Albania Mobile Communications SA (AMC)

Corporate Responsibility Report 2014

AMC Corporate Responsibility Report 2014

Table of Contents 1 About this report...... 1 2 About AMC ...... 1 2.1 AMC Shareholders Structure ...... 1 2.2 AMC Organizational Structure ...... 2 2.3 Main Products and Services ...... 2 2.4 AMC Business Performance Review ...... 3 2.5 AMC Financial Performance ...... 4 2.6 Significant Developments/Changes in 2014 ...... 4 3 CR Strategy and Management ...... 5 3.1 CR Management Approach ...... 5 3.1.1 Key Achievements in 2014 ...... 6 3.2 The CR Governance and Management Structure ...... 6 3.3 CR controlling and integrated reporting ...... 8 3.4 Corporate Governance ...... 9 3.5 Compliance Management System ...... 12 3.6 Measurable results and GRI indicators ...... 16 3.7 Stakeholders Engagement ...... 16 3.7.1 Stakeholders Engagement Approach ...... 17 3.7.2 Stakeholders Dialogue ...... 17 3.8 Memberships and Awards ...... 21 3.9 Achievements in 2014 and Goals for 2015 ...... 21 4 Marketplace ...... 22 4.1 Management Approach ...... 22 4.1.1 Key Achievement in 2014 ...... 24 4.2 Responsible Competition ...... 24 4.2.1 Activities for a Responsible Marketplace ...... 25 4.3 Expanding Mobile Internet in Albania ...... 26 4.4 Penetration ...... 26 4.4.1 Key Investments ...... 26 4.5 Public Awareness ...... 27 4.5.1 Products and Services ...... 27 4.5.2 Cooperation with Recognized Bodies ...... 28 4.6 Responsible Marketing ...... 29 4.6.1 Responsible Marketing Practices ...... 29 4.7 Transparency on Pricing ...... 30 4.7.1 Equipment Safety Labelling ...... 31 4.8 Responsible Procurement and Supply Chain Management ...... 31 4.8.1 Procurement Policy...... 32 4.8.2 Suppliers Evaluation ...... 33 4.9 Customer Service and Satisfaction ...... 34 4.9.1 Complaints Management ...... 34 4.9.2 Customers Survey ...... 35 4.10 Data Security and Privacy ...... 36 4.10.1 Developments to Streamline with Deutsche Telekom security standards ...... 37

Page i AMC Corporate Responsibility Report 2014

4.11 Business Security Management ...... 38 4.12 Achievements in 2014 and Goals for 2015 ...... 38 5 Employees ...... 39 5.1 Management Approach ...... 39 5.1.1 Key Achievement in 2014 ...... 39 5.2 Employment ...... 40 5.2.1 Workforce ...... 40 5.2.2 Fair Employment Policy Framework ...... 42 5.2.3 Non–Discrimination, Equal Opportunity and Diversity ...... 42 5.3 Health and Safety ...... 44 5.3.1 Health and Safety Policy ...... 44 5.3.2 Health and Safety Performance in 2014 ...... 45 5.3.3 Health and Safety Prevention and Awareness ...... 46 5.4 Employee Development ...... 48 5.4.1 Performance Management...... 48 5.4.2 Performance Development ...... 48 5.4.3 Employee Training ...... 49 5.5 Employee Benefits ...... 50 5.6 Internal Communications ...... 51 5.7 Employee Engagement and Satisfaction ...... 52 5.7.1 Employee Engagement ...... 52 5.7.2 Employee Satisfaction ...... 52 5.8 Achievements in 2014 and Goals for 2015 ...... 53 6 Society ...... 55 6.1 Management Approach ...... 55 6.1.1 Achievement in 2014 ...... 55 6.2 Social Products, Services and Offers ...... 56 6.2.1 People with Special Needs, the Elderly and Socially Vulnerably Groups ...... 56 6.2.2 Students ...... 56 6.2.3 Public Helplines, Services and Offers ...... 56 6.3 Social Contribution ...... 57 6.3.1 Supporting Children Welfare and Development ...... 57 6.3.2 Supporting Enable Equal Access to Education and Information ...... 58 6.3.3 Supporting Vulnerable Social Groups and People with Special Needs ...... 59 6.3.4 Promoting Art and Culture ...... 59 6.3.5 Supporting the Environment ...... 59 6.4 Achievements in 2014 and Goals for 2015 ...... 60 7 Environment ...... 61 7.1 Management Approach ...... 61 7.1.1 Environmental Policy ...... 63 7.1.2 Environmental Management ...... 63 7.1.3 Key Achievement in 2014 ...... 65 7.2 Priorities in Addressing Environmental Impacts of AMC Activities ...... 65 7.3 Telecommunication for the environment ...... 66 7.4 Managing Energy Use and Addressing Climate Change ...... 67 7.4.1 Direct and indirect Greenhouse Gases Emissions ...... 67 7.5 Improving Energy Efficiency and Reducing Emissions ...... 70 7.5.1 Energy Consumption ...... 70

Page ii AMC Corporate Responsibility Report 2014

7.5.2 Monitoring Energy Consumption and Energy Conservation in the AMC Network ...... 72 7.5.3 Energy Consumption and Energy Conservation in AMC Buildings and Stores ...... 73 7.5.4 Energy Consumption and Energy Conservation in AMC Transport ...... 73 7.6 Resource Use and Waste Management ...... 75 7.6.1 Hazardous Waste Management ...... 75 7.6.2 Technical Waste Management ...... 76 7.6.3 Paper Waste Management ...... 76 7.7 Electromagnetic Field ...... 78 7.7.1 Following by Design the Precautionary Principle ...... 78 7.7.2 Monitoring the Levels of EMF Radiation ...... 79 7.7.3 Informing Society and Employees ...... 80 7.8 Other Environmental Aspects of AMC Operation ...... 80 7.8.1 Water Consumption ...... 80 7.8.2 Biodiversity ...... 80 7.8.3 Visual Impact ...... 81 7.8.4 Noise ...... 81 7.9 Environmental Awareness Initiatives ...... 82 7.9.1 Initiatives to Enhance AMC Employees Awareness...... 82 7.9.2 Initiatives to Enhance Public Awareness ...... 82 7.10 Achievements in 2014 and Goals for 2015 ...... 82 8 Appendices ...... 84 8.1 Summary of key performance indicators ...... 84 8.2 GRI G3.1 Index ...... 85

Page iii AMC Corporate Responsibility Report 2014

1 About this report

Editorial policy The 2014 CR report is the ninth Corporate Responsibility Report of AMC. Through these reports AMC has provided extensive information to its stakeholders and the general public about its objectives, most significant achievements, activities and projects undertaken in the field of Corporate Responsibility (CR) since 2006. Since 2010, this report — along with regularly updated CR information — is only available online at: http://www.amc.al/al/c/137/CSR-Reports. The company has chosen not to print it as an eco-friendly reporting platform of AMC. Since 2010 AMC CR reports have been prepared according to the sustainability reporting guidelines of the Global Reporting Initiative (GRI).

Scope of the report, boundary and methodology This report contains detailed content and indicators chosen to measure its performance in terms of principle, recommendation and methods as found within the Sustainability Reporting Guidelines (G3.1) and telecom sector supplement (applicable to companies in the telecommunications industry) in its pilot version 2003. To locate the elements and information contained within the guidelines, please refer to the GRI Index in Section 9.

The report covers the operations and activity in Albania of AMC. It makes reference to objectives announced in the 2013 Corporate Responsibility Report of the company. In some of the cases a restatement of the past position is provided.

This report covers the period 01 January – 31 December 2014 (unless otherwise stated in specific items). It also includes some noteworthy accomplishments from the beginning of 2014 and not captured elsewhere.

A production team made up of members from within AMC and from outside the company have developed the elements included and considered from the perspective of stakeholders’ interest, as well as awareness of the company’s priority operations. The team conducted interviews with key persons, directly collected information and numeric data and compiled the report.

This report is dated June 2015 with the 2015 issue planned for publication in the second quarter of year 2016.

Limitations The company has made substantial progress in preparation of its CR reports for the past years. However, it is aware that there exist some limitations in this report, and aims to address them in the future. The limitations include:

 the need for an expansion of the quantitative and qualitative system;  that not all GRI indicators have been disclosed but will be addressed in the coming years;  the validation of quantitative elements has not been made by an independent institution, but by the company itself; and  areas of focus and commitment cover also other indicators and aspects of the company’s approach to sustainability.

The potential to improve these in the future remains strong in terms of ensuring quality of data consistency, completeness and comparability.

Page 1 AMC Corporate Responsibility Report 2014

Structure of this report The 2014 CR Report has been designed as a progress report that provides comparative data as compared to previous year’s report and focuses on the key developments of the reporting period. There are 5 main sections in this report. These are as follows:  CSR Strategy and Management;  Marketplace;  Employees;  Society; and  Environment.

In addition the annexes section provides:  A summary of key performance indicators, providing information about our progress in the past four years; and  GRI 3.1. Index table with a description of relevant GRI performance indicators.

Report data In collecting and presenting data, AMC has been guided by the definitions and parameters of the GRI Indicator Protocols. The data used in this report comprise the following record systems provided by the company:  Aggregated financial and personnel data, aggregated data on customer service, summary data on regulatory actions; and  The environmental data have been calculated according to internationally accepted methods, on the basis of information provided by the Company Operations Divisions and Operations Divisions of AMC.

AMC uses an IT based data collection system, called IKOS, which is used by all Deutsche Telekom (DT) Group Companies as a CR controlling system and which plays an important role when it comes to steering DT Group CR activities. The system gives the company more capacity to conduct extensive analyses of CR data.

GRI Application Level GRI has confirmed that the AMC 2014 CR Report was prepared according to the GRI G3.1 Guidelines, at Application Level B.

The reporting criteria for each level reflect a measure of the extent of application or compliance with the GRI Reporting Framework, and are illustrated in the table below.

Page 2 AMC Corporate Responsibility Report 2014

This report has not been subject to external assurance.

Feedback on this report AMC believes the information in this report to be an accurate representation of its business operations with regard to its corporate responsibility and will be used as a mechanism for building our relationship with our Stakeholders. Your feedback, suggestions and questions are important to us. Please send them via e-mail to: [email protected] or via post to: AMC, Rr.”Gjergj Legisi”, Laprake, Tirana, Albania.

Terminology  The terms “we”, “the company”, “AMC” refer to Albanian Mobile Communication S.A.;  The terms “Report” and “CR Report” refer to the current 2014 Corporate Responsibility Report of AMC; and  The term “CR” refers to Corporate Responsibility and “CSR” refers to Corporate Social Responsibility. Both terms are used as synonyms for each other.

Page 3 AMC Corporate Responsibility Report 2014

2 About AMC

2.1 AMC Shareholders Structure

AMC is one of the largest companies in Albania. It was founded in 1995 as the first mobile telecommunications company in Albania. As of 31 December 2014, AMC counts 2.06 million subscribers, representing a market share of 39%.

AMC is a stockholding company registered in Albania under law no. 7638, dated 14.12.1992 “On trade companies” as amended. As of today, the company is 99.76% directly or indirectly owned by OTE, which is a multinational group with a wide presence in South (www..gr). The OTE Group organizational structure is available on the OTE website: https://www.ote.gr/web/guest/corporate/ir/business-overview/organizational-structure.

In 2009 AMC joined the Deutsche Telekom Group. Being a member of a leading group that operates from Western and South Eastern Europe to the United States. AMC applies technology standards according to EU norms and parameters, and in compliance with the Albanian legislation, placing a particular emphasis on health and environment.

The OTE Group shareholders structure is given below:

OTE Group Shareholders Structure

Greek State

9.90% 10.00% Deutsche Telekom 11.20%

International Institutional Stakeholders 40.00% Greek Institutional 28.90% Stakeholders

Other Stakeholders

The Deutsche Telekom Group is committed to its corporate responsibility and bases its actions on economic as well as social and environmental criteria.

AMC has 452 expert employees, who work with a high degree of passion to offer best solutions to all customers. Company employees are provided with the same standards of the

Page 1 AMC Corporate Responsibility Report 2014

Deutsche Telecom Group’s counterparts in Europe. The company’s revenue for year ending on 31 December 2014 was €81.5 million, and its EBIDA was €29.8 million.

In 2014, AMC did not receive any government financial subsidies, state aid, special tax relief or other government financial payments.

2.2 AMC Organizational Structure

AMC’s organizational structure is designed to operate in the most efficient and effective way possible so as to serve its customers as well as it can. The structure is shown below.

2.3 Main Products and Services

AMC provides a full range of products and services in mobile telephony, covering the increasing communications demands for all consumer groups, be they businesses, public institutions, families or individuals. The following products are designed to do this well:

 Prepaid and post-paid mobile services;  Internet (including 3G up to 42 Mbps);  Other value added services;  Roaming services;  Prepaid and post-paid fix line when at home or office; and  Mobile devices and accessories such as, headsets, Bluetooth©, headphones, chargers, PC tablets, laptops, etc.

Page 2 AMC Corporate Responsibility Report 2014

In 2014 AMC introduced additional new products and services and extensively improved all its existing products and services. Some of the recently introduced services were the following:

 AMC Share: a service that offers all AMC subscribers the opportunity of transferring or asking to receive 60 AMC minutes from the telephone “bundles” of friends who have activated the service;  e-Di application, which is a family location service, allowing people to have updated information about their family members at all times, such as security zone for family members, find family members in real time, and protect their smartphones from various threats;  Magisto application used to create professional videos in only a few minutes;  Wunderlist application used to synchronize and organize data and manage them more effectively;  Tablets at discount prices such as Evernote tablet, Asus, Samsung and many recently launched smartphones; and  HD Voice calls offered for free.

2.4 AMC Business Performance Review

During the year under review AMC has introduced many new products and services thereby bringing more effective solutions to satisfy the growing demand of over 2 million of its subscribers, who extensively use the network for data and voice services.

The number of AMC subscribers in 2014 decreased by c.a. 8% which is the same as the rate that the Albanian market reduced in that same period.

The company has optimized its internal workforce to count 452 professionals from various backgrounds and expertise.

AMC Business Performance Review of December 31, 2014

Customer base Ca. 2.06 million Internet customers Ca. 0.28 million Post-paid Customers Ca. 0.11 million Prepaid Customers Ca. 1.95 million Market share 39% New/Improved Products provided 27 New/Improved Services provided 13 Base stations 516 Population Coverage 99.80% Territory Coverage 92.50%

Number of Employees Page452 3 AMC Corporate Responsibility Report 2014

2.5 AMC Financial Performance

Despite the continuous regulatory pressure and intense competition in the communications market, the company maintained its strong position, delivering a solid EBITDA performance and strong cash performance. The commercial momentum built up over previous year, continued, combined with the optimized cost structure and profitable investment in key areas lead to significantly increased competitive edge for AMC

The financial performance for the year 2014 is given in the table below:

AMC Financial Performance in € million Year 2014 Total Revenues 81.5

Pro forma EBITDA 29.8 as % of Total Revenues 36.56%

2.6 Significant Developments/Changes in 2014

The most significant changes in the year under review relate to the organizational structure, and management elements. These were the following:

 In March 2014, the Residential Sales Director was replaced;  In June 2014, the B2B Sales Director was replaced;  In July 2014, the Shareholders General Assembly re-appointed the Members of the Supervisory Board;

Page 4 AMC Corporate Responsibility Report 2014

3 CR Strategy and Management

3.1 CR Management Approach

AMC as reflected in its everyday operations abides to a well-established CR strategy, documented also in its CR report. As Part of the Deutsche Telekom Group, the company has set and implements sustainable principles and measures targets and well tested instruments which make a good impact for the company, but also the communities where it conducts its business. The Deutsche Telekom Group CR strategy defines mandatory guidelines for all companies that are part of the group.

Based on this strategy, the AMC CEO is the highest executive in charge for implementing CR practices. The CEO delivers CR strategic guidance to the Corporate Affairs Department, which is responsible for issues and programmes of the AMC Corporate Responsibility effort. It reports to the CEO, works closely with all other Departments within the company, and participates in OTE and DT CR Managers’ Networks and meetings held.

Sustainability principles are set in the company’s Code of Conduct, CR Policy, Suppliers Policy and in other documents that guide the relations with internal and external stakeholders. It is important to communicate these fundamental values to all employees in the form of mandatory guiding principles and code of mandatory guiding principles and codes of conduct in order to guarantee a value-based corporate culture. In addition, the company communicates with external and internal stakeholders, in order to take our responsibility for the impact of our company’s activities.

In the course of the year, several occasions have been used to cascade the CR commitment down to individual employee level. Examples include the communication campaign about recycling of mobile handsets, the messages to employees about saving electricity used by PCs and lighting, and their involvement in actions to collect and properly dispose of office waste.

The company’s Corporate Responsibility framework over the past four years has focused on the most material issues, namely the marketplace, employees, environment and society. Implementation of the CR strategy is carried out through frequent engagement with company stakeholders, whose feedback in various issues is discussed also in Group Level meetings, and when relevant, reflected into CR programmes and initiatives.

The company conducts regular studies and surveys to define CR areas of focus. In these surveys individuals were asked about how they perceived the CR activities. The findings of these studies and the information received from other forms of engagement with stakeholders are important for defining how the company engages in the CR activities.

The three Core Corporate Responsibility areas of action are called:

1. Connected life and work; 2. Connecting the unconnected; and 3. A low carbon society.

Page 5 AMC Corporate Responsibility Report 2014

AMC defines Corporate Responsibility as “the commitment of the company to contribute to global sustainable development, by taking economic, ecological and social objectives into consideration in our decision-making processes, to take responsibility for the impact of our organization’s activities, by working and communicating with internal and external stakeholders, while at the same time improving the competitiveness of the company”.

Marketplace Employees Society Environment

 Responsible  Health and Safety  Social Products and  Energy Competition  Fair Employment Services Efficiency  Expanding  Employee  Social Contributions  Road Transport Broadband and Development  Employee  Greenhouse Mobile Internet  Employee Benefits Volunteerism Gases  Responsible  Internal  Water Procurement Communication  Materials and  Public Awareness of  Employee Waste Technology Satisfaction  EMF  Customer  Visual Impact Satisfaction and  Noise Service  Public  Data Security and Awareness Privacy

Connect the Low-Carbon Connected Life and Work Unconnected Society

3.1.1 Key Achievements in 2014

Key achievements in 2014 are the following:

 Further enhancement of AMC CR strategy;  Aligning AMC CR framework with Deutsche Telekom CR framework; and  In 2014 AMC was re-audited for its Environment Management System, Occupational Health and Safety System and Quality Management System by an independent accredited institution. The findings indicated that the systems are in compliance with ISO standards, respectively ISO 14001:2004, ISO 18001:2007 and ISO 9001.

3.2 The CR Governance and Management Structure

The company has fostered its governance structure to align Corporate Responsibility with other strategic and operation activities conducted by AMC. To ensure this, clearly stated roles have been defined for all bodies dealing with CR activities. The main structures, their roles and how they align with each other and overall strategy of the company is given below:

Page 6 AMC Corporate Responsibility Report 2014

Board of Directors carries general responsibility for Corporate Responsibility. It is responsible for the supervision of AMC Corporate Responsibility issues. The Chief Executive reports to the Board of Directors as well, to ensure the AMC CR strategy is streamlined with OTE Group and Deutsche Telecom Group activities. CR strategy and core initiatives are discussed annually.

Chief Executive Officer has a stronger role in Corporate Affairs issues and gives guidance and directions in development of overall Corporate Responsibility strategy, aligning it with the strategy of the company.

Corporate Affairs Office is responsible for the development and implementation of the company’s CR strategy. The Corporate Affairs Manager reports to the CEO and cooperates with the latter on CR strategy issues and initiatives. The AMC Corporate Affairs Office has in its structure the Corporate Responsibility and Corporate Sponsorships Unit. The Corporate Affairs Office cooperates with OTE and Deutsche Telekom CR Managers Networks and other relevant structures in these organizations to share experience, practices and goals on approaching the CR agenda. The CR managers at Deutsche Telekom gather regularly for international talks at live meetings or webinar conferences. At these gatherings, they exchange their experiences on current activities and find out about the status of executing CR strategy and KPIs elsewhere.

In this extent, a meeting was organized in 2014, where all DT Group companies had the opportunity to share their CR activities and discuss specific CR issues that DT should focuse its efforts on.

The managers work in teams to design and implement Group-wide projects. As part of these meetings, the members of the CR manager network inform themselves about best practices and the latest developments.

Corporate Responsibility Unit works for the implementation of CR strategy, coordinates and manages CR activities throughout the company, collects and processes the CR data, monitors the implementation of the CR measures and targets, and communicates internally and externally, the company CR performance. It coordinates common CR activities of the company with OTE Group and Deutsche Telekom Group. The functions of the Corporate Responsibility Department include, inter alia, the implementation and management of regular communication with external experts and stakeholders. All members of the Corporate Responsibility Team contributed significantly to raising awareness and mobilizing employees to enhancing the visibility of Corporate Responsibility, meeting CR objectives and to creating of a common corporate CR culture.

Interdepartmental CR Structures exist for the management of various CR issues. These structures have been created to manage systems that address quality, health and safety, and environment issues, and altogether are incorporated into the AMC Integrated Management System, which is overseen by the Management Systems’ Steering Committee. To ensure the application of several policies and issues and to coordinate the operational works and activities among many structures within the company, various interdepartmental teams have been created. These include:

a. Environmental Management Team which is responsible for the operational aspects of the company’s environmental commitment; b. Health and Safety Team, which is responsible for the operational aspects of the company’s health and safety commitment;

Page 7 AMC Corporate Responsibility Report 2014

c. Business Continuity Management (BCM) Team, which is responsible for planning and implementing Operational Continuity Pans, in order to protect the company from unexpected events. A dedicated BCM specialist has been employed within the Corporate Affairs Office to deal with BCM issues only; d. Crisis Management Team (CMT, which is responsible for decision-making and management of activities in case of significant incidents that may occur; e. Incident Response Team (IRT), which is responsible for responding and dealing with emergency situations in the company premises at first occurrence; and f. Crisis Communication Team (CCT), which is responsible for public, media and internal communication in case of a crisis.

Board of Directors CR Management Structure

QM Team Chief Executive Officer

Management Systems Steering Committees H&S Team

Environmental Corporate Affairs Office Occupational H&S Quality EMS Team

Corporate Responsibility Unit IRT

Business Continuity BCM Team Management

Committee

CCT

Organizational Interdepartmental Interdepartmental

Structures Committees Teams

3.3 CR controlling and integrated reporting

For every company that takes reporting and CR activities seriously, it is important to measure and control indicators in ways that enable clear progress and transparent reporting to the employees, shareholders and all external stakeholders.

