LAMDA Development S.A. ANNUAL FINANCIAL REPORT (In accordance with Article 4 of Law 3556/2007) FOR THE YEAR ENDED 31 DECEMBER 2022 ACCORDING TO INTERNATIONAL FINANCIAL REPORTING STANDARDS (IFRS)

Annual financial report for the year ended 31 December 2022

Index of annual financial report

I. STATEMENTS OF THE MEMBERS OF THE BOARD OF DIRECTORS ........................................... 3
II. ANNUAL MANAGEMENT REPORT OF THE BOARD OF DIRECTORS .......................................... 4
A. GROUP FINANCIAL POSITION ........................................................................................... 4
B. ALTERNATIVE PERFORMANCE MEASURES (“APMS”)............................................................. 8
C. SIGNIFICANT EVENTS UNTIL THE DATE OF THE FINANCIAL RESULTS ................................. 11
D. PROSPECTS, SIGNIFICANT CONTINGENT EVENTS AND RISKS FOR THE YEAR 2023 .............. 18
E. PENDING LITIGATION .................................................................................................... 21
F. RELATED-PARTY TRANSCATIONS .................................................................................... 22
G. BRANCHES ................................................................................................................... 22
H. NON-FINANCIAL POSITION OF THE GROUP ...................................................................... 23
I. CORPORATE GOVERNANCE DECLARATION ........................................................................ 67
J. EXPLANATORY REPORT OF THE BOARD OF DIRECTORS OF LAMDA DEVELOPMENT S.A. ........ 128
III. INDEPENDENT AUDITOR’S REPORT ............................................................................. 134

STATEMENT OF FINANCIAL POSITION (COMPANY AND CONSOLIDATED) ............................... 148
INCOME STATEMENT (COMPANY AND CONSOLIDATED) ....................................................... 149
COMPREHENSIVE INCOME STATEMENT (COMPANY AND CONSOLIDATED) ............................. 150
STATEMENT OF CHANGES IN EQUITY (CONSOLIDATED) 2022 .............................................. 151
STATEMENT OF CHANGES IN EQUITY (CONSOLIDATED) 2021 .............................................. 152
STATEMENT OF CHANGES IN EQUITY (COMPANY) 2022 ....................................................... 153
STATEMENT OF CHANGES IN EQUITY (COMPANY) 2021 ....................................................... 154
CASH FLOW STATEMENT (COMPANY AND CONSOLIDATED) ................................................. 155
NOTES TO THE FINANCIAL STATEMENTS ........................................................................... 157

GENERAL INFORMATION............................................................................................ 157
SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES ..................................................... 157
2.1 BASIS OF PREPARATION OF ANNUAL FINANCIAL STATEMENTS OF PREPARATION ......... 157
2.2 NEW STANDARDS, AMENDMENTS TO STANDARDS AND INTERPRETATIONS .................. 159
2.3 CONSOLIDATION ................................................................................................... 161
2.4 SEGMENT REPORTING ............................................................................................ 163
2.5 FOREIGN CURRENCY TRANSLATION ......................................................................... 163
2.6 INVESTMENT PROPERTY ......................................................................................... 164
2.7 TANGIBLE ASSETS ................................................................................................. 165
2.8 INTANGIBLE ASSETS ............................................................................................. 166
2.9 IMPAIRMENT OF NON-FINANCIAL ASSETS ................................................................ 166
2.10 FINANCIAL ASSETS ............................................................................................ 166
2.11 OFFSETTING FINANCIAL INSTRUMENTS ................................................................ 169
2.12 DERIVATIVE FINANCIAL INSTRUMENTS AND HEDGING ACTIVITIES .......................... 169
2.13 INVENTORIES .................................................................................................... 170
2.14 CASH AND CASH EQUIVALENTS ........................................................................... 171
2.15 SHARE CAPITAL – SHARE PREMIUM – TREASURY SHARES ....................................... 171
2.16 TRADE AND OTHER PAYABLES ............................................................................. 171
2.17 BORROWINGS .................................................................................................... 172
2.18 BORROWING COSTS ........................................................................................... 172
2.19 CURRENT AND DEFERRED INCOME TAX ................................................................ 172
2.20 EMPLOYEE BENEFITS .......................................................................................... 173
2.21 GRANTS ............................................................................................................ 174
2.22 PROVISIONS ...................................................................................................... 174
2.23 REVENUE RECOGNITION ..................................................................................... 175
2.24 LEASES ............................................................................................................. 176
2.25 DIVIDEND DISTRIBUTION ................................................................................... 177
RISKS MANAGEMENT AND FAIR VALUE ESTIMATION .................................................... 177
3.1 FINANCIAL RISK FACTORS...................................................................................... 177
3.2 CAPITAL RISK MANAGEMENT .................................................................................. 182
3.3 RISK MANAGEMENT UNIT ....................................................................................... 182
3.4 FAIR VALUE MEASUREMENT .................................................................................... 184
SIGNIFICANT ACCOUNTING ESTIMATES AND MANAGEMENT JUDGEMENTS ...................... 184
4.1 SIGNIFICANT ACCOUNTING ESTIMATES AND ASSUMPTIONS ...................................... 184
4.2 DECISIVE JUDGEMENTS OF THE MANAGEMENT FOR THE APPLICATION OF THE ACCOUNTING PRINCIPLES ... 185
SEGMENT INFORMATION ........................................................................................... 186
INVESTMENT PROPERTY ............................................................................................ 189
TANGIBLE ASSETS .................................................................................................... 193
INTANGIBLE ASSETS ................................................................................................ 194
INVESTMENTS IN SUBSIDIARIES, JOINT VENTURES AND ASSOCIATES ........................... 196
INVENTORIES ....................................................................................................... 208
11.# TRADE AND OTHER RECEIVABLES

CASH AND CASH EQUIVALENTS

RESTRICTED CASH

FINANCIAL INSTRUMENTS BY CATEGORY

SHARE CAPITAL AND SHARE PREMIUM

TREASURY SHARES

OTHER RESERVES

BORROWINGS

LEASES

NET EMPLOYEE DEFINED BENEFIT LIABILITIES

TRADE AND OTHER PAYABLES

PROVISIONS FOR INFRASTRUCTURE INVESTMENTS FOR HELLINIKON S.M.S.A.

DERIVATIVE FINANCIAL INSTRUMENTS

DEFERRED TAX

REVENUE

EXPENSES RELATED TO INVESTMENT PROPERTY

EXPENSES RELATED TO THE DEVELOPMENT OF THE ELLINIKON SITE

EMPLOYEE BENEFITS EXPENSE

OTHER OPERATING INCOME / (EXPENSES) - NET

FINANCE INCOME / (COSTS) - NET

INCOME TAX

COMMITMENTS

CONTINGENT LIABILITIES AND ASSETS

RELATED PARTY TRANSACTIONS

EARNINGS / (LOSSES) PER SHARE

DIVIDENDS PER SHARE

AUDIT AND OTHER FEES

COMPARATIVE INFORMATION

EVENTS AFTER THE REPORTING PERIOD

V. ANNEX – USE OF PROCEEDS

The financial statements are uploaded on the website www.lamdadev.com, the independent auditor’s report and the annual report of the Board of Directors for the companies which are incorporated in the consolidated financial statements of the Group.

Annual financial report for the year ended 31 December 2022 3

I. STATEMENTS OF THE MEMBERS OF THE BOARD OF DIRECTORS

STATEMENTS OF THE BOARD OF DIRECTORS OF “LAMDA DEVELOPMENT S.A.’’ FOR THE ANNUAL FINANCIAL REPORT FOR THE YEAR ENDED 31 DECEMBER 2022 (ACCORDING TO THE ARTICLE 4, Par.2(c) OF THE LAW 3556/2007)

We state to the best of our knowledge, that the annual financial statements of the Company and the Group of “LAMDA DEVELOPMENT S.A.” for the year ended on December 31, 2022 which have been prepared in accordance with the international accounting standards in effect, reflect fairly the assets, liabilities, equity and the results of “LAMDA DEVELOPMENT S.A.”, as well as of the entities that are included in the consolidation taken as a whole.

Furthermore, we state to the best of our knowledge that the Annual Report of the Board of Directors reflects fairly the development, the performance and the status of LAMDA DEVELOPMENT S.A., as well as of the entities that are included in the consolidation taken as a whole and includes a description of the main risks and uncertainties they confront.

Maroussi, 2 May 2023

The undersigned

Anastasios K.Giannitsis
Chairman of the BoD

Odyssefs E. Athanasiou
Chief Executive Officer

Evgenia G. Paizi
Member of the BoD

Annual financial report for the year ended 31 December 2022 4

II. ANNUAL MANAGEMENT REPORT OF THE BOARD OF DIRECTORS OF THE COMPANY «LAMDA Development S.A.» TO THE ANNUAL GENERAL MEETING OF SHAREHOLDERS FOR THE FISCAL YEAR 01.01.2022 – 31.12.2022

Dear Shareholders,

According to the provisions of L.3556/2007 and the relevant decisions of the Capital Market Committee Board of Directors, we present the annual Board of Directors’ report of “LAMDA Development S.A.” concerning the Consolidated and Standalone Financial Statements for the fiscal year that ended on December 31, 2022.

A. GROUP FINANCIAL POSITION

According to the International Financial Reporting Standards, the main financial figures for the Group and the Company for the fiscal year from 01.01.2022 to 31.12.2022 are as follows:

CONDENSED PRESENTATION OF CONSOLIDATED FINANCIAL RESULTS (amounts in € million)

	01.01.2022 to 31.12.2022	01.01.2021 to 31.12.2021	(%) change
Group operating result (EBITDA) before valuations and other adjustments excluding Ellinikon project	54,4	39,6	+38%
Group operating result (EBITDA) before valuations and other adjustments of Ellinikon project	(67,1)	(31,6)	-
Group operating result (EBITDA) before valuations and other adjustments	(12,6)	8,0	-
Revaluation gains of Shopping Malls and other investment properties	40,4	9,8	-
Revaluation gains of Ellinikon investment properties	105,6	315,5	-
Provision for impairment of inventories	(11,7)	(0,3)	-
Gain on disposal of investments in entities and investment properties	0,1	2,1	-
Total Group operating result (EBITDA)	121,8	335,1	-
Net results (after taxes and non-controlling interests)	(31,4)	191,2	-

Consolidated revenues amounted to €141,7m compared to €79,1m of year 2021. The significant increase in the Group's sales is mainly due to the impact of the Coronavirus COVID-19 pandemic on the revenue from the operation of the Group's shopping malls in the base year 2021, as more specifically for the first semester of 2021 significant rent discounts were applied due to the mandatory exemption from the obligation to pay rents by law. In addition, the Group lost in the first half of 2021 a large part of the revenue from the operation of the car parking stations, revenue from the advertising exploitation of shopping malls and the variable consideration on the sales of the shopkeepers, due to the lockdown and the reduction in traffic and the sales of shopkeepers.

At consolidated level in 2022, a positive effect on the change in revenue is the integration for a period of almost 5 months (from 06.08.2022) of the newly acquired shopping mall Designer Outlet Athens as well as Marina of Agios Kosmas, after the acquisition of the shares of HELLINIKON S.M.S.A. at the end of June 2021. Additionally, within the second half of 2022, the Group recorded total sales from the exploitation of the project in Ellinikon of €25,6 million and mainly concern (a) €21,9 million from residential projects (contracted sales of apartments) and (b) €3,2 million from contracted land rentals and construction project management and supervision services. It is noted that no revenue related to Ellinikon project was recorded in 2021.

Regarding operating results, Group operating result (EBITDA) before valuations and other adjustments excluding Ellinikon project reached €54,4 million increased by 38% compared to 2021. The increase resulted by (a) the significant increase of Shopping Malls operating result EBITDA as explained in detail above and (b)

Annual financial report for the year ended 31 December 2022 5

the integration for a period of almost 5 months (from 06.08.2022) of the newly acquired shopping mall Designer Outlet Athens (positive contribution in EBITDA of €3,7m). The revaluation, by an independent appraiser, of part of the assets (Investment Properties) of HELLINIKON S.M.S.A. improved the consolidated results of the fiscal year 2022 before taxes by €105,6 million, while the revaluation of the Shopping Malls and other Group’s properties recorded profits of €40,4 million. The total operating results (EBITDA) before valuations and other adjustments of the Ellinikon project amounted to losses of €67,1 million compared to losses of €31,6 million in 2021 as the Group has significantly accelerated the preparation and implementation of its strategic plan for the Ellinikon project.

Consequently, the consolidated net results of the Group, after taxes and minority rights, amounted to losses of €31,4 million against profits of €191,2 million in 2021. It is noted that the financial results of 2021 included the positive impact of €315,5 million compared to €105,6 million in 2022 that came from the revaluation, by an independent appraiser, of Investment Properties related to the Ellinikon project. Excluding the net results of Ellinikon project, the Adjusted consolidated net results, after taxes and minority rights, amounted to a profit of €3,0 million (versus a loss of €7,6 million in the corresponding fiscal year 2021).The operating results of Shopping Malls before valuations and other adjustments (Retail EBITDA) are as follows: (amounts in € million)

	01.01.2022 to 31.12.2022	01.01.2021 to 31.12.2021	(%) change
The Mall Athens	26,7	18,5	+44%
Mediterranean Cosmos	19,1	14,1	+36%
Golden Hall	19,1	12,8	+49%
Designer Outlet Athens	3,7	0,0	-
Retail EBITDA (Shopping Malls operating result before valuations and other adjustments)	68,6	45,4	+51%

EBITDA of Shopping Malls
The Mall Athens, Golden Hall and Mediterranean Cosmos in 2022 amounted to €64,9 million, increased by 43% compared to 2021, recording a new historical record-high operating profitability (+1% compared to 2019, milestone year with historically high revenues). It is noted that the operating result EBITDA of Shopping Malls in 2021 was adversely impacted by (a) the suspension of their operation for an aggregate period of about 3 months ¹ , and (b) the legal provision for rent discounts (40% ² discount) to shopkeepers/tenants which applied for the entire period of first half of 2021 (January – June). In 2022, Shopping Malls operated with minimal restrictions ³ related to the pandemic, while no legal provision for rent discounts. EBITDA of Shopping Malls (Retail EBITDA) including the newly acquired Designer Outlet Athens amounted to €68,6 million (+51% compared to 2021 and +7% compared to previous historically high operating profits of 2019). The total gross assets value (GAV) of the Shopping Malls as at 31.12.2022 (based on the assessment of independent appraisers) exceeded €1 billion after the integration of the newly acquired Designer Outlet Athens (from 06.08.2022). Excluding the value of Designer Outlet Athens (€116,3 million), the total value of Shopping Malls as at 31.12.2022 increased by €44,2 million compared to 31.12.2021 reaching to €916.3 million, recording a new record-high (€24 million increase compared to 2019). The Group, amidst the pandemic crisis during the last 2 years, has negotiated new or proceeded to the renewal of commercial agreements under similar or better financial terms that were in force before the pandemic crisis, thus enhancing the Shopping Malls’ value, which is also reflected in revaluations assessed by independent appraisers in 2022. The Group monitors the performance of the Shopping Malls through indicators, out of which the primary, according to the international standards, are the customer visits (total footfall) indicator and the

¹ The Shopping Malls “The Mall Athens” and “Golden Hall” in Athens remained closed for an aggregate period of 95 days each in 2021. “Mediterranean Cosmos” in Thessaloniki remained closed for an aggregate period of 71 days in 2021 (in February 2021, shops in Thessaloniki operated under the restrictive measures click-away). These restrictive measures were abolished on 15.05.2021.
² As per relevant legislation, shopkeepers/tenants have been exempted from paying the full (100%) rent for the entire period between January-May 2021, while the Ministry of Finance compensated LAMDA through a rebate of 60% of the rents. In June 2021, shopkeepers/tenants in the retail trade sector have received a 40% discount on rents, while shopkeepers/tenants active in the sectors of F&B/Entertainment/Cinemas have been exempted from paying the full (100%) rent, with the Ministry of Finance compensating LAMDA through a rebate of 60% of the said rent. No rent discounts are applied from July 2021.
³ Restrictions on the entry of visitors to the retail outlets and F&B shops of the Shopping Malls were in force until 30.04.2022.
Annual financial report for the year ended 31 December 2022 6
tenants/shopkeepers sales indicator which present the percentage increase between the current and the comparative period. Given the suspension of the Shopping Malls operation in 2021 for a total period of approximately 3 months, the comparison of the key Shopping Malls’ indicators against the corresponding period in 2021 is not only practically difficult but also becomes meaningless and therefore, the comparison of the key indicators cannot lead to safe conclusions. Therefore, below are presented the Shopping Malls’ performance indicators comparing 2022 with the corresponding period of 2019 (pre-pandemic period).

Shopping Malls Performance Indicators ⁴

	2022 vs 2019
	The Mall Athens
Tenants’ (shopkeeper) sales ⁵	-10%
Number of visitors (footfall) ⁶	-45%

Despite the adverse conditions in the economy and especially in the retail sector, due to the energy crisis and intense inflationary pressures, the following were observed during the year 2022:
* the total turnover of the stores of The Mall Athens, Golden Hall and Mediterranean Cosmos Shopping Malls in 2022 recorded a new historical record-high (€604 million against the previous record-high of €595 million in 2019). In particular, during in the second half of 2022 the total turnover (€361 million) increased 8% compared to the previous record of 2019. Regarding Designer Outlet Athens, the total turnover of the stores for the period August-December 2022 (consolidated from 06.08.2022) increased by 14% compared to 2019.
* the total number of visitors of The Mall Athens, Golden Hall and Mediterranean Cosmos Shopping Malls in 2022 decreased by 26% compared to 2019, reflecting the negative effects of the pandemic. However, it should be noted that the total number of visitors to the Golden Hall increased by 4% compared to 2019 (second half 2022: +9% compared to 2019) largely reflecting the positive contribution of the expansion of the western part of the property, which gradually started its operation since December 2019. Regarding Designer Outlet Athens, the total number of visitors for the period August-December 2022 (consolidated from 06.08.2022) increased by 12% compared to 2019.
* the average expenditure per visitor of The Mall Athens, Golden Hall and Mediterranean Cosmos Shopping Malls in 2022 increased by 38% compared to 2019, confirming the upward trend recorded from June 2021 onwards, following the gradual relaxation of restrictive measures for dealing with the pandemic. Given the decline in traffic, this increase is largely explained by the fact that the main reason for visiting is now purchases of goods. Regarding Designer Outlet Athens, the average expenditure per visitor for the period August-December 2022 (consolidated from 06.08.2022) increased by 2% compared to 2019.

Regarding the impact of the project for the development of the property in Ellinikon on the Group's net results for 2022, the following are highlighted:
* Total revenues amounted to €25,6 million (in contract to 2021 when no revenues were recorded) and mainly concern (a) €21,9 million from residential projects (contracted sales of apartments) and (b) €3,2 million from contracted land leases and construction project management and supervision services.
* The total operating expenses related to the exploitation of the property in Ellinikon amounted to €73,6 million (€32,0 million in 2021) as the Group has significantly accelerated the preparation and implementation of its strategic plan for the exploitation of property in Elliniko.
* Total operating results (EBITDA) before valuations and other adjustments of the Ellinikon project presented losses of €67,1 million (losses of €31,6 million in 2021).
* The positive impact from revaluation, by an independent appraiser, of the Investment Properties related to the Ellinikon project amounted to €105,6 million (€315,5 in 2021).
⁴ The newly acquired Designer Outlet Athens (consolidated from 06.08.2022) is not included.
⁵ The indicator regarding the change in the tenant’s (shopkeeper) sales is calculated as follows: total tenants’ sales of each Shopping Mall at the reporting period minus total tenants’ sales of each Shopping Mall at the comparative reporting period / Total tenants’ sales of each Shopping Mall at the comparative reporting period.
⁶ The indicator regarding the change of number of visitors (footfall) to Shopping Malls is calculated as follows: Total visitors passing from the entrances of each Shopping Mall at the reporting period minus total visitors passing from the entrances of each Shopping Mall at the comparative reporting period / Total visitors passing from the entrances of each Shopping Mall at the comparative reporting period.
Annual financial report for the year ended 31 December 2022 7
* Finance costs, which do not have an impact on cash and concern the accounting recognition of future liabilities ⁷ regarding the development of the property in Ellinikon, amounted to €38,0 million (compared to €18,6 million in 2021 due to the consolidation of HELLINIKON S.M.S.A. from 25.06.2021).
* Net profits/(losses) of the period for Ellinikon project, amounted to a loss of €34,4 million (against profit of €194,6 million in 2021). The total gross assets value (GAV) of the Ellinikon project on 31.12.2022 amounted to €1,95 billion, increased by approximately €159 million compared to 31.12.2021, due to (a) the accelerated implementation of the investment plan (increase of approximately €72 million) and (b) of inventory sales (decrease approximately €19 million) and (c) revaluation (increase approximately €106 million), based on the independent appraiser's assessment, of the value of the investment properties. The net assets value (NAV) on 31.12.2022 amounted to €1,36 billion (i.e. €7,78 per share), marginally lower (around €5 million) compared to 31.12.2021.

KEY ITEMS OF STATEMENT OF FINANCIAL POSITION (amounts in € million)

	31.12.2022	31.12.2021
Cash	693,9	539,4
Restricted Cash	(178,3)	(377,0)
Free cash	515,5	162,4
Investment Portfolio	3.156,2	2.840,1
Total Investment Portfolio	3.330,6	3.017,5
Total Assets	4.183,3	3.670,9
Total Equity	1.167,6	1.301,2
Total Debt	1.862,5	1.405,6
Adjusted Total Debt	2.491,1	2.040,6
Total Liabilities	3.015,6	2.369,7

⁷ It concerns (a) the purchase price consideration of HELLINIKON S.M.S.A.and (b) the obligation to carry out Infrastructure Projects of public interest (e.g. roads, public utility networks, undergrounding and footbridges etc.) which will be handed over to the Greek State upon completion, free of charge.

8 Adjusted number of shares for the 2.382.693 and 533.292 treasury shares held by the Company on 31.12.2022 and 31.12.2021 respectively.

NET ASSETS VALUE (NAV)

	31.12.2022	31.12.2021	(%)
Net Assets Value (NAV) (€ million) (as derives by internal information of the Group)	1.357	1.362	-0,4%
Net Assets Value (NAV) (€ per share) 8	7,78	7,73	+0,7%

FINANCIAL RATIOS

	31.12.2022	31.12.2021
ADJUSTED NET TOTAL DEBT / TOTAL INVESTMENT PORTFOLIO	54,0%	49,7%
TOTAL DEBT / TOTAL EQUITY AND TOTAL DEBT (GEARING RATIO)	61,5%	51,9%

Annual financial report for the year ended 31 December 2022

8 The impact due to the coronavirus pandemic COVID-19

The COVID-19 pandemic, although in recession, continued to be present during 2022. It is noted that the operating EBITDA of Shopping Malls in 2022 was not negatively affected at all, either by the suspension of store operations or by the implementation of Greek State’s directive for discounts on rents, in stark contrast to the corresponding period of 2021. Consequently, EBITDA profitability of Shopping Malls in 2022 showed accelerated rates of recovery reaching to pre-pandemic (2019) levels.

B. ALTERNATIVE PERFORMANCE MEASURES (“APMs”)

The Group uses certain Alternative Performance Measures (APMs) according to the characteristics of the certain sector that it operates, which are defined as follows:

Definitions :

Group operating result (EBITDA): Profit/(loss) before income tax, plus net finance costs, plus depreciation of tangible assets, intangible assets and right-of-use assets.
Operating result (EBITDA) of Ellinikon project: Profit/(loss) before income tax, plus net finance costs, plus depreciation of tangible assets, intangible assets and right-of-use assets, which concern Ellinikon project, excluding operations of Marina of Agios Kosmas.
Group operating result (EBITDA) excluding Hellinikon project: Group operating result (EBITDA) minus operating result (EBITDA) of Ellinikon project.
Total Group operating result (EBITDA) before valuations and other adjustments: Group operating result (EBITDA) excluding any investment property fair value gains/losses, inventory impairment losses, profit or loss from acquisition/disposal of participation share in investments, profit or loss from disposal of investment properties and other extraordinary valuation gains/losses and costs, as well as other adjustments.
Total operating result (EBITDA) before valuations and other adjustments of Ellinikon project: Group operating result (EBITDA) excluding any investment property fair value gains/losses, inventory impairment losses, profit or loss from acquisition/disposal of participation share in investments, profit or loss from disposal of investment properties and other extraordinary valuation gains/losses and costs, as well as other adjustments, which concern Ellinikon project, excluding operations of Marina of Agios Kosmas.
Total Group operating result (EBITDA) before valuations and other adjustments excluding Ellinikon project: Total Group operating result (EBITDA) before valuations and other adjustments minus total operating result (EBITDA) before valuations and other adjustments of Ellinikon project.
Retail EBITDA (Shopping Malls Operating Result before valuations and other adjustments): Individual operating result (EBITDA) before valuation and other adjustments of the entities LOV S.M.S.A., PYLAIA S.M.S.A. and LAMDA DOMI S.M.S.A. and DESIGNER OUTLET ATHENS S.M.L.L.C., which are involved in the exploitation of the Shopping Malls The Mall Athens, Mediterranean Cosmos, Golden Hall and Designer Outlet Athens respectively.
Net Asset Value (NAV): Equity attributable to equity holders of the Company adjusted by the deferred tax liability and asset attributable to equity holders of the Company.
Investment Portfolio: Investment property, excluding Right-of-use Assets for which a relevant lease liability is recognized, plus Inventories, plus Tangible and Intangible assets, plus Investments in joint ventures and associates, plus Right-of-use Assets of the Ellinikon properties under development.
Total Investment Portfolio: Investment property, plus Inventories, plus Tangible and Intangible assets, plus Investments in joint ventures and associates, plus Right-of-use assets.
Total Debt: Borrowings, plus Lease liabilities, plus Consideration payable for the acquisition of HELLINIKON S.M.S.A..
Adjusted Total Debt: Total Debt, plus Provisions for infrastructure investments in HELLINIKON S.M.S.A..
Net Total Debt: Total Debt, less Cash and cash equivalents, less Restricted cash for serving or securing Borrowings, less Restricted cash for the purpose of repaying Consideration payable for the acquisition of HELLINIKON S.M.S.A..
Adjusted Net Total Debt: Adjusted Total Debt, less Cash and cash equivalents, less Restricted cash for serving or securing Borrowings, less Restricted cash for serving or securing Borrowings,
Adjusted Net Total Debt / Total Investment Portfolio
Gearing Ratio: Total Debt / (Total Equity and Total Debt)
Net profit/(loss) of the period of Ellinikon project: Net profits/(losses) of the period which concern Ellinikon project, excluding operations of Marina of Agios Kosmas.
Adjusted net profit/(loss) attributable to equity holders of the parent Company: Net profits/(losses) for the period attributable to equity holders of the parent Company minus net profits/(losses) of the period of Ellinikon project.

For the present financial report and compared to the previous financial reports of 2022 and 2021, the Group has reformed the APMs to reflect more representatively its performance after the recent developments of the Ellinikon project.

Calculations :

Amounts in € thousand

	01.01.2022 to 31.12.2022	01.01.2021 to 31.12.2021
Total Group operating result (EBITDA) before valuations and other adjustments excluding Ellinikon project	54.428	39.556
Total operating result (EBITDA) before valuations and other adjustments of Ellinikon project	(67.065)	(31.601)
Total Group operating result (EBITDA) before valuations and other adjustments	(12.637)	7.955
Revaluation gains of Shopping Malls and other investment properties	40.423	9.778
Revaluation gains of Ellinikon investment properties	105.609	315.521
Provision for impairment of inventories	(11.736)	(272)
Gain on disposal of investments in entities and investment properties	109	2.092
Group operating result (EBITDA)	121.768	335.074

Amounts in € thousand

	01.01.2022 to 31.12.2022	01.01.2021 to 31.12.2021
Group operating result (EBITDA) excluding Hellinikon project	83.224	51.155
Operating result (EBITDA) of Ellinikon project	38.544	283.919
Group operating result (EBITDA)	121.768	335.074
Depreciation	(8.982)	(8.602)
Finance income	5.289	283
Finance costs	(94.509)	(58.892)
Profit/(loss) before income tax	23.566	267.863

Amounts in € thousand

	01.01.2022 to 31.12.2022	01.01.2021 to 31.12.2021
The Mall Athens	26.730	18.540
Mediterranean Cosmos	19.080	14.061
Golden Hall	19.082	12.792
Designer Outlet Athens	3.721	-
Retail EBITDA (Shopping Malls Operating Result before valuations and other adjustments)	68.613	45.393

Annual financial report for the year ended 31 December 2022

Amounts in € thousand

	01.01.2022 to 31.12.2022	01.01.2021 to 31.12.2021
Net profit/(loss) for the period attributable to equity holders of the parent	(31.409)	191.242
Minus: Net profit/(loss) of the period of Ellinikon project	(34.386)	194.555
Adjusted net profit/(loss) for the period attributable to equity holders of the parent	2.977	(3.313)

Amounts in € thousand

	31.12.2022	31.12.2021
Investment property	2.010.614	1.846.920
Inventories	1.067.924	948.197
Tangible assets	88.429	58.146
Intangible assets	27.920	20.384
Investments in joint ventures and associates	3.919	3.483
Right-of-use assets	131.783	140.329
Total Investment Portfolio	3.330.589	3.017.459

Amounts in € thousand

	31.12.2022	31.12.2021
Borrowings	1.162.661	721.420
Lease liabilities	181.336	182.912
Consideration payable for the acquisition of HELLINIKON S.M.S.A.	518.528	501.245
Total Debt	1.862.525	1.405.577

Amounts in € thousand

	31.12.2022	31.12.2021
Total Debt	1.862.525	1.405.577
Less: Cash and cash equivalents	(515.515)	(162.402)
Less: Restricted cash for serving or securing borrowings	(11.347)	(210.000)
Less: Restricted cash for the purpose of repaying consideration payable for the acquisition of HELLINIKON S.M.S.A.	(167.000)	(167.000)
Net Total Debt	1.168.663	866.175

Amounts in € thousand

	31.12.2022	31.12.2021
Total Debt	1.862.525	1.405.577
Plus: Provisions for infrastructure investments in HELLINIKON S.M.S.A.	628.614	635.008
Adjusted Total Debt	2.491.139	2.040.585

Amounts in € thousand

	31.12.2022	31.12.2021
Adjusted Total Debt	2.491.139	2.040.585
Less: Cash and cash equivalents	(515.515)	(162.402)
Less: Restricted cash for serving or securing borrowings	(11.347)	(210.000)
Less: Restricted cash for the purpose of repaying consideration payable for the acquisition of HELLINIKON S.M.S.A.	(167.000)	(167.000)
Adjusted Net Total Debt	1.797.277	1.501.183

Annual financial report for the year ended 31 December 2022

Amounts in € thousand

	31.12.2022	31.12.2021
Total Investment Portfolio	3.330.589	3.017.459
Total Debt	1.862.525	1.405.577
Net Total Debt	1.168.663	866.175
Adjusted Total Debt	2.491.139	2.040.585
Adjusted Net Total Debt	1.797.277	1.501.183

Group Financial Ratios

	31.12.2022	31.12.2021
ADJUSTED NET TOTAL DEBT / TOTAL INVESTMENT PORTFOLIO	54,0%	49,7%
TOTAL DEBT / TOTAL EQUITY AND TOTAL DEBT (GEARING RATIO)	61,5%	51,9%

C.# SIGNIFICANT EVENTS UNTIL THE DATE OF THE FINANCIAL RESULTS

Important developments regarding Ellinikon project

In January 2022, a framework agreement was signed between HELLINIKO S.M.S.A. and BINCER HOLDING LTD, a company of the group BROOK LANE CAPITAL, for the development of a state-of-the-art Mixed-Use Tower, within the Commercial Hub in the Vouliagmenis Avenue, which will be completed during the first five- year phase of the Ellinikon project. The development concerns the realization of a tower consisting of office space, a luxury hotel and residences, intended to be a landmark of the entire area and will be done through a special purpose vehicle company whose share capital will be held by a company of the group BROOK LANE CAPITAL and by HELLINIKON S.M.S.A. at 70% and 30% respectively. The design of the Mixed-Use Tower has been assigned to the leading international architectural firm AEDAS, while the management of the hotel and residences will be assigned to an internationally renowned management company (hotel operator).

