Cementir Holding

Governance roles

Reference: pages 128-131 (also page 267 for the G1 cross-reference). The ESRS reference table (pages 150-154) lists GOV-1 at pages 128-131, with the board gender diversity datapoint (paragraph 21(d)) at page 129 and the independence datapoint (paragraph 21(e)) at page 128, both flagged as derived from other EU legislation.

Cementir Holding N.V. applies a one-tier governance model under the Dutch Corporate Governance Code. The Board of Directors "is the top management body, which combines both management and supervisory functions" (page 128).

Composition at 31 December 2025 (page 128):

• 8 members: 1 Executive Director and 7 Non-Executive Directors
• 3 Non-Executive Directors are independent (37.5%)
• 4 women and 4 men (50% female representation)
• Appointed 20 April 2023, in office until the Shareholders' Meeting approving the 2025 financial statements

Committees: Audit Committee (3 members, all independent), Sustainability Committee, Remuneration and Nomination Committee (3 members, all independent) and Ethics Committee, which "monitors compliance with the Code of Ethics" (page 129).

Allocation of responsibility (page 130): the Board "takes the final decisions on IROs and approves the Long-Term Business Plan and Sustainability Statement". The Sustainability Committee "approves the IROs and uses the results of the Double Materiality Assessment (DMA) for their inclusion in the Sustainability Roadmap". The Group CFO "is the member of the Executive Management responsible for financial and non-financial disclosure and reporting".

Expertise: the Board Profile requires knowledge of industrial production, in particular cement and construction, and was strengthened to include sustainability and ESG expertise; one Director has specific ESG experience with a focus on social aspects (page 129).

Gap stated by the company: "there is no representation of employees or other workers in administrative, management or supervisory bodies" (page 129).

Information provided to and matters addressed by the governance bodies

Reference: pages 130-131.

The Sustainability Committee "deals specifically with the material IROs identified in the Double Materiality Assessment" and supports the Board in defining sustainability policies and strategic decisions on long-term value creation (page 130).

Reporting rhythm disclosed (page 130):

• Quarterly - "the administrative bodies are informed about the implementation of the due diligence and the effectiveness of the policies/objectives. Top management (CEO, COO) receives the major risk assessments."
• Committee meetings - the Audit Committee meets about 4 times a year (March, May, July and November); the Sustainability Committee "meets regularly about twice a year and, where necessary ... may also be called to meet more frequently".
• Annually - the Audit Committee examines the results of Enterprise Risk Management, mitigation actions and opportunities, which are also communicated to the entire Board.
• Ad-hoc - dedicated meetings in the event of specific risks or emergencies.
• External information - the administrative bodies are also informed through external performance evaluations and annual sustainability reports.

The Internal Control and Risk Management System "follows a top-down risk-based approach for the management of IRO" (page 130).

Limitation: the report does not list the specific sustainability matters addressed at each meeting during 2025, nor how the bodies considered trade-offs between IROs.

Sustainability performance in incentive schemes

Reference: page 131 and page 155 (the E1 chapter repeats GOV-3).

ESG objectives are embedded in the Short Term Incentive (STI) programme "for all Executives and Middle Management across the Group, fully integrated into the performance management process" (page 131). Focus areas named are reduction of CO2 emissions, Green CapEx, circularity, reduction of the clinker factor, water consumption, occupational health and safety, and human capital and development.

Quantified weighting (page 131): for all C-level employees, ESG targets including emission reduction and environmental and social performance "are mandatory in their STI programme, with an indicative weight between 15% - 20% of their variable remuneration, in view of the fact that the weight and composition of ESG targets may vary depending on the role and responsibilities of each".

The E1 chapter adds that "With specific reference to the KPIs related to Climate Change, and the related CO2, the KPIs have been set and linked to the same metrics used in the CSRD for CO2 equivalent emissions" (page 155). Targets relating to biodiversity, ISO certification, circularity, clinker reduction, human capital, development and water consumption were also set for 2025.

The Long-Term Incentive (LTI) plan runs three three-year cycles with performance targets for medium and long-term value creation (page 131).

Gap stated by the company (page 155): "With reference to the incentive systems, currently there are none for the members of the Board. The only recipient of an STI plan is the President and CEO. The STI plan for the President include specific ESG objective as part of its remuneration." The Group "will evaluate in the coming years the possibility of extending this incentive system to the Board as well". No percentage of total remuneration linked to climate considerations is given.

Statement on due diligence

Reference: page 131. The ESRS reference table lists both "GOV-4 Statement on due diligence paragraph 30" and "GOV-4 Statements on sustainability due diligence" at page 131.

The statement takes the form of the mapping table required by ESRS 2 GOV-4, "how and where the application of the main aspects and phases of the due diligence process is reflected in Cementir's Sustainability Statement" (page 131):

The DMA section adds that the assessment "is informed by the Group's human rights and environmental due diligence and includes targeted engagement with affected stakeholders (e.g., local communities around plants, workers in the value chain) and consultation with external experts" (page 133). Due diligence is also identified in the governance table as a Board responsibility: "Corporate conduct policies, including the Code of Conduct, are regularly reviewed and approved by the Board, integrating sustainability standards" (page 130).

Risk management and internal controls over sustainability reporting

Reference: pages 131-133.

The company discloses an absence of a dedicated control framework (page 131): "As of today, Cementir does not have an internal control system for nonfinancial reporting structured around a dedicated risk and control matrix. The internal control system is instead managed through operational processes and procedures aimed at controlling and verifying the data relevant for the nonfinancial statement."

In the environmental and social areas "the information relies on existing company controls, including the controls embedded in the Law 262/2005 matrix within the payroll cycle for financial reporting purposes". Environmental oversight is "ensured through compliance with regulatory obligations (e.g., emissions and ETS)". The Company "is also evaluating the implementation of a review of internal process controls, with the objective of strengthening the overall control environment and improving the quality of nonfinancial information" (pages 131-132).

