environmental impact management policy

The Company recognizes that it has a responsibility to the environment beyond legal and regulatory requirements. We recognize that our supply chain, processes, products, and services have both direct and indirect environmental impacts. The Company is committed to reducing our environmental impact and is therefore continually improving our environmental performance as an integral part of our business strategy and operating methods. Our aim is to achieve continuous improvement in our environmental performance. Throughout our operations we regard compliance with the law as the minimum standard to be achieved and will put in place additional environmental programs to go beyond compliance where appropriate.

Environmental Management System

The scope of the Environmental Management System (EMS) of the Company is to provide a systematic way of managing the organization’s environmental affairs. Gives order and consistency for organization to address environmental concerns through the allocation of resources, assignment of responsibility and ongoing evaluation of practices, procedures, and processes. EMS is the aspect of the organization’s overall management quality structure that addresses immediate and long-term impacts of its products, services, and processes on the environment.

In all circumstances and during any contract performance and/or project, the Company is committed to implementing environmental management measures. As a result, all employees and/or partners have a responsibility in their area to ensure that the aims and objectives of the measures set are met.

Environmental Policy

The aim of the Company’s current policy is to regulate resource use or reduce pollution to promote human welfare and/or protect natural systems. Environmental policy is the commitment of our organization to the laws, regulations, and other policy mechanisms concerning environmental issues, it is a written statement, signed by the senior management team based on a proposal from the environmental coordinator – where the following criteria were used to evaluate the significance of environmental impacts:

a. Legal Compliance
b. Consumption figures of the Company (Procurement, recycling, travel)
c. The Company’s performance against a chosen benchmark (electricity consumption, paper consumption)
d. Potential for performance improvement (travel, procurement, electricity consumption, recycling)

As stated below:

Since the establishment of the Company, we have enfolded the concept of quality service and protecting the environment to meet the diverse needs of our clients.

Our commitment is to:

  1. Establish a comprehensive environmental management system and examine environmental issues to prevent pollution and continually improve our system of management.
  1. Conform to all applicable legal requirements and other requirements to which the Company subscribes which relate to its environmental aspects.
  1. Improve the environmental awareness of all our employees/partners/subcontractors through environmental education and awareness-raising activities.
  1. Reduce adverse environmental impacts due to company’s operational activities.
  2. Use resources effectively and encourage closing the loop in product life cycle through recycling and reusing to minimize waste.
Organization Structure & Responsibilities
  • Executive Director (ED)
    The Executive Director is responsible for:
    a. Endorsing the environmental policy
    b. Ensuring appropriate resource allocation to enable the effective operation and continual improvement of the EMS.

  • EMS Internal Committee (Senior Management Team)
    This committee is consisted by the senior management team, and it is responsible for:
    a. The establishment and implementation of the EMS
    b. The establishment and review of objective, targets & other environmental programs
    c. Ensuring the effective implementation of the environmentally related operational controls & programs
    d. The internal communication of environmental matters between management and employees
    e. Promoting environmental awareness among company staff
    f. The review of the complaint records, nonconformity, corrective action and preventive action reports and the adoption of preventive actions as necessary
    g. Providing leadership in the pursuit of environmental issues
    h. Holding regular meeting (at approximately 3-month intervals)
    i. Participating in the EMS Annual Review

  • Environmental Management Coordinator
    The Environmental Management Coordinator is appointed as the representative of EMS Internal Committee (senior management team) and he/she has the responsibility and authority to carry out the daily management of EMS as per below:
    a. Ensuring that EMS requirements are established, implemented, and maintained in accordance with the legal standards and requirements
    b. Ensuring that sufficient resources are allocated for the proper implementation of the environmental policy and the EMS
    c. Regularly reviewing the policy and the effectiveness of the EMS, and ensuring that the necessary changes are made
    d. Leading the EMS Internal Committee to establish and implement the EMS according to legal standards and monitoring the performance of EMS
    e. Coordinating internal EMS audits to ensure the EMS has been properly implemented and maintained
    f. Handling and investigating nonconformity and ensuring corrective and preventive action has been taken to mitigate any impacts caused
    g. Reporting on the performance of the EMS to the EMS Internal Committee for review and as a basis of improvement during the EMS Annual Review
    h. Introduces new employees to the environmental management system of the Company (in line with HR dept.). The participation in training is registered in the training database, which is maintained by the Company’s Human Resources Department.

