Autohellas

The role of the administrative, management and supervisory bodies

Reference: pages 51-54.

The Board of Directors is the highest governing body for sustainability and is "responsible for approving sustainability policies, overseeing material sustainability-related impacts, risks and opportunities (IROs), and ensuring compliance with ESRS reporting requirements". It reviews sustainability performance annually (page 51).

Board composition, as printed (page 51, 2025 vs 2024):

Three committees carry sustainability duties: the Sustainability Committee (identifies and assesses material sustainability matters and reviews the policies covering climate change, governance, anti-corruption, data protection and workforce well-being), the Audit Committee (oversees the accuracy of ESG reporting) and the Candidacy & Remuneration Committee (pages 52-53).

Two limits are stated plainly. "Although sustainability is not a formal competency requirement for Board members, training and advisory support are provided" (page 52). And "At present, Autohellas Group does not have an employee or workforce representative serving as a member of the Board of Directors" (page 52).

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

Reference: pages 51-52, 61.

The Board "reviews sustainability performance annually and evaluates progress against key environmental, social and governance (ESG) commitments, including climate transition, responsible business conduct and corporate social responsibility initiatives" (page 51). Progress on the DMA-identified material topics reaches the Board through the Sustainability Committee, which "evaluates ESG performance and recommends adjustments" (page 52).

The candid disclosure is the maturity of the reporting cycle: "The Board of Directors, in collaboration with its committees, is in the early stages of establishing a structured process for receiving updates on material sustainability-related impacts, risks and opportunities. At present, sustainability topics are reported to the governing bodies on an ad-hoc basis, with the intention of developing a more structured annual review cycle as the Company further strengthens its sustainability governance mechanisms" (page 52).

Risk reporting is on a fixed cadence: "The Executive Management Team, the Audit Committee and the Board of Directors review and assess the most significant risks on a semi-annual basis" (page 61). The Sustainability Statement itself "is approved by the Board of Directors" (page 52).

Integration of sustainability-related performance in incentive schemes

Reference: pages 53, 72.

A nil return, stated explicitly: "The proportion of variable remuneration within Autohellas Group that is directly linked to sustainability-related objectives and impacts currently stands at 0%. The Company's existing remuneration policy does not formally include sustainability performance criteria" (page 53).

The Remuneration Policy for Board members was prepared under Articles 110 and 111 of Law 4548/2018, first approved by the General Meeting on 18 December 2019 and revised on 15 July 2020, 31 March 2021 and 18 April 2024. Variable remuneration is granted only to executive Board members and is "linked to performance evaluation, achievement of personal or corporate objectives and the financial results of the Company and the Group, while also taking into account compliance with corporate policies, including those related to corporate social responsibility, sustainable development and regulatory compliance" (page 53). The Group calls this "an early-stage assessment of executive variable remuneration with regard to sustainability considerations, although such criteria are not yet quantified".

The climate chapter repeats the point for E1 specifically: "At present, climate-related performance indicators have not been incorporated into the remuneration structure or management-evaluation frameworks" (page 72).

The Group "intends to examine the possibility of integrating specific sustainability indicators into its variable remuneration policy in future periods" (page 53).

Statement on due diligence

Reference: pages 53-54.

Autohellas states that, "Building on its existing practices, the Group is in the process of establishing due-diligence procedures in key areas such as human rights, supply-chain management and stakeholder engagement, ensuring alignment with the relevant OECD Guidelines" (page 53).

The mapping table of the five core elements to sections of the statement (page 54):

The table gives section names rather than page numbers. The Group notes the disclosure "does not introduce additional due-diligence obligations nor does it alter the role of the administrative, management or supervisory bodies" (page 53).

Risk management and internal controls over sustainability reporting

Reference: pages 52, 54.

"The Company applies an internal control and risk-management system, as described in the Internal Charter of Operations, which supports the reliability of the information disclosed in the consolidated report, including the Sustainability Statement. The system encompasses the operation of the Internal Audit Unit, the Risk Management and Regulatory Compliance Unit, as well as related compliance and risk-management procedures" (page 54).

Oversight is split: "The Board of Directors oversees the effectiveness of the internal control system ... while the Audit Committee supports its work by monitoring the financial and non-financial reporting process and the effectiveness of these units" (page 54). The Company "periodically assesses the adequacy and effectiveness of the internal control and corporate-governance system", and audit results are fed back "into the internal processes and functions that support the collection, processing and disclosure of corporate information, including sustainability-related information" (page 54).

On reporting controls specifically: the Group "addresses risks related to incomplete or inconsistent sustainability reporting, as well as potential inaccuracies or errors in data collection", through "control mechanisms for reviewing quantitative and qualitative data across its business units and functions, as well as a reporting process with automated data-input checks within the reporting systems" (page 52). External limited assurance is risk-based, "with the auditors providing updates on their risk assessments to the Audit Committee and management, as well as to the Board of Directors" (page 52).

No control framework is named (no reference to COSO or an equivalent), and no residual reporting risks are listed.

Strategy, business model and value chain

Reference: pages 56-58.

"Autohellas Group manages a rental fleet of more than 65,000 vehicles and operates through over 170 service locations across 9 countries. At the heart of the Group's operations is its workforce, which now exceeds 1,800 employees in Greece and abroad" (page 56).

Core activities (page 56):

• Short-term and long-term vehicle rentals for individuals, businesses and public-sector entities
• Import, trade and retail sale of new vehicles and spare parts
• Sale of used vehicles and spare parts
• After-sales services, including vehicle repair and maintenance

Revenue is allocated across three operating segments and is presented in Note 6 of the Consolidated Financial Statements (page 56). The Group states it "has no revenue from activities related to coal, oil, natural gas or other fossil fuels", nor from "the production of chemicals, controversial weapons, or the cultivation and production of tobacco" (page 57).

Four key inputs are described: the vehicle fleet ("continuously renewed through purchases from car manufacturers, dealers and importers"), infrastructure (company-owned service locations, storage facilities and maintenance centres), financial capital and human capital (page 57). Outputs are framed for customers, employees, shareholders and investors, and communities and society (pages 57-58).

Own workforce is located in Greece (1,302), Portugal (286) and other countries (216) - Cyprus, Bulgaria, Romania, Serbia, Montenegro, Croatia and Ukraine (page 83). The water section gives a second location count, "more than 140 car-rental locations" (page 81).

Interests and views of stakeholders

Reference: page 59.

A single table sets out seven stakeholder groups, their communication channels, main topics of interest and the frequency of contact (page 59):

Topics recorded per group include growth and profitability, good corporate governance and business ethics and "strong social and environmental performance" (investors); job preservation, fair remuneration, occupational health and safety and development opportunities (employees); vehicle quality and reliability, competitive pricing, innovation and protection of personal data (customers); long-term partnerships, "ensuring sustainability" and timely payments (suppliers); social initiatives, employment opportunities and support of local suppliers (local community).