Internal Audit (page 132): in March 2026 the Internal Audit Function "was formally assessed as being in full conformance with the Global Internal Audit Standards issued by the Institute of Internal Auditors (IIA)", supported by an external quality assurance process finalised in the same month. The annual audit plan ensures "coverage of all operations with a frequency of at least three years" and includes an ESG audit for "verification of the completeness and accuracy of sustainability KPIs", EHS audits against ISO 45001 and ISO 14001, Legislative Decree 231/2001 compliance, Law 262/05 testing and whistleblowing investigations.

ERM (pages 132-133): risks are scored as Inherent Risk Value = Impact x Probability, with impact taken as the highest of economic (quantitative), operational (qualitative) and reputational (qualitative) components. The digital risk management system rolled out in 2024 "by 2025 it was fully operational and correctly in use throughout the organisation".

Strategy, business model and value chain

Reference: pages 124-126, with the value chain diagram at page 126. The ESRS reference table lists SBM-1 three times at pages 124-126 (products/markets/customers, headcount by country, breakdown of revenue).

Cementir Holding N.V. is a multinational with its registered office in the Netherlands, listed on the Euronext STAR Milan segment, operating in building materials across "four main business lines: grey cement, white cement, ready-mixed concrete and aggregates" with over 3,000 employees (page 122). It is "the world leader in the niche white cement segment, the leading cement producer in Denmark and ready-mixed concrete producer in the Scandinavian area, the third producer in Belgium and among the leading international operators in Turkiye". Part of the Caltagirone Group since 1992.

Value chain (page 125):

• Upstream - raw materials from owned quarries and third-party suppliers, supported by contractors; main procurement categories are direct materials, energy, logistics and transport, "predominantly via maritime and road channels".
• Own operations - regional integrated platforms across cement, aggregates and concrete; white cement produced on five continents; recovery of industrial waste to produce alternative fuels.
• Downstream - industrial and B2B customers and the construction sector (residential, commercial, infrastructure); "retail sales are residual"; technical assistance, logistics and distribution directly or via third parties.

Country-by-country data (pages 148-149): 2,905 employees and EUR 1,578,241,560 of revenue from sales to third parties, with the largest country entries being Denmark (795 employees, EUR 409.3m), Turkiye (701, EUR 321.6m), Belgium (440, EUR 254.7m) and the USA (202, EUR 174.0m).

Phase-in taken (page 154): "ESRS 2 SBM1 - A breakdown of total revenue, as included in its financial statements, by significant ESRS sectors" is excluded under the Phase-in option, so the sector revenue split is not given.

Interests and views of stakeholders

Reference: pages 127-128, with topic-level repeats at pages 221 (S1), 254 (S2), 258-259 (S3) and 262 (S4).

The Group issued a Stakeholder Engagement Policy in 2023 in accordance with the Dutch Corporate Governance Code, which "establishes the guidelines for stakeholder engagement in all operational activities, ensuring that the administrative, management and control bodies are informed of stakeholder opinions regarding sustainability-related impacts" (page 127).

Link to the DMA (page 127): "Stakeholder opinions were a central element of Cementir's double materiality analysis". The process gathered the interests, opinions and rights of internal staff (S1), value chain workers (S2), impacted communities (S3), consumers and end users (S4) and "other key stakeholders such as investors and environmental experts".

The stakeholder table (page 127) pairs each category with its material topics, engagement tools and ESRS references, for example local communities (circular economy, climate change, waste and water management, human rights; direct meetings and official reports) and trade unions (human rights and industrial relations; European Councils, working groups and dedicated meetings).

Supplier engagement results for 2025 (pages 146-147): 179 suppliers invited to the CDP Supply Chain programme and 51 responses (28.5% response rate, against 31% in 2024). Of those responding on climate change, 89% (65 of 73) had implemented emission reduction initiatives and 58% (42 of 73) reported SBTi-validated objectives. On water security, 100% of responding suppliers had a risk assessment procedure and water management at C-suite level, and 85% reported withdrawal from water-stressed areas.

Limitation: the report does not state how stakeholder views changed the strategy or business model in 2025.

Material impacts, risks and opportunities and their interaction with strategy

Reference: page 163 per the ESRS reference table, with the full IRO register at pages 139-143 and topic-level SBM-3 sections at pages 163-166 (E1), 188-189 (E4), 221 (S1), 254-255 (S2), 258-259 (S3) and 262-263 (S4).

The IRO register (pages 139-143) lists 77 rows, each tagged with its type (negative or positive impact, actual or potential, risk, opportunity), time horizon (short term 1-3 years, medium term to 2030, long term to 2050) and value chain perimeter (upstream, own operations, downstream). Material standards are E1, E2, E3, E4, E5, S1, S2, S3, S4 and G1.

Newly formalised in 2025 (pages 163-164): two positive climate impacts. First, CCS - "Analyses show that up to 70% of process and combustion emissions at selected sites could be captured using CCS technologies", and the Aalborg Portland project "will capture, purify and liquefy around 95% of CO2 emissions using Air Liquide's Cryocap technology", avoiding approximately 1.4 million tonnes of CO2 per year from an expected start-up in 2030. Second, the low-carbon portfolio: FUTURECEM technology "enabling clinker substitution above 35% and up to 30% CO2 reduction in production compared with traditional Portland cement, with substitution levels up to 50% recognised under EN 1975" [EN 197-5 elsewhere in the report], plus D-carb supported by waste heat recovery.

Strategic consequence stated (page 165): "the Group, through research and development, is committed to producing solutions with a significantly reduced climate impact. Therefore, as of today, Cementir has no need to reconvert, or dispose of existing assets, nor to reorient the product and service portfolio to enhance the resilience of its strategy."

Financial effects: "It should be noted that, during 2025, there were no current financial effects" (page 139).

Process to identify and assess material IROs

Reference: page 133 per the ESRS reference table, with the method set out at pages 133-137 and topic-level IRO-1 sections at pages 166 (E1), 175 (E2), 180 (E3), 196 (E4), 201 (E5) and 267 (G1).

