ATHEXClear Disclosure

In accordance with the requirements of article 26 (7) of Regulation (EU) No 648/2012 of the European Parliament and of the Council of 4th of July 2012 (EMIR) and article 10 of the Commission Delegated Regulation (EU) No 153/2013 of 19 December 2012 supplementing Regulation (EU) No 648/2012, ATHEXCLEAR makes available to the public, information on the governance arrangements, on its rules and regulations, on the eligible collateral and the applicable haircuts as well as a list of all current clearing members, including admission, suspension and exit criteria for clearing membership. 

Governance arrangements


Organizational Structure

ATHEXCLEAR's functional organization combines organizational units of the companies of ATHEX Group and distinct units/governance bodies of ATHEXCLEAR:

  • General Assembly (ATHEXCLEAR)
  • Board of Directors (ATHEXClear)
  • Board Committees

1. Supervisory Committees

  • Audit Committee (ATHEXClear),
  • Risk Committee (ATHEXClear),
  • Committee for the Appointment of Executive, Nomination of BoD Members and Remuneration (ATHEXClear)

2. Executive Committeesς

  • Default & Crisis Management Committee(ATHEXClear)
  • Strategic Investment Committee (ATHEX Group)
  • Clearing Fund Assets Management Committee (ATHEXClear)
  • Information Security Management Committee (ATHEX Group)
  • IT Steering Committee (ATHEX Group)
  • Athens Exchange Steering Committee (ATHEX Group)
  • Legal Affairs Monitoring and Coordination Committee (ATHEX Group)
  • Supervisory units
    • Internal Audit Unit (ATHEXCLEAR)
    • Risk Management & Clearing Division, Risk Management Department (ATHEXCLEAR)
    • Compliance Unit (ATHEXCLEAR)
  • Executive Units
    • Risk Management & Clearing Division, Clearing Department (ATHEXCLEAR)
    • IT Development Division (ATHEX Group)
  • Support Functions
    • Infrastructure Management and IT Support Division (ATHEXCSD)
    • Human Resources & Administrative Support Division (ATHEXCSD)
    • Financial Management Division (ATHEXCSD) 

The schematic illustration of the above, taking into account the administrative hierarchy, the report lines and the role of each organizational unit, is presented below:

ATHEXClear Chart


Remuneration Policy

In order to ensure competitiveness as well as stability and long-term development, ATHEXCLEAR has established, maintains and applies Remuneration Policy, that is complying with its business objectives, without compromising the level of security and maintaining ATHEXClear within standard risk limits.
Specifically, although all remuneration provided by ATHEXCLEAR is fixed, where the company decides to pay variable remuneration, the following rules hold: i) the long-term performance of the ATHEXCLEAR and its employees as well as prospective and existing risks and risk outcomes are taken into account, ii) possible mismatches of performance and risk periods are taken into account, and it is ensured that payments of variable remuneration are deferred as appropriate, iii) as regards the executives of the internal audit, risk management and compliance, variable remuneration does not depend on the business performance of the units they audit, iv) the proportion of fixed and variable remuneration is aligned with risk management, v) non-executive members of the Board of Directors receive only fixed remuneration, under the conditions laid down in ATHEXCLEAR's Articles of Association, in order to avoid conflict of interest.  However, where it is deemed necessary to implement mechanisms to provide incentives when determining their remuneration, these mechanisms should be strictly adapted to the duties of those mentioned above as regards monitoring the implementation and revision of the remuneration policy, and to their personal skills and the results achieved, taking into account the institutional and oversight framework of the EMIR. Where financial instruments are given, proper measures must be taken, such as the time they are held is until the end of their term of office, in order to safeguard impartiality in their use, and vi) the fixed and variable components of total remuneration are balanced and are consistent with risk alignment.
Responsible for the prudent management of the Remuneration Policy is the Board's Nomination and Compensation Committee. The Remuneration Policy is subject to independent auditing on an annual basis. 

Financial Information

You can see key financial information for ATHEXCLEAR in the analytical financial statements of ATHEXCLEAR  here.

Legislation and Regulations of ATHEXCLEAR

Operating Framework

The Regulations on Clearing of Transactions on Derivatives and of Transferable Securities Transactions in Book Entry Form include information on the operating framework of ATHEXCLEAR and its procedures, namely:

  • Default management procedures
  • Rights and obligations of clearing members
  • Description of the risks associated with using the ATHEXCLEAR's services
  • Current clearing services
  • Models used in margin calculations
  • Use of collateral and default fund contributions
  • Admission, suspension and exit criteria for clearing membership

Click here to see the Regulations on Transactions Clearing. 

Pricing Policy

ATHEXCLEAR's Pricing Policy as well as the detailed fees for management and use of transactions clearing systems are posted here.

Business Continuity / Disaster Recovery

The business continuity / disaster recovery plan for ATHEXCLEAR's systems and procedures is a part of the general framework for business continuity / disaster recovery of the Athens Exchange Group's operations.

