Abertis Infraestructuras

The role of the administrative, management and supervisory bodies

Board of Directors

Abertis' governance model rests on the Board of Directors and its committees, namely, the Audit, Control and Sustainability Committee and the Nomination and Remuneration Committee and gives top priority to governance excellence and promoting sustainability and good governance practices.

Composition of the Board of Directors

Under the Abertis bylaws the Group's Board of Directors is to be made up of 12 directors, whose term of office is limited to three years. At the date of authorisation of the Consolidated Annual Accounts for the reporting period, the members of the Board of Directors are as follows:

All the directors are over 40 years of age. The Secretary to the Board of Directors is Mario Carlo Colombo, who is not a director.

The Board of Directors performs its duties with independence of judgement and is guided by the interests of the Group (corporate interest) above the particular interests of shareholders, senior managers or the directors themselves. The corporate interest is reconciled with the interests of the Group's employees, suppliers, customers and other stakeholders and the impact of Abertis' activities on the community as a whole and on the environment. Decisions within the Board are made independently, without external influence and avoiding conflicts of interest.

Audit, Control and Sustainability Committee (ACSC)

Composition

The ACSC has the following members:

• Ángel García Altozano, Chair
• Juan Santamaría Cases, member
• Jonathan Grant Kelly, member
• Pedro José López Jiménez, member
• Enrico Laghi, member
• Andrea Mangoni, member

Mario Carlo Colombo holds the position of Secretary to the Audit, Control and Sustainability Committee.

Roles and responsibilities regarding sustainability

On 1 March 2022, the Board of Directors agreed to expand the role and powers of the Audit and Control Committee to include sustainability matters. The ACSC thus took on the task of supervising the Group's overall policy on sustainability and ESG reporting and stakeholder relations, with the aim of ensuring it is aligned with the company's interests.

Key responsibilities include:

• Monitoring the effectiveness of the Group's internal control, internal audit and financial and non-financial risk management systems
• Supervising the process of preparing and presenting the required financial and non-financial information
• Referring to the Board of Directors proposals for the selection, appointment, re-appointment and replacement of the sustainability verifier
• Reporting on financial and non-financial reporting, in particular the Directors' Report, which includes the sustainability information the Group is required to publish

Nomination and Remuneration Committee

Composition

The Nomination and Remuneration Committee has the following members:

• Enrico Laghi, Chair
• Ángel García Altozano, member
• Jonathan Grant Kelly, member
• Andrea Mangoni, member
• Miquel Roca Junyent, member
• Juan Santamaría Cases, member

Annual Assessment

During the year, a formal annual assessment of the work of the Board of Directors and its Committees was carried out. The assessment was carried out by having all the members of the Board of Directors complete a self-assessment questionnaire on matters such as the quality and efficiency of the Board's work, diversity in the Board's composition and powers, the meetings held and the business conducted, and the performance and contribution of individual directors.

The meetings held by the Board of Directors during 2024 addressed all the issues within the Board's responsibility, including the supervision and monitoring of the Sustainability Policy, which involves, among other things, managing the organisation's impacts on the economy, the environment and people.

Integration of sustainability-related performance in incentive schemes

Under the Abertis bylaws, directors receive no remuneration, except for the Chief Executive Officer (CEO). The remuneration of the CEO for the reporting period has been established in accordance with article 28 of the Abertis bylaws, which stipulates that the CEO shall be entitled to receive, in cash or in kind, such fixed or variable remuneration linked to the Group's financial, economic and sustainability objectives and ESG criteria (more specifically, improvements in indicators of user and employee safety, ESG Plan implementation and cybersecurity) as is appropriate for the performance of the CEO's executive functions.

Variable remuneration criteria for senior management

Each year, the Nomination and Remuneration Committee must submit to the Board for approval the criteria or objectives for determining the variable remuneration of the CEO and the members of Abertis' senior management team, together with the annual compliance assessment.

The Nomination and Remuneration Committee met 4 times during the year. The main topics discussed at these meetings were the evaluation of the criteria for determining the variable remuneration of the CEO and the members of Abertis' senior management for 2023, together with the criteria to be set for 2024.

ESG metrics integration

As part of the 2025-27 ESG Plan, variable remuneration schemes linked to ESG metrics have been defined for senior and middle management positions. This represents the implementation of sustainability considerations in the remuneration structure, ensuring alignment with the Group's sustainability objectives and ESG performance indicators.

Statement on due diligence

Human Rights Due Diligence

Abertis has implemented a human rights due diligence system across 100% of its operations. The results of Abertis' Human Rights Due Diligence analysis were used in the double materiality assessment, aimed at identifying negative human rights and sustainability impacts.

During the materiality assessment process, a review was conducted of key documentation related to Abertis' human rights due diligence analysis, which provided input for identifying material impacts, risks and opportunities.

Supply Chain Due Diligence

As part of the 2025-27 ESG Plan, the priority is to manage the supply chain by having a human rights due diligence system in place for 100% of turnover, and ESG auditing of all critical suppliers together with follow-up of the audit results.

At year-end 2024, 100% of critical suppliers had undergone a sustainability audit, meeting the target set in the 2022-24 ESG Plan.

Future Compliance Measures

Throughout 2023 and 2024, Abertis continued to strengthen its Compliance Model and, with a view to the future implementation of the new Sustainability Due Diligence Directive approved by the European Union, worked to develop a Group-wide policy and procedure.

With this new due diligence policy and procedure, Abertis exercises responsible business conduct, integrating, detecting, preventing, supervising, reporting and, where applicable, repairing any adverse impacts that may arise out of its operations.

ESG Supplier Management

The Group applies enterprise-wide ESG management of supplier risks as part of its risk management framework, which includes:

• ESG considerations in due diligence processes for new acquisitions
• Specific control policies and procedures for supplier risk management
• Implementation of supplier approval and assessment tools to mitigate third-party risks
• Requirements for critical supplier sustainability assessments and follow-up

Risk management and internal controls over sustainability reporting

The content of this disclosure requirement is detailed in section 9.2 "Internal control and risk management systems in relation to the sustainability reporting process (ICSR system) (GOV-5)" of the Annex to the Sustainability Report.

Risk Management Framework

Abertis has determined its risk control strategy based on three major considerations:

• The Group's mission, vision and values
• The Abertis corporate strategic guidelines (transparency, good governance, sustainable growth, financial discipline, prudence and toll road management best practices)
• An analysis of the risk's criticality, according to the risk type and the country in which the activity is carried out

The Group's risk appetite statement defines its risk appetite as "Moderate-Minimum", making a distinction between risks to which the organisation is willing to take on more exposure and those to which the Group wishes to maintain minimal exposure (compliance, ethics, environmental, health and safety, and infrastructure integrity risks).

Governance Bodies for Risk Management

Board of Directors: Ultimately responsible for defining the risk strategy and the risk control policy.

Audit, Control and Sustainability Committee: Responsible for supervising the risk control systems, including model approval and risk monitoring. Also responsible for ESG matters, including:

• Monitoring the effectiveness of the Group's internal control, internal audit and financial and non-financial risk management systems
• Supervising the process of preparing and presenting required financial and non-financial information
• Supervising the Group's overall policy on sustainability and ESG reporting

Corporate Risk Officer: Responsible for preparing and updating risk management policies, ensuring effective model implementation and establishing common risk identification, classification and assessment methodology.

Risk Categories

The principal risk categories include:

• Governance and reputational risks: Including organizational governance model, governance standards, loss of reputation, and management of personnel
• Environment, strategy and growth-related risk: Including climate change, natural catastrophes, regulatory changes, and political instability
• Financial risks: Including debt obligations, interest rates, exchange rates, and liquidity
• Industrial risks: Including information systems, health and safety, infrastructure deterioration, and environmental damages
• Reporting and compliance risks: Including financial and sustainability information, tax compliance, and code of ethics

Internal Control Over Sustainability Reporting (ICSR)

Abertis has implemented an ICSR system that includes:

• Organizational and supervisory model for sustainability reporting
• Adoption of formal procedures for sustainability data collection and reporting
• Implementation of specific control activities for sustainability metrics
• Regular monitoring and validation of sustainability information
• Integration of sustainability risks in the overall risk management framework

Strategy, business model and value chain

Business Model

Abertis is a world leader in infrastructure management and mobility services, controlling nearly 7,870 kilometres of high-quality, high-capacity roads in 15 countries across Europe, the Americas and Asia.

Vision and Mission

• Vision: To be a leading global operator in mobility infrastructure management
• Mission: To promote and manage the infrastructure sustainably and efficiently, contributing to the development of the company's infrastructure in harmony with the well-being of its employees, creating long-term value for its stakeholders

Values

• Leading from responsibility and trust in people
• Finding infrastructure development solutions based on dialogue and collaboration with stakeholders
• Anticipating and adapting to the needs of customers and users through innovation and continuous improvement
• Driving efficiency in the organisation based on a simple and pragmatic approach
• Being transparent to showcase rigour and credibility

Global Presence

Abertis operates in 15 countries through various subsidiaries:

Thanks to strong international expansion, nearly 90% of Abertis' revenue now comes from outside Spain, most notably France (34%), Brazil (13%), Mexico (12%), Spain (11%) and Chile (9%).

Value Chain

Upstream Value Chain:

• Suppliers of construction materials and services
• Engineering and construction contractors
• Technology providers for toll collection and traffic management systems
• Financial institutions and investors
• Regulatory authorities and government agencies

Core Operations:

• Motorway and toll road management
• Infrastructure maintenance and improvement
• Traffic management and control
• Toll collection services
• Customer service and user experience
• Safety and security management

Downstream Value Chain:

• End users (drivers and passengers)
• Transport and logistics companies
• Local communities benefiting from improved connectivity
• Economic development in served regions

Strategic Approach

Bases for value creation:

• Being the leading company in the industry, combining quality with innovation
• Long-term commitment and high quality services as a great partner for public authorities
• Continuous investment in smart technologies and engineering
• Combining financial strength and industry experience
• Being part of the solution to mobility and climate change challenges

Industry expertise:

• Engineering: Maintaining highest service levels and controlling construction risks
• Operations: Promoting operational standards for safe and comfortable service
• Technology: Using innovative solutions to increase efficiency, safety and quality

Revenue and Performance

Financial Performance 2024:

• Operating income: EUR 6,072 million (9.8% increase vs 2023)
• EBITDA: EUR 4,292 million (10.2% increase vs 2023)
• Average Daily Traffic: 25,837 vehicles (1.5% increase vs 2023)
• Total network: 7,870 kilometers

Investment and Growth:

• EUR 748 million invested in infrastructure improvements
• Acquisition of new concessions including Santiago-Los Vilos in Chile (223 km)
• Completion of free-flow tolling implementation on A-13 and A-14 motorways in France

Interests and views of stakeholders

Presentation and description of stakeholders

Abertis has a global stakeholder map drawn up initially in 2014 in accordance with the principles established by AccountAbility's stakeholder relations standard AA1000 SES. This map has been updated each year by integrating any changes in the Group's various Business Units, the last in-depth update having been completed in 2021, and is still in force since there have been no significant changes in Abertis' activity.

The stakeholder map shows the characteristics of the stakeholders that are most important to the organisation (depending on the activity and the country), the existing communication and dialogue channels, and any information the organisation has regarding the stakeholders' expectations. It has been drawn up by identifying the common aspects reported for the Group's various activities, including any specific aspects detected for each activity or country. The final map is thus a summary that provides an overview of Abertis' activities, based on and supported by the separate stakeholder maps for each activity and country.

Stakeholder expectations are also identified within the framework of the human rights due diligence process, taking into account the affected social actors in the Group's value chain, and within the double materiality assessment, through consultation with the organisation's stakeholders, i.e. shareholders and investors, representatives of the Business Units and functional areas, suppliers, end-users and customers, the local community, associations and the media, and public authorities and regulators.

The following table shows the main stakeholders, together with their expectations of the organisation and the organisation's expectations of the stakeholders, and the associated channels of engagement. Although the environment is not included as a separate stakeholder, it is included implicitly through the expectations of the various stakeholders.

LIST OF MAIN STAKEHOLDERS

Stakeholder engagement

Abertis maintains a close relationship with its stakeholders and conducts two types of stakeholder engagement, one general and the other specifically for the double materiality process.

General engagement

General engagement is that linked to the operational execution of Abertis' activities. It serves various purposes and is organised mainly through the operational channels linked to the organisation's day-to-day activities.

The table below shows the type of general engagement through the communication channels described above, specifying: who (stakeholder) the engagement is with, how it is organised, its purpose and how its results are used.

Governance and consideration of stakeholders' expectations

The Sustainability Committee, which is made up of representatives of the Corporation and the Business Units, reports to the Audit, Control and Sustainability Committee of the Abertis Board of Directors. This Committee, which is cross-cutting and involves the participation of representatives from the different functional areas, coordinates and monitors the Sustainability Strategy at the global level and monitors and evaluates the execution of projects related to the different sustainability objectives, taking stakeholders' expectations into account. The Sustainability Committee reports to the Audit, Control and Sustainability Committee of the Abertis Board of Directors on overall policy, stakeholder needs, and sustainability objectives and programmes.

The Audit, Control and Sustainability Committee of the Abertis Board of Directors also oversees the overall policy on sustainability reporting, the Sustainability Strategy and stakeholder engagement and is responsible for reporting to the General Meeting of shareholders on the degree of alignment of the organisation's performance with the corporate interest.

Consideration of expectations

In light of the views expressed by stakeholders, the organisation's strategy and business model have been adapted through the establishment of the Sustainability Strategy for the period 2022-30. This strategy is implemented through the deployment of specific three-year plans called ESG Plans, which set intermediate objectives and initiatives, and the associated budget, in all the Business Units that make up the Group.

In addition, as a result of general and specific engagement with stakeholders, the operational processes of the activities carried out by the organisation and the services provided are adjusted so as to gradually respond to the identified expectations. In some cases the adjustment is mandatory, since it is required by the regulations applicable to Abertis' activities; in others, the evolution of the organisation's strategy voluntarily anticipates such regulations (especially when the corporate standards contain requirements that are not included in local legislation) or includes aspects and considerations that are required by the market context in which the various stakeholders are situated.

To comply with the disclosure requirements contained in the topical ESRS regarding own workforce (ESRS S1), workers in the value chain (ESRS S2), affected communities (ESRS S3) and customers and end-consumers (ESRS S4), which are set out in Chapter 7 "Contribution to society", details of the changes made to the strategy and the business model, taking stakeholder expectations into account, are presented below, broken down by type of stakeholder:

• Own workforce: as can be seen throughout Chapter 7.1 Own workforce, Abertis' strategic approach to managing its own employees reflects its commitment to respecting labour rights and human rights, fostering an inclusive and safe environment and promoting the holistic development of its workforce. From this perspective, Abertis considers it essential to take stakeholders' views and interests into account in order to lay a solid foundation for the Group's strategy and business model. This consideration is reflected in the meetings held with the various works councils to discuss matters of interest and incidents. In addition, the ethics channel is the preferred way for stakeholders to interact with the organisation and promotes collaboration in resolving possible incidents. The initiatives adopted are aimed at correct management of the IROs identified in the double materiality assessment.

• Workers in the value chain: As with the own workforce, Abertis considers it vitally important to take the interests and opinions of workers in the value chain into consideration when formulating its strategy. For that purpose it has established various communication channels, including the ethics channel as the preferred channel, to facilitate collaboration between the two parties and allow workers in the value chain to report to the Company of any concerns, suggestions or complaints they may have.

• Affected communities: The expectations expressed by affected local communities in the areas in which the organisation operates, including vulnerable groups, are directly addressed by the activities of the Abertis Foundation and the specific initiatives carried out by the various Business Units within the framework of the 2022-30 Sustainability Strategy, linked to the commitments set out in the Sustainability Policy with respect to the protection of human rights, among other things. Although the projects selected each year for direct involvement fit within the Abertis Foundation's priority lines of action, they respond specifically to the concrete needs of these groups and in some cases vary from year to year. The Abertis Foundation plans to draw up an action plan for the 2025-2027 period that articulates the synergies between the actions it promotes and the material impacts, risks and opportunities identified in the Group's double materiality assessment.

• Customers and end-consumers: The interests, views and rights (including human rights) of consumers and end-users underpin Abertis' strategy and business model, as can be seen throughout chapter 7.4 Consumers and end-users. The initiatives adopted by customer service address the expectations and suggestions expressed by consumers and end-users who may be affected by the organisation's activities. The initiatives implemented are aimed at connecting with customers and their needs from all the areas in which Abertis offers services to customers. The company therefore implements a user-centric approach focused on addressing the IROs identified in the double materiality assessment, promoting accessibility and the use of innovative technology to improve the customer experience, and adopting measures to reduce its environmental impact and contribute positively to society.

Given that both the stakeholders' expectations and the operational context vary over time, this adaptation is an exercise in continuous improvement. General stakeholder engagement will be key to successfully adjusting Abertis' strategy and business model in the future.

Material impacts, risks and opportunities and their interaction with strategy and business model

Material IROs identified

The impacts, risks and opportunities presented below are those identified in the double materiality assessment described in Disclosure Requirement IRO-1 in section 5.2 "Double materiality assessment (IRO-1 and IRO-2)", and the value chain description provided in Disclosure Requirement SBM-1 in chapter 5.4.1 "Strategy, business model and value chain assessment (SBM-1)".

Material IROs in the value chain

Description of material IROs

Transport decarbonisation and infrastructure adaptation (IRO): includes the contribution to the achievement of global climate neutrality objectives through climate change mitigation and adaptation measures, including the promotion of sustainable mobility and the reduction of direct and indirect emissions.