  • Departmental Managers
    The Departmental Managers are responsible for:
    a. Establishing controls for the identified significant environmental aspects for his/her function team/department according to the procedures and instructions
    b. Ensuring that the EMS is properly implemented and that environmental matters are properly handled at all stages

  • All employees/staff members
    All employees are responsible for:
    a. Working in accordance with the documented environmental procedures and instructions, specific responsibilities defined in individual procedures and instructions
    b. Reporting problems ore deviations associated with environmental issues and the EMS to the EMS Internal Committee.
EMS Annual Review & Agenda

Participants & Roles:

  • Executive Director
    The Executive Director must ensure that an annual review of the EMS takes place and involves all key personnel involved with its implementation (EMS Internal Committee – including Coordinator)

  • EMS Internal Committee (Senior Management Team)
    The EMS Internal Committee must ensure that:
    All relevant information is available for review (as detailed below and as required for the agenda)
    All existing targets and objectives have been completed, and new ones are discussed and agreed for the forthcoming year

  • Environmental Management Coordinator
    The Environmental Management Coordinator must ensure that:
    Organizes the annual environmental review and prepares material for discussions
    After the meeting, the results (minutes of the meeting) are available for all company employees and other interested parties
    New targets are put into the environmental manual and itemized on the site improvement action plan.

The Company’s EMS Annual Review consider and document the following Information from the Environmental Management System:

1. The Environmental Policy
2. The Environmental Objectives
3. The Environmental Targets
4. The site improvement action plan
5. Results from internal evaluation of legal compliance
6. Non-conformance reports
7. The environmental performance of the organization (against previous years)
8. The extent to which the targets and objectives have been met
9. Status of corrective & preventative actions
10. Recommendations for improvement

1. Meeting Minutes including:

  1. Decisions and actions relating to the environmental policy, objectives, targets, and other elements.
  2. Any observations, conclusions, and recommendations
  3. Action Plan of the new targets set
  4. Next EMS Annual Review date.


2. Internal Communication & Human Resources Management

The Company ensures that all internal communication relating to its environmental performance are dealt professionally and effectively. According to that, all communications relating to the EMS may be received in the form of a written letter in electronic format via email.

Communication Procedures
  • Environmental Statement/Manual
    The Environmental Management Coordinator collects all related information (input) about the company’s performance in the previous year, according to the inputs of the EMS Annual Review and he/she then prepares a draft environmental statement/manual for approval by the Executive Director. Once approved, he/she save/publish the document on the intranet.

  • Internal Communication
    For Internal Communication, the Company ensures that all information regarding the EMS such as the policy, objectives, targets, environmental performance, etc. is readily available to all employees on the Company’s intranet. The Environmental Management Coordinator is responsible to ensure that an annual environmental report is written and circulated to all employees. Additionally, the Company follows common types of internal communication to spread important information at any time by using employee newsletter or publications, communication through team collaboration apps (Microsoft teams), emails, company handbooks or guidelines, staff seminars and face to face monthly team meetings.

  • Operational Control
    The Company ensures that all operations and activities, carried out by its employees, partners, or contractors, that are associated with the significant aspects are properly controlled, and that appropriate operational control procedures are communicated to personnel whose tasks may result in significant environmental aspects. The Company influences its employees, partners, or contractors by communicating its environmental policy to them.
Training Personnel

The Company assess the competence of staff, identify the training requirements, and undertakes training for all staff on relevant environmental topics. The procedure includes the induction of all new employees, continual workplace training and any other training that is deemed necessary to ensure knowledge levels are sustained.

The Environmental Management Coordinator in close cooperation and in line with the requirements and guidelines of the Head of Human Resources (member of the EMS Internal Committee) will:
– Ensure that any specific environmental responsibilities are defined within the employee’s job description
– Identify the training needs for all employees – through face-to-face meeting.
– Transfer the information from the meeting onto an environmental training plan
– Ensure that dates are planned to deliver the environmental training
– Repeat this process annually
– Provide new starters with an induction which will cover the environmental arrangements of the business
– Keep records of all persons attending training courses (including induction training) and store them within the company filing system (intranet).

All employees (new or existing) for the Company undergo employee orientation, which includes Company Work policies and practices, Health & Safety training, and training on the Environmental Management System. In case of new employee, the orientation training shall be completed within 10 days of the employee’s start date.
Mandatory training is delivered by subject specialists who are either the Environmental Management Coordinator or another specific employee who is well trained, experienced and designated to pass all related information for company’s EMS. Occasionally, an accredited external trainer is contracted for related to EMS policies, procedures, or environmental prevention seminars.
Training records are maintained for training course conducted as per Training Attendance Form and individually in Employee Training Record and should indicate the following: Type of training, method of training, duration of training, date of completion of training, location of training, name of the instructor or individual who conducted the training.
Personnel evaluations are performed on annual basis as per Training Evaluation Form to assess the effectiveness of training. Employee evaluations shall include goals for continual improvement of the employee’s competency and abilities, as well as their growth within the company, as applicable.
The Head of Human Resources Department is responsible for implementation and management of the above stated procedure.

3. Environmental Activities

In all circumstances and during of any contract performance / project, the Company is committed to implement below environmental pollution prevention practices to reduce the amount of pollution generated by an industrial/consumer process. As a result, all employees and/or partners have a responsibility in their area to ensure that the aims and objectives of the measures set are met.

