Responsibility in action. Responsibility for all. · 7 WIND Hellas Telecommunications S.A. is...

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Responsibility in action. Responsibility for all. 2011 Sustainability Report

Transcript of Responsibility in action. Responsibility for all. · 7 WIND Hellas Telecommunications S.A. is...

Responsibility in action. Responsibility for all.

2011 SustainabilityReport

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Message from the Chairman of the Board & CEO .............

What we have accomplished in 2011 ..........................................

WIND Hellas 19 years of Communication ................................

The Telecommunications Network ................................................................Retail Network ....................................................................................................Financial Growth & Data ...................................................................................Recognition ...........................................................................................................Participation ..........................................................................................................

Responsibility in Action for All ...........................................................Our Approach to Responsibility ......................................................................Our Stakeholders ................................................................................................We approach important issues responsibly ................................................We promote Responsible Entrepreneurship ..............................................

Corporate Governance ...........................................................................

Our Principles .......................................................................................................Management Practice .......................................................................................Internal Audit ........................................................................................................Communication with Management ...............................................................Confl ict of Interest – Tackling Corruption ....................................................Management Systems and Certifi cations ...................................................

Market .................................................................................................................

Our Telecommunications Network................................................................Products & Services for All ..............................................................................Responsible Products ........................................................................................Responsible Services .........................................................................................Social Product ......................................................................................................Responsible Marketing ......................................................................................Informing the Public ...........................................................................................Customer Satisfaction .......................................................................................Responsible Suppliers ........................................................................................

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Table of contents

Employees ................................................................................................

Human Resources Data ............................................................................Human Rights & Equal Opportunities ..................................................Freedom of Association ............................................................................Additional Benefi ts ......................................................................................Employee Health & Safety .......................................................................Employee Growth & Development ........................................................Internal Communication ...........................................................................Internal Volunteerism ................................................................................

Environment ...........................................................................................

Environmental Policy .................................................................................Environmental Management ..................................................................Materials Used and Waste Production .................................................Energy, Aerial Emissions, and Climate Change .................................Biodiversity ....................................................................................................Water ...............................................................................................................

Society .........................................................................................................

Our Contribution to Society .....................................................................We Support Sports and Culture ..............................................................Education .......................................................................................................Environment .................................................................................................Social Support ..............................................................................................

Objectives and Results 2011 ......................................................

Glossary ......................................................................................................

About the Report .................................................................................

UN Global Compact: Communication on Progress ...

GRI Index & Assessments .............................................................

7.7.17.27.37.47.57.67.77.8

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1. Message from the Chairman of the Board & CEO

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Dear Friends,

2011 was another year of intense crisis for Greece. Circumstances and events brought us face to face with more problems, dilemmas and challenges. The collapse of our economy exceeded all expectations, aff ecting citizens and businesses.

The Telecommunications sector was no exception. The industry revenues continued to fall, infl uenced negatively by the consumer downturn, regulation, and the very high taxes imposed on our services. In such an environment, the strategy we pursued at WIND Hellas combined sustainable entrepreneurship with corporate responsibility:

We continued to invest. We paid €93.2 million to the state from own funds to renew all the rights of use held by our company since 1992, in order to provide mobile telephony services over GSM. At the same time, we invested almost €90 million in the continuous development of our infrastructure. Aiming to off er our subscribers the experience of wireless broadband Internet, we launched a major project to completely modernize our 3G network in order to create one of the fastest and most advanced mobile networks in Europe.

We off ered more aff ordable products to consumers. The past year, Greeks sought ways to control their telecommunications costs while trying out new services, mainly in the fi eld of wireless internet. Our customers changed and we changed as well, off ering new solutions for all market segments.

We didn’t forget our social footprint. We enabled more activities of public participation, we extended our support to more social groups, and we conducted our business with respect to the environment. As you read through the document you hold in your hands, you will have the opportunity to learn more about the ways we gave back to society, honouring our commitment to the UN Global Compact. 2012 has proven equally critical and it seems that the conditions in our country will remain diffi cult for some time. Our goal at WIND is to maintain our momentum despite the challenges. It is no coincidence that amidst the crisis we confi dently restate our vision:Communication for all, WIND for all. We will pursue this through the prism of sustainable development and corporate responsibility, keeping our eye steadily focused on our long-term perspective.

Nassos ZarkalisChairman of the Board & CEO

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2. What we have accomplished in 2011

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WIND... in fi gures

05/2011: the new WIND to All+ tariff plans are launched and off er cost control tools to the consumers.05/2011: the popular prepaid Q card is renewed and off ers more savings to its customers. 06/2011: the Company’s 3G network modernization begins. This is one of the major infrastructure projects in the Greek

telecommunications market, as well throughout Europe. The project has a 3-year horizon for completion and will create the fastest 3G network in the country, with speeds up to 42Mbps off ering a true wireless broadband internet experience.

07/2011: all WIND clients, both residential and businesses, receive a new printed bill with the option for usage breakdown and complete control of their expenses. The digital WIND e-BILL is also redesigned.

11/2011: WIND supports the 29th Athens Classic Marathon as Offi cial Sponsor. It creates the WIND Running Team with 1,000 runners and participates in the Marathon for a good cause, raising more than €40,000 for the Ark of the World organisation.

11/2011: WIND makes a further major investment in the Greek economy and the telecommunications market by renewing its 900MHz & 1800MHz frequency rights of use. To this end, it pays the amount of € 93.2 million from its own funds.

stores277 total investments €181.5 milemployees1,340years of presence in

the Greek market19

avoidance of emissions of carbon dioxide from energy saving projects

actions for reducing paper usage which on an annual basis may result in over 10 tons of paper savings

10 tn new base stations in the context of modernising Telecommunications Network

6405,877 tn CO2training hours in technical knowledge and management skills

8,914

fixed & mobile telephony customers3,932.3 mil National Fiber Optics

Network4,000 klm reduction in quantity of oil consumed16% social insurance cost€10.7 mil

raised for the Ark of the World, through the participation of the WIND Running Team in the 29th Athens Classic Marathon

€40,000

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3. WIND Hellas 19 years of communication

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WIND Hellas Telecommunications S.A. is presently one of the largest telecommunications companies in Greece. It was founded in 1992 and launched its operations in the Greek market in June 1993, when the fi rst call was made from a mobile phone in Greece. A� er 19 years of operation, the Company has established itself as a pioneer in mobile telephony technology and presented innovative products that changed the way consumers communicate.

In 2007, WIND acquired and merged with Tellas, a fi xed telephony and internet operator, thus launching one of the largest projects to integrate network infrastructures and IT systems at a European level. By bringing together mobile, fi xed telephony and broadband internet infrastructures, it created the fi rst integrated telecommunications network in Greece.

In order to develop infrastructures, WIND has invested €2.1 billion since its establishment in one of the largest private investment projects in Greece. In 2011, WIND launched another major project, modernising its 3G network throughout Greece in order to off er its subscribers a true mobile broadband experience with speeds up to 42Mbps. This is one of the major projects that will be implemented in Greece with the time horizon for completion being 2015.

Presently, WIND Hellas is the only Greek telecommunications operator that off ers consumers mobile telephony, fi xed telephony and internet in an integrated off er providing Communication for All, in line with its philosophy.

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3.1 Telecommunications Network

Our integrated network enables all users to communicate with a high degree of fl exibility, coverage and guaranteed quality, according to the needs and choices of subscribers, whether for mobile telephony, fi xed telephony or internet.

It is based on an integrated architecture, characterised by its fl exibility, reliability and simplicity. It is an infrastructure, a platform, for all telecommunications services, off ering the best voice and data services, whilst it has more than suffi cient capacity to meet the needs in high demand periods.

Our mobile network’s population coverage is close to 100% nationwide and 70% of the installed telephone lines throughout Greece in fi xed telephony and broadband internet, with 262 co-locations at telecommunications nodes.

In the context of continuously developing our telecommunications network and implementing the development law 3299/2004, we proceeded to deploy broadband network infrastructures in the Region of Attica and Thessaloniki and also to provide innovative electronic communication and broadband services. The project was supported by the development law with approximately €1.7 million.

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3.2 Retail Network

3.3 Financial Growth & Data

In meeting our main objective to better serve the needs of our customers and provide answers to any and all of their questions, WIND Hellas has developed a well organised retail network throughout Greece.

WIND Hellas’ shareholders are six of the largest investment funds worldwide, with many years of experience in the fi nancial sector, and the telecommunications sector in particular, and more than $80 billion under management. Following the acquisition of WIND Hellas in 2010, they provided €420 million in direct investments in the Company to fi nance its development, thus securing its long-term prospects. Their investment is one of the highest private foreign investments in Greece made in the past two years.

Our shareholders control WIND Hellas via Largo Limited, a holding company. The Board of Directors of Largo Limited is responsible for the Company’s strategy and the implementation of its operational plan.

The powerful capital structure of WIND Hellas and the commitment of its shareholders to its long-term prospects enable the Company to step up its commercial eff orts and to develop its strategic competitive advantages in order to expand its presence in the Greek telecommunications market.

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In 2011, in very unfavourable macroeconomic conditions, WIND Hellas was able to stabilise its position in the mobile telephony market and at the same time to increase its share in fi xed telephony by changing its operating model. Among the few Greek companies which have zero borrowing,

WIND generated positive cash fl ows to fi nance its expenses and investments exclusively through its own funds, thus retaining its fi nancial autonomy. In 2011, WIND focused on eff ective cost management and reduction of operational expenses, freeing up capital for investments in new infrastructures.

WIND Hellas is the only single telecommunications operator in Greece that off ers fi xed and mobile telephony services, as well as broadband internet services.

2010 2011Turnover €787.4 mil. 1 €661.8 mil.

Investments €90.9 mil. €181.5 mil. 4

Social insurance cost €11.5 mil. €10.7 mil.

Total fi nancial liabilities €548.5 mil. €590.7 mil.

Total equity €436.6 mil. €176.3 mil.

Total assets €1,498.3 mil. €1,194.9 mil.

2010 2011Mobile & fi xed telephony customers 3,959.9 k. 2 3,932.3 k.

Stores 342 3 277

Employees 1,506 1,340

Data

(Data: 31/12/2011)

1. Published fi nancial data

2. The revised data is resulted from an added customers’ category

3. It refers only to WIND stores

4. Including funds allocated for the renewal of the frequency rights of use

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WIND Running Team

3.4 Recognition

The WIND Running Team took the fi rst place in the General Team Category for the 5 and 10 km race of the Athens Classic Marathon 2011. This was the largest team ever to participate in the event, as 1,000 people ran in WIND colours. It should be noted that WIND invited runners to run with a WIND Running Team vest, off ering €10 to the Ark of the World on behalf of every team member.

The WIND team received its award from the SEGAS-Hellenic Association of Amateur Athletics in a special ceremony that took place in the Hellenic Olympic Committee’s amphitheatre in the presence of state representatives, eminent sports personalities and a large audience. Moreover, SEGAS presented WIND an award for its overall contribution to the Athens Classic Marathon 2011 as the Offi cial and Named sponsor of the 5 & 10 km races.

Relying on the technological capacity of its infrastructure, WIND supported the event by off ering mobile and fi xed telephony and wireless internet services, whilst it off ered all runners free innovative services, such as the WIND Sporty Pal special training application and automatic updates through SMS when runners crossed the fi nish line, a service that was launched for the fi rst time at the 29th Athens Classic Marathon.

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WIND Hellas was awarded fi rst prize for the Best CSR campaign for its outreach campaign named “Kids@safety, internet, mobile & child” at the “THALES - CEO & CSR 2011” awards, staged as part of the CEO & CSR Money Conference. The prize awarded for the campaign recognises the Company’s eff ort to provide essential and constructive information to Greek parents on the use of new technologies by children and adolescents. The “Kids@safety, internet, mobile & child” campaign is conducted by WIND under the scientifi c supervision of Child Psychology Professor Ioannis Tsiantis, MD, DPM, FRC Psych., and Scientifi c Director of the Association for the Psychosocial Health of Children and Adolescents (APHCA), and the collaboration of APHCA within the framework of the corporate responsibility strategy, “In Action”.

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3.5 Participation

The telecommunications sector is continuously evolving from a technological and commercial standpoint, both in Greece and internationally. At the same time, changes and developments are noted in the broader institutional and business environment of the sector. In order to foster responsible entrepreneurship, transparency and contribute to the sector’s progress through the exchange of know-how, WIND Hellas participates in a large number of institutional bodies and authorities, so as to promote the role of telecommunications in the economy and society.

In this context, WIND Hellas participates in:

Sustainable Development agencies

� Global Compact Network Hellas

� Hellenic Network for Corporate Social Responsibility

� Institute of Communication

� SEV (Hellenic Federation of Enterprises) Council for Sustainable Development

Professional associations

� Association of Mobile Telephony Companies of Greece (EEKT)

� Hellenic Federation of Enterprises (SEV)

� Athens Chamber of Commerce and Industry

� Federation of Hellenic ICT Industries (SEPE)

� European Competitive Telecommunications Association (ECTA)

� GSM Association Europe

� Mobile Challengers

Hellenic Federation of Enterprises

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4. Responsibility in Action for All

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WIND Hellas knows the important role that our sector plays in the Greek economy and society, as well as the importance of our stakeholders in the context of accomplishing our business goals, which is why we are improving our performance, whilst at the same time we are establishing our long term sustainability, taking into account the aspirations and expectations of our stakeholders.

Our priority is to adopt responsible policies and practices for our business operations based on our Corporate Responsibility strategy, which is expressed through our Company’s key commitment and its focus on international principles for protecting Responsible Entrepreneurship, as expressed in the Global Compact which has been incorporated in our operations since 2008.

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4.1 Our Approach to Responsibility

The Corporate Responsibility strategy constitutes a priority for our business operation and is embedded in our growth strategy and our development procedures. Our long term commitment to Sustainability and Corporate Responsibility is refl ected in our entire internal environment, and the actions that we develop, the targets we set and the appraisal of our results on an annual basis.

Board of DirectorsThe Board is responsible

for the Corporate Responsibility strategy Corporate Affairs DivisionThe Corporate Affairs Executive Director, is responsible for implementing and promoting Corporate Responsibility issues

Corporate Responsibility DepartmentThe department develops Corporate Responsibility programmes and actions both in the internal and external environment of WIND, communicates with the stakeholders and coordinates the CR Committee for issuing the Report

Corporate Responsibility CommitteeThe Committee collects data and

dra�s the Sustainability Report.It promotes Responsibility

in our Company’s internal environment

is resppromo

CorpoThe deprograexternwith tthe CR

sibility Committeeee collects data andustainability Report.

motes Responsibilityternal environment

The Governance Structure of Our Corporate Responsibility

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In this context we are committed to:

off ering responsible products and services, with the purpose of meeting important social needs, such as the need to communicate, throughout Greece.

minimising the environmental impact resulting from our business activity, increasing energy saving, recycling and development of network infrastructures in an environmentally friendly manner.

informing and mobilising our people, urging them to work as volunteers and to become ENGAGED CITIZENS.

supporting Organisations and Bodies which, through their work, contribute to the environmental protection and the support of people and mainly children in need.

The fi ve pillars of our Responsible Commitment are shown in the following chart of our Responsible Activation.

Corporate Governance Market Employees Environment Society

responsible managementethical competitioncommunication withsocial partnerscontribution to technological innovation

quality of products and servicesresponsible marketingsocial productresponsible procurementcustomer satisfactioncorrect information to the public

health & safetypersonal developmentemployee rightsfringe benefitslabour conditionsinternal communication

protection of natural environmentinformation and outreach to the publicreduction of environmentalimpact

support to vulnarable groupscontribution to local communitiesproviding education opportunitiesinformation and outreach to the public

The Corporate Responsibility strategy that we have adopted at WIND Hellas is called “In Action”. Its aim is to apply our responsible policy to our business activity, our employees, the environment and society.

Our strategy for Corporate Responsibility

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We determine who our stakeholders are based on

the impact of our business activity. Accordingly, we

have developed a specifi c approach for precisely

identifying and mapping our stakeholders, as well

as our relationship with them, which we follow up

on an annual basis. Thus, we can ensure the precise

determination of our stakeholder groups, with the

objective of engaging with them in an open and

balanced manner.

In the above framework, we have developed a reliable

mechanism for observations and comments, which

we manage accordingly. Once a year, the Corporate

Responsibility department, a� er checking the

information collected and taking into account the

Company’s targets, prioritises stakeholder groups and

the important issues and then draws up a plan for

dialogue development.

Our stakeholders either belong to the internal

environment of the Organisation or exist and act

in the external environment, in Greece and/or

internationally.

4.2 Our Stakeholders

Prioritizing Stakeholders

Customers

Shareholders

Inte

rnal

External

MediaNGOs

Com

mercial Network

Empl

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Auth

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es

Associates

SuppliersG

over

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Loca

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Comm

unityAcadem

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Regu

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Goverment

Central

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The continuous two-way communication with our

stakeholders is the focus of our operations. We work

closely with diff erent stakeholder groups in order to

realise our vision for communication and responsibility

in Action for All, through specifi c initiatives and

innovative approaches.

Through appropriate policies and procedures, we have

established two-way communication and dialogue with

our stakeholders. In this context, we off er continuous

information regarding our business activity, whilst

at the same time we listen carefully to the opinions,

questions and positions put forth by each stakeholder.

This is also demonstrated in our Sustainability

Report, a tool of information and dialogue with our

stakeholders, whose comments we take very seriously

into account.

Our commitment to being close to them is generating

valuable knowledge vis-à-vis the needs of our

stakeholders and defi nitively guides our Company’s

Management. Our ongoing dialogue with diff erent

groups of stakeholders highlights issues and shapes

proposals which subsequently give rise to action,

through which the Company tries to respond to

the challenges and opportunities off ered by the

environment and its stakeholders.

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Determiningthe Shakeholders

Challenges & Opportunities

Recording

Actio

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Prio

rities

Two-W

ay C

omm

unic

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4.2.1 Dialogue with Stakeholders

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Stakeholders Two-way Communication Priorities – Dialogue Issues

Regulatory Authorities

Participation in consultations (1) Network Infrastructures & InvestmentsParticipation in researches (1) Quality of ServicesParticipation in conferences (1) Market

Competition

NGOs / Citizen Organizations

Partnerships (4) EducationSupport (1) Health & SafetyMeetings (2) Environment Social Contribution

Central Government / Local Government

Meetings (5) E/M RadiationParticipation in local conferences / workshops (3) Economic Development Environment Investments in Technology and Infrastructure Supporting the Local Economy, Social, Cultural

and Educational Institutions

Customers (Individuals – Businesses)

Customer Satisfaction Surveys (2) Technical Issues on Products & Services Customer Service Centre (1) Quality of ServicesOnline Communication (1) Price break down of Telecommunications ServicesSurvey on Corporate Reputation (3) E/M RadiationComplaint Telephone Line (1)

Academic Community

Support to Scientifi c Programmes (1) E/M RadiationEducational Seminars (5) Safe Use of the Mobile Phone and the InternetInformation Days (5) Education

Innovation Health & Safety

Media

Press Conferences (2) ManagementMedia Trips (4) Financial & Commercial ResultsField Trips (3) Regulatory MattersMeetings (1) Quality of Services & Network CoveragePress Releases &Presentations (1) Infrastructures, Technology & Innovation

Social Contribution Environmental Operations

Suppliers

Working Visits (4) Procedural MattersParticipation in industry Associations (5) Financial IssuesOn-going Information & Support (1) Timely Delivery

Safe delivery conditions for employees

External Environment

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Stakeholders Two-way Communication Priorities – Dialogue Issues

Shareholders

Scheduled Shareholders’ Meetings (1) Financial Development / ResultsTargeted Communication (2) ManagementConference Calls (2) Investment Plan Strategic Choices Socioeconomic Developments

Employees

WIND About Magazine (3) EducationNewsletter Eco News (3) Health & Safety

Ιntranet (1) Equal Opportunities for Professional Development

Organisation of Events (3) Business continuity issuesMeetings with Employees’ Union (1)

Commercial Network

Εxtranet (Communication System) (1) Corporate GovernanceCommercial Conferences (3) Sharing Knowledge & Good PracticesMeetings with Sales Executives (2) Initiatives for supporting local community needsOngoing Information & Support (1) Training in New Products & Services

Customer ServiceRecycling, Targets and Ecological Awareness

1 On an on-going basis 2 Regularly 3 Periodically (2-4 times a year) 4 On an annual basis 5 On a case by case basis

BRAVO 2011In 2011, WIND Hellas pursued a dialogue with its stakeholders via BRAVO, an institution in which it participated. One of the tools facilitating the dialogue between our Company and our stakeholders on issues developed and presented in this report, is our participation in BRAVO institution, organised by QualityNet Foundation. This institution

facilitates the dialogue on Sustainable Development between organisations that issue reports and key social partners, enabling the matters to be tackled in a comprehensive manner, appropriate to their importance. Representatives of academic, institutional and business bodies, local government, the press and various NGOs participate in this institution.The results of the dialogue are taken into account in the context of continuously improving our Company’s reporting.

Internal Environment

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4.3 We approach important issues responsiblyWe prioritise Corporate Responsibility issues with respect to their importance for the Company, our stakeholders, society and the environment.

These are determined through an on-going assessment and review process, based on our Corporate Responsibility strategy and the international standards for determining important issues. The following issues are of importance to us in 2011:

CorporateGovernance

We develop Compliance Procedures

With the main objective being to secure that we operate in a context of transparency and in line with our commitments, we have established the Executive Compliance Committee, so as to ensure the oversight of our Company’s Compliance Management System with respect to legal and regulaory requirements.

(More on page 30)

(More on page 43)

Market We create New Products & Services

Cost control

Account Guarantee Service

In responce to the new social and economic conditions, we have proceeded to create products and services that will ensure comprehensive cost control solutions for our customers.

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Employees We are fostering the spirit of Internal Volunteerism

With the aim of acting for a good cause, we created the WIND Running Team, with 1,000 members, that took part in the 29th Athens Classic Marathon and was rewarded for its overall contribution by SEGAS.

(More on page 80)

Society We inform Parents & Educators on the Correct Use of Mobile Phones & the InternetIn the context of a systematic outreach action to inform the broader public and our subscribers on the safe use of mobile telephony and the internet by children, we developed the campaign kids@safety, internet, mobile & child, which includes a series of informative, educational and entertaining actions and is implemented in collaboration with APHCA.

(More on page 114)

Environment We manage our Environmental Impact

With the purpose of improving our Company’s environmental performance, we have undertaken two very important projects: α) installing hybrid energy production systems at remote base stations, andβ) modernising the Telecommunications and Core Network.

(More on pages 97-99)

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4.4 We promote Responsible Entrepreneurship

4.4.1 An initiative to support the Greek economy

4.4.2 Update on developments in the telecommunications market

WIND Hellas became a member of “Alliance for Greece”, joining forces with a host of other market bodies that off er their services free of charge to pro-mote domestic and international tourism in Greece. In order to support this movement, WIND undertook a series of communication actions notifying its cus-tomers, as well as the broader public, on the need to strengthen Greece’s image and to stimulate the market.

“Alliance for Greece” is a way of supporting the na-tional economy in practice, as well as contributing to the establishment of a new development paradigm for Greece based on fair competition and the values of collaboration and protection of common interest.

“Alliance for Greece” constitutes an initiative of the Hellenic Advertisers Association (SDE) with the sup-port and under the auspices of the Ministry of Culture & Tourism and the Greek National Organisation for Tourism (GNTO), aiming at promoting tourism, culture and sports, in the context of volunteerism and Corpo-rate Social Responsibility.

