Acerinox

Reference: pages 84-87, 171.

The Board "is responsible for setting the overall strategy and policies on sustainability matters", a non-delegable power that includes "setting the Group's sustainability strategy and policies and overseeing their implementation" (pages 84-85). After the General Shareholders' Meeting of 6 May 2025 it has eleven directors: non-executive 90.91% against 9.09% executive, independent 63.63%, and female directors 36.4% at 31 December 2025 (23.08% in 2018), with women 57.14% of the independent members (page 84). "There are no directors representing employees and other workers" (page 85). A Board-approved competency matrix maps all eleven directors, including sustainability and environment, energy and digital transformation (page 85).

The Sustainability Committee coordinates sustainability actions and supervises the Group's sustainability plan (page 86). The Sustainability Director sits on the Management Committee and reports at least quarterly (page 87). The Audit Committee supervises non-financial information and risk; "the Chair of the Audit Committee is also a member of the Sustainability Committee" (page 87). Under G1 the same DR is cross-cited to the Compliance Department and the Ethics Committee, which "reports to the Board of Directors through the Audit Committee" (page 171).

Reference: pages 78, 84-87.

The Board "incorporates sustainability matters into its decision-making, and is regularly presented with updates on the Group's targets and progress", and is "responsible for overseeing sustainability-related IROs, approving the setting of targets... as well as overseeing the monitoring of progress" (pages 85-86). The materiality outcome "was approved by the Sustainability Committee, the Audit Committee and subsequently by the Board of Directors in 2024. The material topics were not modified during the 2025 review" (page 78).

Cadence is stated: 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, safety and health indicators, and aspects related to due diligence", before each quarterly external report (page 87).

The 2025 agenda is itemised (pages 86-87): ratification of the Global Sustainability Plan 2025; monitoring of KPIs, targets and ESG ratings (S&P Global, CDP, ISS ESG, MSCI, EcoVadis); oversight of the 2024 NFIS; review of the ESG weighting in senior management bonuses; referral of the 2030 carbon reduction targets and the Decarbonization Plan to the Board; the revised policy framework approved 25 February 2025 and the Code of Conduct approved 29 October 2025; and oversight of the EcoACX launch, the climate risk analysis and the human rights due diligence project.

Reference: pages 88, 99.

The Directors' Remuneration Policy links the CEO's variable pay to "financial parameter and sustainability criteria such as safety at work, GHG emissions, water consumption, diversity, and recycling", weighted at not less than 10% (page 88). For 2025 the weighting rose to 15% for the CEO and the Chief Corporate Officer, 20% for the Secretary-General and 10% for other Senior Management (page 88).

The five 2025 ESG indicators and weightings are: a 10% LTIFR reduction versus 2024 (40%); a 6.76% reduction in Scope 1 and 2 GHG intensity (15%); a 3% reduction in blue water footprint intensity (15%); a 2.10% increase in the waste recycling ratio (15%); and a 0.27% increase in women in the workforce (15%) (page 88). Attainment was validated "at around 80%", against 59% in 2024 (page 88). Business unit CEOs carry the same index against their own companies' targets.

Under E1 the climate element is quantified: the CO2 intensity target "accounts for 15% of the sustainability targets" and "In 2025, the target related to climate change reached 100% compliance, entailing a weighting between 1.5% and 3% of senior management's remuneration", with Scope 1 and 2 intensity moving from 1.07 to 0.93 tCO2 per metric ton, -13.4% (page 99).

Reference: pages 88-89.

Due diligence "aims to reduce the probability and exposure of the Group to risks and impacts and to seize opportunities that impact sustainable value creation", expressed as seven principles (pages 88-89): treating it 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"; measures "proportional to the severity and likelihood" of the effects; integration "into management systems and procedures"; remediation "proportional to the Group's degree of involvement in producing the adverse impact"; collaboration with business-chain partners; "free, accessible, and non-retaliatory complaint, participation, and consultation mechanisms"; and public reporting "including findings and outcomes".

"These principles are taken into account in the management of IROs... and have been incorporated into the development of the new Sustainability Due Diligence Policy, which was approved in early 2025" (page 89). Inputs such as "the ethics channel, customer complaints and stakeholder consultations were previously integrated into the double materiality analysis" (page 89).

The disclosure is narrative. No GOV-4 mapping table is printed locating each core due diligence element against the paragraphs of the statement where it is reported.

Reference: pages 87-88.

"Acerinox has also developed an 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" (page 87).

On risk identification: "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" (page 87).

"The methodological approach is aligned with the three lines of defense (COSO) risk model", with roles for the Board, data management and monitoring officers, internal monitoring and internal audit; "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" (page 88). The Audit Committee supervises "financial and non-financial information, as well as the Group's risk management and monitoring, which is reported on a quarterly basis" (page 87).

Two limits show on the face of the disclosure: the monitoring measures are written in the future tense, so the control set is not presented as fully operating at the reporting date, and no findings, remediation or effectiveness assessment are reported.

Reference: pages 74-76.

Acerinox, headquartered in Spain, is "leader in the manufacture of stainless steel and high-performance alloys, and has a melting capacity of 3.5 million metric tons", with 15 factories on three continents (page 74). The stainless steel division has three integrated flat product plants (Acerinox Europa, North American Stainless, Columbus Stainless) and two long product plants (Roldán, Inoxfil); the high-performance alloys division is VDM Metals and Haynes International, "which have 10 production sites in the US and Germany". Products are "distributed through a wide sales network across more than 80 countries".

The Strategic Plan 2021-2025 rests on excellence, added value, sustainability and financial strength, with the sustainability pillar deployed through the 360º Positive Impact Plan and its five action lines, from governance and eco-efficiency to circular economy, workforce and supply chain (pages 74-75).

The value chain is mapped as upstream (raw materials, transport), own operations (manufacture, research and development) and downstream (distribution and sales, storage, after-sales service and recycling) (page 76). On the benchmark datapoints the Group "is exempt from reporting CAPEX relating to the coal, oil and natural gas sectors, as it does not carry out economic activities linked to fossil fuels" (page 101).

Reference: pages 75-76, 82, 159, 167.

"The materiality analysis is an active listening process that enables the matrix to be validated with stakeholders and their perspective to be incorporated into the analysis, based on a comprehensive methodology that includes interviews and surveys" (page 75). IRO assessment drew on "internal stakeholders (key area managers, managers, and employees) and external stakeholders (proxy advisors, suppliers, and customers) through interviews and surveys" (page 76).

Seven stakeholder groups are defined: employees and their representatives, shareholders and investors, customers, suppliers and other business partners, local communities, public agencies and civil society (page 82). The stakeholder management model, approved in 2022, "establishes the way in which Acerinox identifies and classifies stakeholders" and "determines the method for identifying their needs and expectations" (page 82).

Topic-level engagement is cross-cited: value chain workers through "the Supplier Portal, corporate mailboxes, meetings with suppliers and on-site audit and verification programs" (page 159), customers through "surveys, technical visits and close contact with each customer" (page 167).

Two limits the Company records itself: "External stakeholder participation was not required for this technical target-setting process" for emissions and water targets (page 114), and for the blue water footprint target "No stakeholder involvement was considered" (page 125).

Reference: pages 78-81, 102-103, 215-219.

"The Company' materiality matrix is structured around eight material issues: energy, climate change, water management, circular economy, workforce, supply chain, customers and end-users, and corporate governance and ethics" (page 78). "The material topics were not modified during the 2025 review. No changes to the Company's business model, strategy or assets were identified, demonstrating the Group's resilience" (page 78); only the climate IRO inventory was updated, after the 2025 climate risk analysis. Priority is ranked twice: by impact climate change, circular economy, energy; by financial materiality energy, climate change, circular economy (page 80). E2 Pollution, E4 Biodiversity and ecosystems and S3 Affected communities were assessed and "not identified as material" (pages 80-81).

Annex 8.5 lists 15 impact-materiality rows and 22 financial-materiality rows (pages 215-219).

"The material current financial effects during 2025 are those disclosed in Note 9 on Investments and the Environment", and "No material impact risks have been detected that would entail a significant likelihood of adjustment for the next annual reporting period" (page 81). Anticipated effects are deferred under "the transition period (phase-in) provided for in Annex C of ESRS 1" (page 81).

Climate risk identification, scenario analysis and resilience are also presented under E1-2 and E1-3 (2025 ESRS numbering).

Reference: pages 75-81, 103-110, 121-122, 130.

