The advantages of franchising schemes, such as reasonable initial capital investments, immediate brand awareness and a clear business-management road map, seem to facilitate the endeavours of entrepreneurs in Greece, particularly those who decided to become entrepreneurs because of the crisis and its impact on the labour market, and those who realised the need to change their business focus and enter new market sectors.
Although the situation in the Greek market remains fluid, with businesses starting up and winding down in short time cycles, franchising arrangements may have a role to play in the country’s return to growth.
II MARKET ENTRY
There are no restrictions on foreign franchisors entering the domestic market. The general principles of free movement of goods, persons, services and capital apply in Greece, as a Member State of the European Union.
Foreign franchisors may establish business entities in Greece under the same terms and conditions as Greek natural or legal persons. Moreover, there are no restrictions against a foreign franchisor entering into a franchise agreement without establishing a subsidiary or a branch office. All newly incorporated companies trading in Greece must be registered with the Greek trade registry.
Foreign natural or legal persons must obtain a Greek tax registration number before acquiring real estate property in Greece. Greek law imposes restrictions on the acquisition of real estate property in Greece only on foreign non-EU citizens, and in so far as the real estate property is located in border areas.
At the time of writing, Greece was still under a capital controls regime.
ii Foreign exchange and tax
In general, there are no exchange control restrictions on the payment of royalties to a foreign franchisor. However, because of (currently still applicable) capital controls, transfers of royalties outside Greece require the authorisation of a special committee of the relevant Greek bank.
Franchise agreements are not regulated in Greece for tax purposes. Bilateral tax treaties for the avoidance of double taxation between the country of the franchisor and Greece usually regulate all issues regarding the payment of royalties, interest, dividends, capital gains, etc.
III INTELLECTUAL PROPERTY
i Brand search
Before applying for trademark registration, one should ensure that it does not conflict with any earlier registered trademark or unregistered rights of third parties.
The relevant search for Greek and international trademarks can be carried out via the TMView database (www.tmview.gr) and searches for European trademarks can be conducted through the European Union Intellectual Property Office database (www.euipo.europa.eu).
ii Brand Protection
Registration and protection of trademark rights is regulated under Law 4072/2012. Unregistered marks are protected under Law 146/1914 on Unfair Competition.
Trademark protection is purely territorial (i.e., a trademark registered in Greece will only be valid within the country). EU trademarks and international trademarks designating Greece or the EU enjoy protection in Greece.
For the registration of a national trademark, an application is filed with the Directorate of Commercial and Industrial Property of the General Secretariat of Commerce (the Greek Trademark Office). E-filing is also available.
After a trademark application is filed, the Trademark Office examiner reviews conformity with the formal requirements set out in Articles 135 and 136 of Law 4072/2012, as well as whether absolute or relevant (earlier rights) grounds of refusal apply. If there are no grounds for refusal, the Trademark Office examiner accepts the application. If grounds for refusal apply, the Trademark Office examiner notifies the applicant, who may: (1) withdraw the application, (2) restrict the scope of protection for the trademark to the extent that it is rendered eligible or (3) submit observations, within one month of the notification. A decision by the Trademark Office examiner rejecting the application can be challenged before the Trademarks Administrative Committee within 60 days.
A trademark application will be refused on relative grounds if it is identical to or confusingly similar to an earlier mark, or if the earlier mark is a famous one and use of the later trademark would take, without due cause, unfair advantage of the distinctive character or the repute of the earlier mark or would damage its distinctive character or reputation, regardless of whether the later trademark is intended to distinguish identical, similar or even different goods or services. The notion of ‘earlier mark’ is defined in Paragraph 2 of Article 124 of Law 4072/2012.
Other earlier intellectual property (IP) rights, such as copyright, can also be considered as relative grounds for refusal.
The decision accepting or refusing registration of the trademark is posted on the website of the General Secretariat of Commerce.
The Trademark Office examiner’s decision accepting the registration of application may be opposed by any third party proving legitimate interest within a three-month period from publication of the decision on the website of the General Secretariat of Commerce.
In accordance with Greek legislation, trademarks can be renewed every 10 years.
Provisions on the enforcement of IP rights and anti-counterfeiting measures are set out in various legal instruments, including the following:
- a Trademarks – Law 4072/2012 (Articles 121 to 183) and amending Law 4155/2013 (Articles 14 to 40) relating to trademarks, trademark prosecution or litigation and anti-counterfeiting protection for all IP rights.
