Athens International Airport S.A.

The role of the administrative, management and supervisory bodies

Reference: pages 92-97.

AIA reports governance at both Board and management level, with a table of bodies and their sustainability roles (pages 95-97):

• Board of Directors - "Provides strategic oversight of sustainability integration into corporate governance and decision-making; reviews sustainability performance and endorses strategic priorities."
• Audit Committee - "Oversees sustainability reporting integrity; reviews adequacy of internal controls, ethics, compliance, and assurance processes related to ESG disclosures; monitors independence and quality of external assurance providers."
• Sustainability Committee - a management-level body chaired by the Manager, Sustainability and Industry Affairs, with nine named senior leaders from HR, procurement, energy, environment, aviation, commercial, communications and finance. It reviews the Sustainability Policy, validates the DMA and endorses disclosures.
• Sustainability Strategic Planning & Reporting Department (SPR), reporting to the Chief Strategy Officer, leads the reporting process and the DMA.
• Also listed: the Procurement Department (ISO 20400 alignment in 2025), the safety and environmental risk governance committees, the employee-elected Health & Safety Committee, the Whistleblowing Investigation Committee and the Information Security Department.

Board expertise criteria include "aviation, energy, human resources management, audit, legal, finance, environmental, social and corporate governance (ESG), business administration, commercial activities, cybersecurity, and information technology" (page 97).

Board diversity (Table 3, page 97): 13 members, 9 male (69.23%) and 4 female (30.77%), gender diversity ratio 0.44, 5 independent members (38.50%). All figures unchanged on 2024.

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: pages 98-102.

The Board "receives reports, prepared in accordance with the applicable Corporate Policy, on key aspects of corporate planning, current technical and legal developments in the aviation industry, and on the Company's measures and activities relating to sustainability" (page 98).

Table 4 sets out, body by body, the sustainability matters addressed during FY2025 (pages 98-102):

• Board of Directors - reviewing and approving the DMA outcome, approving limited assurance third-party engagement, and matters grouped under environmental management and climate action (PV park with BESS, electric buses, chargers, outdoor lighting upgrades, the Airport Expansion Program, the Sustainability Support Scheme for airlines), governance and risk, social and human capital, sustainable finance and stakeholder engagement.
• Audit Committee - "CSRD and EU Taxonomy: Corporate developments, reporting and assurance, 2025 plans, external audit engagement", the assurance map, risk appetite and key risk metrics, the Business Continuity Management System, and the Customer Satisfaction Survey methodology and results.
• Remuneration and Nomination Committee - the 2025 Long-Term Incentive Plan and "2025 corporate and sustainability-related targets".
• Board of Executives (CEO, CSO, COO, CDO, CFO) - Scope 1 reduction initiatives, ISO 50001 performance reviews, fleet electrification, NOMOS noise monitoring, sustainable procurement.
• Sustainability Committee - DMA approach and criteria, and "Impact and financial materiality outcomes and validation".

Finance, Investment, Personnel and CapEx Committees are covered as well (pages 100-102).

Integration of sustainability-related performance in incentive schemes

Reference: pages 102-103.

"AIA has integrated ESG-related short-term and long-term incentives into its corporate strategy, incorporating sustainability metrics within its balanced scorecards" (page 102). Climate-related metrics "are embedded in the remuneration strategies for AIA's Executive Members of the Board of Directors, management, and employees, aligning with the Company's GHG emissions reduction targets."

Quantified weightings disclosed (pages 102-103):

• The Overall Passenger Satisfaction Score, part of the Corporate Scorecard, is weighted at 25%.
• Sustainability-related targets account for 15% of the operational scorecard, covering carbon footprint reduction, community engagement and support, sustainable services and human resources development.
• The Operational Performance Ratio derived from that scorecard "can influence the payout pool by +/-10%, indirectly affecting individual incentive payouts."
• "20% of the Long-Term Incentive remuneration for AIA's Executive Members of the Board of Directors and management for FY2025 was specifically linked to climate-related metrics."

Cybersecurity KPIs are also integrated "into the performance evaluations and incentive plans for functions accountable for information security and operational resilience". Targets are set annually by the Management Team and approved by the Board.

Statement on due diligence

Reference: pages 103-105.

Table 5, "Elements of Due Diligence in the Sustainability Statement", maps each of the five core elements of the due diligence process to named paragraphs of the statement (pages 103-105):

• (a) Embedding due diligence in governance, strategy and business model - Sustainability Governance, the DMA results (SBM-3), GOV-2, SBM-1/SBM-2, IRO-1 and the Policies Overview (MDR-P).
• (b) Engaging with affected stakeholders in all key steps - S1-2, S1-3, S2-2, the human rights section, S3-2, the noise remediation section (S3-3, S3-4), S4-2 and S4-3.
• (c) Identifying and assessing adverse impacts - the DMA process and results, "Climate Scenario Analysis and Environmental Resilience Analysis", and the SBM-3 sections for own workforce, value chain workers, affected communities and consumers.
• (d) Taking actions to address those adverse impacts - the Climate Change Action Plan and Climate Change Actions, Water Management Actions, the S1 and S2 action sections, the Community Engagement Plan, passenger safety actions and cyber security actions.
• (e) Tracking effectiveness and communicating - E1-4, E1-5, E1-6, E1-7, E3-3, E3-4, the S1 metrics set, S2-5, S3-5, S4-5 and the cyber security targets and performance section.

The Reference Table marks GOV-4 as derived from other EU legislation (page 251).

Risk management and internal controls over sustainability reporting

Reference: pages 105-106.

AIA describes a chain of responsibility running from data collection to Audit Committee review (page 105): "The sustainability reporting process begins with Data Owners in each Department, who are responsible for accurately recording data in line with established corporate policies and defined methodologies. This data undergoes a formal approval process, whereby designated Approvers ensure appropriate oversight, implement necessary controls, and verify data accuracy, completeness and consistency, supported by validation from Subject Matter Experts where required." The SPR Department compiles the disclosures, the Manager of Sustainability and Industry Affairs and the Chief Strategy Officer provide strategic guidance, and "The Sustainability Committee reviews and approves the Sustainability Statement prior to its submission to the Audit Committee for final review."

The reporting risks named are specific: "data completeness, estimation uncertainty, manual data handling and reliance on multiple data owners and systems", addressed "through defined internal controls, approval hierarchies, documentation requirements and evidence-based validation procedures" (page 105).

AIA states that controls are "progressively aligned with the Company's broader internal control and risk management framework" and that it is "progressing towards increased digitalisation and automation of sustainability data collection and consolidation processes" to meet "limited assurance expectations" (page 106). No conclusion on the effectiveness of these controls is given.

Strategy, business model and value chain

Reference: pages 106-113.

AIA operates Athens International Airport "Eleftherios Venizelos" through two segments, Air Activities and Non-Air Activities, and states that "In FY2025 there were no changes in the Company's business model compared to the previous reporting year" and none in the value chain either (pages 106, 111).

Disclosed specifics:

• ISO 20400 certification obtained in 2025 for sustainable procurement, and "During the reporting period, 1,094 suppliers were covered by contractual agreements including an ESG clause" (page 108).
• "AIA does not operate in the fossil fuel sector, nor is it involved in chemical production, controversial weapons, or the cultivation and production of tobacco" (page 108).
• ROUTE 2025 completed: "As of January 1st, 2026, all of AIA's electricity needs are covered solely by clean, renewable electric energy produced within the airport's premises for self-consumption" (page 108). AIA commissioned a 35.5MWp photovoltaic system and an 82MWh Battery Energy Storage System (page 110).
• Master Plan approved by the HCAA in 2019 for phased development "up to 50 million passengers per year"; the current 40 MAP phase expands the Main Terminal Building, upgrades the Satellite Terminal Building and adds a multi-storey car park (page 111).
• Upstream services listed include security, maintenance, bus transportation, IT&T suppliers, waste contractors and cleaning; downstream comprises airlines, ground handlers, retail, food and beverage, advertising and landside transport (page 111).

Phase-in: the Reference Table records that the "Phased-in option used for par. 40(b), 40(c) and AR12,13 (ESRS sectors)" applies, under Appendix C of ESRS 1 as extended by the "Quick-Fix" Delegated Act of 11 July 2025 (pages 92, 252).

Interests and views of stakeholders

Reference: pages 113-127; ESG ratings page 128.

"AIA's stakeholder engagement is conducted through a structured three-stage process ('Inform - Engage - Feedback'). Relevant AIA Departments collect stakeholder input through established engagement mechanisms within their respective areas of responsibility. The feedback collected is reviewed by management and used to inform strategic considerations and decision-making processes" (page 113).

