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The Hellinikon Stakeholder Lamda Development / Project Engagement Greece Plan

1 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project CONTENTS

01 07 PURPOSE AND OBJECTIVE p. 04 GRIEVANCE MECHANISM 7.1 Principles 02 7.2 Proposed Grievance Procedure p. 21 PROJECT DESCRIPTION p. 05 08 STAKEHOLDER ENGAGEMENT 03 DOCUMENTATION p. 24 APPLICABLE REQUIREMENTS p. 06 3.1 National and EU requirements 3.2 EBRD Performance Requirements 09 MONITORING AND EVALUATION p. 25 04 STAKEHOLDER ENGAGEMENT PROCESS p. 08 10 ROLES AND RESPONSIBILITIES p. 26 05 STAKEHOLDER IDENTIFICATION p. 09 06 STAKEHOLDER ENGAGEMENT PROGRAM p. 14 6.1 Stakeholder Engagement Activities to Date 6.2 Information Disclosure to Date 6.3 Engagement Plan

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APPENDIX A - GRIEVANCE FORM TEMPLATE

List of Figures Figure 1 Grievance Procedure p. 22 Figure 2 Grievance Log Example p. 23

List of Tables Table 1 Identified Groups of Stakeholders related to the Project p. 09 Table 2 Stakeholder Engagement Activities p. 16 Table 3 Information Disclosure Plan Template p. 19 Table 4 Action Plan for Stakeholder Engagement and Disclosure p. 20

Acronyms and Abbreviations EBRD European Bank for Reconstruction and Development EIA Environmental Impact Assessment EMP Environmental Management Plan E&S Environmental and Social ESP EBRD Environmental and Social Policy ESAP Environmental and Social Action Plan EU European Union JMD Joint Ministerial Decision PD Greek Presidential Decree PRs EBRD Performance Requirements SEP Stakeholder Engagement Plan SEA Strategic Environmental Assessment SEIS Strategic Environmental Impact Study SPA The share purchase agreement between Hellenic Republic Asset Development Fund S.A. and the Company relating to the purchase of 100% of the shares of Hellinikon SA, as ratified by the Greek Parliament on [•]

3 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 01 PURPOSE AND OBJECTIVE

The European Bank for Reconstruction and Development (the The overall aim of this SEP is to ensure that a timely, consistent, com- “EBRD” or the “Bank”) has made an equity investment in Lamda De- prehensive, coordinated and culturally appropriate approach is tak- velopment S.A. (the “Company”) participating in the EUR 650 mil- en to consultation and project-related information disclosure. It is lion share capital increase that took place in December 2019. Funds intended to demonstrate the commitment of Lamda Development raised will support the financing of the first phase of the Hellinikon to an ‘international best practice’ approach in line with national re- Urban Regeneration Development (the “Project” or the ‘’Hellinikon quirements and EBRD’s Environmental and Social Policy (ESP) (2014) Project’’), which is intended to regenerate the former Hellinikon Air- Performance Requirements (PR) 10. port located on the coastal front into a sustainable and inte- grated residential, tourist and commercial infrastructure. The SEP defines the stakeholder engagement process including This document in hand is the Stakeholder Engagement Plan (SEP) for stakeholder identification and mapping, engagement, information the Project, which is part of the Disclosure Package. disclosure, consultation meetings and public participation.

Stakeholder Engagement refers to a process of sharing information and knowledge, seeking to understand and respond to the concerns of others and building relationships based on collaboration. Stake- holder consultation and disclosure are key elements of engagement This SEP is a living document, which will be amended and and essential for delivery of successful projects. updated in the course of Project planning and implementation.

4 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 02 PROJECT DESCRIPTION AND IMPACT

The Project site of Hellinikon, the old airport of Athens, is located 8 seums and cultural venues, health and wellness centres, significant km southwest of the centre of Athens. It covers an area of approxi- space for sports and recreation, a modern business park with an ed- mately 620 hectares and has an approximate 3.5 km waterfront, in- ucational and R&D hub as well as the total regeneration of the exist- cluding a marina. The Project comprises the combined development ing marina and the entire Coastal Front that will, along with the Park, of the real estate assets in the former Athens airport of Hellinikon, will be the major attractions of the site. the former Olympic Sailing Centre and the National Athletic Youth Centre in Agios Kosmas (), which, as a whole, constitute the so- The Project constitutes the largest urban regeneration project in Eu- called Metropolitan Hub of Hellinikon - Agios Kosmas. rope, designed to add significant new investments and uses in the areas of tourism, culture, entrepreneurship, innovation and in the The objective of the Project is the re-development of the old Ath- environment. Thus, it is expected to have a positive effect not only ens airport site into a mixed-use location of national importance and on the region of Attica but on the entire country as well. international visibility, as well as an internationally-recognised des- The investment amounts to €8 billion and is expected to create tination, enhancing the attractiveness of the greater Athens area, 10,000 permanent jobs during the construction period and 75,000 both as a global tourist resort and as a business, leisure, health and jobs (IOBE study, July 2016) at its maturity. Moreover, the Project research and development hub. The construction of a world-class is expected to substantially contribute to the repositioning of Ath- Metropolitan Park covering an area of 2,000,000 sq.m., as well as ens as one of the major world-class tourist destinations as it will pro- the enhancement of the Coastal Front, both fully accessible to the vide a significant number of new units as well as thematic tourism public. venues, expected to attract at least one million new tourists, while significantly reducing (summer) seasonality and at the same time The Project consists of an integrated urban development model that increasing the average stay over and spending of tourists in Ath- will combine the area’s natural beauty and unique inherent charac- ens. The Hellinikon Project investment is expected to contribute to teristics with landmark buildings and state-of-the-art infrastructure. the country’s GDP by 2.4% until the development completion date, The ‘green’ and ‘smart’ design approach of the Project will offer while contributing a total of over €14 billion in taxes to the Greek world-class services and amenities while improve the standard of liv- State over the same timeframe. ing of the entire Attica area’s inhabitants. The investment will include a diverse range of residential commu- For more information please visit Hellinikon’s website: nities, hotels, shopping centres, family entertainment venues, mu- http://www.thehellinikon.com