As with many other companies within the Deutsche Telekom Group, AMC has been using an IT based data collection system (called IKOS) for controlling and reporting CR. This system gives the company greater capacity to conduct extensive analysis of CR data, and benchmark it against other companies that are part of DT Group. The controls and

Page 8 AMC Corporate Responsibility Report 2014

processes to date relate to energy consumption, CO2 emission, water consumption, volunteering activities, etc. Such data is entered into the system at least every quarter and helps the company and its employees to deal extensively with its CR status versus its committed targets.

This system is managed by DT hosted on a secure cloud service.

AMC also uses the Energy Consumption and CO2 Emissions KPIs as important performance indicators in internal reports. These KPIs are included in two reports addressed to the Board of Management. Once every quarter, relevant CR information is included in the DT Group HR Management Report using these two KPIs.

3.4 Corporate Governance

Corporate Governance is the legal and factual regulatory framework for governance of the company. It includes a number of principles and responsibilities distributed to corporate bodies to include shareholders assembly, Supervisory Council and Board of Directors with regard to management and supervision of the company. Apart from legal requirements set by the Government of Albania, Telecommunication Supervisory Authority and other legal institutions, the company aims to uphold its performance and the interests of all its shareholders. AMC complies with well-recognized national rules of corporate behaviour, to include the corporate governance principles determined by the Corporate Governance Code (Code) for unlisted joint-stock companies in Albania. The text of this code can be retrieved at http://www.qkr.gov.al/nrc/documents/Codeang.pdf, and other international corporate governance legislation.

AMC has voluntarily adopted its internal regulations to comply with well-known international practices and standards for its operations. All relevant provisions and practices are incorporated in the Internal Operations Regulation, the Company’s Code of Conduct (OTE Group Code of Conduct) and other Policies adopted by the competent corporate bodies. The core governmental structure consists of the following:

General Shareholders Assembly The highest-ranking governance board of AMC responsible to take decisions for important corporate issues (according to law no. 9901 date on 14.4.2008 “On traders and trading companies”) is the “General Shareholders Assembly”.

Supervisory Council The Supervisory Council has the responsibility to ensure that the Company’s activities and operations are in compliance with all laws and regulations. It reviews and monitors any actual or potential situations of conflict of interest and is in compliance with the law. It receives from the Board of Directors (BoD) all the notices of actual or potential conflict of interest or material interest they may have with the Company. In addition, the Supervisory Council supervises the activity of the Board of Directors. The Supervisory Council consists of three members, who are elected by the Shareholder’s Assembly Meeting for a three-year term. The Supervisory Council meets at least once every three months. The composition of AMC Supervisory Council is shown below.

Executive Non-Executive Name Position Member Member

Page 9 AMC Corporate Responsibility Report 2014

Konstandinos Liamidis Chairman

Georgios Tsonis Vice-Chairman

Pavlos Vichos Member

Supervisory Council on the 31.12.2014.

 Mr. Konstandinos Liamidis is Chief International Operations Officer OTE Group as of February 2011. Mr. Liamidis joined as Deputy Commercial Director at the time of its incorporation in 1996. In the beginning of 2000 he was appointed Retail Network Sales Director. In May 2003 Mr. Liamidis became General Commercial Director. He has been as Advisor to the COSMOTE CEO since November 2007. He started his career in OTE and later on became an executive in the Commercial Department of the Organization. He has been Chairman of the AMC Supervisory Council since year 2006.

 Mr. Georgios Tsonis was appointed Technical General Director of COSMOTE in November 2005. In 2000 he joined COSMOTE as Switching Deputy Director, and in 2001 was appointed Switching and Network Management Director. He has been Vice-Chairman of the AMC Supervisory Council since year 2001.

 Mr. Pavlos Vichos has been member of the AMC Supervisory Council since year 2011.

Boards of Directors As described in the company’s statue, the Board of Directors is responsible and defines the general policies and strategy of AMC as well as supervising operational management and the overall activity of the company. The Board of Directors consists of five members appointed by the Supervisory Board for a three-year term. They can each be reappointed. Board of Directors meetings are held at least once every three months. Wages and other compensation of Board members are defined according to General Assembly decisions. The composition of AMC Board of Directors is illustrated below.

Executive Non-Executive Name Position Member Member

Zacharias Piperidis Chairman

Eyriviadis Sarsentis Vice-Chairman

Dimitrios Blatsios CEO/Member

Irini Nikolaidi Member

Page 10 AMC Corporate Responsibility Report 2014

Georgios Athanasopolous Member

Supervisory Council on the 31.12.2014.

 Mr. Zacharias Piperidis is Chief Operating Officer of OTE Group. He has held the position of COSMOTE’s General Commercial Director since November 2007. He has long experience in the telecoms sector, which he has served for more than 18 years. He has been chairman of the AMC Board of Directors since 2010.  Mr. Eyriviadis Sarsentis has been working for OTE Group for the past 10 years, serving as IR & Strategy Director at COSMOTE and more recently as M&A Director at OTE Group. Previously, Mr. Sarsentis has worked for 15 years at investment banks in and abroad. Mr. Sarsentis holds a degree in Economics from LSE and an MBA from City University.  Mr. Dimitris Blatsios has been Chief Executive Officer of AMC since December 2010. Before joining AMC, Mr. Blatsios was Executive Chief Commercial Officer in GLOBUL, COSMOTE's subsidiary in Bulgaria since March 2009 and General Manager in GERMANOS Telecom , since October 2006. Before that, he was Head of the International Retail Division of the GERMANOS Group of Companies (Poland, Bulgaria, Romania, , FYROM and ).

 Ms. Irini Nikolaidi has served COSMOTE since its foundation in 1996 as Legal Counsel – Competition, Legal & Regulatory Affairs General Director. Since January 2011, Ms. Nikolaidi has held the position of OTE Group Legal Counsel - Executive Director of Legal and Regulatory Affairs of OTE Group, which incorporates the General Directorate of Legal Affairs of OTE and the General Directorate of Regulatory Affairs of OTE. She also performs the duties of General Director of Legal Affairs of OTE. Before joining COSMOTE, she had served OTE as an expert in telecommunications. She has been a the member of AMC Board of Directors since 2001.

 Mr. George Athanasopoulos is Chief Information Officer at OTE Group. Since October 2007, he has also been COSMOTE’s Operations & IT Systems General Director. Mr. Athanasopoulos joined the OTE Group in 2002, as OTE Investments Information Management Executive Director, Since September 2006 he held the position of Operational Support Executive Director in OTE Globe. He has been a member of the AMC Board of Directors since 2008.

The Chief Executive Officer (CEO) assumes the primary responsibility for operational management. The CEO is assisted and supported in this operation by Internal Audit and Compliance.

Compensation of all Members of the Board of Directors is approved by the Shareholders’ General Assembly. The Executive Directors’ compensation, including performance–related compensation procedures, is covered by employment contracts, which are approved by the Shareholders’ General Assembly.

On CR matters, the CEO seeks input from the BoD as part of the annual review of strategic objectives. Currently, the evaluation of the CEO, as well as the Boards’ performance does not include specific criteria related to Corporate Responsibility.

Page 11 AMC Corporate Responsibility Report 2014

Employees may bring issues to the attention of the Boards of Directors through the formal dialogue of the Management with the employee representatives.

3.5 Compliance Management System

Compliance Management The Compliance Management system (CMS) is implemented to ensure compliance of all personnel and Management with the legislation in force, the Code of Conduct and internal policies, aiming to avoid risks and other legal consequences for the company.

The key elements of the CMS are prevention of misconduct and protection of the reputation of the company and their personnel, through employee training, continuous communication, detection of compliance risks and violations, and a structured response to them.

The CMS was reviewed and assessed by independent external auditors. The audit covered the procedures/controls as well as anti–corruption controls implemented at the Compliance Department as well as anti–corruption controls implemented at other units (Internal Audit, Human Resources, Sales and Procurement) and confirmed the effectiveness of the companies’ CMS (Compliance Management System Certification 2013).

In 2014, an Interim Risk Assessment (Risk Pulse) exercise was carried out to assess the business units involved and identify the most critical risks, such as those described in the Corporate Risk Register in order to spur optimization of the mitigation procedures. In addition, the AMC CMS structure participated in the project for the creation and establishment of a single corporate risk management methodology for the DT Group.

An Anti–Corruption Training Programme was conducted in May 2014, with the participation of company employees from middle management. The Training Programme covered topics such as avoiding corruption and other conflicts of interest, accepting and granting of benefits and Anti-Trust Policy. Details of the participation rates are given in the Table below. E–Learning Training Program

Anti-corruption Training Program

Training method Number of targeted Number of Participation employees participators rate (%)

e-learning 104 100 94.15%

Classroom 119 113 94.96%

Total 223 213 95.52%

Page 12 AMC Corporate Responsibility Report 2014

In 2014, Compliance Officer handled 81 queries through the “Ask me!” consultation desk. The queries were related mainly to compliance policies of granting and accepting of corporate gifts, corporate events and sponsorship policy.

Ensuring Compliance Management System Compliance stands for a solid commitment to the principles of integrity, transparency, justice, professionalism, team spirit, and respect of the rules and principles, which are essential in governing the functions of the companies.

In the year under review, the Compliance Risk Assessment was conducted to identify and assess compliance risks affecting the company. Many employees, having different core roles within the company were involved in this type of exercise aiming to assess the risks and propose relevant measures in addressing them. The Compliance Risk Assessment including Measure Plan for 2015 was finalized in September 2014 and approved by OTE Group GRC and Audit Committee.

The implementation of the CMS is monitored by COSMOTE Compliance Committee, which consists of:

 The General Director of COSMOTE Group Compliance & Internal Audit Department;  The General Director of COSMOTE Group Competition, Legal and Regulatory Affairs;  The General Director of COSMOTE Human Resources;  The Director of COSMOTE Information Security Department; and  In 2014, AMC received no complaints about compliance issues.

In order to provide the possibility of filing a “tip–off” regarding violations of policies, regulations and of the legislation in force, AMC has adopted a Whistle-blowing Policy and applicable channel to implement it. Employees and/or third parties may anonymously report to the Compliance Office a violation or express a concern or complaint regarding potential violations of the company’s Policies or the legislation (e.g. corruption, abuses, theft, money laundering, financial statements matters, Policies and Procedures, discriminations, employee relations and any misconduct which could harm the company’s reputation, or any attempts to conceal the above).

The Department responsible for the planning and adoption of the CMS, reports directly to the Company’s Board of Directors. The implementation of the CMS is monitored by the Compliance, Enterprise Risks and Corporate Governance Committee. The main purpose of the Committee is to support and monitor the implementation of the Compliance Management and Risk Management systems and review other issues of Corporate Governance.

In the context of implementation of the CMS, the following Policies and Codes are in force:

 Code of Conduct;  Code of Conduct for the protection of the Individual’s Right to Privacy in the handling of Personal Data within OTE Group;  Code of Ethics for Senior Financial Officers;  Whistle-blowing Policy;  Policy on Avoiding Sexual Harassment within OTE Group;  Policy on Accepting and Granting of Benefits;  Policy on Donations and Sponsorships;  Events Policy;  Fraud Policy;

Page 13 AMC Corporate Responsibility Report 2014

 Policy on Insider Trading;  Policy on Avoiding Corruption and other Conflicts of Interest;  Policy on Employee Relations within OTE Group;  Policy on Anti–Trust Law;

AMC communication channels for complaints are the following:  Via Mail @ Albanian Mobile Communications sh.a. Compliance Office, “Gjergj Legisi” str., Laprake, Tirana, Albania  Via e-mail @ [email protected]  Via telephone @ +35542275321 (Monday through Friday: 9 am until 5 pm)  Via the Electronic Whistleblowing Form.

Compliance Management Certification Independent auditors certified Deutsche Telekom's CMS in several companies including AMC in 2013 in accordance with Institute der Wirtschaphfen (IDW) audit standard 980. The audits focused heavily on anti-corruption. This certification is proof that the certified CMS used by AMC is effective when it comes to identifying corruption risks and preventing violations.

AMC abides by the regulation of the DT Group. In line with the DT Group's international structure, strategic issues are discussed with an international compliance advisory team and a shared compliance approach is defined. The team is a trend-setter of sorts, as it provides an impetus for designing and implementing balanced compliance structures at the Deutsche Telekom Group (DT Group).

On the occasion of the International Compliance Days, AMC members of the Compliance Office together with members of 26 other DT Group companies participated in an event at Magyar Telekom in Budapest on April 2 and 3, 2014. Under the slogan, "Compliance today and tomorrow," they discussed compliance strategies and trends as well as new approaches to collaboration.

Preventing and fighting corruption The compliance risk assessment forms the foundation of DT Group’s CMS. The assessment helps the company identify and evaluate compliance risks and develop appropriate prevention measures. Deutsche Telekom created a tool-based process that has to be applied every year throughout the Group. For the process, responsibilities are assigned and assessment criteria defined and are documented.

In 2014, the company participated in a risk assessment analysis conducted for 108 companies within the DT Group. The assessment helps the DT Group and the company identify and evaluate compliance risks and develop appropriate prevention measures. This involves defining which specific threat each risk poses to the company and identifying what has already been done to mitigate this risk. If necessary, additional measures are developed to reduce the risks to a manageable level, as defined by the risk strategy. This assessment is done every two years.

To promote the anti-corruption practices and avoid risks when working with a wide range of suppliers, AMC has adopted Integrity Checks when considering initiation of collaboration with new suppliers. The Integrity Check is done taking into account both the anti–corruption practices and company policies and procedures. Only the suppliers that have sound business practices are considered for cooperation.

Page 14 AMC Corporate Responsibility Report 2014

On 9th of December 2014 and on the occasion of the International Anti–Corruption Day, a communication campaign was organized at all OTE Group companies. The campaign included a message signed by the Chairman and CEO of OTE Group and sent via e–mail to all Group employees. The message of the Chairman and CEO underlined that at the OTE Group “we implement the United Nations Global Compact Principles on human rights, labour standards, the environment and anti–corruption”.

In the framework of the implementation of the Code of Ethics for Senior Financial Officers, BoD members and Senior Financial Officers signed and submitted to the AMC Compliance Office and OTE Group Compliance Office statements in which they declare that they are informed of the provisions of the Code of Ethics for Senior Financial Officers and that they comply with its provisions, aiming for honest and ethical business conduct.

The Annual Compliance Statement and the Conflicts of Interest Statement were signed by the AMC BoD members as well as by the Management Team. The Conflicts of Interest Statement is aligned with the requirements of the Policy on Avoiding Corruption and other Conflicts of Interest.

Investigation based on clear criteria AMC has specified clear criteria for investigating suspected cases of corruption. The company only starts investigations if a violation of legal or internal regulations is reported with a sufficient degree of detail. The Internal Audit and Compliance Office thoroughly investigates any tips that meet these requirements. Any violations uncovered during the company’s investigation are sanctioned appropriately and any weaknesses identified in the internal control system during the investigation are systematically analysed and remedied.

In 2014 no cases of corruption were registered. Based on AMC’s policy, in 2014 the company neither funded any political party nor received financial aid from public authorities.

During 2014, from relevant channel of compliance the AMC Internal Audit received a total of no “tip–offs”/complaints.

Internal Audit Internal Audit is an independent, objective assurance and consulting activity, designed to add value and improve an organization’s operations. It supports an organization to accomplish its objectives, by applying a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes.

The Internal Audit function in AMC operates based on the Internal Audit charter approved by the Board of Directors. The audit charter is in compliance with International Standards for the Professional Practice of Internal Auditing”, which is the guiding framework promulgated by “The Institute of Internal Auditors” (IIA). The IIA is an international professional association, which acts as a global body to provide internal audit professionals worldwide, with authoritative guidance. Furthermore, the company’s Code of Ethics govern the minimum requirements for the conduct and behaviour of, and expectations from auditors, in the conduct of their duty.

In 2014, Internal Audit has contributed to the enforcement of control environment through 8 audit projects, 26 new management actions, an assessment of DT Group Internal Controls System as well as other ad hoc projects. The Internal Audit Team participate in DT Group common audit project, which is of great importance in the further exchange of knowledge

Page 15 AMC Corporate Responsibility Report 2014

and fosters the cooperation of the DT Group of companies in implementing the DT Group CMS.

Audit Committee The primary purpose of the Audit Committee is to assist the Board of Directors, in the exercise of their supervisory role and the satisfaction of their obligations towards shareholders, investors and others, particularly with respect to the integrity of financial statements, the adequacy of internal control procedures and systems, the observance and adequacy of accounting and financial reporting processes, the evaluation of the independence of the companies’ external auditors, as well as the supervision of the Internal Audit.

3.6 Measurable results and GRI indicators

The progress of CR reporting as refered to the requirements of Global Reporting Initiative is given in the graph below.

GRI Reported Indicators

63 GRI Performance 64 Indicators Fully Reported 48 50 GRI Perfomance 43 Indicators Partially Reported

Telecom Sector 23 23 23 Supplement 15 Indicators Fully Reported 11 11 9 14 14 Telecom Sector Supplement 9 10 6 6 Indicators Partially 7 Reported

2010 2011 2012 2013 2014

3.7 Stakeholders Engagement

AMC identifies its key stakeholders as those groups, which have direct impact or influence on the sustainable success of the company. These are categorized into nine groups:

Page 16 AMC Corporate Responsibility Report 2014

customers, employees, shareholders, public, regulatory authorities, value chain partners, local communities, media and not-for-profit organizations. The company regularly engages with representatives of all these stakeholders, keeps them informed and takes account of their concerns.

3.7.1 Stakeholders Engagement Approach

The interaction between AMC and its stakeholders on issues related to CR is coordinated through the Corporate Affairs Office and involves the participation of the whole company. Knowledge of the views and interest of the stakeholder is of great importance for AMC.

AMC uses comprehensive communication tools with stakeholders, including this report. Other means of communication with its stakeholders include electronic and written media, phone conversations, surveys, information events/working sessions, conferences, road shows and promotions, directly at AMC shops.

AMC values the input of both internal and external stakeholders in the development of its CR strategy and initiatives, as well as the continuous improvement of its CR reporting. Regular reviews of its CR strategy and activities are conducted to do this.

3.7.2 Stakeholders Dialogue

The following table provides an overview the AMC stakeholder dialogue, the main topics raised, and the way the company responds to them.

Stakeholder Method of Responsivenes Group Engagement Frequency Topic Raised s

Customers

 Customer Relations  Ongoing  Quality of Service

Activities  Customer  Use of mobile Service  Ongoing phones Centre  Customer  Annually Satisfaction and  EMF Marketplace Survey Ongoing

 Technical Support  Tracking Environment /  Quarterly & Commercial Studies Electromagnetic Issues Fields  Responsible Marketing (e.g. consumer  Call Centres  Ongoing rights)  Introduction of new  Ongoing  Social Media technologies  Data Security and  Ongoing  Sales Network Privacy

Page 17 AMC Corporate Responsibility Report 2014

 Customer Service &  Company's  Ongoing Website Complains Handling Shareholders  Shareholders  Group Strategy and  Bi-Annually meetings Results  Financial  Quarterly reports  Adoption and utilization of  Periodic policies and All Sections principles  CR Report  Annual

 Meetings of  Ongoing Executives  Private  Ongoing Meetings  Daily  Ongoing Collaboration

Employees

 Employee Satisfaction  Annually  Health & Safety

Survey  Employee Carrier  Trainings  Ongoing  Development  Employee  Performance Participation Reviews &  Annually in Company's Appraisals Operations  Informative  Ongoing  Equality Publications

 Employee CSR Strategy and  Ongoing  Fair Work Events Management  Meetings with  Ongoing Employees Employees  Volunteering  Ongoing Activities  Company's website and  Ongoing

intranet  CR Surveys  Annually  Pulse Surveys  Bi-annually  E-mails  Ongoing

Authorities / Government

 Consultations  Meeting Regulatory  Ongoing Marketplace / on regulatory Demands Responsible Competition;

Marketplace / RegulationPage and 18 Competition;

Marketplace / AMC Corporate Responsibility Report 2014

framework

 Written or Verbal Communication with  Ongoing  Governance

Regulatory and Public Sector Bodies  Business  Contribution to legal Meetings &  Ongoing framework Reports  Cooperative  Cooperating in CR  Ongoing Projects Projects  Dialogue with representative of local and  Ongoing  Philanthropic Issues

national authorities  Attendance in  Economic and Associations  Ongoing Technological

and Unions Development

Media

 Timely response is  Media Event  Annually appreciated  Corporate Announcement  Ongoing  Commercial issues

s  Press  Ongoing  Technological issues Conferences  Informative All Sections  Ongoing  Environment issues Publications  Systematic communication and Meetings  Ongoing with Media Representative s  Company’s  Ongoing website

Public

 Surveys  Quarterly  Disaster Relief

 Community  Ongoing  EMF Society Philanthropy  Company’s  Environmental Environment  Ongoing Website Impact  Improving the lives of different

communities

Page 19 AMC Corporate Responsibility Report 2014

NPO

 Improving the lives  Applications  Ongoing of different

communities  Meetings with  Cooperation in CR  Ongoing NPO Projects  Social Contribution CR Strategy and  Meetings and Management Electronic Society

 Internet Safety Environment Public Education

Value Chain Partners (Suppliers & Distributors)

 Periodic &  Transparency &  Conferences About this Report Ongoing governance  Procurement Marketplace / Procedure &  Economic Management  Ongoing Key account Development Approach managers  Improving the lives

 Meetings  Ongoing of different

communities  Customer Marketplace/ Satisfaction  Improving the digital Responsible

Surveys  Annually gap Procurement and  Corporate  Ongoing Supply Chain Announcement  Resolutions for Management s and Press Malfunctions and Marketplace/ Releases Complaints Procurement  Suppliers  Ongoing Policy evaluation  Inserting CR Criteria  Attendance in  Ongoing Sector–based  Tender Criteria and Unions Competition

 Market Policy

Local Communities  Dialogue with  Improving the societal CR Strategy and local  Ongoing needs Management representatives  Support of local  Visits  Ongoing Society Business enterprising  EMF Environment

Page 20 AMC Corporate Responsibility Report 2014

3.8 Memberships and Awards

The company has participated with different organizations and bodies, and through this, has promoted various market developments and CR issues.

AMC is an active member of the following organizations:

 Tirana Chamber of Commerce and Industry;  American Chamber of Commerce and Industry;  Foreign Investors Association of Albania;  Hellenic Business Association of Albania;  German Industry and Trade Association; and  Albanian CSR Network since 2013;

In 2014, AMC did not receive any award on Corporate Responsibility.

3.9 Achievements in 2014 and Goals for 2015

The results achieved in respect its CR strategy and management objectives for 2014, as published in 2013 CR Report and the targets for 2015 are given below:

Section in the Goals for 2014 Progress in 2014 Goals for 2015 Report

Certify our Certify our operations operations according to ISO according to ISO 4.2 14001 for 100% 14001 for Environment Environment Management. Management.

