Acerinox

The Acerinox Board of Directors is the body responsible for representing and managing the Company. This body has all the non-delegable powers established by Royal Legislative Decree 1/2010, of July 2, which approves the revised text of the Corporate Enterprises Act, as well as those established in the Regulations of the Board of Directors, including the monitoring and supervision of sustainability management at the Group, including the monitoring and execution of related policies.

In accordance with Article 19 of the Company Bylaws and Article 4.1 of the Regulations of the Board of Directors, the Board of Directors shall be comprised of a number of Directors to be determined by the General Shareholders' Meeting, between a minimum of five and a maximum of fifteen. The General Shareholders' Meeting held on April 11, 2019 set the maximum number of members of the Board of Directors should at least 40% of the total. All this has led to a progressive increase in the number of female Directors from 23.08% in 2018 to 36.4% at December 31, 2024, complying with the figure set for eleven-member Boards according to the Annex to Directive (EU) 2022/2381 of the European Parliament and of the Council of November 23, 2022 on improving the gender balance among directors of listed companies and related measures. Among the Independent Board Members, female members represent 57% of the Board.

When new vacancies have arisen, the Appointments, Remuneration and Corporate Governance Committee endeavors to ensure that the candidates include women who meet the desired profile, ensuring a non-discriminatory process with the underrepresented sex.

Pursuant to the appointments and re-elections proposed to the General Shareholders' Meeting in recent years (Ms. Rosa María García Piñeiro, Ms. Laura González Molero and Ms. Marta Martínez Alonso in 2017; Ms. Leticia Iglesias Herraiz in 2020; and Ms. Laura González Molero, Ms. Rosa María García Piñeiro and Ms. Marta Martínez Alonso in 2021), the appointment policy used by the Company demonstrates that not only are there no implicit biases that could imply any discrimination and hinder the election of female Directors, but that the Company has deliberately sought to appoint female Directors who meet the requirements of honorableness, suitability, recognized professional solvency, skill, experience, qualifications, training, availability, and commitment, which are indispensable for the proper performance of their duties.

At the behest of the Appointments, Remuneration and Corporate Governance Committee, the Board of Directors drew up and approved its own skills matrix. This document is made to serve as a mandatory guide for all Board Member selection processes and assignments to specific Committees.

In order to ensure that Directors have the necessary skills to carry out their duties properly, the Appointments, Remuneration and Corporate Governance Committee appointed the members who, in accordance with the current General Board Diversity and Director Selection Policy, meet the requirements of honorableness, suitability, recognized professional solvency, skill, experience, qualifications, training, availability, and commitment to their duties, which are indispensable for the proper performance of their duties.

The members of the Board of Directors bring together a huge range of skills, encompassing industry, sales, investment banking, and finance, as well as specialization in areas such as audit, sustainability, energy and new technologies. It is also common for directors to have previous experience on the boards of other major international companies. The criteria for assigning profiles to each Committee are similar to those of the Board.

There are no directors representing employees and other workers.

Sustainability is integrated into Corporate Governance. In this regard, various Company bodies are involved in the establishment, supervision, and management of these issues.

The Board of Directors is responsible for the Company's overall strategy. As part of this, it is responsible for overseeing sustainability-related IROs, approving the setting of targets that contribute to advancing the Group's commitment to the environment, people and society, as well as overseeing the monitoring of progress in this area. Sustainability issues are part of the decision-making process of the Board of Directors, which is regularly updated on the Group's targets and progress in these matters. For more information, see the list of material issues in Appendix 8.5. In addition, in 2024, training was provided to the Board on the contents of the CSRD and the implications at the Board level and on the Group's management and reporting.

The Sustainability Committee is the body in charge of promoting and coordinating the Company's sustainability actions in accordance with the guidelines approved by the Board of Directors, as well as proposing the adoption of any measures related to the aforementioned matters. Its duties also include implementing and monitoring the Group's Sustainability Plan, as well as reporting on this area.

The Sustainability Committee is also responsible for periodically evaluating the Group's Sustainability Policy so that it complies with its mission of promoting the corporate interest and that it considers, as appropriate, the legitimate interests of the remaining stakeholders.

The most significant activities of the Sustainability Committee in 2024 were as follows: • Monitoring of the targets defined as indicators or KPIs by the Board, the associated action plans, and the resources required to achieve them. • Monitoring of the Non-Financial Statement. • Review of ESG indicators for the calculation of senior management bonuses. • Drafting of a plan to adapt to the Corporate Sustainability Reporting Directive. • Review of sustainability policies.

The Sustainability Committee maintains direct communication with Sustainability Management, which is responsible for establishing the Group's sustainability commitment and strategy. The Sustainability Department reports, at least quarterly, on the degree of achievement of the established targets and the Company's progress on environmental matters, social impact, health and safety indicators, and aspects related to due diligence according to the initiatives implemented by the Group. This is done prior to the publication of the quarterly external reports.

The Sustainability Director is also a member of the Management Committee. This Committee is responsible for the regular review of the Company's strategy and business and investment plans, integrating sustainability into these decisions. In this way, the Sustainability Department maintains regular and direct communication with the various corporate areas that are also part of Acerinox's sustainability strategy.

The Audit Committee also acts as a supervisory mechanism in sustainability matters as it is responsible for the supervision of financial and non-financial information, as well as the Group's risk management and monitoring, which is reported on a quarterly basis. In order to ensure coordination between the two committees, the Chair of the Audit Committee is also a member of the Sustainability Committee.

The Acerinox Directors' Remuneration Policy states that the CEO's Bonus goals (variable remuneration) are linked to sustainability criteria such as safety at work, GHG emissions, diversity, and recycling. The weighting of these goals in the total computation of the bonus may not be less than 10%.

The Sustainability Committee and the Appointments, Remuneration and Corporate Governance Committee proposed that the weighting of sustainability indicators in the Acerinox Group's Senior Management variable remuneration should increase to 15% of the total by 2024 in the case of the Chief Executive Officer, the Chief Corporate Officer, the General Secretary and the Deputy Secretary General, and maintain a 10% weighting for the other members of Senior Management.

The ESG indicators used to calculate the Senior Management variable remuneration for 2024 are as follows:

a. 26% annual reduction in Total Incidents Recorded (TIR) for the Group compared with 2023, with a weighting of 50%.

b. 1.54% reduction in the Group's greenhouse gas emissions (Scope 1 and 2) compared to 2023, with a weighting of 16.6%.

c. 4.01% increase in the Group's waste recycling ratio compared to 2023 levels, with a weighting of 16.6%.

d. 0.25% increase in the number of women in the Group's workforce compared to 2023 levels, with a weighting of 16.6%.

For the CEOs of the various business units, the sustainability index is defined in the aforementioned manner, albeit with reference to the specific targets of the companies for which they are responsible.

At the beginning of FY 2025, the Sustainability Committee and the Appointments, Remuneration and Corporate Governance Committee reviewed compliance with ESG targets, which reached 59%.

The ESG indicators for calculating Senior Management bonuses are reviewed annually by the Sustainability Committee and the Appointments, Remuneration and Corporate Governance Committee, and subsequently by the Acerinox Board of Directors.

Acerinox has sustainability targets linked to environmental, social and corporate governance performance, as set out in its Sustainability Master Plan and based on international standards such as the Paris Agreement and the Sustainable Development Goals (SDGs), among others. In addition, the variable remuneration of the members of the Management Committee, including the CEO, is linked to the achievement of certain sustainability targets.

One of these targets, the reduction of CO2 emissions, is related to GHG emissions due to the Group's business model. Positive impacts on GHG Reduction are due to the implementation of measures to mitigate climate change; this comes with the risk of Loss of market share due to non-compliance with CO2 rates, Increase in costs due to non-compliance with CO2e rates and Increase in costs (CAPEX and OPEX) to meet emissions reduction targets.

Until 2023, the CO2 emissions intensity target (Scope 1 and 2) was linked to remuneration at the Stainless Steel Division. In accordance with the Sustainability Master Plan, the Company committed to reduce by 20% the intensity of Scope 1 and 2 CO2 emissions by 2030, reaching a ratio of 0.95 tCO2/metric ton compared to the 2015 value (1.20 tCO2/metric ton). Taking into account the 2023 ratio (1.07 tCO2/metric ton) and the 2030 target (0.95 tCO2/metric ton), the annual Scope 1 and 2 emissions reduction pathway has been set on a linear basis of 1.54% between 2023 and 2030.

In 2024, the reduction target for Scope 1 and 2 CO2 emissions intensity was extended to the entire Group, including the High-Performance Alloys Division. To this end, a reduction in the emissions intensity ratio of 1.54% with respect to 2023 was applied. Considering that the Group's intensity ratio was 1.088 tCO2/metric ton in 2023, the target for 2024 was 1.07 tCO2/metric ton.

The annual variable remuneration bonus is determined based on the achievement of financial and non-financial targets, such as those related to sustainability and climate change. In 2024, 15% of the CEO's bonus and 10-15% of the bonuses of the other members of Senior Management were linked to ESG targets. The CO2 emissions intensity reduction target accounts for 16.6% of the ESG targets. In 2024, the target related to climate change reached 100% compliance.

The CO2 emissions intensity ratio (Scope 1 and 2) is calculated by dividing the estimated Scope 1 and 2 emissions from the 2024 GHG Inventory by the total metric tons produced. The perimeter includes Acerinox Europa, NAS, Columbus Stainless, Bahru Stainless, VDM Metals, Roldán, and Inoxfil.

The Stainless Steel Division also has sustainable loans linked to the reduction of its carbon footprint; these are tied to a 1% annual reduction in emissions intensity (scope 1+2). The 2024 target was met as the ratio was 1.044, below the target of 1.075 tCO2eq/metric ton of production.

The due diligence approach aims to reduce the probability and exposure of the Group to risks and impacts and to seize opportunities that impact sustainable value creation. The Group takes on and promotes a series of principles that must govern its actions:

a) To understand due diligence as a continuous, dynamic process to identify and manage risks and adverse human rights and environmental impacts related to the Group's business activity and its partners in the business chain.

b) To address issues with suitable measures proportional to the severity and likelihood of the actual or potential risks and adverse effects.

c) To integrate due diligence into management systems and procedures, promoting alignment between the different internal departments.

d) To repair any actual adverse effects caused by the Company or its subsidiaries through the implementation of remediation measures proportional to the Group's degree of involvement in producing the adverse impact.

e) Collaborate with partners in the business chain to improve the effectiveness of implemented preventive or corrective action plans.

f) Establish free, accessible, and non-retaliatory complaint, participation, and consultation mechanisms for stakeholders to communicate and participate in the management of adverse effects.

g) Disclose and publicly report information on due diligence processes and measures taken to identify and manage actual or potential adverse effects, including findings and outcomes.

These principles will be taken into account in the management of IROs. They were incorporated in the development of the new Sustainability Due Diligence Policy, which was approved at the beginning of 2025; a project to establish and implement the due diligence model is now underway. This model integrates the company's existing management practices in this area. Some of the included sources of information (ethics channel, customer complaints, stakeholder consultations, etc.) have already been considered in the dual materiality analysis to identify material IROs.

Acerinox is also developing a Internal Control System over Sustainability Reporting (ICSSR) to guarantee the accuracy and integrity of the data, the availability of qualitative and quantitative indicators throughout the value chain, and the availability periods for information.

To this end, risks related to the reporting of sustainability information, which are not significant, have been identified in collaboration with the internal data owners, and a comprehensive set of internal monitoring measures will be implemented to ensure its accuracy and reliability.

The methodological approach is aligned with the three lines of defense (COSO) risk model. Key to the model is the establishment of projected roles and responsibilities to ensure and oversee compliance with the ICSSR: Board of Directors, data management and monitoring officers, internal monitoring, internal audit, etc.

The ICSSR Manual establishes the roles and responsibilities in the system's monitoring and control process, as well as regular reporting to the Audit Committee.

Strategy, business model and value chain

Products, services and key markets

The Group, headquartered in Spain, manufactures stainless steel and high-performance alloys and has a melting capacity of 3.5 million metric tons.