Stakeholder input feeds the DMA: "Stakeholder engagement is also a fundamental component, with insights from investors, customers, suppliers and employees contributing to the assessment of ESG-related risks and opportunities" (page 61). A planned improvement is disclosed: the Group "will further enhance its stakeholder-engagement initiatives by collecting direct customer feedback through structured surveys, targeted focus groups and qualitative interviews" (page 63).

The statement does not describe how stakeholder views were reported to the Board.

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

Reference: pages 60, 65-66.

The DMA results table (page 66) lists 18 material IROs across four topical standards, each typed as Impact (I), Risk (R) or Opportunity (O), with actual/potential, company-specific, time-horizon and value-chain flags:

• E1 Climate change (7): emissions from internal-combustion engines of the vehicle fleet (actual negative impact); reduction in emissions from increased adoption of electric and hybrid vehicles (actual positive impact); faster depreciation and resale uncertainty for BEVs/PHEVs (risk); reduced operating costs from lower EV maintenance needs, increased demand from customer awareness of sustainable mobility, tax benefits for vehicles below 50 g CO2/km, and reduced financing costs through sustainability-linked financing (four opportunities)
• S1 Own workforce (6): occupational health and safety (possible negative impact); occupational hazards from machinery handling and hazards from extreme weather (risks); training and upskilling opportunities (actual positive impact); talent attraction and retention, and operational efficiency (opportunities)
• S4 Consumers and end-users (3): high product and service quality (actual positive impact); reputational harm from an inadequately maintained fleet and from a customer personal data breach (risks)
• G1 Business conduct (2): compliance and ethical business practices (actual positive impact); compliance with regulatory and legal requirements (risk)

E2, E3, E4, E5, S2 and S3 were assessed non-material (page 65).

Under "Strategy and Business Model Resilience" the Group ties these to strategy through "the gradual electrification of the fleet, the adoption of low-emission technologies and efforts to improve energy efficiency", and states it "maintains flexibility in adjusting the composition of its fleet and service portfolio to meet evolving regulatory and market requirements" (page 60).

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

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

Reference: pages 60-65; climate methodology pages 73-75.

Sustainability IROs sit inside the Group's Enterprise Risk Management (ERM) process: "Each identified risk is assigned to a risk owner within the Executive Management Team, who is supported by risk-management officers", and "A two-dimensional risk matrix is used to assess both the severity of potential risks and the likelihood of their occurrence" (page 61).

The DMA is updated annually and is informed by "industry benchmarking, expert consultation, stakeholder feedback and regulatory review" (page 61). The stated stages are (page 62):

• Preliminary analysis and data collection - sustainability data, regulatory developments and market trends
• Impact assessment - severity, likelihood of occurrence, and economic, environmental and social consequences
• Prioritisation and categorisation - "1-Low, 2-Low-Medium, 3-Medium, 4-Medium-High, 5-High priority"
• Monitoring and continuous improvement

Heightened-risk areas are named as fleet management ("Emissions from leased and rental vehicles contribute to climate-related risks") and geographical exposure to varying environmental regulations (page 62). Dependencies are set out for human capital, suppliers (the Group "relies on vehicle manufacturers for the procurement of its fleet"), customers and market demand, regulatory authorities, and investors and financial institutions (pages 63-64).

Financial materiality is assessed through "potential financial consequences, including regulatory fines, shifts in market demand and fluctuations in operating costs" (page 63).

What is not given: no materiality thresholds or scoring scales are quantified, no list of external experts is provided, and the treatment of the value chain in the scoring is described only in general terms.

Climate-specific process detail is under E1-2 (2025 ESRS numbering).

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

Reference: pages 55-56.

The statement prints a real ESRS content index headed "iii. Disclosure requirements covered", listing each covered disclosure requirement with its title and the chapter in which it sits. It gives chapter names, not page numbers.

Covered, as listed:

• General Disclosures: BP-1, BP-2, GOV-1, GOV-2, GOV-3, GOV-4, GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, IRO-2
• Environment - Climate change: E1.GOV-3, E1-1, E1.SBM-3, E1.IRO-1, E1-2, E1-3, E1-4, E1-5, E1-6
• Social - Own workforce: S1.SBM-2, S1.SBM-3, S1-1, S1-2, S1-3, S1-4, S1-6, S1-8, S1-9, S1-12, S1-13, S1-14
• Social - Consumers and end-users: S4.SBM-2, S4.SBM-3, S4-1, S4-2, S4-3, S4-4, S4-5
• Governance: G1.GOV-1, G1.IRO-1, G1-1, G1-2, G1-3, G1-4, G1-5, G1-6

That is 40 rows. E1-7, E1-8 and E1-9 are absent, as are S1-5, S1-7, S1-10, S1-11, S1-15, S1-16 and S1-17. No datapoint-level table (ESRS 2 Appendix B, datapoints derived from other EU legislation) is printed, and no phase-in flags are shown.

Two mismatches are worth a reader's attention. S1-12 Persons with disabilities is listed as covered, but the phrase "persons with disabilities" appears nowhere else in the statement and no disability metric is printed. Conversely, several unlisted requirements do have printed datapoints in the Own workforce metrics tables (adequate wage benchmark, gender pay gap, total remuneration ratio, discrimination incidents), which the index does not claim.

Transition plan for climate change mitigation

Reference: page 76; supporting pages 72, 78.

Autohellas states plainly that no transition plan has been adopted: "Although the Group has not yet formally adopted a transition plan, it is currently assessing the macroeconomic environment, market trends and the regulatory and compliance framework, and is committed to developing a comprehensive programme that will define clear targets and pathways for reducing its environmental footprint and enhancing long-term sustainability" (page 76).

What is disclosed about the intended plan (page 76):

• It "will align with the Group's strategic objectives, focusing on key areas such as fleet electrification, energy efficiency, emissions reduction and responsible supply-chain management"
• "Financial planning will include the necessary capital expenditures and operational investments required to support the implementation of transition initiatives"
• "Once formally developed by the Sustainability Committee, the transition plan will be subject to review and approval by the Board of Directors"

Locked-in emissions are acknowledged qualitatively: "Autohellas recognises that the predominance of internal-combustion-engine (ICE) vehicles in the rental fleet entails significant risks of locked-in greenhouse-gas emissions" (page 72). No quantification is given.

Paris-aligned benchmark exclusion: "Autohellas Group is not exempt from the EU Paris-Aligned Benchmark (EU PAB) indicators, as it does not operate in sectors that result in automatic exclusion under Delegated Regulation (EU) 2020/1818" (page 72).

The nearest thing to a funded decarbonisation pathway is the EUR 450 million investment plan (2022-2026) under Greece's National Recovery and Resilience Plan ("Greece 2.0"): EUR 225 million from the Recovery and Resilience Facility, EUR 135 million from Greek banks and EUR 90 million from the Group, for fleet renewal with electric and hybrid vehicles meeting a 50 g CO2/km threshold (page 78). It is presented under E1 opportunities rather than as a transition plan.