Certify our Certify our operations operations according to according to 4.2 OHSAS 18001 for 100% OHSAS 18001 for Health and Safety Health and Safety Management. Management.

Page 21 AMC Corporate Responsibility Report 2014

Expand the Expand the collection and data collection and data control system, control system, related to our 100% 4.4, 4.7 related to our Corporate Corporate Responsibility Responsibility Report. Report.

Increase the Increase the reference to GRI reference to GRI 4.7 Indicators in the 100% Indicators in the Report. Report. Increase

awareness of CSR issues; integrate corporate 100% 4.2 responsibility into the way we operate.

Introduce new Extend usage of environment new environment friendly 100% 8.6.1 friendly technological technological solutions. solutions.

Integrate all CR management activities in one system to include Quality, 100% 4.2, 4.3

Environmental, Occupational Health and Safety and BCM.

4 Marketplace

4.1 Management Approach

AMC places the highest priority on transparency and ethics whilst at the same time strengthens responsible operations in the marketplace. It operates according to its ISO 9001 certified Quality Management System, aiming to offer high quality services to its customers.

Inspired by the company’s VISON, VALUES and PRINCIPLES, AMC aims to enhance its successful customer-centric philosophy, its competitive positioning and the use of

Page 22 AMC Corporate Responsibility Report 2014

technologically advanced services. The company aims for business excellence and to achieve this it commits itself to:

 Improve its operations by exceeding the expectations of its customers, shareholders, partners, personnel and society; and  Fully comply with ethical systems and current legal standards, and improve the effectiveness of its compliance system.

The company collects topics that are of a great interest for its stakeholders and addresses them by amending policies and procedures and empowering people to make the company and the environment where it operates safer and more responsible.

AMC strives for high standards and continuous improvement in its operations and throughout the entire supply chain. It provides responsible products and services, which consider customer safety, data privacy, and communicates it in a transparent way.

All market practice is conducted in accordance with the existing laws and regulations promoting efficiency, economic development and innovation, which the company considers as elementary components to support the free-market system. The company continually works on the processes and tools to secure customer data held by the company.

Responsibility for the strategy and marketplace management activities lies with the top management level at AMC, overseen by the Board of Directors, CEO and relevant management committees. They prepare the Business Plans, which include assessments of the market, regulatory and commercial risks and opportunities.

In the framework of responsible procurement, AMC runs annually the “Supplier Performance Evaluation” process, which involves the evaluation of its most important suppliers’ and partners’ quality of goods and services delivered, and their commitment toward the protection of the environment, health and safety and corporate responsibility. This process leads to higher standards of products and services and motivates suppliers to improve their performance and their own corporate governance initiatives.

The evaluation process, run in 2014, covered 17 OTE Group suppliers and 22 local suppliers. The suppliers had to return a self-assessment sustainability questionnaire. In addition they were evaluated internally by the respective departments demanding/receiving the designated products and services. This process was coordinated by OTE Group; the results of the evaluation are incorporated in to the Group’s results and announced to all Group companies. The results, and any consequent remediation measures, are then discussed by Senior Management.

Responsibility for the strategy and marketplace management activities lies with the top management level at AMC, overseen by Board of Directors, CEO and relevant management committees. They prepare the Business Plans, which include assessments of market, regulatory and commercial risks and opportunities.

The company offers responsible products and services, which consider customer safety and are communicated in a simple and transparent way. AMC advocates for the safe use of the Internet and has utilised several instruments do to this.

All market practice is conducted in accordance with the existing laws and regulations promoting efficiency, economic development and innovation, which the company considers

Page 23 AMC Corporate Responsibility Report 2014

as elementary components to support the free-market system. The company continually works on the processes and tools to secure customers private data.

The company also considers the risks that may arise from its supply chain and has made good efforts to address them.

4.1.1 Key Achievement in 2014

 Further development of responsible products and services (e.g. the use of the “Business Cloud”, corporate fleet management services; Dropbox, Security-Lookout);  Four brochures for public awareness were issued;  90% of all complaints received by the call centre were resolved in less than 2 days, and 88.5% of all other complaints were resolved in less than 3 days;  Compliance with the Supplier Code of Conduct was included in the contract terms with suppliers;  Evaluated 37 key supplies (17 OTE Group suppliers and 22 local suppliers); and  Successfully audited and certified to comply with the requirements of ISO 9001: 2008.

4.2 Responsible Competition

Competition is an elementary component of the free-market system because it promotes efficiency, economic development and innovation. For this reason the company pays special attention to obeying the national legislation and regulation in the telecommunication marketplace in Albania.

AMC supports fair dealings with its business partners and competitors. It does not disseminate false information about competitor products or services or attempt to undertake any other unfair means to gain a competitive advantage. The company is explicitly opposed to using industrial espionage as a means of obtaining information about market competitors.

The legal basis for regulating competition in Albania is outlined mainly in Law 9121 of 28.07.2003 “On competition”, which aims to protect free and effective competition, as amended frequently and enriched with additional by-laws and regulations by relevant authorities.

AMC is a stockholding company registered in Albania under law no. 9901, dated 14 April 2008 “On traders and trading companies”. The market is also regulated by national Laws, Presidential Decrees, Ministerial Decisions, as well as Decisions from independent administrative authorities. To ensure compliance with these, the company’s legal offices and the respective departments within the company are frequently updated with changes such regulations demand. Specific regulation is in place relating to various issues such as: licensing, tariffs, local loop unbundling, interconnection, leased lines, universal service and privacy issues. The main law to regulate the activities of the company is law number 9918, dated 19 May 2008 “For electronic communication in the Republic of Albania”.

The Authority of Electronic and Postal Communications (AEPC) imposes several regulatory obligations, which often have a substantial impact on the company’s business, such as pricing which the company applies. AEPC considers AMC as an entrepreneur with significant market power (SMP) in Albania. The Albanian market in particular has asymmetry in the

Page 24 AMC Corporate Responsibility Report 2014

termination costs and regularly imposes remedies to SMP operators apart from wholesale market also to the retail market, which can often be burdensome to the company, especially to some of its products and services.

AMC strives to increase transparency of the services, prices and service and contractual conditions it offers to its customers and commercial partners. In this regard, it publishes information and documents on the company’s website. Examples are:

 Partnering shops application form;  Reference interconnection offer;  General conditions of subscribers contract;  Service level agreement;  Indicator of mobile service quality;  Indicator of fix service quality;  SMS termination tariffs; and  SMS termination decision.

AMC has been developing its network to provide high quality telecommunication services to the business community, individuals, government and public entities and community groups. It encourages fair competition, which has a substantial impact on the development of the industry and the country itself. In 2014, neither investigation nor fines for ethical or anticompetitive behaviour was imposed against the company.

The company conducts every year a qualitative and quantitative survey to analyse the strength of AMC and its brands, both in absolute terms and in comparison with its competitors. Every quarter of a year, a quantitative survey is carried out on a representative sample of the Albanian population to measure their perception of the image of mobile operators including AMC.

4.2.1 Activities for a Responsible Marketplace

AMC offers products and services that promote growth, development and cooperation to build a fair marketplace in Albania and extensively contributes in joining and promoting initiatives that contribute in building a better communication market and more responsible environment in general. These initiatives include the following:

 Voluntarily signs and complies with the National Code of Conduct “On the Safe and Responsible Use of Electronic Communication Networks”. This code guides the company towards protection of children and public from the risks that are associated with Internet access, in line with protection level of other European countries;  In February 2014 the company participated in the conference organized by Ministry of Information Technology and discussed measures to increase safety in telecommunication networks and avoid child exposure from inappropriate material on the Internet;  AMC is part of CEO Coalition to make Internet a Safer Place for Children and Young People. AMC participated, as a member of Deutsche Telekom Group, in this cooperative voluntary intervention for the Safe Navigation of Children and Young People in the Internet. Companies that have signed the coalition are committed to take positive action in 5 areas: simple tools for users to report harmful content and contact, age–appropriate privacy settings, wider use of content classification, wider availability and use of parental controls, effective removal of child abuse material; and

Page 25 AMC Corporate Responsibility Report 2014

 AMC is a member of the Albanian CSR Network. It continuously participates in CSR events and contributes to such projects as well as fosters Corporate Responsibility in Albania.

4.3 Expanding Mobile Internet in Albania

The availability of broadband in Albania for fixed line and mobile services has grown extensively over the last few years. Its penetration rate though is still lagging behind the EU average rate. At the end of 2014 the number of subscribers with Internet broadband access from mobile network was circa 1.43 million, and represented a 16% increase compared with the year before.

4.4 Penetration

The number of 3G services offered by mobile operators increased substantially in 2014. Meanwhile, the active number of mobile subscribers decreased by 7.6% compared to 2013, and at the end of 2014 the total number of mobile subscribers was 4.9 million. The number of active users’ penetration rate was 119%, whilst total users penetration rate was 172%, which is higher than the average in EU countries.

In 2014 the number of AMC subscribers was 1.9 million, whilst the number of Internet subscribers was 0.23 million. The number of AMC broadband users is circa 0.23 million, out of which 61,600 (92% more than year 2013) are accessing the Internet broadband service via modems and USBs.

4.4.1 Key Investments

Investments by AMC are based on the companies’ assessments of the market, customer and community needs, and are mainly undertaken by the Commercial and the Technical Directorate. Investments have been in the following areas:

Network update  Company continued to expand the 3G Network. The 3G network NodeBs reached 325, providing 3G coverage for 95.5% of the population and 86.2% of the territory; and  The level of the 3G network HSPA+NodeBs of 21 and 42 Mbs reached 64%, which shows a general improvement.

Moreover the company did the following:

 Deployed a second Radio Network Controller (RNC);  Expanded the Packed Core to support the development of the 3G network;  Modernised the BSS Network; all legacy BSC2i were removed from the network. Traffic was pushed from the legacy MSCi-s to the new MSS/MGW-s. Within the framework of converting the network to all-IP, Multiprotocol Label Switching (MPLS) routers were implemented in two core sites (Lapraka and Kashari);  The legacy Prepaid platform was upgraded into a new technology with all prepaid customers being migrated across to the system;

Page 26 AMC Corporate Responsibility Report 2014

 The Policy and Charging Rules Function (PCRF) node was integrated into the company’s infrastructure. The platform is ready from the technical perspective to support four use cases, planned to be commercial live at the beginning of 2015.

4.5 Public Awareness

AMC offers safe and high quality products and services. It respects relevant national and international requirements regarding use of communication products and sale of headsets. The company goes beyond these requirements in communicating useful and practical information for the users of mobile telephony. In the year under review, it did the following:

 Used its own channels of social media to make many thousands of customers aware of the risk they face when navigating the Internet. Several topics of interest on a protected and responsible use of telephony and Internet were published in company’s website; and  Organized training and information sessions to inform its employees on a safer digital workplace and online experience. Employees were informed on technical and organizational security measures to protect data and participated in an internal awareness quiz about data protection. Information and legal framework of Internet safety and responsible use of Internet is also available in Company’s intranet.  AMC distributed informative brochures including the following: o “Life with our mobile phone” provides useful information on mobile phone etiquette, on how to avoid mobile phone theft; o “How does mobile telephony work” provides information to understand mobile telephony and answer public concerns such on issues such as Electromagnetic Fields and safety standards; and o “Mobile telephony and parenting” provides useful information for parents on how to advise their children on the safe usage of mobile telephony services.

These brochures are available also in their electronic version on the company’s website.

4.5.1 Products and Services

Teleconference A teleconference service is one of the services offered by the company to its business customers, who make extensive use of its products. This service will be extended in the coming years and will offer enterprises the opportunity for immediate teleconferencing practically from everywhere, through smartphones, tablets or laptops.

Fleet Management Service The AMC Fleet Management service is based on monitoring the location of vehicles with the use of a GPS satellite system transmitting information via the AMC 2G/3G network to the customer’s control centre and monitoring the information on a digital map.

The aim is the optimization of vehicle routes and the corresponding reduction of fuel consumption and carbon dioxide emissions.

Responsible use of products and services by minors The use of mobile phones is deployed for use by minors, upon authorization by parents. However, this might require continuous oversight by parents. Parents should be informed

Page 27 AMC Corporate Responsibility Report 2014

properly about mobile phone functions, allowing them to decide what they should permit their children to use.

In response to this, AMC has implemented a series of Policies and Procedures, which include:

 The company does not promote Adult Chatting services;  Company’s services (e.g. SMS Flirt) do not permit access, if the stated aged is below 18;  Collaboration with credible institutions, such as Children’s Right Centre in Albania and UNICEF; and  Raises awareness through distribution of several child targeted publications.

The company has developed a service for parents to provide an option to manage their children’s calls to value added service numbers. More specifically, it provides free of charge the service to block calls to added value services (some ranges of 0900 intended for adults). A customer can ask to block the specific range of numbers, simply by calling the AMC Customer Care Centre.

AMC launched an application named “E di”, which makes possible the control of the location and apps used by child using their parent’s phone. The service is implemented through DT partnership and is offered for iOS & Android smartphones.

Advice by Sales Personnel AMC Sales Representative advise customers about the risk of non-controlled Internet access by children. They explain some of the steps to follow on the Internet Browser and Security Option configurations when customers visit company shops.

Special Headsets AMC offers a mobile headset especially designed to be used by the elderly.

E-applications The company has been working expensively to offer to all its customers and mobile users in Albania practical and smart solutions. Some the main e-applications extensively used offered by the company are:

 Explore Albania; this mobile application offers the possibility to explore and get informed about various categories, e.g. tourist destinations, hotspots, trips, gastronomy, cities and hotels of the country;  Music Streaming-Deezer; is a platform to listen to music on demand with millions of songs and tunes available;  Social Video-Magisto; enables subscribers to edit and produce their own videos;  Cloud-Evernote Wunderlist; is offered with a 1 year free subscription for every new activation with the company. Apart from “cloud” storage, a service is offered with additional features which targets SME/SoHo subcribers to improve their performance;  Dropbox; helps to store, save and synchronize files and share them with others; and  Security-Lookout; is used to protect mobile devices from security threats.

4.5.2 Cooperation with Recognized Bodies

Since 2010, AMC has been cooperating with the Albanian Child Helpline Centre to support children and help them address different issues. The company has utilized its technology so that all subscribers have free access to “ALO 116” (the number of the helpline) to report

Page 28 AMC Corporate Responsibility Report 2014

child abuse. The Centre offers professional psychological help, information and referrals to the respective services according to the specifics of the case. The service is offered free 24 hours per day, 7 days a week. This service extends to parents, teachers, educators or individuals who show interest on issues related to, and for children. The Centre has been functioning for four years and has shown good results in advising and avoiding conflict related to child abuse.

ALO 116 communicates with children in a most difficult period of their life. We work to protect the well-being of the child, through phone counselling, referral and pro-active protection of the children’s rights. In 2014, 25,486 calls were made to ALO 116 counselling service.

AMC participates, via Deutsche Telekom, in the voluntary intervention called “CEO Coalition to make the Internet a better place for kids” for the Safe Navigation of Children and Young People on the Internet and in the ICT Coalition for the Safer Use of Connected Devices and Online Services by Children and Young People in the EU.

Together with other business operators the company contributed in the compilation of the Code of Conduct “On the Safe and Responsible Use of Electronic Communication Networks”. This Code aims to protection public and children in particular from risks associated with Internet access. AMC is also a signatory to this Code.

4.6 Responsible Marketing

AMC adheres to all applicable laws and regulations in relation to marketing and all marketing materials are reviewed carefully before being released.

Marketing and Communication activities are managed to be following structures:

 Corporate Affairs manages AMC's public policy and communications. This includes responsibility for government relations at every level, corporate responsibility, corporate sponsorships, media and public relations;  The Marketing Department is responsible for the promotion, the overall brand, sponsorship, promotion and advertising direction of AMC, as well as maintaining good industry analyst relations and embedding marketing excellence across the company; and  Products and Services are responsible for innovation, products and pricing across the company.

4.6.1 Responsible Marketing Practices

AMC introduces its products in the market in a simple and transparent way. All text and gestures, including slogans and, signage aim to be non-discriminatory and respectful in tone and meaning. To maintain control of the message transmitted the Marketing Department screens everything before introducing them into the market.

All communication is aimed to be clear, easy to understand by target groups. In addition, sales personnel within AMC shops assist customers in understanding the programmes and offers, and make relevant suggestions by guiding them to material available.

Operating in a dynamic sector involves frequent interaction with customers via different means, including SMS. The company utilises appropriate tools for data systems to exercise

Page 29 AMC Corporate Responsibility Report 2014

their right not to receive such communication. This can be done through a request sent to AMC offices or AMC shops, or simply by calling the company’s customer care centre.

In 2014, no case of non-compliance with the relevant legislation was reported.

4.7 Transparency on Pricing

The company communicates in a simple, clear and transparent way to that its products services and their prices are well-understood by all its customers. It complies with legal requirements and high standards set by the company itself. The company aims to have the tools used to make pricing information available compliant with what is required by law and publishes it in the company’s website, customer service lines, information brochures and leaflets, press, and other communications. AMC offers a detailed price breakdown bill for customers who want such information, which is available for paper based bills and electronic bills. Various cost control mechanisms are also available for the customers to control their phone bills.

Two of the most frequently used cost control services offered by the company are:

 Electronic bills, which offer an online bill management service via the web to check and monitor monthly expenses for post-paid subscriber; and  Check Balance, last call and expiry period for pre-paid subscribers can be checked via Interactive Voice Response and Unstructured Supplementary Service Data (IVR/USSD). Actual monthly consumption can be checked via SMS/USSD for post-paid customers.

Over the past few years, the company has reduced its prices. According to AEPC (Albanian Regulatory Authority), the mobile communications prices and mobile communication consumption per user in Albania today are much lower than the average across the EU.

Besides a significant improvement in the quality of service delivered, AMC has responded to customers’ demands for lower prices. Some examples of these cases implemented by the company in 2014 are:

 Prepaid packages "Vitamina" which offers up to a thousand minutes per month for 800 lek;  AMC Relaks offers 60 national/international minutes, 3,000 minutes towards all AMC numbers, 3,000 SMS within AMC network, and unlimited 3G Internet for 1,200 Lek/month;  Post-pay consumers were offered increased discounts on monthly fees and free usage, as well as bonus points for the traffic they generate. The bonus is used either to receive discounts in their bills or discounts in new headsets; and  AMC Traveller which enables all AMC subscribers to talk when roaming to many highly visited destinations with the same tariffs as if within the country, charging a connection fee of 100 Leke.

Pricing and charging issues are communicated with customers systematically, in a transparent way so the latter would have a clear briefing. Customers can control and/or receive information about their pricing through the following methods:

 By calling the AMC customer service centre;  By asking the personnel at the company shops;

Page 30 AMC Corporate Responsibility Report 2014

 By sending an SMS at the automatic information centres (outstanding service control); This informs customers on their expenditure, remaining free call time, SMS, MMS, MegaBytes (MB), until the end of the available billing period;  Through AMC Easy Menu “#100#”, as an alternative access tool; and  By sending a letter to the AMC billing section in Lapraka; and  By sending an email at [email protected];

Other cost control services include:

 Users of personal computers with Mobile Internet access via USB modems can be informed about their data usage and set maximum usage limits. Customers can also see records of their data usage;  “Cost Control” Service: Automatically updates subscribers with free SMS, when they have consumed 80% of their free embedded use of their programme (free talk time, messages or allowance in terms of ΜΒ);  “Check of remaining free usage” service: Informs subscribers with free SMS whenever they choose to, about the remaining free units in their programme;  Packages with additional MB for more Internet usage when needed;  Roaming Services: Roaming network expansion, reduced prices, and data limit programme; and  Multimedia Information Services: Blocking access to Multimedia Information Services Numbers from the subscribers is efficient, as in certain categories of those numbers, the subscriber can choose to block single destinations and direction (for Premium SMS Services).

In 2014, the company did not receive any fine or any other penalty for non-compliance with laws and regulations concerning the provision and use of products and services.

4.7.1 Equipment Safety Labelling

All equipment accompanying products and services, offered by AMC are certified and have mandatory marking and description required by national legislation. AMC does not market or sell any products or services that are subject of product bans in its markets or that key stakeholders or the public have called to be banned. In 2014, no non-compliance case of this nature was recorded.

AMC gives great importance to the procurement of products that are safe and meet national legislation requirements and comply with international standards in the mobile telephony sector. Materials of electronic and electrical equipment sold in AMC shops, carry all the necessary labelling (e.g. European Community) and satisfy all the regulations on electrical and electronic equipment. AMC asks its suppliers for the data concerning the specific absorption rate (SAR) indicator for appliances, which are available for customers.

4.8 Responsible Procurement and Supply Chain Management

AMC’s procurement strategy aims to constantly improve the effectiveness of its value chain by adhering to principles for responsible procurement. The procurement process in AMC is very dynamic with the participation of a large number of suppliers who offer a vast array of

Page 31 AMC Corporate Responsibility Report 2014

goods and services, and is an important part of the provision of a final product to the customer. They all affect the way the company operates and the company affect their way of operation too. This is why CR principles are incorporated in the Company’s Procurement Policy to provide orientation for the company’s suppliers. It streamlines with the DT Group Code of Conduct.

CR facts in the code of conduct We consider a Group-wide corporate culture characterized by honesty, ethics and personal responsibility to be a key factor of success. The Code of Conduct is established to strengthen this culture at the Group and give our employees clear guidance. The code specifies the conduct required in daily work activities and applies to all employees of the Telekom Group worldwide. It connects compliance with laws and regulations with our requirements for ethical behaviour and the values and convictions laid out in our Guiding Principles.

We regularly update the code to be in line with new requirements. We take changing legislation into account and put general conduct requirements into concrete terms with the help of specific policies. This means that everyone at the Telekom Group gets clear guidance for their conduct when dealing with customers, competitors, suppliers and other stakeholders. The code particularly emphasizes the responsible handling of information, avoidance of conflicts of interest and exemplary behaviour on the part of our managers.

4.8.1 Procurement Policy

The company has set up its Suppliers Code of Conduct, which include also principles for social and environmental standards and also for corporate governance, which describes all terms and regulation for conducting procurement in AMC, and also minimum CR standards the company expects from its suppliers. The key objective of this policy is to:

 Optimize the added value in terms of cost, quality and time;  Ensure Transparency; and  Comply with Deutsche Telekom “Global Procurement Policy”.

Specific Corporate Responsibility Clauses and Anticorruption closes are added to the tender requirement by the initiating department. They are also binding to all company’s suppliers and are included in the contract with all suppliers. In addition, all bidding suppliers by submitting their proposals are required to declare that they explicitly agree to adhere to the Company’s Code of Conduct, which codifies AMC will to work to be environmentally friendly and socially sensitive. The Suppliers Code of Conduct is published on the company’s website.