The determination, carried out in 2024 and reviewed in 2025, runs in four phases (pages 75-78): context analysis, drawing on the 2022 materiality analysis, the Group's risk map "including climate and transition risks", the regulatory framework, sectoral trends, investor expectations and sector benchmarking, during which the value chain is defined; IRO identification by topic, sub-topic and sub-sub-topic; assessment through interviews and surveys of internal and external stakeholders; and prioritisation.

Metrics are printed with scales (pages 76-78): magnitude 1-5; scope (global 5, medium 3, limited 1); remediability (not remediable 5 to easily remediable 1); probability (very high 1 at 100% occurrence to very low 0.5 at 10%); and economic valuation 1-5. Time horizons are short term 1 year weighted 50%, medium term 1-5 years 30%, long term over 5 years 20%. Formulas are given per IRO type, with the note that "In the case of potential negative impacts related to human rights, severity is prioritized over probability" (page 78).

One stated omission: "The economic magnitudes associated with each risk level are classified information and are therefore not included in this report" (page 77).

Topic-level IRO-1 disclosures are given for climate (pages 103-110), water (pages 121-122) and circular economy (page 130); the method applied to the non-material topics E2, E4 and S3 is at pages 80-81.

Reference: pages 220-225.

Annex 8.6, headed "ESRS table of contents" and labelled "ESRS2 - IRO 2 Disclosure requirements in ESRS covered by this report", is a real content index: having performed the materiality analysis, "the company presents below the referenced content of the disclosure requirements related to these topics" (page 220).

It is ordered by standard with a page against each requirement. ESRS 2 covers BP-1 (73), BP-2 (74), GOV-1 to GOV-5 (84, 78, 88), SBM-1 (74), SBM-2 (75), SBM-3 (75, 78), IRO-1 (78, 84), IRO-2 (220) and the Article 8 Taxonomy disclosure (92, 209). E1 lists GOV-3, E1-1, SBM-3, IRO-1 and E1-2 to E1-9. E2, E4 and S3 list IRO-1 only, matching the DMA finding that those topics are not material (pages 221, 223). E3 lists E3-1 to E3-5, E5 E5-1 to E5-6, S1 S1-1 to S1-17, S2 S2-1 to S2-5, S4 S4-1 to S4-5, and G1 GOV-1, IRO-1, G1-1, G1-3 and G1-4. G1-2, G1-5 and G1-6 do not appear.

A second table maps the datapoints derived from other EU legislation to their benchmark reference and report section, covering GOV-1, SBM-1, E1-1, E1-4, E1-6, E1-7, E1-9, S1-1, S1-14, S1-16, S1-17, S2-1, S3-1 (marked "Non-material"), S4-1 and G1-4 (pages 223-225). Against both E1-9 benchmark datapoints it records reliance on "Annex C: Disclosure and Application Requirements in Topical ESRS" (page 224).

The index lists coverage only; omissions and phase-in reliefs are stated in the body, at pages 81, 121, 129 and 136.

Reference: pages 99-101.

The Decarbonization Plan 2025-2030 is "based on a bottom-up approach, developed in collaboration with the technical and strategy teams and the CEOs of each factory" (page 100). It is "structured around eight decarbonization levers, detailing estimated GHG emissions, the reduction targets established, and the actions already implemented and planned... including the investment required and the economic and CO2 emission savings for each": energy efficiency, heat recovery, electrification of systems and of the vehicle fleet, renewable energy, low-carbon fuels, scrap use and low-carbon ferroalloys (page 100).

Targets are "designed to be compatible with limiting global warming to 1.5°C and are science-based (SBTi), entailing a 44.76% reduction by 2030 compared to 2021. It also sets a Scope 3 emissions reduction target of 15%... Acerinox is not excluded from the EU benchmark indices aligned with the Paris Agreement" (page 100). "Final approval was formalized in January 2025 by the Board of Directors, upon the proposal of the Sustainability Committee" (page 100).

Funding: "Acerinox allocated CAPEX exceeding €5 million in 2025 (€2 million in 2024)... the OPEX estimate... was more than €16 million in 2025 (€28 million in 2024). Annual CAPEX and OPEX investment is expected to remain at similar levels for the next few years (2026-2030)" (page 101). A Climate Adaptation Plan was developed alongside it in 2025.

Reference: pages 103-110.

Back-filled from the E1 IRO-1 subsection, where this content is disclosed in the FY2025 report (pages 103-110). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"In 2025, the Acerinox Group updated its climate risk and opportunity analysis", following TCFD and "the standardized method set out in ISO 14091, which is aligned with the recommendations of the 5th Assessment Report of the IPCC" (page 103). Risks are split into physical and transition subsections (pages 104-110).

Methodology and scope. Risk = exposure x vulnerability, and "inherent risks are deemed material if classified as high or very high" (page 103). Exposure is geolocated using NASA IBTrACS, NASA COOLR, WRI Aqueduct 4.0 and Copernicus; facility vulnerability scores were "used as a sample to extrapolate to the rest of the consolidation perimeter" (page 105). The analysis "covers a total of 66 Group assets... the three main suppliers and three main customers... for each of the Group's 15 factories" and "all climate hazards established in the Taxonomy Regulation" (page 104), over 2026, 2030 and 2050.

Scenarios. Physical: SSP5-RCP 8.5 ("4.4°C increase in global temperatures") and SSP3-RCP 7.0 (3.6°C) (page 104). Transition: SSP1-1.9, "global Net Zero is achieved by 2050", 1.6°C in 2041-2060, and SSP2-4.5 (2°C) (page 106). The list "includes 33 transition risks and 16 transition opportunities" (page 106).

Reference: pages 102-103, 105-106.

Back-filled from ESRS 2 SBM-3 as presented in the E1 chapter of the FY2025 report (pages 102-103). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Acerinox "has carried out a climate resilience analysis, maintaining the same scope, time horizons and scenarios defined in" the climate risk assessment (page 102).

Results. It "demonstrates that the physical risks facing Acerinox's facilities depend on the specific location of each asset, the nature of the production processes and the sensitivity of critical infrastructure", and "The Adaptation Plan substantially reduces risk levels, thereby strengthening the resilience of the Group's business model in the short, medium and long term, even under a very pessimistic scenario" (page 102). Transition resilience starts from events "classified as high or very high risk under a scenario of very aggressive socioeconomic decarbonization".

Adaptive capacity. The plan identifies "more than 200 additional adaptation measures... with a 2030 horizon. Of these, 60 are unique" (page 106). Insurance is "an additional layer of financial protection" (page 102), and "no assets have been identified that are incompatible with a transition to a climate-neutral economy" (page 106). The visible limits are the extrapolation of facility vulnerability scores (page 105) and the E1-9 deferral (page 121).

No dedicated uncertainty statement is given.

Reference: pages 110-111.

"The formalization and approval of the General Sustainability Policy and the Climate Change Policy in 2025 represent a firm commitment by the Company to addressing the challenges, objectives and goals of climate change" (page 110).

The General Sustainability Policy "serves as the foundational document, setting out the high-level guiding principles that orient and frame the Group's overall strategy and the guidelines for managing impacts, risks and opportunities", including climate mitigation and adaptation. Mitigation "is pursued through energy efficiency, the use of renewable energy and water optimization, among other actions, including adaptation to the effects of climate change where appropriate" (page 110).

The Climate Change Policy "establishes a framework for its current business model and future growth strategy so that it is in line with the commitment to the transition to a low-carbon economy and limiting global warming", rooted in the Sustainability, Due Diligence and Human Rights Policies, the SDGs and the UN Global Compact (page 110).

Scope and oversight: "These 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"; "Compliance with the Policies will be overseen by the Company's highest governing body, the Board of Directors"; "all policies are available on the Company's website" (page 111).

Reference: pages 111-113.

"During 2025, Acerinox implemented more than 50 initiatives integrated into its Decarbonization Plan, achieving a reduction of more than 800,000 tCO2 (472,000 tCO2 in 2024...). The main driver of progress was the substantial increase in the use of renewable energy, which accounted for 53.14% of the Group's total electricity consumption in 2025 (55.17% excluding Haynes)... growth of almost 20 percentage points compared to the prior year" (page 111).

Resources: 2025 CAPEX of approximately €5.2 million splits as "almost €3.5 million to energy efficiency, more than €700,000 to increasing the use of scrap, more than €500,000 to boosting heat recovery systems and almost €500,000 to the other levers", 58% Taxonomy-aligned; estimated OPEX was €16.6 million, 55% aligned (page 111). "To fund the initiatives, Acerinox uses both internal resources and sustainable loans linked to the fulfillment of decarbonization targets" (page 113).

