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NIREUS CORPORATE SOCIAL RESPONSIBILITY AND SUSTAINABLE DEVELOPMENT REPORT 2014-2015

Table of Contents

CEO MESSAGE 4

HIGHLIGHTS 2014-2015 8

ABOUT THIS REPORT 9Report Profile 9Let us have your feedback 9

MEDITERRANEAN AQUACULTURE 10Historical Overview of the Industry 10Contribution in the program “Improvement in Responsible Aquaculture” 13

GROUP PRESENTATION 16Profile 16Historical Overview 18Presentation of Group Companies 20Corporate Governance 33Strategic Development 36Employment 38Supply Chain 42Environmental Management 44Participation and Recognition 46

SUSTAINABLE DEVELOPMENT MANAGEMENT 47Stakeholder Engagement 47Materiality Analysis of sustainable development topics 50

MATERIAL ASPECTS ON SUSTAINABLE DEVELOPMENT 56Consumer Health and safety 58Occupational Health and safety 60Business Ethics and Integrity 62Regulatory Compliance 64Economic Performance 66Fish Health and Welfare 68Research and Development 72Sustainable Fish Feed 76Marine Spatial Planning 80Creating Value in Local Communities 82Raw materials 86

GRI G4 CONTENT INDEX & UNGC COP TABLE 88GRI Content Index for “In accordance” – Core 88UN Global Compact – Communication on Progress 91

4

CEO MESSAGE

Dear Shareholders and Stakeholders,

With great pleasure and satisfaction, we wel-come you to our Group’s Corporate Social Re-sponsibility and Sustainable DevelopmentReport for the two-year period 2014-2015.

Acknowledging the increasing significance ofbeing accountable to all our stakeholders asregards the values inherent in our Group andour impacts on the economy, society and theenvironment, we proceeded with a major en-richment of the contents and structure of ourReport, in accordance with the internationalGRI G4 Sustainability Reporting Guidelines andWorldwide Sustainable Development Goals(SDGs) of the United Nations (UN).

Since its establishment, NIREUS has beenconstantly focusing on the value of businessdevelopment with respect to both the environ-ment and to people. The Group has, for a num-ber of consecutive years, been supportinginternational voluntary initiatives such as theUN Global Compact, endorsing the ten princi-ples on labour issues, human rights, combat-ing corruption and protecting the environment.Furthermore, we are implementing a numberof measures and procedures which enhancedue corporate governance and responsibility.

Our deep and honest conviction that ethics inbusiness and legal compliance comprise thebasic principles by which we operate andfunction, is reflected throughout the context of

this present Report, and is a fact that makesus proud.

During the previous two-year period, we under-took many further actions towards continuouslyimproving our performance in the areas of sus-tainable development, total quality as well ascorporate social responsibility.

More specifically, we:▶ Expanded our operations

as well as employee positions, providing valuable employment to local communities across the country

▶ Reduced our costs applying innovative solutions and improved materials and resource management

▶ Proceeded with new product certifications▶ Reduced our environmental footprint▶ Recycled more materials▶ Emphasised on health and safety training▶ Intensified our social activity

and our voluntary actions.

Having as our valuable guide the material is-sues of sustainable development, as analysedin this present Report and raised through yourfeedback, we are optimistic in being able toplan an improved course of action and en-hanced performance in all areas presented toyou in order that you be able to confirm ourprogress in each forthcoming year.

Antonios ChachlakisCEO

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6

Our VisionTo include our high nutritional value Mediterranean

fish in consumers’ diet around the globe.

Our missionTo operate responsibly in all areas and provide nutritional

high quality Mediterranean fish, thus meeting multiple con-

sumer health needs, in existing and new markets through

widening our distribution network.

Our ObjectivesGroup's strategy for the forthcoming years mainly fo-cuses on the following pillars:

▶ Sustainability▶ Increase profitability – EBITDA ▶ Production Cost Reduction with improvement

in production methods and innovations▶ Maintain market share▶ Expansion of Sales network▶ Designing new value added products ▶ Designing and upgrading information systems▶ Development of a new marketing strategy ▶ Workforce development and training actions


Fattening Unit of Fokida

8

1,095 employees in 2015

185.4millionGroup’s total Sales

€

149.6millionexports

representing

€

81%of sales

40Our products

are distributed in

countries

1.9 in 2014

1.76reduction in the FIFO ratio(Fish In Fish Out) in 2015

as compared to

73%Proportion of spending

(as a percentage of total annual purchases)

to local suppliers, in majorlocations of our operations

1.6milliontotal Research and

Development expenditure

€

4,134 We donated

kg of products for charitable

purposes

84.8%the percentage

of fishmeal derived from fisheries

certified as IFFO RS in 2015

28.94%the percentage

of fishmeal derived from the processing

of fish productsfor the production

of feed in 2015

2%

Improvement in the survival rate of our fish by

and reduction in the mortality rate by

16%

During the years 2014-2015,

500physicochemical and

610microbiological analyses

per year performed in farming waters

HIGHLIGHTS 2014-2015


Let us have your feedback

Considering as a major objective the material and satisfactory briefing of our report to all readers, weexpect to receive your comments, any questions and suggestions for improvement, which you can for-ward to our Company:

NIREUS AQUACULTURE SA1st km Koropiou - Varis Ave. and Dimokritou19400 Koropi, Greece

To the Attention of:

Contact telephone: +30 210 6698310

9

Report ProfileG4-28

Maria Lambrinou,General Legal and Corporate Affairs Directore-mail: [email protected]

Korina Stefaki,Responsible CSR and Public Relationse-mail: [email protected]

G4-29 G4-30 G4-32 G4-33

The present report comprises the 10th consecutive Corporate SocialResponsibility and Sustainable Development Report of the NIREUSGroup which comprises an overview of the Group’s economic, socialand environmental performance for the two year period 2014-2015,with a reference period from January 1, 2014 to 31 December2015.Our previous Report was issued in 2014 relating to the report-ing period 2013.

The Report has been prepared "In accordance-Core" with the Sus-tainability Reporting Guidelines GRI G4, in view of meeting the needsand expectations of the Group’s stakeholders. Furthermore, our ob-jective is to present the manner in which the NIREUS Group managesits most material impactsin the context of sustainable development.The GRI G4 Content Index presented in pages 88-90, includes rele-vant references in the Report.

The prioritization of sustainability topics included in this Report re-sulted following direct engagement with the Group’s internal andexternal stakeholders, through the use of electronic survey and theformation of a specialized workshop.

We have referred to the World Sustainable Development Goals(SDGs) of the United Nations (UN) in order to assess the impacts ofour major topics and material aspects. The respective analysis ispresented in pages 52-55.

The Corporate Social Responsibility and Sustainable DevelopmentReport has not received an external assurance, however all data andcontents have been reviewed internally.

G4-31

ABOUT THIS REPORT


10

In the Mediterranean region, the onset of aquaculture was ini-tially identified in Ancient Egypt. The tomb of Aktichep (2500BC) depicts pictures of men removing tilapia from a pond. TheEtruscans (Italy) had marine sea farms in the 6th century BC,while Greeks farmed molluscan shellfish during the 5th centuryB.C. The Romans harvested marine fish, mainly those of seabass and sea bream, which were considered rare and were verypopular in such recipe books as the "De Re Coquinaria" of Apicioof the 1st century B.C.

This type of aquaculture disappeared with the end of theRoman Empire. It reappeared though in the 15th century A.D.as extensive large-scale aquaculture in the sea lakes ofAdriatic named vallicultura (aquaculture developed in coastallagoons). The farming of fish arose due to a religious practiceaccording to which consumption of animal meat on Fridayswas prohibited.

Modern aquaculture began in the decade of 1980 with the in-troduction of sea bass and sea bream farming, following sig-nificant discoveries in the life cycle of these species. The sectoradopted the technology of fattening in cages by reference tothe salmon sector. It furthermore developed by being supportedthrough significant research, mainly in the areas of reproduc-tion, larval culture, feed manufacturing and engineering tech-nology. The industry presently produces over 300.000 tonsversus only a few thousand tons 25 years ago.

Mediterranean fish farming focuses on the well-known carniv-orous fish species, such as seabass and seabream, which areeither harvested in low quantities or which are over-harvested.Despite the fact that seabass and seabream comprise approx-imately 95% of total production, the farming of new similarspecies such as (red porgy/pagre, sharpsnout seabream, mea-gre/corvina, dentex e.tc.) is currently being developed.

Historical Overview of the Industry

World production 1995-2015 (thsd tons)source: Kontali Analyse

The Mediterranean farming began in the 1980s with the farming of sea bass and rapidly expanded with the inclusion of farming

of sea bream. Its evolution was rapid and it presently ranks second, among the highest positions in sea aquaculture worldwide,

following the farming of salmon - trout.

MEDITERRANEAN AQUACULTURE


11

Greece, Turkey and Spain are the main producing countries of sea bream and sea bass accounting for approximately 80% ofglobal production. The remaining 20% is produced in Italy, France, Portugal, Croatia, Cyprus and countries of N. Africa as well asin the Middle East.The following graph presents the evolution of production per country from year 2000 up until today.

Salmon Trout Sea Bass Sea Bream Cyprinus Carpio Other

FEAP - European aquaculture production 2015 (thsd tons)

Over 60 companies are currently operating in the Greek aquaculture industry with a turnover in excess of € 600 million, providingindirect and direct employment to 15,000 employees in regions remote from urban areas. 60% of turnover is generated from thethree largest companies, while the total sea area covering the industry’s facilities is 7.8 km2 (in comparison to the Spata airportwhich covers an area of 16.5 km2).

0

110

220

330

201520122009200620032000

Greece Turkey Spain Italy France Portugal Croatia Cyprus Others

Evolution of global production of seabream and seabass 2000-2015 (thsd tons)source: FEAP, TURKSTAT, NIREUS projections


12

The sector is one of the largest exporting producers of the country and 80% of total production is exported and mainly directed

to Europe.

Nireus Selonda Andromeda Dias Galaxidi

The largest Greek aquaculture companies - sales 2015 (million €)source: financial statements

Selonda and Dias were merged in 2016 - in 2015, 60% of the sales of Dias were made to Selonda

50,0%

45,0%

40,0%

35,0%

30,0%

25,0%

20,0%

15,0%

10,0%

5,0%

0,0%

10,8%11,8%14,6%

46,2%

3,6% 3,8% 3,0%6,3%

Italy Spain France Portugal England Germany Netherlands Others

Distribution (%) Export volume 2015 Greek fresh sea bream and sea basssource: Kontali Analyse

The aquaculture industry accounts for less than 0.4% of domestic production, while its exports account for 2% of the country's

exports and 11% of the exports of the primary sector.


13

The Mediterranean aquaculture industry is wide and has grown in a rather short periodof time. As a result, detailed guidelines for environmentally responsible practices,measurable and subject to certification, have not yet been established similar to thoseand which exist in other aquaculture sectors such as that of the salmon industry.

Acknowledging such a need, which is fully aligned with the corporate culture ofNIREUS, our Company participates in the pioneering initiative which WWF Greece hastaken in cooperation with AB Vassilopoulos chain of supermarkets aiming at a furtherenhancement of management practices in three farming units of sea bream and seabass located in the regions of Aliveri, Astakos and Nafpaktos.

This program is implemented according to the standards of responsible aquaculturewhich have been developed by the independent international organization of Aqua-culture Stewardship Council (ASC), for other farmed species, and which are adjustedto the requirements of sea bream and sea bass Mediterranean species.

The Company will continuously be subject to audits which are to be performed by areputable international body and will be monitored with respect to its progress and itsimprovements which are expected to arise from the implementation of its initiatives.

Critical areas to be focused on through the program on the improvement in respon-sible aquaculture, are: sea sites selection, release of fish waste in the environment,interaction with wildlife and flora, escapes, antifouling usage effect, fish health andwelfare, fish feed composition, and actions for socially sound working practices.

Our participation in this initiative highlights our strong commitment for responsiblefish farming in all respects.

NIREUS IS A PIONEER IN THE MEDITERRANEAN AQUACULTURE INDUSTRY PARTICIPATING IN A COMMON EFFORT ALONG WITH WWF HELLAS AND AB VASILOPOULOS

G4-15

Contribution in the program "Improvement in Responsible Aquaculture"


Sea Bream of Nireus of a weight of approximately 600 gr, aged 20 months

16

NIREUS AQUACULTURE S.A is the parent company of a verti-cally integrated Group, with aquaculture being its main coreof activities.

The parent company was established in 1988 in Chios, inwhich region the first aquaculture unit initially operated. Inits 28 years of operation, and through continuous develop-ment, mergers and acquisitions, NIREUS conquered the lead-ing position in the production and sale of Mediterranean fishspecies worldwide, simultaneously being among the 10largest aquaculture companies in Europe.

According to international studies and surveys, the Companyholds a significant position worldwide with respect to theaquaculture fish market.

The Company's shares are listed on the Main Market of theAthens Stock Exchange since 1995, while in 2009 the tradingof bonds from the convertible bond loan issued in 2007, com-menced.

Located in the municipality of Koropi Attica, the NIREUSGroup maintains production facilities in Greece and in Spain.

It sells its products to more than 40 countries worldwide andis a leader in the market with respect to all of its products:fish, juveniles and fish feed.

Our customers include large Super Market chains, whole-salers and processors in Europe and America. Furthermore,the customers of NIREUS include aquaculture companies,which are served for the purpose of meeting all operationalrequirements through the purchase of fish feed, juveniles ofexcellent quality, as well as high quality equipment.

NIREUS Group is and vertically integrated in the productionand sale of aquaculture products, covering the entire valuechain of fish feed production broodstock, juveniles, seabream, sea bass, meagre, red porgy/pagre, processed prod-ucts and aquaculture equipment.

The Group has 2 fish feed factories, 4 fish hatcheries, 31 fat-tening units, 3 units pre-fattening juvenile units and 1 geneticresearch and development centre, 8 modernized packagingunits, 1 processing unit, 1 farming equipment manufacturingcompany, such as cages and nets, and 1 company operatingin agriavi and livestock culture.

GROUP PRESENTATION

Profile

Group Companies Structure (30/9/2016)

100% 100% 100% 100%

100%CENTRAL EUROPE

GMBH*

EQUIPMENT SAINTERNATIONAL LTD**

This Report covers all Group companies.* NIREUS (CENTRAL EUROPE) GMBH is a transformation of an existing company, intended to be used as a trading arm for business in Germany.** NIREUS INTERNATIONAL LTD is a holding and parent company of its Spanish subsidiary PREDOMAR.***Is under liquidation

G4-3 G4-4 G4-5 G4-6 G4-7 G4-8 G4-9

MIRAMAR UK PROJECTS***

G4-13 G4-17


17

During the period 2014-2015, the Group proceeded with nego-tiations, reaching an agreement on the total restructuring of itsfinancial loan borrowings.

Aster several months of procedural executions, the Companyproceeded on 24 March 2015 with the signing a Summary ofMutual Agreement and Memorandum of Understanding (MOU)with the Group’s Creditor Banks. The MOU includes the basicterms of the loan refinancing.

Based on this agreement, the Company immediately proceededwith all legal and statutory procedures which included the im-plementation of a number of company actions, drasting newcontracts which resulted, not only in the financial, but also inthe operational restructuring of the entire Group.

The core pillars of the Group’s loan refinancing included the fol-lowing:

▶ Capitalisation of loan liabilities amounting to € 58,600,000 with the issuance of NIREUS new shares with a par value of € 0.30 per share, in favour of the creditor banks, which latter formed a total ownership percentage of the share capital of NIREUS of approximately 75%.

▶ Issuance of joint secured bond loans amounting up to € 94,552,126 at an interest rate of EURIBOR + 4.25%.

▶ Issuance of a ten year convertible, into shares, bond loan of a total amount of €24,466,293 at an interest rate of 1% and with a conversion rate of € 0.31 per share.

▶ Merger by absorption of NIREUS with its subsidiary SEA FARM IONIAN S.A., in addition to company transactions within the Group in connection with the rationalization of its structure.

All of the above restructuring pillars were successfully imple-mented and the Group is already heading towards recovery,thus presenting a significant improvement in both its financialand production key indicators.

Major Events in the Period

Shareholder*

Piraeus Bank 33.10% 30/11/2015

Alpha Bank 20.84% 30/11/2015

Eurobank Εrgasias 16.04% 30/11/2015

National Bank of Greece 5.95% 30/11/2015

Linnaeus Capital BV 5.55% 30/11/2015

Voting Right %Date ofChange

*Shareholders with voting rights exceeding 5%

Shareholder composition and major shareholders

Total number of Group employees 1,095 1,065

Total Group Sales €185,399,812 €193,744,140

Total Assets €371,211,702 €365,063,159

Total Liabilities €250,023,138 €321,662,548

Total Equity €121,188,564 €43,400,611

Group Figures

2015 2014G4-9

G4-13


18

Historical Overview

G4-13

Establishment of the Company / operating as a fattening unit up until 1990.

1988Construction and operation of the first hatchery unit.

1991Commencement of trading of the Company's sharesin the ASE

1995Acquisitions /mergers aiming at increasing production capacity.

19951996

Establishment of the company "PROTEUS EQUIPMENT ".

1996Purchase of the production facility in Koropi and relocation of offices, start-up of the processing units, packaging – storage and uploading of fishes.

19961997

Establishment of FEEDUS and commencement of fish feed production.

1998Acquisitions and company transformations aiming at a further intensification in the area of both food and aquaculture.

19992001

NIREUS SA was assigned as a strategic investor in the agreement between the company SEAFARM IONIAN SA and its creditors.

2005Penetration of the company in the Turkish market with an investmentin the Turkish

aquaculture company ILKNAK.

20052006

Further restructuring of the NIREUS Group through mergers by absorption

2006Establishment of NIREUSINTERNATIONAL L.T.D.

2006


19

Agreement with AB Vassilopoulos for the sale throughits retail stores, with the familiar aquaculture product brand name (SELECT AB - NIREUS).

2006Acquisition of the listed company KEGO S.A.

2007Acquisitionof Spanish companyPREDOMAR.

2007Construction and operation of the modern juveniles pre-fattening unit in Thesprotia.

2007

Merger by Absorption of KEGO S.A. with a simultaneous spin-off of the agri-avi-livestock segment and investment in the subsidiary KEGO AGRI SA.