Special Edition

On the occasion of our participation in the Economist conference, we developed a special edition in which eminent scientists, academics and other institutional bodies expressed their views on the role of telecommunications in a period of economic recession.

“In the present adverse economic conjuncture, investments in broadband infrastructures and networks are not a superfl uous luxury. Instead they are requirements in order to enjoy a wider range of potential benefi ts which will contribute to the economy.“

by Yiannis Stournaras, Professor at the University of Athens, General Director of the Foundation for Economic and

Industrial Research (IOBE) Aggelos Tsakanikas,

Head of Research at IOBE, Assistant Professor at the Technical University of Athens - NTUA

All together in an ALLIANCE FOR GREECE

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4.4.3 Participation in conferences

In 2011, we participated and supported conferences on issues related to the telecommunications sector, the Greek economy and specialised industry conferences in Athens and the rest of Greece.

“The Cyber Crime Unit in cooperation with the

Ministry of Citizen Protection and with support of

sponsors, including WIND thanks to its social policy

and the experience and expertise in internet issues,

stages informative conferences in Greece in which

Greek citizens and especially parents and children

can be informed through interactive participation

both on Internet security and the dangers that lurk in

navigating it.

Such cases unfortunately occur daily. Awareness

is therefore the fi rst precautionary step and that

is precisely the objective of the Ministry of Citizen

Protection and Electronic Crime through activities

carried out in Greece. Early response is the fi rst step

in addressing any risk.

To date, 48 informative conferences have been held

in Greece, through which citizens came in contact with

offi cers of the Cyber Crime Unit, talked about their

concerns and their problems, learned how to talk to

their children and are trained to navigate safely.

WIND’s support, provided in the context of the CSR

programme implemented by the Company, is crucial

and valuable for the Ministry of Citizen Protection

and the Cyber Crime Unit and for the opportunities it

provides for them to communicate with people on this

sensitive issue.”

Emmanouil Sfakianakis, Head of the Cyber Crime Unit

October 2011:13th Info-Com World Conference: “Digital Greece: The day a� er the crisis”

October 2011:Tedx Academy

February 2011:KPMG Ten Years Human Resources Awards

May 2011:Economist Conference, 15th Roundtable: “In the a� ermath of the global economic crisis: What’s next?”

May 2011:CEO & CSR Conference

June 2011:One-day conferences in cooperation with the Cyber Crime Unit in Kos, Cephalonia, Ioannina, Rethymno and Mytilini

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5. Corporate Governance

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At WIND Hellas, we know that telecommunications play an important role in our lives and that our business activity impacts on people and society on many levels – economic, labour, environmental and social. For this reason, we have established and applied policies which act as our guide and prove our commitment to providing quality products and services to our customers, protecting their personal data and privacy in telecommunications and preserving the environment.

At the same time, through careful strategic planning, responsible management practices, controls and assessment of our daily operations, we are making certain that we live up to the expectations of customers, associates and society.

Achievements 2011:

We developed a Quality Policyon Electromagnetic Radiation

measurements

We established Complianceand Information Security Committees

We completed a large scaleBusiness Continuity Plan

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5.1 Our Principles

WIND Hellas is a Company with a vision, a clear mission and values on which we base our activities in the telecommunications sector.

Our vision is to play a leading role in the Greek telecom market, focusing on our customers’ needs and off ering comprehensive telecommunication solutions.

Our mission is to off er high quality services, thus earning the respect and appreciation of our customers, understanding their needs in depth and meeting their expectations by off ering trustworthiness, fl exibility and quality.

Our values

Cust

omer

satis

faci

on

Commitment

to results

Innovation

Inventiveness

Corp

orat

eRe

spon

sibi

lity

Speed & Sense

of Emergency

Collaboration &Communnication

Leadership

& Professional

Superiority

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5.2 Management Practice

The current Board of Directors (BoD) of the Company, which was elected in January 2011, consists of the Chairman and two Members. The Chairman of the Board of Directors also acts as CEO. The BoD members take part in its meetings and jointly decide on the items on the agenda, as these are drawn up each time according to the BoD competences.

WIND HELLAS is a Société Anonyme with registered offi ces in Maroussi. The supreme body of the Company is the General Meeting of shareholders, which, according to the Articles of Association, may reach decisions on any matter pertaining to the Company. The management and representation of the Company and the management of its corporate assets fall under the remit of the Board of Directors, which, according to the Company’s Articles of Association, may consist of three (3) to fi � een (15) members.

Board of Directors

In 2011, the BoD was comprised of the following members:

Athanassios Zarkalis, Chairman and CEO,

Ioannis Palaiokrassas, Independent, Non-Executive Member,

Georgios Rallis, Executive Member

Quality Policy. We understand and foster change as the only way to improve. In its Quality Policy, our Company describes the vision, mission and values it applies throughout its operations.

Environmental Policy. We are committed to environmental protection and we engage in actions to this end which pertain to all our facilities and operations.

Quality & Environmental Policy for WIND Stores. We are committed to giving our customers high-quality products and services, as well as a high level of service through our nationwide retail network,, with respect towards customers, society and the environment.

Our Quality and Environmental Policies are posted in our offi ces and our stores, and are also available to all employees electronically through our corporate website (WIND intranet, WIND extranet).

Quality Policy on Electromagnetic Radiation Measurements. We are committed to providing tests/measurements, as well as service in response to the demands of our customers and our stakeholders.

Data Security Policy. Our Company has drawn up this policy in accordance with EU and national legislation on protection of personal data and confi dentiality of communications. It applies it internally and also imposes it on contractual relations with third parties whose scope is related to accessing and handling such data.

Our policies

30

Committees

The Company’s Articles of Association, as in eff ect today, do not distinguish between “executive” and “independent – non-executive” Board members. However, and in accordance with the Company’s BoD decision dated 24.01.2011, which established the incumbent BoD into a body, the BoD members are distinguished into executive and non-executive members; specifi cally, two Executive Members and one Independent – Non-Executive Member sit on the BoD.

The BoD members are chosen on the basis of their sensitivity to economic, environmental and social issues and their primary obligation and duty is to continuously strive to improve the Company’s economic position on the telecommunications market and to protect corporate goals and prospects.

At WIND Hellas, we operate in a context of transparency, with pertinent limitations and commitments for Senior Management set forth in our Articles of Association. Therefore, in accordance with article 27 of the Company’s Articles of Association, it is forbidden for BoD members and Company managers to act in competition to the Company, professionally on their own account or that of third parties or to participate in companies without the permission of the General Meeting. Furthermore, the above persons must, in a timely manner, disclose to the Board of Directors any personal interests that they may have in Company transactions which fall within their duties, as well as any confl ict of interest with the Company or its affi liated businesses.

Executive Management Committee

This informal body, which consists of the CEO, the Chief Offi cers and Executive Directors, decides on day-to-day Company matters. It does not have specifi c and formally assigned competences or functions based on the articles of association or decisions of the Company’s statutory bodies. However, it reaches important decisions with respect to daily operations and the Company’s oversight, dealing with problems that may arise and dra� ing individual strategies.

Executive Compliance Committee

An executive Compliance Committee, whose main aim is to oversee the WIND’s Compliance Management System with respect to legal and regulatory requirements, the Code of Conduct and the relevant Company policies.

This committee convenes at least 4 times a year, or more o� en should it decide to, whilst the minutes of its meetings are at the disposal of the Company’s Board of Directors. The Company’s CEO presides over it and its members are:

� Chief Financial Offi cer

� Chief Human Resources Offi cer

� Legal Counsel

� Internal Audit, Compliance and Quality Offi cer

Mainly, the Committee’s remit consists of periodically reviewing the Code of Conduct and the Company’s policies with respect to employees, executives, managers and associates, monitoring and confi rming

31

the eff ective implementation of the Company’s Compliance Management System, confi rming the implementation and identifi cation of any violations of the regulatory requirements or the Code of Conduct by Company employees, executives, managers and associates, deciding on any penalties or other measures to be taken as a result of Code violation and controlling the available resources of the Compliance Management System and confi rming their adequacy.

Information Security Committee

A special Information Security Committee which convenes at least 4 times a year, or more o� en should it decide to, whilst the minutes of its meetings are at the disposal of the Company’s Board of Directors. The Company’s CEO is the Chairman of the Information Security Committee and its members are:

� Senior Information Security Offi cer

� Chief Information Offi cer

� Chief Network Offi cer

� Legal Counsel

� Internal Audit, Compliance and Quality Offi cer� Corporate Aff airs Executive Director.

The Information Security Committee has as its main objectives to make certain that there is a framework for the development of an Information Security policy in collaboration with all parties involved in its development and implementation; central control of security policy and its implementation; and ensuring and improving the level of confi dentiality, integrity and availability of information managed by WIND’S systems.

Our Organisational Structure

Audit Committee

Internal Audit & Compliance(IA & C)

Chief CommercialOfficer (CCO)

Chief NetworkOfficer (CNO)

Chief FinancialOfficer (CFO)

Legal & Regulatory Affairs(LRA)

Corporate Affairs(CPR AFR)

Chief HR Officer(CHRO)

Supply Chain& Facilities Management

(SC & FMNG)

Chief ExecutiveOfficer (CEO)

Chief InformationOfficer (CIO)

CEO ExecutiveManagement Committee

InformationSecurity Committee

ExecutiveCompliance Committee

(Data: 31/12/2011)

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WIND Hellas has structured the Internal Audit & Compliance Division. Its competence is to provide reasonable independent assurance to the Board of Directors of the parent Company that the Internal Control System ensures compliance with Company policies, practices and procedures. This is accomplished by assessing the eff ectiveness of risk management systems, controls and governance practices.

Management is responsible for the internal control environment. Line Managers are responsible for establishing the appropriate policies and procedures in order to assist the Organisation in achieving its predetermined objectives.

The organisational independence of the Internal Audit & Compliance Division is achieved, since the Internal Audit Department reports directly to the Board of Directors of the parent Company, through the Audit Committee, which consists of 4 independent members.

The Audit Committee assesses and supports the work of the Division, ensures the suffi ciency of the human and technical resources and the unhindered access to information related to the audits. The Committee is convened at least 4 times annually, and, among its other competences, is informed about the audit fi ndings, the proposed corrective actions, and the follow-up activities on the action plan.

The Internal Audit & Compliance Division, in collaboration with Senior Management and Line Managers, carries out annually a Company-wide self risk assessment in order to draw up the annual audit plan. Risk identifi cation and risk assessment is performed and specifi c processes where audits will be performed are defi ned. Audit reports resulting from the conducted audits are submitted to Senior Management and the Audit Committee.

The ever greater breadth of communication channels and the constructive two-way communication between Employees and Management help keep everyone abreast of Company related developments at all points in time. They are conducive to handling the substance of issues and needs arising at a human resources level reinforce teams collaborating with each other and help tap into the power of constructive dialogue. Within this context, the CEO meets regularly with executives from all departments in the Company.

Similarly, in order to decide on a strategy for realising the Company’s investment plan, we communicate with the Company’s shareholders systematically, at regular time periods, with the aim of informing them directly about the Company and the Greek market in general.

5.3 Internal Audit

5.4 Communication with Management

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Transparency and integrity govern all aspects of our business operation. WIND Hellas applies procedures to ensure the elimination of confl icts of interest and corrupt practices.

Our Company has a specifi c organisational structure designed to eff ectively support its operations and accomplish its purpose. Our main activities are carried out on the basis of written processes and guidelines which outline the responsibilities of each Division, Department, as well as the Employees. In this way, through documentation, confl icts of interest and confusion as to competences are avoided. The processes and instructions are available electronically on our corporate intranet (WIND Intranet).

In addition to processes, the Internal Work Regulations for our Company’s personnel further safeguard transparency in labour relations, employee adherence to good business practices, as well as prevention and tackling of incidents of corruption. The purpose of the Work Regulation is to promote the implementation of ethical values, establish a code of conduct for all employees based on respecting laws, to foster transparency and ethics in all our activities, and to create a sound, safe and pleasant work environment. The Internal Work Regulation is accessible to all employees through our corporate intranet (WIND Intranet).

In the context of continuously demonstrating that WIND operates responsibly, the Board of Directors of WIND Hellas approved the “WIND Hellas Code of Conduct”, which is expected to enter into eff ect in 2012. The purpose of the Company’s deployment of the Code of Conduct is to create the appropriate framework in accordance with the principles of good faith, good business practice and professional ethics to allow all employees to be aware of the rules and principles adopted by the Company. The Code of Conduct sets out both the relations among employees in the Company as well as with any third party with whom they come into contact within the framework of their work and competences.

At the same time, in the context of applying the Code of Conduct, communication channels are expected to be set up in 2012 to enable notifi cations on any violations of the Code of Conduct.

An important part of our Company’s operations is subject to extensive audits each year by the Company’s Internal Audit Division and by independent chartered auditors. Among other things, corruption-related business risks are assessed as part of these audits.

5.5 Confl ict of InterestTackling Corruption

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Its scope of application includes:

Design, Development, Provision, Sales, Billing and Support of Integrated Telecommunications Products and Services (Wireless, Fixed, Data, Internet and Broadband) for Consumer and Business Customers;

Design, Development, Realisation, Operations, Support and Maintenance of Telecom & IT Infrastructure, Telecom and Data Networks, IT Applications and Systems;

Design, Development, Monitor, Control and Support of WIND Stores Network.

5.6 Management Systems and Certifi cations

In order to meet the needs of our customers in combination with the protection of the environment and good use of natural resources through our business activities, we have developed and implement an Integrated Quality and Environmental Management System for all our Company’s facilities.

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The Quality and Environmental Management System is certifi ed according to the requirements of international standards.

Quality Management System certifi ed according to the requirements of international standard ISO9001:2008

� Initial certifi cation: June 2001 Certifi cate Registration No. 04 100 011460

� Latest certifi cation renewal: April 2011, (according to the requirements of revised standard ISO9001:2008) Certifi cation body: TUV Hellas (TUV Nord Group)

Environmental Management System certifi ed according to the requirements of international standard ISO14001:2004.

� Initial certifi cation: December 2008 Certifi cate Registration No. 44 104 090360-000

� Latest certifi cation renewal: scheduled for the beginning of 2012Certifi cation body: TUV Hellas (TUV Nord Group)

5.6.1 Certifi cations

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In recognition of the need and our responsibility to protect all our critical operations so as to ensure uninterrupted service towards our customers, even in the case of an incident which could adversely aff ect important business units, systems and/or services, WIND has developed a Business Continuity Management System.

In the framework of this system, in 2011 we completed a wide scale Business Continuity project with the aim of developing and reviewing business continuity plans in the event of specifi c risks covering:

the critical facilities and infrastructures

the critical operations

our employees by groups

the necessary resources

As part of this project, during 2011 we carried out an information and training program for a large number of our Company’s executives on how to react and implement the response plans in the event that specifi c risks / threats arise.

5.6.2 Business Continuity Management

37

The examination and application of additional

mechanisms to further reduce confl icts of

interest and enhance transparency.

The Internal Audit Division’s continued audit

and cross-checking, on a sampling basis,

of the procedure for gathering data for the

Sustainability Report.

The commencement of the Business Continuity

project in order to ensure the integrity of the

fi xed telephony network and the internet in the

event of a disaster or force majeure, which would

include:

� Business Impact Analysis and Risk Assessment

� Business Continuity Plans for the fi xed telephony and internet

network and services

� Disaster Recovery Plans in the event of emergency,

catastrophic failure and force majeure

Goals 2012

6. Market

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At WIND Hellas, we are committed to providing high quality services and products and a high level of customer service that demonstrates our respect for the customer, for the community and for the environment, while strictly following the codes of conduct and ethical competition. Our standing goal is to meet the telecommunication needs of Greece by designing integrated, fully developed products and services, expanding and upgrading our telecommunications network, developing our sales network and safeguarding a quality level of service which leaves our customers fully satisfi ed and protects their personal data to the greatest extent possible. In addition, we undertake to provide our customers with immediate and integrated information on technologies and innovative products by making our stores a point of reference, thus securing an improved sales experience for our customers.

Achievements 2011:

We embarked on the project to fully moderniseour 3G network, one of the largest infrastructure

projects in the country, with the creation of anentirely new radio network that allows for nominal

mobile broadband speeds of up to 42Mbps

We expanded13 telecommunications nodes

and upgraded the backhaul circuitsat more than 173 sites

We redesigned the www.fasmaprogram.grwebsite which provides the publicwith information on E/M Radiation

We provided our customers withthe option of complete control over their spending

through the Billing Guarantee Service

We automated the activation procedurefor fixed broadband connections

in order to simplify the customer experience duringthe activation of Double Play services

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6.1 Our Telecommunications Network

At WIND, we aim to bring mobile broadband telephony closer to Greek users through investments in our new network and the commercial off ers we make. We are developing our network in a manner that is both responsible and sensitive to health and environmental issues. At the end of 2011, our network’s population coverage is close to 100%.

During the summer of 2011, we launched a network modernisation project which represents one of the largest investments and one of the most signifi cant projects that we have undertaken in recent years. At the completion of the project, WIND’s network will be one of the most modern in Europe and will provide multiple benefi ts for the Company and for the users of our services.

The new modernised 3G network will provide a real improvement in the quality of voice and data services, as well as providing an improved experience for mobile internet users with nominal speeds of up to 42Mbps and actual speeds that are up to 8 times higher than those available prior to the upgrade. The simultaneous increase in the capacity of the network will constitute one more signifi cant improvement and will allow an increase in the number of users with a parallel increase in the quality of the service provided. Additionally, the project provides the Company a

greater level of fl exibility, as well as allowing the concurrent operation of GSM, UMTS/HSPA+ and LTE technologies, essentially paving the way for the transition to the future by supporting 4th Generation technologies.

During the fi rst phase of the project, we focused on the modernisation of stations which cover Athens and Thessaloniki and we will continue over the next two years with other big cities and targeted areas.

6.1.1 The mobile telephony network

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Coverage for fi xed telephony services and broadband internet is at about 70% of the installed telephone lines in Greece, with 262 co-locations at telecommunications nodes that cover Athens, Thessaloniki and an additional 80 cities in 48 prefectures.

During 2011, 13 telecommunications nodes were expanded and at more than 173 sites the connection circuits were upgraded through backhauling.

6.1.2 The fi xed telephony network

(Data: 31/12/2011)

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Development of the Fixed Line Communications Network4,000 km National Fiber Optics Network

50 Gbps International capacity

20 Gbps GR-IX

262 Co-locations at telecommunications nodes

48 Prefectures

80 Large Cities

Submarine Cables Between:Greece - Italy

Crete - Peloponnese

Peloponnese - Sterea Hellas

At WIND, we develop our network of base stations in a responsible manner and with the utmost sensitivity for public health and for the environment. We operate a laboratory for the purpose of measuring high frequency electromagnetic fi elds which carries out measurements on a systematic basis at the base stations themselves in order to ensure strict compliance with all international safety specifi cations and Greek legislative guidelines.

By operating in accordance with the ELOT ΕΝ ISO/IEC 17025:2005 standard, our laboratory certifi es that the high frequency electromagnetic fi eld measurements are carried out on the basis of internationally accepted standards and practices by properly trained and qualifi ed personnel. It is, therefore, able to ensure the reliability of the measurement results and that the set limits on exposure to electromagnetic fi elds incurred by the general public and employees are observed and that our network is operating properly.

Along with carrying out the above measurements and in order to give the public the opportunity to monitor the levels of electromagnetic radiation in the environment on a 24-hour basis, we support the FASMA program. This program was developed and is being implemented by the Radio Communications Laboratory of the Aristotle University of Thessaloniki, which possesses the required technical know-how and the proper equipment to ensure the accuracy of the measurement results. It consists of a network of broadband measuring stations which have been placed mainly near schools and densely populated areas.By the end of 2011, 36 measuring stations had been set into operation under the FASMA program. All of the measurements have found that the intensity levels of the electromagnetic fi eld are much lower than the limits set by the state. In 2011, the www.fasmaprogram.gr website was redesigned and re-launched with the stated goal of promoting a greater understanding of the information presented to the general public by providing enriched data that directly addresses the concerns of consumers.

6.1.3 E/Μ radiation & measurements

42

In 2011, WIND carried out 45 measurements, either as part of the licensing process for base stations or at the request of residents.

At WIND Hellas, we design and promote products and services for mobile, fi xed telephony & internet as well as bundled packages for fi xed and mobile telephony and data to meet the needs of both residential and corporate customers.

6.2 Products & Services for All

Fixed telephony services through own network

Internet services (ADSL) through own network

Integrated telephony and internet packages (ADSL)

Ε-mail

Digital telephony facilities

Prepaid cards

Equipment (ADSL modem/router, telephone handsets)

Dial-up internet

Internet Services through own network leased lines

Data link services

Connection services

Value Added Services

Wholesale services

Fixed telephony & internetConsumer Prepaid products: WIND F2G, Q, WIND Card

Contract services for individuals: WIND to ALL, WIND XS-3XL, WIND card connection, Q Contract

Contract services for companies and professionals

Value added services, such as SMS, MMS, Internet, video calls, etc.

Roaming services in foreign countries

Wireless/portable internet services

Mobile telephones & accessories, such as chargers, wireless Bluetooth devices, carrying cases, etc.

Mobile Telephony

Bundled integrated packages for mobile, fi xed telephony & internet: WIND One

Mobile, fi xed telephony & internet

43

As a result of the new social and economic conditions, a new consumer need arose in prepaid telephony to enable subscribers to communicate without binding conditions, with transparency in charges, along with a demand for additional services depending on the specifi c communication needs of subscribers.In this context, we redesigned and replaced our prepaid WIND card product with a new “WIND Card to All”. The new product was intensively promoted to ensure that its strategic diff erence was completely understood by the fi nal consumer, given that it is targeting subscribers who want to communicate freely with all mobile networks. The goal of this action is that at the beginning of next year (2012), “WIND Card to All” will merge with WIND F2G, emphasising the access to all national networks that consumers truly need. Moreover, given the ever growing internet penetration in Greece and based on research, WIND put faith in the value of social media (Facebook, YouTube, and Twitter) and invested in the creation of online services for all available packages. Thus, we implemented a special website for the main prepaid package WIND F2G (www.f2g.gr). Through the website, subscribers create a new online community where they can check their remaining balance in real time and activate additional services. Subscribers can be notifi ed of special off ers, competitions and collaborations with other companies (cinema tickets, traveling, theatre, concerts, etc.).

Consumer Mobile PrepaidThe “WIND to ALL” programs provide talk time to all networks, both mobile and fi xed line, thus safeguarding subscribers from unexpected charges over and above the fi xed subscription amount. Additionally, the “WIND to ALL” contracts provide the most comprehensive solution for cost control on the Greek mobile telephony market through the unique Guaranteed Billing Service, which provides subscribers with the ability to set an upper limit to their bills, free updates through the 1270 number, 10 minutes of free automatic notifi cation, 10 SMS and 10 MB prior to the exhaustion of the embedded airtime, the ability to increase the upper limit of their bills easily and the ability to purchase additional talk/SMS/MB time at up to 50% lower prices.

WIND to ALL Programs

Νέο

44

The Integrated Information System provides more and more opportunities for sales at the stores; it creates integrated mechanisms for customer support; it expands mobile telephony know-how to fi xed telephony; it unifi es mobile and fi xed customer support; and it provides WIND customers with the unique advantage of a single bill. In this manner, we were able to place more than 30% of our subscriber base in integrated fi xed, mobile & internet packages, giving our customers a single telecommunications experience at home and on the move*.