Safe, sustainable energy (IRO): includes efficiency measures and reduction of the use of non-renewable sources, or use of renewable sources, with the aim of ensuring security of supply and stability in energy cost and availability for Abertis' own activities and for the environment and communities in which it operates.

Air pollution (I, R): Abertis' activities have potential impacts in terms of noise, light and air pollution, accidental spills and other forms of pollution that can affect the ecosystems and populations adjacent to the infrastructure. This topic includes air pollution, which is concentrated in the motorway use phase.

Employment, health, safety and well-being of own workforce and workers in the value chain (IRO): includes the pay and working conditions of Abertis' own workforce and value chain workers, including employee well-being, motivation and work-life balance. It also includes the socio-economic conditions of employees and their families as other employee benefits. Free association and the right to strike of the organisation's own workforce and workers in the value chain are also included. The topic includes professional development, which consists of designing employee attraction and development plans as a lever to ensure employee satisfaction and well-being and foster adaptation to a new digital context. It applies both to Abertis' own workforce and to workers in the value chain. Lastly, it includes occupational health and safety, defined as actions aimed at ensuring healthy and safe working conditions for direct and indirect workers under a risk prevention approach, with a special focus on road safety.

Inclusion (Diversity and equality), engagement and development of own workforce (I, R): consists of having an inclusive work environment that facilitates the professional and personal development of all workers regardless of their status and without discrimination. It applies both to Abertis' own workforce and to workers in the value chain.

Quality and adaptation to new patterns of mobility (I, O): consists of the implementation and development of know-how that adds value by improving congestion and road safety, improving users' quality of life and promoting the socio-economic development of local communities, while also opening up mobility services to a diverse public, giving access to vulnerable groups. It also helps adapt to a context in which the transport sector is changing in line with new trends and user expectations, demographic changes (such as population ageing and city growth) and the emergence of new technologies.

Road safety (IRO): includes the efforts made to ensure the highest levels of road safety, following the recommendations of the United Nations' Second Decade of Action for Road Safety 2021-2030. It involves a variety of initiatives, including training, data analysis, research and the drafting of road safety plans, so that users and employees have the highest quality, safest roads, among other aspects.

Socio-economic development and community participation (IRO): includes measures aimed at ensuring that communities adjacent to the infrastructure managed by Abertis benefit from the social, economic and cultural development driven by mobility; and also the identification and mitigation of potential adverse impacts for these communities and community participation in decision-making, based on dialogue, transparency and accountability.

Human rights in the value chain (IRO): based on due diligence to ensure respect for human rights in the various direct and indirect activities of Abertis and the Business Units and in all countries, including risk prevention and mitigation protocols.

Compliance, corruption and bribery (I, R): as a company that operates in many different jurisdictions, Abertis monitors compliance with the national and international regulations applicable to each of its activities. It also has processes in place to identify, prevent and act against any cases of corruption or bribery that may arise in Abertis' value chain, which, given the nature of its activity, entails continuous engagement with public and private actors.

Digitalisation and cybersecurity (I, R): digitalisation is an essential tool to assist the evolution of the business towards smart mobility, but it entails cybersecurity risks that must be taken into account at all levels of management (strategic, tactical and operational). Secure mobility also means avoiding infrastructure outages due to cybersecurity incidents.

Current and anticipated effects on strategy and business model

Abertis carried out the first formal impact materiality assessment in 2014, in which the sustainability matters that are material for the Group were identified. The results of that analysis provided the basis for the definition of the sustainability action plan to mitigate the Group's negative impacts and enhance its positive impacts on the environment.

The organisation's strategy and related decision-making was modified in 2021 with the establishment of the 2022-30 Sustainability Strategy and the first ESG Plan for the period 2022-24 and the associated governance structure, culminating in the formal assignment of sustainability matters to the ACSC.

This integration affects the business model, which has evolved to incorporate ESG performance considerations and which, with the inclusion of the financial materiality assessment, will directly involve the risk and financial areas through the assessment of material risks and opportunities for the business.

One anticipated effect is that the business model will have to evolve to respond to the material IROs and the related targets set in the Group's strategy (specified in the Sustainability Strategy and the associated ESG Plans). Examples include:

• The deployment of concrete measures to adapt the infrastructure to the current impacts of climate change
• The development of new services to meet changing mobility demands, both in terms of environmental considerations and in terms of technological development and digital transition
• Changes to the organisational structure to ensure talent retention
• The implementation of innovative tools to work towards road safety and occupational safety commitments
• The definition of a purpose that will ensure the organisation maintains its social licence to operate

As the financial materiality assessment gains maturity over the next three years and the detected impacts are formally integrated in the ERM risk management model, the economic bases contextualising the levers for evolving the business model will be established.

The value chain will gradually adapt as the collaborative relationship with the supply chain is strengthened to achieve the goals set in the ESG Plan, taking the evolution of related sectors, the impact of new regulations and future changes in mobility patterns and stakeholders' expectations into account.

Material impacts

The following table shows the characteristics of material impacts, indicating the direction (positive/negative), type of occurrence (actual/potential), link between organisation and impact (cause/contribution), time horizon, and value chain stage:

Financial effects of material risks and opportunities

The relevant risks and opportunities identified are:

Transport decarbonisation and infrastructure adaptation: The identified risks relating to the adaptation of the infrastructure include damage to the infrastructure due to adverse weather events and/or new climate conditions that may increase the accident rate, generate business interruptions, among other effects, and entail adaptation and repair costs. Opportunities arising from the transition to sustainable mobility are also identified in terms of maintaining or increasing the volume of traffic (electrification of the automotive sector and the need for electric vehicle charging stations, new regulatory incentives, etc.). Risks include the increase in regulatory requirements, bringing an increase in costs (taxes, carbon price), investment in adaptation costs or reputational damage, and potential climate litigation due to the difficulty of adapting at the required speed.

Safe, sustainable energy: The associated risks include the difficulty of responding to increasing regulatory requirements regarding the energy transition, on account of the increase in costs associated with transition technologies, the increase in the cost of energy and the difficulty of obtaining a return on the investment. Opportunities include improving energy supply security and reducing supply cost by implementing reuse, efficiency or renewable energy generation measures.

Air pollution: Risk of pollution incidents arising from the undertaking's own activities or from road use, with reputational impacts or costs of damage mitigation or penalties.

Employment, health, safety and well-being of own workforce and workers in the value chain: Improvements in working conditions that result in better professional performance of workers and the reduction of labour disputes have a positive impact on work performance, the cost of social dialogue and the work environment. In relation to health and safety, the assessment identifies the associated potential reputational impact and the impact associated with implementing health and safety best practices (technology, training, awareness raising, etc.).

Inclusion (Diversity and equality), engagement and development of own workforce: Developing talent and fostering a diverse workforce based on the principles of equal opportunity helps mitigate the risk of losing key talent and make it easier to attract new talent in a competitive global context.

Quality and adaptation to new patterns of mobility: Improvements in the user experience (pay-per-use, free-flow), adaptation to new mobility models and sustainable mobility are identified as opportunities, with positive reputational effects.

Road safety: Road safety or accident events that damage reputation, lead to fines or the transfer of users to other alternative options are the main risks. The opportunities include the improvement of road safety conditions, the application of new technologies and best practices that can lead to greater user satisfaction, increased traffic, etc.

Socio-economic development and community participation: Risks include potential reputational damage, social pressures and delays in activities (e.g. construction works), leading to increased costs and loss of profits. The associated opportunity is the positive reputational impact of good community management.

Human rights in the value chain: Direct and indirect activities along the value chain can negatively impact human rights in regard to mobility, security, etc. and can lead to reputational damage, legal disputes, etc.

Compliance, corruption and bribery: The increase in regulatory pressure may entail risks of non-compliance, resulting in reputational effects, fines or sanctions. Likewise, cases of non-compliance, corruption, bribery, anticompetitive practices or money laundering by individuals linked to Abertis, its subsidiaries or its business partners could result in mitigation costs, loss of contracts, legal costs, sanctions or reputational loss.

Digitalisation and cybersecurity: Risk of cyber-attack and of additional costs to protect against security breaches affecting Abertis' operations, intellectual property or the personal data of its stakeholders.

Current financial effects

The identified risks can lead to a variety of direct financial impacts. For example, the occurrence of certain risks can give rise to economic losses due to temporary suspension of activities, damage to the infrastructure entailing high repair and maintenance costs, possible fines and penalties for non-compliance with new regulations, or costs arising from the operational management needed to mitigate these risks.

However, no IROs have been identified for which there is a major risk of material adjustments to the carrying amounts of the assets and liabilities recorded in the Financial Statements in the next annual reporting period.

Anticipated financial effects

Given that it has the option of omitting Disclosure Requirement SBM-3 DR48(e) "Anticipated financial effects of the undertaking's material risks and opportunities on its financial position", Abertis has chosen to avail itself of the transitional period provided by the regulation, since it is not currently possible to provide all the quantitative information for said disclosure. We are working to standardise and systematise the necessary data in order to be able to report quantitative information aligned with this requirement in future periods.

Resilience of the strategy and business model

The management of the identified material IROs is coordinated through the Sustainability Committee and through deployment and implementation of the 2022-30 Sustainability Strategy and the related ESG Plans, which involve all the functional areas of the Corporation and the Business Units. The goal is to perform continuous monitoring, with a view to mitigating negative impacts and material risks and enhancing positive material impacts and potential opportunities.

The ESG Plans start by identifying the material sustainability matters in relation to the relevant IROs to be managed by the organisation and specify concrete actions to enhance opportunities for the business and for stakeholders, environmental efficiency measures and measures to reinforce the contribution to society, as well as initiatives aimed at reducing environmental and social impacts and risks. In addition, to ensure the integration of the Group's Sustainability Strategy in new acquisitions, Abertis' new acquisition analysis procedure includes an assessment of IROs.

Although no formal resilience analysis is prepared, each IRO has specific management elements. These include, among other things, business continuity plans, emergency management processes, business continuity policy and processes such as the corporate Continuity Plan, Succession Management, the crisis management manual, the crisis management protocol, the crisis management communication plan, and the press release issued in the event of an accident, incident or extraordinary event.

Description of the process to identify and assess material impacts, risks and opportunities

Methodology

During 2023 and 2024, Abertis updated its materiality assessment in line with the methodological guidance laid down in the CSRD Directive, applying the principle of double materiality to identify and assess Abertis' material sustainability matters from a double perspective:

• Impact materiality: considering the Group's positive and negative, actual and potential impacts on the environment and people
• Financial materiality: analysing any sustainability-related risks and opportunities that could affect the Group either operationally or financially

Standards and References Used

Primary Standards:

• European Commission's considerations on double materiality as outlined in the ESRS linked to the CSRD Directive
• AccountAbility's AA1000AP (2018) and AA1000SES (2015) principles and standards
• ISO 26000 – Guidance on Social Responsibility
• GRI's universal standards (Sustainability Reporting Standards) in their 2021 version

Additional References:

• United Nations Global Compact (Abertis signatory since 2005)
• United Nations Sustainable Development Goals (SDGs)
• Sustainability Accounting Standards Board (SASB) for infrastructure sector
• Risk and trend analysis from WBCSD and World Economic Forum reports
• TCFD, TNFD, and CDP frameworks

Process Overview

The double materiality assessment was carried out in three steps:

1. Identification

• Matching previous sustainability matters against ESRS topics and global trends
• Analysis of business model, market context, and regulatory requirements
• Integration of internal management systems and stakeholder expectations
• Inclusion of results from Human Rights Due Diligence analysis

2. Assessment

• Internal consultation through interviews with senior management, functional area heads, Business Unit CEOs, and ESG teams
• External stakeholder consultation via document analysis and targeted assessments
• Review of employee surveys, supplier assessments, customer satisfaction surveys
• Analysis of NGO collaborations and social media monitoring

3. Prioritisation

• Integration of internal and external stakeholder assessments
• Evaluation using severity parameters: scale, scope, and irremediable character
• For potential impacts, assessment of probability
• Classification using scoring system (1-5 scale) with thresholds for materiality

Severity Assessment Framework

Severity Classification:

• Low: Score below 5
• Medium: Score between 6 and 10
• High: Score above 11

Scope and Coverage

Geographical Scope: 10 countries across Europe, Americas, and Asia

Activities Covered:

• Transport infrastructure management
• Infrastructure construction
• Communications services for transport management
• Central services

Time Horizons:

• Short term: 0-3 years (aligned with Business and ESG Plans)
• Medium term: 3-10 years (aligned with 2022-30 Sustainability Strategy)
• Long term: >10 years (average term of toll road concessions)

Value Chain Coverage: Upstream and downstream stakeholders and activities directly linked to operations

Key Assumptions and Parameters

The assessment assumes that operating contexts will evolve based on available information, with new acquisitions being incorporated in future materiality updates. The assessment focuses on the current situation with existing operations and applicable regulations, without scenario planning.

Human rights issues are integrated across the organization as cross-cutting concerns. The consolidation scope includes all subsidiaries consolidated in financial statements based on Abertis' control and management ability.

The content of this disclosure requirement is detailed in section 5.2.2 "Disclosure requirements in ESRS covered by the undertaking's sustainability statement (IRO-2)" of the Sustainability Report and in section 9.5 "ESRS Table" of the Annex to the Sustainability Report.

Transition plan for climate change mitigation

Each of the three-year ESG Plans that reflect the medium-term ambition of the 2022-30 Sustainability Strategy constitutes the transition plan for climate change mitigation. These plans include interim decarbonisation targets, along with specific levers encompassing initiatives and cross-cutting projects to achieve the strategic goals by 2030.

Scope of the plan

The 2022-30 Sustainability Strategy is global in scope and applies to all the Group's activities and all the countries in which it operates.

Targets and milestones

The direct decarbonisation targets of the 2022-30 Sustainability Strategy compared to 2019 are as follows:

• A 50% absolute reduction in Scope 1 and Scope 2 emissions.
• A 22% relative reduction in Scope 3 emissions associated with the procurement of goods and services, measured per million kilometres travelled by users of the managed motorways.

These targets have been externally validated by the Science Based Targets initiative (SBTi), an internationally recognised organisation that certifies the alignment of decarbonisation targets with science according to the organisation's established protocols. Abertis' decarbonisation targets have been validated for a 1.5°C scenario under protocol version 4.2.

Interim targets

The 2022-24 and 2025-27 ESG Plans establish specific interim targets:

2024 interim targets:

• Reduction in Scope 1 and 2 emissions (>25% versus 2019)
• Reduction of emissions in purchase of products and services relative to kms travelled (>10% versus 2019)
• Increase in the use of electricity from renewable sources as a percentage of total electricity consumption (>40%)

• 50% of waste generated has been recycled

2027 interim targets:

• Reduction in Scope 1 and 2 emissions (>40% compared to 2019)
• Reduction of emissions from purchased goods and services in relation to kms travelled (>16% in 2027 compared to 2019)

• 85% of total electricity consumed from renewable sources

• 35% of electricity consumption from own production or acquired under a 5-year PPA or equivalent

• 80% of waste generated is recycled or prepared for recycling

• Increase the number of electric vehicle charging stations on the motorways (>918)
• Reduce direct energy consumption/km managed by 10%

Alignment with 1.5°C / SBTi validation

The decarbonisation targets contained in the 2022-30 Sustainability Strategy have been set taking into account scientific standards, applying the Science Based Targets Initiative (SBTi) methodology with a scenario based on a 1.5° increase in the temperature of the planet.

Abertis' decarbonisation targets have been validated for a 1.5°C scenario under protocol version 4.2. The Scope 1 and Scope 2 target aims to reduce absolute emissions by 50% by 2030 compared to 2019, following the Absolute Contraction approach. The ambition for the Scope 1 and Scope 2 targets defined by the Group exceeds the minimum ambition for a 1.5°C trajectory in 2030 and is thus considered ambitious under SBTi criteria. The target includes 100% of Scope 1 and 2 emissions.

The Scope 3 target seeks to reduce emissions intensity by 22% by 2030 compared to 2019, using the 2% Physical Intensity approach. This target, linked to 100% of the emissions from the Scope 3 goods and services procurement category, results in annual reductions of at least 2% without increasing absolute emissions, in accordance with the SBTi methodology.

Net zero ambition

Abertis has not formalised its decarbonisation ambition for 2050. However, under the framework of the 2025-27 ESG Plan, it plans to analyse and assess the resources necessary to commit to net-zero emissions in compliance with prevailing legal requirements and aligned with an international benchmark.

The 2025-27 ESG Plan includes a cross-cutting project to: Evaluate the commitment to Net Zero by 2045 (including Scope 1 and Scope 2 emissions by 2040).

Key decarbonisation levers

The decarbonisation levers outlined in the ESG Plans for 2022-24 and 2025-27, along with the key planned actions under each lever, are as follows:

Energy efficiency

This lever aims to reduce the energy intensity of activities through initiatives such as process optimisation, replacement of equipment with energy-efficient alternatives, and improving the efficiency of processes associated with services provided.

Actions include:

• Installation of LED technology for lighting (France, Spain, Italy, Mexico, Brazil, USA, Puerto Rico, Argentina, India)
• Vehicle fleet energy efficiency (Spain, Brazil, Argentina)
• Energy efficiency of infrastructure (Spain, Italy, Puerto Rico, France, Mexico, Argentina)
• Energy efficiency of services (Abertis Mobility Services - Spain, USA; Chile)
• Energy management systems (France, Mexico, Brazil, USA, Argentina)

Energy transition

The replacement of fossil fuels with alternatives with lower greenhouse gas emissions, ensuring the same level of energy efficiency.