Identification of climate-related risks and scenario analysis

Back-filled from the E1 "Resilience Analysis" section, where this content is disclosed in the FY2025 report (pages 73-75), together with ESRS 2 IRO-1 (pages 61-62). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification. Risks are split into physical and transition: "chronic and acute physical risks related to temperature, water, wind and solid mass, as well as transition risks and opportunities related to policy/legal matters, technology, market changes and reputation, were identified and assessed" (page 74). The single material physical risk is heatwaves; the three material transition risks are stricter GHG regulation, residual-value uncertainty for BEVs/PHEVs, and expenditure on mandatory energy upgrades (pages 74-75).

Methodology and exposure (page 74). An industry analysis and literature review identified relevant risks; economic data were then collected to size potential impacts, "indicatively ... the Group's energy consumption from electricity and fossil fuels, greenhouse-gas emissions and the cost of insurance for its assets". Likelihood was "assessed through statistical analysis of the three scenarios ... in combination with a sensitivity analysis of the Group's facilities and operations". Magnitude was scored "through internal meetings with responsible executives", the final score being the product of likelihood and magnitude on five levels; "Those falling within the medium-high and high categories were identified as material".

Scenarios (pages 73-74). Physical data came from "ensemble simulations based on EURO-CORDEX 11 ... as provided by the European Centre for Medium-Range Weather Forecasts (ECMWF)" for RCP 2.6, RCP 4.5 and RCP 8.5; transition scenarios came from the NGFS.

• Low-emission: RCP 2.6 with NGFS Net Zero, warming "close to 1.5C", global net-zero CO2 by 2050. This meets the 1.5C-aligned transition scenario test.
• Emission-mitigation: RCP 4.5 with NGFS Nationally Determined Contributions, warming stabilising at "approximately 2.5-3C above pre-industrial levels".
• High-emissions (Hot House World): RCP 8.5 with NGFS Current Policies, where "Global warming is expected to exceed 4C above pre-industrial levels". This meets the high-emission physical scenario test.

Time horizons (page 74): short 0-1 year (2025-2026); medium 1-5 years (2026-2030); long more than 5 years (2030-2050).

Scope (page 73): "The analysis covered the most significant part of the Group's activities and facilities - namely Greece - taking into account its value chain. ... The resilience analysis is expected to be extended prospectively to include the Group's foreign operations." The other eight countries are therefore outside it.

Gaps: the RCP 8.5 description is internally inconsistent, stating both that warming "is expected to exceed 4C" and that the increase is "approaching 3C within this century" (page 74). No date is given for when the analysis was carried out, and the key assumptions are described only qualitatively.

Resilience in relation to climate change

Back-filled from the E1 "Resilience Analysis" results (pages 74-76) and ESRS 2 "Strategy and Business Model Resilience" (page 60), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results (pages 74-76). The physical risk of heatwaves is scored, as printed in the table on page 75, Moderate short-term, High medium-term and High long-term. The narrative summary reads differently: "material physical risks are estimated to be of low intensity in the short- and medium-term horizons; however, they intensify over the long-term horizon, with the greatest exposure arising under the high-emissions scenario in the long term" (page 76). The two do not agree.

Transition risks are each scored across the same three horizons on a Low-to-High scale. The narrative conclusion: "the tightening of the legislative and regulatory framework for GHG emissions may lead to increased operating and compliance costs ... In addition, the decline in residual values when procuring/purchasing electric vehicles - due to technological advancements - as well as the need for energy upgrade across the Group may result in lower revenues and higher operating and capital costs in the medium- and long-term horizon" (page 76).

Opportunities are scored (page 75): utilisation of renewable energy sources Moderate / Moderate / Moderate-High, and increased customer demand for zero- or low-emission vehicles Moderate-High / High / High.

Implications and response (page 76). "Autohellas Group leverages the findings of the analysis by integrating them into its operational planning ... Heat-stress risks are addressed through the implementation of emergency measures in accordance with government directives, while transition risks are mitigated through continuous monitoring and application of the applicable legislation, as well as the adoption of sustainable practices and solutions."

Capacity to adjust (page 76). "Overall, the Group considers that it possesses the necessary adaptive capacity in the short- and medium-term and that, by maintaining existing good practices and implementing sustainability-driven initiatives, it can preserve the long-term resilience of its business model and competitive position." Page 60 adds that the Group "maintains flexibility in adjusting the composition of its fleet and service portfolio to meet evolving regulatory and market requirements".

Uncertainty (page 50). "uncertainties exist regarding the level of exposure to such risks, as the assessment supported by climate models is expected to be completed during the next financial year."

One inconsistency to flag: after describing a completed resilience analysis on pages 73-76, the targets section states the Group "intends to conduct a detailed resilience analysis of its business model and climate strategy" (page 79).

Policies related to climate change mitigation and adaptation

Reference: pages 72-73.

A negative disclosure, stated directly: "Autohellas Group recognises the importance of formal policies relating to climate-change mitigation and adaptation; however, it does not currently have explicit, formalised climate policies in place" (page 72).

What the Group does instead of a policy (page 72):

• Targeted electrification through the acquisition of electric and hybrid vehicles in short-term rental operations and through partnerships
• Integration of vehicles meeting a 50 g CO2/km emission threshold
• Energy-efficiency improvements across operational facilities
• Climate-adaptation considerations "examined informally through initiatives aimed at strengthening the resilience and continuity of fleet operations and infrastructure against potential climate-related disruptions"

The Group names the gap as its own: "The formalisation and documentation of these measures into explicit policies represent an area for improvement, with the Group committed to developing formal policies in the near future" (page 73).

Because no policy exists, the ESRS policy datapoints that would ordinarily follow - scope, most senior accountable level, availability to stakeholders, third-party standards referenced - are not disclosed. Governance of climate matters sits with the Board: "Autohellas Group manages climate-related matters directly through the Board of Directors ... The Board monitors the implementation of the Company's climate strategy and may adjust its approach based on evolving sustainability priorities and regulatory requirements" (page 72).

Actions and resources in relation to climate change policies

Reference: pages 72, 76-78; metrics page 79.

Actions are described qualitatively rather than as a resourced action plan. The climate strategy "focuses primarily on strengthening electrification and, more broadly, on the provision of zero- and low-emission vehicles (50 g CO2/km or less) to support the limitation of global warming to 1.5C, in line with the Paris Agreement", alongside "improving energy efficiency across its facilities" and "a culture of sustainable development among employees through targeted training and awareness programmes" (page 72).