In March 2022, the process of the technical and financial evaluation of the submitted offers regarding the infrastructure construction works in Phase 1 of the Ellinikon project has been completed. The process that started in July 2021 and was completed in March 2022, has resulted in the selection of AVAX S.A. to be awarded as Main Contractor. The works started in March 2022 and will continue until September 2025. Infrastructure works in Phase 1 will be delivered gradually and include, inter alia, the provision of an extensive road network. The road network includes the Poseidonos Avenue underpass and flyover, as well as the construction of utilities networks to serve all planned buildings. Among those are the buildings for residential and commercial developments and the sports complex, the Metropolitan Park as well as other developments planned during Phase 1 of the project.

In April 2022, the consortium between Bouygues Batiment International and Intrakat was selected as a consultant to provide pre-construction advisory services in the form of “Early Contractor Involvement (ECI)” for the construction of the Riviera Tower. These ECI consulting services are provided in preparation for the construction of the Riviera Tower and cover the design, planning, procurement, logistics, and construction management, in preparation for the construction of the project.

In April 2022, Lamda Development presented the plans for the new building complex to be developed in the Ellinikon site, which will be the first building of the landmark investment. The incorporation of a building complex for vulnerable groups in the Ellinikon site, confirms that this landmark project involves and supports the entire society. The welfare of people with disabilities and especially the existence of suitable caring and occupational structures are crucial to them and their families. The initiative of the Group to make the first building to emerge at The Ellinikon a building for persons with disabilities is highly symbolic. The new building at The Ellinikon, which will house the associations of Amimoni, Ermis, Niki Victor Artant, as well as the Association of Persons with Multiple Sclerosis, stands out for its pioneering, green, sustainable design, like the rest of the investment. The construction cost of the building at €15 million will be borne entirely by the Group Lamda Development. The vision of Lamda Development goes beyond simply creating a modern building. It showcases a new way of life, of higher quality, easier, more open, more extrovert, that will improve the daily life of children, but also adults with disabilities. It is for that reason that the entire Ellinikon investment was designed, planned, and is being created with special provisions for persons with disabilities.

In May 2022, the building permit was issued for the construction of a new Building Complex to which the above 4 Associations for persons with disabilities are to be relocated. The construction works of the building, which is considered an international model for Care Units, is already underway and will be completed in 2023.

Annual financial report for the year ended 31 December 2022
12

In June 2022, the subsidiary HELLINIKO S.M.S.A. signed a Memorandum of Understanding (MoU) with ORILINA PROPERTIES REIC (hereinafter “ORILINA PROPERTIES”), under which the parties will consider the purchase by ORILINA PROPERTIES of the leasehold rights on parts of the Development Zone of the Coastal Front in the Ellinikon and in particular on land plots located in the wider area of the Marina Agios Kosmas. The said plots, with a potential total buildable area of up to 5.790 sqm.

In August 2022, the Government Gazette of the amendment of the KYA was issued for the "Approval of the spatial organization of the Development Zones PM-A1 "Neighborhood of Marina Agios Kosmas"..." which captures the land plots (located between the residential tower Riviera Tower and the commercial destination of Riviera Galleria) which will be the object of the transaction with ORILINA PROPERTIES, with the completion of the final contract estimated to be signed in May 2023. The total investment by ORILINA PROPERTIES for the development in question is estimated at €70 million and concerns on the one hand a residential building and other ancillary their service facilities, and on the other hand, a building that will include areas for catering, recreation, wellness, events, as well as the sale of catering-related products.

In April 2022, the revision of the building permit was issued for the Experience Center housed in the Air Force Hangar C' designated as a newer monument. The Experience Center opened its doors to the public (free entry) from 28.04.2022.

In June 2022, Lamda Development presented its design for the creation of The Ellinikon Park, the largest coastal park in Europe, which will be positioned in the heart of The Ellinikon. The world-renowned architectural firm Sasaki, which has designed and implemented some of the largest and most impressive urban parks in the world, in cooperation with the Greek architecture office Doxiadis, are currently working on the design and the study for The Ellinikon Park.

The areas of The Ellinikon Park

The Olympic Square will highlight the Olympic heritage, while the nearby amphitheater will host concerts and other events. At its highest point, a variety of open-air, sculpture and contemporary art exhibitions will be curated, with emphasis on works made by Greek artists. An area larger than Pedion tou Areos, will be filled with vine gardens, olive trees and fields, inviting guests on a discovery journey of the Greek agriculture. In the Saarinen area one can find the imposing main building of the Eastern Ellinikon International Airport, which was the gateway to Athens for decades. This modern monument will be given a new life as an exhibition and cultural centre. The Trachones stream is restored resulting in the rejuvenation of the local ecosystem and the transformation of the surrounding area. The remodeled canoe-kayak Lake, created for and used during the 2004 Olympic Games in Athens, will offer spectacular views and countless opportunities for exploration. Lastly, an integral part of The Ellinikon Park is the Experience Park, in proximity to the three hangars of the Hellenic Air Force, which has already become the new destination for relaxation in the southern suburbs.

A “smart” park of the future

The Ellinikon Park will be the first “smart” park in Greece which will incorporate smart solutions for the visitors’ security, and the protection of the natural environment such as lighting systems whose intensity will be adjusted depending on the season and time of day, but also systems for continuous monitoring of surrounding conditions to reduce energy and water consumption. Lamda Development’s objective is for the smart infrastructures at The Ellinikon Park to serve as a model nationally and internationally.

Sustainability being the focus of the design

The Ellinikon Park was designed based on sustainability principles and taking into account the biodiversity of the Attica region. The 1.000.000 new trees and plants that will be planted in the Park will enrich the existing vegetation that will be incorporated in the design. Through innovative, contemporary infrastructures, The Ellinikon Park will be able to cover its irrigation and electricity needs, completely offsetting its carbon footprint in its life cycle. Lamda Development’s objective is to deliver, in the coming years, an urban park which will be one of a kind for Greece and worldwide, and for everyone to visit, enjoy and make part of their daily life.

In June 2022, the subsidiary HELLENIC S.M.S.A. signed a Memorandum of Cooperation (MoU) with PRODEA INVESTMENTS and Costeas-Geitonas School (CGS) with the aim of establishing a modern educational

Annual financial report for the year ended 31 December 2022
13

organization of primary and secondary education in Hellinikon (CGS Ellinikon). The MoU envisages a long-term lease of land to PRODEA, which will develop the school facilities which it will lease to CGS.

In August 2022, the building permit of the Riviera Tower residential building on the Coastal Front of Hellinikon was issued, marking the start of construction work on the tallest (200 meters) building in Greece. It is emphasized that the issuance of the permit was completed according to the schedule, despite the particularly complex and demanding process (due to the large number of more specialized approvals and the parties involved in the process). It should also be noted that the Riviera Tower has received "gold" pre-certification from June 2022, according to the internationally recognized LEED (Leadership in Energy & Environmental Design) certification system for sustainable buildings.Riviera Tower is the first and only residential building in Greece that has a "gold" pre-certification of a "green" LEED building. In September 2022, an agreement was signed between HELLINIKO S.M.S.A (100% subsidiary of the Company) and the company IRC HELLINIKON S.A. (joint venture GEK TERNA - Hard Rock), the Real Estate Agreement for the concession to IRC ELLINIKOU of land in Elliniko, in which the latter has undertaken to develop an Integrated Resort Casino [“Integrated Resort Casino” (IRC)]. The duration of the Real Estate Agreement is 30 years. In March 2023, part of the annual rent of €5 million was received. The development in question will host a five (5) star hotel, conference and exhibition center and public gathering space for sporting and/or cultural events and casino. The development of the IRC will take place in accordance with the provisions of the Concession Agreement between the Greek State and IRC HELLINIKO S.A (L. 4949/2022 - GG A' 126/30.06.2022) and it is estimated that it will be completed within three (3) years from the start of the relevant works. In December 2022, the building permit was issued for the particularly demanding project of the New Sports Facilities in the Metropolitan Park. It should be pointed out that for the specific project important individual permits/approvals/opinions were required with the involvement of many different parties (issuance of a Decision on the Approval of Environmental Conditions by the Environmental Licensing Division of Ministry of the Environment and Energy, approval in terms of functionality by the General Secretariat of Sports of the Ministry of Culture and Sports etc.).

Infrastructure Works and preliminary/preparatory work and other construction work

The Company has significantly accelerated its project execution efforts. Among others we highlight the following:

The AVAX group, as the Main Contractor for the infrastructure construction projects of Phase 1 of the Hellinikon project, started the relevant works from May 2022. It is noted that the infrastructure projects include an extensive road network, including the undergrounding and the uneven junction of Poseidonos Avenue, the port works, the wastewater treatment facility as well as the construction of utility networks to serve all the developments foreseen during Phase I of the project.
construction works related to the Posidonos Avenue underpass: has been completed 50% of the excavations and 25% of the concreting,
was completed the construction of new high-voltage power supply lines,
concreting of central rainwater collectors,
start of main and local road construction works,
construction Flyover works, with preloading of the soil, preparation of a scaffolding and bypass study for the construction of the bridge carrier over Posidonos Avenue,
excavations in the Trachones stream
demolition of existing airport runways and reuse of their materials,
soil and groundwater remediation and decontamination works,
in the new buildings relocation (AMEA) has been completed 100% concrete works. Has been completed 95% of the thermal facade, internal partitions have been completed and the internal finishing works are in full progress. Demarcation and permanent fencing of the property have begun and the Electromechanical works are in full swing. The horticultural works will start in early May and will be Annual financial report for the year ended 31 December 2022 14 completed by the end of the construction. The construction of the PWD project will contractually be completed within the summer of 2023 including testing & commissioning. Pickup / delivery is scheduled for July 2023.
start of deep foundation work (pile construction) at Riviera Tower (approx. 45% of total 300 piles completed).

Commercial developments - Progress of commercial leases

Vouliagmenis Mall: have been already signed/agreed Heads of Terms (HoT) for 52% of the gross leasable area (GLA) (40% on 31.12.2022). Within 2023 HoT are expected to be signed for 70% of GLA. The signing of commercial cooperation contracts is expected to start from the end of 2023.
Riviera Galleria: have been already signed/agreed Heads of Terms (HoT) for 21% of the gross leasable area (GLA) (19% on 31.12.2022). Within 2023 HoT are expected to be signed for 50% of GLA. The signing of commercial cooperation contracts is expected to start from the end of 2023.

Collections from the sale of plots and apartments on the Coastal Front

Villa land plots (The Cove Villas): the sale (signing of a notarial deed) has been completed for 19 plots of land (15 plots on 31.12.2022) out of the total of 28 available plots, with the total proceeds from said sales amounting to approximately €77 million (approximately €55 million on 31.12.2022) (concerns the payment of 50% of the value of the plot as well as 100% of the value of the infrastructures attributable to them). In addition, customer advances have already been deposited for 8 plots, with the total amount of advances amounting to approximately €1.4 million. Completion of the purchase and sale for these 8 plots is expected in Q2 2023. The estimated total gross revenue from the sale of all plots, during the first five years (Phase A'), is estimated at approximately €214 million including revenue from construction management. The construction costs are assumed by the buyers, while the management of the design and partly of the construction by HELLINIKON S.M.S.A.
Riviera Tower: the sale (signing of a notarial deed) has been completed for 133 apartments (122 apartments on 31.12.2022) out of the total of 170 apartments (78% of the total), with the total proceeds from said sales amounting to approximately €75 million. (approx. €69 million on 31.12.2022) (concerns the payment of 20% of the price). In addition, customer advances have already been deposited for 22 apartments (13% of the total), with the total amount of advances amounting to approximately €7 million (approximately €8 million on 31.12.2022). The completion of the sale for the said 22 apartments as well as for the remaining 15 apartments (for which until now there are negotiations with interested buyers but no advances have been deposited) is expected within the Q2 2023. The estimated total gross income for the total of apartments, during the first five years (Phase A'), amount to approximately €625 million.
The Cove Residences (Condos): Regarding the reservations for the future purchase of the said apartments, customer advances have already been deposited, which correspond to approximately 90% of the total (approximately 87% of the total on 31.12.2022), amounting to approximately €26 million (approximately €26 million on 31.12.2022). It is estimated that the signing of the notarial acts for the completion of sales will begin in the Q2 2023, where 25% of the total price will be collected. The estimated total gross income for all the condos, during the first five years (Phase A'), amounts to approximately €279 million, upon completion of the respective sales.
Sale of properties in the context of the of the strategic cooperation between the Company and TEMES S.A.: on 06.03.2023 the first installment of a total amount of approximately €30 million was collected regarding the sale by HELLINIKON S.M.S.A. of the two properties on which the two modern, luxurious 5-star hotels and the corresponding tourist-residential complexes (branded residences) will be developed jointly with TEMES on the Coastal Front of Ellinikon. Annual financial report for the year ended 31 December 2022 15

Building permits, pre-approvals and certifications of sustainable buildings

The Cove Residences (Condos): in January - February 2023, building permits were issued for all building blocks.
Vouliagmenis Mall: a landmark project designed by the world-renowned architectural firm AEDAS from Hong Kong has been designated as of March 2023 as a Building of Special Architectural Design by the relevant agencies of Ministry of the Environment and Energy. The traffic and environmental studies were submitted in December 2022 and are in the approval process with the issuance of the building permit estimated in July 2023 according to the project schedule. The selection of the contractor for the Early Contractor Involvement (ECI) pre-construction consultancy is in final negotiations with the award estimated in May 2023 marking the start of excavation work on this landmark project.
Riviera Galleria: landmark project Riviera Galleria designed by the world-renowned Japanese architect Kengo Kuma has been designated as of October 2022 as a Building of Special Architectural Design by the competent services of of Ministry of the Environment and Energy. It is emphasized that the Riviera Galleria received in December 2022 "gold" pre-certification, according to the internationally recognized LEED (Leadership in Energy & Environmental Design) sustainable building certification system. Riviera Galleria is the first and only shopping malls in Greece that has a "gold" pre-certification of a "green" LEED building. In March 2023 and according to the Project schedule, the Pre-Approval of the building permit was issued, which also ensures the final approval of the building permit, which is estimated in July 2023.

Amendments to the Urban Studies and Amendment of PD for Approval of the Integrated Development Plan in Hellinikon – Agios Kosmas

In March 2022, the Government Gazette of the amendment of the KYA was issued for the "Approval of Urban Planning Studies of the areas to be urbanized A-P1, A-P2, A-P3, A-P4, A-P5, A-P6 and PM-P1 of Metropolitan Pole of Hellinikon-Agios Kosmas..", with the main purpose of turning the residential area on the coastal front (PM-Π1) practically into a "car-free" neighborhood.* In August 2022, the Government Gazette of the amendment of the KYA was issued for the "Approval of spatial organization of the Development Zones PM-A1 "Neighborhood of Agios Kosmas Marina"..." in order to implement new business initiatives, e.g. commercial developments, hotels.
In July 2022, the Government Gazette was issued amending the PD for IDP Approval for the reduction of the required parking spaces in properties served by Fixed Track Vehicles within a radius of 500 meters as well as for the implementation of the NOK's urban planning incentives.

New Business Agreements

As part of the implementation of the business plan for the development of the project, the Company recently announced the following new important business agreements:

Strategic cooperation with TEMES S.A. for the development of a top tourist destination in Ellinikon:

In February 2023 the company BELT Riviera S.A. was established which is 70% controlled by TEMES S.A. and 30% from HELLINIKO S.M.S.A. The company BELT Riviera S.A. will undertake the development, according to the original design, of a 5-star hotel with 160 rooms as well as a residential complex of 17 branded luxury homes/apartments (Branded Residences) with unobstructed sea views. On 06.03.2023 the company BELT Riviera S.A. acquired 100% of the right of full ownership over a property of 80,011 sq.m. in the "PM-A2" Development Zone of the Hellinikon-Agios Kosmas Metropolitan Pole, on which the said development will take place. The total price of the said transaction amounted to approximately €38,3 million, which includes the acquisition value of the property amounting to approximately €22,3 million and the participation in the corresponding infrastructure costs of Metropolitan Pole amounting to approximately €16 million. The first installment of approximately €12,8 million, plus taxes, was paid on 06.03.2023.
In February 2023 the company MALT Riviera S.A. was established. which is 70% controlled by TEMES SA. and 30% from HELLINIKO S.M.S.A. The company MALT Riviera S.A. will undertake the development, according to the original design, of a 5-star hotel with 200 rooms as well as a residential complex of 49 branded luxury homes/apartments (branded residences) with unobstructed views of the sea and Marina Ag. Cosmas. On 06.03.2023 the company MALT Riviera S.A. acquired 100% of the surface right on a property with an area of 132,822 sq.m. in the "PM-A1" Development Zone of the Annual financial report for the year ended 31 December 2022 16 Hellinikon-Agios Kosmas Metropolitan Pole, on which the said development will take place. The total price of the said transaction amounted to approximately €52,5 million, which includes the acquisition value of the property amounting to approximately €32,5 million and the participation in the corresponding infrastructure costs of Metropolitan Pole amounting to approximately €20 million. The first installment of approximately €17,5 million, plus taxes, was paid on 06.03.2023.

Financing for the development of the Property of Ellinikon

The Company, on 27.01.2020 signed with “Eurobank S.A.” and “Piraeus Bank S.A.” the “Heads of Terms” regarding the bank financing intended to cover part of the capital to be invested by the Group during the first five years of the Ellinikon project development. On 07.04.2021, the Company signed with the aforementioned banks an agreement for the update of the “Head of Terms”. This update emanated from the gradual evolution and maturity of the Company’s plans regarding the envisaged projects and investments during the first five years of the Project. The aforementioned bank financing agreement includes:

(a) the financing of infrastructure and other developments’ works during the first five years of the Project (Phase A), as well as the financing of V.A.T., with a bond loan of up to €442m to be issued by HELLINIKON S.M.S.A. (plus an amount of up to €100m for financing of recoverable V.A.T. cost), with a duration of 10 years from the Transfer Date,
(b) the financing of the commercial development on Vouliagmenis Avenue (Vouliagmenis Mall), as well as the financing of V.A.T., with a bond loan of up to €415m to be issued by a special purpose vehicle controlled by LAMDA DEVELOPMENT S.A. (plus an amount of up to €86m for financing recoverable V.A.T. cost), with a duration of 6 years from the first drawdown (with the possibility of the issuing company to extend the maturity for an additional 5 years, reaching 11 years in total from first loan drawdown),
(c) the financing of the commercial development within the Aghios Kosmas Marina (Riviera Galleria), as well as the financing of V.A.T., with the issuance of a bond loan of up to €102m to be issued by a special purpose vehicle controlled by LAMDA DEVELOPMENT S.A. (plus an additional amount of up to €19m for financing of recoverable V.A.T. cost), with a duration of 5 years from the first drawdown (with the possibility of the issuing company to extend the maturity for an additional 6 years, reaching 11 years in total from the loan first drawdown) and in conjunction with the financing mentioned in points (a) and (b) above,
(d) the issuance of a letter of guarantee of €175m, to secure the fulfillment of LAMDA DEVELOPMENT S.A. obligations to cover any cost overruns of Phase A of the Project, as well as to cover any shortfall in sales and/or assets exploitation intended to finance Phase A of the Project budget l.

Following the written agreement dated 29.06.2022 with the Representative of the Bondholders, the amount of the aforementioned Letter of Guarantee was reduced from €175 million to €160 million.

Regarding the (a) above, HELLINIKON S.M.S.A. signed on 06.04.2022 with the banks "Eurobank S.A." and "Piraeus Bank S.A." the bond program and subscription agreement for the financing of infrastructure and other developments’ works of Phase A of up to €394m, as well as for the financing of V.A.T. (additional amount up to €100m), with a duration until the completion of 10 years from the Date of Transfer, a fact that covers its revised needs.

Regarding, (d) above, LAMDA DEVELOPMENT S.A. signed on 06.04.2022 the relevant contractual documents.

Regarding the (b) and (c) above the Company is still in progress to finalize the contractual agreements with the mandated lead arranger banks.

Significant events – Shopping Malls

During July 2022, the Company announced that, through its 100% subsidiary company L.O.V. S.M.S.A. – owner of The Mall Athens, acquired the minority percentage (31,7%) of the subsidiary company LAMDA MALLS S.A., which was previously owned by the company Wert Blue SarL, a 100% subsidiary of Värde Partners and the price amounted to €109 million, which was paid in cash. Therefore, the Company acquired the total control of subsidiary LAMDA MALLS S.A., which owns the companies LAMDA DOMI S.M.S.A. and PYLAIA S.M.S.A., owners of Golden Hall and Mediterranean Cosmos shopping centers respectively. The above transaction is part of the Company's existing strategy aimed at further developing the activities of the Shopping Malls.

In July 2022, the wholly owned subsidiary L.O.V. S.M.S.A. (owner of The Mall Athens) signed a new Common Bond Loan programme with Eurobank and Piraeus Bank, for an amount of €365 million. On August 2022 amount of €361 million was utilized from all three distinct series which were used for the repayment of the Annual financial report for the year ended 31 December 2022 17 existing bond loan with NBG amounting €209,5 million, as well as for the acquisition of (a) minority interest 31,7% of LAMDA MALLS S.A. and (b) 100% of DESIGNER OUTLET ATHENS S.M.L.L.C. (former McArthurGlen Hellas S.M.L.L.C.), owner of shopping center Designer Outlet Athens.

In August 2022, the Company announced that, through its 100% subsidiary company L.O.V. S.M.S.A., acquired on 05.08.2022 100% of the shares of the company DESIGNER OUTLET ATHENS S.M.L.L.C. (former MCARTHURGLEN HELLAS S.M.L.L.C.), owner of the retail park Designer Outlet Athens in Spata, region of Attica, from the company MGE Hellenic Investments S.àr.l.. Designer Outlet Athens is one of the leading retail parks in Greece with a total leasable area of approximately 21,200 sq.m. and more than 100 shops, café and restaurants. The occupancy rate on 30.06.2022 was about 95% while the total number of visitors in full and unhindered operation (in 2019, before the pandemic) was about 4,2 million visitors per year. The said transaction forms part of the Company’s existing strategy to further develop the activities as well as the portfolio of the Shopping Malls.

Significant events – Parent Company

On 28.03.2022 the Board of Directors of the Company decided, following the sad loss (on 20.03.2022) of the member of the Board of Directors Odysseus Kyriakopoulos, to continue the management and representation of the Company with the remaining members and in accordance with the current terms of management and representation.
On 25.05.2022, the Board of Directors of the Company in its meeting accepted the resignation of Mr. Fotios Antonatos from the position of non-executive member of the Board of Directors of the Company and elected Mr. Emmanuel Bussetil as a non-executive Member, replacing the resigned for the remainder of his term of office, in accordance with article 82 of Law 4548/2018 and paragraphs 5 and 8 of article 10 of the Company's Articles of Association.
In June 2022, Lamda Development Group acquired percentage of 67,71% of GREEN VOLT P.C. through participation in a share capital increase of €1,65 million. The subsidiary will be active in the renewable energy sector.# In July 2022, in the midst of adverse market conditions (intense inflationary pressures and rising interest rates, geopolitical and energy crisis), the Company completed, through a Public Offer, the issuance of the first Green Common Bond Loan (CBL) amount of €230 million (7-year duration with interest rate 4.70%), with the participation of more than 14.000 Greek investors, recording a new record of investor participation in a bond issue and with a significant over-coverage (3,12 times). The raised funds of the Green Bond will be allocated exclusively to eligible Green investment categories such as the development of Sustainable Buildings and sustainable urban outdoor spaces, Green Energy and Smart Cities. On 13.07.2022 the trading of the 230.000 bonds in the Fixed Income Securities category of Athens Stock Exchange began (trading code: "LAMDAO2"/"LAMDAB2"). In October 2022, the Company made its first investment in Green Energy, which is financed by the proceeds of the €230 million Green Bond Loan issued on 12.07.2022. LAMDA ENERGY INVESTMENTS, a wholly owned subsidiary of the Company, signed a share transfer agreement for the acquisition of 20% of the share capital of R Energy 1 Holding for a cash consideration of €5 million. At the same time, R Energy 1 Holding S.A. proceeded with the issue of a 3-year convertible bond loan of €10.0 million, which was fully covered by LAMDA ENERGY INVESTMENTS S.M.S.A. in October 2022. Upon conversion of the above-mentioned convertible bond loan, LAMDA ENERGY INVESTMENTS will have the right to acquire a 50,1% stake in the share capital of R Energy 1 Holding. The acquisition of a 20% stake in the share capital of R Energy 1 Holding S.A. was completed in January 2023. R Energy 1 Holding currently owns renewable energy projects in operation with a total capacity of 43,5MW and, according to the company's investment plan, the total installed capacity is expected to reach approximately 100MW by the end of 2024.

Annual financial report for the year ended 31 December 2022

18 D. PROSPECTS, SIGNIFICANT CONTINGENT EVENTS AND RISKS FOR THE YEAR 2023

Impact from inflationary pressures, energy crisis, increased interest rates and geopolitical instability

Increasing energy costs, a trend observed in the international markets, due to the energy crisis, had an adverse impact in Shopping Malls’ operating expenses during 2022. The total energy cost of the Shopping Malls (The Mall Athens, Golden Hall and Mediterranean Cosmos) for the year 2022 amounted to €4,4 million, increased by 64% compared to 2021. Most of the said cost relate to the common areas in the Shopping Malls, which are undertaken by the shopkeepers/tenants. The following are noted regarding the increase in energy costs in 2022:

(a) the Group had active contracts for fixed energy prices until the end of April 2022, which ensured very low unit prices for the first quarter and was not affected by the significantly high market prices,
(b) the Group, in the context of competitions, entered into new fixed-term variable pricing contracts (one for the period up to September 2022 and the second for the following period up to April 2023), with one of the highest-profile providers in Greece, following the conditions of the energy market, which ensured competitive prices compared to the market,
(c) the energy consumption in the Shopping Malls was higher in 2022 compared to 2021, due to their longer operating period (in 2021 the Shopping Malls remained closed, by law, for a total period of about 3 months).

The Group constantly monitors the developments in the energy market in order to react immediately and take advantage of possible market variations. Finally, the Group will intensify its efforts to implement its “green” energy investments in eligible properties, to reduce future energy costs, by limiting dependence on traditional energy sources.

The Group has not agreed or contracted final selling prices for the larger part of the projects and developments included in The Ellinikon. This enables the Group to pass on to its counterparties all or part of the increase in raw material prices and energy costs, observed recently in the market, while maintaining selling prices at competitive levels based on the broader market conditions. Worth noting that, in accordance with international practices related to the preparation of future estimates-budgets for projects of similar size and complexity, the Group has included contingencies in the cost estimates for all projects and developments included in The Ellinikon.

Regarding the exposure, at Group level, to the risk of increases in interest rates, it is pointed out that this risk mainly concerns long-term borrowings with a floating interest rate. Borrowings with a floating interest rate at the end of 2022 (31.12.2022) constituted approximately 53% of total and amounted to approximately €617 million. At the same time, interest rate swap contracts have been concluded, in order to hedge against changes in interest rates, amounting to approximately €112 million. Therefore, according to the relevant sensitivity analyses, a +/- 1 percentage point change in the reference interest rates (Euribor) of floating rate borrowings has an impact of approximately €5 million on the annual finance cost on a consolidated basis (respectively in the pre-tax consolidated results of the Group). In addition to the above, the Group has entered into an interest rate swap agreement of €100 million regarding the bank borrowings to finance the development of the Property in Ellinikon, which has not yet been disbursed.

Regarding the war in Ukraine and the current geopolitical developments, it is worth highlighting the following:

(a) the Company does not own subsidiaries and/or other investments in Russia/Ukraine, or other neighboring areas directly affected from war conflicts
(b) in the Shopping Malls there are no shopkeepers/tenants originated from the said countries and
(c) there are no customers from said countries who have submitted deposits for the future purchase of both apartments on the residential tower Riviera Tower and land plots for Beach Villas.

Annual financial report for the year ended 31 December 2022

19

predict the general impact that may have on the financial status of the Group's customers a prolonged energy crisis and increase in prices in general. Based on its current assessment, it has concluded that no additional provisions for impairment are required for the Group's financial and non-financial assets as at 31 December 2022.

Fluctuations in property values

Fluctuations in property values are reflected in the Income Statement and Statement of Financial Position according to their fair value. An increase in yields would have a significant impact on the Group’s profitability and assets, not only for the existing Shopping Malls, but also for part of the assets (Investment Property) of the HELLINIKON S.M.S.A. In addition, the complete impact of the consequences of the economic situation and the effects of a prolonged crisis in Ukraine, energy crisis, inflationary pressures, as well as the possibility of spread of pandemic COVID-19 may affect the value of the Group’s investment property in the future. However, due to the successful performance of existing Shopping Malls “The Mall Athens”, “Golden Hall” in Maroussi and “Mediterranean Cosmos” in Pylaia Thessaloniki, their market value is less likely to be reduced. We note that despite the existing factors of increased uncertainty, the values reported provide the best estimate for the Company’s investment property.

Credit risk

Credit risk is managed on Group level. Credit risk arises from credit exposures to customers, cash and cash equivalents, as well as restricted cash. Regarding Group revenue, these are mainly deriving by customers with an assessed credit history and credit limits, while certain sale and collection terms are applied. Revenue will be significantly affected in case customers are unable to fulfil their contractual obligations due to either downsizing of their financial activities or weakness of the local banking system. However, the Group on December 31, 2022 has a well-diversified tenant mix consisting mainly of well-known and reputable companies. The customers’ financial condition is monitored on a recurring basis. The Group Management considers that there is no substantial risk for doubtful debts, other than those for which sufficient provisions have already been recognized. In addition, customers' credit risk is significantly reduced due to the Group's policy of receiving bank letters of guarantee from tenants. Taking into account the impact of the COVID-19 pandemic and energy crisis, the Group and the Company have also included in the assessment of expected credit losses, the increase in credit risk to customers whose activities have been adversely affected, as well as to customers whose repayment capacity of their contractual obligations presented a greater risk.Total value of trade and other receivables is the maximum exposure to the credit risk. The deposits and cash of the Group and the Company are rated in Moody’s. As at 31.12.2022, the Group’s cash and cash equivalents and restricted cash are concentrated mainly in 3 bank institutions in Greece higher than 10%, which shows significant concentration of credit risk. No significant credit losses are anticipated in view of the credit status of the banks that the Group keeps current accounts. The recent crisis in the banking sector (Silicon Valley and Credit Suisse) can significantly affect international markets and economies, e.g. widening of credit margins. According to analysis by international rating agencies and a relevant recent report by the Governor of the Bank of Greece, the possibility of the crisis spreading to the rest of the banks is very small. Banks are adequately capitalized, liquidity ratios are very high and there does not seem to be a problem in the Greek or European banking system.

