF to

the Hellenic Corporation of Assets and Participations S.A. (HCAP), without consideration and exempt

from any tax and/or third party rights, was completed, in execution of the provision of article 147 of Law

4876/2021. As a result, the shareholding of HCAP in PPC amounts to 34.12 % directly/indirectly with the

corresponding voting rights, while the HRADF no longer has any shareholding in PPC.

Shares with special control rights

There are no shares granting special control rights, stricto sensu.

Voting rights restrictions

There are no restrictions on voting rights.

Agreements between Company’s shareholders

The Company has no knowledge of agreements existing between its shareholders.

Rules on appointing and replacing members of the Board of Directors

According to article 9 of the Company’s Articles of Incorporation, the Board of Directors consists of

eleven (11) members, including the CEO, elected by the General Meeting of shareholders of the

Company, based on the Company’s Suitability Policy, as in force and posted on the Company’s website,

which includes the Conflict of Interest Policy and rules for safeguarding diversity on the Board of

Directors in terms of gender, age, representation of shareholders and educational and professional

background. The Board of Directors elects from among the said members its Chairman and Vice

Chairman, pursuant to article 14 of the Articles of Incorporation. One (1) non-executive member out of

the aforementioned members of the Board of Directors represents the employees of the Company. This

member shall be elected by the General Shareholders' Meeting from a list of proposed candidates

submitted to the Nomination, Remuneration and Recruitment Committee by the most representative

trade union (ΑSOP), ) at least two (2) months before the expiry, in any way whatsoever, of the term of

the previous member, in order to be evaluated and elected by the General Meeting of the Shareholders

as defined above.

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In the event of non-election or non-prompt filling of any vacancy or non-substitution of the members of the

Board of Directors, for any reason whatsoever, this shall not impede the constitution and functioning of

the Board of Directors without these members, provided that the number of the remaining members is not

less than six (6).

Duties of the Board of Directors with regard to the issuance of new or the purchase of own shares.

According to par.2 article 6 cases a) and b) of the Company’s Articles of Incorporation, for a period not

exceeding five years for each renewal granted, the General Meeting upon its resolution, may renew the

relevant power granted to the Board of Directors, so that the Board of Directors by its decision, taken in

accordance with the increased majority of article 24, Law 4548/2018 as applicable, may:

a) increase the share capital through the issuance of new shares. The amount of the increase may not

exceed triple the share capital, which shall have been paid up on the date of the decision-making by the

General Meeting on the renewal of the relevant power of the Board of Directors and

b) issue bonded loan converted into shares by its decision or otherwise by resolution of the General

Meeting, taken in accordance with the simple quorum and majority requirements, for an amount that

cannot be more than triple the share capital, which shall have been paid up on the date of decision-making

by the General Meeting on the renewal of the relevant power of the Board of Directors. In this case, the

provisions of article 24 L. 4548/2018, as currently in force, shall apply. It is noted that the provisions of

par. 2 of article 6 of the Articles of Incorporation of PPC as mentioned above were applied to the PPC’s

latest share capital increase in 2021, pursuant to the decisions of the Board of Directors held on October

29, 2021 and on November 11, 2021, issued based on the relevant decision of the Shareholders’

Extraordinary General Meeting held on October 19, 2021.

The provisions of articles 49 to 51 of Law 4548/2018, as amended and currently in force, provide for the

Company’s right to purchase own shares, under the responsibility of the Board of Directors, following

approval by the General Meeting of Shareholders and pursuant to the requirements specified in the above

articles.

There is no special provision in the Company’s Articles of Incorporation, concerning the competence of

the Board of Directors or of the General Meeting for the purchase of own shares.

Significant agreements that become effective, are amended or are terminated in the event of

change in control

A significant part of PPC loan agreements provide that in case the Hellenic Republic’s participation in the

share capital of the Company falls below 34%, or in case the Hellenic Republic ceases to control the

Company in any way whatsoever, this may lead to Mandatory Prepayment or may constitute an Event of

Default of these loans.

In addition, any change in PPC shareholder structure, which may lead to a change in control over the

Company, gives rise to an “Accelerated Put/Call Event” according to the Shareholders Agreement

between PPC S.A. and TERNA ENERGY S.A. relating to WASTE SYCLO S.A. This event entitles the

non-defaulting party to exercise his right whether to purchase all the shares of the defaulting shareholder

or to proceed to the disposal of its shares to the defaulting party, based on the procedure set forth in the

Shareholders Agreement. As of the date of drawing up of this Statement, there has been no change in

the above agreement as a result of the change in control of PPC S.A. As at 31 December 2022, no change

had occurred in the above agreement.

With regard to the shareholders’ agreement with ALPIQ, based on which the subsidiary company under

the trade name PPC Bulgaria was established in Bulgaria, in the event of any change in the shareholder

structure of one out of the two shareholders, which leads in a change of control over the company, the

other shareholder may exercise his right to sell his shares to the first shareholder, within a period of 30

working days, pursuant to the procedure provided for in the shareholders’ agreement. As at 31 December

2022, no change had occurred in the above agreement.

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Agreements with members of the Board of Directors or Company Personnel

Pursuant to the Company's Remuneration Policy approved by the Extraordinary General Meeting of

Shareholders held on 14-12-2022, for the period 2020-2025, an additional incentive shall be provided to

reward the executives of PPC S.A. and PPC Renewables Single Member S.A. for their contribution to the

achievement of the medium-term goals of the Group, in the form of four (4) cycles of Stock Awards, which

is governed by the provisions of article 114 of Law 4548/2018 in conjunction with the article 49 the same

law and will be carried out through own shares of the Company. The terms of the Program can be found

in Annex III of the Company’s Remuneration Policy https://www.dei.gr/media/q3vjbijw/epexhghseis-epi-

tou-3ou-thematos-ths-egs-14122022_politikh-apodochon.pdf. A detailed description of the acquisition of

own shares regarding the aforementioned stock awards programme can be found in Notes 7 and 26 of

2022 Financial Statements.

On 22.8.2022, the Company signed a Mandate Contract with the current Chairman and CEO, Mr.

Georgios Stassis. Moreover, the Company has signed Work Contracts for a three-year period with the

Executive Members of the Board of Directors and at the same time Deputy CEOs, Mr. A. Paterakis and

Mr. G. Karakousis as of 20.1.2020 and 27.02.2020 respectively. Furthermore, the Company has signed

a Work Contract for a three-year period with the Deputy CEO and non-member of the BoD, Mr. I.

Kopanakis, on 20.01.2020, which expired on 20.01.2023. Finally, within 2020, PPC proceeded to the filling

up of vacant statutory posts of Chief Officers, Directors, Assistant Directors/ Heads of Unit level, through

public call, with fixed-term contracts for a period of up to three years, which may be renewed only once.

Employees of the Company and nominees outside the Company were entitled to participate in the said

procedure.

VI. Convocation and Functioning of the Governing Bodies

A. Board of Directors

1) Composition and functioning of the BoD – term of office of each member

Composition and Term of Office of the Board of Directors

Pursuant to Article 9 of the Company's Articles of Incorporation, the Board of Directors (or "BoD") shall

consist of eleven (11) members divided into executive and non-executive members and elected for a

three-year term of office, at least five (5) of whom shall be independent non-executive members. In order

to ensure continuity in the administration of the corporate affairs and the representation of the Company,

the term of office of each member may be extended ipso iure until the first Ordinary General Meeting to

be held after the expiration of its term.

The members of the Board of Directors may in any case be re-elected and may at any time be revoked

by the General Meeting of the Shareholders.

The participation of independent and/or non-executive members to the Board of Directors shall not exceed

three consecutive terms, namely nine (9) years in total.

The number of the non-executive members of the Board linked by any type of employment relation to the

Company or to any of its associated companies cannot exceed three (3) out of the total number of its

members.

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The Board of Directors consists of eleven (11) members, including the CEO, elected by the General

Meeting of shareholders of the Company, based on the Company’s Suitability Policy, as in force each

time and posted on the Company’s website, which includes the Conflict of Interest Policy and rules for

safeguarding diversity on the Board of Directors in terms of gender, age, representation of shareholders

and educational/professional background. The Board of Directors elects from among the said members

its Chairman and Vice Chairman, pursuant to article 14 of the Articles of Incorporation. One (1) non-

executive member out of the aforementioned members of the Board of Directors represents the

employees of the Company. This member shall be elected by the General Shareholders' Meeting from a

list of proposed candidates submitted to the Nomination, Remuneration and Recruitment Committee by

the most representative trade union (ΑSOP), at least two (2) months before the expiry, in any way

whatsoever, of the term of the previous member, in order to be evaluated and elected by the General

Meeting of the Shareholders as defined above.

In the event of non-election or non-prompt filling of any vacancy or non-substitution of the members of the

Board, for any reason whatsoever, this shall not impede the constitution and functioning of the Board of

Directors without these members, provided that the remaining members are not less than six (6).

In the event that for any reason whatsoever there is a vacancy in the office of the CEO, or the latter is

absent or temporarily unable to perform his/her duties, the Chairman of the Board of Directors shall

temporarily act as CEO, unless otherwise specified by the Board of Directors.

In the event that for any reason whatsoever there is a vacancy in the office of the Chairman of the Board

of Directors, or the latter is absent or temporarily unable to perform his/her duties, the Vice Chairman of

the Board, appointed pursuant to par.1 article 14 of the Articles of Incorporation, shall temporarily act as

Chairman. If the posts of the Chairman of the Board of Directors and the CEO coincide to the same person

and for any reason whatsoever there is a vacancy in the office, or he/she is absent or temporarily unable

to perform his/her duties, an executive member from among the members of the Board of Directors, to be

appointed or already appointed by the Board of Directors, shall temporarily act as CEO. In such cases,

the Board of Directors shall convene the General Meeting of the shareholders as soon as possible to elect

the new CEO.

For the selection of the candidate members on the Board of Directors, upon decision of the Board of

Directors, the company has established a Nomination, Remuneration and Recruitment Committee

consisting of at least three (3) non-executive Board members, independent in their majority. The

Nomination, Remuneration and Recruitment Committee on the one hand identifies and proposes to the

Board of Directors, and through it to the General Meeting, persons suitable for membership on the Board

of Directors, based on the procedure provided for in the Company’s Rules of Operation and pursuant to

the Suitability Policy adopted by the Company, and on the other hand examines any impediments and

incompatibilities, as well as the criteria of independence of candidates for membership on the Board of

Directors (especially in the case of appointment of independent members), pursuant to Law 4706/2020

and Law 4548/2018, as in force, for candidates proposed by the Nominations, Remuneration and

Recruitment Committee itself or by the shareholders.

The Board of Directors shall post on the Company's website twenty (20) days prior to the date of the

meeting of the General Meeting related to their election, the nominations for membership on the Board of

Directors' with detailed curricula vitae and rationale of its proposal for each candidate.

Pursuant to the Company's Articles of Incorporation as in force as of 7-4-2022 regarding the member-

employee representative on the Board of Directors of the Company, the Nomination, Remuneration and

Recruitment Committee, in view of the election of members of the Board of Directors due to the expiration

of their term of office, sent a letter to the GENOPO/PPC-KIE for appropriate action, to which letter there

was no response and therefore no employee was nominated as Member-Employee Representative for

the one (1) seat on the Board of Directors.

Nevertheless, pursuant to article 9 par. 3 of the Articles of Incorporation of PPC S.A. “In the event of non-

election or non-prompt filling of any vacancy or non-substitution of the members of the Board, for any

reason whatsoever, this shall not impede the constitution and functioning of the Board of Directors without

these members, provided that the remaining members are not less than six (6)”. Given that, the failure to

fill the position of Member-Employee Representative shall not impede the constitution and lawful

functioning of the Board of Directors.

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Following the above, the Annual General Meeting of the Company's shareholders on 29-06-2022 decided

the election of Mr. Grigorios Dimitriadis as a Member of the Board of Directors for a term of office starting

on 29-06-2022 and ending on 28-06-2025, the election of Ms. Despina Doxaki, as Independent Non-

Executive Member of the Board of Directors, for a term of office starting on 29-06-2022 and ending on 28-

06-2025, the election of Mr. Georgios Stassis, as Chief Executive Officer of PPC S.A, Mr. Pyrros

Papadimitriou, Mr. Stephanos Kardamakis and Mr. Stephanos Theodoridis as Independent Non-

Executive Members of the Board of Directors and Mr. Alexander Paterakis and Mr. Alexandros Fotakidis

as Members of the Board of Directors for a term of office starting on 22.08.2022 and ending on 21.08.2025

respectively.

The existing ten-member (10) Board of Directors, which consists of eight (8) men and two (2) women, in

full compliance and harmonization with the provisions of Law 4706/2020 on suitability, diversity and, above

all, adequate gender representation on the Board of Directors, was formed into a Body on August 23,

2022 as follows:

Member

Position on the BoD

Term of office

starting on

Term of office

ending on

Georgios Stassis

Chairman of the BoD &

Chief Executive Officer,

Executive Member

22 August 2022

21 August 2025

Pyrros Papadimitriou

Vice Chairman of the

BoD, Independent Non-

Executive Member

22 August 2022

21 August 2025

George Karakousis

Deputy Chief Executive

Officer, Executive

Member

17 December 2021

16 December 2024

Alexandrer Paterakis

Deputy Chief Executive

Officer, Executive

Member

22 August 2022

21 August 2025

Grigorios Dimitriadis

Non-Executive Member

29 June 2022

28 June 2025

Alexandros Fotakidis

Non-Executive Member

22 August 2022

21 August 2025

Maria Psillaki

Independent Non-

Executive Member

17 December 2021

16 December 2024

Despina Doxaki

Independent Non-

Executive Member

29 June 2022

28 June 2025

Stefanos Kardamakis

Independent Non-

Executive Member

22 August 2022

21 August 2025

Stefanos Theodoridis

Independent Non-

Executive Member

22 August 2022

21 August 2025

2. Curriculum Vitae of the members of the Board of Directors

The brief CVs of the Company’s BoD members are as follows:

Georgios Stassis, Chairman & CEO, Executive Member

Georgios Stassis has more than 17 years of experience in the energy market. He has held important

positions in various organizations and associations within the energy sector in Greece and the southeast

Europe, and within all parts of a utility value chain (generation, distribution, supply). Previously worked for

ENEL SpA, as President & CEO of Enel Romania SrL., the largest vertical integrated energy company in

Romania, and before as head of Green Power for Eastern Europe and Middle East. Mr. Stassis holds a

bachelor’s degree in Civil Engineering and a master’s degree in Management in Construction and

Structural Design from Kingston University (UK) and has attended Executive Courses at Harvard Business

School (US) and at Elis Academy (Italy).

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Pyrros Papadimitriou, Vice-Chairman, Independent Non-Executive Member

Pyrros Papadimitriou is an economist, lawyer and associate professor in International Economic Relations

at the University of Peloponnese. He holds a Degree in Political Science & Public Administration from the

University of Athens (1985), a Law Degree from Athens Law School (1989), a Post-Graduate Diploma in

Economics from Sussex University (1987), a Master in Economics (1988) and a Ph.D. in Economics

(1992) both from Kent University at the UK. In the past he worked as a financial analyst at Gerald &

National Inter Commodities in London (1989-1990) and continued as a researcher at the Foundation for

Economic & Industrial Research in Athens (1994-1995), manager in the Sectoral Research & Analysis

Department of ALPHA Bank (1995-1996), advisor to the European Parliament (1996-1998) and director

of Consulting Services at ICAP S.Α. (1999-2000). In 1996 Pyrros founded HEADWAY Economic

Consultants Ltd and he remained the main shareholder of the company until the end of 2021. Between

2006-2015 as a co-founder, Pyrros cooperated with Four Assist Development Consulting Ltd, which

mainly undertakes projects in the field of Public Financial Management and Economic Development in

developing countries In the period 2007-2009, Pyrros, as Chairman and Chief Executive Officer, ran the

privatization project of Olympic Airlines, Olympic Airways – Services and Olympic Aviation. In 2012 he

has been appointed Coordinator of the Privatization of the Greek Regional Airports, a project that has also

been concluded successfully with the acquisition of the airports from Fraport AG.During the last years,

Pyrros, apart from his academic duties, implements various consulting projects for governments in the

developing word in the field of public financial management and employment. From October 2019, he is

also the general director of the research institute KMOP Policy Center ASBL, based on Belgium.

George Karakousis, Executive member

George Karakousis is an executive with significant experience in commercial roles in the technology,

telecommunications and energy sectors. He has successfully designed and implemented the commercial

strategy for large corporations in Greece and the UK and has led significant commercial transformation

projects. Over the past 18 years he has held commercial roles of increasing responsibility in companies

such as Forthnet and Wind Hellas, successfully introducing new products and services. In the UK he was

responsible for Talk Talk’s product portfolio re-design, while in British Telecoms (BT) he was at the helm

of the biggest service transformation project for over nine million customers. In recent years he has been

leading the commercial transformation of PPC with very positive results. He holds an Electrical &

Computer Engineering degree from the National Technical University of Athens, a master’s degree (MSc)

from Imperial College London and an MBA from ALBA Graduate Business School.

Alexander Paterakis, Executive member

Alexander Paterakis holds a BSc in Computer Engineering and Mathematics from the University of La

Verne. He began his career as a Network Engineer and subsequently held a series of senior IT positions

such as Head of Consulting Division in MicroAge, Management Consultant in Arthur Andersen (now

Accenture) in the UK as well as in Greece. In 2003 he served as Information Technology Director at Tellas,

while in 2008 he joined Vodafone where he was promoted to CIO. He then moved in Etihad Etisalat

(Mobily), where he was appointed as a Chairman of Infotech Mobility India Pvt Ltd and completed his

career as a CIO in Saudi Arabia actively promoting the ICT transformation. Since 2016 he provides

business consulting services focusing on the digital strategy field. In 2018 he assumed the position of CIO

in AXIATA Celcom, a telecommunication provider company in Malaysia.

Grigorios Dimitriadis, Non-Executive Member

Gregory D. Dimitriadis is the Chief Executive Officer and Executive Board Member of GROWTHFUND,

the National Fund of Greece, since February 2021. He studied in the UK and the USA, holding a bachelor

with honours in engineering (Manchester Metropolitan University) and two masters; one in the field of

telecommunications (University College London) and another in international business relations and

international negotiations (The Fletcher School, Tufts University).

He is an executive with national and international experience in leading management positions in both the

private and public sector. He served as Chairman of Enterprise Greece and Secretary General for

International Economic Affairs of the Ministry of Foreign Affairs, dealing with numerous strategic

investments in Greece and led the development of the National Strategy for Trade & Investment

Promotion. Prior to that, he was Executive VP at HVA International in Amsterdam, Managing Director of

Iskra Zaščite (Raycap Group) in Ljubljana, Chairman & CEO of the Athens Urban Transport Organization,

and project leader for Greece’s National Strategy for exports at the Ministry of Development.

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Alex Fotakidis, Non-Executive Member

Alex Fotakidis is a Partner at CVC and Head of CVC Greece. Alex joined CVC in 2006 and is based in

Athens. Alex is responsible for all of CVC’s investment activities in Greece, including Hellenic Healthcare

Group, Skroutz, Vivartia, Dodoni, PPC and Ethniki Asfalistiki. He previously spent five (5) years at CIBC

World Markets, working in the European Leveraged Finance team with primary role the origination,

structuring, execution and syndication of debt financing for buyouts on behalf of private equity clients. Alex

holds an MSc in Environmental and Natural Resource Economics and a BSc in Economics and

Geography, both from University College London.

Maria Psιllaki, Independent Non-Executive Member

Maria Psillaki is Professor at the Department of Economics of the University of Piraeus. She studied at

the University of Nice Sophia Antipolis, in France where she received her Bachelor, Master and PhD with

the highest honors. For her PhD in Finance, she received a scholarship from the French Ministry of

Education. She has held visiting research positions in London (Birckbeck College, University of London)

as Visiting Researcher (Post-Doctoral Research Fellow), funded by the CEPR (Centre for Economic

Policy Research) and ERSC (Economic and Social Research Council) and in Chicago as Visitor

Researcher at the Graduate Booth School of Business, University of Chicago. She has lectured at various

universities abroad to both undergraduate and postgraduate programs. She has also held visiting faculty

positions at European and American universities such as the Rutgers University in New Jersey (USA),

Department of Business Administration, and the University of Cyprus, Department of Public and Business

Administration. Before joining the University of Piraeus in 2009, she was Associate Professor at the

University of Nice-Sophia Antipolis in France at the Economics Department from 2001 until August 2008.

Finally, since 2009 she is a tutor at the Hellenic Open University in the “Banking” postgraduate program.

She has participated in various European research Programs. She has published in high quality reviewed

journals such as the Journal of Small Business Management, the European Journal of Operational

Research, the Journal of Business Finance and Accounting, the Journal of Banking and Finance, the

Small Business Economics, the Applied Financial Economics, the Journal of Productivity Analysis. She

serves as referee in a number of reputed journals such as the Journal of Banking and Finance, the Small

Business Economics, the European Journal of Operational Research. From 2009 to 2012 she was Vice

President of the Hellenic Finance and Accounting Association (HFAA). Her areas of expertise are in

corporate finance, and banking.

Despina Doxaki, Independent Non-Executive Member

Despina Doxaki was born in 1968. She graduated from the School of Law of the National and Kapodistrian

University of Athens and is holder of an LLM in European Law from the Institute of European Studies in

Brussels. She has more than 26 years of working experience in cross-border transactions mainly in

collaboration with commercial, investment, institutional and development banks and specializes (1) in

structuring and negotiating national and international complex financial contracts such as structured

finance, (2) project finance in all development sectors such as energy, infrastructure projects, real estate,

tourism, hospitals etc. through PPP or/and Concession Agreements, (3) corporate finance and

transformations (IPOs, capital markets transactions) (4) all types of corporate lending, debt restructuring

and refinancing etc. During her career she has worked at the European Commission, KPMG, Alpha Bank

S.A., ΚIS ATE, while for the last 15 years she has worked in Kyriakidis-Georgopoulos Law Firm, in

Brussels in the English Law Firm Stanbrook&Hooper (McDermont&Ellis) and in the international law firms

Chadbourne/NRF, Shearman and Milbank in London.Since 2018 she has been Head of Legal at the

Hellenic Financial Stability Fund. She has work experience in Athens, London and Brussels and speaks

Greek, English and French.

Stefanos Theodoridis, Independent Non-Executive Member

Stefanos Theodoridis has served for more than 35 years as Senior Executive of business groups in

Greece and abroad, of which 25 years as CEO. From 1989 to 2006, he held the position of CEO at

DIAGEO S.A., initially for Greece and in the last years for Southern & Eastern Europe. He was responsible

for 18 countries and was also member of the European Executive Committee of the Company. From 2006

to 2011, he had served as CEO of HYATT REGENCY SA, a leader in Tourism & Leisure industry. From

2012 to date, he holds the position of CEO at TEMES Group, one of the leading companies in the

development and management of high-end tourism destinations and holiday destinations, such as Costa

Navarino and HILTON ATHENS. In addition to his current position, he is Vice Chairman of GIOCHI

PREZIOSI Group, a toy import and trading company in Greece & Turkey, Member of the BoD of the

Foundation for Economic & Industrial Research (IOBE) and Member of the Board of Directors of the

Hellenic-Swedish Chamber of Commerce and Member of the Tourism and Development Committee of

the Hellenic American Chamber of Commerce. He is married and has two children.

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Stefanos Kardamakis, Independent Non-Executive Member

Stefanos Kardamakis was born in Athens in 1967. He graduated from the Department of Mechanical

Engineering of the National Technical University of Athens in 1991. He then obtained a Master’s degree

(MSc) in Finance, Commerce and Shipping from City University, Cass Business School of London.He

started his professional career in 1993 in the Technical Department of Adelfia Shipping Enterprises.In

1994 he joined the Dutch Bank ABN AMRO as Customer Manager of the Shipping Finance Department,

where he was promoted to the position of Vice President. In 2004 he served as Head of the newly

established Shipping Division of Egnatia Bank in the field of financing. During his 14-year career in the

Banking industry he was involved in financing proposals, financial transactions and products, as well as

in concluding large, syndicated loans with other banks on behalf of large shipping companies. He was

also occupied with the optimization of internal processes and the introduction of new methods to better

monitor and improve operational & credit risk, as well as the restructuring of non-performing loans. In

2008, he assumed the position of CFO at Conbulk Shipping S.A. and since 2019, he has also held the

position of Chief Operating Officer, being responsible, apart from the financial management, for the

operational, technical and procurement department of the said company.

The composition of the Board of Directors is fully compliant with the Regulations of Law 4706/2020 on

Corporate Governance.

Functioning of the Board of Directors

With regard to the functioning of the Board of Directors, the Company's Articles of Incorporation provide

for the following:

Competences of the Board of Directors

The Board of Directors is the supreme governing body of the Company which shall formulate primarily its

development strategy and Policy, as well as supervise and exercise control over the management of its

assets. The Board of Directors shall approve, upon recommendation of the CEO: a) the Strategic Plan,

which determines the strategic goals for the attainment of the Company’s objectives, b) the Business Plan

of the Company of a duration of three (3) to five (5) years, which specifies the goals of the Strategic Plan

for each year of its duration, c) the methods for the implementation of the Strategic Plan and the Business

Plan for each year of their duration. The Board of Directors shall also monitor the implementation of the

Strategic Plan and the Business Plan.

The Board of Directors shall represent the Company and shall be vested with unlimited authority to decide

on any act and to exercise full power concerning the management of the company, the management of

its property and in general the fulfilment of its object, with the exception of those issues which either by

law or by the Articles of Incorporation, expressly fall within the jurisdiction of the General Meeting.

The Board of Directors shall, upon recommendation of the CEO, approve the annual budget of the

company, prepare, approve and submit to the General Meeting for approval the annual financial

statements of the company and prepare and submit to the General Meeting the annual report. Moreover,

the Board of Directors, upon recommendation of the Nomination Remuneration and Recruitment

Committee, approves the recruitment policy of the Company, pursuant to the relevant legislation as

applicable each time.

The Board of Directors shall decide, upon recommendation of the CEO: a) the necessity of establishing

positions of Deputy CEOs, as well as on their number and competencies thereof, b) the basic organization

of the company divided into Divisions, which constitute the highest administrative level of its organizational

structure, c) the establishment of positions of Chief Officers and their competencies.

The Board of Directors may, upon recommendation of the CEO, delegate part of its administration and

representation competencies, except for those which, pursuant to the Law and its Articles of Incorporation

require collective action or fall within the exclusive jurisdiction of the CEO in accordance with Article 15 of

the Articles of Incorporation, as well as the administration or supervision of the affairs or the representation

of the Company to the Chairman, to the CΕΟ, to the Deputy CEOs, to one or more of the Board Members,

to the Company’s Committees, to the Chief Officers, to the Directors or to employees of the Company.

116

The aforesaid persons to whom the competencies described above are delegated and who do not have

the capacity of Board Member carry the same responsibility towards the Company as the members of the

Board of Directors, pursuant to article 102 of Law 4548/2018 as applicable and to article 12 of the

Company’s Articles of Incorporation.

Convocation and Functioning of the Board of Directors

The Board of Directors shall meet at the seat of the Company and/or outside its seat at the facilities of

PPC at Kozani, Megalopolis and Aliveri, upon the call of the Chairman or his/her substitute on such day

and hour as determined by him/her, whenever required following the needs of the Company.

The Board of Directors may lawfully meet by way of teleconference with some or all Board members,

upon invitation to the Board members, which shall include all necessary information and technical

instructions with respect to their participation in the meeting. In any case, any Board member may request

the holding of a meeting by way of teleconference if he/she resides in a country other than the one where

the meeting is to be held or if there is any other serious reason, especially illness or disability.

At the request of two (2) Board Members, the Chairman or his/her substitute shall be obliged to convene

the Board of Directors, setting the date of the meeting, which shall not be later than seven (7) days from

the submission of the relevant request, under penalty of inadmissibility, which shall also clearly state the

proposed items on the agenda to be discussed by the Board of Directors. In case the Board of Directors

is not convened by the Chairman or his/her substitute within the aforementioned deadline, the requesting

members shall be allowed to convene themselves the Board of Directors within five (5) days from the

expiration of the above deadline of seven (7) days, by notifying the relevant notice to the remaining

members of the Board of Directors.

The agenda of the meetings shall be determined by the Chairman and its items shall be clearly stated in

the notice sent to the members of the Board at least two (2) working days prior to the date of the meeting

and at least five (5) working days in the event that the meeting is to be held at a venue other than the

company’s seat, otherwise the decision-making is allowed only if all members of the Board of Directors

are present or represented at the meeting and none of them objects to the decision-making.

A quorum of the Board shall be deemed to be present and the meeting shall be deemed valid if, pursuant

to paragraph 6 of the present article, one more than half the number of members is present or represented.

In no case, however, shall the number of members physically present be less than three (3). In determining

the number required to form a quorum, fractions, if any, shall be ignored.

The Board of Directors shall take its decisions by absolute majority of the members present or

represented. In case of equality in votes, the Chairman’s vote shall prevail.

Each Board Member may, following written authorization, validly represent only one member thereof. The

representation to the Board of Directors may not be assigned to a person who is not member of the Board

of Directors.

Minutes of the proceedings and decisions of the Board of Directors shall be kept in accordance with the

Law and in particular with article 93 of Law 4548/2018, as applicable. The minutes shall be signed by the

Chairman and the Board Members who attend the relevant meeting. In the event that one of the members

refuses to sign, this shall be indicated in the minutes accordingly.

The copies of and the excerpts from the minutes of the Board of Directors shall be signed by the Chairman

or by a person designated by the Board of Directors to this end, without any other validation being

necessary.

The General Counsel may attend the meetings of the Board of Directors without having the right to vote,

unless otherwise decided by the Board of Directors.

The drawing up and the signing of the minutes by all the members of the Board of Directors or their

representatives is equal to a decision of the Board of Directors, even if no meeting has preceded. The

above section shall also apply if all Board members or their representatives agree to record their majority

decision in the minutes, without holding a meeting. The relevant minutes shall be signed by all members

and shall be entered in the minute’s book in accordance with article 93 of Law 4548/2018.

In the case of the previous paragraph the signatures of the Board Members or their representatives may

be substituted with the exchange of messages via email or other electronic communication media, e.g. by

means of a qualified digital signature.

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Liability and duties of the Board Members

Each Board Member shall be liable vis-a-vis the company, in accordance with articles 96 to 102 of Law

4548/2018, for any fault committed, due to an action or omission during the performance of their duties,

which constitutes violation of their duties, in accordance with the Law and the company’s Articles of

Incorporation, as applicable. In particular, Board members and third parties to whom duties may have

been assigned by the Board of Directors, shall be obliged to disclose to the Board of Directors, promptly

and appropriately, any conflict of interest which may arise during the performance of their duties between

themselves or other persons with whom they have close relations and the company or the companies of

its Group, as soon as they take knowledge thereof. In any case, the aforementioned persons shall be

obliged to refrain from any action related to corporate actions which may give rise to such conflict of

interest until the date on which the company will examine the conflict of interest statement.

The Board Members shall be bound, inter alia, to handle the corporate affairs with a view to promoting

corporate interest, to oversee the execution of the decisions of the Board of Directors and of the General

Meeting, as well as to brief the other Board Members on any corporate affairs.

The Board Members and any third party to whom the Board of Directors has assigned any of its

competences shall be bound to keep absolute secrecy with regard to all confidential information in respect

of the affairs of the company coming to their knowledge in their capacity as Board Members.

The provisions of articles 99 to 101 of Law 4548/2018, which include regulations concerning transactions

with related parties shall also apply to Chief Officers and Directors of the Company.

The appointment and the dismissal for any reason whatsoever of the Board Members and of the persons

empowered to represent the company jointly or severally shall be subject to publication, as stipulated by

articles 12 and 13 of Law 4548/2018, as applicable, together with their identity particulars and in any case

as provided for by law each time.

Compensation of Board Members

The company shall establish a remuneration policy and shall draw up a remuneration report, pursuant to

articles 110 to 112 of Law 4548/2018 and article 11 of Law 4706/2020 as applicable, in accordance with

article 17 par. 1 of the Company’s Articles of Incorporation as in force.

3. Chairman, Vice-Chairman of the Board of Directors and Chief Executive Officer

Chairman of the Board of Directors

The Chairman of the BoD shall be elected by the Board of Directors. The capacity of the Chairman of the

BoD may coincide with that of the CEO. In this case, the Board of Directors shall mandatorily appoint the

Vice-Chairman from among its non-executive members.

The Chairman of the BoD guides the BoD, shall contribute to ensuring the efficient flow of information,

both within the BoD and between the BoD and its Committees and shall be responsible for its effective

overall operation. The Chairman of the BoD shall encourage and promote open and critical discussions

and ensure that divergent views can be expressed and discussed in the decision-making process.

The Chairman of the BoD determines the items on the agenda of the meetings and ensures that issues

of strategic importance are discussed as a matter of priority. The Chairman should also ensure that the

BoD makes informed and appropriate decisions and that the relevant documents and information are

received in a timely manner before the meeting.

The Chairman of the BoD shall contribute to a clear allocation of duties between the BoD Members and

ensure the efficient flow of information between them, so that the BoD Members in their supervisory

function have the opportunity to contribute constructively to the discussions and to exercise their voting

right on a proper basis and in a well-informed manner.

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Vice-Chairman of the Board of Directors

The Chairman of the BoD shall be elected by the Board of Directors. Since in PPC the capacity of the

Chairman of the BoD coincides with that of the CEO, the Board of Directors has appointed the Vice-

Chairman from among its Independent Non-Executive Members, who in the event that for any reason

whatsoever there is a vacancy in the office of the Chairman of the Board of Directors, or the latter is absent

or temporarily unable to perform his/her duties, the Vice Chairman of the Board shall temporarily act as

Chairman and shall have the following responsibilities: to support the Chairman, to act as a liaison

between the Chairman and the members of the Board of Directors, to coordinate the independent non-

executive members and to lead the evaluation of the Chairman.

Chief Executive Officer

The Chief Executive Officer of the Company shall be elected by the General Meeting of Shareholders and

his term of office shall be three years.

The Chief Executive Officer shall be the highest-ranking executive officer of the company, he/she shall be

at the head of all the services thereof, conduct their activities, decide on the further organization of the

Company, within the scope of the present Articles of Incorporation and the relevant resolutions of the

Board of Directors, make the necessary decisions pursuant to the provisions governing the operation of

the Company, the approved plans and budgets, the Strategic Plan (S.P.), the Business Plan (B.P.) and

the terms of the Management Contract he/she has entered into with the company pursuant to Article 16

of the Articles of Incorporation. The Chief Executive Officer shall represent the Company within the limits

of his powers under the Articles of Incorporation or the resolutions of the Board of Directors and may

authorize or empower other persons members of the Board of Directors to senior or top executives of the

Company and any kind of PPC's service units to represent him.

The Chief Executive Officer shall have the following duties under the Articles of Incorporation and such

other duties as the Board of Directors may delegate to him by resolution:

• Submit to the Board of Directors of the Company the proposals and recommendations required

for the attainment of the company’s objects, as specified in the Strategic Plan and the Business

Plan.