Named actions:

• Fleet renewal and electrification. "the Group consistently implements fleet-renewal strategies and strengthens electrification" (page 72). Progress is qualified: "the rate at which electric vehicles (EVs) and hybrid vehicles are being integrated remains gradual", influenced by "limited charging infrastructure and consumer uncertainty regarding electric-vehicle technology" (page 77)
• The EUR 450 million co-financed investment plan (2022-2026) under "Greece 2.0" - EUR 225 million from the Recovery and Resilience Facility, EUR 135 million from Greek banks, EUR 90 million from the Group - "aims at the gradual renewal and expansion of the fleet through the acquisition of electric and hybrid vehicles that meet strict emission standards". "The vehicles acquired under this plan emit approximately 80% fewer pollutants compared with their predecessors" (page 78)
• Adaptation. Heat-stress risks "are addressed through the implementation of emergency measures in accordance with government directives" (page 76)
• Charging infrastructure. Electricity is used "for charging electric and plug-in hybrid fleet vehicles at the Group's owned charging points" (page 81)

Resources. The E1 metrics table carries rows for "Financial resources allocated to action plan (OpEx)" and "(CapEx)", and no monetary amount is printed against either for 2025 or 2024 (page 79). The EUR 450 million plan is presented under opportunities, not as the climate action budget, and no split between climate and non-climate capital expenditure is given.

No expected GHG reduction is attached to any individual action.

Targets related to climate change mitigation and adaptation

Reference: pages 78-79.

Four target statements are given, none of them quantified with a base year and a percentage:

• Emissions intensity. "the Group seeks to achieve measurable annual reductions in its Scope 1 and Scope 2 greenhouse-gas emissions by targeting yearly decreases in emissions intensity, calculated in tonnes of CO2 equivalent (tCO2e) per million euros of revenue, as reported in its consolidated financial statements" (page 79)
• Fleet. "By 2030, the Group aims to materially reduce emissions from the total rental fleet, prioritising the acquisition of electric vehicles and vehicles emitting 50 grams of CO2 per kilometre or less" (page 79). This "commitment - requiring substantial capital expenditure - will be supported in part by the Group's co-financed investment plan"
• Energy. "improvements in the energy efficiency of its operations, particularly by pursuing continuous annual reductions in total energy consumption across its facilities" (page 79)
• Process. the Group "intends to conduct a detailed resilience analysis of its business model and climate strategy, as well as to develop a structured transition plan" (page 79)

No base year, no target value, no interim milestones, no science-based or 1.5C-alignment validation, and no statement of stakeholder involvement in target setting are disclosed. The Group repeats that it "has not yet formally adopted a transition plan" (page 78).

Performance against the intensity ambition moved the wrong way in 2025, driven by a change in what is measured rather than by operations. Location-based GHG intensity rose from 146.62 to 1,441.73 tCO2e per EUR million of net revenue, because Scope 3 was expanded from 103 tCO2e in 2024 to 1,335,409 tCO2e in 2025. The metrics table records "Reduction of absolute GHG emissions" of (1,346,567.36) tCO2e and a "Percentage reduction of total GHG emissions compared to the base year" of -938% (page 79). The Group does not comment on the restatement or explain why the prior-year Scope 3 figure was so small.

Energy consumption and mix

Reference: pages 79-80.

The mix is almost entirely fossil, which follows from the business: the dominant line is fuel burned in the rental and leasing fleet. Total energy consumption rose 5.9% year on year while renewable energy rose 33%, from a very small base.

The Group states it "does not procure Guarantees of Origin (GOs) for the electricity it consumes, meaning that its energy supply is not certified as originating from renewable sources" (page 81); the renewable and nuclear shares are therefore the residual grid mix, not a procurement choice. "The total fossil energy consumed and the total renewable energy consumed include the share of electricity derived from fossil fuels and renewable sources within the overall electricity-supply mix" (page 81).

Rows for self-generated renewable energy, coal, and heating/cooling/steam purchased from renewable sources are printed without values.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 79; accounting policies pages 80-81.

The Scope 3 figure is the story. It moves from 103 tCO2e in 2024 to 1,335,409 tCO2e in 2025, 89.6% of the 2025 footprint. The Group explains the categories now covered but not the change: "Autohellas Group has calculated additional categories in order to provide a comprehensive representation of the indirect emissions associated with its value chain" - Categories 1 (purchased goods and services), 2 (capital goods), 3 (fuel- and energy-related activities), 4 (upstream transportation and distribution), 11 (use of sold products), 13 (downstream leased assets) and 15 (investments) (page 81). No category-level breakdown is printed and no restatement of the 2024 comparative is made, so the two years are not comparable.

Scope 1 "arise primarily from fuel consumption in the Group's rental-fleet vehicles, over which the Group maintains operational control", plus corporate vehicles, natural gas and heating oil at facilities. "Emissions generated by leased and rental vehicles during their use by customers are estimated based on standardised fuel-consumption factors per vehicle category and average mileage data" (page 80).

Scope 2 covers electricity at facilities including EV charging points; market-based factors come from "the Public Authority for Energy & Environmental Resource Management and local suppliers" and location-based from the local grid (page 81).

"Percentage of GHG Scope 3 calculated using primary data" is printed without a value, so the reliance on estimation in the 1.3 million tonne Scope 3 figure is not quantified.

Policies related to own workforce

Reference: pages 85-87.

The Group describes several policies rather than a single workforce policy:

• Health and Safety Policy - "The Policy aligns with internationally recognised standards, such as ISO 45001, and complies with local regulatory requirements". It "incorporates practical measures such as regular risk assessments, tailored training programmes, clearly defined emergency-response procedures and a continuous effort to enhance workplace safety". "The Board of Directors holds ultimate responsibility for its implementation", and it is communicated "through multiple channels, including the Company's internal network, training sessions and communications from the Risk and Compliance Management Unit and the Human Resources Department" (page 86)
• Human rights and labour standards - "strict prohibition of violations such as forced labour, child labour and modern slavery". "All employees are paid above the statutory minimum wage, in accordance with the national legislation of each respective country" (page 86)
• Violence and Harassment Policy - defines violence and harassment as "any behaviour, act, practice or threat that may cause physical, psychological, sexual or economic harm", explicitly covering "gender-based harassment, sexual harassment and discrimination based on sexual orientation, gender identity or gender expression". It "applies to all individuals working with or for the Company, regardless of their employment status, including employees, external partners, trainees and interns" and covers the workplace, business travel, company-provided areas and digital platforms. The Head of the Regulatory Compliance Unit, with the Head of Internal Audit, manages incidents (pages 86-87)

Two gaps are stated by the Group itself. There is no diversity policy: "Although Autohellas does not currently maintain a dedicated policy exclusively focused on diversity, equality and inclusion, it remains fully compliant with national and European legislation on anti-discrimination and equal treatment" (page 86). And no human rights impact assessment has been carried out: "the Group intends to explore the possibility of conducting a Human Rights Impact Assessment (HRIA) in line with the UN Guiding Principles on Business and Human Rights. The potential implementation of such an assessment will be examined during the next reporting period" (page 86).

The statement does not say whether the policies explicitly reference the ILO fundamental conventions or the OECD Guidelines by name in the workforce context.

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

Reference: page 87.

