69713 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

TRUE COPY 69713 OF THE ORIGINAL DOCUMENT Greek Government Gazette

December 31st 2018 SERIES B Issue No. 5916

Gazette Β' 464/19-4-2010). DECISIONS 9. The provisions of ministerial decision “Natural Gas Dec. No 1315/2018 Licensing Regulation” ref. no. 178065 (Government Gazette Β' 3430/17.08.2018, hereinafter referred to as For the granting of a Natural Gas Distribution “Licensing Regulation”). Network Operation License to the company 10. The Tariffs Regulation for Main Distribution Activity under the trade name “Gas Distribution of distribution networks in Attica, Thessaloniki, Company Thessaloniki-Thessaly S.A.” and the and other (Government Gazette Β' distinctive title “EDA THESS” 3067/26.09.2016) (hereinafter referred to as “Tariffs Regulation”). THE REGULATORY AUTHORITY FOR ENERGY 11. The RAE's Decision No 346/2016 on the Approval of Taking into consideration the following: the Tariff for the Charge of the Main Natural Gas 1. The provisions of Law 4001/2011 “For the Distribution Activity on Thessaloniki Distribution Network operation of the Energy Markets of Electricity and (Government Gazette Β' 3490/31.10.2016). Natural Gas, for Research, Production and transmission 12. The RAE's Decision No 347/2016 on the Approval of networks of Hydrocarbons and other arrangements” the Tariff for the Charge of the Main Natural Gas (Government Gazette A’179/22.08.2011), as amended Distribution Activity on Thessaly distribution network and in force (hereinafter referred to as “the Law”), and (Government Gazette Β'3537/03.11.2016). especially articles 80 to 80C thereof. 13. The RAE's Decision No 589/2016 on the "Approval 2. The provisions of Directive 2009/73/ΕC “On the of the Natural Gas Distribution Network Operation Code common rules for the internal market in natural gas in accordance with article 80, paragraph 8 of the Law and repealing Directive 2003/55/EC”. 4001/2011” (Government Gazette Β' 487/20.02.2017, 3. The provisions of Directive 2009/73/ΕC “On the hereinafter referred to as “Natural Gas Distribution common rules for the internal market in natural gas Network Operation Code ” or the “Code”), as amended and repealing Directive 2003/55/EC”. by RAE’s decisions no 702/2017 (Government Gazette Β' 4. The provisions of Law 4336/2015 “Retirement 3221/14.09.2017), 298/2018 (Government Gazette Β' provisions -Ratification of the Draft Financial Assistance 1507/02.05.2018) and 642/2018 (Government Gazette Β' Facility Agreement by the European Stability 3334/10.08.2018) and in force. Mechanism and legislative amendments for the 14. The RAE's Decision No 643/2018 on “Framework implementation of the financing agreement” for the Development of Remote Distribution Networks (Government Gazette Α' 94/2015). using Compressed / Liquefied Natural Gas” (Government 5. The provisions of Law 4513/2018 “Energy Gazette Β' 3334/10.08.2018). Communities and other provisions” (Government 15. The provisions of Law 2364/1995 “Establishment of Gazette Α' 9/18.01.2018), and especially article 24 the Energy Audit and Planning Body. Import, thereof. transportation, trading and distribution of natural gas 6. The provisions of Law 4546/2018 “Incorporation of and other provisions” (Government Gazette Directive 2014/89 / EU into Greek national law “on Α'252/06.12.1995). establishing a framework for maritime spatial 16. The Ministerial Decision no. Δ1/Γ/Φ7/11819/2000 planning” and other provisions” (Government (Government Gazette Β' 1086/31/08/2000) on the Gazette Α' 101/12.06.2018) and especially articles 40 granting of the distribution license of natural gas to “Gas and 47 thereof. Supply Company (EPA)of Thessaloniki SA”. 7. The 2017-2022 National Natural Gas Market 17. The Ministerial Decision no. Δ1/Γ/Φ7/11818/2000 Roadmap, as approved by the Decision no. 78/2018 of (Government Gazette Β'1087/31/08/2000) on the the Government Council for Economic Policy granting of the distribution a license of natural gas to (Government Gazette Β' 59/18.01.2018). “Gas Supply Company (EPA) of Thessaly SA”. 8. The provisions of ministerial decision Δ1/Α/5815 18. The Applications with RAE Ref. No. Ι- “Natural gas licensing regulation” (Government 219565/31.03.2017 and Ι-219571/31.03.2017 of the

69714 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 company under the trade name “GAS DISTRIBUTION 234999/04.04.2018, Ι-5555916234997/04.04.2018,1809/21.05.2018 Ι- COMPANY THESSALONIKI – THESSALY S.A.” and 234998/04.04.2018, Ι-234996/04.04.2018, Ι- distinctive title “EDA THESS S.A.” (hereinafter referred 234971/04.04.2018, Ι-234970/04.04.2018, Ι- to as the “Applicant”) for granting the Natural Gas 235018/04.04.2018, Ι-235003/04.04.2018, Ι- Distribution License & the Natural Gas Distribution 235006/04.04.2018 , Ι-235064/05.04.2018, Ι- Network Operation License, respectively. 235039/05.04.2018, Ι-235029/05.04.2018, Ι- 19. The publications of the Applicant dated 235164/12.04.2018, Ι-235350/17.04.2018 and 11.04.2017 in the newspapers “LOGOS”, “TYPOS Ι-235353/17.04.2018. THESSALONIKIS”, “ELEFTHERIA” and “DIMOKRATIA” 31. The document of RAE with ref. No. 0- (RΑΕ ref. no. Ι- 220094/11.04.2017). 71748/02.05.2018 with which the comments submitted 20. The document with RAE ref. No. Ο- to the public consultation were forwarded to the 68336/10.07.2017 with which RAE requested additional Applicant, as well as the document of the applicant with information and clarifications on the already submitted RΑΕ ref. no. Ι-236461/08.05.2018 with its views on these supporting documents. comments. 21. The document with RAE ref. No. Ι- 32. The documents of the Applicant with RΑΕ ref. no. Ι- 224173/18.07.2017 with which the Applicant requested 241791/28.06.2018 and Ι-244661/30.08.2018 with the an extension on the date of submission of the description of the current Distribution Network by the additional information and clarifications. end of 2017. 22. The document with RAE ref. No. Ο- 33. The document of RAE with ref. no. O- 68589/26.07.2017 with which RAE granted the 73244/7.9.2018 with subject “Update of the extension. applications’ data submitted to the Authority with RAE 23. The document of the Applicant with RAE ref. No. Ι- Ref. no. I-219565 / 31.3.2018 and I-219571 / 31.3.2018, 226824/29.09.2017 with the additional information in accordance with the new Natural Gas Licensing and clarifications. Regulation (Government Gazette Β' 3430/17.8.2018)”. 24. The document with RΑΕ ref. no. 0- 34. The documents with RAE ref. no. Ι- 69619/30.10.2017 with which RAE requested additional 243024/17.07.2018, Ι-243120/243120/18.07.2018, 0- information and clarifications on the already submitted 72703/18.07.2018, 0-72718/19.07.2018, Ι- supporting documents. 243245/20.07.2018, Ι-243336/23.07.2018, Ι- 25. The document of the Applicant with RΑΕ ref. No. Ι- 243354/23.07.2018, 0-72824/27.07.2018, Ι- 228144/02.11.2017 with subject “Submission of 243765/01.08.2018, 0-73034/21.08.2018, 0- Development Program2018 – 2022”. 73036/22.08.2018, Ι-244437/22.08.2018, I- 26. The documents of the Applicant with ref. no. RAE 244871/04.09.2018, I-244848/04.09.2018, 0- Ι-228361/07.11.2017, Ι-229296/01.12.2017, Ι- 73215/06.09.2018, Ι-244990/06.09.2018, I- 229341/04.12.2017, Ι-229793/12.12.2017, Ι- 244975/06.09.2018, I-244974/06.09.2018, 0- 229885/13.12.2017 and Ι-234145/20.03.2018, Ι- 73207/06.09.2018, I-245011/07.09.2018, Ι- 234137/20.03.2018 with additional details on the 245014/07.09.2018, I-245303/11.09.2018, Ι- Application. 245439/13.09.2018, Ι-245557/14.09.2018, Ι- 27. The document with RΑΕ ref. no. 0- 245895/20.09.2018, Ι-246022/24.09.2018, Ι- 71128/20.03.2018 with which RAE provides guidance to 245988/24.09.2018, Ι-246692/03.10.2018, Ι- the Applicant for various regulatory issues and asks for 247131/12.10.2018 concerning the correspondence of further clarifications on the documents that have the Applicant with RAE regarding the submission of already been submitted. additional documents for the Application. 28. The document of the Applicant with RΑΕ ref. no. Ι- 35. The supplementary document of the Applicant with 234213/21.03.2018 with subject: “Placement in a Public RΑΕ ref. No. Ι-246788/4.10.2018 with which is Program Consultation 2018-2022”. substantiated the coverage of the financing needs of the 29. The fact that RAE, within its authorities, pursuant overall business plan. to the provisions of Article 29 of Law 4001/2011, has 36. The Decision of RAE no. 1314/2018 “For the put forward in public consultation the proposal of the granting of a Natural Gas Distribution License to the Applicant for the Five-Year Development Program company “Gas Distribution Company Thessaloniki – 2018-2022 of the Distribution Networks in Thessaloniki Thessaly S.A.””. and Thessaly, from 21.03.2018 until 16.04.2018. 37. The fact that this Decision does not impose a 30. Comments submitted in the context of the public burden on the State Budget. consultation, with the documents with RAE ref. no.: Ι- After due deliberation: 234739/30.3.2018, Ι-234871/02.04.2018, Ι- 234865/02.04.2018 Ι- 234863/02.04.2018, Ι- Whereas, pursuant to paragraph 1 and 2 of article 80 234831/02.04.2018 ς, Ι-234945/03.04.2018, Ι- of the Law: “The construction, operation and 234898/03.04.2018, Ι-234897/03.04.2018, Ι- management of the Natural Gas Distribution Networks 234894/03.04.2018, Ι-234947/03.04.2018, Ι- shall be carried out in accordance with the provisions of 235005/04.04.2018, Ι-235013/04.04.2018, Ι- this Article. The construction of a Distribution Network 235014/04.04.2018, Ι-235007/04.04.2018, Ι- is permitted to those who have been granted a 235012/04.04.2018, Ι-234982/04.04.2018, Ι- Distribution License upon request of the interested

