Aerostar S.A.

Governance roles

Reference: pages 20-23, 126.

Governance is organised on four levels: the General Meeting of Shareholders, the Board of Directors, the Audit Committee and Executive Management (page 20).

Board (page 21). Five members elected by secret ballot on 4 July 2024 for a mandate running 11.07.2024 to 10.07.2028: Filip Grigore (President), Damaschin Doru (Vice-president), Filip Alexandru, Toncea Radu-Tudor, Doros Liviu-Claudiu. Two held executive positions in 2025, three were non-executive. It meets at least quarterly, "approves the Sustainability Report, delegates the achievement of sustainability objectives and targets to the executive management, and closely monitors the performance of these activities" (pages 21-22). The Explanatory Note states that "none of the members of the Board of Directors is independent, but none is in a conflict of interest" (page 4).

Audit Committee (page 22). Established 4 July 2024 under Law no. 162/2017; two members, Botez Daniel and Radu Florin, both accounting specialists; meets at least four times a year.

Executive Management (page 22). Filip Alexandru (CEO) and Damaschin Doru (Financial-Accounting Director), supported by nine operational managers (page 23).

Information provided to the administrative, management and supervisory bodies

Reference: pages 23-24, 126.

The Board "maintains constant contact with the executive management and operational management", and because two Board members hold executive positions "the administration has unrestricted and direct access to company information" (page 23).

A risk management officer position was created in March 2025 under the Bucharest Stock Exchange Corporate Governance Code. The officer "ensures direct communication and functional reporting to the Board of Directors and the Audit Committee and is responsible for the accurate, complete, and timely identification of risks, ensuring that appropriate and feasible risk control measures are in place and monitoring risk management procedures, including those related to sustainability matters" (page 23).

The Board receives periodic reports covering financial and operational matters, health, safety and workplace security, human resources, procurement, development and investment, community relations and philanthropic activities (page 23).

The report does not list which sustainability matters were addressed at named meetings during 2025, or when they were tabled.

Sustainability in incentive schemes

Reference: page 24, 126.

Aerostar discloses a clear negative. The remuneration policy for Directors and executive officers was approved at the Ordinary General Meeting of Shareholders for 24.04.2025 to 23.04.2029 (page 24). Each Director receives a fixed monthly remuneration approved by shareholders alongside the income and expenditure budget. The net fixed monthly remuneration of the CEO and the Financial Director is set by the Board within a cap "limited to ten times the net fixed monthly remuneration of the Board members" (page 24).

The company then states: "the remuneration for persons in Aerostar's management structure is linked to their entire scope of duties and responsibilities, with no incentive systems or remuneration policies specifically related to sustainability matters" (page 24).

No variable pay, bonus pool or ESG-linked metric is attached to sustainability performance, and no percentage of variable remuneration can therefore be linked to climate considerations. The policy is published on the company website and remains available throughout its period of applicability (page 24).

Risk management and internal controls over sustainability reporting

Reference: pages 24-26, 126.

Aerostar has "adopted a risk management policy that takes into account the strategy, nature, and complexity of processes and activities" (page 24). An Integrated Management System covers quality, environment, aviation safety, information security and financial risks, with the methodology in an internal procedure. "The risks presented in the chapter 'Managing Impacts, Risks and Opportunities', detailed at the level of each thematic sustainability standard, are the result of a double materiality analysis in accordance with ESRS/CSDR standards" (page 24).

The internal control system has four components (page 25): management control (asset inventory and transaction checks; in 2025 "no significant differences were identified compared with the accounting records"), budgetary control (a budget officer per structure, quarterly reporting by profit and cost centres), controlling (a compartment reporting to the CEO), and internal audit, staffed with personnel registered with the Chamber of Financial Auditors of Romania. In 2025 a new Internal Audit Charter was approved and an "Internal Audit Coordinator" function established; internal audit reports directly to the Board and Audit Committee (pages 25-26).

No controls specific to sustainability data collection or assurance are described.

Strategy, business model and value chain

Reference: pages 47, 49, 126.

Aerostar S.A. operates from Bacau (head office), Iasi (branch since January 2018) and Fetesti (2023) (page 6). Its principal activity is manufacture of civil aircraft and spacecraft, CAEN code 3031 (page 7), across three business lines: manufacture of aeronautical products, civil aviation MRO and defence systems. It is the National Maintenance Centre for the Romanian Air Force F-16 fleet, a maintenance centre for Ministry of Internal Affairs Black Hawk helicopters, and for Ministry of National Defence rocket launcher systems (page 7).

Strategy priorities (page 47) include continuous improvement of processes, "continuous compliance with environmental protection standards, all quality requirements, and national and international regulations", professional development of employees, efficiency and cost reduction, maintaining top employer status, and creating value for the community.

Value chain (page 49). Upstream: suppliers of materials, services and utilities, "a diversified range of suppliers in both civil and military aviation". Downstream: the Ministry of National Defence, the Ministry of Internal Affairs, companies in the civil and military aircraft manufacturing supply chain, and airlines. The business model "has not been modified as a result of the international context" (page 49). 2025 turnover was RON 620,433,575 (page 111) and headcount 1.874 (page 85).

Interests and views of stakeholders

Reference: pages 50, 75, 92, 96, 101, 115-116, 126.

Stakeholders, their level of interest and the communication channels used are tabulated in Annex 1 (pages 115-116). Sixteen groups are listed with a stated interest level, including shareholders and investors (high), employees (high), customers (high), suppliers (high), local community (high), trade unions (high), universities and technical colleges (high), industry associations and NGOs (medium), competitors (medium) and press and social media (medium).

Aerostar "has included in its Rules of Organisation and Operation both the relevant organizational context matters and the interests and expectations of stakeholders" (page 50). Educational institutions are treated as distinct stakeholders "effectively assimilated with communities, namely: the community of pupils, the community of students, the community of teachers, and the community of scientists" (page 50).

Topic-level restatements follow: employees are "considered the central group in reporting under ESRS S1" (page 75); value chain workers are workers of service and equipment suppliers, client representatives and workers of regulatory bodies (page 92); end-users are "the integrators of our products into the final product", airlines, and the two ministries (page 101).

The report does not describe how stakeholder views changed the strategy or business model during 2025.

Material impacts, risks and opportunities

Reference: pages 53-54, 59-60, 76, 92, 97, 101, 104, 126.

The double materiality assessment produced an unusually narrow result. Across 29 subtopics from the standards and two additional ones, every identified impact was assessed as not material and only two risks were financially material (pages 53-54):

"Two matters were identified, based on the severity threshold, as having financial materiality, and they are priorities for our company: FINANCIAL MATERIALITY: Product safety; Health and safety" (page 54).

• End-users (page 101). "Potential Negative: A decrease in end-user trust in the event of incidents", with the risk "of incidents affecting end-users if all applicable requirements are not complied with". The company states "The risk has financial effects".
• Own workforce (page 76). "a single potential negative impact, associated with a financially material risk, which relates to the occupational health and safety of the Company's own workforce", arising from "noise, vibration, physical strain, and substances specific to industrial processes".

Financial effects are not quantified: "the assessment was carried out mainly in qualitative terms" (page 54).

Every other topical chapter states the contrary, for example "The analysed impacts are not material and the risks do not present financial materiality" (pages 60, 65, 69, 73, 92, 97, 104, 108).

Processes to identify and assess material impacts, risks and opportunities

Reference: pages 51-53, 59-60, 65, 69, 73, 126.

The assessment "was conducted in accordance with the requirements of the European Sustainability Reporting Standards (ESRS) and the provisions of IG 1 - Materiality Assessment" (page 51). A multidisciplinary working group ran data collection, verification and analysis; its eleven members are named (page 52). Method (page 53). Impact materiality used severity and likelihood, with "Severity ... defined and assessed as a combination of factors: scale, scope and irremediability". Financial materiality used "the likelihood of risk materialisation and the severity in terms of the magnitude of financial effects", covering "performance, financial position, liquidity, access to capital and cost of capital", with reputational damage also treated as capable of financial effect. Each criterion was scored and read against an assessment matrix, consolidated into a double materiality matrix.

Scope (page 52). "During 2025, no new company needs were identified and no changes occurred in the context or among stakeholders that would require amendments to the list of analysed matters." Cybersecurity and export/import control were carried forward as additional subtopics; employee satisfaction was added as a new sub-subtopic (page 53).

The description does not cover external stakeholder involvement in scoring, or the thresholds applied.

Disclosure requirements covered by the sustainability statement

Reference: pages 126-131.

Aerostar prints an ESRS content index as Annex 4, headed "IRO-2 - ESRS disclosure requirements covered by the company's sustainability statement" (pages 126-131). It runs across six pages with three columns: Standard, Disclosure requirements (DR), and Applicable data points. Every disclosure requirement of ESRS 2 and of the ten topical standards is listed by number and title, from BP-1 to G1-6.

Two features limit it as a navigation aid:

• There is no page reference column. The index says which data points the company treats as applicable, not where in the 135-page report the disclosure sits.
• The data points column is blank for a number of rows, including E1-7, all six E4 rows, E5-3, E5-4, S2-5 and the whole of S4. For most of these the body also carries no matching section, but S4 is one of the two topics the company itself calls financially material and its S4-1 to S4-4 sections are present and labelled (pages 102-103).

Annex 5 (pages 132-135) separately lists the data points derived from other EU legislation, cross-referenced to SFDR, Pillar 3, the Benchmark Regulation and the Climate Law.