The lever table quantifies savings per lever for 2024, 2025 and 2026-2030 (page 112): 53 initiatives in 2025 delivered 29,794 tCO2eq Scope 1, 669,318 Scope 2 and 131,284 Scope 3; 108 planned initiatives carry 382,547, 4,158,994 and 667,673 tCO2eq. Outcome: "we have reduced our Scope 1 and 2 emissions intensity by approximately 19% in 2025 compared to the baseline year of 2021 (without Haynes)" (page 111).

Reference: pages 113-115.

Base year 2021, "the first fiscal year in which the carbon footprint of the entire Group—including VDM Metals—was calculated and externally verified", restated in 2025 for Haynes: "the total emissions of the Acerinox Group in 2021 amount to 3,246,681 tCO2eq for Scope 1 and 2, and 4,983,067 tCO2eq for Scope 3" (page 113).

"the Company is committed to reducing Scope 1 and 2 emissions by 44.76% by 2030... and Scope 3 emissions by 15% over the same period... The target for 2030 is 1,793,606 tCO2eq of Scope 1 and 2 emissions and 4,235,607 tCO2eq of Scope 3" (page 113). A footnote disaggregates this into "a 42% reduction of Scope 1 and 45.99% of Scope 2, as defined in the SBTi methodology". Scope 2 is market-based; targets are pushed down to each plant.

Target setting compared "the Base Scenario and the Achievable Sustainable Scenario; the latter has been designed to be compatible with the goal of limiting global warming to 1.5°C" (page 113). "External stakeholder participation was not required for this technical target-setting process" (page 114).

Performance: "In 2025, the established target of 284 renewable kWh/metric ton of steel was exceeded, achieving an effective ratio of 724" (page 114), and "the annual target was met with a ratio of 0.925 tCO2eq/metric ton of steel, below the target of 1.012" excluding Haynes (page 115).

Reference: pages 115-117.

Total energy consumption was 5,904,121.81 MWh in 2025 against 5,173,557.54 MWh in 2024 (page 116). Total fossil energy was 4,450,754.66 MWh, 75% of the total (79% in 2024), of which natural gas is 3,183,805.05 MWh and purchased fossil-source electricity, heat, steam and cooling 1,152,690.63 MWh; coal and derivatives fell to 0.00 MWh from 8.04. Nuclear sources were 67,767.08 MWh, 1%. Renewable consumption was 1,385,600.08 MWh, 23% (20% in 2024), of which 1,311,439.84 MWh carried guarantees of origin, 72,784.30 MWh came from the residual mix and 1,375.94 MWh was self-generated. The Company notes that while it "did not generate its own energy in 2024... Thanks to the solar installations at the Arcadia and Hendersonville plants, the Group will begin generating its own energy", and that "Acerinox does not use hydrogen as a fuel source" (page 116).

The high-climate-impact disclosure applies: the activity is "included in Section C. Manufacturing, subgroup 24. Manufacture of basic metals in accordance with Regulation (EC) No. 1893/2006 (NACE Codes)" (page 116). Energy intensity rose 6.87% to 1.02 MWh per € thousand from 0.96, attributed to "factory production profiles to meet changing demand" (page 116). The data "has not been validated by any external body other than the verification provider".

Reference: pages 117-120.

Calculated "in accordance with the corporate standard of the GHG Protocol and the standard for accounting and reporting on the value chain (Scope 3)", base year 2021 (page 117).

Scope 1 was 807,964 tCO2eq, up 14.06% from 708,348 and below 1,004,355 in 2021: stationary combustion 659,348, mobile combustion 13,679, process 130,978, fugitive 3,959; 31.17% falls under regulated emissions trading schemes (21.04% in 2024). Scope 2 was 704,975 tCO2eq location-based (-20.96%) and 1,086,711 market-based (-12.58%). Scope 3 was 4,447,596 tCO2eq (+0.52%), of which purchased goods and services 3,724,055 (+5.15%); capital assets fell 46.19% to 78,887 "due to the update of Ademe emission factors" and waste generated in operations fell 62.69% to 88,756 after slag reclassification (pages 117-119).

Totals: 6,342,271 tCO2eq market-based (-0.53%) and 5,960,535 location-based (-1.07%), against 8,229,748 and 7,511,281 in 2021, with a 2030 market-based milestone of 6,029,213 (pages 117-118). Market-based intensity fell 6.85% to 1.10 tCO2eq per € thousand (page 119), and "Scope 1 and 2 emissions intensity per unit of production decreased more than 13% (excluding Haynes)" (page 120).

"Acerinox does not generate biogenic emissions" and "The measurement has not been verified by any independent external body beyond the verification provider" (page 118).

Reference: page 120.

A nil return on both limbs. "Acerinox remains firmly committed to climate change mitigation and reducing its carbon footprint. To date, however, the Company has not resorted to carbon market mechanisms to offset its emissions, such as carbon credits. The Company has not contributed to greenhouse gas sequestration projects upstream and downstream in its value chain" (page 120).

This is consistent with the target design: the Decarbonization Plan "adopts a conservative approach by integrating only technologies that are currently commercially available" (page 101), and no removals or credits are counted towards the 44.76% and 15% reductions (pages 100, 113).

Credits are flagged as a future possibility rather than a current instrument: "Given current technological limitations in eliminating all emissions, the Group prioritizes the deployment of cutting-edge solutions and will assess the acquisition of carbon credits to offset unavoided emissions" (page 101). No volume, vintage, standard or price is disclosed, because none has been purchased. The EU-legislation datapoint table lists "ESRS E1-7 GHG removals and carbon credits paragraph 56" against the European Climate Law reference and points to this section (page 224).

Reference: page 121.

"The Acerinox Group has set an internal carbon price of €75.30/tCO2 in 2025 (€63.75/metric ton of steel in 2024). This figure is established as a shadow price, meaning it is a theoretical price used internally for decision-making purposes, with no impact on the Company's Financial Statements" (page 121).

Scope of application: "the internal carbon price is applied to Scope 1 and Scope 2 emissions in the economic analysis of all decarbonization and energy efficiency initiatives (see E1-1 Transition plan for climate change mitigation). The internal carbon price is a single price applied across the entire Company, regardless of geography, business unit or activity" (page 121).

Basis and trajectory: "This price is determined on the basis of the estimated trajectory of the carbon price under the European Union Emissions Trading System (EU ETS). To this end, Acerinox draws on reports from specialist carbon market traders. For 2026, the carbon price will be set at €89.15/tCO2" (page 121).

"The carbon pricing has not been verified by any independent external body beyond the verification provider." Note that the 2024 comparative is expressed per metric ton of steel while the 2025 figure is per tCO2, so the two are not comparable as printed.

Reference: pages 121-123.

"Responsible water management is a critical issue for the Group, given that manufacturing stainless steel and high-performance alloys requires intensive use of this natural resource" (page 122). In 2025 the Group "updated the Sustainability and Safety, Health, and Environment Policies, replacing the previous ones", aligned to the SDGs, the Paris Agreement and the UN Global Compact (page 122).

"Acerinox's Sustainability Policy establishes the efficient use of water and the protection of ecosystems as operating principles, linking these targets directly to the strategic management of its IROs", and "the Health, Safety and Environment Policy is dedicated to protecting nature, which includes managing and consuming water resources responsibly... These policies apply to all entities within the Acerinox Group, including those in water-stressed areas" (page 122). "The Board of Directors oversees compliance with both policies, which are available on the Company's website."

Sourcing is described per site: rivers at NAS, Roldán and VDM Metals, swamps at Acerinox Europa, reservoirs at Columbus Stainless, public supply at Inoxfil, Haynes and VDM Metals; "No production center sources marine resources, whether biological or non-biological" (page 122). Marine discharge is limited to "the Acerinox Europa plant, which is the only operating center that discharges into the marine environment", into the Bay of Algeciras under a Monitoring and Control Plan (page 123).

Reference: pages 123-125.

Milestones and 2026-2030 challenges are tabulated: collaboration with the CEO Water Mandate and an improved CDP Water rating; the water footprint model for the high-performance alloys division, then for Haynes; "Reduction and continuous improvement in Blue and Gray Water Footprints"; and "Investments to improve the quality of water management data" (page 123).

Resources: "In 2025, CAPEX allocated to the management of the Company's water resources is estimated at €0.9 million (€1.2 million in 2024) and OPEX at €55 million (€50 million in 2024)", expected to stay in a similar range (page 123).

Named initiatives (page 124): water footprint measurement; "Optimization of pickling processes and neutralization plants to minimize chemical consumption and maximize effluent reuse in our main factories"; water quality analysis covering suspended solids, nitrates, pH, alkalinity and metal content; collaboration with "consortia, hydrographic confederations, government authorities"; and SDG 6. "Over the past five years, Acerinox has managed water resources effectively without any significant incidents".