Foreign exchange risk

The Group operates mainly in Greece and the Balkans and is therefore exposed to foreign exchange risk arising from various currencies. The majority of the Group's transactions are carried out in Euro. Foreign exchange risk arises from future commercial transactions as well as the assets, liabilities and net asset value of investments operating in foreign countries. The Group’s stable policy is to avoid purchasing foreign currency in advance and contracting FX future contracts with external counterparties, as well as FX hedging.

Annual financial report for the year ended 31 December 2022
20

The Group has participations in subsidiaries that operate abroad which equity is exposed to foreign exchange risk at the conversion of their financial statements for consolidation purposes. In relation to the operations outside Greece, the most significant operations take place in Serbia where the foreign exchange rate historically does not show considerable changes and most of the Group’s transactions are conducted in Euro. Also, the Group’s operations outside Greece do not include material commercial transactions and therefore there is not a significant foreign exchange risk.

Interest rate risk

Interest risk mainly derives from the Group’s loans with floating interest rates based on Euribor. This risk is partially hedged through cash held at floating rates. Also, the Group examines its exposure to the risk of changes in interest rates and manages this risk considering the possibility of refinancing, renewal of existing loans, alternative financing and risk hedging. The Group's exposure to the risk of changes in market interest rates mainly concerns the long-term borrowings of the Group with floating interest rates. The Group also manages interest rate risk by having a balanced loan portfolio with fixed and floating interest rates. As of December 31, 2022 approximately 47% of the Group's loans had a fixed interest rate which concern the Common Bond Loan of nominal value €320m and bond yield of 3,40%, as well as the Company’s new Common Bond Loan under the Framework of Green Bond of nominal value €230m and bond yield of 4,70%. Specifically, to cover the changes in interest rates, the Group has entered into interest rate swaps for the conversion of floating interest rates into fixed ones, with respect to part of the loan of the subsidiary LAMDA DOMI S.M.S.A. which amounts to €60,1 million as at 31.12.2022, as well as for part of the loan of the subsidiary PYLAIA S.M.S.A. which amounts to €51,6 million as at 31.12.2022. The change in the fair value of the derivatives (interest rate swaps) was recorded in the statement of comprehensive income and the income statement, as hedge accounting is applied. The sensitivity analysis below is based on change in a variable keeping all other variables constant. Such a scenario is not probable to happen, and changes in variables can be related for example to change in interest rate and change in market price. As of December 31, 2022 a change by +/- 1,00% on reference rates (Euribor) of loans at functional currency with floating rate, would have an impact of +/-€5 million in finance cost at Group level on annual basis and +/-€0,1 million at Company level. The impact (increase / decrease) on results before tax of the year and the equity respectively of the Group and the Company would be corresponding.

Inflation risk

The Group is exposed to fluctuations in demand and offer of real estate in the domestic market which are affected by the macroeconomic developments in the country and the developments in the domestic real estate market (including inventories of the Ellinikon project). Any extreme negative changes of the above may have a corresponding negative impact on business activity, operating cash flows, fair value of the Group's investment property, and in equity. Decrease in the demand or increased offer or shrinking of the domestic real estate market could adversely affect the Group's business and financial condition, as well as negatively affect the Group's investment property occupancy, the base consideration of commercial cooperation contracts, the level of demand and ultimately the fair value of these properties. Also, the demand of spaces in the Group’s investment property may decrease due to the adverse economic condition or due to increased competition. The above may result to lower occupancy rates, renegotiation of commercial cooperation contracts terms, higher costs required for entering into commercial agreements, lower revenue from base remuneration, as well as lower term commercial cooperation contracts. The Group enters into long-term operating lease arrangements for a minimum of 6 years, and the lease payments are adjusted annually according to the Consumer Price Index plus margin coming up to 1,5-2%.

Liquidity risk

Existing or future risk for profits and capital arising from the Group's inability to either collect overdue debts without incurring significant losses or to meet its obligations when payable, since cash outflows may not be fully covered by cash inflows. The Group ensures the required liquidity in time to meet its obligations in a timely manner, through the regular monitoring of liquidity needs and debt collection from tenants, the maintenance overdraft accounts with systemic banking institutions and the prudent management of cash. The liquidity of the Group is monitored by the Management at regular intervals.

Annual financial report for the year ended 31 December 2022
21

As at 31.12.2022, the short-term bank bond loans mainly include the bank bond loan of the subsidiary L.O.V. S.M.S.A. ("LOV") signed on 29.07.2022 with the credit institutions under the name Eurobank and Piraeus Bank new program of common bond loan for amount up to €365m, consisting of three distinct series with interest rate of 2,70% plus 3-month Euribor. Until 31.12.2022, an amount of €361 million has been disbursed, which is classified in the short-term part of the Group's borrowings. The Group in cooperation with the banks, is planning to refinance the said loan, as well as the bank loans of the rest of Shopping Malls, in the context of planned restructure withing 2023. The short-term bank borrowings include also the Credit Agreement with open account of the Company with Piraeus Bank for amount up to €10 million, which was signed on 06.06.2022. As at 31.12.2022, the amount of said loan amounted to €7,98 million. More detailed disclosures regarding liquidity risk are presented in note 3 of the consolidated and standalone financial statements for the year ended December 31, 2022.

External Factors

The Company has investments mainly in Greece, and to a much lesser extent in Serbia, Romania and Montenegro. The Group can be affected by external factors such as political instability, economic uncertainty and changes in local tax regimes. At the macroeconomic level, focusing mainly on Greece, the early repayment of part of the Greek Debt to the IMF strengthens the international profile of the country and signals the recovery of the confidence of the financial markets and international rating agencies, reflecting the successful implementation of reform commitments. Additionally, positive prospects are reinforced by the funds of the EU Resilience and Recovery Fund that are expected to foster economic growth through structural investments. However, the disposable income and private consumption in turn are affected by the current economic conditions in Greece, such as the GDP, unemployment, inflation and taxation levels. As such, a potential deterioration of the aforementioned indicators together with a decline in economic sentiment and/or consumer confidence, could result in a decrease of the spending activity of the Group’s customers. The Company's Management closely monitors and evaluates the events in order to take the necessary measures and to adjust its business plans (if required) in order to ensure business continuity and limitation of any negative effects on the Group's activities. It is worth pointing that the Company has constituted a Risk Management Unit (RMU). The aim of the RMU is to strengthen the risk management culture, while its mission is to make a substantial contribution to the development of a modern operating framework at all organizational levels, to identify, assess and manage the risks faced by the Company. RMU ensures that the risks taken by the company's units comply with the risk appetite and tolerance limits set and shaped by the senior management. Despite the aforementioned uncertainties, the Group’s operations continue without any disruption. However, Management is not able to accurately predict the likely developments in the Greek economy and its impact on the Group activities. The financial risk factors are disclosed in note 3 of the annual consolidated and standalone financial statements for the year that ended on 31.12.2022.
E.# PENDING LITIGATION

THE MALL ATHENS

With regard to the legal issues relating to the particular investment, the following should be noted: The company L.O.V. S.M.S.A. (“L.O.V.”) had to pay for the transfer of specific real property in the past (on 2006), property transfer tax of approximately €13,7m, reserving its rights regarding this tax and finally taking recourse to the administrative courts against the silent rejection of its reservations by the competent Tax Authority. In 2013 the said recourse was accepted in part and the re-calculation of the owed property tax was ordered, which led to the returning to L.O.V. of an amount of approximately €9,5m. Further to appeals on points of law filed by both parties, the Council of State rejected LOV’s appeal and accepted the Hellenic Republic’s appeal; consequently the case was referred back to the Administrative Court of Appeals, which initially postponed the issue of a final decision and obliged the parties to adduce evidence for the determination of the market value of the property; after resuming hearing of the case, the Administrative Court of Appeals finally rejected the recourse, determined the taxable value of the property and obliged the competent Tax Authority to re-calculate the transfer tax due upon the new taxable value. Following this decision, L.O.V. had to pay transfer tax of approximately €16,3m. An appeal on points of law has been filed before the Council of State and is estimated by the legal counsels of the Company to have high chances of success. In specific, grounds of appeal challenging re-calculation of transfer tax upon the market value of the property, to the extent it exceeds the objective value, are expected to succeed with very high probability. The hearing of the appeal was held on 25.5.2022 and on 18.1.2023 Council of State decision No 54/2023 was issued, which remains unclear. According to its published order, the appeal of L.O.V. is accepted and the decision of the Administrative Court of Appeal which calculated the taxable value of the property based on the market value is annulled, to the extent that it exceeds the objective value. Following this, a new tax settlement and return to L.O.V. is expected, equal to the excess amount of approximately €9.3 million (including interest until 31.12.2022).

GOLDEN HALL

With respect to LAMDA DOMI S.M.S.A., a public (already private) law entity under the trade name “Hellenic Olympic Committee” (“HOC”) has filed a lawsuit against the Public Real Estate Property Company S.A. (“ETAD”). By means of the said lawsuit, the HOC claims to be entitled to, and therefore to be granted, the use, management and exploitation of a plot of land of its ownership in which the International Broadcasting Centre (“IBC”) is built. The HOC also claims ETAD to be declared as liable for an overall amount of €90.784.500, which is alleged to have been the lease price paid by the company under the trade name “LAMDA DOMI S.M.S.A.” (“LAMDA DOMI”) to ETAD (and its predecessor “HELLENIC OLYMPIC REAL ESTATE S.A) for the period 30.04.2007-30.06.2019. The said lawsuit is based on the alleged by the HOC contravention of Article 35 of Law 3342/2005 to Article 17 of the Constitution and more specifically on the allegation that the delegation of use, management and exploitation deprives the HOC from its right to use the plot and benefit therefrom as its rightful owner. Pursuant to an impleader by ETAD, LAMDA DOMI filed a “supporting intervention” in favor of ETAD. Pursuant to the hearing of the case on 13.05.2021, decision No. 2374/2021 of the Multi-Member First Instance Court of Athens was issued. By means of said decision, the HOC’s lawsuit has been dismissed. According to the data available on Athens First Instance Court website, an appeal was recently filed against said decision. LAMDA DOMI has not been served with a copy of this appeal yet.

HELLINIKON S.M.S.A.

HELLINIKON S.M.S.A. has no significant open legal cases against, but on the other hand there are several open cases in favor. Therefore, although until the date of publication of the annual financial statements of 31.12.2022 the result cannot be reliably measurable, the Company's Management concludes that by the time those will be finalized, the result will not affect, significantly, the financial results of the Group. For the aforementioned pending litigation of the Group, we should clarify that there is no reason under IAS 37 for recognizing provisions as according to the relevant opinion of the Group’s companies’ legal advisors and the Management’s estimations, it is not considered as likely that resources will be required to settle these cases.

F. RELATED-PARTY TRANSACTIONS

The related-party transactions according to IAS 24 of the Company and the Group are disclosed in note 34 of the consolidated financial statements for the year ended on 31 December 2022.

G. BRANCHES

Branches of the Group are the shopping and entertainment centers "The Mall Athens" and "Mediterranean Cosmos" located in Marousi at 35 A. Papandreou Street and at the 11th km of the Thessaloniki-Neon Moudania National Road respectively, as well as the Agios Kosmas Marina in the Ellinikon region of Attica.

H. NON-FINANCIAL POSITION OF THE GROUP

This Non-Financial Statement is part of the Board of Directors Management Report and includes information related to the LAMDA Development Group activities (hereinafter referred to as "Group" or "LAMDA Development" and “Company” when exclusively referring to the listed LAMDA Development S.A.) in the following thematic aspects, as defined in articles 151 and 154, Law 4548/2018, as codified by Law 5019/2023, Government Gazette A' 104/13-06-2018. In addition, it includes a relevant section in compliance with the EU Taxonomy Regulation 2020/852:

Brief description of the business model
Main non-financial risks
Environmental issues/Climate change
Social and labour issues
Respect for human rights
Anti-corruption and issues related to bribery
Supply chain issues
EU Taxonomy report

This Statement, includes information on the European common enforcement priorities for the annual financial reports and statements for the year 2022, as announced by ESMA (European Enforcers focus on Russia's invasion of Ukraine, economic outlook and climate-related disclosures and European Common Enforcement Priorities 2022) and in particular:

Priority 1: Climate-related topics (see section Environmental issues/Climate change).
Priority 2: Disclosures under Article 8 of the Taxonomy Regulation (see section Taxonomy Report).
Priority 3: Scope of the Report and data quality (below).

The purpose of the non-financial information provided, is to inform stakeholders in an integrated and comprehensive manner, about the strategy, objectives, and performance of the Group (including its subsidiaries) in its value chain (upstream, midstream, downstream). In the context of the sustainable development strategy (it concerns The Ellinikon project, which will also be adapted to the rest of the Group's activities in the coming period), key performance indicators are recognized, to:

monitor the progress of its implementation, as well as to
identify, in a timely manner, potential challenges that may hinder its implementation, and thus, proceed in taking all necessary corrective actions.

These indicators, that will be published in the Sustainable Development Report 2022, will be based both on the materiality analysis results and international best practices. The Sustainable Development Unit is responsible for the preparation of this information and undertakes to collect all the necessary information and compile the present statement, in cooperation with the competent Departments within the Group. The information is reviewed by the Internal Audit Department. The Board of Directors (BoD) approves the annual financial report, of which this non-financial statement forms part. The content of the present non-financial statement has been prepared by taking into consideration the GRI Standards (2021). In addition, it incorporates Athens Stock Exchange's 2022 ESG Disclosure Guide metrics (a more complete depiction of the GRI Standards disclosures and the Athens Stock Exchange ESG Reporting Guide metrics will be available in the Sustainable Development Report 2022). LAMDA Development participates in the ESG index of the Athens Stock Exchange.

The current Statement includes Golden Hall, The Mall Athens, Mediterranean Cosmos, Designer Outlet Athens, Flisvos Marina, The Ellinikon (including Ag.Kosmas Marina), Head Offices (unless otherwise indicated), which constitute more than 85% of the activities of the Group in terms of revenue.

1. Brief description of the business model

LAMDA Development S.A., is a holding Company which specializes in the development, investment, and management of real estate properties. It is the leading Company in the real estate developer in Greece and the undisputed leader in the sector of shopping centers, with successful differentiation in the office and residential spaces sectors. Marinas and coastal development of residences and commercial activities, hold an important share of its portfolio and strategy. Its property portfolio currently includes:

The Ellinikon – Agios Kosmas Metropolitan Park area that is currently being redeveloped (urban regeneration of the former Ellinikon airport and upgrading of the coastal front).
The Mall Athens, the first and largest shopping and leisure center in Greece.
The Golden Hall, an internationally renowned shopping and leisure center, which also houses the Athens Olympic Museum and the XPLORE family leisure center.
The Mediterranean Cosmos, the largest shopping and leisure center in Northern Greece.# Annual financial report for the year ended 31 December 2022

Sustainable Development

The Designer Outlet Athens, Greece’s premier designer outlet in Spata area.
The Marinas in Flisvos and Elliniko (Ag. Kosmas).
Office buildings.
Innovative residential complexes.

Sustainable Development Strategy

The Group has formulated a Sustainable Development Strategy for The Ellinikon project, that will also be tailored to the rest of the Group’s activities over the coming period. The Strategy, once fully integrated into its activities, will constitute an integral part of its business strategy, focusing on achieving the U.N. Sustainable Development Goals. The Strategy for The Ellinikon project was completed in 2021 and was approved by the Board of Directors in 2022. The Strategy consists of 3 main pillars, each of which has a broader target and individual focus areas:

Decarbonization: The goal is to transition to a zero-carbon economy across the entire spectrum of business activity (currently for The Ellinikon project) and to build resilience in a changing environment.
Circularity: A commitment to have a net zero impact on water consumption and waste management.
People and Prosperity: The goal is to create economic value, accelerate social well-being and engage people.

The Strategy was updated at the end of 2022 and will be submitted for approval by the Board of Directors within 2023.

Green Bond Framework

Since 2022, LAMDA Development has drafted and adopted the Green Bond Framework for the issuance of "green" bonds, in accordance with the Green Bond Principles (GBP), of the International Capital Market Association (ICMA), as revised in June 2021 with the aim to describe the use of bond proceeds and define the eligible categories of green investments as well as the evaluation and approval process. According to the Framework, the categories of eligible "green" investments, which will contribute towards specific environmental objectives, as well as towards the U.N Sustainable Development Goals (SDGs), are:

Sustainable buildings and redevelopment of sustainable urban outdoor spaces.
“Green” energy.
“Smart” cities and technologies.

The LAMDA Development Investment Committee is responsible for directing the raised funds towards investments of the above categories. More information is available on the website https://www.lamdadev.com/images/LD_Green-Bond- Framework_ENG.pdf.

Annual financial report for the year ended 31 December 2022 25

Sustainable Development Policy and Oversight

[ATHEX ESG Metric C-G4] Since 2021, a specific Sustainable Development Policy, approved by a BoD decision on July 16, 2021, is published on the website https://www.lamdadev.com. The Policy summarizes the Group's commitment to responsibly manage the economic, social and environmental impacts arising from all its activities to its stakeholders, as well as more broadly, to the economy, society and the natural environment, in order to reduce any negative impacts such as greenhouse gas emissions and to increase positive impacts, such as job creation, in the context of the United Nations Sustainable Development Goals. The Sustainable Development Policy covers the axes of environment, society and corporate governance. The Board of Directors is responsible for observing compliance with the Sustainable Development Policy and the stemming strategy. Moreover, towards the end of year 2022, a dedicated Sustainable Development Policy was drafted for The Ellinikon project, as well as a Sustainable Development Management Plan, in accordance with the Sustainable Development Policy. More information on specific initiatives, results and targets will be available in the Sustainable Development Report 2022.

Corporate Governance

[ATHEX ESG Metrics C-G1, C-G2] LAMDA Development S.A. fully complies with the applicable corporate governance legislation. In this context, and in accordance with the provisions of article 17 of Law 4706/2020 and article 4 of Decision 2/905/3.3.2021 of the Hellenic Capital Market Commission’s Board of Directors, the Company, following the 16.7.2021 decision of its Board of Directors, has adopted, and implements, the Hellenic Corporate Governance Code of the Hellenic Corporate Governance Council, with any deviations that will be explicitly referred in the Corporate Governance Statement, as included in the Annual Financial Report. To achieve its business objectives, a specific corporate governance system is implemented, through which command and control matters are managed. The BoD is the competent body that decides on all matters relating to the representation, administration, management and pursuit of LAMDA Development’s scope, in accordance with the relevant legislation, excluding all matters falling under the competence of the General Meeting of Shareholders to decide. The BoD, exercises effectively its leading role and manages all corporate affairs for the benefit of the Company and all shareholders, ensuring that the Management follows the corporate strategy. Mr. Anastasios Giannitsis is President of the BoD, and a non-executive member, and Mr. Odyssefs Athanasiou is the CEO. The BoD defines and/or allocates the responsibilities of the CEO and establishes a policy for identifying, avoiding and dealing with conflicts of interest between the Company interests and those of all employees and affiliated companies, within the meaning of article 32 of Law 4308/2014, the members of the BoD and its Committees, Directors and Executives, Consultants, Main Shareholders (hereinafter referred to as the "Liable") and any other persons who have a close personal relationship with the above, or legal persons over which they exercise significant influence. In 2022, the Board’s composition 10 consisted by 25% of women (compared to 23% 11 in 2021), 92% are non- executive members (same as 2021 levels), while 33% of the members are non-executive and independent members (compared to 31% in 2021). 83% of the members of the Board of Directors, have the necessary knowledge and skills on sustainable development topics and 92% on corporate governance topics (as of 25.11.2022).

The Sustainable Development Unit is responsible for managing the organization's impact on the economy, the environment and society. At the same time, it is responsible for informing the Board of Directors accordingly. During 2022, sustainable development topics were raised at the meetings of the Board of Directors, such as the approval of the Sustainable Development Strategy for The Ellinikon project and discussion for its further specialization in the Group's individual activities, as well as the approval of the

10 The Board composition for the reference year was recorded at 31.12 and is compared to the corresponding date of 2021, in the meantime the Company proceeded to small changes in the number of members by replacing some of them with others.
11 In 2021, the number of women on the Board of Directors (3 women out of 13 Board members) meets the criterion of 25% of the total number of members rounded up during the calculation, to the previous integer (25%*13=3.25. Therefore 3) referred to in Greek legislation. The discrepancy is due to the different way of calculating the ATHEX ESG Metric C-G1 (3/13%).

Annual financial report for the year ended 31 December 2022 26

establishment of the Sustainable Development Unit in the context of updating the Company's Internal Regulation of Operation. More information is included in the Corporate Governance Statement, within the Annual Financial Report, available on the website https://www.lamdadev.com.

Sustainable Development Unit

In 2022, the Sustainable Development Unit was established, reporting to the Operations Division 12 , with the following responsibilities:

The formulation of the Group's overall strategy proposed to the Senior Management in the areas of Environmental, Social of Sustainable Development as a key pillar of the investment strategy.
The setting and monitoring of key benchmarks, as well as the compliance with the procedures that will govern the group's operation based on the strategy and the supervisory guidelines and compliance rules of local and international bodies.
The coordination of initiatives and all related actions provided for by the ESG/Sustainability frameworks by all the group's financial instruments governed by the relevant principles.
The monitoring of best practices in the industry both in Greece and globally and the formulation of policies and the coordination of actions for the group's harmonization with the highest standards in this area.
The preparation and submission of reports (in cooperation with the respective divisions) to the competent bodies for the company's compliance with its regulatory obligations as well as the communication thereof to third parties.
The rating of the company in the Environmental and Social areas by relevant bodies (ESG rating) as and when deemed appropriate for either regulatory or investment purposes.
The initial assessment, in cooperation with other units of the Company, and submission of "green" investment proposals to the Investment Committee.
The keeping of the Green Bond Register.
The oversight and alignment of the subsidiaries' individual strategic sustainable development objectives with the Group's overall strategy.

Respectively, the responsibility for the implementation of the Sustainable Development programs lies with the individual Divisions in cooperation with the Sustainable Development Unit.

Stakeholder engagement and materiality analysis

[GRI 2-29, ATHEX ESG Metrics C-S1, C-G3] The Group communicates and interacts constantly with its stakeholders, who belong to either its internal or external environment. As key stakeholders are considered those entities, individuals or groups, that are influenced or can be affected by its operations. Continuous communication with its stakeholders, is key in creating mutual trust and seamless cooperation.# Annual financial report for the year ended 31 December 2022

2. Main non-financial risks

A Risk Management Unit has been established, with the main mission to contribute substantially to the development of a modern operational framework at every organizational level, for the identification, evaluation and management of the risks faced by the Group. The Risk Management Unit ensures that the risks assumed by the Units are in line with the risk-taking and tolerance limits, defined and established by the Top Management. The Risk Management Policy as well as the Risk Appetite Statement were formally approved by the BoD in December 2022 and are applied to the entire Group. The Group has identified risks and opportunities including those related to Sustainable Development issues and, in particular, in relation to compliance with regulatory requirements, the sustainable development goals that are set, as well as the ability to adapt and mitigate climate change. In addition, risks related to best Environmental Compliance, as also Health and Safety practices that may result in fines or sanctions issued by regulatory authorities are identified and managed. Other categories of non-financial risks that have been identified, are information security risks, strategic, management of archaeological findings and culture etc. When assessing the level of exposure to identified risks, in addition to the financial impact, reputational criteria, environmental and coexistence issues with communities that influence and are influenced by the Group’s activities, are also taken into consideration. The identification, recording and evaluation of risks and opportunities at Group level is carried out with the help of an electronic application that allows immediate information on all risk (or opportunity) elements, as well as on measures already taken, or actions in progress at any time. For The Ellinikon, a risk management process is implemented, in accordance with the principles described in the ISO 31000 standard, includes, in summary, the following stages:

1) Communication and consulting.
2) Definition of the object and the objectives.
3) Identification of risks.
4) Risk analysis.
5) Risk assessment.
6) Management (treatment).
7) Audit and review.

This process is followed to ensure that the approach is both systematic and effective. It is carried out in conjunction with the operational planning and includes the review and update of risks. The followed approach is top-down, starting from the highest seniority level, and vice-versa.

3. Environmental issues/Climate change

Environmental compliance

The shopping centers, as well as the Flisvos Marina, comply with the requirements of environmental legislation. Where required, they have approved Environmental Impact Studies and the necessary environmental permits have been issued. In addition, all the developments of the Elliniko – Agios Kosmas Metropolitan Pole (M.P.E.A.), comply with the applicable environmental legislation and the approved environmental terms issued, during the evaluation of the Environmental Impact Study (E.I.S.) of the Integrated Development Plan (I.D.P.), (2019), but also the environmental conditions and commitments arising from the individual projects within Elliniko. In the context of compliance with the applicable environmental legislation and the environmental framework, resulting from the approved environmental terms of the I.D.P. of the M.P.E.A. and the individual projects within the M.P.E.A., during 2022 the environmental permitting of 2 individual projects within the M.P.E.A. was completed, 3 Technical Environmental Studies (T.E.S.) were approved and 2 new Environmental Impact Studies (E.I.S.) were submitted for evaluation with regards to upcoming developments.

a) Climate change, air, noise and particulate matter pollution

Corporate policies and due diligence

By following a modern architectural design along with optimal functional uses and implementing sustainability strategies, the Group aims to ensure environmentally friendly operations for all projects in operation and under development, in the context of Sustainable Development. By taking into consideration climate and environmental factors during the design and construction of projects, the Group aims at the resilience and adaptation of its buildings to changing conditions. At the same time, it aims to protect air quality, as well as to control noise emissions from the operation of its existing and under- development properties. More specifically, in projects under construction and with regards to air pollutant and noise emissions management, an integrated Environmental Management System (EMS) is implemented, with the aim of reducing air pollutant concentrations and noise emissions. The main orientation, via these measures of air pollution and noise emissions management, is to ensure the health of employees, visitors and all parties involved. For the year 2022, the evaluation of the carbon footprint in accordance with the specifications of ISO 14064-1:2018 and the GHG Protocol was conducted, including direct and indirect greenhouse gas emissions, and is currently running a verification process of the results. The ultimate goal is to reduce the carbon footprint in all Group’s activities. In addition, in the context of green investments, LAMDA Development proceeded to the drafting of an agreement for the future transfer of shares, which concerns the acquisition of 20% of the share capital of R- Energy 1 Holdings, to which it has provided lending through a Convertible Bond Loan, that will yield the total of at least 50.1% of the company's shares within the next 3 years, with exclusive resources of the Green Bond 2022. R-Energy 1 Holdings S.A is an energy company with a portfolio of Renewable Energy Sources (RES) projects with a total capacity of 44 MW. The company has prepared a Business Plan for further expansion of the portfolio of RES projects by 140MW of capacity, which includes Solar AND Wind Power projects. These projects can directly secure "green" energy for the assets of LAMDA Development S.A. through Bilateral Energy Supply Contracts and will effectively contribute to the avoidance of CO2 emissions for the respective uses.

Shopping centers (Golden Hall, The Mall Athens, Mediterranean Cosmos, Designer Outlet Athens)

The shopping centers apply an EMS and are equipped with Building Management Systems (B.M.S.). Through the B.M.S., the energy consumption is monitored, and the operation of the installed systems is adjusted, aiming at optimal energy consumption, and ultimately maximizing the energy performance of buildings. The Designer Outlet Athens is also certified according to the ISO 14001:2015 with the aim of improving environmental performance. In each shopping center, environmental units have been created which, among other tasks, have the responsibility to monitor energy consumption. Also, in the context of managing and maximizing energy efficiency, the environmental unit undertakes corrective and preventive actions, aimed at reducing energy requirements. The same units monitor the application of management standards, in relation to energy consumption, on a daily basis.

Flisvos Marina

The Management of Flisvos Marina applies an EMS, in accordance with ISO 14001:2015, through which energy consumption is monitored, by taking corrective action where and when required. Respectively, through the EMS, the Marina aims at the systematic management and prevention of air and noise pollution in all its facilities, through specific actions, such as the annual noise measurements. Since 2016, Flisvos Marina has been preparing an energy footprint assessment report, in accordance with the international standard ISO14064-1:2018. In this way, the marina can, in a documented way, utilize the results of the relevant measurements, to implement a mitigation program for pollutants associated with its carbon footprint (CO2), which result from its activities.

The Ellinikon– Phase A

For the development of The Ellinikon, an environmentally friendly design approach is followed, with the aim to mitigate environmental impacts and adapt to climate change.# Environmental, Social, and Governance (ESG)

Environmental

Focusing on the Sustainable Development Strategy and in line with the Sustainable Development Policy, the Environmental Policy and the relevant EMS during the design and construction phase (as well as during the operation of the project), measures are taken for the proper use and consumption of energy, the reduction of embedded carbon during construction, the reduction of greenhouse gas emissions, as well as the dust and air pollution emissions, through a variety of actions. It is worth noting that in 2022, The Ellinikon’s EMS was certified according to ISO 14001:2015. In line with the European climate neutrality objectives, the project aims at maximizing energy efficiency and renewable energy sources use, by applying best practices and by closely monitoring the projects progress. In this context, and in collaboration with designers, contractors, and consultants, principles of sustainable development, bioclimatic design, efficient heating, ventilation, and air conditioning systems, smart building management systems (BMS) and lighting control, selection of sustainable materials resistant to time, with recycled content and a recorded carbon footprint, are incorporated. Moreover, advanced design models are used in the projects, for the simulation of energy behavior, natural lighting analysis and Life Cycle Analysis (LCA). At the same time, upon completion of the projects’ construction, commissioning services are provided by independent consultants, to verify the correct functioning of the building’s systems.

Outcomes of the above policies and non-financial key performance indicators

The full reopening of the shopping centers, the increase in the construction activities of The Ellinikon, the increase of visitors’ traffic at the marina and the addition of the Designer Outlet Athens to the investment portfolio, contributed to the increase of the total energy consumed for 2022.

[GRI 302-1] Energy consumption within the Group (MJ)

Energy consumption from non-renewable energy sources	2022
Natural gas	20,981,188.8
CNG	842.3
Diesel	2,709,521.3
Petrol	3,775,794.3
Total amount of energy consumed within the organization from non-renewable sources	27,467,346.7
Electricity consumption
Total amount of electricity consumed within the organization from non-renewable sources	103,872,290.2
Electricity consumption with Guarantees of origin	15,665,111.0
Total electricity consumption	119,537,401.2
Total energy consumed within the organization	147,004,747.9

Notes:
* The requirements of GRI 302-1b disclosure are met, given that there is no consumption of energy from renewable sources within the Group (based on GRI, guarantees of origin are not included in renewable energy consumption within the Group in disclosure 302-1).
* The requirements of GRI 302-1c disclosure are met given that there is no consumption of heating, cooling, or steam.
* The requirements of GRI 302-1d disclosure are met given that there is no sale of electricity, heating, cooling, or steam.
* For the calculation of the above figures, the methodology followed includes the collection of the Group's primary consumption data (e.g., kWh of electricity, liters of fuel, etc.) from relevant tariffs and meters and their conversion into MJ by multiplication using DEFRA UK conversion factors.
* Any variations in totals are due to rounding.