The DMA is conducted "in accordance with ESRS 1 (chapter 3) and ESRS 2 - IRO1, covering own operations and the upstream/downstream value chain". Methodologies, assumptions and disclosure thresholds "are approved and overseen by the Audit Committee and the Sustainability Committee, which also review updates at least annually and upon significant changes in the business context" (page 133).

Inputs (page 133): internally, Group strategy and sustainability targets, audit results, whistleblowing complaints and the ERM register. Externally, the SASB Materiality Finder and the MSCI ESG Industry Materiality Map for the cement sector, a regulatory review of the jurisdictions where the Group operates, megatrends from MSCI, Refinitiv and S&P Global, and a 2025 peer benchmarking exercise "against main peers along the entire value chain to surface new IROs, emerging trends, stakeholder expectations and international best practices".

Scoring and threshold (pages 134-137): severity of negative impacts is assessed on scale, scope and irremediability, with likelihood added for potential impacts; "for potential negative human rights impacts, severity takes precedence over likelihood". Severity is assessed "on an inherent basis (before controls)". A 1 (Low) to 5 (High) scale is used and "the Audit Committee and Sustainability Committee have set the materiality thresholds at 'medium'; therefore, impacts/risks with a 'medium' or higher score, and the associated ESRS topic, are considered material". Financial materiality is scored on magnitude (with "EBITDA based triggers among others") and likelihood over the three horizons, "performed using the Group's Enterprise Risk Management (ERM) framework" with scenario-based assessment and subject-matter expert input.

2025 changes disclosed (pages 135-136): for E2, "waterrelated pollution and impacts on living organisms and food resources were deemed nonmaterial for Cementir's activities and were removed from the perimeter"; E4 "is the area undergoing the most change", with a new TNFD-consistent classification of impacts; for E1 two opportunity categories not present in 2024 were formalised (CCS and low-carbon products); S2 introduced new risks on third-party accidents and child and forced labour in high-risk areas.

ESRS content index

Reference: pages 150-154. The statement prints a genuine "ESRS reference table": "In our Sustainability Statement, we have adhered to the Disclosure Requirements stipulated by ESRS as displayed below. The following content index illustrates the locations where the lists of Disclosure Requirements can be found. Some of these have been incorporated by reference" (page 150).

The table gives, for each ESRS code, the description, the page reference, any note and a flag for datapoints derived from other EU legislation. All page references in this file follow the report's own printed page numbers, which run two behind the PDF page numbers of the published file.

Covered by the index: BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2; E1-1 to E1-6 and E1-8; E2-1 to E2-4; E3-1 to E3-4; E4-1 to E4-5; E5-1 to E5-5; S1-1 to S1-17; S2-1 to S2-5; S3-1 to S3-5; S4-1 to S4-5; G1-1, G1-3, G1-4 and G1-5.

Not covered. A second table (page 154) states: "The following DRs have not been included because the Group has decided to omit the information for this year, as provided for in Annex C of ESRS 1, or because they are not relevant, in the opinion of Cementir":

Two defects in the index. First, the E2-5 row carries the description of E2-6 (anticipated financial effects), so the phase-in declared under the code E2-5 in fact covers E2-6; substances of concern are separately outside the material E2 sub-topics. Second, several page references are evidently mistyped: S1-6 is shown as "233-217", S1-7 as "227" and S1-8 as "228" (the actual sections sit at pages 233-237 and 237-238), and SBM-3 for S2 is shown as "254-235".

G1-2 and G1-6 appear nowhere in the index, consistent with the DMA finding that management of relationships with suppliers, including payment practices, is not a material G1 sub-topic (page 139).

Transition plan for climate change mitigation

Reference: pages 155-157, with the investment detail at page 162 and the net-zero pathway at pages 162-163.

Cementir presents its transition plan through the TCFD structure (governance, strategy, risk management, metrics and targets) and the Roadmap to 2030. In 2022 the Group commissioned S&P to run a gap assessment of its climate disclosures, in which "Cementir achieved a total score of 100% on the overall assessment" on TCFD metrics (page 156).

SBTi validation (page 144): in February 2024 the SBTi validated the 2030 and 2050 CO2 reduction targets as consistent with the 1.5C scenario, with official approval published on 29 February 2024. From a 2021 base year: gross Scope 1 and 2 down 29.33% per tonne of cement product by 2030 and 96.1% per tonne by 2050; Scope 3 purchased goods and services down 23.00% per tonne of clinker and cement purchased by 2030 and absolute Scope 3 down 90% by 2050; net zero across the value chain by 2050.

2025 progress against the Roadmap (page 157): "In 2025, emissions per tonne of grey cement were 610 kg, down 15% compared to 2020, while emissions per tonne of white cement were 868 kg, down 5% compared to 2020. The Roadmap for 2025 for grey was 607 kg and consequently aligned with the plan. With reference to white the target was set to 848 kg but due to market demand for cement with high clinker content the result has been higher instead of the plan (2%)." The combined factor was 668 against a roadmap value of 664.

2030 destination (page 157): the Aalborg CCS system will capture 1.4 million tonnes of CO2 per year, taking grey cement Scope 1 to 418 kg per tonne, "thus reaching an emissions level lower than those required by the European Taxonomy, and corresponding to a 42% reduction compared to 2020 levels"; white cement falls to 730 kg per tonne.

Levers (pages 158-159): clinker ratio to 69% grey and 80% white through supplementary cementitious materials, FUTURECEM and D-Carb; alternative fuels to 53% grey and 8% white; partial conversion from petcoke to natural gas in Denmark and Belgium with multi-fuel burners; energy recovery to district heating in Aalborg; renewable electricity through PPAs and on-site generation; ACCSION carbon capture.

Locked-in emissions (page 157): "With reference to potential 'locked-in' GHG emissions, it is specified that finished products do not have blocked emissions. In fact, 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."

