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Annual Financial Report for the year ended December 31, 2022 
(amounts in Euro unless stated otherwise) 
 
 
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.
 
 
4
4
 
 
STATEMENT OF CORPORATE GOVERNANCE .......................................................................................................................................... 72 
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1
1
0
0
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9
 
 
INDEPENDENT AUDITORS' REPORT…………………………………………………………………………………………………………………………………………………112 
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1
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4
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1.  ESTABLISHMENT AND ACTIVITY OF THE COMPANY ............................................................................................................. 124 
2.  BASIS OF PRESENTATION OF FINANCIAL STATEMENTS: ....................................................................................................... 125 
3.  PRINCIPAL ACCOUNTING POLICIES ....................................................................................................................................... 128 
4.  PROPERTY, PLANT & EQUIPMENT ........................................................................................................................................ 142 
5.  RIGHT OF USE ASSETS – LEASE LIABILITIES ............................................................................................................................ 143 
6.  INVESTMENT PROPERTY ...................................................................................................................................................... 144 
7.  INTANGIBLE ASSETS ............................................................................................................................................................. 145 
8.  OTHER NON-CURRENT ASSETS ............................................................................................................................................. 146 
9.  INCOME TAX (CURRENT AND DEFERRED) ............................................................................................................................. 147 
10.  INVENTORIES ....................................................................................................................................................................... 150 
11.  TRADE AND OTHER RECEIVABLES ........................................................................................................................................ 150 
12.  PREPAID EXPENSES .............................................................................................................................................................. 152 
13.  CASH AND CASH EQUIVALENTS ........................................................................................................................................... 152 
14.  SHARE CAPITAL .................................................................................................................................................................... 153 
15.  RESERVES ............................................................................................................................................................................ 153 
16.  GOVERNMENT GRANTS ....................................................................................................................................................... 154 
17.  RESERVE FOR STAFF LEAVING INDEMNITIES ........................................................................................................................ 155 
18.  PROVISIONS ......................................................................................................................................................................... 156 
19.  LONG-TERM & SHORT TERM BORROWINGS ........................................................................................................................ 157 
20.  DIVIDENDS ........................................................................................................................................................................... 158 
21.  ACCRUED AND OTHER CURRENT LIABILITIES ....................................................................................................................... 159 
22.  DEFERRED INCOME ............................................................................................................................................................. 159 
23.  SEGMENT INFORMATION .................................................................................................................................................... 161 
24.  REVENUES ........................................................................................................................................................................... 163 
25.  ANALYSIS OF EXPENSES ....................................................................................................................................................... 164 
26.  OTHER OPERATING INCOME / EXPENSES ............................................................................................................................ 165 
27.  FINANCIAL  INCOME/EXPENSES ........................................................................................................................................... 166 
28.  DEPRECIATION AND AMORTISATION .................................................................................................................................. 166 
29.  PAYROLL AND EMPLOYEE RELATED COST ............................................................................................................................ 166 
30.  EARNINGS PER SHARE.......................................................................................................................................................... 168 
31.  COMMITMENTS AND CONTINGENT LIABILITIES .................................................................................................................. 168 
32.  RELATED PARTIES ................................................................................................................................................................ 171 
33.  FINANCIAL INSTRUMENTS ................................................................................................................................................... 173 
34.  SUBSEQUENT EVENTS.......................................................................................................................................................... 176 
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Page 3 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Statements of the Members of the Boards of Directors

(In accordance with article 4 par. 2 of L. 3556/2007)

The Board of Directors Members of the Company “Piraeus Port Authority Societé Anonyme” and trade

title “PPA S.A.” (hereinafter referred to as “Company” or as “PPA”) and the undersigned:

1. YU Zeng Gang , Chairman of the Board of Directors

2. ZHANG Anming, Chief Executive Officer (Acting)

3. LI JIN, Member of the Board of Directors

In our above-mentioned capacity and as specifically appointed by the Board of Directors of the

Company, we state and we assert that to the best of our knowledge:

(a) the financial statements of the societe anonyme Company under the name “Piraeus Port Authority

Societe Anonyme” and trade title “PPA S.A.” for the period from January 1, 2022 to December 31,

2022, which were compiled according to the applicable International Financial Reporting Standards

as adopted by the E.U., provide a true and fair view of the assets and the liabilities, the equity and

the results of the period of the Company, according to that stated in paragraphs 3 to 5 of article 4

of the L.3556/2007 and the relevant executive Decisions of the Board of Directors of the Capital

Market Commission.

(b) the annual Report of the Company’s Board of Directors provide a true and fair view of the evolution,

the achievements and the financial position of the Company, including the description of the main

risks and uncertainties it faces and relevant information that is required according to paragraphs 6

to 8 of article 4 of the L. 3556/2007, and the relevant executive Decisions of the Board of Directors

of the Capital Market Commission.

Athens, March 17, 2023

YU ZENG GANG

ZHANG ANMING

LI JIN

Chairman of the

Board of Directors

Chief Executive Officer (Acting)

Member of the

Board of Directors

Passport No ΡΕ1895434

Passport No PE2110665

Passport No PE1614410

Page 4 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

“

”

“

”

from 1st January 2022 until 31st December 2022

(In accordance with article 5 par. 6 of L. 3556/2007)

1. Development & performance of the Company

Α. Brief Description of Business

The Port of Piraeus (Piraeus Port) is the largest port in Greece, with a coast line spanning over twenty-

four kilometers in length and expanding over an aggregate area exceeding five million square meters.

The geographic location of the Piraeus Port makes it a vital transportation, trade and supply, tourism

and communication hub connecting the Greek islands with the mainland, as well as being an

international centre of marine tourism and the commercial passage of cargos. The position of the

Piraeus Port is conducive to its operation both as a commercial and touristic gate of Greece and as

transshipment hub for the Balkans and Black Sea countries.

The Port of Piraeus is situated at the intersection of sea routes linking the Mediterranean with Northern

Europe and its geographic position (south of the 38

parallel) enables major liner ships to access it

without significant deviation from the Far East trade routes. It hosts a complex and unique variety of

port activities, including Cruise activity, Coastal (ferry/passenger) activity, Container and Car and other

General Cargo activities, Ship Repair activities, as well as Free Zone operations under applicable tax and

customs legislation in the area currently designated pursuant to Decisions D18/7.8.2013 (Government

Gazette B’ 2038/22.8.2013) and D18/9.9.2013 (Government Gazette B’ 2330/17.9.2013) of the Minister

of Finance (Piraeus Free Zone).

Further to the amendment and codification on 24/06/2016 in a single text of the Concession Agreement

dated 13/02/2002 between the Hellenic Republic and Piraeus Port Authority S.A., which was ratified by

Law 4404/2016 (Government Gazette A 126/8.7.2016) (hereinafter CA), the Company retains the

exclusive right to use and exploit the land, buildings and infrastructure that are included in the Piraeus

Port until 13/02/2052.

Page 5 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

B. Objectives, Core Corporate Values and Key Strategies

▪ b.1. Objectives

o The implementation of the Investment Plan that multiplies benefits for the local and national

economy

Under Article 7 of the Concession Aggreement between PPA S.A. and the Hellenic Republic, the

Company is required to implement, within the First Investment Period, mandatory investments,

summed with a total reference cost of 293.8 million Euros, which concern the following:

- Passenger Port Expansion (Southern Zone Phase A)

- Repair of Pier I RMG yard area and cranes

- Conversion of Pentagonal Warehouse into Cruise Passenger Terminal

- Underground Linkage of Car Terminal with Former ODDY Area

- Port Infrastructure Improvement and Maintenance

- Supply of Equipment

- Dredging of Central Port

- Construction of New Oil Pier

- Car Terminal Expansion (Herakleous)

- Improvement Infrastructure of Ship Repair Zone

o The further highlighting and reinforcement of Piraeus position as a hub for passenger and

freight transportation

The Company's declared goal is the further highlighting of Piraeus Port strategic advantages and

strengthening its position in the port industry.

The role of the Piraeus Port is not only consolidated but further upgraded through the Investment Plan

of PPA S.A., the customer-oriented approaches and the marketing policy, while the outward

development and the international collaborations were enhanced.

In the above context, the Company has strengthened its presence in national and international

organizations relating to the port industry (detailed reference follows in paragraph b.3, titled “outward

looking’’).

▪ b.2. Core Corporate Values

The basic values that constitute the central core and driving forces of the Company are related to:

a. Preservation and promotion of the general corporate interest and the interests of the

Shareholders.

The primary concern and duty of the Company is the continuous pursuit of enhancing the Company's

long-term financial value and the protection of the general corporate interest and the interests of the

Shareholders.

Page 6 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

b. Continuous improvement

The ultimate aim is the continuous improvement of the port services provided to the port users, at

levels comparable to the best practices adopted by ports of international scope. The Company has as its

primary concern to build strong and long-lasting relationships with its customers, and to provide

excellent service, especially in terms of quality, reliability and delivery time.

c. Health and Safety

The value of human life is the primary Company value, by creating conditions for a safe working

environment.

Particular emphasis is placed on the continuous improvement of the systems and procedures related to

environment, health and safety in the workplace, through full compliance with relevant legislations.

d. Evolution of employees

The Company recognizes that the cornerstone for the achievement of its goals is the best utilization of

its human resources. By understanding and respecting the needs of the personnel and by using

meritocratic criteria, the Company ensures the continuous training and development of the employees,

taking into account the needs of the Company and the protection of the corporate interests.

e. Social Responsibility

Corporate Social Responsibility is a daily practice of how the Company operates. Creating relationships

of trust and cooperation with local communities is a priority of the Company's Management, which aims

at setting up a sustainable development model with the emphasis on environmental protection, poverty

aid, supporting education, sport and other charity causes within the capability of the Company.

▪ b.3 Key Strategies

o Strategic Business Objectives

The formation of the strategic axes of the Company takes into account the very positive perspectives

that were formed by the establishment and activation of the COSCO SHIPPING group in the

organization. The Company continues to work towards the achievement of its strategic goals, as

described below, in a dynamic context and high economic uncertainty arising mainly from geo-

economic factors which are estimated to affect their implementation.

1. Leadership in the Mediterranean homeport cruise: Attract additional homeport cruise passengers

(as a port of departure) in order to create a significant benefit to the local economy. Support

the objective by strengthening non-port infrastructure.

2. Eastern Mediterranean Ship Repair Hub: Installation of a new Floating Dock and revival of ship

repairs attracting 350-450 ships per year as a result of the increased reliability and efficient

service.

3. Southern gateway to Chinese-European trade: Expansion of container terminal activities by

enhancing ocean lines and use to the extent of land interconnection with transit centers

(trains), attracting new Ro-Ro customers and expanding supply chain activities.

4. Passenger port for the whole of Greece: Maintaining the current level of activity and upgrading

the services provided through targeted investments (e.g. parking, dredging, commercial

activity).

Page 7 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

o Outward looking Strategy

Piraeus among the top 10 global ports in 2022 shipping index

Τhe Port of Piraeus ranked 9th internationally on the Xinhua-Baltic International Shipping Centre

Development (ISCD) Index. The ISCD Index provides an annual independent ranking of the performance

of the world’s largest cities that offer port and shipping business services based on three primary

dimensions -port infrastructure, shipping services and general environment- and 16 secondary

indicators to evaluate the comprehensive performance of 43 cities worldwide.

Strong Presence at Delphi Economic Forum 2022

PPA honored with a strong presence the 2022 Delphi Economic Forum, the flagship event gathering top

leaders from across sectors of politics, economy and society.

PPA’s BoD Chairman Yu Zenggang attended and esteemed top business and state leaders of the Greek

economy the panel discussion “Economic Cooperation Between China & the Region”. Mr. Yu Zenggang

highlighted the obvious successes as a result of the excellent cooperation and perfect interplay of the

two cultures, the Greek and the Chinese. The Port of Piraeus impressive ranking jump in recent years,

the many distinctions and awards in environmental and sustainability factors, but also the recent all-

time peak in the financial results of the company in all port activities are all indicators of the right

strategic framework and execution on a mutual benefit vision.

PPA S.A. proud Gold Partner of the Hellenic Olympic Team at the Beijing Winter Olympics

The Piraeus Port Authority, through the years a constant sponsor of Sports and an active supporter of

the Greek athletes, launches another major initiative, this time as a proud Gold Partner of the Hellenic

Olympic Team, in the Winter Olympic Games that took place in Beijing from 4 to 20 February 2022.

A farewell event for the athletes of the Greek delegation was held at the premises of the Hellenic

Olympic Committee, during which the exchange of cooperation documents between the Chairman of

the Piraeus Port Authority Mr. Yu Zenggang and the President of the Hellenic Olympic Committee Mr.

Spyros Kapralos took place, who thanked PPA and COSCO SHIPPING for their decision to become the

Gold Sponsor of the Greek delegation at the Winter Olympic Games in Beijing.

It is reminded, that in the same framework, the Group during a previous athletic year has been a proud

Major Sponsor of the Hellenic Paralympic Committee, supporting disabled athletes to fulfill their

dreams.

- Participation in National and International Forums

PPA S.A. remains strongly extrovert and actively participates in a series of national and international

maritime and maritime oriented/related organizations, trying not only to follow but also to contribute to

the developments taking place in the port industry. In the above framework, PPA S.A. participates in:

➢ European Sea Port Organization, by staffing the structures of the below technical committees:

- Marine Affairs,

- Cruise & Ferry Port Network,

- Trade Facilitation, Customs and Security,

- Port Governance,

- Sustainable Development,

- Economic Analysis and Statistics,

Page 8 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

- Multimodal, Logistics and Industry,

- Labor and Operation

➢ Hellenic Ports Association,

➢ Piraeus Chamber of Commerce and Industry,

➢ Chamber of Greek-Chinese Economic Cooperation,

➢ Association of Mediterranean Cruise Ports,

➢ Cruise Lines International Association (CLIA).

- Participation in international exhibitions

Important event of PPA S.A. in the context of the CIIE International Exhibition. The ESG Report 2021

was presented

PPA promoted the quality, professional and high level services of the Greek port industry at the online

presentation for its activities in issues of the environment, corporate governance and society which was

held in the framework of the China International Import Expo - CIIE in Shanghai.

At the beginning of the presentation, an extensive report was made of the very good financial results of

the Company in 2022 as well as of the investments that have been made. However, as mentioned, the

Company's goals are not limited to improving financial indicators, but also include:

– The development of business activities with respect to the environment

– The welfare of the employees

– The concern for dealing with climate change

– The reduction of CO2 emissions

– Energy efficiency and its energy transition according to the new energy production and storage data

and also the protection of water, the waste management and other.

– Digitalization.

Greece’s largest Port strong presence at Posidonia 2022 showcasing one stop hub capabilities for all

port services, delivering proven excellence in all.

PPA S.A. is setting the pace for the port industry with a strong presence at this year’s Posidonia, held at

Athens' Metropolitan Expo Centre from 6-10 June, showcasing PPA’s strong achievements for the Port

of Piraeus with the slogan “One stop hub for all port services, excellence in all”.

Following the opening ceremony held on the first day of the exhibition, the Prime Minister, the Minister

of Maritime Affairs and Insular Policy, the Chinese Ambassador to Greece, alongside other governmental

officials and press representatives visited PPA’s stand, where they received a warm welcome by PPA’s

Chairman Yu Zenggang and the company’s representatives. During their visit, the high ranking visitors

could take a close look at the diverse and holistic activities of the Port of Piraeus, comprising a range of

services such as cruise, ferry, container, passenger and car terminal services, as well as ship repair and

logistic services and finally the Land-Sea Express service turning the Port of Piraeus into a global

gateway.

Page 9 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Participation at the International Seatrade Cruise Global 2022 in Miami

PPA S.A. presented and promoted the Greek Cruise Industry at the global Seatrade Cruise Global 2022

event taking place from the 25

to 28

of April, as the Port of Piraeus is one of the leading cruise ports

in the Mediterranean Region and Europe. The Seatrade Cruise Global is one of the largest and more

significant cruise events in the industry in Miami, the leading cruise port in the world providing all

stakeholders an excellent platform for discussion and networking as well as of information exchange

around the newest updates in the industry.

PPA was represented by a delegation team at the booth of the National Tourism Organization together

with representatives of other Greek ports such as Thessaloniki and Corfu, the Region of Central

Macedonia and the South Aegean Region. During the event, P.P.A. appreciated the excellent feedback

received from leaders within the cruising industry, who already enjoy the holistic and high-end cruise

services and support provided at the Port.

C. Administration Principles

The management of the Company provides direction, leadership and an appropriate environment for its

operation to ensure that all its available resources are fully engaged in the achievement of its objectives.

The Company's policies at the stages of its productive and operational activity emphasize on

implementing procedures based on transparency and fairness, and establishing common principles and

rules, through the below principles:

Collectivity in decision-making

The function of the Administration Board, which supports and advises the other Company bodies in the

exercise of their responsibilities, is constituted by the Chairman of the BoD, the CEO, the Deputies and

Assistants to the CEO, ensuring better exchange of information, fuller exploration and better evaluation

of alternatives, consistency of the Management Team, increasing acceptance of the decision issued.

Segregation of Responsibilities

Clear distinction in the allocation of responsibilities through the assignment of specific duties at all levels

of the PPA hierarchy ensures the speed of decision making, the smooth operation of the business and

the subsequent effective control of all its actions.

On the basis of this principle, all members of the Company, according to their positions in the hierarchy

and qualifications, undertake specific responsibilities and are given the necessary authorities to carry

out the obligations arising therefrom.

Responsibility - Accountability - Liability

Responsibility - Accountability - Liability is vital to ensure high performance of the Company.

The Company's Management clearly communicates its expectations and sets out specific objectives to

the persons responsible for the execution of specific tasks and duties. Clear communication of

expectations and clearly defined goals are aimed at enhancing performance at all organizational levels

and structures of the Company.

Through the submission of continuous progress reports to the Management of the Company, the

organizational units of PPA S.A. are provided with the possibility to operate within the components of

the particular administration principle (Responsibility - Accountability - Liability), as well as to the

Company's Management to check its effectiveness.

Page 10 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Good Governance

The primary objective of the Company's Management is to increase its value and protect the legitimate

interests of all its shareholders. The PPA S.A.’s management bodies, in the exercise of their discretionary

powers, act in accordance with the rule of law in order to avoid unnecessary and unfair solutions. Good

administration, both as a principle and as a right, is a particularly useful "instrument" of the

Administration in order to ensure the trust of the persons who are managed and to firmly establish the

legal certainty and the legitimacy of its actions.

Audit - Transparency

For PPA S.A., adherence to market rules, participation in international standards of corruption

prevention and transparency enhancement, are commitments that are fully in line with its Values and

Principles, while at the same time demonstrate the degree of commitment to integrity practices and

Corporate Governance.

D. Internal Management Systems

Periodic Evaluation Policy of the Internal Control System of PPA SA and Implementation of the

provisions on Corporate Governance of Law 4706/2020

Key Elements

PPA SA having recognized the importance of the operation of an adequate and integrated Internal

Control System (hereinafter "ICS") for achieving its business objectives and in accordance with Law

4706/2020 regarding corporate governance and decision of the Board of Directors of the Hellenic

Capital Market Commission 1/891/30.09.2020 as in force from time to time, adopted a policy of periodic

evaluation of the Company's ICS as well as of the Implementation of the provisions on Corporate

Governance of Law 4706/2020.

The Company's ICS includes five (5) basic elements that exist and operate in the Company and are

described in general terms below:

i. Control Environment

The Company is committed to operate with integrity and ethical values. Its organizational structure

determines a specific position and specific and distinct responsibilities for each body and organizational

unit of the Company. There are specific benchmarks and areas of responsibility in achieving the

Company's goals, while a regulation is followed on the selection and recruitment of staff and senior

management as well as a remuneration policy aiming at attracting and retaining highly qualified human

resources.

ii. Risk Management

The Purpose of the Risk Management Function is to assist the Board of Directors regarding the

performance of its responsibilities on the management of operational risks. The above will be achieved

through the supervision, evaluation and the controlling by the Risk Management Function, the

supervision and the implementation through a risk management framework, which consists the suitable

response plans, taking into account the scope of activities, critical infrastructure and the complexity of

the organization.The Company clearly communicates its objectives in the individual Departments in a

simple and understandable way, so that they are taken into account during the process of risk

identification and risk assessment as well as its acceptable risk tolerance level.

Page 11 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

In general, the Top Management of the Company determines the way of responding to the risks by

categorizing them according to the probability and their impact on the operation of the Company in the

following categories:

• High risk: immediate actions required

• Increased risk: immediate actions required

• Acceptable risk: immediate actions required

• Low risk: no immediate action required

The recording of the potential risks faced by the Company as well as the management and risk response

procedures, is carried out in all operations of the Company on an annual basis. In case of emergency

reasons, an extraordinary assessment on selected departments, will take place. In addition, the

Company has established control mechanisms and safety valves to detect and/or prevent the inability to

deal with risks, in order to achieve its objectives.

Risk Management function

The Company has a Risk Management function, which operates in accordance with appropriate and

effective policies, procedures and tools (such as keeping a risk register) on the determination, analysis,

control (risk control matrix), management and monitoring of any kind of risk inherent to the operation

of the Company.

Based on the above, the implementation of KRI’s matrix for each PPA’s department, giving back an

“early warning” signal of risk.

iii. Controls Activities

The Company develops policies and procedures in accordance with the objectives of the Management.

In addition, it implements a system of safety valves, based on the risks it has identified, but considering

the specific characteristics of the Company. Special emphasis is placed on the adequacy, proper

implementation and monitoring of procedures, the handling of error cases and the frequency of

reassessment of policies and procedures.

In addition, the Company implements adequate safeguards for issues of conflict of interest, segregation

of duties as well as the governance and security of its Information Systems.

iv. Communication System

The Company ensures the quality of financial and non-financial information and follows appropriate

ways of internal and external communication, such as communication with the members of the Board of

Directors, shareholders and investors, communication with the existing Company committees,

complaint on whistleblowing, Regulatory Authorities etc.

v. Monitoring of the Internal Control System

The Company has mechanisms and functions that have as its objective the continuous evaluation of the

Internal Audit System and the reporting of findings to be corrected or improved.

Page 12 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Internal Orgazination and Operation Regulation (IOOR)

The updated Internal Operation Regulation (IOOR) of the Company is the Company's compliance with

the requirements of the applicable regulatory framework, as formulated, in particular, by Law

4706/2020 «Corporate governance of public limited companies, modern capital market, incorporation

into Greek legislation of Directive (EU) 2017/828 of the European Parliament and of the Council,

measures for implementation of Regulation (EU) 2017/1131 and other provisions» (Government

Gazette 136/17.7.2020), Law 4548/2018 "Reform of the Company Law (New legislation for Societe

Anonymes)" (Government Gazette A '104/13-06-2018), Law 3016/2002 "On Corporate Governance etc."

(Government Gazette A 110/17-05-2002) as in force today, the general provisions of the legislation

governing companies that have listed shares in the regulated stock market.

The Regulation came into force with the no. 32/2021 decision of the Board of Directors of the Company,

and as amended and codified by the decision no. 15/2022 of the Board of Directors, and its objective is

to reflect:

a) The organizational structure, the units’ objectives, the committees of article 10 L.4706/2020 or other

standing committees’ objectives, as well as the duties of their heads and their reporting lines.

b) The main characteristics of the Internal Control System, i.e. the Internal Audit Department and the

functions of risk management and regulatory compliance.

c) The process of hiring and evaluating Senior Executives.

d) The compliance procedure for persons holding managerial duties, as defined in number 25 of par. 1 of

article 3 of Regulation (EU) 596/2014, and the persons closely related to them, according to the

definition of par. 14 of article 2 hereof, which include the obligations deriving from the provisions of

article 19 of Regulation (EU) 596/2014.

e) The procedure for notifying the existence of dependent relations, in accordance with Article 9, of the

independent non-executive members of the Board of Directors and of the persons who have close ties

with these persons.

f) The procedure to comply with the obligations arising from articles 99 to 101 of Law 4548/2018,

regarding transactions with related parties.

g) The policies and procedures for the prevention and management of conflict of interest situations.

h) The policies and procedures of compliance of the Company with the legislative and regulatory

provisions that regulate its organization and operation, as well as its activities.

i) The procedure available to the Company for the management of privileged information and the

correct information of the public, in accordance with the provisions of Regulation (EU) 596/2014.

j) The policy and procedure for conducting periodic evaluations of the Internal Control System, in

particular as regards the adequacy and effectiveness of financial information, on an individual and

consolidated basis, as regards risk management and regulatory compliance, in accordance with

recognized standards of evaluation and internal control, as well as the implementation of the provisions

on corporate governance of this law. This evaluation is carried out by persons who have proven relevant

professional experience and do not have dependent relationships according to par. 1 of article 9.

Page 13 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

k) The training policy of the members of the Board of Directors, the Executives, as well as the other

executives of the Company, especially those involved in internal control, risk management, regulatory

compliance and information systems.

l) The sustainable development policy followed by the Company.

General Staff Regulation

The General Staff Regulation drafted as per the provisions of Law 1876/1990 and Article 10A (a) of Law

4404/2016 "Ratifying the amendment dated 24.6.2016 and codification into an integrated text of

Concession Agreement dated 13.2.2002 between the Hellenic Republic and Piraeus Port Authority S.A.

and other provisions".

The GSR is intended to regulate all employment relations, on the basis of the principles of equality and

transparency, with a view to ensuring the smooth and efficient operation of all Company Departments

and serving effectively the common interests of the Company and its staff.

Regulation of operation of Internal Audit Department

As a listed Company, the Company has an independent Internal Audit Department, the operation of

which is supervised by the Audit Committee.

Based on the Regulation of Operation of Internal Audit Department as approved by the Board of

Directors of the Company, the mission of the Internal Audit Department is to add value and improve the

operations of the Company, providing objective and risk-based assurance, advice, and insight. The

Internal Audit Department helps the Company to achieve its objectives, adopting a systematic,

professional approach to evaluating and improving the effectiveness of Risk Management, Internal

Control Systems, and Corporate Governance processes.

During the year 2022, the Internal Audit Department, submitted eleven (11) planned internal audit

reports according to the Annual Audit Plan and two (2)ad-hoc internal audit reports . Also, the Internal

Audit Department provided periodic reports for the work performed to the Audit Committee on a

monthly, quarterly and annual basis and to the BoD on a quarterly and annual basis.

After the proposal of the Institute for Internal Auditors Greece, PPA participated to its Annual

Conference, as a silver sponsor. The Conference was held in the context of the effort to improve the

professional development and training of its members and all those involved in Internal Audit, Risk

Management, Regulatory Compliance and Governance in general.

Members of the Internal Audit Department, as active members, have gained valuable knowledge and

practical tools they can apply to their work, while the principles, standards and best practices of the

industry in the private sector have been shared.

The sponsorship reflects the importance PPA attaches and interest in the fields of Internal Audit, Risk

Management, Regulatory Compliance and Governance.

Internal Complaint Process (ICP)

The Company maintains an Internal Complaint Process (ICP), which is described in the Code of Conduct

that has been approved by the Administration Board with the decision n. 1/17-1-2020.

As part of Good Governance Policy and respect to the company’s shareholders PPA SA sees every

complaint as an opportunity to assess business processes and improve them whenever possible.

Page 14 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

It is believed that the ICP will offer the chance to get feedback on the business activities/ operations and

will serve as a quick and efficient means of resolving any problems that may arise and will promote good

relations and communication between the Company and its employees. According to the ICP, a

complaint falls into the following (indicative) categories:

01. Fraud

02. Internal Policy / Regulation / Procedure Violation

03. Data Privacy Protection

04. Corruption / Bribery

05. Human Rights Issues

06. Issues regarding failure in services provided to clients

07. Issues regarding health and safety

08. Issues regarding rational resource management of the company

09. Issues regarding environmental protection and energy saving

10. Other

Should a complaint being made involves a member or members of the Board of Directors or the Audit

Committee, or the Administration Board, Internal Audit Department must immediately report the

complaint to the Audit Committee or to the Board of Directors respectively, which will forthwith direct

the investigations and necessary actions as appropriate.

On a monthly basis, the Internal Audit Department provides to Top Management (Chairman of the BOD,

CEO, Deputy CEOs, Assistant CEOs) information regarding the complaints it receives, the actions taken in

order to facilitate them and any proposed improvements that need to be implemented.

On an annual basis the Internal Audit Department provides to the Audit Committee a summary report of

the above work performed.

During 2022, two (2) complaints were submitted through the ICP, for which the approved procedures

were followed.

Certifications & Implementation of Standards and other requirements

Quality, Environmental & Energy Management Certification (ISO 9001:2015 - ISO 14001:2015 - ISO

50001:2018)

In 2022, the scope of the triple certification as per ISO 9001:2015, ISO 14001:2015 & ISO 50001:2018

standards for quality, environmental and energy management was renewed for the next three (3) years,

by certification body Lloyd’s Register Quality Assurance (LRQA) for all PPA activities.

This triple certification demonstrates the company’s commitment to best practice for quality,

environmental and energy management.

In 2022, with the renewal of the three (3) certifications, their expiry dates were alighed, thus providing

increased internal efficiency for their management and maintenance.

Through the Integrated Quality, Environmental & Energy Management System that is applied in line

with these three (3) standards’ requirements, PPA SA works in a consistent way to understand

customers’ needs and expectations, continually improve the level of services provided, address the

environmental challenges emerged in daily operation and improve the energy performance.

Page 15 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

According to PPA SA’s Quality - Environmental - Energy Policy, that is available on PPA SA official

website, the company is committed to improving the quality of the provided services, the environmental

and energy performance and setting quality, environmental & energy objectives to address risks and

opportunities, significant environmental aspects and significant energy uses. These objectives are

continuously monitored and reviewed.

Risks and opportunities are defined through systematic analysis of internal and external issues.

Significant environmental aspects are defined through assessment of the impact port activities pose or

may pose to the environment. Significant energy uses are defined through Annual Energy Reviews.

Also, internal inspections are conducted regularly and the top management, through the Management

Reviews, assesses the effectiveness of the Integrated Quality, Environmental & Energy Management

System, the achievement of the objectives set and supports actions to ensure continual improvement.

PPA SA through the certification as per these three (3) standards also contributes to the achievement of

UN Sustainable Development Goals.

Global Reporting Initiative (GRI) Standards for Corporate Social Responsibility Reporting

The Corporate Social Responsibility Report has been prepared in accordance with GRI standards.

AEOF license

PPA SA is an Authorized Economic Operator (AEOF/ Security and Safety). The relevant license facilitates

the implementation of customs procedures, providing a competitive advantage to PPA SA.

E. Major events of 2022

Infrastructure upgrade and reconstruction works at the Perama Ship Repair Zone at the Eastern side

of Pier II successfully completed

The works are part of the second phase of a broader infrastructure improvement project in the Perama

ship repair zone involving among others a complete platform replacement.

The maintenance works at the Piraeus I floating dock were both started and completed during the

second half of 2022. The scope of the project includes the replacement of nearly 400 tons of steel plates

& stiffeners, high-pressure hydro-blasting & anti corrosion painting in the ballast tanks and external

areas, as well as the maintenance and repair of pumps, valves, and piping systems. During the whole

period of special inspection and repair, the average number of workforce in dock and workshops

reached 150 per day, while directly driving the need of a large number of materials and relating

supporting business activities. In addition, this creates a large number of job and income opportunities

for local workers and relevant staff in the industry.

Overall, the systematic enhancement projects and the targeted investments at the Perama Ship Repair

Zone have already led to the desired outcomes. The large-scale investment projects started back in 2016

by COSCO SHIPPING GROUP, greatly contributed towards the revitalization of the Ship Repair industry in

the country. All ship repair operation indicators are improving on a year on year basis, while enabling

state of the art services, higher capacity solutions and higher safety standards.

Piraeus Port Authority (PPA) awarded three certifications against ISO 9001:2015, ISO 14001:2015

and ISO 50001:2011 by LRQA.

At a ceremony held during international shipping exhibition Posidonia, PPA S.A. awarded with

certifications of ISO 9001:2015 for Quality Management, ISO 14001:2015 for Environmental Management,

and ISO 50001:2018 for Energy Management, by Mr. Stuart Kelly, LRQA Global Sales Director, Business

Assurance. This demonstrates the company’s commitment to best practice for quality, environmental and

energy management.

Page 16 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Amongst the “Most Sustainable Companies in Greece 2022”

Following the announcement of the Quality Net Foundation, the Piraeus Port Authority has been

included in the List of the “Most Sustainable Companies in Greece 2022” as announced by the

Foundation’s Annual Evaluation Report measuring business performance in Sustainable Development

based on the ESG criteria. The inclusion of companies in the list of "The most Sustainable Companies in

Greece", provides the highest possible distinction in Sustainable Development in the country.

It is pointed out that the Piraeus Port Authority, fully aligned to the new world order, prioritizes and

incorporates in the company’s strategy every aspect related to the Environment, Society and Corporate

Governance (ESG), while satisfying investors’ and all stakeholders’ expectations.

F. Past performance, comments on Financial Statements and investments

F1. Past performance

International trade volumes depend on global economic conditions. The estimates of this year’s January

by the IMF

[1]

record a GDP increase of 0.7% in the Euro area and 2.9% worldwide. These estimates are

improved compared to the previous quarter mainly due to inflation restraints made in October 2022.

Estimates for 2022 record global GDP growth of 2.9%. The European Commission, in autumn 2022,

predicts that the economy of the zone will show a marginal increase of 0.3% in 2023 and 1.6% in 2024

[2]

However, it is noted that in the current environment of economic uncertainty created by the effects of

inflation and the geopolitical conditions in Eastern Europe, the estimates record significant variations

per quarter.

The Greek Economy registers significant resistance to the negative effects of imported inflation and the

GDP of 2023

[3]

is estimated to increase by 2.1% as recorded in the Budget proposal.

It is noted in November 2022 that the European Commission records for Greece an estimate of GDP

growth of 1.1% for 2023 and 2% for 2024.

[1] https://www.imf.org/-/media/Files/Publications/WEO/2023/Update/January/English/text.ashx [Accessed 1

Feb. 2023]

[2] https://economy-finance.ec.europa.eu/document/download/1a6a5006-02ae-40d2-b003-

a9630a2cbd62_en?filename=ip187_en.pdf [Accessed 1 Feb. 2023]

[3] https://www.minfin.gr/documents/20182/17982418/3-10-

2022++++%CE%9A%CF%85%CF%81%CE%B9%CF%8C%CF%84%CE%B5%CF%81%CE%B1+%CF%83%CE%B7%CE%BC

%CE%B5%CE%AF%CE%B1+%CF%80%CF%81%CE%BF%CF%83%CF%87%CE%B5%CE%B4%CE%AF%CE%BF%CF%85+

%CE%9A%CF%81%CE%B1%CF%84%CE%B9%CE%BA%CE%BF%CF%8D+%CE%A0%CF%81%CE%BF%CF%8B%CF%80%

CE%BF%CE%BB%CE%BF%CE%B3%CE%B9%CF%83%CE%BC%CE%BF%CF%8D+2023.pdf/1f9a9ceb-5093-48b6-9782-

6bc033f42198 [Accessed 1 Feb. 2023]

Page 17 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

F2. Comment on Financial Statements for the 2022

Revenues

The total revenues for the year 2022 amounted to € 194.6 million increased by 26.2% or € 40.4 million

(2021: € 154.2 million). The increase is mainly due to the significant increase of revenues from the cruise

sector,the container terminal and the car terminal sector by 85.2%, 35.2% and 23.8% or by € 8.1 million,

€ 10.4 million and € 3.4 million respectively, as well as to the increase of revenues from coasting sector by

20.3% or by € 1.9 million. Moreover, there was an increase by 18.0% or by € 12.6 million in the revenue

from the Pier II + III concession agreement with PCT . Finally in the shiprepair sector there was an increase

in revenues by 12.1 % or by € 1.6 million.

Cost and Expenses

The key operating costs mainly relate to the payroll costs which in 2022 did not show a significant

variation and amounted to € 58.0 million compared to € 58.5 million in 2021 (Note 29).

In regard to the remaining operating costs, except for payroll costs, they remained consistent to the prior

year figures except for the following:

A significant increase was noted in "Third Party Services" by € 3.6 million, due to the increase in the

Company’s electricity charges as well as in "Third Party Fees and Expenses" by € 1.2 million, mainly due

the use of external partners by the Company.

The "Greek State Concession" fee presented an increase during the current year, by € 1.4 million

(31.12.2022: € 3.5 million compared to 31.12.2021: € 2.1 million) which is mainly due to the increase in

revenues of the period compared to the fiscal year 2022 (Note 25).

Provisions for legal cases decreased significantly which during the current year amounting to € 0.2 million

and were reversed or used provisions amounting to € 2.1 million mainly due to legal cases which were

ruled in Company’s favor. During the previous year, provisions of € 4.4 million were recorded (Note 18

and Note 25).

There was a decrease in the consumption of materials by 14.3% which in the current period amounted to

€ 2.4 million while in the previous year was € 2.8 million.

Depreciation did not show a significant change during the current period, amounting to € 18.3 million

(31.12.2021: € 17.9 million) (Note 28).

Other Operating Income/Expenses

Other operating income for the current year showed a small change compared to the previous year

amounting to € 0.8 million (31.12.2022: € 5.5 million compared to 31.12.2021: € 4.7 million). In the

current year an increase was noted in rental income by € 1.0 million, which was offset by the decrease in

revenues by insurance compensation by € 0.1 million as well as in rental subsidy due to Covid 19 by € 0.1

million which was collected during the previous year (Note 26).

Other operating expenses for the period amounted to € 16.8 million compared to the corresponding

period of 2021 (€ 0.6 million) presented a significant increase amounting to € 16.2 million. This increase is

due to the increase of prior years’ income tax fines and penalties related to differences in tax audit for

the year 2016 amounting to € 6.4 million (Note 9) as well as to the diferrence related to the calculation of

employees withheld income tax for the years 2016-2018 amounting to € 1,4 million. In addition, a

significant increase was noted to third party compensation, which relate mainly to a compensation paid

to a supplier in accordance with a relevant decision of an arbitral tribunal, as well as to interest

compensation according to court decisions finalized against Company (Note 26).

Page 18 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Financial Expenses

In financial expenses during the current year a decrease was noted (31.12.2022: € 2.6 million instead of €

3.3 million in 31.12.2021), which is mainly due to a corrective commission amount for the years 2016 to

2022 amounting to € 0,8 million (Note 27).

Net impairment losses on financial assets

The net impairment loss on financial assets showed a decrease during the current year and amounted to

€ 0.4 million (31.12.2021: € 0.9 million).

Total Assets

Total assets at December 31, 2022 amounted to € 573.4 million, increased by 9.0 % or € 47.2 million

(31.12.2021: € 526.2 million).

The increase in total assets was mainly due to the following sub-items, namely:

• increase in cash and cash equivalents by € 36.6 million

• increase of the unamortized balance of tangible property, plant and equipment by € 10.7 million (due

to the additions € 27.7 million of the year reduced by € 16.3 million current year depreciation and

net value of write-offs-sales/transfers to intangible property, plant and equipment by € 0.8 million).

• increase in other long-term receivables by € 4.7 million mainly due to an additional advance payment

amounting to € 4.8 million for the implementation of additional future works.

This increase was mainly offset by:

▪ decrease of the deferred tax asset by € 3.4 million (Note 9)

▪ decrease in right of use assets by € 2.0 million due to the current year depreciation.

Total Liabilities

Total liabilities as at 31.12.2022 amounted to € 258.9 million increased by € 8.9 million (31.12.2021: €

250.0 million) .

The change in total liabilities was mainly due to the following:

• increase in income tax payable by the amount of € 7.5 million.

• increase in accrued and other liabilities by the amount of € 10.4 million (Note 21).

• increase in suppliers by the amount of € 2.2 million.

• increase in other long term liabilities by the amount of € 0.2 million.

• decrease in bank debt by € 6.0 million due to the repayment of four installments of the long-term

loan.

• decrease in the provisions for legal cases by the amount of € 1.9 million (Note 18).

• decrease in deferred income by € 1.3 million (Note 22)

• decrease in short-term and long-term lease liabilities by € 1.1 million (Note 5), due to the current

year payments of € 3.7 million, finance cost € 2.4 million and additions of € 0.2 million

• decrease in provision for staff leaving indemnities by € 0.2 million (Note 17).

• decrease in grants by the amount of € 0.9 million due to the current period’s depreciation.

Page 19 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

F3. Investments

The implementation of investment plan is to strengthen the financial position and sustainable

development of the Company. It will benefit also to the local economy by creation job opportunity and

bring tax contribution to the national economy. According to the Concession Agreement, the mandatory

investment of the Company is around € 293.8 million of Reference Cost and the additional investment is

budgeted around € 167.0 million of Reference Cost. Until end of 2022, the accumulated contracted

amount for the above investment is € 250.5 million with the reference cost of € 278.6 million in total,

94.8% of total reference cost.

The accumulated investment amount by end of December 2022 for the above contracts for mandatory

investments have been made around € 133.4 million which can be split into completed project € 68.0

million, projects under construction € 60.0 million and prepayments of € 5.4 million.

Apart from the above, the Company completed some additional investments as maintenance

infrastructure of the port with the amount of € 8.4 million.

Page 20 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Page 21 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

2. Principal Risks Analysis and Risk Management

A. Monitoring the supply chain with reference to the main suppliers and their cooperation rules

There are no suppliers, the interruption of which would jeopardize the operation of the Company in

the event of a temporary failure of supplies provision.

B. Other risks that are related to the activity or sector that the company is operating.Risk of loss of

assets

- Risk of property loss

The Company takes all necessary measures to minimize the risk and possible losses of assets due to

natural disasters or similar related causes.

- Property insurance

PPA S.A. has insured all its assets in accordance with the provisions of Article 17.1 of the CA with the

Greek State for the following indicative but not limited to perils:

Fire, lightning, explosion, storm damage, aircraft crashes and named perils or Property All Risks, based

on new replacement cost of asset.

The income loss due to disaster-related closing / business interruption of the business facility or due to

the rebuilding process after a disaster, i.e. storm, earthquake, flood, strikes, riots and terrorist actions,

has been insured.

- Third Party Liability and Employer’s Liability

PPA S.A. maintains insurance in respect of third party liability in accordance with the provisions of

Article 17.1 of the CA with the Greek State for all its activities.

- Maximum Probable Loss (MPL) analysis

According to the requirements of the provisions of Art. 17 and Annex 17.1 of the CA, the company is in

the process of finalizing the Maximum Probable Loss (MPL) analysis.

The respective contract has been signed with a specialized consulting firm in the field of risk insurance.

Currently data collection has been completed and MPL analysis performed by the awarded consulting

firm is in progress. The updated first draft has been submitted and the MPL is under insurance

coverage.

The MPL analysis includes as a minimum the following elements:

1. Estimation of Maximum Probable Property Loss and loss of income for normal risks, excluding

natural disasters (such as earthquakes, tsunamis, etc.).

2. Estimation of Maximum Probable Property Damage and Loss of Revenues in Disastrous Risks, and in

particular in the event of an earthquake.

3. Risk Accountability Quotient that will analyze and quantify the probable scenarios of liability losses,

including environmental liability, under the worst-case scenario.

- Business Risks Associated with the Company's business activities

A detailed report on the main risks associated with the sector in which the Company operates is set

out in Chapter of the Non-Financial Report, which follows (Risk Policy and Risk Management / Major

Business Risks and Uncertainties).

Page 22 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Financial Instruments

Fair Value: The carrying amounts reflected in the accompanying sheets of financial position for cash and cash

equivalents, trade and other accounts receivable, prepayments, trade and other accounts payable and

accrued and other current liabilities approximate their respective fair values due to the relatively short-term

maturity of these financial instruments.

The fair value of variable rate loans and borrowings approximate the amounts appearing in the statements of

financial position.

The Company categorized its financial instruments carried at fair value in three categories, defined as

follows:

Level 1: Quoted (unadjusted) values from active financial markets for identical negotiable assets or liabilities.

Level 2: Other techniques for which all inflows that have a significant impact on the recorded fair value are

identified or determined directly or indirectly from active financial markets.

Level 3: Techniques that use inflows that have a significant impact on the recorded fair value and are not

based on quoted prices from active financial markets.

During the years ended December 31, 2022 , there were no transfers between Level 1 and Level 2 fair value

measurements, and no transfers into and out of Level 3 fair value measurements.

As at December 31, 2022 and 2021, the Company held the following financial and non financial instruments:

December 31, 2022 Level 1 Level 2 Level 3 Total

Financial assets

Investment property - - 5,578,000.00 5,578,000.00

December 31, 2021 Level 1 Level 2 Level 3 Total

Financial assets

Investment property - - 5,580,000.00 5,580,000.00

Financial risk management:

The financial risks related to the Company and their respective management are as follows:

Credit Risk: There is no significant credit risk for the Company towards the contracting parties, since it

receives advance payments or letters of guarantee from customers. In addition, the Company's deposits are

placed in bank financial institutions in Greece with the following ratings (Moody's credit rating):

December 31, December 31,

2022 2021

Β1 170,682,700.95 Β2 102,383,876.42

Β2 816,687.84 Β3 32,775,682.28

Total 171,499,388.79 135,159,558.70

Page 23 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Foreign Exchange Risk: The Company is neither involved in international trade nor has any long term loans

in foreign currency and therefore is not exposed to foreign exchange risk resulting from foreign currency

rate variations.

Interest rate risk: The Company’s borrowings consist of two loans in Euro and one is subject to fixed

interest rate and the other one to floating interest rate (Note 19). The Company does not use derivatives in

financial instruments in order to reduce its exposure to interest rate risk fluctuation as at the balance-sheet

date. The Company management believes that there is no significant risk resulting from a possible interest

rate fluctuation.

Following the ECB's decisions to proceed with interest rate increases after 11 years, and while due to the

increase in inflation, new interest rate increases are possible in order to achieve the objective of 2%

inflation in the medium term, the Management is closely monitoring the evolutions in the current period

and considers that the risk from the change in interest rates has increased compared to previous years.

However, the Company's management does not consider that this increase will have a significant impact on

its borrowing costs and its creditworthiness or its financial results, as the Company is not significantly

exposed to bank borrowing, and especially to the risk interest rate fluctuations. Additionally, in the context

of the more effective managing of its assets as effectively but also to the limitation of any potential impact

of increased borrowing rates on its results, the Company's management, taking advantage of its strong

liquidity, has begun evaluation procedures for potential reinvestment opportunities, considering the

increased deposit rates. The Company's management believes that there are no significant risks from a

possible change in interest rates.

The table below presents and analyses the sensitivity of the result in relation to financial assets (cash on

hand and in banks) and financial liabilities (loans) of the Company to the interest rate risk changes assuming

a simultaneous change in interest rates by ± 100 basis points on the Company’s profit.

2022 Decrease (Increase)

Financial assets Accounting values +100bips(Euribor) -100bips(Euribor)

Cash and cash equivalents

171,535,343.22 1,715,353.43 (1,715,353.43)

Effect before income tax

1,715,353.43 (1,715,353.43)

Income tax 22%

(377,377.76) 377,377.76

Net effect

1,337,975.67 (1,337,975.67)

Financial liabilities

Long term loans

(38,499,999.99) (385,000.00) 385,000.00

Effect before income tax

(385,000.00) 385,000.00

Income tax 22%

84,700.00 (84,700.00)

Net effect

(300,300.00) 300,300.00

Total net effect

1,037,675.67 (1,037,675.67)

2021 Decrease (Increase)

Financial assets Accounting values +100bips(Euribor) -100bips(Euribor)

Cash and cash equivalents

134,975,285.73 1,349,752.86 (1,349,752.86)

Effect before income tax

1,349,752.86 (1,349,752.86)

Income tax 22%

(296,945.63) 296,945.63

Net effect

1,052,807.23 (1,052,807.23)

Financial liabilities

Long term loans

(44,499,999.99) (445,000.00) 445,000.00

Effect before income tax

(445,000.00) 445,000.00

Income tax 22%

97,900.00 (97,900.00)

Net effect

(347,100.00) 347,100.00

Total net effect

705,707.23 (705,707.23)

Page 24 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Liquidity risk: The effective management of liquidity risk is ensured by maintaining sufficient cash and the

availability of financing in case of need. Corporate liquidity risk management is based on the proper

management of working capital and cash flows.

The following table summarizes the maturity dates of the financial liabilities of 31 December 2022 and 2021

respectively, arising from the relevant contracts at unpaid prices.

Amounts of fiscal year 2022 Current portion

Less than

6 months

6-12 months 1 to 5 years >5 years Total

Borrowings - 3,496,453.75 3,456,534.58 26,215,186.67 8,713,215.83 41,881,390.83

Lease liabilities 4,624.60 3,520,579.48 9,000.00 14,000,000.00 87,937,500.00 105,471,704.08

Trade and other payables* 12,752,159.07 11,844,765.75 4,876,319.15 - - 29,473,243.97

Total 12,756,783.67 18,861,798.98 8,341,853.73 40,215,186.67 96,650,715.83 176,826,338.88

Amounts of fiscal year 2021 Current portion

Less than

6 months

6-12 months 1 to 5 years >5 years Total

Borrowings - 3,031,400.42 3,029,374.58 24,162,066.67 14,536,464.99 44,759,306.66

Lease liabilities 3,496.15 3,515,530.77 10,346.15 14,000,000.00 91,437,500.00 108,966,873.07

Trade and other payables* 6,653,055.85 8,301,662.10 4,022,595.27 - - 18,977,313.22

Total 6,656,552.00 14,848,593.29 7,062,316.00 38,162,066.67 105,973,964.99 172,703,492.95

* Trade payables do not have interest and are settled in up to 60 days. Other payables also do not bear any

interest and are settled in up to 12 months.