Annual financial report for the year ended 31 December 2022 30

[ATHEX ESG Metric C-E3] Energy consumption and production

	2022
Total amount of energy consumed (MWh)	40,835
Percentage of electricity consumed over the total energy consumption	81.3%
Percentage of energy consumed from renewable sources over the total energy consumption	10.7%
Total amount of energy produced (MWh)	0
Percentage of energy produced from renewable sources over the total energy consumption	0%

[GRI 305-1, GRI 305-2, ATHEX ESG Metrics C-E1, C-E2] Greenhouse Gas Emissions

	2022
Direct emissions - Scope 1 (tCO 2 e)	2,489.63
Biogenic emissions (tCO 2 e)	0
Indirect emissions - Scope 2 location-based (tCO 2 e)	13,946.69
Indirect emissions - Scope 2 market-based (tCO 2 e)	11,003.61
Total emissions - Scope 1 & Scope 2 location based (tCO 2 e)	16,436.32
Total emissions - Scope 1 & Scope 2 market based (tCO 2 e)	13,493.24

Notes:
* The disclosure requirements of GRI 305-1 d and 305-2 d cannot be met, as 2022 is the first year in which the Group proceeded with the calculation of emissions.
* The gases included in the calculations are CO2, CH4, N2O.
* The conversion factors used to calculate emissions were obtained from the most recent national emission inventory, from the reports of the Renewable Energy Sources and Guarantees of Origin Operator (DAPEEP), as well as from DEFRA UK (only for fugitive refrigerants). CH4 GWP = 25, N2O GWP = 265.
* The consolidation method used is that of "Operational Control".
* The methodology followed is that of the GHG Protocol.
* Emissions intensities, along with Scope 3 emissions, according to the requirements of ATHEX ESG disclosures C-E1, C-E2, GRI 305-3, GRI 305-4 will be available in the 2022 Sustainable Development Report.

b) Biodiversity, soil, resource efficiency

Corporate policies and due diligence

The Group aims to protect biodiversity and continuously improves its efforts to reduce its impacts on the fauna and flora in the areas where it operates, as well as to prevent the disruption of ecosystems and soil. Emphasis is placed mainly on projects which are expected to have a significant impact on existing ecosystems and relate to the regeneration and development of wider areas, such as Flisvos Marina and The Ellinikon. Respectively, the Group recognizes the importance of the sustainable use of raw materials and natural resources and the need to implement systems and practices that will reduce the use of materials during the operation of existing business units (Golden Hall, The Mall Athens, Mediterranean Cosmos, Designer Outlet Athens and Flisvos Marina), but also in new projects such as The Ellinikon.

Shopping centers (Golden Hall, The Mall Athens, Mediterranean Cosmos, Designer Outlet Athens)

Golden Hall started its operation in November 2008 and is centrally located on Kifissias Avenue in Athens, while The Mall Athens and Mediterranean Cosmos started operating in November and October 2005 in the Neratziotissa area, in Athens, and in Thermi, in Thessaloniki, respectively. Designer Outlet Athens started its operation in June 2011 in Spata, Attica and was incorporated in the Group in 2022. None of the above areas are designated as protected areas under current legislation or as areas with high biodiversity value, according to the United Nations Convention on Biological Diversity (1992). Its apprοach with regards to the sustainable use of raw and other materials, is reflected, on the one hand, in the application of the EMS in Golden Hall, The Annual financial report for the year ended 31 December 2022 31 Mall Athens, Mediterranean Cosmos and Designer Outlet Athens shopping centers, and in its Suppliers’ Code of Ethics on the other.

Flisvos Marina

Flisvos Marina develops various initiatives for the protection of biodiversity, although it is not located in or near protected areas or areas of high biodiversity value. For these purposes, the marina monitors various marine species that visit it, such as sea turtles, seals, and species of fish (mullet), although a complete record is not kept. For the protection of the marine ecosystem and the contribution to the protection of the environment, which constitutes a strategic goal of the marina, 2 special devices have been installed with a basket (Seabins) for the removal of sea microplastics and floating waste/waste, with the aim to maintain the marina’s water quality, while fishing is prohibited within the marina. Regarding the control of water quality, 8 samplings are carried out from various points and depths of the port during the year in collaboration with a specialized accredited laboratory.

The Ellinikon – Phase A

For the development of The Ellinikon, the Group is committed to the protection of biodiversity and the protection and improvement of the soil. In cases of building and infrastructure demolition, before the entry of the machinery, the species of fauna are investigated, located and removed. These species, after being tested by biologists, are released into natural ecosystems. The conservation and restoration of the existing soils in the project and the wider area of the of the Elliniko Metropolitan Pole, is in line with the recent recognition of healthy soil as a valuable commodity and component of local Mediterranean ecosystems, according to the European Green Deal. More specifically, the design of the sections of the Metropolitan Park, including the first part of the park “The Experience Park”, was designed to meet the requirements of international certification systems, such as the “Sustainable SITES Initiative” certification, which includes special requirements regarding biodiversity, soil conservation and enhancement and sustainable conservation of the site. Goals are already set from the design phase of the project, for the preservation of the existing natural areas (soils and plantations), and the environmental restoration, and enrichment of the damaged areas in terms of biodiversity. 2022 was the first full year of operation (official opening 20/12/2021) of "The Experience Park", a new urban park covering an area of 75 acres within The Ellinikon. The basic principles were sustainable development and respect for the environment and the heritage of the area. The soil was enriched, in line with a special study, to make it more fertile and better support the planted surfaces. Plants and trees remained in place, where possible, and were supplemented with new or transplanted native plants. About 700 trees and over 77,000 plants were put in place, in total, within the project.# Annual financial report for the year ended 31 December 2022 32

c) Environmental management

Transplanting – New plantings

The overall objective of The Ellinikon is the implementation of the "Biodiversity Net Gain" practice. In particular, within the Metropolitan Park, the planning includes the addition of more than 31,000 new trees of 59 species, of which more than 14,000 will be planted in Phase A of the project. A wide range of different species of trees and plants is included, so that the design enhances the biodiversity of the project, to complement the ecosystem of the wider area of Elliniko and constitute a potential fauna refuge. At the same time, an effort is made to maintain or transplant existing healthy trees. In collaboration with specialized green engineering companies and Greek nurseries, temporary spaces have been created within The Ellinikon, hosting 2,100 with the prospect of reaching more than 3,000 existing trees, which will be protected until they are gradually transplanted into the Metropolitan Park and public areas.

Reuse of materials and soils

Regarding the sustainable use of raw materials and other materials, the Group aims to design projects in accordance with international sustainable development certification systems, such as "LEED" (Leadership in Energy and Environmental Design) for buildings and SITES for outdoor landscape configurations, which include specific requirements for product, supplier and raw material selection methods, aiming at saving resources and the circular economy. In the context of achieving the above certifications, there are prerequisites and objectives regarding the appropriate selection and use of materials with environmentally friendly properties, while, among other things, significant opportunities are created for the reuse of existing materials. The project prioritizes the use of materials with recycled content, mined and produced within a close range. At the same time, the selection of materials is based on whether there is a record of their environmental footprint.

Rehabilitation and decontamination

In 2022, works began, over the entire project, to restore soils and groundwater, burdened with pollutants from previous uses of the site (former airport location, military installations, etc.). As part of the restoration and decontamination works, old infrastructures and fuel installations are removed, while contaminated soils and groundwater are cleaned up using "in-situ" methods. The aim is to reduce the waste generated, to minimize transport inside and outside the pole and, finally, to reuse the soil.

Outcomes of the above policies and non-financial key performance indicators

[ATHEX ESG Metric A-E5] In the context of the Environmental Impact Studies that have been carried out for the construction of the shopping centers (including XPLORE and the Athens Olympic Museum located at the Golden Hall premises) and the Environmental Impact Assessment that has been submitted and approved for the development of The Ellinikon, none of the above areas are characterized as protected areas according to current legislation or as areas of high biodiversity value, in accordance with the United Nations Convention on Biological Diversity (1992). Specifically, the three malls do not record any impact from their activities of any nature, including the reduction of fauna and flora species in the area, changes in ecological processes, introduction of pathogens and insects. Subsequently, for Flisvos Marina, no significant direct or indirect impacts have been identified from its respective activities on the biodiversity of the area and the soil quality.

[GRI 301-1] Materials used (tones)

	2022	2021	2020
Total non-renewable materials used	39,340.8	85.2	100.2
Total renewable materials used	0	0	0
Total materials used	39,340.8	85.2	100.2

Notes:
* For The Mall Athens, there is no information available for the total quantities of incoming used materials, information that the Group intends to gather in the coming years. Accordingly, relevant information has been partially provided for the Golden Hall.
* The large increase in materials used observed, compared to 2021, is due to the start of construction works of The Ellinikon.

[GRI 301-2] Incoming recycled materials used (percentage)

	2022	2021	2020
Recycled materials used	3.2%	0.3%	0.3%

Notes:
* For Golden Hall, The Mall Athens, Mediterranean Cosmos, as well as the Designer Outlet Athens, there is no information available for recycled and non-recycled materials, information that the Group intends to gather in the coming years.
* The large increase in the use of materials observed compared to 2021 is due to the start of construction works of The Ellinikon.

Annual financial report for the year ended 31 December 2022 33

c) Water, wastewater and solid waste

Corporate policies and due diligence

[ATHEX ESG Metric SS-E4] In the context of the Group’s commitment to environmental protection, the sustainable use of water resources, the proper management of solid waste, the promotion of recycling, and the application of the principles of the circular economy, constitute a daily reality for the shopping centers, Flisvos Marina, as well as for new projects, such as The Ellinikon.

Shopping centers (Golden Hall, The Mall Athens, Mediterranean Cosmos, Designer Outlet Athens)

At Golden Hall, The Mall Athens, the Mediterranean Cosmos, and the Designer Outlet Athens, a complete EMS has been set in place, with the aim to reduce production and proper treatment of solid waste, thus ensuring the Group’s commitment to reduce the negative impacts of waste and protect the environment. The main objectives of the above system are:
* The minimization of solid waste generated in the shopping centers.
* The separation at the source of recyclable waste, as well as those that need specific management.
* The maximization of the percentage of waste made available for recycling.
* The ongoing compliance with current solid waste provisions in force.

The integrated waste management system includes the following basic procedures for shopping centers:
* Separation of the waste streams at the source (packaging materials, glass, plastic, paper, inorganic waste).
* Special area for the temporary storage of non-recyclable solid waste, including the temporary cold storage of organic waste.
* Availability of predetermined waste storage areas.
* Collaboration with specialized solid waste management and treatment companies, where the collection of recycling materials is carried out by specialized contractors, with the aim of their separation and controlled disposal.
* Emergency preparedness and response procedure in case of hazardous waste leakage.
* Recording of waste data in the Electronic Waste Register of the Ministry of Environment and Energy.

The Group’s approach to the management of water and wastewater has, as its main pillar, the optimization of water use in shopping centers by installing mechanisms and devices of water saving by connecting with the municipal sewerage networks for the channeling of the generated urban wastewater. In particular, in the Designer Outlet Athens, an urban wastewater treatment plant is in operation for the use of treated water for watering purposes, and thus reducing the use of drinking water by the municipal water supply network. The purpose of these initiatives is to minimize the impact on biodiversity and the available natural water sources in the areas, where it operates.

Flisvos Marina

The marina directs all waste generated from both its own activity and from the activities of its customers (boats and lessees) for management/recycling to licensed operators. For this purpose, it collects the waste generated by its customers and from its operation and delivers it to licensed waste management operators, for their further treatment. Furthermore, since July 2020 13 , an outdoor composting unit has been operating for the treatment of green waste from its gardens (branches, lawns, leaves, etc.) and coffee residues from the shops located in its area. Municipal waste and recyclable materials are collected in specially marked bins and, under the responsibility of the Municipality, are taken to landfills. Also, the marina manages the solid waste resulting from pollutants, through the installation of a floating dam on the piers where the rainwater pipes end.

13 In the Sustainable Development Report 2021 it has been inadvertently reported that the outdoor composting plant has been operating since 2010.

Annual financial report for the year ended 31 December 2022 34

Regarding water use, the water supply in Flisvos Marina is provided by the network of EYDAP and concerns the coverage of the irrigation needs of the marina's outdoor areas, the service of the employees, the visitors, and the boats as well as the cleaning of the outdoor areas, piers and common areas in its commercial sections. To save water, best practices of rational use have been adopted, while regular maintenance of the water supply network is carried out for the immediate detection of leaks. Moreover, the watering of greenery, over an area of 25 acres, is carried out through automatic watering programmers. The purpose of this action is to better control the water consumption for the watering needs of outdoor gardens, as well as its remote management, in order for watering to be adjusted according to weather conditions. In this way, more rational use and saving in water consumption is achieved. Urban wastewater is collected and diverted to the central sewer system of EYDAP. Other types of waste (such as mineral oil mixtures, waste lubricating oils, etc.) generated from the use of vessels are managed by external collaborators. Flisvos Marina has entered into a contract with a company specialized in dealing with marine pollution emergencies, thus ensuring immediate response 24 hours a day, 7 days a week, and the availability of an anti-pollution boat with a crew.# The Ellinikon – Phase A

For the development of The Ellinikon, the certified, according to ISO 14001, EMS, that is followed, includes procedures for the management of solid and liquid waste, as well as water, which aim at the rational management and protection of natural resources. The Group implements an environmentally friendly waste management planning, in line with the approved Environmental Conditions. At the same time, it sets the objectives and plans for the majority of The Ellinikon’s project, within the framework of international certification systems for sustainable development, such as “LEED”, which include the development and implementation of a Construction and Demolition Waste Management Plan, aiming at recycling at least 75% of construction and demolition waste.

The fundamental principles of the project waste management system are:

Separation at the source of waste streams (collection in 6 separate bins) during operation, which will be managed by the Solid Waste Management Facility (SWMF), that will be created in The Ellinikon during the operation phase of the project.
Minimization of the percentage of waste disposed in landfills both during construction and during the operation phase.
Reuse, recycling, and recovery of construction waste, reducing the percentage that ends up in landfills and optimal use of demolition materials and methods.
Management of hazardous waste, in cooperation with licensed operators, in accordance with legislation requirements.
Recording of waste and their management, during the construction and operation phase.

The reuse of materials constitutes a priority throughout the design of the project. The demolition materials are kept and temporarily stored within the Metropolitan Pole so that they can be used in their entirety in future works. At the same time, the excavation materials are also kept and temporarily stored.

Regarding water use, during the construction and operation phase, the implementation of a Unified Water Management Plan is foreseen, which includes a Water Saving Program and a Water Contamination Protection Program. The potential impacts on the quality of natural resources are analyzed in the Environmental Impact Study. At the same time, within the framework of the international certification systems for sustainable development that are followed in the project, such as LEED, WELL, SITES, etc., specific objectives are put in place for the reduction of water consumption inside the buildings, through the installation of taps with reduced consumption, as well as outside the buildings, through the installation of smart irrigation systems and the selection of plants with reduced irrigation needs, the reuse of treated water or rainwater, rainwater management and water quality assurance.

In the context of circular economy, a Sewage Treatment Plant (WWTP) is designed inside The Ellinikon, which will produce, with proper treatment, irrigation water for the needs of the Metropolitan Park. In July 2022, a relevant Memorandum of Understanding was signed between the Group (through its subsidiary HELLINIKON S.M.S.A.) and EYDAP concerning the supervision of the construction of water supply projects, sewerage and treatment water production installation. At the same time, the planning of the upgrade of the Trahones stream has initiated. The new projects in the area of Trahones include:

the maintenance of the existing culvert up to Poseidonos Avenue by cleaning and maintaining its basin,
the new section, more than 1km long, that will cross through the Metropolitan Park, creating wetland conditions of flowing waters, while significantly improving the overall drainage capacity of the stream.

Outcomes of the above policies and non-financial key performance indicators

The complete reopening of the shopping centers, the increase in the construction activities of The Ellinikon, the increase of visitors traffic at the marina and the addition of the Designer Outlet Athens to the investment portfolio, contributed to the more than doubling of water consumption.

[GRI 303-3] Total water withdrawal (ML)

Water source	2022		2021		2020
	All areas	Areas with water stress	All areas	Areas with water stress	All areas	Areas with water stress
Total surface water	0	0	0	0	0	0
Freshwater	0	0	0	0	0	0
Other water	0	0	0	0	0	0
Total ground water	101.7	67.9	75.0
Freshwater	0	0	0	0	0	0
Other water	101.7	67.9	75.0
Total seawater	0	0	0	0	0	0
Freshwater	0	0	0	0	0	0
Other water	0	0	0	0	0	0
Total produced water	0	0	0	0	0	0
Freshwater	0	0	0	0	0	0
Other water	0	0	0	0	0	0
Total third-party water (network)	427.0	154.0	145.2
Freshwater	427.0	154.0	145.2
Other water	0	0	0	0	0	0
Total third-party water withdrawal per water source
Surface water	Not available
Ground water
Seawater
Produced water
Total water withdrawal	528.7	221.9	220.1

The areas in which the Group operates, are characterized as areas that are under increased pressure in terms of water resources according to Aqueduct Water Risk Atlas of the World Resources Institute.
According to the GRI freshwater is defined as: ≤1,000 mg/L total dissolved solids, other water >1,000 mg/L total dissolved solids.
The above data were collected from invoices and direct measurements of the Group's water consumption from the local water supply networks and drilling facilities. No standard or methodology has been followed beyond direct recording and no relevant assumption has been made.

[GRI 303-5] Total water consumption (ML)

	2022	2021	2020
Total water consumption	528.7	221.9	220.1
Total water consumption in areas with water stress

Due to inability to collect water discharge data (GRI 303-4), consumption is considered equal to withdrawal (GRI 303-3) whose data were collected from the Group's invoices and direct water reclamation measurements from the local water supply networks and drilling facilities. No standard or methodology has been followed beyond direct recording and no relevant assumption has been made.
The requirements of the disclosure GRI 303-5 b have been met, as the areas in which the Group operates, are characterized as areas that are under increased pressure in terms of water resources according to Aqueduct Water Risk Atlas of the World Resources Institute.

The increase in construction works at The Ellinikon results in an increase in waste generation. However, due to the very high rates of reuse, recycling and recovery of the waste generated on site, the final disposal of waste is prevented. Detailed data will be available in the 2022 Sustainable Development Report.

[GRI 306-3] Total waste generated (t)

Waste categories	2022	2021	2020
Hazardous Waste
Antifreeze liquids	16 01 14*	0	0.7
Other fuels (including mixtures)	13 07 03*	28.9	0
Wastes not otherwise specified	13 08 99*	0	3.4
Used batteries	16 06 01*	0	0.8
Waste of lubricating oil mixtures and collector oils	13 02 05, 13 04 01, 13 05 06*	43.6	55.4
Contaminated absorbent materials	15 02 02*	10.4	2.3
Waste paint and varnish containing organic solvents or other dangerous substances	08 01 11*	0.5	4.7
Depleted oil and air filters	16 01 07*	18.5	0.7
Fluorescent lamps	20 01 21*	9.6	1.2
Waste from electrical and electronic equipment	20 02 21, 16 02 11, 20 01 35, 20 01 23	1.5	1.3
Contaminated packaging	15 01 10*	1.7	3.0
Mixed batteries	20 01 33*	0.6	0.2
Waste printing toner containing dangerous substances	08 03 17*	0	0.1
Waste blasting material containing dangerous substances	12 01 16*	0	7.6
Chlorofluorocarbons, HCFC, HFC	14 06 01*	0	0.0
Organic wastes containing dangerous substances	16 03 05*	1.6	0.5
Gases in pressure containers (including halons) containing dangerous substances	16 05 04*	1.5	1.1
Discarded inorganic chemicals consisting of or containing dangerous substances	16 05 07*	0.0	5.5
Discarded organic chemicals consisting of or containing dangerous substances	16 05 08*	0.7	3.0
Soil and stones containing dangerous substances	17 05 03*	12,212.0	0.7
Insulation materials containing asbestos	17 06 01*	0	0.8
Construction materials containing asbestos	17 06 05*	0	65.2
Petroleum waste	13 04 03, 13 05 07, 13 03 10, 16 07 08, 13 05 08*	262.5	73.2
Total hazardous waste	12,593.4	230.7	121.0
Non-hazardous Waste
Organic wastes	16 03 06	17.8	10.9
Mixed municipal waste	20 03 01	21,290.9	15,498.4
Metals and metal packaging	15 01 04, 17 04 01, 17 04 02, 17 04 05, 17 04 07, 20 01 40	11,673.5	1,459.5
Plastic and plastic packaging	15 01 02, 20 01 39	464.8	224.3
Paper and cardboard packaging	15 01 01	803.3	575.2
Wood and wooden packaging	15 01 03, 17 02 01, 20 01 38	14.4	79.3
Glass packaging	15 01 07	32.1	6.7
Mixed batteries	16 06 04, 16 06 05, 20 01 34	0.2	0
Construction and demolition waste	17 01 07, 17 09 04	60,948.2	5,454.1
Disposable electrical and electronic equipment	20 01 36	18.7	0.6
Glass	20 01 02	12.1	11.0
Biodegradable waste	20 02 01	712.8	52.6
Cables	17 04 11	0	72.9
Soil and stones	20 02 02	11,485.1	37.0
Edible oils and fats	20 01 25	39.3	19.3
Sludges from on-site effluent treatment	07 01 12	0.6	0
Total non-hazardous waste	107,513.7	23,501.9	8,757.6
Total waste	120,107.0	23,732.5	8,878.6

The above information was collected from shipping notes and invoices of certified external partners who undertake the Group's waste management, monthly reports of partners-contractors as well as annual EMA reports of the Group.
The above information was adjusted for the years 2021 and 2020, as had been mentioned in the Sustainable Development Report 2021, as the more complete record of waste was completed.# GRI 306-4 Waste diverted from disposal per recovery process (t)

Waste categories and recovery process	2022			2021			2020
	Onsite	Offsite	Total	Onsite	Offsite	Total	Onsite	Offsite	Total
Hazardous waste
Preparation for reuse	0	0	0	0	0	0	0	0	0
Recycling	0	12,593.4	12,593.4	-	230.7	230.7	0	121.0	121.0
Composting	0	0	0	0	0	0	0	0	0
Total	0	12,593.4	12,593.4	0	230.7	230.7	0	121.0	121.0
Non-hazardous waste
Preparation for reuse	72,433.3	0	72,433.3	3,021.0	0	3,021.0	0	0	0
Recycling	0	13,058.3	13,058.3	0	4,961.0	4,961.0	0	836.1	836.1
Composting	16.8	696.0	712.8	10.5	0	10.5	3.2	-	3.2
Total	72,450.1	13,754.3	86,204.4	3,031.5	4,961.0	7,992.5	3.2	836.1	839.3

GRI 306-5 Waste directed to disposal per disposal process (t)

Waste categories and disposal process	2022			2021			2020
	Onsite	Offsite	Total	Onsite	Offsite	Total	Onsite	Offsite	Total
Hazardous waste
Landfill / Total	0	0	0	0	0	0	0	0	0
Non-hazardous waste
Landfill / Total	0	21,309.6	21,309.6	0	15,509.3	15,509.3	0	7,918.3	7,918.3

Notes:
* The above information was collected from shipping notes and invoices of certified external partners who undertake the Group's waste management, monthly reports of partners-contractors as well as annual EMA reports of the Group.
* The above information was adjusted for the years 2021 and 2020, as had been mentioned in the Sustainable Development Report 2021, as the more complete record of waste was completed.
* The requirements of disclosure GRI 306-5 b and c are met, as the Group does not have hazardous or non-hazardous waste for incineration or other methods of final disposal, other than landfilling.

Annual financial report for the year ended 31 December 2022 38

[ATHEX ESG A-E3] Waste management

	2022	2021	2020
Total amount of hazardous waste generated (t)	12,593.4	230.7	121.0
Total amount of non-hazardous waste generated (t)	107,513.7	23,501.9	8,757.6
Total amount of waste generated (t)	120,107.0	23,732.5	8,878.6
Percentage of waste directed to recycling/reuse	81.7%	34.6%	10.8%
Percentage of waste directed to composting	0.6%	0.0%	0.0%
Percentage of waste directed to landfill	17.7%	65.4%	89.2%

Note: Any variations in the totals are due to rounding.

d) International building certifications (The Ellinikon)

Corporate policies and due diligence

All of The Ellinikon's developments holistically follow the highest standards of sustainable development both in design, construction and operation. All commercial developments during Phase A of the project, as well as most residencies, aim at an international “LEED” sustainable development certification. At the same time, the certification of individual projects with the international “WELL” and “SITES” certifications is promoted, aiming at the users’ health and well-being and the development of sustainable outdoor spaces.

During 2022, 13 building registrations were submitted to the U.S. Green Building Council certification body for the application of the international sustainable development certification "LEED", including:

The Riviera Tower, 200 meters high, with 169 apartments on 50 floors, which, upon its completion, will be the tallest building in Greece. Its study and design have been entrusted to the internationally renowned award-winning architectural firm Foster+Partners. A key feature of the design approach is the creation of a landmark building, in full harmony with the sea and the special features of the mediterranean landscape with a bioclimatic character. Riviera Tower, by fully integrating sustainable development strategies, is the 1st residential building in Greece to be pre-certified according to the LEED sustainable buildings standard at Gold level, in June 2022.
The Relocation Building of Associations of People with Disabilities will house the services of Day Care Centers (DCC) and Lifelong Learning Centers (LLC), of 4 associations for children and adults with disability and special skills. The construction of the project began in 2022 and within the same year the evaluation of the design of the complex by the certification body of the LEED standard was completed. The final LEED certification of the project is expected in 2023.
The Riviera Galleria will have shops, dining areas and venues for cultural and recreational events. The internationally renowned architectural firm Kengo Kuma and Associates, in collaboration with BETAPLAN, designs the Riviera Galleria, aiming to become an architectural reference point in the new marina of Agios Kosmas and a pole of attraction for visitors from Greece and around the world. The Riviera Galleria follows high standards of sustainable design and is the 1st commercial complex to be pre-certified according to the LEED sustainable building standard at Gold level, in December 2022.

At the same time, it is worth noting that The Ellinikon Metropolitan Park follows high standards of sustainable development, as a whole. At the same time, it aims at reusing existing materials, prioritizing materials with domestic characteristics, as well as absorbing large amounts of atmospheric carbon through the new plantings that will be carried out.

In August 2022, the Group proceeded to agreements with Lafarge Beton, a member of HERACLES Group, and with TITAN Group for the installation and operation of a ready-mix concrete production unit to serve the needs of the project. The units will adhere to high standards of environmental management and provide low-carbon concrete products for The Ellinikon's construction works.

Annual financial report for the year ended 31 December 2022 39

4. Social and labour issues

a) Labour issues

Corporate policies and due diligence

Employment

The Group recognizes that its business success is based on its people. Considering that employees are the most important asset, the Group recognizes and rewards their valuable contribution to its development and positive course. Therefore, it is of particular importance to improve management of human resources and the Group, in a sustainable way to provide the best possible work environment and experience for all employees. For this reason, strategies of attracting, developing, and retaining human resources are followed, while providing equal opportunities to all. Within this framework, the following policies, codes and regulations, have been created:

Car and Fuel Policy.
Code of Conduct.
Employees’ Training and Development Policy.
Expenses Policy.
Internal Announcement and Coverage of New Jobs Policy.
Internal Regulation of Operation.
Mobile Phone Policy.
Performance Evaluation Policy.
Procurement Policy.
Recruitment Policy and Procedure.
Suppliers’ Code of Ethics.
Sustainable Development Policy.
Travel Policy.
Whistleblowing Policy.
Workplace non-discrimination, anti-harassment and violence prevention Policy.

GRI 401-2

The Group supports its people in their learning, development, mobility, and achieving their goals. It implements development training programs, in which all employees can participate to meet their training needs, improve their skills, their continuous professional development and their ability to better respond to the fulfillment of Group's objectives. It is interested in informing employees, improving inter-company communication, their satisfaction and strengthening the corporate culture.

Several additional financial and social benefits and programs are offered to the employees and their families, not only as a reward for their good performance, but also to enhance and strengthen the sense of job security. The benefits offered indicatively to employees in Greece are:

Performance-based bonus.
Special stock option program for senior and senior executives.
Medical and pharmaceutical health and insurance program.
Corporate car and a fuel card to the members of the Management and to those executives who have the right to grant, from the hierarchical level of their position or the description of their role (duties). Consulting services program and special retirement plan.
Provision of meal vouchers.
Mobile phone/tablet to facilitate employees in carrying out their work.
Grant of interest-free loans to employees to cover serious emergencies.
Additional days of maternity leave.
Additional days of educational leave for those attending postgraduate studies.
Rewarding gifts for excellent students for the children of employees.
Gifts to the employees’ children at Christmas.
Gifts to employees at Christmas and Easter.
Wedding gift.
Gift of having a child.
Reward gift for many years of presence.
Discounts at the Company's shopping centers.
Occupational prevention for health and safety.

Annual financial report for the year ended 31 December 2022 40

Employee Assistance Programs, which concern the “It's up to You” program (psychological support line and sessions).

The above benefits are addressed to permanent contract employees, under full-time and part-time employment (except for the provision of stock options), based on specific criteria, such as the nature of the work, the employment area, the expertise of the employee and the level of each job position. Moreover, based on the above criteria, as well as on the individual performance of each employee and the results of the Group, additional variable pay systems are applied. Fixed-term employees benefit from the medical and pharmaceutical program, as well as the meal vouchers.# Training and skills development of the future

The Group is actively interested in informing and training employees, improving intra-corporate communication, ensuring employee satisfaction and strengthening corporate culture. In this context, policies have been established relating to the Internal Regulation of Operation and the Employee Education/Training program. The training program is formulated on an annual basis and is part of the annual budget, aligned with the strategy and objectives of the Group, as well as the needs arising from the annual employee evaluation process. Moreover, the Human Resources Department can receive a request/proposal for training from any employee, following the consent of his/her Manager. It is noted that there is no differentiation in the provision of educational programs, for example in terms of employees’ gender.

Health, safety and well-being

The Group recognizes its responsibility to ensure health and safety throughout its value chain, as well as to promote well-being and work-life balance. For this reason, it carries out a set of actions related to health, safety and well-being for all its employees, as well as for all those affected by its activities and operation. The Group is aware and promotes the improvement of the health and wellbeing of its employees, offering them the opportunity to have a complete package of private insurance and additional consulting support services (see above for the benefits list). Moreover, annual training programs on occupational health and safety, are covered by the Group, as well as regular safety drills for the event of earthquakes, fires and other threats in all shopping malls, while all employees have attended threat seminars. The training programs, the exercises and seminars are regularly monitored by the health and safety officer. Systematic measurements are carried out on air quality, noise level and appropriateness of lighting in its facilities, while an evacuation plan has been drawn up and dedicated teams have been set up by employees responsible for the implementation of the plan. Training is carried out in the shopping centers on an annual basis by a certified training organization on first aid as well as in the use of a defibrillator. Respectively, in The Ellinikon the corresponding training is carried out in the emergency teams. Shopping centers are prepared for all possible crisis scenarios, while a dedicated security company is responsible for safety matters. In addition, regular safety drills for earthquakes, fires and other threats are performed in all shopping malls, while all employees have attended threat response seminars. Cases of risk cases and data evaluation are included in the Crisis Manual. The Group takes corrective action to ensure and, where necessary, reduce health and safety risks. In this context, strict specifications apply on the installation of filter arrays in the ventilation systems, minimizing the burden of air quality within the stores of sanitary interest located within Golden Hall, The Mall Athens and Mediterranean Cosmos shopping centers. In addition, the relevant provision for the newly acquired Designer Outlet Athens shopping center is being examined. The air quality in the underground parking lots of the shopping centers is constantly monitored with a special automatic installation, so that the air is kept at a constant permissible level. Respectively, in Flisvos Marina, as well as in the Designer Outlet Athens, an Occupational Health and Safety Management System is implemented, certified according to ISO 45001:2018, though which all existing and potential risks to Occupational Health and Safety are tentatively identified, and establishes measures for eliminating, reducing, or controlling them. Furthermore, for The Ellinikon, during Phase A of the project’s implementation, an Anthropocentric Integrated Health and Safety Management System has been developed, which approaches holistically all Health and Safety issues and was designed taking into consideration international standards and encompasses a variety of internal mechanisms and procedures for managing and controlling effectiveness. Compliance with all the Health and Safety Management System requirements constitutes a contractual obligation for all parties involved in the development of The Ellinikon, even if those requirements are stricter than those foreseen by national and European legislation. The Health and Safety Management System was certified in 2022 according to ISO 45001:2018. During 2022, the implementation of protection measures against the COVID-19 pandemic continued, in accordance with the instructions provided by the National Public Health Organization (NPHO). A strong recommendation was given to all employees to use a mask in public areas, elevators and workplaces where there was overcrowding, while at the same time employees who were in contact with the general public were given a self/rapid antigen test for weekly use. In case of contact with a case, the instructions of NPHO were followed. In addition, concerning office employees, measures were implemented to avoid overcrowding both in business meetings attended physically, as well as in the restaurant of the office headquarters.