The contract that successful bidders are called to sign includes specific clauses on anti- corruption and confidentiality. AMC is examining the introduction of additional clauses, related to corporate responsibility performance issues, to the contract.

CR issues included in the procurement Policy

Freely Chosen Employment Labour Child Labour Avoidance Working Hours

Page 32 AMC Corporate Responsibility Report 2014

Terms & Payment Humane Treatment Non-Discrimination Freedom of Association Occupational Safety Working environment Health and Safety Physically Demanding Work Health & Safety Policy by the Suppliers Pollution Prevention and Resource Reduction Hazardous Substances, Wastewater and Solid Waste Environment Emissions Environmental Policy by the Suppliers Corruption, Extortion, or Embezzlement Disclosure of Information Ethics No Improper Advantage Protection of Intellectual Property

The company’s Procurement Policy does not make a distinction between local and non–local suppliers. However, as per common practice when the work can be done by local supplier, under the same conditions of quality and price, preference is given to them.

The company applies good standards for timely payment of its suppliers, as per each contract conditions with each supplier. In 2014, the average payment time for company suppliers, was 90 days.

4.8.2 Suppliers Evaluation

AMC active suppliers are evaluated on an annual basis. This process is conducted at OTE Group level for all OTE Group companies since 2010 and is coordinated by Process Improvement and International Process Management Coordination Department, OTE Group.

The evaluation of its most important suppliers’ and partners’ quality of goods and services delivered, and their commitment toward the protection of the environment, health and safety and corporate responsibility. This process leads to higher standards of products and services and motivates suppliers to improve their performance and their own corporate governance initiatives.

The suppliers to be evaluated are selected on the basis of mainly the purchase orders issued within a 12 months period. In 2014 the suppliers evaluated were selected based on the total purchase orders/invoices issued in the period 1/10/2012 to 30/9/2013.

Thus, all suppliers who had received orders above €2 million and all suppliers of important commodities (as defined by OTE Group, i.e. products/services which may have a strong impact on products and services offered to clients) with orders above €500,000 were evaluated. In addition, all suppliers that their products/services were related to OTE and

Page 33 AMC Corporate Responsibility Report 2014

COSMOTE certified management systems (i.e. management systems according to ISO 9001, ISO 14001, OHSAS 18001 etc.) were evaluated, along with some suppliers, not meeting the above selection criteria, that were identified by OTE Group Directors.

The evaluation process, run in 2014, covered 17 OTE Group suppliers and 22 local suppliers. The suppliers had to return a self-assessment sustainability questionnaire. In addition they were evaluated internally by the respective departments demanding/receiving the designated products and services. This process was coordinated by the OTE Group; the results of the evaluation are incorporated in the Group’s results and announced to all Group companies. The results and any consequent remediation measures to be adopted are then discussed by the Senior Management.

The five criteria used for their evaluation are:

 Company Assessment;  Product or Service (or Both) Overview;  Delivery Performance;  Supplier Relationship Management; and  Corporate Responsibility/Quality Management Systems.

4.9 Customer Service and Satisfaction

Customers are the most important stakeholder group, and the company’s make all efforts in understanding their wants and offers high quality, reliable products to satisfy all their expectations. The company promotes and makes significant effort for connected life and work. This is one goal of the AMC CR strategy with the company driving the development of making Albania more digitized every day.

The company provides easy to use tools for customers to present all their requests and feedback and process them in the shortest time possible. In addition, it continuously monitors the quality of its service and the opinion of its customers about the service they receive.

4.9.1 Complaints Management

AMC consistently works to improve its products and services by investing in modern networks, innovative products and services and consulting offers. AMC’s customer service also guarantees a high degree of availability and makes every effort to keep promises and deadlines.

The company’s aim is to have no dissatisfied customers at all. To achieve this, the company reviews every complaint and request coming from the subscribers. The customers can make a complaint using one of the following methods:

 By letter to the AMC offices;  E-mail sent to: [email protected];  Calls to Call Centres, calling 139, 144 or 165;  At AMC help desk by placing a written claim request; and  Personal contacts at the company’s sales points.

Page 34 AMC Corporate Responsibility Report 2014

The claim and request form is also available and can by downloaded from the company’s website.

AMC handles complaints that come from its customers on a regular basis, and gives them absolute priority. The response time regarding further activities necessary for the complaint's resolution is provided within two days. In the case of delays, the customer is informed as to the reasons of delay and is informed when their compliant will be resolved. The handling of complaints is followed up by a “Voice of Customer” system, which modifies the flows in the customer experience prospective.

In 2014, AMC received 830 written complaints, 2,019 e-mail complaints from its customers, and 4,235 via its call centres. 88.8% of these complaints were processed immediately in an average of 2.3 days, making a substantial improvement over the previous year. In 2014, the complaints were processed immediately in an average of 4.2 days.

Complaints Average Issues raised by resolved in Type of complaints Number days for the complaints short-time resolving (5 days)

Roaming charging, Data traveller, Complaints received Prepaid charging, 2,019 87.9% 2.7 by e-mail CUG service, proportionality of rate plan change. Voice charging national & international. Written complaints 830 90.0% 2.9 Delays on offer application for business customers. Delays on Complaints received offer/service 4,235 90.0% 1.5 by call centre activation, network coverage.

Total complaints 7,084 88.8% 2.3

4.9.2 Customers Survey

AMC systematically evaluates all customer feedback, so that it can develop products and services that meet customer expectations. To evaluate customer satisfaction and analyse feedback, the company conducts each year a number of surveys, the main ones being:

 International Customers Contact Analysis (ICCA), which is an outbound calls sms survey conducted every day that targets customers to evaluate their experience at customers contact points;  Analysis for unsatisfied replies through a detailed evaluation process; and  Public surveys, telephone interviews and dedicated sessions with customers.

Page 35 AMC Corporate Responsibility Report 2014

The most common way to conduct a customer satisfaction survey is via SMS, which is a practice widespread through the DT Group and used by AMC since 2012. The survey is managed by Response Tek, a well-known Canadian company. Its aim is to measure the customer satisfaction deriving from three main contact points with AMC (call centre, self- service 142 and shops).

Every day, a number of randomly selected subscribers receive an SMS, asking their opinion about the quality of service in one of the above-mentioned contact points. Subscribers reply for free, via one SMS, using a 1 to 5 ranking (1-lowest, 5-highest).

4.10 Data Security and Privacy

As society becomes more connected, people must have more confidence in the digital work and its services. AMC has put into place polices, rules and mechanism to safeguard customer data and assures its customers, sales partners, employees and shareholders on the security of the services and products it provides. They must be confident that all data and information, entrusted to the company, is processed purely for their intended purpose and are protected from its misuse.

AMC has in place the General Security Policy (GSP), which is part of the Deutsche Telekom Group Security Policies Harmonisation Project. The implementation of this policy will lead the implementation of the other Information Security policies that are created and implemented in AMC.

The aim of this DT Group Security Policies Harmonisation Project and of the company is to have Data Security and Privacy compliant with the requirements of ISO 27001 and 27002. This Information Security Management System is a systematic approach to managing sensitive company information so that it remains secure. It includes people, processes and IT systems by applying a risk management process. It is the best-known standard in providing requirements for an information security management system (ISMS).

Deutsche Telekom Data Protection Principles

Trust: Your trust in us is our first principle and leads us to continuously take measures of improvement to protect your personal data.

Transparency: We inform on our website and on demand, what personal information is used for what reason.

Responsibility: We take the responsibility to protect your personal data and clarify open questions and issues immediately.

Avoidance: We avoid collecting information for further purposes than contractual fulfilment. We only use information for other purposes as personal product consultancy with your explicit consent.

Page 36 AMC Corporate Responsibility Report 2014

AMC takes this issue very seriously and asks its employees to do the same, following the moto:

”Security in AMC is part of the business, because we sense it, and we take care of it”.

The main security management systems of the company are the following:

 AMC currently implements the European Security Standard ISO 2700: 2005, ETSI and 3GPP. These are the most comprehensive security management systems (ISMS) used today. It consists of policies and procedures that include all legal, physical and technical controls involved in an organization’s information risk management processes;  Applications meet Data Security Standards (DSS) (ISO 27001/2:2005) requirements and are done through: Web Application Firewalls (WAFs), Security Codes and Anti-virus Systems;  3G network infrastructure is implemented based on ISO27001/2 Security Standard;  Data transfer in AMC network equipment uses the company’s encrypted radio link signal; and  “Breaching tests” are frequent.

AMC provides advice and tips to all its subscribers and public for online safety by publishing information on the web. The information includes the following:

 Email and security;  Safety for children;  How to navigate safely online?  What can you do to protect your personal computer?  What can you do to secure your mobile device? and  The most important questions about storing your data.

4.10.1 Developments to Streamline with Deutsche Telekom security standards

The company has undertaken the following initiatives to streamline with Deutsche Telekom security standards:

Security Portal Security Portal is a web application that was created and managed by IS Office. This portal was created to publish all the information related to the Information Security Office, Physical Security Office and BCM.

Access Management System Access Management System is a dedicated tool that was created by IT and IS Office. As part of the implementation of the Access Control Policy, this system is used by HR, IS Office and all the AMC system administrators in order to manage the access of the users on the IT and Core systems.

Honeynet project This project is related to the installation of some secure devices on the AMC network (honeynet) in order to fight unauthorized access to systems and DT security standards were incorporated in AMC policies.

Page 37 AMC Corporate Responsibility Report 2014

4.11 Business Security Management

AMC has established a Business Continuity Management System (BCMS) to comply with the standards of ISO 22301. In 2014 substantial progress was made to ensure that all employees have the appropriate understanding of their roles and responsibilities related to the company’s Business Continuity programme.

The BCMS auditing for ISO22301 compliance by British Standards Institution will be conducted in 2015.

4.12 Achievements in 2014 and Goals for 2015

The results achieved in respect of the market place objectives for 2014, as published in 2013 CR Report and the targets for 2015 are given below:

Progress in Section in the Goals for 2014 Goals for 2015 2014 Report

Publish and distribute Print and distribute 2 2 types of informative types of informative booklets on Mobile 5.7 booklets on Mobile 100% Telephony & Telephony & Electromagnetic Field. Electromagnetic Field.

Continue our information programme on safe 5.7 use of mobile phones. 100% Publish one brochure/leaflet.

Handle 83% of Handle 85% of complaints related to complaints related to 5.7 customer service in 100% customer service in less less than 5 days. than 5 days.

Conduct a customer or Conduct a customer or public based survey on 100% 5.2, 5.4 public based survey on CR topics. CR topics.

Have the BCM system successfully certified by an independent auditor to comply with the ISO22301 compliance by British Standards Institution.

Page 38 AMC Corporate Responsibility Report 2014

5 Employees

5.1 Management Approach

AMC is one the largest companies in Albania. Employees are the foundation of AMC innovation and development, as well as the ones who provide customer service and implement innovative practices. Employees expect a healthy and safe working environment, fair promotion opportunities, promising career paths, and more importantly, respect and appreciation of their value. In view of that, AMC provides a safe, stable, and harmonious working environment to meet employee needs, and career development and employee care to improve their lives. It provides its employees training and focused instruction, to obtain and retain all necessary expertise required to assure quality service.

AMC is aware that when its people are engaged, they are more able to deliver better performance and enjoy greater job satisfaction. AMC has developed many activities, where its employees can be engaged, including the ones where they can voluntarily participate. In 2014, over 3,000 hours of training were invested to develop the company’s workforce and their safety.

The company’s employment policies framework is based on the principles of full respect for human rights, fair employment, non–discrimination, equal treatment for women and men, and prevention of child labour or forced labour.

The basic framework for the AMC Employee Relations policy comprises respect for human rights, fair labour practices, non-discrimination, equal treatment for men and women, and combating child or forced labour. The approach and guiding principle of the company for its people and the guiding principle is: “Best place to work and grow”.

The company’s HR department makes sure that qualified professional are hired to fill the jobs at the right time and at reasonable costs. The Human Resources Department is based on a well-structured model where roles and competencies are well-defined. The structure includes: Human Resources (HR) Training Unit, HR Recruitment Unit, HR Health and Employee Engagement Unit, HR Shared Services with other structures for effective management of the HR services. The Human Resources manager reports directly to company’s CEO and is part of AMC management team.

5.1.1 Key Achievement in 2014

The following key achievements in 2014 were recorded for the company with respect to staff management:

 Was successfully audited to comply with OHSAS 18001;  Marked another year without fatal accidents during working hours;  Reached 49% female in middle management positions and 52% female in upper and middle management position;  92% of the company employees completed the satisfaction survey and 93% of the employees who filled in the questionnaire were satisfied with the company; and  60% of the top management reporting directly to CEO are women.

Page 39 AMC Corporate Responsibility Report 2014

5.2 Employment

5.2.1 Workforce

Technological development helps to optimize costs and usage of personnel, increase competitiveness and performance. At the same time the company continuously introduces new hires to its workforce, who work to develop and widen the use of communication technology to its customers and society. With such development, the company counts 452 employees as of 31 December 2014.

Workforce Diversity at AMC in 2014

Type of employment Number % Full time 452 100% Part time 0 0% Employees with In-determinant Term 452 100% Contracts Gender Male 181 40% Female 271 60%

Age Under 30 112 25% Age 30-50 326 72% Over 50 14 3%

Region Ex-pat 8 1.8% Albanian 444 98.2%

Position Directors (CEO, Division Director) 5 1.1% Male 4 80% Female 1 20% Upper Level Managers 21 4.6% (Department/Office) Male 10 47.6% Female 11 52.4% Middle Level Managers (Head of 73 16.2% Section/Unit) Male 37 50.7% Female 36 49.3%

Page 40 AMC Corporate Responsibility Report 2014

AMC harnesses its employees’ diverse experiences and backgrounds to better understand the needs of its customers, drive innovation, and enhance employee engagement. The company’s culture creates an atmosphere where everyone is made to feel welcome, valued, respected and empowered.

No substantial structural changes occurred in 2014, and the very minor changes were also informed to the employees at an early stage. However, in every case the legal requirements are followed. Minimum notice period in this case is 30 days. The changes in company’s workforce are illustrated below.

Changes in Company's Workforce

Description Recruited

Gender No % Male 21 65.6% Female 11 34.4%

Age No % Under 30 19 59.4% Age 30 -50 13 40.6% Over 50 0 0%

We use our technology to enable employees to work together wherever they are in Albania and with our partners and associates. Listening to our people and encouraging them to share ideas helps us evolve and enhance the company.

The company offers same recruitment and carrier advancement opportunities to national and foreign citizens. However, for certain positions which require good knowledge of the Albanian language and local environment preference is given to local or national citizens. 69% of top management team and 100% of middle management team are Albanians.

AMC offers excellent employment opportunities for young people. 30% of its people fall into the age 18-30 years, and 60% of the new people employed by the company in 2014 fall into this age category.

AMC offers good employment opportunities to students and provides them internship programmes so they can gain real work experience and training on the job with valuable skills that help them perform better on their jobs or on their studies. The students were given the opportunity to apply their knowledge in a real working environment, to gain work experience, to be trained (on-the-job) and to develop skills that will help them perform better in the future.

In 2014, AMC participated in a number of carrier events which were either organized by universities and/or other prominent institutions to support young people in vocational and career planning (career events) and which also give them an opportunity to find a new job. The main events were the following:

Page 41 AMC Corporate Responsibility Report 2014

 Supported the establishment of the employment office in Tirana, managed by the Albanian Ministry of Labour Affairs.

5.2.2 Fair Employment Policy Framework

AMC does the utmost to ensure that is non-discriminatory and fair. The Employment Policy Framework complies with the followings:

 The national labour code and relevant regulatory framework which prohibits the use of child labour, and forced labour;  The company’s Code of Conduct and Employee on Labour Relations Policy which expressing recognize the basic right of freedom of association and the right to engage in collective bargaining, within the framework of national laws, and expressly prohibit unlawful discrimination or harassment, on the grounds of age, gender, religion, aptitude or in ancestry or sexual orientation;  AMC employee manual, which highlights principles and guides behaviour of the company’s employees; and  The United Nations Global Compact, which is signed by the company.

AMC operates in compliance with the Code of Conduct for the Protection of the Individual’s Rights to Privacy in the handling of Personal Data within the OTE Group. This has been developed to comply also with the existing national legal framework.

AMC holds personal documentation of employees only as long as necessary in relation to their employment and determining remuneration, and is compliant with the stipulations set forth in data privacy laws. No proceedings or investigations were launched against the company in this regard.

Despite the fact that AMC recognizes the basic right of freedom of association and the right to engage in collective bargaining within the framework of national laws and regulations, currently no contract has been part of any collective bargaining agreement.

5.2.3 Non–Discrimination, Equal Opportunity and Diversity

The company’s Code of Conduct includes basic rules of conduct, principles and values such as equality, respect for diversity, integrity, ethics, transparency and personal responsibility, which are adopted by the company in all its operations. It also includes issues such as non- discrimination based on gender, age, religion, ability, origin or sexual orientation.

The core principle regarding issues such as recruitment, wages, growth and employee development are characterized by meritocracy, transparency and non-discrimination.

All employees can report of seek for advice on discrimination issues at the two communication channels available by the company. These are either:

 “Ask Me”, which provides info on the Code of Conduct, Employee Policies and other regulation; or  “Tell Me”, which is a confidential channel on information where employees may report complaints about violations of law and company’s regulation, which are then addressed by the company.

Page 42 AMC Corporate Responsibility Report 2014

In 2014, 65 employee’s queries were made by through the “Ask Me” process, and none was related to discrimination issues. The company received no complaint through the “Tell Me” process.

Non-discriminatory remuneration At AMC there is no gender, origin or other forms of discrimination regarding the salary remuneration. As stated in the Employee Manual and Company Code of Conduct, a fair and equal pay for men and women is applicable within the company. Payment is subject to position, qualification, individual performance, market competitiveness, experience, years of employment within the company or the industry and local legal requirements.

In 2014, the lowest wage in the company was 105% higher than the legal lowest wage salary.

Parental Leave The company provides maternity leave for childbirth and parental leave for childcare for all its employees. Parental leave is considered and paid as working time and is available to working mothers or fathers, immediately after the end of maternity leave. The following are the general rules:

 Working one hour per day less for two years; or  Taking one year full parental leave;

Men are also entitled to take the above-mentioned parental leave, provided that their spouses have not taken advantage of the specific leave from their employer. In addition, men can take up to 4 months parental leave to take care of their children in the first six years of their child’s life.

Gender Diversity Gender diversity is respected at all company levels, including top and middle management positions. In 2014, this diversity was maintained, and the workforce was made of 60% women, the management (upper and middle management) was made of 52% women, Board of Directors was made of 20% women, and from those reporting directly to CEO 42% were women.

Nationality Diversity Over 9% of AMC employees are Albanians. The top management composition is made professionals from different countries of nationality such as Albania, Greece, Germany, and Macedonia.

The presentation of Albanian citizens and foreign nationals is given below:

Year 2011 Year 2012 Year 2013 Year 2014 AMC Structures Local Local Local Expat Local Local Local Expat

Supervisory Board 0 3 0 3 0 3 0 3

Board of Directors 0 5 0 5 0 5 0 5

Upper Management 16 9 18 16 18 7 13 8

Page 43 AMC Corporate Responsibility Report 2014

Interdepartmental 5 7 5 5 8 7 8 7 Committees

AMC employees have the right and opportunity of one-to-one counselling with staff in the Human Resources Department regarding any discrimination issue. In 2014 no discrimination cases were reported.

5.3 Health and Safety

Ensuring health and safety of its employees, partners and customers is a top priority for AMC. The Health and Safety issues are considered crucial for the successful and sustainable future of the company and have a direct impact on issues such as employee satisfaction, well-being, quality of work and the corporate culture. In this regard, AMC acts proactively and goes beyond the requirements of the Albanian legislation, and has voluntarily adopted and complies with international well-known standards,

Since 2012, AMC has implemented a Health and Safety Management System which is based on the international standard OHSAS 18001 for Occupational Health and Safety. This system and the Health and Safety Policy complies with Albanian national laws and regulations but also shapes a preventive culture for health and safety at work, to encourage, train and support employees’ involvement in improving health and safety.

5.3.1 Health and Safety Policy

AMC Health and Safety (H&S) policy is integrated in the company’s Health, Safety and Environment (HSE) Policy and is based on national legislation and a risk assessment conducted by the company’s H&S groups.

Responsible for the implementation of H&S, is the Health and Safety Committee at Work, which consists of elected representatives of employees company-wide vote. They meet every quarter with Management representatives to discuss issues and processes related to the improvement of Health and Safety at work. All employees have access to health and safety policy and health and safety documents.

Health and safety at work issues are also evaluated by employees through the Employee Satisfaction Survey, which is conducted every two years and focuses on issues related to health, such as mental/physical well-being and work-life balance. The results and findings of the survey form the basis for improvement actions within the company.

The company H&S policy is based on the following principles and systems:

 Compliance with all national legislative requirements;  Certification of all operations to comply with the requirements of OHSAS 18001;  Updating of Occupational Risk Assessments at least every three years and additionally, when conditions change with significant risk implications, or when new activities or services are introduced;  Have in place a comprehensive Health and Safety Committee and Team system, including employees from the base and from the management to develop proper consultation;

Page 44 AMC Corporate Responsibility Report 2014

 Systematic training for company employees in Occupational Health and Safety (OH&S) principles and practices, with additional specialist training for potentially hazardous work related to installation;  Comprehensive Accident–Incident Reporting system, maintained by the AMC Occupational H&S Team, covering event investigation, recommendations and statutory reporting;  Regular building evacuation and safety drills;  Provision of workshops, newsletters and Intranet articles on important health and well- being topics, throughout the year; and  Scheduled medical check–ups for all employees across the country every year, in order to develop the individual health files per employee and prevent potential health issues.

5.3.2 Health and Safety Performance in 2014

In 2014, the company put strong emphasis on the health and safety prevention through training, awareness activities and inspections which are conducted frequently by the company and independent licensed bodies. The following table shows the H&S performance for 2014.