5 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 03 NATIONAL AND EU REQUIREMENTS

This SEP is prepared in consideration of the following standards: EC), which stipulates that any citizen should have the right to get • Applicable local, national aånd regional regulatory requirements, a broad and easy access to environmental information and that including relevant EU legislation related, but not limited to, the the public has a right to participate in decision making in environ- EIA legislation; mental matters; • The EBRD’s Environmental and Social Policy (ESP) (2014) and the • Joint Ministerial Decision 3711/2003, “On the means of inform- Stakeholder Engagement relevant Performance Requirements; and ing citizens on the procedure of approval of environmental • EBRD’s Grievance Management, Guidance Note (2012). terms.” • Presidential Decree of 28.02.2018 (AAP35/01.03.2018 “On the 3.1 National and EU requirements approval of the Integrated Development Plan (IDP) of the Met- ropolitan Hellenic - Agios Kosmas Region of Attica”; The Greek national legislation on Stakeholder Engagement activities • 74502 EX 2019 / 3-7-2019 NTUA (2792 B ‘) Joint Ministerial De- includes the following: cision of the Ministers of Finance, Culture and Sport, and the • Joint Ministerial Decision 107017/28.8.2006 ((Β΄1225/5.9.2006) Ministers of Environment and Energy (“Approval of the general “On the assessment of the effects of certain plans and programs organization of the Metropolitan Park of the Metropolitan Hub on the environment, in compliance with the provisions of Direc- of Hellinikon – Agios Kosmas and its environmental conditions”), tive 2001/42/EC with the same subject”, as modified with Joint which was subsequently amended by No. 93298 EX 2019 / 28- Ministerial Decision 40238/28.9.2017 (Β΄ 3759/25.10.2017); 8-2019 Joint Ministerial Decision (Government Gazette 3294 B); • Joint Ministerial Decision 1649/45/2014, “On the specification of • Joint Ministerial Decision no. 93620 EX 2019 / 29.08.2019 – consultation procedures and information to the public and par- (Government Gazette B ‘3347) of the Ministers of Economy and ticipation of interested parties in the public consultation proce- Development, Finance, Environment and Energy, and Tourism, dures within the context of the environmental licensing of cate- for the Development Zone in the area of the former airport; gory A projects and activities”, which specifies provisions for the • Joint Ministerial Decision no. 96572 EX 2019 / 05.09.2019 – consultation means of the different authorities and the ways of (Government Gazette B ‘3405) for the Development Zones in informing the public, as well as its participation in the public con- the coastal area; sultation during the environmental permitting procedure; • Joint Ministerial Decision no. 109171 EX 2019/ 03.10.2019 (Gov- • Law 4014/2011 (A209/2011) “On the environmental licensing of ernment Gazette 3687) on the Development Zones Α-Π1, Α Π2, works and activities”; Α-Π3, Α-Π4, Α-Π5, Α-Π6 and ΠΜ-Π1; • Law 3422/05, “On the ratification of the Aarhus Convention on access to information, public participation in decision-making and access to justice in environmental matters” (Directive 2013/35/

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• Ministerial Decision no. 3906 (B5798 21/12/2018) “On the spe- turally appropriate manner and free of manipulation, interference, cialization of the content of the Environmental Impact Assess- coercion and intimidation. The nature and frequency of stakeholder ment study for the Implementation of the Integrated Develop- engagement must be proportionate to the nature and scale of the ment Plan”; project and its potential adverse impacts. • Ministerial Decision no. 3907 (Β5798/21.12.2018) that amends the Ministerial Decision no. 37674 (B2471/10.8.2016) on the PR10 requires in particular: classification of public and private works in categories pursuant • The commencement of stakeholder engagement activities at to Law 4014/2011; and the earliest stage of project planning and continuous through- • Ministerial Decision no. 167563/15.4.2013 “On the specifications out the life of the Project; of procedures and criteria for the environmental licensing of • A systematic identification and mapping of stakeholders to be works and activities pursuant to Law 4014/2011” (Β΄ 964). documented into a SEP; • All of this legislation is publicly available and has been the sub- • A disclosure of the ESIA and disclosure of project information ject of regular press reporting. to ensure meaningful consultation and to allow stakeholders to provide inputs and raise concerns, taking into account specific 3.2 EBRD Performance Requirements needs of groups that may be differentially or disproportionately affected by the project; and The Performance Requirements (PRs) of the EBRD provide a use- • The provision of an effective procedure or mechanism through ful structure to define the manner in which the Company has been which people can make comments or raise grievances. complying with its information and public engagement obligations. The relevant PR for Stakeholder Engagement is PR10 (Information Disclosure and Stakeholder Engagement) . The EBRD Guidance Note on Grievance Management is considered EBRD’s PR10 states that national laws and regulations regarding a benchmark for good practice with regard to defining grievance public information disclosure and consultation must always be con- mechanism and managing grievances. The Guidance Note advo- sidered when developing and implementing a project. In the event cates that managing grievances is essential for a robust stakeholder that national laws are insufficient or there are significant discrepan- engagement strategy and, implicitly, for a successful project imple- cies between national and PR10 provisions, the principles of PR10 mentation. The Guidance Note outlines how the grievances process should then be considered. should be set up, with human resources allocated to it, as well as ar- The EBRD PR10 requires its clients to conduct stakeholder engage- rangements made by the project developer around maintaining con- ment based on providing local communities that are directly affect- fidentiality and keeping timelines defined for resolving grievances. ed by the Project and other relevant stakeholders with access to timely, relevant, understandable and accessible information, in a cul-

7 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 04 STAKEHOLDER ENGAGEMENT PROCESS

Stakeholder engagement constitutes the basis for building up constructive and strong rela- tionships, which are essential for a successful project’s risk management. Good stakeholder engagement that lasts throughout the life of a project will enable Lamda Development to solve problems faster and at less cost. The key principles are to be open and transparent with stakeholders, and to be willing to accept responsibility to account for impacts associated with the Project activities.