Its production network comprises 15 factories on three continents. The Group has five factories in its Stainless Steel Division:

• Three integrated flat product factories:
  • Acerinox Europa (2,364 employees)
  • North American Stainless (1,688 employees)
  • Columbus Stainless (1,319 employees)
• Two long product factories:
  • Roldán (350 employees)
  • Inoxfil (100 employees)

The Group's High-Performance Alloys division (a world leader in this sector) is made up of:

• VDM Metals (2,074 employees)
• Haynes International (1,276 employees)

They have 10 production sites in the US and Germany.

Acerinox products have a wide range of references and are distributed through a wide sales network across more than 80 countries. The Group had 13,781 customers in 2024.

Key production figures:

• 1.7 million metric tons of stainless steel
• 78,258 metric tons of high-performance alloys steel
• €551 million in sales to customers
• €18 million in R&D&i

Significant groups of products/services

Because of their versatility, their physical, chemical and mechanical properties, and their aesthetics, the materials manufactured by the Group are used in a wide variety of sectors:

• Construction industry: products for residential and commercial buildings to infrastructure projects. Clients include manufacturers of elevators, chimneys, and ventilation systems, as well as distributors of construction materials.
• Home appliances: steel for manufacturers of appliances such as refrigerators, washing machines, and dishwashers.
• Transportation: production of components for both passenger and freight vehicles. Clients include automobile manufacturers, railroad car producers, and heavy transportation equipment companies.
• Industrial equipment: supplying the chemical, pharmaceutical, food, and paper industries.
• Steel processors: providing stainless steel to companies that transform it into value-added products like precision parts, profiles, or tubes.
• Metal products: supplying manufacturers of catering equipment, cutlery, and household goods.
• Aerospace sector: through the acquisition of Haynes International.

Significant markets and geographies

The Group operates across three continents with 15 factories:

Employees by geography (2024):

Total workforce: 9,293 employees

Acerinox distributes products through a sales network across more than 80 countries.

Revenue by significant ESRS sustainability matter

No breakdown of total revenue by specific ESRS sustainability matter was disclosed in the excerpts.

Sustainability-related goals embedded in the business model

The Group's integrated business vision is set out in the Strategic Plan 2021-2025. The plan is based on four pillars:

1. Excellence (LEADER): Engine to boost the Group's competitiveness
2. Added value (PREMIUM): Shift in sales mix towards high value-added stainless steels and high-performance alloys
3. Sustainability (KEY): Business model center and value-added driver
4. Financial Strength (EFFICIENT): Responsible and transparent capital allocation throughout the cycle

The Group's vision is to become a supplier that responds to present and future needs by offering the widest selection of materials and solutions. Acerinox efficiently manufactures stainless steels and high-performance alloys with an environmentally-friendly approach that takes into account the needs of the value chain.

360º Positive Impact Master Plan - 5 strategic lines:

1. Ethical, responsible, and transparent governance: promote the development of a responsible and transparent management model and solid corporate governance, with a sustainable and long-term vision.

2. Eco-efficiency and climate change mitigation: establish commitments and objectives in climate change mitigation and develop an action plan to achieve them that includes energy efficiency measures.

3. Circular economy and sustainable product: integrate circular economy processes into all operations by driving the development of sustainable and low-emission products.

4. Committed team, culture, diversity, and safety: strengthen the alignment of people with the values of Acerinox, boosting their commitment to sustainability, promoting equality, the development of talent and the improvement of the climate, guaranteeing safety, health and well-being.

5. Supply chain and societal impact: manage the supply chain responsibly and be a company recognized for its commitment to local society and creating positive community impact.

2024 transformational changes:

• Completed acquisition of Haynes International (USD 799 million), an American high-performance alloys company with extensive exposure to the aerospace sector
• Sale of Bahru Stainless (Malaysia)
• New collective bargaining agreement at Acerinox Europa
• Launch of EcoACX® product
• New decarbonization plan

Haynes acquisition benefits:

• Reinforcement of Acerinox's leading global position in the high-performance alloys segment
• Expanding presence in the US
• Increased significant opportunities in the aerospace sector
• Initial estimated synergies of USD 71 million
• USD 200 million investment over next four years in the US platform

Description of upstream and downstream value chain

Value chain stages:

1. SUPPLY: Raw materials from suppliers; Transport of raw materials to factories; Workers in the value chain

2. STORAGE: Warehouses; Own workforce

3. MANUFACTURE: Stainless steel manufacture; High-performance alloys manufacture; Research and development; Own workforce

4. DISTRIBUTION AND SALES: Distribution of finished product; Marketing; Customer handling; Management of customer needs and expectations; Workers in the value chain; Own workforce

5. AFTER-SALES SERVICE AND RECYCLING: Maintenance; Quality and safety; Waste management; Circular economy; Own workforce

Supplier categories:

The Group's supply chain is divided into:

• Direct procurement: raw materials used in the manufacture of the final product (scrap, ferroalloys, and other elements)
• General procurement: all services and materials necessary for the manufacturing process (chemical products/acids, packaging materials, energy, transport services, etc.)

In 2024, the Group had 7,335 active suppliers, with EUR 4,396 million in expenditure on suppliers.

Customer types:

Customers serve as intermediate links in the value chain, transforming or distributing products before they reach the final consumer. They include:

• Manufacturers in various sectors (construction, appliances, transportation, industrial equipment)
• Distributors who purchase, store, and distribute products to their own clients
• Steel processors who transform steel into value-added products

Key inputs and outputs

Key inputs:

Recycled materials used in production (2024):

Acerinox uses secondary materials such as scrap, reaching figures close to 90% of recycled material as inflows to the process.

Virgin materials used in production (2024):

Other key inputs:

• Energy: 5,166,010.67 MWh total energy consumption (79% fossil, 20% renewable, 1% nuclear)
• Water: water consumption in production processes (specific volumes not disclosed in excerpts)

Key outputs:

• 1.7 million metric tons of stainless steel
• 78,258 metric tons of high-performance alloys
• €5,413 million net revenue (2024)
• Employment for 9,293 employees
• €671 million on salaries
• €501 million in taxes
• €155 million in dividends
• €980 million in investments in non-current assets
• Waste generation: 82.29% recycling ratio achieved in 2024 (target: 90% by 2030)

Stakeholder dialogue and communication was conducted both through online surveys (questionnaires for employees, customers, suppliers and investors, and voting advisors) and interviews (the format used for dialogue with Company senior managers and directors).

Listening results are reported to the Board of Directors. It was not thought necessary to change this strategy or the business model in 2024.

In the dual materiality analysis, all sustainability aspects with significant relevance for the Group were identified and evaluated. Included in the 2024 list of material impacts, risks and opportunities are those related to climate for the Company's own operations. For more information on the materiality process, see the Result of the dual materiality analysis section in the 7.1 General disclosures chapter.

The following table shows climate-related impacts, risks, and opportunities and their categorization as physical or transitional climate risks, according to the Task Force on Climate-Related Financial Disclosures (TCFD) methodology. The IPCC scenarios for physical risks were taken into account in the climate risk analysis. For transition risks, the International Energy Agency's Stated Policies Scenario (STEPS) and Sustainable Development Scenario (SDS) scenarios were evaluated.

Acerinox manages significant IROs associated with climate change mitigation and adaptation at all levels of the organization. For example, in the Sustainability Master Plan, which sets targets for the most significant climate-related IROs: energy, emissions and water use.

With respect to the last point, the Group has calculated its water footprint and is currently working on various projects to improve the efficiency of its water consumption.

In the process of reviewing and updating the decarbonization plan, no significant changes were identified in the business model or in the company's assets, demonstrating the company's resilience to climate change.

The Group's climate change management model identifies and assesses the impacts of our operations on climate change following TCFD recommendations. The Greenhouse Gas (GHG) emissions inventory, conducted annually, uses methods consistent with internationally recognized standards. The carbon footprint is certified by an external verifier.

In 2024, Acerinox reviewed its activities to determine future sources of GHG emissions. In addition to calculating the carbon footprint of the factories, an estimate was made for the service centers, warehouses and sales offices. The results concluded that these emissions are not significant, as they account for less than 2.5% of the total emissions.

Scope 3 categories not previously included in the GHG inventory were also estimated, and those that were material were reported.

In 2024, the Group's total GHG emissions (Scopes 1, 2 and 3) were 6,374,512 metric tons of CO2 equivalent, 13% higher than the previous year carbon footprint, mainly as a result of the increase of emissions associated with the acquisition of materials and ferroalloys and the consideration of new reporting categories.

Corporate risk analysis analyzes short-term climate risks. The time horizon refers to the period adopted by the company as the reference period in its financial statements. The medium-term horizon (2030) is aligned with the term of the Sustainability Master Plan and its targets, while the long-term horizon (2050) is linked to the climate neutrality targets set by the most ambitious geographical area (European Union).

Climate change impacts were identified and assessed according to the methodology described in ESRS 2 SBM-3 on climate change.

The impact of climate risk on the Group's financial statements is structured into three main areas: analysis of the recoverability of non-financial assets, determination of the useful lives of plants and equipment and credit ratings. Due to Acerinox's structure and business model, at the end of this year (short term), no material impacts related to climate change have been identified; accordingly, it is considered that there is no material impact of climate change risk that should be considered in future estimates for the calculation of cash flows.

In the medium and long term, climate risk analysis using different scenarios helped us to better understand our risks and make better decisions.

In 2025, the climate risk analysis will be updated, incorporating risks related to the value chain; Haynes International will also be included.

Physical risks

Two scenarios were selected from the Intergovernmental Panel on Climate Change (IPCC): • SSP5-RCP 8.5: High emissions scenario, with a business-as-usual perspective. It forecasts that carbon dioxide emissions levels will triple by 2075, with global temperatures rising by 4.4°C. • SSP 1-RCP 2.6: Low emissions scenario aligned with the Paris Agreement, in line with achieving net zero emissions by 2050. It forecasts global temperatures to rise and stabilize at 1.8º Celsius by the end of the century.

The difference in global emissions between RCP 8.5 and RCP 2.6 represents the implementation gap to reach the Paris Agreement's target of below 2°C.

The analysis was carried out at all the Group's factories. Site-specific climate data is extracted from each plant location for each individual climate hazard included in the CRISP platform. The analysis took into account the climate-related risks identified in the CSRD. The nine most relevant are detailed below: • Extreme heat. • Extreme cold. • River flooding. • Flooding due to extreme precipitation. • Coastal flooding. • Tropical cyclones. • Wildfires. • Rainfall-induced landslides. • Water stress and drought.

For each hazard, the platform contains a global climate indicator for the starting point and future time horizons (medium and long term).

Most physical risks take into account the duration of the risk to determine the level of criticality. The results of the climate hazards (magnitude) and degree of exposure (likelihood) are combined to calculate risk scores, which can range from 0 to 10. This allows climate hazards to be compared, determining the relative level of risk associated with each hazard.

Transition risks

The analysis was carried out using two International Energy Agency (IEA) scenarios. • Stated Policy Scenario (STEPS): provides foresight based on the latest policy measures, including energy, climate, and related industrial policies. More conservative outlook ("business as usual"), with no additional or more ambitious measures to address climate change, highlighting the risks if announced targets are not met. • Sustainable Development Scenario (SDS): aligned with the Paris Agreement, this scenario assumes that all national climate and energy sector-related targets announced by governments are met in full and on schedule.

The global emissions gap between STEPS and the SDGs represents the implementation gap that must be closed for governments to achieve their announced decarbonization targets.

Transition risks have been assessed for the Company's assets in five geographical blocks: European Union, United States, Africa, Southeast Asia, and global.

The transition risk assessment includes seven climate scenario indicators that describe the risks and opportunities associated with the transition to a low-carbon economy: • Risk: Carbon mechanisms and carbon taxes. • Risk: More stringent environmental regulations. • Risk: Changes in consumer preferences. • Risk: Transition to low-carbon technologies. • Opportunity: Increased demand for low-carbon products. • Opportunity: Energy efficiency. • Opportunity: Use of renewable or low-carbon energy.