Our customers are informed about the products, their characteristics and any instructions for their use

through our website, www.wind.com.gr, at their local stores and sales points, through printed promotional material and pre-recorded information or by calling the Customer Service Centre.

Additionally, via our Company’s offi cial website, the special section “WIND Stores” off ers complete information on the services that are provided by our stores, with the goal of improving the lives and communication of our customers. A special application on the site enables customers to locate the nearest WIND store, fl ip through our stores’ latest brochure and fi nd all the latest products and applications.

www.wind.com.gr*(Data: 31/12/2011)

45

According to our contracts with our various suppliers, the products we receive and off er for sale through our network of associates are covered by European legislation (the “CE mark”), (http://ec.europa.eu/enterprise/policies/single-market-goods/cemarking/faq/index en.htm), as harmonised with Greek law. Additionally, every six months we carry out inspections all over Greece in order to ensure the quality of the equipment (sample inspections at the time of delivery, regular and impromptu inspections, etc.).

Our systematic research in the market for new technologies which contribute to making equipment more environmentally friendly (in terms of the materials that are used and their energy consumption) has already resulted in the upgrading of the equipment provided to consumers for accessing the internet, thus allowing us to achieve more effi cient operation of the local consumer networks.

We ensure that all of the mobile telephony handsets strictly adhere to the specifi cations for safe levels of radiation, as set by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) and the Federal Communications Commission, while actual SAR levels are much lower than the offi cial allowable limits.

For more information, please visit www.wind.com.gr

6.3 Responsible Products

6.3.1 Environment 6.3.2 Health

For more information, please visit www.wind.com.gr

46

Balance Information serviceEvery user of prepaid mobile telephony can have immediate access to their balance information, automatically and free of charge. Consumers can learn their remaining balance from airtime, balance remaining a� er use of free airtime and bonus credit.

WIND SOS Recharge serviceIn the event of an emergency, subscribers can extend their airtime balance, even if they have a zero balance, simply by dialling a 4-digit number.

WIND Ring Me Now serviceThis service allows subscribers to send an immediate alert to any WIND customer, either prepaid or postpaid, requesting a call-back when there is insuffi cient balance on a prepaid service. To use the service, subscribers simply send an SMS to a special 4-digit number, writing only the mobile number from which the subscriber is requesting a call-back.

Prepaid Tariff Plan Change This service enables subscribers to select the prepaid tariff plan according to which they will be charged. The tariff plan change can be performed by calling 1342 free of charge, activating the change immediately. Requests for plan changes may be made once per month.

6.4 Responsible Services

WIND FLEETAt WIND, in the context of our innovative services that contribute to a green economy, we have developed the WIND FLEET service, providing the opportunity to companies, professionals and public agencies who manage fl eets of vehicles and transport to reduce their operating costs, to allocate resources better and to increase their productivity by optimising their operations and procedures. Thus, by reducing the cost and overall fuel consumption, a signifi cant reduction in a Company’s carbon footprint is achieved.

47

6.5 Social Product

As part of our active support of social groups in need, we proceeded in 2011 to design special off ers for the unemployed. By doing so, we were able to provide a discount on fi xed telephony and internet, and free use of mobile services (prepaid and postpaid) to subscribers who are entitled to Manpower Employment Organisation (OAED) benefi ts.

The “I contribute” serviceThis is a joint charitable initiative of the three mobile telephony operators in Greece which began in February 2006. The service involves the activation of a common 5-digit number for a specifi c period of time, during which mobile subscribers are able to send as many SMS as they wish (at a cost of €1 + VAT). Thus, they are able to fi nancially support a non-profi t or non-governmental organisation every time they do so. The total net revenue (excluding VAT) generated from the use of the service is given to the eligible NGO, without any deduction.

In 2011, the service was activated 16 times and WIND distributed €39,880 to various organisations through the “I contribute” service.

“Médecins sans frontières”Subscribers may donate €2 to the MSF organisation by sending a blank SMS to the 19192 number or by calling 9011602020. Since 2009, there has been the additional option of making a donation to MSF through WIND Plus, WIND’s mobile portal, as well as the option for WIND subscribers to be informed through articles and photos of the work performed by MSF worldwide.

In 2011, subscribers donated €720.49 to MSF.

“SOS Children’s Villages”Since December 2011, we have enabled our subscribers to donate €2 to the SOS Children’s Villages by calling 14567.

In 2011, subscribers donated €1,664.60 to the SOS Children’s Village.

“Ark of the World” Also since December 2011, subscribers have been able to donate €2 to the Ark of the World by calling 14849 or sending a message to 54232.

In 2011, subscribers donated €1,412 to the Ark of the World.

6.5.1 Special off ers

6.5.2 Social contribution Phone Lines

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Through our network, we provide our subscribers the option of free calls and SMS messages to emergency numbers such as 100, 166, 199, 112, 197 and 108.

In 2011, 1,887,598 such calls were made.

Since June 2002, and through the WIND Care program, we have provided the option to people with disabilities (hearing impaired, families of individuals with severe learning disabilities, autism, physical and multiple disabilities) of communicating via SMS at half-price. Individuals who are entitled to join the program may be new or existing subscribers with postpaid or prepaid packages.

“Amber Alert Hellas”Through our telecommunications network throughout Greece, are customers are able to participate actively in the process of locating either a missing or abducted child via SMS to 1056 from their mobile.

“SOS Line – The Smile of the Child”We off er our subscribers the option of calling 1056 free of charge from their mobile, thus helping to deal with serious incidents in which children are the victims.

Moreover, we provide the option of making a €2.016 donation by sending a text message to 54020 and a €2 donation by calling 14545. In 2011, €206,596.63 was given to the Smile of the Child organisation.

“European helpline for children”We support the European helpline for children 116000, through which cases of missing children can be easily and quickly reported for free or through which assistance for children in need can be arranged. The 116000 number now also functions for sending free SMS messages.

“Support Line for Children and Adolescents of APHCA”The support line for children and adolescents, 116111, is a toll-free phone number which any child or adolescent up to 18 years of age can call in order to speak with qualifi ed mental health counsellors. WIND acknowledges the importance of prevention and treatment of mental health problems related to childhood and adolescence by off ering its subscribers access to this phone number.

6.5.3 Εmergency Numbers

6.5.4 WIND Care

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6.6 Responsible Marketing

At WIND, through our voluntary commitment framework, we act in accordance with ethical and moral behaviour guidelines. By promoting good business practices throughout our operations, we adhere to policies on privacy and confi dentiality of communications and the Code of Conduct for the provision of electronic communications to consumers, which sets out the general principles and basic rules of behaviour towards consumers with respect to customer service and support of our products and services that should be applied by the representatives of our Company (e.g. CS agents, POS and our Associates).

All the plans we off er are in accordance with the regulations and voluntary codes related to communication and marketing with the aim of providing consumers with the most complete information possible on the characteristics of our products and services. Thus, we ensure that our communication and promotional material complies with the Greek Code of Advertising- Communication, the provisions relating to unfair competition and to consumer protection in general and to existing Greek legislation. We monitor and strictly observe the regulations / guidelines of the Advertising Self-Regulation Council (SEE).

The language used in our communication is friendly and straightforward, and the communication material itself is comprehensive, analytical, legal, fair, and sincere; it does not hide any details from the customer, is based on facts, is responsive to every age, gender and religious group and gives priority to the diversity of people and is available at each consumer contact point.

To ensure the above, our Company’s Marketing Department carries out frequent checks of our advertising messages before these are sent out.

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Transparency

Truth

Respect for morality

Respect for the customer

Clarity in communication

The codes of conduct towards our customers include detailed descriptions of our policies and our principles as well as the basic rules of conduct for the Customer Services Department, WIND stores and our associates regarding the sale and support of WIND products and services, as well as for our customer service. These are available to all interested parties through the respective corporate websites.

We strictly adhere to the codes that have been issued by EETT and which relate to issues of consumer protection and we also required our partners to do so as well. The codes are:

1. Code of Conduct for Providing Electronic Communications Services to Consumers (Dec. 488/82/30-7-2008 EETT), as in force.

2. Code of Conduct for the Provision of Multimedia Information (Dec. 451/10/1-10-2007 EETT), as in force.

In the context of self-regulation of the mobile telephony sector and aiming at its active participation in the proper use of the value added services (for example content services, videos, MMS), WIND and the other mobile telephony companies jointly signed a Code of Conduct for value added services off ered through mobile phones and the protection of minors. This code relates to services addressed to adults. Taking into account developments in the industry at a European level, we and the other companies incorporated the European Memorandum on safer mobile use by children and adolescents into this Code.

We apply the principle of ethical competition and the competition law. Our Company has not been the subject of any legal action for breach of competition law at the time of reporting.

In addition, during 2011, we implemented and coordinated an educational program for a large number of executives in our Commercial Division which was designed to promote our clear-cut policy in favour of the principle of ethical competition, and provide specialised information on Competition Law and the impact it could have on the Company, on employees and on the market if practices are not consistent with the requirements of fair competition.

6.6.1 Codes of Conduct 6.6.2 Ethical competition

51

52

Intellectual Property Rights

6.6.3 Intellectual Property Rights and Communication Security and Privacy

Communication Security and Privacy

The Company fully complies with its legal obligations as a provider of electronic communications in relation to the protection of intellectual property. In all of our contracts with customers, we include strict conditions in relation to copyright protection when using its services by prohibiting our subscribers from using its services in a way that violates copyright law under penalty of the termination of the contract. Strict intellectual property rights protection clauses are also included in all of the contracts that the Company signs with third parties, its suppliers and affi liates in order to better secure its transactions under this criterion as well.

The management of our customers’ personal data is in full compliance with laws protecting individuals from the processing of personal data (L.2472/1997, L.3471/2006, L.3917/2011). We have a full set of safety rules in the form of policies and procedures for ensuring confi dentiality of electronic communications.

53

6.6.4 Communication principlesNowadays, when the volume and complexity of commercial communication make the selection of products and services a diffi cult process for the consumer, we at WIND are committed to adhering to our 3 basic principles of simplicity, honesty and directness in each one of our communications.

Overall for 2011, the combination of research tools for continuously measuring customer satisfaction, our commitment to our communication principles and our innovative use of new media is the main reason for the spectacular improvement in WIND’s corporate image, as compared to 2010.

Simplicity The goal of our efforts at promoting simplicity throughout the entire range of our products and in how the consumer is

informed about them is that of providing the consumer with the best and most comprehensive understanding of our

products and services to the greatest extent possible. In particular, all of our commercial communications pass through a

thorough review before they are officially aired. They are examined with respect to their ease of comprehension and the

simplicity of their messages, but also to identify and improve any point which might create confusion among consumers.

Furthermore, full descriptions and detailed explanations can be found on the official WIND website (www.wind.com.gr) for

products which involve a significant amount of information that cannot be communicated given time and space limitations.

Honesty Relationships of trust are built through the daily honest relationship that we have with our customers. In this effort,

we commit ourselves to complying with all of the rules of the communications code of the Greek Advertising Self-Regulation

Council (SEE), even when asked to immediately accept and comply with its recommendation. In 2011, out of the

16 recommendations made by the SEE to all telecommunications providers in Greece, only one case concerned WIND

and a recommendation to amend a communication, with which we voluntarily complied the following day.

Moreover, despite the absence of a specific code addressing this category, we decided for yet another year to refrain

from promoting, in any of our communications, the use of mobile phones by children and in general by those groups

which require greater responsibility in their use of mobile phones.

Directness In 2011, we adopted a 360-degree communication strategy, choosing to communicate and to explain our products and

services in a simple and understandable manner through all available media. Thus, consumers were able to receive

our proposals in the most direct and familiar manner for them, resulting in a 100% level of immediacy of

communication. A characteristic example: We had over 3,000,000 unique views of our advertising on YouTube by

young consumers. Nevertheless, the most important aspect is that our customer service is improved significantly

through these new channels of communication and social networking.

6.7 Informing the public

It is important to us that customers understand the billing process and the amount that they are charged. Therefore, we make sure that in all the communication vehicles (monthly bill, E-Bill, www.wind.com.gr, etc.) where customers can fi nd such information, billing information is presented in a transparent, detailed and clear manner, and that it is explained simply and accurately through updated price lists, press releases or through personal communication.

As regards multimedia information services and calls charged at higher rates, we provide detailed information to our subscribers concerning these charges, fully implementing the regulations of the Hellenic Telecommunications and Post Commission (EETT), clearly announcing the charge for the call

with a free pre-recorded message. The charges for all multimedia information services for each product can be found on the Company’s website (www.wind.com.gr).

In 2011, we carried out a redesign of our bills focusing on simplicity and on providing a detailed explanation of fees and charges, and containing specifi c recommendations depending on the specifi c needs of our customer base.

6.7.1 Transparency in billing

54

Nowadays, everyone is able to enjoy the services off ered by mobile telephony and to benefi t from its advantages. At the same time, though, there are concerns regarding the relationship between health and mobile phones. WIND has closely adhered to the philosophy of respecting the concerns of its consumers since it entered the Greek market. In this context, it systematically informs its subscribers through specialised publications (e.g. “mobile phones in our lives”) or through www.wind.com.gr of the basic principles involved in the operation of mobile telephony, about legal issues, the results of international research and answers to frequently-asked questions. In addition, Company executives inform consumers of the latest developments in research conducted in Greece and abroad, and disseminate the opinions of experts on radiation issues by writing articles and giving interviews in the media.

Internet users are able to restrict access through the settings of their equipment by prohibiting certain sites or URL groups, allowing access only to specifi c devices, etc. It is also possible to limit certain protocols in order not to allow specifi c applications. In this manner, parental control is enhanced.

6.7.2 Parental Control

6.7.3 Electromagnetic Radiation

“The new WIND bill is more clear and simple; thus I quickly understand the kind and number of calls I have made”.

Vaggelis Ntasis, Subscriber

55

6.8 Customer Satisfaction

During 2011 and in the context of supporting the Company’s customer-focused philosophy, we implemented an online Customer Satisfaction Survey at the end of their telephone communication with our call centre agents for the purpose of safeguarding and enhancing our quality of service. Subscribers could select to register the level of the quality of service experienced through a convenient and user-friendly voice portal. The registering of the subscriber’s customer service experience took into account 5 axes through which we collected results regarding the quality of service, while ensuring the accuracy and validity of the information provided and the high level of services off ered. All of the data collected was communicated to Management and the competent departments for their review.

6.8.1 Measurements & evaluation Customer Satisfaction Survey results for 2011

Figure 1 2011 Average

Mobile Telephony Customer Service Department

0%

20%

40%

60%

80%

100%

ServiceSatisfaction

85.32%

Resolutionof Request

84.87%

First Contactregarding

the same issue

74.23%

Training ofthe Service

Representative

92.79%

56

40%

50%

60%

70%

80%

90%

100%91.26 92.01 91.87 92.28 91.54 91.66

94.96 94.34 94.71 93.36 93.03 93.24

82.20 83.32 82.51 83.16 82.33 82.98

88.43 87.58 88.88 88.20 88.27 88.38

Satisfaction from Service ReceivedTraining of the Service Representative

Jan Feb Mar Apr May Jun Jul Aug Sep Okt Nov Dec

40%

50%

60%

70%

80%

90%

100%

Jan Feb Mar Apr May Jun Jul Aug Sep Okt Nov Dec

First Contact regarding the same issueResolution of Request

72.00 73.05 73.12 73.28 73.98 73.46 75.08 74.50 74.41 77.40 76.91 76.15

82.1583.91 83.86 84.34

83.35 83.0685.88 85.50 85.84 87.37 87.54 87.91

Figure 2 2011

Mobile Telephony Customer Service Department

Figure 32011

Mobile Telephony Customer Service Department

57

As regards fi xed telephony and the internet, and in the context of developing the mechanism for monitoring the quality of service, as perceived by our subscribers, we designed a single vehicle for enabling the personalised and two-way communication between the Company and each subscriber by creating “WIND for me”, a program aimed at continually increasing subscriber satisfaction through frequent communication. The valuable information gathered has already borne fruit, as refl ected in our measurements of satisfaction levels. The level of satisfaction for 2011 continues to remain stable at around level 4 on a scale of 1 to 5.

In 2011, we continued to implement practices to monitor the satisfaction levels of our mobile, fi xed telephony and internet customers as part of the ongoing improvement of our customer service practices.

Welcome Calls A few days a� er the fi rst bill has been issued, we call our Voice Tariff subscribers in order to welcome them, to record the level of their satisfaction and to fi nd out about their experience. Our goal is to ensure the best possible experience from the very start of our mutual cooperation.

Health Check Campaigns A� er a Customer Service request has been resolved, we contact our customers to fi nd out about their experience with how their request was managed, the adequacy of information received, the resolution time involved and fi nally their overall satisfaction. During the conversation, additional explanations are provided, and any additional issues raised by the customers are resolved. The aim of this activity is to measure the degree of customer satisfaction, to identify any weaknesses in procedures / policies, and primarily to provide a positive experience for the customer.

These two activities were launched in September 2011, and by the end of the year, we had contacted approximately 27,000 customers with respect to each axis.

Research and auditing at the stores

The basis axis of this eff ort consists of a comprehensive system of researching and auditing customer satisfaction implemented on an ongoing basis with the following key tools:

monthly Satisfaction Survey of mobile telephony customers;

ongoing collection of customer satisfaction data through our call centre and the daily contact with customers at our retail stores;

advertisement evaluation research;

research directed at customers who may have chosen another network;

measuring customer satisfaction using new technologies.

58

6.8.2.1 Process Reengineering

6.8.2 Responding to the needs of our customers

In 2011, we prepared the ground work to embark on redesigning the Company’s processes, with our principal goal being:

to improve and to realign all of our processes in order to increase their effi ciency and eff ectiveness by making the best use of our resources;

to render our processes a competitive advantage by providing improved agility, responsiveness and quality of services.

In 2011, an upgrade of the Siebel application was designed and will be implemented during 2012. This application constitutes the central management system for the entire customer base (individuals and corporate subscribers) for customer service, marketing, and the sales departments. The upgrade is intended to improve internal processes for managing the entire customer base more eff ectively and to ensure the prompt handling and resolution of subscriber requests.

Review D

ecis

ion

Leve

ls

Impr

ove

Flex

ibili

ty/

Free Up Resources

Automate, Simplify,

Establish/Improve

Control Mechanisms

Sim

plify

, Spe

ed U

P,

Impr

ove

Serv

ice Le

vel

59

In the context of continuously increasing customer satisfaction, we proceeded with product recommendations and corrective changes designed to meet our subscribers’ demand for communication with all the networks and to provide more comprehensive and straightforward information. All of the changes were fully supported by the mobile telephony customer service department which received the necessary guidance through targeted educational programs, ensuring the accuracy and validity of the information that they provide. Additionally, through education procedures and continuous updates, we proceeded with the development of our employees’ expertise and skills to provide over-the-phone support for the basic setup, installation and connection of the iPhone device, thereby off ering an integrated delivery of services through the new technologies service department by calling 1231.

6.8.2.2 Mobile Telephony 6.8.2.3 Fixed telephony & internet

In 2011, signifi cant improvements to customer satisfaction practices took place.

New procedure with respect to the initial installation of equipment and activation of internet services which considerably reduces the steps involved in the procedure;

Informing subscribers of their billing information through the voice portal;

Information regarding the status of new applications through IVR, voice portal and through the WIND website;

Sending activation codes for internet service by SMS;

Reducing the number of customers calling for support by up to 35%, despite the increase in the size of our subscriber base for fi xed and internet services, which was 25% higher at the end of 2011 compared to the end of 2010;

Reducing by 45% the amount of unresolved technical issues (technical support, faults), despite the increase in the size of our subscriber base for fi xed and internet services, which was 25% higher at the end of 2011.

60

In doing so, we were able to improve the entire customer experience. Moreover, in conjunction with the continuous investment in network infrastructure, we signifi cantly improved the quality of the services provided.

Redesign of our Extranet Portal with WIND stores

Since our goal is the continuous improvement of the services off ered through our retail stores, we redesigned the Company’s Extranet to achieve a more customer-oriented and user friendly approach and provide stores with the most complete information regarding all our products and services.

New “e-Personal Plan” interactive application

In order to reinforce our stores via new digital tools, we developed and presented the e-Personal Plan. The customer who visits one of our stores has the opportunity to browse the applications under the guidance of sales personnel, and arrive at a comprehensive solution for mobile, fi xed telephony & internet which meets his needs through a series of smart questions.

Digital Signage System

This complete Digital Signage system consists of electronic applications and digital monitors through which the customer can be informed about our Company’s products, services and off ers by using a touch screen interactive application. The system has been implemented on a pilot basis in 6 stores.

WIND Sales Team Club

Our priority is not only to reward our franchise store sales employees’ high levels of performance, but also to make them an essential part of the WIND family. In this context, we created the WIND Sales Team Club, in which all of our franchise store employees are eligible to become members and thus receive special benefi ts.

6.8.2.4 At our retail stores

61

6.9 Responsible Suppliersdaily procurement activities are carried out on the basis of detailed, documented and formal procedures that respect human rights and observe the principles of transparency by requiring specifi c procedures, controls and approvals.

The target set for 2011 regarding the full automation of the ordering process was implemented successfully. Specifi cally, in 2011 we designed and implemented changes that allow the automatic approval of purchase orders only by the authorised offi cers of the Company under the authorisation strategy laid down by the Board of Directors and their automatic dispatch to suppliers. In this manner, we ensured the better control of the approvals process for the approximately 4,000 purchase orders that are issued each year and we reduced the risk of incidents of corruption which may arise from unauthorised approvals.

We evaluate our suppliers in accordance with the requirements of the management systems under ISO 9001 and ISO 14001, monitor tenders and perform inspections when appropriate.

In 2011, the Supply Chain department continued to make regular visits to the premises of critical suppliers in order to verify they are in complete compliance with the requirements of the respective projects and that they meet the above-mentioned specifi cations. During the current year, we evaluated our 40 largest suppliers and we did not fi nd any relevant incidents of non-compliance.

At WIND, we have established a series of procedures to ensure strict, objective criteria by collecting specifi c data using a questionnaire for each supplier.

In order for an interested supplier to join the list of approved suppliers, they must fi rst meet the necessary requirements regarding the following:

compliance with legislation,

health and safety in the workplace,

child labour,

equal treatment,

forced labour and exploitation,

behaviour towards employees,

compensation,

freedom of association,

corporate responsibility,

quality,

data security, and

protection of the environment.

It should be noted that all of our contracts ensure that our suppliers comply with Greek and European Legislation.

In order to ensure the integrity of the operation of our Supply Chain department, transparency and the avoidance of any incidents of corruption, the selection and evaluation of our suppliers, the tenders and the

62

NETWORK33%

INFORMATION SYSTEMS 18%

COMMERCIAL OPERATIONS 23%

TELECOMMUNICATIONS PRODUCTS

26%

At WIND, we are able to provide concrete support to local economies through our extended network of associates by operating more than 140 WIND stores in locations outside Athens and Thessaloniki.

In order to support the Greek market, we endeavour to select Greek suppliers in general, and not only those based in Athens.

Moreover, we support local markets mainly through building/construction works for which we use local companies. With respect to purchases of promotional materials and printing work, we typically use Greek companies from all over the country. The percentage of spending on local suppliers (Greek companies) was 94.4% of WIND’s total expenditures for 2011. The majority of spending on non-local suppliers relates to the purchase of telecommunications products for which there is no local representation.