Approval and embedding (page 157): "The climate change targets established by the Group have been deployed per single plant and year and were included in the 2026-2028 Industrial Plan approved by the Board of Directors of Cementir Holding on 12 February 2026."

Benchmark exclusion (page 157): "please note that Cementir is excluded from the EU Paris-aligned Benchmarks."

Confidentiality exemption (page 121): absolute 2030 gross Scope 1 and 2 emission targets are withheld under Articles 19a(3) and 29a(3) of Directive 2013/34/EU, as the data "may reveal commercially sensitive information relating to turnover and sales volumes, and will therefore only communicate the equivalent intensity of emissions".

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 (pages 163-166), the E1 TCFD subsection (pages 155-157) and the basis of preparation (pages 121-122), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification of risks (page 164). Physical variables are split into two categories: "Acute: related to the occurrence of extreme weather conditions such as cyclones, hurricanes or floods" and "Chronic: refers to gradual and long-term changes in climate patterns (e.g., sustained high temperatures) that can cause sea-level rises or chronic heat waves". Transition exposure covers "changes in the regulatory, technological, market and reputational context". The IRO register (pages 139-140) names specific transition risks including CBAM compliance cost, new regulations, failure of the CCS project (exposing the Group to "the loss of benefits on investments made (EUR 100 million)"), poor market alignment for low-carbon products, rising OPEX and CAPEX from stricter regulation and energy price exposure, and one adaptation risk (water stress and seasonal variation disrupting production).

Scope and methodology (page 164). "As part of our TCFD assessment, we have evaluated the exposure of our plants to physical risks ... The assessment was done for each of the Group's plants." Time horizons are short term 1-3 years linked to the Industrial Plan, medium term to 2030 and long term to 2050 (page 165). The Group notes that "the Group applies internal time horizons that differ from the ESRS reference definitions" (page 121).

Physical scenarios (page 165). Three IPCC RCP pathways, named with their temperature projections:

• RCP 8.5 - high climate change, "As likely as not to exceed 4C", business as usual with emissions at current rates
• RCP 4.5 - medium, "More likely than not to exceed 2C", emissions halved by 2080
• RCP 2.6 - low, "Not likely to exceed 2C", emissions halved by 2050

Transition scenarios (page 165). Carbon price scenarios drawn from OECD and IEA research, with prices per region and year, for example the high scenario at USD 131/tCO2 in the EU in 2030 and USD 207 in 2050, the moderate scenario at USD 98 and USD 207, and the low scenario at USD 41 and USD 66. Regional variants are given for the US, Asia, China, the Middle East and Turkiye. "For its assessment, the Group has used the moderate scenario" (page 164), defined in a footnote as "a midlevel risk situation, positioned between a bestcase (low-risk) and a worstcase (high-risk or extreme) scenario".

Findings against ESRS E1 paragraph 17. A high-emission physical scenario is named (RCP 8.5), satisfying 17(a)(i). No 1.5C-aligned transition scenario is named: the most ambitious carbon price scenario is described as sufficient "to reduce greenhouse gas emissions in line with the goal of limiting climate change to 2C by 2100", so 17(a)(ii) is not met. Temperature projections are given per physical scenario, satisfying 17(a)(iii) for those. Key assumptions are limited to carbon prices; public policy, macroeconomic, energy mix and technology assumptions are not set out separately. The date of the analysis is not stated beyond the 2022 TCFD assessment, and the report does not say whether the scenario work was refreshed in 2025.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (pages 163-166) and the E1 strategy section (pages 155-162), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A resilience analysis is claimed (page 165): "Cementir assesses the resilience of its climate strategy relating transition risks with different carbon price scenario based on research by the Organisation for Economic Cooperation and Development (hereinafter 'OECD') and the International Energy Agency (hereinafter 'IEA')", and "The scenario modelling approach has been adopted to test the sustainability strategy's resilience and for the identification of appropriate mitigation actions."

Result for the business model (page 165): "Moreover, the Group, through research and development, is committed to producing solutions with a significantly reduced climate impact. Therefore, as of today, Cementir has no need to reconvert, or dispose of existing assets, nor to reorient the product and service portfolio to enhance the resilience of its strategy." The Group also states that it has adopted "a framework that highlights physical and transition risks and opportunities and indicates the management responses for each of them".

How the response is informed (pages 162, 168): "To facilitate the transition to a low-emission economy, decisions on reduction targets and related investments are based on a detailed scenario analysis, in line with the targets for the cement sector" (page 162). The internal carbon price feeds CapEx evaluations, budget planning for the EU ETS plants in Denmark and Belgium, and risk management (pages 174-175).

Capacity to adapt (page 162). Named flexibility levers are the 2026-2028 plan of around EUR 77 million in sustainability projects, including wind turbines in Belgium, plant upgrades for FUTURECEM, the natural gas transition in Denmark and Belgium, more alternative fuels in Turkiye and their introduction in Malaysia and China, and feasibility studies for carbon capture in Belgium. The Industrial Plan 2026-2028 chart shows EUR 32 million of sustainability CapEx in 2026 out of EUR 128 million total, and EUR 77 million of EUR 386 million over 2026-2028.

Areas of uncertainty disclosed (page 162): the ACCSION investment of "approximately EUR 120 million for the three-year period starting from 2027" carries the caveat that "this investment plan is not actually included in the approved business plan as reported in the press release", and "The time distribution of these investments will also be defined according to the development of the CO2 transport and storage infrastructure network, which is the responsibility of third parties, public and private."

Limitations. No quantified financial resilience result is given, and the Group states that "during 2025, there were no current financial effects" (page 139). The Group frames the exercise as incremental: "As declared by the TCFD, the process of disclosing information on the risks and opportunities connected with climate change will be gradual and incremental from year to year" (page 165).

Policies related to climate change mitigation and adaptation

Reference: pages 167-168.

The policy instrument is the Group Environmental Policy, which "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" (page 167).