Each indicator scores each location by combining the relevance weighting with the difference between the scenarios over the time horizons, also known as the "scenario delta." The higher the delta, the greater the difference between the scenarios and, consequently, the greater the risk. Thresholds denote high, moderate, and low risk, as well as high, moderate, and low opportunities.

The results show that transition risks are more significant for some assets depending on their location. However, no assets have been identified that are incompatible with a transition to a climate-neutral economy.

In 2020, Acerinox committed to decarbonizing its activity by implementing its Sustainability Master Plan Positive Impact 360º. One of its pillars is eco-efficiency and climate change mitigation. The Master Plan set the target of a 20% reduction in GHG emissions intensity (Scope 1 and 2) by 2030, using 2015 as the base year for the Stainless Steel Division. This was extended to the entire Group in 2024.

Among the initiatives implemented by the Group's entities to fulfill this commitment are the improvement of energy efficiency, the promotion of heat recovery systems, the electrification of systems and vehicle fleets, and the increased use of renewable energies.

In 2024, it took a further step in the transition to climate change mitigation with the creation of a Decarbonization Plan through 2030 that integrates existing and new initiatives to drive the decarbonization of operations and the value chain. It also integrates the decarbonization initiatives included in the new Beyond Excellence 2024-2026 efficiency plan, approved by the Board of Directors in 2023. The 2025-2030 Decarbonization Plan has the following pillars:

• Improvement of energy efficiency: the adoption of new technologies or machinery that allow better management of process times and more efficient management of consumption.

• Promotion of heat recovery systems from process sources: installation of recovery systems that optimize processes and allow the reuse of the heat generated at the exit of furnaces or boilers. The aim is to increase the efficiency of the recovery process and generate more steam, thus avoiding its production in gas boilers.

• Electrification of systems: replacement of machinery or boilers that use fossil fuels with others that use electricity (e.g. heat pumps).

• Electrification of the vehicle fleet: replacement of the fossil fuel fleet (company cars, vans, forklifts, etc.) with electric vehicles.

• Increased use of renewable energies and, in particular, renewable electricity: signing of green energy purchase contracts with guarantee of origin (GoO), purchase of renewable energy certificates and installation of solar panels for self-supply.

• Use of low-carbon alternative fuels: use of alternative fuels in the production process (e.g. hydrogen/natural gas mix in boilers, use of biomethane, etc.).

• Increased use of scrap: installation or expansion of scrap recovery plants, improved segregation and use of scrap.

• Increased use of low-carbon raw materials or ferroalloys: prioritization of suppliers and purchase of low-carbon raw materials or ferroalloys.

• Others.

The Decarbonization Plan has a bottom-up approach, as it is designed in collaboration with each factory's technical teams and CEOs in alignment with the factory's strategy. It is also aligned with Beyond Excellence 2024-2026, the Group's strategic plan to drive competitiveness across the board.

The Decarbonization Plan does not include climate change adaptation measures. The climate risk analysis will be updated in 2025, and an adaptation plan will be developed based on the results achieved.

The Plan and the proposed emissions reduction targets for each of the factories and at the Group level were presented to the CEOs of the factories and the Group's Chief Executive Officer. They were subsequently approved by the Board of Directors, at the proposal of the Sustainability Committee, in January 2025. The targets will be monitored regularly after approval. At least quarterly, the Sustainability Director reports to the Sustainability Committee on target evaluation.

The Decarbonization Plan sets more ambitious Scopes 1 and 2 emissions reduction targets, with the aim of being compatible with limiting global warming to 1.5°C and aligned with science-based targets (SBTi): Acerinox must reduce Scope 1 and 2 emissions by 45.28% by 2030 compared to 2021. It also sets a Scope 3 emissions reduction target of 15% for the same year. Acerinox is not excluded from the EU benchmarks harmonized with the Paris Agreement.

Climate change is one of the greatest environmental, social, and economic challenges. The Group believes that mitigation should be integral to every activity and decision, knowing that this goal can be achieved without sacrificing excellence, profitability, efficiency, and returns for all stakeholders.

This commitment is embodied in the General Sustainability Policy and the Climate Change Policy, presented to the Sustainability Committee in October 2024 and approved by the Board of Directors in February 2025.

The General Sustainability Policy establishes the principles that should govern the Acerinox Group's strategy and guidelines for managing sustainability incidents, risks and opportunities, including mitigation and adaptation to climate change.

The Group takes on and promotes a series of principles that must govern its actions. These include, among others, mitigating climate change by implementing energy-efficiency measures, promoting the use of renewable energies, and optimizing water consumption, as well as adapting to the effects of climate change where appropriate.

The General Sustainability Policy also addresses the promotion of the circular economy and the rational and sustainable use of natural resources, as well as the protection and recovery of biodiversity and ecosystems.

The Group's Climate Change Policy establishes a framework for its business model and strategy to be consistent with its commitment to the transition to a low-carbon economy and limiting global warming.

The purpose of the Acerinox Group's Climate Change Policy is rooted in its General Sustainability Policy, the Sustainability Due Diligence Policy, the Group's Human Rights Policy, the Sustainable Development Goals, and the United Nations Global Compact Principles, among others.

Policies are developed in specific action plans, such as the Beyond Excellence Plan, Decarbonization Plan, and so on.

Both policies apply to all entities within the Group, which will ensure that the principles of these policies are also adopted by other business partners in the activity chain. The Board of Directors oversees compliance with both policies, and they will be available on the Company website.

In 2024, more than 50 decarbonization initiatives were carried out, saving more than 450,000 tCO2. The main decarbonization lever was the increased use of renewable energies, which in 2024 accounted for 44.45% of the Group's electricity consumption, having increased by almost 10%. Also noteworthy are the energy efficiency measures and the increased use of scrap.

Each of the actions has an associated budget (CAPEX or OPEX) that must be approved by the CEO of the corresponding factory. The table below reports the emissions avoided in 2024. Based on the financial data, an estimate has been made to allocate CAPEX or OPEX to energy efficiency (EUR 1,402,478 and EUR 216,933 respectively) and to the other decarbonization levers (EUR 635,600 and EUR 27,910,939 respectively). The Group is currently working to improve the granularity of the financial information associated with climate change actions.

The 2025-2030 Decarbonization Plan requires an estimated annual investment of EUR 817,500 in CAPEX and EUR 1,711,315 in OPEX. 95% of the CAPEX and 49% of the OPEX of the 2024 decarbonization initiatives is aligned with the Taxonomy (Acerinox Europa, Columbus Stainless and NAS). It is estimated that, in the future, the Company will have an aligned CAPEX and OPEX percentage in a similar range to that of 2024, taking into account the uncertainty that exists in this estimate.

The table includes own and upstream decarbonization measures for Acerinox Europa, NAS, Columbus Stainless, VDM Metals, Roldán, and Inoxfil. Haynes International's initiatives will be integrated into the 2025-2030 Decarbonization Plan. Specific targets and actions for climate change adaptation are expected to be added in the coming years.

The Decarbonization Plan has adopted a conservative approach, and only feasible technologies that are available today have been taken into account in the emissions reduction estimates. This mitigates the potential risk of not meeting the approved emissions reduction targets.

To carry out the initiatives, in addition to internal financing, Acerinox has sustainable credits linked to the fulfillment of decarbonization targets.

For one, the Group has a sustainable credit linked to the increase in renewable energy sources. The Company committed to improving the renewable electricity intensity ratio of the entire Group (Stainless Steel and High-Performance Alloys Divisions) by 4% per year from 2020. In 2024, this target was 273 renewable Kwh/metric tons of steel; the actual figure was 578 renewable Kwh/metric tons of steel, reaching the target. In 2024, renewable energy accounts for 44.45% of the Group's electricity consumption.

For another, the Stainless Steel Division signed credits linked to a 1% annual reduction in emissions intensity (Scope 1+2). The 2024 target was met as the ratio was 1.044, below the target of 1.075 tCO2eq/metric ton of production.

Stainless steel is a very sustainable, long-lasting, and infinitely recyclable material. Despite these positive qualities, its manufacture accounts for a considerable proportion of global industrial emissions due to the intensive use of electrical energy to melt scrap and ferroalloys, as well as the use of fossil fuels, such as natural gas, in the heating and smelting processes. In addition, the production of stainless steel and high-performance alloys requires the use of ferroalloys and other raw materials, and their availability is crucial to the Group.

One of the pillars of the Sustainability Master Plan is eco-efficiency and climate change mitigation, which sets a target of a 7.5% reduction in energy intensity, a 20% reduction in GHG emissions intensity (Scopes 1 and 2) and a 20% reduction in water withdrawal intensity by 2030, based on 2015.

In relation to the emissions reduction target, the 2025-2030 Decarbonization Plan establishes new, more ambitious targets, aiming to be compatible with limiting global warming to 1.5ºC, and based on science (SBTi). According to this methodology, Acerinox must reduce Scope 1 and 2 emissions by 45.28% by 2030 compared to 2021. A Scope 3 emissions reduction target of 15% for 2030 compared to 2021 has also been set.

2021 has been selected as the base year because it is the first year in which the GHG Inventory of the entire Group, including VDM Metals, was calculated and verified by an external party, as per the GHG protocol. Due to the sale of Bahru Stainless in 2024 and given that the inventory was conducted at the factory level, the recalculation involved the accurate subtraction of emissions associated with Bahru Stainless operations. Acerinox Group emissions in 2021, excluding Bahru Stainless, were 3,117,325 tCO2e Scope 1 and 2 and 4,877,793 tCO2e Scope 3.

In 2025, Haynes International will be integrated into the perimeter of the Decarbonization Plan and its associated targets.

The established emissions reduction targets include the operational approach and the same GHG gases that are included in the GHG inventory. The market-based approach is also used for Scope 2 emissions. The target for 2030 is 1,705,705 tCO2e of Scope 1 and 2 emissions and 4,146,124 tCO2e of Scope 3 emissions.

Prior to the approval of the decarbonization targets, the Company examined two scenarios: the baseline scenario and the achievable sustainable scenario (that aims to be compatible with limiting global warming to 1.5ºC).

First, a baseline scenario in which production remains constant between 2025 and 2030 at 2023 values while the measures included in the Decarbonization Plan are implemented. Under this scenario, the use of renewable energy will not increase in the future.

Second, the achievable sustainable scenario, in which production increases according to internal forecasts in 2030 compared to 2023 and 60% of electricity comes from renewable sources.

Depending on the production level and starting point of each factory, internal goals are established for each premise, with targets for each factory. The individual targets ensure compliance with the group-level target for Scopes 1 and 2. In addition, the overall target is also set in terms of intensity.

Similarly, Scope 3 emissions reduction targets are set at the factory level, both in absolute and relative terms. Under this scenario, the 15% reduction target in Scope 3 emissions by 2030 compared to 2021 is also achieved.

The Decarbonization Plan includes the adoption of new technologies that cannot currently be implemented due to their level of maturity, such as the use of biofuels.

Some studies and pilot projects on hydrogen injection into the natural gas grid were carried out in different factories in Europe, and the biomethane market is being assessed.

Some of these projects are expected to be completed by the end of the plan period.

According to applicable policies, the definition of the energy, emissions and blue water footprint targets was set based on estimated production capacity and industry benchmarks, Stakeholder participation was not considered.

The Sustainability Committee reviews the progress the indicators of energy intensity, emissions intensity and water footprint intensity intensity against the target quarterly, evaluating at the group, division, and factory levels. If significant discrepancies arise, the Head of Sustainability consults with factory managers and presents explanations for these discrepancies to the Sustainability Committee.

The targets established in terms of energy, GHG emissions and water withdrawal are in response to the climate risk analysis conducted in 2023 according to the TCFD methodology. The assessment showed significant transition risks related to carbon taxation mechanisms and significant physical risks related to water stress at the Acerinox Europa and Columbus Stainless factories.

Our targets for 2030

These targets are monitored monthly by the sustainability managers at each factory and later reviewed by the corporate sustainability team. Likewise, changes are assessed on a quarterly basis by the Sustainability Committee, which subsequently reports to the Board of Directors. In each case, the necessary measures are taken.

