Sustainable development policy

Introduction

The company "Aegean Airlines S.A." (hereinafter the "Company") establishes, maintains and implements basic principles regarding the pillars of society, the environment and the economy and has developed, formulated and implemented a specific policy regarding sustainable development and the management of social, environmental and governance issues (Environmental, Social, Governance Issues – ESG).
This policy (hereinafter the "Sustainability Policy") has been formulated in harmony with the requirements of the existing legislative and regulatory framework, and in particular considering:

Directive 2014/95/EU of the European Parliament and of the Council of 22 October 2014 amending Directive 2013/34/EU as regards disclosure of non-financial and diversity information by certain large undertakings and groups,
Law 4403/2016, which adapts Greek legislation to the provisions of Articles 19, 20, 29, 30, 33, 35, 40 to 46 of Directive 2013/34/EU and to the provisions of Directive 2014/95/EU,
Section 7 “Non-financial Information Report” of the Circular 62784/2017 of the Ministry of Economy and Development,
Law 4548/2018 on the reform of the law of public limited companies
Law 4706/2020 on the Corporate Governance of Public Limited Companies.

Furthermore, the Company, in the context of the preparation and implementation of this Sustainable Development Policy, has considered and has voluntarily adopted international standards and principles, with particular emphasis on:

The “2030 Agenda” of the United Nations (UN) with the 17 Sustainable Development Goals (SDGs), adopted in September 2015 by the 193 UN member states,
The 10 Principles of the UN Global Compact.

Scope

Sustainable development, contribution to society and partnership in collective goals that promote social well-being and protect the environment constitute the only sustainable business practice, which is why they have been at the heart of the Company's daily efforts since the first day of its operation. The factors related to environmental protection, positive impact on society and good governance, constitute a set of criteria which the Company, as well as its stakeholders, take very seriously into consideration.
The Company has adopted responsible practices, due diligence policies, reporting mechanisms, commitments and targets for all the above issues which are described in detail in the Company's annual sustainability and non-financial reporting reports. The recording and communication of all the above issues to stakeholders is aligned with international and national standards and indicators with the aim of providing reliable and transparent information to all stakeholders. The annual reports are available on the corporate website.

Field of application

The current sustainability policy:

It binds the Company and all its subsidiary Companies (hereinafter jointly with the Company, the Group).
>It applies to all members of the Board of Directors, senior management, employees of the Company and the Companies of the Group, and in general all persons employed by the Group either under an employment contract or through another contractual relationship.
It binds all third parties that provide services for the Group (supply chain) or in the name and on behalf of it (including partners and suppliers, intermediaries, and any other persons with whom the Group collaborates under outsourcing contracts or other types of agreements).
Covers all activities of the Group in Greece and abroad, including all operations carried out by the Company, its subsidiaries or a third party acting on behalf of or in collaboration with the Group (value chain).

The rules included in the Company's Procurement Code of Ethics & Conduct, the Corporate Governance Statement and the Greek Corporate Governance Code for Listed Companies of the Hellenic Corporate Governance Council (HCGCC), which the Company has adopted, remain in force and are applied in parallel with this Policy.

Stakeholders

Stakeholders are the environment (direct and indirect) that interacts with the Company and is interested in its activities. For the Company, stakeholders are defined as those entities that either have a direct or indirect impact on the Company and its activities or are recipients of the direct or indirect impact resulting from the Company and its activities. A basic principle of the Company is to conduct a dialogue with its stakeholders, creating appropriate conditions for the exchange of views to listen to their needs and expectations, receiving feedback at regular intervals on its operation and the impacts it creates.
In the context of its operation, the Company collaborates within and outside the aviation community with various stakeholder groups, with distinct needs and priorities:

Passengers
Employees
Shareholders/Investors
Aviation Community
Government/Regulatory Authorities
Suppliers/Partners
Local and Broader Society

Through continuous dialogue with stakeholders, the Company improves its Sustainable Development strategy, its relevant initiatives and its corresponding commitments, with the aim of operating responsibly across the entire scope of its activity, at local, national and international levels.