Engagement is direct rather than representative, and the Group says why: "Autohellas Group maintains regular and transparent communication with its employees through structured channels such as the open-door policy and the internal intranet platform. Employees can openly raise concerns, suggestions or comments directly with supervisors and senior management ... This is particularly important given the absence of formal employee representatives" (page 87).

That statement sits alongside the metric "Percentage of employees covered by workers' representatives (%): 0.0%" for both 2025 and 2024 (page 89), while 97.67% of employees are covered by collective bargaining agreements (page 88).

Accountability: "Senior management, supported by departmental heads, holds operational responsibility for ensuring effective employee engagement across the Organisation" (page 87).

Frequency and form: "Employee engagement takes place on a regular basis throughout the year through scheduled team meetings, discussions with supervisors and participation in internal employee-satisfaction surveys. Team meetings and discussions with management occur periodically as part of the departments' day-to-day operations, while structured employee surveys are conducted at regular intervals to collect systematic feedback on working-environment issues, skills development and organisational culture" (page 87).

Effectiveness: assessed "through regular employee-satisfaction surveys and analysis of workforce feedback". Conclusions "directly inform the Company's decisions, particularly on matters concerning occupational safety, training and skills-development initiatives, working conditions and diversity and inclusion policies" (page 87).

No global framework agreement is reported, and no arrangement for engaging particularly vulnerable groups of workers is described.

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

Reference: pages 87-88.

Channels are set out concretely. Employees have "direct communication with supervisors and management teams through the Group's established 'open-door' policy, as well as electronic channels such as the corporate intranet" (page 87). Under the Reporting Management Policy, reports may be submitted anonymously (page 87):

• In writing, addressed to the Head of the Regulatory Compliance Unit
• By email, at whistleblowing@autohellas.gr
• Through the We Act TOGETHER platform

Scope of the channel extends beyond employees: "Employees, customers and suppliers of the Company are encouraged to submit reports concerning criminal acts, suspected incidents of unlawful behaviour, cases of mismanagement or serious irregularities/omissions" (page 88). It "is managed internally".

Protections: "the confidentiality of the report and its associated data is safeguarded, as well as the protection of the reporter's anonymity, even in cases where a report is subsequently found to be incorrect or unfounded. At the same time, the Company maintains a zero-tolerance policy toward any form of threat, retaliation, sanction or adverse discriminatory treatment against the reporter, the reported individual or any person participating in the investigation process" (page 88).

Tracking: "Autohellas systematically monitors and records issues reported through these mechanisms. The Group maintains detailed records of submitted concerns, ensures timely responses and evaluates the effectiveness of corrective actions. Regular reviews by senior management confirm that these channels remain effective and reliable", supported by "internal employee surveys to assess employee awareness and trust in these processes" (page 88).

The statement does not say whether employees are aware of the channels in measured terms, and the related metric "Complaints filed through channels for people in the company's own workforce to raise concerns" is printed without a value (page 89).

Taking action on material impacts on own workforce

Reference: pages 83-85.

Actions are grouped against the six material S1 IROs.

Occupational health and safety (possible negative impact). "the Group implements a health-and-safety policy that is consistently applied across all facilities. Regular occupational-safety training programmes and targeted employee-awareness initiatives reinforce these policies, further supported by periodic safety inspections and risk assessments. In addition, the incident-reporting and corrective-action framework ensures the ongoing monitoring and improvement of occupational-safety performance" (page 84).

Occupational hazards from machinery handling (risk). The risk falls "primarily affecting employees in technical environments such as body shops, workshops and car-wash facilities". "In 2025, four workplace accidents were recorded." Mitigation is "regular inspections and preventive maintenance of equipment ... while strict adherence to regulations concerning personal protective equipment (PPE) and safe-operation standards further strengthens employee protection" (page 84).

Hazards from extreme weather (risk). "the Group has in place emergency-preparedness and crisis-management plans, which are reinforced through regular training programmes and emergency-response drills for employees. Ongoing assessment of facility vulnerabilities and the proactive implementation of resilience measures further enhance the Group's ability to manage and respond effectively to emergency situations. In parallel, clear and reliable communication protocols have been established for emergency scenarios" (page 84).

Training and upskilling (actual positive impact), talent attraction and retention and operational efficiency (opportunities). "Autohellas promotes internal career pathways and advancement opportunities while maintaining competitive remuneration and comprehensive benefits packages", supported by "regular satisfaction surveys and targeted internal actions". Training programmes are systematically updated, "integrating industry best practices and emerging trends", and effectiveness is "monitored through key operational performance indicators linked to workforce capabilities" (page 85).

The Group differentiates by employee group: "employees in demanding, high-intensity roles benefit from strengthened health and safety protocols, while specialised professionals require continuous training to adapt to new technologies and sustainability practices" (page 83). No resources or budgets are attached to any action.

Characteristics of the undertaking's employees

Reference: pages 83, 88.

Headcount at the reporting date (page 83):

"The other countries in which Autohellas Group maintains its own workforce are Cyprus, Bulgaria, Romania, Serbia, Montenegro, Croatia, and Ukraine" (page 83).

Breakdown by gender and contract type (page 88):

Turnover rose from 19% to 22% while headcount fell by 17. The Group notes that "Total departures include, in accordance with the relevant ESRS definition, dismissals, retirements, voluntary resignations, as well as any work-related fatalities" (page 89).

Not disclosed: no non-guaranteed-hours headcount, no full-time and part-time split, and no reconciliation of the workforce number to the financial statements.

Collective bargaining coverage and social dialogue

Reference: pages 88-89.

Coverage is close to universal at 97.67%, and 100% within the EEA. The Group does not disaggregate the EEA figure by country despite the row heading asking for it, and does not explain the 2.33% not covered - most plausibly the non-EEA operations in Serbia, Montenegro and Ukraine, though the statement does not say so.

The workers' representation figure of 0.0% is corroborated in the engagement text: employees raise matters directly with supervisors and senior management, which the Group says is "particularly important given the absence of formal employee representatives" (page 87). No works council, European works council or global framework agreement is reported, and no description is given of social dialogue arrangements at establishment or European Economic Area level beyond the coverage percentages.

Human resources matters reach the Board indirectly: workforce topics "are managed through the Human Resources Department and the Candidacy and Remuneration Committee, which provide information to management and the Board of Directors on workforce-related risks and opportunities" (page 52).

Diversity metrics

Reference: pages 88-89.

Gender at top management - the Group applies "the ESRS definition of top management as one and two levels below the administrative and supervisory bodies" (page 89):

Female representation in top management fell from 28.6% to 22.2%, two women fewer, while total top management grew from 28 to 27 posts as counted. Across the whole workforce, women are 25% of employees (446 of 1,804), up from 24% (page 88).

Age distribution (page 89):

The bands sum to the 1,804 total headcount. The workforce is ageing: the over-50 share rose 2.5 percentage points in a year while the under-30 share fell 1.5 points.

Board-level diversity is reported separately under GOV-1: 30% female, gender diversity ratio 0.43 (3/7) (page 51).