The annual variable remuneration of the Group's main senior managers is linked to the achievement of these targets, which are being deployed in the different organizational areas.

*This target was initially set for the Stainless Steel Division, but was extended to the entire Group in 2024. **Increase in the percentage of women on staff compared to the previous year, excluding the Haynes staff as it was not part of the scope when the targets were defined.

The targets linked to variable remuneration for 2025, in line with the target's review carried out and compatible with the 2030 Group roadmap, are as follows:

*Increase in the percentage of women on staff compared to the previous year.

Energy consumption and mix

Scope and methodology

Acerinox reports energy consumption for its production network. In 2024, the perimeter includes 15 factories: five stainless steel factories (three integrated: Acerinox Europa, NAS, Columbus Stainless; two long product: Roldán, Inoxfil) and ten high-performance alloys factories (seven VDM Metals, three Haynes International). Bahru Stainless was sold in May 2024 and is excluded from year-end figures; its emissions and consumption up to sale are included in inventory totals where stated.

Energy consumption is sourced from primary data (invoices) reported by facility managers. Where primary data is unavailable, secondary data (internal control records) is used. Net calorific value is established based on validated and updated sources according to facility location. Conversion factors are applied where necessary.

The 2024 energy consumption was 9.37% lower than 2023, primarily due to a ~10% decrease in melting shop production (12% including factories without melting shop).

Energy consumption and mix (MWh)

*Renewable electricity from the energy mix refers to the percentage of renewable energy from the remaining energy mix, excepting Columbus Stainless, VDM Metals USA, and Bahru Stainless from the supplier's energy mix.

**Acerinox does not produce its own energy.

***Acerinox does not consume hydrogen as fuel.

Supplementary consumption data by fuel type (MWh)

*Note: Total consumption in this table (5,173,558 MWh for 2024) differs slightly from the total in the primary energy mix table (5,166,010.67 MWh) due to different consolidation scope or rounding.

Energy intensity

Energy intensity per net revenue (MWh per EUR thousand):

Net income from activities in high-climate-impact sectors: EUR 6,607,978 thousand (2023), EUR 5,413,128 thousand (2024). Acerinox Group net income is included in the Net Revenue figure of the Profit and Loss Statement of the financial statements.

Energy intensity per tonne of steel produced:

The Group reports an energy intensity of 10.19 GJ/metric tonne of steel produced in 2024 (2023: 9.9 GJ/t). The worsening indicator is attributed to a ~10% drop in melting shop production due to the Acerinox Europa strike, Bahru Stainless closure, and macroeconomic factors. The Group has a 2030 target of 7.5% reduction in energy intensity compared to 2015 (initially for Stainless Steel Division, extended to entire Group in 2024).

Renewable energy

In 2024, renewable energy accounted for 44.45% of the Group's electricity consumption (up almost 10 percentage points from 2023). Acerinox purchased 962,202 MWh of electricity through guarantees of origin or renewable energy certificates.

The Group has a sustainable credit linked to increasing renewable electricity intensity by 4% annually from 2020. The 2024 target was 273 renewable kWh/metric tonne of steel; actual performance was 578 renewable kWh/metric tonne, exceeding the target.

Taxonomy alignment

In 2024, prior to approval of the 2025-2030 Decarbonization Plan, the Group allocated EUR 28,127,871 in OPEX to decarbonization (95% associated to Taxonomy activities), of which 1% corresponded to energy efficiency and 99% to all other decarbonization levers. CAPEX totaled EUR 2,038,078 (49% Taxonomy-aligned), of which 69% was energy efficiency and 31% other levers.

Key performance indicators (CAPEX and OPEX) for Taxonomy-eligible activities at Acerinox Europa, NAS, and Columbus Stainless were EUR 164,512,879 (CAPEX) and EUR 57,235,954 (OPEX) in 2024.

Sources and verification

Activity data for energy consumption follows the hierarchy: primary (measured/invoiced) > secondary (internal records) > estimated. Emission factors are sourced from official databases (IPCC, DEFRA UK, Spanish Ministry for Ecological Transition, Ecoinvent v3.10, supplier-specific factors, etc.).

The measurement has not been verified by an independent external body beyond the verification provider. However, the environmental management system is certified under ISO 14001.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reporting basis

Acerinox calculates its GHG inventory following the GHG Protocol Corporate Standard and the GHG Protocol Corporate Value Chain (Scope 3) Standard. The consolidation approach changed in 2024 to operational control to align with CSRD requirements. The baseline year is 2021, the first year the entire Group (including VDM Metals) inventory was calculated and externally verified.

Greenhouse gases included: CO₂, CH₄, N₂O, HFCs, PFCs, SF₆. Global warming potentials are from the IPCC Sixth Assessment Report (AR6, 100-year time horizon). No biogenic emissions are generated.

The 2024 inventory covers 13 factories (Acerinox Europa, NAS, Columbus Stainless, VDM Metals, Roldán, Inoxfil; Bahru Stainless sold in May 2024; Haynes International acquired in 2024 but not included in 2024 GHG data). Service centres, warehouses and sales offices account for <2.5% of emissions and are excluded as immaterial. Bahru Stainless emissions for 2024 prior to sale: 78,961 tCO₂eq; its 2023 emissions (378,214 tCO₂eq) also excluded from 2023 comparative figures shown.

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Gross GHG emissions

Table: Gross Scopes 1, 2, 3 and Total GHG emissions (tCO₂eq)

*2021 baseline excludes Bahru Stainless (recalculated): Scope 1+2 = 3,117,325 tCO₂eq; Scope 3 = 4,877,793 tCO₂eq.
Note: 2024 figures exclude Haynes International (acquired December 2024). Biogenic CO₂: none. Categories 3.10 (processing of sold products), 3.11 (use of sold products), 3.13 (downstream leased assets), 3.14 (franchises), 3.15 (investments) excluded due to data dispersion, immateriality, or sectoral practice (not in EPD/SBTi Steel scope).

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GHG intensity

By net revenue (tCO₂eq per EUR thousand)

Net revenue (financial statements): 2023 = €6,607,978 thousand; 2024 = €5,413,128 thousand.
All net revenue from activities in high climate-impact sectors (NACE C24 Manufacture of basic metals).

By metric ton of steel produced (tCO₂eq per metric ton)

Note on intensity: The ~10% drop in production (12% including non-melting-shop factories) in 2024 adversely affected intensity metrics despite absolute emission reductions in Scopes 1 and 2.

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Scope 1 regulated emissions

21.04% of 2024 Scope 1 emissions are from facilities regulated under emissions trading schemes (2023: 26.61%; 2021 baseline: 32.49%). Calculation: (ETS facilities tCO₂eq) / (Total Scope 1 tCO₂eq). No carbon credits purchased; ETS allowances excluded from Scope 1 totals.

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Verification and quality assurance

The GHG inventory has been externally verified by a third-party provider. The environmental management system is ISO 14001 certified. Data collection uses primary data (invoices, weighbridge records, certificates) where possible; secondary data (internal systems) and estimates (Ecoinvent LCA, distance calculations) where primary unavailable. Emission factors from IPCC AR6, national inventories (Spain GHG Report 1990–2022, Germany DEHST, South Africa DFFE, US EPA), DEFRA, Ecoinvent 3.10, WorldSteel LCA, supplier-specific factors, and the Ministry for Ecological Transition (Spain) calculator v29.

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Changes from prior years

• Scope 3 category 3.2 Capital goods newly reported in 2024 (146,606 tCO₂eq); zero in prior years (not previously calculated).
• Haynes International acquired December 2024 but excluded from 2024 inventory; will be integrated in 2025.
• Bahru Stainless sold May 2024; its 2024 emissions (78,961 tCO₂eq) and 2023 emissions (262,245 tCO₂eq recalculated) excluded from comparative figures.
• Baseline year (2021) recalculated excluding Bahru Stainless for comparability.
• Scope 3 increase (+31% vs 2023) driven by higher ferroalloy/raw material acquisition emissions (category 3.1) and the addition of category 3.2.
• Scope 1+2 market-based fell 14% year-on-year due to energy efficiency and 10% increase in renewable electricity use (44.45% of total electricity in 2024).

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Scope 3 exclusions and rationale

• 3.8 Upstream leased assets: Immaterial (<0.9% of account 62102).
• 3.10 Processing of sold products & 3.11 Use of sold products: Excluded per GHG Protocol allowance (section 6.4) due to data dispersion (>18,000 product SKUs, 13,781 customers, diverse end-use sectors). Not included in EPD PCR, Steel SBTi, or Steel Climate Standard downstream scope.
• 3.13 Downstream leased assets: Immaterial (two subsidiaries; one lessee energy in Scope 1+2; rental income 0.03% of Group land/buildings).
• 3.14 Franchises: None.
• 3.15 Investments: Investment entities not consolidated in financial statements (immaterial); excluded from non-financial reporting.

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Phase-in and future scope

Acerinox is using the ESRS 1 Appendix C phase-in for anticipated financial effects (E1-9). Climate risk analysis (TCFD-aligned) updated in 2025 to incorporate value chain risks and Haynes International. Scope 3 categories to remain under review; materiality reassessed annually.

The Acerinox Group did not develop any GHG removals and GHG mitigation projects financed through carbon credits. The Company is exploring the possibility of CO2 capture, storage, and use projects. Currently, some projects are in a preliminary phase. For example, a implementation feasibility study has been conducted at one of the factories.

On the other hand, Company has not contributed to greenhouse gas sequestration projects upstream and downstream in our value chain.

The Acerinox Group has set an internal carbon price of EUR 63.75/tCO2 in 2024. The internal carbon pricing system is a shadow price, i.e., a theoretical price based on external resources. It is based on estimated changes to the carbon price in the European Emissions Trading Scheme (Carbon Pulse EUA Price Forecast, which takes into account the forecast of twelve traders). This price applies to the entire company: it is a single price, regardless of location, business unit, or activity.

Acerinox projected its carbon price according to information from the report, last updated in April 2024. The result was the following:

• 63.75 /tCO2 in 2024 • 75.30 /tCO2 in 2025 • 91.35 /tCO2 in 2026 • 109.30 /tCO2 in 2027 • 123.85 /tCO2 in 2028 • 128.45 /tCO2 in 2029 • 134.85 /tCO2 in 2030

This forecast predicts that the price of carbon will increase by 111% over the next 7 years.

The internal carbon price is applied to Scope 1 and Scope 2 in the economic analysis of energy efficiency and other decarbonization initiatives in order to incorporate this variable into investment decisions.

The Financial Statements do not take into account the carbon price.

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

Phase-in Exemption

The Group is also working to better quantify anticipated financial impacts of climate risks and is taking advantage of the phase-in period under ESRS 1-10 regarding the timeline for reporting this quantification in future years.

Identification of climate-related risks and scenario analysis

Back-filled from E1 IRO-1 (pages 82-85) and the E1 SBM-3 climate table (pages 80-81). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risks are classified physical or transition following TCFD (pages 80-81, 84-85).

Methodology (page 82). Short term is the financial-statement reference period, medium term 2030 (Sustainability Master Plan), long term 2050 (EU climate neutrality). The physical analysis "was carried out at all the Group's factories", using site-specific CRISP platform data for nine hazards including extreme heat, river and coastal flooding, cyclones, wildfires and water stress. Hazard magnitude and exposure likelihood combine into risk scores from 0 to 10 (page 83).

Scenarios. Physical: IPCC SSP5-RCP 8.5, which "forecasts that carbon dioxide emissions levels will triple by 2075, with global temperatures rising by 4.4°C", and SSP1-RCP 2.6, where temperatures "stabilize at 1.8º Celsius by the end of the century" (page 82). Transition: IEA STEPS and SDS, the latter carrying "a 50% probability of limiting global temperature increase to 1.65ºC" (page 83) rather than a 1.5 C no- or limited-overshoot scenario, assessed across five geographical blocks.

Scope. Value chain is excluded for 2024: "In 2025, the climate risk analysis will be updated, incorporating risks related to the value chain" (page 82).