2008Establishment of a NIREUS branch in Milan Italy

2009Award bestowed to the company in the category Environmental Management from PASEPPE (Greek Association of Environment Protection Companies).

2010Establishment of a modern standardized processingunit in the Location Tsapournia, Municipality of Xiromero.

2012

2015Sale of the Turkish company ILKNAK and itsassociated companies.

Signing of the Summary of Mutual Understanding(MOU) with the creditorbanks for its loan refinancing

Acquisition of the remaining 50% of the company PROTEUS EQUIPMENT SA

Completion of the mergerby absorption with thecompany SEAFARM IONIAN SA

"Award of Diversification in Foreign Markets through Subsidiaries and / or Franchises”granted in the context of GreekExports Awards 2013 (EthosMedia).

A distinction was awarded to NIREUS once again, for its exporting performance with the award "ActiveBusiness Awards 2015".

An Excellency award granted on Innovation by the Ministry of AgriculturalDevelopment

2013


20

JuvenilesProduction commences from juveniles, the new-born fish isgenerated from specially selected broodstock which pro-duces millions of eggs through natural means within theboundaries of our hatcheries.

Nireus is one of the major producers of juveniles of Mediterraneanspecies (sea bream, sea bass, meagre/corvina, red porgy/pagreetc). The largest percentage of juveniles is consumed by the Com-pany itself, which supplies its own production units for the pur-pose of fish fattening, while a portion is also sold to othercompanies of the industry in request of NIREUS juveniles, beingof excellent quality and high performance.

Through appropriate broodstock selection and by using spe-cialized monitoring methods and food diets, juveniles areproduced. Once exceeding a specific weight size (usually 1to 2gr), they are then placed in fish cages for fattening.

At times when the sea water temperature is low (in the wintermonths or in the fattening units of the open sea), juveniles arepre-fattened in special pre-fattening units, where they reachthe size weight of 10 gr., before being placed into the sea.

NIREUS Aquaculture SA

AquacultureWith the core pillar of its activities being aquaculture, NIREUS is distinct in producing a wide range of high quality and specialised products.Vertical integration ensures complete monitoring throughout the production process, from food and juveniles to farming, standardization,sale and distribution.

Juveniles

Presentation of Group Companies


21

Hatchery Unit in Chios

The Company implements the most integrated programs of GeneticSelection of sea bream and sea bass in Greece, and is consideredas being the most competitive Company in the Mediterranean region.The objective of the company’s Genetic Selection programs is theselection of faster growing fish for the purpose of being farmed.Such fish should also present an optimum shape and be more re-sistant to common diseases.

A highly specialized team of executives has been engaged indeveloping the necessary infrastructure for the purpose of im-plementing the selection programs. In conjunction with theabove, the team has an exclusive collaboration with the com-pany AKVAFORSK, the largest global service provider of geneticselection which supports more than 40 programs of fish andshrimp selection around the globe.

Head of the Genetic Improvement Program is M. E.. Kottaras, holding seabream broodstock.


22

Fish feedFish feed production is also an important activity meeting theGroup's requirements, while part of production is also soldto other industry companies, which seek quality guaranteedfish feed in their production.

The products of the company NIREUS include various fishfeed lines of Mediterranean fish and trout. Each product lineis available in grain sizes and composition depending on theage, size and fish species for which consumption is intended.

The Company has two owned fish feed production facility

plants with a total annual capacity of 90,000 tons. One fishfeed plant is located in the industrial area of Patras while thesecond fish feed plant is located in the industrial area of NeaArtaki, in Evia.

The referred to production facility in NIREUS has the abilityto manufacture ecological high calorie raw vegetable mate-rials for the use in animal feed. Furthermore, other groupproducts produced include special mineral feed and supple-ments necessary for the production of all types of farmedanimal species.

Fish feed plant facilities in the industrial area in Patras

Fish feed plant facilities the industrial area Nea Artaki, in Evia


23

Once fish reach a specific net weight and size,starting from weight size of approximately 350gr, they are then harvested by means of mod-ern methods and immediately transported toour packaging units where they are standard-ized either as whole, or gutted and cleaned orin fillets according to customer orders. Theseare further directed through our distributionchannels to Greece and to the internationalmarket.

Production of fresh fishThe farming process, in which Group’s fish feedis consumed, begins following the placementof juveniles in our sea sites across the country.The duration of farming procedures is on aver-age 17 months. All units are situated in excel-lent locations and with a 24 hour constantvigilance throughout the year, ensuring excel-lent welfare conditions for our fish.

Packaging

Packaging unit in Tsapournia Aitoloakarnanias

Harvesting


24

ProcessingProcessing is the operation that involves the transformation of fresh fish into fillets or gutted fish which are sold either fresh orfrozen in retail and wholesale packages.

The core centre of processing operations is the unit located in Koropi Attica, which employs specialized personnel and has specialequipment, adhering to strict standards and hygiene principles for the optimal results.

Production of hand-made fillets at Koropi

Packaging


25

Our fish and their nutritional valueWe are proud for the quality and nutritional richness of our fish which are distinct in an industry that is already producing natural productsin our clean seas. This contributes to recognized value by our consumers around the globe.

Our 4 basic species are:

Sea Bream

Red Porgy/(Pagre)

Sea Bass

Meagre/(Corvina)


26

The major benefits of consuming fish which entail the preven-tion of various diseases, thus ensuring good health, are wellknown and scientifically proven.

According to health claims, as approved in the context of theEU Regulation 1924/2006, the consumption of farmed SeaBream and Sea Bass, rich in omega-3 polyunsaturated fattyacids (EPA & DHA), as part of a healthy lifestyle, helps maintaina normal heart function, normal blood pressure and normalblood triglyceride levels.

All such benefits are appreciated by the consumers of our prod-ucts. In addition, our fish bears the guarantee of the largestcompany in the industry, while food consumption comprisesthe best nutritional proposition for the entire family.

According to ongoing sample analyses performed, NIREUS fish

appears to possess organic characteristics highly ranked interms of nutritional value.

The quality of our fish is guaranteed and fully monitored giventhat we produce fish feed consumed in our own productionplants, using our own recipes which contain biological ingre-dients such as other fish (fish meal), fish fats, soy based plants,wheat and microorganisms such as Saccharomyces yeast, sup-plying our fish with essential vitamins.

This is a very important diversification given that the Group hasparticularly invested in vertical integration throughout all theseyears.

All harvesting, packaging and distribution procedures are beingmonitored on a daily basis, until fish reach their point of saledestination.

Type of Fish Calories (Kcal) Protein (gr) Fat (gr) Omega-3 (gr) Source

Sea Bream Aquaculture 130.7 20.4 5.3 1.42 GrigorakisSea Bream free fishing 97.6 20.2 1.8 0.34 GrigorakisSea Bass aquaculture 141.9 20.9 6.4 1.41 GrigorakisSea Bass free fishing 128.3 18.9 5.7 1.58 GrigorakisSwordfish 144.0 19.7 6.7 0.92 USDACommon Sole 85.9 18.7 1.1 0.36 DTUAtlantic Cod 81.3 18.7 0.6 0.26 DTUΤuna (yellow fin) 109.0 24.0 0.5 0.12 USDAΤilapia aquaculture 96.0 20.0 1.7 0.03 USDAPerch 85.2 18.1 1.3 0.02 DTU

Source: Federation of Greek Marine Mariculture (F.G.M)

We, are therefore certain for the optimum growth, contents, freshness and taste of our products.

1 po

rtion

= 10

0 gr

Organoleptic properties of our products

Sea bass Nireus Sea bream Nireus

Red porgy/ (pagre) Nireus Meagre /(corvina) Nireus

8.1 gr

9.5 gr

6.0 gr

8.9 gr

1.18 gr

1.01 gr

0.95 gr

0.86 gr

20.7 gr

20.6 gr

21.4 gr

17.7 gr

155,7 kcal

167,9 kcal

140 kcal

151 kcal

Fat Omega-3polyunsaturated fatty acids

Protein CaloriesNutritional components

Parameters Total Fat Total of EPA + DHA

Dailyrecommended dose 55-90 gr / day 0.25 gr / day 58 gr / day 2,000 kcal

Nutritional value facts per portion 100gr


28

KEGOagri is a 100% subsidiary of the Group and operates withinthe Sector of Animal Production holding a leading position inproviding services of integrated solutions and selling productsmainly in the sectors of Poultry, Pig and Ruminants, in additionto producing animal feed.

The company's vision is to effectively contribute to the devel-opment of the production process of the primary sector,through continuous research and development on innovativeproducts and services.

The dynamics of KEGOagri are based on its exclusive collabo-ration with the leading producers of global genetic material,food types, medicines, bio protected products and equipmentfor production plants.

In the modern and privately owned production facilities ofNIREUS, certified in accordance with the international certifi-cations EN ISO 9001: 2008 & EN ISO 22000: 2005 (HACCP), an-imal feed products are produced, flexible in meeting increasingdemands and product transformation, thus satisfying the needsof each customer. As a result of the above, the culture ofKEGOagri is characterized as being fully customer driven.

The company has a specialized scientific professional employeestaff with years of field experience and in-depth technicalknow-how and expertise, and produces a wide range of prod-ucts and services. KEGOagri provides consumers with highquality produced food, combining high quality with the lowestpossible cost.

KEGOagri

G4-4 G4-8 G4-9

International Collaborations


29

Products and servicesKEGOagri’s main products and services include the following:▶ Provides selected reproduction material in pig farming,

aviculture and cattle farming, of a high genetic value,through reproduction selection programs.

Since 2015, KEGOagri has been cooperating with the com-pany TOPIGS NORSVIN, participating in the global reproduc-tion and genetic improvement program, producing pig geneticmaterial in a privately owned, modernized and standardizedreproduction unit in Viotia.

The company is a representative, both in Greece and inCyprus, of the Ross chickens of the AVIAGEN company, aworld leader in aviculture genetic material.

▶ Provides technical know-how and technical solutions to producers on nutritional issues, on issues of reproduction, management, veterinary and hygiene, via its specialised products and consulting services.

▶ Food products for livestock.

Logistics warehouse ΚΕGOagri

Pig farming unit KEGOagri


30

Products and services▶ Conventional Nets, enhanced and produced by Dyneema▶ Nets for tuna▶ Cages of all types and sizes for Mediterranean fish and Tuna▶ Mooring Systems and accessories▶ Boats and barges▶ Equipment, underwater cameras, control systems,

feeding cannons for farms▶ Equipment and water treatment equipment for hatcheries▶ Integrated design solutions and construction

aquaculture facilities▶ Innovative purifying systems for nets (R.O.N.C.)▶ Grading Systems (Flexipanels)▶ Vaccinations for juveniles.

▶ Vaccination needles for juveniles and spare inoculants▶ Repair services for net cages▶ Repair and modification services for aquaculture cages▶ On -site cleaning nets services

Exporting ActivityThe company aims at further expanding its exports in markets inwhich it currently holds a large market share as well as in mar-kets with a strong growth potential, such as in the countries of N.Africa and in Arab countries.

PROTEUS is a 100% subsidiary of NIREUS Group and spe-cialises in the manufacturing process of equipment providingintegrated technical solutions of high quality. Our subsidiarysatisfies all Group requirements, in addition to meeting theneeds of Mediterranean aquaculture producers worldwide.PROTEUS provides complete technical solutions for Mediter-ranean aquaculture and has the ability to deliver projects "ona turnkey” basis: from the design and feasibility study to theconstruction and installation of hatcheries, processingplants, packaging and fish farming units.

The company has a plant in Chios, which strictly combinesselected quality procedures and carefully selected materialsfor the construction and maintenance of nets for fish farmingcages. Furthermore, it manufactures resistant cages of alltypes and sizes for fish farming in the open sea.

PROTEUS envisions to retain its strong position in the area

of marine farming equipment and to play a leading role inthe Mediterranean region, providing integrated, pioneeringand innovative solutions that contribute to a substantial re-duction in the sector’s operating costs. Its target is that pro-ducers seek Proteus for any requirement which may arise,convinced that they will there find optimal solutions.

PROTEUS has gained in depth expertise, over the years sincethe establishment of aquaculture in our country up untiltoday. The company’s human capital which possesses ex-pertise in all areas of the production process, along with in-novative production processes and combined with excellentmaterials and techniques, adds overall value to the com-pany’s products and services, differentiating these fromcompetition.

PROTEUS

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Sewing Nets


31

Predomar is a subsidiary of NIREUS Group in Spain and oper-ates in aquaculture.It was acquired in year 2007 by the NIREUS Group and in 2008it expanded its operations in the production and distribution ofmarketable size fresh sea bass and sea bream fish.

Both juveniles and fish are available for delivery all year round,meeting the needs of the most demanding customers given thatthey are farmed in conditions close by to nature, under the high-est quality standards and with the expertise of NIREUS.

Plant FacilitiesPlant facilities operate under the highest health and safety stan-dards, as certified in accordance with the GLOBAL G.A.P. stan-dards, ISO 9001 and ISO 14001 for Quality and EnvironmentalManagement respectively.

Pre-fattening unitThe company owns and operates a modern pre-fattening unitin Carboneras, near Almeria which abides by the standards

of the Andalusian local government for sustainable fishingpractices.Due to the fact that the production unit is located near the nat-ural park of Cabo de Gata, juveniles grow in natural clean water.The park is the largest protected coastal area in Andalusia andthe only region in Europe that has a hot desert climate.

The farming of juveniles close by to nature promotes theirinitial growth which is a further advantage for which cus-tomers are informed.

Fattening unitThe company produces marketable size seabream and seabasson an offshore farm located in San Pedro Del Pinatar, 200 kmNorth of Almeria.

The farm has an annual production capacity of 1,500 tons.

The unit is located in an area subject to strong currents so thatfish swim in plenty of sea water, thus ensuring their excellentquality.

QualityPREDOMAR’s goal is to continuously provide high quality prod-ucts to its customers which contribute to value added localbusinesses.

Being a subsidiary of the NIREUS Group, the company appliesthe same high Group standards throughout its productionprocess, ensuring full traceability and reliability, high qualitysale of fish at competitive prices all year round, which com-prises a basic point of differentiation as compared to othercompanies.

PREDOMAR

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Predomar’s Team


33

▶ ΑUDIT COMMITTEEThe Company had already established, since 2002, the AuditCommittee, while it has already fully complied with the provi-sions of Article 37 L.3693 / 2008 with respect to the establish-ment of an Audit Committee from the members of the Board ofDirectors.

This Committee has the following responsibilities:● to monitor financial reporting procedures● to monitor the effectiveness of internal audit and risk man-agement procedures, in addition to monitoring the proper func-tioning of the internal audit department of the entity under audit● to monitor the progress of the statutory audit of both the standalone and consolidated financial statements● to review and monitor issues thus ensuring the existence andmaintenance of the statutory auditor’s or audit firm’s objectivityand independence, particularly in connection to services pro-vided to the audited company.

The Audit committee’s mission and discussion matters focuson securing the effectiveness and efficiency of the company’soperations, on monitoring the reliability of the financial infor-mation presented to investors and to the Company’s share-holders, ensuring the Company’s compliance with the legal

and statutory framework, safeguarding the Company’s assetsin addition to identifying and encountering major risks.

During the year 2014 (01/01/2014-31/12/2014) the AuditCommittees convened six (6) times, with the participation ofall members either in person or by proxy.During the year 2015 (01/01/2015-31/12/2015) the AuditCommittee convened four (4) times, with the participation ofall members in person or by proxy.

▶ Strategic Planning and Investment CommitteeThe main purpose of the Strategic Planning and Investment Committee is to formulate and present proposals on strategic matters to the Board of Directors

Board of Directors Committees

Strong corporate governance is an integral part of theGroup's main values, supporting its vision for sustainabledevelopment. NIREUS Group is committed to the adoptionand implementation of sound principles and corporategovernance practices.

In this section you will find information as regards theBoard of Directors, as well as the structure and gover-nance procedures of the Committees of the Board of Di-rectors, the Group’s organizational structure, the InternalAudit department and the external Certified Auditors aswell as information on the rights and obligations of share-holders and members of Management.

The Board of Directors comprises of experienced business andfinancial Advisors, who ensure the effective formulation of theGroup's strategy in addition to monitoring all operations.

G4-34 G4-56

Board of Directors▶ Aristides Belles, Chairman, Non-Executive Member▶ Nikolaos Chaviaras, Vice President, Non-Executive Member▶ Chachlakis Antonios, Chief Executive Officer▶ Lito Ioannidou, Independent, Non-Executive Member▶ Markos Komondouros, Independent, Non-Executive Member▶ Lambrinopoulos Konstantinos, Independent,

Non-Executive Member▶ Anna Pouskouri, Independent, Non-Executive Member▶ Christina Sakellaridi, Independent, Non-Executive Member▶ Petros Fronistas, Independent, Non-Executive Member

Corporate Governance


34

Internal Audit is an independent department under the super-visory board of the Audit Committee. The main responsibilitiesof the Internal Audit department are the following:

▶ To monitor the implementation of the Group’s internal business policies as well as the articles of association and the legislative framework governing its operations and activities.

▶ To report to the Board of Directors any cases of individual conflicts of interest among the Board of Directors or the members or management with the interests of the Group.

▶ To prepare written reports to the Board of Directors for ongoing audits

The Internal Auditor attends the Shareholders’ GeneralMeetings

Internal Audit

The organizational structure of the NIREUS Group which com-prises the platform on which all Group activities are based, de-fines the responsibilities and the limits of each businessdepartment.

Moreover, it is structured in such a manner that it:▶ meets the needs of key business areas in which

the Group operates▶ aligns with the respective regulatory framework

governing the operations of S.A companies▶ allows the development and diffusion of a unified

business culture▶ ensures the monitoring of operations and risk

management and▶ ensures independence between auditors and

audited companies

Organizational Structure

ORGANIZATIONAL STRUCTURE

BOARD OF DIRECTORS

STRATEGICDESIGN

& INVESTMENTCOMMITTEE

CEO

GENERALFINANCIAL

DEPARTMENT

GENERAL DEPARTMENT OF

LEGAL & CORPORTE AFFAIRS

DOMESTIC SUBSIDIARIES &

INDUSTRIAL SALES

GENERALDEPARTMENT

OF AQUACULTURE

COMMERCIALSALES

DEPARTMENT

TOTALQUALITY

MANAGEMENTAND R&D

SUPPLYCHAIN

DEPARTMENT

AUDITCOMMITTEE

INTERNALAUDIT

EXECUTIVE ASSISTANT


35

Management Team

▶ Theodoros Alexakos, Commercial Sales Director

▶ Rea Elestheraki, Supply Chain Director

▶ Stratis Elissaios, Chief Financial Officer

▶ Lambrinou Maria, Director of Legal and Corporate Affairs

▶ Gerasimos Balomenos, Aquaculture Production Manager

▶ Leonidas Papacharisis, Quality Manager /

Research & Development

▶ Yiannis Stamoulis, General Director of Subsidiaries in Greece

▶ Miltiadis Chatzimanolakis, General Director of Aquaculture

Each share incorporates all rights and obligations stipulatedby Law and by the Company’s present Article of Association.Ownership of a share automatically entails acceptance ofthe Company’s Statutes as well as all legal decisions takenby its responsible officials. Each common share providesequal voting rights. Shareholders’ liability is limited to thenominal value of their shares.