Table 6 sets out engagement channels, frequency and thematic areas per stakeholder group across pages 114-125, covering employees, passengers, airlines and business partners, local communities and municipalities, authorities, analysts, lenders and investors (for example analyst briefings and debt investor roadshows "ad hoc as per business requirements", credit rating reports annually, financial statements twice per year, covenant reporting in January, March, July and September, page 125).

The narrative section "Interests and views of different stakeholders [ESRS S1, S2, S3, S4 SBM-2]" (pages 125-127) records that dialogue with employees runs through the Employees' Union, established in 1999, with "Collective Labour Agreements ... negotiated annually since 2000", supplemented by employee surveys and the I-mind Program.

AIA states that its "Audit Committee is briefed annually about the views and interests of affected stakeholders" and that in 2025 it "incorporated external ESG ratings into its sustainability business strategy", registering with FTSE4Good and S&P Global, and being included in the ATHEX ESG Index and the ESGr interbank platform (page 128).

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

Reference: pages 128-137; impact table pages 129-135; financial table page 136.

AIA conducted the DMA "for a second consecutive year" (page 128). Table 7 lists 13 material impacts with codes, and Table 8 lists 4 material risks; no opportunities are identified.

Impacts (Table 7): E1.I1 climate change mitigation (negative); E3.I1 water reliance and potential water resource depletion (negative); S1.I1 employment security (positive); S1.I2 adequate wages (positive); S1.I3 employee health and safety (negative); S1.I4 training and career development (positive); S2.I1 health and safety of value chain workers (negative); S3.I1 noise pollution (negative); S3.I2 community engagement and local development (positive); S3.I3 socioeconomic contribution (positive); S4.I1 passenger health and safety incidents (negative); S4.I2 enhancing passenger and visitor safety (positive); ES.I1 cybersecurity threats (negative, entity-specific).

Risks (Table 8): E1.R1 extreme weather events, own operations and downstream, short to long term, "No current financial effects"; S4.R1 health and safety risks, short term, current financial effect EUR 378,042; ES.R1 customer satisfaction and service issues; ES.R2 cybersecurity vulnerabilities. All four are marked as having anticipated financial effects.

Change on 2024: "Customer Satisfaction was reclassified from an impact to a risk, to better reflect its nature as an operational outcome" (pages 128, 137). "Apart from this reclassification, the impacts identified during the FY2024 Double Materiality Assessment remain unchanged" (page 128).

Phase-in: paragraph 48(e) quantitative anticipated financial effects are omitted under Appendix C of ESRS 1 (pages 92, 252).

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

Reference: pages 138-142; environmental screening pages 140-141.

AIA applies a five-step methodology: Understanding, Identification, Assessment, Determination of material IROs, and Validation and Strategic Implications (pages 138-142).

Thresholds and scoring are stated explicitly:

• Sustainability matters are scored "on a 1-to-6 scale, with scores of 4 or higher regarded as relevant for the materiality assessment" (page 139).
• "Negative impacts are evaluated by averaging scale, scope, and irremediability... Positive impacts are assessed using scale and scope... Likelihood ... is applied only to potential impacts" (page 141).
• "An impact score, scaled from 1 to 5, is calculated by averaging severity and likelihood. Impacts exceeding the materiality threshold of 4.0 are classified as material" (page 141). The financial assessment "follows the same methodology, scoring system, and threshold", averaging magnitude and likelihood against a threshold of 4.0.

Scope: activities are classified by NACE code across upstream, own operations and downstream; "AIA has no subsidiaries and ... its primary operations are based in Spata, Greece, which is therefore identified as the key operational site which forms the reporting boundary" (page 138).

The 2025 refinement was to identify and assess "each impact, risk, and opportunity both as current and anticipated and separately across short, medium, and long term" (page 138). Outcomes are "formally approved by the Chief Strategy Officer (CSO), under the ultimate oversight of the Board of Directors" (page 142).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: page 144; Reference Table pages 251-270.

AIA prints a full ESRS content index, the Reference Table on pages 251-270, giving for each disclosure requirement the standard, the DR number, its description, the chapter or paragraph where it sits, whether it is derived from other EU legislation, cross-references, and a comments column recording omissions and non-applicable paragraphs.

The IRO-2 narrative states the topic-level materiality outcome directly: "Based on the 2025 Double Materiality Assessment (DMA), AIA has determined that ESRS E2, ESRS E4, ESRS E5, and ESRS G1 are not material and has excluded the related Disclosure Requirements from reporting" (page 144). Those four standards each appear in the Reference Table as a single "All DRs" row carrying the not-material comment (pages 256-258, 269).

On the materiality of information, AIA states: "For this second year of reporting, no quantitative thresholds were applied; decisions were based on the relevance of information to stakeholders and their importance for understanding AIA's sustainability performance" (page 144).

The Reference Table also covers an entity-specific topic, Cyber Security, through ESRS 2 GOV-2, GOV-3, GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, MDR-P, MDR-A and MDR-T rows (pages 269-270), and a Customer Satisfaction entity-specific risk reported under S4.

AIA adds that "Unless otherwise specified within the topical disclosures, the metrics included in the Sustainability Statement are not validated by any external body" (page 144).

Transition plan for climate change mitigation

Reference: pages 189-191; financial resources Table 23, page 190.

AIA's plan is ROUTE 2025, "approved by the Board of Directors", which "served as the primary framework for integrating climate-related considerations into AIA's long-term strategic and operational planning" (page 189).

• "In 2025, AIA completed the ROUTE 2025 Roadmap comprising a suite of energy projects. As a result, AIA has been able to achieve a reduction of more than 90% in Scope 1 and Scope 2 greenhouse gas emissions compared to its 2010 baseline" (page 189).
• The plan is "aligned with ... the principles of the Greenhouse Gas Protocol and the objectives of the Paris Agreement to limit global warming to 1.5 degrees C", and "AIA is not excluded from the EU Paris-aligned Benchmarks" (page 189).
• The transition plan is being rewritten: "Following the completion of ROUTE 2025, AIA is in the process of updating its climate transition plan", which "is expected, over time, to progressively expand its scope to include Scope 3 emissions" and "will be subject to formal approval by AIA's administrative, management and supervisory bodies" (page 189).

Resources (Table 23, page 190): ROUTE 2025 CapEx EUR 44,356,802 in FY2025 against EUR 10,397,279 in FY2024 (+327%), and OpEx EUR 3,690 (FY2024 EUR 2,846). Financing: "a secured common bond loan of up to EUR 35.2 million. Of this amount, EUR 22 million was provided by the Greek State through the Recovery and Resilience Fund (RRF)" (page 191). "Additional financial resources are planned for 2026, amounting to EUR 65,913,577."

The Reference Table records "Par. 16 determined not applicable for AIA" (page 254).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and E1 ESRS 2 SBM-3, where this content is disclosed in the FY2025 report under the heading "Climate Scenario Analysis and Environmental Resilience Analysis [E1 ESRS 2 IRO-1, E1 ESRS 2 SBM-3]" (pages 142-144). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification. The DMA identifies a single material climate risk, E1.R1 "Extreme weather events", located in own operations and downstream over short, medium and long term (Table 8, page 136) - a physical risk. AIA states plainly that the existing study did not cover transition risk: "Due to the limited scope of the study, transition risks were not evaluated" (page 143).

Methodology and exposure. Physical risks were assessed through a "Climate Change Adaptation Study completed in 2019" and are being reassessed through a "new Climate Change Risk Assessment and Adaptation Planning Study for the airport, initiated in 2025 and expected to conclude in 2027" (pages 142-143). The new study will "evaluate exposure and sensitivity of assets and activities, considering both the current airport infrastructure and the phased development of new infrastructure planned between 2025 and 2046" (page 142).

Scenarios (paragraph 17). The new study will use IPCC SSP2-4.5 and SSP5-8.5 to 2100, including a high-emission scenario, and will follow ICAO airport-industry standards (page 142). The current results still rest on a 2018 study using IPCC SRES scenarios A2, A1B, B2 and B1 over horizons of 2040 and 2070 (page 143). No 1.5 degrees C-aligned transition scenario is named and AIA states the 2018 horizons "were not aligned with the climate and business scenarios employed to assess material physical and transition risks or to set greenhouse gas (GHG) emissions reduction targets" (page 143).

Resilience in relation to climate change

Back-filled from E1 ESRS 2 SBM-3, disclosed in the FY2025 report within "Climate Scenario Analysis and Environmental Resilience Analysis" (page 143). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results. "The analysis indicated that short-term risks (up to 2040) are assessed as limited, while medium- to long-term risks (up to 2070) show an increasing trend. For Athens International Airport, the most significant risks identified to date relate to long-term changes in temperature and humidity, as well as changes in the frequency and intensity of storm events. Wildfire risk has not been identified as material, taking into account the mitigation measures in place, including an on-site fire-fighting station staffed by personnel dedicated exclusively to AIA's operational needs" (page 143).