Corporate Governance and Business Ethics

The Company has adopted the Principles of Corporate Governance as defined by current Greek legislation and international practices. Corporate Governance as a set of rules, principles and control mechanisms based on which the Company is organized and managed, aims at transparency towards the investing public, as well as safeguarding the interests of the Company's shareholders and all those connected with its operation. The Company has voluntarily decided to adopt and implement the Hellenic Code of Corporate Governance for Listed Companies of the Hellenic Federation of Enterprises and Industries (SEV). This Code is available on the website of the Hellenic Exchanges S.A. group (https://www.helex.gr/el/web/guest/esed-hellenic-cgc ). More information on the Structure and Governance of the Company can be found on its website, in the Corporate Governance section.
Furthermore, the company is certified in accordance with ISO 37000:2021 (Governance of organizations).

Anti-Corruption and Anti- Bribery

The Company recognizes that the phenomena of corruption, bribery, fraud and money laundering from illegal activities undermine its ethical environment and can cause human rights violations, adverse environmental impacts, distortion of competition, obstruction of the distribution of economic resources and the economic development of the country.
The treatment of corruption and bribery is a key element of the Company's operating regulations. The principle of integrity is linked to firm commitment to zero tolerance for these issues and is implemented by avoiding any transaction and contact with any third party that may have committed or is suspected of being involved in creating conditions for the development of incidents of corruption, extortion or bribery.
The participation of directors in the successful implementation of the policy is direct and substantial, emphasizing that corruption and bribery are not acceptable.
Furthermore, the company is certified in accordance with ISO 37001:2017 (Anti-bribery Management Systems).

Respect for Human Rights

The Company respects human rights, defends diversity and treats all its employees, customers and partners with respect and equal treatment. Any form of child forced, or compulsory labor is condemned and denounced. At the same time, the Company is legally and ethically committed to processing personal data in a lawful manner, with respect for the rules of confidentiality of processing and the rights of data subjects, in full compliance with European Regulation 679/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and Law 4624/2019 on the protection of personal data.
The Company's Human Resources & Corporate Affairs Department promotes the principles of equal treatment, respect for human rights, diversity, zero tolerance for child or forced labor and the provision of equal opportunities to all. Additionally, a direct communication channel with the Internal Audit department has been developed, ensuring the protection of identity and the anonymity of any complaint for reporting incidents that endanger or violate basic Human Rights principles. At the same time, the Company trains its staff with a view to ensuring equality for every passenger, equal treatment and preventing any kind of racist behavior.

Procurement Code of Ethics and Conduct

The Company has developed and implemented a Procurement Code of Ethics and Conduct, which concerns the Company’s requirements towards its suppliers, as well as the central procurement department. This Code is based on the principles of the UN Global Compact, as well as on relevant international standards, including the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, Children’s Rights and Business Principles, the core conventions of the International Labour Organization (ILO), the OECD Guidelines for Multinational Enterprises, as well as relevant practices concerning the environment.
Social Responsibility
As the country's main air carrier, the Company contributes decisively to the creation of value for society and the environment in which it operates. By providing high quality in all services provided and recognizing its impact on the Economy, Society and the Environment, the Company creates value in the quality of Greek air transport and contributes substantially to sustainable development, contributing, among others:

to the national economy and the country's GDP, through an increase in inbound tourism and the Company's business activity,
to employment, through the creation of direct and indirect jobs throughout the Company's value chain,
to innovation and infrastructure, through the development of new air transport services and products,
to social development, through the support of social programs, vulnerable groups, the new generation, culture and sports.

Quality, Safety and Customer Service

Flight safety and operational readiness are top priorities for the Company and are intertwined with its very operation. The Company applies a Safety Management System, and it is the responsibility of each employee to contribute to safety performance and its continuous improvement, as well as to take serious compliance with safety rules and flight safety in all actions and activities performed. Furthermore, the Company, aiming to meet the needs of customers and improve their experience, has developed and implemented a comprehensive quality management system in accordance with the guidelines of international standards:

ISO 9001:2015 - Quality Management System - Requirements
ISO 10002:2018- Quality Management System - Customer Satisfaction - Guidelines for Handling Complaints in Organizations.

