Astarta Holding

The responsibilities of the governing bodies and key executive management on sustainability matters are reflected in the Explanatory guidance note to the Board of Directors, Rules of the Sustainability and Corporate Responsibility Committee and Rules of the ESG Committee which are available on the Company's corporate website.

For composition and diversity of the Board of Directors, Executive Management and the Company's committees including the number of executive and non-executive Directors and their and Management team biography, please refer to the Corporate Governance section of this report as well as to the Company's corporate website.

The Company has a two-level structure for management of the sustainability matters.

The Board of Directors level (strategic level)

Based on the Explanatory Guidance Note to the Board of Directors approved by the Annual General Meeting of the Company the Board of Directors is responsible for overall environmental and social governance, overseeing the sustainability-related issues including but not limited to the climate strategy, the climate performance objectives and targets, budget associated with the climate-related issues, reviewing the material climate-related risks once per year. To assist the Board of Directors in fulfilling its responsibility for oversight of relevant sustainability and corporate social the Company established the Sustainability and Corporate Responsibility Committee.

Committee consists of three members of the Board of Directors. Based on its Rules the Committee regularly reports to the Board of Directors and meets at least two times a year. In 2024 the Committee conducted two meetings and discussed key data on GHG emissions, energy and water consumption, waste management as well as key climate related risks and opportunities.

The Committee has the following roles and responsibilities: • oversee and provide input to management on the Company's policies, strategies and programmes related to matters of sustainability, corporate responsibility including climate-strategy, plans of action related to climate strategy; • consider the climate strategy of the Company, provide corresponding recommendations, and submit the same for the approval of the Board of Directors. • set the goals and targets and monitor the progress against them on matters related to sustainability and corporate social responsibility including climate issues; • review of the reports regarding relationships with key external stakeholders on the sustainability and corporate social responsibility matters; • oversee and provide input to management on the Company's identification, assessment and management of risks associated with sustainability and corporate responsibility issues, including, but not limited to, climate change and food safety; • review of the sustainability-related results; • advise and make proposals with respect to budget on sustainability and corporate social responsibility activities.

The Executive Management level (operating level)

To govern the environmental, social, and corporate governance issues including those that relate to climate matters on the operating level, the Company has an Environmental Social and Governance (ESG) Committee. The ESG Committee consists of the key members of the Executive Management including the CFO, heads of upstream and downstream operations and is chaired by the CEO. Based on its Rules the Committee meets at least two times a year. In 2024 the Committee conducted three meetings.

The Rules of the Committee include the following roles and responsibilities: • review and approval of the ESG strategy, targets, plans, and programmes on environment, social and corporate governance; • review of the climate risks and opportunities and other ESG risks; • review and monitor the performance of the ESG strategy, plans, programmes, and targets; • reporting to the Sustainability and Corporate Responsibility Committee members on key ESG results and issues, including climate matters.

The Director for Sustainable Business Development and Investor Relations (SBDIR Director) leads the sustainability function on behalf of the executive management board. The scope of responsibilities covers sustainability strategy, monitoring of implementation of sustainable practices and targets, overseeing compliance with local and international standards and requirements in the sphere of sustainable development, as well as reporting to stakeholders. According to the Rules of the ESG Committee the SBDIR Director is also responsible for receiving information on key impacts, risks and opportunities from other members of the Executive Management team in accordance with their functional responsibilities.

The SBDIR Director prepares the report on key findings and outcomes including climate issues, monitoring of performance status on plans and targets and, after approval by the ESG Committee, brings it to the attention of the Sustainability and Corporate Responsibility Committee. After consideration by the members of the Sustainability and Corporate Responsibility Committee the report is presented to the Board of Directors on at least bi-annual basis.

In 2024 the information collected by the SBDIR Director from the executive management team included, among others, impact on the environment such as energy and water consumption, waste management, impact in the social sphere such as human capital and local communities. In 2024 the ESG Committee discussed the matters including but not limited to ESG metrics of the Company, level of preparedness for ESRS reporting, development of the previously agreed plans in the area of environmental data collection, integration of recommendations received under the project on Sustainable Procurement.

Key issues that were considered by the agenda of the Sustainability and Corporate Responsibility Committee and the Board of Directors was review of the periodic ESG results and assessment of the Rules of the Committee.

The Company can also engage third party expertise to assess its impact in relation to sustainability matters. By way of example in 2024 the Company completed a project on sustainable procurement and started a new project on climate-nature impacts and dependencies with the support of the EBRD and KPMG Ukraine.

The Company plans to disclose additional Information on sustainability-related expertise that bodies either directly possess or can leverage as well as information on sustainability-related skills and expertise relate to material impacts, risks and opportunities in 2025 report.

The responsibilities of the governing bodies and key executive management on sustainability matters are reflected in the Explanatory guidance note to the Board of Directors, Rules of the Sustainability and Corporate Responsibility Committee and Rules of the ESG Committee which are available on the Company's corporate website.

In 2024 the Company developed a dedicated procedure for sustainability due diligence and double materiality assessment and approved a corresponding internal Regulation. According to the Regulation, the ESG Committee is involved in the process of reviewing the relevant and material sustainability matters. The Company also reports material Impacts, Risks and Opportunities (the IRO) in its Annual Report which is subject for approval by the Board of Directors and is a communication tool to inform stakeholders about the results of the materiality assessment, actions, targets and metrics related to its material IRO.

The list of material IRO is disclosed alongside the relevant disclosures.

In 2024 the Company revised its Remuneration Policy in collaboration with EY to align with best market practices. The Remuneration policy came into effect after the approval at the Annual General Meeting on June 04, 2024. It is based on a gender-neutral assessment, establishes a link between the size of the remuneration and the level of involvement of the members of the Board of Directors in the business activities of the Company and their responsibilities.

Executive directors may receive remuneration that consists of a fixed and variable component. The Company expects that the variable remuneration to represent between 0% and 80% (depending on whether relevant goals are achieved) of total remuneration of the Company's Executive Directors. Other Directors will receive only fixed annual remuneration.

The variable part considers various factors, including financial and non-financial targets and is linked to the achievement of short- and long-term operating goals.

The Long-term incentive targets include financial and non-financial targets. The last one is related to GHG emissions reduction.

The long-term incentives are subject to prior approval by the Board acting on the recommendation of the Remuneration Committee. The Board also determines the targets that comprise specific metrics and the peer group constituents.

The Remuneration Policy is available on the Company's website.

Core elements of sustainability due diligence with link to relevant paragraphs in the sustainability statement are disclosed in the Table 2 Annex 1 to this section.

Table 2. Mapping of information provided in sustainability statement about due diligence process

The Company continually improves its sustainability reporting by the accounting for and control over a widening range of non-financial data. To ensure that the information which is disclosed in sustainability reporting is free from material misstatements the Company has an internal accounting system where relevant data is collected. To reduce the scope for human error in sustainability reporting the Company also has an automated accounting system for key non-financial data which was integrated as an add-on to the Company's main financial accounting system, with clear roles and responsibilities assigned to management and employees.

The system covers data on energy and water consumption, waste management, pollution and relates to all activities, products, and services. It allows to clearly differentiate resources consumed for production and administrative needs. The system performs a comparative analysis of resource consumption between business segments. To ensure the quality of the information the system has a control point such as documentary confirmation of the data uploaded to the system.

In 2022 Astarta entered into a tri-party agreement with the EBRD and EY to develop a comprehensive system of climate corporate governance. Under the project the Company developed a dedicated model for GHG emissions calculation which is based on IPCC methodologies.

The Company has also initiated a project on automated data accounting for material categories of Scope 3 GHG emissions which will contribute to the comprehensive data collection.

The Company identified key risks related to sustainability reporting following the risk assessment results. Considering the scale of the business of the Company and its diverse nature Astarta is still working on the improvement of data accounting in the sphere of water consumption and waste generation. The key reason for this is complexity of installation of data control and measuring devices at each point of water withdrawal, water discharge and waste generation which requires adjustments of it accounting methodology. As this work remains in progress, the Company didn't disclose data related to volumes of water consumption and waste generation.

Astarta is committed to integrating sustainability into the core of its business strategy. The Company recognises that its operations and value chain have the potential to affect various environmental, social, and governance issues and is committed to managing these impacts responsibly.

According to the ESRS sector classification Astarta's activities are concentrated in two key business sectors: Agriculture & Farming and Food & Beverages. In those sectors Astarta identifies four key business segments: Agriculture and Cattle Farming in Agriculture & Farming sector and Sugar Production and Soybean Processing in Food & Beverages sector.

All of the Company's production assets are located in Ukraine and almost all employees are also based there. For more information on the Company's employees, please refer to the "Own Workforce" section of this report.

In 2024 Astarta's revenues totalled EUR612m. Revenues in Agriculture & Farming (code: AAF) and Food & Beverages (code: MFB) sectors amounted to EUR262m and EUR335m correspondingly. For more information, please refer to the section "Segment Reporting" in the Notes to the Consolidated Financial Statements of this report.

Description of inputs and approach to gathering, developing and securing inputs is disclosed in the Business Model section of this Annual Report.

Description of outputs and outcomes in terms of current benefits for customers, investors and other stakeholders is disclosed in the Value Creation section of this Annual Report.

The Company plans to provide description of main features of upstream and downstream value chain and undertakings position in value chain in 2025.

Key elements of Astarta's general strategy with sustainability implications:

• Market Position: Astarta aims to be a leader in row crop production and processing and in dairy farming industry in Ukraine. By focusing on regenerative farming, renewable energy and energy efficiency the Company offers sustainable food products/ingredients such as grain and oilseeds, sugar, soybean meal and oil in domestic and international markets.

• Growth Strategy: Astarta expects to grow its business through expansion of the product range towards higher value-added ingredients/products and increasing the production of key agricultural products by scaling up precision and regenerative farming with focus on soil health and decarbonisation; digitalisation of agricultural production; expansion of organic farming; increasing energy efficiency; growing alternative energy generation for inhouse consumption and potential sale to the market. For more information, please refer to the "Strategy and Outlook" section of this report.

• Innovation: Astarta is committed to research and development in sustainable technologies to improve environmental footprint and resource efficiency. The Company developed a proprietary integrated multi-module IT software, called AgriChain which is focused on improving agribusiness management through the implementation of modern digital technologies in agriculture.

• Value Chain Management: The Company is actively working on promotion of sustainable practices in business among its suppliers. In 2024 Astarta completed a project to enhance its procurement process by introducing sustainability criteria in its relationship with key suppliers. This should allow to mitigate environmental and social impact within the Company's supply chain.

• Risk Management: in 2022 Astarta identified and assessed materiality of climate risks associated with its operations and the value chain. The Company also identified possible actions to mitigate the risk. For more information, please refer to the "Climate Change" section of this report. In 2024 the Company also conducted impacts, risks and opportunities identification and assessment according to the requirement of ESRS standards.

Astarta's Strategy is based on its vertically integrated and diversified business model (as presented in the "Business Model" section of this report). It acts as a liaison, connecting its activities and resources to value creation for all stakeholders and building a resilient and sustainable ecosystem. This win-win approach fosters long-term success, ensuring the Company thrives while contributing positively to the communities and environment it operates within. For more information on value creation please refer to the "Value Creation" section of this report.

The Company defines the following group of stakeholders based on the business model of Astarta: employees, shareholders and investors, creditors, clients, local communities, suppliers and local farmers, media, landowners, NGOs, authorities. The Company engages with all stakeholders and considers each of them to be essential for its business. Please refer to the Table 3 Annex 1 to this section.

The Company is engaging with stakeholders on a regular basis according to the Stakeholder Engagement Regulation (the "SER"). The purpose of Astarta's SER is to provide a framework for consultation and participation strategy which: • Ensure timely and transparent informing of stakeholders about the Company's business, including new projects. • Provide an opportunity to express proposals for stakeholders. • Consider stakeholders' proposals in the process of decision making, determining relevant sustainability topics, material impacts, and materiality thresholds. • Minimise possible negative impact by the Company and its new development projects activities on stakeholders. • Contribute to the sustainable development of the Company and new development projects. • Contribute to raising the efficiency of the business model by integrating the results of the engagement into the strategy.