Capacity to adapt. "The results indicate AIA's capacity to adapt its strategy and business model across short- (up to 2040), medium-, and long-term (up to 2070) horizons" (page 143). The 2024 Hydraulic Study "found that the network is properly sized and maintained so as to manage the increased frequency and intensity of precipitation foreseen and safeguard operations against flooding events, considering the latest climate scenarios" (page 143).

Uncertainty. The assurance report records that the resilience information "is based, among other things, on climate-related scenarios, which are subject to inherent uncertainty regarding the likelihood, timing or impact of potential future natural and transient climate-related impacts" (page 394). AIA itself flags the age and limited scope of the 2018 work and states "the resilience analysis will be updated ... based on the outcomes of the new study initiated in 2025 and due to be completed by January 2027" (page 143).

Policies related to climate change mitigation and adaptation

Reference: pages 191-192; Policies Overview Table 9, pages 145-154.

Three policies carry the climate commitments (pages 191-192):

• Environmental Policy - "outlines AIA's commitment to continuously improving environmental performance by preventing or minimising impacts arising from airport development and operations. Its objectives include reducing GHG emissions, enhancing sustainability, and managing material impacts and regulatory compliance risks." It applies to all AIA employees, management, contractors and organisations operating at the airport, is endorsed by the Managing Director (CEO), with the Manager of Environmental Services accountable for implementation, and is public on the corporate website. It is implemented through an Environmental Management System certified to ISO 14001:2015.
• Sustainability Policy - covers GHG reduction, resource efficiency and responsible business practices.
• Energy Policy - "aligned with third-party standards such as ISO 50001:2018, the Airport Carbon Accreditation (ACA) program, and national requirements under Greek Law 4342/2015", supported by an Energy Management System certified to ISO 50001:2018 covering electricity and natural gas across buildings and services.

On adaptation, "The Policies also address climate change adaptation, requiring ongoing monitoring of environmental conditions, the identification of vulnerabilities and the management of emerging challenges" (page 191), with the Airport Emergency Plan named as an implementing instrument.

The MDR-P table lists the climate policies against IRO codes E1.I1, E3.I1 and E1.R1, with the Manager, Procurement and Manager, Environmental Services as accountable owners (page 148).

Actions and resources in relation to climate change policies

Reference: pages 192-194; resources Table 24, page 194.

ROUTE 2025 levers (page 190): "operation of a 35.5MWp photovoltaic station with battery storage, reducing Scope 2 emissions through the substitution of grid electricity with renewable energy produced onsite; electrification of AIA's vehicle fleet, contributing to the reduction of Scope 1 emissions; replacement of natural gas heating units with heat pumps, further reducing Scope 1 emissions."

Climate Change Corporate Action Plan (CCCAP), in the Corporate Scorecard "since 2009". 2025 actions: lighting upgrades across all buildings and outdoor areas, virtualisation of physical servers, and IT&T energy-saving initiatives (page 193). Quantified where available: "The indoor lighting upgrade is estimated to have delivered a medium-level reduction of 100-999tCO2, while outdoor lighting upgrades are estimated to have reduced energy consumption by 1,033.96MWh per year, representing a 66.99% reduction" (page 193). "CCCAP actions were financed through AIA's internal capital expenditure (CapEx) budget... No sustainable finance instruments were used during the reporting period."

Scope 3 actions (pages 193-194): additional third-party EV charging infrastructure; a Sustainability Support Scheme giving "a modulated discount on the Passenger Terminal Fee (PTF) per departing passenger, calculated according to the fuel efficiency of the aircraft"; and a SAF Working Group, after which "fuel suppliers at Athens International Airport supplied SAF slightly exceeding the 2% blend mandated for 2025 by the ReFuelEU Aviation Regulation". AIA also participates in the EU-funded STARGATE project.

Resources (Table 24, page 194): outdoor lighting EUR 519,945 current and EUR 330,055 future; indoor lighting EUR 485,639 current and EUR 1,290,645 future; cloud migration EUR 787,000 future; process digitalisation EUR 23,000 future; STARGATE EUR 59,787 current.

Targets related to climate change mitigation and adaptation

Reference: pages 194-195.

AIA's mitigation target is framed as an outcome of ROUTE 2025 rather than a dated reduction percentage: "With respect to climate change mitigation, AIA has completed the suite of energy projects comprising the ROUTE 2025 initiative, establishing the equipment and infrastructure required to achieve Net Zero Scope 1 and Scope 2 emissions" (page 194). Achieved reduction against the 2010 baseline is more than 90% for Scope 1 and 2 (page 189).

No Scope 3 target is set. "Currently, AIA has not set a quantitative reduction target for Scope 3 emissions. This will be assessed in the context of AIA's planned progression to Level 5 of the Airport Carbon Accreditation (ACA) program, which requires participating airports to commit to achieving Net Zero Scope 3 emissions by 2050, supported by interim science-aligned targets. Work toward meeting these requirements will guide AIA's future target-setting framework" (page 194). The Reference Table records "Par 34(a), 34(b) are not applicable as AIA has not set reduction targets on Scope 3 emissions" (page 254).

Target-setting inputs are listed: "changes in passenger traffic and operational demand, evolving regulatory requirements, and technological progress, including advances in SAF availability, the electrification of ground operations, low-carbon airport infrastructure and the collective progress made within the airport community and aviation value chain" (pages 194-195).

No adaptation target is stated; adaptation is managed through the studies and the stormwater network described under the resilience section (page 143). Note that no interim milestone years, no base year for a forward target and no SBTi validation are disclosed anywhere in the statement.

Energy consumption and mix

Reference: pages 195-197; Table 25, page 196.

Total energy consumption 86,147.64MWh in 2025, down 4.68% from 90,380.03MWh in 2024 (Table 25, page 196).

Coal, other fossil fuels, purchased fossil-sourced electricity and renewable fuel consumption are all zero.

"AIA ensures that all electricity purchased from the grid ... has been matched with the purchase of Guarantees of Origin (GOs), zeroing out its Scope 2 market-based emissions. The amount of renewable energy AIA produced through its on-site photovoltaic installations for self-consumption purposes in 2025 was 37,691.53MWh" (page 195).

Energy intensity in high climate impact sectors: 0.000127MWh/EUR excluding the Airport Expansion Program accounting treatment (2024: 0.000136) and 0.00011172MWh/EUR including it, on net revenue of EUR 735,058,867 including and EUR 675,552,858 excluding AEP (pages 195-196).

The Reference Table records "Par 37(b) is omitted as not applicable / not material for AIA" (page 254).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 197-201; Table 26, page 197.

Scope 3 is 99.5% of the location-based total. Largest categories: use of sold products 3,606,209tCO2eq and fuel and energy-related activities 8,259tCO2eq (down 74.4%); purchased goods and services rose from 111 to 6,245tCO2eq. Categories 2 (997tCO2eq) and 13 (19,200tCO2eq) are reported "first included in 2025" with no FY2024 comparative (pages 197-199). Categories reported are 1, 2, 3, 5, 6, 7, 11 and 13; "Scope 3 categories not included in the inventory (i.e., Category 4, 8, 9, 10, 12, 14 and 15) are excluded due to materiality considerations" (page 199). Primary data was used only for categories 2, 3, 6 and 13.

Restatements (page 197): the 2024 Scope 2 figure was corrected from 24,316tCO2eq to 16,153tCO2eq, and 2024 Scope 3 was recalculated on actual data.

Market-based method: GOs cover grid purchases; "the percentage of contractual instruments used for the consumed electricity is 63.71%", with an open tender for a further 33,700MWh of GOs at the time of reporting (page 198). Calculations use ACI's ACERT tool (page 198).

Intensity (Table 27, page 199): 0.0050tCO2eq/EUR including AEP and 0.0054tCO2eq/EUR excluding it, on both bases. Zero Scope 1 emissions fall under an emissions trading scheme. GHG figures were not externally verified for 2025 (page 197 footnote).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 201.

AIA reports carbon credits, not removals in its own value chain. The Reference Table records "Par. 56 (a), par. 58 (a) and Par. 58 (b) are not applicable to AIA, as there are not GHG removals and storage in own operations or value chain for FY25" (page 255).

"AIA purchases carbon credits to counterbalance its residual greenhouse gas (GHG) emissions, in accordance with the requirements of the Airport Carbon Accreditation (ACA) program. All credits procured by AIA comply with the quality criteria set out in the Airport Carbon Accreditation Carbon Offset Requirements, Issue 2 (June 2025)" (page 201).