The footprint uses the Water Footprint Network methodology for blue and gray water with WRI water stress projections; "Currently, 2 of the main factories... are located in regions with a level of water stress considered high or very high" (pages 124-125).

Reference: pages 125-126.

"In 2020, the Group incorporated water resource management into its 360º Positive Impact Plan... set the target of a 20% reduction in water consumption intensity by 2030, using 2015 as the baseline" (page 125). That target was met: "In 2024, once the specific water withdrawal target for 2030 was achieved, a new annual target to reduce blue water footprint intensity by 3% at Group level was established, effective as of 2025. Starting this year, targets will also be set on a plant-by-plant basis, linked to reducing blue and gray water footprint intensity" (page 125).

The target was missed in its first year: against the 3% annual reduction, blue water footprint intensity excluding Haynes moved from 2.03 to 2.56 m3 per metric ton, a 26.11% increase, which the Company attributes to "the production profile of the factories" (page 125).

The Company discloses the limits of its own target-setting: "the blue water footprint target was defined based on estimated production capacity and industry benchmarks, without considering conclusive scientific evidence or ecological thresholds. No stakeholder involvement was considered, nor was any analysis of trends" (page 125). It adds that "The definition of water related targets is carried out voluntarily", that no marine targets are set "Since the Acerinox Group does not rely on marine resources", and that "As of now, there is no defined target for reducing water consumption" (page 125).

Reference: pages 126-129.

Water consumption was 3,107,876 m3 in 2025 against 1,647,162 m3 in 2024, of which 1,602,732 m3 in water-stressed areas, all of it in the stainless steel division (page 126). The rise is explained as "due to the inclusion of Haynes in the reporting perimeter and the recovery of Acerinox Europa production following the strike" (page 127). Intensity rose 76.69%, from 0.30 to 0.54 m3 per € million of net income (page 127).

Withdrawal totalled 8,694,353 m3 (5,818,316 m3 in 2024): surface water 7,211,190 m3, third-party 1,180,493 m3 and rainwater 302,670 m3, with groundwater, seawater and process water nil; 3,219,596 m3 came from water-stressed areas (page 127). Discharge totalled 5,586,477 m3: surface 3,332,535 m3, seawater 1,442,541 m3, third-party 811,401 m3 (page 128).

The water footprint table gives blue footprint 4,950,396 m3 (1,930,687 m3 in 2024) at 2.56 m3 per metric ton, gray footprint 1,160,739 m3 at 0.60, and total 6,111,135 m3 at 3.17 (page 129). "Only the NAS and Roldan plants have a gray water footprint", and Haynes, VDM Metals USA and Bahru are excluded. The 2024 blue footprint "has been restated due to the availability of improved information, without affecting comparability with 2025."

Controls: "Volumes are accounted for daily through flow meters and verified annually by a third party", "Acerinox does not store water" (page 126), and recirculated-water data is still being developed.

Reference: pages 130-131.

Acerinox "developed and implemented sustainability and responsible procurement policies setting out the fundamental principles that guide the Group's procurement, production and distribution activities", so that "operations are conducted in an ethical and environmentally-friendly manner" (page 130).

The waste hierarchy is addressed: "both the Sustainability Policy and the Health, Safety, and Environment Policy 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 130).

The Health, Safety and Environment 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" (page 130).

Scope and oversight: "Both policies, approved by the Board of Directors in 2025, facilitate improved management of IROs. These policies are mandatory for all Acerinox Group entities, which will ensure that their principles extend to the business partners forming part of their activity chain. Compliance... is overseen by the Board of Directors, and the policies are available to stakeholders on the Acerinox website" (page 131).

Reference: page 131.

"Acerinox prioritizes the use of scrap as a strategic raw material, achieving utilization rates of up to 90% to maximize the circularity of its production processes. This action serves as a driving force for the 2025-2030 Decarbonization Plan" (page 131).

Acerinox "invests on an ongoing basis in developing cutting-edge solutions for the recovery and recycling of a wide range of alloys", exploring "innovative solutions to optimize resource use (particularly raw materials and ferroalloys)". It is explicit that "The Company is not currently engaged in any industrial symbiosis processes" (page 131).

Value chain actions run both ways: "Acerinox helps reduce waste generation upstream in the value chain by promoting the use of bulk supplies and/or recyclable packaging", and downstream it "maximizes the use of recycled material for customer shipments and recyclable packaging (cardboard, plastic and metals)" (page 131).

Resources: "In 2025, we worked on increasing the granularity of the information reported on investments and expenditures related to the circular economy, estimating CAPEX of €0.8 million and OPEX of approximately €50 million (in 2024, this information was not detailed)", expected to stay in a similar range (page 131). Environmental Product Declarations give customers "quantitative, verified information on the environmental impact of its products throughout their life cycle" (page 131).

Reference: pages 131-132.

"Acerinox's goal is to recycle 90% of all waste generated in own operations by 2030. This goal has not been set in response to any regulatory requirement but was established by the Group on a voluntary basis" (page 131).

Progress went backwards in 2025. The target table records 90% waste recycled for the Acerinox Group, with a degree of progress of 79.36%, a -3.56% move against 2024 (page 132). The cause is given under E5-6: "the recycling rate fell compared to the prior fiscal year due to adjustments in production profiles" (page 136). The 2025 variable remuneration target of an 84% recycling ratio, a 2.1% improvement, was therefore missed (page 90), and the 2026 target has been reset to 81% (page 91).

Governance of the target is described: "the environmental officers at each facility site monitor progress on a monthly basis, while the corporate sustainability team conducts periodic reviews and consolidates the data. In addition, the Sustainability Committee is responsible for quarterly monitoring and any necessary corrective measures" (page 131).

Two limits are stated by the Company itself: "The 2020 target did not take into account conclusive scientific evidence nor ecological thresholds. Stakeholder participation was also not considered", and "Acerinox has not currently established additional targets related to the resource use or circular economy" (page 132).

Reference: pages 132-133.

"During the melting process, raw materials (scrap, ferro-alloys and other elements) are melted down to make stainless steel. Acerinox uses secondary materials such as scrap, reaching figures close to 90% of recycled material as inflows to the process. This percentage varies depending on the final product specifications. In the other stages, the main raw materials used are chemical products (acids and gases) for surface treatments and process adaptation, as well as packaging materials" (page 132).

Total inflows were 2,656,847 metric tons, "7% higher than 2024 (2,484,371 metric tons)" (page 133). Recycled materials totalled 1,823,756.78 t: scrap and metals 1,809,628.18 t, recycled acids 14,006.63 t, other recycled material 121.97 t. Virgin materials totalled 833,090.22 t: alloys 521,215.48 t, gases 271,609.93 t, acids 40,264.80 t. As shares, scrap and recycled metals are 77.64%, recycled acids 34.79%, and recycled materials 68.64% of total inflows (67.84% in 2024).

Definitions are given: scrap covers "process and internal scrap, as well as metal recovered from slag"; recycled acid is the "nitric and hydrofluoric acid recovered from the process itself"; and "Acerinox does not use biological materials in its production process". Data is from direct measurement or periodically reviewed inventories and "has not been verified by an independent external body beyond the verification provider" (page 133).

Reference: pages 134-135.

Products: "The Company's product is based in the circular economy: 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 134). Durability is explained through the passive layer: chromium "forms a self-regenerating surface layer (passive layer) that provides corrosion resistance and ensures the steel's indefinite durability under normal conditions", with loss of passivity at "mechanical joints, compact corners, or incomplete or poorly finished welds" (page 134).

Volume and recycled content: "Factory production amounted to 1,911,276 metric tons in 2025 (1,828,133 metric tons in 2024), of which 68.65% came from recycled material. Additionally, 77.64% of scrap and other metals are recycled" (page 134). Applications span "transport, industrial equipment and engineering, construction and infrastructure, the food industry, household appliances and kitchenware, as well as energy and environmental technology" (page 134).

No expected durability in years relative to industry averages, and no recyclable-content rate for packaging, are disclosed. "Each factory monitors the output of Acerinox Group's products using software tools", and "The data has not been verified by an independent external body beyond the verification provider" (page 134). Waste outflows from the same section are captured under the Waste entry.

Reference: pages 134-136.

Total waste was 1,332,597 metric tons in 2025 against 1,172,638 t in 2024, a 13.64% rise attributed to "the increase in melting shop production in 2025 of around 7% compared to 2024" (pages 135). Of the total, 1,057,605 t (79.36%) was recycled or recovered and 274,992 t (20.64%) landfilled, against 82.29% and 17.71% in 2024 (page 135).