Resilience in relation to climate change

Back-filled from E1 SBM-3 (page 81) and the double materiality analysis (page 62). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The resilience conclusion is one sentence tied to the decarbonisation plan review: "In the process of reviewing and updating the decarbonization plan, no significant changes were identified in the business model or in the company's assets, demonstrating the company's resilience to climate change" (page 81). The DMA section makes the same claim across all topics (page 62).

The report adds that "no assets have been identified that are incompatible with a transition to a climate-neutral economy" (page 83). Each risk in the IRO-1 table carries mitigation measures: water consumption targets and water treatment investment; carbon intensity targets, energy efficiency, renewable electricity, hydrogen and biomethane in place of natural gas, and carbon capture analysis (page 84).

Adaptive capacity. The Decarbonization Plan "has adopted a conservative approach, and only technologies available today have been taken into account in the emissions reduction estimates. This mitigates the potential risk of not meeting the approved emissions reduction targets" (page 80).

No significant areas of uncertainty are disclosed, and no separate resilience analysis beyond the plan review is described.

Responsible water management is crucial for the Group, given that producing stainless steel and high-performance alloys requires substantial amounts of this natural resource.

In 2025, the Group updated the Sustainability and Safety, Health, and Environment Policies, replacing the previous ones. The rational and sustainable use of water, along with ecosystem protection across all activities, are key principles in the Sustainability Policy, as well as in IRO management.

Similarly, the Health, Safety and Environment Policy is dedicated to protecting nature, which includes managing and consuming water resources responsibly and maintaining their quality. These policies apply to all entities within the Acerinox Group, including those in water-stressed areas. They must ensure that policy principles are followed by all commercial partners involved in the activity chain.

The Board of Directors oversees compliance with both policies, and they will be available on the Company website.

Most factories source their water from rivers (NAS, Roldán, and VDM Metals). However, some facilities draw water from swamps (Acerinox Europa), reservoirs (Columbus Stainless and Bahru Stainless), or the public supply network (Inoxfil and VDM Metals). No factory sources its water from marine resources, whether biological or non-biological.

Water is essential throughout the production process for cooling machinery and molten steel, cleaning equipment, generating steam, and treating wastewater.

Our factories have measures in place to prevent, avoid and act in the event of spills or discharges resulting from the storage of other substances. Neutralization and treatment facilities for both acidic and basic water, along with emergency ponds, allow us to maximize the recirculation of water and prevent any discharges into the natural environment. Together with other security measures, they eliminate the risk of spills. The tanks are equipped with a permanent secondary containment mechanism, as well as cleaning and emergency shutdown services.

The Group's operations have a minimal impact on marine resources since only Acerinox Europa discharges water into the sea. Water is discharged into the Bay of Algeciras through a general collector managed by the Major Industries Association of Campo de Gibraltar. This discharge is subject to regular analysis in accordance with the Plan for the Monitoring and Control of the Receiving Environment for Discharges into the Bay of Algeciras.

Actions and resources related to water and marine resources

Overview

Sustainable water management is key to ensuring the continuity of operations and contributing to a more sustainable future.

Key actions and milestones

CEO Water Mandate

Action: Membership of CEO Water Mandate

• Scope: Corporate
• Time horizon: 2024 (achieved)
• Description: In 2024, Acerinox joined the United Nations CEO Water Mandate initiative to advance sustainable water practices and strengthen commitment to environmental challenges. The goal is to implement innovative and sustainable practices.
• Link to target: Improved CDP Water rating (2025-2030). Acerinox earned a B rating from CDP for its sustainable water management.

Water Footprint Development

Action: Development of water footprint model for the High-Performance Alloys Division

• Scope: High-Performance Alloys Division, US operations (Haynes)
• Time horizon: 2024 (model development started); 2025-2030 (expansion to Haynes)
• Description: Assessment of the company's water footprint with specific models developed for divisions.

Action: Improvement of water footprint parameter calculation processes

• Scope: Global
• Time horizon: 2024 (achieved); 2025-2030 (ongoing improvements)
• Expected outcomes: Reduction and continuous improvement in Blue and Gray Water Footprints (2025-2030)

Water Management Policies and Infrastructure

Action: Development of policies, including water management

• Scope: Global
• Time horizon: 2024 (developed)
• Link to policy: Updated Sustainability and Safety, Health, and Environment Policies in 2025. Rational and sustainable use of water is a key principle in the Sustainability Policy and IRO management.

Operational measures in place:

• Neutralization and treatment facilities for acidic and basic water
• Emergency ponds to maximize water recirculation and prevent discharges
• Secondary containment mechanisms for tanks
• Cleaning and emergency shutdown services
• Regular analysis of discharges (e.g., Plan for Monitoring and Control of the Receiving Environment for Discharges into the Bay of Algeciras at Acerinox Europa)

Resources Allocated

2024 financial resources:

• OPEX: EUR 50,374,836
• CAPEX: EUR 1,251,201
• Total: EUR 51,626,037

Future investments (2025-2030): Investments to improve the quality of water management data. The Company estimates that future CAPEX and OPEX percentages will be similar to those in 2024, although there is some uncertainty in this estimate.

Note: Resources allocated to water resource management are detailed in Note 9 (Property, plant and equipment - Environment) in the Consolidated Annual Accounts.

Targets related to water

Acerinox has established water withdrawal intensity reduction targets as part of its Sustainability Master Plan under the eco-efficiency and climate change mitigation pillar.

Target 1: Water withdrawal intensity reduction (original target - achieved)

Target 2: Blue water footprint intensity reduction (new target from 2025)

Note on water consumption targets: As stated in the disclosure, "there is no defined target for reducing water consumption" - targets are focused on water withdrawal intensity and blue water footprint intensity only.

Note on marine resources: The Acerinox Group does not rely on marine resources and has not set any targets related to them.

Water consumption

Acerinox monitors water withdrawal and discharge volumes daily through flow meters, verified annually by third parties. The Group uses various water sources certified by suppliers: surface water (primary), production water, and third-party municipal water. All discharges are regularly tested for compliance with Emission Limit Values (ELVs) and legal requirements. All factories have treatment and neutralization plants to stabilize and remove contaminants before discharge, plus secondary containment systems to prevent accidental spills.

Water consumption by area and division

Note: Acerinox does not store water. The Group is investing in and developing methods to gather accurate data on recirculated water at each factory.

Water consumption in 2024 decreased by -35.34% compared to 2023 due to decreased production (around 10% in melting shop production, 12% including factories without melting shop) and water saving plans implemented at the factories. The stainless steel division's water consumption in water-stressed areas decreased by -35.17% due to the strike at Acerinox Europa. Water consumption in non-stressed areas (-70.59%) decreased significantly due to improvements in water reservoir management, better control of cooling towers, and repairs to valves and water pumps to remedy leaks.

Water intensity

Note: Acerinox Group net income is included in the Net Revenue figure of the Profit and Loss Statement of the financial statements.

Water withdrawal by source and area (2024)

Water discharge by destination and area (2024)

Blue, gray, and total water footprint (Acerinox Group)

*The Group's production in 2024 includes 5,420 metric tons from the Altena and Werdohl cold rolling mills.

Methodology: Blue water footprint (surface and groundwater) and gray water footprint (contaminated water) calculated using the Water Footprint Network (WFN) methodology. Water stress assessment uses data from the World Resources Institute (WRI) and future projections. 13% of the Group's factories are situated in regions experiencing high or extremely high water stress.

Verification: The data has not been verified by an independent external body beyond the verification provider. However, the environmental management system is certified under ISO 14001.

Water withdrawal and discharge - historical comparison (2023)

Water withdrawal (2023):

Water discharge (2023):

Water-stressed areas: Shortage areas are defined as permanent deficit situations in relation to water demand in a regional water resource system, characterized by either an arid climate or rapidly growing demand in consumption. Two factories are in water-stressed areas: Acerinox Europa (Campo de Gibraltar, Spain, in the Guadarranque river basin) and Columbus Stainless (Middelburg, South Africa, in the Olifants river basin).

Anticipated financial effects from material water and marine resources-related impacts, risks and opportunities

During the current financial year, there were no significant financial impacts, nor are any expected to appear in the short-term financial statements.

Policies related to resource use and the circular economy

Reference: page 101 (ESRS index: E5-1, page 101).

Circular economy is managed through the General Sustainability Policy and the Health, Safety and Environment Policy, plus a responsible purchasing policy. Both "prioritize the waste minimization by promoting the sustainable resource use and the circular economy, optimizing the use of recycled and reused materials throughout the business chain. In terms of the waste hierarchy, the Sustainability Policy has established the promotion of waste recycling as one of its general principles of action" (page 101).

The Health, Safety and Environment Policy is rooted in the General Sustainability Policy, the Sustainability Due Diligence Policy, the Human Rights Policy, the SDGs and the UN Global Compact principles (page 101).

"Both policies were updated in 2024 and approved by the Board of Directors in 2025, enhancing the management of the IROs identified in the double materiality analysis." They apply to all Group entities, which "will ensure that the principles of these policies are also adopted by other business partners in the activity chain". The Board of Directors oversees compliance and the policies "will be available on the Acerinox website" (page 101).

Actions and resources related to resource use and the circular economy

Reference: pages 101-102 (ESRS index: E5-2, page 101).

Acerinox "maximizes the use of scrap in production processes, with levels of up to 90% for circularity purposes", described as a driving force for the 2025-2030 Decarbonization Plan (page 101). The Group invests in research into recovering, recycling and reusing metals and alloys across the product life cycle, and states plainly: "The Company is not currently engaged in any industrial symbiosis processes" (page 101).

Upstream, waste generation is reduced "by promoting the use of bulk supplies and/or recyclable packaging" and by purchasing recycled materials; downstream, recyclable cardboard, plastic and metal packaging "encourages circularity among its customers" (page 101). Environmental Product Declarations are made available to customers, giving "quantitative, verified information on the environmental impact of the Group's products throughout their life cycle" (page 102).

On resources: "The 2024 actions have a continuity approach with respect to what has been done in previous years", and "Implementing these initiatives does not require significant capital or operating expenses beyond those mentioned in E1-1" (page 101).

Targets related to resource use and circular economy

Reference: page 102 (ESRS index: E5-3, page 102).

One target: recycle 90% of all waste generated in own operations by 2030, scope Acerinox Group, with progress of 82.29% in 2024 and a 3.36% improvement on 2023 (page 102). "This goal has not been set in response to any regulatory requirement but was established by the Group on a voluntary basis."

The company discloses the limits of how the target was set: "The 2020 target did not take into account conclusive scientific evidence nor ecological thresholds. Stakeholder participation was also not considered." It also states that "Acerinox has not currently established additional targets related to the resource use or circular economy" (page 102), so there are no targets for resource inflows or outflows.

Monitoring is layered: factory sustainability officers track progress monthly, the corporate sustainability team conducts periodic reviews, and the Sustainability Committee is "responsible for quarterly monitoring and any necessary corrective measures" (page 102).

Resource inflows

Reference: pages 102-103 (ESRS index: E5-4, page 102).

Total resource inflows in 2024 were 2,484,370.56 metric tons, "14% lower than 2023 (2,881,404.04 metric tons)", attributed to the roughly 10% fall in production (page 103).

Recycled inflows, 2024 (2023): scrap and metals 1,674,448.87 t (2,016,920.85), recycled acids 11,028.47 t (14,092.11), other recycled material 0.00 t (2,842.22), total recycled materials 1,685,477.34 t (2,033,855.18). As percentages: scrap and recycled metals 76.65% (78.98%), recycled acids 32.06% (41.49%), recycled materials overall 67.84% (70.59%). "Unlike 2023, in 2024 no other recycled materials were used" (page 102).

Virgin inflows, 2024 (2023), tons: alloys 509,969.89 (536,757.82), gases 254,519.97 (276,822.50), acids 34,403.36 (33,968.53), total virgin materials 798,893.22 (847,548.85). "Acerinox does not use biological materials in its production process" (page 103).