6.9.1 Local Suppliers

0%

10%

20%

30%

40%

Attica

Thessaloniki

Peloponnese

Macedonia

Thrace

Sterea H

ellas

Crete

Thessaly

Epirus

Ionian Islands

Eastern

Aegean

Cycladic

Islands

Northern

Aegean

Geographical distributionof the WIND stores by areaPercentage of suppliers

who were evaluated per category of product/service

63

64

To emphasise our advantages through our

web product pages and the development of an

additional special site for the Q prepaid mobile

plan (www.myq.gr).

The completion of the laboratory accreditation

procedures in accordance with the requirements

of the ELOT ΕΝ ISO/IEC 17025:2005 standard

by the Hellenic Body for Standardisation.

The redesign of procedures at our stores, the

supply chain and the development of new

products and services.

Investing in the creation of simple and

comprehensive services in fi xed telephony and

internet for everyone at competitive prices.

Investing in the continuous improvement of

customer experience with an even greater

emphasis on customers who have chosen WIND

to meet all of their telecommunications needs.

The expansion of broadband services with the

concept of the “Connected Home”, at even

greater connection speeds.

Goals 2012

Enhancing broadband off ers with “over the

top” services and reinforcing the broadband

experience at home with customised

applications.

To further promote electronic billing with the

goal of reducing the amount of paper used to

meet the needs of our subscriber base.

Further strengthening WIND’s broadband

“everywhere” profi le through the modernisation

of the mobile data network and mobile data

plans for all users.

Adding the option of registering customer

satisfaction through voice recorded customer

satisfaction surveys for fi xed telephony.

The completion of the option of activating

“Emergency Call”, a digital convenience through

which at-risk groups can easily call a pre-set

number from their fi xed phone in case of an

emergency.

The completion of the procedure to provide

security and parental control services to internet

(ADSL) subscribers.

65

7. Employees

66

At WIND Hellas, we combine the Company’s growth with the demanding environment of the telecommunications sector by off ering our employees the opportunity to grow professionally within one of the leading companies in Greece. We daily prove our commitment to our people by establishing a quality working environment with equal opportunities for development, zero tolerance towards discrimination, freedom of association and respect for human rights.

Achievements 2011:

We implemented Development Centresin specific employee groups

We implemented WIND Parent's Day, raising awarenessand contributing to the significant effort

of advocating and protecting children's rights,offering our employees' children symbolic gifts

from the Smile of the Child Foundation

We sensitised our employees through specialpublications on environmental and ecological issues

We participated in two major athletic eventsthrough the WIND Running Team

We implemented two Blood Donations and collected83 units of blood to support the social contribution

of the WIND Blood Bank

We strengthened the concept of internal volunteerismby informing and encouraging our employees to actively

participate in voluntary environmental activities

We provided preventive medical examinationsto employees and their families

67

7.1 Human Resources Data

At WIND, our basic purpose is to attract, retain and develop professionals who are able to think beyond the usual mindset. In this way, people who are passionate about learning and growing within a dynamic environment of new technologies can make their way towards an exciting career.

At WIND, we contribute signifi cantly to the Greek economy be employing 1,340 individuals.

Most (98.8%) of our employees are employed under long-term contracts (1.36% work part-time). The remaining 1.2% are employed under fi xed term contracts (of whom 25% work part-time).

During 2011, we proceeded to 40 new hires, whereas no new hires were necessary in the outlying regions.

All of the job descriptions and the candidates’ profi les for these positions are posted on our webpage (www.wind.com.gr) as well as on the relevant job market websites. They are also announced via classifi ed ads in selected newspapers.

Our human capital is characterised by high academic level and specialisation.

Distribution of employees/department Total

General Manager and other Administrative Departments (Quality, Physical Safety, Internal Audit, Legal & Regulatory, Corporate Aff airs, Supply Chain & Facilities Management)

77

Human Resources Department 21

Commercial Department 576

Financial Department 92

IS Department 130

Network Department 444

Employees’ academic credentials

Holders of post-graduate degrees(including doctorates)

25%

Holders of university degrees 45%

Holders of technical diplomas 18%

Grand Total 1,340

(Data: 31/12/2011)

(Data: 31/12/2011)

68

7.2 Human Rights & Equal Opportunities

At WIND Hellas, we are committed to policies of transparency, meritocracy and objectivity for a fair and reliable working environment. Our strategic approach and our philosophy are not restricted to numbers but are based on the principle of non-discrimination, equal opportunity policies and the

recognition of every individual’s right to work.

Thus, we off er equal opportunities to all our employees throughout Greece, without gender or other discrimination, cultivating a dignifi ed environment of mutual respect.

Due to our equal opportunity policy, 43% of our employees are female and 57% are male.

Employee Distribution by Region, Age Group and Gender

ATTICA 91.65%

THESSALONIKI5.22%PATRA

1.34%CRETE

0.82%

LARISSA 0.52%

OTHER0.45%

Dem

FEMALE 43%

MALE57%

35-4553.81%

<3541.49%45-55

4.48% >550.22%

Figure 1 WIND Hellas – Region

Figure 3 WIND Hellas – Employees by Gender

Figure 2 WIND Hellas – Age Group

69

Since the Company’s establishment, no discrimination incident has been reported at any level of WIND’s working environment. Moreover, with regard to human rights, we absolutely respect and we abide by all the international human rights provisions.

On the basis of the UN Global Compact, which our Company has signed, we ensure that no minors are hired and that there are no incidences of forced labour in our Company.

Moreover, our Company has not received any complaints or accusations regarding a violation of human rights, either from third parties nor from its employees during the period under review.

At WIND, we respect and protect the right of all employees to participate in unions and the existence of information mechanisms. In July 2007, the fi rst Company’s Collective Agreement (ESSE) was announced being in eff ect from October 2006.The latest renewal was in September of 2011.

This agreement, among others, provides for:

7.3 Freedom of Association

covering child care expensesuntil primary education age

providing child allowances, even for the first child, while most existing sectoral labour aggreements require payment of

a child allowance starting with the third child

covering the cost of preventive medicalcheck-ups every two years

providing a study allowance to WIND store sales employees

providing standby duty benefitto all employees registered as standby employees

granting paid study leave

70

7.4 Additional Benefi ts Benefi ts Packagecompetitive remuneration packages – fi xed and variable – which are based on comparisons with the market and reward employee contributions to the achievement of corporate goals

life insurance covering disability and accident

group medical plan coverage with the participation of employees’ families

subsidised private pension plans

preferential mobile phone use

restaurant – coff ee shop (on Kifi ssias and Athinon Sites) with highly preferential prices for employees

discounts on company products at WIND stores

benefi ts under the card reward program for transactions through WIND Bonus AMEX and WIND Bonus VISA

discounts and special off ers in shops and businesses throughout Greece

As one of the most responsible employers, we ensure excellent working conditions for our employees and provide signifi cant benefi ts and many advantages. Thus, we have developed a comprehensive and competitive compensation package which rewards performance, skills development and overall corporate success.

In the framework of welcoming newcomers into the Company, the HR Department undertakes a detailed personal presentation of the compensation package to every new colleague. Also, whenever considered necessary, the Company organises scheduled presentations of additional benefi ts by geographical region. Finally, with the aim of informing employees with regard to the Company’s benefi ts packages, information leafl ets and user friendly information cards with telephone numbers for each department are distributed and regular updates are provided via the special intranet website.

71

Our key priority as well as one of our main goals is that of safeguarding the health of employees through the implementation of all safety policies, and by providing proper information on issues related to health and directly aff ect each employee.

In 2011, we updated all of the instructions relating to the protection of our employees who deal with the maintenance and operation of our network base stations, such as, on the appropriate use of personal protection means, fi re safety, working at heights, use of hazardous substances, etc. These are accessible to all our employees via the Company’s intranet.

At the same time, we have already started communicating all the updated Business Risk Assessment Studies and the respective instructions to our network of associates who work at our base stations. For the technicians working close to our base stations in particular, we have obtained personal dosimeters which record the radiation levels in all work areas. The results are collected, assessed and fi led accordingly. For 2012, an increase in the number of individual dosimeters issued is planned, together

with the provision of information to our technical personnel on electromagnetic radiation issues.

As part of our ongoing eff ort to achieve high levels of Health & Safety at our Company, this year we also continued our collaboration with the External Protection and Prevention Service (GENIKI EX.Y.P.P. PROSTASIA S.A.), which provides us with the high level services of Safety Technicians and Occupational Physicians.

On the basis of the visits carried out by the Safety Technicians, which are conducted continuously on the basis of a specifi c annual program of visits, signifi cant improvements were made with the goal of complying with Greek and European legislation, as well as generally promoting the health and safety of our employees.

During the visits carried out by the Occupational Physicians, also carried out according to a specifi c schedule of planned visits, the health of our employees was monitored and personal health fi les were maintained.

The following table summarises the incidents related to health and safety issues in the workplace during the last few years, indicating that no serious incident involving fatalities has taken place.

7.5 Employee Health & Safety

Lossesin employees

Number of accidents(absence > 1 day)

Number of accidents(absence > 3 days)

Total days of absencefrom work

2008 0 0 2 1962009 0 1 6 1372010 0 1 3 352011 0 0 4 38

7.5.1 Indices of injuries, professional sicknesses, loss of working days and absences

72

At WIND, we consider it our duty to provide reliable information on the health and safety issues which directly aff ect each one of our employees.

During 2011, we systematically promoted the concept of preventive care for our employees and their families (spouse, children and parents) by off ering a number of preventive health examinations throughout the year, either free or at special reduced prices. These examinations included stress tests and monitoring of hypertension, thyroid screening, allergy diagnostics, type A & B preventive check-ups, and thyroid monitoring, comprehensive eye tests, preventive type A & B check-ups for the children of employees, testing for prostate cancer for men aged 50-75 years, preventive cardiology testing (adults), testing for breast cancer for women aged 30-40 years, preferential prices for packages of check-up tests, thyroid screening in children and adolescents, clinical investigation of incontinence, breast ultrasound scans and digital mammography and osteoporosis screening.

WOMENS DAYIn light of the celebration of International Women’s Day on 8 March, we held a series of activities specifi cally dedicated to our female colleagues and designed to raise awareness on health issues related to women.

Thus:

we provided a FREE Pap test to every one of our colleagues at one of our associated diagnostic centres throughout Greece.

we hosted informative talks at our facilities at Athinon Avenue and Kifi ssias Avenue, on health matters such as “Promotion of Mental and Physical Health of Women”, in collaboration with “Hellas EAP” (“Employee Assistance Programs”) and an expert psychologist Maria-Daphne Chrysikopoulou, and “Women’s Health & Prevention” with the scientifi c support of specialists in cooperation with the National Network of Workplace Health Promotion (NNWHP) and Nikos Salakos, Assistant Professor of Obstetrics and Gynaecology at the Athens University Medical School.

In addition, as part of the “In Action” Social Responsibility strategy and on the occasion of International Women’s Day, we collaborated with the “Ark of the World” to cover the rent for one single-parent family (mother and child) for one year in a symbolic gesture of social support.

7.5.2 Information on Health Matters

73

We periodically carry out specialised training sessions on health and safety in order to ensure that all employees are fully informed and prepared for these important matters. According to each training need, we design and implement informative programs on the following subject areas:

Fire Safety, Fire Protection and First Aid

These are directed towards our colleagues who are involved in the fi re safey teams at our facilities throughout Greece. The training consists of both theoretical and practical components and is conducted in collaboration with the Fire Brigade and the Occupational Physicians of our Company. In 2011, over 460 hours of training was provided.

Site Security, Offi cers Safety

These workshops are conducted in cooperation with the State Department of Safety, and consist of a theoretical and a practical component. They are directed toward our colleagues on the Site Security teams of our facilities throughout Greece.

SAFE USE OF THE INTERNET AND MOBILES BY CHILDRENIn the context of our campaign “Kids@safety, internet, mobile, and child”, through which parents are provided with information and scientifi c advice regarding the systematic protection, education and awareness regarding the safe use of new technologies by children and adolescents, the intense interest of the parents regarding the use of new technologies by children and how they must themselves provide proper guidance led us to host a seminar especially for working parents and/or their spouses on the “Safe use of the internet & mobiles by children.” The seminar was held in February 2011, and the lecturer was Mr John Tsiantis, Professor of Psychiatry. At the end of the seminar, attendees received specialised information materials and useful parental control so� ware helping children to safely navigate the internet.

7.5.3 Training on safety and health issues at work

74

The human resources management philosophy at WIND is linked to the concepts of continuous training, encouragement and support of initiatives that lead to the development of a quality working environment which respects and develops employees.

Our people know that WIND invests in them by ensuring the proper growth conditions, both on a personal and a professional level.

7.6 Employees Growth & Development

Category Hours of Training Percentage Averagetraining /employee

2010

Upper level executives 361.5 2.02%

11

Mid-level executives 833.5 4.66%

Technical Personnel 6,267 35.01%

Sales & Customer Service 9,789.5 54.68%

Remaining Personnel 650.5 3.63%

TOTAL 17,902 100%

2011

Upper level executives 224 5.21%

6.65

Mid-level executives 533 5.89%

Technical Personnel 4,608 51.69%

Sales & Customer Service 3,032 34.01%

Remaining Personnel 517 5.80%

TOTAL 8,914 100%

LibraryWe established a library at our Company’s central offi ce where more than 1,000 books and professional articles on various categories are available to all employees, aiming at knowledge dissemination in various fi elds, according to their area of expertise.

Our key priority is the continuous training of our employees so that they can grow while improving their performance through equal training opportunities that support employees’ career progress and generate a competitive edge for our Company in relation to the competition. Training is provided on technical and managerial skills so that employees are fully trained in their area of expertise. In 2011, more than 8,900 hours of training were provided.

7.6.1 Training

75

WIND Corporate University Since 2007, we have been running the Corporate Leadership Program, which is known by the distinctive title “WIND Corporate University” (WCU). It is aimed at executives who lead small or larger groups for the purpose of communicating the new leadership framework and enhancing corporate culture. The WCU was designed to function as a mini MBA business program with procedures, structures and functions that correspond to those of an academic institution. At the same time the coordination and organisation of the WCU is managed by the Human Resources Department with the support of the Company’s Top Management. Overall since 2007, over 8,500 hours of training have taken place in 10 educational programs, which combine theory with laboratory exercises / activities from Harvard Business School topics.

Scholarships A program to fi nance bachelor’s and master studies aiming at earning valid qualifi cations for those employees who have high career growth potential in the Company. Since 2002, the Human Resources Department has granted a total of 42 scholarships for undergraduate and postgraduate studies in public and private academic institutions, of which 30 were for postgraduate degrees and 12 for undergraduate degrees.

Induction ProgramsWe undertake programs for all new hires in all divisions and departments, during which they are given the appropriate guidance regarding what the employees need to know about the Company and the telecommunications market.

E-learning E-Gnosis has been operating since 2006 and includes MS Offi ce, Business and Harvard Business courses designed by the Harvard Business School in collaboration with the Human Resources Department. It is an innovative and comprehensive training tool based on the principles of e-learning. Learning takes place via computer and hours and days of attendance are fl exible. It is also possible for each Department to create its own electronic library and set of training programs which are fully adapted to the Company’s needs.

Categories of Training

As our main goal is to provide career opportunities for our employees, we empower employees to work closely with their supervisors in every department of our Company with a view to furthering their development, establishing the framework that integrates their individual abilities and aspirations into the skills required by the Company. We invest in our people and in their development, using the latest tools available for their development.

7.6.2 Professional Development

76

Internal Candidate RecruitmentWhen there is a need to fi ll an open post, we fi rst look among our own people, as the best source of qualifi ed candidates. Thus, our employees are encouraged to explore opportunities for a change and growth in other posts or departments in order to give them the chance to acquire knowledge, personal growth and freedom of choice. At WIND Hellas, all employees can evolve into “knowledge leaders” or “people leaders”.

Performance Management SystemThe role of the system is twofold: it provides an objective evaluation of employee performance, while it also aims to foster further progress and development. The key goal is to contribute to the achievement of corporate goals. A basic element in this process is to establish two-way communication (between employees and their superiors) to achieve a fair and smooth employee evaluation leading to further progress.

The evaluation system is based on a list of key competencies on which the employees are evaluated. A� er the assessment, employee and manager jointly complete the Individual Development Plan which monitors the employee’s performance so as to achieve further growth. A� er having completed the evaluation, the employee is also given targets for the next year.

Development CentresThe Development Centres are created with the aim of identifying each participant’s competencies and characteristics, based on the skills and performance levels required by the Company. At the same time, they recognise the participants’ strengths and areas in need of development in order to lay the groundwork for a wider dialogue regarding their Individual Development Plan. In 2011, 32 individuals from the Sales department participated in the Development Centres for a total of 150 hours.

Individual Development PlanThe Individual Development Plan ensures that all our employees have the opportunity to advance according to their abilities and to our Company’s needs based on a common framework that defi nes the skills required at every step of their professional development process. This plan is carefully designed for each one of our employees in close cooperation with their supervisors and is based on the development experiences which are necessary for the achievement of the common goals.

Performance E

valu

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n

Guidance / FeedbackInterm

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Goal-setting

Dev

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men

t Pla

n

Eval

uatio

n an

d In

divi

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Guidance / Feedback

Annu

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erfo

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7.7 Internal Communication

At WIND Hellas, our working environment is characterised by mutual respect and trust. Sincerity and responsibility for our customers and colleagues is an integral part of the employees’ professional conduct, whilst we operate with transparency and

reliability in all our daily transactions inside and outside the Company. A basic prerequisite for all the above is the development of a proper communication policy parallel to a system of continuous “coaching” for a successful human resources management.

We believe that deepening internal communication at all levels is one of the fundamental factors that determine our success and strengthens the climate of trust and contributes to the establishment of a single culture that acknowledges individual capability, eff ort and contribution, while further enhancing team work. For this reason, we strengthen communication either through tools that develop an open and constructive internal dialogue or by staging various events for our employees.

At WIND, by exploiting all modern means of internal communication, we keep our employees informed of all issues that directly concern them as members of society. The methods and channels of communication used are numerous and are developed over time.

WIND was among the fi rst companies in Greece to create an internal website (WIND Portal).

In June 2010, on the occasion of World Environment Day, we launched the WIND Eco News column, which is one of the key new sections of the WIND Portal aiming to continually sensitise everybody regarding the protection of the environment. WIND Eco News systematically provides information about the developments and news from Greece and the world on broad environmental issues. Moreover, it off ers useful advice which all of us can easily adopt in our daily lives in order to decrease our energy consumption and improve our environmentally friendly attitude. Since our environmental philosophy starts with educating our children, we devote the subsection Eco Kids to informing our young friends with regard to various environmental activities and events in which they can actively participate. In parallel, WIND Eco News is the eco-communication tool by which we off er ongoing information to our employees as regards the environmental actions we undertake.

7.7.1 Two-way communication

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Our constant objective is to support those methods that further strengthen the development of relations among our employees in the corporate environment by organising various events throughout the year. The Christmas party, the Parent’s Day event and other similar events contribute to work-life balance.

7.7.2 Employee eventsIn 2011, WIND Eco News focused its issues on the axis of “Ecology and Economy”. The reason for doing so, in addition to that of providing useful information on a sensitive and topical issue, was to provide practical advice

that will bring us even closer to the environment and that will also contribute to reducing the cost of living. Concepts such as alternative tourism, alternative transport, alternative cooling sources, “green” islands and eco travel boosted the ecological awareness and sensitivity of our employees.

In the context of the above special issues, we off ered our lucky colleagues the following:

an alternative three-day trip for 2 persons to beautiful Evrytania, with walking tours in the Pantavrehi (“always rains”) Gorge and a canoe trip on Kremasta Lake

a handy city bike, as well as

an ecological lunch box for our employees’ children.

Parent’s DayFor the ninth consecutive year in 2011 we staged WIND Parent’s Day, turning the outdoor area of

the WIND premises into a vast playground fi lled with games, gi� s and surprises. The event aims at bringing children into contact and familiarising them with their parents’ working environment, as well as the promotion of the concept of balance between professional and personal life. The Human Resources Department presented the children with symbolic gi� s from the Smile of the Child Foundation, thus raising awareness and solidifying our contribution to this important eff ort towards defending and protecting children’s rights.

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7.8 Internal Volunteerism

With a focus on the belief that knowledge and awareness start from the internal environment, we systematically develop volunteerism within the Company aiming at informing and encouraging employees to actively participate in our Company’s social program. WIND’s social policy derives from our own people who participate in many actions that address either society in terms of supporting those social groups in need, or the environment through voluntary actions, while also relaying the message and value of community service.

“Volunteerism does not have any boundaries nor does it have limits. It is multi-faceted and timeless.

Volunteerism is especially important

at this point in time. Volunteerism is usually addressed to people or companies who are considered sensitive and is connected with non-governmental organisations, with respect to matters such as ecology, sport or helping specifi c social groups. Thus, our Company has for many years embraced volunteerism with sensitivity and willingness. This inspired me to participate in as many WIND-sponsored volunteer activities as I could. These selfl ess acts make one feel more human and this is a one-of-a-kind feeling.”

Nikos Gouliaditis, Employee at WIND MKT COM

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In April 2011, the WIND Running Team was created with the aim of providing community service through the development of the internal and external volunteerism. The group’s fi rst race was the 6th International “Alexander the Great” Marathon in Thessaloniki, in which 23 of our employees took part. They fi nished successfully and through their presence supported the work of the Hellenic Society for Disabled Children (ELEPAP) of Northern Greece.

This was followed in November 2011 by the 29th Athens Classic Marathon, where the WIND Running Team was out in full strength along with 1,000 runners who through their presence supported the work of the Ark of the World. The 100 employees who participated in the WIND Running Team have further promoted the meaning of the terms “I participate” and “I contribute” through internal volunteerism.

WIND Running Team Recycling at the offi ce

Every year, over 200,000 tons of electrical and electronic equipment are distributed on the Greek market and eventually become waste (data: Eurostat 2008). Most contain hazardous substances, and in addition to harming the environment, their large quantity exceeds the available landfi ll space for their disposal.

As a telecommunications services provider, our Company uses large amounts of electrical and electronic equipment, which at the end of its life-cycle is automatically converted to waste.

What do we do about this, as a Company?

We collect and recycle all of the electronic and electrical equipment that we use when it is no longer needed.

We work together with all the relevant recycling organisations.

We operate mobile phone and accessory collection points for the public as well as for our employees in all of our stores and facilities.

What do all of us do, as environmentally conscious citizens, through the WIND family?

We instituted our “Electrical Equipment Recycling Week”, which we inaugurated in February and March of 2011 in cooperation with “Appliances Recycling S.A.”

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One of our most important initiatives is the creation of a Blood Bank, which has been operating since 2002 thanks to our employee voluntary blood donation program which now takes place twice per year. The aim of the Blood Bank is to contribute to the national eff ort to obtain adequate blood supplies and to immediately support employees and their families should they require blood. For the implementation of the program, we collaborate with the major hospitals and institutions. Since 2002, the Blood Bank has received a total of 643 voluntary participants.

Consistently supporting the WIND Employees’ Blood Bank, the Human Resources Department in 2011 held two blood donations in Athens, with the participation of more than 80 volunteers who donated a total of 83 units of blood. Blood donations were also held in other cities outside Athens for colleagues who wished to participate. Once again, the motto “Donors of Life” strengthened the WIND’s team of voluntary blood donors who off er this most precious good of all.

In 2011, the Blood Bank met the needs of 25 of our people (colleagues and their relatives) by providing 37 units of blood.

Employee voluntary blood donations

With the goal of motivating our employees to use more sustainable transport methods while facilitating them in their transportation to and from work, we created special bicycle parking spaces both at the WIND facilities at Kifi ssias Avenue and at Athinon Avenue.