Key stages of stakeholder's engagement:

• Identification and analysis of stakeholders. Identification of their interests and expectations. • Stakeholder engagement. Means and channels of communication with stakeholders for engagement. • Grievance mechanism. All stakeholders are eligible to register suggestions and complaints addressed to Astarta. • Monitoring and reporting. Assessment of the effectiveness of engagement and reporting on its results.

Integration of the results of stakeholder engagement is an important part of successful business, which contributes to the Company's sustainable growth, allows for improvement in decision making process, improve reputation and create new opportunities for development.

Integration of results of stakeholder's engagement:

• Analysis and synthesis: to identify material topics, issues and opportunities, the results of stakeholder engagement are thoroughly analysed and synthesised. The topics, issues and opportunities identified as having an impact on the strategy and business model of the Company are presented to the ESG Committee with operational and strategic implications, as well as recommendations on the ways for inclusion of stakeholder's views into the strategy and business model. • Integration into the strategy: following the results of the analysis and synthesis, the ESG committee may decide on the topics and opportunities to be included in the strategic planning and its business model. • Development of an action programme: following the decision on the topics and opportunities to be included in the strategic planning and its business model, the Company develops a corresponding action programme. • Communication and reporting: the Company informs its stakeholders on the progress of the action programme.

Table 3. Stakeholders and type of engagement

As a large-scale business in the Agriculture & Farming and Food & Beverages sectors with assets and operations in different rural regions of Ukraine, Astarta identified material impacts, risks and opportunities related to the nature of the Company's activities. Most of the impacts are current. Significant part of impacts, risks and opportunities relates to the environmental sphere, namely: climate change, water and energy resources use, waste management, pollution and biodiversity. Its activities are associated with certain negative impacts on the environment and people such as reduction of available water resources for human and nature, pollution and contribution to climate change due to use of fossil energy sources, loss of biodiversity. At the same time there are impacts which positively affect the environment and people through use of by-products in the main production process for reduction of GHG emissions and pollution as alternative energy source.

The current financial impact of the risks is rather limited while the anticipated impact of certain risks related to the dependencies on the resources and materials can become more significant.

In the Social sphere majority of material impacts identified are related to own workforce and workforce within in the value chain as well as local communities. Key material negative impacts mainly refer to the russian invasion and related changes in the Ukrainian legislation resulting in drafting of employees to the Armed Forces of Ukraine, overtime work for employees, health and safety risks. Material positive impacts derive from for employee's social protection, corresponding remuneration, support and development of employees.

In the Governance sphere the Company identified material impacts which relate to corporate culture, animal welfare, corruption and bribery. There are mainly positive material impacts that were identified which contribute to a more stable and sustainable business landscape.

The Company has not identified any material risks in the Social and Governance sphere as it has sufficient control instruments which allow for reduction of risks to the level below materiality.

Material IRO are affecting Astarta's business model, strategy and decision-making process. Recognizing the critical connection between material IROs and business growth, the Company has strategically embedded initiatives to minimize negative impacts within its governance systems. Astarta has improved its governance mechanism, developed several programmes related to efficiency of use of natural resources, support and development of employees and local communities.

All material IRO are covered by ESRS disclosure requirement except for IRO related to the russian invasion impact.

As 2024 marked the Company's first year conducting due diligence and a double materiality assessment according to ESRS standards, Astarta plans to provide information about the resilience of its strategy and business model in addressing material impacts, risks, and opportunities in its 2025 report.

In 2024 the Company developed internal Regulations for Sustainability Due Diligence process and Double Materiality assessment in the environmental, social and governance sphere according to the requirements of ESRS standards.

The Company uses various methods to identify IRO, including brainstorming, surveys, interviews, and the analysis of historical and statistical data. The identification process also involves reviewing internal documents, external sources, stakeholder feedback, and market trends. The Company also considers its own business model and any relevant regulations.

The process of identifying and assessing potential impacts involves determining the processes and their results, identifying all impacts from these processes, classifying the impacts as positive or negative, and determining the time frame of the impact. The impacts are then assessed based on their potential severity and likelihood. The Company prioritizes negative impacts based on their severity and likelihood, and positive impacts based on their scale, scope, and likelihood. It also uses a double materiality assessment approach to determine which sustainability matters are material for reporting purposes.

The process focuses on specific activities, business relationships, and country geographies that may lead to a heightened risk of adverse impacts. The Company considers its own operations and business relationships, as well as external factors, to identify and assess potential impacts. It consults with related stakeholders to understand how they may be affected by the Company's operations and with external experts, including environmental experts and non-governmental organizations, to identify and assess potential impacts.

To identify and assess risks and opportunities the Company uses various methods, including statistical and historical data analysis, expert opinions, and the assessment of controls. It also includes consideration of the impact of risks on reputation and operations. The Company prioritizes risks based on their likelihood and potential impact and monitors them on an ongoing basis.

Decision-making process involves identifying and assessing potential impacts, developing and implementing mitigation measures, and monitoring the effectiveness of these measures. There are also internal control procedures in place to ensure that risks are identified and managed effectively.

The process to identify, assess, and manage risks corresponds to the Company's overall risk management process. At the same time IRO are considered by the ESG committee, the latter also being responsible for reviewing and approval of programmes to manage risks, and opportunities. For more information, please refer to disclosure GOV-1 "The role of the administrative, management and supervisory bodies".

The input parameters used in the process to identify, assess, and manage material impacts, risks, and opportunities include the business model, internal documents, external sources, stakeholder feedback, and market trends.

Climate-related risks and opportunities identification and assessment

The Company performed a comprehensive analysis of climate-related risks, opportunities and financial impacts based on TCFD recommendations in 2022 together with EY. The assessment includes physical and transition risks, and opportunities within own operations and along its upstream and downstream value chain.

Physical risks and opportunities

According to TCFD physical risks are the risks that emanate from climate change and relate to event-driven (acute) risk such as increased severity of extreme weather events (e.g., cyclones, droughts, floods, and fires) as well as to longer-term shifts (chronic) in precipitation and temperature and increased variability in weather patterns (e.g., sea level rise). While a potential positive impact can arise from efforts undertaken to mitigate and adapt to climate change.

Analysis of physical risks and opportunities under the 1.5ºС and >3ºС temperature scenarios was performed using the Representative Concentration Pathway (RCP) scenarios: Scenario 1 - RCP 1.9 (1.5°C equivalent) and Scenario 2 - RCP 8.5 (>3°C equivalent).

To estimate the importance of the risks and opportunities for the Company a dedicated scoring matrix of prioritisation of risks and opportunities was developed. The scoring approach considers the following parameters:

Likelihood: indicates the probability of the risk and opportunity materialising over the projection horizon

• High: Risk/opportunity is highly likely to occur with high frequencies of recurrence
• Medium: Risk/opportunity is occasional in nature with moderate frequency of recurrence
• Low: Risk/opportunity is less likely to occur with low frequency of recurrence

Impact: indicates the severity and duration of financial/operational impact, should the risk and opportunity materialise.

• Strongly positive: Opportunity is expected to create high monetary benefits for business/ operations and persist for a long duration
• Positive: Opportunity is expected to create moderate monetary benefits for business/operations and persist for long to medium duration
• Neutral: Risk/opportunity is expected to have minimal positive/negative impact on business/ operations and persist for medium to short duration
• Negative: Risk is expected to have moderate financial impact on business/operations and persist for long to medium duration
• Strongly negative: Risk is expected to have high financial impact on business/ operations and persists for a long duration

Based on the level of likelihood and impact a score from 0 (a risk with the low level of likelihood and neutral impact) to -12 (a risk with the high level of likelihood and strongly negative impact) was assigned to each risk identified. A score from 0 (an opportunity with the low level of likelihood and neutral impact) to 12 (an opportunity with the high level of likelihood and strongly positive impact) was assigned to each opportunity identified.

The physical risks analysis covers a projection horizon from 2020 to 2050 and focuses on the most significant (by the size of leased farmland) regions of Astarta's operations in the Centre and West of Ukraine as well as key business segments of the Company.

Physical risks and opportunities identified and analysed are presented in comprehensive tables covering various climate scenarios and their financial implications, along with possible adaptation measures.

Transition risks and opportunities

Transition risks are the risks that show non-physical potential impacts of climate change on the organization and can be associated with the transition to a lower-carbon global economy, the most common of which relate to policy and legal actions, technology changes, market responses, and reputational considerations.

Analysis of transitional risks and opportunities was performed based on the scenarios developed by International Energy Agency (IEA); Network for Greening the Financial System (NGFS); Principles for Responsible Investment network (PRI). The following scenarios were chosen to identify and analyse risks and opportunities under the 1.5ºС and >3ºС pathways:

• Scenarios under 1.5ºС pathway: IEA Net Zero Emissions by 2050, NGFS Net Zero 2050, PRI IPR 1.5°C Required Policy Scenario, which mostly correspond to each other. • Scenarios under >3ºС pathway: IEA Stated Policies, NGFS Current Policies Scenario, which mostly correspond to each other.

Transition risks and opportunities analysis was conducted using similar approach to those of physical risks and opportunities scoring that enables prioritisation of risks and opportunities. The transition risks analysis covers short-term (2022-2025), medium-term (2025-2030) and long-term (2030-2050).

The document includes detailed tables showing key transition risks and opportunities along the value chain, with scoring matrices and financial implications for both pathway scenarios.

Climate-related risks identification and assessment is part of the general approach to principal risk management. For more information on risk management please refer to the Risk Management section of this report.

Astarta continues implementing the Climate Corporate Governance Action Plan developed in partnership with the EBRD and EY in 2023. Under this plan the Company monitors and calculates GHG emissions for each business segment, implements decarbonisation initiatives following the targets of its decarbonization strategy which was approved by the Board of Directors and published on the Company's corporate website.

The Company's transition plan is deeply integrated into its core business strategy. Astarta systematically considers climate-related risks and opportunities in all strategic decision-making processes. Furthermore, the transition plan is closely aligned with financial planning, with budgets and forecasts reflecting the necessary investments in sustainable technologies, energy efficiency, and supply chain adjustments.

Astarta continues to demonstrate commitment to its transition plan, achieving a 17% renewable energy share in total consumption in 2024. This progress is underpinned by specific initiatives within key business segments. The Sugar Production segment consumed 22kt of plant-derived pellets and 62mm3 of biogas produced in-house as part of its energy mix. The Soybean Processing segment also used 9 mm3 of biogas in 2024.

In the Agriculture segment, Astarta continues to advance sustainable practices through reduced tillage and the use of cover crops. In 2024, the Company's commitment to soil health was demonstrated by the implementation of reduced tillage across 177kha and cover crops - 16kha.

The Company adopted the Policy on Climate Change, Greenhouse Gases (the GHG) and Energy Efficiency. The Policy sets targets, defines actions and principles in the climate change mitigation and adaptation according to Ukrainian and EU regulations.

In 2024 Astarta continued reporting under the Carbon Disclosure Project (CDP) on its activities aimed at climate change adaptation and mitigation and had its rating confirmed at "C".

Key actions related to climate change are disclosed in the section E1-1. Transition plan for climate change mitigation. Also, Astarta reiterated its commitment to operational excellence in 2024 by continuing the implementation of Best Available Techniques (BAT) programme across its sugar plants. These initiatives strategically targeted resource efficiency, leading to reduced electricity and freshwater consumption per tonne of processed sugar beet.

A comprehensive qualitative assessment of potential locked-in GHG emissions from the Company's key assets and products requires both thorough analysis and a stable operating environment. Therefore, the Company plans to conduct this assessment once military hostilities have ceased and the operating environment returns to normal.

The process for setting climate-related target is disclosed in the section E1-1. Transition plan for climate change mitigation.

