ASTM

Board of Directors

Chairperson: Angelino Alfano (1)(2) Vice Chairman: Franco Moscetti (1) Chief Executive Officer: Umberto Tosoni

Directors: Caterina Bima (1)(3)(4), Beniamino Gavio, Stefano Mion (2), Luca Pecchio, Andrea Giovanni Francesco Pellegrini (2)(3), Federica Vasquez (3)

Board Committees:

• (1) Member of the "Remuneration Committee"
• (2) Member of the "Audit and Risk Committee"
• (3) Member of the "Sustainability Committee"
• (4) Member of the "Oversight Committee"

Powers of Company Officers: The Chairperson exercises the powers envisaged by article 27 of the Company's Articles of Association. The Vice-Chairman was granted powers to be exercised in case of absence or impediment of the Chairman. The Chief Executive Officer was appointed by means of a Board resolution dated 23 April 2024 and exercises the management powers granted to them by law and the Articles of Association.

Term of Office: The Board of Directors were appointed for three financial years by the Ordinary Shareholders' Meeting on 23 April 2024 and its term of office will expire with the Shareholders' Meeting that will be held for the approval of the 2026 Financial Statements.

Integration of sustainability-related performance in incentive schemes

Roles covered

The remuneration policy covers:

• Executive directors
• Top management

Incentive scheme structure

As of 2019, the remuneration policy includes:

• Annual variable incentive schemes (MBO - Management By Objectives)
• Long-Term Incentives (LTIs)

Sustainability KPIs tied to remuneration

The schemes are based on the achievement of sustainability objectives related to:

• Environmental sphere (including emission reduction targets)
• Social sphere
• Governance sphere

Weighting

Sustainability objectives are weighted at 20% of the total variable remuneration.

Governance oversight

The Remuneration Committee assists the Board of Directors by:

• Preparing the remuneration policy
• Monitoring the actual application of the policy
• Checking that performance targets — including those on sustainability — are actually achieved
• Periodically assessing the adequacy and overall consistency of the policy for the remuneration of directors

The Sustainability Committee supports the Remuneration Committee by identifying sustainability targets consistent with the Group's strategy for incorporation into the remuneration policy.

Approach

This structured approach to remuneration ensures that sustainability and environmental responsibility are at the core of the performance evaluation and compensation for ASTM's top management, guiding the company towards its climate goals.

ASTM, through the Group companies, is mainly active in the management of motorway networks under concession and in the sectors of design and construction of major infrastructure works ("EPC"), as well as technology applied to transport mobility.

In particular, through its subsidiaries and associated companies operating in the motorway sector in Italy and Brazil (EcoRodovias, Brazilian holding listed on the Novo Mercado BOVESPA), the ASTM Group is one of the main international players in the motorway concession management sector.

In the EPC sector, the ASTM Group – through the Itinera Group and SINA – carries out the planning and construction of major transport infrastructure works (roads, motorways, railways, metros, bridges, viaducts and tunnels), as well as civil and industrial construction works (hospitals, shopping centres and airports). Note that the Itinera Group operates in the United States through the subsidiary Halmar International, one of the main EPC companies in the northeastern area of the USA.

In the technology sector, the ASTM Group operates through Sinelec, which carries out design, creation and management of advanced infrastructural network monitoring systems, info-mobility and toll collection systems, as well as the design and creation of integrated systems and solutions in the EPC context, with particular attention on hospital and university construction, as well as road, motorway and airport infrastructure.

Business Model - One Company Approach: Within the ASTM Group, the three business segments operate in synergy with a One Company approach, where experience and expertise gained for the EPC and technology sectors in a competitive market are also harnessed internally to extract value from an integrated approach to business. In particular, Group companies working in the EPC and technology sectors operate jointly with the concession holder companies for tender activity, design, construction and management of infrastructure.

Geographic Presence:

• Italy: Over 1,100 km of motorway networks in north-western Italy
• Brazil: 4,700 km through EcoRodovias subsidiaries
• UK: 85 km
• USA: Operations through ASTM North America and Halmar International

Value Creation: Overall, in 2024 the economic contribution generated in the local area is estimated at around EUR 13 billion with an employment effect along the entire value chain estimated at over 180 thousand workers.

Interests and views of stakeholders

ASTM Group's main stakeholders fall into different categories, each with specific expectations and requirements which are taken into consideration when defining the Group's strategy. The main stakeholders, i.e. all those who participate in or are affected by the Group's activities throughout the value chains, are listed in the table below. A dedicated section on stakeholder engagement has been created on ASTM website, illustrating the expectations of each type of stakeholder and methods for engaging them, as shown in the table below. By establishing an ongoing dialogue with its stakeholders and maintaining it over time, ASTM is able to identify the most important sustainability matters, to forge a relationship of trust on ESG matters of shared interest, and to evaluate how best to integrate them into its sustainability strategy, industrial activities and impact, risk and opportunity management plans throughout the supply chains. The interests and perspectives of stakeholders are brought to the attention of the administrative, management and supervisory bodies, and specifically the Board of Directors, the Committees and the Board of Statutory Auditors, at the appropriate times, in order to guide future action plans.

Identified stakeholder groups and engagement methods

Integration into strategy and decision-making

The results of stakeholder engagement activities are analysed by the competent departments to assess whether, in light of the interests and views gathered, there is a need to implement appropriate actions from a strategic, operational or management perspective. More details on the processes of engaging specific stakeholder categories and the specific initiatives implemented are detailed in the following chapters.

Complementing the processes of stakeholder engagement and of assessing impacts, risks and opportunities with regard to sustainability issues, ASTM adopted the Human Rights Framework in 2024, to implement due diligence based on the risk of non-compliance with human rights in its activities and throughout its value chains. Based on the findings of this process, an action plan is prepared with measures to prevent, mitigate and eradicate the identified impacts and risks.

As part of the recent update to the 2022-2026 Sustainability Plan, among other factors, the above-mentioned aspects were taken into account in defining the Group's sustainability guidelines and goals.

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

List of Material IROs

The complete list of material IROs identified through ASTM's double materiality analysis is presented in tabular format covering the following ESRS topics:

E1 – Climate change

E2 – Pollution

E4 – Biodiversity and ecosystems

E5 – Circular economy

Innovation and Mobility

S1 – Own workforce

S2 – Workers in the value chain

S3 – Affected communities

S4 – Consumers and end-users

G1 – Business conduct

Interaction with Strategy and Business Model

The results of the double materiality analysis revealed issues of Governance and Climate Change to be the most material for ASTM Group, followed by the sector-specific area of Innovation and Sustainable Mobility, and by issues related to its own workforce. Compared to the analysis conducted in the previous financial year, issues related to water use were not found to be material, while issues related to climate change issues gained greater materiality, both in terms of their impacts and of their risks and opportunities.

The positive material impacts are the result of the strategy implemented by the Group for several years now, and of the implementation of the Sustainability Plan. Meanwhile, the negative material impacts are closely related to the Group's intrinsic activities, and to the construction of infrastructure in particular.

The results of the double materiality analysis are taken into account in strategic planning, including for the definition and implementation of the most appropriate and effective actions to manage impacts and mitigate risks, as well as to exploit the opportunities that emerge.

Sustainability Plan Integration

As explained in the paragraph on "Strategy, business model and value chains", the Group's 2022-2026 Sustainability Plan covers all ESG areas and specifically, since the update in 2024, all sustainability issues found to be material following the double materiality analysis. At the same time, the implementation of the Plan during 2024 actually caused several of the impacts which turned out to be material, highlighting the close connection between ASTM's strategy and business model and sustainability issues.

The strategic guidelines identified for each area are as follows:

• Environment: Greenhouse gases, Circular economy and responsible use of resources, Biodiversity and ecosystem services, Pollution
• Innovation and Mobility: Innovation and technological evolution, Sustainable Mobility
• Social: Health and Safety, People care, Supply chain, Community and value for the territory
• Governance: Ethics and Integrity, Human Rights

Climate Change – Specific Interaction

Scenario Analysis

The scenarios used for the analysis of risks and opportunities reflect various future possibilities. The technological and economic changes needed to mitigate climate change were analysed through transition scenarios, while the climate's reaction to changes in concentrations of greenhouse gases (GHG) was considered through the physical scenarios. Different scenarios, both physical and transition, were selected; specifically RCP 8.5, IEA 2DS and IEA B2DS, considering medium- and long-term time horizons, and up to 2050 for the transition scenarios, consistent with the planning of interventions affecting motorway infrastructure under concession.