Scrap reaches "figures close to 90% of recycled material as inflows to the process", varying with final product specifications (page 102). Data come from direct measurements, weighing or periodically reviewed inventories, consolidated monthly into the corporate ESG tool; they have "not been verified by an independent external body beyond the verification provider", though the environmental management system is ISO 14001 certified (page 103).

Resource outflows

Reference: pages 103-104 (ESRS index: E5-5, page 103).

Products. Output is split into stainless steel and high-performance alloys, flat or long. "The factories produced 1,828,133 metric tons in 2024, of which 67.84% came from recycled products and 76.65% came from recycled scrap (2023: 2,072,867 metric tons)" (page 103). Durability and recyclability are described rather than quantified: the chromium passive layer "ensures the steel's indefinite durability under normal conditions", and "at the end of its life cycle, the materials return to being raw materials, without losing any of their properties in the reconversion and transformation process" (page 103).

Waste. Total waste fell to 1,172,638 t from 1,298,793 t, of which 964,988 t (82.29%) recycled or recovered and 207,650 t (17.71%) landfilled; non-hazardous 1,041,161 t (88.79%), hazardous 131,477 t (11.21%) (page 104). "The recovery operation carried out by Acerinox is recycling. Disposed waste is landfilled. No other disposal operations are performed", and "Acerinox's processes do not generate radioactive waste" (page 104).

Output is monitored per factory with software tools and reported monthly to the corporate strategy department; the data have "not been verified by an independent external body beyond the verification provider" (page 103).

Waste

Reference: pages 103-104 (part of E5-5 Resource outflows in the ESRS index, page 103).

Total waste, tons, 2024 (2023): 1,172,638 (1,298,793); landfill 207,650 / 17.71% (262,827 / 20.24%); recycled or recovered 964,988 / 82.29% (1,035,966 / 79.76%). Non-hazardous 1,041,161 / 88.79%, of which 138,367 landfilled. Hazardous 131,477 / 11.21% (116,058 / 8.94%), of which 69,283 landfilled, so 52.70% of hazardous waste goes to landfill (page 104).

By stream, 2024, tons: metal-bearing 1,042,134 (160,239 landfill, 881,895 recycled); sludge and chemicals 102,673 (40,260, 62,413); paper, wood, plastic and others 27,831 (7,151, 20,680) (page 104).

"Waste generation in 2024 decreased by -9.71% compared to the previous year", on the roughly 10% production fall; "Waste sent to the landfill decreased by -20.99%, while recycled waste decreased by -6.85%" (page 104).

Metal-containing wastes from steelmaking and rolling (slag, fumes, scale) "are recovered by specialized companies and reincorporated into the production process"; chemical waste and water-treatment sludge go for recycling; municipal solid waste is landfilled (page 104). "Acerinox's processes do not generate radioactive waste" (page 104).

The company flags the basis of its split: "The percentage of waste sent for disposal is not supported by any industry standard; it relies on internal waste management practices" (page 104). The 90% recycling target sits under E5-3 (page 102).

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Reference: pages 104-105 (ESRS index: E5-6, page 104).

No figures are given. "The acquisition of scrap metal and the volatility of raw material prices in 2024 have impacted product costs. No financial penalties have been incurred due to poor waste management" (page 104).

The main risk identified in 2024 was "the increase in costs due to the volatility of raw material prices and scarce resources, as in the case of ferroalloys. This risk is managed on a daily basis within the Company's operations through the economic study of primary and secondary raw materials" (page 104). Against that, "our results show an opportunity for cost reduction from scrap reuse by optimizing and increasing the use of recycled materials" (page 104), and a product opportunity was taken up: "In 2024 it launched the ECO ACX low-emissions product, which uses more than 90% recycled material" (page 105).

Quantification is deferred: "The Group is also working to better quantify anticipated financial impacts and is taking advantage of the phase-in period under ESRS 1-10 regarding the timeline for reporting this quantification in future years" (page 105).

Policies related to own workforce

Reference: pages 106-107 (ESRS index: S1-1, page 106).

The Code of Conduct and Good Practices is the anchor: everyone working for the Group "is entitled to dignified treatment, equal opportunities, fair wages, career advancement, and safe working conditions in an environment where they can freely express their opinions and concerns", and all agreements between Group companies and their employees must incorporate these principles. The Code "strictly bans forced labor and child labor" (page 106).

The Human Rights Policy, "revised in 2024 and approved by the Board of Directors in 2025", is aligned with the UN Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Global Compact, the ILO Tripartite Declaration and ILO conventions (page 106).

Three further policies, reviewed in 2024 and approved by the Board in 2025 (pages 106-107):

• Work Selection and Promotion Policy - hiring "based on merit and ability".
• Equality, Diversity and Inclusion Policy - applies to all companies, with Equality Plans at Acerinox SA, Acerinox Europa, Roldan, Inoxfil and Inoxcenter.
• Health, Safety and Environment Policy - "focused on achieving zero accidents across its operations", covering employees and contractors, implemented through ISO 45001-based management systems and the Cardinal Rules (page 107).

Adequate wages

Reference: pages 106 and 109 (ESRS index: S1-10, pages 106, 109).

The company labels S1-10 against its policy and pay-framework text rather than an adequate-wage benchmark. The Code of Conduct entitles everyone working for the Group to "dignified treatment, equal opportunities, fair wages, career advancement, and safe working conditions" (page 106).

On how pay levels are set: "In 2024, the Group evaluated all positions using a certified system. This system provides an objective methodology for evaluating job positions and establishing the salary framework. This system enhances the organizational structure and increases transparency in all aspects of people management" (page 109). The Group also states that "it ensures working and salary conditions worthy of the people who work for the company" (page 110), and reports collective bargaining coverage of 60.36% (page 112).

No percentage of employees paid below an applicable adequate wage benchmark is disclosed, and no benchmark is named.

Social protection

Reference: pages 108-110 and 112 (ESRS index: S1-11, pages 108, 112).

Coverage is described by event rather than by percentage of employees: Acerinox "offers employees social protection against loss of income due to events that may occur in the employees' lives: illness, unemployment, work accidents, acquired disability, parental leave or retirement" (page 110).

"The set of benefits that the company offers include life insurance, medical insurance, disability or invalidity coverage, pension fund, transportation compensation, study scholarships for workers and their children, assistance for death of family members, school and daycare assistance, subsistence allowances and parental leave" (page 110). The same page repeats that social protection applies "for its employees against income loss due to life events such as illness, unemployment, work-related accidents, acquired disability, parental leave, or retirement".

Well-being support includes the Employee Assistance Program, with 24/7 access to a psychologist and monthly health and wellness workshops (page 108).

No country-by-country statement of which major social protection events are not covered by public programmes is disclosed.

Persons with disabilities

Reference: page 113 (ESRS index: S1-12, page 112).

"By the end of the financial year, Acerinox employed 258 persons with disabilities (227 men and 31 women)" (page 113). No percentage of total employees is stated, and the figure is not broken down by country; against the reported headcount of 9,293 it is the only disability metric given.

The Group's strategy for disability inclusion "focuses on two main areas": first, "enhancing employability and directly hiring persons with disabilities"; second, engaging "in initiatives and programs that raise disability awareness and provide training for our employees" (page 113).

Acerinox "collaborates with various foundations to develop activities that improve the quality of life of people with intellectual disabilities. These initiatives include participation in workshops, team-building activities, promotion of teamwork, mentoring sessions and training programs for this group" (page 113). Inclusion of people with disabilities is also named as an objective of the Equality, Diversity and Inclusion Policy (page 112).

Training and skills development metrics

Reference: pages 113-115 (ESRS index: S1-13, pages 108, 113).

"The average number of training hours per employee in 2024 was 58.7 hours" (page 113), down from 73.5 in 2023, on total training hours of 542,031 (599,866 in 2023) and 7,173 employees trained (5,778) (page 114).

Average hours by category, 2024 (2023): director 4.8 (11.4); manager 18.1 (25.8); analyst 26.7 (30.0); specialist 19.7 (29.0); administrative staff 26.0 (31.0); operator 102.9 (131.5). Women average more hours than men in most categories, for example analyst 30.0 against 25.5 and operator 109.3 against 102.4 (page 114).

Performance reviews: "By the end of 2024, 50% of employees had participated in this performance evaluation, with 48% being men and 61% women", covering 4,438 employees against 2,981 in 2023 (page 114). Coverage ranges from 88% of directors to 39% of administrative staff and 46% of operators (page 115).

Delivery is through an online training catalogue on the talent management platform, including "technical and specific training for the steel sector to ensure that know-how is kept up-to-date", plus "a digitized map of the skills associated with each position, which determines the training and certifications required at each point in the employee's career" (page 113).

Health and safety metrics

Reference: pages 115-117 (ESRS index: S1-14, page 116).

"In 2024, a colleague tragically lost their life while working on the Group's premises" (page 116). The own-workforce table reports 0 fatal accidents and the contractor table 1 fatal accident in 2024 (pages 116-117), so the fatality falls in the contractor population.

Coverage: 8,448 employees, 90.91%, are covered by a health and safety management system (7,485 and 90.96% in 2023); "90% of the Group's employees work in facilities that have occupational health, safety, and welfare management systems certified under the ISO 45001 and ISO 14001 standards" (page 116).

Own workforce, 2024 (2023): hours worked 13,843,592 (14,466,641); recordable accidents 124 (130); accidents with leave 60 (59); LTIFR 4.33 (4.08); TRIR 8.96 (8.99); severity rate 7.54 (7.90); absenteeism 835,332 hours, 6.03% (914,451, 6.32%); work-related illnesses 9 (7); fatalities from work-related illness 0 (0) (page 116). The headline indicators reported for the Group are LTIFR 3.83 (3.42), TRIR 8.25 (7.92) and TIR 19.12 (20.99), with severity of incidents resulting in sick leave "declining from 0.32 in 2023 to 0.18 in 2024" (page 116).

Contractors, 2024 (2023): hours worked 5,197,375 (5,115,271); recordable accidents 33 (25); accidents with leave 13 (8); LTIFR 2.50 (1.56); TRIR 6.35 (4.89). "Data on contractor absenteeism and contractor occupational diseases are not recorded" (page 117).

Work-life balance metrics

Reference: page 115 (ESRS index: S1-15, pages 108, 115).

"A total of 9,132 employees were eligible for parental leave. Of them, 241 took maternity and paternity leave, after which the return-to-work rate (201 men, 40 women), namely 95% (98.5% men and 77.5% women) and retention rate, namely 73% (71% men and 85% women) remained high" (page 115).

Entitlement is described by country: "In addition to European countries like Sweden, Portugal, Germany, and the United Kingdom, as well as the USA, where 100% of employees are entitled to family leave, workers in other regions such as Colombia, Peru, Singapore, and India have various recognized family rights and leave options that support work-life balance and shared responsibility" (page 115). A single figure for the percentage of all employees entitled to family-related leave is not given.

Supporting measures include remote work extended to more employees, flexible hours and continuous workdays, and breastfeeding rooms in some factories and service centres under the Equality Plans (page 110). The Group states that upholding "work-life balance rights and related leave" is one of its strategic goals (page 115).

Remuneration metrics (pay gap and total remuneration)

Reference: page 115 (ESRS index: S1-16, page 115).

"The pay gap between men and women in 2024 stood at 6.74%" (page 115). The basis is stated: "The wage gap was calculated as the average gross hourly pay of salaried men minus the average gross hourly pay of salaried women, divided by the average gross hourly pay of salaried men. For this purpose, we have taken into account the number of hours worked by men and women reported in the calculation of accident rates (S1-14)."

The company explains the gap as structural: "This difference is primarily due to the later addition of women to the workforce and their under representation more broadly in the industry. These factors have an adverse effect on women in terms of receiving salary items associated with concepts such length of service or shift work" (page 115).

Total remuneration ratio: "The total annual remuneration of the highest-paid individual (excluded from the calculation) is 32 times the average total annual remuneration of all other employees" (page 115).