Labor issues

The Company’s employees are the most important and valuable asset, the driving force behind its successful course and development. The Company invests in creating strong relationships with its employees by ensuring an operating framework based on respect for human rights, the protection and safeguarding of their health and safety and the enhancement of the value of each employee as an active member in the formulation and implementation of strategic and business goals.
The Company takes into consideration all applicable legislation with respect to the fundamental principles, as defined in the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work. As an employer, it contributes to improving the living standards of employees through full and secure employment and decent work. It ensures excellent working conditions, recruits and maintains qualified personnel in accordance with the principles of equal treatment without discrimination and provides opportunities for development based on merit. The Company provides fair remuneration based on contracts that are consistent with the relevant legislation and ensures compliance with national regulations on legal minimum wages, working hours and the granting of leave.
The Company ensures the creation of a safe and healthy workplace and is not limited only to compliance with the current legislative framework but also extends to the adoption of best practices and training and awareness-raising actions, promoting a culture of accident prevention and safe work. The protection of the health and safety of staff and associates is ensured holistically through the Health and Safety Management System (OHSAS 18001:2007) and the Health and Safety Policy implemented by the Company.

Social Contribution

Social contribution is a fundamental principle of the Company's philosophy, which seeks to support vulnerable social groups, as well as the work of important social organizations. Through its activity, the Company seeks to:

the promotion of local suppliers and producers by including their products in the aircrafts,
the creation of synergies with institutions and organizations for the promotion of cities, regions, the country's cultural heritage and the Greek tourist product,
the sustainable development of cities through the provision of safe and accessible transportation systems for more people,
the support of Greek sports and the new generation.

Environmental Responsibility

A responsible attitude towards the environment is a priority for the Company. An integral part of its general policy is not only the full compliance and observance of the applicable legislative requirements in the exercise of each corporate activity, but also the continuous effort to improve its environmental performance, in the context of the effort to reduce its environmental footprint. The Company's management documents its commitment to environmental protection through the environmental policy, which is not limited to the adoption of appropriate and best green practices, but also extends to awareness-raising actions of the public and its employees, as well as to the support of organizations working for this purpose. Environmental compliance and environmental performance are documented with THE certification according to the requirements of the international standard ISO 14001:2015, thus providing full and broad transparency regarding the environmental care and protection provided.
The Company monitoring energy consumption and related greenhouse gas emissions as it has recognized that the aviation industry plays a significant role in carbon dioxide emissions. The combustion of aviation fuel is responsible for gas emissions that contribute to climate change and reducing fuel consumption is a key objective of the Company's environmental protection program. Carbon dioxide emissions are reported to the:

Ministry of Environment and Energy,
European Emissions Trading Scheme (EU ETS Directive 2003/87/EC), where they are monitored by an independent accredited body,
Swiss Emissions Trading Scheme from 1/1/2021 (CH ETS),
British Emissions Trading Scheme (UK ETS),
ICAO Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).

In the waste management sector, the Company has designed and is implementing a pioneering in-flight recycling program, which includes the separation into four types of materials. On the ground, every effort is made to minimize the consumption of consumables, as well as to recycle waste, where possible. Regarding organic waste, the Company, in collaboration with Athens International Airport, is implementing a composting program. Regarding hazardous waste, the nature of the operations dictates the use of many chemical products, which is governed by strict frameworks that ensure their proper management from use to final disposal.
Finally, the activities of the aviation sector are associated with noise pollution from the aircrafts during various phases of the flight, but also during movement on the ground, which is why the Company is implementing a series of measures to reduce the noise pollution caused by its activity.

Implementation, monitoring, and modification of the Policy

The Board of Directors is responsible for overseeing the implementation of the Sustainable Development Policy. In this context, the Internal Audit Unit provides assistance by conducting scheduled audits throughout the year. As a result of these audits, reports are compiled to inform the Board of Directors.
The Board of Directors and/or the Internal Audit Unit may recommend revisions to the Sustainable Development Policy. A revision of the Sustainable Development Policy takes place whenever deemed necessary.
Regarding the Company's daily operations, the Corporate Responsibility Manager is responsible for adherence to the principles and practices of this Policy, as well as for the Sustainable Development issues mentioned herein and concerning the Company in general. Organizationally, the Corporate Responsibility Manager reports to the Human Resources and Corporate Relations Directorate.
The Policy is maintained electronically, and any modification is adequately documented. Every modification requires approval from the Sustainable Development Committee and the Board of Directors.