Physical Effects

The physical effects which are most likely to impact the Group's business over the long term in the geographic areas of greatest interest to it (Europe and Latin America):

• increase in the damages associated with floods and landslides, river overflows and coastal erosion
• increase in water scarcity and consequent restrictions on water use
• increase in the damages caused by extreme heat and forest fires

Climate Transition Plan

In 2021, ASTM became the first European motorway operator to set science-based targets for the reduction of emissions by 2030 validated by the Science-Based Targets initiative (SBTi). These targets have been integrated into the Group's financial strategy through the publication of the first Sustainability-Linked Financing Framework. In 2024, ASTM prepared a Climate Transition Plan based on the guidelines drawn up by the CDP (formerly the Climate Disclosure Project), as well as on the reporting requirements of the CSRD, and in line with the Group's Business Plan.

Emission Reduction Targets

Financial Resources

The financial resources to support the implementation of the Climate Transition Plan with regard to the reduction of Scopes 1 and 2 are mainly attributable to the concessions sector and, therefore, are included in the Economic-Financial Plans of the concessionaire companies with particular reference to energy efficiency solutions (e.g. the changeover to LED lighting), the installation of photovoltaic panels, and Intelligent Transport System (ITS) solutions, totalling EUR 44.6 million (EUR 40.3 million in 2023).

Biodiversity and Ecosystems – Specific Interaction

The planning of new works takes into account an analysis of their potential negative impacts on biodiversity and ecosystems, integrating appropriate activities for the mitigation and reduction of these potential negative effects into their design and implementation.

ASTM has adopted a target for contribution to the preservation of biodiversity in new projects:

The Group's main sites which overlap with biodiversity areas consist of the road stretches operated by the concessionaire companies. Of these, 17 are located in or near protected areas or major biodiversity areas, representing a total area of 1,780.2 hectares. More specifically, 11 are in Italy, for a total area of 567.6 hectares, with 6 in Brazil for a total area of 1,212.6 hectares.

Resilience

In order to ensure business continuity, the Board of Directors of each Group company defines the nature and level of risk (Risk Appetite Framework) compatible with the company's strategic objectives and periodically reviews the main risks affecting the organisation, as part of its responsibilities within the Internal Audit and Risk Management System. Climate change and its effects on economic activities represent one of the main risk factors for the continued operation and resilience of the infrastructure managed by Group companies. With particular reference to the most vulnerable areas and works, therefore, infrastructures are constantly monitored in order to guarantee their safety and resilience for the circulation of motorway traffic, in accordance with the regulations in force.

The Group's motorway companies are continuing their investment plans for the resilience of the infrastructure and the safety of motorway users, including through the use of new technologies. In terms of the resilience of the strategy and the business model, it is worth noting its over 30 years of active participation in the research programmes of the World Road Association (PIARC), and its 15-year presidency of the National Technical Committee which oversees climate change, mitigation and adaptation policies and infrastructure resilience.

Challenges

Of the main future challenges which the Group must face in implementing its ESG strategy:

• the involvement of supply chain players in the ecological transition pathway is particularly noteworthy, specifically with reference to the targets to reduce Scope 3 emissions from goods and services purchased
• the Group must take into account the technological innovations and the regulatory changes that characterise the sectors in which it operates
• as part of the Group's path of international growth, the promotion of high standards of sustainability even in countries outside of Europe, such as the United States and Brazil, represents a further challenge for the implementation of the Group's ESG strategy

Economic Impact

The economic impact generated in 2024 was around EUR 13 billion. Of this figure, EUR 5.2 billion represent a direct effect, EUR 3.5 billion are an indirect effect occurring along the value chains, and EUR 4.2 billion derive from the induced effect generated by the spending of those employed. The employment effect along the value chains is estimated at over 180 thousand workers.

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

Overview of double materiality process

ASTM conducts a double materiality analysis process coordinated by the Sustainability Unit with the support of the Risk Management Unit. The process assesses climate-related risks and opportunities on an annual basis as an integral part of the Risk Management model and the double materiality process.

Governance and oversight

The Sustainability Committee examines the content of the Consolidated Sustainability Statement, including the double materiality analysis, on an annual basis before it is submitted to the Board of Directors for approval.

The Control and Risk Committee, consisting of three directors, annually examines the content of the Consolidated Sustainability Statement, including the double materiality analysis, which is relevant for the purposes of the Internal Control and Risk Management System.

The Board of Statutory Auditors reports on the Consolidated Sustainability Statement in its annual report to the Shareholders' Meeting.

Supporting units

The following units play vital roles in supporting the activities of the Board of Directors, the Committees and the Board of Statutory Auditors:

• Sustainability Unit: Reports directly to the CEO, contributes to the definition of the sustainability strategy by proposing areas and projects for the improvement of the sustainability model. It coordinates the double materiality analysis process with the support of the Risk Management Unit, and the process of drafting the Consolidated Sustainability Statement.

• Risk Management Unit: Supports the Sustainability Unit in coordinating the double materiality analysis process.

• Second-Level Control Unit (ICSRS Unit): In charge of managing the Internal Control over Sustainability Reporting System. Coordinates the activities of defining and monitoring the ICSRS, identifying any deficiencies and coordinating the determination of corrective actions.

• Legal, Corporate Affairs and Compliance Unit: Submits the Consolidated Sustainability Statement to the Board of Directors for approval.

• Communication and Public Affairs Unit: Responsible for publishing the Consolidated Sustainability Statement on the company website.

Frequency of review

Climate-related risks and opportunities are assessed on an annual basis. The Sustainability Committee examines the double materiality analysis on an annual basis before submission to the Board of Directors for approval.

Training and awareness

ASTM is committed to raising awareness of sustainability matters among the members of its Board of Directors, including environmental issues related to climate change. The Board of Directors is involved in specific induction sessions which include a focus on regulatory updates regarding sustainability and an examination of the main impacts on Group activities and on environmental issues (e.g. SBTi and the Climate Transition Plan).

The Sustainability Committee and the Sustainability Unit also support the Board of Directors and the other Committees in understanding and incorporating sustainability matters, including with the support of subject-matter experts where deemed appropriate.

Integration with climate strategy

The double materiality process is integrated with ASTM's climate strategy, which includes:

• Defining a long-term climate strategy in line with the reduction trajectories of the Paris Agreement and consistent with financial planning, including the production of a decarbonisation roadmap which encompasses reduction actions, green procurement policies and supply chain involvement

• Assessing climate-related risks and opportunities on an annual basis as an integral part of the Risk Management model and the double materiality process

Transition plan for climate change mitigation

Overview

In 2021, ASTM became the first European motorway operator – and the largest in terms of km managed – to set science-based emission reduction targets for 2030 validated by the Science-Based Targets initiative (SBTi), in line with the reduction trajectories set out in the Paris Agreement. These commitments have been integrated into the Group's financial strategy through the publication of the first Sustainability Linked Financing Framework, which links environmental results to specific financial indicators. At 31 December 2024, approximately 68% of the Group's consolidated gross financial debt was linked to ESG targets, accruing a cumulative benefit in terms of lower financial expenses currently quantifiable at around EUR 4.1 million.

In 2024, ASTM prepared a Climate Transition Plan based on the guidelines drawn up by the CDP (formerly the Climate Disclosure Project), as well as on the reporting requirements of the CSRD, and in line with the Group's Business Plan.

Scope of the plan

The Climate Transition Plan covers all business units of the ASTM Group. The emission reduction targets have been set in accordance with the principle of financial control, taking all emissions of the joint operations into account, regardless of the stake held.

