SUSTAINABLE DEVELOPMENT REPORT 2016 - Sunlight...sustAinABLE dEvELopmEnt rEport 2016 sunLigHt group...

SUSTAINABLE DEVELOPMENT

REPORT 2016

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SUSTAINABLE DEVELOPMENT REPORT 2016 | SUNLIGHT GROUP

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Contents

3. EnvironmEnt 36 3.1 Investments in the circular economy 39 3.2 Precautionary approach

to environmental challenges 43 3.3 Solid waste 44 3.4 Air emissions 49 3.5 Effluents 56 3.6 Natural resources 60 3.7 Biodiversity 65

4. Anti-corruption 66 4.1 Steps to ensure a work environment

free from corruption 68 4.2 Communication of Anti-Corruption

Policies and Procedures to third parties 70 4.3 Participation in joint actions

for anti-corruption 72

initiAtivEs For tHE sociEtY 74

strAtEgic pArtnErsHips 80

sunLigHt group AwArds 81

AppEndiX sustAinABLE dEvELopmEnt goALs 82

oLYmpiA group 4

sunLigHt At A gLAncE 6

cEo mEssAgE 8 AcHiEving BusinEss dEvELopmEnt ALong witH sociAL rEsponsiBiLitY 10 mAnAgEmEnt tEAm 12

industriAL ActivitY And EnvironmEntAL pHiLosopHY FocusEd on tHE circuLAr EconomY 14

sustAinABLE dEvELopmEnt strAtEgY, FocusEd on rEsponsiBLE production 16

1. HumAn rigHts 20 1.1 Health and Safety 22 1.2 Adherence to working hours and

provision of annual leaves beyond the legislative framework 27

1.3 Fair treatment and equal opportunities 28

2. LABour conditions 32 2.1 Freedom of association

and collective bargaining 34 2.2 Elimination of forced

or compulsory labour 34 2.3 Abolition of child labour 34 2.4 Νon-discriminationinemployment 35

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OLYMPIA Group Building bridges between the present and the future

Olympia Group of Companies, founded by Panos Germanos, has been a reference point for the Greek corporate community since the ‘80s, by “building bridges” between the present and the future. With consistency, continuity, duration and faith in the philosophy of entrepreneurship, the Group is growing dynamically within highly competitive markets, aiming for business excellence. Olympia Group is in its fourth decade of successful presence in Greece, through a wide range of activities that build bridges between the present and the future. These “bridges” are built through the Group’s business units: retail, industry, telecoms, distribution of technology products,businesssoftwareandconsumerfinance.

At the same time, for the past twenty years the Group has also been creating value in the international business scene, either through exports or through its physical presence abroad, constituting a pillar for growth. With strong management, a successful course of strategic collaborations and more than 5,800 direct and 12,000 indirect jobs, both in Greece and abroad, Olympia Group constitutes an extended business ecosystem in critical market sectors.

> In the technology products retail sector, through the Public chain stores, with 54 stores in Greece and Cyprus and 2 e-commerce stores.

> In the energy storage sector, through the company SYSTEMS SuNliGHT SA, which maintains its production in Greece and exports to more than 100 countries all over the world.

> In the industrial recycling sector, through the innovative company SuNliGHT REcYcliNG, located in Komotini, which constitutes the next business step for SYSTEMS SUNLIGHT SA.

> In the technology products distribution sector, through the company WESTENET DiSTRibuTiON,withsignificantactivity in the distribution of IT hardware and mobility products in Greece and Cyprus.

> In the development of business software services and products in Greece and Southeast Europe, through SOFTONE.

> In the telecoms sector, through the mobile telephony company PlAY in Poland, one of the most dynamic providers, demonstrating the highest growth at European level.

> Intheconsumerfinancesector,throughtheFinishcompanyAASA, which has been expanding its operations in the countries of North Europe.

> In the electronic engineering sector, tailored to the needs of global shipping, through METiS cYbERSPAcE.

> In the wider telecoms sector for the European market, through TOllERTON iNVESTMENTS.

THE FOuNDER OF OlYMPiA

The founder of Olympia, Panos Germanos, has infused into the Group, the partners and the personnel, his personal vision on corporate development and business ethics. He has created a modern, financially strong Group, which isgoverned by non-negotiable corporate responsibility rules. This philosophy dictates practices of business autonomy, without obligation and dependencies. This way, he ensures that Olympia Group’s future will be equally strong, while “building bridges” to allow a smooth, creative, and successful transition to the new era.

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Reference date: June 2017

Unless stated otherwise, the data in this Report refer to SYSTEMS SUNLIGHT and SUNLIGHT RECYCLING.

GRI 102-45

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State-of-the-art industrial battery production plant in Xanthi

We contribute to the improvement of the country’s environmental performance regarding the collection rates of old lead – acid batteries

green mission, a sunLigHt rEcYcLing environmental initiative

gold award to sunLigHt rEcYcLing, in the waste recycling – reuse category

Produced 1.56 million batteries in 2016

39,416 m3 Wastewater treated in 2016

0%of effluent discharge

One of the biggest

motive power battery producers in the world

Holding a prominent position in the market of

advanced technology batteries30 years of collaboration with

Toshiba in the European market

SUNLIGHT at a glance

84%of production is exported

100+ countries

500+ clients

GRI 102-2 GRI 102-7

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We invest in Greece

1 4Group Companies

757 Employees

€ 23 mil.investment in the Recycling Plant in Komotini during the past 5 years

20% increase of Group employees in 2016

€ 40 mil.annual reduction in resource outflows

100+ countries

>58% of the total needs in lead is covered with recycled lead from SUNLIGHT RECYCLING

82%the total efficiency of SUNLIGHT RECYCLING’s recycling procedure

Turnover in 2016*

€ 153.9 mil.16% increase compared to 2015

EBITDA 2016*

€ 17.2 mil.41% increase compared to 2015

SUNLIGHT RECYCLINGNew recycling unit in Komotini

Production

15,600 tons of recycled lead in 2016

*data for SUNLIGHT Group

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Dear readers,

It is with great joy that we present to you SUNLIGHT Group’s first Sustainable Development Report, covering the fiscalyears of 2014, 2015, and 2016. In the context of our focus on the goal for sustainable development and corporate responsibility, SUNLIGHT Group is committed to adhere to the United Nations Global Compact (UNGC) Ten Principles, in the areas of Human Rights, Labour Conditions, the Environment, and Anti-Corruption. This Report constitutes ourfirstCommunicationonProgressregardingouradherenceto these Principles. Moreover, the Report includes indicators from “Global Reporting Initiative” (GRI) International Standards for sustainability reporting, as well as the connection of the issues included in its contents with the new UN Sustainable Development Goals.

In celebration of SUNLIGHT Group’s 25 years of operations and having now fully adopted an export orientation, 2016 hasbeenarecordyearforourfinancialresults.TheGroup’sturnover has exceeded € 153 mil., recording a 16% increase compared to 2015. The company continued increasing its shares in every sector of operation, including industrial Traction and Backup batteries, Consumer - Cylindrical batteries and advanced technology batteries for defence, having a prominent position in most of them.

In 2016, we continued investing in our factory with the purpose of meeting the increasing demand for our products. In addition, we strengthened our human resources with 137 new positions - a very important number both for our Group and for the local communities of Xanthi and Komotini, the regions that provide us with the majority of our employees.

Circular economy is an integral part of our Group’s corporate philosophy and the basis of our approach to sustainable development. In this context, in 2016, recycled lead used by SYSTEMS SUNLIGHT reached 58% of the total quantity of lead, while SUNLIGHT RECYCLING produced 15,600 tons, which were used for the production process of SYSTEMS SUNLIGHT. At the same time, we launched the environmental initiative Green Mission, which aims to raise awareness among the public and the business community about the proper recycling of lead – acid batteries.

Maintaining high ethical standards remained a top priority for 2016, in compliance with national and international laws. Having adopted the Corporate Compliance Code of Conduct since 2015, this year we implemented once more a new series of initiatives. The most important was our participation in the anti-corruption roundtable discussion held by TRACE International, a world-renowned anti-corruption organization. At the same time, with respect to human rights and diversity, we have improved our performance on employment-related indicators.

SUNLIGHT Group’s first Sustainable Development Reportdoes not only serve as an account on everything we achieved during the past three years, while staying focused on our objectives and vision; it also lays the foundations for everything we have pledged to achieve in the future, having as our main concern the respect to the environment, to society, to human rights at work while being focused on employee health and safety and on ensuring product quality and safety.

With our best regards,

Vasili BillisChairman of BoD & CEO

CEO MessageGRI 102-14

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Circular economy is an integral part of our Group’s corporate philosophy and the basis of our approach to sustainable development.


Achieving Business Development with Social Responsibility

1991

Acquisition of the battery manufacturing plant located in Neo Olvio, in Xanthi, by GERMANOS S.A.

2006

Spinoffoftheindustrial sector from GERMANOS S.A. and establishment of SYSTEMS SUNLIGHT S.A company.

1985

Germanos S.A. starts to represent TOSHIBA consumer batteries in the Greek market

2004

CertificationtoOHSAS18001 (Health & Safety System for human resources)

1995

Design and production of dry cell batteries, using Chloride- Zinc technology, which are friendly to the environment (without mercury).

1997

Certification to ISO 9001 (Quality Assurance System)

2009

Installation of a photovoltaic system for providing lightning to the factory warehouse building, exclusively via this system

2001

CertificationtotheISO14001(Environmental Management System)

Representation of TOSHIBA batteries throughout Europe.

InstallationinCreteofthefirstinterconnected photovoltaic station in Greece, with installed power of 168 KWp

2008

New production line for lead oxide

Aiming to produce 1,000,000 industrial-type batteries, by expanding the equipment (2 automated COS assembly lines, along with Inbatec machinery).

Installation of specialized systems in the manufacturing plant’s production areas, allowing in natural light that results in electricity savings.

2002

New closed-type lead industrial batteries (VRLA) production line

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2000

Commencement of vertical production of submarine and PzS/PzV industrial type batteries


2011

Foundation of ALSE (Advanced Lithium Systems Europe) company through a joint venture with the German ATLAS ELEKTRONIK GmbH

Continuation of investments in the production plant in Xanthi

2010

Completed the expansion of the factory and the supply chain and transportation management centre in Xanthi.

2013

Strategicredefinition of operations and focus on batteries

€ 96.2 mil. turnover for SYSTEMS SUNLIGHT

430SYSTEMS SUNLIGHT’s employees

2015

CertificationtoISO14001 (Environmental Management System) for SUNLIGHT RECYCLING

SYSTEMS SUNLIGHT becomes a member of TRACE International, the international organization supporting professional transparency and anti-corruption

€ 132.9 mil. turnover for SUNLIGHT Group

620SUNLIGHT Group employees

2014

Launch of SUNLIGHT RECYCLING, a state-of-the-art European lead battery recycling plant in Komotini.

Establishment in the Xanthi factory of a dust return screw system, allowing the dust’s reuse in production and installation of a system for the air transport of lead oxide, resulting to reduced air pollutants in the factory’s work environment.

€ 120 mil. turnover for SUNLIGHT Group

565SUNLIGHT Group employees

b

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2016

Environmental initiative of companies from various sectors aiming to achieve proper lead-acid battery recycling.The Green Mission is a SUNLIGHT RECYCLING’s initiative.

Application of Regulation 1221/2009 regarding the participation of SUNLIGHT RECYCLING in the European Union’s Eco-Management and Audit Scheme (EMAS)

1.56 mil. batteries – new production record

€ 153.9 mil. turnover for SUNLIGHT Group

757SUNLIGHT Group’s employees


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georgios giapoutzis Production Planning Director

Konstantinos georgiadisGroup Human Resource Director

Lampros BisalasChief Commercial Officer

Foteini voulgari

Consumer Batteries

BU Director

dimitris naoumidis Advanced Batteries

BU Directorvicky KokothakiSales Operations Director

Management Team


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spyros Kopolas

CEO SUNLIGHT

RECYCLING

stefanos KanidisChief Technical Officer

Vasili billischairman of boD & cEO

michalis mastorakis

Chief Financial Officer

christos Kartalis

Group Senior

Advisor

nikos KontosGroup

Marketing Director

tania chadouliLegal Counsel & Compliance Director

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Industrial Activity and Environmental Philosophy focused on the Circular Economy

The company’s factory in Xanthi constitutes a key factor for our dynamic growth, while being one of the most modern industrial plants in Europe, in accordance with the strictest international standards.