The statement gives no list of disclosure requirements complied with by page or paragraph, and no phase-in table for ESRS 1 Appendix C reliefs.

Transition plan for climate change mitigation

Reference: page 59, 127.

The section headed E1-1 describes completed investments rather than a transition plan in the ESRS sense. Aerostar "has committed to environmental protection through its internal policy and has continued implementing actions to optimise resource consumption, including" (page 59):

• Thermal rehabilitation of building facades with sandwich panels. "Approximately 70% of all buildings have been rehabilitated in this way. Their installation has improved the thermal insulation of buildings by approximately 20%."

• Replacement of old boilers with energy-efficient dual-burner boilers running on methane gas or diesel.

• "Commissioning of a photovoltaic park with a total capacity of 3 MWp."

• Potabilization of groundwater extracted from the F2 well.

"Aerostar seeks to use resources responsibly by setting annual process-level objectives documented in process sheets" (page 59).

What is absent. No decarbonisation lever analysis, no GHG reduction pathway, no locked-in emissions assessment, no capital expenditure attached to the plan, no statement of compatibility with limiting warming to 1.5 degrees Celsius, no reference to the EU Paris-aligned benchmarks, and no statement that the plan was approved by the administrative bodies. The company found no material climate impact and no financially material climate risk (page 60), so the disclosure is voluntary in substance.

Identification of climate-related risks and scenario analysis

Reference: pages 59-60, 64.

Back-filled from ESRS 2 IRO-1 and SBM-3 (pages 59-60) and E1-9 (page 64). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk identification. "In the double materiality analysis, we included aspects related to adaptation to climate change and the risk of increasing utility costs due to the investment in purchasing GHG emission certificates to cover any shortfall" (page 59). The E1 IRO table records one real negative impact (greenhouse gas emissions) and one real positive impact (renewable generation), each with one risk or opportunity (page 60).

Physical and transition split. The IRO table does not label risks as physical or transition; E1-9 does: "The main physical risks anticipated for the Company include potential disruptions to raw material supply due to prolonged droughts, as well as possible increases in energy costs resulting from stricter regulations. The transition to a green economy may also require additional expenditure to implement energy-efficient technologies and low-emission standards" (page 64).

No scenario analysis was performed. No scenario, high-emission pathway, 1.5 degree pathway or temperature projection is named, so paragraph 17 does not apply and its absence is not a gap.

Policies related to climate change mitigation and adaptation

Reference: pages 51, 60, 127. The report prints no section headed E1-2. The requirement is listed in the Annex 4 index with applicable data point 22 (page 127), and the policy content sits inside the section headed "Climate change policy actions and resources, E1-3" on page 60.

The instrument is the Quality and Environmental Policy, which "aims at improving environmental performance and includes a commitment to take action to protect the environment" (page 60). It is supported by the development strategy, which "reflects our commitment to comply with all legal requirements and implement concrete measures to reduce our carbon footprint, thereby contributing to global climate change mitigation objectives" (page 60).

The policy sits inside a certified system: the company "maintains an Environmental Management System in accordance with the requirements of the SR EN ISO 14001 standard, duly certified. The effectiveness of the system is supported through continuous monitoring, evaluation and improvement actions, including ensuring the alignment of environmental policy and objectives with the operational context and the company's strategic direction" (page 51).

The disclosure does not say whether the policy addresses climate adaptation as distinct from mitigation, does not identify the most senior level accountable, and does not state whether it is publicly available.

Actions and resources in relation to climate change policies

Reference: pages 59-60, 64, 127.

Climate actions run through an energy audit and its action plan: "Following the energy audit conducted in 2023, recommendations were formulated to improve the energy performance of our Company. These recommendations were carefully analysed, and in 2024 the Action Plan for implementing the recommendations from the comprehensive energy audit was approved. The Action Plan includes short-, medium-, and long-term measures, with its implementation extending into 2025" (page 60).

The physical measures are listed under E1-1 (page 59): thermal rehabilitation of facades across approximately 70% of buildings, improving insulation by approximately 20%; replacement of boilers with energy-efficient dual-burner units; full replacement of the heat distribution network; and commissioning of a photovoltaic park. The plant "in its second year of operation... with an installed capacity of 2,9 MW, generated 2.418.155 kWh of electricity" (page 64), and renewable production has "led to a reduction of approximately 20% in purchased energy" (page 59).

What is absent. No capital or operating expenditure is attached to the actions, no expected GHG reduction per action, no completion dates for outstanding action plan items, and no link to amounts in the financial statements or to EU Taxonomy CapEx.

Targets related to climate change mitigation and adaptation

Reference: page 61, 127.

The targets are energy intensity targets relative to turnover, not GHG reduction targets. "Our objectives aim at optimising resource management and reducing consumption. In this regard, we make continuous efforts to improve the efficiency of natural gas and electricity consumption through long-term targets" (page 61). Baseline year 2017, target year 2030:

The 2030 target values are less demanding than the 2025 outturn as printed. Gas intensity of 0,0045 and electricity intensity of 0,0328 for 2030 sit above the 2025 figures of 0,0026 and 0,0172, so on the face of the table both targets are already passed by a wide margin. The report offers no explanation and no restatement.

There is no absolute GHG reduction target, no base-year emissions value, no science-based validation, no Scope 1, 2 and 3 decomposition, and no statement on reliance on removals or carbon credits.

Energy consumption and mix

Reference: pages 61-62, 64, 127.

Electricity and natural gas against a 2017 baseline (page 61):

Electricity use rose 1,7% year on year and gas 0,7%.

Fossil fuel (page 62). Diesel for heat production: 10.821 litres in 2021, 1.433 in 2022, 183.531 in 2023, 196 in 2024 and 104 in the final line. That last line is printed as "Diesel consumption in 2021 (for heat production) = 104 litres", repeating the 2021 label, but the narrative identifies it as the current year: "in 2025 diesel consumption was strictly limited to the periodic systemic testing".

Renewable generation. The photovoltaic plant "generated 2.418.155 kWh of electricity" in 2025 (page 64), and purchased electricity comes from Hidroelectrica, "which generates 91,82% of its electricity from renewable sources" (page 64).

What is absent. No total energy consumption in MWh, no renewable and non-renewable split in the ESRS format, no energy intensity per net revenue from high climate impact sectors, and no statement of whether the company operates in such a sector.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 62-64, 127.

2025 (page 62). "Scope 1 covers fuel and natural gas consumption... our Scope 1 carbon footprint in 2025 amounted to 3.134 tons of CO2e. Scope 2 represents electricity consumption... Total carbon emissions for Scope 2 in 2025 amounted to 36.616 tons of CO2e."

Scope 2 movement (page 64). "CO2e emissions per kWh now at 4,332 g/kWh compared with the value reported by the previous supplier of 169,65 g/kWh... In 2024, Hidroelectrica's CO2e emissions per kWh were 1,298 g/kWh, increasing to 4,332 g/kWh from April 2025. This explains the 204,45% increase in the Scope 2 carbon footprint in 2025, while still maintaining a low overall level."

Intensity (page 63). Total GHG per unit of turnover fell from 0,0000156 in 2021 to 0,0000051 in 2025.

Scope 3 is not reported. "we are in the process of defining and adapting our Scope 3 methodology, with the ultimate objective of obtaining a calculation that includes emissions arising from the supply chain" (page 62). Location-based and market-based Scope 2 are not distinguished, biogenic emissions are not reported, and no consolidation boundary is stated.

Internal carbon pricing

Reference: page 64, 127.

The disclosure is a single sentence: "The Company monitors the trading price of a GHG certificate on a quarterly basis on the European Energy Exchange (EEX) platform" (page 64).

That is market price observation rather than an internal carbon price. The report does not describe an internal carbon pricing scheme of any type, does not state a price per tonne applied in decision making, does not identify the scopes of emissions such a price would cover, does not give the share of emissions covered, and does not explain how any price is consistent with the prices used in the financial statements.

Related context appears under E1-9 rather than here: the last trading price of 2025 is used to size the compliance exposure, "Based on the last trading price in 2025 (EUR 85,12 per GHG certificate on 30 December 2025), the financial impact of purchasing 3.000 GHG certificates is approximately EUR 255.000" (page 64). The monitoring described under E1-8 is therefore best read as support for managing the company's emissions trading position rather than as a shadow price used to steer investment decisions.

Anticipated financial effects from physical and transition risks and climate opportunities

Reference: pages 59, 64, 127.

This is the one climate disclosure Aerostar quantifies, and it concerns its emissions trading position (page 64):

"At the end of 2025, the RUEGES account held 7.179 GHG certificates. Considering an average of 3.000 certificates returned per year, this reserve can cover approximately two years. In the coming years, the Company will need to purchase additional certificates to maintain compliance with regulatory requirements, which will reduce the financial benefit currently provided by free GHG allocations. Based on the last trading price in 2025 (EUR 85,12 per GHG certificate on 30 December 2025), the financial impact of purchasing 3.000 GHG certificates is approximately EUR 255.000."

What is absent. No monetary amount for the physical or transition risks beyond the certificate estimate, no disaggregation of assets at material physical risk by acute and chronic hazard, no location of significant assets at risk, and no time horizon beyond the two-year certificate cover.

Qualitative physical risks named on page 64 are raw material supply disruption from prolonged droughts and higher energy costs from stricter regulations; the transition risk is additional expenditure on energy-efficient technologies.

