The Board of Directors is responsible for the overall conduct of the Cementir Group and has the powers, authorities and duties vested in it by and pursuant to the relevant laws of the Netherlands and the Articles of Association. In all its dealings, the Board shall be guided by the interests of the Cementir Group as a whole, including but not limited to the Company's shareholders and also taking into account the interests of relevant stakeholders. The Board has the final responsibility for the management, direction and performance of the Company and the Cementir Group.

The Board of Directors is currently made up of one Executive Director (Francesco Caltagirone, Chief Executive Officer or "CEO") and seven Non-Executive Directors (Alessandro Caltagirone and Azzurra Caltagirone, Vice Chairmen; Adriana Lamberto Floristan, Senior Non-Executive Director; Saverio Caltagirone, Fabio Corsico, Benedetta Navarra and Annalisa Pescatori).

Three Non-Executive Directors of the Company are qualified as independent for the purposes of the Code: Adriana Lamberto Floristan, Benedetta Navarra and Annalisa Pescatori.

The Board has allocated duties and powers to the Directors by Board Rules approved pursuant to Art. 7.1.5 of the Company's Articles of Association on 5 October 2019 and subsequently last amended on 27 April 2023.

Board Committees

Audit Committee

The Audit Committee consists of three members: 1. Benedetta Navarra (Chairman, expert in financial reporting), 2. Annalisa Pescatori, 3. Adriana Lamberto Floristan. All members of the Audit Committee are independent pursuant to Best Practice provision 2.1.8 of the Code.

Remuneration and Nomination Committee

The Remuneration and Nomination Committee consists of three members: 1. Annalisa Pescatori (Chairman), 2. Benedetta Navarra, 3. Adriana Lamberto Floristan. All the members of the Remuneration and Nomination Committee are independent pursuant to Best Practice provision 2.1.8 of the Code.

Sustainability Committee

The Board of Directors established the Sustainability Committee in its current composition on 27 April 2023. The Sustainability Committee consists of: Chairman Francesco Caltagirone Jr., and Members Annalisa Pescatori (independent), Benedetta Navarra (independent), and Adriana Lamberto Floristan (independent).

The Group Sustainability Committee plays the key role of assisting Cementir Holding's Board in formulating and implementing a sustainability strategy for the creation of long-term value.

During 2024, 5 meetings of the Board of Directors were held, in which the Board of Directors, among other things:

• examined and approved the preliminary consolidated results for the fourth quarter of 2023 and for the year ended 31 December 2023;
• examined and approved the 2024 budget and the update of the 2024-2026 Business Plan. In this context, in particular, the Board examined and discussed the strategic vision underlying the 2024-2026 Business Plan proposed by the CEO and, in its integrated composition of Executive and Non-Executive Directors, shared and approved this strategy, participating in the definition of sustainable long-term value creation;
• examined and approved the financial statements for the year ended 31 December 2023, preceded by the approval of the impairment test, and also approved the Cementir Group's Sustainability Report - Non-Financial Statement 2023 with the related materiality matrix, the Corporate Governance Report pursuant to the Code and the Remuneration Report;
• examined and approved the quarterly financial results of the Cementir Group and the half-year financial report;
• examined and approved the Internal Audit plan for the year 2025 and the Group's risk assessment, in which the risks associated with the strategy and activities of the Company and its subsidiaries were identified and analysed, in particular the strategic, financial, operational, compliance and sustainability risks, and specific and separate information was provided on the risks related to climate change and the energy transition, which were therefore a further opportunities for discussion and in-depth analysis of sustainability issues within the Board;
• reviewed the performance and procedures of the Board itself and its Committees, assessing their size and composition, also in consideration of professional experience, management expertise, gender;
• verified the diversity targets for 2023 and also defined the diversity and inclusion targets for the Board and senior management for 2024;
• approved the policy for the regulation of lobbying activities and political contribution, the Audit Manual and the Internal Audit Charter, and updated the procedure for handling and disseminating inside information and the Internal Dealing Code.

In line with the suggestions arising from the Board's annual self-assessment, Board meetings were opened with a brief introductory presentation by the Chairman on the current geopolitical situation, strategic issues and/or potential risks facing the Company, as a useful tool to provide Directors with a better visibility and understanding of the Company's business.

Integration of sustainability-related performance in incentive schemes

Overview

Cementir adopts a competitive remuneration system which guarantees a balance between corporate strategic objectives and recognition of the merits of Group employees. By using variable short and medium/long term remuneration components, the Policy is designed to align staff interests with the pursuit of the priority objective - value creation - and the achievement of financial and sustainability objectives.

This objective is also pursued by linking a significant portion of remuneration to the achievement of defined performance targets, by means of both the short-term incentive scheme (STI) and the long-term incentive scheme (LTI).

Roles Covered

Executive Directors:

• The CEO is covered by variable remuneration tied to sustainability performance
• ESG objectives are included in the STI Program of all executives and middle management of the Group
• All C-level employees have sustainability KPIs in their STI program

Board of Directors: There are no incentive schemes and remuneration policies linked to sustainability matters for members of the administrative, management and supervisory bodies. The only recipient of an STI plan is the President and CEO, but at present, no ESG objectives are foreseen. The Group will evaluate in the coming years the possibility of extending this incentive system to the Board as well.

In 2024, the Company worked to define the remuneration package of the CEO based on target related to ESG requirements, which will be effective from the beginning of 2025.

Short-Term Incentive (STI) Programme

In 2024, within the STI Program, which is fully integrated in the Performance management process, the Group continued to enhance the ESG objectives at all levels of the organization.

Sustainability KPIs: Particular attention was directed to the issues of:

• CO2 emissions reduction
• Green Capex / sustainability Capex (directly related to the Taxonomy)
• Occupational Health & Safety
• Biodiversity
• ISO certification
• Circularity
• Clinker factor reduction
• Human capital and development
• Water consumption

C-Level Remuneration: The remuneration of the whole C-level is strictly linked to ESG topics:

• Occupational Health & Safety target and CO2 emissions reduction target are included in the STI program of all C-level employees
• Weighting: These KPIs account for 15% - 20% of their remuneration
• With specific reference to KPI connected to Climate Change and its CO2 emission, KPIs are set and connected to the same metrics used in the CSRD for the CO2 equivalent emissions

Therefore, ESG related issues have a consistent and specific weight in determining the variable remuneration of senior executives.

Long-Term Incentive (LTI) Plan

The LTI Plan consists of three three-year cycles, each providing for the payment of an incentive subject to the achievement of performance targets at the end of the performance period. This plan ensures the long-term retention of a selected group of Group managers in strategic positions.

The Plan proposed the following objectives:

• Allow beneficiaries to focus on medium/long-term objectives in order to create sustainable value over time in line with the Company's strategic objectives
• Act as a tool for retaining beneficiaries
• Align compensation packages with market practices

CEO Remuneration 2024

Chairman and CEO Francesco Caltagirone:

Fixed component: EUR 1.8 million per year before taxes, payable on a monthly basis.

Variable component: The variable components for 2024 were estimated at EUR 5.422 million, before tax. The achievement was calculated as 2% of Net Operating Cash Flow.

Total remuneration 2024: EUR 7,329 thousand

Remuneration breakdown:

• 70% variable remuneration
• 30% fixed remuneration

Key Executives Remuneration 2024

** Including Group COO, Group CFO, Heads of Region and Business Unit Managing Directors

Governance

The Sustainability Committee reviews, evaluates and makes recommendations to the Cementir Holding Board and other Group bodies such as the Remuneration Committee on sustainability objectives to incentivise management at Group, regional and BU level.

Specifically, the Sustainability Committee:

• Reviews, assesses and makes recommendations to the Board and to other Group bodies such as the Nomination and Remuneration Committee on sustainability-related targets for management incentives at Group, region and BU level

Continuous Improvement

Metrics and targets, with particular reference to short-term ones, are being continuously assessed and monitored, with a view to a progressive improvement path to ensure an ever-increasing alignment between strategy, sustainability and incentive systems.

The 2024 Remuneration Policy does not provide for substantial changes compared to the one approved in 2023, continuously strengthening the number and relevance of the objectives linked to the strategy sustainability of the company at different organizational levels, confirming the extension of the audience of interested in all ESG issues.

The Audit Committee prepares the decision-making of the Board regarding the supervision of the integrity and quality of the Company's financial reporting and the effectiveness of the Company's internal risk management and control systems.

The Audit Committee focuses on monitoring the Board of Directors, among others, in the following matters: • relations with the internal and external auditors, and compliance with and follow-up on their recommendations and comments.

The internal audit function has sufficient resources to execute the internal audit plan and has access to information that is important for the performance of its work. The internal audit function has direct access to the Audit Committee and the external auditor. Records are kept of how the Audit Committee is informed by the internal audit function.

The internal audit function reports its audit results to the Board and the Audit Committee and informs the external auditor. The findings of the internal audit function include the following:

• any flaws in the effectiveness of the internal risk management and control systems;
• any findings and observations with a material impact on the risk profile of the Company and its subsidiaries; and
• any failings in the follow-up of recommendations made by the internal audit function.

During 2024, the Audit Committee met 4 times. During these meetings, the Audit Committee examined and discussed the activities carried out by the Internal Audit function and the Ethics Committee during 2023; examined the activities of the Internal Audit function referring to the first quarter and half-year of 2024, agreeing on methods and timing for the receipt of periodic or event-based information, with particular reference to significant events subject to audits, whistleblowing reports and litigation; the Audit Committee then examined the Audit Plan prepared by the Internal Audit function for 2025, together with the budget for that function for the same year. It also examined the Group's Enterprise Risk Assessment.

Group Profile

Cementir Holding N.V. is a multinational company with its registered office in the Netherlands, listed on the Euronext Star Milan segment. The company operates in the building materials sector and focuses on four main business lines: grey cement, white cement, ready-mixed concrete and aggregates.

Cementir is the world leader in the niche segment of white cement. The company is the largest producer of cement in Denmark and ready-mixed concrete in the Scandinavian area, the third largest cement producer in Belgium, and one of the main international operators in Türkiye, with two companies listed on the Istanbul Stock Exchange. In Belgium, the Group operates one of the largest aggregate quarries in Europe, and in Türkiye it processes industrial waste to produce fuel for its cement plants.

Group Strategy

Cementir strategy is built upon five pillars defined in the Group Industrial Plan: Sustainability, Enhancement of people, Innovation, Competitiveness Improvement, Growth and Positioning.

1) Sustainability

Cementir commitment is to constantly reduce its carbon footprint and achieve net zero emissions by 2050. This decarbonization path, articulated in a detailed Roadmap, sets sustainability objectives consistent with those of the United Nations and reflected in management incentive schemes. The main actions are:

• Clinker reduction: Cementir aims to progressively replace clinker with alternative materials such as fly ash, slag and calcinated clay, leading to the development of low-carbon cements like FUTURECEM® and D-Carb®.
• Alternative fuels and Energy: the Group is continuously increasing both the use of alternative fuels, such as biomass and gas, and the proportion of alternative energy sources, including renewables through long-term Power Purchase Agreements (PPAs).
• Recycling and Reuse: Cementir promotes the recycling and reuse of materials as part of its circular economy approach, such as concrete recycling as a substitute for natural aggregates and water usage optimization in the production process.
• Thermal efficiency optimization: the Group is constantly optimizing thermal efficiency, in order to reduce energy consumption and carbon emissions.
• Transport and Logistics: Cementir is implementing initiatives to reduce the climate impact of transport, procurement and logistics, including e-procurement, electric ready-mix trucks and fuel-efficient vessels.
• Adoption of breakthrough technologies such as Carbon capture and storage (CCS): the ACCSION project, based in Aalborg, Denmark, will be Cementir first carbon capture initiative and one of the first and largest full onshore carbon capture and storage project in Europe. By 2030 it is expected to reduce CO2 emissions by 1.5 million tons per year.

2) Valuing people

The Group's commitment is to promote a strong safety culture with the goal to achieve Zero Accidents through regular training and awareness programs. It also aims to prioritize employee development and foster a positive, inclusive work environment that champions diversity and inclusion, leveraging on learning platforms such as the Cementir Academy.

3) Innovation

Innovation is a core driver of Cementir long-term success. This pillar focuses on:

• Developing sustainable solutions: Cementir invests in research and development to create new low carbon solutions and other sustainable and high added-value products such as FUTURECEM®, and D-Carb®.
• Digital transformation: the company embraces digital technologies to enhance operational efficiency, improve customer experiences, and drive innovation across its operations, also with the adoption of Artificial Intelligence solutions.
• Breakthrough technologies: Cementir actively collaborates with external partners, including research institutions and universities, to accelerate the development and adoption of new technologies.

4) Improve competitiveness

The Group is implementing a series of actions to further enhance profitability and operational efficiency, including process digitization, preventive and predictive maintenance, advanced production control systems, intelligent logistics, warehouse management and integrated digital sales planning.

5) Growth and Positioning

Cementir strives to combine organic growth, strategic acquisitions, and targeted investments in key markets. Whilst strengthening its vertically integrated model in the Nordic & Baltic, Belgium and Türkiye regions, the Group aims to consolidate its global leadership in white cement through targeted actions in strategic markets.

Interests and views of stakeholders

Identified key stakeholder groups

Cementir Holding has identified the following main stakeholder categories with whom the company interacts and has a stable relationship (at holding or local level):

• Personnel (Own workforce)
• Institutions and Authorities (local and national)
• Shareholders
• Trade Unions
• Local communities and local committees
• Customers
• Suppliers
• Value chain workers
• Consumers and end-users
• Investors and financial analysts
• Environmental experts
• NGOs and conservation organizations

The stakeholder categories are defined based on the working and non-working relationships that the Group, each region and each individual business unit has externally and internally as well as directly and indirectly.

Engagement channels and frequency

The following table lists the Group's main stakeholders, subjects of interest and engagement tools:

At local level, in all the countries where the Company operates, HSE Managers are responsible for the active dialogue with local communities supporting their exigencies and specific requests, through regular meetings based on their needs. The Company regularly updates the communities on its activities and gathers their concerns.

Key concerns and views raised by stakeholders

Stakeholder engagement is a critical component of Cementir's materiality assessment (DMA) process. Stakeholder views were considered when evaluating the ESRS gross list of topics, ensuring that their interests were incorporated into the determination of material topics.

The stakeholder engagement process has focused on gathering information regarding the interests, views, and rights of individuals within:

• The company's own workforce (S1)
• Value chain workers (S2)
• Affected communities (S3)
• Consumers and end-users (S4)
• Other key stakeholders, such as investors and environmental experts

Both positive and negative issues have been raised, some of which have been identified as material by Cementir.

Specific concerns identified include:

Own workforce:

• Secure employment and stable contracts
• Work-life balance
• Health & Safety, particularly inhalation of silica dust and risks from heavy equipment
• Human rights issues (child labor/forced labor)

Affected communities:

• Water scarcity and impacts on local communities and other industries
• Air quality and dust impacts
• Community engagement and local development needs

Value chain:

• Human rights compliance in the value chain
• Working conditions of value chain workers

Integration into strategy and business model

Group Stakeholder Engagement Policy: The Group Stakeholder Engagement Policy was approved by the Board of Directors on 6 November 2023 and published on the Company's website. The policy:

• Recognizes that dialogue with stakeholders plays a fundamental role in the success of the Company and the Group
• Sets as the Group's objective the establishment of constructive dialogue with stakeholders to establish lasting and effective relationships, not limited to sustainability aspects alone
• Requires all employees of the Group to acknowledge and comply with the Policy
• States that the impact on stakeholders is considered material when it concerns the actual or potential effects of the Group on people or the environment in the short, medium and/or long term time horizons

Materiality assessment: Various stakeholders are involved in periodically updating the materiality matrix, which considers as relevant those issues that may have a direct or indirect impact on the Company's ability to establish, maintain or adversely affect the Group's values.