69715 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

party, in accordance with the Licensing Regulation, by including the State and the insurance funds, which decision of RAE. 2 Operation and exploitation of concerns the contributed Distribution or Supply sector, Distribution Networks is permitted to those who have in respect of which the relevant GDC(EDA) or new GSC been granted a Distribution Network Operation (EPA) is substituted by the above. The new company is License. The Distribution Network Operation License is exempt from any obligations, titles or rights that are granted upon submission of an application in not transferable by law or contract or concern the accordance with the Licensing Regulation, by decision assets of the networks that remain property of Public of RAE. The Distribution Network Operation License Gas Corporation of Greece (DEPA) S.A. as defined in the may be granted, on the basis of efficiency and provisions of Article 80B. Any accounting or tax financial balance, to a person other than the holder of treatment carried out by the contributing company, the Distribution License. In this case, the holder of the which concerns the distribution or supply sector and Distribution License enters into a contract with the involves future benefits or charges, is transferred as a holder of the Distribution Network Operation License, result of the secession to the acquiring GDC (EDA) or which determines the consideration due to take over new GSC (EPA), to its benefit or against it”. the operation of the Distribution Network from the Whereas, as it derives from the Notice of the General total receivable income of the Distribution Network, Commercial Registry with ref. no. 23045/30.12.2016, based on the published invoices for its use”. on 30.12.2016 was registered in the General Α. On the incorporation of the company “GAS Commercial Registry with Entry Code Number 877054, DISTRIBUTION COMPANY THESSALONIKI - THESSALY the Decision of the Regional Governor of Central S.A.” Macedonia with ref. no. 15.669/27.12.2016, approving the merger of the Sociétés Anonymes under the trade Whereas, pursuant to paragraph 3 of article 80A of names “THESSALONIKI GAS SUPPLY COMPANY S.A.” the Law: “Until January 1st, 2017, the current Natural and ”THESSALY GAS SUPPLY COMPANY S.A.”, by take- Gas Distribution Companies of Attica, Thessaloniki and over of the latter by the former and on the other hand Thessaly are required to legally and functionally the amendment of articles 1, 2, 3, 4, 5, 7, 8, 9, 11, 13, unbundle the Operation of the Distribution Networks 14, 15, 18, 21, 29, 31 and 33 of the articles of of Attica, Thessaloniki and Thessaly from their other association of the first company. According to the text activities, by the contribution at their discretion, of the amended Articles of Association, the first alternatively, either the distribution sector or the Company, which took-over the second, renamed to supply sector of each of them, during the “GAS DISTRIBUTION COMPANY THESSALONIKI – establishment phase of GDC (EDA) or new GSC (EPA) THESSALY S.A.” with the distinctive title “EDA THESS in accordance with the provisions herein and of law S.A.”. 2190/1920. In the case of contribution of the Supply sector, the trade name of current GSC (EPAs) may be Whereas, the Applicant is, by operation of law, amended accordingly and the current GSC (EPAs) will universal successor of the companies under the trade be renamed to Gas Distribution Companies. The name “THESSALONIKI GAS SUPPLY COMPANY S.A.” current GSC (EPAs) of Thessaloniki and Thessaly may and” THESSALY GAS SUPPLY COMPANY S.A.”, in relation jointly contribute the Distribution or Supply sector of to the distribution activity and was substituted for all each of them, during the establishment phase of a the rights, obligations and all legal relations of these joint GDC (EDA) or a new GSC (EPA) respectively, in companies with regard to the contributed distribution the share capital of which the two contributing sector. companies are involved in proportion to their Β. Legislative provisions on the Distribution Network contribution. For the purposes herein, Distribution of Thessaloniki and the Distribution Network of and Supply Sectors are the homonymous autonomous Thessaly organized functional units of the current GSC of Attica, Thessaloniki and Thessaly, including the assets of each Whereas, the case (i2) of paragraph 2 of Article 2 of of the above existing GSC(EPA) and the related to the Law provides that: “Distribution Network of these assets and liabilities that fall within the Thessaloniki: The Distribution Network already competence of the above units”. developed or to be developed according to an approved Development Program within the Whereas, pursuant to paragraph 6 of article 80Α of geographical area defined by ministerial decision (Β' the Law: “GDC(EDA) and new GSC (EPA) of par. 3 are 1086) no. Δ1/Γ/Φ7/11819/29.8.2000 and extends to substituted, irrespective of the time of their consumers' premises”. generation, for all the rights, obligations and legal relations of the case-by-case contributing company Whereas, the case (i3) of paragraph 2 of Article 2 of concerning the contributed branch, in particular with the Law provides that: “Distribution Network of regard to the rights of use of the assets, and enjoy the Thessaly: The Distribution Network already developed tax advantages and defects established in favor of the or to be developed according to an approved contributing company. This transfer is assimilated to Development Program within the geographical area universal succession and from the date of registration defined by ministerial decision (Β' 1087) no. in the General Commercial Register of the relevant Δ1/Γ/Φ7/11818/29.8.2000 (Β' 1087) and extends to approving decision the contributing in sector company consumers' premises”. is exempt from any obligation against any third party ,

69716 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 Whereas, in accordance with article 80B of the Law: allocated to a Distribution Network55559161809/21.05.2018 Operation License “1. Distribution Networks constructed within the and which: (a) are not included into the approved Greek territory either by Public Gas Corporation of Development Program of the Network or Greece (DEPA) S.A. or by Gas Supply Companies of (b) are included in the approved Development Attica, Thessaly and Thessaloniki under the Program, but eighteen (18) months have elapsed Distribution Licenses issued under the provisions of without completing the development of the Network Law 2364/1995 remain the exclusive property of provided for by the timetable contained in the Public Gas Corporation of Greece (DEPA) S.A. 2. Distribution License, any interested party who meets Expansion works of existing Distribution Networks the requirements of the Licensing Regulation may apply that are being implemented by the GDCs (EDAs) from to RAE for the granting of a distribution license and a April 1st, 2017 which arise, in accordance with the distribution network Operation License for the provisions of Article 80A, and are Operators of the development of a network in that particular area”. Distribution Networks of Attica, Thessaloniki and Thessaly, on the basis of the respective distribution Whereas, according to element c) of paragraph 8 of licenses, belong to their exclusive ownership. The article 24 of Law. 4513/2018: “ c) License applications value of replacement or restoration works of existing for the supply of natural gas, INGS (ASFA), Natural Gas Distributive Networks belonging to the exclusive Distribution, operation of INGS(ASFA) and Natural Gas ownership of Public Gas Corporation of Greece (DEPA) Distribution Network operation that are pending before S.A. and carried out by GDCs (EDAs) is considered as RAE at the effective date of this, are also assessed in income of Public Gas Corporation of Greece (DEPA) accordance with the provisions of Article 90 of Law S.A. For income tax purposes, this income is 4001/2011, as amended herein, and the delegated distributed and taxed equally in financial period, regulatory acts issued pursuant to that law. Applicants, within which the replacement or restoration of the whose application is pending before RAE, are required Networks referred to in the preceding paragraph is to update the details of the application in compliance completed and in the remaining financial periods until with the aforementioned provisions”. the end of the duration of the Distribution Network Operation License in accordance with paragraph 2 of Whereas, the present Application was acceptably Article 80C”. submitted within three months from the applicant's establishment and in particular on 31-3-2017. C. On the Application of “GAS DISTRIBUTION COMPANY THESSALONIKI – THESSALY S.A” Whereas, the publications of the Applicant for submission of application for a Distribution License and Whereas, pursuant article 80C of the Law: “The their notice to RAE (relevant 19) took place in due time GDCs deriving in accordance with article 80A are and lawfully, in accordance with the applicable obliged, within three months of their establishment, Licensing Regulation at the time of submission. request a distribution license and a Distribution Network Operation License granted by RAE in Whereas, no objection was raised to this Application. accordance with the provisions of Article 90 of Whereas, as defined in paragraph 1 of Article 4 of the Licensing Regulation". The Distribution Network Licensing Regulation, the application for the granting of Operation License also covers any future expansion of license is submitted to RAE in hard copy, in accordance the above Networks within the above areas. For the with Application Form for the Granting of License, Networks owned by DEPA SA, the License also defines which is set out in Annex I of Section I of the Licensing the obligations and rights of the Network Operator Regulation. The application shall be accompanied with regarding the granting of their management to it and all documents and details provided for in Annex IV to the obligations and rights of the owner. DEPA SA as Section I of the Licensing Regulation and the the Owner of the Networks is not entitled to any information referred to in paragraphs 1a and 1b of consideration for the granting of the management and article 4 of Licensing Regulation. exploitation of the Distribution Districts of Attica, Thessaly and Thessaloniki until the right to use and Whereas, as it derives from the details of the enjoyment has been discharged in accordance with Applicant, as well as all additional details (hereinafter the provisions of Article 7 of Law 2364/1995 and in referred to “Application File”), the submitted particular until the expiry of the distribution license application is formally complete. granted to GDCs (EDAs) in accordance with the D. Application Appraisal provision of paragraph 2. ….2 The duration of the licenses granted to the GDCs shall be determined by Whereas, RAE appraises the application, pursuant to decision of RAE and shall be at least 20 years with the articles 9, 11 and 12 of the Licensing Regulation. possibility of an extension for twenty (20) additional Whereas, the article 11 of the Licensing Regulation years. 3. The GDCs (EDAs) that "arise" in accordance defines the following: “1. In the process of appraising with the provisions of Article 80A are Operators of the the applications, RAE appraises the fulfillment of the respective Distribution Networks within the general appraisal criteria of paragraph 2 of article 90 of geographical limits provided by the Distribution the Law, as specified below: Network Operation Licenses granted to them. For individual areas within the geographical limits (a) The security and protection of Natural Gas Systems, as well as facilities and associated equipment,

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taking into account, in particular, the requirements of (c) The compliance with the technical specifications the National Natural Gas System Operation Code and and requirements for the design, operation and the Natural Gas Distribution Network Operation Code maintenance of the Network and the achievement of as well as the proposed planning of the Applicant for the performance targets for the Distribution activity, safety, maintenance and emergency response as with regard to, among other things, losses, supply indicated by the relevant application file. During this reliability, load balancing, Emergency Needs and inspection, the security in the operation of the Customer Service Quality as defined in the Network corresponding infrastructure project is not examined, Operation Code. since this is checked at a subsequent licensing stage (d) The Access to the Suppliers and Customers' by the competent technical services. Network, in accordance with the terms and conditions (b) The particular technical and economic set out in the Network Operation Code, based on tariffs characteristics of the Applicant, in particular: α) its issued in accordance with the Tariffs Regulation of technical experience in matters concerning the Article 88. exercise of the natural gas activity to which the (e) The connection to the Network to those who application relates, b) its organizational and request it, in accordance with the terms and conditions administrative structure, which should be appropriate set out in the Network Operation Code for tariffs to ensure the credible, prudent and useful exercise of approved under the Tariffs Regulation issued in the gas activity for which application is made and c) its accordance with Article 88. solvency for the realization of the activity, as evidenced by the documents and data submitted in (f) The procurement, installation, maintenance, accordance with the respective Annexes to Section 1 operation and replacement of metering devices of the Annexes to this Regulation. installed in the Network in accordance with the provisions of the Network Operation Code and the (c) Consumer protection with a view to providing collection of relevant measurements, taking into high-quality services and achieving the best prices, in account the provisions of Regulation (EU) 312/2014 particular ensuring uninterrupted gas supply and (ΕΕΕΕ L 91/15). optimal relationship between quality and price, taking into account in particular the design of the Applicant (g) Providing the Network Users and the as contained in its business plan. Interconnected Natural Gas and Distribution Networks Operators with the information required for effective (d) The protection of the environment and climate network access, in accordance with the terms and from the effects of Natural Gas activities, if the conditions of the Network Operation of Code, taking application file or any data brought to the attention of into account the provisions of Regulation (EU) the Authority shows that maximum environmental 312/2014 (ΕΕΕΕ L 91/15). problems are created. This inspection does not generally examine the environmental impacts of the (h) Avoiding any discrimination between User or project as it is controlled at a subsequent licensing Users categories of the Network and in particular in stage by the competent environmental authorities”. favor of its affiliates and the preservation of the confidential commercially sensitive information (e) Ensuring and reinforcing healthy competition in received from third parties in the provision or the natural gas market with the aim of reducing the negotiation of access to the Network. cost of energy for all Users and Customers and with particular emphasis on avoiding distortions or (i) The cooperation with the operators of the restrictions of competition between undertakings Interconnected Natural Gas and Distribution Networks carrying out Energy Activities as well as the provision for the instruction and implementation of appropriate of access to third parties to gas networks and facilities communication and cooperation protocols to ensure transparently, objectively and impartially between the proper and uninterrupted operation of their Users. Liability Networks, the exercise of their responsibilities and the operation of the market, as well as cooperation 2. If even one of the criteria is not met, the with organized market operators in which wholesale application is rejected and the other criteria are not energy products are traded as defined in Regulation examined”. (EU) 1227/2011 (ΕΕΕΕ L 326/1) and under the terms Whereas, in accordance with paragraph 7 of article and conditions of the Network Operation Code for 80 of the Law: «The obligations of the Distribution participation in these markets for the provision of Network Operator are specialized in the Distribution balancing services. Network Operation License and may include, but are (j) Design, planning and implementing the not limited tο the assurance of: development of the Network, examining the feasibility (α) The credibility and security of the Network while of energy efficiency measures. taking appropriate measures to protect the k) The ability to attract new consumers and their environment. connection to the Network in accordance with the (b) The maintenance of a technically sound and terms and conditions set out in the Network Operation cost-effective Network. Code”.

