Responsibility in Action... for All. Printed on Recycled, 100% Non-Chlorinated Paper 100% Non-Chlorinated on Recycled, Printed

Responsibility in action... for all. Printed on recycled, 100% non-chlorinated paper 100% non-chlorinated on recycled, Printed

Sustainability WIND Hellas S.A. Report 66 Kifissias Avenue, 151 25 Maroussi www.wind.com.gr e-mail: [email protected]

CORPORATE RESPONSIBILITY WIND

1. Information regarding the Report The WIND Hellas’ Sustainability Report is the fourth annual Report that we issue and the third that follows the GRI Content Index. This report covers the activities of our Company in Greece of the year from January 1st 2010 until December 31st 2010. At WIND Hellas we are committed to adopt Corporate Responsibility policies and practices in terms of our Governance method and our Human Capital, with regard to the Environment and the Market and, finally, in relation to the whole Society. All these themes are included in the strategy “In Action” under which we validate all our actions. This publication was based and developed on the following axes: - Approaching stakeholders by means of the Corporate Responsibility Strategy - Corporate Responsibility in Corporate Governance, for the Environment, in Society, at the Market, for our Employees. Under this framework the Report’s essential sections relate to our Company’s financial, environmental and social impacts, which are the issues that influence our stakeholders. This publication constitutes an action of our Company, which has the purpose of initiating improved communication channels with our stakeholders, while achieving broader promotion of the Corporate Responsibility concept. Determining Indices & Gathering Information Our Company’s Corporate Responsibility Committee is responsible for gathering all evidence and information and for ensuring clarity and reliability of all data; this Committee is made up of executives from all of the Company’s major departments and divisions and is competent to prepare the Report, by coordinating the collective work of all divisions. Data and evidence for the particular Report were based on the following elements: Our environmental operation performance, as evidenced in our internal recording, auditing and verification processes, as well as on the basis of the International Accreditation Standard ISO 14001, under which our Company is certified; Information regarding our social impact, as reflected in the official records, surveys and data regarding quality, health & safety and human resources issues; Financial data coming from our financial department, which are in accordance with our annual financial statement. This year we have tried to register the impact of our operation on more parameters, by developing more indicators & indices, according to accepted standards. However, we acknowledge that the preparation of this report has been restricted by certain constraints, as for example the lack of measurable objectives for each of the programs we develop or the evaluation of the completeness of the content by an independent body, parameters that we intend to address in the future. In order to determine and develop the content of this Report, as we did in the previous years, we have taken into consideration the core business of our Company, in terms of being a telecommunications provider, the Sustainable Development Principles, as they are defined in the UN Global Compact, issues that concern our stakeholders as they have been determined according to the Principles of Inclusivity, Materiality and Responsiveness, as well as version G3 of the Global Reporting Initiative Guidelines, which constitute the framework under which we can monitor our environmental, financial and social impact. The GRI Content Index can be found on page 92 of this publication and the Assurance Statement of the requirements for GRI application level B+ on page 98. 2. Message from the Chairman of the Board and CEO Dear Friends, 2010 was a year that raised many issues and challenges for our company, as well as our country and the Greek society at large. It became clear to all of us that the market was undergoing fundamental and rapid changes as a result of continuing economic pressures. Additional regulatory and competition pressures changed even more the face of the telecommunications industry. These adverse conditions affected WIND Hellas business and made it imperative for us to change our financial structure in order to remain strong. To this end we initiated and successfully concluded a restructuring process which led to a new shareholder structure as well. Since December 2010, WIND Hellas is owned by a group of international investors acquired our company by making the largest private investment in Greece, of the last two years. This development has rendered WIND a stronger company, allowing us to step forward, to invest and work confidently towards growth. None the less, we acknowledge the fact that macroeconomic conditions will continue to challenge our goals. Within this framework, Corporate Responsibility as a principle and an action remains relevant more than ever as a critical part of our business operation, both internally, as well as externally. Looking inside the company, during 2010 we continued to streamline our processes and structure, thus creating a lean and efficient organization. This is an ongoing effort: as our environment changes, so do we. We also changed the way we do business. It is our responsibility to offer our customers the best possible services and 2010 was the year that we did so in many ways. On one hand, we fully integrated our IT platforms and telecom infrastructure into a unique network that delivers mobile and fixed telephony, as well as broadband Internet services. I am proud to say that we are the only operator in Greece able to do this. On the marketing front, we revisited our offers in order to make them simpler, fairer and closer to the consumer needs and patterns. Our motto, “For All”, captures the exact essence of this strategy. In doing so, we made sure that our network investments would bring the benefits of the digital world to the greatest extent, striving to avert the digital divide in our country. This is an issue of responsibility that matters to us a lot and a defining angle of our growth plans. Our goal for 2011 is to initiate a network modernisation that will upgrade our mobile broadband capabilities all over the country, within a period of three years. At the same time, we need to be environmentally responsible and continue to reduce our ecological footprint. Our commitment is to save energy, increase recyclables and contribute to green actions. 2010 was another yet year of great results in these fields, as you will be able to read further on in this report. This Report will also give you a clear picture of our last year’s social return as implemented through our Corporate Responsibility strategy ‘In Action’, but also through the implementation and development of the 10 Principles of the UN Global Compact, which have pledged to support. As a socially responsible Company, we aim to make a difference through specific actions in the areas of education, culture and social support. I believe we do have good stories to tell as a result and most of all, that our actions have had a positive impact upon people’s lives.

Nassos Zarkalis Chairman of the Board and CEO 2010 Landmarks

Commencement of the Company’s Financial 6/2010 Restructuring Procedure

Completion of the Mobile, Fixed & Internet Information Systems Integration. For the first 7/2010 time in the telecommunications sector in Greece a single IT platform is created for all services

Launch of the WIND e-shop, through which 7/2010 every user can activate a new Mobile, Fixed & Internet connection

3. WIND Hellas Creation of the first single communications network in Greece. Completion of the 10/2010 integration of the Mobile, Fixed & Internet at a glance network infrastructure

WIND One. Launch of a new generation of 10/2010 communication products, based on the integrated Mobile, Fixed & Internet communications network

WIND is acquired by six (6) International 12/2010 Investment Funds, which is the largest private investment in Greece in the last two years

Foundation of Largo Limited holding company, 12/2010 which undertook overall control of WIND Hellas WIND ... in numbers

18 years in the Greek market 385 Stores (POS) 90,9 million € total investment in infrastructure 1.506 employees 3.824.000 customers of fixed and mobile telephony 99,61 GSM network coverage & 80% 3G UMTS 4.000 km National Fiber Optic Network 14,55 % waste reduction we produced by our operation 90 tons of paper savings through the reduction of the use of paper 200 base stations with new radionetwork equipment, friendly to the environment 10 years of continuous program implementation Journey in the World of Knowledge 17.902 training hours in technical knowledge and administrative skills 11,5 million € insurance contributions 05 4. WIND Hellas In order to develop infrastructures, WIND since its establishment has implemented investments amounting to 2 billion €, which constitute one of the largest private investment projects in our country.

Telecommunications constitute a factor of progress and growth, since they are one of the most dynamic sectors of the Greek Economy. In particular, Mobile Telephony is one of the “steam engines” of the economy, with 2% annual GDP contribution. The private capital that the Mobile Telephony sector has invested, since 1992, has exceeded the amount of six (6) billion € and has significantly contributed to the National Competitiveness and Productivity as well as the Labour Market. It is estimated that the mobile telephony sector today employs, directly and indirectly, more than 70,000 people, with annual gross income of 2.2 billion €. During its 18 years of operation, WIND Hellas Telecommunications SA has been established as a pioneer in mobile telephony technology and has launched innovative products that have managed to make a real difference in the consumers’ communication habits. In 2007 WIND acquired and merged with Tellas Fixed Telephony & Internet Company, thus initiating one of the largest network infrastructures’ and IT systems’ integration project at a European level. In 2010 WIND concluded the integration of the Mobile, Fixed Telephony & Broadband Internet Infrastructures; integration, which resulted in the creation of the first single telecommunications network in Greece. In December 2010 a totally new era has begun for WIND, after the successful acquisition of the company by foreign investors. The new shareholders have a long term presence in the financial sector, especially in the telecommunications field. After the acquisition of WIND Hellas the shareholders have also proceeded with direct investments in order to finance the company’s growth, thus assuring its long term prospect. Today, WIND Hellas is the only Greek Telecommunications Company, which offers Mobile and Fixed telephony & Internet Services to consumers in a single package, from one sales & service point and with one single bill. The seat and headquarters of WIND Hellas are in Athens, at 66 Kifissias Avenue, at Maroussi. The Company has also offices in Thessaloniki, Patras, Larissa and Herakleion.

07 Our new integrated telecommunications network is environmentally friendly, as it is constantly updated, and its operation requires up 4.1. Our Company’s Telecommunications Network to 30% less energy consumption, thus decreasing the Company’s energy footprint. Our integrated network can offer high flexibility, extended coverage & guaranteed quality communication services to Our network: all users, according to every subscriber’s personal needs and It reaches 100% Greek coverage for 2nd generation technology (GSM) choices for Mobile or Fixed telephony or Internet services.

It is based on a single architecture, which is characterized It exceeds 80% for 3rd generation (UMTS) by flexibility, reliability and simplicity. It consists of a It reaches 70% of the installed telephone lines all over the country single infrastructure, namely, a single platform for all in terms of Fixed telephony & broadband Internet services, with 250 telecommunication services, thus offering better voice and data collocation sites, which cover Athens, Thessaloniki and 80 more cities services and more than adequate capacity in order to cover in 48 prefectures demand during peak periods.

(Reference: 31/12/2010) 4.2. Our Store Network 4.3. Financial Growth

Having as our main objective to serve our In 2010 WIND Hellas Group proceeded with capital restructuring, customers’ needs, and to respond to all their which has attracted significant investors. In December 2010 the queries, WIND Hellas has developed a perfectly alternative strategies research procedure was successfully completed organised store chain throughout Greece. with the acquisition of all WIND Hellas Telecommunications S.A. shares by senior bond holders.

The new owners, six (6) of the largest international investment fund firms, have been operating in the financial sector for many years, focusing particularly on the telecommunications field. After the acquisition of WIND Hellas, they proceeded with direct investments amounted to 420 million€, in order to finance WIND Hellas’ long term growth and business plan.

This investment constitutes one of the largest foreign private investments in our country in the last two years.

At the same time, Largo Limited holding company was founded, which has the overall control of WIND Hellas. The Board of Directors of Largo Limited is responsible for the Company’s strategy and the implementation of the business plan.

The new WIND Hellas capital structure and the commitment of its new shareholders for its full support, provide to the Company the opportunity to enhance its commercial efforts and to exploit its strategic competitive advantages in order to expand its presence in the Greek telecommunications market.

2009 2010

Turnover 1.073 m € 804,7 m €

Investments 131,3 m € 90,9 m €

Insurance contributions 13,5 m € 11,5 m €

Mobile and Fixed Telephony Customers 5.750.000 3.824.000

Number of Stores (POS) 393 385

Employees 1.592 1.506 (Reference: 31/12/2010)

09 4.4. Distinction WIND has received the CSR Excellence Award ranking first in the category Society: Youth and Education for implementing the program WIND Hellas has been distinguished for its social contribution of donating technological equipment to remote schools of our during the award ceremony for the Corporate Social Responsibility country, which is entitled Journey in the World of Knowledge. Excellence Awards that was organised by the Greek Advertisers Association (SDE) for the 5th consecutive year. The program is being consistently implemented each year, during the last 10 years, and has already equipped 344 schools in 14 prefectures in Greece. 4.5. Memberships WIND Hellas is a member in a significant number of institutional bodies and organisations. By means of its participation in

Governance bodies

Various programs or Committees

Unions and international/national rights organisations aims at know how exchanges, commitment for responsible entrepreneurship, promotion of the current demands of the telecommunications sector in a transparent and institutionally sound way, both in Greece and internationally, considering that being a member of these bodies is of strategic importance.

Under this framework, WIND Hellas participates in

Bodies promoting sustainable development: • Greek Global Compact Network – United Nations • Greek Network for Corporate Social Responsibility • Hellenic Marine Environment Protection Association (HELMEPA) • Institute of Communication • Hellenic Federation of Enterprises (SEV) - Council of Sustainable Development

Professional bodies: • The Greek Mobile Telephony Association (EEKT) • SEV Hellenic Federation of Enterprises • Commercial and Industrial Chamber of Athens • Greek Association of Communication and Information Companies (SEPE) • European Competitive Telecommunications Association (ECTA) • GSM Association Europe- GSM Operators Forum • Mobile Challengers

11 5. Responsibility in Action... Our commitment is reflected on the Internal Governance Structure of our At WIND Hellas, we recognise Corporate Responsibility. the important role that both the Direction of Corporate Board of Corporate Affairs - Corporate Responsibility telecommunications sector and Directors Responsibility Department Committee our Company have upon our lives. The Board is It is responsible for It is responsible responsible developing Corporate for collecting Based on the significance of for planning Responsibility information our business activity for our and applying programs & activities and preparing the Corporate both inside our the Corporate customers and the whole Society Responsibility Company and beyond, Sustainability Strategy to communicate with Report and to and considering our impact on the our stakeholders and generally to generally coordinate promote the Environment, we incorporate in the Corporate Responsibility Responsibility our daily practice a multifaceted Committee to publish mentality in our the Corporate Company Corporate Responsibility Strategy, Sustainability Report which addresses both our people and the Society in broader terms. Under this framework, at WIND Hellas we have adopted the Corporate Responsibility Strategy “In Action”. The goal of this strategy is to implement our responsibility policy in our Business activity, the Adopting Responsible Business Environment, the Society and the Market. Policies and Practices, based Thus, we commit ourselves to: on our Corporate Responsibility Supply responsible products and services with the aim to cover important Strategy, is our permanent social needs throughout the Greek territory, as for example the human need for communication priority, which is expressed via Minimize the environmental impact from our business activity focusing on our Company’s core commitment decreasing energy consumption, recycling materials and developing our network infrastructures in an environmentally friendly way and via the adoption of the UN Inform and motivate our people by encouraging them to become volunteers and Global Compact. active citizens Support those organisations and bodies, which, through their work, contribute to the protection of the Environment and support people in need, especially children.

CORPORATE RESPONSIBILITY WIND

13 The basic axes of our responsible action are the following:

Corporate Governance

• Responsible governance • Moral competition • Contact with social partners • Contribution to technological innovation Society • Support of socially groups Corporate in need • Contribution to local Responsibility communities • Provision of education opportunities

Human Environment Resources • Protection of the natural environment • Health & safety • Awareness campaigns • Personal development addressed to the general • Working rights public • Additional beneﬁts Market • Decrease our impact on • Working conditions the environment • Quality of products and services • Responsible marketing • Social product • Responsible procurements • Customer satisfaction 5.1. Our stakeholders

With the aim to improve our business performance and to assure our long term sustainability at WIND Hellas we recognise our stakeholders, which either belong to the internal environment of our organisation or the external one , Greek or Global, having as a goal the continuous two way communication with them, by systematically investing in the development of our mutual relations.

Our stakeholder groups are defined based on the effect of our business activity. According to this, we have acknowledged a process and followed a structured approach for properly identifying and mapping who our stakeholders are and the Media nature of our relationship with them on an annual basis. Thus, we ry Go Lo to v c a es er a make sure that we have accurately ul iti n l g r m e o e identified our stakeholder R th n u E t A xt groups and determined our key t e n rn stakeholders based on an internal e a m hol l n are ders e procedure, so as to engage with o Sh n ir v v i them in an open and balanced way. r S n o e u n l p m Based on that, we have created a a p s n e l i O r reliable mechanism for observations n e e C G t r t

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n y o a i t w a c o i n w u 3 . T . m R 2 e m c o a or C n d d ing op ch po alle rtu nges nities

By investing in the creation of communication and dialogue channels, at WIND we implement relevant policies and procedures so that each group of our stakeholders has access to information regarding our business activity but also the opportunity to express their opinions, thoughts or positions. On our behalf, we make an effort to be close to all of our stakeholders by means of surveys, interpersonal meetings and daily cooperation, always responding to their needs, concerns and questions.

All issues, comments and proposals that are gathered during our contact with our stakeholders are assessed and recorded with the aim to collect a set of actions that shall respond to the challenges and opportunities resulting from our two way communication.

In addition, when responding to such challenges, we always take into consideration the Company’s priorities, its strategic planning and, of course, the general impact that our communication could have on each party of stakeholders. Stakeholders Two way Communication Issues for discussion

Participation in consultations [1] Market Regulatory Authorities Participation in surveys [1] Quality of services Participation in conferences [5] Competition

Partnerships [4] Training Support [1] Health & Safety NGOs / Citizens’ organizations Meetings [2] Environment Social contribution

Meetings [5] E/M radiation Participation in local conferences / congresses [3] Financial development Central Government / Local Environment Government Support of local economy, social, cultural and educational institutions

Customer satisfaction surveys [2] Product and services technical matters Customer service centre [1] Service quality Customers (Individuals / Οn-line communication [1] Analysis of telecommunication charges Companies) Corporate brand survey [3] E/M radiation Hot line for complaints [1]

Support of scientific programs [1] E/M radiation Training seminars [5] Health & Safety Academic Community Awareness events/ conferences [5] Training Innovation External Environment

Press Conferences [2] Administration Media Trips [4] Financial and commercial results Field Trips [3] Regulatory issues Media Meetings [1] Service quality and network coverage Press releases & presentations [1] Technology & innovation Social contribution Environmental operation

Work visits [4] Procedural matters Participation in professional associations [5] Financial matters Suppliers Continuous information and support [1] Timely delivery Safe delivery conditions for employees

Regular shareholders meetings [1] Financial growth / results Targeted communication [2] Governance Shareholders Conference calls [2] Investment plan Strategic choices Social and financial developments

Magazine WIND About [3] Training Newsletter Eco News [3] Health & Safety Employees Ιntranet [1] Equal opportunities for career development Events organisation [3] Meetings with employees’ union [1]

Εxtranet (communication system) [1] Corporate governance Commercial conferences [3] Training in new products and services Internal Environment Commercial network Meetings with sales managers [2] Continuous information & support [1]

[1] On a permanent basis [2] Regularly [3] Periodically (2-4 times/year) [4] On an annual basis [5] Ad hoc basis

17 5.2. We responsibly approach the issues of our stakeholders

Important Issues Continuous information & support

Electromagnetic Nowadays, mobile phones are an indispensable part of our lives and almost all of us enjoy the advantages of mobile telephony. However, Radiation we do know that there are people, who are concerned about the impact of the base stations on human health and the environment in general. We take such concerns very seriously and we try to balance the needs of our customers with the demands of the broader public. We take all precautions in order to deploy our network in a secure and responsible manner, taking a step further beyond the fulfilment of our legal obligations, including among others: • Compliance with the strictest exposure limits, which are foreseen by legislation and by competent international organisations • Cooperation with local authorities whenever we construct new base stations • Construction of joint base stations in cooperation with the other mobile telephony companies We are informed of all new findings related to health & safety of the mobile telephony networks We have compiled a guide which includes useful documented information and data as well as a list of all competent bodies, whom citizens can address regarding any concern about electromagnetic radiation issues.

