Freedom of the Press
Freedom of the Press in Greece
1. The main points of the report
Authors: Vlasis Vlasidis, Ass. Professor of Communication, University of Macedonia
Dr. Athanasios Grammenos, FNF Greece
On April 20, the annual World Press Freedom Index for 2021 was published by Reporters Without Borders (RSF). It is the established annual survey that assesses the freedom enjoyed by journalists in 180 countries, and which includes scores and benchmarks according to a number of criteria. In recent years, as the influence of many governments on the media has affected the quality of information, this research has become particularly important.
This year's report on Greece is very worrying. The country is in 70th place, dropping 5 places compared to 2020. Emphasis is placed on the negative role of the conservative Government of Mitsotakis, as – according to the research – it sought to control the flow of information by offering funding for advertising to many media on the occasion of the COVID-19 pandemic and the refugee crisis. Violence against journalists, photojournalists and TV cress was also mentioned.
This dependence created a new situation in which "journalists had to get the government’s permission before reporting in hospitals, while the Ministry of Health banned medical staff from talking to the media". In February 2021, public TV channels were ordered not to broadcast video circulating on social media that showed the prime minister disregarding lockdown rules and had lunch with a crowd of people in Ikaria.
There are also cases of foreign journalists covering of the refugee crisis in Lesvos and Samos, who were removed by the Police in order not to record the unfolding events. The Greek public TV channel ERT, which according to the report is "controlled by the Prime Minister", censored news about the refugee crisis and the events of the refugee camp in the town of Moria. Reference is also made to the law on demonstrations, which defines special zones for journalists, making their work more difficult. In conclusion, the assassination of Giorgos Karaivaz dominates, ranking Greece among the 5 countries (along with Afghanistan, Bangladesh, Lebanon and Syria) where an information professional has lost his life.
This negative development of press freedom in Greece, as in other countries in the region, did not surprise the experts. Those who are diligently researching this subject have been waiting for it. The research methodology evolves over the years and is based on the recording of all kinds of interventions against the free media (legislation against the press, attacks on media by representatives of the state, political organizations and even citizens, financial situation of the media and independence).
The criteria are the same for all countries. In the data collection assist journalists and correspondents around the world. It should be noted that the "score" records a steady decline in press freedom in Greece, from 2010 onwards with the exception of 2018 – 2020. It is generally coincided with the period of the economic crisis and the implementation of the memorandums.
More specifically, the ranking of Greece from 2007 until today is as follows:
2. Murderous attacks and Yellow Journalism
On April 10, 2021, crime reporter Giorgos Karaivaz, who worked for the Star TV and also ran the www.bloko.gr web page, was murdered outside his home. The culprits shot him 10 times in the chest and head. From the very beginning, the Greek Police spoke of a "contract killing" (1). The assassination occupied both the domestic (2) and international media (3), which linked the assassination with his work, which covered organized crime and corruption. Among other things, it has been said that the journalist was killed so that he could not make any other journalistic revelations.
On July 27, 2020, journalist and publisher Stefanos Chios was shot outside his home, seriously injured but survived (4). Chios is an eccentric persona that started as a TV editor and has grown into a controversial journalist who turns against everyone, especially politicians, the gay community and the business world, inciting the public to revolt against them, through the newspaper Makeleio.
In 2018, after the signing of the Prespa Agreement, he was arrested as he had proposed the execution of the President of the Hellenic Republic Prokopis Pavlopoulos, the Prime Minister Alexis Tsipras and the Minister of Foreign Affairs Nikos Kotzias (5). In April 2020, bailiff Aris Raftopoulos complained that Chios had shot him outside the offices of his newspaper (6). A few months later, the Documento newspaper published photographs of the surveillance cameras showing Chios holding a gun (7). Also in March 2020, an arrest warrant was issued against him for spreading false news about COVID-19 (8).
From the above it appears that Chios is a typical example of a journalist and publisher is involved in the murky waters of populism, the extreme right and the fake news. However, as for the attack against his life, he had stated that he was receiving threats because he was practicing «investigative journalism" (9). At the time of this report, the Greek Police have not yet solved this case.
3. The Acropolis Group
Another journalist and publisher who lost his life was Panagiotis Mavrikos. On June 8, 2016, the Porsche Cayenne that he was driving caught fire while driving on a highway and even hit the dividing wall, as a result of which the doors could not be opened. Mavrikos was burned alive (10). According to the finding of the Greek Police, responsible for his death was the poor repair and maintenance of the car and not a terrorist act (11).