Capital Management

The primary objective of the Company's capital management is to ensure the maintenance of high credit

rating, and healthy capital ratios in order to support and expand the Company's operations and maximize

shareholder value. The Company's policy is to maintain leverage targets, according to an investment grade

profile. The Company monitors capital adequacy using the ratio of total debt to operating profits, which

should be lower than 9.80 based on the loan agreements (Note 19). The debt includes interest-bearing

loans and lease liabilities, while the operating profit includes profit/(loss) before taxes, financing costs and

depreciation.

2022 2021

Long-term borrowings 32,499,999.99 38,499,999.99

Short-term borrowings 6,000,000.00 6,000,000.00

Lease liability (long-term/short-term) 64,307,226.11 65,435,982.72

Total Debt (including lease liabilities) 102,807,226.10 109,935,982.71

Earnings before interest, tax, depreciation and amortization (EBITDA)

95,566,069.35 70,304,423.14

- Total Debt / EBITDA 1.08 1.56

December, 31

Page 25 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

3. Environmental issues

The Company recognizes both its obligations to the environment and the need for continuously

improvement for its environmental performance so as to achieve a balanced economic development in

harmony with environmental protection.

A. Actual and potential impacts on the environment

The actual and potential impacts on the environment caused by the operation and activities of PPA S.A.

are assessed in the approved Environmental Impact Assessment Study of PPA S.A. The company has in

force an Environmental Terms Decision, approved by the Ministry of Environment & Energy, and cares

for the correct and full implementation of these Environmental Terms in order to ensure the prevention

and reduction of the impacts on all the environmental parameters. The No 94701/5991/11-12-2020

Environmental Terms Decision of PPA SA was issued regarding the renewal and modification of the

environmental licensing of all the activities and projects of PPA SA and is valid for 15 years.

B. Notification of the Procedures implemented for the prevention and control of pollution and the

environmental impacts by various factors

In the context of the environmental management system it applies, PPA S.A. has elaborated and

implemented specific environmental policy, procedures of implementation and monitoring of

environmental parameters associated with all the activities, while it aims at continuous improvement of

its environmental performance, following the European and international standards with aim the

protection of the environment and the conservation of the natural resources for future generations.

Thus, Piraeus port is committed to the principles of the ESPO Green Guide and establishes objectives

and targets to achieve improvement of its environmental performance.

Taking into consideration all the above and in accordance with the Environmental Terms of port’s

operation, PPA S.A. has developed and implements the following procedures for the prevention and

control of pollution and environmental impacts:

• Environmental quality monitoring Program on acoustic environment. PPA S.A. implements, in

collaboration with external specialized consultants, an integrated noise monitoring programme,

covering the entire port area and focusing on the reduction of noise levels from sources related

to container terminal operations, construction works, vehicles movements etc. The Lden

indicator is measured and monitored throughout the entire port area of PPA S.A. twice a year.

The program includes eight (8) locations of 96-hour environmental noise measurement, four (4)

locations of 24-hour traffic measurement and the three (3) permanent noise Monitoring

Stations. The permanent stations were co-financed through the participation of PPA in the

European Programs PIXEL and GREEN C PORTS.

• Air quality monitoring Program. Since 2009, PPA S.A. has been implementing, in cooperation

with the National Technical University of Athens, an integrated program for the monitoring of

air pollution through a specialized monitoring station in order to identify, assess and quantify

the gas emissions of the port and to develop appropriate actions and operational techniques for

protecting and improving air quality in the port area. The parameters recorded and monitored

are: NOx, SO2, CO, heavy metals, PAHs, PM

particles, PM

2.5

particles, BTEX hydrocarbons. The

Program was recently strengthened with three (3) additional permanent air pollution

Monitoring Stations, which were co-financed through the participation of PPA in the European

PIXEL and GREEN C PORTS Programs.

Page 26 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

• Sea water quality monitoring Program. PPA S.A. in cooperation with the laboratory of Sanitary

Technology of Civil Engineering School of National Technical University of Athens (NTUA) applies

a seawater quality monitoring program to the entire port area and finds, where applicable,

corrective measures. The sampling frequency is twice a year in twenty (20) positions each time.

• Marine Sediments Quality Monitoring Program. PPA S.A. in cooperation with the laboratory of

Sanitary technology of Civil Engineering School of National Technical University of Athens

(NTUA) applies a quality monitoring program of marine sediments to the entire PPA S.A.

jurisdiction. The sampling frequency is twice a year in ten (10) positions each time.

• Integrated waste management system produced on land installations. PPA S.A. implements

since 2009 a special management system to enhance recycling, to reduce the quantities led to

final disposal at landfills and to enhance the production of environmentally friendly materials,

where applicable. The main waste streams that are recycled are paper, glass, packaging, empty

ink cartridges & toners, used batteries and accumulators, waste of electrical and electronic

equipment, lubricant oils, tires, wood waste, operational waste by workshops, operational

waste of floating and dry docks, scrap and metal waste etc.

• Ship-generated Waste Management Plan, approved by the Ministry of Shipping.PPA SA

implements a special, approved by the competent Ministry, Plan since 2008 for ship- generated

waste and cargo residues in accordance with the respective European Directive, the provisions

of the International Convention on Marine Pollution and MARPOL 73/78. According to this Plan,

a port Waste Reception System has been set up for the collection and management of solid and

liquid ship- generated waste by specialized contractors. To date, there have been no complaints

from a ship about the inadequacy of the services provided.

• Contingency plan of land and sea pollution incidents, approved by the competent Ministry. PPA

SA has a special Plan for dealing with incidents of pollution from oil and other harmful

substances both in the marine area and on land (piers) in the port area of its competence, while

with a specialized contractor takes care of the daily cleaning of marine waters.

• PPA S.A. is certified according to ISO 14001: 2015 for Environmental Management by Lloyd’s

C. Reference to the development of green products and services where exist

PPA SA recognized the need to reduce resource consumption and in particular energy savings

throughout the port sector. PPA SA highlights the issue by promoting initiatives and behaviors to

improve the balance of the demand and supply of energy and to reduce energy consumption.

In this context, PPA S.A. has installed and operates since August 2016 a photovoltaic power plant

producing up to 430 kWp by using solar panels. The photovoltaic plant is connected to the electricity

system of DEDDIE S.A. (Administrator of the Greek Electricity Distribution Network).

Page 27 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

4. Labor issues

Promoting equal opportunities and protecting diversity are key principles of the Company. Management

does not discriminate in recruitment / selection, pay, education, job assignment or any other work

activities. The factors that are exclusively taken into account are person's experience, personality,

theoretical training, qualifications, efficiency and abilities.

The Company is in favor of respecting the diversity of each employee and does not accept behaviors

that may discriminate in any form whatsoever.

A. Policy of diversification and equal opportunities (regardless of gender, religion, disadvantage or

other aspects).

Liable to article 11 b of GSR, the Company, as employer, is: applies the principle of equality in all

respects in its employment relations, including the equal treatment of male and female employees.

At 31/12/2022 PPA S.A. employed 962 employees. From this staff:

- 140 (14.55%) were women and 822 (85.45%) men

- 809 employees (84%) covered by collective labor agreements,

- 179 employees worked on individual contracts (Company Executives, Managers, Deputy Managers,

and Assistant Managers, Employees, etc.).

- 2 were trainee lawyers, 3 were employed on a project contract basis and 1 was an internship.

In addition, there were 23 employees under labor contract of private law for a fixed period.

The gender difference in the Company's staffing is mainly attributable to the labor-intensive

characteristics of the main work items of PPA S.A. (dockworkers, operators, lifting equipment operators,

heavy-duty drivers). In the 2022’s recruitment announcements there were no gender exclusion criteria.

Of the 150 employees assigned in responsibility positions on various tiers of the company's hierarchy

(manager, deputy manager, assistant manager, head of sector, superintendent, supervisor), 111 (74%)

were men and 39 (39%) were women.

The women participation among manager, deputy manager, and assistant manager positions reached

32.65%.

B. Respect for employees' and trade union rights

Respect for employees rights

The Company respects the rights of employees and observes the Labor Legislation. In the year 2022, no

control body accused the Company for violations of labor law.

Page 28 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Trade union rights

The Company, as employer, is liable to (articles 11 e, f, g of GSR):

- Ensure that the trade unions of its employees are regularly informed of all staff-related matters

and of the Company's business activities in general, where those have an impact on

employment relations;

- Not intervene in any manner in the legitimate trade union activities of employees;

- Promote interactive discussion with the representatives of employees, especially with any first-

degree and second-degree trade unions representing its employees in the context of collective

autonomy and informed dialogue.

Also, under Article 14.7 of the GCF, provision is made for discharge of their regular work duties

throughout their tenure (depending on the number of members) during their term of office to

members of trade unions.

Labor legislation

The Company, as employer, is liable to (article 11 a of GSR) comply consistently with all labor

regulations and all individual and Collective Labor Agreements applicable to its staff.

C. Health & Safety

Safety at work for employees is a top priority and a prerequisite for the operation of the Company.

Health and Safety Committee Establishment

Company employees have established a Workers’ Health and Safety Committee (W.H.S.C.), consisting of

their elected representatives in the company.

1. W.H.S.C. or the representative is a consultative body and has the following responsibilities:

(a) studying the company working conditions, proposes measures to improve the working conditions as

well as the working environment, monitors compliance with health and safety measures and contributes

to their implementation by employees,

(b) in cases of serious labor accidents or related incidents, proposes appropriate measures to prevent

recurrence,

address it, by participating in this way in the formulation of company's policy for occupational risk

prevention,

(d) is informed by the management of the occurring occupational accidents’ and occupational diseases’

data,

(e) is informed for the introduction of new production processes, machinery, tools and materials to the

company, or the operation of new installations, insofar as they affect health and safety,

(f) in the event of immediate and serious risk, invites the employer to take the appropriate measures,

without excluding the disruption of the machinery or the installation or the production process,

(g) may seek the assistance of experts on Workers’ Health and Safety Matters, with the agreement of

the employer.

Page 29 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Health and safety conditions

The Company, as employer, is liable (article 11.c of GSR) to take all necessary steps to ensure health and

safety at the workplace.

The Company is liable to ensure proper health and safety conditions for all employees and installations

under its responsibility. For that purpose, it is liable to apply proper health and safety rules by means of

special safety regulations, circulars, announcements and instructions. In particular, the Company is liable to

(article 12.3 of GSR):

1. Ensure, carry out and supervise, through its duly authorised bodies, the implementation of all

preventive, operational or corrective measures and procedures necessary to ensure safe execution of all

Company operations;

2. Train its staff to promptly identify all risks and handle same efficiently, in line with the applicable safety

procedures;

3. Keep the staff thoroughly informed of all applicable regulations establishing minimum health and safety

standards at the workplace, as in force from time to time.

Safety Engineer

The company has two Safety Engineers, in accordance with the applicable Legislation, who provide

indications and advices to the employer, in matters concerning the safety of employees and the prevention

of working accidents (article 14 of Law 3850/2010)

Occupational Physician

The company has Occupational Doctors, in accordance with the applicable Legislation, who provides

indications and advices to the employer, employees and their representatives, regarding the measures to

be taken for the physical and mental health of employees. (article 17 of Law 3850/2010).

D. Training systems, promoting staff ways, etc.

Education and training programs

The Company, as employer, is liable to ensure, within its powers, that the employees gain all professional

knowledge and are offered good opportunities to develop their skills and maximize their efficiency, to the

benefit of the Company but also for the development of their own career and personality.

Staff training is one of the Company's development objectives, which improves the quality of the services

rendered by the Company and the Company's overall productivity. In this context, the Company plans and

subsidizes staff training programs, either on its own or in cooperation with third-party educational/training

organizations. The staff shall participate in these programs at Company's cost.

Employee's career development

According to article 7.1 of GSR each employee's career development depends primarily on their:

1. Professional experience and scientific expertise;

2. General performance while on duty, primarily in terms of efficiency, initiative and responsibility;

3. Planning and coordination skills;

4. Role in improving the efficiency of inferiors and encouraging them to improve their working

performance;

5. Ongoing training, primarily attendance of educational/training seminars and involvement in

projects or studies relating to their work post.

Page 30 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

5. Financial and Non-Financial performance indicators.

A. Financial indicators and Alternative Performance Measures (APM’s)

Financial indicators showing the Company's financial position are presented in the table below:

Financial Structure ratios

31/12/2022 31/12/2021

1. Current assets 195,200,731.58 158,012,453.33

Τotal assets 573,363,875.66 526,175,272.31

2. Total equity 314,495,516.16 276,169,642.65

Total liabilities 258,868,359.50 250,005,629.66

3. Total equity 314,495,516.16 276,169,642.65

Non-current assets 378,163,144.08 368,162,818.98

4. Current assets 195,200,731.58 158,012,453.33

Current liabilities 67,932,099.18 47,689,071.95

5. Borrowings 38,499,999.99 44,499,999.99

Total equity 314,495,516.16 276,169,642.65

Performance and efficiency ratios

31/12/2022 31/12/2021

6. Profit before income taxes 74,664,659.74 49,210,993.70

Revenue 194,567,342.48 154,189,971.98

7. Profit before income taxes 74,664,659.74 49,210,993.70

Total equity 314,495,516.16 276,169,642.65

8. Gross profit 111,033,669.55 76,814,354.80

Revenue 194,567,342.48 154,189,971.98

9. EBITDA 95,566,069.35 70,304,423.14

Revenue 194,567,342.48 154,189,971.98

23.74%

17.82%

57.07%

49.82%

49.12%

45.60%

287.35%

331.34%

12.24%

16.11%

38.37%

31.92%

34.04%

30.03%

121.49%

110.47%

83.16%

75.01%

The Company uses as Alternative Performance Measures (“APMs”) the ratios No 4, 5 and 9, in the context

of making decisions concerning its financial, operational and strategic planning, as well as assessing and

publishing its performance. These APMs help better understand the Company’s financial and operating

results, financial position and cash flow statement. Alternative performance measures (APMs) must always

be taken into account in combination with the financial results prepared in accordance with International

Financial Reporting Standards (“IFRS”) and will not replace the latter under any circumstances.

Page 31 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

B. Non-financial performance indicators

Non-financial performance indicators of PPA S.A. operating activities are set out in the Non-Financial

Report below.

6. Activity of the Company in the field of research and development

PPA SA actively participated in 2022 in the field of research and development, implementing synergies with

entities from Greece and abroad and developing initiatives in the direction of the development of new

technological applications and innovative processes that create new horizons of development and

optimized operation, ensuring the competitiveness and participation of port of Piraeus in the relevant

decision making.

PPA SA with its participation in co-financed development projects supports and promotes practices and

investments in green technologies, in the use of alternative fuels and in environmentally sustainable

operations aiming to fulfill the objectives of the European Fit for 55 initiative, at environmental

sustainability and social well-being.

In 2022, PPA S.A. participated as a partner or coordinator in seven (7) European research and development

co-funded projects, which continue to be under implementation in 2023, details of which are shown in the

table below:

Program

Name of

project

Full Name

Budget for

PPA

Co-funding rate

CEF

EALING

European flagship action for cold ironing in ports

€ 191,219

50%

ADRION

SUPER-LNG

Plus

SUstainability PERformance of LNG-based maritime

mobility Plus

€ 20,118

85%

ADRION

MultiAPPRO

Plus

Multidichiplinary approach and solutions to

development of intermodal transport in region Plus

€ 21,700

85%

Η2020

D4Fly

Detecting Document frauD & iDentity on the fly

€ 111,125

100%

CEF

GREEN C

PORTS

Green and Connected Ports (GREEN C PORTS)

€ 455,500

50%

H2020

ARSINOE

Climate Resilient-Regions Through Systemic

Solutions and Innovations

€ 497,500

70%

CEF

CIPORT

Cold Ironing in the Port of Piraeus: Taking the Final

Step

€ 170,000

50%

Page 32 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Within 2022, ten (10) European research and development co-funder projects were submitted for funding,

with PPA SA participating as a partner or coordinator and whose assessment is expected in the first

semester of 2023. Details of the submitted proposal are shown in the table below:

Program

Name of project

Full Name

Budget for PPA

Co-funding rate

CEF

JUST-IN-TIME

PORTS (*)

Just In Time Arrivals and Port Call

Synchronisation of Ships with Sea Traffic

Management in European Ports

€ 530,000

50%

CEF

SSEPP (*)

Shore side electricity infrastructure in

the port of Piraeus

€ 15,634,615

85%

CEF

SMILE (*)

Sustainable Multimodal digital

Interoperability in ports and Logistic

Environments

€ 630,000

50%

HORIZON

TRIERES

H2 VALLEY

Towards the development of a hydrogen

valley demonstrating applications in an

integrated EcoSystem in Greece

€ 705,500

70%

HORIZON

SYSTEMIC

A Collaborative Framework for

Regulatory Systemic Supply-Chain Risk,

Vulnerability and Incident Management

of Large-Scale, Cross-Sector and Cross-

Border Digital Infrastructure

€ 174,375

70%

HORIZON

CASTRO-MAR

Underwater Screening framework for

enhanced Security of ports and

Maritime transport

€ 120,000

100%

INTERREG

EURO-MED

COM4PORTS

Towards the enhancement of

competences supporting the sustainable

& green management of Mediterranean

ports

€ 304,900

80%

INTERREG

EURO-MED

TREASURE

Testing pollution reduction measures in

and around Mediterranean ports

€ 325,160

80%

INTERREG

EURO-MED

RENEWPORT

Harnessing Renewable energy potential

for clean energy transition of MED Ports

€ 319,800

80%

LIFE2027

GREENLIFE4SEAS

Green Engineering solutions: a new LIFE

for Sediments and Shells

€ 258,403

60%

(*) They were submitted in 18/1/2023

Page 33 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

7. Non-Financial Information Report

A. Description of PPA S.A. Business Model

In addition to the Report of the Board of Directors entitled "Development & performance of the Company"

and the brief description of the business model that has taken place, the following are stated:

A1. Evolution of Piraeus Port Authority S.A. (PPA)

PPA is the legal entity entrusted with the administration and operation of the Port of Piraeus. It was

established as a legal entity of public law by virtue of Law 4748/1930, which was restated by Compulsory

Law 1559/1950 and ratified by Law 1630/1951, each as subsequently amended and supplemented. In 1999

PPA was transformed into a stock corporation (société anonyme). Pursuant to the enabling provisions

contained in the thirty-fifth article of Law 2932/2001 (Government Gazette A’ 145/27.7.2001), the Hellenic

Republic and PPA entered into a concession agreement on 13 February 2002 (2002 HRCA). In the 2002

HRCA, the Hellenic Republic granted PPA the exclusive right of use and exploitation of the land, buildings

and infrastructure comprising the Port of Piraeus, for an initial term of forty years, and subject to further

terms and conditions. Certain amendments to the 2002 Agreement, including the extension of the

concession’s term by ten years, were authorised on behalf of the Hellenic Republic by virtue of a joint

ministerial decision on 19 November 2008 (Government Gazette B’ 2372/21.11.2008). These amendments

were agreed upon in an addendum to the 2002 Agreement executed between the Hellenic Republic and

PPA on 18 November 2008 (the 2008 HRCA). The 2002 Agreement, as amended by the 2008 Addendum

(together the Old Concession Agreement), was subsequently ratified by virtue of the first and third article

of Law 3654/2008 (Government Gazette A’ 57/03.04.2008).

In April 2016, following an open international public tender process, the Hellenic Republic Asset

Development Fund (HRADF), under its capacity as the major shareholder of PPA, and COSCO HK Ltd entered

into a Shares Purchase Agreement (hereinafter: SPA) for the acquisition of the majority participation of the

share capital of PPA. In August 2016, after the satisfaction of certain conditions precedent, the SPA was

affected by the execution of the transaction and the transfer of PPA’s majority shares from HRADF to

COSCO HK Ltd and PPA S.A..

In the framework of the Privatization Process and as envisaged and permitted by the Old Concession

Agreement (including, without limitation, article 15.1(iii) thereof), the Hellenic Republic and PPA engaged in

negotiations, resulting in the finalization and conclusion of a new amendment of the Old Concession

Agreement, which was finally signed by the parties on 29/06/2016 and ratified by law 4404/2016

(Government Gazette A’ 126/08.07.2016).

The objective of the Company is to perform its obligations, conduct its activities and exercise its faculties

under or in respect of the concession agreement between the Company and the Hellenic Republic dated 13

February 2002 regarding the use and exploitation of certain areas and assets within the Port of Piraeus, as

amended and in force (the “Concession Agreement”), in accordance with the law.

For the purpose of attaining its object under paragraph 1 above, the Company may, by way of an illustrative

but no means exhaustive list, conduct and engage in the following activities:

(a) use all rights assigned to the Company pursuant to the CA and maintain, utilize and exploit all

concession assets in accordance with the Concession Agreement;

(b) provide services and facilities to vessels, cargo and passengers, including ship berthing and cargo and

passenger handling to and from the port;

Page 34 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

(d) undertake any activities related to the port and all other commercial activities associated with or

reasonably incidental to the operation of the port of Piraeus;

(e) engage third parties to provide any kind of port services;

(f) award contracts for works;

(g) engage in such further activities as are prudent or customary for the proper conduct of its business and

operations in accordance with the Concession Agreement; and

(h) engage in any and all activities, transactions or operations of a type that are conducted by commercial

corporations generally.

A.2 Evolution of Business Activities

Cruise Activity

In 2022 the cruise industry saw significant growth in both arrivals and passenger traffic. Total passenger

traffic in 2022 amounted to 880,416 compared to 303,665 in 2021 recording an increase of 190%. Cruise

calls also increased by 79% with 677 calls compared to 379 the previous year, surpassing even pre-

pandemic levels. In addition, it is worth mentioning that homeport arrivals recorded an increase of 100.5%

compared to 2021.

Coastal Shipping Activity

Coastal shipping activity recorded an increase in ship routes and passenger/vehicle flows compared to the

previous year. The total passenger traffic, in 2022, on domestic routes recorded an increase of 26% with

14,976,394 compared to 11,896,187 passengers in 2021. Also, an increase of 10% is recorded in the vehicle

traffic sector, 2,772,525 in 2022 compared to 2,521,898 in 2021.

Car Terminal

Car terminal volume showed a drop in 2022 recording an 18% decrease due to the Ukraine-Russia war

resulting in a reduction in transshipment volume to the Black Sea as well as supply chain disruptions with

semiconductor shortages and the very long delay in receiving new vehicles. Total volume was 350,970

vehicles compared to 429,213 in 2021. Local volumes increased by 16.5% (from 100,225 in 2021 to 116,732

in 2022) while transshipment volumes decreased by 29% (from 328,988 in 2021 to 234,238 in 2022).

Container Terminal

Container terminal has maintained its increasing trend during 2022 compared to previous years. In specific,

the total volume of Pier I increased by 5.4% (from 615,510 TEUs in 2021 to 648,889 TEUs in 2022) due to

the increase in transshipment volumes but also a significant increase in the volume of domestic cargo.

Transshipment volumes increased by 3.7% (from 480,912 in 2021 to 498,815 TEUs in 2022), mainly due to

the contribution of the COSCO Shipping group while domestic cargo increased by 11.5% (from 134,598

TEUs in 2021 to 150,074 in 2022) corresponding to the country's import/export increase.

Ship Repair Activity

In the field of dry-docks, 133 ships were served in 2022 compared to 141 in 2021 (-6%). This decrease is

mainly due to the fact that one of PPA's large dry-docks, which operates at significant occupancy, was out

of operation for 3 months in 2022 due to maintenance and repair works that were successfully completed.

Additionally, total occupancy days increased by 12% (from 1161 to 1304 days). Also, there was an increase

in the number of ships in the Ship Repair Zone with 280 ships in 2022 compared to 264 the previous year

(+6%).

Page 35 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

A.3 International Conditions – Prospects

The nature of PPA's business activities depends on domestic and external macroeconomic and geopolitical

data with emphasis on the countries of the Southeastern Mediterranean and the countries served through

the port of Piraeus. It is further influenced by developments in the global port industry in general, as well as

from the development of individual port activities that are largely related to both the investment program

of PPA SA and the level of services provided to port users.

Significant growth rates were expected in 2022 as the global economy recovered from the impact on

production and distribution chains of the Covid 19 pandemic. However, the start of the armed conflict in

Ukraine and the negative impact on energy prices created inflation situations with the European economy

that had a negative effect on growth. High inflationary pressures mainly in the EU of 9.3% (8.5% in the euro

area) have an impact on consumption and especially on the economic environment as uncertainty arises in

relation to the economic outlook. In November 2021 the estimate for EU GDP in 2022 was 4.3% growth was

ultimately one point lower (3.3%) and the estimate for 2024 is almost zero (0.3%).

Indicative of the uncertainty in the economic field is the continuous adjustment of the forecasts of

international organizations. The IMF forecasts global economy to grow by 2.9% in 2022 against a forecast of

2.7% in October and 3.2% in July 2021. The World Bank revised the Eurozone's growth forecasts for 2023 by

-1.9 points compared to June and now forecasts zero growth for 2023

In the above context of uncertainty of global economic activity, a significant impact was recorded by the

policy of zero Covid19 cases in China as domestic consumption was limited and exports in October 2022

recorded a decrease, negatively affecting global supply chains that to date have not returned to a stable

equilibrium.

The container terminal recorded a 5.4% load increase in 2022 following a 13.9% increase in 2021. Domestic

cargo throughput increased by 11.5% compared to 2021 supported by significant economic activity in the

country in the first half of the year due to deferred demand from 2021. Especially while in the first half of

2022 an increase of 45.7% in domestic cargo handling is recorded as a result of deferred demand and the

positive impact of high tourism flows, in the second half of the year negative rates of -15.2% domestic

cargo handling are recorded compared to the corresponding period of 2021 as the decrease in purchasing

power and high energy prices affect the financial planning of households. Transshipment throughput was

also increased by 3.7%. Despite the uncertain outlook for 2023, the container terminal recorded for the

first time positive financial results in 2022 with profitability in its operation as a result of increased volumes,

improved local/transshipment ratio and cost control measures.

In the car terminal sector, the disruption of production chains by the lack of microprocessors, which

particularly affects European factories

, is particularly evident. As recently as January 25, TOYOTA

announced a suspension of production of the plant in the Czech Republic

for February. In addition, port car

terminals throughout Europe record very high vehicle storage times as a result of the inability of transport

chains to absorb flows that are erratic from factories due to a lack of railcars or trucks. The resumption of

production of vehicle factories was not combined with an increase in ship capacity and freight rates

increased, but mainly producers are now experimenting with sending cars in containers

. PPA manages

container and car terminals and has unique flexibility to serve such cargoes.

https://openknowledge.worldbank.org/bitstream/handle/10986/38030/GEP-January-2023-GDP-growth-data.xlsx

[Accessed 1, Feb. 2023]

https://www.acea.auto/message-dg/chip-shortage-auto-industry-calls-for-more-eu-made-semiconductors/

https://europe.autonews.com/automakers/toyotas-czech-plant-halt-production-during-

february#:~:text=%22Due%20to%20a%20shortage%20of,to%20202%2C255%20cars%20last%20year.

https://www.automotivelogistics.media/finished-vehicle-logistics/ro-ro-capacity-crunch-means-carmakers-are-

looking-for-containers/43864.article

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

It has already served three ships with 4019 vehicles originating in China on transport platforms at the

container terminal while the distribution to the final destination was made by car carrier from the car

terminal.

As a result of production problems and imbalance between production and distribution, passenger car

registrations in the EU in 2022 recorded a decrease of 14.6% with fewer vehicles even compared to 2020,

which was a pandemic

year. In Greece, registrations in 2022 recorded an increase of 4.3%

as a result of

the increase in deliveries as the PPA's car terminal had reduced congestion in the storage areas although it

operates at particularly high levels of capacity usage. The interruption of vehicle flows to the markets of

Ukraine and Russia is the main reason for the reduction of the transshipment load at the car terminal

where a decrease of 29% was recorded. However, the positive impact of the significant 16.5% increase in

the domestic contributed to the improvement of the terminal's financial results.

In the cruise sector, after the almost total suspension of 2020, cruising resumed on May 14, 2021, faster

than other Mediterranean ports. Piraeus with the positive activity both during the pandemic in 2020 and

the quick response to the restart of the industry in 2021 has been recorded as a reliable partner and the

preference of cruise companies to use the port as a homeport was recorded vividly in 2022. Besides the

increase of passengers (+190%) and vessel calls (+79%) a significant increase was recorded in ships and

homeport passengers and is further strengthened in 2023 based on pre-bookings. Said structural change is

in absolute alignment with the strategic objectives of the Company and the expansion of the cruise port

which is already underway will allow Piraeus to capitalize on the successful management of the cruise

during the pandemic years by making permanent the use of Piraeus as a Homeport.

In the coastal shipping sector in 2022, an increase in passenger and vehicle flows was recorded also aided

by the greatly improved tourism flows but without traffic reaching the figures of 2019. The total traffic of

passengers and vehicles on domestic lines in 2022 saw a 26% increase in passengers (14,976,394 compared

to 11,896,187 passengers in 2022) and 10% (2,772,525 compared to 2,521,898 vehicles in 2022) in vehicles.

Despite the significant improvement in traffic volumes it is still behind 2019 (16,551,054 passengers and

2,742,213 in 2019). The improvement of coastal shipping flows is a necessary condition for the renewal of

the fleet as well as for the adaptation to the emission reduction policies adopted in the EU.

In the ship repair sector, there was an increase in the number of ships in the Ship Repair Zone by 6% (from

264 in 2021 to 280 in 2022) but a decrease of 6% in dry-docks (from 141 in 2021 to 133 in 2022). Despite

the increase in ships in the Ship Repair Zone (SRZ), a decrease in revenue was recorded as the increase was

due to lower fee stern moorings. Accordingly, despite the reduction of vessels in the dry-docks, higher

revenues are recorded as the average duration of stay increased by 29% (9.8 vs. 7.6 days).

https://www.acea.auto/cv-registrations/commercial-vehicle-registrations-14-6-in-2022-5-1-in-december/

https://seaa.gr/wp-content/uploads/2023/01/2022-12-b-1.pdf

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(amounts in Euro unless stated otherwise)

B. Policies and Due Diligence

B1. Policies and Due Diligence for environmental issues

PPA S.A. implements Land and Marine Pollution Contingency Plans, approved by the competent Ministry, for

dealing with oil pollution incidents and other harmful substances in the port area. Emergency situations are

fully covered by the aforementioned contingency plans.

During the year 2022, 15 incidents of marine pollution and 14 incidents of land pollution were recorded in the

area of responsibility of PPA SA (compared to 22 incidents in the marine environment and 9 incidents in the

land area in 2021). All the incidents were of small-scale and were addressed by PPA S.A. directly and

effectively. The marine pollution incidents were related to petroleum or hydraulic oils and transferred

materials from land-based sources. Land pollution incidents were related to spillage of petroleum products or

oils from machinery and vehicles.

In addition to the above, the Environmental Protection Sector of the PPA, in order to ensure the proper

environmental management of the premises and the proper waste management and any pollution incidents,

sends at regular intervals relevant informative documents-instructions to the users of the premises. The

following are noted for 2022:

• "Instructions for the management of land pollution incidents and waste management in the areas of the

Container Terminal" (no. 2620/22-02-2022)

• "Proper environmental management of the under concession areas of activity" (no. 11658/1-09-2022).

Finally, it is noted that within 2022, a revision of the Dangerous Goods Management Regulation at the PPA

Container Terminal was carried out and the inclusion of a relevant thematic section on dangerous goods

management in the PPA staff training program.

B2. Policies and Due Diligence for safety issues

At high-risk areas (Container Terminal and Perama Ship Repair Zone) the Company provides two ambulances

with trained rescue personnel (two rescuers per vehicle) that are available 24/7, to cover emergencies that

may occur in the above mentioned areas.

B3. Due Diligence Policies for Regulatory Issues

Legislative and Regulatory Framework

PPA SA has a Regulatory Compliance Function (RCF), which is functionally independent, with staff with

sufficient knowledge, experience to carry out its responsibilities, appropriate training and information to

monitor the effective adoption and smooth implementation of the changes that take place in a regulatory and

legislative context and concern the Company. The RCF shall follow an annual action plan adopted by the Audit

Committee, and its findings shall be communicated in a timely and true manner to the Audit Committee and

the Company Administration.

The main mission of RCF is the effective regulatory and legislative implementation management undertaken

by the Company as a prerequisite for high standards of Corporate Governance and leads to high efficiency and

optimal business performance.

Its purpose is the preparation and implementation of appropriate procedures methodology for regulating,

assessing and managing Company's policies and procedures according to existing legislation, and general

coordination of the process through the Company's Departments. RCF must have the ability of understanding

on important future regulatory changes, having at the same time the appropriate procedural treatment.

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It monitors the effective adoption and unwavering implementation of changes taking place in the regulatory

framework, with direct access to all required sources of information.

Regulatory Compliance carries the responsibilities assigned by Law 4706/2020 “Corporate governance of

joint-stock companies, modern capital market, incorporation into Greek legislation of Directive (EU) 2017/828

of the European Parliament and of the Council, measures to implement Regulation (EU) 2017/1131 and other

provisions”, as in force, decision 1/891/30-9-2020 of the Hellenic Capital Market Commission’s Board of

Directors as in force, and the best practices framework according to national and international compliance

standards.

Monitoring Developments in Legislative and Regulatory Framework

RCF is constantly monitoring developments on legislative and regulatory framework with regards to all key

issues of organization and operation of Company. In particular, it is informed and informs the Company’s

Administration of any changes and amendments on Greek, European and international legislation and the

derivative legislation. It is further informed of any change in regulatory acts concerning the Company, such as

indicative regulatory administrative acts, administrative and judicial decisions and relevant case law,

regulations and compliance standards on national and European level and in general, whatever is necessary

for the Company’s institutional and regulatory compliance with the view to achieving optimal regulatory

functionality. It shall also be regularly informed by Departments of any demonstrable changes on the specific

regulatory framework governing them (guidelines, ministerial decisions, individual or regulatory acts,

executory decision by authorization of International Contracts, Directives and compliance standards. RCF shall

inform Company Administration any appropriate tool, written or verbal opinions, e-mails, answer to day-to-

day questions raised by Company’s Departments or Administration concerning the implementation of the

abovementioned legislative framework, and informative notes, addressed to any interested party or Company

Bodies (Top Management, Department Managers, or functions of Departments).

B4. Outcome of Policies Issues

Outcome of Policies for environmental protection issues

The results of the policies on environmental protection issues are analyzed in a next chapter of this Non-

Financial Information Report entitled "Environmental Issues - Non- financial indicators for environmental

performance”.

Outcome of Policies for Safety Issues

The results of the policies on working safety are analyzed in a next chapter of the Non-Financial Report

entitled "Employee Issues - Safety working conditions”.

Outcome of Due Diligence Policies for Regulatory Issues

As a result of the due diligence policies for regulatory issues, it is reported that in fiscal year 2022, no control

entity identified any relevant violations. In addition, the Company took the required actions for regulatory

issues to comply with the observations of the external consultant who carried out the evaluation of the

Internal Control System.

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C. Risk Policy & Management of These Risks

C1. Risk Policy

Piraeus Port Authority S.A. aims to provide high quality, efficient and safe port services in a

sustainable manner, contribute to local and national economy, strengthen the port’s position and

achieve sustainable growth. Various factors such as internal and external issues, interested parties’

needs & expectations could be considered as possible risks that can or could negatively affect the

company in achieving its objectives and strategy and therefore it is vital to be identified and

addressed. The Company determines, evaluates and addresses any possible risks in order to:

- achieve its mission, vision, profit, objectives, policy, customer satisfaction, legal and other

obligations compliance, enhancement of environmental and energy performance

- enhance desirable effects

- prevent or reduce undesired effects, including the potential for external environmental conditions

to affect the organization

- achieve continual improvement

PPA’s Top Management is committed to ensure the continuing effort to address all risks involved

with its operation and undertake all necessary proactive actions.

C2. Risk Management Process

PPA S.A. is promoting awareness of risk-based thinking to all its departments in order to protect its

values and address uncertainty and address the uncertainty and insecurity that is largely due to the

international environment. Therefore, each business unit is responsible to implement a risk

assessment procedure.

The Company has approved a Risk Management function, which is functionally independent. The

main mission of Risk Management is the effective risk management of risks undertaken by the

Company as a prerequisite for high standards of Corporate Governance and leads to high efficiency

and optimal business performance.

Its purpose is the preparation and implementation of an appropriate methodology for identifying,

assessing and managing the Company's risks according to defined criteria and the general

coordination of the process through the Company's Departments. Risk Management must have the

ability of understanding on important future changes, having at the same time the appropriate

strategically treatment.

Risk Management must have the ability of understanding on important future changes, having at the

same time the appropriate strategically treatment. Risk Management has direct access to all the

elements which are necessary for the proper performance of its duties and submits written reports to

Top Management regarding the implementation of appropriate and effective policies, procedures and

tools (such as keeping a risk register) on the determination, analysis, control, management and

monitoring of any kind of risk inherent to the operation of the Company. Risk management carries out

the responsibilities assigned by Law 4706/2020, decision 1/891/30-9-2020 of the Hellenic Capital

Market Commission’s Board of Directors and the best practices framework. The main purpose of the

document is to establish the general Risk Management Framework which consists of the following:

➢ Identification of potential incidents that may affect the Company and the determination of levels of

risk deemed acceptable for the Group (Risk Appetite Statement).

➢ Implementation of the relevant methodology regarding the identification, evaluation and

management of risks for their proper and effective / appropriate management and prioritization.

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➢ Structured approach to risk management which is the basis for the provision of assurances regarding

the achievement of the Company 's business objectives.

The purpose of this Policy is not to eliminate the risk, but to effectively manage the risks involved in

the activities of the Company and its subsidiaries in order to maximize opportunities and minimize

adverse effects. Specifically, the organization:

➢ Ensures that risk management is an integral part of all decision-making processes of the Company and

its subsidiaries.

➢ Evaluates and improves risk management policies, procedures and systems.

➢ Understands and monitors the risks associated with the strategy and business objectives.

➢ Informs the Management about any new significant risk and related safety controls.

➢ Provides appropriate risk management training to management and staff.

➢ In cooperation with the Audit Committee ensuring that the significant risks that have been highlighted

by the IAD, are included in the risk register process while informing for the risks that have been came

out from Risk Management Function.

➢ Evaluation of actions’ effectiveness through monitoring Key Performance Indicators (KPIs). This

process is monitored by the Quality Control and Inspection Dept through Internal Audits conducted at

all company’s departments. The above process is coordinated by the Quality Control and Inspection

Department, which provides support to each department for training as well as for the necessary

review and updating of risk assessment.

The review and update are carried out at least once a year and necessarily before the implementation

of any change, so that the Company is informed in a timely manner about the upcoming changes to

which it must react and prepare accordingly. Documented information as evidence of the results of

monitoring and measuring the actions taken, is maintained by each competent department as well as

by the Department of Quality Control and Inspection. During the Management Review, the Quality

Control and Inspection Department presents all the necessary information and data on the progress

and effectiveness of the actions taken to address the risks.

The above procedure is included in PPA’s Procedures’ Manual that has been approved by Top

Management’s decision. The same approach is also followed for energy related matters within the

framework of the Energy Management Certification as per ISO 50001:2018 standard under the

coordination of PPA SA ‘s Energy Management Team. The company determines, evaluates and

addresses any possible risks related to energy in order to improve energy performance. Significant

Energy Uses are defined through Annual Energy Reviews. During Management Reviews by the Top

Management, all necessary information and data on the energy performance, the progress and

effectiveness of actions taken to address energy related risks are presented to Top Management for

further decision making. Thus, achieving continual improvement.

C3. Main Business Risks and Uncertainties

General economic environment

The maintenance of the stable economic environment in the country is directly linked to the volumes

of imports and exports and, by extension, to the volumes of cargo handled, which offer the largest

average income to the Company. Economic uncertainty in 2023 with high inflation rates and the

maintenance of geopolitical instability in Europe create waiting conditions for investments and

negatively affect consumption and growth. Regardless of the economic impacts that differ from

industry to industry, the geopolitical crisis and pandemic highlighted the criticality of the time factor

in impact assessment. In particular, geopolitical instability in the eastern Mediterranean and the Black

Sea further intensify uncertainty about trade flows and volumes. The Company also monitors

developments in this area and makes assessments of any positive or negative effects on

transshipment cargo.

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Economic instability

Geopolitical and economic instability in North African, Asian Mediterranean and Black Sea countries can

adversely affect transit cargo served by Piraeus. The slippage of the Turkish lira made Turkey's exports

more competitive but at the same time hit domestic demand and hampered imports of raw materials,

creating instability in an important economic partner for Greece.

The Company, for the purpose of risk mitigation, aims to strengthen and develop rail connectivity with

central Europe and seeks cargo and customers to expand the port hinterland to the north, thereby

reducing dependence on markets with maritime borders to the south and southeast.

Energy Policy

The recent sharp increase in electricity prices due to a multitude of factors affects the Company's

operating costs to a significant extent. The Company has taken this into account and is adjusting its

charges while closely monitoring the developments for any further actions.

The Green Deal policy and especially certain policies such as EU ETS on ships and zero emission policies

of ships are likely to affect the Company's operations. In this context, the developments are recorded

and the Company actively participates in international Bodies in order to transfer any improvement

proposals to the regulatory imperatives of the European Regulations.

Non- expanded customer base (Container Terminal)

The Company, through the cooperation with the neighboring container terminal under PCT SA,

managed to significantly mitigate the very high dependence it had for many years on one customer. In

2022 the cooperation with PCT SA contributed to approximately 42% of the total load. In addition to

the above action, the Company has adopted a customer-centric approach while at the same time

implementing an aggressive policy to attract new customers. However, the structure of the container

shipping market provides limited options for attracting new cargo in the short term.

Geopolitical conditions

Piraeus which relies mainly on transit cargo from Asia due to distance from EU production centers could

lose competitiveness. But at the same time, the change in the supply chain also provides opportunities.

The Company has intensified discussions with European and Asian car manufacturers to demonstrate

the benefits of Piraeus. The tension in Ukraine as well as the elections in Greece and Turkey add to the

uncertainty for the rest of the year. Although geopolitical conditions cannot be influenced by the

Company, they are closely monitored in order to record the effects immediately.

D. Financial and Non-Financial Performance Indicators ESG

A detailed presentation of a mixture of general and sectoral indicators took place in the module

Business Model - Evolution of Business Activities with a distinct reference to traffic data of each

Company's business sector (Cruise, Coastal Shipping, Car Terminal, Container Terminal, and Ship

Repair).

It is pointed out that, PPA SA has included all the elements of non-financial information in the

Corporate Responsibility and Sustainable Development Report 2022 which will be created and

published based on the international standard Global Reporting Initiative (GRI), version. The Report will

be uploaded on the corporate website (www.olp.gr) in the section "Social Responsibility".

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(amounts in Euro unless stated otherwise)

In addition, PPA SA recognizing that the international ESG indicators (in the already published

Corporate Responsibility and Sustainable Development Report 2020, there is a special reference to ESG

issues entitled "ESG Data Scorecard") are a strategic tool for investor support in the context of

identifying risks and opportunities associated with the viability of their investment portfolio and

responding at the same time to the challenges of the new environment, builds a sustainable

development strategy, aiming to minimize the negative impact that its activities may have.

The Company's long-term commitment to Sustainable Development has already led to its participation

(August 2020) in the new ATHEX ESG index of the Athens Stock Exchange.

As demonstrated in the Corporate Governance Statement, PPA SA attaches great importance to

Sustainable Development and taking into account both the new legislation on Corporate Governance

and the principles of Taxonomy (EU Taxonomy).

EU Taxonomy

The EU Taxonomy is the European Union classification system of activities that can under certain

conditions be considered as environmentally sustainable or as activities that enable the transition to

environmental sustainability. Under the Taxonomy regulation, companies and organizations can attract

funds to develop their sustainable activities as well as expand them further, provided they meet certain

criteria.

The criteria that determine the level of sustainability of certain economic activities are set by the

Taxonomy Regulation (2020/852/EU). In order to achieve sustainability of its economic development,

the European Union has stipulated 6 environmental goals, the achievement of which will advance

sustainable development within the Union. Specifically, the environmental goals at the center of the

Taxonomy framework are the following:

1. Climate change mitigation;

2. Climate change adaptation;

3. The sustainable use and protection of water and marine resources;

4. The transition to a circular economy;

5. Pollution prevention and control;

6. The protection and restoration of biodiversity and ecosystems.

The achievement of one or several of the above-mentioned goals provides an economic activity with

the status of sustainable, transitional or enabling according to their alignment to the Taxonomy

framework. Specifically, depending on whether the activity has the potential to be conducted in a fully

sustainable way at present, whether it can help the economy transition to a more sustainable model or

whether it can allow other activities to be conducted sustainably, the economic activities have been

designates into different subgroups. In order to be considered aligned to the EU Taxonomy, an

economic activity must fulfil all of the following criteria:

I. Contributes substantially to one or more of the environmental objectives set out in the Regulation

II. Does not significantly harm any of the environmental objectives set out in the Regulation

III. Is carried out in compliance with the minimum safeguards laid down in the Regulation

IV. Complies with technical screening criteria stipulated by the Commission for each economic activity

towards the achievement of the environmental goals of the Taxonomy.

At the moment of publication of the present report, the Taxonomy framework contains specific

technical screening criteria solely for the first two goals (Climate change mitigation & Climate change

adaptation). The technical screening criteria relating to the achievement of these goals have been

adopted via the Climate Delegated Act (2021/2139/EU) as well as the Complementary Climate act

(2022/1214/EU). The first year of Taxonomy alignment reporting will be conducted based on the

criteria set out by these legislative acts.

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The compliance with said criteria is monitored continuously and reported on an annual basis, included

in the non-financial section of the respective annual financial statements. As part of the Taxonomy

reporting process, we disclose in the following section the key performance indicators relating to our

economic activities for the FY2022 as well as supplementary contextual information on said activities.

Piraeus Port Authority activities

The Company since the first period of Taxonomy reporting for FY2021, examined its activities through

the prism of EU Taxonomy in order to report on its eligible activities. This is the first step in the

Taxonomy reporting process of P.P.A. each year and through it the Company has identified eligibility

according to the following activities for FY2022:

• 6.16 Infrastructure for water transport

• 6.10 Sea and coastal freight water transport, vessels for port operations and auxiliary activities

The second step following the eligibility examination, was to evaluate alignment with EU Taxonomy

based on the criteria provided by the Climate Delegated Act (2021/2139/ΕU). The result of this

evaluation is presented in the following section of the report.

Substantial Contribution to Climate Change Adaptation

The Company is acutely aware of the risks to its activities as a result climate change and monitors

them based on the latest scientific reports and relevant publications on an ongoing basis. Both of its

reported activities have been considered within the “Adaptation to climate change” environmental

goal, therefore the substantial contribution criterion applies to both equally. Additionally, owing to

the fact that all P.P.A. activities are conducted within the same, fairly limited geographic area, it was

determined that the physical climate risk and vulnerability assessments conducted at the organization

level, encompass adequately both its economic activities for EU Taxonomy purposes.

The Company’s climate risk analysis takes into account scenarios RCP2.6 and RCP 8.5 of the IPCC

report in its best effort to cover a broad spectrum of possibilities. On the country level, the only

completed national climate change impact and vulnerability assessment report has been produced by

the Bank of Greece and P.P.A. has considered its results and recommendations carefully.

Furthermore, the Company incorporates scientific models and projections in its risk analysis such as in

the reports issued by the Hellenic National Meteorological Service, in order to continuously improve

the accuracy and credibility of its business plans as well as safeguard its long-term successful and

sustainable activity. In the first years of EU Taxonomy reporting, P.P.A. is confident that its existing

environmental risk inventory is sufficient for the purposes of the climate change adaptation technical

screening criteria as it understands them based on both the EU Taxonomy Climate Delegated Acts and

relevant interpretive documents by the regulators (e.g. FAQ documents). The Company’s process to

identify and address physical climate risks follows a series of distinct stages as presented below:

I. P.P.A. risk analysts screen all economic activities to identify the physical climate risks that have the

potential to affect the performance of such activities within a reasonable period of time

II. The identified risks are categorized and prioritized using input from various Company departments

according to likelihood and severity of impact on economic activities

III. The risk department compiles an annual report detailing the actions to be taken and providing

recommendations to Management

IV. Based on the results of the risk report, the Company plans and implements counter-measures in

line with national and international recommendations.

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Through its existing processes, the Company has identified a series of risks including physical climate

risks to its activities. After close examination of the table of risks provided in Appendix A to the

Climate Delegated Act, P.P.A. presents the physical climate risks in its existing portfolio that corelate

more closely to the risks of the Taxonomy Annexes:

1. Extreme wind patterns

2. Changing precipitation patterns

3. Storm surges

In fact, P.P.A. has designated Climate risks as Top risks in terms of likelihood, deeming them almost

certain. To adapt to such risks, the Company plans and executes targeted measures in line with

recommendations by the National Strategy for Adaptation to Climate Change, the National Strategy

for the protection and management of the marine environment, etc. It is worth noting that the

National strategy for adaptation to climate change of Greece proposes actions and measures based

on the findings presented in the report by the Bank of Greece.