By hazard class: non-hazardous waste was 1,238,305 t (92.92%), of which 1,024,003 t recycled and 214,302 t landfilled; hazardous waste was 94,292 t (7.08%), down from 131,477 t, of which 33,602 t recycled and 60,689 t (64.36%) landfilled (page 135). By stream: metal-bearing wastes 1,188,762 t, sludge and chemicals 114,009 t, and paper, wood, plastic and others 29,825 t (page 135).

Treatment routes are named: "The recovery operation carried out by Acerinox is recycling. Disposed waste is landfilled. No other disposal operations are performed"; "Metal-containing wastes from the steelmaking and rolling mill processes (such as slag, smoke dust and scale) are recovered by specialized companies and reincorporated into the production process"; hazardous and non-hazardous chemical waste and water treatment sludge go "for recycling by specialized companies"; and "Acerinox's processes do not generate radioactive waste" (page 135).

A five-year recycling series is charted at 77.1% (2021), 70.1% (2022), 79.8% (2023), 82.3% (2024) and 79.4% (2025) (page 136).

Reference: pages 138-140.

"The Code of Conduct, updated in 2025, is the cornerstone that guides conduct related to people and the workplace... This code guarantees dignified treatment, non-discrimination and equal opportunities, the safety and health of all people working at Acerinox facilities" and reaffirms "the absolute prohibition of child labor and any form of labor coercion" (page 138). It covers discrimination "based on race, nationality, origin, sex, sexual orientation, marital status, age, religion, ideology, disability or any other personal, physical or social condition", in the Group's own activities and those of its Business Partners.

Policies approved by the Board in 2025 include the Human Rights Policy, "aligned with the UN Universal Declaration, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises... the conventions of the International Labor Organization"; an Equality, Diversity and Inclusion Policy; the Work Selection and Promotion Policy; the Corporate Whistleblowing Channel Policy, which carries "an express prohibition of any type of retaliation"; and the Sustainability Due Diligence Policy (pages 138-139).

Spanish companies also hold Equality Plans, with new plans negotiated in 2025 at Acerinox S.A., Acerinox Europa, Inoxfil and Inoxcenter (page 139).

Reference: pages 140-141.

"The Acerinox Group is committed to creating a work environment that fosters active collaboration both with its employees directly and with their representatives, through continuous two-way communication", with channels "ultimately driven and supervised by the Human Resources Department". "The information collected through these channels is assessed and used for decision-making and the deployment of measures and initiatives to manage the impacts, risks and opportunities related to the company's own staff that have been identified" (page 140).

A new instrument was introduced this year: "In 2025, a new global consultation process has been launched through an engagement survey. These surveys make it possible to systematically gather employee perceptions regarding key matters for the organization - such as job satisfaction - and to understand their needs, transforming impressions regarding satisfaction and work environment into concrete action plans" (page 140).

On worker representatives, the Company "promotes active collaboration with trade union organizations based on mutual respect and explicit recognition of their legitimacy as representatives of its own staff"; "Through regular meetings with employee representatives, the company and the unions jointly address working conditions, compensation, conflict resolution and mediation mechanisms, internal cohesion" and collective bargaining (page 140).

Reference: pages 140-141, 143, 173-175.

"all employees have access to the Group's whistleblowing channel, allowing them to report anonymously any irregularities or inappropriate behavior they observe. Likewise, through this channel, employees can report any health and safety danger that may pose a risk within the facilities or operations" (page 141). "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 141), and the Group "fosters a culture in which any employee can freely raise their doubts and concerns with their direct superior, contact the Human Resources department or approach the Compliance department directly" (page 174).

Channel design is set out in the business conduct chapter: reports "may be submitted anonymously and are in all cases treated confidentially", the channel "safeguards the rights of whistleblowers, related third parties and persons affected by the report", was "adapted to Act 2/2023, on the protection of persons who report regulatory violations", and in 2025 "the process of integrating and unifying the whistleblowing channels of all Group companies was completed" (page 173). Access runs through a digital platform, two email addresses, post, in-person meetings "within a maximum of seven days from the date of the request", and national telephone lines (page 174).

Reference: pages 141-145.

Actions are organised under four headings (pages 141-145). Safe working environment: risk analyses identify "ergonomic risks (repetitive strain injuries - RSI - and load handling), chemical risks (exposure to hazardous substances) and physical risks (noise, vibrations and temperature stress)"; ISO 45001 systems cover "Practically all staff, workplaces and activities for which Acerinox is responsible for control"; Process Safety Management principles draw on World Steel, the European Center for Process Safety and the Center for Chemical Process Safety; each facility has an Emergency Plan tested by drills. The process safety indicator shows 0 Tier 1 events and 7 Tier 2 events in 2025 (11 in 2024), a PSIR of 0.30 against 0.58 (page 142). "senior management and plant managers have objectives linked to improvements in accident rate performance", and a sustainability-linked loan targets "improving the LTIFR indicator by 5% compared to the previous year" (page 142).

Absenteeism is addressed case by case with "constant communication with employees and service providers" and training for middle managers (page 142). Talent attraction includes graduate programmes, "collaboration agreements with over 30 universities and training centers", the World Steel Steel Challenge and hiring of people over 50 (page 143).

Reference: pages 145, 90-91.

Two measurable workforce targets are disclosed, both tracked in the variable remuneration scheme. On gender, "Acerinox has continued to make progress towards its strategic target of achieving 15% female representation on staff by 2030. Specifically, this year, 14.6% were women (13.39% in 2024)", against a 2026 milestone of 14.71% (pages 145, 91). On safety, "in 2025, a target was set to reduce the Lost Time Injury Rate (LTIR) by 10% compared to the previous year's target, achieving a decrease of more than 15%", and "Acerinox met the sustainable credit target linked to the reduction of the LTIFR with a score of 3.01 compared to the target of 3.42" (page 145). The 2026 target is 2.9 LTIFR (page 91).

Beyond these two, the Company states a nil return: "No material objectives that warrant disclosure have been identified in the other areas of this topic. The established processes are embedded within the departments responsible for daily compliance with the Company's policies in this area. Policies and actions are mainly monitored by analyzing the primary employee contact tools, as noted in previous sections" (page 145).

So there is no target for absenteeism, training, pay gap, collective bargaining coverage or disability employment, even though the first two are named as material IROs in Annex 8.5 (pages 215, 218).

Reference: pages 146-147.

Headcount at year end was 9,139 employees against 9,293 in 2024, split 7,801 men and 1,338 women, with "Other" and "Not reported" both nil (page 146). By contract type: 8,953 permanent, 186 temporary, 0 non-guaranteed hours; 9,045 full-time and 94 part-time. The gender breakdown of permanent staff is 1,313 women and 7,640 men (page 146).

By country, for countries with 50 or more workers: United States 3,184, Spain 2,564, Germany 1,825, South Africa 1,226, Malaysia 48, Italy 46, and 246 in other countries (page 146). By region: Europe 4,579, America 3,219, Africa 1,226, Asia 106 and Oceania 9, with the same breakdowns by contract type and working time (page 147).

Turnover is disclosed with its components: "In 2025, 986 employees left the company (575 in 2024). Of these, 340 were layoffs (126 in 2024), 525 were voluntary resignations (312 in the previous fiscal year) and 121 were retirements (137 in 2024). Thus, the total turnover rate for the year was 10.79% (in 2024 it was 6.19%)", calculated on year-end headcount, with a restated 2024 comparative. "The Group's voluntary turnover rate in 2025 was 7.07%", against 4.83% in 2024 (page 147). Exit interviews are used "as a tool to identify opportunities for improvement and detect reasons that influence employee turnover".

Reference: pages 137, 146.

Indexed at page 146 alongside S1-6. The population is defined in the S1 SBM-3 section: "Acerinox also collaborates with external professionals who, despite not being part of the permanent workforce, add significant value to the business. The Group has subcontractors through Temporary Employment Agencies (TEAs) (at year-end 2025, the Group worked with 1,650 contractors), as well as a few freelance professionals hired in certain cases. These hirings correspond to specific needs or specific moments" (page 137).

The reporting boundary is stated plainly: "the information regarding staff and the pay gap detailed in this report refers exclusively to the Group's salaried staff. In those cases where contractor staff information is presented, it is duly specified" (page 137). The employee table confirms the point, recording "Number of non-guaranteed hourly employees" as 0 across all regions and both years (pages 146-147).

So a single headcount is given for non-employee workers, without the ESRS split between self-employed people and people provided by undertakings primarily engaged in employment activities, and without a country or region breakdown.

