AVAX

Reference: page 36 (ESRS content index, page 166); detail on pages 36-45.

AVAX is managed by an eleven-member Board of Directors, elected by the General Meeting on 12.06.2024 for a three-year term to 13.06.2027. Six members are executive (including the Chairman) and five are non-executive (45%), of whom four are independent (36%); three members are women (27%). Average tenure is 12.7 years and average age 65.7 (page 38).

Board committees are the Council Management / Strategic Planning Committee, the Risk Management Committee, the Audit Committee, the Remuneration and Nomination of Board Members Committee, the ESG & Sustainability Committee and the Project Bidding Committee (pages 39-45).

The ESG & Sustainability Committee is chaired by executive Board member Antonios Mitzalis, with the Group Financial Officer as Vice Chairman and members drawn from HR, QSHE, Governance & Compliance and the ESG Head (page 44). Its remit includes implementing the Sustainable Development Strategy and Policy, ensuring resource adequacy, and approving the Group's annual Sustainability Report (pages 43-44).

On oversight of impacts, risks and opportunities the report states: "Aside from the ESG & Sustainability Committee and the ESG Head, the Risk Management Committee, the Risk Officer and the Audit Committee are responsible for the oversight of impacts, risk and opportunities" (page 44).

It also states plainly: "There is no employee representation in the administrative, management and supervisory bodies" (page 38).

Reference: page 53 (ESRS content index, page 166).

"The administrative, management and supervisory bodies and the relevant committees are informed periodically and/ or in the context of special needs about the impact of material issues on the Company's financial performance and on the wider society and the environment by the ESG/ Sustainability Committee and the ESG Head, who are assisted by a specialized external Company-consultant" (page 53).

Beyond the general strategic framework set by the top management body and its committees, AVAX has created a Strategy Officer role reporting directly to the CEO (page 53).

The disclosure then describes the reporting-management framework established under the Greek whistleblowing law, which also absorbs reports on labour legislation (violence and harassment) and on equality and human rights at work. Reports may be submitted by employees, collaborators, consultants, shareholders, members of management bodies and committees, subcontractors, partners and suppliers, and third parties connected to them. Alongside the dedicated electronic platform, channels include postal mail to the Internal Reporting Receiving and Monitoring Officer (R.M.O.), a recorded voice-messaging system where the reporter has consented, and verbal reporting at a personal meeting with the officer (page 53).

The report does not set out a calendar of specific matters addressed by each body during 2025, nor how sustainability matters were taken into account in particular decisions.

Reference: pages 53-54 (ESRS content index, page 166).

AVAX reports a nil return: "During the fiscal year 2025, the Group did not link sustainability performance results or other climate-related parameters to incentive schemes for members of its administrative, management and supervisory bodies, as it has not developed such an incentive scheme" (page 53).

A structural reason is given: "due to the specific nature of the Company's activity and the assignment of a large part of its projects by the Public Sector, such incentives cannot be included, as there is no relevant freedom or discretion to decide and shape the incentive system" (pages 53-54).

The Group nonetheless argues an indirect link: "through the implementation of the Sustainable Development Policy, which applies to all the Group's companies, all administrative, management and supervisory bodies are given the incentive to manage the operation of the Group and make decisions based on the principles of sustainability" (page 54). The Board Members' Remuneration Policy "links the remuneration system to the suitability and performance of the members of the Company's highest governing body and, through the relevant Suitability Policy, to the adequate understanding, among others, of the sustainability issues and framework" (page 54).

No percentage of variable remuneration linked to sustainability or climate targets is therefore disclosed, because none exists.

Reference: page 54 (ESRS content index, page 166); narrative on pages 54-56.

The statement carries the mapping table required by GOV-4, tying each due diligence element to the chapters that carry it: integration into governance, strategy and business model to GOV-2, GOV-3 and SBM-3; stakeholder involvement to GOV-2, SBM-2 and IRO-1; identification and assessment of negative impacts to SBM-3 and IRO-1; implementation of measures to E1-3, E3-2, E5-2, S1-3, S1-4 and G1-3; and monitoring of effectiveness and communication to GOV-2 (pages 54-55).

The Group is candid about the maturity of the process: "The Group has not developed an autonomous holistic due diligence process, but incorporates multiple internal processes and programs, with the aim of identifying, preventing and mitigating negative impacts arising from the Group's own activities and value chain" (page 55). It adds that "in 2025, a Third-Party Due Diligence Questionnaire was developed" (page 55).

The framework rests on "the UN Guiding Principles on Business and Human Rights and the OECD Guiding Principles" (page 56), and is supported by nine certified management systems, listed as ISO 9001, ISO 14001, ISO 45001, ISO 50001, ISO 37001, ISO 27001, ISO 39001, ISO 22301 and ISO 14064-1 (page 55).

Reference: page 56 (ESRS content index, page 166); narrative on pages 56-58.

AVAX operates an Enterprise Risk Management framework within the broader Internal Control System, "based on an approved Risk Management Policy and Methodology that takes into account internationally recognized standards, such as the COSO Enterprise Risk Management (ERM) framework" (page 56). Risks are assessed on probability and potential impact against strategic, operational, regulatory and reporting objectives, and the results feed "the data collection, processing and verification processes used for the preparation of the Sustainability Report" (page 56).

Controls specific to sustainability reporting are described: "the Group applies specialized internal controls over ESG data, addressing risks such as data completeness and reliability or incorrect data transfer" through a two-level control mechanism (page 57):

1. Primary verification – data is entered into the ESGENIOUS sustainability database by designated Data Owners in the business units, responsible for completeness and documentation of primary data.
2. Secondary verification – "Before finalization, each element is cross-verified by the Head of the department."

Final results are validated by the ESG Head in ESGENIOUS before being passed for integration into the published financial statements (page 57). Internal Audit is "an independent, objective, auditing, assurance and advisory function... supervised by the Audit Committee of the Board of Directors and administratively subordinate to the CEO" (page 57).

Reference: pages 58, 61, 62, 64 (ESRS content index, page 166); value chain on page 66.

AVAX is a Greek construction group with a presence in Europe, Asia and Africa. Construction is organised in three business areas: Infrastructure & Building Projects, Energy & Industrial Projects (EPC, specialising in LNG facilities and power plants) and Network Projects (fuel, natural gas and telecommunications networks) (pages 60, 62-63). Alongside construction the Group runs Concessions/PPPs, real estate development (AVAX Development), energy (iXion), facility management (TASK AVAX), vehicle inspection (AUTECO) and Athens Marina (pages 59-61).

The Group "holds the highest public works contractor qualification provided for (7th class)" and can bid independently for public works with an unlimited budget; subsidiary ETETH holds a 6th grade degree (pages 59, 65). Customers "mainly consist of government agencies and large private entities" (page 63).

Value chain (page 66). Upstream covers strategic study and design, procurement of materials, and project implementation, where "significant environmental and social impacts are identified related, among others, to Scope 3 emissions, the use of natural resources, working conditions in the supply chain and business ethics issues". Downstream covers delivery, operation, maintenance and management, where the report assesses "impacts and risks related to the energy efficiency of constructions, resilience to climate change, user safety and health, as well as end-of-life waste management".

Twelve ESRS areas are listed as important to the business, from energy transition and climate change through to responsible supply chain (page 63).

Reference: page 67 (ESRS content index, page 166); table on pages 68-69.