69718 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 Whereas, paragraph 1 of article 12 of the Licensing business supervision of 5555916 the 1809/21.05.2018 Vertically Integrated Regulation defines the following: “1In appraisal of Undertaking concerning the return on investment. The applications RAE appraises the fulfillment of the parent company may, in particular, approve the annual following specific criteria, by type of license, as financing plan or other equivalent instrument without specified below: Α… Β… C…D. In the case of an INGS having the right to intervene in any way in the (ASFA)Operation License or a Natural Gas Distribution management, on the daily operation or individual Network Operation License, that the Applicant has a decisions concerning the upgrade of the Distribution share or company capital of at least four hundred Network, if not exceeded the financial framework thousand (400,000) euro.”. approved. The parent undertaking is not allowed to give instructions on the daily operation or on individual Whereas, Article 31 of the Licensing Regulation decisions on the construction or upgrade of the defines that: “1. The Distribution Operation License Distribution Network that do not exceed the terms of Holder manages and operates the Distribution the approved financial plan or any equivalent Network specified in the Distribution Network instrument. Operation License within the geographical area referred to and must further develop it with the d) The Holder of the Distribution Network Operation financial resources provided by the Holder of the License prepares and implements a compliance Distribution License in accordance with the approved program, indicating the steps taken to exclude any Development Program ". discriminatory behavior in favor of the Vertically Integrated Undertaking and to ensure proper Whereas, article 32 of the Licensing Regulation monitoring of compliance with the program. The defines that: “1. The Distribution Network Operation compliance program sets out the specific obligations of License granted under those specified in sections A to employees to achieve this objective. This program is C. subject to the approval of RAE, which is considered to Whereas, the Applicant is part of the vertically be provided if RAE does not object within three (3) integrated undertakings DEPA SA and Eni Gas e Luce weeks after submission of the program for approval. SpA, with participation in the Applicant’s shareholder The approved compliance program is posted on the structure by 51% and 49%, respectively. In addition, website of the Distribution Operation License Holder Eni Gas e Luce SpA exercises the Applicant's within five (5) days of its approval. Without prejudice to management. the responsibilities of RAE as defined in Article 20 herein, the compliance to the program is subject to Whereas, according to paragraph 5 of article 80 of independent audit from the responsible executive or the Law: “When the holder of Distribution License and body - responsible for monitoring the compliance / or Distribution Network Operation License program - οf the Distribution Network Operation participates in Vertically Integrated Undertaking of License Holder who acts as compliance officer and has Natural Gas or Electric power, must be independent of access to all necessary information from the operator other sectors or departments of that Operation, at and any subsidiary company for the performance of his least in the legal form, organization and decision- / her duties. The compliance officer shall submit to RAE making process. For this reason: “α) The persons in writing, by March 31st of each year, an annual report exercising the management of the Distribution License describing the measures taken to comply with the and / or Distribution Network Operation License compliance program, which shall be published on RAE’s holder are not allowed to participate in the website within five (5) days of its submission. The administration, sectors or departments of the Distribution Network Operator is required to comply Vertically Integrated Undertaking of Natural Gas or with the recommendations of RAE and submit for Electric power or other Related Business of the approval, in accordance with the provisions of this Vertically Integrated Undertaking of Natural Gas or paragraph, a new compliance program within fifteen Electric power, which are responsible, directly or (15) working days of the notification of the RAE. RAE indirectly, for the operation of generation, publishes on its website an evaluation report of the transportation and supply of natural gas. compliance program of the Distribution Network b) The persons exercising the management of the Operator until April 30th of each year. Distribution License and / or Distribution Network e) Notices and trademarks of the holder of the Operation License are not allowed to have same Distribution License and the holder of Distribution interests, which obstruct the performance of their Network Operation License may not be confusing with duties in an independent and objective manner. regard to the separate identity of the supply sector of c) The Holder of the Distribution Network Operation Vertically Integrated Undertaking of Natural Gas or License takes decisions on the resources and Electric Power”. investments required for the operation, maintenance Whereas, in accordance with par. 1 last subparagraph and development of the Distribution Network, of article 80 C: “The Distribution License and the regardless of the Vertically Integrated Natural Distribution Network Operation License specify the Undertaking of Natural Gas or Electric Power. Such terms, conditions and the necessary measures to decision making does not exclude coordination ensure the independence, functional unbundling and procedures, in order to ensure the protection of fair and non-discriminatory behavior of the licensee

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according to the specific provisions of this law. executive or body, responsible for monitoring the compliance program, the compliance officer of the Whereas, with the above provisions are entered in distribution system operator shall submit to the the Greek legal order the provisions of articles 26 and regulatory authority referred to in Article 39 paragraph 27 of the Directive, which define the following: 1 an annual report describing the measures taken, Article 26 “1. If the distribution system operator is which shall be published. The compliance officer of the part of a vertically integrated undertaking, it must be distribution system operator shall be fully independent independent, at least in terms of its legal form, and shall have access to all necessary information from organization and decision-making, from other the distribution system operator and any subsidiary of activities not linked to the distribution. These rules do it for the fulfillment of his/her tasks. not imply an obligation to unbundle the ownership of 3. If the distribution system operator is part of a the assets of the distribution system from the vertically integrated undertaking, the regulatory vertically integrated undertaking. authorities, if member states have such a provision, or 2. In addition to the requirements of paragraph 1, member states ensure that the activities of the if the distribution system operator is part of a distribution system operator are monitored by the vertically integrated undertaking, it must be regulatory authorities or other competent bodies so independent, at the level of organization and decision- that it is not able to take advantage of its vertical making, from the other activities not related to integration in order to cause distortion of competition. distribution: In particular, notices and trademarks of vertically integrated distribution system operators shall not α) the persons responsible for the management of cause confusion as to the separate identity of the the distribution system may not participate in the vertically integrated undertaking's supply. structures of the integrated natural gas undertaking which are directly or indirectly responsible for the 4. Member States may decide that paragraphs 1, 2 daily performance of gas production, transportation and 3 do not apply to integrated natural gas and supply activities, undertakings serving less than 100 000 connected customers”. b) appropriate measures must be taken to ensure that the professional interests of the persons Article 27 “1. Without prejudice to Article 30 or any responsible for the management of the distribution other legal obligation to disclose information, the system are taken into account in such a way to ensure distribution system operator shall preserve the that they are able to act independently, confidentiality of the commercially sensitive information came in its knowledge in the performance c) the distribution system operator must have of its tasks and shall prevent any discriminatory effective decision-making powers, irrespective of the disclosure of information concerning its own activities integrated natural gas undertaking, with regard to the and may offer commercial advantages. resources necessary for the operation, maintenance and development of the network. For the fulfillment 2. When purchasing or selling natural gas from of these duties, the distribution system operator shall affiliated undertakings, distribution system operators have the necessary human, technical, financial and shall not abuse commercially sensitive information material resources. This should not prevent the received from third parties in the provision or existence of the appropriate coordination mechanisms negotiation of provision of network access”. which will ensure that the financial rights and the Whereas, the complex of the EU rules that impose management supervision rights, which the parent the independence and functional unbundling of company has in respect of the return of the subsidiary Distribution Network Operators, which are part of a resources of the company which are indirectly vertically integrated undertaking, are interpreted and regulated in accordance with Article 41 paragraph 6. applied in the Greek legal order in order to make In particular, this allows the parent company to certain the intended purpose. In particular, it is approve the annual financing plan or an equivalent acknowledged that Directive 2009/73 / EC regulates the instrument of the distribution system operator and to de minimis obligations regarding the activity of set total limits on the levels of charging of its Distribution Network Management and it is up to the subsidiary. It does not allow the parent company to Member States to impose additional measures to give instructions on thedaily operation or individual ensure the effectiveness of the unbundling. In this decisions on the construction or upgrade of context, it should be noted that the article 41 par. 1 of distribution lines which do not exceed the terms of the Directive includes in the Regulatory Authority’s the approved financial plan or any equivalent duties “[...] b. to ensure the compliance of transmission instrument, and and distribution system operators [...]to their d) the distribution system operator shall draw up a obligations under this Directive and any other relevant compliance program, indicating the measures taken to community legislation [...]· [...] r. to monitor the avoid any discriminatory behavior and ensuring implementation of the rules concerning the role and proper monitoring of compliance with the program. responsibilities of transmission system operators, The compliance program sets out the specific distribution system operators, [...]in accordance with obligations of employees to achieve this objective. Τhe the Regulation (EC) No. 715/2009”.