• Make decisions on the awarding of contracts of a value to be determined on each occasion by

resolution of the Board of Directors.

Deputy CEOs

The Deputy Chief Executive Officers shall report to the Chief Executive Officer and shall be at the head

of wider business activities structured into Divisions and Business Units. They may be members of the

Board of Directors among those elected by the General Meeting of the shareholders of the Company. The

number and duties of the Deputy Chief Executive Officers shall be determined by the Board of Directors

upon recommendation of the Chief Executive Officer.

Secretary of the Board of Directors

The Secretary of the Board of Directors, who is the Director of the BoD Secretariat shall provide support

to the Board of Directors, ensuring its smooth and efficient functioning.

The BoD Secretariat, in the context of its mission, shall be responsible for handling all matters related to

the functioning of the Board of Directors, in accordance with the Law, the Articles of Incorporation and the

Regulations of the Company and for handling matters pertaining to the administrative and operational

support of the Board Committees and their members.

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4. Definition of the non-executive BoD members that the Board of Directors views as independent

and the rationale behind this view

Non-Executives and Independent Non-Executives Members of the BoD shall have a purely supervisory

and strategic role in contrast to the Executive Members who are responsible for the implementation of the

BoD strategy and have executive responsibilities regarding the management of the Company.

The independent Non-Executives Members of the BoD play a key role in enhancing the effectiveness of

controls and the balance within the BoD by improving the oversight of decision-making by the executive

management, as well as by ensuring that:

• the interests of all stakeholders, including minority shareholders, are duly taken into account in

the discussions and decision-making of the BoD.

• the undue domination of individual BoD Members who represent a specific group or category of

stakeholders is mitigated or compensated for; the decision-making is not dominated by an

individual or a small group of members; and

• conflicts of interest between, on the one hand, the Company, its business units, other entities

that fall within the accounting scope of consolidation and, on the other hand, external

stakeholders, including customers, are subject to proper management.

The independence criteria of the Independent Non-Executive Members of the Board of Directors are

specified in the Suitability Policy for the members of the Board of Directors of PPC S.A., as well as in the

Procedure for Disclosure of any Dependency Relations of the Independent Non-Executive Members of

the Board of Directors of PPC S.A. as follows:

A Non-Executive Member of the BoD is considered independent if during his/her appointment and during

his/her term of office:

(a) does not hold, directly or indirectly, a percentage of voting rights greater than zero-point five

percent (0.5%) of the Company's share capital, and

(b) is free from financial, business, family or other dependent relationships, which may influence its

decisions and its independent and objective judgement (hereinafter referred to as "dependent

relationships").

A dependent relationship exists in the following cases:

(a) When a member receives any significant remuneration or benefit from the Company, or from an

affiliated company, or participates in a stock options system or any other performance-related

remuneration or benefit system, other than remuneration for his/her participation in the BoD or in its

Committees, as well as in the collection of fixed benefits within the framework of the pension system,

including the rescheduled benefits, for his/her previous services in the Company. The criteria defining the

meaning of meaning of significant remuneration or benefit are defined in the Company's remuneration

policy.

(b) When the member or person who has close ties with the member maintains or has maintained a

business relationship during the last three (3) financial years prior to his/her appointment with:

(ba) the Company, or

(bb) an affiliated person of the Company, or

(bc) a shareholder who directly or indirectly holds a stake equal to or greater than ten percent (10%) of

the Company's share capital during the last three (3) financial years prior to his/her appointment, or an

affiliated company, provided that this relationship affects or may affect the business activity of either the

Company or the person referred to in par. 1 or the person having close ties with it. Such a relationship

exists especially when the person is a significant supplier or a significant customer of the Company.

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c) When the member or the person who has close ties to the member:

(ca) has been a member of the BoD of the Company or of an affiliated company thereto for more than

nine (9) financial years in total at the time of his/her election,

(cb) has been a Senior Executive or entered into an employment or project or service relationship or a

salaried mandate relationship with the Company or with an affiliated company thereto during the last three

(3) financial years prior to his/her appointment,

(cc) is related to the second degree by blood or by marriage, or is a spouse or partner equated with a

spouse of a Board Member or Senior Manager or shareholder, with a participation percentage equal to or

greater than ten percent (10%) of the Company’s share capital or an affiliated company thereto,

(cd) has been appointed by a specific shareholder of the Company, in accordance with the Articles of

Incorporation, as provided for in article 79 of Law 4548/2018,

(ce) represents shareholders holding directly or indirectly a percentage equal to or greater than five

percent (5%) of the voting rights at the General Meeting during his/her term of office, without any written

instructions;

(cf) has carried out a statutory audit to the Company or to an affiliated company thereto, either through a

company or by himself/herself or by an up to second-degree relative by blood or by marriage, or by his/her

spouse, during the last three (3) financial years prior to his/her appointment,

(cg) is an Executive member in another company, in the BoD of which an Executive member of the

Company participates as a non-executive member.

(d) When the member falls under one of the dependent relationships provided for in any other statutory

or regulatory texts to which the Company is subject and which the Company applies, either on an optional

or a mandatory basis (for instance, Articles of Incorporation of the Company, Corporate Governance

Code, Rules of Procedure of the Board of Directors).

The Independent Non-Executive Members of the Board of Directors jointly submitted a Report to the

Annual General Meeting of Shareholders on 29.06.2022, in accordance with article 9 par. 5 of Law

4706/2020 and the relevant guidelines of the Hellenic Capital Market Commission with reference to the

manner in which the Non-Executive Members of the Board of Directors, including the Independent Non-

Executive Members fulfilled their obligations in the financial year 2021 with regard to:

a) Monitoring and review of the Company's strategy and its implementation, as well as of the achievement

of its objectives.

b) Ensuring effective supervision of executive members, including monitoring and controlling their

performance.

c) Considering and expressing their views on proposals submitted by executive members, based on

existing information.

Also, in compliance with the relevant provision of the Hellenic Corporate Governance Code of the Hellenic

Corporate Governance Council, which the Company has adopted and applies, the Non-Executive

Members of the Board of Directors of the Company met on 12.12.2022, with the Independent Vice-

Chairman of the Board of Directors in the chair. During the said meeting, improvement actions were

discussed following the internal evaluation of the Board's performance conducted during the first half of

2022.

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5. Number of meetings of the Board of Directors, frequency of participation of each member

and issues dealt with by the Board of Directors

In 2022, 26 meetings of the Board of Directors took place. In particular, the table below shows the number

of meetings attended by the members of the Board of Directors.

Member

Position on the BoD

Number of meetings

attended by the BoD

members

Georgios Stassis

Chairman & Chief Executive Officer,

Executive Member

Pyrros Papadimitriou

Vice-Chairman, Independent Non-

Executive Member

George Karakousis

Deputy Chief Executive Officer,

Executive Member

Alexander Paterakis

Deputy Chief Executive Officer,

Executive Member

Maria Psillaki

Independent Non-Executive Member

Despina Doxaki

Independent Non-Executive Member

Stefanos Kardamakis

Independent Non-Executive Member

Stefanos Theodoridis

Independent Non-Executive Member

Michael Panagiotakis

Independent Non-Executive Member

Pantelis Karalefteris

Non-Executive Member - Employee

Representative

Nikolaos Fotopoulos

Non-Executive Member - Employee

Representative

Grigorios Dimitriadis

Non-Executive Member

Alexandros Fotakidis

Non-Executive Member

Note:

(1) On 29.06.2022 the term of office of the Members of the Board of Directors - Employee

Representatives Mr. Pantelis Karalefteris and Mr. Nikolaos Fotopoulos expired.

(2) The Annual General Meeting of the Company's shareholders held on 29.06.2022 decided the

election of Mr. Grigorios Dimitriadis following the reduction of the positions of Employee

Representatives from two (2) to one (1) (due to the relevant amendment of the provisions of the

Company's Articles of Incorporation).

(3) The Annual General Meeting of the Company's shareholders on 29.06.2022 decided the election

of Mr. Alexandros Fotakidis, with term of office starting on 22.08.2022, to replace Mr. Michael

Panagiotakis, due to the expiration of his term of office on 21.08.2022.

The main issues discussed at the Board of Directors' meetings during the 2022 financial year:

• Approval of the Financial Statements.

• Approval of new and/or revision of existing Regulations and Policies in the context of compliance

with the new law on corporate governance.

• Approval of the amended Remuneration Policy, approval of the FY 2021 Remuneration Report,

approval of the report on the degree of achievement of the CEO's objectives, which are also the

Group's objectives, for the Financial Year 2021.

• Approval of a new Regulation on Works, Supplies and Services (RWSS) of PPC S.A.

• Procurement issues (tendering procedures, contracts, awarding, etc.).

• Subsidiaries’ issues (new investments, financing, mergers, changes in share capital, etc.).

• Bond loans (approval of the prospectus and related documents, amendment of contracts, etc.).

• Risk Assessment and Annual Audit Plan (AAP) of the Internal Audit Department (IAD) for the

year 2022.

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• Amendments to the Articles of Incorporation.

• Proposal to the General Meeting of the Company's shareholders for the election of Board

members and Chief Executive Officer due to the expiry of their term of office.

• Appointment of members of the Audit Committee, Appointment of members of the Nomination,

Remuneration and Recruitment Committee.

• Staff management issues, new recruitment policy, recruitment notices and organisational

changes, voluntary redundancy scheme 2022.

• New investments (approval of the implementation of an investment in the telecommunications

sector, development, installation and operation of the East Med Corridor cable system (EMC

System), establishment of a company jointly with Motor Oil (Hellas) Corinth Refineries S.A. for

the production, storage and trading of green hydrogen).

• Establishment of a plan to purchase own shares.

• Approval of the 2023 Budget.

6. Suitability Policy for the members of the Board of Directors of PPC S.A.

The Company has a Suitability Policy for the members of the Board of Directors, which was drafted

according to the guidelines of the Hellenic Capital Market Commission (Circular no. 60 / 18-09-2020) and

includes:

a. the principles concerning the election or replacement of the Board members, as well as the renewal

of the term of office of the existing BoD members

b. the criteria for the evaluation of the individual and collective suitability of the BoD members

c. the criteria of diversity and adequate gender representation

d. the role of the Nomination, Remuneration and Recruitment Committee

e. the induction training program of the BoD members, and

f. the continuous monitoring and evaluation of the Board’s suitability

Any amendments to the Suitability Policy that are material (i.e., if they introduce derogations or

significantly change its content, in particular with regard to the general principles and criteria applied) are

submitted for final approval to the General Meeting. The amendments to the said Policy, especially when

they concern changes in the legal framework of Corporate Governance, are approved by the Board of

Directors upon the recommendation of the Chief Officer of the Legal Affairs and & Corporate Governance

Division and with the consent of the Nomination, Remuneration and Recruitment Committee. Simple

organisational changes are approved by the Chief Executive Officer.

The Suitability Policy of the Company was initially approved by the Board of Directors' decision no 46/13-

05-2021, in accordance with article 3 par. 1 of Law 4706/2020 and by the Extraordinary General Meeting

of Shareholders, pursuant to article 3 par. 3 of Law 4706/2020, on 4 June 2021. Two amendments to

the Suitability Policy followed, which were approved by the Company's Board of Directors' Decisions No.

132/26.10.21 & 10/23.02.22, respectively. The second amendment became effective by the resolution of

the Extraordinary General Meeting of the shareholders of the Company dated 17.03.22. Finally, the last

amendment to the Suitability Policy of the Company was approved by the Board of Directors' Decision

No. 45/10-05-2022.

The updated text of the Company's Suitability Policy is posted on the Company's website

(https://www.dei.gr/el/dei-omilos/i-dei/etairiki-diakivernisi/organosi-etaireias/dioikitiko-symvoulio-dei/)

Monitoring the implementation of the Suitability Policy of the Board of Directors

The BoD is responsible for monitoring the implementation of the Suitability Policy and its periodical

assessment, assisted by the Nomination Remuneration and Recruitment Committee, the Audit Committee

and the Legal Affairs and Corporate Governance Division, as well as by other organizational units of

similar scope, such as the Internal Audit Department and the Human Resources & Organisation

Department, as deemed appropriate.

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Training Policy for Board Members

The Company has a Training Policy for Board Members (BoD Decision No. 80/29-06-2021), through which

it adopts a structured and effective education system that meets the needs of the induction program of

the new members as well as those of the continuous training of the Board members.

Through said education system, the Company seeks to contribute to the development of the BoD

members, to ensure their suitability, and ultimately to the effective operation of the BoD and its

committees.

7. Evaluation of the Suitability and Effectiveness of the Board of Directors and its Committees

In 2022 the Board of Directors (BoD) by its Decision no. 45/10-05-2022 approved the Policy and

Procedure for the Evaluation of the Suitability and Effectiveness of the Board of Directors of PPC S.A.

and its Committees (the "Policy").

Based on the above Policy, the first internal evaluation of the individual and collective suitability and

effectiveness of the Board of Directors and its Committees was carried out in 2022, covering a period of

twenty-four (24) months prior to its commencement.

The evaluation of the effectiveness of the Board of Directors at the individual level was carried out using

self-assessment questionnaires.

In particular, the individual performance of each member was examined, taking into account his/her

capacity (executive, non-executive, independent non-executive) and specifically:

• the fulfilment of his/her duties, in accordance with the provisions of the Company's Articles of

Incorporation, the Company's Regulations and Policies and the applicable legislation,

• the degree of compliance with the policies and procedures of the Board of Directors and the Company

to the extent that they apply to each member,

• his/her contribution to the effective functioning and overall performance of the Board of Directors,

• the degree of consistency and participation in the BoD meetings,

• the participation in BoD committees and the assumption of specific responsibilities/projects,

• the use of knowledge and experience,

• the effectiveness in managing the matters he/she undertakes to deal with.

The evaluation of the Chairman of the Board of Directors was carried out through the use of questionnaires

completed by all Board members -except for the Chairman- and submitted anonymously to the Nomination

Remuneration and Recruitment Committee. Specifically, the evaluation of the Chairman focused on the

following criteria:

• Relationship management and degree of communication with the members of the Board and its

individual Committees,

• Communication with executives, shareholders and other stakeholders,

• Ability to coordinate collective discussions,

• Ensuring that the Board members are provided with correct and timely information prior to the holding

of Board meetings,

• Demonstrating leadership skills,

• Creating an environment of "confidentiality" for Board members to raise issues and concerns,

• Promoting constructive discussion/dialogue and effective decision-making process during Board

meetings.

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Since the capacities of Chairman and CEO of the Company coincide into the same person, the

assessment was made for both positions.

The individual suitability of Board members was assessed for all Board members, regardless of their

capacity, based on the following criteria:

1. Allocation of sufficient time

2. Adequacy of knowledge, skills and experience

3. Guarantees of good repute and morality; and

4. Independent judgement and absence of conflicts of interest

For the criteria 3 and 4, each member of the Board of Directors submitted, inter alia:

➢ Declaration by Board Members on own interests or conflicts of interest/duties

➢ Declaration under Article 3 par. 4 of Law 4706/2020 on the non-issuance of a final conviction for loss-

making transactions of the Company

➢ Declaration on the assessment of the reputation, integrity and honesty of the members of the Board

of Directors according to the questionnaire included in the Suitability Policy for the members of the

Board of Directors of the Company (Section V of the Annex “Suitability Policy”)

Based on the above, a summary table of the collective suitability/effectiveness of the Board of Directors

was completed, taking into account the individual self-assessments of the Board members, the

assessments of the collective suitability of the Board of Directors, as well as the evidence of individual

suitability, focusing mainly on the following issues:

a. Suitability of the Board for the exercise of its responsibilities,

b. Suitability of the composition of the Board of Directors for the management of the Company and

balanced decision-making,

c. Collective suitability of members to make decisions and monitor the operation of the Company

as a whole,

d. Board members' expertise in key areas of knowledge,

e. Level of managerial and administrative skills,

f. Understanding of the Board's areas of responsibility and possessing the necessary skills to

exercise management and oversight of the Company,

g. Implementation of the Company's Diversity Policy,

h. Ensuring that there is no exclusion, as regards the possibility of selection and election as a

member of the Board,

i. Meeting the criteria of adequate representation by gender,

j. Representation of a wider range of shareholders, who, either individually or in aggregate,

represent at least 10% of the Company's share capital.

On the basis of the above, the following conclusions were reached:

The composition of the Board of Directors was deemed adequate given the size of the Company, the

complexity of its activities and its business model. The Board of Directors of the Company is composed

of persons from different business sectors both in the domestic and international market, with high

professional qualifications, covering a wide age range, and combining dynamism and experience.

Furthermore, the composition of the Board of Directors meets the quota requirements of the Law regarding

the adequate representation of the underrepresented gender (25%). In any case, the Diversity Policy

adopted by the Company applies.

In 2020 the Board of Directors met twenty-one (21) times and in 2021 thirty (30) times and took 144 and

172 Decisions respectively, in their majority accompanied by written recommendations. The participation

rate of the Board members in the BoD meetings was high.

The participation of each of the Board members in the work of the Board of Directors during the last two

years was deemed significant both in in terms of carefully considering the issues submitted to it and in the

decision-making process

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In the Board of Directors there is a clear distinction between its executive function and its supervisory-

non-executive function. All members of the Board are fully aware of its structure and responsibilities.

The members of the Board of Directors are aware of the decision-making process and recognise the

importance of transparency in decision-making, as well as when corporate decisions are in line with the

corporate strategy and serve the corporate interest.

The members of the Board of Directors actively participate in the decision-making process, always with

the necessary independence in thought and judgement.

The role of the Chairman of the Board of Directors has had a catalytic effect on its smooth operation, as

he ensures the efficient flow of information received from the internal or external environment to the

members of the Board and its committees and convenes meetings at regular intervals in order to

discuss corporate issues. The Chairman of the Board creates an atmosphere of respect during meetings

and encourages and promotes open and critical discussion.

Taking into account the long-term perspective of the Company, a series of improvement proposals and

actions were presented aiming at further improving the flow of information in general to the Board of

Directors, the process of making recommendations, the recording of the proceedings of the Board of

Directors, the further involvement of the non-executive Board members in the effectiveness of the Internal

Control System, and the intensification of information and training actions for the members of the Boards

of Directors, with a view to maintaining and deepening the knowledge and skills necessary for the exercise

of their responsibilities.

Results of the Audit Committee’s Evaluation

With regard to the results of the Audit Committee’s evaluation, the Chair of the Audit Committee, Maria

Psyllaki, submitted to the Chairman of the Audit Committee, Pyrros Papadimitriou, a summary of the

Evaluation Report of the Audit Committee, the conclusions of which are summarized as follows:

The Audit Committee of PPC S.A. has been established in accordance with the Law and has

independence, which allows it to conduct constructive discussions and exchange views with the Board of

Directors, and generally operates within the framework set by its Rules of Operation and the Company’s

Articles of Incorporation. Due to the Company's size, activities and the issues raised, the meetings are

sufficient in number to address all issues that fall within the Committee’s remit.

In this context, the Audit Committee holds periodic meetings with the aim of monitoring the internal audit

systems, corporate governance and open corporate communication, in order to identify any important

issues with Management. Minutes are kept of all meetings of the Audit Committee, which include a

summary of the content of the discussions and the supporting material submitted. The minutes of the

Committee meetings shall be complete, prepared in a timely fashion and submitted, where required by

the applicable provisions, before the expiry of the legal deadlines of compulsory Law. Aiming at its

smoother operation, the Audit Committee proposed the improvement of the flow of information, given the

complexity of the issues it handles.

Results of the Evaluation of the Nomination, Remuneration and Recruitment Committee (NRRC)

The Independent Vice Chairman of the Board, Pyrros Papadimitriou, in his capacity as Chairman of the

NRRC, drafted the Report of the first internal evaluation of the NRRC in accordance with the above, the

conclusions of which are summarised below:

The NRRC consists of three (3) non-executive members of the Board of Directors, who are in their entirety,

and not in their majority, as stipulated by Law 4706/2020, independent of the Company, in the sense of

the provisions of Law 4706/2020.

126

Moreover, the NRRC has complementarity and a combination of qualifications among its members, and

each member has the necessary knowledge, skills and competencies to effectively fulfil their duties. It

meets at regular intervals and has 100% participation by its members to date. The Secretary of the NRRC

undertakes the organization of its meetings, attends meetings, edits the drafting and timely signing of the

minutes, and keeps complete records.

The materials NRRC members receive before meetings are adequate and ensure that they are properly

informed.

NRRC decisions comprise, as appropriate, recommendations or announcements or reports to the Board

of Directors. The Committee, through its Chairman, submits its decisions to the Chair of the Company’s

Board of Directors for inclusion in Board meetings and for the necessary executive decisions to be taken.

In accordance with the above, the composition of the NRRC was deemed adequate and its method of

operation effective, and as such no issue was raised for drawing up an action plan for improvement actions

in the near future.

8. External professional obligations of the Board of Directors members.

The external professional obligations of the BoD members are provided in the table below:

Board Member

Profession

Participation as member of the BoD of other

companies and non-profit Organizations (in any

capacity e.g. Independent member, Executive

member, Independent Non-Executive member, etc.)

Giorgos Stassis

Civil Engineer

Member of the Board of Directors of the following

companies:

PPC Renewables Single Member S.A.

Arkadian Sun Ena S.A.

Arkadian Sun Dio S.A.

Solar Arrow Ena S.A.

Amalthia Energiaki S.A.

SOLARLAB S.A.

Solar parks Western Makedonia Ena S.A.

Solar parks Western Makedonia Dio S.A.

Geothermikos Stochos S.A.

Geothermikos Stochos Dio sole shareholder S.A.

EEN VOIOTIA S.A.

PPC RENEWABLES- EDF EN GREECE

PPC RENEWABLES- - TERNA ENERGY S.A.

PPC RENEWABLES - ROKAS S.A.

GITANI S.A.

127

VORINO PELLIS S.A.

MYHS SMIXIOTIKOU S.A.

OROS ENERGY S.A.

GREENESCO ENERGIAKI S.A.

SOLAR PARK KILIZA S.A.

SOLAR PARK AG. ONOUFRIOS S.A.

SOLAR PARK MPAMPO VIGLIES S.A.

SOLAR PARK LOUKO S.A.

SOLAR PARK LEYKIVARI S.A.

VOLTERRA LYKOVOUNI S.A.

VOLTERRA K-R S.A.

Eurelectric – the European Union of the Electricity

Industry

Board Member at the HELLENIC AMERICAN

CHAMBER OF COMMERCE

Pyrros Papadimitriou

Attorney-at-law, Economist,

Professor at University of

Peloponnese

KMOP Policy Center ASBL (Co-director of a non-profit

research center in Belgium)

George Karakousis

Engineer

Alexander Paterakis

IT Consultant

Strategic consultant, Lumia Capital 2014

Management

Non-Executive Member of PPC RENEWABLES

Non-Executive Member of HEDNO S.A.

Grigorios Dimitriadis

Engineer

CEO AND MEMBER OF THE BOARD OF

GROWTHFUND

Board Member OF THE HELLENIC CORPORATE

GOVERNANCE COUNCIL (HCGC)

Alex Fotakidis

Economist

Member of the Board of Directors of the following

companies:

ETHNIKI SA

SKROUTZ INTERNET SERVICES S.A.

VENETIKO HOLDINGS S.àr.l.

128

SAIGA S.àr.l.

ETHNIKI HOLDINGS S.àr.l.

HELLENIC HEALTHCARE S.àr.l.

Chairman of the BoD of the companies:

BARBA STATHIS S.A.

ELLINIKI ZYMI

VENETIKO HOLDINGS S.A.

CVC ADVISERS GREECE S.A.

Maria Psyllaki

Economist, Professor at the

Department of Economics

of the University of Piraeus

Member of the BoD of the Hellenic Exchanges

Shareholders Association -(CoEx), Non-profit

Association

Despoina Doxaki

Attorney-at-law, Head of

Legal Service at the

Financial Stability Fund

Stefanos

Kardamakis

Mechanical Engineer

Director of the CONBLUK

SHIP MANAGEMENT

CORPORATION

Stefanos

Theodoridis

Senior Executive Officer

BYZADIUM S.M.S.A., Managing Director

PANORAMA SA, Chairman

NAVARINO BELLA VISTA, Vice-Chairman

TEMES S.A., Managing Director

COSTA NAVARINO NORTH PROPERTIES, Chairman

& Managing Director

COSTA NAVARINO SOUTH PROPERTIES, Chairman

& Managing Director

IONIAN HOTEL ENTERPRISES S.A., BoD Member

DUNES GOLF S.A., Vice-chairman

PREZIOSI GROUP, Vice-Chairman

VINEYARDS S.A., Chairman

GREKA ICONS S.A., Chairman

PHILOMEL PROPERTIES S.A., Chairman & Managing

Director

AZOV S.A., Chairman & Managing Director

129

ARMIDE PROPERTIES S.A., Chairman & Managing

Director

ATHENS BEACH CLUB S.A., BoD Member

ELECION ENERGY S.A., Chairman

PILEAS S.A., Chairman

TVIC S.A., Chairman

ALAS TOURISTIKI Ι.Κ.Ε., Administrator

STADIO 2020, Non-Executive Chairman

130

9. Number of shares held by the Board members (article 18, par. 3 Law 4706/2020)

Member

BoD Position

Number of Shares owned as of

31.12.2022

Giorgos Stassis

BoD Chairman & CEO,

Executive Member

Pyrros Papadimitriou

Vice Chairman of the BoD

Independent, Non-

Executive Member

George Karakousis

Deputy CEO Executive

Member

Alexander Paterakis

Deputy CEO Executive

Member

Grigorios Dimitriadis

Non-Executive Member

Alexandros Fotakidis

Non-Executive Member

Maria Psyllaki

Independent, Non-

Executive Member

Despoina Doxaki

Independent, Non-

Executive Member

Stefanos Kardamakis

Independent, Non-

Executive Member

Stefanos Theodoridis

Independent, Non-

Executive Member

6,656

Michail Panagiotakis

(1)

Independent, Non-

Executive Member

Pantelis Karaleftheris

(2)

Non-Executive Member/

Representative of

Employees

Nikolaos Fotopoulos

(2)

Non-Executive Member/

Representative of

Employees

Notes

(1) The term of office of Mr. Michail Panagiotakis expired on 21 August 2022

(2) The term of office of Board Members – Employee Representatives, Pantelis

Karaleftheris and Nikolaos Fotopoulos expired on 29-06-2022.

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The number of Company’s shares held by the members of the Audit Committee, non-members of the

Board of Directors (third parties)

Member

BoD Position

Number of Shares

owned at

31.12.2022

Evangelos Angeletopoulos

Audit Committee member -

Non-BoD member (third

party)

Aimilios Stasinakis

(1)

Audit Committee member -

Non-BoD member (third

party)

Konstantinos Cholevas

Audit Committee member -

Non-BoD member (third

party)

Christos-Stergios Glavanis

Audit Committee member -

Non-BoD member (third

party)

Note

(1) Following the resignation for personal and professional reasons submitted by the member of the

Audit Committee, Mr. Aimilios Stasinakis, with effect from 30 April 2022, on 5 May 2022, the

Extraordinary General Meeting of the Company's Shareholders elected as its member, the Board

of Directors’ recommendation, Konstantinos Cholevas, replacing the resigned member and for

the remainder of his term of office.

The number of Company shares that Executive members and Directors held are provided later on in the

appendices of this Statement.

10. Remuneration Policy for the Board of Directors

The Company has established and implements a Remuneration Policy for members of its Board of

Directors and Committees (hereinafter “Remuneration Policy”). The Company’s current

Remuneration Policy was approved by decision of the Extraordinary General Meeting of

Shareholders on 14.12.2022 and is effective for four (4) years from the date of its approval, unless

revised and/or amended earlier by virtue of another decision of the General Meeting due to a

material change in the conditions on the basis of which it was prepared.

This Remuneration Policy of the Company supplements the Remuneration Policy as adopted

pursuant to the Decisions of the Company’s General Meeting of Shareholders of 4.6.2021 and takes

into account the relevant best practices for listed companies, Law 4548/2018 on the reform of the

law on public limited companies, Law 4706/2020 on Corporate Governance, the provisions of the

Company’s Articles of Incorporation and the Corporate Governance Code that the Company has

chosen to follow.

The Remuneration Policy for the BoD's members and its Committees has as its purpose to

contribute to the implementation of the Company's business strategy, to serve its long-term

interests, as well as to contribute to its sustainability by establishing a remuneration framework for

Executives that a) favours their alignment with short-term and long-term corporate targets, b)

supports team spirit and performance, c) recognizes their efforts and the level of their contribution

to its results, so that the Company continues to create added value for its customers, shareholders,

employees and the Greek economy.

132

The forms of remuneration and benefits that may be paid pursuant to the Remuneration Policy

approved by the General Meeting to the Non-Executive Members of the Company’s Board of

Directors are summarised below:

⎯

The gross sum of 600 euros per BoD meeting

⎯

Additional benefit: For travel expenses incurred by the Members of the Board of Directors

outside the Regional Unit of the place of their permanent residence in order to attend the

meetings of the Board of Directors or its Committees, travel, accommodation and meal

expenses shall be paid, according to the applicable provisions of the Company.

For any non-executive members from the Company’s regular staff,

⎯

The fixed remuneration paid for their position,

⎯

The additional benefits of regular personnel.

In addition, members of the Committees of the Board of Directors of the Company are paid

(a) the gross amount of 13,000 euros to the Chairman of the Committee, and 11,000 euros to the

members per year, and (b) the gross amount of 400 euros per Committee meeting.

The overall amount of the above compensations for participation in BoD Committees shall not

exceed, for the Chairman and each Member of the Committee, the gross amount of 23,000 euros

per year.

The forms of remuneration and benefits that may be paid under this Policy to the Executive

Members of the Company’s BoD are summarised below:

⎯ Fixed remuneration: The fixed remuneration amount is delimited in this Policy, is precisely

determined by the BoD and is included in the annual remuneration report which is

submitted to the General Meeting. The BoD reviews the base salaries of its executive

members and decides whether conditions justify adjustments, on the recommendation of

the Nominations, Remuneration and Recruitment Committee. When considering base

salary raises, the criteria used are inflation, market wage levels, the need to retain talent,

individual performance, and average increases in salary among the Company’s general

personnel. The amount of annual gross remuneration is determined through the PPC’s

Fixed Executive Remuneration Scheme (FERS)

⎯ Variable annual earnings (bonus): This amount is determined through the Variable

Executive Remuneration Scheme (VERS) of PPC

⎯ Reward Incentive: For the 2020-2025 period, an additional incentive shall be provided to

reward the executives of PPC and PPC Renewables for their contribution to the

achievement of the mid-term objectives of the Group, in the form of four (4) cycles of Stock

Awards, according to Annex III “Stock Awards Plan” of the Remuneration Policy. The Board

of Directors shall be authorized to determine any details of implementation of this Plan, as

well as the respective activation condition of each cycle of the Plan, in accordance with its

provisions.

133

⎯

Provision of a company car and coverage of the respective expenses.

⎯

Private medical and life insurance plans with parallel third-party insurance coverage for

any acts and/or omissions that may be attributed to them during the exercise of their duties.

⎯

Additional benefit: For travel expenses incurred by the Members of the Board of Directors

outside the Regional Unit of the place of their permanent residence in order to attend the

meetings of the Board of Directors or its Committees, travel, accommodation and meal

expenses shall be paid, according to the applicable provisions of the Company.

⎯

BoD participation remuneration gross amount 600 euros per BoD meeting

Additionally, the Executive members of the Company’s BoD Committees are paid

(a) gross amount of 13,000 euros for the Chairman of the Committee and 11,000 euros for the

members annually, and

(b) gross amount per Committee meeting of 400 euros.

The overall amount of the above compensations for participation in BoD Committees shall not

exceed, for the Chairman and each Member of the Committee, the gross amount of 23,000 euros

per year.

PPC’s current Renumeration Policy is available on the Company’s official website

https://www.dei.gr/el/dei-omilos/i-dei/etairiki-diakivernisi/kodikes-kanonismoi-kai-politikes/

The total of the remuneration granted to the BoD members during fiscal year 2022 is included in the

respective Remuneration Report, which will be posted in the Company’s website when the required

approvals are received.

The full content of the Remuneration Report of the Board of Directors for financial year 2022, in

accordance with the provisions of article 112 of Law 4548/2018, and the Remuneration Policy will be

submitted for approval to the Shareholders General Meeting in 2023, for the approval of the financial

results of fiscal year 2022.

11. Disclosure of direct and indirect conflicts of interest

The Company implements a Conflict of Interest Policy. Through this Policy, the Company seeks to provide

support, information and guidance to all staff (Senior Management and employees) on the principles and

rules for the prevention or management of conflict-of-interest situations and how to apply these principles

and rules. PPC implements appropriate mechanisms and procedures for the timely identification of

conflicts, both prior to the taking up of duties by its executives and during the performance of their duties.

In accordance with the above Policy, all members of the BoD of the Company and any third person to

whom duties have been assigned by them must, through the Company Secretary, notify, in a timely,

adequate and written manner, the other members of the BoD of the direct or indirect conflict of interest of

which they are aware of and which has arisen from the Company's transactions and/or during the

performance of their duties.

Where the BoD is informed of the existence of direct or indirect conflict of interest or decides, following

relevant notification by the involved/interested member of the BoD, that such a conflict exists, the

interested party/BoD member involved in the relevant transaction is not entitled to vote on those matters

in which there is direct or indirect conflict of interest ("abstention rule"). In these cases, decisions are made

by the other members of the BoD.

134

At each meeting of the BoD (and the Committees of the BoD), and before the start of the discussion of

the items on the agenda, the Company Secretary reminds the participating members of the BoD of the

relevant "abstention rule".

The Secretary of the BoD prepares a register of conflicts of interest reported by the members of the BoD,

which is constantly updated. The information contained in this register is sufficiently detailed to allow

proper understanding of any conflict of interest situation and shall be made available to the Audit

Committee and the Legal Affairs and Corporate Governance Division upon request.

Throughout fiscal year 2022 the "abstention rule" was applied in four meetings of the Board of Directors,

where the members in question of the Board of Directors did not vote on four items of the agenda. More

specifically, on 31.3.2022 (1) one Executive Member of the BoD abstained; on 28.6.2022 (1) one

Executive Member of the BoD abstained; on 4.10.2022 (1) one Executive Member of the BoD abstained,

and on 19.12.2022 when all three (3) Executive Members of the BoD abstained.

12. Determination of the independence of the independent non-executive members of the Board.

The Nomination, Remuneration and Recruitment Committee, in compliance with par. 3 of article 9 of L.

4706/2020, confirmed the fulfilment of the independence conditions, within the meaning of par. 1 and 2 of

article 9, of the six (6) independent members of the Board of Directors. (Appendix on BoD Member

Suitability Policy, Section XII).

13. Communication with shareholders and other stakeholders

The Company places great emphasis on communication and cooperation with stakeholders. Stakeholder

groups have been defined as the result of internal management consultations, discussions and working

meetings of the Company's Top Management with Executives. However, the prioritization of stakeholders

and their priorities is a dynamic process, and for this reason, the map of stakeholders is regularly reviewed

by the Board of Directors.