The objective of the Stakeholder Engagement process is to: • Identify key groups affected by or with an interest in the Hell- • provide means for adequate engagement and ensure that mean- inikon project; ingful environmental and social information is disclosed to the • understand their interests in and concerns with the Project; Project’s stakeholders; and • provide an outline of planned Stakeholder Engagement for the • define the roles, responsibilities, and resources necessary to im- Project; plement the SEP, including the procedures to monitor and fol- • build and maintain a constructive relationship with Stakeholders, low up on stakeholder feedback and grievances. in particular the directly affected communities;

8 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 05 STAKEHOLDER IDENTIFICATION

The objective of stakeholder identification is to establish which organizations and individuals A stakeholder is defined as any may be directly or indirectly affected (positively and negatively / permanently or temporarily) individual or group, who is or have an interest in the Project. Stakeholder identification is an ongoing process, requiring potentially affected by the Project regular review and updating as the Project proceeds. (affected parties) or is interested The main groups of stakeholders identified so far are listed in Table 1. The list will be updated in the Project and its impacts and modified in the course of the Project development. (interested parties).

Table 01 Identified Groups of Stakeholders related to the Project Group of Stakeholders Description Point of contact Relevance to/ Interest in the Project

Local population • Residents located • Residents of the Elliniko-, • Lamda Development’s website and • Possible nuisance during construction near the project and municipalities; the Company’s information desk. Any phase; affected area; • Local businesses & other businesses request is forwarded to the relevant • Benefits from infrastructure development • Residents of with activity in the area around the departments to answer. The e-mail or (road and tram network, pedestrian and communities located Project. phone number of the person who cycle routes, etc); near roads used contacted the company is archived for transporting according to the statement of consent. • Quality of life (metropolitan park, materials during numerous playgrounds, coastal front) construction. and economic benefits during and post construction.

Municipal • The Project spans • Municipality of Elliniko-Argyroupolis • Chief Corporate Affairs Officer, Corporate • Provide valuable local support and three municipali- Authorities • Municipality of Alimos; Affairs. contribution to ensure that the project ties: Elliniko-Argy- brings optimum value to local residents roupolis, Alimos • Municipality of Glyfada; and Glyfada. • If their concerns are not taken into ac- count, they may proceed to actions that may put the development at risk • Will often be the first point of contact for proposals and complaints from local residents, who will expect the municipal authorities to pursue their complaints/ proposals.

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Table 01 Identified Groups of Stakeholders related to the Project Group of Stakeholders Description Point of contact Relevance to/ Interest in the Project

Administrative • National author- • Ministry of Finance; • Regular meetings. • Issue the necessary Joint Ministerial Bodies and ities (related Decisions (JMD) relevant to the ministries) • Ministry of Environment and Energy; • Chief Corporate Affairs Officer, Corpo- Authorities rate Affairs. development • Regional author- • Ministry of Growth & Investment; • Issue the necessary permits for ities (district • Ministry of Culture and Sports; level government construction and other works authorities). • Ministry of Infrastructure & Trans- • Issue decisions pertaining to certain port; aspects of the project and its operation • Ensure that archaeological and other • Ministry of Tourism findings on the site are treated appro- • Region of Attica; priately whilst allowing the project to • Region of Attica - Regional Unit of proceed. South Athens. General public, • General public • Universities and academic commu- • Lamda Development’s website and • Provide expert opinion and advice on Non-Governmen- • Specialized nity (esp. economists, architects, the Company’s information desk. Any particular aspects of the project related tal Organizations environmental, urban planners, etc.); request is forwarded to the relevant to their specialization social and research department to answer. The e-mail or • May make proposals to make the (NGOs) and inde- organizations, • Chambers of Commerce & Industry; pendent experts NGOs phone number of the person who Project more valuable to local residents • Industry & Professional associations contacted the company is archived or to particular vulnerable or minority • Experts on a (SEV, SETE, etc.); national and inter- according the statement of consent. groups national level. • Think tanks (IOBE etc.); • Public consultation on the Strategic • Will help to ensure environmental best • Key opinion leaders in Greece and Environmental Impact Study took place practice and monitoring abroad; in 2017 (see section 6.1). • Will contribute proposals to assist the incorporation of the project into the • NGOs fabric of local commercial and residen- • Environmental NGOs; tial communities • Activist groups. • May raise objections and other obsta- cles to certain aspects of the project.

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Table 01 Identified Groups of Stakeholders related to the Project Group of Stakeholders Description Point of contact Relevance to/ Interest in the Project

Administrative • National author- • Ministry of Finance; • Regular meetings • Issue the necessary Joint Ministerial Bodies and ities (related Decisions (JMD) relevant to the devel- ministries) • Ministry of Environment and Energy; • Chief Corporate Affairs Officer, Corporate Authorities Affairs. opment • Regional author- • Ministry of Growth & Investment; • Issue the necessary permits for ities (district • Ministry of Culture and Sports; level government construction and other works authorities). • Ministry of Infrastructure & Transport; • Issue decisions pertaining to certain aspects of the project and its operation • Ministry of Tourism • Ensure that archaeological and other • Region of Attica; findings on the site are treated appro- • Region of Attica - Regional Unit of priately whilst allowing the project to South Athens proceed.

Media • Press (news & • National news media (general interest • According to the Corporate Commu- • Cover news related to the Project on an lifestyle) & business, e.g. Kathimerini, To nication Policy of the Company, the ongoing basis • Radio, TV Vima, Ta Nea, Proto Thema, Capital. person responsible from Lamda • Help inform the public and specific • Internet sources gr, Euro2day.gr, Newmoney.gr, SKAI, Development is the Chief Marketing audiences on key aspects of the Project (blogs, social me- MEGA, etc.); and Communications Officer. • The media acts as a conduit of public dia, etc.). • Local media of Southern Attica; (e.g. opinion and feedback relating to issues notia.gr, vimaonline.gr, nou-pou.gr) of general and particular concern, allowing the Company to respond either • Specialised media (real estate, individually or publicly to the issues construction, environmental, etc., raised. We view media reporting and e.g. ered.gr) commentary as an opportunity rather • Individual journalists; than a threat. • Bloggers & social media influencers.