Policies related to pollution

Reference: pages 65-66, 127.

"Our Quality and Environmental Policy includes a commitment to the prevention of pollution" (page 66). Within the environmental chapter of the development strategy, two directions are identified (page 66):

• "continuing the implementation of the Plan for the Prevention and Control of Accidental Pollution at the Company's sites in Bacau and Iasi";
• "strengthening pollution prevention measures across all operational stages through the responsible management of waste, hazardous chemical substances, and emissions to air, water, and soil."

The policy operates inside the certified ISO 14001 Environmental Management System (page 51), and activities "are regulated under environmental protection legislation and are supervised by regulatory authorities" (page 65).

The company is explicit that this is voluntary disclosure against an immaterial outcome: "Although the double materiality assessment revealed that the evaluated impacts are not material and the analysed risks have no financial effect, we provide clear and detailed information on relevant aspects to demonstrate our commitment to sustainability and responsibility" (page 65).

The disclosure does not state the policy's scope by activity or value chain, does not name the most senior level accountable, does not say whether it is publicly available, and does not set out substitution or minimisation of substances of concern as a policy commitment.

Actions and resources related to pollution

Reference: page 66, 127.

Resources. "The financial resources required for the implementation of environmental monitoring and control measures are ensured through the allocation, within the Company's annual budget, of dedicated amounts for environmental expenditure, including costs related to periodic monitoring activities and compliance with all legal obligations regarding pollution prevention and reduction" (page 66). No amount is given.

Abatement assets installed (page 66):

• "two neutralisation plants, used for the treatment of wastewater and the physical processing of residual sludge through dehydration and pressing";
• "a reverse osmosis installation";
• "upgraded fume exhaust systems for special process lines equipped with new generation scrubbers for gas scrubbing";
• "enclosed, environmentally friendly paint booths equipped with dry filter systems for air purification";
• "oil separators".

A measured outcome of one action is reported under E2-4: the move to water-based paints containing on average 3% volatile organic compounds, against 60 to 90% for solvent-based paints, drove volatile organic compound emissions down 69,78% against the 2017 baseline (page 67).

The disclosure gives no time horizon, no operating or capital expenditure, no expected quantitative reduction per action, and no action addressing the value chain.

Targets related to pollution

Reference: pages 66-67, 127.

"The Company establishes its pollution-related objectives in accordance with the limits and requirements imposed by the applicable legislation, with the primary aim of maintaining its operations within the legally established limits for environmental factors through the implementation of proactive monitoring, control, and prevention measures" (page 66).

Three targets are listed, none quantified (page 66):

• "ensuring that all wastewater is discharged in compliance with the applicable regulations, thereby protecting natural resources and local ecosystems";
• "allocating annual funds dedicated to investments in clean technologies, safe equipment, and energy-efficient equipment and environmentally friendly equipment";
• "promoting a culture of sustainability at all levels of the organisation."

These are compliance commitments rather than measurable outcome-oriented targets. There is no base year, no target year, no target value for any pollutant, and no statement of whether they are mandatory under legislation or voluntary. The one quantified pollution series in the report, the volatile organic compound trend to 2025 (page 67), is presented as an outcome under E2-4 and is not tied to a target level here.

Pollution of air, water and soil

Reference: page 67, 127, 132.

Monitoring. "The Company has a contract with an authorised service provider to carry out monitoring of wastewater and air emissions... Test reports issued for the 2025 monitoring activities revealed that all pollutants analysed were within the maximum permitted limits" (page 67).

Volatile organic compounds, the one quantified pollutant series (page 67):

"The reduction... is due to the use, in the Automatic Paint Line, of water-based paints containing on average 3% VOCs, compared to conventional solvent-based paints, which contain approximately 60-90% VOCs" (page 67).

Soil. "Soil monitoring is carried out in accordance with the Integrated Environmental Permit (once every 10 years). The last monitoring was conducted in 2017, and the values measured were within the maximum permitted limits" (page 67). No 2025 soil measurement is available.

What is absent. Annex 5 lists the E-PRTR data point on the amount of each pollutant emitted to air, water and soil (page 132), but no pollutant-by-pollutant amounts are reported, and water discharge volumes are not given.

Substances of concern and substances of very high concern

Reference: pages 65, 67-68, 127.

The disclosure is a detailed narrative on hexavalent chromium authorisation status with no amounts of any kind.

Authorisation position (page 68). Authorisation for chromium trioxide "was revoked by the European Court of Justice on 20 April 2023, and we are currently in a transition period." Four workstreams follow: the ADCR Consortium, which obtained 21 authorisation decisions for five chromates in early 2025 with a 12-year review period and of which Aerostar is a downstream user; the CTAC sub consortium decision, cancelled from April 2024; a Safran LS application on which Aerostar is a co-applicant; and chromate-containing primers authorised until January 2026 with renewals filed in May 2024.

Against the requirement. ESRS E2 paragraph 34 requires the total amounts of substances of concern "generated or used during the production or that are procured, and the total amounts... that leave its facilities", split by hazard class, with substances of very high concern presented separately under paragraph 35. Aerostar reports neither limb: no tonnage procured or used, none leaving the facilities, no hazard-class split. The impact sits in own operations (substances used in special processes on site, page 67), so the value chain transitional relief does not reach it.

Anticipated financial effects from pollution

Reference: pages 54, 65, 69, 127.

The disclosure is two paragraphs and contains no monetary amount (page 69):

"On an annual basis, environmental impacts related to air emissions, noise generation, soil discharges, and waste generation are assessed, and environmental aspects are evaluated to identify the significant aspects.

The values determined through monitoring activities carried out during 2025 were within the limits established by the applicable legal requirements, thereby confirming the Company's ongoing efforts to minimise environmental impact."

The pollution risks are stated elsewhere in qualitative terms only. For air, water and soil the identified risk in each case is "Reputational risk in case of exceeding legal limits (sanctions from environmental authorities)" or, for soil, "in case of accidental contamination"; for substances of very high concern the risks are "Non-compliance with applicable legal requirements and REACH Regulation" and "Discontinuation of the special process in which the authorized/restricted substance is used" (page 65). None is sized.

The company states more generally that monetary quantification of financial effects awaits a finalised methodology (page 54), and the pollution impacts were found not material (page 65).

Policies related to water and marine resources

Reference: page 69, 117, 127.

Scope is set first: "The double materiality assessment considered the subtopic water resources, as defined in the thematic standard; the Company does not use marine resources" (page 69). Annex 2 marks marine resources, water withdrawals, water discharges and discharges into oceans as not applicable, leaving water consumption as the only row with an identified impact (page 117).

The policy statement (page 69):

"Our company is committed to managing water resources responsibly, with the primary objective of ensuring efficient use and reducing consumption wherever possible. We implement measures for the regular monitoring of water consumption and promote technological solutions aimed at minimising losses and enabling the reuse of water in internal processes. In addition, we ensure that wastewater discharge complies with all applicable legal regulations, thereby protecting natural resources and local ecosystems."

The disclosure does not say whether the policy addresses water management in areas at water risk, does not refer to sustainable oceans and seas, does not address product design for water efficiency, and does not state whether it is publicly available. The identified impact is potential negative, "Excessive water use", with the risk of "insufficient water availability" (page 69).

Actions and resources related to water and marine resources

Reference: pages 70-71, 127.

Four continuing actions are listed (page 70):

• "Continuous monitoring of water consumption to identify and reduce losses";
• "Implementation of technological solutions aimed at optimizing water use within operational processes";
• "Proper collection and treatment of wastewater, in compliance with applicable legal and regulatory requirements";
• "Promotion of water reuse initiatives, where feasible, thereby contributing to the reduction of impacts on natural resources."

"These actions are supported by an annual budget allocated to monitoring activities, equipment maintenance, and the continuous improvement of water management infrastructure" (page 70). No amount is disclosed.

The infrastructure actions themselves are described under E3-4 (page 71): replacement of cast-iron pipelines with HDPE pipelines "guaranteed to operate without failure for a minimum of 50 years"; modernisation of potable water control and distribution from the point of entry, including pumping to the water towers; replacement of defective hydrants; prompt remediation of failures in potable, industrial and recirculated water installations; and potabilisation of groundwater from well F2, which produced "approximately 23.000 cubic meters" in 2025.

The disclosure does not identify which actions relate to areas at water risk, does not give expected water savings per action, and does not cover the value chain.

Targets related to water and marine resources

Reference: pages 70, 72, 127.

"As part of our sustainability efforts, we have established targets related to the management of water consumption" (page 70). The target is water consumption relative to turnover against a 2017 baseline:

As with the E1-4 energy targets, the 2030 target of 0,3594 mc/RON sits well above the 2025 outturn of 0,1981, so the target as printed is already met by a wide margin. The report gives no explanation and no restatement, and sets no absolute volume target.

A second, operational target is recorded under E3-5: "In 2025, Aerostar set a target to reduce the amount of potable water purchased from the supplier CRAB, with the goal of meeting 50% of the total consumption needs" (page 72).

The disclosure does not state whether the targets relate to areas at water risk, does not distinguish withdrawal from consumption or discharge, and does not say whether they are mandatory or voluntary.

Water consumption

Reference: page 71, 127, 133.

Total water consumption in cubic metres (page 71):

Consumption rose 7,7% year on year. The mix shifted: potable water fell 22,6% while industrial water rose 58,6%, consistent with the company beginning its own potable water production. Consumption relative to turnover is charted at 0,1981 for 2025 against 0,1952 in 2024.