"Stakeholders are defined as those who have a direct or indirect influence on the Group's operations and activities, as well as those who are affected by its business activities. Stakeholders are evaluated at regular intervals and are subject to review when necessary, always taking into account the Group's values, strategy, and the overall business context" (page 67).

Eleven stakeholder groups are tabulated with engagement method and purpose (pages 68-69): shareholders and investors, employees, customers, suppliers, subcontractors, partners, government, state and other bodies, fund providers (banks), media, regulatory and sustainable development bodies, and local communities.

Methods range from meetings and presentations, sustainability reports and site visits, internal newsletters, seminars and workshops, supplier inspections and progress reports, feedback and experience-exchange sessions, participation in consultations and public meetings, through to collaboration with local organisations and volunteer programmes. Stated purposes include "Ensuring sustainable supply chains and partnerships", "Managing risks from subcontractors" and "Strengthening social cohesion and positive impact on the local community" (pages 68-69).

Stakeholder input fed the double materiality assessment directly: specialised questionnaires were developed for the ten high-priority issues and the responses "were converted into quantitative data" to build the Impact Materiality axis from external stakeholders and the Financial Materiality axis from internal stakeholders (page 85).

Reference: page 69 (ESRS content index, page 166); IRO tables on pages 70-79, matrix on page 80.

The 2025 double materiality assessment identified 10 material sustainability issues (page 82). Ranked on the materiality matrix (page 80) they are: 1 creating and distributing economic value, 2 ensuring business continuity and emergency preparedness, 3 combating bribery and corruption, 4 employee health and safety, 5 employee development, 6 labor practices, 7 waste management and circular economy, 8 water management, 9 climate change adaptation, 10 energy management.

The material ESRS standards are E1, E3, E5, S1 and G1 (pages 35, 85, 166). E2, E4, S2, S3 and S4 are not material.

Two tables set out the IROs. The risk and opportunity table (pages 70-74) lists 31 rows across E1, E3, E5, S1, G1 and the entity-specific topics of responsible supply chain, cybersecurity and economic value creation, each typed Risk or Opportunity and placed in the value chain. The impact table (pages 74-79) lists 13 impacts typed positive or negative, actual or potential, with time horizon.

Examples: "Failure to respond to extreme weather events may increase the vulnerability of infrastructure and slow down the progress of work" (Risk, own operations, page 70); "The lack of a clear and documented transition plan towards a low-emission model substantially increases the transition risk" (Risk, own operations, page 71); and, as an actual negative impact, greenhouse gas emissions in Scopes 1, 2 and 3 which "negatively impact long-term environmental sustainability" (whole value chain, long term, page 75).

Reference: page 82 (ESRS content index, page 166); methodology on pages 82-85.

AVAX describes a six-step double materiality methodology "aligned with international standards (CSRD, ESRS)" (page 83):

1. Defining purpose and framework, scoping upstream (materials, equipment and services from partners and subcontractors), own activities, and downstream (use, maintenance, disposal and end of life of projects), "in accordance with ESRS 1, paragraph 43 and ESRS 2 IRO-1" (pages 83-84).
2. Research on international standards and industry mapping, with "An extensive sector benchmarking of the material issues that emerge for the Group's sector of activity... based on SASB Materiality Maps", classified Class A (AVAX's 2024 material issues plus international standards), Class B (domestic peers) and Class C (foreign peers) (page 84).
3. IRO analysis, assessing impact significance on "extent, scope, irreversibility and likelihood of occurrence", with human rights integrated "in accordance with ESRS S1, S3 and S4". Risks were scored on probability and severity "on a scale of 1-5, in accordance with the EFRAG Materiality Assessment Implementation Guidance", "at the level of inherent risk, i.e. before the implementation of any mitigation or compensation measures" (page 84). Dependencies were assessed "in accordance with ESRS 1 paragraph 50" (page 84).
4. Financial materiality, based on probability and size of financial impact on revenue, costs, investment requirements, asset value and access to capital, run "in collaboration with the Risk Manager and the relevant functional areas" (page 85). 5-6. Matrix, final evaluation and disclosure, reviewed by the Sustainability Committee (page 85).

"The comparative analysis resulted in a total of 15 issues with high importance scores. Subsequently... the Group proceeded to a targeted selection of 10 high-priority issues for the stakeholder consultation phase" (page 85).

Reference: pages 166-168.

The statement carries a real ESRS content index, headed "Appendix – Disclosure Requirements": "The table below presents all the disclosure requirements of ESRS 2 according to the European sustainability reporting standards (ESRS) and the five thematic standards that are considered significant for the Group and guided the preparation of sustainability statements" (page 166). It is cross-referenced from BP-2: "The list of disclosure requirements incorporated by reference and their location in this report can be found in the table on page 166" (page 34).

The index lists each disclosure requirement with a single page number. ESRS 2: BP-1 (32), BP-2 (33), GOV-1 (36), GOV-2 (53), GOV-3 (53), GOV-4 (54), GOV-5 (56), SBM-1 (58, 61, 62, 64), SBM-2 (67), SBM-3 (69), IRO-1 (82). E1: SBM-3 (86), IRO-1 (93), E1-1 (86), E1-2 (97), E1-3 (98), E1-4 (98), E1-5 (99), E1-6 (100). E3: IRO-1 (103), E3-1 (103), E3-2 (103), E3-3 (105), E3-4 (106). E5: IRO-1 (107), E5-1 (108), E5-2 (108), E5-3 (111), E5-4 (112), E5-5 (112). S1: SBM-2 (128), SBM-3 (128), S1-1 (131), S1-3 (135), S1-4 (136), S1-6 (141), S1-7 (144), S1-8 (144), S1-9 (145), S1-12 (148), S1-13 (148), S1-14 (148), S1-16 (149), S1-17 (149). G1: GOV-1 (154), IRO-1 (154), G1-1 (156), G1-2 (158), G1-3 (161), G1-4 (163), G1-5 (164), G1-6 (165).

Two points a reader should note. IRO-2 does not appear as a row in its own index. And the index omits S1-2, S1-5, S1-10, S1-11 and S1-15 even though S1 is material, and omits E1-7, E1-8, E1-9, E3-5 and E5-6.

Reference: page 86 (ESRS content index, page 166).

AVAX has no finalised transition plan. The disclosure states: "The Group is in the process of preparing a Transition Plan, in line with the National Climate Law (Law 4936/2022) and the requirements of ESRS E1-1. Although the Transition Plan has not yet been finalized, key actions have already been implemented that constitute fundamental elements of a transition strategy, namely:

• The completion of an assessment of natural and transitional climate risks through climate scenario analysis, which provided a documented assessment of the Group's risk level and resilience.
• The comprehensive valuation of greenhouse gas emissions for Scope 1 and Scope 2, as well as the valuation of indirect emissions (Scope 3), in 2025, enhancing the transparency and completeness of the Group's climate footprint" (page 86).

The preceding paragraph records that "In 2025, the Group completed its climate risk and resilience assessment through climate scenario analysis, in accordance with the requirements of ESRS E1", covering physical and transition risks over the short term (to 2027), medium term (to 2030) and long term (to 2050), including "a qualitative mapping of the potential financial impacts" for transition risks (page 86).

The intended next step sits in E1-2: "in the context of developing the transition plan for climate change mitigation, the Group aims to develop short-term and long-term greenhouse gas emission reduction targets, as well as decarbonization actions and mechanisms, all of which will frame a stand-alone Climate Action Policy" to be "discussed and approved by the Board of Directors" (page 98).