The practical component of the strategy focuses on initiatives in the two business segments (The Agriculture and the Sugar Production) which have the highest potential for emissions reduction. Among them is scaling up regenerative farming practices, improving energy efficiency, and using alternative energy sources. Side benefits also include enhancing soil health and preservation of moisture, reduction of fertiliser use, increasing crop yields, and reduced energy consumption in production, including precision agriculture.

With these measures Astarta planned to reduce total GHG emissions by 44% to 450kt CO2eq in 2030 compared to 2022 baseline in line with the Paris Agreement requirements. In particular, a 27% reduction is targeted in Scope 1 from 480kt CO2eq, 47% reduction in Scope 2 from 15kt CO2eq and 70% reduction in biogenic emissions from 311kt CO2eq.

The measures to reduce Scope 1 and Scope 2 emissions include:

• Energy efficiency programmes - 73kt CO2eq of estimated GHG reduction; • Use of biofuel in agricultural machinery - 51kt CO2eq of estimated GHG reduction; • Substitution of fossil fuels with renewable ones at processing facilities - 14kt CO2eq of estimated GHG reduction.

The measures to reduce biogenic emissions include:

• Expansion of area under reduced tillage up to 180kha - 189kt of CO2eq of estimated GHG reduction; • Increase acreage under cover crops up to 25kha - 29kt CO2eq of estimated GHG reduction.

Energy consumption and mix

E1-5. Total energy consumption related to own operations

Astarta uses an automated accounting system, based on approved internal methodology, to comprehensively track resource consumption across operations, covering both fossil and renewable energy sources.

In 2024, total energy consumption from activities in high climate impact sectors was 1,224,473 MWh. Total energy consumption (including non-high-impact activities) was 1,225,097 MWh.

Renewable energy sources accounted for 206,745 MWh energy equivalent, or 17% of the Company's total energy consumption.

Key sugar production and soybean processing assets successfully confirmed certification according to the international standard ISO 50001 "Energy management" in 2024.

Energy consumption and mix (2024)

Breakdown by business segment (2024):

• Sugar Production: 887,364 MWh (72% of total)

  • Natural gas: 590,862 MWh (67% of segment total)
  • Coal: 130,457 MWh (15% of segment total)
  • Renewable energy (biogas and biomass): 144,467 MWh (16% of segment total)

• Agriculture: 211,894 MWh (17% of total)

  • Diesel: 176,843 MWh (83% of segment total)
  • Natural gas: 9,789 MWh (5% of segment total)

• Soybean Processing: 77,128 MWh (6% of total)

  • Biogas: 44,545 MWh (58% of segment total)
  • Natural gas: 19,556 MWh (25% of segment total)

• Cattle Farming: 39,341 MWh (3% of total)

  • Diesel: 25,203 MWh (64% of segment total)
  • Purchased electricity: 9,938 MWh (25% of segment total)

E1-5. Energy intensity

Energy intensity based on net revenue, MWh/'000 EUR (2024)

Methodology

To calculate energy consumption, Astarta used Ukraine's Greenhouse Gas Inventory 1990-2021, CDP Technical Note: Conversion of fuel data to MWh, and internal technical documentation as the main source of specific indicators.

For net revenues used to calculate energy intensity, refer to Note 13 of the Consolidated Financial Statements in this Annual Report.

Gross Scopes 1, 2, 3 and Total GHG emissions

Astarta calculated GHG emissions following GHG Protocol Standards and IPCC Guidelines for GHG inventory. The global warming potential used is based on the IPCC's Sixth Assessment Report, 2022 (AR6).

Total GHG emissions disaggregated by Scopes 1, 2 and significant Scope 3

GHG emissions by segment (2024)

Scope 1 sub-breakdown (2024):

Agriculture segment (234,049 tCO2eq):

• Land management (N inputs, atmospheric deposition, N leaching/runoff): 182,605 tCO2eq (78%)
• Mobile sources (agricultural machinery): 49,405 tCO2eq (21%)

Sugar Production segment (172,575 tCO2eq):

• Stationary sources (natural gas and coal combustion): 144,207 tCO2eq (84%)

Soybean Processing segment (4,561 tCO2eq):

• Natural gas combustion: 3,942 tCO2eq (86%)

Cattle Farming segment (90,338 tCO2eq):

• Enteric fermentation: 68,982 tCO2eq (76%)

GHG Intensity based on net revenue

Biogenic CO2 emissions

Biogenic emissions are reported separately from Scope 1. In 2024 biogenic emissions totalled 287,888 tCO2eq (including removals from cover crops), due to lower output of key agricultural crops by -29% y-o-y to 555kt.

Biogenic emissions are defined as emissions from biological sources or materials derived from biological matter. All sources are associated with carbon of biomass origin, which has been previously accumulated from atmosphere during biomass growth period.

GHG removals

Astarta expands regenerative agricultural practices such as cover cropping, diversified crop rotation, reduced tillage, and organic fertilisers application. In 2024, 15,844 ha of Astarta's land were sown with cover crops which removed 14,525 tCO2eq or 0.92 tCO2eq per ha.

The Company did not purchase nor intend to purchase carbon credits from the voluntary market in 2024.

Methodology

Methodologies used for GHG emissions calculation:

Scope 1 and biogenic emissions:

• GHG Protocol 'A Corporate Accounting and Reporting Standard'
• GHG Protocol 'Agricultural Guidance. Interpreting the Corporate Accounting and Reporting Standard for the agricultural sector'
• 2006 IPCC Guidelines for National Greenhouse Gas Inventories
• 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories
• US EPA 'Greenhouse Gas Inventory Guidance. Direct Fugitive Emissions from Refrigeration, Air Conditioning, Fire Suppression, and Industrial Gases'
• Ministry of Environmental Protection and Natural Resources of Ukraine / UNFCCC 'Ukraine's Greenhouse Gas Inventory. Annual National Inventory Report for Submission under the United Nations Framework Convention on Climate Change and the Kyoto Protocol'
• Ministry of Environmental Protection and Natural Resources of Ukraine. Methodological recommendations for estimating greenhouse gas emissions by type of activity of installations

Scope 2:

• GHG Protocol. Scope 2 Guidance
• Harmonised IFI Default Grid Factors 2021 v3.2

Scope 3:

• GHG Protocol. Corporate Value Chain (Scope 3) Standard
• Scope 3 Calculation Guidance
• GHG Protocol, Scope 3 Evaluator
• Department for Environment, Food & Rural Affairs of UK, UK and England's carbon footprint to 2019
• United Nations, IFI Default Grid Factors 2021 v3.2
• United States Environmental Protection Agency, GHG Emission Factors Hub
• Ministry of Environmental Protection and Natural Resources of Ukraine / UNFCCC 'Ukraine's Greenhouse Gas Inventory'
• EPA Center for Corporate Climate Leadership. 2023 GHG Emissions Factors Hub
• Employee commuting emissions are calculated using an average CO2eq factor per employee. This factor is calculated by dividing the total CO2eq emissions (from the survey conducted by the Company among its employees in 2023) by the total employee number.

Scope 2 emissions calculation is based on location-based method. The Company does not apply market-based Scope 2 calculation.

Astarta expands the scale of regenerative agricultural practices across its farmlands such as cover cropping, diversified crop rotation, reduced tillage, organic fertilisers application etc. In 2024 15,844ha of Astarta's land were sown with cover crops which removed 14,525t CO2eq or 0.92t CO2eq per ha.

In 2024 the Company did not purchase nor intended to purchase carbon credits from the voluntary market.

Astarta does not apply internal carbon pricing schemes to support decision making and incentivise the implementation of climate-related policies and targets.

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

The Company disclosed information about anticipated financial effects from material physical and transition risks and potential climate-related opportunities in disclosure IRO-1.

Astarta commits to reduce negative impact from production activities by implementing energy efficiency programmes, regenerative farming, GHG emissions reduction measures, monitoring of pollutants and developing preventative measures.

Basic principles of the Environmental protection policy:

• To reduce waste; • To prevent pollutants or harmful substances from entering water bodies; • To ensure the protection of the sanitary zones around water bodies; • To perform the monitoring of water bodies; • To contribute to the reduction of emissions of air pollutants; • To prevent soil contamination; • To implement land protection programmes; • To prevent accidental spills of harmful substances.

In 2025, the Company plans to update internal policies including for the purposes of addressing substituting and minimizing the use of substances of concern and phasing out substances of very high concern.

To avoid significant pollution of environment Astarta has a monitoring system to control emissions of contaminants. The monitoring is conducted by accredited laboratories on an annual basis according to special permits and Ukrainian legislation requirements.

The main air pollutants monitored by the Company are particulate matter, nitrogen dioxide, ammonia, sulphur dioxide, carbon monoxide, methane, carbon dioxide etc.

Due to the ongoing war, Astarta will prioritize the setting of pollution targets upon the restoration of stable operating conditions.

Pollution of air

Astarta does not directly measure air pollutant emissions. The Company uses the calculation methods set out in the document "Report on Inventory of Air Pollutant Emissions from Stationary Sources" prepared for each business facility.

Main methodologies used: • IGD 34.02.305-2002 Emissions of pollutants into the atmosphere from power plants. Method of determination. 2002. • Collection of methods for calculating the content of pollutants in emissions from non-organised sources of air pollution. • Collection of indicators of emissions (specific emissions) of pollutants into the atmosphere by various industries (volumes 1-3). • Methodology for calculating emissions of harmful substances from quarries considering the non-stationarity of their technological processes. Kryvyi Rih, NIIBTG, 1989. • OND-86. Methodology for calculating concentrations of harmful substances in the atmospheric air arising from emissions of enterprises. • RD 52.04.52-85. Guidelines. Regulation of emissions under adverse meteorological conditions. • Collection of Methods for Calculating Air Pollutant Emissions by Various Industries.

Ukrainian legislation allows the use of other methodologies.

Astarta has a comprehensive automated system of environmental management that includes a monitoring module for all types of emissions data, sources, dates of sample intakes, volume of contaminants etc. for each facility. Environmental monitoring is performed under internal monitoring plans that include requirements of the Ukrainian legislation and internal standards.

The total volume of material air pollutants under Annex II of the Regulation (EC) No 166/2006 was 173,553t.

Air pollutants, 2024, t

*- emissions were calculated under IPCC Methodologies

Pollution of water

Astarta performs monitoring of quality of water discharged according to permits from the State Agency of Water Resources. The Company monitors major parameters in discharges such as suspended solids, sulphates, chemical oxygen demand, biological oxygen demand, chlorides total, phosphates, ammonium nitrogen, nitrates, saponins etc. Based on the analysis conducted by accredited laboratories Astarta does not exceed the thresholds of pollutants under Annex II of the Regulation (EC) No 166/2006.

In 2025 the Company plans to perform an analysis on compliance with the requirements of Ukrainian legislation in comparison with the EU requirements on water quality and assess its materiality.

Pollution of soil

The Company monitors quality of soil within sanitary protection zones around production facilities according to internal environmental regulations. The sampling is taken in areas which are located near open storage lagoons for sugar beet pulp, manure storage systems, warehouses for fuel and plant protection products. The soil samples are analysed for the concentrations of ammonia, oils, pH, lead and its compounds, nitrates, phosphates, chlorides total, zinc etc. Due to the difference in approach and methods of soil sampling between the EU and Ukrainian requirements, Astarta is unable to assess compliance of thresholds under Annex II of the Regulation (EC) No 166/2006 for soils within sanitary protection zones. Based on Astarta's double materiality assessment, soil pollution is a material impact, primarily attributed to fertilizer use. Specifically, the Company's 2024 fertilizer consumption data reveals that 2,977,609kg of phosphorus and 16,038,445kg nitrogen were applied to the soil. Total nitrogen and total phosphorous cross the value threshold outlined in Annex II of Regulation (EC) No 166/2006.

Microplastics

As a result of double materiality assessment generation of microplastics was recognised as nonmaterial.