Mavrikos had bought the titles of distinguishednewspapers that had ceased to circulate (Acropolis, 24 Ores, Mesimvrini, Ellinikos Vorras, Athlitiki Imera, Epikairotita). The Acropolis was the most important of his newspapers. During the premiership of Antonis Samaras (2012-2014) he was severely critical of the government from the right, so much so that the heirs of the former owners of the historical newspaper of the Botsis Group had resorted to the courts against him, complaining that he had been turned into a mouthpiece of Chrysi Avgi [Golden Down]. The study of the newspaper indicated that he ranged in the ideological space from the center – right to the extreme right. In March 2015, he founded a party called Dexia-Neo dexio komma, making special reference to patriotic ideals (12) and introduced himself as the "Alexis Tsipras of the Right". The texts of his newspapers adopted the expression and terminology expressed by the area of the popular right and extreme right and their subject matter was typical of right-wing populism.
However, Mavrikos was accused of participating in a criminal organization for financial gain, professional blackmailing and conspiracy, as well as bribery against public organizations, businesses and banks, threatening their executives that if they did not assign him advertising, he would he discredited them through his newspapers (13). Through Greek Publiv TV Channel ERT he had turned against the then President of New Democracy Vangelis Meimarakis (14).
This was not the only case of blackmail reported by publishers and journalists. In 2005, the publisher of the newspaper Eleftheri Ora, which belongs in the area of extreme right (and conspiracy theories) was sentenced to 18 years in prison for blackmailing businessmen (15). It is therefore not uncommon for publishers to be involved in blackmailing cases or to be accused by businessmen of similar action (16).
4. The case of the assassination of Golias
A different case, with a sense of terrorism, is the third assassination of a journalist. Sokratis Golias was murdered at the entrance of his house, in the early hours of July 19, 2010. The terrorist organization "Sect of Revolutionaries" took responsibility. Golias was a low-profile journalist, a member of the team of journalist Makis Triantafyllopoulos, who practiced investigative journalism. He was a communication consultant for the media businessman Dimitris Kontominas and director of the radio station Thema FM. In 2008 he created the blog troktiko.blogspot.com which became very popular in a short time, as it published topics and reports that no other media touched on (issues of illegal enrichment, corruption, business relations with politicians, big debtors of the State, privatization scandals etc.) (17). He also defended Greek track and field and weight lifting champions who turned out to have used banned substances, saying they were anti-Greek conspiracies.
He had broken with the anti-authoritarian and anarchist network Indymedia for the way it covered the arrests of members of the terrorist organization Epanastatikos Agonas (18). As in previous cases, his word was strongly accusatory, with a strong element of populism, without sufficiently substantiating his allegations. His assassination was never solved. His wife, Adamantia, said in an interview in 2014 with the newspaper Proto Thema that Golias had told his brother shortly before his death that he would be killed by the journalist Makis Triantafyllopoulos and that it would look like the Sechta Epanastaton had done so (19).
In all three cases, the relatives and the professional environment of the two dead and one injured cannot pinpoint the perpetrators of the attacks, but attribute them to people affected by the journalists' allegations.
5. Attacks by the State
However, it is not only populist / extreme right journalists and publishers who are at risk in Greece. During the financial crisis, the lives of many journalists and photojournalists were endangered, and some were injured. During the rallies of 17 November 2010 and a few months later, on 28-29 June 2011, many professionals were attacked by the police and injured despite clearly wearing their badges (20). On August 15, 2011, photojournalist Manolis Kypraios was beaten by riot police forces while covering the demonstrations of the strike actions, so much so that he lost his hearing and remains unable to walk (21). Photojournalist Tatiana Bolari (22) was brutally beaten during the same demonstrations. Two more photojournalists, Manolis Lolos and Giannis Liakos, have been hit by riot police in 2012 and 2014 respectively, as they covered anti-government demonstrations. The first was in fact the president of the Union of Greek Photojournalists (EFE) (23). According to the EFE, until the end of 2014 there were 12 attacks against photojournalists, which are documented with photographic material and four more without photographic evidence (24). The most recent is the attack of police officers against the photojournalist Marios Aravantinos, on November 17, 2019 (25). From the above it seems that the police forces have more problems with the TV crews and photojournalists who record footage of their own action, than with the journalists who broadcast information.