All rights of shareholders are presented in the "Sharehold-ers' Rights" Section of Investors /Corporate Governance asposted on the Company’s website www.nireus.com.

The Management Team of NIREUS consists of executiveswho have extensive professional experience in their field ofexpertise and in the industry. The executives comprising theExecutive Group committee, under the supervision of thecompany’s CEO, manage all areas of implementation of theCompany’s strategy.

Shareholders’ Rights

Headquarters, Koropi


36

G4-6 G4-8

OTHERPORTUGALSPAINN. AMERICAFRANCEGERMANYITALYENGLANDGREECE

11%

6%

20%

6%

15%

6%

15%

9%11%

0

5

10

15

20

25

30

Fish sales 2015 of NIREUS Group by country (% value)

Strategic Development


The strategic development of NIREUS Group is focused on expanding into new markets in conjunction with the development andsale of new products.

Group’s total sales in 2015 amounted to € 185.4 million while exports amounted to € 149.6 million, accounting for 81% of sales.

Since the beginning of its operations, NIREUS Group pioneered in opening new markets and is, today, the leading exporting Greekcompany in the food sector, with 81% of fish being directed to 40 countries worldwide.

38

Employment

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NUMBER OF EMPLOYEES GROUP NIREUS *

2015 2014

Number of employees per employee contract

Indefinite 815 251 774 247

Fixed-term 14 15 17 24

Trainees - - 2 1

Total 829 266 793 272

Number of permanent employees by employment type

Full-time 805 228 765 220

Part-time 10 23 11 28

Total 815 251 776 248

Workforce by region

Attiki 77 80 72 83

Aitoloakarnania 199 47 175 61

Argolida 25 4 25 4

Achaia 50 10 49 8

Evia 197 53 200 47

Thesprotia 64 14 57 13

Lefkada 24 0 23 0

Fokida 75 20 75 21

Chios 104 32 103 32

Carboneras 14 6 14 3

Total 829 266 793 272

* The number of employees relates to the reporting dates 31.12.2015 and 31.12.2014 respectively.* The number of employees include those of: NIREUS, SEAFARM IONIAN, KEGOagri, PROTEUS, PREDOMAR* A substantial amount of work is not performed by persons legally recognized as self-employed or by individuals who are not employees or supervised employees of the company or by its contractors.* There are seasonal variations in the number of employees (fixed-term recruitment), of approximately 60 people per annum.* The percentage of employees covered by collective labour agreements approximate 70% of total employees.

Principles 1, 2, 3, 4, 5, 6


39

Human Rights

The Group is committed to supporting the Universal Declaration of Human Rights of the UN, complying with all relevant legis-lation (of Greece and of the countries in which it operates). Furthermore, the Group’s priority is the satisfaction of its workforce(potential for further development, worthy benefits, organized seminars for further training).NIREUS seeks to ensure that its partners are not involved in any form of human rights violations.

Workplace

The NIREUS Group secures employees’ freedom of association and for this reason there are three employee unions with whichmanagement engages in open and frequent communication. We adhere to legislation which prohibits any form of forced orcompulsory employment.

According to the principles governing the Group, and in compliance with the UN Global Compact, our Group does not supportor encourage child labor. This is referred to in a large number of customer contracts. NIREUS Group recognizes that its greatestasset is its people, and is therefore attentive in promoting professional advancement and development through training andother activities. It furthermore, promotes through various corporate benefits, a work balance between professional and personallife. The Group is therefore in full compliance with the Greek Legislation.

Training and EducationContinuous training and education is the basic pillar of development of human capital

NIREUS Group has a widespread perception that its vision for continuous advancement in business and employee performanceis directly linked to the continuous enhancement of its competencies and skills.

Continuous, broad and targeted training of our workforce has been noted to be very crucial for both the company and employeesthemselves.

During the design and implementation of training programs, areas requiring improvement are identified and needs are assessed.Thereaster specific objectives are set as well as educational material required for meeting these targets.

Workers in the packaging unit of Aliveriou


Principles 1, 2, 3, 4, 5, 6

40

Being mindful of this, in the two year period 2014-2015 the following training activities were held:

2014

In 2014 the Group financed employee participations in postgraduate programs and diplomas HACCP Training for Health and Food Safety

Workshop on the Global Food Standard British Retail Consortium BRC / ISSUE 6 In-house training for the New Tax Code, changes in Law 4093/2012 in addition to amendments in the income tax legislation

Seminar on Payroll adapted to the New Labour legislation Long-term seminar of a100- hour duration was held at the Athens Information technology with the following subject: Tech mini MBA: Leading strategic innovation Sales Seminar with the subject "Communication in the workplace: communicating with colleagues and customers" Moreover, employees participated in business topics and personal advancement such as:

● “Supply chain management”, ● “Time & stress management”, ● “Types of Work Behaviour" and ● “HR Master Negotiation” Furthermore, participation was attended in the following conferences: ●6th Panhellenic Procurement and Supply Management Conference. ●3rd Conference on Business Intelligence "The data 360 Forum" ●1st International Congress of Applied Ichthyology and Aquatic Environment "Hydromerit 2014". The conferences’ themes were driven by the presentation of scientific work, including the production potential

of our country’s aquaculture industry as well as the promotion of sustainable water use.

Employees of the Fattening unit of Astakos


41

In 2015, the training needs of employee programs continued in areas such as in: The Financial Department on issues which relate to the Greek Accounting Standards of L.4308 / 2014 The Production Department for Food Safety and Hygiene -HACCP. The objective set was to train employees on Health

and Safety issues as well as training all staff of the Quality and R &D department for the certification of international standard GLOBAL GAP Compound feed manufacturing as well as ensuring their participation in the "Fish Welfare for Aquaculture Specialists", by early 2017.

Moreover, in context of employee development, postgraduate training programs continued in the Financial

and Supply Chain departments in addition to foreign languages being taught while further intensifying participation in conferences.

More specifically the following were held: In-house seminar at Koropi with the subject "Greek Accounting Standards L.4308 / 2014" Seminars "Hygiene and food safety -HACCP." The seminars were carried out by certified professional staff from the EFET

During the year 2015, actions for the 2 production plants of NIREUS in Patras and New Artaki commenced in order that the standard GLOBAL GAP Compound Feed Manufacturing certification be obtained.For this reason a seminar was undertaken for its better understanding and application.

Training programs were held in cooperation with the Hellenic Management Association (HMA) aiming at providing high-level postgraduate professional specialization in key practice areas of Financial Management and of the MBA.

Programs addressing issues such as: ●“Developing teamwork skills” ●“Lead your team” ●“Inventory management in times of crisis” ●“Credit risk management” ●“National and European Legislation Analysis and practical aspects of the Greek Capital Market” ●Specialized IT seminars "Microsost SQL Server" ●English Courses

Participation in conferences on the following topics:●Reliable and Economical International Freight Transportation", organized by the Supply Chain Institute.

●"11th E-Business Forum», Applications of electronic Marketing ●“4th Conference Interdisciplinary Approaches in Fish Skeletal Biology"

with an emphasis on issues of fish skeletal malformations. ●“CSR in Action- Making the difference”.

2015


42

The supply chain of NIREUS Group consists of the Procurement andLogistics Department which operate under recorded and approvedprocedures, ensuring transparency and effectiveness.

The main objective of the Procurement Department is to ensure asufficient level of supplies, of any type, and at competitive prices,to seek new reliable suppliers and new alternatives and / or inno-vative products ascertaining the smooth operations as well as re-ducing the Group’s procurement costs.

The number of suppliers in the supply chain totals 1,990 and is seg-regated into the following main categories:

▶ Raw fish feed materials for plants

▶ Raw and secondary materials for fish farming

▶ Packing material (for aquaculture & fish feed)

▶ Fixed assets

▶ Technical projects

▶ Repairs / maintenance services

▶ Services

▶ Transportation

From the above figure mentioned, 90% are domestic suppliers.

The Logistics Department ensures that the Group’s productsare delivered on time, in the proper quantity and quality inview of reducing both the Group’s transportation costs aswell as the method of transporting goods (imported and ex-ported).

The Group has three logistic centres, of which one is locatedin Koropi, 1 in Patras and 1 in Italy.

Logistics Centre in KoropiIn Koropi, Attiki, a logistic centre is located which includeswarehouses for our products (maintenance, refrigerators andfreezers) of a surface area of 1,076 m2 as well as five ownedrefrigerator trucks used for transporting our products withinGreece. Furthermore, the company’s air transportation deliv-

eries via the Athens airport are performed from our logisticcentre in Koropi.

The centre, which employs 10 workers and has 4 cargo rampswith a capacity of 210 tons per week, through which our prod-ucts are distributed to 19 countries.

Logistics Centre in PatrasThe logistics Centre in Patras began its operations in 1997 in theIndustrial Area of Patras. In 2005 it transferred its facilities to itsroofed plant facilities of 2,500 m2 near the Rio Bridge, which hasrefrigerator freezers of a total surface area of 750m2, 7 loadingramps and two reception ramps.The centre employs 21 workers and has a capacity of 650 tonsper week, while it delivers NIREUS products to 230 customers in24 countries.

It carries out major transportation and distribution servicessuch as:▶ Deliveries to all Greek market customers,

within 8 hours from the moment of product packaging ▶ Delivery of food and packaging materials through

its own fleet▶ Monitoring and temperature recording systems in all

national and 60% international transportation trucks▶ Transportation and product distribution of all sizes

from 1 box to 1 truck all across Europe▶ Scheduled departures 365 days a year, with a 24-hour

surveillance of all deliveries▶ Designing and Planning product pick-ups forwarding

goods for shipment throughout Europe from our 2 different Logistics Centers and 3 Packaging units

▶ Innovative services specifically tailored to each customer at the lowest cost

Logistics Centre in ItalyThe presence of NIREUS in Italy begins from its initial establishment.Given that the Italian market is very wide, it has always been con-sidered as a tremendous opportunity for our Group. We had ap-proached this market in the past either directly throughrepresentatives or by immediate contact through our Sales depart-ment at Koropi. In 2009 and due to the increase of our exports toItaly, it was decided upon to establish a branch in the local region.Our offices are located in Colturano (Milan) within the logistics prem-ises of STEF, which is a European leader in the transportation and

G4-12

Supply Chain


43

storage of fish, as well as being our strategic partner.

Goods are transported from Greece to Colturano 4 times aweek, which are then distributed to more than 70 destinations(S / Ms & Wholesalers).Services provided through the branch are more efficient andcompetitive, given that this also ensures the highest possiblequality and freshness of the products.The workforce of our branch consists of the Director Mr. Gio-vanni Bacchini and two other employees.The branch’s objectives as set, since its establishment are nu-merous, analysed as follows:

▶ Closer contact and presence with major customers so as to strengthen and reinforce our collaborations

▶ Exploiting opportunities available in the market not only with respect to new customers but as well as to new markets or market niches

▶ Continuous effort for cost reduction and satisfactory market growth (without intermediaries, consumers margin account, timely payments, better logistics and other)

▶ “Building” in Italy a high quality image for NIREUS products at every stage, in order that each product delivered be considered as unique.

Loading procedures


44

Environmental Management SystemThe design of the Environmental Management System hasbeen prepared in accordance with the Process Mappingmethodology. The initial step of the process includes a de-scription of each production process and thereaster as a nextstep, and for each process, all inputs (e.g. raw materials, in-frastructures, employees) and all outputs (products) are there-aster recorded. An "environmental aspect" is defined as an"element of a company which has an environmental impact"(ISO, 2004).We consider each input and output as being an en-vironmental aspect or parameter of aquaculture activity. Fol-lowing the above, environmental parameters are assessed fortheir impact on the environment, considering the number andmagnitude of incidences occurring. The assessment is docu-mented according to the International Bibliography, the Lawas well as to previous years' experience. Parameters evalu-ated as being significant become topics of environmental pro-grams. This process is repeated on an annual basis so thatperformance and substantiality of the applied environmentalprograms, be evaluated.

G4-14

NIREUS Group has, over the years, been committed to achieving acontinuous improvement with respect to environmental perform-ance, to the prevention of pollution, to the implementation of theprecautionary principle as well as to ensuring compliance with leg-islation. Towards meeting this end, the Group applies a continuouslyevolving Integrated Management System to all its activities, includ-ing the environment, occupational health, and safety of operations.Besides being certified by GLOBAL G.A.P., ISO certifications are alsopossessed in accordance with the international ISO standards 9001:2008, ISO 22000: 2005 (HACCP), ISO 14001: 2004 and BRC GlobalStandards (British Retail Association).

Principles 7,8,9

Net Repairing

Environmental Management


45

Recycled Material 2015 2014Batteries and Accumulators 600 kg 1,500 kg

Paper 4.3 tn 4 tn

Ink Ribbons 243 pieces 500 pieces

Oils 1,800 lt 2,000 lt

Polystyrene 46.5 tn 50 tn

Protection of marine ecosystems in farming unitsAn enormous weight is placed on the initial selection of afloating farming unit’s location in view of protecting both thebiodiversity and the environment. Detailed studies on the en-vironmental impacts, are prepared, which take into accountthe currents in the area, the depths and the calculation of theunit’s "Carrying capacity" ensuring no impact on the environ-ment and on the biodiversity. Calculations are based on anumber of research projects and years of studies. Further-more, an external and independent body certifies that nomeadows of Posidonia oceanica which comprise an indige-nous species of the Mediterranean sea, exists at the bottomof the sea. The underwater meadows of Posidonia are themost important ecosystems of the Mediterranean sea, actingas forests, protecting the seabed from erosion and maintain-ing the ecological balance.

During the years 2014-2015, 500 physicochemical and 610 mi-crobiological analyses were carried out per year.

The physicochemical analyses, performed entailed the analysisof heavy metals, mercury, pesticide residues and salt nutrients,and microbiological Total Viable Count (TVC),Total Coliforms, E.coli, Staphylococcus aureus, Salmonella, Listeria, Fecal strep-tococci, Clostridiumperfringens, Pseudomonas, Fecal coliforms.

The biodiversity on the seabed underneath the farming unitsare annually monitored, in conjunction with the chemical andmicrobiological indicators, while the results are evaluated inthe same manner.

Monitoring liquid waste parametersWe distinguish among two waste categories according to theproduction process: seawater in hatchery units and fresh water

in packaging and fish processing units.

Most hatcheries operate by means of a "flow through" systemwhereby seawater is pumped and then processed so as to pre-vent the transmission of pathogenic organisms from the opensea, bypassing through sections of the units as well as fromliquid waste processing, ultimately returning back to the marineenvironment.

Liquid waste derived from fish packaging and processing units,is processed in specially designed biological treatment units.All liquid waste is monitored for biochemical oxygen demand(BOD), chemical oxygen demand (COD), total suspended solids(TSS), total nitrogen and total phosphorus through laboratoryanalyses performed either in in-house laboratories and/or atexternal accredited laboratories. The purpose of the analysesis to ensure that the physicochemical properties of the final re-cipient (sea, sewage nets) will not be modified. During the years2014-2015, 750 and 700 analyses respectively, were under-taken in wastewater.

Solid waste managementThe largest volume of waste generated by the farming processconsists of fish feed plastic bags which are collected and sent forrecycling.

The final produced product is packaged in fish containers from ex-panded polystyrene. Meanwhile, the Group and in cooperation withits suppliers, is seeking and examining alternative means of pack-aging material.

The Group actively participates in Collective Recycling Programsheld nationwide but is also engaged in smaller own developed proj-ects which it has developed. Projects are reassessed and the Groupis in continuous search for materials and partners in order to im-prove its environmental performance.


46

European Pact 4 Youth

The Company has also signed the European Pact 4 Youth, which com-prises a joint commitment among the business world officials and theEuropean Union. It relates to an initiative of the CSR Europe in coop-eration with its national partners, which brought together represen-tatives of the business industry, of the academic world, youth andEuropean regulatory officials. According to the Pact, all enterprises,social partners, professional training providers, youth organizations,public and private sector employment agencies, teachers, trainers,students, parents as well as other significant bodies, develop and re-inforce collaborations that support young people’s employability andintegration of youth without any exclusions.

G4-16

Participation in organizations/associationsThe Company supports and is a member of the following

organizations:

▶SEV (HELLENIC FEDERATION OF ENTERPRISES)

▶SEV WESTERN GREECE

▶FGM (FEDERATION OF MARINECULTURE)

▶ACCI (HELLENIC ATHENS CHAMBER OF COMMERCE

AND INDUSTRY)

▶PEA (PANHELLENIC EXPORTERS ASSOCIATION)

▶HMA (HELLENIC MANAGEMENT ASSOCIATION)

▶ENTREPRENEURSHIP CLUB

▶CSR NETWORK (GREEK NETWORK

OF CORPORATE SOCIAL RESPONSIBILITY)

▶HELLENIC ECONOMIC CHAMBER

▶ASSOCIATION OF FISH FARMERS THESPROTIAS

▶GREEK-RUSSIAN CHAMBER

▶GREEK-ITALIAN CHAMBER

▶GREEK-TURKISH CHAMBER

▶ARAB-GREEK CHAMBER

▶COMPANIES UNION OF EAST ATTIKI

▶ILME (HELLENIC INSTITUTE OF LOGISTICS MANAGEMENT)

▶GREEK LOGISTICS COMPANY

▶ASSOCIATION OF HUMAN RESOURCES MANAGEMENT

Participation and Recognition

G4-15

Global Compact UN

NIREUS is the sole Aquaculture company in Greece which, since2008, supports the Global Compact of the United Nations (UNGlobal Compact), and whose primary objective it to build andpromote social legitimacy of businesses and markets. It is thelargest global initiative of Sustainable Development in whichmore than 3.500 companies from over 100 countries participate.