Quantities and timing (page 201):

• 2025 residual emissions: "4,755tCO2eq" of carbon removal credits to be purchased, "corresponding to the combined total of AIA's Scope 1 and business travel emissions for the year". "The tender process to procure these credits is expected to conclude in the 2nd quarter of 2026."
• Guarantees of Origin: "The estimated volume of GOs to be purchased for 2025 is 33,700MWh."
• 2024 comparatives: "the Company purchased 5,039tCO2eq of carbon offsets and 43,881MWh of GOs".

"AIA is transitioning from carbon avoidance offsets to carbon removal credits, in line with evolving best practice" (page 201). AIA was "first certified as carbon neutral under the ACA program in 2016, following verification of its 2015 residual emissions", and states that its "GHG neutrality claims relate to its emissions up to and including 2024 and have been independently verified". Credits "are used solely to neutralise residual emissions that cannot currently be eliminated".

Policies related to water and marine resources

Reference: pages 202-203.

"AIA's commitment to responsible water management is articulated in its Environmental Policy, which sets out AIA's broader environmental responsibilities and its objective to continuously improve overall environmental performance" (page 202).

The operational instrument is an internal Water Management Process whose "objectives ... include promoting water conservation, implementing water-saving initiatives and ensuring ongoing compliance with applicable environmental standards" (page 202). Its scope "covers the monitoring of potable water, groundwater, surface water, and wastewater quality at selected areas, as well as potable water consumption across the airport. It encompasses all airport operations, including upstream and downstream activities, and involves key stakeholder groups such as third-party contractors and all airport community members."

Accountability is split by asset (pages 202-203): "The procedures related to potable, irrigation and firefighting water are authorised by the Chief Development Officer (CDO). The Energy & Asset Management Department is accountable for their implementation. The STP & IWTF procedure is authorised by the Chief Operating Officer (COO), while the Manager of Environmental Services, is accountable for its implementation."

AIA links the policy to local water stress: "Recognising that Athens is a water-stressed area, AIA's Environmental Policy and Water Management Process inherently support the reduction of water consumption across its own operations and the wider value chain" (page 203). The Reference Table marks E3-1 as derived from other EU legislation and records that paragraphs 12(a)iii, 12(b) and 14 "were deemed not material, as per the outcome of the DMA for marine resources" (page 256).

Actions and resources related to water and marine resources

Reference: pages 203-204.

Treatment and monitoring (page 203). "In 2025, AIA carried out planned monitoring of groundwater and surface water" and "continued operation of its STP and the Industrial Wastewater Treatment Plant (IWTP), ensuring that treated effluent met the required quality standards for safe reuse in non-public irrigation areas." Surface water quality is monitored by ad hoc sampling during rain events and by the Online Water Monitoring System before offsite discharge (page 202).

Resources (page 203). "During 2025, AIA made significant investments to maintain and improve water-related infrastructure, including the upgrade and maintenance of AIA's Water Telemonitoring System and the refurbishment of the IWTF and STP. Specifically, a total amount of approximately EUR 430,000, including both capital and operational expenditure, was allocated for these upgrades." For 2026: "approximately EUR 1,290,000 in planned capital expenditures and approximately EUR 470,000 in operational expenditures", with an intention to investigate upgrading the STP to tertiary treatment.

Consumption optimisation (page 204). "AIA is exploring the prospect of defining measurable targets to improve water management performance... To support this effort, AIA is developing a Water Management Plan, with the associated roadmap expected to be completed within 2026. As part of this work, a gap analysis is underway to identify and assess the actions needed to align AIA's existing Water Management System with the requirements of ISO 46001, supporting future certification."

Context on water stress is given twice and inconsistently: page 203 states "the groundwater status currently does not meet the criteria for water stress", while page 204 states that AIA's location in Athens is "classified as high-water-stress (>80%) according to the Aqueduct Water Risk Atlas of the World Resources Institute".

Targets related to water and marine resources

Reference: page 204.

AIA reports the absence of targets and the reason, which is a complete answer under MDR-T: "AIA has not yet established formal water-related targets, as these will be defined upon completion of the Water Management Plan and the ongoing gap analysis, both of which are scheduled for finalisation in 2026" (page 204).

Effectiveness in the meantime is tracked through monitoring rather than a target: "While the gap analysis remains in progress, AIA continues to monitor and analyse water-related data through its established Water Management Procedure, ensuring that both consumption and water quality remain fully compliant with applicable legislative thresholds" (page 204).

AIA sets out what the future targets will rest on: "This continued monitoring provides the foundation for the development of future quantitative targets, which will be informed by a structured understanding of water use patterns, operational needs, and local water-stress conditions. The output of the Water Management Plan will guide AIA in setting evidence-based, measurable and time-bound targets, supporting long-term improvements in water efficiency and responsible resource management" (page 204).

The Reference Table lists E3-3 against the chapter "Water-related Targets [E3-3]" with no omission comment (page 256). No baseline year, target value or target date is disclosed for FY2025, because none has been set.

Water consumption

Reference: pages 204-205; Table 30, page 205.

"In 2025, AIA recorded a total water consumption of 452,119m3, all of which occurred within areas classified as high-water-stress zones, including the wider Athens region" (page 204). Note: the narrative figure of 452,119m3 does not agree with the 452,190.00m3 in Table 30 on page 205; the table figure is used above.

Reuse exceeds consumption: "During the reporting year, AIA reused 459,660m3 of water derived from the outflow of its Sewage Treatment Plant, which was subsequently utilised for irrigation purposes. This reuse rate exceeds the volume of water consumed, as the STP receives and treats wastewater from all third parties operating on AIA's premises" (page 204).

Groundwater: "Groundwater extraction remained minimal, with 963.80m3 abstracted in 2025 against a licensed allowance of 180,000m3", all of it from local aquifer basins and used exclusively for irrigation. AIA cites the "1st Update of River Basin Management Plans - River Basin District of Attica (EL06)", under which "the Mesogheia aquifer is classified as having poor chemical status but good quantitative status" (page 204).

Restatement: total water stored for 2024 was restated from 15,450m3 to 4,200m3 after an erroneous calculation that included water used for cleaning and flushing (pages 91, 205). Water data comes from EYDAP plus third-party consumption processed by the Energy & Asset Management Department; measurement uncertainty arises from "averaging data from sample sites" (page 91).

Policies related to own workforce

Reference: pages 206-207, 214, 217, 220-222; Policies Overview Table 9, pages 145-154.

The workforce policy set is disclosed across four sub-sections plus the MDR-P table:

• Human Rights Policy - "reflects a zero-tolerance approach to any form of human rights violation and aligns with Greek and EU legislation as well as international frameworks, including the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises, and the UN Global Compact" (page 206). The Board holds ultimate accountability; implementation is coordinated by the Director of Human Resources and the Director of Legal Affairs & Corporate Governance.
• Compensation Policy - defines job descriptions, evaluation methodology, grading, fixed and variable pay and benefit eligibility, with annual benchmarking against external market data (page 214).
• Training & Development manual covering needs identification, the annual training plan and upskilling and reskilling, plus a separate Training Policy for the Members of the Board of Directors and Senior Executives (page 217).
• Workplace Violence and Harassment Prevention Policy, implemented under Greek Law 4808/2021 Part II, which "strictly prohibits all forms of violence and harassment, including sexual and gender-based harassment"; in 2025 the recruitment policy was formalised as the Staffing and Recruitment Framework Corporate Procedure (page 220).
• Occupational Health & Safety Manual (OHSM) "in accordance with EN ISO 45001 guidelines", and the OHS Incident Reporting and Investigation Policy aligned with Laws 3850/2010 and 1568/1985 (pages 221-222).

Policies are held on the corporate Intranet, with the Human Rights Policy, Whistleblowing Policy and Codes also public on the website (page 207).

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

Reference: pages 211-212.

Employee Opinion Survey. "AIA systematically incorporates employee perspectives into workforce management through ongoing direct engagement mechanisms, including an anonymous online Employee Opinion Survey (EOS), which is conducted biennially." "Based on the 2024 Employee Opinion Survey (EOS), in which 86% of employees participated and an engagement score of 81% was achieved among respondents, as well as insights gathered through employee focus groups, AIA developed a targeted action plan" implemented through 2025 (page 211).

2025 initiatives from that plan: quarterly "Coffee with the CEO" meetings, a Management Summit expected to recur annually, thematic employee focus groups, and structured Departmental walkthroughs by management (page 211).

Worker representation. The Occupational Health and Safety Committee "operates in full compliance with Law 3850/2010. Its members are biennially elected by AIA personnel... The Committee meets quarterly, providing a structured platform for dialogue and collaboration between management and workforce representatives" (page 211).

Collective bargaining. "AIA engages employees in the negotiation of labour terms through the annual establishment of a Collective Labour Agreement. In accordance with Article 4 of Law 1876/1990, the negotiation process is initiated by the Employees Union's representatives" (pages 211-212). The Union was established in 1999 and agreements have been negotiated annually since 2000 (page 125).