The aim of the Company’s Board of Directors is to create the conditions for an ongoing interactive dialogue

with stakeholders, in order to understand the effects of the Company’s activity and improve its

performance, taking into account the opinions, concerns, needs and suggestions of all stakeholders, that

it affects and is affected by, in its decision making and the development of its strategy.

In this context, the Company has developed communication mechanisms with the shareholders and other

stakeholders in order to understand their interests, so as to take them into account in BoD discussions

and decision-making.

In particular:

Communication with the shareholders and the investor community

The PPC, by adopting corporate governance best practices for the General Meetings, has the capability

to remotely conducting all the General Meetings of shareholders via teleconference, enabling each

shareholder (natural person or institutional investor) to participate, express their views and vote.

Furthermore, PPC shareholders may also submit proposals for the election of new members of the Board

of Directors. In accordance with the Company's Suitability Policy, the proposals above accompanied by

the necessary information which will allow the evaluation of the suitability of the nominated persons, as

specified within the aforementioned Policy, are submitted to the Nomination, Remuneration and

Recruitment Committee at least seven (7) days prior to the General Meeting that will decide the

appointment of the members, in order to ensure that the evaluation of the nominated persons’ suitability

is as exhaustive as possible.

135

The Chairman and CEO, the CFO and the Investment Relations Division are in ongoing communication

with institutional investors through:

• Τeleconferencing that takes place to comment on the financial results.

• participation in roadshows, both in Greece and abroad,

• one-on-one meetings with institutional investors.

• presentations of the strategy of PPC and the Group in general (Investor Days)

At the same time, the Investment Relations Division is in constant communication with shareholders,

financial analysts and the investment community in general, providing information (based on publicly

available information) on the progress of PPC’s quantitative and financial figures, current business

developments, while communicating the positions, strategy and vision of Management.

Constructive dialogue with other stakeholders

➢ The Company conducts a materiality analysis every two years in order to prioritize the material

issues for the Company and the stakeholders. The results of the materiality analysis are

discussed by the Board of Directors and are taken into account in the risk assessment process

and in decision making. The stakeholder groups, which have been defined via internal

consultations, discussions and working meetings of the Top Management of each Company with

executives, are the following: Employees, High Voltage Customers, Medium Voltage Customers,

Low Voltage Customers, Organizations, Regulatory Authorities, Sustainable Development

Agencies, Investment Community, Financial Institutions, Non-Governmental Organizations and

Local Communities, Media, State - Public Agencies- Local Government Organizations, Business

Communities (Greek and International), Partners and Suppliers, other companies in the same

industry, Academic Community and Research Centers.

➢ The Company publishes the material issues that emerge from the stakeholders’ questionnaires

and the actions taken during the fiscal year to address them. The most recent materiality analysis

was carried out in Q3 of 2021.

➢ In 2022, on the initiative of the Company’s Sustainable Development Division, a survey was

carried out concerning PPC S.A. and the major subsidiaries HEDNO S.A. and PPC Renewables

Single Member S.A., to form the list of identified Sustainable Development issues. The purpose

of the survey was to collect information that will contribute to the preparation and compilation of

the list of identified Sustainable Development issues that will be examined in 2023, based on the

new data for the Group and the broader international developments that have emerged since

August 2021, in the context of the new materiality analysis that will be carried out using the

double materiality approach, during the first half of 2023. The survey was carried out in the form

of focus groups and questionnaires that were provided to top and senior management

executives. The results of the survey showed useful qualitative data that will contribute to better

understanding and handling of sustainable development/ESG issues by the management of the

three Group companies.

➢ PPC Group, faithful to its commitment to providing transparent, reliable, and comparable

information for stakeholders on the impact its activity has on the ecosystem, published its

Sustainability Report for 2021 in December 2022. This report sets out in detail the performance

of PPC SA and its major subsidiaries on Sustainable Development issues, based on the ESG

criteria, and presents actions that contribute to the achievement of the UN’s seventeen (17)

Sustainable Development Goals.

➢ Company employees are systematically informed about the developments in the Company.

➢ Finally, in 2022, on the initiative of the Human Resources Division, the ‘Great Place to Work’

employee satisfaction survey was carried out, with the main evaluation factors being credibility,

respect, pride, fairness and collegiality, the results of which will be used appropriately so that the

Company can focus its efforts on the areas where they will have the greatest added value with

the aim of creating an exceptional work environment that ensures optimum and smooth

operation.

136

B. Audit Committee

1. Composition and functioning - term of office of members

The Audit Committee of PPC SA operates within the framework of the provisions of Article 10 of Law

4706/2020 “on corporate governance” and having regard to Article 9 of Law 4643/2019, and in accordance

with the provisions of secondary legislation, such as the relevant circulars and decisions of the Hellenic

Capital Market Commission), as in force from time to time (indicatively the circulars/letters

1302/28.04.2017, 1508/17.7.2020, 427/21-02-2022) of the Directorate of Listed Companies of the

Hellenic Capital Market Commission.

Its purpose is to assist the Board of Directors in fulfilling its duties and responsibilities to shareholders, the

investment community and third parties, and particularly ensuring the integrity, objectivity, adequacy, and

efficiency of the following:

• the financial reporting procedures and in particular the financial reporting process and the

process of the statutory audit of the individual and consolidated financial statements by

independent auditors – accountants,

• the corporate governance, risk management, quality assurance and internal control systems,

• the Internal Audit Department, which it oversees and

• the Company’s Procurement function for works, supplies, and services.

The current Audit Committee of PPC S.A., further to the decisions of the Extraordinary General Meeting

of shareholders on 14.12.2022, constitutes an independent ‘mixed’ committee consisting of three (3)

Independent Non-Executive Members of the Board of Directors and three (3) third persons (non-Members

of the Board of Directors) in accordance with article 44, paragraph 1, case a, sub-case (ab) of Law

4449/2017, as in force.

Specifically, the members of the Audit Committee have been appointed by the General Meeting of the

Shareholders as follows: Four (4) members, pursuant to Article 44 of Law 4449/2017, as in force,

independently of the Company within the meaning of the provisions of Law 4706/2020, and two (2)

members, in accordance with Article 9 of Law 4643/2019, chosen from a list of persons with proven

experience in the sector of works, supplies and services contracts, who are independent of the Company,

in the sense of the provisions of Law 4706/2020.

The members of the Company’s existing Audit Committee were elected as follows:

the Extraordinary General Meeting of the Company’s shareholders on 14.12.2022 elected the additional

sixth (6th) member of the Audit Committee, Christos-Stergios Glavanis, for a three-year term of office.

Following the authorisation given by the Ordinary General Meeting of the Company's shareholders on

29.6.2022, by its Decision No. 79/5-7-2022, the Board of Directors appointed as its members, the

Independent Non-Executive Members of the Audit Committee, Despina Doxaki, Stefanos Kardamakis and

Maria Psyllaki, with a three-year term coinciding with their term on the Board of Directors, who are elected

pursuant to Article 44 of Law 4449/2017, as in force.

Evangelos Angeletopoulos, elected by the Extraordinary General Meeting of 8 May 2020, with a three-

year term in office, namely from 8 May 2020 to 7 May 2023, and Konstantinos Cholevas, elected by the

Extraordinary General Meeting of 5 May 2022, serving out the term of the resigned member, had been

elected as non-members of the Board of Directors in accordance with article 9 of Law 4643/2019.

Subsequently, during its meeting of 21 December 2022, the Audit Committee elected Ms. Maria Psyllaki,

Independent Non-Executive Member of the Company’s Board of Directors, as Chairperson thereof, in

accordance with the provisions of Article 44 par. 1 of Law 4449/2017, as in force.

137

According to the above:

Maria Psyllaki

Independent Non-

Executive Member of

the BoD

Chairperson of the

Audit Committee

With a three-year term of

office, i.e., from

17.12.2021 until

16.12.2024

Despoina Doxaki

Independent Non-

Executive Member of

the BoD

Member

With a three-year term of

office, i.e., from 29.6.2022

until 28.6.2025.

Stefanos Kardamakis

Independent Non-

Executive Member of

the BoD

Member

With a three-year term of

office, i.e., from 22.8.2022

until 21.8.2025

Christos-Stergios

Glavanis

Non-BoD member

Member

With a three-year term of

office, i.e., from 14.2.2022

until 13.12.2025

Evangelos

Angeletopoulos

Non-BoD member

Member

With a three-year term of

office, i.e., from 8.5.2020

until 7.5.2023

Konstantinos Cholevas

Non-BoD member

Member

To replace a member who

resigned, and for the

remainder of the three-

year term of such

member, i.e. from

5.5.2022 to 7.5. 2023

2. Curriculum Vitae of the existing Audit Committee members

For reasons of completeness the curriculum vitae of the Audit Committee members are listed below:

The curriculum vitae of Ms. Maria Psyllaki, Ms. Despina Doxaki and Mr. Stefanos Kardamakis, are

presented in detail in Section VI.4 of this Statement. The curriculum vitae of non-members of the Board

who are members of the Audit Committee are listed below:

Evangelos Angeletopoulos, Non-Member of the Board, Member of the Committee

Mr. Evangelos Angeletopoulos is a C-Level Executive with forty (40) years of extensive involvement and

experience in many fields of management and operations as an executive, researcher, business

consultant, professor, mentor and analyst/writer. He has managed a number of special projects with a

high degree of difficulty and complexity, covering a wide range of business activities and requirements in

companies and organisations, heavy industry, commerce, FMCGs, and provision of services, in both the

public and private sectors.

Christos-Stergios Glavanis, Non-Member of the Board, Member of the Committee

Mr. Christos Glavanis, Certified Public Accountant, has more than 35 years of experience in the audit

profession. He has served for more than 30 years as a senior executive of the EY audit firm, both in

Greece and in the region of Central and Southwest Europe. He serves as Chairman of the Audit

Committee of Attica Bank and has served as Chairman of the Audit Committee of the Hellenic Financial

Stability Fund (HFSF). He holds a degree in economics from the University of Hull and is a Member of the

Institute of Chartered Accountants of England & Wales as well as the Institute of Certified Public

Accountants of Greece.

138

Konstantinos Cholevas, Non-Member of the Board, Member of the Committee

Mr. Konstantinos Cholevas has served as a senior executive for 23 consecutive years at leading

multinational companies (LafargeHolcim, Lafarge, SAP, CoCa Cola 3E, Rank Xerox) and in key positions

with recognised and tangible results in the sectors of Business Administration, Development of New

Business Activities, Marketing, Exports & International Energy & Fuel, Supply Chain, IT, Corporate

Transformation, Optimization of Procedures/Systems and Best Business Practices, Management and

Organisation of complex projects. He developed and managed two new international activities in the

Energy sector and managed large-scale and complex industrial operations and business projects with

complex and international teams of employees and associates, exceeding business objectives. Mr.

Cholevas is the recipient of several professional awards, most recently the 2019 Professional of the Year

by the European Logistics Association.

In addition, the conditions of independence, as defined by the current regulatory framework and in

particular by par. 1 and 2 of article 9 of L. 4706/2020, are met by all the members of the Audit Committee.

3. Responsibilities of the Audit Committee

According to the requirements of article 44 of Law 4449/2017, as in force, the Audit Committee shall be

responsible for the following:

• Monitoring the external audit process and informing the BoD about its result.

• Monitoring, reviewing and evaluating the corporate governance, quality assurance and internal

control systems.

• Overseeing the selection of chartered auditors - accountants or audit firms and reviewing their

independence.

• Monitoring, reviewing and evaluating the corporate governance, quality assurance and internal

audit systems.

• Monitoring, reviewing and evaluating the procurement function for works, supplies and services.

The purpose, competencies and functioning of the Audit Committee are described in detail in its Rules of

Procedure, which are posted on the Company's website (https://www.dei.gr/el/dei-omilos/i-dei/etairiki-

diakivernisi/organosi-etaireias/epitropes-ds/).

4. Frequency of Audit Committee Meetings and participation of members

In 2022, the Audit Committee met twenty-three (23) times. The number of participations of each member

in the meetings of the Audit Committee is presented in the table below:

Member

Position in Committee

Number of Meetings

attended by members of the

BoD / Total Number of

Meetings held

Maria Psyllaki

Chair of the Audit

Committee

23/23

Despoina Doxaki

Member

22/23

Stefanos Kardamakis

Member

17/23

Christos-Stergios Glavanis

(1)

Member

1/1

Evangelos Angeletopoulos

Member

23/23

Konstantinos Cholevas

(2)

Member

13/13

Aimilios Stasinakis

(2)

Member

10/10

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*Notes:

(1) From 14 December 2022, the date of election of Mr. Christos-Stergios Glavanis by the Company’s Extraordinary

General Meeting of Shareholders, until 31 December 2022, one (1) meeting of the Audit Committee was held with the

participation of Mr. Glavanis.

(2) Mr. Aimilios Stasinakis, during the period from 01-01-2022 to 05-05-2022, participated in all 10 meetings of the

Audit Committee. Mr. Konstantinos Holevas, who was elected by the General Meeting of Shareholders on 5 May 2022

to replace resigning member Aimilios Stasinakis, participated in all the meetings that took place during the period (13

meetings)

5. Proceedings of the Audit Committee for the fiscal year 2022

During the meetings of the Audit Committee in the fiscal year 2022, all the issues provided in the

Company's Rules of Operation and in the Rules of Procedure of the Internal Audit Unit were discussed

and addressed. The main ones are summarized below:

A. External Audit / Financial Reporting Procedure

• Re-evaluation of the independence of the audit company that carries out the statutory audit of

the Company’s individual and consolidated financial statements and the absence of a conflict of

interest in view of the renewal for another year of the conduct of the statutory audit for 2022,

given that the Company’s Ordinary General Meeting of Shareholders on 24-6-2020 had

approved the assignment of the statutory audit for FY20, FY21 and FY22.

• Ensuring the independence and objectivity of the Certified Public Accountants throughout FY22,

in accordance with the relevant provisions of Law 4449/2017 and Article 5 of Regulation (EU)

537/2014.

• Monitoring the process of financial reporting and the course of the compulsory audit of the

Company’s individual and consolidated financial statements for the fiscal year 2021.

• Monitoring the process of financial reporting and the course of the compulsory audit of the

Company’s individual and consolidated financial statements for the first half of 2022.

• Monitoring the process of the Company’s internally prepared individual and consolidated

financial statements for the first quarter and the nine months of the fiscal year 2022.

• Update on the amount of letters of guarantee that were issued and remained in force for the first

and second half of 2020.

• It is underlined that for FY22, the Audit Committee held five (5) meetings with the external

auditors, supervising the process of the relevant audit of the financial statements.

B. Internal Control System

I. Risk Management Division

During 2022, the Audit Committee was briefed by the Director of Risk Management Division on the RMD

activities and risk management in the Company. In particular:

• the key principles of the planning and operation to date of the Corporate Risk Management

Framework were presented and the Committee was informed about the project of identifying and

quantifying the main corporate risks, which was carried out with the assistance of an external

consultant.

• the methodology followed and the results of the project for identifying and quantifying corporate

risks were presented, and the Committee was briefed on the classification (risk register) of

Company Risks.

• the Committee, along with the external advisor that helped the RMD in the exercise, analysed

the most important risks recognised by the exercise for the identification and quantification of the

main corporate risks and the controls for their management.

140

II. Compliance Division (CD)

The Audit Committee was briefed by the Compliance Director and the Energy Transaction Compliance

Director on the action plan and the objectives they implemented during 2022.

The Compliance Division’s work, as presented to the EU, specifically included:

• Completion of the ‘Ethics and Compliance program’, with the main milestones being the revision

and approval of the Code of Conduct, preparation and approval of the Policy against Corruption

and Bribery, the Policy against Violence and Harassment at Work, in implementation of Law

4808/2021, the Sanctions Policy and the Whistleblowing Policy.

• DUE Diligence Third Parties (1st phase - Planning). Prepared a plan with the prerequisites for

the thorough inspection of Suppliers and Partners.

• Implementation of action for updating and correct implementation of Policies in Business

Operation.

• Cooperation with external agencies and professional associations

• Organizational Changes (implementation of a new Organizational Chart of the Compliance

Directorate).

• Continuous training of compliance officers (Webinars SEKASE, HCAP, Dpo Network).

• Recording of the main, specific regulatory obligations of the Energy Management & Trading

Business Unit with regard to the energy exchange.

• Preparation of guidelines for preventing market manipulation and insider dealing.

• Implementation of the corporate policy against money laundering actions in the context of the

transactions of the Energy Management & Trading Department operations.

ΙΙΙ. Energy Transaction Compliance Division (DSYMES)

The Energy Transaction Compliance Division’s work, as presented to the Audit Committee, specifically

included:

• Holding of a training seminar aimed at familiarising the competent officers of the Energy

Management & Trading Department with the current legislative and regulatory framework for

money laundering and terrorist financing operations.

• Drawing up of implementation guidelines for the Energy Management & Trading Department,

with the aim of facilitating and effectively implementing the Policy.

• Conclusion of a contract by the Energy Management & Trading Department with business

information services provider Dun & Bradstreet (ICAP representative) to derive assessment data

in relation to compliance with the Anti-Money Laundering and Terrorist Financing Framework.

IV. Internal Audit Department (IAD)

Regarding the scheduling of the IAD audit activity, the Audit Committee received and evaluated the annual

Programme and the resource requirements for its completion. The annual audit programme of the IAD

was prepared based on the relevant legislative framework with regard to the IAD’s obligations, as well as

based on risk assessment. More specifically, it includes audits concerning:

• the implementation of the Rules of Operation and the Internal Audit System, especially with

regard to the adequacy and correctness of the financial reporting, regulatory compliance and the

corporate governance code followed by the Company;

• the quality assurance mechanisms

• the corporate governance mechanisms

• compliance with the commitments contained in prospectuses and the Company’s business

plans;

• the Company’s procurement system, and more specifically the implementation of the Regulation

of Works, Supplies and Services.

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The Audit Committee recommended to the BoD the annual audit programme and the enforcement of the

IAD with the necessary audit resources. It also assessed and recommended to the BoD, together with the

IAD, the required changes to the annual audit programme during the year.

With regard to monitoring the audit work and the results of the internal audit, the Audit Committee took

note of the detailed reports to the audited units. In addition, it monitored the work of the IAD through

quarterly reports and was briefed in detail on the most important issues of the audits and the results of

the response of the audited units to the IAD’s improvement proposals. Based on the above, the Audit

Committee recommended that the quarterly reports be submitted to the BoD jointly with the IAD.

In 2022, the Internal Audit Director was evaluated for 2021, in accordance with the evaluation procedures

for personnel kept by Human Resources.

The Audit Committee monitored its independence and sufficient access to business units and information

on the exercise of its duties throughout the year.

.C. Operation of the Company's Procurement function for works, supplies and services

The Audit Committee, in implementation of the provisions of the existing legal and regulatory framework

that governs the Operation of the Company’s Procurement function during year 2022:

• Carried out Random Checks to monitor the correct application of the Regulatory Framework

applicable to the Company (Procurement Manual, Regulation of Works, Supplies and Services,

etc.)

• Monitored the Performance of the Procurement function, based on indicators (Key Performance

Indicators - KPIs)

• Submitted proposals for improving the Company’s Procurement function.

D. Sustainable Development Policy

In the context of drawing up and implementing the Group’s Sustainable Development strategy, which is

based on the philosophy of creating shared value between the company, society and the environment,

the Sustainable Development Policy was presented to the Audit Committee and was revised (BoD

decision No. 88/12.7.2022) with the aim of gradually aligning the business model with it, in the framework

of the transformation of PPC and the Group as a whole.

Within 2022, a number of actions and initiatives were undertaken and coordinated by the Sustainable

Development Directorate and supervised by the Sustainability Committee, in collaboration with other units

of the Company and the Group’s major subsidiaries (HEDNO and PPC Renewable) that relate to

monitoring and strengthening of the corporate transition taking place in terms of sustainable development

and based on the ESG criteria, such as:

• PPC Group’s inclusion to the international “Science Based Targets initiative” (SBTi)

• The response to the international initiative of the “Task Force on Climate Related Financial

Disclosures” (ΤCFD)

• The Group’s commitment to the ten general principles of the UN Global Compact

• Response to the CDP Climate Change Global Initiative

• The Company’s participation as a signatory (one of 330 companies worldwide) to the Business

For Nature campaign “Make it Mandatory”

• The Group’s participation in the “Women’s Empowerment Principles” initiative, etc.

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6. Audit Committee Evaluation

In accordance with the Rules of Procedure of the Audit Committee, the Committee is periodically

evaluated in terms of its performance under the supervision of its Chairman, who is responsible for the

implementation of the evaluation process.

The first internal evaluation of the Audit Committee was carried out in fiscal year 2022 in the context of

the evaluation of the BoD and its Committees, which was based on the new Policy and Procedure for

Evaluation of the Suitability and Effectiveness of the BoD and its committees. Extensive reference to the

results of the Audit Committee’s assessment is provided in paragraph 7 “Evaluation of Suitability and

Effectiveness of the Board of Directors and its Committees” of Section VI. Composition and Functioning

of the Governing Bodies of this Statement

C. Nominations, Remuneration & Recruitment Committee

1. Composition and operation of the Committee – members’ term of office

The Company has established a Nominations, Remuneration & Recruitment Committee, in accordance

with articles 10, 11 and 12 of L. 4706/2020, and the Articles of Incorporation of the Company, which is

established with a Board of Directors decision. The purpose of NRRC is to support the BoD on issues: a)

examination of existing and BoD member candidates according to the Company’s Suitability Policy, b)

recruitment, c) remuneration policy and d) remuneration and incentives of the Company’s executives.

The existing Nominations, Remuneration & Recruitment Committee (NRRC) of PPC SA (hereinafter, “the

Committee”) consists of three (3) non-executive members of the Board of Directors, who are independent

of the Company within the meaning of the provisions of Law 4706/2020.

Specifically, the Company’s Board of Directors, which was elected by the Ordinary General Meeting of

the Shareholders on 29 June 2022 and which was formed into Body during the meeting on 05 July 2022,

decided, through decision 80/05-07-2022, according to the Law, the Articles of Incorporation and the

Rules of Operation of NRRC, the appointment as members, with a three-year term coinciding with his

corresponding term as Members of the Board, of Independent Non-Executive Members of the Board,

Pyrros Papadimitriou, Despina Doxaki and Stefanos Theodoridis, and their respective positions. In its

Decision No. 98/23-08-2022, the Company’s Board of Directors confirmed the composition of the NRRC

as follows:

Member

Role

Beginning of term

of office

Ending of term of

office

Pyrros Papadimitriou

Independent - Non-Executive

Member, Chair of the NRRC

22-08-2022

21-08-2025

Despoina Doxaki

Independent - Non-Executive

Member, Member of the NRRC

29-06-2022

28-06-2025

Stefanos Theodoridis*

Independent - Non-Executive

Member, Member of the NRRC

22-08-2022

21-08-2025

*Until 5.7.2022, the date of appointment of the members of the new Nominations, Remuneration and

Recruitment Committee, the Committee consisted of the following three Independent Non-Executive BoD

members, Pyrros Papadimitriou, Despina Doxaki and Stefanos Kardamakis.

2. Curriculum vitae of the members of the NRRC

The Curriculum Vitae of the members of the Nomination, Remuneration & Recruitment Committee are

mentioned in Section VI.4 of this Statement.

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3. NRRC responsibilities

Responsibilities on matters pertaining to Recruitment, Remuneration & Incentives

Making recommendations to the BoD for:

o The definition of a policy for the recruitment of permanent personnel, within the framework of the

Company’s Business Plan, to be approved by the Board of Directors,

o the establishment of a procedure for recruiting senior managers (Deputy CEOs and Chief Officers)

and managers (Directors and Assistant Directors/ Heads of Units), to be approved by the General

Meeting,

o the drawing up of the Company’s remuneration policy, pursuant to Articles 110-112 of L. 4548/2018,

as applicable,

o the remuneration of the persons falling within the scope of the remuneration policy (members of the

Board of Directors, Deputy CEOs, Chief Officers, Directors and Assistant Directors/Heads of Units),

to be approved by the General Meeting.

o Examining the information contained in the final draft of the annual remuneration report, providing

its opinion to the Board of Directors, prior to the submission of the report to the General Meeting , in

accordance with article 112 of L. 4548/2018.

o Receiving and reviewing the report on the degree of achievement of the CEO’s objectives, through

which the degree of achievement of the Group’s objectives is confirmed and submitting it to the

Board of Directors for final approval.

o Finally, at the care and diligence of the NRRC, the projected annual report on staff recruitment of the

prior year under Article 185(3) of Law 4964/2022, as in force, is submitted to the Company's General

Meeting of Shareholders.

Responsibilities for the Nomination of Candidates for Board Members

Identifying and recommending to the Board of Directors persons eligible for acquiring the capacity of

Board members, by applying the following procedure:

• Periodically evaluates the size and composition of the Board of Directors.

• Submits proposals for the diversity policy adopted by the Board of Directors, and, in general, for

the implementation of the provisions of the relevant applicable legislation.

• Evaluates Board Candidates:

taking into account the factors and criteria defined by the Company, in accordance with the Suitability

Policy that it adopts; and examining any impediments and incompatibilities, as well as the criteria of

independence of candidate members (especially in the case of their appointment as independent

members), in accordance with Law 4706/2020 and Law 4548/2018, as applicable.

Responsibilities for the Assessment, Training and Succession Planning of Board members

The Committee shall have the competencies and the individual and collective responsibility for the

assessment of the BoD, for the training and succession planning, as provided for in the respective articles

of the Suitability Policy and the Training Policy for Board Members.

Other Responsibilities

Support the BoD, with the assistance of other competent services, in carrying out an audit of the fulfilment

of the conditions of independence of the non-executive members of the BoD, in accordance with the

provisions of Law 4706/2020.

It carries out a periodic assessment of its performance, under the responsibility of its Chairman, and

identifies any areas that need to be improved.

Detailed information on the role, responsibilities and functioning of the Nomination, Remuneration &

Recruitment Committee are included in its Rules of Procedure, which is posted on the Company's website

(https://www.dei.gr/el/dei-omilos/i-dei/etairiki-diakivernisi/organosi-etaireias/epitropes-ds/)

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4. Frequency of meetings and members' participation

✓ In 2022, the Audit Committee met eleven (11) times. The number of participations of each member

in the meetings of the Audit Committee is presented in the table below:

Member

Position in Committee

Number of Meetings in

which the members of the

BoD participated

Pyrros Papadimitriou

Chairman of NRRC

Despoina Doxaki

Member

Stefanos Kardamakis

Member

(for the period 01-01-2022 to

05-07-2022, during which 6

meetings took place)

Stefanos Theodoridis

Member

(for the period from 05-07-

2022 to 31-12-2022, during

which 5 meetings took place)

✓ Company executives were present at all meetings of the Committee, at its invitation, to present

their views on matters within their competencies.

5. Proceedings of the Nomination, Remuneration & Recruitment Committee for 2022

The main issues discussed, and the decisions taken by the Committee during 2022 are summarized

below:

The NRRC expressed its consent regarding the amendments to the Articles of Incorporation and the

Company's Suitability Policy regarding the term in office of the Independent Non-Executive Members and

Non-Executive Members of the Board of Directors of PPC SA. In its Decision No. 10/23.2.2022 the Board

of Directors decided to propose to an Extraordinary General Meeting of the shareholders of PPC S.A. the

amendments to the Articles of Incorporation and the Suitability Policy of the Members of the Board, which

were approved by the Extraordinary General Meeting of the shareholders on 17 March 2022.

The NRRC decided to propose to the Board of Directors of PPC S.A. to approve the Draft Policy and

Procedure of Evaluation of the Suitability and Effectiveness of the Board of Directors of PPC S.A. and its

Committees, and that the procedure for assessing the suitability and effectiveness of the Board of

Directors of PPC SA and its Committees is launched. During the same meeting, the roles and

responsibilities of the NRRC were discussed, with regard to the aforementioned evaluation process as

well as the timeframe of actions in view of the election of Board Members to the Ordinary General Meeting

of shareholders on 29-06-2022. The Board of Directors, by its decision No. 45/10.5.2022 approved the

Policy and Procedure of Evaluation of the Suitability and Effectiveness of the Board of Directors and its

Committees.

The NRRC approved the Evaluation Report of the Suitability and Effectiveness of the Board of Directors

of PPC S.A. and its Committees and decided to submit it, as well as the proposed improvement actions,

to the Board of Directors of PPC S.A. in order to take a decision on finalising the action plan. The Board

of Directors in its Decision No. 60/6.6.2022 approved the Evaluation Report of the Suitability and

Effectiveness of the Board of Directors of PPC S.A. and its Committees, with the improvement proposals

and actions included therein.

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The NRRC decided to propose to the BoD the election of eight (8) BoD Members due to the expiry of the

term of office of an equal number of its members, including the election of the CEO, in accordance with

article 15 of the Articles of Incorporation of PPC SA, having taken into consideration the proposals of the

shareholders and having verified that the conditions under Law and the Company’s Suitability Policy are

met. The Board of Directors through its Decision No. 61/6.6.2022 decided to recommend to the Ordinary

General Meeting of the Shareholders the election of eight (8) members of the Board due to the expiry of

the term of office of an equal number of members, including the CEO, and the General Meeting elected

them on 29 June 2022.

The NRRC decided to approve the Annual Remuneration Report of the Company of Article 112 of Law

4548/2018 for fiscal year 2021. The Board through its Decision No. 55/6.6.2022 decided to approve the

Company’s Annual Remuneration Report of FY21 and to submit it to the Company’s Ordinary General

Meeting of Shareholders on 29 June 2022, which approved it.

The NRRC determined, within the framework of its responsibilities, the extent to which the CEO’s

objectives for 2021 have been achieved, and has decided to submit its Report on the Achievement Degree

of CEO’s objectives for financial year 2021, to the Board of Directors for approval, which constitutes final

certification of the achievement degree of the Group’s objectives for financial year 2021. The Board of

Directors in its Decision No. 75/28.6.2022 decided to approve the Report on the Achievement Degree of

the CEO's objectives, which constitutes final certification of the achievement degree of the Group’s

objectives for financial year 2021.

The NRRC decided to submit a recommendation to the Company’s Board of Directors for approval of the

Policy for the Recruitment of Personnel with indefinite and fixed-term employment contracts, submitted

by the competent services, and of the Executive Recruitment Policy. The Board of Directors in its Decision

No. 131/22.11.2022 decided to approve the Policy for the Recruitment of Personnel with indefinite and

fixed-term employment contracts and the Executive Recruitment Policy.

The NRRC decided to propose to the Company’s Board of Directors, for submission to the General

Meeting of shareholders and approval, a revised Remuneration Policy for Members of the Company’s

Board of Directors. The Board of Directors , by its Decision No. 130/22.11.2022 decided to recommend

to the Company’s General Meeting of shareholders on 14 December 2022 the revised Remuneration

Policy for members of the Company’s Board of Directors, which approved it.

In view of the election of a new member to the Company’s Audit Committee and in the context of the

Board of Directors having left the initiative to the Company’s Shareholders to make relevant proposals up

to seven (7) seven days before the Extraordinary General Meeting of the Company’s shareholders at the

latest, the NRRC proceeded with the evaluation of the candidates and the check whether they have the

qualities and characteristics required by Law, and decided to propose to the Board of Directors, for

approval at the Company’s Extraordinary General Meeting of Shareholders on 14.12.2022, the election

of Mr. Glavanis Christou-Stergiou, as member of the Audit Committee of PPC SA The Board, by its

Decision No. 146/9.12.2022, decided to recommend to the General Meeting of the Company’s

shareholders, on 14 December 2022, the election of Mr. Christos Stergios Glavanis, as member of the

Audit Committee of PPC S.A., which elected him.

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6. Evaluation of the Committee

In accordance with the Rules of Operation of the Nomination, Remuneration & Recruitment Committee,

the Committee is periodically evaluated in terms of its performance under the supervision of its Chair, who

is responsible for the implementation of the evaluation process.

During 2022, the first internal evaluation of the Nomination, Remuneration & Recruitment Committee took

place in the context of the evaluation of the BoD and its Committees, which was based on the new Policy

and Procedure of Evaluation of the Suitability and Effectiveness of the BoD and its committees. Extensive

reference to the results of the NRRC evaluation is made in paragraph 7 “Evaluation of the Suitability and

Effectiveness the Board of Directors and its Committees” of Section VI. Composition and Functioning of

the Governing Bodies of this Statement.

D. Other Committees

Executive Committee

The Company has an Executive Committee. The Executive Committee is composed of the CEO, who is

also its Chairman, any Deputy CEO’s and the Chief Officers. The current Executive Committee consists

of nineteen (19) members. The Executive Committee shall operate in conformity with the decisions of the

Board of Directors, ensuring the necessary collective handling of administrative and operational issues of

the Company, as well as the consistency in its operation. Within this framework, the Executive Committee

shall be responsible for important matters concerning inter alia the productivity, the performance of the

company units, the organization and operation of activities of the Company, as well as for the budget and

the Strategic and the Business Planning.

For 2022, and up to the date of amendment of the Articles of Incorporation by decision of the Company’s

Extraordinary General Meeting of Shareholders on 14.12.2022, the Executive Committee, in addition to

the foregoing, decided on the award of contracts concerning supplies, works, provision of services and,

in general, any type of contract with a financial object up to the amount set by the Board of Directors in

each case.

During 2022, the Executive Committee met twenty (20) times and its main topics were:

● Award of tenders for Works, Procurement and Service Provision contracts

● Extensions of contractual deadlines

● Increases in contractual object

● Amendments to contractual terms

● Leasing of properties to cover the Company’s housing needs

Procurement Committee

The Company’s Procurement Committee (PC) was established on 14 December 2022 by decision of the

Company’s Extraordinary General Meeting of Shareholders. The PC is comprised of the CEO, who is its

Chairman, any Deputy CEOs, the Chief Support Operations Officer, the Chief Legal Officer for Legal

Affairs and Corporate Governance, and the Chief Financial Officer. The competent Chief Officer for each

topic will participate in the aforementioned Committee’s meetings as rapporteur.

The PC operates in accordance with the decisions of the Board of Directors, ensuring more effective

monitoring of the new Procurement Operation Model, the annual Procurement Plan and the performance

of the company’s counterparties. In this context it shall decide on the awarding of contracts concerning

supplies, works, provision of services and in general any kind of financial contract up to an amount fixed

as per case by the Board of Directors. The Executive Committee shall operate in accordance with its

Rules of Operation, as approved by the Board of Directors upon recommendation by the CEO.

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Risk Management Committee

The Company has a Risk Management Committee, which was established with Decision No

112/23.09.2020 of the Board of Directors, which is responsible for the risk oversight in all of the Company’s

activities and contributes to the development of the Corporate Risk Management Framework and the

monitoring and reporting of significant Corporate Risks.

The Risk Management Committee consists of ten (10) members, as follows: More specifically, the Risk

Management Committee is composed of the CEO who is also its Chairman, the three (3) Deputy CEOs,

the Chief Legal Officer for Legal Affairs and Corporate Governance, the Chief Financial Officer, the Chief

Strategy & Transformation Officer, the CEO of PPC RENEWABLES SA, the Chief Energy Management

& Trading Officer and the Chief Risk Management Officer. The Chief Risk Management Officer also serves

as the Secretary of the Committee and replaces the Chairman of the Committee in his absence.