- b Acts of unfair competition – Law 146/14, as amended.
- c Copyright – Law 2121/1993 on Copyright, Related Rights and Cultural Issues, as amended.
- d Patents – Law 1733/1987 on Technology Transfer, Inventions and Technological Innovations, as amended, and Law 3966/2011 (Article 53) on Industrial Property Issues, which transposes, for patents, the EU IP Rights Enforcement Directive (2004/48/EC).
- e Industrial designs – Law 2417/1996 on the implementation of the Hague Convention for the international registration of industrial designs, Law 259/1997 and Law 3966/2011 on Industrial Property Issues.
- f Torts and protection of personality – Articles 57–59 and 914 et seq. of the Greek Civil Code.
- g Border measures – the Greek Customs Code (Law 2960/2001, as amended) and the EU Customs Regulation (608/2013), which is directly applicable.
- h Infringements that also constitute a criminal offence – the Criminal Code and the Code of Criminal Procedure.
Civil disputes related to infringement of trademarks are heard before the civil courts. Remedies include preliminary and definitive injunctions, seizure of assets, pecuniary or non-pecuniary damages. Trademark owners may also initiate or enjoin criminal proceedings over trademark infringement. Disputes related to the registration or cancellation of trademarks are brought before the Greek Trademark Office and the administrative courts.
iv Data protection, cybercrime, social media and e-commerce
Greece transposed the EU Data Protection Directive 95/46/EC via Law 2472/1997 on the Protection of Individuals with regard to the Processing of Personal Data, as amended.
The Hellenic Data Protection Authority (HDPA) is responsible for overseeing the Data Protection Law. The data controller must notify the HDPA in writing about the establishment and operation of a data archive or the commencement of data processing.
Collection and processing of personal data is permitted only when the data subject has given his or her consent. Exceptionally, data may be processed even without this consent, in special circumstances provided by Law 2472/1997. The collection and processing of sensitive data is prohibited. However, exceptionally, the collection and processing of sensitive data, as well as the establishment and operation of the relevant data archive, is permitted by the HDPA, again in special strict circumstances.
The transfer of personal data is permitted for Member States of the European Union and for non-members of the European Union following an authorisation by the HDPA if it deems that the country in question guarantees an adequate level of protection. An authorisation is not required if the European Commission has decided, on the basis of the process of Article 31, Paragraph 2 of Directive 95/46/EC, that the country in question guarantees an adequate level of protection, in the sense of Article 25 of the aforementioned Directive. The transfer of personal data to a non-Member State of the European Union that does not ensure an adequate level of protection is allowed, following authorisation by HDPA, under exceptional conditions, including where the data subject has consented to the transfer and the transfer is necessary to protect the vital interests of the data subject.
The above will apply until 25 May 2018, when the new EU Data Protection Regulation (GDPR) will take effect. The GDPR refers to data controllers and processors within the EU and outside the EU if their processing or monitoring activities refer to EU citizens or data subjects. In certain circumstances, data controllers and processors must designate a data protection officer as part of their accountability obligations to demonstrate compliance.
Data processors must keep a written record of processing activities on behalf of each controller, appoint a representative in certain circumstances and notify the controller if they become aware of a personal data breach.
A data subject’s consent must be freely given, informed, unambiguous and as easy to withdraw as it is to give. Data controllers must provide transparent information to data subjects and notify data breaches to the HDPA. Moreover, a significant change is the removal of the general requirement to notify the HDPA of a controller’s data processing activities and seek approval in specific circumstances. As regards international transfer, the GDPR contains essentially the same provisions as were set out in the previous Directive.
E-commerce is regulated under Presidential Decree (PD) 131/2003, as amended, by virtue of which the EU e-commerce Directive 2000/31/EC was transposed in Greece. As this piece of legislation regulates only partially the commercial relationship between the seller or supplier of goods or services and the purchaser or user, all other aspects of this same commercial relationship are regulated by the provisions of the Greek Civil Code, as well as by the legislation for protection of consumers, manufacturer’s product liability and unfair competition.