SYSTEMS SUNLIGHTState-of-the-art industrial battery production plant.

Total plant area142,000 square meters

Quality Management Certification

DΙΝ ΕΝ ISO 9001:2008

Environment Management Certification

DIN EN ISO 14001:2009

Occupational Health & Safety Certification

BS OHSAS 18001:2007

Vertical integration of SUNLIGHT’s production process.

With SUNLIGHT RECYCLING’s lead-acid battery recycling plant, we achieve a drastic reduction of the quantity of imported lead, by applying the principles of the circular economy. In addition, we are making a major contribution to the achievement of the nationaltargetsforleadrecyclingrates,asthosearedefinedbytheEU.

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Environment Management Certification

DΙΝ ΕΝ ISO 14001:2004

“The concept of Sustainable Development is inextricably linked with our company’s strategy that aims at a modern and effective recycling procedure, with respect to the naturalenvironment and public health. To achieve our objectives and ensure unparalleled quality for our recovered materials, we proceeded to the formation of a strategic collaboration with Engitec, the global leader in the construction of lead recycling plants. The design and productionprocessofSUNLIGHTRECYCLINGperfectlyreflectsourcompany’sVisionforsustainabledevelopmentˮ.

Spyros KopolasCEO SUNLIGHT RECYCLING

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SUNLIGHT RECYCLING The new, contemporary, lead-acid battery recycling unit in Komotini.An investment exceeding € 23 mil.

Total unit area42,000 square meters

Capable of recycling 25,000 tons

of used batteries per year

cutting-edge technology One of the most modern

lead battery recycling units in Europe

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Our business model is designed based on the principles of the circular economy, with a clear extrovert orientation:

We focus on disseminating responsible business practices to all our partners, by focusing on working conditions, anti-corruption and protecting the environment.

We safeguard our employees’ labour and human rights, focused on their health and safety, while eliminating discrimination and providing equal opportunities to all. Our goal is to maintain a modern and productive work environment.

Sustainable development Strategy, focused on Responsible Production

We preserve and strengthen the natural capital by utilizing recycled materials in our production process and by reducing our dependence from primary natural resources, while at the same time minimizing our waste and our impacts on land, water and air.

We support employment in remote regions with high unemployment rates.

We undertake actions to support our local communities as well as vulnerable groups.

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cREATiNG VAluE FOR OuR EMPlOYEES

cREATiNG VAluE FOR THE MARKET

cREATiNG VAluE FOR THE SOciETY

cREATiNG VAluE FOR THE ENViRONMENT

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Starting in 1991 with a plant of 9,900 m2, we now operate in Xanthi one of the largest factories for the production of industrial batteries in Europe, which occupies an area of 142,000 m2, and has a production capacity of more than 1.5 million batteries per year.

christos Kartalisgroup senior Advisor

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1.Human Rights

Principle #01Businesses should support and respect the protection of internationally proclaimed human rights

Principle #02 Businesses should make sure that they are not complicit in human rights abuses.

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Commitments and Policies

At SUNLIGHT Group we respect and actively support the Universal Declaration of Human Rights and we pledge to comply with the current law on the protection of human rights. According to this pledge of ours, we have implemented a series of policies, including a code of Professional Ethics, the Employee Code of Conduct, the Code of Business Conduct and an integrated Health and Safety System based on the OHSAS 18001 standard, aiming to safeguard the human rights of our employees, our clients and our suppliers. Moreover, we have implemented a special reporting mechanism for identifying and responding to any violations of our Policies.

We are training all our employees on occupational health and safety issues and we have prepared special brochures and safety manuals to better inform and prepare them. For this reason, we have sought to actively participate in Eurobat (Association of European Automotive and Industrial Battery Manufacturers), in which we are also members. Through this participation, we are committed to the continuous improvement of occupational health and safety conditions, especially regarding the maximum lead exposure levels. It this context, we are conducting systematic measurements on the exposure of our employees to lead and we take special precautionary measures.

Risk Assessment Study

Until now, we have not proceeded to the development of a risk assessment study on issues concerning human rights ingeneral,butonlyforspecificareasthereof,suchashealthand safety issues, through the relevant Occupational Risk assessments.

Goals

Our goal is to constantly abide by the commitments described in our Policy, i.e. in the Code of Ethics and in the Employee Code of Conduct and the Code of Business Conduct. In addition, for 2017, we pledge to establish more specificgoals for human resources in accordance with our Group’s activities and priorities.

Prioritizing our people

The respect and protection of human rights is of paramount importance and serves as a guiding principle for SUNLIGHT Group. Our aim is to provide a fair working environment, where our employees feel that they have equal opportu-nities to create and progress, within a constantly evolving organisation. At the same time, we commit to providing a safe and healthy work environment for all our employees, by fully aligning all of our activities with the applicable legislative and regulatory framework, while minimising accident risk and protecting our employees from exposure to a health-threatening environment.

A significant part of the effort and investment we makefor our people, concerns the constant update of their knowledge through an annual training programme. Through the continuous training of our employees on compliance with occupational health and safety issues, as well as on issues regarding human rights in general, we have managed not only to avoid any work accident, serious illness, or violations of human rights incidents during the 2014-2016 period, but we have also managed to receive praise for 3 consecutive years on our health and safety practices and for the human resources management practices that we follow.

dr. Konstantinos georgiadisgroup Human resource director

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1.1Health and Safety

Our approach

Health & Safety System based on OHSAS 18001

AtSUNLIGHTGroup,weareamongstthefirstinGreecetoapply, in 2004, an integrated Health & Safety Management System based on OHSAS 18001. This System aims to support, organize, implement and constantly improve models and practices, allowing the company’s operation to meet all the requirements of the applicable Greek and European legislation, along with the strictest quality requirements, minimising the possibilities of an accident or some other harmful incident, especially for the company employees in the Xanthi factory. At the same time, SUNLIGHT, as a member of Eurobat, has an active participation in the relevant fora and is constantly abreast of international developments.

Specifically:

> We systematically record any incidents (accidents) and near incidents at the workplace.

> We monitor the level of exposure of our employees to lead and we regularly inform the competent authorities.

> We monitor the air quality at the workplace.

Code of Professional Ethics

Through the Code of Professional Ethics, our Group pledges to provide a safe and healthy work environment for all our employees. In this context, employee adherence to health and safety rules constitutes a key factor for their assessment and reward, as well as for selecting our partners.

Every employee and every manager / executive:

> Is regularly informed about the guidelines that concern the proper execution of his / her duties, as well as the applicable legislation.

> Participates in relevant training programmes.

> Reports immediately to his / her supervisors, to the Human Resourcesdepartment,tothecomplianceofficer,ortotheGroup’s anonymous help line ([email protected]), any dangerous conditions and events that have come to his / her attention.

> Complies with the Health and Safety Rules while performing his / her daily duties.

> Actively contributes to the prevention of accidents.

All SUNLIGHT employees, along with third-party personnel, contribute to the accomplishment of these goals, since our associates are equally liable when present at our Group’s facilities.

We all strictly adhere to the Health and Safety Rules, without any deviations or compromises. We are all considered personally responsible, hence we constitute the most important success factor.

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Employee Code of Conduct

The Employee Code of Conduct has been formulated based on the requirements of the relevant labour legislation, with the purpose of maintaining smooth relations between the Group’s Management and employees. The Code includes a special chapter on health and safety, which describes the Group’s obligations and the duties of the employees, along with, among others, the methods for dealing with occupational accidents. The Code sets out the way to achieve legislation adherence, the presence of Occupational Physicians, as well as the emergency plans.

Code of Business Conduct

Employeesareobliged to fulfil theirdutiesby following theHealthandSafetyRules,asthesearespecifiedoradjustedby the Management of the Group, a practice that allows idealworking conditions to be safeguarded and the possibility of an accident or any other harmful incident to be reduced, both for the employees and for their work environment.

For the purposes of ensuring the ideal health and safety conditions at the group’s production areas, the directors of the production, Human resources and technical management departments, along with the safety Technician and the occupational physicians:

> Ensure the application of an integrated Occupational Health and Safety Management System, while focusing on the working environment conditions and protection of the employees working in production.

> Investigate all incidents and near accidents, so that, based on the conclusions, to suggest to Management the application of measures for the assessment and improvement of the Health and Safety Management System.

> Apply programmes for the preventive maintenance and inspection of equipment.

> Jointly prepare contingency plans for the production areas and work together with the authorities for the preparation of the external contingency plans.

> They tend to the conduction of readiness drills for the personnel, in cooperation with the competent authorities.

> Conduct internal inspections to establish the adherence to the Health and Safety Management System.

> Organize training programmes and take steps for the active participation of all personnel.

Safety Instructions Booklet for Visitors

For the protection of our visitors at our factories’ facilities, both for SYSTEMS SUNLIGHT and for SUNLIGHT RECYCLING, we have issued a special booklet, which includes the following:

> Instructions for company protection.

> Instructions for visitor safety.

> Instructions in case of risk.

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Communication and Training

In 2015, we conducted a training seminar for all employees regarding the Code of Business Conduct, with special emphasis on health and safety issues.

The following table includes information on the training sessions on health and safety issues provided by SYSTEMS SUNLIGHT in the past three years. It should be noted that, in 2016, the total number of training hours on health and safety issues were increased by 71% in comparison to the training hours of 2014.

2014 2015 2016

Health and Safety issues 18 8 10

Total number of training hours 268,5 333 460

2015 2016

Health and Safety issues 3 13

Total number of training hours 40,5 1.019

Employee Health and Safety Committee (EHSC)

The EHSC is a consulting body, comprising of a Management representative, the Safety Technician, the occupational physician and six elected employee representatives. This Committee represents the employees and is responsible for scheduling regular meetings with management. Its purpose is to communicate and negotiate issues of concern for our employees.

The Committee:

> Assess working conditions, suggests measures for their improvement, as well as the improvement of the work environment, monitors adherence to the health and safety measures and contributes to their implementation by the employees.

> In cases of serious work accidents or relevant incidents, suggests the necessary measures to avert reoccurrence.

> Highlights occupational risk at relevant areas or work posts and suggests treatment measures, thus participating in the formulation of the Policy for the prevention of occupational risk.

> Gets updated by Management about the details of occupational accidents and occupational illnesses that take place.

> Stays informed about the introduction of new production procedures, machinery, tools and materials, or for the operation of new facilities at the factory, to the extend they affectoccupationalhealthandsafetyconditions.

> In the event of direct and serious risk, requests from the employer to take the necessary measures, without excluding the possibility of interrupting the operation of a machine or of a facility or production.

> May request the assistance of experts on occupational health and safety issues, always upon consent by the company.

The respective table for SUNLIGHT RECYLCING is as follows:

GRI 403-1

2014 2016

268,5 460

Total number of training hours(SYSTEMS SUNLIGHT)increase of total number

of training hours provided to employees in 2016,

compared to 2014


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In addition to the Code of Ethics, the Code of Business Conduct and the Employee Code of Conduct that apply to the entire Group, sunLigHt rEcYcLing’s policy on employee Health and Safety includes the following:

> Training sessions and informing the personnel on health and safety issues related to lead exposure and on the use of personal protection measures. To better inform employees, a special booklet has been created, titled «Working with lead».

> Application of hygiene measures, such as cleaning of work attire in special facilities as well as cleaning at close of business.

