This remuneration policy (the “Remuneration Policy”) was established by the Board of Directors of the company “AUTOHELLAS TOURIST AND TRADING SOCIETE ANONYME” (the “Company”) pursuant to articles 110 and 111 of Law 4548/2018 and was approved by the decision dated 18 December 2019 of the Extraordinary General Assembly of the Company’s shareholders.
The members of the Board of Directors and, if any, the General Director and Deputy General Director fall within its scope. For the purposes of this Remuneration Policy, where executive members of the Board of Directors are mentioned, it is understood that also the positions of the General Director and Deputy General Director are included, if any, whether they are members of the Board of Directors or not.
The Board of Directors is responsible for submitting the motion of the Remuneration Policy to the General Assembly and monitoring, reassessing and applying it.
The Remuneration Policy has a duration of four (4) years from the date of its approval by the General Assembly of the Company’s shareholders, i.e. from 18 December 2019.
This Remuneration Policy is available on the Company website at the following url: https://www.autohellas.gr/wp-content/uploads/2019/12/Remuneration-Policy-3.pdf.
2. Basic Principles of the Remuneration Policy.
2.1. The Remuneration Policy aims to align the interests of the Board of Directors members with the long-term interests, the business strategy and the sustainability of the Company.
The establishment of a remuneration framework based on the object, the position responsibilities, the contribution and the performance of Board members, contributes to the attraction and keeping of the appropriate members/executives, as well as the maintenance of an attractive and efficient environment for Board members, thus achieving the maximization of the Company value and the fulfilment of the shareholders’ interests.
2.2. The Board of Directors receives regular information about the elements of remuneration structure and practices followed in the Company and take it in to account when establishing and reassessing the Remuneration Policy, in order to establish the structure of remunerations for different positions. At the same time, it is recognized that the structure of the remuneration of the executive Board members is necessarily different from that of the other employees, due to the responsibilities connected to their role and also due to their impact on the Company performance.
The remuneration of non-executive Board members, due to the nature of their duties, is not comparable to the structure of the remuneration of the executive Board members and other Company employees.
3. Remuneration Policy remuneration categories.
3.1 Executive Board Members.
The total remuneration of the executive Board members dealing with the daily administration of the Company may consist of regular and/or variable, as well as of other remuneration offered voluntarily.
3.1.1 The regular remuneration aims at the creation of a steady basis for the undistracted fulfilment of executive Board member functions and includes their salary or fee, also pursuant to the respective employment and/or service rendering contracts.
3.1.2 The variable remuneration is an annual remuneration to the executive Board members formed based on the individual and/or corporate targets set and depend on the Company’s financial results. This remuneration intends to offer motives to fulfil the role of the executive Board members in establishing and achieving the short-term and long-term goals of the Company, increasing competitiveness and attracting and keeping high-quality executives.
Corporate targets are those relating to financial results in Group level. Individual targets are those relating to the areas of responsibility and the position of each executive Board member.
3.1.3 Other remuneration may be offered according to paragraph 5 of this Remuneration Policy.
3.2 Non- Executive Board Members.
Non- Executive Board Members only receive regular remuneration which reflects their employment duration and their responsibilities as participants of the Board meetings and/or committees.
The variable part of the remuneration does not regard non-executive Board members, in order to avoid conflicts of interests in their decisive and independent, as the case may be, function and in order to not discourage cases of contesting the management on risk-taking matters.
The Company may compensate any reasonable expenses incurred by the non-executive Board members when exercising their duties, such as travel and accommodation expenses for the participation in the Board or Board committees’ meetings, further training expenses in subjects related to their position.
4. Remuneration components of the Remuneration Policy
4.1 Executive Board Members
The regular remuneration received by executive Board members consists of the salary based on any employment contracts and/or their annual remuneration under their capacity as Board members. Its levels are determined by a combination of criteria, such as experience and seniority of the Board member/executive, the role, his/her duties and responsibilities, taking into account those usually applying in the labor market for respective roles in similar-sized companies.
The variable remuneration is connected to the achievement of quantitative and qualitative targets of the Company, set annually, at the beginning of each financial year, mainly the achievement of a certain EBT of the Group. If variable remuneration is paid, this cannot exceed 250% of the regular remuneration of the respective executive Board member.
4.2 Non-Executive Board Members.
Remuneration and eventual compensation of non-executive Board Members are proportionate to their participation in the Board’s meetings and Company committees and are determined by the General Assembly, upon proposal of the Board of Directors.