Measurements & We systematically proceed to audits and measurements either in the framework of licensing specific base stations or in response to citizens’ Audits requests. In 2010, we realized 88 measurements. In 2010, the Greek Atomic Energy Commission (GAEC), in the framework of sample checks, but also in response to requests submitted by natural entities, has undertaken measurements in 1,553 antennae stations, 27% of which belong to WIND. With the view to assure the reliability of our measurements of the electromagnetic radiation levels in the sites where antennas are configured, in 2009 WIND’s laboratory for Measuring Electromagnetic Fields initiated all the necessary procedures so that, in 2011, to be granted the Accreditation Certificate from the Hellenic Accreditation System (ESYD), in accordance with the requirements set out by the standard ELOT ΕΝ ISO/IEC 17025.

Environmental We modernise and upgrade both our equipment infrastructure and facilities with the view to providing high featured services to our Impact of Base customers while protecting the environment, via investments that contribute to reducing pollutants and saving energy. The energy Stations which is saved by the new equipment we have installed amounts up to 50% per base station. For the operation of Stations in places that are not easily accessible, we invest in hybrid technologies in order to save fuel and to reduce polluting emissions. The use of these new hybrid systems is expected to lead to nearly 70% of fuel savings or to an emission reduction of approximately 10,000 tons of equivalent carbon dioxide.

Supporting We strongly believe that telecommunications in a modern society constitute a vehicle of progress, social cohesion and prosperity. Thus, Groups in Need we make available our technological infrastructures and resources to the society as a whole or to specific bodies, the objectives of which we support, by means of the creation of special social services. In this way, we have developed: Programs for Disabled People Free of charge Hot Lines (“I Offer” Service, Médecins Sans Frontiers, SOS “The Child’s Smile” Hot Line, Amber Alert Hellas, European Help Line for the Child, Children and Adolescents Support Line - A.P.H.C.A.) Emergency Numbers FASMA Program

The FASMA Program consists of a network of fixed broadband measurement stations, which have mainly been installed in “sensitive” sites, such as schools and densely populated areas. The program has been developed and is being materialised by the Radio Communications Laboratory of the Aristotle University of Thessaloniki, which, due to its know how and proper equipment, can assure the validity of the measurements’ findings.

WIND supports this program in order to give the public the opportunity to monitor electromagnetic radiation levels in the environment on a 24 hour basis.

All measurements of the FASMA program find that electromagnetic field intensity levels are much lower than the limit set by the State.

Till the end of 2010, 32 measurement stations have been operating, while one of our goals for 2011 is to increase their number.

www.fasmaprogram.gr

5.3. We participate in actions that promote 5.3.2. Developing a communications network Responsible Entrepreneurship Principles By employing a clear strategy, we strengthen our presence 5.3.1. Supporting the Regions in initiatives that promote the development of technology and the telecommunications sector based on sustainability We systematically invest in actions that support our presence in the principles. regions aiming at bridging the gap and inequalities between the regions and the urban centres. May 2010: 2nd conference on Green IT and Communications Technologies entitled “Green ICT”. WIND March 2010: Conference entitled “The Internet as a place of creative supported the conference proving its commitment to freedom and promiscuity – Protection and Violation of Private Life”, development based on sustainability principles organised by the Scientific Association of Lawyers «e-Themis» at Arahova. May 2010: Telecommunications, Media and Technology Conference entitled ‘Building a competitive converged April 2010: Economist Conference entitled “What is shaping the industry in Greece’, where WIND participated as a Global Agenda” where WIND Hellas participated in the session telecommunications provider, which aimed to assess “Broadband infrastructure as leapfrog into the digital era” with a the new landscape that is shaping Greece and the speech by its CEO, Mr. Nassos Zarkalis. opportunities opening up towards creating effective goals and outlooks. May 2010: Conference entitled “Economy of Western Greece: handling the crisis” at Patras, with the participation of distinguished October 2010: 12th International Info-Com World personalities of the business community, who focused on the Congress entitled “Digital Greece: At the crossroad of significance of technology in handling the financial crisis. Broadband development”. The event was a meeting point for executives from the Telecommunications, IT and Media July 2010: 1st Pan-Hellenic Conference of TV Stations of the Regions, which took place in Athens, entitled “The Regions at the Centre” under Markets, who attended and actively participated in all the auspices of EPEK (Association of Regional TV Channels of Greece) sessions. and TEP (Greek Regional Television), which represent almost all Regional TV Stations of the country. WIND’s support and participation in this conference confirms both our trust to the local Media and our belief that local Media can play a critical role in the new digital era.

21 ...Corporate Governance, At WIND Hellas we have 2010 Achievements: defined the mission and the values of our Company Business Continuity System: completion of a large scale project in a clear and meaningful related to the IS Division way, by establishing policies and implementing Introduction of Corporate Responsibility principles in the Company’s quality policy practices, with regards to the environment, the quality of New composition of the Board of Directors with the participation of an independent our products and services, non executive member the protection of personal data and confidentiality of telecommunications. At the same time, by means of careful strategic planning, responsible administrative practices, audits and assessments of our daily operation, we ensure our respond to the expectations of customers, associates and the Society.

23 6. The Principles Supporting our Corporate Our mission Responsibility To supply high quality services winning the respect and appreciation At WIND Hellas we operate with a clear vision, mission and set of values of our customers, by deeply understanding their needs and fulfilling by following systems, standards and procedures, totally aligned with their expectations with reliability, flexibility and quality. the principles of responsible entrepreneurship, as they are defined by national and international standards. Our policies Our principles Quality Policy: We recognize and encourage change as the only way towards improvement. Our quality policy includes the Company’s vision, mission and values and governs all our Commitment operations. for results Environment Policy: We are committed to protect the environment in all our Company’s facilities and functions.

Innovation Quality and Environment Policy in the WIND Customer Stores: We are committed to offer high quality services satisfaction and products, through the constantly evolving chain of our Proactive response WIND Stores with respect to customers, the Society and the Environment.

The Quality and Environmental Policies are posted on all the working areas of the Company including the Stores, and they are Corporate Responsibility available to all our employees via the corporate network (WIND Leadership and intranet, WIND extranet). Professional superiority communicationCooperation Personal Data and Telecommunications Confidentiality Policy: We implement an internal and policy of data security and we impose it in all contracts with third parties, the scope of which relates to the access and

of urgency management of data of sensitive nature. Speed and sense

Our vision

To lead the Greek telecom market focusing on our customers’ needs and offering complete telecommunications solutions. 6.1. Organisational Structure

Our Company’s organisational structure is clearly defined and reflects its main functions. The responsibilities of each Division, each Department and each employee are detailed in written procedures and work instructions, which are kept electronically at the corporate network (WIND intranet) and are accessible to all.. In this way, we avoid confusion of functions and conflict of interest.

Board of Directors Chief Executive Oﬃcer (CEO)

Internal Audit

Chief Financial Oﬃcer (CFO) Chief HR Oﬃcer (CHRO)

Corporate Aﬀairs (CRP AFR)

Supply Chain & Facilities managment (SC & FMNG) Legal & Regulatory Aﬀairs (LRA)

Chief Network Officer (CNO) Chief Commercial Officer (CCO) Chief Information Officer (CIO)

(Reference: 12-2010) 25 6.2. Management Practice The Company’s current Articles of Association do not include any classification for the Board members in terms At WIND Hellas the Shareholders’ General Assembly is of “executive”, “independent” or “non executive”. Following the superior body of our Company, which takes decisions the decision by the Company’s Board of Directors dated with regards to issues that concern our Company. Furthermore, the Board of Directors, which consists of 16.12.2010 a distinction between “executive” and “non three (3) up to fifteen (15) members, has the power of executive” members was introduced, where one Independent managing, representation & asset management of the – Non Executive Member participates in the new Board of Company. Directors that is established pursuant to the above decision.

As far as the company’s decisions, with regard to Board members are selected on the basis of their day-to-day issues, an informal body is convened, which sensitivities to financial, environmental and social issues, consists of the CEO, Chief and Executive Dirtectors whilst the Company is in the process of creating a procedure (Executive Committee). This body does not have any with the view to determine qualifications and specialised formally assigned competencies or functions. However, expertise required by the Board members. The primary it takes major decisions, related to the everyday obligation and duty of the members of the Board is to operation and supervision of the Company, such as continuously pursue the strengthening of the Company’s handling serious issues and preparing the allocation financial position in the telecommunications market and the of issues and developing strategies. protection of the general corporate interest and objectives.

In addition, we implement policies and procedures, which aim 6.2.1. The Board of Directors at promoting transparency and avoiding conflicts of interest At the end of 2010, the Board of Directors (BoD) among the Board members. of the Company had three members and consisted of the Chairman and CEO According to our Company’s Articles of Association, it is and two members, forbidden to all the members of the Board of Directors as one Executive and one well as the Directors to conduct, for their own account or Independent, which is Non on behalf of third parties, any professional activities which Executive. Apart from the are included in the scope and mission of the Company or Chairman, the other BoD either to participate in any other organisation which pursues members take also part in a similar objective, without the permission of the General BoD meetings and decide together on the items of Assembly. At the same time, the members of the Board of the agenda, as these are Directors and the Directors have to timely disclose to the prepared according to the Board of Directors their own interests, which can occur from BoD competencies. the Company’s transactions, that fall into their competency, as well as any other possible conflict of interests with those of the Company or other affiliated firms. 6.2.2. Internal Audit Company. At the meetings the various goals are presented in the context of their progress during the year, so that they The Company has an Internal Audit and Compliance are all aligned with the Company’s priorities and the targeted Department, which is responsible to provide to the Board results. In addition to that, the executives have the opportunity of Directors independent, reasonable assurance that to express their thoughts and to submit proposals and ideas the Internal Control System ensures compliance with that are related to our entrepreneurial activity. the policies, practices and procedures of the Company. This is achieved by evaluating the effectiveness of risk Communication with the shareholders management systems, points of control and governance Communication with the shareholders is systematic, practices. The Management is responsible for internal regular and aims at their direct information with regards control. The Directors of the divisions at WIND Hellas are to the performance of the Company as well as the responsible to create appropriate policies and procedures, general developments in the Greek market. This two-way in order to help the organisation achieve specific communication has as a goal to set the strategy for the objectives. implementation of the Company’s investment plan. The organisational independence of the Internal Audit is achieved due to the fact that the Internal Audit Department at WIND Hellas refers directly to the 6.3. Code of Conduct Board of Directors through the Audit Committee. The By means of preparing an internal policy, we fully implement Audit Committee evaluates and supports the work of Community and National legislation regarding protection of personal the Management, ensures the adequacy of human and data and confidentiality of communications. In addition, we fully technical resources and a total access to information implement and contractually bind third parties to apply specific related to audit work. Codes, which have been issued by the EETT, have been concluded and implemented among the Mobile Telephony Service Companies with regard to the following issues: 6.2.3. Communication with the Management a. Consumer protection (1. Code of Conduct for the provision of Continuous expansion of the communication channels Electronic Communications Services to the Consumers, EETT Decision and the constructive two way communication between 488/82/30-7-2008 and 2. Code of Conduct for the provision of Employees and the Management contributes to timely Multimedia Services, EETT Decision 451/10/1-10-2007, as in force); and notification of all parties of any new development related to the Company, such as the essential handling of every b. Protection of minors (1. Code of Conduct for value issue or need that emerges at the HR level, with the view added services via mobile phones and the protection of to further strengthening constructive dialogue and the under-aged users; and 2. European Memorandum for the cooperation between teams. safe use of mobile phones by children and young adolescents), In this framework, regular meetings are held between which are contracted and implemented among the companies providing the CEO and executives from all the departments of the Mobile services.

27 6.4. Transparency – Corruption Handling

At WIND Hellas, we are committed to operate with No cases of breach of the regulation articles related to assurance of integrity by applying a set of procedures aiming to transparency and treatment of promote transparency and avoid corruption practices; such corruption were reported in 2010. procedures are implemented over many Company functions so as to timely handle any business risks that might relate to corruption.

Besides our procedures, transparency in working relations, employment of sound business practices by our employees 6.5. Quality Management Systems as well as the prevention and handling of corruption cases and Accreditations are further assured and strengthened by the “Internal At WIND Hellas, we have developed and we Work Regulations” Code for the Company’s personnel. The implement an Integrated Quality and Environment aim of the “Internal Work Regulations” Code is to promote Management System, which covers all our activities the implementation of moral principles and to establish and facilities, aiming at our customers’ satisfaction a code of conduct for all employees, based upon respect and at assuring the protection of the environment. of the law and promotion of transparency and ethics in This system is certified according to the all our activities, as well as the creation of a healthy, safe requirements of international standards and includes and pleasant working environment. The “Internal Work the following: Regulations” Code is accessible to all employees via the WIND intranet. Design, Development, Provision, Sale, Billing and Support of Integrated Telecommunications Any confirmed disciplinary offenses and infringements Products and Services (Mobile and Fixed Telephony, with respect to the regulation’s provisions are examined Data, Internet and Broadband) for Individuals and and treated on the basis of the disciplinary procedure, and Companies; penalties are imposed when necessary. Design, Development, Implementation, Operation, Support and Maintenance of Telecommunications In order to avoid any cases of corruption related to the and IT Systems Infrastructure, Telecommunications operation of procurement, the Company defines formal and Data Networks, IT Systems and Applications; procedures to follow when selecting and assessing suppliers Design, Development, Monitoring, Control and at all specific check points and approvals of all orders or Support of the WIND Stores’ chain. ongoing tenders. The main objectives of the system are the Quality Management System certified according protection of our customers’ and the Company’s to the requirements of the international standard interests, including the safety of our employees, ISO9001:2008 by TUV Hellas Accreditation Body our associates and the visitors in our facilities, but (TUV Nord Group). also protection of our commercial prestige, fame and value, against any serious risk event and/ or First accreditation: June 2001 business failure. Certificate record no 04 100 011460 Last renewal of accreditation: April 2010, The system foresees the continuous information (according to the requirements of the reviewed and training of the employees in matters of standard ISO9001:2008) business continuity management thus further enhancing the organisation’s strength and Environment Management System certified assuring an efficient response that shall also according to the requirements of the international standard ISO14001:2004 by TUV Hellas Accredita- include efficient event management. tion Body (TUV Nord Group). The Business Continuity Management Team that has been established aims at implementing, First accreditation: December 2008 developing and maintaining this system by Certificate record no applying the principles of the international 44 104 090360-000 standard BS25999 in the organisation.

6.5.1. Business Continuity Management

The Business Continuity Management System, which we have designed he Org at WIND Hellas, recognises possible threats and the adverse impacts n t an i Understanding iz that these could have on critical functions of ours, or on significant M the organization a C t io business units or systems, and thus on the seamless provision of B n

g ’ services to our customers. Exercising, BCM Deterrmining s n maintaining, BCM

i Programme C

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u d Management

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e u

r b

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m implementing E a BCM response

BCM lifecycle (source: British Standard) BS25999

29 Actions implemented successfully in 2010 Designed… …Implemented

√ Completion of a large scale project for the IS Division. Completion of a large scale project for the IS Division. The project was completed in 2010 after the successful implementation of the following phases: -Analysis of Business Impacts in the operation of IS Division by focusing on the services rendered to our customers and the services to the information system users -Analysis, prioritisation and classification of risks that could threaten the smooth operation of systems and employees’ work -Strategy of Business Continuity and proposed Business Continuity Plans

√ Further development & implementation of Business Continuity in other We continue to implement and improve the existing Business Continuity business units of the organisation, following the proposed framework of System in all the organisation’s business sectors 2009; reviewing, additionally, the general strategic business plan of the Organisation as well as the Management’s priorities

√ Re-assessment of the existing strategies and further development of We have analysed business impacts, we have implemented risk critical function recovery plans in various sectors and areas where management in the IT network sectors and we have developed recovery business continuity projects have been completed. strategies. We have proposed a series of projects aiming at the efficient response of the IS Division in case of adverse events that could seriously influence systems and services.

√ All departments’ employees information and training programs in During the implementation of various projects in the Company’s Divi- business continuity matters, where similar business continuity projects sions, we have developed awareness campaigns and training workshops are to be implemented in order to inform all employees particularly the top management of the importance, the basic principles and the methodology of business continuity Goals 2011

The review and implementation of additional mechanisms in order to further reduce conflict of interests and to enhance transparency.

The exclusion of possible cases of corruption that may arise from unauthorised or incompetent endorsements, by strengthening the mechanism to automate the procedure of the approval of orders, thereby ensuring more effective control.

Further development of Business Continuity System, the annual reassessment of existing strategies and At WIND we have made important plans to further develop critical recovery functions in « different sectors and areas where business continuity steps with regards to corporate respon- projects have been completed (e.g. Network, Customer sibility. We now know very well that our Service, IS Division) Company’s financial development is closely related with the course of the Society we do business in. Implementation of training and information » program: the aim is to continue the training (through workshops) of employees in sections where similar George Rallis projects of business continuity will be developed. CFO and member of the Board of Directors

The accreditation of WIND’s laboratory for Measuring Electromagnetic Fields by the National Accreditation System (ESYD) in accordance with the requirements of the standard ELOT EN ISO / IEC 17025.

The control and verification –on a random basis-by the Internal Audit and Compliance Department, of the data collection process for the annual Corporate Responsibility Report.

31 ... Society, At WIND Hellas, according to 2010 Achievements: our Corporate Responsibility 10 years of continuous implementation of Strategy In Action, we respond the program Journey in the World of Knowledge to the needs of our Society and we actively contribute Materialisation of an outdoors basket ball court at Aharnes, under the framework of to the improvement of the program Children Win the quality of life of local Participation of 130 schools in the Sustainable School Award communities in association Creation of an awareness campaign with with bodies and institutions regards to safe mobile and internet use for children and young adolescents that promote welfare and improvement of the citizens’ living conditions.