Organizations in- • Construction and • Master Planner: Foster + Partners • Their contact point is their direct • Involved in the planning, design and volved in Project design companies Limited partner or the respective department construction of particular elements of involved in imple- • Staff of Hellinikon S.A. and Lamda of Lamda, as well as the Chief Project the project implementation/ mentation of the internal Stake- Project Development. Manager & Construction Office and • Employees and contractors are directly holders • Contractors and Chief Planning Officer involved in the development of the contractors’ staff. • Human Resources (for employees). site and have a direct interest in its success (and in the proper observance of environmental and health and safety regulations).

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Table 01 Identified Groups of Stakeholders related to the Project Group of Stakeholders Description Point of contact Relevance to/ Interest in the Project

Investors • Lamda • Consolidated Lamda Holdings • The request is received via Treasury • Provide the equity capital necessary for Development (50.62%) and Investors Relations Department, the realization of the project shareholders Lamda Development’s website and the • Monitor and raise questions regarding as of 31.12.2019. • Voxcove Holdings (10%) Company’s information centre (phone/ the project progress and economic • Aegean Airlines SA (1.66%) fax) and is forwarded to the appropriate results and prospects. • Greek institutional investors department to answer. The e-mail or (6.93%) the phone number of the person who • Greek private investors (8.17%) contacted the company is archived according the statement of consent. • International investors (20.85%). • According to the Corporate Commu- nication Policy of the Company, the person responsible from Lamda Development is the Chief Marketing and Communications Officer.

• Creditors/ Banks • Eurobank Ergasias SA • The request is received via Treasury • Provide funding for the implementation • Analysts • bank and Investors Relations Department, of the project Lamda Development’s website and the • Provide debt capital for Lamda devel- • Stock brokers • Athens Exchange Group. • Athens Exchange Company’s information centre (phone/ opment and the construction of the community. fax) and is forwarded to the appropriate project department to answer. The e-mail or • Provide independent analysis, valuations the phone number of the person who and assessments on action plans, deliv- contacted the company is archived erables, actual results versus plans and according the statement of consent. forecasts pertaining to Lamda Development • According to the Corporate Commu- and the project. nication Policy of the Company, the person responsible from Lamda Development is the Chief Marketing and Communications Officer.

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Table 01 Identified Groups of Stakeholders related to the Project Group of Stakeholders Description Point of contact Relevance to/ Interest in the Project

Specific vul- • People with diffi- • Lamda will ensure the rehousing of • The request is received via Lamda • In addition to the NGOs and public ser- nerable groups culty in engaging public benefit organisations currently Development’s website and Compa- vices directly impacted by the Project as with the stake- housed in the Hellinikon site (e.g. ny’s information centre (phone/ fax) they are situated on the site, overall the impacted by holder consulta- the Project tion process Metropolitan Community Clinic at and is forwarded to the appropriate Project is intended to provide signifi- • People with Hellinikon); department to answer. The e-mail or cant benefits to all of the residents of special vulnerability • Lamda is consulting directly with the phone number of the person who Attica as a whole, and local residents in due to physical the NGOs that are to be moved to contacted the company is archived particular, regardless of age or need. disability, social, appropriate facilities within the project according the statement of consent. • Consultation is particularly important political, or eco- in order to ensure that the publicly-ac- nomic standing, (Amimoni, Ermis, Victor Artant, legal status, limited Association of People with Mul- cessible parts of the Project provide education, lack of tiple Sclerosis), where Lamda has suitable access and amenities to all employment or undertaken to ensure the creation social groups. housing. of a housing space for associ- ations representing those with special needs within the property with specifications corresponding to the spaces currently used by these associations in the property.

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6.1 Stakeholder Engagement Activities to Date Sustainability Report (for 2019) will be published, and once the Proj- ect commences, its aspects will be integrated. The Project has been subject to a local Strategic Environmental In addition, there is a Project dedicated website, which aims to pro- Impact Study (SEIS) for the PD (Presidential Degree) and to an En- vide relevant information about the Project to the public. The web- vironmental Impact Study (EIS) for the Joint Ministerial Decisions site includes a contact form, and a grievance form. (JMDs) with associated public consultation and public disclosure in Information Disclosure to Date accordance with local/national legal and permitting requirements Disclosure of information about the Project is essential, to guide the reportedly, stakeholders have been engaged, in accordance with the process of stakeholders in understanding and evaluating the risks, national environmental legislation. The public consultation of the impacts and opportunities of the Project. The existing Project web- Strategic Environmental Impact Study started by the publication of site (https://thehellinikon.com/) already provides detailed informa- the relevant announcement in six newspapers on 20 July 2017 and tion about the Project in Greek and English language. The ‘Media 21 July 2017. Associations and individuals took part in the consul- Centre’ on the website provides updates regarding press releases as tation and expressed their objections to a number of issues related well as other relevant informative notes and publications. to the Integrated Development Plan and its SEIS. The public consul- Besides using the contact form via the website, specific information tation ended when the Environmental Licensing Directorate of the requests can be made to Lamda Development directly: Ministry of Environment issued its positive recommendation on 21 November 2017 (updated on 20 December 2017) having taken into Lamda Development S.A. consideration all the opinions of the bodies and the public even af- 37A Kifissias Ave. (Golden Hall) ter the expiration of the 20-day deadline for submission of opinions 151 23 Maroussi, Greece set out in Article 2 par.4 of Law 4062/2012. Phone +30 210 7450600 Fax +30 210 7450645 After the preparation of the EIA, various municipal consultation events have taken place. Comments from municipalities, affected [email protected] residents and journalists have been received during these events https://www.lamdadev.com/el/ as well as events (press, etc) organised by the company. In addition, Lamda Development is actively implementing a CSR program for which an external consultant has been hired. The SEIS has been prepared, consulted upon and subsequently dis- closed in accordance with Greek legislation. Furthermore, the first