Initiatives include:

• Transitioning vehicle fleets to alternative fuels
• Testing new alternative fuels
• Deploying electricity generation installations powered by solar energy for self-consumption
• Acquiring renewable electricity guarantees of origin
• Entering long-term contracts for the purchase of such electricity

Actions include:

• Purchase of electricity from renewable sources (France, Spain, Italy, Chile, Mexico, Brazil, USA, Argentina, India)
• Installation of solar panels (Spain, Brazil, Puerto Rico, France, Italy, Mexico, USA, Argentina, India)
• Migration of fleet to electric vehicles (France, Spain, Italy, India, Chile, Mexico, USA, Argentina, Puerto Rico)
• Fleet fuel efficiency initiatives (France, Spain, Mexico, Brazil, USA, Argentina)

Waste and materials

Reducing the volume of waste generated and increasing recycling rates, re-inputting waste into operational processes to minimise external material consumption, evolving operational processes to reduce material usage and increasing the use of environmentally friendly materials.

Actions include:

• Reduction in Scope 3 (materials procurement and waste separation and recycling) across multiple countries
• Use of recycled material instead of new materials (Spain, Chile, Puerto Rico)
• 15% of binder and base materials used in pavement maintenance (ordinary and extraordinary) are recycled
• Metals monitoring and inclusion in purchasing processes

Other initiatives

Actions related to management aspects, such as implementing energy management systems, incorporating specific clauses in procurement processes for products and services and improving the granularity of the carbon footprint inventory.

Actions include:

• Review of the study to identify concrete decarbonisation measures (Brazil)
• Employee commuting and remote work study (Puerto Rico)
• 100% of Group employees fly with SAF (cumulative 20% per year from 2024)
• Increased use of alternative fuels

Baseline year

The year 2019 was selected as baseline, following SBTi's recommendation to use the most recent year with complete data, excluding 2020 due to the COVID-19 pandemic's impact on the organisation's performance.

Baseline values (2019):

• Scope 1 and 2 emissions: 99,037 tCO2eq
• Scope 3 emissions (procurement of goods and services per million km travelled): 8.3 tCO2eq/million km

Implementation status

It should be noted that almost all initiatives planned under the 2022-24 ESG Plan have been implemented, achieving the GHG emission reduction targets for the triennium.

Estimates indicate the following variations compared to 2019 values: a reduction of 42,709 tonnes of CO₂e related to the energy transition lever.

CapEx and investment

The systems currently in place do not have a breakdown by share of operating expenses (OpEx) and investments in fixed assets (CapEx) for the actions related to climate change.

The budget is allocated (OpEx and CapEx) within the organisation's strategic plan and linked to the initiatives implemented in each business unit.

Locked-in emissions and stranded assets

Due to the nature of Abertis' activities, the requirements related to locked-in greenhouse gas emissions and significant CapEx related to coal, oil and gas activities do not apply.

Carbon credits and removals

The organisation's sustainable financing framework, which was updated during 2024, includes emission reduction targets along with others linked to the promotion of electric mobility. Progress in these initiatives is set out in a specific report published for the first time in 2024.

Paris-aligned benchmarks

Abertis' stock market delisting in 2018 resulted in its exclusion from various sustainability performance indices in which it previously participated. Nevertheless, external evaluations by specialised analysts have continued as the organisation issues debt that is traded on international markets. To date, Abertis is not aware of having been excluded from any EU Paris-Aligned Benchmarks. However, this cannot be confirmed through any centralised source, as such a repository does not exist, and the constituents of indices are not always publicly available. Abertis does not meet any of the exclusion criteria outlined in Article 12.1 of Regulation EU 2020/1818 and annually discloses information regarding compliance with the "Do No Significant Harm" criteria linked to Regulation EU 2020 852.

Summary tables

GHG EMISSION REDUCTION TARGETS FOR 2030

INTERIM GHG EMISSION REDUCTION TARGETS FOR 2024

INTERIM GHG EMISSION REDUCTION TARGETS FOR 2027

Policies related to climate change mitigation and adaptation

Abertis does not have a specific policy for climate change mitigation and adaptation. However, the sustainability policy, as outlined in section 5.4.1 "Strategy, business model and value chain" (SBM-1), includes explicit commitments related to mitigating and adapting infrastructure and services to physical and transitional climate risks, while leveraging opportunities arising from climate change through proactive measures against the climate crisis.

Sustainability Policy

Key content and principles:

• Mitigating and adapting infrastructure and services to physical and transitional climate risks
• Leveraging opportunities arising from climate change through proactive measures against the climate crisis
• Principles of energy efficiency
• Renewable energy development
• Promotion of a circular economy through the sustainable use of natural resources, in line with planetary boundaries
• Integration of innovation in processes and materials

Reference: See section 5.4.1 "Strategy, business model and value chain" (SBM-1) for full details.

Actions and resources in relation to climate change policies

Abertis has deployed and planned actions and resources as part of its transition plan for climate change mitigation and its 2022-30 Sustainability Strategy and ESG Plan. The initiatives are linked to the budget allocated (OpEx and CapEx) within the organisation's strategic plan, though systems currently in place do not provide a breakdown by share of operating expenses (OpEx) and investments in fixed assets (CapEx) for climate change actions.

Climate Change Mitigation Actions Under the 2022-24 ESG Plan

Decarbonisation Lever: Energy Efficiency

Installation of LED technology for lighting

• Scope: Own operations
• Countries: France, Spain, Italy (implemented); Mexico, Brazil, USA (in progress)
• Expected results: Reduction of CO₂e emissions; reduction in associated maintenance; improved road safety, personnel safety and visual perception
• Status: LED tunnel replacement completed in Spain and France; lighting tower replacement at toll booths/junctions completed in Italy; in progress in USA, Mexico and Brazil according to roadway plans

Vehicle fleet energy efficiency

• Scope: Own operations
• Countries: Spain, Brazil, Argentina (implemented); Brazil (in progress)
• Expected results: Reduction of fuel consumption and associated pollution
• Actions implemented: Brazil and Spain replaced obsolete vehicles with more efficient models (e.g., diesel to natural gas, diesel to ethanol); eco-driving courses in Spain; GPS systems installed in Argentina fleet to optimize routes

Energy efficiency of infrastructure

• Scope: Own operations
• Countries: Spain, Italy, Puerto Rico (implemented); France, Mexico, Argentina (in progress)
• Expected results: Energy saving
• Actions implemented: Argentina facility analysis for improvement plans (light sensors, thermal insulation); Mexico headquarters relocation to Leed Green-certified building (completed early 2025); Spain replaced heating systems with aerothermal systems; France replaced boilers; Italy implemented heat pump systems; Puerto Rico and Argentina focused on equipment maintenance to prevent refrigerant gas leaks

Energy efficiency of services

• Scope: Own operations and downstream
• Countries: Abertis Mobility Services (Spain, USA) implemented; Chile (in progress)
• Expected results: Energy saving; potential reduction of up to 50% of total energy consumption for future gantries
• Actions implemented: Abertis Mobility Services developed energy efficiency programme for Free Flow service; Chile evaluating "Stop & Go" system to reduce travel time and associated emissions

Decarbonisation Lever: Energy Transition

Purchase of electricity from renewable sources

• Scope: Upstream, own operations
• Countries: France, Spain, Italy, Chile, Mexico, Brazil (implemented); USA, Argentina, India (in progress)
• Expected results: Reduction of CO₂e emissions; avoiding reliance on fossil fuel-derived electricity
• Actions implemented: Purchase of renewable energy certificates I-REC in France, Spain, Italy, Brazil; direct supply contract maintained in Mexico; in process in USA, Argentina, India

Installation of solar panels

• Scope: Upstream, own operations, downstream
• Countries: Spain, Brazil, Puerto Rico (implemented); Mexico, Brazil (in progress)
• Expected results: Reduction of CO₂e emissions; fostering renewable electricity use
• Actions implemented: Solar panels for self-consumption in Brazil and Puerto Rico; Spain installed photovoltaic plant for toll operations and highway lighting

Migration of fleet to electric vehicles

• Scope: Own operations
• Countries: France, Spain, Italy, India (implemented); Chile, Mexico, USA, Argentina (in progress)
• Expected results: Reduction in fuel consumption and CO₂e emissions

Decarbonisation Lever: Waste and Materials

Material reduction and recycled materials use

• Scope: Upstream (Scope 3)
• Countries: France, Chile, Brazil, USA, Puerto Rico, India
• Expected results: Reduction of CO₂e emissions
• Actions implemented: Reduced office material use (Abertis Mobility Services, Italy); recycled materials in pavement and asphalt projects; continuous improvement with waste collection providers (Italy, Mexico); improved waste separation at highways/offices (France, Spain, Italy, Argentina); employee and user recycling awareness campaigns (Italy, Argentina, Mexico, Puerto Rico)

Decarbonisation Lever: Other

Review of study to identify concrete decarbonisation measures

• Scope: Upstream, own operations, downstream
• Countries: Brazil (in progress)

Employee commuting and remote work study

• Scope: Own operations
• Countries: Puerto Rico (implemented)
• Expected results: Identification of actions to implement

Estimated Emission Reductions (2022-24 ESG Plan)

Internal systems do not allow specific breakdown per initiative, but estimates indicate compared to 2019:

• Energy transition strategy: Reduction of 42,709 tonnes of CO₂e
• Waste and materials strategy: Reduction of 89,621 tonnes of CO₂e
• Energy efficiency: Increase of 6,597 tonnes of CO₂e (due to operational scope changes and increased liquid fuel consumption)
• Other factors: Increase of 27,318 tonnes of CO₂e (activity intensity changes, improved data granularity, enhanced calculation systems)

Note: Many projects in Argentina paused in 2024 due to operations nature and market context regarding access to environmental innovation technology.

Climate Change Mitigation Actions Under the 2025-27 ESG Plan

The 2025-27 ESG Plan aligns with sustainability policy commitments and targets a 40% reduction in Scope 1 and 2 emissions by 2027 (vs. 2019) and >16% reduction in CO₂e from purchased goods/services relative to kilometres travelled.

Decarbonisation Lever: Energy Efficiency

Installation of LED technology for lighting

• Scope: Own operations
• Countries: France, Spain, Puerto Rico, Argentina, India
• Expected results: Reduction of CO₂e emissions; reduced maintenance; improved road safety, personnel safety and visual perception
• Status: Starting in 2025

Energy management

• Scope: Own operations
• Countries: France, Mexico, Brazil, USA, Argentina
• Status: Starting in 2025

Energy efficiency of infrastructure

• Scope: Own operations
• Countries: Italy, USA
• Expected results: Energy saving

Decarbonisation Lever: Energy Transition

Purchase of electricity from renewable sources

• Scope: Upstream, own operations
• Countries: All
• Expected results: Reduction of CO₂e emissions

Installation of solar panels

• Scope: Upstream, own operations, downstream
• Countries: France, Spain, Italy, Chile, Mexico, Brazil, USA, Puerto Rico, Argentina, India
• Status: Starting in 2025

Innovation Initiatives

Drone Challenge

• Description: Seeks innovative solutions to mobility challenges through drone utilization for automated road/structure inspections
• Expected results: Improved road operations and infrastructure maintenance planning; replacing patrol vehicles and reducing associated emissions

Circular economy integration

• Description: Developing new materials for road maintenance
• Examples: Recycled Asphalt Pavement (RAP) in asphalt layers; recycled plastic pavement; rubber in Brazil; natural pine resin in France
• Note: Technology take-up depends on evolving national regulations determining maximum percentage of recycled materials allowed in paving

GHG Emission Reduction Targets to 2030 and Associated Reduction Levers

Resource Allocation

The initiatives implemented in each business unit are linked to the budget allocated (OpEx and CapEx) within the organisation's strategic plan. However, the systems currently in place do not have a breakdown by share of operating expenses (OpEx) and investments in fixed assets (CapEx) for the actions related to climate change.

Targets related to climate change mitigation and adaptation

2030 Sustainability Strategy Targets (SBTi-validated)

Abertis has committed to greenhouse gas emission reduction targets validated by the Science Based Targets initiative (SBTi) in 2023, aligned with a 1.5°C scenario:

Interim Targets - ESG Plan 2024

Interim Targets - ESG Plan 2027

Cross-cutting Projects 2025-27

• Evaluate Net Zero commitment by 2045 (including Scope 1 and Scope 2 emissions by 2040)
• 100% of Group employees fly with SAF (cumulative 20% per year from 2024)
• Increase consumption of alternative fuels
• Measure and increase percentage of waste reused as recycled material
• 15% of binder and base materials used in pavement maintenance from recycled materials
• Implement biodiversity methodology and set related targets
• Establish methodology for Nature-Based Solutions for climate adaptation

Reduction Levers to 2030

Geographic Scope: All targets apply globally to all countries where Abertis operates (France, Spain, Italy, Chile, Mexico, Brazil, USA, Puerto Rico, Argentina, India)

Coverage: Targets cover 100% of emissions for the categories specified, aligned with financial consolidation perimeter

GHGs included: CO2, CH4, N2O, HFCs, PFCs, SF6, NF3

Energy consumption and mix

Energy consumption by source (MWh)

Energy intensity (based on net revenue)

Scope and methodology

Organisational perimeter: Total energy consumption in 2024 was 567 GWh, including perimeter expansions in Spain, the United States, and Puerto Rico. The 2022 and 2023 data are presented on a current perimeter basis at year-end.

High-climate-impact sector: Abertis operates in a high-climate-impact sector; thus, the net revenue figures used to calculate energy intensity align with the revenue from operations as outlined in section 1.1.2 of the Annual Report and the Consolidated Statement of Profit or Loss in the Consolidated Annual Accounts.

Renewable electricity: 72.8% of direct electricity consumed in 2024 came from renewable sources (compared to the target of >40% by 2024). This includes purchased guarantees of origin, self-generation from solar panels (62 plants operational), and contracted renewable electricity supply.

Fossil fuel breakdown: Petroleum-derived fuels accounted for 85% of total fossil fuel consumption in 2024. Fossil fuel consumption decreased by 20% compared to 2023, driven by fleet migration initiatives (732 alternative fuel vehicles by end-2024, including 299 ethanol, 289 electric, 138 hybrid).

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 GHG Emissions

Evolution of Scope 1 GHG Emissions (tCO₂eq)

Note: Abertis does not participate in any regulated emissions trading schemes.

Scope 1 emissions by activity and country (2024, tCO₂eq)

Scope 1 emissions by activity (tCO₂eq)

Scope 2 GHG Emissions

Evolution of Scope 2 GHG Emissions (tCO₂eq)

Scope 2 emissions by activity and country (2024, tCO₂eq, market-based)

Scope 2 emissions by activity (tCO₂eq, market-based)

Scope 3 GHG Emissions

Evolution of Total Scope 3 GHG Emissions by Category (tCO₂eq)

Scope 3 emissions by activity and country (2024, tCO₂eq)

Scope 3 emissions by activity (tCO₂eq)

Note: Categories 8, 9, 10, 12, 13 and 14 do not apply to Abertis' activities. Category 11 (Use of sold products) emissions are excluded from the inventory as they are considered indirect and voluntary under the GHG Protocol; however, estimates are disclosed separately in the air pollution section (ESRS E2).

Total GHG Emissions

Evolution of Total GHG Emissions (tCO₂eq)

Total emissions by activity and country (2024, tCO₂eq, market-based)

Total emissions by activity (tCO₂eq, market-based)

GHG Intensity

Evolution of GHG Intensity Based on Net Revenue (tCO₂eq per million euros)

GHG Intensity by Activity (tCO₂eq per million euros, market-based)

Scope 1 and 2 Emissions Intensity for Toll Roads (tCO₂eq per ADT)

Biogenic Emissions

Evolution of Biogenic Emissions (tCO₂eq)

Note: Biogenic emissions are reported separately from gross Scopes 1, 2 and 3 but are included in target achievement calculations per SBTi protocols.

Methodology and Scope Notes

Organizational Boundaries: The carbon footprint includes emissions from activities where Abertis has operational control. The organizational boundaries align with the Group's financial consolidation perimeter. All subsidiaries consolidated in the financial statements are included. In 2024, there were no joint ventures except for financial holdings included in Scope 3 under category 15 (Investments).

Base Year: 2019 was selected as the baseline year following SBTi recommendations to use the most recent year with complete data, excluding 2020 due to COVID-19 impacts. The base year values are reviewed periodically; if a 5% variation threshold due to changes in consolidation scope is exceeded, the base year is recalculated. A formal review was conducted in 2022; the next review is scheduled for 2025.

GHGs Included: Carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulphur hexafluoride (SF₆), and nitrogen trifluoride (NF₃), expressed in tonnes of CO₂ equivalent (tCO₂eq).

Global Warming Potentials (GWP): GWPs from AR4, AR5 and AR6 are used depending on the emission factor database, with priority given to AR6.

Emission Factors: 2023 emission factors were used for the 2024 inventory due to timing constraints. Country-specific factors are prioritised; global databases are used when local factors are unavailable. Sources include UK BEIS, MITECO, ADEME, Programa Brasileiro GHG Protocol, US EPA, IEA, Ecoinvent, AIB, among others.

Scope 1: Covers gross emissions from stationary and mobile combustion sources and refrigerant gas leakage. Reported consumption data include natural gas, petrol, diesel, butane, propane, ethanol (in litres or kWh) and HFC refrigerants (in kilograms). Abertis does not participate in regulated emissions trading schemes.

Scope 2: Calculated using both location-based and market-based approaches. The market-based approach is the basis for the 2022-30 Sustainability Strategy and ESG Plans. Covers electricity consumption from stationary and mobile sources. In 2024, 50.6% of Scope 2 emissions were covered by contractual instruments (guarantees of origin or direct renewable energy contracts).