Governance integration: The Group's administrative, management, and supervisory bodies are informed about the views and interests of affected stakeholders concerning sustainability-related impacts. The constant and constructive dialogue with stakeholders is fundamental to the proper functioning of the company's business model, which aims to create economic, social and environmental value for all.

Due diligence: As stated in the sustainability statement: "Engaging with affected stakeholders in all key steps of the due diligence" is reflected in the Social Information chapter (S1, S2, S3, S4).

Strategic commitments: The Company's sustainable development strategies pursue various objectives, including constant improvement of environmental and occupational health and safety conditions, and compliance with international standards such as:

• The United Nations International Charter (UN): Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, International Covenant on Economic, Social and Cultural Rights
• The fundamental conventions of the International Labour Organization (ILO) - n. 29, 87, 98, 100, 105, 111, 138, 182 - and the Declaration on Fundamental Principles and Rights at Work
• The UN Convention on the Rights of the Child
• The ILO Conventions n.107 and n.169 on the Rights of Indigenous and Tribal Peoples
• The European Convention on Human Rights

Action plans: With the implementation of a wide range of actions, Cementir is in a position to anticipate stakeholders' needs and priorities. The Company recognizes that its actions will have a direct impact on the ecosystem it is part of, and they take into account the environment, the economy and society as inseparable parts of the same whole.

The Company is committed to identifying and analysing priorities and expectations for each stakeholder category and adapting engagement strategies and actions accordingly. This analysis process allows for the adoption of targeted, customised and proactive engagement plans to foster effective communication, accurate information sharing and constructive collaboration with relevant stakeholders.

Distinction between affected stakeholders and users of information

The engagement process specifically distinguishes between:

Affected stakeholders (those impacted by the business):

• Own workforce (S1)
• Value chain workers (S2)
• Affected communities (S3)
• Consumers and end-users (S4)

Users of sustainability information:

• Investors
• Shareholders
• Financial analysts
• Lenders (implied through financial stakeholder discussions)

Relations with shareholders and financial analysts are handled with a high degree of accuracy and in compliance with the policy, the Dutch Corporate Governance Code and applicable regulations.

The Chairman and CEO of the Group assesses on a case-by-case basis which stakeholders are relevant to the Company, with whom to enter into dialogue and in what form, and has the power to make changes to the list of stakeholders.

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

Full list of material IROs

The following table lists the sustainability-related impacts, risks and opportunities (IROs) identified and assessed as material as a result of Cementir's double materiality assessment process, including a brief description. The table shows whether impacts are positive or negative; the time horizon: short term (ST), medium term (MT), long term (LT); and the scope of the value chain: upstream (U), own operations (OO), downstream (D).

Detailed description of material IROs

S1 - Own Workforce

The following material negative impacts have been identified:

Working Conditions:

• Secure employment: Not giving access to secure employment through stable contract and not promoting the well-being of people could lead the employees to be stressed and not satisfied having consequently low performances on the organization and having a negative impact on business and results of Cementir. (Widespread or systemic in contexts where Cementir operates)

• Work-life balance: Cementir not ensuring a proper work-life balance for its employees, not maintain a healthy equilibrium between private and working life can have a negative impact on employees and consequently on the performance of the Company. (Widespread or systemic in contexts where Cementir operates)

• Health & Safety: The inhalation of silica dust by workers can lead to the development of chronic health conditions, resulting in negative external impacts on their health. (Widespread or systemic in contexts where Cementir operates)

• Health & Safety: The use of heavy equipment and quarrying operations by the undertaking can lead to high fatality rates, significant health and safety risks for their employees and contractors. (Related to individual incidents)

Other work-related rights:

• Child Labor/Forced Labor: Severe human rights issues (e.g. forced labor, human trafficking or child labor) affecting the undertaking's own workforce can lead to a negative impact for Cementir. (Widespread or systemic in contexts where Cementir operates)

Material positive impacts:

S2 - Workers in the Value Chain

The potential negative impacts identified are:

• Upstream activities Mining and Quarrying there is the possibility that contracts (e.g temporary) do not guarantee contractual security.
• The inhalation of silica dust by workers can lead to the development of chronic health conditions, resulting in negative external impacts on their health.
• The use of heavy equipment and quarrying operations by the undertaking can lead to high fatality rates, significant health and safety risks for their employees and contractors.
• Severe human rights issues (e.g. forced labor, human trafficking or child labor) affecting the undertaking's own workforce can lead to a negative impact for Cementir.

No material positive impacts are defined.

The resulting risks are:

• Risks related to vendors, haulers, clients, subcontractors injuries during the service performing or in close proximity of the company's plant can lead to significant reputational damage and legal liabilities. These incidents could result in increased insurance costs, potential legal settlements, and loss of business. Such financial impacts would likely contribute to a decrease in EBITDA.
• Worker injuries, illnesses, and fatalities can lead to regulatory penalties, negative publicity, low worker morale and productivity, increased healthcare and compensation costs, and potential litigation, all of which can have a significant financial impact on the business.
• Geographical areas can have risk related to child and forced labor can lead to reputational risk and sanctions, operational costs can increase.

S3 - Affected Communities

Negative impacts identified:

• The companies' activities, in particular related to the production ones, may lead to critical and/or unfavourable attitudes among local communities and local stakeholders, with consequent deterioration of the Company's image.
• The large amount of water required for production can lead to water scarcity in water sensitive areas.

S4 - Consumers and End-Users

Citizens who use the final product for personal purposes may face potential risks to their right to privacy and protection of personal data.

G1 - Business Conduct

The assessment resulted in the identification of the following risks:

• Whistleblowing Channel Policy with reference to confidentiality and anonymous complaint report potential misconduct or concerns with the aim to correct the problem timely without compromising the company's reputation, transparency and prevent financial risk/damages.
• Risks related to money laundering regulations' violations can lead to a financial loss for criminal and civil fines as per penalties and reputation damage that can drive to a loss of sales and consequently on revenues.
• Risks related to anti-corruption regulations' violations can lead the Company to pay fines and sanctions and can affect economic development, debarment from public contracts, and reputational damage.
• Business activity leading to price fixing or other manipulation of prices may result in material legal fines, business disruption, and financial losses.

Linkage between IROs and strategy/business model

Climate Change Strategy

Cementir pursues a sustainable growth strategy, focusing on product leadership, the pursuit of excellence and the efficiency of operating processes. The Group has achieved important ESG recognitions, including the validation of its 2030 decarbonization objectives by the Science Based Target initiative (SBTi) and an A rating by CDP on climate change and A- on water security.

The Company' strategy is supported by the ERM, through the analysis of climate risks that mostly impact the company's type of business. The strategy is constantly updated based on the risks monitored through ERM and the scenario analysis.

In 2024, there were no current financial effects from material IROs.

Integration with Business Model

Cementir's long-term sustainability strategy has been developed through a bottom-up approach over recent years. The functions concerned within the local structures, under the coordination of the Group's top management, have translated individual concepts and notions into a unique and coherent way of thinking, defining the Group's internal culture and identity, setting precise expectations, objectives and commitments.

The strategy drawn up by the Chief Executive Officer and submitted to the Board in its entirety for approval in the context of the approval of the Industrial Plan, was inspired by the aim of long-term value creation by the Company and the other companies in the group, with particular reference to the "Sustainability Roadmap".

Based on the analysis carried out, the Group has set 26 Sustainability Goals to be achieved by 2030, which cover the priority areas for Cementir. The objectives are linked to Cementir's effort to adopt all necessary measures and the most innovative technology to minimise the impact of the Cementir's Group activity on the environment; creating a healthy, safe and inclusive work environment; respecting human rights and building a constructive and transparent relationship with local communities and business partners.

These objectives, set by individual plant and by year, are included in the Business Plan and the short-term incentive system for employees. Cementir also pursues the creation of long-term value through a Long-Term Incentive Plan for its top management.

How material IROs interact with the business

Governance and Oversight

The Board during its regular meetings, at least quarterly, among other issues receives updates on the strategy targets, discusses and approves the quarterly Management Reports and monitors the risk management examining and approving the Enterprise Risk Assessment.

The Sustainability Committee prepares the decision-making process of the Board of Directors in formulating and implementing a strategy in line with a view on long-term value creation by Cementir Holding N.V. and its subsidiaries, regarding the development and promotion of a healthy, safe and secure environment for the Company's stakeholders as well as the sustainable development and social responsibility.

Throughout the reporting period, the Sustainability Committee has addressed the material impacts, risks, and opportunities reported in the "Double Materiality outcome" section.

The administrative bodies are informed about the implementation of due diligence on quarterly basis. They are also informed about the results and effectiveness of policies, actions, metrics and targets adopted to address material impacts, risks and opportunities, by Internal Control and Risk Management System.

Integration in Incentive Schemes

In 2024, within the STI Program, the ESG objectives are included in the STI Program of all executives and middle management of the Group. Particular attention was directed to the issues of CO2 emissions reduction, Green Capex and Occupational H&S.

The remuneration of the whole C-level is strictly linked to ESG topics. Occupational Health & Safety target and CO2 emissions reduction target are included in the STI program of all C-level employees. Specifically, these KPIs account for 15% - 20% of their remuneration.

Resilience to identified IROs

Climate Change Resilience

Cementir has conducted climate-related scenario analysis using:

• Physical climate scenarios: Three IPCC scenarios (RCP 2.6, RCP 4.5, RCP 8.5) representing low, medium, and high climate change scenarios
• Transition scenarios: Different carbon price scenarios based on OECD and IEA research

The Group has assessed the resilience of its climate strategy relating transition risks with different carbon price scenarios and evaluated the exposure of plants to physical risks including acute (extreme weather events) and chronic (long-term climate pattern changes) risks.

For biodiversity, the Group will utilize scenario analysis in the coming year to further the identification and assessment of biodiversity and ecosystem-related risks and opportunities across short, medium, and long-term horizons to ensure that the Group's business strategy remains resilient and adaptable to emerging trends and challenges.

Time Horizons

The three-time horizons are defined as:

• Short term (1-3 years): in which sensitivity analyses based on the Industrial Plan presented to investors can be performed
• Medium term (until 2030): a time horizon beyond the Industrial Plan but addressed by the Cementir Climate Change Strategy and its 10-year roadmap
• Long term (2030-2050): in which chronic structural changes in the climate should begin to emerge

Medium and long-term time horizons definition is aligned with the recommendations of international frameworks such as TCFD and with the time horizons envisaged by the group's industrial plan and decarbonization Road Map.

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

Overview of the ESRS Four-Step Process

According to the ESRS, to be compliant, an organization must determine its relevant sustainability topics. The ESRS Standards defined four steps that an organization should follow to determine its relevant topics:

1. Understanding the context and defining the stakeholder engagement strategy.
2. Identifying the list of potential sustainability issues and impacts, risks, and opportunities (IROs).
3. Determining the final list of relevant sustainability topics through the Double Materiality Assessment (DMA).
4. Reporting the evaluation process.

Understanding the Context

Cementir Group operates in the building materials sector and focused on four main business lines: grey cement, white cement, ready-mixed concrete and aggregates. With over 3,000 employees, Cementir is the global leader in the white cement niche segment, the leading producer of cement in Denmark and of ready-mixed concrete in the Scandinavian area, the third largest producer in Belgium and among the main international players in Türkiye, with two listed companies on the Istanbul Stock Exchange.

Value Chain Mapping

Upstream

Cementir is sourcing goods and services to support its daily operations across the world. Main categories of expenditures are direct materials, energy, logistics and transportation and technical services. Raw materials can be sourced from:

• its own quarries by means of external contractor's services or;
• third party suppliers who are delivering on site.

Main transport categories are seaborne to large ports and trucks to deliver to customers. Cementir works globally with several contractors which are performing technical services as mechanical and electrical maintenance, industrial cleaning and various operations support.

Own Operations

Cementir Holding is a multinational Group delivering innovative building solutions worldwide. Its operations are structured on a regional basis in seven geographical regions: Nordic & Baltic, Belgium, North America, Türkiye, Egypt, Asia Pacific and Italy/Holding & Services. Precisely, operations are composed by three vertically integrated platforms operating in aggregates, cement and concrete production and distribution in three countries: Denmark, Belgium and Türkiye.

Downstream

Cementir Holding N.V. offers a wide range of products, solutions and services. The products offered and distributed are cement (grey – white), aggregates and concrete. Primary customers within the value chain are in the industrial and B2B sectors (1st end users), as well as the construction sector (2nd end users - including private and general contractors for new construction and renovation in residential, commercial/industrial and infrastructure/public works sectors).

Stakeholder Engagement Strategy

Stakeholder engagement is a critical component of Cementir's materiality assessment (DMA) process. Stakeholder views were considered when evaluating the ESRS gross list of topics, ensuring that their interests were incorporated into the determination of material topics. The stakeholder engagement process has focused on gathering information regarding the interests, views, and rights of individuals within the company own workforce (S1), value chain workers (S2), affected communities (S3), and consumers and end-users (S4).

Based on the working and non-working relationships that the Group, each region and each individual business unit has externally and internally as well as directly and indirectly the Group proceeded with the identification of its stakeholders. The identified and listed stakeholders are those that the company interfaces and has a stable relationship with (Holding level or regional level).

Identification of Potential Sustainability Issues and IROs

Initially, an analysis of the actual and potential impacts generated on the economy, environment and people through corporate operations was carried out. This analysis was facilitated by consulting internal documents from 2023, such as:

• the Group's strategy
• the Group's sustainability targets
• audits results
• complaints received through the whistleblowing channel
• Group Enterprise Risk Management

To enhance the analysis, the impact materiality together with the financial materiality – which has been defined based on ERM – lead to the Double Materiality Assessment. Concerning the Group Risk Management, consultation of the risk register allowed for a more accurate delineation of the main business impacts.

External Sources Consulted

Following internal analysis, we turned to external sources to verify the level of alignment or misalignment with the 2023 material topics:

• the SASB Materiality Finder (sector specific)
• the MSCI ESG Industry Materiality Map
• documents and research issued by cement trade associations
• main laws and regulations in the countries where the Group operates
• ESG mega trends, as reported by MSCI, Refinitiv, S&P Global and from official ESG papers of the main international consulting firms
• industry benchmarking of 10 competitors in the cement sector

The result of the identification and research phase is a list of Impacts, Risks and Opportunities related to the Operations of Cementir Holding.

Double Materiality Assessment Process

CSRD is based on Double Materiality Assessment (DMA), which has two dimensions, namely: impact materiality and financial materiality. A critical part of the assessment involves measuring impacts, risks, and opportunities not only for stakeholders but also for the company and its strategy.

