Recommendation 1 Recommendation 2 Recommendation 3 Recommendation 4

Recommendation 5 Recommendation 6 Recommendation 7 Recommendation 8

Market selection

Recommendation 4

Each market must have clear rules assuring investor protection by safeguarding participants from the financial risks of failed settlement and ensuring that listed companies are required to follow sound policies on corporate governance, transfer of economic benefits and shareholder rights.

1.	Does the depository or the market have securities lending and borrowing schemes in place, and are these open to all market participants and their settlement agents?	Yes, securities borrowing and lending is available to all market participants. B&L is operated as two distinctive REPO styled derivatives products utilizing the Athens Derivatives Clearing House as central counterparty which also administers the lending pool.
2.	Does the settlement system mark fail trades to market and collect margin from the failing counterparty to protect the innocent counterpart's interest?	No, the settlement procedure is accomplished on T+3 settlement day and does not permit failing from any counterpart.
3.	Does the market operate a guarantee fund or have an equivalent procedure to protect against the cost of failed transactions; and which sectors of the market does it cover?	There are two types of funds aiming to securities settlement and investor protection: The Supplement Fund is administrated by CSD through a committee consisting of the CSD's Managing Director, ASE Vice President and the Vice-President of the Brokers Association. It is funded by initial contributions of the ASE members plus a fee based on the value of the transaction collected daily. The current assets of the Supplement Fund are around 80 million Euro. The ASE Members Guarantee Fund is a legal person private entity, administrated by Board of Directors. It is funded by initial contributions of the ASE Members. It's current assets are around 400 million Euro and is frequently reviewed by Capital Market Commission. Additional contributions are based on member trades value. It is activated in case of final and irrevocable ASE member default and the maximum compensation is 30.000 Euro per investor.
4.	Are the stock transfer agents (share registrars) linked electronically to the depository?	CSD acts itself as the stock transfer agent as it has been appointed by law as the register of all securities listed in the Athens Stock Exchange.
5.	Is there a legal maximum time period to complete ownership transfers in the books of the issuer? If so, does market practice adhere to the deadline?	Completion of ownership transfers to the accounts of the investors occurs automatically in DSS as a result of the settlement process.
6.	Are investors entitled to all benefits arising on a security from the point of purchase; and how are any rules enforced?	Investors are entitled to all benefits arising on a security from the point of purchase but they have legal ownership by the time of book entry.
7.	Is proxy voting permissible in the market and can such proxies be lodged by post or other remote delivery method?	Yes, proxy voting is permissible through post only.
8.	Are there binding rules in the market stating the minimum and maximum lapsed time between the announcement and completion of key events, including registration, the calling of shareholder meetings, the payment of dividends or interest, rights issues, tender offers and other voluntary corporate actions?	Yes, corporate act legislation, decisions of the Capital Market Commission Board of Directors and decisions of the Athens Stock Exchange Board of Directors.
9.	Are all voluntary corporate actions advised through a central mechanism assuring consistent information to all investors?	Yes, Athens Stock Exchange gazette and website and the financial and daily press.
10.	Is information on corporate actions available electronically, and is the minimum lapsed time for responding to such actions sufficient to enable all domestic and foreign investors to respond in a timely and considered fashion?	Yes, the information on corporate actions is also available through the Athens Stock Exchange website. Time depends on the action in question, but generally it is sufficient to enable all domestic and foreign investors to respond in a timely and considered fashion. For example, in general meetings shareholders must be notified at least 20 days before the day of the assembly.