For the year 2022, the Risk Management Committee met ten (10) times and its main topics were the

following:

• approved the methodology for the conduct and oversaw the Exercise of the Self-Assessment

and Risk Control,

• oversaw the results of the aforementioned exercise and approved the Company’s major risks,

• was briefed on major regulatory developments and their potential impact on the Company,

• extensively reviewed material issues regarding Market Risk Management, receiving regular

updates on the Company’s positions and portfolios, fundamentals, and developments in

domestic and international markets,

• was briefed on and commented on calculation models that exist or are under development for

assessing financial risks, forecasting demand for electricity generation, estimating sales and

data related to them, etc.

• approved the plans for publications on the risks and their management,

• was briefed and provided guidance on issues and corporate texts related to risk governance in

the Company.

Hedging Committee

Within 2022, with Decision No. 221/2022 of the CEO, the Hedging Committee was established in order to

elaborate the Trading Price Hedging Strategy of the Department of Energy Management & Trading, based

on the relevant decisions and guidelines of the Risk Management Committee. The Committee consists of

five members and is composed of the Chairman and CEO, as Chairman of the Committee, the Chief

Energy Management and Trading Officer, as Deputy Chairman of the Committee, as well as the Chief

Financial Officer, the Director for Long-Term Transactions of the Department of Energy Management &

Trading, and the Director for Market Analysis of Department of Energy Management & Trading, as

members.

The Committee met three (3) times during 2022, and the main topics which the Hedging Committee

addressed are the following:

• The new regulatory framework in the wholesale electricity market, which was implemented in

July 2022, and how this affects PPC’s exposure to risk

• The hedging strategy that is recommended for PPC to implement based on the new regulatory

framework

• Latest developments in the energy market in Greece and the EU (market view)

• Energy Management & Trading Department trading limits

• Participation in new Markets/Exchanges and new energy products

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Cybersecurity Committee

Within 2022, with Decision No. 138/23-11-2022 of the Board of Directors, the Cybersecurity Committee

of PPC SA was established. It is a seven-member Committee consisting of the CEO as the Chairman of

the Committee, the Deputy CEO of Digital Transformation as the Deputy Chairman of the Committee, two

Deputy CEOs, the Chief Digital Systems Development and Operations Officer, the Chief Cyber Security

Officer and the Chief Risk Management Officer.

The main framework of the Committee’s responsibilities includes:

• Drawing up a cyber security action plan for the Company in the context of the General Corporate

Information Security Policy

• Coordination and oversight of implementation of the Corporate Information Security Framework

• Managing and responding to high-risk and high-impact cyber security incidents

• Approval of reports to the competent corporate bodies on cyber security strategy and the method

of its implementation.

During 2022, the Cyber Security Committee met three (3) times and its main topics were the following:

• The creation of a Cyber Security Department

• Governance issues (policies and procedures)

• Forging a cybersecurity strategy

Sustainability Committee

Based on the decision of the Board of Directors No. 142/9.11.2021, a Sustainability Committee has been

established with representation from the top management, which will be responsible for the supervision

of Sustainability and for informing the Board of Directors on Sustainability matters. The establishment of

this Committee was carried out in the context of the TCFD (Taskforce for Climate-related Financial

Disclosure) action plan, according to which the risks that the Company will face in its activities due to

climate change, as well as the ways to address them, will be examined.

The purpose of the Sustainability Committee is at minimum the involvement, the understanding and

reporting to the BoD of subjects related to the following:

(a) supervision, coordination and promotion of policies and actions related to Sustainability and Climate,

(b) overseeing the identification, monitoring and management of risks and opportunities related to

Sustainability and Climate,

(d) overseeing and approving the Sustainability Report and the wider implementation of appropriate non-

financial reporting and ESG (Environment, Society, Governance) disclosure frameworks,

(e) oversight and monitoring of the annual targets around Sustainability, CSV (Creating Shared Value)

and Climate for all Group Departments and sections, and with respect to HEDNO, the monitoring of its

business plan in relation to Sustainability matters on behalf of the shareholder; and

(f) reporting to the Board of Directors on these matters on a regular basis, with the ultimate objective of

further enhancing the Board’s oversight and awareness.

The Sustainability Committee consists of seven (7) members, namely the Chairman & CEO of PPC SA,

as Chairman of the Committee, three (3) deputy CEOs, the Chief Financial Officer, the CEO of the

subsidiary PPC Renewables SA, and the Sustainable Development Director, as Secretary of the

Committee and Deputy Chairman of the Committee.

149

In 2022, the Sustainability Committee met 4 (four) times. During these meetings: 1) the 2020 Sustainability

Report was approved and relevant objectives were set for the next Report and the necessary projects for

2022; 2) priorities were set, such as the commitment to the Science Based Targets (SBTi) initiative for

setting short- and long-term greenhouse gas emission reduction targets; 3) it was decided to consolidate

– in a single plan – actions that concern the “Taskforce for Climate-related financial disclosure and

“Environmental and Social Action Plan” (TCFD/ ESAP), 4) a plan for the renewed Sustainable

Development and Environmental Policy was formulated and approved, 5) climate scenarios were

presented in the context of the recommendations of the TCFD by the Strategy Directorate, 6) the review

of the activities of the year took place, and the revised procedure for drafting the Sustainability Report

was approved.

VII. Diversity Policy

The Company has put in place and implements a Diversity Policy with a view to promoting a suitable level

of diversification inside the BoD and an inclusive team of members. Putting together a broad range of

qualifications and skills when selecting BoD members guarantees diversity of insight and expertise with a

view to sound decision-making. The Diversity Policy is taken into consideration when appointing new BoD

members.

By adopting and implementing a Diversity Policy, the Company ensures that no one is excluded from

selection and appointment in the BoD because of gender, race, colour, ethnic or social origin, religion or

belief, property, birth, disability, age or sexual orientation. In addition, the Company must ensure an

adequate representation of gender corresponding to at least twenty-five per cent (25%) of the total number

of BoD members. In case of fraction, this number is rounded down to the previous integer. Respectively,

through the Competent Units, the Company takes appropriate initiatives to achieve a wider range of

representation of shareholders at the BoD, who, either individually or in the aggregate, represent at least

10% of the Company’s share capital. The Nominations, Remuneration & Recruitment Committee takes

these criteria into consideration when making proposals for the appointment of BoD members.

More Specifically, the Diversity Policy explains the Company’s approach to equality and diversity within

the Board. The Company is committed to promoting equality and diversity within the Board, as well as to

promote a culture that, on the one hand, values and respects diversity and, on the other hand, recognizes

that people from different backgrounds and experiences can make a valuable contribution to the work of

the Board. The broader goal of the Company is to be an inclusive organization, which provides equal

opportunities in the whole range of employment, including recruitment, training, and development of the

members of the Board of Directors and the employees.

VIII. Related Parties Transactions’ Regulation

The Company has a “Related Parties Transactions” Regulation, which introduces Regulations and internal

procedures for the transparency and supervision of transactions and contracts of PPC S.A. with Related

Parties of the Company, in order to strengthen the existing ones, in compliance with Law 4548/2018 (A

104) [articles 97, 99--101 and 109, paragraph 3], the Decisions of the Hellenic Capital Market Commission

No. 1/434 / 3.7.2007 and 8/754 / 14.4.2016, and the Circular of the Hellenic Capital Market Commission

No. 45 / 21.07.2011.

This Regulation sets out the rules, procedures and in general the framework for the Company to carry out

transactions and conclude contracts with related parties (related party transactions), i.e., with persons

who can exercise control or undue influence over it.

150

With regard to the definition of the personnel-subjective scope of the Regulation, a reference is made to

the provisions of the accounting law and, in particular, to the persons defined in IAS 24. The objective

scope of the Regulation covers in principle all transactional relations between the Company and its

affiliates. Therefore, no distinction is made between loan and credit agreements / transactions, on the one

hand, and "other agreements / transactions", on the other; on the contrary, all agreements / transactions,

independently whether they concern agreements / transactions from which only benefits arise for the

Company, are subject the provisions of the Regulation.

Furthermore, the Regulation governs the remuneration to members of the Board of Directors for services

they provide to the Company on the basis of a special relationship, such as indicatively, by way of

employment, work contract or mandate.

The General Division of Financial Services draws up a specific list in which the details of the related parties

are registered and updated ("List of Related Parties"). The list of Related Parties is updated whenever

required by the circumstances and in any case at least once a year, by requesting from the persons

directly connected with the Company (and / or their legal representatives) to confirm the information

already submitted, including information already submitted that relate to other persons who, the directly

related parties, know or have good reason to believe that, also constitute (indirectly) related parties with

the Company. In addition to the above periodic updates, the General Directorate of Financial Services

may, at any time it deems appropriate or necessary, request the update of the Directory.

The Annual Report of the Board of Directors of the Company (L. 3556/2007 as in force) includes the most

important transactions of the Company with related parties, as defined in IAS 24, and at least the

transactions between the Company and each related party that took place during the financial year and

which substantially affected the financial position or performance of the Company during that year.

IX. General Meeting and Shareholder’s Rights

Responsibilities of the General Meeting

The General Meeting of shareholders is the supreme authority of the Company and shall have the right

to adopt resolutions on all matters concerning the company, unless otherwise stipulated in the company's

Articles of Incorporation, and more particularly to decide regarding:

The amendments to the Articles of Incorporation, such amendments are also deemed to be the increase

or reduction of the share capital, subject to the provisions of article 6 of the Articles of Incorporation and

article 117 par. 2 of Law 4548/2018, as applicable. The resolutions concerning amendments to these

Articles of Incorporation shall be valid, provided that the relevant amendment is not prohibited by an

express provision hereof or by law,

– The election of Board Members, pursuant to article 9 of the Articles of Incorporation, of the CEO

and of the regular auditors,

– The approval of the overall management pursuant to article 108 of Law 4548/2018 and the

discharge of the auditors,

– The approval of the annual and consolidated financial statements of the Company,

– The distribution of the annual profits,

– The approval of the provision of remunerations in accordance with article 17 of the Articles of

incorporation, as well as the approval of the Remuneration Policy of article 110 and the

remuneration report of article 112 of Law 4548/2018,

– The issuance of loan through bonds convertible into shares, by virtue of those especially

provided for in article 71 of Law 4548/2018 and subject to those provided for in article 6 of the

Articles of Incorporation. The issuance of bonded loans non-convertible into shares shall be

allowed by resolution of the Board of Directors,

– The merger, division (demerger), conversion, revival, extension of term or dissolution of the

Company and

– The appointment of liquidators.

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Any holder of fully paid-up voting shares shall participate in the General Meeting of shareholders of the

Company only to the extent of the number of shares which he/she holds.

Convocation of the General Meeting

The General Meeting of the shareholders of the Company shall be convened by the Board of Directors

and shall meet at the seat of the Company and/or at any other venue other than its seat, in accordance

with the provisions of articles 119 and 120 of Law 4548/2018, at least once a year, no later than the tenth

(10th) calendar date of the ninth month following the termination of the fiscal year in order to adopt

resolutions on the approval of the annual financial statements and the election of auditors (Ordinary

General Meeting). The Board of Directors may convene an Extraordinary General Meeting of the

shareholders, whenever this is prescribed by special provisions or whenever the Board considers it

appropriate.

The Board of Directors may, in accordance with Article 120, paragraph 3 of Law 4548/2018, as in force,

decide that the General Meeting will not be convened at a specific venue, but will be held exclusively with

the remote participation of shareholders via the electronic means provided for in the applicable Article 125

of Law 4548/2018.

Within ten (10) days from the submission by the auditors of a request to the Chairman of the Board, the

Board of Directors shall be bound to convene the General Meeting of shareholders having as for items on

the agenda those listed in the submitted request.

Invitation to the General Meeting

The Invitation to the General Meeting, with the exception of repeat General Meetings and of meetings

regarded as such, shall clearly state at least the venue, date, and time of the meeting, the items on the

agenda, the shareholders entitled to participate, as well as precise instructions about the way the

shareholders shall be able to participate in the meeting and exercise their rights in person or by proxy, or

potentially through remote attendance (from a distance), shall be available in a prominent place at the

registered office of the company and shall be published by posting on the website of the Company and

the website of the GECR, and in any case, as provided for by law each time.

In case of application of the possibility provided for in Article 20, paragraph 2 of these Articles of

Incorporation, the invitation of the General Meeting shall expressly provide for the possibility of

participating in the General Meeting remotely via audiovisual or other electronic media, without the

shareholder’s physical presence at the venue, under the specific conditions provided for in Article 125 of

Law 4548/2018, as applicable.

With the exception of the repeat Meetings, the General Meeting shall be convened at least twenty (20)

full days prior to the date set for the meeting. The invitation shall be posted on the Company's website at

least twenty (20) full days prior to the date of the General Meeting and at the same time it shall be

registered with the Company's section at the GECR (G.E.MI) as per law.

The day of publication of the notice of invitation to attend a General Meeting and the day on which such

meeting shall be held are not counted.

In addition to the information of par.1 the invitation:

include information on at least:

– the shareholders' rights of par. 2, 3, 6 and 7 of article 28 of the Articles of Incorporation, stating

the time period within which each right may be exercised, the respective deadlines specified in

the above paragraphs of article 28 of the Articles of Incorporation or, alternatively, the closing

date by which such rights may be exercised, on condition that the detailed information concerning

the said rights and the terms of their exercise is posted, with an explicit reference in the invitation,

on the Company's website www.dei.gr, and

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– the procedure for the exercise of the voting right by proxy and more in particular the printed forms

used by the Company to this end, as well as the means and methods provided for in article 22

of the Articles of Incorporation, in order that the company may receive electronic notifications of

any appointment and revocation of proxy holders,

– the procedures regarding the exercise of the voting right via registered mail or email according

to those provided for in articles 125 and 126 correspondingly, of L. 4548/2018 and article 22 of

the Articles of Incorporation.

– set the record date as provided for in par. 2 article 22 of the Articles of Incorporation in

accordance with par. 6 article 124 of L. 4548/2018, as applicable, pointing out that only those

persons having the shareholder capacity on such date shall have the participation and voting

right at the General Meeting.

– inform about the location where the full text of documents and draft resolutions provided for in

cases c) and d) of par. 5 article 22 of the Articles of Incorporation are made available, as well as

their reception mode.

– mention the Company's website address where the information of par. 5 of article 22 of the

Articles of Incorporation is posted.

The Company shall publish in the media referred to in par. 1 a summary of the invitation containing at

least the precise address of the venue, the date and the time of the meeting, the shareholders entitled to

participate, as well as an explicit reference to the address of the Company's website where the full text of

the invitation and the information provided for in article 123 of L. 4548/2018 are posted.

In the case of application of par. 2, article 141 of L. 4548/2018, the publication in the media in accordance

with the par. 1 of article 21 of the Articles of Incorporation shall contain at least a clear indication that any

revised agenda shall be posted on the Company's website and in the media referred to below. In addition

to the publication in the media of par. 1 of article 21 of the Articles of Incorporation including the Company's

website, the full text of the invitation shall also be published within the prescribed deadline of par. 2 of

article 21 of the Articles of Incorporation, in such a way as to ensure rapid and non-discriminatory access

to it, in the media that the Board of Directors considers reasonably reliable for the effective dissemination

of information to the investors through printed and electronic media of national and Europe-wide

circulation.

Participation in the General Meeting

Any shareholder shall be entitled to attend and vote at the General Meeting.

Any shareholder who holds and proves his shareholder capacity on the date of the General Meeting shall

be entitled to participate in the General Meeting. In particular any person holding the shareholder capacity

on the commencement of the fifth (5th) date prior to the date of the initial date of the General Meeting

(Record Date) shall be entitled to participate in the General Meeting. The above Record Date shall apply

even in the event of a postponed or repeat meeting on condition that the postponed or repeat meeting is

not held later than thirty (30) days from the Record Date. If that is not the case or if, in the event of a

repeat General Meeting, a new Invitation is published in accordance with those provided for in article 130

of L. 4548/2018, any person having the shareholder capacity on the commencement of the third (3rd) day

prior to the date of the postponed or repeat General Meeting shall be entitled to participate in the General

Meeting. The shareholder capacity shall be evidenced by any legal means and in any case based on the

information received by the Company from the Central Securities Depository, on condition that the latter

provides registry related services.

Shareholders shall participate in the General Meeting either in person or by proxy. Each shareholder may

appoint up to three (3) proxy holders. Any proxy holder holding proxies by several shareholders may cast

votes differently for each shareholder. The appointment, revocation or substitution of any proxy holder

shall be made in writing or by mail and shall be notified to the company in accordance with the same

procedure as above at least forty eight (48) hours prior to the date set for such General Meeting. Legal

entities shall participate in the General Meeting by their representatives.

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Ten (10) days prior to the ordinary General Meeting, the Company shall make available to the

shareholders the annual financial statements thereof, together with the relevant reports of the Board of

Directors and of the auditors, posting the relevant information on the Company's website as specified in

par. 1 and 2 of article 123 of L. 4548/2018.

Each shareholder, for each item on the agenda which allows for open vote, shall be entitled to participate

in the General Meeting via distance voting, registered mail or through electronic means, with the voting

being held prior to the General Meeting, subject to the conditions set out in article 126 of L. 4548/2018.

As of the date of publication of the invitation to the General Meeting and until the date of the General

Meeting, at least the following information shall be posted on the company's website:

– the notice of invitation to the General Meeting,

– the total number of shares and voting rights on the date of such invitation,

– the documents to be submitted at the General Meeting,

– a draft resolution for each proposed item on the agenda or in case no resolution has been

submitted for approval, a comment by the Board of Directors on each item on the agenda and

any draft resolutions submitted by the shareholders, right after being received by the Company

and

– the printed forms to be used for the exercise of voting rights by proxy.

Ordinary Quorum and Majority

A quorum of the General Meeting shall be deemed to be achieved for the proper discussion of the items

on the agenda, when shareholders representing at least one fifth (1/5) of the paid-up share capital are

present or represented thereat.

If the quorum referred to in the preceding paragraph is not obtained, the General Meeting shall be held

again within twenty (20) days from the date of the postponed meeting, following invitation being notified

at least ten (10) days prior to the meeting date. At such a repeat meeting a quorum shall be deemed to

be obtained in order to duly discuss the items set out on the original agenda, regardless of the proportion

of the paid-up share capital represented thereat.

A new notice of invitation is not required, in the event that the original notice of invitation states the venue

and date of the repeat meetings provided for by the law, in case a quorum has not been reached, on

condition that there is a lapse of at least five (5) days between the postponed meeting and the repeat one.

The resolutions of the General Meeting shall be adopted by absolute majority of the votes represented

thereat.

Extraordinary Quorum and Majority

Exceptionally, for resolutions involving:

• change in the nationality of the Company,

• modification of the object of the Company,

• issuance of bonded loans convertible into shares, as stipulated by par. 1(g) article 19 of the

Articles of Incorporation,

• increase of the shareholders' obligations,

• increase of the share capital, subject to the provisions of article 6 of the Articles of Incorporation,

or unless it is imposed by law or is effected by capitalization of reserves,

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• the reduction of share capital, excluding the case of paragraph 6 of Article 49 of Law 4548/2018,

as in force, or except for the cases where a special law or the Articles of Incorporation are

otherwise regulated,

• change in the manner of profits' distribution,

• restriction or abolition of the pre-emption right of the old shareholders in the cases of and subject

to the conditions set out in article 27 of Law 4548/2018,

• merger, division (demerger), conversion, revival, extension of term or dissolution of the company,

• granting or renewing of powers to the Board of Directors for the increase of the share capital or

the issuance of a bonded loan in accordance with the provisions of article 6 par. 2(b) of the

Articles of Incorporation, and

• any amendment to this article and in any other case stipulated by the law.

The Meeting has quorum and legally meets on the items set out in the agenda, when shareholders

representing one half (1/2) of the paid-up share capital are present or represented thereat.

If the said quorum is not obtained, a repeat General Meeting shall be convened in accordance with the

provisions of par. 2, article 23 of the Articles of Incorporation, a quorum of which shall be obtained for the

proper transaction of the business set out in the initial agenda, when at least one fifth (1/5) of the paid-up

share capital is present or represented thereat.

A new notice of invitation is not required on condition that the venue and time of the repeat meetings, as

provided for by law, are set in the initial invitation, and that at least five (5) days intervene between each

postponed meeting and each repeat one.

The resolutions stipulated in par. 1 article 24 of the Articles of Incorporation shall be made by a two third

(2/3) majority of the votes represented thereat.

Chair to the General Meeting

The Chairman of the Board of Directors shall preside, provisionally, as chairman at the General Meetings.

If unable to perform his/her duties, he/she shall be replaced by his/her substitute. Secretarial duties at the

meetings shall be performed, provisionally, by a person appointed by the Chairman.

Following approval of the final list of shareholders with voting rights, the General Meeting shall proceed

to the election of its Chairman and of one (1) Secretary, who shall also act as scrutineer.

Agenda - Minutes of the Meetings

The discussions and the resolutions of the General Meeting shall be limited to the items on the agenda

published in accordance with article 21 of the Articles of Incorporation.

A summary of all discussions and resolutions of the General Meeting shall be entered in a minute book

signed by the Chairman and the Secretary. At the request of any shareholder, if any, the Chairman shall

be obliged to record an exact summary of the said shareholder's opinion in the minutes. In the same

minute book, a list of shareholders who attended the General Meeting in person or by proxy shall also be

recorded. The results of the voting shall be posted on the Company's website under the responsibility of

the Board of Directors within five (5) days at the latest from the date of the General Meeting, indicating for

each resolution at least the number of shares for which valid votes were cast, the proportion of the share

capital represented by such votes, the total number of valid votes, as well as the number of votes cast in

favour and against each resolution and the number of abstentions.

Copies of and excerpts from the minutes of the General Meeting shall be certified by the Chairman of the

Board of Directors or his/her substitute and provided that there is an obligation to be registered with the

General Electronic Commercial Registry (GECR), they shall be submitted to the competent service of the

GECR within twenty (20) days as of the holding of the General Meeting.

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Minority rights

1. At the request of shareholders representing one twentieth (1/20) of the paid-up share capital, the Board

of Directors shall be bound to convene an Extraordinary General Meeting, setting the date of such a

meeting, which shall not be later than forty-five (45) days from the date of service of such request to

the Chairman of the Board of Directors. The agenda items shall be stated in detail in the said request.

If the General Meeting is not convened by the Board of Directors within twenty (20) days from the

service of the said request, the meeting shall be convened by the requesting shareholders at the

expense of the Company, upon ruling of the Single-Member Court of First Instance at the Company's

registered seat, issued following the procedure of interim measures. The place and date of the

meeting, as well as the items on the agenda, shall be defined by the said ruling. This ruling may not

be contested by any judicial remedies. The Board of Directors convenes the General Meeting,

pursuant to the general provisions or uses the procedure set out in article 135 of Law 4548/2018,

unless the requesting shareholders have precluded that possibility.

2. At the request of shareholders representing one twentieth (1/20) of the paid-up share capital, the Board

of Directors shall be obliged to insert additional items on the agenda of a General Meeting already

convened, if the relative request has been submitted to the Board of Directors at least fifteen (15) days

prior to the General Meeting. The request for the insertion of additional items in the agenda shall be

accompanied by the reasoning or a draft resolution to be approved by the General Meeting and the

revised agenda shall be published or notified under the responsibility of the Board of Directors,

pursuant to article 122 of L. 4548/2018, as applicable, according to the same procedure as above,

thirteen (13) days prior to the date of the General Meeting; at the same time it shall be made available

to the shareholders on the Company's website along with the reasoning or the draft decision submitted

by the shareholders in accordance with the provisions of par. 5 article 22 of the Articles of

Incorporation. In the event that these items are not published, the requesting shareholders are entitled

to request the postponement of the General Meeting, pursuant to par. 5 of article 22 of the Articles of

Incorporation and proceed on their own to their publication, in accordance with the provisions of the

present paragraph, at the expense of the Company.

3. At the request of shareholders representing one twentieth (1/20) of the paid-up share capital, the Board

of Directors shall make available to the shareholders in accordance with the provisions of par. 5 article

22 of the Articles of Incorporation, at least six (6) days prior to the General Meeting any draft

resolutions on items included in the initial or the revised agenda, provided that such request is

submitted to the Board of Directors at least seven (7) days prior to the date of the General Meeting.

4. The Board of Directors shall have no obligation to proceed to the insertion of items on the agenda nor

to publish or notify such items along with the reasoning and the draft resolutions submitted by the

shareholders in accordance with the above paragraphs 2 and 3 respectively if their content is obviously

contrary to Law and morality.

5. At the request of shareholders representing one twentieth (1/20) of the paid-up share capital, the

Chairman of the General Meeting shall be obliged to postpone, only once, the decision-making

process by the ordinary or extraordinary General Meeting for all or specific items, setting at the same

time as date when the meeting will reconvene for decision-making, the one specified in the request of

the shareholders, which may not be later than twenty (20) days from the date of postponement.

The General Meeting, which follows the postponed one, is considered a continuance of the previous

one and no repetition of the requirements for the publication of the shareholders' invitation is required.

New shareholders may also attend this meeting, pursuant to the provisions of article 22 of the Articles

of Incorporation.

156

a) At the request of shareholders representing one twentieth (1/20) of the paid-up share capital

submitted to the Company, the Board of Directors shall be bound to announce to the General

Meeting of shareholders, provided it is an ordinary General Meeting, the amounts paid by the

Company, for any reason whatsoever, within the last two (2) years, to members of the Board of

Directors, to the Chief Officers, to the Directors or other employees of the Company, as well as any

other benefit paid to the said persons or any contract of the Company concluded with the above

mentioned persons for any reason whatsoever.

b) At the request of any of the shareholders, submitted to the Company within at least five (5) full days

prior to the General Meeting, the Board of Directors shall be bound to provide any requested

information with respect to the Company affairs, to the extent that such information is useful for the

actual evaluation of the agenda items. The Board of Directors may give a common reply to all

shareholders' requests having the same content. There shall be no obligation to provide information,

on condition that such information is already posted on the Company's website, especially in

question and answer form.

In both cases above, the Board of Directors may refuse to provide the requested information, if

sufficient material grounds exist, recording the reasons for such refusal in the minutes. Such reason

may be, depending on the circumstances, the representation of the requesting shareholders at the

Board of Directors, pursuant to articles 79 or 80 of L. 4548/2018. In the cases of the present

paragraph, the Board of Directors may give a common reply to all shareholders' requests having the

same content.

7. At the request of shareholders representing one tenth (1/10) of the paid-up share capital submitted to

the Company within the time limit referred to in the preceding paragraph, the Board of Directors shall

be obliged to provide to the said shareholders during the General Meeting information on the progress

of the affairs and on the financial condition of the Company. The Board of Directors may refuse to

provide the requested information, if sufficient material grounds exist, recording the reasons for such

refusal in the minutes.

8. In the cases referred to in the par. 6a and 7, any issue in dispute over the validity of the reasons for

such refusal by the Board of Directors shall be resolved by the Single Member Court of First Instance

of the Company's registered seat, following the procedure of interim measures. By the same ruling,

the court shall oblige the Company to provide any information it refused. This ruling may not be

contested by any judicial remedies.

9. At the request of shareholders representing one twentieth (1/20) of the paid-up share capital, a

resolution concerning any item on the agenda of the General Meeting shall be made by open vote.

10. In all cases referred to in the par.1 to 9, the shareholders submitting such a request shall be obliged

to provide during the exercise of their rights evidence of their shareholding capacity, in conjunction

with article 22 of the Articles of Incorporation, and except in the case of the second section of par. 6

of the article 22 of the Articles of Incorporation, of the number of their shares during the exercise of

their right. Shareholders' capacity may be evidenced by any legal means and in any case based on

the information that the Company receives from the Central Securities Depository, on condition that it

provides registry-related services.

157

11. Shareholders of the Company representing one twentieth (1/20) of the paid-up share capital shall

have the right to request by the Single-Member Court of First Instance of the Company's registered

seat the performance of an audit of the Company. Such audit shall be ordered, in the event it is

assumed that certain acts reported against the Company violate the provisions of the law, of the

Articles of Incorporation or of the resolutions of the General Meeting. In all cases, the petitions

requesting an audit shall be filed within three (3) years from the date of approval of the annual financial

statements of the financial year within which such reported acts took place.

12. Shareholders of the Company representing one fifth (1/5) of the paid-up share capital shall have

the right to request by the court referred to in the preceding paragraph the performance of an audit of

the Company, provided it is assumed from the general progress of the company affairs, that the

management thereof is not carried out in accordance with the principles of honesty and prudence. The

last section of paragraph 3 of Article 142 of Law 4548/2018 is not applicable.

13. Shareholders who make a request in accordance with par. 11 and 12, must provide evidence to

the Court that they are in possession of the shares, in conjunction with article 22 of the Articles of

Incorporation, granting them the right to request the audit of the Company.

14. Without prejudice to the provisions on personal data protection, any shareholder may request a

list of the Company's shareholders, bearing the name and the address of each shareholder as well as

the number of shares held by each shareholder. The Company shall not be obliged to include in this

list shareholders holding up to 1% of the share capital.

15. Within ten (10) days as of the publication of the announcement concerning the granting of

permission by the Board of Directors under par. 2 of article 101 of L. 4548/2018, shareholders

representing one twentieth (1/20) of the capital may request the convocation of a General Meeting in

order to decide on the granting of such permission.

X. Sustainable Development Policy

In the context of devising and implementing the Group’s Sustainable Development strategy, which is

based on the philosophy of creating shared value between the Company, Society and Environment, the

Sustainable Development Policy (BoD decision No. 88/12.7.2022) was revised with the aim of gradually

aligning the business model with it, in the context of transforming PPC and the Group as a whole.

The Group’s Sustainable Development Policy is the basic framework of its commitment to the continuous

effort to improve the environmental, social and economic value it creates, for those who have legitimate

interests from its operation, but also for society as a whole.

PPC links its business decisions to environmental sustainability, social responsibility and good corporate

governance, incorporating the ESG criteria into its strategy and operation, thus adopting a business model

that is more transparent and people centered.

The main principles of the Sustainable Development Policy are fully harmonised with the Group’s strategic

plan, while sustainability issues are addressed in a continuous effort for Creating Shared Value for

Society, the Company and the Stakeholders.

As part of implementation of the Policy, PPC is aligned with the international frameworks of commitments,

public disclosures and assessments (SBTi/CDP), in line with international standards, principles and

guidelines (UN Global Compact, SDGs, OECD Guidelines, ISO 26000, GRI Standards, TCFD, SBTi, CDP

etc) and complies with the currently applicable legislative and regulatory framework.

158

The Sustainable Development Policy and the Environmental Policy of PPC, as an integral part hereof,

form part of the Rules of Procedure of PPC S.A. The full text of the Sustainable Development Policy is

posted on the company’s website https://www.dei.gr/el/dei-omilos/viosimi-anaptiksi/politiki-viosimis-

anaptiksis/eisagogi/

XI. Non - Financial Information

Non - Financial Information is presented in a different section and includes, among others, the following:

• Reference to the risks related in the long-term sustainability of the Company

• Reference of the standards the Company takes into consideration regarding the disclosure of

such non-financial information.

• Information related to article 8 of EU Regulation 2020/852 of the European Parliament and

Council on June 18, 2020, on the establishment of a framework to facilitate sustainable

investment, as well as information regarding the authorization of EU regulation 2021/2178 of the

Committee on July 6, 2021 for the completion of 2020/852 Regulation

• Climate change-related issues (Strategy, major impacts, risks and opportunities).

• Purpose of the non-financial information provided and data of its quality.

159

APPENDIX

1. Curriculum Vitae of the Chief Officers of the Company

Alexis Paizis, Deputy CEO of Production Operations (since 1 February 2023)

Mr. Alexis Paizis took over the position of Deputy CEO of Production Operations as of 1st of February

2023. Mr. Alexis Paizis is a Mechanical Engineer, a member of the Technical Chamber of Greece since

2001, with undergraduate, postgraduate and doctoral studies in Great Britain. During his 20-year career

in Greece and abroad, he has undertaken positions of responsibility that pertain to the planning -

construction, operation - maintenance and management of technical projects. In recent years he has

served as an executive in the Ellaktor Group, with a more recent position at Helector, which is active in

the Energy and Environment sectors.

Chief Officers

Economou Argiris, General Counsel - Chief Legal Officer for Legal Affairs and Corporate Governance

Mr. Economou has been the General Counsel of the Company since February 1st, 2005. Before that, he

was managing partner at “Stratigis & Associates” Law Firm and had served as legal counsel in various

companies of both the private and public sector. Along with his capacity as General Counsel, he was

since 2005 also acting as the Director of the Legal Department. Since 24.9.2019 he has also been

appointed as Chief Legal Officer for Legal Affairs and Corporate Governance. He has been an alternate

member on the Hellenic Competition Commission, Chairman of Eurelectric’s Legal Affairs Working Group,

Member of the Board of Directors of TAYTEKO (Insurance Fund of Bank and Public Utilities Employees)

and “Egnatia Odos S.A.”. Since 2014 he has been Secretary General of the Hellenic Association of Energy

Law. He has been member of various law drafting committees on listed Societes Anonymes and has

published various articles and studies on Corporate Governance, Compliance and Energy Law issues.

Georgia Christodoulopoulou, Director General of Supporting Operations

Ms Georgia Christodoulopoulou held the position of Director of the Administration Office since 2019. She

has been in the Company’s workforce for 30 years and has served in various positions of responsibility at

the Company. Has 15 years of experience in transformation programmes and introduction of new systems

and processes. She is an Economist – Agronomist and has postgraduate studies in Marketing from the

National Kapodistrian University of Athens and an MBA from ALBA Graduate Business School.

Alina Papageorgiou, Director General for Human Resources and Organisation

Ms Alina Papageorgiou, Director General for Human Resources and Organisation of PPC since June

2023, has 28 years of experience in the Human Resources Management sector, with latest positions

those of Chief HR Officer at Lamda Development, Chief HR Officer at Intralot Group and Group HR

Director at Vivartia Group and with Management positions in Human Resources in multinational

companies such as Diageo, Astrazeneca and Nestle Hellas. She also has 6 years of teaching experience

as a professor at Deree, American College of Greece. It has a B. Sc. at Management & Organisational

Behaviour from Deree, American College of Greece and MBA from the City University Business School

in London

Georgios Damaskos, Director General for Telecommunications

Mr. Damaskos served as General Manager of Human Resources from 2013 to 2022. Mr. Damaskos joined

the company in 1987. For 16 consecutive years since his recruitment he has served as Head of various

front-line operating units of the former Distribution Division (currently known as Hellenic Electricity

Distribution Network Operator). From 2002 to 2006 he was Head of the company’s Tariffs Section. He

has held the position of Director of the Corporate Development and Administration Department (currently

Strategy Department and Office of the Executive), as well as the position of Director of Planning and

Human Resources of the Commercial Activities Division. From 2008 until his assignment in the position

of Chief Officer of Human Resources in 2013, he was Director of Human Resources and Organization of

the Company. From 2008 to -2011, along with his duties at PPC, he was member of the Board of Directors

of the Insurance Fund for Bank and Utility Companies Employees (TAYTEKO) as representative of the

employers, on behalf of the Company. He also served as member of the Executive Committee of IKA-

ETAM/PPC Personnel Insurance Sector (TAP-DEH). Prior to joining PPC he worked in the private sector,

in the Construction Industry, and he was specialized in the implementation of PPC projects, thus acquiring

a significant construction and site experience. Mr. George Damaskos is an Electrical Engineer, member

of the Technical Chamber of Greece, and holds a degree in Economic Sciences from the Economics

Department of the Faculty of Law, Economics and Political Sciences of the Athens University. He also

holds an MBA degree in Business Administration from the Kingston Business School (Kingston

University).