But the violence against journalists does not come only from the Greek Police. Extreme right political groups have attacked journalists (26) or organized cyber-attacks against them for covering issues related to immigrants and refugees (27). The area of the non-parliamentary left-wing has a corresponding action, mainly against the media and secondarily against individual journalists. Ways of expression against the work of journalists are the attack and destruction of offices, as in Thessaloniki against the municipal media TV100 and FM100 (28), in Athens against the newspaper Athens Voice (29) and the placement of a powerful bomb on the TV channel SKAI (30).
6. Violence against the media and the Greek society
Already in 2010, a significant portion of citizens accepted the use of force as a legitimate action of reaction and claim (14%) and showed tolerance for the destruction of buildings and shops (31). At the time, groups of citizens who spontaneously protested against the effects of the financial crisis and groups of the extreme right party Chrysi Avgi considered that journalists collectively sided with governments and through television stations and newspapers tried to promote government views against the people. During the years 2010-2015 there were many attacks by citizens against journalists in Athens and the region (32). In 2010, a survey of 635 Greek journalists showed that between September 2009 and September 2010, 17.5% had been physically assaulted in their workplace, while 72.4% had experienced psychological abuse at least once (32).
Attacks on journalists continue even in cases where the reportage is about social rather than political issues. On May 14, 2020, journalist Rena Kouvelioti of Alpha TV was reporting on the beaches of Attica and was attacked with stones, causing her to lose consciousness (33). The next day, May 15, 2020, SKAI TV crew with journalist Panos Garyfalias was attacked by a resident of the settlement of Nea Smyrni in Larissa during a reportage on the effects of COVID-19 (34). Attacks are also recorded against sports journalists even away from sports venues, usually by fans of teams that do not agree with the views they convey (35).
Foreign media journalists are not excluded from the attacks. On 19 January 2020, Deutsche Welle correspondent Tomas Jakobi was attacked and beaten by extreme right groups for trying to take pictures during a demonstration (36). On March 2, 2020, German journalists Julian Bush and Franziska Grillmeier, as well as Belgian Quentin Warlop of Belgian Public Television (RTBF), were attacked by men dressed in black and masked while covering migrants arriving in Lesvos. In the same incident, violence was exercised against the correspondent of Spiegel Online magazine Giorgos Christidis and the freelance photographers Michael Trammer and Raphael Knipping (37).
7. Causes of the media crisis
A recent nationwide poll by KAPA Research on behalf of the Friedrich Naumann Foundation for Freedom (38) well reflects the citizens' crisis of confidence in the media. 67% answered that the Greek media broadcasts false (invalid) news. The degree of freedom of the media was assessed with only 4.09 / 10. Finally, more than 8 in 10 citizens believe that the media is controlled by the government or the political parties. It is a seething cauldron, posing risks to all information professionals without exception.
Therefore, it is not at all easy to be a journalist or photojournalist in Greece. The prevailing view, according to many researchers, is that political parties, businesses, and especially the banks and the media, had created a particular web of relationships and mutual support based on serving their own interests (39). In fact, the participation of the media in this triangle was ensured either directly or indirectly – through state loans – public financing. The amount of loans to the media totals 1,27 billion Euros (40). In this light, it is not surprising that Greeks have a low opinion for the media and Greece is the only country in the world where the public trusts social media more than conventional media (41).
On the other hand, the journalist Giannis Pantelakis considers that a great burden of responsibility lies with those journalists who made discounts in their profession, preferring to indiscriminately adopt the impressive news, "yellowing" and in many cases reproducing fake news (42). However, it should be noted that journalism has lost very important and experienced reporters of the older generation, whose gap has not yet been filled. For example, Aristea Bougatsou and Kostas Efimeros, the first died of cancer in 2013 (43) and the second of heart failure in 2017 (44). Bougatsou had revealed some of the most important scandals in Greece, such as the venality of politicians by Siemens, the bribes for the supply of the C41 of the security system of the 2004 Olympic Games, the telephone interceptions, the Vatopedi scandal and the Lavrentiadis scandal. Efimeros was a member of the International Press Institute (IPI) and had done extensive research on corruption in Greece and media debts (45).