Three lines of action (pages 167-168):

• Energy efficiency - increase efficient energy use within an Energy Management System "compliant with the internationally recognised standard (i.e. ISO 50001)", promoting energy recovery and renewable sources.
• Alternative fuels and raw materials - increase alternative fuel use including low-carbon fuels and biomass, promote "a co-processing and circular approach to waste as a fuel", and use decarbonised or alternative raw materials "to minimise the usage of non-renewable resources".
• Product innovation and new technologies - increase production of lower carbon cements such as FUTURECEM and D-Carb, encourage greater use of cement-based demolition waste as a substitute for natural aggregates in ready-mixed concrete, and participate in the development of CCUS systems at the Group's "hard-to-abate" plants.

Adaptation coverage (page 168): the policy is said to address adaptation through product innovation and circular strategies, because reuse and recycling "help to mitigate the risks associated with resource scarcity and the need to adapt to new climatic conditions, such as the reduction in the availability of natural materials or the increase in production costs due to climate change".

"These lines of action guide the Group's strategy towards carbon neutrality by 2050, in line with the 1.5 C scenario defined in the Cement Sector Guidance of the SBTi" (page 168).

Certification status, with an internal inconsistency. Page 167 states "In the manufacture of cement, 9 out of 11 cement plants are certified ISO 14001. The Group aims at obtaining the mentioned certification for all cement plants by 2025." Page 177 states that with the 2025 certification of the Waco and York plants in the United States "All cement production sites are now ISO 14001 certified". Ready-mixed concrete coverage is about 25% of production, with a target of 100% by 2027.

Actions and resources in relation to climate change policies

Reference: page 168, with the action detail at pages 157-163 and the measure-by-measure table at page 169.

"Cementir has set targets for reducing GHG emissions in the short and long term consistent with a scientific path towards climate neutrality. The Group aims at significant reductions in Scope 1, 2 and 3 emissions through a combination of operational decarbonisation levers and the introduction of innovative technologies" (page 168).

CCS as the principal action (page 168): "The CCS programme, starting with the Aalborg Portland site, is a crucial enabler for achieving long-term goals. The project foresees the capture of about 95% of process and combustion emissions, equal to about 1.4 million tonnes of CO2 avoided per year by 2030." ACCSION received EUR 220 million from the EU Innovation Fund, runs 2025-2030 with Air Liquide as partner, and "aims to deliver 113% of GHG emissions avoidance over its first ten years of operations" (pages 162-163). By 2030 Aalborg Portland "aims to become Europe's first net-zero cement plant producing grey and white cement, leveraging on capturing and storing the biogenic CO2 fraction".

Actions taken during 2025:

• Pilot and research projects CASPER, CORT and ConsenCUS across capture, treatment, transport and storage (page 163)
• In March 2025 CCB signed an agreement with Fluxys "aimed at starting the study and engineering phase of the piping system from the plant to the various exit points in Belgium (Antwerp, Ghent and Zeebrugge)" (page 162)
• New PPAs with Engie and EtherEnergy for the Belgian subsidiary CCB, delivering 61,933 MWh of green electricity, about 5% of total electricity consumption (page 169)
• Guarantees of Origin purchased to cover all electricity consumption, as in 2024 (page 163)
• Energy recovery at Aalborg supplying district heating to about 20,000 households, annual potential 2 million GJ rising to 3 million with carbon capture, "an estimated saving per year of about 187,000 tonnes of CO2, calculated on the basis of avoided emissions from natural gas boilers (62.40 gCO2e/MJ, IPCC 2006)" (page 159)

Resourcing (page 162): around EUR 77 million of sustainability projects planned for 2026-2028, with EUR 16 million for ACCSION in 2026 and approximately EUR 120 million of net Group investment for the three years from 2027.

"Cementir's GHG targets are integrated into financial planning, investment decision-making processes and operational KPIs, and are supported by the transition plan described in E1-2" (page 168). Note that the report's internal cross-references here are mislabelled: it calls the transition plan "E1-2" and the mitigation targets "E1-3", whereas under the 2023 ESRS those codes are the policies and actions requirements.

Targets related to climate change mitigation and adaptation

Reference: pages 168-169, with the quantified target tables at pages 144 and 158.

GHG reduction targets (page 144), SBTi-validated in February 2024 against a 2021 base year:

• Gross Scope 1 and 2: down 29.33% per tonne of cement product by 2030, down 96.1% per tonne by 2050
• Scope 3 purchased goods and services: down 23.00% per tonne of clinker and cement purchased by 2030; absolute Scope 3 down 90% by 2050
• Net zero GHG emissions across the value chain by 2050

Intensity roadmap by product (page 158):

"Such targets have been deployed in every single plant and were included in the 2026-2028 Industrial Plan and in our employee short-term incentive system" (page 158).

Scope 3 intensity progress (page 160): CO2 per tonne of clinker and cement purchased fell from 873 kg in 2021 to 876 (2022), 836 (2023), 833 (2024) and 831 kg in 2025, against a 23% reduction target.

Decarbonisation measures table (page 169): ten measures, each with description, expected GHG contribution, timeline and 2025 status, including CCS at Aalborg ("Very high (transformative measure for net-zero path)", expected launch 2030, "Ongoing - engineering and permitting phase"), CCS scalability at Group sites ("High", 2030-2040, "Under evaluation"), FUTURECEM ("~30% less CO2 per tonne than OPC", continuous, "Commercially available; expanding"), waste heat recovery, alternative fuels, alternative raw materials, energy efficiency and electrification, renewable energy purchase, and logistics optimisation ("Low", 2025-2030, "In development").

Limitations. Absolute Scope 1 and 2 targets for 2030 are withheld under the confidentiality exemption (page 121), so only intensity targets are published. No adaptation target is set. The base year table required by AR 48 of E1-6 is also omitted as confidential.

Energy consumption and mix

Reference: pages 169-171.

"In 2025, cement plants used 9.7 million MWh of thermal energy, and 1.2 million MWh of electrical energy ... Ready-mixed concrete consumes, for example, about 1% of the total energy used by the Cementir Group, while others consume another 1%. In 2025, ready-mixed concrete production plants used 95,475 MWh" (page 169).