Sustainable mobility

In this manner we managed to collect 153 pieces of electrical equipment, weighing a total of 600 kg which consisted of:

21 small household appliances

51 types of IT and telecommunications devices

14 consumer products

36 lighting fi xtures

27 electrical and electronic tools

4 electronic games

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The development of the electronic publication WIND Eco News as a source of information about the environment to encourage employees’ active participation in its protection.

The continuation of the WIND Running Team while also promoting the concept of corporate sports teams through the active participation of our employees, promoting team spirit and volunteerism through sports.

The further strengthening of the concept of internal volunteerism by informing our people and actively participating in voluntary environmental actions and social responsibility activities.

Providing continuous information on health and safety issues by promoting activities that contribute to the prevention of health care issues for our employees and their families through the provision of special preventative medical examinations to employees and their families, either for free or at special prices.

Strengthening our Employees’ Blood Bank.

Further improvement in Health and Safety conditions through: � the completion of occupational risk assessments for all

telephony base stations: To achieve this goal, inspections of technical safety personnel at representative base stations, chosen in collaboration with the Technical Department of our Company, have commenced.

� the continuous monitoring of the micro-climate conditions of our offi ces. We plan to repeat the measurements of temperature, humidity, lighting and ventilation in 2012 in order to ensure the best possible working conditions.

� the scheduling of electromagnetic radiation measurements at base stations.

� the monitoring of the quality of water consumed by our employees or used to wash hands, utensils, etc. by carrying out water quality tests.

� the continued provision of appropriate personal protection equipment (PPE) for employees. Through internal control procedures that are applied in order to identify gaps with respect to safety measures for employee protection, but also through the development of Occupational Risk Assessments, we aim to continue providing the appropriate equipment to employees, depending on the nature of their work, to train employees on PPE use and to monitor its proper use. Examples include the immediate scheduling of training on the use of the electromagnetic radiation dosimeters for all employees who work at base stations.

Goals 2012

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8. Environment

84

At WIND Hellas, we consider our socially responsible behaviour and our recognition of our responsibility towards the environment and sustainable development to be an important parameter for our operation.

In this context, we are committed to developing and directing our business activity in the fi eld of telecommunications with respect to environmental protection and the principles of sustainability, responding dynamically to the challenges of our era.

Given that each one of our activities aff ects the environment, we focus on any negative impacts resulting from our operations and invest in sustainability with manageable measures, but also substantive actions.

Achievements 2011:

We sold 81,253 kg of equipment for re-use,the majority of which came from RBS units

from our network upgrading project

We implemented actions for reducing paper usagewhich on an annual basis may result in

over 10 tons of paper savings

We reduced our oil consumption by 16%by replacing the constantly operating

power generators with hybrid/battery systems

We saved the equivalent of approximately5,877 tons of carbon dioxide emissions through

the energy-saving actions we implemented

We replaced 58 air conditioning units operatingon HCFC-22 at our Base Stations with unitsthat operate using a zero ODR refrigerant

We saved over 1,000,000 litres of fuel or approximately45,500 GJ of energy by installing hybrid systems

at our Base Stations

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8.1 Environmental Policy

8.2 Environmental Management

Through our Environmental Management System, which is certifi ed in accordance with the international standard ISO14001, we monitor and record the environmental impact of our operations, we classify the types of impact by signifi cance, focus on their solution by order of priority, and comply with the relevant legislative framework, while constantly trying to fi nd ways to reduce the impact of our operations on the environment, thus ensuring a sustainable path for our future.

Signifi cant Environmental Impacts of the Operation of WIND Hellas We recognise, evaluate and set priorities in reference to the impact of our operations on the environment in accordance with the procedures of the certifi ed Environmental Management System that we apply, and then we develop actions to monitor, manage, and minimise or eliminate these impacts. The list of main impacts and their evaluation are reviewed regularly or whenever there is a signifi cant change in our operations.

At WIND Hellas, we acknowledge that the path to sustainable development requires taking immediate and eff ective action against major environmental issues, and we take action without delay, in accordance with our environmental policy, which focuses on the following:

preventing pollution

minimising our environmental impact

regularly reviewing our Environmental Management System

educating and informing our stakeholders

complying with regulatory requirements

Our environmental policy is available in detail atwww.wind.com.gr

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The majority of the projects and investments that we implement have a positive eff ect on environmental performance, but are not recorded as an environmental investment. As a result, there is no data available. Expenses recorded as environmental protection, such as waste management maintenance of the ISO14001-certifi ed environmental management system, and compliance with obligations under Law 2939/2001 on alternative management of specifi c waste streams amounted to approximately €30,0001.

In order to control, eliminate or minimise the impact of our operations, we are planning a series of actions that o� en coincide with actions relating to our Company’s growth and are not considered strictly environmental actions. Since technology is constantly evolving and the improvement of the environmental performance of all kinds of equipment and systems is a part of its development, signifi cant projects such as the modernisation of our Company’s networks provide signifi cant environmental benefi ts. Thus, it is proven in practice that ecology o� en coincides with economy and technological development.

Transport of personnel to and from work or using the Company fl eet and business travel may also be considered as having a signifi cant impact. In 2011, for the fi rst time we recorded and calculated the fuel consumption of our Company’s fl eet of vehicles and the pollutants produced.

Table 1 Signifi cant Environmental Impact of WIND Hellas’ Operations

Environmental Aspect Environmental Impact Actions

Consumption of electricity by all sites Depletion of natural resources, atmospheric pollution, contribution to climate change and atmospheric acidifi cation

Energy saving projects (equipment renewal)

Consumption of heating oil and/or energy production at all sites

Depletion of natural resources, atmospheric pollution, contribution to climate change and atmospheric acidifi cation

Energy saving projects (hybrid energy power generators)

Waste production by all sites Depletion of natural resources, creation of pollution, landfi ll saturation

Actions with the threefold focus “Reduce – Re-use – Recycling”, such as elimination of the use of paper, inspection and re-use of electronic equipment and batteries, recycling of waste, etc.

Electromagnetic energy emissions Atmospheric pollution Environmental Impact Assessments, EM energy emissions assessments, compliance with limits and standards set by Greek and EU legislation as well as international standards.

Transport and travel Depletion of natural resources, atmospheric pollution, contribution to climate change and atmospheric acidifi cation

Employees are prompted to avoid car use and use electronic alternatives to avoid commuting and transport of personnel and materials/documents.

Air conditioning of facilities Atmospheric pollution, depletion of the ozone layer, contribution to climate change

Unit checks, replacement of coolant with zero ODP and reduced GWP.

1 Εstimate

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At WIND Hellas, as a telecommunications service provider, we are not producing products at our facilities, and therefore we are not using raw materials in the same way that manufacturing activities do. However, we do market products with material substance, some of which are manufactured or re-packaged by third parties on our behalf. In addition, through our network of stores, we provide retail bags when purchasing our products. For all of the above, we are monitoring and recording the quantities of paper and plastic used either for products themselves or as packaging.

In 2011, we used 9,943 kg of plastic bags in the sale of our products, 2,030 kg of paper bags, 20.46 tons of paper to print top-up cards, 9.52 tons of plastic for SIM cards, and fi nally, 1.97 tons of plastic, 25.86 tons of paper, and 46.85 tons of paper cartons in the secondary and tertiary packaging of all of the above. In our offi ce operations, in 2011 we used 17,690 kg of paper for printing or photocopies and 683 consumable items for printers. That is, in total, 112.9 tons of paper and 21.43 tons of plastic.

In 2011, we also included the cardboard packaging used by our partner warehouses for transporting our products (cards, discount packages, etc.) in our count of packaging materials. As a result, the paper used for packaging increased by a factor of 2.8 and the average weight of packaging per 1,000 product units increased by 2.8 kg. At the same time, the amount of plastic used was signifi cantly reduced.

8.3 Materials Used & Waste Production

8.3.1 Materials Used

0

2

4

6

8

2009 2010 2011

4.344.84

7.52

0102030405060708090

100

2011 2010 2009

Paper-cardboardPlasticWood

Figure 1Kg of packaging per 1,000 product units

Figure 2Percentage of materials used

in product packaging

88

Retail Bags The plastic bags that we provide at our stores are a special case: they are made of plastic with the addition of a special catalyst that makes them oxo-degradable. The catalyst accelerates the decomposition of the plastic’s molecular chain into small pieces and subsequently, with the aid of the micro-organisms present in nature, it decomposes into non-toxic ingredients that are absorbed by the environment within a few years. The use of similar materials that eff ectively degrade into organic components and are eff ectively absorbed into the environment signifi cantly reduces the volume of waste that is sent for sanitary disposal at Greece’s already saturated landfi lls.

One Step Closer to a Paperless Offi ceAs we believe that the use of paper can be limited to a signifi cant extent with the help of technology, we are continuously searching for new ways to reduce paper consumption in our operations. As a consequence, the amount of paper consumed has been declining for the past 7 years, and we have managed to reduce our paper consumption from 2004 to the present by almost 65%, from approximately 20,000 packs per year to just 7,000 packs. Digitisation and the use of technology off er benefi ts for the environment and for our operations by simplifying, accelerating and streamlining our internal procedures and, naturally, reducing the respective costs.

Paper

Knowing that the use of paper at our offi ces is unavoidable, we use paper that complies with the following criteria in order to reduce the impact of paper use as much as possible.

It is certifi ed by Ecolabel, the European certifi cation for products produced with respect for the environment

It is produced at facilities with ISO 14001 certifi cation

It possesses FSC certifi cation, that is, wood that comes from forests managed with sustainable methods

Finally, any paper that is actually used is gathered in special paper recycling containers located in all of the Company’s buildings and delivered to licensed companies for recycling.

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In this context, in 2011 two new paperless electronic procedures were designed and applied, concerning the handling of purchase orders and the electronic management of invoices. These projects aim to eliminate, to the extent possible, printed internal and external communication, to automate procedures and introduce the use of electronic communications and approvals. The new procedures ensure, on one hand, the acceleration and standardisation of the process of handling the above documents and on the other hand, the reduced use of paper and consumables. At the same time, the need for physical transport of printed documents between the Company’s various sites and / or those of its partners is also eliminated, further contributing to the reduction of the required amount of vehicle routes for correspondence needs.

Electronic processing of orders concerns the electronic issuing, approval and dispatch to suppliers of all purchase orders for the products and services that we procure. The project was applied on a pilot basis in mid-2011 and its scope was extended to all orders by the end of the year. We are expecting the results of full application within 2012, but our initial estimates show that we will save at least 8-10,000 pages of paper.

The electronic invoice management project (e-invoice), which concerns the electronic issuing and dispatch of invoices, began to be applied on a pilot basis in 2010 and was expanded in 2011. The fi rst data from the completion of the application showed that we are handling 160,000 invoices in this way. These invoices are now sent to our partners electronically, thus saving the corresponding amount of paper. We estimate that in the future, from the two above projects, we will save approximately 850 kg of paper per year.

Electronic order management E-invoice

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Initiatives Leading to Paper Saving

Electronic order management

E-invoice

Single-page receipt printing

E-bill

Taking into consideration the relative importance of every procedure that is digitised, the most important projects in terms of saving paper are always the procedures that concern the retail chain and services for our customers.

Thus, in 2011, through the elimination of printing of two documents during the credit top-up process for prepaid telephony and by printing herea� er of a single page, we are saving an estimated 1,900,000 pages, an amount that corresponds to 9.54 tons of paper or an annual 50% reduction. The project in question was applied in June 2011 and follows a series of already completed actions, such as the elimination of copies of receipts for paid bills, replacing the printers with a diff erent type of printer, the elimination of printed communication between stores and the Company and the extensive digitisation and automation of various procedures.

We provide our customers with the option of using the e-bill service and receiving their bill for services in electronic form without requiring printing or receiving only one of the two pages of the bill in printed form. The service has been available since 2010 and we are observing an increase of registered users on the level of 3,000-3,500 subscribers per month. The paper saved per registered individual customer is at least one sheet per bill, which corresponds to at least 30,000-40,000 fewer sheets of paper per year. Considering that most new registered users (about 85%) choose not to receive a printed bill at all, the resulting savings exceeds an estimated 480 kg of paper per year2.

In total, the service has 50,864 registered users. Given that these users, regardless of which form of the service they choose, reduce the printing required by at least one sheet with their registration, then all the users in total are saving at least 8 tons of paper per year and the corresponding printing consumables.

Saving paper in our retail stores Electronic billing of telecommunication services (e-bill)

2 Including envelopes

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In 2011, the operation of our facilities produced in total approximately 502 tons of waste, which consisted of approximately 215 tons of hazardous waste and 287 tons of non-hazardous waste3. The large increase shown in electric, electronic equipment and relevant consumables waste produced due to the upgrading of our network should be mentioned.

The hazardous waste includes accumulators, batteries and electric and electronic equipment containing hazardous components (e.g. computer monitors). Electronic equipment that does not contain hazardous elements is counted as non-hazardous waste. There is no data available regarding the quantities of certain categories of waste produced at base stations and managed by our sub-contractors and associates, nor is there data available for each base station, only for them as a whole.

3 Does not include retail store waste

0

50

100

150

200

250

300

Non-hazardous WasteHazardous Waste

43%

57%

ACCUMULATORS38%

BATTERIES1%

MIXED6%

ELECTRICAL& ELECTRONIC EQUIPMENT WASTE 19%

OTHER 3%

PAPER17%

Figure 3Waste production (tn)

Figure 4Waste production by type

8.3.2 Waste Produced

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0

50,000

100,000

150,000

200,000

Electrical & Electronic Equipment

Waste

AccumulatorsBatteriesMetalPaper

200920102011

Alternative Management 2009-2011Disposal at a Landfill Site

0

100

200

300

400

2009 2010 2011

SALE16%

LANDFILL8%

RECYCLING / ALTERNATIVE MANAGEMENT 76%

Figure 5Waste production by type 2009-2011 (tn)

Figure 6Waste disposal method (tn)

Figure 7Waste management 2011

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We place emphasis on the re-use and recovery of electrical and electronic equipment and other items such as batteries, but also on the reduction of the quantity produced to begin with, whenever this is feasible, based on the European principle “Reduce – Re-use – Recycle”. Recycling or alternative management of as many types of waste as possible is our fi rst choice, followed by sanitary waste disposal when no other solution is feasible.

Dismantled electronic equipment and certain consumables (for example lead-acid batteries) are examined before being disposed of as waste for the possibility of re-use as a whole or for spare parts. The practice of re-using equipment, parts and accessories is particularly widespread and provides fi nancial and environmental benefi ts. In many cases, the option of selling equipment is also examined, since a technology may be considered outdated in Greece but may be fully functional in another country, thus extending its useful life signifi cantly. In this framework, our Company’s procurement department extensively investigated the possibility of sales and successfully found buyers for a total of 81,253 kg of equipment, mostly RBS equipment originating from the upgrading of our network.

In addition, in 2011 15% of the accumulators dismantled as part of the base station upgrading project were re-used. The batteries were found to be reusable a� er inspection and were re-used at other base stations. In this way, we reduced the amount of battery waste produced by approximately 28 tons.

8.3.3 Equipment re-use 8.3.4. Collective Recycling Systems – Hazardous and “Special Waste” Management

Collective Systems Type of Waste

AFIS S.A.(Recycling of Portable Power Poles)

Small household type batteries

Appliance Recycling S.A.All types of WEEE(waste of electrical and electronic equipment)

SYDESYS S.A.(Alternative Accumulator Handling System)

Industrial type batteries and accumulators

Fotokyklosi S.A. (Light Recycling)

Lighting equipment, light bulbs

Hellenic Recovery Recycling Corporation S.A.

All kinds of product packaging

Table 2Collective Recycling Systems for Hazardous Waste

We cooperate with or participate in

Finally, we are continuing the recycling program at our stores (batteries and telecom products and accessories), establishing our stores throughout Greece as collection points for recyclable materials.

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8.4 Energy, Aerial Emissions& Climate Change

In 2011 we consumed a total of 544,708 GJ from three major sources: electrical energy supplied by the Public Power Corporation, fuel oil used for heating and power generators and petrol consumed by our vehicle fl eet.

8.4.1 Energy Consumption, Electricity and Fuel

PETROL19,773

4%

FUEL OIL 233,60743%

ELECTRICITY 291,32853%

Figure 8Total Energy Consumption (GJ)

Vehicle Fleet Petrol

Fuel Oil

In 2011, the Company’s fl eet of vehicles, which consists of various types of vehicles using gasoline, consumed a total of 441,362 litres of unleaded petrol. The number of vehicles on 31 December 2011 was 271, taking into consideration that the size of the fl eet of vehicles constantly fl uctuates during the year. The total energy consumed for transportation by our fl eet of vehicles corresponds to 19,773 GJ.

We consume diesel oil for heating and power generators that are installed at our base stations and our buildings. The generators either operate continuously, supporting the operation of remote base stations without access to the power grid or remain on standby and operate only when there is a power failure at a site normally supplied by the electricity grid. It is evident that the quantity consumed at the permanently operating generators is the largest, representing approximately 90-95% of our total oil consumption.

95

In 2011 a signifi cant decrease (16%) of the amount of oil consumed was observed due to one particularly important project - the replacement of the permanently operating power generators with hybrid generator / battery systems. The project is ongoing but has already yielded signifi cant savings in energy and thus emissions.

Overall, over the last two years, oil consumption has been reduced by 25%, due to the ongoing project but also due to the elimination of a number of permanent power generators and the connection of base stations to the electricity grid.

Fuel Oil (GJ)

200,000

220,000

240,000

260,000

280,000

300,000

320,000

2009 2010 2011

tonCO2e

10,00011,00012,00013,00014,00015,00016,00017,00018,00019,00020,000

Figure 9Oil Consumption and aerial emissions

ElectricityTotal electricity consumption for our operations in 2011 remained stable, at the same level as in 2010, with a negligible increase of 0.02%. Actual consumption amounted to 80,924 MWh compared to 80,908 in 2010. Consumption on the Company’s network declined for the third consecutive year, to 51,629 MWh, a decrease of 4.26% compared to 2010 and 7.48% compared to 2009. The decrease in question is due to the ongoing projects of the Company to modernise its telecommunications network while simultaneously increasing its effi ciency in terms of energy consumption.

0

50,000

100,000

150,000

200,000

250,000

2009 2010 2011

Office BuildingsTelecommunications Buildings

Base Stations

Figure 10Electricity Consumption (GJ)

96

Hybrid Energy Production at Remote Base Stations

In 2011 we initiated a particularly important project for the Company’s environmental performance, which concerns the replacement of the permanently functioning power generators at remote base stations with new hybrid systems. The new systems utilise the energy produced by the generator’s operation in order to charge battery packs, which in turn power the station when the generator stops. The batteries then empty, the generator restarts and the cycle is repeated. In this way, the power generator does not need to be operating 24 hours a day, but instead only 4-5 hours, thus saving considerable amounts of fuel and avoiding the emission of pollutants. This project is under way and is expected to be completed by the end of 2012. By 31 December 2011, 85% of the generators scheduled for replacement had been replaced. The system is saving almost 80% of fuel oil consumption on a daily basis, which corresponds to over 3,000,000 litres of fuel per year, or approximately 186,000 GJ. In 2011, due to the gradual replacement of the systems, the actual savings amounted to approximately 1,000,000 litres of fuel or about 45,500 GJ.

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“In the adverse domestic and international economic situation that we are experiencing, in which the system is unable to support entrepreneurship and green investments, the need for

intelligent and innovative solutions that provide savings and improvements to effi ciency is more urgent than ever. The innovative ‘green’ Hybrid Fuel Savings System (HFSS), completely designed and manufactured by ILVIOKAT S.A., has already been installed in remote WIND Hellas base stations that are not connected to the electricity grid which are powered through 24-hout power generators. The HFSS provides more than 70% fuel savings compared to the installed 24-hour generators and a corresponding reduction of greenhouse gas emissions, which translates into the equivalent of approximately 7,000 tons of carbon dioxide per year.“

Emmanuel Mantouvalos, Director of the Energy Sector, ILVIOKAT

Initiatives to Save Energy Modernisation of the Telecommunications Network

Modernisation of the Core Network

The Network Modernisation Project constitutes one of the largest investments and most important projects for the Company in recent years.

The cleverly designed new equipment that replaces older technology units on mobile phone base stations provides a clearly improved ratio of performance / capacity with low energy consumption. For example, the energy savings is expected to reach 50% for radio network equipment, e.g. moving from a typical consumption of around 2.5 to 3.0 KW to consumption that does not exceed 1.5KW. In addition, the technology used to cool the equipment utilises natural ventilation, allowing for greater economy in energy consumption.

Considering a base station overall, the energy saving we expect may reach 15%, an estimate that has been confi rmed by electricity bills for the stations that have completed the upgrade. For all base stations that have been replaced so far, we estimate that annually we save 9,624 GJ4.

All the new electronic equipment is completely harmonised with the European-wide requirements to limit use of hazardous materials and in particular

heavy metals during their manufacture (RoHS), according to the information provided to us by the manufacturers. Finally, the new equipment is signifi cantly reduced in size, and in some cases, occupies almost half the space required with previous technology.

Since the beginning of the project, 640 base stations of various types have been replaced (Dec. 2011).

4 Calculation was carried out with the average annual consumption for all the base stations that have been replaced from the beginning of the project until the end of 2011.

Wherever GJ are shown, the conversion factors mentioned in the standard GRI 3.1 have been used.

Modernisation of the Telecommunications Network

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Besides the changes carried out at the base stations, the modernisation of the Company’s core network equipment is also being implemented gradually at ten locations. The project is at an advanced stage, with the goal of completion at the end of 2012. With the upgrading of systems and the replacement of equipment with newer technology (e.g. blade servers with upgraded hardware), we estimate that up to 247,000 KWh are being saved on an annual basis in the entire project. Savings result from more effi cient operation of the new servers, combined with the removal of servers that due to the overall upgrade are no longer required for the smooth functioning of our network. In total, servers at 4 of the Company’s facilities will be fully eliminated, and those at 8 facilities will be replaced.

With the completion of the upgrade on our entire network, we estimate that we will be able to achieve energy savings of 22,000 GJ or more.

Modernisation of the Core Network

The most important sources of greenhouse gases emissions are the consumption of fuel oil for power generators for permanent continuous operation or back up use at facilities, in the heating boilers and the indirect emissions from the consumption of electricity from the Public Power Corporation. Other sources of emissions are WIND’s fl eet of vehicles and business travel (by air and by sea).

To calculate emissions, we use the calculation guide of the Greenhouse Gas Protocol5. Indirect emissions from electricity consumption form an exception; for them, we use the average conversion coeffi cient announced by the Public Power Corporation for its entire network, from which we obtain all of our electricity. The most recent conversion coeffi cient from the PPC concerns the year 2009 and amounts to 0.997kg/kWh.

Greenhouse gas emissions from the Company’s activities are divided into direct and indirect emissions. Direct emissions are considered to mean the emissions from the use of fuel oil for heating and for the power generators, while indirect ones mean emissions from the use of electricity, transportation of employees, etc. The available data based on which we have calculated pollutant emissions for 2011 include the use of fuel oil and fuel for our fl eet of vehicles, consumption of electricity, business trips by airplane and boat, and approximately calculated refrigerant leaks.

The total amount of greenhouse gases that we emit due to our activity in accordance with the above, calculated in tons of carbon dioxide equivalent, amounted to 98,433 tn.