IV FRANCHISE LAW
Franchise agreements are neither regulated in Greece by a specific franchise law nor included among the agreements specifically regulated by the Greek Civil Code. Franchise agreements are considered to be sui generis bilateral commercial agreements. This means that parties enjoy wide discretion in structuring their contractual relationships.
In brief and by way of indication, the following legislation applies to franchise agreements:
- a Commission Regulation (EU) No. 330/2010 of 20 April 2010 on the application of Article 101(3) of the Treaty to categories of vertical agreements and concerted practices;
- b Greek Law 3959/2011 (the Greek Competition Act);
- c Law 4072/2012 on Trade Marks;
- d Law 146/1914 on Unfair Competition;
- e Law 1733/1987 on Transfer of Technology, Inventions, Technological Innovations and Establishment of an Atomic Energy Committee;
- f Law 2251/1994 on the Protection of Consumers;
g Law 2121/1993 on Intellectual Property;
h PD 219/1991 on Commercial Agents; and
- i general provisions of the Greek Civil Code.
ii Pre-contractual disclosure
Greek Law does not provide for franchise-specific pre-contractual disclosure requirements.
The general provisions of Articles 197 and 198 of the Greek Civil Code, which set out the obligations arising from negotiations, apply. According to these provisions, during the negotiations phase, the parties must follow certain rules of conduct based on good faith and fair commercial practice. On this basis, the franchisor must disclose to the prospective franchisee the necessary information about the system in question before the conclusion of a franchise contract. Failure to reveal this information may be deemed as conduct in bad faith.
The culpable violation of the above-mentioned obligation by the franchisor may result in an obligation to indemnify the prospective franchisee for the damage incurred, even if the franchise contract has not been concluded (responsibility arising from negotiations or culpa in contrahendo). This compensation will cover only reliance damages.
On the other hand, the Code of Ethics of the Greek Franchise Association (the Code of Ethics) and the case law of the Greek courts provide for specific pre-contractual obligations for the franchisor. Indicatively, the franchisor must disclose to the prospective franchisee crucial information relating to the franchise system, such as details about the franchisor and its corporate status, a general description of the business and the characteristics of the know-how, an estimation of the investment and expenditure to be carried out by the franchisee, and the essential clauses of the franchise agreement (rights and obligations of the parties, duration or termination of the agreement, etc).
The Code of Ethics is a self-regulatory instrument of the Greek Franchise Association, a private body representing the interests of Greek entities involved in franchising. The provisions of the Code of Ethics are compulsory for the members of the Greek Franchise Association, but they are not legally enforceable.
There are no registration requirements for franchise agreements in Greece.
However, to the extent that a franchise agreement includes licensing or transfer of IP rights, the franchise agreement (or a short form licence agreement) will need to be registered with the competent IP authority (the Greek Trademark Office for trademark licences or the Greek Industrial Property Organisation for designs or patent licensing and transfer of know-how; there is a specific Technology Transfer Register maintained by the Greek Industrial Property Organisation, according to Article 21, Paragraph 1, and Article 22 of Law 1733/1987).
iv Mandatory clauses
There are no mandatory clauses in franchise agreements in Greece.
However, according to the general principles of law and the Code of Ethics, a franchise agreement should include all necessary terms regarding the collaboration between the franchisee and the franchisor, namely the rights and obligations of both parties, the licensing of the franchise ‘package’ by the franchisor to the franchisee, analysis of the content of the franchise package, the goods or services to be provided to the franchisee, the terms of payment by the franchisee, the duration and renewal of the franchise agreement, etc.
v Guarantees and protection
Greek law includes no specific guarantees for franchisees or franchisors. Guarantees can be provided, on the basis of contractual freedom, in accordance with general Greek contract law.
Guarantees from individuals and companies to the franchisor or franchisee are enforceable according to the general rules of the Greek Civil Code.
i Franchisor tax liabilities
The general provisions of Greek tax law apply for both the franchisor and the franchisee, since there is no specific tax framework for franchising in Greece.