47

NIREUS Group recognizes as stakeholders, those impacted by its activities and those who impact, through their decision making,the Group’s long-term sustainability. The table below presents information with respect to the Group’s stakeholders and mannerof engagement with them.

Stakeholder Engagement

G4-24 G4-25 G4-26 G4-27

Method and frequency of engagement

EMPLOYEESMETHOD OF COMMUNICATION FREQUENCY & ENGAGEMENT OF ENGAGMENTE-mails Per occasionElectronic corporate newspaper MonthlyTelephone Communication Per occasionWritten announcements Per occasionon notice boards

SHAREHOLDERS & INVESTORSMETHOD OF COMMUNICATION FREQUENCY & ENGAGEMENT OF ENGAGMENTTelephone Communication On occasionE-mails On occasionMeetings Annual and on occasion

UNIVERSITY COMMUNITYMETHOD OF COMMUNICATION FREQUENCY & ENGAGEMENT OF ENGAGMENTResearch 3-4 times per yearMeetings On occasionE-mails On occasion

LOCAL COMMUNITIES & AUTHORITIESMETHOD OF COMMUNICATION FREQUENCY & ENGAGEMENT OF ENGAGMENTPersonal contact – Meetings ContinuousTelephone Communication Monthly and on occasionE-mails Frequent and on occasion

NON-GOVERNMENTAL ORGANIZATIONS (NGO) METHOD OF COMMUNICATION FREQUENCY & ENGAGEMENT OF ENGAGMENTMeetings Twice a yearE-mails MonthlyTelephone Communication Monthly, on occasion

SUPPLIERSMETHOD OF COMMUNICATION FREQUENCY & ENGAGEMENT OF ENGAGMENTTelephone Communication Continuous and on occasionE-mails Continuous and on occasionMeetings Frequent

CUSTOMERSMETHOD OF COMMUNICATION FREQUENCY & ENGAGEMENT OF ENGAGMENTE-mails DailyTelephone Communication DailyMeetings 2-3 times per yearInternational Reports Annual

STATE AND REGULATORY AUTHORITIESMETHOD OF COMMUNICATION FREQUENCY & ENGAGEMENT OF ENGAGMENTE-mails Weekly- MonthlyTelephone Communication MonthlyPersonal Contact On occasion

SECTORS, ASSOCIATIONS AND BODIESMETHOD OF COMMUNICATION FREQUENCY & ENGAGEMENT OF ENGAGMENTTelephone Communication WeeklyΕ-mails Weekly-MonthlyMeetings Monthly and on occasion

UNIONS AND ASSOCIATIONSMETHOD OF COMMUNICATION FREQUENCY & ENGAGEMENT OF ENGAGMENTTelephone Communication On occasion Ε-mails On occasion Meetings On occasion

MANAGEMENT OF SUSTAINABLE DEVELOPMENT


48

Researchand Development

Major Topics of interest and method of response

Section Report: Health and Consumer Safety

We ensure the quality of products we provide following a number of goodpractices including:

▶ Non-use of genetically modified raw materials▶ Continuous monitoring of the farming processes▶ Constant and strict quality controls on fry, fish feed,

finished end products▶ Monitoring the environment through rigorous tests

and measurements▶ Complete traceability system.

Section Report: Occupational Health and Safety

One of the Group’s principles and commitments is to ensure the overallhealth and physical integrity of its labour force working on its sites. Forthis purpose, the Group has allocated a significant part of the responsibleDepartment’s budget to training its workforce.

Section of Report: Business Ethics and Integrity

Professional ethics and values have been incorporated in the Group’sCode of Conduct, which came into force in 2013 and which depicts theGroup's objectives to each shareholder, partner, trader and employee, aswell as our commitment to high standards of conduct and our continuousstrive for improvement in all areas of major concern.

Section Report: Regulatory Compliance

The governing responsible officials that exist within the Group and all rele-vant Departments comprise the guardians of compliance with Group’s obli-gations. The fact that the Group has not been imposed with major fines ornon-monetary sanctions for non-compliance with laws and regulations dur-ing 2014-2015, is a result of both its existing and effective structure as wellas its ongoing monitoring compliance with all regulatory obligations.

Section Report: Financial Performance

The Group has established procedures and has set key performanceindicators for monthly reporting requirements to the Board of Direc-tors on its financial performance. Meanwhile, it has also establisheda weekly reporting procedure on informing management directorswith respect to trends in revenue being the main source of funding.

Section Report: Fish Health and Welfare

Policies and actions that contribute to the health and welfare of fish havebeen incorporated in the Group’s plans, while for the following years itsgoal remains high with respect to improving the survival rate of fish by 4percentage points until year 2020.

Section Report: Research and Development

The Group’s Research and Development department has prepared a 5-year business plan approved by the Board. The project’s annual budgetand its infrastructure for the implementation of research projects in directcooperation with academic institutions and research bodies. PROTEUS inturn innovates and provides final solutions through the use of anti-foulingand trial use of stunner equipment.

●University Community●Suppliers●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions

MAJOR TOPICS OF INTEREST

METHOD OF RESPONSE

STAKEHOLDERS

Consumer Healthand Safety

Occupational Health and Safety

BusinessEthics andIntegrity

RegulatoryCompliance

EconomicPerformance

Fish Healthand Welfare

●Employees●NGO●University Community●Local Communities & Authorities●Suppliers●Customers●Shareholders & Investors●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions

●Employees●NGO●State & Regulatory Authorities●Sectoral associations and entities●Trade Unions

●Employees●NGO●University Community●Suppliers●Customers●Shareholders & Investors●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions

●NGO●Local Communities & Authorities●Customers●Shareholders & Investors●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions

●Suppliers●Shareholders & Investors●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions

●Employees●NGO●University Community●Customers●Shareholders & Investors●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions


49

Liquid Effluentsand Waste

Βασικά θέματα ενδιαφέροντος και τρόπος απόκρισης

Section Report: Sustainable Fish Feed

The Group has succeeded in reducing the use of fishmeal from 30% to18% and of fish oil from 7.5% to 4%. The improvement of the FIFO ratio(Fish In Fish Out) is equally important, reduced from 1.9 in 2014 to 1.76in 2015, while the target for 2019 is set at 1.5.

Section Report: Marine Spatial Planning

The Group has a leading role in the establishment of special managemententities in organised regions of aquaculture development, as defined bythe law in accordance with the specific spatial framework of 4/11/2011.During 2015, the Group participated and supported the establishment ofspecial management entities in organised regions of aquaculture devel-opment, in three geographical areas (Echinades, Argolida, Chios), and intwo geographic regions of (Thesprotia, Amvrakikos) in 2014.

Creating value for local communities:

▶ Product donations and other sponsorships▶ Employment of local communities to a very large percentage

of the Group’s total workforce▶ selecting suppliers from local communities▶ carrying out training activities in our facilities▶ constant and frequent engagement with them.

Section Report: Raw Materials

It has been established a policy of raw material supplies, whereby thesupply of raw materials is made through the Group’s approved suppliers,according to specific procedures outlined in the respective quality controlforms (ISO) of the Group.

Professional development is based on evaluation and internal transfers

Benefits: company cars, company mobiles, interest-free loans, salaryadvance payments, marriage bonuses, christening, 3 days leave peryear over and above the specified per law.

Examining product labels for sale of products (positive release)

Monitoring legislation in all countries to which we export so that productlabelling complies with the legal requirements of each country.Exclusive collaborations with customers for branded product.

Continuous monitoring of qualitative parameters of effluents in both thefully equipped laboratory as well as in external accredited laboratoriesMonitoring farming water parameters.

Developing solid waste recycling systems

Our Group is attentive to providing employees with professional advance-ment and briefings through training and other activities.

●Trade Unions

MAJOR TOPICS OF INTEREST

METHOD OF RESPONSE

Sustainable Fish feed

Marine Spatial Planning

Creation of Valuein LocalCommunities

Raw materials

Professionaldevelopment and services

Product Labelling

Educationand EmployeeTraining

STAKEHOLDERS

●NGO●Customers●Shareholders & Investors●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions

●Local Communities & Authorities●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions

●Trade Unions

●NGO●Suppliers●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions

●Employees●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions

●University Community●Local Communities & Authorities●Shareholders & Investors●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions

●NGO●Local Communities & Authorities●State & Regulatory Authorities●Sectoral associations and bodies●Trade Unions


50

In May 2016, NIREUS completed a materiality analysis alongwith the collaboration of both internal and external stakehold-ers, in view of identifying material sustainable development is-sues to be included in the contents in the present Report for theperiod 2014-2015. Material issues are those that either reflectsignificant economic, environmental and social impacts orwhich significantly impact NIREUS stakeholders’ evaluationsand decisions.

The materiality analysis will also be used by NIREUS as a pointof reference for reviewing and improving the wider sustainabledevelopment strategy of the Group. The analysis has been con-ducted for the first time in accordance with the SustainabilityReporting Guidelines GRI G4 and therefore there are no differ-entiations in relation to material aspects and major topics or totheir boundaries, as compared to previous years. Furthermore,there are no restatements in either the data or information thathave been published in previous reports.

The materiality analysis methodology of sustainable develop-ment issues is presented below:

Phase 1: Identification of relevant topicsIn the first phase of the analysis, NIREUS has taken into con-sideration the GRI G4 Principles of Stakeholder Inclusivenessand the Sustainability Context, and has recognized topics in re-lation to activities and it stakeholders. Findings have beenraised following the review of the following:

▶Internal documents on policies, procedures, strategies and conclusions following prevailing engagement with stakeholders

▶Relevant publications for the period 2014-2015 in relation to farming operations and to the NIREUS Group

▶Reports of the NIREUS Group on Sustainable Development for the years 2012 and 2013

▶Sustainability Reports issued by similar foreign companiesin the global aquaculture industry

▶New global Sustainable Development Goals of the United Nations

▶Publications of the GRI's organization issued for the food industry

▶Leading international sustainability standards and directives set for both the aquaculture sector as well as for the wider industry.

Phase 2: Prioritization of aspectsIn the second phase, the Group has considered the GRI G4 Prin-ciples of Materiality and Stakeholder Inclusiveness and has pri-oritised issues identified in the first phase, according to twocriteria:

▶the importance and materiality of issues on the Group’s long-term strategy and sustainable development

▶the importance and materiality of issues to the Group’s internal and external stakeholders

With respect to the first criterion, the Group has formed a spe-cial 'workshop', with the involvement of NIREUS managers, inorder to prioritize issues.

With respect to the second criterion, the Group has conductedan electronic survey along with its stakeholders. The resultshave assisted in preparing a more qualitative analysis of theGroup’s major topics, in addition to obtaining a better under-standing of the participating teams’ expectations and concerns.The results of the analysis are presented in the materiality map.

Phase 3: Validation of the resultsDuring the third phase of the analysis, NIREUS along with theGroup’s upper level management has validated the results ofthe second phase. This procedure considered the GRI G4 Prin-ciples of Stakeholder Inclusiveness and Completenes.

Through this analysis, 11 topics were identified and selectedfor inclusion in the Report, which are presented in pages 54-55 along with their impact boundaries as analysed in the sec-tion Key Topics/Material Aspects. The materiality map belowshows 22 recognized sustainability topics as prioritised basedon the materiality analysis.

G4-18 G4-22 G4-23

Materiality Analysis of sustainable development issues

G4-19


51

1

20

10

87

4

21

3

18

2

6

SIGNIFICANCE FOR THE NIREUS GROUP

SIGN

IFIC

ANCE

FOR

STA

KEHO

LDER

S

1. Marine Spatial Planning2. Economic performance3. Regulatory compliance4. Business ethics and integrity5. Anti-competitive behaviour6. Research and development7. Fish health and welfare 8. Sustainable fish feed9. Biodiversity10. Raw materials and products11. Liquid effluents and waste

12. Energy13. Greenhouse gas emissions14. Responsible supply chain15. Employment16. Education and employee training17. Professional development and benefits18. Occupational Health and Safety19. Diversity and equal opportunities in the working environment20. Creating value in local communities21. Consumer Health and Safety 22. Product Labelling

Materiality Map of NIREUS Group


52

The following diagram depicts the life cycle of the Group’s aquaculture products, linking phases in the life cycle to its subsidiariesand to external stakeholder groups. The following diagram has been included for a better understanding of the below table onthe impact of the material aspects of the Group’s sustainable development.

Material Aspect Boundaries

G4-19 G4-20 G4-21

The following table presents the life cycle phase for each ma-terial aspect in which the major impacts occur, as well as theaspect boundaries of the entities within or outside the Groupwhich may cause or be associated with the impacts. The sec-tions of the key topics and material aspects (pp. 56-87) includea detailed description of the impacts and our approach to man-aging the underlying causes of the issues raised. The specifiedmaterial aspects have been based on the WorldwideSustainable Development Goals of the UN.

More specifically, in September 2015, all Member States of theUnited Nations adopted a plan to achieve a better future for all,by developing a course of action for the following 15 years toeradicate extreme poverty, fighting inequality and injustice andprotecting our planet. The heart of this “Agenda 2030 "includes17 Sustainable Development Goals (Sustainable DevelopmentGoals - SDGs), and 169 additional specific targets which relateto these goals and in relation to the most challenging issuesof our time (economic, social, environmental and governance).

Life cycleof aquaculture

products

RAW MATERIALSPROTEUS EQUIPMENT SAAquaculture Farming equipment manufacturing companyKEGOagriAnimal production company

OTHER SUPPLIERSEND OF LIFE-CYCLEDisposal / Recycling (Packaging) /Recovery of Energy / Compost /Other economical recycling practices

CONSUMPTION

Final consumers

Associations and Bodies /Management entitiesEnd of Product Life Cycle

SUPPLY - SALE

CUSTOMERSSuper Market, wholesalers,processors, aquaculture companies

DISTRIBUTIONNIREUS AQUACULTURE SA E

& PREDOMAR S.L.Logistics: Koropi, Patras, Italy

PARTNERS / DISTRIBUTORS

PROCESSING - PACKAGING

NIREUS AQUACULTURE SA& PREDOMAR S.L.

8 modern packaging units

NIREUS AQUACULTURE SA1 processing unit

FISH FARMINGNIREUS AQUACULTURE SA& PREDOMAR S.L.4 hatcheries31 fattening units3 pre-fattening juvenile units

PRODUCTION OF FISH FEED

NIREUS AQUACULTURE SA2 fish feed plants


53

PAINTING CONTEST 2015for THE Group employees’ children aged 6-12 years with the theme "Journey to the underwater world"

detail from the artwork of Katerina Melachrous, age 11, Nea Artaki

54

MATERIAL ASPECTSSignificant impacts

based on WorldSustainable Development Goals

of the UN

Aspect Boundariesentities within or outside the Group which may cause or be associated

with the impacts

Life cycle phasein which

the impact occurs

CONSUMERHEALTHAND SAFETY

SUPPLIERS Raw materialsNIREUS AQUACULTURE SA

PREDOMAR S.L.PARTNERS / DISTRIBUTORS

Fish feed productionFish farming

Processing / PackagingDistribution

CUSTOMERS Supply / SaleCONSUMERS ConsumptionSUPPLIERS Raw materials

NIREUS AQUACULTURE SAPREDOMAR S.L.

Fish feed productionFish farming

Processing / Packaging

CONSUMERS ConsumptionEnd of Lifecycle

OCCUPATIONAL HEALTH AND SAFETY

SUPPLIERS Raw materialsNIREUS GROUP Fish feed production

PARTNERS / DISTRIBUTORS Fish farming Processing / Packaging

Distribution

PROTEUS EQUIPMENT SA Raw materialsSUPPLIERS

NIREUS GROUP Fish feed production

CUSTOMERS Supply / Sale

PARTNERS / DISTRIBUTORS Fish farming Processing / Packaging

DistributionCUSTOMERS Supply / Sale

BUSINESS ETHICS AND INTEGRITY

Raw materialsSUPPLIERS

NIREUS GROUPFish feed production

PARTNERS / DISTRIBUTORSFish farming


REGULATORYCOMPLIANCE

Raw materialsSUPPLIERSNIREUS GROUP Fish feed production

PARTNERS / DISTRIBUTORS Fish farmingProcessing / Packaging

Distribution

CUSTOMERS Supply/ Sale

ECONOMICPERFORMANCE

SUPPLIERS Raw materialsNIREUS GROUP Fish feed production

Fish farmingProcessing / Packaging

Distribution

CUSTOMERS

Disposal / Sale

SUPPLIERS Raw materialsNIREUS AQUACULTURE SA

PREDOMAR S.L.Fish feed production

Fish farmingFISH HEALTHAND WELFARE

NIREUS AQUACULTURE SAPREDOMAR S.L.

Fish farming


55

MATERIAL ASPECTSSignificant impacts

based on WorldSustainable Development Goals

of the UN

Aspect Boundariesentities within or outside the Group which may cause or be associated

with the impacts

Life cycle phasein which

the impact occurs

RESEARCHAND DEVELOPMENT

NIREUS AQUACULTURE SA Fish feed productionFish farming

NIREUS AQUACULTURE SAPREDOMAR S.L. Fish farming

SUSTAINABLE FISH FEED

SUPPLIERS Raw materials

NIREUS GROUP Fish feed productionFish farming

Raw materialsSUPPLIERSNIREUS AQUACULTURE SA

PREDOMAR S.L.Fish feed production

Consumption

Fish farming

NIREUS AQUACULTURE SA

MARINE SPATIALPLANNING

Fish farming

CONSUMERS

CREATING VALUEIN LOCAL COMMUNITIES

Raw materialsSUPPLIERS

NIREUS GROUPFish feed production

PARTNERS / DISTRIBUTORSFish farming


Supply / SaleCUSTOMERS

RAW MATERIALS

Raw materialsFish feed production

Fish farming

ConsumptionCONSUMERS

SUPPLIERSPROTEUS EQUIPMENT SA

NIREUS AQUACULTURE SAKEGOagri

Raw materialsFish feed production

Fish farming

SUPPLIERSPROTEUS EQUIPMENT SA



ANALYSIS OF MATERIAL ISSUES

Consumer Health and Safety


Business Ethics and Integrity

Regulatory Compliance

Economic Performance

Fish Health and Welfare

Research and Development

Sustainable Fish Feed


Creating value in local communities

Raw Materials

▶ Environmentally, economically and socially sustainable production of fish products.▶ Compliance with legal regulatory requirements concerning products’ safety and hygiene.▶ Providing high quality products and services by the Group to its customers.▶ Use of the most technologically advanced methods for production and product distribution, under the continuous

target of improving the quality and safety of produced fish and fish feed.▶ Timely delivery of products, according to mutually accepted contract terms.