8.4.2 Greenhouse Gases Emissions

5 http://www.ghgprotocol.org

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HFC 410a8%

HFC 407c52%

HFC 2240%

HEATING & FUEL OIL15%

PETROL1%

ELECTRICITY82%

TRAVEL0%

REFRIGERANT LEAKS2%

Figure 11Total Greenhouse Gases Emissions

Figure 12 Estimation of Refrigerant Leaks into the Environment

Table 3Benefi t to the Environment

from energy saving projects

Project Energy Saved Emissions Avoided

Installation of hybrid power generators instead of permanently operating power generators

44,563 GJ 2,767 tn CO2e

Telecommunication and Core Network Upgrade

105,262 GJ 2,915 tn CO2e

We estimate that with the energy conservation actions that we applied, in 2011 we saved the approximate equivalent of 5,877 tons of carbon dioxide. The benefi t from the respective actions was as follows:

WIND’s services and operations do not produce ozone depleting gas emissions. The only source is possible leaks from the circuits of the air conditioning units.

A program is already under way to replace the old air conditioning units that operate using HCFC-22, a refrigerant that will be completely phased-out from the European market by 2015, in the framework of the overall worldwide eff ort to eliminate the use of hydrochlorofl uorocarbons (HCFC) that are harmful to the ozone layer.

In total, in 2011 58 air conditioning units using HCFC-22 were replaced at base stations. The new systems contain a refrigerant with zero impact on the ozone layer (Ozone Depleting Potential).

8.4.2.1 Pollutant emissions / ozone depleting emissions

100

Figure 13 Estimated Eff ect on the Climate from Refrigerant Leaks

Since 2008, more than 300 air conditioning units have been replaced by newer technology models that use non-chlorinated refrigerants. In addition, the new types of refrigerants have a slightly improved Global Warming Potential6. That is, if all of our air conditioning units operated using HCFC-22, we would have had 193.5 more tons of CO2e emissions.

Besides HCFC-22, in the entire year 768 kg of HFC 407c refrigerant were used and 125 kg of refrigerant type HFC 410a. We estimate that of these, approximately 650 kg of HFC 407c and 105 kg of HFC 410a were released into the environment. Calculating the global warming potential for each one of these substances in total, we estimate that the release of fl uorinated refrigerants into the environment accounted for the emission of 586 tons of CO2e.

We recorded the addition of 588 kg of refrigerant to the circuits of the units that contain HCFC-22 and are going to be replaced but are still operating. Considering that at least 80-90% of this quantity probably leaked into the atmosphere, we calculate that for 2011, approximately 500 kg of HCFC-22 may have been released into the atmosphere, which corresponds to the equivalent of approximately 905 tons of CO2.

We estimate that in total, out of all types of refrigerants: 1,259 kilos of refrigerants were released, which corresponds to the equivalent of 2,084 tons of carbon dioxide. Our goal is to replace all of the HCFC-22 that we have at our facilities by 2015, in line with the regulations of European and national legislation and the demands of the Montreal Protocol.

6 GWP Values for HCFC-22: 1810, HFC-410a: 1725, HFC407c: 1526 / Source: GRI 3.1 and Greenhouse Gas Protocol

kg of refrigerantCO2e (tn)

0

200

400

600

800

1,000

1,200

HCFC22 HFC407c HFC410a

101

8.5 Biodiversity

The recognition of the importance of biodiversity and natural resources is continuously gaining ground worldwide and in the European Union, and increasingly measures are being taken to control the impact of human presence and activity on nature. The most profound characteristic of Greek nature is the variety of ecosystems, rich in fl ora and fauna, which include many endemic plant and animal species. Further, for many rare or endangered animals, Greece is one of the last refuges in the Mediterranean and in Europe. Thus, 27.29% of the Greek landscape has been included in the European network Natura 2000 framework, created to protect and conserve nature and biodiversity in the EU; the majority of the sites are of considerable size7.

Therefore, it is inevitable that a number of base stations will be located within designated protected areas.

According to the latest count of base stations located within designated areas, we calculate that they occupied approximately 11,760 square metres of land in 43 prefectures in the country8. The table below lists the specifi c identifi cation numbers of the designated area where the station is located in each prefecture. More information about these areas can be found on the offi cial web pages of the Ministry of the Environment, Energy, and Climate Change9.

8.5.1 Presence in Protected Areas

7 http://www.ypeka.gr/LinkClick.aspx?fi leticket=13dUwY5yc7U%3D&tabid=432 8 Calculated at 70 m2/station

9 http://www.ypeka.gr/Default.aspx?tabid=432&language=el-GR

Prefecture Designated Area CodeAITOLOAKARNANIA GR2310001, GR2310005, GR2310010, GR2310012, GR2310015ARGOLIDA GR2510003ARCADIA GR2520001, GR2520006ATTICA GR2530005, GR3000001, GR3000005, GR3000006, GR3000008,GR3000012, GR3000013ACHAIA GR2320001, GR2320002, GR2320004GREVENA GR1310001DRAMA GR1140004DODECANESE GR4210003, GR4210004, GR4210005, GR4210006, GR4210008, GR4210010, GR4210015, GR4210024EVROS GR1110002, GR1110004, GR1110005, GR1110008, GR1110009EVIA GR2420001, GR2420008EVRYTANIA GR2430001ILEIA GR2330002IMATHIA GR1210001, GR1210002 HERAKLIO GR4310002, GR4310004, GR4310005, GR4310008, GR4310010THESPROTIA GR2120009

Table 4Presence in Natura designated areas

102

Prefecture Designated Area CodeTHESSALONIKI GR1220002, GR1220003, GR1220010IOANNINA GR2130001, GR2130004, GR2130006, GR2130007, GR2130008, GR2130010KAVALA GR1150010KERKYRA (CORFU) GR2230004KEFALLONIA GR2220001, GR2220002KILKIS GR1220002CORINTHIA GR2530001, GR2530004, GR2530005CYCLADES GR4220003, GR4220004, GR4220009, GR4220011, GR4220012, GR4220014, GR4220020, GR4220024 LAKONIA GR2540001, GR2540003, GR2550006, GR2540007, GR2550009, LARISSA GR1420001, GR1420004, GR1420005, GR1420006, GR1420007, GR1420008LASSITHI GR4320002, GR4320005, GR4320006, GR4320009, GR4320010LESVOS GR4110001, GR4110002, GR4110003, GR4110005MAGNISIA GR1430001, GR1430004MESSINIA GR2550003, GR2550006, GR2550009XANTHI GR1120005PELLA GR1240002, GR1240004PIERIA GR1250001RETHYMNO GR4330004, GR4330005, GR4330007, GR4330009, GR4330012, GR4330019RODOPI GR1130011SAMOS GR4120003, GR4120004, GR4120005, GR4120006SERRES GR1150005, GR1260001, GR1260004, GR1260008, GR1260009, GR1260010TRIKALA GR1440001, GR1440002, GR1440003, GR1440005FTHIOTIDA GR2450005FLORINA GR1240001, GR1340001FOKIDA GR2450001, GR2450002, GR2450004CHALKIDIKI GR1270001, GR1270002, GR1270003, GR1270005, GR1270012CHANIA GR4340004, GR4340008, GR4340013CHIOS GR4130001

The impact of the installation and operation of most base stations is generally limited, and specifi cally in regard to biodiversity, it is negligible, according to current scientifi c data. The vast majority of the facilities consist of small installations without any personnel. In any case, all the recognised forms of impact are recorded and analysed in detail through the Environmental Impact Studies that are prepared in the licensing process for every site.

The most important impact of the operation of base stations is energy consumption and emission of electromagnetic energy in the form of waves. There is also limited production of waste from equipment maintenance work, an impact that is more important at the station construction or dismantling stage, as well as impact from movement of persons and vehicles. During operation, transportation to and from the station is limited.

8.5.2 Impact on Biodiversity – Environmental Impact Assessment

103

Water usage at our facilities is limited to serving per-sonnel at buildings and to watering gardens. For this reason, the quantity consumed is ultimately rather limited for the Company’s size and is not considered to have a signifi cant impact. Consumption is recorded only for the Company’s large facilities, which account for 85% of our personnel, and in 2011 it amounted to 15,265 cubic meters.

Likewise, liquid waste production is limited to waste generated from the personnel services; waste is then directed to the sewage system. Considering the percentage used by the water provider, that is, 75% of the water that we use goes to the sewage network as waste, and subtracting the amount used for watering, which corresponds to approximately 40% of total con-sumption, we estimate that approximately 6,900 cubic meters of wastewater was diverted to the municipal

sewage system. The reduction recorded in the graph is due to the reduction of the number of employees and to the use of more effi cient irrigation methods (automated drip system).

8.6 Water

Figure 14Water Consumption (m3)

13,50014,00014,50015,00015,50016,00016,50017,00017,50018,000

2009 2010 2011

Some sites have more numerous and more signifi cant impacts, but the number of those sites is very small compared to the total, while they are mainly located within urban areas. In 2011, only 2.5% of the studies submitted concerned sites of this type (Α2).

In addition, for every type of site, instructions are provided to our personnel and associates through the environmental management system that we apply

in order to minimise and / or eliminate the impact of the existence and operation of the site, and / or implemented improvement projects, such as the reduction of energy consumption (e.g. hybrid power generators), ensuring compliance with the emission limits of EMR to the environment (e.g. laboratory accreditation according to ISO17025) and monitoring of waste with emphasis on hazardous waste generated.

104

10 Out of total emissions due to energy consumption

105

Regarding paper use, we aim in 2012 to examine the possibility of switching from a two-page standard services bill to a one-page, thus reducing the amount of paper used in billing our customers for the services they receive.

With respect to waste management and in-line with our continuous performance improvement policy, we aim to re-design the waste data collection process from base stations.

We aim to organise the separate collection and recycling of aluminium and plastic household-type waste from our main offi ce buildings (>85% of employees), with a target to further reduce the amount of waste being sent to landfi ll.

The completion of the installation of hybrid energy production systems at remote base stations in accordance with our plan.

The completion of the project for the replacement and renewal of equipment at the telecommunication centres and the Company’s core network. Our target is to reduce energy consumption by 5% of total (-56,000GJ) and pollutant emissions by 15% (-20,000 tn CO2e)10.

Goals 2012

9. Society

106

As our main strategy is to continuously and systematically contribute to Sustainable Development and to improve the overall quality of life in the local communities where we are active, what we provide to residential customers and businesses, fi rst and foremost, is reliable and technologically sound services.

At the same time, we endorse a wide range of social activities in local communities related to supporting a large variety of initiatives –social, cultural, athletic, environmental and educational– to help create a better tomorrow for everyone.

Achievements 2011:

We implemented thekids@safety, internet, mobile & child

campaign, by developing informational material, carrying out scientific researches, creating entertaining

and interactive trivia games, videos and other educational media as well as organising seminars

We donated €40,000 to the Ark of the World organisation through the participation of the WIND Running Team

in the 29th Athens Classic Marathon

We actively supported volunteer rescue teamsas part of the European Year of Volunteerism

We stood by our fellow citizens by covering their telecommunications needs in response to

the adverse economic times Greece is experiencing

We donated €21,700 to social organisations,through the Children Win campaign,

which we implemented for the third consecutive year

107

9.1 Our Contribution to Society One of our main goals for 2011 was not only fi nancially supporting one action or organisation, but also creating those circumstances that could lead to the active involvement of more and more people in achieving a specifi c goal, advocating social solidarity and participation.

In 2011 we focused on fortifying sports, mainly by culti-vating athletic ideals, such as fair play and competitive virtues.

The selection of the action areas arose from:

We followed a specifi c management and assessment plan.

implementing actions and providing aid to organisations in the following areas: Culture, Sports, Education/Children, Environment and Social Support.

the resultsof dialogue

with stakeholders

cooperationand dialogue

with organisations

the examinationof actions carried out

by other Europeantelecom operators

targeted socialneeds to whichwe responded

ActionSelection

Monitoringand

Assessment

ActionDesign

ActionImplementation

108

9.2 We Support Sports and Culture

We support eff orts and initiatives aiming at the further diff usion of sports and culture in Greece and at raising awareness.

9.2.1 Sports

29th Athens Classic Marathon

The year 2011 was marked by great success with our participation in the 29th Athens Classic Marathon. As an Offi cial Sponsor and Name Sponsor in the 5 & 10 km races, we formed the WIND Running Team, the largest team that has ever participated in these races. More than 1,000 runners of the WIND Running Team contributed to the social solidarity initiative to support the work of the Ark of the World organisation. With the message “One Race for All”, in WIND we believe that ALL people, each in his or her own way, regardless of age or gender, can participate and gain the unique experience of running a race that is linked to so many diff erent and signifi cant ideals. The WIND Running Team is made up by WIND employees, associates and friends. The team members always run for a good cause and aim at promoting fair play, dedication to a goal and love of sports, not only as a way of life, but also as a means of strengthening social solidarity.

In the 29th Athens Classic Marathon we implemented a multitude of actions. Through a series of “mechanisms” that we activated both before and during the races, we managed to collect the amount of €40,000 for the children of the Ark of the World.

109

Children Win

For the third year in a row, basketball players Thodoris Papaloukas and Dimitris Diamantidis scored “shots of

love” as part of the Children Win social campaign. By shooting hoops, the players supported two social groups since WIND sponsored each winning shot with €100. The amount collected from this very special initiative for the 2011 basketball season, including the Cup Final, the Greek Basket League and the Euroleague Games, came to €21,700.

The money from Thodoris’s shots went to the Child Neurology Ward of the Pendeli Children’s Hospital in Athens to remodel two special wards to better accommodate and care for the young patients. Dimitris’s shots funded the renovation needs for the Society for the Protection of People with Autism Day Centre in his hometown in southern Kastoria.

Children Win is an initiative that tangibly shows our substantial support to vulnerable social groups both in the urban centres as well as in the rural regions.

110

We actively and systematically contribute to the development of sports by fi nancially supporting athletic clubs, regional teams and many athletes. In 2011 we supported both professional teams, such as the Olympiakos basketball team, as well as amateurs, such as the IT Department Basketball Team of the Athens Kapodistrian University.

Over the last 19 years we have consistently supported the WIND Zantino sailboat, which grew into something even greater in 2011. It became the symbol of journeying over the Greek seas and the ambassador in our eff orts to inform citizens about stray and abandoned animals.

Equally commanding was our presence in the fi eld of Culture as we fostered many diff erent types of artistic events, such as theatre, fi lm, music and the visual arts.

9.2.2 Culture

We want to make a step forward! TEDxAcademy 2011Radical Change, Transformation and New Era were the three themes of the TEDxAcademy 2011 program held at the Benaki Museum in Athens with speakers from all over the world presenting their thoughts and proposals to a full amphitheatre that could help Greece take a step forward in overcoming the fi nancial crisis.

The rooting out of stereotypes, the contemporary approach to agriculture, the potential of innovation for environmentally friendly solutions, the power of the internet, resourcefulness and creativity, the challenges Greek society faces, and the progress of European Union were only some of the issues touched upon by the speakers.

This was the second time a TEDxAcademy event was held in Greece.

111

Since the very beginning of our activity in the telecoms sector, top priority was given to the participation in and support of education. It is no accident that to this day we have implemented numerous actions aiming at strengthening the educational process, funding state schools and graduate studies for students completing their fi rst degree. Thus, in the last 11 years we have been implementing the initiative entitled Journey into the World of Knowledge, aiming at creating in action those conditions for the equal access of all children to education, while narrowing the digital gap and keeping children abreast of the fast-paced changes in new technologies.

Due to the particular fi nancial circumstances, in 2011 we donated hardware and so� ware to more than 14 schools in the Attica Prefecture and rural regions.

9.3 Education

11 years358 schools15 prefectures

Journey into the World of Knowledge

Year Number of Schools

2001 15

2002 24

2003 45

2004 39

2005 42

2006 38

2007 54

2008 44 + 8

2009 12 + 11

2010 12

2011 14

Region

Evros

The Dodecanese Islands

Epirus

Chania, Crete

Northern Sporades Islands

Rodopi & Xanthi

Messinia

Fthiotida & other regions

Arcadia & other regions

Heraklion, Crete

Attica and broader regions

Total 358

112

Bronze medal in the 2011 European Union Science Olympiad (EUSO 2011)

2nd Experimental General Lyceum of Athens

With great pleasure we supported the 2nd Experimental General Lyceum of Athens and its participation in the 9th European Union Science Olympiad (www.euso.dcu.ie), which was held in the Czech Republic from 10 to 16 April 2011.

The bronze medal won by the team of the 2nd Experimental General Lyceum of Athens helped the Greek delegation stand out, with the students performing exceptionally and receiving one of the highest scores in Europe. The EUSO involves a laboratory competition in the Natural Sciences, aimed at:

promoting experimental teaching of the Natural Sciences (Physics, Chemistry, Biology).

engaging students in scientifi c methodology for the purposes of solving real problems in day-to-day life through experimentation in the school science laboratory.

The students represented their country a� er fi rst distinguishing themselves in a Greece-wide competition held by the Panhellenic Association of Heads of Natural Science Laboratory Centres (PANEKFE) under the auspices of the Ministry of Education, Lifelong Learning & Religious Aff airs.

113

Mobile phones and the internet are now an important part of our children’s lives. Like every technological advance, they have both positive and negative repercussions, particularly when they are used on a daily basis. Both the internet and mobile phones are technological privileges, and we can train our children to use them properly, adopting safe internet conduct and avoiding potential hazards.

In 2011 we put particular emphasis on carrying out the Kids@safety, internet, mobile and child awareness campaign aimed at raising parents’ substantial and constructive awareness of new technologies and in particular of the appropriate use of mobile phones and the internet by children.

For the fi rst time we created specialised materials under the scientifi c supervision of Ioannis Tsiantis, MD, DPM, FRC Psych. Professor of Child Psychology, Scientifi c Head of the Association for the Psychosocial Health of Children and Adolescents (A.P.H.C.A.).

Kids@safety, internet, mobile and child

“The need to inform parents about ways children can use the internet safely is now imperative. Since 2010 we have been working with WIND to inform parents about the dangers children may come across on the internet, ways to deal with these dangers, prevention and the advantages of the proper use of the internet.”

Anna E� himiou, Chairman of the N.G.O. N.E.O.I. Thessaloniki

114

and in collaboration with the A.P.H.C.A. Through specialised print and electronic materials, as well as a number of coordinated actions and activities throughout the year, we focused on the important psychosocial role played by the Internet and mobile phones in children’s lives today, while at the same time we proposed ways to train and guide children to use the new technologies responsibly and safely.

Our awareness campaign was developed on many levels, including informative leafl ets, scientifi c researches, fun quizzes, interactive knowledge games, videos and other educational tools, as well as seminars at schools and for our employees, special commercial off ers with free parental-control so� ware packages and many other actions that make up the major Kids@safety, internet, mobile and child social awareness campaign. All the materials are available at www.kidsatsafety.gr, a website created exclusively for this purpose.

Most parents in Greece recognise that they need to familiarise their children with computers and the internet, for both educational and social purposes, while more and more parents are allowing their children to use mobile phones. In this context, the Cyber Crime Unit headed by Director Emmanuel Sfakianakis, launched a series of informative one-day conferences throughout Greece. From the very outset, we supported this eff ort and we continue to respond positively to such initiatives. Thus, within the framework of the kids@safety awareness campaign, we supported the new A.P.H.C.A. initiative to publish the book Delete Electronic Bullying, which, in accessible and modern language, addresses adolescents on an issue that concerns them directly.

“Delete Electronic Bullying enables children to recognise, reject and react in a way similar to how they deal with other forms of bullying.”

Betina Davou, Professor of Cognitive Psychology

115

“The basic rules of road safety must be taught to children very early on.

Our Municipality’s initiative for the creation of a special leafl et has precisely this aim: To prepare children by helping them understand the basic rules of road safety so that, as they get older, they can become responsible citizens and responsible pedestrians and drivers. This educational action on the part of our Municipality was supported by WIND, because of its contribution in raising awareness among young pupils of the road safety.”

Andreas Filias, Vice Mayor of Education, Transparency &

e-Government, Municipality of Patras

Road Safety

116

“85,000 animals are abandoned every year in Greece. This is sad, particularly when you consider that the great thinker Mahatma Ghandi once said that ‘The greatness of a nation and its moral progress can be judged by the way its animals are treated.’ For 50 years

now, the GAWF has been trying to improve the lives of animals in Greece. The GAWF always has allies in this eff ort, and WIND is among them, helping the GAWF, with sensitivity and responsibility, to continue its animal welfare work, starting with a dynamic campaign for the neutering of animals in Athens and Thessaloniki. We support such initiatives and hope for their continuation so that we can bring on-going improvement to the lives of all the ‘homeless’ animals in Greece.”

Amalia Sotirhou, CEO of the Greek Animal Welfare Fund

On the occasion of World Animal Day, on 4 October, we conveyed the message of love and care for our four-legged friends. In collaboration with the Greek Animal Welfare Fund (GAWF) we initiated a program for neutering stray animals in Attica and Thessaloniki, concurrently supporting the eff orts of local animal welfare groups.

The program was set to last 3 months, from 4 October to the end of December 2011; 19 groups joined the program for locating and transporting animals for surgery, neutering eventually over 100 animals. The program is part of a long-term eff ort on the part of the GAWF and many animal welfare groups to promote more civilised treatment of the stray animals that wander the streets without homes or food. The ultimate goal of this eff ort is a reduction in stray animals, greater safety for residents, the promotion of social awareness among citizens, and the adoption of animals by people who will give them the warmth and security of a family.

GAWF… and caring for stray animals “In Action”

117

The 1st Sustainable School Award contest was carried out with great success and the participation of 140 schools. The contest is held by the Environmental Education Council of the Hellenic Society for Environment & Culture, under the auspices of the Ministries of Education, Life-long Learning & Religious Aff airs and Environment, Energy & Climate Change, with the generous support of the Bodossaki Foundation and WIND.

The schools that distinguished themselves were the 2nd Experimental Elementary School of the University of the Aegean-Rhodes, the 2nd Junior High School of Xylokastro, Corinthia, and the Special Technical School of Patras, who won in their respective categories.

Sustainable School Award

9.4 Environment

118

It’s up to all of us to protect the forests! For the fourth consecutive year we support the Volunteer Firefi ghter and Rescue Teams of the Rodopolis Municipal Department of the Municipality of Dionysos, as their contribution to the protection of human life and the environment is invaluable. Every year, 70 fi re-fi ghters and rescuers volunteer their personal time and energy for the sole purpose of providing assistance to our fellow human beings who are in danger.

2011 European Year of Volunteerism

“VOLUNTEERISM HAS NO BORDERS OR LIMITS. This is a matter that concerns all of us, regardless of class or profession. The Attica Hellenic Rescue Team has really made us proud.”

V. Orfanos, Member of the Hellenic Rescue Team

Hellenic Rescue TeamActively supporting volunteerism, we undertook to cover all the telecommunications needs of the Athens HRT. Specifi cally, within the framework of the Corporate Responsibility strategy we covered the Team’s mobile and fi xed telephone needs, contributing to the volunteers’ eff orts to help those who need organised and specialised support.

“I’m no diff erent from you. I, too, am just a simple person who isn’t trying to change the world. The only thing I want is to protect human life and the environment. But I can’t do that alone, and that’s why I became a volunteer fi refi ghter.”

A. Kounis, Volunteer Chief Firefi ghter

119

9.5 Social Support

Communication doesn’t stop in diffi cult circumstances

We provided the possibility for covering the basic telecommunications needs of 100 single-parent families in Ioannina with mobile telephony services. In collaboration with the Municipality of Ioannina’s Social Policy Service, we provided mobile telephony services to cover the essential communication needs of eligible customers and their families.