As indicated above, it is a regular annual remuneration, unaltered by other parameters. The remuneration of each non-executive member for his/her participation in more than one (1) committees of the Board of Directors may not exceed double the amount received for his/her participation in one (1) committee.
5. Other benefits
The other benefits are applicable only for executive Board members (with the exception of the Management Executives liability insurance program which applies also to the non-executive members) and do not constitute part of the variable remuneration of the Remuneration Policy, but are voluntary benefits, which the Company reserves the right to revise or even repeal them completely anytime in the future, at its sole discretion.
The Company offers a complete and organized voluntary benefits program, such as: Company Car, Company Mobile Phone & Mobile Data, Company Computer (Laptop, Tablet), Company Credit Card, Group Life, Accident and Medical Insurance, Retirement Plan.
The Company provides Management Executives liability insurance program to its members of the Board (executive and non-executive).
6. Duration – Termination – Compensations.
The legal provisions are applicable for executive Board members as for the termination of their relationship in their capacity as Board members, in terms of notice and of any payment connected to the termination.
Insofar as persons having a position of executive Board members are at the same time connected with the Company under an employment contract, these are employment contracts of indefinite duration, for the termination of which by the Company the legal deadlines are respected and the legal compensation is paid, as provided for by the legislation in force.
The dismissal of non-executive Board members is made according to the legal provisions and no further remuneration is paid apart from the one due until the dismissal date.
The duration of the Board members’ term (executive and non-executive) is determined in the Company’s Articles of Association.
7. Cases of return of variable remuneration.
Either pursuant to policy or contractual regulations, no variable remuneration return is established for executive Board members.
8. Allowed deviation.
In exceptional cases, the Board of Directors may apply deviations from this Remuneration Policy on regular and/or variable remuneration, provided it is necessary for the long-term fulfilment of the Company interests or securing of its sustainability. In this case, information regarding any deviation from the application of this Remuneration Policy with explanation of the exceptional nature of circumstances and indication of particular elements of the Remuneration Policy, against which the deviation was made, are included in the remuneration report according to article 112 paragraph 2(g) of Law 4548/2018.
9. Content determination – Application monitoring – Reassessment/ Revision of the Remuneration Policy.
The Board of Directors submits the content of the Remuneration Policy for approval to the General Assembly and also monitors and ensures the proper application of the Company Remuneration Policy, examines the remuneration report and suggests the remuneration of its members to the General Assembly, if approved by the latter; the member in question does not participate in the discussion.
Also, it examines any necessary amendments of the Remuneration Policy, if so needed, by offering information with comparative data and the market trends for the categories of Company executives falling within its scope of application. In case there is a need to replace or amend the Remuneration Policy, this is amended and submitted anew for approval to the General Assembly.
For the above purpose, the Board of Directors receives remarks of the Company competent units, including that of Internal Audit, as arising from the audit of the Remuneration Policy application, changes in the regulatory framework, as well as best practices adopted in the market.
Every year, pursuant to the provisions of article 112 of law 4548/2018, an annual remuneration report is established to allocate remuneration paid during the previous financial year, which is submitted to the General Assembly according to the provisions of the aforementioned article.
We are Autohellas Tourist and Trading Societe Anonyme and its subsidiaries operating under the Hertz, Thrifty, Dollar, Firefly and Hertz Operating Lease brands (together “we”, “us”, and “our”). This policy does not cover our affiliates or other third parties through whom you may interact with us. This is a high level summary to explain how we collect, processes, store and otherwise use information about you and your rights in relation to that information. For full information, please see the full policy below.
|SHARING||RETENTION & SECURITY|
|YOUR RIGHTS||QUESTIONS & CHANGES|
We are the Greek Company Autohellas Tourist and Trading Societe Anonyme, official franchisee of Hertz International for Greece and other seven (7) countries in which we are running business activities through our subsidiaries, as shown in the following table. Our activities include between others:
The commercial brands that we use are Hertz, Thrifty, Dollar, Firefly and Hertz Operating Lease (together “we”, “us”, and “our”).
|1||Autohellas Tourist and Trading Societe Anonyme||Greece||GR|
|2||Autotechnica Hellas S.A.||Greece||GR|
|3||Autotechnica (Cyprus) Ltd.||Cyprus||CY|
|5||Autotechnica Fleet Services SRL||Romania||RO|
|6||Autotechnica Serbia DOO||Serbia||RS|
|7||Autotechnica Montenegro DOO||Montenegro||ME|
|9||Autotechnica Fleet Services LLC||Ukraine||UA|
This Policy covers the information we collect about you in connection with the abovementioned business activities, which identifies, or can be used to identify, directly or indirectly, you as an individual (“Personal Data”). It does not apply to information that cannot reasonably identify you. For example, but without limitation, aggregated anonymous data are not Personal Data.