Group Targets on Quality and Food Safety

Consumers demand the food they purchase and consume to be safe and of a high quality. Despite the fact that the institutionaland regulatory framework plays an important role in ensuring food safety and quality, the ultimate responsibility for ensuringthe implementation of appropriate procedures and controls lies with the food producing company, which supervises and monitorsthe products produced from raw materials to the final end product.

A food production company’s success which is measured in terms of profitability, is fully dependent upon the satisfaction of itsconsumers. Therefore, it is in the Group’s interest that it develops monitoring controls that ensure a continuously safe and highquality product.

In order to identify the critical points in determining health issues and product safety, the Group undertakes a Risk Analysis andCritical Control Points (HACCP - Hazards and Critical Control Points). Contrary to the approaches taken for quality assurance thatfocus on the final end product, following an approach in accordance with HACCP, acts as a prevention measure by identifyingcritical points in all stages of the production process.

Managing health and consumer safety concerns the Group's entire value chain, from the production of fish feed and farming tothe distribution of the final end product to customers. Meanwhile, the issue also significantly impacts all Group stakeholders.

Why is it material?

How do we manage this?

A structure of vertically integrated production processes, has al-lowed the Group to monitor controls applicable to all productionstages, from the broodstock up to the final end product, both withrespect to raw materials as well as, and up to, the intermediateand final end product.

The Quality Control Department, prepares annual budgets for thepurpose of monitoring raw materials, intermediate, semi-finishedand finished products.

The Group has established and operates three laboratories for thepurpose of product control, one of which is used to monitor freshharvested fish and two for monitoring feed. Through this mannerregular inspection of produced products is ensured. Furthermore,the Group has established and maintains a long-term relationshipwith specialized monitoring laboratories for testing a number ofparameters. Further specialized analyses for final end productsare regularly performed by the following institutions: Universityof Athens, University of Patras and Democritos.

The Group operates under a complete traceability system, in ac-cordance with predefined health and safety standards, meeting the

required standards and the needs of its customers worldwide.

It ensures the quality of products provided, abiding by a numberof good practices, including:▶ The non-use of genetically modified raw materials▶ The continuous monitoring of the farming processes▶ Continuous and strict quality controls for fry, fish feed,

finished products▶ Monitoring the environment through tests and measurements▶ A Full traceability system.

Traceability is a method applied to fish farming according towhich the Group records detailed information, at all stages ofthe product production process, such as from its birth, to itsgrowing process inside the sea, to its diet, its packaging andits delivery to its final point of sale destination. In this manner,we are in a position to trace the fish’s entire history until thepoint it reaches your table, thus being able to guarantee a safeand highly nutritious food product.

Consumer Health and Safety

58

59

How do we evaluate our approach?The effectiveness of the Group’s developed procedures andstandards is evaluated, through internal audits performed in allproduction facilities. All production procedures and supportingdocuments and records are monitored. Internal reviews and in-spections are made by professionally qualified personnel.

The Group is certified according to the following internationalrecognized standards for Quality, Health and Safety of products,Environmental Management and Best Practices:

ISO 9001: 2008ISO 22000: 2005BRCISO 14001: 2014GLOBALG.A.P.

Proper implementation is verified by inspections from third par-ties, including certified bodies, responsible state authorities,the EU and other countries to which the Group exports.Examples include:

FVO: Food and Veterinary Office EUFDA: Food and Drug Administration USAROSSELKHOZNADZOR: Russian Veterinary OfficeFurthermore, the Group is ostentimes subject to visits and in-spections from its customers.Inspections of farmed fish are both continuous and numerous.Apart from the same fish itself, tests are also performed withrespect to farming waters, fish feed and well as surface areaswith which they come into contact. Independent bodies and uni-versities monitor procedures, all of which are certified. All ofthe above guarantee high quality and provide reassurance tothe final consumer. More than 500 chemical analyses and 5,000microbiological analyses of raw materials, products, fresh andsalt water and surfaces are annually performed.

The majority of products will also undergo secondary long-termquality audits. 32,500 packages were inspected in 2015.

▶ Minimizing non-conformities to nil incidences.▶ Ensuring conditions that guarantee occupational health and safety.▶ The focus of all employees in a continuous effort to improve their quality of work.▶ Suppliers’ compliance with quality and technical standards and to specific product delivery schedules set by the Group.▶ Production of feed that does not transfer natural, chemical, biological hazards to farmed animals intended

for human consumption.▶ The supply and use raw material fish feed derived from sustainable production processes, placing an emphasis

on feed generated from the sea environment. Gradual reduction in the use of raw materials used for human consumption.▶ The production of non-genetically modified products and the use of non-genetically modified organisms in food.

The Group's targets are reviewed on an annual basis and are redefined based on the results of the Quality Control System’sand Occupational Health and Food Safety’s annual Reviews.

INCIDENTS OF NON-COMPLIANCE* 2014 2015Incidents of non-compliance with regulations resulting in a fine 0 0Incidents of non-compliance with regulations resulting in a warning 0 0Incidents of non- compliance with voluntary codes * 2 1Total number of incidents which impact health and safety 2 1

The percentage of total products produced in certified areas amounts to 53%.Percentage of total products produced in certified areas.

*Incidences of non-compliances recorded concern either rejection of raw materials and returns sent back to the suppliers or re-processing product procedures and re-cleaning procedures of equipment which were found to be below theboundaries which the Group has set in assessing its cleanliness.**Voluntary codes: Voluntary standards for safety and food hygiene. Voluntary commitments for non-use of genetically modified (GM) feed raw materials.

G4 PR2

The number of complaints and grievances we receive from customers corresponds to 0.15 ‰.

G4 FP5


The NIREUS Group, being an aquaculture group is particularly sensitive to Health and Safety issues. The quality of people’s work life,which impacts their productivity and ethics, is the starting point for the sustainable development whose target is to operate underhigh quality standards, respecting both its people and the environment. Managing this key topic, concerns all phases of the valuechain up to its distribution, with major impacts on its labor force.

Due to the fact that the Group's production processes and its numerous activities involved take place to a large extent in the sea en-vironment under difficult weather conditions, given that workers are engaged in onshore facilities and with sea fish farming, theGroup’s objective is to protect them by applying Hygiene and Security measures in order to minimise incidents and illnesses.

Given the human-oriented character of NIREUS Group, it does not see its human capital only as a factor of production, but further con-sider its people as being a factor that contributes to the potential welfare of all. With the contribution of its professional staff andthrough regular inspections, the Group monitors each parameter which may affect employees’ job security, taking all measures toprevent accidents and to improve the technological and aesthetic working environment.

Why is it material?


Internal labor regulationsIn December 2011, the Directorate of Social Inspection of East-ern Attiki ratified the Internal Working Regulations and code ofconduct which include all rules, rights, obligations, proceduresas well as the broader philosophy governing Personnel rela-tions with the Group.

The entire workforce is informed with respect to the Group’sinternal business policies which are posted on bulletin boardsand well as on a common electronic internet page.

More specifically, according to Articles 83-87 the company en-sures compliance with Health and Safety Standards in theworkplace, for the purpose of improving working conditions inaddition to supplying and replacing where deemed necessary,Personal Protection Equipment.

All facilities’ managers holding supervisory positions, are re-

sponsible for applying Hygiene and Safety measures to theirstaff in accordance with the suggestions and recommendationsof Physicians and Labour Safety Officers.

All employees are required to report any matter concerningHealth and Safety at work, complying with the Group's guide-lines in addition to maintaining the working environment cleanand organised.

In the event of labor incidents, first aid is provided either locallyor at the nearest Hospital depending on the severity of the in-cident. Furthermore, all procedures are fully abided by as stip-ulated by legislation in relation to the relevant notifications ofthe responsible institutions.

A number of actions are taken into account, aiming at prevent-ing the impact of harmful factors in the workplace, thus en-hancing the culture on safety in the workplace.


60

Physicians in the workplaceIn all NIREUS Group facilities, regularly visits are performed bySpecialised Labor Physicians who maintain medical records forall workers, issuing certifications regarding staff’s Medical Suit-ability, with the possibility of renewal at regular intervals. Re-newal procedures have been enacted since 2016 concerning allstaff on an annual basis.

Labor physicians undertake, through regular visits, employeetraining on first aid. Each unit in the local regions, maintain afirst aid pharmacy, while the head of each department, accord-ing to doctor's advice, is responsible for renewing medical andrelative material. The doctors’ written instructions are recordedin a special company book. Furthermore, a Blood Bank is main-

tained for fulfilling the needs of employees and their families,when deemed necessary.

Employee Training and DevelopmentThrough staff training on issues relating to early detection andmethod of managing risks, employee safety working practicesare promoted, thus reinforcing a safe working culture.

A two-day training course of a 14 hour duration on HACCP Hy-giene and food safety with the participation of 28 people wasperformed in March 2014 in our facilities in Chios. Issues dis-cussed in the training program included, among other matters,employee personal hygiene, hygiene during the process of ac-cepting delivery of raw materials, hygiene during food prepa-

The Group’s basic principle and commitment is to preserve the overall health and physical integrity of its personnel working onits sites.

61

The program’s target is to train all NIREUS Group employees in all branches and areas of specialisation, by early 2017.

Targets

How do we evaluate our approach?Safety TechniciansThroughout the year, visits are made by Safety Technicians soas to ensure that safety rules are complied with, and who alsotrain employees, through visits held in the year, in the use ofPersonal Protective Equipment that satisfy both the require-ments as well as employee staff positions.

Safety Technicians are also responsible for preparing studies,available in all our facilities, on occupational risks and hazards.

From November 2015 up until September 2016, all studieswere certified by experts in all Group facilities.

Occupational risk assessmentThe assessment of occupational risk comprises a complex and dy-namic process which through the working environment analysis,contributes to the formation of a healthy and safe workplace adaptedto human potential.

All information and data derived from the working environmentanalysis and its impact on health and safety, properly processed,

contribute to the formation of preventive interventions that help toadjust the working environment to the dimensions of the workingemployee.

A proper and effective assessment of occupational risks, is thus, abasic requirement for safe work, rendering it fundamental in avoid-ing negative impacts.

Monthly reporting formsIn the context of continuous improvement of employee Health andSafety in the working environment, the Legal and Corporate affairsdepartment, in May 2013, established a procedure of completingmonthly reporting forms in relation to health, safety and other ad-ministrative issues concerning all Group units located either on landand/or in the sea area. This monthly form is completed by eachunit’s responsible official, under the supervision of his manager,and which through e-mails is then sent to the Head of Legal andCorporate affairs who then has the responsibility of informing otherdepartments, if deemed necessary.

ration as well as cleaning and disinfecting areas, surfaces,equipment and utensils.

Similar topics were discussed in June’s 2014 HACCP 14 hourduration seminars carried out in the facilities in AstakosAitoloakarnanias and in Patras with the participation of 18 and17 people respectively.

HACCP training seminars on Hygiene and food safety continuedin 2015 as well, with the participation of 21 employees fromour plant in Fokida and 20 workers from the production plantin Koropi.

In May 2016 a need arose for more specialized staff training

concerning "Health and Safety in the Workplace".

During the period May-July 2016 seminars were held in 4 majorGroup facilities in Astakos, Fokida, Igoumenitsa and Aliveri, incollaboration with external parties.Topics discussed included security and safety marking in work-ing areas, use of protective equipment as well as dealing withurgent incidents at work.Discussion matters were applied to specific employee work po-sitions and to those participating in the seminars such as fish-workers, ichthyologists, divers, sailors, night guards, etc.

A total number of 400 employees were trained through seminars of a total duration of 92 hours.

* The injury rate is expressed as the number of injured workers per 100 employees. Injuries observed in staff concerned minor injuries such as cuts, abrasions and slight sprains of arm-leg .** The lost working days ratio was calculated as a percentage of the number of total ill health days due to any disease and as a result of occupational incidents..*** The absenteeism rate was calculated as a percentage of total staff absentees in each unit to the total number of working days in each plant.

The indices in the table above relate to domestic operations in Greece. It should be noted that during the period 2014-2015 therewere no fatalities or cases of occupational disease.

2014 2015 M W M W 0.76 0 0,46 0LOST WORKING DAYS RATE** 0.00119 0.0004 0.00113 0.0005ABSENTEE RATE *** 0.004 0.005 0.007 0.003

INJURY RATE *

G4 LA6


Since inception, the NIREUS Group has stood out for its professional ethics and timeless values, which characterize every aspectof its business, in all applicable areas.

These values are incorporated in the Code of Conduct, which came into force in 2013 and which depicts the Group's position toeach shareholder, partner, trader and employee. This substantiates our commitment to high standards of conduct and our con-tinuous effort for improvement in all areas of concern.

Improper implementation and application of the above could negatively affect the entire value chain, as well as employees’morale, with the imposition of legal sanctions and fines to the Group, consequently impacting its reputation and financialperformance. For this reason, this issue has been a key topic of interest for most stakeholders such as Employees, Share-holders and Investors, the Academic Community, the NGOs, Suppliers and Customers, since it either directly or indirectlyimpacts their activities.

Why is it material?


Accountability and transparencyNIREUS Group is particularly attentive to the implementationof all Corporate Governance guidelines, which have been inter-nationally established and which mainly focus on providingcomplete and timely information to investors and to the rele-vant authorities, for each substantial issue concerning eithersignificant developments or financial information, and for theprotection of shareholders’ interests and rights.

Our primary interest is to communicate and notify all stake-holders with respect to our activities, in compliance with themandatory provisions, given that this ensures the required levelof transparency further to that it strengthens relationships oftrust towards our Group.

At the same time, our people’s duty and responsibility is to con-tinuously act in a lawful and ethical manner. They are further-more, to perform duties uninfluenced by others, refusing anyform of reward from third parties, to adhere to professionalconfidentiality and to refrain from any unauthorized commercial

act, or other practice, or from any prohibited use of inside in-formation.

Code of Conduct- Labour regulationsIn compliance with all the above and by applying all actionsrecorded in detail in the Group’s Code of Conduct, all employeesthereby contribute to the prevention and/or to the proper man-agement of any potential case of abuse, corruption or incorrectpractice, thus contributing to the sustainment of the Group’shigh reputation.

The Group’s principles on corporate ethics and employees’ ap-propriate conduct towards its customers, suppliers and otherpartners are, inter alia, referred to in the Group’s Code of Con-duct in Chapter F "Protection of interests and resources".

The Code of Conduct, also provides for the imposition ofpenalties in case of violation of rules, which are escalatedaccording to the seriousness of the misconduct ranging fromreprimand up to dismissal.

Business Ethics and Integrity

62

NIREUS Group supports the UN Global Compact as mentioned inthe relevant section of the Report "Participation and Recognition",since 2008. Certain principles of the Global Compact with whichNIREUS Group has voluntarily complied, include fighting against

corruption, including extortion and bribery, protection of interna-tionally proclaimed human rights, and non-complicity in humanrights abuses.

Global Compact of the United Nations (UN Global Compact)

Principle 10

63

Expansion of the Grievance Management Policy (WhistleBlowing Policy) enabling the notification of grievance incidents to the Group'sManagement as well as to any third-party stakeholder engaging with the Group such as public authorities, suppliers and customers.

Targets

How do we evaluate our approach?Regular and Ad-hoc Grievance ReportsHaving established numerous branches in Greece and abroad, andaiming at the establishment of direct and structured communicationof local working groups with headquarters, NIREUS Group has es-tablished, since 2013, a monthly policy on completing Regular andAd hoc grievance reports through a special form.All Branch Managers and Directors have been informed with respectto this Policy, while the relevant document has been sent and iscompleted on a monthly basis by the local responsible officials.This Policy systemizes critical issues monitored in all our facilities(labor, environmental, health and safety, etc.) and enormously as-sists local responsibles in providing direct notification for any majorproblem which may occur, to the company’s headquarters and toManagement.Through the above procedures, the manner by which the respectiveissues are being encountered is examined, in addition to being dealtwith by other responsible officials apart from regional managers,thereby ensuring objectivity and impartiality.

Grievance Management Policy (Whistleblowing Policy)Furthermore, the Group has established since 2013 a GrievanceManagement Policy implemented in all facilities, aiming at es-tablishing early warning procedures in view of tracking any il-legalities and irregularities for any matter relating to theGroup's operations. With respect this policy, all Group employ-ees are notified through relevant announcements.

On the basis of this policy, all Group employees have a moralduty to report instances or suspicions of irregularities that havecome to their attention and which is contrary to the Group’sproper course of business or is detrimental to the reputation,prestige, morale and /or to its economic interest.

In the context of this Policy, each worker has the right and ob-ligation to confidentially report to the General Department ofLegal and Corporate Affairs any concern in relation to any pos-sible violation of the Code of Conduct or failure to comply withthe prevailing legislation, via a special email address: [email protected].

Remediation PlansElectronic submission of Regular and Ad-hoc Grievance Re-ports through means of direct electronic submission and au-tomatic notification to all responsible officials concerned is inplace, thus maintaining, in this manner, an electronic file forthe purpose of transparency.

CONFIRMED INCIDENCES OF CORRUPTION AND REMEDIATION ACTIONS TAKEN *

Total number and nature of confirmed incidents of corruption.

Confirmed incidents where employees

were dismissed or disciplined for corruption

Confirmed incidents where contracts with business partners

were terminated or not renewed due to violations relating to corruption

Public legal cases regarding corruption in which the company or employees

were accused during the reporting period and the results of such cases

* Relates to the period 2014-2015

0

0

0

0

G4 SO5


Given the nature of the Group’s main activities, relating to food and primary production, the NIREUS Group is particularly attentive incomplying with all legal matters governing production facilities and processes. Regulatory Compliance is a key topic of interest tomost stakeholders, since it directly or indirectly impacts Shareholders & Investors, Local Communities, Authorities and NGOs, whileit relates to and has a material impact on all phases of the Group’s value chain. Incidences of non-compliance with regulations andlegislation may have a potential adverse impact on our reputation and on our financial performance, with the possibility of havingsanctions and fines imposed.