This action is part of our Corporate Responsibility strategy “In Action”, and this way we show in practice that we stand by the residents of Ioannina, covering all their telecommunications needs through special rates and off ers, and supporting them socially.

Support of 100 single-parent families

We off ered special rates for mobile, fi xed & internet services to those unemployed with Manpower Employment Organisation (OAED) eligibility, responding positively to a relevant invitation and initiative from the OAED Management. WIND not only responded positively to this OAED initiative, but was among the fi rst companies to participate.

Support for the unemployed

120

The strengthening of the volunteer groups involved in protecting the environment and promoting social contribution through sports.

The continued eff ort to raise awareness among parents and children regarding the safe use of mobile phones and the internet through the staging of events in schools and cities throughout Greece.

The support of groups of people in need (e.g. unemployed, homeless, etc.) due to the economic crisis in Greece.

The investment in the “Journey in the World of Knowledge” program, providing schools in isolated areas and elsewhere with technological equipment, with the aim of giving all children an equal opportunity to utilise the new technologies.

The support for the eff ort to neutering stray animals.

Goals 2012

121

Goal 2011 Result

CORPORATE GOVERNANCE

To explore and implement additional mechanisms to further restrict confl icts of interest and enhance transparency. √

To eliminate possible incidents of corruption that could arise from non-authorised approvals or approvals outside the

competence remit, by strengthening the automated order approval mechanism, thus ensuring more eff ective control. √

To further develop the Business Continuity System, with an annual review of the existing strategies and further development

of plans for the recovery of critical operations in various sectors and areas in which Business Continuity Plans have been

completed (e.g. Network Department, Customer Service Department, IT Department).

To implement an information & training program: the aim was to continue training (through workshops) the personnel of all

departments in which similar Business Continuity projects will be prepared. √

To accredit WIND’s Electromagnetic Field Measurement Laboratory according to the requirements of ELOT EN ISO/

IEC17025:2005 standard by the Hellenic Accreditation System (ESYD). In progress

Sample verifi cation and cross-checks by the Internal Audit Department of data collection for our annual Sustainability Report. √

SOCIETY

To develop actions and broaden our kids@safety, internet, mobiles and child informative campaign through one-day events,

e-content, partnerships etc.√

To place special emphasis on social groups such as children and the unemployed. √

To expand existing programs in favour of the groups we are already supporting. √

To promote and showcase sports events which contribute to a better quality of life. √

TedxAcademy: to participate just as actively in 2011 and to disseminate outputs to stakeholders and to the greater public. √

ENVIRONMENT

To continue replacing conventional generators with hybrid systems, combining power generators running on oil and

batteries, the aim being to cut down on oil consumption at least by 3 million litres and on carbon dioxide equivalent at least

by 8 thousand tonnes.

In progress

Replacement of base station equipment as per our triennial plan. In progress

To generate even less waste destined for sanitary landfi ll sites. √

To increase the part of waste under Alternative Waste Management. √

10. Objectives & Results 2011

122

Goal 2011 Result

MARKET

Expanding our Customer Satisfaction Measurement System to include the Fixed Telephony Call Centre. In progress

A new website with a plethora of on-line apps and an on-line shop off ering fast and reliable service to the users. √

Continuous improvement of monitoring, recording and disclosure systems and procedures for Quality Indicators. In progress

Investing in integrated fi xed telephony, mobile telephony and internet services for all at competitive prices. √

Creating innovative mobile telephony products and services that guarantee good value for money and fl exibility by putting

our subscribers in control of their bills.√

Plain language bills including a breakdown of charges, taxes and levies, together with personalised suggestions

depending on each subscriber’s needs. √

A strong social media presence on Facebook and Twitter in order to come even closer to our subscribers. √

Parental control so� ware to be provided upon activation of Internet services. In progress

EMPLOYEES

Development Centres for specifi c staff groups to foster professional development for our people in order to improve

the quality of services provided to our customers.√

Eco News, an e-bulletin aspiring to inform and raise awareness about the environment among our staff as well as

to encourage them to become actively involved in its protection. √

Invest in internal Communication through presentations and discussions to improve staff access to corporate information

and know-how. √

WIND’s Running Team together with encouragement of corporate sports teams with the active participation of

our employees in order to promote team spirit and volunteerism. √

To further empower the concept of volunteerism within the company by informing our people and encouraging them to

actively participate in environmental actions as volunteers. √

Regular information on health and safety matters and off er of check-ups for our personnel and their families either

for free or at concessionary rates. √

WIND’s Parents’ Day promoting ecological awareness and social work by supporting charitable and environmental

organisations. √

Support for the Blood Bank of our employees. √

123

11. Glossary

Base Station: These are fi xed locations of the mobile telephony network, through which data and information reception and transmission take place, so that network coverage is expanded and also shared with hierarchically lower networks.

Stations possess the necessary infrastructure for continuous operation and monitoring.

Broadband: Broadband is the technology that enables high speed Internet connection. This connection is continuous with high speed of downloading and uploading data, voice, sound, image, etc.

Core Network: The central and hierarchically higher part of a telecommunications network through which various individual networks are connected, securing geographical coverage.

Corporate Responsibility: Refers to corporate actions whose aim is to help tackle environmental and social issues in the area of their operation, recognising the responsibility that corresponds to them.

Double Play: Double Play is the service that combines fi xed telephony and high speed access to the internet (usually through DSL).

EETT: The National Telecommunications and Post Commission of Greece, which is an Independent Authority that controls, regulates and supervises the electronic communications and postal services markets.

Extranet: Is a network of computers and data which is fully or partially accessible for a specifi c purpose or use from points outside that network. Frequently the term is also used for the companies’ portal which is accessible by associates, sales network, etc.

Gbps: Measurement unit of the rate of data transmission (Gigabit per second).

Gbps GR-IX: High speed connection (Greek Internet Exchange) between Internet Service Providers operating in Greece, through which their traffi c is directly exchanged, resulting in faster service to Internet users.

Global Compact: The United Nations initiative for businesses that are committed to operating in accordance with 10 internationally recognised principles.

Global Reporting Initiative (GRI): The International Organisation which has developed a sustainability reporting framework aiming at the systematic incorporation of sustainability in the company’s approach to environment, society and governance.

GSM: GSM is the European standard for the technology deployed in mobile telephony for receiving and transmitting voice.

International Organisation for Standardisation (ISO): The International Organisation for Standardisation which develops internationally recognised standards, with 162 member countries.

124

Intranet: A network of computers and data which is accessible only from points within the network (e.g. by an organisation’s computers/users). Frequently the term is used for the company’s internal portal.

IOBE: Foundation for Economic and Industrial Research.

LTE: A modern technology standard for high speed wireless data transmission, chiefl y used in mobile telephony.

Multimedia Information Service: The Multimedia Information Services are electronic communications services that pertain to the transmission of information/content in electronic communication networks, whose pricing is done by charging calls to numbering resources of the National Numbering Plan, particularly the 901, 909, 14, 190-195 and 54 series (e.g. SMS, MMS, Audiotext, Videotext and other services).

Natura 2000 Network: The Natura 2000 Network consists of the Special Areas of Conservation set forth in Directive 92/43/EEC and of Special Protection Areas for birds set forth in Directive 79/409/EEC for the protection of birds. The creation of the “Natura 2000” network, which also constitutes an obligation of Greece, contributes to the more eff ective protection of endangered species and habitats and constitutes the main means of conserving biodiversity and the general protection of the natural environment.

Optical Fibres: High tech telecommunications cables through which data transmission is carried out in the light spectrum frequencies, ensuring very high speed of transmission, low level signal attenuation and very high level of protection from interference. The operation of the optical fi bre is based on light refraction within the fi bre.

RBS: Base stations for mobile telephony used for transmission and reception.

RoHS: A standard which sets the limit to the quantity of metals and substances, in general, used for the manufacture of electronic devices in order to reduce their impact on the environment.

Specifi c Absorption Rate (SAR): SAR (Specifi c Absorption Rate) is a measure of the rate at which energy is absorbed by the human body when this is exposed to electromagnetic fi elds (e.g. mobile phone fi eld) and is measured in Watts per kilogram. SAR is measured in a specifi c manner and there are acceptable safety limits.

Sustainable Development: Refers to economic growth which is planned and implemented taking into account environmental protection and sustainability for future generations.

UMTS/HSPA+: A modern technology standard for fast wireless data transmission chiefl y used in mobile telephony.

125

12. About the Report

At WIND Hellas we operate in the framework of Responsible Entrepreneurship and we communicate openly the results of our operations to our stakeholders. In this context we understand the legitimate interest of our stakeholders with respect to our performance regarding the Economy, Society and the Environment and we strive to satisfy their interest by providing comprehensive and correct information.

We always try to provide information about our operations taking into account stakeholders’ comments that we have received. We welcome the increased interest shown by a greater part of the public on our economic, social and environmental impact, which we noted from the evaluation of our Report by its readers and from the visitors to our website. Thus, with this edition, we strive in practice to improve our channels of communication with our stakeholders.

The present Sustainability Report of WIND Hellas constitutes the fi � h annual edition of such a Report and the fourth based on the Global Reporting Initiative standard. This Report covers our Company’s activity for the year starting 1 January and ending 31 December 2011, in Greece. The seat and central offi ces of WIND Hellas are located in Athens, at 66 Kifi ssias Ave., Maroussi, whilst we also have offi ces in Thessaloniki, Patras, Larissa and Heraklion.

This year, we are issuing our Report earlier, in our eff ort to notify our internal and external stakeholders in a timelier manner.

It includes our impact on the Economy, Environment and Society as regards our Company’s important issues, as well as the degree to which these aff ect our stakeholders, according to the materiality analysis that we have performed.

Moreover, in order to determine and develop the content of the present Report, as was also the case in previous years, we took into account the Company’s type of activity, the Principles of Sustainable Development, as set out in the Global Compact Standard and the G3.1 edition of the Global Reporting Initiative guidelines, which constitute the framework for controlling our environmental, economic and social impact.

We have chosen not to use the pilot version of the Telecommunications Sector Supplement as it was developed in accordance with the 2002 guidelines, an older version of the G3.1 guidelines which we use and already covers the topics that are material for us.

2011 Report

126

The Company’s Corporate Responsibility Committee is responsible for collecting data and for the reliability and clarity of the information. This Committee comprises representatives of the Company’s main departments and is competent for compiling the Report through collective interdepartmental work.

The collection of data for the specifi c Report was carried out as follows:

Indicators & Data Collection

Performance data on our environmental operations were drawn from internal recording, control and verifi cation procedures, based also on the ISO 14001 international standard which was used for our Company’s certifi cation, whilst wherever an estimate is included it is mentioned accordingly;

Data on our social impact were based on offi cial records, surveys and data on quality, health & safety, human resources;

Our fi nancial data were taken from the fi nancial department and are in accordance with our annual fi nancial results.

In this framework, the present edition develops the following axes:

Our Corporate Responsibility Strategy, “In Action”, through our approach to our stakeholders;

Our Corporate Responsibility based on the pillars of corporate governance, market, employees, environment and society, which are refl ected in the present document according to how these were prioritised in the context of the materiality analysis.

This year we have tried to record the eff ect of our operations on more issues, simultaneously developing indicators according to the standard, and to ensure

that an independent body externally assures the GRI B+ Report Application level of compliance.

However, we are aware of the restrictions that existed when dra� ing the present report, such as the lack of measurable targets for each program or action or the comprehensiveness of our Report’s content being verifi ed by an independent body, and we will try to overcome them in the future.

GRI Index is on page 130 of the present Report and the Independent Assurance Report according to GRI requirements is on page 142.

127

Selected Company performance data on Corporate Responsibility issues are also confi rmed by the actions carried out each year by Internal Audit which verifi es that the data cited in the Sustainability Report is correct.

Verifi cation of Report Data

Application Level Table

Report on:1.12.1 - 2.103.1 - 3.8, 3.10 - 3.124.1 - 4.4, 4.14 - 4.15

Report on all criteria listedfor Level C plus:1.23.9 , 3.134.5 - 4.13, 4.16 - 4.17

Same as requirementfor Level B

Not Required Management ApproachDisclosures for eachIndicator Category

Management ApproachDisclosures for eachIndicator Category

Report on a minimum of10 Performance Indicators,including at least one fromeach of: Economic, Social and Environmental.

Report on a minimum of20 Performance Indicators,at least one from each of Economic, Environmental, Human rights,Labor, Society,Product Reponsibility.

Report on each core G3 and Sector Supplement Indicator with due regard to the Materiality Principle by either:a) reporting on theIndicator or b) explainingthe reason for its omission.

Report Externally Assured & GRI Checked

Stan

dard

Dis

clos

ures

Report Application Level C C+ B B+ A A+

G3 ProfileDisclosures

G3 ManagementApproachDisclosures

G3 PerformanceIndicators &Sector SupplementPerformanceIndicators

OU

TPU

TO

UTP

UT

OU

TPU

T

128

13. UN Global Compact: Communication on Progress

WIND Hellas supports the 10 principles of the United Nations Global Compact regarding human rights, labour practices, protection of the environment and corruption fi ght.

With intent to actively support and develop these principles in our sphere of infl uence, we are committed

to implement the Global Compact and its principles in our strategy, culture and everyday functioning, and also to clearly communicate this commitment to our employees, partners, customers and the general public. Focusing on monitoring and transparency, we report our progress in the various axes to all our stakeholders.

Principle Reference (paragraph in the Report)

Human Rights

Principle 1 Businesses should support and respect the protection of internationally proclaimed human rights 4, 4.1, 4.2, 4.3.5, 6.3, 6.6, 6.7, 7, 7.2, 7.5, 8.4.2.1, 8.5

Principle 2 Businesses should make sure that they are not complicit in human rights abuses 6.9, 7.2, 7.4, 7.6

Labour Practices

Principle 3 Businesses should uphold the freedom of association and the eff ective recognition of the right to collective bargaining

6.9, 7.3

Principle 4 Businesses should uphold the elimination of all forms of forced and compulsory labour 6.9, 7.1, 7.2

Principle 5 Businesses should uphold the eff ective abolition of child labour 6.9, 7.2

Principle 6 Businesses should uphold the elimination of discrimination in respect of employment and occupation

6.9, 7.2, 7.6

Environment

Principle 7 Businesses should support a precautionary approach to environmental challenges 1, 4.3, 5.6, 5.1, 8.1, 8.2

Principle 8 Businesses should undertake initiatives to promote greater environmental responsibility 6.3, 6.4, 6.9, 7.7, 7.8, 8.3, 9.4

Principle 9 Businesses should encourage the development and diff usion of environmentally friendly technologies

6.1, 6.4, 8.4.1, 8.4.2.1, 8.6

Anti-Corruption

Principle 10 Businesses should work against corruption in all its forms, including extortion and bribery 5.2, 5.5, 5.6, 6.9, 7.7

Report on:1.12.1 - 2.103.1 - 3.8, 3.10 - 3.124.1 - 4.4, 4.14 - 4.15 Report on all criteria listedfor Level C plus:1.23.9 , 3.134.5 - 4.13, 4.16 - 4.17 Same as requirement forLevel BNot Required Management ApproachDisclosures for eachIndicator Category Management ApproachDisclosures for eachIndicator CategoryReport on a minimum of10 Performance Indicators,including at least one fromeach of: Economic, Social and Environmental. Report on a minimum of20 Performance Indicators,at least one fromeach of Economic, Environmental, Human rights, Labor, Society, Product Reponsibility. Report on each core G3 andSector Supplement Indicatorwith due regard to theMateriality Principle byeither: a) reporting on theIndicator or b) explainingthe reason for its omission.Report Externally Assured

Report Externally Assured

Report Externally Assured

Standard Disclosures

Report Application Level C C+ B B+ A A+G3 ProfileDisclosuresG3 ManagementApproachDisclosuresG3 PerformanceIndicators &Sector SupplementPerformanceIndicators

OUTPUTOUTPUT

OUTPUT

Index of Global Compact Principles

129

14. GRI Index & AssessmentsProfi le

Disclosure Description Reported Cross-reference / Direct answer

PROFILE DISCLOSURES

1. Strategy and Analysis

1.1 Statement from the most senior decision-maker of the organization. n 1. Message from the Chairman & CEO (p. 3)

1.2 Description of key impacts, risks, and opportunities. n

1. Message from the Chairman & CEO (p. 3) / 2. What we have accomplished in 2011 (p. 5) / 3. WIND Hellas 19 years of communication (p. 7) / 4. Responsibility in Action for All (p. 15-17) / 4.3. We approach important issues responsibly (p. 22-23) / 4.4. We Promote Responsible Entrepreneurship (p. 24-25) / 5.6. Management Systems and Certifi cations (p. 34-36) / 5.6.2. Business Continuity Management (p. 36) / 8.2. Environmental Management (p. 86-87) / 10. Objectives and Results 2011 (p. 122)

2. Organizational Profi le2.1 Name of the organization. n 3. WIND Hellas 19 years of communication (p. 7)

2.2 Primary brands, products, and/or services. n 6.2. Products & Services for All (p. 43-45) / 6.4. Responsible Services (p. 47) / 6.5. Social Product (p. 48-49)

2.3Operational structure of the organization, including main divisions, operating companies, subsidiaries, and joint ventures.

n 3.3. Financial Growth & Data(p.9-10) / 5.2. Management Practice (p.29-31)

2.4 Location of organization's headquarters. n 12. About the Report (p. 126-128)

2.5Number of countries where the organization operates, and names of countries with either major operations or that are specifi cally relevant to the sustainability issues covered in the report.

n 3. WIND Hellas 19 years of communication (p. 7) / 12. About the Report (p. 126)

2.6 Nature of ownership and legal form. n 3.3. Financial Growth & Data (p. 9-10)

2.7Markets served (including geographic breakdown, sectors served, and types of customers/benefi ciaries).

n 3. WIND Hellas 19 years of communication (p. 7)

2.8 Scale of the reporting organization. n3.3. Financial Growth & Data (p. 9-10) / 6.5. Products & Services for All (p. 43-45) / 6.9.1. Local suppliers (p. 63) / 7.1. Human Resources Data (p. 68)

2.9 Signifi cant changes during the reporting period regarding size, structure, or ownership. n 1. Message from the Chairman & CEO (p. 3) / 3.3. Financial Growth &

Data (p. 9-10) / 5.2. Management Practice (p. 29-31)

2.10 Awards received in the reporting period. n 3.4. Recognition (p. 11-12)

3. Report Parameters

3.1 Reporting period (e.g., fi scal/calendar year) for information provided. n 12. About the Report (p. 126-128)

130

3.2 Date of most recent previous report (if any). n 12. About the Report (p. 126-128)

3.3 Reporting cycle (annual, biennial, etc.) n 12. About the Report (p. 126-128)

3.4 Contact point for questions regarding the report or its contents. n P. 144

3.5 Process for defi ning report content. n 12. About the Report (p. 126-128) / 4.2.1. Dialogue with Stakeholders (p. 19-21) / 4.3. We approach important issues responsibly (p. 22-23)

3.6 Boundary of the report (e.g., countries, divisions, subsidiaries, leased facilities, joint ventures, suppliers). n 12. About the Report (p. 126-128)

3.7 State any specifi c limitations on the scope or boundary of the report. n 12. About the Report (p. 126-128)

3.8Basis for reporting on joint ventures, subsidiaries, leased facilities, outsourced operations, and other entities that can signifi cantly aff ect comparability from period to period and/or between organizations.

n There are no joint ventures or other entities that aff ect comparability

3.9Data measurement techniques and the basis of calculations, including assumptions and techniques underlying estimations applied to the compilation of the Indicators and other information in the report.

n 12. About the Report (p. 126-128) / 8. Environment (p. 85-105)

3.10Explanation of the eff ect of any re-statements of information provided in earlier reports, and the reasons for such re-statement.

n 3.3. Financial Growth & Data (p. 9-10)

3.11Signifi cant changes from previous reporting periods in the scope, boundary, or measurement methods applied in the report.

n 12. About the Report (p. 126-128)

3.12 Table identifying the location of the Standard Disclosures in the report. n 14. GRI Index & Assesment (p. 130)

3.13 Policy and current practice with regard to seeking external assurance for the report. n 12. About the Report (p. 126-128) / 14. GRI Index & Assessment (p.

142)

4. Governance, Commitments, and Engagement

4.1Governance structure of the organization, including committees under the highest governance body responsible for specifi c tasks, such as setting strategy or organizational oversight.

n 4.1. Our approach to Responsibility (p. 15-17) / 5.2. Management Practice (p. 29-31)

4.2 Indicate whether the Chair of the highest governance body is also an executive offi cer. n 5.2. Management Practice (p. 29-31)

4.3For organizations that have a unitary board structure, state the number and gender of members of the highest governance body that are independent and/or non-executive members.

n 5.2. Management Practice (p. 29-31)

Profi le Disclosure Description Reported Cross-reference / Direct answer

n Fully Reported n Core Indicator

131

4.4Mechanisms for shareholders and employees to provide recommendations or direction to the highest governance body.

n 4.2.1 Dialogue with Stakeholders (p. 19-21) / 5.4. Communication with Management (p. 32)

4.5

Linkage between compensation for members of the highest governance body, senior managers, and executives (including departure arrangements), and the organization's performance (including social and environmental performance).

n 5.2. Management Practice (p. 29-31) / 7.6.2. Professional Development (p. 76-77)

4.6 Processes in place for the highest governance body to ensure confl icts of interest are avoided. n 5.2. Management Practice (p. 29-31) / 5.3. Internal Audit (p. 32) / 5.5.

Confl icts of Interest - Tackling Corruption (p. 33)

4.7

Processes for determining the composition, qualifi cations, and expertise of the members of the highest governance body and its committees, including any consideration of gender and other indicators of diversity.

n 5.2. Management Practice (p. 29-31)

4.8Internally developed statements of mission or values, codes of conduct, and principles relevant to economic, environmental, and social performance and the status of their implementation.

n

5.1. Our Principles (p. 28) / 5.5. Confl icts of Interest - Tackling Corruption (p. 33) / 6.6. Responsible Marketing (p. 50) / 6.6.1. Codes of Conduct (p. 51) / 6.6.2. Ethical competition (p. 51) / 6.6.3. Intellectual Property Rights & Communication Security and Privacy (p. 52) 6.6.4. Communication principles (p. 53)

4.9

Procedures of the highest governance body for overseeing the organization's identifi cation and management of economic, environmental, and social performance, including relevant risks and opportunities, and adherence or compliance with internationally agreed standards, codes of conduct, and principles.

n 5.2. Management Practice (p. 29-31) / 5.6. Management Systems and Certifi cations (p. 34-36)

4.10Processes for evaluating the highest governance body's own performance, particularly with respect to economic, environmental, and social performance.

n 5.3. Internal Audit (p. 32)

4.11 Explanation of whether and how the precautionary approach or principle is addressed by the organization. n 5.6. Management Systems and Certifi cations (p. 34-36)

4.12Externally developed economic, environmental, and social charters, principles, or other initiatives to which the organization subscribes or endorses.

n

3.5. Participation (p. 13) / 4.4. We promote Responsible Entrepreneurship (p. 24-25) / 6.3. Responsible Products (p. 46) / 6.6.1. Codes of Conduct (p. 51) / 8.3.3. Equipment re-use (p. 94) / 8.5. Biodiversity (p. 102) / 2011 European Year of Volunteerism (p.119) / 13. UN Global Compact (p. 129)

4.13

Memberships in associations (such as industry associations) and/or national/international advocacy organizations in which the organization: * Has positions in governance bodies; Participates in projects or committees; Provides substantive funding beyond routine membership dues; or Views membership as strategic.

n 3.5. Participation (p. 13)

4.14 List of stakeholder groups engaged by the organization. n 4.2. Our Stakeholders (p. 18)

4.15 Basis for identifi cation and selection of stakeholders with whom to engage. n 4.2. Our Stakeholders (p. 18) / 4.2.1 Dialogue with Stakeholders (p.