160

Alexandridis Konstantinos, Chief Financial Officer

Mr. Alexandridis is an economist with many years’ experience in the Financial Management of large listed

companies, having served as senior executive at OTE Group (member of Deutsche Telekom Group). He

holds a Bachelor of Science in Mathematics from the University of Ioannina, an MSc in Decision Modelling

and Information Systems from Brunel University UK and an International MBA from the Athens University

of Economics and Business.

Sotirios Hadjimichael, Chief Strategy & Transformation Officer

Mr. Sotirios Hadjimichael has been working at PPC S.A. for the past 33 years. Prior to his appointment

as Chief Strategy & Transformation Officer, he held important positions and acquired experience in a wide

range of activities of PPC, the Transmission Network, the Electricity Market operation, etc. In particular

he worked: - In 1986 in the Planning Department, where he was involved in the Transmission Systems

Plans, the elaboration of the Transmission System Development Plan, etc. - In 1995, in the Purchasing

Department, as Inspection Engineer, where he dealt with Inspection-Testing-Material Acceptance issues,

acquiring significant experience on a multitude of materials and machineries of PPC, as well as on

purchasing procedures. - In 2000, at the Executive Office of PPC as Advisor, where he was involved in a

variety of issues falling within the competence of the Chairman. - In 2002 he was promoted to the position

of Head of the New Business Activities Section of the Strategy Department. He was involved in the

development of new activities, the expansion in new markets outside Greece, etc. - In 2008, in the Testing,

Research & Standards Center (TRSC) he worked as Head of the Research Programmes Section, where

he was involved in the central organisation of PPC’s participation in Research Programmes. - In 2010 he

was promoted to the position of PPC Executive Office Director. This position involves a wide range of

activities in all PPC fields, as well as participation in the Board of Directors and in the Executive Committee

of PPC. - In 2015 he was appointed as Director of the Strategy Department, where he has been involved

in a variety of activities ranging from the elaboration of the new Strategic Plan of the Company, the

coordination of Regulatory Issues, the strategy planning in matters of Electricity Market and the

development of PPC’s CSR. He was the Project Manager of the sale of IPTO to the Hellenic Republic and

a private investor. In 2019 he was promoted to Chief Strategy & Transformation Officer, heading the

Departments of Strategy, Mergers & Acquisitions, Regulatory, Research Programmes and

Representation in the European Union. His term of office as Chief Officer was renewed in 2023 for three

more years. In 1978 he graduated from the Varvakeio Experimental School of Athens. In 1984 he

graduated from the National Technical University of Athens with a Diploma in Electrical Engineering, with

the orientation of Energy Engineering. In 1993 he obtained a PhD from the Imperial College London, in

energy and RES issues.

Bali Efthymia, Chief Sales Officer

Ms. Bali has been working in PPC since May 1990. In 2007, she undertook the position of Head of

Subsection the Keratsini Sales Office, before the distinction between Commercial Activities and Network.

In 2008, with the creation of the Supply Business Division, she was appointed as Head (Director) of the

Piraeus Sales Section and was involved in the setting up of the first sales offices of the newly established

Division. In June 2014 she was appointed as Head of Unit of the Attica Retail Department and in August

2017 she was promoted to Director of the Department. She has been involved in customer service as well

as in the implementation of the tariff and commercial policy of the Company, and its procedures in general.

Furthermore, from 2014 until today, in addition to the aforementioned issues, she has dealt with the

overdue receivables issue and the methods to tackle it. She holds a Diploma from the School of Political

Science and Public Administration of the National and Kapodistrian University of Athens. Before her

recruitment by PPC, she worked for two years as an HR Manager in a private company.

Tsagiannis Ioannis, Chief Customer Management Officer

Mr. Ioannis Tsagiannis holds a Diploma from the Department of Primary Education of the National and

Kapodistrian University of Athens. He has served for 23 years in various managerial positions, in the

private sector, in the customer service sector in telecommunications such as Director of Customer

Service, Chief Officer of Customer Relationships and Chief Officer of Customer Experience

Configuration. He has great experience in the customer management sector, having achieved for a

number of years to combine the knowledge of commercial procedures with change management, in the

sector of organization and management of populous service groups, with optimal results.

161

Metikanis Dimitrios, Chief Officer of Lignite Generation Business Unit

Mr. Dimitrios Metikanis serves as Chief Lignite Generation Officer since November 19, 2017. Mr.

Metikanis has been a member of PPC staff since 1986; his career set off at Ptolemais Thermal Power

Plant, where he remained for more than five years, therefore gaining significant know-how in the operation

of thermal Power Plants. Thereafter, he was appointed in several technical and administrative positions

in the Generation Division, holding posts in the Generation Exploitation Department and the Materials,

Fuel and Purchasing Department (1992-2007), as well as in the Materials, Fuel Purchasing and Logistics

Department (2007-2008) of the Finance Division. During his term in the above-mentioned Departments,

he gained experience in dealing with various projects regarding, among others, power plants’ operation

and environmental affairs, as well as fuels’ purchasing and management (lignite, coal, oil and natural

gas). In May 2008 he was appointed Director of Generation Planning and Performance Department,

vested with a series of competencies, ranging from the development of Generation's Strategic and

Business Plan, the Units’ operational planning up to the monitoring of their operational and financial

efficiency. In January 2017 he assumed the duties of Chief Generation Officer and in November 2019

those of Chief Lignite Generation Officer. Prior to joining PPC he worked in the pharmaceutical

industry. Mr. Metikanis holds a diploma in Chemical Engineering from the National Technical University

of Athens (NTUA), as well as an MBA degree.

Karagiannis Fotios, Chief Thermal and Hydro Generation Officer

Mr. Fotios Karagiannis is a Mechanical Engineer of the National Technical University of Athens (1982)

and holds two Msc degrees from the Ecole Nationale Supérieure de l’Aéronautique et de l’Espace

(E.N.S.A.E.) in Toulouse, France. In 1987 he obtained the Doctorat de l'E.N.S.A.E. (grade "Très

honorable"). After that, he worked for 5 years as a post-doc Researcher in the Laboratory of Thermal

Turbomachinery of the National Technical University of Athens. In 1992 he joined the PPC, where he held

various managerial positions. On December of 2006 he was appointed as Director of the CEO’s Office

and then as Director of the Hydroelectric Projects Development Department. In 2008 he was appointed

as Director of the Thermal Projects Engineering and Construction Department. In 2017, he was appointed

as Director of the Business Development Implementation Department and then as Director of the New

Products & Services Development & Promotion Department. In 2019 he was appointed as Director of the

Support of Generation Business Department, while in February 2020 he was appointed to the position of

Chief Thermal and Hydro Generation Officer.

Zagalikis Konstantinos, Chief Digital Systems Development and Operations Officer

Mr. Konstantinos Zagalikis has many years of experience in the field of consulting and IT services, with

particular emphasis on digital transformation. He has held important managerial positions in Vodafone

and IBM Hellas. Following that, he moved to Printec Group where he was responsible for the technological

implementation of solutions in Greece and Southeast Europe, while later on, he was appointed as CIO in

Forthnet- Nova. He held one of the leading parts in the transformation of information systems (BSS-OSS)

in Huawei, for DU Telecommunications in Dubai. Until recently he held the post of Operations Director in

Tech Mahindra, where he was responsible for the cloud transformation of the existing infrastructure for

Celcom Telecommunications in Malaysia. He holds a B.Eng. in Computer Systems Engineering from the

University of Sussex in the UK and a M.Sc. in Telecommunications and Information Systems from the

University of Essex in the UK.

Kofinas Kyriakos, Chief E–Mobility Officer

Mr. Kyriakos Kofinas has 30 years of executive experience in Europe, Middle East, Africa and Asia. He

held positions as Regional CEO, Chief Officer, Principal and as Head Coach in the sectors of FMCG,

Medical, Retail, Luxury, Executive Search, and in e-Mobility. He holds a BA in Economics from the

University of Athens, an ΜΒΑ from the Manchester Business School and an MSc in E-Commerce from

the Athens University of Economics and Business. He is also a certified Executive & Business Coach.

162

Nazos Konstantinos, Chief Energy Management and Trading Officer

Mr. Mr. Konstantinos Nazos was appointed as Chief Energy Management & Trading Officer on December

17, 2020. He joined PPC S.A. in 2004 and since then, he has been working in the Department of Energy

Management & Trading acquiring significant experience in the whole spectrum of energy management

activities, with significant specialization in the areas of electricity markets analysis and modelling, bidding

strategies analysis, optimization and risk management of complex energy portfolios and cross-border

electricity trading. From July 2010, and for eight years, he served as Head of the Market Analysis Section

and then he was promoted to the position of Assistant Director of Market Analysis Unit. In June 2020 he

was appointed as Assistant Director of the Department of Energy Management & Trading, having among

others the responsibility for managing the Department’s transformation towards the transition of the Greek

electricity market to the EU Target Model. In 2016, along with his duties in PPC, he was a member of the

Board of Directors of the Insurance Fund for Bank and Utility Companies Employees (TAYTEKO), as

representative of the employers, on behalf of the Company. Additionally, he was actively engaged in the

establishment of the subsidiary company PPC Albania, in which he took the role of Executive Director and

Vice Chair of the Board, from 2016 to 2019. Before joining PPC S.A., he worked for 7 years as production

and maintenance engineer in the aluminium rolling industry and in the home appliances industry, thus

acquiring significant industrial and construction-site experience. Mr. Konstantinos Nazos holds a diploma

in Mechanical Engineering from the National Technical University of Athens (1994), as well as an MBA

degree (Executive MBA) from Athens University of Economics and Business.

Mentzos Vassilis, Chief Project & Customer Experience Officer

Mr. Vassilis Mentzos is a PMO executive and business transformation expert with international experience

in leading and managing major complex projects. During his 20-year career, he has held roles of increased

responsibility mainly in telecom operators (Wind Hellas & Vodafone UK) where he led their network

development activities. From 2018 to 2020 he led the 5G Network Deployment Programme for Vodafone

UK in London. Until recently he held the position of the PMO Director for all commercial activities at PPC.

He holds a Diploma (MEng) in Civil Engineering from the Polytechnic School of the Democritus University

of Thrace.

Spanos Aggelos, Chief Marketing and Products Officer

Mr. Angelos Spanos is an executive with more than 25 years of experience in Product Marketing, New

Business development, customer experience, project & demand management, budget management and

Technology. He served in positions of responsibility abroad (Vodafone Albania), as well as in Greece

(Vodafone Greece), with more than 15 years in management positions and being responsible for major

projects, products and corporate transformation processes. From April 2020 to April 2021, he served as

Director of Marketing & Pricing Policy at PPC and subsequently as Chief Marketing & Products Officer

(including Pricing Policy and New Commercial Activities). He holds a BSc in Physics and a

Telecommunications MSc from the National and Kapodistrian University of Athens (NKUA), while being

awarded multiple additional certifications (Business Administration from AUEB, PRINCE II project

management Practitioner, crisis & change management etc).

163

2. Shares held by the senior executives of the Company

The following table lists the number of shares held by the Company's Executive Officers on 31.12.2022

in accordance with par. 3 article 18 of par. 3 of Law 4706/2020

Name of Executive Officer

Position in the Company

Number of

Shares owned at

31.12.2022

Ioannis Kopanakis

Deputy CEO of Production

Operations

Argyris Economou

General Counsel and

Chief Legal Affairs and

Corporate Governance

Officer

Zorzeta Christodoulopoulou

Chief Support Operations

Officer

209

Sotiris Hadjimichael

Chief Strategy &

Transformation Officer

Konstantinos Zagalikis

Chief Digital Systems

Development and

Operations Officer

Konstantinos Nazos

Chief Energy Management

& Trading Officer

234

Kyriakos Kofinas

Chief E–Mobility Officer

Konstantinos Alexandridis

Chief Financial Officer

4,000

Alina Papageorgiou

Chief Human Resources &

Organization Officer

George Damaskos

Chief E–Mobility Officer

Nikolaos Aravantinos

Chief Support Operations

Officer

2,464

Dimitrios Metikanis

Chief Officer of Lignite

Generation Business Unit

567

Fotios Karagiannis

Chief Thermal and Hydro

Generation Officer

Efthymia Bali

Chief Sales Officer

Ioannis Tsagiannis

Chief Customer

Management Officer

Aggelos Spanos

Chief Marketing and

Products Officer

Vasilis Mentzos

Chief Project & Customer

Experience Officer

Note:

The term of office of Messrs. Ioannis Kopanakis, Nikolaos Aravantinos, Fotios Karagiannis has been expired by the

date of publication of this Statement.

164

APENDIX

Definitions and reconciliations of Alternative Performance Measures (“APMs”)

ALTERNATIVE PERFORMANCE MEASURES (“APMs”)

The Group and the Parent Company use Alternative Performance Measures («APMs") in taking decisions

concerning their financial, operational and strategic planning, as well as for the evaluation and publication

of their performance. These APMs serve to better understand the financial and operating results of the

Group and the Parent Company, their financial position and cash flows. Alternative indicators (APMs)

should always be read in conjunction with the financial results that have been prepared in accordance

with IFRS and in no way replace them.

Alternative Performance Measures (“APMs”)

In discussing the Group’s and the Parent Company’s performance, “Adjusted” measures are used such

as: EBITDA Recurring without one off effects and EBITDA Recurring margin % without one off effects as

well as Profit / (Loss) without one-off effects. These adjusted measures are calculated by deducting from

performance measures directly derived from amounts of the annual Financial Statement the effect and

costs arising from events which have occurred during the reporting period and which have not affected

the amounts of previous periods.

EBITDA (Operating Income before depreciation, amortization and impairment, net financial

expenses and taxes).

EBITDA serves to better analyze the operating results of the Group and the Parent Company and is

calculated as follows: Total turnover minus total operating expenses before depreciation and impairment.

The EBITDA margin (%) is calculated by dividing EBITDA by total turnover. Calculation of EBITDA and

EBITDA margin is presented in Table A.

Operating Expenditure before tax, depreciation, amortization net financial expenses, profit/(loss)

from sale of related companies and taxes excluding one off effects

This measure is calculated by subtracting the one-off effects mentioned in the EBITDA Recurring note

below, from the EBITDA measure. It is presented in Table B.

EBITDA Recurring (Operating Income before depreciation, amortization and impairment, net

financial expenses and taxes, excluding one off effects)

EBITDA Recurring serves to better analyze the Group's and the Parent Company’s operating income,

excluding the impact of one-off effects. For the year 2022, the one-off effects that affected EBITDA

Recurring are as follows : a) a provision for allowance for employees’ severance payments amounting to

€ 50,476 thousand for the Group and € 49,194 thousand for the Parent Company (negative impact), b)

an extraordinary levy for electricity producers amounting to €245,322 thousand for the Group and the

Parent Company (negative impact) and c) a retroactive charge due to the recovery of special allowances

from the implementation of the Collecctive Labour Agreement 2021-2024 amounting to € 6,593 thousand

for the Group and the Parent Company (negative effect). EBITDA Recurring Margin (%) is measured by

dividing EBITDA Recurring by Total Turnover. EBITDA Recurring and EBITDA Recurring margin are

presented in Table C.

EBIT (Operating Income before net financial expenses and taxes)

EBIT serves to better analyze the Group’s and the Parent Company’s operating results and is calculated

as follows: EBITDA (Operating Income before depreciation and impairment, net financial expenses and

taxes) less depreciation and impairment. EBIT margin (%) is calculated by dividing EBIT with total

turnover. Calculation of EBIT and EBIT margin is presented in Table D.

165

Net amount of Depreciation, Financial Expense and Profit from Associates.

This Index is calculated as the net amount of depreciation expense, net financial expenses and profits/

(losses) from the Group's associates. The detailed calculation is presented in Table E.

Net Debt

Net debt is an APM that Management uses to evaluate the capital structure of the Group and the Parent

Company as well as leverage. Net debt is calculated by adding long-term loans, the current portion of

long term loans and short term loans and subtracting from the total, cash and cash equivalents, restricted

cash related to loan agreements and financial assets measured at fair value through other comprehensive

income and adding the unamortized portion of borrowing costs. Calculation of Net Debt is presented in

Table F.

166

TABLE A - EBITDA (Operating Income before depreciation, amortization and impairment, net financial expenses and taxes)

Total Group

01.01-31.12.2022

Total Group

01.01-31.12.2021

Total Group

01.10-31.12.2022

Total Group

01.10-31.12.2021

Amounts in ‘000€

Total Turnover (1)

11,253,107

5,706,391

2,690,356

2,008,848

less :

Operating expenses before depreciation and impairment (2)

10,601,815

4,885,334

2,407,264

1,764,622

Payroll cost

768,554

730,371

236,291

198,103

Lignite

16,216

41,104

(922)

(1,294)

Liquid Fuels

853,239

537,003

216,624

126,779

Natural Gas

1,758,161

910,068

370,060

457,334

Energy purchases

4,720,240

1,286,722

1,106,488

552,739

Materials and consumables

121,547

121,643

31,204

26,802

Transmission system usage

143,321

129,257

41,821

32,696

Distribution system usage

Utilities and maintenance

210,920

180,212

63,552

42,313

Third party fees

184,403

141,812

71,082

36,102

CO2 emission rights

1,037,545

699,164

185,849

159,721

Risk allowances

(16,653)

88,847

(4,135)

41,976

Provisions for impairment of materials

(6,801)

25,762

(10,435)

5,929

Provisions for bad debt

207,526

(59,740)

21,425

89,976

Extraordinary levy of electricity producers

245,322

(30,726)

Other Losses / (Gains), Net

358,275

53,109

109,086

(4,554)

EBITDA (Α) = [(1) - (2)]

651,292

821,057

283,092

244,226

EBITDA MARGIN [(Α) / (1)]

5.8%

14.4%

10.5%

12.2%

167

TABLE A - EBITDA (Operating Income before depreciation, amortization and impairment, net financial expenses and taxes)

Total Company

01.01-31.12.2022

Total Company

01.01-31.12.2021

Total Company

01.10-31.12.2022

Total Company

01.10-31.12.2021

Amounts in ‘000€

Total Turnover (1)

10,847,079

5,399,475

2,586,587

1,923,538

less :

Operating expenses before depreciation and impairment (2)

10,582,824

4,583,957

2,397,541

1,672,689

Payroll cost

480,782

412,094

169,693

109,900

Lignite

14,657

21,323

(923)

(335)

Liquid Fuels

850,141

530,825

216,624

123,999

Natural Gas

1,758,161

910,068

370,060

457,334

Energy purchases

4,883,818

1,487,577

1,108,965

604,898

Materials and consumables

92,161

71,650

24,402

14,584

Transmission system usage

143,321

129,257

41,821

32,696

Distribution system usage

429,551

220,588

97,192

68,839

Utilities and maintenance

135,940

109,651

43,800

28,911

Third party fees

116,185

89,035

47,820

20,153

CO2 emission rights

963,855

573,793

185,846

138,364

Risk allowances

5,796

105,430

12,299

65,975

Provisions for impairment of materials

1,168

24,272

(697)

7,267

Provisions for bad debt

161,662

(108,938)

21,586

15,495

Extraordinary levy of electricity producers

245,322

(30,726)

Other Losses / (Gains), Net

300,304

7,332

89,776

(15,391)

EBITDA (Α) = [(1) - (2)]

264,255

815,518

189,046

250,849

EBITDA MARGIN [(Α) / (1)]

2.4%

15.1%

7.3%

13.0%

168

TABLE B- Operating Expenditure before tax, depreciation and impairment, net financial expenses, profit/(loss) from sale

of related companies and taxes excluding one off effects

Total Group

01.01-31.12.2022

Total Group

01.01-31.12.2021

Total Group

01.10-31.12.2022

Total Group

01.10-31.12.2021

Notes

Amounts in ‘000€

Operating expenses before depreciation and

impairment (2)

10,601,815

4,885,334

2,407,264

1,764,622

less :

Provision for allowance for employees’ severance

payments

50,476

16,075

50,476

1,154

Note 7, 31 of the Annual

Financial Report 2022

Retroactive charge due to recovery of special

allowances from the implementation of the Collective

Labour Agreement 2021-2024

6,593

34,555

6,593

(101)

Note 7, 31 of the Annual

Financial Report 2022

Extraordinary levy of electricity producers

245,322

(30,726)

Note 2 of the Annual

Financial Report 2022

Operating expenses before depreciation and

impairment without one-off effects (2)

10,299,424

4,834,704

2,380,921

1,763,569

TABLE B- Operating Expenditure before tax, depreciation and impairment, net financial expenses, profit/(loss) from sale of related companies

and taxes excluding one off effects

Total Company

01.01-31.12.2022

Total Company

01.01-31.12.2021

Total Company

01.10-31.12.2022

Total Company

01.10-31.12.2021

Notes

Amounts in ‘000€

Operating expenses before depreciation and

impairment (2)

10,582,824

4,583,957

2,397,541

1,672,689

less :

Provision for allowance for employees’ severance

payments

49,194

13,591

49,194

1,700

Note 7, 31 of the

Annual Financial

Report 2022

Retroactive charge due to recovery of special

allowances from the implementation of the Collective

Labour Agreement 2021-2024

6,593

22,074

6,593

(104)

Note 7, 31 of the

Annual Financial

Report 2022

Extraordinary levy of electricity producers

245,322

(30,726)

Note 2 of the Annual

Financial Report 2022

Operating expenses before depreciation and

impairment without one-off effects (2)

10,281,715

4,548,292

2,372,480

1,671,093

169

TABLE C- EBITDA Recurring (Operating Income before depreciation and impairment, net financial expenses and taxes exluding one-off effects).

Total Group

01.01-31.12.2022

Total Group

01.01-31.12.2021

Total Group

01.10-31.12.2022

Total Group

01.10-31.12.2021

Notes

Amounts in ‘000€

EBITDA (1)

651,292

821,057

283,092

244,226

Plus one-of effects (2):

302,391

50,630

26,343

1,053

Provision for allowance for employees’ severance

payments

50,476

16,075

50,476

1,154

Note 7, 31 of the Annual

Financial Report 2022

Retroactive charge due to recovery of special

allowances from the implementation of the

Collecctive Labour Agreement 2021-2024

6,593

34,555

6,593

(101)

Note 7, 31 of the Annual

Financial Report 2022

Extraordinary levy of electricity producers

245,322

(30,726)

Note 2 of the Annual

Financial Report 2022

EBITDA RECURRING EXLUDING ONE-OFF

EFFECTS (3) = [(1)+(2)]

953,683

871,687

309,435

245,279

TOTAL TURNOVER (4)

11,253,107

5,706,391

2,690,356

2,008,848

EBITDA RECURRING MARGIN EXLUDING

ONE-OFF EFFECTS (3)/(4)

8.5%

15.3%

11.5%

12.2%

170

TABLE C- EBITDA Recurring (Operating Income before depreciation and impairment, net financial expenses and taxes exluding one-off effects).

Total Company

01.01-31.12.2022

Total Company

01.01-31.12.2021

Total Company

01.10-31.12.2022

Total Company

01.10-31.12.2021

Notes

Amounts in ‘000€

EBITDA (1)

264,255

815,518

189,046

250,849

Plus one-of effects (2):

301,109

35,665

25,061

1,596

Provision for allowance for employees’

severance payments

49,194

13,591

49,194

1,700

Note 7, 31 of the Annual

Financial Report 2022

Retroactive charge due to recovery of special

allowances from the implementation of the

Collecctive Labour Agreement 2021-2024

6,593

22,074

6,593

(104)

Note 7, 31 of the Annual

Financial Report 2022

Extraordinary levy of electricity producers

245,322

(30,726)

Note 2 of the Annual

Financial Report 2022

EBITDA RECURRING EXLUDING ONE-OFF

EFFECTS (3) = [(1)+(2)]

565,364

851,183

214,107

252,445

TOTAL TURNOVER (4)

10,847,079

5,399,475

2,586,587

1,923,538

EBITDA RECURRING MARGIN EXLUDING

ONE-OFF EFFECTS (3)/(4)

5.2%

15.8%

8.3%

13.1%

171

Table D - EBIT (Operating Income before net financial expenses and taxes)

Total Group

01.01-31.12.2022

Total Group

01.01-31.12.2021

Total Group

01.10-31.12.2022

Total Group

01.10-31.12.2021

Amounts in ‘000€

Ποσά σε ‘000€

EBITDA

651,292

821,057

283,092

244,226

less :

Depreciation and Amortization

640,380

666,248

136,334

166,690

Impairement of Property, Plant and Equipment

(197,675)

107,575

(55,622)

75,795

Impairment of lignite subsidiaries’

ΕΒΙΤ (Α)

208,587

47,234

202,380

1,741

Total turnover (1)

11,253,107

5,706,391

2,690,356

2,008,848

EBIT MARGIN [(Α) / (1)]

1.9%

0.8%

7.5%

0.1%

Table D - EBIT (Operating Income before net financial expenses and taxes)

Total Company

01.01-31.12.2022

Total Company

01.01-31.12.2021

Total Company

01.10-31.12.2022

Total Company

01.10-31.12.2021

Amounts in ‘000€

EBITDA

264,255

815,518

189,046

250,849

less :

Depreciation and Amortization

306,147

346,923

52,898

85,566

Impairement of Property, Plant and Equipment

(199,966)

78,675

(57,913)

46,895

Impairment of lignite subsidiaries’

88,000

ΕΒΙΤ (Α)

158,074

301,920

194,061

118,388

Total turnover (1)

10,847,079

5,399,475

2,586,587

1,923,538

EBIT MARGIN [(Α) / (1)]

1.5%

5.6%

7.5%

6.2%

172

Table E - Net amount of Depreciation, Financial Expense and Profit from Associates

Total Group

01.01-31.12.2022

Total Group

01.01-31.12.2021

Total Group

01.10-31.12.2022

Total Group

01.10-31.12.2021

Amounts in ‘000€

Ποσά σε ‘000€

DEPRECIATION, NET FINANCIAL EXPENSE AND

PROFIT FROM ASSOCIATES

874,963

863,304

213,645

233,261

Depreciation and Amortization

640,380

666,248

136,334

166,690

Financial expense

344,451

259,541

90,434

78,394

Financial income

(55,464)

(59,294)

(12,925)

(12,202)

Net (profit)/loss from associates

(61,677)

(4,350)

(1,082)

(1,552)

Net loss/(profit) from FX differences

7,273

1,159

884

1,931

Table E - Net amount of Depreciation, Financial Expense and Profit from Associates

Total Company

01.01-31.12.2022

Total Company

01.01-31.12.2021

Total Company

01.10-31.12.2022

Total Company

01.10-31.12.2021

Amounts in ‘000€

DEPRECIATION, NET FINANCIAL EXPENSE AND

PROFIT FROM ASSOCIATES

511,346

534,790

117,112

149,298

Depreciation and Amortization

306,147

346,923

52,898

85,566

Financial expense

283,895

251,963

74,054

73,725

Financial income

(86,045)

(65,222)

(10,809)

(11,969)

Net (profit)/loss from associates

Net loss/(profit) from FX differences

7,349

1,126

969

1,976

173

TABLE F – NET DEBT

GROUP

COMPANY

Amounts in ‘000€

31.12.2022

32.12.2021

31.12.2022

31.12.2021

Long-term borrowing

3,822,907

4,062,638

2,496,509

2,723,954

Current portion of long term borrowing

591,894

353,632

357,662

207,051

Short term borrowing

108,333

271,337

50,000

260,000

Cash and cash equivalents

(3,159,484)

(2,832,351)

(2,760,552)

(2,512,204)

Restricted cash

(50,843)

(53,323)

(23,008)

(35,754)

Financial assets measured at fair value

through other comprehensive income

(330)

(327)

(329)

(325)

Unamortized portion of borrowing costs

75,666

88,166

74,017

88,166

TOTAL

1,388,143

1,889,772

194,299

730,888

Athens, March 23

2023

For the Board of Directors

The President and CEO

The Vice President

Georgios I. Stassis

Pyrros D. Papadimitriou

174

This page is left blank intentionally

175

C. AUDITOR’S REPORT

176

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

THIS REPORT IS A FREE TRANSLATION FROM THE GREEK ORIGINAL

INDEPENDENT AUDITOR’S REPORT

To the Shareholders of Public Power Corporation 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 Public Power Corporation S.A. (“the

Company”), which comprise the separate and consolidated statement of financial position as of December 31, 2022, the

separate and consolidated statements of income and other comprehensive income, the statements of changes in equity and

cash flows for the year then ended and a summary of significant accounting policies and other explanatory information.

In our opinion, the accompanying separate and consolidated financial statements present fairly in all material respects the

financial position of Public Power Corporation S.A., and its subsidiaries (“the Group”) as at December 31, 2022 and their

financial performance and cash flows for the year then ended in accordance with International Financial Reporting Standards,

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 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.

177

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

Key audit matter

How our audit addressed the key audit matter

Unbilled revenue recognition and related contract assets from low tension customers (separate and consolidated financial

statements)

The Company’s and the Group’s unbilled revenue for the

year ended December 31, 2022 and the related contract

assets from low tension customers as at December 31,

2022 amounted to €590mil.

The estimation method used, requires the management

to make judgments and use estimates and assumptions

with a high degree of uncertainty, of which the most

significant are related to the technical and non-technical

losses of the distribution network, the invoicing period,

the average revenue and the adjustments for discounts

and expected credit losses.

We have identified the estimation process of the unbilled

revenue and the related contract assets from low tension

customers as one of the key audit matters due to the

inherent risk of revenue recognition in the correct

period, the significant audit effort required, and the high

degree of subjectivity in the management’s judgments,

estimates and assumptions used in this process.

The Company’s and Group’s disclosures relevant to the

accounting policy, the judgments, the estimates and the

assumptions used to determine the unbilled revenue and

the related contract assets from low tension customers

can be found in notes 4.3, 4.4, 6 and 22 to the separate

and consolidated financial statements.

The audit procedures that we performed, among others were as

follows:

- We discussed with management and assessed the design of

internal controls over the estimation of the unbilled

revenue and the related contract assets from low tension

customers.

- We received and audited the calculation of the

management’s estimate, evaluating the judgments,

estimates and assumptions related to the technical and

non-technical losses of the distribution network, the

invoicing period, the average revenue and the adjustments

for discounts and expected credit losses.

- We assessed the consistency of application of the

estimation, the methods, the assumptions, and the

calculations used between periods and whether events of

the current year that alter the environment, the

circumstances and data, in which the estimates and

assumptions used by the management are based, have

been taken into consideration, as well as changes in the

business practices, the accounting principles and policies

affecting the related calculations.

- We tested the calculations for mathematical accuracy and

the correct accounting of the related amounts in the

financial statements.

- Finally, we assessed the adequacy and appropriateness of

related disclosures in the separate and consolidated

financial statements.

178

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

Key audit matter

How our audit addressed the key audit matter

Trade receivables impairment test (separate and consolidated financial statements)

At December 31, 2022, the Company’s and the Group’s

trade receivables amounted to €1,201mil and €1.366mil.,

after accumulated impairment losses of €2.380mil. and

€2.500mil., respectively.

The audit procedures that we performed, among others were as

follows:

- We discussed with management and assessed the design

of internal controls over the impairment process of trade

receivables impairment test.

Key audit matter

How our audit addressed the key audit matter

Trade receivables impairment test (separate and consolidated financial statements) (continue)

The Company and Group apply the simplified approach of

IFRS 9 “Financial Instruments” and determine lifetime

expected credit losses (“ELC”) on their trade receivables by

using historical information, including the current

economic conditions, which reflect the expected effect of

current information in future.

We have identified the process of trade receivables

impairment test as a key audit matter due to the

magnitude of the related accounts and the significance of

management’s assumptions and estimates used.

The Company’s and Group’s disclosures relevant to the

accounting policy, the judgements, the estimates and the

assumptions used for the impairment test of trade

receivables can be found in notes 4.3, 4.4 and 21 to the

separate and consolidated financial statements.

- We received and audited the calculation of trade

receivables impairment performed by management,

evaluating, among others, the completeness and

accuracy of the data used for the determination of

expected credit losses and the assumptions on which

the management’s estimation was based.

- We tested the calculations for mathematical accuracy

and the accounting treatment of the related amounts in

the separate and consolidated financial statements.

- Finally, we assessed the adequacy and appropriateness

of related disclosures in the separate and consolidated

financial statements.

Key audit matter

How our audit addressed the key audit matter

Valuation of Property, Plant and Equipment (separate and consolidated financial statements)

At December 31, 2022 Company’s and Group’s property,

plant and equipment amounted to €5.210mil. and

€10.551mil., respectively.

Property, plant and equipment are measured at revalued

amounts (fair values less accumulated depreciation and

impairment loss), except for the mines and lakes that are

measured at cost (less accumulated depreciation and

impairment) and property, plant and equipment under

The audit procedures that we performed, among others were as

follows:

- We discussed with management and assessed the design of

management controls over the evaluation process of

whether the fair values of the property, plant and equipment

have changed significantly, and impairment indications or

179

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

construction, that are measured at cost (less

accumulated impairment loss).

The fair values of property, plant and equipment that are

measured at revalued amounts, are determined by

independent appraisers periodically, in order to assure

that the carrying value of an asset does not differ

significantly from its fair value. The last revaluation was

performed as in 2019.

indications of reversal of an impairment loss recognised in

prior periods exist for the property, plant and equipment.

- For property, plant and equipment that are measured at fair

values, we evaluated the management’s assessment on

whether their fair values remain unchanged.

- For property, plant and equipment that are measured at

cost, we assessed the management’s evaluation on whether

there were indications of impairment or indications of

reversal of impairment loss recognised in prior periods.

Key audit matter

How our audit addressed the key audit matter

Valuation of Property, Plant and Equipment (separate and consolidated financial statements) (continue)

The determination of the fair values of property, plant

and equipment requires the management to make,

among others, estimations, assumptions and judgements

regarding the ownership, the use and the existence of

any physical, operational and economic obsolescence.

In addition to the above, the Company and the Group

assess annually whether impairment loss indications or

indications of reversal of an impairment loss recognised

in prior periods exist and if this is the case, estimate the

recoverable amount of the related property, plant and

equipment.

This process incorporates judgements, estimates and

assumptions with high degree of subjectivity, the most

important of which are related to the estimated future

production capacity and use of the property, plant and

equipment, the determination of the cash generating

unit on which the estimation of the recoverable amount

of the property, plant and equipment will be performed,

their discounted future cash flows and other factors.