Scope 3: All relevant categories under the GHG Protocol are included. Categories 8, 9, 10, 12, 13 and 14 do not apply to Abertis' activities. Category 11 (Use of sold products, i.e. emissions from vehicles on motorways) is excluded from the inventory as these are indirect emissions considered voluntary under the GHG Protocol and not included in SBTi target scope. These emissions are estimated separately and disclosed in the air pollution section (ESRS E2). 60.8% of Scope 3 emissions are calculated using primary (physical) data; the remainder use economic data and emission factors.

Data Sources:

• Scope 1 and 2: Physical data from periodic consumption records.
• Scope 3 Categories 1, 5, 6, 7: Mix of physical data (fuels, electricity, water, materials, waste, distances) and economic data (services).
• Scope 3 Categories 2, 4, 15: Economic data.
• Scope 3 Category 3: Calculated from Scope 1 and 2 physical data.
• Employee commuting (Category 7): Based on a 2024 employee survey extrapolated to the entire workforce.

Methodological Changes in 2024:

• Updated employee commuting survey with broader vehicle type classifications (including ethanol vehicles).
• Expanded Category 15 (Investments) using PCAF methodology for financial participations.
• Increased granularity for purchased services and waste categories.
• Incorporated estimated emissions for subsidiaries not reporting direct data, bringing the carbon footprint perimeter in line with the financial consolidation perimeter.

Uncertainty: The overall carbon footprint has a cumulative uncertainty of 8.2% (Scope 1: 3.7%; Scope 2: 4.2%; Scope 3: 9.0%), calculated per GHG Protocol guidance.

Perimeter Changes: Baseline year (2019) and 2022 data are presented on a constant perimeter basis. Data for 2023 and 2024 reflect the current perimeter, including acquisitions in Spain (Autovía del Camino in February 2024, Trados 45 stake increase) and Puerto Rico (PRTR in December 2023). Biogenic emissions are reported separately but included in target achievement calculations.

Validation: Scope 1 and Scope 2 reduction targets and the Scope 3 purchased goods and services reduction target were validated by the Science Based Targets initiative (SBTi) in 2023 under protocol version 4.2 for a 1.5°C scenario.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Use of phase-in provision

With respect to topical Disclosure Requirements E1-9 and E2-6, in line with the provisions of Appendix C of ESRS 1 of the Regulation, Abertis has opted to avail itself of the transitional period, since it is not currently possible to provide all the quantitative information needed to meet those requirements.

Given the option to omit the Disclosure Requirement under E1-9 "Potential financial effects from material physical and transition risks and potential climate-related opportunities", Abertis opts to adhere to the transitional period established by the regulation. Currently, it is not possible to provide all the quantitative information required under this provision.

Policies related to pollution

Abertis does not have a specific air pollution policy, as air pollution is primarily linked to the use of infrastructure by vehicles travelling on motorways, over which the company has no direct control. However, the Group estimates pollutant gas emissions throughout the infrastructure life cycle, with the aim of identifying potential measures to help reduce this environmental impact, as well as assessing the effects of the transition of vehicle fleets in different countries on this impact.

Sustainability Policy

While lacking a dedicated pollution policy, the company's sustainability policy includes aspects relevant to pollution:

Key content:

• Fight against climate change
• Enhancement and conservation of natural capital
• Sustainable use of natural resources
• Innovation in processes and materials

These elements are all linked to air pollution management.

Public availability: Detailed in section 5.4.1 Strategy, business model and value chain (SBM-1)

Implementation: The environmental component of the sustainability policy is reflected in actions under the ESG Plans and the 2022-30 Sustainability Strategy, including initiatives to reduce air pollution undertaken by the Group's Business Units under the 2022-24 ESG Plan.

Actions and resources related to pollution

Overview

Actions and resources are aligned with the environmental component of the sustainability policy, reflected in the 2022-24 ESG Plan and 2025-27 ESG Plan, as outlined in the 2022-30 Sustainability Strategy.

Resource allocation: The systems currently in place do not have a detailed breakdown of the OpEx and CapEx of actions related to air pollution.

Actions under 2022-24 ESG Plan

EV charging stations installation

• Action: Installation of EV charging stations on motorways
• Scope: Entire value chain (downstream)
• Geographic deployment: France, Spain, Italy, United States (2024); also managed in Mexico and Chile
• Scale: Total of 776 charging points installed by 2024
• Time horizon: 2024 (completed)
• Link to strategy: Linked to energy transition lever and decarbonisation objectives of the 2022-30 Sustainability Strategy
• Expected outcome: Reduce polluting emissions associated with the use of motorways

Stop & Go system (Chile)

• Action: Stop & Go system to reduce fuel consumption
• Description: Allows users to reduce travel time under toll gantries
• Scope: Own operations (downstream)
• Geographic deployment: Chile
• Time horizon: 2024 (implemented)
• Expected outcome: Reduce fuel consumption and associated pollution

Toll-discount programme (United States)

• Action: Toll-discount programme with free tolls for specific groups
• Description: Free tolls for specific groups to improve downstream circulation
• Scope: Own operations (downstream)
• Geographic deployment: Elizabeth River Crossing motorway, United States; occasionally at Aucat, Spain
• Time horizon: 2024 (continued)
• Expected outcome: Improve downstream circulation and reduce associated pollution

Noise pollution monitoring and mitigation

• Action: Noise level monitoring, noise mapping, and noise barrier implementation
• Scope: Own operations
• Geographic deployment:
  • Acoustic studies: Spain, France, Brazil, Chile, Italy (2,764 km of motorways in 2024)
  • Noise maps: France and Spain (in compliance with legal requirements)
  • Noise barriers: 146 km of motorways in Spain, France, Brazil, Chile, Italy, Puerto Rico, and United States
• Time horizon: 2024 (completed)
• KPI: Complaints about noise were minimal: 1 complaint in Spain (Trados 45) and 11 in Chile (Autopista Central)
• Expected outcome: Identify hotspots and mitigate noise pollution associated with motorway traffic

Actions under 2025-27 ESG Plan

EV charging stations installation (continued)

• Action: Continue installing EV charging stations
• Scope: Entire value chain (downstream)
• Geographic deployment: France, Spain, Italy, Chile planned; other countries subject to market context review as pilot projects have not been operative or failed to achieve intended results
• Time horizon: 2025-2027
• Link to policy: Aligned with European Alternative Fuels Infrastructure Regulation framework
• Expected outcome: Maximise free-flow toll system transactions to reduce vehicle fuel consumption and associated polluting emissions

Decontaminating additive in asphalt (Chile)

• Action: Incorporation of decontaminating additive in asphalt mixes
• Scope: Upstream value chain
• Geographic deployment: Chile
• Time horizon: Starting in 2025
• Expected outcome: Reduce polluting gases

Noise reduction barriers (Italy)

• Action: Installation of noise reduction barriers
• Scope: Downstream
• Geographic deployment: Italy
• Time horizon: From 2025
• Expected outcome: Mitigate environmental and noise pollution

Sound-reducing pavement surfacing (Chile)

• Action: Use of sound-reducing pavement surfacing
• Scope: Downstream
• Geographic deployment: Chile
• Time horizon: From 2025 (under consideration)
• Expected outcome: Significantly lower vehicle traffic decibel levels and reduce impact on neighbouring communities

Targets related to pollution

Abertis does not disclose specific direct targets for prevention, control and reduction of air pollution emissions in its 2022-30 Sustainability Strategy and ESG Plans. However, the company establishes indirect objectives linked to air pollution through its decarbonisation and climate change mitigation targets.

Indirect pollution reduction targets

The following climate change targets contribute indirectly to air pollution reduction:

Target for 2030:

• Metric: Scope 1 and 2 emissions (market-based)
• Baseline: 99,037 tCO2e (2019)
• Target: 50% reduction (absolute)
• Target value: 49,518 tCO2e reduction
• Coverage: 100% of emissions
• Type: Absolute target

Interim target for 2024:

• Metric: Scope 1 and 2 emissions (market-based)
• Baseline: 99,037 tCO2e (2019)
• Target: 25% reduction (absolute)
• Target value: 24,759 tCO2e reduction
• Coverage: 100% of emissions
• Type: Absolute target

Interim target for 2027:

• Metric: Scope 1 and 2 emissions (market-based)
• Baseline: 99,037 tCO2e (2019)
• Target: 40% reduction (absolute)
• Target value: 39,615 tCO2e reduction
• Coverage: 100% of emissions
• Type: Absolute target

Additional indirect objectives

• Maximise transactions using free-flow toll systems (aligned with local regulatory frameworks) to reduce vehicle fuel consumption and associated polluting emissions
• Installation of electric vehicle charging stations (contextualised within the European Alternative Fuels Infrastructure Regulation framework)

Scope and alignment

These targets are aligned with the company's Sustainability-Linked Financing Framework and aim to contribute to the decarbonisation of road transport. The targets were defined based on stakeholder expectations gathered through the materiality analysis process and consider upstream and downstream impacts on the organisation.

Pollution of air, water and soil

Air pollution (E2-4)

Under Regulation 166/2006 on the European Pollutant Release and Transfer Register (E-PRTR), pollutants linked to vehicle traffic on the infrastructure include nitrogen oxides (NOx) from fuel combustion, particulate matter smaller than 2.5 microns (PM2.5) and 10 microns (PM10) emitted by vehicles, carbon monoxide (CO), volatile organic compounds (VOCs) and carbon dioxide (CO2). These gases can impact health and contribute to respiratory problems.

This European legislation applies to manufacturing industries and sectors that are significant emitters of pollutants, and it does not directly apply to Abertis. Therefore, the Group does not have precise monitoring of air pollutant emissions from vehicles using the infrastructure it manages. However, the Group tracks emissions from associated traffic using an estimate based on the standards for calculating the carbon footprint.

Methodology: The estimates are based on the 2019 Emissions Inventory Guide from the European Monitoring and Evaluation Programme (EMEP) and the European Environment Agency (EEA), as well as emission estimation methodologies from Spain's Ministry for the Ecological Transition and the Demographic Challenge (MITECO). Pollutants are estimated by applying emission factors to CO2e emissions of the carbon footprint, in Scopes 1 and 2 on direct emissions (considering fossil fuels used in facilities and vehicles) and for Scope 3 (including emissions generated by vehicles using the motorways). To determine emission factors for vehicles on motorways, data on kilometres travelled and an estimate of the vehicle fleet in each country, based on official statistics, are used.

As this methodology involves estimating pollutants from an estimate of CO2e emissions, the associated level of uncertainty is high.

Abertis applies this methodology to estimate gases emitted across the entire lifecycle of infrastructure. The following gases are included: carbon monoxide (CO), volatile organic compounds (VOC), non-methane volatile organic compounds (NMVOC), methane (CH4), nitrogen oxides (NOx), nitrogen monoxide (NO), nitrogen dioxide (NO2), nitrous oxide (N2O), ammonia (NH3), particles with a diameter of less than 2.5 microns (PM2.5), particles with a diameter of less than 10 microns (PM10), total particulate matter (PM) and sulphur oxides (SOx).

The evolution of the organisation's energy intensity, together with the evolution in the transition of the vehicle fleets in the different countries, is reflected in the evolution of atmospheric pollutants, which in general show slightly lower values than those of the previous year.

Emissions of pollutants (tonnes) - 2024

Water and soil pollution

Water and soil pollution and substances of concern or very high concern are not material for the Group. As a result, the content only addresses the disclosure requirements related to air pollution.

Wastewater discharges

No subsidiary discharges wastewater in water stressed areas. In some countries, however, including France, Spain, Argentina, Brazil and Mexico, wastewater has to be treated at the point of discharge to purify it.

The accompanying table shows the amounts of wastewater discharged by water type and disposal destination (to the surface, ground or sea or to a third party, including providers of water treatment services).

Total wastewater (m³) generated by water type and discharge destination

Anticipated financial effects from pollution-related impacts, risks and opportunities

Phase-in exemption applied

Considering the possibility of omitting the disclosure requirement under E2-6, "Expected financial effects of pollution-related risks and opportunities", Abertis opts to adhere to the transitional period established by the regulation, as it is currently not possible to provide all the quantitative information required for this disclosure.

Furthermore, current systems do not allow for a detailed breakdown of asset investments and operating and fixed costs associated with air pollution in the reporting period, including major incidents and deposits.

Use of phase-in provisions

With respect to topical Disclosure Requirements E1-9 and E2-6, in line with the provisions of Appendix C of ESRS 1 of the Regulation, Abertis has opted to avail itself of the transitional period, since it is not currently possible to provide all the quantitative information needed to meet those requirements.

The phase-in provisions of Appendix C of ESRS 1 have been applied for the following disclosure requirements: ESRS E1-9 Anticipated financial effects from material physical and transition risks and potential climate-related opportunities and ESRS E2-6 Anticipated financial effects from pollution-related impacts, risks and opportunities.

Policies related to own workforce

Abertis has implemented a comprehensive set of people management policies that apply to all Group employees. These policies ensure respect for workers' rights, with a particular focus on professional development, remuneration and contractual conditions, equal opportunities, well-being, occupational health and safety, and fostering social dialogue. The policies aim to prevent and mitigate potential negative impacts while enhancing positive impacts on employees.

Human Resources Policy

Scope: All Group employees

Key content:

• Lays down basic guidelines for people management within the organisation
• Ensures employees possess the knowledge, skills, motivation and values needed to achieve the Group's objectives
• Fosters and promotes an environment that encourages personal responsibility in development and continuous improvement
• Equips employees with skills necessary to perform their roles with maximum efficiency and effectiveness
• Promotes continuous learning to prepare employees for future growth, both personally and professionally

Diversity, Equality and Inclusion Policy

Scope: All Group employees

Key content:

• Reflects commitment to diversity, equality and inclusion principles
• Promotes an equitable and inclusive work environment through recruitment, promotion and training practices based on merit and respect for individual uniqueness
• Prevents any type of discrimination
• Results in a positive impact by fostering a diverse and engaged workforce, improving employability and well-being
• Ensures equal opportunities through professional development, promotion and compensation practices that value knowledge and skills
• Evaluates objectives and performance based on principles of equality and non-discrimination
• Recruitment processes designed to be neutral and objective, focusing on candidates' knowledge, capabilities, and skills
• Supports professionals with disabilities by promoting their integration
• Encourages collaboration across geographies and teams
• Values contributions of all employees regardless of personal or social circumstances
• Recognises generational diversity as a source of enrichment and values different races, origins and religions
• Promotes use of inclusive language in corporate communications
• Ensures a workplace free from all forms of harassment, especially those with direct or indirect discriminatory intent
• Includes commitment to integrating vulnerable groups into the workforce (e.g., Diversity Programme in Brazil focusing on LGBTQ+, persons with disabilities, race, age and gender; recruitment strategies in the United States for people of colour, persons with disabilities and war veterans)

Code of Ethics

Scope: All Group employees and stakeholders

Last updated: 2023

Key content:

• Guarantees equality and non-discrimination among individuals and stakeholders based on gender, race, nationality, religion, beliefs, age, sexual orientation, marital status, disability or any other social condition or circumstance
• Updated in 2023 to ensure that human rights due diligence is integrated across the entire organisation
• Reinforces human rights protections and extends them to relationships with business partners
• Establishes that persons in conflict of interest situations shall act at all times with loyalty and shall refrain from taking part in or influencing decisions on matters affected by the conflict

Remuneration Policy

Scope: All Group employees

Key content:

• Outlines basic principles for ensuring competitive and market-aligned remuneration programmes
• Enables the Group to attract, motivate, and retain employees
• Promotes pay equality between men and women
• Guarantees internal equity and gender parity in remuneration

Health and Safety Management System

Scope: All Group employees

Alignment with standards: International standards and local requirements

Key content:

• Adheres to international standards and local requirements
• Ensures employee protection and mitigates operational risks in the countries where it operates
• In jurisdictions lacking specific legal obligations, the company implements internal procedures to safeguard well-being and safety of all employees
• Strengthens positive impact on health and safety of all stakeholders
• Addresses risks inherent to highway operations through continuous training programmes and reinforcement of a safety culture
• Includes awareness campaigns and specific protocols for high-risk areas to contribute to accident prevention

Human Rights Policy

Approval date: 2023

Scope: All Group employees and extended to value chain

Governance: Chief Executive Officer is responsible for implementation

Public availability: Available on the corporate website

Alignment with international standards:

• United Nations Guiding Principles on Business and Human Rights (UNGPs)
• OECD Guidelines for Multinational Enterprises
• UN Global Compact
• ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy
• ILO Declaration on Fundamental Principles and Rights at Work (1998) and complementary fundamental conventions

Key content:

• Formalises Abertis Group's commitment to human rights as recognised in national and international legislation
• Defines principles of action the Group applies in carrying out due diligence
• Concerning customers and end users, committed to: (i) ensuring protection of personal data, (ii) safeguarding accessibility and people's safety, and (iii) eliminating all forms of discrimination
• Explicitly commits to rejecting any action or measure that constitutes a violation of human rights
• Group is responsible for disseminating this policy to stakeholders, including suppliers, contractors and business partners, who must extend it across their supply chains

Explicit commitments include:

• Prohibition of child and forced labour
• Prevention of violence and harassment
• Protection of health and safety of individuals and ensuring social protection for workers
• Fair and equitable employment conditions and remuneration
• Freedom of expression and association
• Diversity and inclusion
• Respect for human rights of communities, including rights of ethnic minorities and local communities
• Transparency, anti-corruption and anti-bribery measures
• Protection of the environment and natural resources
• Privacy and personal data protection

Human Rights Due Diligence Procedure

Approval date: Corporate procedure developed in 2023; Business Unit-specific procedures approved in 2024

Scope: All Business Units

Governance: Involves various departments including People, Compliance, Procurement, Internal Audit and Risk Management

Key content:

• Developed based on global risk and impact analysis on human rights across all countries where the Group operates
• Analysis considers factors such as likelihood of occurrence, stakeholders involved (internal users and customers, communities and associations, own workforce, value chain and vulnerable groups) and sector (Toll roads and AMS)
• Serves to identify main human rights risk factors in each country and the due diligence effort each risk requires
• Specifies risks linked to the Group's activities, including commercial relationships, products and services, that may have an adverse human rights impact
• Defines the Group's approach to effectively executing due diligence processes
• Establishes guidelines for Business Units on how to incorporate the Group's commitment to human rights and integrate the due diligence approach into their own governance policies and management systems
• Specifies how Business Units should use the Global Risk Map to identify and manage their own priority risks

Implementation:

• Each Business Unit tracks effectiveness of actions through qualitative and quantitative indicators to assess risks and performance
• Business Units may conduct specific verification activities (e.g., on-site checks, supplier audits) based on indicator evolution

Compliance Policy

Scope: All members of the organisation

Key content:

• Aims to define the scope of the Group's compliance framework
• Establishes roles and responsibilities of all members of the organisation in monitoring and ensuring compliance with applicable regulations
• Sets out internal control measures to detect, prevent and mitigate potential legal risks
• Defines responses to instances of non-compliance
• Includes disciplinary measures aligned with applicable labour legislation in cases of non-compliance

Sustainability Policy

Scope: All Group companies and operations

Key content:

• Cross-cutting framework that includes management of impacts, risks, and opportunities related to own workforce
• Establishes governance, strategic priorities, and commitments across environmental, social and governance areas

Ethics Channel Policy

Scope: All stakeholders including own employees

Key content:

• All Business Units have an ethics channel to receive reports and consultations from stakeholders in relation to human rights violations
• Stipulates that proposals for resolution of consultations or communications must be issued within the time limit set by law
• If legislation does not state a maximum resolution time limit, proposal must be issued within three months
• Exceptionally, this time limit may be extended where good reason is given

Personal Data Protection Internal Regulations

Key content:

• Establishes guidelines for privacy management and provides reference framework governing all personal data processing activities

Monitoring and Implementation

The policies are overseen by the Chief Executive Officer who ensures their enforcement across all Business Units. The Group's compliance model is designed to identify, prevent and mitigate risks related to violation of fundamental rights and compliance with current regulations.