Health and Safety Performance 2012 2013 2014

Fatalities Employee Fatalities 0 0 0 Contractors Fatalities 0 0 0 Work-Related Accidents (Employees) 0 0 0 Number of Employees Injured 0 0 0 Men 0 0 0 Women 0 0 0 Total 0 0 0 Injury rate¹ 0 0 0 Men 0 0 0 Women 0 0 0 Total 0 0 0 Occupational Diseases Rate² 0 0 0 Men 0 0 0 Women 0 0 0 Total 0 0 0 Lost Day Rate³ 0 0 0 Men 0 0 0 Women 0 0 0 Total

Page 45 AMC Corporate Responsibility Report 2014

Occupational Diseases Rate4 0 0 0 Notes 1 Injury rate = (Total number of injuries / Total hours worked) x 200,000. The factor 200,000 is derived from 50 working weeks for 40 hours per 100 employees. The data do not include minor (first–aid level) injuries. 2 Occupational diseases rate = (Total number of occupational diseases cases / Total hours worked) x 200,000. The factor 200,000 is derived from 50 working weeks for 40 hours per 100 employees. 3 Lost day rate = (Total number of lost days / Total hours worked) x 200,000. The factor 200,000 is derived from 50 working weeks for 40 hours per 100 employees. Lost days for OTE are calculated as calendar days, while lost days are calculated as scheduled work-days. Lost days count begins on the day of the injury or the next day, depending on the time of the day that the injury occurs. 4 Absentee rate = (Total number of missed absentee days / Total number of workforce days worked) x 25,000. The factor 25,000 is derived from 50 working weeks for 5 days per 100 employees.

5.3.3 Health and Safety Prevention and Awareness

In 2014 the company continued to give Health and Safety preventive measures. The development of the annual plan for H&S training is based on the general evaluation of the previous year’s actions, such as inspection result performed by the medical and technician staff, records of occupational accidents, and success of training programmes. The following measures took place in 2014:

Medical Exams including Physical Check–ups, Health Promotion Tests, Clinical Examinations A corporate programme for “Medical Examination” is established for many years. According to this programme annual medical examination is provided for all company employees as well as additional medical examinations for employees whose job is classified as difficult.

First Aid Training According to the “First Aid Training Programme”, training is provided for all employees involved in jobs classified as difficult (working at height, working with electricity, within warehouses, etc) and for all employees who are part of the Emergency Response Structure, (ERT). This includes first aid treatment of small skin injuries from paper cutting, scratches, skin allergies, blood pressure measurements mainly in young people and pregnant women “suffering” from low blood pressure, etc.

Physical support in case of medical issues All building in company headquarters and company owned shops are equipped with a First Aid Kit. There are 27 in total. In addition an Occupational Physician employed in the Human Resources Department is available to assist employees in case of health issues.

Occupational Hazard Studies On a yearly bases an Occupational Risk Assessment is performed by the H&S Team, following a standard methodology according to OHSAS 18001:2007 requirements.

Internal information campaigns Information campaigns were organized via the company’s intranet, internal e-mails, articles and a newsletter on Hepatitis B prevention and counselling (on the occasion of World Hepatitis Day), Smoking and Health (on occasion of World No Tobacco Day), Heart Treatment (on occasion of World Heart Day), Electronic Cigarettes (awareness session on

Page 46 AMC Corporate Responsibility Report 2014

electronic cigarettes), Snake Bite Instructions (awareness session to all employees working in the field) and Ergonomic Issues and Safe Body Posture.

Working safely at heights training programme It aims to ensure appropriate capabilities and knowledge is provided for performing work at height. Training of all new employees involved with working at height and an annual refresher training for all existing employees involved with working at height. This training includes complete education and hands-on application for security techniques whilst working at height, plus training in the use of specialised equipment. At the same time, a significant part of the training is about workers’ understanding of the risk-potential of an accident and the necessity for security measures. Training covers all areas necessary for safe working conditions on overhead pylons including demonstration of required Personal Protective Equipment (PPE), theoretical training for working at heights, hands-on, practical exercises for working at heights and rescue procedures.

Workplace Safety Inspections Regular inspections are conducted on company premises (usually monthly but also on a quarterly basis). Health and safety training is organized on a regular basis for employees particularly at risk and on yearly basis for many other employees.

In 2014 the following health and safety training programmes were conducted by the company:

Health & Safety training sessions Number of Employees Hours

Health & Safety topics in induction 36 (2 hours) 72 program

Emergency drills 438 (1 hours) 438

Fire Protection & Emergency Preparedness Training –Incident 4 (1 hours) 4 Response Directors

Tower climbing & working at height 11 (16 hours) 176

Working with electrical equipment & 19 (8 hours) 152 instalments

First Aid training 57 (7 hours) 399

Store security 73 (1 hours) 73

Occupational health & safety awareness 30 (1 hours) 30 sessions -

Total 649 1,344

Page 47 AMC Corporate Responsibility Report 2014

5.4 Employee Development

The aim of the company is to create a workplace, which is safe, fair and facilitates personal and professional development of its employees. The approach and guiding principle of the company for its people is: “Best place to work and grow”. The company supports the skills, experience and talent development and aims to create appropriate systems that its employees can thrive professionally. Employee development includes the following main activities:

 Performance management, as a basis of transparency and meritocracy and performance development for enhancing career opportunities within the company;  Learning, skilling and training programmes for groups of employees or individuals; and  Opportunities for international mobility within the DT Group, knowledge and best practices sharing.

5.4.1 Performance Management

The company uses a well-defined Performance Appraisal System, which is given in the Performance Appraisal Guidelines and is available to all employees through the company’s intranet. The performance of each employee is evaluated every year by their direct Supervisor based on pre-defined objectives. Through this system the strengths and areas for improvement is possible to be identified. All newly appointed managers attend prior to the annual performance appraisal process, a tailor-made training on how to assess the annual performance appraisal process, a tailor-made training on how to assess their own performance and create an individual development plan based on their needs. In 2014, a total of 129 new managers attended the training programme.

The AMC Performance Appraisal System is adapted to the vision, mission, values, high performance culture and specific needs of the company and its employees. It is designed with an emphasis on strengthening the excellence in the customer experience (Customer Experience Excellence) and is harmonized with the AMC Guiding Principles of its Code of Conduct. It is also based on the parameters of specific and measurable objectives, professional competencies and performance criteria, which are revised as often as necessary to reflect current standards in the telecommunications sector and the corresponding required expertise.

In 2014, all company employees were appraised and middle and top managers were trained in the usage of the Performance Appraisal System before the company appraisal took place. In addition, AMC Management’s executives (in alignment with the DT Group), also participated in the Performance and Potential Review process, which, besides evaluating executives’ performance, ascertains the degree of readiness to undertake more demanding duties in the future.

5.4.2 Performance Development

AMC places special emphasis to support and encourage its employees to stand out and develop, both personally and professionally in a continuously demanding and ever-changing working environment. To achieve this several Human Resources tools have been utilized.

To assess and make sure that the role content and of the profile of each employee is fully understood, the company uses the Job Families Model (JFM). JFM helps make for an efficient

Page 48 AMC Corporate Responsibility Report 2014

internal recruiting and career path. All roles in the JFM are analysed and described, taking into consideration the common functionality framework.

Emphasis was also given to the improvement of Employees Development Guide, a well- structured tool for supporting the role of managers as coaches (employees’ weaknesses and strengths, developmental goals, developmental action plan, measures and resources).

The recruitment process for internal and external candidates is based on the criteria of transparency and meritocracy. The internal recruitment includes internal announcement, interview and selection process and when necessary also testing.

5.4.3 Employee Training

Training is fundamental for the development, satisfaction and competition of the company’s employees. AMC Training programmes provide multiple benefits for employees and the company. They are carefully planned and properly implemented.

In 2014, the company conducted many training programmes as per below.

Training topics The company has carefully designed and implemented training. The main training topics included the following:

 Performance Appraisals: the training programme was developed and implemented at supporting the new policy on performance appraisal (PA) and target management processes;  Mentoring the Mentors: this training programme was designed for company’s directors, who were trained to:

 Develop a coaching style that can be taught to others.  Support a positive shift in team ability and confidence in asking for and gaining commitment.  Significantly increase the percentage of constructive feedback their team experiences for increased Leadership effectiveness.  Review the Coaching Platform to assess, coach, and monitor continuous improvement in the gaining commitment strategy.  Practice their Coaching style in a one-on-one.  Project Management Training: is designed for employees who participate in complex project to help them deliver smarter solutions on time and within budget.  Sales People Management Training: is designed for sales personnel increase capabilities of senior sales employees and sales managers to increase their team’s performance.  Negotiation Skills Training: develops tactics in a variety of negotiation situations and is designed for procurement and sales personnel.  Presentation Skills Training: aims to develop the confidence and capability to give good presentations, and to stand up in front of an audience and speak well, are also helpful competencies for self-development and social situations  ACCA & IFRS Training: this training was customized for employees working in finance and accounting;  CISCO Trainings: this training were designed for engineers who deliver on-site services for Cisco products; and

Page 49 AMC Corporate Responsibility Report 2014

 SAP Training: these training were offered to many employees working in different departments, who use SAP in their operations. The aim of the training was to drive greater proficiency across the company through the utilization of SAP solutions.

In 2014 special attention was paid to training and development of the company’s sales force. The figures below referr only to the training of sales force, excluding the training mentioned above where sales people might have participated.

A total of 1,714 training hours were devoted to Sales Employees (170) exclusively. All of them have participated in training modules on the tools they use every day, on new offers, products and services launched during the year, and how to successfully deal with promotional activities.

The following topics are specifically emphasized:

 Getting the best of Deezer, Evernote – products developed with international partners.  How to use the upgraded EPOS, SAP, SMPOS in the daily operations.  Introducing Vitamina – an AMC package dedicated to youth.

A number of training hours was offered to AMC partners as well. Some examples include:  Sales team improved the professional skills of the force that works for our network of distributors;  Sales team demonstrated the data entry process to our partners that are responsible for this process on behalf of AMC; and  The company briefed the promotional agencies about how the AMC offers could be delivered best.

Two international partners (Cognity, Printec) provided learning modules on products the company purchased from them.

5.5 Employee Benefits

Besides salary and other benefits provided by law, each year AMC offers its employees additional benefits, in order to help support the daily needs for themselves and their family, the balance between work and professional life. The main categories of the benefits are the following:

Employee Benefits

Health and Insurance

• Life insurance program for all employees • Yearly check-up • Physiotherapist in house (twice per week) • Free ORL and Audiogram medical visits • Wellbeing services • Gym benefits

Page 50 AMC Corporate Responsibility Report 2014

Products and Services

 Corporate mobile phones are available for all employees with preferential tariffs and have free monthly phone traffic based on position;  Preferential post-paid and pre-paid tariffs for employee family members; and  Reduced prices on headsets and accessories purchased through the company’s own shops.

At Work Benefits

 Partial refunding of lunch, served a catering company;   Flexible daily work attendance; and  Seniority Reward – Extra days of annual leave for those being in the company for 10 year or more.

Other Benefits

 Team event and internal championship and activities in order to balance employees’ professional and personal life (6x6 volleyball championship, bowling championship, ping pong championship, etc.);  Bus service for transportation of personnel, to and from the company offices in Lapraka and Kashar;  Access to various socio-cultural activities, through prize draw tickets; and

 Cooperation with various companies to ensure preferential treatment of employees and special discounts for products and services.

Family

• Summer camp for children of employees  A Christmas gift for all employees’ children up to the age of 12;  A special end of the year coupon to buy goods in different local stores;  Additional days of leave, in case of special needs; and  Flexible leave policy, attentive to special needs.

In principle, AMC grants the same benefits to all employees, with minor changes between management staff and non-management staff.

5.6 Internal Communications

Effective internal communication is crucial to achieve good performance for the company. AMC maintains a transparent, continuous and interactive communication with its employees using a range of tools to promote knowledge and providing employees with an opportunity to participate in different aspects of company activities.

In 2014, to inform its employees the company did the following:

Page 51 AMC Corporate Responsibility Report 2014

 Used its intranet for several postings and publications;  Sent Electronic briefings (e-mails) for corporate and other issues; some of the most important were the communication on Data Privacy Day, Guiding Principles Day, Code of Conduct, World Day of Safer Internet and the “revamped” brand;  Five internal awareness campaigns were promoted via the Intranet, including banners, thematic configuration of the home page elements and campaign–related content, also via posters, leaflets, brochures and other promotional items;  The detailed results of Pulse Surveys, were announced to all employees;  Two internal company events were organized;  One in-house volunteering activity was organized. The number of AMC employees participating in this event was 35 and 80 hours was spent in this activity; and  A call for “Bota Jone ti” to evaluate ideas on initiatives to support the environment or the people in need.

All our employees have access to documents concerning aspects of human rights that are relevant to their operations. The documents can be easily accessed through the company’s Intranet. These documents include the Employee Manual, Suppliers Code of Conduct, specific policies and guidelines per specific positions and the Labour Code.

Company policies and procedures related to anti-corruption are available to all employees through their publication on the Intranet.

5.7 Employee Engagement and Satisfaction

5.7.1 Employee Engagement

In today’s rapidly changing business environment, it becomes more difficult to motivate employees and ensure growth and productivity. AMC considers employee engagement vital for connecting the employees with the success of the company, by giving them the feeling of belonging to the company and its success, and creating a culture that supports and builds a powerful employer brand. This can be achieved by constantly informing employees about the strategic, technological and organizational changes made and to seek the understanding and active participation of employees.

AMC encourages their employees to communicate openly. Through various channels, they can choose such as meetings and presentations, workshops, internal memos and satisfaction surveys to raise their concerns. Specific e-mail addresses are available for employees to communicate as well. All these aim to create and maintain a work environment characterized by an open communication and dialogue culture.

5.7.2 Employee Satisfaction

AMC recognizes and gives special attention to the opinion of its employees. It frequently collects, analyses and monitors their opinion. The main tools used by the company to receive its employees’ opinion are the Employee Satisfaction Survey conducted every two years, and the Pulse Survey conducted annually. Surveys are also a reliable tool, amongst other inputs, for alerting management to decisions about potential changes, improvements and action plans needed. The results of employee surveys are communicated through the corporate Intranet and discussed in meetings held at the organizational unit level.

Page 52 AMC Corporate Responsibility Report 2014

Pulse survey

One of the most important indicators of employee satisfaction towards the company, is the feedback collected from the Pulse Survey regularly organized in DT Group level. AMC as one company in the DT Group has the highest participation level. 92% of AMC employees have participated in this survey and their satisfaction is consistently high. These results show that an upward trend over previous year. The employee satisfaction rate from the survey held in November 2014 was 93%.

Another component which relates to AMC employees awareness of being a big international group is significantly growing to 88%. Collaboration among colleagues through different functions, departments and companies is another positive development with 85% showing their collaboration efforts. Feedback from employees given in the surveys is always considered from the top management in order to identify and impact areas for improvement.

2014 Pulse Survey Data

Issues Results Employee Participation rate 92% Employee Satisfaction rate 93% Employer branding 95% Aware of DT Group 88% Collaboration with Others 85%

5.8 Achievements in 2014 and Goals for 2015

The results achieved in respect of the employees objectives for 2014, as published in 2013 CR Report and the targets for 2015 are given below:

Section in the Goals for 2014 Progress in 2014 Goals for 2015 Report

Conduct a pulse Conduct a pulse 100% 6.7.2 survey survey.

Continue Continue developing developing an an employee employee 6.6, 7.4 volunteering culture. 25% volunteering Organize 4 culture. Organize 3 volunteering actions. volunteering actions.

Page 53 AMC Corporate Responsibility Report 2014

15% of employees 15% of employees to to receive receive development 7.4 100% development training. training.

Introduce new team Print and distribute spirit activities for as informative employee benefits and 100% 6.6 leaflets/brochures on socializing and safety and security entertainment. for school pupils.

Page 54 AMC Corporate Responsibility Report 2014

6 Society

6.1 Management Approach

AMC considers itself an active member of society and which can contribute to its well-being in different ways. The company’s social activities are conducted to comply with its CR strategy and are based on two main pillars: a) Corporate Volunteering, supporting the company employees in their community volunteering activities; and b) Partnerships with various organizations to:

i. Support Children Welfare and Development. ii. Support Vulnerable Social Groups and People with Special Needs. iii. Provide Equal Access to Education and Information. iv. Alleviate Disasters.

AMC tries to make technology available to those groups of society without access to it. It pays special attention to identifying and helping marginalized groups and especially those with particular needs, offering its technology to fulfil their needs.

The company takes part in many social initiatives and cooperates with many organizations, aiming to improve the lives of many in the communities where it operates. Simultaneously, in order to improve the management of corporate responsibility, it systematically evolves internal mechanisms and processes of social contribution.

The key management mechanisms to administer social contribution activities are the following:

 The social contribution activities are designed and implemented by the Corporate Affairs Office with the direction and support of the CEO;  All sponsorships and donations approved by the company’s CEO are firstly reviewed by AMC Compliance Office for their compliance with the company’s regulations;  The feedback from stakeholders regarding social contribution is collected by Corporate Affairs Office, which provides the basis for new proposals, new initiatives or changes in the current CR program. This Office is also responsible for collecting all data, concerning the measurement of the programs’ impact on the society; and  The success or social commitment of it activities are evaluated using relevant Key Performance Indicators.

The company collaborates closely with other companies in the DT Group to share experiences and best practices across countries.

6.1.1 Achievement in 2014 Key achievements in 2014 included the following:

 Organized a communication campaign “Bota jone ti” to invite people to introduce ideas, Six projects from 100 people were selected; and  Organized an awareness campaign to clean the country's coastline.

Page 55 AMC Corporate Responsibility Report 2014

6.2 Social Products, Services and Offers

AMC seeks for ways to contribute to improving the quality of life of vulnerable social groups, people with disabilities, and more, through the use of new technologies. The provide special products and services for these target groups and support actions and programmes that make a contribution, through the use of telecommunication products and services.

6.2.1 People with Special Needs, the Elderly and Socially Vulnerably Groups

AMC makes substantial effort to ensure that people with special needs have access to technology and mobile communication services, enabling them to enjoy the benefits these services bring. It does this through special technology, services and discounts:

Special headsets AMC offers a mobile phone specially designed for the elderly and for people with sight problems at a very low price. These phones have been accessed by the elderly through AMC owned shops.

Special tariff plans The company provides 66% monthly fee discount to members of the Albanian Association of Blind People.

Voice message This service provides people with sight problems the ability to manage their messages easily. Via voice recognition technology, users are able to hear and answer their e-mails, by giving phonetic commands (free of charge), as well as hearing out loud emails in their inbox. At the same time, they can forward, or erase, messages.

6.2.2 Students

The company continues to offer students easy access to technology and various communication tools providing them tools for their development. The main ones are the following:

 Reduced communication expenses for students, with special offers and unique gifts. Students could choose among offers on What’s Up, all Cost Control plans and Mobile Internet tariff plans;  Broadband connection at very attractive price offers with discount. Many people have benefited from the company offers and discounts; and  Donation of computers and other technology equipment to schools and not for profit organization.

6.2.3 Public Helplines, Services and Offers

In 2014, AMC continued to offer free of charge calls to all its subscribers in emergencies through the use of public emergency short code.

Donation service through short codes

Page 56 AMC Corporate Responsibility Report 2014

In order to support institutions and not-for-profit organizations, AMC supports a 5 digits short code exclusively activated for charity contributions. The end user sends an SMS with a text and is charged for their donation from their own account. At the end of the period the money, is transferred to the beneficiary institution.

6.3 Social Contribution

AMC continued to promote and engage in social contribution activities in accordance with the needs of the communities where it operates. It has supported and cooperated with many organizations with experience in supporting children and people in need. Through these activities the company aims to fulfil its corporate social responsibilities as “good citizens” contributing to various solutions for the benefit of the communities and the country. The strategic area where AMC focuses its social contribution were:

 Children Welfare and Development;  Equal Access to Education and Information;  Equal Opportunities for Disadvantaged Groups; and  Alleviation from Consequences of Natural Disasters.

In 2014, AMC introduced a communication campaign “Bota jone ti” to invite people to introduce ideas on social projects which would then be financially supported by AMC. Everyone could send a simple application electronically in just a few minutes. The campaign was organized via various communication tools, electronic and written media. Around 100 applications came from all over Albania and were focused primarily at increasing green spaces and social inclusion of vulnerable groups. The 15 best project ideas were introduced for a final evaluation before a group of environmental experts, civil society and AMC`s representatives selected the winners. Each participant in the ceremony made a project presentation in front of the jury and other competitors. All ideas were published on the official website of AMC, where anyone could vote for their favourite project. The following six projects were selected to be implemented by AMC:

 Building a “A neighbourhood, a multifunctional park” which aims to turn a damaged space into a community park;  Building a sports field for “Muharrem Çollaku” high school in Pogradec;  Building of a sports site and a green area in Lushnje;  Building a Kids Playground on an eco-social farm in Shkodra, which also included people with special needs;  Development of a waste recycling and environmental education for teenagers at Bathore, Kamza; and  Rehabilitation of a two thousand square metres garden for students of "Vasil Sota" school in Fier and the community living nearby.

6.3.1 Supporting Children Welfare and Development

SMS of Love From the SMS’s sent during the 2014 New Year’s Eve celebration, part of the “SMS of Love Project”, AMC donated an echocardiograph machine to the Paediatric Hospital in Tirana. The new machine was designed to serve greater assess to the overall health of children from birth to 15 years of age. The Echocardiology Unit is responsible for the management of 3,000 patient visits a year, including children under treatment from neighbouring countries.

Page 57 AMC Corporate Responsibility Report 2014

6.3.2 Supporting Enable Equal Access to Education and Information

Supporting Public Institution with IT Equipment AMC donated sixty electronic devices with modern parameters for several educational and health institutions in the country. This initiative was in the framework of ongoing projects that AMC has undertaken through the years to help technological development and integration of these institutions. Specifically, the company donated:

 Ten new computers with high technological parameters and ten fax and telephone handsets for the “Agricultural University of Tirana”;  Six computers and eight fax and telephone handsets for the “National Museum”;  Ten computers to the “University Hospital Centre “Mother Theresa”, Tirana; and  Six computers for “28 Nentori” School in Lapraka to help the improvement of teaching conditions.

Scholarship Programme of the American Farm School of Thessalonica One Albanian student was awarded a full year scholarship to the American Farm School of Thessalonica in Greece.

Scholarship Programme of Business Academy University Two scholarships were awarded for two students studying at the Business Academy University, in Tirana, to attend the Fastip programme.

Scholarship Programme of Albanian Public Universities AMC offered 20 scholarships to university students, studying in Albanian Public Universities, with the condition that they maintain high academic results.

Internship Programme AMC cooperates with universities and supports undergraduate students to do their internships within AMC. These students work in different departments, relevant to their field of study for 3-4 weeks. In 2014, 20 students completed internships within AMC.

Conferences and Forums AMC supported the first international forum in Albania called “Smart City”, which took place in Durres. The forum aimed to gather and exchange ideas, knowledge, experience and international best practice, which will merge with the vision of smart cities, for a contemporary development.

AMC also supported the community of young entrepreneurs called “Startup Grind”, to organize monthly activities of young people with innovative ideas and investors, founders of the most successful companies in Albania. These are organized as forums to share with “Startup Grind” community their experiences and to discuss the right way to establishing a business in Albania.