The Group does not explain the decline in women at top management, and no diversity target is set - consistent with its statement that it "does not currently maintain a dedicated policy exclusively focused on diversity, equality and inclusion" (page 86).

Persons with disabilities

Reference: pages 55-56 (ESRS content index).

S1-12 is listed in the Group's ESRS content index as a covered disclosure requirement, under the chapter "Own workforce" (pages 55-56). No supporting content appears in that chapter. The phrase "persons with disabilities" does not occur anywhere in the Own workforce section, no percentage of employees with disabilities is printed in either metrics table (pages 88-89), and no statement is made about the legal limitations on collecting such data in the countries where the Group operates.

The only disability content in the whole statement concerns customers rather than employees, in the Consumers and end-users chapter: "Autohellas is committed to accommodating the needs of people with disabilities by providing specially adapted vehicles with accessibility modifications such as wheelchair ramps, hand controls and customised seating" (page 90). That is an S4 accessibility disclosure, not an S1-12 workforce metric.

The classification here follows the Group's own index, which claims the requirement as covered. A reader looking for the percentage of employees with disabilities, with or without the note on legal restrictions that ESRS S1-12 permits in its place, will not find it. The gap is the finding.

Training and skills development metrics

Reference: page 89.

Average training hours fell 18% year on year, from 14.81 to 12.14 hours per employee, with the decline in both genders. Women receive more than twice the training hours of men (21.00 against 9.36), a gap the statement does not explain.

The performance review rows are all 0.0% for both years. The Group does not say whether that means no structured review cycle operates, or that the figure was not collected. Read against the S1 targets, the second reading is more likely: one of the three 2026 targets is to "Enhance the reporting framework for employee training and upskilling initiatives ... systematic recording of participation rates, training hours and skills-development outcomes, ensuring greater transparency" (page 88).

Qualitatively, training is one of the Group's two positive S1 impacts: "By investing in targeted employee-development programmes, the Group strengthens its workforce with modern skills, knowledge and expertise tailored to the requirements of the industry" (page 85). The reported hours moved against that narrative in 2025.

Health and safety metrics

Reference: pages 84, 89.

Recordable accidents halved, from 8 to 4, and the rate fell from 2.27 to 1.10. The narrative confirms the count: "In 2025, four workplace accidents were recorded" (page 84). No fatalities are reported for either year, though the cells are printed as dashes rather than zeros.

Coverage of the health and safety management system is 100%, and the Health and Safety Policy "aligns with internationally recognised standards, such as ISO 45001" (page 86). The statement does not say whether any site is certified to ISO 45001.

Not disclosed: no number of days lost to injuries, ill health or fatalities, no cases of recordable work-related ill health, and no basis for the accident rate (the denominator - hours worked or headcount - is not stated), which makes the 1.10 figure hard to benchmark. Non-employee workers on the Group's sites are covered by the fatality row only.

The accidents concentrate in "technical environments such as body shops, workshops and car-wash facilities", and mitigation runs through PPE rules, equipment inspection and preventive maintenance, and safety training (page 84).

Policies related to consumers and end-users

Reference: pages 92-93.

Consumer policies sit inside the Group's risk-management framework and "are reviewed periodically to address emerging challenges and evolving consumer expectations. The Board of Directors and senior management oversee the effectiveness of these policies" (page 92).

• Customer rights. The Group's human rights commitment "extends to customers and end-users through adherence to internationally recognised standards such as the UN Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises and the ILO Declaration on Fundamental Principles and Rights at Work". The approach "includes non-discrimination in service delivery, protection of customer privacy and ensuring access to complaint-handling mechanisms", and is embedded in the Code of Conduct, "which explicitly prohibits unfair treatment and discrimination in customer interactions" (page 92)
• Customer Satisfaction and Service-Quality Process - covers short-term and long-term rentals and vehicle sales, with "flexible solutions and personalised services" (page 92)
• Privacy and Personal-Data Protection Policy - safeguards data "collected through rental, leasing and sales activities, ensuring secure processing and confidentiality ... Customer consent and transparency are prioritised, with clear disclosures on data collection, use and retention" (page 93)
• Vehicle Safety and Maintenance Process - "a rigorous maintenance programme, performing regular inspections, repairs and preventive work in line with manufacturer guidelines and industry best practices" (page 93)
• Complaint-Handling and Dispute-Resolution Policy - "a structured explanation of how complaints can be submitted through various channels, such as customer-service departments, digital communication platforms and dedicated service centres" (page 93)

The policies apply "to all customer categories, including private renters, corporate short-term and long-term rental clients and vehicle purchasers" (page 92). The statement does not name the most senior level accountable for each policy or say whether the policies are published.

Processes for engaging with consumers and end-users about impacts

Reference: pages 93-95.

Seven engagement mechanisms are described (pages 93-94):

• Customer service department available "24 hours a day, 7 days a week", by phone or online contact form
• Mystery shopper surveys - "to collect objective data on the customer experience and identify both strengths and areas for improvement"
• Customer-satisfaction surveys - "Autotechnica Hellas conducts monthly customer-satisfaction surveys in collaboration with ICAP, one of the largest business-information groups ... At the end of each month, ICAP delivers a detailed report with the survey findings"
• Digital communication channels - social media, corporate email, online form
• Specialised customer-service call centres
• Net Promoter Score (NPS) - assessed "on a monthly basis"
• E-commerce - "Through the Hertz online store, the Group promotes and internally circulates key evaluations and feedback collected from its customers"

Accountability is named: "Responsibility for ensuring effective consumer engagement lies with the Directors of Long-Term and Short-Term Rentals and the Directors of Car Sales, who report directly to senior management and oversee the effectiveness of all customer-interaction channels" (page 94).

Effectiveness is "assessed through key performance indicators such as customer-satisfaction scores, number of complaints and service-quality evaluations" (page 95).

Vulnerable groups. "The Group has also taken proactive measures to engage vulnerable consumer groups, ensuring accessibility and non-discriminatory service provision" (page 95). Specific accommodations named include "specially adapted vehicles with accessibility modifications such as wheelchair ramps, hand controls and customised seating", and for families "safe, legally compliant child seats, spacious vehicles and flexible rental options" (page 90).

End-user groups are segmented as short-term rental customers, long-term leasing customers, private buyers and indirect end-users who "purchase vehicles through dealers associated with the Group's import subsidiaries", where "the Group indirectly influences service standards and the quality of the vehicles" (page 90).

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

Reference: page 95; supporting page 93.

"Customers have access to structured complaint-handling mechanisms, which include online reporting channels, direct communication with customer-service representatives and escalation pathways to independent mediation bodies where necessary. The 'We ACT Together' Reporting Platform provides an additional channel for stakeholders to anonymously report ethical concerns, with strict protections against retaliation" (page 95).

Channel awareness is addressed practically: "The Group communicates available reporting channels to consumers and monitors issue-resolution rates to assess effectiveness. All communication channels are included in service documents, such as offers, rental agreements and invoices" (page 95).

