The Hellenic Post is going through extremely difficult times, having to deal with the total liberalization of the postal market, the intense competition by 530 post services companies licenced by the Hellenic Telecommunications and Post Commission, the reduction of letter mail due to its replacement by electronic mail, the recession in Greece and, finally, various economic adversities that the company is facing.

However, despite all the above problems and no matter how adverse the circumstances may be, the Hellenic Post is the only presence of the Greek state in remote, hard to reach border regions, where it offers Universal Postal Services and Services of General Economic Interest without ever receiving any kind of compensation for them.

Mr Minister,

According to the amendment you proposed, the rights of the Postal Code should no longer belong to the Universal Service Provider. If your proposition becomes a reality, it will take away tools which are vital for the Hellenic Post’s operation and thus lead to its shrinking and destroy all its future prospects.

The above argument is supported by historic facts, as the Hellenic Post has been the only Universal Postal Services Provider in Greece for the last sixty years and therefore the sole responsible for the creation, processing and constant improvement and updating of the Postal Code.

The above tool was first created and is still being developed with the main purpose to support the various productive procedures of the Hellenic Post. This means that the latter has intellectual property rights on the Postal Code.

According to the regulatory framework currently in force, the Hellenic Post grants access to the postal code data base in exchange for a reasonable fee which is necessary for the maintenance, development and updating of the above data base in a way that ensures its functionality.

Undoubtedly, the regulations regarding access to the Postal Code aim at boosting entrepreneurship and the economy in general; at the same time, they recognize the Hellenic Post’s vested rights thereof as well as the fact that it has spent and keeps spending considerable funds for the development of the Postal Code. This framework protects against violations of fundamental principles such as economic freedom and proportionality; without it the maintenance of the Postal Code would be endangered.

We believe that the proposed amendment leaves serious issues unregulated, among which the exact procedure regarding the management and utilization of the Postal Code, the question of who should participate in it and decide on relevant issues such as the method of its creation and processing. These omissions could lead to a plethora of functional problems as well as uncertainty of the legal framework.

Moreover, the following should be taken under advisement:

·         Greece would be the only European country where the Postal Code would not belong to the Universal Services Provider, since it is a fact that currently, all over Europe, the USPs have exclusive rights over the postal codes of their respective countries.

·         It will be impossible to improve speed, reliability and quality of all regular and universal postal services so as to benefit consumers and providers, if the Postal Code is taken away from the organization which created it in the first place. The Hellenic Post has been collecting valuable experience on a daily basis from its activities all over the country, therefore knows best how to maintain, develop and adapt the Postal Code to the ever changing demands of consumers and other providers.

·         The Postal Code is mostly a production tool of the Hellenic Post which brings multiple benefits to the universal services sector as well as the postal market in general. Thus a “mechanistic” approach would prove ineffective.

·         It requires high cost of maintenance and updating.

·         Any changes to the Postal Code would result in great difficulty and delays in the public’s and the companies’ adapting thereof.

·         Any kind of “new model” application cannot possibly be imposed on the market.

In any case, taking this tool away from the Universal Services Provider would lead to reduction of its income and consequently to significant economic loss as well as huge and probably insurmountable problems in the overall Universal Services sector.

In the special meeting of the members of our Federation which took place on August 4 2017, the employees of the Hellenic Post unanimously decided to demand the withdrawal of the amendment on the Postal Code.