Health Services In its effort to contribute to improved health services to social groups in need, AMC in collaboration with the Ministry of Health, provided to three public health clinics in remote areas of North Albania necessary medical equipment as well as an IT infrastructure to maintain a fully functional and detailed database of their patients, affording them the ability to connect in real time with more specialized hospitals in their region, in case of emergencies.

Page 58 AMC Corporate Responsibility Report 2014

6.3.3 Supporting Vulnerable Social Groups and People with Special Needs

End of Year Tour Noting that mobile telephone services reduced the feeling of isolation that the elderly often feel, AMC, on New Year’s Eve, provided the residents of the Tirana Elderly House and the people who visit frequently the Elderly Daily Centre in Tirana with free mobile headsets together with SIM cards and free talk time to enjoy the benefits of telecommunication.

Supporting Special Institutions AMC supported the initiative of the Downes Syndrome Albania Foundation, the first such organization that cares for children with Downes syndrome in Albania. It donated the whole ICT infrastructure – and the technical expertise needed – for the newly-established centre of the Foundation. It is thanks to this contribution that the specialized workers of this centre can consult the latest world developments and conduct their daily activities in a manner to benefit better its young patients. In addition AMC covered all the necessary therapeutic treatment needs for the children hosted by the Centre for a 6-month period. This was part of the on-line awareness campaign “#AMCDSA”, and was joined by hundreds of thousands of users of social networks by associating their posts with this hashtag.

In addition, AMC supported the same organization to organize the "Buddy Walk Tirana" with the subject "Come to have a friend beside you". The walk started at the Maternity Hospital "Queen Geraldine" and ended at the Youth Park. Awareness activities continued with a concert, barbecue and entertainment for children.

6.3.4 Promoting Art and Culture

German October AMC supported the seventh edition of the “German October” in Tirana, which included rock concerts and classical music, theatre and poetry and literature readings, exhibitions and many others.

Concerts AMC supported the event “Albania-Kosovo, 15 years later...”, an event organized fifteen years after the Exodus.

6.3.5 Supporting the Environment

Earth Day Photo Contest AMC developed an awareness campaign by addressing over 450,000 users on the social network Facebook. This campaign focused on the competition named “Earth Day 2014” with photos from Albanian environment and nature. Its main goal was to increase public awareness on environmental protection. The competition was organized on the official website of AMC on Facebook, during which 5 days were sent from AMC`s Facebook Friends page, many photos taken in Albania. In this contest were selected over 200 photos from the Albanian nature and in "Earth Day 2014" there were selected 10 winning photos that received the most likes by voting on official profile on Facebook. The winners are awarded with prices, such as AMC Green packages. Winning photos that received most "likes" were for different landscapes of Albania.

Green Ideas Contest

Page 59 AMC Corporate Responsibility Report 2014

In 2014 AMC supported “Partners Albania” in organizing a regional contest called Green Philanthropy, which aimed at engaging with local communities and interested parties in mitigating negative environmental effects.

The competition was open to all civil society organizations, social enterprises and business ventures that identified, choose, and later implemented innovative ideas for a greener environment. One of the winning project ideas was “Green Sight, Kala m’Kala” which aimed at promoting tourism through bicycle guides in the town of Shkodra, and which was financed by AMC.

Awareness campaign to clean the country's coastline Green Line and AMC launched an awareness campaign along the country’s coastline. The two week campaign called “Green Tour” aimed not only to raise awareness, but also to visit and enhance knowledge of the current situation of pollution in coastal areas.

Many roundtables were organized to promote the “Green Tour” campaign with local authorities, in order to get support and make a coordinated plan for beach cleaning. Thousands of volunteers participated in the beach cleaning actions in May 2014 along the entire Albanian coastline. 35 AMC employees joined this initiative as volunteers.

6.4 Achievements in 2014 and Goals for 2015

The results achieved in respect of the society objectives for 2014, as published in 2013 CR Report and the targets for 2015 are given below:

Progress in Section in the Goals for 2014 Goals for 2015 2014 Report

Offer scholarships to Support equipment 10 students studying 7.3.2 or rehabilitation of a 0% in Albanian universities health centre

Page 60 AMC Corporate Responsibility Report 2014

Offer job practices Offer job practices to to at least 20 at least 20 students 7.3.1 students studying studying in Albanian 100% in Albanian Universities. Universities.

Conduct an awareness campaign to support Conduct a children in need and competition for 100% 7.3.2 gather funds for innovative organizations that project/ideas. support children.

Financially support Financially support innovative green innovative green ideas 100% 7.3.5 ideas in the Green in the Green Awards. Awards and Green Contest. Provide internet access to students in at least 3 schools in remote areas Organize an awareness campaign to support children in need

7 Environment

7.1 Management Approach

AMC is aware that although companies in the telecommunication sectors are not generally considered to have a high environmental impact compared to other industries, those that have a leading role need to consider their environmental footprint in all operational activities and combine them with sustainable financial growth. Besides the company’s efforts toward an improvement of their environmental footprint, the Information and Communication Technologies offer numerous opportunities for other companies and sectors for better use of environment and energy sources.

The specific actions taken by AMC are therefore aimed at reducing its environmental footprint and providing technological solutions (products and services) to individuals, companies and sectors that not only improve productivity but in parallel lesson the environmental footprint and raise awareness for more responsibility toward environmental protection.

Page 61 AMC Corporate Responsibility Report 2014

An integrated environmental policy and management scheme has been formulated for all and is effective for AMC. It also includes an Environmental Management Systems (EMS) certified by an independent accredited institution according to ISO 14001:2004 standard.

Through the EMS that is in place, AMC analyses all activities, products and services with reference to applicable legislative requirements and their impact on the environment, and continuously strives to improve its environmental performance by setting goals, quantifying appropriate key performance indicators (KPIs) and taking cost–effective actions.

Since 2011 AMC has created and used its environmental brand “AMC Green”. AMC Green is the umbrella of all the company’s environmental activities and aligns with AMC’s long-term strategy for achieving environmental sustainability and incorporating it into the company’s everyday activities. The “AMC Green” concept relates to the efficient use of resources, reducing telecom equipment, optimizing equipment for minimizing use of energy and usage of telecommunication services in an environmentally friendly way.

Page 62 AMC Corporate Responsibility Report 2014

7.1.1 Environmental Policy

AMC is committed to protect the environment as stated in its integrated Quality, Health and Safety and Environment policy. This policy places the highest managerial priority on activities related to the preservation of the environment. This policy is revised every-year and considers the environmental potential and current environmental challenges.

The environmental policy is a set of principles that outlines the company’s mission to manage the environmental effects of its people, activities, and operations and helps to put its environmental commitments into practice. Recently, it has been included in the integrated management policy, which is detailed below.

AMC Quality, Health & Safety and Environmental Policy

We, at AMC, inspired by our VISΙON, MISSION and STRATEGIC PRIORITIES, strive to enhance our successful customer–oriented philosophy, our competitive positioning and the provision of technologically advanced products and services. As a responsible corporate citizen, we aim at delivering value to our stakeholders and believe that quality, health– safety and environment constitute crucial concerns embedded in our company’s culture. In this context, we expect our senior management to act as role models.

Aiming at Business Excellence, we therefore commit ourselves to:  Continually improving our operations and performance by setting, monitoring and reviewing our objectives with the intent to meet and, where possible, to exceed the expectations of our stakeholders;  Acting with foresight and comply with the requirements laid down by applicable legislation, or even exceeding these, where we can;  Require our personnel, and our contractors and suppliers, to actively participate in achieving our objectives, regarding the quality of our operations, occupational health & safety and environmental protection, by implementing all relevant regulations and programs adopted;  Strive to find innovative approaches for our operations, products and services, adopting preventive approaches to reduce our environmental impact & pollution, and avoid potential injury and ill health of our personnel, partners and the general public;  Keep the public, our personnel and our stakeholders informed on quality, environmental and occupational health & safety issues;  Voluntarily protect the public through the principles and recommendations laid down in the EMF policy, including transparency, information, participation and promotion of science; and  Fully comply with the requirements of our Integrated Management System and continuously improve its effectiveness.

Dimitrios Blatsios, Chief Executive Officer

7.1.2 Environmental Management

The management of environmental aspects is overseen by the CEO. To assist him a high level Steering Committee has been established in the framework of the Integrated Management System which is in place (Quality, Health and Safety, and Environment).

Page 63 AMC Corporate Responsibility Report 2014

The Integrated Systems Steering Committee comprises managers from departments whose operations have a large impact on the environment, and an Environmental Management Team, which comprises key experts dealing with environmental issues. Both, the Integrated Systems Steering Committee and the Environmental Management Team are strongly engaged to implement environmental programmes and coordinate the work of other employees (non-team members) to reach the targets and objectives set in advance.

The AMC Corporate Affairs Manager has been appointed as the Chairman of the Management System (EMS) Steering Committee, and managers of other departments serve as Environmental Committee members. The Committee is supported by the Environmental Management Team with members of relevant AMC organizational units.

The responsibilities of the Committee, with respect to the EMS, include, among others, the approval of EMS documentation including objectives, KPIs and targets set out as well as the environmental programmes to achieve these objectives/targets, EMS audit results, EMS performance results, customer and employee feedback/complaints, periodic reviews and follow up actions from previous management reviews of the EMS and the improvements deemed necessary to enhance its effectiveness.

Furthermore, members of the Environmental Management Team, monitor continuously the implementation of the environmental programmes, identifies the environmental aspects of the activities, and proposes remedial actions for improvement, and analyses the data needed to determine the environmental performance of the company.

AMC Environmental Management System

Management Systems Steering CEO Committee  Corporate Affairs Manager  Radio & Transmission Engineering Manager  Operations & Maintenance Manager Procurement & Logistics Manager  Human Resources Manager  Anyone deemed necessary Corporate Affair Office (depending on the issue considered)

Environmental Management Team CR Unit  Representatives from selected AMC Organisational Units

Page 64 AMC Corporate Responsibility Report 2014

7.1.3 Key Achievement in 2014

Highlights of the main environmental performance achievements for 2014 are as follows:

 Passed successfully in 2014 the external audit surveillance for the ISO 14001:2004 certification;  Participated in the DT group climate change strategy, adopted by the DT Board of Management in 2013. The decision adopted sets a reduction target for the DT group CO2 emissions of 20% by 2020., Despite the significant expansion of the OTE and COSMOTE Group network (Network Modernization, New LTE implementation etc.), it set as a first priority target, the transition to a more energy efficient network leading to CO2 emissions reduction. To this end, and aiming to contribute to the achievement of the DT adopted target, specific actions are planned and implemented on a year-to-year basis; and  Efforts to ensure that AMC activities are in full compliance with environmental legislation and minimize any associated fines as well as the number of non-monetary sanctions imposed have continued. No fines or non-monetary sanctions (related to the environment) have been imposed in 2014.

7.2 Priorities in Addressing Environmental Impacts of AMC Activities

The ISO 14001:2004 based environmental management system of AMC provides a good instrument to identify and control the company’s environmental impact and constantly aims to improve its environmental performance. It covers all necessary areas such as training, record management, inspections, objectives and policy.

As part of the planning process the company has examined all environmental aspects that can have a negative impact on the environment and has determined the aspect that are most significant and those that are less significant based on well-known criteria considered important in the telecommunication sector. Based on these, the company has designed programmes, which consist of an action plan, role and responsibilities, schedule for addressing these, and targets to aim for of identified environmental aspects.

During the last year, AMC re-evaluated the environmental impact of its activities by examining environmental impacts under three different scenarios in normal, abnormal and emergency situations. In this exercise AMC invited representatives from its customers and the community to participate aiming at both ensuring transparency and increasing environmental awareness among its major stakeholders.

The company has committed to address the following aspects, based on their significance to its operations. The performance of the implemented environmental programs further demonstrates AMC’s achievements in safeguarding the environment. In 2014, AMC introduced two new environmental programs to monitor the consumption of natural resources, i.e. fuel and water, in order to be able to set SMART targets for the following years.

Environmental Activity Included in the EMS Response Aspects

Page 65 AMC Corporate Responsibility Report 2014

Energy Yes 8.5.2

Mobile Network Technical Waste Yes 8.6.2

EMF No 8.7

Energy Yes 8.5.1 Support of Telecom Operation Hazardous Waste Yes 8.6.1

Energy Yes 8.5, 8.5.3

Office Waste (Paper) Yes 8.6.3

Offices, Shops, Waste Disposal Yes 8.6.3 Warehouses

Water No 8.8.1

Mobile Recycling No

Vehicles Energy No 8.5.2, 8.5.4

7.3 Telecommunication for the environment

Information and Communications Technology (ICT) has changed our society remarkably in the last few years. It is recognized that advances in ICT have changed the very concepts of global connectivity, community and capacity to learn. Although its effects on our everyday lives is obvious, they have some negative effect on the environment or definitely can have a better environmental performance and allow growth for many sectors of the economy.

Reports from the International Telecommunication Union (ITU), indicate that sources at the intersection of the ICT and the climate change fields have covered extensively the potential of ICT in the abatement of greenhouse gases (GHG) emissions and in the achievement of energy efficiency, their role in early warning and disaster risk management, and increasingly, their contribution to adaptation within vulnerable environments. These analyses suggest that, while emissions generated by the ICT sector represent between 2% and 3% of global emission, their positive effects on climate change mitigation, monitoring and adaptation hold a greater potential.

The ICT revolution is powering even more innovations than once imagined, leading to greater potential to cut GHG emissions, and a smaller ICT footprint. A “SMARTer 2020” study by the Global e-Sustainability Initiative (GeSI) estimated that:

 The footprint of the ICT sector is projected to rise to 1.27 Gt CO2 eg by 2020;

Page 66 AMC Corporate Responsibility Report 2014

 The abatement potential enabled through the use of ICT applications in different sectors of the economy is 7 times higher (9.1 Gt CO2 eq);  The exploitation of this potential could yield US $1.9 trillion in savings for consumers and businesses; and  29.5 million jobs would be created worldwide as a result.

Realizing the potential enabled by ICT products and services becomes imperative. As the goal of keeping global temperature increases below 2°C compared to pre-industrial levels, requires all countries to make an additional effort and cuts of 80-95% by 2050 by developed countries have been agreed. The European Union (EU) has set already as its target the reduction of GHG emissions by 20% in 2020, with a view to move to a further 30% decrease, as part of an agreed global effort. As of October 2014, the European Council endorsed a binding EU target of an at least 40% domestic reduction in GHG emissions by 2030 compared to 1990.

The ICT sector response to climate change has involved actions aimed at mitigating its effects (e.g. by driving down emissions in the sector, reducing emissions and fostering energy efficiency in other sectors), monitoring climatic trends (e.g. through ICT-enabled data capture, processing, presentation and dissemination) and adapting to its impacts (e.g. by helping to reduce the vulnerability of various sectors, strengthening networking, decision making and resource access for adaptation).

AMC has been active by undertaking and taking part in several initiatives for environment protection. Details for this are given in the following sub-chapters – Managing Energy Use and Addressing Climate Change, Improving Energy Efficiency and Reducing Emissions, Resource Use and Waste Management, Electromagnetic Field, Other Environmental Aspects of AMC Operations, Environmental Awareness Initiatives.

7.4 Managing Energy Use and Addressing Climate Change

The majority of the company’s energy needs come from operating its network infrastructure. In the interest of the customers, the company is constantly increasing network performance, which is, however, associated with increasingly higher energy needs. However, the company has in place environmental programmes that mitigate the negative impact its operations have on the environment.

AMC contribution in minimizing the environmental problems associated with energy use is done through the following approaches:  Monitor the use of energy consumption, especially in the network system;  Reduce energy consumption and optimize energy usage to cause less emission;  Raise awareness among employees to reduce energy consumption in and outside the office; and  Utilize technology by developing products and services that contribute to less energy consumption in other sectors.

7.4.1 Direct and indirect Greenhouse Gases Emissions

AMC recognises the importance of Climate Change impacts. The primary risks that AMC faces from climate change fall into the following categories:

Page 67 AMC Corporate Responsibility Report 2014

 Regulation risks related to increased energy costs resulting from any new climate change regulations on national and global levels. Such increases will affect almost all levels of operations at AMC, including building operations and supply chain costs.  Physical, operational and financial risks to the company’s telecommunications infrastructure resulting from extreme weather events associated with climate change. Damage to our infrastructure could also carry financial implications (for example. the need for additional cooling needs and energy consumption, or network interruption as result of floods, forest fire, etc.).  Reputation risks whose financial implications are related to a potential loss of market share as a result of consumers’ behaviour reaction against companies with inadequate policies as regards climate change.

AMC is committed to understanding and responsibly managing the impacts of climate change on its business, with consideration given to:  Assessing both climate change risks and opportunities at multi-levels across AMC, including the Environmental Steering Committee and the Environment team through the annual carbon footprint assessment.  Having BCM and emergency plans in dealing with events that can be influenced by climate change, such as extreme weather conditions.  Continuing to build on initiatives within Environmental Management System implementation, whereby “impacts” are reviewed to determine significance (“materiality”).

AMC has calculated the Green House Gas (GHG) emissions from its operations based on the methods described in the GHG Protocol developed by the World Business Council for Sustainable Development (WBCSD) and the World Resources Institute (WRI). In 2014 AMC total (direct and indirect) emissions of CO2, which were related to the company’s energy consumption for its offices, network and transportation, reached 2,536 tons. The CO2 emission sources for 2014 are presented below per sector and per activity. This corresponds to 10.7% decrease compared to last year. The decrease in the GHG emission is attributed to company’s mobile network, as result of optimization of connection to electricity grind and increase of base stations shared with other operators, and transportation, as result of decrease of company fleet, respectively by 8.9% for mobile network and by 27.5% for company’s vehicles fleet.

Page 68 AMC Corporate Responsibility Report 2014

AMC direct and indirect GHG emission in Year 2014

Transportation; 14.8%

Buildings; 5.3% Mobile Network; 79.9% - Mobile Networks includes BTS & BCS -Buildings include Offices, Warehouses, Data Centers and Own Shops - Transportation includes Company's Car Fleet and Business Flights

AMC direct and indirect GHG emission for Year 2014 (by source)

2,500 2,005.7 2,000

1,500

1,000

500 253.0 165.6 56.7 30.6 11.0 13.8 0 Flights Fleet Fleet diesel Fuel oil for Electricity Electricity Fuel oil for gasoline Heating & consumptionconsumption Heating & Diesel oil for in Mobile in Offices, Diesel oil for generators network Warehouse generators for network and Own buildings Shops

The direct GHG emissions (covers emissions due to fleet, generators used to supply electricity to network and generator used to supply electricity to buildings and for heating) were 2.330 tons of CO2 and the indirect GHG emission (covers emissions due to electricity consumption, and flight) were circa 206.6 CO2. “Business Air Travel” CO2 emission in 2014 was 165 tons CO2, with a travelled distance of 462,404 km.

Page 69 AMC Corporate Responsibility Report 2014

AMC direct GHG emission for year 2014

Transportation 13.3%

Buildings 0.6%

Mobile Network; 86.1%

AMC indirect GHG emission for year 2014

Mobile Network, 14.8% Offices and Buildings, 5.3%

International Business Travel, 79.9%

7.5 Improving Energy Efficiency and Reducing Emissions

7.5.1 Energy Consumption

Page 70 AMC Corporate Responsibility Report 2014

In 2014, the total energy consumption of AMC was 28.2 GWh (TJ 101.3), which only 0.7% less than previous year. In terms of primary energy source used, this energy consumption is equivalent to 19.5 GWh of direct energy consumption (or 70 TJ), all coming from renewable sources and 8.1 GWh of indirect energy consumption (or 29.1 TJ).

AMC monitors energy consumption in the offices and warehouses. Its buildings are supplied with electricity by a public company, and diesel which is used for generators, that are activated only when there is electricity shortage or improper power supply.

Currently, the electricity consumption is measured as a cluster that includes offices, data centres and warehouses in Lapraka and Kashar, and AMC own shop in Lapraka. In 2013, AMC electricity consumption for this grid was 5,129 MWh, which is 20% more than last the previous year. Monitoring, better management of the available resources and internal awareness campaigns have contributed to such decrease.

In 2014, the petrol consumption used for generators that supply energy to the buildings grid was 5.2 tons, representing a decrease of 60% compared with 2013. In 2014, there were less cases of power interruption from the public supply company, which caused automatic activation of generators.

In 2014, electricity consumption in AMC network was 14,303 MWh, which overall is 7.8% higher than last year and per base station 6.6 % higher than the previous year. This increase is mainly attributed to the extension of 3G network coverage, whose supporting equipment require more energy, and installation of new base stations to increase overall territory coverage.

When there is no electricity supply from the public supplier and when is power interruption, AMC network is supported by generators or other energy alternatives. The number of BTS-s working with 24 hours generators increased in 2014 remained the same as in 2103, and the number of base stations working with stand-by generators increased. In 2014, the diesel consumption of company’s generators used to supply AMC network was 752.2 tons, which is 11% less than last year, due to less power interruption.

Page 71 AMC Corporate Responsibility Report 2014

AMC Energy Consumption (in MWh)

14,303 13,269 12,013

9,020 8,582 2012 7,519 2013 4,713 2014 5,317 5,129

1,741 1,939 1,270 107 132 52

Road Transportation Electricity Electricity Energy Consumption Energy produced Consumption in Consumption in from Base station from office Mobile Network Building (offices, Generators generators warehouses and shops)

7.5.2 Monitoring Energy Consumption and Energy Conservation in the AMC Network

 AMC has been upgrading its technology network in different aspects to ensure optimal and fast communication for all its subscribers. Hence, it has increased the number of base stations to cover even the most remote areas in Albania. It provides excellent services to people living in these areas, and updates its network to offer maximum Internet speed through 3G technology. AMC provided Internet as fast as 42 Mbps to its subscribers.

The 3G network requires the installation of new equipment and devices however this has resulted in increased energy consumption by an order 50% more. In addition, 6 new Base stations have been installed. To overcome this problem and reduce energy consumption, the company made substantial efforts by doing the following:  Equipped additional Base Stations with stand by generators; and  Shared with other operators new base stations, and increased the number of BTSs shared with other operators.

AMC is committed to building a high-quality mobile network, while optimizing activities towards reducing of its footprint on the environment. Its territory coverage is 92.50%, whilst its population coverage is close to 100%. In the graph below, AMC energy supply sources are shown for the company’s network and the changes in optimization of energy sources it has achieved.

Page 72 AMC Corporate Responsibility Report 2014

Mobile Network Energy Supply 600

516 Number of BTS 504 510 487 497 500 Number of BTS connected 402 400 405 403 on the electricity grid 400 407 Number of BTS shared with other operators

300 Number of BTS working with 223 24h generators 215 207 214 222 200 Number of BTS with Flexi 167 158 systems

107 144 88 Number of standby 100 59 72 generators 38 18 7 8 8 4 7 5 2 5 2 Number of BTS working with 0 hybrid system 2010 2011 2012 2013 2014

7.5.3 Energy Consumption and Energy Conservation in AMC Buildings and Stores

AMC energy consumption in AMC buildings and stores represents 14% of total energy consumption by the company. As highlighted earlier in the buildings’ electricity grid are included AMC offices, warehouses and data centres installed inside the buildings in Lapraka and Kashar.

