Internal Audit Department constitutes an independent, impartial, assurance and advisory activity of the Company designed to add value and improve Company’s operations. Supports Company in achieving its objectives, through a systematic and structured approach over the evaluation and improvement of efficiency in risk management, internal control systems and corporate governance procedures.

Basic Operational Principles

Internal Auditors while exercising their duties are independent, they do not come under the hierarchical authority of any other department of the Company and are monitored by the Company’s Board of Directors through the Audit Committee.

Internal Audit Department reports the results of its work to the Audit Committee and to the Board of Directors, which is the overseeing body for the Internal Audit Department. Internal Audit Manager is an individual with adequate qualifications and experience appointed by the Company’s Board of Directors.

Internal Audit Department investigates and assesses the adequacy and efficiency of Internal Control Systems as well as the quality and efficiency of any other systems in place for the achievement of Company’s objectives defined. Moreover, the Department reviews the implementation of internal control systems in all Groups’ subsidiaries and holds the responsibility for the adoption of common internal control principles by all the Group’s subsidiaries.

Basic objective of internal audit is to provide reasonable assurance to the shareholders over the achievement of Company’s business objectives.

Internal Auditors exercise their duties according to the Code of Ethics of Internal Auditor’s Institute and so principles of independence, objectivity and confidentiality are implemented. Moreover they act according to the Standards for the Professional Practice of the Internal Audit and the Company’s policies and procedures.

Internal Audit Department has full access to all data and records, employees, facilities and activities of the Company and its subsidiaries, which are necessary in performing audit projects. Moreover, the Department is responsible for the safeguard of data confidentiality. Members of the Board of Directors cooperate with and provide information to Internal Auditors and generally facilitate them in exercising their duties.

Company’s Management provides to the Internal Audit Department any information and data necessary for the fulfillment of audit projects and cooperates with the Department during audit projects as well as while implementing proposals for improvements submitted.

Responsibilities

The responsibilities of Internal Audit Department include the following:

– Recording, critical reviewing and auditing Company’s Internal Control System.
– Reviewing of the system providing financial and administrative information to the Company’s Management.
– Confirming of the implementation of policies and procedures, which have been adopted in order for the Company’s business objectives to be achieved.
– Performing regular and irregular audits.
– Auditing Company’s accounting and information technology systems.
– Reviewing of the safeguard means of Company’s assets.
– Performing irregular audits in collaboration with the Company’s Management.
– Monitoring the implementation and renewal of Operation Regulation, as defined by the Company’s Board of Directors, article of association and legislation concerning the Company and especially stock market’s legislation and legislation for Société Anonyme.
– Monitoring the implementation of Company’s commitments included in Company’s Newsletters issued, regarding the use of capitals retrieved from stock market.
– Monitoring the legality of remuneration and all kinds of compensation to Management’s members in connection to the decisions of the Company’s bodies in charge.
– Monitoring Company’s relations and transactions with affiliated companies.
– Participating advisory in evolving new systems aiming to the introduction of efficient control systems.
– Cooperating with External Auditors.
– Internal Audit Department reports to the Company’s Board of Directors conflicts between Board of Director’s members or Company’s Directors personal interests and Company’s interests, traced while performing its duties.
– Reporting in written to the Audit Committee at least once every three months in relation to the audit projects performed so as for the Committee to subsequently inform the Board of Directors.
– Being present at the Shareholders’ General Assemblies.
– Providing after the approval of the Company’s Board of Directors any information requested in written from regulatory authorities, cooperate with them and facilitate them by any means possible in the monitoring, auditing and supervision tasks they perform.