Minimum Safeguards

The Taxonomy criterion relating to the minimum safeguards is understood as applicable on the

Company level rather than for each specific economic activity within an organization. In the absence

of specific reporting methodology on the issues covered in the minimum safeguards, P.P.A. presents

its structured approach to safeguarding social issues within the scope of its activities and value chain.

Corporate Responsibility is an integral part of our operations. Creating relationships of trust and

cooperation with local communities is a Management priority which seeks to establish a sustainable

development model focused on environmental protection, charity work and the support of

education,sports and cultural activities, to the best of the Company’s ability.

The Company acknowledges that development of its human resources is the cornerstone in achieving

its goals. Through understanding and respecting employee needs and applying merit-based criteria,

the Company ensures the ongoing training and development of its employees, considering the needs

of PPA S.A. and the protection of corporate interests.

At PPA S.A. we uphold the United Nations 2030 Agenda, as such is represented by the 17 Sustainable

Development Goals for 2030.

Our intention is to actively contribute to their achievement by promoting the population’s well-being

and security, protecting the environment and combating poverty.

Our priority is to achieve those goals directly linked to the activities and challenges specific to our

sector and to all material aspects arising from this report. The table below details how our

programmes and actions are associated with the Sustainable Development Goals.

OECD Guidelines for Multinational Enterprises

During 2020, the Company has established the “PPA S.A. Code of Conduct”, which was distributed to

all staff and members of the Management. The PPA S.A. Code of Conduct has been developed taking

into account the OECD Guidelines for Multinational Enterprises. At PPA S.A. we consider our people

as our most valuable asset. We thus invest in our human resources in order to maximise their

efficiency, organisation and the services they provide. We take steps to ensure responsibly excellent

working conditions, benefits, advantages and training and advancement opportunities for our people,

even in the difficult circumstances that we had to face in 2020 due to the COVID-19 pandemic.

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Responsible Risk Management Policy

PPA S.A. aims to provide high-quality and efficient port services safely, contribute to the local and

national economy and strengthen the port’s position through sustainable development. Various

factors, such as internal and external issues or stakeholders’ needs and expectations, could be seen as

potential risks that negatively affect or may negatively affect the Company in achieving its objectives

and strategy; therefore, it is necessary to identify them in order to be able to address them. The

Company’s Management undertakes to ensure that continuous efforts are made to address all risks

associated with its operation and take all necessary preventive actions. PPA S.A. promotes risk-based

thinking in all its Departments to protect the Company’s values and address uncertainty. Each

Business Unit is therefore responsible for the implementation of a risk assessment procedure.

Respect of Human and Labour Rights

The Company respects human rights as well as the rights of employees and observes the Labour

legislation. To this end, the following issues are material to the Company:

Employee Associations

There are four first-degree Associations (Association of Permanent Employees, Association of

Technicians & Operators, Association of Dockworkers, Association of Supervisors - Foremen) and one

second-degree Association (Federation of Permanent Port Employees of Greece) at PPA S.A. The

Company’s Management is in close cooperation with the employees’ representatives to ensure the

proper functioning of its services and to promote the common interests of the Company and its

employees.

Diversity, Equal Opportunities and Non-Discrimination

The Company’s basic principles include the promotion of equal opportunities and the protection of

diversity. The Company’s Management makes no discrimination in terms of personnel recruiting or

selection, earnings, training, assignment of work-related tasks or other work activities.

The Company favours respecting the diversity of each employee and does not tolerate any behavior

that could lead to discrimination of any form.

At PPA S.A., the experience, personality, theoretical training, qualifications, efficiency and

competences of each individual are the main factors that determine their choice for more complex

and demanding positions of responsibility. Characteristics related to candidates’ gender, age, religion,

origin and colour, physical particularities or beliefs are not reasons for their preference or exclusion.

In this way, we promote a climate of equality, which in turn is anchored in respect for diversity and

human dignity. At the same time, we have put in place three key tools for supporting equal

opportunities and diversity.

Furthermore, in accordance with the applicable Enterprise-Level Collective Labour Agreement, we

provide our employees with a series of additional benefits, in order to meet their medical and

financial needs, thus contributing to the health and well-being of their families. These benefits testify

to our intent to invest in our employees and our commitment to providing a quality work

environment.

Occupational health and safety

PPA S.A. acknowledges the importance of ensuring safe conditions and workplaces for its personnel,

as well as safe transportation conditions for all involved parties, customers, passengers, etc. Safety at

work for employees is a top priority and a prerequisite for the Company’s operation.

The Company as an employer is obliged to take all appropriate measures to protect the safety and

health of employees in the workplace.

PPA S.A. ensures health and safety conditions for employees and their areas of responsibility. We thus

establish health and safety rules through circulars, announcements and instructions.

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Stakeholders communication and engagement

As a business organization that prioritizes transparency and continuous communication of its actions,

we systematically interact with our Stakeholders, who form either part of the Company’s internal

environment (Shareholders, Employees) or external environment (Suppliers, Customers, Local

Communities, NGO Representatives) and are directly or indirectly affected by our actions. Our main

concern is to be in constant and active communication with our stakeholders, with the aim of building

mutual trust and excellent cooperation. Maintaining the dialogue and interaction with each of our key

stakeholders and improving our relationship with them, is particularly important to identify their

needs and expectations which are essential for our operations.

More information can be found in the annual Corporate Responsibility and Sustainability Report at

https://www.olp.gr/en/corporate-responsibility/social-responsibility

Infrastructure for water transport

Taxonomy activity description: Infrastructure for water transport

This activity consists of the construction, modernization and operation of waterways, harbor and

rivers works, pleasure ports, locks, dams and dykes and other, including the provision of architectural

services, engineering services, drafting services, building inspection services and surveying and

mapping services and the like as well as the performance of physical, chemical and other analytical

testing of all types of materials and products and excludes project management activities related to

civil engineering works. The economic activities in this category exclude dredging of waterways.

Eligible PPA activity description:

The Company owns and operates the port of Piraeus, the largest port in Greece and its surrounding

area, including facilities and infrastructure for commercial purposes. In the framework of its

operations, the Company also undertakes maintenance and modernization tasks of said facilities. The

services provided to incoming marine traffic include inter alia the provision of shore-side services

vessels at berth, loading, unloading and transshipment of goods.

Examination of alignment with the DNSH technical screening criteria regarding the environmental goal

of Climate Change Adaptation

1. DNSH Climate change mitigation

Due to its exceptional significance and prime geographic location, the port of Piraeus serves as a

gateway to Europe, Asia and Africa, In the course of its activities as a busy hub for commerce, it

facilitates all kinds of imports and exports, including fossil fuels. However, the facilities are in no way

explicitly dedicated to the transportation or storage of fossil fuels. Over the past year, the Company

continued renovation works in and around port premises as part of a broader plan approved by the

Greek state for the development of the southwest areas of Athens which has been in the making for a

number of years. Within this plan, P.P.A. undertook works to improve the environmental efficiency of

infrastructure including roads and ship-repair stations that will ultimately expedite both inland and

marine traffic, resulting in decreased emissions as a direct result of its activities. Moreover, the

Company calculates the direct and indirect emissions pursuant to the National Climate Law

(4936/2022) for all of its activities.

2. DNSH Sustainable use and protection of water and marine resources

The Company monitors the achievement of good water status and ecological potential in accordance

with Directive 2000/60/EU as well as by use of an established Water Quality Management Program,

the results of which are reviewed under the stipulations of the same Directive. All of the Company

activities are subject to mandatory Environmental Impact Assessment (EIA) pursuant to L. 4014/2011

in the framework of inland and port construction projects’ environmental authorization process.

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3. DNSH Transition to a circular economy

All non-hazardous construction and demolition waste generated by the Company over the course of

its works is prepared for reuse, recycling or other kinds of material recovery pursuant to applicable

legislation. The official Approval decision of Environmental Terms (ΑΕΠΟ) that dictates the

construction works undertaken by the Company contains specific provisions for the management of

solid and liquid waste byproducts according to national law.

4. DNSH Pollution prevention and control

As in the case of waste, the official Approval decision of Environmental Terms (ΑΕΠΟ) that dictates

the construction works undertaken by the Company contains specific provisions for the reduction of

noise, vibration, dust and other pollutant emissions.

5. DNSH Protection and restoration of biodiversity and ecosystems

The submission of an Environmental Impact Assessment (EIA) is a legal prerequisite pursuant to L.

4014/2011 for inland and port construction projects’ environmental authorization process. Therefore,

it has been completed for all of the facilities of the Company. Monitoring its proper application

including related measures adopted for mitigation and compensation and protection of the

environment, is part of the responsibilities of the Environmental Committee of P.P.A. S.A. There are

no sites located in or near biodiversity-sensitive areas.

Vessels for port operations and auxiliary activities

Taxonomy activity description: Sea and coastal freight water transport, vessels for port operations and

auxiliary activities

This activity consists of the purchase, financing, chartering (with or without crew) and operation of

vessels designed and equipped for transport of freight or for the combined transport of freight and

passengers on sea or coastal waters, whether scheduled or not. Moreover, the activity includes the

purchase, financing, renting and operation of vessels required for port operations and auxiliary

activities, such as tugboats, mooring vessels, pilot vessels, salvage vessels and ice-breakers.

Eligible PPA activity description:

The Company owns and operates 3 floating tanks (elevators) that are used in shipbuilding and ship

repairing operations as auxiliary equipment/infrastructure. These vessels, play an integral part in the

processes of shipbuilding and ship repairs as they enable the total removal of ships from the sea in

order to be tended to properly. The vessels function with the use of electricity and batteries, thus

reducing their direct GHG emissions significantly and contributing to the reduction of the ship repair

operations’ emissions output.

Examination of alignment with the DNSH technical screening criteria regarding the environmental goal

of Climate Change Adaptation

1. DNSH Climate change mitigation

The auxiliary vessels in question are used solely for the purposes of assisting ship-repairing activities,

therefore no activities relating to fossil fuels take place in them.

2. DNSH Sustainable use and protection of water and marine resources

The auxiliary vessels, as part of the broader apparatus for the regular operation of the port facilities

have been considered in the framework of the Environmental Impact Assessment (EIA) undertaken for

the port infrastructure as a whole. The EIA includes measures addressing the climate risks that were

identified, which have been applied by the Company in (among others) the activities of the auxiliary

vessels. The vessels do not receive or discharge any water from/to any water body.

3. DNSH Transition to a circular economy

Page 48 of 177

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(amounts in Euro unless stated otherwise)

Since the auxiliary vessels are utilized in ship repairs, the amount of actual waste generated by them is

immaterial. This waste is collected and stored in specified containers until the contracted waste

management company receives it. Additionally, during the cleaning of the vessels, any amount of

material produced (usually mud) is collected and turned over to for alternative use (most commonly

production of biogas).

4. DNSH Pollution prevention and control

Given their nature and mode of operation, the floating tanks give out no direct gaseous emissions such as

sulfur oxides, nitrogen oxides, etc. The implementation obligation refers to vessels, therefore this

criterion does not apply to auxiliary shipping. At the same time, the floating tanks have no sewage and

domestic sewage discharges. The generated waste (wastewater) of IV Marpol category, arising from the

vessels served in the tanks, constitute the Vessel Waste Plan category and are received and managed by

a licensed company.

5. DNSH Protection and restoration of biodiversity and ecosystems

No ballast water is discharged while the float tanks are in operation, since the float tanks remain

motionless. Therefore, introduction of non-native species through biological deposits on the hull of the

float tanks is not possible. Ballast water may only be drained when repair/maintenance works are

performed on the tanks. In this case, however, the water is taken from the same area as the float tanks

remain in the place.

Noise and vibrations generated by all the PPA operations comply with the limit benchmarks and

specifications established by the Decision on the Approval of Environmental Conditions (AEPO).

According to the Decision and the effective legislation, PPA shall monitor the noise at the external

boundaries of its facilities (boundaries with the urban area and other uses outside the port).

Page 49 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Qualitative information

Accounting Policy

I. Proportion of the total turnover. The proportion of aligned economic activities against the total

turnover has been calculated based on the net turnover from services corresponding to Taxonomy

activities (numerator), divided by the total net turnover (denominator), both of which referring to

FY2022. Specifically, the total turnover of PPA SA is presented in the “Revenue” line of the

“Statement of Comprehensive Income for the year ended December 31, 2022” of the “Annual

Financial Report” of the Company.

II. Proportion of the total CapEx. It was calculated based on the capitalized expenses incurred for

additions to assets or processes corresponding to aligned economic activities and it includes the

Taxonomy capital expenditure (numerator) divided by the total capital expenditure (denominator).

The total capital expenditure contains the additions to property, plant and equipment as well as

intangible assets and right-of-use assets during the fiscal year, before accounting for depreciation and

any impairment. The total capital expenditure is determined based on the Statement of Financial

Position and is the sum of the following funds in the “Annual Financial Report” of the Company: line

“Additions” in “Property, Plant & Equipment” (Note 4), line “Additions” in “Leases” (Note 5), as well as

line “Additions” in “Intangible Assets” (Note 7).

III. Proportion of the total OpEx. It was calculated based on the operating expenses related to the repair

and maintenance of assets or processes corresponding to aligned economic activities and includes the

operational expenses (numerator) divided by the total operational expenses for repair and

maintenance as well as leases of less than 12 months duration (denominator). The definition of EU

Taxonomy for the operational expenses includes expenses for research and development, renovation

of buildings, maintenance and repair, as well as any other direct expenses related to the day-to-day

maintenance of property, plant and equipment.

The accountingprinciples used in the preparation of the table presented above are outlined in Note 3

“Principal Accounting Policies” of the “Annual Financial Report” (for the Group and the Company) as

of December 31, 2022. The financial report of PPA SA has been prepared in accordance with

International Financial Reporting Standards (IFRS) as adopted by the European Union (E.U.).

The information presented herein abide by the Regulation’s requirements and the Delegated Acts

issued as of the time of this publication. The related guidelines have a relative margin of

interpretation and are constantly involving to adjust to the needs of the process. Following this, PPA

SA will pay close attention to the related developments and will adjust its approach accordingly

regarding the assumptions and applicable methodology.

Page 50 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Turnover KPI table

Page 51 of 177

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(amounts in Euro unless stated otherwise)

Capital Expenses KPI table

Economic

activities (1)

Code(s) (2)

Absolute CapEx (3)

Proportion of CapEx (4)

Climate change mitigation (5)

Climate change adaptation (6)

Water and marine resources (7)

Circular economy (8)

Pollution (9)

Biodiversity and ecosystems (10)

Climate change mitigation (11)

Climate change adaptation (12)

Water and marine resources (13)

Circular economy (14)

Pollution (15)

Biodiversity and ecosystems (16)

Minimum safeguards (17)

Taxonomy-

aligned

proportion of

CapEx, year Ν

(18)

Taxonomy-aligned

proportion of

CapEx, year Ν-1

(19)

Category

(transitional

activity)

(21)

€000 % % % % % % % Y/N Y/N Y/N Y/N Y/N Y/N Y/N Percent Percent E T

Α. TAXONOMY-ELIGIBLE

ACTIVITIES

Α.1 Environmentally

sustainable activities

(Taxonomy-aligned)

Sea and coastal freight water

transport, vessels for port

operations and auxiliary activities

6.10 4,345 16% 100% Y N/A Y Y Y Y 16%

Infrastructure for water transport

6.16 15,772 56% 100% Y Y Y Y Y Y 56%

CapEx of environmentally

sustainable activities

(Taxonomy-aligned) (A.1)

20,117 72% 100% 72%

Α.2 Taxonomy-Eligible but not

environmentally sustainable

activities

(not Taxonomy-aligned activities)

CapEx of Taxonomy-Eligible but

not environmentally sustainable

activities

(not Taxonomy-aligned activities)

(A.1 + A.2)

0 0%

Total (Α.1 + Α.2) 20,117 72% 72%

B. TAXONOMY-NON-ELIGIBLE

ACTIVITIES

CapEx of Taxonomy-non-eligible

activities

(Β)

7,833 28%

Total (Α + Β) 27,950 100%

Substantial contribution criteria

DNSH criteria

("Does Not Significantly Harm")

Page 52 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Operational Expenses KPI table

Page 53 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

D1. Environmental Issues

In PPA S.A. remaining consistent with our responsibilities towards the environment we adopt policies for

the gradual reduction of carbon emissions and the reduction of the energy footprint of our activities.

In this scope, PPA’s first photovoltaic station generating energy using solar panels operated in July 2016,

generating up to 430 kWp. The photovoltaic Station is linked up to the grid of DEDDIE S.A. (Administrator of

the Greek Electricity Distribution Network).

It is also noted that in 2020, PPA SA invested in changing the mode of operation of the Container Terminal

by replacing Straddle Carriers with Terminal Tractors, for the handling of containers. Terminal Tractors have

lower fuel consumption, which has the consequence of reducing fuel consumption and pollutant emissions

at the Container Terminal.

Other indicative energy saving measures implemented by PPA S.A. are:

▪ Staff environmental awareness

▪ Purchasing of electrical equipment with > A energy class and certification

▪ Replacement of all light bulbs with LEDs

▪ Improvement of buildings’ energy efficiency

Non- financial indicators for environmental performance

1. Waste generated by the operation of port installations

The quantities of domestic and recyclable waste from all premises of PPA S.A. for the years 2021 and 2022

are presented in the Table below.

The increased amount of waste produced in 2022 compared to 2021 is mainly due to the reduced traffic of

the passenger port in 2021 due to the restrictive measures of the pandemic. In 2022 the operation of the

port was normalized and can be considered more representative.

Waste of PPA installations*

2021

2022

ton

Domestic waste (non-hazardous municipal waste)

648

734

Recyclable packaging waste (paper, plastic, glass, metal,

wood)

108

It is noted that the above quantities only include domestic waste (green and blue recycling bins) produced

during the normal operation of the port and do not include:

• operational waste to be reused/recovered (produced at the PPA’s workshops etc)

• hazardous waste

• waste from by case, special cases of work and cleaning of the port.

*The data of waste of each company are finalized by submitting the annual Waste Report to the Electronic Waste Register (HMA) of

the Ministry of Environment and Energy (submitted for each year on March 31 of the following year). The waste data for the year

2021 have been finalized by registering the annual Waste Report of 2021 in the HMA. However, the above waste data for 2022 have

not been finalized yet in the HMA. The finalized waste management data, including the categories of operational and hazardous

waste will be presented in detail in the ESG 2022 of PPA SA.

Page 54 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

2. Sea and Land Pollution incidents

The above data show that in the year 2022 marine pollution incidents were reduced, while land pollution

incidents were increased compared to 2021. However, both years, all the incidents were small and local

and were treated immediately without problems, by implementing the contingency plans of PPA S.A.

3. Noise Monitoring Results

According to the new Environmental Terms Decision PPA SA has the obligation to implement a new

specialized Noise Monitoring Program in the entire port area.

In this context, the new Noise Monitoring Program was elaborated and it is implemented twice a year

including new indicators ( , ) etc. Eight (8) positions are examined by conducting 24-hour

environmental noise measurements lasting 4 days (96 hours) and four (4) positions by conducting traffic

load measurements. At the same time, data is being collected from three (3) Permanent Noise Monitoring

Stations (ΣΠΘ) of the PPA.

For the A Semester of 2022, the following measurements are presented:

Summary graph of sound level results at 96-hour measurement positions _A Semester 2022

2021

2022

Sea area accidental pollution

(no. of incidents)

Land area accidental pollution

(no. of incidents)

Page 55 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Position

ΣΠΘ01 – Roof of Container Terminal main

building

61,8

69,8

ΣΠΘ02 – In Container Terminal

60,8

68,7

ΣΠΘ03 – Main premises of PPA

63,4

71,3

Summary table of results from the permanent monitoring stations_ A Semester 2022

For the B Semester of 2022, the following measurements are presented:

Page 56 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Summary graph of sound level results at 96-hour measurement positions _B Semester 2022

Position

ΣΠΘ01 – Roof of Container Terminal main

building

62,4

70,4

ΣΠΘ02 – In Container Terminal

61,9

69,8

ΣΠΘ03 – Main premises of PPA

63,5

71,3

Summary table of results from the permanent monitoring stations_ B Semester 2022

The main conclusion is that some small excesses are noted in the Passenger Port, while in the rest of the

areas of responsibility of PPA S.A. (Shipyard repair zone, Container Terminals, Car Terminal, A/K Nikolaidis)

the noise levels are within the permitted limits.

4. Results of air quality monitoring measurements

Since 2009, PPA S.A. has been implementing, in cooperation with the National Technical University of

Athens, an integrated program for the monitoring of air pollution through a specialized monitoring station

in order to identify, assess and quantify the gas emissions of the port and to develop appropriate actions

and operational techniques for protecting and improving air quality in the port area.

Moreover, the Program was recently strengthened with three (3) additional permanent Air Pollution

Monitoring Stations, which were co-financed through the PPA's participation in co-financed European

Programs. According to the annual monitoring report of 2022, the following main conclusions are noticed:

▪ Volatile organic compounds (ΒΤΕΧ) are in low concentrations. The average yearly value of benzene

concentration is less than the limit value of 5.0 μg m-3. The average values of benzene, toluene,

ethylene benzene, m + p-xylene and o-xylene were determined to be 3.1, 8.4, 1.8, 5.6 και 1.9μg m-

3, respectively. The results are at the same level as the previous periods.

▪ Suspended particles vary in their concentrations. The average yearly value of suspended particles

(PM10) is 38 μg m-3 and does not exceed the limit 40 μg m-3. During the measurements, however,

the daily limit of 50 μg / m3 was exceeded in a total of 84 cases. The excesses that are observed are

mainly associated in the winter season with the known problem of smog due to burning and in the

spring with the transport of dust from other areas.

▪ The average yearly value of nitrogen dioxide ΝΟ2 is 20,3 μg m-3 and does not exceed the annual

limit of 40 μg m-3.

▪ NO2, SO2, CO did not exceed the limits of average hourly value and average eight-hour value.

▪ O3 did not exceed the average hourly rate (limit to inform) nor of the 8-hour average limit.

Page 57 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

5. Complaint Management

For the year 2022, the following two complaints were recorded:

• One (1) complaint related to air emissions from a specific vessel (Hellenic Seaways FLYING DOLPHIN

XXIX), which was submitted on 13/03/2022 by a citizen’s association (Observatory of Piraiki) and

which was addressed outside the PPA and to other related recipients, such as the Hellenic Coast

Guard and the Region of Attica. Given that the complaint was exclusively related to the operation of

the ship, the PPA responded with the 28/03/2022 electronic message listing the actions

implemented by the company within the framework of its responsibilities for monitoring the quality

of the atmosphere for all the activities that take place within the port area. However, it should be

noted that these responsibilities do not include the control of point emissions from ships, the control

of which is the responsibility of the Coast Guard. The Region of Attica/Environmental Measurement

& Hydroeconomics Control Department also responded to the complaint with its document

Φ31Z(1)/17/223831/16-03-2022, calling on the Coast Guard to take appropriate actions.

• One (1) complaint related to noise from a cruise ship (Odyssey), submitted on 21 and 30-05-2022

by citizens to the Coast Guard and forwarded to the PPA under No. 2132.22-1-07-22/ 3/6/2022

document of the Coast Guard. The PPA responded to the Coast Guard with the email from 7/06/2022

in which it is pointed out that the complaints sent to us concern the operation of a specific ship

which is a point source, while the control of the operation of ships is not the responsibility of the PPA

SA .

In 2022, no fine was imposed on the PPA for environmental issues.

6. Energy production by renewable energy sources (Container Terminal 430KWp photovoltaic power)

2022

2021

Total energy efficiency of PV power station (kWh)

682

648

Emissions’ Reduction (saving of) CO

(tn)

580

551

Table: Energy Production from renewable sources (PV Station) at the facilities of PPA S.A. and

corresponding avoidance of CO2 emissions for the two years 2021-2022.

It is noted that the reduction of CO2 emissions (tn), for reasons of comparability of results between years,

is calculated with the same coefficient of carbon footprint of electricity production.

Diagram: Energy production in MWh from the PV Station at the facilities of PPA S.A., compared for the

years from 2016 to 2023

Page 58 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

From the above data it is concluded that the P/V Station presents a stable energy production as well as a

stable contribution to the reduction of CO

emissions and therefore a stable contribution to the

improvement of the environmental footprint of the PPA.

7. Expenditures for environmental programs

Research program

COST (€)

2021

2022

Acoustic Environment Monitoring Program for the total of PPA area

22,700

21,500

Sea Water Quality Monitoring Program of PPA S.A. area

19,000

Marine Sediments Quality Monitoring Program of PPA S.A. area

16,000

Air Quality Monitoring Program

36,000

39,000

Installation of a PM

2.5

particle analyzer in the context of monitoring the Air

Quality Monitoring Program

14,000

D2. Social Issues

The Company pays particular attention to social contribution, as demonstrated and expressed through the

timeless efforts and initiatives of both Management and Employees. The Company aims to contribute to

the development of society and especially the creation of added value for the communities that surround

it.

Concession Fee

PPA S.A. pays to the Hellenic Republic an annual concession fee which, equals to three point five percent

(3.5%) of the annual Consolidated Revenue of the Company. With effect from the Effective Date of the new

concession agreement, the annual Concession Fee shall not be less than € 3,500,000. Further to the

Concession Fee, PPA S.A. pays all taxes, duties, levies, VAT, contributions and charges as imposed by

generally applicable tax law. No special privilege arising from Concession Agreement in connection with tax

matters is given to the Company.

Caring for the Society

PPA S.A. published its 4

Corporate Responsibility Report for 2021, which presents in detail all the

responsible actions and policies that the company implements, as well as its positive impact on the wider

society, the environment, the local and national economy, adopting modern and strict standards of

transparency in Sustainable Development and Corporate Responsibility. In addition to the strengthening of

the national economy and boosting the local economy employment, the table for financial support of local

communities by PPA S.A. for the year 2022 (compared with the corresponding amounts for the year 2021),

concerns the following:

2021

2022

% 2021/2022

Economic support of vulnerable social groups of neighboring

municipalities, orphanages, special schools etc

226,373

-22.88%

Facilitating the charitable effort of the Holy Metropolis of Piraeus,

Nikaia and St. Nicholas Church

40,000

Facilitating sports clubs and athletes

35,400

102,221

+188.00%

Aiding cultural associations of Piraeus Region

2,372

15,000

+532.00%

Other donations

242,150

276,090

14.02%

TOTAL

546,295

607,897

+11.28%

Page 59 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The SILO building and its adjacent spaces granted to the Greek Ministry of Culture and Sports by PPA S.A.

for the construction of the Museum of sea antiquities

The SILO building and the adjacent spaces comprising a total of 13,761 sqm. are conceded to the Ministry

of Culture and Sports by P.P.A. S.A. in a special event at the company’s premises, in the presence of the

leadership of the Ministry of Culture and Sports, PPA’s Chairman, and the Ambassador of the People’s

Republic of China in Greece. In the SILO building and the adjacent spaces, the Ministry of Culture and Sports

has planned the creation of the Museum of Sea Antiquities. The project is financed through the funds that

the Ministry of Culture and Sports has obtained through the Recovery Fund. The Museum of Sea Antiquities

will host findings from Greek seas: statues, parts of sculptures, exchange means, ship hulls and ship

equipment, weapons tools, inscriptions, toiletries, functioning and table pottery, utilities and diverse

objects obtained through underwater inspections, explorations and excavations, but also through voluntary

offerings by private individuals or seizures. The museum’s premises will exceed 13,000sq.m. and will be

divided into galleries for permanent and temporary exhibitions; facilities for educational programs, science

activities (amphitheater, library, multimedia) and preservation workshops; visitor areas (reception,

cloakroom, shop, cafe/restaurant, medical facilities), and administration offices.

Vital corporate responsibility initiatives on the occasion of Christmas

PPA S.A. on the occasion of Christmas and New Year holidays, consistently and with real commitment

implements for just another year its program, being part of the company’s broader social responsibility

strategy, involving a range of great initiatives and actions aiming at local community, port neighboring

municipalities but also employee reinforcement and broader support.

Specifically, the company has proceeded with its yearly care activity to the municipalities of Piraeus,

Salamina and Perama, offering more than 3,000 gift vouchers to children in need in their communities,

following relevant evaluation. In addition, PPA S.A. offered 1000 gift vouchers to the children of the

members of Union of Metal Workers & Employees of Attica Prefecture and workers in the Ship Repair

Industry of Greece.

Also, the support of the local social groceries, continued for a fourth consecutive year through the purchase

of necessary products and food vital for their operation, executed on a monthly basis.

In addition, the Company in collaboration with the Holy Metropolis of Piraeus, with the aim to foster the

charity work of the latter, supported its “Meals of Love” initiative donated gifts to the children in

institutions in the area.

Finally, the Management of PPA S.A. offered gifts to employees and their families along with supermarket

and toy store gift vouchers, while also proceeding with the provision of financial awards to employee

children with excellent academic performance.

Completion of restoration works at the "Saint George" Summer Camp run by the Metropolis of Nicaea at

Viotia

In 2022 the restoration works at "Saint George" Summer Camp of the Metropolis of Nicaea at Stefani

Viotia, fully funded by PPA S.A., have been successfully completed and within schedule.

More specifically, all actions and necessary building works and interventions were carried out in all three

camp building complexes, through the use of the latest technology materials to ensure the provision of safe

and high-level camp services to the children within a pleasant environment and a functional space.

Page 60 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

It is noted that the specific initiative is part of the targeted corporate social responsibility program of PPA

S.A. and confirms that the systematic support of the Greek society is a top priority and a key company

objective.

It should be also noted that the specific summer camp hosts every year children, who mainly live in the

municipalities of Keratsini- Drapetsona and Perama.

PPA S.A. supported the Perama Municipality with five vehicles

At a special event held in the presence of the Mayor of Perama, PPA announced the offer of 5 vehicles - 1

Cargo, 1 Dumper Track, 1 Personnel Transport Vehicle and 2 Fiorino Cargo - to the Municipality of Perama,

covering their total cost. PPA S.A., fully inline with the company’s CSR strategy, is steadily supporting the

local communities and neighboring municipalities of the Port of Piraeus through targeted initiatives and

actions. With this sponsorship, the Company by accepting the request of the Mayor of Perama, contributes

significantly to the improvement of the services provided by the Perama Municipality and to the coverage

of the Municipality’s increased needs, ultimately aiming at improving citizens’ quality of life.

PPA S.A. supported the event SALAMINIA 2022

PPA S.A. supported the event SALAMINIA 2022 organized by the Region of Attica and the Municipality of

Salamis, under the auspices of the Ministry of National Defence. The event's topic was "The Importance of

the Battle of Salamis for the Western World".

Educational visits

Recognizing the need to support the new generation and broaden knowledge through the educational

process, PPA S.A. through educational visits and guided tours in its premises provides the opportunity to

get acquainted with the objects of operation.

A large number of pupils and students of educational institutions of all levels, from Greece and abroad, visit

the PPA S.A. installations every year.

In 2022, due to special conditions and restrictions due to the pandemic, only a limited number of visits took

place, according to the health protocols as they were currently in force.

2022

2021

Number of

visits

Number of

people

Number of

visits

Number of

people

SECONDARY EDUCATION

HIGHER EDUCATION

360

OTHER INSTITUTIONS

TOTAL

534

Page 61 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Caring for people with mobility problems

PPA S.A. takes care to eliminate the difficulties faced by people with disabilities in the use of the Cruise and

Ferry port facilities and their movement within the passenger port.

Within this concern, the following actions are followed:

• Ferry passengers are provided with full discount/exemption for their embarkation and

disembarkation, in accordance with the applicable law.

• Employees, drivers, dockworker’s supervisors and foremen working in Cruise and Ferry Department

have participated in seminars on the management and servicing of people with mobility problems

and people with disabilities in general.

• Accessibility facilities are provided at Cruise and Ferry terminals.

• Meeting points are available at Cruise Terminals for passengers with mobility problems.

• Toilets for passengers with mobility problems are available at every cruise and ferry passenger

terminal.

• Check-in and passport control points at cruise passenger terminals are designed to facilitate people

with mobility problems.

• Specially designed water coolers placed at a proper height are operated at cruise passenger

terminals.

• All buses used for transportation within the passenger port have ramps for wheelchairs.

• Specially designed electrically driven vehicles are available for the transport of disabled passengers

and their escorts in Cruise Terminals.

• Special wheelchairs for people with disabilities are available at cruise and ferry terminals.

The Company's planning for the future includes:

• The creation, upgrading and modernization of meeting points for people with disabilities across the

passenger port.

• The improvement of the procedures for servicing passengers with special needs.

• The creation of information material on the rights of passengers with special needs.

• The informing and cooperation with all parties involved in order to provide optimal service to

passengers with special needs to the cruise terminal.

• The further training and informing of staff about servicing people with disabilities.

Page 62 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

D3. Employee Issues

1. Company’s Continuity Plan in the midst of the COVID-19 Pandemic

Within the framework created by the COVID-19 Pandemic, PPA SA, with responsibility and commitment

to its corporate values, actively participated in the effort of the Greek state to limit the spread of

coronavirus (COVID-19) and in the protection of the public and private health, successfully implementing

a set of targeted measures to combat its transmission, in accordance with the decisions and

recommendations of the Ministry of Health and National Public Health Organization, in order to ensure

the health and safety of employees, customers and users of the port, who in combination are a key pillar

of business development.

In particular, since the outbreak of the pandemic in Greece, the Company has implemented those

policies that were deemed necessary and appropriate, in order to ensure its business continuity, its

smooth operation and the reduction of negative consequences to the smallest possible extent, through

the:

➢ Ongoing market research and procurement of personal protective equipment to maintain sufficient

stock for employees

➢ Supply a sufficient number of laptops with the appropriate software, allowing remote access to

corporate resources to employees working from home.

➢ Adoption of teleworking for employees who can perform their work from home, so as to achieve

overcrowding and avoid close contacts (In total 211 employees had followed the "Work from Home"

practice with respective creation of equal amount of VPN accounts, for totally 3,432 days during the

period from 1/1/2022 έως και 31/12/2022).

➢ Taking care of those employees belonging to vulnerable groups, in accordance with the instructions

of the NPHO (EODY) and the Occupational Doctor.

➢ Encouraging business partners for the use of electronic services.

➢ Maintenance of communication channel and constant updating by the competent authorities of the

State and the Port (NPHO-EODY / Piraeus Port Health Services / Hellenic Coast Guard).

➢ Restriction (where possible) of the entry of business partners into PPA’s premises.

➢ Disinfection of public areas (most of the time on a daily basis):

- inside PPA’s buildings,

- ferry Terminal waiting rooms and Cruise Passenger Terminals

- PPA’s public buses

as well as increasing the frequency of cleaning and disinfecting workplaces where staff regularly move

such as:

- waiting rooms, garages, etc.

- vehicles / machinery used in freight loading (Cranes, RMGs, Straddle Carriers etc.).

➢ Installation of antiseptic hand bases at Cruise Terminal and PPA’s buses, as well as at key points of

the company's buildings.

➢ Installation of floor marking and plexiglass protective dividers in the passenger Terminals, in

platform scales and shuttle buses.

➢ Reproducing of informational videos of NPHO (EODY) at the passenger stations of Cruise Terminal

and at the company's HQs.

➢ Installation of A4 size laminated posters with NPHO (EODY) guidelines regarding compliance with

hygiene rules in prominent areas of the company's premises.

➢ Limitation of business trips and delegations visits to and from abroad.

➢ Encouraging the conduct of business meetings via videoconferencing.

➢ Informing of maritime agencies about the actions to be taken by crews, in case of close contacting

with PPA’s employees. (Wearing masks etc.)

➢ Equipment of the company's ambulances with the necessary materials to be ready to deal with a

potential incident.

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

➢ Creation of an Action Plan for a suspected case during work.

➢ Sending of informative messages to all employees of the company, regarding preventive measures.

➢ Supply of materials and personal protective equipment (antiseptic gels, FFP2 masks, surgical masks,

gloves etc.) and distribution to all staff.

➢ Continuous communication of the Occupational Doctor with employees presenting symptoms, in

order to provide medical instructions.

2. Safety working conditions

In addition to those mentioned in the BoD report on working safety issues, it is noted that the Company

recognizes the importance of providing safe conditions and workplaces to the staff and safe conditions

of travel - circulation of all involved, tradesmen, passengers etc.

All areas of the port are regularly inspected to ensure that employees comply with health and safety

rules of the company and the instructions of those responsible.

PPA S.A. also monitors and controls the compliance of third parties (contractors) with the Occupational

Health and Safety legislation, requiring health and safety plans before and during the implementation of

technical projects.

For this purpose, PPA SA employs two (2) safety engineers and doctors, who submit relevant reports to

the Company's Management in accordance with Law 3850/2010. It has been also set up an Employees'

Health and Safety Committee (EYAE), which consists of elected employees, has all the responsibilities

deriving from the current legislation and meets in the presence of the employer's representatives at

regular intervals.

Potential accidents are recorded and investigated, and corrective actions are planned in order not to be

repeated. Additionally, at high-risk areas (Container Terminal and Perama Shipyards Zone) the Company

provides two ambulances with trained rescue personnel that are available 24/7.

The Company carried out health and safety training sessions with the participation of 290 employees

(dock workers, supervisors - foremen, drivers and operators). The following table illustrates the

evolution in the number of accidents, the loss of working days and the number of transits from the

Container Terminal premises of the Company.

2022

2021

Number of accidents (totally declared) of which:

• Labor

• Pathologic / on arrival

Number of accidents with loss of working days based on the

ESAW methodology used by ELSTAT *

11 accidents /

675 working

days lost

4 accidents / 92

working days

lost

Ambulance services (Container Terminal)

114

Ambulance services (Ship Repair Zone)

Page 64 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

3. Leave of absence (parental, sick)

Following the aforementioned in the BoD Management Report and in accordance with the applicable

regulations, parental leave is granted for employees in order to attend school performances of children

as well as sick leave is granted. Details are shown in the below tables.

The number of employees who are entitled to parental leaves for attending their children school

performance increased (by 12.16%) from 148 employees in 2021 to 166 employees in 2022, also the

total number of parental leave granted between 2020 and 2021 increased by 49.45%, from 547 to 706.

2022

2021

Number of

employees who

have taken sick

leave

Number of sick

days leave

granted

Number of

employees who

have taken sick

leave

Number of sick

days leave

granted

661

13,447

547

12,153

With regard to the granting of sick leave, it is noted that the number of employees who have used sick

leave increased by almost 12.08% between 2021 and 2022 (from 547 to 661 respectively) and the total

number of sick leave days increased comparatively by 10.64% (from 12,153 days in 2021 compared to

13,447 in 2022).

4. Educational and training programs

In addition to those mentioned in the BoD Management Report, on staff education and training

programs, the table below provides detailed information on educational programs that took place in

2022 and the participation of employees in them.

2022

2021

Percentage of trained employees

56,2 %

38,6%

32.38 %

Training man hours

4,604

1,930

Total training cost (€)

66,982.48

48,420.00

From the above analysis it follows that education is always a development objective of the PPA S.A., in

ordeto improve its services and increase its productivity, while implementing measures in accordance

with the decisions and recommendations of the Ministry of Health and the ESA, with a view to ensuring

the health and safety of workers. In 2022 the number of trainings and participants increased

significantly compared to 2021, as most of the trainings were carried out through Web Seminars.

The objective of the Company remains the increase in the number of training courses for the following

years as well.

2022

2021

Number of beneficiaries for parental leave

166

148

Number of parental leaves given

706

547

Page 65 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

5. Employee Associations / Unions

In PPA S.A. are active total four (4) primary Associations (Association of Permanent Employees, Union of

Technicians and Operators, Association of Dockworkers, Association of Supervisors & Foremen) and one

(1) secondary Association (Federation of Permanent Port Employees of Greece). The Management of the

Company is in close collaboration with employee representatives in order to achieve the proper

functioning of its services and to promote the common interest of the Company and its employees.

6. Additional Social Benefits

Under current operational collective labor contracts, the Company offers to its staff additional social

benefits. In particular, the Company grants interest –free loans to its employees up to amount of 3.000 €

to cover exceptional and unforeseen needs, wedding assistance, creches and camps costs for the

children of staff, prizes for the children of staff with excellent school performance, donation of gifts and

voluntary blood donation leaves, under the conditions that apply for all employees without any

discrimination.

In particular for 2022, there were provided:

o 39 awards of excellence, towards 51 in 2021,

o 33 marriage grants, towards 23 in 2021,

o camping allowance for 96 employees’ children, towards and 79 in 2021,

o loans for 144 staff members towards 135 in 2021,

o nursery allowance for 46 employees’ children towards 44 children in 2021.

D4. Respect of Human Rights

Protection of personal data

The Company being in compliance with the European General Data Protection Regulation 2016/679

which came into force on 25 May 2018 establishing a single legal framework across the EU for the

protection of personal data, as it is demonstrating through the year’s great dedication and sensitivity

regarding the management and protection of personal data, takes all necessary steps to ensure that its

entire staff is sensitized and constantly working to be compliant with the New GDPR Regulation.

The company recognizes that transparency and accountability are the basis for a trustworthy

collaboration with its customers, whereas legitimate and sensitive handling of personal data is equally a

critical issue to the company and its employees.

For any information or questions regarding the protection of Personal Data or the exercise of legal rights

in relation to Personal Data you can contact us at gdpr@olp.gr.

D5. Anti – Corruption and Bribery Matters

1. PPA S.A. Code against Corruption and Bribery

ΡΡΑ S.A. is committed to its activities in accordance with the applicable National and European

Legislation and commercial customs and this commitment is incorporated into the present Code. PPA

S.A. considers that on Company level, participation in corruption phenomena inflicts the reputation,

credibility of the Company itself, causes penal consequences and other legal risks as well as financial

damage (in the case of fines imposition), increases operational cost, affects the loyalty and faith of

Company personnel, creates negative corporate culture and causes exclusion from potential business

opportunities. It is also considered, as "bribery" any offer of any object with value, with the view to

influence a decision for conducting operational activities with PPA S.A. or providing an illicit advantage,

including assurance of cooperation, maintenance of existing cooperations or provision of any

Page 66 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

inappropriate advantage, therefore it implements its professional activity with strict ethical compliance

procedures.

The absolute commitment of this Company to the above principles implies zero tolerance to bribery and

corruption practices and professional integrity by which it launches its business dealings, relationships

and transactions. Finally, PPA S.A. acknowledges that corruption distorts business environment and

causes unfair competition and therefore any business active in a certain field, in which corruption

incidents take place, is in danger of presenting reduced revenues and loss of turnover (e.x. loss of a

project, because a competitor took up a project with bribery).

The purpose of the Code against corruption and bribery which approved by BoD decision 40/2022 is the

absolute compliance of the personnel of the Company, including managers, financial directors, Top

Management members and members of the Board of Directors external associates, suppliers and

contractors of the Company with the relevant European and Greek Legislation.

2. Regulation for the award of works, Services, and Procurement

According to the approved Regulation for the award of works, Services, and Procurement, the Company

implements control procedures, under penalty of exclusion, through the obligation to submit certificates

issued by the local competent judicial authority:

a) participation in criminal organizations within the meaning of Article 2 of Council Framework Decision

2008/841/JHA of the Council of October 24

2008 for the combat against organized crime;

b) bribery within the meaning of Article 2(1) of Council Framework Decision 2003/568/JHA of the

Council of July 22

2003 for the combat against bribery in private sector;

c) fraud within the meaning of Article 1 of the Convention to protect the financial interests of the

European Communities;

d) terrorism or terrorism – related crimes as defined in Articles 1 & 3 of Council Framework Decision

2002/475/JHA of the Council of June 13

2002;

e) money laundering within the meaning of Article 1 of the Directive 2005/60/EC of the Council of

October 26

2005;

f) child labour and other offences concerning trafficking in human beings, as defined in Article 2 of the

Directive 2011/36/ΕC of the Council of April 5

2011;

g) embezzlement, fraud, extortion, forgery, perjury, bribery, fraudulent deliberate bankruptcy,

according to the Greek Penal Code or crimes similar in their specific aspects to the above, provided for

in foreign legal orders.

3. General Staff Regulation (GSR)

According to the article 17.4 of the General Staff Regulation (GSR) are clearly considered (among others)

as disciplinary offences the following:

- Solicitation or acceptance of any fee, consideration or favorable treatment from any person whose

affairs are managed by the employee concerned as part of his/her duties;

- Any action that is detrimental to Company's reputation, staff or any individual member of the staff, in

relation to their duties;

- Participation, whether directly or through third parties, in any auctioning procedure carried out by the

Company;

- Engagement in private activities for profit or in any form of remunerated employment, save where this

is requested and specifically authorized by the CEO. Such authorization is granted, provided that the

employee's performance within the Company is not howsoever impaired.

- Any act that constitutes a criminal offence, if committed on or off the PPA premises by an employee

during the performance of his/her duties or if committed on the PPA premises during or after the

Page 67 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

employee's work time; In this latter situation, the act constitutes a disciplinary offence only if it is

directly and seriously harmful to the employment relationship.

- Failure to prosecute or sanction a disciplinary offence;

- Any acts or omissions committed by fault, potentially capable of causing material or moral damage to

the Company or to any member of its staff;

- Any act of mismanagement;

Also according to the article 17.6 of the GSR temporary or permanent suspension (dismissal) may be

imposed (among others) in respect of the following offence:

- Acceptance of any fee or consideration from any person whose affairs are managed by the employee

concerned as part of his/her duties;

- Characteristically improper or indecent conduct demonstrated by an employee either on or off

Company's premises;

4. Internal Complaint Process (ICP)

Through the PPA S.A. Internal Complaint Process (ICP) as described in the Code of Conduct, provides the

chance for complaints submission on issues related to Fraud and Corruption / Bribery.

D6. Supply Chains

1. Contracts and Subconcessions Regulations

The aim of the Contracts and Subconcessions Regulations (which entered into force by the CEO’s

Decision No. 833/04-10-2019) is to create a stable reference framework for the Company and its related

traders, in the regulated sectors. This Regulation is more simplified in fulfilling the procurement process.

Furthermore, backbone of the Regulation is primarily to serve the interests of the Company and the

strict compliance towards obligations that arise from Concession Agreement, through the proper

selection of the most appropriate counterparty, in financial terms and in terms of adequacy.

Furthermore, the Regulation sets the general award procedures, with reference to the respective

Declaration and context for signing a contract for the case when specific setting of the award conditions.

This option provides greater flexibility and simplification of procedures, which may contribute decisively

to the fulfillment of the Mandatory Investment Program completion timelines.

With the application of Contracts and Subconcessions Regulations, Company fulfills its obligation to

respect the principles of transparency, publicity and equal treatment in the awarding of project

execution, studies and services, as reflected in the provision of art. 8 par. 2 N. 4404/2016.

2. Procurements

For its procurement needs, PPA S.A., pursuant to the Contracts and Subconcessions Regulations (CEO’s

Decision No. 833/04-10-2019) fulfills the statutory obligation to observe the principles of transparency,

publicity and equal treatment in the award of works, studies and services, as reflected in the relevant

provision of Law 4404/2016 as in force.

In the year 2022, PPA S.A. conducted 106 open tenders including selective bid invitations with a total

contractual value of € 23.5 million, with average number of bidders (an average of 3 - 4 participants per

tender).

The Company's main suppliers come from both the National and International markets. The rules of

cooperation between them are in line with the prevailing market conditions.

Page 68 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

3. Establishment of Approved Contractors Register

Further to the already existing Contractors Register in Project categories and Implementation of

European programs and Tourist services, , PPA S.A. published and completed tender procedure for the

creation of an approved Suppliers Register in the categories of provision of handling – driving and labor

services, electomechanical type of supplies and spare parts, and supplies and servicers for IT

department. In addition, 7 more Contractors Register for PPA’s needs have already been

published/under evaluation of offers or are ready to be published and will be concluded within the next

few months. The contractors’registers created following open invitation procedures for each category

with specific criteria and will be evaluated regularly by PPA. Suppliers will have specific rights and

obligations. Regarding the process of creating the Contractors’ Register, Procurement Department has

contacted operational Departments to investigate the needs, the criteria, the prerequisites and the way

they are evaluated.