Pay structure: fixed pay reflects "experience, responsibility, and role within the company" and variable pay "relies on indicators tied to the Group's performance", which the company says "avoids subjective evaluations, thus minimizing any potential for discrimination" (page 115).

Incidents, complaints and severe human rights impacts

Reference: page 117, with detail on pages 126-127 (ESRS index: S1-17, page 117).

"In 2024, 56 complaints were received. Investigations revealed that 68% involved breaches of internal regulations or applicable laws. Once they had been analyzed, it was found that there had been no human rights violations" (page 117).

The business conduct chapter breaks the same 56 complaints down: "56% related to human resources issues, including discrimination, inappropriate behavior, disrespect, bullying, and a harassment case involving an employee of an external contractor working at our facilities. This latter case was substantiated, prompting the implementation of protocols, necessary measures, and the dismissal of the worker by the contractor. The second most common category involved health and safety issues, making up 19% of the cases" (page 127).

By type: work-related 56%, health and safety 19%, fraud and petty corruption 11%, other violations 8%, conflicts of interest 6%. Corrective actions: organisational and process improvements 55%, layoffs 28%, communication enhancement 8%, reported to police or authorities 6%, other disciplinary measures 3%. 70% of cases came through the whistleblowing channel and 87% arose outside Spain (pages 126-127).

No fines, penalties or compensation for severe human rights incidents are reported, consistent with the finding of no violations.

Processes for engaging with own workers and workers' representatives about impacts

Reference: page 108 (ESRS index: S1-2, page 108).

"Regular meetings are held with various works councils at our facilities, as well as with the Health and Safety Committees. While extraordinary meetings can be convened as needed by either party, these regular meetings occur at least annually." The Human Resources Department oversees the channels, with site HR departments keeping them operational (page 108).

Specific mechanisms (page 108):

• Acerinox Insights, launched 2023 and developed in 2024, conferences led by department heads on sustainability, digital transformation and production processes.
• The Innovation Committee, which "gathers all suggestions for continuous improvement through various channels that are accessible to all employees".
• A personnel management platform including Communities, "designed to facilitate and promote communication between employees and the Company".
• The Management by Objectives evaluation, with "intermediate checkpoints and informal follow-up meetings", so that "these interactions provide employees with meaningful feedback and the opportunity to express their views to their supervisors".
• An annual Health, Safety and Environment Week across five continents, "a platform for the company to engage with employees, allowing them to voice their concerns and opinions on the crucial topic of operational safety".

Processes to remediate negative impacts and channels for own workers to raise concerns

Reference: page 108 (ESRS index: S1-3, page 108 twice).

"All employees have access to the Group's whistleblowing channel, allowing them to report any irregularities or inappropriate behavior they observe. Through this channel, employees can also report any potential dangers or risks within the facilities or operations." How the channel works is described in the business conduct chapter (page 108, cross-referring to pages 126-127), where the policy "explicitly prohibits retaliation" and the Code Monitoring Committee keeps "the case manager or investigator separate from the management chain of the issue" (pages 126-127).

Employees "can also approach their various representation bodies, such as staff representatives or works councils, which convey their concerns and grievances to the company" (page 108).

Remediation for the Group's main negative impact is described in the same section: where an accident leads to incapacitation or disability, "the Group has procedures in place for job relocation and role adaptation" (page 109). An Employee Assistance Program provides psychological counselling, with "access to a psychologist in real-time, 24/7, along with monthly workshops on various health and wellness topics" (page 108).

Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities

Reference: pages 108-110 (ESRS index: S1-4, page 108).

The material negative impact is health and safety: the industry "involves complex processes that pose significant health and safety risks to workers, along with inherent chemical and physical hazards" (pages 108-109). Actions (pages 109-110):

• Process Safety Management, drawing on World Steel, the European Center for Process Safety and the Center for Chemical Process Safety, to prevent "structural collapses, explosions, fires, and toxic releases". Its reactive indicator fell to 0.58 (Tier 1: 0, Tier 2: 11) from 1.94 in 2023.
• Risk analyses "whenever there are changes to facilities or operations", safety days at all centres, and dissemination of the Cardinal Rules.
• Accountability: "senior management and plant managers have objectives linked to improvements in accident rate performance", and sustainability-linked loans aim to "enhance the LTIFR indicator by 2% compared to the previous year at the Acerinox Europa, NAS, Columbus Stainless and Bahru factories".
• Absenteeism: every case reviewed individually, with training for workers and middle managers.
• Talent: all positions evaluated in 2024 "using a certified system" setting the salary framework; the Excellence Talent Program and Leadership Academy.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 110, with performance on pages 112 and 116 (ESRS index: S1-5, pages 110, 112, 116).

Gender. "The Acerinox Group aims to increase female representation to 15% by 2030. In 2024, the Group reached 13.39% women, excluding Haynes which was not part of the scope when this target was set" (page 110). The chart shows 12.81% in 2022, 13.28% in 2023 and 13.39% in 2024 against a 15.00% line for 2030.

Safety. "A target of a 26% reduction in the TIR was set for 2024, but only an 8% reduction was achieved." The sustainable credit target was met: LTIFR of 3.56 at Acerinox Europa, NAS, Columbus Stainless and Bahru Stainless, "surpassing the target of 4.26" (page 110). Group LTIFR was 3.83 against 3.42 in 2023 and TIR 19.12 against 20.99 (page 116).

Elsewhere the company invokes the minimum disclosure requirement limb rather than setting targets: "No material objectives that warrant disclosure have been identified in the other areas of this topic. Our established processes are embedded within the departments responsible for daily compliance with policies in this area. Policies and actions are mainly monitored by analyzing the primary employee contact tools" (page 110).

Characteristics of the undertaking's employees

Reference: page 111 (ESRS index: S1-6, page 111).

All workforce data are headcount at year end; average employee numbers sit in Note 18.2 of the Consolidated Annual Accounts (page 111).

Total 9,293 employees: 7,944 men, 1,349 women, none reported as other or not reported (page 111).

By country (countries with 50 or more workers): United States 3,192; Spain 2,626; Germany 1,779; South Africa 1,289; Italy 54; Malaysia 50 (page 111).

By region: Europe 4,661; America 3,228; Africa 1,289; Asia 107; Oceania 8 (page 111).

By contract type: permanent 9,088; temporary 205; non-guaranteed hours 0; full-time 9,204; part-time 89 by region, reported as 9,200 and 93 in the gender table (page 111). By gender, permanent 1,307 women and 7,781 men; temporary 41 women and 164 men; part-time 74 women and 19 men.

Turnover: "In 2024, 438 employees left the company; 126 were dismissals, and 312 were voluntary resignations. The 2024 turnover rate was 5.39%", calculated as leavers over average employees. Exit interviews are used "to identify opportunities for improvement and to understand the reasons for staff turnover" (page 111).

Characteristics of non-employee workers in the undertaking's own workforce

Reference: page 111 (ESRS index: S1-7, page 111).

The workforce is defined to include non-employees: "Non-employee workers includes subcontracted services from freelancers, service companies, and temporary employment agencies (TEAs). All of these individuals may face various impacts due to the Company's operations" (page 106).

The single headcount figure is given at year end: "Besides its employees, Acerinox collaborates with external professionals who, despite not being part of the permanent workforce, add significant value to the business. This typically includes professionals from temporary employment agencies (TEAs). By the end of 2024, the Acerinox Group collaborated with 2,773 contractors" (page 111).

No breakdown of non-employee workers by gender, region or contractual arrangement is disclosed. Contractor safety performance is reported separately under health and safety, including 5,197,375 hours worked, 33 recordable accidents and one fatal accident in 2024 (page 117).

Collective bargaining coverage and social dialogue

Reference: pages 111-112 (ESRS index: S1-8, page 111).

"As of December 31, 2024, 60.36% of employees are covered by collective bargaining agreements (66.45% in 2023)" (page 112). The Group "has collective bargaining agreements in all production centers in Spain, maintaining an open, fluid, and cooperative dialogue with the workers' representatives" (page 111).

Coverage is banded by country (page 112):

• 80-100%: Germany, Spain, Italy
• 40-59%: South Africa
• 0-19%: United States, Malaysia

On-site representation in the European Economic Area is reported for Spain only, in the 80-100% band (page 112).

"Meetings with workers' representatives are held regularly or whenever required to address a specific issue. These meetings address various issues, including working conditions, organizational matters, health and safety, and career development" (page 111).

Diversity metrics

Reference: pages 112-113 (ESRS index: S1-9, page 112).

"As of the end of 2024, the Acerinox Group consists of 7,944 men and 1,349 women. The total number of directors is 33, with 28 being male and 5 female. In the next management tier, there are 320 male managers and 82 female managers" (page 112). Expressed as a share, the workforce chart gives 85.5% men and 14.5% women in 2024, against 7,136 men and 1,093 women in 2023 (page 113).

Age distribution, 2024 (2023) (page 113):

The company notes that "multiple generations are represented, with a notable number of older employees" (page 113).

Policies related to value chain workers

Reference: pages 118-119 (ESRS index: S2-1, page 118).

The sustainable purchasing policy has applied "since 2021, and after its 2024 review and approval by the Board of Directors in 2025", covering "economic, competitive, social and environmental matters" for all Group companies (page 118).

General conditions for procuring goods and services require suppliers to guarantee "quality and compliance with labor, tax, safety and environmental regulations", drawing on the UN Global Compact principles, the ILO Declaration on Fundamental Principles and Rights at Work, and the UN Convention against Corruption (page 118).

The Code of Conduct for business partners, "revised in 2024, establishes clear standards for labor, environmental, and human rights, as well as business ethics", and "is a fundamental requirement for any contractual relationship within the Group". It aligns with the OECD Due Diligence Guidance for minerals from conflict-affected and high-risk areas, and "In 2024, a total of 1,676 suppliers signed this guidance" (page 118).

The General Human Rights Policy was "revised in 2024 before getting approval from the Board of Directors in 2025" and binds suppliers as well as Group companies (pages 118-119).

Using its third-party risk platform the Group "identified suppliers operating in countries with a high risk of child labor. We have already audited those suppliers we deem strategic" (page 119).

Processes for engaging with value chain workers about impacts

Reference: page 119 (ESRS index: S2-2, page 119).

Engagement is with suppliers rather than directly with their workers. "The main information channel is the Group's website which, through the new supplier portal, details the purchasing process and requirements for commercial partners. Their code of conduct is available on this portal" (page 119).

Mechanisms (page 119):

• A confidential whistleblowing channel open to suppliers, whose visibility the Group "raised... to improve service and help people submit queries or report violations".
• A supplier satisfaction programme piloted at Columbus, which "added a survey under the signature line of each of its emails"; "During 2025, satisfaction surveys will be launched at the rest of our group companies".
• Suppliers Days: "The Company organized its first Suppliers Days in Germany, which took place on September 26, 2024", with a plan "to carry out one per year in each country where we have large factories".
• Channel effectiveness testing: "questions about the effectiveness of the whistleblowing channel and communication channels with Acerinox will be asked in our ESG audits and in our supplier satisfaction surveys".

On retaliation, the whistleblowing policy states that "members of the organization are prohibited from retaliating against bona fide whistleblowers, including threats of retaliation and attempted retaliation" (page 119).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: pages 119-120 (ESRS index: S2-3, page 120).

The whistleblowing channel is open to value chain workers and suppliers, with anti-retaliation guaranteed by the "Policy approving the basis of the whistleblowing system of the Acerinox Group" (page 119). Hazards can also be raised operationally: "Potential hazards are also reported through preventive observations and the whistleblowing channel", and "Acerinox monitors all safety incidents in its operations and investigates and implements the necessary corrective and preventive measures" (page 120).

Remediation runs through audits and improvement plans. "In 2024, a total of 43 audits were carried out on critical suppliers, classified in category A or B... conducted by certified external auditors, who issued detailed reports with the final results and proposed action plans. All audit reports have been transferred to the GoSupply platform... This platform facilitates the implementation of corrective actions, closure of evidence, and issuance of improvement orders" (page 119). "In 2024, 20 action plans were established as a result of these audits" (page 120).