The results of the Double Materiality Assessment can be affected in the next years by possible future changes in the ongoing due diligence and double materiality assessment process, including engagement with affected stakeholders. Due diligence is an on-going practice that responds to and may trigger changes in the company's strategy, business model, activities, business relationships, operating, sourcing and selling contexts relevant for stakeholders as a group. The double materiality assessment process may also be impacted in time by sector-specific standards to be adopted. The sustainability statement may therefore not include every impact, risk and opportunity or additional entity-specific disclosure that each individual stakeholder may consider important in its own assessment.

Impact Materiality Assessment

Process:

1. Analysis of the Sustainability Reports of competitors, industry trends, main reporting standards and ratings of sustainability, legislative pressures in the sector, geographic reference context, media analysis to understand the context in which the Group operates and identify a preliminary list of impacts generated on the environment and people.
2. Analysis of the documents of the Cementir Holding N.V.
3. Validation of impact materiality.

Scoring Criteria:

As per the ESRS guidance, the relevance of each impact has been assessed by considering its:

• severity (negative impact) or significance (positive impact), which final score is given by the average ones of:

  • 'scale': how great the impact is on the environment or people, after consideration of mitigation actions already in place
  • 'scope': how widespread the impact is based on parameters such as percentage of sites, employees, or financial spend that the impact relates to
  • 'irremediability character' (for negative impacts only): how difficult it is to reverse the damage in terms of cost and time horizon

  The evaluation scale goes from 1 (Low) to 5 (High).

• probability of occurrence, is defined as the possibility of impact occurring. The probability varies depending on the measures taken by the Company to prevent and/or mitigate the impact.

If the impact negatively affects human rights, the severity of the impact takes precedence over the probability as required by the ESRS.

The total severity of an impact is then used to calculate the average relevance.

Materiality Threshold:

Based on severity/significance and probability scores of each impact, a threshold has been identified: only impacts above or equal the defined threshold resulted as relevant for Cementir. Threshold is above or equal to 3, in a range scale going from 1 to 5.

The Audit Committee and the Sustainability Committee have set the materiality thresholds at 'medium'. This means that impacts and risks scored as 'medium' or above, and their associated ESRS topic, are deemed material.

Financial Materiality: Risk and Opportunities Assessment

Process:

1. Mapping of business relationships, natural, social and human resource dependencies along the value chain and actions implemented by the Group to address sustainability issues.
2. Preliminary identification of sustainability risks and opportunities.
3. Validation of Financial Materiality.

Sources Considered:

To identify material risks and opportunities for the company, it is necessary to consider:

1. Impacts: a risk or opportunity that may arise from an impact generated by the Company.
2. Impacts or risks from actions to address sustainability issues: risks and opportunities may be generated by actions that the company takes to mitigate its negative impacts or to maximize positive impacts on sustainability.
3. Dependencies and relations: dependencies can activate risks and opportunities in two possible ways:
   • may affect the ability of the enterprise to continue to use or obtain resources necessary for its business processes, as well as the quality and price of such resources
   • they can impact the company's ability to rely on the necessary relationships for its business activities under acceptable conditions

The actors and capital on which the Group depends and with which it interacts also include its own Stakeholders, which were considered in the analysis of Double Materiality.

Scoring Criteria:

The measurement methodology of CSRD used for financial materiality is to include two qualitative variables: magnitude and probability.

Each risk and opportunity have been assessed by considering:

• the potential magnitude of financial effects based on different triggers, including EBITDA. It was scored as 'low', low-medium', 'medium', 'medium-high' or 'high'.
• the probability of occurrence, scored as 'low', 'low-medium', 'medium', 'medium-high' or 'high', by using relevant time horizons of short-, mid-, or long-term.

Cementir assessed the nature of these effects in different scenarios with assumptions based on input parameters from subject-matter experts.

Materiality Threshold:

Based on magnitude and probability scores of each risk and opportunity, a threshold has been identified; only risks and opportunities above the defined threshold have been defined as relevant for Cementir.

Our Audit Committee and Sustainability Committee have set the materiality thresholds at 'medium'. This means that impacts and risks scored as 'medium' or above, and their associated ESRS topic, are deemed material.

Frequency and Last Review

The document does not explicitly state the frequency of review or when the assessment was last conducted, though the report refers to 2024 as the reporting year and mentions that 2023 material topics were used as a baseline for comparison.

Governance and Oversight

Group Finance plays the leading role in identifying, managing, and communicating our IROs. They ensure both financial and non-financial compliance by establishing effective controls and procedures for sustainability data collection, which is integrated with our Management Reporting systems and guidelines.

The Board of Directors, with the Audit Committee's involvement, uses processes, controls, and Double Materiality Assessment results to guide target-setting related to our significant IROs when applicable. Once targets are established, they are tracked with appropriate qualitative and quantitative indicators. The Board of Directors makes the final decisions on IROs.

Transition plan for climate change mitigation

Overview

Cementir is publicly committed to adopting the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). The Group's commitment is to constantly reduce its carbon footprint and achieve net zero emissions by 2050. This decarbonization path is articulated in a detailed Roadmap, setting sustainability objectives consistent with those of the United Nations.

In February 2024, the Science Based Targets Initiative (SBTi) validated that the CO₂ reduction targets for the near-term (2030) and long-term (2050) defined by Cementir are in line with the 1.5°C Scenario.

Scope of the transition plan

The transition plan covers:

• Entities: All Cementir Group operations globally
• Geographies: Denmark, Belgium, Türkiye, Egypt, China, Malaysia, United States, Sweden, Norway, Italy
• Value chain segments:
  • Upstream: Raw materials sourcing (own quarries and third-party suppliers), energy, logistics and transportation, technical services
  • Own operations: Cement production (grey and white), aggregates, ready-mixed concrete, precast concrete
  • Downstream: Industrial and B2B customers, construction sector, traders and distributors

Target years and milestones

Overall Net-Zero Target

Cementir Holding N.V. commits to achieving net-zero greenhouse gas (GHG) emissions across the value chain by 2050.

Near-Term Targets (2030)

Scope 1 and 2:

• Reduce gross Scope 1 and 2 GHG emissions 29.33% per ton of cementitious product by 2030 from a 2021 base year

Scope 3:

• Reduce gross Scope 3 GHG emissions from purchased goods and services 23.00% per ton of purchased clinker and cement by 2030 from a 2021 base year

Long-Term Targets (2050)

Scope 1 and 2:

• Reduce gross Scope 1 and 2 GHG emissions 96.1% per ton of cement by 2050 from a 2021 base year

Scope 3:

• Reduce absolute Scope 3 GHG emissions 90% by 2050 from a 2021 base year

Detailed targets by product type

Grey Cement:

White Cement:

Alignment with 1.5°C and SBTi validation

In February 2024, the Science Based Targets Initiative (SBTi) validated that the CO₂ reduction targets for the near-term (2030) and long-term (2050) defined by Cementir are in line with the 1.5°C Scenario. SBTi disclosed the approval of the target on February 29, 2024.

Cementir is committed to developing a business model in line with sustainability strategic goals and CO2 emission reduction targets judged by SBTi to be consistent with a 1.5°C world.

Targets will be reviewed and revalidated every five years from the date of original target approval to ensure they remain aligned with the most recent climate science.

Key decarbonization levers

Scope 1 emissions reduction

1. Clinker reduction:

• Grey cement: Reduce clinker content to 64% by 2030 (from 82% in 2020)
• White cement: Reduce clinker content to 79% by 2030 (from 82% in 2020)
• Use of alternative decarbonised mineral additives such as fly ash and slag
• Development of FUTURECEM®: a new low-carbon cement with carbon footprint approximately 30% lower than regular Portland cement. FUTURECEM® allows more than 35% of the energy-intensive clinker in cement to be replaced by limestone and calcined clay. By 2030, FUTURECEM® volumes sold are expected to reach around 51% of total volumes sold in Europe and 60% of grey cement volumes
• Development of D-Carb®: a new umbrella brand for white low-carbon cements with 15% lower CO2 emissions compared to standard white cement

2. Alternative fuels:

• Replace fossil fuels with waste-derived fuels and biomass fuels
• Grey cement: Increase alternative fuel use to 48% by 2030 (from 28% in 2020)
• White cement: Increase alternative fuel use to 6% by 2030 (from 3% in 2020)

3. Fuel switching:

• Partial transition from petcoke to natural gas at Danish and Belgian plants
• Aalborg Portland has entered into an agreement with Danish gas distribution company Evida to connect the Aalborg plant to the gas distribution network
• CCB has signed a gas transportation contract with Fluxys in Belgium
• Installation of multi-fuel main burners for kilns

4. Energy recovery:

• Aalborg plant recovers excess heat from cement production to provide district heating to around 20,000 families in Aalborg, Denmark, with aim to increase to over 30,000
• Potential annual energy recovered is around 2 million GJ
• With carbon capture project, heat recovery will increase to 3 million GJ, allowing CO2 savings of around 187,000 tons

5. Carbon Capture and Storage (CCS):

• ACCSION project in Aalborg, Denmark: Joint venture between Aalborg Portland and Air Liquide
• Expected to reduce CO2 emissions by 1.4-1.5 million tons per year by 2030
• One of the first and largest full onshore carbon capture and storage projects in Europe
• Received €220 million from EU Innovation Fund
• Planned to be operational by end of 2030
• By 2030, Aalborg Portland aims to become Europe's first net-zero cement plant producing grey and white cement

Scope 2 emissions reduction

Renewable energy:

• Installation of photovoltaic panels and windmills
• Increase purchase of electricity from renewable sources through Power Purchase Agreements (PPAs)
• In 2023, CCB signed agreements with Engie (15 MW wind turbine, 5-year contract) and Ether Energy (10 MW solar, 15-year contract)
• In 2023, CCB signed cooperation agreement with IPALLE to develop wind farm project in Barry quarry (around 50 MW wind turbine)
• In 2024, the Group used 49,071 MWh of green electricity through PPAs, representing approximately 4% of total electricity consumption
• After 2030, eliminate Scope 2 emissions by expanding renewable energy sources

Scope 3 emissions reduction

• Embedding of CO2 emissions in sourcing decisions for all purchase categories
• Promotion of zero-emissions transportation solutions
• Participation in CDP Supply Chain program to enhance transparency on suppliers' emission reduction measures
• Since late 2023, non-European suppliers of clinker and cement are obligated to disclose Scope 1 and Scope 2 emissions directly to Cementir (CBAM compliance)
• Third-party verification of supplier disclosures planned in accordance with EU guidelines
• By 2024, Scope 3 emissions reduced by 23% per ton of purchased clinker and cement compared to 2021 levels (target achievement ahead of 2030 deadline)

CapEx and investment commitments

The 2024-2026 Industrial Plan, approved by the Board of Directors in February 2024, targets €100 million investments in Sustainability and Digitalisation, including:

• Preliminary studies for CCS in Denmark and Belgium
• Kiln upgrade at Belgian plant to increase alternative fuels from current 40% to over 70%
• Transition to natural gas in some of the Group's plants
• Preparation of structures necessary for production of FUTURECEM® in Denmark

The 2025-2027 Industrial Plan approved by the Board of Directors on 11 February 2025 includes climate change targets deployed per single plant and year.

ACCSION project: €220 million from EU Innovation Fund (plus additional project funding)

Locked-in emissions and stranded assets

With reference to potential 'locked-in' GHG emissions, finished products do not have blocked emissions. When products are used by end users to produce concrete, no further GHG emissions occur. Emissions only occur during the production phase. Therefore, there are no potential impediments to Cementir achieving its emission reduction targets.

The Group has not identified stranded assets related to the climate transition.

Use of carbon credits and removals

2050 strategy:

• Carbon offset measures to compensate for unavoidable residual emissions
• Leveraging on capturing and storing the biogenic CO₂ fraction, which offsets any remaining fossil emissions
• By 2030, Aalborg Portland aims to become Europe's first net-zero cement plant by capturing and storing biogenic CO2 fraction

Specific volumes or costs of carbon credits/removals are not disclosed in current targets.

Integration with business model

The climate change targets have been:

• Deployed per single plant and year
• Included in the 2025-2027 Industrial Plan approved by the Board of Directors
• Included in employee short-term incentive schemes
• Reflected in management incentive schemes
• Integrated into strategic planning and capital allocation

Governance and accountability

The Sustainability strategy receives board and management attention. Climate-related targets are monitored by:

• Board of Directors
• Sustainability Committee
• Group Top Management
• Regional management

For detailed governance structure, see ESRS 2 General Information chapter.

Time horizons

The Group uses three time horizons for climate planning:

• Short term (1-3 years): Aligned with Industrial Plan
• Medium term (until 2030): Addressed by Cementir Climate Change Strategy and 10-year Roadmap
• Long term (2030-2050): Structural climate changes and net-zero pathway

Exclusion from Paris-aligned Benchmarks

For the sake of completeness, Cementir is excluded from the EU Paris-aligned Benchmarks.

Key projects supporting the transition

ACCSION (Carbon Capture)

• Partners: Aalborg Portland, Air Liquide
• Timeline: 2025-2030
• Funding: €220 million EU Innovation Fund
• Target: Capture 1.4 million tons CO2 annually

CASPER (CCS demonstration)

• Total budget: €2 million (€600,000 from partners including Cementir)
• Timeline: 2024-2026
• Partners: Aalborg Portland, Technical University of Denmark, Pentair, others
• Purpose: Demonstrate full CCS value chain from cement plant

CORT (Advanced amine solvents)

• Total budget: €2.6 million (€150,000 from Cementir)
• Timeline: 2022-2025
• Partners: Aalborg Portland, Pentair, Danish Technical University, others
• Purpose: Investigating advanced amine solvents for carbon capture

Performance tracking

2024 Results vs targets:

All targets are described as "in line with the planned roadmap."

Policies related to climate change mitigation and adaptation

Cementir acknowledges its environmental responsibilities across all areas of its operations and is committed to reducing its environmental footprint, with a particular focus on addressing climate change. Climate change, along with broader environmental concerns, forms a core component of the Group's sustainability framework and strategy.

In order to manage its relevant impacts, risks and opportunities related to climate change mitigation and adaptation, Cementir has an Environmental Policy in place (reference made to the General Information section for detailed information), which applies to all operational activities within the Cementir Group.

Environmental Policy

Scope:

• Applies to all operational activities within the Cementir Group
• Each operating company is responsible for implementing the policy's directives and guidelines as a crucial and integral component of its own Environmental Management System
• These systems and policies must incorporate the principles and commitments outlined in the Group's Environmental Policy

Key content / Principles:

The Environmental Policy focus is based on three lines of action and operates on multiple fronts regarding climate change mitigation and energy efficiency:

• Energy efficiency: Aims to increase the efficient use of energy in the framework of the Energy Management System, compliant with the internationally recognized standard (i.e., ISO 50001). It promotes energy recovery and the use of renewable energy sources, thus reducing energy consumption and, consequently, CO2 emissions.

• Alternative fuels and raw materials: Aims at increasing alternative fuels usage in cement production, such as low-carbon fuels and biomass, thus reducing environmental impact. Promotes the adoption of a co-processing and circular approach to waste as a fuel, which contributes to lower emissions compared to traditional fossil fuels. Defines the use of decarbonized/alternative raw materials to minimize the usage of non-renewable resources.

• Product innovation and new technologies: Promotes an increase in the production of low-carbon cement such as FUTURECEM, encouraging the circularity and reducing emissions throughout the products' lifecycle. Promotes an increase in the use of concrete-based demolition waste as substitutes of natural aggregates in concrete production following circular economy strategy. Includes engagement and participation in new technologies implementation such as Carbon Capture, Usage and Storage in Cementir's "hard-to-abate" plants.