Page 69 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

E. Related Parties

The Company provides services to certain related parties in the normal course of business. The

Company’s transactions and account balances with related companies are as follows:

31.12.2022 89,054,072.42 54,892.48

31.12.2021 78,206,476.27 73,513.45

31.12.2022 310,866.55

19,680.45

31.12.2021 44,934.22

9,112.93

31.12.2022

52,991.58 11,050.00

31.12.2021

36,555.59 -

31.12.2022

- -

31.12.2021

27,300.00 -

31.12.2022

3,023.42 -

31.12.2021

- -

31.12.2022

- 142,465.99

31.12.2021

- 9,244.91

31.12.2022

16,464.90 -

31.12.2021

- -

31.12.2022

- 142,958.00

31.12.2021

- 106,346.61

31.12.2022

727.82

31.12.2021

- -

31.12.2022

- 674,937.19

31.12.2021

- 509,727.44

31.12.2022

- 75,245.15

31.12.2021

- 83,570.51

31.12.2022

- 29,463.04

31.12.2021

- 95,145.41

31.12.2022 89,437,418.87 1,151,420.12

31.12.2021 78,315,266.08 886,661.26

31.12.2022 4,889,650.89 5,416.16

31.12.2021 2,635,950.59 7,776.48

31.12.2022

482.00 39,353.25

31.12.2021

- 35,164.30

31.12.2022

18,414.00 -

31.12.2021

- -

31.12.2022

1,397.58 15,578.00

31.12.2021

- -

31.12.2022

646.50

31.12.2021

- -

31.12.2022

- 685,638.70

31.12.2021

- -

31.12.2022

- 15,474.70

31.12.2021

- -

31.12.2022

- 277.56

31.12.2021

- -

31.12.2022

181.91 -

31.12.2021

181.91 -

31.12.2022 4,910,126.38 762,384.87

31.12.2021 2,636,132.50 42,940.78

COSCO SHIPPING DEVELOPMENT CO. LTD

Related Party

COSCO SHIPPING TECHNOLOGY (BEIJING)

Related Party

COSCO SHIPPING SPECIALIZED CARRIERS CO.LTD

Related Party

QINGDAO OCEAN SHIPPING SERVICES

Related Party

COSCO (HONG KONG) INSURANCE BROKERS L.T.D.

Related Party

PCDC S.A.

Related Party

DIAMOND LINES GMBH

Related Party

PIRAEUS CONTAINER TERMINAL S.A

Related Party

COSCO SHIPPING LINES GREECE S.A.

Related Party

Relation with

the Company

Year ended

Amounts due from

related parties

Amounts due to related

parties

COSCO SHIPPING PORTS LIMITED

Related Party

COSCO (HONG KONG) INSURANCE BROKERS L.T.D.

Related Party

COSCO SHIPPING TECHNOLOGY (BEIJING)

Related Party

COSCO SHIPPING GLOBAL EXH

Related Party

QINGDAO OCEAN SHIPPING SERVICES

Related Party

COSCO SHIPPING TECHNOLOGY Co LTD

Related Party

DIAMOND LINES GMBH

Related Party

COSCO SHIPPING DEVELOPMENT CO. LTD

Related Party

COSCO SHIPPING SPECIALIZED CARRIERS CO.LTD

Related Party

PCDC S.A.

Related Party

PIRAEUS CONTAINER TERMINAL S.A.

Related Party

COSCO SHIPPING LINES GREECE S.A

Related Party

Related party

Relation with

the Company

Υear ended

Sales to related parties

Purchases from related

parties

Page 70 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The revenues of € 82,720,264.87 (2021: € 70,097,734.43) (Note 24) from Piraeus Container Terminal S.A.

(PCT S.A.) are related to the fixed and variable revenue from the concession agreement (PIER II & III) and

revenues of € 6,333,807.55 (2021: € 8,108,741.83) related to mooring and loading/unloading. Besides, PPA

in April 2020, signed a contract about the provision of project management services with PCT S.A. for the

business operation of Pier I of PPA S.A. On December 29, 2020, the letter of guarantee from PCT S.A. with

the amount € 42.0 million, reduced by 50% to € 21.0 million in previous year, and the letter of guarantee

with the amount € 475,000.00, reduced from € 950,000.00 by 50% in previous year, were returned to PCT

S.A. On the same date, a new letter of guarantee of € 663,000.00 regarding the rest of the construction of

the west side of Pier III for the construction works of Pier II and III was received (Note 22). This letter of

guarantee expired on December 29, 2022.

The transactions with COSCO SHIPPING LINES GREECE S.A. relate to ship services.

The transactions with COSCO SHIPPING GLOBAL EXH relate to exhibition expenses.

The transaction with COSCO SHIPPING TECHNOLOGY (Beijing) relates to software update .

The transaction with COSCO (HONG KONG) INSURANCE BROKERS L.T.D. of the current and the previous

year relates to the insurance coverage of PPA S.A. regarding third party liability, employer' s liability,

property and business interruption and directors and officers liability, according to article 17 of the

Concession Agreement (Law 4404/2016).

The transaction of the current and the previous year with COSCO SHIPPING PORTS LIMITED is related to

software for the purchase of software and tax interconnection services with the SAP software.

The transaction with COSCO SHIPPING TECHNOLOGY Co. LTD relates to software support costs.

Board of Directors Members Remuneration: During the year 2022, remuneration and attendance costs,

amounting to € 1,105,404.21 (2021: € 889,082.91) were paid to the Board of Directors members.

Furthermore during the year ended December 31, 2022 emoluments of € 338,557.41 (December 31, 2021:

€ 554,857.42) were paid to Managers / Directors for services rendered.

The Extraordinary General Meeting of the Company's shareholders on September 23, 2019 approved the

long-term incentive bonus plan, which is cash settled of a certain number of Units. Beneficiaries of the

program are members of the Board of Directors, senior executives and other key management and

business executives who have a significant influence on the performance and uninterrupted operation of

the Company (Note 29).

Page 71 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

F. GOING CONCERN DISCLOSURE:

The Company, for the preparation of the Financial Information of December 31, 2022, has adopted the

going concern basis. For the application of this principle, the Company took into account the current

financial developments as well as the risks arising from the financial environment and made estimates

for the shaping, in the near future, of the trends and the economic environment in which it operates.

The main factors that can affect the implementation of this principle are mainly related to the economic

environment in Greece and internationally as well as the ongoing Russia/Ukraine conflict with the

resulting issues in the energy sector and rising inflation.

As part of the consideration of whether to adopt the going concern basis in preparing the financial

statements, management has considered the Company’s financial performance in the year, as well as a

quantitative viability exercise, including the performance of various stress tests that consider the

Company’s principal risks, including that relating to climate change, and confirms the Company’s ability

to generate cash in 12 months from the date of approval of the financial statements and beyond. The

Company’s strong balance sheet and liquidity position, its operation in several segments, the strong and

dynamic management and the experienced human resources as well as the fact that the war in Ukraine

has not affected significantly the Company’s operations, will allow the Company to successfully

overcome any period of uncertainty.Therefore, it is deemed appropriate that the Company continues to

adopt the going concern basis for the preparation of the financial statements.

Accordingly, and having reassessed the principal risks, the Directors continue to adopt the going concern

basis of accounting in preparing the Annual Financial Statements and have not identified any material

uncertainties to the Company's ability to continue trading as a going concern over a period of at least 12

months from the date of approval of annual financial statements.

Piraeus, March 17 , 2023

THE CHAIRMAN OF BoD

YU Zeng Gang

Page 72 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

STATEMENT OF CORPORATE GOVERNANCE

(Article 152 of L. 4548/2018)

Ι. Code of Corporate Governance

Law 4706/2020 (Government Gazette 136 / Α / 17-7-2020), on Corporate Governance of public limited

companies, modern capital market, which incorporated in Greek legislation the Directive (EU) 2017/828

of the European Parliament and Council, measures to implement Regulation (EU) 2017/1131 and other

provisions, as well as Decision 2/905 / 3.3.2021 of the Board of Directors of the Hellenic Capital Market

Commission establish the obligation to adopt and implement the Corporate Governance Code, which

has been prepared by a body of known prestige.

The Company, in compliance with the requirements and regulations of the said law, implements with a

relevant decision of its Board of Directors the Code of Corporate Governance, of the Hellenic Corporate

Governance Council issued in June 2021, the text of which is available at website of the Company at the

following link: https://www.esed.org.gr/en/code-listed.

The implementation of this Code aims at the continuous improvement of the corporate institutional

framework and the wider business environment, as well as the improvement of the Company's

competitiveness as a whole.

Deviation from the Corporate Governance Code

The Company fully complies with the provisions of the relevant Greek legislation, rules and regulations

and internal corporate values for the development of corporate governance principles it applies and has

adapted to those defined by the existing institutional framework of corporate governance.

As mentioned above, following a Board of Directors decision and in accordance with article 17 of law

4706/2020, it implements and adopts the Hellenic Corporate Governance Code (HCGC, June 2021) of

the Hellenic Corporate Governance Council (HCGC). HCGC 2021 of HCGC is available at the following

link: https://www.esed.org.gr/web/guest/code-listed.

The Company has not adopted some specific practices of the Code that are specifically mentioned below

but remains faithful to its commitment to take all the necessary actions for the implementation of the

provisions of Law 4706/2020:

Deviation from the Special practice of Code 1.13: “ The non-executive members of the Board of

Directors meet at least annually, or exceptionally when judged appropriate without the presence of

executive members in order to discuss the performance of the latter. At these meetings the non-

executive members shall not act as a de facto body or a committee of the Board of Directors. ”.

Explanation: The individual evaluation process from the non Executive BoD members regarding the

effective fulfillment of the duties of the executive BoD members was not considered necessary at the

present time. Given the BoD term of office which expires in July 2023, it was decided by the non-

executive members of the Company's Board of Directors that the performance of the effectiveness of

the BoD and its executive members will be evaluated annually by the Ordinary General Assembly, at the

same time as the evaluation of the annual financial statements of the Company and the relevant reports

in combination with the results of use and the general course of the Company's operations.

Page 73 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Deviation from the Special practice of Code 2.2.15: “ The company ensures that the diversity criteria

concern, in addition to the members of the Board of Directors, senior and/or senior management with

specific representation objectives by gender, as well as timetables for achieving them. ”.

Explanation: Due to the particular nature of the sector of the port industry in which the Company

operates and given that the overwhelming percentage of its staff is employed in labor-intensive

activities (dockworkers, operators of lifting machines, drivers of heavy-duty vehicles, workshop staff,

etc.), it is not possible to define and ensure specific goals of representation by gender, (beyond the BoD

members in accordance with the provisions of Law 4706) among the Managerial staff. Apart from the

BoD members for the selection of which the Company applies the diversity criteria provided for in the

BoD Suitability Policy, no specific gender representation goals and specific timetables for their

achievement have been set for the selection of the Company's Managerial staff. However, the

Company's Code of Conduct, which is uploaded on the Company's website, states (Chapter of Equal

Opportunities) that the Company promotes a work environment that respects equality, individual rights

and diversity no matter on characteristics such as age, gender, race, nationality and physical ability. On

31.12.2022, the participation of women in all of the Company's managerial positions amounted to

32.65%.

Deviation from the Special practices of Code: 2.2.21: “ The Chair shall be elected by the independent

non-executive members. In the event that the Chair is elected by the non-executive members, one of

the independent non-executive members shall be appointed, either as vice-chair or as a senior

independent member (Senior Independent Director)”. 2.2.22: “ The independent non-executive Vice-

Chair or Senior Independent Director shall, as appropriate, have the following responsibilities: to

support the Chair, to act as a liaison between the Chair and the members of the Board of Directors, to

coordinate the independent non-executive members and lead the evaluation of the Chair”. 2.2.23:

“Where the Chair is an executive, then the independent non-executive vice-chair or the senior

independent member (Senior Independent Director) shall not replace the Chair in his executive duties.”.

Explanation: The Company's BoD, when constituted as a Body, applies the provisions of article 8 of Law

4706/2020 "In the event that the BoD appoints one of the executive members as Chairman, it must

appoint a Vice-Chairman from among the non-executive members". In addition, 70% of the members of

the Company's existing BoD are Non-Executive members, while the Chairmen and the majority of the

members of the Article 10 Committees (Audit, Remuneration, Nomination) are Independent Non-

Executive members. Taking into account the above, the Company's BoD considers that the non-

appointment of one of its members as Senior Independent Director does not create any problem in its

orderly operation and the fulfillment of its duties, as well as that the burden of the independent non-

executive members with the additional burden of the object of the Vice Chairman of the BoD was not

desirable, while it might cause obstacles in the work of the above Committees. With the above specific

balance, its efficient and productive operation has been ensured during all the last years.

Deviation from the Special practices of Code: 2.3.1: “ The company has a framework for filling positions

and succession of the members of the Board of Directors, in order to identify the needs for filling

positions or replacements and to ensure each time the smooth continuation of the management and

the achievement of the company's purpose”. 2.3.2: “ The company ensures the smooth succession of

the members of the Board of Directors with their gradual replacement in order to avoid the lack of

management.”. 2.3.3: “ The succession framework shall in particular take into account the findings of

the evaluation of the Board of Directors in order to achieve the necessary changes in composition or

skills and to maximise the effectiveness and collective suitability of the Board of Directors.”.

Page 74 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Explanation: Regarding to the succession of the BoD members, given that the term of office of the BoD

members is one year, it was not considered appropriate at this particular time to have a procedure for

the prior and ongoing activity of the Nominations Committee. In the event of the need to replace one or

more members of the Board of Directors, the Nominations Committee is activated to find suitable

candidates for new members in accordance with the Company's Nominations Policy in order to carry out

the replacement of members, the procedure defined in the Committee's Operation Regulation and the

BoD Operation Regulation.

Deviation from the Special practice of Code 2.3.4: “ The company also has a succession plan for the

Chief Executive. The preparation of an integrated succession plan for the Chief Executive shall be

entrusted to the nomination committee, which in this case shall be responsible for: (a) identifying the

required quality characteristics that the Chief Executive should have, (b) ongoing monitoring and

identification of potential internal nominees, (c) where appropriate, search for potential external

nominees, (d) and a dialogue with the Chief Executive on the evaluation of nominees for his / her

position and other senior management positions. ”.

Explanation: The company has not formulated a special succession plan for the CEO, as the CEO is

replaced (by BoD decision), in case of absence or impediment, by the Chief Financial Officer who is also

an executive BoD member. In addition, the CEO has four (4) Deputies CEO, thus ensuring the smooth

continuity of the management of the Company's affairs and its daily corporate operation.

Page 75 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

ΙΙ. Description of the main features of the Company’s internal control and risk management

systems in relation to the financial reporting process

II.1. The internal control system of the Company covers adequately the control procedures involving risk

management and preparation of financial reports.

II.2. In respect of the preparation of financial statements, the Company considers its accounting system

adequate for reporting to the Management and external users. The financial statements are prepared in

compliance with the International Financial Reporting Standards, as adopted by the European Union for

reporting purposes to the administration, and also for the purpose of publication in line with the

applicable regulations (hereinafter, “IFRS”). All reports include the data of the current period, compared

to the respective data of the Budget as approved by the Board of Directors, and to the data of the

respective period of the year before the report. All published interim and annual financial statements

include all necessary information and disclosures in compliance with the IFRS, are reviewed by the Audit

Committee and are approved in their entirety by the Board of Directors.

II.3. Safeguards are implemented with respect to: a) supervision and approval of all important

transactions through the structural hierarchy of the Company; b) monitoring of financial figures and risk

evaluation as for the reliability of the financial statements; c) fraud prevention and tracking; and d)

protection of data provided by information systems.

II.4. The internal reports to the Management and the reports required from the provisions of the

legislation and by the supervisory authorities are prepared by the Financial Management Department,

which is staffed with adequate and experienced executives to this effect.

II.5. The statutory auditors of the Company KPMG Certified Auditors S.A. (Greek AM SOEL 114), i.e. the

statutory audit firm of financial statements of the Company for the year ended on 31 December 2022,

are not related to the Company or to any persons having supervisory responsibilities over the

Company’s financial reporting in ways which could be considered as affecting their independence as of

the date of this report. Therefore, they remain independent within the meaning of Article 21 of Law

4449/2017.

II.6. Provision of non-audited services by statutory Auditors: The statutory auditors do not offer to the

Company non-audit services which are prohibited, as per the provisions article 5 of Regulation (EU)

537/2014 of the European Parliament and of the Council and of Law 4449/2017, that are relevant to the

audit of the financial statements in Greece.

The non-audit services that have been provided to the Company, during the year ended as at 31

December 2022, are disclosed in the note 24 to the financial statements.

III. Reference to the information required by points (c), (d), (f), (h) and (i) of paragraph 1 of

article 10 of the Directive 2004/25/EC

The above information is included in another part of the Management Report, i.e. in the Explanatory

Report of the Board of Directors according to article 4, par. 7 and 8 of Law 3556/2007.

Page 76 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

IV. Composition and operation of the administrative, management and supervisory bodies of

the Company

IV.1. General Assembly of Shareholders

1. The General Assembly of the shareholders of the company is the supreme body of the Company and

is entitled to decide on any affair regarding the Company. Its legal resolutions also bind the absent or

disagreeing shareholders.

2. The General Assembly of shareholders is convened by the Board of Directors and meets obligatorily at

the seat of the Company or in the region of another municipality within the region where the seat of the

company is located, at least once in any corporate fiscal year until the tenth (10th) calendar day of the

ninth month at the latest after the end of the corporate financial year. It may also be convened at the

region of the Municipality, in which the seat of the Athens Stock Exchange is located.

3. The General Assembly has a quorum and validly meets on the issues of the daily agenda, provided

they are present or represented therein shareholders representing at least one fifth (1/5) of the paid

share capital. If no such quorum occurs at the first meeting, a repetitive General Assembly is convened

within twenty (20) days from the date of the cancelled meeting, which is convened at least ten (10) days

prior to this meeting, unless the procedure of article 9 par. 5 last sentence of these articles of

association has been applied. This repetitive General Assembly has quorum and validly meets on the

issues of the initial daily agenda, whichever is the part of the paid share capital of the company, which

represented in the meeting. The resolutions of the General Assembly are taken upon full majority of the

votes represented in the meeting.

4. Until the election of its Chairman, performed by the same meeting with a simple majority, in the

General Assembly chairs the Chairman of the Board of Directors or his/her alternate. The Chairman of

the meeting may be assisted by a secretary and a teller, elected in the same way. The Chairman checks if

the convocation of the General Assembly follows the normal procedure, the identity and legalization of

those present in the meeting, the accuracy of the minutes, administers the discussion, sets the issues on

vote and announces the results of the vote.

5. The discussions and resolutions of the General Assembly are limited to the issues of the daily agenda.

The result of the voting is announced by the Chairman of the General Assembly as soon as it is

confirmed. The company, under the responsibility of its Board of Directors, publishes in its website the

results of the voting within maximum five (5) days from the date of the General Assembly, specifying for

each resolution at least the number of shares for which valid votes were given, the percentage of the

share capital that is represented by these votes, the total number of valid votes, as well as the number

of votes for and against each resolution and the number of the absences.

IV.2. Board of Directors

1. The Company is managed by the Board of Directors composed by nine (9) to thirteen (13) members

(directors), elected by the General Assembly, subject to paragraph 2 below, with absolute majority of

the represented votes, for a duty up to five (5) years, which is extended until the expiry of the deadline,

within which the next ordinary General Assembly following directly the previous one must be convened

and until the adoption of the relevant resolution.

2. As long as the Hellenic Republic Asset Development Fund S.A. or any global successor or successor by

operation of law of the Hellenic Republic Asset Development Fund S.A. (each and collectively, the

“FUND”) holds at least one million two hundred and fifty thousand (1,250,000) voting shares and less

than 10% of the voting shares issued by the Company and subject to the FUND is entitled to appoint one

(1) Member pursuant to article 79 of Law 4548/2018 as in force. If the FUND holds at least 10% of the

voting shares, the FUND is entitled to appoint 1/3 of the total number of Members of the Board of

Directors of the Company.

Page 77 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

3. Should any Director appointed pursuant to paragraph 2 of this article resign or become incapacitated

for whatever reason, they shall be replaced by such persons the HRADF shall specify in a pertinent

written notice to the Company, with immediate effect.

4. The directors, shareholders and non-shareholders may always be reelected and are freely revocable.

5. Member of the Board of Directors may also be a legal person. In this case the legal person is obliged

to appoint a natural person for the exercise of the powers of the legal person as member of the Board of

Directors. This appointment is subject to publicity according to article 13 of the L.4548/2018. The

natural person is jointly and severally liable together with the legal person for the company's

management.

6. The Board of Directors consists of executive, non-executive and independent nonexecutive members.

7. Executive members are those who deal with the day-to-day management of the Company. The

executive members of the Board of Directors, in particular: (a) are responsible for the implementation of

the strategy determined by the Board of Directors and (b) consult at regular intervals with the non-

executive members of the Board of Directors on the most appropriate strategy to be implemented. In

situations of crisis or risk, as well as when circumstances require it to take measures that are reasonably

expected to significantly affect the Company, such as when decisions are to be made regarding the

development of the business and the risks that are expected to affect the financial situation of the

Company, the executive members inform the Board of Directors in writing without delay, either jointly

or separately, submitting a relevant report with their estimates and proposals.

8. The non-executive members of the Board of Directors, including the independent nonexecutive

members, have, in particular, the following obligations: (a) They monitor and examine the Company's

strategy and its implementation, as well as the achievement of its objectives. (b) Ensure effective

oversight of executive members, including monitoring and control of their performance. (c) Examine and

express views on the proposals submitted by the executive members, based on existing information.

9. The number of non-executive members of the Board of Directors must not be less than 1/3 of the

total number of members, including independent non-executive members.

10. Independent non-executive members are those members who are elected by the General Assembly,

or appointed by the Board of Directors (according to par. 4 of article 9 of Law 4706/20120), who are free

from financial, business, family or other relationships of dependency with the Company or with persons

related to it, which may influence their decisions and their independent and objective judgment, and

meet the additional conditions provided by the relevant legislation (article 9 of Law 4706/2020),

including non-executive obstruction assistance and not exceeding the maximum permitted percentage

of their participation in the share capital of the Company.

Power - Duties of the Board of Directors

1. The Board of Directors, acting collectively, exercises the management of the Company and exercises

control over its all activities. Manages the corporate property, represents the Company and makes

decisions on all matters concerning the Company with a view to promoting the corporate purpose,

except for matters relating to the exclusive responsibilities of the General Assembly of Shareholders.

It is further responsible for the complete and effective control of the Company's activities and acts in

accordance with the provisions of the law and the articles of incorporation.

Page 78 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The main responsibilities of the Board of Directors include:

• The drawing up of strategic directions, including the sale or otherwise disposal of the Company's

shares, the acquisition of any company or the proposal to merge the Company with another company,

which are subject to the final approval of the General Assembly of the shareholders.

• The management and disposal of the corporate property and the representation of the Company in

court and out of court.

• The conclusion and receipt of loans on behalf of the Company.

• The conclusion of any kind of contract, subject to articles 99 -101 of Law 4548/2018 and agreements

with any third physical or legal persons.

• Ensuring the completeness and reliability of the data and information required for the accurate and

timely determination of the financial situation of the Company and the preparation of reliable financial

statements, as well as its non-financial situation, according to article 151 of law 4548/2018.

• The preparation of the annual budget and the business plan of the Company.

• Defining and achieving the Company's efficiency goals.

• Monitoring the progress of the Company and the control of large capital expenditures.

• Ensuring the adequacy and efficiency of the Company's Internal Control System, which aims in

particular:

a) the consistent implementation of the business strategy,

b) the identification and management of material risks associated with its business and operation,

c) the efficient operation of the internal control unit.

• Ensuring that the functions of the Internal Audit System are independent of the business sectors they

control, and that they have the appropriate financial and human resources, as well as the powers to

operate them effectively.

• The definition of the strategy and business risk management of the Company.

• The formulation, dissemination and application of the basic values and principles of the Company that

govern its relations with all parties, whose interests are related to those of the Company.

• The convergence of the General Assemblies (regular or extraordinary) and the determination of the

issues of its agenda.

• The preparation of the Company's remuneration policy, which is submitted for approval by the

General Assembly of Shareholders (following a relevant proposal of the Remuneration Committee).

• The submission of a proposal for approval by the General Assembly of Shareholders for the

distribution of dividends.

• The submission of a proposal for approval by the General Assembly of Shareholders for the election of

Statutory Auditors, for the regular audit of the financial statements of the Company (following a

relevant proposal of the Audit Committee).

• The submission of a proposal for approval by the General Assembly of Shareholders for the eligibility

policy of the members of the Board of Directors (as well as any substantial modification) and its posting

on the Company's website.

• The preparation of training policy for the members of the Board of Directors and executives of the

Company.

• The approval and any revision of the Internal Regulation of the Remuneration Committee as well as

the Nominations Committee (following a relevant suggestion of the above Committees).

• The responsibility for the compliance of all types of activities of the Company with the regulatory and

legislative framework, as well as the internal regulations governing the operation of the Company.

• The succession planning for the members of the Board of Directors and the Chief Executive Officers.

Page 79 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The annual collective evaluation of the effective BoD functioning, the fulfillment of its duties as well as

its committees.

The adoption of a calendar of meetings and an annual action plan, at the beginning of each calendar

year, which is revised according to the developments and needs of the Company, in order to ensure the

correct, complete and timely fulfillment of its duties.

• Supervising the implementation as well as ensuring the adequacy and effectiveness of the corporate

governance systems on which the Company operates and taking appropriate action to address

deficiencies.

• The appointment of the head of the Internal Audit Service of the Company.

• The possibility of assigning the duties of Coordinator or Mandated Advisor to one or more of its

members.

2. The Board of Directors may, only and exclusively in writing, assign the exercise of all its powers and

duties, save these requiring a collective action, as well as the representation of the company to one or

more persons, members of the Board of Directors, managers and employees of the company or third

parties, by specifying at the same time the scope of such assignment as well. All these persons may, as

long as it is provided by the relevant resolution of the Board of Directors, assign further the exercise of

the powers entrusted to them or part of these powers to other members or third parties.

Constitution of the Board of Directors

1. The Board of Directors elects one of the Directors as Chairman and may designate up to two (2) other

Directors as Vice Chairmen.

2. The Chairman of the Board of Directors chairs its meetings and exercises the responsibilities provided

by law and the articles of association. When the Chairman is absent or hindered, he shall be replaced by

the appointed for this purpose Vice Chairman.

3. In case the Board of Directors, by way of derogation from par. 1, of article 8 of law 4706/2020

appoints as Chairman one of the executive members of the Board of Directors, it obligatorily appoints a

vice-chairman from the non-executive members.

4. The Board of Directors elects a Member as the Chief Executive Officer of the Company. The Chief

Executive Officer and the Chairman may be the same person.

Convocation of the Board of Directors

1. The Board of Directors should meet any time provided by law, the articles of association or required

under the needs of the company.

2. Meetings of the Board of Directors shall convene within the Municipality of the registered office of

the Company or alternatively within the prefecture of the Municipality of the registered office of the

Athens Exchange. Alternatively, meetings of the BoD may convene in Mainland China or Hong Kong.

3. The Board of Directors may duly meet at another place out of the seat of the company, located either

in Greece or abroad, provided that in this meeting all the members of the BoD are present or

represented, and no member objects to the execution of the meeting and to the adoption of

resolutions.

Page 80 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

4. The invitation to the members of the Board of Directors may provide that the meeting of the Board of

Directors will take place through conference call for some or for all members. In this case, the invitation

addressed to the members of the Board of Directors includes the necessary information and technical

instructions about their participation in the meeting.

5. The Board of Directors is convened by the Chairman or Vice Chairman who chair its meetings, upon

invitation notified to its members at least two (2) working days prior to the meeting, and at least five (5)

working days if the meeting is going to be held in a location outside the seat of the company. In the

invitation the issues of the daily agenda must be stated clearly, otherwise the adoption of resolutions is

permitted only if present or represented are all the members of the Board of Directors and none objects

to the adoption of resolutions.

The composition of the Board of the Directors has as follows:

Name BoD position

BoD

Meetings

(Total 10)

Gender

Number of BoD

meetings taken place

within 2022, during

the BoD Member

term of office

Percentage of

participation in

BoD meetings

Initial date of

undertaking of

terms office (prior

to the current term)

Date of

commencement

of term office or

re-election

End of term

of office

Yu Zenggang BoD Chairman, Executive Member 10 M 10 100,0% 5/6/2019 13/7/2022 13/7/2023

Zhang Anming Acting CEO, Executive Member 10 M 10 100,0% 24/7/2020 13/7/2022 13/7/2023

Li Jin CFO, Executive Member 10 F 10 100,0% 13/7/2021 13/7/2022 13/7/2023

Zhu Jianhui

BoD Vice Chairman, Non Executive

Member

9 M 10 90,0% 10/8/2016 13/7/2022 13/7/2023

*Feng Boming Non Executive Member 2 M 3 66,7% 10/8/2016 28/4/2022

Yu Tao Non Executive Member 10 F 10 100,0% 6/12/2021 13/7/2022 13/7/2023

Kwong Che Keung

Gordon

Independent, Non Executive Member 10 M 10 100,0% 10/8/2016 13/7/2022 13/7/2023

IP Sing Chi Independent, Non Executive Member 10 M 10 100,0% 10/8/2016 13/7/2022 13/7/2023

Arvanitis Nikolaos Independent, Non Executive Member 10 M 10 100,0% 1/4/2016 13/7/2022 13/7/2023

Moralis Ioannis Independent, Non Executive Member 8 M 10 80,0% 13/10/2014 13/7/2022 13/7/2023

Politis Dimitrios Non Executive Member 9 M 10 90,0% 31/8/2021 13/7/2022 13/7/2023

* Mr. Feng Boming was a non-executive member of the Board until 28.04.2022, the date on which he submitted his resignation.

Assertion of compliance with independence criteria for Independent BoD members (par. 3 article 9 of

Law 4706/2020)

The Board of Directors, following a relevant recommendation of the Nominations Committee,

ascertained (BoD 20/2022) that each of the four (4) independent members (a) KWONG Che Keung

Gordon, (b) IP Sing Chi, (c) ARVANITIS Nikolaos, (d) MORALIS Ioannis, at the time of their appointment

met all suitability and reliability criteria included in the Suitability Policy, for their election as members

of the Company's Board of Directors, and the conditions of independence defined in article 9 par. 1 and

2 of law 4706/2020, as in force, as well as that there are no obstacles or incompatibility in the face of

any Candidate in relation to any relevant provisions, including the Corporate Governance Code (HCGC)

applied by the Company and the Rules of Operation of the Company. [...]».

In particular, none of the above, directly or indirectly held a percentage of voting rights greater than

zero-point five percent (0.5%) of the share capital of the Company and each of them was free from

financial, business, family or other dependent relationships, which may influence their decisions and

their independent and objective judgment.

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Furthermore, from the performed audit and from the relevant personal declarations submitted by each

of the above independent members, it had been confirmed that, apart from the criteria of par. 1 of

article 9 of Law 4706/2020, as in force, the indicative dependence criteria of par. 2 of article 9 of Law

4706/2020, as in force, are not met either, as each of the above proposed independent members:

Did not receive any significant remuneration or benefit from the Company, or from a company affiliated

with it, nor participated in a stock options scheme or in any other remuneration or benefit system

related to the performance, other than the fee for their participation in the Board of Directors or its

committees, nor participates in the collection of fixed benefits under the pension system, including

deferred benefits, for previous services to the Company.

Had neither the same nor a person, who had close ties with it, a business relationship during the last

three (3) financial years before their appointment with: ba) the Company or bb) a person affiliated with

the Company or bc) a shareholder who directly or indirectly held a participation percentage equal to or

greater than ten percent (10%) of the share capital of the Company during the last three (3) financial

years before their appointment, or a company affiliated with them, if this relationship affected the

business activity of either the Company or the candidate independent non-executive member of the

Board of Directors of the Company or the person who had close ties with them.

Had neither the same nor a person who had close ties with it had: ca) served as member of the Board of

Directors of the Company or any company affiliated thereto for more than nine (9) financial years in

total at the time of their election, cb) been an executive or maintained an employment or contractor or

services provision relationship or a paid mandate with the Company or with a company affiliated with it

during the last three (3) financial years prior to its appointment, cc) a second degree kinship by blood or

by marriage, or is a spouse or partner equated with a spouse, member of the Board of Directors or

senior executive or shareholder, with a participation percentage equal to or greater than ten percent

(10%) of the share capital of the Company or a company affiliated with it, cd) been appointed by a

certain shareholder of the Company, in accordance with the articles of association, as provided in article

79 of law 4548/2018, ce) been nominated as represented of shareholders who directly or indirectly hold

a percentage equal to or greater than five percent (5%) of the voting rights at the General Assembly of

the Company's shareholders during his/her term of office, without written instructions, cf) conducted a

mandatory audit of the Company or a company affiliated with it, either through a company or himself

or a second-degree relative by blood or by marriage of him/her or his/her spouse, during the last three

(3) financial years prior to his/her appointment, cg) been assigned as an executive member in another

company, in the Board of Directors of which an executive member of the Company participates as a

non-executive member.

Board of Directors and Committee Evaluation Process – Results of Evaluation Process

In compliance with the provisions of Law 4706/2020, Circular 60 of the Capital Market Commission, the

Hellenic Code of Corporate Governance and the Internal Operating Regulations of the Board of

Directors, the Company commissioned, following a competitive process, the assessment of the

adequacy and effectiveness of the Board of Directors and its Committees to an external consultant.

The BoD Assessment Policy and the BoD Operation Regulation provides for the annual evaluation of the

effectiveness of the Board of Directors (as a collective body), its committees and their individual

members, while this evaluation is provided by an external consultant every three years. To this end, as

mentioned above, the Company awarded (December 2022), following a tendering process, to the

company ERNST AND YOUNG Single Member Societe Anonyme for the Provision of Advisory Services to

carry out the evaluation process.

Page 82 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The evaluation concerned the collective abilities of the Board of Directors as a body, its committees and

the individual abilities of its members. The evaluation was carried out using evaluation tools provided by

the external advisor (filling out an electronic questionnaire, etc.) and through personal interviews. The

evaluator had access to the BoD’s and BoD’s Committees operating details.

The purpose of the evaluation was to determine whether the Board and its Committees function

effectively and efficiently, based on the Board Directors’ responses to the online questionnaires

covering a wide range of topics, documentation review and selected interviews with Board Directors.

The conclusion of the above evaluation states, among other things, the following:

“Based on the evaluation of the Board of Directors and its Committees, with a reference date of March

02, 2023, nothing has come to our attention that could be considered a significant weakness in the

operation of the above entities or required to be taken as immediate corrective action pursuant to the

current Legislative/Regulatory Framework.

The Board operates effectively and in a manner that encourages open and frank discussion where all

Board Directors feel free to express their views.

The reviews of the performance of the Board’s Committees did not raise any significant issues and the

evaluation concludes that the Committees are operating effectively and are highly rated overall. In

respect to the evaluation of Individual Directors, it is concluded that each Director performs effectively

and demonstrates commitment to their role, as does the Chairperson of the Board”.

The above result is a confirmation of both the proper functioning of the Board of Directors and its

compliance with the current legislative and regulatory framework.

External professional commitments of the BoD members.

With a solemn declaration, the BoD members informed twice, about their other professional

commitments, that they do not participate in more than three (3) Boards of Directors of listed

companies.

The General Assembly of July 13th 2022 approved the re election of existing BoD members for one year.

The term of the above Board of Directors expires on July 13th 2023.

Determination of fulfillment of conditions of par.1 of article 9 of Law 4706/2020

The Board of Directors of the Company during its meeting of June 21st, 2022, in the context of the

review, the fulfillment of the conditions for the characterization of its members as independent (in

order to be nominated for election by the General Assembly of Shareholders), and following a related

proposal of the Nominations Committee carried out an audit and found that are applied the

independence conditions of Mr. (a) KWONG Che Keung Gordon, (b) IP Sing Chi, (c) ARVANITIS Nikolaos,

and (d) MORALIS Ioannis. Each of the four independent BoD members also submitted a relevant

responsible declaration.

BoD members' Remuneration

The remuneration of the members of the Board of Directors is determined by the Remuneration Policy,

which was prepared in the context of article 110 of Law 4548/2018 and includes all the information

provided for in article 111 of Law 4548/2018. The existing Policy was approved by the Extraordinary

General Assembly of September 23rd, 2019 (quorum: 85.60%, votes in favor: 83.66% of the represented

shareholders) The Policy is available on the corporate website www.olp.gr in the most specific option:

Organization > Corporate Governance > Policies.

Page 83 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Regarding Executive BoD Members

During the fiscal year 2022 and in compliance with the approved Company Remuneration Policy, the

remuneration of the Executive BoD Members shall be analyzed as follows:

Fixed Remuneration of Executive BoD Members

During the fiscal year 2022, the Company held contracts of employment with the Executive Members of

BoD, Mr Yu Zeng Gang (Chairman), Mr Zhang Anming (CEO), Ms LI Jin (CFO). These contracts of

employment were for an indefinite period and included a monthly salary and ancillary benefits, and

applied to those requirements of the labor law relating to periods of notice, retirement and the

payment of legal compensation in the event of termination of the contract. Furthermore, the above

Executive BoD Members received fees for their participation in the meetings of the BoD (in proportion

to the period of expiry or the beginning of their term of office within the year) which had been approved

by the Decision of 13/07/2022 of Annual General Assembly (40,000.00€ annually per Member).

Variable remuneration of Executive BoD Members

During the fiscal year 2022, no variable remuneration was paid to any Executive Member of BoD. All the

above remuneration of the Executive BoD Members shall be subject to the deductions provided for in

the applicable tax and labor legislation.

Regarding Non-Executive BoD members

During the fiscal year 2022 and in compliance with the approved Company Remuneration Policy, the

remuneration of the Non-Executive BoD Members shall be analyzed as follows:

Fixed remuneration of Non-Executive BoD Members

During the fiscal year 2022, the Non-Executive BoD members received fees for their participation in the

meetings of BoD, which were approved by the Annual General Assembly Decision of 13/07/2022

(€40,000.00 annually per Member).

Variable remuneration of Non-Executive BoD Members

During the fiscal year 2022 no variable remuneration was paid to any non-executive BoD member. All

the above remuneration of the Non-Executive BoD members shall be subject to the deductions provided

for in the applicable tax and labor legislation.

Shares and/or stock options for shares

The Company has not granted any shares or stock options for shares to either the BoDs or the DCEOs.

Use of retrievability of variable remuneration

The Company did not make use of the possibility to recover variable remuneration during the fiscal year

2022.

CV’s of members of the BoD and Deputies CEO

CV’s of the BoD members

Below are presented the CV’s of the members of the Board of Directors members pursuant to the

provision of Article 18 of Law 4706, 2020 which can are available on the web page of the Company, at

the link https://www.olp.gr/en/about-us/corporate-governance/board-of-directors.

Page 84 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Mr. Yu Zenggang

Mr. Yu Zenggang is Executive Vice President and Member of China COSCO SHIPPING Corporation

Limited. He started his career in August 1984, and served as the Chief Representative of the Japan

Representative Office of Shanghai Shipping Bureau, BoD Member and President of Shanghai Haixing

Shipping (Japan) Co. Ltd., Deputy General Manager, General Manager of the Development Division of

China Shipping (Group) Company, Executive Vice President of China Shipping (North America) Holding

Co., Ltd., President of China Shipping (Europe) Holding GmbH, General Manager of the President Office

of China Shipping (Group) Company, Director of BOD Office and General Office, Executive Vice President

and BOD Secretary of China Shipping (Group) Company. He has over 35 years’ working experience in

shipping industry, and has abundant expertise in corporate management, corporate governance,

overseas port industry development, international operation, and listed company management. Mr. Yu

Zenggang graduated from Wuhan University of Technology with a Bachelor’s Degree of engineering

science in 1984 and obtained the Master’s Degree in from CEIBS (China Europe International Business

School).

Mr. Zhang Anming

Mr. Zhang Anming has over 25 years of work experience in the shipping industry. Mr. Zhang has

extensive experience in container shipping and management. He has served (period 1996-2002 and

2009-2012) from different financial managerial positions COSCO Container Lines Ltd, while he had

international working experience from serving as Deputy General Manager of COSCO Container Lines in

Italy (period 2002-2008). In 2012 he appointed as Deputy General Manager and in 2016 Managing

Director of Piraeus Container Terminal SA. He graduated from Peking University, Guanghua School of

Finance and Management.

Mr. Zhu Jianhui

Mr. Zhu Jianhui possesses extensive professional knowledge in ocean shipping and logistics

management and also has rich experience in corporate operation and management. Mr. Zhu was

graduated from Shanghai Maritime College (now known as Shanghai Maritime University) and obtained

a Master's degree. He is a senior economist.

Ms. LI Jin

Ms. LI serves since May 2020 till today as a Deputy Chief Executive Officer and Chief Financial Officer of

PPA SA. Ms. LI has over 25 years’ professional experience and throughout her career professional served

COSCO Ocean Shipping, China COSCO Holding and COSCO SHIPPING in various Financial Managerial

positions up to the General Manager of Finance Division level and she has international working

experience by serving COSCO SHIPPING Group, In Oceania and Europe. Ms. LI got the senior accountant

qualification certificate and senior economist qualification certificate in 2008, and became a Certified

management accountant in 2015. Ms. LI participated in “the National Accounting Leading Talents

training project” which was organized by Ministry of Finance of the People’s Republic of China from

2012 to 2019 and in “the special training course for international talents” which was organized by China

COSCO Shipping Group in 2019. Ms. LI graduated from Beijing Vocational College of Finance and

Commerce and holds a bachelor’s degree in International Credit and Investment and a Master’s Degree

in Finance from Beijing Central University of Finance and Economics.

Page 85 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Mr. Kwong Che Keung Gordon

Mr.Kwong has been the Independent Non-executive Director of the COSCO SHIPPING INTERNATIONAL

(HONG KONG) CO., LTD since July 2020. Mr. Kwong is also independent nonexecutive director of a

number of listed companies in Hong Kong, namely, Agile Group Holdings Limited, Chow Tai Fook

Jewellery Group Limited, FSE Lifestyle Services Group Limited, Henderson Investment Limited,

Henderson Land Development Company Limited. Mr. Kwong graduated from The University of Hong

Kong with a bachelor’s degree in social sciences in 1972 and is a fellow member of the Institute of

Chartered Accountants in England and Wales and the Hong Kong Institute of Certified Public

Accountants respectively. Mr. Kwong was a partner of international accounting firms from 1984 to 1998

and an independent member of the Hong Kong Stock Exchange Council from 1992 to 1997, during which

he had also served as Chairman of both the Listing Committee and the Compliance Committee of the

Hong Kong Stock Exchange. He has over 40 years of experience in accounting and auditing, as well as

long experience in port industry.

Mr. Ip Sing Chi

Mr. Ip Sing Chi is the Group Managing Director of Hutchison Port Holdings Limited and the chairman of

Yantian International Container Terminals Co., Ltd. He is also an executive director of Hutchison Port

Holdings Management Pte. Limited (the Trustee-Manager of Hutchison Port Holdings Trust, listed in

Singapore, stock code NS8U), an outside director of Hyundai Merchant Marine Co., Ltd. (listed in Korea),

an independent non-executive director of COSCO Pacific Limited (listed in Hong Kong) and a non-

independent non-executive director of Westports Holdings Berhad (listed in Malaysia). Mr. Ip was the

founding chairman (in 2000-2001) of the Hong Kong Container Terminal Operators Association Limited.

Mr. Ip was a non-executive director of Tradelink Electronic Commerce Limited (listed in Hong Kong). Mr.

Ip has over 30 years of experience in the maritime industry, and holds a Bachelor of Arts degree.

Mr. Nikolaos Arvanitis

He studied and participated in seminars in the Maritime Economics, in the Management and

Organization of Shipping Companies and in Combined Transport. He has been graduated from BCA

College of Athens, London School of Foreign Trade and City of London Polytechnic. He started his career

in 1980 in London at FENTON STEAMSHIP CO, a subsidiary of Hellenic Lines LTD, and continued in Top

Management positions in Piraeus at ZIM HELLAS SA 1984-2010 and at VISTA MARITIME & LOGISTICS LTD

since 2010.

He has participated since April 2000, as an elected member of the BoD of the International Maritime

Union, (an institution representing the agencies of international shipping companies in Greece) and was

elected President of the BoD for two consecutive terms Apr. 2006 - Mar- 2012. In June 2013 the

International Maritime Union BoD unanimously named him as Honorary President. Due to his

institutional role as President of the International Maritime Union, he participated in working

committees and meetings on issues related to the Port Industry, Shipping Policy, Customs and

Regulation Issues, in collaboration with the Ministry of Merchant Shipping & Island Policy, the General

Secretariat of Ports Policy and Maritime Investments, the PPA SA and other Port Organizations, the PCT

SA, the Customs Administration. He has participated in many national and international conferences on

port industry development, liner shipping services, combined transport and supply chain & Logistics

infrastructure. His articles and interviews have been published in many magazines, newspapers and

media both in Greece and abroad.

Page 86 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Ms. Yu Tao

Ms. Yu Tao is economist (graduated from University of International Business and Economics) and she

also holds a Master degree in Business Administration (Guanghua School of Management Peking

University), while she has significant experience in the following areas:

• "International Transportation"

• "Business Administration"

• "Import/Export trade"

• "Logistics"

• "Shipping Lines Management"

• "Container Lines Management".

Ms. YU Tao has also served in various management positions (Deputy Chief Executive Officer) at COSCO

Logistics Co., COSCO Container Lines Co., and COSCO SHIPPING Lines Co.

Mr. Moralis Ioannis

Mr. Moralis Ioannis studied at the finance department of the University of Piraeus. Son of the late

Minister Petros Moralis was always interest in citizenship and politics but without having actively joined

a political party. He works since the age of 22 years old. For more than 20 years he was engaged in

Piraeus both as a freelancer in the field of Sports Marketing and communication, as well as the strain

Olympiacos FC having taken major positions of responsibility. In 2011 he was appointed Vice President

and General Manager of Olympiacos FC. In 2012 he was elected Chairman of the Super League. In 2014

and in 2019 he was elected Mayor of Piraeus.

Mr. Dimitris Politis, Chief Executive Officer of Hellenic FUND

Dimitris Politis is a graduate of the American College of Greece and holds an MBA in International

Business & Export Management from City University Business School in London, as well as various

professional certifications. Since 1993, he has held positions of responsibility at international financial

organizations. He began his career at HSBC Bank PLC, initially in Athens and then in London, in the

Sector of Investment Banking, covering Greece and the wider region of Southeast Europe and the

Middle East. He returned to Athens in 2001 as head of Credit Commercial de France, and in 2003 he

returned the HSBC Bank plc Greece as Head of Corporate & Institutional Banking. From 2012 to

September 2020, he worked at Credit Suisse AG, based in Zurich, as head of Wealth Management

UHNWI for Greece and Cyprus while in October 2020 he took on the same role at EFG Bank AG, based in

Zurich. Mr. Politis is highly experienced in attracting and managing investments in strategic sectors of

the economy and has close professional relationships with international institutional and private

investors.

CV’s of Deputies CEO

Captain Jin Beiyuan has ten years’ officer experience on Ocean Going Ship from 1991-2002. Since then

he has served for China Shipping Container Line as planner and operator, General Manager of China

Shipping Europe Holding operator and planner department, General Manager of China Shipping (France)

Agency, Vice General Manager of China Shipping Car Carrier Company Limited, and General Manager of

Guangzhou Cosco Shipping Car Carrier company limited. He now serves as Deputy CEO in Piraeus Port

Authority (since 2022).

Mr. QU Shengbin is a Senior Economist and holds a University Degree and an MSc in Transportation

Planning and Management. He has two decades of work experience in the shipping and logistics

industry. He joined the COSCO family initially working and gaining extensive business experience,

covering a wide range of fields such as shipping agent, cargo forwarder, air cargo transport, project

logistics, project management, etc.. He then enriched his company management experience, serving as

top management member in COSCO Logistics ShenZhen, KunMing, GuangXi and PENAVICO FangCheng.

Furthermore, Mr. Qu was appointed to upper managerial positions in COSCO SHIPPING headquarters, in

both the Operation Management Division and the Strategic and Corporate Management Division. He

now serves as Deputy CEO in Piraeus Port Authority (since 2022).

Page 87 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Mr. Angelos Karakostas joined COSCO SHIPPING Lines (Greece) S.A. in 1997 as General Manager. In

2009, he was appointed Deputy General Manager of the Piraeus Container Station (PCT SA). In August

2016, he took over the duties of Deputy CEO of the Port of Piraeus SA. He holds a degree in

Mathematics and a postgraduate degree in Business Research from the University of Patras. He holds an

MBA and an MSc in Management from Teeside University of the United Kingdom.

From the above Members of the Board and Company Executives Mr. Nikolaos Arvanitis, Independent

Board Member on 31/12/2022 held 500 shares of PPA SA and Mr. Angelos Karakostas on 31/12/2022

held 1559 shares of PPA SA.

For the fiscal year 01.01.2022-31.12.2022, the compensations paid to the Board of Directors members

are those provided in the current Remuneration Policy and as has been approved by General Assembly

of Shareholders decision (gross annual compensation for each Board of Directors member of the

amount of € 40,000.00).

It is to be noted that in 2022, the Company prepared the members of the Board of Directors

remuneration report for fiscal year 01.01.2021-31.12.2021 in accordance with article 112 of Law

4548/2018. The remuneration report was discussed at the Regular General Assembly of the Company on

13.07.2022, which was attended by shareholders representing 76.95% of the share capital, while the

percentage of "FOR" votes amounted to 97.82% of the shareholders present. The remuneration report

for the fiscal year 01.01.2021-31.12.2021 is available on the Company's website:

https://www.olp.gr/en/about-us/corporate-governance/board-of-directors.

IV.3. Administration Board

1. The Administration Board operates within the Company, supports and advises the other bodies of the

Company in the discharge of duties thereof and takes decisions on the matters, which have been

assigned thereto by virtue of a relevant decision of the Board of Directors.

2. The Administration Board consists of the Chairman of the Board of Directors, the CEO, the Deputies to

the CEO, whoever they are each time. The composition of the Administration Board may be extended by

decision of the Board of Directors or of the Chairman of the Board of Directors.