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6.2 Engagement Plan Stakeholder Engagement Activities

The Project will ensure that consultation with stakeholders will be Stakeholder engagement will have to be carried out at the following undertaken under an inclusive approach. All affected groups shall phases of the Project implementation: be represented as appropriate, to ensure that particular needs are highlighted and given sufficient weight and inclusion. Stakeholders 1. Pre-construction; will be informed about decisions and changes in project planning 2. Construction (envisaged to commence in 2020); and that affect them along with reasons and considerations on which 3. Operation. the decision is based, because of the engagement process. Consul- tation shall be free of external manipulation, interference, coercion At each stage certain engagement activities will be conducted by or intimidation. All engagement will be documented adequately. Lamda to keep the stakeholders informed and continuously reach for their feedback. Lamda is responsible to follow up all activities Detailed plans for later phases of the Project will be developed planned. during the next phases of the Project (construction and operation). This version of the SEP will be disclosed together with the Environ- The intention will be to continue an active program of engagement mental and Social Action Plan (ESAP) and the Non-Technical Summa- with affected and interested parties to ensure they are kept in- ry (NTS). Future versions of the SEP, which are under responsibility formed and have an opportunity to continue a constructive dialogue of Lamda Development, should be consulted with affected commu- about the Project and with Lamda Development. Lamda will develop nities to achieve feedback on perception of engagement during the a list of meetings offering the opportunity for stakeholders to pro- pre-construction phase. Additionally, the implementation of the SEP vide comments and raise concerns and reach out to special needs will be subject to regular monitoring. Specific information should be groups in order to ensure that their views and concerns are taken presented how specific groups will be consulted; mechanisms to into account. Locations and dates will be communicated in advance feed disclosure results back and to consider them. Table 2 provides and Lamda Development will define the relevant channels of notifi- an example of the stakeholder engagement activities conducted cations. to date, as well as planned future activities.

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Table 02 Stakeholder Engagement Activities Date Timing/ Target Stakeholders Type of Description Responsibility Follow-up/Action Project engagement Points resulting Stage Activity from activity

March each year. Pre-construction, Lamda shareholders Release of Fiscal Published on athexgroup.gr and Chief Construction, Investors Year results & on lamdadev.com Marketing and Operation. teleconference. Communications Creditors/ Banks Analysts Press Release sent to all nation- al media and key international Officer. Stockbrokers business media Financial Community Special presentation for analysts Athens Exchange via teleconference. Media.

May, September, Pre-construction, Lamda shareholders Release of Q1, Published on helex.gr and on November each year. Construction, Creditors/ banks H1, 9-month lamdadev.com Operation. results and Analysts Press Release sent to all national teleconference. media and key international Financial Community business media Media. Special presentation for analysts via teleconference.

June each year & Pre-construction, Lamda shareholders, Annual Meeting Invitation (incl. dates and agenda) at different points Construction, Investors of Shareholders, to the annual shareholders meeting Operation. Extraordinary published on athexgroup.gr and throughout the year Creditors/ Banks Analysts Meetings of lamdadev.com in advance (at if deemed necessary. Stock brokers Shareholders. least 20 days before the meeting), Financial Community as well as the resolutions of the meeting. Athens Exchange Media.

May each year. Pre-construction, Creditors/ banks Annual briefing Presentation for analysts at the Construction, Analysts of analysts on the Athens Exchange. Operation Financial Results. Financial Community.

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Table 02 Stakeholder Engagement Activities Date Timing/ Target Stakeholders Type of Description Responsibility Follow-up/Action Project engagement Points resulting Stage Activity from activity

June each year. Pre-construction, Lamda shareholders Corporate Annual Presentation during the Annual Chief Construction, Investors CSR Report, in- General Assembly and distribution Marketing and Operation. cluding Hellinikon to the press. Communications Stock brokers Project aspects. Officer. Athens Exchange Creditors/ banks Analysts Financial Community Media.

Ongoing. Pre-construction, Lamda shareholders Announcements Published on athexgroup. Construction, Investors concerning The gr and on lamdadev.com, Hellinikon Project thehellinikon.com Operation. Stock brokers posted on the Press Release sent to all national Athens Exchange athexgroup web- media and key international Creditors/ banks site and on the business media. project’s website Financial Community here. Media.

Multiple times per Pre-construction, National authorities Participation in Keynote speeches and participation year. Construction, Regional authorities business con- in panel discussion by the CEO Operation. ferences and and other top executives, as Local authorities forums. appropriate. Business Community Financial community Potential investors.

When necessary. Pre-construction, National authorities Meetings and One-to-one or one-to-few meetings Construction, Regional authorities calls. and calls between Lamda Operation. Development top executives and Local authorities interested parties in appropriate Business Community circumstances. Financial community Potential investors.

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Table 02 Stakeholder Engagement Activities Date Timing/ Target Stakeholders Type of Description Responsibility Follow-up/Action Project engagement Points resulting Stage Activity from activity

Prior to procurement Pre-construction, Residents and businesses Digital app. Development of a special digital Chief of and construction Construction. located near the app to provide the space for a Marketing and two-way dialogue between Lamda Communications actions. Hellinikon project site. Development and residents, as Officer. well as to respond to questions.