The economic crisis that started in 2010 found unprepared the Greek society, the parties and the media. Many media collapsed financially and unemployment in the industry was huge. The profession of journalist was devalued and the frustrated citizens turned against them. Given the suffocating finances of news companies, many journalists have come under intense and overt pressure, as well as suggestions from media owners not to be an obstacle to their political aspirations or their texts not to have a negative impact on the financial interests of each property. This pressure has led to a peculiar "self-censorship" of journalists which ultimately do not meet the demands of society (46).
This situation was reflected in the RSF reports as mentioned above. Greece has slipped from 30th place in 2007, to 99th in 2014 and 70th this year (2021). It is worth noting that the worst ranking of Greece were recorded in the period 2012-2014 (84-99), during the conservative alliance of New Democracy – PASOK, while freedom of the press marked some improvement in the years of government of the left SYRIZA 2015-2019 ( 91-65). At the time, New Democracy accused SYRIZA of trying to control the media.
Media Associations (Alliance Internationale des Journalistes, Association of European Journalists – AEJ, AMARC Europe, Deutsche Welle Akademie, European Center for Press & Media Freedom – ECPMF, European Federation of Journalists – EFJ, Free Press Unlimited, Global Forum for Media Development – GFMD, IFEX, International Press Institute – IPI, PEN International and RSF) consider that in Greece in 2020 there is no good environment for journalists to practice their profession safely and ask the EU and the Member States to take action to ensure a new framework, to remove all restrictions on information and expression, to bring to justice those responsible for attacks on journalists and action to be taken against false news and hate speech (47). Pauline Adès – Mevel, Head of European Union and Balkan desk at RSF, stated that "the police must receive not only proper training but also a direct order to respect journalists who do their job by covering demonstrations and other events" (48). She also noted that the New Democracy government should make it clear that it will not allow violence against journalists in the future. When it comes to citizens, they should understand that they should not attack journalists because they hinder their work (49).
Prime Minister Kyriakos Mitsotakis has promised to take action against the violence, but the Greek police do not seem to be changing their approach. In November 2020, photojournalist Antonis Rigopoulos was beaten by police while covering a demonstration (50). In February 2021, when the social tensions had started again, a photojournalist was detained on February 6, police violence and beatings on another on February 10, and a chemical attack on a third party on February 26 (51). Incidents of lesser intensity according to photojournalists also occurred in March (52). Foreign journalists were not excluded from the repression either. As mentioned above, in October 2020 a German TV crew was detained by the Lesvos Police Station so not to report on refugees and migrants on the island (53). RSF states that there is a specific government policy against media seeking to cover refugee crisis (54).
At the same time, violence against media people continued by protesting groups of citizens across the country, where protests and disputes are taking place or even without a strong cause. Of course, this does not concern exclusively Greek society as IPI states that during the COVID-19 crisis, 42.3% of violent attacks on journalists in Europe were carried out by citizens who disagreed with the coverage of the situation (55).It is not clear why this is the case; however the financing of the media with 20,000,000 euros by the Government in 1.232 media, in order to contribute to the communication of the pandemic, did not find the public opinion in agreement. Many questioned the motives of this action while the political opposition united, along with civil society organizations, denounced the grant procedures.
IPI, in a letter to Prime Minister Kyriakos Mitsotakis from 15 July 2020, welcomed the government's action but expressed its reservations about the inclusion in the list of 200 digital entities not listed in the Greece's Online Media Register, as some are inactive and others have low traffic. It also expressed its dissatisfaction because the newspaper Documento was excluded from the funding and even with the justification of the government spokesman Stelios Petsas, who claimed that the newspaper (which is close to SYRIZA) is spreading fake news. IPI has the opposite view, characterizing the newspaper as a weekly investigative newspaper (56). However, IPI was not placed for the next financing of the media from the state budget with € 18,500,000. On December 24, 2020, the Minister of Health, Vasilis Kikilias, by his decision provided the media with the above amount to help the government's strategy for the vaccination of the citizens, which would start after a few months (57). This time, the issue of media funding did not receive the same publicity.