Non-employee workers are nonetheless inside the scope of several qualitative S1 disclosures.

Reference: pages 147-148.

"Globally, as of December 31, 2025, 59.96% of employees are covered by labor negotiation frameworks (60.36% in 2024)" (page 148).

"In Spain, 100% of employees and operating centers have negotiated collective bargaining agreements, and 97% of employees are represented by unions or workers' representatives. In this geographical area, Acerinox has more than 10 different collective bargaining agreements. These form the basis of the social dialogue framework within which the mutual interests of the Company and its employees are addressed" (page 147). "In addition, the Acerinox Group includes its employees in collective bargaining agreements in Italy, Germany, South Africa and the United States, all of which are represented by an internal body or by a sector union" (page 148).

A banded table reports coverage for countries with more than 50 employees, separating EEA and non-EEA employees and showing on-site representation for the EEA only. For 2025 it places Malaysia in the 0-19% band, the United States in 20-39%, South Africa in 40-59%, and Germany and Spain in 80-100%; the 2024 column shows the same pattern with the United States and Malaysia swapped between the two lowest bands (page 148).

Reference: pages 148-150.

Gender distribution at top management is given in two tiers: "the Acerinox Group consists of 7,801 men and 1,338 women (7,944 men and 1,349 women in 2024). The total number of directors is 30, with 24 being male and 6 female. The next management tier comprises 405 managers (323 male and 82 female). In 2024, the Company had 33 directors, with 28 male and 5 female directors, while there were 320 male managers and 82 female managers" (page 148). Group-wide, women are 14.6% of the workforce against 14.5% in 2024 as charted (page 149).

Age distribution is reported in the three ESRS bands: "<30 years 1,064; 30-50 years 4,846; >50 years 3,229", total 9,139, against 1,099, 5,023 and 3,171 in 2024, with the Company noting "a higher representation of older age employees" (page 150).

Supporting initiatives are named: progressive increases in "the presence of women in the technical maintenance area of several production centers... particularly noteworthy at the operational level, where they have been less represented up to this point"; the Progresa Program backed by Foment del Treball, CEOE and Esade; the Women in Steel workshop and UNESID's Women of Steel platform; Girls' Day at VDM Metals; a Women in Steel day at NAS; the CEO Alliance for Diversity; and the Empowering Women's Talent programme, in which "A total of 118 women participated... in 2025" (pages 148-150).

Reference: pages 141, 143.

Indexed at page 141, the start of the "Measures to manage impacts, risks and opportunities related to employees" section, which carries the label "S1-3, S1-4, S1-10, S1-11, S1-13, S1-15".

The adequate wages statement is a blanket assertion of compliance above a benchmark: under Stable and Quality Employment the Company reports that it "has carried out an objective job evaluation under a certified system in order to ensure a fair, neutral and unbiased structure. It also periodically reviews the salary tables in order to be competitive and ensure fairness. In addition, it guarantees fair remuneration in all the regions where it operates, ensuring salaries that are four times the living wage standard of each country" (page 143).

Supporting framework: the remuneration system "consists of a fixed salary, determined exclusively by objective criteria such as career history, level of responsibility and professional category in the organizational chart, plus variable compensation, which is linked to the achievement of individual and departmental key performance indicators (KPIs), as well as the Group's financial results" (page 156), and Spanish Equality Plans include "equal pay for men and women" measures (page 139).

No percentage of employees paid below an adequate wage is reported, and no country is identified as falling short, because the Company asserts that all employees are above the applicable benchmark by a factor of four.

Reference: pages 141, 144, 148.

Indexed at pages 141 and 148. The substantive disclosure sits under Working conditions: "The Company provides social protection for its employees against income loss due to life events such as illness, unemployment, work-related accidents, acquired disability, parental leave, or retirement. Other social benefits are also offered, such as health insurance, school assistance, transportation assistance and meal tickets or pension funds, among others. These position the company as a leading employer" (page 144). The same benefit list appears in the S1 strategy section (page 138).

That list names all of the major life events covered by the ESRS datapoint, and the statement asserts coverage without exception rather than reporting residual gaps. No country is identified where employees are not covered for one or more of the listed events, and no percentage of employees covered is given.

Reference: pages 148-149.

"To promote the inclusion of groups that have had difficulty entering the labor market, such as people with disabilities, the Group's strategy includes two lines of action. First, enhancing employability and directly hiring persons with disabilities. By the end of the financial year, Acerinox employed 253 persons with disabilities (217 men and 36 women). In 2024, the Group had 258 people with disabilities (227 male and 31 female). Second, Acerinox engages in initiatives and programs to raise awareness and provide training on disability issues for its employees" (page 149).

On a year-end headcount of 9,139, the 253 figure is 2.8% of the workforce, though the Company does not itself compute or disclose the percentage, and does not break the figure down by country or note which legal definitions of disability apply in each jurisdiction.

A positive impact in this area is one of only two S1 impacts in the material IRO list: Annex 8.5 records "Reassignment to an adapted job in case of incapacity or disability" under the sub-topic "Employment and inclusion of people with disabilities" (page 215), and the S1 actions section confirms that "if an accident occurs leading to incapacitation or disability... the Group has procedures in place for job relocation and role adaptation" (page 143).

Reference: pages 150-155.

"In 2025, the average number of training hours per employee was 58.2 hours, similar to the average number of training hours in the previous year (58.8), an average of 62.3 training hours for men and an average of 39.7 training hours for women (61.4 hours for men and 48.51 hours for women in fiscal year 2024). The average training expenditure per employee was €360. (€336 for men and €499 for women)" (page 151).

Totals and breakdowns are given by professional category and gender across three tables: 7,143 employees trained (7,173 in 2024) and 527,936 total training hours (542,031 in 2024), with operators accounting for 4,645 of those trained and 475,867 hours at an average of 102.4 hours each, against 15.3 hours for directors (pages 151-153).

Performance review coverage is reported and fell sharply: "At the end of 2025, 41% of employees participated in this performance evaluation. 40% of the Group's men participated, while 49% of women did. In 2024, 50% of employees had a performance evaluation (48% of men and 61% of women)", with the cause stated in a footnote as "the temporary suspension of the performance evaluation process at the Columbus factory. This process will resume in 2026" (page 153). The number assessed fell from 4,438 to 3,615, with the administrative staff rate dropping from 39% to 13% (pages 154-155).

Reference: pages 156-158.

Coverage: "91% of the Group's employees (90% in 2024) work in facilities that have occupational health, safety, and welfare management systems certified under the ISO 45001 and ISO 14001 standards", being 8,298 of 9,139 employees (page 156).

Own workforce, 2025 against 2024 (page 158): hours worked 16,939,570 (13,843,592); recordable accidents 124 (124); fatal accidents 0 (0); accidents with leave 56 (60); TRIR per million hours 7.32 (8.96); LTIFR per million hours 3.31 (4.33); severity rate 6.65 (7.54); absenteeism rate 5.32% (6.03%); work-related illnesses 23, up from 9; fatalities due to work-related illnesses 0. "There are no excluded workers."

Contractors are reported separately (page 158): hours worked 6,278,791 (5,197,375); recordable accidents 34 (33); fatal accidents 0, against 1 in 2024; accidents with leave 14 (12); TRIR 5.42 (6.35); LTIFR 2.23 (2.50). "Data on contractor absenteeism and contractor occupational diseases are not recorded."

Group headline rates are given in a separate table: LTIFR 3.01 against 3.83, TRIR 6.80 against 8.25, and TIR 19.21 against 19.12 (page 157). Note a tension on the face of the report: the narrative states "The main benchmarks have improved by 15% for the LTIFR and 16% for the TIR, including Haynes International operations" (page 156), yet the TIR row moves the wrong way, from 19.12 to 19.21.

Reference: pages 155-156.

"At Acerinox, we understand that work-life balance is essential. As a result, the Group has set as one of its strategic goals upholding work-life balance rights and related leave" (page 155).

Entitlement: "With regard to paternity or maternity leave, in Spain, other European countries such as Sweden, Portugal and Germany, and in the United Kingdom and the United States, 100% of employees are entitled to take parental leave. In all cases, the legislation in force in each country applies." Employees are also "entitled to other paid leave to care for family members", and "in other regions such as Colombia, Peru, Singapore and India, workers are granted different rights and family leaves" (page 155).

Take-up is reported with the return-to-work rate: "In 2025, 7,684 were eligible for parental leave (9,132 in 2024). Of these, a total of 266 enjoyed paternity and maternity leave (216 men and 50 women). In fiscal year 2024, 241 employees (201 men and 40 women) took leave. In addition... a high level of return-to-work was maintained, with 251 of the 266 employees who took this leave returning to work. That is, the return-to-work rate in 2025 was 94%; in 2024, 95% of employees returned to work (99% of men and 75% of women)" (page 155).