> Maintaining updated data sheets on the chemical substances used.

In addition, for the effectivemanagement of contingencies(e.g.caseoffire,earthquake,etc.),SUNLIGHTRECYCLINGhas developed special action plans in collaboration with the Safety Technician. To this end, possible contingencies are assessed and spotted, the respective action plans are developed, and finally employee training sessions areorganized.

Action plans are available for each of the following contingencies:

> Treatment of leaks.

>Firefighting.

>Settingupafiresafetyteam.

> Dealing with an earthquake.

> Factory evacuation.

> Injuries / First Aid.

Every contingency plan includes a description of the possible risks, the necessary prevention measures and control measures for avoiding them, along with actions that must be taken if any such incidence actually occurs.


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Indicators

results of biological tests over a three-year period for the employees of sYstEms sunLigHt

Our performance

Distinctions

SYSTEMS SUNLIGHT has been awarded with the Silver Award at the 2014 Health and Safety for its commitment to provide a safe work environment that safeguards its employees’ health.

Internal & External Audits

Inspection of performance on health and safety issues, and generally on issues concerning human rights, is not performed separately but falls under the Group’s Internal Audit, which began in 2016. At the same time, audits are performed at our facilities by both our clients and the competent authorities.

Compliance with laws or regulations

Duringthereportingperiod(2014-2016)therewerenofinesnorsanctions related to employee health and safety.

measurement results to ensure ambient air’s safe values at the workplace of sYstEms sunLigHt

Σύνολο Εκπαιδεύσεων 2014 2015 2016

Number of measurements 21 30 30

Higher value of lead observed (μg/m3)

71 65 67


Total number of employees who underwent medical exams

376 400 506

Total number of employees exceeding the maximum blood lead levels

0 0 0

*According to the relevant legislation concerning the protection of employees exposed to mineral lead (PbB), the Limit Value of the biological indicator is70μg/dl. Noemploymentmeasurement reached theLimitValue.

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Our approach Our performance

1.2Adherence to working hours and provision of annual leaves beyond the legislative framework

The establishment of the Employee Code of Conduct ensures compliance to the applicable legislation regarding the working hours, the annual leaves and the compensation of our Group companies’ employees. Moreover, the Code provides for a mechanism for the submission of complaints on labour issues.

Regarding official holidays, the Christian holidays apply.However, there is a significant number ofMuslim colleagueswhose religious holidays are not covered by the Greek Labour Law. Concerning Muslim holidays, the dates are variable. For this reason, at the beginning of each year, we consult with the MuftiofficeinXanthi,concerningthedatesoftheirtwoofficialholidays; based on this communication, we amend the work and production schedule to provide the respective leaves to our Muslim colleagues. This holiday lasts for two days and covers theofficialfirstandsecondday.

Specifically,forRamazanSekerBayrami,thefastingofMuslimcolleagues always commences one month prior to the holiday and their fasting requires avoiding the consumption of food, drinks,orwater. To thisend, theGroup isdiscreetly flexibletowards colleagues who are fasting, in order for them to have the option for more breaks, especially towards colleagues who are strictly fasting and do not consume water or food during the day.Onanycase,werequesttheflexibilityfromtherestofthecolleagues in writing, regarding such a delicate issue, as well as theflexibilityfromforemenonissuesofheat,breaks,pressure,etc. In this context, every year we prepare a plan on thermal fatigue.

GRI 419-1


Duringthereportingperiod(2014-2016)therewerenofinesnorsanctions related to cases of illegal work, overwork and other labour issues in general.

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1.3 Fair treatment and equal opportunities

Our approach

Code of Business Conduct and Grievance Mechanisms

Our Code of Business Conduct and Behaviour establishes Integrity as a key value for our everyday behaviour, while highlighting Management’s commitment towards this direction. The Code is based on the respect to laws and regulations, our client-oriented approach, the careful selection of partners based on our Principles, the preservation of our corporate property, the respect to the individual and the active care for the environment and the society.

Our Group has adopted and applies suitable procedures in order to identify any training needs, give incentives to our employeesandachievemaximumemployeeefficiency,withina non-exclusive professional environment. Each and every one of us is expected to showcase integrity in our interactions with other employees and external bodies, to report any concerns regarding equal opportunities and to demonstrate zero tolerance to any form of discrimination.

Should any employee becomes aware of any discriminatory activity in our Group, or if they feel that themselves or anyone else is a victim of racial, religious, sexual, or other harassment, they are requested to report this to the Human Resources Department ([email protected]) or to the Compliance Officer. All cases are treated in a confidential manner, withobjectivityandhighsensitivitytowardstheaffectedpersonsandall other parties involved.


Within the context of the two-day training session on Compliance issues, which was held at the end of 2014 for all senior Group executives, special reference was made to human rights. At the same time, all new employees receive special briefings on human rights as part of their trainingwhen joining the Group.

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Indicators*SYSTEMS SUNLIGHT

Our performance

Awards

SYSTEMS SUNLIGHT has received the following awards:

2014Bronze Award in the HR Excellence Awards, in the Human Resources Management section, for the recent successful enrolment, integration and inclusion of 50 new colleagues in our factory.

2015Award in the “Talent Selection & Retention” category, within the context of the “Human Resources Awards» held by KPMG.

2016Award to SUNLIGHT in the HR Awards. Category: Best Change Management Strategy - Initiative.


Inspection of performance on discrimination issues, and generally on issues concerning human rights, is not performed separately, but falls under our Group’s Internal Audit, which begun in 2016. Our Group does not conduct an External Audit on Human Rights issues.

GRI 419-1


During the reporting period (2014-2016), there has been no incident of legislation violation regarding discrimination and equalopportunitiesissues,noranyrelevantfineswereimposed.

SYSTEMSSYNLIGHT

% of governance

bodies

%of other

employees

gender

Men 67 88

Women 33 12

Age

< 30 - 11

30-50 73 75

> 50 27 14

other diversity indicators

Religious minorities

- 12

*thefiguresreferto2016

% of women

in managerial positions

2014 9 1 11%

2015 8 2 20%

2016 8 4 33%

GRI 405-1

increase in the percentage of women in managerial positions (Athens)

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TheSUNLIGHTTeamhassignificantly increased in the past years, always managing to meet high quality and reliability standards for its products in an international and very competitive environment.

stefanos KanidisChief Technical Officer

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2.Labour conditions

Principle #03 Businesses should uphold the freedom of association and the effectiverecognitionoftherightto collective bargaining

Principle #04the elimination of all forms of forced and compulsory labour;

Principle #05theeffectiveabolitionofchildlabour; and

Principle #06the elimination of discrimination in respect of employment and occupation.

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Our employees’ rights and obligations derive from labour legislation, from the Group’s Code of Business Conduct and from the personal labour agreements they sign.

Our Group companies strictly adhere to the Code of Professional Ethics that stipulates that decisions on employment (from start to termination) shall be solely based on work-related factors, such as qualifications,achievements,effectiveness,andperformance.

Moreover, to achieve the best possible work environment, the Code of Business Conduct ensures the proper utilization of personnel with emphasis on training and personal progress, while also describing the rules of conduct between employees and analysing the policies on Remuneration and Benefits.

Aiming to the best possible application of our policies, we arrange training sessions that include topics related to human rights, such as discrimination and ways to address it, while at the same time we have established a special grievance mechanism for Policy violation incidents. In addition, we have set up a special Health & Safety Committee, which represents all of our employees, aiming to allow the timely discussion of any issue of concern with senior management.

Fair employee treatment

One of our Group’s primary objectives is to ensure ideal working conditions; this is achieved through the fair treatment of employees and the protection of the freedom of association. To this end, we take steps every day to foster a healthy environment that is based on honest dialogue and mutual respect.

We appreciate diversity, while we discourage and reject all kinds of discrimination. Our decisions on employment are based solely on business reasons and criteria, such as qualifications, talent, achievement, effectiveness andperformance, while they are always taken according to the local and international labour laws. This allows us to build a fair work environment, attract and retain the most specialised employees and remain true to our Principles. Our Group has adopted and applies appropriate procedures to detect any training needs, while providing incentives to our employees toachievemaximumefficiency,aswellasopportunities fordevelopment.

dr. Konstantinos georgiadisgroup Human resource director

34


2.2Elimination of forced or compulsory labour

Our approachOur Group commits to comply with legislation and eliminate all forms of forced or compulsory labour. To this end, the Code of Ethics places emphasis on respecting the law and the integrity of each individual person. In addition, our Employee Code of Conduct protects employment relations and makes sure that labour laws prevail.

Our performanceDuring the reporting period, no cases of forced or compulsory labour concerning the Group’s activities, have taken place.

2.3Abolition of child labour

Our approachOur Group, through its Code of Professional Ethics, expressly prohibits child labour and complies with the respective legislation. As a result of our approach, the Group companies do not employee persons under the statutory age limit. We aim to see this commitment of ours, getting also adopted by our direct and indirect partners.

Our performanceDuring the reporting period and for the duration of our Group’s operation, there have not been any cases of child labour concerning the Groups’ activities.

2.1Freedom of association and collective bargaining

Our approachThe Group is committed to recognize employees’ rights to freedom of association and collective bargaining. In this context, all employees have the right to elect and be elected in the Health & Safety Committee, which they can contact in order to discuss any matter of concern. This Committee represents the employees and is responsible for arranging regular meetings with the Group’s senior management, with the purpose of communicating and negotiating any issues of concern for our employees.

Our performance

GRI 419-1

During the reporting period (2014-2016), no fines wereimposed and there was no litigation concerning collective bargaining and freedom of association issues.

35



Employees in religious minorities - Foremen

- 1 2

Employees from religious minorities hired

36 43 46

Our performanceIndicators

The following have been observed during the reporting period (2014 – 2016):

> Sharp increase of new employee hires belonging to religious minorities (Komotini, Xanthi).

> Increase progression rates to administrative positions for colleagues belonging to religious minorities (Komotini, Xanthi).

> Small percentage of women in the factories. This is due to the increased protection of women from exposure to a lead environment, since this could cause problems to pregnant women.

GRI 406-1

Discrimination incidents

During the reporting period (2014-2016) no discrimination incident was recorded in our Group.

2.4Νon-discrimination in employment

Our approachWe discourage and reject any kind of discrimination based on origin, nationality, the colour of the skin, religion, age, gender, family status, health, sexual preferences, or any beliefs.

We are all required to show integrity in our interactions with other employees and external bodies, to report on any concerns and demonstrate zero tolerance to any kind of abusive discrimination.

In addition, in the interviews held with prospect employees, we apply policies against discrimination. Even though these policies are not recorded, all responsible for the recruitment procedures follow strict orders by Management and impartially decide about who is more suitable to work for our Group.

Should we become aware of any discriminatory activity in our Group, we must report this to the Human Resources Department ([email protected]) or to the Compliance Officer.

Communication and Training Sessions

Within the context of the two-day training session on Compliance, held at the end of 2014, for all senior executives of our company, special mention was made to the importance of communication between employees regarding discrimination issues and on the methods for addressing them.

36


Principle #07 Businesses should support a precautionary approach to environmental challenges;

Principle #08Businesses should undertake initiatives to promote greater environmental responsibility; and

Principle #09Businesses should encourage thedevelopmentanddiffusionof environmentally friendly technologies.

3.Environment


36

37



SYSTEMS SUNLIGHT operates in an ecodevelopment area of the National Park of East Macedonia and Thrace, which includes the wetlands of the Nestos delta, of the Vistonida and Ismarida lakes and their wider area, strictly adhering to theenvironmentaloperation limits,as thesearedefinedbythe Greek legislation, in accordance with the provisions of the Ramsar Convention on wetlands and the Natura 2000 Network. In this context, we closely follow and comply with all new such decisions for the entire scope of our activities. In addition, the competent departments are regularly informed and comply with new trends, as they are described by the environmental legislation, with the purpose of ensuring that we are always capable of complying with new requirements.