Where verification finds "actual or potential adverse effects on sustainability... corrective actions will be considered. These may ultimately lead to the suspension or termination of the contractual relationship" (page 118).

Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities

Reference: pages 120-121 (ESRS index: S2-4, page 120).

The main negative impact is contractor health and safety. Acerinox applies the WorldSteel process safety model and its six principles, and extends the HSE Cardinal Rules to "all workers at our facilities, including those in the value chain", with emergency plans and "continuous training and education programs to contractor employees" (page 120).

Supplier ESG assessment (page 120): "In 2024, the Group had 7,335 active suppliers. Of these, 1,520 suppliers, accounting for EUR 4,396 million in expenditure, underwent an online ESG assessment. Among them, a total of 346 are strategic suppliers." Questionnaires cover "environmental preservation, child labor, slavery, diversity, freedom of association". Type A (Tier-1) suppliers were evaluated in 2023 and 2024; "In 2026, Type B (Tier-2) suppliers will be evaluated."

Audits: "In 2024, 43 audits were completed, 27 of which targeted strategic suppliers. This was in addition to the 20 audits conducted in 2023, with 14 focusing on strategic suppliers" (page 120).

Training: through the Sustainable Supplier Training Program led by the Spanish Global Compact Network, "92 of the Group's suppliers have been trained" (page 121).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 121 (ESRS index: S2-5, page 121).

No target values are set for 2024. "To measure the impact of sustainable procurement initiatives, the Group has designed key performance indicators (KPIs) to be implemented in the coming years" (page 121). The five indicators are: percentage of suppliers that have signed the Code of Conduct; number of suppliers evaluated under ESG criteria; percentage of suppliers audited on-site; percentage of suppliers that have implemented improvement plans based on audit and evaluation recommendations; percentage of action plans in progress and implemented; and number of supplier training programmes and suppliers trained (page 121).

A quantified multi-year audit plan is disclosed: "2025: approximately 100 audits, on-site and online" and "2026: approximately 203 audits more, on-site and online", which "takes the form of an estimated 346 strategic suppliers audited over the 2024-2026 period. Of these, 43 have already been assessed this year" (page 121).

Current metrics, 2024 (2023): suppliers 7,335 (7,702), of which 78.49% local (78.59%); expenditure EUR 4,396,210 thousand (4,966,503), 63.36% local (59.12%); strategic suppliers in category A 346, 4.72% (267, 3.47%); strategic suppliers evaluated with ESG criteria 43, 12.43% (54, 20.22%) (page 121).

Policies related to consumers and end-users

Reference: page 122 (ESRS index: S4-1, page 122).

Two instruments are named. The General Conditions of Sale "provide the legal foundation for all of Acerinox's commercial transactions. They specify the terms and conditions related to buying and selling products, including payment terms, applicable taxes, and potential price changes. They also outline delivery times and locations, as well as each party's responsibilities in the transportation process. These conditions cover the quality standards of the products sold, the guarantees offered to customers, and the limits of Acerinox's liability in cases of contract breaches or product defects." They are presented as ensuring "a clear and transparent legal framework for all commercial activities, protecting the interests of both customers and the Group" (page 122).

The Code of Conduct and Good Practices covers "meeting all quality requirements and standards in product manufacturing" and "forming business relationships based on mutual interest and a continuous service-oriented approach, with a strong commitment to honesty and professional responsibility" (page 122).

Customers are intermediate links rather than consumers: "Acerinox's customers serve as intermediate links in the value chain, transforming or distributing products before they reach the final consumer" (page 122).

Processes for engaging with consumers and end-users about impacts

Reference: pages 122-123 (ESRS index: S4-2, page 122).

"Acerinox gathers valuable insights into customer needs and expectations through surveys, meetings, and direct communications from its service centers and subsidiaries. This information helps improve product quality, streamline processes, and strengthen relationships" (page 122).

The main instrument is an annual survey: "The Group launches annual customer satisfaction surveys covering most of the customers it works with, the main parameter collected being the NPS (Net Promoter Score)" (page 122), assessing "three main areas: customer satisfaction, brand image, and strategic market positioning" (page 123). No NPS value is published.

Process: "Customers have one month to respond to the survey, and weekly follow-ups are made with those who have not responded. Once their responses have been collected, a final report is prepared with the main results of the metrics broken down by geographical area... Based on these results, specific action plans are designed and implemented by the Sales Department" (page 123).

Findings feed risk management: "Findings indicate that customers are primarily concerned with product quality, delivery times, and incident management" (page 123). Sector Managers act as sector points of contact, and the commercial network provides "direct and seamless communication with our sales representatives" (page 123).

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: page 123 (ESRS index: S4-3, page 122).

"The Group also manages customer complaints daily to address issues promptly and take short-term actions. This process enables us to quickly coordinate responses to arising problems, providing early resolutions" (page 123).

How complaints are handled: "All customer complaints (including commercial subsidiaries) are processed, managed, and resolved individually in the ERP systems of the Group's billing companies. Complaints are classified according to their nature, divided into technical and commercial. These are managed through complaint tickets, with 100% traceability in terms of dates, assigned departments, and authorization chains, each with its corresponding attachments or justificatory material." Technical complaints arising from a manufacturing problem go to the factory's Technical Department; sales complaints, including materials damaged during transport, are resolved by the Sales Department (page 123).

"Like all other stakeholders, the Company's customers have access to a whistleblowing channel to report queries or violations" (page 123). The commercial network also "assesses the best way to resolve issues, utilizing resources like our complaints channel or sending a sales technician from the subsidiary or factory if needed" (page 123).

No number of customer complaints received in 2024 is disclosed.

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities

Reference: pages 123-124 (ESRS index: S4-4, page 123).

The incident response protocol is numbered: "1. Immediate logging of all incidents and complaints in a centralized system (ERP). 2. Assigning responsibility to a specific manager. 3. Escalating more complex incidents to the appropriate organizational levels. 4. For every type of complaint, there is traceability from its initiation to its resolution. Each complaint has therefore a personalized action plan to ensure the best decision is made to prevent recurrence" (page 123).

Quality assurance: "all service centers undergo thorough audits based on ISO 9001 Quality Management standards. These audits cover all material transformation processes and the operations related to the workshop", with inspection of "every item... before shipping" where additional protocols apply (page 123).

Delivery reliability: "To prevent delivery delays, Acerinox maintains both buffer stocks and consignment stocks" (page 123).

Remedy: "If a delay in delivery cannot be mitigated, Acerinox compensates the customer financially and conducts a root cause analysis... Next, specific corrective actions are implemented to prevent recurrence in the future. The final step involves following up with the customer to ensure the issue has been resolved" (page 124).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 124 (ESRS index: S4-5, page 124).

Acerinox sets no targets for consumers and end-users and says so, invoking the minimum disclosure requirement limb on tracking effectiveness instead:

"No material objectives have been identified that warrant disclosure. The established processes are embedded within the departments responsible for daily compliance with corporate policies in this area. Policies and actions are mainly monitored by analyzing the primary customer contact tools, as noted in previous sections" (page 124).

The "primary customer contact tools" referred to are the annual satisfaction survey with NPS as its main parameter, the daily complaints process in the ERP systems with full ticket traceability, the commercial network and Sector Managers, and the ISO 9001 audits of service centres (pages 122-123). No NPS value, complaint count or quality metric is published for 2024, so effectiveness is described qualitatively rather than measured.

The customer risks the Group identifies, against which any target would be set, are "product quality, delivery timelines, and overall customer satisfaction", where delays or quality failures "can significantly affect the Company's reputation, lead to customer loss, and ultimately impact its profitability" (page 122).

Corporate culture and business conduct policies

Reference: pages 125-128 (ESRS index: G1-1, page 125).

The Code of Conduct and Good Practices, approved by the Board in 2016, "sets mandatory rules and standards for professional behavior that all employees and managers must follow", aiming "to regulate which behaviors are permitted and prohibited within the Group" and to set the ethical principles guiding "the actions of Acerinox, its employees, and administrators" (page 125). "Violation of the Code could result in disciplinary action, without prejudice to the administrative or criminal sanctions that may apply" (page 126).

Governance: the Code of Conduct Monitoring Committee "reports to the Board of Directors through the Audit Committee, supervises compliance with and internal dissemination of the code among employees, interprets it and also controls and supervises the processing of each case" (page 125).

Development rules cover the crime prevention model and internal instructions on gifts and invitations, conflicts of interest, bribery prevention, competition, good financial practices, confidentiality, third-party risks and the commission of crimes (page 126). A separate business partner code "establishes the duties and commitments of suppliers".

In 2025 "the new compliance Master Plan will be rolled out, prioritizing the update of the Code" (page 125). 4,459 employees were trained in 2024 (page 128).

Prevention and detection of corruption and bribery

Reference: pages 128-130 (ESRS index: G1-3, pages 125 and 128).

"Acerinox is committed to fostering a culture of zero tolerance towards any form of bribery or corruption, whether active or passive, private or public, in every country where it operates", with policies aligned to the UN Convention against Corruption (page 128). Controls include "the approval of gifts by independent departments, risk assessments in sensitive areas, the implementation of internal financial and accounting controls, and both internal and external audits".

Risk assessment: "the areas related to corruption and bribery are considered low-risk and are part of the compliance management system, which is updated in accordance with the UNE 19601 standard" (page 129). Offences identified include "influence peddling, bribery, illegal financing of political parties, business corruption, money laundering... and fraud against public administrations". "Since Acerinox does not directly sell to governments or public administrations, the risk of corruption involving public officials... is low" (page 129).

Programme: the Crime Prevention Program runs an annual four-phase cycle: processes and monitoring update; self-assessment surveys; evaluation and certification of criminal risks; action and training plan. It was subjected to "an external audit conducted by AENOR", and holds UNE 19601 certification (page 130).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets fall under the minimum disclosure requirements rather than a numbered DR. G1-3 became a standalone DR only in the 2025/2026 ESRS; the company's ESRS index lists only G1-1, G1-3 and G1-4 under ESRS G1 (pages 169-171).

Acerinox states no measurable business conduct target. The G1 chapter's "Parameters and targets" heading carries only the anti-corruption incident metrics under G1-4 (page 130), and the blanket statement used under S1 and S4 ("No material objectives that warrant disclosure have been identified") is not repeated here.

Consistent with the other limb of MDR-T, effectiveness is tracked in the absence of a target:

• The annual Crime Prevention Cycle provides "monitoring, measurement, analysis, and evaluation", with self-assessment surveys, assessment of criminal risks against the results, signed "certificates of compliance", and documented action and training plans (page 130).
• Certification: the programme holds UNE 19601, and the 2025-2028 Compliance Master Plan "includes plans to obtain ISO:37001 certification for anti-bribery management systems" (page 130).
• Channel assurance: "In 2024, an external auditor conducted a comprehensive review of the whistleblowing channel" (page 126).

Training volumes stand in for a target: 4,459 employees trained in 2024, 416 of them on corruption, bribery, fraud and money laundering (page 128).

Confirmed incidents of corruption or bribery

Reference: page 130, with the complaints breakdown at pages 126-127 (ESRS index: G1-4, page 130).

"No cases of corruption or bribery were detected in 2024. However, there were four substantiated cases, classified as fraud and petty corruption, related to the misuse of company assets or theft. Two of these cases were reported to the police or authorities. One of the cases resulted in a dismissal. In all cases, corrective measures were implemented to prevent future incidents" (page 130).

Context from the whistleblowing data: of the 56 complaints received in 2024, "68% involved breaches of internal regulations or applicable laws", with fraud and petty corruption accounting for 11% of cases and conflicts of interest 6% (pages 126-127). Corrective actions across all substantiated complaints were organisational and process improvements 55%, layoffs 28%, communication enhancement 8%, reported to police or authorities 6%, and other disciplinary measures 3% (page 127).

Acerinox reports no fines or convictions for violation of anti-corruption and anti-bribery laws; the datapoint is listed in the appendix of datapoints derived from other EU legislation against this section (Appendix 8.6, page 172), and the disclosure of no detected corruption or bribery cases is the company's answer to it.