If the franchisor has a permanent establishment in Greece, the Greek tax authorities will consider the franchisor as a Greek resident for tax purposes. If the franchisor has no permanent establishment in Greece, the relevant tax treaties for the avoidance of double taxation between Greece and the franchisor’s country and specifically the provisions regarding the taxation of royalties will be applicable. In the absence of such a treaty, royalties of intellectual property rights paid to the franchisor will be taxed in Greece with 20 per cent on the gross amount paid by the franchisee to the franchisor. The above-mentioned percentage will be withheld by the franchisee and attributed to the Greek state. This is also a prerequisite for the banks to transfer the royalty payment to the franchisor. After the above-mentioned withholding takes place, the franchisor has no other tax obligation in Greece arising from the franchise agreement.
ii Franchisee tax liabilities
According to Greek tax law, royalties of intellectual property rights paid to the franchisor are deducted from the franchisee’s gross income. When royalties are paid to foreign enterprises, they are deducted from the gross income only on the condition that the franchise agreement is in writing and the relevant withholding tax has been attributed to the Greek state.
iii Tax-efficient structures
To determine a tax-efficient structure for a franchise agreement, the parties should carefully review beforehand all the particulars of the franchise relation, the nature of the business, the tax residence of the parties, the type of goods and services to be provided, etc.
During the past few years, efforts have been made to include franchise systems in the framework of projects eligible for funding by EU structural funds.
VI IMPACT OF GENERAL LAW
i Good faith and guarantees
Article 288 of the Greek Civil Code provides that the contracting parties are required to fulfil their obligations arising from contract, on the basis of the prevalent criteria of ‘good faith’ and ‘fair trade practices’. Good faith is a binding criterion in assessing the conduct of the contracting parties in a franchise agreement.
Moreover, under the Code of Ethics, both the franchisor and the franchisee must act fairly, reasonably and in good faith not only during the term of the franchise agreement but also during the pre-contractual phase (see Section IV.ii) and after the termination of the franchise agreement (see Section VI.vii).
In cases of culpable breach of this good faith, the aggrieved party may be entitled to damages.
ii Agency distributor model
Franchise agreements and agency agreements are conceptually different, as the franchisee acts on its own behalf, bearing the relevant business risk, while the commercial agent negotiates on behalf of the principal or proceeds to transactions on behalf and in the name of the principal.
However, several legal theorists support the analogical application of PD 219/1991 on commercial agents to franchise agreements. According to prevailing opinion, PD 219/1991 applies only where franchisees would be considered as being integrated into the sales organisation of the franchisor. In particular, the following conditions would have to be met for a franchisee to be treated as a commercial agent: (1) the franchisee acts as part of the sales organisation of the franchisor or supplier (being dependent on the franchisor or being integrated into his or her network); (2) the franchisee contributes to the extension of the franchisor’s clientele; (3) the franchisee undertakes a non-compete obligation; (4) the franchisee enjoys a specific protected territory; and (5) the franchisor has knowledge of the franchisee’s clientele and, after termination of the franchise agreement, the franchisee delivers to the franchisor a list of its clientele.
In such cases (analogous application), relevant provisions of PD 219/1991 regarding goodwill compensation on termination of the agreement, the termination notice term and the post-term obligations would also apply to the franchise agreement.
Over the past few years, Greek courts have addressed the above issue and enriched the relevant case law. The conclusion, therefore, is that the question of whether PD 219/1991 applies to a franchise agreement needs to be answered with a case-by-case analysis of the ‘integration’ criteria stipulated above.
iii Employment law
Franchisee and franchisor are regarded as separate, independent business partners. In general, the franchisee acts on its own behalf and not as an agent, representative, or employee of the franchisor. If the franchisee is in control of its business, sells the products in its own name and for its own account, and controls its sale prices and working hours, the chances that it may be considered as an employee are limited.
However, under certain circumstances, the franchisee may be deemed to be the franchisor’s employee; for example, if the franchisee is financially dependent on the franchisor; or the franchisee takes no business risk and makes no (or limited) investment; the franchisee has no employees and the franchisor is its only customer or supplier; or the degree of supervision of the franchisee and its employees by the franchisor goes beyond what is necessary. In such cases, Greek employment law would apply.
iv Consumer protection
Franchisees are very unlikely to be considered as consumers within the framework of a franchise agreement, taking into consideration that pursuant to Article 1(4)(a) of Law 2251/1994 on the Protection of Consumers, a consumer is every physical or legal entity or union of entities without a legal personality who constitute the target group for products or services offered in the market and who use products or services and are their end user.
v Competition law
Franchise agreements are subject to competition law and the rules on restrictive agreements.
Competition in the Greek market is primarily protected by Law 3959/2011 on the Protection of Free Competition, which aims at ensuring effective competition.
