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Aegean Airlines’ disclosures focus extensively on its internal governance framework—highlighting that the Internal Operation Regulation was “revised as per the 14.07.2021 decision of the Board of Directors” to align with “the corporate governance statement and the Corporate Governance Code” and describing an “Internal Audit System … defined as the set of internal control mechanisms and procedures, including risk management, internal control and regulatory compliance.” The company lists robust governance policies such as its “Environmental Policy” and “Risk Management Policy,” yet contains no mention of any process to oversee or align lobbying activities, nor any reference to the oversight of direct or indirect policy engagement or climate lobbying. The disclosures do not identify any individual or formal body responsible for lobbying oversight, and there is no description of mechanisms to ensure that lobbying aligns with Aegean’s corporate or environmental objectives.
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