AIA states that "no additional engagement processes are applied specifically to vulnerable or marginalised employee groups beyond those described above" (page 212). Overall responsibility rests with the Director of Human Resources.

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

Reference: page 222; grievance mechanism pages 206-208.

OHS incident remediation (page 222). "All OHS incidents are reported and investigated in a timely manner in order to identify root causes, contributing factors, and responsibilities. Incidents are classified by severity and cause to support appropriate remediation actions and reporting. Based on the findings of investigations, AIA implements corrective measures aimed at preventing recurrence, which may include adjustments to working conditions, enhancement of safety controls, equipment upgrades, or revisions to operating procedures."

Support is specific: "Employees affected by OHS incidents receive immediate first aid and emergency response support, coordinated with the airport's emergency medical services (EKAB) and Fire Department, as well as access to psychological support through HELLAS EAP. In cases involving injury or fatality, support and compensation are provided to affected employees or their families, in accordance with applicable legal provisions." Incidents and trends are reported to the Board and the Board of Executives quarterly.

Channels (page 222). Concerns "may be reported verbally or in writing through the line management hierarchy or directly to designated functions, including the Director, Legal Affairs & Corporate Governance, the Director, Human Resources, or the Manager, Internal Audit. All reports are handled confidentially, with the identity of the reporting individual protected in line with the Whistleblowing Policy."

The Whistleblowing Investigation Committee administers the grievance mechanism, with "voice messages, email forms, and secure online submissions, with the option for a personal interview" and case records "anonymised upon closure" (page 207). "AIA also uses employee opinion surveys to assess awareness of, and trust in, the reporting channels and their effectiveness" (page 222).

Taking action on material impacts on own workforce

Reference: pages 214-215, 217-218, 220, 222-223.

Wages and employment security (pages 214-215). The Compensation Policy, the annual Collective Labour Agreement, the Corporate Procedure on Working Time Schemes and the Employees Leaves and Absences Procedure. The "Life in Balance" well-being programme covers shift and non-shift employees and in 2025 included the Wellness Gate fitness facility, functional movement assessments, on-site nutritionist consultations, online health webinars, a new stress management e-learning programme and a 24/7 Employee Assistance Program. "Overall participation in well-being, social, and professional development initiatives in 2025 exceeded 50%." Employees donated 86 units of blood in 2025.

Training (pages 217-218). "In 2025, AIA made a significant investment in training, with total training operation costs amounting to EUR 436,317.93 compared to EUR 315,038.93 in 2024... For 2026 AIA has allocated EUR 450,000 in planned capital expenditures for training programs." Board members completed all corporate governance e-learning plus sessions on Strategy, Artificial Intelligence, Corporate Governance and Sustainability.

Harassment prevention (page 220). Enhanced training rolled out in 2025 with completion rates of "87% for Workplace Harassment, 86% for Whistleblowing and 88% for Anticorruption training". AIA sponsored the WHEN Career Fair and inc.lude Conference (24-25 January 2025) with EUR 3,500, and ran a structured discussion on International Women's Day.

Health and safety (pages 222-223). Annual OHS courses on office safety, baggage handling system safety, terminal services operations and technician safety, delivered on hiring and on assignment; OHS risk assessments and inspections; "Safety annexes are included in tenders and contracts".

Targets related to own workforce

Reference: pages 215, 218, 221, 223.

Only one quantified workforce target is set, and AIA states plainly where targets are absent.

Training hours per FTE (page 218). "For 2025, the target was set to provide between 37.09 and 43.93 training hours per FTE." The baseline method is described: "Rather than relying on a fixed historical base year, AIA defines the 'On Target' baseline annually based on the average performance of the past seven years... The 'Outstanding' performance level (score 5) is determined by the average of the top three annual results achieved over the same period. Employees are not involved in the target-setting process." Progress is monitored quarterly through the Corporate Operational Scorecard. "In 2025, AIA achieved outstanding performance, delivering a total of 54,974 training hours, corresponding to 60.63 training hours per FTE, thereby surpassing the established target range."

Adequate wages (page 215). "During the 2025 reporting period, the Company did not establish specific, measurable targets explicitly focused on adequate wages", relying instead on annual benchmarking against Greek industry peers and alignment with "upper-quartile market remuneration standards".

Harassment prevention (page 221). "While the Company has not set specific, measurable quantitative targets in this area, it assesses performance using key metrics, including the number of severe human rights incidents involving its workforce and the total amount of fines, penalties or compensation for damages."

Health and safety (page 223). "AIA has not established specific numerical targets for workplace Occupational Health and Safety (OHS). The effectiveness of its OHS management practices is instead monitored through key performance indicators, with a continued qualitative objective of zero (0) incidents."

The Reference Table records "Par. 44 (c) does not apply as AIA does not have material risks and opportunities" (page 260).

Characteristics of the undertaking's employees

Reference: pages 212-214; Tables 33 and 34.

Headcount 879 at 31 December 2025, up 6.03% from 829 (Table 33, page 212): 557 male (+3.72%) and 322 female (+10.27%).

"The number of non-guaranteed-hours employees is zero (0)" and every employee is full-time (Table 34, page 213).

Turnover (page 214): "A total of 35 (34 in FY2024) employees left AIA during the reporting period, due to resignations, retirements, and dismissals, resulting in a 4.13% (4% in FY2024) turnover rate", calculated "using the average annual headcount of permanent employees as the denominator, excluding seasonal staff".

Methodology: "Data compilation methods define headcount as employees actively employed on December 31, 2025 and 2024 respectively... include both open-ended and contracted employees, while excluding those hired as maternity replacements. The data was sourced from the Human Resources Information System (HRIS)", and "This data can be cross-referenced with Paragraph 1.1 in AIA's Financial Statements" (page 212).

No country breakdown is given because AIA operates as a single entity at Spata, Greece (page 138). The Reference Table records "Par. 50 (b) iii. constitute conditional disclosures that do not apply" (page 260).

Characteristics of non-employee workers

Reference: page 214.

AIA reports a single figure with a definition. "For the reporting period, the total number of non-employees in AIA's workforce is 28 compared to 17 in FY2024" (page 214), an increase of 64.71%.

The footnote defines the population: "The number of non-employees includes temporary personnel subcontracted by external service providers and not directly employed by AIA. Headcount is recorded at the end of the reporting period, in accordance with ESRS S1 reporting requirements for workforce metrics" (page 214). The scoping section adds that AIA's workforce "includes open-ended (permanent) employees, fixed-term employees, and non-employees, such as subcontracted workers engaged through third-party providers", with the ESRS definition of non-employees quoted in full, covering self-employed people and people provided by undertakings primarily engaged in employment activities under NACE Code N78 (page 209).

Non-employees are also carried through the health and safety metrics: all 28 are covered by AIA's Health and Safety Management System (100%), with zero fatalities, zero recordable accidents, a 0.00% accident rate and 36,448.25 hours worked in 2025 (Table 37, page 224).

The Reference Table records "Par. 55 (c) and 57 constitute conditional disclosures that do not apply" (page 260). No breakdown by gender or contract type is given for non-employees.

Adequate wages

Reference: page 215.

AIA reports its approach to adequate wages rather than a benchmark percentage. "AIA is dedicated to providing fair and equitable remuneration across its workforce, in full compliance with applicable labour legislation. Minimum salary thresholds are reviewed and determined annually as part of AIA's salary planning process. The salary plan is approved by the Managing Director (CEO), the Chief Financial Officer (CFO), and the Director of Human Resources, ensuring robust governance and oversight" (page 215).

On competitiveness: "AIA remains committed to attracting and retaining highly qualified employees and contractors by systematically benchmarking its compensation practices against industry peers in Greece. Through this process, AIA seeks to ensure alignment with upper-quartile market remuneration standards, reflecting best practices in the sector" (page 215).

The underlying framework is the Compensation Policy, which "maintains a structured job evaluation system based on a globally recognised methodology, with clearly defined job grades and salary ranges, to support fairness and prevent discrimination", with annual benchmarking against external market data (pages 210, 214). The annual Collective Labour Agreement "outlines agreed general salary adjustments levels and employee benefits in accordance with applicable labour legislation" (page 214).

The Reference Table lists S1-10 against the chapter "Adequate Wages Performance [S1-5, S1-10]" with no omission comment (page 260). AIA does not state the percentage of employees paid at or above an applicable adequate wage benchmark, nor identify the benchmark used.

Social protection

Reference: page 216.

AIA reports coverage across the five ESRS-listed events plus parental leave. "Specifically, employees are protected against income loss arising from sickness, unemployment, retirement, occupational injury, acquired disability and parental leave, through mandatory social security contributions and other public social protection programs, in accordance with Greek legislation" (page 216).