Specific measures and activities that have a significant effect in consumption and conservation of energy resources are the following:  AMC continued upgrading the capacities of its data centres to respond to the demand for data processing required by the customers and the upgraded network;  Continued awareness campaigns among its employees about the consequences of energy consumption to environment and methods as how to save energy while at the office such as switching off the lights and turning off computers when not in use;  Completed the remodelling of all own and distributors shops;  Additional energy upgraded were made in both company’s building in Lapraka and Kashar;

7.5.4 Energy Consumption and Energy Conservation in AMC Transport

Page 73 AMC Corporate Responsibility Report 2014

The maintenance and development of the telecommunication network and distribution of AMC products to sales point and spreading of customer service throughout the country are the main drivers of transport activity and the most used form of transportation for the company is by road. The company owns and uses a car fleet for this purpose. Plane transportation is used only when travelling to other countries, whist rail and other forms of transportation are not appropriate for Albania.

The daily transportation of the employees to and from the company headquarters is done by bus though a private licensed supplier contracted by AMC. Apart from this, the company uses its own mini-bus for the transportation of shift work employees working at AMC offices. On average circa 200 employees use company transportation every day.

In 2014, AMC operated a service fleet of 34 vehicles (all using unleaded gasoline), and a company fleet of 24 vehicles (2 diesel and 22 unleaded gasoline). The total fuel consumption on vehicles was 131,406 (21,473 litres diesel and 109,933 litres gasoline), which is 26.4% less than in 2014, attributed to reduction of service fleet vehicles.

The distance covered by the company car fleet in 2014 was 1.29 million kilometres, corresponding to 37.2% decrease compared to year 2014. The average vehicle consumption for company’s car fleet was 10.2 lt/100 km, which is 19% more than previous year, occurred as result of reduction of service fleet, which were of smaller engine compared to company fleet vehicles, which have bigger engine than service fleet vehicles.

AMC Vehicles Fleet

Fuel Consumption in 000 liters Distance in 000 km average fuel consumption lt/100km 198 200 2,067 2,050 190 1,771 1,773 178.2 180 1,288 169 170 167

160 9.54 10.2 150 9.43 9.58 8.69 140 131.4 130

120 2010 2011 2012 2013 2014

To reduce the environmental impact associated with transportation, the company took the following measures:  Reduced the size of service fleet;and

Page 74 AMC Corporate Responsibility Report 2014

 Rational use of cars through a vehicle sharing platform for vehicles used by company employees (non-managerial staff). This platform works via the Intranet and applies to all employees, except sales personnel, who due to the specification of their jobs use company cars everyday.

Business travel represents a significant transportation activity for AMC. With a view to reduce the relevant activity and the associated emissions, AMC teleconference facilities are utilized in AMC offices. Audio conferences facilities are available in most of the offices and are used by all company employees. Video conferences facilities are available in two points in the company’s headquarters in Lapraka.

In addition, the company strives to resolve by phone as many issues (technical issues, telephone directions, connection issues, etc.) as possible, thereby avoiding substantial amounts of CO2 emissions that would have been generated from transportation activities.

When company employees travel for business purposes to other countries, the company usually uses aerial service, and bus or train transportation when traveling in the city. In 2014, the distance covered by company employees for business purposes through aeroplane, bus and trains was 462,404 km (457,984 km by airplane, 1,600 km by bus, and 2,820 km by train).

7.6 Resource Use and Waste Management

To reduce waste the company uses the principle “Reduce – Reuse – Recycle”. In this context, the key principles of AMC policy regarding resource use and waste management are:  Monitoring of materials used and waste generated;  Reduced use of office paper  Paper recycling  Reuse of materials either internally or through collaboration with authorized waste management entities;  Special treatment of waste that contaminate the environment (e.g. electronic equipment, lead batteries, and materials that contain substances detrimental to the environment, i.e. oil lubricants); and  Enhancement of public awareness to increase participation in recycling practices.

It should be noted that since AMC is not manufacturing any products but provides telecommunications services and the use of materials is limited.

7.6.1 Hazardous Waste Management

Batteries In order to continuously provide telecommunication services to customers, in many base stations the company has installed batteries, which are activated when electricity supply problems occur. When the life of these batteries is complete they will need to be replaced. AMC considers the management of waste accumulators of great importance.

Accumulators provisionally stored in the warehouse upon de-commissioning are tested in order to determine their operational status. The accumulators categorized as faulty by the

Page 75 AMC Corporate Responsibility Report 2014

responsible engineer are then labelled and stored accordingly to the company’s store procedures and are triggered as ready for disposal.

AMC has signed a contract with a licensed batteries recycling company, which receives and recycles the accumulators ready for disposal. In 2014, 26 tons of batteries were withdrawn from service and all of them sent for recycling.

Lubricant Oils Lubricants are used in generators in Base Stations and seldom partially in office buildings. The company recognizes the fact that they might pollute landfill and water sources. Hence, considers their proper management of great importance, and for this reason it is considering the development of a programme for recycling of oil lubricants and filters.

For the management of waste lubricant oils AMC cooperates with a licensed company to collect all used oil lubricants and maintenance waste. The oil is then sent for the appropriate disposal and in the full amount of used lubricants replaced.

In 2014, 4.53 tonnes of lubricant oils and 2152 filters (1,076 air filters and 1,076 oil filters) have been collected with zero spills and forwarded for recycling.

7.6.2 Technical Waste Management

Telecommunication companies generate different types of waste to conduct their daily operations. The company is aware of the technical waste it generates and has developed a waste management programme to address these issues. This programme is upgraded continuously to address waste issues as much as possible. Currently the company manages the Electrical and Electronic Equipment Waste and in the future will address other type of technical waste.

Electrical and Electronic Equipment Waste Electrical and electronic equipment that is inadequate or out-dated is de-installed and provisionally stored in the Company’s warehouses and is either reused, whenever possible, or tested in order to determine equipment’s operational status. The equipment categorized as “not usable” by the responsible Engineers of the Operations & Maintenance Department are then labelled and stored accordingly by the responsible Warehouse Specialist. These are then sent for further processing (dismantling, recycling and disposal, according to the nature of the material). In 2014, withdrew from service 1.56 tons of equipment from this category and recycled 100% of them. This includes all types of technical waste according to "WEEE Telco Equipment & Computer Hardware" (electronic waste from ICT, devices, components, circuit boards, cables, PCs, mobile devices, etc.). It should be noted that the quantities forwarded vary with the lifetime and replacement schedules of the particular equipment.

Some of the hardware used at the Company’s offices (computers, printers, monitors, other peripherals) that is out-dated technology for telecommunication companies can still be used for other purposes. This equipment is either donated to schools, institutions and Non- Government Organizations. In 2014, 14 PCs were donated to public institutions or NGOs.

7.6.3 Paper Waste Management

Page 76 AMC Corporate Responsibility Report 2014

Paper is extensively used in all AMC operations at different levels, including AMC offices and AMC shops, for billing purposes (customer bills), promotion and communication campaigns, etc. Efforts to reduce papers in AMC offices and shops are on-going for many years. To achieve this, the company uses the “Reduce-Reuse-Recycle” principle, and conducts the following activities:  Offers paper saving services to company customers and employees, such as e-billing solutions. This is paperless electronic billing. All AMC employees in possession of corporate mobile numbers and AMC benefits use only e-bills as a billing service. This service is offered for free. Due to legal constraints, mobile operators must issue also a print hand-out to the customers;  Embeds a paper saving message in the official e-mail signature of all AMC employees, reminding them of the importance of environmental preservation;  Uses electronic media, whenever possible to disseminate information of brochures and reports. Since 2011 the CR Reports have been available only in electronic form;  The company uses an internal e-mail communication policy and e-archiving practice. The SAP programme used by the company minimizes the necessity for hard-copies;  The printers used are only centralized ones (one per each floor in each of the buildings);  The two–side starting from 2014 is set by default by the company to all its employees;  AMC offers prepaid customers the option to charge their accounts using e-vouchers. AMC also encourages customers to use the AMC Flexi e-voucher option system, and offers bonus airtime to many of those who do so; and  Conducts awareness campaigns to reduce paper usage and increase recycling of wasted paper.

AMC has signed an agreement with a local company and a local not-for-profit organization (NPO) to collect and recycle office paper from AMC offices in Lapraka and Kashar. AMC does not sell the recyclable paper, but provides it for free to the collecting NPO. The latter uses the proceedings in favour of Roma children. The AMC paper recycling programme is implemented in AMC offices and AMC shops only.

In 2014 office paper consumption was 4.20 tons, corresponding to 60% decrease from the previous year, and paper recycling reached 2.8 tons, or 61.9% of the paper consumption. The recycling ratio is 8.3% higher than the previous year.

Page 77 AMC Corporate Responsibility Report 2014

Office Paper Management

10.5 9.9 10.1 9.5 Office Paper Consumption

5 5.3 5.6 6 4.2 Office Paper 2.6 Recycled

2010 2011 2012 2013 2014

Bags Bags used in the company shops are important for protecting the environment. To overcome their effect to the environment, the company uses only paper bags and biodegradable bags, made of polyethylene with reverted technology. The bags if not recycled completely degrade after a few years. The company uses such bags within all of its shops.

7.7 Electromagnetic Field

Electromagnetic fields used in mobile communications have given rise to concerns among the general population about potential health risks during the last years. In mobile communications, this affects network build-out and the use of devices.

Over the past few years, recognized expert organizations such as the World Health Organization (WHO) and the International Commission on Non-Ionizing Radiation Protection (ICNIRP) have repeatedly reviewed the current limit values for mobile communications and confirmed that the use of mobile technology is safe based on current scientific knowledge. In addition, relevant legislative framework has been developed.

7.7.1 Following by Design the Precautionary Principle

The important benefits that mobile telephony offers to citizens in their everyday life, is the main reason leading to a dynamic growth of mobile telephony. At the same time however, AMC recognizes public concerns about potential consequences of electromagnetic radiation on health.

Page 78 AMC Corporate Responsibility Report 2014

Mobile phones transmit radio waves and create electromagnetic fields as they communicate with base stations. The strength of the radio wave depends on the specific mobile phone, as well as its distance to the base station. Wireless technologies are used for both phones and networks. The common denominator to all wireless technologies is that they send a weak signal, which decreases with distance. The stronger the electricity, the stronger the electromagnetic field, as soon as the electrical device is turned off, the electromagnetic field is also turned off. There is currently no scientific evidence that electromagnetic exposure from mobile site antennas is dangerous to health. Beside this the company does the following:  Ensuring product and service safety is important to AMC. AMC uses modern technology in our operations, (mostly Nokia Siemens technology network). AMC follows national and internationally accepted guidelines and the norms within the area of its operations. It follows the recommendations of national authorities, the International Commission for Non-Ionizing Radiation Protection (ICNIRP) Guidelines and the recommendations of World Health Organization (WHO). The levels of electromagnetic fields in all Base stations comply with the limits suggested by these organizations;  In accordance with national laws, radio wave signals emitted by the network are measured at each base station before acquiring the license, and which is within the legal limits. These measurements are taken once a year;  For every Base Station an electromagnetic study is conducted by specialized AMC personnel to ensure that company Base Stations operate within legal limits;  The company has supported programmes concerning EMF organized in collaboration with prominent national institutions; and  All phones sold in AMC own shops operate within electromagnetic field safety limits (expressed in Specific Absorption Rate – SAR units).

7.7.2 Monitoring the Levels of EMF Radiation

 In 2012-2013, AMC re-supported the project of the Polytechnic University of Tirana, Faculty of IT to measure the Electromagnetic Waves Emissions in critical spots high density populated areas, (such as hospitals, schools, etc). The measurements during this period were conducted in 50 Base Stations in Kavaje, Elbasan, Lac, Lezhe and Shkoder. The measurements for these sites showed that all AMC base stations are significantly lower than the limits recognized by the International Commission for Non-Ionizing Radiation Protection Guidelines. The results were published in the form of a report by Faculty of IT; and  In 2014, six additional ad hoc measurements were conducted by specialized scientific personnel of AMC, because of licensing application procedures requirements or public sensitivities regarding AMC antennas. Public exposure safety limits were not found to be exceeded (in points of free public access), in any of these measurements.

Communication with stakeholders AMC uses different means to communicate with customers and the public about how mobile telephony works. These include:  Frequent on site measurements conducted by the company, upon request by local communities, and continuous dialogue with them where Base Stations are installed. The radiation level, in all company Base Stations are significantly lower than national limits and internationally recognized limits. In 2014, six measurements were conducted by AMC specialized personnel, as results of requests coming from the community; and  Publication and distribution of booklets such as “The life with our mobile phone”, “How does mobile telephony work” and “Some questions regarding the mobile telephony

Page 79 AMC Corporate Responsibility Report 2014

antennas” were published. These booklets are available in AMC shops, downloadable from the company’s website and have been distributed to the general public at different events.

7.7.3 Informing Society and Employees

To address EMF public concern, AMC communicates with customers and the public through the followings:  In 2014, informative sessions were organized with communities who had concerns about EMF issue.  Publication and distribution of booklets such as “The life with our mobile phone”, “How does mobile telephony work” and “Some questions regarding the mobile telephony antennas” were published. These booklets are available in AMC shops, downloadable from the company’s website and have been distributed to the general public at different events; and  Briefings and presentations were also conducted by staff employees to students from various public schools and universities, as part of their introduction tour to AMC.

7.8 Other Environmental Aspects of AMC Operation

7.8.1 Water Consumption

Since telecommunications operations have no specific need for water use, AMC uses the water solely for the employees’ hygiene, watering of plants and cleaning of the workplaces. The water AMC consumes is acquired from the public water suppliers which are responsible not only for water supply but also for the sustainable uptake of water from the available water resource system.

Although the water doesn’t have a significant effect on the company’s activities, the company monitors water consumption and raises awareness among its employees on the rational use of water. Water consumption in 2014 in AMC buildings (Lapraka and Kashar) was 13,073 m3, which is 8.3% more than in the previous year.

Wastewater is directed through the sewerage to urban wastewater treatment plants and is treated in the municipality wastewater facilities. No planned or unplanned water discharges to the environment as well as no significant spills occurred during 2014.

Drinking water is purchased in bottles and/or churns by the company and is available for all company employees and guests.

7.8.2 Biodiversity

Page 80 AMC Corporate Responsibility Report 2014

The influence of AMC activities on biodiversity is insignificant and does not constitute a priority for action in comparison to other issues addressed in this chapter. Nevertheless, the company does the following:  It conducts an Environmental Impact Study for base stations, through which it identifies the potential impact of base station construction on the natural environment and strives to integrate base stations within the environment, with the least possible impact. All potential impacts are addressed in the Environmental Impact Assessment studies carried out and submitted for approval to the designated authorities as foreseen by national legislation in force.  Some of the base stations, which are necessary to ensure telecommunication services in Albania, are located outside populated areas. The sealed surface area per each station is a few square meters and when demolished, the land is put back as it was prior to the base station instalment, or upon the request of the land owner the concrete instalment is left for their use. Usually they are without permanent personnel and with limited transportation activities at the operational stage; and  It is committed to restore some of the negative repercussions the company offices and Base Stations might have on the ecosystem.

According to Law 8990, dated on 23.1.2003 “For environmental assessment” all mobile telephony base stations antennas in Albania have to be retroactively accompanied by an Environmental Impact Study approved by state authorities. The company complies with the laws and regulations and has not been subject of any fine for noncompliance with the regulation. All AMC Base stations are licensed by the relevant authorities as authorised by the National Ministry of Environment.

7.8.3 Visual Impact

Mobile telecommunication companies have relatively small visual impact on the environment compared to company’s operating in other industries. However, AMC takes this issue into consideration and to minimize this, it does the following:  Builds new Base Stations, which are smaller in size compared to the old construction design. The new Base Stations cover an area circa 50% smaller than the old ones; and  In many cases AMC locate Base Stations in installations, which it shares with other operations. Hence, one area serves more than one operation, reducing the overall visual impact of mobile telecommunication company.

The company built four new base stations (new sites and re-installed sites), with one being co-located with other companies. In total, more than 79 base stations were built as collocations will other companies.

Data 2010 2011 2012 2013 2014

New Base Stations 46 24 20 4 NA (number)

Collocations (number) 49 72 78 79 NA

7.8.4 Noise

The noise impact of AMC is insignificant, because:

Page 81 AMC Corporate Responsibility Report 2014

 Its buildings are located within urban areas (while generators are used only in cases of electricity failure);  Base Stations powered by electricity have practically zero noise emission;  Base Stations using generators are located in remote areas. In urban areas, AMC uses “Closed Type Power Generator Systems”, with noise level of 64dB at 7m distance. In rural areas, we use Open Type Power Generator Systems, with noise level of 105dB at 7m distance; and  In special cases where the noise level from generators should be reduced, AMC has installed noise isolation or hybrid systems, to reduces or eliminates the noise. Two hybrid systems have been installed so far.

7.9 Environmental Awareness Initiatives

7.9.1 Initiatives to Enhance AMC Employees Awareness

AMC aims to enhance awareness and increase engagement of its employees in initiatives toward the common objective of environmental protection. Its initiatives include the followings:  Celebrated the World Environment Day AMC organizing an internal event, to inform its employees on the achievement and commitment of the company towards environment;  Participated in WWF earth hour, and did the following: o Switched off the lights in AMC Headquarters for one hour; o Switched off the advertising installation on the roof of AMC building headquarters; o Announced the initiative in the company’s intranet, as well as inviting employees to extend the idea to their homes; and o Organized one cleaning action, in support of the national initiative “Let’s clean Albania in one day”, In the cleaning action voluntarily participated 35 AMC employees.

7.9.2 Initiatives to Enhance Public Awareness

To enhance public awareness towards protection of the environment AMC did the following activities:  Supported Partners Albania in the Green Ideas 2014 national competition, which aims to engage local communities and interested parties in mitigating negative environmental effects. The competition was open to all civil society organizations, social enterprises and business ventures that identify, choose, and later implement innovative ideas for a greener environment.  Supported the “Green Line” organization, which during May – June 2014 organized a series of environmental awareness meetings with local authorities and inhabitants in several areas of the country. The awareness meetings included efforts to collect detritus from beaches on the coast. AMC’s employees also joined this campaign and participated in collecting waste from the central streets of Durres (Albania’s second largest city).

7.10 Achievements in 2014 and Goals for 2015

The results achieved in respect of the environment objectives for 2014, as published in 2013 CR Report and the targets for 2015 are given below:

Page 82 AMC Corporate Responsibility Report 2014

Progress in Section in the Goals for 2014 Goals for 2015 2014 Report

Reduce energy Reduce energy consumption in the consumption in the buildings (consumption 0% 8.5.1 buildings per m² of building) by (consumption per m² 1%. of building) by 1%.

Reduce C02 emission Reduce C02 emission 8.4.1 from operations by 100% from operations by 2%. 2%.

Reduce office paper Reduce office paper 100% 8.6.3 consumption by 3%. consumption by 3%.

Increase office paper Increase office paper recycled as compared recycled as compared 8.6.3 to office paper 100% to office paper consumed by 3%. consumed by 3%.

Recycle 100% WEEE Recycle 100% WEEE 100% 8.6.2 materials withdrawn. materials withdrawn.

Recycle 100% Recycle 100% accumulators 100% 8.6.1 accumulators withdrawn. withdrawn.

Enhance green areas Enhance green areas 0% - by planting 100 by planting 100 trees. trees.

Recycle 100% oil- Recycle 100% oil- 100% 8.6.1 lubricants withdrawn lubricants withdrawn.

Page 83 AMC Corporate Responsibility Report 2014

8 Appendices

8.1 Summary of key performance indicators

The key financial, environmental and social performance indicators for AMC are presented in the table below. More information can be found in the relevant sections of the Report.

CR Performance 2011 2012 2013 2014

GRI Indicators

GRI Fully Reported Indicators 59 61 77 78

GRI Partially Reported Indicators 32 33 21 20

Financial Performance

Total Revenues (in million euro) 94.2 88.6 86.2 81.5

EBIDA (in million euro) 37.6 29.3 33.7 29.8

Social Security contribution (in million euro) 0.9 0.9 0.52 NA

Investments (million euro) 21 11.5 10.53 NA

Taxes paid (million euro) 15.6 9.7 8.73 NA

Marketplace

Customer base ( in millions) 1.92 1.9 2.06 2.06

Market share (based on customer base) 37% 34% 37% 39%

Internet subscribers (in millions) - 0.25 0.28 0.28

Broadband subscribers (in thousand) - - 22 230

Number of complaints received by customers 2,603 3,137 2,906 2,019

% of complaints resolved in a short time 89 88 83.1 90

Employees

Employees 475 487 471 452

% of females 55.7 55 59 60

% of females in management position 47 50 54 52.4

Number of employees trained (number) 347 88 58 -

Fatal Accidents (number) 0 0 0 0

Trainings hours (number) 14,256 2,018 3,966 1,344 Employee volunteering (person x times in 295 252 255 35 number)

Page 84 AMC Corporate Responsibility Report 2014

Internal coverage of open position (%) 20 36 35 35

Number of Complaints received regarding 0 0 0 0 Discrimination requiring corrective actions

Society

People Supported NA NA 1,485 1,000

Number of volunteering projects 5 5 4 1 Working hours invested in employee NA NA 3,300 80 volunteering activities Scholarships provided to students (in number) 17 20 14 -

Environment

Overall CO2 emission (from offices, 2,900 3,075 2,841 2,536 transportation, backbone networks, BTS) (ton)

Overall electricity consumption (from offices, 16.86 17.34 17.98 19.5 shops, backbone network, BTS) (GWh) Bio-degradable/paper bags purchased 327 70 14 - (thousand) Water consumption (m³) 6,700 7,700 12,071 13,073 Petrol consumption for heating and generators 788.0 888.7 858.6 858.6 used for BTSs (thousand litres)

Hazardous Waste (ton) - 51 12.7 26

Non–hazardous Technical Waste from Telecom - 5.91 0.74 1.56 Operations (ton) Fuel consumption from vehicles (thousand 167 198 178.2 131.4 litres) Road transportation distance (thousand km) 1,773 2,067 2,050 1,290

Office paper consumption (ton) 9.5 10.1 10.5 4.2

Office paper recycling (ton) 5.3 5.6 6 2.8

8.2 GRI G3.1 Index

Page 85 AMC Corporate Responsibility Report 2014

AMC Corporate Responsibility Report is based on the requirements defined by the Global Reporting Initiative (GRI). GRI has confirmed that the 2014 CR Report of AMC has been compiled according to the guidelines of GRI G3.1, B application level.