Target years and alignment

Target year for net zero / carbon neutral: 2050

Alignment with Paris Agreement / SBTi validation:

• Targets validated by the Science-Based Targets initiative (SBTi)
• In line with the reduction trajectories set out in the Paris Agreement
• Long-term carbon footprint reduction pathway involves ambitious reductions without relying on offsets
• Offsets will only be evaluated to neutralise residual emissions (up to a maximum of 10% of the baseline) to complete the Net Zero pathway

GHG emission reduction targets

Initial targets (2021 Sustainability-Linked Financing Framework):

• KPI 1: Reduction of greenhouse gas emissions classified as Scope 1 and 2 (market-based) by 25% by 2030, against the benchmark of 2020
• KPI 2: Reduction of greenhouse gas emissions classified as Scope 3 by 13% by 2030, relative to goods and services acquired, against the benchmark of 2020

Updated targets (May 2023 Sustainability-Linked Financing Framework):

• KPI 1: Reduction of greenhouse gas emissions classified as Scope 1 and 2 (market-based) by 54% by 2030, against the benchmark of 2020
• KPI 2: Reduction of greenhouse gas emissions classified as Scope 3 by 11.1% by 2030, relative to goods and services acquired, against the benchmark of 2021
• KPI 3: Installation of electric vehicle charging stations in 100% of the service areas present along the motorway networks managed by the ASTM Group in Italy and Brazil, by 2026

Intermediate targets:

• For KPI 1: intermediate targets set for 2024, 2026, 2027, and 2028
• For KPI 2: intermediate target set for 2027 and 2028
• Note: The intermediate KPI 1 target for 2024 was achieved

Long-term targets to 2050:

Key decarbonization levers and initiatives

For Scope 1 and 2 emissions reduction:

1. Switching from fossil fuels to low environmental impact fuels:

   • Use of biodiesel where possible
   • Use of XTL diesel (HVO - Hydrotreated Vegetable Oil) in Italy, Europe and Brazil
   • Over 40% of vehicles authorized in Italy used HVO in 2024
   • Target: 100% of light vehicles and 70% of heavy vehicles by 2030
   • EcoRodovias Group policy favoring ethanol use in light vehicle fleet
   • Evaluation of biodiesel replacement through partnerships with biodiesel distributors and producers

2. Electrification of company vehicles:

   • Gradual replacement of company fleet and construction site vehicles with lower environmental impact models
   • EcoRodovias plans to replace some light haulage trucks with electric vehicles by 2025

3. Energy efficiency plan:

   • Modernization of lighting systems in motorway areas (tunnels, car parks, junctions, toll stations) using LED technology
   • Replacement essentially complete for most Italian concessionaires, expected completion on all routes by 2025
   • Replacement of oil and gas boilers to improve building energy efficiency
   • Optimization of heating and cooling temperatures in tech rooms and buildings
   • Installation of meters to measure gas consumption
   • Plan to replace conventional boilers with condensing boilers at Itinera's main locations in 2025
   • EcoRodovias plan to transition air-conditioning units using high-impact refrigerant gases to more environmentally-friendly units by 2030
   • ISO 50001:2018 certified energy management system implemented by Itinera and Sinelec

4. Self-generation and purchase of renewable energy:

   • Installation of photovoltaic plants completed for Italian concessionaires in 2023
   • Design finalized for new renewable energy production plants on A4 Torino-Milano section managed by SATAP
   • EcoRodovias continued implementation of photovoltaic plant installation plan, focusing on toll areas
   • Halmar photovoltaic plants at headquarters and warehouse, scheduled completion by 2026
   • Purchase of certified renewable energy (Certificates of Origin)

5. Dynamic management systems:

   • Reduce energy consumed by infrastructures and offices for lighting and HVAC to a minimum

6. Innovative monitoring technologies:

   • Monitoring of motorway infrastructure using drones and sensors to reduce kilometres travelled on the network

7. Research and innovation:

   • Development of energy-recovery technologies

For Scope 3 emissions reduction (goods and services purchased):

1. Process efficiency:

   • Increasing efficiency of processes to reduce demand for goods and services

2. Green procurement policies:

   • Favour sustainable suppliers and products/services with low carbon emissions
   • Focus on technological innovation in materials
   • Specific measures for asphalt production:
     • ~20% reduction in materials for asphalt production
     • Use of materials that can be processed at lower temperatures
     • Use of machinery complying with maximum age limits
     • Use of slag to avoid waste and replace greenhouse gas-emitting materials

3. Supplier engagement:

   • Increase awareness of environmental issues
   • Promote sustainable transition practices
   • Collection of primary data on suppliers through dedicated IT platform
   • Promotion of EPD (Environmental Product Declaration) or LCA (Life Cycle Assessment) product certifications

External decarbonization factors considered:

• Technology innovation in materials
• Energy mixes with lower carbon emissions
• Efficiency trends and electrification for all business sectors used for procurement

CapEx and investment commitments

Energy efficiency investments (2024):

• EUR 7.2 million for increasing energy efficiency of lighting systems in motorway areas (EUR 2.8 million in 2023)
• Aligns with EU Taxonomy activity CCM 7.3 "Installation, maintenance and repair of energy efficiency equipment"

Renewable energy investments (2024):

• EUR 5.5 million for installation of alternative energy production plants (EUR 3.1 million in 2023)
• Aligns with EU Taxonomy activity CCM 4.1 "Electricity generation using solar photovoltaic technology"

Total eligible mitigation CapEx (2024):

• EUR 46 million (includes activities not in Transition Plan but contributing to climate change mitigation)
• EUR 44.6 million specifically for Scope 1 & 2 reduction (EUR 40.3 million in 2023)

These investments contribute to CapEx KPIs pursuant to EU Taxonomy and are included in "Motorway sector – planning and construction activities (IFRIC 12)" as reported in Note 1 – Intangible assets, section 1.c) Concessions – non-compensated revertible assets of the Consolidated Financial Statements.

Financial resources mainly attributable to concessions sector and included in Economic-Financial Plans of concessionaire companies, particularly for:

• Energy efficiency solutions (e.g. changeover to LED lighting)
• Installation of photovoltaic panels
• Intelligent Transport System (ITS) solutions

Locked-in emissions and stranded assets

A specific qualitative assessment was conducted on the "locked-in" emissions of ASTM Group's key assets, which include:

• Offices
• Vehicle fleet
• Motorway infrastructure

Evolutions in the impact of assets were estimated for Scopes 1 and 2 over the operational life of key assets (active or planned) from the baseline year to 2030 and 2050. Evolution dictated by:

• Upward trends due to business growth (e.g. renewal of EPC portfolio, investments in modernisation of infrastructure under concession)
• Downward trends from detailed decarbonisation plan for Scope 1 and 2 emissions

Use of carbon credits and removals

Carbon credits and offsets will only be evaluated to neutralise residual emissions, up to a maximum of 10% of the baseline, to complete the Net Zero pathway. The long-term carbon footprint reduction pathway does not rely on offsets.

Integration with financial strategy

Sustainability-Linked Financing Framework:

• First published in 2021
• Updated in May 2023 to align with:
  • Changes in Group corporate structure
  • Latest version of Sustainability-Linked Bond Principles (ICMA)
  • Sustainability-Linked Loan Principles (LMA)

Sustainability-Linked Bonds and Loans:

• At 31 December 2024: ~68% of Group's consolidated gross financial liabilities (net of EcoRodovias Group debt) linked to sustainability targets
  • 38% in SLB format
  • 26% in SLL format
  • 4% in Green & Social format

Three tranches of Sustainability-Linked Bonds issued 18 November 2021 (total EUR 3 billion):

• "2021-2026 bond": EUR 750 million, maturity 25 November 2026, coupon 1.00%
• "2021-2030 bond": EUR 1,250 million, maturity 25 January 2030, coupon 1.50%
• "2021-2033 bond": EUR 1,000 million, maturity 25 November 2033, coupon 2.375%

First bond issue in Europe by an "Infrastructure" issuer incorporating sustainability targets. Step-up mechanisms for coupons in event of failure to achieve KPI sustainability targets at respective maturities.