In the context of the process for the assessment of

impairment loss indications and indications of reversal of

an impairment loss recognised in prior periods and taking

also into consideration the requirements of the updated

lignite phase-out plan, management estimated the

recoverable amount of the related property, plant and

equipment, which resulted in an impairment loss of

€3mil. and €5mil. for the Company and the Group,

respectively, as well as a reversal of impairment loss

recognised in prior periods of €178mil. for the Company

and the Group, which were recognised in the current

year’s separate and consolidated statements of income,

respectively.

- For property, plant and equipment that are measured at

cost, and for which impairment indications or indications of

reversal of impairment loss recognised in prior periods

existed, we assessed with the contribution, where

necessary, of EY valuation specialists, the reasonability and

accuracy of the assumptions and methodology used in

estimating the recoverable amounts.

- We tested the calculations for mathematical accuracy and

the correct accounting treatment of the related amounts in

the separate and consolidated financial statements.

- Finally, we assessed the adequacy and appropriateness of

the related disclosures in the separate and consolidated

financial statements.

180

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

We have identified the valuation of property, plant and

equipment as a key audit matter due to magnitude of the

related accounts and the significance of management’s

judgments, estimates and assumptions on which is

based.

Key audit matter

How our audit addressed the key audit matter

Valuation of Property, Plant and Equipment (separate and consolidated financial statements) (continue)

The Company’s and Group’s disclosures relevant to the

accounting policy, the judgments, the estimates and the

assumptions used for the valuation in fair values and the

assessment of impairment loss indications and

indications of reversal of an impairment loss recognised

in prior periods for the property, plant and equipment

can be found in notes 4.3, 4.4, 15 and 35 to the separate

and consolidated financial statements.

Key audit matter

How our audit addressed the key audit matter

Accounting treatment of the sale of 49% of investment in HEDNO and NCI put option (separate and consolidated financial

statements)

On February 2022, the Company signed an agreement

with MSCIF Dynami BidCo Single Member S.A.(«MSCIF»)

for the transfer of 49% of its investment to the subsidiary

company Hellenic Distribution Network Operator

(«HEDNO») with a carrying amount of € €526mil. for a

cash consideration of €1.323mil.

In the separate financial statements , the difference of

€790mil. between the carrying amount and the cash

consideration, including the transaction costs, was

presented as Gain from partial sale of subsidiary in this

year’s statement of income in accordance with IAS 27

“Separate Financial Statements”.

In the consolidated financial statements, changes in

parent’s ownership interest in a subsidiary that do not

result in the parent losing control of the subsidiary, are

equity transactions in accordance with IFRS 10

“Consolidated Financial Statements”. Hence, at the date

of the sale, the Company recognised in the consolidated

statement of financial position non-controlling (“NCI”)

interests amounted to €637mil., which corresponded to

The audit procedures that we performed, among others were as

follows:

- We received the valuation report of NCI put option (which

was recognised in the consolidated financial statements)

and the related derivative financial instrument (which was

recognised in the separate financial statements) from an

independent appraiser and assessed with the contribution

of EY valuation specialists, the methodology used, as well as

the reasonability and accuracy of the assumptions used.

- We evaluated the competence, capabilities and objectivity

of the independent appraiser to whom the management

engage the valuation of the financial liability and the related

derivative financial instrument.

- We evaluated with the contribution of EY specialists, the

correctness of the accounting treatment of the sale

181

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

49% of the net assets of HEDNO. As the sale of 49% of

investment in HEDNO, did not affect the control of the

Company, the difference of €679mil. between the

carrying amount of NCI interests and the cash

consideration was recognised directly in the Group’s

equity,

transaction and the NCI put option in the separate and

consolidated financial statements, in accordance with the

provisions of IFRS.

- We have evaluated the adequacy and the appropriateness

of the related disclosures in the separate and consolidated

financial statements.

Key audit matter

How our audit addressed the key audit matter

Accounting treatment of the sale of 49% of investment in HEDNO and NCI put option (separate and consolidated financial

statements) (continue)

The agreement also includes a put option for the sale of

the shares acquired by MSCIF after 8 years and within 6

months from the date of the sale, with an exercise price

equal to the then fair value of the shares.

In the separate financial statements, the put option is

accounted as a derivative financial instrument with an

exercise price equal to the fair value of the share and

therefore his value was determined to be nil.

In the consolidated financial statements, the financial

liability of the NCI put option is initially recognised in the

present value of the estimated exercise price. Based on

the valuation conducted, the Company recognised a

financial liability of €1,411mil, in the consolidated

statement of financial position with a corresponding

debit in the equity and reserves.

In the consolidated financial statements, the financial

liability is subsequently remeasured at amortised cost. As

at December 31, 2022, the financial liability increased by

the amount of the financial cost and amounted to

€1.420mil., while the respective change was recognised

in the financial expenses in the consolidated statement

of income.

We have identified the accounting treatment of the sale

of 49% of investment in HEDNO and NCI put option as a

key audit matter due to magnitude of the related

accounts and the significance of management’s

judgments in relation to the estimation of future cash

flows and discount rate

The Company’s and the Group’s disclosures relevant to

the accounting policy, the judgments, the estimates and

the assumptions used for the accounting treatment of

the sale of 49% of the investment in HEDNO and the NCI

put option can be found in notes 4.1, 4.2 and 5, of the

separate and consolidated financial statements.

182

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

Other information

Management is responsible for the other information in the Annual 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 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 the 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 (Law 44 ν.4449/2017) is responsible for overseeing the Company’s and the Group’s financial

reporting process.

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.

183

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

• 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.

• Obtain sufficient appropriate audit evidence regarding the financial information of the entities or business activities

within the Group to express an opinion on the separate and consolidated financial statements. We are responsible

for the direction, supervision and performance of the Company and its subsidiaries. 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.

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 Corporate

Governance Statement that is included therein, according to the provisions of paragraph 5 article 2 of Law 4336/2015 (part

B), 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 150-151 and 153-154 and paragraph 1 (c and d) of article 152 of Law 4548/2018 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, 2022.

c) Based on the knowledge and understanding concerning Public Power Corporation S.A. and its environment,

obtained during our audit, we have not identified information included in the Board of Directors’ Report that

contains a material misstatement.

184

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

2. Unbundled Financial Statements

The management is responsible for the preparation of the Company’s and the Group’s unbundled financial statements as

required by the article 141 of Law 4001/2011 and the Decision 266/2014 of the Regulatory Authority for Energy (RAE) and

for those internal controls that management determines are necessary to enable the preparation of the Company’s and

Group’s unbundled balance sheets as at December 31, 2022 and the unbundled statements of income before tax for the

period from January 1, 2022 to December 31, 2022 that are free from material misstatement, whether due to fraud or error.

The methodology of preparation of the unbundled financial statements is described in note 2 of appendix 1 to the financial

statements.

In our opinion, the Company’s and Group’s unbundled financial statements as at December 31, 2022, as presented in the

relevant appendix to the separate and consolidated financial statements, have been prepared in accordance with the

provisions of article 141 of Law 4001 / 2011 and the Decision 266/2014 of the Regulatory Authority for Energy (RAE).

3. 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.

4. Provision of Non-audit Services

We have not provided any prohibited non-audit services per article 5 of the EU Regulation 537/2014.

Non-audit services provided by us to the Company and its subsidiaries during the year ended December 31, 2022, are

disclosed in Note 13 of the separate and consolidated financial statements.

5. Appointment of the Auditor

We were firstly appointed as auditors of the Group by the General Assembly on June 7, 2018. Our appointment has been

uninterruptedly renewed annually by virtue of decisions of the annual general meetings of the shareholders for a total period

of four years.

6. 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

7. Reasonable Assurance report on the European Single Electronic Format

We have examined the digital files of the company Public Power Corporation S.A. ( hereafter “Company” and “Group”)

prepared in accordance with the European Single Electronic Format (“ESEF”) as defined in the EU Delegated Regulation

2019/815, as amended by the EU Delegated Regulation 2020/1989 of the European Commission (hereinafter referred to as

“the ESEF Regulation”), that comprise an XHTML file “"213800T9Y5XCOVRZ4Y57-2022-12-31.xhtml” which includes the

separate and consolidated financial statements of the Company and the Group for the year ended December 31, 2022, and

an XBRL file “213800T9Y5XCOVRZ4Y57-2022-12-31-en.zip” with appropriate tagging of the aforementioned consolidated

financial statements, including the explanatory notes (Notes to the financial statements).

185

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

Regulatory Framework

The digital files of the European Single Electronic Format are prepared in accordance with 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

(hereinafter referred to as the "ESEF Regulatory Framework"). This Framework provides, 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 in the statement of income, the statement of other comprehensive income, the statement of financial

position, the statement of changes of equity and the statement of cash flows, as well as the financial information included in

the explanatory noted, should be marked-up (XBRL tags and block tags), 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.

The requirements set out in the ESEF Regulatory Framework provide appropriate criteria for us to express a reasonable

assurance conclusion.

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 for the year ended December 31, 2022, in accordance with the requirements set out in the ESEF Regulatory

Framework, and for such internal control as management determines is necessary to enable the preparation of the digital

files that is free from material misstatement, whether due to fraud or error.

Auditor’s Responsibilities

Our responsibility is to plan and perform this assurance engagement in accordance with 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 February 14, 2022

(hereinafter referred to as “ESEF Guiding Instructions”), in order to obtain reasonable assurance that the separate and

consolidated financial statements prepared by management in accordance with ESEF comply, in all material respects, with

the ESEF Regulatory Framework.

Our work was performed in accordance with the International Ethics Standards Board for Accountants’ Code of Ethics for

Professional Accountants (IESBA Code), as incorporated in Greek Law, and we have fulfilled our other ethical independence

responsibilities in accordance with Law 4449/2017 and the EU Regulation 537/2014.

The assurance engagement we performed, in accordance with the International Standard on Assurance Engagements 3000,

"Assurance Engagements Other Than an Audit or Review of Historical Financial Information", is limited to the objectives

included in the ESEF Guiding Instructions. Reasonable assurance is a high level of assurance, but it is not a guarantee that this

reasonable assurance engagement will always detect a material misstatement with respect to non-compliance with the

requirements of the ESEF Regulatory Framework when it exists.

186

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: +30 210 2886 000

Fax:+30 210 2886 905

ey.com

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, 2022, in XHTML file format

"213800T9Y5XCOVRZ4Y57-2022-12-31.xhtml” as well as the required XBRL file “213800T9Y5XCOVRZ4Y57-2022-12-31-

en.zip” with appropriate tagging on the aforementioned consolidated financial statements, have been prepared, in all

material respects, in accordance with the ESEF Regulatory Framework.

Athens 23 March 2023

Ioannis Pierros

Certified Auditor Accountant

SOEL R.N. 3505

ERNST & YOUNG (HELLAS)

Certified Auditors – Accountants S.A.

8B Chimarras, Maroussi,

151 25, Greece

Company SOEL R.N. 107

187

This page is left blank intentionally

188

PUBLIC POWER CORPORATION S.A.

Consolidated and Separate

Financial Statements

December 31

2022

In accordance with the

International Financial Reporting Standards

adopted by the European Union

The attached separate and consolidated financial statements have been approved by the Board

of Directors of Public Power Corporation S.A. on March 23

2023 and they are available on the

web site of Public Power Corporation S.A. at www.dei.gr.

The attached separate and consolidated financial statements have been translated from the

original version in Greek.

CHAIRMAN AND CHIEF

EXECUTIVE OFFICER

VICE

CHAIRMAN

CHIEF FINANCIAL

OFFICER

ACCOUNTING

DEPARTMENT

DIRECTOR

GEORGIOS I.

STASSIS

PYRROS D.

PAPADIMITRIOU

KONSTANTINOS A.

ALEXANDRIDIS

STERGIOS A.

TSIFOTOUDIS

PUBLIC POWER CORPORATION S.A.

CONSOLIDATED AND SEPARATE STATEMENTS OF INCOME FOR THE YEAR ENDED DECEMBER 31, 2022

(All amounts in thousands of Euro)

189

- The accompanying notes are an integral part of the consolidated and separate financial statements.

GROUP

COMPANY

Note

01.01.2022-31.12.2022

01.01.2021-31.12.2021

01.01.2022-31.12.2022

01.01.2021-31.12.2021

Total Group

Total Company

Continuing

Operations

Discontinued

Operations

REVENUES:

Revenue from energy sales

10,712,719

5,015,668

10,694,874

4,987,108

Revenue from natural gas sales

4,920

1,161

4,945

1,161

Other sales

535,468

689,562

147,260

411,206

320,170

91,036

11,253,107

5,706,391

10,847,079

5,399,475

5,308,439

91,036

EXPENSES:

Payroll cost

768,554

730,371

480,782

412,094

Lignite

16,216

41,104

14,657

21,323

Liquid Fuels

853,239

537,003

850,141

530,825

Natural Gas

1,758,161

910,068

1,758,161

910,068

Depreciation and amortization

640,380

666,248

306,147

346,923

Energy purchases

4,720,240

1,286,722

4,883,818

1,487,577

Materials and consumables

121,547

121,643

92,161

71,650

Transmission system usage

143,321

129,257

143,321

129,257

Distribution system usage

429,551

220,588

459,293

(238,705)

Utilities and maintenance

210,920

180,212

135,940

109,651

Third party fees

184,403

141,812

116,185

89,035

Emission allowances

1,037,545

699,164

963,855

573,793

Provisions for risks

40,32

(16,653)

88,847

5,796

105,430

Provision for impairment of inventories

(6,801)

25,762

1,168

24,272

Provision for expected credit losses

21,22,23

207,526

(59,740)

161,662

(108,938)

Financial expenses

344,451

259,541

283,895

251,963

206,575

45,388

Financial Income

(55,464)

(59,294)

(86,045)

(65,222)

Impairment loss on Lignite Subsidiaries

88,000

Impairment loss on assets

(197,675)

107,575

(199,966)

78,675

Extraordinary contribution on electricity generators

2.4

245,322

Other (income) / expenses, net

358,275

53,109

300,304

7,332

13,017

(5,685)

Gains from associate and joint ventures

(61,677)

(4,350)

Gain from partial sale of a subsidiary/ the spin off of

distribution network

(790,021)

(52,301)

Foreign currency losses, net

7,273

1,159

7,349

1,126

11,279,103

5,856,213

10,104,183

5,233,121

5,432,123

(199,002)

PROFIT/(LOSS) BEFORE TAX

(25,996)

(149,822)

742,896

166,354

(123,684)

290,038

Income tax

17,081

131,452

27,196

139,791

20,829

118,962

NET PROFIT/(LOSS)

(8,915)

(18,370)

770,092

306,145

(102,855)

409,000

Attributable to:

Owners of the Parent

(19,003)

(18,404)

Non - controlling interests

10,088

Profit/(Loss) per share, basic and diluted

(0.02)

(0.05)

Weighted average number of shares

380,104,130

382,000,000

PUBLIC POWER CORPORATION S.A.

STATEMENTS OF COMPREHENSIVE INCOME FOR THE YEAR ENDED DECEMBER 31, 2022

(All amounts in thousands of Euro)

190

GROUP

COMPANY

Note

01.01.2022-31.12.2022

01.01.2021 -31.12.2021

01.01.2022 -

31.12.2022

01.01.2021 -

31.12.2021

01.01.2021 -

31.12.2021

01.01.2021 -

31.12.2021

Total Group

Total Company

Continuing

Operations

Discontinued

Operations

Net Profit/(Loss) for the year

(8,915)

(18,370)

770,092

306,145

(102,855)

409,000

Other Comprehensive (losses)/income to be reclassified to profit or loss in subsequent

periods

Reclassification of hedging transactions through the statement of comprehensive income

(237,309)

(244,864)

(237,309)

(244,864)

Foreign exchange differences

(642)

Gains/ (losses) from the valuation of hedging transactions

(6,122)

459,808

(8,181)

459,808

Deferred tax on gains/ losses from the valuation of hedging transactions

2,682

(17,305)

3,134

(17,305)

Deferred tax on gains from the valuation of hedging transactions due to change of tax rate

1,538

Net Other Comprehensive (losses)/ income to be reclassified to profit or loss in

subsequent periods

(240,728)

198,535

(242,355)

199,177

197,639

Other Comprehensive (losses) / income not to be reclassified to profit or loss in

subsequent periods

Gains / (Losses) on financial assets at fair value through total income

(539)

(319)

Revaluation of Property, plant and equipment

331,190

Deferred tax on revaluation of Property, plant and equipment

46,946

Deferred taxes on fixed assets due to change of tax rate

123,354

79,840

43,514

Provision for decommissioning and dismantling of facilities/ equipment of Units, Wind

Parks and Mines

5,619

11,165

8,573

11,165

Deferred taxes on provision for decommissioning and dismantling of facilities/ equipment

of Units, Wind Parks and Mines

(1,236)

(2,456)

(1,886)

(2,456)

Deferred taxes on provision for decommissioning and dismantling of facilities/ equipment

of Units and mines due to tax rate change

(2,494)

Actuarial gains/ (losses)

29,976

29,819

17,652

18,517

Deferred tax on actuarial gains/ losses

(6,594)

(6,560)

(3,883)

(4,074)

Deferred tax on actuarial gains/ losses due to tax rate change

(2,483)

(1,828)

Net Other Comprehensive (losses) / income not to be reclassified to profit or loss in

subsequent periods

27,767

527,942

20,457

141,865

104,881

43,514

Other Comprehensive (losses) / income for the year after tax

(212,962)

726,477

(221,898)

341,042

302,521

43,514

Total Comprehensive (losses)/ income for the year after tax

(221,877)

708,107

548,194

647,187

199,666

452,514

Attributable to:

Owners of the Parent

(231,965)

708,073

Non-controlling interests

10,088

- The accompanying notes are an integral part of the consolidated and separate financial statements.

PUBLIC POWER CORPORATION S.A.

CONSOLIDATED AND SEPARATE STATEMENT OF FINANCIAL POSITION AS OF DECEMBER 31, 2022

(All amounts in thousands of Euro)

191

GROUP

COMPANY

Note

31.12.2022

31.12.2021

31.12.2022

31.12.2021

ASSETS

Non - Current Assets :

Property, plant and equipment, net

10,550,781

10,265,746

5,210,419

5,118,915

Intangible assets, net

613,939

359,989

518,094

333,783

Right of use assets

175,470

134,570

147,724

102,769

Investments in subsidiaries

1,019,518

1,241,530

Investments in associates

60,147

38,822

537

Financial assets measured at fair value through other

comprehensive income

330

327

329

325

Other non - current assets

24,168

3,921

11,841

13,689

Deferred tax asset

426,393

382,487

760,852

731,841

Derivative Financial instruments

43.1

43.2

15,482

Total non - current assets

11,866,710

11,185,862

7,669,314

7,542,889

Current Assets :

Inventories

840,184

609,902

616,689

430,136

Trade receivables

1,365,605

1,100,625

1,200,734

875,909

Contract assets

868,662

660,345

868,662

660,345

Other receivables

1,330,661

1,242,540

1,268,002

1,119,988

Derivative Financial instruments

76,908

Income tax receivable

7,439

4,795

Cash and cash equivalents

3,159,484

2,832,351

2,760,552

2,512,204

Restricted cash

67,847

65,856

40,012

48,278

Total

7,639,882

6,593,322

6,754,651

5,723,768

Total Assets Held for Sale

5.2

20,623

Total current assets

7,660,505

6,593,322

6,775,274

5,723,768

Total Assets

19,527,215

17,779,184

14,444,588

13,266,657

EQUITY AND LIABILITIES

EQUITY :

Share capital

947,360

Share premium

1,018,747

1,018,753

1,018,747

1,018,753

Legal reserve

136,635

128,317

136,635

128,317

Statutory revaluation surplus

(947,342)

Revaluation surplus

5,150,332

5,163,915

3,064,597

3,000,597

Other Reserves

(1,321,801)

306,377

39,190

263,326

Treasury shares

(40,683)

Retained earnings

(869,348)

(1,538,702)

1,011,644

249,016

Total Equity attributable to the Owners of the Parent

4,073,900

5,078,678

5,230,148

4,660,027

Non - controlling interests

605,970

329

Total equity

4,679,870

5,079,007

5,230,148

4,660,027

Non - Current Liabilities :

Long - term borrowings

3,822,907

4,062,638

2,496,509

2,723,954

Post-retirement benefits

137,395

209,372

75,992

119,625

Provisions

804,029

835,261

801,977

809,980

Financial lease liability

142,838

119,461

122,604

94,825

Contract liabilities

2,384,657

2,349,074

435,732

438,272

Subsidies

182,955

137,548

89,217

95,665

Long term financial liability from the securitization of receivables

350,089

229,475

350,089

229,475

Financial liability from NCI Put option

1,420,017

Other non - current liabilities

35,541

35,564

512

Total non - current liabilities

9,280,428

7,978,393

4,372,632

4,511,834

Current Liabilities :

Trade and other payables

1,146,725

970,073

735,889

480,202

Short term financial liabilities from the securitization of

receivables

8,540

150,620

8,540

150,620

Income tax payable

42,955

70,461

15,175

63,778

Short - term borrowings

108,333

271,337

50,000

260,000

Current portion of long - term borrowings

591,894

353,632

357,662

207,051

Short - term financial lease liability

36,131

17,672

28,282

10,573

Accrued and other current liabilities

1,983,756

1,677,820

1,997,677

1,712,403

Derivative Financial instruments

43.2

11,732

Current portion of the provision of decommissioning and removal

of Power Plants’, Mines’ and Wind Parks’ facilities and mines’

land restoration areas

81,963

80,598

81,963

80,598

Current portion of post-retirement benefits

64,803

Short-term contract liabilities

1,490,085

1,129,571

1,490,085

1,129,571

Total Current Liabilities

5,566,917

4,721,784

4,841,808

4,094,796

Total Equity and Liabilities

19,527,215

17,779,184

14,444,588

13,266,657

- The accompanying notes are an integral part of the consolidated and separate financial statements.

PUBLIC POWER CORPORATION S.A.

CONSOLIDATED STATEMENT OF CHANGES IN SHAREHOLDERS' EQUITY

FOR THE YEAR ENDED DECEMBER 31, 2022

(All amounts in thousands of Euro)

192

- The accompanying notes are an integral part of the consolidated and separate financial statements.

GROUP

Other Reserves

Note

Capital

Premium

Treasury

Legal

Reserve

Revaluation

Surplus

Statutory

Revaluation

Surplus

Fair Value of

financial

assets

through

comprehensi

ve income

Foreign

exchange, Tax-

free and Other

Reserves

Other

Reserves

Total

Retained

Earnings

Total

Equity

Non-

Controlling

Interest

Total

Equity

Balance, January 1st, 2021

575,360

106,679

128,317

4,686,388

(947,342)

87,536

87,605

(1,550,361)

3,086,646

295

3,086,941

Profit/(Loss) for the year

(18,404)

(18,370)

Other comprehensive income/

(loss) for the year after tax

507,705

(539)

219,311

218,772

726,477

Total Comprehensive income/

(loss) for the year, after tax

507,705

(539)

219,311

218,772

(18,404)

708,073

708,107

Share capital increase

372,000

978,000

1,350,000

Expenses of the share

capital increase

(65,926)

Disposals of property, plant and

equipment

(30,178)

30,178

Other movements

(115)

Balance, December 31

, 2021

947,360

1,018,753

128,317

5,163,915

(947,342)

(470)

306,847

306,377

(1,538,702)

5,078,678

329

5,079,007

Balance, January 1

, 2022

947,360

1,018,753

128,317

5,163,915

(947,342)

(470)

306,847

306,377

(1,538,702)

5,078,678

329

5,079,007

Net Profit/(Loss) for the period

(19,003)

10,088

(8,915)

Other total (losses) / income for

the period, after tax

4,383

(217,347)

(217,345)

(212,962)

Total Comprehensive income/

(losses) for the period, after tax

4,383

(217,347)

(217,345)

(19,003)

(231,965)

10,088

(221,877)

Expenses of the share capital

increase

(6)

Disposals of property, plant and

equipment

(17,966)

17,966

Financial liability from NCI Put

option

(1,410,833)

Sale of subsidiary

678,686

637,203

1,315,889

Dividend distribution

(41,650)

Treasury shares

(40,683)

Formation of legal reserve

8,318

(8,318)

Other movements

Balance, December 31

, 2022

947,360

1,018,747

(40,683)

136,635

5,150,332

(947,342)

(468)

(1,321,333)

(1,321,801)

(869,348)

4,073,900

605,970

4,679,870

PUBLIC POWER CORPORATION S.A.

SEPARATE STATEMENT OF CHANGES IN SHAREHOLDERS' EQUITY

FOR THE YEAR ENDED DECEMBER 31, 2022

(All amounts in thousands of Euro)

193

- The accompanying notes are an integral part of the consolidated and separate financial statements.

COMPANY

Other Reserves

Note

Capital

Premium

Treasury

Legal

Reserve

Revaluati

Surplus

Statutory

Revaluation

Surplus

Fair Value of

financial assets

through

comprehensive

income

Tax-free and

Other

Reserves

Other

Reserves

Total

Retained

Earnings

Total

Equity

Balance, January 1

, 2021

575,360

106,679

128,317

4,594,433

(947,342)

(82)

51,934

51,852

(1,780,536)

2,728,763

Profit/(Loss) for the year

306,145

Other comprehensive income/ (loss) for the

year after tax

129,569

(319)

211,793

211,474

341,042

Total Comprehensive income / (loss)

for the year, after tax

129,569

(319)

211,793

211,474

306,145

647,187

Share capital increase

372,000

978,000

1,350,000

Expenses of the share capital increase

(65,926)

Disposals of property, plant and equipment

(26,929)

26,929

Transfer of the revaluation surplus of

property, plant and equipment of Ditribution

Network due to the spin -off

15,

(1,696,476)

1,696,476

Other movements

Balance, December 31

, 2021

947,360

1,018,753

128,317

3,000,597

(947,342)

(401)

263,727

263,326

249,016

4,660,027

Balance, January 1

, 2022

947,360

1,018,753

128,317

3,000,597

(947,342)

(401)

263,727

263,326

249,016

4,660,027

Net Profit/(Loss) for the period

770,092

Other total income / (loss) for the period,

after tax

6,687

(228,586)

(228,585)

(221,898)

Total Comprehensive income/ (loss) for

the period, after tax

6,687

(228,586)

(228,585)

770,092

548,194

Expenses of the share capital increase

(6)

Disposals of property, plant and equipment

(13,952)

13,952

Absorption of Lignite subsidiaries

5.1

71,265

4,446

(13,099)

62,612

Treasury shares

(40,683)

Formation of legal reserve

8,318

(8,318)

Other movements

Balance, December 31

, 2022

947,360

1,018,747

(40,683)

136,635

3,064,597

(947,342)

(400)

39,590

39,190

1,011,644

5,230,148

PUBLIC POWER CORPORATION S.A.

CONSOLIDATED AND SEPARATE STATEMENTS OF CASH FLOWS FOR THE YEAR ENDED

DECEMBER 31, 2022

(All amounts in thousands of Euro)

194

GROUP

COMPANY

Note

01.01.2022-

31.12.2022

01.01.2021-

31.12.2021*

01.01.2022-

31.12.2022

01.01.2021-

31.12.2021*

Cash Flows from Operating activities

Profit/ (Loss) before tax from continuing operations

(25,996)

(149,822)

742,896

(123,684)

Profit/ (Loss) before tax from discontinued operations

290,038

Profit/ (Loss) before tax

(25,996)

(149,822)

742,896

166,354

Adjustments:

Depreciation and amortization

619,883

662,273

290,366

342,992

Depreciation of right-of-use assets

33,426

20,147

25,038

13,827

Impairment loss on assets

(197,675)

107,575

(199,966)

78,675

Impairment loss of the shareholding of Lignite Subsidiaries

88,000

Amortization of subsidies

(12,929)

(16,172)

(9,257)

(9,896)

Income from long-term contract liabilities

(96,343)

(91,852)

(248)

Gain from partial sale of a subsidiary/ the spin off of distribution network

(790,021)

(52,301)

Provision for post retirement benefits

50,476

49,194

Gains from associates

(61,677)

(4,350)

Interest income and dividends

(43,857)

(59,294)

(86,045)

(65,222)

Other provisions

179,343

5,038

166,295

(22,336)

Valuation of derivatives - swap agreements

125

11,732

Utilization of provision for decommissioning/ dismantling of Units, Mines

(26,785)

(10,777)

(26,785)

(10,777)

Finance expense for the provision for decommissioning

33,024

27,795

32,898

27,795

Foreign exchange gains losses on loans and borrowings

(7,273)

(1,159)

(7,349)

(1,126)

Unbilled revenue

(154,882)

(347,935)

(154,882)

(347,935)

Disposals of property, plant and equipment and intangible assets

(5,775)

(4,536)

(13,811)

(559)

Amortization of loans’ issuance fees

6,527

7,133

6,440

7,133

Interest and other expense

187,076

160,244

126,665

107,278

Operating profit/(loss) before working capital changes

476,688

304,308

163,160

321,654

(Increase)/decrease in:

Trade receivables

(487,418)

(234,030)

(584,788)

(364,629)

Other receivables

(141,770)

(830,768)

(95,127)

(848,738)

Inventories

(205,102)

(5,311)

(134,288)

769

Increase/(decrease) in:

Trade payables

33,670

(319,754)

84,046

(444,194)

Other non - current liabilities

484,676

700,317

485,899

685,929

Accrued and other liabilities (excluding accrued interest)

115,679

987,090

66,861

1,045,037

Restricted cash

(1,991)

(7,154)

8,266

4,525

Change in Intangible assets (Emission allowances)

(185,311)

(242,297)

(185,311)

(242,297)

Proceeds from long-term contract liabilities

134,216

179,094

Income tax (paid) /received

(72,302)

100,261

(56,699)

103,153

Discontinued operations

135,932

Net Cash from/ (used) in Operating Activities

151,035

631,756

(247,981)

397,141

Cash Flows from Investing Activities

Interest and dividends received

43,857

59,294

86,045

65,222

Capital expenditure for property, plant and equipment and intangible assets

15,16

(686,211)

(437,851)

(206,095)

(183,756)

Proceeds from subsidies

58,336

Investments in subsidiaries and associates

(4,759)

(304,389)

(33,700)

Sales of property, plant and equipment

17,958

40,637

17,958

40,637

Proceeds from the sale of subsidiary

1,323,276

Acquisition of subsidiaries, net of cash acquired

(57,191)

Discontinued operations

(170,353)

Net Cash from/ (used in) Investing Activities

(623,251)

(342,679)

916,795

(281,950)

Cash Flows from Financing Activities

Net change in short-term borrowings

(163,004)

229,185

(210,000)

230,000

Proceeds from long-term borrowing

392,304

1,896,888

215,669

1,880,364

Principal payments of long-term borrowing

(471,404)

(1,497,516)

(317,432)

(1,343,742)

Principal lease payments of right-of-use assets

(39,122)

(22,711)

(29,810)

(15,052)

Interest paid and loans’ issuance fees

(160,368)

(162,274)

(107,411)

(110,929)

Dividends paid

(41,650)

(12)

Treasury shares

(40,683)

Share capital increase including expenses

1,284,074

Proceeds from the sale of subsidiary

1,323,276

Discontinued operations

(154,630)

Net Cash used in Financing Activities

799,349

1,727,634

(489,667)

1,770,073

Net increase / (decrease) in cash and cash equivalents

327,133

2,016,711

179,147

1,885,264

Cash and cash equivalents at the beginning of the year

2,832,351

815,640

2,512,204

626,940

Cash and cash equivalents from Absorption

5.1

69,201

Cash and cash equivalents at the end of the year

3,159,484

2,832,351

2,760,552

2,512,204

-The accompanying notes are an integral part of the consolidated and separate financial statements.

- * Certain figures of the Group and the Parent Company have been restated compared to those published on 31.12.2021 for better illustration and comparability purposes with

other companies of the industry. Specifically, the change in intangible assets (Emission Rights) with an amount of € 242.297 was transferred from cash flows from investing activities

(Capital expenditure for property, plant and equipment and intangible assets) to cash inflows from operating activity in a separate line. Moreover, the proceeds from long-term

contract liabilities of the Group and the Parent Company amounting to € 179,094 and €154,754 (discontinued operations) respectively, were transferred from cash flows from

investing activities to cash inflows from operating activities in a separate line (Note 4.2).

195

D. NOTES ΤΟ THE FINANCIAL STATEMENTS

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro unless otherwise stated)

196

1. CORPORATE INFORMATION

Public Power Corporation S.A. (“PPC” or the “Parent Company”) was established in 1950 in Greece for an unlimited

duration as a State owned and managed corporation for electricity generation, transmission and distribution

throughout Greece.

In January 1, 2001 PPC was transformed into a société anonyme with a duration of 100 years and effective

December 2001, PPC’s shares are listed on the Athens Stock Exchange.

PPC headquarters are located at 30, Chalkokondili Street, Athens, 104 32 Greece.

The accompanying financial statements include the separate financial statements of PPC and the consolidated

financial statements of PPC and its subsidiaries (“the Group”).

On December 31

, 2022 the number of personnel employed by the Group was 12,755 (2021: 12,909). On

December 31

, 2022, 93 employees of the Group (2021: 95), have been transferred to several State agencies, out

of which, 88 were compensated by PPC (2021: 90). The total payroll cost of such employees, for the fiscal year

ended December 31

, 2022 amounted to € 4,308 (2021: € 3,969). Additionally, on December 31

, 2022, PPC’s

transferred employees in EFKA (Greek Single Social Security Institution) amounted to 147, (2021: 185) for which

payroll cost amounted to € 7,779 (2021: € 8,933).

PPC Group generates electricity from the power generating stations of the Parent Company and its subsidiary “PPC

Renewables S.A.” and distributes electricity to consumers through the distribution network for Medium and Low

voltage by its subsidiary “HEDNO S.A.”. PPC Group has also developed an urban fibre optics network. Lignite

consumed by the Group’s lignite-fired power stations is extracted, to a significant extent, from its own lignite mines.

From the Fourth Quarter of 2019, the Parent Company started to operate in the Natural Gas market.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

197

2. LEGAL FRAMEWORK

SIGNIFICANT CHANGES IN 2022

2.1. ELECTRICITY MARKET

• By RAE Decisions 185/2022 (OG B' 985/04.03.2022), 212/2022 (OG B' 1644/06.04.2022), 233/2022, 480/2022

(OG B' 2810/06.06.2022) and 585/2022 (OG B' 3426/04.07.2022) the framework for the participation of

Dispatchable Load Portfolio (Demand Response) and Dispatchable RES Units Portfolio in the Balancing Market

was established.

• By RAE Decision 751/2022 (06.10.2022) PPC was granted an Aggregator licence with regard to the Demand

Response service in the electricity market, for a capacity of 1000 MW and a duration of 20 years, which marks

the start of the Company's activation as Aggregator, based on the relevant regulatory framework of the market.