More specifically, the Group ensures regulatory compliance with all forms of additional production activities including packaging, fishfeed plants, etc. Furthermore, by providing employment to over 1,100 employees and being one of the largest employers in the country,the Group has an organized payroll department which ensures compliance with labor and social security legislation. Finally, giventhat the NIREUS Group has listed its shares for trading on the Athens Stock Exchange since 1995, it is subject to all provisions of theCapital Market regulations.

Why is it material?


Audit CommitteeThe Audit Committee’s mission and discussion matters in meet-ings, is to ensure the effectiveness and efficiency of corporate op-erations, the reliability of financial reporting to the Group’sinvestors and shareholders, the Group’s compliance with the ap-plicable legal and regulatory framework as well as protection ofthe Group’s investments and assets, in view of identifying and ad-dressing the most significant risks.

Responsibilities :▶ monitoring financial reporting procedures,▶ monitoring the effectiveness of internal audit and risk

management procedures, in addition to monitoring the proper functioning of the internal audit department of the company under audit,

▶ monitoring the statutory audit’s progress of the individual and consolidated financial statements,

▶ overviewing and monitoring issues related to the existence and maintenance of objectivity and independence of the statutory auditor or audit firm, particularly concerning other services being provided by the statutory auditor or audit firm.

Regulatory Compliance

64

The governing bodies as well as the relevant Departments that prevail within the Group constitute the Guardians of compliancewith the Group’s obligations, as referred to below:

Internal AuditMonitoring procedures of the Group’s regulatory obligationswhich are performed by the Group’s Internal Audit department,an independent department which is supervised by the AuditCommittee, is of greater decisive significance.

The Internal Auditor has complete, free and unrestricted accessto all Group companies’ premises, officers of all hierarchicallevels and data within the context of regular and ad-hoc audits.

Main responsibilities include the following:

▶ The implementation of Internal Business Policies, the Statute and the legislative framework governing the Group’s operations and activities.

▶ Reporting to the Board of Directors any conflicts of private interests between Board membersor executives, versus Group interests.

▶ Preparing reports to the Board of Directors for audits undertaken.

* The composition and functioning of the Audit Committee is governed by the provisions of article 37 of L.3693 / 2008

Principle 10

65

How do we evaluate our approach?

The Responsible DepartmentsFurthermore, the Group has special departments in relation tothe monitoring of thematically separated regulatory require-ments governing its activities, namely:

1) General Legal and Corporate Affairs Department

This department includes the Group's Legal Department, theHuman Resources Management, Regulatory Compliance andCorporate Social Responsibility.

2) Quality DepartmentThe Department deals, inter alia, with the compliance of legis-lation, ensuring the highest quality governing production and

sale of the Group's products.

3) Relations with Investors andCorporate Announcements Department

The main objective of this Department is the fulfillment of allobligations arising from the Stock Exchange Market regula-tions.

4) Licensing DepartmentThis department is primarily concerned with monitoring allGroup regulatory and individual obligations as regards permits(licenses, environmental conditions, etc.)

The fact that the Group has not been subject to significant fines or non-monetary sanctions for non-compliance with laws and regulations during the period 2014-2015 is the result of the Group’seffective and existing structure as well as ongoing monitoring procedures and compliance with allregulatory obligations.

Meetings of the NIREUS Group Audit Committee

(01/01/2015-31/12/2015)

participation of all members

either in person,

either by proxy

(01/01/2014- 1/12/2014)

participation of all members

either in person,

either by proxy

Field of operations of the NIREUS Group Internal Audit Department

2015 2014

2015 2014

4 6

18 17

G4-SO8

Meetings Meetings

Meetings Meetings

Year Year

Year Year


The General Financial Department is responsible for monitoring Economic performance. The Group’s main objective is to contin-uously reinforce the economic value of the Group for its shareholders, employees and society through its main operations ofsustainable aquaculture.

Economic performance is essential to establishing the Group’s long-term strategic path, given that it comprises the primarymeans through which it finances its investment plan, it safeguards resources for the welfare of its workforce, it fulfills its obli-gations to various creditors, and maintains its position as a key member in the local communities in which it operates.

The Group’s enhanced economic performance ensures continuous success and therefore significantly contributes to the growth ofthe Greek aquaculture sector and to the national economy, as it is one of the most growing and extroverted sectors nationwide.

Therefore and as a result of all the above, managing this major topic is related to and affects the entire value chain, significantlyimpacting its shareholders, investors, state, suppliers and the wider community.

Why is it material?

Economic Performance

Fattening unit of Kofinas Evia

67

How do we evaluate our approach?Monthly key performance indicators are compared againstthe respective figures of the previous year. Ongoing monthlyassessment of indices in conjunction with corrective planningand remediation actions, when deemed necessary, assist inachieving the desired result and an alignment with thestrategic path from a short and long term perspective.

How do we manage this?The Group has established procedures and has designedKey performance indicators for the purpose of reportingto the Board of Directors, on a monthly basis, its financialperformance. It has, furthermore, established weekly re-porting procedures in view of informing high level man-agement with respect to its trends in revenue, that whichconstitutes its main source of financing.

For more information on the management of economicperformance, please refer to the Annual Financial State-ments for the year 2015, as posted on our company’s web-site [http://www.nireus.com]

DIRECT ECONOMIC VALUE GENERATED AND DISTRIBUTED * (€)

* The Economic value distributed for years 2014 and 2015 includes the Group's results as published per year, adjusted for the following items: losses relating to the impairment ofgoodwill and intangible assets, gains from the measurement of financial liabilities, due to refinancing, impairment loss of the parent company’s investments and subsidiaries, provisionsfor expenses and bad debts, as well as depreciation expense and amortization of grants. Furthermore, the change in the fair value of biological assets at year-end as compared tothe previous year, has been excluded from the calculation.

2014 2015

Direct economic value generated

Economic value distributed

Economic value retained

Revenue

Operating costs

Salaries and employee benefits

Payments to providers of capital

Payments to the state and government agencies

Investments in Society / Donations

"Direct economic value generated“ - "Economic value distributed"

198,347,415

158,198,960

27,625,827

13,605,344

1,555,789

34,042

- 2,672,547

188,283,511

140,127,529

27,005,862

12,981,104

849,091

24,993

7,294,932

G4 EC1


Fish health and welfare is vital for any aquaculture company, both from an ethical as well as from a financial perspective. Themanagement of the issue has major impacts on the first two stages of the value chain, e.g, in relation to fish feed and its culti-vation, as well as in the final stage, being the customer. More specifically, the health and welfare of fish significantly contributesto their high survival, while it is also a key factor for the treatment of a virus or disease. A potential disease which may emergein a fish population and lack of timely treatment through best management practices, can lead to significant financial conse-quences, to the degradation of the entire fish population’s survival, thus reducing the quality of the produced product.

Moreover, it also affects, among others, important parameters in relation to the value chain such as product price, consumers’perception of food quality and hence consumers’ decision to purchase. The results of protecting the health and welfare of fishalso impacts employees, shareholders, investors and the academic community as well as a wider group including social insti-tutions. Actions required to improve this target are to be assumed throughout the entire production chain. Effectiveness also de-pends upon close working relationships with suppliers as well as through the entire research and academic community, in viewof developing innovative technologies, applications and products to ensure and to promote fish health and welfare.

Why is it material?


The overall control and responsibility of ensuring good healthand welfare of fish belongs to the Fish Pathology Department.One of the Group’s main objectives and part of its overall effortis to ensure viable sustainable development by applying bestpractices for the fish health and welfare in the fish population.

The use of technology, continuous staff training, enrichment ofits workforce capacity with specialized scientists / fish pathol-ogists, modernization of equipment both in its basic Group lab-oratory units, as well as in various production sites, formationof special groups designed to improve survival conditions, andmaintain fish health at high levels, have all in total proven asbeing essential in achieving the specific objective.

This specific objective is generally complex and an improvementin the prevailing situation is significantly affected by both ex-ternal factors, environmental and non -environmental in nature,which can be monitored by the Group itself.Actions designed are directed towards influencing both groupsof factors which affect fish health and welfare.

At the same time, fish welfare is now an integral part of theGroup's production operations. As producers, we act as

guardians of the welfare of fish and we are ethically and typi-cally responsible for ensuring a level of care and welfare of thefish that grow in our production operational units.

Measures applied ensure that throughout the process of theirgrowth, all fish under cultivation is not subject to actions thatcreate pain, discomfort and hunger.

Given that aquaculture is a relatively new form of intensive an-imal production which takes place in a marine production area,emerging diseases differ from those that exist in other animalpopulation.

An array of various infectious parameters such as viruses, bac-teria, fungi and various pathogens are generally present amongthe wild fish populations and prevail along the coasts andrivers, usually without any apparent negative impacts. However,when introduced in the production environment of fish farming,the above can cause diseases that can result in a loss of fishpopulation with serious economic consequences. A major chal-lenge entails the prevention, treatment and general handling ofthese diseases.

Fish Health and Welfare

68

69

The occurrence of various fish diseases and the intensity of thephenomenon depends on several factors, such as:▶ presence of pathogens in the environment.▶ stressful and adverse environmental conditions -

improper living conditions.▶ overall nutritional status of the fish.

ResponsibilitiesThe Group has formed special teams of scientists specializedin the prevention and treatment of various diseases in acknowl-edgement of these factors and their impact on the health andwelfare of fish. In conjunction with the above, work groups havebeen developed aiming at reducing the presence of such factorsin the production environment which are responsible for neg-atively impacting the condition of the fish.

These groups are:▶ Individual Dietary Groups under the guidance of

the Nutrition team per production site▶ Group Ichthyopathologists per production site or

per hatchery or farm with the participation of a qualified person in the department of Ichthyopathology

▶ Quality Control Groups (Quality control andquality assurance teams)

▶ Groups consisting of members of the production department of the Group’s operations.

These groups work together and complementary to achievingthe Group's target.

The Fish Pathology Department consists of qualified staff andpossesses a fully equipped laboratory unit in the area of Hili-adou Fokida. The Ichthyopathologists of the Department, whosetarget is the prevention and prompt suppression of various dis-eases that may arise, have been split among the various pro-duction sites of Group Ichthyopathologists. Ichthyopathologistscomprises members and coordinators of the local group Ichthy-opathology. Each regional Ichthyopathology team is appropri-ately equipped for monitoring pathogens - so as to predictoutbreaks, thus being able to avoid or reduce the impacts of apotential disease, by implementing actions as specified in therespective protocols, for managing the issue.

Specific actionsResearch efforts made in fighting various diseases in collaborationwith leading research institutions and through the use of externalassistance and laboratory tests conducted in collaborating re-

search centers and universities such as the University of Sterling,is of vital importance.

PoliciesThe Group's plans also include the design of integrated and imple-mented policies and actions that contribute to good fish health andwelfare such as:

▶ Production and development conditions in locationscarefully selected according to physicochemicaland environmental measurements in isolated coastswith strong currents

▶ Cages with a small number of fish- cages with lowfish stock densities so that fish can freelyswim for optimum health and firm flesh.(2% fish, 98% water)

▶ Growth which is continuously monitored▶ A balanced diet with high-quality raw materials▶ Strict avoidance of all chemical substances, prohibiting

the use of genetically modified raw materials▶ Specific protocols for managing and executing

productive functions adapted to the conditionsof each region optimizing operations and interactions with the wider natural and wild environment

▶ Applying written documentation on best labor practicesand behavior to ensure that farmed species are treated with caution and respect

▶ Continuous measurements of various physicochemicalparameters of the production sea area

▶ Development and use of new technologies in allproduction processes that ensures optimal fish survival

▶ Applied vaccination plan tailored to the diversities and peculiarities of each species produced, arousing and exploiting the mechanisms of each species in view of fighting any possible infection

In the context of prevention planning and under the Ichthyopathol-ogy Department’s supervision, innovative and new vaccines aimedat controlling and limiting incidences of various bacterial and viraldiseases, were utilized.


70Phytoplankton production unit

71

The target continues and remains high for the following years having designed a detailed action plan to improve survival by anadditional 4 percentage points, by 2020.

Targets

How do we evaluate our approach?Despite the fact that our industry is facing wider challenges in rela-tion to fish health and welfare, by evaluating and comparing ourGroup against similar companies in the Mediterranean aquaculturesector as well as with the broader industry of intensive aquaculturelevels worldwide, all measures, rules and protocols applied withinthe Group as well as its final performance results, confirm theGroup’s high level of targets.

Monitoring mechanismsThe NIREUS Group is certified in accordance with the updated 4.0edition of the GLOBAL G.A.P. standard for aquaculture, since 2012,following four years of extensive research, which has resulted inextending, for the first time, the certification to include the aqua-culture industry as well.

ResultsAs a result of all these successive actions, key achievementsin 2015 include the achievement in the improvement of the, al-ready high, survival rate by an additional 2% as compared to2013-2014, as well as a reduction in the percentage of mortal-ities by 16%.

During 2015, pilot and sample tests were carried out with theuse of electricity anesthesia at the sudden death stage of fish.A special plan for introducing new vaccines has been underwayfor the coming years. Results of actions taken in year 2015, willbe recorded in the following year (2016).

The total production of species are farmed in cages at selected sea areas with specific stockingdensities per cage and per farmed species, in order to ensure both the welfare and growth of fish.

G4-FP11

Research & Development Department


The Group's products are classified as basic product commodities, which are sold in markets which do not present particulardifferentiation as compared to similar competitive products. The only manner by which the Group’s competitiveness will be main-tained is to continuously improve its technical efficiency and productivity. The Group’s development and its target to maintain itsleading position in the aquaculture industry requires product expansion, continuous restructuring and redesigning of its productionpractices, development of new products, as well as designing new tools for production.

The fulfilment of our customers' needs is for us a continuous effort, which is reflected not only in the quality of our products butalso in the constant search for development and adoption of new and innovative practices. Our continuous effort for developmentand innovation in products and services provided comprises a prominent feature throughout our operations.

Further information is presented in our website under the section: In service of our Customers.[Http://www.nireus.com/93_1/sthn-uphresia-ton-pelaton-mas]

Therefore, properly managing the issue, has major and positive impacts on all phases of Group's value chain up to its distribution,in addition to significantly impacting the Academic community and our Suppliers.

Why is it material?

How do we manage this?Our Group’ sales commercial department, regularly engageswith its customers and participates in exhibitions held inmajor markets. During such contacts, information on markettrends and consumer needs, is gathered. The continuousprocess of monitoring Mediterranean aquaculture productsaimed at understanding competition and market trends, ismade through a price and quantity observatory system fromthe KONTALI company. At the same time, market trends aremonitored through systematic editions of the EUMOFA service(European Market Observatory for Fisheries and Aquacultureproducts) of DG MARE.

Product expansion so as to include value added products pro-

vided, by the Group to its customers, comprises a need ex-pressed by the markets. Systematic farming of new sea fishspecies requires several years of intense effort and resourceallocation. Systematic research on reproduction and farmingof new Mediterranean species, is mainly carried out by theHellenic Centre for Marine Research (HCMR) and the Univer-sity of Crete. The farming of new species, requires the devel-opment of fish feed used in order to meet their nutritionalneeds and to ensure their health and welfare. Finally, fishfarming technology is evolving with the target of reducingproduction costs in addition to increasing the capacity offarming units in more exposed marine locations.

Research and Development

72

Our valuesThe values that govern our Group are the following:▶ Regular enhancement of innovation.▶ Encouraging innovation, new ideas and

initiatives.

Research and DevelopmentOur Group has developed a Research and Development de-partment, staffed with employees bearing the following mainresponsibilities:▶ Planning priorities and targeting new product development,

improving production activities and adopting / developing new

technologies▶ Creating basic infrastructure for the implementation

of experimental tests▶ Implementing the Genetic Selection Program for main

farmed species▶ Developing collaborations with research centers in Greece

and Abroad▶ Developing partnerships with other production companies for

the joint resolution of production issues and the implementation of research projects

▶ Ensuring possibilities of financing of research projects and experiments from national and European resources.

73

The Group’s Research and Development department has pre-pared a 5-year business plan, which has been approved by theBoard of Directors. It has an annual budget for project implemen-tation and improvement in monitoring costs. It is staffed with therequired level of research experience in critical, for the produc-tion areas, personnel which, depending upon the topic of re-search, is supported by executive employees of the productiondepartment possessing the necessary level of expertise.

For the purpose of implementing research activity, the followinginfrastructure has been developed:▶ One Hatchery in Pyrgoulaki, which is the core (nucleus)

of the Genetic Selection Program for sea bass (Dicentrarchus labrax) and sea bream (Sparus aurata) species, which the Group implements.

▶ One Laboratory Fish Nutrition, which includes a location with basic equipment for materializing nutritional tests in tanks and laboratory areas.

▶ One Farming unit for new species in the location of Deep Vali, in Paleros Village, which specializes in the farming of new species and in the development of relevant production protocols.

For the purpose of meeting its targets, the R&D Department hasdeveloped collaborations with external research bodies, whohave presented research work in matters of interest for develop-ing experiments. For the better assessment of capabilities, exec-utives of the Department participate in scientific conferences heldin Greece and abroad, where they can familiarize themselveswith research projects. Ongoing and several years of collabora-tion exists with the following research institutions:▶ National and Kapodistrian University of Athens▶ National Technical University (Metsovio)▶ University of Thessalias▶ University of Crete▶ HCMR ▶ AKVAFORSK

Further information is presented in the following website page:[Https://www.youtube.com/watch?v=wxJgwDytn3A].

Areas of interest and activities of the Group’s R & D departmentinclude the following:▶ SECTION A: Research programs aimed at improving

available biological material ●Fish Selection Genetics Program. ●Production of New Species. ●Production of Value Added Products. ●Vaccines and anti-parasitic fish protection. ●New technologies and equipment(Through its subsidiary PROTEUS SA).

▶ SECTION B: Research programs for the improvement of nutritional performance

● Development of fish feed with ingredients which are not used in human nutrition.

● Improvement in red porgy feed(Pagrus pagrus - Pagrus major).

● Improvement in meager feed (Argyrosomus regius). ● Improvement in juvenile feed for improved adjustment

in diets developed. ● Development of feed for broodstock. ● Development of seasonal rations.