Outcomes of the above policies and non-financial key performance indicators [GRI 2-7, GRI 2-30, ATHEX ESG Metrics C-S2, C-S7]

The increase in the employees’ number in 2022 compared to 2021 is due to the design and construction works at The Ellinikon, the opening of The Experience Park, as well as to the increase in central services that provide support to all LAMDA Development’s subsidiaries. Female employees constituted 52.2% of the workforce. To calculate the number of employees, the "headcount" methodology was applied on 31.12 of the respective year, while all employees with an employment contract were included in the count. 100% of the employees are covered by the National Collective Labor Agreement.

Employees

	2022			2021			2020
	Women	Men	Total	Women	Men	Total	Women	Men	Total
Number of employees (Total)	343	314	657	284	260	544	210	199	409
Number of permanent employees	336	308	644	268	253	521	201	188	389
Number of temporary employees	7	6	13	16	7	23	9	11	20
Number of non-guaranteed hours employees	0	0	0	0	0	0	0	0	0
Number of full-time employees	322	307	629	265	259	524	202	198	400
Number of part-time employees	21	7	28	19	1	20	8	1	9

Note: Employees from Designer Outlet Athens are not included, as their absorption took place on 01.01.2023 and have therefore been included in the workers who are not employees.

Employees by region

	2022			2021			2020
	Women	Men	Total	Women	Men	Total	Women	Men	Total
Attica	332	303	635	271	249	520	198	188	386
Rest of Greece	8	10	18	9	10	19	10	10	20
Activities abroad	3	1	4	4	1	5	2	1	3

Employees by function

	2022
	Women	Men	Total
Shopping centers (Golden Hall, The Mall Athens, Mediterranean Cosmos)	102	72	174
The Ellinikon (including Agios Kosmas Marina)	161	140	301
Flisvos Marina	11	28	39
Head offices	66	73	139
Αctivities abroad	3	1	4

Note: The number of employees per function for the years 2020 and 2021 is not available.

Workers who are not employees [GRI 2-8]

For 2022, 1,073 workers in the investment properties were not employees. In particular:
* the majority of those are employed by The Ellinikon and concern employees of the contractors who have undertaken the construction works,
* there are employees of consulting companies with which the Group has business relationships and are employed in its premises,
* the Group’s headquarters and shopping centers employ cleaning crews and security employees.

For the calculation of workers who are not employees, the methodology "headcount as an average across the reporting period" was applied.

	2022
	Women	Men	Total
Shopping centers (Golden Hall, The Mall Athens, Mediterranean Cosmos)	153	218	371
Designer Outlet Athens	13	26	39
Flisvos Marina	6	50	56
Head offices & The Ellinikon (including Agios Kosmas Marina)	164	443	607
Activities abroad	Not available	Not available	Not available

Note: The number of workers who are not employees for the years 2020 and 2021 is not available.

New employee hires and employee turnover [GRI 401-1]

	2022 Total	<30 years old			30-50 years old			>50 years old
		Women	Men	Total	Women	Men	Total	Women	Men	Total
Number of employees	105	43	148	205	202	407	33	69	102
Number of new employee hires (#)	73	26	99	35	50	85	5	8	13
Rate of new employee hires (%)	70	60	67	17	25	21	15	12	13
Number of employee turnover (#)	27	5	32	11	15	26	6	2	8
Rate of employee turnover (%)	26	12	22	5	7	6	18	3	8

Note: The change in voluntary turnover is mainly due to activities that show frequent staff turnover at young ages. The indicator of non-voluntary turnover decreased in 2022, mainly due to the improvement in the provision of appropriate training and the integration of processes leading to an increase in skills and adaptation and productivity of employees.

Employee Turnover	2022	2021	2020
Voluntary turnover rate	6.5%	4.9%	3.1%
Involuntary turnover rate	1.5%	3.7%	1.8%

CEO-employees compensation ratio [GRI 2-21, ΑΤΗΕΧ ESG Metric A-S4]

The CEO-employees compensation ratio is defined as the difference between the annual total remuneration of the CEO and the average value (median) of the total remuneration of the employees in Greece (except for the remuneration of the CEO). For the 2022 reporting period, the above ratio was 38.7:1.

Variable pay [ATHEX ESG Metric A-G4]

Variable pay for 2022 stood at 46% of the total, showing a small decrease compared to 2021 (51%). For the calculation of variable pay 14 , the corporate bonus scheme plus long-term incentive scheme was used, which includes the remuneration of all workforce, including the CEO remuneration.# Annual financial report for the year ended 31 December 2022

Variable pay

	2022	2021	2020
46%	51%	25%

[GRI 404-1] The training hours of employees increased due to the increase in the number of employees. Also, training expenditure showed a slight increase compared to the previous year, despite the relatively larger increase in training hours, due to the use of in-house trainers and e-learnings.

Average training hours per employee	2022			2021
	Men	Women	Total	Men	Women	Total
Total training hours	3,830	4,198	8,028	2,735	3,508	6,243
Average training hours	12.2	12.2	12.2	10.5	12.4	11.5

14 The percentage of variable pay is calculated as the ratio of the amount of variable remuneration to the total of all types of remuneration received by the Group’s employees during the reporting period.

[ATHEX ESG Metric C-S5] Average training hours based on hierarchy and total compensation

	2022	2021
Total number of training hours provided to each employee in the top 10% of employees by total compensation	640	550
Total number of employees included in the top 10% of employees by total compensation	66	54
Average training hours (top 10% of employees by total compensation)	9.7	10.2
Total number of training hours provided to each employee in the bottom 90% of employees by total compensation	7,388	5,693
Total number of employees included in the bottom 90% of employees by total compensation	591	490
Average training hours (bottom 90% of employees by total compensation)	12.5	11.6

[ATHEX ESG Metric A-S2] Total training expenditures (€)

	2022	2021	2020
117,309	115,885	73,464

[GRI 404-3] 100% of employees irrespective of level and gender, in Greece, received regular performance and career development review.

[GRI 403-9, GRI 403-10, ATHEX ESG Metric SS-S6] Through the effective management and continuous improvement of the level of health and safety in its activities and facilities, the Group monitors, minimizes or eliminates the potential risks of accidents and diseases.

Health and safety performance

	2022	2021	2020
Employees
Total working hours	1,024,484	978,288	741,044
Number of fatalities as a result of work-related injury	0	0	0
Rate of fatalities as a result of work-related injury	0	0	0
Number of high-consequence work-related injuries (excluding fatalities)	0	0	0
Rate of high-consequence work-related injuries (excluding fatalities)	0	0	0
Number of recordable work-related injuries	2	2	2
Rate of recordable work-related injuries	1	0.4	0.3
Accident frequency rate 5	2	0.4	0.4
Accident severity rate 5	5.9	6.1	0.5
Number of fatalities as a result of work-related ill health	0	Not available	Not available
The number of cases of recordable work-related ill health	0	Not available	Not available
Workers who are not employees
Total working hours	4	815,132	179,273
Number of fatalities as a result of work-related injury	0	0	Not available
Rate of fatalities as a result of work-related injury	0	0	Not available
Number of high-consequence work-related injuries (excluding fatalities)	0	0	Not available
Rate of high-consequence work-related injuries (excluding fatalities)	0	0	Not available
Number of recordable work-related injuries	2	4	0
Rate of recordable work-related injuries	4.9	1	0
Accident frequency rate 5	1	0	Not available
Accident severity rate 5	7.6	0	Not available
Number of fatalities as a result of work-related ill health	0	Not available	Not available
The number of cases of recordable work-related ill health	0	Not available	Not available

Main types and number of work-related injuries (employees and workers who are not employees)

	2022	2021	2020
Minor accidents (slipping, injury at work at height)	5	2	0
Road accident	0	0	1
Fall	1	0	0

Notes:

(1) The employees’ data for the years 2020, 2021 and 2022 refer to shopping centers (Golden Hall, The Mall Athens and Mediterranean Cosmos), Flisvos Marina, The Ellinikon and the headquarters.
(2) In 2022, employee incidents concern 1 employee injury due to a fall at Ag. Kosmas Marina at The Ellinikon and 1 minor injury due to a minor accident at the Group's headquarters. For the recovery of the employees, it was deemed necessary to grant 30 working days leave. The incidents of workers who are not employees, concern 4 minor injuries from minor accidents. For the recovery of the employees, it was deemed necessary to grant leave of 39 working days. For all incidents, regardless of their severity, an investigation is carried out to establish their causes. Moreover, from now on, the conclusions arising from these incidents will be recorded, so that they become valuable lessons that will be communicated to all employees involved in similar works.
(3) In 2021, a minor injury occurred to a Flisvos Marina employee. For the recovery of the employee and given the nature of his work, it was deemed necessary to grant a leave of 30 working days (6/9/2021 – 15/10/2021). The investigation of the circumstances of the accident proved that the cause of this is not related to incomplete training or non-use of personal protective equipment. As part of the strategy for complete accident avoidance, the marina consistently ensures that appropriate measures are taken, including regular training to protect health and safety.
(4) The information for workers who are not employees for 2020 and 2021 concerns only The Ellinikon. For cases of subcontractors or outsourcing of personnel (workers who are not employees), the relevant information is not available for the other investment properties. . For 2022, the data refer to the Designer Outlet Athens shopping center, Flisvos Marina, The Ellinikon and the head offices, w hile for Golden Hall, The Mall Athens and Mediterranean Cosmos shopping centers no data are available.
(5) For 2020 and 2021, the indicators have been calculated by the coefficient of 200,000 ([total number of recorded workplace-related injuries or number of working days lost due to accidents at work / total number of working hours of all workers in the year] x 200,000). The coefficient of 200,000 indicates the number of hours worked by 100 full-time employees in a year. For the year 2022, the indicators have been calculated by the coefficient of 1,000,000 ([total number of recorded workplace-related injuries or number of working days lost due to accidents at work / total number of working hours of all workers in the year] x 1,000,000). The coefficient of 1,000,000 indicates the number of hours worked by 500 full-time employees in a year. The change in the coefficient was made due to the number of employees.
(6) All employees are included in the counting of the statistics, the data collected is true and real, collected through the cooperating contractors and incorporated in the respective company reports.
(7) In order to avoid road accidents, preventive measures are taken at The Ellinikon, by delimiting the movement of vehicles within the area where construction works are carried out, setting low speed limits and training vehicle drivers on pedestrian protection and the safe entry and exit of vehicles from construction and parking areas. Regarding the management of health and safety issues specifically in The Ellinikon, for 2022, the identification of the main risks has been performed, with the fall from heights being the one with the greatest risk. Within the reporting period, a similar incident occurred, and for this reason a cooperation with an external partner was put in place for conducting relevant training. Working at heights cannot be avoided, however the aim is to effectively control the process by which this work is carried out. Moreover, the inspection of all projects under construction has been proceeded, for defining the basic safety levels that must be complied with, which allow focusing on each area of work and identifying areas requiring improvement. It should be noted that the Compliance Unit receives information on developments regarding health and safety issues for The Ellinikon from the competent Department, which it incorporates into the Compliance Report it prepares every quarter and submits to the Audit Committee.

b) Social issues

Corporate policies and due diligence

Prosperity for the society and the local communities

The Group, through the established communication channels with the interested parties, receives requests to support various actions and programs, which it evaluates, in order to design and implement or support those that are in line with its strategy in the field of social contribution, as well as with its business model, while at the same time covering actual needs and creating positive effects on a large number of beneficiaries. The Marketing and Communications Department is in constant and close communication with all the Divisions, to jointly plan, coordinate and implement, these actions. The evaluation of each initiative is carried out internally without the participation of the stakeholders involved in each action. However, all stakeholders, through the available channels of communication and consultation, can contact the Group and get inform about any issue of concern in relation to this matter.

Collaborations with Non-Governmental Organizations (NGOs)

The Group maintains long-term partnerships with more than 45 NGOs and organizations that stand out for their work and actively supports them both by providing free space areas for informative events, and financially, through the collection of basic necessities, as well as by any other way that can aid and support their work. In collaboration with Golden Hall, The Mall Athens, and Mediterranean Cosmos Shopping Centers, Flisvos Marina and The Ellinikon/Experience Park, activities are carried out where collaborating organizations are given the opportunity to be hosted in the public spaces of the shopping centers and Flisvos Marina and communicate their work to their visitors.The purpose of these actions is to raise awareness among citizens and to financially support the activities of NGOs. An important role is also played by its human resources, which is encouraged to participate in social programs. Volunteering programs of employees continued throughout 2022 with the aim to increase their level of contribution. Indicatively, reference is made to the following actions: • Promotion of recycling in the workplace. • Voluntary blood donation • Responding to vulnerable social groups and/or population affected by natural disasters (e.g. earthquake, fires, war, etc.) by collecting food and basic necessities. Economic and social development of communities The Ellinikon is being developed as a single property and as an area of multiple functions of metropolitan dimension and international reference. The aim is to enhance Athens as a tourist destination, as a business center and recreation area. At the same time, The Ellinikon aims at the creation of jobs, a Metropolitan Park and other destination points, and that provides the wider metropolitan complex of the capital with green and recreation areas and that regenerates and promotes its seafront. A city is being developed based on modern international practices, where everyone will be able to find what he/she requires on daily basis, and at a very close distance: schools and sports facilities, health and welfare services, as well as entertainment and recreation areas. Smart City The Ellinikon is designed to be equipped with all the physical infrastructure and information systems that will make it a model Smart City. Telecommunication networks (fiber optics, WiFi, 5G and IoT) will allow a variety of sensors and devices to communicate and collaborate in order to minimize resource consumption and environmental footprint, on the one hand, and to offer unique digital services to residents, visitors and businesses within Elliniko, on the other. Indicative applications include uniquely fast Fiber to the Premise (FTTP), public network & public WiFi available over the whole of its area, smart power management, smart home, smart lighting, smart parking, smart waste management, smart environmental monitoring, an Ellinikon resident app, an Ellinikon visitor app, smart bike parking pods, smart irrigation and many more. Citizens' perceptions of The Ellinikon In March 2022, a follow-up survey was conducted in collaboration with an external consultant (the initial survey was conducted in May 2021) regarding the citizens' perceptions of The Ellinikon's project. The purpose of the survey was to align the main points of the communication strategy that have a positive effect on the image of the Group and The Ellinikon and making full use of the corporate actions that relate communication and its relationship with the younger generations and local communities. The results showed that respondents perceive The Ellinikon as a large redevelopment project that is recognizable by the majority of the population, and thus understand its size and impact. Moreover, there is a clear connection between LAMDA Development and the project, which evolves at a slower pace compared to the recognition of the project itself, but is higher than the recognition of companies of other important large- scale projects that are presently developed in Greece. With regards to the recognizable benefits, at an economic level there is an increase in employment and a reduction of unemployment and an improvement of the tourism services and the rise of tourism. Moreover, at a socio-cultural level, it emerges that respondents perceive as benefit the contribution of The Ellinikon to the development of smart technologies and the reputation of the country abroad. Annual financial report for the year ended 31 December 2022 47 Additionally, an evaluation of the "mechanisms" that are activated in citizens when they hear positive news was carried out. Indicatively: • Hope - News create a high degree of hope for a project that will positively upgrade the Elliniko region and the country's economy. • Admiration - News create a high degree of admiration due to the project’s size and the possibilities it will offer to the public. • Personal Benefit - Young people, especially those living in the surrounding areas, identify the benefit of the park in their daily lives. In the near future, The Ellinikon is expected to further enhance its communication towards the age group of 18-24 and respond to recognized ambiguities and grey areas that indicate a possible lack of knowledge, such as the free access to the new 1.5 km long beach and the metropolitan park, that will be open to all. Therefore, the public should keep receiving information on the above matters, so that the percentage of reflection and concern that hinder the positive evaluation of the project, is further reduced. Customers’ health and safety In addition to the measures implemented to ensure the health and safety of employees, the Group has set as a priority the protection and safety of both its employees and visitors of its shopping centers. Thus, it collaborates with distinguished security companies, that have signed the Code of Conduct 15 , so as to meet the standards of service quality set by the Group, that constitute a prerequisite for the smooth operation of its activities. Systems (Enterprise Risk Management) and related control procedures (Center Management) are implemented, aiming at the continuous improvement and development of key sectors, such as health, safety, environment, and service quality. More information is available in the chapter “Health, safety and well-being”. Personal data protection [ATHEX ESG Metric C-G6] The Group fully complies with its obligations arising from the legislation on data protection, such as the General Regulation on Personal Data, Law 4624/2019, and the guidelines and relevant decisions of the Personal Data Protection Authority. In addition, all appropriate technical and organizational measures for the lawful processing of personal data, as well as ensuring the confidentiality, integrity, and availability of such data, have been taken. The Group, being fully compliant with the General Regulation 2016/679 of the European Union on Data Protection Regulation (GDPR) and the relevant national legislation, has a Personal Data Protection Policy, which reflects the principles of data processing, protection and security and the responsibilities of those involved. Moreover, it provides on its website https://www.lamdadev.com, the Privacy Statement and the basic commitments regarding the Protection and Security of Personal Data. The actions taken - towards full compliance - include the appointment of a Data Protection Officer (DPO), the creation and continuous updating of a File of Processing Activities, the preparation of all necessary informative texts (Privacy Notices) and consent, as well as the development of Impact Assessment Studies, for those processing activities that are deemed appropriate. It takes the appropriate technical and organizational measures to ensure the security of the data and, in particular, the integrity, confidentiality and availability, while ensuring that its partners, to whom it assigns the processing of personal data, also comply with these measures. It proceeds to periodic staff trainings to ensure the information, training and awareness of employees on Personal Data Protection issues. In 2022, issues of personal data processing were raised at Board meetings, such as the approval of the Revised Version of the Rights Management Process for Reporting Subjects and the Information Systems Security Policy. 15 For the Designer Outlet Athens mall, the Code of Conduct has not been signed by a security company, but it will be signed by the security company with which the relevant contract will be concluded, within 2023. Annual financial report for the year ended 31 December 2022 48 Outcomes of the above policies and non-financial key performance indicators [GRI 416-2, GRI 418-1] In 2022: • There has been no incident of non-compliance with legislation and/or voluntary codes, regarding the effects on the health and safety from the Group’s services. • There has been no incident of violation of customer privacy and/or loss of customer data. 5. Respect for human rights Corporate policies and due diligence Dignity and equality The Group aims to create an excellent working environment that ensures dignity and equality and provides equal opportunities for all. The creation of such an environment is based on the impartial attraction of new employees regardless of gender, age, etc., and extends to an impartial performance evaluation of employees. The Group is committed to addressing and eliminating discrimination, violence and harassment in the workplace, to ensure a working environment, where respect for human dignity prevails and discrimination is tolerated, based on personal characteristics and choices. It takes into consideration international standards (e.g., International Charter of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work) in promoting diversity and providing equal opportunities to its employees and candidates at all levels of the hierarchy. The Group commitment is not limited towards current legislation but reflects its practical effort to protect dignity and equality in the working environment, which it has set as a goal, to have no incident of discrimination of any nature. This goal concerns all Group employees, its subsidiaries, but also external partners. An environment that promotes these values has the potential to be a fertile ground for creating an environment of trust to employees and shareholders, which will, at the same time, enhance the efficiency of its employees and will strengthen the reputation of the Group.# Business Conduct & Human Rights [ATHEX ESG Metrics C-S6, C-G5]

Since the beginning of its operation, the Group has adopted a corporate culture with values and rules of conduct, characterized by integrity, ethics, transparency and personal responsibility. As far as employees are concerned, the Code of Conduct is the guiding instrument in their daily behavior in the context of the provision of their services. In addition, business ethics issues relating to the Group's suppliers are covered by the Supplier Code of Ethics referred to in chapter 7. The Code of Conduct, which was revised in November 2022, acts as a means of guiding the LAMDA Development employees and its subsidiaries, in which it holds the majority, so that the Group conducts its activities in an ethical and honest manner. The Code acts in addition to, and complementary to, the current legislation and is used as a lever in the process of establishing minimum rules and integration of business ethics principles and ethical behavior, which must be observed by the liable persons. Based on the precautionary principle, the Code of Conduct is made available at the beginning of the employment relationship to the liable persons. The Code of Conduct rules are applied by the liable persons, that are defined as follows:

the Members of the LAMDA Development Board of Directors and any third party to whom responsibilities of the Board of Directors have been assigned,
the Managers
Persons contracted with a Group company with a fixed-term or indefinite employment contract or persons linked to the Group by another employment relationship, such as consultants, persons who are seasonal staff and/or persons employed as trainees of the Group company

Human rights issues are covered in the Code of Conduct, since the Group does not have a separate related Policy. The Management, recognizing the particular importance of its human resources, which is the main factor for achieving its goals, ensures the formation of a working environment, where all Obliged Persons at each level of hierarchy have equal rights and opportunities, while at the same time rewarding effort and protecting diversity. The Group expresses its zero tolerance to discrimination, violence and harassment that occurs during work, whether related to it or resulting from it, while at the same time it is committed to addressing and eliminating these incidents, in order to ensure a working environment where respect for human dignity prevails. The Group selects, assigns, evaluates, rewards and compensates Obliged Persons on the basis of their formal and substantive qualifications for the needs of their work, without discrimination on the basis of race, color, national origin, nationality, religious or other beliefs, disability or chronic disease, age, marital or social status, identity or gender, citizenship, sexual orientation or any other personal characteristics. To ensure respect for human rights, the Group has individual policies approved by the Board of Directors, which are posted on the Group's Intranet and/or on the Company's website.

Anti-Discrimination, Violence and Harassment Policy

The purpose of the policy is to prevent and combat all forms of discrimination based on personal characteristics and choices, as well as any violence and harassment that occurs during work, whether it is related to it or arises from it.

Whistleblowing Policy

A Whistleblowing Policy (https://www.lamdadev.com/en/the-company/whistleblowing/whistleblowing-policy.html) has been developed, based on which an innovative and integrated mechanism for the submission, management and investigation of reports (Whistleblowing) has been adopted, with the aim of enhancing the transparency and integrity of the Group. Thanks to this mechanism, all employees of LAMDA Development and its subsidiaries, as well as its external partners, can, anonymously or not, report incidents in the workplace, such as violations of transparency and integrity, as well as any form of discrimination, violence and harassment at work, as reflected in the Whistleblowing Policy. The Group has developed a series of individual policies and procedures for the internal allocation of responsibilities regarding the way of submitting, managing and investigating reports (Whistleblowing):

the Reporting Process, which institutionalizes reporting channels and describes in detail how employees and external partners submit reports,
the Reports Management Procedure, which defines the competent bodies and the individual steps for the proper and effective handling of complaints, and
the Internal Investigation Policy and Procedure, which sets out how reports should be investigated.

In the context of the aforementioned mechanism, a new customized platform (https://lamdadev.sec.fraudline.gr/) was created for the submission of reports exclusively for the Group, which in combination with the relevant email ([email protected]) constitute the innovative and integrated mechanism for submitting, managing and investigating reports. It is worth noting that the Group treats with due seriousness, confidentiality and attention all reports submitted (anonymous or not) through the aforementioned statutory reporting channels, while it has developed interactive and comprehensible audiovisual material to educate and raise awareness among stakeholders.

Diversity Policy

A Diversity Policy has been adopted that is included in the Suitability Policy, which is posted on the website https://www.lamdadev.com, with the aim to promote, on the one hand, the necessary differentiation in the BoD, and, on the other hand, attaining the inclusiveness of the group’s members. When selecting members of the BoD, the necessary provision is made to ensure the diversity of opinions and experiences, in order to reach good decisions.

To all members of the BoD, emphasis is placed on the diversity of the group of BoD members, with the main characteristic being the representation by gender (at least 25% of the total members rounded when calculated, to the previous integer) and the absence of discrimination in the selection of members.

Outcomes of the above policies and non-financial key performance indicators [ATHEX ESG Metric C-S3]

During the reporting period, female employees in managerial positions (the percentage of women in the top 10% of highest-paid employees) accounted for 28.9%.

Female employees in managerial positions (%)	2022	2021	2020
	28.9%	23.9%	28.0%

[GRI 405-1]

Composition of governance bodies and employee breakdown by gender (%)

	2022
	Men	Women
Board of Directors	75.0%	25.0%
Senior Executives	74.6%	25.4%
Middle executives	50.2%	49.8%
Support staff	42.2%	57.8%

Composition of governance bodies and employee breakdown by function (%)

	2022
	Men	Women
Shopping centers (Golden Hall, The Mall Athens, Mediterranean Cosmos)	11.0%	15.5%
The Ellinikon (including Agios Kosmas Marina)	21.3%	24.5%
Flisvos Marina	4.3%	1.7%
Head offices	11.1%	10.0%
Abroad activities	0.1%	0.5%
Total	47.8%	52.2%

Composition of governance bodies and employee breakdown by age group (%)

	<30	30-50	>50
Board of Directors	0%	17.0%	83.0%
Senior Executives	0%	55.6%	44.4%
Middle executives	2.4%	80.0%	17.6%
Support staff	36.7%	53.5%	9.8%

Composition of governance bodies and employee breakdown by age group (%)

	<30	30-50	>50
Shopping centers (Golden Hall, The Mall Athens, Mediterranean Cosmos)	9.3%	14.9%	2.3%
The Ellinikon (including Agios Kosmas Marina)	9.9%	27.9%	8.1%
Flisvos Marina	0.3%	3.6%	2.0%
Head offices	3.0%	14.9%	3.2%
Abroad activities	0.0%	0.6%	0.0%
Total	22.5%	61.9%	15.6%

Gender pay gap (%)	2022	2021	2020
	32.9%	31.5%	34.6%

Note: The calculation of the metric took into account the payroll of all full-time employees who worked throughout the year and not as a headcount at 31.12 of each year. A forecast of the bonus of the year 2022 has also been included in the calculation, which will be paid to employees in 2023.

[GRI 406-1] For 2022, there were no recorded incidents of discrimination either among internal stakeholders (employees) or external stakeholders (e.g., suppliers).

6. Anti-corruption and issues related to bribery

Corporate policies and due diligence

Since the beginning of its operation, the Group has adopted a corporate culture with values and rules of conduct, characterized by integrity, ethics, transparency, and personal responsibility for each employee. Apart from complying with the current legislation and the regulatory framework, all employees must also comply with the Internal Regulation of Operation, the Code of Conduct, as well as the Policies, Codes and Procedures, established by Management, in order to add value and ultimately enhance the Group's competitiveness. The Principles, Codes, Procedures and Policies that are applied and are available - as appropriate - on its website and intranet (either in Greek and/or English), cover issues such as anti-corruption, conflicts of interest, personal data, confidentiality, customer relationships, market abuse, inside information management, discrimination in the workplace, etc. Their content is examined at regular intervals and updated according to the new data, so that they always remain up to date and meet the needs of each time.# As a measure of best practice and promotion of corporate compliance, it has adopted the Anti-Corruption Policy, as approved by the BoD, with which it places restrictions on its interactions with various employees of the public and private sector, in order to maintain a high level of professional behavior, while reflecting the zero-tolerance approach to any form of corruption. To achieve the above objectives, this Policy includes both quantitative and qualitative restrictions on the provision and acceptance of gifts, trips, meals and other benefits by staff to third parties and vice versa. The ultimate goal is to conduct business activity and transactions with professionalism, integrity and fairness. More specifically, issues such as the integrity and respect for labor relations, the commitment of employees to corporate goals, the commitment to the continuous professional training of its human resources, as well as the continuous effort of employees to achieve maximum performance and the continuous improvement of the result of their work, are covered. In addition, procedures are implemented relating to ensuring confidentiality of operations and confidentiality in general, the fight against corruption, conflicts of interest, the out-of-company activities of employees, the use of the Group’s assets, and its relations with customers and suppliers, which must be based on trust, mutual respect, impartiality and honesty, thus ensuring long-term partnerships. The above act as tools of best practice and compliance with the current legislation, with the aim of adding value and ultimately enhancing the competitiveness of the Group. In addition, they promote transparency, health and safety of employees, sustainable development principles regarding the environment and the relations with society and especially with vulnerable social groups and local communities in the areas where it operates. Their content is reviewed at regular intervals and updated according to new data, so that they remain always up to date and meet the needs of each case.

Outcomes of the above policies and non-financial key performance indicators [GRI 205-3, ATHEX ESG Metrics C-G5, A-G2]

The application of the Code of Conduct provisions is mandatory and is subject to control by the competent supervisory bodies of the Group. For this purpose, those responsible for its implementation must familiarize themselves with its content and sign the relevant acceptance form, which is delivered to the Human Resources Department. In 2022, there was no confirmed incident of corruption or bribery, and no relevant intent to commit corruption or bribery came to the attention of the relevant officials. In addition, there was no monetary loss as a result of violations of the Code of Conduct. Moreover, within the framework of the Whistleblowing Policy, an innovative and integrated mechanism for the submission, management and investigation of reports is implemented, with the aim of enhancing the transparency and integrity of the Group. This mechanism is available for the submitting various types of reports, in accordance with the relevant policy available on the website https://www.lamdadev.com.

7. Supply chain issues

Corporate policies and due diligence

The Group’s supply chain is divided into 3 main categories, which relate to real estate investment, projects in the development phase, and procurements to meet operational needs. More specifically:

Procurement Policy and Supplier Code of Ethics [ATHEX ESG Metric C-S8]

The Procurement Policy determines, through the recording of the basic guidelines and rules, the operating framework with regards to the procurement of materials, equipment, and services during the exercise of the Group’s activities. It aims at covering, in time and in adequate quality, the needs in materials, equipment, services and projects, , under the best possible terms (quality, price, payment method, guarantees, etc.) in order to:

Strike a balance between technical adequacy, quality and price of tenders, as well as the quality and acceptance of the supplier, in order to maximize the overall benefit.
Ensure transparency, objectivity, impartiality and equal opportunities.
Minimize operational and credit risks, arising from partnerships with suppliers.
Increase credibility vis-à-vis third parties.

