Strategy

TITAN

Managing Risks and Opportunities

Compare to Report 2010

Social and political unrest has increased potential risks that may affect TITAN operations either directly or indirectly. Particularly in Greece and Egypt, but also in other countries where risks like bribery and corruption are considered extremely high, continuous monitoring and risk assessment of potential impacts on TITAN is an integrated process related both to financial risk assessment and compliance with TITAN values and its Code of Conduct.

In addition, a Direct Employee Communication Line operates for all employees in Greece and a similar system titled “Ethic Point” is available for employees in the U.S.A., so as to facilitate direct communication of incidents – anonymously if necessary - to senior management. Other mechanisms for reporting grievances are available in all countries, either in the form of a yellow safety box for employee communication with management or in the form of written procedures.

In 2011, a total of 11 cases were reported through this process as non-compliance with the TITAN Group CoC. Five of these cases were reported in the U.S.A., four in Greece and two in Egypt. All cases were fully investigated by independent committees and handled accordingly.

In all relevant communication with employees, contractors and key business associates it is clearly stated that non-compliance with specific standards and principles may cause specific impacts – even a suspension of co-operation.

The risk of corruption is considered in all business units and is one of the topics examined during annual corporate social responsibility assessment at both local and Group levels. In 2011, relevant risks have increased in countries with increased social and political instability, like Egypt. The Transparency International Index shows only minor improvements in other countries where TITAN operates, like F.Y.R. of Macedonia and Serbia. For many years TITAN follows, as a standard practice, a policy aiming at balancing private with public customers, so that the majority of sales in each country are to private customers. Moreover, it continuously examines risk assessments from independent authorities and implements relevant training programs for all managers and employees - particularly in functions that are more exposed to such potential risks - so as to ensure that TITAN standards are fully met.