No sanctions have been received from administrative or judicial bodies in relation to non-compliance affecting human rights during 2024. Additionally, there are no open cases in the OECD National Contact Point or in the BHRRC portal.

Content covered in section 7.1 Own workforce (ESRS S1) of the Sustainability Report.

Content covered in section 7.1 Own workforce (ESRS S1) of the Sustainability Report.

Taking action on material impacts on own workforce

Promoting and developing talent

Scope: Own operations
Time horizon: Long-term focus, continuously adapted to evolving needs

Abertis promotes a culture of continuous learning through diverse practices and programmes to foster professional growth. The Group is committed to fostering the development of its professionals, ensuring they possess the motivation, experience, skills, knowledge and values needed to contribute to the organisation's sustainable growth.

Key programmes and initiatives:

• Sustainability training programme: Aimed at promoting the transition to a greener, climate-neutral economy. The Group's management committee has participated in specialised sustainability training.

• Abantis Programme: Aimed at identifying and nurturing high-potential individuals within the organisation. In 2024, training initiatives focused on increasing internal knowledge on business strategy and operations, with emphasis on communication as a core leadership competency.

• Executive Development Programme: Designed to strengthen the competencies and skills of leaders in executive roles. In 2024, initiatives included:

  • Specialised sustainability training programs
  • Mentoring methodology with personalised approach
  • Transformational leadership training (coaching-based leadership, effective multicultural team management, adaptation to cultural diversity)
  • Executive Committee participated in AI training programme

• Personalised development initiatives: Including coaching and mentoring programmes, 360-degree evaluations

• Annual performance evaluation: In 2024, 99% of senior management positions, 94% of middle management positions and 64% of all other workers had annual objectives set within the framework of the Group's MBO system

• Individual career plans: To foster talent growth and engagement, focusing on competency development through tailored training

• Internal promotion: In 2024, 329 individuals (195 men and 134 women) were promoted internally, an increase of 8.9% compared to 2023. 89% of vacancies in executive positions were filled by internal talent.

• Employee engagement surveys: Conducted regularly to assess employee satisfaction and well-being. During 2024, surveys were conducted in France, Spain, Italy, Chile, Brazil, the USA, Puerto Rico, Argentina, India and the Corporation, with participation exceeding 70% in most cases (except Spain at 48% and Argentina at 72% of non-unionised employees and 9% of unionised employees).

Expected outcomes: Enhanced job quality, talent attraction and retention, increased employee satisfaction, continuous professional development, highly diverse, skilled and engaged team

Links to policy: Human Resources Policy

Knowledge management

Programme name: Connectis programme
Scope: Own operations (global across Business Units)
Time horizon: Long-term focus

During 2024, Abertis strengthened its Industrial Knowledge Management Model through three pillars:

1. Knowledge exchange networks

• New digital platform launched early 2024: 388 employees accessed the platform by year-end
• Four webinars held: "ERC Gantry Renovation Project", "RCO Branch Lines Project: A Design Optimisation Case", "Key Innovation: Where Data and AI are Leading Us" and "Management and Energy Efficiency" - total 459 participants
• Two face-to-face technical sessions: Paris (France) on Transformation Project implementing Free Flow on A13/A14, and Barcelona (Spain) on Traffic Management - total 47 participants

2. Knowledge centres

• 20 active communities of practice with 388 participants
• Address areas such as road surfaces, road safety, crisis management, tunnels and free-flow tolls
• Nine collaborations carried out with nine experts in projects for Business Units

3. Competence centres

• Mobility services competence centre expanded internationally to North America and Europe
• Participated in projects developing digital tools for satellite-based distance tolling system for low-emission zones

Overall reach: 588 individuals engaged in various Connectis activities in 2024

Employee exchange programme: Short-term programme introduced in 2023 enabling exchanges between Business Units across countries. Main objectives are knowledge transfer, professional and personal development, cross-cultural awareness and increased employee engagement.

Health and Safety Management

Scope: Own operations
Time horizon: Ongoing

Abertis' Health and Safety Management System adheres to international standards and local requirements, ensuring employee protection and mitigating operational risks.

Key actions:

• Continuous training programmes
• Reinforcement of a safety culture
• Awareness campaigns
• Specific protocols for high-risk areas
• Regular assessments to monitor and identify hazards in each job
• Training programmes on protocols for responding to extraordinary events linked to climate change

Coverage: Health and Safety Committees cover 82.3% of direct employees and 72.6% of indirect employees

Expected outcomes: Accident prevention, robust safety culture across all organisational levels

Links to policy: Health and Safety Management System aligned with international standards

Human Rights Due Diligence

Scope: Own operations and value chain
Time horizon: Ongoing (developed under 2022-30 Sustainability Strategy)

In 2023, the Group developed its Human Rights Policy and Due Diligence Procedure. In 2024, the Corporate Human Rights Due Diligence Management System was implemented, based on a global risk and impact analysis across all countries where the Group operates.

Key elements:

• Global Risk Map to identify and manage priority risks
• Each business unit responsible for tracking effectiveness through qualitative and quantitative indicators
• Business Units may conduct specific verification activities (e.g., on-site checks, supplier audits)
• Analysis considers likelihood of occurrence, stakeholders affected (own employees, value chain workers, customers, communities, vulnerable groups) and sector of activity

Links to policy: Human Rights Policy, Human Rights Due Diligence Procedure

Ethics and Compliance

Scope: Own operations and stakeholders
Time horizon: Ongoing

Key mechanisms:

• Ethics channel overseen by Ethics Committee, operating under principles of integrity, confidentiality, objectivity and fairness
• Enables employees, third parties and stakeholders to report potential violations or irregularities
• In 2024: 247 reports received; 92 open at year-end, rest closed with specific actions applied

Links to policy: Code of Ethics, Compliance Policy

Note on resources: The company states that "Currently, the company's systems do not differentiate between operating expenses (OpEx) and capital expenditures (CapEx) for each action." No specific financial allocations are quantified for the above actions.

Targets related to own workforce

Abertis has set specific targets related to its own workforce aligned with the 2022-30 Sustainability Strategy, the 2022-24 ESG Plan and the 2024-27 ESG Plan, and linked to variable remuneration schemes.

Occupational Health and Safety

Target description: The Group sets specific occupational health and safety improvement objectives for all regions where it operates. New indicators have been introduced:

• Work Zone Intrusions
• High-Risk Incidents (defined as situations that, under certain circumstances, could have resulted in a serious injury or even a fatality)

Scope: All regions where the Group operates

Approach: Implementation of preventive measures and critical risk assessments in collaboration with expert safety providers to identify risk factors on motorways that could lead to serious accidents. An action plan will be developed with concrete measures to mitigate these risks.

Note: Specific quantified targets, baseline years, and target years are not disclosed in the excerpts provided.

Gender Pay Gap

Target metric: Gender pay gap at all levels of responsibility

Target value: Ensure that any unjustified differences do not exceed 5%

Scope: Each Group company

Target type: Absolute threshold

Approach:

• Clear and objective criteria for determining employee compensation
• Annual salary analysis to identify and quantify existing gender disparities
• Specific action plans designed and implemented for each company
• Periodic monitoring to assess impact and apply corrective adjustments

Note: Baseline year, target year, and current progress values are not disclosed in the excerpts provided.

Indirect Employee Safety Measurement System

Target description: Establishment of a measurement system to monitor accidents involving indirect employees to standardise data reporting across all Business Units.

Objective: Significantly reduce injuries that result in lost working time

Scope: All Business Units

Note: This objective is not explicitly included in the 2025-27 ESG Plan. Quantified targets, baseline years, and target years are not disclosed.

Employee Engagement Survey

Target description: Direct employee engagement survey conducted every two to three years, measuring the Trust Index (level of trust employees have in their teams and the organisation).

Objective: Foster a more engaged and cohesive workforce

Scope: All employees across the Units

Approach: Results are analysed to develop actionable and specific plans that are monitored to ensure progress and impact.

Note: This objective is not included in the ESG Plan. Quantified targets, baseline values, and target values are not disclosed.

Characteristics of the undertaking's employees

Total headcount and FTE

At 31 December 2024, the Group's total workforce consisted of 12,325 own employees. The average equivalent workforce for the year was 12,009. Both figures are slightly higher than the previous year, primarily due to perimeter changes.

The mechanisms for collecting and preparing the information are standardised across all Group units, using consistent formats that enable data consolidation. Data collection by the Business Units is conducted through their respective payroll systems. The calculations take into account the definitions of the characteristics of direct employees that are regulated by the national legislation of each country.

Evolution of the number of employees at 31 December and annual average workforce by country

Headcount by contract type and gender

Permanent contracts are the norm in the Group, covering 99% of direct employees in 2024 (99% for men and women alike), very similar to the previous year, with practically the same distribution in all the countries.

No employees are engaged under zero-hours contracts.

Evolution of total employees by contract type and gender (at 31 December)

Note: No unreported or other genders have been self-declared by direct employees.

Number of permanent and fixed-term contracts by age group and country (at 31 December)

Headcount by employment type (full-time/part-time)

The distribution of own employees by working hours has remained consistent compared to the previous year, with the vast majority working full-time — 97% of men and 93% of women. Employees with part-time hours are primarily in non-management roles. Employee benefits offered make no distinction based on the type of working hours of the employee.

Number of employees by working hours, gender and country (at 31 December)

Note: No unreported or other genders have been self-declared by direct employees.

New hires

New hires in 2024 totalled 2,407, an increase over the previous year. There are no major differences between the percentage of men (53%) and women (47%) among the year's new hires. The percentage hired under permanent contracts (84%) is higher than the previous year (79%). Of the new hires with permanent contracts, 54% are men and 46% women.

Number of employee new hires per year by contract type, gender and country

Note: No unreported or other genders have been self-declared by direct employees. No employees are engaged under zero-hours contracts.

Employee turnover

The minimum notice period is 30 days in most countries except France (60 days), Italy (1 day), India and AMS (90 days), Puerto Rico (7 days) and the Corporation and Mexico (15 days).

In 2024, 2,377 people ceased working with the group. The number of dismissals came to 699, up 1% compared to the previous year. Of these dismissals, 97% involved employees in the non-management category, 55% involved men and 59% involved individuals aged 30 to 50. Brazil and Chile accounted for 74% of the year's dismissals.

Annual employee turnover by gender

Absenteeism

The absenteeism rate is 1.9% overall. This rate considers only unapproved absences, i.e., hours during which an employee was expected to be at work but was not. In 2024, these unapproved absences totalled 449,285 hours, an increase compared to the previous year.

Non-employee workers (indirect employees)

At 31 December 2024, the number of indirect employees totalled 19,239, a 47% increase compared to 2023, largely due to improved data collection.

This category comprises individuals working within Abertis's business activities but who do not have a direct contractual relationship with the company. Instead, these individuals are employed by suppliers, contractors, subcontractors or other third parties with a commercial relationship with Abertis. These workers are engaged mainly in on-road activities, maintenance and conservation, gardening, cleaning, road support and user assistance, among other activities. In most cases they work under fixed-term contracts with the external contractor.

Characteristics of non-employees in the undertaking's own workforce

Total non-employee workers

At 31 December 2024, the number of indirect employees totalled 19,239, a 47% increase compared to 2023, largely due to improved data collection.

This category comprises individuals working within Abertis's business activities but who do not have a direct contractual relationship with the company. Instead, these individuals are employed by suppliers, contractors, subcontractors or other third parties with a commercial relationship with Abertis.

Types of work performed

These workers are engaged mainly in:

• On-road activities
• Maintenance and conservation
• Gardening
• Cleaning
• Road support and user assistance
• Other activities

In most cases they work under fixed-term contracts with the external contractor.

Methodology

The mechanisms for collecting and preparing the information are standardised across all Group units, using consistent formats that enable data consolidation. Each Business Unit collects this data based on information provided by external companies.

Note: The disclosure confirms coverage of "employees and regular non-employee workers" distributed across countries where the organisation operates. Regular non-employee workers are included in workforce representation mechanisms in all countries except Brazil (where industry-specific unions exist but not specific works councils representation), Puerto Rico and the United States (where worker representation is not recognised in the legal framework).

Collective bargaining coverage and social dialogue

Coverage of collective bargaining agreements

All activities and countries, with the exception of motorways in India and Puerto Rico, have collective bargaining agreements covering 81% of the workforce, a figure similar to that of the previous year.

Social dialogue arrangements

The 36 works councils and 88 employee representatives took part in a total of 164 meetings, slightly fewer than the previous year, while the number of works councils and number of employee representatives are similar.

Abertis also has a European Works Council, which meets annually in order to respond to the information and consultation rights of the employees of the Business Units in the European countries.

Country-by-country breakdown

Workers' representation context

Representation of workers is common in all countries except Brazil, where it does not exist as such but consists of a series of industry-specific unions that are not specifically represented in the organisation through works councils, and Puerto Rico and the United States, in which worker representation is not recognised in the legal framework.

Health and Safety Committees

Abertis has Health and Safety Committees in all the countries where it operates, covering 82.3% of its own employees workforce (a decrease of 2% from the previous year) and 72.6% of its indirect employees. In 2024, these committees met 243 times, a slight decrease compared to the prior year, with the number of meetings varying by activity and country, ranging from a minimum of 4 meetings in ERC and Corporation to a high of 91 meetings in Brazil.

Data limitation

This year, Abertis does not have information on the percentage of direct employees working in establishments where workers are represented by union representatives. However, the company is committed to improving data collection on this matter and will include it in next year's report.

Diversity metrics (S1-9)

Direct employees are 59% men and 41% women, the same percentages as the previous year. Moreover, 32% of senior and middle management positions are held by women and 83% of senior management positions are filled from the local community, percentages similar to those of the previous year.

Gender split by professional category and country (at 31 December 2024)

Percentages represent women in each category

Age band distribution of total workforce by country (at 31 December 2024)

Age band distribution summary (31 December 2024):

• Under 30 years old: 16% of employees
• 30 to 50 years old: 57% of employees
• Over 50 years old: 27% of employees

The proportion of employees under 30 has slightly increased, while those aged from 30 to 50 have decreased compared to the previous year.

Board and senior management diversity

Regarding the average remuneration of board members and senior managers, in accordance with Article 25 of Abertis' Bylaws, directorships are unpaid, except for the office of CEO. Therefore, during 2024 (as in 2023), no remuneration was paid by board members for their directorships, and only the CEO received remuneration.

Average remuneration by gender (2024):

*No unreported or other genders have been self-declared by direct employees.

Adequate wages

Abertis remunerates all its employees in accordance with market remuneration practice in all the countries in which it operates.

Benchmark used

Abertis benchmarks wages against statutory minimum wage in each country of operation. All of the Group's Business Units pay their employees above the statutory minimum wage. In Italy, where there is no statutory minimum wage, remuneration is mainly regulated through sector collective bargaining between unions and business associations.

Coverage and performance

The disclosure covers all countries where Abertis operates (France, Spain, Chile, Mexico, Brazil, USA, Puerto Rico, Argentina, India, and Other).

In each of the companies, the lowest salary does not include apprentices and trainees, and includes both the base salary and any guaranteed fixed payments.

Annual entry wage of own employees as a percentage of the statutory minimum wage:

All employees are paid above the statutory minimum wage in their respective countries.

Methodology

The percentages shown were obtained from the values reported by the different business units. The calculation is based on entry-level wages (excluding apprentices and trainees) compared to the statutory minimum wage or, in the case of Italy, sector collective bargaining agreements.