33 Journey in the World of Knowledge 10 years - 344 schools - 14 prefectures

7. Our activities We develop programs and actions having as a goal to inform, relieve and encourage citizens, according to the Table of overall Data of the Program areas of our activities on the following pillars: “Journey in the World of Knowledge” Education, Child, Social Support, Environment and Year Number of schools Region Culture. 2001 15 Evros 7.1. Education 2002 24 Dodecanese Our permanent goal is to promote education by laying strong 2003 45 Epiros foundations for learning and by providing the opportunity for equal access to knowledge for everyone, while supporting 2004 39 Chania remote regions of our country. On this basis, we implement 2005 42 Northern Sporades actions and programs with long term perspectives. 2006 38 Rodopi & Xanthi Under this context, in 2010 we proceeded to the 2007 54 Messinia implementation of the following projects: 2008 44 + 8 Fthiotida & other areas Journey in the World of Knowledge 2009 12 + 11 Arcadia & other areas In 2010 our Company’s initiative entitled “Journey in the World of Knowledge” celebrated its 10th year, having offered 2010 12 Herakleion (Crete) until today technological equipment to more than 344 Total 344 schools in 14 prefectures in our country. Career Days The 2010 action included the creation of 12 digital classrooms in 12 schools in Herakleion Prefecture, offering By being constantly and dynamically present in the most important in this way to both pupils and teachers the innovative Career Days Events of some of the largest Universities and Academic technology of the digital interactive board. The learning Institutions we have the opportunity to meet University students, experience through the digital interactive board motivates graduates and professionals from several disciplines. In this way, we the entire class, assists and encourages pupils so as to come into contact with potential future “executives” and we promote actively participate in the teaching process. By taking into our activities towards a dynamic audience, which consists of the advantage the infinite capabilities of broadband services, professionals of tomorrow. schools are transformed into contemporary education We contribute to career orientation of the young people centres, thus reducing the digital gap and eliminating any inequalities between the regions and the major cities Since 2001 up until today, we have realized six (6) “WIND Telecoms of our country. Career Day” Events under the subject “Employment and career prospects at WIND”. During the Events, our Company’s executives present to the young participants a snapshot of the working environment at the mobile telecommunications sector and inform them of the perspectives for employment and career at WIND. In addition, young people have the opportunity to participate in special preparation workshops to enter the labour market as well as interviews with our HR executives and representatives from various Departments of our Company.

7.2. Child

The right of all children to a proper psychological and physical development, smooth socialisation and access to equal opportunities are significant priorities for all of us at WIND. Aiming at our active contribution to the improvement of children’s living conditions in 2010 we implemented actions to support various organisations. In particular:

Children Win

We continued and expanded our successful campaign Children Win also for the game period 2010-2011 headed by the two leading Greek basket ball players: athletes Thodoris Papaloukas and Dimitris Diamantidis. In 2010, we fulfilled our promise and delivered to the children of Aharnes Municipality their new outdoors basket ball court, showing in action that we support the local community and we assist young people to come closer to sports and sporting values.

In the period 2009-2011 this particular social campaign was extended; thus, apart from the money that we collected by each point scored by the two basket ball players in the Greek Basketball League, we have also included every goal of the football teams SKODA Xanthi and Ergotelis, aiming at financially supporting the Psychological Centre of Northern Greece (Xanthi Department), the Centre for Children with Special Needs “Zoodohos Pigi” and the Centre for Children with Special Needs “Agios Spyridon” of the Herakleion prefecture in Crete, respectively. 35 As a result, the Ark achieved its goal in terms of purchasing the building which will become the shelter for the Daily Care & Support Centre of Mother and Child.

The Ark of the World

Under the framework of supporting the multifaceted work of the Ark of the World for the creation of a Daily Care & Support Centre The Ark was awarded as one of the best for Mother and Child, we have designed and implemented an organizations in the care of children in Greece elaborated plan of actions with essential benefit for the Ark. in November 2003 at the Old Parliament In particular, we have extended the scope of the program by the former President of the Republic Mr. Children Win via which for each point scored by the Olympiacos Konstantinos Stefanopoulos and in December basket ball team in the EuroLeague Final Four in Paris we offered 2005 by the current President of the Republic 1000 Euros to the Ark of the World. Combining the power of Mr. Karolos Papoulias. In December 2004, the Olympiacos and the commitment of WIND for social assistance Arc was awarded by UNESCO for its work, and in each point in the games became a basket of love for the children December 2008 Father Antonios was awarded of the Ark of the World. In addition to that, a core commercial by the Academy of Athens for his exceptional collaboration for the new WIND advertisement campaign volunteering work. starring “Radio Arvyla”, was transformed into a social solidarity Finger Prints 2010 contribution. WIND supported a unique art and craft exhibition with the The overall compensation fee of “Radio Arvyla” plus 2% of WIND’s participation of 1,300 children from 44 social organisations total earnings from WIND prepaid telephony card services for six and schools who created 850 works. months were given to the Ark of the World. The Finger Prints 2010 Exhibition, which was successfully organised for the 2nd year, is an initiative of the Association The Arc of the of Social Responsibility for Children and Youth (SKEP) with World gathers the collaboration of Vorres Museum. today 300 children approximately “Finger Prints” is an art and craft exhibition that gathers –from infants to works made by children and teenagers, who very seldom eighteen years old- have the opportunity to create together such as children in a multi-religious from special schools, institutions, social organisations, and multicultural working side by side with students from the primary, community. secondary and tertiary educational level. When they paint all together, they have the Safe Use of Mobile Phone & opportunity to build relations of understanding, Internet by Children – Advice to Parents respect and acceptance through their work. Mobile telephony services, internet access and the mobile phone More than 2,000 people, children and adults are basic tools of communication for children and young adolescents. have visited the Museum in order to honour the WIND, as an integrated telecommunications provider (mobile, fixed telephony & internet) under the framework of Corporate Responsibility, effort of the children and to support the social implements a series of actions aiming at informing and guiding both organisations that participated. parents and children with regards to the safe use of mobile phones and the internet. The Lyreio Children’s Foundation In this context, during the last few years, we systematically publish During the last 5 years at WIND we consistently printed material with advice to parents so that their children make support the Lyreio Children’s Foundation covering safe use of new technology. on an annual basis their school items’ expenses, In 2010, aiming at further promoting the safe use of mobile phones & as well as offering state of the art technological internet by children & young adolescents, as well as offering a complete equipment for the children’s educational needs informative campaign for parents on this particular issue, we initiated a collaboration with the Association for the Psychosocial Health of Children and caring for their entertainment by organising and Adolescents (A.P.H.C.A.), and Professor Ioannis Tsiantis (MD, DPM excursions and visits to theatrical plays. FRC Psych., Deputy Professor of Child Psychiatry, Scientific Officer of A.P.H.C.A.) in order to create an integrated social awareness program entitled Kids@safety, internet, mobile and child, which is materialised by means of various informative events, as for example promotion campaigns, printed information, online communication, training videos, special printed material, which is available in our Stores, conferences at schools, etc. At the same time, we also conducted a qualitative survey regarding the use of Mobile Phones and the Internet by Children while we also supported a quantitative survey with similar content conducted by the NGO “NEOI” based in Thessaloniki.

37 7.3. Social Support In 2010 we supported the Aegean Team sea crossing, which was realised for the 16th consecutive year. The members of the Aegean Team, with We recognise the important contribution of various organisations with 11 speed boats accompanied by the ambulance boat “Minas E”, visited regards to the support of social groups in need. Thus, it is our commitment patients at Sikinos, Amorgos, Koufonisi, Patmos, Arkioi, Leipsoi, Agathonisi, to contribute to the effort to improve their quality of life through several Fournoi and Thymaina. Medical examinations, screening tests and programs and actions. In 2010, we supported the following actions: preventive checkups have been realised and also significant donations The Aegean Team of infrastructure projects were made, such as children’s playgrounds, a library, 5X5 football court, ambulance, equipment for kindergarten. The Aegean Team consists of doctors, lawyers, workers, businesspeople and other experts who, based on the values of social solidarity, volunteerism Titanes of Ahaia and collective action, attempts to contribute to the relief, support and Supporting the right for equal opportunities for the inhabitants of all enhancement of the life at remote islands of the Aegean Sea. Greek regions and especially people with special needs we have been supporting, throughout the gaming period 2010-2011, the local basket ball team of Athletes with disabilities, Titanes of Ahaia. Hellenic Rescue Team

WIND supports volunteerism in action and thus, it undertook The Sustainable School Award which is organised under the auspices of to cover all telecommunications needs of the Athens the Ministry of Education, Life Long Learning and Religion, addresses Hellenic Rescue Team (EOD). In particular, we offered free schools of primary and secondary level aiming at incorporating the internet access from fixed and mobile phones as well as concept of sustainability in every aspect of the daily life at school, Fixed and Mobile telephony services thus contributing to the namely administration, learning, building management, transport from volunteers’ effort to help all those who need organized and and to school, the relations of the school with the school community, specialized support. the manner to consume energy, paper, etc.

The Athens Hellenic Rescue Team is specialized in dealing with problems that occur after extreme weather phenomena, such as massive destruction, in the search and rescue missions on mountains and in the sea, in the provision of humanitarian assistance in Greece or abroad. All actions are included in the axis Provision – Treatment – Recovery.

The Team has been awarded the title of the best volunteers’ team by the General Secretary of Civil Protection for their overall contribution throughout Greece, ranking first in its participation in the rescue mission at Haiti. 7.4. Environment

At WIND Hellas the protection, improvement and restoration of the natural environment is our continuous priority. For this reason, we develop actions, which inform, sensitise and ultimately mobilize citizens of all ages. In addition, we support actions of other organizations, as for example HEMELPA, MOM, etc. Thus in 2010 we adopted the following programs:

Sustainable School Award

With the participation of more than 130 schools from Attica, Dodecanese, Thessaloniki and Korinthos, and aiming at students to develop attitudes supporting sustainable development and decreasing their ecological footprint, a new environmental awareness institution has been created by the Hellenic Society for the Protection of the Environment and the Cultural Heritage, with the support of WIND.

39 The Dolphin’s Path

For the 2nd consecutive year WIND invited all those travelling by yacht in the Aegean waters to contribute to the protection of the dolphins living in the Greek seas. This opportunity is offered via the environmental program The Dolphin’s Path, which WIND has created with the help of all of us. The goal of the program is to create a file log recording observations on the four (4) basic kinds of dolphins living in our country’s seas, namely common dolphin, bottle nose dolphin, striped dolphin and Risso’s dolphin.

Peoples’ response to the invitation of this environmental program via the webpage www.spotadolphin.gr, with comments, observations and the expression of various questions, constituted an encouraging sample of an essential attempt to record and protect the cetaceans that live in the Greek seas.

In 2010 the Ambassador of the program in the Greek seas was again the vessel WIND ZANTINO (www.windzantino. gr) that together with the other yachts participating in the Aegean Rally and the Ionian Rally brought about significant results. In particularly, participants have observed bottle nose dolphins in the areas east of Sifnos, south of Paros and north-east of Astypalaia , while during the period 16- 24 July the approximately 500 participants of the Aegean Rally observed many small bottle nose dolphins in flocks during the Paros- Nisyros and the Nisyros – Koufonisi sections of the rally. 3rd Mediterranean Summit on Sustainable Energy The Island

Under the framework of its awareness policy with regards to issues In 2010 we supported one of the most important and successful of Climate Change and Energy Safety, WIND has supported as a Greek TV series The Island, a production that promotes Greece and telecommunications provider the 3rd Mediterranean Sustainable reveals aspects of our country’s history. The series constitutes the TV Energy Summit 2010. The Summit took place in Athens in 18 & 19 adaptation of the novel by Victoria Hislop, which opens up a “new” page May 2010 after an initiative by the Institute for Climate & Energy in our country’s history, which many of us did not know. Security & Financial Times Business under the auspices of the The story is set in Crete and it describes, among various fictional President of the Hellenic Republic Mr. Karolos Papoulias. scenes, the events that took place on the island of Spinalonga the During the Summit, numerous participants from Greece and the time when residents on the island were people afflicted with Hansen’s Mediterranean countries had the opportunity to discuss matters disease. The series was an impressive success in terms of numbers of regarding alternative energy sources and sustainable energy viewers and managed to make modern Greeks “travel” back in time, in solutions in the Mediterranean. the difficult years from 1940 until approximately 1960.

7.5. Culture

It is our permanent commitment to support actions and programs that contribute to growth via the promotion of culture and the Greek regions. Thus, in order to offer our share in the broader vision for a better Society, in 2010 we have supported the following cultural actions:

Infertile Fertile Line

For the 3rd consecutive year we supported the Program Infertile Fertile Line, which is organised by the non- profit society “Diadrasi” and is under the auspices of the European Parliament. Infertile Fertile Line is a cultural institution that offers cultural and training workshops to remote Greek islands, in the so called “infertile line”. In 2010, the program travelled from March until April in five (5) islands: Irakleia, Amorgos, Thirasia, Astypalaia and Kastelorizo.

41 A journey to Mytilene For the first time, numerous people had the opportunity to enjoy a different experience in terms of listening Aiming at contributing to the cultural growth of the island of Lesvos and to more than 20 speakers approaching the event’s in an effort to preserve local music tradition, we supported in 2010 the subject from their personal perspective. Distinguished international first screening of the new film by the multi-award winning personalities, scientists, businesspeople, investors, director Lakis Papastathis titled A journey to Mytilene as well as a big social economists, artists, IT experts, innovation experts concert given by the music company of Agiasos’ “Anagnostirio”. and communication and management gurus all shared The events were hosted at the “Archipelagos” Company’s Elaiotriveio their thoughts with the audience in three basic sessions: (Oil Press) – Vranas Museum, a unique venue for cultural events. Vision, Values, and Action.

Under the context of this event, WIND created a 10th Festival of Exomvourgos Municipality communication space named “connectivity alley” where the participants spoke to our camera about their own WIND sponsored the Festival of Exomvourgos Municipality thus recognis- vision for Greece. ing its contribution to the cultural development of the island of Tinos during the last 10 years. The Festival’s Agenda, which lasted from the end of July until September, has included a series of events such as concerts, theatrical plays, visual events, activities for children and also the 1st International Literature Festival of Tinos.

1st TEDxAcademy in Greece

WIND supported the successful organisation of the Greek TEDxAcademy Event entitled “What Greece needs today: A new Vision”. Goals 2011

Development of projects and further expansion of the campaign kids @ safety internet, mobile & child with workshops, online content, collaborations with NGO’s, etc.

Emphasis on social groups, such as unemployed and children

Maintenance and development of The Hellenic Society for the Protection of the Environment the existing programs of the various «and the Cultural Heritage Committee (HELL.ET) with WIND’s categories we already support. support promoted our common vision to integrate the idea of sustainability in each aspect of the school’s life, namely, administration, learning, building management, transport Promotion of sporting activities that to and from school, relations of the school with the school improve the quality of life. community, the way the school consumes energy, paper, etc – and all these by means of the “Sustainable School Award”. TedxAcademy: to actively participate Our aim is that students adopt attitudes that contribute in 2011 and spread the results of the to sustainable development and decrease their ecological meeting to our stakeholders and the footprint. Our experience from the first year of the pan- general public. Hellenic application of the program is indeed very positive and encouraging. We are ready to continue at a higher level with the participation of a greater number of schools, so as to create the critical mass needed to make change possible at school as well as in the Society.»

Dr. Dimitrios Kalaitzidis Director of Ralleion Experimental Female Secondary College in Piraeus Chairman of the Board for Environmental Training at the HELL.ET

43 ... Environment, At WIND Hellas we recognise the 2010 Achievements: importance of protecting the natural environment in order Decrease by 14, 55% of our waste that was sent originally to landfills to assure both our present and our future; we consider that Increase of the percentage of waste that is sent to Alternative Management by sustainable development and 30.91% environmental responsibility Saving more than 90 tons of paper through is not only a significant factor the paper saving program for our operation but also the WIND Fleet: New services that contribute cornerstone of our socially to the decrease of carbon footprint of our customers responsible behaviour. Thus, we develop and drive our business activities in the telecommunications sector focusing on the protection of the environment and the principles of sustainability, dynamically responding to the challenges of our era.

45 8. Our environmental Policy and 8.2. Environmental Management Practice System Since the way to sustainable development presupposes At WIND we successfully implement -for the third undertaking direct action against major environmental consecutive year- an Environmental Management problems of our times, at WIND Hellas, without any delay, System, certified in accordance to the international we take action. Given that every activity has an impact standard ISO 14001, with the view to develop an upon the environment we focus on our own operation efficient and comprehensive approach towards the and we invest in sustainability by taking organisational environmental impact of our operation. measures and essential actions. Having this in mind, we ensure that:

we monitor systematically our environmental impact by registering every dimension of our 8.1. The Axes of our Environmental Policy operation that could possibly influence the environment;

we implement management programs aiming at reducing serious impact when it is not possible to prevent from the very start the tion of pollu vent tion development of every single impact; Pre we continuously monitor and abide by all new o f m R th e legislative regulations regarding the protection a e g n u e a l of the environment; e g n a c e v r n i m r r a i o e l e we check our system’s efficiency on an annual n v p n i m e t m w basis in order to achieve better results; s e o

y n

C s

a e

l we encourage all our employees to undertake

m an active role with regards to the protection of the environment, both inside and outside the Company;

n M io o t we continue to seek for new ways to further u in a s r i r e m rm e reduce our environmental impact at critical n iz o ld v a nf o i ir tio i h points, even under adverse situations. m on n & e p m of g ak ac en inin st t tal Tra ur of o 8.3. Raw Materials & Waste Packaging material

Kilos 2010 2009 2008 2007 2006 8.3.1. Raw materials use Paper-carton 25.830 55.390 118.060 144.600 63.890 Having incorporated in our culture the logic that raw materials used in the products and the services with which we supply the Greek market Plastic 51.230 72.180 120.630 184.570 78.020 are integrally related to the protection of the planet, we have concluded Wood 4.210 9.780 20.820 36.890 24.860 to strictly comply with the rule for the Rational Management of Raw Materials. Packages 16.780 31.642 46.853 50.384 21.919 In this way we contribute to the saving and efficient use of natural (thousands) resources while we also minimize, as much as possible, the total Total 81.270 137.350 259.510 366.060 166.770 environmental impact from the supply of our products. weight In 2010, this effort has resulted in the preservation and often reduction (source: HE.R.R. Co [Hellenic Recovery Recycling Corporation] reports) of the average weight per category of devices used in relation to 2009. A certain increase was noted in 2010 in the case of using packaging 8.3.2. Waste management material having plastic as raw material (pp, pet, etc) – this justifies the increase by five (5) percent of the average for year 2009 and 2010 – In order to preserve and support sound environmental aiming at replacing the old packaging with new one, with high quality management practices in terms of the solid waste from all characteristics, in order to better supply our products to the consumers. our activity, we operate under three principles Systematize, Monitor, Improve. The practices we implemented during the previous years as well as the follow up and implementation of new technologies in issues of environmental care, have helped us to draw conclusions and enhance our efforts in the sector of waste Average packaging weight/ management. 1000 items (Kg) 7.61 Our primary goal for the last three years has been the reduction of waste that we produced, which is forwarded to the already full 7.27 landfills. This effort aimed at the alternative waste management by means of Recycling, Reuse and Rational Discard, accordingly.