The CSRD, set to apply from January 1, 2024, for financial years starting on or after that date, introduces specific requirement to report on changes over time. As a result, the Company will begin reporting on changes over time starting with the reporting year following 2024, allowing for meaningful comparisons based on the new CSRD guidelines.

Substances of concern and substances of very high concern

Astarta has a management system for hazardous substances in place. The internal standard requires to use only those substances which are approved by the Ukrainian legislation and international standards. The Company drew a list of substances that contains the following information: volumes, class of hazard, storage and safety requirements.

Astarta did not perform compliance assessment for used substances under the ECHA/NR/21/20 Candidate list of substances of very high concern. The Company plans to conduct this assessment in 2025.

No quantitative disclosure of total amounts of substances of concern or substances of very high concern in tonnes is provided for the 2024 reporting year.

The Company disclosed information about anticipated financial effects from pollution in Table 6 Annex 2 to this section.

In 2024 there were no pollution-related major incidents and deposits. At the same time the Company plans to provide information on overall operating and capital expenditures related to pollution in 2025 report.

In the Environmental policy Astarta is committed to fully comply with Ukrainian legislation in water resource management, adhere to rational use of water resources and prevent pollution of water bodies, perform monitoring of water sources and discharges from own operations. Astarta implements environmental monitoring programme to ensure the quality of intake water and discharged wastewater. The Company uses a comprehensive automated system for data management. Furthermore, the Company intends to adopt a Water Resource Policy in 2025, to take into account identified impacts, risks, and opportunities.

Astarta strives to comply with the requirements of special water permits, adhering to the set water intake limits and monitoring water resources.

In the Sugar Production segment, the Company implements measures to reduce freshwater consumption, improve the quality of water in the Second category, and ensure proper maintenance of water treatment facilities.

In the Soybean Processing segment the Company applies a reverse osmosis system. Discharged water goes through physic-chemical and biological purification at the local water treatment facilities. After this stage the water is discharged to the absorption fields for further biological treatment.

Water consumption is measured at water intake and discharge sources by metering equipment. The Company measured 97% of water intake and 6% of water discharge by water flow meters (the low share of measurement of the latter is explained by the fact that certain discharge sources do not require water flow meters, such as septic tanks).

The ongoing war in Ukraine lead to postponement of setting targets related to water consumption.

In 2024 Astarta continued developing internal accounting of water consumption to cover water balance in the Sugar Production and more precise accounting of water usage in plant protection in the Agriculture.

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

The Company disclosed the information about anticipated financial effects from pollution in Table 6 Annexe 2 to this section.

The project "Investigating climate-nature impacts and dependencies for Astarta" includes a biodiversity impact assessment for core business segments: the Agriculture, Sugar Production, Soybean Processing and Cattle Farming. Based on the project outcomes the Company plans to develop an action plan to prevent, mitigate and account for the actual and potential negative impacts on the biodiversity.

Astarta implemented the following key standards, policies and procedures in the sphere of land use and biodiversity: the Sustainability Policy, the Environmental Policy, the Sustainable Agriculture Policy, the Deforestation Policy, the Biodiversity Corporate Standard.

The Company's biodiversity policy aims to:

• conduct thorough assessments of potential impacts, including cumulative, direct, and indirect effects, on biodiversity resulting from all greenfield and brownfield projects. • ensure the sustainable utilization of biological diversity, preventing long-term depletion through responsible resource management. • adhere to the principle of impact avoidance and implement effective mitigation strategies to minimize potential harm to biodiversity. • maintain operational exclusion from legally protected areas, such as nature reserves. • integrate and promote contemporary regenerative agriculture practices. • prioritize the use of indigenous species, naturally adapted to local and regional ecosystems, to enhance resilience against pests and diseases. • implement industry-leading best practices for the sustainable management of living organisms.

Actions and resources related to biodiversity

Astarta explicitly states that it plans to develop actions and identify resources based on outcomes of the project "Investigating climate-nature impacts and dependencies for Astarta".

Project: "Investigating climate-nature impacts and dependencies for Astarta"

Description: A comprehensive study on biodiversity in accordance with requirements of the Corporate Sustainability Reporting Directive.

Scope: Regions of Astarta's operations

Time horizon: Started in 2024, expected completion in 2025

Resources allocated:

• Non-financial: Partnership with KPMG, support from EBRD

Expected outcomes:

• Identify and assess actual and potential negative impacts, risks and opportunities in the regions of operations
• Suggest relevant targets and metrics
• Inform development of biodiversity-related actions and resource allocation
• Basis for setting biodiversity targets
• Basis for disclosing impact metrics and anticipated financial effects

Current status: Preliminary assessment of biodiversity-related impacts (identified from analysis of scientific sources) will be conducted after completing the project in 2025.

Other biodiversity-related practices mentioned

The company states commitments to:

• Prioritize the use of indigenous species, naturally adapted to local and regional ecosystems, to enhance resilience against pests and diseases
• Implement industry-leading best practices for the sustainable management of living organisms

Note: These are stated as principles/commitments rather than defined actions with allocated resources.

Targets related to biodiversity and ecosystems

Astarta plans to set targets based on outcomes of the project "Investigating climate-nature impacts and dependencies for Astarta" and war situation in Ukraine.

No specific biodiversity and ecosystem targets have been disclosed as of the reporting period. The company is conducting a comprehensive biodiversity study in 2024 together with KPMG under EBRD support, and expects to identify relevant targets and metrics upon completion of this project in 2025.

Impact metrics related to biodiversity and ecosystems change

Disclosure Status

Astarta has not disclosed quantified biodiversity impact metrics for the 2024 reporting period. The company states that it will disclose information about impact metrics in 2025 based on outcomes of the project "Investigating climate-nature impacts and dependencies for Astarta" which started in 2024 with KPMG support under EBRD.

Land Use Context

The company notes that approximately 4,000 hectares of farmland in the Chernihiv region were under temporary occupation until the beginning of April 2022. This land was cleared from mines, unexploded shells, and sizeable metal fragments and returned to farming operations. Nearby forests remain uncleared of mines, unexploded shells, metal fragments and chemicals.

Future Reporting

The company plans to:

• Identify and assess actual and potential negative impacts, risks and opportunities in the regions of its operations through the ongoing biodiversity project
• Develop relevant targets and metrics based on the project outcomes
• Conduct preliminary assessment of biodiversity-related impacts after completing the project in 2025

The company explicitly states: "The Company will disclose the information about anticipated financial effects and impact metrics in 2025 based on outcomes of the project 'Investigating climate-nature impacts and dependencies for Astarta'."

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

The Company will disclose the information about anticipated financial effects and impact metrics in 2025 based on outcomes of the project "Investigating climate-nature impacts and dependencies for Astarta".

The Company's Environmental policy outlines priorities on protection of natural resources and minimizing environmental impact, commitment to complying with environmental laws and minimizing carbon footprint, continuous improvement and efficient resource use. It also emphasizes waste reduction, water conservation, and biodiversity preservation. The Climate Change, GHG emissions and Energy Efficiency policy emphasizes a continuous improvement approach, integrating sustainable practices throughout business operations.

The sustainability principles of Astarta business are to minimise the impact of its activities on the environment by using renewable energy sources, implementation the energy efficiency measures, reduction of natural resources consumption and waste, using modern and sustainable technologies and approaches.

Astarta, on an annual basis, implements specific initiatives within the Best Available Techniques (BAT) programme in the Sugar Production segment. These measures are specifically designed to optimize resource efficiency, focusing on the reduction of water, raw material, and energy consumption per tonne of sugar beets processed.

Due to the ongoing war, Astarta will prioritize the setting of resource use and circular economy targets upon the restoration of stable operating conditions.

Materials outflows

Across its value chain Astarta identified the following key material outflows for each business segment.

The key products produced by the Agricultural segment are grains and oilseeds as well as sugar beets. Grains and oilseeds are sold in bulk, mainly for exports, and sugar beets are processed internally by the Sugar Production segment. The Agricultural segment handles organic residue after harvesting row crops. Some of the residues are left in the fields to preserve soil and some are used in cattle farming as bedding for cows.

There is also some plant-based residue generated in silos from handling of grains and oilseeds which are partially disposed to landfills and partially sold. The residue for sale is typically processed into pellets, animal feed and bedding. The Agriculture segment also generates waste from operating and maintenance of machinery and transport as well as packaging from pesticides and fertilisers.

Soybean meal and oil are the key products in soybean crushing which are sold in bulk. The by-product of the crushing process is husk which is sold to third parties. The Soybean Processing segment also generates waste during the process of equipment cleaning and replacement of filters in dust and gas treatment installations.

Milk is the key product of the Cattle Farming segment. The milk is sold in bulk without packaging. Manure generated on the cattle farms is applied as fertiliser on the fields in the Agricultural segment. The Cattle Farming generates waste from use of veterinary inputs and medicines derived from animal healthcare.

As a big agro-industrial holding Astarta generates hazardous (according to the national legislation waste of 1st, 2nd, 3rd classes of hazard) and non-hazardous waste (4th class of hazard) in the process of its daily operating activities. The separate waste collection and temporary storage comply with domestic legislation and internal standards. Before disposing of hazardous and non-hazardous waste, it is temporary stored in special yards with marked boxes for waste sorting. To dispose of the hazardous and non-hazardous waste, Astarta cooperates with companies that are reputable and licensed by relevant authorities to handle such waste. Within waste recovery operations these companies typically obtain valuable components or incinerate waste for energy generation.

The share of hazardous waste is negligible and mainly comes from fluorescent lamps, battery packs, used oils, used packaging of pesticides, fertilisers, other chemical materials etc.

Non-hazardous waste generated by the Company mainly includes residue from the production process such as paper, plastic, waste from packaging materials, used tires etc.

Solid household waste generated within the Company's activity is disposed at landfills.

In the process of sugar beets processing Astarta produces sugar and generates by-products such as sugar beet pulp and molasses. Sugar is sold mainly in 25kg, 50kg and 1,000kg polypropylene bags, in bulk as well as other packaging.

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

The Company disclosed the information about anticipated financial effects related to resource use and circular economy in the Table 6 Annex 2 to this section.

Note: The referenced Table 6 Annex 2 was not included in the provided excerpts.

Waste

Waste generation:

As a big agro-industrial holding Astarta generates hazardous (according to the national legislation waste of 1st, 2nd, 3rd classes of hazard) and non-hazardous waste (4th class of hazard) in the process of its daily operating activities.

The share of hazardous waste is negligible and mainly comes from fluorescent lamps, battery packs, used oils, used packaging of pesticides, fertilisers, other chemical materials etc.

Non-hazardous waste generated by the Company mainly includes residue from the production process such as paper, plastic, waste from packaging materials, used tires etc.

Solid household waste generated within the Company's activity is disposed at landfills.

Waste management approach:

The separate waste collection and temporary storage comply with domestic legislation and internal standards. Before disposing of hazardous and non-hazardous waste, it is temporary stored in special yards with marked boxes for waste sorting.

To dispose of the hazardous and non-hazardous waste, Astarta cooperates with companies that are reputable and licensed by relevant authorities to handle such waste. Within waste recovery operations these companies typically obtain valuable components or incinerate waste for energy generation.

Segment-specific waste:

Agriculture segment:

• Organic residue after harvesting row crops. Some of the residues are left in the fields to preserve soil and some are used in cattle farming as bedding for cows.
• Plant-based residue generated in silos from handling of grains and oilseeds which are partially disposed to landfills and partially sold (processed into pellets, animal feed and bedding).
• Waste from operating and maintenance of machinery and transport as well as packaging from pesticides and fertilisers.

Sugar Production segment:

• Filtration sludge in the technological process with two fractions: dry and wet. The wet fraction is disposed to the absorption fields. The dry fraction is used for maintenance of absorption fields.
• Other waste comes from input materials such as technological inputs, batteries, materials for laboratory and transport maintenance which are sent on for further disposal by third parties.