Moreover, SUNLIGHT Group closely adheres to the Code of Business Conduct, according to which environmental protection and the preservation of natural resources are a top priority for us and an integral part of our activities. Through the continuous guidance and our employees’ commitment, we seek to perform our activities in a manner that is safe for the environment and we strive to constantly improve our environmental performance.

Respectively, with the purpose of protecting the environment in the context of our activities, at SUNLIGHT RECYCLING we have developed and apply an Environmental Management System in accordance with the requirements of the ISO 14001:2004 standard and of Regulation 1221/2009 on the voluntary participation of organisations in the European Eco-Management and Audit Scheme (EMAS). More relevant information is available in section 3.2.

Business activity with environmental orientation

At SUNLIGHT Group we are characterized by a sense of responsibility towards the environment, since it constitutes an integral part of our activities. The principle of Sustainable Development constitutes a key choice and objective, while the circular economy is at the epicentre of our business vision and operation. Our goal and purpose is to achieve growth that will satisfy current needs, without compromising the needs of future generations.

In 2015, we established SUNLIGHT RECYCLING, in the Industrial Area of Komotini, through the practical application of a circular economy business model, which constitutes the firstcomprehensiveapproachforrecyclingleadbatteriesinGreece. The technology used by this newly-established unit iscertifiedbyENGITECandisconsideredthemostmodernand environmentally-friendly technology at a European level. SUNLIGHT RECYCLING constitutes SYSTEMS SUNLIGHT’s business evolution and concerns an investment exceeding € 23 mil. The lead produced is then used by SYSTEMS SUNLIGHT for the production of new batteries in Greece.

By closely adhering to strict environmental limits for our Group’s operation, which are defined by environmentallegislation, as well as through the continuous training of our employees on environmental issues, we have achieved our full compliance with environmental rules, by internally setting stricter rules than those legally required.

Finally, we are proud for the launch of the Green Mission environmental initiative, aiming to inform and raise awareness among the public and businesses about the benefits ofadhering to proper lead battery recycling procedures and about our awards and distinctions for our environmental and management practices.

spyros KopolascEo sunLigHt rEcYcLing

GRI 102-10

38


Environmental Impact Assessment

In the context of applying the International Environmental Management Standard ISO 14001:2009, SUNLIGHT Group has also performed a relevant Environmental Impact Assessment.

The starting point for SUNLIGHT RECYCLING, which also participates in the European Eco-Management and Audit Scheme (EMAS) for the planning and application of the EnvironmentalManagementSystem,istheidentificationofallenvironmental aspects related to its activities. For each of the environmental aspects recognized per activity, the respective possibleimpactontheenvironmentisalsoidentified.

Theidentificationandanalysisoftheenvironmentalaspectswere performed by taking into consideration all operational conditions, regular or not, emergencies, as well as the status of other activities. In addition, the indirect environmental aspectsthroughwhichthecompany’soperationcouldaffecttheenvironmentwere identifiedanddefined.The followingenvironmental aspects were deemed as material by taking intoaccountthemeasurestakenandstillineffect:

> Air pollution, which could be caused by the emission of particulate matter.

> Atmospheric pollution, which could be caused by air emissionsfollowingafire.

> Uncontrolled disposal and possibility of a hazardous substances spill to the environment from raw material or liquid product waste, during storage.

> Soil and subsoil pollution, which could be caused by the disposal of hazardous waste.

> Soil and subsoil pollution, which could be caused in case of an emergency.

As Sunlight Recycling aims to continuous improvement of its environmental performance, it sets goals and objectives based on the environmental aspects of primary and secondary importance.

Objectives

The environmental objectives of SUNLIGHT RECYLCING are the following:

5% reduction of water consumption for the next year

10% reduction of electricity consumption per ton of produced Pb for the next year

5%reduction of natural gas consumption for the next year

4%reduction of CO2 emissions from energy consumption for the next year.

5% Increase of the solid waste recycling rate for the next year and subsequent reduction of solid waste sent for disposal.

Installation and operation of a technology for the

continuous measurement of particulate matter emissions in the chimney, with the purpose of taking complete measurements in real time.

39


3.1Investments in the circular economy

Our approachOur Group is applying in practice the circular economy model, since we believe that this is the only option for sustainable business development. SUNLIGHT Group acknowledges the significant opportunities that the circular economyoffers to businesses, both in terms of economic growthand competitive advantages and in terms of environmental protection.

According to this model and with the goal of conserving natural resources on one hand and making use of used lead batteries on the other, SUNLIGHT RECYCLING recycles used lead batteries and provides SYSTEMS SUNLIGHT recycled lead for the production of new batteries. Moreover, SUNLIGHT RECYCLING markets in Greece and abroad additional products resulting from the battery recycling procedure, such as sodium sulphate and polypropylene.

Lead batteries recycling procedure

Recyclingleadismoreenergyefficientthan mining and processing it, allowing for energy savings of

70%

State-of-the-art Recycling Unit SuNliGHT

REcYcliNG

iNNOVATiVE REcYcliNG PROcEDuRE

WiTH TWO DESulFuRiZATiON

STAGES

New battery Used battery

lEADfrom lead paste, grids and battery

poles

Sold to businesses in Greece and abroad

Production of new SuNliGHT batteries and exports all over

the world

POlYPROPYlENE from the plastic parts

of the battery

SODiuM NiTRATE ΝA2 SΟ4

from the neutralisation of the electrolyte

Collection, transportation,

storage


40

Environmentally-friendly technology

SYSTEMS SUNLIGHT’s production process is in accordance with the European Union’s relevant Best Available Techniques (BREF), ensuring both the lowest possible consumption of natural resources and raw materials and the limited generation of waste.

SUNLIGHT RECYCLING is also following the Best Available Techniques (BREF), which contribute to the conservation of natural resources and auxiliary materials (chemical reagents), while also reducing the production of solid waste and emissions.Specifically,thankstothetechnologyusedbythecompany, we are able to achieve the following:

> high rates of recycling for raw materials – batteries;

> electrolyte collection before and during the breaking of batteries;

> clear separation of all streams resulted from the breaking of batteries (polypropylene, heavy plastics, paste, grids);

> production of high purity sodium sulphate > 99.5%

> Two stages of lead paste desulfurization, which contributes to: - higher rate of lead recovery - reduced amount of produced slag

> closed loop effluentmanagement by the recirculation ofwater within the unit

> low emissions, in compliance with the limit values set by European Legislation.

GREEN MISSIONEnvironmental Initiative

In 2016, the Management of SUNLIGHT RECYCLING presented the Green Mission environmental initiative, which aims to raise awareness among the public and the business community regarding the proper recycling of lead-acid batteries. Green Mission has brought together various institutional bodies and is implemented with the support of companies active in the Greek and international markets.

It should be noted that the problem in Greece, which Green Mission is helping to mitigate, is rather serious, since only 51% of the used lead batteries are collected and recycled, while the respective rate in Europe reaches 95%. At the same time, a large percentage of used batteries is sent for illegalrecycling,whichhassignificantnegativeimpactsbothto the Greek economy and to our country’s environment.

www.greenmission.gr

THE

GREENRECYCLE RIGHT

http://www.greenmission.gr

41


The Green Mission’s objectives, which is a SUNLIGHT RECYLCING’s initiative, include:

> contribution to the improvement of the country’s performance concerning the indicators for the collection of used lead-acid batteries;

> provide information and raise awareness among the public andbusinessesregardingthebenefitsofcompliancewiththe proper recycling process of lead-acid batteries.

The programme’s actions have already begun and are the following: For the first two-yearperiodof 2016-2017,the Green Mission initiative aims to inform and raise awareness among 14,000 Greek businesses producing and/or managing significant quantities of industrial waste.Already, more than 40 major businesses from various sectors participate in the Green Mission.

In this context, the www.greenmission.gr website was created, mainly aiming to serve as a reliable source of informationfortheproblemsthatconcernthefieldof lead-acid batteries recycling. Private parties and companies have the opportunity of receiving advice regarding the proper recycling of lead-acid batteries, obtaining information on the legislation, etc.


www.greenmission.gr

41

Proper recycling of lead-acid batteries.

Ελαχιστοποίηση αέριων ρύπων

Minimisation of liquid waste Minimisation of air emissions

Neutralisation of electrolyte

Recycling 1 ton of batteries reduces cO2 emissions by 1,625 kg, which is the annual cO2 absorption by 74 trees.

Recycling batteries offers energy

savings of up to 70%.

95% of the materials used in an acid-lead battery could be used to create new products.

75% reduction of the hazardous waste and proper management of the remaining materials.

Electrolyte Neutralization

Emissions Minimization

SAlT

www.greenmission.gr

http://www.greenmission.gr

42


82%ThetotalefficiencyofSUNLIGHTRECYCLING’s recycling procedure

95%thetotalefficiencyof used batteries recycling

>58%the percentage of SYSTEMS SUNLIGHT’s needs that are met with recycled lead by SUNLIGHT RECYCLING

Our performance

Distinctions

Environmental Awards 2015 & 2016

SuNliGHT REcYcliNG received the Golden Award in the Environmental Awards for 2015 and 2016 in the Waste Management – Recycling & Waste Reuse category.

The award was received by the company’s Managing Director, Mr. S. Kopolas, who stated: “SUNLIGHT RECYCLING is now the most modern lead battery recycling unit in Europe. The cutting-edge technologies used ensure the environmentally proper recycling and puts into practice the model of the circular economy in our country. Environmentally proper recycling is not just a wish list. It is a necessity for the protection of the environment, public health and the economy. At SUNLIGHT RECYCLING, we believe that this is a matter of concern for all of us. With the purpose of raising awareness among the public and businesses, a few months ago we launched the Green Mission awareness campaign. Currently, more than 40 major companies are already participating, while their number is constantly increasing. We are inviting everyone to become a member”.

bravo AwardsWanting to place emphasis on the responsible business practices applied by SUNLIGHT RECYCLING, we participated in the “Bravo Sustainability Awards 2020”. We participated through the presentation and recording of our actions that promote Sustainable Development & Responsible Business Practices inside the company as well as the general operation in the wider environment.

This mechanism covers the recent need expressed by European Institutions regarding the creation of tools to monitor good practices towards Sustainable Development at member state level, along with the need of establishing a systematic national monitoring mechanism for Sustainability and social Responsibility.

43


2015 2016

Total training sessions 4 4

Total training manhours 44 22,5

The following table includes the total number of sessions and total number of training manhours on environmental issues for SUNLIGHT RECYCLING:

3.2Precautionary approach to environmental challenges

Our approachOur objective and purpose is to achieve development that will meet current needs, without compromising the needs of future generations.

In this context, at SUNLIGHT RECYCLING we also implement an Environmental Management System in accordance with the requirements of the ISO 14001:2004 standard and the Regulation 1221/2009 concerning the participation of organisations in the European Eco-Management and Audit Scheme (EMAS), aiming at the protection of the environment within the context of our activities.

We recognize our responsibilities and obligations towards the environment and we pledge to the following:

> continuous monitoring and compliance with environmental legislation;

> systematic identification, assessment and control of theenvironmental impacts resulting from our activities;

> continuous improvement of our environmental performance and the reduction of environmental impacts;

> informing and encouraging our personnel for their active participation in the improvement of the work environment and in environmental protection actions that fall within the scope of our activities.

Specifically,in2015,weconductedaneducationalseminarfor all employees on the Code of Business Conduct, placing special emphasis on environmental issues, such as:

> Limiting the use of energy and raw materials.

> Limiting environmental emissions.

> Use and production of recycled and recyclable materials.

At the same time, all new employees must attend special training on environmental issues that relate to the Group.

Our performance


Inspection of our performance on environmental issues, since they are of paramount importance to us, falls under the company’s Internal Audit, which began in 2016.

At SUNLIGHT RECYCLING, the annual Internal Inspections programme covers the various audit requirements for the application of the respective management systems:

> Environmental Management System (ISO 14001:2004 standard)

> EMAS regulation.