Consequently there is no decarbonisation lever quantification, no capex or opex allocated to the plan, no locked-in emissions assessment and no GHG reduction target for 2025.

Reference: pages 86-93 and 95-97.

Back-filled from ESRS 2 SBM-3 and the E1 IRO-1 sections, where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification. Risks are assessed as natural (physical) or transitional. Physical risks were narrowed from the full ESRS list to "flood, forest fire and heatwave as acute risks, and sea level rise as a chronic risk" (page 87). Transition risks were assessed across five mechanisms: "(a) Legislative risks – ... carbon pricing and energy efficiency and environmental compliance regulations. (b) Market risks – ... the increase in energy and fuel costs, the increase in the cost of materials and services and the indirect pass-through of carbon costs to prices. (c) Technological risks – ... the need for more efficient or low-emission equipment, mandatory technical upgrades... (d) Legal risks – ... non-compliance with environmental or climate regulations, fines and penalties... (e) Reputational risks – ... investor and customer demands, public image, and sustainability (ESG) ratings" (pages 87-88).

Methodology. The assessment covered activities under organisational and operational control, grouped into the Infrastructure – Construction sector and the Technical Support and Facilities Management sector, plus owned or operated real estate. Upstream raw materials, equipment, suppliers and transport networks were included qualitatively; "The assessment did not extend to the operation or use phase of the projects after the completion of construction, as the Group does not exercise operational control over them" (pages 86-87). It followed "the European Commission's Technical Guidelines for Strengthening the Resilience of Infrastructure to Climate Change, and included sensitivity, exposure and vulnerability analysis stages for each infrastructure" (page 88).

Scenarios. Physical: "the IPCC RCP4.5 (intermediate stabilization scenario) and RCP8.5 (adverse high emissions scenario) scenarios were used, with particular emphasis on RCP8.5". Transition: "IEA transition scenarios (STEPS, APS and NZE) were examined, with emphasis on the Net Zero Emissions by 2050 (NZE) scenario, compatible with limiting warming to 1.5°C (SSP1-2.6)" (page 88). Guidance came from IFRS S2 (ISSB), which "incorporates the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD)", and IPCC AR5 regional projections (pages 96-97).

Horizons and timing. Short term to 2027, medium to 2030, long to 2050; construction sites were assessed only to 2027 "given that the projects are completed within this period", while buildings and operational infrastructure and all transition risks were assessed on the 2031-2050 horizon (page 88). The analysis was completed in 2025 (page 86).

Not disclosed: the global average temperature projection associated with each scenario.

Reference: pages 86-93.

Back-filled from ESRS 2 SBM-3, where the resilience analysis is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

AVAX performed a resilience assessment as part of its 2025 climate scenario analysis, with a stated method: "All risks were assessed before implementing mitigation measures and at the final stage, the adaptation measures implemented by the Group for significant risks were identified... where protection is sufficient and the activity can withstand the risks, resilience is considered high... Conversely, where vulnerabilities remain or protection does not fully cover all risks, resilience is assessed as moderate" (page 89).

Results (Table 1, pages 90-93).

• Physical risks – high resilience. For floods and heat, "The Natural Climate Risk analysis demonstrates that the Group's resilience is assessed as high, both for existing infrastructure and construction sites. In infrastructure, resilience is based on vulnerability assessment, strengthening drainage systems and adapting design, while in construction sites it is ensured through adapting construction site practices, protecting materials and equipment and incorporating the requirements of Environmental Conditions Approval Decisions." The underlying risk is not small: under RCP8.5 the assessment "shows a high risk to existing infrastructure in the long term, while at construction sites the risk is assessed as moderate in the short term".
• Transition risks – moderate resilience. For market risk: "Resilience to transitional market risks is assessed as moderate, as although compliance measures are implemented, the increase in energy, fuel and material costs, as well as the indirect pass-through of carbon costs to prices, create uncertainty for the future full assurance of compliance and financial stability" (pages 91-92). For legislative risk: "Resilience to legislative transition risks is assessed as moderate, as although compliance measures are implemented, uncertainty about the evolution of the regulatory framework limits full compliance assurance" (pages 92-93).

Financial effects are not quantified. "At the financial level, a qualitative assessment was made of whether the identified climate risks may lead, for example, to an increase in operating costs, energy costs or other financial burdens, without quantifying the amount of such impact" (page 87).

Areas of uncertainty are acknowledged only through the moderate transition-resilience ratings; capacity to adjust or adapt is not discussed in terms of financial flexibility or asset redeployment.

Reference: page 97 (ESRS content index, page 166); narrative on pages 97-98.

Climate policy sits in two documents rather than a dedicated climate policy: the Environmental Policy (ISO 14001:2015) and the Energy Management Policy (ISO 50001:2018), which "function as a cornerstone for the management of all the material environmental issues it has identified" (page 97). Both "are publicly available on the Group's website and have been approved by the Group's highest governance body, the Board of Directors", with the Head of ESG responsible for implementation and updating and the ESG & Sustainable Development Committee responsible for informing the Board (page 97).

The Group "complies with the guidelines of the National Climate Law (Law 4936/2022), the National Plan for Energy and Climate and the National Strategy for Adaptation to Climate Change, aiming for net zero by 2050" (page 97).

Energy Management System commitments are listed (page 98): improving the energy efficiency of facilities and planned projects; saving natural resources at all stages of construction, operation and project management; procurement of highly energy-efficient products and services; providing the necessary resources for energy-saving actions; compliance with current and emerging obligations "to achieve climate neutrality"; and continuous training and awareness-raising of employees.

A dedicated climate policy is promised but does not yet exist: "the Group aims to develop short-term and long-term greenhouse gas emission reduction targets, as well as decarbonization actions and mechanisms, all of which will frame a stand-alone Climate Action Policy" (page 98).

The policies cover mitigation and adaptation but the report gives no policy-level treatment of energy efficiency targets, renewable energy deployment or other ESRS E1-2 sub-topics beyond these commitments.

Reference: page 98 (ESRS content index, page 166).

This is the thinnest disclosure in the E1 chapter. In full, the actions disclosure reads: "In implementation of the objectives of the Sustainable Development Strategy for a continuous contribution to curbing the effects of Climate Change and developing sustainable constructions, the Group places particular emphasis on implementing actions aimed at reducing greenhouse gas emissions and by extension limiting its environmental footprint. The Group continues to carry out non-quantified actions in accordance with the ESRS related to energy saving and energy efficiency, while through the actions to protect and restore the natural environment implemented by the Group, it contributes to the strengthening of ecosystems that function as carbon sinks, enhancing the role they play in climate regulation" (page 98).

No individual action is named, scoped, dated or costed. No capex or opex is allocated to climate action, and the EU Taxonomy disclosure reports 0% aligned turnover, capital expenditure and operating expenditure for 2025, with both eligible activities failing the DNSH assessment (pages 119, 125-127).

The nearest thing to a resourced action sits in the E1-4 target table: rolling out the ESGenius! sustainability data platform to all construction sites, reducing electricity consumption at fixed facilities year on year, and certifying the company for Building Information Modeling under EN ISO 19650-2:2018, all dated 2026 (page 99). Adaptation actions appear indirectly through the resilience assessment, which names strengthened drainage systems, adapted design, adapted construction-site practices and protection of materials and equipment (page 90).