Own production. "The quantity of potable water produced through the company's own reverse osmosis installation in 2025 amounted to approximately 23.000 cubic meters" (page 71).

Site context (page 71). "No instability phenomena, active or stabilised landslides have been identified either on-site or in the surrounding area... The site is not located in the path of torrential flows and is not situated within a flood-prone area."

What is absent. No water withdrawal figure as distinct from consumption, no water recycled and reused volume, no water stored, and no breakdown for areas at water risk or high water stress. Annex 5 lists the water consumption per net revenue data point (page 133) without reporting it.

Anticipated financial effects from water and marine resources

Reference: pages 54, 69, 71-72, 127.

The section headed with E3-5 does not present financial effects. It reports the outcome of a substitution project (page 72):

"In 2025, Aerostar set a target to reduce the amount of potable water purchased from the supplier CRAB, with the goal of meeting 50% of the total consumption needs. In this regard, the process for treating water from drilling Well No. 2 was initiated in 2024, and in January 2025, the Bacau County Public Health Directorate authorised Aerostar's potable water supply system (Authorisation No. 2120/21.01.2025).

As a result, in 2025, Aerostar's production of potable water accounted for approximately 50% of the total consumption needs."

The underlying figures support the claim: purchased potable water fell from 71.536 cubic metres in 2024 to 55.379 in 2025, while own production was approximately 23.000 cubic metres (page 71).

No monetary amount is disclosed. The company does not size the avoided purchase cost, the capital cost of the well treatment process, or any anticipated financial effect from the identified risk of "insufficient water availability" (page 69). That risk was assessed as having no financial materiality, and monetary quantification across the statement awaits a finalised methodology (page 54).

Transition plan on biodiversity and ecosystems

Reference: pages 72, 118, 128.

The disclosure is a single short paragraph under the heading "Transition plan and integration of biodiversity and ecosystems into the strategy and business model, E4-1" (page 72):

"Our operational site is located within an industrial area, with no direct impact on protected natural areas or vulnerable habitats. However, we are aware of our responsibility regarding the sustainable use of natural resources and the reduction of impacts on local biodiversity."

This is a statement of no impact rather than a transition plan. Annex 2 records the whole of ESRS E4 as "Not applicable to our company. The activities carried out within our organisation do not generate any impact on protected natural areas, vulnerable habitats, or ecosystems" (page 118), with no impacts, risks or opportunities counted for any E4 subtopic, and the Annex 4 index row carries no applicable data points (page 128).

The disclosure contains no plan, no target aligned to the Kunming-Montreal Global Biodiversity Framework, no time-bound milestones, no explanation of how the business model is compatible with biodiversity limits, and no statement of whether the value chain was assessed. Related content elsewhere is confined to permit compliance: soil monitoring under the Integrated Environmental Permit (page 67) and the site stability description (page 71).

Actions and resources related to biodiversity and ecosystems

Reference: pages 72, 118, 128.

The disclosure is forward-looking and unresourced (page 72):

"Although our location does not impact protected ecosystems, we aim to integrate biodiversity into our sustainability approach in the future by:

• Conducting periodic assessments of the impact of our activities on the local environment;
• Collaborating with environmental organisations on projects that support regional biodiversity;
• Promoting a responsible supply chain that includes sustainability criteria for suppliers."

None of the three items is dated, costed, assigned or measured. No action was taken during 2025, no financial or human resources are allocated, no expected outcome is stated, and no biodiversity offset is claimed or excluded. The third item, sustainability criteria for suppliers, is not reflected in the supplier chapters: under S2 the company states that in 2025 it "did not apply social criteria in their selection" of suppliers (page 93).

Context: Annex 2 marks the whole of ESRS E4 as not applicable (page 118), and the Annex 4 index row for E4-3 carries no applicable data points (page 128). The disclosure is voluntary and describes an intention rather than an action taken.

Policies related to resource use and circular economy

Reference: pages 51, 57, 73, 128.

"The circular economy and waste management are of great importance to us, reflecting the responsibility we have assumed toward the environment. One of the key action areas included in the company's development strategy is ensuring the rigorous implementation of the Waste Prevention and Reduction Plan for waste generated by our own activity" (page 73).

"We monitor both hazardous and non-hazardous waste. For the handling, collection, segregation, baling, and temporary storage of waste generated on-site, we collaborate with specialised waste management companies that provide the necessary equipment and human resources to carry out these operations" (page 73).

The policy sits within the certified ISO 14001 system (page 51), and responsibility for sustainable resource use and reducing natural resource consumption is delegated to the Director of the Infrastructure and Utilities Division (page 57). The IRO-1 statement frames the priority as "increasing waste recovery and educating all employees on minimising waste generation" (page 73).

The policy addresses waste and resource use in own operations. It does not address the transition away from virgin resources, the sustainable sourcing of renewable resources, the waste hierarchy in explicit terms, or the value chain, and the report does not state whether it is publicly available or name the accountable level.

Actions and resources related to resource use and circular economy

Reference: pages 73-74, 128.

"Throughout the year, monthly and periodic reports are prepared regarding waste management, both for internal company reporting and for reporting to environmental authorities, in accordance with the requirements set out in the environmental authorisations held. The reports include information on: waste types, quantities generated, and recovery methods" (page 73).

Four categories of activity are listed (pages 73-74):

• "Identifying and classifying waste in accordance with applicable environmental legislation";
• "Conducting waste management audits in compliance with applicable legislation (Government Emergency Ordinance 92/2021) and implementing programmes to prevent and reduce the quantities of waste generated";
• "Ensuring the provision of appropriate collection infrastructure (waste bins, dustbins, containers, retention tanks, and specially designated spaces/areas for temporary waste storage)";
• "Identifying and analysing the best available recovery solutions on the market for the waste generated."

The measured outcome appears under E5-4 and E5-5: total waste fell from 1.711.620 kg in 2024 to 1.281.793 kg in 2025 and hazardous waste from 554.610 kg to 294.180 kg, while the recovery rate fell from 79% to 76% (page 74).

No expenditure, time horizon or expected reduction per action is given, and no action addresses resource inflows or the value chain.

Resource inflows

Reference: pages 56, 73-74, 128.

The report prints a combined heading, "Resource inflows and outflows, E5-4, E5-5" (page 74), but the material that follows is waste and packaging data, that is, outflows. No resource inflow quantities are given. There is no total weight of products and technical and biological materials used, no share of biological materials, no share of secondary reused or recycled components, and no split between own operations and the value chain.

What the report says about inflows is qualitative and sits in the materiality tables. Annex 2 records one impact for "Resource inflows, including resource use" with no risk and no opportunity (page 118); the E5 IRO table describes it as "Excessive use of raw materials" (page 73); and the summary table of potential impacts lists it under circular economy as "Possible overuse of raw materials" (page 56). The company concluded that "no material impacts or risks with financial materiality were identified" for the standard (page 73).

Adjacent information does not answer the requirement: the business description names the metals worked, "hundreds of thousands of machined parts and hydraulic systems made from aluminium alloys, steel, bronze and titanium" (page 7), without tonnage. The Annex 4 index row for E5-4 carries no applicable data points (page 128).

Resource outflows

Reference: page 74, 128, 133.

Outflows are reported as waste generated and as recovered packaging (page 74).

Recovered packaging (page 74). "Other resource outflows include recovered packaging, reported monthly to the Environmental Fund Administration, mentioning that these quantities are already included in the overall waste reporting... in 2025, the quantities generated were: plastic 348 kg, paper-cardboard 2336 kg, metal 1614 kg, wood 46573 kg."

Total waste fell 25,1% year on year and hazardous waste 47,0%, while the recovery rate declined for a second year, from 90% in 2023 to 79% and then 76%. The report explains neither movement.

What is absent. No product-level circularity disclosures: no expected durability relative to industry average, no reparability, no recyclable content in products or packaging, and no rates of recyclable content.

Anticipated financial effects from resource use and circular economy

Reference: pages 54, 73-74, 128.

The disclosure is qualitative and contains no amounts (page 74):

"Regarding financial risks related to resource use, legal and regulatory sanctions may arise (fines and financial losses in the event of non-compliance with resource use and waste management regulations). Additionally, waste disposal costs can have a financial impact, resulting from inefficient waste management, which may entail higher fees or additional costs for storage and recycling.

An opportunity offered by the circular economy is energy efficiency; thus: the implementation of circular solutions reduces energy consumption and associated costs, contributing to long-term savings."

The identified risk in the E5 materiality table is "Higher taxes and increased costs for hazardous waste disposal", attached to the generation of hazardous waste (page 73). It is assessed as not material and without financial materiality, so quantification was not required.

No monetary amount, time horizon or assumption set is given, and the effects are not linked to any line item in the financial statements. Relevant movements are reported elsewhere without being costed: hazardous waste fell from 554.610 kg in 2024 to 294.180 kg in 2025, while the recovery rate fell from 79% to 76% (page 74).

Waste

Reference: pages 73-74, 128.

Waste is the one E5 area Aerostar quantifies, over five years (page 74):

In 2025 hazardous waste was 23,0% of the total by weight, down from 32,4% in 2024. Waste intensity relative to turnover fell to 0,0020 kg/RON from 0,0029.