Collaboration with Academic Institutionsand Research BodiesSignificant research collaboration has begun with HarokopeioUniversity / Department of Nutrition and Dietetics. The projectcomprises the third phase of significant research which hasbeen launched by the Group aiming at developing aquacultureproducts with special nutritional characteristics. This researchactivity, which began in 2012, has an overall budget of € 80,000and was completed at the end of 2013. Project, of a budget €21,000, for residue control and self-test performance on Groupproducts. Assessment of possible impacts on products fromother activities in the sea environment (e.g oil spills).

The program is implemented in collaboration with the Universityof Athens / Analytical Chemistry Laboratory.

For the period 2014-2015, cooperation with the Norwegian re-search center AKVAFORSK Genetics Center AS continued withrespect to genetic selection of sea bream and sea bass. Thevery positive results from the evolution of the genetics selectionprogram have already begun to arise, as presented in theGroup’s productive results.

PROTEUSPROTEUS is a pioneer, providing definitive solutions to the prob-lem of environmental pollution which environment is impactedfrom the widespread use of anti-fouling:

1. Cooperation with the Dutch company MICANTI is focused onresearch aimed at replacing anti-fouling with special THORN-D processing, aiming at providing modern production producerswith low maintenance and cleaning costs.


Our Quality and R & D manager Mr. L. Papacharisis along with the responsible official of Quality Systems Management Ms. S. Bolar

75


Monitoring projects of the R&D department is done throughmonthly reports, in which projects’ development progress is im-mediately presented, as well as any potential issues arising, inaddition to actions needed to be taken. Intermediate results orfinal results, are reported through special reports and internalmemos. In cases of co-financed projects with the national or Eu-ropean funds, official reports are also sent.

In conjunction with the above, and in the context of monitoringthe implementation of the Research & Development BusinessPlan which has been prepared and approved, regular meetingsare held between the Finance and all other departments for dis-cussing the presentation of projects in their progress, evaluatingresults, and resolving issues which may arise. Expected resultsstemming from pilot tests and research projects have been bud-geted in the Group’s 5 year Business Plan.

Performance indicators

Annual expenditure R & D (2015) 898,700€

New products or significantly improved existing products 2

► Renewal of sea bream broodstock ► Introduction of new A’ raw material in feed New Production Process 1 ► Red porgy (pagre) farming in Astakos

Annual expenditure R & D (2014) 683,000€

New products or significantly improved existing products 2

► Renewal sea bass broodstock ► Pilot red porgy(pagre) farming in research production unit New Production Process 1 ► Systematic monitoring of broodstock with the use of ultrasound

Initial tests were successfully completed and the project wastransferred to units with greater demands so that the resultsobtained at the end of 2014 include adverse and demandingproduction processes.

2. The innovative design of the robotic machine of MPI, ROBOTCLEANER, which cleans the nets placed inside the sea waterwhile minimizing any potential damage, simultaneously reduc-ing labor costs, provides a solution in replacement of the useof anti-fouling.

PROTEUS has started testing the stunner equipment testing (an-imal welfare), in collaboration with ACE AQUATEC company,aiming at establishing best practices for harvested fish man-agement. Its use results in sudden death with no further burdenon fish through stress, simultaneously ensuring excellent prod-uct quality delivered to the consumer.


By the term "sustainable fish feed" we refer to fish feed composed of raw materials:▶natural or complex byproducts and side products of vegetable or animal origin products▶are produced under agricultural, livestock and fishing best practices of sustainable agriculture and▶do not affect human interest for nutritional use.

The main raw materials used in fish feed for the purpose of farming sea species are fish meal and fish oil of a high nutritionalvalue which comprise necessary ingredients of fish feed. Catches used for the production of fish feed which are not primarily in-tended for human consumption, are of a high volume production and usually of a short life cycle. These are fished in certainregions around the globe, for most of which, good fisheries policies are presently applied.

Overfishing of fish stocks in recent years has resulted in a reduction of produced fish meal, which in conjunction with con-tinuous fish farming, directs both research and fish feed production, in replacing these two basic raw materials by other vi-able alternatives.

Sustainable fish feed is a major topic, given that sustainability of aquaculture is to a large extent based on raw materials usedfor the production of fish feed (fishmeal and fish oil). Apart from the reduction in supply, several objections and criticisms emerge,such as whether the use of catch could potentially be a ready-to-eat food instead of being used as a raw material for the pro-duction of intermediate support links in the food chain. Furthermore, an important factor to be emphasized, which further impactsthe sustainable development of aquaculture, is the performance indicator of farmed aquaculture fish as a proportion of fish mealand fish oil consumption as a food ingredient, in addition to wild catch used for the production of fishmeal and fish oil. The math-ematical formula of this performance indicator is expressed by the FIFO ratio (Fish in - Fish out), calculated as follow :

FIFO =FFIFF * FCR,FFIFF (Feed Fish Inclusion Factor Of Fish)={Yield of FM in diet(%)+Yield of FO in diet(%) /Yield of FM from wild fish(%)+Yield of FM from wild fish(%)} &FCR (Feed Conversion Rate) = Feed consumption in Kgs/growth of fish in Kgs

It should be noted that the yield of wild catch into fish meal and fish oil are 22.5% and 5% respectively, e.g one kilo of wild catchproduces 225gr of fish meal and 50gr of fish oil.

Sustainable fish feed is a matter of great interest with significant impacts on shareholders, suppliers, customers and NGOs.

Why is it material?


Sustainable TargetOur sustainable target is that each kilo of wild catch to yield an equalor greater amount of farmed fish, namely FIFO≤1.

On a global level, research carried out focuses on the alterna-tive use of raw materials, of plant and animal origin, which willgenerate either equivalent or improved results in terms of fishgrowth, health and quality.

Program on Sustainable Fish Feed Use In order to achieve the above future targets, further to the significantresults already achieved up until today, the Group has designed anddeveloped a program on sustainable use of fish feed.

The sustainable fish feed project’s objective is to adopt newbasic fish feed, and to adapt to animal assets -biopopulation-,and to guide its human resources to its use. The target is to re-place feed ingredients currently used by the Group for Mediter-ranean fish farming with new fish feed. This will be achievedthrough the selection of alternative new ingredients, either al-ready existing, or ingredients expected to be available in thenear future, without these being competitive for the needs ofhuman consumption, simultaneously though meeting the nu-tritional requirements of fish.

Adapting to the new fish feed will result in additional targets

Sustainable Fish Feed

76

77

aimed at ensuring the Group's higher productivity, and improv-ing the individual productive indicators (KPI's). For this reason,a number of individual sample tests of a small or larger scaleare needed and have been designed to reduce risk and to adaptto the specific requirements of Mediterranean aquaculture.

The quality of end products -aquaculture fish- will remain athigh levels as is today, simultaneously informing both end con-sumers, as well as all intermediate links in the value chain, withrespect to the alternative use of sustainable raw materials inthe production of fish feed.

The specific program will be one of the Group projects aimedat the reduction of production costs in the following 5 years.The program is monitored by the Group’s specialized executiveteam, which is the Nutrition Group.

Nutrition groupIn mid-2013, a scientific team was formed, named "NUTRITIONTEAM" which engages in resolving problems in relation to fishdiet aiming at maximizing its performance. In order to maximizethe performance of all parameters and stages in which nutritionis involved, directly or indirectly, the following are taken intoaccount such as:▶ Quality of raw materials▶ Selection Genetics Program▶ Nutritional Diseases and Pathology▶ Feed Fish Management in the Production farming process

The Research and Development group, which designs and im-plements R&D in the fish feed business sector consists of thefollowing:

▶ Quality and R&D Director▶ Group’s Responsible official for fish feed composition▶ Group’s Coordination and Nutrition fattening officer▶ Group’s Ichthyopathology Director▶ Selection Genetics Program Officer

Through scheduled meetings, the nutrition group plans andsupervises the progress of ongoing action plans while plan-ning future actions as well. It does not have an administrativecharacter but it instead operates horizontally in our organi-zational structure.

As a result of these ongoing activities, the Group has beencertified with a number of recognized certifications such as"Certification for Responsible Aquaculture”, “GLOBAL G.A.P”and "ACS."

In parallel, the group manages and participates in Europeanprograms for sustainable fish feed production, improving theproduction results of Mediterranean aquaculture farming prod-ucts. Such programs include the «PERFORMFISH», while it alsofunctions as an active observer of the results and the progressof the «ARRAINA» program.

The main objectives of the sustainable fish feed project , forwhich its achievement is coordinated by this group, are the fol-lowing:

Qualitative and Environmental Targets▶Improvement in the characteristics of the final end

product such as a reduction in flesh fat (<9%), and in the fish belly

▶Coverage of the demands in nutritional requirements for ensuring the daily dose of 250mg EPA + DHA from the consumption of 2-3 servings per week

Environmental TargetsTarget for 2019: Fish In / Fish Out = 1.5

From 2009 and onwards, several experiments have been con-ducted aimed at reducing the use of fishmeal / fish oil and re-placing these with alternative raw materials.

Experiments are divided into three categories according to therange of their scale. Small and medium scale experiments arecarried out on onshore hatcheries, while large-scale experi-ments are undertaken in controlled environmental conditionsmonitoring and recording all Group’s production sea sites.

Other TargetsThe achievement of the project’s objectives affect the entireGroup.

The Group’s future plans includes the development of a productionsea unit - which will operate for the purpose of undertakingmedium-scale experiments. This pilot facility will include twelve(12) floating cages with 7x7 dimensions for nutritional experiments.

It is to be noted that the use of sustainable fish feed is a verycrucial and significant target. There are frequent and regularbriefings from the Nutrition Group to Management Group as re-gards the progress of the entire design, while during themonthly meetings held among the aquaculture production


Blueline 3.5 mm Fish feed

79


ResultsNIREUS Group has, for several years, focused on this significantissue, which also comprises a key target. Through systematicresearch undertaken by both the Nutrition team that has beenformed and which consists of experienced professionals withtechnical know-how in the broader field of aquaculture, andthrough cooperation with various research institutions and uni-versities, the following has been achieved:

▶ reduction in the use of fishmeal from 30%,being the per-centage contributed in the middle of the previous decade, to18%, presenting a decrease of 40%, with a corresponding re-duction in fish oil used from 7.5% to 4%, presenting a de-crease in excess of 46%. These achievements were obtainedfollowing numerous time-consuming experiments and smallsample uses in specific fish population’s biomass, in additionto several improvements in the results of experiments andthe replacement of specific raw materials used for fish feed

with alternative raw materials mainly of plant origin.

▶ improvement in the FIFO ratio at the lowest value limitscharacterizing farming of Mediterranean species. The FIFOratio of the wider Mediterranean aquaculture industry is cur-rently at 1.85% while the corresponding ratio of the NIREUSGroup stands at 1.76%. It is evident that the indicator still de-viates from our ultimate target, however, a detailed businessplan, has been designed, entailing specific steps and accord-ing to which a declining trend in the index is marked, aimingat it reaching sustainable values by early next decade. Theperiod of such a drastic change is small compared to theoverall average production cycle of Mediterranean fishspecies which approximates 16 to 18 months depending uponcertain conditions and parameters.

teams, there are regular briefings on the results of actionstaken. The Nutrition team generally acts as an advisory, sup-portive and research tool for the Group’s production operations.

ResourcesIn order to realize all of the above, the Group has substantiallyinvested in the specific design, with the involvement of, almostpractically, the entire productive workforce in the individual pro-ject’s design, implementation, testing and actions at variouspoints in time.

Furthermore, experiments, laboratory analyzes and tests are beingperformed with the help of research centers and universities such

as HCMR, UNIVERISTY of CRETE UNIVERSITY of Thessalias, whilesynergies with other companies that exclusively specialize in theproduction of fish feed are constantly being developed. We indica-tively note, experiments which were conducted in collaboration withthe company SORGAL and NORDSIMEL.

CollaborationsThroughout the designing and planning phase, the Grouphas direct and close collaboration both with global envi-ronmental organizations (Greenpeace, WWF) as well aswith a wider customer base, for the production of fish prod-ucts of a high biological value, in a sustainable manner.

Performance indicator

FIFO Ratio FIFO Ratio kg of fresh catch used to produce one kilo of Sea Bream or Sea Bass

2014 Fish In / Fish Out = 1.9

2015 Fish In / Fish Out = 1.76


Over the past 35 years, an impressive growth in the productive sector of aquaculture has been marked which has also been wellobserved on a global basis as well, thus promoting Greek aquaculture to a leading and dominant position in the global marketof Mediterranean aquaculture products.

Along with this rapid growth a number of concerns, issues and conflicts among competitive and non-competitive groups, havebeen raised with respect to the industry’s operations and its further development. The initial lack of specific experience in thedesign phase, along with the absence of general and special regional planning frameworks, were ostentimes the basic causesbehind such phenomena.However, by exploiting the competitive advantages mainly of the Hellenic Sea Area, Greek aquaculture has developed along thecoastline, in the sea and on land, paying particular attention to spatial location selection.

As a result, the development of a special spatial coastal design, was imperative to ensure the industry’s further expansion, andcreation of synergies, with multiple benefits occurring on both a local and national level.

By implementing marine spatial planning, the benefits for both the industry and NIREUS Group are particularly significant since:

▶ the necessary space and prerequisites/conditions for viable and sustainable development are specified▶ terms and conditions for further aquaculture growth are included, identifying specific regions and geographical zones

where the industry could develop, and defining specific areas and production capacity per production unit▶ conditions that must be met for obtaining a license for an aquaculture production business, are determined▶ specific characteristics of the production operations, introducing concepts and fallowing areas / zones in accordance

with agricultural fallowing regions, are taken into consideration▶ protection of the aquatic marine space and the wider environment is ensured▶ contributes to the optimization, coexistence and rationalization of relations with other operational activities

and other business sectors and▶ creates conditions for the creation of synergies among companies within the industry so as to encounter matters

in relation to fish health, sustainable development, and creation of economies of scale in the areas of organized development of aquaculture activities.

The above noted positive impacts associated with the proper management of the issue are identified in the cultivation and har-vesting phase of Group's value chain, while Local Communities and authorities are also positively influenced.

Why is it material?


80

Sea Bass ready for harvesting

81

How we evaluate our approach?

Due to the significance of the entire action plan in addition tothe broader dispersion of production units in the Greek territory,monitoring and developing the implementation of a wider spa-tial coastal planning objective assumes the form of a project.The company's management is actively involved in the first levelof communication with institutions and other bodies within theindustry, however it is only the responsible officials of the aqua-

culture units throughout Greece, that monitor and participatein the project’s second level.

Throughout the course of implementing this objective, theGroup cooperates with special consulting firms so as to safe-guard, from both a research and theoretical aspect, the maingoals and objectives of spatial coastal planning.


▶Implementation of methods and integrated management strategies in the coastal zone regions in which the Areas of Organized Development of Aquaculture Activities is located (POAY).

▶Implementation and management of co-financed projects from the European Fisheries Fund and other Community or International Programs in relation to aquaculture, the marine environment, the sale and promotion of aquaculture products, industry’s collective actions and sustainable development of farming regions.

▶Support actions and practices that improve the quality and hygiene of aquaculture products.

▶Studies undertaken in relation to the Group's objectives reporting results to stakeholders.

▶The monitoring of developments in the aquaculture industry at a national, European and international level.

▶Collaboration with local public and private institutions to address aquaculture issues.

▶Cooperation and exchange of experiences with corresponding counterparts of other regions in the country or abroad.

▶Training employees in the industry, for the purpose of advancing their role and their productivity aiming at an Enhancement in the Local Economy.

▶Informing and communicating with units as well as with the public through the issuance of informative material of any form in addition to its realizing or participating in the industry’s promotional events.

Special Management Entities forAreas of organized development ofaquaculture activitiesThe Group, having recognized the necessity of marine spatialplanning has pioneered in the establishment of special man-agement entities for areas of organized development of reg-ulated aquaculture activities, as stipulated by law inaccordance with the specific spatial framework dated4/11/2011.

These special entities have the structural / organizationalstructure and legal form of companies. Their objective is todevelop aquaculture in marine waters of each developmentregion, by applying methods and techniques friendly to the en-vironment. Furthermore, their goal is to improve the compet-itiveness of the industry, to expand production units, improvingthe quality and hygiene of products in addition to having an ex-tensive set of additional goals, as these have been correspond-ingly recorded in the entity’s records of establishment. Weindicatively, mention the following objectives:

Performance indicator

During 2015 the Group participated and supported the establishment of management entities in areas of organized developmentof aquaculture activity in three geographical areas (Echinades, Argolida, Chios), while in 2014 such entities were establishedin two geographic areas (Thesprotia, Amvrakikos).The establishment of entities in other geographical areas (such as Channel Maliakos/ Fokida, Korinthiakos) will proceed during2016-2017

Targets and Objectives


NIREUS Group acknowledges that highly rated companies are judged not only by their financial results or by the quality of their productsand services they provide, but are also judged in terms of their contribution to the social groups with which they interact.

Creating value in local communities, comprises a permanent chapter in the formation the CSR and the strategy of the NIREUS Group andits employees. Managing the issue directly impacts local communities of the regions in which we operate. Furthermore, influences areacknowledged to exist at various stages of the Group’s value chain, such as in the production of fish feed, cultivation and processing.

Why is it material?

How do we manage this?The progress of the Group for 25 years, is characterized by re-sponsible development, with transparency and responsibilitytowards society and stands out for consistency and reliability.For all of us, responsible and consistent policy for society andhumans is a firm commitment.

The economic crisis which has impacted the country in recent

years has resulted in significant changes in the broader busi-ness environment which is adapting to new circumstances.Within this context, the Group proceeded during the past twoyears in enhancing the spirit of volunteerism, apart from theactive support in our country’s cultural, intellectual and sociallife. At the same time and, through concrete actions, solidarityand disinterested programs were implemented.

Creating Value in Local Communities

82

We create value for local communities through:

● product donations and other sponsorships

● employing workers from local communities to a very large extent as a proportion to total Group employees

● selecting suppliers from local communities

● carrying out training activities in our facilities

● maintaining constant and frequent communication with them.

Donations and sponsorshipsThe Group has persistently responded to requests for donationsor sponsorships in cultural and social associations. Our goal isto continue developing initiatives and programs, exhibiting duerespect to fellow men, as well as focusing on quality and pro-tection of the environment.

We primarily reinforce NGOs, Churches, Organizations, Foun-dations, Social Grocery Stores, Sports Associations, CulturalEvents, and Academic Institutions, in practically all our regions,on a systematic or ad hoc basis.