Reference: page 98 (ESRS content index, page 166); target table on page 99.

AVAX discloses no greenhouse gas emission reduction target. The disclosure states only that "The Group will assess the results of the climate risk analysis and create a roadmap with adaptation and mitigation actions where required, a specific timeline and performance indicators (KPIs)" (pages 98-99).

The target table that follows contains three items, none of them an emissions target (page 99):

There is therefore no base year, no absolute or intensity reduction percentage, no 2030 milestone, no Scope 3 target and no science-based target validation. The electricity target is directional rather than quantified. The commitment to develop "short-term and long-term greenhouse gas emission reduction targets" is deferred to the future Climate Action Policy (page 98).

Against that, energy consumption rose in 2025: total energy consumption went from 67,857.14 MWh in 2024 to 102,708.05 MWh in 2025, while energy intensity per net revenue fell from 0.0001135 to 0.0001072 MWh/€ (pages 99-100).

Reference: page 99 (ESRS content index, page 167); tables on pages 99-100.

Total energy consumption rose 51% year on year and is 100% fossil. The report is explicit: "There is no energy consumption from any other source by the Group other than fossil sources for 2025. The Group has no energy production except for backup generators that produce negligible quantities in cases of power outages from the grid" (page 99). No renewable energy consumption, no nuclear share and no self-generated energy are reported.

Energy intensity is disclosed for high climate impact sectors, the NACE F Construction sector (page 100):

Conversion factors are "the coefficients of the Ministry of Energy and Rural Development for the climate law" (page 99). Note that the narrative on page 99 gives total 2025 consumption as 102,718 MWh while the table gives 102,708.05 MWh.

Reference: page 100 (ESRS content index, page 167); tables on pages 100-102.

2025 is the first year AVAX has quantified Scope 3. Calculation follows "ISO 14064-1:2018 and in line with the National Climate Law of Greece, Directive (EU) 2018/2066, Joint Ministerial Decision 181478/965/2017 and the Greenhouse Gas Protocol" (page 100).

Scope 3 is 94% of the footprint, and category 1 alone is 437,121.90 tCO2eq, 91% of Scope 3. Other categories: capital goods 6,724.04; fuel and energy-related activities 7,632.90; upstream transport and distribution 6,022.18; waste generated in operations 19,345.18; business travel 726.24; employee commuting 1,395.68 (page 101).

Seven categories were screened in; "the remaining categories (downstream) were either deemed not relevant (e.g. Categories 9, 10, 14), or not significant (Category 8, 11, 12, 15) according to the GHG Protocol criteria" (page 102). Methods are disclosed by category: "a spend-based methodology was applied for Categories 1, 2, 4 and 6... the average data method for Category 3, the waste-type specific method for Category 5 and the distance-based method for Category 7" (page 102).

Two nil returns: "Percentage of Scope 1 GHG emissions from regulated emission trading schemes – 0.00" (page 100), and Scope 3 is "calculated without including carbon removals nor the use, purchase, sale or transfer of carbon credits or greenhouse gas emission allowances" (page 102). No 2024 comparative is given for any GHG figure.

Reference: page 103 (ESRS content index, page 167); narrative on pages 103-105.

Water is covered by existing environmental policy rather than a dedicated water policy. "The Group recognizes the management of water and marine resources as a material environmental issue and responds and has adopted policies and procedures that meet the requirements of ESRS E3-1" through the Environmental Policy Statement, the Sustainable Development Policy and the ISO 14001:2015 Environmental Management System, "which covers the sustainable management of water resources and the prevention of pollution" (pages 103-104). Implementation "is supervised by the Head of ESG and the ESG Committee" (page 104).

AVAX gives an explicit reason for not adopting a water-stress-specific policy: "In accordance with the requirements of ESRS E3-1 §13, the Group assesses the areas in which it operates, taking into account international indicators and available data. Therefore, the existing environmental management policies and procedures, including the Environmental Management System ISO 14001:2015, adequately cover the needs of water resources management, so it has not been deemed necessary to adopt an additional specialized policy for these specific areas" (page 104).

The same reasoning is applied to marine resources: "The Group, although it has not adopted a separate policy exclusively for marine resources, covers the relevant requirements through the Environmental Policy Statement and the Environmental Management System ISO 14001:2015, which are applied to all projects, including port and coastal projects... If future projects with significant impacts on marine ecosystems are undertaken, the Group will consider developing a specific policy or process to manage the associated risks and opportunities" (page 105).

Design-stage integration is drawn from the Business Conduct Policy, under which "the purpose of environmental protection must govern the design, planning and construction of projects" (page 104).

Reference: page 103 (ESRS content index, page 167); narrative on pages 104-105.

Actions are operational and site-level. They include "training personnel for responsible water use, regular inspection and maintenance of hydraulic equipment to avoid leaks, rational use of water for wetting, monitoring and recording of potable and non-potable water consumption, appropriate planning of work to avoid waste and immediate response to leakage incidents". The Group also prohibits unlicensed abstraction: "water abstraction from natural water bodies without a permit, such as rivers, streams, lakes or unlicensed drilling, is prohibited" (page 104).

During construction, "rainwater and excavation water management systems are designed. Surface water management measures are implemented on construction sites, with the aim of avoiding pollution of water and marine recipients", with emphasis on rational water use during concreting (page 104). Scope covers "all Group construction sites where excavations are carried out or groundwater is present, projects with increased stormwater management requirements, coastal and port projects, as well as central facilities where water consumption is monitored" (page 105).

The Group states the limits of the disclosure itself: "In accordance with the requirements of ESRS E3-2 and ESRS 2 MDR-A, the Group declares that, during the current reporting period, it has not yet adopted fully developed action plans with defined time horizons, quantitative progress indicators or detailed allocations of financial resources (Capex and Opex) specifically related to the management of water and marine resources. The reason is that the Group is in the process of developing a comprehensive monitoring framework" (page 105).

Reference: page 105 (ESRS content index, page 167); narrative on pages 105-106.

AVAX discloses operational objectives rather than measurable targets. "The Group applies the principle of rational water management in all its operations and has established specific operational objectives within the framework of the Environmental Management System ISO 14001:2015. These objectives include the gradual reduction of water consumption at the headquarters, the prevention and avoidance of pollution of water and marine resources on projects with the aim of zero environmental accidents, as well as the rational use of water in all construction site activities" (page 105).

None carries a base year, a percentage or a deadline.

The company states why, and when that will change: "The Group is in the process of evaluating the possibility of developing quantitative targets for water resources management, which will be adopted in subsequent periods, when the development of a unified data collection system at group level is completed, covering consumption, abstraction, discharges and data per watershed, so that a baseline can be determined and measurable targets can be set in accordance with the requirements of the standard" (page 106).

This matters because water management ranks 8 of 10 on the materiality matrix on impact materiality, the highest-scoring environmental issue on that axis (page 80), and because 512,520.56 m3 of the Group's 552,890.56 m3 of water use in 2025 was in areas of high water stress (page 106).

Reference: page 106 (ESRS content index, page 167).

93% of water use sits in areas of high water stress. "The WRI Aqueduct tool has been used to identify areas with high water stress, while all data is collected from external provider documents" (page 106).

The uses are broken out in the narrative: 288,138 m3 of potable water from the mains for hygiene and catering at offices and construction sites; 217 m3 of potable water in containers where mains access was not possible; non-potable water for dust control on construction sites; and 9,394 m3 for other uses such as preparing and maintaining concrete (page 106).