Inspections are conducted on a monthly basis by associates from the company’s headquarters, as well as from properly trained individuals, in collaboration with the factory manager. In addition, external audits are performed every four months by a collaborating consulting company.


During the reporting period (2014-2016), there have been no fines or litigation related to environmentalmanagementissues.

GRI 102-11

GRI 307-1

44


Non-Hazardous Solid WasteThe non-hazardous waste resulting from our activities are:

> Paper packaging materials for products and raw materials (e.g. crates, dividers).

> Wood waste, mainly packaging materials (e.g. palettes, chipboards, crates, frames).

> Plastic waste, mainly packaging materials (e.g. palettes, bags,wrappingfilm).

> Pieces of lead resulting mainly from cutting and/or processing (e.g. defective lead plates, lead pieces / scrap resulting from the formation, pressing – cutting process).

> Non-ferrous metals resulting mainly from the cutting and processing of raw materials (e.g. residues and chips of zinc, silver and other electrodes, waste from the cutting of anode electrodes).

> Ferrous metals mainly resulting from the processing and cutting operations in maintenance and infrastructure works (e.g. iron residues, iron chips, useless iron electrodes, miscellaneous).

> Defective batteries (e.g. alkaline and other batteries).

> Sludge from the liquid waste treatment system for lead batteries (gypsum)

> Municipal solid waste, mainly from auxiliary areas and production areas that do not contain hazardous substances (e.g.offices,changingrooms,bathrooms,etc.)

Hazardous Solid WasteThe hazardous waste resulting from our activities are:

> Particulate matter-dust and lead particles deriving from the antipollution systems located in the lead battery production area, residues from lead oxide pastes, sludge from the wells located in the lead battery production areas, residues of lead oxide dust.

> Plates and filters containing Pb and defective cells/batteries (Pb, Ni/Cd).

> Battery electrolytes (Pb, Ag/Zn, Ni/Cd).

> Lubricant oils from the operation of the mechanical equipment.

> Polluted packaging materials.

> Absorbing materials, filter materials, wiping cloth andprotecting clothes.

> Sludge from the wastewater processing system of the silver-zinc batteries.

All of the unit’s waste (hazardous or not) are managed by authorized waste management companies or are treated within the facilities (Pb/acid electrolytes and Ag/Zn).

3.3 Solid waste

SYSTEMS SUNLIGHT

Our approach

45


SYSTEMS SUNLIGHT

Our performance

Recycled / total % Non-recycled / total %

100%90%80%70%60%50%40%30%20%10%0%

2014 2015 2016

14,3%

85,7%

14,9%

85,1%

15,7%

84,3%

Percentage of recycled and non-recycled waste per year*

2014 2015 2016

Quantities of recycled solid waste per year*(t)

PLA

STIC 23,1

27,140,2

WO

OD 131,1

136,9160,3

PAPE

R 119,482,5

50,2

*The deviations observed are due tothedifferentsalesmixforeachyear.

* the increase in the quantity of paper recycled is attributed to better sorting, increased volume of sales and mix, while the reduction in wood and plastic is due to the minimization of waste materials.

46


2014 2015 2016

Quantities of recycled solid waste per year*(t)

GY

PSU

M

SLU

DG

E 745,3100,0

50,0

CO

PPER 15,0

25,12,2

IRO

N

52,018,4

63,5

2014 2015 2016

Percentage of recycled solid Pb waste per year (t)

Pb B

ATT

ERIE

S

1.204,7783,5

656,0

SCR

AP

Pb 1.162,8899,6

270,5

Pb S

LUD

GE

528,1404,3

520,7

* The increase observed in gypsum sludge and iron is due to the production mix and to the increased production volumes, while the reduction of copper is due to the reduction of waste materials.

47


SUNLIGHT RECYCLING

Our approach

Solid waste resulting from the unit’s production activities and the management method thereof are analysed below.

Non-Hazardous Solid WasteThe non-hazardous waste produced is:

> packaging materials for raw materials (e.g. palettes, plastic bags,wrappingfilm,paperbags,andcartoncrates);

> plastics that do not contain hazardous substances (polypropylene, etc.) resulting from the breaking of the batteries and the sorting of the lead waste;

> ferrous metals resulting from the breaking of the batteries, which are collected by using a magnetic belt;

> municipal solid waste from the offices (printing paper,packaging materials, boarding waste, etc.).

All non-hazardous waste is managed by authorized waste recycling companies.

Hazardous Solid WasteThe hazardous waste produced is:

> plastics containing hazardous substances resulting from the breaking of batteries;

> metal slags resulting from the rotary kiln;

> raw material packaging waste that contain hazardous substances;

> used lubricants and plastic lubricant containers resulting from the maintenance of the vehicle and forklift maintenance.

All hazardous waste is provisionally stored per type in separate special bins, which are managed by specialized authorized companies. The maintenance of the vehicles and forklifts is performed by external, authorized crews.

48


The following table lists collectively all quantitative data regarding the unit’s solid waste that have been managed (recycling by authorized companies). The same table presents the indicator of produced waste per ton of product.

Quantities of solid waste and waste indicator per product quantity

*EWC code: Code based on the European Waste Code

indicators Quantity 2014 (t) Quantity 2015 (t) Quantity 2016 (t)

Solid waste / Pb product and Na2SO4 (t/t)

0,15 0,099 0,036

Solid waste / Pb product (t/t) - 0,113 0,039

Waste EWc code* Quantity 2014 (t) Quantity 2015 (t) Quantity 2016 (t) Management

Slag from primary and secondary production

10 04 01* - 266,4 -

Recycling / Disposal

Plastic packaging 15 01 02 1 11,1 26

Wooden packaging 15 01 03 - 15,8 49,4

Packaging containing residues of hazardous substances or polluted by them

15 01 10* - 0,6 2,2

Iron and copper 17 04 05 - 0,6 -

Ferrous metals 19 12 02 - 5,0 76,9

Plastics and rubber 19 12 04 - 420,4 397,6

Plastics containing hazardous substances

19 12 11* - 0 31,8

Mixed urban waste 20 03 01* 10,2 40,5 17,8

SUNLIGHT RECYCLING

Our performance

49


3.4 Air emissions

SYSTEMS SUNLIGHT

Our approach

The main air emissions generated during the production process include:

> Particulate matter – dust and lead particles from the production areas of the lead-acid batteries

The particulate matter - dust and lead particles result from the processes of melting and casting lead in pots operating with a propane burner, from the production of lead oxide and minium, from charging positive plates, from the application of paste to negative plates, from the assembly / welding of grids, and from the drying of plates.

To reduce the particulate matter emissions – dust and lead particles, air ducts have been installed in all casting and melting kilns, as well as at any areas where it is possible to have dust emissions. The air ducts have been placed either above the workpostsorabovefixedmachineryandleadtoself-cleanedbag filters, which are equippedwith high-density filter bags.The lead particles are collected from the lower part of the filters,placed inclosedcanisters,andare recycled,while theconcentration of suspended particles – dust and lead particles is regularly measured.

> Air emissions from the torpedo batteries (silver-zinc) production sites.

The operation of the torpedo batteries production unit may generate very low emissions of dust particles when cutting, assembling, and welding the Ag-Zn batteries.

Air ducts have been placed over these areas, which lead to two systems of self-cleaning filter bags that have beeninstalled outside with the purpose of retaining dust.

> Air emissions from the electrochemical formulation of plates and the electrochemical formulation and charging of battery elements / batteries when charging the electrodes.

During the electrochemical formulation of the plates and the electrochemical formulation and charging of the batteries, sulphuric acid vapours may be emitted in the workplace.

Aiming to ensure air quality and the health and safety of employees during these stages, there are air vents in these areas, which lead to KUSTAN and INBATEC type water scrubbers.

In the scrubbers, the exhaust gases contact water through reverseflow,aimingtodetainanyacidvapours.

> Exhaust gases from the operation of the propane burners

The unit is not equipped with boilers or steam boilers in the production process, but with propane burners, which areused forproduction.Specifically, theseareused in thelead melting pots to produce lead oxide, minium from lead oxide, industrial-grade grids and submarine-grade grids, submarine-grade poles and paste. The exhaust gases are measured in the furnace burners, which are equipped with a separate exhaust vent. The measurements include the measurement of oxygen, of the exhaust gases’ temperature and of the soot indicator as per Backarach.

> Volatile Organic compounds (VOc) during the production of the canisters for the submarine batteries

Resins are used when producing the submarine battery canisters. During this procedure, the VOC emissions are low and mainly take place when producing the resin mix and less duringthesolidificationofthecanisters.Anairventhasbeeninstalled in the mixing area and in the and residue areas to remove any VOC to the outside air.

This activity does not fall in the provisions of Joint Ministerial Decision 36060/1155/E.103/2013 (Government Gazette 1450/Β)regardingtheuseofsolventsandtheemissionsofvolatile organic compounds. To this end, it is not required to perform measurements or take additional measures.

50


SYSTEMS SUNLIGHT

Our performance

The particulate matter and inorganic lead emissions are systematically measured at specific points inside the factory. In everymeasurementtaken,theparticulatematterandthePbparticleemissionswerefoundtobesignificantlylowerthantheallowedlimitof100mg/m3 and 10mg/Nm3 respectively, as shown in the following charts.

concentration of particulate matter emissions

70

80

90

100

60

50

40

30

20

10

0F1 F2 F3 F4 F5 F6 F7 F8 F9 F10 F11 F12 F13 F14 F15 F16 F17 F19 F20 F21 F28 F29

RedLead

RedLead

LeadOxide

LeadOxide

PARTiculATE MATTER

mg/

m3

Extractions

2014 2015 2016

Maximum limit 100 (mg/m3)

51


concentration of suspended Pb particles

7

8

9

10

6

5

4

3

2

1

0F1 F2 F3 F4 F5 F6 F7 F8 F9 F10 F11 F12 F13 F14 F15 F16 F17 F19 F20 F21 F28 F29

iNORGANic Pb

mg/

Nm

3

Extractions

2014 2015 2016

RedLead

RedLead

LeadOxide

LeadOxide

Maximum limit 10 (mg/Nm3)

52


SUNLIGHT RECYCLING

Our approachThe most significant air emissions generated during the production process include:

> Sulfuric acid and sulphur dioxide vapours

The sulfuric acid and sulphur dioxide vapours generated during the batteries production process.

To minimise vapours in the internal air, a ventilation system, with suitable air ducts, has been installed, both in the storage room area and in the battery processing area. The unit equipment (breaker, centrifugal separator, desulphurization reactors,filterpresses,sodiumsulphateprocessingreactors,etc.) is connected to the air extraction system. The extraction systemleadstheairtoascrubberfilledwithmaterial,usedto retain all acid vapours and particles and minimise the emission of gaseous pollutants to the atmosphere.

> Particulate matter – dust, lead particles

Particulate matter - dust and lead particles are generated fromtheproductionprocessandspecificallyfromtherotatingkilnandtherefiningprocedure.Tominimisedustemissionsinthe atmosphere, the exhaust gases from the rotating kiln and theleadcleaningtanksarefedtotwobagfiltersystemsthatare equipped with a pulse jet self-cleaning system.

The unit has been fittedwith a system for the continuousmeasurement and recording of suspended particles. Pb, nitrogen oxide (NOx), and sulphur dioxide (SO2 emissions, TOC in the exhaust gases of the rotary kiln and at the refiningstageattheexitpointofthefilterbagsaremeasuredmonthly. Annual regular measurements are performed with regard to dust, lead, and sulphur dioxide at the exit point of the scrubber. The sampling and the analysis of these parameters are performed in agreement with the available national and other international standards (ISO, CEN).

> Emissions from combustion

Combustion products are released into the atmosphere from the steam boiler of the unit producing sodium sulphate, from the burner producing hot air in the sodium sulphate producing unit, from the burner of the rotating kiln used for melting lead, and from the burners in the tanks used for cleaning the lead.