According to Article 1, Paragraph 1 of Law 3959/2011, all agreements between undertakings, all decisions by associations of undertakings and concerted practices that have as their object or effect the prevention, restriction or distortion of competition in the Greek territory are prohibited and, in particular, those that:
- a directly or indirectly fix purchase or selling prices or any other trading conditions;
- b limit or control production, markets, technical development or investment;
- c share markets or sources of supply;
- d apply dissimilar conditions to equivalent transactions with other trading parties, thereby impeding competition, in particular by refusing without valid justification, to sell, purchase or conclude any other transaction; or
- e make the conclusion of contracts subject to acceptance by other parties of additional obligations that, by their nature or according to commercial usage, have no connection with the object of the contracts.
The prohibition captures both horizontal and vertical agreements.
As regards vertical agreements, Commission Regulation (EU) No. 330/2010 (the Block Exemption Regulation) and the related Guidelines, apply in Greece, with exclusivity, resale price maintenance, product ties and restriction of passive sales constituting the main points of concern. As for the vertical restraints on the purchase, sale and resale of goods and services within a franchising arrangement, the Block Exemption Regulation applies up to the 30 per cent market share threshold.
vi Restrictive covenants
An obligation not to compete with the franchisor’s business is common in franchise agreements. A non-compete obligation on the goods or services purchased by the franchisee is permitted for the duration of the franchise agreement as long as it is necessary for the protection of know-how and maintenance of the identity and reputation of the franchise network. Generally, such non-compete obligations are compatible with competition law rules for a reasonable period after the termination of the agreement (one year) and as long as the territory that is subject to the post-term non-compete obligation is the same as the territory in which the franchisee operated its business during the term of the agreement.
Resale price restrictions (price-fixing) and restrictions on cross-supply between authorised distributors are prohibited.
The general principles of Greek civil law apply to the termination of franchise agreements.
Termination clauses depend on whether the franchise agreement is entered into for a fixed or an indefinite period. In the first case (fixed term), termination takes place when the agreed term expires or when there is due cause for early termination. In the latter case (indefinite term), the franchise agreement can be terminated at any time. However, the following should be taken into consideration.
If PD 219/91 is applicable, as mentioned above, according to Article 8, Paragaraphs 3 and 4, ‘where a contract is concluded for an indefinite period either party may terminate it by notice. The period of notice shall be one month for the first year of the contract, two months for the second year commenced, three months for the third year commenced, four months for the fourth year commenced, five months for the fifth year commenced and six months for the sixth year commenced and subsequent years. The parties may not agree on shorter periods of notice.’ Moreover, according to Article 8, Paragraph 5 and 6 of PD 219/91, ‘If the parties agree on longer periods than those laid down in Paragraphs 3 and 4 of PD 219/91, the period of notice to be observed by the principal must not be shorter than that to be observed by the commercial agent. Unless otherwise agreed by the parties, the end of the period of notice must coincide with the end of a calendar month.’
If PD 219/91 is not applicable, the time frame for the notice of termination shall be defined on the basis of goodwill, taking also into consideration other criteria such as the duration of the agreement, etc.
Franchise agreements may be immediately terminated, without the application of the above-mentioned periods of notice, if one of the contracting parties fails to comply with all or part of its obligations or in cases of exceptional circumstances.
If PD 219/91 applies, the indemnity clauses mentioned below shall apply in any case (provided that the terms and conditions of the indemnity are met).
According to Article 9 of PD 219/1991, ‘the agent, after termination of the agency contract, shall be entitled to an indemnity if and to the extent that he has brought the principal new customers or has significantly increased the volume of business with existing customers and the principal continues to derive substantial benefits from the business with such customers and the payment of this indemnity is equitable having regard to all the circumstances and, in particular, the commission (profits) lost by the distributor on the business transacted with such customers’.
The grant of goodwill indemnity shall not prevent the franchisee from seeking any damages (actual damages or loss of profits, or both of these) arising as a result of the termination of the franchise agreement. Of particular interest is the contractual provision relating to unsold stock and unamortised investment, in the event of termination of a franchise agreement, whereby the franchisor undertakes the obligation to repurchase the products at an agreed price. The above-mentioned obligation derives from the relevant goodwill obligation of the franchisor. If the franchise agreement is terminated for due cause by the franchisor, the latter is not bound by this obligation. The same applies to unamortised investments.