Remedy. "In cases where material adverse impacts on consumers have been identified, the Group takes immediate action to remedy the situation. Corrective measures may include revision of service agreements, provision of refunds, enhancement of vehicle-safety measures or strengthening of data-protection protocols. If a consumer-related issue indicates systemic risks, the Group conducts a root-cause analysis and implements broader policy changes" (page 95).

Under the Complaint-Handling and Dispute-Resolution Policy, "All complaints are carefully reviewed, documented and assessed to determine appropriate solutions ... The Company prioritises transparency by clearly communicating the complaint-resolution process and expected response times" (page 93).

Outcome for the year: "It is noteworthy that no serious human-rights incidents related to end-users were recorded during the year" (page 95).

No number of complaints received or resolved is published, and no third-party grievance mechanism is named, so the effectiveness claim rests on process description rather than data.

Taking action on material impacts on consumers and end-users

Reference: pages 91-92, 95.

Actions are set against the three material S4 IROs.

High product and service quality (actual positive impact). "Autohellas Group systematically implements maintenance and inspection processes, regularly invests in fleet upgrade with reliable vehicles, and actively incorporates customer feedback ... employee training is continuously enhanced to strengthen awareness of quality assurance, customer safety and transparent communication." Digitalisation is added as a lever: "online reservations, digital contracts and user-friendly self-service options" (page 91).

Reputational harm from an inadequately maintained fleet (risk). "Vehicles undergo detailed safety inspections before each rental, with particular focus on critical safety features such as airbags, braking systems (ABS), tyre condition and lighting systems." The Group "continuously invests in advanced vehicle-diagnostic technologies, preventive-maintenance solutions and specialised staff training", maintains records "to ensure timely maintenance interventions", and proactively informs customers "of upcoming service schedules and required maintenance intervals" (page 91). Outcome for the year: "no road accidents related to inadequately maintained vehicles occurred during the year" (page 92).

Reputational harm from a customer personal data breach (risk). Mitigation is "advanced data encryption, secure information systems and regular cybersecurity audits", plus "ongoing training programmes to educate employees on GDPR compliance and data-protection best practices". Internal processes "clearly define proper data-handling procedures, customer-consent protocols and regular personal-data-protection checks" (page 92). Outcome: "no customer data-breach incidents were recorded during the year" (page 92).

Two categories of material impact are mapped to affected groups (page 90): "Data Protection/Privacy Risks" to short and long-term rental customers, and "Dependence on Accurate Information" to all end-user groups.

No resources or budget are attached to any of these actions.

Targets related to consumers and end-users

Reference: page 96.

Four measurable targets are printed, each tied to an activity and a metric (page 96):

These are the only quantified targets anywhere in the sustainability statement, and two of them are benchmarked against an external reference (the EMEA average NPS of 45.2 and the car sector average of 38).

No performance against them is reported. The statement does not print the achieved NPS scores, complaints ratio or call centre service level for 2025 or 2024, so a reader cannot tell whether any target was met. Nor is a target date given for any of the four.

On involvement, the Group states that "Consumers participate in the definition and monitoring of these targets through regular consultations, surveys and advisory committees. Performance against these targets is monitored through periodic reviews, and adjustments are made based on consumer feedback" (page 95). No advisory committee is named.

The NPS is measured monthly (page 93), so the underlying data exist; only the results are absent from the statement.

Business conduct policies and corporate culture

Reference: pages 96-100.

Five policies are described (pages 98-100):

• Code of Conduct - "sets out the ethical principles and guidelines for responsible business practices, ensuring compliance with local and international legislation, as well as respect for human rights and environmental standards". It "applies to all employees, suppliers and business partners of the Group", is "approved by the Company's Board of Directors, as are any amendments", and monitoring sits with the Human Resources Department. "The Code of Conduct is included in the onboarding package for newly hired employees, and all employees are required to sign a declaration of acceptance and commitment to its principles upon initial issuance or revision" (page 98)
• Internal Regulation of Operation - prepared under Article 14 of Law 4706/2020 and the Hellenic Corporate Governance Code of SEV, covering "regulatory compliance, the management of inside information, transactions with related parties, the prevention of conflicts of interest" and the Company's sustainability policy (pages 98-99)
• Whistleblowing Policy - "a safe and confidential channel for reporting incidents of unethical conduct, irregularities or violations of laws, regulations or corporate policies". In compliance with Directive (EU) 2019/1937, "Autohellas protects whistleblowers from retaliation, ensuring that reports are handled confidentially and investigated impartially" (pages 99-100)
• Anti-Money Laundering Policy - requires "customer due-diligence procedures, identification and verification of customer details and beneficial ownership, checks against international sanctions lists and transaction-monitoring mechanisms". Ownership sits with "the Group's Anti-Money Laundering and Sanctions Compliance Officer" (page 99)
• Board of Directors and Executive Training Policy - under Laws 4706/2020 and 4548/2018, delivered "under an annual training plan approved by the Board of Directors" (page 99)

Culture and investigations. "Autohellas has established clear procedures for investigating incidents involving violations of business conduct, including cases of corruption and bribery. Investigations are conducted independently of the management hierarchy to ensure impartiality. The Group regularly assesses its corporate culture, integrating feedback from employees, governance assessments and compliance audits" (page 100).

Animal welfare is addressed as a nil return: "Although Autohellas operates in a sector where animal-welfare issues are not applicable, the Company acknowledges the related disclosure requirement and confirms that it does not currently maintain any specific policies on this matter" (page 100).

Management of relationships with suppliers

Reference: pages 101-102.

The disclosure is brief. "Autohellas Group applies a Supplier Evaluation Process to ensure that its suppliers comply with environmental, social and governance (ESG) criteria. Beyond operational requirements, Autohellas assesses its suppliers based on their commitment to ethical business practices and sustainability standards" (page 101).

The Code of Conduct extends to the supply chain: it "applies to all employees, suppliers and business partners of the Group" (page 98), and the whistleblowing channel is open to suppliers, who "are encouraged to submit reports concerning criminal acts, suspected incidents of unlawful behaviour, cases of mismanagement or serious irregularities" (page 88). Suppliers are one of the seven stakeholder groups, engaged daily, with "Maintaining long-term partnerships", "Ensuring sustainability", "Timely payments" and "Complaint resolution and flexibility" as their recorded topics of interest (page 59).

On payment practices as they affect suppliers: "Autohellas Group does not maintain a formal policy specifically aimed at preventing late payments; however, it adheres to contractual terms and prevailing industry standards when processing supplier payments. In cases of delays, the Company communicates directly with suppliers to facilitate the timely settlement of outstanding obligations" (page 101).

The Group's dependence on its suppliers is set out in the IRO-1 section: it "relies on vehicle manufacturers for the procurement of its fleet, making it dependent on the sustainability practices, emission-reduction strategies and supply-chain transparency of its suppliers" (page 63).