Natural gas is used as fuel. The steam boiler, as well as the entirety of the production unit’s mechanical equipment are state of the art. In addition, combustion products are emitted from the direct burning of diesel oil during the operation of the forklifts. The forklifts are properly maintained and inspected by external accredited bodies.

> carbon dioxide emissions

We have calculated the CO2 emissions generated from the company’sactivitiesandspecifically from theconsumptionof electricity, natural gas and diesel oil.

53


SUNLIGHT RECYCLING

Our performance

The quantity of CO2 emissions in tons, as listed in the following tables, has been calculated using the tool: “The GHG Indicator: UNEP Guidelines for Calculating Greenhouse Gas Emissions for Businesses and Non-Commercial Organizations”.

Air emissions from the consumption of natural gas in the production process

Emission

Quantity emitted (t/year)

2015 2016

cO (source of literature factor: CORI-NAIR 2007) 0,51 0,62

cO2 (source of literature factor: UNFCC) 1.670 2.029

NMVOc Total mass of volatile organic compounds, except methane (source of literature factor: CORINARI 2007 / AP 42)

0,15 0,84

NOx/NO2 Total mass of nitrogen monoxide and nitrogen dioxide expressed as nitrogen dioxide (source of literature factor: CORINAIR 2007)

3,01 3,66

PM10 (source of literature factor: CORINAIR 2007) 0,42 0,34

Pb 0,48 0,50

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A specialized external associate takes measurements every four months to monitor emissions. The results of the measurements are presented in the following table.

Emissions measurement results

Measurement spot Date of measurement

Dustmg/Νm3

Pbmg/Νm3

TOcmg/Nm3

SO2mg/Nm3

NOxmg/Nm3

Scrubber02/2015 1,81 0,18 - 0,9 -

11/2016 2 0,09 - - -

Kilnandrefinementbagfilterchimney

04/2015 0,91 1,51 - 17,5 <1,5

07/2015 4,73 1,70 0,5 7,2 2,5

12/2015 4,89 0,71 - 9,1 1,3

04/2016 0,55 1,97 - 0,3 5,9

7/2016 1,26 0,41 - 51,6 2,9

11/2016 1,53 0,33 1,9 137,0 2,8

12/2016 2,06 0,30 - 25,8 5,9

Limit value in mg/Nm3 (Decision Approving the Environmental Terms issued by the Ministry for the Environment, Division for Controlling Environmental Pollution and Noise, Department of Industries, Protocol no.: 162707/28.07.2014)

- 5 2 15 200 300

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cO2 tons produced

indicators Quantity2015

Quantity2016

cO2 emissions / Pb product and Na2SO4 (t/t)

0,57 0,29

cO2 emissions / Pb product (t/t) 0,65 0,31

cO2 emissions from the consumption of electricity (t)(conversion factor:0.685 tCO2/MWh, IEA, CO2 Emissionsfrom Fuel Combustion, 2014 Edition.International Energy Agency)

2.675 2.831

cO2 emissions from the consumption of natural gas (t)(source of literature factor: UNFCC)

1.670 2.029

cO2 emissions from the consumption of diesel oil (t)(conversion factor: 2.648 tCO2/klt, Defra/DECC (2014). UK Governmentconversion factors for greenhouse gasreporting. Department of EnvironmentFoodandRuralAffairs/DepartmentforEnergy and Climate Change, London.)

34 43

Total 4.380,22 4.903,6

GRI 305-1 GRI 305-2 GRI 305-4

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Effluents from the unit’s operation are divided into the following three categories:

1. Effluents from the production process

> Effluentsfromtheproductionareasofthelead-acidcells/batteries, which result from the electrochemical formulation of the plates, thewashing of electrodes, floor cleaning,the cooling of plates at the drying furnaces (SOVEMA, TIGEL),alongwitheffluentsgeneratedfromtheoperationof the scrubbers.

> Effluents from the silver-zinc (Ag-Zn) battery productionfacilities, which are generated from the galvanization procedure and the washing of electrodes.

Alltypesofeffluentsarefedtoadifferenteffluentsprocessingsystem, while the treated effluents are fed to an irrigationditch.Itispossibletoreusethetreatedeffluents.

2. Sewage from the sanitary facilities available to the personnel and from various auxiliary activities.

Effluentsresultingfromthesanitationfacilitiesavailabletothepersonnel (bathrooms, sinks, etc.) are collected and fed to theeffluentstreatmentsystem.

All other wastewater is fed to septic (sealed) trenches, which are located inside the unit’s premises and are regularly emptied by tanker trucks and led to the Wastewater Treatment Facilities of the Municipality of Xanthi.

Wastewater, regarding the hydraulic and pollutant charges produced by the unit’s personnel are at lower levels in comparison to the respective urban waste.

3. Rainwater

Rainwater is collected from the uncovered areas of the unit’s property through a network of channels and are led outside the plot’s borders.

3.5 Effluents

SYSTEMS SUNLIGHT

Our approach

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It must be noted that the 0.05 mg/l concentration matches the discerning capacity of the measuring instrument; in other words, the measuring instrument may not measure concentrations lower than 0.05 mg/l.

2014 2015 2016

SYSTEMS SUNLIGHT

Our performance

Despitethesignificantincreaseinproductionduringthepastthreeyears,wehavemanagedtoretainthewastewaterwetreatedatthesamelevels, thanks to the increase in the volume of water recycled internally for production purposes.

Volume of wastewater treated (m3)

2014 2015 2016

13.136,2 13.136,2 13.144,5

Average concentration of sulphur in disposed water (mg/l) (Limit: <1000)

JAN0

200

400

600

800

1.000

2,5

MAY SEPTMAR JUL NOVFEB JUN OCTAPR AUG DEC

SO4/

(mg/

l)

Month

max

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2014 2015 2016

Average value of PH in disposed water (6<Limits>9)

JAN5,0

5,5

6,5

7,5

8,5

9,5

6,0

7,0

8,0

9,0

10,0


PH

Month

2014 2015 2016

Average concentration of Pb in disposed water (mg/l) (Limit: <0.2)

JAN0,00

0,04

0,08

0,12

0,16

0,20

0,24


Pb/(

mg/

l)

Month

max

max

min

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SUNLIGHT RECYCLING

Our approach

At SuNliGHT REcYcliNG we have achieved zero disposal of effluents to the environment, through the complete recirculation of water within the factory.

1. Effluents from the production process

Recycling takes place at every point that generates liquids in the following manner:

> The electrolyte is reused at the desulphurization stage for the lead paste.

> The liquid from the thickening stage is recirculated and feeds the sprinklers in the centrifugal separator.

> The sodium sulphate solution from paste desulfurization – hyperdsulfurization stage is treated for the production of sodium sulfate.

> The vapour condensation from the crystallizer are collected in a tank and are then reused.

> The liquid from the Na2SO4 suspension centrifugation unit is recirculated in the crystallizer.

2. Personnel effluents

Effluents from the sanitation facilities available to thepersonnelandbyofficecleaningarecollectedandfedtotheeffluentsbiologicaltreatmentsystemoftheIndustrialAreaofKomotini.

3. Rainwater

Rainwater is collected from the uncovered areas of the unit’s property through a channel of ducts and is fed to rainwater tanks. In each tank’s first chamber the solid content getssettled,whileviaoverflowingthewater is fed to thesecondchamber. From there, again throughoverflowing, rainwateris fed to the Industrial Area’s rainwater collection network. Industrial Area’s representatives perform regular inspections regarding wastewater; the results of these measurements are under the applicable limits.

SUNLIGHT RECYCLING

Our performance

> Minimisation of effluents released to the environment, through complete recircu-lation of the water inside the factory.

> Zero acid waste, due to the conversion of the acid solution to quality industrial-grade salt (sodium sulphate).

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Energy

The unit is supplied with electricity for its operating needs from the Public Power Corporation’s (PPC) grid. The electric power is used by the unit for the electrochemical formulation of the plates and the electrochemical formulation and charge of the lead-acid cells / batteries, the operation of the mechanicalequipment,andtheelectrificationofitsbuildings.

The unit is equipped with burners for its production and for heating the areas, which operate with propane; these are stored in above-ground tanks.

Finally, a photovoltaic system (PV) provides all necessary energy to the unit’s distribution centre.

use of Water

Water is used from the water supply network for the unit’s operating needs, along with water from a drilling, which is located within the unit’s property.

Water is used:

> To produce deionized water through the use of osmosis, which is then used for the production of lead-acid cells/batteries / batteries (dilution of the dense sulphuric acid to produce electrolyte, for the production of the paste, and for washing the plates following the electrochemical formulation).

> Tocleantheinternalareas(washingthefloors).

> For the personnel’s sanitary needs.

> To irrigate the surrounding area.

> To cool the mechanical equipment used in the production of the batteries.

> Forthefire-fightingnetwork.

3.6 Natural resources

SYSTEMS SUNLIGHT

Our approach

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SYSTEMS SUNLIGHT

Our performance

Percentage of recycled raw materials

The recycled materials used in the production of our products are lead and polypropylene. Lead amounts to 70% of the quantity of materials included in a battery. The quantities of recycledleadusedtoproducenewbatteriesaresignificantlygreater than the respective quantities of primary material.

Specifically, the percentage of recycled lead over the totalquantity of lead used in the past three years is:

Percentage of recycled lead

2014 2015 2016

60% 54% 58%

4035302520151050

2014 2015 2016

24,8 29,6 35,7

Total electricity consumption (GWh/Year)

2014 2015 2016

GW

h

*It must be noted that the increase in energy consumption is related to the increase in production.

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Energy

For its operating needs, the unit is supplied with electricity by the Public Power Corporation’s (PPC) grid. In addition, the unit uses natural gas in its production process, and specifically:

> in the burner of the rotating kiln used to melt lead;

> infourburnersintheleadcleaningtanks(refiningprocess);

> in the steam boiler in the unit producing sodium sulphate;

> in the burner used in the drying unit for sodium sulphate.

Finally, the unit uses diesel for its forklifts.

The unit has been designed by taking into considerations various issues, such as energy conservation mainly by reducing the loss of energy in auxiliary activities (utilization of hot exhaust gases, etc.).

The total energy consumed by the unit (consumption of diesel oil, of electricity, and of natural gas) is presented below.

The objective is to monitor the consumption of electricity, natural gas, and oil through the various bills on a monthly basis.

use of Water

GRI 303-1

The unit uses water taken from the municipal water supply network. The water is used for the following:

> the production process,

> cleaning of areas and of personnel’s sanitation facilities,

> inthefirefightingtank.

A cooling water recycling system has been installed in the company’s facilities, with the purpose of reducing water consumption. To reduce water consumption, the following measures have been taken:

> Systems are used for the complete recirculation of water in the production process.

> A system checking for leaks has been installed.

> All pipework runs above the ground, to allow for the easy identification of leaks.

> Regular leak tests are conducted under the maintenance and inspection programme of the unit.

> Water consumption is monitored through the bills issued.

SUNLIGHT RECYCLING

Our approach

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SUNLIGHT RECYCLING

Our performance

Percentage of recycled raw materials 82%

of the raw materials used by SYSTEMS SUNLIGHT are recycled or reused.