Climate adaptation elements:

The policy addresses climate change adaptation through product innovation and the adoption of circular and sustainable strategies. The adoption of innovative technologies, such as FUTURECEM cement, could make products more durable and resistant to extreme climatic conditions, indirectly contributing to climate change adaptation. The use of more resilient materials could improve the resistance of buildings and infrastructure to extreme weather events. The reuse of demolition materials and the recycling of construction materials contribute not only to sustainability but also help reduce risks related to resource scarcity and the need to adapt to new climatic conditions.

Linkage to standards:

• Energy Management System compliant with ISO 50001 standard
• Lines of action guide the CO2 strategy of the Group to net zero by 2050, aligned with the 1.5 °C scenario defined in the Cement Sector guidance of SBTi (Science Based Targets initiative)

Actions and resources in relation to climate change policies

Cementir discloses that actions are defined in relation to climate change policies in the "Cementir Roadmap 2030" section and "EU Taxonomy" paragraph (cross-referenced). The following specific actions are described:

CDP Supply Chain Program – Climate Change and Water Security

What it does:

• Since 2020, strategic suppliers invited to complete the Climate Change Questionnaire disclosing climate-related risks, emissions data, targets, and reduction actions
• Since 2023, expanded to Water Security Questionnaire to assess water resource usage, risk management, and mitigation strategies
• Supplier training webinars held since 2020 to communicate importance of transparently reporting on emissions and water security

Scope: Upstream value chain (suppliers)

Time horizon: Ongoing since 2020, expanded in 2023

Resources allocated: Not quantified

Outcomes (2024):

• 173 suppliers involved (vs. 154 in 2023)
• 74 suppliers responded to Climate Change questionnaire (43% response rate)
• 88% of responding suppliers implemented emission reduction initiatives
• 81% of responding suppliers set climate targets
• 35 suppliers have SBTi-approved targets
• 53 suppliers responded to Water Security questionnaire (31% response rate)
• 100% of responding suppliers have risk assessment procedures

Links to policy/target: Supports Climate Transition Plan to achieve net-zero GHG emissions across entire value chain by 2050

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European Carbon Border Adjustment Mechanism (CBAM) Compliance

What it does:

• New requirements introduced late 2023 for non-European suppliers of clinker and cement to disclose Scope 1 and Scope 2 emissions directly to Cementir
• Supply Chain team works with suppliers to ensure data provision in cases of non-compliance
• Plans to implement third-party verification of disclosures in near future

Scope: Upstream value chain (non-EU suppliers)

Time horizon: Started late 2023, third-party verification planned for near future

Resources allocated: Not quantified

Outcomes: Enhanced transparency and regulatory compliance

Links to policy/target: Supports Scope 3 emissions management within Climate Transition Plan

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Carbon Capture Technologies – Research Projects

What it does:

• Dedicated team focused on advancing carbon capture implementation at Aalborg (Denmark) and CCB (Belgium)
• Three project types: (1) techno-economic assessments, (2) pilot projects for small-scale CO2 capture testing, (3) value chain development for transport and permanent storage

Scope: Own operations

Time horizon: Various projects underway

Resources allocated: Not quantified at program level

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ACCSION Project

What it does:

• Establish one of Europe's first full onshore carbon capture, transport, and storage value chain
• Capture 1.4 million tons of CO2 annually from Aalborg Portland cement plant
• Aims to make Aalborg Portland Europe's first net-zero cement plant producing grey and white cement by 2030

Scope: Own operations (Aalborg Portland, Denmark)

Time horizon: 2025 to 2030 (operational by end of 2030)

Resources allocated:

• Grant amount: €220 million from EU Innovation Fund
• Partners: Cementir Holding-Aalborg Portland, Air Liquide

Expected outcomes:

• 1.4 million tons CO2 captured annually
• 113% of GHG emissions avoidance over first ten years
• Net-zero cement plant by 2030

Links to policy/target: Supports Climate Transition Plan net-zero by 2050 goal; Denmark's GHG emissions reduction goals

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CASPER Project

What it does: Purpose not fully disclosed in excerpts

Scope: Not specified

Time horizon: Not specified

Resources allocated: Not specified

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Renewable Energy Expansion via Power Purchase Agreements (PPAs)

What it does:

• Significantly increased use of renewable energy through green electricity PPAs
• New agreements signed with Engie and EtherEnergy for Belgian subsidiary CCB

Scope: Own operations

Time horizon: 2024 (recent expansion)

Resources allocated: Not quantified

Outcomes (2024):

• 49,071 MWh of green electricity via PPAs
• Represents approximately 4% of total electricity consumption
• Total renewable energy consumption: 1,365,112 MWh (12.6% of total)

Links to policy/target: Supports energy transition and emissions reduction

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Science Based Targets Initiative (SBTi) Validation

What it does:

• CO2 emissions reduction targets validated by SBTi since 2021
• As of February 2024, deemed consistent with 1.5°C scenario
• Targets to be reviewed and revalidated every five years

Scope: Entire value chain

Time horizon: Ongoing (next review due 2026)

Resources allocated: Not quantified

Links to policy/target: Ensures CO2 strategy alignment with net zero by 2050 and 1.5°C scenario

Targets related to climate change mitigation and adaptation

Cementir has established comprehensive climate change mitigation targets validated by the Science Based Targets initiative (SBTi) in February 2024, aligned with the 1.5°C scenario.

Overall Net-Zero Target

Target: Achieve net-zero greenhouse gas (GHG) emissions across the value chain by 2050

• Scope: Scope 1, 2, and 3 emissions
• Type: Absolute
• Validation: SBTi-approved (February 2024)

Near-Term Targets (2030)

Grey Cement CO2 Reduction Target

Progress (2024):

• CO2 emissions: 634 kg CO2/ton cement (9% reduction vs 2020)
• Clinker ratio: 77%
• Alternative fuel use: 34%

Type: Intensity-based (per ton of cement) Scope: Scope 1 emissions Validation: SBTi-validated

White Cement CO2 Reduction Target

Progress (2024):

• CO2 emissions: 860 kg CO2/ton cement (6% reduction vs 2020)
• Clinker ratio: 80%
• Alternative fuel use: 2%

Type: Intensity-based (per ton of cement) Scope: Scope 1 emissions Validation: SBTi-validated

SBTi Near-Term Commitment

Target: Reduce gross Scope 1 and 2 GHG emissions 29.33% per ton of cementitious product by 2030

• Baseline year: 2021
• Type: Intensity-based
• Validation: SBTi-validated (February 2024)

Target: Reduce gross Scope 3 GHG emissions from purchased goods and services 23.00% per ton of purchased clinker and cement by 2030

• Baseline year: 2021
• Baseline value: 873 kg CO2/ton purchased clinker and cement (2021)
• Type: Intensity-based
• Validation: SBTi-validated (February 2024)

Progress (2024):

• Scope 3: 830 kg CO2/ton purchased clinker and cement

Long-Term Targets (2050)

Target: Reduce gross Scope 1 and 2 GHG emissions by 96.1% per ton of cement by 2050

• Baseline year: 2021
• Type: Intensity-based
• Validation: SBTi-validated (February 2024)

Target: Reduce absolute Scope 3 GHG emissions 90% by 2050

• Baseline year: 2021
• Type: Absolute
• Validation: SBTi-validated (February 2024)

Supporting Operational Targets

Alternative Fuels

Target: 48% alternative fuel use for grey cement production by 2030

• Progress (2024): 34% (vs 33% in 2023)
• Intermediate milestone: 2025

Target: 6% alternative fuel use for white cement production by 2030

Denmark-Specific Target

Target: Reduce Scope 1 emissions to maximum 600,000 tonnes by 2030 (Aalborg Portland)

• Baseline year: 2021
• Reduction: 73% reduction vs 2021 levels
• Type: Absolute
• Scope: Aalborg Portland plant in Denmark

Carbon Capture and Storage

Target (ACCSION Project): Capture 1.4 million tons of CO2 annually from Aalborg Portland cement plant

• Target year: End of 2030
• Scope: Denmark operations
• Validation: EU Innovation Fund grant of €220 million awarded

Energy Targets

Target: Increase use of renewable electricity through Power Purchase Agreements

• Progress (2024): 49,071 MWh of green electricity (approximately 4% of total electricity consumption)

Investment Commitment

Target: €100 million investments in Sustainability and Digitalisation in 2024-2026 period

• Status: Approved by Board of Directors in February 2024

Target: €53 million investments in sustainability projects over 2025-2027 period

• Scope: FUTURECEM® production upgrades, switch to natural gas in Danish plant, CCS projects in Denmark and Belgium, water resource optimization
• Note: ACCSION project (CCS in Denmark) not included in this figure; €220 million EU Innovation Fund grant also not included

Monitoring and Governance

Targets are deployed per single plant and year, included in the 2025-2027 Industrial Plan approved by the Board of Directors on 11 February 2025, and incorporated into employee short-term incentive systems.

Energy consumption and mix

Total energy consumption

Fossil sources disaggregation

Energy intensity

Methodology note: In 2024, cement production plants used 9.4 million MWh of thermal energy and 1.2 million MWh of electricity. Ready-mix concrete production plants used 115,370 MWh (approximately 1% of total energy). Other activities consume another 1%. Energy consumption data is sourced primarily from direct measurements at cement plants under the EU ETS, and from plant-specific or IPCC/CSI default emission factors for non-ETS sites. For purchased electricity market-based accounting, the residual mix factor is used where available (European countries), otherwise the location-based factor applies (non-European countries).

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 – Direct GHG emissions

Cementir discloses Scope 1 emissions by cement type (grey and white cement) and per ton of cementitious product. The following table shows Scope 1 emissions per ton of cementitious product for the reporting period and prior years:

Reduction versus 2020 (Grey Cement):

• 2024: -12%
• 2030 target: -36%

Reduction versus 2020 (White Cement):

• 2024: -6%
• 2030 target: -19%

Methodology note: Scope 1 emissions are calculated using the Global Cement and Concrete Association (GCCA) CO₂ and Energy Protocol, Version 3. Default CO₂ emission factors from the GCCA were used. Scope 1 includes direct emissions from on-site fuel combustion and process emissions from clinker production (calcination).

Scope of reporting: The emissions data covers all fully consolidated cement plants producing grey and white cement. The subsidiary SCT is fully consolidated in sustainability reporting (65% in financial reporting).

Scope 2 – Indirect GHG emissions from purchased energy

Cementir does not disclose separate location-based and market-based Scope 2 figures in the excerpts provided. The company states it follows the GCCA Protocol for Scope 2 calculation but does not present disaggregated Scope 2 data in the sustainability statement.

Methodology note: The GCCA Protocol references are provided, and the company uses emission factors from Ecoinvent and other databases, but explicit Scope 2 figures are not reproduced in the excerpts.

Scope 3 – Indirect GHG emissions from value chain

Cementir calculates Scope 3 emissions primarily for Category 1: Purchased goods and services, focusing on purchased clinker and cement. The company has set a Science Based Target to reduce Scope 3 emissions from purchased clinker and cement by 23% per ton by 2030 (from a 2021 baseline).

Scope 3 categories covered: The company explicitly calculates and discloses Category 1 (Purchased goods and services). The excerpts reference engagement with suppliers on climate change and water security through CDP Supply Chain, indicating data collection for upstream emissions. However, no breakdown by all 15 GHG Protocol categories is provided.

Methodology note: Scope 3 emissions are calculated using emission factors from Ecoinvent 3.7.1 (for 2021), Ecoinvent 3.8 (for 2022), Ecoinvent 3.9 (for 2023), BEIS & DEFRA (2021-2022), and IEA (2022). The company acknowledges high measurement uncertainty for Scope 3 due to reliance on third-party databases and average emission factors.

Total GHG emissions and intensity

The excerpts do not provide an explicit total (Scope 1 + 2 + 3) figure in absolute terms (tCO₂eq). The company presents emissions intensity by product (kg CO₂/ton of cement) rather than consolidated absolute emissions across all scopes.

GHG intensity metrics:

• Grey cement Scope 1: 632 kg CO₂/ton cement (2024)
• White cement Scope 1: 859 kg CO₂/ton cement (2024)
• Scope 3 (purchased clinker and cement): 830 kg CO₂/ton (2024)

No revenue-based intensity (tCO₂eq per M€) is disclosed in the excerpts.

Regulated emissions and biogenic CO₂

The company operates cement plants in EU ETS jurisdictions (Denmark, Belgium) and references CBAM (Carbon Border Adjustment Mechanism) compliance obligations. However, explicit figures for EU ETS allowances, verified emissions under ETS, or separate biogenic CO₂ emissions are not provided in the excerpts.

Biogenic CO₂: The company references biogenic CO₂ from alternative fuels (biomass) and notes that capturing and storing biogenic CO₂ through CCS would offset residual fossil emissions, enabling the Aalborg plant to become "net-zero" by 2030. However, a separate biogenic CO₂ figure is not quantified.

Country-by-country emissions data

The company provides a country-by-country reporting table (for tax transparency purposes) including number of employees, revenues, and tangible assets by jurisdiction. However, this table does not break down Scope 1, 2, or 3 emissions by country. Plant-level emissions are not disclosed.

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Note on disclosure quality: Cementir provides robust Scope 1 intensity metrics by cement type with multi-year trends and clear baseline (2020) and target year (2030). Scope 3 disclosure is limited to Category 1 (purchased clinker and cement) with high reliance on third-party emission factors. Scope 2 location-based vs. market-based distinction is not disclosed. Absolute emissions (tCO₂eq) across all scopes are not consolidated into a single total figure. The company acknowledges measurement uncertainty for Scope 3 and notes the use of Ecoinvent databases.

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

Phase-in exemption applied

Cementir Holding has applied the phase-in option for ESRS E1-9 (Anticipated financial effects from material physical and transition risks and potential climate-related opportunities) in the 2024 reporting period.

As stated in the exclusion table:

Time horizons

The company has defined three time horizons for climate-related considerations:

• Short term: 1-3 years, in which sensitivity analyses based on the Industrial Plan presented to investors can be performed
• Medium term: until 2030, a time horizon beyond the Industrial Plan but addressed by the Cementir Climate Change Strategy and its 10-year roadmap
• Long term: 2030-2050, in which chronic structural changes in the climate should begin to emerge

Approach to climate-related financial planning

The Group regularly assesses current and potential impacts of climate-related risks and opportunities on the business and consequently updates its strategy and its financial planning. The long-term sustainability strategy assumptions and implications have been encapsulated in the Group Industrial Plan 2021-23, approved by Cementir Board of Directors in February 2021, and in the Group Consolidated Financial Statements and Sustainability Report for year 2020.

Policies related to pollution

Cementir addresses pollution through its overarching Environmental Policy, which applies to all operational activities within the Cementir Group. The policy is not exclusively focused on pollution but includes specific commitments and mechanisms relevant to pollution management.

Environmental Policy

Scope: All operational activities within the Cementir Group (applies to all 11 cement plants, with ISO 14001 certification in 9 out of 11 plants as of 2024, targeting full certification by end of 2025)

Governance and oversight: The Environmental Policy is approved at Group level. Each operating company is responsible for implementing the policy's directives and guidelines as part of its own Environmental Management System. The HSE function is responsible for ensuring adherence to the Group's Environmental Policy.