The Group distinguishes withdrawal from consumption and estimates the latter: "Water consumption as defined by the ESRS (i.e. pumping minus discharges) can be estimated through bibliography (100% estimate) at 282,067.5 m3 in areas with high water stress, 293,371 m3 in total and a consumption intensity of 306.2 m3/million €" (page 106).

Data quality is disclosed: consumption is metered, but "In cases where data collection is not possible, assumptions and projections are made based on data from previous periods and/or financial data, in total, the specific data is estimated to concern approximately 9.3% of the water use records" (page 106).

Two nil returns: "During the reporting period, no recycled or reused water was recorded for all Group companies", and stored water and changes in stored stocks "are zero for the reporting period, as there are no relevant water storage infrastructures or processes" (page 106). No 2024 comparative is given.

Reference: page 108 (ESRS content index, page 167).

AVAX states the absence of a dedicated policy and names the instruments that stand in its place: "The Group does not have a specific policy related to waste or the circular economy, however, it is committed to preventing environmental pollution through its Environmental Policy and its Sustainable Development Policy (which are posted in its facilities, construction sites and online). Within the framework of these policies, it has set as its main goal the reduction of waste produced both in its facilities and on the construction sites of the projects it implements, by implementing its certified ISO 14001:2015 System" (page 108).

The policy content is expressed as nine waste-reduction practices applied "to all activities and operations of the company's projects and facilities" (page 108): optimisation of ordering "so that materials are ordered at the appropriate time and in accurate quantities"; minimisation of material losses; appropriate storage; "Separation of hazardous and non-hazardous materials/waste materials, so that non-hazardous materials are not contaminated and end up as hazardous waste"; execution of work by specialised personnel; proper maintenance of equipment, machinery and vehicles; office-level measures such as double-sided printing and long-lasting oils; site organisation and tidiness rules; and training of project personnel and subcontractors.

"The policies are available to all employees, subcontractors and other interested parties via the Internet and the Group's facilities, in order to ensure information and compliance" (page 108). The disclosure is framed against the European Green Deal and the transition to circular systems in production and consumption (page 108).

Reference: page 108 (ESRS content index, page 167); narrative on pages 108-110.

Actions cover construction and demolition waste and the wider reuse and recycling programme.

Reuse (page 109): "Reuse of suitable excavation materials in backfills"; reuse of concrete from demolitions and other materials removed from the project where permitted; and "Use of other materials not useful in one project as useful in another". Beyond construction materials the Group promotes "Reuse of high-end computers by users with lower requirements", reuse of site containers and equipment on later projects, "Use of vehicle and machinery components at the end of their life cycle as spare parts", and "Return of packaging materials to the company's respective suppliers for reuse".

Recycling (pages 109-110). Waste recycling programmes are written per site and facility and specify the type of waste, sorting and storage method, collection frequency, the management body, the recording process "(e.g. from shipping notes, weighing lists, etc.)", staff training and "Economic and technical data". Named streams: used lubricating oils and hazardous liquid waste collected in special containers "to avoid possible leaks" and passed to licensed managers; paper, with priority on office paper; excavation and demolition waste, where the site "if permitted, reuses suitable excavation and demolition products, or manages the rocky excavation waste (e.g. via mobile crushers) to produce aggregates for use on the project"; computers, ink and toner; and tyres, batteries, iron and wood.

Resources are not quantified: "The specific actions are budgeted for each project and are not considered significant at this time" (page 110).

Reference: page 111 (ESRS content index, page 167); narrative on pages 111-112.

AVAX discloses internal targets and says plainly that they are not ESRS-compliant: "The Group has set as its main objective the reduction of waste generated both in its facilities and on the construction sites of the projects it implements. To achieve this objective, it has set monitoring indicators for non-hazardous and hazardous waste generated by its activities and operations, and targets related to waste management. At present, there are no quantified targets according to the ESRS, however, the Group has set some internal targets related to waste management, the following are mentioned:

• Percentage of hazardous waste in relation to total waste <0.5%
• Zero environmental accidents from leaks of liquid hazardous waste, to avoid pollution and the production of hazardous waste" (pages 111-112).

A third priority is stated for resource use: "the company has set as its main priority the reuse of the largest possible percentage of waste at its place of production or in its other projects and facilities" (page 112).

Performance against the one numeric target can be read from the E5-5 table: hazardous waste of 2,858.88 tonnes against total waste of 2,266,024.02 tonnes is 0.13%, inside the <0.5% threshold (page 112).

No target is set for total waste reduction, for diversion from disposal, or for recycled content in materials, and no base year or deadline is attached to any of the three.

Reference: page 112 (ESRS content index, page 167).

The ESRS content index lists E5-4 Resource inflows at page 112, and page 112 carries the heading "[E5-4, E5-5] Resource Inflows and Outflows". No resource-inflow data follows. The only sub-heading under it is "[E5-5] Resource Outflows", and the only table is the waste-management table. No overall total weight of products and technical and biological materials used, no share of biological materials, no share of secondary reused or recycled components, and no materials are named.

The nearest relevant content sits in E5-1 and E5-2, which describe inflow-side management qualitatively rather than quantitatively: ordering optimisation "so that materials are ordered at the appropriate time and in accurate quantities", minimisation of material losses and appropriate storage (page 108), and reuse of suitable excavation materials in backfills and of crushed rocky excavation waste "to produce aggregates for use on the project" (pages 109-110). The Group's stated circular-economy priority is "the reuse of the largest possible percentage of waste at its place of production or in its other projects and facilities" (page 112).

This entry is marked reported because the company's own ESRS content index lists E5-4 with a page reference. A reader checking that page will find no inflow figures.

Reference: page 112 (ESRS content index, page 167).

Preparation for reuse is reported as 0.00 tonnes for both hazardous and non-hazardous waste, and incineration is zero.

"The above quantities are collected based on the documents from external partners as reported in the National Waste Register. The Group does not produce radioactive waste, while the waste produced that is not recycled is 895,677 tn, which corresponds to 39.5% of the total in 2025" (page 112).

All hazardous waste is diverted from disposal. The entire disposal figure is non-hazardous landfilling, which is consistent with the composition of the waste stream: construction and demolition waste including excavated soil accounts for 2,120,435.84 tonnes of the total (page 111). No 2024 comparative is given.

Reference: pages 111-112 (E5-5 in the ESRS content index, page 167).

The 2025 waste stream is disclosed by European Waste Catalogue chapter (page 111):

Construction and demolition waste is 94% of the total. "The Group has recognized waste management as a significant issue and meets its regulatory obligations on an annual basis in relation to the management of hazardous and non-hazardous waste generated" (page 111).

Waste is also a material Scope 3 category: waste generated in operations produced 19,345.18 tCO2eq in 2025, calculated with "the waste-type specific method" (pages 101-102). Disposal routes and the 39.5% non-recycled share are in E5-5 (page 112).

Reference: page 131 (ESRS content index, page 167); narrative on pages 131-135.

Four policy areas are described (page 131): health, safety and well-being; protection of human rights; diversity and equal opportunities; and training and development.