Second Party Opinion:

• Moody's Investors Service assigned Sustainability Quality Score of SQS2 (Very Good)
• Positions ASTM as leading company in infrastructure sector

Financial benefits:

• Cumulative benefit in terms of lower financial expenses currently quantifiable at around EUR 4.1 million

Governance and accountability

The Climate Transition Plan is integrated into the governance structure:

• Board of Directors periodically receives reports on environmental matters including metrics, targets and action plans
• Sustainability Committee provides proposals and consulting to Board on sustainability matters
• Climate strategy activities include:
  • Setting science-based targets
  • Incorporating targets into financial strategy
  • Publishing Sustainability-Linked Financing Frameworks
  • Issuing Sustainability-Linked Bonds and Loans
  • Defining long-term climate strategy consistent with financial planning
  • Annual assessment of climate-related risks and opportunities

Remuneration integration:

• Since 2019, remuneration policy for executive directors and top management includes annual variable incentive schemes (MBO) and Long-Term Incentives (LTI)
• Based on achievement of sustainability objectives including emission reduction targets
• Weighted at 20% of total variable remuneration

Scenario analysis and assumptions

Climate scenario analysis conducted using:

• RCP 8.5: High greenhouse gas emissions scenario ("business as usual")
• IEA 2DS: 2°C Scenario - rapid decarbonisation to limit temperature increase to 2°C
• IEA B2DS: Beyond 2°C Scenario - limit temperature increase to 1.75°C, energy sector carbon neutrality by 2060

Scenario analysis results influenced:

• Decisions on when and how to design new works
• Extraordinary maintenance of existing infrastructure
• Identification of acute and chronic physical risks
• Appropriate adaptation interventions

External factors and uncertainties:

• Structure includes elements related to external factors beyond Group's control:
  • Adoption of decarbonisation plans by suppliers
  • Long-term assumptions to be revisited based on future business, technological, and regulatory developments
  • Approval of concessionaire companies' Economic-Financial Plans by Granting Body

Just transition considerations

No negative impacts on personnel resulting from the Transition Plan identified. Positive impacts include:

• Training on sustainability matters (280,000 hours delivered to employees in 2024)
• Development of professional, technical, engineering and IT skills
• First Group Sustainability Workshop in 2024 involving 150+ managers
• E-learning training on sustainability issues for 1,800+ Group employees

Policies related to climate change mitigation and adaptation

ASTM has disclosed several policy frameworks and strategic documents relevant to climate change mitigation and adaptation, though these are described primarily as strategic plans and frameworks rather than traditional standalone policies.

Climate Transition Plan

Key content: The Climate Transition Plan was prepared in 2024 based on CDP guidelines and CSRD reporting requirements, aligned with the Group's Business Plan. It establishes a long-term carbon footprint reduction pathway with ambitious reductions in Scope 1, Scope 2 (market-based) and Scope 3 emissions from goods and services purchased by 2050, without relying on offsets.

Targets:

• Scope 1 & 2 (market-based) emissions reduction: -54% by 2030, -90% by 2050 (baseline 2020: 145 ktCO2eq)
• Scope 3 emissions from goods and services purchased (category 1): -11% by 2030 (baseline 2021: 2,261 ktCO2eq)
• Scope 3 intensity reduction: -97% by 2050

Scope: Own operations and upstream value chains; all Business Units

Key initiatives for Scope 1 & 2 reduction:

• Switching from fossil fuels to low environmental impact fuels (e.g. biodiesel)
• Gradual replacement of vehicles with environmentally friendly models (e.g. electric cars)
• Plan to replace bulbs with LED technology
• Dynamic management systems to reduce energy consumption
• Promotion of energy efficiency technologies
• Research and innovation for energy-recovery technologies
• Self-generation and purchase of certified renewable energy
• Monitoring of motorway infrastructure using innovative technologies

Key initiatives for Scope 3 reduction:

• Increasing process efficiency to reduce demand for goods and services
• Green procurement policies favoring sustainable suppliers and low-carbon products/services
• Engaging suppliers to increase environmental awareness
• Collection of primary supplier data through dedicated IT platform
• EPD (Environmental Product Declaration) or LCA (Life Cycle Assessment) product certifications

Governance: The Climate Transition Plan is overseen by the Board of Directors, with support from the Sustainability Committee and Sustainability Unit. The Board is involved in specific induction sessions on regulatory updates regarding sustainability and environmental issues including SBTi and the Climate Transition Plan.

Monitoring: ASTM monitors performance annually against emissions reduction targets validated by SBTi and integrated into the Climate Transition Plan roadmap. Results are illustrated through key performance indicators.

Link to standards: The Plan incorporates science-based targets validated by the Science-Based Targets initiative (SBTi), aligned with the Paris Agreement reduction trajectories.

Financial resources: Financial resources to support implementation regarding Scope 1 and 2 reductions are mainly attributable to the concessions sector, included in Economic-Financial Plans totaling EUR 44.6 million (EUR 40.3 million in 2023). These investments contribute to CapEx KPIs pursuant to EU Taxonomy activities CCM 7.3, CCM 4.1, and CCM 6.15.

Sustainability-Linked Financing Framework

Key content: Published to integrate financial strategy with meaningful and ambitious sustainability targets. Updated in May 2023 to include new SBTi-validated emissions reduction targets and targets for e-vehicle charging station installation.

Governance: The Framework was structured to align with relevant market principles and contribute to achieving UN Sustainable Development Goals.

Link to standards: Alignment with relevant market principles confirmed by independent external entity and independent third party (May 2023).

Environmental Policy

Key content: The Environmental Policy is referenced as governing climate-related matters, as indicated in the content index where ESRS E1-2 (Policies related to climate change mitigation and adaptation) points to "The Environmental Policy, page 90-91."

Note: While the Environmental Policy is referenced multiple times in the document index, the specific content of this policy is not included in the provided excerpts.

Energy Management

Governance: A Group Energy Manager was appointed. Itinera and Sinelec implemented an ISO 50001:2018 certified energy management system.

Climate Change Adaptation

The document references "The Group's commitment to climate change adaptation" (pages 116-118) as part of the policy framework, though specific adaptation policy content is not detailed in the excerpts provided.

Integration with Remuneration

Since 2019, the remuneration policy for executive directors and top management includes sustainability objectives related to environmental, social and governance spheres, including emission reduction targets, weighted at 20% of total variable remuneration. The Remuneration Committee monitors achievement of performance targets including sustainability objectives.

Actions and resources in relation to climate change policies

Climate Strategy and Financing Framework

Sustainability-Linked Financing Framework (SLFF)

• Action: Published first SLFF in 2021, updated in May 2023
• Scope: Own operations and value chain
• Time horizon: Medium and long term
• Description: Framework setting out emissions reduction targets validated by SBTi, linking financial strategy to sustainability targets. The 2023 update included new SBTi-validated emissions reduction targets and a target related to installation of e-vehicle charging stations
• Link to policy: Aligned with relevant market principles and contributes to UN Sustainable Development Goals. Alignment confirmed by independent third party
• Expected outcomes: Achievement of SBTi-validated emissions reduction targets

Climate Transition Plan

• Action: Development and integration of Climate Transition Plan
• Scope: Group-wide
• Description: Integrated climate-related targets into strategy through comprehensive transition plan
• Link to policy: Further details referenced in "Climate Transition Plan" paragraph (pages 104-106)

Climate Change Adaptation

Infrastructure Resilience Measures

• Action: Implementation of adaptation interventions based on scenario analysis results
• Scope: Own operations (infrastructure assets)
• Description: Interventions including:
  • Strengthening infrastructure foundations
  • Increasing frequency of routine maintenance
  • Ground and slope stability measures
• Link to policy: Informed by scenario analyses contributing to formalization of Group's climate strategy
• Expected outcomes: Enhanced resilience to physical climate risks

Biodiversity and Ecosystems

Biodiversity Risk Management and Mitigation

• Action: Implementation of mitigation hierarchy framework
• Scope: Own operations and project sites (concessions and construction sectors)
• Description: Multiple actions following mitigation hierarchy:
  • Limiting negative impacts and biodiversity loss from Group operations
  • Minimizing duration and intensity of unavoidable impacts
  • Restoring and regenerating degraded ecosystems using green infrastructure
  • Compensating for biodiversity loss where "no net loss" cannot be achieved
  • Promoting gradual internal and external transformation to address systemic drivers of biodiversity loss
• Link to policy: Commitment to respecting balance of ecosystems and biodiversity