Recovered packaging generated in 2025, already counted inside those totals: plastic 348 kg, paper-cardboard 2.336 kg, metal 1.614 kg, wood 46.573 kg, reported monthly to the Environmental Fund Administration (page 74).

The identified impact is "Generation of hazardous waste", with the risk of "Higher taxes and increased costs for hazardous waste disposal" (page 73), assessed as not material and without financial materiality.

What is absent. Waste is not split by treatment route into preparation for reuse, recycling, other recovery, incineration, landfill and other disposal; the non-recycled share is given only implicitly through the recovery rate; no radioactive waste statement is made; and the recovery rate itself is not defined.

Policies related to own workforce

Reference: pages 75, 79-80, 129.

"The Human Resources policies include firm commitments to equal opportunities, non-discrimination, and fair treatment, ensuring equal access to recruitment, training, and career advancement opportunities, regardless of gender, age, ethnicity, or any other criteria unrelated to competence... All Aerostar HR policies and operational procedures apply across the entire Company" (page 80).

The framework documents named elsewhere are the Collective Labour Agreement, which "transposes nationally the principles set out in the International Charter of Human Rights and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work" (page 75), the Internal Regulations, the Code of Conduct and Ethics (page 81) and the "Guidelines for the Prevention and Combating of Sexual and Psychological Harassment in the Workplace" (page 79).

The disclosure does not state whether the policies are publicly available, does not name the accountable level, and does not address human trafficking or forced labour in own operations as explicit commitments.

Engaging with own workforce and workers' representatives

Reference: pages 78, 81, 85, 129.

"Aerostar systematically integrates the perspective of employees and their representatives into the process of identifying, evaluating, and managing impacts on its own workforce. Worker involvement is part of the strategic social governance approach and is essential for risk prevention, improving working conditions, and fostering an organisational climate based on trust and transparency" (page 81).

Channels described (page 81): "periodic meetings between management and employee representatives, direct consultations on occupational health and safety, as well as ongoing exchanges regarding operational schedules, workload, training needs, and factors affecting professional well-being."

Two standing bodies carry the engagement:

• a joint management-employee committee monitoring implementation of the Collective Labour Agreement;
• the Occupational Health and Safety Committee (CSSM), "composed of representatives from management and employee representatives appointed under the CCM, with subcommittees organised to address specific issues within the divisions".

The disclosure does not identify the operational-level responsibility for feeding engagement outcomes back into the company's approach, and does not describe engagement with workers particularly vulnerable to impacts.

Remediation channels for own workforce

Reference: page 81, 129.

The named channel is an email address: "All employees are encouraged to report any suspicions regarding compliance breaches or violations of ethical or conduct rules by email: sesizari@aerostar.ro. Beyond the existence of a formal organisational framework, however, reporting misconduct remains an individual responsibility" (page 81).

"All reports are examined through a clearly defined process, which includes an objective assessment of the situation, consultation with the parties involved, and the establishment of appropriate remedial measures. Depending on the nature of the case, interventions may range from adjustments to work organisation, clarification of responsibilities, and improvement of equipment, to updates of internal procedures or additional training" (page 81).

The framework rests on the Internal Regulations, covering "non-discrimination and respect for human dignity, conflict of interest, disciplinary procedures, and the handling of employee requests and complaints", and on the Code of Conduct and Ethics (page 81). A parallel whistleblowing system permitting safe and anonymous reporting is described under G1-3 (page 106).

The disclosure does not state whether the company tracks employee awareness of or trust in the channel. S1-17 reports zero complaints for 2025 (page 91).

Taking action on material impacts on own workforce

Reference: pages 82-83, 125, 129.

Actions are anchored on the one financially material risk. "Considering the potential negative impact on health and safety, associated with a financially material risk, we have implemented and maintain an occupational health and safety management system, certified by AEROQ, in accordance with the SR ISO 45001 standard" (page 82), covering safe working conditions, risk and opportunity actions, individual responsibility, hazard elimination, and consultation of workers or their representatives.

"The Company periodically assesses the risks of work-related injuries and occupational illnesses at workplaces and workstations across each organisational structure... through the implementation, monitoring, and, where necessary, adjustment of the measures included in the 'Prevention and Protection Plan for ensuring employee health and safety,' prepared annually. In 2025, all measures outlined in this plan were fulfilled" (page 82).

Diversity is quantified in the same passage: "out of 1.874 employees, 560 are women, and of the 189 holding management positions, 49 are women" (page 82). Note that Annex 3 gives 187 management employees for 2025 and 189 for 2024 (page 125); the report does not reconcile the two.

No expenditure is attached to the actions, and effectiveness is not measured beyond the S1-14 health and safety metrics.

Targets related to own workforce

Reference: pages 78, 83, 129.

Four target areas are described, none with a numeric level or a target year (page 83):

• Occupational health and safety. Indicators monitored are "the number of reported incidents, the results of risk assessments, the level of SSM compliance, and employee participation in safety training."
• Workforce stability. "maintaining a high level of permanent employment contracts and reducing employee turnover in critical areas", monitored through "the voluntary departure rate and the consolidation of exit interview".
• Training. "increasing the number of training hours per employee, developing a standardised training portfolio, and expanding collaborations with educational institutions."
• Equal opportunities and inclusion, including "ensuring transparency in the promotion process and equal pay treatment for equivalent roles".

One new instrument is announced: "Aerostar intends to develop modern tools for assessing employee perceptions through the introduction of an annual employee satisfaction survey", addressing the identified potential negative impact that satisfaction "is not measured systematically" (pages 78, 83).

No base year or outcome level is given, workers are not said to have been engaged in setting the targets, and the targets are not linked to the metrics reported under S1-13, S1-14 and S1-16.

Characteristics of the undertaking's employees

Reference: pages 85, 123-124, 129.

Headcount at 31 December 2025. 1.874 employees, of whom 1.314 male and 560 female, with zero recorded as other and zero as undeclared. The 2024 comparative is 1.883 (1.330 male, 553 female) (pages 85, 123).

Working time (page 85). "Out of a total of 1.874 active individual employment contracts in 2025, 2 contracts are part-time and 1.872 are full-time. A full-time contract is defined as 40 hours/week, while part-time contracts are considered as 4 hours/day (20 hours/week) and/or 6 hours/day (30 hours/week)."

Sites (page 124). Bacau 1.793 (550 female, 1.243 male) and Iasi 81 (10 female, 71 male).

Turnover. "The voluntary departure rate in 2025 was 9,58%, lower than in 2024 (10,73%)" (page 85).

A contradiction in the contract-type split. Annex 3 gives two different breakdowns of the same 1.874 employees. Page 123 reports 1.781 permanent and 93 temporary; page 124 reports 1.622 permanent contracts and 252 fixed-term. Both sum to 1.874 but they cannot both be right, and the report neither reconciles them nor defines the difference between "temporary" and "fixed-term".

Employees with non-guaranteed working hours are reported as zero for both years (page 123). No total turnover including involuntary departures is given, and no methodology note states whether headcount is at period end or an average.

Characteristics of non-employee workers

Reference: pages 75, 80, 84, 129. The report prints a combined heading, "Characteristics of AEROSTAR's own workforce, ESRS S1-6; ESRS S1-7" (page 84), so S1-7 is labelled but not separately answered.

No headcount of non-employee workers is disclosed. The section carrying the S1-7 label describes only the employee population: contract stability, technical qualification, age distribution, the representation of women in technical roles, and administrative and support personnel (page 84). No figure is given for self-employed people or for people provided by undertakings primarily engaged in employment activities, and no methodology or estimate is offered.

Non-employee workers are nonetheless within the scope the company sets: "When presenting information about our own workforce, we refer to all company employees (full-time, part-time, fixed-term, or permanent), as well as those provided to the company through temporary employment agencies" (page 75). The Annex 4 index lists S1-7 with the applicable data point "55 (a)" (page 129), the headcount of non-employees, but no such number appears anywhere. Workers employed by suppliers who work on Aerostar premises are covered separately under S2, where they receive site-specific safety training and protective equipment (page 94).

Collective bargaining coverage and social dialogue

Reference: pages 78, 85-86, 124, 129.

Coverage is complete. "Aerostar has a Collective Labour Agreement (CCM) applicable to its entire workforce, which is negotiated periodically in collaboration with the representatives of the Avias trade union" (page 85). Annex 3 reports 1.874 employees covered in 2025 and 1.883 in 2024, that is 100% in both years, with union membership at 56% in 2025 and 57% in 2024 (pages 86, 124).

Dialogue in practice (page 85). "Social dialogue is structured and recurrent, carried out through periodic meetings between management and the union... Topics discussed during these interactions include: working conditions, remuneration, working hours, occupational health, and safety, among others. Representatives of the Avias trade union have access to relevant information necessary for the performance of their activities, and Aerostar ensures that they can act freely, without pressure or constraints."

"The relations between the employer and employees are fully in compliance with applicable legal provisions, with no conflictual issues identified in 2025" (page 86). Coverage is not broken down by country or region, and workers' representation is not reported separately from union membership.

Employees may join the Avias trade union, the representative union at unit level under Law no. 367/2022 (page 85).

Diversity metrics

Reference: pages 82, 86, 125, 129.

"Our company analyses and monitors workforce diversity from multiple perspectives: gender, age, management level, distribution across professional categories, and the representation of women in leadership positions. Although the technical nature of the industry may result in a lower presence of women in certain roles, all employees have equal access to employment and development opportunities" (page 86).