69720 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 Whereas, in accordance with par. 1 last Decisions Δ1/Γ/Φ7/118195555916 and1809/21.05.2018 Δ1/Γ/Φ7/11818, subparagraph of article 80 C: “The Distribution License Government Gazette Β' 1086/31.08.2000, Government and the Distribution Network Operation License Gazette Β' 1087/31.08.2000, respectively) contributes specify the terms, conditions and the necessary to the view that it possesses the necessary technical measures to ensure the independence, functional competence to guarantee the intact and safe unbundling and fair and non-discriminatory behavior construction and the safe and reliable operation of the of the licensee according to the specific provisions of Distribution Network. The above are supported by the this law”. fact that the Applicant's shareholders are companies of recognized solvency and great experience in the field of Whereas, RAE under its responsibilities, according to Energy at global level. Regarding the solvency of the the provisions in particular of articles 13 and 80 to 80C Applicant to carry out the Distribution activity from the of the Law as well as the relevant provisions of the information provided to date, it appears that the Licensing Regulation, examined the Application File Applicant has, at the date of granting this License, the submitted for the award of the -under evaluation- solvency required to carry out the activity in question Natural Gas Distribution Network Operation License. and is subject to a continuous control and supervision Whereas, from the examination of the data of the by RAE. submitted File, regarding the fulfillment of the criteria c) With regard to consumer protection, the data in of article 11 of the Natural Gas Licensing Regulation, the Application File show that the Applicant intends to the following were found: provide the high-level services as described in the Code a) Regarding the security and protection of the and to ensure the uninterrupted supply of Natural Gas Natural Gas Systems as well as of the installations and to the Final Customers who are connected to its connected equipment, the data of the Application File Distribution Network. Additionally, the distribution show that the applicant's design for security, tariffs recovered by Distribution Users, are regulated, maintenance and emergency response is compatible approved by the Regulatory Authority for Energy as set with the requirements of the National Natural Gas out in the Tariffs Regulation, are publishable and follow System Operation Code and the Natural Gas Network cost-oriented billing rules while providing incentives to Operation Code. According to the submitted the Licensee for the economic provision of services and Organizational Chart, the Applicant has a special Unit the effective development of the distribution network dealing with Operation and Maintenance issues of the in such a way as to ensure consumer protection. The Distribution Network for Thessaloniki and Thessaly Ancillary Services tariffs are also cost-oriented, and the respectively. Moreover, the Applicant has the revenue recovered from them further reduces the appropriate staff which constantly trains and Distribution Tariffs. This will ensure the optimal relation appropriate infrastructure in order to guarantee the between quality and price in the provision of the Distribution Network Safety in the geographical area distribution services and ensure that the public interest of its License. is served. The applicant's financial data is subject to continuous control by the Regulatory Authority for b) About the special technical and financial Energy. characteristics of the Applicant, from the Application File derives that the Applicant has, at its date of d) Concerning the protection of the environment and License granting, the technical experience in matters within the competence of the Authority according to relating to the exercise of the Distribution activity and item d of article 11 of the Licensing Regulation, it the appropriate organizational and administrative appears on the basis of the information provided to the structure in order to ensure the credible, prudent and Authority that there are no major environmental useful exercise of the Distribution activity. According problems from the activity, which is in any case subject to the applicant's submitted organization chart, there to compliance with the rules controlled by the are distinct Units of Strategic Planning and Regulatory competent environmental authorities. Affairs, Network Development and New Connections, e) With regard to assurance and reinforcement of Operation and Maintenance and Network Access, healthy competition in the gas market with the aim of necessary structures for the provision of the regulated reducing the energy costs for all Users and Customers, Non-Competitive Activity, which can support the as evidenced by the data in the Application File, the intact and safe development and operation of the Applicant will provide full third party access to the Distribution Network as well as impartiality in the Distribution Network as well as any other installations provision of services to Users under the terms of with transparent, objective and non-discriminatory financial efficiency, to ensure that no discriminatory rules as defined in the Directive, the Law, the Code and behavior is created for specific Users but also that the other regulatory texts, aiming to promote competition regulated Non-Competitive Distribution Activity will between companies carrying out Energy Activities. The be provided cost-effectively, especially given that the applicant is required to provide full third-party access distribution network will be under continuous growth to the Distribution Network with transparency, and that the Natural Gas market has recently been objectivity and impartiality. Thereunto, the Energy liberalized. Regulatory Authority has approved the Tariffs Furthermore, the fact that the Applicant is holder, Regulation for the Distribution Networks of since 2000, of natural gas licenses (see the Ministerial Thessaloniki and Thessaly, Distribution Tariffs, and the

69721 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

Natural Gas Network Operation Code. Therefore, the Initial Plan approved by the Distribution License compliance with the principles of third Decision is an integral part of this Distribution Operation License, without requiring any modification. party access obligation is ensured in a direct and In that connection, article 32 of the Law provides for cost-effective way, in accordance with the principle of RAE's decisions to be published by posting it on the RAE transparency and without discrimination between website. Users or Users’ categories. In addition, the Applicant is required to keep separate accounting records Whereas, the Development Program 2018-2022, submitted annually to the Energy Regulatory Authority which reflects the current situation of the Distribution and audited to avoid any distortion and to fully record Networks of Thessaloniki and Thessaly in function, was the actual cost of the distribution network. The approved as the Initial Development Program under objective of the Authority is to reduce the actual cost RAE’s decision No. 1314/2018 on the granting of a of the distribution network, which will help reduce the Natural Gas Distribution License to the Applicant. final cost of energy for all Customers. Therefore, since the publication of this Decision is an integral part of this and it does not need to be Whereas, further to the examination of the data of amended. the submitted File, it was ascertained that the criteria of Article 12 of the Natural Gas Licensing Regulation Whereas, in the submitted business plan is described are met. In particular, the Applicant has a share capital and documented in detail the way of financing the of at least four hundred thousand euro (400.000,00 €). development of the Natural Gas Distribution Network through bank lending and equity. Whereas, Article 14 of the new Licensing Regulation provides as follows: "The License includes general and Whereas, the submitted business plan presents the special terms as defined in the respective Annexes to appropriate financial analysis of the project with Section II of the Annexes to this Regulation. The detailed reference to the projected cash flows from the general terms are the minimum terms of the License. investment, operating and financial activity of the RAE may, when granting or modifying the License, company. impose special terms or restrictions on the exercise of Whereas, as defined in Directive (ΕU) 2016/1148 of the rights granted to it, if necessary, in particular for the European Parliament and Council, of July 6th, 2016, the purposes of consumer protection, the public “concerning measures for a high common level of interest, competition and security of supply”. security of network and information systems across the Whereas, in accordance with Article 25 par.1 of Union” and provided that EDA THESS fall within its Directive 2009/73/EC: “The distribution system scope, is required within the period of its full operator shall be responsible for ensuring the application set out in Article 25, have implemented a system's long-term ability to meet reasonable framework and procedures to achieve the necessary demands for gas distribution, as well as for the security and reliability of information systems and operation, maintenance and development of a secure, networks, by communicating them to RAE and any reliable and efficient network in its area under cost- other competent national authority within a reasonable efficient conditions, with due regard to the time. environment and energy efficiency”. For the above reasons, decides: Whereas, in accordance with paragraph 10 of article 1. The granting of a Natural Gas Distribution 80 of Law: "The Distribution Network Operator shall Network Operation License to the company “GAS implement the Distribution Network with the funds of DISTIBUTION COMPANY THESSALONIKI-THESSALY S.A.” the Distribution License holder in accordance with the and distinctive title “EDA THESS”, in accordance with Development Program prepared by the Operator and the Law, the Licensing Regulation and the conditions submitted to RAE for approval in accordance with the listed below. The geographical area is defined with the Operation Code. The Initial Development Program is Ministerial Decisions Δ1/Γ/Φ7/11819/29.8.2000 and co-submitted with the application for the granting of Δ1/Γ/Φ7/11818/29.8.2000 (Government Gazette Β' the Distribution License. The first year of the Initial 1086) and Government Gazette Β' 1087), and is Development Program is the year in which the described in more detail in Annex II hereto Distribution License enters into force” Furthermore, Article 33 of the Licensing Regulation states that: “1. The Annexes I, II, III, IV annexed to this Decision form In addition to those referred to in Article 15 of this an integral part of this Decision. Regulation, the Distribution License includes: a. The current approved Development Program of the 2. The publication of this Decision in the Official Distribution Network, as well as the relevant timetable Government Gazette. for the development of the Distribution Network. Each approved Development Program is, since the publication of the RAE's approval decision, an integral part of the Distribution License without requiring any modification of the License”. Whereas, in accordance with the above provisions,

69722 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 PROFILE TABLE OF NATURAL GAS LICENSE 55559161809/21.05.2018

Details GAS DISTIBUTION COMPANY THESSALONIKI- ΕΤΑΙΡΕΙΑ ΔΙΑΝΟΜΗΣ ΑΕΡΙΟΥ ΘΕΣΣΑΛΟΝΙΚΗΣ - of Licensee THESSALY S.A. ΘΕΣΣΑΛΙΑΣ A.E. 51% PUBLIC GAS CORPORATION OF GREECE (DEPA) Shareholder S.A. 51% ΔΗΜΟΣΙΑ ΕΠΙΧΕΙΡΗΣΗ ΑΕΡΙΟΥ Α.Ε. Structure 49% ENI GAS Ε LUCE SPA 49% ENI GAS E LUCE SPA NATURAL GAS DISTRIBUTION NETWORK ΑΔΕΙΑ ΔΙΑΧΕΙΡΙΣΗΣ ΔΙΚΤΥΟΥ ΔΙΑΝΟΜΗΣ ΦΥΣΙΚΟΥ Type of License OPERATION LICENSE ΑΕΡΙΟΥ Period of Validity 25 YEARS (ending on 31.12.2043) 25 ΕΤΗ (με λήξη την 31.12.2043) 1.Subject of the License Without prejudice to paragraph 3 of Article 80C of the Law, the holder of this License (hereinafter referred to as the “Operator” acquires the right to manage and operate the Distribution Networks of Thessaloniki and Thessaly as they are developed in accordance with the approved Development Program, within the geographical area defined by Ministerial Decisions no. Δ1/Γ/Φ7/11819 and Δ1/Γ/Φ7/11818 (Government Gazette Β' 1086 and Government Gazette Β' 1087), and is described in more detail in Annex II to this Decision. 2.Period of Validity of License This Natural Gas Distribution Network Operation License is granted for a period of twenty-five (25) years from the date of its entry into force and expiry date on 31.12.2043. The period of validity of the License may be extended in accordance with the provisions of the Law and the Licensing Regulation. 3.Description of the Distribution Network 3Α. Distribution Network of Thessaloniki Thessaloniki's distribution network extends from the entry points of the National Natural Gas Transmission System (NNGTS) to the Municipalities of Regional Unity of Thessaloniki.

Minimum / s/n Code Name Maximum Inlet Pressure Maximum Station Capacity (Nm3 / h)

1 U-2240 NORTH 35,6 barg / 55 barg 145.054 THESSALONIKI

2 U-2220 EAST 34,2 barg/ 55 barg 145.054 THESSALONIKI

There are no other points of interconnection of the Thessaloniki Distribution Network with other Natural Gas Systems or Distribution Networks. The medium pressure network 131.8 km long is made up of 4 "to 10" diameter steel pipes and operates at a nominal maximum pressure of 19 bar. It is supplied by the 2 National Gates of the National Gas System (U-2240 and U-2220), and it supplies 57 metering / regulating distribution stations (IRI) 19/4, and a limited number of big consumers. The 19/4 metering stations degrade the network pressure from 19 bar to 4 bar. After the stations, a low-pressure polyethylene network, up to a maximum of 4 bar, is developed. The low-pressure network with a total length of 1,128.5 km consists of pipes of different diameters F63 to F160. At the Distribution Network of Thessaloniki there are 3 natural gas compression points.