The total annual compensation ratio is affected by the difference between wage levels in Spain and in certain other countries in which the Group operates, where the proportion of lower-paid operating jobs is higher, as is the case in Brazil, Mexico and Argentina.

Living wage benchmark

No living wage benchmark (such as Fair Wage Network, WageIndicator, Anker Methodology, or similar) is disclosed. The disclosure focuses exclusively on compliance with statutory minimum wages and market remuneration practices.

Social protection

The Group's companies ensure that all employees are enrolled in social security programmes as mandated by local legislation and applicable agreements.

Additionally, the companies have contracted life and/or accident insurance policies with various insurance providers for own employees, offering coverage for death and disability in accordance with market practices in each country.

Parental leave and family-related leave

In all countries where Abertis operates, employees are entitled to access paid leave for situations such as maternity and paternity (in some countries exceeding the legally established number of days), as well as serious accidents or illnesses of a family member, with or without hospitalisation.

In Puerto Rico, employees can take voluntary leave to care for dependent persons, while in the corporation, this right extends to cases of collaboration with NGOs or further studies.

Unemployment protection

In relation to unemployment benefits, in all countries where Abertis is present, with the exception of India, there are unemployment insurance systems that offer temporary economic support to workers dismissed without cause, financed by contributions from employees and employers or by the State.

Retirement benefits

Abertis also promotes the implementation of private retirement plans in its Business Units as an additional layer of protection to complement the social security benefits in each country, ensuring coverage for all employees.

Note: The company describes qualitatively that coverage exists across all areas (sickness, parental leave, unemployment, retirement) but does not provide specific percentage coverage metrics by protection type or country.

Persons with disabilities

Abertis is committed to maintaining an inclusive work environment that fosters the professional development of all people, complies with the quota of employees with disabilities in those countries where so required by law. The definition of a person with a disability is taken from each country's law.

These quotas are achieved through direct hiring of individuals with disabilities or through alternative measures such as procuring goods or services from special employment centres that provide work for this group.

In all countries where it operates, Abertis either has recruitment and selection procedures in writing and implemented that include a commitment to non-discrimination, or it otherwise complies with the provisions of the country's legislation on the rights of people with disabilities.

Notably, the corporation has renewed its Bequal Plus50 certification for the third consecutive time, recognising it as a socially responsible company for disability inclusion. Additionally, it continues to maintain the 'Iguales' programme, which provides free advisory services to all employees on matters related to disability.

Employees with disabilities

In 2024, the Group employed a total of 315 own employees individuals with disabilities, representing 2.6% of the total workforce (184 men and 131 women), a figure similar to the previous year.

Methodology

Definition: The definition of a person with a disability is taken from each country's law.

Compliance approach: Quotas are achieved through:

• Direct hiring of individuals with disabilities
• Alternative measures such as procuring goods or services from special employment centres that provide work for this group

Training and skills development metrics

Training hours summary

In 2024, a total of 349,449 training hours were delivered across the organization, distributed as follows:

• Executive positions: 2,760 hours
• Middle management: 29,625 hours
• Other workers: 317,064 hours

The average training per employee was 29.10 hours, representing an increase compared to the previous year.

The Group invested EUR 4.1 million in training, 29% more than in 2023.

A total of 35,386 hours were devoted to sustainability and human rights training.

Average training hours by gender

Average training hours by gender and country

No unreported or other genders have been self-declared by direct employees

Average training hours by employee category and country

Performance and career development reviews

During 2024, the following percentages of employees were assessed under the Group's management by objectives (MBO) system:

• Senior managers: 99%
• Middle managers: 94%
• Other workers: 64%

Overall, 66% of the workforce (66% of both men and women) participated in an MBO programme.

Performance review coverage by gender and employee category

Health and safety metrics

Coverage of health and safety management system

70.3% of Abertis' turnover is derived from businesses that have an Occupational Health and Safety (OHS) Management System in place aligned with international standards such as ISO 45001. These systems, along with operational oversight in Business Units without formalised systems, facilitate the management and monitoring of workplace accident indicators and the implementation of preventive and safety measures.

Abertis has Health and Safety Committees distributed throughout the countries where it operates, covering 82.3% of the organisation's own employees (2% less than the previous year), as well as 72.6% of the indirect employees.

Fatalities

In 2024, two own employees (one in France and one in Mexico) and five indirect employees (two in Mexico, two in Brazil, and one in India) lost their lives.

Employee fatalities per year by gender:

Recordable work-related accidents and rates

During 2024, the total number of hours worked was 22,385,324 (13,245,212 for men and 9,140,112 for women). In that same period, there was a total of 265 recordable accidents involving direct employees. Of this total, 68% involved men.

The overall recordable accident rate is 11.8 (13.7 for men and 9.2 for women). Lost time accidents totalled 196, having fallen in most countries.

In 2024, there were two high-severity accidents among our own personnel in Italy and Mexico.

The incidence rate for direct workers is 16.3 points, down 2% compared to the previous year, while the frequency rate is 8.8 points, down 5%. The severity index is 0.8 points, decreased by 42%, mainly due to the reduction of accidents resulting in fatalities and the reduction of days lost due to work accidents in Mexico, Argentina and France.

Annual recordable accident rate by gender:

Annual frequency rate by gender:

Indirect employees:

The total number of recordable accidents and accidents resulting in sick leave totalled 316 cases and 240 cases, respectively, 24.4% and 52.9% higher than in the previous year. For indirect employees, the ratio of recordable accidents was 6.6, the severity ratio was 1.2 and the frequency index was 4.5, all of which excludes Argentina, as the number of hours worked by indirect employees is not available for that business.

Days lost

The total number of workdays lost by direct employees due to fatalities, job-related diseases and workplace accidents during 2024 was 17,761 (14,029 for women and 3,732 for men), of which 12,000 were due to fatalities, 155 to job-related diseases and 5,606 to workplace accidents.

Annual severity rate by gender:

Note: The severity index is calculated assuming 6,000 days for each death and the actual days lost due to occupational illness.

Work-related ill health:

A total of 10 cases of occupational illnesses were reported, all in France (four women and six men).

Methodology

These rates are calculated in accordance with international standards. The accident rate is the ratio of the number of lost time occupational accidents to the average workforce for the year, multiplied by one thousand. For the frequency rate, the ratio of the number of lost time accidents to the total number of hours worked is multiplied by one million. The severity rate is calculated as the ratio of days lost as a result of occupational accidents (with 6,000 days assigned for each death) to the number of hours worked per year, multiplied by one thousand.

Work-life balance metrics

Parental leave metrics (2024)

During 2024, out of the total workforce, 330 employees took parental leave, 56% of whom were women. The overall retention rate reached 99% for men and 93% for women.

Annual retention rate by gender and country

No unreported or other genders have been self-declared by direct employees.

Entitlement to family-related leave

All direct employees across all the countries where the Group operates have the right to paid family-related leaves (100% entitlement).

Compensation metrics (ESRS S1-16)

Pay gap

The pay ratio of women to men reached 96.4% overall in 2024 (97.8% in senior management positions, 95.5% in middle management and 96.5% for other workers), an increase compared to 2023 in management and other workers, but a slight decrease in senior managers.

Average annual remuneration of women as a percentage of remuneration for men by job category and country:

For the first time in 2024, the gender pay gap is reported based on the gross average hourly remuneration for actual hours worked, calculated as the difference between the gross average hourly pay level of all direct employees and that of women, expressed as a percentage of the gross average hourly pay level of men:

Gender pay gap between men and women per actual hour worked:

Average remuneration by professional category and gender (2024):

Remuneration ratio

The ratio between the CEO's remuneration and the Group's median remuneration was 137.3 in 2024, compared to 87.4 in 2023. This difference is explained by a change in the calculation methodology, in compliance with the CSRD Directive, which requires the calculation to be based on the median rather than the average, as previously mandated by Law 11/2018.

It is important to note that this ratio is strongly influenced by the fact that a significant portion of the Group's workforce is located in countries with considerably lower salary levels than Spain. While the Group pays wages above the minimum wage in each country, the gap between salary levels in some countries and those in Spain remains substantial.

Methodology

To calculate the gender pay gap by category, the base salary, variable compensation and any other additional remuneration elements subject to disparity were considered. Within each Business Unit, the pay gap by category is obtained by weighting the gap observed at each responsibility level (where both men and women are present) by the proportional representation of each level within the total workforce of that category. Levels with no representation of both genders were excluded from the calculation.

The hourly pay gap methodology differs from the category-based calculation and takes into consideration the total gross remuneration of employees, including the CEO or General Manager of the business, whereas the first calculation of the pay gap did not include the CEO.

The gender pay gap within each job category can be attributed to factors directly related to the individual worker, such as their performance, length of service and employment history, as well as other factors such as the number of employees of each gender, promotions, new hires and departures, and salary differences across geographic zones within the same country.

Incidents, complaints and severe human rights impacts

Ethics Channel Reports (2024)

A total of 871 reports were received in 2024 through the Ethics Channel of Abertis Infraestructuras and other Group ethics channels:

• 247 related to potential breaches of the Code of Ethics and/or Abertis internal policies
  • 92 remain under analysis by the Ethics Committee
  • 155 concluded as true and founded, with corresponding measures taken

Note: The current Ethics Channel does not differentiate between communications from own employees and those from the activity chain/stakeholders, as there is no legal requirement for such differentiation. The Group is analyzing the convenience of including this differentiation.

Resolution Timeframe

Proposals for resolution of consultations or communications must be issued within the time limit set by law. Where legislation does not state a maximum resolution time, proposals must be issued within three months (exceptionally extendable with justification).

Geographic Distribution

• Brazil and Mexico: largest number of reports
• India and Puerto Rico: no reports
• ERC (United States): significant year-on-year increase due to rollout of Compliance Model and increased awareness

Typology of Incidents Reported

Main categories:

• Inappropriate behaviour: 28.3%
• Harassment: 10.1%
• Breach of internal policies: 6.9%
• Conflicts of interest: 6.9%
• Corruption cases: 12 reported
  • 4 determined to be founded
  • 4 contained unfounded facts
  • 4 still under analysis

Classification of Communications Received

• 33.6% not related to matters applicable to the Ethics Channel
• 27.4% categorized as "not found" (facts not founded or considered true)

Measures Applied

• 99.2% of founded breaches led to application of measures by the company
• 58.9% of measures involved sanction and/or dismissal
• 31.5% of measures involved training and awareness-raising actions

Discrimination Incidents

Reports of discrimination in 2024: 15 (mainly in Brazil)

• 5 considered unfounded
• 2 remain under analysis by the Ethics Committee
• 8 considered founded and resolved with company action

Multi-year comparison:

Fines and Sanctions

No fines or sanctions were received from administrative or judicial bodies related to discrimination issues.

No monetary amount was required for fines, sanctions, or compensation.

No compensation was made for damages resulting from communications affecting human rights.

Severe Human Rights Impacts

No cases of child labour or forced labour were detected in any Business Unit.

No open cases were reported through:

• OECD National Contact Point
• BHRRC portal

Value Chain Workers

Monitoring of suppliers has detected no incidents involving value chain workers, no fines or sanctions, and no indemnities arising from cases involving human rights issues.

Policies related to value chain workers

Abertis does not have a specific Code of Conduct for suppliers. Instead, the company applies several existing policies to value chain workers, including policies primarily designed for own workforce and specific procurement-related policies.

Sustainability Policy

• Scope: Cross-cutting framework that includes management of impacts, risks, and opportunities related to value chain workers
• Governance: Ultimate responsibility for implementation rests with the Chief Executive Officer, who ensures enforcement across all Business Units
• Public availability: Published on the Group's website (referenced in section 5.4.1)

Human Rights Policy

• Scope: Applies to value chain workers and other affected groups; encourages suppliers, contractors and business partners to formalize their commitment to human rights and extend this commitment throughout their own operations
• Key content: Establishes the Group's principles of action in human rights, in line with commitment to national and international legislation
• Governance: Each Business Unit approved its own Human Rights Due Diligence Policy and Procedure in 2024, involving departments including People, Compliance, Procurement, Internal Audit and Risk Management; ultimate responsibility for implementation rests with the Chief Executive Officer
• International alignment: Aligns with internationally recognised frameworks (detailed in Chapter 7.1)
• Monitoring: The Corporate Human Rights Due Diligence Management System was developed in 2023, based on global risk and impact analysis on human rights across all countries where the Group operates

Human Rights Due Diligence Procedure

• Key content: Defines the Group's approach to effectively executing due diligence processes; establishes guidelines for all Business Units on:
  • How to incorporate the Group's commitment to human rights and integrate the due diligence approach into governance policies and management systems
  • How to use the Global Risk Map to identify and manage priority risks and implement Human Rights Due Diligence Systems
  • How to conduct monitoring and reporting
• Scope: All Business Units; includes value chain workers among affected groups; encourages suppliers, contractors and business partners to formalize their commitment to human rights
• Governance: Implemented in 2024 across Business Units
• Monitoring: Serves as an effective mechanism for implementing the policy, enabling identification of measures to prevent, mitigate and remedy human rights impacts; advocates for periodic human rights risk assessments

Code of Ethics

• Scope: Shared with all suppliers and is mandatory; applies to all individuals directly or indirectly involved in the Group's procurement and supply activities
• Key content: Ensures strict compliance with ethical standards, applying the same level of responsibility to value chain workers as to own employees
• Note: Although Abertis does not have a specific Code of Conduct for suppliers, the Code of Ethics is mandatory for suppliers

Procurement Policy

• Development: Product of a collaborative process involving various Abertis departments
• Scope: Applies to all organizational areas involved in procurement and all Group companies
• Key content: Establishes minimum requirements based on five core principles:
  • Competition: All procurement processes must include a search for new suppliers to promote free market; relationships with strategic suppliers must be overseen by each Business Unit's Purchasing area
  • Supplier management: Build long-term relationships, ensuring contractors meet commitments; establishes mechanisms to control suppliers, particularly ensuring best practices in compliance, sustainability and human rights, while rejecting human trafficking, forced labour and child labour
  • Planning: Procurement processes must be planned in advance to optimize results
  • Efficiency: Purchasing must be conducted in accordance with principles of need, suitability and austerity
  • Control: Establishes necessary control mechanisms (committees, management tools) to ensure policy compliance and prevent risks from procurement activities
• Governance: Ultimate responsibility for implementation, oversight of procurement process and compliance assurance rests with the Chief Procurement Officer
• International alignment: Aligns with ISO 20400 for sustainable procurement, UN Guiding Principles on Business and Human Rights (Ruggie Principles), and frameworks from international organizations such as the United Nations Global Compact (of which Abertis is a member)
• Public availability: Published on the Group's website, Intranet, and Supplier Evaluation Platform
• Monitoring: Described as a living document subject to constant review and evolution

Compliance Policy

• Key content: Aims to define the scope of the Group's compliance framework; establishes roles and responsibilities of all members of the organization in monitoring and ensuring compliance with applicable regulations; sets out internal control measures to detect, prevent and mitigate potential legal risks and define responses to instances of non-compliance
• Scope: Sets out principles for supplier relations (part of the Group's Compliance Model)
• Governance: Ultimate responsibility for implementation rests with the Chief Executive Officer

Content covered in section 7.2 Workers in the value chain (ESRS S2) of the Sustainability Report.

Content covered in section 7.2 Workers in the value chain (ESRS S2) of the Sustainability Report.

Taking action on material impacts on value chain workers

Abertis assumes responsibility for ensuring that its activities neither cause nor contribute to negative impacts affecting workers throughout the value chain and allocates the necessary resources to manage these impacts. Most of the actions implemented are annual and fall within the framework of the strategy.

Monitoring mechanism for contracting companies

Description: The Group has a monitoring mechanism for contracting companies to assess whether they implement the established measures for improving working conditions and sustainability. This involves various strategies, including internal and external audits, which help evaluate compliance while proactively identifying and correcting deviations.

Scope: Value chain / suppliers

Time horizon: Annual (ongoing)

Expected outcomes: This monitoring enforces strict occupational health and safety standards for the companies working with Abertis, leading to a reduction in workplace accidents and consequently improving the physical well-being of value chain workers.

Performance: Monitoring of suppliers has detected no incidents involving value chain workers, or fines or sanctions, or indemnities arising from any cases involving human rights issues.

Preventive contractual actions

Description: Following market best practices, the Procurement areas focuses on preventive actions in several areas. These include:

• Incorporating specific contractual clauses that require compliance with labour standards
• Implementation of strict occupational health and safety regulations for contracted suppliers
• Awarding longer and more stable contracts, which not only guarantee compliance with labour rights but also have a positive impact on workers

Scope: Value chain / suppliers

Time horizon: Ongoing

2nd Edition of the Sustainable Suppliers Training Programme

Description: In 2024 Abertis participated for the second consecutive year in the 2nd Edition of the Sustainable Suppliers Training Programme, led by the UN Global Compact, Fundación ICO and ICEX. As a driving entity of this initiative, Abertis offers SMEs providing goods and services high-quality and fully free training for their workers without restrictions.

Scope: Value chain / suppliers (SMEs)

Time horizon: 2024 (second consecutive year)

Resources: Fully free training programme for suppliers' workers

Focus areas: Training in road safety and sustainability concepts. Abertis' operations require suppliers characterised by a combination of technical and administrative skills, coupled with a strong focus on safety and customer service. Workers are typically trained in engineering, technology, maintenance, operations, administration and customer care. Additionally, they must be knowledgeable about road safety regulations and sustainability, possess project management skills and demonstrate effective communication abilities.

Expected outcomes: Training in road safety and sustainability concepts has a positive impact across the entire value chain.

Local procurement promotion

Description: The Group promotes local procurement due to its connection with the regions where its motorways and operations are located.