Soybean Processing segment:

• Waste during the process of equipment cleaning and replacement of filters in dust and gas treatment installations.

Cattle Farming segment:

• Waste from use of veterinary inputs and medicines derived from animal healthcare.

Data disclosure status:

The Company categorized waste as hazardous and non-hazardous according to the Ukrainian legislation. Astarta is in the process of developing the waste accounting methodology.

Considering the scale of the business of the Company and its diverse nature Astarta is still working on the improvement of data accounting in the sphere of water consumption and waste generation. The key reason for this is complexity of installation of data control and measuring devices at each point of water withdrawal, water discharge and waste generation which requires adjustments of it accounting methodology. As this work remains in progress, the Company didn't disclose data related to volumes of water consumption and waste generation.

Policies related to own workforce

Astarta's HR management principles are based on a set of internal policies approved in compliance with Ukrainian legislation requirements. Information about current and updated policies is disseminated to employees through electronic mailings and posting on the corporate web portal. All new employees are required to sign confirmation that they have read the Collective Bargaining Agreement, Social Policy, and Code of Business Ethics.

The Company builds labour relations on the principles of responsibility and fairness, provides safe working conditions, ensures voluntary employment, and does not discriminate on the basis of gender, skin colour, religion, sexual orientation or disability.

HR Policy

• Scope: Own operations
• Key content: Defines HR management principles, freedom of assembly and collective bargaining, recognition of the right of employees to join or form associations and negotiate collective agreements. Enshrines principles of social dialogue, mutual respect and equality, compliance with obligations and agreements, mutual responsibility.
• Approval/Oversight: Not specified
• Public availability: Not specified

Social Policy

• Scope: Own operations
• Key content: Regulates social programmes, employee benefits including additional leave for employees with children or caring for adults with disabilities, parental leave, childbirth leave, adoption leave, and other leave provisions.
• Approval/Oversight: Not specified
• Public availability: Not specified
• Monitoring: All new employees required to sign confirmation they have read the Social Policy

Human Rights Policy

• Scope: Own operations/Value chain
• Key content: Emphasizes commitment to respect human rights, provide safe and inclusive work environment, including: respect for human rights, community engagement, diversity and equal opportunities, safe workplace, no forced labour or child labour, fair wages and working conditions, environmental responsibility, grievance mechanism. The Company opposes harassment, oppression, discrimination, intolerance, coercion, humiliation, mobbing, bullying, violence of any type and rejects any form of forced or child labour.
• Approval/Oversight: Key senior management
• Public availability: Corporate website (publicly available and disseminated to all employees at each operating business facility)
• International standards: Universal Declaration of Human Rights; International Labour Organization Declaration on Fundamental Principles and Rights at Work; UN Guiding Principles on Business and Human Rights; Aarhus Convention; EU Directives 2000/43/EC and 2000/78/EC
• Monitoring: The Company conducts annual monitoring of the Human Rights Policy, assesses possible risks, takes on board expectations of personnel regarding human rights, develops actions, standards, regulations, sets targets and gets it approved by management (in accordance with UN Guiding Principles on Business and Human Rights and ILO Declaration)

Code of Conduct (Code of Business Ethics)

• Scope: Own operations/Value chain
• Key content: Describes approach to open dialogue, principles related to employees, human rights, respect of local traditions and law, actions under Martial Law, approach to assets use, digital innovations, safety and quality of products, business conduct and interaction with stakeholders, corporate social responsibility, actions against climate change, data protection, anticorruption. Defines basic principles of business-wide culture: openness, tolerance and respect.
• Approval/Oversight: Not specified
• Public availability: Corporate website
• International standards: UN Global Compact (company joined in 2008), UN Guiding Principles on human rights, decent work and economic growth, gender equality, reduction of inequality
• Monitoring: All new employees required to sign confirmation they have read the Code of Business Ethics. HR and Security departments as well as Compliance Committee monitor performance and effectiveness. In 2024, Compliance Committee held nine meetings and did not identify gross violations of the Code of Conduct.

Occupational Health and Safety Policy

• Scope: Own operations
• Key content: Ensures safe working conditions at workplace, safety of technological processes, machinery, equipment, and other means of production, availability of protective equipment, compliance of sanitary conditions with labour protection regulations. All employees covered by health and safety management system based on legal requirements. Certified according to ISO 45001.
• Approval/Oversight: Not specified
• Public availability: Not specified (referenced in Collective Bargaining Agreement)
• International standards: ISO 45001, ISO 9001, ISO 14001, ISO 22000
• Monitoring: Company conducts internal audits of occupational health and safety management system in accordance with Ukrainian legislation and ISO standards. Conducts internal audits and inspections according to approved programme. Non-conformities are analyzed and corrective actions developed and monitored.

Policy on Whistleblowers Protection

• Scope: Own operations
• Key content: Describes instruments for employees to report potential violations through confidential channels, rights of whistleblowers, protection from retaliation, responsibilities of management.
• Approval/Oversight: Key senior management
• Public availability: Corporate data base

Conflict of Interest Rules

• Scope: Own operations
• Key content: Defines conflict of interest, close persons, outlines prevention and declaration procedures, provides resolution methods and reporting mechanism. Protection of employees who report conflicts, limiting access to information.
• Approval/Oversight: Compliance department
• Public availability: Corporate website

Rules on Business Gifts and Business Hospitality

• Scope: Own operations
• Key content: Defines types of allowed and prohibited gifts, procedure for gifts giving and receiving, value limit for gifts, rules of business hospitality, channels for violations reporting.
• Approval/Oversight: Compliance department
• Public availability: Corporate website

Collective Bargaining Agreement

• Scope: Own operations
• Key content: Regulates labour relations and interests of employees and employers based on legislation, parties' commitments, interests of employees and employers. Guarantees freedom of organizations, trade unions and public interest organizations. Establishes safe working conditions, notification periods for planned changes (two months), dismissal procedures, alternative job offerings.
• Approval/Oversight: Not specified (negotiated with trade unions)
• Public availability: Not specified
• Monitoring: All new employees required to sign confirmation they have read the Collective Bargaining Agreement. Primary trade unions established at subsidiary levels recognized as party to collective bargaining.

Remuneration Policy

• Scope: Own operations
• Key content: Fair and transparent remuneration system, decent and competitive level of remuneration, unbiased assessment of employees' performance, decisions on promotion and bonuses based on results achieved. Minimum remuneration cannot be lower than cost-of-living set by Government.
• Approval/Oversight: Not specified
• Public availability: Referenced in text

Draft Policy on Prevention and Combating Discrimination, Sexual Exploitation, Violence and Harassment

• Scope: Own operations
• Key content: Includes specific procedures aimed at preventing sexual exploitation, violence and harassment, mitigating impacts and taking action if it occurs, principles for promoting diversity and inclusion.
• Approval/Oversight: Not specified
• Public availability: Not yet adopted (prepared in 2024, plans to adopt in 2025)

Governance and Responsibility

The HR, Corporate Partnership and Communications Department is responsible for engagement with employees, development of action programmes for managing material impacts, risks and opportunities identified during due diligence, and monitoring compliance with labour legislation.

Responsibility for equal treatment and opportunities in employment at top management level is assigned to the Director for HR, Corporate Partnership and Communications.

Whistleblowing Mechanism

The Company maintains a Trust Line operated by independent third-party LLC "Ethicontrol" which guarantees anonymity and confidentiality. Employees can report concerns through telephone, e-mail, dedicated web platform (https://astarta.ethics.help/web/uk), Incident Management Platform, and security managers of regional subsidiaries. In 2024 the Company received 692 messages through the Trust Line. Information about the Trust Line is publicly available for all employees.

Compliance

In 2024 there were no lawsuits against the Company for violation of employees' labour rights and labour legislation. There were no incidents or complaints related to discrimination and severe human rights issues recorded in 2024. No fines, penalties, or compensation for damages as result of incidents of discrimination in 2024.

Taking action on material impacts on own workforce

Active and Healthy Longevity project

Description: Large-scale initiative launched to address negative impacts on employees resulting from martial law restrictions. The project seeks to promote active aging in Ukraine, effectively mitigate workforce shortages, drive positive contributions to the national economy, and significantly enhance the well-being of older adults.

Scope: Own operations

Link to policy: Addresses material impacts on employees related to russian invasion and changes in Ukrainian legislation under martial law introduced in 2022.

Social Policy benefits programme

The Company provides the following benefits to create comfortable working conditions and stimulus:

• Financial incentives: One-time financial assistance, reimbursable financial assistance (loans)
• Medical insurance and services: Preventative medical examination, voluntary medical insurance or wellness programmes
• Working and living conditions: Assistance in improving housing conditions for key employees, professional development and training, transportation services including personal cars for key employees
• Other: Additional paid leave on wide range of occasions

Link to policy: Social Policy adopted to strengthen social protection of employees

Heat stress management measures (climate adaptation)

Description: Actions to manage heat stress impacts on vulnerable employees including:

• Limiting time in heat, effective rotation of employees
• Monitoring of labour, increasing the number of workers per task
• Providing adequate amounts of cool, portable water near the work area
• Permitting rest periods
• Training programmes on heat stress for employees

Scope: Own operations

Time horizon: Acute/annual

Financial implication: Annual value of production lost up to 1.1-1.5% due to heat impacts

Labour relations and working conditions

Description: Actions embedded in Collective Bargaining Agreement including:

• Ensuring efficient use of labour force
• Reducing unproductive time during working hours
• Maintaining appropriate conditions for employment
• Five-day working week with standard working hours no more than 40 hours per week
• Two-month advance notification of planned changes in essential working conditions or planned dismissals

Link to policy: Collective Bargaining Agreement regulating labour relations and aligning interests of employees and Company

Safe working conditions programme

Description: Commitment to ensuring:

• Safe working conditions at workplace
• Safety of technological processes, machinery, equipment
• Availability of protective equipment
• Compliance of sanitary conditions with labour protection regulations

Link to policy: Requirements set out in collective bargaining agreement

Governance and oversight

Responsibility: Management team in charge of ecological, social and governance issues responsible for developing requirements for managing and controlling impacts, risks and opportunities

Framework: Regulation on development of policies, targets, measures and metrics in the sustainability sphere, including assessment of effectiveness of actions and initiatives

Targets related to own workforce

In 2024 the Company performed due diligence to identify material impacts, risks and opportunities. As a result, there were impacts related to the Company's own workforce that were identified as material.

No targets have been established.

The martial law which was introduced in Ukraine in 2022 resulted in certain restrictions which impacts Astarta's employees and the ability of the Company to manage negative impacts. Therefore, development and application of targets will be considered in detail after the end of military hostilities and the Martial Law.

Characteristics of the undertaking's employees

Total headcount and FTE

As at 31 December 2024:

• Total employees: 6,939
• Male: 4,693 (68%)
• Female: 2,246 (32%)
• Other: 0
• Not reported: 0

As at 31 December 2023:

• Total employees: 7,233

Average headcount for 2024:

• Total: 6,938 employees
• Permanent employees: 5,028 (72%)
• Temporary employees: 1,910
• Non-guaranteed hours employees: 0

Note: The Company was unable to accurately disclose the number of full-time and part-time employees for 2024 due to war-related circumstances, including drafting into the Armed Forces of Ukraine and shortage of employees, which resulted in splitting working hours between employees of different subsidiaries with probable double counting.

Employee headcount by contract type and gender (average headcount)

Employee headcount by region/country

99% of employees are located in Ukraine. The Company maintains a nation-wide presence with around 7k employees based at production and storage facilities in seven regions:

• Poltava region
• Vinnytsia region
• Khmelnytskyi region
• Chernihiv region
• Zhytomyr region
• Ternopil region
• Kharkiv region

The Company had no employees in other countries outside Ukraine where the total number of employees was more than 50 or representing at least 10% of total number of employees.