• Health and Safety Policy Statement, backed by an ISO 45001:2018 system "universally applied across all facilities, construction sites, and activities of the Group, without any exceptions". Responsibility sits with the Department of Quality, Health and Safety, Environment and Sustainable Development (pages 131-132). A Road Safety Policy certified to ISO 39001:2012 covers driving and traffic conditions for employees, partners, subcontractors and third parties (page 132).
• Human Rights Protection Policy: the Group "prohibits forced labour, and fully respects the freedom of association", "defends children's rights", and states that "All employees are paid an adequate salary, in accordance with the legislation in force in each country and are covered by social security". Compliance and updating sit with the Human Resources Department, "with final approval from the Board of Directors" (pages 132-133).
• Equality, Diversity & Inclusion Policy, covering recruitment impartiality, age diversity, disability inclusion and LGBTQ+ employees, with breaches "subject to disciplinary sanctions or/and termination of the employment contract" (pages 133-134).
• Violence and Harassment Policy, aligned with Greek Law 4808/2021, covering "employees, consultants, volunteers, trainees, job candidates, and individuals whose employment relationship has ended", with a three-member Complaint Investigation Committee and protection against retaliation (pages 134-135).

Policies are communicated through the intranet, the workplace and the ethics platform at https://ethicsavaxgroup.avax.gr/#/ (page 135).

Reference: page 135 (ESRS content index, page 167); narrative on pages 135-136.

"The Group has procedures in place to identify, manage and remediate actual or potential adverse impacts that may affect its workforce. These procedures are based on a set of policies and governance mechanisms covering occupational health and safety, equal opportunities, diversity and inclusion, combating violence and harassment, and protecting human rights" (page 135).

Investigation route. "For each issue that arises, a competent monitoring and control committee is appointed, which examines the report, assesses the facts and recommends appropriate corrective or remedial measures. In cases where immediate crisis management is required, a Crisis Management Team is activated, which identifies and implements appropriate response actions on an ad hoc basis" (page 135).

Channels. "The available channels include a dedicated reporting platform, the possibility of direct communication with competent services or managers, electronic submission via email, as well as submission of a report via letter. These mechanisms ensure the confidentiality of information, the possibility of anonymous reporting and the protection of employees from possible retaliation. The Human Resources Department is responsible for communicating with employees" (page 135). Channels are publicised through internal updates, email, the intranet, the Group website, the policies themselves and training (page 135).

Monitoring. "a report monitoring system operates, through which the categories and frequency of issues that arise are recorded and evaluated, in order to identify recurring issues and propose corrective actions" (pages 135-136).

The report does not disclose whether employees trust these channels or how that is assessed.

Reference: page 136 (ESRS content index, page 167); narrative on pages 136-140.

Health and safety. Each project carries a written Occupational Risk Assessment "integrated into the budget and operational planning", with Health and Safety Plans "regularly updated"; accidents trigger "an immediate investigation... to identify the causes and implement corrective actions" (page 136). Employee health provision includes private medical and pharmaceutical cover for employees and families, a weekly medical adviser at head office, "a fully equipped medical office... with a permanent nurse", and an Occupational Doctor (page 136). Safety extends to subcontractors through contractual requirements and inspections (page 136).

Digital tools. "Through specialized applications and interactive questionnaires, the understanding of safety rules by employees is assessed. In cases of insufficient compliance, access to the construction site is restricted." This began "on a pilot basis on the Athens Metro Line 4 project and is expected to be extended to all future projects" (page 137).

Training. Introductory and periodic training run internally and with certified bodies "such as the EKAB (Emergency Medical Service) and the Fire Department", with daily Toolbox Talks (page 137).

Human rights. Actions are tabulated on page 138 and include the statement that "100% of employees are covered by a Health and Safety system" and that "100% of employees are covered by a collective labour agreement and are compensated with a fair salary" - note that S1-8 reports collective agreement coverage of about 83% (page 144).

Benefits (page 139): private healthcare for employees and family, corporate car policy, a voluntary blood-donation bank, company mobile phones, "Cash assistance and salary advances to cover urgent financial needs", and weekly visits from a medical consultant.

Development. AVAX holds the ACCA Approved Employer certification, which exempts employees from ACCA Practical Experience Requirements (pages 139-140).

Reference: page 141 (ESRS content index, page 167); tables on pages 141-144.

Headcount is taken "from the Group's HRMS system with a reference date of the last working day of each reporting year, i.e. 31/12/2025", and "all employees in the Group are permanent" (page 141).

Total: 3,195 employees at 31.12.2025 (2,602 male, 593 female), down from 3,303 in 2024 (pages 141-142). By entity: AVAX 1,861; AVAX branches 452; joint ventures 407; TASK AVAX 275; AUTECO 94; ETETH 62; Athens Marina 18; AVAX Development 16; iXion 10.

By contract and hours (page 142): 2,925 permanent and 270 term contracts; 3,129 full time (2,591 male, 538 female) and 66 part time (11 male, 55 female).

By age at Group level (page 146): 332 under 30, 1,490 aged 30-50 and 1,373 over 50, against 194 / 1,532 / 1,105 in 2024.

Turnover. "The employee mobility rate amounted to 28.45% in 2025" (page 143). Departures totalled 489 voluntary (468 male, 21 female), 414 layoffs (361 male, 53 female) and 6 retirements (page 144).

Note that the age table totals 3,195 for 2025 but 2,831 for 2024, against the 3,303 reported in the headcount table for the same year (pages 142, 146). No country breakdown of employees is given.

Reference: page 144 (ESRS content index, page 167).

"During the reporting year, the Group employed 519 people who were self-employed" (page 144). The breakdown by entity is:

The population is defined in the S1 introduction: "The Group's workforce consists mainly of salaried employees, while there is also a percentage of self-employed workers" (page 128).

The disclosure covers self-employed people only. No headcount is given for people provided by undertakings primarily engaged in employment activities, and the report does not say whether the figure is a headcount or an FTE, nor whether methodologies and assumptions used to compile it have changed. The 519 self-employed workers are excluded from the 3,195 employee headcount reported under S1-6.

Separately, working hours for non-salaried people whose work or workplace the organisation controls are reported under S1-14 at 1,450,473 hours for 2025 (page 149).

Reference: page 144 (ESRS content index, page 167).

"In the year 2025, 2,743 Group employees are covered by collective labor agreements, a percentage that corresponds to approximately 83% of the total human resources. This coverage concerns employees employed by the companies AVAX (1,861 employees), ETETH (62 employees), TASK AVAX (275 employees), AUTECO (94 employees), ATHENS MARINA (18 employees), AVAX DEVELOPMENT (16 employees) and iXion (10 employees), as well as employees employed in the Group's project consortiums (407 employees)" (page 144).

On social dialogue: "The Group operates employee representation mechanisms at the facility level. In 2025, 468 employees of AVAX work in facilities where employee representatives operate, which corresponds to approximately 25.15% of the company's workforce. In addition, 2 employees of AUTECO work in facilities where employee representatives exist. There are no corresponding employee representation structures in the other companies of the Group" (page 144).

"The terms of employment of employees are determined in accordance with applicable labor legislation as well as the applicable collective labor agreements" (page 144).

Two points to check. The seven entities plus consortiums listed as covered total exactly 2,743 - their entire combined workforce - and the only part of the Group left out is the 452 employees in AVAX branches. That makes coverage 85.9% of the 2025 headcount of 3,195; the stated 83% corresponds instead to the 2024 total of 3,303 (pages 142, 144). And the S1-4 human rights table states that "100% of employees are covered by a collective labour agreement" (page 138), which does not agree with either figure. No breakdown is given between EEA and non-EEA countries.

