In general

The Internal Audit Department (hereinafter “IAD”) is an independent organizational unit, which operates in accordance with articles 15 and 16 of Law 4706/2020 on Corporate Governance, as well as the Internal Regulations of the Company and conducts the internal audit of the Company.

The main purpose of the IAD is to provide auditing and consulting services, as well as compliance assurance services, with objective and independent judgment, in order to ensure the smooth and efficient operation of the company, within the framework of its overall strategy, in respect of achieving the planned qualitative and quantitative objectives.

The scope of work of the IAD includes the evaluation of the adequacy and effectiveness of the governance functions, the management of risks and safeguards, as well as the performance of the Company and its subsidiaries, taking into account the provisions of the legislation and regulations of the Hellenic Capital Market Commission, while also being able to provide consulting services. In the latter case, the IAD shall remain independent and not assume administrative responsibility.

The IAD may also support the Company in tasks beyond Internal Audit, such as regulatory compliance or risk management activities, either independently or in collaboration with other units of the Company, in accordance with decisions of its competent bodies. These tasks should not interfere with or give the impression that they interfere with the independence and objectivity of the department.

The head of the IAD is appointed by the Board of Directors of the Company, upon the proposal of the Audit Committee and is a full-time and exclusive employee. During the performance of his/her duties, he/she is personally and operationally independent and has the required knowledge and expertise. The head is subordinate to the Board of Directors, but reports, is supervised and evaluated in terms of its work by the Audit Committee.

The number of internal auditors of the Internal Audit Department is proportional to the size of the company, the number of its employees, the geographical locations where it operates, the number of operating and executive units and the audited entities in general.

Presently, the IAD is staffed by one (1) person, the employee of the company Mrs. Sultana Stroikou, who has specialized and sufficient knowledge and expertise in the accounting and auditing sector, with parallel knowledge of the general structure and functions of the individual departments of the Company.


Activities of the Internal Audit Department

Within the framework of its general responsibilities, pursuant to articles 1 to 24 of law 4706/20120, the IAD:

  1. a) Monitors, controls and evaluates:
  2. aa) the implementation of the Rules of Operation and the Internal Audit System, in particular as to the adequacy and correctness of the provided financial and non-financial information, risk management, regulatory compliance and the corporate governance code adopted by the Company;
  3. ab) the quality assurance mechanisms,
  4. ac) the corporate governance mechanisms; and
  5. ad) compliance with the commitments contained in prospectuses and the Company’s business plans regarding the use of funds raised from the regulated market.
  6. b) Prepares reports to the audited units with findings regarding the items above under a), the risks arising from them and suggestions for improvement, if any. The reports thereof are submitted quarterly to the Audit Committee, after incorporating the relevant views of the audited entities, the agreed actions, if any, or the acceptance of the risk of omission on their behlaf, the limitations on its scope of control, if any, the final internal proposals and the results of the response of the audited units of the Company to the Committee’s proposals.
  7. c) Submits reports at least every three (3) months to the Audit Committee, describing the most important issues and its proposals, regarding the tasks of items described under a) and b) hereof, which the Audit Committee presents and submits, along with its remarks to the Board of Directors.

At the same time, the IAD:

  • Examines the mechanisms for the safeguarding and protection of the Company’s assets.
  • Examines the risk management mechanisms and the operation of the regulatory compliance as well as the integrity, reliability, confidentiality and continuous availability of information systems.
  • Examines any issue requested by the Audit Committee and / or the Board of Directors, if it receives the relevant approval from the Audit Committee.
  • Informs the Audit Committee, and the Board on a regular basis or in exceptional cases, should these circumstances arise.
  • Informs the Audit Committee and the Board of the Company for cases of conflict of private interests.
  • Controls the relations and transactions of the Company with its related parties,
  • Controls the fees and all kinds of benefits to the members of the Board, based on decisions of the General Meeting of the shareholders.
  • Monitors the adequacy of risk identification and management procedures.
  • Controls and ensures the quality and reliability of the information provided by the Management to the Board of Directors regarding the internal control system.
  • Periodically confirms (follow-up) the degree of implementation of the agreed actions and informs the Audit Committee.

In particular, in the context of the evaluation of the Internal Control System (Internal Controls) and Risk Management (Risk Management) of the Company, the Internal Control Department:

  • Monitors, examines and evaluates the adequacy and effectiveness of all the policies, procedures and safeguards of the Company regarding on the one hand the Internal Control System (Internal Controls) and on the other hand ensuring the quality of the financial information provided to the Board.
  • Identifies the main risks and uncertainties of the Company, evaluates the methods used by the Company to identify and monitor them as well as address the most important ones through the Internal Controls system, as well as their proper and accurate disclosure to the published financial statements.
  • Examines the existence and content of the procedures, according to which the Company’s staff will be able, in confidence, to express their concerns about possible illegalities and irregularities.