Gender at management level (page 125). In 2025, 187 management employees, of whom 49 female and 138 male, that is 26,2% women in management. The 2024 comparative is 189 (49 female, 140 male). Age distribution (page 125). For 2025: under 30 years 23% (female 5%, male 18%), 30 to 50 years 43% (female 16%, male 27%), over 50 years 34% (female 9%, male 25%). Overall the workforce is 30% female and 70% male, against 29% and 71% in 2024.

"We also track diversity in recruitment. Selection processes are neutral, fair, and based exclusively on competence" (page 86).

A cross-reference to check. The S1-4 narrative states that "of the 189 holding management positions, 49 are women" during the reporting period (page 82), while Annex 3 gives 187 for 2025 and 189 for 2024 (page 125). The report does not reconcile them.

Top management is not reported separately from all management, and diversity is not broken down by employee category beyond management.

Adequate wages

Reference: pages 16, 86, 119, 129.

"AEROSTAR's employee remuneration is uniformly governed by the Collective Labour Agreement. Our company places central importance on ensuring adequate remuneration for all employees, in accordance with national legislation, industry standards, and principles of internal equity. The remuneration system is designed to accurately reflect the complexity of roles, required competences, assumed responsibilities, and performance levels" (page 86).

The claim on wage floors is explicit: "To guarantee appropriate pay levels, we use transparent pay grids, established based on an objective analysis of roles and professional requirements. Base salaries are supplemented by additional financial benefits. The company ensures that all base salaries exceed the legal minimum and are aligned with industry standards. An important aspect is the periodic review of the salary structure to prevent unjustified disparities" (page 86).

What is absent. The ESRS measure is the percentage of employees paid below the applicable adequate wage benchmark, by country. Aerostar reports compliance with the national legal minimum, which is not that benchmark, gives no percentage and does not name the benchmark used. Annex 2 records no impact, risk or opportunity for the adequate wages sub-subtopic (page 119).

Social protection

Reference: pages 86-87, 89-90, 129.

"Aerostar ensures that all employees have access to a strong social protection system, in accordance with national legislation and industry best practices, as part of its commitment to the well-being of its workforce" (page 86).

"In accordance with the Collective Labour Agreement (CCM), all our employees benefit from social protection at the workplace. Social protection covers a broad range of benefits and measures designed to provide financial security, support in unforeseen situations, and long-term stability for employees and their families. Additional elements of social protection may include: financial support for marriage, childbirth, bereavement, among others. Employees may also benefit from additional leave for various personal situations, enabling them to maintain a healthy work-life balance" (page 87).

What is absent. The disclosure is a statement of universal coverage without the structure ESRS asks for. It does not confirm coverage against each of the major life events, namely sickness, unemployment from the moment the employee's own work ends, employment injury and acquired disability, parental leave and retirement, and gives no percentage of employees not covered by any of them, by country. Aerostar is a single-country employer with sites in Bacau, Iasi and Fetesti (page 6), which limits the reporting burden but does not remove the requirement.

Persons with disabilities

Reference: pages 87, 119, 129.

The disclosure carries one figure and one policy statement (page 87):

"Although the company does not have positions specifically designated for persons with disabilities, employees with disabilities are integrated into regular teams and benefit from the same rights, opportunities, and responsibilities as the rest of the personnel.

Recruitment and selection processes are non-discriminatory, ensuring equal access to positions for persons with disabilities, while taking into account the specific requirements and risks associated with each role.

The total percentage of employees with disabilities in 2025 is 0,32%."

At a headcount of 1.874 (page 85), 0,32% corresponds to about six employees, although the report does not state the number.

No prior-year comparative is given, so no trend can be read, and the figure is not broken down by gender. The report does not state whether the percentage is subject to legal limitations on the collection of data, which is the ESRS qualification for this metric, and does not address the Romanian statutory quota for employing persons with disabilities or any contribution paid in lieu.

Annex 2 records no impact, risk or opportunity for the sub-subtopic "Employment and inclusion of persons with disabilities" (page 119), and the accessibility dimension, adapting workplaces or equipment, is not addressed.

Training and skills development metrics

Reference: pages 87-88, 129.

Training volume (page 87). Total training hours rose from 45.066 in 2024 to 67.494 in 2025, an increase of 49,8%.

Participation in 2025 (page 87):

The percentages are expressed as shares of the whole workforce rather than of each gender, so they sum to the total rather than describing coverage within each group.

"Training programmes cover technical and operational areas, including occupational health and safety, quality management, digital skills, communication, and organisational efficiency" (page 87). "Particular attention is given to the training and retention of EASA-licensed aeronautical technical personnel, who perform and certify maintenance work on aircraft and their components" (page 88). New employees receive "a structured onboarding and professional adaptation programme", and there is an annual employee evaluation process (page 88).

What is absent. ESRS asks for the average number of training hours per employee by gender. The report gives an absolute hours total and gender-split participation rates, but no average hours per person and no gender split of the hours.

Health and safety metrics

Reference: pages 82, 88-89, 129.

Reported incidents (page 88):

Two points a reader should check. First, narrative and table disagree: the text says "In 2025, Aerostar identified, analysed, and resolved a single work-related event, classified as an 'off-duty accident'" (page 88), while the table records zero off-duty accidents and one minor work accident. Second, the two rate measures look inconsistent with the counts: one recordable accident across 1.874 employees would give a rate in the order of 0,03 per 100.000 hours worked, not 0,00001, and the report states neither the hours worked nor the rate definitions.

"no occupational illnesses were reported/investigated/declared during 2025" (page 88), and "In 2025, the company recorded no litigation arising from work-related incidents and did not have to pay damages" (page 89). Non-employee workers in own operations are not covered by these metrics.

The 2024 column records one fatal work accident, which the report does not describe.

Coverage. 100% of the own workforce is covered by the AEROQ-certified SR ISO 45001 system (pages 82, 88).

Work-life balance metrics

Reference: pages 16, 87, 89-90, 129.

"Working schedules are organised to provide predictability and stability, minimising unnecessary overtime and ensuring compliance with rest periods. Employees have access to flexible working arrangements where the nature of the activities and operational requirements allow... Work-life balance is monitored through metrics such as leave utilisation, overtime hours, and personnel turnover" (page 89).

Family-related leave (pages 89-90):

The ESRS measure is the percentage of employees entitled to family-related leave and, of those, the percentage that took it, by gender. Aerostar reports eligibility for "additional leave" at 100% rather than entitlement to family-related leave, and expresses take-up as a share of the total workforce rather than of those entitled, so the second limb is not answered in the prescribed form. As with the training metrics, the female and male percentages sum to the total rather than describing take-up within each group.

Compensation metrics (pay gap and total compensation)

Reference: pages 83, 90, 129.

The formulas are printed with the table (page 90):

"Pay gap between women and men= (Average gross hourly rate of male employees - Average gross hourly rate of female employees)/ Average gross hourly rate of male employees*100"

"Ratio of total annual remuneration= Total annual remuneration (salary & management allowance) of the highest-paid employee/ Average total annual remuneration of employees (excluding the highest-paid employee)"

Both match the ESRS definitions, including the exclusion of the highest-paid individual from the denominator of the compensation ratio. The overall pay gap narrowed by 0,49 percentage points and the management-level gap by 2,70 points, while the pay ratio widened from 5,58 to 5,77.

The disclosure does not give the contextual information ESRS asks for where a gap exists, such as the drivers behind it or the actions planned to close it, beyond the general statement under S1-5 that targets include "equal pay treatment for equivalent roles" (page 83).

Incidents, complaints and severe human rights impacts

Reference: pages 81, 91, 129.

Aerostar reports a nil return across every measure (page 91):

"In 2025, no incidents of discrimination or harassment among the Company's employees were reported, and no employee complaints regarding occupational health and safety were recorded. Furthermore, no incidents and/or complaints related to labour or serious impacts on human rights (e.g., forced labour, human trafficking, or child labour) were registered within the Company's workforce" (page 91).

No monetary amount is stated for fines, penalties or compensation for damages, which would be zero on the narrative, and no reconciliation to the financial statements is given. The reporting channel behind these figures is sesizari@aerostar.ro (page 81). The company adds that no cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration or the OECD Guidelines were identified in the period (page 91).

Policies related to value chain workers

Reference: pages 93-94, 106, 130.

The instrument is the Suppliers' Code of Conduct: "Our Company consistently pursues the highest standards of business ethics, which has led us to adopt the 'Suppliers' Code of Conduct.' This code represents the expectations we have of our suppliers to ensure a healthy business relationship, in line with our values, principles, and ethical standards. In cases where the expectations of this Code are not met, the business relationship may be reviewed and the Company may propose corrective actions regarding the contractual terms" (page 93).

Coverage measure (page 94). "Following the survey of suppliers within the value chain, the proportion of suppliers who, at Aerostar's initiative, signed and committed to the 'Declaration of Adherence to the Ethics and Conduct Policy,' throughout their collaboration with our Company remains at 87%." There were "no significant changes compared to 2024 regarding expectations for suppliers".

Suppliers must "comply with the labour legislation applicable in their country of origin" (pages 93, 106), and the company works "with suppliers from member countries of the International Labour Organization" (page 93).

The disclosure does not state whether the policy addresses human trafficking, child labour or forced labour by name, does not describe monitoring beyond the adherence declaration, and does not name the accountable level.

Engaging with value chain workers about impacts

Reference: page 94, 130.