The contemporary implementation of an environmental policy in 5.54 the waste management field at a Community and International level as well as the need for efficient protection of the 4.34 environment and control of waste pollution, has set new targets 2006 4.84 and imposed a comprehensive treatment and a documented analysis of any environmental malfunction. It is known that solid 2007 waste is a serious source of pollution with serious consequences 2008 on the environment and, at the same time, an irrational waste of resources. 2009 The basic axes of the waste management policy we implement are 2010 defined by the Acquis Communautaire. Having that in mind, 47 specific guidelines are set and general waste management principles Alternative Waste Management (ton) are prioritised, such as: 2008-2010 Prioritised prevention of waste creation;

Promotion of waste reuse and recycling practices;

Other exploitation forms (materials and energy recovery), leading to the decrease of adverse impacts and the environmentally safe supply of our products.

We have achieved our objective with spectacular and encouraging 10 results. In our reports we observe that in 2010 we have decreased 20 30 the amount of waste produced by our operation* which is sent 40 50 60 to the already full landfills by 14.55%, namely 18 tons less, in 70 80 comparison to 2009. 90 100 110 2010 2009 2008 120 Waste production & management (ton)

2010 Landﬁll 104 Alternative Management In 2010 we have increased accumulators’ management by 12% in comparison to 2009, due to the regular maintenance of all equipment 2009 122 operating with 270 14.000 Recycling of Accumulators and accumulators, since 2008 12.000 Batteries 2007-2010 their life time is 206 limited. Accumulators 185 10.000 Batteries Accumulators that are replaced 8.000 are all delivered to 6.000 special accumulators’ 180 100.000 4.000 90.000 recycling facilities, 2.000 80.000 which remove all 70.000 0 heavy metals and 60.000 reuse them in order 50.000 to fabricate new 40.000 accumulators. In this At the same time, it is very encouraging the increase of waste 2007 30.000 management practices by 30.91%, namely 64 tons more compared 20.00 way, this kind 2008 0 to 2009 in terms of waste being forwarded to Alternative Management 10.000 of waste is managed 2009 Practices. 0 in the best possible 2010 *Waste from our Stores’ chain is not included manner. For the fourth consecutive year we observe more than 100% increase in the number of batteries that we have treated by means of the “AFIS”, which operates as a collection point for the public.

In 2010 we collected 11,817 kilos of batteries waste (EEEW) refers to a wide range of materials and in essence in the special vertical containers that have been constitutes the most complex kind of solid waste. Its complexity is due installed in all our facilities and stores. The number of to the large variety of raw materials used to produce electrical and battery pieces has increased by 6 percentage units electronic equipment (EEE) as well as to the large number of electrical during the last four years. Our coordinated efforts to and electronic products. sensitize the consumers with regard to the necessity to recycle batteries have led to significant results. Therefore, we are cooperating with all approved Collective Waste Particularly in the years 2009 and 2010 the recycling Management Systems. These organisations are non-for-profit bodies, percentage has increased by 69.32%, namely by which, manage and coordinate with the participation and collaboration 8,192 kilos in relation to the year 2009. The number of interested companies, the recycling and alternative management of battery pieces recycled is approximately 370,000* of certain kinds of hazardous waste also known as “specific waste units by means of the recycling body “AFIS”. streams”.

In 2010, we observed a spectacular increase in Collective Waste Management Systems the alternative management of “other” materials, per Waste Category including furniture, from the extended refurbishment Collective System Kind of Waste of our offices. The obsolete furniture items were A.F.I.S. (Recycling Small household classified accordingly and large numbers of these of Small Household batteries up to 1.5 kg were donated to individuals and organisations. All Batteries) remaining furniture was dismantled and their spare Appliances Recycling All kinds of parts were sent to recycling. Any material that could S.A. electrical and not be recycled was alternatively used as burning fuel electronic for energy production in properly licensed facilities. equipment Alternative management of waste that is considered SYDESIS (alternative All types of potentially hazardous for human health, according accumulator accumulators to national and European legislation in force, management system) determines that it is prohibited by law to discard such characterized hazardous waste in the natural ΣΥ.ΔΕ.ΣΥΣ environment or at landfills. Our Company’s Fotokiklosi Lighting fittings, harmonization with the legal framework in force leads lamps, equipment, to the exclusively specific management of any waste lights we produce that can be characterized as hazardous. Private waste management companies, which are properly and fully licensed At the same time, we have also included in the according to the legislation in force, are included in the list of our partners management process all electronics and consumable and they cover any case that cannot be treated by any of the Collective waste. The term electrical and electronic equipment Waste Management Systems (waste that is not covered by their scope). For 2010, about 10% of our waste was hazardous and 90% non-hazardous. * Approximately 38 battery pieces / kilo (AFIS calculation) 49 8.4. Towards a Paperless Future In 2010 more than 90 tons of paper Internal program to decrease paper use or respectively 1,530 trees, in terms of wood, were saved. At WIND we invest in paper saving infrastructures and procedures having as a goal to protect the environment and to complete our tasks in a more efficient way while saving resources. In this framework, we have completed a series of paper saving projects, such as:

development of an internal website In 2010, we successfully ceased keeping hard copies of electronic corporate document management our customers’ bill payment receipts – a simple move that replacement of printing and photocopying equipment with saved approximately more than 5,000,000 A4 pages or a more advanced technological system approximately 27 tons of paper.

provision of electronic bill (e-bill) to our customers and In addition, by replacing the receipt printing machines with employees different kind of equipment, we estimate that paper use is further decreased by 40%, since the printing size in use was digitisation of our customers’ signatures at our stores also decreased. From this project we saved approximately At the same time we continuously invest in removing obsolete 60 tons of paper (annual estimates) while we had multiple printing devices, such as fax devices. benefits, since printing is now faster and customer service is enhanced. Thanks to a transfer towards digital document management (digitisation) and automation of procedures, we estimate that At the same time, we invested in a new on-line application, that we save 50,000 A4 size pages every month or 600,000 annually facilitates communication among our Stores and the Company, or 3 tons of paper (which is 1200 A4 paper packs). and runs in an exclusively electronic context, thus eliminating fax copies or any other kinds of printed communication.

Finally, we activated a pilot project of electronic invoicing – e-invoice – namely the issuance and forwarding of invoices via the internet. The purpose of this project is to assure safe electronic transactions between WIND Hellas and its partners, in order to have a mutual benefit. It has been estimated that through this project we shall avoid printing and use of paper by approximately 8,160 sheets annually (this calculation includes only the cases of roaming invoices printed, while gradually more types of invoices shall be included in the project). Introducing rational water use policies in the employees’ bathrooms A4 Paper Purchases (packages) and the cleaning up of the premises. 2004-2010 23.000 20410 In 2009 we consumed 17,443 m3 of water, while in 2010 we had consumed 15,608 m3. We have achieved a significant decrease in water use by 1,835 21.000 18000 18000 m3, which reflects a decrease by 10.52% between 2009 and 2010. 19.000 16000 17.000 14500 Water Consumption (m3) 15.000 12000 11840 25.000 13.000 20.000 11.000 9.000 15.000 7.000 10.000 2004 2005 2006 2007 2008 2009 2010 5.000

0 Gradually, WIND has achieved a 40% decrease of A4 paper supplies thus saving thousands of tons of paper annually.

By recognizing that it is, currently, impossible to totally abolish printing, 2008 in 2010 we replaced the paper we use for printing and copying inside the 2009 Company with certain kind of paper with the following characteristics: 2010 Is certified with regards to its protection of the environment (ecolabel) Is produced in facilities accredited by ISO14001 8.6. Energy and Climate Change Is FSC certified (forest sustainability certification) 8.6.1. Energy consumption & related pollutants’ emission

8.5. Water Electricity consumption was slightly decreased in 2010, after an increase in 2009 due to the annexation of buildings and equipment of Fixed telephony With regards to water consumption our impact on the environment is minimal due to the scope of our activities. Nevertheless, we implement network. Total consumption amounted to 81.000 MWh while the CO2 emis- the best possible water management and consumption practices. sions were in respective levels.

In all cases, we control use of water in terms of: The slight decrease that was observed in office areas is due to the restriction of the total space used for offices. Furthermore, the decrease observed in Continuously monitoring the water supply network in order to detect any possible leaks; the telecommunications buildings and the Mobile and Fixed telephony stations is due to our equipment upgrade project whereby old equipments Avoiding purposeless water use in cases where plants are placed in the are gradually replaced by low energy new ones. office premises;

51 Electricity Consumption (MWh) Electricity Consumption (GJ) Total Oil Consumption (GJ) 60.000 250.000 300.000 Emissions CO2 (ton) 275.000 Emissions CO2e (ton) 50.000 200.000 2007 2009 250.000 2007 2009 225.000 GJ 2010 40.000 2008 2010 2008 200.000 ton CO2e 150.000 175.000 30.000 150.000 100.000 125.000 20.000 100.000 75.000 10.000 50.000 50.000 25.000 0 0 0

Oﬃce Buildings Oﬃce Buildings 2007

2008 Tel. Buildings Tel. Buildings

2009 Mobile and Fixed TelephonyMobile andStations Fixed Telephony Stations 2010

This graph illustrates both MWh consumption and CO2 emissions in tons since the conversion factor is 1kgCO2/kWh* (Source: Environmental Report by PPC for 2009). 8.6.2. We Invest in the Essence

Diesel fuel consumption derives primarily from those fuels that 8.6.2.1. Network Modernization supply the electrical power generators of mobile telephony base Under the framework of the three year sustainable development project stations that are not connected to the PPC power grid. Since the -for the years 2011-2013, we have invested 300m€ into our business decrease in 2010 of the number of such power generators in those plan. A large part of the funds allocated to the implementation of the stations, one has also remarked a decrease in the total diesel project will cover investment for the update and modernisation of the fuel consumption by approximately 750,000 lt. This decrease network as well as the upgrade of infrastructures for the equipment is particularly important since when diesel fuel is burned it pro- and facilities so as to provide high quality services to our customers, duces high quantities of carbon dioxide and other pollutants, such and protection of the environment, via investments that contribute to as ash particles. A decrease in diesel fuel consumption has also led a decrease of pollutant factors, such as decrease of emitted pollutants to a decrease in CO2 emissions by almost 2,000 tons. Since there is and energy saving. a greater number of pollutants per fuel unit coming out from diesel In this way, we plan to gradually proceed with the replacement of our usage compared to the consumption of electricity, our priority is Radio Network structural elements, as well as the entire first level of the to decrease diesel fuel consumption. In addition, since more than Transmission Network. The new Radio Network equipment will include 90% of the annual diesel fuel quantity is consumed on the power Single BTS and Multi-mode BSC Solutions, which efficiently support generators that are not connected to the PPC power grid, we plan multiple mobile telephony technologies, thus introducing to the WIND in 2011 to further eliminate and replace simple power generators Network the concepts of Convergence, Broadband, Energy Saving with hybrid ones, which shall operate with diesel fuel and accumulators and Development. combined together. 8.6.2.2. Power supply of remote Base Stations Since 2005, we implement the GreenLight program, an initiative of the European In order to provide full network coverage, even to the Union for the reduction of the energy most remote areas of the country, we have installed consumption by the lighting. and we operate Base Stations at not easily accessible locations, which do not have the capability to connect to the electricity grid.

For the operation of such Stations, it is necessary The new equipment that is being installed: the use of power generators supplied with diesel Gives the opportunity to develop new services fuel. Since burning diesel fuel produces significant quantities of carbon dioxide, at WIND we invest Improves the quality of the services provided on hybrid technologies in order to save fuel and Decreases operational cost to diminish the emitted pollutants. By combining power generators and accumulators, the Stations Requires up to 70% less space for its installation that have been operating until today consuming Saves energy up to 50% per base station diesel on a 24 hour basis, will now be operating only 4 hours a day on diesel fuel, while during the rest The first level of WIND’s Transmission Network will be updated with 20 hours all necessary energy shall be supplied by the introduction of a single transmission solution, which assures accumulators. The use of this new hybrid system very high speed, high capacity, high reliability and smart operation. The “All IP” protocol will be installed in the whole mobile telephony is expected to save fuel up to 70% or to avoid network. emissions up to 10,000 tons of CO2 on an annual base at all non connected Base Stations (Computing In addition, the new equipment utilises “smart” air conditioning tool: World Resources Institute (2009)/ GHG systems, which significantly reduce the need to cool areas with ProtocoltoolforstationarycombustionVersion 4.0, traditional air conditioning systems that consume too much www.ghgprotocol.org). energy, merely by using fans in order to facilitate the already existing air circulation to transfer and exchange heat with the 8.6.2.3. Information Systems external environment. In 2010 under the context of the international effort By means of the above, it is estimated that we can avoid the to save energy and resources in the Information emission of more than 7,000 CO2 tons thus saving more than Systems of IT Centres – the so-called Green IT – 7,200 MWh of electricity annually from the operation of mobile we have implemented an expansion of the system telephony base stations. virtualization which was already in operation during 2009 as a pilot action with positive results. According to the project schedule, modernisation of the WIND Through this system, we have succeeded to mitigate Radio Network has already started and until middle 2012 Athens and Thessaloniki will be amongst the first cities to be ready, 150 physical systems to 13 physical servers, with followed by the rest of Greece. the capability to host even more systems in the same array. Some of the benefits of the above Moreover, during 2010 we have completed the replacement of implementation are the remarkable energy saving in Radio Network equipment in 200 base stations which has resulted terms of cooling and power supply as well as space in up to 20% energy saving in all these stations. saving at the IT Centre. 53 8.6.2.4. Eliminating hazardous substances in the electronic equipment 8.6.2.5. Substances that harm Ozone layer

Waste which is created from the use of telecommunications equipment Our activity does not produce air pollutants other than those (electrical and electronic equipment) and sent to recycling systems is that result from energy consumption under normal conditions. increased by 16-28% every five years, in a rate three times faster than However, according to European Directive 2037/2000, which was municipal waste. In addition to that, this type of waste constitutes one incorporated into the Greek law in 2007, and also considering the of the most frequent sources of heavy metals and organic pollutants hazard of refrigerant leakage from air conditioning systems, due that the local authorities have to deal with. to the fact that in such cases the ozone layer is destroyed, we pay efforts, especially in remote locations, to gradually replace all air With the introduction of the Life Cycle Analysis (LCA) methodology, conditioning units, which contain the hazardous refrigerant R-22 a technique that assesses the environmental impact of a certain type with new ones, which do not contain R-22 or other ozone layer product, manufacturers of most electrical and electronic equipment harming (HCFC) for cooling. consider the final impact of their products on the environment, after the completion of their useful life cycle. Thus, measures are now taken In 2010 we have replaced in total 90 systems with new ones, which in order to decrease the impact during the product design phase as contain the recommended by the European and Greek legislation well. environmentally friendly refrigerant. In total, these air conditioning units are classified as energy class “A”, in terms of the energy Certain hazardous substances, such as heavy metals and brominated saving achieved. flame retardants (BFR), have been replaced by less dangerous materials in the new electrical and electronic equipment as from 8.7. WIND Fleet: New Services that contribute January 1st 2008. to the decrease of carbon footprint of our costumers When the “RoHS” EU Directive regarding the restriction of usage of hazardous substances in electrical and electronic equipment items Management of fleet was entered into force, a new page was turned for the environment. Through “WIND Fleet”, the new fleet telematic management service A smaller amount of heavy metal and other hazardous substances are of WIND, our Company facilitates other firms, professionals and initially used and are consequently placed in the environment – which public bodies, that own fleets of professional vehicles and transport is beneficial to us all. means, to decrease their operational costs, to better allocate their All our partners are now completely aligned with such requirements resources and to increase their productivity, by optimising their and indeed some of them even exceed the legal requirements, by operations and procedures. At the same time, the WIND Fleet voluntarily preparing lists of prohibited substances, even though the Service achieves a decrease in costs, in total fuel consumption, existing framework in force allows for some exceptions for several as well as in company’s carbon footprint while contributing to years. Thus, environmentally friendly innovation is being developed the protection of the environment and the better management of and the final management of such products is facilitated. climate change. Goals 2011

Further abolishment and replacement of the simple power generators with hybrid ones, which shall operate on combinations of diesel fuel and accumulators, aiming at decreasing diesel oil consumption by at least 3mLt and the respective CO2 emissions by at least 8,000 tons.

Replacement of our equipment in the Base Stations according to our three year Company plan.

Further decrease of waste sent to landfills. WIND proves, for another year, its sensitivity «towards environmental protection through its Increase of waste sent to Alternative actions. The support of our team enables us to Waste Management Systems. deal with difficult conditions that we face mainly every summer. We are integrated into the Fire Brigade’s operational planning of the prefecture of Attica and as residents of these areas we do respond quickly. In parallel, we achieve awareness of local community and encourage people to protect the environment, something that is transmitted to the younger generation, as well.» Apollon Kounis President of Voluntary Forces of Forest Firefighting & Rescue

55 ... Market, At WIND Hellas we cover all 2010 Achievements: telecommunications needs by Coverage of the GSM Network at designing integrated products approximately 100% and services, by expanding and Development of new products & services in order to cover telecommunications needs updating our network in order to cover all Greek territory, Development of systemic upgrades and automated solutions in relation to the by continuously evolving our procedure for managing subscriber queries sales network, by supporting and providing services to our Commencement of regular inspections at the facilities of our critical suppliers customers in every possible way. We comply with codes of conduct Granting 103,050 € to various bodies by means of our social services and of moral behaviour and we are committed to offer high quality products and services and high level of customer service, with full respect for the customers, the society and the environment.