Reference: page 145 (ESRS content index, page 167); tables on pages 145-147.

Gender at senior management level (page 145). 37 senior managers Group-wide: 30 male (81%) and 7 female (19%). By entity, AVAX 22 (18 male / 4 female, 82%/18%); iXion 3 (1/2, 33%/67%); AVAX Development 2 (1/1, 50%/50%); joint ventures, ETETH and AUTECO 2 each with no women; TASK AVAX and Athens Marina 1 each with no women. "the senior management level includes Department Managers, Heads of Sectors and Heads of Independent Services with managerial rights in accordance with the employment contract they have concluded with the Group" (page 145).

Age distribution (page 146). At Group level 332 employees are under 30, 1,490 are 30-50 and 1,373 are over 50 - "the smallest percentage of employees belongs to the age group under 30, while approximately equal numbers of employees are divided into the age groups 30 to 50 and over 50".

Group-wide the workforce is 2,602 male and 593 female, so women are 18.6% of employees and 19% of senior management (pages 141, 145).

The report also presents family-related leave data by entity and gender on page 147, covering employees eligible for and taking maternity, paternity, parental and carer's leave: 1,564 male and 297 female AVAX employees were eligible, of whom 14 men and 7 women took family-related leave. That data is not indexed to a disclosure requirement.

Reference: page 148 (ESRS content index, page 167).

The full disclosure reads: "The collection of data on the disability status of employees is subject to restrictions arising from the legislation on the protection of personal data. The percentage of persons with disabilities among employees subject to legal restrictions on data collection is 0.094%" (page 148).

The Group's policy commitment sits in the Equality, Diversity & Inclusion Policy: "The Group ensures equal opportunities and promotes the full integration of individuals with disabilities, offering equal terms for learning, professional development, and fair remuneration" (page 134).

Two caveats a reader should carry. The figure is not broken down by gender, and the sentence structure leaves it unclear whether 0.094% is the share of the whole workforce or of the subset for which data may lawfully be collected. Against a headcount of 3,195 (page 141), 0.094% would be three people.

Reference: page 148 (ESRS content index, page 168).

AVAX opens with a candid limitation: "Although a fully systematic program of regular performance evaluations and professional development activities for all employees has not yet been established, the process of upgrading skills is adopted through the updates provided by each supervisor in the Human Resources Department, within the general training framework followed by the organization" (page 148).

The metrics disclosed are: "6,319 hours of training were implemented during the reporting year at the parent company AVAX and in ETETH 320 hours of training were recorded, contributing to the upgrading of employees' skills. In addition, training expenses, amounting to 68,644 euro, reflect the commitment to continuous development and improvement of the staff" (page 148).

Against AVAX's 1,861 employees that is about 3.4 hours per employee, though the report does not compute an average and does not break hours or participation down by gender, which S1-13 requires. No figure is given for the percentage of employees who participated in regular performance and career development reviews, and no training hours are reported for the Group's other entities, which together employ a further 1,272 people.

Training and development ranks 5 of 10 on the materiality matrix (page 80), and the S1 target table sets an "Increase in total training hours and strengthen training programs in subsidiaries" for 2026 (page 150).

Reference: page 148 (ESRS content index, page 168); narrative on pages 148-149.

"All employees of the Group are covered by an occupational health and safety management system, which is based on legal requirements and recognized standards or guidelines, and covers 100% of the executive and workforce. Within the Group, zero fatal work-related injuries have been recorded, both among the executive and workforce and among other employees operating on the Group's premises" (page 148).

The accident frequency rate fell from 4.5 to 3.88, but days lost rose 78% and the severity rate rose from 66.72 to 75.10, so accidents were fewer and more serious. Total working hours rose 69%, which explains part of the frequency improvement.

Working hours "for all employees who are not salaried but whose work and/or workplace is controlled by the organization, amounted to 1,450,473 hours for 2025" (page 149), though no injury data is given for that population.

Risk elimination follows the hierarchy of controls: "elimination, replacement, mechanical controls, marking and administrative controls, and finally personal protective equipment" (page 149). The 2026 target is a 5% reduction in accident frequency (page 150).

Reference: page 149 (ESRS content index, page 168).

Both required S1-16 datapoints are disclosed. Women are paid 14.36% less than men on average, and the highest paid individual receives 50.27 times the median annual total remuneration.

The report gives no context for either figure: no explanation of the drivers of the pay gap, no breakdown by level or function, no statement of whether the gap is calculated on gross hourly pay, and no prior-year comparative for either metric. It does not say whether the ratio was adjusted for changes in the workforce or for part-time employment.

The figures sit against a workforce that is 18.6% female and a senior management population that is 19% female (pages 141, 145), which the report does not connect to the pay gap.

The Group's stated policy position is that recruitment and evaluation are carried out "with absolute impartiality, regardless of gender, age, race, nationality, religious or political beliefs, sexual orientation, marital status, educational or socio-economic background" and that "Equality ensures that all employees have the same opportunities to perform, contribute, and grow" (pages 133-134).

Reference: page 149 (ESRS content index, page 168); table on page 150.

The narrative states: "In the reporting year, no incidents of discrimination were recorded, while no fines or sanctions related to such issues were imposed. Three (3) complaints or reports of concerns were recorded through the relevant channels. They were investigated and are not considered incidents of discrimination. Furthermore, there were no serious human rights issues or incidents related to the Group's human resources that violated the UN Guiding Principles or the OECD Guidelines for Multinational Enterprises" (page 149).

The table on page 150 reports:

The table and the narrative disagree. The table records 3 discrimination incidents; the narrative says none were recorded and that the 3 items were complaints that, on investigation, were not discrimination incidents. A reader should treat the narrative as the explanation of the row.

Complaints reach the Group through the ethics platform, direct communication with managers, email and letter, all with anonymity and protection from retaliation (page 135).

Reference: page 156 (ESRS content index, page 168); narrative on pages 156-158.

"The Group has established policies aimed at managing the material impacts, risks and opportunities associated with business conduct. All Policies relating to business conduct matters, including the Code of Ethics and Business Conduct, are continuously available to all employees and any interested stakeholder through the Company's website and internal communication channel (intranet)" (page 156).

Corporate culture is developed through three named mechanisms (page 156): induction and training for new employees; communication channels, the website and intranet; and a Training Policy "which was updated in early 2026 and covers the full scope of the Company's activities, including business conduct" and "applies to the entire workforce of AVAX and the Group's Companies".

The Code of Ethics and Business Conduct "applies to the employees and all individuals engaged by it, as well as to all types of external partners, suppliers, and subcontractors, including joint ventures in which the Company participates" and "is an integral part of the contractual terms of cooperation with employees, members of the Board of Directors, third parties and other persons acting on its behalf" (pages 156-157).

Whistleblower protection. The Whistleblowing Policy protects reporters "provided that, when submitting a Report or making a Public Disclosure, they had reasonable grounds to believe that the information regarding the reported breaches of EU law within the Company was true", extends to anonymous reporters later identified, and to "colleagues or relatives of the Whistleblowers, personal businesses or legal entities in which the Whistleblowers have an interest" (page 157). A dedicated anti-bribery line and email operate alongside it, and an explanatory whistleblowing video sits on the intranet (page 157).

Five policies are tabulated on page 158, and the Group "closely monitors the operations that are at the highest risk in relation to corruption and bribery, particularly in departments such as Accounting, Procurement and Projects" (page 157).