Supplementary cover is described: "Since July 2021, AIA has established an occupational retirement fund (IORP), providing supplementary pension coverage through monthly employer contributions, in addition to statutory primary and supplementary social security benefits. Participation in the occupational fund is voluntary and is open to all AIA employees holding either an open-ended employment contract or a paid mandate" (page 216).

"Beyond public social protection, AIA offers a comprehensive private group insurance program, providing additional coverage for life, accident, disability, sickness, and loss of income... Dependants, including spouses and children, are also covered for both hospital and non-hospital healthcare expenses under the group insurance scheme" (page 216).

Non-employees: "Non-employees are covered by their direct employers and are subject to the same national social protection regulations applicable under Greek law" (page 216).

The Reference Table records "Par. 75 constitutes a conditional disclosure that does not apply for AIA" (page 260), that paragraph being the requirement to identify countries where employees are not covered. No numerical count of employees lacking coverage is given, consistent with universal statutory coverage in Greece.

Persons with disabilities

Reference: page 216.

AIA reports a single percentage together with the legal constraint that shapes it. "Consistent with the applicable legal framework in Greece, which restricts the collection of certain categories of employee data, 0.90% of AIA's employees have voluntarily self-identified as persons with disabilities. This information supports AIA's broader monitoring of diversity, equal treatment, and non-discrimination across the organisation" (page 216).

The footnote sets out how the figure is derived and its limits: "This data reflects employees who have applied for Special Leave for employees with disabilities, as required by labour regulations. To qualify, employees must provide the necessary documentation. The Airport Company does not require proof of physical ability for employment, and disclosing a disability is voluntary, with no assumptions made. The degree and duration of the disability are determined by the relevant Social Security Authorities, and the Company does not conduct additional validation" (page 216).

The Reference Table lists S1-12 against the chapter "Monitoring Performance on Workplace Violence and Harassment Prevention [S1-5, S1-12]" with no omission comment (page 260). No breakdown by gender is provided and no prior-year comparative is given for this metric.

Training and skills development metrics

Reference: pages 218-219; Tables 35 and 36.

Performance reviews (Table 35, page 219):

The denominator is defined: "the total number of employees eligible for a review, which includes open-ended employees with six or more months of service", and the metric "is not validated by an external body" (page 219).

Training hours (Table 36, page 219):

Training hours cover "in-person workshops, online courses, and on-the-job training", tracked in the HRIS with internal quality checks, and are "not subject to external validation" (page 219). AIA attributes the 19.31% rise in total hours partly to workforce growth and "a significant share of on-the-job training activities" (page 218).

Health and safety metrics

Reference: pages 223-224; Table 37.

"AIA's Health and Safety Management System meets legal requirements and recognised standards, providing full coverage for all employees. As shown below, 100.00% of the workforce is covered" (page 223), for both the 879 employees and the 28 non-employees.

"In total, AIA reported six work-related accidents in 2025, resulting in a 3.29% accident rate, which corresponds to a 6.8% decrease compared to the previous reporting year and 102 days lost, compared to 60 days in FY2024. The increase in absence days in 2025 is driven by two isolated incidents that, while not severe, required longer medically advised recovery periods. Moreover, there were no fatalities or work-related ill-health cases among employees, non-employees, or workers across AIA's value chain" (page 223).

Metrics are tracked under the Incident Reporting and Investigation Procedure; "While not externally validated, AIA's Internal Audit team ensures the accuracy of the data", and the management system "has been internally audited and/or audited or certified by an external party" (page 224). The Reference Table records "Par. 34 constitutes a conditional disclosure that does not apply" (page 259).

Incidents, complaints and severe human rights impacts

Reference: pages 208-209; Table 31.

The single incident is described: "During the reporting period, one whistleblowing report was submitted and was investigated in accordance with AIA's Whistleblowing Policy, the Whistleblowing Committee's Charter, and AIA's Policy on the Prevention of Violence and Harassment at Work. The Whistleblowing Committee resolved that the report was partially substantiated and ensured that appropriate actions were taken to address the findings, reinforce preventive controls and uphold the Company's commitment to EU Workplace Harassment standards, Law 4808/2020 and the Company's respective policy" (page 208).

"Other than this incident, no complaints concerning Own Workforce-related sustainability matters, excluding harassment, were submitted by AIA's workforce through the established reporting channels" (page 208).

Value chain context: "no instances of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises were reported in 2025 in relation to AIA or its upstream and downstream value chain" (page 208). The Reference Table marks S1-17 as derived from other EU legislation (page 261).

Policies related to value chain workers

Reference: page 225; human rights pages 206-208.

The governing instrument is the same manual that covers AIA's own workforce: "AIA has implemented policies to address material impacts on value chain workers. The Occupational Health and Safety Manual (OHSM), described in section 'Policies related to Health and Safety for AIA's Workforce', applies to all workers across the value chain. It defines roles and responsibilities, procedures for risk management, and mechanisms for reporting incidents or near misses. The OHSM is accessible to all value chain workers through their employers" (page 225).

The Human Rights Policy extends to the value chain: "AIA expects its suppliers to adhere to the same values and standards outlined in its Human Rights Policy, which protects labour and human rights for all workers, including those within its value chain" (page 207). It addresses "working conditions, health and safety, prevention of violence and harassment, freedom of association and collective bargaining, prohibition of trafficking, forced compulsory labour or child labour, and protection of personal data and privacy" (page 206).

The Business Partners' Code of Conduct "ensures AIA's partners adhere to ethical, sustainable practices, covering areas such as integrity, governance, anti-corruption, labour rights, health and safety, and environmental management. It aligns with the OECD Guidelines, the UN Global Compact (UNGC), and ILO Standards" and is public on AIA's website, with "compliance ensured through documentation, specific terms, and ongoing audits" (page 207).

An ESG clause is included in supplier agreements, covering 1,094 suppliers in the reporting period (page 108). The Reference Table records "Par. 11 (a) iv., 11 (b), and 11 (d) constitute disclosures that are not relevant to AIA operations. Par. 10 (b), 11 (e) and 13 do not apply as there are not material risks and opportunities" (page 263).

Processes for engaging with value chain workers about impacts

Reference: page 225.

Engagement is indirect, through employers, and AIA says so: "AIA ensures value chain workers have a voice in Health and Safety matters by providing them with representation through their employers at the established forums, (i.e., Airside Safety Committee, Working Groups, Safety Awareness Sessions, Safety Events, Health & Safety Coordination Meetings etc.). This allows the active engagement and contribution of all relevant stakeholders" (page 225).

A direct reporting route also exists: "Additionally, value chain workers can report near-miss incidents or accidents via the Health and Safety reporting platform, allowing AIA to be promptly informed of serious cases that require further evaluation or investigation" (page 225).

The contractual basis is stated: "It is a contractual requirement for every entity within AIA's value chain to fully uphold and respect the rights of the individuals they engage with" (page 225).

Frequency is given in the S2-4 section: eleven Airside Safety Committee meetings were held in 2025 with ground handlers, airlines and state entities, and "quarterly OHS coordination meetings are conducted with all third parties operating within the airport community" (page 227).

AIA does not name a senior person with operational responsibility specifically for value chain worker engagement, nor does it report assessing the effectiveness of this engagement with the workers themselves.

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

Reference: pages 225-226.

"AIA is committed to transparency and accountability in addressing potential negative impacts on workers within its value chain. Its approach to remediation mirrors the processes applied to AIA's own employees, guided by the Human Rights Policy, Code of Business Conduct, and Whistleblowing Policy, all of which apply equally to value chain workers" (pages 225-226). The S1-3 incident reporting, investigation and remediation process "applies equally to workers in AIA's value chain" (page 226).

Channels named (page 226): the whistleblowing system administered by the Whistleblowing Investigation Committee, "Additional publicly available channels (Corporate | AIA; Contact with Athens Airport | AIA), as well as operational processes available via the corporate Intranet (e.g., Handling of AIA's Liability Claims process)". The Whistleblowing Policy "applies to the Board of Directors, Management, employees, and business partners without exception", prohibits retaliation, and anonymises personal data on case closure (page 207).

Procurement is the route by which requirements reach third parties: "The Procurement Department (PRC) is involved in the tender process, ensuring that third parties are informed of AIA's Occupational Health and Safety (OHS) policies and requirements. Each Project Manager (PM) is responsible for ensuring that these provisions are implemented and upheld throughout the lifecycle of relevant projects" (page 226).

On incidents: "In the event of an accident, AIA conducts analyses to identify root causes and any underlying systemic issues that require corrective action" and "Transparent communication with affected individuals and stakeholders is prioritised" (page 226). AIA does not report whether value chain workers are aware of or trust these channels.

Taking action on material impacts on value chain workers

Reference: pages 226-227.