Water consumption data

2015 2016

Water consumption indicator / Pb and Na2SO4 (m3t) quantities 0,25 0,14

Water consumption indicator / Pb (m3t) products quantities 0,28 0,15

Water consumption (m3) 1.920 2.315

Pb and Na2SO4 (m3t) quantities 7.749 16.741

Pb product quantities (m3/t) 6.784 15.577

GRI 301-2

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2015 2016

Qua

ntiti

es

Electricity

Electricity consumption (MWh) 3.905 4.133

Natural gas

Natural gas consumption (m3) 863.813 1.049.756

Natural gas consumption (converted to MWh using an appropriate conversion factor (10.89 kW/m3)

9.407 11.432

Diesel oil

Diesel Consumption (It) 12.670

Consumption (converted to MWh using an appropriate conversion factor (10,0 kw/K)

126,7 163

Total energy consumption (MWh) 13.438,7 15.728

indi

cato

rs

Electricity / Pb product and Na2SO4 (MWh/t) 0,50 0,25

Electricity / Pb product (MWh/t) 0,58 0,27

Natural gas / Pb product and Na2SO4 (MWh/t) 111,5 62,7

Natural gas / Pb product (m3/t) 127,3 67,4

Diesel oil / Pb product and Na2SO4 (lt/t) 1,4 0,73

Natural gas / Pb product (MWh/t) 1,6 0,97

Diesel oil / Pb product (lt/t) 1,9 1,04

Diesel oil / Pb product (MWh/t) 0,02 0,01

Total energy / Pb product and Na2SO4 (MWh/t) 1,73 0,94

Total energy / Pb product (MWh/t) 1,98 1,01

The conversion of oil liters and natural gas cubic meters consumed into KWh was performed using “XENIOS” guidelines on energy and environmental management and the natural gas pricelists issued by the Gas Supply Corporation (EPA).

Energy consumption data

GRI 302-1 GRI 302-3

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3.7 Biodiversity

Our approach

SYSTEMS SUNLIGHT

Despite the fact that we are active in the wider ecodevelopment ares of the Eastern Macedonia and Thrace National Park, therearenospecial formsof floraand fauna inSYSTEMSSUNLIGHT’s area of operation since the area is characterized as «permanently irrigated land». These areas are found at the perimeter of the site, at a great distance.

The company has taken all the necessary preventive measures and has installed modern equipment to ensure that any environmental impact to the wider area is avoided. In this context, no degradation of the existing natural environment has been caused or is expected due to the operation and modernization of the Group’s production units.

SUNLIGHT RECYCLING

The company conducts frequent inspections and applies follow-up procedures regarding soil pollution resulting from the activities of the recycling unit. The soil may be polluted following the disposal of hazardous waste generated during production or in the event of an emergency / accident from the storage of the raw and auxiliary materials. Sampling tests are performed for the soil by the facilities of the unit and analyses are conducted in a certified laboratory thatexamines the levels of lead, sulphur compounds, and pH. The levels of lead measured are lower than the levels of lead allowed for soil intended to agricultural use based on the legislation.

To this end, the company’s operation does not affectbiodiversity. It must be noted that the unit is not operating within a protected area. Specifically, the unit has beenestablished within an organized hub for industrial activities, in the Industrial Area of Komotini.

Our performance

Despite the fact that following the assessment of the environmental aspects and impacts to the environment, no impacts to biodiversity have been observed, for SUNLIGHT RECYCLING, the ratio of covered surfaces (buildings, roads, platforms, paved surfaces, etc.) to the uncovered areas of the company facilities was measured and presented in the following table.

Ratio of surfaces covered

Covered areas (m2) 7.853,3

Uncovered areas (m2) 34.146,6

Ratio of covered to uncovered areas 0,23

4.Anti-corruption

Principle #10 Businesses should work against corruption in all its forms, including extortion and bribery


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Operating with integrity, honesty, and respect

SUNLIGHT is one of the most dynamically growing companies in the international market of energy storage systems. Having now achieved to export more than 84% of ourproducedproducts toover100differentcountriesandto600differentclientsallovertheworld,wemustmanagethe complexity in our collaborations, while we frequently participate in international tender procedures. To this end, fightingcorruptionisamajorpriorityforus.TheSUNLIGHTGroup’s vision is to be the most reliable partner and to continuebeing thefirstoption forourclients,byoperatingwith integrity. For this reason, we pay special attention to monitoring transactions with our external partners, as well as fostering integrity to our employees, by creating on a daily basis an environment of transparency that is free from corruption.

To this end, in the past three years, we have launched a series of very important initiatives and we have created the following:

> Anti-corruption policy, with rules that affect our daily practice.

> Questionnaires addressed to all our suppliers, including compliance with our anti-corruption rules.

> Policy that expressly prohibits Bribing, supported by strict internal and accounting audits.

> Regular training sessions at various levels of our organization.

Finally, in 2016, we participated in the discussion held by the internationally renowned anti-corruption organization, TRACE International. Our collaboration with such a major organization proves our commitment for the increase of transparency in our global transactions at a global scale.

tania chadouliLegal counsel & compliance director

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SUNLIGHT Group in committed to maintain a work environment free from corruption. To this end, our Group expects that all its employees and its Management adhere to the Code of Business Conduct, to the bylaws and respective policies of the Group, while also strictly adhering to applicable legislation.

Specifically,ourGroupfollowsananti-corruptionPolicythatisbinding for the Management, the executives, the employees, and all other persons providing services to the Group or on its behalf, without allowing any exceptions or deviations. We are all committed to comply with the requirements of this Policy and ensure its proper application.

In addition, our Group is committed to comply with the requirements of the Greek and European competition law, as well as of the national competition laws in the countries where we operate. The ultimate purpose of the Group’s Anti-Trust Policy is the identification of the possible pointsofconflictwiththerequirementsofthecompetitionlawsandthe creation of suitable knowledge to avoid them at every hierarchy level of our Group.

Risk Assessment Study

In the context of the new international Standard ISO 37001 on Anti-Corruption, we have proceeded to procedures for the evaluation and management of possible risks for possible corruptionareas.Weappliedafive-tiermethodology:

1st tier > Risk recognition2nd tier > Risk evaluation3rd tier > Preventing measures 4th tier > Remaining risk calculation 5th tier > Corrective actions

Objectives> Achieving a work environment free from corruption.

> Recording zero cases of corruption.

> OurobjectiveistobecomethefirstcompanytoreceivetheISO37001certificationinGreecein2017.

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Our approachWe are committed to strictly adhering to the provisions of Greek and European Union’s (EU) anti-corruption laws, as well as to the national anti-corruption laws stipulated in the countries where we operate. The ultimate objective of our Group’s Anti-Corruption Policy is to provide information on any possible violations of the anti-corruption rules and avert such violations by our personnel, employed at any level, from workers to middle and senior management.

In addition, the Compliance Programme promotes and ensures clear understanding by the Group’s personnel and management of both anti-corruption rules and the impact thereof on our everyday operations and on the formation of our commercial and operational practices. Understanding is necessary to avert any possible violations of anti-corruption laws, which could expose our Group and every member of our personnel, individually and jointly, to the risk of serious sanctions.

Regarding bribery, our Group prohibits offering objects orservicesofvaluewiththepurposeofinfluencingorobtainingan unfair advantage in order to acquire or preserve a business relationship. We follow strict internal accounting audits to avert anyhiddenbriberiesorothersimilarfinancialtransactions.Ouremployees, suppliers, consultants, representatives, or dealers are chosen and act always with the purpose of protecting the reputation and integrity of the Group in the international market.

Asfarasmoneylaunderingisconcerned,wefightitbypayingspecial attention when doing business with new business partners, in order to specify the origin of the capitals and assetsinapromptandeffectivemanner.

The compliance and application of the Anti-Corruption Policy, including the disclosing and reporting procedure concerning any possible violations, fall within the responsibility of the Legal Affairs and Compliance Division; the Division is regularly assigned to examine a series of events to ascertain the application of the Compliance Policies.

Any member of the Group’s employees and Management who discovers any law violations concerning competition or has suspicions or doubts about the compatibility of an action or contract with anti-corruption laws, or has doubts about the application of this Policy may:

> report this information: •to the Manager of their department; •to the Human Resources department; •totheLegalAffairsandComplianceDivision;

•totheComplianceOfficer; •to the Chairman of the Compliance Committee, acting as

whistle blowing line ([email protected]), by providing their name or anonymously.

> request advice and discuss the issue of concern by the Compliance Division or with any person suggested to them;

> submit written questions requesting clarifications, advice,and instructions;

> filearelevantwrittenreport;

> submit questions and reports via email at: [email protected]

> callthewhistleblowinglineforissuesconcerningthefightagainst corruption.

4.1 Steps to ensure a work environment free from corruption

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Our performance

GRI 419-1


During the reporting period (2014 - 2016), there has been no case of failure to comply with laws or regulations.


Our performance is not audited separately but collectively through the Group’s Internal Audit. During the reporting period, our Group did not conduct any External Audit on anti-corruption issues.

Allouremployeesconfirmthattheyhavereadandunderstoodthe SUNLIGHT Code of Conduct and agree to apply its provisions, by signing a form of acceptance. It is required from allouremployeestoprovidesimilarconfirmationsataregularbasis. Failure to read the code or sign the acceptance form does not release anyone from the obligation to comply with the Code.


Our company communicates regularly its commitment to fightcorruptiontoitsemployees,whileitalsoorganizesanti-corruption training sessions for all its employees. In 2015, we launched and implemented a special training seminar for all employees on the SUNLIGHT Code of Conduct, paying special attention to issues of integrity, protection of our assets, respect to fellow citizens, to society, and to the environment, while focusing on our clients and on the good policies on Competition, on Anti-Corruption, and on the application of the Code of Conduct. The participants of these seminars received named participation certificates, confirming that all Groupemployees have been informed about the Code and the Anti-Corruption Policies, including the sanctions imposed following a failure to comply with them.

In addition to the above, and especially for middle / senior executives, the training sessions were focused more on issues of competitive behaviour, while paying special attention to the issueofconflictofinterestforallemployees.

Specificallyin2016,wecollaboratedwithTRACEInternationalInc., by adopting their innovative online tools for the conduction of training sessions on behalf of our company to all of our employees.

In addition, as mentioned above, all Group employees, regardless of their hierarchical level, gets informed through the Compliance Programme of our Group on the laws on good

competition practices, on the key clauses of the Greek and European competition law, on the reasoning behind them, on the practices prohibited and the related sanctions, as well as on the Administrative Authorities that are responsible for applying them. The provision of this information aims to assist both the Management and the employees of the Group understand firstly the fundamental principles of Competition Law andsecondly the impact of these rules on the everyday operation of the Group and on the formulation of business practices. This understanding is necessary to avert any violations of the competition law that could leave the Group exposed or expose the employees to the risk of severe sanctions. Moreover, it is attempted to provide information and raise the awareness of the company personnel in relation to possible or actual foul play by customers, suppliers and/or Group competitors.

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Our approachThe preservation of strict ethics standards, in compliance with the national and international laws, constitutes a guiding principleofourGroupandaffectsallitsoperationsandactivitiesaround the world. Considering the complicated and peculiar characteristics of the global market where we are engaged, compliance with the anti-corruption laws requires continuous and updated information on the development of markets, understanding the fundamental need of complying with the laws in general, as well as showing vigilance, consistency, and integrity for the implementation of the anti-corruption policy by every member of the personnel, regardless of level.

We also align ourselves with the Council of Europe’s Criminal Law Convention on Corruption.

Before concluding any agreement with any client, representative, partner in a joint venture, contractor, distributor, reseller, or other intermediary and third person, or anyone who shall act on our behalf, the Group, as appropriate, performs due diligence and ensure from the third party that they are fully aware of and agree with our Anti-Corruption policy. The employeesofourGroupmustalwaysconsulttheLegalAffairsand Compliance Division before proceeding to any such commitment, in order to allow for the performance of due diligence.

Morespecificinstructions,regardingPublicServants,prohibitthe conclusion of contracts with intermediaries (consultants, representatives, and other commercial partners) who may maintain relations with Public Servants or sign contracts on behalf of these persons, unless:

4.2Communication of Anti-Corruption Policies and Procedures to third parties

> ApprovalhasbeensecuredinadvancefromthelegalAffairsand Compliance Division.

> A due diligence has been performed to ensure that the intermediary will retain from actions of corruption.

> Afileiskeptwiththeresultsoftheduediligencestudy.

> The agreement with the intermediary includes the following clauses:

• Statement under which the intermediary pledges to comply with the current anti-corruption law.