Profile Section on the Description Coverage Disclosure Report / Notes

1. Strategy and Analysis Statement from the most senior decision-maker 1.1 Fully 1 of the organization. Description of key impacts, risks, and 1.2 Fully 1, 4.1, 4.2, 4.5, 8.2 opportunities.

2. Organizational Profile

2.1 Name of the organization. Fully 2, 3.1 2.2 Primary brands, products, and/or services. Fully 3.3 Operational structure of the organization, 2.3 including main divisions, operating companies, Fully 3.2 subsidiaries, and joint ventures. 2.4 Location of organization's headquarters. Fully 2 Number of countries where the organization operates, and names of countries with either 2.5 Fully 3.1, 3.4 major operations or that are specifically relevant to the sustainability issues covered in the report. 2.6 Nature of ownership and legal form. Fully 3.1 Markets served (including geographic 2.7 breakdown, sectors served, and types of Fully 3.1, 3.4 customers/beneficiaries). 2.8 Scale of the reporting organization. Fully 2, 3.1, 3.4 Significant changes during the reporting period 2.9 Fully 3.6 regarding size, structure, or ownership. 2.10 Awards received in the reporting period. Fully 4.8 3. Report Parameters Reporting period (e.g., fiscal/calendar year) for 3.1 Fully 2 information provided. 3.2 Date of most recent previous report (if any). Fully 2 3.3 Reporting cycle (annual, biennial, etc.) Fully 2 Contact point for questions regarding the report 3.4 Fully 2 or its contents. 3.5 Process for defining report content. Fully 2, 4.1

Page 86 AMC Corporate Responsibility Report 2014

Boundary of the report (e.g., countries, divisions, subsidiaries, leased facilities, joint ventures, 3.6 Fully 2 suppliers). See GRI Boundary Protocol for further guidance. State any specific limitations on the scope or 3.7 boundary of the report (see completeness Fully 2 principle for explanation of scope). Basis for reporting on joint ventures, subsidiaries, leased facilities, outsourced 3.8 operations, and other entities that can Fully 2 significantly affect comparability from period to period and/or between organizations. Data measurement techniques and the bases of calculations, including assumptions and techniques underlying estimations applied to the 3.9 compilation of the Indicators and other Fully 2 information in the report. Explain any decisions not to apply, or to substantially diverge from, the GRI Indicator Protocols. Explanation of the effect of any re-statements of information provided in earlier reports, and the reasons for such re-statement (e.g., 3.10 Fully 2 mergers/acquisitions, change of base years/periods, nature of business, measurement methods). Significant changes from previous reporting 3.11 periods in the scope, boundary, or measurement Fully 2 methods applied in the report. Table identifying the location of the Standard 3.12 Fully 9.2 Disclosures in the report. Policy and current practice with regard to seeking 3.13 Fully 2 external assurance for the report.

4. Governance, Commitments, and Engagement

Governance structure of the organization, including committees under the highest 4.1 governance body responsible for specific tasks, Fully 4.2, 4.4 such as setting strategy or organizational oversight. Indicate whether the Chair of the highest 4.2 Fully 4.4 governance body is also an executive officer. For organizations that have a unitary board structure, state the number and gender of 4.3 Fully 4.4 members of the highest governance body that are independent and/or non-executive members. Mechanisms for shareholders and employees to 4.4 provide recommendations or direction to the Fully 4.2, 4.4, 6.2.3 highest governance body. Linkage between compensation for members of the highest governance body, senior managers, and executives (including departure 4.5 Fully 4.4, 6.2.2, 6.2.3 arrangements), and the organization's performance (including social and environmental performance).

Page 87 AMC Corporate Responsibility Report 2014

Processes in place for the highest governance 4.6 Fully 4.4, 4.5 body to ensure conflicts of interest are avoided. Process for determining the composition, qualifications, and expertise of the members of 4.7 the highest governance body and its committees, Fully 4.4, 6.2.3 including any consideration of gender and other indicators of diversity. Internally developed statements of mission or values, codes of conduct, and principles relevant 4.8 to economic, environmental, and social Fully 4,1, 4.5, 7.1, 8.1 performance and the status of their implementation. Procedures of the highest governance body for overseeing the organization's identification and management of economic, environmental, and 4.9 social performance, including relevant risks and Fully 4.2, 4.4 opportunities, and adherence or compliance with internationally agreed standards, codes of conduct, and principles. Processes for evaluating the highest governance body's own performance, particularly with 4.10 Fully 4.4 respect to economic, environmental, and social performance. Explanation of whether and how the 4.11 precautionary approach or principle is addressed Fully 4.8, 8.1, 8.7.1 by the organization. Externally developed economic, environmental, 4.12 and social charters, principles, or other initiatives Fully 4.8, 5.3.1 to which the organization subscribes or endorses. Memberships in associations (such as industry associations) and/or national/international advocacy organizations in which the organization: * Has positions in governance 4.13 Fully 4.8 bodies; * Participates in projects or committees; * Provides substantive funding beyond routine membership dues; or * Views membership as strategic. List of stakeholder groups engaged by the 4.14 Fully 4,.4, 6.2.3 organization. Basis for identification and selection of 4.15 Fully 4.7 stakeholders with whom to engage. Approaches to stakeholder engagement, 4.16 including frequency of engagement by type and Fully 4.7 by stakeholder group. Key topics and concerns that have been raised through stakeholder engagement, and how the 4.17 Fully 4.7 organization has responded to those key topics and concerns, including through its reporting. STANDARD DISCLOSURES PART II: Disclosures on Management Approach (DMAs)

DMA EC Disclosure on Management Approach EC

Economic performance Fully 1, 5.1, 5.12, 9.1 Aspects Market presence Fully 1, 5.1, 5.12, 9.1 Indirect economic impacts Fully 1, 4.1, 5.1, 5.12,

Page 88 AMC Corporate Responsibility Report 2014

9.1

DMA EN Disclosure on Management Approach EN

Materials Fully 8.1, 8.2, 8.6 Energy Fully 8.1, 8.2, 8.5 Water Fully 8.1, 8.2, 8.8.1 Biodiversity Fully 8.1, 8.2, 8.8.2 8.1, 8.2, 8.4, 8.5, Emissions, effluents and waste Fully Aspects 8.6, 8.8.1 8.1, 8.2, 8.5, 8.6, Products and services Fully 8.7, 8.8 Compliance Fully 8.1, 8.2, 8.7 8.1, 8.2, 8.4.1, Transport Fully 8.5.4 Overall Fully 8.1, 8.2

DMA LA Disclosure on Management Approach LA

Employment Fully 6.1, 6.2, 6.5 Labor/management relations Fully 6.1, 6.2.2 Occupational health and safety Fully 6.1, 6.3 Aspects Training and education Fully 6.1, 6.4 Diversity and equal opportunity Fully 6.1, 6.2, Equal remuneration for women and men Fully 6.1, 6.2.3

DMA HR Disclosure on Management Approach HR

Investment and procurement practices Fully 5.9

Non-discrimination Fully 6.1, 6.2.3 Freedom of association and collective bargaining Fully 5.9.1, 6.1, 6.2.2 Child labor Fully 5.9.1, 6.1, 6.2.2 Aspects Prevention of forced and compulsory labor Fully 5.9.1, 6.1, 6.2.2 Security practices Fully 5.11 Indigenous rights Not Not Relevant Assessment Fully 4.5, 6.4.2 Remediation Fully 6.1, 6.2.3

DMA SO Disclosure on Management Approach SO

Local communities Fully 4.1, 6.1, 7.3, 8.7 Corruption Fully 4.5

Aspects Public policy Fully 4.1, 4.5, 5.1, 5.3

Anti-competitive behavior Fully 5.1, 5.2, 5.3 Compliance Fully 4.5

DMA PR Disclosure on Management Approach PR

Page 89 AMC Corporate Responsibility Report 2014

Customer health and safety Fully 5.1, 5.8.1, 8.6, 8.7

Product and service labelling Fully 5.1, 5.8.1, 8.7 Aspects Marketing communications Fully 5.1, 5.7, 5.8.1 Customer privacy Fully 5.1, 5.11 5.1, 5.7, 5.8.1, Compliance Fully 5.11 STANDARD DISCLOSURES PART III: Performance Indicators

Economic

Economic performance Direct economic value generated and distributed, including revenues, operating costs, employee EC1 compensation, donations and other community Partially 3.4, 3.5, 9.1 investments, retained earnings, and payments to capital providers and governments. Financial implications and other risks and EC2 opportunities for the organization's activities due Fully 5.6.1, 8.3, 8.4 to climate change. Coverage of the organization's defined benefit EC3 Partially 6.5 plan obligations. Significant financial assistance received from EC4 Fully 3.1 government.

Market presence

Range of ratios of standard entry level wage by EC5 gender compared to local minimum wage at Fully 6.2.3 significant locations of operation. Policy, practices, and proportion of spending on EC6 locally-based suppliers at significant locations of Fully 5.9 operation. Procedures for local hiring and proportion of EC7 senior management hired from the local Fully 6.2.1, 6.2.3 community at significant locations of operation.

Indirect economic impacts

Development and impact of infrastructure investments and services provided primarily for 5.4, 5.5 5.6.1, 7.2, EC8 Fully public benefit through commercial, in-kind, or 7.3, 8.3, 8.7, 8.8.2 pro bono engagement. Understanding and describing significant indirect 5.4, 5.5 5.6.1, 7.2, EC9 economic impacts, including the extent of Fully 7.3 impacts.

Environmental

Materials

EN1 Materials used by weight or volume. Partially 8.6, 9.1 Percentage of materials used that are recycled EN2 Fully 8.6, 9.1 input materials.

Page 90 AMC Corporate Responsibility Report 2014

Energy

Direct energy consumption by primary energy EN3 Fully 8.5.1, 9.1 source. EN4 Indirect energy consumption by primary source. Fully 8.5, 9.1 Energy saved due to conservation and efficiency EN5 Fully 8.5.2, 8.5.3, 8.5.4 improvements. Initiatives to provide energy-efficient or renewable energy based products and services, EN6 Partially 8.3, 8.8.5 and reductions in energy requirements as a result of these initiatives. Initiatives to reduce indirect energy consumption EN7 Partially 8.4.1, 8.5, 8.6 and reductions achieved.

Water

EN8 Total water withdrawal by source. Fully 8.8.1 Water sources significantly affected by EN9 Fully 8.8.1 withdrawal of water. Percentage and total volume of water recycled EN10 Fully 8.8.1 and reused.

Biodiversity

Location and size of land owned, leased, managed in, or adjacent to, protected areas and EN11 Fully 8.8.2 areas of high biodiversity value outside protected areas. Description of significant impacts of activities, products, and services on biodiversity in EN12 Fully 8.8.2, 8.7.1, 8.7.2 protected areas and areas of high biodiversity value outside protected areas. EN13 Habitats protected or restored. Fully 8.8.2 Strategies, current actions, and future plans for EN14 Partially 8.8.2 managing impacts on biodiversity. Number of IUCN Red List species and national EN15 conservation list species with habitats in areas Not affected by operations, by level of extinction risk.

Emissions, effluents and waste

Total direct and indirect greenhouse gas EN16 Fully 8.4.1, 9.1 emissions by weight. Other relevant indirect greenhouse gas emissions EN17 Fully 8.4.1, 9.1 by weight. Initiatives to reduce greenhouse gas emissions EN18 Fully 8.5 and reductions achieved. Emissions of ozone-depleting substances by EN19 Not weight. NOx, SOx, and other significant air emissions by EN20 Not type and weight. EN21 Total water discharge by quality and destination. Fully 8.8.1, 9.1 Total weight of waste by type and disposal EN22 Partially 8.6, 9.1 method. EN23 Total number and volume of significant spills. Fully 8.6.1, 8.6.2, 8.8.1

Page 91 AMC Corporate Responsibility Report 2014

Weight of transported, imported, exported, or treated waste deemed hazardous under the EN24 terms of the Basel Convention Annex I, II, III, Fully 8.6.1, 8.6.2 and VIII, and percentage of transported waste shipped internationally. Identity, size, protected status, and biodiversity value of water bodies and related habitats EN25 Fully 8.8.1 significantly affected by the reporting organization's discharges of water and runoff.

Products and services

Initiatives to mitigate environmental impacts of EN26 products and services, and extent of impact Fully 8.5, 8.6, 8.8 mitigation. Percentage of products sold and their packaging EN27 Partially 8.8.3 materials that are reclaimed by category. Compliance Monetary value of significant fines and total number of non-monetary sanctions for non- EN28 Fully 8.1.3, 8.8.2 compliance with environmental laws and regulations.

Transport

Significant environmental impacts of transporting products and other goods and materials used for EN29 Fully 8.4.1, 8.5.4 the organization's operations, and transporting members of the workforce.

Overall

Total environmental protection expenditures and EN30 Not investments by type.

Social: Labor Practices and Decent Work

Employment

Total workforce by employment type, LA1 employment contract, and region, broken down Fully 6.2.1 by gender. Total number and rate of new employee hires LA2 and employee turnover by age group, gender, Fully 6.2.1, 6.2.3 and region. Benefits provided to full-time employees that are LA3 not provided to temporary or part-time Fully 6.5 employees, by major operations. Return to work and retention rates after parental LA15 Fully 6.2.3 leave, by gender.

Labour/Management relations

Percentage of employees covered by collective LA4 Fully 6.2.2 bargaining agreements. Minimum notice period(s) regarding significant LA5 operational changes, including whether it is Fully 6.2.1 specified in collective agreements.

Page 92 AMC Corporate Responsibility Report 2014

Occupational health and safety

Percentage of total workforce represented in formal joint management-worker health and LA6 Fully 6.3.1 safety committees that help monitor and advise on occupational health and safety programs. Rates of injury, occupational diseases, lost days, LA7 and absenteeism, and number of work-related Fully 6.3.2 fatalities by region and by gender. Education, training, counselling, prevention, and risk-control programs in place to assist workforce LA8 Fully 6.3.3 members, their families, or community members regarding serious diseases. Health and safety topics covered in formal LA9 Fully 6.3.2 agreements with trade unions. Training and education Average hours of training per year per employee LA10 Partially 6.4.3 by gender, and by employee category. Programs for skills management and lifelong learning that support the continued employability LA11 Partially 6.4 of employees and assist them in managing career endings. Percentage of employees receiving regular LA12 performance and career development reviews, Fully 6.4.2 by gender.

Diversity and equal opportunity

Composition of governance bodies and breakdown of employees per employee category LA13 Fully 4.4, 6.2.1, 6.2.3 according to gender, age group, minority group membership, and other indicators of diversity. Equal remuneration for women and men Ratio of basic salary and remuneration of women LA14 to men by employee category, by significant Fully 6.2.3 locations of operation. Social: Human Rights

Investment and procurement practices Percentage and total number of significant investment agreements and contracts that HR1 include clauses incorporating human rights Fully 5.9.1 concerns, or that have undergone human rights screening.

Percentage of significant suppliers, contractors HR2 and other business partners that have undergone Not human rights screening, and actions taken.

Total hours of employee training on policies and procedures concerning aspects of human rights HR3 Partially 6.6 that are relevant to operations, including the percentage of employees trained.

Page 93 AMC Corporate Responsibility Report 2014

Non-discrimination Total number of incidents of discrimination and HR4 Fully 6.2.3, 9.1 actions taken.

Freedom of association and collective bargaining

Operations and significant suppliers identified in which the right to exercise freedom of HR5 association and collective bargaining may be Fully 6.2.2 violated or at significant risk, and actions taken to support these rights. Child labor Operations and significant suppliers identified as having significant risk for incidents of child labor, HR6 Fully 5.9.1, 6.2.2 and measures taken to contribute to the effective abolition of child labor.

Forced and compulsory labor

Operations and significant suppliers identified as having significant risk for incidents of forced or HR7 compulsory labor, and measures to contribute to Fully 5.9.1, 6.2.2 the elimination of all forms of forced or compulsory labor.

Security practices

No training Percentage of security personnel trained in the addressing organization's policies or procedures concerning HR8 Fully specifically human aspects of human rights that are relevant to right issues took operations. place in 2014

Indigenous rights

Total number of incidents of violations involving HR9 Not Not Relevant rights of indigenous people and actions taken.

Assessment

Percentage and total number of operations that HR10 have been subject to human rights reviews Partially 4.5, 6.2.2 and/or impact assessments.

Remediation No grivance related Number of grievances related to human rights to human rights HR11 filed, addressed and resolved through formal Fully have been grievance mechanisms. submitted.

Social: Society

Local communities

Percentage of operations with implemented local 4.7, 6.3.1, 7.1, 7.3, SO1 community engagement, impact assessments, Fully 8.7 and development programs.

Page 94 AMC Corporate Responsibility Report 2014

Operations with significant potential or actual SO9 Fully 8.2, 8.7, 8.8.2 negative impacts on local communities. Prevention and mitigation measures implemented in operations with significant SO10 Partially 8.7, 8.8.2 potential or actual negative impacts on local communities. Corruption Percentage and total number of business units SO2 Fully 4.5 analyzed for risks related to corruption. Percentage of employees trained in SO3 organization's anti-corruption policies and Fully 4.5 procedures. Actions taken in response to incidents of SO4 Fully 4.5 corruption.

Public policy

Public policy positions and participation in public SO5 Fully 5.3.1 policy development and lobbying. Total value of financial and in-kind contributions SO6 to political parties, politicians, and related Fully 4.5 institutions by country.

Anti-competitive behavior

Total number of legal actions for anti-competitive SO7 behavior, anti-trust, and monopoly practices and Fully 5.3 their outcomes.

Compliance

Monetary value of significant fines and total 5.3, 5.7.1, 5.8.1, SO8 number of non-monetary sanctions for non- Fully 8.5.1 compliance with laws and regulations.

Social: Product Responsibility

Customer health and safety

Life cycle stages in which health and safety impacts of products and services are assessed PR1 for improvement, and percentage of significant Partially 5.8.1, 8.6, 8.7 products and services categories subject to such procedures. Total number of incidents of non-compliance with 5.8.1, 8.6, 8.7 regulations and voluntary codes concerning

PR2 health and safety impacts of products and Fully

services during their life cycle, by type of

outcomes.

Product and service labelling

Type of product and service information required by procedures, and percentage of significant PR3 Fully 5.8.1, 8.7 products and services subject to such information requirements.

Page 95 AMC Corporate Responsibility Report 2014

Total number of incidents of non-compliance with regulations and voluntary codes concerning PR4 Partially 5.8.1 product and service information and labeling, by type of outcomes. Practices related to customer satisfaction, PR5 including results of surveys measuring customer Fully 5.10 satisfaction.

Marketing communications

Programs for adherence to laws, standards, and voluntary codes related to marketing PR6 Fully 5.7, 5.8 communications, including advertising, promotion, and sponsorship. Total number of incidents of non-compliance with regulations and voluntary codes concerning PR7 marketing communications, including Fully 5.7 advertising, promotion, and sponsorship by type of outcomes. Customer privacy

Total number of substantiated complaints PR8 regarding breaches of customer privacy and Partially 5.11 losses of customer data.

Compliance

Monetary value of significant fines for non- PR9 compliance with laws and regulations concerning Fully 5.7 the provision and use of products and services. Telecom Sector Supplement Capital investment in telecommunication network IO1 Fully 3.1, 3.5, 9.1 infrastructure broken down by country/region. Net costs for service providers under the Universal Service Obligation when extending IO2 service to geographic locations and low-income Not groups, which are not profitable. Describe relevant legislative and regulatory mechanisms.

Health and Safety

Practices to ensure health and safety of field personnel involved in the installation, operation and maintenance of masts, base stations, laying cables and other outside plant. Related health IO3 Fully 6.3.3 and safety issues include working at heights, electric shock, exposure to EMF and radio frequency fields, and exposure to hazardous chemicals. Compliance with ICNIRP (International Commission on Non-Ionising Radiation IO4 Fully 5.8.1, 8.7.1, 8.7.2 Protection) standards on exposure to radiofrequency (RF) emissions from handsets Policies and practices with respect to Specific IO5 Fully 5.8.1 Absorption Rate (SAR) of handsets.

Infrastructure

Page 96 AMC Corporate Responsibility Report 2014

Policies and practices on the siting of masts and transmission sites including stakeholder consultation, site sharing, and initiatives to IO6 Partially 8.8.3 reduce visual impacts. Describe approach to evaluate consultations and quantify where possible. Number and percentage of stand-alone sites, IO7 Fully 8.8.3 shared sites, and sites on existing structures. Access to Telecommunication Products and Services: Bridging the Digital Divide Policies and practices to enable the deployment of telecommunications infrastructure and access PA1 Fully 3.4, 5.4, 5.5, 5.8 to telecommunications products and services in remote and low population density areas. Policies and practices to overcome barriers for access and use of PA2 telecommunication products and services Partially 5.8, 7.2.1, 7.2.2 including: language, culture, illiteracy, and lack of education, income, disabilities, and age. Policies and practices to ensure availability and reliability of PA3 telecommunications products and services and Fully 3.4, 5.4, 5.5 quantify, where possible, for specified time periods and locations of down time. Quantify the level of availability of PA4 telecommunications products and services in Fully 3.4, 5.4, 5.5 areas where the organisation operates. Number and types of telecommunication PA5 products and services provided to and used by Fully 3.3, 5.4, 5.5 low and no income sectors of the population. Programmes to provide and maintain PA6 telecommunication products and services in Fully 7.2.3, emergency situations and for disaster relief. Polices and practices to manage human rights PA7 issues relating to access and use of Partially 4.5 telecommunications products and services. Customer Relations Policies and practices to publicly communicate on PA8 Fully 8.7.3, EMF related issues. Total amount invested in programmes and PA9 Partially 8.7.3, activities in electromagnetic field research. PA10 Initiatives to ensure clarity of charges and tariffs. Fully 5.8 Initiatives to inform customers about product features and applications that will promote PA11 Partially 5.8 responsible, efficient, cost effective, and environmentally preferable use. Technology Applications

Resource Efficiency Provide examples of the resource efficiency of TA1 telecommunication products and services Partially 5.6.1 delivered.

Page 97 AMC Corporate Responsibility Report 2014

Provide examples of telecommunication TA2 products, services and applications that have the Fully 5.6.1 potential to replace physical objects Disclose any measures of transport and/or resource changes of customer use of the TA3 Fully 5.6.1, 8.5.1 telecommunication products and services listed above. Disclose any estimates of the rebound effect (indirect consequences) of customer use of the TA4 products and services listed above, and lessons Not learned for future development. This may include social consequences as well as environmental. Description of practices relating to intellectual TA5 Not property rights and open source technologies.

Page 98