Prior to procurement Pre-construction, National authorities Launch event & Organization of a launch event of works and Construction. Regional authorities press conference to take place at the beginning of construction. construction actions. Local authorities Business Community Media

Ongoing. Preconstruction, National authorities Public consulta- All construction actions will Construction, Ministry of Culture: The tion including be operated with respect to Operation: the environment, culture and Ministry of Culture’s archaeology issues during the archaeological findings, according terms are described JMDs for the to a very strict procedure that is in relevant PD, JMDs, described to the two JMDs, which Development will be confirmed by [permanent SPA and general legis- Zone in the area on-site experts appointed by the lation. Both the Central of the former air- Ministry]. port and related to Archaeological Council the casino licensing (“KAS”) and the Central competition, JMC Prior the beginning of any Committee for modern no. 93620 EX technical work at the Hellinikon 2019 / 29.08.2019 Site, archaeological research will monuments have issued – (Government be carried out and measures will opinions which were taken Gazette B ‘3347)]. be taken to protect and preserve into account in the above And the JMDs for the monuments, where necessary, in accordance with the terms, to be followed the Development Zones in the terms of the memorandum that during construction and coastal area, JMC will be concluded between the operation. A Memorandum no. 96572 EX Company and the archaeological authorities according to par. 12 of understanding as 2019 / 05.09.2019 – (Government of article 7 of PD 28.2.2018 described in the PD, to Gazette B ‘3405)]. (Government Gazette AAP 35). clarify further details of cooperation between the Ministry of Culture and HELLINIKON SA is the next step to be finalized within 2020.

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Table 02 Stakeholder Engagement Activities Date Timing/ Target Stakeholders Type of Description Responsibility Follow-up/Action Project engagement Points resulting Stage Activity from activity

Prior to procurement Pre-construction, Local authorities Meetings with Organization of meetings with Chief of works and Construction. Media. Local Authorities. Local Authorities and NGOs as Marketing and required on Site to understand Communications construction actions. and support their needs. Officer.

Prior to Pre-construction, Prime Contractors/ Monthly status Reports to be submitted to the construction actions Construction. Construction managers reports. Company by all key contractors throughout the construction and throughout and Project Management phase in order to ensure effective construction. services providers. monitoring.

Information Disclosure

Lamda Development will ensure that the following type of informa- For this purpose, there will be regular updates on the Project web- tion will always be up to date and available to individuals and groups site, announcements and press releases issued, information dis- affected by the Project: closure and information on the grievance mechanism through the • The type and duration of Project activities; stakeholder engagement application. Additionally, the public griev- • Potential risks and impacts of the Project and intended mitiga- ance form will be accessible via the Company’s website (www.lam- tion measures; dadev.com), the Hellinikon website (www.thehellinikon.com) and • Planned stakeholder engagement, consultation and participa- the Company’s Information Desk. tion process; • Communication channels and timelines; and • Process of submitting grievances and how they will be managed.

Table 03 Information Disclosure Plan Template Type of Documents/ Project Stage Date, Schedule, Target Publication Source Language Information to be Timing Stakeholders released The Hellinikon 2-Year Construction Q2 2020 All stakeholders Lamda Development Greek & English Plan

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Table 04 Action Plan for Stakeholder Engagement and Disclosure Activity/Element Target Description Timing Responsibility Follow up Stakeholders (documentation, monitoring etc.)

Stakeholder comments All stakeholders. Comments on the EIA in the frame of the formal Completed in 2017 during SEIS Lamda/ External on the Project SEIS and environmental permitting procedure for the Project. and EIA preparation in consultant. EIA. The comments were received and processed by the accordance with Greek Ministry of Environment. legislation (see section 6.1). Public hearing of the Project EIA in the frame of the formal environmental permitting procedure for the Project (Joint Ministerial Decision 5798 21/12/2018).

Online publication All stakeholders. A summary of the grievance mechanism (in the form Prior to commencement of Lamda/ External of project related of a bullet point list of the grievance process) and the construction. consultant. documentation and Grievance Form (Appendix A) shall be available on grievance form. the Project website in Greek and English languages. The Project NTS and ESMP will be available in digital format (as pdf files) on the Project’s website in both Greek and English languages.

Addressing comments, All stakeholders. Comments, questions and grievances on the Project During the lifetime of the Lamda/ External questions, grievances received via email, or post will be addressed and Project. consultant. received on the documented according to the grievance procedure. Project. Enquiries and answers provided via telephone will be also recorded in the grievance log.

Address Project-related Local community Explain the Project, its associated impacts and Prior to commencement of Lamda/ External aspects in local members improvements, implementation progress during construction and during the consultant. community meetings. (municipality, scheduled community meetings. lifetime of the Project. representatives Identify the extent of the impact on local business of affected activities. parties). Bring awareness of the means of information and grievance submission available.

Address Project-related Municipal Discuss/inform on Project and implementation status During the lifetime of the Lamda/ External aspects during regular Environmental during the regular meetings with the environmental Project. consultant. authorities’ meetings. Authorities. authorities.

20 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 07 GRIEVANCE MECHANISM

In addition to the contact form on the Project website, Lamda Devel- opment will establish a functioning grievance mechanism for inter- nal staff as well as external stakeholders.

7.1 Principles

A grievance may take the form of specific complaint about impacts, The Grievance Procedure specific to the Project is developed with damage or harm caused by the Project, concerns about access to the the following aims: project stakeholder engagement process or about how comments have been addressed, and concerns about Project activities during construction or operation, or perceived incidents or impacts. • To build and maintain trust with all stakeholders; A Grievance Mechanism is an established process to receive stake- • To prevent adverse consequences of failure to adequately holder concerns and grievances and to facilitate their resolution address grievances; and through a set procedure. Depending on the scale of potential risks • To identify and manage stakeholder concerns and thus support and adverse impacts of a project, the grievance mechanism may be effective risk management. adjusted.

The general principles of an effective grievance mechanism are:

• Assignment of responsible person, team or function to organise the resolution of grievances; • All stakeholders have the right to be informed about the Project and to raise concerns and suggestions during the decision-mak- ing process; • Grievances and concerns are to be addressed promptly and ef- fectively; • The process is to be transparent, culturally appropriate and anon- ymous (if required, protecting privacy of affected individuals); • The Grievance Mechanism is to be accessible to all stakeholders at no cost and without retribution; and • All stakeholders are to be continuously informed about the Grievance Mechanism. 21 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 07

7.2 Grievance Procedure

The internal and external Grievance Procedure will be free, open location will be displaying information of the project sponsor, along and accessible to all and comments and grievances will be addressed with a phone number included for possible grievances. promptly and effectively in a fair and transparent manner that is Lamda Development shall assign staff responsibilities to appropri- culturally appropriate. Information about the procedures, who to ately manage the Grievance Management (See section 10). contact and how, will be made available on the Project website and The grievance procedure comprises the following steps: communicated during engagement meetings. A sign at the Project

Figure 1 Grievance Procedure

1. Receipt and Recording • Identification of grievance (submission through online form, call center, phone, fax, Lamda Development or grievance box). of Grievance • Recording and classification of grievance in Grievance Log.