Group energy balance (page 170), MWh:

Fossil fuel detail for 2025 includes petroleum coke 4,856,961 MWh, coal 1,692,887, natural gas 528,843, diesel 218,546, combustible oil 135,608 and lignite 61,005, plus a fossil fraction of waste fuels of 908,457 MWh. The biogenic fraction of waste fuels was 1,489,107 MWh and biofuels 7,244 MWh.

High climate impact sector disclosure (page 171): the Group states "Cementir's sector is considered as high climate impact" and reports energy intensity of 0.0068 MWh per euro of net revenue in 2025 (0.0064 in 2024, 0.0065 in 2023), on net revenues of EUR 1,639,640,086.

Alternative fuels (page 171): "In 2025, 25% of the thermal energy needed in the cement production process has been generated from alternative fuels. The goal is to reach 35% globally; 53% of alternative fuels in the production of grey cement, and 8% for that of white cement by 2030."

Data defect to check. The disaggregated fossil-source table on page 171 repeats several 2023 values in the 2025 column (coal 2,253,054 MWh, natural gas 527,311 MWh, other fossil sources 1,045,146 MWh and purchased fossil electricity 1,161,691 MWh), which conflicts with the detailed balance on page 170 for the same items.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 171-174.

Footprint composition (page 172): Scope 1 accounts for 71% of the footprint, Scope 2 for 4% and Scope 3 for 25%. "In 2025, total CO2 emissions (direct and indirect) amounted to 9,987,354 tonnes from fossil sources, and 499,723 tonnes from biogenic sources. Emissions under the direct control of the Cementir Group, i.e. those of Scope 1, amounted to 7,103,019 tonnes. The share of biogenic emissions from Scope 1, not included in the 7,103,019 tonnes, amounts to 499,723 tonnes."

Group emissions, tonnes (page 172):

The 2024 market-based Scope 2 figure was restated: "it has to be noted that In the Annual Report 2024 the data disclosed was equal to 532,615 tons but with the consideration of the GoO the new data for 2024 is equal to 377,811 tons" (page 172).

Cement production (page 174): Scope 1 7,064,626 t, Scope 2 location based 399,992 t and market based 378,279 t; total location based 7,464,618 t and market based 7,442,905 t. Intensity: 610 kg CO2 per tonne of cementitious product for grey cement and 868 kg for white. Other activities (ready-mixed concrete, aggregates, precast, waste) contributed Scope 1 of 38,393 t and market-based Scope 2 of 11,720 t.

Intensity per net revenue (page 174): total location-based GHG 6.10 kgCO2eq per euro (5.81 in 2024, +5%) and market-based 6.09 (5.89 in 2024, +3%).

Scope 3 by category, 2025 (pages 172-173): purchased goods and services 1,169,496 tCO2e (47%); fuel and energy-related activities 901,873 (36%); downstream transportation 187,964 (8%); upstream transportation 156,709 (6%); capital goods 59,364 (2%); end-of-life treatment of sold products 14,031 (1%); business travel 4,447; waste 452. Employee commuting, upstream leased assets, processing of sold products, use of sold products and investments are reported as negligible; downstream leased assets and franchising as not applicable.

Method (page 171): for EU ETS plants "measured and certified values provided by accredited laboratories are used"; for others, plant-specific factors where reliable, otherwise IPCC and CSI Cement CO2 and Energy Protocol defaults. Scope 3 uses Ecoinvent 3.12 for 2025, 3.11 for 2024 and 3.10 for 2023, with CEDA 2025 spend-based factors for capital goods and business travel and BEIS/DEFRA 2025 for transport, fuels and waste. "Additionally, the Internal Audit Function periodically verifies the completeness and accuracy of CO2 calculations during Environmental, Social, and Governance (ESG) audits."

The auditor flagged this disclosure. PwC's emphasis of matter draws attention to the E1-6 subsection, which "identifies the quantitative metrics for the scope 1, 2 and 3 emissions that are subject to a high level of measurement uncertainty" (page 390 of the report).

Omissions and defects. The AR 48 table disaggregating total GHG emissions by Scope 1, 2 and significant Scope 3 against the base year and absolute targets is omitted as confidential (page 121). In the published text the rows for the ETS share of Scope 1 and for market-based Scope 2 by year do not align to their column headings, so those two figures cannot be read reliably from the Group table.

Internal carbon pricing

Reference: pages 174-175.

"Cementir Group (CH) has established an internal carbon pricing system to strengthen financial and strategic decision-making, particularly in relation to CO2 cost management and investment planning" (page 174).

How the price is set (page 174): "Each year, CH determines its internal carbon price through a structured evaluation process that considers multiple factors, including benchmarking against industry peers and technical analysis based on an adaptive expectations approach." The method incorporates "Historical price trends within the European Emission Trading System (ETS), ensuring alignment with observed market dynamics" and "Consensus projections from leading international forecasters, particularly Carbon Pulse, a globally recognised organisation specialising in carbon markets and sustainability".

Where it is applied (page 175):

• Investment decisions and sensitivity analysis - "Integrated into CapEx evaluations and strategic planning to assess the financial feasibility of projects that impact Scope 1 and Scope 2 absolute CO2 emissions, either through reduction measures or increased production capacity."
• Financial forecasting - "Incorporated into budget planning and cost projections, particularly for CH's plants in Denmark and Belgium, which are subject to the EU ETS."
• Risk management - "Used to measure, model, and manage financial and regulatory risks associated with both existing and potential government carbon pricing regimes."

The price itself is withheld. The basis of preparation records a disclosure exemption under ESRS 1 Section 7.7: "Domestic Carbon Price (DR E1-8 - Setting the domestic carbon price): The option to omit disclosure of the internal carbon price was exercised, as such information could reveal confidential business strategies" (page 121).