Engagement runs through employers, not through the workers themselves. "We collaborate and maintain contact with representatives of the companies to which Value Chain Workers belong, whether those with whom we already have concluded contracts/agreements/protocols or other arrangements, or those with whom such arrangements may be established in the future" (page 94).

"Our Company is engaged in mutual evaluation mechanisms with the employers of Value Chain Workers aimed at assessing the degree to which requirements are met; thus, we respond to evaluation questionnaires proposed or requested by clients and, in turn, we assess suppliers based on questionnaires" (page 94).

Accountability is named. "Operational responsibility for ensuring that this collaboration takes place lies with the Company's Chief Executive Officer, who, depending on needs, delegates authority or grants mandates" (page 94).

What is absent. ESRS asks whether engagement is direct with value chain workers or with credible proxies, at which stage and how often, and how effectiveness is assessed. Aerostar describes commercial engagement with supplier management, reports no engagement with workers' representatives, trade unions or worker proxies, and does not identify workers particularly vulnerable to impacts.

Remediation channels for value chain workers

Reference: pages 81, 94-95, 130.

Channels (page 95). "any form of direct communication between Value Chain Workers and our employees designated as business contacts is permitted, as well as communication between their employers and our Company through the formal communication channels described in the section 'Aerostar's Own Workforce'... Email is a common and accessible channel through which Value Chain Workers are encouraged to express their concerns or needs."

"Any Value Chain Worker may submit complaints if they become aware that an employee or representative of our Company has engaged in misconduct related to conduct and ethics, including if they have perceived or become aware of any form of retaliation... The Company will act responsibly in addressing complaints, taking measures to ensure the protection of personal data, while also accepting and resolving anonymous complaints" (page 95).

The channel referred to for own workforce is sesizari@aerostar.ro (page 81). The disclosure does not state whether value chain workers are aware of or trust the channel, does not describe how remedy is provided or tracked, and reports no grievance received in 2025.

Taking action on material impacts on value chain workers

Reference: pages 93-95, 130.

Outcome for the year. "In 2025, no issues or incidents related to human rights were reported within the upstream or downstream value chain" (page 95).

Actions taken (page 95). "In addition to the measures taken to manage the potential negative impact related to health and safety, our Company carried out actions aimed at preventing negative impacts on Value Chain Workers. In this regard, the sustainability self-assessment questionnaire developed by Aerostar was sent to the most important suppliers, and by the end of 2025 the proportion of those who provided feedback in response to our request reached 80%. We will continue our actions so that the remaining suppliers also provide a response."

On-site protective actions are described under S2-3: safety training on access, personal protective equipment, and contractual allocation of employer responsibilities (page 94).

A stated limitation. "In 2025, we continued with good supplier selection practices, did not apply social criteria in their selection, and no negative social impact was created within our supply chains" (page 93). Supplier selection therefore does not screen on social performance, notwithstanding the 87% adherence rate to the ethics declaration (page 94).

No expenditure or time horizon is given, and effectiveness is tracked only through the response rate.

Policies related to affected communities

Reference: pages 97-99, 121, 130.

"The Company's policies aim to mitigate risks and capitalise on opportunities of any kind identified in connection with its activities, including those relating to affected communities... Our Company represents a stable presence on the labour market and, as an employer with significant economic potential, provides communities with opportunities for secure employment while also contributing substantial tax revenues to local budgets. In this way, the Company has a positive impact on improving the living standards of community members" (page 97).

Six lines of community engagement are listed (pages 97-98):

• "participation in public-interest partnerships with local authorities";
• "involvement in education and vocational training processes through collaboration with educational institutions and participation in joint projects aimed at supporting the development of young people";
• "cooperation with non-profit organisations to support cultural, sports and extracurricular educational activities";
• "sponsorship of various public events or initiatives"; "The Company's sponsorship policy is published on the corporate website, under the section 'Investor Relations'" (page 99).

The disclosure does not address the rights of indigenous peoples, human rights defenders or free, prior and informed consent, all of which Annex 2 marks as not applicable (page 121), and does not name the accountable level.

Engaging with affected communities about impacts

Reference: pages 98-99, 130.

Aerostar engages through membership of standing bodies rather than a bespoke consultation process. "Our presence in various advisory bodies representing the local community enables and sustains ongoing dialogue with local communities. Among these bodies, we highlight the following: Social Dialogue Commission attached to the Prefect's Institution of Bacau County; Local Committee for the Development of the Social Partnership (CLDSP) in Bacau and Iasi, where the Company currently holds the presidency, and the Regional Committee for the Development of the Social Partnership (CRDPS), of which it is also a member" (page 98).

Education (pages 98-99). The company "is a member of a legally established association created to set up a dual education cluster in Bacau". "Subsequently, a consortium was formed that implemented a project financed through the National Recovery and Resilience Plan - 'Educated Romania'. Within this project, in 2025, construction works were carried out to establish an integrated vocational, secondary, and university campus for dual education in Bacau."

The disclosure does not describe engagement with communities particularly vulnerable to impacts, nor how effectiveness is assessed.

Remediation channels for affected communities

Reference: page 99, 130.

Outcome for the year. "As in previous years, in 2025 our company did not record any negative impacts on communities. Our focus remains on maintaining this situation... continuing to use our methods and tools to closely and systematically monitor operational results, detect risks early, evaluate impacts, and identify and implement corrective and improvement measures in a timely manner" (page 99).

Channels (page 99). "Should a member or representative of a community become aware of, or believe they have been affected by, either an action or an inaction of the company in a case where action would have been appropriate, they may submit notifications, complaints, or grievances through any publicly available contact channel: in writing, at the company's head office, via the registry, by post, fax, or e-mail. Such notifications may be submitted either personally or through a third party expressly authorised by the individual."

"In all such cases, the Company acts diligently to resolve notifications, complaints, or grievances, even if submitted anonymously. Cases are handled discreetly, with due respect for the confidentiality of information" (page 99).

The disclosure does not report the number of grievances received, does not state whether communities are aware of or trust the channels, and does not describe how remedy would be provided or tracked.

Taking action on material impacts on affected communities

Reference: pages 99-100, 130.

"In 2025, Aerostar continued to carry out extensive activities to present the company and its job opportunities at technical colleges, technological high schools, and technical universities across the country... We maintain close relationships and formal partnerships with technological high schools and technical colleges in Bacau and Iasi, allowing their students to undertake internships within the company. For a significant number of these students, we also provide private scholarships; upon graduation, these students are given priority for employment" (page 100).

Environmental impacts on communities (page 100). Measures sit in the "Action Plan for Achieving Quality and Environmental Objectives" for 2025: updating environmental work instructions, training environmental officers, environmental inspections in areas with significant environmental aspects, and planned environmental audits.

"During 2025, no issues or incidents were reported regarding human rights in relation to affected communities" (page 100). No expenditure, scholarship count or intern count is given, and effectiveness is not measured.

Targets related to affected communities

Reference: pages 97, 100, 130.

The objective and its monitoring measures are stated (page 100):

"The Company's objective is to attract as much of the local human resources as possible and to make jobs attractive to young graduates, in order to hire and retain them within the company. Through monthly human resources reports, the Company monitors the evolution of the number of graduates employed and, among them, the number of those who have received private scholarships, as well as the retention rate of employed graduates over relevant time intervals (1 year, 2 years, 3 years, 5 years), with the aim of identifying and planning targets and courses of action for improvement."

This is effectiveness tracking rather than a target: the monitoring is being used "with the aim of identifying and planning targets", which places target setting in the future. No base year, target year or level to be achieved is given, and none of the monitored values, graduates employed, scholarship holders among them, or retention rates at one, two, three and five years, is reported.

The community impacts were found not material and the risks without financial materiality (page 97). The disclosure does not say whether affected communities were engaged in setting the objective.

Policies related to consumers and end-users

Reference: pages 101-102, 131.

End-users are one of the two areas Aerostar identifies as financially material (page 54). Its end-users are "the integrators of our products into the final product" in manufacturing, airlines in civil aircraft MRO, and the Ministry of National Defence and the Ministry of Internal Affairs in military MRO (page 101).

Data confidentiality (page 102). "Our management system ensures the confidentiality of our customers' data through the implementation of effective strategies designed to prevent any breaches. Thanks to the system and our ongoing efforts to enhance it, no complaints have been recorded from customers or end-users regarding non-compliance with data confidentiality requirements."

The safety commitment carrying the material risk sits in the SBM-3 section rather than here: "The delivery of products and services that ensure the highest level of safety for users, closely linked to compliance with quality standards and continuous improvement, represents a top priority objective for the Company" (page 101).

What is absent. The Annex 4 index lists S4-1 with the data points column blank (page 131). No named policy document is identified, public availability is not stated, no accountable level is named, and alignment with the UN Guiding Principles for this group is not described.

Engaging with consumers and end-users about impacts

Reference: pages 102-103, 115, 131.

"We place particular importance on communication and transparency, ensuring that customers and end-users have direct channels of contact via email, telephone numbers, or fax listed on the Company's website, as well as through other means recorded in the 'Stakeholders' table. In addition, in business relationships, each operational department within the Company maintains direct contact with the corresponding departments of our customers. The Marketing and Development department also includes a communications office responsible for public relations" (page 102).

"Transparent communication strengthens and consolidates our partnerships. This approach enables us to expand our market presence and develop long-term relationships" (page 102).