2. Acknowledgement Formal acknoweldgement through a personal meeting, phone call, email or of Grievance Receipt letter as appropriate, within 5 working days of submission.

• Delegation of grievance to relevant Lamda department. 3. Investigation and Resolution • Identification of risk category. • Development of appropriate response.

4. Response on Grievance • Implementation of required actions, recording of actions in grievance log. Resolution • Communication to affected party and recording of reaction. • Closing of grievance.

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7.2 Grievance Procedure

Grievances shall be documented by using an electronic grievance log • Proposed resolution of the complaint; to ensure proper registration and giving Lamda Development the • Due date; possibility to track the given response to a grievance. A grievance log • Decision; will contain the following entries: • How and when relevant Project decisions were communicated • Date lodged by complainant; to the complainant; • Contact details of complainant (if not anonymously submitted); • Feedback from the complainant; • Name of the staff charged with addressing the complaint; • Results; and • Type of grievance and general information; • Closing date of the issue.

Figure 2 Grievance Log

(Source: EBRD Grievance Management, Guidance Note)

Lamda Development will collect logged grievances on a regular basis During construction and operation phase, the grievance form will (e.g. once a week). The Grievance Form is presented in Appendix A. be made available at The Hellinikon Project ΑPP and at the Visitor The grievance form will be uploaded in the contact sections of the Centre. website of both Lamda Development (www.lamdadev.com) and The If the complainant is not satisfied with the solutions proposed/ Hellinikon Project (www.thehellinikonproject.com). implemented to address the grievance, it is entitled to exercise all Grievance forms will also be accessible at the Company’s reception his/her legal remedies in accordance with the legal framework of (37A Kifissias Ave. (Golden Hall) 151 23 Maroussi, Greece). Greece, including applications for interim injunctions, cancellation All requests are forwarded to the appropriate department to an- of administrative acts and claims for tortious compensation. swer. The Corporate Communications Department is responsible to contact the interested party and provide them the necessary infor- mation.

23 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 08 STAKEHOLDER ENGAGEMENT DOCUMENTATION

Documentation is key to ensure transparent Stakeholder Engagement and inter- nal and external communication. Lamda Development aims at addressing every issue raised in an adequate and timely manner and compile individual responses and arrange further meetings where necessary. This shall provide input and consideration in the overall de- cision-making process. To guide and manage this process, documentation and reporting of all stakeholder engagement is essential. The elements of the Stake- holder Engagement documentation shall include at least:

• Minutes produced from all external consultation meetings and documented within a consultation register; • Grievances log and the documented provided responses; and • Register of trainings, internal emails and intranet notes will be kept in order to document the communication regarding the workers’ Grievance Mecha- nism.

Lamda Development shall update this SEP prior to construction and a second time prior to operation. Additional updates due to Project development may be required. In the process of updating the SEP the past stakeholder engagement activities will be described.

24 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 09 MONITORING AND EVALUATION

The Project performance will be monitored and periodic reports will Engagement level of stakeholders will be monitored by a set of indi- be provided to EBRD. Lamda Development will have the responsibil- cators, which may include the following items: ity to facilitate any monitoring visit or audit requested by EBRD. An- nual monitoring reports will be made available to affected commu- • Number of communications; nities concerning ongoing risks, impacts and mitigation measures. • Type of communications; Reporting will be scheduled according to the ESMP. • Frequency of communications; • Number of valid complaints (and number rejected as unclear, The effectiveness of engagement activities will be evaluated against problematic or dubious); the goals and objectives set out in the SEP. The evaluation will be • Type of complaints; performed independently based on meeting minutes, stakeholder • Sources of complaints; engagement logs and the grievance log. This evaluation will exam- • Number of resolved complaints; ine the extent to which activities were implemented in accordance • Average time for resolution of complaints; with the SEP, and the extent to which they achieved the aims de- • Number of presentations on environmental, social and econom- fined here. ic status of the company; • Number of mass media articles and / or announcements; In the monitoring and evaluation process for stakeholder engage- • Number of stakeholders involved per action; ment, all the consultations undertaken, all the issues raised, and the • Level / degree of involvement for each stakeholder; actions taken will be recorded. Also, this process implies the descrip- • Number of visitors on the websites; and tion of the lessons learned and any changes to the consultation pro- • Number of requests for information via websites. cess. All queries in relation to the project will be filed in a comments registry, analysed, and reported to management team on a two- Therefore, Lamda Development will keep a clear record of all these months basis during project development and implementation. The indicators. results and feedback from information disclosure and public consul- tation will be documented and reported as appropriate. Summary reports will contain details about suggestions or concerns raised by stakeholders and how their comments have been taken into account.

25 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 10 ROLES AND RESPONSIBILITIES

Lamda Development will be responsible to ensure adequate stake- It depends on Lamda’s management to decide how these activities holder engagement and grievance management throughout the en- will be allocated e.g. same employee, dedicated experts, group of tire Project. In line with this, Lamda Development will coordinate all employees, Lamda’s management etc. aspects related to the implementation of the SEP according to all relevant national and international standards. Apart from contact point and the internal mechanism, including all Company’s departments (development, legal, treasury and invest- Clear definition and communication of roles and responsibilities are ment relations, investment department, construction’s manage- key for a successful implementation of the SEP. Lamda Development ment, financial and administrative and communications and mar- will assign an employee to manage and follow up the grievances re- keting departments) all requests are forwarded to the appropriate ceived for the Project. Training will be provided if required. department to answer. The Corporate Communications Depart- Key roles and responsibilities for Lamda Development to assign are: ment is responsible to contact the interested party within 5 days of request submission and provide them the necessary information • Overall SEP implementation: monitoring and reporting; • Provide access to relevant information about the project on the Where a grievance management system is managed by an external Project’s and Lamda Development’s website; service provider, it is important to recognise that the ultimate re- • Organize public hearings related to the permitting processes sponsibility for grievance resolution lies with Lamda Development, and project compliance; including such cases where the third party fails to reach an accept- • Organize public consultations with the local community via a spe- able resolution. cial mobile app in order to provide information and engage in a two-way dialogue with interested parties regarding the project; • Media campaigns and events/ Press releases/ Information dis- closure: offer relevant information to the mass media and third parties; • Implement and manage the grievance mechanism system via a special call centre and through email including: identification, re- ception, maintenance of grievance log, preparation and issuance of response to grievances.