69723 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 In the table below is detailed information of the medium and low-pressure network, as well as the installed meters per Municipality. Medium Pressure Low Pressure Thessaloniki Distribution Network Meters Network 19bar (m) Network P.E. 4bar(m) MUNICIPALITY OF THERMAIKOS 4.048,49 24.988,50 2.379 MUNICIPALITY OF THERMI 11.946,72 62.523,83 2.740 MUNICIPALITY OF KALAMARIA 6.743,34 150.014,56 26.369 MUNICIPALITY OF THESSALONIKI 22.762,96 283.049,48 111.782 MUNICIPALITY OF AMPELOKIPOI- 2.762,00 66.931,15 12.744 ΜΕΝΕΜΕΝI MUNICIPALITY OF DELTA 39.196,97 58.564,99 2.135 MUNICIPALITY OF KORDELIO - EVOSMOS 4.575,11 102.837,81 20.188 MUNICIPALITY OF NEAPOLI – SYKIES 103,5 83.324,04 16.844 MUNICIPALITY OF PAVLOS MELAS 9.254,10 99.932,10 13.723 MUNICIPALITY OF PYLAIA - CHORTIATIS 22.363,00 127.558,23 10.334 MUNICIPALITY OF CHALKIDONA 600,91 10.045,70 117 MUNICIPALITY OF ORAIOKASTRO 7.441,57 54.136,66 2.543 MUNICIPALITY OF LAGKADAS 0 4.559,00 0 TOTAL 131.798,67 1.128.466,05 221.898

3Β. Distribution Network of Thessaly The distribution network of Thessaly extends from the entry points of the NNGTS in the 4 prefectures of the Region of Thessaly.

s/n Code Name Minimum / Maximum Maximum Station Inlet Pressure Capacity (Nm3 / h) INDUSTRIAL AREA OF 1 U-2515 35 barg / 66,4 barg 10.000 2 U-2680 45,3 barg/ 66,4 barg 51.643

3 U-6240 (ΤΜ3-Α) 35 barg / 66,4 barg 20.000

4 U-2670 ΚΟΚΚΙΝΑ 35 barg / 66,4 barg 10.000

5 U-2520 NORTH LARISSA 45,4 barg / 66,4 barg 25.910

6 U-2530 SOUTH LARISSA 45,4 barg / 66,4 barg 25.910

7 U-6260 (ΤΜ3-Β) 35 barg/ 66,4 barg 20.000

8 U-6280 25 barg / 66,4 barg 7.000

There are no other points of interconnection of the Thessaly Distribution Network with other Natural Gas Systems or Distribution Networks. The medium pressure network 69,5 km long is made up of 4 " to 14" diameter steel pipes and operates at a maximum pressure of 19 bar. It is powered by the 8 City Gates of the National Gas System and it supplies 27 metering / regulating distribution stations (IRI) 19/4, and a limited number of large consumers The 19/4 metering stations degrade the network pressure from 19 bar to 4 bar. After the stations, a low-pressure polyethylene network, up to a maximum of 4 bar, is developed.

69724 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 The low-pressure network with a total length of 857,5 km consists of pipes of 5916/31.0different 12diameters5.2018 F63 to F160. 55559161809/21.05.2018 At the Distribution Network of Thessaly there are 3 natural gas compression points. In the table below is detailed information of the medium and low-pressure network, as well as the installed meters per Municipality.

Installed Thessaly Distribution Network Medium Pressure Low Pressure Network 19bar (m) Network P.E. 4bar(m) Meters MUNICIPALITY OF LARISSA 31.264,60 353.095,00 43.916 MUNICIPALITY OF VOLOS 27.067,10 270.436,50 26.997 MUNICIPALITY OF KARDITSA 4.264,16 90.429,53 10.284 MUNICIPALITY OF TRIKALA 3.457,02 93.670,10 9.411 MUNICPALITY OF FARSALA 2.671,99 10.642,50 562 MUNICIPALITY OF 776,91 6.970,70 95 MUNICIPALITY OF RIGAS FERAIOS 0,00 9.179,60 132 MUNICPALITY OF 0,00 5.867,10 11 MUNICPALITY OF 0,00 13.685,50 239 (NIKAIA) MUNICPALITY OF KALAMPAKA 0,00 2.924,60 0 MUNICPALITY OF 0,00 560,00 0 TOTAL 69.501,78 857.461,13 91.647

4.Description of the assets of DEPA SA and authority. obligations and rights deriving from b) Comply with the terms and conditions ownership contained in the License granted to it, as well In Annex II, the assets of DEPA SA are as any other rule of law governing its activity, described in accordance with the provisions and in particular the safety and of paragraph 2 of article 33 of the Licensing environmental protection rules, and shall Regulation and a relevant map is included in take all necessary actions to ensure that the Annex III. other licenses required for the exercise of its Finally, Annex IV sets out the specific activity are valid. obligations and rights of Thessaloniki and c) Carry out its activities in a manner Thessaly Distribution Network Operator on consistent with Community and national the granting of its operation to it by the competition law. owner of the assets described in Annexes II d) Pay in due time the fees attributable to and III, as well as the obligations and rights it in accordance with the Law and its of the owner. delegated current provisions. 5.Obligations of the Operator e) Fulfill the obligations laid down 5.Α. Compliance with the General Terms of regarding the maintenance of accounts in the Licensing Regulation for the Natural Gas accordance with Article 89 of the Law and Distribution Network Operation License Access of RAE to these. The Operator is required to comply with f) Publish its financial statements as set out the provisions of Annex 1 to Section II of the in its legislation and its Articles of Association Licensing Regulation "General License and provide RAE, upon its request within a Terms", as applicable. specified period of time, with any additional For the completeness of this License, the information relating thereto. General License Terms are listed below: g) Provide RAE with the technical, financial, 1.Throughout the validity period of the accounting, commercial, and other relevant License, its holder must: documents or information requested in the a) Comply with the provisions of the Law exercise of its responsibilities in accordance and the regulatory acts issued under its with the Law. In particular, it shall notify RAE,

69725 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 within a specified period of time and at a applicable legislation, the administrative reasoned request thereof, copies of the penalties provided for by the provisions of minutes of the general assembly meeting of Article 36 of the Law are imposed on the shareholders, copies of the minutes of the Licensee and Article 20 of the Licensing meetings of the board of directors, its annual Regulation is applied. financing plan, the corporate business plan The above General Terms bind the as well as data on the activities of the holder Distribution Network Operation License in the energy sector not regulated by the holder as they apply after any modification. License granted to it in accordance with 5.Β. Compliance with the Special Terms of Regulation. the Licensing Regulation for the Natural Gas h) Facilitate RAE when conducting audits, Distribution Network Operation License in particular spot inspections of the facilities The Holder of this License is required to and controls of its books, records and comply with the provisions of Annex 5 of accounts. Section II of the Licensing Regulation "Special i) Comply with the public service Terms of the Distribution License" as obligations and the additional obligations applicable. imposed on it either at the time of granting For the completeness of this License, the the License or later in accordance with the Special License Terms are listed below: applicable legislation, in particular in 1. General Obligations paragraphs 3 and 4 of Article 90 of the Law, a. The Distribution Network Operation and take the measures required for the License Holder must maintain, operate, fulfillment of these obligations. preserve, develop and deploy a reliable, safe, 2.This License shall in no case exempt its technically efficient, operant and cost- holder from the obligation to obtain other effective Distribution Network of required permits or approvals provided for Thessaloniki - Thessaly, with due regard to by the applicable legislation. environmental protection and energy 3.The Licensee is required to submit an efficiency, and to provide Distribution Users application for amendment of its License with access to the Distribution Network it when the cases in paragraph 2 of Article 17 manages, in the most cost-effective, of the Licensing Regulation apply. transparent and direct manner, without 4.The Licensee must notify RAE of its discriminations. intention to change the shareholders' b. The Distribution Network Operation composition in accordance with paragraph 8 License Holder is required to carry out the of Article 18 of the Licensing Regulation. If main Distribution Network Management the change of control falls under the activity exclusively in the geographic area for procedure of preventive control of which the License is granted. concentrations pursuant to article 5 of Law c. The Distribution Network Operation 3959/2011, the holder shall also notify RAE a License Holder must provide access to copy of the decision of the Competition Distribution Users in accordance with the Commission on the notified concentration. terms and conditions set out in the 5.The Licensee must notify RAE within ten Distribution Network Operation Code, based (10) days of any disposal by the holder of a on tariffs issued in accordance with the significant asset, property or equipment of Tariffs Regulation. significant value used to carry out the activity d. The Distribution Network Operation for which the License is granted. License may carry out activities that do not 6.The disclosure obligations of the fall within the scope of the License if they are preceding paragraphs are imposed on the approved by RAE and if a) the uninterrupted, Licensee in addition to the other disclosure secure and reliable provision of services to obligations directly deriving from the consumers associated with the Distribution relevant provisions of the Law. Network and its users is not affected and b) 7.In the event of a breach of the disclosure these activities do not affect the costs of obligations of the preceding paragraphs the activities falling within the scope of the sanctions provided for in paragraph 1 of License. For these activities, the Operator is Article 36 of the Law are imposed. required to keep separate accounts. 8.If RAE discovers submission of false e. The Distribution Network Operation declaration, irrespective of the imposition of License Holder must be insured for civil any other penalties provided for by the liability against third parties from the

69726 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 exercise of its activities. License holder must notify RAE at the end of 55559161809/21.05.2018 f. In the event that the Distribution each calendar semester of the progress of Network Operation License is granted to a the Network's development works. person other than the Distribution License d. If there is a significant delay in the holder, the Distribution Network Operation development of the Network in relation to License holder enters into a contract the RAE approved Development Program, agreement with the Distribution License the Distribution Network Operation License holder, by which is determined the Holder shall disclose that fact to RAE, co- consideration due for taking over the submitting a special reasoned report on the Distribution Network's operation from the causes of the delay and actions to be taken total income receivable of the Distribution against them. The Operator is required to Network. This contract is approved by RAE provide RAE with any other clarification prior to the commencement of the operation requested. activity. e. If the details of paragraphs c and d show g. The Distribution Operation License definite inability to obtain the necessary Holder has the obligations defined in permits and approvals or failure of paragraph 7 of Article 80 of the Law as may implementation the development of the be specialized in the Operation License. Network, it is considered by RAE if there is a h. Without prejudice to any legal need to apply the conditions laid down in obligation to disclose information, and in Article 20 of the Licensing Regulation on particular the obligation to provide revocation of the License. information to RAE, the Distribution System Operator shall preserve the confidentiality of 3.Operation and Maintenance of the commercially sensitive information Distribution Network which becomes available to it during the a. The Distribution Network Operation performance of its duties, and prevents the License holder shall be responsible for the disclosure of information in a discriminatory proper operation and maintenance of the manner relating to its own and may provide Distribution Network in accordance with commercial benefits. national specifications and technical i. The Distribution Network Operation regulations and in the event that they do not License Holder preserves the confidentiality exist, in accordance with the regulations and of the commercially sensitive information practices applicable to the gas industry in the which comes to its knowledge in the context Member States of the European Union. of exercising its activity. b. The Distribution Network Operation 2. Distribution Network Development License holder must carry out the necessary a. The Distribution Network Operation inspections, maintenances, repairs and License Holder is required to design, plan replacements of the Distribution Network in and implement the development of the accordance with the above specifications. Distribution Network. Thereunto, two c. The Distribution Network Operation months before the end of each year of the License holder shall take all necessary approved Development Program, the holder measures to ensure the safe operation of the of the Distribution Network Operation Thessaloniki-Thessaly Distribution Network License submits annually to RAE for approval and to avoid any bodily injury or property a five-year Distribution Network damage. For this purpose, the holder of this Development Program, and specifically License has, in particular: justifies any deviation from the previous i) To inform promptly and by any Development Program. This Development appropriate means consumers, Users, Program also includes the relevant timetable managers of upstream Natural Gas Systems for the development of the Distribution and upstream or downstream Distribution Network. Network operators for any damages to the b. The Distribution Network Operation Distribution Network and the estimated time License holder is required to develop the for their recovery. Distribution Network in accordance with the ii) To inform consumers about the approved by RAE Development Program and potential risks of using natural gas. the relevant Network Development iii) To organize a telephone service to timetable. report any emergencies and, in particular, c. The Distribution Network Operation natural gas leaks.