Employee headcount by category

Employee turnover

• Employees who left in 2024: 1,608
• Turnover ratio: 23%

The turnover ratio is calculated according to the manual for employees' statistics of the State Statistics Service of Ukraine №286 dated September 28, 2005. The turnover ratio can be explained by movement of temporary employees during the year due to the seasonal nature of the business.

All Company's employees are hired through employment contracts.

Employee age distribution (as at 31 December 2024)

• Under 30 years old: 677 (10%)
• 30-50 years old: 3,596 (52%)
• Over 50 years old: 2,666 (38%)

Diversity at top management level

Top management is defined as one level below the Board of Directors - the Executive Management Team at LLC firm Astarta-Kyiv.

As of 31 December 2024:

• Total Executive Management Team members: 10
• Male: 6 (60%)
• Female: 4 (40%)
• Percentage of employees at top management level: 0.1%

Other workforce characteristics

Employees aged 60+:

• As of end of 2024: 685 persons (5% increase from 2023)

Military service impact:

• 630 Astarta employees joined the Armed Forces of Ukraine
• 66 drafted employees were killed in combat or are missing

Collective bargaining coverage:

• 99.3% of Astarta's employees were part of the collective bargaining agreement in 2024

Reporting methodology

Employee numbers are reported in head count. The information relates to Ukrainian operations, where 99% of the workforce is based. Reporting follows ESRS S1-6 requirements with some limitations due to war-related circumstances affecting accurate FTE and part-time/full-time classification in 2024.

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

Sugar Beet Supply - Third-Party Growers

In 2024, Astarta cooperated with 112 partners for sugar beet supply, including large-scale and small private farmers. These independent sugar beet growers are described as an important part of Astarta's value chain.

Sugar beet supply from third parties increased to 32% of the total (previous year—26%) to 817kt (+16% y-o-y).

Contractors - Logistics

The Company references having "a well-developed contractor base" and mentions in risk mitigation factors the "search for new contractors" in relation to logistics disruption risks.

General References

The Code of Business Ethics is stated to be accessible to "every employee, contractor, partner and other stakeholder." However, no quantitative headcount data, FTE figures, or breakdown by contractor type (agency workers, self-employed, etc.) is provided for non-employee workers in the undertaking's own workforce.

Collective bargaining coverage and social dialogue

The Company's approach to the freedom of associations and collective bargaining is based on the national legislation. Astarta's collective bargaining agreement clearly states prevention of any direct or indirect limitation of any rights, no direct or indirect privileges related to the membership in trade unions or any other association of people. The agreement also includes guarantees for freedom of association, functioning of primary trade union organisation, civic organisation.

In 2024 99.3% of Astarta's employees were part of the collective bargaining agreement.

Information on collective bargaining coverage and social dialogue

Trade union representation

Primary trade unions representing employees are established at the Company's subsidiary levels. The employer recognises all trade unions operating as a party to collective bargaining.

All workers are employed or transferred to other jobs with their consent, on own request and in compliance with the requirements of the current labour legislation of Ukraine. These norms are defined in the Collective Bargaining Agreement.

All new employees are required to sign confirmation that they have read the Collective Bargaining Agreement, Social Policy, and Code of Business Ethics.

Diversity metrics

Top management gender distribution

The Company defines the top management as one level below the Board of Directors of ASTARTA HOLDING PLC - the Executive Management Team at the main subsidiary – of LLC firm Astarta Kyiv.

As of the end of 2024, there were 10 members of the Executive Management Team:

• Male: 6 (60%)
• Female: 4 (40%)
• Other: Not disclosed

The percentage of employees at top management level in total was 0.1%.

Age band distribution of workforce

As of the end of the reporting period, the distribution of employees by age group was the following:

Overall gender distribution (year-end 2024)

Female employees represented 32% and male employees 68% of the total workforce at year-end 2024.

Adequate wages

The Company complies with the minimum remuneration guarantees established by the legislation of Ukraine according to which the minimum remuneration cannot be lower than the cost-of-living set by the Government.

No living wage benchmark is applied. The disclosure references only compliance with Ukraine's statutory minimum wage and government-set cost-of-living threshold. No coverage metrics, employee assessment percentages, or forward-looking targets are provided.

Social protection

All employees of the Company are covered by state social insurance against loss of income in case of any of the following major life-changing events:

• sickness;
• unemployment;
• injury and acquired disability during work;
• parental leave;
• retirement.

Coverage details

Type of scheme: Public (state social insurance)

Geographic scope: Ukraine (all operations)

Coverage rate: 100% of employees covered by state social insurance for all major life events listed above.

Social benefits provided by the Company

In addition to state social insurance, the Company provides supplementary social protection through its Social Policy, which regulates the following benefits:

Financial incentives:

• One-time financial assistance
• Reimbursable financial assistance (loans)

Medical insurance and services:

• Preventative medical examination
• Voluntary medical insurance or wellness programmes

Working and living conditions:

• Assistance in improving housing conditions for key employees
• Professional development and training
• Transportation services including personal cars for key employees

Other benefits:

• Additional paid leave on wide range of occasions

Persons with disabilities

The Company complies with the requirement by the Ukrainian legislation to employ people with disabilities for at least 4% of its workforce.

2024 metrics

As of 31 December 2024, the share of employees with disabilities was 7.6% of the total number of employees or 528 individuals.

Breakdown by gender:

• Male: 70% (369 employees)
• Female: 30% (159 employees)

Methodology

Employees provide information and relevant documents about their disability on a voluntary basis, at the time of employment. Subsequently, this information is entered into the internal accounting system for personnel records and payroll.

Training and skills development metrics

In 2024, 14,635 participants attended various types of training modules (one employee can attend several training modules), including:

• 8,201 men;
• 6,434 women.

Average number of training hours by gender and on average by employee in 2024

Information on employees that participated in regular performance and career development reviews (KPI) by employee category in 2024

Proportion of performance and career development reviews per employee by gender in 2024

Health and safety metrics

All employees of the Company are covered by the health and safety management system based on legal requirements.

Work-related accidents and fatalities (2024)

Coverage and methodology

All employees of the Company (100%) are covered by the health and safety management system based on legal requirements. The Company's processing assets are certified according to ISO 45001. In 2024 there were no fatalities arising from work-related injuries or work-related ill health among Company's employees and other workers performing jobs at its production sites.

The Company set targets for 2024 including: no fatalities related to production processes; Lost Time Incident Rate below 2023 level (<0.9); and 10% reduction in road accidents compared to the previous year. The rate of recordable work-related accidents reported was 0.3 in 2024.

Work-life balance metrics

Entitlement to family-related leave

Astarta respects the right of the employees to family-related leave which is secured in domestic legislation and internal policies of the Company. All employees of the Company have right to family-related leave, including:

• additional leave for employees who have children or looking after an adult with a disability from childhood of subgroup A of group I;
• parental leave until the child reaches the age of three years or six years in the case a child with special needs;
• leave related to the adoption of a child;
• childbirth leave;
• other leave in accordance with Social Policy.

100% of employees are entitled to family-related leave.

Take-up of family-related leave (2024)

In 2024, 6.1% of average number of employees exercised their right to family-related leave, of which:

• 1.5% were male
• 5.5% were female

Return-to-work rate after parental leave

Not disclosed.

Compensation metrics

Pay gap

In 2024 the gender pay gap which is defined as the difference of average pay levels between female and male employees of Astarta, expressed as percentage of the average pay level of male employees of the Company was 2%.

Remuneration ratio

In 2024 the annual total remuneration ratio of the highest paid employee in the Company to the median annual total remuneration for all employees of Astarta (excluding the highest-paid individual) was 307.

Methodology

The gender pay gap is calculated as the difference of average pay levels between female and male employees, expressed as a percentage of the average pay level of male employees.

The remuneration ratio compares the highest-paid employee to the median employee, excluding the highest-paid individual from the median calculation.

Incidents, complaints and severe human rights impacts

There were no incidents or complaints related to discrimination and severe human rights issues recorded in 2024. There were also no fines, penalties, and compensation for damages as result of incidents of discrimination in 2024.

Workers in the value chain

The Company has not registered cases of non-respect of the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises that involve value chain workers.

Affected communities

Not separately disclosed for affected communities in the S1-17 section.

Policies related to value chain workers

The Company does not have a dedicated policy to manage material impacts, risks and opportunities related to value chain workers, as the Company's impact on workers in the value chain is limited.

However, the Company has separate policies the scope of which includes the Company's stakeholders (referred to in Table 1 Annex 1 to the section General Disclosure).

Planned: Supplier Code of Conduct

Based on findings from a sustainability procurement project conducted with the EBRD and KPMG Ukraine to identify supply chain sustainability priorities, Astarta plans to develop a Supplier Code of Conduct.

Status: Under development (planned)

Trust Line Regulation

Scope:

• All individuals that use channels to raise concerns or needs

Key content:

• Protection against any retaliation for individuals raising concerns or needs

Public availability:

• Information on the Trust Line is publicly available on the Company's corporate website

Due Diligence Regulation

Governance:

• Certain members of the management team in charge of ecological, social and governance issues are responsible for developing requirements for managing and controlling impacts, risks and opportunities

Key content:

• Sets out requirements for managing and controlling impacts, risks and opportunities
• Includes assessment of effectiveness of actions and initiatives in delivering outcomes
• Helps identify which action is needed and appropriate in response to particular actual or potential negative impacts on workers in the value chain

Regulation on development of policies, targets, measures and metrics in the sustainability sphere

Key content:

• Sets out requirements for managing and controlling impacts, risks and opportunities
• Includes assessment of effectiveness of actions and initiatives in delivering outcomes

Governance and operational responsibility

Most senior roles with operational responsibility for engagement with suppliers:

• Director of strategic marketing and commerce
• Head of sugar raw materials
• Director for legal and security issues

Implementation measures

The Company ensures safe working conditions through:

• Maintaining rigorous oversight of supplier's qualifications in procurement of work of high-risk
• Enforcing strict safety compliance through contractual obligations
• Conducting mandatory on-site safety checks
• Communicating all violations for immediate corrective actions
• Rigorously monitoring sanitary and legislative labour protection requirements during new construction projects

The Company encourages initiatives to improve its positive impacts on workers in the value chain through adopted internal policies and actions taken.

Link to international standards

The excerpts reference alignment with:

• UNGPs on Business and Human Rights
• OECD guidelines
• Fundamental International Labor Organisation Conventions 1 to 8

Taking action on material impacts on value chain workers

Context and limitations

Having identified material impacts on workers in the value chain for the first time in the 2024 reporting year, the Company plans to disclose information on the resources allocated to manage these impacts in 2025 report.

The primary material negative impact is excessive overtime for value chain workers, driven by Ukraine's workforce shortage due to the russian invasion. Due to limited direct influence over supplier workforce and the constraints of ongoing military hostilities, Astarta's ability to directly mitigate this impact and take remedial actions and set targets is limited.

Planned actions

Development of a Supplier Code of Conduct

• Scope: Upstream value chain (suppliers)
• Status: Planned development based on findings from a sustainability procurement project conducted with the EBRD and KPMG Ukraine to identify supply chain sustainability priorities
• Time horizon: After the end of military hostilities, Astarta plans to actively engage with suppliers on sustainability, including material impacts management, by integrating findings from the sustainability procurement project into its internal procurement system
• Resources allocated: Not disclosed

Current actions to ensure safe working conditions

The Company maintains the following measures:

• Rigorous oversight of supplier's qualifications in procurement of work of high-risk
• Enforces strict safety compliance through contractual obligations
• Conducts mandatory on-site safety checks
• Communicates all violations for immediate corrective actions
• Rigorously monitors sanitary and legislative labour protection requirements during new construction projects

Governance arrangements

According to the Due Diligence Regulation, certain members of the management team in charge of ecological, social and governance issues are responsible for developing requirements for managing and controlling impacts, risks and opportunities. These requirements are set out in the Regulation on development of policies, targets, measures and metrics in the sustainability sphere. The Regulation also includes assessment of effectiveness of actions and initiatives in delivering outcomes.