Energy Consumption
  1. Office Computers & Peripherals
    1.1. Turn off computers and monitors when not in use.
    1.2. Use power management settings determine when the computer and monitor shut off, or go into sleep or
    hibernate modes, which use less power than regular operating mode.
    1.3. Turn off peripherals, such as printers, scanners, speakers, external drives, and gaming systems, when not in use.
    1.4. Use of power strip which can turn off peripherals automatically when we shut off the main device.
    1.5. Use a laptop or tablet instead of a desktop. Laptops typically consume less power than desktops, and
    tablets even less.
    1.6. When buying a new computer, we consider energy efficiency and environmental impact. We check for the Energy Star label to identify devices that are more energy efficient than similar products.
  2. Lighting
    2.1. Use of compact fluorescent lamps (CFLs), and light emitting diodes (LEDs) which have the following advantages: Typically use about 25%-80% less energy than traditional lamps and can last 3-25 times longer.
    2.2. Use of motion-sensor lighting solutions. We light our office spaces only when necessary.
    2.3. Use of automatic office light control system with scheduled on and off timer & brightness adjustment for less energy consumption.
  3. Server Room
    3.1. We determine computational functions / Turn off any unused servers.
    3.2. We increase cooling supply air temperature set point to 25 degrees Celsius (as optimal temperature.)
    3.3. Use cooling systems with economizers.
  4. Cooling/Heating Systems
    Use cooling systems with economizers.
    4.2.Use of automatic office heating control system with scheduled on and off timer & temperature adjustment (according to outside temperature) for less energy
Paper Consumption
  1. Alternatives
    1.1. Only when needed, we use ecofriendly paper which are made entirely from recycled fibers (Replace virgin paper with recycled paper.)
  2. Paperless
    2.1. Use electronic means to communicate (internally & externally).
    2.2. Implemented digital forms & switched to digital reporting (e.g.: e-Invoices)
    2.3. Store files/documents digitally (online or cloud storage)
    2.4. Track the personal printing footprint in the office (there is limitation per person). Also, we strictly print on both sides of the paper.
    2.5. Use projectors and white board for presentations.
  3. Recycling
    3.1. We use separate bins for paper and other waste.
    3.2. Reuse and recycle all paper where possible.
    3.3. Buy recycled and recyclable paper products.
Water Consumption
  1. Indoor Use (Office)
    Install a self-closing nozzle on the wash-down hose, so the water will not run when not needed (Touch free faucets).
    1.2.Reuse reject water or process water from other parts of the facility for mopping, provided this
    complies with health regulations.
  1. Local Transportation
    We encourage (or subsidize) employees to use public transportation and we allow employees to work from home whenever possible (hybrid working hours plan).

  2. Travelling Abroad
    2.1. We minimize business travel through web conferencing – restricting to necessity trips only.
    2.2. When go abroad, we accommodate the needs of transport by walking or using public transport or bicycles.
    2.3. If we must fly, we only book nonstop flights since the 25% amount of a plane’s emissions caused by takeoff and landing.

4. Monitoring and Measurement

The Company shall establish, implement, and maintain procedures to monitor and measure, on a regular basis, the key characteristics of its operations and activities that have significant impacts on the environment.
This shall include procedures for tracking of performance, applicable operational controls and conformity with the company’s objectives and targets, as well as the calibration and maintenance of monitoring equipment. The information on environmental monitoring shall be documented.

Nonconformity & Corrective Action

Continual improvement of the EMS can be achieved by identifying nonconformity, correcting nonconformity, and preventing nonconformity from occurring again. Regarding non-conformity and its subsequent corrective / preventive action, the Company shall establish, implement, and maintain a procedure which defines the responsibilities and authorities to:
– handle and investigate nonconformity
– take action to mitigate the impacts caused
– initiate and complete corrective and preventive actions
– ensure that the corrective or preventive actions taken to eliminate the causes of actual and potential nonconformity are appropriate to the magnitude of problems and commensurate with the environmental impacts encountered
– record the results of corrective and prevention actions taken
– review the effectiveness of corrective action and preventive actions taken
– implement and record any changes in the documented procedures resulting from corrective and preventive action.

5. Recycling Activities

The Company promotes constant recycling not only of paper, plastic and metal but also of:

  • Toner cartridges which contain electrical parts
  • Ink cartridges which contain electrical parts
  • Small electric appliances
  • IT & Telecommunications equipment
  • Lighting equipment

We cooperate with Appliances Recycling S.A., a Collective System for the Alternative Management of Waste Electrical and Electronic Equipment (WEEE), and an organization approved by the Hellenic Recycling Organization. Twice a year we send full bins and we receive a recycle receipt.

Small appliances & IT & Telecommunications equipment recycle bin placed in the ground floor of the Company

Toner cartridges which contain electrical parts & Ink cartridges which contain electrical parts recycle bin placed in the ground floor of the Company

Lighting equipment recycle bin placed in the ground floor of the Company

6. Annual Core Environmental Indicators of the Company (Year 2023)