Covenants not to compete are generally enforceable in Greece (see Section VI.vi), the same applies for post-term confidentiality obligations.
Moreover, in the event of breach of the franchise agreement by the franchisee and termination by the franchisor, a ‘step-in’ right in the franchise agreement (whereby the franchisor may take over the ownership and management of the former franchisee’s franchised business) is recognised by Greek law.
viii Anti-corruption and anti-terrorism regulation
There is no specific, franchising-related legislation on prevention of fraud, anti-corruption and money laundering in Greece.
The main regulatory instrument on fraud (and other fraud-related offences) is the Greek Criminal Code (GCC). Article 386 of the GCC defines fraud as any intentional misrepresentation or concealment of facts to convince a third party to dispose of assets resulting in financial loss, for the purposes of the personal gain of the perpetrator. Moreover, Article 237B of the GCC punishes bribery in business or commercial activities. The basic legal provisions against money laundering and terrorist financing were introduced by Law 3691/2008, which is in line with relevant international conventions and other legal instruments in force. Under Greek Criminal Law, legal entities cannot be held criminally liable. On the other hand, there is no general rule concerning the personal liability of managers, officers and directors for offences relating to a business entity’s activities. The above-mentioned persons may be criminally liable if their actions fall within the actus reus of the relevant criminal provisions. However, for some offences relating to the activities of legal entities, the relevant legal provisions expressly provide for the criminal liability of managers, officers and directors.
ix Dispute resolution
The vast majority of cases in Greece are resolved in court. A smaller fraction of disputes are resolved through arbitration, while the recently introduced method of mediation in commercial disputes is still not common.
The remedies provided by Greek law in the event of violation of the terms of a franchise agreement by either party are:
- a preliminary and definitive injunctions;
- b seizure of assets;
- c disclosure of financial records;
- d pecuniary or non-pecuniary damages; and
- e threat of pecuniary penalties in the event of future violation of the court’s order.
Criminal action may also be initiated in certain circumstances.
As regards the applicable law, Greek courts recognise the choice of foreign law in a franchise agreement in respect of a franchise business operating in Greece. However, certain Greek law provisions may apply, despite the choice of the foreign law. These provisions relate to the protection of Greek public order, and also to competition law, labour law, tax law, data protection law, etc.
Greek Law provides for two different categories of rules, to apply to domestic and international arbitration respectively.
International commercial arbitration proceedings are governed by Law 2735/1999 on International Commercial Arbitration, which incorporates the UNCITRAL Model Law in the Greek legal system. Articles 867 to 903 of the Greek Civil Procedure Code regulate domestic arbitration. The Greek legal framework is supplemented by numerous international conventions, such as the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) (the New York Convention).
In general, parties are free to decide on the procedural rules of the arbitration subject to mandatory rules of the law. An arbitral award is not subject to appeal.
A foreign arbitral award is recognised automatically in Greece, provided that the recognition requirements set out in Article IV, Paragraph 1 of the New York Convention are met and none of the grounds for refusal referred to in Article V of the Convention exists. Awards in domestic arbitration are recognised and enforced in the same way as the decisions of the national courts.
Mediation is not common in Greece. Law 3898/2010, transposing Directive (EC) 2008/52, governs, among other things, confidentiality issues, enforcement of mediation procedures and the professional certification process for mediators.
The board of directors of the Greek Franchise Association encourages the use of a simplified mediation procedure for dispute settlement, which is different from the procedure provided in Law 3898/2010. The mediator is appointed from a list of mediators accredited by the Greek Franchise Association.
VII CURRENT DEVELOPMENTS
Two key characteristics of franchise relationships, namely the ‘transfer’ of brand recognition and business operation methods, seem to fit well with the current situation in the Greek economy.
According to statistics, despite the fact that many small businesses ceased operations as a result of the recession, many others started up on the basis of franchise agreements. Moreover, the pool of entrepreneurs appears to have increased in numbers as a result of unemployment.
Part of this entrepreneurial body seems to be interested in reaping the benefits of franchise deals, which potentially reduce costs associated with creating brand awareness, and with know-how, particularly, during the crucial, initial phase of operations.
1 Nancy G Gerakini is a partner at Prentoulis Gerakini Law Partnership.