Training (page 226). "AIA delivers training to third-party employees within the Airport Community through a 'Train the Trainer' approach, with emphasis on basic ground handling regulations and occupational safety standards. This initiative aims to reduce safety incident risks by ensuring that third-party representatives operating at the airport are adequately informed and trained. In addition, tailored OHS awareness programs are delivered for specific job roles and risk profiles."

Audits (page 226). "In 2025, six (6) Aviation Safety Management System audits of ground handling operators were carried out in collaboration with the Corporate Health & Safety function, in alignment with EASA, ICAO, and national aviation safety requirements."

Coordination (page 227). "During the reporting period, eleven (11) Airside Safety Committee meetings were held with airport stakeholders, including ground handlers, airlines, and state entities. In addition, quarterly OHS coordination meetings are conducted with all third parties operating within the airport community."

Resources (page 226). "AIA allocates appropriate financial and human resources to support OHS management across the value chain, including dedicated budgets for training, audits, modern safety equipment, and contingency arrangements to enable timely incident response. Qualified OHS professionals play a key role in the implementation, monitoring, and continuous improvement of these measures." No monetary amount is given.

Risk identification uses the Written Occupational Risk Assessment (WORA) to "systematically identify these risks and prioritize mitigation measures" (page 225). The Reference Table records "Par. 34 (a), 34 (b) and 31 (b) do not apply as there are not material risks and opportunities. Par. 37 is not applicable for AIA as no targets have been disclosed in relation to ESRS S2" (page 264).

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

Reference: page 227.

AIA discloses the absence of targets and the reason, which is the MDR-T alternative limb. The section is short and complete: "AIA has not set specific targets for the health and safety conditions of workers in its value chain, as these workers are employed and managed by third parties. The effectiveness of AIA's practices is instead monitored through key measures, with a continued qualitative objective of zero (0) incidents" (page 227).

The measures relied on in place of a target are reported elsewhere in the S2 chapter and in the health and safety metrics: six Aviation Safety Management System audits of ground handling operators, eleven Airside Safety Committee meetings and quarterly OHS coordination meetings with all third parties in 2025 (pages 226-227), and the value chain outcome that "There have been no work-related fatalities or incidents of ill health among workers in AIA's value chain" (page 223). For the 28 non-employees in AIA's own workforce, Table 37 records zero recordable accidents, a 0.00% accident rate and 36,448.25 hours worked (page 224).

The Reference Table confirms the position: "Par. 39 (a), 39 (b), 39 (c), 42(a), 42(b) and 42(c) do not apply as AIA does not have targets" (page 264). No value chain worker representative is reported as involved in setting or tracking these measures.

Policies related to affected communities

Reference: pages 228-229; human rights pages 206-208.

Three instruments carry the community commitments:

• Environmental Policy - "AIA is committed to reducing its environmental impact through its Environmental Policy, which prioritizes environmental protection, noise pollution prevention, and the minimisation of disturbances to local communities, recognizing that complete elimination of certain impacts, such as aircraft noise, is not always feasible due to the nature of airport operations" (page 228).
• Sustainability Policy and the annual publication Care for the Environment, which "highlight the Company's ongoing initiatives to manage its environmental impacts and outline its approach to addressing material impacts on affected communities" (page 228).
• Sponsorships and Donation Policy - its objectives "include advancing social partnerships, supporting cultural initiatives, contributing to tourism, providing humanitarian assistance and maintaining AIA's 'social licence to operate'". Governance is split: "the Managing Director (CEO), who sets the guidelines for sponsorships and donations, and the Chief Operating Officer (COO), who is responsible for defining the strategy and approving the community engagement plans", with the Director, Communications & Marketing overseeing implementation (page 229).

The Human Rights Policy "sets out the Company's commitments to respecting the rights of local communities and guiding its Corporate Social Responsibility (CSR) initiatives" and underpins the Community Engagement Plan (page 206). "AIA's policies do not include specific provisions for indigenous people, as there are no indigenous people in the vicinity of the airport" (page 207).

The Reference Table records that "Par. 8 (b), 9 (d), 11 have been omitted because there are no risks or opportunities regarding affected communities" (page 265).

Processes for engaging with affected communities about impacts

Reference: page 229.

Volume of engagement is quantified: "In 2025, AIA conducted 332 structured engagements with local mayors, municipal officials, NGOs, associations, schools, and residents. These interactions enable the Company to understand local concerns and ensure that the perspectives of affected communities inform its decision-making and community programs" (page 229).

Operational responsibility is named: "The Environmental Services Department holds operational responsibility for ensuring that insights from community engagements are captured, communicated internally and integrated into AIA's management of community-related impacts" (page 229).

A gap is stated openly: "Although AIA has not yet established a formal mechanism to evaluate the effectiveness of stakeholder engagement, governance structures are in place to ensure that feedback from stakeholders is carefully considered, communicated internally, and incorporated into operational and strategic decision-making" (page 229).

Vulnerable groups: "To better understand and support vulnerable and marginalised groups in the surrounding area, AIA collaborates with the Social Services of the Municipality of Spata-Artemis to provide targeted assistance" (page 229).

Two further channels are described: WebTrak, which "gives local residents access to detailed flight tracking and measurement data from its Noise Monitoring System", and a 2025 survey of local communities "to assess the actual and perceived impacts of airport operations", designed "to capture the perspectives, needs, and expectations of affected residents systematically and to inform strategic planning" (page 229). The Reference Table marks S3-2 as derived from other EU legislation (page 265).

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 235; human rights pages 207-208.

Dedicated noise hotline. "A dedicated 'We Listen' telephone line (+30 210 3530003) operates on a 24/7 basis, enabling local residents to submit inquiries and complaints, primarily in relation to aircraft noise. All complaints received are forwarded to the competent authorities, including the Air Traffic Control of the Hellenic Aviation Service Provider (HASP), the Hellenic Civil Aviation Authority (HCAA), and the Ministry of Environment & Energy, for information and any follow-up actions falling within their respective mandates" (page 235).

Process and tracking. "To ensure consistent and timely handling of community feedback, AIA has established an inter-departmental procedure defining workflows, roles and responsibilities related to noise-complaint management. Feedback is systematically recorded, assessed and monitored through defined key performance indicators, such as the volume of comments and response times, supporting the identification of trends and recurring issues" (page 235).

Whistleblowing. "AIA's Whistleblowing Policy is also applicable to local community members, providing a confidential channel for reporting suspected legal or corporate misconduct and ensuring protection against retaliation in accordance with applicable legislation" (page 235). The Community Engagement Plan additionally "provides multiple channels for raising concerns, including a 24-hour hotline and online forms" (page 208).

A limitation is stated: "Although AIA does not currently conduct formal assessments of external stakeholders' awareness of, or confidence in, these mechanisms, all reports received are systematically monitored. Insights derived from this process support ongoing improvements to the mechanisms and related procedures" (page 235).

The Reference Table records "Par. 29 is not applicable for AIA" (page 265).

Taking action on material impacts on affected communities

Reference: pages 230-233, 235; Table 38.

Community Engagement Plan (page 230). In 2025 AIA "awarded high-performing students and provided scholarships to postgraduate students at the University of the Aegean", gave financial aid to families in need and to social and cultural associations, and continued preserving "the local Vravrona and Aliki Wetlands in partnership with the Hellenic Ornithological Society". To date, the Company has installed more than 600 new units in the Municipalities of Spata-Artemis, Koropi, Markopoulo, Paiania and Rafina." Support for the Palliative Care Centre "Galilee" continued "for the eighth consecutive year".

Local procurement (page 230). "During the reporting period, 93.00% of total procurement spend was directed to local suppliers, defined as suppliers established in Greece. Greek suppliers represented 86.00% of AIA's total supplier base."

Resources (page 230). "At the end of 2024, a provision of EUR 1,121,500 was recognised, of which EUR 749,994 was utilised for actions implemented during 2025. At the end of 2025, the corresponding provision amounts to EUR 500,000 (OpEx) relating to projects scheduled for implementation in 2026."

Noise mitigation (page 235). Noise Abatement Procedures cover "preferential runway use during the afternoon and night, aircraft engine testing, and Auxiliary Power Unit (APU) usage", revised on the basis of Strategic Noise Mapping and the Noise Action Plan. "In 2025, AIA allocated approximately EUR 109,000 to the operation and maintenance of NOMOS, with approximately EUR 120,000 budgeted for 2026."

The Reference Table records "Par. 34 (a), 34 (b) have been omitted because there are no risks or opportunities regarding affected communities" (page 266).

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

Reference: pages 234, 236.

No targets are set, and AIA says so: "AIA has not yet established quantitative targets for its socioeconomic impacts. Nevertheless, the Company systematically monitors and assesses its contribution to the economy and society through externally commissioned studies and ongoing stakeholder engagement" (page 234). "With regard to the Corporate Community Engagement Plan (CEP), no specific quantitative targets have been set to date. In 2025, the CEP comprised 17 actions, all of which were implemented as planned" (page 234).