Responsible management team members include: Head of marketing and commerce, Head of sugar raw materials and Director for legal and security issues.

Targets related to value chain workers

No quantified targets related to value chain workers are disclosed.

The Company states that having identified material impacts on workers in the value chain for the first time in the 2024 reporting year, it plans to disclose information on the resources allocated to manage these impacts in the 2025 report.

The primary material negative impact identified is excessive overtime for value chain workers, driven by Ukraine's workforce shortage due to the russian invasion. The Company acknowledges that due to limited direct influence over supplier workforce and the constraints of ongoing military hostilities, Astarta's ability to directly mitigate this impact and take remedial actions and set targets is limited.

After the end of military hostilities, Astarta plans to actively engage with suppliers on sustainability, including material impacts management, by integrating findings from the sustainability procurement project into its internal procurement system.

Policies related to affected communities

Astarta recognises its impact on the communities in which it operates. The Company does not have a separate policy which manages material impacts, risks and opportunities (IROs) related to affected communities and plans to develop it in 2025.

The Company is currently guided by the following policies with relevance to affected communities:

Human Rights Policy

Key content and principles:

• Based on international practices set out in the Universal Declaration of Human Rights and the UN Global Compact
• The Company respects human rights and does not discriminate on political, religious, ethnic, gender or other grounds
• Includes commitment to respect human rights for all stakeholders

Links to international standards:

• Universal Declaration of Human Rights
• UN Global Compact
• UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work

Public availability:

• Publicly available and disseminated to all employees at each operating business facility

Monitoring and oversight:

• The Company conducts annual monitoring of the Human Rights Policy in accordance with the UN Guiding Principles on Business and Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work
• Assesses possible risks, takes on board expectations of the personnel regarding human rights, develops actions, standards, regulations, sets targets and gets it approved by the management

Code of Corporate Ethics

Key content and principles:

• Defines the basic principles of business-wide culture: openness, tolerance and respect

Community Engagement Memorandums

Key content and principles:

• The Company's commitments to affected communities are set out in its Community Engagement Memorandums
• Part of the Corporate Social Responsibility strategy

Governance and oversight:

• Responsibility for community engagement is assigned to the directors of subsidiaries and employees in charge of social issues
• At the top management level, responsibility for community engagement is assigned to the Director for Human Resources, Corporate Partnerships and Communications Department
• The Company's Executive Management Team reviews and analyses the information received, and if necessary, takes appropriate decisions or remedial actions

Future plans: The Company plans to develop a comprehensive Corporate Social Partnership Strategy by end 2025, although the ongoing war situation in Ukraine may influence the timing of the development and implementation of this strategy.

Taking action on material impacts on affected communities

Overview

The Company manages its material impacts, risks, and opportunities related to affected communities through internal documents including:

• Stakeholder Engagement Regulation
• Community Memorandums
• Human Rights Policy
• Corporate Partnership Strategy
• Code of Ethics

The Company relies on research by external organizations to identify community needs and to develop and implement projects to mitigate negative impacts and support positive ones, alongside charitable aid upon request from local institutions.

Grant Projects for Local Economic Development

Based on recommendations from socio-economic studies by Ruban Litvinova Social Impact Advisory, the Company launched the following grant projects to stimulate development of local businesses:

"Wings" Project

• Type: Grant project
• Objective: Stimulate local business development
• Scope: Own operations / local communities
• Research basis: Ruban Litvinova Social Impact Advisory assessment

"Brave" Project

• Type: Grant project
• Objective: Stimulate local business development
• Scope: Own operations / local communities
• Research basis: Ruban Litvinova Social Impact Advisory assessment

"Course to Independence" Project

• Type: Grant project
• Objective: Stimulate local business development
• Scope: Own operations / local communities
• Research basis: Ruban Litvinova Social Impact Advisory assessment
• Validation: Further validated by Ruban Litvinova Social Impact Advisory
• Monitoring: Company utilizes specific indicators and individual project assessments to measure effectiveness

Resilience Centres

Partnership with Ministry of Social Policy of Ukraine

• Action: Joined the project to develop resilience centres across the country
• Objective: Creating the concept of Resilience and establishing Centres for Community Resilience
• Partners: Ministry of Social Policy of Ukraine
• Research basis: Informed by research from Ruban Litvinova Social Impact Advisory and Kyiv International Institute of Sociology
• Scope: National (Ukraine)
• Services: Provide psychological help and social recovery during the war
• Support type: Financial, methodological, and expert resources

War-Related Support

The Company provides:

• Needs-based projects
• Charitable aid in response to war-related hardships
• Actions aligned with community requests through research and collaboration with local authorities
• Support facilitated by cooperation memorandums and social partnership strategies

Community Support Approach

The Company addresses community needs through:

• Development of new projects with partners when targeted action is required
• Support of existing projects with financial, methodological, and expert resources
• Engagement with community leaders and humanitarian organizations to identify and address critical needs
• Both immediate relief and long-term strategic community support

Tax Contribution

2024 Tax Payments:

• Amount: UAH 2.3 billion (EUR 52 million)
• Type: Direct and indirect taxes and duties in Ukraine
• Impact: Key direct contribution to the Ukrainian economy and local budgets

Planned Actions

Corporate Social Partnership Strategy Update

• Timeline: Planned for development by end 2025
• Scope: Comprehensive strategy incorporating targets and actionable initiatives
• Note: Timing may be influenced by the ongoing war situation in Ukraine
• Objective: Foster sustainable community development considering evolving military hostilities
• Current status: Company is developing plans to update the strategy

Community Engagement Policy

• Timeline: Planned for 2025
• Current status: Currently does not have a separate Policy which manages material IRO related to affected communities
• Objective: Formalize comprehensive process for engaging with affected communities

Measurement and Monitoring

Current approach:

• Specific indicators for grant programmes like "Course to Independence"
• Individual project assessments
• Network of regional coordinators to gather feedback for charitable activities
• Annual reporting on stakeholders' engagement
• Social impact assessment of key projects including impact on particularly vulnerable groups

Planned development: More detailed metrics will be developed within the Corporate Social Partnership strategy.

Resources Allocated

Financial resources:

• EUR 52 million in taxes (2024) contributing to local budgets
• Financial support for community projects (amounts not specified)
• Charitable assistance (amounts not specified)

Non-financial resources:

• Methodological support
• Expert resources
• Regional coordinators network
• Partnerships with Ruban Litvinova Social Impact Advisory, Kyiv International Institute of Sociology, Ministry of Social Policy of Ukraine

Human resources:

• Directors of subsidiaries responsible for community engagement
• Employees in charge of social issues
• Director for Human Resources, Corporate Partnerships and Communications Department (top management level responsibility)
• Executive Management Team reviews and analyses community information

Responsibility Structure

• Operational level: Directors of subsidiaries and employees in charge of social issues
• Top management level: Director for Human Resources, Corporate Partnerships and Communications Department
• Executive level: Executive Management Team reviews, analyses and takes decisions on remedial actions

Targets related to affected communities

The Company has not established specific targets for managing material negative impacts, advancing positive impacts, and managing risks and opportunities related to affected communities, primarily due to the ongoing russian invasion of Ukraine, which has necessitated a focus on immediate humanitarian needs and delayed the update of Corporate Social Partnership Strategy which will incorporate corresponding targets.

However, this lack of formal targets is mitigated by ongoing, direct engagement with communities through signed memorandums and continuous dialogue with regional coordinators, ensuring their input shapes partnership objectives and allowing for assessment of project effectiveness via accessible impact study results.

Business conduct policies and corporate culture

Astarta has established multiple policies governing business conduct and corporate culture. These policies are designed to maintain ethical standards, prevent corruption, ensure compliance with laws and regulations, and promote a culture of integrity throughout the organization.

Code of Conduct

• Scope: Own operations and value chain
• Key content: Describes approach to open dialogue, the Company's principles related to employees, human rights, respect of local traditions and law, actions under Martial Law, approach to assets use, digital innovations, safety and quality of products, business conduct and interaction with stakeholders, corporate social responsibility, actions against climate change, data protection, anticorruption
• Public availability: Corporate website
• Monitoring: One of the key elements of Astarta's compliance culture. The Code is available on Astarta's corporate website and is accessible to every employee, contractor, partner and other stakeholder. The management contribute and promote the Company's corporate values when performing their duties, disseminate the corporate culture among employees, and follow the Company's mission and values.

Anti-corruption Policy

• Scope: Own operations/Value chain
• Oversight: Key senior management, Risk Committee
• Key content: Outlines the Company's commitment to uphold ethical business practices and combat corruption. The Company aims to create a stable and corruption-free working environment. It prohibits any form of bribery or undue influence and promotes transparency and accountability in all business dealings. The Policy also emphasizes the importance of due diligence in selecting partners and ensuring compliance with anti-corruption laws. Based on national and international best practices, defining anti-corruption principles and measures. The Policy includes a list of corruption offenses and corresponding liabilities for violations.
• Public availability: Corporate website
• International standards: UN Convention against Corruption
• Monitoring: In 2024, a working group was established to update the Policy and develop anti-corruption programmes through 2027, aligning with national and international best practices. The Company supports the principle of zero tolerance to any manifestations of corruption, fraud, money laundering and other illegal actions. The Company does not identify percentage of functions-at-risk covered by training programmes but focuses on preventing risks through raising awareness of the basic principles among employees and paying significant attention to risk management in the Company's key processes to prevent such risks.

Human Rights Policy

• Scope: Own operations/Value chain
• Oversight: Key senior management
• Key content: Emphasizes the Company's commitment to respect human rights, provide a safe and inclusive work environment, including: respect for human rights, community engagement, diversity and equal opportunities, safe workplace, no forced labour or child labour, fair wages and working conditions, environmental responsibility, grievance mechanism.
• Public availability: Corporate website
• International standards: Universal Declaration of Human Rights; International Labour Organization Declaration on Fundamental Principles and Rights at Work; UN Guiding Principles on Business and Human Rights; Aarhus Convention; EU Directives 2000/43/EC and 2000/78/EC
• Monitoring: In 2008, Astarta was one of the first companies in Ukraine to join the UN Global Compact and sign up to the UN Guiding Principles on human rights, decent work and economic growth, gender equality, and the reduction of inequality. The Company is vigilant about identification and prevention any human rights abuses in a timely manner by implementing prescribed actions and procedures.

Sanctions Policy

• Scope: Own operations/Value chain
• Oversight: Financial Director
• Key content: Sanctions risks assessment, criteria for business partners' verification, methods of verification, cooperation with partners. Developed to preserve the impeccable business reputation of the Company, to avoid cases of cooperation with counterparties for which international and/or national sanctions had been imposed, related financial, operational and other risks, as well as to ensure the continuity of business processes.
• Public availability: Corporate website
• Monitoring: The Company regularly implements various measures, on a continuing basis, to ensure that the Company complies with all applicable national and international sanctions, embargo and international frameworks related to international trade.

Conflict of Interest Rules

• Scope: Own operations
• Oversight: Compliance department
• Key content: Defines a conflict of interest, Close persons, outlines prevention and declaration procedures, and provides resolution methods and reporting mechanism. Protection of employees who report conflicts, limiting access to information.
• Public availability: Corporate website
• Monitoring: The Company's employees with senior level of responsibility submit declarations of conflicts of interest on an annual basis.

Rules on Business Gifts and Business Hospitality

• Scope: Own operations
• Oversight: Compliance department
• Key content: Defines types of allowed and prohibited gifts, procedure for gifts giving and receiving, value limit for gifts, rules of business hospitality, channels for violations reporting.
• Public availability: Corporate website

Policy on Whistleblowers Protection

• Scope: Own operations
• Oversight: Key senior management
• Key content: Describes instruments for employees to report potential violations through confidential channels, Rights of whistleblowers, protection of whistleblowers from retaliation, responsibilities of management. Aims to encourage employees to report potential violations through confidential channels, protecting them from retaliation for disclosing information they believe to be true, regardless of their motives.
• Public availability: Corporate data base
• Monitoring: Everyone who works in the Company or with Astarta can provide information about suspected fraud or other violations by telephone, post, e-mail, or the Company's website through the Trust Line. Over the last twelve months the Company received 692 messages through the Trust Line.