57 9.1. Products and Services Our customers can be informed of our product portfolio, their features, of the existing instructions and of all our services via our webpage At WIND Hellas, we offer Mobile and Fixed telephony & Internet (www.wind.com.gr), or at the WIND stores throughout Greece and the products and services from one sales & service point and with collaborating sales points, where printed material is available and is one single bill for all services. provided for free, or even via specially configured voice messages (recorded information) or by calling our Customer Service Centre. The products and services we supply to our costumers are the following:

Mobile telephony Fixed telephony & Mobile & Fixed Internet telephony & Internet

- Post-paid services - Fixed telephony & - Bundle for residentials Internet services packages of and professionals (double play) Mobile & Fixed telephony and - Prepaid - Fixed telephony data packages telephony services services Under the framework of our strategic design of products - ADSL Internet and services that respond to consumers’ needs, in 2010 we - Added value services, Selection services like SMS, / Carrier have developed a new category of products based on the MMS, Internet, Preselection integrated Mobile and Fixed Telephony & Internet Network. Video calls, etc services - Roaming - Dial -up Internet The Integrated Information System provides to our Stores services abroad services higher sales capabilities, creates integrated customer loyalty - Wireless/mobile - Prepaid Cards mechanisms, expands the know how of Mobile Telephony internet services - Additional to Fixed Telephony, unifies the Mobile & Fixed Telephony - Mobile phones, Services Customer Service and offers to the WIND customers the mobile telephony unique advantage of a Single Bill. accessories, like - Digital telephony chargers, wireless facilities This is a development that eliminates differences between Bluetooth, cases, - E-mail etc the mobile and the fixed phone by providing a Single - Equipment (ADSL Communication Service, with a single price, available from all modem/ router, telephone devices) devices. Thus the subscribers do not need any more to think - Fixed telephony & which device to use in order to speak or to navigate on the Internet services Internet. via Leased Lines - Interconnection services - Value Added services - Wholesale services 9.2. The Mobile and Fixed Telephony Network 9.2.1. Mobile Telephony Network

The national telecommunications network backbone is based on The increase in the number of subscribers and the fiber optics, LMDS multipoint technology and microwave links. improvement of the offered services requires the expansion of The Company’s telecommunications network exploits in total capacity of the existing base stations but also the construction 4,000 km of fiber optics among which submarine cables for local of new ones, wherever this is deemed necessary. and international interconnection, as well as 30,000 of microwave During the last few years we have installed in total 350 base technology. stations near the borders of the country (borders with Albania Thus it can offer voice and data services with the use of advanced up to Bulgaria as well as the regions adjacent to Turkey), more software and encryption protocols, while it provides more than than 500 base stations to cover the main national roads, while adequate capacity in order to cover needs during peak demand 120 more stations have been installed near the country’s periods by automatically forwarding calls to the nearest free centre. coastline in order to provide long distance coverage and 475 more stations have been installed on the Aegean islands. The mobile telephony signal is transmitted through base stations, which are located at every corner of our country, while the Fixed telephony and broadband Internet services are offered to the subscribers via unbundled access to the local loop (LLU) via the use of advanced technology (DSLAM/MSAN). In addition, in order to cover the increased telecommunications needs of large corporate customers we also offer Fiber to the Building (FTTB) services.

At WIND, we provide 2nd and 3rd generation network coverage for voice and text communication and for data services both in Greece and abroad.

Population coverage of the WIND GSM network at the end of 2010 was 99.61%, while it exceeds 80% for the 3rd generation (UMTS).

59 9.2.2. Fixed Telephony Network 9.3. Responsible Marketing

Fixed telephony and broadband Internet services coverage reaches 70% Our Company’s communication is based on the principles of of the installed telephone lines throughout the country, with 250 transparency, truth, respect of customary ethics and respect of the collocation points covering Athens, Thessaloniki and 80 more cities customer. In our self-commitment framework, we act in accordance with in 48 prefectures. the codes of conduct and ethical behaviour. In 2010 the network was expanded to 16 telecommunication hubs By promoting rational business practices in all our operations, we while the connections to the backbone network have been upgraded (backhauling) in more than 118 sites; at the same time, in total 700 km implement policies to protect personal data and telecommunications’ of fiber optics were laid for the development of the backbone secrecy and we comply with the Code of Conduct for the supply of telecommunications network. Electronic Communications to Consumers, which sets and defines the general principles and the basic rules of consumers’ behaviour, Deployment of the Fixed Communications Network of customer service and of product & services promotion, which are applied by the representatives of the Customer Service Department, our 4.000 km National fiber optics Network Stores and our Associates. Our basic objective is to assure a qualitative 24 Gbps International Capacity service level aiming at absolute customer satisfaction and personal data protection. 20 Gbps GR-IX The Code complies with the requirements of the Code of Conduct for the 250 Collocation points in telecommunications nodes supply of Electronic Communications to Consumers issued by the EETT 48 Prefecture (Decision no 488/82) (http://www.eett.gr/opencms/export/sites/default/ EETT/Electronic_Communications/EC_codes_analyt.pdf) and is available 80 large cities both to the representatives of the Customer Service Department and our Submarine fiber optics cables between: Stores via the respective corporate informative web pages.

Greece – Italy The programs that we provide are in accordance with regulations and optional codes, which are related to communication and marketing, this Crete – Peloponnese way focusing on sincerity and communication clarity, with the purpose Peloponnese – Sterea Hellas to reach the consumers and comprehensively inform them about the In order to inform the public in all regions about the deployment advantages of our products and services. of our Company’s Fixed communications network at a local level, Thus, we assure that our communication and promotion material complies we have implemented extended communication campaigns via with the provision of the Greek Advertising & Marketing Communication printed material, outdoors, massive transport media, local media, Code (EKD-E), the provisions regarding unfair competition and conferences, etc protection of the consumers and the general Greek legislation Intellectual Property Rights in force. We follow and strictly abide by the regulations set by In all the contracts we conclude with our consumers our the Communication Control Board (SEE). Company includes strict terms related to the protection of We try to use friendly, simple and clear language for our intellectual property rights during the use of its services. In bills, e-bills and voice messages. particular, we do not allow our subscribers to use our services in a way that violates the intellectual property rights laws on The promotion material is also straightforward, explanatory, the penalty of termination of the relevant contract. Moreover, legal, just and sincere; it does not hide any details from the our Company fully fulfils its legal obligations as a network and customer, it is based on actual data, it addresses every age, electronic communication services provider with regard to the gender and religion and gives priority to the differences among protection of intellectual property rights. people. Assurance of Communication Security and Privacy In order to assure all the above our Company’s Marketing Division frequently checks all our advertisement messages, At WIND we have a set of safety rules in the form of policies before these are communicated. and procedures, which are related to the assurance of secrecy and the protection of personal data. In particular, In 2010 we proceeded to systematic actions in order to all communication over the Mobile telephony network is improve the existing processes and thus to improve our completely encrypted, according to international mobile customers’ information. telephony technical specifications, which guarantee privacy of communications. Our customers’ personal data management takes place with absolutely strict criteria and abides by the provisions in force of the law on protection of the individual from the process of personal data (Consumer Protection Law 2251/1994, Protection of personal data and privacy of individuals in electronic communication sector Law 3471/2006.”

61 9.4. Responsible Products At WIND we recognize the importance of recycling 9.4.1. Environment electronic items and thus we have installed in all our stores special bins for old mobiles, accessories and In every contract we conclude with our suppliers we request batteries, which the users do not need any more. that the products that we receive and we commercially provide through our associates’ network are fully compliant with the European Legislation (CE mark) (http://ec.europa. 9.4.2. Health eu/enterprise/policies/single-market-goods/cemarking/faq/ index_en.htm), as this has been harmonised with the Greek All mobile phones should strictly abide by safe radiation emission requirements. Characteristic Legislation. samples of such specifications are, among others, The CE Mark has been used since 1993 as a clear indication the guidelines by the International Committee for of a product’s specification compliance with EU legislation Non Ionizing Radiation Protection (ICNIRP), guidelines and permits free movement of the goods that abide by this of the Federal Communications Committee (FCC) law. and the ANSI/IEEE C95.1-1992 Guidelines. In the European Union the limit has been set to 2 Watt per In the cases that products from third countries are kg of human body tissue while in the USA the Federal imported we request further CE guarantees from the local Communications Commission FCC has set as the bodies, beyond the EU ones. maximum allowed radiation limit at 1.6 Watt for each kg of human tissue (Watt/kg). In order to assure quality of equipment every six months we conduct regular inspections throughout Greece (sample As far as mobile devices are concerned and checks upon deliveries, regular and extra inspections, according to the manufacturers – and the values etc). Moreover, we systematically conduct surveys of new they are obliged to record in the mobile phones’ technologies that exist in the market, with the view to user manuals – SAR (it measures the power that is absorbed per weight unit of biological tissues) is identify those that are environmentally friendly (in terms lower than permissible limits. SAR measurements of materials and electricity consumption). The result of this in the laboratories are conducted at the maximum research is that we have already renewed the fixed Internet permissible emission power of the mobile phones. access equipment that we offer to our consumers, thus Under circumstances of normal use the actual SAR achieving a more efficient operation of local networks. levels of the devices are much lower, since they In order to better inform the consumers, all devices that have been manufactured in such a way so as to use we commercially supply bear the special EU mark, which the minimum possible emission power required to achieve connection with the network. indicates that the device should be recycled rather than discarded to landfills. The telephone’s battery also bears As a result, the lower the distance between this special mark as it can constitute hazardous waste and the mobile phone and the base station of should be recycled. the network, the lower are the SAR levels. 9.5. Responsible Information of the Public Services

9.5.1. Transparent Pricing Balance Information Service

It is important for us that our customer knows, in detail, the At any time every prepaid subscriber can have amount and the way one is billed. For this reason, we assure immediate, automatic and free information of the that all our Customer Information Points (monthly bill, e-bill, remaining airtime and the balance after having www.wind.com.gr, etc) present transparent billing detail and consumed the free time of his package. clarity and it is explained in a simple and accurate way. With regard to the multimedia information services we analytically Airtime Extension Service inform our subscribers about their charges, thus complying with all EETT rules. With regard to the premium charge calls, Our subscribers have the choice by just dialling a we are fully harmonized with the EETT regulations and we 4 digit number, even with zero balance airtime, inform our customers, for each such service, the charge of to extend their remaining airtime. In this way every call to the 901 & 909 premium series, by means of a they can use their phone immediately in a case of free recorded message. Moreover, we have set a limit to the emergency. duration of every single call to such numbers, which cannot exceed 20’/call. WIND Ring Me Now Service

The charges of all multimedia information services per product This service enables subscribers to immediately can be found in the Company’s website (www.wind.com.gr). call any WIND mobile telephony customer when one does not have enough balance in his prepaid card phone. The service is activated by sending an SMS to a 4 digit number and by merely writing in the test the mobile phone number they want to call.

Change of Tariff Plan

This service facilitates the subscriber to choose the Tariff Plan on the basis of which one is charged. Transfer into the new Tariff Plan can be made by calling 1342 for free and the change in charges will be activated immediately. Change of Tariff Plan can be realised once per month. www.wind.com.gr

63 9.5.2. Parental Control At WIND we are committed to safeguard responsible use of our services by minors. Thus, we have developed proper procedures in Telecommunications, centred on mobile telephony and broadband Internet, play a dominant role order to protect certain of our services by means of a parental control in the way modern Greeks communicate, having mechanism such as premium charge numbers or services accessing already penetrated younger ages, teenagers’ even applications that address exclusively adults. In this way, parents are children’s populations. This fact renders extremely able to control and block their children’s access to such services upon important the responsible and safe use of the their request. services we offer to society and has led us to take actions and initiatives towards this direction. In addition, we have published relevant leaflets about the safe use of mobiles and internet by children, which are available at all our stores and in our Company’s webpage (www.wind.com.gr).

Services

WIND Plus Mobile Telephony Self-Regulation Framework Parents and guardians of minors have the option to block access to certain categories of services, as for example Erotica, which addresses In the framework of self regulation of the only adults, either directly from their children mobile phone or by mobile telephony sector in Greece the sector’s calling to Customer Service Department at 1260 and requesting the Companies have adopted and apply a “Code of blocking of this category. Conduct for Services via Mobile Phones and the Premium charged calls (numbers in series 901 & 909) Protection of Minor Users”. This Code expresses WIND subscribers can request to block all numbers starting from 901 the commitment of the companies for the and/or 909 by calling Customer Service Department at 1260 in order sound use of the value added services by their to be protected from high charges (series 901) and/or content that is customers (for example, content services, videos, addressed only to adults (series 909). MMS) and in particular for services with themes Community Services that address adults. In Community Services all entries are controlled and the use of preset The objective of the telecoms Companies is inappropriate words is excluded. Also, we can prohibit access to such to continuously improve the content of this services to persons that violate the services’ terms and rules of use. particular Code according to the developments Regarding the Community Services including the Date and Chat in the mobile telephony sector at the European services, their barring is realised by means of a simple phone call to level. Thus, in 2010 the sector also continued to Customer Service Department at 1260. work towards this direction by incorporating in Additionally, Internet users have the option, by means of certain this code a relevant European Memorandum for equipment settings, to restrict access, thus blocking specific URL or the safer use of mobile phones by children and URL groups by only allowing access by specific devices, etc. Moreover there is an option to restrict specific protocols so as not to allow teenagers. specific applications. In this way, parental control is strengthened. 9.5.3. Safety & Health 9.6. Communication with our Customers Mobile Telephony and the Internet, as communication means, are today an integral At WIND we are committed to be close to every customer and to respond to part of our everyday life and thanks to their technological capabilities they have his or her needs in the most direct and reliable way. freed and enhanced our communication by abolishing all borders in the promotion of ideas and the exchange of information. 9.6.1. Research & Evaluation Nevertheless, not all of us are equally familiar with the functions of technology We frequently conduct regular checks and audits throughout Greece in and its relation with health and safety. Issues that largely concern the public. For order to assure the network’s quality and the constant and seamless communication for our customers. Thus, we regularly conduct surveys at instance the network of mobile telephony and the fact that the mobile phone does all our customers’ contact points whereby we can measure our relation not operate without base stations as well as the link between mobile telephony and with them and to constantly improve ourselves the motive for continuous health. improvement. At WIND, considering all the above issues, we inform the public about those issues: WIND Research Program 2010: We have published the informative leaflet “The Mobile Telephony in our life” Continuation Surveys/ Planned Surveys where we methodically summarise the basic principles of the mobile telephony operation, legislation issues, findings of international research and answers to Advertisement evaluation survey: ad tracker frequent questions. The survey consisted of 11 monthly “waves” (Except August) on a monthly sample of 710 telephone interviews in Athens, Thessaloniki and 5 more big cities. Corporate image evaluation survey: Βrand Dynamics The survey consisted of 3 quarterly “waves” that aim to record and analyse the company’s image. Subscribers’ survey on fixed telephony and Internet – IPTV The survey took place via personal interviews on a sample of 20,000 consumers analogically distributed throughout the whole period of the survey (46 weeks per year). National survey on mobile telephony The survey took place during 46 weeks of the year on a sample of 20,000 persons aimed at recording and monitoring basic factors, as for example penetration of mobile phone possession, network and type of subscription, or users’ profile analysis at the level of demographics Recording mobile telephony devices purchase: Retail Audit We provide useful information on health issues via our website (www.wind.com.gr) This survey is conducted on a monthly basis and records mobile telephony Moreover, we understand that technology could hide risks, if we do not know how to purchases from all available channels use it properly. For this reason via our webpage we provide information on the Mobile Telephony Company Customers’ Satisfaction Survey mobile phone and Internet safe use, via the publication of useful data and advice with regards to the way we can protect ourselves from possible dangers, as for The survey was conducted in the form of telephone interviews on a National example malignant software or viruses, and in this way to safeguard the users’ scale (Athens, Thessaloniki and 5 big cities) on a sample of 1,000 consumers, personal data. Furthermore, all communication over the WIND’s network is fully 700 professionals and 300 persons from a special group of immigrants. This encrypted according to the international mobile telephony technical specifications particular survey aimed at revealing all factors that influence the customers’ and there is no case to intrude our customers’ personal data and information. satisfaction degree (both of WIND and of the competition).

65 Since the end of 2010 the satisfaction level seems to be stable above 4 on the scale from 1 to 5.

Ad hoc Surveys Also, in 2010 on the basis of continuous improvement of In response to certain requests from various departments of the our customer service and satisfaction practices, we have Company, ad hoc surveys have been conducted to examine particular proceeded with the following: matters. As far as the methodology is concerned, they are divided into Innovative integrated product proposals qualitative and quantitative surveys while in order to address needs of certain ones we have combined both methodologies in a single Development of knowledge and skills of our people via training research program. The surveys that have been completed in 2010 and continuous information processes concern mainly the assessment of product promotions and evaluation of communication. Upgrades of systems and automated solutions in terms of the consumers’ queries management process With regard to Fixed Telephony & Internet in 2010 we have developed contact processes with our subscribers in all regions of Greece in order Integrated deployment of an advanced system of enhanced to collect information regarding the degree of their satisfaction in terms network coverage management of services and service points. Installation of an automatic system that permits measuring the Measurement of our customers’ satisfaction on a monthly basis gave us quality of the services provided via the mobile telephony customer the opportunity to detect areas in need of further improvement with the service centre long term purpose to continuously upgrade the customer’s experience. Improvement of our customers’ experience at our stores’ chain The information (satisfaction level & ad hoc comments) collected from by implementing a series of projects so as to make customer this contact with the Fixed Telephony & Internet subscribers has already service more direct and comprehensive for more than 60,000 borne fruits, as reflected on the measurement of the satisfaction degree. queries per month 9.6.2. Customer Satisfaction The average response time of incoming calls to Customer Service Following our commitment to supply our customers with integrated (for postpaid and prepaid telephony) initiated to a high quality telecom solutions in 2010, we have successfully completed the level. The same response can be observed in the times of service integration of information systems with the creation of a single IT of the “WIND One” new product from the date of the launch infrastructure to support functions and services in the Mobile and Fixed since the end of 2010 (26 October - 31 December 2010). More Telephony and broadband Internet. specifically, during this period, 90% of calls to Customer Service The new architectural structure of our information systems was (not including calls relating “WIND One” product) were answered in designed with simplicity by using state of the art technologies and less than 20’’ and the average response time since the subscriber aiming at the best service of our customers with regards to sales, had chosen to connect to a customer service employee is 10’’. customer relations management, and billing as well as the offering of Similarly, 92% of calls to Customer Service regarding “WIND One” bundle products and discounts. The main characteristic of the new IT were answered in less than 20’’ and the average response time infrastructure of our Company is the automation of procedures that since the subscriber had chosen to connect to a customer service used to be executed manually, thus achieving an increase of efficiency in employee is 7’’, as shown in diagram that follows: performance. Call Center 26 Oct - 31 Dec 2010 1277: a number for every need of our Costumer Care vs. Wind One corporate customers 100 90% 90 In 2010 WIND integrated the support and information departments of the 92% Costumer Care 80 WIND One existing or potential corporate customers in terms of both Mobile Telephony 70 and Fixed Telephony & Internet. Now, all those who need to be informed of the 60 corporate products of WIND or to notify a failure can call a SINGLE number 50 for Mobile, Fixed or Internet Services. Via recorded voice messages (IVR) the 40 customer is quickly and easily guided to the appropriate department; this results 30 to an enhanced customer experience and to more efficient response to their 20 queries. 10 0 10 SL(%) 7 Costumer Care Av. Queue WIND (Sec) One

Significant improvements in the practices related to customer satisfaction were also realised in the Quality of the Electronic Communication Services to the Public Fixed Telephony – Internet Sector. Indicatively, we At WIND Hellas, showing for one more year the respect we have to all those can mention the following: people who receive electronic communication services, and in compliance with the Decision by the National Telecommunications and Post Commission (EETT) New procedure for the first equipment instal- (no 480/017/13-05-2008, FEK issue no 1153/24-06-2008) according to which lation and Internet connection where time and comparable Quality Indices are defined, we continued, with integrity, the more number of steps have been drastically decreased extended and more accurate measurement of the Quality Indices and their Subscribers’ information on billing data via voice timely publication on our corporate website (www.wind.com.gr) and on EETT’s portal website (www.eett.gr). The publication of the Quality Indices, in terms of: Information of the candidate subscribers’ application progress via the voice portal and our a. Fixed telephony services webpage b. Mobile telephony services Improvement of the troubleshooting time on the c. Fixed broadband services and VoIP services first call up to 40% d. Customer service, and Improvement of activation times up to 30% e. Directory inquiry services In this way, and thanks to our constant investments in modern network equipment, we significantly aims at facilitating our end users to compare the service quality offered by the improved the quality of the services offered and thus various electronic communication services providers as well as to check the the user’s or our stores customer’s total experience. certification of the quality of the services they already get, if this is available. 67 9.7. Responsible Suppliers any of their facilities. With the aim to support the Greek market we try to assign projects to Greek suppliers – not The Supply Chain Department knowing that our Company is necessarily based in Athens. an entity acting within the Society, where it influences and is influenced by contemporary matters, has set a series of We evaluate our suppliers according to the requirements procedures so as to assure strict objective criteria, via an of the management systems ISO 9001 and ISO 14001, we internal questionnaire, for each supplier. To enter the list of monitor tenders and we conduct inspections when this is approved suppliers, a potential supplier should comply with the deemed necessary. necessary prerequisites in relation to the following issues: After an initiative by the Supply Chain department in 2010 Compliance with legislation we initiated a plan of regular visits to the facilities of our critical suppliers in order to verify full satisfaction of the Matters of health and safety at work requirements of each project as well as the fact that they Child labour abide by such requirements.