EcoRodovias Biodiversity Programme

• Action: Biodiversity awareness and impact management plan
• Scope: EcoRodovias operations (Brazil)
• Time horizon: Adopted as of 2023
• Description: Structured programmes to raise community awareness and manage biodiversity impacts

Environmental Assessment and Monitoring

• Action: Environmental mitigation and monitoring plans for new projects
• Scope: New concessions and construction projects
• Description: Assessment of interactions with protected areas and Natura 2000 Network (Europe). Verification and evaluation within scope of individual interventions
• Expected outcomes: Prevention and/or mitigation of impacts on biodiversity

Business Continuity and Cyber Security

IT Systems Protection

• Action: Implementation of cyber security safeguards
• Scope: Own operations (Group IT infrastructure)
• Time horizon: 2026 and 2030 targets set
• Description: Multiple initiatives including:
  • Development and implementation of "Service & Data Protection Management" Guidelines and operational procedures with qualified third party support
  • ICT evolution project adapted to BU needs: centralised antivirus software installed (Itinera Group in Italy, Sweden, Denmark, Brazil, France, USA) and two-factor authentication activated
  • Ongoing Vulnerability Assessment mechanism for infrastructure security
  • Awareness-raising and training initiatives on cyber-security (including phishing campaign by Sinelec)
• Expected outcomes: Zero stoppage of critical IT systems due to cyber attacks (target: 0 by 2026 and 2030)
• KPIs: Zero stoppage of critical IT systems due to cyber attacks achieved in 2024 (baseline 0 in 2023)
• Resources: Non-financial - support from qualified third parties, internal training programmes

Note: Resources allocated to climate actions are not quantified in financial terms (no capex/opex amounts disclosed) in the excerpts provided. Further details on actions and targets are cross-referenced to other sections of the report (pages 80-81, 90-91, 104-118).

Science-Based Targets: In 2021 ASTM became the first European motorway operator – and the largest in terms of km managed – to set science-based emission reduction targets for 2030 validated by the Science-Based Targets initiative (SBTi), in line with the reduction trajectories set out in the Paris Agreement.

Sustainability-Linked Financing Framework KPIs:

• KPI 1: Reduction of greenhouse gas emissions classified as Scope 1 and 2 (market-based) by 54% by 2030, against the benchmark of 2020
• KPI 2: Reduction of greenhouse gas emissions classified as Scope 3 by 11.1% by 2030, relative to goods and services acquired, against the benchmark of 2021
• KPI 3: Installation of electric vehicle charging stations in 100% of the service areas present along the motorway networks managed by the ASTM Group in Italy and Brazil, by 2026

For KPI 1, ASTM has also set intermediate targets for 2026 and 2028, while for KPI 2 an intermediate target has been set for 2028. Note that the intermediate KPI 1 target for 2024 was achieved.

Energy consumption and mix

Total energy consumption

Total energy consumption in 2024 was 505,900 MWh (483,118 MWh in 2023), representing a 5% increase compared to the previous year.

Energy consumption by source (MWh)

Scope and methodology

Energy consumption is monitored at least every six months in accordance with GHG Protocol Corporate Accounting and Reporting Standard guidelines. The increase in fossil energy consumption is primarily attributable to higher activity levels, while the significant increase in renewable electricity reflects the Group's commitment to sourcing renewable energy.

Electricity consumption details

Total electricity consumed in 2024: 183,140 MWh (164,660 MWh in 2023)

• Electricity from renewable sources: 171,041 MWh (93% of total electricity; 67% or 109,486 MWh in 2023)
• All purchased renewable electricity was certified through Guarantees of Origin
• Self-generated energy: 3,741 MWh (3,396 MWh in 2023), 100% from photovoltaics

Energy intensity

Energy intensity for high climate impact sectors (construction, concessions, holding companies with high climate impact subsidiaries): 0.079 MWh per thousand EUR net revenue (0.082 in 2023).

Net revenue used for calculation: EUR 6,048,914 thousand (companies with NACE codes classified as high climate impact sectors). Total Group net revenue was EUR 6,157,631 thousand.

Gross Scopes 1, 2, 3 and Total GHG emissions

Summary of GHG emissions (2024 and 2023)

ASTM Group reports GHG emissions in accordance with the GHG Protocol Corporate Accounting and Reporting Standard. The reporting boundary follows operational control. Scope 2 is reported using both location-based and market-based methods. Scope 3 includes categories deemed relevant to the Group's activities.

Scope 1 breakdown by source type

Scope 1 breakdown by GHG type

Scope 3 breakdown by category

GHG intensity

Net revenue used for intensity calculation: EUR 6,158 million (2024); EUR 5,677 million (2023), matching "Total Revenue" in the Consolidated Financial Statements.

Biogenic emissions

Biogenic emissions for Scope 2 were not calculated separately due to the absence of specific emission factors.

Scope 1 and 2 emissions by Business Unit (2024)

Scope 3 category 1 emissions by Business Unit (2024)

Long-term targets (aligned with Climate Transition Plan)

The following table shows baseline values and targets. Targets are set on a financial control basis (including 100% of joint operations emissions), differing from the operational control basis used for reporting under ESRS.

Targets validated by Science-Based Targets initiative (SBTi).

Methodology and scope notes

• Consolidation approach: Operational control.
• Conversion factors: DEFRA 2024 for emission factors and GWP; TERNA 2020 and AIB 2023 for grid factors.
• Scope 1: Includes direct emissions from stationary and mobile combustion, process emissions, and fugitive emissions (HFC from refrigeration/air conditioning).
• Scope 2: Reported using both location-based (grid average) and market-based (contractual instruments, including Guarantees of Origin for renewable electricity) methods. 100% of purchased electricity from renewable sources certified via Guarantees of Origin.
• Scope 3: Categories calculated based on GHG Protocol guidance. Category 1 (purchased goods and services) is the most material. Calculations use: (i) primary supplier data (5% of Scope 3 in 2024); (ii) emission factors applied to quantities; (iii) spend-based carbon intensity. Categories 9, 10, 11, 12, 13, 14 not applicable or not material.
• Regulated emissions: Not disclosed separately (e.g., EU ETS).
• Joint operations: Emissions from joint operations are included on a 100% basis under operational control for ESRS reporting. Targets use financial control (proportional consolidation).

Energy intensity (high climate impact sectors)

Energy intensity for companies in high climate impact sectors (NACE codes per Delegated Regulation (EU) 2022/1288): 0.079 (2024); 0.082 (2023). Net revenue of high impact climate sectors: EUR 6,048.9 million (2024); EUR 5,594.2 million (2023).

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

Phase-in exemption applied

ASTM applies the phase-in exemption for ESRS E1-9 Anticipated financial effects from material physical and transition risks and potential climate-related opportunities. This exemption is allowed for the first 3 reporting years under CSRD.

Related datapoints subject to phase-in

The following specific datapoints under ESRS E1-9 are also subject to the phase-in provision:

• ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks (paragraph 66) - aligned with Annex II to Delegated Regulation (EU) 2020/1818 and Annex II to Delegated Regulation (EU) 2020/1816

• ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk (paragraph 66 (a)) - aligned with Article 449a of Regulation (EU) No 575/2013; paragraphs 46 and 47 of Commission Implementing Regulation (EU) 2022/2453; Template 5 – Banking book – Indicators of potential climate change physical risk: Exposures subject to physical risk

• ESRS E1-9 Location of significant assets at material physical risk (paragraph 66 (c)) - aligned with Article 449a of Regulation (EU) No 575/2013; paragraphs 46 and 47 of Commission Implementing Regulation (EU) 2022/2453; Template 5 – Banking book – Indicators of potential climate change physical risk: Exposures subject to physical risk

• ESRS E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes (paragraph 67 (c)) - aligned with Article 449-bis of Regulation (EU) No. 575/2013; point 34 of Commission Implementing Regulation (EU) 2022/2453; Template 2: Banking book - Climate change transition risk: loans collateralised by immovable property – Energy efficiency of the collateral

• ESRS E1-9 Degree of exposure of the portfolio to climate-related opportunities (paragraph 69) - aligned with Annex II to Delegated Regulation (EU) 2020/1818

Policies related to own workforce

ASTM has adopted several policies specifically related to its own workforce, covering diversity and inclusion, human capital development, occupational health and safety, data privacy, and working conditions.