Reference: page 158 (ESRS content index, page 168); narrative on pages 158-161.

"The Group implements policies and business conduct actions aimed at preventing late payments and enhancing sustainability in its relationships with its suppliers... Suppliers are required to adopt the Group's environmentally friendly practices and comply with anti-bribery policies and the Code of Ethics and Business Conduct" (page 158).

Supplier base 2025 (page 159):

Selection criteria. "In cases where it is up to the Group, the selection of a supplier is made on the basis of sustainability criteria. These criteria are either included in the tender documents or are taken into account as per the Group's policy." Suppliers are asked to confirm certified quality, environmental and health and safety management systems; complaint-handling procedures; the criteria used to select their own suppliers and subcontractors; "if he or she has been fined or sanctioned for breaches of safety, health, environmental legislation or for cases of bribery in the last three years"; corporate social responsibility actions; and a description of main activities over the last three years (page 161). Each purchase order "states that the order is given on the condition of acceptance and adoption by the supplier, of the Anti-Bribery Policy and the Code of Ethics and Business Conduct" (page 161).

The Group is explicit about the gaps: "Although the processes of systematic auditing, social and environmental performance assessment, as well as the management of vulnerable suppliers are in development, the Group recognizes the importance of developing integrated procurement policies" (page 159). No count of suppliers actually assessed against sustainability criteria is given.

Reference: page 161 (ESRS content index, page 168); narrative on pages 161-163.

"AVAX implements an integrated system of policies and procedures for the prevention, detection and response to incidents of corruption and bribery, based on the requirements of the ISO 37001:2016 standard. In the context of due diligence procedures, the questionnaire method is used, inter alia, for risk assessment" (page 161).

Independence of investigation. "The investigating committee and the Internal Reporting Receiving and Monitoring Officer (R.M.O.) are separate from the Anti-Bribery Management Officer, who sees to ensure the prevention and detection of corruption and bribery, thus safeguarding the independence and objectivity during the investigation of reports" (page 161).

Certification and audit. "During the 2025 fiscal year, a full audit and recertification of the Company were conducted based on the relevant standard (zero findings of non-compliance)", and "In December 2025 the periodic audit on the basis of the prerequisites of the ISO 37001 System was carried out by TUV HELLAS" (pages 48, 52).

Training coverage. An anti-bribery Training Booklet was revised and posted on the intranet, distributed to administrative staff "including through the KNOWB4 training platform", and sent to all construction sites with instructions (page 53). The training matrix on page 162 shows delivery across administrative units, critical organisational units at risk, construction sites and critical subsidiaries, covering the definition of bribery and corruption, examples, consequences, AVAX policies, prohibition of retaliation, reporting channels and "Do's & Don'ts". Coverage is stated as "covering all functions exposed to high risk (100%)" (page 161).

Actions are listed on page 163: mandatory ethics and anti-corruption training, "regular internal and external audits by independent auditors", the whistleblowing system, transparency procedures to prevent conflicts of interest, and policy review.

No percentage of employees actually trained, and no separate figure for functions-at-risk trained, is quantified.

Reference: page 164.

Back-filled from the business conduct chapter, where targets are addressed as MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 Targets became a standalone disclosure requirement only in the 2025/2026 ESRS.

The statement carries a target table headed "[G1] Corporate Governance Targets", introduced with "Within the framework of its sustainable development strategy, the Group aims to achieve the following with regard to corporate governance" (page 164):

The zero-incident target is already reflected in current performance: "During the fiscal year no incidents were reported or identified, in accordance with the Policy and the zero incidents' goals" (page 52), and G1-4 reports zero violations, convictions and fines (page 163).

Effectiveness in the absence of quantified outcome targets is tracked through ISO 37001 recertification with zero findings of non-compliance and the December 2025 periodic audit by TUV HELLAS (pages 48, 52), and through "regular internal and external audits by independent auditors to assess compliance with internal regulations and regulatory requirements" (page 163). No base year or measurable milestone is attached to the three qualitative targets.

Reference: page 163 (ESRS content index, page 168); narrative on pages 163-164.

"During the reporting period, there were no violations of anti-corruption and anti-corruption procedures and standards, reflecting the effectiveness of the Group policies and prevention measures. In addition, no convictions or fines related to anti-corruption and bribery laws have been recorded" (page 163).

A separate, non-zero figure is disclosed for other regulatory breaches: "During the reporting period, fines for cases of non-compliance with laws and regulations amounted to €42,546.87. They mainly concerned labor-related issues, among others. No monetary loss was caused as a result of breaches of business ethics or as a result of legal proceedings related to data security and privacy breaches. Within the same framework, no lawsuit is pending, nor has a final decision been issued regarding monopoly practices, cartels, or unfair competition" (page 164).

The same nil result is reported in the governance policies section: "During the fiscal year no incidents were reported or identified, in accordance with the Policy and the zero incidents' goals" (page 52).

The report does not disclose the number of confirmed incidents relating to contract terminations with business partners, nor details of public legal cases regarding corruption or bribery brought against the undertaking or its own workers, beyond stating that none exist.

Reference: page 164 (ESRS content index, page 168).

AVAX frames lobbying through sector representation rather than direct political influence: "The Group maintains a transparent and responsible approach to lobbying activities, which in the Greek market do not manifest themselves in the same way as in other legal systems. Instead, the Group actively participates in institutionalized and non-institutionalized bodies of collective representation of sectors" (page 164).

The bodies are named: "the Association of Technical Companies of the Upper Classes (STEAT), the Panhellenic Association of Qualified Engineers and Public Works Contractors (PEDMEDE), the Panhellenic Association of Public Works Contractors' Associations (PESEDE), the Association of Enterprises and Industries (S.E.V.) and the Athens Chamber of Commerce and Industry (ACCI), through which special issues of the sector are discussed and managed" (page 164).

On the revolving door, the report gives the datapoint the standard asks for: "the Group has not appointed members of its administrative, management and supervisory bodies who hold a corresponding position in the public administration in the two years prior to their appointment, thus ensuring independence and the avoidance of conflicts of interest" (page 164).

No political contributions are reported, and no monetary or in-kind amounts are disclosed for financial or in-kind political contributions. The report does not name the representative appointed as responsible for oversight of lobbying activities, nor disclose whether the Group is registered in the EU Transparency Register.

Reference: page 165 (ESRS content index, page 168).

"The Group's credit policy is formulated on a case-by-case basis, on terms agreed between the parties, taking into account the size and category of the supplier. In order to expand credit limits, suppliers work with specialized rating agencies, such as COFACE and ATRADIUS, and receive the necessary credit limits. At the same time, the Group provides letters of guarantee (E/E) in order to enhance the trust of suppliers" (page 165).

A structural constraint is disclosed: "As there are significant delays in payments by the State, arrangements for overdue payments are agreed on a case-by-case basis. The Group strives to secure special working capital (on a project basis) and invoice factoring for the effective management of the project's cash flow and the payment of obligations" (page 165). That matters for a contractor whose customers "mainly consist of government agencies" (page 63).

The one quantified payment datapoint sits in the G1-5 section rather than here: "the contractual and legal payment term is strictly adhered to, with the average number of days for the payment of invoices being ninety (90) days" (page 164).

The report does not disclose the percentage of payments aligned with standard payment terms, the number of outstanding legal proceedings for late payments, or a description of standard payment terms by main supplier category, which the disclosure requirement asks for.