Unequal treatment During the audits we have conducted we did not notice Behaviour towards the employees any such discrimination.

Compensation

Freedom of Association Supplier's percentage graded per category Corporate responsibility of product/service

Quality

Safety of information, and TRADE NETWORK OPERATIONS 15% 23% Protection of the environment FACILITIES Our daily procurement activities are realised on the base MANAGEMENT of detailed recorded and official procedures, which respect 11% human rights and abide by transparency principles. TELECOM INFORMATION PRODUCTS SYSTEMS The process of selecting and evaluating our suppliers foresees 39% 12% specific measures, controls and approvals in order to avoid any case of corruption. In addition to that, we wish that our Finally, it is worth noting that in all our contracts we bind our suppliers do not employ persons aged under the legal working suppliers to comply with the Greek and the European legislation. age nor to tolerate or overlook any possible physical or other harassment or exploitation or the use of forced labour in In 2010, 2,69m calls have been realised to emergency numbers. 9.7.1. Local Suppliers At WIND we support local markets, in particular in subcontracting and building projects, where we use firms of the local community; at the same time, for the purchase of promotion materials and for printing 9.8. Infrastructures in Society jobs we normally employ Greek firms from various regions of the At WIND Hellas we strongly believe that telecommunications country. are a vehicle of progress in a modern society; a vehicle of Moreover, a basic criterion to select our partners in order to expand our social coherence and wellness. store chain is the strengthening of local economy. 9.8.1. Emergency numbers This is reflected in the following diagram of geographical distribution of In 2010 overall 2,691,291 million calls have been realised our store chain: almost half our stores operate in areas beyond the two over our network to emergency numbers as 100, 166, 199, main Greek cities. 112, etc. It should be noted that both calls and text messages [SMS] to emergency numbers are free for our subscribers.

Geographical distribution of 9.8.2. Programs for the disabled Attica WIND Stores / region Thessaloniki Through our Company’s WIND Care project that we have Macedonia developed since June 2002, we provide the opportunity to Peloponnese persons with a certain degree of disability percentage to 12% Mainland Greece 11% communicate via SMS at a 50% discount prices. Crete 10% 7% According to a recent Ministerial Decision, the list of SMS Thessaly 5% 50% discount beneficiaries, which until recently included only Eastern Aegean 4% people with hearing problems, has now been extended. Epirus 4% 38% 3% Ionian Islands 2% More specifically, decision 44867/1637 (FEK 1667/Β/18-8- Cyclade 2% 08) stipulates that the following categories are entitled to the Thrace 2% 50% discount on SMSs on a single connection: Minors with hearing problems and disability percentage of 50% or more, with their connection in the name of one of their two parents or another person, who is the minor’s guardian, after producing the relative disability certificate plus certificate of family status. Families of persons with mental retardation, autism, psychosomatic and multiple disabilities, with percentage of disability of 67% or above, with the basic precondition a certificate by the Health Committees determined in Law Spending on locally-based suppliers (Greek companies) represents about 3528/2007 83% of WIND total spending for year 2010. The majority of spending at Persons entitled to enter the WIND Care program can be non-locally based suppliers concerns telecom products purchases that new or existing subscribers and can hold either contract or there is no local representation of the company in Greece. prepaid cards.

69 9.8.3. Free of charge lines SOS Line for the “Smile of the Child”

We offer our technological infrastructures and We offer to our subscribers the capability to call free of charge from resources to bodies whose objectives we support via their mobile the SOS line 1056 and thereby provide assistance to serious the creation of special social services. incidents involving children. In addition to that, in December 2010 we initiated the donation of 2.016€ via the use of SMS to the number “I Offer” Service 54020. In 2010, 10,501€ was offered to the “Smile of the Child”. The service regards the activation of a 5 digit number for a certain time where the mobile telephony subscribers can send as many text messages they wish (cost 1€ plus VAT) in order Amber Alert Hellas to support a Financially Non Profitable – Non We participate in the Amber Alert program via our telecommuni- Governmental Organisation. This is a common cations network we have all over Greece. Thus our customers can initiative with a philanthropic character, undertaken actively participate in the process of locating a missing or kidnapped by all 3 mobile telephony companies in Greece and child via SMS to 1056 from their mobile phone. which has started in February 2006.

In 2010 the service was activated 11 times. All net collected revenues (before VAT) resulting from the use of the service are given by the companies to European Help Line for the Child the body or organisation that has organised the charitable event, without any deduction of revenues. We support the European help line for the child 116000 via which In 2010 WIND granted 90,625€ to various it is easy, fast and free to report any cases of missing children or to organizations via the “I Offer” Service. assist children in need.

Médecins Sans Frontiers

By sending a void text message to 19192 or by calling 9011602020 our subscribers donate 2€ to Children and adolescents support line A.P.H.C.A. the Médecins Sans Frontiers. Since 2009, we have also given the opportunity of a donation via WIND The operation of 116111, the children and adolescents support line was Plus, WIND’s mobile portal. From this particular launched by the Association for the Psychosocial Health of Children and service the WIND subscribers can also be informed Adolescents (A.P.H.C.A.). It is a free of charge number that any child or about the work of Médecins Sans Frontiers all over minor up to 18 years can call. Mental health expert consultants specialised in the world, via updated articles and photographs. In children and teenagers answer the calls. WIND Hellas offers to its subscrib- 2010 the WIND subscribes offered 1,924€ to the ers the capability to access the number, since it recognises the importance Médecins Sans Frontiers. of preventing mental health problems during childhood or adolescence. Goals 2011

The expansion of the system measuring the satisfaction of our customers to the Call Centre of Fixed Telephony as well.

Creating a new site with many on line applications and on line shop providing prompt and reliable service to users.

Continuing the improvement of the systems and processes for monitoring, recording and publication of Quality Indicators.

The investment in creating integrated services of Fixed, Mobile and Internet for all at competitive rates. « From the very first day I subscribed Creating innovative products and mobile services to WIND Hellas, the Company is beside me, covering the telecommunications in order to provide low costs and flexibility and to needs of my business in terms ensure control of the bill of our subscribers. of continuously developing the available programs and services and The redesigning of the bill with an emphasis on of responding to and immediately simplicity and a detailed explanation of fees and resolving any issues that might occur.» charges, enriched with specific recommendations depending on the needs of the customer base. Ioannis Haidas, Owner of a tax consulting firm The dynamic presence in social media with web development on facebook and twitter with the view to reach out our subscribers.

The provision of parental control software through Internet services.

71 ... Employees ... Employees At WIND Hellas we combine 2010 Achievements: the company’s growth with Strengthening of behaviours that support the culture of high performance through the demanding environment of implementation of the performance management system for all employees and the telecommunications sector the development of the working climate by offering our employees Implementation of environmental the opportunity to grow actions with the employees’ volunteering participation professionally within one of the Preventive health examinations to leading companies in Greece. employees and the members of their families We daily prove our commitment to our people, by establishing 17,902 training hours in technical knowledge and managerial skills a quality working environment Publication of WIND EcoNews, an electronic with equal opportunities for bulletin aiming at sensitising our employees with regards to environmental issues development, zero tolerance Collection of 94 blood units for the WIND towards discrimination, freedom Blood Bank by blood donor colleagues of association and respect of human rights.

73 10. Our people

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

From our first day back in 1992 when WIND Hellas had only 7 Our human capital is characterized by high academic level and specialisation. employees we invested heavily upon the creation of many new jobs, while remaining faithful to our principles and our philosophy Employees’ academic credentials regarding our human resources management. Holders of Masters degrees 22% 10.1. Human Resources Data (including PhDs)

At WIND we contribute largely to the strengthening of our country’s Holders of university degrees 45% economy by employing 1,506 people at the end of 2010. Holders of technical diplomas 19%

(Data of 31/12/2010) Employee distribution per Department 96.22% of our employees are employed under long term Department Total contracts (out of which 1.06% is employed under part-time General Management & other Administrative contracts). The remaining 3.79% is employed under fixed Departments (Quality, Physical Safety, Internal term contracts (out of which 1% is employed under part- 78 Audit, Legal & Regulatory, Corporate Affairs, Supply time contracts). Chain & Facilities Management) 10.2. Human Rights – Equal Opportunities Human Resources Department 32 Our strategic approach and philosophy is not restricted to Commercial Department 680 numbers but it is based on the principle of non discrimination, equal opportunities policies and the recognition of the Financial Department 97 rights of every human being at work. We are committed to IS Department 135 policies of transparency, meritocracy and objectivity for a Network 484 fair and reliable working environment.

Grand Total 1.506 Thus, we offer equal opportunities to all our employees throughout Greece, without any gender or other descrimi- (Data of 31/12/2010) nation. 131 new recruitments in 2010, Employee distribution by region, age group and gender 16 of which in the periphery WIND Hellas - Region

OTHERS PATRA 0.33% 0.80% LARISA THESSALONIKH 0.40% 6.51%

CRETE 1% Under the framework of equal treatment we proceeded with 131 new recruitments in 2010, 16 of which in the periphery. ΑΤΤΙΚA 90.97% Regional recruitments in 2010 are detailed as follows: WIND Hellas - Age Group Thessaloniki 12

Recruitments Crete 2 45-55 >55 3.19% 0.20% Patras 2

Total 16

All of the job descriptions and the candidates’ profiles for these positions are posted on our webpage 35-45 <35 (www.wind.com.gr) as well as on the relevant labour 46.35% 50.26% market websites. They are also communicated via small ads in selected newspapers. WIND Hellas - Employees by Gender Since the Company’s beginning until today, no discrimination incident was reported at WIND’s working environment. Moreover, with regard to human rights, we absolutely respect and we abide by all the international human rights provisions. MEN WOMEN 55% 45% On the basis of the UN Global Compact, which our company has signed, we ensure that no minors are hired amongst our staff and no cases of forced labour Due to our equal opportunity policy, 45% of the staff is female and 55% is male. It is worth noting that no incidents of unequal treatment between exist in our Company. employees of all ranks have ever been reported.

75 10.3. Freedom of Association 10.4. Benefits to Our Employees

At WIND we respect and protect the right of all employees At WIND Hellas, considered to be one of the most responsible employers, to participate in unions and the existence of information we ensure perfect working conditions for our employees and provide mechanisms. significant benefits and many advantages. Thus, we have developed a comprehensive and competitive compensation package, which rewards In July 2007 the first Company’s Collective Agreement performance, skills development and overall corporate success and (ESSE) was announced being in effect from October 2006. includes: It was renewed in 2008 and in 2010. Competitive remuneration packages -fixed and variable- which are This agreement, among others, provides for: based on comparisons with the market and reward employees’ achievement of corporate goals Covering child care expenses until primary education age; Life insurance covering disability and accident

Providing child allowances, even for the first child, while Group Medical plan coverage with the participation of employees’ most existing collective agreements anticipate the relative families allowance from the third child; Subsidised private pension plans

Covering the cost of preventive medical “check ups” Preferential mobile phone use every two years; Restaurant - coffee shop (on Kifissias and Athinon Sites) with highly preferential prices for employees Providing study allowance, also to the WIND stores’ sales staff; Discounts on company products at WIND stores Providing stand-by benefit to all staff registered as Benefits under the card reward program for transactions through stand by staff; WIND Bonus AMEX and WIND BONUS VISA

Granting paid study leave. Discounts and special offers in shops and businesses throughout Greece In the framework of welcoming newcomers in the Company, the HR Department undertakes a detailed In 2010, we updated all safety instructions aiming at personal presentation of the compensation package to protecting employees engaged in maintenance and every new colleague. operation of our network base stations. Also, whenever this is considered necessary, the company organises scheduled presentations of the additional benefits by geographical region. protection of the public and employees, proper use of Personal The employees express their interest to participate in Protection Means, fire fighting, working at heights, the use of hazardous such scheduled events by means of a special electronic substances, etc., and is accessible to all our employees via the platform stating the location, date and time of Company’s Intranet. preference. At the same time, we have already started communicating all the updated Finally, with the view to inform the employees with Business Risk Assessment Studies and the respective instructions to regards to the benefits packages, the Company: our network of associates, who work at our Base Stations. In particular for the technicians working close to our Base Stations Distributes information leaflets and user friendly we have obtained personal dosimeters, which record the radiation information cards with the telephone numbers for levels at all working areas. All results are collected, assessed and filed each department accordingly. Updates regularly a special intranet website 10.5.1 Indices of injuries, professional sicknesses, loss of working days and absences

10.5. Health & Safety The following table summarises the incidents related to health & safety issues during the last few years, showcasing that no serious Health & Safety of employees is a priority at WIND. Our basic incident with fatalities has taken place. goal towards our human capital is to preserve the health & safety of our employees through the implementation of No of No of safety practices that we have developed, and the proper accidents accidents Total days informing on issues related to health and directly affect each Losses in (absence > 1 (absence > 3 of absence employee. employees day) days) from work 2007 0 1 7 152 Specifically, for the base stations, all detailed instructions have been adapted according to the type of the Station and 2008 0 0 2 196 the detailed Business Risk Assessment Study, which we have 2009 0 1 6 137 implemented accordingly, and covers issues such as radiation 2010 0 1 3 35

77 10.5.2. Keeping employees informed of health issues 10.5.3. Employee training in health & safety issues Moreover, it is our duty to properly inform all our employees on the health & safety issues, which regard to each one of our At WIND, specialised training takes place in the employees. field of health and safety in order to ensure that all employees are fully informed about these important Mutual respect of all employees, smokers and non matters. smokers is a priority for our Company. Since September According to the training needs, we design and 1st 2010, after the application of new legislation implement informative programs on the following stipulating total banning of smoking in all public and subject areas:

private spaces, which are used as working environments, Fire detection – Fire fighting and First Aid we informed our employees about an extension of the These workshops address the needs of the fire fighting smoking ban in all indoor spaces. Thus, we stopped teams’ members in our facilities throughout the use of the configured indoor smoking areas and Greece. They have both a theoretical and a practical developed specific areas outside the buildings. component and they are conducted in collaboration with the Fire Brigade and the Occupational Doctors Furthermore, for the information of our employees, of our Company. we communicated all relative legislation as well as the “www.Help-eu.com”, following an EU initiative, which Site Security Officers Safety provides simple and useful advice on this matter. These workshops are conducted in cooperation with the State Department of Safety. They have theoretical In 2010 we further informed our employees of various health and a practical component and they are designed issues and offered to them free preventive health check-ups, for colleagues in the site security teams throughout such as: Greece. In 2010 we completed 188 training hours in Safety Issues for the Site Security Officers. Obstructive pulmonary disease test