Animal Welfare Policy

• Scope: Own operations
• Oversight: Key senior management
• Key content: Outlines commitment to humane treatment of animals, including measures to promote their welfare, prevent cruelty, and prohibit research testing. Declares focus on achieving high standards of management in animal husbandry, provide qualified animal care, prohibit cruel slaughter methods, and ensure appropriate animal housing conditions. The Policy also emphasizes the importance of ensuring adequate space, lighting, temperature control, and fresh air. According to the Policy the Company limits the number of animals on the farm to ensure proper conditions and provides access to sufficient food and water. The policy prohibits the testing of toxic drugs and cosmetics on animals, as well as genetic engineering and cloning of animals within its products.
• International standards: IFC. Good Practice Note: Improving Animal Welfare in Livestock Operations; World Organisation for Animal Health. Terrestrial Animal Health Code
• Monitoring: Applies to dairy farms of the Company and is available at the official Astarta's webpage. Every employee and stakeholder who cooperates with the Company is encouraged to take an active part in applying the principles of humane treatment of animals.

Human Resources Policy

• Scope: Own operations
• Oversight: Key senior management
• Key content: Describes key goals and principles in relation to the Company's employees. The Policy focuses on six interconnected HR areas: organizational change management, recruitment and adaptation, motivation and rewards, evaluation, training and development, and internal communications and corporate culture. It aims to optimize processes, align authority and responsibility, speed up decision-making, eliminate duplication of functions, and optimize staffing levels. The policy also emphasizes the importance of attracting and retaining qualified specialists, providing fair and transparent remuneration, and supporting employees' development.
• Public availability: Corporate website

Social Policy

• Scope: Own operations
• Oversight: Key senior management
• Key content: Describes instruments for strengthening of social protection of employees, identifies social benefits and regulates realisation of these benefits for the employees.
• Public availability: Corporate database

Occupational Health and Safety Policy

• Scope: Own operations/Value chain
• Oversight: Key senior management
• Key content: Outlines the key principles in occupational health and safety (OHS) in the Company including OHS management system, safety at production sites, safety during business trips, accommodation for employees.
• Public availability: Corporate database
• International standards: ISO standards; IFC Performance Standards; EBRD Performance Requirements; Legislation of Ukraine

Policy on the Quality and Safety of Food and Feed Products

• Scope: Own operations/Value chain
• Oversight: Key senior management
• Key content: Outlines the Company's objectives, principles, and strategies for ensuring quality, safety, and halal compliance throughout its food chain operations, including risk assessment for food, feed, and halal products, implementation of risk mitigation measures, and enhancing customer satisfaction to deliver high-quality, safe food chain products.
• Public availability: Corporate data base
• International standards: ISO, FSSC, GMP+, GSO standards; Legislation of Ukraine

Corporate Governance Structure and Compliance Mechanisms

The Company has established a Compliance Committee consisting of at least eight members and chaired by the CEO. The Compliance Committee supports the Board of Directors in discharging its responsibility for assuring and managing compliance. Under the scope of the Compliance Committee the following areas of compliance risks are covered: (i) issues relating to the Code of Conduct, (ii) anti-bribery, (iii) fraud, (iv) conflicts of interests (v) data protection, (vi) human rights, (vii) KYC procedures and counterparties risk and (viii) Trust Line and forensic. In 2024 the Compliance Committee held 20 meetings.

The Company systematically monitors the performance of the Code of Conduct and its effectiveness. The above function lies with the HR and Security departments as well as Compliance Committee established on the main operating subsidiary level. During the reporting period the Compliance Committee held nine meetings. The Committee had not identified gross violations of the Code of Conduct.

In 2024 there were no convictions and fines for violation of anti-corruption and anti-bribery laws.

As a public company based in Cyprus with shares traded on the EU regulated market in Poland, ASTARTA HOLDING PLC adheres to both the Cyprus Stock Exchange Corporate Governance Code and the Code of Best Practice for WSE Listed Companies.

Prevention and detection of corruption and bribery

Astarta has established multiple policies and procedures to prevent and detect corruption and bribery. The Company supports the principle of zero tolerance to any manifestations of corruption, fraud, money laundering and other illegal actions.

Anti-corruption Policy

Scope: Own operations

Approval and oversight: Key senior management and Risk Committee

Key content and principles:

• Outlines the Company's commitment to uphold ethical business practices and combat corruption
• Aims to create a stable and corruption-free working environment
• Prohibits any form of bribery or undue influence
• Promotes transparency and accountability in all business dealings
• Emphasizes the importance of due diligence in selecting partners and ensuring compliance with anti-corruption laws
• Includes a list of corruption offenses and corresponding liabilities for violations
• Based on national and international best practices, defining anti-corruption principles and measures

Public availability: Corporate website

Monitoring and implementation:

• In 2024, a working group was established to update the Policy and develop anti-corruption programmes through 2027
• Analysis of internal documents to ensure no gaps that can result in corruption acts by employees
• Control of business processes to minimise corruption risks and other illegal actions
• Involvement of senior managers into prevention, identification and response to any acts of corruption
• Use of whistleblowing mechanism (Trust Line)
• In case of identification of possible employee misconduct, the Company conducts investigation according to the Instruction for Conducting an Internal Investigation
• The head of Legal and Security Department regularly reports to key management on the results of investigations
• The Company does not identify percentage of functions-at-risk covered by training programmes but focuses on preventing risks through raising awareness among employees
• Training on anti-corruption conducted by the Departments for Compliance and HR

Code of Business Ethics / Code of Conduct

Scope: Own operations/Value chain

Key content and principles:

• Describes approach to open dialogue
• Principles related to employees, human rights, respect of local traditions and law
• Actions under Martial Law
• Approach to assets use
• Digital innovations, safety and quality of products
• Business conduct and interaction with stakeholders
• Corporate social responsibility
• Actions against climate change
• Data protection
• Anti-corruption provisions, including a list of conflicts of interest, prevention and counteraction to corruption, fraud and money laundering
• Regulation of business hospitality and business gifts

Public availability: Corporate website

Monitoring and implementation:

• New employees are required to read the Code of Business Conduct
• Employees have access through the corporate website and internal resources
• Information on principles of compliance and communication channels are available in the office of the Company and its subsidiaries
• Policies communicated to all employees via corporate mail and available on the corporate website and internal data resources

Conflict of Interest Rules

Scope: Own operations

Approval and oversight: Compliance department

Key content and principles:

• Defines a conflict of interest and close persons
• Outlines prevention and declaration procedures
• Provides resolution methods and reporting mechanism
• Protection of employees who report conflicts
• Limiting access to information

Public availability: Corporate website

Monitoring and implementation:

• The Company's employees with senior level of responsibility submit declarations of conflicts of interest on an annual basis
• New employees are required to read the Conflict of Interest Management Policy

Policy on Whistleblowers Protection

Scope: Own operations

Approval and oversight: Key senior management

Key content and principles:

• Describes instruments for employees to report potential violations through confidential channels
• Rights of whistleblowers
• Protection of whistleblowers from retaliation
• Responsibilities of management
• Aims to encourage employees to report potential violations through confidential channels, protecting them from retaliation for disclosing information they believe to be true, regardless of their motives

Public availability: Corporate data base

Monitoring and implementation:

• Trust Line available as effective mechanism for tracking information regarding existing or potential violations, including anti-corruption ones

Sanctions Policy

Scope: Own operations/Value chain

Approval and oversight: Financial Director

Key content and principles:

• Sanctions risks assessment
• Criteria for business partners' verification
• Methods of verification
• Cooperation with partners

Public availability: Corporate website

Rules on Business Gifts and Hospitality (Regulation on Business Gifts and Hospitality)

Scope: Own operations

Approval and oversight: Compliance department

Key content and principles:

• Accepting and granting business reasonable gifts and business hospitality is not forbidden in the Company subject to compliance with applicable anti-corruption law
• Defines types of allowed and prohibited business gifts and hospitality

Public availability: Corporate website

Policy on Informational Security

Key content and principles:

• Outlines rules, requirements and principles in relation to informational security
• To prevent and mitigate any vulnerabilities to the information assets of the Company

Compliance Committee

Structure and function:

• Established on the main operating subsidiary level
• One of the goals is to consider issues related to compliance with business ethics
• Train employees on compliance policies and procedures
• In the event of a complaint regarding violations of the Code of Business Ethics, the issue is considered by the Compliance Committee
• Held nine meetings during the reporting period
• The Committee had not identified gross violations of the Code of Conduct

Additional measures

Due diligence:

• The Company conducts due diligence of counterparties and job applicants
• Monitors business processes aimed at minimising corruption risks, conflicts of interest and other illegal actions
• All potential business counterparties are subject to security checks for compliance with anti-corruption laws

Training and awareness:

• In 2024, the Company continued its practice of raising employee awareness regarding compliance requirements and corruption prevention through posters in common areas, internal messages and mailings, discussions, and analysis of current situations and case studies in working groups and committee meetings
• Security department performs explanatory work for employees regarding relevant anti-corruption laws and internal regulations
• Employees encouraged to contact the Compliance team if they need additional clarification or instructions

Reporting:

• Any person may report of any known or suspected violation either personally to the management, or anonymously through the Trust Line

Political neutrality:

• The Company is not engaged in politics or makes payments to political parties or to the funds/entities that promote any party's political interests
• When dealing with government or state agencies, the Company is encouraged to promote and defend its legitimate commercial objectives through industry associations
• The Company does not participate in charitable and sponsorship projects with the direct or indirect purpose to influence decisions of government bodies

Performance in 2024

In 2024 there were no convictions and fines for violation of anti-corruption and anti-bribery laws.

Incidents of corruption or bribery

Confirmed incidents

In 2024, there were no confirmed incidents of corruption or bribery recorded by the Company.

Convictions and fines

In 2024 there were no convictions and fines for violation of anti-corruption and anti-bribery laws.

Speak-up mechanisms and investigation procedures

The Company maintains a Trust Line whistleblowing mechanism operated by an independent third-party LLC "Ethicontrol", which guarantees complete anonymity and fairness in relation to concerns registration. The Trust Line is accessible through telephone, e-mail, and a dedicated web platform at https://astarta.ethics.help/web/uk.

According to the Rules of the Trust Line, all appeals are received by the Trust Line Operator, which registers them in the system. After registration, the Trust Line Operator sends the appeal to the administrator, who conducts an initial analysis and selects the authorised employee(s) for further consideration and verification of the facts contained in the appeal.

The authorised employee informs the applicant of the results of the review no later than within thirty (30) calendar days from the date of registration of the appeal. In the event of an internal audit or internal investigation, the deadline for informing the applicant on the results of the review shall be extended for the duration of such audit or investigation.

The Company guarantees anonymity and confidentiality of all reported concerns received through the Trust Line. All individuals that use channels to raise concerns are protected against any retaliation according to the Company's Trust Line Regulation.

Over the last twelve months, the Company received 692 messages through the Trust Line.

Anti-corruption awareness and training

In 2024, the Company continued its practice of raising employee awareness regarding compliance requirements and corruption prevention. Well-established methods such as posters in common areas, internal messages and mailings, discussions, and analysis of current situations and case studies in working groups and committee meetings proved effective.

A working group was established in 2024 to update the Anti-corruption Policy and develop anti-corruption programmes through 2027, aligning with national and international best practices.

Compliance Committee

Astarta established a Compliance Committee consisting of at least eight members and chaired by the CEO. The Committee held 20 meetings in 2024 and covers areas including: (i) Code of Conduct issues, (ii) anti-bribery, (iii) fraud, (iv) conflicts of interests, (v) data protection, (vi) human rights, (vii) KYC procedures and counterparties risk, and (viii) Trust Line and forensic matters.