Diversity and Inclusion Policy

Scope: The Policy is addressed to members of the administration and control bodies, managers and employees, and to all collaborators, consultants, suppliers, contractors and business partners with whom any kind of dealings or relationship exists. All personnel are obliged to comply with the principles contained within this Diversity and Inclusion Policy in all relationships with colleagues, clients, suppliers and anyone they may come into contact with when carrying out their activities.

Key content: ASTM and its main operating subsidiaries emphasize their commitment to promoting an inclusive work environment and recognising diversity as a strategic resource. The companies are committed to preventing all forms of discrimination concerning employment and work, and do not tolerate any type of discrimination based on ethnic or racial origin, skin colour, sexual orientation, gender, religious beliefs, nationality, age, political opinions, trade union affiliation, marital status, health, or any other social or personal characteristics. They are dedicated to promoting an inclusive culture which is welcoming to disabilities.

Governance and oversight: Particular responsibility for the application, dissemination and implementation of the Diversity and Inclusion Policy falls upon members of management whose position sees them involved in the day-to-day management and supervision of employees, in addition to their hiring, recruitment, promotion and training processes.

Links to international standards: When defining the principles and commitments to be contained in the Diversity and Inclusion Policy, ASTM took into account the following documents issued by the relevant international organisations:

• Declaration on Fundamental Principles and Rights at Work and Conventions (International Labour Organization)
• Guidelines on Diversity & Inclusion in the Workplace (UN Global Compact)
• Guiding Principles on Business and Human Rights (United Nations)
• United Nations International Bill of Human Rights, including the UN Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights
• ILO Convention no. 111 concerning discrimination
• Agenda 2030 for Sustainable Development adopted on 25 September 2015 by the United Nations General Assembly and its 17 Sustainable Development Goals (SDGs, specifically Goal 5 on gender equality)

ASTM has subscribed since 2020 to the Women's Empowerment Principles (WEPs) promoted by the United Nations Global Compact to guide companies towards gender parity in employment, on the market and in the community.

Monitoring: Monitoring of violations and compliance with the Policy are ensured through a disciplinary system that provides for sanctions in the event of non-compliance. The Group is committed to taking concrete measures to prevent discriminatory behaviour and violations of the principles and contents of the policy.

Human Rights Framework

Scope: The framework applies to members of the administration and control bodies, employees, collaborators, consultants and business intermediaries, suppliers, contractors and subcontractors, as well as to business partners with whom business dealings or relationships exist or who operate in the name of or on behalf of ASTM or its subsidiaries in any capacity and regardless of the type of contractual relationship.

Key content: The Human Rights Framework adopted by ASTM and its main operating subsidiaries defines the reference framework for the Group to raise awareness of and strengthen respect for Human Rights within its sphere of influence. In compliance with the framework, each Group company defines its own governance in relation to human rights within the scope of its management autonomy and following a risk-based approach, assigning roles and responsibilities to each unit (e.g. Human Resources, Procurement, Health and Safety, etc.) to the extent of their specific remit. The Group companies integrate due diligence activities into their processes and are committed to promoting respect for human rights, including through targeted awareness-raising activities.

Links to international standards: The Human Rights Framework is based on the main international standards on human rights, such as:

• UN Guiding Principles on Business and Human Rights
• Universal Declaration of Human Rights
• ILO Conventions
• European Directive on Corporate Sustainability Due Diligence

Public availability: The framework is communicated to all those directly affected, as well as being made available on ASTM website and those of the main operating subsidiaries.

Monitoring: The main operating subsidiaries have begun integrating into their Risk Management model a process that includes:

• Identifying and assessing actual and potential negative impacts on human rights
• Defining and implementing an action plan to prevent, end and mitigate impacts on human rights
• Providing a complaints procedure and channel and implementing appropriate measures to remedy actual impacts
• Monitoring the effectiveness of the policy and measures implemented
• Transparent reporting on the methods and measures with which the organisation addresses and intends to address negative impacts on human rights

Data Privacy Policy

Key content: Referenced in relation to own workforce policies (page 149).

Occupational Health and Safety Policies

Key content: ASTM has implemented policies and management systems for workplace accident prevention, as described on pages 146-147. These policies are referenced as part of the Group's comprehensive approach to protecting own workforce.

Working Conditions and Well-being Policies

Key content: The Group has adopted policies relating to working conditions and employee well-being, as described on page 150.

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Integration with other policies: The regulations represented by the Diversity and Inclusion Policy and the Human Rights Framework reaffirm and integrate the principles set out in:

• The Group Code of Ethics and Conduct
• The Organisation, Management and Control Model pursuant to Italian Legislative Decree no. 231/2001 adopted by ASTM
• The SA8000:2014 Guidance Document for Social Accountability
• Current company policies and procedures

Taking action on material impacts on own workforce

Actions in the field of Diversity and Inclusion

D&I Team Ambassador

• Description: Team set up in 2024 to share, promote and disseminate diversity, inclusion and gender equality initiatives across all Group companies, and to monitor their implementation and effectiveness
• Scope: Own operations, all BUs
• Resources: Includes resources from ASTM's Sustainability, Organisation and Key People, Personnel Administration and Industrial Relations, and Communication and Public units. To be expanded in 2025 to include representatives from other corporate units and Group companies
• Time horizon: Launched 2024, expansion planned 2025

Video Training Materials

• Video clips on disability topics ("people first" approach; Disability & Diversity Managers) used in employee training initiatives and external stakeholder engagement, available in the "Sustainability" section of the company website
• Scope: Own operations

Certifications in the field of Diversity and Inclusion

• Description: ISO 30415 "Diversity & Inclusion" and UNI PdR 125-2022 "Gender Equality" certifications obtained by Itinera and Sinelec in 2024
• Scope: Own operations
• Resources: Coordinated and managed by personnel departments with support of specialised consultants
• Time horizon: 2025 target to extend certifications to other Group companies
• Expected outcomes: Further narrow the gender gap by fostering equal career opportunities, equal pay, support for parenthood and work-life balance

Diversity Target

• Increase the % of women in top management from 17% (2024) to 20% by 2026 and 30% by 2030

Actions for human capital development

Young Talent Development Centre (YTDC)

• Description: Development roadmap programme to attract and hire young talent in all Group business sectors, build their loyalty, foster belonging through intra-Group initiatives, and invest in them through assessment and training processes
• Scope: Own operations, all Group business sectors
• Time horizon: 2023-2026
• Resources: Coordinated by the Organisation and Key People unit
• Expected outcomes: Increase the percentage of high-potential young employees involved in YTDC; accompany young employees from joining through first four years with development and salary paths
• Programme areas: (i) communication and community; (ii) training; (iii) evaluation, development and career paths; (iv) initiatives to attract young resources

Politecnico di Milano Investor Programme

• Description: Partnership with Politecnico di Milano University to promote recruitment and talent-development activities through integrated calendar of events and communication activities
• Scope: Own operations (Italy)
• Time horizon: 12-month programme
• Expected outcomes: Position amongst Politecnico di Milano's top employer rankings; includes meetings, consultations and internship opportunities

Politecnico di Torino Collaboration

• Description: Collaboration renewed in 2024 to introduce young graduating students to motorway concessionaires' world of work
• Scope: Own operations (Italy)
• Resources: 60 students participated in 2024 (40 in previous edition)
• Activities: Two days of workshops including theoretical training and practical experience at construction sites (Mompantero Tunnel, Bussoleno Viaduct on A32 motorway)
• Expected outcomes: Identify and develop young talent; confirm ASTM's role as incubator of highly qualified professionals