What is therefore missing: the carbon price level or range, the types and scope of carbon pricing schemes applied, the share of gross Scope 1, 2 and 3 emissions covered, and the consistency of the price with the carbon price used in financial statements. The external price scenarios used for transition risk are published separately under the climate scenario analysis (page 165) and should not be read as the internal price.

Policies related to pollution

Reference: pages 175-177.

The policy instrument is again the Group Environmental Policy, which "establishes the principles and commitments for responsible environmental management across all operations. While its scope is broader than pollution alone, it includes explicit commitments to mitigate pollutant emissions, manage waste and hazardous substances, reduce wastewater discharge, and minimize negative impacts on surrounding areas and communities" (page 175).

Scope (page 175): "The Policy applies to all operational activities of the Group and provides mandatory guidance to all operating companies. It must be integrated into each company's Environmental Management System (EMS) in alignment with ISO 14001, ensuring consistent application across sites and geographies."

Commitments listed (pages 175-176):

• Mitigation and monitoring of pollutant emissions "using Best Available Techniques (BAT) and maintaining effective systems for emission prevention and control"
• Minimising wastewater discharge, reducing water losses and improving water reuse and recycling
• Minimising hazardous waste generation and increasing recycling or recovery "wherever feasible under a circular-economy approach"
• Assessing and mitigating environmental impacts "including on land, biodiversity, and surrounding communities"
• Compliance with all applicable local, regional, national and international environmental laws
• Monitoring, reviewing and disclosing environmental performance "based on recognized international indicators"
• Promoting responsible practices among employees, suppliers and contractors through training

Governance (page 176): "The Policy is approved by Group Executive Management and is binding across all operating companies." Operating companies must integrate its principles into their EMS, implement the required controls and pursue continuous improvement.

Coverage against ESRS E2 sub-topics (page 176): the Group states the policy addresses "air pollutants (dust, NOx, SOx, VOCs)", "soil and land contamination risk" and "hazardous materials and waste management". Substances of concern, substances of very high concern and microplastics are not listed, consistent with the DMA outcome that only air and soil pollution are material E2 sub-topics (page 137).

Actions and resources related to pollution

Reference: pages 177-178, with the Anqing case study at page 176.

"Cementir has adopted an action plan for the management and mitigation of pollutants which consists, first and foremost, of a continuous control system for emissions into the atmosphere and a series of discontinuous measurements" (page 177).

Group guidelines "define the minimum requirements for the identification of the parameters to be monitored, the frequency of measurement, and the indicators that must be implemented by each operating company within its environmental management system ... The guidelines are applicable to all cement plants in the Group and focus on emissions from kiln stacks, the primary sources of emissions" (page 177).

Substances covered (page 177): dust, nitrogen oxides and sulphur oxides as the main emissions, plus total organic compounds including VOCs, chlorides (HCl) and gaseous fluorides (HF), ammonia, carbon monoxide, heavy metals such as mercury, cadmium and thallium, and polychlorinated dioxins and furans reported as toxicity equivalent.

Resourcing (page 177): "The financial resources allocated to the air emissions monitoring and mitigation plan are subject to periodic controls and include both Operating expenditure (OpEx) and capital expenditure (CapEx) for asset improvement. The financial resources are aligned with the Group's 2030 roadmap and are integrated into the ordinary management activities of individual organisations." No pollution-specific CapEx or OpEx total is given.

2025 actions (page 177-178): "a series of planned improvement interventions were initiated, and in some cases completed, especially in relation to the mitigation of dust and NOx emissions. The positive effects will be fully effective from 2026." Named sites are Aalborg (improved electrostatic precipitator performance on kiln 87 with attention to cooler fumes, installation of natural gas burners and related feed and control infrastructure), Anqing (new selective catalytic reduction unit) and Izmir (improved dust abatement efficiency).

One quantified action (page 176): at Anqing, China, a new SCR unit was made operational from the second half of 2025. "The process has a high denitrification efficiency (>90%) and ensures that the concentration of NOx in the exhaust gas is reduced to below 40 mg/Nm3 (authorised limit 50 mg/Nm3). The cost incurred in 2025 for this project exceeded EUR 1.5 million."

ISO 14001 completion (page 177): "In 2025, with the certification of the Waco and York plants in the United States, the Group completed its ISO 14001 certification programme for cement plants. All cement production sites are now ISO 14001 certified (as well as ISO 45001). By 2027, all ready-mixed concrete plants will also be certified. At present, ISO 14001 certification covers approximately 25% of these sites."

Several actions listed under E2-1 are drawn from the biodiversity and EMS programmes, which the company states "While primarily part of ESRS E4, these actions also limit pollution impacts on land" (page 176).

Targets related to pollution

Reference: page 178.

The company discloses that it has no pollutant reduction target. "It has to be highlighted that for the current reporting period, the Group has not set dedicated targets associated with specific pollutants reduction" (page 178).

What is set instead is compliance-based and certification-based:

• "The emission monitoring and control objectives for compliance with the authorised emission limits are coordinated by the Group HSE department, which is responsible for ensuring compliance with the Environmental Policy. As part of the overall Environmental Management System (EMS), the individual issues are addressed at the level of the management system for each production site."
• "By 2027, upon completion of the Group's voluntary programme, all concrete production plants will also be ISO 14001 certified. At the moment, this certification covers about 25% of these sites."
• "The Group monitors and communicates emissions from cement production in compliance with its own guidelines, which are consistent with relevant internationally recognised documents such as industry BAT and GCCA Sustainability guidelines."

The DMA summary at page 137 frames the E2 ambition in the same terms: "Monitoring and mitigation of non-GHG emissions (PM, NOx, SO2, NH3, HCl, HF, Hg, TOC, CO, Metals). Definition of site operational targets for compliance with legal limits." For soil: "Prevention of contamination through control practices in the management of hazardous substances and waste."