3. Upon invitation by the Chairman of the Board of Directors, to the meetings of the Administration

Board may attend and participate, without the right to vote, external Advisors of the Company and the

each time responsible managers or acting managers of departments of the Company, for matters

related to their responsibilities.

IV.4. Audit Committee

The Audit Committee operates in accordance with the provisions of article 44 of L.4449/2017. It is a

Committee of the Board of Directors and is composed of three (3) non-executive members of the Board

of Directors, of which two (2) are independent under article 9 of Law 4706/2020, which were appointed

by the BoD meeting that took place on 13.07.2022.

Page 88 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

During the fiscal year 2022, the Audit Committee’s composition was as follows:

- Kwong Che Keung Gordon, Board of Directors independent Non-Executive Member and Chairman of

the Audit Committee.

- Arvanitis Nikolaos, Board of Directors independent Non-Executive Member and Member of the Audit

Committee.

- Politis Dimitrios, Board of Directors Non-Executive Member and Member of the Audit Committee.

The term of office of the Audit Committee will be equal to the term of office of the elected Board of

Directors of the Company, whose term of office is annual, ie until 13.07.2023, which is extended, in

accordance with the provisions of article 85, par. c of Law 4548/2018 until the expiration of the

deadline, within which the next Ordinary General Meeting must be convened in 2023 and until the

relevant decision is taken.

The members of the Audit Committee, all non-executive members, did not hold positions incompatible

with their status during 2022, while both their objectivity and independence were ensured, in the

absence of any transaction with the Company that could affect them.

The main responsibilities of the Audit Committee is to assist the work of the Board of Directors in the

execution of its duties by overseeing the financial information procedures, policies and internal control

system of the Company. Its responsibilities are defined by the current legislation (Law 4449/2017) as in

force, within the current institutional framework and corporate governance principles regarding

companies whose securities are traded on a regulated market (listed companies) and its Operation

Regulation, which has been approved by the BoD and is uploaded to the company’s website.

During 2022, the Audit Committee met five (5) times while additionally in five (5) other cases decisions

were issued through circulation of minutes. All its members participated in all meetings.

In order to ensure the Company’s independence, the meetings took place without the presence of other

top management executives, except in cases where their presence was deemed necessary (such as the

cases of discussion of the review of the interim and annual Financial Reports). All Committee members

participated in all the meetings and all Committee decisions were taken unanimously.

The main issues handled by the Audit Committee in 2022 were the following:

➢ Monitoring and evaluation in collaboration with the competent bodies of the Management and the

External Auditor of the Company the process of preparation of the semi-annual and annual Financial

Statements, prepared in accordance with the International Financial Reporting Standards, and

confirmation of their accuracy and completeness, according to the information provided to its members.

➢ Evaluation of the Financial Statements of the Company (annual and semi-annual) and confirmation

of their completeness and consistency, before their approval by the Board of Directors.

➢ Discussion with the External Auditor and receiving information about their cooperation with the

Management in issues of financial control.

➢ Discussion and provision of its agreement to all official announcements concerning the Company's

financial issues.

➢ Evaluation and approval of the internal audit program and then reviewed the results of the audits

carried out by the Internal Audit Department.

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(amounts in Euro unless stated otherwise)

➢ Monitoring the effective operation of the internal control and risk management system, in

accordance with international standards and the applicable legal and regulatory framework.

➢ Provision of its consent to the proposal of the Board of Directors to the Ordinary General Meeting of

Shareholders for the appointment of the auditing company “KPMG Certified Auditors S.A.”, for the

mandatory audit of the Company for the year 2022.

➢ Evaluation and confirmation the objectivity and independence of the cooperating External Auditor,

receiving a relevant letter.

➢ Assessing the nature and cost of the non-audit services provided by the auditing firm “KPMG

Certified Auditors S.A.” and confirmation that they do not pose a threat to the independence of the

latter regarding the regular audit of the fiscal year 2022, in accordance with the provisions of

L.4449/2018 and Regulation 537/2014 of the EU.

➢ It is noted that the external auditors did not provide the Company with non-audit services prohibited

according to Article 5 of the European Union (EU) Regulation No. 537/2014 or other permitted non-

audit services.

➢ Information towards the Board of Directors of the Company about the issues within its competence.

A self-assessment process of the Audit Committee took place in the form of a questionnaire. The

structure of the questionnaire was designed to assist and to provide guidance to PPA SA Audit

Committee in evaluating the key roles, responsibilities and general effectiveness of its operation and

identify any weaknesses that should result in an action plan for improving its performance to an

acceptable level, by including questions that have been selected from the Legislative and Regulative

framework applied for its operation. Through the above self-assessment process, no issues were

identified, which need corrective actions.

In carrying out its work in general, the Audit Committee had full access to all the information necessary

for the effective performance of its duties. The discussions and the decisions of the Audit Committee are

recorded in minutes signed by the members.

I.V.5. Nomination Committee

The Nomination Committee operates in accordance with the provisions of articles 10 and 12 of

L.4706/2020. It is a Committee of the Board of Directors and is composed of three (3) non-executive

members of the Board of Directors, of which two (2) are independent under the article 9 of Law

4706/2020, which were appointed by the BoD Meeting of Shareholders that took place on 13.07.2022.

During the fiscal year 2022, the Nomination Committee’s composition was as follows:

- IP Sing Chi, Board of Directors independent Non-Executive Member and Chairman of the Nomination

Committee.

- ZHU Jianhui, Board of Directors Non-Executive Member and Member of the Nomination Committee.

- Kwong Che Keung Gordon, Board of Directors independent Non-Executive Member and Member of the

Nomination Committee.

Page 90 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The term of office of the Nomination Committee will be equal to the term of office of the elected Board

of Directors of the Company, whose term of office is annual, i.e. until 13.07.2023, which is extended, in

accordance with the provisions of article 85, par. c of Law 4548/2018 until the expiration of the

deadline, within which the next Ordinary General Meeting must be convened in 2023 and until the

relevant decision is taken.

The members of the Nomination Committee, all non-executive members, did not hold positions

incompatible with their status during 2022, while both their objectivity and independence were

ensured, in the absence of any transaction with the Company that could affect them.

The responsibilities and the mode of operation of the Nomination Committee are described in the

updated Internal Operation Regulation of the Committee, which has been approved by the Board of

Directors and is available at website of the Company.

During 2022, the Nomination Committee met four (4) times. All its members participated in all

meetings.

To ensure the independence of the Nomination Committee, the meetings were held without the

presence of other members of the Management. All the members of the Committee attended all the

meetings and all the decisions of the Committee were taken unanimously.

The main issues handled by the Nomination Committee in 2022 were the following:

➢ The continuation of the collective suitability and diversity of the Board of Directors, in such a way

that the composition of the Company’s Board of Directors, fully covers the appropriate and suitable

exercise of the responsibilities of the Board of Directors of the Company, and reflects the size and

activity of the Company and can further contribute to the implementation of its business objectives.

➢ The taking into account expiration of the Company’s Board of Directors term of office, submission of

proposal to the Board of Directors for the election of persons suitable for the acquisition of the status of

a Board of Directors member, based on factors and criteria of individual and collective suitability

determined by the Company, in accordance with the suitability policy that it has adopted, through the

initiation of the suitability assessment process by the existing Board of Directors members, as initial

candidates for the acquisition of the status of a Company's Board of Directors member.

➢ Regarding the (individual and collective) suitability criteria of the candidates for election as members

of the Board of Directors, the Committee took into account:

- the verification of the fulfillment of the eligibility criteria of the candidates for election as Company's

Board of Directors members,

- the thorough examination of the detailed CVs of each of the candidate BoD member,

- the overview of the participation and in general presence of the candidates in the meetings of the

existing Board of Directors of the Company throughout its term of office, of which the candidates are

members,

- the establishment of independence of their judgement, the possibility of allocating the necessary time

for the fulfillment of their duties,

- the adequacy of knowledge (including sufficient knowledge in the Company's field of activity, in

particular in the subject in which the Company operates, the skills

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

- the experience required to perform their duties,

- the processing on a case-by-case basis, in accordance with the approved Eligibility Policy of the

Company, responsible declarations about the non-assistance of incompatible / obstacles, educational

qualifications, certificates, excerpts from the criminal record, etc..

➢ Regarding the conditions and criteria of independence, regarding the verification of the fulfillment of

the criteria and conditions, independence, within the meaning of article 9 par. 1 and 2 of Law

4706/2020, as applicable, of the candidates for election as members of the Company's Board of

Directors, the Committee:

- received responsible statements from the proposed independent members, regarding their

independence towards the Company, within the meaning of article 9 par. 1 and 2 of Law 4706/2020, as

applicable,

- carried out an investigation and audit of the Company's share register and found that the case of

article 9 par. a of Law 4706/2020, as applicable, does not apply,

- carried out an investigation and audit of the Company's accounting books and contracts and found that

none of the proposed members is an important customer or supplier of the Company and that none of

the cases of article 9 par. 2 of the law. 4706/2020, as applicable.

➢ The based on the above, submission of a proposal by the Committee to the Company’s BoD, in order

to recommend to the Ordinary General Assembly of Shareholders of the Company, that the new

Company’s BoD have the following composition, which fully meets the requirements of law 4706/2020

on corporate governance and fully covers the appropriate and appropriate exercise of its responsibilities

for the benefit of its Shareholders.

➢ The supervision of the preparation of the introductory information program of the BoD members in

the context of fulfilling their duties and according to the BoD operational needs.

➢ The BoD members appointed during 2022 have received an Induction Program whose main

objectives were to (a) communicate the Company's vision and culture, (b) communicate practical

procedural duties, (c) reduce the time taken for them to become productive in their duties, (d) become

familiar with the Company's organizational structure, (e) give them an understanding of Company's

business and strategy and the markets in which it operates, (f) to provide a link with the Company’s

people and an understanding of its main relationships. Also, the BoD members, upon their appointment

received information material of Company’s Obligations towards Supervisory Authorities, aiming to

inform them on their main obligations under the legislative and regulatory framework that the Company

operates.

➢ The organizing (in Dec. 2022), of a training session conducted by Hellenic Corporate Governance

Council, for the field of ESG and Sustainability.

➢ The approved by BoD the at least once per year attendance by BoD Members of training sessions

provided by Hellenic Corporate Governance Council, in a range of courses and educational services

designed to improve skills and understanding about corporate governance issues.

➢ The evaluation of the fulfillment of the independence criteria of the Independent Non-Executive BoD

Members, according to the definition of the law, as well as the evaluation of the existence of conflicts of

interest to the extent that hinders the ability of Members to perform their duties independently and

objectively will).

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(amounts in Euro unless stated otherwise)

➢ The submission of proposal to BoD for the update of PPA SA Nomination Committee Operation

Regulation.

➢ The submission of proposal for the update of PPA SA Suitability Policy of BoD members.

➢ The submission of proposal for the update of PPA SA Diversity Policy of PPA SA BoD members.

➢ The submission of proposal for the update of PPA SA Succession planning policy for the BoD

members and the Executive Officers.

➢ The information towards the Company’s BoD about the issues within its competence.

IV.6. Remuneration Committee

The Remuneration Committee operates in accordance with the provisions of articles 10 and 11 of

L.4706/2020. It is a Committee of the Board of Directors and is composed of three (3) non-executive

members of the Board of Directors, and all of them are independent under the article 9 of Law

4706/2020, who were appointed by the BoD Meeting of Shareholders that took place on 13.07.2022.

During the fiscal year 2022, the Remuneration Committee’s composition was as follows:

- ARVANITIS Nikolaos, Board of Directors independent Non-Executive Member and Chairman of the

Remuneration Committee.

- IP Sing Chi, Board of Directors independent Non-Executive Member and Member of the Remuneration

Committee.

- KWONG Che Keung Gordon, Board of Directors independent Non-Executive Member and Member of

the Remuneration Committee.

The term of office of the Remuneration Committee will be equal to the term of office of the elected

Board of Directors of the Company, whose term of office is annual, ie until 13.07.2023, which is

extended, in accordance with the provisions of article 85, par.1 c of Law 4548/2018 until the expiration

of the deadline, within which the next Ordinary General Meeting must be convened in 2023 and until

the relevant decision is taken.

The members of the Remuneration Committee, all non-executive members, did not hold positions

incompatible with their status during 2022, while both their objectivity and independence were

ensured, in the absence of any transaction with the Company that could affect them.

The responsibilities and the mode of operation of the Remuneration Committee are described in the

updated Internal Operation Regulation of the Committee, which has been approved by the Board of

Directors and is available at website of the Company.

During 2022, the Remuneration Committee met three (3) times. All its members participated to all

meetings.

To ensure the independence of the Remuneration Committee, the meetings were held without the

presence of other members of the Management, All the members of the Committee attended all the

meetings and all the decisions of the Committee were taken unanimously.

The main issues handled by the Remuneration Committee in 2022 were the following:

➢ The submission of proposal to the Company’s BoD, for the setting up of the regular remuneration up

to the amount of 40.000€ per annum, for the newly elected BoD members.

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(amounts in Euro unless stated otherwise)

➢ The submission of a proposal to the Company's BoD for the Remuneration Report of the members of

the Board of Directors for the year 2021.

➢ The submission of a proposal to the Company's BoD for the pre-approval by the Ordinary General

Assembly of the BoD members remuneration for the year 2022.

➢ The submission of a proposal to the Company's BoD regarding the remuneration of persons falling

within the scope of the remuneration policy, in accordance with article 110 of N. 4548/2018.

➢ The submission of a proposal to the Company's BoD for updating the Operating Regulations of PPA

SA Remuneration Committee based on the recommendations of the Auditing Company KPMG, in the

context of the PPA SA Internal Control System evaluation.

➢ The further Implementation of the Company's Long-term Incentive Bonus Plan of the Company.

➢ Conducting contacts of the Committee’s Chairman with the Senior Management of the Company on

issues related to the responsibilities of the Committee, as well as initiating a process of possible

updating of policies and procedures related to the remuneration of persons falling within the scope of

remuneration policy.

➢ IV.7. Periodic Evaluation Policy of the Internal Control System of PPA SA and Implementation of

the provisions on Corporate Governance of Law 4706/2020 – Internal control system evaluation

results is expected by KPMG

1. Key Elements

PPA S.A. (hereinafter the "Company") recognizing the importance of the operation of an adequate and

integrated Internal Control System (hereinafter "ICS") to achieve its business objectives and in

accordance with Law 4706/2020 regarding corporate governance and decision of the Board of Directors

of the Hellenic Capital Market Commission 1/891/30.09.2020 as in force from time to time, adopts the

present policy of periodic evaluation of the Company's ICS as well as of the Implementation of the

provisions on Corporate Governance of Law 4706/2020.The Company's ICS includes five (5) basic

elements that exist and operate in the Company and are described in general terms below:

a. Control Environment

The Company is committed to operate with integrity and ethical values. Its organizational structure

determines a specific position and specific and distinct responsibilities for each body and organizational

unit of the Company. There are specific benchmarks and areas of responsibility in achieving the

Company's goals, while a regulation is followed on the selection and recruitment of staff and senior

management as well as a remuneration policy aiming at attracting and retaining highly qualified human

resources.

In particular:

Integrity, Moral Values & Top Management Behavior:

The Management of the Company provides direction, leadership as well as an appropriate environment

for its operation, in order to ensure that all its available resources are fully utilized to achieve its

objectives. The Company has a Code of Conduct. Any deviation is reported to the Top Management

which is solely responsible for taking relevant actions.

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(amounts in Euro unless stated otherwise)

Organizational structure:

The Company maintains an organizational structure sufficient for the planning, execution, control and

supervision of corporate operations for all its Departments and operational activities, according to

which the main areas of responsibility are determined while at the same time the appropriate reference

lines are established.

Board of Directors:

The Board of Directors of the Company meets every time the Law, the Bylaws or the needs of the

Company dictate and decides on any matter concerning the management of the Company, the

management of its assets and the general pursuit of its purpose. The Board of Directors maintains

adequate oversight of the operation and effectiveness of the ICS. For this purpose, it consists of a

sufficient number of executive, non-executive and independent non-executive members, with a variety

of knowledge, skills and experience in order to achieve the business model and strategy of the

Company.

Corporate Responsibility:

The Company maintains appropriate structures and pursues policies that promote the principle of

responsibility, the speed of decision making, the smooth operation of the Company and the effective

control of all its actions. Based on this principle, responsibilities are assigned to the executives of the

Company, according to their position in the hierarchy and their qualifications. Furthermore, the

Company forms the framework to enable the individual organizational units to operate within the

components of the specific management authority (Responsibility – Accountability Obligation -

Assumption of Responsibility), as well as the Management to control its effectiveness.

Human Recourses:

Recognizing the utilization of human resources as a cornerstone for the achievement of the Company's

goals, the Company pursues specific policies of recruitment, training, remuneration, and evaluation of

staff.

b. Risk Management

The Company clearly communicates its objectives in the individual Departments in a simple and

understandable way, so that they are taken into account during the process of risk identification and risk

assessment as well as its acceptable risk tolerance level. In general, the Top Management of the

Company determines the way of responding to the risks by categorizing them according to the

probability and their impact on the operation of the Company in the following categories:

• High risk: immediate actions required

• Increased risk: immediate actions required

• Acceptable risk: immediate actions required

• Low risk: no immediate action required

The recording of the risks faced by the Company as well as the management and risk response

procedures, is carried out in all operations of the Company on an annual basis. In addition, the Company

has established control mechanisms and safety valves to detect and/or prevent the inability to deal with

risks, in order to achieve its objectives.

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Risk Management function

The Company has a Risk Management function, which operates in accordance with appropriate and

effective policies, procedures and tools (such as keeping a risk register) on the determination, analysis,

control, management and monitoring of any kind of risk inherent to the operation of the Company.

c. Controls Activities

The Company develops policies and procedures in accordance with the objectives of the Management.

In addition, it implements a system of safety valves, based on the risks it has identified, but considering

the specific characteristics of the Company. Special emphasis is placed on the adequacy, proper

implementation and monitoring of procedures, the handling of error cases and the frequency of

reassessment of policies and procedures.

In addition, the Company implements adequate safeguards for issues of conflict of interest, segregation

of duties as well as the governance and security of its Information Systems.

d. Communication System

The Company ensures the quality of financial and non-financial information and follows appropriate

ways of internal and external communication, such as communication with the members of the Board of

Directors, shareholders and investors, communication with the existing Company committees,

complaint on whistleblowing, Regulatory Authorities etc.

e. Monitoring of the Internal Control System

The Company has mechanisms and functions that have as object the continuous evaluation of the

Internal Audit System and the reporting of findings to be corrected or improved:

Audit Committee

The Company has an Audit Committee, which is a committee of the Board of Directors, consists in its

majority of independent non-executive members of the Board and its goal is to support the Board of

Directors fulfilling its responsibilities for overseeing compliance control procedures with the legislative

and regulatory framework on: (a) financial information, (b) the internal control system, the risk

management system, the regulatory compliance system and (c) its supervision of the (external)

statutory audit of the financial statements of the Company.

Internal Audit Department

The Company has an Internal Audit Department, which operates in accordance with the applicable

Regulation approved by the Board of Directors. The Internal Audit Department is organizationally

independent and adequately staffed. Implements the appropriate tools and control methodology in

order to achieve the best result, while the audit reports that are prepared are submitted at least

quarterly to the Audit Committee and then to the Board of Directors.

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Regulatory Compliance function

The Company has a Regulatory Compliance function, which is functionally independent. It is staffed with

staff who have sufficient knowledge and experience to carry out their responsibilities and are trained

and informed in order to monitor the effective adoption and unwavering implementation of changes

taking place in the regulatory framework, with direct access to all required sources of information. It

follows the annual audit plan, while the findings of its work are promptly and truthfully communicated.

2. General Description

The Company in the context of ensuring the continuous operation of an adequate and integrated ICS

and the continuous improvement where and when deemed appropriate, follows this policy, which sets

out the framework for periodic evaluation of the ICS and implementation of the provisions on Corporate

Governance of Law 4706/2020 that is in effect and governs its operation.

3. Legal and regulatory framework

The content of this policy fully complies with Law 4706/2020 and the relevant decision

1/891/30.09.2020 of the Board of Directors of the Hellenic Capital Market Commission. The terms of

this policy are applied in combination with the respective provisions of the Company's Internal

Organization and Operation Regulations, the Regulations of the Audit Committee, the Internal Audit

Department, the Regulatory Compliance function and the Risk Management function.

4. Policy Purpose

The purpose of this policy is to establish the framework to ensure the timely and correct

implementation of the periodic evaluation of the ICS based on the respective standards by appropriate

evaluators and the compliance of the Company with the applicable legislation on relevant corporate

governance matters.

5. Policy Scope - Compliance

This policy applies to Top Management, the collective bodies and all the organizational units of the

Company, its processes and functions, as well as its Information Systems.

The Top Management, the collective bodies and all the organizational units are obliged to comply with

the content of this policy.

6. Policy Subject

The subject of this policy includes the general principles regarding the object, the periodicity of the

audit, the scope of evaluation and the general process which governs the periodic evaluation of the

Company's ICS as well as the Implementation of the provisions on Corporate Governance of Law 4706 /

2020 as well as the assignment and monitoring of the results of the evaluation and the determination of

the object of the evaluation.

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7. Evaluation Process

7 a. General

The periodic assessment of the adequacy of the ICS is carried out on the basis of international best

practices.

The purpose is to evaluate the system of identification and risk management and regulatory compliance

developed by the Company, the system of safeguards that applies to the adequacy and effectiveness of

financial information, as well as the application of corporate governance provisions of the Law.

4706/2020.

7 b. Evaluation Subject

Subject of the evaluation are the following:

Control Environment

The review of the control environment consists mainly of the following:

Integrity, Morals & Conduct of the Management: Examines to what extent a clear framework of integrity

and morals that run through the decision making of the Board of Directors have been implemented as

well as to what extent there are monitoring procedures on full compliance so as any deviation is

detected promptly and corrected appropriately.

Organization structure: To what extent the organizational structure of the Company provides for a

framework on the planning, execution, control and supervision of the Company’s activities based on its

organizational structure for each business unit and its operational activities according to which the

primary areas of responsibility within the Company are determined and the suitable reference

guidelines are determined depending on the size of the Company and the nature of its activities.

Board of Directors: The structure, organization and the way of operation of the Boards of Directors and

its committees are examined: in particular, with regard to a) the relation with the executive

administration, b) the supervision authority on the operation and the effectiveness of the ICS and c) the

composition of the Board of Directors (eg size, suitability and diversity of its members etc.).

Corporate responsibility: The operation of the higher executive administration and the way in which it

implements under the supervision of the Board of Directors, the appropriate infrastructures, reference

lines, areas of responsibility and power in order to achieve the scope of the Company are examined.

Human Resources: The following but not limited to the recruitment practices, fees, training and

evaluation of the performance of the personnel are examined in order to establish the commitment of

the Administration to the principles of integrity, morals and sufficient knowledge of the personnel.

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Risk Management

It consists of the review of the risk acknowledgement and assessment procedure (risk assessment),

management and response procedures of the Company to the said risks (risk response) and the

procedures on the monitoring of the development of the risk (risk monitoring).

In particular, the following are reviewed:

- the work and duties of the Risk Management function, and

- the implementation of the appropriate and effective policies, procedures and tools (such as

keeping a risk register) on the determination, analysis, control, management and monitoring of any

kind of risk inherent to the operation of the Company.

Control Activities

Review of the mechanisms on the control of the critical safety net emphasizing on the safety net related

to conflict of interest issues, separation of duties and governance and security of Information Systems.

Information and Communication

Review of the procedure of the development of the financial including the reports of the auditing

mechanisms (e.g. Supervisory, Regulatory and Regulating Authorities, Independent Professional Entities

etc.) and non-financial information (e.g. sustainable development policy, environmental, social and

labor issues, respect of human rights, fight against corruption, issues on bribery as provided in article

151 of Law 4548/2018) as well as the review of the procedures on the critical internal and external

communication of the Company, which are mentioned above at point 1.d.

Monitoring of ICS

Review of the infrastructure and the mechanisms of the Company that are competent for the constant

evaluation of the components of the ICS and the report of the findings to be corrected or improved.

In particular, the operation of the following infrastructure and mechanisms are reviewed:

Audit Committee

It concerns the review by the evaluator of the procedure on the monitoring of the efficiency of the ICS

by the Audit Committee.

Internal Audit Department

It includes the review by the evaluator of the following elements on the organization and operation of

the Internal Audit Department and the compliance with the provisions of articles 15 and 16 of Law

4706/2020 and the applicable regulatory framework, i.e. the policies, procedures, practices and

applicable legislative and regulatory requirements and in particular:

- The implementation and application of an approved Regulation of Operation of the Internal Audit

Department by the Board of Directors.

- The integration of the operation of the Internal Audit Department to the framework of the governance

of the Company, its organizational independence and the sufficiency of its staffing.

- The review of the tools and techniques used by the Internal Audit Department.

- The review of the combination of the knowledge and qualifications of the personnel of the Internal

Audit Department.

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- The “random” review of the audit reports on the Internal Audit Department of the Company and its

affiliates as to the prompt filling as well as the appropriateness and completeness thereof based on the

provisions of article 16 of Law 4706/2020.

- The effective operation of the supervisory bodies of the Internal Audit Department as these are

provided in the regulatory framework and the Company’s Internal Organization and Operation

Regulations.

Regulatory Compliance

It refers to the review by the evaluator of the monitoring procedure on the compliance with the

regulatory and legal framework as well as the internal regulations that govern the operation of the

Company. The provisions on corporate governance of Law 4706/2020 are included in the said

framework.

In particular, the following are reviewed:

- the Regulatory Compliance function, as to its independence, possibility to access all the necessary

sources of information, the prompt and truthful communication of all its findings, the training on

regulatory compliance matters and the monitoring of the effective adoption and the application

without any deviations of the changes in the regulatory framework.

- the sufficient staffing with persons that have the sufficient knowledge and experience to carry out

the said duties.

- the adoption of an approved annual audit plan and the monitoring of its implementation.

7 c. Timing – periodicity

The evaluation of the ICS is carried out either periodically or on an ad hoc basis.

Periodicity is defined as the time period between two consecutive evaluations and which is determined

in three (3) years starting from the reference date of the last evaluation.

The time is defined as the time at which it is required to carry out either the periodic evaluation or the

ad hoc evaluation at the request of the Hellenic Capital Market Commission.

In any case, the evaluation of the ICS is part of the overall evaluation of the corporate governance

system of the Company, according to article 4 par. 1 of Law 4706/2020.

The first evaluation of the ICS must be completed, according to the provisions of this decision, as in

force to the law 4706/2020.

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7 d. Characteristics of the persons that carry out the evaluation

The evaluator is a legal or natural entity or association of persons. The evaluator shall have the following

characteristics:

Matters of independence and objectivity

When selecting the evaluator of the ICS, matters of independence and integrity of PPA SA are taken into

consideration. The evaluator and the members of his taskforce must be independent and do not have

any dependency according to par. 1 of article 9 as particularized in par. 2 of Law 4706/2020 as well as be

objective in the course of exercising his duties.

When the evaluation is carried out by a physical person in the context of an employment or cooperation

relationship with a legal entity, the dependency relationship concerns the physical pearson himself and

not necessarily the legal entity with which he has an employment or cooperation relationship.

Objectivity is the impartial attitude and ways of thinking that shall allow for the evaluator to perform his

duties as he thinks proper and do not settle as to its quality. The objectivity requires for the evaluator

not to be affected by third parties or other facts.

In the course of ensuring the independence and the objectivity, the evaluation of the ICS shall not be

carried out by the same evaluator for three subsequent evaluations.

Proven relevant professional experience and training

When selecting the evaluator of the ICS matters related to the knowledge and his professional

experience are taken into consideration. In particular, the head of the taskforce of the evaluation of the

ICS and in any case the signatory of the evaluation must have the appropriate professional qualifications

(depending on the professional standards that he refers to) as well as proven relevant experience (such

as in evaluations of other ICS and structures of corporate governance).

The evaluator implements all the necessary measures in order in the course of his work the persons that

participate therein have the appropriate knowledge and experience as to the duties assigned to them

and he uses the suitable systems on quality assurance, sufficient human and material resources and

procedures in order to ensure the continuity, periodicity and quality of the performance of the works.

7 e. Candidates selection and award of evaluation – Responsibilities

The Company assigns timely, through its competent bodies, the evaluation of the ICS to a suitable

external evaluator. Specifically:

Within a reasonable time and at least six months before the date of mandatory submission of the final

evaluation report to the Hellenic Capital Market Commission, the Audit Committee arranges for the

selection of suitable candidate or candidates to submit a tender within a specific deadline, after the

relevant invitation (7 d).

Interested parties are invited to submit a bid within a specific deadline specified in the relevant

invitation, where relevant reference is especially made to the independence and proven experience and

training in relevant ICS and corporate governance structure evaluation projects as defined in point (7 d).

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The submitted offers are reviewed and evaluated by the Audit Committee, which proposes as the

competent body to the Board of Directors, the assignment of the evaluation of the ICS to an appropriate

at their discretion candidate, considering the independence and professional experience of the

candidate. The Board of Directors decides upon the assignment of the project of the periodic evaluation

of the ICS to the appropriate evaluator.

The Regulatory Compliance function and / or the Internal Audit Department, under the guidance of the

Audit Committee, facilitate the evaluator during the implementation of his project regarding the

communication and cooperation with the various bodies or Departments of the Company.

7 f. Evaluation report and recipients

The evaluator carries out the evaluation of the ICS, within the agreed schedule and upon completion

submits an evaluation report, which should at least include:

▪ Summary of test results and a detailed description of them;

▪ The time of submission of the evaluation report;

▪ The reference date of the evaluation and the period it covers (which starts from the next

day of the reference date of the previous evaluation).

The summary includes the evaluator’s conclusion regarding the adequacy and effectiveness of the

Internal Control System. It also includes the most important findings of the evaluation, the risks and the

consequences arising from them as well as the response from Top Management to these findings,

including the relevant action plans with clear and realistic timetables.

The detailed report includes all the findings of the evaluation with the relevant analyses.

Recipients of the report are defined the Audit Committee and the Board of Directors.

The Company submits without delay to the Hellenic Capital Market Commission, and in any case within

three (3) months from the reference date of the evaluation report, the report and, if required, the

detailed report.

The annual declaration on corporate governance includes a relevant reference on the results of the

Evaluation Report, the response of the Company’s management through a competent body decision, as

well as the action plans of the Company with the relevant time plans.

8. Relevant documents – references

Reference of this policy is made to the Internal Organization and Operation Regulation of the Company

as it applies, the Regulation of operation of the Audit Committee and the Internal Audit Department and

the Hellenic Corporate Governance Code adopted by the Company.

9. Force – Exceptions

This policy shall enter into force on the date of its adoption and shall not be subject to any exceptions.

10. Policy Update

This Policy will be evaluated for update when significant changes are identified in the covered area or

upon the implementation of legislative changes.

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Results of the process of the evaluation of the Internal Control System (ICS) of PPA S.A. for the period

17-07-2021 until 31-12-2022, in accordance with article 14, par. 3 (j) and par. 4 of L. 4706/2020 and

the relevant decisions of the Board of Directors of the Hellenic Capital Market Commission

The Company, by decision of its BoD, assigned to KPMG Certified Auditors S.A. the assessment of the

adequacy and effectiveness of the Internal Audit System of the company PPA S.A., with reference date

of 31 December 2022, in accordance with the provisions of section j of par. 3 and par. 4 of article 14 of L.

4706/2020 and decision 1/891/30.09.2020 of the Capital Market Commission’s Board of Directors as

applicable (the "Legislative Framework"). The assurance was carried out in accordance with the audit

program included in the decision of the Hellenic Accounting and Auditing Standards Oversight Board

(HAASOB), number 040/2022 and the International Standard on Assurance Engagement 3000

"Assurance Engagements other than Audits or Reviews of Historical Financial Information".

Based on the work carried out by the evaluator regarding the assessment of the adequacy and

effectiveness of the Company’s Internal Audit System, we report that no material weaknesses were

identified.

This result constitutes one more confirmation that the Company is in constant compliance with the

current legislative and regulatory framework governing the Internal Control System to ensure the lawful

and orderly operation towards achieving its sustainable development strategy.

IV.8. Internal Audit Department

1. The Company has an Internal Audit Department under the supervision of the Audit Committee. The

Board of Directors, upon the proposal of the Audit Committee, appoints the Head of the Internal Audit

Department, pursuant to article 15 of Law 4706/2020. The members of the Internal Audit Department

are independent in the exercise of their duties, do not belong to any other Department of the Company

and are supervised by the Audit Committee, which is responsible for monitoring their independence and

their evaluation.

2. The responsibilities of the Internal Audit Department, are the following:

a) To monitor, audit and evaluate:

• the implementation of the Internal Organization & Operation Regulation and the Internal Audit

System, in particular as to the adequacy and accuracy of the provided financial and non-financial

information, risk management, regulatory compliance and the Code of Corporate Governance adopted

by the Company,

• the internal controls of quality assurance

• corporate governance mechanisms, and

• the compliance with the commitments contained in newsletters and the Company's business plans

regarding the use of funds raised from the regulated market.

b) To prepare reports to the audited Departments with findings regarding tasks Nr. a), the risks arising

from them and suggestions for improvement, if any. The reports, after incorporating the relevant

comments of the audited Departments, the agreed actions, if any, or the acceptance of the risk of non-

action by them, the limitations on its scope of audit, if any, the final internal audit proposals and the

results of the response of the audited Departments of the Company to its proposals, are submitted at

least quarterly to the Audit Committee.

c) To inform the Audit Committee on a monthly basis about its activities, the audits carried out and the

progress of its work.

d) To submit at least every three (3) months to the Audit Committee reports, including its most

important issues and proposals, regarding the tasks a) and b), which the Audit Committee presents and

submits along with recommendations to the Board.

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e) To ensure the receipt of written complaints and their examination, in accordance with the provisions

of the Code of Ethics chapter 19, regarding the Internal Complaints Process (ICP).

f) To be present only to the tenders that concern Mandatory Enhancements (ME), providing at all stages

of the tender procedure consulting assistance to the Tender Management Committees and Tender

Evaluation Committees, regarding the issues of compliance of the procedures with the decisions of the

Management and the Internal Regulations and to those who are specially assigned by the Chairman of

the BOD and/or the CEO and submits relevant reports to the President of the TMT and the CEO and

Administration Board at the stage of submitting the relevant proposals.

3. Further to the responsibilities described above, the Head of the Internal Audit Department especially:

a) Submits to the Audit Committee an annual audit plan for the following year and the requirements for

the necessary resources, as well as the implications of the resource limitation or audit work of the

Department as a whole. Once approved, the annual audit plan is submitted by the Audit Committee to

the Board of Directors for final approval.

b) Attends the general meetings of shareholders and

c) Provides in writing any information requested by the Hellenic Capital Market Commission, cooperates

with it and facilitates in every possible way the task of monitoring, auditing and supervising by it.

V.Diversity Policy applied in relation to the Company’s administrative, managerial and supervisory

bodies

Description of the policy of diversity with regard to the administrative bodies of the Company.

Given the fact the Board of Directors is the highest administrative body of the Company, which is

responsible for the safeguarding of the broader corporate interests, the policy making and the growth

strategy of the Company as well as for the strengthening of the long-term economic value of the

Company, it is very essential for the particular body to possess, with regard to its composition, a

diversity of skills, views and abilities which at the same time respond to the need to effectively attain

corporate goals.

From the time of the Company’s establishment and until today, the entire members of the Board of

Directors fulfill all necessary conditions and have set the foundations in order to be granted with the

capacity of the member of the Board of Directors. At the same time, they are distinguished for their high

professional skills, educational level, knowledge, capabilities, experiences and their organizational and

administrative abilities, and at the same time they possess high standards of ethics and integrity of

character. The members of the board of Directors cover a broad range in terms of age combining

effectively their dynamics and experience (indicatively between 49 and 73 years old). The members, in

their majority, are holders of graduate and postgraduate degrees of domestic as well as international

universities, have worked in high ranked positions of major companies domestically and abroad. They

have also been members of the higher managerial staff of large organizations and as a result they

possess significant international experience in the corporate as well as the broader social fields and are

in position to actively contribute to the growth prospects of the Company. They finally fulfill the

requirements of suitability as well as the criteria with regard to the Company’s effective staffing and

operation.

The current composition of the Board of Directors aims undoubtedly at the best possible facilitation of

corporate goals, as it increases the pool of skills, experience and vision that the Company has for its

highest-ranking personnel, and consequently its competitiveness, productivity and innovation.

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The current 10-member (after the resignation without replacement of a non-executive member of the

Board of Directors) Board of Directors of the Company, consists of 9 men and 2 women and was elected

in the framework of the decision of the Company’s Management for immediate, substantial and

effective compliance and harmonization with the provisions of the law 4706/2020 on suitability,

diversity and, above all, adequate representation by gender on the Board of Directors and completely

covers the appropriate exercise of the responsibilities of the Board of Directors of the Company, reflects

the size and activity of the Company and its characteristic feature is diversity of knowledge, skills and

experience that can contribute to the achievement of business objectives.

Procedure to comply with the obligations arising from Articles 99 to 101 of law 4548/2018, regarding

transactions with related parties

The Company recognizes the importance of its compliance with the obligations arising from articles 99

to 101 of Law 4548/2018, regarding transactions with related parties, to ensure the smooth and

efficient operation of the market.

Therefore, the Company establishes the following procedure of compliance with the obligations arising

from articles 99 to 101 of Law 4548/2018, regarding transactions with related parties:

The Group to which the company belongs, maintains a list of related parties, from which the Company

has the opportunity to obtain relevant information.

Contracts of the Company with related parties, as well as the provision of security and guarantees to

third parties in favor of such parties, within the meaning of articles 99-101 of Law 4548/2018, are only

permitted upon prior authorization by the Board of Directors or, in the case of paragraph 4 of this

article, by the General Meeting. Related parties with respect to the Company are those parties defined

as related parties of the Company pursuant to International Accounting Standard 24, as well as the legal

entities controlled by them, pursuant to International Accounting Standard 27.

In the case where, a contract with a related party of the Company is awarded after and according to

tender procedures, as they are described in the approved and posted on the Company's website

Regulations for the Award of Contracts and Sub-concessions of the Company, the above paragraph is

not followed.

The Board of Directors may grant authorization, pursuant to the preceding paragraph, which is valid for

six (6) months. In the case of recurring contracts with the same person, a single authorization may be

provided that sets forth the characteristics of the contracts concerned and is valid for one (1) year.

Within ten (10) days as of the publication of the notice on the granting of the said permission by the

Board of Directors, shareholders representing one twentieth (1/20) of the paid-in share capital may

request the convocation of the General Meeting in order for the General Meeting to adopt a resolution

on the matter of the said permission. The contract for which permission has been granted by the Board

of Directors shall be considered as effective only after the lapse of the said ten-day time period or upon

securing the permission of the General Meeting or upon a written statement by all shareholders to the

Company to the effect that they do not intend to request the convocation of the General Meeting.

If by the time permission is granted by the General Meeting, the contract under par. 1 of this article has

already been concluded or the guarantee or security has been provided, then the granting of permission

by the General Meeting is canceled if objected to by shareholders representing one twentieth (1/20) of

the capital represented at the Meeting.

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If the transaction involves a shareholder of the Company, the shareholder concerned does not take part

at the vote in the General Meeting and is not counted for the purposes of quorum and majority. Other

shareholders with whom the counterparty is related under a relationship falling under paragraph 2 of

article 99 of Law 4548/2018 will not take part in the vote either. This paragraph is not applicable when

permission by the Board of Directors was given with the concurrence of the majority of its independent

members.

In all cases, the granting of permission by the General Meeting is canceled if opposed by shareholders

representing one third (1/3) of the capital represented thereat.

If the permission for the conclusion of the contract was given by the General Meeting, any amendments

thereto may be made under permission by the Board of Directors, unless the General Meeting has

reserved for itself the right to authorize such amendments as well.

Decision thereon by the Board of Directors or the General Meeting is made on the basis of a report by a

certified public accountant or auditing firm or other third party unrelated to the Company, that assesses

whether the transaction is fair and reasonable for the Company and shareholders who are not a related

party, including the minority shareholders of the Company, and explains the assumptions on which it

has relied together with the methods employed.

The Board of Directors issues a notice about the granting of permission to the conclusion of the contract

by the Board itself or by the General Meeting, and the lapse of the time period set forth in paragraph 4

of the present article. Such notice is published prior to the conclusion of the transaction. An inaccuracy

in the notice cannot be invoked towards third parties, unless the Company demonstrates that such third

parties were aware of the inaccuracy in question. The notice shall as a minimum include information: (a)

on the nature of the relationship of the Company to the related party; (b) the date and value of the

transaction; (c) any other information as necessary in order to assess whether the transaction is fair and

reasonable for the Company and those persons who are not a related party, including the minority

shareholders. The said notice is accompanied by the report referred to in the preceding paragraph.

A transaction entered into between the related party of the Company and a Company subsidiary shall

also be submitted to the publication formalities.

Sustainable development policy followed by the Company

The Company, implements a Sustainable Development Policy and seeks, over time, to create value for

its stakeholders, i.e. shareholders, customers, employees and society in general.

To achieve this goal, the Company places particular emphasis on, among others, the training and

development of its personnel, health and safety at work, as well as respect for the environment,

following the principles of sustainable development. The Sustainable Development Policy of the

Company reflects the approach and commitment of the Management to the issue of responsible

operation. Responsible operation is a continuous commitment to action of substance, in order to

generate value for all stakeholders that meet the modern needs of society and contribute in general to

its prosperity. The Company has a specific strategy, which focuses on the important issues related to its

activity and seeks its continuous responsible development, focusing on the critical pillars of business

responsibility: Economy, Society, Environment.

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Sustainable development is an integral part of the Company's business practice model and culture. In

the context of the implementation of Sustainable Development, the Company develops activities,

among others, in the following areas:

a) Personnel health and safety

The Company places the protection of the health and safety of its personnel as a priority and primary

concern. As part of the implementation of this policy, the Company adopts every best international

practice that contributes to the strengthening and improvement of the safety culture and organizes

training programs, both for the knowledge of the risks of the production process and for the cultivation

of a common awareness and behavior of safety among the personnel.

b) Training and development of Personnel

The Company recognizes the contribution of the staff to its successful business course. The extensive

experience, the high specialization, the know-how of the staff in matters of the port industry support

the development perspective of the Company. The Company attaches great importance to the

continuous training of the staff, designing and implementing educational programs of high added value,

which highlight the knowledge and skills of the staff.

c) Corporate Social Responsibility

The Company seeks the sustainability of the local community by maintaining a two-way relationship and

continuous cooperation with it. The Company derives a significant part of its needs in human resources

from the local community in which it operates. Of the total workforce, 42% are workers from local

communities (Piraeus Regio), thus contributing to the local economy. In relation to the Company's social

contribution initiatives, the support of vulnerable groups, the strengthening of sports clubs and cultural

activities, the provision of donations and equipment to charitable organizations or institutions, the

support of schools, and other initiatives that promote common values for progress, development and

social special offer.

d) Environmental protection

Protecting the environment and reducing environmental footprint is a strategic goal and commitment of

the Company. In this context, the Company adopts policies and implements actions to minimize the

environmental impacts resulting from its activities, reduce energy consumption and improve its energy

efficiency.

e) Market

As part of its Sustainable Development strategy, the market pillar largely determines the Company's

business activities. The Company's goal is to respond consistently, transparently and responsibly to

market demands and to be able to respond promptly and effectively to challenges, creating value for

society as a whole.

f) Corporate governance

In order to record the practices that it implements both voluntarily and due to its obligations based on

the legislation, as well as for reasons of greater transparency, PPA S.A. has adopted the Corporate

Governance Code of the Hellenic Corporate Governance Council.

For the above main issues concerning the Company, individual Sustainable Development goals are set,

which are evaluated on an annual basis in terms of their effectiveness and are reviewed when

necessary.

Page 107 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The policy, the results of the Company's performance in the issues of Sustainable Development, as well

as the implementation of the programs and the achievement of the objectives, are published on an

annual basis, in order to fully and comprehensively inform under a general framework of transparency

of all partners, which are considered during the annual Management Review for all the above issues.

PPA SA Supports the United Nations 2030 Agenda, as set out in the 17 Sustainable Development Goals,

with a view to actively contributing to their achievement by promoting the prosperity and security of

the people and environmental protection.

The priority of PPA SA is the fulfillment of the objectives that are directly related to the activities and

challenges of the sector in which it operates, as well as to the essential issues arising from the ESG

Report, which details the connection of the programs and of the Company's actions with the Sustainable

Development Goals.

The strategy, programs, results and related commitments are analyzed in the annual ESG Report, which

is based on the Global Reporting Initiative (GRI) Universal Standards guidelines, which are the most

internationally recognized and demanding guidelines of their kind and is available in the Company’s

website.

Materiality Assessment

Material Recognition Process

One of the most important and fundamental guiding principles of the GRI is the concept of materiality.

PPA SA addresses the issues that cause the most significant economic, environmental, and social impact,

or those that are considered most important, by its internal and external stakeholders. In the process of

identifying the essential issues PPA SA actively involves its stakeholders and considers all the issues and

topics in the given time period that fall within the limits of the organization's exposure.

During the process of identifying the essential issues, PPA SA conducted quality, electronic research on

representatives of its Stakeholders in order to examine all important issues related to Sustainability, as

well as to systematize the dialogue with them on these issues.

Methodology

The methodology followed is described below:

Step 1: Identify and prioritize the main Stakeholders, who will be included in the process of finding the

essential issues. Involves stakeholder groups such as employees, NGO representatives, suppliers,

customers and local community representatives.

Step 2: Identify and prioritize key indicators (economic, environmental, social, work practices, human

rights, responsible services, etc.), using the GRI guidelines.

Step 3: Conduct a survey, through a quality questionnaire to identify the key issues in the opinion of

stakeholders and management. The following quality scale was used for each question: Very Important,

Important, Not at all Important. The stakeholders who responded to the questionnaire consist of the

following internal and external ensembles: employees, NGO representatives, suppliers, customers and

local community representatives. The same questionnaire was completed by the members of the

administration.

Step 4: Create a table (matrix) that identifies the essential issues. A numerical value was given to each

response to the significance questionnaire (High Significance = 3, Medium Significance = 2, Low

Significance = 1).

For each essential question included in the questionnaire, an average value was calculated through the

answers of all interested parties.

Page 108 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Material aspects and Materiality Matrix

The GRI guidelines recommend the design of issues according to their materiality in a materiality matrix,

with the X-axis representing issues that cause significant impact on the operation of PPA SA.

(Management view), and the Y-axis to represent issues that are considered important between

stakeholders (stakeholder view). The issues that are considered very important for the Management and

the Stakeholders are included in detail in the report.

By calculating both above parameters, as essential issues for 2022 are mentioned:

• Occupational health and safety

• Anti-corruption

• Tax

• Customer health and safety

• Employment

• Anti-competitive behavior

• Waste

• Security Practices

• Local communities

• Indirect economic impacts

• Training and education

• Economic performance

• Freedom of collective associating

Page 109 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Board of Directors Explanatory Report (according to article 4,

par. 7 and 8 of Law 3556/2007)

The present explanatory report of the Company’s Board of Directors to the annual General Meeting of

Shareholders is an integral part of the Annual Report of the Board of Directors.

Share capital structure

The Company’s share capital amounts to Euro fifty million (50,000,000€) and is divided into 25 million

ordinary shares, of a nominal value of Euro two (€2,00) each. Each share is entitled to one vote. The

Company’s shares are dematerialised and listed to trading on the Athens Stock Exchange.

According to the Company’s Articles of Association, the Company’s shares and rights deriving therefrom

are indivisible and, in case of joint ownership, the joint owners exercise their rights through a common

representative, whereas each joint owner is jointly and severally liable to the Company for the

fulfillment of the obligations deriving from the share.

Restrictions on the transfer of the Company’s shares

The Company’s shares may be transferred in the manner laid down by law and there are no restrictions

on their transfer contained in the Articles of Association of the Company.

Major direct or indirect holdings within the meaning of Articles 9 to 11 of Law 3556/2007

The major holdings (over 5%) as at 31.12.2022 were as follows:

Following the execution of a share purchase agreement and corresponding over the counter transaction

made on August 10

, 2016, COSCO SHIPPING (Hong Kong) Co., Limited obtained 51% of shares and

voting rights in the Company.

As a result of an over-the-counter transaction that took place on 06 October 2021, the percentage of

voting rights of COSCO SHIPPING (Hong Kong) Co., Limited in PPA S.A. has increased from 51% to 67%.

With the above over-the counter transaction, COSCO SHIPPING (Hong Kong) Co., Limited has acquired

from Hellenic Republic Asset Development Fund S.A. an additional 16% of shares in PPA S.A.

The above transaction has taken place under an Amended Share Purchase Agreement between COSCO

SHIPPING (Hong Kong) Co., Limited as Purchaser and Hellenic Republic Asset Development Fund S.A. as

Seller, following ratification of an Amendment to the Concession Agreement between the Hellenic

Republic and PPA S.A. (Law 4838/2021, Government Gazette 180A/ 01.10.2021).

COSCO SHIPPING (Hong Kong) Co., Limited is 100% held by China Shipping Group Co. Ltd, which is 100%

held by China COSCO Shipping Corporation Limited. As a result of the transaction, China COSCO Shipping

Corporation Limited indirectly holds 67% of voting rights in PPA S.A.