Integration of sustainability skills into performance appraisal system

• Description: Integration of "Sustainability Skill" into Performance Appraisal system for middle managers and executives in 2024, defined as "Ability to consciously adopt and to promote the adoption of practices and actions that protect the environment and promote diversity and inclusion"
• Scope: Own operations, all BUs
• Time horizon: Extended to middle managers and executives in 2024; planned extension to "professional" tier in 2025
• Expected outcomes: Raise awareness and deliver alignment on strategic skills and expected behaviours; support evolution of leadership models; structure growth paths and facilitate talent development

ASTM Academy

• Description: Technical training courses for young engineers and architects, new talents in the workforce, to develop multidisciplinary skills in design, construction, management and ecological transition for large infrastructures
• Scope: Own operations
• Resources: Contribution of industry experts, academics and institutional representatives; specialised trainers and leaders
• Time horizon: Two editions, each lasting two years; first edition ended in 2024
• Activities: Vertical sector meetings (e.g. workplace safety sessions); soft skills development programmes; training on socially relevant topics (e.g. fight against gender violence)

Training Target

• Increase % of employees involved in ESG training (including business ethics, Human Rights, etc.) from 59% (2024) to 70% by 2026 and 85% by 2030

Actions on occupational health and safety

Widespread training on health and safety issues

• Description: Training and prevention programmes to reduce injuries, guarantee safe working environment, and promote virtuous behaviour in the workplace
• Scope: Own operations, all BUs
• Activities: Sharing good practices; active engagement of employees through field exercises; "safety talks" and communication campaigns through EcoRodovias Group's "Segurança Sempre" programme
• Expected outcomes: Drop in rate of recordable work-related accidents
• 2024 Performance: Rate of recordable work-related injuries for employees dropped from 10.1 (2023) to 8.0 (-21%)

Health and Safety Management Systems

• 71% of Group employees and 94% of non-employee workers covered by health and safety management system based on legal requirements and/or recognised standards (66% and 82% respectively in 2023)
• ISO 45001 certifications obtained by companies of EcoRodovias Group (Ecorodoanel, Ecosul, Termares), Itinera Group (SEA Segnaletica Autostradale, ICCR RIO MINAS), and Tangenziale Esterna

Target on Occupational Health & Safety

• Reduce Rate of recordable work-related accidents (per million hours worked) from 8.00 (2024) to 7.80 by 2026 and 7.00 by 2030

Actions on data protection

Data Privacy Policy

• Description: Policy adopted by ASTM and main operating subsidiaries governing processing of personal data by employees, collaborators or authorised persons to ensure compliance with GDPR
• Scope: Own operations
• Responsibility: Chief Executive Officer of each company
• Regulatory references: GDPR, OECD Convention, UN Convention against Corruption, FCPA, UK Bribery Act, Civil Law Convention on Corruption, African Union Convention

Data protection organisational and management model

• Components: (i) Data Protection Officer in each company; (ii) internal regulations, guidelines, policies, procedures and protocols; (iii) digital platform for management and accountability of all data protection activities
• Coordination: Data Protection Officers Group with role of raising collective awareness and connecting methodologies
• Resources: Training initiatives based on corporate profiles; special focus on data processor employees

Data Protection Target

• Increase % of data processor employees trained on data protection from 80% (2024) to 80% by 2026 and 100% by 2030 (baseline 76% in 2023)

Actions on working conditions and well-being

Renewal of second-level contracts

• Description: Renewal in 2024 of second-level agreements with Tangenziale Esterna, Aurea, Concessioni del Tirreno, SINA and Itinera supplementing collective bargaining agreements
• Scope: Own operations (Italy)
• Benefits provided: Supplementary pension policies; medical expense reimbursement for employees and families; Long-Term Care (LTC); special conditions for company microloans; additional life and accident insurance; advances/loans at special conditions
• Additional measures: Parenthood measures; organisational flexibility; care for family members; school-related bonuses; additional paid leave for children starting nursery/kindergarten; leave for accompanying family to emergency room; bonuses for birth of child; psychological support for staff returning from maternity leave or serious illness; solidarity leave; graduation bonuses
• ESG integration: Supplementary agreements with Aurea and SINA include ESG parameters for performance bonuses (CO2 emissions reduction per employee; employee participation in ESG training)
• Ongoing: Trade union negotiations for renewal of second-level agreements with Sinelec, SATAP and SAV
• Effectiveness monitoring: Monitored through use of supplementary services; consistently high levels of employee uptake of supplementary pension schemes (98% entitled to leave for family reasons; 5.7% took advantage in 2024)

"Brandability" project

• Description: Project launched in 2024 to strengthen Group's Corporate Identity externally while promoting internal corporate culture consistent with new set of values
• Scope: Own operations
• Resources: Representative sample of Group employees involved through workshops and surveys (diverse by business sector, seniority, age and gender)
• Time horizon: Completed 2024; internal and external communication campaign planned 2025
• Outcomes: Definition of Group's new purpose, vision, mission, and values
• Preparatory initiatives: "Coffee with the CEO" initiatives to draw out aspirations and vision of young employees

Characteristics of the undertaking's employees

Total headcount and FTE

As at 31 December 2024, ASTM Group's total number of employees was 13,964 (13,499 as at 31 December 2023). Unlike the financial statements, the number of employees of the joint operations is reported in full, without factoring in the stake held in the company. The figures for manual workers include Union Workers on the payroll at the reporting date, regardless of the number of hours worked in the reporting period.

Headcount by gender

Headcount by country/region

Headcount by employment contract type

31/12/2024

31/12/2023

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

31/12/2024

31/12/2023

Headcount by region and contract type (31/12/2024)

Headcount by region and contract type (31/12/2023)

Employee turnover

A total of 5,304 employees left the Group's companies during the financial year (compared to 4,964 in 2023), resulting in a turnover rate of 39.3% (38% in 2023). This can mainly be attributed to turnover in certain companies of the EPC Business Unit, the expiration of motorway concessions, and the seasonal nature of certain professional roles in the concessions sector related to staffing motorway toll booths.

The turnover rate is calculated by dividing the total number of employees who left the Group during the financial year by the total number of employees in the workforce at the end of the previous financial year, and multiplying by 100.

Non-employee workers

In addition to employees, the Group's own workforce also includes 468 collaborators or non-employee workers (287 as at 31 December 2023), of whom 57 are self-employed workers (45 as at 31 December 2023) and 411 are workers provided by third party undertakings primarily engaged in employment activities (NACE code N78) (242 as at 31 December 2023). The change of 181 compared to 2023 is mainly attributable to the increased use of temporary workers in the construction sector in Italy.

Methodology notes

• Employees with non-guaranteed hours, of whom there were 1,873 (804 as at 31 December 2023), are represented solely by Union Workers of the US companies of the Halmar Group.
• For joint operations in which ASTM does not hold operational control, the percentage of its ownership is taken into account when reporting information on environmental indicators, while full information is provided for social indicators.
• Nearly all employees (98%) are entitled to leave for family reasons, in accordance with the provisions of collective agreements and the social policy adopted by Group companies.

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

Total non-employee workers

As at 31 December 2024, ASTM Group's own workforce included 468 non-employee workers (287 as at 31 December 2023).

Breakdown by type

Methodology

Non-employee workers include:

• Self-employed workers employed under individual contracts
• Temporary workers from recruitment, selection and supply agencies, including temporary workers and interns

The count excludes Union Workers, who are reported under employees. Union Workers are workers on the payroll of Halmar Group companies under existing contracts with trade unions in the United States.

Year-on-year change

The change of 181 non-employee workers compared to 2023 (+63%) is mainly attributable to the increased use of temporary workers in the construction sector in Italy.

Coverage by health and safety management systems

94% of non-employee workers are covered by a health and safety management system which is based on legal requirements and/or recognised standards (82% in 2023). The percentage was calculated taking into account the number of workers in the workforce of companies holding ISO 45001 certification.

Collective bargaining coverage and social dialogue

Overall coverage

The total percentage of employees covered by collective agreements is 96% (95% as at 31 December 2023).

The total percentage of employees covered by workers' representatives is 43% (55% as at 31 December 2023).