Key content and principles:

• Prioritizing environmental factors in the development of operations and assessing impacts on new or modified sites to achieve positive outcomes
• Promoting efficient environmental practices and exploring advanced technologies to minimize environmental footprint throughout the product lifecycle
• Setting clear, measurable environmental targets aligned with the UN Sustainable Development Goals
• Regularly monitoring, reviewing, and disclosing environmental performance using internationally recognized indicators
• Fostering constructive cooperation within the company and with local communities and institutions to address environmental challenges
• Encouraging employees and supply chain partners to adopt sustainable environmental practices through training and awareness activities
• Ensuring compliance with all relevant laws and corporate guidelines
• Pollution-specific commitments:
  • Reducing pollutant emissions and maintaining an efficient monitoring system to prevent and control emissions to the environment, following the Best Available Techniques (BAT)
  • Minimizing the impact of operations on nearby areas and the community
  • Managing environmental responsibilities through effective implementation and maintenance of an Environmental Management System (EMS) compliant with ISO 14001

Public availability: The document refers to the Environmental Policy being detailed in the "General Information section" but does not provide a specific URL or web location.

Link to international standards:

• ISO 14001 (Environmental Management System) - certification present in 9 out of 11 plants, targeting 100% coverage by end of 2025
• UN Sustainable Development Goals (SDGs)
• EU Best Available Techniques (BAT)
• GCCA Sustainability Guidelines
• Industrial Emissions Directive (2010/75/EU) and EU BAT conclusions (applicable to cement plants in Denmark and Belgium)

Monitoring and implementation:

• ISO 14001 certification process requires risk assessment related to environmental impact through an evaluation matrix involving affected communities
• Environmental Risk Management (ERM) focuses on managing and monitoring material pollution impacts
• Continuous air emission monitoring through Continuous Emission Monitoring Systems (CEMS) and discontinuous measurements
• In 2024, 100% of clinker production was monitored through CEMS and discontinuous measurements
• 99% of total clinker production monitored through CEMS for primary pollutants (dust, NOx, SOx)
• The Group has a Monitoring and reporting of air emissions guideline that defines minimum requirements for parameters, measurement frequency, and indicators for all cement plants
• Monitoring and reporting align with internationally recognized reference documents (EU BAT and GCCA Sustainability Guidelines)
• HSE function integrated into established processes to ensure policy adherence
• Annual community engagement and impact assessment as part of certified environmental management systems (though not all plants participate annually)

Actions and resources related to pollution

Cementir Group has an action plan for managing pollutants, consisting of a continuous air emission monitoring and discontinuous measurements control system.

The plan focuses on mitigating the negative impacts associated with environmental sustainability issues and ensuring compliance with current regulations as well as voluntary and sector-specific guidelines.

Monitoring and reporting of air emissions

Objective: Guidelines for monitoring and reporting environmental performance related to channelled air emissions (excluding CO₂) in cement plants.

Scope:

• Applies to all cement plants within the Cementir Group (own operations)
• Focuses on emissions from the kiln stack, the primary source of emissions
• Excludes CO₂ emissions, which are covered by separate Group guidelines

What it does:

• Defines minimum requirements for parameters, measurement frequency, and indicators to be implemented by each operating company as part of its environmental management system
• Outlines the reporting process to the Group HSE function
• Provides standardized guidance for air emissions accounting

Pollutants monitored:

• Dust, nitrogen oxides (NOx), and sulphur oxides (SOx)
• Total organic compounds (TOC), including volatile organic compounds (VOC)
• Gaseous chlorides (HCl) and fluorides (HF)
• Carbon monoxide (CO)
• Heavy metals such as mercury (Hg), cadmium (Cd), thallium (Tl), and others
• Polychlorinated dibenzodioxins and dibenzofurans (PCDD/Fs), reported as International Toxic Equivalent (I-TEQ)

Measurement approach: Monitoring using continuous (CEMS) or periodic (discontinuous) measurements according to:

• Air emissions permit/authorization by local competent Authority
• Local environmental standards and regulations
• Recognized sectorial monitoring rules and metrology standards

Expected outcomes: Effective management of air pollutants addresses air quality and indirectly mitigates negative impacts on soil, living organisms, and food resources, as identified in the Double Materiality assessment.

Resources allocated: Financial resources allocated to the air emissions monitoring plan include:

• Operational expenses (Opex) for the daily management of activities
• Capital expenditures (Capex) for the management and maintenance of assets
• Funds aligned with the Group's 2030 roadmap and integrated into routine management activities
• Note: There are no significant Opex or Capex expenses to report

Link to policy:

• Integrated into the HSE function, which ensures adherence to the Group's Environmental Policy
• Aligned with ISO 14001 certifications (present in 9 out of 11 plants, with goal of extending to all plants by end of 2025)
• Monitored according to guidelines consistent with EU BAT and GCCA Sustainability Guidelines

Targets related to pollution

At the moment, the Group has not defined measurable targets related to pollution.

The established processes are integrated into the HSE function, which is responsible for ensuring adherence to the Group's Environmental Policy.

The Group monitors and reports emissions from cement production according to guidelines consistent with recognized international reference documents, such as the EU BAT and GCCA Sustainability Guidelines.

ISO 14001 certifications are present in 9 out of 11 plants, with the goal of extending this certification to all plants by the end of 2025.

Pollution of air, water and soil

The pollution ranges within which kilns operate depend largely on the nature of the raw materials, fuels, age and design of the plant. The concentration of impurities and the behaviour of the limestone during firing/calcination can influence pollutants, e.g. the variation of the sulphur content in the raw material plays an important role and influences the range of the sulphur emissions in the exhaust gas.

The Group implements suitable technologies to reduce air emissions in line with the Best Available Techniques (BAT), such as electrostatic precipitators and fabric filters for dust, low NOx burners, and selective non-catalytic reduction systems for NOx.

In particular, cement plants located in Denmark and Belgium are subject to the Industrial Emissions Directive (2010/75/EU) and the relevant EU BAT conclusions.

In 2024, 100% of clinker production was monitored through Continuous Emission Monitoring Systems (CEMS) and discontinuous measurements of all emissions, with an increased frequency of sampling compared to 2023. Additionally, 99% of the total clinker production at the Group level was monitored through CEMS for the primary pollutants: dust, nitrogen oxides (NOx), and sulphur oxides (reported as SO2). Volatile Organic Compounds (VOCs), measured as Total Organic Compounds (TOC), are also reported.

Although present in very small quantities, emissions of volatile or semi-volatile heavy metals and their compounds, as well as polychlorinated dibenzodioxins and dibenzofurans (PCDD/Fs), are also considered significant. These emissions are influenced by kiln and process design, as well as the composition of raw materials and fuels, including biomass. Non-volatile metal compounds remain within the process and are incorporated into the clinker composition.

Monitoring and reporting air emissions are key components of the Group's efforts to minimize its environmental impact. The Cementir Group's monitoring guidelines align with internationally recognized reference documents, such as the EU BAT and GCCA Sustainability Guidelines, for tracking and reporting emissions from cement production.

In 2024, the Cementir conducted a review of the monitoring procedures across all cement plants. Some nonconformities were identified, mainly due to calculation errors, which have since been corrected. As a result, emission data was revised, recalculated, and aligned with previous years' values.

Over the past three years, the Group has seen an overall improvement in key air emission indicators, attributed to more stable operating conditions and lower sulphur content in raw materials and fuels. The optimization of production between white and grey cement also contributed.

Several environmental projects are currently underway, aiming to further improve the Group's performance, particularly in reducing dust emissions (e.g., installation of fabric filters).

During the year, no fines and penalties were received.

Air Emissions (2022-2024)

[1] Sb, As, Pb, Cr, Co, Cu, Mn, Ni, e V.

Water Discharge

Water from production phases is typically treated on-site before discharge (97% of total water discharge in 2024).

The primary treatment involves the physical removal of suspended solids and floating materials, usually through sedimentation.

Secondary treatment, including wastewater treatment plants (e.g., biological units), is implemented in some cement plants and in our waste treatment plants.

Tertiary treatment (chemical and biological), applied after secondary treatment, removes suspended, colloidal, and dissolved constituents such as nutrients, heavy metals, and other contaminants. This tertiary treatment is only relevant for the Group's waste management plants.

Of the total water discharged from cement production, 96% was freshwater.

Quality monitoring of water discharge is conducted periodically. The frequency of these measurements is typically monthly but may vary depending on local regulations (e.g., quarterly) and environmental permits. Effluent parameters are periodically monitored using recognized analytical methods required by local authorities, such as total suspended solids, pH, temperature, and oxygen demand.

Examples of periodic measurement methods include: EN 872 or ISO 11923 for total suspended solids, EN ISO 10523 for pH, and EN 1899 or ISO 5815 for BOD (Biochemical Oxygen Demand).

Soil Pollution

The effective management of air pollutants not only addresses air quality but also indirectly mitigates negative impacts on soil, living organisms, and food resources, as identified in the Double Materiality assessment. This is achieved through the Company's action plan, which focuses on monitoring and controlling air emissions while actively managing their broader environmental effects.

E-PRTR Compliance

The document references that emissions are monitored in accordance with Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) for pollutants emitted to air, water and soil (paragraph 28). The Group's monitoring guidelines align with internationally recognized reference documents, including EU BAT and GCCA Sustainability Guidelines.

Measurement Methods and Standards

Best Available Techniques include continuous and periodic measurements in line with relevant EN, ISO, or US EPA standards:

• EN ISO 13284 / US EPA 5 for dust
• EN ISO 14792 / US EPA CTM 34 for NOx
• EN ISO 14791 / US EPA 6 for SO2
• EN 14385 and EN 13211 / US EPA 29 and 30 for metals and mercury

For continuous measurements, measurement uncertainty is determined according to EN 14181.

Substances of concern and substances of very high concern

E2-5 is assessed as not material by Cementir Holding and therefore no disclosure is provided in the 2024 sustainability statement.

As stated in the phase-in and materiality table (page 195), Cementir has determined that E2-5 (Substances of concern and substances of very high concern) is not material to its operations and has not disclosed quantitative or qualitative information regarding:

• Total amounts of substances of concern (SoC) generated, used or procured
• Total amounts of substances of very high concern (SVHC)
• Breakdown by hazard class
• Amounts leaving facilities as emissions, products, or services
• Narrative on monitoring and management (REACH compliance, etc.)

Anticipated financial effects from pollution-related impacts, risks and opportunities

The Group has elected to use the phase-in option for this disclosure requirement.

As stated in the disclosure table, E2-6 (Anticipated financial effects from pollution-related impacts, risks and opportunities) is subject to the Phase-in option.

Policies related to water and marine resources

Cementir Holding has established policies to manage water resources across its operations and value chain.

Group Water Policy

Scope:

• Applies to all operations within the Group
• A fundamental part of each company's Environmental Management System
• Extends to supply chain partners through the Supplier Code of Conduct

Governance:

• Head of Region are responsible for the correct application of the Policy

Key content and principles:

• Assess water supply as a risk/opportunity in business operations and development
• Promote water efficiency through practices such as recycling, minimizing wastewater discharge, reducing freshwater use, and utilizing alternative water sources
• Prioritize freshwater efficiency, especially in high-water-stress areas identified by the World Resources Institute's Aqueduct map
• Set measurable water management targets aligned with the UN Sustainable Development Goals
• Regularly monitor, review, and disclose water management performance using internationally recognized indicators
• Foster constructive cooperation within the Group, local communities, and institutions to address water conservation challenges
• Encourage responsible water use and conservation among employees and supply chain partners
• Ensure compliance with all relevant local, national, and international laws, as well as corporate guidelines

Link to international standards:

• Aligned with the UN Sustainable Development Goals

Public availability:

• The policy is referenced in the General Information section (detailed location for access not specified in excerpts)

Supplier Code of Conduct

The Supplier Code of Conduct addresses water management expectations for suppliers.

Scope:

• Applies to suppliers throughout the value chain

Key content related to water:

• Suppliers are expected to be committed to efficient water management practices, including minimizing freshwater withdrawal, reducing wastewater discharge, and enhancing water recycling and reuse at an appropriate level
• Suppliers must uphold socially responsible practices and address climate change and emissions
• Relationship with local community is critical, as business activities impact surrounding areas

Public availability:

• Available via a link (link reference provided but actual URL not included in excerpts)

Implementation monitoring:

• The Group believes that effective water management is achieved through the implementation and upkeep of Environmental Management Systems
• Regular monitoring, review, and disclosure of water management performance using internationally recognized indicators

Actions and resources related to water

Starting with water-scarce areas as a priority, the Group promotes the sustainable use of water across all its activities.

Cementir is strongly committed to reduce water consumption through:

• Increasing water reused/recycled (e.g., drainages improvement and rainwater collection to reuse/recirculate a portion of water)
• Minimizing water withdrawal and wastewater discharge
• Minimizing losses (e.g., periodical checks of underground water piping and pump conditions and their replacement if needed)
• Promoting water management efficiency practices

One of the objectives is to maximize the collection of rainwater. Most sites have adequate collection systems (e.g. running tank) for production processes. There is no punctual monitoring of total volumes of water stored.

Cement production

Scope: Own operations
Performance (2024):

• Water consumption: 3,429 thousand m³ (78% of Group total)
• Water consumption in high water stress areas: 31% of total consumption
• Water reused/recycled: 31% of total water withdrawn
• Freshwater discharge: 96% of total water discharged

Wastewater as a resource (Al Arish, Egypt)

Action: Use of wastewater from water treatment unit

Description: Part of water flow not usable for industrial purposes due to high salinity. Three initiatives implemented in 2024:

1. Agricultural purposes: 130 olive trees planted. Number of trees will be increased in future years.
2. Quarry road spraying: Wastewater used for spraying quarry roads to reduce dust emissions from vehicles and mobile equipment.
3. Pet coke storage: Wastewater fed to tank of water spray system for pet coke storage to control dust emissions and maintain product moisture content.

Scope: Own operations (Al Arish, Egypt)
Time horizon: Ongoing (2024 implementation, expansion planned)
Resources: Not quantified
Expected outcomes: Utilize wastewater not suitable for industrial use; reduce dust emissions; agricultural development

Ready-mix concrete production

Scope: Own operations
Performance (2024):

• Water consumption: 657 thousand m³ (15% of Group total)
• Water consumption in high water stress areas: 70% of total ready-mix consumption
• Water reused/recycled: 24% of total water withdrawn

The Group is actively working to maximize water reuse for new preparations and on-site activities.

Zero water discharge

Action: Zero water discharge in ready-mix production plants

Description: Maximize rainwater collection and recycled water recovery to achieve zero water discharge, starting with plants in high water stress areas (e.g., Belgium, Northern France). Where possible, water after sedimentation steps is reused for new product preparation. In some plants, capacity of water recovery basins was increased, reaching zero discharge.

Example site: New basin at Noyelles-Lès-Seclin

Scope: Own operations (prioritizing high water stress areas: Belgium, Northern France)
Time horizon: Ongoing
Resources: Not quantified (infrastructure: water recovery basins expansion)
Expected outcomes: Zero water discharge at plants in high water stress areas

Aggregates production

Scope: Own operations
Performance (2024):

• Water consumption: 327 thousand m³ (7% of Group total)
• Water reused/recycled: 14% of total water withdrawn
• Increase compared to 2023 due to initiation of new activities

Actions: Where quarry dewatering is implemented, focus on recovering quarry water. Pumped water repurposed for:

• Washing aggregates
• Watering tracks

In many cases, water use arranged in closed-loop system to minimize volume of pumped water.