Not disclosed: the criteria used in the Supplier Evaluation Process, the proportion of suppliers assessed, any outcome of those assessments, and whether social or environmental criteria are used in the selection of new suppliers. No consideration of vulnerable suppliers or of SMEs is described.

Prevention and detection of corruption and bribery

Reference: pages 96-97, 100.

"The Company complies with the United Nations Convention against Corruption through the implementation of its Anti-Bribery/Anti-Corruption Policy, under which it commits to conducting its activities with integrity ... The Company follows a zero-tolerance approach to bribery, corruption and any form of unethical behaviour and requires employees and third parties acting on its behalf to adhere to the relevant principles and procedures" (page 96). The Policy "strictly prohibits all forms of corruption, including bribery, money laundering and extortion" and "is available to all employees through the corporate intranet" (page 100).

Training is described by audience (page 100):

• All personnel receive ad-hoc training
• "all newly hired employees must attend relevant training during their onboarding to understand Autohellas' zero-tolerance policy towards corruption and bribery from the outset"
• Content covers "identifying and preventing incidents of corruption and bribery, understanding legal requirements, the importance of transparency in business activities, the consequences of non-compliance and the available channels for reporting potential incidents"
• "For members of the administrative, managerial and supervisory bodies, the training is even more extensive, focusing on their distinct roles and responsibilities regarding compliance oversight and management of ethical risks", delivered through the Board Training Policy

Detection and investigation. "The Company also applies additional controls and monitoring systems in these high-risk areas ... Investigations are conducted independently of the management hierarchy to ensure impartiality." A whistleblowing platform enables "both identified and anonymous reports" (page 100). Corruption and bribery risks are integrated into the ERM framework: "Risk-mitigation strategies are continuously adjusted based on emerging threats and compliance developments" (page 102).

No percentage of employees or of functions-at-risk actually trained is published, and the training coverage figure appears only as a forward target (page 101).

Targets related to business conduct

(part of MDR-T/GDR-T disclosures)

Reference: page 101. The statement was prepared under the 2023 ESRS, where business conduct targets fell under MDR-T rather than a numbered G1 targets requirement; the content below is the target disclosure the G1 chapter carries.

Under "Metrics and Targets", the Group states: "Although the relevant policies are already in place, Autohellas is committed to continuously strengthening its anti-corruption practices. The Company's future targets include:

• Updating the Anti-Corruption Policy with the aim of (i) conducting an annual review and adaptation of the relevant policies in line with regulatory requirements and best practices, and (ii) achieving a minimum rate of internal training coverage relating to awareness of these policies.
• Further enhancement of staff training: Delivery of refresher training to employees of the Group's Greek subsidiaries, covering at least 50% of employees. These training sessions will be implemented within the next 12 months, with the support and oversight of the Risk Management and Regulatory Compliance Unit" (page 101).

The second target is measurable and time-bound: at least 50% of Greek subsidiary employees within 12 months. The first is only partly so - the annual review is a clear commitment, but the "minimum rate of internal training coverage" is not given a number.

Effectiveness tracking in the absence of fuller targets runs through the metrics table, which reports 8 compliance audits conducted in 2025 against 9 in 2024, and prints no value for whistleblower reports received and resolved, legal cases related to corruption, or fines paid (page 101). The Group also states that it "regularly assesses its corporate culture, integrating feedback from employees, governance assessments and compliance audits to strengthen ethical practices" (page 100).

No target is set for the other material G1 matter, compliance with regulatory and legal requirements, and no baseline is given for the training coverage target.

Incidents of corruption or bribery

Reference: page 101.

"During the year, Autohellas did not face any legal consequences related to anti-corruption and anti-bribery legislation, with no convictions or fines recorded. This reflects the Company's consistent commitment to business ethics, regulatory compliance and safeguarding corporate integrity" (page 101).

The metrics table (page 101):

Compliance audits fell from 9 to 8. No value is printed for the other three rows, so a reader cannot tell from the table alone whether the figure is nil or was not collected. The narrative resolves the two corruption rows by stating that there were no convictions or fines, but leaves the whistleblower report count genuinely unknown.

That gap matters because the Own workforce chapter records two incidents of discrimination or harassment in 2025 (page 89), and the same "We Act TOGETHER" platform and Reporting Management Policy serve both (pages 87-88). The statement does not reconcile the two.

No breakdown by nature of incident, no number of convictions or amount of fines for violation of anti-corruption and anti-bribery laws, and no information on actions taken to address breaches in procedures and standards is given.

Political influence and lobbying activities

Reference: page 101.

A clean nil return: "Autohellas Group does not engage in lobbying activities and does not provide monetary or non-monetary political contributions to government officials, political parties or advocacy organisations. The Company maintains a neutral position on political matters and ensures that its business activities remain independent from undue political influence" (page 101).

Accountability: "The Board of Directors is responsible for overseeing compliance with the Company's political-neutrality policy and for ensuring that no lobbying activities or political contributions take place within Autohellas Group" (page 101).

Revolving door: "Autohellas Group does not appoint individuals to its administrative, management or supervisory bodies who have held equivalent positions in public administration within the two years preceding their appointment, as this is not aligned with the Company's governance practices" (page 101). The governance oversight section repeats the transparency point: "Autohellas Group discloses whether any member of the Board has held positions in the public sector within the past two years, ensuring transparency and preventing potential conflicts of interest" (page 102).

Transparency register: "The Company is not registered in the EU Transparency Register nor in any equivalent lobbying register, as it does not engage in activities that would require such registration" (page 101).

Because no contributions are made and no lobbying is undertaken, the ESRS datapoints for amounts contributed by country and for the main topics covered by lobbying do not arise. No financial or in-kind contribution figure is printed, consistent with the nil position.

Payment practices

Reference: pages 101-102.

The disclosure is a statement of absence plus a forward commitment. "Autohellas Group does not maintain a formal policy specifically aimed at preventing late payments; however, it adheres to contractual terms and prevailing industry standards when processing supplier payments. In cases of delays, the Company communicates directly with suppliers to facilitate the timely settlement of outstanding obligations" (page 101).

The two headline ESRS metrics are not yet produced, and the Group gives a date for when they will be: "From 1 January 2026 onwards, the relevant indicators (average invoice-payment time and the percentage of on-time payments) will be systematically monitored and optimised through the implementation of the new ERP (back office) system, which aims to improve efficiency and strengthen financial-management processes" (page 102).

One datapoint is given for the year: "Up to 31.12.2025, Autohellas did not face any legal proceedings related to late payments" (page 102).

So for FY2025 the average time to pay an invoice from the date the contractual or statutory term starts is not disclosed, the percentage of payments aligned with standard payment terms is not disclosed, and there is no description of standard payment terms by supplier category. Timely payment is recorded as a topic of interest for both suppliers and financial institutions in the stakeholder table (page 59).

No statement is made about whether SMEs are treated differently, which is the point of the requirement.