Scope: Value chain / suppliers

Time horizon: Ongoing

Performance: During 2024, the volume of purchases from local suppliers remained very high, reaching 97.7% of the total purchases made by all the Business Units during the year.

Expected outcomes: This approach contributes to economic growth and strengthens communication and collaboration with local suppliers.

Supplier Selection, Registration, and Evaluation Standard (since 2022)

Description: Applied the Supplier Selection, Registration, and Evaluation Standard, initially introduced in 2022. Under this standard, any new supplier must register on the Supplier Risk Management Platform (GoSupply) to be appropriately monitored and classified. Supplier segmentation classifies suppliers as critical, strategic, standard and elementary, according to their level of criticality for Abertis.

Scope: Value chain / suppliers

Time horizon: Implemented 2022, ongoing application

Resources: Digital platform (GoSupply) for supplier risk management

Risk assessment criteria:

• Financial health
• Compliance
• Cybersecurity
• Occupational risk prevention
• ESG factors (minimum score 30/100 required in each of three sections: Environment, Governance, Social)
• Road safety (where applicable)

Performance: In 2024, a total of 9,007 suppliers were assessed on risk criteria, i.e., more than 88% of the Group's total suppliers.

Expected outcomes: The company uses GoSupply, a digital platform that monitors suppliers through a combination of self-assessment questionnaires and advanced data analytics, including web-based risk searches. This system detects potential risks, be they financial, environmental, legal, labour-related, human rights-related or reputational.

ESG audit campaign for critical suppliers

Description: Completion of an ESG audit campaign for critical suppliers that have already been assessed. This campaign has been rolled out in all the Group's Business Units, applying consistent criteria across all units.

Scope: Value chain / critical suppliers (all Business Units)

Time horizon: Completed in 2024

Resources: Internal and external audit resources

Focus areas: Besides carrying out supplier audits, depending on the risk level and the performance assessment, the Procurement area and other areas responsible for supplier management (Risk, Compliance, Quality, Health and Safety, Information Security, etc.) may present suppliers with proposals for improvement plans.

Human rights due diligence in supply chain

Description: The Group's Human Rights Policy incorporates key international human rights standards and explicitly commits to rejecting any action or measure that constitutes a violation of these rights. The Group is responsible for disseminating this policy to its stakeholders, including suppliers, contractors and business partners, who in turn must extend it across their supply chains.

Scope: Value chain / suppliers, contractors, business partners

Time horizon: Ongoing

Performance: During 2024, no sanctions have been received from administrative or judicial bodies in relation to non-compliance that affects human rights. Additionally, there are no open cases in the OECD National Contact Point or in the BHRRC portal.

Carbon footprint measurement in supply chain

Description: The Group's corporate Technical and Purchasing areas are managing the protocols that will enable the Group to measure suppliers' carbon footprint and extend this practice to the supply chain.

Scope: Value chain / suppliers

Time horizon: Ongoing (in development)

Digitalization initiatives

Description: Work on digitising the Group's procurement processes continued, building on previous years' achievements. Digital transformation projects include implementation of e-sourcing and electronic invoicing tools, and a budgeting tool to facilitate the digitalisation and alignment of each Group company's multi-year procurement plan.

Scope: Value chain / procurement processes

Time horizon: Ongoing

Resources: E-sourcing tools, electronic invoicing tools, budgeting tool

Expected outcomes: Achieve maximum efficiency and become an agile, competitive and innovative company.

AI in early risk assessment

Description: Implementation of new technology and innovation projects in the supply chain. In 2024, incorporation of AI in early risk assessment.

Scope: Value chain / supplier risk assessment

Time horizon: 2024 (new)

Resources: AI technology

Expected outcomes: Essential to achieve efficient, transparent and sustainable management.

Targets related to value chain workers

Abertis is committed to promoting fair, safe and equitable working conditions throughout its operational network. Recognising the importance of setting outcome-oriented targets to address negative impacts, drive positive results and manage the most significant risks and opportunities related to workers across the value chain, section "5.4.1 Strategy, business model and value chain (SBM-1)" outlines the Sustainability Strategy. This strategy includes objectives related to the value chain. The table included in that section presents the establishment of strategic objectives related to safety and quality, the supply chain and due diligence.

Human Rights Due Diligence Target

Target metric: Implementation of Human Rights Due Diligence Processes across operations

Target value: 100% of operations

Target year: Not specified

Baseline year and value: Not disclosed

Scope: Own operations (internal framework across all operations)

Type: Absolute (percentage coverage)

Validation: Internal framework

Progress to date: Not disclosed

Note: The document references strategic objectives related to safety and quality, supply chain and due diligence that are presented in a table in section 5.4.1, but the specific quantified targets are not included in the excerpts provided.

Policies related to affected communities

Abertis does not have a specific policy for affected communities. The company's approach to managing impacts on affected communities is incorporated through its Sustainability Policy and Human Rights Policy, which are described below.

Sustainability Policy

• Scope: Applies to general communities and stakeholders within the value chain, but does not specifically define affected communities; applies to all Business Units within the Abertis Group
• Key content: Incorporates management of impacts on affected communities through commitments including:
  • Reducing traffic accidents and fatalities
  • Fostering positive synergies with local communities where the Group operates
  • Ensuring equal opportunities among groups
• Governance: At least once a year, the Group publicly reports on its progress in sustainability and performance regarding material environmental, social, and governance aspects
• Public availability: Available on the Abertis website, allowing stakeholders and potentially affected groups to access information and understand steps to take in case of non-compliance
• Links to international standards: Grounded in human rights principles, aligning with:
  • United Nations Guiding Principles on Business and Human Rights (Ruggie Principles)
  • Fundamental conventions of the International Labour Organisation (ILO)
  • Principles of the United Nations Global Compact (UNGC)

Human Rights Policy

• Approval and oversight: Approved in 2023; ultimate responsibility for implementation rests with the CEO
• Scope: Applies to all Business Units within the Abertis Group
• Key content:
  • Formalises the Group's commitment to human rights recognised under national and international law
  • Defines principles of action for conducting human rights due diligence
  • Explicitly emphasises respect for the human rights of local communities
  • Outlines remediation measures for impacts, including notifying competent authorities in cases of detected violations
  • Commits to engaging stakeholders and establishing strong relationships through reporting mechanisms for complaints and grievances to address potential human rights violations
  • Focuses on inclusion of vulnerable groups
• Public availability: Available on the Abertis website for easy access by stakeholders
• Links to international standards: Adheres to:
  • United Nations Guiding Principles on Business and Human Rights
  • OECD Guidelines for Multinational Enterprises
  • UN Global Compact
  • ILO Tripartite Declaration
• Monitoring: Integration of human rights due diligence across the Group through the Code of Ethics, which was updated in 2023. Issues and serious cases concerning human rights violations affecting communities are reported, particularly non-compliance with international standards such as the Ruggie Principles, OECD Guidelines and ILO conventions

Code of Ethics

• Update: Updated in 2023
• Key content: Integrates human rights due diligence across the Group

Content covered in section 7.3 Affected communities (ESRS S3) of the Sustainability Report.

Content covered in section 7.3 Affected communities (ESRS S3) of the Sustainability Report.

Taking action on material impacts on affected communities

Overview

Actions are determined through materiality analysis to identify material impacts related to road safety and communities near motorways. These are incorporated into the 2022-30 Sustainability Strategy and three-year ESG Plans, with specific objectives for each Business Unit.

Governance and Coordination

The Institutional Relations, Communication and Sustainability area in the central offices coordinates the activities of the Abertis Foundation and the rollout of specific projects focused on:

• Road safety
• Contribution to society
• Environmental protection

The Abertis Foundation enhances the impact of economic activity on the territory in countries where Abertis operates, carrying out social action initiatives focused on:

• Road safety
• The environment
• Education and culture

Actions Implemented in 2024 (2022-24 ESG Plan)

During 2024, no actions were taken to remedy negative impacts; instead actions were pursued to mitigate and prevent negative impacts, to manage risks and to generate positive impacts.

Prevention/Mitigation of Negative Impacts and Risk Management

Social action projects with local communities to promote social and economic development in areas surrounding the motorways, as well as road safety initiatives:

Equipment Distribution and Community Support:

• Business Units in Mexico, India, Abertis Mobility Services, Argentina and Brazil distributed equipment to communities and schools, supporting education and improving quality of life

Emergency Response:

• Humanitarian aid during DANA emergency in Spain, including deployment of volunteers and equipment such as cleaning vehicles and supplies

Donation Programmes:

• Food banks (Spain)
• Blood donations (Puerto Rico)
• Toy donations (Italy and AMS)
• Vehicle donations to reintegration association (France)
• Flu vaccines (Argentina)

Fundraising Initiatives:

• Support for hospitals and associations in Spain, AMS, Mexico, Brazil, United States and Puerto Rico
• Activities include charity marathons, races, publication of solidarity books, and bottle cap collections

Community Programmes in Chile:

• Support for homeless communities
• Food network
• Family support programme for children with Down syndrome to promote inclusion

Volunteering:

• Environmental volunteering programme continued in Spain and Puerto Rico (2024), with activities focused on biodiversity protection
• Social initiatives in Mexico, Puerto Rico and Brazil

Financial Contributions:

• Cultural projects (France, Spain, Argentina, Puerto Rico)
• Education initiatives including scholarships (United States)

Scope and Integration

Value Chain Coverage:

• Downstream: Communities near highways and road users during infrastructure usage phase
• Not covered: Communities linked to the organisation's suppliers

Affected Community Types:

• Communities neighbouring the motorways (individuals/groups near infrastructure, pedestrians)
• Users (individuals using highways)
• Research institutions (bodies and associations involved in sustainable/safe mobility, culture, health research)

Link to Strategy

All actions are consistent with:

• Commitments outlined in the sustainability policy
• Objectives defined in the 2022-30 Sustainability Strategy
• 2022-24 ESG Plan objectives, primarily relating to socio-economic development of communities near highways and promotion of road safety

Resource Allocation

Resources: Financial contributions mentioned but not quantified in the excerpts. Non-financial resources include volunteers, equipment deployment, and coordination through central sustainability area and Abertis Foundation.

Time Horizon: Actions implemented during 2024 under 2022-24 ESG Plan framework, aligned with 2022-30 Sustainability Strategy (long-term).

Targets related to affected communities

Within the 2022-30 Sustainability Strategy and the ESG Plans in place, under the strategic pillar of generating synergies with the local community, two levers related to affected communities have been defined: road safety and fostering synergies with local communities.

Target 1: Fatality Rate Reduction

Target 2: Local Procurement

Additional Ambitions: Collaboration with Local Communities

The 2022-30 Sustainability Strategy does not quantitatively define the Group's ambition to increase collaboration with local communities. Projects funded by Business Units and the Abertis Foundation aim to contribute to overall objectives. One cross-cutting project in the 2025-27 ESG Plan seeks to bridge sponsorship projects through the Abertis Foundation's strategic plan for 2025-27, aiming to:

• Strengthen relationships
• Increase participation in number of projects developed
• Expand allocated budget
• Assess social impact of initiatives

These objectives are not scientific and are not measured against a specific baseline year.

Target Methodology

Targets were defined based on:

• Double materiality analysis results
• Stakeholder engagement
• Trend analysis
• Designed to reduce negative impacts, enhance positive impacts and manage material risks and opportunities

Affected communities were not involved in the establishment of these targets beyond what has been reported in the SBM-1 block.

Progress toward targets is reviewed annually by Business Units and the Institutional Relations, Communication and Sustainability department, with end-of-cycle assessments informing the next ESG Plan.

Policies related to consumers and end-users

Abertis has implemented several policies that relate to consumers and end-users, including both cross-cutting policies and specific policies addressing road safety, quality, and data protection.

Sustainability Policy

• Scope: Cross-cutting policy covering the Group and value chain
• Key content: Establishes the framework, principles and basic criteria for sustainability management across Abertis, including management of impacts, risks and opportunities related to consumers and end-users. Lays the groundwork for extending commitments throughout the value chain and systematizes their monitoring.
• Reference: Further details provided in section 5.4.1 Strategy, business model and value chain (SBM-1)

Diversity, Equality and Inclusion Policy

• Scope: All users
• Key content: Ensures that all users, regardless of age, gender, abilities or socio-economic status, have equitable access to services
• Reference: Cross-cutting policy with more information in Policies related to own workforce (S1-1)

Ethics Channel Policy

• Key content: Establishes clear guidelines to ensure transparency in interactions with users, offering products and services that respect human rights and comply with local and international regulations
• Reference: Further details in section on Channels for remedying negative impacts and channels for workers in the value chain to raise their concerns

Human Rights Policy

• Key content: Sets out the Group's principles of action in human rights through the effective implementation of a Human Rights Due Diligence System, which focuses on identifying measures to prevent, mitigate and remedy any human rights impacts caused by the Group's activities or those of its business partners, including those affecting users and internal clients
• Oversight: All Business Units have implemented an ethics channel, enabling stakeholders, including users and end consumers, to submit inquiries and communications related to human rights violations
• Monitoring: No complaints, incidents or claims have been received regarding human rights violations
• Reference: More information in Policies related to own workforce (S1-1) and Statement on due diligence (GOV-4)

Road Safety, Traffic Management and Tunnel Policy

• Scope: Mandatory for all Group companies; has an impact on consumers and end-users
• Key content: Sets out the fundamental principles of road safety, traffic management and tunnel operations to ensure efficient and effective management, minimizing the impact that various motorway incidents may have on customers and end-users. Main stakeholders were taken into account in its development.
• Approval and oversight: The company's CEO is responsible for implementing the policy
• Link to standards: The policy is supported by a Road Safety Policy Implementation Guide (published in 2023) based on standards established in ISO 39001 for Road Traffic Safety Management
• Monitoring: Operations Departments of each Business Unit are responsible for enforcing the provisions outlined in the Guide to enhance road safety management and traffic on the Group's motorways. They ensure regulations are properly communicated and made available to stakeholders through established channels in each Business Unit

Privacy Policy

• Scope: Covers all personal data processing activities related to recurring, organizational and business processes carried out within the Group
• Key content: Establishes the Group's principles and guidelines for privacy management and provides the reference framework governing personal data processing. Key objectives include ensuring compliance with national and international regulations on personal data protection, safeguarding the personal data of individuals affected by the Group's processing activities, and protecting the rights and freedoms of those individuals. Guarantees that individuals maintain control over their personal information at all times.
• Public availability: Serves as the legal basis for data processing, including video surveillance on motorways

Content covered in section 7.4 Consumers and end-users (ESRS S4) of the Sustainability Report.

Content covered in section 7.4 Consumers and end-users (ESRS S4) of the Sustainability Report.

Taking action on material impacts on consumers

Abertis states that necessary resources are allocated within relevant departments for impact management. The company has developed a structured approach to road safety actions across its Business Units.

Road Safety Programme

Scope: Own operations (highways and motorways managed by Abertis across multiple countries)

Time horizon:

• Infrastructure-related actions: Permanent timeline (implemented in 2024 with no set end date)
• Collaboration initiatives and awareness campaigns: Annual timeline (reviewed and adapted each year)

Process: Actions are classified into two categories:

1. Infrastructure-related actions (construction or investment projects)
2. Collaboration initiatives or awareness campaigns

The definition process follows: (1) investment analysis to identify high-accident sections, (2) assessment of common accident types to design targeted action plans, (3) evaluation of effectiveness in reducing accident rates.

Targeted impacts: Prevention and mitigation of accidents, risks from motorist migration to other roads, and reputational harm.

Country-Specific Actions (2024)

Chile:

• Coordinated actions with administration to reduce presence of homeless individuals near highways
• Highway R-68: Renovations of ventilation systems and equipment in tunnels

Mexico:

• Installation of safety barriers in high-accident zones (positively impacted accident severity, reducing fatalities)

Brazil:

• Installation of speed control radars
• Construction of three pedestrian bridges
• Commissioning of the Florianópolis Bypass (major project to alleviate congestion and reduce accidents)

India:

• Partnerships with police authorities to detect motorcyclists riding without helmets
• Continued collaboration with UNICEF on road safety education in schools near highways

European countries:

• Innovation initiatives to prevent and detect potential accident-causing situations

All countries:

• Continuous improvements in signage, mechanical assistance and medical emergency services
• Road safety awareness campaigns targeting issues identified through driver behaviour observatories
• Operational plans for adverse weather conditions (winter, flooding, fires, hurricanes)
• Action plans for motorways with tunnels (periodic tunnel incident drills conducted)

AWAI Mobile Application

Description: Free app enabling drivers to pay tolls automatically, evolving into comprehensive mobility tool

Features: Safety alerts, traffic recommendations, route information

Expected outcomes: Service excellence and achieving zero traffic fatalities

Resources allocated: Not quantified in financial or non-financial terms. The company states "necessary resources are allocated within the relevant departments" but does not specify amounts, FTE, or partnerships beyond those mentioned in country-specific actions.

Targets related to consumers and end-users (S4-5)

Road Safety Target

Target metric: IF3 mortality rate (fatalities per 100 million kilometres travelled)

Target value: 20% reduction

Target period: 2022-24

Baseline year: 2021

Baseline value: Not disclosed

Type: Intensity-based (fatalities per 100 million kilometres travelled)

Scope: Group-wide operations. Countries with greatest weight in terms of number of victims are Brazil, Mexico and India.

Validation: Based on internal expertise and specific circumstances of each country. Takes into account internal projections, stakeholder input, studies from public administrations and concession contracts (which in some cases include specific road safety targets). Aligned with United Nations' target.

Progress to date (2024):

• IF3 reading for 2024: 1.3
• Decrease of 4% with respect to 2023
• Mexico: reduction of 15% vs 2023
• India: reduction of 17% vs 2023
• Brazil: increase of 4% vs 2023
• Total Group-wide fatality count: 1,004 (0.4% lower than previous year)

Note: This objective has remained unchanged during the three-year period. The fatality evolution indicator, along with the IF1 hazard indicator (accidents with casualties per 100 million kilometres travelled), is used by Business Units to evaluate effectiveness of infrastructure improvements.