We respect the privacy rights of our customers and are committed to protecting your privacy. This Policy explains our data handling practices with regard to your Personal Data, as well as your rights associated with that data.
We collect Personal Data that you provide during the execution of our services, on our websites, on third-party websites, on applications that we use in order to provide our services, in connection with any inquiries, reservations, rentals or purchases you make in relation to our services. We may collect your Personal Data directly or through our service providers, our subsidiaries, our franchisor, business partners and booking channel providers. For further details, see below:
1.Α. TYPES OF INFORMATION COLLECTED may include, but are not limited to:
We may collect certain Personal Data that constitutes sensitive data in some countries, such as (indicatively but not limited to):
1.Β. METHODS AND SOURCES OF COLLECTION may include, but are not limited to:
Generally, our cookies may perform the following functions:
|Essential cookies||Some cookies are vital to the operation of our websites. Without them you will not be able to navigate in the web site and to use some of its features. The basic cookies allow smooth transition from page to page on the site and are absolutely necessary for its appropriate functioning.|
|Functionality cookies||We do not use functionality cookies and we cannot remember your preferences and selections you have requested in previous visits to our sites.|
|Performance cookies||We use performance cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. These cookies don’t collect information that identifies a visitor. All information collected is aggregated and therefore anonymous and is only used to improve how our website works.|
|Third Party cookies||Third party cookies are set by a different organisation to Hertz. For example, our websites may contain content embedded from, for example, YouTube, and banners delivered for Hertz through an advertising partner’s network. These sites may set their own cookies which are beyond of our control.|
Our websites are not directed to individuals under the age of 13 and we do not knowingly obtain Personal Data from such individuals.
Depending on the purposes for which we collect and use your Personal Data, as set out in this Policy, the Personal Data we collect from you may be required due to a statutory or contractual obligation, or provided by you on a voluntary basis, or necessary for us to enter into a contract with you and provide you with our services. If you do not provide your Personal Data to us we may not be able to provide the requested services (renting, leasing, maintenance, sales etc.).
Below we have set out the various purposes for which we process your Personal Data. We have also set out the legal grounds for the processing of your Personal Data for each purpose:
2.1. OPERATIONS AND SERVICES: We may use your Personal Data to provide you with the services or products you request from us and to perform other activities related to such services or products, including billing and collection following a rental or leasing, or to communicate with you regarding:
Legal grounds: to perform our contract with you or to take steps at your request prior to entering into a contract with you.
2.2. OUR MARKETING: With your consent, we may use your Personal Data to provide you with marketing information, customer satisfaction or services assessment surveys, special offers and promotions via various means, including e-mail and SMS messages, in accordance with applicable law.
Legal grounds: on the basis of your consent. However, where permitted by applicable law we may lawfully use your Personal Data to send you such marketing communications (including via email) for these marketing purposes where necessary for our legitimate interests, which include promoting our products and services, special offers and promotions which may be of interest to you.
You can unsubscribe from receiving such messages at any time by contacting us at the details at Section 6 below as well as by the unsubscribe link in each e-mail message. Please note that if you exercise these choices, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you. Please also note that this unsubscribe process may take some time to complete, consistent with applicable law.
2.3. THIRD PARTY MARKETING: We may also share your Personal Data with a sponsor or other third party that provides you with special offers or promotions that may be of interest to you (“Third Party Provider”) where permitted.
Legal grounds: on the basis of your consent. You may instruct us at any time not to share your Personal Data covered by this Policy with such Third Party Providers where you have previously consented.
2.4. NORMAL COURSE OF BUSINESS: We may also process your Personal Data and other information if such processing is necessary:
2.5. WEBSITES: If you use our websites we may process your Personal Data as follows:
We are not responsible for the information that you or others choose to disclose publicly and such information is not subject to this Policy.
3.Α. THIRD PARTY COMPANIES
We may share your Personal Data with third parties in the following circumstances:
3.Α.1. To provide services to you: We will share your personal data among ourselves, our agents, our licensees and other companies to provide services to you, including among others
3.Α.2. Disclosure to companies you use: We will also share your information with companies you use in connection with your rental, including:
3.Α.3. Protective and legal uses: We may use, share and disclose your personal data for legal reasons as we believe necessary or appropriate, including among others to:
3.Α.4. Disclosure to our service providers and agents: We may use other companies as our service providers or agents to act on our behalf and assist us in the conduct of our business, performing services for us under our instruction. These services may include hosting certain websites or databases, operating “apps” for us on our social media networks’ pages, running contests, sweepstakes and other promotions for us, sending marketing communications, carrying out data analysis and conducting customer satisfaction surveys or other researches. We will always require our service providers and agents to maintain appropriate security standards to protect your personal data and use the personal data we provide to them only for the purposes we specify and according to law.