Scope: Own operations (quarries)
Time horizon: Ongoing
Resources: Not quantified
Expected outcomes: Minimize pumped water volume through closed-loop systems

Value chain actions

As per the Supplier Code of Conduct, suppliers are expected to be committed to efficient water management practices, including:

• Minimizing freshwater withdrawal
• Reducing wastewater discharge
• Enhancing water recycling and reuse at an appropriate level

Scope: Upstream value chain (suppliers)
Time horizon: Ongoing
Resources: Not quantified (governance through Supplier Code of Conduct)
Link to policy: Supplier Code of Conduct

Targets related to water and marine resources

Cementir Holding has established water consumption reduction targets aligned with its 2030 Roadmap and based on water stress scenarios from the World Resources Institute (WRI) Aqueduct Water Risk Atlas.

Group-level target for cement production

Target metric: Water consumption in cement production
Target value: 30% reduction
Target year: 2030
Baseline year: 2019
Baseline value: Not disclosed
Scope: Own operations - cement production
Type: Intensity-based (implied)
Validation: Internal (aligned with Group's 2030 Roadmap)
Note: Target was revised upward from previous 20% reduction target

Target for plants in high and extremely high water stress areas

Target metric: Water consumption at plants in high and extremely high water stress areas
Target value: 25% reduction
Target year: 2030
Baseline year: 2019 (recalculated based on updated Atlas data)
Baseline value: Not disclosed
Scope: Own operations - specific cement plants:

• Al Arish (Egypt) - Arid and low water use risk category
• Izmir (Turkey) - Extremely high-risk category
• Gaurain (Belgium) - Extremely high-risk category
• Kars (Turkey) - High-risk category
  Type: Intensity-based (specific consumption rate mentioned)
  Validation: Internal (aligned with Group's 2030 Roadmap)
  Note: These plants start with specific consumption rate significantly lower than Group average

Water stress future scenarios

Metric tracked: % of cement plants operating in high and extremely high-water stress areas

• 2024: 36%
• 2030: 36%
• 2050: 54%

Metric tracked: % of all sites operating in high and extremely high-water stress areas

• 2024: 35%
• 2030: 38%
• 2050: 40%

Water consumption

Water management achievements:

• Cementir maintained its leadership in water management by achieving a score of A- in CDP Water, for the third consecutive year.
• The Group updated the water risk assessment at the individual cement plant level, according to the scenarios reported in the World Resources Institute (Aqueduct) information platform.
• At the Group level, compared to 2019 values, the target of reducing consumption in cement production was increased to 30% from the previous 20%.
• For plants located in high water stress areas, the reduction target for 2030 is 25%.

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

Phase-in exemption applied

Cementir Holding has applied the phase-in option for E3-5 Anticipated financial effects from water and marine resources-related impacts, risks and opportunities, as indicated in the disclosure requirements table.

Policies related to resource use and circular economy

Cementir has disclosed one named policy covering resource use and circular economy matters.

Environmental Policy

Scope:

• Applies to all operational activities within the Cementir Group
• Each operating company is responsible for implementing the directives and guidelines of the policy, integrating them as a vital part of its Environmental Management System

Key content and principles:

• Increasing the use of alternative fuels, including low-carbon fuels and biomass, while adopting a co-processing and circular approach to using waste as fuel
• Minimizing the use of non-renewable resources through the use of decarbonized and alternative raw materials
• Progressive reduction in the use of virgin resources and corresponding increase in the use of secondary resources, such as concrete-based demolition waste, to replace natural aggregates in concrete production
• Waste management focus on treatment plants that convert waste back into fuel
• Minimizing the production of hazardous waste and enhancing recycling, recovery, and reuse through a circular approach
• Improving environmental integration between the cement and waste treatment sectors to support the transition to renewable and alternative resources

Public availability:

• The disclosure refers readers to the "General Information section to deep dive" but no specific URL is provided in the excerpts

Governance:

• Not disclosed in the excerpts provided

Monitoring:

• Not disclosed in the excerpts provided

Links to international standards:

• Not disclosed in the excerpts provided

Actions and resources related to circular economy

The Group is committed to adopting a co-processing and circular approach both for the management of wastewater discharges and for the waste produced.

Regarding the activities of recovery and reuse of wastewater, please refer to chapter "E3 Water and marine resources".

Co-processing of waste in cement kilns

Action description: Co-processing of waste in cement kilns is an established and environmentally effective option and a circular solution for end-of-life materials. It not only recovers the energy content of the waste but also recycles its mineral content into high-value products. Co-processing results in the reduction of raw materials and fossil fuel consumption mitigating the effect of green-house gases. It also offers an effective solution to the waste management (e.g., storage and disposal).

For example, co-processing of waste allows for prevention of plastic pollution in the environment and avoiding options not environmentally sustainable such as disposal in landfills.

Waste is not only a source of recyclable materials, but also alternative fuels with a high calorific value. The Group is therefore committed to this dual-purpose use.

Scope: Own operations (cement kilns)

Time horizon: Ongoing since 2009

Resources allocated:

• Non-financial: From a business perspective, the Group was one of the leading industrial players to capitalise on these opportunities and since 2009 has been operating in the renewable energy, urban and industrial waste management and processing sectors. These operations are conducted through Recydia, which owns the Sureko businesses in Türkiye.
• Through its modern facility located to the west of the city of Izmir, Sureko is involved in the management of industrial and hazardous waste and the production of alternative fuels that are used at the Izmir plant.
• Company's plants use the latest biological technologies to produce alternative fuels and thermal energy.
• Financial: The financial resources allocated to waste monitoring and reporting activities are subject to periodic monitoring and include both operational expenses (OpEx) for the daily management of activities and capital expenditures (CapEx) for the management and maintenance of assets. These funds are aligned with the Group's 2030 roadmap and are integrated into the organization's routine management activities. (No specific amounts disclosed)

Expected outcomes:

• Minimising landfill waste
• Contributing to the reduction of greenhouse gas emissions
• Storage of urban waste releases methane, a greenhouse gas with a polluting effect 21 times greater than that of carbon dioxide. Therefore, using urban waste as an alternative fuel in cement plants contributes to the sustainable disposal of waste and reducing the negative effects of greenhouse gases
• Unlike the process in waste-to-energy plants, use of waste as an alternative fuel in cement plants does not produce residues, as the ash derived from combustion is recycled in cement production
• Reuse and recycling contribute to environmental footprint reduction by helping to improve sustainability within the cement value chain

Link to policy/target:

• Aligned with the Group's 2030 roadmap
• The established processes are integrated into the Technical Department mission and related job description, which is responsible for ensuring adherence to the Group's Environmental Policy
• The Group has targets related circular economy approach referring to resource use and in particular alternative fuels (refer to Chapter E1 Climate Change, section E1-5 Energy consumption and mix)

Minimizing hazardous waste production and enhancing recycling, recovery, and reuse

Action description: Efforts are made to minimize the production of hazardous waste and to enhance recycling, recovery, and reuse through a circular approach.

Scope: Own operations

Link to policy/target: The Group is committed to improving environmental integration between the cement and waste treatment sectors, further supporting the transition to renewable and alternative resources.

Waste monitoring and management

Action description: The Group constantly monitors waste production generated by its activities and adopts waste management solutions that allow recycling and/or reusing based on an environmental circular approach.

Resources allocated: The established processes are integrated into the Technical Department mission and related job description.

Targets related to circular economy

At the moment, the Group has targets related circular economy approach referring to resource use and in particular alternative fuels (please refer to Chapter E1 Climate Change, section E1-5 Energy consumption and mix).

The established processes are integrated into the Technical Department mission and related job description, which is responsible for ensuring adherence to the Group's Environmental Policy.

The Group constantly monitors waste production generated by its activities and adopts waste management solutions that allow recycling and/or reusing based on an environmental circular approach.

For further details on this aspect, please refer to sections "E5-2 Actions and resources related to resource use and circular economy" and "E5-5 Resource outflows".

Note: No specific quantified circular economy targets are disclosed in this section. The company refers to alternative fuel targets in the E1 Climate Change chapter (section E1-5).

E5-4 Resource inflows

Cementir Holding discloses resource inflows in accordance with ESRS E5-4. The data reported have been calculated using a mass balance determined by mass measurement devices.

Overall resource inflows (2024)

Note: The total reported is composed of the total of raw materials, both renewable and non-renewable, used for cement production and the total of raw materials, both renewable and non-renewable, used to produce "other products."

Alternative raw materials

Cement production requires large quantities of natural raw materials, such as limestone, clay and gypsum, extracted from natural quarries. The Group is particularly focused on reducing the use of non-renewable raw materials, promoting the use of alternative raw materials from other production processes.

In 2024, the cement production plants of the Cementir Group used a total of about 14.7 million tons of materials to produce cement and the percentage of alternative raw materials was 12%.

Raw materials used in cement production

Non-renewable raw materials used in cement production

Renewable materials used in cement production

Raw materials used in production for other products

In 2024, Cementir Group plants for all other activities different from cement production used a total of 10 million tons of raw materials, mainly in the ready-mix business where there is high usage of sand, stone, and cement. Use of renewable raw materials is far lower than in the cement business (about 72,000 tons), less than 1% of total raw materials used.

Raw materials used in production for other products

Non-renewable raw materials used in production for other products

Renewable materials used in production for other products

Resource outflows

Cementir produces cement, ready-mixed concrete, aggregates, and precast concrete products. The company has developed low-carbon cement products including FUTURECEM® (with up to 30% lower carbon footprint than ordinary Portland cement) and D-Carb® for white cement (15% lower CO2 emissions). These products contribute to sustainability through reduced clinker content and incorporation of alternative mineral additives such as fly ash, slag, limestone, and calcined clay.

For ready-mixed concrete, the company tracks Global Warming Potential (GWP) as a key performance indicator, which defines the amount of CO2 emitted for the same mechanical properties by a specific concrete recipe. This allows monitoring and improvement of the environmental impact of concretes produced.

Cementir promotes circularity through the reuse of demolition materials and recycling of construction materials. The company uses reclaimed aggregates from returned concrete and recycled concrete as substitutes for natural aggregates. In Denmark, surplus concrete (leftover from construction sites) is increasingly being recycled through crushing and reusing hardened concrete for aggregates and sand.

Products based on white cement provide enhanced durability compared to painted surfaces, requiring much less maintenance. The use of FUTURECEM® and similar technologies can make products more durable and resistant to extreme climatic conditions, improving the resistance of buildings and infrastructure to extreme weather events.

The company has Environmental Product Declarations (EPDs) available for main products in Denmark, Belgium, and for white cement offerings, providing transparent communication of environmental performance over product lifetime.

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

Phase-in exemption applied

Cementir Holding has applied the phase-in option for E5-6 Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities, as disclosed in the materiality assessment table.

Waste

Waste Management Approach

Cementir is committed to a circular economy approach that includes the recycling and reuse of materials. The Group's environmental policy aims at managing environmental responsibilities through effective implementation of Environmental Management Systems compliant with ISO 14001. As part of this certification, risk assessment processes related to environmental impact are required, which must be carried out through evaluation matrices involving affected communities.

The Group promotes co-processing and circular approaches to waste as fuel, which contributes to lower emissions compared to traditional fossil fuels. In Turkey, the Group processes industrial waste to produce waste-derived fuel for cement plants. The waste sector reported 72% higher revenues and 88% higher EBITDA in local currency in 2024 compared to 2023, due to increased volumes and prices of alternative fuels (RDF), collection of materials for fuel production, and increased quantities sent to landfill.

Alternative Fuel Production from Waste

In 2024, the Group's treatment plants produced a total of 15,569 tons of fuel from waste. The Group plans to increase alternative fuel usage, with targets of 48% for grey cement and 6% for white cement by 2030.

Scope 3 Waste Emissions

Scope 3 emissions from waste disposal and treatment in 2024 were:

The waste category includes emissions from external wastewater treatment, calculated using BEIS&DEFRA 2024 emission factors. End-of-life treatment includes emissions from the waste disposal and treatment of products sold by Cementir, also using BEIS&DEFRA 2024 emission factors.

Material Risks and Opportunities

The Double Materiality Assessment identified waste as a material issue. Waste from production processes, pollution control devices, and hazardous waste management activities present regulatory risks and can increase operating costs (assessed as medium-term risk across upstream and own operations).

Policies related to own workforce

Cementir Holding has established several policies governing its own workforce, covering diversity and inclusion, human rights, health and safety, and ethical conduct. These policies are integrated into the company's governance framework and regularly monitored through internal audit processes.

Group employees' diversity, equity & inclusion policy

Scope: All employees across the Cementir Group

Key content and principles:

• Establishes guidelines to promote a culture of respect for diversity, work equality, non-discrimination and inclusion of labor groups
• Promotes equal opportunities throughout the entire organization
• Prohibits discrimination based on race, disability, ethnicity, colour, pregnancy, gender, language, nationality, religion, age, sexual orientation and identity, political opinion, social status and disability
• Main objectives include:
  • Attract, hire and retain diversified talent for all positions
  • Facilitate an inclusive working environment
  • Promote equal opportunities in all areas
  • Foster collaboration respecting communication among team members
  • Promote achievement of UN SDGs 5 (Gender Equality) and 10 (Reduce Inequalities)

Approval and oversight:

• Board of Directors sets mid/long-term diversity targets and reviews them yearly
• Remuneration and Nomination Committee develops the diversity and inclusion policy for the composition of the Board and certain categories of senior management

Public availability: Published in November 2022, communicated to all employees

International standards alignment: Aligned with UN SDG 5 and SDG 10

Monitoring:

• Internal Audit Department conducts Diversity, Equity and Inclusion Self-Assessment as part of standard internal audit process
• In 2024, assessment covered 100% of Cementir's workforce worldwide (Belgium, Denmark, Norway, Türkiye, United States, China, Malaysia, Egypt, Italy, France, Iceland, Australia and Poland)
• Online training course launched focusing on DE&I principles
• Code of Ethics, Human Rights, Diversity, Equity and Inclusion Awareness Survey conducted in December 2024 (response rate over 20%)
• Specific training provided to all new hires

Group Human Rights Policy

Scope: All employees and business relationships (contractors, suppliers, business partners)

Key content and principles:

• Activities based on respect for global human rights as a non-negotiable fundamental value
• Applies founding principles of:
  • The United Nations International Charter (UN): Universal Declaration of Human Rights, International Convention on Civil and Political Rights, International Convention on Economic, Social and Cultural Rights
  • The fundamental conventions of the International Labour Organization (ILO) - n. 29, 87, 98, 100, 105, 111, 138, 182 - and the Declaration on Fundamental Principles and Rights at Work
  • The UN Convention on the Rights of the Child
  • The ILO Conventions n.107 and n.169 on the Rights of Indigenous and Tribal Peoples
  • The European Convention on Human Rights
• Explicitly prohibits child, forced or compulsory labor
• Supports freedom of association and collective bargaining
• Promotes respect for personal dignity and equal treatment

Approval and oversight: Board of Directors oversight through governance framework

Public availability: Published on corporate website under Governance/Ethics and Compliance section

International standards alignment:

• United Nations Guiding Principles on Business and Human Rights ("Protect, Respect and Remedy" Framework)
• ILO fundamental conventions and Declaration on Fundamental Principles and Rights at Work
• UN Global Compact membership since 2022 (Principles 1, 2, and 3)
• OECD Guidelines for Multinational Enterprises
• UN Declaration of Human Rights
• Standard SA8000® (as reference tool for managing Social Responsibility)

Monitoring:

• Online training course launched in 2020 focusing on policy principles
• Internal Audit Department includes human rights checklist in standard audit process since 2019
• In 2024, audits conducted covering 100% of Cementir's workforce (Belgium, Denmark, Norway, Türkiye, United States, China, Malaysia, Egypt, Italy, Poland, France, Australia, Iceland)
• Audits verify compliance in: Child Labour, Forced Labour, Non-Discrimination, Conditions of Employment, Security and Supply Chain Management, Community Relationship, Customer Management and Diversity, Equity and Inclusion
• No risks identified during 2024 audit activities
• Whistleblowing mechanism available for reporting violations

Group Occupational Health & Safety (OH&S) Policy

Scope: All employees across operating companies

Key content and principles:

• Protection of occupational health and safety and well-being of people as core values
• Commitment to a safe and healthy workplace environment, free from injuries, fatalities, and illnesses
• Framework for prevention of work-related incidents and illnesses aligned with international reference standards
• "Zero accident strategy" implementation
• Six Pillars of Action: Leadership in Practice, Commitment & Responsibility, Risk Management, Involvement & Participation, Competence & Awareness, Continuous Improvement
• Group's golden rules of safety (5 life-saving rules)

Approval and oversight:

• Corporate Health, Safety & Environment Function defines guidelines, rules and standards at Group level
• Group Management Team (GMT) ensures monthly monitoring of performance and progress
• Board oversight through Sustainability Committee

Public availability: Published as part of Group policies

International standards alignment:

• ISO 45001 certification (all cement plants certified since 2022)
• ISO 9001 certification
• Guidelines focused on ISO 45001 systemic approach

Monitoring:

• Global interconnected Health and Safety Network coordinated by Corporate HSE Function
• Network met 11 times in 2024
• H&S Committee at every site/business chaired by senior manager
• Common leading indicators set across the Group
• Health and Safety Balanced Scorecard tool evaluated for three cement plants in 2024
• Regular audits by Internal Audit Department

Code of Ethics

Scope: All company officers, employees, and anyone working with the company in any capacity

Key content and principles:

• Endorses business principles that all stakeholders are required to comply with in pursuing company business
• Prohibits discrimination on any grounds
• Ensures equal treatment and opportunities for professional and personal growth
• Guarantees fair and dignified treatment of employees
• Promotes respect for human rights and adherence to international standards

Approval and oversight:

• Board of Directors reviews and approves regularly
• Ethics Committee (established 13 November 2019) composed of Group General Counsel and Chief Internal Audit Officer, with powers equivalent to former Supervisory Body under Legislative Decree 231/2001

Public availability: Available on company intranet and public website

International standards alignment:

• UN Global Compact Ten Principles
• International human rights standards

Monitoring:

• Whistleblowing Management Procedure for reporting violations
• Internal Audit Department conducts investigations
• Code of Ethics, Human Rights, Diversity, Equity and Inclusion Awareness Survey conducted in December 2024

Whistleblowing Management Procedure

Scope: All internal and external stakeholders (employees, collaborators, administrators, third parties)

Key content and principles:

• Allows reporting of potential violations, non-compliance, or unlawful activities without fear of retaliation
• Covers: human rights violations, discrimination, harassment, violations of Code of Ethics, equal opportunities issues, mobbing, and other compliance concerns
• Guarantees confidentiality of whistleblower identity
• Online channel available 24/7
• Complies with European Directive 1937/2019 and Legislative Decree 24/2023

Approval and oversight:

• Ethics Committee oversight
• Board of Directors approval
• Review conducted end of 2024 to align with new applicable legislations (new procedure effective beginning of 2025)

Public availability: Published on corporate website

Monitoring:

• Internal Audit Department receives, analyzes and investigates all reports
• Investigations comply with IIA International Standards and Code of Ethics
• Periodic reporting to Top Management on complaints received, analyses progress, and action plans
• Statistics tracked on types, numbers, confirmed cases, and geographic location

Water Policy

Scope: All operations, particularly those in water-scarce areas

Key content and principles:

• Promotes sustainable use of water across all activities
• Commitment to reduce water consumption, increase water reused/recycled
• Minimize freshwater withdrawal and wastewater discharge
• Minimize losses through infrastructure monitoring
• Promote water management efficiency practices
• Maximize collection of rainwater

Monitoring:

• Regular monitoring of water consumption and recycling rates
• Focus on areas experiencing high water stress
• 2024 metrics: 31% of total water withdrawn was reused or recycled in cement production

Remuneration Policy

Scope: Executive Directors, Non-Executive Directors, and all employees

Key content and principles:

• Determines principles and guidelines for remuneration of Board members
• Ensures fair and attractive reward package considering individual performance, internal equity, market practices, macroeconomic environment
• Total reward strategy includes competitive base salary, short-term variable incentive, long-term variable incentive for top management, welfare offerings
• Promotes conduct aligned with corporate culture and values
• Contributes to long-term sustainable value creation

Approval and oversight:

• Remuneration and Nomination Committee examines and discusses remuneration policy
• Committee reports to Board of Directors
• General Meeting votes on Remuneration Report
• Committee met 3 times in 2024

Public availability: Main elements of Executive Director agreements published on company website

International standards alignment: Complies with Dutch law (Art. 2:135a of Dutch Civil Code) and Dutch Corporate Governance Code Best Practice provision 3.1

Monitoring:

• Annual Remuneration Report drawn up in accordance with legal requirements
• External benchmarking by independent expert (Korn Ferry) to align with best practices
• Pay ratios within company monitored and disclosed
• Gender pay gap analysis conducted (2024: -3.5% mean gender pay gap at Group level)

Supplier Code of Conduct

Scope: All Cementir Group Procurement suppliers (applies to value chain but relevant for own workforce standards)

Key content and principles:

• Sets minimum standards enforced contractually
• Requires suppliers to uphold socially responsible practices
• Expects suppliers to ensure safe and healthy work environment
• Prohibits child labor, forced labor, human trafficking
• Promotes respect for human rights throughout supply chain
• Includes requirements for health and safety management, emissions control, water management

Public availability: Available on corporate website

International standards alignment:

• UN Global Compact principles
• ILO fundamental conventions
• UN Framework and Guiding Principles on Business and Human Rights
• Universal Declaration of Human Rights

Monitoring:

• Contractual enforcement with suppliers
• Suppliers expected to constantly monitor compliance
• Whistleblowing channel available for supply chain workers

Taking action on material impacts on own workforce

Health and Safety Actions

Cementir's efforts regarding health and safety focus on:

• Building a robust HSE system
• Fostering safety awareness
• Reporting and analysing root causes to prevent incidents

These ongoing actions aim to prevent fatalities and health and safety incidents among employees.

Enterprise Risk Management and Internal Audit

Through the Enterprise Risk Management and Internal Audit teams, the Company has established an internal control system that supports management in defining strategies and mitigating risks related to its workforce.

Activities:

• Regular audits on social aspects including:
  • Human rights
  • Working conditions
  • HSE
  • Diversity and inclusion

Scope: Group-wide across all Company offices and sites

Policy Implementation and Training

All policies, procedures and activities implemented by the company are aimed to prevent and mitigate the identified negative impact identified by the double materiality.

Training actions:

• Code of Ethics and Conduct training for all employees (online)
• Majority of employees have completed the training
• Training included in induction for new employees

Diversity, Equity and Inclusion Training Programme

Launched in 2023 with the following characteristics:

Objective: Inform all employees and strengthen the creation of a safe and equitable workplace for all

Key focus areas:

• Coalition and empathy as key concepts for inclusive behaviour

Continuation: Training continued in 2024 and is mandatory for all new hires (training related to the Group employees' diversity, equity & inclusion policy)

Scope: All employees without distinction of level

Turnover Management Actions

Specific actions put in place by the Company with the support of the results of the People Survey.

Outcomes:

• Overall turnover rate decreased to 14% in 2024 (down from 16% in 2023)

Ongoing commitment:

• Yearly analysis to identify main reasons for leaving
• Development of possible actions and strategies to mitigate the turnover rate

Risk Mapping and Monitoring

Risk mapping performed at Group level regarding:

• Internal and external aspects related to the business (commercial, procurement & supply chain, macro-economic facets)
• Regulatory features (insurance, tax, general regulations)
• Values (ethics, social-environmental)

Process:

• Qualitative-quantitative assessments
• Definition of governance and management structures
• Preparation of mitigation and/or remediation plans and investment
• Risk reduction/elimination actions pursued at each country/function
• Implementation kept under control by identified process owners

Scope: Entire value chain, not just direct operations

Targets related to own workforce

The excerpts disclose that Cementir Holding sets targets related to own workforce, specifically in the areas of health and safety, and diversity, equity and inclusion.

Health and Safety Targets

The document states:

"The process of setting and monitoring health and safety targets takes into account factors such as past performance analysis, the company's risk profile, and alignment with Cementir's strategic initiatives. This ensures that the targets are both relevant and achievable."

No specific quantified health and safety targets, baseline years, target years, or target values are disclosed in the excerpts provided.

Diversity, Equity and Inclusion Targets

The Board of Directors sets mid/long-term targets related to Diversity, Equity and Inclusion:

"In order to ensure its adoption as well as the presence of workplace practices to give effect to it, the Cementir Holding Board of Directors sets mid/long-term targets related to Diversity, Equity and Inclusion and reviews them on a yearly base."

"According to the internal timeline the BoD define the annual target related to Diversity, Equity and Inclusion, for the Board itself and the Senior Management."

Board of Directors - 2024 targets achieved:

• Maintaining four Directors of the less represented gender, up to a total of nine members on the Board
• Target period: up to the deadline of the Board set with the approval of the financial statements for the year 2025
• Achieved gender parity: Board of Directors comprised of 8 Directors in absolute gender parity (appointed 20 April 2023)
• Additional targets achieved:
  • 3 Directors in which 1 crossbencher is younger than the CEO
  • 1 Director with specific experience in ESG issues having particular experience on social aspects

"It has to be noted that the targets mentioned above have been confirmed by the Board of Directors for the next two financial years."

Target governance:

• Targets can be extended to specific clusters or all employees
• Group HR is responsible for monitoring and reporting to the Board about progress
• Progress reported through the Group's Sustainability Statement

No specific quantified workforce-wide targets with baseline years, target years, or numerical values are disclosed in the excerpts provided.

Employees

Key workforce metrics for 2024:

• Total employees: 3,082 (as reported in key highlights)
• As at 31 December 2024, the Group's headcount stood at 3,082 employees, 37 more than at the end of 2023, mainly related to the expansion of the concrete production perimeter in Denmark.
• Personnel costs increased by approximately EUR 9 million compared to 2023 but were lower than the budget for 2024. The change is mainly due to the adjustment of personnel costs with respect to rising inflation, as also provided for in many local trade union agreements, turnover and recruitment processes and, lastly, to the effects due to currency exchange rates.

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

Number and breakdown of non-employees

The Cementir Group workforce comprises 988 contractors as of 31 December 2024. Cementir employs contractors primarily for the execution of operations inside the quarries and packing operations inside the cement plants.

Breakdown by type and region

The table below summarizes the main non-employee workforce figures by category and region as of 31 December 2024:

Methodology

The counting methodology uses headcount (number of persons).

Health and safety coverage

Non-employees in the undertaking's own workforce include both individual contractors supplying labour to the undertaking ("self-employed people") and people provided by undertakings primarily engaged in "employment activities" (NACE Code N78).

Health and safety data covering non-employees:

• Total LTIFR (lost time injury frequency rate) includes total accidents with absence from work for employees and contractors on site per million hours worked
• The number of recordable work-related accidents of non-employees in the entity's workforce in 2024 was equal to 37
• One contractor fatality occurred in cement plant after completion of a cleaning work; this event is under investigation by competent Authority to clarify if it was work-related or not

Collective bargaining coverage and social dialogue

Group-wide collective bargaining coverage

In 2024 around 61% of employees across the entire Group are covered by collective bargaining agreements (in line with the previous year). This percentage varies from country to country depending on the applicable local legislation and on the job classification categories.

Employees not covered by collective labour agreement are protected by the application of minimum wage salaries and the respective national labour agreement, if present - as per the Directive (EU) 2022/2041 of the European Parliament and of the Council of 19 October 2022 that guarantee an adequate minimum wage in the European Union, promoting collective bargaining on wages.

Coverage by country and region

Countries with more than 10% of total group employees:

EEA country-specific coverage

Denmark:

Belgium:

Non-EEA coverage

European Works Council (EWC)

The Cementir Group maintains an ongoing, structured dialogue with the representatives of its companies' European workers, in compliance with EU regulations and according to the framework adopted by the Group's European Company Committee (EWC). Throughout the year, management informed and consulted employees and trade unions on transnational issues concerning the status of its activities and other significant decisions that the Group has taken in relation to the business and its employees.

In June 2024, at the Gaurain plant (Belgium), management informed and engaged in discussions with employees and trade unions on transnational issues related to the status of operations and significant decisions made by the Group concerning the business and its employees. Key economic and financial results for the period were shared, along with the main ongoing strategic initiatives, such as the Carbon Capture project in Denmark and the Kiln 4 investment in Belgium, as well as key outcomes and subsequent challenges in the area of Health and Safety.

Diversity metrics

Gender distribution - Top Management

The gender distribution with specific reference to Top Management is presented below:

Top management definition by entity:

• Nordic&Baltic: CEO+CFO
• Belgium: CEO+EXPAT+DIRECTORS (N-1 Excluded Assistant)
• North America: CEO + MD
• Türkey: CEO + LOCAL CHAIRMAN
• Asia Pacific: CEO + MD + EXPAT
• HQ: All employees under Directors' collective Bargaining Agreement
• Egypt: CEO + DIRECTORS (N-1 Excluded Assistant)

Board of Directors and Committees - Gender and age diversity (multi-year)

The gender distribution of the members of the Board of Directors and the Committees of the Cementir Holding is shown in the table below. The following chart shows the distribution of the Board of Directors and the Committees as of December 31 of each of the last three financial years, in terms of diversity by age and gender.

Board of Directors

Board composition note: The Board of Directors is composed by 4 female board members out of a total of 8 ones elected by the Shareholders' Meeting, defining a 50% female representation, with an equal gender distribution: four women and four men.

Audit Committee

Remuneration and Nomination Committee

Sustainability Committee

Age distribution - Total workforce

Adequate wages

Benchmark used

Cementir Holding uses an external provider to provide salary benchmarks data to ensure that a proper compensation package is offered according to the breadth, complexity and strategic nature of the role held by each employee, anchoring value to the reference local market.

The salary benchmarks are updated on an annual basis. In case of high inflation, a more frequent update is considered to take into account the inflation impact on the job market.

Methodology

The salary increase is defined based on the following variables:

• Remuneration fairness compared to local market
• Performance rate
• Inflation of the country
• Available budgets

The increase of base salary or variable incentive level is decided based on two elements: market positioning and performance rate, the latter as result of Performance Management process.