In the context of enhancing the understanding and acceptance of the Group’s corporate values by its entire supply chain, the Supplier Code of Ethics was approved in December 2022, also available on the website (https://www.lamdadev.com/images/corporate_governance/Suppliers_Code_of_Ethics.pdf) containing the ethical principles that should govern the conduct of potential suppliers, contractors, service providers and consultants entering into a contractual relationship with the Group. The purpose of the Supplier Code of Ethics is, among others, to promote safe and fair working conditions as well as the responsible management of social, ethical, and environmental issues in the Group supply chain. Suppliers are required to ensure that their own suppliers and subcontractors are subject to principles of conduct equivalent to those set out in the Group’s Supplier Code of Ethics. The Supplier Code of Ethics is incorporated in the tenders launched by the Group prior to the commencement of any contractual relationship (except in cases where the candidate supplier has its own stricter framework). Specifically, it is requested to be accepted in writing by the candidate suppliers, through a relevant questionnaire, in the context of their preliminary evaluation and through their terms of participation for the tenders of the Group.

Procurement Evaluation [ATHEX ESG Metric C-S8]

The responsible Procurement Management Departments, which have the knowledge about the products and services on offer, conduct market research, in order to identify potential new suppliers. Before launching any request for proposals, they assess potential suppliers to verify that the supplied products and services meet the respective requirements, as well as to minimize any operational and credit risks that may arise from possible wrong partnerships. In the context of the preliminary evaluation, general information about the business activity of potential suppliers is collected, through a relevant questionnaire that is sent to them, and are then categorized appropriately. Where deemed necessary, targeted preliminary assessments (PPQs) are carried out, to select candidate suppliers who meet the participation requirements of specific tenders. According to the Code of Conduct, all suppliers are provided equal opportunities and as stated in the Procurement Policy, the evaluation of bids and, consequently, the cooperation decisions, are based on the following technical evaluation criteria, which consider environmental and responsible entrepreneurship parameters of the supplier candidates:

compliance with technical specifications,
quality,
methodology and execution schedule,
criteria related to responsible entrepreneurship (e.g., certification of quality systems, environmental management, health and safety, etc.).

In cases of procurement and projects requiring on-site audits at the suppliers’ premises, or of existing projects already being performed by suppliers, those suppliers are further being evaluated based on the following criteria:

quality policy and quality control procedures,
implementation quality of existing projects,
development laboratories and techniques,
equipment capabilities,
employee capabilities and training.

Respectively, Flisvos Marina lends wight to the safeguarding of a continuous, transparent, and efficient procurement process, for hazardous and non-hazardous materials, equipment, and services (of contractors and external partners). The marina sets as a priority the safety and protection of the environment for the supplied materials, equipment, and services, as well as for the activities for the management of its facilities. In this way, it seeks to minimize the risks arising from their use and ensure compliance with quality, safety and environmental policies. Flisvos Marina follows specific procedures aiming at the effective management of its partnerships with its suppliers, subcontractors and partners. In the context of the award of works and services (relating to a specific amount of money or above), a technical evaluation report is prepared by the technical evaluation committee, which provides a summary of all the tenders received, as well as a clear and objective analysis and evaluation of the technical, environmental (if they fall under the criteria of the technical assessment) and qualitative aspects of the tenders, in order to determine impartially the technically valid candidates. The composition of these committees shall be determined based on the type of the proposed award. Additionally, apart from the commercial and technical documentation, it is required through the relevant Request for Proposal (RFP), that suppliers also include documentation on “Health safety and environment”.

Outcomes of the above policies and non-financial key performance indicators

In 2022, the Group (including all its subsidiaries, with the exception of LAMDA Flisvos Marina A.E.) collaborated with more than 1,250 suppliers of services and products. Respectively, Flisvos Marina collaborated with 248 suppliers of services and products. During the reporting year, there were no audits of suppliers characterized as high risk, nor any cases of termination of cooperation with suppliers, due to non-compliance with the Supplier Code of Ethics.

8.# EU Taxonomy Report [ATHEX ESG Metric A-S1]

The EU Taxonomy Regulation (2020/852/EU) is one of the tools established due to the European Green Deal, which aims at the transformation of the European Union, into a modern, efficient, competitive and climate-neutral economy by 2050, in a fair manner. The Regulation establishes the technical screening criteria for determining whether an eligible economic activity qualifies as environmentally sustainable (taxonomy aligned). Consequently, the Regulation sets a common classification system with regards to the economic activities that have a significant positive impact on the climate, the environment and the society. An economic activity is eligible according to EU Taxonomy if it is described in one of the Delegated Acts 2021/2139 and 2022/1214, irrespective of whether that economic activity meets any or all of the technical screening criteria laid down in those delegated acts.

For an economic activity to qualify as environmentally sustainable, i.e., Taxonomy-aligned, the activity is required to meet all the following requirements:
* Contributes substantially to one, or more, of the six (6) environmental objectives set by the Regulation
* Does not significantly harm any of the other five (5) environmental objectives
* Complies with the minimum social safeguards
* Complies with the technical screening criteria as set by the Commission

The six environmental objectives set by EU Taxonomy Regulation are the following:
* Climate change mitigation
* Climate change adaptation
* Sustainable use and protection of water and marine resources
* Transition to a circular economy
* Pollution prevention and control
* Protection and restoration of biodiversity and ecosystems

Currently, according to the Delegated Acts 2021/2139 and 2022/1214, there are available technical screening criteria only for the two (2) of the six (6) environmental objectives, and specifically for:
* climate change mitigation and
* climate change adaptation.

EU Taxonomy Reporting Methodology

The methodology for the determination of the key performance indicators (KPI) of the Group for 2022, which according to Article 8, paragraph 1, of EU Taxonomy Regulation (2020/852/EU), the non-financial undertakings are subjected to an obligation to publish, was as follows:

Identification of the Taxonomy-eligible economic activities
Assessment to determine alignment of the Taxonomy-eligible economic activities based on the technical screening criteria of the below:
a. Substantial contribution to the climate change mitigation and climate change adaptation environmental objectives
b. Do no significant harm (DNSH)
Assessment on the compliance of the Group with the minimum social safeguards
Calculation of the key performance indicators:
- The proportion of their turnover («Turnover») derived from products or services associated with economic activities that qualify as environmentally sustainable.
- The proportion of their capital expenditure («CapEx») related to assets or processes associated with economic activities that qualify as environmentally sustainable.
- The proportion of their operating expenditure («OpEx») related to assets or processes associated with economic activities that qualify as environmentally sustainable.

The methodology was based on the EU Taxonomy Regulation (2020/852), its Delegated Acts as well as any additional guidance released:
* The Climate Delegated Acts 2021/2139 and 2022/1214.
* The Disclosure Delegated Act 2021/2178.
* Final Report on Minimum Safeguards.

Identification of the Taxonomy-eligible economic activities

LAMDA Development Group plays an extremely important role in the field of large shopping and entertainment centers in Greece, while has investments in residential and office developments, mainly in Greece, as well as in countries of SE Europe. Currently, the Group's real estate portfolio includes the following:

the complete urban regeneration of the Metropolitan Pole of Elliniko – Agios Kosmas area (the redevelopment of the former Elliniko airport, as well as the promotion of the coastal front),
the Mall Athens, the first and largest shopping and entertainment center in Greece,
the Golden Hall, an internationally renowned shopping center, in which the new Olympic Museum of Athens and the XPLORE family entertainment center are located,
the Mediterranean Cosmos, the largest shopping and entertainment center in Northern Greece,
the Marinas in Flisvos and Elliniko, Agios Kosmas,
office buildings, and
innovative residential complexes.

The determination of the eligible economic activities of Group’s economic activities was conducted based on the description and the NACE codes associated with its activities. During the financial year 2022, 79% of its turnover, 61% of its capital expenditure («CapEx») and 70% of its operating expenditure («OpEx»), were identified as Taxonomy-eligible.

The economic activities of the Group which were identified as Taxonomy-eligible for the financial year 2022 are the following:

Economic activity	Description	NACE- Code
4.3 Electricity generation from wind power	Construction or operation of electricity generation facilities that produce electricity from wind power.	D35.11
7.1 Construction of new buildings	Development of building projects for residential and non-residential buildings by bringing together financial, technical and physical means to realise the building projects for later sale as well as the construction of complete residential or non-residential buildings, on own account for sale or on a fee or contract basis.	F41.2
7.7 Acquisition and ownership of buildings	Buying real estate and exercising ownership of that real estate.	L68
13.2 Libraries, archives, museums and cultural activities	Libraries, archives and museums of all kinds.	Ρ91

Eligibility Assessment based on technical screening criteria

The Group proceeded with the assessment of its eligible economic activities and assets, against:

The technical screening criteria (TSC) concerning substantial contribution for at least one (1) environmental objective, the climate change mitigation or the climate change adaptation, in order to identify in which of these two (2) objectives, they substantially contribute. In addition, it was determined whether each economic activity is considered an enabling or a transitional one.
For economic activities which are not characterized as enabling (i.e., 4.3, 7.1 and 7.7), the assessment was conducted according to the technical screening criteria for the substantial contribution to climate change mitigation, as the turnover derived from products and services associated with an adapted activity (which is not considered as enabling), cannot be recognized as Taxonomy-eligible.
For the Activity 13.2, the assessment was conducted according to the technical screening criteria for the substantial contribution to climate change adaptation, as this activity is considered an enabling activity, but also is not included in the list of activities that could potentially contribute significantly to climate change mitigation.
The technical screening criteria (TSC) concerning “do no significant harm” in relation to the remaining five (5) environmental objectives. More specifically, the assessment was carried out according to the criteria concerning either the climate change mitigation or the climate change adaptation environmental objective, depending on the objective assessed during the substantial contribution assessment, as well as the remaining four (4) objectives (Sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, protection and restoration of biodiversity and ecosystems).

The purpose of this assessment was the determination of the level for alignment of the Group’s eligible economic activities with the TSC and the requirements of Taxonomy Regulation, as well as the identification of potential gaps, in order the Group to develop a specific action plan to align its eligible economic activities, with the Taxonomy Regulation, in the coming years.

Activity 4.3 Electricity generation from wind power

The Group is active in the construction of wind turbines in wind farms, as well as in the production of electricity from wind farms, through its subsidiary GREENVOLT IKE. For 2022, the total capacity of the projects which are under development is 250 MW. During 2022, this economic activity has showed Turnover €0 m. (0% of the total Turnover), CapEx €1 m. (2% of the total CapEx) as well as OpEx €0 m. (0% of the total OpEx).

Substantial contribution
The activity substantially contributes to climate change mitigation, as it is related to electricity generation from wind power.

Do No Significant Harm (DNSH)

The assessment was based on the criteria described in Activity 4.3 and are related to:
- The assessment of the physical climate risks
- The utilization of equipment and components of high durability and recyclability
The completion of an Environmental Impact Assessment (EIA) and the implementation of the required mitigation and compensation measures for protecting the environment

The assessment concluded the activity do not comply with the technical screening criteria of the climate change adaptation, as the Group has not identified and assessed the physical climate risks related to this activity. With regards to equipment utilization, the wind turbines consist of approximately 97% of durable and recyclable components. Subsequently, the activity complies with the technical screening criteria related to the transition to a circular economy.# Annual financial report for the year ended 31 December 2022

With regards to the implementation of the required mitigation and compensation measures for the protection of the environment, considering that all the wind farms of the Group are currently under development, and that all approved Environmental Impact Assessments (EIA) are available, the implementation of the mitigation measures, as described in each EIA will follow as soon as wind farm’s construction will be completed and their connection to the grid is secured.

Activity 7.1 Construction of new buildings

This activity includes 68 assets related to the following subsidiaries: ELLINIKO S.Μ.S.A. (64 buildings), LAMDA VOULIAGMENIS S.M.S.A. (1 building complex) as well as LAMDA RIVIERA S.M.S.A. (1 building complex – 3 buildings). All assets are related to the projects that the Group develops in the Metropolitan Pole of Elliniko – Agios Kosmas. During 2022, this economic activity has showed Turnover €21,9 m. (16% of the total Turnover), CapEx €25,8 m. (44% of the total CapEx) as well as OpEx €0 m. (0% of the total OpEx).

Substantial contribution

The assessment related to the substantial contribution to climate change mitigation was based on the criteria related to:
* The Primary Energy Demand (PED)
* The testing for airtightness and thermal integrity, for buildings larger than 5,000 m2
* The life-cycle Global Warming Potential (GWP) calculation, for buildings larger than 5,000 m2

For buildings smaller than 5,000 m2 (47 buildings), the assessment concluded that:
* 20 buildings (29% of the total number of buildings) comply with the technical screening criteria of substantial contribution to climate change mitigation, as, based on the design phase studies, it is anticipated their energy consumption to be at least 10% lower than the lower threshold set for the nearly zero-energy building (NZEB).
* 4 buildings (6% of the total number of buildings) do not fulfill the criterion related to the Primary Energy Demand.
* 23 buildings (34% of the total number of buildings) are still at an early design stage and as a result they could not be assessed for their alignment. These buildings are not assessed against the rest of the technical screening criteria of substantial contribution.

For buildings larger than 5,000 m2 (17 buildings), the assessment concluded that:
* 14 buildings (21% of the total number of buildings), either already comply, or it is already planned to comply, based on their studies, with the criterion concerning energy consumption. With regards to the requirement of testing for airtightness and thermal integrity, it is planned to be carried out for all new buildings, by the completion of their construction. As far as the life-cycle Global Warming Potential (GWP) calculation, taking into consideration that many new buildings are on track to be certified with LEED (12 buildings), the relevant study is already initiated regarding building’s shell and structure.
* 3 buildings (4% of the total number of buildings) do not fulfill any of the 3 criteria of the substantial contribution.
* 4 buildings (6% of the total number of buildings) are still at an early stage concerning their studies and as a result they could not be assessed for their alignment. However, during the design phase of these buildings, the related technical screening criteria will be considered.

Do No Significant Harm (DNSH)

The assessment was based on the technical screening criteria described in the Activity 7.1 which are related to:
* The assessment of the physical climate risks.
* The installation of low consumption water appliances to ensure sustainable use and protect water and marine resources.
* The reuse, recycle or other recovery of non-hazardous construction and demolition waste.
* The building’s design and construction techniques to support circularity and demonstrate how they are designed to be more resource efficient, adaptable, flexible and dismantleable to enable reuse and recycling.
* The use of building components and materials with low emissions of carcinogenic volatile organic compounds and the limitation of the use of construction materials containing specific chemical substances.
* The completion of an Environmental Impact Assessment (EIA) and the implementation of the required mitigation and compensation measures for protecting the environment.

The assessment concluded in non-alignment of the activity with the technical screening criteria of the climate change adaptation, as the Group has not identified and assessed the physical climate risks related to this activity. However, this assessment is already on track currently for 3 projects (Riviera Tower, Riviera Galleria and Vouliagmenis Mall Complex) to be conducted during the next reporting period.

The assessment of the activity with the technical screening criteria of the sustainable use and protection of water and marine resources concluded that 20% of buildings (8 buildings), which are in the design phase, the installation of appliances with low water consumption is already planned. For the rest, it will be considered during the maturity of their studies. At the same time, 100% of the buildings either already have approved Environmental Impact Assessment, or, for cases that a new Environmental Impact Assessment is required, its issuance is in progress and is planned to be submitted. During construction phase, the related Environmental Management Plan is already applied, according to the approved environmental terms. For the buildings for which the LEED certification is planned (63% of the total buildings), there is already a requirement for significant percentage of reuse and recycle of non-hazardous construction and demolition waste, above the limit set in the technical screening criteria of the transition to a circular economy environmental objective. In parallel, according to the Environmental Management Plans of both construction and operation all the required measures for the reduction of noise, dust and pollutant emissions are applied. With regards to the construction materials, for all new, under development, buildings, the selection of all indoor materials and components will be conducted, to the extent possible, based on the technical screening criteria of the pollution prevention and control, which set the emissions and limitation of the usage of specific chemical substances.

Activity 7.7 - Acquisition and ownership of buildings

This activity includes the assets related to the following subsidiaries: PYLAIA S.M.S.A., LAMDA DOMI S.Μ.S.A., L.O.V. S.M.S.A., DESIGNER OUTLET ATHENS S.M.L.L.C., LAMDA FLISVOS MARINA S.A., LAMDA PRIME PROPERTIES S.M.S.A., LAMDA ESTATE DEVELOPMENT S.M.S.A. and KRONOS PARKING S.M.S.A. (8 assets of the Group in total: Mediterranean Cosmos, Golden Hall, The Mall Athens, Designer Outlet Athens, Cecil, the buildings of Flisvos Marina, Othonos Parking and Kronos Parking). During 2022, this economic activity has showed Turnover €89,6 m. (63% of the total Turnover), CapEx €8,7 m. (15% of the total CapEx) as well as OpEx €3,6 m. (68% of the total OpEx).

Substantial contribution

The assessment related to the substantial contribution to climate change mitigation was based on the criteria related to:
* The Energy Performance Certificate, for buildings built before 31 December 2020.
* For buildings built after 31 December 2020, the criteria specified for Activity 7.1, concerning the Primary Energy Demand (PED) and based on the footage of the building, the conduction of testing for airtightness and thermal integrity and the life-cycle Global Warming Potential (GWP) calculation.
* Where the building is a large non-residential building (with an effective rated output for heating systems, systems for combined space heating and ventilation, air-conditioning systems or systems for combined air-conditioning and ventilation of over 290 kW) it’s efficient operation through energy performance monitoring and assessment.

All buildings of this economic activity have been constructed before December 31st, 2020. The assessment concluded that no building is aligned with the Energy Performance Certificate related criterion. As an alternative to the Energy Performance Certificate, the Regulation states that for buildings constructed before December 31st, 2020, it may comply with the Energy Performance Certificate related criterion if it is within the top 15% of the national or regional building stock, in relation to Primary Energy Demand. The assessment against this criterion was not currently possible due to insufficient national statistics data. There is already a provision for the energy upgrade of some buildings of the portfolio, with the aim of improving their energy efficiency, which will contribute to their alignment with the technical screening criterion related to Energy Performance Certificate.

Regarding the criterion related to monitoring and assessment of heating, ventilation and air-conditioning systems, the assessment concluded that all 3 buildings with a useful nominal power of more than 290 kW are aligned with the criterion. The assets concerning the subsidiaries LAMDA ESTATE DEVELOPMENT S.M.S.A. and KRONOS PARKING S.M.S.A., as they constitute parking lots, cannot be aligned with the technical screening criteria of substantial contribution, due to the fact that, based on legislation, they do not have Energy Performance Certificates.

Do No Significant Harm (DNSH)

The assessment of the Activity 7.7 was based on the technical screening criteria for the climate change adaptation which is related to the assessment of the physical climate risks. The physical climate risks assessment is already conducted for one building (The Mall Athens), while for the rest of the buildings the physical risks have not been identified and assessed.# Annual financial report for the year ended 31 December 2022

Activity 13.2 Libraries, archives, museums and cultural activities

This activity includes the subsidiary ATHENS OLYMPIC MUSEUM Α.Μ.Κ.Ε.. During 2022, this economic activity has showed Turnover €0,2 m. (0,1% of the total Turnover), CapEx €0 m. (0% of the total CapEx) as well as OpEx €0,1 m. (2% of the total OpEx). The activity is considered an enabling activity according to EU Taxonomy Regulation.

Substantial contribution

The assessment of this activity was based on the technical screening criteria for the climate change adaptation which is related to the assessment of the physical climate risks. The assessment concluded in non-alignment of the activity with the technical screening criteria of the climate change adaptation, as the Group has not identified and assessed the physical climate risks related to this activity.

Do No Significant Harm (DNSH)

For this activity there are no DNSH criteria available for any of the remaining environmental objectives

Minimum Social Safeguards

The Group was assessed against the requirements of the minimum social safeguards as set out in Article 18 of the EU Taxonomy Regulation (2020/852/EU). The minimum social safeguards are a set of defined UN, EU and other international human rights guidelines, as follows:

The OECD Guidelines for Multinational Enterprises
The United Nations Guiding Principles (UNGPs) on Business and Human Rights
The principles and rights set out in the eight fundamental conventions identified in the Declaration of the International Labor Organization on Fundamental Principles and Rights at Work
The International Bill of Human Rights

According to the Final Report on Minimum Safeguards of the Platform on Sustainable Finance, the minimum social safeguards cover the following areas:

Human rights (including labor rights)
Corruption/Bribery
Taxation
Fair Competition

All human rights, listed in the ILO fundamental conventions and the International Bill of Human Rights are taken into account in the UNGPs. Therefore, the assessment of the minimum social safeguards had as main reference points the OECD Guidelines for Multinational Enterprises and the UNGPs.

Human Rights

The Group has adopted, an approved by the BoD, Code of Conduct, which includes specific commitments regarding the observance of human rights, including the rights of employees. These commitments apply to all employees as well as business partners. The Group also applies, an approved by the BoD, Suppliers’ Code of Ethics, which is available on Group’s website and includes the ethical principles that must govern the conduct of any suppliers, contacts, service providers and consultants who contract the Group and which must be expressly accepted by them prior to the commencement of the contract. Among these ethical principles, the Suppliers’ Code of Ethics covers human rights and labor practices. Furthermore, to properly prevent and combat any form of discrimination based on personal characteristics and choices as well as any violence and harassment that occurs during work, whether connected to it or resulting from it, the Group implements its Workplace Non-discrimination, anti-harassment, and violence prevention Policy. The Group Human Resources Department is responsible for the Policy. The Policy includes all measures to prevent, control and limit risks, information actions and awareness actions as well as the option to submit, investigate and deal with complaints. In particular, the Group implements a Whistleblowing Policy, within which an anonymous and confidential reporting platform operates in conjunction with a relevant email ([email protected]), where all employees and external partners can submit reports for workplace violations, after which a relevant investigation is carried out. Priority is to ensure transparency against fight corruption and fraud, safeguard integrity and fight any form of discrimination, violence and harassment at work. The Group also has a mechanism for submitting suggestions or complaints (Grievance Mechanism) from its interested parties. In this direction, a form for submitting suggestions or complaints has been created (https://www.lamdadev.com/en/conatct/public-grievance-form.html). In addition, specific requests for information can be submitted through the Group's social media, as well as directly to LAMDA Development at the following address: LAMDA DEVELOPMENT S.A./ 37A Kifissias Ave. (Golden Hall) /151 23 Maroussi, Greece /Phone: +30 210 7450600/Fax: +30 210 7450645/ [email protected] / https://www.lamdadev.com/en/, as well as through the dedicated website for the Hellinikon project (www.theellinikon.com.gr). The Group's main objective for the next reporting year is to conduct a Human Rights Due Diligence throughout the value chain.

Corruption/Bribery

The Group shows zero tolerance for corruption. Based on the Regulatory Compliance Policy and the regulatory compliance procedures manual, the Regulatory Compliance Unit is responsible for taking preventive, suppression/detection and response actions in relation to matters of business ethics, transparency, integrity, safeguarding the interests of shareholders and protecting the traders with the Group. In addition, the Group has drawn up an Anti-Corruption Policy, which has been approved and adopted by the BoD. This Policy reflects the framework accepted by the Group for offering and accepting gifts and other benefits, from employees to third parties and vice versa. The Policy also regulates matters of work employment, including internships, as well as matters of charitable donations. Employees and in general persons who fall within the definition of the Code of Ethics must comply with the Policy and bring to the attention of the Group incidents that may violate its provisions. For the best possible implementation of the above Policy, the Anti-Corruption Procedure has additionally been drawn up, which includes specific steps and safeguards required to deal with bribery and corruption issues. In addition, external and potential business partners must comply with the principles contained in the Supplier Code of Conduct, including the principles in relation to bribery and corruption. In addition, the Group has adopted and implements, a Conflict of Interest Policy, approved by the Board of Directors, in order to identify, prevent and manage situations that affect Group’s interests and its affiliated companies. All actual and potential conflicts of interest at the Board level are investigated, notified and documented to the Audit Committee, as defined in the relevant procedures. The Human Resources Department, in collaboration with the Regulatory Compliance Unit, organizes relevant trainings for employees, in order for the latter to be informed and aware of corruption issues.

Taxation

With respect to taxation matters, the Group ensures compliance with accounting and tax laws, statutory and other regulatory considerations for itself and all its subsidiaries. Compliance with tax legislation is also ensured through the issuance of an "Annual Tax Certificate". In addition, the Group recognizes and assesses risks related to tax issues as part of the risk management process.

Fair competition

The Group attaches particular importance to compliance with Competition Law. To this end, the Regulatory Compliance Unit has included Fair Competition issues in the Regulatory Compliance pillars that it supervises on a quarterly basis and reports to the Audit Committee. Within the year 2022, no incidents of violation of the relevant legislation have been reported to the Regulatory Compliance Unit and therefore the need to take and coordinate corrective measures has not arisen.

Accounting policy for the determination of key performance indicators (KPIs)

The key performance indicators of eligible (aligned and non-aligned) and non-eligible economic activities of the Group have been calculated based on the following Accounting Policy, as stated in the Disclosure Delegated Act 2021/2178.

Turnover (turnover KPI)

The proportion of turnover referred to in Article 8(2), point (a), of the Regulation (EU) 2020/852 is calculated as the part of the net turnover derived from products or services, including intangibles, associated with Taxonomy-aligned economic activities (numerator), divided by the net turnover (denominator) as defined in Article 2, point (5), of Directive 2013/34/EU. The turnover covers the revenue recognized pursuant to International Accounting Standard (IAS) 1, paragraph 82(a), as adopted by Commission Regulation (EC) No 1126/2008. The denominator includes the total sales of note 25 "Revenue" of the Annual Financial Report for the year ended December 31, 2022. The KPI referred to in the first subparagraph excludes from its numerator the part of the net turnover derived from products and services associated with economic activities that have been adapted to climate change in line with Article 11(1), point (a) of Regulation (EU) 2020/852 and in accordance with Annex II to Delegated Regulation (EU) 2021/2139, unless those activities qualify as enabling activities in accordance with Article 11(1), point (b) of Regulation (EU) 2020/852. To avoid double counting in the allocation in the numerator of turnover across economic activities, the figures used have eliminated intergroup transactions.

Capital expenditure (CapEx)

The proportion of CapEx referred to in Article 8(2), point (b), of Regulation (EU) 2020/852 is calculated as the numerator divided by the denominator as specified in points 1.1.2.1 and 1.1.2.2 of Annex I of the delegated Regulation (EU) 2021/2178.# Denominator

The denominator covers additions to tangible and intangible assets during the financial year considered before depreciation, amortization and any re-measurements, including those resulting from revaluations and impairments, for the relevant financial year and excluding fair value changes. The denominator also covers additions to tangible and intangible assets resulting from business combinations. For non-financial undertakings applying international financial reporting standards (IFRS) as adopted by Regulation (EC) No 1126/2008, CapEx shall cover costs that are accounted based on: (a) IAS 16 Property, Plant and Equipment, paragraphs 73, (e), point (i) and point (iii); (b) IAS 38 Intangible Assets, paragraph 118, (e), point (i); (c) IAS 40 Investment Property, paragraphs 76, points (a) and (b) (for the fair value model); (d) IFRS 16 Leases, paragraph 53, point (h). Leases that do not lead to the recognition of a right-of-use over the asset are not counted as CapEx. The denominator includes the "Capital expenditures on investment property" of under development and in operation investment properties of note 6 "Investment property", the "Additions", the "Additions due to acquisition of subsidiary" and the "Accumulated depreciation due to acquisition of a subsidiary" of note 7 "Tangible fixed assets", the "Additions" and "Additions due to acquisition of subsidiary" excluding column "Goodwill" of note 8 "Intangible Assets", , as well as the "Additions due to remeasurement of lease assets" and the "Additions" of note 19 "Leases" of the Annual Financial Report for the year ended 31 December 2022.

Numerator

The numerator equals to the part of the capital expenditure included in the denominator that is any of the following:
(a) related to assets or processes that are associated with Taxonomy-aligned economic activities;
(b) part of a plan to expand Taxonomy-aligned economic activities or to allow Taxonomy-eligible economic activities to become Taxonomy-aligned (‘CapEx plan’) under the conditions specified in the second subparagraph of point 1.1.2.2 of Annex I of the delegated Regulation 2021/2178 EU;

The CapEx plan, referred to in the first paragraph of this point, meet the following conditions based on point 1.1.2.2 of Annex I of the delegated Regulation 2021/2178 EU:
(a) the plan aims either to expand the undertaking’s Taxonomy-eligible and Taxonomy-aligned economic activities or to upgrade Taxonomy-eligible economic activities to render them Taxonomy-aligned within a period of five years;
(b) the plan is disclosed at economic activity aggregated level and be approved by the management body of non- financial undertakings either directly or by delegation.

The CapEx plan, referred to in the first paragraph of point 1.1.2.2 of Annex I of the delegated Regulation 2021/2178 EU, meet the following conditions:
(a) the plan aims either to expand the undertaking’s Taxonomy-eligible and Taxonomy-aligned economic activities or to upgrade Taxonomy-eligible economic activities to render them Taxonomy-aligned within a period of five years;
(b) the plan is disclosed at economic activity aggregated level and be approved by the management body of non- financial undertakings either directly or by delegation.

Where the relevant technical screening criteria are amended before the completion of the CapEx plan, non- financial undertakings shall either update the plan within two years to ensure the economic activities referred to in point (a) are aligned with the amended technical screening criteria upon the completion of the plan or restate the numerator of the CapEx KPI. The updating of plan shall restart the period referred to in point (a). The period referred to point (a) of the second paragraph of this point 1.1.2.2 can exceed five years only where a longer period is objectively justified by specific features of the economic activity and the upgrade concerned, with a maximum of 10 years. That justification shall feature in the CapEx plan itself and in the contextual information detailed under point 1.2.3 of the Annex I of the delegated Regulation 2021/2178 EU. Where the CapEx plan fails to meet the conditions referred to in the second paragraph of this point 1.1.2.2, previously published KPI related to capital expenditure shall be restated. The numerator also contains the part of the CapEx for adaptation of economic activities to climate change in accordance with Annex II to this Climate Delegated Act. The numerator provides for a breakdown for the part of CapEx allocated to substantial contribution to climate change adaptation. To avoid double counting in the allocation in the numerator of CapEx across economic activities, the figures have eliminated intergroup transactions.

Operating expenditure (OpEx)

The proportion of OpEx referred to in Article 8(2), point (b), of Regulation (EU) 2020/852 is calculated as the numerator divided by the denominator as specified in points 1.1.3.1 and 1.1.3.2 of the Annex I of the delegated Regulation 2021/2178 EU.

Denominator

The denominator covers direct non-capitalized costs that relate to building renovation measures, short-term lease, maintenance and repair, and any other direct expenditures relating to the day-to-day servicing of assets of property, plant and equipment by the undertaking or third party to whom activities are outsourced that are necessary to ensure the continued and effective functioning such assets. The denominator includes all the lines "Repairs and maintenance costs" and "Cleaning services" of notes 26 "Expenses related to investment property", 27 "Expenses related to the development of the Ellinikon site" and 29 "Other operating income / (expenses) - net" of the Annual Financial Report for the year ended 31 December 2022.

Numerator

The numerator equals to the part of the capital expenditure included in the denominator that is any of the following:
a) related to assets or processes associated with Taxonomy-aligned economic activities, including training and other human resources adaptation needs, and direct non-capitalized costs that represent research and development;
b) part of the CapEx plan to expand Taxonomy-aligned economic activities or allow Taxonomy-eligible economic activities to become Taxonomy-aligned within a predefined timeframe as set out in the second paragraph of point 1.1.3.2 of the Annex I of the delegated Regulation 2021/2178 EU.

The CapEx plan, referred to in the first paragraph of point 1.1.3.2 of Annex I of the delegated Regulation 2021/2178 EU, shall meet the conditions specified in point 1.1.2.2 of the Annex I of the delegated Regulation 2021/2178 EU. Research and development costs already accounted for in the CapEx KPI is not counted as OpEx. To avoid double counting in the allocation in the numerator of OpEx across economic activities, the figures have eliminated intergroup transactions.