19-21)

Profi le Disclosure Description Reported Cross-reference / Direct answer

132

4.16Approaches to stakeholder engagement, including frequency of engagement by type and by stakeholder group.

n

4.2.1. Dialogue with Stakeholders (p. 19-21) / 4.4. We Promote Responsible Entrepreneurship (p. 24-25) / 5.4. Communication with Management (p. 32) / Social Product (p. 48-49) / 6.8.1. Measurement & Evaluation (p. 56-58) / 6.9. Responsible Suppliers (p. 62-63) / 7.7.Internal Communication (p. 78-79)

4.17Key topics and concerns that have been raised through stakeholder engagement, and how the organization has responded to those key topics and concerns, including through its reporting.

n

4.2.1. Dialogue with Stakeholders (p. 19-21) / 4.3. We approach important issues responsibly (p. 22-23) / 6.5. Social Product (p. 48-49) / 6.7. Informing the Public (p. 54-55) / 6.8.2. Responding to our customer's needs (p.59-61) / 8. Environment ( p. 85-105)

Disclosures on Management Approach

Aspects

ECONOMY

Economic performance n

1. Message from the Chairman & CEO (p. 3) / 2. What we have accomplished in 2011 (p. 5) / 3. WIND Hellas 19 years of communication (p.7-10) / 10. Objectives and Results 2011 (p. 122-123) / 3.3. Financial Growth & Data (p. 9-10)

Market presence n

3.1. The Telecommunications Network (p. 8) / 3.2. Retail Network (p. 9) / 6. Market (p. 39) / 6.1. Our Telecommunications Network (p. 40-42) / 6.2. Products & Services for All (p. 43-45) / 6.3. Responsible Products (p. 46) / 6.4. Responsible Srevices (p. 47) / 6.9. Responsible Suppliers (p. 62-63) / 6.9.1. Local suppliers (p. 63)

Indirect economic impacts n 6.5. Social Product (p. 48-49) / 6.9.1. Local suppliers (p. 63) / 7.4. Additional Benefi ts (p . 71) / 8.2. Environmental Management (p. 86-87)

Aspects

ENVIRONMENT

Materials n 8.3.1. Materials used (p. 88-91) / 8.3.3. Equipment re-use (p. 94) / 7.8. Internal Volunteerism (p. 81-82)

Energy n 8.4.1. Energy consumption, electricity and fuel (p. 95-99)

Water n 8.6. Water (p. 104)

Biodiversity u 8.5. Biodiversity (p. 102-104)

Emissions, effl uents and waste n8.3.2. Waste produced (p. 92-93) / 8.3.3. Equipment re-use (p. 94) / 8.3.4. Collective Recycling Systems (p. 94) / 8.4.2. Greenhouse Gases Emissions (p. 99-101)

Products and services n 6.3. Responsible Products (p. 46) / 6.4. Responsible Services (p. 47)

Compliance n 8.2. Environemental Management (p. 86-87)

Transport u 7.8. Internal Volunteerism (p. 82) / 8.2. Environmental Management (p. 86-87) / 8.4.1. Energy consumption, electricity and fuel (p. 95-99)

Overall n

2. What we have accomplished in 2011 (p. 5) / 4. Responsibility in Action for All (p. 15-17) / 5.6. Management Systems and Certifi cations(p. 34-36) / 8. Environment (p. 85) / 8.1. Environmental Policy (p. 86) / 8.2. Environmental Management (p. 86-87) / 10. Objectives and Results 2011 (p. 122-123) / 8.3.1. Materials used (p.88-91) / 8.4.1. Energy consumption, electricity and fuel (p. 95-99) / 8.4.2.1. Pollutants emissions / ozone depleting emissions (p. 100-101) / 8.5.2. Impact on Biodiversity - Environmental Impact Assessment (p. 103-104)

n Fully Reported u Partially Reported l Not Reported n Core Indicator

Profi le Disclosure Description Reported Cross-reference / Direct answer

133

Aspects

LABOUR PRACTICE

Employment n4. Responsibility in Action for All (p. 15-17) / 7. Employees (p. 67) / 10. Objectives & Results 2011 (p. 122-123) / 7.1. Human Resources Data (p. 68) / 7.2. Human Rights & Equal Opportunities (p. 69-70)

Labor/management relations n5.4. Communication with Management (p. 32) / 7.3. Freedom of Association (p. 70) / 7.4. Additional Benefi ts (p. 71) / 7.7. Internal Communication (p. 78-79) / 7.8. Internal Volunteerism (p. 80-82)

Occupational health and safety n 7.3. Freedom of Association (p. 70) / 7.4. Additional Benefi ts (p. 71) / 7.5. Employee Health & Safety (p. 72-74)

Training and education n 7.6. Employees Growth & Development (p. 75-77)

Diversity and equal opportunity n 7.2. Human Rights & Equal Opportunities (p. 69-70) / 7.6. Employees Growth & Development (p. 75-77)

Equal remuneration for women and men l

Aspects

HUMAN RIGHTS

Investment and procurement practices n 5.2. Management Practice (p. 29-31) / 6.9. Responsible Suppliers (p. 62-63)

Non-discrimination n6.9. Responsible Suppliers (p. 62-63) / 7. Employees (p. 67-82) / 7.2. Human Rights & Equal Opportunities (p. 69) / 7.6.2. Professional Development (p. 76-77)

Freedom of association and collective bargaining n 7.3. Freedom of Association (p. 70)

Child labor n 7.2. Human Rights & Equal Opportunities (p. 69-70)

Prevention of forced and compulsory labor n 7.2. Human Rights & Equal Opportunities (p. 69-70)

Security practices n 7.5. Employee Health & Safety (p. 72-74)

Indigenous rights l

Assessment l

Remediation l

Aspects

SOCIETY

Local communities n

1. Message from the Chairman & CEO (p. 3) / 2. What we have accomplished in 2011 (p. 5) / 3.5. Participation (p. 13) / 4.4. Responsibility in Action for All (p. 15-17) / 4.3. We approach important issues responsibly (p. 22-23) / 6.5. Social Product (p. 48-49) / 9. Society (p. 107-121) / 10. Objectives and results 2011 (p. 122-123)

Corruption n5. Corporate Governance (p. 27) / 5.2. Management Practice (p. 29-31) / 5.3. Internal Audit (p. 32) / 5.5. Confl icts of Interest - Tackling Corruption (p.33) / 5.6.2. Business Continuity Management (p. 36)

Public policy l

Anti-competitive behavior n 6.6. Responsible Marketing (p. 50-51) / 6.6.2. Ethical competition (p. 51)

Compliance n There have been no fi nes or sanctions during 2011

Profi le Disclosure Description Reported Cross-reference / Direct answer

134

Aspects

PRODUCT RESPONSIBILITY

Customer health and safety u

4.3. We approach important issues responsibly (p. 22-23) / 5.6. Management Systems and Certifi cations (p. 34-36) / 6.1.3. E/M radiation & measurements (p.42) / 6.3. Responsible Products (p. 46) / 6.7.3. Electromagnetic Radiation (p. 55) / 10. Objectives and Results 2011 (p. 122-123)

Product and service labelling n 6.2. Products & Services for All (p. 43-45) / 6.4. Responsible Products (p. 46)

Marketing communications n 6.6. Responsible Marketing (p. 50-53)

Customer privacy u 6.6.1. Codes of Conduct (p. 51) / 6.6.3. Intellectual Property Rights and Communication Security and Privacy (52)

Compliance n 6.6. Responsible Marketing (p. 50-52) / 6.6.4. Communication principles (p. 53)

Performance IndicatorsEconomic

EC1

Direct economic value generated and distributed, including revenues, operating costs, employee compensation, donations and other community investments, retained earnings, and payments to capital providers and governments.

n 3. WIND Hellas 19 years of communication (p. 7) / 3.3. Financial Growth & Data (p. 9-10)

EC2Financial implications and other risks and opportunities for the organization's activities due to climate change.

u 8.2. Environemental Management (p. 86-87)

EC3 Coverage of the organization's defi ned benefi t plan obligations. l

EC4 Signifi cant fi nancial assistance received from government. l

EC5Range of ratios of standard entry level wage by gender compared to local minimum wage at signifi cant locations of operation.

l

EC6 Policy, practices, and proportion of spending on locally-based suppliers at signifi cant locations of operation. n 6.9.1. Local suppliers (p. 63)

EC7Procedures for local hiring and proportion of senior management hired from the local community at signifi cant locations of operation.

u 7.2. Human Rights & Equal Opportunities (p. 69-70)

EC8Development and impact of infrastructure investments and services provided primarily for public benefi t through commercial, in-kind, or pro bono engagement.

n3. WIND Hellas 19 years of communication (p. 7-8) / 3.3. Financial Growth & Data (p. 9-10) / 6.1. Our Telecommunications Network (p. 40-41)

EC9 Understanding and describing signifi cant indirect economic impacts, including the extent of impacts. n

6.9. Social Product (p. 48-49) / 6.9.1. Local suppliers (p. 63) / 7.1. Human Resources Data (p. 68) / 7.2. Human Rights & Equal Opportunities (p. 69-70)

n Fully Reported u Partially Reported l Not Reported n Core Indicator n Additional Indicator

Profi le Disclosure Description Reported Cross-reference / Direct answer

135

Environmental

EN1 Materials used by weight or volume. u 8.3.1. Materials used (p. 88-91)

ΕΝ2 Percentage of materials used that are recycled input materials. u 8.3.3. Equipment re-use (p. 94)

EN3 Direct energy consumption by primary energy source. n 8.4.1. Energy consumption, electricity and fuel (p. 95-99)

ΕΝ4 Indirect energy consumption by primary source. n 8.4.1. Energy consumption, electricity and fuel (p. 95-99)

EN5 Energy saved due to conservation and effi ciency improvements. n 8.4.1. Energy consumption, electricity and fuel (p. 95-99)

EN6Initiatives to provide energy-effi cient or renewable energy based products and services, and reductions in energy requirements as a result of these initiatives.

n 8.4.1. Energy consumption, electricity and fuel (p. 95-99)

ΕΝ7 Initiatives to reduce indirect energy consumption and reductions achieved. n 8.4.1. Energy consumption, electricity and fuel (p. 95-99)

EN8 Total water withdrawal by source. u 8.6. Water (p. 104)

ΕΝ9 Water sources signifi cantly aff ected by withdrawal of water. n No water sources are signifi cantly aff ected since the only water used is

for servicing offi ces and watering gardens.

ΕΝ10 Percentage and total volume of water recycled and reused. n Water is used only for servicing offi ce employees. No water is recycled

or re-used.

ΕΝ11Location and size of land owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas.

u8.5.1. Presence in Protected Area (p. 102-103)/ Actual site size not available, information on sites adjacent to protected areas not available. Natura area data provided for year 2007.

ΕΝ12Description of signifi cant impacts of activities, products, and services on biodiversity in protected areas and areas of high biodiversity value outside protected areas.

n

8.5.2. Impact on Biodiversity - Environmental impact assessment (p. 103-104) / Environmental Impact Assessments composed for every site inside or outside of proteceted areas describe per site all impacts identifi ed. In summary, there are no signifi cant impacts for biodiversity.

EN13 Habitats protected or restored. n None. Biodiversity impact not signifi cant.

EN14 Strategies, current actions, and future plans for managing impacts on biodiversity. n

There are no signifi cant impacts to biodiversity. Despite that fact, all Radio Base Stations located at sensitive areas are examined for environmental impacts.

ΕΝ15Number of IUCN Red List species and national conservation list species with habitats in areas aff ected by operations, by level of extinction risk.

n

8.5.2. Impact on Biodiversity - Environmental impact assessment (p. 103-104) / No such area signifi cantly aff ected by Wind Hellas operation. No evidence that the presence of Radio Base Stations at ecologically sensitive areas is aff ecting any protected species at operation phase.

EN16 Total direct and indirect greenhouse gas emissions by weight. n 8.4.2. Greenhouse Gases emissions (p. 99-101)

ΕΝ17 Other relevant indirect greenhouse gas emissions by weight. n 8.4.2. Greenhouse Gases emissions (p. 99-101)

EN18 Initiatives to reduce greenhouse gas emissions and reductions achieved. n 8.4.2. Greenhouse Gases emissions (p. 99-101) / 8.4.2.1. Pollutants

emissions / ozone depleting emissions (p. 100-101)

EN19 Emissions of ozone-depleting substances by weight. n 8.4.2.1 Pollutants emissions / ozone depleting emissions( p. 100-101)

Profi le Disclosure Description Reported Cross-reference / Direct answer

136

ΕΝ20 NOx, SOx, and other signifi cant air emissions by type and weight. u

8.4.2. Greenhouse gases emissions (p. 99-101) / Vehicle related emissions are calculated as CO2e and included in relevant category. No other such emissions are relevant for WIND Hellas operations

ΕΝ21 Total water discharge by quality and destination. n 8.6. Water (p. 104)

EN22 Total weight of waste by type and disposal method. n 8.3.2. Waste produced (p. 92-94) / 8.3.3. Equipment re-use (p. 94) / 8.3.4. Collective Recycling Systems (p. 8.3.4.)

ΕΝ23 Total number and volume of signifi cant spills. n There have been no signifi cant spils in 2011

ΕΝ24

Weight of transported, imported, exported, or treated waste deemed hazardous under the terms of the Basel Convention Annex I, II, III, and VIII, and percentage of transported waste shipped internationally.

n

8.3.2. Waste produced (p. 92-94) / Not relevant. WIND Hellas does not transport, import or export hazardous waste itself. What hazardous waste have been transported on behalf of WIND Hellas are reported at code EN22

ΕΝ25Identity, size, protected status, and biodiversity value of water bodies and related habitats signifi cantly aff ected by the reporting organization's discharges of water and runoff .

n

8.6. Water (p. 104) / Not relevant, Wind Hellas does not have a signifi cant impact on any water bodies through discharges, runoff , or other.

EN26Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation.

n

8.2. Environemental Management (p. 86-87) / 8.3.1. Materials used (p. 88-91) / 8.3.3. Equipment re-use (p. 94) / 8.3.4. Collective Recycling Systems (p. 94) / 8.4. Energy, Aerial Emissions and Climate Change (p. 95-101) / 8.5.2. Impact on Biodiversity - Environmental impact assessment (p. 103-104) / 8.6. Water (p. 104)

EN27 Percentage of products sold and their packaging materials that are reclaimed by category. n

8.3.4. Collective Recycling Systems (p. 8.3.4.) / Being part of the collective recycling system for packaging products and packaging, we are not responsible for reclaiming neither products nor packaging. Data from the collective recycling system does not identify origin of items, thus it is impossible to know the percentage of packaging and items actually reclaimed. WIND Hellas acts as a collection point for mobile handsets and accessories for the public, but the items collected do not originate from WIND Hellas alone, but from all retailers of such equipment.

ΕΝ28Monetary value of signifi cant fi nes and total number of non-monetary sanctions for non-compliance with environmental laws and regulations.

n There have been no signifi cant fi nes and sanctions relating to environmental laws and regulations for year 2011.

ΕΝ29Signifi cant environmental impacts of transporting products and other goods and materials used for the organization's operations, and transporting members of the workforce.

u 8.2. Environmental Management (p. 86-87)

ΕΝ30 Total environmental protection expenditures and investments by type. u 8.2. Environmental Management (p. 86-87)

Social: Labor Practices and Decent Work

LA1 Total workforce by employment type, employment contract, and region, broken down by gender. n 7.1. Human Resources Data (p. 68) / 7.2. Human Rights & Equal

Opportunites (p. 69-70)

LA2 Total number and rate of new employee hires and employee turnover by age group, gender, and region. l

n Fully Reported u Partially Reported l Not Reported n Core Indicator n Additional Indicator

Profi le Disclosure Description Reported Cross-reference / Direct answer

137

LA3Benefi ts provided to full-time employees that are not provided to temporary or part-time employees, by major operations.

n 7.3. Freedom of Association (p. 70) / 7.4. Additional Benefi ts (p. 71)

LA4 Percentage of employees covered by collective bargaining agreements. l

LA5Minimum notice period(s) regarding signifi cant operational changes, including whether it is specifi ed in collective agreements.

l

LA6Percentage of total workforce represented in formal joint management-worker health and safety committees that help monitor and advise on occupational health and safety programs.

l

LA7Rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities by region and by gender.

n 7.5.1. Indices of injuries, professional sicknesses, loss of working days and absences (p.72)

LA8Education, training, counseling, prevention, and risk-control programs in place to assist workforce members, their families, or community members regarding serious diseases.

n 7.5. Employee Health & Safety (p. 72) / 7.5.2. Information on Health Matters (p. 73) / 7.5.3. Training on safety and health at work (p. 74)

LA9 Health and safety topics covered in formal agreements with trade unions. n 7.3. Freedom of Association (p. 70)

LA10 Average hours of training per year per employee by gender, and by employee category. u 7.6.1. Training (p. 75-76)

LA11Programs for skills management and lifelong learning that support the continued employability of employees and assist them in managing career endings.

u 7.6.2. Professional Development (p. 76-77)

LA12Percentage of employees receiving regular performance and career development reviews, by gender.

l

LA13Composition of governance bodies and breakdown of employees per employee category according to gender, age group, minority group membership, and other indicators of diversity.

u 7.1. Human Resources Data (p. 68) / 7.2. Human Rights & Equal Opportunites (p. 69-70)

LA14Ratio of basic salary and remuneration of women to men by employee category, by signifi cant locations of operation.

l

LA15 Return to work and retention rates a� er parental leave, by gender. l

Social: Human Rights

HR1Percentage and total number of signifi cant investment agreements and contracts that include clauses incorporating human rights concerns, or that have undergone human rights screening.

l

HR2Percentage of signifi cant suppliers, contractors and other business partners that have undergone human rights screening, and actions taken.

n 6.9. Responsible Suppliers (p. 62-63)

Profi le Disclosure Description Reported Cross-reference / Direct answer

138

HR3Total hours of employee training on policies and procedures concerning aspects of human rights that are relevant to operations, including the percentage of employees trained.

l

HR4 Total number of incidents of discrimination and actions taken. n 6.9. Responsible Suppliers (p. 62-63) / 7.2. Human Rights & Equal

Opportunities (p. 69-70)

HR5Operations and signifi cant suppliers identifi ed in which the right to exercise freedom of association and collective bargaining may be violated or at signifi cant risk, and actions taken to support these rights.

n 6.9. Responsible Suppliers (p. 62-63) / 7.3. Freedom of Association (p. 69-70)

HR6Operations and signifi cant suppliers identifi ed as having signifi cant risk for incidents of child labor, and measures taken to contribute to the eff ective abolition of child labor.

n 6.9. Responsible Suppliers (p. 62-63) / 7.2. Human Rights & Equal Opportunities (p. 69-70)

HR7Operations and signifi cant suppliers identifi ed as having signifi cant risk for incidents of forced or compulsory labor, and measures to contribute to the elimination of all forms of forced or compulsory labor.

n 7.2. Human Rights & Equal Opportunities (p. 69-70)

HR8Percentage of security personnel trained in the organization's policies or procedures concerning aspects of human rights that are relevant to operations.

l

HR9 Total number of incidents of violations involving rights of indigenous people and actions taken. l

HR10Percentage and total number of operations that have been subject to human rights reviews and/or impact assessments.

l

HR11 Number of grievances related to human rights fi led, addressed and resolved. l

Social: Society

SO1Percentage of operations with implemented local community engagement, impact assessments, and development programs.

n3.5. Participation (p. 13) / 4.3. We approach important issues responsibly (p. 22-23) / 6.5. Social Product (p. 48-49) / 9. Society( p. 107-121)

SO2 Percentage and total number of business units analyzed for risks related to corruption. l

SO3 Percentage of employees trained in organization's anti-corruption policies and procedures. l

SO4 Actions taken in response to incidents of corruption. n 5.5. Confl icts of Interest - Tackling Corruption (p. 33) / 5.6.2. Business Continuity Management (p. 36)

SO5 Public policy positions and participation in public policy development and lobbying. l

SO6Total value of fi nancial and in-kind contributions to political parties, politicians, and related institutions by country.

l

Profi le Disclosure Description Reported Cross-reference / Direct answer

n Fully Reported u Partially Reported l Not Reported n Core Indicator n Additional Indicator

139

SO7Total number of legal actions for anti-competitive behavior, anti-trust, and monopoly practices and their outcomes.

n 6.6.2. Ethical competition (p. 51)

SO8Monetary value of signifi cant fi nes and total number of non-monetary sanctions for non-compliance with laws and regulations.

n There have been no fi nes or sanctions during 2011

SO9 Operations with signifi cant potential or actual negative impacts on local communities. l

SO10Prevention and mitigation measures implemented in operations with signifi cant potential or actual negative impacts on local communities.

l

Social: Product Responsibility

PR1Life cycle stages in which health and safety impacts of products and services are assessed for improvement, and percentage of signifi cant products and services categories subject to such procedures.

u5.6. Management Systems and Certifi cations (p. 34-36) / 6.1.3. E/M radiation & measurements (p. 42) / 6.3.2. Health (p. 46) / 6.7.3. Electromagnetic Radiation (p. 55)

PR2Total number of incidents of non-compliance with regulations and voluntary codes concerning health and safety impacts of products and services during their life cycle, by type of outcomes.

l

PR3Type of product and service information required by procedures, and percentage of signifi cant products and services subject to such information requirements.

n 6.2. Products & Services for All (p. 43-45) / 6.3. Responsible Products (p. 46) / 6.4. Responsible Services (p. 47)

PR4Total number of incidents of non-compliance with regulations and voluntary codes concerning product and service information and labeling, by type of outcomes.

l

PR5 Practices related to customer satisfaction, including results of surveys measuring customer satisfaction. n 6.8. Customer Satisfaction (p. 56-61)

PR6Programs for adherence to laws, standards, and voluntary codes related to marketing communications, including advertising, promotion, and sponsorship.

n 6.6. Responsible Marketing (p. 50-53) / 6.7. Informing the public (p. 54-55)

PR7Total number of incidents of non-compliance with regulations and voluntary codes concerning marketing communications, including advertising, promotion, and sponsorship by type of outcomes.

n 6.6.4. Communication principles (p. 53)

PR8Total number of substantiated complaints regarding breaches of customer privacy and losses of customer data.

u 6.6.3. Intellectual Property Rights & Communication Security and Privacy (p. 52)

PR9Monetary value of signifi cant fi nes for non-compliance with laws and regulations concerning the provision and use of products and services.

l

Profi le Disclosure Description Reported Cross-reference / Direct answer

n Fully Reported u Partially Reported l Not Reported n Core Indicator n Additional Indicator

140

141

142

143

Thank you for reading our Report.If you wish to receive additional information please contact:

WIND Hellas Corporate Aff airs Department 66 Kifi ssias Ave., 151 25 MaroussiTel.: 210- 6158574, Fax: 210-6105022 e-mail: [email protected]

Please send your comments to: [email protected] or fi ll out the form that you will fi nd on www.wind.com.gr

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WIND Hellas Telecommunications S.A.66 Kifissias Ave.,151 25 Maroussiwww.wind.com.gre-mail: [email protected]