Socioeconomic footprint (page 234). The most recent study, commissioned to the Foundation for Economic & Industrial Research (IOBE) and published in 2024, found that "AIA's activities generated an added value of approximately EUR 2.8 billion, corresponding to 2.60% of Attica's GDP, and supported around 37,000 jobs in the Attica region, representing 1.90% of total regional employment. the Airport's total contribution to GDP is estimated at EUR 8.6 billion, equivalent to 3.80% of Greece's total GDP in 2023."

Noise performance (page 236). Measurements are assessed against Joint Ministerial Decision 211773/27-4-2014 limits of "60dB(A) for night-time aircraft noise (23:00-07:00) and 70dB(A) for the 24-hour period. In 2025, based on the measurement results recorded at all permanent and mobile Noise Monitoring Terminals, none of these limits were exceeded." Complaints fell: "In 2025, the Company received 51 aircraft noise-related complaints, compared with 68 complaints in 2024."

The Reference Table records "Par. 39 (a), 39 (b) are omitted as the undertaking has not yet set any targets, 39(c) is omitted as there are no risks or opportunities regarding affected communities" (page 266).

Policies related to consumers and end-users

Reference: pages 239, 242-243; human rights pages 206-208.

Two policy strands are reported against two material S4 matters.

Safety of persons (page 239). "AIA's Safety Policy prioritizes aviation safety for efficient airport operations, emphasizing compliance with legal standards, best practices, and collective employee commitment to safety... Every employee, regardless of role, shares responsibility for safety with the Managing Director (CEO), as the Accountable Manager, holding ultimate accountability. The Safety Policy is accessible to all AIA employees." "Additionally, to manage Health and Safety impacts on passengers and visitors AIA leverages the implemented Health and Safety Management System and the Occupational Health & Safety Manual (OHSM)."

Customer satisfaction (pages 242-243). "AIA's commitment to delivering high-quality passenger experience is embedded in its Sustainability Policy, which includes explicit provisions related to customer experience." "To support effective implementation, AIA has established a Passenger Comment Management Procedure, which provides a structured process for receiving, recording, evaluating and responding to passenger feedback and concerns."

Rights of end-users (page 237). "The Company ensures that end-users are not subjected to services that violate their rights, including the right to privacy, the protection of personal data, freedom of expression and non-discrimination", with all personal data processed under the GDPR. "The Company does not engage in marketing, sales, or operational practices that exploit vulnerable groups, including minors or financially at-risk individuals." Passenger rights are safeguarded "through grievance mechanisms, compliance with GDPR, and adherence to EASA and ICAO safety standards" (page 208).

The Reference Table marks S4-1 as derived from other EU legislation (page 267).

Processes for engaging with consumers and end-users about impacts

Reference: pages 237-238.

Five continuous feedback programmes are described with sample sizes (pages 237-238):

• Passenger Survey - "collects feedback from approximately 40,000 passengers around the clock, capturing demographic data, travel patterns and overall satisfaction levels."
• Quality Monitor Survey - "conducted on a 24/7 basis and gathers detailed assessments from approximately 7,000 passengers regarding the quality of airport services and facilities throughout the terminal."
• ACI Airport Service Quality (ASQ) Benchmarking - "collects feedback from approximately 2,200 passengers, enabling AIA to assess its performance on a global scale."
• Persons with Disabilities and/or Reduced Mobility (PRM) Satisfaction Survey - "conducted monthly, engaging approximately 650 PRM passengers to assess accessibility, service experience, and satisfaction levels."
• Parking Users Satisfaction Survey - "conducted annually with over 10,000 parking users."

Beyond surveys, "AIA has established a formal process to receive, record, analyse, respond to, and communicate passenger comments and enquiries submitted through multiple channels, including the AIA website, a dedicated email address, and the Company's social media platforms" (page 238).

Safety feedback has a defined route: it "is initially handled by the Communications & Marketing Department through the Comments Management & Customer Experience function" and, where it concerns aviation safety, is referred to the Aviation Safety Services Office, which "coordinates follow-up actions with the relevant parties" (page 238).

The Reference Table records "Par. 22 does not apply as AIA has adopted general processes" (page 267).

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

Reference: pages 239-240.

Safety hazards. "In line with ICAO/EASA and national regulations, the Aviation Safety Services Office (ASSO) manages aviation safety hazards at Athens International Airport, focusing on airside risk mitigation. AIA implements measures to address material impacts related to consumers and end-users, ensuring alignment with Safety Risk Management principles" (page 239).

Complaint handling. "AIA has established a cross-Departmental procedure to systematically record, assess, investigate, and respond to comments and complaints received through all available communication channels. Passenger feedback is actively encouraged to enhance customer experience, while stakeholder input is gathered through structured safety forums, committees, and working groups" (page 240). "Passenger-related issues are monitored across all channels, with findings communicated to the responsible managers to ensure timely investigation and the implementation of corrective actions where necessary."

Data protection. "AIA ensures that passengers are appropriately informed about feedback submission requirements and the processing of personal data, in full compliance with the General Data Protection Regulation (GDPR)" (page 240).

Whistleblowing. "Incidents reported under the Whistleblowing Policy are handled in accordance with the applicable internal procedures, ensuring confidentiality, impartial investigation, and strict protection against any form of retaliation" (page 240).

The Reference Table records "Par. 27 does not apply as AIA has adopted general processes" (page 267). AIA does not report tracking whether passengers are aware of or trust these channels.

Taking action on material impacts on consumers and end-users

Reference: pages 240-241, 243-245.

Passenger and visitor safety (pages 240-241). "During 2025, CHS conducted a total of 14 Safety Management Audits within the AIA premises, in accordance with the annual audit plan. Six (6) of these were carried out in collaboration with Aviation Safety." Terminal Services staff conduct daily walkthroughs for hazards such as spillages and tripping risks, and the I-mind programme "empowers employees to act as passengers, identifying situations needing immediate attention". "For the 2025 reporting year, ASSO allocated operating expenditure (OpEx) of approximately EUR 25,521 to support these safety awareness actions. Planned financial resources for the 2026 reporting year amount to EUR 60,000."

Capacity, via the Airport Expansion Program (pages 243-244). The AEP team grew "from 19 members in 2024 to 30 members in 2025", costing EUR 3.7 million in 2025 with EUR 6.4 million planned for 2026. Construction of the Multi-Storey Car Park and North-West Apron cost EUR 21.3 million in 2025 with circa EUR 133 million estimated for 2026 and completion anticipated in 2027;

Service quality spend (page 245). "During the reporting period, EUR 339,463 in operating and capital expenditures were dedicated to structured resource allocations supporting service-quality initiatives. Of this amount, EUR 197,476 supported the Voice of Customers program, EUR 39,412 funded the I-mind initiative, and an additional EUR 97,640 was invested in the real-time assessment of passenger experience... EUR 4,935 was allocated to the ACI Customer Experience Accreditation - Level 2." For 2026, EUR 332,850 is allocated.

The Reference Table records "Par. 33 (b) does not apply as there are not material opportunities. Par. 36 is not applicable as targets have not been disclosed in relation to ESRS S4" (page 268).

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

Reference: pages 241, 245-246.

Safety: no target, monitoring instead (page 241). "AIA has not established measurable, outcome-oriented targets specifically for the health and safety of passengers and visitors. Nevertheless, the effectiveness of AIA's health and safety actions is monitored through performance measurement and stakeholder engagement." Performance metrics "are aligned with the Hellenic Civil Aviation Authority (HCAA) National Plan for Aviation Safety, focusing on defined Key Performance Areas (KPAs) and Key Performance Indicators (KPIs)". Outcome: "During the 2025 reporting period, ASSO reported zero (0) incidents of non-compliance with regulatory and/or voluntary codes related to aviation safety impacts of products and services, consistent with 2024."

Customer satisfaction: a quantified target that was met (page 245). "AIA sets an annual Passenger Satisfaction Score target in the range of 4.05 to 4.15... The previous year's average score is used as the baseline for target-setting, which is subject to annual review." "In 2025, passengers evaluated their overall airport experience with an overall evaluation score of 4.17, representing an above-target performance for the reporting year." "Proposed targets are set by the Management Team and submitted to the Board of Directors (BoD) for approval."

Waiting times deteriorated (Table 39, page 246): check-in 5 minutes 59 seconds in 2025 against 4 minutes 40 seconds in 2024 (+28.00%); security screening 3 minutes 11 seconds against 2 minutes 44 seconds (+16.00%).

The Reference Table records "Par. 41 does not apply for AIA, as no targets have been disclosed in relation to ESRS S4" (page 268), which sits alongside the passenger satisfaction target actually disclosed.