Page 110 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

As a result of the above referred transaction, the “Hellenic Republic Asset Development Fund S.A.”

percentage of voting rights in PPA S.A. directly has fallen from 23.1378% to 7.1378%. The total (100%) of

the shares in HRADF S.A. is owned by EESYP S.A., which is 100% controlled by the Greek State. The

transfer is attributed to an amended Share Purchase Agreement following ratification of the

amendment of the Concession Agreement (Law 4838/2021, Government Gazette 180A/ 01.10.2021).

Pursuant to a transaction made on November 10, 2021, the percentage of voting rights in PPA held by

the shareholder Helikon Long Short Equity Fund Master ICAV amounts to 5.376%.

Holders of any type of shares granting special rights of control

There are no shares of the Company that grant to their holders special rights of control.

Restrictions to voting rights

The Company’s Articles of Association do not contain any restrictions to the voting rights deriving from

the Company’s shares.

Agreements between shareholders which result in restrictions on the transfer of shares or limitations

on voting rights

The Company is aware of a Shareholders Agreement dated 8 April 2016 between COSCO Hong Kong

Group Limited (currently incorporated under the corporate name COSCO SHIPPING (Hong Kong) Co.,

Limited) and Hellenic Republic Asset Development Fund S.A., which contains certain restrictions on the

transfer of shares and certain limitations on voting rights of the contracting parties.

The rules contained in the Company’s Articles of Association on appointment and replacement of

members of the Board of Directors and on amendment of the provisions of the Articles of Association

are not different from the provisions of the legislation. However, the Company wishes to inform that

according to article 18 of the Articles of Association, as long as the Hellenic Republic Asset Development

Fund S.A. or any global successor or successor by operation of law of the Hellenic Republic Asset

Development Fund S.A. (each and collectively, the “FUND”) holds at least one million two hundred and

fifty thousand (1,250,000) voting shares and less than 10% of the voting shares issued by the Company

and subject to the FUND is entitled to appoint one (1) Member pursuant to article 79 of Law 4548/2018

as in force. If the FUND holds at least 10% of the voting shares, the FUND is entitled to appoint 1/3 of

the total number of Members of the Board of Directors of the Company. Should any Director appointed

pursuant to paragraph 2 of this article resign or become incapacitated for whatever reason, they shall be

replaced by such personas the HRADF shall specify in a pertinent written notice to the Company, with

immediate effect.

Competence of the Board of Directors or of some of its members to issue new shares or purchase own

No special competence different from the provisions of the legislation is awarded by the Articles of

Association to the Board of Directors or to some of its members to issue new shares or purchase own

shares of the Company.

Page 111 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Important agreements contracted by the Company, which will enter into effect, be amended or expire in

case of change in the Company’s control following a public offer and the results of such agreements

There are no such agreements.

Agreements that the Company has contracted with the members of the Board of Directors or with its

personnel, which provide for the payment of compensation in case of resignation or release without

substantiated reason or in case of termination of their term or employment due to a public offer

There are no such agreements.

Piraeus, March 17, 2023

THE CHAIRMAN OF THE BoD

YU ZENG GANG

Page 112 of 177

Independent Auditors’ Report

(Translated from the original in Greek)

To the Shareholders of

Piraeus Port Authority S.A.

Report on the Audit of the Financial Statements

Opinion

We have audited the accompanying Financial Statements of Piraeus Port Authority S.A. (the

“Company”) which comprise the Statement of Financial Position as at 31 December 2022, the

Statements of Comprehensive Income, Changes in Equity and Cash Flows for the year then ended,

and notes, comprising a summary of significant accounting policies and other explanatory

information.

In our opinion, the accompanying Financial Statements present fairly, in all material respects, the

financial position of Piraeus Port Authority S.A. as at 31 December 2022 and its financial

performance and its cash flows for the year then ended, in accordance with International Financial

Reporting Standards as adopted by the European Union.

Basis for Opinion

We conducted our audit in accordance with International Standards on Auditing (ISA), as

incorporated in Greek legislation. Our responsibilities under those standards are further described

in the Auditors’ Responsibilities for the Audit of the Financial Statements section of our report.

We are independent of the Company in accordance with the International Ethics Standards Board

for Accountants’ Code of Ethics for Professional Accountants, as incorporated in Greek

legislation, and the ethical requirements that are relevant to the audit of the financial statements in

Greece and we have fulfilled our other ethical responsibilities in accordance with the requirements

of the applicable legislation. We believe that the audit evidence we have obtained is sufficient and

appropriate to provide a basis for our opinion.

Key Audit Matters

Key audit matters are those matters, that, in our professional judgment, were of most significance

in our audit of the Financial Statements of the current period. These matters and the relevant

significant assessed risks of material misstatement were addressed in the context of our audit of

the Financial Statements as a whole, and in forming our opinion thereon, and we do not provide a

separate opinion on these matters.

Page 113 of 177

Contingent liabilities and provisions arising from litigation

Refer to Notes 18 and 31a) to the Financial Statements.

The key audit matter

How the matter was addressed in our audit

The Company faces a number of pending legal

proceedings with a claimed amount of EUR 123,7

million from which a provision of EUR 19 million

has been recognized (Note 31a) Commitments

and Contingent Liabilities and Note 18

Provisions). The Company establishes provisions

based on management’s estimates of the probable

amount that will be required for the settlement of

the liabilities.

This area was considered a key audit matter due

to the significant number of pending legal cases

and the significance of the relative amounts

claimed, as well as the extent of estimates and

assumptions made by management regarding the

amounts of the provision and the extent of

disclosures regarding the legal cases of the

Company in the financial statements.

Our audit procedures with regards to this matter

included, among others, the following:

• We obtained analysis of provisions

established and approved by management

and we compared them to the detailed lists

provided by the legal department.

• For a sample of these pending legal

proceedings, we examined documentation

supporting the movement of the accounting

balance of the provision during the year

ended 31 December 2022.

• We obtained external legal confirmations

directly requested by us and we discussed

with the internal legal department a sample

of legal cases with respects to the estimated

outcome of the legal proceedings in order to

assess the relevant management estimates.

• We assessed the reasonableness of

management’s assertions and estimates

regarding litigation proceedings against the

Company which could result to a negative

outcome and relevant outflows.

• We also assessed the appropriateness and

adequacy of the disclosures in the financial

statements regarding this matter.

Page 114 of 177

Other matter

The Financial Statements of the Company for the prior year ended 31 December 2021, were audited

by another Audit Firm, for which the Certified Auditor issued an audit report on 14 March 2022

expressing an unmodified opinion.

Other Information

The Board of Directors is responsible for the other information. The other information comprises the

information included in the Board of Directors’ Report, for which reference is made in the “Report on

Other Legal and Regulatory Requirements” and the Declarations of the Members of the Board of

Directors but does not include the Financial Statements and our Auditors’ Report thereon.

Our opinion on the Financial Statements does not cover the other information and we do not express

any form of assurance conclusion thereon.

In connection with our audit of the Financial Statements, our responsibility is to read the other

information and, in doing so, consider whether the other information is materially inconsistent with

the Financial Statements or our knowledge obtained in the audit, or otherwise appears to be

materially misstated. If, based on the work we have performed, we conclude that there is a material

misstatement of this other information, we are required to report that fact. We have nothing to report

in this regard.

Responsibilities of the Board of Directors and Those Charged with Governance for the

Financial Statements

The Board of Directors is responsible for the preparation and fair presentation of the Financial

Statements in accordance with International Financial Reporting Standards as adopted by the

European Union, and for such internal control as the Board of Directors determines is necessary to

enable the preparation of the financial statements that are free from material misstatement, whether

due to fraud or error.

In preparing the Financial Statements, the Board of Directors is responsible for assessing the

Company’s ability to continue as a going concern, disclosing, as applicable, matters related to going

concern and using the going concern basis of accounting unless the Board of Directors either intends

to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

The Audit Committee of the Company is responsible for overseeing the Company’s financial

reporting process.

Page 115 of 177

Auditor’s Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the Financial Statements as a whole

are free from material misstatement, whether due to fraud or error, and to issue an auditors’ report

that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee

that an audit conducted in accordance with ISAs which have been incorporated in Greek legislation

will always detect a material misstatement when it exists. Misstatements can arise from fraud or error

and are considered material if, individually or in the aggregate, they could reasonably be expected to

influence the economic decisions of users taken on the basis of these Financial Statements.

As part of an audit in accordance with ISAs, which have been incorporated in Greek legislation, we

exercise professional judgment and maintain professional scepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the financial statements, whether due to

fraud or error, design and perform audit procedures responsive to those risks, and obtain audit

evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not

detecting a material misstatement resulting from fraud is higher than for one resulting from error,

as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override

of internal control.

• Obtain an understanding of internal control relevant to the audit in order to design audit

procedures that are appropriate in the circumstances, but not for the purpose of expressing an

opinion on the effectiveness of the Company’s internal control.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting

estimates and related disclosures made by the Board of Directors.

• Conclude on the appropriateness of the Board of Directors’ use of the going concern basis of

accounting and, based on the audit evidence obtained, whether a material uncertainty exists

related to events or conditions that may cast significant doubt on the Company’s ability to

continue as a going concern. If we conclude that a material uncertainty exists, we are required to

draw attention in our auditors’ report to the related disclosures in the Financial Statements or, if

such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit

evidence obtained up to the date of our auditors’ report. However, future events or conditions

may cause the Company to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the Financial Statements, including the

disclosures, and whether the financial statements represent the underlying transactions and events

in a manner that achieves fair presentation.

We communicate with those charged with governance regarding, among other matters, the planned

scope and timing of the audit and significant audit findings, including any significant deficiencies in

internal control that we identify during our audit.

We also provide those charged with governance with a statement that we have complied with relevant

ethical requirements regarding independence, and communicate with them all relationships and other

matters that may reasonably be thought to bear on our independence, and where applicable, related

safeguards.

From the matters communicated with those charged with governance, we determine those matters

that were of most significance in the audit of the Financial Statements of the current period and are

therefore the key audit matters. We describe these matters in our auditors’ report unless law or

regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we

determine that a matter should not be communicated in our report because the adverse consequences

of doing so would reasonably be expected to outweigh the public interest benefits of such

communication.

Page 116 of 177

Report on Other Legal and Regulatory Requirements

1. Board of Directors’ Report

The Board of Directors is responsible for the preparation of the Board of Directors’ Report and the

Corporate Governance Statement that is included in this report. Our opinion on the financial

statements does not cover the Board of Directors’ Report and we do not express an audit opinion

thereon. Our responsibility is to read the Board of Directors’ Report and, in doing so, consider

whether, based on our financial statements audit work, the information therein is materially

misstated or inconsistent with the financial statements or our audit knowledge. Based solely on

that work pursuant to the provisions of paragraph 5 of Article 2 of Law 4336/2015 (part B), we

note that:

(a) The Board of Directors’ Report includes a Corporate Governance Statement which provides

the information set by Article 152 of L. 4548/2018.

(b) In our opinion, the Board of Directors’ Report has been prepared in accordance with the

applicable legal requirements of Articles 150-151 and of paragraph 1 (cases c and d) of

article 152 of L. 4548/2018 and its contents correspond with the accompanying Financial

Statements for the year ended 31 December 2022.

and its environment, we have not identified any material misstatements in the Board of

Directors’ Report.

2. Additional Report to the audit Committee

Our audit opinion on the Financial Statements is consistent with the Additional Report to the

Audit Committee of the Company dated 16 March 2023, pursuant to the requirements of article 11

of the Regulation 537/2014 of the European Union (EU).

3. Provision of non Audit Services

We have not provided to the Company any prohibited non-audit services referred to in article 5 of

Regulation (EU) 537/2014. The permissible non-audit services that we have provided to the

Company during the year ended 31 December 2022 are disclosed in Note 25 of the accompanying

Financial Statements.

4. Appointment of Auditors

We were appointed for the first time as Certified Auditors of the Company based on the decision

of the Annual General Shareholders’ Meeting dated 13/07/2022.

5. Operations Regulation

The Company has an Operations Regulation in accordance with the content provided by the

provisions of the article 14 of Law 4706/2020.

Page 117 of 177

6. Assurance Report on the European Single Electronic Reporting Format

We examined the digital files of the company Piraeus Port Authority S.A., which were prepared in

accordance with the European Single Electronic Format (ESEF) that is determined by the

Commission Delegated Regulation (EU) 2019/815, as amended by the Regulation (EU)

2020/1989 (the ESEF Regulation) that include the financial statements of the Company the year

ended as at 31 December 2022 in XHTML format.

Regulatory framework

The digital files of the European Single Electronic Format are prepared in accordance with the

ESEF Regulation and the 2020/C 379/01 Commission Interpretative Communication issued on

10 November 2020, as required by the L. 3556/2007 and the relevant announcements of the

Hellenic Capital Markets Commission and the Athens Stock Exchange (the “ESEF Regulatory

Framework”).

This Framework includes in summary, among others, that all the annual financial reports must be

prepared in XHTML format.

The requirements as defined in the ESEF Regulatory Framework as in force are appropriate

criteria in order to express a reasonable assurance conclusion.

Responsibilities of the Board of Directors and those charged with governance

The Board of Directors is responsible for the preparation and filing of the financial statements of

the Company, for the year ended as at 31 December 2022, in accordance with the requirements

determined by the ESEF Regulatory Framework, and for such internal control as management

determines is necessary to enable the preparation of digital files that are free from material

misstatement, whether due to fraud or error.

Auditors’ Responsibilities

Our responsibility is the planning and the execution of this assurance engagement in accordance

with the 214/4/11-02-2022 Decision of the Hellenic Accounting and Auditing Standards

Oversight Board and the Guidelines for the assurance engagement and report of Certified Auditors

on the European Single Electronic Reporting Format (ESEF) of issuers with shares listed in a

regulated market in Greece”, as these were issued by the Institute of Certified Public Accountants

of Greece on 14/02/2022 (the “ESEF Guidelines”), in order to obtain reasonable assurance that the

financial statements of the Company that are prepared by the management of the Company in

accordance with the ESEF comply in all material respects with the ESEF Regulatory Framework

as in force.

Our work was performed in accordance with the International Ethics Standards Board for

Accountants’ Code of Ethics for Professional Accountants, as it has been incorporated into Greek

legislation and we have also fulfilled our independence requirements, in accordance with the

L. 4449/2017 and the Regulation (EU) 537/2014.

The assurance work that we carried out refers exclusively to the ESEF Guidelines and was

conducted in accordance with the International Standard on Assurance Engagements 3000,

“Assurance Engagements other than Audits or Reviews of Historical Financial Information”.

Reasonable assurance is a high level of assurance, but is not a guarantee that such an assurance

engagement will always detect a material misstatement regarding non-compliance with the

requirements of the ESEF Regulation.

Page 118 of 177

Conclusion

Based on the procedures performed and the evidence obtained, we express the conclusion that the

financial statements of the Company for the year ended as of 31 December 2022 in XHTML

format, have been prepared, in all material respects, in accordance with the requirements of the

ESEF Regulatory Framework.

Athens, 17 March 2023

KPMG Certified Auditors S.A.

AM SOEL 114

Ioannis Bravos, Certified Auditor Accountant

AM SOEL 40651

Page 119 of 177

–

In accordance with the International Financial Reporting

Standards as adopted by the European Union

Page 120 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Notes 01.01-31.12.2022 01.01-31.12.2021

Revenue 24

194,567,342.48 154,189,971.98

Cost of sales 25

(83,533,672.93) (77,375,617.18)

Gross profit

111,033,669.55 76,814,354.80

Administrative expenses 25

(22,108,761.94) (27,686,314.12)

Net impairment losses on financial assets 11

(392,770.24) (882,101.88)

Other operating expenses 26

(16,802,261.66) (580,106.38)

Other operating income 26

5,495,898.96 4,747,118.22

Financial income 27

81,046.55 106,376.68

Financial expenses 27

(2,642,161.48) (3,308,333.62)

Profit before income taxes 74,664,659.74 49,210,993.70

Income taxes 9

(21,778,232.23) (12,449,283.84)

Net profit after taxes

52,886,427.51 36,761,709.86

Net other comprehensive income not to be reclassified in profit or

loss in subsequent period:

Actuarial losses 17 1,460,828.21 (34,245.43)

Income taxes 9

(321,382.21) 7,533.99

Other total comprehensive income after tax

1,139,446.00 (26,711.44)

Total comprehensive income after tax

54,025,873.51 36,734,998.42

Profit per share (Basic and diluted) 30

2.1155 1.4705

Weighted Average Number of Shares (Basic & Diluted)

30 25,000,000 25,000,000

The accompanying notes are an integral part of Financial Statements

Page 121 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Σημ. 31.12.2022 31.12.2021

ASSETS

Non current assets

Property, Plant and Equipment

4 304,412,893.51 293,677,764.81

Right-of-use assets

5 57,286,157.86 59,230,344.35

Investment property

6 734,338.38 734,338.38

Intangible assets

7 1,213,999.27 1,376,775.69

Other non-current assets

8 10,922,924.33 6,197,709.52

Deferred tax assets

9 3,592,830.73 6,945,886.23

Total non current assets

378,163,144.08 368,162,818.98

Current assets

Inventories

10 3,522,946.02 3,332,545.45

Trade Receivables and other receivables

11 18,386,945.15 18,148,475.76

Prepaid Expenses

12 1,755,497.19 1,342,878.91

Restricted cash

13 - 213,267.48

Cash and cash equivalents

13 171,535,343.22 134,975,285.73

Total Current Assets

195,200,731.58 158,012,453.33

TOTAL ASSETS

573,363,875.66 526,175,272.31

EQUITY AND LIABILITIES

Equity

Share capital

14 50,000,000.00 50,000,000.00

Reserves

15 84,953,696.20 84,221,336.11

Retained earnings

179,541,819.96 141,948,306.54

Total equity

314,495,516.16 276,169,642.65

Non-current liabilities

Long-term borrowings

19 32,499,999.99 38,499,999.99

Lease liabilities

5 62,937,704.62 64,128,097.26

Government grants

16 37,408,538.60 38,273,263.52

Reserve for staff retirement indemnities

17 9,983,578.40 10,207,275.80

Provisions

18 19,061,195.53 21,005,319.88

Other non-current liabilities

29 1,139,582.86 952,089.75

Deferred income

22 27,905,660.32 29,250,511.51

Total Non-Current Liabilities

190,936,260.32 202,316,557.71

Current Liabilities

Trade accounts payable

10,415,658.86 8,168,097.17

Short term of long term borrowings

19 6,000,000.00 6,000,000.00

Lease liabilities

5 1,369,521.49 1,307,885.46

Income tax

12,766,413.33 5,236,248.21

Accrued and other current liabilities

21 32,615,396.76 22,214,968.78

Deferred income

22 4,765,108.74 4,761,872.33

Total Current Liabilities

67,932,099.18 47,689,071.95

Total liabilities

258,868,359.50 250,005,629.66

TOTAL LIABILITIES AND EQUITY

573,363,875.66 526,175,272.31

The accompanying notes are an integral part of Financial Statements

Page 122 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Notes

Share capital

(Note 14)

Statutory reserve

(Note 15)

Other reserves

(Note 15)

Retained earnings Total

Total Equity at January 1, 2021 50,000,000.00 14,096,221.09 68,287,029.53 117,051,393.61 249,434,644.23

Profit after income taxes - - - 36,761,709.86 36,761,709.86

Other comprehensive loss after income taxes - - - (26,711.44) (26,711.44)

Total comprehensive income after income taxes - - - 36,734,998.42 36,734,998.42

Dividends payable 2020

- - - (10,000,000.00) (10,000,000.00)

Transfer to reserves - 1,838,085.49 - (1,838,085.49) -

Total Equity at December 31, 2021

50,000,000.00 15,934,306.58 68,287,029.53 141,948,306.54 276,169,642.65

Total Equity at January 1, 2022 50,000,000.00 15,934,306.58 68,287,029.53 141,948,306.54 276,169,642.65

Profit after income taxes - - - 52,886,427.51 52,886,427.51

Other comprehensive loss after income taxes - - - 1,139,446.00 1,139,446.00

Total comprehensive income after income taxes

- - -

54,025,873.51 54,025,873.51

Dividends payable 2021

- - - (15,700,000.00) (15,700,000.00)

Transfer to reserves - 732,360.09 - (732,360.09) -

Total Equity at December 31, 2022 50,000,000.00 16,666,666.67 68,287,029.53 179,541,819.96 314,495,516.16

0.00 140,169,875.79

The accompanying notes are an integral part of Financial Statements

Page 123 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Notes 01.01-31.12.2022 01.01-31.12.2021

Cash flows from Operating Activities

Profit before income taxes 74,664,659.74 49,210,993.70

Adjustments for:

Depreciation and amortisation

28 17,035,592.53 16,626,697.23

Amortisation of subsidies

28 (864,724.92) (864,724.92)

Depreciation right-of-use assets

28 2,169,427.07 2,129,500.19

Finance cost for lease liabilities

27 2,393,727.05 2,433,961.29

(Gain)/ Loss on disposal of property, plant & equipment and non current assets held for sale 4,26 72,661.05 (89,235.16)

Financial expenses, net

27 167,387.88 767,995.65

Provisions for cash settled share based payments

29 187,493.11 284,398.46

Provision for staff retirement indemnities

17 1,576,830.81 1,821,366.68

Other Provisions

11,18 (1,551,354.11) 5,159,016.09

95,851,700.21 77,479,969.21

(Increase)/Decrease in:

Inventories (190,400.57) 370,743.07

Trade and other receivables (2,425,717.99) (2,627,625.96)

Prepaid expenses (78,725.36) (1,144,265.02)

Restricted cash 213,267.48 -

Other long term assets (6,661.56) (2,518.00)

Increase/(Decrease) in:

Trade accounts payable 7,877,164.80 3,075,312.96

Accrued and other current liabilities 10,469,861.57 5,957,469.03

Deferred income 22 (1,341,614.78) (1,061,242.69)

Payments for staff leaving indemnities 17 (339,700.00) (2,162,000.00)

Interest income on debtors late payments 27 76,818.25 96,585.78

Cash generated from operating activities 110,105,992.05 79,982,428.38

Interest paid (240,680.39) (346,009.31)

Income taxes paid 9 (10,863,233.60) (5,228,338.35)

Net cash from Operating Activities 99,002,078.06 74,408,080.72

Cash flow from Investing activities

Grants received

16 1,095,291.89 11,717,036.41

Proceeds from the sale of property, plant and equipment and non current asset held for sale 4 23,354.10 287,000.00

Capital expenditure for property, plant and equipment and intagible assets 4 (32,695,099.21) (40,647,689.68)

Advances for capital expenditure for property, plant and equipment 8 (5,092,600.90) (1,931,968.55)

Interest and related income received

13,27 4,228.30 9,790.90

Net cash used in Investing Activities (36,664,825.82) (30,565,830.92)

Cash flows from Financing Activities

Net change in long-term borrowings 19 (6,000,000.00) (6,000,000.00)

Interest paid and guarantee fee (341,646.96) (528,363.05)

Lease payments 5 (3,735,547.79) (3,692,915.08)

Dividends paid 20 (15,700,000.00) (10,000,000.00)

Net cash used in Financing Activities (25,777,194.75) (20,221,278.13)

Net increase in cash and cash equivalents 13 36,560,057.49 23,620,971.67

Cash and cash equivalents at the beginning of the year 13 134,975,285.73 111,354,314.06

Cash and cash equivalents of the end of the year 13 171,535,343.22 134,975,285.73

The accompanying notes are an integral part of Financial Statements

Page 124 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

1. ESTABLISHMENT AND ACTIVITY OF THE COMPANY

“Piraeus Port Authority S.A” (from now on “PPA S.A.” or “Company”) was established in 1930 as Civil Law

Legal Corporation (C.L.L.C.) by Law 4748/1930, which was revised by L.1559/1950 and was ratified by

L.1630/1951 and converted into a Societé Anonyme (S.A.) by Law 2688/1999. The Company is located at

Municipality of Piraeus, at 10 Akti Miaouli street, TC 185 38.

The Company’s main objective is to perform its obligations, conduct its activities and exercise its faculties

under or in respect of the concession agreement between the Company and the Hellenic Republic dated 13

February 2002 regarding the use and exploitation of certain areas and assets within the Port of Piraeus, as

amended and in force.

The Company may, by way of an illustrative but no means exhaustive list, conduct and be engaged in the

following activities:

- to use all rights assigned to the Company pursuant to the Concession Agreement and maintain,

utilize and exploit all concession assets in accordance with the Concession Agreement;

- provide services and facilities to vessels, cargo and passengers, including ship berthing and cargo and

passenger handling to and from the port;

- install, organize and exploit all kinds of port infrastructure;

- undertake any activities related to the port and all other commercial activities associated with or

reasonably incidental to the operation of the port of Piraeus;

- engage third parties to provide any kind of port services;

- award contracts for works;

- engage in such further activities as are prudent or customary for the proper conduct of its business and

operations in accordance with the Concession Agreement; and

- engage in any and all activities, transactions or operations of a type that are generally conducted by

commercial corporations.

The main activities of the Company are anchoring services of vessels, handling cargo, loading and unloading

services as well as goods storage and car transportation. The Company is also responsible for the

maintenance of port facilities, the supply of port services (water, electricity, telephone connection etc.

supply), for services provided to travelers (coastal and cruise ships) and for renting space to third parties.

The Company is governed by the principles of L. 4548/2018 as replaced the Company Law 2190/1920 and

the founding Law 2688/1999, as amended by Law 2881/2001 and Law 4404/2016.

The duration period of the Company is one hundred (100) years from the effective date of Law 2688/1999.

This period may be extended by special resolution of the shareholders general meeting.

COSCO SHIPPING (Hong Kong) Limited controlled the 51% of the voting rights, with date of transfer of such

rights on 10 August 2016. COSCO SHIPPING (Hong Kong) Limited is 100% held by China Shipping Company

Limited, which is 100% held by China COSCO SHIPPING Corporation Limited, a Chinese state-owned

company. As a result, China COSCO SHIPPING Corporation Limited, by indirectly holding 100% of COSCO

SHIPPING (Hong Kong) Limited, indirectly held 51% of the voting rights in PPA.

On 6 October 2021, an over-the-counter transaction took place where COSCO SHIPPING (Hong Kong) Co.,

Limited acquired from Hellenic Republic Asset Development Fund S.A. an additional 16% of shares in PPA

S.A.As a result, the percentage of voting rights of COSCO SHIPPING (Hong Kong) Co., Limited in PPA S.A. has

increased from 51% to 67%. The above transaction has taken place under an Amended Share Purchase

Agreement between COSCO SHIPPING (Hong Kong) Co., Limited as Purchaser and Hellenic Republic Asset

Development Fund S.A. as Seller, following ratification of an Amendment to the Concession Agreement

between the Hellenic Republic and PPA S.A. (Law 4838/2021, Government Gazette 180A/ 01.10.2021).

Page 125 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

As a result of the above transaction, China COSCO Shipping Corporation Limited indirectly holds 67% of

voting rights in PPA S.A.

The Company’s number of employees as at December 31, 2022 amounted to 962. At December 31, 2021,

the respective number of employees was 960.

Certain prior year items have been reclassified in ordrer to be similar and comparable to current year’s

items.

2. BASIS OF PRESENTATION OF FINANCIAL STATEMENTS:

(a) Basis of Preparation of Financial Statements

The financial statements have been prepared in accordance with International Financial Reporting

Standards (IFRS) as adopted by the European Union (E.U.). These financial statements have been

prepared under the historical cost, except for liabilities for cash settled share based payments that are fair

value, as well as going concern basis. All amounts presented in the financial statements are in euros. Any

differences between the amounts included in the financial statements and the respective amounts

included in the notes are attributed to roundings.

The preparation of financial statements according to the IFRS requires estimates and assumptions to be

made by the management, influencing the assets and liabilities amounts, the disclosure of potential

receivable and liabilities as at the financial statements date, as well as the revenue and expenditure

amounts, during the financial period. Actual results may differ from these estimations. It also requires

management to exercise its judgment in the process of applying the accounting policies which have been

adopted. The areas involving a higher degree of judgment or complexity, or areas where assumptions and

estimates are significant to the financial statements are disclosed in note 2(c).

The Company's Management observes closely and evaluates continuously the protracted conflict in

Ukraine and its effects on the macroeconomic and financial environment, such as the unprecedented

energy crisis, the rapid increase in cost energy and bank interest rates, but also the more and more

intense inflationary pressures the last decades, as well as to a lesser extent, the evolution of the COVID-

19 pandemic, in order to ensure that all necessary actions and initiatives are undertaken to minimize

possible consequences for the Company’s activities.

Management believes that its strong capital position and liquidity, its activity in different sectors, its

strong and dynamic management and the experienced human resources as well as the fact that until now

the war in Ukraine has not significantly affected its activities , will allow the Company to successfully

overcome any period of uncertainty and has reached the conclusion that no additional impairment

provisions of the financial and non-financial assets of the Company are required on December 31, 2022.

(b) Approval of Financial Statements

The Board of Directors of the Company approved the financial statements for the year ended at

December 31, 2022, on March 17, 2023. The abovementioned financial statements are subject to the final

approval of the Annual General Assembly of the Shareholders.

The Company makes estimates and judgments in order to select the most appropriate accounting

principles taking into consideration the future outcome of events and transactions. Estimates and

judgments are continually evaluated and are based on historical experience and other factors, including

expectations of future events that are believed to be reasonable under the circumstances. Estimates and

judgments adopted in the preparation of the annual financial statements are consistent with those

followed in the preparation of the annual financial statements for the year ended December 31, 2021.

Page 126 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The estimates and judgments that have a risk of causing a material adjustment to the carrying amounts of

assets and liabilities within the next financial year are as follows:

c.1 Significant accounting estimates and assumptions

(i) Allowance for doubtful accounts receivables and legal cases: Management periodically reassess the

adequacy of allowance for doubtful accounts receivable following an expected credit losses (‘ECLs’)

approach. The expected loss rate is assessed on the basis of historical credit losses adjusted to reflect

current and forward-looking information. ECLs are based on the difference between the contractual cash

flows due and all the cash flows that the Company expects to receive and taking into consideration reports

from its legal department. For the allowance of legal cases management assesses the probability of

negative outcome, as well as possible payment amounts for their settlement.

(ii) Provision for income taxes: According to IAS 12, income tax provisions are based on estimations as to

the taxes that shall be paid to the tax authorities and includes the current income tax for each fiscal year,

the provision for additional taxes which may arise from future tax audits and the recognition of future tax

benefits. The final clearance of income taxes may be different from the relevant amounts which are

included in these financial statements.

(iii) Deferred tax assets on provisions of bad debts: Deferred tax assets are recognized for provisions of

bad debts to the extent that it is probable that, based on tax law, the Company has the right to proceed

with the tax deduction of the related provision. Significant management judgment is required to determine

the amount of deferred tax assets that can be recognized, based upon the particular actions that have been

taken (seizure, auction, filling of relevant lists to the tax authorities etc.) in order to record a provision for

bad debts.

(iv) Depreciation rates: The Company’s assets are depreciated over their estimated remaining useful lives.

These useful lives are periodically reassessed to determine whether the original period continues to be

appropriate. The actual lives of these assets can vary depending on a variety of factors such as

technological innovation and maintenance programs.

(v) Provision for staff leaving indemnities:The cost for staff leaving indemnities is determined based on

actuarial valuations. The actuarial valuation requires management to make assumptions about future salary

increases, discount rates, mortality rates, etc. Management, at each reporting date when the provision is

re-examined, tries to give its best estimate regarding the above mentioned parameters.

(vi) Leases: The Company during the prior year made a significant estimate to determine the “incremental

borrowing rate” that it used to recognize its lease contract with the Greek State because of its special

nature. This contract is the Company's main lease agreement (Note 3 (t)).

(vii) Share-based payments, cash-settled : At each reporting date, the Company makes estimates to

measure the fair value of the share-based benefit obligation on the data to be included in the relevant

valuation model as the dividend yield, free interest-risk. In addition, the Management of the Company, in

assessing the fair value of the obligation of the specific benefits, makes estimates regarding the

performance of its specific financial figures, as well as estimates regarding the performance of the

beneficiaries of those benefits.

(viii) Impairment of property, plant and equipment: Property, plant and equipment are tested for

impairment when there are indicators that the carrying amounts may not be recoverable. When value in

use calculations are undertaken, management estimates the expected future cash flows from the asset or

cash-generating unit and chooses a suitable discount rate in order to calculate the present value of those

cash flows. The impact of COVID-19 pandemic on specific segments of activity (Note 23) as well as the

deterioration of the macroeconomic environment in previous year, led the Company to proceed with an

interim assessment of impairment of the recoverable amount for the sectors of activity that were

significantly affected and recorded losses due to COVID-19 pandemic impact and deteriorating

macroeconomic conditions.

Page 127 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The Company, as the previous year, conducted an impairment assessment of the recoverable amount on

December 31, 2022 , in the activity sector of the Container Terminal, which continued in the current year to

show losses, although important reduced compared to previous year.

On June 30, 2022, the Company conducted an interim assessment of impairment of the recoverable

amount for the Container segment, although in the first half of 2022 there were significantly reduced losses

comparatively to the 1

semester of 2021.

The recoverable amount of the sector was determined by the value in use which was calculated based on

adjusted discounted cash flows and revised business plans of the sector. The pre-tax interest rate used to

discount the projected cash flows is 9.5% (31.12.2021: 7.10%). Sensitivity analysis was performed on the

positive or negative change in the discount rate and revenues by 0.25% and 0.50% respectively. Based on

the results, the present value exceeds the carrying amount of the tangible assets of the container terminal

and therefore on 30 June 2022, no impairment was recorded.

Subsequent to the interim assessment, the Company performed an assessment of impairment of the

recoverable amount on December 31, 2022, evaluating the new data in the Container Terminal segment

which continued to present losses in the current year, but they were significantly reduced from the

previous year.

Regarding the Container Terminal, the recoverable amount of the sector was determined from the value in

use which was calculated based on adjusted discounted cash flows and revised business plans of the sector.

The pre-tax interest rate used to discount the projected cash flows is 10.30% (31.12.2021: 7.10%).

Sensitivity analysis was performed on the positive or negative change in the discount rate and income by

0.25% and 0.50% respectively. Based on the results, the present value exceeds the book value of the

tangible fixed assets of the Container Terminal and therefore as at 31 December 2022, no relevant

impairment was recorded.

(ix) Contingent liabilities: The existence of contingent liabilities requires from management to make

assumptions and estimates continuously related to the possibility that future events may or may not occur

as well as the effects that those events may have on the activities of the Company.

c.2 Significant judgements on the implementation of accounting policies

(ii) Leases: The Company made judgments as to whether the sub-lease agreements in which the Company

is a lessor relate to operating or finance leases. The contracts to which the Company is a lessor relate

mainly to the contract with Piraeus Container Terminal S.A. (Note 3 (t)) as well as contracts related to

leased areas to ship repair zone. The management's judgment was based mainly on the duration of the

leases.

Concerning the contract with Piraeus Container Terminal S.A., in previous years management concluded

that it is an operating lease due to its duration and because the lease does not substantially transfer the

risks and rewards of the right of use.

With regard to the concession agreement with the Greek State, the Company concluded that it falls under

the provisions of IFRS 16 and not to the corresponding provisions of IFRIC 12, as the Company has the

control over the pricing of its services other than coastal shipping and therefore the contract is a contract

lease.

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

3. PRINCIPAL ACCOUNTING POLICIES

The Company applies the following accounting policies for the preparation of the accompanying financial

statements:

(a) Tangible Assets: Buildings, technical projects and other building installations are valued at acquisition cost

less accumulated depreciation and possible impairment provision. The privately owned land, machinery

and other equipment, acquired before PPA’s conversion into an S.A., 1.6.1999, were valued at deemed

cost, arising by the Evaluation Committee of article 9 C.L. 2190/1920, while those acquired afterwards are

valued at acquisition cost less accumulated depreciation and possible value impairment provision.

Acquisition cost of a building installation or equipment consists of purchase price include import duties,

plus non-refundable purchase taxes as well as any cost required for the asset to become operational.

Repairs and maintenance are posted to the financial period in which they were incurred. Significant

additions and improvements made at a later stage are capitalized in the relevant asset cost.

Fixed assets constructed by the Company are posted to the self-construction cost which includes

subcontractors’ fees, materials and technicians’ payroll costs involved in the construction (including

relevant employer contributions) as well as part of general administration expenses.

Assets under construction include fixed assets under construction and are stated at their cost. Assets

under construction are not depreciated until the fixed assets are complete and operational.

(b) Depreciation: Fixed assets are depreciated on a straight line basis according to the following useful lives

per fixed asset category:

Fixed Asset Categories

Useful Life (years)

Buildings, technical & port projects

25-40

Machinery & other equipment

10-30

Motor Vehicles

5-12

Floating transportation means

20-35

Furniture, fixture & fittings

5-10

The residual value, the useful life and the depreciation method of the Company's assets are examined

annually and they are adjusted if necessary.

be evaluated for possible impairment loss, when there are indications that the asset’s book value is over its

recoverable amount. When an asset’s book value is over its recoverable amount, the respective

impairment loss is posted to the period financial results. An asset’s recoverable value is the greater amount

between the fair value less cost of disposal and the value in use.

Value in use is based on the Company's projected cash flows, discounted to present value using a discount

rate that reflects current economic considerations and risks associated with the particular asset or cash-

generating unit.

For the purpose of assessing impairment, assets are grouped at the lowest level for which cash flows can be

identified separately (cash generating units). Impairment losses recognized in prior periods in non-financial

assets are reviewed at each reporting date for any reversal.

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

(d) Investment property: Investment property that includes land and buildings is held by the Company for

long-term rental yields and not for own use. Investment property is measured at cost less depreciation

and impairment.

The depreciation of buildings is calculated using the straight line method over the buildings’ useful life

which is 30 years. When the carrying amounts of the investment property exceed their recoverable

amounts, the difference (impairment) is charged directly to the statement of comprehensive income.

Land is not depreciated.

Transfers are made to investment property when, and only when, there is a change in use, evidenced by

the end of owner occupation.

(e) Fixed Asset Subsidies: Government grants are recognised when there is reasonable assurance that the

grant will be received, and all attached conditions will be complied with. Subsidies are considered as

deferred revenue and are recognized as income at the same depreciation rate as the relevant subsidized

fixed assets are depreciated. This income is deducted from the depreciation in the period financial results.

(f) Intangible Assets: Intangible assets include software purchase cost and any expenditure for software

development. Software is carried at cost less accumulated amortization. Software depreciation is

calculated on a straight line basis and its useful life of 3-4 years.

(g) Borrowing Cost: Borrowing costs are interest and other costs an entity incurs in relation to the borrowing

of funds. Borrowing costs directly attributable to the acquisition, construction or production of an asset

that necessarily takes a substantial period of time to get ready for its intended use or sale are capitalised

as part of the cost of the asset.

Borrowing costs are capitalized if the funds raised are specifically used for the acquisition of fixed

assets. If the funds were generally raised and used for the acquisition of fixed assets, the portion of the

borrowing costs capitalized is determined by applying a capitalization factor to the cost of acquiring the

asset. All other borrowing costs are expensed in the period in which they occur.

(h) Non-current assets (or disposal groups) held for sale

Non-current assets (or disposal groups) are classified as held for sale if their carrying amount will be

recovered principally through a sale transaction rather than through continuing use and a sale is

considered highly probable. They are measured at the lower of their carrying amount and fair value less

costs to sell.

The criteria for classifying assets held for sale are deemed to be met only when the sale is highly probable,

and the asset or disposal group is available for immediate sale in the present situation. The steps required

to complete the sale should indicate that it is unlikely that significant changes will be made to the sale or

that the sale decision will be revoked. Management must commit to the plan of sale of the asset and the

sale that is expected to be completed within one year from the date of classification.

An impairment loss is recognised for any initial or subsequent write-down of the asset (or disposal group)

to fair value less costs to sell. A gain is recognised for any subsequent increases in fair value less costs to

sell of an asset (or disposal group), but not in excess of any cumulative impairment loss previously

recognised. A gain or loss not previously recognised by the date of the sale of the non-current asset (or

disposal group) is recognised at the date of derecognition.

Non-current assets (including those that are part of a disposal group) are not depreciated or amortised

while they are classified as held for sale. Interest and other expenses attributable to the liabilities of a

disposal group classified as held for sale continue to be recognised.

Page 130 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

(i) Financial Instruments: Initial recognition and subsequent measurement

A financial instrument is any contract that gives rise to a financial asset of one entity and a financial

liability or equity instrument of another entity.

▪ Financial assets

Initial recognition and measurement

Financial assets of the Company are classified, at initial recognition, as subsequently measured at

amortised cost, fair value through other comprehensive income, and fair value through profit or loss.

The classification of financial assets at initial recognition depends on the financial asset’s contractual cash

flow characteristics and the Company’s business model for managing them.

Cash and cash equivalents are related to short-term, highly liquid investments (cash at banks, mutual

funds), which are easily convertible into cash and are so close to expiry that they show non significant risk

for changes in their valuation at the time of their liquidation.

With the exception of trade receivables that do not contain a significant financing component or for

which the Company has applied the practical expedient, the Company initially measures a financial asset

at its fair value plus, in the case of a financial asset not at fair value through profit or loss, transaction

costs. Trade receivables that do not contain a significant financing component or for which the Company

has applied the practical expedient, are measured at the transaction price as determined under IFRS 15.

In order for a financial asset to be classified and measured at amortised cost or fair value through other

comprehensive income, it needs to give rise to cash flows that are solely payments of principal and

interest on the principal amount outstanding. This assessment is referred to as the ‘solely payments of

principal and interest’ test and is performed at an instrument level.

The Company’s business model for managing financial assets refers to how the Company manages its

financial assets in order to generate cash flows. The business model determines whether cash flows will

result from collecting contractual cash flows, selling the financial assets, or both.

Purchases or sales of financial assets that require delivery of assets within a time frame established by

regulation or convention in the market place (regular way trades) are recognised on the trade date, i.e.,

the date that the Company commits to purchase or sell the asset.

Subsequent measurement

For purposes of subsequent measurement, financial assets are classified in four categories:

• Financial assets at amortised cost (debt instruments)

• Financial assets at fair value through OCI with recycling of cumulative gains and losses (debt

instruments)

• Financial assets designated at fair value through OCI with no recycling of cumulative gains and

losses upon derecognition (equity instruments)

• Financial assets at fair value through profit or loss

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Financial assets at amortised cost (debt instruments)

This category is the most relevant to the Company. The Company measures financial assets at amortised

cost if both of the following conditions are met:

• The financial asset is held within a business model with the objective to hold financial assets in

order to collect contractual cash flows

And

• The contractual terms of the financial asset give rise on specified dates to cash flows that are solely

payments of principal and interest on the principal amount outstanding.

Financial assets at amortised cost are subsequently measured using the effective interest (EIR) method

and are subject to impairment. Gains and losses are recognised in profit or loss when the asset is

derecognised, modified or impaired.

The Company’s financial assets at amortised cost include trade and other receivables.

Derecognition of financial asset

A financial asset (or, where applicable a part of a financial asset or part of a group of similar financial

assets) is derecognised when:

• The rights to receive cash flows from the asset have expired

• The Company tranfers a financial asset and the tranfer meets the requirements for write-off. The

Company transfers a financial asset if, and only if, it either:

• transfers the contractual rights to receive the cash flows of the financial asset

• retains the contractual rights to receive the cash flows of the financial asset but assumes a

contractual obligation to pay the cash flows to one or more recipients in an arrangement.

When the Company transfers a financial asset, it shall evaluate the extent to which retains the risks and

rewards of ownership of the financial asset.

In this case:

• if the Company transfers substantially all the risks and rewards of ownership of the financial asset, the

entity shall derecognise the financial asset and recognise separately as assets or liabilities any rights and

obligations created or retained in the transfer.

• if the Company retains substantially all the risks and rewards of ownership of the financial asset, the

Company shall continue to recognise the financial asset.

• if the Company neither transfers nor retains substantially all the risks and rewards of ownership of the

financial asset, shall determine whether it has retained control of the financial asset. In this case:

(i) if the Company has not retained control, it shall derecognise the financial asset and recognise

separately as assets or liabilities any rights and obligations created or retained in the transfer.

(ii) if the Company has retained control, it shall continue to recognise the financial asset to the extent of

its continuing involvement in the financial asset.

Impairment of financial assets

The Company recognise an allowance for expected credit losses for all debt instruments not held at fair

value through profit or loss. Expected credit losses are based on the difference between the contractual

cash flows due in accordance with the contract and all the cash flows that the Company expects to

receive, discounted at an approximation of the original effective interest rate.

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The expected cash flows will include cash flows from the sale of collateral held or other credit

enhancements that are integral to the contractual terms.

For trade and other receivables, the Company apply a simplified approach in calculating expected credit

losses. Therefore, the Company does not track changes in credit risk, but instead recognises a loss

allowance based on lifetime expected credit losses at each reporting date. For other financial assets, the

ECL is based on the 12-month ECL. The 12-month ECL is the portion of lifetime ECLs that results from

default events on a financial instrument that are possible within 12 months after the reporting date.

However, when there has been a significant increase in credit risk since origination, the allowance will be

based on the lifetime ECL. The Company considered the risk of default, the days past due and the

historical credit losses experienced adjusted to reflect current and forward-looking information per

debtor to measure the expected credit losses for each individual trade and other receivable balance.

At each reporting date, the Company assess whether the credit risk of a financial asset has increased

significantly from the initial recognition. The Company consider a financial asset in default when

contractual payments past due over the Company’s credit policy. However, in certain cases, the Company

may also consider a financial asset to be in default when internal or external information indicates that

the Company is unlikely to receive the outstanding contractual amounts in full before taking into account

any credit enhancements held by the Company. A financial asset is written off when there is no

reasonable expectation of recovering the contractual cash flows.

▪ Financial liabilities

Initial recognition and measurement

Financial liabilities of the Company are classified, at initial recognition, as financial liabilities at fair value

through profit or loss, loans and borrowings, trade and other payables.

All financial liabilities are recognised initially at fair value and, in the case of loans and borrowings and

payables, net of directly attributable transaction costs.

The Company’s financial liabilities include trade and other payables, loans and borrowings including bank

overdrafts.

Subsequent measurement

The measurement of financial liabilities depends on their classification, as described below:

Loans and borrowings

After initial recognition, interest-bearing loans and borrowings are subsequently measured at amortised

cost using the effective interest rate method. Gains and losses are recognised in the statement of

comprehensive income when the liabilities are derecognised as well as through the effective interest rate

amortisation process.

Amortised cost is calculated by taking into account any discount or premium on acquisition and fees or

costs that are an integral part of the effective interest rate. The effective interest rate amortisation is

included as finance costs in the statement of comprehensive income.

This category generally applies to interest-bearing loans and borrowings. Loans and borrowings are

classified as current liabilities unless the Group and the Company has the right to defer settlement for at

least twelve months from the date of financial position date.

Trade and other payables

Trade payables are obligations for goods or services that have been acquired in the ordinary course of

business by suppliers. Accounts payable are classified as current liabilities if payment is due within one

year or less. If not, they are presented as non-current liabilities. Trade account payables subsequent to

the initial recognition are measured at amortized cost using the effective interest method.

Page 133 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Derecognition of financial liabilities

A financial liability is derecognised when the obligation under the liability is discharged or cancelled or

expires. When an existing financial liability is replaced by another from the same lender on substantially

different terms, or the terms of an existing liability are substantially modified, such an exchange or

modification is treated as the derecognition of the original liability and the recognition of a new

liability.The difference in the respective carrying amounts is recognised in the statement of

comprehensive income.

▪ Offsetting of financial instruments

Financial assets and financial liabilities are offset, and the net amount is reported in the consolidated

statement of financial position if there is a currently enforceable legal right to offset the recognised

amounts and there is an intention to settle on a net basis, to demand the assets and settle the liabilities

simultaneously.

(j) Share Capital: The share capital includes the Company's ordinary shares that are included in equity. Upon

acquisition of treasury shares, the consideration paid, including the related expenses, is shown as a

deduction from equity (share premium). Expenses incurred for the issue of shares are recognized after

deduction of the relevant income tax, net of the issue proceeds. Expenses related to the issue of shares

for the acquisition of business are included in the acquisition cost of the business acquire.

The Company considers as cash (apart from cash on hand) time deposits and liquid investments maturing

in three months from the acquisition date.

(k) Provisions: Provisions are recognized when the Company has a present obligation (legal or constructive)

as a result of a past event, it is probable that an outflow of resources embodying economic benefits will

be required to settle the obligation and a reliable estimate can be made of the amount of the obligation.

If the effect of the time value of money is material, provisions are measured by discounting the expected

future cash flows at a pre-tax rate that reflects current market assessments of the time value of money

and the risks specific to the liability. Where discounting is used, the increase of the provision due to the

passage of time is recognized as a borrowing cost. Provisions are reviewed at each reporting date, and if

it is no longer probable that an outflow of resources embodying economic benefits will be required to

settle the obligation, they are reversed. Provisions are used only for expenditures for which they were

originally recognized. No provisions are recognized for future operating losses. Contingent assets and

contingent liabilities are not recognized.

(l) Income Tax (Current and Deferred): Current and deferred income tax assessment are based on the

relevant amounts of the financial statements, according to tax Laws effective in Greece. Current income

tax concerns tax on the Company taxable profits, adjusted according to Greek tax Law and calculated

using the current tax rate on the reference date.