69727 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 4.Distribution Network Operation Code requests that meet the criteria set out in the and Metering Regulation Distribution Network Operation Code and a. The Operator must ensure the whose facilities are in the Distribution achievement of performance targets for Network and to make connections within a distribution network operation activity in reasonable time, in accordance with the terms of losses, supply reliability, load terms of the Distribution Network Operation balancing, emergency response and Code. customer service quality as defined in the b) Provide sufficient justification for any Distribution Network Operation Code. denial of connection. b. The Operator must comply with the c) Compile, submit to RAE for approval and Distribution Network Metering Regulation as subsequently publish a Standard Connection well as the regulatory texts resulting Agreement with the Distribution Network, therefrom. including in particular the terms of c. The Operator must install, maintain, connection in accordance with the replace and ensure the proper functioning of Distribution Network Operation Code, the the metering devices installed in the applicable connection fees and the rights Distribution Network in accordance with the and obligations of counterparties and, in provisions of the Distribution Network particular, the dispute settlement procedure. Operation Code and the Metering d) Not modify unilaterally and with less Regulation. favorable terms the Connection Agreements d. The Operator must provide Users of concluded with consumers. Distribution Network and Interconnected e) Compile and publish annually a Natural Gas and Distribution System statement of connection fees with the Operators with the information required for Distribution Network for each consumer effective access to the distribution network category and not modify this statement in accordance with the terms and conditions during the relevant year. Connection fees of the Distribution Network Operation Code. will be determined in such a way that, based e. The Operator must ensure the on reasonable estimates of the number and possibility of attracting new consumers and type of connections, the Operator will, on their connection to the Network in average, regain the cost for each connection accordance with the terms and conditions category. Connection Fees and Tariffs of any set out in the Distribution Network other Ancillary Service are approved by RAE. Operation Code. f) No later than October 30th of each year, 5. Distribution Network Tariffs Regulation the Operator shall submit to RAE for and Tariffs for the Use of Distribution approval the proposed Connection Fees for Network the following year. a. The Distribution Network Operation 7.User access to the Distribution Network License holder shall within five (5) days from The Distribution Network Operation the approval of Tariffs for the Use of License holder must not discriminate Distribution Network from RAE, publish the between Network Users and Categories of tariffs for use of Distribution Network as Network in terms of access to the defined in article 88 of the law. Distribution Network. It must also ensure b. The Distribution Network Operation that Network Users have access in the most License Holder must publish a list of charges cost-effective, transparent and direct way. for additional services provided to Network For these purposes the Distribution Network Users, such as consumer reading meters Operation License holder must: services etc. a) Accept all requests for access to the 6.Connection of Consumers with the Distribution Network that meet the criteria Distribution Network set out in the Distribution Network The Distribution Network Operation Operation Code and specifically justify each License holder must not discriminate case of denial of access in accordance with between End Customers as far as it concerns the terms of the Distribution Network the terms of connection of their facilities Operation Code. with the Distribution Network of Thessaloniki b) Compile, submit to RAE for approval and - Thessaly. For this purpose the Operator subsequently publish a Standard Distribution must: Network Usage Agreement, including in a) Accept all End Customer connection particular the terms of use of Distribution

69728 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 Network, and specifying the rights and Distribution Network Operation Code 55559161809/21.05.2018 obligations of counterparties and, in approved by RAE. particular, the dispute settlement procedure. c. The Distribution Network Operation c) Publish the approved from RAE list of License holder shall submit to RAE, within six charges for Ancillary Services which provides (6) months from the end of each year, the to Network Users. financial statements for that year as well as 8.Data Submission the accounting segregated accounts in a. The Distribution Network Operation accordance with Article 89 of the Law. License holder submits to RAE, based on the d. The Distribution Network Operation Distribution Network Operation Code, by License holder must submit to RAE any other November 1st of each year, a five-year information or data requested by RAE to Distribution Network Development Program fulfill its duties. with which are specified in particular the 9.Legal and Functional Independence of projects and the timetable of the Network the Distribution Network Operation License development, taking into account, in Holder particular, the evolution of demand, the a. The Distribution Network Operation needs for connecting new users, the need to License holder shall within one (1) month improve the efficiency, safety and quality of from the day on which the limit of 100,000 service of the Distribution Network connected customers was exceeded as Operator, the implementation of new provided for in paragraph 6 of section 80 of technologies and as far as possible uniform the Law, to inform RAE in writing of this fact technical specifications and environmental and within one (1) month to submit to RAE protection. documentation proving its compliance with In the Development Program, in addition the provisions of paragraph 5 of article 80 of to the data referred to in Article 58 of the the Law. Distribution Network Operation Code, the b. Subject to the provisions of paragraph 6 following data are included for each year: of Article 80 and of Articles 80A to 80C of the i) Design on the development of the Law, the Distribution Network Operation Network, with an analysis per Municipality License holder which is involved in a on the length of a new medium and low- Vertically Integrated Undertaking of Natural pressure distribution network, the Gas or Electric Power shall take all necessary development areas of the Network and the measures to ensure its legal and operational corresponding cost. independence against the Vertically ii) Estimates on the number of new Integrated Undertaking and shall in consumers to be connected to the particular comply with the provisions of Distribution Network. subparagraphs (a) and (b) of paragraph 5 of iii) Estimates on the quantity of gas to Article 80 of the Law. be distributed through the Network for each 10.Interoperability of Distribution consumer category. Networks b. The Distribution Network Operation a. In the development and operation of the License holder compiles and submits to RAE Distribution Network, the Distribution a natural gas monitoring report, within three Network Operation License holder shall take (3) months of the end of each year, on the all necessary measures and apply technical activity of the Licensee in the previous year, rules and specifications to ensure the in particular regarding: interoperability of the NNGS (ESFA), other i) The number of new consumers INGSs (ASFA) or Distribution Networks in connected to the Distribution Network in accordance with the legislation in force or, if that year and the number of all consumers it does not exist, the specifications, served by that Network. regulations and practices applicable in the ii) The quantity of natural gas European Union. distributed through the Network for each b. The Distribution Network Operation consumer category. License holder provides to any other iii) Data related to Network Users and in Transmission System Operator, particular the number of consumers served Transportation LNG and/or to a Storage by each User and the corresponding quantity System Operator, sufficient information to of natural gas. ensure that the transportation and storage iv) Other data in accordance with the of natural gas is carried out in a manner

69729 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 compatible with the safe and efficient network. It is also staffed with all human operation of the interconnected Network. resources and equipped with all the The above Special Terms bind the holder of technical, material and financial resources the Distribution Network Operation License necessary for the fulfillment of its obligations as valid after any modification. under the Law and this License. 5.C. Additional Special Terms and b. The Distribution Network Operation Obligations. License holder must maintain the necessary 1. The Distribution Network Operation technical knowledge and experience for the License holder must cooperate with the proper and safe construction of the operators of the Interconnected Natural Gas Distribution Network in accordance with and Distribution Networks in order to applicable law. For this reason, it must have develop and implement appropriate and maintain the appropriate personnel and communication and cooperation protocols, the organizational and administrative to ensure the proper and uninterrupted structure that is compatible with the operation of their Liability Networks, the fulfillment of the purpose of the License and exercise of their responsibilities and the its Business Plan. In addition, the Licensee orderly functioning of the markets in which must comply with relevant Authority energy products are traded as defined in guidelines and inform the Authority of any Regulation (EU) 1227/2011 (ΕΕΕΕ L 326/1) significant change in its organizational and under the terms and conditions of the structure. Distribution Network Operation Code for c. The total organizational structure and participation in these markets for the the articles of association of the Operator provision of balancing services. ensure its effective independence from the 2. Business Plan and Financing of Vertically Integrated Undertaking. The Distribution Network Development Vertically Integrated Undertaking is a. Since they coincide in the face of the forbidden to define the behavior of the company “Gas Distribution Company Operator in relation to its daily activities and Thessaloniki – Thessaly S.A.” the properties the management of the Distribution of the holder, on the one hand, of the Network. distribution license and, on the other hand, d. In performing its tasks under the terms of the distribution network operation of the Law, this License and the Distribution license, the holder of the Operation License Network Operation Code, the Operator shall shall submit to the Authority for approval by not discriminate against persons or entities November 1st of each year a Development and shall not restrict, distort or prevent Program incorporating the Business Plan. competition in the sector of production or The Business Plan is prepared by the holder supply of Natural Gas. of the Distribution License and must e. All commercial and financial relations explicitly state the method of financing of between the Vertically Integrated the Distribution Network development and Undertaking and the Operator, including the be compatible with the organizational granting of loans, should be in line with structure and personnel, which the Operator market conditions. The Operator is required must have for the proper performance of its to keep detailed records of these commercial duties. Furthermore, the holder of the and financial relations and to make them Operation License does not make any available to RAE upon request. reduction in its Share Capital without the f. The Operator submits to RAE for consent of the Authority, which is expressly approval all commercial and financial or tacitly granted within a period of one (1) agreements with Vertically Integrated after having been informed. Undertaking. 3.Legal and Functional Independence g. The information obligations of the a. The Distribution Network Operation shareholders pursuant to the provisions of License holder always acts in such a way as Codified Law 2190/1920 shall under no to ensure that it has the resources it needs circumstances imply notification by the to smoothly and efficiently carry out the Operator of commercially sensitive activity of the Natural Gas Distribution information to the Vertically Integrated Network Management and in particular for Natural Gas Undertaking. Decisions of the the development and maintenance of an General Assembly Meeting or the Board of efficient, secure and economical distribution Directors of the Operator which contradict