What is absent. ESRS asks whether engagement occurs directly with consumers and end-users or with credible proxies, at which stage and how often, its purpose, and how effectiveness is assessed. Aerostar describes commercial contact routes rather than engagement about impacts, states no frequency or stage, names no function with operational responsibility, and does not identify end-users who may be particularly vulnerable. The Annex 4 index row carries no applicable data points (page 131).

Remediation channels for consumers and end-users

Reference: pages 81, 95, 99, 102-103, 131.

The disclosure is short and preventive in emphasis (page 103):

"Recognising the importance of protecting the well-being of end-users of our products and anticipating potential impacts, we strictly follow manufacturing processes in accordance with our customers' specifications. AEROSTAR has action plans and objectives in place to reduce the risk of non-compliance and eliminate associated costs if they arise.

In our sustainability policy, we are committed to ensuring the highest standards of quality, reliability, and safety."

No grievance channel for end-users is identified. The report describes named channels for employees (sesizari@aerostar.ro, page 81), for value chain workers, including anonymous complaints (page 95), and for communities, in writing at the head office, via the registry, by post, fax or email, also accepting anonymous submissions (page 99). For consumers and end-users it describes commercial contact routes under S4-2 (page 102) but does not present them as a route for raising concerns or as a remediation process.

How remedy is provided, whether third-party mechanisms exist, and the number of complaints received are all unreported. The Annex 4 index row carries no applicable data points (page 131).

Taking action on material impacts on consumers and end-users

Reference: pages 101-103, 131.

Aerostar's response to its one financially material product-safety risk is a certification and audit regime rather than a set of dated actions (page 103):

"Relevant certification bodies audit our production facilities and support functions at least annually, carrying out surveillance audits, and these are recertified every three years. We hold EASA, FAA, and EMAR certifications, covering design, production, and maintenance. In addition, we hold authorisations obtained following audits conducted by our customers.

AEROSTAR directly monitors compliance with internal procedures and policies through continuous internal audits.

We are certified according to ISO 9001 and EN/AS9100, management standards, aligning us with international quality standards.

Products and services are developed in full compliance with the requirements of our customers and end-users, as well as with applicable legal and regulatory requirements, to ensure the health and safety of users."

What is absent. No outcome metric for the material risk: no product safety incident count, no customer complaints figure, no field returns or airworthiness findings, no audit non-conformity count, and no expenditure. Effectiveness is asserted through certification rather than measured.

Business conduct policies and corporate culture

Reference: page 105, 131.

The instrument. "General guidelines regarding the conduct of the Company's business... are detailed in the 'Aerostar Code of Conduct and Business Ethics,' which we have voluntarily adopted for several years. This Code forms part of the Collective Labour Agreement and is made available to all stakeholders through publication on the Company's website. The Code of Conduct and Ethics is mandatory for all employees, regardless of their hierarchical position, and applies both to employee conduct and to interactions with customers, suppliers, investors, representatives of the local community, and other business partners. Where the Code requires a higher standard than that demanded by commercial practices or applicable laws, rules, or regulations, we ensure that we adhere to these higher standards" (page 105).

Expected behaviour and sanctions (page 105). Those acting for the company "are expected to communicate openly and always act with the highest integrity... No unethical behaviour is tolerated under any circumstances... Any individual who violates these conduct and behavioural rules may be subject to disciplinary, civil, or criminal sanctions."

The disclosure does not describe how corporate culture is evaluated in measurable terms, reports no training coverage, and does not describe whistleblower protection by reference to the EU Whistleblowing Directive.

Management of relationships with suppliers

Reference: pages 93-95, 105-106, 131.

Process (page 106). "The principles for evaluating and selecting suppliers for procurement, as well as the methods for monitoring supplier performance in use, are defined in the Company's internal procedure for the procurement of products and services. This involves continuous dialogue with suppliers through self-assessment questionnaires and clarifications where needed, as well as monitoring sheets, calculation of performance metrics, and communication of monitoring results to suppliers."

Documents (page 106). The Supplier Code of Conduct sets expectations and "where our expectations are not met, the business relationship may be reviewed and corrective actions proposed under the terms of the contract". Suppliers must "comply with the labour legislation applicable in their country of origin", with further requirements in the "General Terms and Conditions of Purchase". Quantified coverage is reported under S2: 87% of suppliers have signed the Declaration of Adherence to the Ethics and Conduct Policy (page 94) and 80% of the most important suppliers returned the sustainability self-assessment questionnaire by the end of 2025 (page 95). The company also states it "did not apply social criteria in their selection" in 2025 (page 93).

The disclosure does not address the risk of vulnerable suppliers in the supply chain.

Prevention and detection of corruption and bribery

Reference: pages 106-107, 131.

Detection and reporting (page 106). Employees "are required to report it immediately to management, which will take all necessary steps to verify the accuracy of the event. Established reporting channels and a whistleblowing system enable employees to report, safely and anonymously, any suspected violations. Both Company employees and members of our local community can submit requests, complaints, notifications, or proposals to management through formal meetings... held by the Chief Executive Officer, or, in their absence, by their designated deputy... The final resolution is communicated in writing to the concerned party."

What is absent. No anti-corruption training coverage by function at risk; no separation described between the investigating function and the management chain receiving reports; and no risk assessment of functions most at risk of corruption.

Targets related to business conduct

Back-filled from the professional conduct chapter, where targets fall under the minimum disclosure requirements rather than a numbered disclosure requirement. G1-3 became a standalone targets DR only in the 2025/2026 ESRS.

Reference: pages 104, 106-107.

Aerostar sets no measurable business conduct target. No base year, target year or level to be achieved appears in the professional conduct chapter, and none is set for training coverage, incident rates, payment days or supplier code adherence.

Consistent with the alternative limb of MDR-T, effectiveness is tracked in the absence of targets:

• Supplier monitoring. The procurement procedure provides for "continuous dialogue with suppliers through self-assessment questionnaires and clarifications where needed, as well as monitoring sheets, calculation of performance metrics, and communication of monitoring results to suppliers" (page 106).

• Outcome tracked year on year. "In 2025, no concerns or requests for guidance regarding unethical or illegal behaviour, or organisational integrity, were reported within the Company. No incidents of corruption occurred, no employees were dismissed or sanctioned for acts of corruption..." (page 107).

• Stated improvement aim. The only forward commitment in the G1 materiality table is recorded as an opportunity rather than a target: "Improving control over compliance with the Company's Code of Conduct and Ethics" (page 104).

Incidents of corruption or bribery

Reference: pages 104, 107, 122, 131.

Aerostar reports a complete nil return for 2025 (page 107):

"In 2025, no concerns or requests for guidance regarding unethical or illegal behaviour, or organisational integrity, were reported within the Company. No incidents of corruption occurred, no employees were dismissed or sanctioned for acts of corruption, and no corruption-related incidents led to the termination or refusal to renew contracts with business partners. During 2025, we were not involved in incidents of this nature, nor were any legal actions recorded in relation to these matters."

That covers the substance of the requirement: convictions and fines for violation of anti-corruption and anti-bribery laws (none), confirmed incidents (none), incidents in which own workers were dismissed or disciplined (none), and incidents relating to contracts with business partners that were terminated or not renewed (none). Legal proceedings are also addressed (none).

The disclosure does not state the total amount of fines as a monetary figure, which would be zero, and does not describe the functions or standards covered by the count. The reporting channels behind the figure are described under G1-3 (page 106).

Political influence and lobbying activities

Reference: pages 21-23, 107, 122, 131.

The disclosure is a nil return with a governance statement attached (page 107):

"Consistent with its beliefs, principles, and values, in 2025 our Company continued to have no political interests or affiliations of any kind. Consequently, we made no political donations and undertook no lobbying activities.

Furthermore, during 2025, none of the members of the Board of Directors or of the Company's management and supervisory bodies held a comparable position in public administration (including within regulatory authorities)."

The second paragraph answers the ESRS requirement to disclose whether a member of the administrative, management or supervisory bodies held a comparable position in public administration, at least for the reporting year. The governance tables corroborate it: the political affiliation column reads "None" for every one of the five Board members, both executive managers and all listed operational managers (pages 21-23).

Aerostar is a supplier to the Romanian Ministry of National Defence and Ministry of Internal Affairs (page 7) and is part of the national defence industry under Law 232/2016 (page 8), which makes the nil return on political contributions and lobbying a meaningful disclosure rather than a formality.

Annex 2 records no impacts, risks or opportunities for the political engagement subtopic (page 122).

Payment practices

Reference: pages 104, 107, 122, 131.

"The major risk of a decrease in the company's turnover due to the loss of customers as a result of the inability to deliver products/services on time, caused by supply issues, drives us to maintain strong relationships with suppliers and to build their confidence through fair payment practices. Given that in the aviation sector we work with suppliers mandated by our customers, who are often limited in number or overburdened... we cannot afford to weaken the supply chain through late payments or non-payment to suppliers. For these reasons, we act to ensure a positive impact regarding our fair payment practices, which involve honouring all invoices promptly, within agreed terms, for all suppliers who fulfil their contractual obligations. In 2025, there were no reported delays in payment, nor any legal actions concerning non-compliance with our payment terms" (page 107).

What is absent. None of the four ESRS measures is reported: the average time to pay an invoice from the date the contractual or statutory term starts; the percentage of payments aligned with standard payment terms; a description of standard payment terms by main supplier category; and the number of outstanding legal proceedings for late payment. The nil statement addresses the fourth in narrative form only, and no payment-days figure is given.