Sponsorships in recent years, mainly relate to product dona-tions. Products donated comprise 90% of non-commercial

species. Regarding sponsored regional infrastructure projects,such as streets, earthworks, reconstruction etc., local commu-nities are also served by a small percentage.

The Director of the hatchery unit in Kanatadika Mr. K. Koukouliampaswith students from EPAL Istieas

83

▶Minimize complaints.▶More systematic cleaning of the sea bed, ports,

coasts in operational regions.▶Gradual segregation and concentration (within 5 years)

of fattening units, in larger demarcated by the State parks so as to reduce the fragmentation of our units, as well as arbitrary nuisance which may be created in enterprises near our activities.

Objectives

How do we evaluate our approach?Evaluating our management approach is mainly per-formed through the General Department of Corporateand Legal Affairs as well through our frequent engage-ment with those participating in our local communities.

Local employmentWith the exception of the headquarters in Koropi, the vastmajority of our staff who are employed in our Group (90-100%) and in our 36 branches (11 regions), come from sur-rounding areas.

Local suppliersAt the same time, one of Group’s supply chain pillars was theinclusion in the supply links, support operations and selectionof suppliers from the local communities.Despite the fact that this policy applies to the entire supplychain, within the context of near shoring philosophy, only localsuppliers have been selected and collaborated with for trans-portation services, thus enhancing our presence in the commu-nities of Astakos, Arta-Preveza-Igoumenitsa, Chios as well asNorth and South Evia.

These areas account for 85% of the NIREUS Group productionsites and for those areas, the selected carriers either dry cargo- transporting feed from our plants in Artakis and Patras- orfresh fish, are based in such regions.

Responsibility for managing this issue lies with the Group’s Cor-porate Social Responsibility Department.

Educational activitiesThe Group meets the demands of elementary schools, highschools, Greek and foreign colleges who wish to visit its facilitiesin the context of training activities in order they familiarize them-selves with aquaculture.

Engagement with local communities▶Sustainable Development ReportUntil today 9 annual Corporate Social Responsibility reportshave been issued, between the period from 2005 to 2013. TheSustainable Development Report issued, comprises a meansof communication, transparency and accountability to ourStakeholders, while creating a responsible management andsustainable development tool for the Group.

▶ FacebookThe electronic page of Nireus Aquaculture S.A, was created inFebruary 2015. Up until June 2016 we had 2,283 followers, whodaily viewed the 2 posts. Approximately 25,510 people, permonth, interact in the page (read posts, show Likes and makecomments), or approximately 850 people per day, mainly fromGreece, as well as from 14 other countries around the globe(indicatively, from Turkey, Germany, America, Italy, Cyprus,England, Australia, Norway and Belgium).

▶ Reception and management of complaints and grievances.Despite the fact that the entity is a low disturbance, there arecertain complaints stemming from local communities whichare mainly related to odors and to occupying sea area, whichare managed by adhering to all specifications and standards,and with immediate remediation actions in collaboration withthe Authorities and the specific social groups expressing com-plaints.

Cleaning the seabed and the coast in the regions of Astakos, by our divers


84

SponsorshipsSponsorships are included in our Group’s Corporate Social Responsibility program and are evaluated based on internal mechanisms.

Products by region kilos Products per activity kilos €

Athens 1,877 Cultural Institutions 2,150 3,400 Charitable Associations

Chios 1,099 Nursing Homes 336 400 Orphanages Hospitals

Astakos 453 Municipalities 653 1,800 Social Grocery Stores Port Authorities Fire Brigade

Evia 394 Sports Events 30 6,055 Sport associations Igoumenitsa 150 Schools 195 1,880 Universities Educational Institutions

Fokida 100 Temples / Metropolises 770 Lefkada 50

Total (products worth of approximately € 12,402 cash + € 13,535) 4,134 25,937

Educational Activities 2014-2015

FEBRUARY 2014 ● Educational visit from the 1st High School in Nea Smirni to the Production Plant in KoropiDECEMBER 2014 ● Students’ visit of EPAL Istieas to the hatchery unit in Kanatadika Evia.More specifically, 30 students of the third grade from the field of Agriculture Food and Environment, along with three professors who guided them to ourunit for the purpose of the course "Animal Production". Students visited all production areas and obtained knowledge with regards to the entire productionprocess performed in a hatchery unit.MARCH 2015 ● Presentation of the aquaculture sector in the VIMA BUSINESS ENTERPRISES made by the MBA department of theAthens University of Economics and Business (A. Grammenos). ● Participation in EU training program for the promotion of Aquaculture(visit by the M. Kotsovou to the 17th School of Piraeus).MAY 2015 ● Visit to the Kindergarten and Elementary School Greek District, in the municipality of Istiaia in the Hatchery unit inKanatadika. SEPTEMBER 2015 ● Visit of the 1st Chios Scout System to the Lagada facilities.NOVEMBER 2015 ● Co-signing of the European Convention for the Young (PACT4YOUTH).

ANNUAL CHILDRENS’ DRAWING CONTESTCHILDRENS’ PAINTING CONTEST 2014 SUBJECT: PAINTING LOVECHILDRENS’ PAINTING CONTEST 2015 SUBJECT: TRIP TO THE WORLD OF THE SEA BED

Specifically for this period we have donated:


85

FEBRUARY 2014 APRIL 2014 JUNE 2014 SEPTEMBER 2014

Voluntary Activities Report 2014-2015

DELIVERY OF FOOD IN THE EARTHQUAKE

REGIONKEFALONIA

EASTER BAZAAR 2014

CLEANING OF THE SEABED

& ASTAKOS COAST

ENHANCEMENT OF ELEMENTARY

ATHENS NURSURIES

OCTOBER 2014 OCTOBER 2014 DECEMBER 2014 MARCH 2015OUR STAFF CLOSE BY TO THE

ASSOCIATIONOF THE PROTECTION

OF THEUNBORN CHILD

"THE HUG" (AGKALIA)

COLLECTION OF ITEMS

FOR THE ORGANIZATIONCHILD & FAMILY

CHRISTMAS BAZAAR

EASTER ACTIONCOLLECTION OF

FOOD "WILL YOU CONTRIBUTE? "

VOLUNTARY BLOOD DONATIONIN KOROPI

APRIL 2015 AUGUST 2015 SEPTEMBER 2015 DECEMBER 2015CLEANING THE SEABED

ASTAKOS PORT PARTICIPATION OF

WORKERS IN CHIOS INTHE 4th SEMI-MARATHON

CONTEST IN CHIOSAS VOLUNTEERS

OFFERING WATER ANDISOTONIC DRINKS

CLEANING THE COASTOF EDIPSO WITH THE

ASSISTANCE OF NIREUS GROUP

PARTICIPATION OFWORKERS

IN THE CONTESTHELLENIC ASSOCIATION

OF WOMEN WITH BREASTCANCER

"ALMA LIFE"

COLLECTION OF ITEMSFOR SYRIAN REFUGEES

IN CHIOS

CHRISTMAS BAZAAR

ENGAGEMENT WITH LOCAL COMMUNIITIES

REGIONS ACTIVITIES GROUP TYPE OF ENGAGEMENT 1 2 3 4 5 6ARGOLIDA • • • • • •ASTAKOS • • • • • •EVIA • • • • • •IGOUMENITSA • • • • • •KOROPI • • • • • •LEFKADA • • • • • •NAFPAKTOS • • • • • •PATRAS • • • • • •FTHIOTIDA • • • • • •CHIOS • • • • • •SPAIN • • • • • •

PERCENTAGE OF ACTIVITIES 100%

TYPES OF ENGAGEMENT:

1. Review of environmental impacts and continuous monitoring.

2. Public disclosure of environmental and social impact assessments.

3. Local community development programs based on local communities’ needs

4. Stakeholder engagement plans based on stakeholder mapping

5. Workers councils, health and safety committees at work and other employee representative bodies to address the impacts.

6. Formal local community management reporting procedures.

G4 SO1


For the purpose of fish feed production in our two plants, specific raw materials standards are used, which have been set by theNutritional Group and the Quality Control department of the Nireus Group.

All purchased raw materials must comply with these standards, given that their quality has a direct impact on the health andgrowth of fish. Furthermore, the diet of our fish which includes fish feed which meet certain standards is taken seriously intoconsideration by our customers (super market chains, restaurants, end consumers), some of which also set this as a prerequisitefor initially cooperating with our Group.

Therefore, improper management of this significant issue negatively affects all stages of fish feed, fish cultivation and our valuechain customers, while significant impacting suppliers and NGOs.

Why is it material?

Raw materials

86Own Produced Fish Feed

87

One of the environmental problems currently being faced aroundthe globe is the overfishing of oceans, a space of which is alsoused for the production of fishmeal and fish oil.

Thus, the reduction of the proportion of fishmeal and fish oil de-rived from wild fish and used for fish feed is among the Group’sobjectives. Out Group correspondingly seeks to increase the pro-portion of raw materials originating from land-based culturesand from products not intended for human consumption.Another objective is to increase the use of fishmeal and fish oilcertified by IFFO RS (Global Standard for the Responsible Supplyof Fish meal and Fish oil).

Targets and Objectives How do we evaluate our approach?During the screening procedures of suppliers, they are pro-vided with a questionnaire to be completed and which includesquestions concerning environmental issues as well as an as-sessment of their own suppliers.

The Group’s Quality control and Procurement Departmentsmonitor global alerts for qualitative issues of raw materials,in order that if a supplier of ours is reported in these, that hebe temporarily removed from the list of desired suppliers anddepending upon the outcome of the alert, that he be either re-activated or not.

How do we manage this?Raw materials procurement policyOur supply of raw materials is made in collaboration with theGroup’s approved suppliers.

When it comes to screening a new supplier, raw material spec-ifications are sent to the potential supplier, from which productsare to be purchased, in accordance with the Quality Control de-partment’s specifications. The supplier then returns back theresults of the requested analysis as well as samples of the rawmaterial to be purchased, which is then tested in our own lab-oratory through basic analyses.

Once the specific raw material has been approved for accept-ance, all remaining certificates required by the Quality Man-agement System (ISO, HACCP, required supporting documentsfor each consignment, etc.) are then requested. Certificates areexamined and if these meet our requirements, the supplier isrecorded on the list of approved suppliers and, if necessary,appropriate inspections of the supplier’s premises are per-formed by a person from our Quality control department.

Concerning procurement procedures and our broader collaborationwith raw materials suppliers, there are procedures in place and cor-responding forms in our Group’s quality system (ISO).

The responsible raw material procurement practices of theGroup are further analyzed as follows:

SocietyThe Group seeks to acquire, as many raw materials as possible,from Greek suppliers, provided that these are available. Fur-thermore, all raw materials used are non- genetically modified(Non-GMO).

EnvironmentCertain raw materials used for the production of fish feed areby-products of food production processes of human consump-tion, which would otherwise end up as waste thus negativelyimpacting the environment.

Indicative Examples:▶The MPC raw material (Concentrated fish protein liquid)

derived from byproducts of salmon filleting.▶From by-products of fish processing including

(e.g tuna, squid) fish meal and fish oil are also produced

PERFORMANCE INDICATORSPercentage of fishmeal derived from fisheries certified as IFFO RS (Responsible Sourcing)

Percentage of fishmeal derived from the processing of fishery products for food production

GREECE

SPAIN

84.8%

Proportion of spending (as a percentage of total annual purchases) to local suppliers, in major locations of our operations

94.1%

28.94% 7.03%

73%

73%

GREECE

SPAIN

73%

73%

2015 2014G4 FP2 G4 EC9


88

GRI G4 CONTENT INDEX & UNGC COP TABLE

GRI Content Index for “In accordance” – Core

G4-32

GENERAL STANDARD DISCLOSURES

General Standard Disclosure Page

STRATEGY AND ANALYSIS G4-1 Statement from a senior decision maker of the organization 4 ORGANIZATIONAL PROFILE G4-3 Name of the organization 16 G4-4 Primary brands, products and services 16, 28-31 G4-5 Location of organization’s headquarters 16 G4-6 Number of countries where the organization operates 16, 36-37 G4-7 Nature of ownership and legal form 16 G4-8 Markets served 16, 28-31, 36-37 G4-9 Scale of the organization 16-17 28-31 G4-10 Workforce by employment type, contract, region and gender 38 G4-11 Percentage of total employees covered by collective bargaining agreements 38 G4-12 Organization’s supply chain 42-43 G4-13 Significant changes occurred during the reporting period regarding the organization’s size, structure, ownership or its supply chain 16-19 G4-14 Precautionary approach or principle 44-45 G4-15 Economic, environmental and social charters, principles, or other third party initiatives 13, 46 G4-16 Memberships of associations and national and international advocacy organizations 46 IDENTIFIED MATERIAL ASPECTS AND BOUNDARIES G4-17 Entities included in the organization’s consolidated financial statements or equivalent documents 16 G4-18 Process for defining the report content and Aspect Boundaries 50-51 G4-19 Material aspects identified in the process for defining report content 50-55 G4-20 Aspect Boundary within the organization 52-55 G4-21 Aspect Boundary outside the organization 52-55 G4-22 Effect of any restatements of information 50-51 G4-23 Significant changes from previous reporting periods in the Scope and Aspect Boundaries 50-51 STAKEHOLDER ENGAGEMENT G4-24 List of stakeholder groups engaged by the organization 47-49 G4-25 Basis for identification and selection of stakeholders with whom to engage 47-49 G4-26 Approach to stakeholder engagement 47-49 G4-27 Key topics and concerns that have been raised through stakeholder engagement 47-49 REPORT PROFILE G4-28 Reporting period 9 G4-29 Date of most recent previous report 9 G4-30 Reporting cycle 9 G4-31 Contact point for questions regarding the report or its contents 9 G4-32 ‘In accordance’ option, GRI Content Index and reference to external assurance 9 G4-33 Organization’s policy and current practice with regard to seeking external assurance for the report 9 GOVERNANCE G4-34 Governance structure of the organization 33 ETHICS AND INTEGRITY G4-56 Values, principles, standards and norms of behaviour such as codes of conduct and codes of ethics 33


89

SPECIFIC STANDARD DISCLOSURES

DMA and Indicators

ECONOMY GRI ASPECT: ECONOMIC PERFORMANCE MATERIALISSUE: "ECONOMIC PERFORMANCE" 66-67 G4-DMA Disclosure on Management Approach G4-EC1 Direct economic value generated and distributed

GRI ASPECT: PROCUREMENT PRACTICES MATERIAL ISSUE: "SUSTAINABLE FISHFEED" & "RAW MATERIALS" 76-79, 86-87 G4-DMA Disclosure on Management Approach G4-EC9 Proportion of spending on local suppliers in significant locations of operation FP2 Products produced in certified areas as a percentage of the total

SOCIETY LABOR PRACTICES AND DECENT WORK GRI ASPECT: OCCUPATIONAL HEALTH AND SAFETY MATERIAL ISSUE: "HEALTH AND SAFETY OF WORKERS” 60-61 G4-DMA Disclosure on Management Approach G4-LA6 Type of injury and rates of injury, occupational diseases, lost days, and absenteeism, and total number of work related fatalities, by region and by gender SOCIETY GRI ASPECT: LOCAL COMMUNITIES MATERIAL ISSUE: "CREATING VALUE IN LOCAL COMMUNITIES “ 82-85 G4-DMA Disclosure on Management Approach G4-SO1 Percentage of operations with implemented local community engagement, impact assessments, and development programs GRI ASPECT: ANTI-CORRUPTION MATERIAL ISSUE: "BUSINESS ETHICS AND INTEGRITY" 62-63 G4-DMA Disclosure on Management Approach G4-SO5 Confirmed incidents of corruption and actions taken GRI ASPECT: COMPLIANCE MATERIAL ISSUE: "REGULATORY COMPLIANCE" 64-65 G4-DMA Disclosure on Management Approach G4-SO8 Monetary value of significant fines and total number of non-monetary sanctions and non-compliance with laws and regulations

Description Page


90

FISH HEALTH AND WELFARE GRI ASPECT: ANIMAL WELFARE MATERIAL ISSUE: "FISH HEALTH AND WELFARE" 68-71 G4-DMA Disclosure on Management Approach FP11 Total produced farmed species RESPONSIBILITY FOR THE PRODUCT GRI ASPECT: CONSUMER HEALTH AND SAFETY MATERIAL ASPECT: " CONSUMER HEALTH AND SAFETY” 58-59 G4-DMA Disclosure on Management Approach G4 PR2 Total number of incidents of non-compliance with regulations and voluntary codes concerning the health and safety impacts of products and services during their life cycle, by type of outcomes FP5 Percentage of production volume manufactured in certified sites

MATERIAL ASPECT NIREUS GROUP: RESEARCH AND DEVELOPMENT 72-75 G4-DMA Disclosure on Management Approach NIREUS GROUP Annual expenditure R & D INDICATOR

MATERIAL ASPECT GROUP NIREUS: MARINE SPATIAL PLANNING 80-81 G4-DMA Disclosure on Management Approach NIREUS GROUP Participation and realization recommendation Package

INDICATOR

SPECIFIC STANDARD DISCLOSURES

DMA and Indicators Description Page


91

UNGC COP TABLE

Principle Description Page

UNGC COP TABLE – PROGRESS REPORT

Principle 1 Businesses should support and respect the 38-39 protection of internationally proclaimed human rights Principle 2 Businesses should ensure they are not complicit in human rights abuses 38-39

Principle 3 Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining 38-39

Principle 4 Businesses should uphold the elimination of all forms of forced or compulsory labour 38-39

Principle 5 Businesses should uphold the effective abolition of child labour 38-39

Principle 6 Businesses should uphold the elimination of discrimination in relation to employment and occupation 38-39

Principle 7 Businesses should support a precautionary approach to environmental challenges 44-45

Principle 8 Businesses should undertake initiatives to promote greater environmental responsibility 44-45

Principle 9 Businesses should encourage the development and diffusion of environmentally friendly technologies 44-45

Principle 10 Businesses should work against corruption in all its forms, including extortion and bribery 62-65


NIREUS Sea Bream with lemon and mashed artichokes


1st km Koropiou - Varis Ave. and Dimokritou19400 Koropi, Greece

Τel.: (+30) 210 66 24 280Fax: (+30) 210 66 26 804

E-mail: [email protected]

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