Note that the eligible population fell from 9,132 to 7,684 while headcount fell only from 9,293 to 9,139; the report does not explain the change in the eligibility base.

Reference: page 156.

"The wage gap for 2025 is 11.54% (6.74% in 2024). This was calculated as the average gross hourly pay of male employees minus the average gross hourly pay of female employees, divided by the average hourly pay of male employees. For this purpose, the number of hours worked by men and women reported in the calculation of accident rates (S1-14) was taken into account" (page 156). That is the ESRS formula applied as prescribed, with the hours base disclosed.

The near-doubling is explained in a footnote: "The increase in the wage gap in 2025 compared to the previous year is due to a variation in the volume of hours worked. This change is primarily explained by the extension of the reporting scope to include Haynes International (the working hours of which were not included in the 2024 figures) and by the normalization of operations at Acerinox Europa, as the volume of hours worked in 2024 was lower due to the strike at that factory" (page 156). So the comparative is not like for like.

Structural causes are given: "the late entry of women into the steel industry and the weight of pay linked to seniority and shift work, where the male presence is mostly higher due to the historical configuration of the workforces" (page 156).

Pay ratio: "the total annual compensation of the highest paid senior manager is equivalent to 18 times the average salary of the rest of the workforce (32 times in 2024, excluding the highest-paid officer)" (page 156).

Reference: pages 159, 175-176.

"In 2025, 57 complaints were received (56 in 2024). After investigation, it was determined that seven of them did not fall within the scope of the whistleblowing channel. Of the remaining 50 cases, 64% were found to involve breaches of internal regulations or applicable laws (in 2024, non-compliance was identified in 68% of cases). Once they had been analyzed, it was found that there had been no human rights violations" (page 159).

The business conduct chapter breaks the same population down. By subject, "The majority of breaches, 71%, related to human resources matters, predominantly cases of inappropriate behavior, unfair treatment and discrimination", and "For all complaints where violations were found, corrective and/or disciplinary actions were taken" (page 175). By geography, 19 reports came from Spain and 38 from other geographies, against 27 and 29 in 2024 (page 175). By type: inappropriate conduct 27 (14 in 2024), other breaches 16 (9), safety and health 4 (9), fraud 3 (4) and corruption or bribery 0 (2), with inappropriate conduct covering "instances of disrespect, microaggressions and unfair treatment" (page 176).

Corrective actions taken in 2025 were 12 training, mentoring and coaching measures, 6 communication enhancements, 5 written or verbal warnings, 3 layoffs, 3 referrals to police or authorities and 3 process and procedure improvements (page 176).

Reference: pages 160-161.

"Having been approved by the Board of Directors in 2025, the Company's Sustainable Procurement and Human Rights Policies set the road map for the entire Group. These frameworks define the ethical and environmental behavior expected in each purchase, placing respect for human rights as a strategic priority" (page 160). Internal rules, "most notably the Code of Conduct", are aligned with "the UN Guiding Principles, the OECD Guidelines for Multinational Enterprises, the ILO Tripartite Declaration on Multinational Enterprises and its fundamental conventions, the Sustainable Development Goals (SDGs) and the UN Global Compact" (page 160).

Extension to suppliers runs through the Business Partner Code of Conduct: "Acceptance of this code is an indispensable contractual requirement that imposes rigorous labor, ethical and environmental standards, including the responsibility to declare the use of 'conflict minerals' under the guidelines of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas" (page 160). Coverage: "in 2025, 3,186 suppliers ratified these guidelines, an increase of 90% over the 1,676 of the previous year. This meant reaching a coverage of 77.8% in the strategic supplier segment and moving steadily towards the final target of 98%" (page 160).

Reference: pages 159, 161-162.

Channels: "While the corporate website acts as a public repository of requirements and policies, the Supplier Portal has been consolidated as a comprehensive management tool for document operations, approvals and performance evaluation. Given its strategic importance, the Business Partner Code of Conduct is always accessible and highlighted on both platforms" (page 161). Dialogue runs "mainly through the Purchasing Department, relying on active listening tools such as the Supplier Portal, corporate mailboxes, meetings with suppliers and on-site audit and verification programs" (page 159).

The grievance route is open to the whole chain: "One of the Acerinox's pillar of integrity culture is the whistleblowing channel, a secure channel accessible for its entire value chain... This policy strictly prohibits any retaliation, threat or attempt against whistleblowers acting in good faith" (page 161).

2025 initiatives are quantified (page 162). Supplier Satisfaction Survey: "After a pilot test in 2024 limited to a single plant (220 suppliers and 90% satisfaction), in 2025, it was extended to 300 significant suppliers at Group level. This call resulted in a response rate of 36% and a satisfaction index of 95%, thus achieving an increase of 5 percentage points". Suppliers Day: a face-to-face event at VDM's facilities "with 18 key companies in the expansion project".

Reference: pages 161-163.

The channel for value chain workers is the Group whistleblowing channel, described as "a secure channel accessible for its entire value chain. This system allows people to report irregularities or ask questions with complete confidentiality. The model is governed by a specific Group Policy that guarantees transparency in management and, above all, the protection and rights of the people who use it. This policy strictly prohibits any retaliation, threat or attempt against whistleblowers acting in good faith" (page 161). Full access details, including the digital platform, email addresses, postal address, in-person meetings within seven days and country telephone lines, are set out in the business conduct chapter (page 174), and management of the channel "is outsourced to ensure maximum independence" (page 175).

On safety hazards specifically: "Potential hazards are also reported through preventive observations and the whistleblowing channel. Acerinox monitors all safety incidents in its operations and investigates and implements the necessary corrective and preventive measures" (page 163), and Management of Change analyses are run "when changes occur in facilities or operations".

Reference: pages 162-165.

On the main negative impact, contractor health and safety, Acerinox "incorporates the Six Safety and Health Principles of World Steel", including "All injuries and work-related illnesses can and must be prevented" and "Working safely is a condition of employment" (page 162). "in 2025 Acerinox launched a Process Safety Framework aligned with international industry benchmarks", aimed at "Avoiding containment loss of chemicals with potentially serious consequences for people, the environment and assets" (pages 162-163). The Group "designs specific emergency plans and continuous training programs for contractor staff", and "senior management and factory management... have targets directly linked to performance in accident rates" (page 163).

On positive impacts, the Strategic Procurement Plan 2025-2029 carries "a road map overseen by the Audit and Sustainability Committees of the Board of Directors" (page 163). Quantified results: the supply chain has been mapped, leading to "the identification of 52 single-source suppliers, for which specific mitigation plans are already being implemented"; "2,928 ESG assessments were completed in 2025, an increase of 92.6% compared to the 1,520 completed in 2024" (page 163). Training: "In 2025, a total of 154 of the Group's suppliers started this specialized ESG training, and 56 of them successfully completed it" under the UN Global Compact programme (page 164).

Reference: pages 165-166.

Three tracked indicators with targets are disclosed, and the Company frames them as monitoring "the economic and operational impact of its supplier base to ensure business resilience, leverage opportunities and mitigate risks for workers in the value chain" (page 165).

Local sourcing, against targets of 80% of suppliers and 60% of expenditure: 2025 actuals were 90.78% of 8,340 suppliers (78.49% in 2024) and 75.24% of €4,462,789 thousand of expenditure (63.36% in 2024), both comfortably ahead of target (page 165).

Strategic concentration: spending on strategic suppliers rose from 42% to 43% of total spending, and the Company states the indicator "was increased from 2024 to 2025, with the aim of stabilizing in a range of 50-60% of total spending", noting that "the 'strategic supplier' criteria changed in 2025, becoming more restrictive in order to increase efficiency" (pages 165-166).

ESG assessments: strategic suppliers (category A) numbered 193, 2.31% of total suppliers, down from 346 and 4.72% on the tightened definition; 186 were evaluated on ESG criteria, 96.37%, against a 90% target, up from 43 and 12.43% in 2024; and 2,928 suppliers in total were evaluated, 35%, against a 40% target, up from 1,520 and 21% (page 166). "Looking ahead to 2026, the goal is to increase our ambitions, aiming to evaluate 98% of strategic suppliers and 50% of total suppliers" (page 166).

These are process and spend targets.

Reference: page 168.

"Acerinox's strategy is based on a framework of policies designed to ensure excellence in service and integrity in business relationships. The Group has a set of internal rules and procedures that regulate interaction with the market, ensuring that each transaction is carried out under standards of transparency and responsibility" (page 168).