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APPENDIX A Grievance Form Template Public Grievance Form

Reference No. (assigned by [Insert Project Implementing Party’s name]:

Please enter your contact information and grievance. This informa- Please note: If you wish to remain anonymous, please enter your tion will be dealt according to the Personal Data Protection State- comment/grievance in the box below without indicating any con- ment at the end of the present form. tact information – your comments will still be considered by Lamda Development.

Full Name Description of incident or Please provide all relevant grievance: information that are considered Anonymous submission I wish to raise my grievance anonymously necessary for the purposes of the present form. Please mark how you wish By mail (please provide mailing address): to be contacted (mail, ______telephone, e-mail). By telephone (please provide telephone number): ______By e-mail (please provide e-mail address): ______

Preferred English for communication Other, please specify: ______

Date of incident/grievance: What would you like to see happen to resolve the problem? One time incident/grievance (date ______) Happened more than once (how many times? ______) On-going (currently experiencing problem)

27 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 10 PERSONAL DATA PROTECTION STATEMENT WITH WHOM WE SHARE IT

Our company, “LAMDA DEVELOPMENT SA”, a company incorporat- Your personal data is collected and further processed by the respon- ed under the laws of Greece (“société anonyme”) with its registered sible and duly authorized employees of our Company. seat located at 37a Kifisias Avenue, Marousi 151 23, Greece (herein- In the context of Grievance Handling, the recipients of your personal after “LAMDA”, ”Company”, “we”) is Data Controller for the process- data might be one or more of the following categories of our part- ing of your personal data in the context of the handling of grievance ners: (hereinafter “Grievance Handing”). • Other companies such as other legal entities of our Group or third parties that collaborate with us for the purposes of the This Statement intends to provide information on the nature of your present privacy notice. personal data collected, the means and the purposes of collection, • Any other administrative, judicial or public authority or any legal any third parties with which this data is being shared, as well as the or natural person against which LAMDA has the relevant obliga- rights that you have, according to Greek Law 2472/1997 and Regula- tion or right to disclose such data, by law or by court decision. tion 2016/679 of the European Union on the protection of personal data. HOW LONG WE KEEP IT

WHICH PERSONAL DATA WE COLLECT Your personal data in the context of Grievance Handling will be re- tained for a period of five (5) years upon the receipt of the griev- In the context of Grievance Handling, LAMDA collects and further ance, on a case by case basis, depending on the nature of the griev- processes your name and your contact details, as well as any other ance. Upon expiration of the retention period, LAMDA safeguards personal data that you willingly disclose in your grievance. that your personal data is destroyed from its systems or records, provided that their retention is no longer required for our business, WHY WE COLLECT IT tax or accounting obligations or the advocacy of its rights before any competent court or any other authority. Personal data is processed pursuant to the following legal bases: A. Legitimate Interest The collection of the aforementioned data is necessary for the ful- filment of a legitimate interest of LAMDA, and more specifically, for the handling and reply to the grievance submitted to the Company. Β. Legal Claims LAMDA might further process sensitive personal data of yours, which you have willingly disclosed in your grievance, in order to be able to exercise and/or advocate its legal claims.

28 Stakeholder Engagement Plan - The 15 | 06 | 2020 Hellinikon Project 10 OUR COMMITMENTS You can exercise any of the abovementioned rights by submitting a written request to our Company. You can expect a reply to such a In order to ensure the minimization, completeness and accuracy of request within one (1) month following its receipt by the Company. your personal data, we are committed to periodically review your This deadline may be extended for two (2) additional months due to data and rectify or erase the data, which is not necessary for the the complexity of your request, and/or the high volume of requests purpose described in this notice. Furthermore, we guarantee that received. we have undertaken all the appropriate technical and organization- al measures, according to the technical standards and the applica- CONTACT DETAILS ble laws and regulations, in order to safeguard that the process of your personal data, either by the Company or by third parties on its You may address all your questions, clarifications or requests relat- behalf, is legitimate, appropriate and adequately secure in order to ed to the process of your personal data in the context of Grievance prevent any accidental or unlawful destruction, loss, alteration, un- Handling, by contacting the Data Protection Officer of LAMDA via authorised disclosure of, access to or any other use of such data. the email: [email protected]

YOUR RIGHTS In any case, if you feel that we did not provide a satisfactory response to your request and the protection of your personal data is violated According to applicable legislation, in the context of Grievance Han- in any way whatsoever, you have the right to lodge a complaint with dling, you have and can exercise the following rights, after verifica- the Hellenic Data Protection Authority, using the following contact tion of your identity: details: • right to access your personal data, including the right to be in- formed on whether your personal data is being processed at all and if yes, to obtain further information on the processing, Website www.dpa.gr / • right to rectification of any inaccurate or incomplete personal data of yours, Address Kifisias Avenue 1-3, P.C 115 23, Athens • right to object to the processing, for which the Company invokes Contact Center +30 210 6475600 it legitimate interest, as well as -and only if the conditions speci- Fax +30 210 6475628 fied by applicable legislation are met: • right to erasure and E-mail [email protected] • right to restriction of processing

In case of exercising your right to rectification, erasure and restric- tion of your data, these requests will also be communicated to any third-party recipients to whom this data has been in the context of Grievance Handling.

29 Stakeholder Engagement Plan / The Hellinikon Project /