69730 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 the provisions of the Law and the terms of which is directly or indirectly responsible for 55559161809/21.05.2018 this License are automatically void. the operation of the production, h. The Distribution Network Operation transportation and supply of natural gas. License holder involved in Vertically (iv) RAE may object to the appointment, Integrated Undertaking of Natural Gas or renewal, termination and the work Electric Power shall take all necessary framework - including the remuneration, measures to ensure its legal and operational duration and nature of the employment - of independence vis-à-vis the Vertically the members of the Board of Directors, Integrated Undertaking and shall in within one (1) month from the notification of particular comply with the provisions of the above to the Authority. The Licensee is paragraph 5 of Article 80 of the Law as required to inform RAE without delay and to specified below: comply with any relevant decisions. In (i) The members of the board of particular, as regards the appointment of the directors of the Distribution Network BoD members, RAE ensures the fulfillment of Operation License holder, the general the conditions of professional independence managers, the managers, and any other and adequate competence. In case of person who exercises management or makes termination of their contract or any other decisions about the Distribution Network form of early termination of their must, during their term of office, be employment, the members of the Board of independent and not linked with any Directors may apply to RAE, in accordance employment relationship, work or mandate with the provisions of article 34 of the Law, or other business or professional relationship to check the connection of the above and not having any liability or interest in any termination with reasons connected with branch or part or other Affiliate of the their independence and the proper Vertically Integrated Undertaking of Natural performance of their duties, in fulfilling the Gas or Electric Power within the meaning of Operator's obligations under the current article 32 of L.4308 / 2014, which are directly framework. Furthermore, the reasons for or indirectly responsible for the operation of revoking or replacing the members of the the production, transportation and supply of board of directors of Distribution Network natural gas. Operation License holder on the initiative of (ii) The members of the board of the Vertically Integrated Undertaking or an directors of the Distribution Network affiliated undertaking must be listed Operation License holder, the general exhaustively in its articles of association. managers, the managers, and any other (v) The Distribution Network Operation person who exercises management or makes License holder shall take measures to ensure decisions about the Distribution Network that its transactions do not cause confusion during their term of office do not hold shares as to the separate identity of the supply in the Vertically Integrated Undertaking of sector of either the Vertically Integrated Natural Gas or Electric Power or an affiliated Undertaking of Natural Gas or Electric Power undertaking within the meaning of Article 32 or its affiliated undertaking. In particular, it of Law 4308/14, that are directly or indirectly does not use a confusing logo, it does not responsible for the operation of the selectively make postings on the website of production, transportation and supply of the links to the website of the natural gas. aforementioned companies and without (iii) The remuneration, including all prejudice to paragraph 17 of Article 80A is wages and benefits, as well as the not located in the same office building. inducements of the members of the board of (vi) The Distribution Network Operation directors, the general managers, managers License holder is required to take all and any other person exercising necessary measures to avoid cross- management or decision-making on the subsidization between the distribution distribution network, are exclusively related activity and that production or supply or to the activity of the holder of the other activity. Distribution Network Operation License. It is 4.Compliance Program forbidden to be linked to the performance or a. The Distribution Network Operation profitability of a branch or affiliated License holder is required to draw up and enterprise of the Vertically Integrated implement a compliance program specifying Undertaking of Natural Gas or Electric Power the measures taken to exclude

69731 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 discriminatory behavior against persons or (a) drafting and submitting for approval to entities and to ensure that competition is not the RAE the Compliance Program, restricted, distorted or impeded. (b) monitoring the implementation of the b. The Compliance Program also sets out Compliance Program, the specific obligations of the Operator's (c) the preparation of an annual report employees to achieve these objectives. presenting all the measures taken to c. The Compliance Program is submitted to implement the Compliance Program and its RAE for approval within one month of the submission to RAE, granting of the Distribution Network (d) submitting a report to the Board of Operation License. directors and issuing recommendations on d. The approved Compliance Program is the Compliance Program and its posted on Operator’s website within five (5) implementation, days of its approval by RAE. (e) the presentation to RAE (without prior 5.Compliance Officer approval of the Board of Directors or any i) The person or body responsible for other Body of the Operator) of any material monitoring the Compliance Program, namely breach with regard to the implementation of the Compliance Officer of the Distribution the Compliance Program, Network Operator (natural or legal person), (f) the submission of a report to RAE for all shall act fully independently in accordance commercial and financial relations between with the requirements of the Union the Vertically Integrated Natural Gas framework and shall be appointed by the Company and the Operator. Board of Directors of the Operator, subject v) The Compliance Officer shall take to the prior approval of RAE. RAE may within part in such meetings as it considers crucial three (3) weeks from the above disclosure to facilitate the performance of its duties and raise objections to the independence and may provide guidance on facilitating the professional competence of the Compliance compliance of the Operator. Officer. The Authority reserves the right to vi) The Board of Directors of the object to the designated Compliance Officer Operator shall not prevent in any way the throughout his/her term of office if doubts direct communication of the Compliance arise in that regard. Officer with the Energy Regulatory Authority ii) The Compliance Officer may not hold and in particular the approval of the Board of any other professional position or Directors or other administrative body of the responsibility on the Operator, which Operator shall not be required. conflicts with his / her responsibilities. The vii) The conditions governing the terms governing the duration, renewal and mandate or the conditions of employment of termination of the term of the Compliance the Compliance Officer, including the Officer and the reasons for any proposed duration of his/her mandate, shall be subject decision to terminate the employment to the prior approval of RAE. In any case, period shall be communicated to RAE for its these conditions ensure the independence of consent. In this respect, the Authority may the Compliance Officer, including the raise objections within three (3) weeks of provision of all the resources required to such notification. The Licensee must comply perform his / her duties. During his / her with the Authority's Decision. mandate, the Compliance Officer may not iii) The Compliance Officer must have hold any other professional position, the appropriate training, which is proven by responsibility, or interest, directly or the diplomas of the person(s) who indirectly, in the Vertically Integrated Natural constitutes it, as well as the proven Gas Undertaking or any branch or part specialized knowledge, experience and thereof or any other Affiliated Business or know-how in the field of regulation of controlling shareholders. Transmission Systems and Distribution viii) The Compliance Officer submits Networks. In particular, it must be regularly a report to RAE. In any event, the sufficiently aware of the European and Compliance Officer submits to RAE by March national regulatory framework, relating to 31st of each year, an annual report the distribution of natural gas and the way describing the measures taken to comply the gas market operates. with the Compliance Program, published on iv) The Compliance Officer is responsible the Operator's website within five (5) days of for: submission to RAE. Based on the reports of

69732 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 the Compliance Officer, RAE assesses each systems across the Union”, as well as the 55559161809/21.05.2018 year the independence of the Operator and General Regulation on Personal Data may, by its decision, impose a modification 2016/679, the Operator is obliged to submit of the Compliance Program, in order to annually to RAE an evaluation report of the ensure the independence and impartiality of effectiveness of safeguard procedures of the the Operator by indicating for this purpose confidentiality and protection of the appropriate measures. commercially sensitive information. The Operator is obliged to comply with c) The Operator should take part in RAE's recommendations and to submit for working groups in Greece and abroad on the approval a new Compliance Program within regulation of gas distribution issues. In fifteen (15) working days of the notification particular, the Operator should take part in of RAE's decision. RAE publishes on its surveys conducted across Europe on its website an evaluation report of the comparative assessment with other Operator's Compliance Program by April Distribution Network Operators. In addition, 30th of each year. the Operator's staff takes part in specific ix) The Compliance Officer may training programs of the Commission, CEER, participate without voting rights in all ACER and Distribution Network Operator meetings of the Board of Directors and the organizations according to their needs as General Assembly of the Operator. In any well as the directions of the Energy case, the Compliance Officer is required to Regulatory Authority. participate in all meetings that address the d) The Operator participates in Seminars following items: and working groups of the Regulatory (a) the terms of access to the Distribution Authority of Energy on the enactment or Network, in particular with regard to usage amendment of secondary legislation. tariffs, User Network Distribution Services, e) Any refusal of communication with the Use and Connection Agreements, Authority is considered as a non-compliance (b) the preparation of the Development with the specific terms of this License. Program and the design of projects 6. Modification of the License undertaken for the development, operation The Natural Gas Distribution Network and maintenance of the Distribution Operation License is amended in accordance Network, including investments in new with the provisions of articles 17 and 18 of areas, connection and meter replacement the Licensing Regulation. projects, 7. Transfer of the License (c) any purchases or sales of electric power The Natural Gas Distribution Network or gas necessary for the operation of the Operation License is transferred in Distribution Network. accordance with the provisions of Article 19 (d) relations / contracts of the Operator of the Licensing Regulation. with third parties. 8. Revocation of the License (e) relations / contracts of the Operator The Natural Gas Distribution Network with holders of Supply License. Operation License is revoked in accordance 6. Terms of Operator’s Communication with the provisions of Article 20 of the with RAE Licensing Regulation. a) The Operator must contact the Authority officially and mainly by correspondence. Where appropriate, the Authority may specify the manner and rules for such communication. b) The Operator must provide the Authority with any kind of information on any matter requested by the Authority. In that connection, taking into account, on the one hand, the obligation of confidentiality of the Operator, as defined in Article 27 of Directive 2009/73, on the other hand, the obligations arising from Directive 2016/1148 “ concerning measures for a high common level of security of network and information

69733 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

Annex Ι Description of the geographical area of this Natural Gas Distribution Network Operation License

i Regional Unit of Thessaloniki 1. Municipality of Ampelokipoi - Menemeni 2. Municipality of Thessaloniki (Thessaloniki, Triandria) 3. Municipality of Kalamaria 4. Municipality of Kordelio - Evosmos (Eleftherio-Kordelio, Evosmos) 5. Municipality of Neapoli - Sykies (Agios Pavlos, Neapoli, Pefka, Sykies) 6. Municipality of Pavlos Melas (Efkarpia, Polichni, Stavroupoli) 7. Municipality of Pylaia – Chortiatis (Panorama, Pylaia, Chortiatis) 8. Municipality of Volvi (Agios Georgios, Apollonia, Arethousa, Egnatia, Madytos, Rentina) 9. Municipality of Delta (Axios, Echedoros, Chalastra) 10. Municipality of Thermaikos (Epanomi, Thermaikos, Michaniona) 11. Municipality of Thermi (Vasilika, Thermi, Mikra) 12. Municipality of Lagkadas (Assiros, Vertiskos, Kallindoia, Koroneia, Lagkadas, Lachanas, Sochos) 13. Municipality of Chalkidona (Agios Athanasios, Koufalia, Chalkidona) 14. Municipality of Oraiokastro (Kallithea, Mygdonia, Oraiokastro)

Region of Thessaly i Regional Unit of Karditsa

1. Municipality of 2. Municipality of Karditsa 3. Municipality of Plastiras Lake 4. Municipality of 5. Municipality of

6. Municipality of

ii Regional Unit of Larissa 1. Municipality of Agia 2. Municipality of Elassona 3. Municipality of Kileler 4. Municipality of Larissa

5. Municipality of

69734 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018 6. Municipality of Tyrnavos 7. Municipality of Farsala

iii Regional Unit of Magnisia 1. Municipality of Almyros 2. Municipality of Volos 3. Municipality of Zagora-Mouresio 4. Municipality of South 5. Municipality of Rigas Feraios iv Regional Unit of 1. Municipality of 2. Municipality of 3. Municipality of v Regional Unit of Trikala 1. Municipality of Kalampaka 2. Municipality of 3. Municipality of Trikala 4. Municipality of

69735 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

Annex ΙΙ

Fixed assets belonging to DEPA S.A.