Quality and Customer Service Objectives

Qualitative targets established annually for all geographic areas:

• Enhancing corporate image through communication plan highlighting highways as high-quality infrastructures
• Promoting communication strategies on Road safety, sustainability, innovation, customers, compliance, equality and cybersecurity
• Reviewing and coordinating processes to deliver unified image to customers, ensuring excellent customer service at all contact points

Type: Qualitative improvement targets

Scope: All geographic areas of operation (Autopistas)

Validation: Internal targets based on stakeholder feedback initiatives through surveys and forms

Business conduct policies and corporate culture

Abertis has established a comprehensive regulatory framework for business conduct resting on four pillars: the Code of Ethics, the Compliance Policy, the Anti-Corruption and Anti-Fraud Standard, and the Ethics Channel Policy. These policies promote an organisational culture based on ethical principles of integrity, honesty, transparency and sustainability.

Code of Ethics

Approval and oversight: Approved by the Board of Directors. Can be adapted to local needs of each Business Unit.

Scope: Mandatory for all covered persons (employees) and establishes standards of conduct for stakeholders who have dealings with Abertis Group companies.

Key content/principles:

• Adherence to ethical principles of integrity, honesty and transparency, acting in good faith
• Compliance with all applicable laws and regulations in every country where Abertis has a presence and with Group internal regulations
• Ethical conduct and regulatory compliance come before Group results
• Avoidance of conflicts of interest
• Utmost care in the processing of information
• Appropriate use and protection of company assets
• Equal opportunities and non-discrimination
• Non-retaliation for good faith reporting of breaches
• Principles related to human rights, freedom of association, rejection of child, forced or discriminatory labour, anti-corruption, anti-money laundering and counter-terrorism financing

Public availability: Available on the corporate intranet and on the Abertis website.

Link to international standards: Respects the principles of the United Nations Global Compact and has been drawn up in strict compliance with all laws and regulations in force.

Implementation and monitoring: Training offered to all employees on the Code of Ethics. All new employees at Corporation receive training. Annual declaration of compliance with the Code of Ethics required. Breaches are analysed by Ethics Committees and Compliance functions. The ethics channel (available online, by post, or email) enables reporting of potential violations, managed under principles of integrity, confidentiality, objectivity and fairness.

Compliance Policy

Key content: Defines the scope of the Abertis Group's compliance model, establishes roles and responsibilities of all members of the organisation in monitoring compliance with applicable regulations, and outlines internal control measures to detect, prevent and mitigate possible legal risks.

Scope: All Business Units.

Public availability: Available on the corporate intranet and on the Abertis website.

Anti-Corruption and Anti-Fraud Standard

Key content: Develops guidelines for fighting all forms of corruption and fraud, with special attention to:

• Public sector relations
• Conflicts of interest
• Institutional hospitality and gifts
• Representation expenses
• Facilitation and extortion payments

Scope: All Business Units can either adopt it directly or approve their own anti-corruption standards tailored to the particular characteristics of the country in which they operate.

Public availability: Available on the Abertis website.

Ethics Channel Policy

Key content: Sets out the general principles of the ethics channel and for protecting the rights of any individual who, in good faith, reports a suspected breach of applicable law or Abertis Group internal regulations through the ethics channel.

Scope: All Business Units have their own ethics channel, managed by an Ethics Committee.

Monitoring: The ethics channel is overseen by the Ethics Committee in each Business Unit. The Corporation's Compliance Area reserves the right to handle reports relating to subsidiaries that may have a significant impact on Abertis Infraestructuras or the Abertis Group. In 2024, 247 reports of possible breaches of the Code of Ethics were received; 92 are open and the rest have been closed by applying specific actions.

Three-year Compliance Plan

Key content: Aimed at monitoring business ethics and compliance with national ESG legislation applicable to Abertis and each of the Group's Business Units, with a strong focus on:

• Anti-corruption and anti-crime initiatives
• Environmental law
• Occupational hazard prevention
• Intellectual and industrial property rights
• Antitrust
• Personal and business data protection
• Promotion and development of an ethical business culture, guided by the values set out in the Code of Ethics

Implementation: Throughout 2023 and 2024, Abertis continued to strengthen its Compliance Model and worked to develop a Group-wide policy and procedure in view of the future implementation of the new Sustainability Due Diligence Directive approved by the European Union.

Human Rights Policy and Due Diligence Procedure

Approval: Developed in 2023 under the framework of the 2022-30 Sustainability Strategy. Each Business Unit approved its own Human Rights Due Diligence Policy and Procedure in 2024.

Key content: Formalises Abertis Group's commitment to human rights as recognised in national and international legislation and defines principles of action for conducting due diligence. Enables identification of measures to prevent, mitigate and remedy any human rights impacts from the Group's activities or those of business partners.

Link to international standards: Aligns with:

• United Nations Guiding Principles on Business and Human Rights (UN 2011)
• OECD Guidelines for Multinational Enterprises (OECD 2011)
• ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy
• UN Global Compact (UN 1999)
• ILO Declaration on Fundamental Principles and Rights at Work (ILO 1998) and complementary fundamental conventions

Implementation: In 2024, the Group implemented the Human Rights Due Diligence Procedure across all Business Units, involving various departments (People, Compliance, Procurement, Internal Audit, Risk Management). The procedure establishes guidelines for incorporating human rights commitment into governance policies and management systems.

Procurement Policy and Associated Standards

Approval and oversight: Ultimate responsibility for implementation, oversight of the procurement process and compliance assurance rests with the Chief Procurement Officer.

Scope: Applies to all organisational areas involved in procurement.

Key content/principles:

• Competition: All procurement processes must include a search for new suppliers
• Supplier management: Build long-term relationships ensuring contractors meet commitments with no disruptions; establish mechanisms to control suppliers, particularly ensuring best practices in compliance, sustainability and human rights; reject human trafficking, forced labour and child labour
• Planning: Procurement processes must be planned sufficiently in advance
• Efficiency: Purchasing must be conducted in accordance with principles of need, suitability and austerity
• Control: Establish necessary control mechanisms to ensure compliance and prevent risks

Link to international standards: Aligns with:

• ISO 20400 for sustainable procurement
• UN Guiding Principles on Business and Human Rights (Ruggie Principles)
• Frameworks from international organisations such as the UN Global Compact (of which Abertis is a member)

Public availability: Published on the Group's website, Intranet, and Supplier Evaluation Platform.

Implementation and monitoring: In 2024, Abertis applied the Supplier Selection, Registration, and Evaluation Standard (introduced in 2022). New suppliers must register on the Supplier Risk Management Platform (GoSupply) for monitoring and classification. In 2024, 9,007 suppliers (88% of total) were assessed on risk criteria including ESG aspects. ESG audit campaign for critical suppliers completed in all Business Units.

Artificial Intelligence Policy and Procedure

Key content: Following the adoption of the Artificial Intelligence Regulation by the European Parliament in 2024, Abertis created a multidisciplinary group bringing together compliance, privacy and information security areas to develop policies, supervision and employee training on proper use of AI tools.

Implementation: In July 2024, the multidisciplinary group conducted its first training for all Abertis Corporation employees on obligations contained in the Artificial Intelligence Regulations and proper use of AI tools by employees.

Sustainability Policy

Key content: Cross-cutting framework that includes management of impacts, risks and opportunities related to business conduct and governance. Establishes basic principles for responsible business conduct.

Link to international standards: Integrates ESG matters into the value chain and Group's growth, illustrated by establishment of ESG due diligence procedure for new acquisitions.

Risk Management and Control Policy

Key content: Provides basic guidelines for identifying main risk factors affecting the Group, establishing common risk identification and assessment methodology and systematic risk control approach to adopt measures most likely to achieve Abertis Group's objectives.

Information Security Procedure

Implementation: The rollout of the Cybersecurity Policy has been implemented in all Business Units.

Tax Policy

Key content: Aware of its fiscal responsibility and complexity of operating in various countries, Abertis tailors its tax policy accordingly. Since 2014, Abertis has voluntarily adhered to the Spanish Code of Good Tax Practices.

Guiding principles:

• Foster reciprocal cooperation with tax authorities based on good faith and transparency
• Increase legal certainty in application and interpretation of tax legislation
• Reduce litigation and avoid conflict in the tax sphere

Monitoring: Annually, Abertis voluntarily submits a Tax Transparency Report to the Spanish tax agency disclosing all relevant and significant tax-related information.

Training and Compliance Management

Training: 100% of executive positions and middle management trained in sustainability. 100% of employees trained in sustainability. 100% of stakeholders engaged with Code of Ethics. Each Business Unit's Compliance area leads anti-crime and anti-corruption training campaigns, covering 100% of risk functions. Training covers ethical values, compliance model, anti-corruption, prevention of workplace harassment, and inappropriate use of information.

Certification: ISO 37001 certification implemented in Spain, under way in rest of Group.

Monitoring mechanisms: The Audit, Control and Sustainability Committee (ACSC) supervises sustainability policies and compliance policies, including supervision of compliance systems. The Sustainability Committee acts as a governance body and knowledge-sharing space. During 2024, no sanctions were received from administrative or judicial bodies in relation to non-compliance affecting human rights, corruption or bribery.

Content covered in section 8.1 Business conduct (ESRS G1) of the Sustainability Report.

Prevention and detection of corruption and bribery

Abertis has established a comprehensive regulatory framework to prevent and detect corruption and bribery, resting on four pillars that form the corporate culture promoting ethical principles of integrity, honesty and transparency.

Group Code of Ethics

Scope: Mandatory ethical reference framework governing the behaviour of covered persons at work and in professional contexts, and creating reference standards of conduct for stakeholders who have dealings with any Abertis Group companies.

Key principles:

• Adherence to the ethical principles of integrity, honesty and transparency, acting in good faith at all times
• Compliance with all applicable laws and regulations in every country in which Abertis has a presence and with the Group's internal regulations and Business Unit rules
• Ethical conduct and regulatory compliance come before Group results
• Where applicable law and the Group's internal regulations conflict, applicable law must prevail
• Avoidance of personal situations in which the interests of covered persons come directly or indirectly into conflict with the interests of a Group company
• Utmost care in the processing of information
• Appropriate use and protection of the company's assets
• Guarantee of equal opportunities and non-discrimination
• Guarantee of non-retaliation for any consultation or report of a possible breach of applicable law or of the Group's internal rules, provided it is made in good faith

Implementation: The Code's principles are implemented through internal regulations, general policies to guide implementation of Group strategy, and operational policies and standards providing specific guidelines for execution of the Group's various activities.

Monitoring: The Group has ethics channels publicly accessible via the company's website. Each Business Unit manages its internal communications independently and has mechanisms in place for reporting potential breaches while ensuring confidentiality and protection against retaliation. A digital platform for managing ethics channels is in place for several Business Units, complying with Directive (EU) 2019/1937 on the protection of whistleblowers and, in Spain, Law 2/2023.

Training and awareness: Multiple training programmes are conducted across Business Units including:

• Corporation: All new employees receive training in anti-corruption, Code of Ethics, Advocacy Lobby, Attention and Gifts, conflicts of interest, workplace harassment, and sponsorships and donations
• ERC: Compliance training for Ethics Committee members
• A4 Holding: Anti-corruption training for all employees, directors and exposed personnel
• Arteris (Brazil): Mandatory training in anti-corruption, Code of Ethics, interaction with the public sector, conflicts of interest and data protection
• Isadak (India): Training in anti-corruption, code of ethics and compliance policy
• Argentina: Annual training on the compliance and anti-corruption model for all employees
• Metropistas (Puerto Rico): Training in anti-corruption, criminal risks, hospitality and gifts, and conflicts of interest
• RCO (Mexico): Training sessions on workplace harassment and campaigns on conflicts of interest, hospitality and gifts, use of ethics channel, and donations and sponsorships
• Autopistas (Spain): Campaigns on ethics channel knowledge, internal regulations, hospitality and gifts, and anti-corruption
• Sanef (France): Awareness-raising campaigns on ethical values and anti-corruption, and on ethics channel
• Vías Chile: Awareness campaigns on ethics and compliance and anti-corruption

Performance: In 2024, no sanctions or fines related to corruption or bribery were received from any competent authority, and no disciplinary action was taken for breaches of anti-corruption or bribery standards.

Group Compliance Policy

Content: Part of the four-pillar regulatory framework supporting the Group's governance model, designed to ensure consistent, effective implementation of the Compliance Management System.

Group Anti-Corruption and Anti-Fraud Standard

Key restrictions:

• Prohibition on directly or indirectly financing political parties, trade unions or related entities, or their candidates or legal representatives, including politically exposed persons currently in office or who left office in the previous two years (exception: related entities presenting projects aligned with sustainability objectives)
• Prohibition on directly or indirectly seeking to influence decisions of political parties, trade unions or related entities
• Requirement to refrain from participating in related lobbying groups

Note: The Group does not make any political contributions, either directly or indirectly, whether financial or in-kind, in any country or geographical area.

Cybersecurity Policy

Implementation: The Cybersecurity Policy has been rolled out and implemented in all Business Units.

Incidents of corruption or bribery

Confirmed incidents

Abertis reported zero confirmed incidents of corruption or bribery during 2024. As stated in the report: "no sanctions or fines in relation to corruption or bribery were received in 2024 from any competent authority."

Convictions and fines

No convictions or legal decisions (criminal or administrative) related to corruption or bribery were reported for 2024.

Total amount of fines paid: €0 (no fines were levied or paid for violations of anti-corruption/anti-bribery laws).

Disciplinary actions

Abertis stated that it "took no specific disciplinary action for breaches of anti-corruption or bribery standards, as there were none, so it was not considered necessary."

Number of employees dismissed or disciplined: 0

Contracts terminated

The report does not disclose information regarding the number of contracts with business partners terminated or not renewed due to corruption or bribery.

Investigation procedures and speak-up mechanisms

Abertis maintains a comprehensive compliance framework including:

• Ethics Channel: A digital platform available to employees, third parties and stakeholders to report potential violations or irregularities. The channel operates under principles of integrity, confidentiality, objectivity and fairness, and complies with EU Directive 2019/1937 on whistleblower protection.

• Ethics Committees: Each Business Unit has its own Ethics Committee responsible for monitoring compliance with the Code of Ethics, handling queries, investigating reports and proposing solutions. The Committees must adhere to principles of honour, autonomy, independence, confidentiality, objectivity and fairness.

• Reporting process: In 2024, the ethics channel tool was updated and improved. A total of 247 reports of possible breaches of the Code of Ethics were received during the year; 92 remained open at year-end and the rest were closed with specific actions applied. Of the measures applied, 58.9% involved a sanction and/or dismissal and 31.5% involved training and awareness-raising actions.

• Anti-Corruption and Anti-Fraud Standard: This develops guidelines for fighting all forms of corruption and fraud, with special attention to public sector relations, conflicts of interest, institutional hospitality and gifts, representation expenses, and facilitation and extortion payments.

• No political contributions: Abertis does not make any political contributions, either directly or indirectly, whether financial or in-kind, in any country or geographical area.

Public legal cases

No open cases were reported through the OECD National Contact Point or the BHRRC portal related to corruption or bribery.

Political influence and lobbying activities

Political engagement approach

Abertis does not, either directly or indirectly, make any political contributions, whether financial or in-kind, in any country or geographical area. The Group companies may themselves maintain relationships with political parties, trade unions and related entities in accordance with the legal system of the countries in which they operate. Such relationships may only be established by the persons within the Group who are duly empowered or authorised to do so, expressly and in writing, in accordance with their corporate activities.

Ethical standards and guidelines

The Group is prohibited from directly or indirectly financing political parties, trade unions or related entities, or their candidates or legal representatives, including politically exposed persons currently in office or who left office in the previous two years, counting from the time of leaving office. This prohibition does not apply to related entities that present projects aligned with the various sustainability objectives.

Group companies are also prohibited from directly or indirectly seeking to influence the decisions of political parties, trade unions or related entities. For this reason, they are required to refrain from participating in related lobbying groups, as indicated in the Group's anti-corruption and anti-fraud standard.

Governance and oversight

The representative or representatives in the administrative, management and supervisory bodies responsible for supervising the activities included in Disclosure Requirement G1-5 are:

• General Director of Legal Advice and Compliance
• Director of Institutional Relations, Communication and Sustainability

Political contributions

Abertis does not make any political contributions, whether financial or in-kind, in any country or geographical area.

Total political contributions (2024): €0

Lobbying expenditure

Group companies are prohibited from directly or indirectly seeking to influence the decisions of political parties, trade unions or related entities and are required to refrain from participating in related lobbying groups.

Total lobbying expenditure (2024): €0

EU Transparency Register

Abertis is registered in the EU Transparency Register under the name ABERTIS INFRAESTRUCTURAS, S.A., with identification number 934237012880-23.

Payment practices

Average payment period and contractual terms

The following table sets out the disclosures required under the Third additional provision of Spanish Law 15/2010 of 5 July, as amended by the Third final provision of Law 18/2022 of 28 September, establishing measures to combat late payment in commercial transactions:

Legal maximum payment period: The maximum payment period applicable to the Group companies with tax residence in Spain is, under Law 11/2013, of 26 July, 30 days, unless a longer period has been contractually specified, although such period must not exceed 60 days.

Scope: The payments to suppliers detailed in the table above relate to suppliers that, because of their nature, are trade creditors for the supply of goods and services and, therefore, they are included in "Trade payables" under "Payable to Suppliers and other payables" on the consolidated balance sheet.