• Law 4951/2022 (OG A' 129/04.07.2022) as amended and in force by Law 4964/2022 (OG A' 150/30.07.2022)

defined, among other things, issues related to the licensing framework and the operation of RES units, as well as

to the generation and storage of electricity, the development of marine floating solar plants and special issues

related to the energy market. In particular, the law provided for:

➢ The conclusion of Contracts for Emergency Standby Capacity between IPTO and the owners of thermal units

(PPC) located in the electricity systems of the island regions, which no longer fall under the Non-

Interconnected Islands (interconnection with mainland's Transmission System). The issuance of a Joint

Ministerial Decision is expected within 3 months from the entry into force of the law, which specifies for the

period from 01.01.2004 until the entry into force of the Contracts for Emergency Standby Capacity for the

electrical systems of the islands of Andros, Tinos, Mykonos, Syros and Paros, the amount of the relevant

consideration (PPC), which is calculated on the basis of documented full cost ex post data, provided by PPC

and HEDNO, with coverage of the consideration through the Special Account for Public Service Obligations.

Currently, no provision has been made in the financial statements of the Group and the Parent Company for

the amount of the consideration to be received by PPC, as it is expected to be determined by a joint decision

of the Ministers of Environment and Energy and Finance, following the opinion of RAE.

➢ With article 122 of Law 4951/2022 through the addition of article 12A to Law 4425/2016 the Temporary

Mechanism for Returning Part of the Revenues of the Next Day Market and Intraday Market to Electricity

Producers from their participation in the markets of ENEX was established, with application initially until

01.06.2023, which was however extended until 30.06.2023, based on article 92 of Law 5027/2023 (OG A'

48/02.03.2023), through an amendment to article 12A of Law 4425/2016. By means of the above Temporary

Mechanism, all Power Generation Units of the Interconnected System participating in the Day-Ahead Market

(Lignite, Natural Gas, Large Hydroelectric Plants and RES Portfolios) return part of their revenues from the

Day-Ahead Market to the Energy Transition Fund (ETF), so that they are ultimately paid based on a regulated

unit price (in €/MWh) multiplied by the energy of these Units (in MWh) in the Day Ahead-Market.

The Joint Ministerial Decision YPEN/DIE/70248/2434 (OG B' 3517/06.07.2022) defined the methodology

applied by the Day Ahead Market Clearing House (EnExClear) for the calculation, on a monthly basis, of the

administratively determined unit Regulated Revenue Price for Lignite, Natural Gas Units, Large Hydroelectric

Power Plants (HPPs) and Renewable Energy Portfolios of the Interconnected System.

For the Lignite Units and the Natural Gas Units the regulated unit price is calculated every month based on a

mathematical formula (different for each category) which includes a price index of Natural Gas and CO2/Day.

For the HPPs and the RES Portfolios the regulated unit price is fixed and different for each category.

8 July 2022 was set as application date of the Mechanism in the Day-Ahead Market by the decision

YPEN/DIE/69734/2413 (OG B' 3517/06.07.2022), while by the decision YPEN/DIE/102621/3568 (OG Β’

5200/06.10.2022), the application of the Temporary Mechanism on the sales transactions carried out in the

Intraday Auctions(CRIDAs) started on 7 October 2022.

The Joint Ministerial Decision YPEN/DIE/115180/4229 (OG B' 5649/04.11.2022), by amending the Joint

Ministerial Decision YPEN/DIE/70248/2434, incorporated, as from 06.11.2022, in the calculations of the

regulated price for natural gas units, the special contribution of 10€/MWh imposed on the quantity of natural

gas used for the generation of electricity from natural gas units payable to the ETF, for each obligated

electricity producer under article 62 of Law 4986/2022, with the result that the electricity producers are not

charged with this contribution.

With article 89 of Law 5027/2023, through an amendment of article 62 of Law 4986/2022, from 01.03.2023

the amount of the contribution was changed from the fixed price of €10/MWh to a rate of 5% of the numerical

average of daily average prices of the natural gas trading platform “Title Transfer Facility” (TTF).

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

198

2.LEGAL FRAMEWORK (CONTINUED)

With article 109 of Law 5007/2022 (OG A’ 241/23.12. 2022), the extension of the application of the Temporary

Mechanism for the Refund of Part of the Revenue of RES Generation Units and Portfolios was provided to the

entire Intraday Market (not only to the sales transactions carried out in the Intraday Auctions as was the case)

but also during the continuous intraday market trading (XBID), starting as from 2 January 2023, based on the

Decision YPEN/DIE/138775/4768 (OG B' 6950/30.12.2022).

By means of this mechanism, the exposure of the power Generation activity in the Interconnected System to

the fluctuation of fuel, CO2 and electricity prices ceases for the Group and the Parent company from

08.07.2022 until 01.06.2023 (until 30.06.2023 after amendment of the respective Law in March 2023) (Note

43).

• Article 41 of Law 4994/2022 (OG A' 215/18.11.2022), through the addition of article 143Z to Law 4001/2011, the

Electricity Demand Reduction Service was established as an obligation for electricity consumers or Aggregators

(DRP/Aggregators) to reduce the active power they consume or represent during peak hours by at least a certain

predetermined volume based on participation in relevant auctions of the competent operator, IPTO. The Electricity

Demand Reduction Service may be provided for the period 01.12.2022 – 31.03.2023.

The procedures for registration with the Electricity Demand Reduction Service Providers Registry and the

Electricity Demand Reduction Portfolio Registry of IPTO have been completed, with PPC among those registered,

but the scheduled auctions were not held due to the non-receipt of the European Commission's consent on the

content of the official notification of the Hellenic Republic for the Electricity Demand Reduction Service, as

provided for in the relevant Joint Ministerial Decision.

• By RAE Decision 862/2022 (OG Β’ 6063/28.11.2022) the coupled operation of the Intraday Market and through the

Single Intraday Coupling (SIDC), at the bidding zone borders Greece – Italy and Greece – Bulgaria (through the

XBID platform) was launched as from 30.11.2022, following the launch of the coupled operation of the Intraday

Market as from 22.09.2021, through only the Complementary Regional Intraday Auctions (CRIDAs), in order to fulfil

the objective of completion of the single European electricity market according to the EU Target Model. On this

basis, the provisions relating to Continuous Intraday Trading in the Regulations and Codes of the markets are

activated, while, pursuant to Article 5 of Law 4414/2016 as in force, with the development and operation of the

Continuous Intraday Electricity Market, RES Units with Market Participation Obligation for which a Sliding Feed-in-

premium Contract has been concluded acquire full balancing obligations, differentiating the way they participate in

the markets.

• By RAE Decision 928/2022 (OG B' 6868/29.12.2022), the supply share for each Market Time Unit was set for the

year 2023 at 40% to which 30% is applied as the maximum threshold of transactions on Energy Financial

Instruments (Forward Hedging Ratio, FHR) with physical delivery of energy, which have been concluded within the

Energy Derivatives Market or bilaterally. This restriction is directly applicable only to the amount of physical delivery

transactions carried out by PPC. The maximum percentage of transactions was increased from 20% in 2022 to

30% in 2023.

Issues of the Electricity Retail Market

• The Law 4886/2022 (OG Α’ 12/24.01.2022) expands the granting of subsidy for the consumption of electricity and

natural gas (as a credit to the beneficiaries' accounts by suppliers) through the Energy Transition Fund (ETF)

managed by DAPEEP, which was established by Law 4839/2021, and from now on all electricity consumers,

regardless of voltage level, with variable electricity supply tariffs that are adjusted on the basis of the wholesale

electricity market price, and all natural gas consumers, except electricity producers, including cases of combined

heat and power, whether high-efficiency or not, for the part of gas consumption related to thermal energy

generation, can be eligible for subsidy.

The amount of the subsidy (€/MWh), the procedure, the way and time of its granting, the time of settlement, the

consumption period, the maximum and minimum consumption limits, the obligations of the electricity and gas

suppliers, as well as any other issue related to the granting of the electricity and gas subsidy for the year 2022 were

established by a series of joint ministerial decisions (JMD) issued within 2022. The Energy Transition Fund in order

to protect consumers provided an electricity subsidy from September 2021 and throughout 2022.

Also by the Joint Ministerial Decision YPEN/DIE/13046/455 (OG B' 560/10.02.2022) the electricity consumption

subsidy for the months of August - December of the year 2021 was determined for consumers with agricultural

supplies and consumers active in the drying of agricultural products, of low and medium voltage (LV, MV), who

have variable tariff contracts that are adjusted based on the wholesale electricity market price.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

199

2.LEGAL FRAMEWORK (CONTINUED)

In particular, eligible for the electricity consumption subsidy were all residential electricity consumers for supplies

relating to main residence, while the subsidy was scaled, for the first tier of monthly electricity consumption from 0

to 150 kWh and the second tier of monthly electricity consumption from 151 kWh to 300 kWh. For residential

consumers, the unit subsidy for the two tiers from the lowest to the highest monthly consumption was set for January

2022 for the first and second consumption tiers at €160/MWh and €120/MWh respectively, for February and March

2022 for the first and second tiers at €150/MWh and €110/MWh respectively, for April 2022 at €270/MWh and

€210/MWh respectively, for May 2022 at €205/MWh and €160/MWh respectively and for June 2022 at €185/MWh

and €140/MWh respectively on electricity consumption. In addition, for May and June 2022 1) a subsidy of

€100/MWh has been set for excess consumption, consumption above the limits, and 2) a subsidy of €100/MWh

has been set for supplies relating to non-main residence. For all residential consumers, regardless of consumption

limit and type of residence, a subsidy of €200/MWh was set for July 2022, €337/MWh for August 2022 and

€639/MWh for September 2022. For the months of October – December 2022, all residential consumers, regardless

of the type of residence, were granted a tiered subsidy, for monthly electricity consumption from 0 to 500 kWh, from

501 kWh to 1,000 kWh and for consumption exceeding 1,000 kWh, whereby for monthly consumption exceeding

the consumption limits of a certain scale, the excess consumption is subsidised on the basis of the unit subsidy

price of the next in order tier. Specifically, the unit subsidy for the three tiers, from the lowest to the highest monthly

consumption, was set for the month of October 2022 at €436/MWh, €386/MWh and €336/MWh respectively, for the

month of November 2022 at €238/MWh, €188/MWh and €98/MWh respectively and for the month of December

2022 at €221/MWh, €171/MWh and €81/MWh respectively. In addition, an electricity saving incentive has been

introduced for all residential consumers, except for the Social Residential Tariff (KOT) and Solidarity Services Tariff

(ΤΥΑ) beneficiaries, whose consumption exceeds 500 kWh, with an additional subsidy of €50/MWh for residential

consumers who achieve a 15% reduction in their average daily consumption compared to the respective last year's

consumption.

Also, eligible for the subsidy were all beneficiaries of the Social Residential Tariff (KOT) (regardless of main

residence), with the subsidy covering the first 300 kWh. For these consumers, the monthly subsidy on electricity

consumption for January 2022 was set at €180/MWh, for February and March 2022 at €170/MWh, and for April

2022 at €290/MWh. For the months May - December 2022, the subsidy was set at €215/ΜWh, €195/ΜWh,

€240/ΜWh, €377/ΜWh, €677/ΜWh, 485/ΜWh, €286/ΜWh and €269/ΜWh respectively, irrespective of

consumption limit.

For beneficiaries of the Solidarity Services Tariff, the same subsidy was set for all months, irrespective of

consumption limit.

For all non-residential electricity consumers (Agricultural, Commercial, Industrial, Professional, Other Uses, etc.),

who have variable electricity supply tariff contracts, the unit subsidy was set for January to March 2022 in the

amount of €65/MWh, for April to December 2022 at €130/MWh, €120/MWh, €100/MWh, €148/MWh, €250/MWh,

€342/MWh, €230/MWh, €50/MWh, and €34/MWh respectively, irrespective of consumption limit.

In particular, with the Joint Ministerial Decision YPEN/DIE/152/4 (OG B' 3/03.01.2023), in addition to the subsidies

defined in the Joint Ministerial Decisions YPEN/DIE/12477/435/09.02.2022 as in force, a subsidy from the ETF for

electricity consumption was provided to all non-residential electricity consumers with business activity who meet

the following requirements: 1) Have power supplies up to 35 kVA, or have a main activity with an Activity Code

Number (ACN) 10. 71, i.e. bakeries, irrespective of the supply power limit and voltage level, or have an agricultural

supply, irrespective of the supply power limit and voltage level, 2) From February 2022 to July 2022, be contracted

to variable electricity supply tariffs adjusted on the basis of the wholesale electricity market price and from August

2022 to November 2022, be contracted to variable electricity supply tariffs or electricity supply tariffs under section

138 of Law 4951/2022 and 3) Have notified both the competent electricity network operator and the electricity

supplier of their Tax Identification Number (TIN).

The subsidy shall be granted for consumption in the months of February - November 2022 and shall be granted no

later than 31 December 2023 and the total subsidy shall not exceed 80% of the adjustment clause that applied to

these tariffs. Furthermore, the total amount of the subsidy is granted without prejudice to any thresholds set in the

context of subsidies granted under the Communication from the Commission No. 2022/C 131 I/01 on the Temporary

Crisis Framework for State aid measures in support of the economy following Russia's aggression against Ukraine,

as amended by European Commission Communications C/2022/5342 and C/2022/426/01. For a consumption

period falling within the period of application of the measure and for which a bill has already been issued, the subsidy

will be applied to a consumption bill issued within one month of the entry into force of the JMD.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

200

2.LEGAL FRAMEWORK (CONTINUED)

In article 93 of Law 5027/2023, through an amendment to paragraph 3 of article 61 of Law 4839/2021, it was defined

that sustomers who have entered into over the counter contracts for the physical delivery of electricity, the quantities

of which, based on the article 92 of the same law, are not counted and are not taken into account during the

application of the Temporary Mechanism for Returning Part of the Revenues of the Day-Ahead and Intra-Day

Market to Electricity Producers and no subsidy is granted for the quantities delivered pursuant to these contracts.

For the natural gas consumption subsidy, Joint Ministerial Decisions were issued within 2022 which set the subsidy

for residential consumers at €20/MWh on the total natural gas consumption for the months of January, February

and March, at €40/MWh for April and at €20/Mwh for May and June. For non-residential consumers the subsidy

was set at €30/MWh for the month of January, at €20/MWh for the months of February and March, at €40/MWh for

the month of April, at €20/MWh for the months of May and June, at €30/MWh for the months of July, August and

September and at €40/MWh for October on the total consumption of natural gas (including the consumption of

Cogeneration of Heat and Power (CHP) and High Efficiency Cogeneration of Heat and Power (HECHP) for the

generation of useful thermal energy, excluding quantities of natural gas used for the generation of electricity), laying

down in particular issues of subsidy in the case of self-consumption.

In this context, within 2022, amounts totalling €3.9 billion were credited to PPC from DAPEEP for electricity

consumption, as this subsidy was included in energy (and gas to a lesser extent) bills, reducing the amount of

consumers' bills due to PPC.

• Law 4951/2022 (OG A' 129/04.07.2022) as amended and in force by Law 4964/2022 (OG Α’ 150/30.07.2022),

defined:

➢ The non-application of an adjustment clause or a corresponding clause in variable electricity tariffs, which is

linked to the fluctuation of wholesale market figures, whether or not there is an explicit reference to such

clause in these tariffs, for the consumption of electricity from 1 August 2022 to 1 July 2023.

➢ The obligation of the suppliers of electricity to announce on a monthly basis and in a prominent place on

their website, by the 20th day of the previous month (m-1), the fixed fees and the electricity supply charges

for the capacity and energy component applicable to the variable tariffs for the month of application m.

• The Decision of the Ministry of Environment and Energy YPEN/GDE/6186/194 (OG B' 420/03.02.2022) amended

the Decision YPEN/GDE/57469/2612 (OG B' 2400/17.06.2020) which specified the provision of the Universal

Service, regarding the provision and application of a unit charge (clause) of adjustment on the charges for the

provision of the Universal Service. The decision YPEN/DIE/63233/2187 reappointed PPC as one of the five

Universal Service Suppliers for the two-year period 23.6.2022 - 22.06.2024.

• Based on RAE Decision 696/2022 (OG B' 4955/21.09.2022), the tendering procedure for the selection of the

Supplier of Last Resort (SLR) was declared unsuccessful as of 29.09.2022 and for a period of 2 years (RAE

Decision 588/2022, OG B' 3721/14.07.2022) and based on the provisions of Article 57 of Law 4001/211, by RAE

Decision 712/2022 (OG B' 5084/28.09.2022), PPC was appointed as the Supplier of the Last Resort service for

the period 29.09.2022 - 28.09.2024.

• Article 40 of Law 4994/2022 (OG Α’ 215/18.11.2022) established a Temporary Mechanism for Refund of Part of

the Revenues from Electricity Suppliers, under which an extraordinary contribution is imposed on each electricity

supplier, based on its excessive revenues from its activity in the domestic retail electricity market during the period

01.08.2022 - 01.07.2023.

The proceeds of the levy shall be credited to the DAPEEP who manages of the special Account of the Energy

Transition Fund (ETF) for subsidizing consumers’ electricity bills.

For the calculation of the excessive revenues, the Reasonable Maximum Retail

Price (RMRP), based on the average cost of supplying electricity, plus a reasonable maximum profit margin and

taking into account a reasonable percentage for system losses, operating costs and risk of bad debts and the

Average Billing Price (ABP) will be taken into account per month under review, as the average billing price on the

tariffs provided by the supplier, based on the consumption per tariff, excluding any state subsidy, with the

possibility of including also fixed tariff types of low-voltage consumers by priority, as well as discounts provided

by suppliers.

The excessive revenue per month for each supplier will be calculated as the product of the difference between the

Average Billing Price and the corresponding Reasonable Maximum Retail Price, multiplied by the quantity of

electricity supplied per month, minus the amounts paid by the liable party in the context of the settlement of

monthly electricity purchase contracts and monthly hedging operations.

A joint decision is expected to be issued by the Ministers of Environment and Energy and Finance, which will

define every relevant detail and procedure for the implementation of the Mechanism following a proposal by RAE,

as well as the procedure and time for the imposition, certification, collection and reimbursement of the

extraordinary contribution to the ETF.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

201

2.LEGAL FRAMEWORK (CONTINUED)

At present, any financial impact of the extraordinary contribution on electricity supplier cannot be determined.

2.2. Public Service Obligations (PSOs)

• By RAE Decision 97/2022 (OG B' 900/28.02.2022) and RAE Decision 99/2023 (OG B' 958/23.02.2023), the cap

on the annual charge for customers per consumption point for the coverage of the costs for the provision of PSOs

was adjusted to € 789,249 for the year 2022 and € 865,017 for the year 2023 respectively.

• By RAE Decision 605/2022 (OG Β’ 4232/10.08.2022) the monthly ex-post NII_PSO compensation, per NII

System, were approved, forming a PSO compensation on the total NII for the year 2018 of €646.5 million and on

the basis of the ex-post data of the energy to be billed corresponding to each Supplier active in each NII System,

the PSOs Operator (HEDNO) will proceed to a final settlement for each Supplier, in accordance with the

methodology for determining NII_PSO compensation as in force.

• The Joint Ministerial Decision YPEN/DIE/81948/2763 (OG B΄4266/11.08.2022) and YPEN/DIE/124862/4493 (OG

Β΄6166/05.12.2022), approved the financing of the Energy Transition Fund (ETF) through the Special Account for

Public Service Obligations (PSOs), in the amount of €300 and €100 million respectively. Within 2022, the

subsidiary HEDNO paid the amount of €400 million from the surplus of the PSO account to the Energy Transition

Fund account managed by DAPEEP.

• With article 58C of Law 4001/2011 as valid, based on article 61 of Law 4986/2022 and article 90 of Law 5027/2023,

it was defined that the compensation for the risk from energy crises constitutes a Service of Public Interest (PSO),

and that by a decision of the Ministry of Energy, following potentially a proposal from the competent Administrator,

the persons obliged to provide, the type of risk compensated on a case-by-case basis, the exact method of

compensation, the amount necessary for effective compensation, the relevant matters of its transfer from the

administrative account of PSO, the determination of the PSO, the beneficiaries of its provision, as the case may

be.

2.3. Hellenic Electricity Transmission System (HETS) and Hellenic Electricity Distribution Network (HEDN)

• On 18 March 2022, the Regulatory Authority for Energy issued the decision no 868/2021, which set the Required

Revenue of HEDN for 2022 at €797.9 million.

• The Joint Ministerial Decision YPEN/ESPAEN/98830/1514 (OG B’ 5127/30.09.2022) defined the operations

(projects), the procedure, the obligations and the amount of HEDNO’s S.A financing through the Public Investment

Programme and in particular form the resources of the Recovery and Resilience Fund. On 31/10/2022, the

subsidiary HEDNO received €50 million as an advance payment for the financing of its projects and specifically

of actions 16900 and 16901, following the approval of the contracts by the Special Coordination Service of the

Recovery Fund and the finalization of 38 Contracts’/Subprojects’ Technical Data Sheets.

2.4. Other Issues of the Electricity Market

• Law 4920/2022 (OG A' 74/15.04.2022) defined the investment and operating aid framework for electricity storage

stations and issues related to the installation and operation of electricity storage stations with pumped storage

technology.

• Law 4936/2022 (OG A'105/27.05.2022) in Part A established strategies, policies and measures aiming at adapting

the country to climate change and ensuring decarbonisation by the year 2050, with a reduction of net

anthropogenic greenhouse gas emissions by at least 55% and 80% as interim climate targets for the years 2030

and 2040 respectively, compared to 1990 levels, taking into account the projections of the National Energy and

Climate Plan (NECP).

Indicatively, electricity generation from solid fossil fuels is prohibited from 31.12.2028 onwards and from

01.01.2030 onwards the use of fuel oil for electricity generation in the Non-Interconnected Islands will be

prohibited, except in cases of emergencies that put at risk the security of electricity supply. It also provided for the

establishment of a mechanism for carbon budgeting for key sectors of the economy, including power and heat

generation, and for the governance and participation system for climate action.

In Part B of the law, measures relating to the electricity market were introduced, including the extraordinary

contribution on electricity generators, based on the increase in the gross profit margin from the participation of

each power unit in the electricity markets for the period from 01.10.2021 to 30.06.2022. Electricity generators are

liable to pay the charge for all their power units, as well as for those represented by Aggregators.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

202

2.LEGAL FRAMEWORK (CONTINUED)

The charge is calculated per month of the period under review, by applying a factor of 90% on the positive

difference in the Gross Profit Margin of the liable party, between the month under review and the same month of

the previous year, weighted by the Fixed Price Supply Contracts and net of discounts to final consumers and

refunds under Bilateral Power Purchase Agreements. The proceeds of the contribution shall be credited to the

special account of the Energy Transition Fund (ETF) for subsidizing consumers’ electricity bills. The amount of

the charge is calculated by RAE,on a producer-by-producer basis, imposed by the Ministry of Environment and

Energy and certified and collected forthwith by the Independent Authority for Public Revenue, as public revenue,

in accordance with the Public Revenue Collection Code (Decree-Law 356/1974). The joint ministerial decision

(JMD) of the Ministers of Environment and Energy and Finance YPEN/DIE/87027/2890/30.08.2022 (OG Β’

4658/05.09.0222), as amended by the JMD YPEN/DIE/111281/4111(OG Β’5537/26.10.2022) and

YPEN/DIE/8304/148 (OG Β’383/27.01.2023), defined the assumptions, the issues of application of the

methodology, the parameters and special issues related to the calculation of the contribution, as well as the

procedure for the imposition, certification, collection and payment of the contribution to the special account of the

Energy Transition Fund, and any detail and procedure required for the implementation of the levy. Initially, the

provisional amount of the extraordinary contribution was determined by RAE and, upon completion of the final

settlement procedure, the final amount of the extraordinary contribution was re-determined by RAE, based on the

final figures as certified by a certified public accountant.

On 7 November 2022, PPC received an information note with the provisional amount of the extraordinary

contribution amounting to €276,048 that was paid in December 2022. On 14 February 2023, PPC received an

information note with the final amount of the extraordinary contribution amounting to €245,322. As of 31 December

2022, the final amount of the extraordinary contribution is included in the Income Statement under the account

"Extraordinary contribution on electricity generators" of the Group and the Parent Company, while it recognized a

receivable of €30,726 from the difference between the provisional and final charge (Note 23).

• The decisions RΑΕ 866/2022 and 868/2022 (24.11.2022), replacing the initially issued Decisions RΑΕ 501/2022

and 502/2022 (09.06.2022) respectively, due to a regulatory obligation to update the licences under the provisions

of articles 132Α – 132Η of Law 4001/2011, PPC was granted licenses for electricity storage (simultaneous

condensation) with a validity period of 25 years, in Unit III and Unit IV of Kardia TPP in the Western Macedonia

Region, in order to enable the implementation of the company's initiative for the conversion of the generators of

Units III and IV into simultaneous capacitors and to provide for reactive power regulation, voltage and inertia

support auxiliary services to HETS based on the relevant market regulatory framework.

2.5. NATURAL GAS MARKET

B1. Gas balancing Platform

Issues concerning the operation of the Trading Platform (spot market) for natural gas and the way to participate in

it, which was launched in Greece by the Hellenic Energy Exchange on 21 March 2022 and in which the Company

participates, were defined:

• RAE Decision 60/2022 (OG B' 454/07.02.2022) approved the operation and management of the Natural Gas

Trading Platform by the company "Hellenic Energy Exchange S.A." (HEnEx) and by RAE Decision 88/2022 (OG

B' 513/09.02.2022) the company "Energy Exchange Clearing House S.A." (EnExClear) was approved as the

Clearing House of the Natural Gas Trading Platform, in accordance with the provisions of Law 4425/2016.

• RAE Decision 61/2022 (OG B' 336/01.02.2022), approved the Rulebook for the Gas Trading Platform, which

includes the rules and procedures governing transactions between Participants in the Trading Platform and the

National Natural Gas System Operator (DESFA) and by RAE Decision 89/2022 (OG B' 515/08.02.2022), the

Clearing Rulebook for Transactions on the Gas Trading Platform was approved.

• RAE Decision 62/2022 (OG B' 584/11.02.2022) approved the specifications of products traded on the Gas Trading

Platform.

• RAE Decision 90/2022 (OG B' 488/08.02.2022) approved the risk management procedures of the Gas Trading

Platform Clearing System and RAE Decision 91/2022 (OG B' 823/24.02.2022) approved the Implementing

Decision of the Clearing Rulebook for Transactions on the Trading Platform, which defines the measures imposed

by the Clearing House (EnExClear) on Clearing Members, in cases of, indicatively, violation of the provisions of

the Rulebook, non-compliance with the technical instructions and specifications, submission of false or misleading

information, non-fulfilment or defective fulfilment of obligations, insolvency issues, bankruptcy, etc.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

203

2.LEGAL FRAMEWORK (CONTINUED)

2.6. ELECTROMOBILITY

2.7. ISSUES OF RENEWABLE ENERGY SOURCES (RES) AND HIGH EFFICIENCY CO-GENERATION OF

HEAT AND POWER (HECHP)

• The Decision YPEN/DAPEEK/81329/3660 (OG B’ 4247/10.08.2022) as provided for in Article 143 of Law

4001/2011, determined the methodology for calculating the charge imposed on load representatives, the creation

and the amount of the contingency reserve of the Sub-account of new RES and HECHP projects of the National

Plan for Energy and Climate - NPEC (OG B’ 4893/23.12.2019), which compensates the owners of RES and

HECHP stations that are commissioned as from 1.1.2021 and whose revenue, among other things, is the charge

imposed on load representatives and charged to the customers of each electricity supplier, depending on energy

consumption, and reflected in the electricity bill. The decision defined the procedure for the imposition and

adjustment of the charge, the procedure for the invoicing and settlement of the load representatives, as well as

the way in which RES and HECHP projects commissioned after 1.1.2021 are included in the New Projects Sub-

account and all relevant details and procedures during the operation of the Sub-account.

2.8. SPECIAL ISSUES

• By RAE Decision 672/2022 (OG B' 4792/12.09.2022), as amended by RAE Decision 792/2022 (OG B'

5534/26.10.2022) and in force, the revised Preventive Action Plan (PAP) was approved, in accordance with

Regulation (EU) 2017/1938 concerning measures to safeguard the security of gas supply.

•

The PAP adopts 4 Strategies with 11 appropriate measures (Actions) with a view to reducing or eliminating the

risks that may affect the security of natural gas supply in Greece, in case of significant disruptions in the demand

and/or supply of Natural Gas, taking into account the conclusions of the Studies conducted at regional level, the

results of the Identification of National Electricity Crisis Scenarios and the results of the updating of the National

Risk Assessment Study in terms of secure gas supply. PPC S.A. is liable for the following Actions of PAP:

Action D3: Obligation to maintain a natural gas reserve in underground storage infrastructure of another Member

State (Italy, Bulgaria) for the period November 2022 - March 2023, under which the Liable Suppliers will store a

regulatory quantity of natural gas in underground storage facilities in neighbouring Member States, which will be

transported to Greece at a fixed daily withdrawal rate (a quantity equal to 1/151 of their obligation) and will make

it available to the Greek market through the Natural Gas Trading Platform. In the context of this action, PPC

maintains, through DEPA, a reserve of €2.7 million as of 31 December 2022 in underground infrastructure in Italy.

Action D4: Maintenance of a natural gas safety reserve at Revythoussa from gas-fired power plants without the

possibility of fuel switching, in the context of which each holder of a natural gas-fired power generation license,

who has chosen as a specific condition of his/her generation license the option to maintain a natural gas reserve

in a storage facility and has a commercial operation license (for PPC: the Aliveri V, Lavrion V and Megalopolis V

Units) shall be subject to the obligation to maintain a sufficient natural gas reserve and to store it before November

15, 2022 in the storage facility of Revythoussa and to replenish it no later than 7 days as from its consumption

during the 5-month period and provided there are no reasons of force majeure. In the context of this action, PPC

maintains at Revythoussa a safety reserve of €29 million as of 31 December 2022.

For Actions D3 and D4, the coverage of capital costs shall be paid in the form of compensation to the Liable

parties and not as a return on reserves.

Action D5: Increase of alternative fuel (diesel) reserves in gas-fired power plants with fuel switching possibility, in

the context of which the license holders of electricity generation with NG and fuel switching possibility (for PPC:

Komotini and Lavrion IV Units) are obliged to maintain reserves of alternative fuel (diesel) for 20 days or up to the

maximum storage capacity of the existing tank, if lower, with the deadline for filling the tanks fixed at November

15, 2022. In compliance with the above action, PPC maintains increased fuel switching reserves at the Komotini

and Lavrion IV Units.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

204

2.LEGAL FRAMEWORK (CONTINUED)

Finally, according to par. 6 of Article 73 of Law 4001/2011, as in force, in order to finance the measures of the

Preventive Action Plan, the Νational Natural Gas System Operator (DESFA) collects, from all Users, the Supply

Security Levy per unit of natural gas quantity that the users receive from the National Natural Gas System(NNGS),

which is recovered from Natural Gas Customers. In particular, RAE Decision 888/2022 (OG B' 6917/30.12.2022)

determined the amount of the unit Supply Security Levy for each category of natural gas Customers with effect

from 2023 (Interruptible consumers: 0€/MWh, Electricity Producers: 2,49€/MWh, Other Consumption: 1,99€/MWh

and Protected Consumers: 2.84€/MWh), the maximum allowable limit and the maximum negative balance of the

security of supply account (€50 million), as well as the necessary terms and conditions for financing the measures

of the Preventive Action Plan.

3. SIGNIFICANT EVENTS

Effects of the COVID-19 Pandemic

The COVID-19 pandemic continues in year 2022 to affect the global social and economic life. In Greece, after the

resumption of the restrictive measures from October 2020 until approximately the end of March 2021, from mid-

April 2021 the restrictive measures gradually began to be lifted, as a result of the program of massive vaccination

applied, while there was an almost complete liberalization of the operation of stores.

Due to the fact that the majority of the impacts mainly comes from the measures taken, both worldwide and in

Greece since mid-March 2020 to reduce the spread of the pandemic and to mitigate the economic impact on

businesses and individuals, the Group’s and the Parent Company’s operation has been affected, initially causing

short-term positive effects on their financial position, operating results and cash flows, mainly due to the

considerable decrease in oil and natural gas prices in 2020. In the medium to long term, the pandemic has resulted

in the delay or freezing of new energy investments, which at least partially corresponds to the high prices of energy

products (electricity, natural gas, oil, CO2 emission allowances etc.), observed in 2021 and in 2022, combined with

the strong global recovery in demand for these energy products during 2021 and until mid 2022, as well as with the

geopolitical frictions and the Russia-Ukraine war (below section) that created nervousness in the energy markets

and strong upward trends in the prices of all energy products. In particular in Greece, after the recovery of electricity

demand observed in 2021 in the Interconnected System and continued in the first half of 2022, a significant increase

in electricity prices in the Day-ahead Market was observed, which in combination with the increase in prices for

emission allowances CO2 and natural gas, contributed to the increase of the energy balance cost of both Greece

and PPC for this period. It is noted that from July 2022 until today, a significant decrease in electricity demand in

the Interconnected System has been observed, which is related on the one hand to the prevailing mild weather

conditions and on the other hand to the reasonable reaction of consumers to the very high prices of electricity.

The Group and the Parent Company implemented a series of actions aimed at informing employees, raising their

awareness of prevention and protection measures, providing them with appropriate Personal Protection Measures

(PPE), protecting both them and their families and at the same time ensuring the smooth operation of their activities.

They also took emergency measures to energy consumers due to the pandemic, as mentioned in the Commercial

Policy section below.

However in any case, the Group’s and the Parent Company’s Management monitors constantly the developments

of the COVID-19 pandemic and evaluates any possible further effects on the operation, financial position and results

of the Group and the Parent Company, being alert to take further appropriate precautionary measures to safeguard

the Group’s and the Parent Company’s liquidity and business activities.

War Russia-Ukraine

The current geopolitical crisis in Ukraine, combined with the economic sanctions imposed on Russia by the

European Union and the United States of America, have created conditions of uncertainty in the economic

environment at European and global level.

PPC Group does not have a relevant commercial presence in Russia and Ukraine and as a result there is no direct

effect on its activities, but the indirect effect, as it develops, is particularly important.

The increased costs in the wholesale electricity market due to the unprecedented increase in the price of natural

gas is a development that indirectly affects the activities of the Group, which is, however, largely protected by the

vertically integrated nature of its activities, due to its presence in both generation and supply of electricity. The

aforementioned protection of the Group due to its vertically integrated nature is mitigated to some extent, as a

consequence of the Temporary Mechanism of Law 4971/2022 (Article 122) for Returning Part of Income of the Next

Day Energy Market.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

205

3.SIGNIFICANT EVENTS (CONTINUED)

Based on this Mechanism, which is valid during the period 8/7/2022-1/6/2023, which, however, was extended until

30/06/2023 based on article 92 of Law 5027/2023 (GO A' 48/02.03.2023), the power generation units of the

Interconnected System (except Crete) is compensated in the Day-Ahead Market based on regulated prices as

defined by Ministerial Decision (practical part of their income from the Day-Ahead Market is withheld, with which

the special account "Energy Transition Fund" is financed). With the above Mechanism, the income of Generation

in the Day-Ahead Market arises based on the variable cost of the units (cost plus), while the costs of Supply in the

same Market arise based on the Clearing Price of this Market.

As an emergency measure to strengthen the energy sufficiency of the country and reduce the supply of natural gas

from Russia, the PPC Group launched within 2022 the increase of lignite production, contributing to the adequacy

of the country's electrical system for the period of the energy crisis, through a review of the mining planning and by

changing the estimated withdrawal plan of the lignite units, with a slight extension of it, depending on the market

conditions.