Business Continuity / Disaster Recovery Procedures

In cases of malfunctioning or failure of the clearing system or other emergencies that may cause difficulties or make it impossible to carry out the obligations of ATHEXCLEAR, ATHEX Group is responsible for:

  • establishing procedures and plans to achieve business continuity / disaster recovery
  • having installed a disaster recovery site synchronized with its primary site with a different geographic profile than that of the main data center
  • performing annually, trials of disaster scenarios in order to familiarize ATHEXCLEAR and market participants (members, data vendors, etc.) with the IT infrastructure and the activation mechanism of the Group's business continuity plan on the disaster recovery site, to the smallest possible time not exceeding two (2) hours.

Group's business continuity plan has been certified in accordance with the International Business Continuity Standard ISO-22301.

Establishment of Crisis Management and Emergency Management Groups

These groups aim to maintain the continuity of the provision of Group's services and consequently ATHEXCLEAR's in the event of an unforeseen event.

Back-up clearing systems

ATHEXCLEAR's clearing and other operations systems are installed and operate at the ATHEX Group's data center. The data center consists of two, independent of the site, the support facilities and the provided technological services, mirror data centers, so that there is redundancy and increased availability re-ensuring the uninterrupted function of ATHEXCLEAR systems.

Business impact analysis

A business impact analysis is conducted annually assessing the risk of disruption of critical operations of ATHEXCLEAR and appropriate measures are taken to mitigate this risk. This risk is monitored on an ongoing basis.

Investment Policy

ATHEXCLEAR has established Investment Policy that concerns the investments of cash (own resources and capital requirements), cash from clearing of derivatives and securities as well as safety margins (guarantees) of members.

Having as priority the security of ATHEXCLEAR funds as well as the collaterals (margins, clearing fund of derivatives and securities), ATHEXCLEAR as CCP invests all above funds only in cash in EUR and strictly at the Bank of Greece.

More information on this policy is provided in the ATHEXCLEAR's Annual Financial Report 2014, which is posted here.

Eligible Margin Collaterals and Haircuts

More information on the risk management parameters for derivatives and securities markets is posted here.

List of Clearing Members

You can see a list of clearing members here.

Policy and Procedure for Complaints Management

ATHEXCLEAR's management and staff respect the right of the persons with whom they deal, to complain about the level of services provided by ATHEXCLEAR.

With the Complaint Management Policy, ATHEXCLEAR ensures that all complaints from the clearing members are recorded and received the appropriate attention, and provision is made for them to be processed / resolved fairly, in a timely, impartial and transparent manner.

The clearing members are treated with dignity, professionalism and fairness during the process of submitting and processing their complaint and, in the event that they are not satisfied with the response given, they are provided with the necessary information and means of communication in order to reach a higher level of hierarchy or a competent body.

The process of complaints management is in compliance with the principles and rules of personal data and confidential information protection.

Any expression of dissatisfaction from clearing members about ATHEXCLEAR's performance (delays, mistakes, etc.) or failure to fulfill its obligations is considered a complaint.

The key steps of complaints submission procedure are the following:
  • The complaint shall be submitted by the person in charge of the Clearing Member (who has the role of "membership issues") or the person in charge for clearing securities or derivatives. It is recommended that the complaint would be submitted through "Service Desk" to ensure that it would be handled in accordance with ATHEXCLEAR's procedures. The description of the complaint should be brief but at the same time sufficiently documented, accurate, containing the necessary information for being easily understood and effectively handled. Also, any accompanying explanatory documents should be attached.
  • The complaint is received, investigated and answered by senior executives of ATHEXCLEAR within a reasonable time. In order to address it more effectively, further information and clarifications may be required. In any case, whether the request is described as a complaint or not, the Clearing Member will receive a documented response.
  • If the Clearing Member is not satisfied with the response, it may request a reexamination of the complaint, after explaining the reasons for the non-satisfaction and submitting any additional information. The process is monitored by the ATHEXCLEAR's Compliance Unit, which operates independently of its other functions. 

ATHEXClear Report on PFMI (PFMI)

ATHEXClear complies with the Principles for Financial Market Infrastructures (PFMI) published by the Committee on Payment and Settlement Systems (CPSS) and the Technical Committee of the International Organization of Securities Commissions (IOSCO) in April 2012. The detailed assesment can be viewed here: ATHEXClear REPORT on PRFMI Principles.

ATHEXClear Public Disclosure of Levels of Protection & Segregation

ATHEXClear publicly disclose the levels of protection and the costs that are connected to  the different levels of segregation which it provides for clearing purposes per System as provided for under Article 39(7)  of Regulation (EU) No 648/2012 and in particular in accordance with the provisions of the Rulebook of System operation "Rulebook for Clearing of Transactions in Transferable Securities in Book Entry Form" and the Rulebook of System operation "Rulebook for Clearing of Transactions in Derivatives", as adopted by the Board of Directors of ATHEXClearand and approved by the Hellenic Capital Market Commission (HCMC).





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