Deferred tax is assessed using the liability method in all temporary tax differences on the balance- sheet

date between the tax base and the accounting value of assets and liabilities. The expected tax

consequences from the temporary tax differences are assessed and stated either as deferred tax

liabilities or as deferred tax assets. Deferred tax assets are posted to the financial statements for all

allowable temporary differences and tax losses carried forward as far as it is likely to set off these

allowable temporary differences against available taxable profits.

The accounting value of deferred tax assets is revised at each balance- sheet date and it is reduced up to

the point that it is not likely to have enough taxable profits, where part or all of the deferred tax assets

may be set off against. Current income tax receivable and liabilities for current and previous financial

years are valued at the amount expected to be paid to Tax Authorities (or be refunded by them), using

the tax rates (and tax Laws) in force up to the balance- sheet date.

Page 134 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Any differences resulting from tax audits are recorded in accordance with International Accounting

Standard 12 "Income Taxes" in the "Income Tax" line of the Statement of Comprehensive Income, while

the corresponding fines and surcharges are recorded in the "Other Operating Expenses" line of the

Statement of Comprehensive Income in accordance with the provisions of IAS 37.

(m) Revenue Recognition: Revenue is the amount of consideration expected to be received in exchange for

transferring promised services to a customer, excluding amounts collected on behalf of third parties

(value-added tax, other sales taxes, etc.).

The Company recognizes revenue upon the transfer of promising goods or services to customers, in

amounts that reflect the reward to which the Company is expected to be entitled of these goods or

services based on the following five-step approach: Step 1: To identify the Contract Step 2: To identify the

separate performance obligations within a Contract Step 3: To determine the transaction price. Step 4: To

allocate the transaction price to the performance obligations in the Contract Step 5: To recognize revenue

when or as a performance obligation is satisfied.

The Company derives revenue from Cargo loading and unloading services, mooring services, storage of

cargo services, income from coastal and cruise ships services, which include income from mooring and

berthing of the vessels as well as income from passenger fees and income from vehicle passage, Dry

docking, and shipbuilding repair zones services which include the income for the berthing, the use of dock

and ship-building zones and the provision of electricity and water to the vessels that are in the zone,

Environmental services which include a standard fee charged to each vessel approaching the port and

fees related to the waste handling of the vessels and Other supporting services to the vessels (e.g

provision of water, use of loading machines).

Revenue is recognized when (or as) a performance obligation is satisfied by transferring the control of a

promised service to the customer. A customer obtains control of a service if it has the ability to direct the

use of and obtain substantially all of the remaining benefits from that service. Control is transferred over

time or at a point in time when the service is provided to the customer.

Management has determined that for loading and unloading services, berthing and mooring services,

services relating to the provision of water and electricity, and for environmental services there is a single

performance obligation which is the loading and unloading of the respective cargo (container, vehicles),

the berthing and the mooring of the vessel, the provision of water and electricity, the mooring of the

vessel and the waste handling, respectively, and revenue is recognized at a point in time when the

respective service is provided to the customer and the customer obtains the benefit of these services. For

the storage services where the customer is charged with a daily charge for each day that the cargo

remains in the warehouse and for dry-docking and shipbuilding repairs zone services where the customer

is charged with a daily charge for each day that the vessel remains in the zone, the Company has

determined that there is one single performance obligation which is to provide the customer with the

required space and the related services. The Company has concluded that revenue from these services

meets the criteria to be recognized over time because the customer simultaneously receives and

consumes the benefits of the Company’s performance as the Company performs. Therefore, since the

Company’s performance obligation is met evenly, revenue is recognized ratably for the period that the

cargo actually remained in the warehouse and the period that the vessel actually remained in the zone,

respectively. Prices for all services are fixed, based on stand-alone selling prices derived from price lists.

A receivable is recognized when there is an unconditional right to consideration for the performance

obligations to the customer that are satisfied.

Page 135 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

A contract asset is recognized when the performance obligation to the customer is satisfied before the

customer pays or before payment is due, usually when services are transferred to the customer before

the Company has a right to invoice.

A contract liability is recognized when there is an obligation to transfer services to a customer for which

the Company has received consideration from the customer (prepayments) or there is an unconditional

right to receive consideration before the Company transfers a service (deferred income). The contract

liability is derecognized when the promise is fulfilled and revenue is recorded in the profit or loss

statement.

(n) Inventories: Materials and spare parts related to the Company mechanical equipment maintenance are

valued at the lower of acquisition cost and net realisable value and their cost is determined on the

weighted average cost basis. Net realizable value is estimated based on the current selling price in the

ordinary course of business, less selling expenses. Materials are posted to inventories on purchase and

recognized as expenditure on consumption.

(o) Defined benefit plan: The provision for staff termination indemnities recorded in the statement of

financial position for the defined benefit plan is the present value of the liability for the defined benefit in

addition to changes occurring from any other actuarial profit or loss and the past service cost. The

discount rate is considered as the yield, at the balance sheet date, of high quality European corporate

bonds which have a maturity which approaches the time period of the Company’s liability.

The liability for this plan is determined using the projected unit credit method from an independent

valuer and includes the present value of accrued services during the year, the interest on future liabilities,

the prior service cost and the actuarial gains or losses.

The cost of current employment of defined benefit plan, the past service cost and finance cost are

recognized in the Statement of Comprehensive Income.

Re-measurements, comprising of actuarial gains and losses, the effect of the asset ceiling, excluding net

interest and the return on plan assets, are recognized immediately in the statement of financial position

with a corresponding debit or credit to the actuarial differences reserve through other comprehensive

income in the period in which they occur. Remeasurements are not classified to profit or loss in

subsequent periods.

Page 136 από 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

(p) Leases:

a) Company as lessee

Leases are recognised as a right-of-use asset and a corresponding liability at the date at which the leased

asset is available for use by the Company. Each lease payment is divided between the lease liability and the

finance cost. The interest on the lease liability for each period of the lease term is equal to the amount

resulting from the application of a fixed periodic interest rate on the outstanding balance of the lease

liability. The right of use asset is depreciated over the shorter period between the useful life of the asset

and the lease contact duration.

The assets and liabilities arising from the lease are initially valued at present value.

Assets and liabilities arising from a lease are initially measured on a present value basis. Lease liabilities

include the net present value of the following lease payments:

• fixed payments (including in-substance fixed payments), less any lease incentives receivable,

• variable lease payment that are based on an index or a rate, which are initially measured using the ratio

or interest rate at the date of commencement of the lease term

• amounts expected to be payable by the lessee under residual value guarantees,

• the exercise price of a purchase option if the lessee is reasonably certain to exercise that option, and

• payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that

option.

The lease payments are discounted using the interest rate implicit in the lease. If that rate can not be

determined, the lessee’s incremental borrowing rate is used, being the rate that the lessee would have to

pay to borrow the funds necessary to obtain an asset of similar value in a similar economic environment

with similar terms and conditions.

After the commencement date, the lease liability is measured by increasing the carrying amount to reflect

interest on the lease liability and by reducing the carrying amount to reflect the lease payments made.

The lease liability is remeasured to reflect any reassessment or lease modifications or to reflect revised in-

substance fixed lease payments.

The Company elected to use the on-going recognition exemptions for lease contracts that, at the

commencement date, have a lease term of 12 months or less and do not contain a purchase option (short-

term leases), and lease contracts for which the underlying asset is of low value (low-value assets).

Payments associated with short-term leases and leases of low-value assets are recognized on a straight-line

basis as an expense in profit or loss.

Finally, the Company chose not to separate the non-lease components from lease components, and instead

account for each lease component and any associated non-lease components as a single lease component

for all classes of underlying assets to which the right of use relates.

Right-of-use assets are measured at cost comprising the following:

• the amount of the initial measurement of lease liability,

• any lease payments made at or before the commencement date less any lease incentives received,

• any initial direct costs, and

• an estimate of costs to be incurred by the lessee in dismantling and removing the underlying asset,

restoring the site on which it is located or restoring the underlying asset to the condition required by the

terms and conditions of the lease, unless those costs are incurred to produce inventories. The lessee incurs

the obligation for those costs either at the commencement date or as a consequence of having used the

underlying asset during a particular period.

The Company presents the rights of use of the assets of the assets, which are not investment properties, in

the account "Right of use assets".

Page 137 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

b) Company as lessor

The leases in which the Company is a lessor relate solely to sub-leases and are classified as finance or

operating. The Company's sub-lease agreements at 31 December 2022 and 31 December 2021 relate

exclusively to operating leases.

Revenue from rental income arising, from operating leases, is accounted for on a straight-line basis over

the lease terms.

The Company reflects the future tax impacts of leases and recognises deferred tax. When recognising

deferred tax the Company has assessed the lease asset and lease liability together as a single or ‘integrally

linked’ transaction and assessed the net temporary difference.

(q) National Insurance Programs: The obligation for main or supplementary pension provision is covered by

the main National Insurance Department (EFKA- Social Insurance Institute) which concerns private sector

and provides retirement, medical and pharmaceutical services. Each employee is obliged to contribute part

of his salary to the National Insurance Department, while part of the total contribution is paid by the

Company. On employee retirement the National Insurance Department is responsible for their pension

payments. Therefore, the Company has no legal or presumed obligation for future payments according to

this program.

The employees of PPA are entitled upon retirement an allowance from the Unified Fund for Supplementary

Benefits and Lump-sum Benefits (ΕΤΕΑΕP) according to the statutory provisions of the Fund and the Law N.

2084/92.

For the two welfare sectors, dockworkers and employees of PPA, the granted amount is currently

determined on the basis of the provisions of article 35 of Law N.4387 / 12-05-2016 (FEK), considering the

average of the total remuneration – without accounting holiday bonus - on which were calculated social

insurance contributions for welfare for the five-year period 2009-2013 and with the employee's work year

experience until 31/12/2013.

To this amount is added the total of insurance contributions for welfare from 01/01/2014 and afterwards.

Every employee is required to contribute a part of his monthly salary to the fund, while part of the total

contribution is covered by the Company.

This fund is a legal public company and is responsible for paying the above benefits to employees.

Consequently, the Company has no legal or constructive obligation to pay future benefits under this plan.

(r) Earnings per Share: Earnings per share are calculated by dividing the financial period net profit,

corresponding to ordinary shareholders, by the weighted average number of ordinary shares issued. The

accompanying financial statements did not include any profit decreasing bonds or other stock, convertible

to shares. Consequently, diluted earnings per share were not calculated.

(s) Dividends: Dividends are accounted for when receipt rights are finalized by the resolution of the

shareholders general meeting.

(t) Concession Agreement to PPA S.A.: In persuasion of the 35th article of 2932/2001 Law, Greek Government

and the Company signed on 13.2.2002 the Concession Agreement, by which the government transfers its

exclusive right of use and exploitation of port zone lands, buildings and facilities of Piraeus Port to the

Company.

This concession was agreed for fixed period initial duration of 40 years, beginning on the day the

agreement and ending on 13.2.2042. The initial duration is possible to be extended once or several times

by Law. And a new written agreement and modification of the 4.1 article of the Concession Agreement.

Page 138 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

With the Common Ministry Decision (CMD) no. 8322/3-12-2008, published in Government Paper 2372/21-

11-2008, the Concession Agreement duration has been modified from 40 to 50 years, beginning on the

13/2/2002 (initial signature date) and ending on the respective date of the year 2052.

Management has examined whether the contract for the concession of the exclusive right to use and

exploit land, buildings and facilities at the Port of Piraeus Land Zone fall under the scope of the provisions

of Interpretation 12. Management concluded that the concession does not fall under the scope of

application of Interpretation 12, as it is a lease contract.

Government has received 1% of the Company’s consolidated annual income for each of the first 3 years of

the concession. The above percentage has increased to 2% of the Company’s consolidated annual income

after the 3rd year, on the same calculation basis. Based on the new Concession Agreement signed on

24.6.2016 the percentage to Greek State has increased to 3.5% of the Company’s consolidated annual

income excluding finance income with fixed minimum fee amounted to € 3.5 million.

As of 1/1/2019, due to the adoption of IFRS 16, in the expenses is recorded only the variable amount of the

concession fee while the fixed minimum fee amounted to € 3.5 million is included to the right-of-use assets

and lease liability (Note 5).

The Company most significant obligations arising from this agreement are:

• Constant rendering of port services

• Responsibility for the installation, improvement and maintenance of the security level in Piraeus

Port.

• Ensure fair deal to all port users

• Payment of maintenance expenditure for all the property included in the Concession Agreement

The Concession Agreement was amended by Law 4838/2021, Government Gazette 180A/ 01.10.2021 and

the main points are the following:

• non-imposition of liquidated damages for the non-time completion of the first mandatory

enhancements under article 16 of the concession agreement par 5 (a) (i)

• extension of the first investment period for five (5) years

• possibility of suspension of the first investment period - establishment of an amicable settlement

mechanism - possibility of replacing of the first investment period

• non-imposition of liquidated damages against PPA in case of suspension

• extension of the second investment period

• introduction of a flexible procedure for the approval of final studies and non-mandatory PPA

investments

• extension of the grace for the partial achievement of minimum levels of services

(u) Concession Agreement of Piers II and III with COSCO Pacific Ltd (currently COSCO Shipping Port Ltd): The

Law 3755/2009 ratified by the Parliament ruled the concession of use and operation of Piers II and III

between the Company and COSCO Pacific Ltd. The contract term provided for 35 years at fair value of € 4.3

billion, of which 79% is guaranteed by future income and additional investment at € 620 million to be

implemented. The Concession Agreement entered into force on 1/10/2009 and till 31/5/2010 the

operation of Pier II was provided by the staff of the Company as a subcontractor. Within this period the

project in Pier I, which was constructed by the Company, was completed and started its operation by

providing services directly to Company’s clients.

The Agreement B. Modification of the original Concession Agreement (OG 52 / 30.03.2009) between the

Company and PCT S.A., following the 'Practical Process Amicable Settlement', has been published in the

Government Gazette 269 / 24.12.2014.

Page 139 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

According to the above, the payment of the guaranteed consideration was suspended until 31.12.2021 and

has been replaced by paying only Variable consideration that arises as a percentage on consolidated

revenues of PCT SA from the previous contract year.

The calculation of fixed consideration I & II is adjusted regarding the length of exploitation and the

corresponding sq.m (Note 24). The concession consideration is calculated and recognized in income for the

period in accordance with the terms of the contract and considered as lease contract based on IFRS 16

(Notes 2c and 3p).

The payment of Variable Consideration is performed on a monthly basis in arrears and the payment of the

standard exchange every six months in advance (Note 24).

(v) Benefits that depend on the value of share and are settled in cash:

The Company in accordance with IFRS 2 measures the services it obtains and the liability it undertakes at

the fair value of the liability. Until the settlement of the liability, the entity shall remeasure the fair value of

the liability at the reporting date as well as at the settlement date, and any changes in fair value are

recognized in profit or loss for the period. The obligation is measured, initially and at each reporting date

until the final settlement, at the fair value of the units on the increase in the share price from the grant

date and the respective redemption date, with the application of a valuation model taking into account the

terms and conditions under which the units have been granted. The fair value of the long-term reward plan

was determined using the Binomial model taking into account the share price, the expected volatility of the

share, the dividend yield as well as the free interest rate (Note 29) and the liability is recognized in other

long-term liabilities.

(w) Foreign Currency Conversion: All the operations of the Company are all performed in Euro. Transactions

made in foreign currencies are converted into Euro using exchange rates effective at transaction date.

Receivable and liabilities in foreign currency are adjusted at the financial statements preparation date in

order to state the exchange rates effective at that date. Gains or losses arising from these adjustments are

included in the Statement of comprehensive income as foreign exchange gains or losses.

Changes in accounting policies and disclosures

The accounting policies adopted in the preparation of the annual financial statements, are consistent with

those followed for the year ended December 31, 2021, except for the adoption of new standards and

interpretations applicable for fiscal periods beginning at January 1, 2022.

New standards, amendments to standards and interpretations: Certain new standards, amendments to

standards and interpretations have been issued that are mandatory for periods beginning on or after January

1, 2022. The Company’s evaluation of the effect of these new standards, amendments to standards and

interpretations is as follows:

Standards and Interpretations effective for the current financial year

IAS 16 Property, Plant and Equipment (Amendments) prohibit a company from deducting from the cost

of property, plant and equipment any proceeds from the sale of items produced while bringing the asset

to the location and condition necessary for it be capable of operating in the manner intended by

management. Instead, a company recognizes such sales proceeds and related cost in profit or loss.

Page 140 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

IAS 37 Provisions, Contingent Liabilities and Contingent Assets (Amendments) specify which costs a

company includes in determining the cost of fulfilling a contract for the purpose of assessing whether a

contract is onerous. The amendments clarify, the costs that relate directly to a contract to provide goods

or services include both incremental costs and an allocation of costs directly related to the contract

activities.

IFRS 3 Business Combinations (Amendments) update a reference in IFRS 3 to the previous version of the

IASB’s Conceptual Framework for Financial Reporting to the current version issued in 2018 without

significantly changing the accounting requirements for business combinations.

Annual Improvements 2018-2020 make minor amendments to IFRS 1 First-time Adoption of

International Financial Reporting Standards, IFRS 9 Financial Instruments and the Illustrative Examples

accompanying IFRS 16 Leases

The amendments had no impact on the financial statements of the Company.

Standards and Interpretations effective for subsequent periods

• IAS 1 Presentation of Financial Statements and IFRS Practice Statement 2: Disclosure of Accounting

policies (Amendments)

The Amendments are effective for annual periods beginning on or after January 1, 2023 with earlier

application permitted. The amendments provide guidance on the application of materiality judgements

to accounting policy disclosures. In particular, the amendments to IAS 1 replace the requirement to

disclose ‘significant’ accounting policies with a requirement to disclose ‘material’ accounting policies.

Also, guidance and illustrative examples are added in the Practice Statement to assist in the application

of the materiality concept when making judgements about accounting policy disclosures.

• IAS 8 Accounting policies, Changes in Accounting Estimates and Errors: Definition of Accounting

Estimates (Amendments)

The amendments become effective for annual reporting periods beginning on or after January 1, 2023

with earlier application permitted and apply to changes in accounting policies and changes in

accounting estimates that occur on or after the start of that period. The amendments introduce a new

definition of accounting estimates, defined as monetary amounts in financial statements that are

subject to measurement uncertainty, if they do not result from a correction of prior period error. Also,

the amendments clarify what changes in accounting estimates are and how these differ from changes

in accounting policies and corrections of errors.

• IAS 12 Income taxes: Deferred Tax related to Assets and Liabilities arising from a Single Transaction

(Amendments)

The amendments are effective for annual periods beginning on or after January 1, 2023 with earlier

application permitted. The amendments narrow the scope of and provide further clarity on the initial

recognition exception under IAS 12 and specify how companies should account for deferred tax related

to assets and liabilities arising from a single transaction, such as leases and decommissioning

obligations. The amendments clarify that where payments that settle a liability are deductible for tax

purposes, it is a matter of judgement, having considered the applicable tax law, whether such

deductions are attributable for tax purposes to the liability or to the related asset component. Under

the amendments, the initial recognition exception does not apply to transactions that, on initial

recognition, give rise to equal taxable and deductible temporary differences. It only applies if the

recognition of a lease asset and lease liability (or decommissioning liability and decommissioning asset

component) give rise to taxable and deductible temporary differences that are not equal.

Page 141 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

• IAS 1 Presentation of Financial Statements: Classification of Liabilities as Current or Non-current

(Amendments)

The amendments are effective for annual reporting periods beginning on or after January 1, 2024, with

earlier application permitted, and will need to be applied retrospectively in accordance with IAS 8. The

objective of the amendments is to clarify the principles in IAS 1 for the classification of liabilities as

either current or non-current. The amendments clarify the meaning of a right to defer settlement, the

requirement for this right to exist at the end of the reporting period, that management intent does not

affect current or non-current classification, that options by the counterparty that could result in

settlement by the transfer of the entity’s own equity instruments do not affect current or non-current

classification. Also, the amendments specify that only covenants with which an entity must comply on or

before the reporting date will affect a liability’s classification. Additional disclosures are also required for

non-current liabilities arising from loan arrangements that are subject to covenants to be complied with

within twelve months after the reporting period. The amendments have not yet been endorsed by the

EU.

• IFRS 16 Leases: Lease Liability in a Sale and Leaseback (amendments)

The amendments are effective for annual reporting periods beginning on or after January 1, 2024, with

earlier application permitted. The amendments are intended to improve the requirements that a seller-

lessee uses in measuring the lease liability arising in a sale and leaseback transaction in IFRS 16, while it

does not change the accounting for leases unrelated to sale and leaseback transactions. In particular,

the seller-lessee determines ‘lease payments’ or ‘revised lease payments’ in such a way that the seller-

lessee would not recognise any amount of the gain or loss that relates to the right of use it retains.

Applying these requirements does not prevent the seller-lessee from recognising, in profit or loss, any

gain or loss relating to the partial or full termination of a lease. A seller-lessee applies the amendment

retrospectively in accordance with IAS 8 to sale and leaseback transactions entered into after the date

of initial application, being the beginning of the annual reporting period in which an entity first applied

IFRS 16. The amendments have not yet been endorsed by the EU.

The Company's Management is in the process of assessing the impact of the standards or the

modification of the standards on its financial condition or performance.

Page 142 από 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

4. PROPERTY, PLANT & EQUIPMENT

Property, plant and equipment are analysed as follows:

Buildings

Machinery &

equipment

Motor vehicles and

floating docks

Furniture, fixtures and

fittings

Advances & Assets

under construction

Total

ACQUISITION COST

Balance January 1, 2021 256,593,195.68 151,882,937.39 44,663,765.52 10,250,241.82 19,558,926.37 482,949,066.78

Additions 338,323.95 434,772.07 210,590.00 236,269.54 37,458,079.50 38,678,035.06

Disposals/ write off - - - (1,986,496.34) - (1,986,496.34)

Transfers 239,484.80 1,194,643.80 - 620,857.54 (2,054,986.14) -

Transfers to intangibles

- - - - (506,489.45) (506,489.45)

Balance December 31, 2021 257,171,004.43 153,512,353.26 44,874,355.52 9,120,872.56 54,455,530.28 519,134,116.05

Additions 319,754.52

214,143.96 110,157.00

370,562.91 26,635,529.59 27,650,147.98

Disposals/ write off - (2,436,510.65) - (227,972.23) - (2,664,482.88)

Other movement - - - - (21,000.00) (21,000.00)

Transfers 11,007,046.00 1,930,621.94 2,924,588.00 1,248,176.15 (17,110,432.09) -

Transfers to intangibles

- - - - (539,571.55) (539,571.55)

Balance December 31, 2022 268,497,804.95 153,220,608.51 47,909,100.52 10,511,639.39 63,420,056.23 543,559,209.60

DEPRECIATION

(96,679,678.51) (95,784,540.08) (11,660,492.50) (7,304,878.19) - (211,429,589.28)

Depreciation (7,902,667.01) (5,957,847.58) (1,505,148.44) (633,330.43) - (15,998,993.46)

Disposals

- - - 1,972,231.50 -

1,972,231.50

Depreciation December 31, 2021

(104,582,345.52) (101,742,387.66) (13,165,640.94) (5,965,977.12) - (225,456,351.24)

Depreciation (Note 28)

(8,134,085.54) (5,797,117.33) (1,544,583.36) (782,647.53) - (16,258,433.76)

Disposals / write off

- 2,345,435.92 - 223,032.99 - 2,568,468.91

(112,716,431.06) (105,194,069.07) (14,710,224.30) (6,525,591.66) - (239,146,316.09)

NET BOOK VALUE

January 1,2021 159,913,517.17 56,098,397.31 33,003,273.02 2,945,363.63 19,558,926.37 271,519,477.50

December 31, 2021 152,588,658.91 51,769,965.60 31,708,714.58 3,154,895.44 54,455,530.28 293,677,764.81

December 31, 2022 155,781,373.89 48,026,539.44 33,198,876.22 3,986,047.73 63,420,056.23 304,412,893.51

Depreciation December 31, 2022

Depreciation January 1, 2021

The Company’s property, plant and equipment are insured with various insurance companies. Insurance

covers compulsory insurance of transport vehicles and machinery up to 30.11.2023 as well as general civil

liability up to 31.10.2023 and employer liability up to 30.09.2023, property insurance up to 16.11.2023 and

floating tanks insurance up to 31.10.2023 .

During the year ended December 31, 2022, the total investment in property, plant and equipment

amounted to € 27,650,147.98 (01.01.2021-31.12.2021 € 38,678,035.06) and related mainly to the purchase

of machinery and other equipment as well as port infrastructure. Fixed assets under construction

amounting to € 63,420,056.23 mainly include projects in progress as part of the Company's mandatory

investments.During the current year, the Company made payments of € 32,695,099.21 (01.01.2021-

31.12.2021 : € 40,647,689.68) to suppliers related to investments in tangible and intangible fixed assets.

Property, plant and equipment are tested for impairment when there are indicators that the carrying

amounts may not be recoverable. During 2022, an impairment test for Container Terminal Segment was

conducted, where the present value exceeds the book value of the tangible fixed assets of the Container

Terminal and therefore as at 31 December 2022, no relevant impairment was recorded (note 2b(i)).

There is no property, plant and equipment that has been pledged as security.

Page 143 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

5. RIGHT OF USE ASSETS – LEASE LIABILITIES

The recognised right-of-use assets and lease liabilities as at December 31, 2022 and December 31, 2021 are

as follows:

31/12/2022 31/12/2021

Right-of-use assets

Concession Agreement with Greek State 56,876,700.24 58,829,548.32

Motor vehicles 409,457.62 400,796.03

57,286,157.86 59,230,344.35

31/12/2022 31/12/2021

Lease-liabilities

Current 1,369,521.49 1,307,885.46

Non-current 62,937,704.62 64,128,097.26

64,307,226.11 65,435,982.72

Regarding the recognized right of use assets from the concession of the Greek State, see accounting

principle (t).

The amounts recognized in the statement of comprehensive income and the movement of the right of use

of assets and the lease liability from 1 January 2022 to 31 December 2022 as well as the corresponding

period last year are as follows:

Concession Agreement

with Greek State

Motor vehicles Total Lease liability

Balance 1.1.2022 58,829,548.32 400,796.03 59,230,344.35 65,435,982.72

Additions - 201,002.62 201,002.62 201,002.62

Cancellation / modification of contracts -

24,237.96 24,237.96 12,061.51

Depreciation (Note 28)

(1,952,848.08) (216,578.99) (2,169,427.07) -

Finance cost (Note 27) - - -

2,393,727.05

Payments - - -

(3,735,547.79)

Balance 31.12.2022 56,876,700.24 409,457.62 57,286,157.86 64,307,226.11

Concession Agreement

with Greek State

Motor vehicles Total Lease liability

Balance 1.1.2021 60,782,396.40 420,993.05 61,203,389.45 66,538,481.42

Additions -

156,455.09 156,455.09 156,455.09

Cancellation / modification of contracts - - - -

Depreciation (Note 28)

(1,952,848.08) (176,652.11) (2,129,500.19) -

Finance cost (Note 27) - - -

2,433,961.29

Payments - - -

(3,692,915.08)

Balance 31.12.2021 58,829,548.32 400,796.03 59,230,344.35 65,435,982.72

Right-of-use assets

Lease expense less than 12 months for 2022 amounted to € 166,734.25 (31.12.2021: € 171,598.90) and is

included in Expenses and specifically in the lines “Payroll and employee related costs” and “Third-party

services” (Note 25).

Page 144 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

6. INVESTMENT PROPERTY

For the year ended December 31, 2022:

Land Buildings Total

Net Book Value at January 1, 2022 734,338.35 0.03 734,338.38

Additions - - -

Depreciation - - -

Net Book Value at December 31, 2022 734,338.35 0.03 734,338.38

December 31, 2022

Cost 734,338.35 0.03 734,338.38

Accumulated Depreciation - - -

Net Book Value 734,338.35 0.03 734,338.38

For the year ended December 31, 2021:

Land Buildings Total

Net Book Value at January 1, 2021 734,338.35 0.03 734,338.38

Additions - - -

Depreciation - - -

Net Book Value at December 31, 2021 734,338.35 0.03 734,338.38

December 31, 2021

Cost 734,338.35 0.03 734,338.38

Accumulated Depreciation - - -

Net Book Value 734,338.35 0.03 734,338.38

Investment property includes seven land plots and four buildings (commercial spaces and schools) located

in Athens and Piraeus.

There is no investment property that has been pledged as security.

The fair value of investment property as at December 31, 2022 amounted to € 5.6 million (December 31,

2021: € 5.6 million) according to the valuation of an independent appraiser. The valuation, as a Level 3

(Note 33) fair value measurement is based on comparative assessment method, residual replacement cost

method and cost approach depending on the particular characteristics of each property.

Income from rent for the above investment property for the year ended December 31, 2022 and December

31, 2021 amounted to € 19,233.93 and € € 19,219.30 respectively and is included in other operating income

(Note 26). For the years ended December 31, 2021 and 2020 there were no repair and maintenance costs

for investment property.

Page 145 από 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

7. INTANGIBLE ASSETS

For the year ended December 31, 2022:

Software

Net Book Value January 1, 2022 1,376,775.69

Additions 74,812.01

Disposals/ write off (597,174.27)

Transfers from assets under construction 539,571.55

Amortisation of the year (Note 28) (777,158.77)

Disposals/ write off 597,173.06

Net Book Value December 31, 2022 1,213,999.27

January 1, 2022

Cost 11,055,081.25

Accumulated amortisation (9,678,305.56)

Net Book Value 1,376,775.69

December 31, 2022

Cost 11,072,290.54

Accumulated amortisation (9,858,291.27)

Net Book Value 1,213,999.27

For the year ended December 31, 2021:

Software

Net Book Value January 1, 2021 1,409,534.21

Additions 88,455.80

Transfers from assets under construction

(Note 4)

506,489.45

Amortisation of the year (Note 28) (627,703.77)

Net Book Value December 31, 2021 1,376,775.69

January 1, 2021

Cost 10,460,136.00

Accumulated amortisation (9,050,601.79)

Net Book Value 1,409,534.21

December 31, 2021

Cost 11,055,081.25

Accumulated amortisation (9,678,305.56)

Net Book Value 1,376,775.69

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

8. OTHER NON-CURRENT ASSETS

This account consists of the following:

31/12/2022 31/12/2021

Guarantees to third parties 321,871.75 323,407.75

Car leases guarantees 85,802.56 77,605.00

Advances to suppliers

10,515,250.02

5,796,696.77

Total 10,922,924.33 6,197,709.52

The item "Advances to suppliers" refers to the unamortized balance of advance payments that have been given

to suppliers for the construction of investment projects of significant value, which advance payments are

reduced by the amount of the 5% withholding on the issued invoices related to the execution of their work, in

accordance with the signed contracts . The item is analyzed as follows:

• Project " Expansion of the cruise Passenger Port"

During 2020, an advance payment of € 5,147,718.36 was given to a supplier for the commencement of work for

the project. On 31 December 2020, the amount of withholding amounted to € 394,632.51 and the respective

receivable amounted to € 4,753,085.85. As of December 31, 2021, the amount of withheld on the issued invoices,

amounted to € 840,996.55 and the balance of the receivable amounted to € 3,912,089.30.

In the current year an amount of € 134,593.03 was withheld on the value of the invoices issued and an additional

advance payment amounted to € 4,771,785.90 was given related to additional future works of the project and

the balance of the receivable amounted to € 3,777,496.27.

• Project " Improvement of Infrastructure of the Ship Repair Zone"

During 2021, an advance payment of € 941,444.13 was given to a supplier for the commencement of work for the

project. On 31 December 2021 the amount of withholding amounted to € 18,212.91 and the respective receivable

amounted to €923,231.22. In the current year an amount of € 30,149.32 was withheld on the value of the

invoices issued and the balance of the receivable amounted to € 893,081.90.

• Project “Expansion of the Car Terminal (Hrakleous Port) "

During 2021, an advance payment of € 990,524.42 was given to a supplier for the commencement of work for the

project. On 31 December 2021 the amount of withholding amounted to € 29,148.17 and the respective receivable

amounted to €961,376.25. In the current year an amount of € 444,443.87 was withheld on the value of the

invoices issued and the balance of the receivable amounted to € 516,932.38.

• Project “Underground road connection of Car Terminal with ex-ODDY "

In addition, during the current year an advance payment of € 320,815.00 was given to a supplier for the

commencement of work for the project. On 31 December 2022 the amount of withholding amounted to €

71,277.66 while the respective receivable amounted to € 249,537.34.

• Project “Dredging of port”

During the current year, an advance payment of € 306,416.23 was given to a supplier for the commencement of

work for the project.

Page 147 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

9. INCOME TAX (CURRENT AND DEFERRED)

With Law 4799/2021 the income tax rate amounded to 22% for the financial income of the fiscal year 2021 and

afterward.

The amount of income taxes which are reflected in the statements of comprehensive income are as follows:

Statement of comprehensive income 1/1-31/12/2022 1/1-31/12/2021

Current income taxes 12,401,346.00 11,464,004.35

Tax audit differences financial year 2016 6,345,212.94 -

Deferred income taxes 3,031,673.29 985,279.49

Total 21,778,232.23 12,449,283.84

Other Comprehensive Income

Deferred income taxes 321,382.21 (7,533.99)

Total 321,382.21 (7,533.99)

The payments made for the income tax liability of the current and prior year amounted to € 10,863,233.60 and

€ 5,228,338.35, respectively.

The reconciliation of income taxes reflected in statements of income and the amount of income taxes determined

by the application of the Greek statutory tax rate to pretax income is summarized as follows:

2022 2021

Profit pre-tax income 74,664,659.74 49,210,993.70

Income tax calculated at the nominal applicable tax rate in effect (2022 and

2021: 22%)

16,426,225.14 10,826,418.61

Reversal of temporary differences for which no deferred tax was recognised

(3,120,586.39) 615,064.63

Tax effect of non-taxable income and expenses not deductible for tax purposes

2,127,380.54 449,386.78

Tax differences from tax audit 2016

6,345,212.94 -

Change in tax rates

- 558,413.82

Income tax reported in the statements of comprehensive income

21,778,232.23 12,449,283.84

December 31

Greek tax laws and regulations are subject to interpretations by the tax authorities. Tax returns are filed annually

but the profits or losses declared for tax purposes remain provisional until such time, as the tax authorities

examine the returns and the records of the taxpayer and a final assessment is issued. Tax losses, to the extent

accepted by the tax authorities, can be used to offset profits of the five fiscal years following the fiscal year to

which they relate.

Page 148 από 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Tax Compliance certificate:

From the financial year 2011 and onwards, all Greek Societe Anonyme and Limited Liability Companies that are

required to prepare audited statutory financial statements must in addition obtain an “Annual Tax Certificate” as

provided by Article 65Α of L.4174/2013. This “Annual Tax Certificate” must be issued by the same statutory

auditor or audit firm that issues the audit opinion on the statutory financial statements. For tax years

commencing from 1/1/2016 onwards, the tax compliance report becomes optional according to the provisions of

Law 4410/2016. Upon completion of the tax audit, the statutory auditor or audit firm must issue to the entity a

"Tax Compliance Report" which will subsequently be submitted electronically to the Ministry of Finance, by the

statutory auditor or audit firm.

For the Company, the tax audit for the financial years 2011 to 2021 was performed by the statutory auditors. The

tax audit for the current financial year is in progress by the Company’s statutory auditors. The tax certificate will

be granted after the publication of the Financial Statements.

The movement of the deferred tax asset is as follows:

31/12/2022 31/12/2021

Opening balance 6,945,886.23 7,923,631.73

Income taxes (debit) (3,031,673.29) (985,279.49)

Income taxes credit – Other Comprehensive Income

(321,382.21) 7,533.99

Closing balance

3,592,830.73 6,945,886.23

The movement of deferred tax assets/liabilities as at December 31, 2022 and 2021 is as follows:

31/12/2022 31/12/2021 31/12/2022 31/12/2021 31/12/2022 31/12/2021

Deferred tax assets:

Investment property

144,810.10 144,810.10 - - - (13,164.56)

Provisions (Doubtful receivables, Legal cases, Staff retirement indemnities)

5,339,697.40 8,389,510.89 (321,382.21) 7,533.99 (2,728,431.28) (43,441.94)

Accrued expenses

107,049.65 107,049.65 - - - (9,731.78)

Finance lease (IFRS 16)

1,544,635.01 1,365,240.44 - - 179,394.57 84,818.37

Cash settled share based payments

250,708.23 209,459.75 - - 41,248.48 49,213.84

Other

794,165.61 748,242.11 - - 45,923.50 (116,683.67)

Deferred tax asset

8,181,066.00 10,964,312.94 (321,382.21) 7,533.99 (2,461,864.73) (48,989.73)

Deferred tax liabilities:

Depreciation based on useful life

(4,546,452.91) (3,974,745.15) - - (571,707.76) (942,332.66)

Accrued income

(41,782.36) (43,681.56) - - 1,899.20 6,042.90

Deferred tax liability

(4,588,235.27) (4,018,426.71) - - (569,808.56) (936,289.76)

Deferred tax asset

3,592,830.73 6,945,886.23

Deferred tax recognized in the statement of comprehensive income

(321,382.21) 7,533.99 (3,031,673.29) (985,279.49)

Statement of financial position

Statement of comprehensive

Other comprehensive

Page 149 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The deferred tax asset balance from provisions includes the relevant deferred tax on the provision on doubtful

receivables which has been established mainly in previous years (before 2016) when the Company was operating

under specific legislation Law 1559/1950 and Law 2688/1999. The Company believed that they had taken the

ultimate possible measure for collecting a long outstanding receivable balance, part of which has been assigned

to tax authority for collection. Until previous year, the Company for the doubtful receivable balances which has

been assigned to tax authority for collection had calculated deferred tax asset amounted to € 2.6 million making

use of the tax benefit and considering that had taken the ultimate possible measure required by the tax

legislation. That intention was declared in a notice letter to the Ministry of Finance.

After resetting the request to Tax Authorities (AADE) on January 20, 2022, the Company received the protocol no.

ΔΕΑΦ B 1053370/17.6.2022 response letter from Tax Authorities (AADE) according to which:

"the Company can record a provision for doubtful debts in accordance with the provisions of paragraph 1 of

article 26 of the Tax Law for the amount of receivables that maintains from the period during which it operated as

a legal entity under public law and later as Société Anonyme public company, the collection of which was

entrusted to the Tax Authorities according to a ministerial decision, as long as this action is considered appropriate

to ensure the right to collect the related claims. For the write-off of the bad debts under review based on par. 4 of

no. 26 of the Tax Law, the transfer debt collection to Tax Authorities is not considered fulfiling the pre-condition iii

of paragraph a' of paragraph 4 of no. 26 of the KFE, since these debts cannot be characterized as uncollectible

according to article 82 K.E.D.E. as well as the responsible authorities continue to pursue the collection of these by

taking necessarily and other collection measures in accordance with the provisions of the K.E.D.E, as well as

ensuring the interruption of their statute of limitations."

The management of the Company, interpreting the above response of the AADE, and following the confirmation

of its main claims that had been assigned for collection by the competent DOU, proceeded during the current

fiscal year to form a tax provision for bad debts amounting to € 24.6 million and correspondingly de-recognized

the amount of the deferred receivable that it had recorded during the previous years.

The unaudited fiscal years of the Company are the years ended on December 31, 2017 up to December 31, 2022.

The Company’s management expects that no material taxes and fines will be raised.

With No.444 and No.445 of October 6, 2021 orders from the General Directorate of Tax Administration (Audit

Authority Center for Large Enterprises) was notified to the Company a tax audit for the period 1/1/2020-

31/7/2021 and 1/1/2016-31/12/2019, respectively.

On December 29, 2022, the final deed of corrective determination/imposition of income tax fine for the tax year

1/1/2016-31/12/2016 was communicated to the Company, resulting in additional income tax and fines

amounting to € 6,345,212.94 and € 3,172,606.47 respectively (Note 26). Furthermore, additional increments of €

3,057,123.59 were imposed (Note 26). The Company, disputing the above final deed of corrective

determination/imposition of an income tax fine, proceeded to appeal against the entire definitive act of the

General Directorate of Tax Administration (Note 34). On January 2023 the additional income tax and fines as well

as the additional increments were paid.

For the pending tax audits based on the above audit orders for the period 1/1/2017-31/7/2021, they may result in

the imposition of additional taxes and fines, the amount of which, according to the assessment of the Company's

management, is not expected to be important.

Page 150 από 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

10. INVENTORIES

Inventories are analysed as follows:

31/12/2022 31/12/2021

Consumable materials

498,977.12 441,426.91

Spare parts and equipment

3,023,968.90 2,891,118.54

Total 3,522,946.02 3,332,545.45

Inventory consumption cost for the year ended December 31, 2022 and 2021 amounted to € 2,378,374.54 and €

2,820,801.67 respectively (Note 25). Consumables include an amount of € 0 (31.12.2021: € 65,239.12) related to

write off of obsolete tools.

There was no inventory devaluation to their net realisable value.

11. TRADE AND OTHER RECEIVABLES

This account is analysed as follows:

31/12/2022 31/12/2021

Trade Debtors

54,210,929.56 51,782,819.58

Minus: Provision for doubtful debts

(41,222,818.71) (40,830,048.47)

Total trade receivables

12,988,110.85 10,952,771.11

Personnel loans

438,893.09 391,994.51

Advances to suppliers

640,872.18 1,592,594.35

Other receivable

2,283,908.71 2,080,663.58

Grant receivable

4,239,203.86 5,334,495.75

Minus: Provision for other receivables and advances

to suppliers

(2,204,043.54) (2,204,043.54)

Total other receivables

5,398,834.30 7,195,704.65

Total trade and other receivables

18,386,945.15 18,148,475.76

Personnel loans: The Company provides interest-free loans to its personnel. The loan amount per employee does

not exceed approximately € 3,000.00 and loan repayments are made by withholding monthly instalments from

the employee salaries.

Other receivable: Other receivable include the compulsory seizure of Piraeus municipality amounted to

€ 238,838.62 (2021: € 238,838.62), as well as receivable from third parties and municipality of Drapetsona

amounted to € 2,045,070.09 (2021: € 1,841,824.96). For the claim of the Municipality of Drapetsona, a provision

amounted to € € 1,740,149.52 has been recorded.

Grant receivable: The grant receivable for the current and previous year concerns the outstanding balance from

the Attica Regional Fund of the approved grant for the project "Expansion of the Passenger Port for cruise ship

”(Note 16).

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The movement of the allowance for doubtful trade receivables is analysed as follows:

31/12/2022 31/12/2021

Beginning balance 40,830,048.47 39,885,944.27

Provision for the year 392,770.24 1,220,277.88

Provision used - (276,173.68)

Ending balance 41,222,818.71 40,830,048.47

The provision used in the previous year of € 276,173.68 relates to the write-off of customers’ debt

based on a decision of the Board of Directors and for which a provision for doubtful debts had been

made in previous years.

Trade receivables are normally settled on 10 days’ terms. A single customer (Piraeus Container

Terminal S.A.) represents 46% of the Company’s total revenue (2021:51 %). The outstanding amount

of this customer as at December 31, 2022 amounted to € 4.9 million (2021: € 2.6 million ) (Note 32).

For trade receivables and other receivables, the Company has calculated estimated credit losses (ECLs)

based on lifetime expected credit losses. Taking into consideration that trade receivables are normally

settled within 10 days from the issuance of the invoice, the risk of default and the expected loss rate of

0.5% has been determined by management whereas for all balances that are outstanding for less than

10 days (no overdue balances). Regarding the outstanding balances above 10 days, the Company has

considered the risk of default, the days past due and the historical credit losses experienced adjusted

to reflect current and forward-looking information per debtor to measure the expected credit losses

for each individual trade receivable balance.

The Company is actively monitoring the recoverability of trade receivables and ensures that the loss

allowance recorded reflects, on a timely basis management’s best estimate of potential losses in

compliance with IFRS 9

The ageing analysis of trade receivables (net of ECLs) is as follows:

2022 2021

Not overdue 10,288,740.02 7,557,250.75

10-90 days 332,007.45 445,897.96

91-180 days 150,662.34 208,328.53

181-365 days 171,030.27 280,218.29

>365 days 2,045,670.77 2,461,075.59

Total 12,988,110.85 10,952,771.11

December 31,

The ageing analysis of receivables past due more than 365 days applies to claims for which the

Company has filed appeals or taken actions for their collectability. Management and Legal Department

estimate that the final court decisions and the other actions will be in favour of the Company .

Page 152 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The movement of the allowance for doubtful other receivables and advances to suppliers is analysed

as follows:

31/12/2022 31/12/2021

Beginning balance 2,204,043.54 2,542,219.54

Provision for the year - -

Reversal of provision

(338,176.00)

Ending balance 2,204,043.54 2,204,043.54

The net impairment losses on financial assets are analysed as follows:

31/12/2022 31/12/2021

392,770.24 1,220,277.88

- (338,176.00)

392,770.24 882,101.88

Movement in loss allowance for trade receivables

Impairment losses

Reversal of provision

12. PREPAID EXPENSES

Prepaid expenses of current year mainly includes an advance payment of the commission for the

guarantee of the existing loans amounting to € 792,567.00 (31.12.2021: € 457,619.66) as well as an

advance payment to the insurance company about the property and civil liability amounting to €

623,565.24 (31.12.2021: € 620,448.88).

13. CASH AND CASH EQUIVALENTS

Cash and cash equivalents are analyzed as follows:

31/12/2022 31/12/2021

Cash in hand 35,954.43 28,994.51

Cash at banks 171,499,388.79 134,946,291.22

Total 171,535,343.22 134,975,285.73

Restricted cash - 213,267.48

Total 171,535,343.22 135,188,553.21

Cash at banks earns interest at floating rates based on monthly bank deposit rates. Interest earned on

cash at banks and time deposits is accounted for on an accrual basis and for the year ended December

31, 2022, amounted to € 4,228.30 (31.12.2021: € 9,790.90 ).These amounts are included in the

financial income (Note 27).

The restricted cash of the previous period amounted to € 213,267.48 related to Company’s freezed

deposits, in favor of a municipality against which there were pending trials.

Page 153 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

14. SHARE CAPITAL

Share capital amounts to € 50,000,000.00 is fully paid up and consists of 25,000,000 ordinary shares, of

nominal value € 2.00 each. There are neither shares which do not represent Company’s capital nor

bond acquisition rights.

15. RESERVES

Reserves are analysed as follows:

31/12/2022 31/12/2021

Statutory reserve 16,666,666.67 15,934,306.58

Special tax free reserve L. 2881/2001 61,282,225.52 61,282,225.52

Specially taxed income reserve 728,128.36 728,128.36

Taxed reserve L. 4172/2013 art. 72 6,087,915.56 6,087,915.56

Taxed reserve based on general provisions 188,760.09 188,760.09

Total 84,953,696.20 84,221,336.11

Statutory reserve: Under the provisions of Greek corporate Law, companies are obliged to transfer at

least 5% of their annual net profit, as defined, to a statutory reserve, until the reserve equals the 1/3

of the issued share capital. In the current year the Company covers the amount required by the law.

The reserve is not available for distribution throughout the Company activity.

Special tax free reserve Law 2881/2001: This reserve which is exempt from taxation, was created

during the conversion of the Company to a Societé Anonyme. The total Company’s net shareholder

funds (Equity) was valued, by the article 9 Committee of the Codified Law 2190/1920, at €

111,282,225.52, € 50,000,000.00 out of which was decided by Law 2881/2001 to form the Company

share capital and the remaining € 61,282,225.52 to form this special reserve. The above Special Tax-

Free Reserve is taxed under the conditions and to the extent provided for in the general provisions, i.e.

in the event of its distribution or capitalization.

Untaxed or specially taxed income reserve: This is interest income which was either not taxed or

taxed by withholding 15% tax at source. In case these reserves are distributed, they are subject to tax

on the general income tax provision basis. Based on Article 72 par.11 of Law 4172/2013 those reserves

are subject (from 1 January 2014) to an independent taxation at a rate of 19%. On December 30

2014, the Company proceeded to the taxation of those reserves which amounted to € 1,428,029.58.

After the tax deduction created the taxed reserves of Article 72 N.4172 / 2013 and the taxed reserve

with the general provisions amounting to € 6,087,915.56 and € 188,760.09 respectively.

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(amounts in Euro unless stated otherwise)

16. GOVERNMENT GRANTS

The movement of the account is analyzed as follows:

31/12/2022 31/12/2021

Opening 51,912,350.22 38,242,578.05

Approved grant in current year - 13,669,772.17

Closing 51,912,350.22 51,912,350.22

Accumulated amortization (14,503,811.62) (13,639,086.70)

Net Book Value 37,408,538.60 38,273,263.52

Grants received up to December 31, 2011 relate to the requirements of the Olympic Games of 2004 (€

11,400,000.00) and on the construction of infrastructure for the OSE S.A. port station (€ 3,700,000.00).

Also, a grant of € 3,653,518.80 has been received in 2012 and is divided in a) € 2,536,168.80, which relates to

the widening of the quay Port Alon and b) € 1,117,350.00 for the construction of new dock at the area of Agios

Nikolaos in the central port of Piraeus, under the operational program “Improvement of accessibility-energy”

of the Attica region. Finally, a grant amounted to € 9,901,740.45 has been received in December 2013 and

relates to the operational program “Support Accessibility” of the Ministry of Infrastructure, Transport and

Network and in particular, in two projects which have been completed. According to a decision of Attica

Region issued during 2017, it was decided to return the amount of € 13,735.39 for the correction of the

subsidy for the project "Widening of the quay Port Alon".