Collective Bargaining Coverage and Social Dialogue by geography and coverage bands

Second-level agreements

ASTM Group operates in full compliance with the provisions of national collective bargaining agreements applied by Group companies and undertakes to periodically renew supplementary packages.

In 2024, ASTM Group renewed its second-level agreements with Tangenziale Esterna, Aurea, Concessioni del Tirreno, SINA and Itinera. These agreements supplement the benefits provided by collective bargaining agreements which apply to all employees of Group companies, excluding managers.

Trade union negotiations are also underway for the renewal of the second-level agreements with Sinelec, SATAP and SAV.

Adequate wages

All employees of Group companies are paid an adequate wage, defined pursuant to the terms of collective agreements, where any such exist. In countries where collective agreements are not applicable, adequate wages are defined by reference to the applicable minimum wage established by local legislation.

Diversity metrics

Gender diversity in top management

Gender distribution among top management (managers of all companies within the reporting perimeter):

Women represent 17% of top management (15% in 2023). With regard to representation on the Board of Directors, reference is made to the paragraph on the "Governance Structure" in the "General Disclosures" section.

Age band distribution of total workforce

58% of employees are between 30 and 50 years old (54% in 2023), while employees under 30 make up 16% (18% in 2023).

People with disabilities

People with disabilities constituted 2.38% of the Group's total employees (2.34% as at 31 December 2023), totaling 333 people (316 as at 31 December 2023). Of these:

• 202 were men (200 as at 31 December 2023)
• 130 were women (114 as at 31 December 2023)
• 1 belonged to the gender-neutral category (2 as at 31 December 2023), shown as "other genders"

Adequate wages

All employees of Group companies are paid an adequate wage, defined pursuant to the terms of collective agreements, where any such exist. In countries where collective agreements are not applicable, adequate wages are defined by reference to the applicable minimum wage established by local legislation.

Benchmark Used

No living wage benchmark is applied. ASTM defines "adequate wage" based on:

• Collective agreements (where applicable)
• Applicable minimum wage established by local legislation (where collective agreements do not exist)

Coverage

All employees (100% of own workforce) are covered by either collective agreements or minimum wage provisions.

Geographic Scope

Global coverage across all countries of operation, including Algeria, Botswana, Russia, Kuwait, UAE, France, Italy, Sweden, North America, and Latin America.

Targets / Commitments

No targets or commitments regarding living wage disclosed.

Methodology

No living wage methodology disclosed. The company relies on compliance with collective bargaining agreements and local minimum wage legislation.

Social protection

Almost all employees are covered by social protection measures, such as public programmes or benefits offered by the undertaking, against loss of income due to one of the following major life events: illness, unemployment, occupational injury and acquired disability, parental leave and retirement in accordance with local laws.

Coverage exclusions by country

Algeria:

• No law in place regarding unemployment protection
• No parental leave benefits recognised
• No sick leave protection currently recognised

Botswana:

• No law in place regarding unemployment protection

Russia:

• No law in place regarding unemployment protection
• No parental leave benefits recognised
• No sick leave protection currently recognised

Kuwait:

• Unemployment law covers only Kuwaiti employees (foreign employees not covered)
• No parental leave benefits recognised
• Pension contributions paid only for Kuwaiti employees (foreign employees hired locally not subject to contributions)

United Arab Emirates:

• Pension contributions paid only for Emirati employees (foreign employees hired locally not subject to contributions)

Overall coverage

The percentage of employees not covered by social protection measures is currently 0.3%.

This means approximately 99.7% of employees are covered by social protection measures for major life events.

Type of scheme

Coverage is provided through a combination of public programmes and benefits offered by the undertaking, in accordance with local laws.

Training hours provided to employees:

In 2024, approximately 280 thousand hours of training were delivered to employees, of which:

• 136 thousand hours related to health and safety
• 102 thousand hours dedicated to the development of professional, technical and engineering and IT skills
• 23 thousand hours on business ethics

Young Talent Development: Employees involved in the Young Talent Development Centre: 216 in 2024, up from 135 in 2023 (+60%)

Health and safety metrics

Coverage by health and safety management system

71% of Group employees and 94% of non-employee workers are covered by a health and safety management system based on legal requirements and/or recognised standards (66% and 82% respectively in 2023). The percentage was calculated taking into account the number of workers in the workforce of companies holding ISO 45001 certification. The increase is attributable to new certifications obtained by companies of the EcoRodovias Group (Ecorodoanel, Ecosul and Termares), the Itinera Group (SEA Segnaletica Autostradale and ICCR RIO MINAS) and Tangenziale Esterna.

Fatalities and work-related injuries

The rate of recordable work-related injuries for employees dropped from 10.1 in 2023 to 8.0 (-21%). The rate of recordable work-related injuries is the LTIFR (Lost Time Injury Frequency Rate): ratio of the number of injuries leading to absence from work in the year to the total number of hours worked, multiplied by 1,000,000.

Fatal accidents involving contractors

Eight fatal accidents occurred at some of the Group's operating sites (compared to three in 2023). These involved seven workers from contractors of the EcoRodovias Group's companies (two in 2023), and one worker from an Itinera subcontractor (one in 2023). For completeness, one fatal accident occurred in 2024 at the operating site of the Telt SEP JV joint operation, in which Itinera has an interest, involving an employee of a partner in the joint operation.

Work-life balance metrics

Entitlement to and uptake of family-related leave

In line with the previous year, almost all employees (98%) are entitled to leave for family reasons, in accordance with the provisions of collective agreements and the social policy adopted by Group companies. Of these, 5.7% took advantage of it (5.9% in 2023), with slightly higher uptake among female employees.

The percentage of employees who took advantage of this leave is shown in the following table, broken down by gender.

Supporting programmes

The Group has renewed second-level agreements that include special measures relating to parenthood, organisational flexibility, care for family members and school-related bonuses. These include additional paid leave entitlements for when children start nursery and/or kindergarten and up to the age of three; leave for accompanying family members to the emergency room; bonuses for the birth of a child and psychological support for staff returning from compulsory maternity leave; solidarity leave; and bonuses for graduation.

The Group also operates the "0-18" programme offering services such as childcare, educational support, and holiday activities, as well as the Care programme providing assistance for elderly or dependent family members.

Compensation metrics

Pay gap

The gender pay gap in the Group stands at 22%. This indicator is calculated as the difference between the average hourly wage level paid to female and male workers, expressed as a percentage of the average hourly wage level of male workers, excluding companies where either gender is not represented. For the purpose of calculating the average wage level, basic salary was added to complementary or variable components, including overtime pay. The total was then considered in relation to hours worked, understood as the sum of contractual working hours on an annual basis plus overtime.

Remuneration ratio

The ratio of the highest-paid individual's annual total remuneration to the median annual total remuneration for all employees was 68 as at 31 December 2024. The data used for this assessment is based on the annual remuneration, including fixed contractual components and variable components, of all Group workers employed as at the reporting date, excluding those who left during the year.

Methodology

Gender pay gap calculation: The indicator excludes companies where either gender is not represented. Wage level includes basic salary plus complementary or variable components (including overtime pay), divided by hours worked (contractual working hours on an annual basis plus overtime).

Remuneration ratio calculation: Based on annual remuneration (fixed contractual and variable components) of all Group workers employed as at the reporting date, excluding those who left during the year.

Incidents, complaints and severe human rights impacts

Information on work-related incidents and complaints involving the undertaking's own workforce, in relation to their human rights, is presented below.

Status of complaints

The numbers referring to incidents of discrimination and complaints filed refer to the total number of reports received, regardless of whether the reported cases are upheld. Specifically:

• Of the 130 cases of discrimination and harassment (of which 125 were related to the EcoRodovias Group), 17 cases were upheld
• Of the 376 complaints filed (of which 364 were related to the EcoRodovias Group), 38 were upheld, all in relation to the EcoRodovias Group

The increase in complaints is mainly attributable to the EcoRodovias Group, following the major awareness-raising campaign carried out during the year to encourage use of the reporting channels.

Fines and sanctions

With reference to the aforementioned incidents, no charges were incurred in the income statement for the companies of ASTM Group.