From the above considerations it can be concluded that Greece faces a lot in terms of the issue of freedom of journalists and the media. The main problem lies in the control and repression measures taken by any government against the media. One of the first actions of the current government was to bring under the direct control of the Prime Minister's Office the Public Television (ERT), the Athens-Macedonian News Agency (AMNA) and the Greek Intelligence Service (NIS – EYP), and later the General Secretariat of Information and Communication responsible for media supervision. This is an option that does not contribute to media independence (58). On the day this decision was published, the Prime Minister violated the health protection measures in Ikaria and an announcement was posted in ERT's workplaces that read:
"To colleagues Public Producers. We do not play photo, nor video of K. Mitsotakis from the veranda of the house of Stefanadis (lunch) in Ikaria. We also only play footage of Lignadis, not of others".
The COVID-19 health crisis has greatly reduced the political and social conflicts and changed the agenda (agenda setting), but the problems in the media and the safety of journalists remain. The state of emergency that developed on the political agenda and lasted as long as the first wave of the pandemic contributed to this. At that time, the government, the political parties, the media and the society were mobilized for the common goal of dealing with the pandemic. It was an expression of the rally round the flag effect.
But when the second wave broke out, the government tried to take advantage of the consensus on the health crisis. The result was to provoke political and social reactions. The media continued to cover the news and, depending on their political position, to convey the relevant images to their audience. But citizens feel that the media, not only public but also private, have sided with the government not only to deal with the health crisis, but to promote its overall policy.
On the other hand, the RSF report comes at a crunch time to note what other international organizations have expressed earlier: concerns about the treatment of journalists by the Greek Police, restrictions on coverage of the immigration issue and direct or indirect effort of the Greek government to control the flow of information for political gain. In conclusion, 2020 was not a good year for freedom of speech and the exercise of the journalistic profession in Greece.
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 Polymenopoulou, Report, p.21-22.
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 Larissa: attack with fists and bottles on SKAI journalist, Lifo, 15.05.2020 at https://www.lifo.gr/now/media/282512/larisa-epithesi-me-grothies-kai-mp...
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Stephen Gray, Dina Kyriakidou, Special Report: Greece's triangle of power, Reuters Special Reports, 17.12.2012, at https://www.reuters.com/article/us-greece-media/special-report-greeces-triangle-of-power-idUSBRE8BG0CF20121217. Stylianos Papathanassopoulos, “Greece: Press Subsidies in Turmoil” in PC Murschetz (ed.), State Aid for Newspapers, Media Business and Innovation; Theories, Cases, Actions, New York: Springer, 2013, p. 240-242. P. Iosifidis, D. Boucas, (2015). Media policy and independent journalism in Greece. London: Open Society, Foundations, p. 14-16. Retrieved from https://goo.gl/Vvyvvx.
 Tasos Morfis, Five (simple) reasons why Greece urgently needs more #PressFreedom, Athens Live 03.03.2017 at https://medium.com/athenslivegr/five-simple-reasons-why-greece-needs-urgently-more-pressfreedom-58d91ceaf4cb.
 Nic Newman with Richard Fletcher, Antonis Kalogeropoulos, David AL Levy and Rasmus Kleis Nielsen, Digital News Report 2017, Reuters Institute-University of Oxford, 2017, p.73.
 See Giannis Pantelakis, The lost value of journalism, 20 + 1 stories of yellow journalism, Athens, Themelio, 2018.
 Aristea Bougatsou: the bravest and most irreconcilable reporter of Greece is no longer here, iefimerida.gr 11.02.2013, at https://www.iefimerida.gr/news/90131/%CE%B1%CF%81%CE%B9%CF%83%CF%84%CE%AD%CE%B1-%CE%BC%CF%80%CE%BF%CF%85%CE%B3%CE%AC%CF%84%CF%83%CE%BF%CF%85-%CE%B7-%CF%80%CE%B9%CE%BF-%CE%B3%CE%B5%CE%BD%CE%BD%CE%B1%CE%AF%CE%B1-%CE%BA%CE%B1%CE%B9-%CE%B1%CF%83%CF%85%CE%BC%CE%B2%CE%AF%CE%B2%CE%B1%CF%83%CF%84%CE%B7-%CF%81%CE%B5%CF%80%CF%8C%CF%81%CF%84%CE%B5%CF%81-%CF%84%CE%B7%CF%82-%CE%B5%CE%BB%CE%BB%CE%AC%CE%B4%CE%B1%CF%82-%CE%B4%CE%B5%CE%BD-%CE%B5%CE%AF%CE%BD%CE%B1%CE%B9-%CF%80%CE%B9%CE%B1-%CE%B5%CE%B4%CF%8E. Niki Mariam Onti, Eleftherotypia's Bougatsou Dies at 49, Greek Reporter 10.02.2013, at https://greece.greekreporter.com/2013/02/10/eleftherotypias-bougatsou-dies-at-49/.