Cementir develops and adopts retention plans considering general macroeconomic scenario and salary benchmarks of each country, with related updates performed periodically due to continuous changes.

Minimum wage compliance

With regards to standard salary paid to new hires during the first year in the Company, the total amount provided to employees is higher than the minimum prescribed by law and no difference between gender is made.

The company also references that employees not covered by collective labour agreements are protected by the application of minimum wage salaries and the respective national labour agreement, if present, as per the Directive (EU) 2022/2041 of the European Parliament and of the Council of 19 October 2022 that guarantees an adequate minimum wage in the European Union, promoting collective bargaining on wages.

Coverage and scope

No specific percentage coverage or geographic scope for living wage assessment is disclosed. The disclosure references that the external market benchmark is used "to ensure the alignment of the whole employee population."

For additional context on industrial relations, the company cross-references section S1-2.

Social protection

The Company makes sure that its employees are protected against loss of income resulting from significant life events, such as illness, workplace injury, parental leave, and retirement, in line with the terms and conditions outlined in contracts.

Coverage

At Group Level all employees in all countries are protected against loss of income resulting from significant life events, such as illness, workplace injury, parental leave, and retirement, with the exception of the following life events in USA:

• Illness
• Unemployment

Employees not covered by social protection

Persons with disabilities

Scope and restrictions

Due to legal restrictions under the EU General Data Protection Regulation (GDPR), which applies to all EU member states and EEA countries, as well as similar personal data protection principles established by national legislation in the countries where the company operates outside the EU and EEA, it is unable to report all the number of persons with disabilities within its organization.

For the countries not present in the table, the data cannot be disclosed/collected due to law reason.

Percentage of employees with disabilities by country and gender

Training and skills development

Training and development initiatives:

• The Group's commitment is to prioritize employee development and foster a positive, inclusive work environment that champions diversity and inclusion, leveraging on learning platforms such as the Cementir Academy.
• Since 2020, the comprehensive training offered by the Cementir Academy to Cementir Group employees has been extended to board members. Among the courses, offered in micro e-learning mode, are those on fraud management, whistleblowing, human rights, cybersecurity, GDPR (Data Protection Regulation (EU) 2016/679), Code of Ethics, 231 Models, Diversity Equity & Inclusion.
• Since 2024, to emphasise the Company's commitment to sustainability, the course list has been expanded with a course on ESG issues, aimed at deepening the current position and outlining the Group's ESG objectives.

Health and safety metrics

Coverage by health and safety management system

58% of people in the own workforce are covered by the Health and Safety Management System certified ISO 45001. All cement production plants (11/11) are ISO 45001 certified. The Group plans to certify all RMC plants by 2027.

Fatalities and work-related accidents

Notes:

• Fatality rate: (fatal injuries/hours worked) × 1,000,000
• LTIFR: (injuries with working days of absence/hours worked) × 1,000,000
• LTISR: (working days of absence/hours worked) × 1,000

In 2024, there were no fatalities among employees and contractors/subcontractors. One contractor fatality occurred in February 2025 at the Izmir plant; investigations are ongoing.

The number of recordable work-related accidents of employees in 2024 was 76. The number of recordable work-related accidents of non-employees was 37.

Days lost

The number of days lost to work-related injuries and fatalities from work-related accidents, work-related ill health and fatalities from ill health of employees was 877.5 in 2024.

Methodology

All Health & Safety indicators refer to employees unless otherwise noted. 100% of clinker production was monitored through Continuous Emission Monitoring Systems (CEMS) and discontinuous measurements. Health checks were more than 2,350 in 2024, conducted in compliance with health protocols defined by Occupational Physicians. No occupational illness allegations were received during the year.

Work-life balance metrics

Cementir is committed to supporting its employees in their parenthood journey.

Family-related leave entitlements and uptake (2024)

Methodology notes:

The percentage of employees entitled to parental and/or carers' leave is calculated based on those who, according to national law, collective agreements, or local policies, are eligible for leave due to the birth of a child.

The percentage of employees who took parental and/or carers' leave is determined by the number of employees who took at least one day of leave in 2024, divided by the total number of entitled employees.

As of 2024, 97% of women working in the Group had the right to take time off work for the birth of a child; helping them to reconcile their career with growing family responsibilities.

Compensation metrics

Pay gap

The mean gender pay gap across the Group is -3.5% (calculated using the ESRS formula: ((Average Gross Hourly Level of Male Employees - Average Gross Hourly Level of Female Employees) / Average Gross Hourly Level of Male Employees)) × 100).

In 2024, the Group consolidated its approach by conducting a gender pay gap analysis covering the entire population of the Group (with the exclusion of Sweden). The data considered is updated to July 31, 2024, with no significant salary changes observed in the latter part of the year. The conversion rate applied is based on the above-mentioned date.

Important conditions related to the Cement industry that affect the analysis:

• There are more men than women (13% women vs men at Group level)
• Women are under-represented in the business department compared to the staff department (9% vs 43%)
• The single indicator used does not account for regional salary differences across the areas where the Group operates
• Different seniority can affect the results
• Unique KPI including BCs and WCs

The HR department conducted a deeper analysis by role, showing that men and women are paid the same salary for equivalent levels of work when the presence of the less represented gender is statistically significant.

Remuneration ratio

In 2024, the ratio between the annual total remuneration of the most paid employee and the median of all other employee's annual total remuneration was 107:1.

Total Annual Remuneration includes Base Annual Gross Salary, Variable Incentives (Sales incentives, short- and long-term variable plans), Profit Sharing, other variable cash payment. Variable incentives are considered as Actual paid during the reference year, taking into account pro-rata calculation linked to the effective presence in the company. For the specific calculation of the total remuneration, the effect of IAS29 is excluded from the personnel cost.

Historical pay ratios:

Methodology

The average remuneration of each employee is EUR 68,711, which represents the total cost of EUR 211,768.4 thousand for the total 3,082 employees.

The gender pay gap calculation covers the entire Group population (excluding Sweden) with data as of July 31, 2024. The unadjusted figure uses the ESRS S3 Equal Opportunities formula based on average gross hourly levels.

The internal pay ratio compares the remuneration of the sole Executive Director (Group Chairman and CEO) with the average remuneration of personnel of all levels operating throughout the Group. The Cementir Group has offices across the world, and geographical location has a strong impact on remuneration rules and measures.

Incidents, complaints and severe human rights impacts

In 2024 no work-related incidents of discrimination - on the grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms of discrimination involving internal and/or external stakeholders across operations- have been found.

S1-17 Metrics

Additional Context

The company states: "If no such incidents have occurred, the undertaking shall state this" - confirming zero severe human rights incidents in 2024.

All concerns raised are assessed and investigated by the Internal Audit Department within the timeframe provided by applicable directives. The company ensures protection of whistleblowers from retaliation and discrimination as stated in the Supplier Code of Conduct.

Business conduct policies and corporate culture

Purpose, Vision, Mission and Values:

Our purpose is to build with ambition a sustainable future for generations to come.

Our vision is to be a driving force in shaping a sustainable future for the building industry, delivering tangible value through innovation and agility.

Our Mission is to generate value for our stakeholders through a sustainable growth path, achieved by focusing on product leadership, the pursuit of excellence and operating efficiency. We want to contribute to the development of essential infrastructure and to a more sustainable building industry, minimizing our environmental footprint, promoting circular economy principles, and actively working towards a carbon-neutral future.

Core Values:

• SUSTAINABILITY: We are committed to environmentally responsible practices and strive to minimize our impact on the planet.
• DYNAMISM: We embrace change and are constantly seeking ways to improve and innovate.
• QUALITY: We are dedicated to providing high-quality products and services that meet the highest industry standards.
• VALUE OF PEOPLE: We believe that our people are our greatest asset. We are dedicated to respecting human rights, promoting equal opportunities, and fostering their health, safety, well-being, development, and growth.
• DIVERSITY AND INCLUSION: We value and celebrate the unique perspectives and contributions of all our stakeholder (employees, customers, local communities, unions, etc.).

Governance and Ethics:

• The Board approved the policy for the regulation of lobbying activities and political contribution, the Audit Manual and the Internal Audit Charter, and updated the procedure for handling and disseminating inside information and the Internal Dealing Code.
• Our motto "Concretely Dynamic" embodies our dedication to delivering tangible results and our commitment to innovation and adaptability.
• Social responsibility: the Group emphasizes ethical business practices, workplace safety and positive engagement with local communities.

Incidents of corruption or bribery

Confirmed incidents

Cementir reported zero confirmed incidents of corruption or bribery during the 2024 reporting period.

Convictions and legal decisions

The company reported:

• 0 convictions for violation of anti-corruption and anti-bribery laws in 2024
• 0 fines for violation of anti-corruption and anti-bribery laws in 2024

Disciplinary actions

Cementir reported:

• 0 confirmed incidents in which own workers were dismissed or disciplined for corruption or bribery-related incidents in 2024

Contracts terminated

Cementir reported:

• 0 confirmed incidents relating to contracts with business partners that were terminated or not renewed due to violations related to corruption or bribery in 2024

Multi-year data

Investigation procedures and speak-up mechanisms

Cementir has established a comprehensive whistleblowing system in place since 2013, which has been continuously updated. The company recognizes its importance as an effective tool to prevent illicit activities and uphold individuals' freedom of expression as a fundamental human right.

Reporting channels available:

• Online form on the company's official website
• Email to a specified address
• Postal mail to a designated address
• Dedicated hotline

The Internal Audit Department of Cementir Holding is responsible for managing the whistleblowing process across all companies within the Group. The department ensures that all reports are handled in compliance with international standards and the company's Code of Ethics. The company guarantees that the identity of the whistleblower will not be disclosed without explicit consent.

Ethics Committee oversight: The Board of Directors established an Ethics Committee that:

• Monitors dissemination of the Code of Ethics
• Verifies violations
• Follows up on any reports of infringements
• Receives periodic information reports on whistleblowing

Whistleblowing activity in 2024: In 2024, 15 alleged violations were reported and investigated through the whistleblowing system:

• 5 claims were confirmed (leading to disciplinary actions, organizational changes, and operational improvements)
• 4 claims were dismissed due to insufficient information
• 1 claim was not confirmed after investigation
• 5 claims remain under analysis as of March 2024

Note: None of the confirmed violations in 2024 related to corruption or bribery. The confirmed cases involved misuse of industrial fuel, Code of Ethics violations related to purchasing procedures, and non-adherence to Group reporting procedures.

Public legal cases

An administrative dispute is pending before the Court of Appeal in Türkiye, brought by Çimentaş AS (indirect subsidiary). The dispute relates to an order by the Turkish Capital Market Board requiring payment of approximately 100 million Turkish lira (around €3 million) related to alleged hidden profit distribution. A judgment dated 6 September 2023 ordered Cementir Holding to pay approximately 1 million Turkish lira. Both Cementir Holding and CMB appealed the decision. The company notes there is no other significant litigation or significant instances of non-compliance pending.

Anti-corruption compliance program

Cementir has established a comprehensive anti-corruption policy and compliance program since 2015, including:

• Written policy defining roles, responsibilities, operating methods and behavioral rules
• Compliance program covering the UK Bribery Act
• Procedures regulating gifts and hospitality
• Assessment of corruption risk
• Due diligence for third parties
• Training and education plans

Training coverage in 2024: Cementir provided anti-corruption training to at-risk functions during 2024, covering:

• 16 of 17 Head of Region/BU Managing Directors
• 8 of 8 Group Chief Officers
• 137 of 175 Sales, Marketing & Business Development personnel
• 129 of 147 Supply Chain personnel
• 175 of 279 White Collar employees at risk

Training topics included: definition of corruption, company policy, and procedures on suspicion/detection.

Political influence and lobbying activities

Political engagement approach

On 29 July 2024, the Company's Board of Directors approved the Group Policy on Lobbying Activities and Political Contributions.

The aim of the Policy is to provide the principles and guidelines that the Cementir Group must observe when dealing with public authorities, with any type of direct or indirect communication, in order to:

• pursue the interests of the Cementir Group with the aim of influencing the process of political deliberation and decision-making;
• inform public debate and/or assist public authorities in their decision-making processes on issues of relevance to the Group;
• determine the terms and conditions of any financial contributions to political parties, causes or activities (collectively, "Advocacy Activities").

All activities are conducted to ensure that Advocacy Activities take place in a clear, transparent and lawful manner, in light of the disclosure requirements of the CSRD and ESRS standards and in compliance with local laws, internal procedures and Group culture.

Ethical standards and guidelines

The Policy applies to all Cementir Group companies and to all Group employees whether they operate directly or indirectly through third parties, respecting fair information, the rights and freedom of expression of stakeholders and the rules of fair competition and management of conflicts of interest.

Conduct that may constitute bribery and corruption acts in any form is expressly prohibited.

All Advocacy Activities, with the sole exception of memberships in Chambers of Commerce or industry organisations, are subject to prior approval and must be informed by the principles of transparency and integrity in compliance with laws, policies and procedures of the Group.

Political contributions

The Company remains politically neutral and abstains from donations to political entities, except those expressly approved if and to the extent permitted by local laws.

Trade association memberships

Cementir is a member of several industry associations:

Global Cement and Concrete Association (GCCA)

• Cementir participates in specific working groups arranged by the GCCA for the development of sector guidelines concerning the definition of a net zero roadmap, the management of health and safety and ESG reporting.

European Cement Research Academy (ECRA)

• The ECRA's most important research projects are related to carbon capture and storage (CCS) technology.

CEMBUREAU (European Cement Association)

• The Group is a member of CEMBUREAU, through which it is directly involved in dedicated working groups that are participating in advocacy regarding new legislation, as well as providing feedback to the EU Commission concerning the EU Taxonomy, CSRD (Corporate Sustainability Reporting Directive) and with the aim of supporting the sustainability agenda of the cement industry.

In CEMBUREAU, Cementir participates in the following bodies:

• Board
• Climate & Energy
• Resources and Processes
• Health & Safety
• Markets and Products

Danish Climate Partnership

• Since November 2019, through the Danish subsidiary, Aalborg Portland, the Group has been involved in the most ambitious CO₂ reduction project ever sponsored by a national government. In autumn 2019, the Danish government made a broad political agreement with all political parties, including one at the parliamentary level, on a binding climate law with the target of reducing Danish CO₂ emissions by 70% by 2030 compared with the 1990 baseline.
• The Chief Commercial Officer of Aalborg Portland is leading the climate partnership for Danish energy-intensive industry. The working group will provide the Danish government with a technical forecast of all potentially achievable CO₂ reductions and will define the prerequisites (policy, research, innovation, subsidies, etc.) for such reductions.

Lobbying expenditure

No specific lobbying expenditure amounts are disclosed.

Focus areas

Advocacy topics include:

• Net zero roadmap development
• Health and safety management
• ESG reporting
• Carbon capture and storage (CCS) technology
• New EU legislation (EU Taxonomy, CSRD)
• Sustainability agenda of the cement industry
• CO₂ emission reduction targets and climate policy

Materiality assessment

According to the ESRS disclosure index (page 195), G1-5 Political influence and lobbying activities is classified as "Not material" for Cementir Holding.

Payment practices

G1-6 Payment practices is assessed as not material by Cementir Holding.

No metrics disclosed for:

• Average time to pay invoices
• Standard contractual payment terms
• Number or value of legal proceedings for late payment
• Compliance with prompt payment code