Key Performance Indicators 2022

In the following tables the percentages of turnover, CapEx and OpEx of Taxonomy aligned, Taxonomy-non- aligned and Taxonomy-non eligible economic activities for the financial year 2022, are presented, according to the results of the alignment assessment of the economic activities of the Group. In the financial year 2022, 79% of turnover, 61% of capital expenditure (CapEx) and 70% of operating expenditure (OpEx) of the Group were determined to be related to eligible non-aligned, with the EU Taxonomy Regulation, economic activities.

Turnover

Substantial contribution criteria	Economic activities	Codes	Turnover	Proportion of total Turnover	Climate change mitigation	Climate change adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems	Climate change mitigation	Climate change adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems	Minimum safeguards	Taxonomy -aligned proportion of Turnover FY22	Taxonomy -aligned proportion of Turnover FY21
			€m	%	%	%	%	%	%	%	%	%	%	%	%	%	Y/N	%	%
A. Taxonomy-Eligible Activities
A.1 Environmentally sustainable (taxonomy-aligned) activities				0%	0%	0%	0%	-	-	-	-	0%	*	0%	0%
A.2 Non environmentally sustainable (non-taxonomy-aligned) activities	Electricity generation from wind power	4.3		0%
	Construction of new buildings	7.1		21,9%	16%
	Acquisition and ownership of buildings	7.7		89,6%	63%
	Libraries, archives, museums and cultural activities	13.2		0,1%	0%
	Total Turnover from taxonomy-non-aligned activities (A.2)		111,7	79%
	Total Taxonomy-eligible Turnover (A.1 + A.2)		111,7	79%	0%	*	0%	0%
B. Taxonomy-Non-Eligible Activities	Sales and rental of plots of land	30,0		21%
	Total Turnover from Taxonomy-non-eligible activities (B)		30,0	21%
	Total Turnover (A+B)		141,7	100%

There was no obligation to be calculated for 2021

CapEx

Substantial contribution criteria	DNSH criteria ('Does No Significant Harm')	Economic activities	Codes	CapEx	Proportion of total CapEx	Climate change mitigation	Climate change adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems	Climate change mitigation	Climate change adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems	Minimum safeguards	Taxonomy- aligned proportion of CapEx FY22	Taxonomy- aligned proportion of CapEx FY21	Category (Enabling activity)	Category (Transitional activity)
				€m	%	%	%	%	%	%	%	%	%	%	%	%	%	Y/N	%	%
A.

OpEx

Economic activities	OpEx	Proportion of total OpEx	Climate change mitigation	Climate change adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems	Climate change mitigation	Climate change adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems	Minimum safeguards	Taxonomy- aligned proportion of OpEx FY22	Taxonomy- aligned proportion of OpEx FY21
	€m	%	%	%	%	%	%	%	%	%	%	%	%	%	Y/N	%	%
A. Taxonomy-Eligible Activities
A.1 Environmentally sustainable (taxonomy-aligned) activities
Total OpEx from taxonomy-eligible and aligned activities (A.1)	0	0%	0%	0%	-	-	-	-	0%	*	0%	0%
A.2 Non environmentally sustainable (non-taxonomy-aligned) activities
Electricity generation from wind power	4.3	0	0%
Construction of new buildings	7.1	0	0%
Acquisition and ownership of buildings	7.7	3,6	68%
Libraries, archives, museums and cultural activities	13.2	0,1	2%
Total OpEx from taxonomy-non-aligned activities (A.2)		3,7	70%
Total Taxonomy-eligible OpEx (A.1 + A.2)		3,7	70%	0%	*	0%	0%
B. Taxonomy-Non-Eligible Activities
Exploitation of Marinas, other	1,6	30%
* There was no obligation to be calculated for 2021
Total OpEx from Taxonomy-non-eligible activities (B)		1,6	30%
Total OpEx (A+B)	5,3	100%

I. CORPORATE GOVERNANCE DECLARATION

This Corporate Governance Statement is a special section of the Annual Report of the Board of Directors of "LAMDA Development S.A." (the "Company") and has been prepared in accordance with Article 152 of Law 4548/2018, Article 18 of Law 4706/2020, as well as the Greek Corporate Governance Code 2021 (the "HCGC") of the Hellenic Corporate Governance Council, and in particular in accordance with both the Special Practices contained in the Hellenic Corporate Governance Code and Part E referring to the guidelines for preparing the Corporate Governance Statement.

A. Notes on the Corporate Governance Code

The Company has adopted the HCGC of the Hellenic Corporate Governance Council, as revised in 2021. The HCGC was adopted at the Company's Board of Directors meeting dated 16.7.2021. The HCGC has been uploaded on the Company's website (www.lamdadev.com).

A.1 Deviations from the HCGC and explanation of the reasons for non-compliance

The following table lists the Special Practices (SPs), which are governed by the "comply or explain" principle, and from which the Company deviates, as well as the explanation of the reasons for non-compliance:

SP	Description of SP	Non-compliance explanation
2.4.13	The maturity of the preemptive rights is defined for a period not less than three (3) years from the date of their granting to the executive members of the Board of Directors.	The Stock Option Plan to the management and staff of the Company and its affiliated companies within the meaning of article 32 of Law 4308/2014 (the "Stock Option Plan"), which is currently in progress, was approved by resolution of the Extraordinary General Meeting of the Company's Shareholders dated 22.12.2020 Regarding the maturity of the options, the Stock Option Plan provides that the initial options will mature after two (2) years and the beneficiary may exercise options up to a maximum of 50%. It also provides that after the lapse of three (3) years, the beneficiary will be able to exercise in maximum the remaining percentage of options (i.e. the remaining 50% or other remaining percentage). This HCGC Practice applies to the CEO of the Company. It is noted, however, that when the initial options matured upon the lapse of two years, on 22.12.2022, neither he nor the other executives exercised such options.

B. Notes on the Internal Regulation

The Company has adopted an Internal Regulation (hereinafter the "Regulation"), which has been prepared in accordance with the regulatory decisions of the Hellenic Capital Market Commission and Law 4706/2020 on corporate governance of societes anonymes listed on the Athens Exchange. Its latest revision was approved at the Board of Directors' meeting dated 25/5/2022, a summary of which is posted on the Company's website (www.lamdadev.com).

The Regulation operates complementary to the provisions of the Company's Articles of Association. It is noted that the Company's Articles of Association, as in force according to the resolution of the General Meeting of Shareholders of 10.10.2019, are posted on the Company's website and their amendment are subject to a simple majority vote. The content of the Regulation complies with the minimum content required to be included, according to article 14, paragraph 3 of Law 4706/2020. In addition, the Regulation is based on the Company's current organizational chart, it corresponds to its size and object and contains binding provisions regarding the powers and responsibilities of the Company's administrative bodies and senior management.

The Regulation governs, inter alia:

The organisational structure, the respective objects of the operational units and various committees, and the tasks and responsibilities of their respective heads, as well as the reporting lines of the organization.
The reporting lines of the main features of the Internal Control System, namely the Internal Audit Service, the Risk Management Unit and Compliance Unit.
The Procedure for the Recruitment and Performance Evaluation of Senior Management Officers.
The procedure for ensuring the compliance of persons discharging financial responsibilities, as defined in article 3, par. 1(25) of Regulation (EU) No. 596/2014, as well as persons closely associated with them, as defined in Article 2, par. 14 of Law 4706/2020, including the obligations arising from the provisions of Article 19 of Regulation (EU) 596/2014.
The procedure for the disclosure of relationships of dependency between the independent non-executive BoD members and the persons closely associated with them.
The procedure for the compliance with the obligations arising from articles 99 to 101 of Law 4548/2018, on related-party transactions.
The policies and procedures for the prevention of and response to conflict of interest.
The policies and procedures for the compliance of the Company with the legislative and regulatory provisions governing its organisation and operation, as well as its activities.
The procedure for the management of inside information and for ensuring that the public is correctly informed, according to the provisions of Regulation (EU) 596/2014.
The policy and procedure for the periodic evaluation of the Internal Control System, as well as for the implementation of the provisions on corporate governance under Law 4706/2020.
The Training Policy for Directors, Management Officers & Other Officers of the Company involved in Internal Audit, Risk Management, Compliance and Information Systems.
The Sustainable Development Policy of the Company.

The Purpose of the Regulation is to regulate the organization and operation of the Company in order to ensure:

Business Integrity;
Transparency of business
Supervision of the Management and in particular the decision-making process.
Compliance with the legislation and in particular with the obligations laid down for listed companies.

The Regulation is communicated to the Company's employees, who must comply with it.

C. Notes regarding the General Meeting of Shareholders

The General Meeting of Shareholders is the supreme organ of the Company, it is convened by the Board of Directors and has the power to decide upon all matters relating to the Company. Under the Articles of Association and according to paragraph 3, article 130 of Law 4548/2018, the following matters fall within the exclusive competence of the General Meeting:

any material change in the Company’s business,
any amendment to Article 2 of the Articles of Association,
the cessation of operations of material subsidiaries of the Company,
any agreement of the Company by which it undertakes to proceed to a material change of business or to the amendment of Article 2 of its Articles of Association or to the aforementioned cessation of operations.

The General Meeting validly resolves on all the aforementioned matters to the extent that no objections are raised by shareholders holding 10% of the Relevant Equity Shares (as defined under article 19 of the Articles of Association). The duly-taken decisions of a lawfully convened General Meeting are binding on all, including the absent or disagreeing, Shareholders.

C1. Attendance of Shareholders at the General Meeting

The General Meeting may be attended by the shareholders, in person or by duly authorised proxy, pursuant to the legal procedure as in force from time to time.# Entitled to participate and vote in the General Meeting shall be any person that on the beginning of the fifth (5th) day before the date of the General Meeting (the "Record Date") is recorded as shareholder in the records of the securities system where the Company's securities are held. The Record Date shall also apply in the case of an adjourned meeting, provided that such adjourned meeting is not held later than thirty (30) days from the Record Date. Exercising the aforesaid rights is not subject to the blocking of the shareholder's shares nor to any other similar procedure. The shareholders may appoint proxies to represent them, should they so wish. For any other matter, the Company conforms with the provisions of Codified Law 4548/2018, as in force from time to time. The Company supports and ensures both the participation of the shareholders in the general meetings and the effective exercise of their rights to the maximum extent possible. In order to ensure the greatest possible participation of shareholders in the General Meeting on the basis of full information, the Company sets up mechanisms for the timely publication of the Notice of the General Meeting, which must at least specify the date, venue, proposed agenda and exact description of the procedures for the participation and voting of shareholders. The Board of Directors ensures that the preparation and holding of the Shareholders' General Meeting facilitates the efficient exercise of the shareholders' rights, within the limits of the relevant statutory provisions, and the participation of said shareholders in the meeting, especially that of the minority shareholders, foreign and remotely residing shareholders.

C.2. Voting Procedure at the General Meeting

The Shareholders may attend the General Meeting and vote therein either in person or by proxy. Every Shareholder may appoint up to three (3) proxies and if the shareholder is a legal entity they may appoint up to three (3) natural persons as proxies. In case any shareholder has Company's shares recorded in more than one securities accounts, such shareholder may appoint different proxies to represent the shares recorded in each securities account. A proxy acting for and on behalf of more than one shareholders may vote differently for each shareholder.

It is noted that, provided that the Board of Directors confirms that the Company's logistical infrastructure has been adapted in advance to ensure the identification of shareholders and the security of the electronic or other connection, and to enable the transmission of the Meeting or two-way communication, the shareholders may participate at the General Meeting by electronic means, i.e. without physical presence at the venue of the General Meeting. This participation may take place via real time transmission of the meeting or real time two- way communication, enabling shareholders to address the General Meeting from a remote location. The company's Board of Directors shall be responsible to establish whether the above requirements, such as are necessary to ensure the technical feasibility and security of the participation in the General Meeting by electronic means, are met.

Provided that the Board of Directors confirms that the Company's logistical infrastructure has been adapted in advance to ensure the identification of shareholders and the security of the electronic or other connection, the Company's shareholders shall be able to participate remotely in the voting of the General Meetings either by exercising their voting rights by electronic means or by postal voting. In such an event, the Company shall distribute ballot forms beforehand either in electronic format via its website or in paper form at its registered office. The exercise of voting rights by electronic means may take place before or during the General Meeting. In any case, the Board of Directors shall include in the Notice of the General Meeting all the necessary information on the possibility of distant voting and the participation in the General Meeting by electronic means. If the Board of Directors determines that the technical requirements for the secure holding of the General Meeting by electronic means or the shareholders' distant voting at the General Meeting, are not met, then it shall mention this fact in the notice of the General Meeting.

Voting at the General Meeting takes place by open ballot system. The Company shall publish, under the responsibility of the Board of Directors, the results of the voting within five (5) days at the latest from the date of the General Meeting, specifying, for each resolution, at least the number of shares for which valid votes were cast, the shareholding represented by such shares, the total number of valid votes, and the number of votes in favour and against any resolution and the number of abstentions.

C.3. Minority Rights

As regards minority rights, article 23 of the Company's Articles of Association shall apply. More specifically:

All issues pertaining to minority issues and minority rights shall be governed by the provisions of Law 4548/2018, as in force.
At the request of shareholders representing at least 10% of the Relevant Equity Shares, or at the request of the Minority Shareholder, to the extent that the latter represents at that time at least 10% of the Relevant Equity Shares, such request to be submitted to the Company within the timeframe of Article 141, par. 6 of Law 4548/2018, the Board of Directors is obliged to provide the General Meeting with the following information:
(a) non-confidential information regarding any event or development that occurs within the Company or which comes to the attention of the Company and which could reasonably be expected to cause a material change to the Group’s business or the cessation of operations of any material subsidiaries of the Company, lead to the de-listing of the shares of the Company and/or to the conversion of the Company into a private company and/or affect its ability to perform its material obligations relating to the acquisition by the Minority Shareholder of the 12.83% of the share capital of the Company on 2.7.2014; and
(b) material details of any formal third-party written offer or approach (officially coming to the attention of the Board of Directors) which might reasonably be expected to lead to any sale or disposal or a series of sales or disposals by Consolidated Lamda Holdings S.A. (and/or by persons affiliated to such shareholder) of securities (including shares, preferred shares, any convertible securities as well as stock options or convertible bond options into shares and/or shareholder loans) that exceed in aggregate 5% of the securities issued from time to time by the Company or by any holding company thereof, with a substantially similar share capital structure to that of the Company, to any third party that is not an affiliate entity with such shareholder (or does not constitute a shareholder, partner, representative or agent of such affiliated entity established in any jurisdiction directly or indirectly with the purpose to hold such shares on its behalf or on behalf of another affiliate) such sale or series of sales being completed through transfer of legal ownership against consideration during the twelve (12) month period starting on 3 July 2014 or any successive twelve month period, unless in the case of a bona fide sale on an arm’s length basis by a holder of Company securities that holds those securities solely as (an in rem) security for any loan, credit, liability or obligation duly created on an arm’s length basis.

It is noted that, according to Articles 10, paragraph 11 and 12 of the Company's Articles of Association:
* “Minority Shareholder” shall mean the legal entity “VOXVOCE HOLDINGS LIMITED” and any other person that may succeed it lawfully and without contractual breach, by acquiring at least 10% of the Relevant Equity Shares of the Company.
* “Relevant Equity Shares” shall mean the share capital of the Company, as formed from time to time, excluding any shares issued under any stock option plan in force approved by resolution of the General Meeting and under any other stock option plan approved pursuant to Article 113 of Law 4548/2018.

C.4. Investor Relations and Corporate Communications Department

The Company has established and maintains an Investor Relations and Corporate Announcements Department responsible, inter alia, for:

General Meeting of Shareholders:

providing information on annual or extraordinary general meetings and the resolutions adopted by them
communicating and sharing information and data with Central Securities Depositories and mediators for shareholders identification purposes
maintaining channels of communication with shareholders
informing shareholders, in conformity with the provisions of article 17 of Law 3556/2007 (Α` 91), on the facilities and data provided by the Company
monitoring the exercise of rights attached to shares, especially as regards shareholders' ownership interests and the exercise of voting rights in general meetings.

Corporate announcements:

the necessary announcements concerning regulated information, in accordance with the provisions of Law 3556/2007 (A' 91), as well as corporate events in accordance with the provisions of Law 4548/2018 (A' 104), in order to inform shareholders or holders of other securities of the Company
the Company's compliance with the obligations provided for in Article 17 of Regulation (EU) 596/2014 regarding the disclosure of privileged information and other applicable provisions.# D. Notes on the Board of Directors

The operation of the Board of Directors of the Company is governed by the Internal Regulation, which is posted on the Company's website (www.lamdadev.com).

D.1. The role of the Board of Directors

The Board of Directors shall be competent to decide upon all issues pertaining to the representation, administration, and management of the Company and the fulfillment of its corporate object in general. In the exercise of its duties, the Board of Directors shall have extensive powers, limited only by the actions or decisions that fall within the competence of the General Meeting. Indicatively and not restrictively, the Board of Directors convenes the General Meetings of shareholders, ordinary or extraordinary, and sets the agenda items. It also prepares the annual financial statements and annual reports in accordance with the each time applicable provisions of Law 4548/2018 and submits them to the Ordinary General Meeting for approval, proposing at the same time the depreciation to be made on the establishment costs and the necessary Annual financial report for the year ended 31 December 2022 72 deductions for the statutory reserve. The Board of Directors must ensure that the annual financial statements, the annual management report and the corporate governance statement, the consolidated financial statements, the consolidated management reports and the consolidated corporate governance statement, if any, as well as the remuneration report under article 112 of Law 4548/2018 are prepared and published in accordance with the provisions of the applicable laws. It is competent to propose the dividends to be distributed, to determine the Company's establishments and operations, the general expenses, to hire and terminate personnel, to keep meeting Minutes, to conclude contracts, etc. The Board of Directors shall arrange for the completion of the publication formalities provided in articles 12 and 13 of Law 4548/2018, as in force. However, the powers of the Board of Directors shall be subject to articles 19 and 99-101 of Law 4548/2018, as in force.

By decision of the Board of Directors, the powers of management and representation of the Company may be delegated to one or more persons, than may but need not be, Directors. The same decision shall also determine the extent of this delegation and the authority to further sub-delegate, in whole or in part, the powers vested in them to other Directors or any third parties. This authorization may be granted for an indefinite or specific period, or for specific actions.

The Board of Directors also has the power to decide upon bond issues, with the exception of those that fall within the competence of the General Meeting pursuant to articles 71 and 72 of Law 4548/2018. As regards convertible bonds, the Board may decide on their issue following authorization of the General Meeting, in accordance with article 24, of Law 4548/2018.

D.2. Responsibilities of the Board of Directors

The main, non-delegable, responsibilities of the Board of Directors include:

Determining the Company's values and strategic orientation, as well as continuously monitoring their compliance. At the same time, the Board of Directors remains responsible for the approval of the Company's strategy and business plan. The Board of Directors also regularly reviews the opportunities and risks in relation to the defined strategy, as well as the relevant measures taken to address them. It may seek to obtain information from the CEO and the managing officers, as well as updates about the market and any other developments affecting the Company.
Ensuring that the Company's values and strategic planning are in line with the corporate culture. The Company's values and purpose are translated and applied in practice and influence practices, policies and behaviours within the Company at all levels. The Board of Directors and the senior management set the standard for the characteristics and behaviours that shape the corporate culture and are an example of its application. At the same time, they use tools and techniques aimed at integrating the desired culture into the Company's systems and procedures.
Determining the nature and extent of the Company's exposure to the risks that the Company intends to assume in the context of its long-term strategic objectives.
Establishing a policy for the prevention, identification and management of conflicts of interest among its members or persons to whom the Board has delegated some of its powers. This policy is based on clear procedures, which define the manner of timely and complete disclosure to the Board of Directors of their interests in transactions between related parties or any other possible conflict of interest with the company or its subsidiaries. Measures and procedures shall be evaluated and reviewed to ensure their effectiveness.
Providing the appropriate approval, monitoring the progress of the implementation of the strategic guidelines and objectives and ensuring the availability of the necessary financial and human resources, as well as the existence of an internal control system.
Determining the responsibilities of the Chief Executive Officer.
Approving the annual budget and the business plan, as well as taking decisions on major capital expenditures, acquisitions and divestments.
Selecting and, if required, replacing the executive members of the Board, as well as overseeing the planning of their succession.
The performance review of senior management and the alignment of the remuneration of senior officers with the long-term interests of the Company and its shareholders, taking into account the relevant recommendations of the Compensation and Nomination Committee.
Ensuring the reliability of the Company's financial statements and data, the financial reporting systems and the data and information that are made public, as well as ensuring the effectiveness of the internal control and risk management systems.
Ensuring the adoption of an effective procedure for the Company's compliance with applicable laws and regulations.
Responsibility for making relevant decisions and monitoring the effectiveness of the Company's management system, including decision-making procedures and the delegation of powers and duties to other officers.

In addition the Board:

Approves the annual report of the Company and anything else required by the capital market legislation.
The Board of Directors binds and monitors the executive administration on matters relating to new technologies and environmental issues in accordance with HCGC Special Practice 5.9.
Approves partnerships of subsidiaries, aimed at establishing new companies or strategic joint ventures with third parties, mergers and acquisitions of companies.
Resolves on the Company's entry into other sectors of activity.
Decides on the acquisition/establishment/sale of subsidiaries.
Approves participation for developments/investments or even disinvestments, including real estate sales, above EUR 10 million.
It sets the maximum total amount of developments/investments for each year.
Decides to take legal action in favour of the Company.
Defines and oversees the implementation of the corporate governance system under the provisions 1 to 24 of Law 4706/2020.
It ensures that the functions constituting the Internal Control System, and in particular the set of internal control mechanisms and procedures, including risk management, internal audit and compliance, are independent of the business areas they control, and that they have the appropriate financial and human resources, as well as the authority to operate effectively, as required by their role.

D.3. Composition, establishment and term of office of the Board of Directors.

The Board is made up of executive, non-executive and independent non-executive directors. The directors' capacity as executive or non-executive members is determined by the Board of Directors. Independent non- executive directors are appointed by the Company's General Meeting of Shareholders and may not be less than one-third (1/3) of the total number of directors and, in any case, may not be less than two (2). If the resulting percent is a fraction, their number is rounded up to the nearest integer. They meet all the independence requirements set out under Law 4706/2020.

The size and composition of the Board enable the efficient fulfilment of its responsibilities, and reflect the size, activity and ownership status of the Company. Article 10 of the Company's articles of association includes provisions on the size, term of office and appointment of the members of the Board. More specifically:

The Company is administered by a Board of Directors consisting of minimum five (5) to maximum fifteen (15) Members that are elected by the Shareholders' General Meeting and that may, but need not be, Shareholders. The Members may be either natural or legal persons. In the case that a legal person is Member of the Board of Directors, it is required to designate a natural person to exercise its powers as member of the Board of Directors. The elected Members of the Board of Directors may be reelected. The General Meeting may, as and when it considers appropriate, elect Substitute Members, up to a number that shall not surpass that of the ordinary Members.# Annual Financial Report for the Year Ended 31 December 2022

D.4. Composition and term of office of the current Board of Directors.

The current Board of Directors of the Company was elected by the Extraordinary General Meeting of the Company's Shareholders on 22 December 2020 for a five-year term of office, i.e. until 22.12.2025 and may be extended until the first Ordinary General Meeting convened after the expiration of the said five-year term, but cannot exceed six (6) years in total. The Board of Directors consists of twelve (12) members. Out of the total members of the Board, one is an executive director and the remaining members are non-executive directors, four (4) of which are independent non-executive directors. Its composition is as follows:

Full name	Position on the Board	Term of office of each member including expiry date
Giannitsis Anastasios	Chairman, Non-executive Director	22.12.2020 - 21.12.2025
Chronis Evangelos	Vice-Chairman, Non-executive Director	22.12.2020 - 21.12.2025
Athanasiou Odyssefs	CEO, Executive Member	22.12.2020 - 21.12.2025
Vasilakis Eftychios	Non-executive Director	22.12.2020 - 21.12.2025
Bussetil Emmanuel 1	Non-executive Director	25.05.2022 - 21.12.2025
Zafiriou Ioannis	Senior Independent Non-executive Director	22.12.2020 - 21.12.2025
Katsos Vassilios	Non-executive Director	22.12.2020 - 21.12.2025
Kotsolis Stefanos 2	Non-executive Director	24.11.2022 -21.12.2025
Kyriazis Chariton	Independent Non-executive Director	22.12.2020 - 21.12.2025
Nomikos Calypso Maria	Independent Non-executive Director	22.12.2020 - 21.12.2025
Paizi Evgenia	Non executive-Director	22.12.2020 - 21.12.2025
Papadopoulou Ioanna	Independent Non-executive Director	22.12.2020 - 21.12.2025

Notes:

The Board of Directors of the Company, at its meeting on 25.5.2022 accepted the resignation of Mr Fotios Antonatos dated 25.5.2022 from the position of non-executive Director of the Company and elected Mr Emmanuel Bussetil as a non-executive Director for the remainder of the term of the resigned member. This replacement was announced to the Company's Ordinary General Meeting on 23.06.2022
The Board of Directors of the Company, at its meeting on 24.11.2022 accepted the resignation of Mr Aris Sermpetis dated 23.11.2022 from the position of non-executive Director of the Company and elected Mr Stefanos Kotsolis as a non-executive Director for the remainder of the term of the resigned member. It is noted, however, that according to the recommendation of the Compensation and Nomination Committee of 22.11.2022, Mr Stefanos Kotsolis meets the conditions of independence, since he meets the criteria of article 9 of Law 4706/ 2020, and for this reason the Board of Directors intends to table a motion at the next General Assembly for his appointment as an independent non-executive Director.

D.5 Directors CVs

Below are the CVs of the members of the Board of Directors:

Anastasios Giannitsis, Chairman, Non-Executive Director. Professor at the National Kapodistrian University of Athens until 2011. Since then he holds the title of emeritus professor. He studied Law and Economic & Political Sciences at the University of Athens and obtained his PhD in economics at the Free University of Berlin. He served as Minister of Labor and Social Affairs, Alternate Minister of Foreign Affairs, Minister of Foreign Affairs and Minister of Interior, Economic Advisor to the Prime Minister, President of Economic Advisors, President of Hellenic Petroleum Co. Member of the Board of Directors of the National Bank of Greece Cultural Foundation and Honorary Member of Special Olympics Hellas. He has published many books and articles on economic, social and political issues. His research focuses on issues of development theory and policy, the problems of the Greek economy, international economics, issues of European integration and the economics of technology.

Evangelos Chronis, Vice-Chairman, Non-Executive Director Mr Evangelos Chronis studied shipping in London and worked closely with John S. Latsis for 28 years. Today, he serves as Chairman and Member of the BoD for a number of the Latsis Group companies, as well as for non-profit and charitable organizations.

Odyssefs Athanasiou, CEO, Executive Director Mr Odyssefs Athanasiou holds the position of Chief Executive Officer at LAMDA Development S.A. for more than 13 years. He has a long experience in senior executive positions in Greece and abroad. In his 9-year career in the U.S., he worked at Ernst & Young and Emerson Electric. He has served as CFO for Western Europe at Barilla, based in Paris, CFO at Diageo Hub Greece-Turkey and CFO for Greece at Titan cement company. He holds a BSc in Economics and Political Science from the University of Athens and an MBA from the University of Texas in Austin. Mr Athanasiou is a member of the Board of Directors of Endeavor Greece, a founding member of the non-profit initiative Coalition for Greece, and member of the TEDX Academy Greece committee.

Eftychios Vasilakis, Non-executive Director Mr. Eftichios Vassilakis is the Chairman of AEGEAN and Olympic Air and also the CEO of Autohellas S.A. /Hertz. He holds non-executive directorships with Greek listed retailer Fourlis, with listed real estate holding company Lamda Deveopment and also with the luxury resorts developer company TEMES, as well as on the boards of other larger and smaller companies. He previously served as a non-executive member of the Board of Directors of Piraeus Bank and TITAN Cement. He has been a member of the Board of Directors of the Greek Tourism Confederation (SETE) since 2011, and in 2014 he has been appointed Vice President. He is both a member of the Board of Directors and the Executive Board of the Hellenic Federation of Enterprises (SEV). He is a member of the Board of Directors and one of the founders of "Marketing Greece" as well as of the consortium to enhance the tourism and cultural promotion of Athens "This is Athens". Mr. Vassilakis holds a B.A. in Economics from Yale University (1988) and an MBA from the Columbia Business School of New York (1991). He is married with three children.

Emmanuel L. Bussetil, Non-Executive Director. Mr Εmmanuel Bussetil joined the Latsis group of companies in 1982 as Chief Internal Auditor and, since then, he has held a number of executive and non-executive positions for other principal commercial holding and operating companies controlled by Latsis Family Interests. Prior to that, he was an Audit Manager at Pricewaterhouse in the United Kingdom, where he was employed from 1976 to 1982. Mr Bussetil received his GCSE A-Levels in mathematics and physics in 1970.# Annual financial report for the year ended 31 December 2022

77

He attended the Thames Polytechnic London, UK, and obtained his Higher National diploma in mathematics, statistics & computing in 1972. His professional training was undertaken as an Articled Clerk at Dolby Summerskill, Liverpool (1972/1973), and at Morland and Partners, Liverpool (1974/1976). He is a Fellow of the Institute of Chartered Accountants of England and Wales.

Ioannis Zafiriou, Senior Independent Non-Executive Director

Throughout the course of his international banking career, Mr Ioannis Zafiriou has occupied a number of roles covering all areas of finance. He began working in New York City at Bankers Trust and subsequently moved to Milan focusing on Italian government agencies, financial institutions and corporates in the area of derivatives. In 1990, he joined Credit Suisse’s Investment Bank (Credit Suisse First Boston, CSFB) with a team of colleagues and established a subsidiary of the Credit Suisse. In 1998, became the head of the European Fixed Income and Equities Group at CSFB with focus on European institutional clients. Furthermore, he was a member of the Global management and Operating Committee of CSFB. In 2004, he moved to the Wealth Management Division of Credit Suisse and established a global investment banking unit, Credit Suisse Solution Partners, while he was a member of the Management Board of the Private Bank. Mr Zafiriou was also extensively involved in real estate sector. He has a BA in Economics from Amherst College and an MBA in Finance from the NYU Stern School of Business. He was a member of the General Council of the HSFS (Hellenic Financial Stability Fund) from 2012 to 2015.

Vassilios Katsos, Non-executive Director

Mr Vassilios Katsos was born in Athens in 1973. He graduated from Pierce College and continued his studies at the University of Athens, Faculty of Pharmacy. Since 1993 he became President of the Board of Directors at Pharmathen Pharmaceuticals as one of the major shareholders. Under his leadership, the strategic restructuring of the family company, placing emphasis first on strengthening the company’s presence and thereafter on the expansion of international activities. In 2015 BC Partners has acquired significant majority in Pharmathen, which today is an international pharmaceutical company headquartered in The Netherlands with operations in more than 85 countries across the world. As Chairman – Co founder of VNK Capital, has actively pursued and invested in a growing portfolio companies such as Pharmathen, Innovis, Lamda Development , Palirria, Cafetex, among others. In April 2009, Mr. Katsos was announced as the “Entrepreneur Of The Year 2008” by Ernst & Young and participated as country winner in Monte Carlo for the 9th Annual Ernst & Young World Entrepreneur Of The Year Award. Through his intense entrepreneurial activities he sits on the board of various companies where he has invested and has been recipient of various awards and distinctions internationally and in Greece for his business activities.

