Internal Control System

Internal Audit System

Internal Audit System is the set of internal control mechanisms (safeguards) and procedures, including risk management, internal control and regulatory compliance, which continuously covers every activity of the Company and contributes to its safe and effective operation.

Internal Audit Department

The Internal Audit Department operates according to articles 15 and 16 of law 4706/2020, the Hellenic Corporate Governance Code that the Company has voluntarily adopted ( and provisions of the Internal Regulation Charter. Internal Audit Charter that has been approved by the Company’s Board of Directors, describes the responsibilities, duties and obligations of the Internal Audit Department in relation to the above framework.

The Internal Audit Department is an independent organizational unit within the Company in order to monitor and improve its functions and policies regarding the Internal Audit System.

The Internal Audit Department adopts the following definition from the International Institute of Internal Auditors and is universally accepted:

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


Regulatory Compliance Unit

The Regulatory Compliance Unit constitutes an independent organisational unit operating within the Company, and also constitutes separately the 2nd defence line aiming at the establishment and implementation of the proper and updated policies and procedures, so that the full and continuous compliance of the Company with the relevant applicable and effective institutional and supervisory framework can be timely achieved, and a full picture about the extent of fulfilment of this purpose shall exist at any time. For the establishment of the relevant policies and procedures, the complexity and nature of the company’s business has been assessed, including the development and promotion of the new products and business practices.

The Regulatory Compliance Unit operates pursuant to the article 13 of L.4706/2020, the decision no.1/891/30.09.2020, the Greek Corporate Governance Code, voluntarily adopted by the Company, and the provisions of the Charter of Operations of the Company.

The Regulatory Compliance operations shall be performed by the Head of the Regulatory Compliance.

External Independent Evaluation of Internal Control System

The first evaluation of the ICS has been assigned to Grant Thornton (TIN 094399329) and aimed at ensuring the adequacy and effectiveness of the Company’s ICS, in accordance with the provisions of article 14 par.3 lit.i and par.4 of L.4706/2020, the Decision No.1/891/30.09.2020 of the Board of Directors of the Hellenic Capital Market Commission, as well as the Decision No. 2/917/17.06.2021, which has amended the Dec.1/891.

The entire project has been directed by Mrs Athina Moustakis, Partner holding the Reg.No. 28871 in the Institute for Certified Public Accountants, who participated in all its stages and was responsible for the final approval, signing and execution of the deliverables. The conclusion of Adequacy and Effectiveness Evaluation Report of the ICS was unqualified (without reservation), given that no substantial deficiencies have been detected and the relevant Detailed Report dated 6/3/2022 has been submitted to the Board of Directors and to the Company’s Audit Committee, whereas its summary has been submitted to the Hellenic Capital Market Commission.



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