•Statement by which the intermediary pledges, upon request by the company, to provide copies of any document or security that may be related to the commercial collaboration in question.

•Statementbywhich the intermediaryconfirms that theyhave been informed about this policy and agree to be bound by its clauses.

•The terms of the agreement may be disclosed to competent state services, if the company considers this necessary. •The intermediary shall not assign or delegate to others any workundertakenwithoutthepriorandspecificconsentofthe Group.

•The intermediary shall disclose to the Group any relation that may arise between them and a public servant.

• The intermediary shall file official statements confirmingthey have complied with anti-corruption laws, annually or, if deemed necessary by the Group, every six months.

•The Group shall be able to retain payments based on the contractual terms, or terminate the contract, if they consider, while acting in good faith, that the intermediary has violated anti-corruption laws.

•The Group shall have access, within reason, to the books and files of the intermediary, alongwith the right to auditthem regularly, provided such access and audits are allowed under the standard commercial practices.

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All policies are connected to the suppliers, clients, representatives, or any kind of our Group’s associates:

suppliersAllourbasicsuppliers,domesticandforeign,fillinandsignonan annual basis the respective questionnaires, where, apart from the general information and their details, disclose if they haveanyspecificcertificates,suchasaQualityManagementSystemcertifiedtoISO9001,aSafetyManagementSystemcertifiedtoOHSAS18001andanEnvironmentalManagementSystemcertified to ISO14001/EMAS;otherwise, theymustreply to a series of questions to allow us form a complete picture about whether or not they comply with regulations, while there are concrete questions also included on compliance with Anti-Corruption Rules.

representativesRespectively, all our representatives, who mediate for the sale of goods or services on behalf of our Group or for any of its affiliates,inalignmentwiththeanti-corruptionprogramme,areobligedtofillinandfileaDisclosureStatementforreviewandapproval.

consultantsAn assessment – review procedure is applied in all cases for consultants,requestingthemtofillinarelevantformcontainingthe details of the consultant, including details of persons who can provide references. These details include, among others, information about management, the shareholder composition, and other details (for example, whether there is a family relation with members of public administration) to evaluate whether they fall in the cases of increased risk. This form is accompanied by formsevidencingall the relevant information (e.g.certificateissued by the competent chamber, articles of association, and other documents, to the extent that no privacy laws are violated).

clientsIn every contract signed with clients, we expressly state the requirements of the SUNLIGHT Code of Conduct applicable to our Group, while also citing our own statement that the fees we are going to collect from them are not going to be used for corruption.

In case of doubt regarding the origin of the money collected from our business partners, we proceed to the respective procedures to ensure that they do not refer to money laundering, prior proceeding with any transaction with the partner in question.

Respectively, when we receive any information about any activity or transaction we consider or suspect that could be related to money laundering, we take the necessary steps, as set out in our code, and disclose all relevant available information.

When there is no direct contact with a business partner and theverificationoftheiridentityiscomplex,additionalverificationmeasures are requested.

Our performanceAll Group partners, as described above, have been informed about our Policies concerning compliance with the law and Anti-corruption.

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the most important action taken by the group during the reporting period, regarding the joint actions for anti-corruption, was its participation in the round table discussion on anti-corruption, held by trAcE international, a globally respected anti-corruption organization, in Athens, on september 16, 2016.

The discussion was led by the President of Trace International, Ms. Alexandra Wrage, an executive with international reputation in the field of Compliance. The event was attended byrepresentatives of companies from various business sectors, along with the SUNLIGHT Group, which was represented by Ms. Tania Chadouli, Legal Counsel and Compliance Director, and by Mr. Dimitrios Gkoumas, independent member of the Board and President of the Company’s Compliance Committee.

This event was focused on the best practices to ensure corporate transparency and on the developments of the industry both regarding compliance and anti-corruption. The participants exchanged their views regarding the Greek economy and entrepreneurship, the current legislative framework and the methods by which corporate ethics can be improved, while promoting transparency in commercial practices.

Alexandra Wrage presented specific examples from Greekreality that refer to the application of relevant practices used for combatting phenomena of corruption in our country, while representatives of SYSTEMS SUNLIGHT discussed about the innovative tools developed by the Group, in addition to those provided by TRACE, seeking to ensure transparency in the corporate commercial transactions.

4.3Participation in joint actions for anti-corruption

The participants unanimously agreed that the adoption of measures for preventing and fighting corruption in Greececould significantly boost the effort to end the financialcrisis. Adopting suitable training tools for employees and the dedication of resources for the creation of departments of compliance are necessary steps to this direction, having TRACE as a precious ally.

TRACE is very pleased from the round table discussion held in Athens. We have participated in high-level talks firstlyconcerning the international segmentof fightingcorruptionand secondly about the steps that must be taken by Greek companies to improve their departments of compliance.

TRACE, with the purpose of increasing transparency in commercialtransactionsataglobalscale,offersitsmemberstraining programmes, both online and through individual meetings, through which the companies become able to understand these practices and contribute to prevention against corruption. At the same time, TRACE provides audit services, including theTRACECertificate, acertificate thatunderscores the commitment of a company to transparency in its commercial practices, and to compliance procedures against bribing.

SYSTEMS SUNLIGHT is very proud for its compliance programme, the adoption of international practices against bribery and about its commitment to transparent commercial transactions, as well as about its participation in the event heldbyTRACEInternational–thefirsteventofsuchcalibreheld in Athens.


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Initiatives for the Society

Donation of Toshiba products to the Scouts of Greece.

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Corporate responsibility forms an integral part of our Group’s strategy and operation. Apart from our practical commitment, in the context of our circular economy business model and the responsible business activities in our everyday operations, SUNLIGHT Group also implements a series of actions that focus on the needs of the society and its members, in various areas such as health, education, sports, and social solidarity. In addition, we pledge to interact in a positive manner with the communities where we live and work.

For 2015, we supported the following actions:

donation to «make a wish»

With great sensibility, SUNLIGHT made a donation to “Make a Wish”, the voluntary organization that fulfills thedesires of children with serious and life-threatening illnesses, participating in the realization of a wish for a four-year girl from Xanthi for the construction of her room.

Offer to «Flame»

At the same time, we supported the Association of Children with Neoplastic Disease «Flame», in order to help them meet the operational needs of their family guesthouse.


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supporting institutions in the city of Xanthi

In addition, SUNLIGHT supporting the local community of Xanthi, provided support to the Nursing home, the Psychological Center and the Filoproodos Association of Xanthi (FEX).

coralia Educational trip

The «Educational Trip» program was created to familiarize Greek students with a different academic reality andtransfer knowledge and experience of successful foreign practices to Greek universities.


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For 2016 we supported the following actions:

supported basketball team «Aspida Xanthis»

By participating actively in the local actions of the cities where we operate, and with a sense of social responsibility towards youth and sports, we covered the operating costs of “Aspida Xanthi” basketball team for the whole year.

collection of necessities for refugees

Following Olympia Group’s initiative, we launched a major collection effort for necessities for refugees, buildingbridges with society. In collaboration with NGO “Nostos”, we gathered necessities that we delivered at the refugee arrival and stay points, such as Piraeus and Mytilene.

donations to the greek scouts

By supporting youth actions, we donated 4,000 Toshiba battery packs to cover the scouts’ needs nationwide.


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corallia Educational trip

Once again, we continued our contribution to the Educational Trip program.

Blood donation

Olympia Group has created our own blood bank by allowing all of us to contribute to the purpose of voluntary blood donation.

visits by educational institutions to our plant in Xanthi

In 2016, twelve schools and technical educational institutions visited and toured the plant in Xanthi. In total, more than 800 children and young people had the opportunity of seeing and learning about our company’s production process, and this is another proof that SUNLIGHT supports the local community.


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Strategic PartnershipsGRI 102-13

sEvHellenic Federation of Enterpriseswww.sev.org.gr

EEdEHellenic Management Association www.eede.gr

sEpAnFederation of Recylcing and Energy Recovery Industries and Enterpriseswww.sepan.gr

tErrAnovAEnvironmental engineering and counselingwww.terranova.gr

AFisRecycling of Portable batterieswww.afis.gr

comBAttSystem of Alternative Management of lead-acid and nickel-cadmium batteries www.combatt.eu

SYSTEMS SUNLIGHT, is a member of reputable organizations and has established collaborations with strategic partners to strengthen its position in commercial, business, and environmental matters:

trAcEInternational Organization for the Promotion ofProfessionalTransparencyandthefightagainstcorruptionwww.traceinternational.org

EuroBAtEuropean Association of European Automotive and Industrial Battery Manufacturers www.eurobat.org


SUNLIGHT Group Awards

tErrAnovAEnvironmental engineering and counselingwww.terranova.gr

2016

trAcE internationalParticipated as coordinating company in the round table discussion on anti-corruption

“sales Excellence Awards”Gold Award in the “Exceptional Performance & Sales Increase” category

“greek Exports Awards”Triple distinction as “Top Exports Company”, “Top Industrial Company”, “Top Innovation Company”

“Hr Awards”Award for “Best Change Management Strategy - Initiative” category

“Environmental Awards”Award to SUNLIGHT RECYCLING in “Waste Management - Recycling & Re-Use of Waste” category

2015

“Environmental Awards”SUNLIGHT RECYCLING was awarded the Gold Award

“Kpmg Human resources Awards”Award in category “Selection and Retaining of Human Resources”

“transport & Logistics Awards”Best Performance Award

“greek Exports Awards”Leading distinction as “Top Greek Export Company” and Gold Award as a “Top Industrial Company”

“sales Excellence Awards”Silver Award for “Sales Increase”

“Best supplier Award”Above & Beyond Supplier of the Year 2015 by NACCO, Materials Handling Group

2014

“sales Excellence Awards”“Increasing Exports” award

“made in greece” institution Two distinctions for Export and Industrial Excellence

“Health & safety Awards”Silver Award

“greek value for northern greece” AwardsDistinction

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We end all poverty, everywhere.

We ensure availability and sustainable management

of water and hygienic facilities for all

We create safe, adaptable, viable and inclusive cities and human settlements

We promote peaceful and inclusive societies, provide

access to justice for all, and buildeffectiveinstitutionsat

all levels

We end hunger, achieve food security, improve

nutrition and sustainable agriculture.

We ensure access to economic, reliable,

sustainable and modern energy

We ensure sustainable con-sumption and production

methods

We are strengthening the means of implementation

and renew the Global Partnership for Sustainable

Development

We ensure a healthy life and promote well-being for all,

at all ages.

We promote continuous, sustainable, and inclusive

growth and full employment and decent work for all

We take immediate action to combat climate

change and its consequences

We ensure free, equal and quality education by promoting opportunities

for lifelong learning

We build sustainable infrastructure, promote open and sustainable industrialization and

encourage innovation

We protect and use with a sustainable way oceans,

seas and marine resources to allow for sustainable

development

We achieve gender equality and the emancipation of all

women and girls

We reduce inequality within and between countries

We promote the sustainable use of terrestrial ecosys-temsandforests,wefightdesertification,wereversethe degradation of soil and

biodiversity

On September 25, 2015, the U.N. member states adopted a set of objectives for the eradication of poverty, the protection of the planet and the protection of well-being for all as part of a new 15-year sustainable development agenda. At the heart of Agenda 2030arethe17SustainableDevelopmentGoals(SDGs)and169specifictargetsrelatedtothem,whichrefertothemostimportanteconomic, social, environmental, and governance challenges of our time. According to the U.N., these objectives shall promote actionsthataffectcitizens,theplanet,prosperity,peace,andcooperation.

In the context of this Report, we have described, where relevant, our impact on the Sustainable Development goals.


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Sustainable Development GoalsGRI 102-12

This Report has been prepared with the support of EY (Ernst & Young Hellas).

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SUSTAINABLE DEVELOPMENT REPORT 2016 - Sunlight...sustAinABLE dEvELopmEnt rEport 2016 sunLigHt group...

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