Stefanos Kotsolis, Non-executive Director

Mr Stefanos Kotsolis was born in 1962 in Athens. He went to high school in the Hellenic American Educational Foundation (Athens College) and subsequently studied Civil Engineering in the National Technical University of Athens on a state scholarship. After his graduation, he continued his education in Yale University (1986-1988), where he obtained a Master’s in Business Administration. During 1988- 1990, he worked for Citicorp in New York and Athens (Global Finance), participating in the planning and financing of energy projects in the Middle East. During 1991-2007, he was active in the public works sector as a shareholder and CEO of a construction company, specialized in state buildings, as well as in infrastructure and energy projects. Since 2000, he has also acted as a shareholder and CEO of a real estate development company, constructing several housing and office buildings, having implemented a large number of relevant projects. During 2019-2022, he served as the General Director of the Hellenic Cadastre.

Chariton Kyriazis, Independent Non-executive Director

Mr Chariton Kyriazis is a Civil Engineer (NTUA), has an MBA from INSEAD and a Ph.D. from the University of London. He initially worked in manufacturing, and served as General Secretary of the National Economy (1992-1993). From 1994 to 2011 he was Head of the Tax and then Consulting department of Arthur Andersen and of the Advisory department of PwC, with experience in private and public sector projects. He was an elected member of the Board of SEV for 21 years, where he served as Executive Vice-President (2011-2015) and as Advisor to the Board in matters of social dialogue and corporate governance (until Sep. 2019). Today he is a business consultant, and participates in the Board of Directors or as Chairman of the Audit Committee of listed and non-listed companies (currently Lamda Development, PQH, Skama). He participates, among other, in the Governing Body of the International Labour Organization (ILO) and is the Chairman of the Social Affairs Committee of BusinessEurope.

78

Calypso Maria Nomikos, Independent Non-executive Director

Ms Calypso Maria Nomikos is chairwoman of the Board of Directors of A.M. Nomikos Transworld Maritime Agencies S.A., a family-owned international ship owning and ship management company. She sits on the boards of various other international companies in the shipping industry. She is currently a member of the advisory board of a Family Office in Greece and that of several NGOs such as Solidarity Now, the Museum of Cycladic Art, and MDA Hellas. Ms Calypso Nomikos previously held the position of Vice Chairwoman of the Board of Directors of S&B Industrial Minerals S.A., until the company was taken private in June 2013 and was a board member of the Greek branch of Transparency International. She holds a BSc in Economics and Business Administration and has completed the President's Program in Leadership (PPL) at Harvard Business School.

Evgenia Paizi, Non-executive Director

Ms Evgenia Paizi is Group Investment Officer at the SETE Family Office in Geneva. She joined the Latsis Group in 2001 and is involved in business development for the Group's activities in healthcare, asset management and other investments in Europe and the Middle East. She serves on the board of directors of companies in Switzerland, Luxembourg and Saudi Arabia. Prior to joining the Group, Mrs Paizi held positions in banking in Greece, including at the National Bank of Greece. She holds an MBA from INSEAD (2000) and a Bachelor of Science in Operations Research and Marketing from the Athens University of Economics and Business.

Ioanna Papadopoulou, Independent Non-executive Director

Ms Ioanna Papadopoulou was born in Athens. After graduating from The Hill School, she furthered her studies in Food Chemistry, in the UK. In 1977, she assumed the position of Vice President & Deputy Managing Director of E.J. PAPADOPOULOS S.A., Biscuit & Food Products Manufacturing Company and in 1996 she took over the position of President & Managing Director of the company. She is the President and Managing Director of the following companies: Ε.J. PAPADOPOULOS S.A., GREEK FOOD PRODUCTS S.A., IKE AKINITA S.A. She is also a Board member of Endeavor Greece and has also served as a member of the Board of Directors of ALPHA BANK and TITAN CEMENT GREECE. She speaks English and French fluently.

In addition, the curriculum vitae of Mr. Konstantinos Sfakakis, who is a member of the Audit Committee, a third person outside the Company, independent within the meaning of article 9 par. 1 & 2 of Law 4706/2020, meeting in any case the criteria of article 4 of Law 3016/2002, as currently in force, is also presented.

Konstantinos Sfakakis, member of the Audit Committee

Mr Konstantinos Sfakakis graduated from the Athens University of Economics and Business (AUEB) with a degree in Business Administration. He commenced his professional career abroad at the international auditors’ firm PEAT, MARWICK, MITCHELL & CO and held senior positions in Finance at BRISTOL MAYERS INT’L CORPORATION and JOHNSON & JOHNSON HELLAS S.A. During his 25 year tenure at COCA-COLA TRIA EPSILON, he worked as Country CFO, Corporate Finance and External Relations Director, while being a member of the working team responsible for the Mergers and Acquisitions of the same company’s Group. From 2012 has been offering his services as Advisor to the Board of SEV on Tax Policy Issues. Mr Sfakakis, among the administrative bodies of various associations and companies in which he has served, he has been a Chairman of the Board of the Federation of Greek Soft Drinks Industries (SEVA), while today, he serves in the Board of Directors of the Hellenic Accounting and Auditing Standards Oversight Board, he is an ordinary member of the Taxation Committee of the American-Hellenic Chamber of Commerce as well as a member of the Greek Branch of the International Fiscal Association (IFA).

D.6. Board of Directors Meetings

The BoD convenes at the Company's registered address whenever this is required by the law, the Articles of Association or the Company's needs. The Board of Directors may also convene by teleconference in which some or all of its Members may participate. In this case, the notice of meeting to the Members of the Board of Directors must include the necessary information and technical instructions for their participation in the meeting. The BoD convenes validly away from the Company’s registered address, at another location in Greece or abroad, provided that all the Directors are present or represented at the meeting and none of them are opposed to the meeting being held and to decisions being made.

Annual financial report for the year ended 31 December 2022

79# D.7. The Chair of the Board of Directors

The Chair of the Board has the following responsibilities:

The Chair of the Board presides over its meetings and is responsible for setting the items on the agenda, ensuring the proper organisation of its operations and the efficient conduct of its meetings.
The Chair shall ensure the smooth and effective functioning of the Board as a collective body, promoting a culture of open-mindedness and constructive dialogue in the conduct of its work.
The Chair ensures that the work of the Board is carried out smoothly and that each member of the Board is able to perform the work assigned to him/her, while ensuring that there is a constructive working relationship between executive and non-executive or independent members, as well as sufficient time to resolve all operational issues.
The Chair shall ensure that the Board as a whole has a satisfactory understanding of the views of shareholders and shall ensure effective communication with all shareholders as well as the fair and equitable treatment of their interests and the development of constructive dialogue with them in order to understand their positions.
The Chair certifies copies and extracts from the books of minutes (Board of Directors and General Meeting) of the Company, and from any other book, the keeping of which is required by law.
The Chair shall preside over the Board's evaluation process.

D.8. Vice-Chair of the Board of Directors

The Vice-Chair shall stand in for the Chair of the Board in case of the latter's absence or inability to act.

D.9. Senior Independent Director

During the meeting of 07.12.2021, the Board elected as Senior Independent Director Mr I. Zafiriou. The Senior Independent Member has 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
to lead the evaluation of the Chair.

D.10. Chief Executive Officer

The CEO exercises his/her management duties and any other responsibilities determined and/or delimited by the Board of Directors and ensures the fulfilment of the object for which the Company was established, in accordance with the applicable Greek and Community legislation in force. The CEO heads all the Company's Division/Departments, directs their work, takes the necessary decisions within the framework of the approved business plan and budget and ensures, together with the members of the top management, that all members of the Board of Directors receive accurate, timely and necessary information for the execution of their duties. Among the main responsibilities assigned by the Board of Directors to the CEO are the following:

Proposes the Company's strategy and oversees its implementation.
Specifies the Company's objectives and policy, examines alternative actions, selects proposals, supervises their implementation, evaluates the results and provides the Board of Directors with information about the Company’s activities.
Supervises the conduct of the operations of each service and functional unit and monitors the implementation of internal regulations and procedures, having command of the Company's personnel.
Works closely with the Chair and the Secretary of the Board for the preparation of the Board and the full briefing of its members.
With regard to his/her succession plan, he/she takes part in the process of evaluating candidates for his/her position and discusses with the Compensation and Nomination Committee when it is necessary to evaluate candidates for other senior management positions.

The CEO, subject to the prior notification to, and approval of, the Board of Directors, may delegate actions that fall within his/her responsibilities to the Directors and other officers of the Company. In its meeting of 29.09.2022, the Board of Directors unanimously decided to assign the legal representation of the Company and all relevant powers and responsibilities to the CEO, Mr Odyssefs Athanasiou, who shall bind the Company with his sole signature under the corporate name. The powers and responsibilities delegated to the CEO at the above Board meeting include, but are not limited to, the powers:

To appoint and terminate generally the Company's personnel, determining the authority, obligations and remuneration of each of them, as well as the remuneration of those who are entrusted with a special service or mandates, provided that they are not members of the Board of Directors
To oversee the management and expenses of the Company
To represent and bind the Company before any Public Authority, Agency, Organisation and Service Provider (including but not limited to: HRADF SA, Hellinikon Office, Tax and Police Authorities, Social Security Bodies, First and Second Degree Local Government Authorities, Planning Offices, Ministries and the Secretariat General of the Government, Citizens' Service Centres, power, water and sewerage and natural gas providers, telecommunications and internet providers, courier and express consignment services, etc.)
To represent and bind the Company before Judicial Authorities, in person or by judicial or general proxy and process agent (plirexousios & antikllitos); to bring (or to waive or withdraw from) legal actions, petitions, administrative appeals, oppositions, ordinary and extraordinary legal remedies, applications, suspension of enforcement and rehearings; to appear before any and all courts and judicial, criminal, civil, administrative, customs, and other authorities, including the Supreme Court (Areios Pagos), the Supreme Council of State/Supreme Administrative Court (Symvoulio tis Epikrateias), the Court of Audit (Elegktiko Synedrio), etc., and the Hellenic Cadastre; to register and discharge mortgages or prenotations of mortgages in favour of the Company; to collect paid stamp duties and to collect any court costs that the State or any third parties are ordered to pay to the Company; and in general to conduct and manage any case and to take any and all actions related to Courts and Judicial Authorities;
To further authorise, by written mandate and power of attorney, one or more members of the Board, Managers and/or employees of the Company or third parties, in order for them, acting jointly or severally, to perform specific actions, subject to the provisions of the decision of the aforementioned Board meeting.

D.11. Company Secretary

The Board is supported by a Secretary, Mr Ioannis Giannakopoulos, who is the Chief Legal Counsel and Chief Legal and Compliance Counsel and attends its meetings. The task of the Board Secretary is to provide practical support to the Chair and other Board members, collectively and individually, with a view to ensuring that the Board complies with the relevant laws and regulations, as well as the Company's internal rules. All Board members have access to the services of the Secretary of the Board of Directors. The detailed responsibilities of the Secretary of the Board of Directors are set out in the Board of Directors' Rules of Procedures, which are posted on the Company's website. The CV of Mr I. Giannakopoulos is included below, in section E: Senior Officers’ CVs.

D.12. Independent non-executive Directors

The independent non-executive Directors are the non-executive members of the Board of Directors of the Company who, upon their appointment or election and throughout their term of office, meet the independence criteria provided for in article 9 of Law 4706/2020, as in force. The independent non-executive Directors are the following:

All the above independent non-executive members Directors meet the requirements of article 9, paragraphs 1 and 2 of Law 4706/2020, as determined in accordance with the Dependency Disclosure Procedure applied by the Company.

D.13.

In the year 2022, thirteen (13) meetings of the Board of Directors were convened. The table below shows the attendance of Board Members at these meetings:

Full name	Position on the Board	Attendance in Board meetings	Attendance by Proxy	Attendance percentage	Comments
Giannitsis Anastasios	Chairman, Non- executive Director	13	-	100%
Chronis Evangelos	Vice-Chairman, Non- executive Director	13	2	100%
Athanasiou Odyssefs	CEO, Executive Director	13	-	100%
Antonatos Fotios	Director, Non-executive	5	-	100%	Director until 25.5.2022.
Vasilakis Eftychios	Director, Non-executive	10	3	77%
Bussetil Emmanuel	Director, Non-executive	7	-	88%	Director since 25.05.2022.
Zafiriou Ioannis	Senior Independent Non-executive Director	13	-	100%
Katsos Vassilios	Director, Non-executive	13	2	100%
Kotsolis Stefanos	Director, Non-executive	1	-	100%	Director since 24.11.2022.
Kyriazis Chariton	Independent Director, Non-executive	13	-	100%
Nomikos Calypso Maria	Independent Director, Non-executive	13	-	100%
Paizi Evgenia	Director, Non-executive	13	-	100%
Papadopoulou Ioanna	Independent Director, Non-executive	13	3	100%
Sermpetis Aris	Director, Non-executive	11	-	92%	Director until 24.11.2022.

Note: The late Odysseas Kyriakopoulos was a member of the Board of Directors of the Company until 20.03.2022, on which date he passed away. Up to the said date, the Board of Directors of the Company held one (1) meeting on 10.03.2022, in which he did not participate due to health reasons.

Annual financial report for the year ended 31 December 2022 80# Evaluation of the Board and its Committees

In compliance with the provisions of Law 4706/2020 and the Hellenic Corporate Governance Code, the Board of Directors' evaluation process provides for the following evaluations:

Each member of the Board of Directors is assessed for his/her individual suitability every six months based on the relevant criteria set out in the Company's Suitability Policy, which are the following:

Knowledge and special qualifications;
Integrity and good reputation;
Conflict of interest;
Independent thinking;
Adequate availability;

These criteria are general and apply to all Board members, regardless of their status as executive, non- executive or independent non-executive Directors. The assessment shall include, but not be limited to, collection of evidence and statements, research for publications, personal interviews and completion of questionnaires. The latest evaluation carried out did not reveal any material findings.

In addition, each member of the Board of Directors is evaluated annually by the other Directors for his/her efficiency and the fulfilment of his/her duties. Key criteria for this evaluation include, but are not limited to, the participation in the development of strategy, business plans and general decision making, recognition of the Company's long-term interests, cooperation with other Directors, preparation for meetings, as well as personality traits, such as integrity, impartiality and professionalism, which are considered essential in the performance of each Board member's duties. The evaluation shall be carried out by means of a questionnaire. This process shall be chaired by the Chair of the Board in cooperation with the Compensation and Nomination Committee.

Full name	Justification of Independence
John Zafiriou	Mr Ioannis Zafiriou is independent of the Company because apart from his participation in the Audit Committee and the Compensation and Nomination Committee of the Company, as well as his service on the Board of Directors of the Company, he has no significant shareholding or other relationship with the Company.
Chariton Kyriazis	Mr Chariton Kyriazis is independent of the Company because apart from his participation in the Audit Committee and the Compensation and Nomination Committee of the Company, as well as his service on the Board of Directors of the Company, he has no significant shareholding or other relationship with the Company.
Calypso Maria Nomikos	Ms Calypso Maria Nomikos is independent of the Company, because apart from her participation in the Company's Compensation and Nomination Committee and her service on the Board of Directors, she has no significant shareholding or other relationship with the Company.
Ioanna Papadopoulou	Ms Ioanna Papadopoulou is independent of the Company, because apart from her service on the Board of Directors of the Company, she has no significant shareholding or other relationship with the Company.

Annual financial report for the year ended 31 December 2022 83

As regards, in particular, the evaluation of the Chair of the Board of Directors and the Chief Executive Officer, additional criteria are taken into account regarding the knowledge, special skills and abilities required for the effective performance of their duties. Indicatively, the evaluation of the Chair of the Board of Directors covers areas such as leadership skills, authority and relations with the other members of the Board of Directors, the effective conduct of Board meetings and other issues related to the Chair’s responsibilities. Accordingly, the evaluation of the CEO focuses on:

a) individual skills, abilities and knowledge, such as leadership and management skills, strategic thinking, internal and external communication, relations with other Board members,

b) areas of responsibility, such as the identification of opportunities for the Company, proposals for the strategy and the effective supervision of its implementation, the effective organizational structure of the Company and the effective supervision and management of the operation and affairs of the Company.

These assessments are carried out through the completion of relevant questionnaires by the other members of the Board. The evaluation process for the Chair of the Board of Directors is chaired by the Senior Independent Director, while the evaluation process for the Chief Executive Officer is chaired by the Chair of the Board of Directors, always in cooperation with the Compensation and Nomination Committee.

Finally, the Board is evaluated annually as a body based on criteria of collective suitability and the effective performance of its duties. The main criteria for this evaluation are the knowledge, skills and experience of the members collectively required to fulfil their duties, adequate gender representation and diversity criteria, the composition of the Board, the effective cooperation of the Board members, the effective organization and functioning of the Board and its Committees, its decisions and its performance based on its responsibilities. These evaluations take into account the results of the individual evaluation as well as information collected through the completion of relevant questionnaires. The collective suitability process is chaired by the Compensation and Nomination Committee and the Board effectiveness process is chaired by the Chair of the Board in cooperation with the Compensation and Nomination Committee.

Re-assessment of suitability based on the Suitability Policy is mandatory also in the following cases:

where doubts arise as to the individual suitability of the members of the Board or the suitability of the composition of the body,
in the event of a significant impact on the reputation of a Board member,
in any event that may significantly affect the suitability of a Board member, including in cases where members do not comply with the Company's Conflict of Interest Policy.

In addition, at least every three years these evaluations will be assisted (in accordance with the applicable provisions of the law) by an external consultant. The procedures for the above evaluations for the year 2022 have already began and the results are expected to be extracted during the first half of 2023 and will be discussed in detail at the next Board meeting. It is noted that the above evaluations for the year 2021 were completed during the first half of 2022, without any material weaknesses.

Inter alia, during the discussions for the Board evaluation, the future developments for the Company, its governance and the functioning of the Board were analysed and the organisational measures to be taken for the better functioning of the Board were discussed, such as the regular monitoring by the Board of the Group's strategic directions and objectives, the timely information of the Board by the Audit Committee of its activities, the review of the Remuneration Policy for Board members and senior officers to ensure that performance criteria and financial incentives are aligned with their responsibilities and the complex situation of the Group, and the timely distribution of information material to Board members on matters to be approved by the Board as the number of Board members is expected to increase. Also, acknowledging that sustainable development ((Environmental, Social, Governance "ESG") issues are at the center of business interest at an international level and that a huge market is emerging around them, the members ensured that they were thoroughly briefed by specialized consultants in order to understand in depth the Company's efforts to meet the growing demands of both financial institutions and investors. Further, during the current financial year, the Company has decided to implement a training program for Board members on issues related to information systems and new technologies, while the detailed plan for Board training programs will be reviewed regularly in order to meet needs that may arise.

Annual financial report for the year ended 31 December 2022 84

D.14. Suitability Policy - Diversity Policy

D.14.1. Suitability policy

The Company implements a Suitability Policy, which was established by the Compensation & Compensation Committee. Nomination of Candidates in accordance with the provisions of Article 3 of Law 4706/2020 and the Guidelines of Circular No. 60 of the Hellenic Capital Market Commission. The current Suitability Policy was approved by the decision of the Annual General Meeting of the Company's Shareholders on 23.06.2021, when it came into force. It is posted on the Company's website (www.lamdadev.com).

The scope of the Suitability Policy covers the executive and non-executive members of the Board of Directors of the Company (and its subsidiaries), including the independent non-executive members and alternate members of article 81 of Law 4548/2018. The purpose of the Suitability Policy is to ensure the quality of staffing, effective operation and fulfilment of the role of the Board of Directors based on the overall strategy and the medium and long-term business objectives of the Company, with the aim of promoting the corporate interest.

The current Suitability Policy is in line with the provisions of the Company's Internal Regulation, the Corporate Governance Code adopted and applied by the Company and in accordance with the Guidelines of the Hellenic Capital Market Commission, and the corporate culture. It is clear and adequately documented and is governed by the principles of transparency and proportionality, while promoting diversity, meritocracy and efficiency, both in the selection and during the term of office of the members of the Board of Directors.

Furthermore, in the preparation of the Suitability Policy, consideration was given to, inter alia, the size, internal organization, risk appetite, the nature, scale and complexity of the Company's activities, as well as any other elements specific to the Company.The Suitability Policy takes into account the specific description of the responsibilities of each Director, his/her participation in committees, the nature of his/her duties (as an executive or non-executive Director), his/her classification as an independent or non-executive Director, as well as specific characteristics related to the nature of the Company's activity or the Corporate Governance Code that the Company applies. The Compensation and Nomination Committee recommends to the BoD its staffing with persons of integrity and reputation, who have the experience required for the duties and role they undertake, on the one hand, and sufficient time to carry out their duties, on the other hand. When appointing the members of the Management Board, the Compensation and Nomination Committee with the assistance of the Board Secretary, obtains written confirmation from the members that they accept in their entirety the policies, procedures and other internal documents of the Company and are bound by them. The selection of appropriate methodological tools ensures that the candidates for the Board of Directors are aware of Company's corporate culture, values and general strategy, inter alia, both before assuming their position and during their term of office. The Company has developed and implements a program of a) induction following the selection and at the beginning of the term of office of new Board members and b) continuous briefing and training of Board members on issues related to the Company. Furthermore, the members of the Board of Directors are regularly informed regarding business developments and the major risks to which the Company is exposed, as well as any changes in legislation and the market environment in which the Company operates. To this end, they maintain regular contact with the Company's senior management through regular presentations by the heads of the Company's Divisions and Departments. The suitability of the members of the Board of Directors is reviewed, either periodically or on a case-by-case basis, in the context of the operation of the Internal Control System and in accordance with the specific applicable rules. In any case, the Compensation and Nomination Committee shall monitor the suitability of the members of the Board on a continuous basis, in particular to identify, in the light of any relevant new event, instances in which a re-evaluation of their suitability is deemed necessary. The Compensation & Compensation Committee maintains a list of nominees who possess the specific characteristics required for the implementation of the Company's long-term plan. In this context it ensures Annual financial report for the year ended 31 December 2022 85 the existence of an appropriate succession plan to ensure the smooth continuity of the management of the Company's affairs and decision-making after any vacancies of Board members, in particular executive Directors and members of its committees. The succession plan shall in particular take into account the findings of the evaluation of the Board in order to achieve the required changes in its composition or specific characteristics and to maximize the efficiency and collective suitability of the Board.

D.14.2. Diversity policy as regards the composition of the Board of Directors and senior management

The Company adopts a Diversity Policy, aiming on the one hand to promote the necessary diversity in the Board of Directors and on the other hand to foster the inclusiveness of its membership. When selecting Board members, the necessary care is taken to ensure a diversity of views and experience in order to make sound decisions.

D.14.3. Diversity Criteria - Diversity Practices

The Company is committed to respecting and ensuring diversity and equality of opportunity for all Board members and prospective Board members, for senior executives and for all employees and candidates at all levels of the hierarchy regardless of race, color, religion, ancestry, gender, sexual orientation, age, disability, marital status, or any other characteristic protected by law, and expressly prohibits any discrimination or harassment based on these factors. All decisions concerning recruitment, promotion, training, performance appraisal, pay and benefits, disciplinary misconduct and dismissal are free from any unlawful discrimination. It should be noted that there have been no incidents of discrimination in the Company's workplace and that there is gender balance in the Company's workforce. The table below shows the gender representation ratios in the personnel and the senior and top management of the Company:

The constructive use of diversity, the respect and value of individuality, and the fostering of a fair and meritocratic workplace for all employees without exception, are integral parts of the Company's strategic goals and development. Driven by the principles of diversity, the Company's Board of Directors possesses the collective knowledge, skills and expertise necessary to discharge its responsibilities. At the same time, there is diversity in terms of age and adequate representation by gender, in accordance with the provisions of Law 4706/2020 (25% of the total number of Board members, rounded to the previous integer during the calculation). The current composition of the Board of Directors gives the advantage of a diversity of opinions, concerns, questions and experiences that contribute to making sound decisions. The Company's Diversity Practices are posted on the Company's website (www.lamdadev.com). The table below shows the diversity and the necessary knowledge and skills of the Company's Board of Directors.

Gender representation ratios	Women	Men
LAMDA Development S.A.: (consolidated)
Personnel	52%	48%
Top and senior managers	44%	56%

Annual financial report for the year ended 31 December 2022 86

Ages

Average age: 64.53
Age variation: 10.08

D.15. External professional commitments of the Board members

In accordance with the Company's Suitability Policy in force, all members of the Board of Directors must devote the necessary time and resources to achieve a satisfactory response and effective fulfilment of their duties. In determining the adequacy of time, consideration shall be given to the status and responsibilities assigned to the Board member, the number of positions held as a member of other Boards and other positions held by such member at the same time, as well as other professional or personal commitments and circumstances. Each prospective Board member shall be informed of the expected time required to devote to his or her duties and to meetings of the Board and any other committees on which he or she serves as a member. Further, the aforementioned Suitability Policy provides that each Board member must regularly attend Board and Committee meetings and must show flexibility regarding attendance at extraordinary meetings. To this end, the Policy provides the possibility of participation in up to 5 Boards of listed companies (for non-executive members) and up to 3 (for the Chair). The external professional commitments of Board members are shown below:

FULL NAME	CORPORATE NAME	POSITION (MEMBER OF ADMINISTRATIVE, MANAGEMENT OR SUPERVISORY BODY)	PARTNER/ SHAREHOLDER
EVANGELOS CHRONIS	PRIVATSEA MARINE PROJECTS SA	BoD Member
	PRIVATSEA YACHTING SA	BoD Member
	JOHN S. LATSIS PUBLIC BENEFIT FOUNDATION	Member of Executive Board
	NERAIDA FLOATING MUSEUM	Chair of the Board
ODYSSEFS ATHANASIOU	ENDEAVOR	BoD Member
	ALLIANCE FOR GREECE	Vice-Chair of the Board
	BRAINY I.K.E	Partner
EFTYCHIOS VASILAKIS	AUTOHELLAS ATEE	CEO, Executive Member
	AEGEAN AIRLINES SA	Chair of the Board; Executive Member
	TRADE ESTATES REIC	BoD Member, Consultant, Non- Executive Member
	KIA HELLAS SA	BoD Member, Executive BoD Member
	HYUNDAI HELLAS SA	BoD Member, Executive BoD Member
	FASTTRAK SINGLE MEMBER SA	Chair of the Board
	SPORTSLAND SA	Chair of the Board & CEO
	KRITIKA GOLF S.A.	Chairman & BoD Member
	TEMES SA	Non-executive BoD Member
	GOLF REGENCIES SA	BoD Member, Non- Executive Member
	GROUND DYNAMIC SA	BoD Chairman Executive Member
	SETE	Vice-Chair of the Board
	SEV	BoD Member
	ENDEAVOR Greece INC.	BoD Member
	FELIX HOLDINGS Sarl		Shareholder 100%
EMMANUEL BUSSETIL	European Financial Group EFG (Luxembourg) SA	Member of Administrative Body (Director)
	EFG Bank (Monaco)	Member of Administrative Body (Director)
	EFG International AG	Member of Administrative Body (Director)
	EFG European Financial Group Ltd	Member of Administrative Body (Director)
	A) Consolidated Lamda Holdings S.A.	Member of Administrative Body (Director)
	B) Hellinikon Global I SA.
	C) Lamda Developments SA
	Paneuropean Oil and Industrial Holdings SA	Member of Administrative Body (Director)
	SETE Holdings Sarl	Member of Administrative Body (Director)
	Ophelia International Investments SA	Member of Administrative Body (Director)
	Gestron Asset Managemen SA	Member of Administrative Body (Director)
	Pronia Health SICA R (former Pronia Holding)	Member of Administrative Body (Director)
	John S. Latsis Public Benefit Foundaton	Member of Administrative Body (Director)
IOANNIS ZAFIRIOU	ELIZA, NON-PROFIT ORGANIZATION	Treasurer & BoD Member
VASILEIOS KATSOS	DIALBEN INVESTMENTS LIMITED	Member of Administrative Body (Director)until 12.12.2022 As of 23/12/2022 the company went into liquidation
	VNK CAPITAL LTD	Partner
	NADEAU INVESTMENTS LIMITED	Administrator - Partner
	ER.NI.K STABLES SINGLE- MEMBER PC	Partner
	INVEST IN MEMORIES NEPA	Shareholder
	MONACO RIB BOATS SARL	Co-administrator Partner
	SCI AMALIA	Shareholder
	PALAZI REALI A.E	Chairman and CEO:
STEFANOS KOTSOLIS	TECHNIKI KOTSOLIS AE KAI SIA EE	Limited Partner
	Α.KOTSOLIS TECHNIKI Α.Ε UNDER LIQUIDATION	Shareholder and Liquidator
	TECHNIKI ETAIREIA G.

Annual financial report for the year ended 31 December 2022 87
Annual financial report for the year ended 31 December 2022 88
Annual financial report for the year ended 31 December 2022 89# DIMOPOULOU Α.KOTSOLI & SIA ΟΕ
General partner and Co- administrator

PALAZI REALI LTD

Shareholder

CHARITON (HARRY) KYRIAZIS

"SKAMA E. Skazikis - L. Maragos SA" BoD Member without executive powers
“C. Kyriazis Consulting PC” Administrator Partner
“PQH Single Special Liquidator” BoD Member and member of the Audit Committee

Institute of Industrial and Business Education & Training (IVEPE) SEV

Non-profit educational organization
Chair of the Board

Organization for Mediation & Arbitration (OMED)

Non-profit legal person under private law
Alternate BoD Member without executive powers

International Labour Organization (UN Agency)

International Organization
Alternate BoD Member without executive powers

CALYPSO-MARIA NOMIKOS (N.E.A.R.)

NEW ERA ASSET RECOVERY LIMITED (CY)
Shareholder

KEFY HOLDING COMPANY LIMITED (CY)

Shareholder

F.H.C. Fizzlec Corporation Ltd. (CY)

Shareholder

A.M. NOMIKOS TRANSWORLD MARITIME AGENCIES SA (PA)

Manager / Chair of the Board.
Shareholder

A.M. NOMIKOS & SON (UK) LIMITED (UK)

Manager
Shareholder

AMN BULK CARRIERS INC. (MH)

Shareholder

AMN COMMERCIAL SERVICES INC. (MH)

Manager / Chair and Treasurer of the Board.
Shareholder

AMN AQUARIUS INC. (MH)

Shareholder

AMN MARITIME SERVICES INC (MH)

Manager/ Treasurer of the Board
Shareholder

AMN UNIMAR INC (KY)

1 Manager/ Chair of the Board
Shareholder

AMINAV SHIPPING CORPORATION (KY)

Manager/ Chair of the Board
Shareholder

AMN INC (KY)

Manager/ Chair of the Board
Shareholder

AMN HOLDINGS CORP (KY)

Manager/ Chair of the Board
Shareholder

KEY SHIPPING INC. (MH)

1 Manager/ Chair of the Board
Shareholder

ATLANTICA INC. (NO)

Manager / BoD Member

NORTH EAST CHEMICAL CARRIER INVEST INC. (NO)

Manager / BoD Member
Shareholder

SOLIDARITY NOW (GR)

BoD Member

MDA HELLAS, Association for People with Neuromuscular Diseases (GR)

BoD Member

GEORGE VERGOTTIS MEMORIAL FUND STIFTUNG (Lichtenstein)

BoD Member

KOURKOUMELATA WELFARE FOUNDATION (Lichtenstein)

Chair of the Board

Gestron Holding (Luxembourg) Sarl

Gestron Asset Management SA (Luxembourg)