 Trailblazing Greek journalist Costas Efimeros dies at 42, The Press Project, 12.08.2017, στο https://thepressproject.gr/trailblazing-greek-journalist-costas-efimeros-dies-at-42/.
 What the media owe, The Press project, 06.03.2011, at https://thepressproject.gr/ti-chrostane-ta-mme/. The debts of the channels to the banks, The Press project, 17.10.2015, at https://thepressproject.gr/ta-xrei-ton-kanalion-pros-tis-trapezes/. Media debts to Insurance Fund of Media Staff (ETAP-MME), The Press Project, 02.09.2012, at https://thepressproject.gr/101-ekat-euro-xrei-sto-tameio-ton-mme/.
 Sofia Iordanidou, Emmanouil Takas, Leonidas Vatikiotis and Pedro García, Constructing Silence: “Processes of Journalistic (Self-) Censorship during Memoranda in Greece, Cyprus, and Spain”, Media and Communication, 8/1 (2020), 15-26, DOI: 10.17645/mac.v8i1.2634. Eugenia Siapera, Lambrini Papadopoulou, Fragiskos Archontakis, Post crisis Journalism. Critique and Renewal in Greek Journalism, Journalism Studies, 16/3 (2015), 449-465.
 EU and Member States must create safe environment for journalists reporting in Greece, IPI Signs Joint Statement, 05.03.2020 at https://ipi.media/eu-and-member-states-must-create-safe-environment-for-journalists-reporting-in-greece/.
 Greek police must be trained to respect journalists, RSF says, RSF, 26.11.2019, at https://rsf.org/en/news/greek-police-must-be-trained-respect-journalist....
 RSF, Reporters in Greece must be protected from attack by anti-migrant residents, 04.03.2020 at https://rsf.org/en/news/reporters-greece-must-be-protected-attack-anti-migrant-residents.
 Podcast - Spotlight: The journalist who was beaten by the Police describes the orgy of repression, Documentonews, 17/11/2020 at https://www.documentonews.gr/article/podcast-spotlight-o-dhmosiografos-poy-xtyphthhke-apo-thn-astynomia-perigrafei-to-orgio-katastolhs/.
 Dimitris Manolaros, Third attack on photojournalists within a month, at https://www.photocontest.gr/articles/triti-epithesi-se-fotoreporter-mesa-se-enan-mina.
 Photojournalist attacked in today's demonstration for Koufontinas, 6.3.2021 at https://twitter.com/bikosmariosraf/status/1368154239835471873?ref_src=twsrc%5Etfw%7Ctwcamp%5Etweetembed%7Ctwterm%5E1368154239835471873%7Ctwgr%5E%7Ctwcon%5Es1_&ref_url=https%3A%2F%2Fwww.enallaktikos.gr%2FArticle%2F59026%2Fh-nea-epithesh-twn-mat-kai-o-xylodarmos-toy-fwtoreporter-shmera--kanei-to-gyro-toy-diadiktyoy-binteo
 Greek police uses brutal violence and arbitrary bans to obstruct reporting on the refugee crisis, RSF, 17.9.2020 at https://rsf.org/en/news/greek-police-uses-brutal-violence-and-arbitrary-bans-obstruct-reporting-refugee-crisis.
 Verbal or physical Attacks Against Journalists Covering Covid-19, https://ipi.media/covid19-media-freedom-monitoring/.
 Greece urged to ensure fair and transparent media support scheme, International Press Institute, 15.07.2020 at https://ipi.media/greece-urged-to-ensure-fair-and-transparent-media-support-scheme/.
 "Approval of feasibility for the provision of citizens' communication services, for the timely vaccination against the covid-19 and the promotion of messages and the national campaign against the covid-19 in all the Media", Athens. 24.12.2020, online publication number: ΨΘ75465ΦΥΟ-8Ν5.
 Presidential Decree 81, Government Gazette of the Hellenic Republic, no. 119, issue A ', 08.07.2019, p.3181-3184.