Prevention against Diabetes

Memory Test

Prostate Cancer Examination

Smoking impacts test

Parkinson test Employees’ Personal Development & Career Growth The most important employee training categories regard the following: At WIND, the Human Resources Management philosophy is linked WIND Corporate University (WCU) to the concepts of continuous training, encouragement and support

of initiatives that lead to the development of a quality working environment, which respects and promotes employees. Since 2007, we run the Corporate Leadership Program, Our people know that WIND invests on them by ensuring the proper which internally has the distinctive title growth conditions both in the personal and the professional level. “WIND Corporate University” (WCU). It addresses executives that run small 10.6. Training or large groups. The mission of the WCU is to communicate the new leadership One of our basic priorities is the continuous training of our employees so WIND Hellas framework and enhance corporate culture. Telecommunications AEBE that they can grow while improving their performance by means of offering The WCU supports employees development through equal training opportunities that support the employees’ career progress, training on managerial and leadership practices. whilst generate a competitive edge for our Company in relation to the competition. It was designed to function as a standard mini- Business MBA program, with equivalent processes, Training is provided as far as technical and managerial skills are concerned structures and functions. At the same time, the so that the employees are fully trained in their area of expertise. coordination and organisation of the WIND Corporate In 2010 more than 17,902 training hours have been realised. University is managed by the Human Resources Department with the support of the Company’s Top Management. Up to date, over of training Total training hours Average training hours / 8,500 hours have taken place through WCU in ten ( ) employee 10 educating programs, which combine theory with laboratory 17.902 11 exercises/ activities, “case studies” or “refresher courses” from the Harvard Business School Agenda. Category Training Hours Top Management 361,5 2,02% E-learning Middle Management 833,5 4,66% Ε-Gnosis operates since 2006 and includes MS Office Technical Personnel 6267 35,01% and Business workshops as well as Harvard Business Sales & Client Service Personnel 9789,5 54,68% classes designed by the Harvard Rest of Employees 650,5 3,63% Business School in collaboration Total 17902 100,00% with the HR Department. E-gnosis, Focusing on the training of our employees who work in the perfecture, is an innovative and comprehensive in 2010 we completed 1,702 training hours for our employees at training tool based on the principles regional departments, aiming at the development of their technical and of e-learning. Learning takes place via the PC of each managerial skills. employee and there is a certain amount of flexibility in the hours and days taken by the employees. Moreover, At our Company’s central offices, we founded a library with more than each Department has the opportunity to create its own 1,000 books and professional articles with regards to Management, electronic library and set of training programs, which People’s Management, Marketing, Finance, Public Relations and are fully adjusted to the corporate needs. Information Technology topics. This material is available to all employees and aims at knowledge dissemination in various fields, according to their area of expertise. 79 Scholarships time recognising the participant’s strengths and points in need for further development in order to prepare the WIND has a program to finance bachelors and masters ground for a wider dialogue regarding their Individual studies aiming at certified and valid qualifications for Development Plan. those employees, who have high career growth potential in the Company. Since 2002, up until now, the HR Individual Development Plan Department has granted a total of 42 scholarships for The Individual Development Plan ensures that all our undergraduate and postgraduate studies in public and employees have the opportunity to advance according private academic institutions, out of which 30 relate to to their abilities and to our Company’s needs based on post graduate degrees and 12 regard undergraduate a common framework that defines the skills required at degrees. every step of their professional development process. 10.7. Professional Development This plan is carefully designed for each one or our employees in close cooperation with their supervisors Our main goal is to provide every employee with and is based on the development experiences which are the possibility to exploit to the fullest the career necessary for the achievement of the common goals. opportunities presented in our Company. Under this context, in every department, our employees work Internal Candidate Recruitment closely with their superiors with the view to furthering In case of a need to fill in an open post we firstly look their development and establishing the framework that into our own people, as the best source of qualified integrates their individual abilities and aspirations into candidates. Thus, we encourage our employees to the skills required by the Company. explore new opportunities for change and growth, in We invest in our people and their development, using the other posts or departments, in order to give them the latest tools for their development: chance to acquire knowledge, personal growth and freedom of choice. At WIND Hellas, all employees can Induction Programs evolve into knowledge leaders or people’s leaders. We undertake induction programmes for all new hires Performance Management System in all divisions and departments. The programmes offer appropriate guidance regarding what the employees The role of the system is twofold: whilst it gives an need to know about both the Company and the objective evaluation of employee’s performance, it telecommunications market. also looks at their further progress and development. The key goal is to contribute to the achievement Development Centres of corporate goals. A basic element in this process The Development Centres are created with the aim is to establish a two way communication (between to identify each participant’s competences and employees and their superiors) which aims to achieve characteristics, based on the skills and performance a just and smooth employee evaluation leading to his levels required by the organisation, while at the same overall progress. The assessment system is based on a list of key 10.8. Internal Communication skills (competencies) against which employees At WIND Hellas our working environment is characterized by mutual are evaluated. After the assessment, employee respect and trust. Sincerity and responsibility for our customers and and manager complete together the Individual colleagues is an integral part of the employees’ professional behaviour Development Plan which monitors the employee’s whilst we operate with transparency and reliability in all our daily performance so as to achieve further growth. After transactions inside and outside the Company. A basic prerequisite for all having completed the evaluation, the employee is the above is the development of a proper communication policy parallel also given targets for the next year. to a system of continuous “coaching” for a successful human resources management.

We believe that deepening internal communication at all levels is one of the fundamental factors that determine our success, which strengthens the climate of trust and contributes to the establishment of a single tion lua va Tar culture that acknowledges individual capability, effort and contribution e E ge c Plan t S an nt et d e tin rm n pm g while further enhancing team work. o a lo rf e e v P e l D l a a For this reason we strengthen communication by means of either tools u u n d i n iv A d that develop an open and constructive internal dialogue or by means of n I

various events that we organize for our employees.

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81 WIND Portal Internal network where all employees have access to all kinds of information aiming at a live two communication platform promoting awareness of the Company’s events, enchances knowledge (e-library, e-learning) facilitates internal processes (electronic applications) & decreases bureaucracy. WIND About Company magazine that is distributed to employees, it covers corporate issues but it is Internal also the voice of our people since it is presenting the most signiﬁcant Communication company projects & the revelant experience of those that Channels participated.

Ιnternal SMS messages Ε-Νews Special e- news bulletins Bulk SMS to the mobile aiming at promoting advanta- phones of all employees in geous seasonal discounts at WIND order to promote corporate stores and participation of issues. employees in lotteries with presents and invitations to Internal sponsors’ events. Marketing Products & services internal promos by employing: monitors, e-communication, e-contests, special promotions, internal branding. 10.8.1. We take the two way communication process further In June 2010, on the occasion of the International At WIND we keep our employees informed of all issues that directly Environment Day we launched the WIND EcoNews concern them as they are part of the wider society, by exploiting column, which is one of the basic new sections at all modern means of internal communication. Numerous methods our WIND Portal that aims to continually sensitise & channels of communication are employed, having a long term everybody in the Company on issues regarding the perspective. protection of the environment.

WIND is among the first companies in Greece that created an WIND EcoNews systematically informs about the internal website (WIND Portal). environmental developments and news from Greece The goal of 2010 was achieved with the renewal of WIND Portal and the World. Moreover it offers useful advice, by introducing new sections as well as new content to the existing which all of us can easily adopt in our daily life in ones. One of the most important new sections was the creation of order to decrease our energy consumption and WIND Eco News, a new column, which is specially designed in the improve our environmentally friendly attitude. framework of continuously making our employees aware of issues Since our concerning the protection of the environment; it includes environ- environmental ment news from Greece and the whole world and also the latest philosophy developments related to the actions that our Company undertakes starts from either by means of our employees’ initiatives or by means of the the training of Corporate Responsibility Strategy “In Action”. our children, we devote the sub-section Eco Kids to the information of our young friends with regard to various ongoing environmental events and activities in which they can actively participate.

In parallel, WIND EcoNews is the eco-communication tool by which we offer continuous information to our employees with regards to the environmental actions that we undertake.

83 10.8.2. Organisation of employees’ events 10.9. Promoting Volunteerism Internally

Our permanent objective is to support those methods that further With a focus on the belief that knowledge and awareness start strengthen the development of relations among our employees and from the internal environment, we promote the systematic facilitate work-life balance. development of volunteerism within the Company aiming at informing and encouraging employees to actively participate in our Company’s social program.

WIND’s social policy derives from our own people, who In 2010, for the 8th consecutive year, we organized the WIND Parent’s participate in many actions that address either society Day and gave the children symbolic WWF presents, which aimed to make in terms of supporting those social groups in need or the everyone a little more aware of the protection of the ecosystem while environment, through voluntary actions by which the contributing to a more balanced co-existence of nature with man. message of the value of social offer is conveyed to all A few days after the schools close our Company’s employees welcome employees. their children into their offices to celebrate together the established 10.9.1. Social support WIND Parent’s Day. Gathering clothes and toys for social groups in need

On the occasion of Christmas we gathered clothes and shoes for infants, children and adults (up to 14 years) as well as toys for several vulnerable groups of the Municipality of Maroussi. This donation targeted poor families with many children or single parent families, persons released from prison, immigrants and children with special needs of “Sykiarideion” Foundation.

The event aims at the children’s contact and familiarization with their parents’ working environment, as well as the promotion of the concept balancing their professional and personal life. 10.9.2. Protection of the environment from work, we proceeded with the creation of 30 bicycle parking spaces at our office facilities at Athinon Avenue. Similar actions Recycling at the office are planned for the rest of our facilities so as to raise awareness It is widely known that no successful recycling program can exist amongst employees with regards to sustainable mobility. without the participation of all; for this reason, we motivate all Cleaning Up beaches employees to recycle in special containers, which are placed in all our premises. We give the possibility to our employees to recycle On the occasion of the 25 years of the organization of the Interna- variable materials, like paper, batteries, telecommunication acces- tional Coastal sories, which would otherwise end up at landfills, and throw them Cleanup Day into the containers placed in the special break areas. (25th September) on Saturday Sustainable Mobility 2/10/2010 the Having as a goal to motivate our employees to use more sustainable Hellenic Marine transport methods while facilitating them in their transport to and Environment

Protection Association (“HELMEPA”) coordinated this international initiative in Greece, where WIND employees, accompanied by their friends and families, got together and cleaned the beach of Shinias of the Prefecture of Attica.

85 In 2010 the Blood Bank actively responded to 10.9.3. Voluntary blood donation of employees the needs of 44 employees and their relatives One of our most important initiatives is the creation of a Blood by offering more than 80 blood units. Bank, which was opened in 2002 thanks to the voluntary blood donation program of our employees which takes place twice a year. The aim of the Blood Bank is to contribute to the national efforts to obtain adequate blood supplies and to immediately support any employee and his family in case they are in need for blood.

For the implementation of the programme we collaborate with the largest hospitals in the country. Since 2002, the Blood Bank has received a total of 560 contributions by volunteers.

Consistently promoting the enhancement of the WIND Employees’ Blood Bank, in 2010 the Human Resources Management organized a Blood Donation program in Athens, with the participation of more than 70 volunteers who totally donated 94 blood units, as well as in other cities, for those employees who wished to participate. Thus, the motto “Charge Life” strengthened once again the WIND’s team of voluntary blood donators to offer the most invaluable good of all. Goals 2011

Implementation of Development Centres in specific employee groups aimed at the professional development of our people with regard to improving the quality of services offered to the customer.

The development of the e-newsletter Eco News, to a source of information about the environment and encouragement of employees’ active participation towards its protection.

The investment in internal communication by means of organising presentations and discussions aimed at improving employees’ access to corporate knowledge and information.

The creation of WIND Running Team and the promotion of the concept of corporate sports teams with the active participation of our employees by promoting the team spirit and volunteerism through sports.

Further strengthening the concept of internal volunteerism by informing our people and actively partici- When our Company participates pating in voluntary environmental actions. «or organises actions for volunteers I am always happy to participate, to offer what I can and mainly to share The continuous information about health and safety valuable experience and time with by offering specific preventive medical examinations my colleagues. It is very important to to employees and their families, whether free or at participate in a voluntary initiative. special prices. Sharing all these experiences with your colleagues is invaluable! The implementation of the WIND Parents Day event, » enhancing both environmental awareness and social contribution by supporting charitable and environ- Elena Anogiati, mental organisations. Executive Secretary

Strengthening our employees’ Blood Bank. 87 11. 2010 Goals & Results Target 2010 Result Corporate Governance Axis The study and further development of methods which will enhance transparency and limit any conflict of interests within the Company ✓ Regarding the Business Continuity Management: ✓ the completion of a large-scale project concerning IS Department ✓

further development and application in other business units of the Organisation, based on the proposal which was formed in 2009, while considering the overall strategic business plan and ✓ priorities of the Company’s Management

annual reassessment of existing strategies and plans, further growth of recovery plans of critical functions in various sectors and regions where business continuity projects have completed ✓

awareness and training program: a continued education (by means of workshops) for employees of departments wherein Business Continuity projects have been executed ✓ Environment Axis Further reduction of paper use by extending the signature digitization project by the use of special equipment in Fixed telephony and Internet and replacing our equipment ✓ Reducing the production of air pollutants through the modernisation of the network and infrastructure upgrading ✓ Saving energy by using new technological systems ✓ Market Axis Network modernisation by extending it by 8% rate and upgrading up to 10%, according to our three year plan *in progress Annual assessment of all our Company’s critical suppliers, covering the majority of our markets, by integrating a series of additional measurable social and environmental criteria ✓ Selection and evaluation of new associates to manage customers in arrears under new stricter criteria ✓ Target 2010 Result Human Resources Axis Maintaining the regularity of labor relations in the midst of significant social and economic change ✓ Strengthening internal communication by means of our internal website and periodical meetings between Employees and the Company’s Management ✓ Signing of the Collective Agreement ✓ Strengthen and support employees’ training system with an emphasis on training of Sales employees and Technical Divisions on new technologies ✓ Extended automation of internal processes through extensive use of new technologies, aiming to minimise time management and reduce energy consumption ✓ Further develop partnerships with academic institutions, continuing our dynamic presence in "Career Days" of major Universities ✓ Continue the program of internal volunteer program with the view to encourage the active involvement of employees in our Company’s social program and also strengthen the actions of ✓ social responsibility through employees’ initiatives Raise awareness of employees on environmental issues by creating a special electronic publication under the title "WIND ECO NEWS" via the intranet ✓ Continuous and constant cooperation between all departments of the Company to achieve corporate strategic goals ✓ Society Axis To maintain and develop existing programs ✓ To further develop partnerships with Organisations ✓ The implementation of awareness campaigns among the general public ✓

89 Intranet: It is a computer network and data which is accessible only from 12. Glossary points within the network (e.g. computers / users in an organization). Often the term is used for the internal corporate portal. Backbone: The central and highest part of a hierarchical telecommunications network through which interconnect various sub networks, ensuring International Organization for Standardization (ISO): The International geographic coverage. Organization for Standardization which develops internationally recognized technical standards, with members from 162 countries Base Station: This is a fixed point of the mobile network, through which reception and transmission of data and information to the network coverage LMDS (Local Multipoint Distribution System): Microwave technology expands and share in lower hierarchical networks. The stations have the through which offered high-speed connection from a central point (antenna) infrastructure necessary for continued operation and monitoring. at many points in the coverage area.

Broadband: The technologies and infrastructure through which users enjoy Local Loop Unbundled (LLU): The twisted metallic pair cable that is con- high-speed Internet connections, and their respective services. necting a subscriber’s telephone or Internet to the public telephone network.

Corporate Responsibility: Refers to actions of Organizations, aimed at Microwave couplings: set-up of antenna through which wireless high-speed contributing to address environmental and social issues in the areas they data transmission and information is being achieved (from few meters to operate, recognizing their responsibility. several kilometers). Usually the transmission is point to point.

EETT: The National Telecommunications and Post Commission of Greece, Microwave technology: wireless technology and high speed data and infor- which is the Independent Authority that controls, regulates and supervises mation transmission (at frequencies in the range of GHz), through appropri- the markets for electronic and postal communications. ate devices and infrastructure used by telecom providers.

Extranet: It is a computer network and data which is accessible in full or Specific Absorption Rate (SAR): The SAR (Specific Absorption Rate) is an partially and for a particular purpose or use from outside the network. Often index that reflects the energy absorption by the human body when exposed the term used for the corporate portal which is accessible by partners, to electromagnetic fields (eg the field of mobile phone) and is measured in network sales, etc. Watt per kg. The SAR is measured in a certain way and there is acceptable safety limits. Fiber Optics: High-tech telecommunication cables in which the data transmission is at frequencies of the light spectrum, ensuring very high speeds, Sustainable Development: Refers to growth that is planned and imple- very low attenuation very high level of protection from interference. The mented taking into account environmental protection and sustainability for operation is based on the reflection of light within the fiber. future generations.

Fiber to the Building (FTTB): Extension of a fiber network to central com- Technologies DSLAM / MSAN: The DSLAM (Digital Subscriber Line Access munications infrastructure of a building (distributor) in order to provide Multiplexer) equipment is used by telecommunications providers in typically high-speed requirements in the departments / offices building urban telecommunication centers, through which many DSL lines connected to the Internet using multiplexing techniques. The MSAN (Multi Service Ac- Gbps: Unit of measurement of data rate (Gigabit per second). cess Node) equipment is used by telecommunications providers in typically Gbps GR-IX: High-speed interconnect (Greek Internet Exchange) between Internet urban telecommunication call centers, through which multiple lines con- Service Providers operating in the Greek territory, through which they peer nected to the telephone network and the Internet, through a platform. directly with each other, resulting in faster services to Internet users. Unbundled Local Loop Access: Providing SP access to the local loop or Global Compact: Initiative of the United Nations for Organizations, committed local sub-loop (ie. the twisted metallic pair cable which is connected to the to operate in accordance with 10 internationally recognized principles. public telephone network), which allows full or partial use of the spectrum of the loop. Global Reporting Initiative (GRI): International Organization, who has developed the framework for sustainability reporting, aims at the systematic Voice over IP (VoIP): Office phone-based Internet Protocol (IP) technology integration of the company’s approach to the environment, society and and not the traditional phone network. governance. 13. UN Global Compact: Communication on Progress

WIND Hellas supports the 10 principles of United Index of Global Compact Principles Nations Global Compact regarding human rights, labour practices, protection of the environment Principle Reference and fight corruption. With intent to actively sup- Human Rights port and develop these principles in our sphere Principle 1 Businesses should support and respect the protection of 5, 5.1.1, 5.2, 6, 6.3, of influence, we are committed to implement the internationally proclaimed human rights 8.6.2.4, 9.3, 9.4, 9.5, Global Compact and its principles in our strat- 10, 10.2, 10.5 egy, culture and everyday functioning, and also Principle 2 Business should make sure that they are not complicit in 9.7, 10.4, 10.6, 10.7 to clearly communicate this commitment to our human rights abuses employees, partners, customers and the general Labour Practices public. Focusing on monitoring and transparency, we report our progress in the various axes to all Principle 3 Businesses should uphold the freedom of association 9.7, 10.3 and the effective recognition of the right to collective our stakeholders. bargaining

Principle 4 Businesses should uphold the elimination of all forms of 9.7, 10.1, 10.2 forced and compulsory labour

Principle 5 Businesses should uphold the effective abolition of child 9.7, 10.2 labour

Principle 6 Businesses should uphold the elimination of discrimination 9.7, 10.2, 10.7 in respect of employment and occupation

Environment

Principle 7 Businesses should support a precautionary approach to 2, 8, 8.1, 8.2, 5, environmental challenges 5.2, 6.5

Principle 8 Businesses should undertake initiatives to promote greater 4.1, 7.4, 8.3, 8.4, 8.5, environmental responsibility 8.6.1, 8.7, 9.7, 10.8.1, 10.9.2

Principle 9 Businesses should encourage the development and diffu- 8.6.2, 8.7, 9.4.1 sion of environmentally friendly technologies

Anti-Corruption

Principle 10 Businesses should work against corruption in all its forms, includ- 6.2, 6.4, 6.5, 9.7, ing extortion and bribery 10.8

91 14. GRI Index & Assessment

Profile Disclosure Description Reported Cross-reference/Direct answer STANDARD DISCLOSURES PART I: Profile Disclosures 1. Strategy and Analysis

Statement from the most senior decision-maker of the 2. Message from the Chairman of the Board and 1.1 organization. Fully CEO (p. 3) 2. Message from the Chairman of the Board and CEO (p. 3) / WIND Hellas at a glance (p. 4) / 5. Re- sponsibility in Action (p. 13-14) / 5.2 . We responsi- 1.2 Description of key impacts, risks, and opportunities. Fully bly approach the issues of our stakeholders (p. 18) / 6.5.1. Business Continuity Management (p. 29-30) / 11. 2010 Goals & Results (p. 88) 2. Organizational Profile

2.1 Name of the organization. Fully 4. WIND Hellas (p. 7)

2.2 Primary brands, products, and/or services. Fully 9.1. Products and Services (p. 58)

Operational structure of the organization, including main divisions, 3. WIND …in numbers (p. 5) / 4. WIND Hellas (p. 7-9) 2.3 operating companies, subsidiaries, and joint ventures. Fully / 6.1. Organisational Structure (p. 25)

2.4 Location of organization’s headquarters. Fully 4. WIND Hellas (p. 7)

Number of countries where the organization operates, and names of 1. Information regarding the report (p. 1) / 2.5 countries with either major operations or that are specifically relevant to the Fully sustainability issues covered in the report. 4. WIND Hellas (p. 7)

2.6 Nature of ownership and legal form. Fully 4. WIND Hellas (p. 7) / 4.3. Financial Growth (p. 9)

Markets served (including geographic breakdown, sectors served, and 2.7 types of customers/beneficiaries). Fully 4. WIND Hellas (p. 7-8) Total Capitalization in terms of debt 548.529.000€ and equity 436.634.000€. Also, 4.3. Financial 2.8 Scale of the reporting organization. Fully Growth (p. 9) / 9.1. Products and Services (p. 58) / 10.1. Human Resources Data (p. 74) 2. Message from the Chairman of the Board and 2.9 Significant changes during the reporting period regarding size, Fully CEO (p. 3) / 3. WIND Hellas at a glance (p. 4) / 4. structure, or ownership. WIND Hellas (p. 7) / 4.3. Financial Growth (p. 9)

2.10 Awards received in the reporting period. Fully 4.4. Recognition (p. 10) 3. Report Parameters

3.1 Reporting period (e.g., fiscal/calendar year) for information provided. Fully 1. Information regarding the report (p. 1)

3.2 Date of most recent previous report (if any). Fully 1. Information regarding the report (p. 1)

3.3 Reporting cycle (annual, biennial, etc.) Fully 1. Information regarding the report (p. 1)

3.4 Contact point for questions regarding the report or its contents. Fully Contact (p. inside the back cover)

1. Information regarding the report (p. 1) / 5.1.1. Developing a dialogue with the stakeholders (p. 16- 3.5 Process for defining report content. Fully 17) / 5.2. We responsibly approach the issues of our stakeholders (p. 18) Boundary of the report (e.g., countries, divisions, subsidiaries, leased 3.6 facilities, joint ventures, suppliers). See GRI Boundary Protocol for Fully 1. Information regarding the report (p. 1) further guidance.