Two instruments are named. The Standard Terms of Sale "are the legal basis for all commercial transactions, detailing the terms applicable to the purchase and sale of products. This framework sets out key aspects such as payment terms, applicable taxation and possible price variations. Delivery times and locations are also established, along with the logistical responsibilities of each party in the transportation process. With regard to quality, these conditions include product standards, warranties offered and limits to liability in the event of contractual non-compliance or technical defects" (page 168).

The Code of Conduct "reflects the Group's commitment to compliance with manufacturing standards. This document establishes that commercial relations must be based on mutual benefit and a constant attitude of service, always under the umbrella of honesty and professional responsibility" (page 168). The EU-legislation datapoint table maps the S4-1 UNGP and OECD datapoint to "S4-1: Consumer and end-user policies" (page 225).

Reference: pages 167, 169.

"Acerinox performs an exhaustive analysis of the satisfaction surveys and complaints received in order to strengthen customer relations and mitigate risks. Annually, the Group launches surveys that measure its Net Promoter Score (NPS) and evaluate three topics: satisfaction, brand image and strategic positioning. After a month of compilation and follow-up, the Sales Department prepares reports by geographical area and annual comparisons in order to design specific action plans" (page 169).

"This comprehensive analysis allows us to identify that customers' main priorities are product quality, delivery times and incident resolution" (page 169).

The strategy section describes the same loop: feedback "is gathered through active listening, which includes surveys, technical visits and close contact with each customer as a result of the relationship that the Company's sales network establishes with all of them. In this way, critical needs are identified in order to transform these into action plans that reinforce our value offering, such as the Customer Portal, the Acerinox Direct e-commerce platform and new types of steel tailored to the specific needs of customers, in addition to products such as Lean Duplex and our sustainable EcoACX®" (page 167).

Reference: page 169.

"the Group manages complaints on a daily basis through its ERP systems to provide immediate solutions. This procedure guarantees 100% traceability and classifies incidents into two categories: Technical: Deriving from manufacturing problems and managed by the factory's Technical Department. Sales: Related to sales management or transport damage, resolved by the Sales Department" (page 169).

The procedure is formalised: "This procedure is included in the Commercial Instructions Procedure (CIPS) duly authorized and validated by Sales Management. These procedures clearly delimit and specify targets, scope, procedure flows and responsibilities (as well as exceptions, if any). In particular, this adds some service level agreements (SLA) to the previous procedure that must be complied with according to the type of complaint" (page 169).

A second, independent route is available: "As an additional channel of communication and transparency, customers also have access to the whistleblowing channel, where they can submit queries and report infractions" (page 169). That channel is described in the business conduct chapter as open to "all employees and external stakeholders", anonymous and confidential, with management outsourced "to ensure maximum independence" and oversight by the Ethics Committee and the external auditor (pages 173-175).

Reference: pages 169-170.

"To optimize incident management and keep customers satisfied, Acerinox relies on an internal and external communication system that prioritizes transparency and channel accessibility. The Sales Network is the cornerstone of this system... This structure allows early problem detection while providing personalized responses to customer concerns", with responses ranging "from the activation of the formal complaints channel to an in-person visit by technical-sales staff from the subsidiaries or factories for an on-site assessment" (page 169). A Sector Manager "acts as a specialized point of contact for each activity sector", ensuring "that issues are escalated appropriately if necessary".

The complaint handling process runs in three phases: "Centralized recording: Immediate recording of any incident in the ERP system. Assignment of responsibilities: Designation of a specific person responsible for case management. Scalability: In highly complex situations, the incident is handed up to higher levels of the organization." "Each claim is fully traceable from opening to closure, allowing customized action plans to be implemented. The ultimate goal is risk mitigation to avoid the recurrence of detected events" (page 169).

Reference: page 170.

A nil-target return, stated in full: "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 170).

So no measurable outcome-oriented target is set for consumers and end-users, and effectiveness is tracked instead through the engagement and complaint tools described under S4-2, S4-3 and S4-4: the annual Net Promoter Score survey covering satisfaction, brand image and strategic positioning; daily complaint management through the ERP with "100% traceability"; the service level agreements attached to the Commercial Instructions Procedure; and ISO 9001 audits at all service centres (pages 169-170).

The same form of words is used for the residual areas of S1-5 (page 145), so the phrasing is a consistent group-wide convention rather than a topic-specific judgement.

This leaves the one material S4 IRO without a target. Annex 8.5 records the risk of "Loss of customers due to missed delivery dates or compromised product quality" for own operations (page 219), and the report names "product quality, delivery times and incident resolution" as customers' main priorities (page 169), but no on-time delivery, defect rate, complaint resolution or satisfaction target is published against them.

Reference: pages 171-178.

"In October 2025, the Board of Directors approved the new version of the Acerinox Group Code of Conduct... the essential framework for conducting operations with integrity, respect human rights, engage in dialogue with stakeholders, adhere to legal requirements, provide a safe work environment, combat corruption, and maintain social and environmental responsibility" (page 172). Scope is set out in detail: it applies "without exception to the entire Acerinox Group", to all entities "regardless of their legal form" and all natural persons including governing bodies, senior management, employees, temporary employees, volunteers and associates, and the Group "will endeavor to ensure that these also extend to third parties" including suppliers, subcontractors, customers, consultants and agents (page 173). A separate code of conduct for business partners applies to suppliers, and "Non-compliance may entail a range of consequences in the contractual relationship".

The Ethics Committee "reports to the Board of Directors through the Audit Committee", oversees Code compliance and dissemination, interprets the Code, and "Annually... submits to the Audit Committee an annual report on the channel's operation, indicating the number of complaints received and their origin" (page 173). "Failure to comply with the Code may give rise to labor sanctions, which will be proportional to the nature and seriousness of the infraction" (page 173).

Reference: pages 178-180.

"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. The company has implemented a series of policies and technical guidelines that align with the United Nations Convention against Corruption" (page 178). Controls named 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", plus confidential reporting systems (page 178).

Risk assessment: "In the risk matrix, 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 for criminal compliance management systems". Identified offences are "influence peddling, bribery, illegal financing of political parties, business corruption, money laundering, corporate crimes, and fraud against public administrations" (page 178). Fifteen sensitive activities are listed, from public tenders and licence applications to "Receiving funds from clients, particularly those based in tax havens" (pages 178-179). "since Acerinox does not directly sell to governments or public administrations, the risk of corruption involving public officials in Acerinox's operations is low" (page 179).

Reference: pages 173, 177-180.

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Acerinox discloses no measurable outcome-oriented business conduct target. No figure, base year or target year is given for the two material G1 impacts in Annex 8.5, both under Corporate culture (page 216), and business conduct is absent from the five ESG indicators in the 2025 incentive scheme (page 88).

Consistent with the other limb of MDR-T, effectiveness is tracked instead. "The Program's monitoring, measurement, analysis, and evaluation are conducted in line with the annual Crime Prevention Cycle", running from a processes update, through "Monitoring self-assessment: dispatch of monitoring confirmation surveys", to "Evaluation and certification: assessment of criminal risks in light of the survey results; certificates of compliance are prepared and signed", and an "Action and training plan" (page 179).

Three further measures are reported. External certification: UNE 19601 was obtained after a 2024 AENOR audit, and "In 2025, Acerinox S.A. obtained ISO 37001 certification, with the intention of extending its scope to other geographies" (page 180). The Ethics Committee reports annually to the Audit Committee on complaints and corrective measures (page 173).

Reference: pages 176, 180.

"In 2025, no cases of corruption or bribery were found, nor did we experience any monetary losses arising from any corruption-related legal proceedings. However, two reports were filed in South Africa classified as fraud and malpractice related to the misuse of assets or theft. One case was dismissed; in the other, which was substantiated, the person responsible was dismissed. In both cases, corrective measures were implemented to prevent future incidents" (page 180).

The complaints table corroborates the nil return: cases of "Corruption or bribery" are 0 in 2025 against 2 in 2024, with the footnote repeating that the two 2025 South African reports were "classified as fraud and malpractice related to the misuse of assets or theft" (page 176). Other case types in 2025 were inappropriate conduct 27, other breaches 16, safety and health 4 and fraud 3 (page 176).

So there were no convictions and no fines for violation of anti-corruption and anti-bribery laws, which is the datapoint the EU-legislation table maps to this requirement under "ESRS G1-4 Fines for violation of anti-corruption and anti-bribery laws, paragraph 24(a)" and Delegated Regulation (EU) 2020/1816, Annex II (page 225).