69736 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

DISTRIBUTION NETWORK OF THESSALONIKI 31/03/2017 Numbe Number r of Numbe Networ Network Total Number of Number of Number of of Mediu r of Number Points of Imposed Municipality k 19bar Network Installed Number of PTZ Distributio Customer m Law of Medium Measuremen Current 4bar (m) Length Reducers Installed Meters Correctors n Stations Stations Pressur Pressur Pressure t of Cathodic Stations (m) (m) (M/R e e Valve Stations Protection Stations) Valves Valves THESSALONI KI 326.419 26.983 353.402 17.514 105.970 30 19 80 34 847 11 121 2 KORDELIO - 103.457 6.185 109.643 4.791 17.938 1 4 4 6 289 1 19 0 EVOSMOS NEAPOLI - 91.836 1.454 93.290 4.592 15.572 1 2 6 2 228 1 3 0 SYKIES PAVLOS MELAS 106.721 11.381 118.102 4.350 11.741 7 4 13 11 295 5 49 0 AMPELOKIPO I - MENEMENI 48.444 4.729 53.173 2.560 11.943 0 2 3 3 107 5 0 0 PYLAIA – 112.896 21.106 134.002 3.747 9.145 12 6 24 19 347 8 36 3 CHORTIATIS DELTA 49.547 28.780 78.327 529 1.452 41 6 60 53 198 15 129 1 ORAIOKASTR O 46.133 7.813 53.945 1.211 2.114 5 2 32 9 118 4 10 0 THERMAIKOS 21.685 56 21.741 546 1.739 0 0 0 0 64 0 20 0 THERMI 48.562 13.099 61.661 1.325 2.225 8 5 13 8 145 9 25 0 KALAMARIA 113.485 4.828 118.313 5.267 24.885 1 5 8 5 245 3 22 0 CHALKIDONA 5.646 3.342 8.988 82 80 2 1 6 6 15 3 18 0 TOTAL 1.074.832 129.757 1.204.588 46.514 204.804 108 56 249 156 2.898 65 452 6

69737 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

DISTRIBUTION NETWORK OF THESSALY 31/03/2017

Number of Number Number Netwo Networ Total Number of Number of Number of Customer of of Law Number Points of Imposed Municipality rk k Network Installed Number of PTZ Distribution Stations Medium Pressur of Medium Measuremen Current 4bar 19bar Length Reducers Installed Meters Correctors Stations (M/R Pressure e Pressure t of Cathodic Stations (m) (m) (m) Stations) Valves Valves Valve Stations Protection 342.34 22.89 LARISSA 3 4 365.237 13.728 39.841 35 7 34 18 704 12 74 1 261.33 28.46 VOLOS 2 4 289.797 10.989 24.397 44 9 42 31 556 22 90 2 13.24 ALMYROS 6.795 0 20.035 45 48 1 1 1 3 35 6 41 1 KARDITSA 87.015 3.957 90.972 2.516 8.868 4 3 7 2 211 5 13 1 TRIKALA 90.755 4.166 94.921 2.242 7.965 3 2 7 1 273 5 10 1 KILELER 20.784 8.949 29.733 137 161 2 2 7 7 74 7 22 1 FARSALA 9.447 2.666 12.113 95 213 0 1 0 2 51 0 9 1 RIGAS 15.34 FERAIOS 1.207 3 16.550 0 0 0 1 14 22 6 6 41 0 819.67 99.67 TOTAL 8 9 919.357 29.752 81.493 89 26 112 86 1.910 63 300 8

69738 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018 Annex ΙΙΙ

Map of Fixed assets belonging to DEPA S.A.

Routing Maps of Natural Gas Distribution Networks of Municipal Units Prefecture of Thessaloniki – EDA THESS

GREEK GOVERNMENT GAZETTE 69739 Series B- 5916/31.12.2018

69740 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69741 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69742 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

JGKK 5916/31.0125.2018 55559161809/21.05.2018

69743 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69744 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

GREEK GOVERNMENT GAZETTE 69745 Series B- 5916/31.12.2018

69746 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

5916/31.0125.2018 55559161809/21.05.2018

69747 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69748 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69749 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69750 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69751 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69752 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69753 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69754 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69755 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69756 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69757 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69758 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69759 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

GREEK GOVERNMENT GAZETTE 69760 Series B- 5916/31.12.2018

5916/31.0125.2018

55559161809/21.05.2018

69761 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69762 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69763 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 Routing Maps of Natural Gas Distribution Networks of Municipal Units Prefecture of Thessaly – EDA THESS

69764 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69765 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69766 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69767 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69768 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69769 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69770 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69771 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

GREEK GOVERNMENT GAZETTE 69772 Series B- 5916/31.12.2018

5916/31.0125.2018

55559161809/21.05.2018

69773 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69774 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69775 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69776 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69777 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69778 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69779 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69780 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

% ΕΔΛ

69781 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69782 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018

69783 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

69784 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 55559161809/21.05.2018 Annex IV Obligations and rights governing the relation between the Operator and the owner of the assets of the Distribution Network which existed prior to April 1st, 2017

According to paragraph 2 of article 47 of law 4546/2018, the Reference Date is set the 1st/4/2017. The Distribution Network that was built and completed before the Reference Date means the Existing Distribution Network and is owned by DEPA. Extensions to the Existing Distribution Network executed from April 1st, 2017 by the Licensee (hereinafter referred to as the "Operator"), in accordance with the provisions of Article 80A, are its sole property.

The replacement or rehabilitation of the Existing Distribution Network is carried out by the operator and is owned by DEPA. Replacing or restoring an Existing Distribution Network means any work for the exclusive replacement or maintenance of the Existing Distribution Network: • Replacement of Low-Pressure network in order to increase its safety. Replacement (due to damage or change category) of existing stations of Medium or Low Pressure by adding new equipment. • Replacement (due to damage or change category) of existing valve stations of Medium or Low Pressure by adding new equipment. • Replacement of a medium pressure steel network or Low Pressure PE. • Medium & Low Pressure works involving medium or low-pressure network shifts due to third parties works (Region, Municipalities etc). Cases of construction of Medium and Low pressure networks on a road or part of a road where there was a Natural Gas network until the end of the H.Α. which at the end of the work is isolated. • Replacement of a meter from the existing Distribution Network with a meter of the same technology and equal capacity. In case of replacement of a meter from the Existing Distribution Network with a new meter (Smart Meter), the new meter will be considered as a fixed asset for the Distribution Network Operator. • Replacement of pressure reducers to Existing Network due to damage. The Existing Distribution Network and its replacements or restorations throughout the validity of this License belongs to the ownership of DEPA. DEPA grants without any consideration the operation and exploitation of the Existing Network as well as its replacements or restorations to the Operator.

69785 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

The conditions under which DEPA grants the Operator the operation and exploitation of the Existing Distribution Network are the following:

1. Obligations and Rights of DEPA (1.1) DEPA will not guarantee or be liable to the Operator for specifications and construction or installation works and, in general, the status of any part of the Existing Distribution Network, which is the exclusive property of DEPA. (1.2) For the replacement or restoration of the Existing Distribution Network, DEPA and the Operator are required to implement annually all the necessary actions for the transfer of the respective fixed assets from Operator to DEPA and the granting of the right to use, free of charge, from DEPA to the Operator. (1.3) DEPA and the Operator must jointly agree on a process of recording and maintaining a file of the existing Distribution Network segments, recording all replacements / restorations of the Existing Network and the dates on which the ownership is transferred to them. (1.4) DEPA after receiving the List of the Transferred of Assets, the Certificate of Completion of Fixed Asset Construction to Transfer and the electronic file of "As-Built" Designs and upon written notice from the Operator, performs an audit of the financial and technical scope of the assets. If deviations occur from the above controls, DEPA and the Operator will jointly agree the appropriate actions to be taken by the Operator for the redress.

2. Obligations and Rights of Operator (2.1) The Operator has the full and exclusive right to manage and exploit the Existing Distribution Network. (2.2) The Operator, under its exclusive right to manage and exploit the Existing Distribution Network, has the right to develop the Distribution Network and / or to replace, upgrade, modify or remove part or parts thereof in accordance with financial and technical criteria, as well as criteria related to the safe operation of the Distribution Network and to security of the consumer's supply. (2.3) The Operator maintains and repairs the Existing Distribution Network in accordance with the Good Operation Practices, the Distribution Network Operation Code, the applicable regulatory framework, the Technical Regulations and in compliance with the terms of the applicable License.

69786 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018 5916/31.0125.2018 (2.4) The Operator must insure the Distribution Network (including55559161809/21.05.2018 but not limited to for mechanical damages, material damages, stoppage of work, terrorist acts, civil liability). (2.5) The Operator must be insured for the civil liability against third parties arising out of the exercise of its activities. (2.6) In the event that the Repair or Extension of Existing Network is attached to a Third Party, the Operator shall remain solely responsible for confirming that the construction and installation of any parts of the Distribution Network made by Third Parties on behalf of the Operator shall not cause any damage to the Existing Distribution Network. (2.7) The Operator is solely responsible for any Third Party's claim, and in particular for compensation for any damage, arising as a result of the Operator's activities, including the construction, extension, operation, use, repair or maintenance of the New Network, of its ownership, and the Existing Distribution Network ownership of DEPA, until the expiry of the right to use it. The relevant trials are directed solely at the Operator, fully exempting DEPA from any liability. (2.8) The Operator shall not transfer or otherwise dispose of or assign any encumbrances to any part of the Existing Distribution Network owned by DEPA. (2.9) The Operator is required to keep in storage materials of DEPA property that are removed from the Existing Distribution Network. DEPA is required to regularly (at least every semester) receive, remove, sell and / or destroy such materials. (2.10) The Operator may, subject to the provisions of the Distribution Network Measurement Regulation, install in the Existing Distribution Network measurement equipment. Every new installation of Measurement Equipment is property of the Operator. Any replacement of Measurement Equipment that was disabled due to damage belongs to the ownership of DEPA. (2.11) The Operator is required to register and keep a record of the Existing Distribution Network parts owned by DEPA. (2.12) During the entire period of validity of the License, the Operator will provide DEPA with information on the replacement or restoration of the Existing Distribution Network to the extent that the DEPA is reasonably required to receive.

3. During the last year of the Operation License and if the Operator has not applied to RAE for its extension, the following terms apply: (3.1) DEPA is entitled to request from the Operator the appointment of an independent technical consultant and with the appropriate qualifications, in order to examine and report on the replacement / restoration works of the Existing Distribution Network, which is exclusive ownership of DEPA

69787 GREEK GOVERNMENT GAZETTE Series B- 5916/31.12.2018

(3.2) If DEPA requests the appointment of an independent technical consultant, then: (a) The selection will be made unanimously by DEPA and the Operator. (b) The expenses of the independent technical consultant will burden DEPA. (c) The Operator will provide all information and access to its facilities and records, which the independent technical consultant reasonably asks.

The present decision is to be published in the Greek Government Gazette.

Athens, December 21st, 2018 The President NICOLAOS BOULAXIS

69788 GREEK GOVERNMENT GAZETTE Series B- 1809/21.05.2018

Series B- 1809/21.05.2018 GREEK GOVERNMENT GAZETTE 69789