3.7 State any specific limitations on the scope or boundary of the report. Fully 1. Information regarding the report (p. 1)

Basis for reporting on joint ventures, subsidiaries, leased facilities, There are no subsidiaries or other entities that 3.8 outsourced operations, and other entities that can significantly affect Fully affect the comparability of data comparability from period to period and/or between organizations. Data measurement techniques and the bases of calculations, including assumptions and techniques underlying estimations 1. Information regarding the report (p. 1) / 3.9 Fully applied to the compilation of the Indicators and other information in …Environment (p. 45-55) the report. Explanation of the effect of any re-statements of information provided There are no changes that modulate the information 3.10 Fully in earlier reports, and the reasons for such re-statement. provided in earlier reports Significant changes from previous reporting periods in the scope, boundary, 3.11 Fully 1. Information regarding the report (p. 1) or measurement methods applied in the report.

3.12 Table identifying the location of the Standard Disclosures in the report. Fully 14. GRI Index & Assessment (p. 92)

Policy and current practice with regard to seeking external assurance 3.13 Fully 1. Information regarding the report (p. 1) for the report. 4. Governance, Commitments, and Engagement

Governance structure of the organization, including committees under 5. Responsibility in Action (p. 13) / 4.1 the highest governance body responsible for specific tasks, such as Fully 6.2. Management Practice (p. 26) setting strategy or organizational oversight.

Indicate whether the Chair of the highest governance body is also an 4.2 Fully 6.2.1. The Board of Directors (p. 26) executive officer. For organizations that have a unitary board structure, state the number 4.3 of members of the highest governance body that are independent and/or Fully 6.2.1. The Board of Directors (p. 26) non-executive members.

4.4 Mechanisms for shareholders and employees to provide recommendations or Fully 5.1.1. Developing a dialogue with the stakeholders (p. 17) direction to the highest governance body. / 6.2.3. Communication with the Management (p. 27) Linkage between compensation for members of the highest governance body, senior managers, and executives (including departure arrangements), 6.2. Management Practice (p. 26-28) / 10.7. Professional 4.5 and the organization’s performance (including social and environmental Fully Development (p. 80-81) performance). 6.2.1. The Board of Directors (p. 26) / 6.2.2. Internal Audit 4.6 Processes in place for the highest governance body to ensure conflicts of Fully (p. 26-27) / 6.4. Transparency - Corruption Handling interest are avoided. (p. 28) Process for determining the qualifications and expertise of the members 4.7 of the highest governance body for guiding the organization’s strategy on Fully 6.2.1. The Board of Directors (p. 26) economic, environmental, and social topics. 6. The Principles Supporting our Corporate Responsibility (p. 24) / 6.3. Code of Contact (p. 27) / 6.4. Transparency - Internally developed statements of mission or values, codes of conduct, and Corruption Handling (p. 28) / 9.3. Responsible Marketing, 4.8 principles relevant to economic, environmental, and social performance and Fully Intellectual Property Rights, Assurance of Communication the status of their implementation. (security and Privacy) (p. 60-61) / 9.5.2. Parental Control (p. 64) Procedures of the highest governance body for overseeing the organiza- 4.9 tion’s identification and management of economic, environmental, and social Fully 6.2. Management Practice (p. 26-28) / 6.5. Quality performance. Management Systems and Accreditations (p. 28-30)

4.10 Processes for evaluating the highest governance body’s own performance. Fully 6.2.2. Internal Audit (p. 26-27)

Explanation of whether and how the precautionary approach or principle is 4.11 addressed by the organization. Fully 6.5.1. Business Continuity Management (p. 29-30)

4.5. Memberships (p. 11) / 5.3. We participate in actions Externally developed economic, environmental, and social charters, principles, that promote Responsible Entrepreneurship Principles 4.12 or other initiatives to which the organization subscribes or endorses. Fully (p. 21) / 8.6. Energy and Climate Change (p. 53) / 9.5.2. Parental Control (p. 64) / 13. Global Compact (p. 91)

4.13 Memberships in associations. Fully 4.5. Memberships (p. 11)

4.14 List of stakeholder groups engaged by the organization. Fully 5.1. Our Stakeholders (p. 15)

5.1. Our Stakeholders (p. 15-17) / 5.1.1. Developing a 4.15 Basis for identification and selection of stakeholders with whom to engage. Fully dialogue with the stakeholders (p. 16-17) 5.1.1. Developing a dialogue with the stakeholders (p. 16-17) / 5.3. We participate in actions that promote 4.16 Approaches to stakeholder engagement, including frequency of engagement Fully Responsible Entrepreneurship Principles (p. 21) / 9.7. by type and by stakeholder group. Responsible Suppliers (p. 68-69) / 10.8. Internal Com- munication (p. 81-85) 5.1.1. Developing a dialogue with the stakeholders (p. Key topics and concerns that have been raised through stakeholder 17) / 5.2. We responsibly approach the issues of our 4.17 engagement, and how the organization has responded to those key topics Fully stakeholders (p. 18-19) / …Environment (p. 45-54) / 9.5. and concerns, including through its reporting. Responsible Information of the Public (p. 63-65) / 9.8. Infrastructures in Society (p. 69-70) STANDARD DISCLOSURES PART II: Disclosures on Management Approach ECONOMY Fully 2. Message from the Chairman of the Board and CEO (p. 3) / 4. WIND Hellas (p. 7) / 11. 2010 Goals & Results (p. 88) Economic performance Fully 4.3. Financial Growth (p. 9) Market presence Fully 4.1. Our Company’s telecommunication network (p. 8) / 4.2. Our store network (p. 9) / 8.7. WIND Fleet (p. 54) /

ASPECTS …Market (p. 57) / 9.7. Responsible Suppliers (p. 68) / 9.7.1. Local Suppliers (p. 69) Indirect economic impacts Fully 8.6.2. We invest in the essence (p. 52-54) / 10.4. Benefits to our employees (p. 76) ENVIRONMENT Partially 3. WIND Hellas at a glance (p. 4-5) / 5. Responsibility in action…(p. 13-14) / 6.5. Quality Management Systems and Accreditations (p. 28-30) / …Environment (p. 45) / 8.1. The axes of our environmental policy (p. 46) / 8.2. Environmental Management System (p. 46) / 11. 2010 Goals & Results (p. 88) Materials Fully 8.3. Raw Materials & Waste (p. 47-51) Energy Fully 8.6. Energy & Climate Change (p. 51-54) Water Fully 8.5. Water (p. 51)

ASPECTS Emissions, effluents and waste Fully 8.3. Raw Materials & Waste (p. 47-51) Products and services Fully 8.7. WIND Fleet (p. 54) / 9.4. Responsible Products (p. 62) Overall Fully 4.1. Our Company’s telecommunication network (p. 8) / 7.4. Environment (p. 39-41) LABOR Fully 5. Responsibility in action (p. 13-14) / …Employees (p. 73) / 11. 2010 Goals & Results (p. 88) Employment Fully 10. Our People (p. 74) Labor/management Fully 10.3. Freedom of Association (p. 76) / 10.4. Benefits to our employees (p. 76-77) / relations 10.8. Internal Communication (p. 81-84) / 10.9. Promoting Volunteerism internally (p. 84-86) Occupational health and safety Fully 10.5. Health & Safety (p. 77-78) /10.3. Freedom of Association (p. 76)

ASPECTS Training and education Fully Employees’ Personal Development & Career Growth (p. 79-81) Diversity and equal Fully 10.2. Human Rights - Equal Opportunities (p. 74-75) opportunity HUMAN RIGHTS Partially 5. Responsibility in action (p. 13-14) / …Employees (p. 73) / 11. 2010 Goals & Results (p. 88) Investment and Fully 9.7. Responsible Suppliers (p.68-69 ) procurement practices Non-discrimination Fully 9.7. Responsible Suppliers (p. 68-69) / 10.2. Human Rights - Equal Opportunities (p. 74-75) Freedom of association and Fully 10.3. Freedom of Association (p. 76)

ASPECTS collective bargaining Child labor Fully 10.2. Human Rights - Equal Opportunities (p. 74-75) Forced and compulsory labor Fully 10.2. Human Rights - Equal Opportunities (p. 74-75) SOCIETY Partially 4.5. Memberships (p. 11) / 5. Responsibility in action (p. 13-14) / 11. 2010 Goals & Results (p. 88) Community Fully 5.2. We responsibly approach the issues of our stakeholders (p. 18-19) / 5.3.1. Supporting the regions (p. 21) /… Society (p. 33-42) / 9.8. Infrastructures in Society (p. 69-70) Corruption Fully 6.4. Transparency - Corruption Handling (p. 28) ASPECTS

PRODUCT RESPONSIBILITY Partially 5. Responsibility in action (p. 13-14) / … Market (p. 57) / 6.5. Quality Management Systems and accreditations (p. 28-29) / 11. 2010 Goals & Results (p. 88)

Customer health and safety Partially 5.2. We responsibly approach the issues of our stakeholders (p. 18-19) / 9.4. Responsible products (p. 62) / 9.5. Responsible Information of the public (p. 63-65) Product and service labelling Fully 9.1. Products and Services (p. 58) / 9.4. Responsible products (p. 64) ASPECTS Marketing communications Fully 6.3. Code of Conduct (p. 27) / 9.3. Responsible Marketing (p. 60-61) / 9.6. Communication with our customers (p. 65-67) Customer privacy Partially 6.3. Code of Conduct (p. 27) / 9.3. Responsible Marketing (p. 60-61)

95 Profile Disclosure Description Reported Cross-reference/Direct answer STANDARD DISCLOSURES PART III: Performance Indicators Economic Direct economic value generated and distributed, including revenues, operating costs, employee compensation, donations and other community EC1 investments, retained earnings, and payments to capital providers and Fully 4.3. Financial Growth (p.9) / …Market (p. 57) governments. Policy, practices, and proportion of spending on locally-based suppliers 9.7. Responsible Suppliers (p. 68) / EC6 at significant locations of operation. Fully 9.7.1. Local Suppliers (p. 69) Procedures for local hiring and proportion of senior management hired EC7 from the local community at significant locations of operation. Fully 10.2. Human Rights - Equal Opportunities (p. 74-75) Development and impact of infrastructure investments and services 8.6.2. We invest in the essence (p. 52-53) / 9.2. The EC8 provided primarily for public benefit through commercial, in-kind, or Partially Mobile and Fixed Telephony Network (p. 59-60) / 9.8. pro bono engagement. Infrastructures in Society (p. 69-70) Environmental EN1 Materials used by weight or volume. Fully 8.3.1. Raw Materials Use (p. 47) 8.6.1. Energy consumption & related pollutants’ EN3 Direct energy consumption by primary energy source. Fully emission (p. 51-52) All energy consumption comes from non-renewable EN4 Indirect energy consumption by primary source. Fully sources. 8.6.1. Energy consumption & related pollutants’ emission (p. 51-52) 8.6.1. Energy consumption & related pollutants’ emission (p. 51-52) / 8.6.2.1. Network modernisation (p. 52-53) / EN5 Energy saved due to conservation and efficiency improvements. Fully 8.6.2.2. Power supply of remote base Stations (p. 53) / 8.6.2.3. Information Systems (p. 53) Initiatives to provide energy-efficient or renewable energy based EN6 products and services, and reductions in energy requirements as a result Fully 8.6.2. We invest in the essence (p. 52-54) of these initiatives. EN8 Total water withdrawal by source. Fully 8.5. Water (p. 51) 8.6.1 Energy consumption & related pollutants’ emission EN16 Total direct and indirect greenhouse gas emissions by weight. Fully (p. 51-52) 8.6.1. Energy consumption & related pollutants’ emission EN18 Initiatives to reduce greenhouse gas emissions and reductions achieved. Fully (p. 52) / 8.6.2. We invest in the essence (p. 52-53) EN19 Emissions of ozone-depleting substances by weight. Partially 8.6.2.5. Substances that harm Ozone layer (p. 54) EN22 Total weight of waste by type and disposal method. Fully 8.3.2. Waste Management (p. 47-49) 4.1. Our Company’s telecommunication network (p. 8) / Initiatives to mitigate environmental impacts of products and services, 7.4. Environment (p. 39-41) / 8.4. Towards a paperless EN26 and extent of impact mitigation. Fully future (p. 50-51) / 8.6.2. We invest in the essence (p. 52- 54) / 8.7. WIND Fleet (p. 54) Percentage of products sold and their packaging materials that are 8.6.2.4. Eliminating hazardous substances in the elec- EN27 reclaimed by category. Partially tronic equipment (p. 54) / 9.4.1. Environement (p. 62) Social: Labor Practices and Decent Work 10.1. Human Resources Data (p. 74) / LA1 Total workforce by employment type, employment contract, and region. Fully 10.2. Human Rights - Equal Opportunities (p. 75) Benefits provided to full-time employees that are not provided to 10.3. Freedom of Association (p. 76) / LA3 temporary or part-time employees, by major operations. Fully 10.4. Benefits to our employees (p. 76-77) Rates of injury, occupational diseases, lost days, and absenteeism, and 10.5.1. Indices of injuries, professional sicknesses, loss LA7 number of work-related fatalities by region. Fully of working days and absences (p. 77) Education, training, counseling, prevention, and risk-control programs LA8 in place to assist workforce members, their families, or community Fully 10.5. Health & Safety (p. 77-78) members regarding serious diseases. Health and safety topics covered in formal agreements with trade LA9 unions. Fully 10.3. Freedom of Association (p. 76) Average hours of training per year per employee by employee LA10 category. Fully 10.6. Training (p. 79-80) Programs for skills management and lifelong learning that support the LA11 continued employability of employees and assist them in managing Partially 10.7. Professional Development (p. 80-81) career endings. Social: Human Rights Percentage of significant suppliers and contractors that have HR2 undergone screening on human rights and actions taken. Fully 9.7. Responsible Suppliers (p. 68) 9.7. Responsible Suppliers (p. 68) / 10.2. Human Rights - HR4 Total number of incidents of discrimination and actions taken. Fully Equal Opportunites (p. 74-75) Operations identified in which the right to exercise freedom of association HR5 and collective bargaining may be at significant risk, and actions taken Fully 9.7. Responsible Suppliers (p. 68) / 10.3. Freedom of to support these rights. Association (p. 76) Operations identified as having significant risk for incidents of child 9.7. Responsible Suppliers (p. 68) / 10.2. Human Rights - HR6 labor, and measures taken to contribute to the elimination of child labor. Fully Equal Opportunites (p. 74-75) Operations identified as having significant risk for incidents of forced HR7 or compulsory labor, and measures to contribute to the elimination of Fully 10.2. Human Rights - Equal Opportunities (p. 74-75) forced or compulsory labor. Social: Society 4.5. Memberships (p. 11) / 5.2. We responsibly approach Nature, scope, and effectiveness of any programs and practices that the issues of our stakeholders (p. 18-19) / 5.3.1. SO1 assess and manage the impacts of operations on communities, including Fully Supporting the Regions (p. 21) / …Society (p. 33-42) / entering, operating, and exiting. 9.8. Infrastructures in Society (p. 69-70) SO4 Actions taken in response to incidents of corruption. Fully 6.4. Transparency - Corruption Handling (p. 28) Social: Product Responsibility 5.2. We responsibly approach the issues of our stake- Life cycle stages in which health and safety impacts of products and holders (p. 18-19) / 6.5. Quality Management Systems PR1 services are assessed for improvement, and percentage of significant Partially and Accreditations (p. 28-29) / 9.4.2. Health (p. 62) / products and services categories subject to such procedures. 9.5.3. Safety & Health (p. 65) Type of product and service information required by procedures, and PR3 percentage of significant products and services subject to such Fully 9.1. Products and Services (p. 58) / 9.4. Responsible information requirements. Products (p. 62) Practices related to customer satisfaction, including results of surveys PR5 measuring customer satisfaction. Fully 9.6. Communication with our customers (p. 65-67)

PR6 Programs for adherence to laws, standards, and voluntary codes related to 6.3. Code of Conduct (p. 27) / 9.3. Responsible Marketing (p. marketing communications, including advertising, promotion, and sponsorship. Partially 60-61) / 9.5. Responsible Information of the Public (p. 63-65) Total number of substantiated complaints regarding breaches of PR8 customer privacy and losses of customer data. Partially Assurance of Communication - Security and Privacy (p. 61) ■ Core Indicators ■ Additional Indicators

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