Moreover, according to a decision of Attica Region issued during 2018, it was decided to return the amount of

€ 546,750.77 for the correction of the subsidy for the project “Construction of new dock of Ag. Nikolaos”.

During the previous year, the Attica Regional Fund approved a grant of € 10,147,804.96 for the project

"Expansion of the Passenger Port for the service of the cruise" and the amount of € 6,766,044.97 was

collected. The above amount concerned two payment orders for the project of the expansion of the

Themistocleous pier and the construction of a new Pier on the south side of the central port, with a total

approved amount of € 97,720,853.49 from the ATPIC WPP (NSRF 2013 - 2020) according to the decision

Α.Π.403 / 11-2-2020.

During the previous year, a grant of € 13,669,772.17 was approved by the Attica Regional Fund for the project

"Expansion of the Passenger Port for the service of the cruise", which is under execution. As at December 31,

2022 the amount of approved grant of € 4,239,203.86 (Note 11) is pending (31.12.2021: € € 5,334,495.75),

while in the current year the amount of € 1,095,291.89 was received (31.12.2021: € 11,717,036.41).

Grants are considered as future revenue and are recognized in revenue at the same rate at which the

subsidized assets are depreciated (note 28) . Grants related to assets under execution are not amortized until

the fixed asset is completed and available for its intended productive operation.

There are no other obligations regarding the received grants.

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(amounts in Euro unless stated otherwise)

17. RESERVE FOR STAFF LEAVING INDEMNITIES

The relevant provision movement for the financial year ended on December 31, 2022 and the financial

year ended on December 31, 2021 is as follows:

Liability in Statement of Financial Position 1.1.2021 10,513,663.70

Current cost of employment 1,742,514.20

Interest cost on liability 78,852.47

Actuarial (gain)/loss liability due to financial assumptions 83,167.96

Actuarial (gain)/loss on liability due to experience (48,922.53)

Benefits paid (2,162,000.00)

Liability in Statement of Financial Position 31.12.2021 10,207,275.80

Current cost of Employment 1,383,460.45

Interest cost on liability 61,243.65

Actuarial (gain)/loss liability due to financial assumptions (1,443,514.96)

Actuarial (gain)/loss on liability due to experience (17,313.25)

Cost of arrangements, cuts and special cases 132,126.71

Benefits paid (339,700.00)

Liability in Statement of Financial Position 31.12.2022 9,983,578.40

According to the Collective Agreement Port Workers (dated 1/7/2022) an employee who fulfills

retirement conditions, leaving the Company, is entitled to a retirement allowance of € 34,000.

According to the Collective Agreement, employees of PPA SA (effective from 1/11/2020, article 8),

employee who fulfills retirement conditions, leaving the Company, is entitled to a retirement allowance of

€ 34,000.

According to the Collective Agreement of Supervisors / Planners of PPA SA (effective from 1/4/2022,

article 8,) an employee who fulfills retirement conditions, leaving the Company is entitled to receive a

retirement allowance of € 34,000.

The principal actuarial assumptions used are as follows:

2022 2021

Discount Rate 3.53% 0.60%

Salaries increase 0.00% 0.00%

Average annual growth rate of long-term inflation 2.20% 1.80%

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(amounts in Euro unless stated otherwise)

A quantitative sensitivity analysis for significant assumption as at December 31, 2022 and December 31,

2021 is as shown below:

2022

0.50% 0.50%

increase decrease

Impact on defined benefit obligation (215,407.40) 223,708.60

2021

0.50% 0.50%

increase decrease

Impact on defined benefit obligation (273,202.80) 284,965.20

579,923.20

Future increase in salaries

Discount rate

Sensitivity Level

Discount rate

Sensitivity Level

1.00%

increase

468,014.60

1.00%

increase

The expected cash flows in the future years are analyzed as follows:

2022 2021

Within the next 12 months (next annual reporting period)

1,924,664.00 1,382,105.00

Between 2 and 5 years 6,791,084.00 5,221,132.00

Between 5 and 10 years 7,214,685.00 8,398,595.00

Beyond 10 years 12,187,928.00 12,348,043.00

Total expected payments 28,118,361.00 27,349,875.00

The average duration of the defined benefit plan obligation at the end of the year is 4,7 years (2021:5,50

years).

18. PROVISIONS

The Company has made provisions for various pending legal cases as at December 31, 2022 amounting to

€ 19,061,195.53,(2021: € 21,005,319.88)relating mainly to claims from personnel and other third parties.

The movement of the provision for legal claims by third parties is as follows:

31/12/2022 31/12/2021

Opening balance 21,005,319.88 16,728,405.67

Charge of the year (Note 25) 188,089.97 4,389,258.57

Provision used (173,544.94) (87,925.94)

Reversal of provision (Note 25) (1,958,669.38) (24,418.42)

Closing balance 19,061,195.53 21,005,319.88

The current’s year provision relates to legal cases of employees, Greek State and other third parties

amounting to € 164,780.97, € 6,000.00 and € 17,309.00 respectively (31.12.2021: € 1,734,308.57,

€ 2,000,000.00 and € 654,950.00 respectively) .The reversal of the provision relates to legal cases which

have been reassessed by the Company’s legal department based on current developments or finalized in

favor of the Company. The provision used relates to legal cases which have been finalised against the

Company and a related provision has been made in prior years.

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(amounts in Euro unless stated otherwise)

19. LONG-TERM & SHORT TERM BORROWINGS

a) Long-term borrowings:

The long term portion of borrowings as at December 31, 2022 and December 31, 2021 respectively is as

follows:

31/12/2022 31/12/2021

Total of Long term borrowings

38,499,999.99 44,499,999.99

Minus:

Short term portion of Long term borrowings

Long term portion 32,499,999.99 38,499,999.99

6,000,000.00

Balance included in the following loans between the Company and the European Investment Bank:

1. Loan of € 35,000,000.00 for the construction of Container Terminal Pier I, issued on 30/7/2008.

The repayment of the loan will be in thirty (30) semi-annual installments, payable from December 15, 2013

up to and including June 15, 2028. As amended in October 2, 2017 the loan bears an annual interest rate,

that is the sum of a fixed interest rate and a margin of 0.25% which is payable quarterly.

From this contract there are obligations and restrictions for the Company, the most important of which are

summarized as follows: (i) to submit the annual financial statements within 1 month of publication along

with a Certificate of Compliance audited by a recognized firm of certified auditors, and (ii) to hold throughout

the duration of the loan and until fully repaid, the following financial ratios, calculated on annual financial

statements, audited by certified auditors, for each financial year:

1. EBITDA [Profit / (loss) before interest, taxes, depreciation and amortization] / Interest ≥ 3.00

2. Total gross bank debt / EBITDA [Profit / (loss) before interest, tax, depreciation, amortization]

≤ 9.80

3. Total shareholders' equity ≥ 140 million

As at 31 December 2022 the Company was in compliance with the above financial ratios.

The balance of the loan as at 31 December 2022 amounted to € 12,833,333.27 (31.12.2021: € 15,166,666.61).

2. Loan of € 55,000,000.00 for the construction of Container Terminal Pier I issued on the 10/02/2010.

The repayment of the loan will be in thirty (30) semi-annual installments, payable from 15 June 2015 up to

and including 15 December 2029. As amended in October 2, 2017 the loan bears an annual interest rate, that

is the sum of a floating EURIBOR interest rate and a margin of 0.25% which is payable quarterly.

The balance of the loan as at 31 December 2022 amounted to € 25,666,666.72 (31.12.2021: €

29,333,333.38).

From this contract there are obligations and restrictions for the company, the most important of which are

summarized as follows: (i) to submit the annual financial statements within 1 month of publication along

with a Certificate of Compliance audited by a recognized firm of certified auditors, and (ii) to hold throughout

the duration of the loan and until fully repaid, the following financial ratios, calculated on annual financial

statements, audited by certified auditors, for each financial year:

1. EBITDA [Earnings before interest, taxes, depreciation and amortization] / Interest ≥ 3.00

2. Total gross bank debt / EBITDA [Earnings before interest, taxes, depreciation, amortization]

≤ 9.80

3. Current assets / current liabilities ≥ 1.2

4. Total shareholders' equity ≥ 140 million.

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

As at 31 December 2022 the Company was in compliance with the above financial ratios.

On September 26, 2017 a Guarantee Issuance Facility Agreement was signed between the Company and the

‘’Export Import Bank of China’’, in respect of the issuance of guarantees of an initial amount of €

75,074,999.99 to support the loans from the European Investment Bank outstanding debt. The amount of

guarantee is variable and is based on an amortization table linked to the total outstanding balance of both

loans agreements. The guarantee bears an issuance fee of zero point six per cent (0.6%) of the relevant

maximum guarantee amount. This fee paid for the year ended December 31, 2022 amounted to €

457,619.66 (31 December 2021 € 457,619.66), which is reduced by € 792,567.66 due to a corrective fee

amount for the years 2016 until 2022 and its difference is included (decreasing) in financial expenses (Note

27).

For the year ended December 31, 2022 and 2021, total interest expense on long-term borrowings, amounted

to € 281,734.83 and € 70,743.39 respectively and is also included in financial expenses (Note 27).

On November 8, 2019 a loan agreement of € 100,000,000.00 was signed between PPA S.A. and the European

Investment Bank. The purpose of the loan is to finance the projects relating to the expansion and upgrading

of many areas of Piraeus Port, such as the extension of the car terminal, improving the infrastructure of the

ship repair zone, the development of a new Iogistics Port Center, the construction of a new cruise service

facility, the acquisition of new container terminal equipment and the renovation-upgrading of other port and

electromechanical installations. Guarantor of P.P.A. regarding the loan is the Export-Import Bank of China

(based on contract 14/11/2019) and a letter of guarantee € 105 million will be issued upon the draw down

of the loan. As at December 31, 2022 and 2021 the Company has not drawn down any amount.

b) Short-term borrowings:

The Company has a credit line available for € 50,000,000.00 with National Bank of Greece valid until

December 31, 2023. The credit line bears annual variable interest rates of Euribor, plus margin 2.90%. The

Company has not utilised any amount under the overdraft agreement.

20. DIVIDENDS

Dividends related to fiscal year 2021, paid in 2022: The Annual General Meeting of the Company, which

took place on July 13, 2022, approved the proposal of the Board of Directors proposed for the distribution of

dividend for the fiscal year 2021 amounted to € 15,700,000.00 or € 0.6280 per share. The dividend is subject

to withholding tax at the corresponding rate provided by income tax. The dividend for the fiscal year 2021

was paid on July 29, 2022.

Dividends proposed for the fiscal year 2022: On March 17, 2023 the Board of Directors proposed for the

fiscal year 2022 a dividend distribution amounting to € 26,000,000.00 or € 1.040 per share. The final

authorization is subject to the approval by the Annual General Assembly.

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(amounts in Euro unless stated otherwise)

21. ACCRUED AND OTHER CURRENT LIABILITIES

This account is analyzed as follows:

31/12/2022 31/12/2021

Taxes payable (except Income taxes) 5,113,883.51 3,333,511.76

National insurance and other contribution 2,419,185.39 2,225,157.43

Salaries Payable 1,126,128.31 882,015.42

Concession Agreement Liability 3,502,213.43 2,062,798.16

Other creditors 2,375,986.28 2,811,941.36

Other Short Term Obligations 1,278,206.76 871,325.32

Regulatory Authority for Ports 600,432.86 477,130.41

Greek State committed dividends 804,000.00 804,000.00

Customers’ payment in advance 6,024,742.77 5,847,083.54

Accrued expenses 9,370,617.45 2,900,005.38

Total 32,615,396.76 22,214,968.78

Taxes Payable: Current period’s amount consists of: a) Value Added Tax € 3,480,771.20 (31.12.2021: €

1,685,968.50 b) Employee withheld income tax € 1,366,739.03 (2021 € 1,290,539.49) and c) other third party

taxes € 266,373.28 (2021: € 357,003.77).

Concession Agreement Liability: The liability relates to the variable amount of annual fee with an equal

debit in the expense account “Concession agreement fee” (Note 25) and excludes the fixed minimum annual

fee for the current period of € 3,500,000.00. Regardless of the application of IFRS 16, the Company's

contractual obligation to pay to the Greek State as at 31 December 2022 amounted to € 7,002,213.43 (31

December 2021: € 5,562,798.16) and was calculated as a percentage of 3.5% on the total revenue of the

current year excluding financial income.

Payment in advance: The Company receives payments in advance for services rendered on an ordinary

basis, which are then settled on a regular basis. Customer payments in advance amounted to € 6,024,742.77

(31.12.2021: € 5,847,083.54).

Accrued expenses: The accrued expenses of the current year mainly include the fines and surcharges of the

tax audit of the year 2016 amounting to € 6,229,730.06.

22. DEFERRED INCOME

a) On April 27, 2009 “PCT S.A.” paid € 50,000,000.00 as a one-off consideration for the use of port facilities of

Piers II and III of SEMPO of PPA (N.3755/2009). From the aforementioned amount, € 2,930,211.41 was offset

with the cost of supplies and parts provided by PCT S.A., while the remaining amount of € 47,069,788.59 is

amortized over the concession period. On August 2009, PPA S.A received from PCT S.A. three letters of

guarantee amounted to € 61.4 million, € 21.0 million and € 42.0 million respectively for the concession

agreement, the upgrade of PIER II and the construction of PIER IIΙ respectively. The letter of guarantee of €

21.0 million has been expired and returned in 2013. On September 2016, the last letter of guarantee of €

42.0 million, was reduced by 50% to € 21.0 million, upon completion of the project construction of the

eastern side of PIER III. The letter of guarantee of € 61.4 million from China Development Bank was replaced

with an equal letter of guarantee of COSCO SHIPPING Port Ltd. and came into effect on 26.8.2019. In

addition, the Company has received from PCT S.A. letter of guarantee for the construction of the petroleum

pier of € 950,000.00, which was reduced by 50% to € 475,000.00. On December 29, 2020, the letter of

guarantee from PCT S.A with the amount of € 42.0 million (which had been reduced by 50% to 21.0 million)

and the letter of guarantee with the amount € 475,000.00 were returned. On the same date the Company

received a letter of guarantee of € 663,000.00 regarding the rest of the construction of the west side of Pier

III . This letter of guarantee expired on December 29, 2022.

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The initial concession period was thirty (30) years, which was increased to thirty five (35) years, after the

completion the construction of the port infrastructure on the east side of Pier III.

Following the transfer of the cumulative amount € 17,819,277.16 on revenue of the years 2009 until 2022

the new balance at December 31, 2022 amounted to € 29,250,511.43 (December 31, 2021: € 30,595,362.59).

b) The Company receives Fixed Annual Consideration from PCT S.A based on the length and surface of the land

under concession. Fixed Annual Considerations is invoiced in advance in April and October of each fiscal year.

As a result the company has recognized as deferred revenue of € 3,290,861.90 and € 3,160,771.94 as at

December 31, 2022 and December 31, 2021 respectively.

Balance December 31, 2020

35,039,563.55

Less: Amortization of the year – Initial concession (1,344,851.10)

(3,099,349.84)

Plus: Deferred Fixed Annual Consideration for the period 1.1.2022-31.3.2022

3,160,771.97

Balance December 31, 2021

33,756,134.58

Less: Amortization of the year – Initial concession (1,344,851.16)

(3,160,771.94)

Plus: Deferred Fixed Annual Consideration for the period 1.1.2023-31.3.2023

3,290,861.90

Balance December 31, 2022

32,541,373.38

Less: Deferred Fixed Annual Consideration for the period 1.1.2021-31.3.2021 realized

Less: Deferred Fixed Annual Consideration for the period 1.1.2022-31.3.2022 realized

c) Additionally as at December 31, 2022, deferred income includes an amount of € 129,395.68 (31.12.2021:

€ 256,249.26) which relates to the deferred income from rentals.

An amount of € 4,761,872.33 concerning the 2021 fiscal year is presented in short-term liabilities in order to

be comparable with the current fiscal year.

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(amounts in Euro unless stated otherwise)

23. SEGMENT INFORMATION

The Company operates in Greece, regardless of the fact that its clientele includes international companies.

Additionally, the Company has no other commercial or industrial activities other than the provision of

services solely in the Port area and does not have income or assets from foreign customers (based on the

geographical area in which they operate).

The port of Piraeus is a port complex activity, putting work in many areas of port activity, such as containers

Car-terminal, shipping, cruise, Ro-Ro, ship repairing, environmental and logistics services.

It is the main port of coastal connecting mainland Greece and the islands, the main cruise port service in the

country, the main port container, the main car – terminal port of the country.

PPA S.A. provides all the requested port services: water, fuel oil, solid and liquid slot tankers, jack residual oil,

electricity, fiber optics and internet, victuals, repairs, environmental services and is fully connected to all

activities with modern computer systems.

The management of PPA S.A. monitors at the level of results of the above activities and takes business

decisions based on the implemented internal management information system.

Based on the above and in accordance with the provisions of IFRS 8, the Company has determined to disclose

the following segments:

• Container Terminal

• Car Terminal

• Coasting

• Cruise

• Ship repairing

• Other segments (water supply, space management, merchandise management)

The other segments include activities representing less than 10 % of total revenue and profit in all segments

and therefore are not disclosed as separate operating segments.

The Company level includes revenues and expenses that are not allocated by operating segment because

management monitors them at entity level.

Management does not make business decisions and does not monitor periodically the assets and liabilities of

the business sectors and for this reason does not make the relevant disclosures as required by the provisions

of IFRS 8.

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The segment information for the years ended December 31, 2022 and 2021 is analysed as follows:

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Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

24. REVENUES

Revenues are analyzed as follows:

1/1-31/12/2022 1/1-31/12/2021

Revenue from:

Loading and Unloading

39,112,739.87 34,118,025.70

Storage

10,590,773.95 3,755,225.38

Supply of water

1,953,712.12 1,412,144.39

Dry docking services

8,516,410.93 6,660,355.12

Cruise services -main activity

9,994,059.23 4,140,283.89

Ferry services - main activity

8,322,871.51 7,005,210.65

Environmental services

3,325,119.43 2,400,927.50

Mooring

13,284,651.75 10,872,845.98

Shipbuilding Repair Zone services

6,481,671.79 6,713,797.70

Other supporting services

9,896,781.31 6,695,340.51

Revenue from concession of liquid wastes’ collection and

transportation

368,285.66 318,080.71

Total

111,847,077.55 84,092,237.53

Revenue from Fixed and Variable Consideration:

Revenue from concession agreement Pier ΙΙ+ΙΙΙ 81,302,099.26 68,631,091.05

Other income from concession agreement Pier ΙΙ+ΙΙΙ

1,418,165.67 1,466,643.40

Total

82,720,264.93 70,097,734.45

Grand total 194,567,342.48 154,189,971.98

The current year increase in revenue is mainly due to the significant increase in revenues from the main

activity of the cruise services by € 5,853,775.34 or 141.4% and revenue from storing services by €

6,835,548.57 or 182.0% mainly due to the increase in transshipment volumes compared to the previous

year.

In 2022 the cruise industry saw significant growth in both arrivals and passenger traffic. Total passenger

traffic in 2022 amounted to 880,416 compared to 303,665 in 2021 recording an increase of 190%. Cruise calls

also increased by 79% with 677 calls compared to 379 the previous year, surpassing even pre-pandemic

levels.

The increase in revenue from the Pier II + III concession agreement is mainly due to the increase in the

variable consideration which amounted to € 68,138,651.46 (31.12.2021: € 55,988,003.14).

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(amounts in Euro unless stated otherwise)

25. ANALYSIS OF EXPENSES

Expenses (cost of sales and administrative expenses) are analyzed as follows:

1/1-31/12/2022

1/1-31/12/2021

Payroll and employee related costs (Note 29) 57,969,386.55 58,475,925.78

Third party fees 4,598,912.22 3,395,542.46

Third party services 14,895,053.78 11,251,090.09

Depreciation- Amortization (Note 28) 18,340,294.68 17,891,472.50

Taxes and duties 898,978.38 729,455.19

General expenses 4,829,800.70 4,070,005.30

Cost of sales of inventory and consumables (Note 10) 2,378,374.54 2,820,801.67

Provision for pending lawsuits (Note 18) (1,770,579.41) 4,364,840.15

Consession agreement fee (Note 21) 3,502,213.43 2,062,798.16

Total 105,642,434.87 105,061,931.30

The above expenses are analyzed as follows:

1/1-31/12/2022

1/1-31/12/2021

Cost of sales 83,533,672.93 77,375,617.18

Administrative expenses 22,108,761.94 27,686,314.12

Total 105,642,434.87 105,061,931.30

Third party fees: The significant increase of third party fees is mainly due to the increased use of external

partners for the provision loading and unloading services, as a result of the increase of the corresponding

works.

Third party services (including concession agreement fee):

a) For the year ended December 31, 2022 third party services include electricity charges of € 6,686,228.15

(31.12.2021: € 3,838,004.16), water supply charges of € 1,613,470.88 (31.12.2021: € 1,312,053.17),

telecommunication charges of € 246,213.91 (31.12.2021: € 278,796.85), rental expenses (including

concession agreement fee) of € 3,614,846.42 (31.12.2021: € 2,187,449.54), insurance expenses of

€ 1,295,228.42 (31.12.2021: € € 1,063,419.02), repair and maintenance costs of € 2,368,072.88 (31.12.2021:

€ 2,495,627.29) and other expenses of € 2,573,206.55 (31.12.2021: € 2,138,538.26).

b) Additionally, third party services include the fees of the company "KPMG Certified Auditors S.A." for the

services provided related to statutory audit fees for the financial statements (€ 95,000.00), tax audit

certificate in accordance with article 65A of L. 4174/2013 and the POL 1124/18.06.2015 (€ 25,000.00) as well

as other non – audit services (€ 51,000.00).

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(amounts in Euro unless stated otherwise)

26. OTHER OPERATING INCOME / EXPENSES

OTHER OPERATING INCOME

The amounts are analyzed as follows:

1/1-31/12/2022 1/1-31/12/2021

Rental income 4,360,230.78 3,400,757.54

Income from European Union programs

332,865.37 429,828.41

Income from the sale of consumables and other materials

151,540.20 -

Grants from OAED

26,479.78 -

Insurance compensation

121,054.36 224,679.38

Rental subsidy due to COVID-19

- 127,342.25

Various other operating income

503,728.47 564,510.64

Total

5,495,898.96 4,747,118.22

Rental income concerns land and building rents as well as the investment properties rent (Note 6).

According to legislative regulations, the companies that have been taken special and extraordinary measures

to suspend or temporarily ban operation for preventive or repressive reasons related to pandemic COVID-19,

is exempted from the obligation to pay 40% of the total rent from March 2020 to June 2021. Τhe Company

applied the above legal regulations for the lease of its premises to third parties. As a state subsidy for the

reduction of rents the Company received the amount of € 127,342.25 during the previous year.

OTHER OPERATING EXPENSES

The amounts are analyzed as follows:

1/1-31/12/2022

1/1-31/12/2021

Third parties compensation 8,244,517.15 156,190.61

Prior years' income tax fines and penalties 7,804,667.25

Loss on disposal of fixed assets

72,661.05 14,264.81

Other expenses 680,416.21 409,650.96

Total 16,802,261.66 580,106.38

The prior years’ income tax fines and penalties related to differences from tax audit for the year 2016 (Note

9). In addition an amount of € 1,376,120.29 related to a diferrence to the calculation of employees withheld

income tax for the years 2016-2018 as well as an amount of € 165,225.13 related to VAT penalties for the

year 2016, are included.

The third parties compensations relate mainly to a compensation paid to a supplier in accordance with a

relevant decision of an arbitral tribunal, as well as to interest compensation according to court decisions

finalized against Company. The Company on November 30, 2022 filled a lawsuit for the cancellation of this

decision of the arbitral tribunal which will be discussed on January 18, 2024.

Page 166 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

27. FINANCIAL INCOME/EXPENSES

The amounts are analyzed as follows:

1/1-31/12/2022 1/1-31/12/2021

Interest income and related financial income

4,228.30 9,790.90

Finance cost for lease liabilities (Note 5)

(2,393,727.05) (2,433,961.29)

Interest expense and related financial expenses (248,434.43) (874,372.33)

(2,637,933.18) (3,298,542.72)

Interest income on debtors late payments

76,818.25 96,585.78

Total (2,561,114.93) (3,201,956.94)

The reduction during the current year of interest expense and related financial expenses is mainly due to

a corrective commission amount to loans guarantee which relates to the years 2016 to 2022 amounting to

€ 792,567.00 (Note 19).

28. DEPRECIATION AND AMORTISATION

The amounts are analyzed as follows:

1/1-31/12/2022 1/1-31/12/2021

Depreciation of property, plant and equipment (Note 4)

16,258,433.76 15,998,993.46

Software depreciation (Note 7) 777,158.77 627,703.77

Depreciation of right of use assets (Note 5)

2,169,427.07 2,129,500.19

Fixed assets subsidies depreciation (Note 16)

(864,724.92) (864,724.92)

Total

18,340,294.68 17,891,472.50

29. PAYROLL AND EMPLOYEE RELATED COST

The amounts are analyzed as follows:

1/1-31/12/2022 1/1-31/12/2021

Wages and salaries 43,846,030.64 43,130,552.48

Social security costs 10,001,784.62 9,832,978.59

Other staff costs 2,357,247.37 2,068,629.57

Provision for staff leaving indemnities (Note 17) 1,576,830.81 1,821,366.68

Employee retirement incentives

1,338,000.00

Provision for cash-settled share based payments

187,493.11

284,398.46

Total 57,969,386.55 58,475,925.78

The Company had announced in prior years the offer of voluntary retirement incentives to those employees

who are close to retirement date with any legislation and under certain circumstances that were defined by

the Company until September of 2021.

In the previous year 11 workers and 48 employees made use of the incentives of € 1,338,000.00. According

to the decision 25 / 15-04-2021 of the BoD Chairman, the employees eligible for these incentives had to

retire until 30/09/2021. Therefore there is no intention to continue the incentive program beyond

30/9/2021.

Page 167 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Cash settled share based payments

The Extraordinary General Meeting of the Company's shareholders on September 23, 2019 approved the

long-term incentive bonus plan, which is cash settled of a certain number of Incentive Units. Beneficiaries of

the program are qualified members of the Board of Directors, senior executives and other key management

and business executives who have a significant influence on the performance and uninterrupted operation of

the Company.

The total number of Incentive Units in the Program is six hundred sixty-six thousand (666,000) and 80% of

the Incentive Units, equal to five hundred thirty-two thousand eight hundred (532,800) Incentive Units, were

allocated to the first Award date, and the remaining 20% of the total number of Incentive Units, namely one

hundred thirty three thousand two hundred (133,200) Incentive Units, was reserved for beneficiaries that

will join the Company or be promoted to beneficiary positions after the First Award Date and until 31

October 2020 Award date. Any key management personnel joining the Company after 31 October 2020 will

not benefit from the Program.

The Board of Directors of the Company at the meeting of October 25, 2019 named the beneficiaries of

498,200 units at the first award date (October 8, 2019). The minutes of the Board of Directors of December

22, 2020 named the beneficiaries of the program including the new-coming qualified managers and/or

promoted managers and canceling the Incentive Units of the beneficiaries who left the Company during the

period between the grant date and 31 October 2020 along with the remaining unallocated units. Following

this decision of the Board of Directors, there is no change in the Units of the program regarding the issuance

of new units. The Board of Directors of the Company at the meeting of December 6, 2021 decided the

cancellation of 92,000 units. The Board of Directors of the Company at the meeting of December 22, 2022

decided the cancellation of 21,300 units.

In more detail, the movement of the Program Units during the year and the final Units are listed in the table

below:

Number of Units

January 1, 2020

498,200

Forfeited units (54,900)

Granted units

47,900

December 31, 2020

491,200

Forfeited units (92,000)

Granted units -

December 31, 2021

399,200

Forfeited units (21,300)

Granted units

December 31, 2022

377,900

The amount payable to the beneficiaries is determined by the increase in the share price from the grant date

(8/10/2019: € 22.53) and the redemption date. The amount payable is determined by the same parameters

for the units granted in 2020. In addition, the redemption of the Incentive Units depends on the achievement

of predetermined performance criteria of the Company and the Beneficiaries.

Page 168 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

After fulfilling the Program's performance criteria over two years, the Incentive Units will be redeemed on

specific dates on the 2nd, 3rd and 4th anniversary from the date of the first award with the possibility of

being redeemed by the 7th anniversary by the above dates. The date of the first expiration, provided that no

redemption, will take place after the seventh (7th) anniversary. During the 2nd anniversary of the 1

award

date (8/10/2021) due to non-fulfillment of the performance criteria of the Program, no unit was redeemed.

The fair value of the long-term incentive bonus plan as of December 2019 was determined using the Binomial

model with the following data:

Share price at measurement date Εuro 21.85

Expected share voladility 25%

Dividend yield 2%

Risk-free interest rate 0%

The fair value of the units of the long-term reward plan granted during the fiscal year 2020 was determined

using the Binomial model with the following data:

Share price at measurement date Εuro 17.86

Expected share voladility 30%

Dividend yield 2%

Risk-free interest rate 0%

The valuation of the liability as at December 31, 2022 amounted to € 1,139,582.86 (31 December 2021 €

952,089.75) and is recorded in line item “Other long-term liabilities”.

30. EARNINGS PER SHARE

The earnings per share for December 31, 2022 and 2021 are as follows:

1/1-31/12/2022 1/1-31/12/2021

Net profit for the year 52,886,427.51 36,761,709.86

Weighted average number of shares 25,000,000 25,000,000

Basic Earnings per share 2.1155 1.4705

31. COMMITMENTS AND CONTINGENT LIABILITIES

(a) Litigation and Claims: The Company is currently involved in several legal proceedings and has various

claims against it of a total amount of approximately € 123.7 million (December 31, 2021: € 144.4 million).

These claims concern mainly labour disputes of a total claimed amount of 93.1 € (December 31, 2021: €

83.3 million), disputes with the Greek State of a total claimed amount of € 9,1 million (31.12.2021: € 31.8

million) and disputes with suppliers and others of a total claimed amount of € 21.5 million (31.12.2021: €

29.1 million). The employee labour cases are pending litigations against PPA SA before the civil and

administrative courts of all degrees and relate mainly with: a) claims against PPA for additional

compensation for the years 2010 and 2011 for the enforcement of the Agreement between PPA and the

labour unions to ensure equal working conditions and renumeration of PPA ‘s employees following the

concession of Pier II to PCT SA, b) claims against PPA for salary reduction based to the laws 3833/2010,

3845/2010 and 4024/2011 cases before the privatization of PPA, c) claims against PPA for salary

reduction based to the laws 3833/2010, 3845/2010 and 4024/2011 cases according after the

privatization of PPA SA , d) Few labor accidents and e) various other (pay grade cases, dockworkers’

overtime cases before the privatization period).

Page 169 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Disputes with general administration concern litigations before the administrative courts of all degrees,

having to do with decisions, taxes, charges, fines from Municipalities, Prefecture, Public Service

Decisions, Ministerial Decisions, Public Authorities’ Decision etc. The supplier / client dispute cases

concern compensation/ financial differences between PPA and its suppliers or customers arising in the

normal course of business. All other kind of cases that cannot be included to the above three categories

are characterized as “other”, for example non labour accident cases, compensation of third parties, real

estate cases, lease differences etc. The claimed amount of the Company’s other cases amounted of Euro

14,9 million (31.12.2021: Euro 20.5 million). Based on currently available information, management and

its legal department believe that the outcome of these proceedings will not have a significant effect on

the Company’s operating results or financial position, except for the recorded provisions in Note 18.

(b) Liabilities arising from letters of Guarantee: The Company has issued letters of guarantee amounting to

€ 19,520,412.45 (December 31, 2021: € 19,493,412.45), of which € 4,428,900.45 (December 31, 2021:

€ 4,428,900.45) in favor of the General Directorate of Customs (E 'and F' Customs Office) of the Ministry

of Economy for the operation of all warehouses for temporary storage of goods PPA S.A. Under the

current concession agreement of 24.06.2016 between the PPA and the Greek Government, PPA has

issued a letter of guarantee in favor of the Ministry of Finance General Secretariat of Public Property

amounted to € 15,000,000.00.

existing rental agreements are as follows:

31/12/2022 31/12/2021

Within 1 year 15,371,695.17 14,248,075.79

Beetween 1 and 2 years 14,960,666.47 13,706,007.96

Beetween 2 and 3 years 14,300,874.17 13,558,551.93

Beetween 3 and 4 years 14,189,555.79 13,445,672.53

Beetween 4 and 5 years 14,128,327.17 13,428,069.23

Over 5 years 236,658,215.75 244,433,546.89

Total 309,609,334.52 312,819,924.33

(d) Commitments for investments based on concession arrangement: Pursuant to the provisions of the

Concession Agreement signed between the Company and the Hellenic Republic dated on 24.06.2016, as

ratified by Law 4404/2016 (Gov. Gazette A '126 / 08.07.2016), the Company has the contractual

obligation for the implementation of investments in projects within the Port of Piraeus for the five

years, August 2016 - August 2021 amounting to € 293.8 million. The Concession Agreement included

specific terms regarding the conditions for the imposition of penal clauses by the Greek State, in case of

non-execution of mandatory investments as of August 2021. The possibility of imposing penalties under

the Concession Agreement was assessed by Compamy Management during the previous period and

was deemed remote, as the Company was able to prove that delays in the execution of mandatory

investment projects were outside the Company's reasonable control and therefore fell within the

exemption from the imposition of penalties in Article 16.5 (a) (i) of the Contract Concession. This

assessment was verified with the agreement of 22/09/2021 Amendment the Concession Agreement

between the Company and the Greek State as verified by Law 4838 / 1.10.2021 Government Gazette

180 A '(Note 3(t)).

As at December 31, 2022, the mandatory investments comprise of:

• completed mandatory investments of € 68.0 million (31.12.2021: € 60.3 million),

• projects under construction € 60.0 million (31.12.2021: € 51.7 million)

as well as prepayment for a mandatory investment of € 10.5 million (31.12.2021: € 5.8).

Page 170 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

(e) Contractual commitments with creditors: with regard to (d) above and other contracts signed, the

outstanding balance of the contractual commitments with suppliers on significant infrastructure

projects (construction, maintenance, improvements, etc.) at December 31, 2022 amounted to

approximately € 123.0 million (December 31, 2021: € 148.8 million) of which approximately € 75.6

million relate to the project "Passenger Port Expansion - South Zone - Phase A ' (December 31, 2021:

approximately € 76.5 million).

(f) Special Contribution to Social Security Institute (IKA – ETAM): On November 7, 2011 the Company

notified the management of IKA its intention to stop paying the special contribution in favor of the

supplementary fund of Company’s employees, since after the merger of IKA with IKA – TEAM

management of the Company considers that there is no further obligation. From October 2013, The

Company decided to cease the payments to those institutions. The management of the Company

believes that this contingent liability could be settled without significant adverse effects on its financial

position.

Page 171 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

32. RELATED PARTIES

The Company provides services to certain related parties in the normal course of business. The Company’s

transactions and account balances with related companies are as follows:

31.12.2022 89,054,072.42 54,892.48

31.12.2021 78,206,476.27 73,513.45

31.12.2022 310,866.55

19,680.45

31.12.2021 44,934.22

9,112.93

31.12.2022

52,991.58 11,050.00

31.12.2021

36,555.59 -

31.12.2022

- -

31.12.2021

27,300.00 -

31.12.2022

3,023.42 -

31.12.2021

- -

31.12.2022

- 142,465.99

31.12.2021

- 9,244.91

31.12.2022

16,464.90 -

31.12.2021

- -

31.12.2022

- 142,958.00

31.12.2021

- 106,346.61

31.12.2022

727.82

31.12.2021

- -

31.12.2022

- 674,937.19

31.12.2021

- 509,727.44

31.12.2022

- 75,245.15

31.12.2021

- 83,570.51

31.12.2022

- 29,463.04

31.12.2021

- 95,145.41

31.12.2022 89,437,418.87 1,151,420.12

31.12.2021 78,315,266.08 886,661.26

31.12.2022 4,889,650.89 5,416.16

31.12.2021 2,635,950.59 7,776.48

31.12.2022

482.00 39,353.25

31.12.2021

- 35,164.30

31.12.2022

18,414.00 -

31.12.2021

- -

31.12.2022

1,397.58 15,578.00

31.12.2021

- -

31.12.2022

646.50

31.12.2021

- -

31.12.2022

- 685,638.70

31.12.2021

- -

31.12.2022

- 15,474.70

31.12.2021

- -

31.12.2022

- 277.56

31.12.2021

- -

31.12.2022

181.91 -

31.12.2021

181.91 -

31.12.2022 4,910,126.38 762,384.87

31.12.2021 2,636,132.50 42,940.78

COSCO SHIPPING DEVELOPMENT CO. LTD

Related Party

COSCO SHIPPING TECHNOLOGY (BEIJING)

Related Party

COSCO SHIPPING SPECIALIZED CARRIERS CO.LTD

Related Party

QINGDAO OCEAN SHIPPING SERVICES

Related Party

COSCO (HONG KONG) INSURANCE BROKERS L.T.D.

Related Party

PCDC S.A.

Related Party

DIAMOND LINES GMBH

Related Party

PIRAEUS CONTAINER TERMINAL S.A

Related Party

COSCO SHIPPING LINES GREECE S.A.

Related Party

Relation with

the Company

Year ended

Amounts due from

related parties

Amounts due to related

parties

COSCO SHIPPING PORTS LIMITED

Related Party

COSCO (HONG KONG) INSURANCE BROKERS L.T.D.

Related Party

COSCO SHIPPING TECHNOLOGY (BEIJING)

Related Party

COSCO SHIPPING GLOBAL EXH

Related Party

QINGDAO OCEAN SHIPPING SERVICES

Related Party

COSCO SHIPPING TECHNOLOGY Co LTD

Related Party

DIAMOND LINES GMBH

Related Party

COSCO SHIPPING DEVELOPMENT CO. LTD

Related Party

COSCO SHIPPING SPECIALIZED CARRIERS CO.LTD

Related Party

PCDC S.A.

Related Party

PIRAEUS CONTAINER TERMINAL S.A.

Related Party

COSCO SHIPPING LINES GREECE S.A

Related Party

Related party

Relation with

the Company

Υear ended

Sales to related parties

Purchases from related

parties

Page 172 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The revenues of € 82,720,264.87 (2021: € 70,097,734.43) (Note 24) from Piraeus Container Terminal S.A.

(PCT S.A.) are related to the fixed and variable revenue from the concession agreement (PIER II & III) and

revenues of € 6,333,807.55 (2021: € 8,108,741.83) related mainly loading/unloading. Besides, PPA in April

2020, signed a contract about the provision of project management services with PCT S.A. for the business

operation of Pier I of PPA S.A. On December 29, 2020, the letter of guarantee from PCT S.A. with the amount

€ 42.0 million, reduced by 50% to € 21.0 million in previous year, and the letter of guarantee with the

amount € 475,000.00, reduced from € 950,000.00 by 50% in previous year, were returned to PCT S.A. On the

same date, a new letter of guarantee of € 663,000.00 regarding the rest of the construction of the west side

of Pier III for the construction works of Pier II and III was received (Note 22). This letter of guarantee expired

on December 29, 2022.

The transactions with COSCO SHIPPING LINES GREECE S.A. relate to ship services.

The transactions with COSCO SHIPPING GLOBAL EXH relate to exhibition expenses.

The transaction with COSCO SHIPPING TECHNOLOGY (Beijing) relates to software update .

The transaction with COSCO (HONG KONG) INSURANCE BROKERS L.T.D. of the current and the previous

period relates to the insurance coverage of PPA S.A. regarding third party liability, employer' s liability,

property and business interruption and directors and officers liability, according to article 17 of the

Concession Agreement (Law 4404/2016).

The transaction of the current and the previous year with COSCO SHIPPING PORTS LIMITED is related to

software for the purchaseof software and tax interconnection services with the SAP software.

The transaction with COSCO SHIPPING TECHNOLOGY Co. LTD relates to software support costs.

Board of Directors Members Remuneration: During the year 2022, remuneration and attendance costs,

amounting to € 1,105,404.21 (2021: € 889,082.91) were paid to the Board of Directors members.

Furthermore during the year ended December 31, 2022 emoluments of € 338,557.41 (December 31, 2021: €

554,857.42) were paid to Managers / Directors for services rendered.

The Extraordinary General Meeting of the Company's shareholders on September 23, 2019 approved the

long-term incentive bonus plan, which is cash settled of a certain number of Units. Beneficiaries of the

program are members of the Board of Directors, senior executives and other key management and business

executives who have a significant influence on the performance and uninterrupted operation of the

Company (Note 29).

Page 173 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

33. FINANCIAL INSTRUMENTS

Fair Value: The carrying amounts reflected in the accompanying sheets of financial position for cash and cash

equivalents, trade and other accounts receivable, prepayments, trade and other accounts payable and

accrued and other current liabilities approximate their respective fair values due to the relatively short-term

maturity of these financial instruments.

The fair value of variable rate loans and borrowings approximate the amounts appearing in the statements of

financial position.

The Company categorized its financial instruments carried at fair value in three categories, defined as

follows:

Level 1: Quoted (unadjusted) values from active financial markets for identical negotiable assets or liabilities.

Level 2: Other techniques for which all inflows that have a significant impact on the recorded fair value are

identified or determined directly or indirectly from active financial markets.

Level 3: Techniques that use inflows that have a significant impact on the recorded fair value and are not

based on quoted prices from active financial markets.

During the year ended December 31, 2022 , there were no transfers between Level 1 and Level 2 fair value

measurements, and no transfers into and out of Level 3 fair value measurements.

As at December 31, 2022 and 2021, the Company held the following financial and non financial instruments:

December 31, 2022 Level 1 Level 2 Level 3 Total

Financial assets

Investment property - - 5,578,000.00 5,578,000.00

December 31, 2021 Level 1 Level 2 Level 3 Total

Financial assets

Investment property - - 5,580,000.00 5,580,000.00

Financial risk management:

The financial risks related to the Company and their respective management are as follows:

Credit Risk: There is no significant credit risk for the Company towards the contracting parties, since it

receives advance payments or letters of guarantee from customers. In addition, the Company's deposits are

placed in bank financial institutions in Greece with the following ratings (Moody's credit rating):

December 31, December 31,

2022 2021

Β1 170,682,700.95 Β2 102,383,876.42

Β2 816,687.84 Β3 32,775,682.28

Total 171,499,388.79 135,159,558.70

Page 174 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Foreign Exchange Risk: The Company is neither involved in international trade nor has any long term loans in

foreign currency and therefore is not exposed to foreign exchange risk resulting from foreign currency rate

variations.

Interest rate risk: The Company’s borrowings consist of two loans in Euro and one is subject to fixed interest

rate and the other one to floating interest rate (Note 19). The Company does not use derivatives in financial

instruments in order to reduce its exposure to interest rate risk fluctuation as at the balance-sheet date. The

Company management believes that there is no significant risk resulting from a possible interest rate

fluctuation.

Following the ECB's decisions to proceed with interest rate increases after 11 years, and while due to the

increase in inflation, new interest rate increases are possible in order to achieve the objective of 2% inflation

in the medium term, the Management is closely monitoring the evolutions in the current period and

considers that the risk from the change in interest rates has increased compared to previous years. However,

the Company's management does not consider that this increase will have a significant impact on its

borrowing costs and its creditworthiness or its financial results, as the Company is not significantly exposed

to bank borrowing, and especially to the risk interest rate fluctuations. Additionally, in the context of the

more effective managing of its assets as effectively but also to the limitation of any potential impact of

increased borrowing rates on its results, the Company's management, taking advantage of its strong liquidity,

has begun evaluation procedures for potential reinvestment opportunities, considering the increased

deposit rates. The Company's management believes that there are no significant risks from a possible change

in interest rates.

The table below presents and analyses the sensitivity of the result in relation to financial assets (cash on

hand and in banks) and financial liabilities (loans) of the Company to the interest rate risk changes assuming

a simultaneous change in interest rates by ± 100 basis points on the Company’s profit.

2022 Decrease (Increase)

Financial assets Accounting values +100bips(Euribor) -100bips(Euribor)

Cash and cash equivalents

171,535,343.22 1,715,353.43 (1,715,353.43)

Effect before income tax

1,715,353.43 (1,715,353.43)

Income tax 22%

(377,377.76) 377,377.76

Net effect

1,337,975.67 (1,337,975.67)

Financial liabilities

Long term loans

(38,499,999.99) (385,000.00) 385,000.00

Effect before income tax

(385,000.00) 385,000.00

Income tax 22%

84,700.00 (84,700.00)

Net effect

(300,300.00) 300,300.00

Total net effect

1,037,675.67 (1,037,675.67)

2021 Decrease (Increase)

Financial assets Accounting values +100bips(Euribor) -100bips(Euribor)

Cash and cash equivalents

134,975,285.73 1,349,752.86 (1,349,752.86)

Effect before income tax

1,349,752.86 (1,349,752.86)

Income tax 22%

(296,945.63) 296,945.63

Net effect

1,052,807.23 (1,052,807.23)

Financial liabilities

Long term loans

(44,499,999.99) (445,000.00) 445,000.00

Effect before income tax

(445,000.00) 445,000.00

Income tax 22%

97,900.00 (97,900.00)

Net effect

(347,100.00) 347,100.00

Total net effect

705,707.23 (705,707.23)

Page 175 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

Liquidity risk: The effective management of liquidity risk is ensured by maintaining sufficient cash and the

availability of financing in case of need. Corporate liquidity risk management is based on the proper

management of working capital and cash flows.

The following table summarizes the maturity dates of the financial liabilities of 31 December 2022 and 2021

respectively, arising from the relevant contracts at unpaid prices.

Amounts of fiscal year 2022 Current portion

Less than

6 months

6-12 months 1 to 5 years >5 years Total

Borrowings - 3,496,453.75 3,456,534.58 26,215,186.67 8,713,215.83 41,881,390.83

Lease liabilities 4,624.60 3,520,579.48 9,000.00 14,000,000.00 87,937,500.00 105,471,704.08

Trade and other payables* 12,752,159.07 11,844,765.75 4,876,319.15 - - 29,473,243.97

Total 12,756,783.67 18,861,798.98 8,341,853.73 40,215,186.67 96,650,715.83 176,826,338.88

Amounts of fiscal year 2021 Current portion

Less than

6 months

6-12 months 1 to 5 years >5 years Total

Borrowings - 3,031,400.42 3,029,374.58 24,162,066.67 14,536,464.99 44,759,306.66

Lease liabilities 3,496.15 3,515,530.77 10,346.15 14,000,000.00 91,437,500.00 108,966,873.07

Trade and other payables* 6,653,055.85 8,301,662.10 4,022,595.27 - - 18,977,313.22

Total 6,656,552.00 14,848,593.29 7,062,316.00 38,162,066.67 105,973,964.99 172,703,492.95

* Trade payables do not have interest and are settled in up to 60 days. Other payables also do not bear any

interest and are settled in up to 12 months.

Capital Management

The primary objective of the Company's capital management is to ensure the maintenance of high credit

rating, and healthy capital ratios in order to support and expand the Company's operations and maximize

shareholder value. The Company's policy is to maintain leverage targets, according to an investment grade

profile. The Company monitors capital adequacy using the ratio of total debt to operating profits, which

should be lower than 9.80 based on the loan agreements (Note 19). The debt includes interest-bearing loans

and lease liabilities, while the operating profit includes profit/(loss) before taxes, financing costs and

depreciation.

2022 2021

Long-term borrowings 32,499,999.99 38,499,999.99

Short-term borrowings 6,000,000.00 6,000,000.00

Lease liability (long-term/short-term) 64,307,226.11 65,435,982.72

Total Debt (including lease liabilities) 102,807,226.10 109,935,982.71

Earnings before interest, tax, depreciation and amortization (EBITDA)

95,566,069.35 70,304,423.14

- Total Debt / EBITDA 1.08 1.56

December, 31

Page 176 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

34. SUBSEQUENT EVENTS

On January 2023, the Company proceeded with the total repayment of the additional income tax and

fines as well as the additional increments resulting from the income tax audit for the tax year 1/1/2016-

31/12/2016. Disputing the final deed of corrective determination/imposition of the income tax fine for

the year ended December 31, 2016, proceeded to appeal against the entire definitive act of the General

Directorate of Tax Administration (Note 9).

Except from the above, there are no other events subsequent to December 31, 2021 which would

influence materially the Company’s financial position.

Piraeus, March 17, 2023

CHAIRMAN OF THE BOARD OF

DIRECTORS

CHIEF EXECUTIVE OFFICER (ACTING)

FINANCIAL MANAGER

YU ZENG GANG

ZHANG ANMING

SERAFEIM MARMARIDIS

Passport No ΡΕ1895434

Passport No PE2110665

License No. Ο.Ε.Ε. 0110075

Page 177 of 177

Annual Financial Report for the year ended December 31, 2022

(amounts in Euro unless stated otherwise)

The annual financial report of the Company, the independent auditor’s report and the Management

Reports are available to the website www.olp.gr.