3.Α.5. Disclosure for corporate transactions: We may disclose your personal data to a third party in connection with any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
3.Β. INTERNATIONAL TRANSFERS
Some of the uses and disclosures mentioned in this Policy may involve the transfer of your Personal Data to various countries around the world that may have different levels of privacy protection than your country of residence or interaction with us, such as when you request rental services to be provided to you in a country outside the European Union (“EU”).
Where our transfer of your data is necessary to provide rental services requested by you, the legal basis for the transfer is the contractual necessity of the transfer, and your Personal Data will be processed by the company providing the services you requested in accordance with applicable local law and the relevant bi-country agreements.
Where we transfer your Personal Data to a third party outside the European Union and no legal basis applies, such as where we transfer the data to a company processing it to our instruction to enable us to provide our services, we will ensure that the required safeguards are in place for the transfer.
4.Α. DATA RETENTION
We retain personal data about our customers for as long as necessary for the purposes for which it was collected, or unless otherwise allowed or required by you or by law. We collect Personal Data for a number of purposes (see above) and may be required to retain it for legal (including tax, civil or other legal regulations) reasons for a period which is longer than the time we need or use the data for the purpose of providing our rental services to you. We maintain a data retention policy to cover all the Personal Data we retain across our systems. If you have any questions about the retention period applying to the Personal Data we collect about you, please contact us (see Section 6).
4.B. SECURITY MEASURES
Information is stored and accessed in various locations, including cloud services. Servers which store information are primarily located in Greece, Europe and the United States, although storage may occur in other locations as well. We use reasonable administrative, technical, personnel, and physical measures (a) to safeguard Personal Data against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of your Personal Data. To help us protect your privacy, you should maintain the secrecy of any logon IDs and passwords, Member numbers, or other identifiers or credentials you may have set up or were provided with in connection with your participation in or use of our products, services, or websites.
As you may be aware, there is no completely secure method of transmitting or storing data. Although their physical characteristics are different, postal mail, telephone calls, text messages, faxes and transmissions over the Internet or wireless networks all present possibilities of loss, misrouting, interception and misuse of the data that is transmitted. If you have reason to believe that any account with us is no longer secure, you must immediately contact us.
We try to strike a balance between the security of your data and your convenience. As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative. For example, but not limitation, we may send you an e-mail or a text message in unencrypted form (i.e. instantly readable) because many of our customers are unable to access encrypted (i.e. coded) e-mail or messages. This means that our message, if misrouted or intercepted, could be read more easily than encrypted messages. Such messages may contain Personal Data. Please do not include confidential information, such as your credit card number or account passwords, in any e-mail or text you send to us or on any posting you make to a public area of a third-party social network page, especially since any such posting immediately becomes public. For a more secure way to communicate with us over the Internet, please click on the “Contact Us” link on any of our websites.
5.Α. You have all the rights according the provisions of the law. Especially, you have the right to request access to, review, and update your Personal Data covered by this Policy, and can request this by contacting us at the details set out in Section 6 below. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws. If you are a member of one of our membership or rewards programs, you may update the information in your member profile by logging into your applicable member profile.
5.B. Among others, you also have the right to:
5.C. In addition, where we process your Personal Data on the basis of your consent, you can withdraw that consent at any time.
You can make a request to us to exercise any of these rights by contacting us as set out in Section 6 below.
6.Α. CONTACT US: We do business in many countries and aim to comply with the privacy laws applicable to the Personal Data we collect and use. Should you have a concern or request about our handling of your Personal Data, you may contact us directly via the methods described below. We will work to respond and resolve your complaints in an expeditious manner. You also have the right to lodge a complaint with a competent data protection supervisory authority in your jurisdiction.
Please contact us by emailing at email@example.com or writing to the address below if you have any questions, wish to exercise your rights of access, or seek other assistance as described above.
General Data Protection Regulation
Autohellas Tourist and Trading Societe Anonyme
31 Viltanioti Str., Kifissia
6.Β. CHANGES: We reserve the right to change this Policy at any time for any reason by posting revisions on this webpage or on applicable apps or other sites. Such changes will be effective upon posting, but will not apply retroactively.