In addition, indirect effects may arise due to the consequent reduction of our customers' disposable income, as a

result of increased energy costs and the intensification of inflationary pressures. As mentioned, already in the

previous paragraph, there is a significant decrease in electricity demand during the second half of 2022, which is

partly attributed to the increased energy costs.

Any overall final economic impact of the Russia-Ukraine war on the global and Greek economies and businesses

cannot be estimated at present, due to the high degree of uncertainty arising from the impossibility of predicting the

final outcome, but also due to the its secondary effects listed above. In any case, the Management of the Group

and the Parent Company continuously monitors the relevant developments and evaluates any possible further

effects on the operation, financial position and results of the Group and the Parent Company, being in a state of

increased vigilance to take appropriate precautionary measures to safeguard the liquidity and business activities of

the Group and the Parent Company.

Commercial policy

PPC in an effort to hold the arising energy costs and offset the impact on customer tariffs, it maintained energy

discounts on contracts with floating tariffs until July 2022 and alongside fully implemented the supporting measures

introduced by the State, incorporating the subsidies to beneficiary customers in both electricity and natural gas.

In April 2022, the pricing policy was adjusted to the high cost conditions, to Electricity products with fixed tariff (as

well as to the product portfolio of Natural gas products as a whole), however, only affecting the new contracts and

preserving those who had chosen in previous months one of these products.

In the context of its corporate operation, the Company has been developing and has implemented action programs

for a long time, with the main objective of improving collections and at the same time providing integrated solutions

to its customers in terms of servicing their due bills. In particular, it improves its credit policy in accordance with the

Electricity Supply Code by creating scalable actions of information and collection, which are constantly evolving,

and it measures their effectiveness.

At the same time, it continues its cooperation with a company that provides specialized support services in the

context of the securitization of company's trade receivables with the aim of reducing overdue debts and preventing

the creation of new ones, imposed by the criticality of the situation in the field of Energy. It applies new debt

settlement policy for its entire customer base giving flexible settlement programs and personalized solutions

according to the needs of its customers.

It also created new electronic and telephone bill collection services. Finally, in the new PPC store, apart from energy

products (electricity and natural gas), there is a special area for the sale of smart products, with the latest

technology.

With Law 4951/2022, from August 1, 2022, the adjustment clause in electricity supply tariffs is abolished. Instead,

Suppliers in the case of floating tariffs announce in advance the prices that will apply for each month. PPC, in the

application of the Law, has proceed with the relevant announcements (Note 2.1).

In November 2022, PPC rationalized its product portfolio in Natural Gas, eliminating fixed price products and

updating the pricing policy of variable price products.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

206

3.SIGNIFICANT EVENTS (CONTINUED)

Signing of MoU for the financing of the development of a Fiber to The Home Network (FTTH)

In January 2022, Public Power Corporation S.A. signed an MoU with Alpha Bank S.A and Piraeus Bank S.A. for

the financing of the construction and operation of a Fiber To The Home (FTTH) Network in selected areas of Greece.

The agreement includes the issuance of a long-term bond loan for up to € 530 million under the form of project

financing by the 100% subsidiary of special purpose PPC fiber communications SA, which was established by PPC

in December 2022 and which will undertake the construction, operation, exploitation and maintenance of the fiber

optics network to be established.

On February 16, 2023, an amount of €30 million was paid by the Parent company as the initial share capital of the

subsidiary.

Shareholders’ agreement for the construction, installation, operation, management, ownership and sale of

capacity via East Med Corridor System

On July 26, 2022, PPC signed a Shareholders’ Agreement to set up a joint venture which will construct, install,

operate, manage, own and sell capacity via a new submarine cable system and ancillary terrestrial infrastructure

and network (the “East Med Corridor System” or EMC project), linking Europe with Asia.

The shareholders being MENA HUB a subsidiary of STC from Saudi Arabia, TTSA a Greek telecoms and satellite

applications company, Digimed a subsidiary of Cyprus telecoms operator CYTA and PPC, have agreed to establish

the joint venture company under the laws of the Republic of Cyprus. PPC will hold a minority stake with a 25%

participation in the joint venture company.

Cooperation with RWE Business Group for the joint development of RES projects

In October 2021, PPC Renewables SA and RWE Renewables GmbH have signed the Joint Venture Formation

Agreement and the Shareholders' Agreement, with the aim of jointly contributing and implementing photovoltaic

stations with a total installed capacity of up to 2 GW through a JV investment vehicle (JVCo). In this context, in

August 2021, 9 subsidiaries were established (companies "AMYNTAIO") in Amyntaio, Florina, for the creation of

photovoltaic projects with a total capacity of up to 940 MW, which are located in Western Macedonia, within the

former Lignite Mine Amyntaio.

On January 14, 2022, the process of the contribution in kind to METON ENERGY SA was completed from PPC

Renewables, of the shares of its 9 subsidiaries AMYNTAIO which were valued on August 2, 2021 at € 75,185 by

Certified Public Accountants and acquired 49% of its shareholding, while RWER, contributed the amount of € 78,254

to METON ENERGY and acquired 51% of its shareholding. Photovoltaic projects are in various stages of

development, while the first projects are expected to start operating in 2023.

Group treated this transaction as a contribution in kind (IAS 28, par.28) of the net assets of its 100% subsidiaries

(with loss of control) and recognition of shareholding in the fair value of 49% in the associate company METON

ENERGY SA and its consolidation with the equity method.

On January 14, 2022, the Group recognized in the Income Statement "Gain from associates" amounting to € 38.1

million as it lost control of these assets while it recognized shareholding in associates amounting to € 38.7 million.

The Certified Public Accountant estimated the fair value of the 9 subsidiaries at € 153.4 million using the Cash Flow

Discount method based on the Business Plan of the 9 subsidiaries for the period 2021 to 2058.

In October 2022, RWE Renewables, following the agreement with PPC Renewables, granted METON an option to

purchase a portfolio of photovoltaic projects under development in Central Macedonia with a total capacity of

approximately 710 MW, which was exercised by METON.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

207

3.SIGNIFICANT EVENTS (CONTINUED)

Acquisition of RES portfolio subsidiaries

The Group, through its subsidiary PPC Renewables, entered into an agreement to purchase 100% of the shares of

subsidiary companies of Volterra (100% subsidiary of AVAX), for a consideration of €59.7 million paid on June 22,

2022.

More specifically, the Group acquired 55% of the shares in Volterra K-R SA and Volterra LYKOVOUNI SA, in which

it was already a shareholder with stake 45% in each company since 2019. Volterra K-R SA and Volterra

LYKOVOUNI SA own wind farms with a total capacity of 69.7 MW in Etoloakarnania and Viotia.

Also, the Group acquired 100% of Heliofaneia S.A. which owns a 2.7 MW photovoltaic park in operation in Viotia,

as well as the companies Volterra DOUKAS SA and Volterra KOUKOULI SA which own installation licenses for

wind farms with a total capacity of 39.5 MW, the construction of which are scheduled to start shortly in Western

Macedonia.

In August 2022, the 100% subsidiaries were renamed to K-R WIND PARK SHOLESHAREHOLDER S.A.,

LYKOVOUNI WIND PARK SHOLESHAREHOLDER S.A., DOUKAS WIND PARK SHOLESHAREHOLDER S.A.,

and KOUKOULI WIND PARK SHOLESHAREHOLDER S.A. by signing their new statutes.

The fair value of the assets and liabilities of the companies recognized in the Group's financial statements at the

acquisition date amounted to:

Fair value

Amounts in thousands of euro

Property, plant and equipment, net (Note 15)

79,239

Intangible assets, net (Note 16)

52,729

Right of use assets

357

Other non – current assets

2,611

Total Non – Current Assets

134,936

Trade receivables

2,607

Restricted cash

12,084

Cash and cash equivalents

5,786

Total Current Assets

20,477

Total Assets

155,413

Provision for dismantling of Wind Parks’ facilities (Note 32)

(1,246)

Long - term borrowings (Note 30)

(46,181)

Other long- term liabilities

(2,126)

Deferred tax liabilities

(13,496)

Financial lease liability

(344)

Total Non – Current Liabilities

(63,393)

Trade and other payables

(902)

Income tax payable

(249)

Short -term borrowings

(5,303)

Current portion of long - term borrowings (Note 30)

(4,626)

Short – term financial lease liability

(21)

Accrued and other current liabilities

(3,055)

Total Current Liabilities

(14,156)

Total Liabilities

(77,549)

Total net assets acquired at fair value

77,864

Minus: Fair value of investment in Associates (45% Volterra K-R SA, Volterra

LYKOVOUNI SA)

(39,385)

Plus: Goodwill arising on acquisition (Note 16)

21,191

Purchase consideration transferred

59,670

On the acquisition date, goodwill of €21.2 million was recognized in intangible assets that was not allocated to any

specific intangible asset.

Additionally, as the Group already owned 45% of the share capital in the companies Volterra K-R SA and Volterra

LYKOVOUNI SA, it recognized a gain from the valuation at fair value of its investment in associates on the date of

their acquisition amounting to €20.7 million, which is included in the Statement of Income in "Gains from associates".

In accordance with IFRS3 on a step-by-step acquisition of an equity interest, the acquirer re-measures the equity

interests previously held by the acquiree at fair value at the acquisition date and recognizes any gain or loss in the

Statement of Income.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

208

3.SIGNIFICANT EVENTS (CONTINUED)

Other significant events of the period

Within 2022, the sale of 49% of HEDNO (Note 5) and the absorption of the lignite subsidiaries companies Lignitiki

Megalopolis S.A. and Lignitiki Melitis S.A. from PPC S.A. were completed (Note 5.1). Moreover, the Programme

Agreement was signed with the Greek State that defined the hive down of the branch Post-Lignite Exploitation of

the Core Lignite Phase-out Zones of PPC to a new under incorporation subsidiary and the sale of its shares to the

Greek State (Note 5.2).

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

209

4. BASIS OF PREPARATION AND PRINCIPAL ACCOUNTING POLICIES

4.1. BASIS OF PREPARATION

Statement of compliance

The financial statements have been prepared in accordance with International Financial Reporting Standards

(IFRSs) as adopted by the European Union.

Approval of financial statements

The Board of Directors of the Parent Company approved the accompanying financial statements for the year ended

December 31

, 2022, on March 23

, 2023. These financial statements are subject to approval by the Parent

Company’s General Shareholders’ Meeting.

Basis of preparation of financial statements

The financial statements have been prepared under the historical cost convention, except for property, plant and

equipment (exluding lakes and mining land), financial assets valued at fair value through other comprehensive

income and derivative financial instruments that have been measured at fair value and assuming that PPC will

continue as a going concern. The financial statements are presented in thousands of Euro and all values are

rounded to the nearest thousand, unless otherwise stated. Management considers that the going concern principle

is the appropriate basis for the preparation of the present financial information.

Basis of consolidation

The consolidated financial statements include the financial statements of the Parent Company and its subsidiaries,

drawn up to December 31

each year. Subsidiaries (companies in which the Group directly or indirectly or through

other subsidiaries has an interest of more than one half of the voting rights or otherwise has power to exercise

control over their operations) have been consolidated. Subsidiaries are consolidated from the date on which

effective control is transferred to the Group and cease to be consolidated from the date on which control is

transferred out of the Group. Losses within a subsidiary are apportioned to the non-controlling interest even if that

results in a deficit balance. A change in the ownership interest of a subsidiary (without any change in control) is

accounted for as an equity transaction. All inter-company balances and transactions have been fully eliminated as

well as unrealized intra – group gains and losses. Where necessary, the accounting policies of subsidiaries have

been revised to ensure consistency with the accounting policies adopted by the Group.

In case that the Group loses control of a subsidiary then the following are :

Derecognized :

- The assets (including the surplus value) and liabilities of the subsidiary

- The book value of the non-controlling interest

- The accumulated exchange differences, which have been recorded in Equity

Recognized:

- The fair value of the price obtained

- The fair value of the remaining participation

- Any surplus or deficit in the Statement of Income

- The Parent Company’s share in the elements previously recognized in the comprehensive income

statement, in the income statement or the retained earnings where that is judged necessary.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

210

4.2. CHANGES IN ACCOUNTING POLICIES AND DISCLOSURES

New standards, amendments to standards and interpretations adopted by the Group and the Parent

Company

The accounting policies on the basis of which the annual separate and consolidated financial statements were

prepared for the year ended December 31

, 2022 were consistent with those used in the preparation of the annual

separate and consolidated financial statements for the year ended December 31

, 2021 with the exception of the

following amendments and standards, which were adopted by the Group and the Parent Company on January 1

2022 and did not have a material impact on the annual separate and consolidated financial statements for the year

ended December 31

, 2022.

As of December 31, 2022, the change of emission allowances for the Group and the Parent Company of € (185,311)

was transferred from cash flows from investing activities (Capital expenditure for property, plant and equipment and

intangible assets) to cash flows from operating activities for better illustration and comparability purposes with other

companies of the industry. As a result, the Group and the Parent Company included in their principal accounting

policies: As the cash flows of CO2 emission allowances relate to the operating activities of the Group and the Parent

Company, are shown in the cash flows from operating activities in the Cash Flow Statement.

As of December 31, 2022, the proceeds from long-term contract liabilities for the Group and the Parent Company

of € 134,216 were transferred from cash flows from investing activities to cash flows from operating activities for

better illustration and comparability purposes with other companies of the industry. As a result, the Group and the

Parent Company included in their principal accounting policies: As the cash flows from customers’ contributions

relate to the operating activities of the Group and the Parent Company, are shown in the cash flows from operating

activities in the Cash Flow Statement.

Moreover, the Group and the Parent Company on February 28, 2022, the date of completion of the sale of 49% of

the shareholding in HEDNO provided to the Non-controlling interest Put Options (sale) to PPC under certain

conditions of the shares acquired by Macquarie Asset Management in HEDNO, with exercise price the fair value of

the shares on the exercise date (Note 5). As a result, the Group and the Parent Company included in their principal

accounting policies the below:

Financial liability from NCI put option

According to IAS 32, the Group recognizes these written put option commitments as a "Financial liability from NCI

put option" in the Statement of Financial Position with equal recognition of "Other Reserves" in equity. The "Non-

controlling interests" related with the above financial liability are recognized in equity according to IFRS 10, while

the Group chose their full recognition on the date of initial recognition.

The above financial liability is initially recognized at the present value of the redemption amount. Subsequent

changes in the value of the financial liability resulting from the remeasurement of the present value of the amount

payable upon the exercise of the non-controlling interest, are recognized in the Income Statement in the results

attributable to Company's shareholders and not in the results attributable to the non-controlling interests.

In the case of exercise of the Put Option (sale) on maturity, the financial liability is de-recognized with the amount

paid by the Group to acquire the shares of the subsidiary. Whereas if the Put Option (sale) expires without being

exercised, the financial liability is de-recognized in other reserves in equity, which have been established on its

initial recognition.

On Parent Company level, the Put Option (sale) on subsidiary’s shares is treated as a derivative financial instrument

and as its exercise price is at fair value of the shares, the Put Option (sale) on shares has no value.

On June 22, 2022, the Group proceeded with the acquisition of subsidiary companies through its subsidiary PPC

Renewables and recognized Goodwill amounting to €21.2 million (Note 3). Therefore, the Group and the Parent

company included in their principal accounting policies the following:

Intangible assets- Goodwill

Goodwill is initially measured at cost and represents the excess amount between the aggregate consideration

transferred and the fair value of the Group's and Parent Company’s share of the acquiree's identifiable assets and

liabilities at the date of the acquisition.

If the fair value of net assets acquired by the Group and the Parent Company on the acquisition date is in excess

of the aggregate consideration transferred, a negative goodwill arises which is recognized directly in the Statement

of Income.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

211

4.2 CHANGES IN ACCOUNTING POLICIES AND DISCLOSURES (CONTINUED)

After initial recognition, Goodwill is measured at cost less any aggregate impairments. For the purpose of

impairment testing, Goodwill is allocated to cash-generating units (CGU), on acquisition date. The allocation is

made to the generating units that are expected to be benefit from the business combinations in which the goodwill

was identified and is recognized according to the operating segment.

Goodwill is subject to an impairment test annually, or even sooner if there are relevant indications. Goodwill

impairment is determined by estimating the recoverable value of each CGU (or group of CGU’s) to which the

goodwill has been allocated. When the recoverable amount (defined as the greater value between value in use and

fair value reduced by the required cost to sell) of the CGU is less than its book value including goodwill, an

impairment loss is recognized. Goodwill impairment cannot be reversed later.

In the context of the free of charge equity settled stock awards to the executives of PPC S.A. and PPC Renewables

S.A., the Group and the Parent Company proceed for the first time in 2022 with the purchase of own shares based

on the provisions of article 49 of Law 4548/2018 (Note 26). Therefore, the Group and the Parent company included

in their principal accounting principles the following:

Treasury shares

Own equity instruments that are reacquired (treasury shares) are recognized at cost and deducted from equity. No

gain or loss is recognized in the Statement of Income on the purchase, sale, issue or cancellation of the Group’s

own equity instruments. Any difference between the carrying amount and the consideration, if reissued, is

recognized in the share premium.

The Parent company, in the context of the absorption of Lignite subsidiaries (Note 5.1), proceeded with the following

addition to its principal accounting policies:

Investments in subsidiaries- merger of business

The absorption of the 100% subsidiary company by exchange of shares of the Parent company is treated in the

separate financial statements as a transaction between companies under common control and management is

required to determine an appropriate accounting policy to depict the transaction. The Company de-recognizes its

participation in the subsidiary and recognizes the net assets of the subsidiary either at fair value or at the carrying

value that was reflected in the consolidated financial statements of the Group at the date of the legal merger (taking

into account the commercial substance of the transaction).

• IFRS 3 Business Combinations; IAS 16 Property, Plant and Equipment; IAS 37 Provisions, Contingent

Liabilities and Contingent Assets as well as Annual Improvements 2018-2020 (Amendments)

The amendments are effective for annual periods beginning on or after 1 January 2022 with earlier application

permitted. The IASB has issued narrow-scope amendments to the IFRS Standards as follows:

➢ IFRS 3 Business Combinations (Amendments) update a reference in IFRS 3 to the previous version of

the IASB’s Conceptual Framework for Financial Reporting to the current version issued in 2018 without

significantly changing the accounting requirements for business combinations.

➢ IAS 16 Property, Plant and Equipment (Amendments) prohibit a company from deducting from the cost

of property, plant and equipment any proceeds from the sale of items produced while bringing the asset to

the location and condition necessary for it be capable of operating in the manner intended by management.

Instead, a company recognizes such sales proceeds and related cost in profit or loss.

➢ IAS 37 Provisions, Contingent Liabilities and Contingent Assets (Amendments) specify which costs

a company includes in determining the cost of fulfilling a contract for the purpose of assessing whether a

contract is onerous. The amendments clarify, the costs that relate directly to a contract to provide goods or

services include both incremental costs and an allocation of costs directly related to the contract activities.

➢ Annual Improvements 2018-2020 make minor amendments to IFRS 1 First-time Adoption of

International Financial Reporting Standards, IFRS 9 Financial Instruments, IAS 41 Agriculture and

the Illustrative Examples accompanying IFRS 16 Leases

• IFRS 16 Leases-Cοvid 19 Related Rent Concessions beyond 30 June 2021 (Amendment)

The Amendment applies to annual reporting periods beginning on or after 1 April 2021, with earlier application

permitted, including in financial statements not yet authorized for issue at the date the amendment is issued. In

March 2021, the Board amended the conditions of the practical expedient in IFRS 16 that provides relief to

lessees from applying the IFRS 16 guidance on lease modifications to rent concessions arising as a direct

consequence of the covid-19 pandemic. Following the amendment, the practical expedient now applies to rent

concessions for which any reduction in lease payments affects only payments originally due on or before 30

June 2022, provided the other conditions for applying the practical expedient are met.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

212

4.2 CHANGES IN ACCOUNTING POLICIES AND DISCLOSURES (CONTINUED)

Standards and Interpretations which are mandatory for subsequent periods and have not been applied

earlier by the Company and the Group

The following new standards, amendments to standards and interpretations have been issued but are mandatory

for subsequent periods. The Company and the Group have not yet applied the following standards.

• IAS 1 Presentation of Financial Statements and IFRS Practice Statement 2: Disclosure of Accounting

policies (Amendments)

The Amendments are effective for annual periods beginning on or after January 1, 2023 with earlier application

permitted. The amendments provide guidance on the application of materiality judgements to accounting policy

disclosures. In particular, the amendments to IAS 1 replace the requirement to disclose ‘significant’ accounting

policies with a requirement to disclose ‘material’ accounting policies.

Also, guidance and illustrative examples are added in the Practice Statement to assist in the application of the

materiality concept when making judgements about accounting policy disclosures. The Group is in the process of

assessing the impact of the application of the amendments to its financial statements.

• IAS 8 Accounting Policies, Changes in Accounting Estimates and Errors: Definition of Accounting

Estimates (Amendments)

Amendments take effect for annual reference periods beginning on or after 1 January 2023 with earlier application

permitted and applicable to changes in accounting policies and changes in accounting estimates made on or after

the beginning of this period. The amendments introduce a new definition of accounting estimates, defined as

monetary amounts in financial statements that are subject to measurement uncertainty. The amendments also

clarify what changes in accounting estimates are and how they differ from changes in accounting policies and error

corrections. The Group is in the process of assessing the impact of the application of the amendments to its financial

statements.

• Amendment in IFRS 10 Consolidated Financial Statements and IAS 28 Investments in Associates and Joint

Ventures: Sale or Contribution of Assets between an Investor and its Associate or Joint Venture

The amendments address an acknowledged inconsistency between the requirements in IFRS 10 and those in IAS

28, in dealing with the sale or contribution of assets 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 subsidiary or not). A partial gain or loss is recognized 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 indefinitely pending the outcome of its research project on

the equity method of accounting. The amendments have not yet been endorsed by the EU. The Group is in the

process of assessing the impact of the application of the amendments to its financial statements.

• IAS 1 Presentation of Financial Statements: Classification of Liabilities as Current or Non-current

(Amendments)

The amendments are effective for annual reporting periods beginning on or after January 1, 2024, with earlier

application permitted, and will need to be applied retrospectively in accordance with IAS 8. 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 management 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

current 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 liability’s classification. Additional disclosures are also required

for non-current liabilities arising from loan arrangements that are subject to covenants to be complied with within

twelve months after the reporting period. The amendments have not yet been endorsed by the EU. The Group is in

the process of assessing the impact of the application of the amendments to its financial statements.

• IAS 12 Income taxes: Deferred Tax related to Assets and Liabilities arising from a Single Transaction

(Amendments)

The amendments are effective for annual periods beginning on or after January 1, 2023 with earlier application

permitted. The amendments narrow the scope of and provide further clarity on the initial recognition exception under

IAS 12 and specify how companies should account for deferred tax related to assets and liabilities arising from a single

transaction, such as leases and decommissioning obligations.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

213

4.2 CHANGES IN ACCOUNTING POLICIES AND DISCLOSURES (CONTINUED)

The amendments clarify that where payments that settle a liability are deductible for tax purposes, it is a matter of

judgement, having considered the applicable tax law, whether such deductions are attributable for tax purposes to the

liability or to the related asset component.

Under the amendments, the initial recognition exception does not apply to transactions that, on initial recognition, give

rise to equal taxable and deductible temporary differences. It only applies if the recognition of a lease asset and lease

liability (or decommissioning liability and decommissioning asset component) give rise to taxable and deductible

temporary differences that are not equal. The Group is in the process of assessing the effect of applying the

amendments to its financial statements.

• 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, with earlier

application permitted. The amendments are intended to improve the requirements that a seller-lessee uses in

measuring the lease liability arising in a sale and leaseback transaction in IFRS 16, while it does not change the

accounting for leases unrelated to sale and leaseback transactions. In particular, the seller-lessee determines ‘lease

payments’ or ‘revised lease payments’ in such a way that the seller-lessee would not recognise 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 recognising, in profit or loss, any gain or loss relating to the partial or full termination of a lease. A seller-lessee

applies the amendment retrospectively in accordance with IAS 8 to sale and leaseback transactions entered into

after the date of initial application, being the beginning of the annual reporting period in which an entity first applied

IFRS 16. The amendments have not yet been endorsed by the EU. The Group is in the process of assessing the

effect of applying the amendments to its financial statements.

4.3. SIGNIFICANT ACCOUNTING JUDGMENTS AND ESTIMATES

The preparation of financial statements requires Management to make estimates and assumptions that affect the

reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial

statements and the reported amounts of revenues and expenses during the reporting period. Actual results may

ultimately differ from those estimates. The principle judgments and estimates referring to events, the development of

which could significantly affect the items of the financial statements during the forthcoming twelve month period are as

follows:

Post-retirement benefits

a) The Parent Company provides to Group’s employees and pensioners supply of electricity at reduced tariffs. Such

reduced tariffs to pensioners are considered to be retirement obligations and are calculated at the discounted value

of the future retirement benefits deemed to have accrued at year-end based on the employees earning retirement

benefit rights steadily throughout the working period. The relevant retirement obligations are calculated on the basis

of financial and actuarial assumptions.

b) According to Law 4533/2018 (OG A’ 7527/4/2018) PPC and its subsidiaries pay an one-off allowance to the

beneficiaries of pension (who are insured employees leaving PPC) in proportion to the years of actual service to

PPC. This allowance cannot exceed the amount of €15.000 for insured employees which are retiring due to the

termination of the employment contract, or due to the fact that insured employees reached the age limit or due to

another reason for leaving, according to the provisions of the law.

The above is a defined benefit plan in accordance with the provisions of IAS 19. The present value of the liability

assumed by PPC and its subsidiaries, is calculated at the end of each year using actuarial methods and is a past

service cost for service provided in previous periods.

Details of the underlying assumptions and estimates of the above mentioned post - retirement benefits are included in

Note 31.

Fair value and useful lives of property, plant and equipment

The Group carries its property, plant and equipment (except for mining land and lakes) at revalued amounts

(estimated fair values) as determined by an independent firm of appraisers. Revaluation is performed periodically

(every three to five years). The determination of the fair values of property, plant and equipment requires from

management to make estimates, assumptions and judgements with respect to the ownership, the value in use and

the existence of any economic, functional and physical obsolescence of property, plant and equipment.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

214

4.3 SIGNIFICANT ACCOUNTING JUDGMENTS AND ESTIMATES (CONTINUED)

The last revaluation of property, plant and equipment was conducted on December 31

, 2019. In addition, within

2021 the valuation of the tangible fixed assets of the Distribution Network and the tangible fixed assets of the

Lignite subsidiaries took place. The main estimates, assumptions and judgments made for the determination of

their fair value are included in Note 15. Morever, as of December 31

, 2022 Management of the Group, taking into

account changes in the economic environment as well as developments within the year of the key assumptions

used in the recent revaluation of property, plant and equipment, believes that any change in the fair value of

property, plant and equipment will not have a significant impact on the accompanying separate and consolidated

financial statements.

Furthermore, the management makes estimates regarding the total and the remaining useful lives of property,

plant and equipment which are subject to periodic review. Useful lives as estimated are included in Note 4.4.

Impairment of property, plant and equipment and intangible assets

The Group assesses at each reporting date whether there is an indication that a long – term asset may be impaired.

The determination of whether such indications exists, requires from Management to make estimates, assumptions

and judgments with respect to external and internal factors that may affect the recoverability of assets, as well as

assumptions on the determination of the cash flow generating units. More specifically, external factors include the

change in the institutional framework, inflation, interest rates. On the other hand, internal factors are related to the

internal decisions and the business plan of the Group and the Company. Indicatively, the key assumptions for the

impairment test are the weighted average borrowing costs and the future cash flows of the assets under

consideration.

The Group and the Parent Company as lessee

The Management, in order to measure the right-of-use assets, determines the lease term as the non-cancellable

term of the lease, together with any periods covered by a) an option to extend the lease if it is reasonably certain to

be exercised, or b) an option to terminate the lease, if it is reasonably certain not to be exercised.

In determining the lease term, Management assesses all the facts and circumstances that create economic

incentive in order to exercise the option of renewal or not exercise the option of termination.

After the commencement date of the lease, Management reassesses the lease term if there is a significant event

or change in circumstances that is within their control and affects their ability to exercise (or not to exercise) the

option to renew (for example a change in the Group’s and the Parent Company’s business strategy).

In addition, the Management in order to calculate the financial lease liability determined the incremental borrowing

rate (IBR) at the lease commencement date as the interest rate implicit in the lease contract is not readily

determinable. The IBR is the rate of interest that the Group and the Parent Company would have to pay, to borrow

over a similar term and with a similar security, the funds necessary to obtain an asset of a similar value to the right-

of-use asset.

Decommissioning and removal costs of property, plant and equipment and mines’ land restoration costs

Based on the provisions of IAS 16 “Property, plant and equipment” the cost of an item of property, plant and equipment

includes, among others, the initial estimate of the costs required for the dismantling and removal of such an item.

These costs are quantified and recognized in the financial statements in accordance with the provisions of IAS 37

“Provisions, contingent liabilities and contingent assets”, while any subsequent change in the measurement of this

provision is treated in accordance with the provisions of IFRIC 1.

The respective provision includes the land remediation cost, the cost of dismantling the existing equipment/machinery,

the cost of demolition of buildings and collection of any waste from power plants and mines. At the time of their

dismantling and removal, the actual cost and the commencement and expiration date of the relevant works may differ

from Management’s estimate.

In addition, the Group and the Parent Company, in order to calculate the provision of decommissioning, determined

the discount rate that reflects the current market estimates for the time value of money and the risks associated with

the liability.

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

215

4.3 SIGNIFICANT ACCOUNTING JUDGMENTS AND ESTIMATES (CONTINUED)

Regarding the remediation of the environment of the hydro power plants, the Group and the Parent Company estimate

that the relevant cost in present values is not significant on December 31

, 2022 and therefore they have not

established any provision. In the future the actual commencement date of the relevant works and the remediation cost

may differ from Management’s estimate.

Details of the underlying assumptions and estimates for the decommissioning provision are included in principal

accounting policies and in Note 32.

Provisions for risks

The Group establishes provisions associated with claims by third parties against companies of the Group and which

might lead to an outflow of resources for their settlement. The provision is established based on amounts claimed and

the possible outcome of the legal dispute.

Provisions for trade receivables

The Group and Parent Company apply the simplified approach set out in the Standard IFRS 9 for the calculation of

Expected Credit Losses, according to which the respective provision is always measured in amount equal to the

expected credit losses over the life of customer receivables. The provision for doubtful receivables is formed for high

voltage customers on an individual basis in the assessment of the expected credit loss per customer, while for the

estimation of the expected credit losses from medium and low voltage customers, credit loss provision tables are

applied with an ageing analysis of the trade receivables balances, based on the historical data of the Group and the

Parent Company for credit losses and adjusted for future factors with respect to debtors and the economic

environment.

Provisions for income taxes and recognition of deferred tax receivables

Current provisions for income tax liabilities for current and prior years are calculated at the amounts expected to be

paid to the tax authorities, using the prevailing tax rates at the balance sheet date. Provision for income tax includes

current taxes reported in the respective income tax returns and potential additional taxes that may be imposed by

the tax authorities upon settlement of the unaudited tax years on the basis of the findings of prior tax audits.

Therefore, final settlement of the income taxes might differ from the income taxes that have been accounted for in

the financial statements. From the fiscal year 2011 onwards, the Parent Company and several of its subsidiaries are

audited for tax purposes by the Certified Auditors Accountants in accordance with the provisions of Income Tax

Legislation. The audit for the fiscal year 2022 is ongoing and the relative tax conformity report will be issued after the

publication of the financial statements for the year 2022. If, at the completion of the tax audit, additional tax liabilities

arise, the Management estimates that these will have no material effect on the financial statements. Deferred tax

receivables are recognized on carried forward tax losses to the extent that it is probable that future taxable profits will

occur to offset carried forward tax losses. Deferred tax receivables that are recognized, require Management to make

assessments as to the time and level of realization of future taxable profits.

Revenue recognition from consumed and non-billed energy and Contract Assets with low voltage customers

Management considers that its customers consume the benefit of electricity over the period of the sale, while the

Parent Company continues to fulfil its contractual liabilities. For this reason, revenue is recognized based on actual

quantities of electricity consumed and based on an estimation of electricity consumed (unbilled revenue).

Especially for low voltage customers at each balance sheet date, unbilled revenue is recorded to account for electricity

delivered and consumed by these customers but not yet billed. Unbilled revenue is estimated using certain

assumptions with respect to quantities of electricity consumed, network losses and average electricity sale prices. The

actual amounts that will be finally billed may differ from those provided for.

Recognition of revenue from customers’ contributions

The Group estimates that customers’ contributions refer to the initial and continuous connection to the distribution

network which is a distinct service, separate from electricity sale. The service which is promised to be delivered is

the only one to be executed by HEDNO and this transaction is considered a separate contractual obligation.

Therefore, revenue from customers’ contributions is recognized as the service transferred to the customer. As the

contract with the customer is not of a specific time duration, the revenue is recognized based on the useful life of

the distribution network property, plant and equipment (35 years).

PUBLIC POWER CORPORATION S.A. AND SUBSIDIARIES

NOTES TO THE FINANCIAL STATEMENTS DECEMBER 31, 2022

(All amounts in thousands of Euro, unless otherwise stated)

216

4.4. PRINCIPAL ACCOUNTING POLICIES

Foreign currency translation

The functional and reporting currency of all the Group entities is the Euro. Transactions involving other currencies

are converted into Euro using the exchange rates, which were in effect at the time of the transactions. At the balance

sheet date, assets and liabilities that are denominated in foreign currencies are adjusted to reflect the current

exchange rates at the balance sheet date. Gains or losses resulting from foreign currency adjustments are reflected

in foreign currency gains (losses), in the accompanying statements of income. Non-monetary items in foreign

currency which are valuated at acquisition cost are converted using the exchange rate of the date of acquisition.

The non-monetary items which are measured at fair value in foreign currency are converted using the exchange

rate of the fair value’s calculation date. The profit or loss from the conversion of non-monetary items is treated in

the same way as the profit or loss from the conversion of fair value of these items.

Intangible assets

Intangible assets mainly include software, CO

emission allowances and goodwill from acquisition.

Software

Software programs are measured at their acquisition cost minus accumulated depreciation and impairments. In

case of withdrawal or sale, the cost of acquisition and depreciation are written off. Any profit or loss resulting from

the write-off is included in the Statement of Income. Software is depreciated using the straight line amortization

method over a five-year period.

Emissions Allowances (CO2)

The Parent Company acquires CO2 emission allowances in order to meet its obligation arising from the actual CO

emissions of its electricity generation units. This liability is measured at fair value to the extent that Parent Company

has the obligation to cover its emissions through purchases (after offseting of any free CO

emission rights held).

Emission rights purchased and held are recognized as intangible assets, at their acquisition cost less any

accumulated impairment loss. As the cash flows of CO2 emission allowances relate to the operating activities of

the Group and the Parent Company, are shown in the cash flows from operating activities in the Cash Flow

Statement.

Goodwill