Reading of this disclosure. Site-level legal-limit compliance objectives are not measurable outcome-oriented targets in the ESRS sense, and the Group says as much. The absence of a pollution target is disclosed rather than concealed, which is the relevant compliance point, but a reader cannot track pollutant performance against any stated ambition. The 2025 absolute figures show dust up from 127,105 kg to 173,587 kg, SO2 up from 1,264,110 kg to 1,653,820 kg and HCl up from 23,625 kg to 46,958 kg year on year (page 179), with no target against which to judge them.

Pollution of air and soil

Reference: pages 178-179. The report titles this section "E2-4 - Pollution of air and soil", reflecting the DMA outcome that water pollution is not a material E2 sub-topic (page 135).

Abatement techniques (page 178): "The Group adopts appropriate techniques for the mitigation of emissions into the atmosphere according to BAT such as electrostatic precipitators and bag filters for dust, low-NOx burners and selective reduction systems, catalytic and non-catalytic, for NOx. The expansion of the use of fuels with lower sulphur content (e.g., natural gas, also of biogenic origin) is an integral part of the improvement roadmap, the results of which, in terms of emissions, are expected as early as 2026."

Monitoring coverage (page 178): "In 2025, 100% of clinker production was monitored by CEMS and through periodic sampling of all pollutants, with an increased frequency compared to 2024 at certain sites, such as in Egypt. 97% of the total clinker production was continuously monitored for dust, NOx, SO2 and CO." Methods follow EN, ISO and US EPA standards and EN ISO 14956 and EN 14181 for continuous measurement uncertainty.

E-PRTR datapoint (page 178): "The result of the year is that none of the Cementir plant emitted soil pollution that goes above the threshold set by the Annex II of Regulation (EC) No 166/2006 ... (European Pollutant Release and Transfer Register 'E-PRTR Regulation')." Soil controls are preventive: "regular inspections of equipment and containment areas, leak prevention programs, and timely maintenance interventions designed to avoid spills or accidental releases."

Air emissions from cement plants exceeding the Annex II threshold, 2025 (page 179): dust 173,587 kg; NOx 11,081,370 kg; SO2 1,653,820 kg; NH3 223,498 kg; HCl 46,958 kg; TOC (NMVOC) 104,615 kg; CO 11,665,835 kg; Hg 20 kg; PCDD/Fs 0.00022 kg TEQ; sum of Cd and Tl 140 kg; sum of Sb, As, Pb, Cr, Co, Cu, Mn, Ni and V 248 kg, against a conservatively applied total threshold of 100 kg.

Specific emissions, all cement plants (page 179): dust 33 g/t clinker (32 in 2024), NOx 1,405 g/t (1,390), SO2 234 g/t (189), TOC 33 g/t (32), Hg 0.007 g/t (0.005), PCDD/Fs 0.041 microgram TEQ/t (0.028), Cd and Tl 0.018 g/t (0.012).

IED scope and enforcement (page 178): plants within the Industrial Emissions Directive (2010/75/EU) and sector BAT are Aalborg (Denmark) and Gaurain (Belgium). "No sanctions and/or penalties relating to emissions into the atmosphere were received during the year."

Not disclosed: emissions to water and to soil in quantified form, and any microplastics datapoint, both outside the material sub-topics.

Policies related to water and marine resources

Reference: pages 180-182.

The policy instrument is the Group Water Policy, which "establishes the principles for the responsible use and management of water resources across all operations. It recognizes water as essential for communities, ecosystems, and industrial activities, and affirms the Group's responsibility to manage water sustainably" (page 180). It applies to all operational activities, with each operating company implementing it "as an integral part of its Environmental Management System".

Commitments (page 180):

• Responsible water management through EMS implementation and maintenance
• Integration of water supply considerations into risk and opportunity assessments for current and future operations
• Water efficiency practices, "including reduction of freshwater withdrawal, increased recycling/reuse, minimization of wastewater discharge, and use of alternative water sources"
• "Prioritization of freshwater efficiency at sites located in high waterstress areas, as defined by the WRI Aqueduct Water Risk Map"
• Setting measurable water-management targets aligned with the UN Sustainable Development Goals
• Monitoring and disclosure "using internationally recognized indicators (e.g., GRI Standards)"
• Compliance with all relevant legislation and Group rules, and cooperation with local communities and institutions

Governance (page 180): approved at Group Executive Management level and binding across operating companies, with the Group HSE function supporting implementation "through guidance, monitoring, and performance oversight".

Value chain reach (page 182): "The Supplier Code of Conduct requires partners to implement efficient water management practices, including: the minimisation of fresh water withdrawals; reduction of wastewater discharges; maximising water recycling/reuse."

A community water project (page 180): at Clypot and Gaurain in Belgium, quarry water is recovered and supplied to the public distribution network operated by Societe Wallonne des Eaux. "The total volume of water from the Clypot and Gaurain quarries, sent for drinking water treatment, was 2,117 thousand m3 (1,627 thousand m3 in 2024). The medium-term goal is to maximise these flows to about 4,000 thousand m3." The Group notes this reduces "the community's dependence on well water, particularly in the Gaurain and Clypot districts, which are areas of high water stress".

Dedicated policy datapoint. The ESRS reference table flags the "Dedicated policy paragraph 13" and "Water and marine resources paragraph 9" datapoints at pages 180-182. Marine resources are not a material sub-topic (page 137), so the policy content addresses water only.

Actions and resources related to water and marine resources

Reference: pages 182-183, with the supporting action list at page 181.

"Starting from areas subject to water scarcity, the Group regularly promotes a sustainable use of water in all its activities by committing to reduce water consumption through reuse/recycling (for example, by improving drainage systems and collecting rainwater to reuse at least part of it), minimising withdrawals and wastewater, reducing losses (for example, through periodic checks of underground water pipes and the state of pumps) and promoting management practices focused on efficiency" (page 182).

Action categories (page 181): water efficiency and conservation; risk-based actions in water-stressed areas, where "Operational sites located in high waterstress regions adopt strengthened efficiency measures based on WRI Aqueduct risk classification"; monitoring, measurement and reporting; target setting at operating company level; stakeholder engagement with communities, institutions and regulators; and compliance and governance actions verified through internal EMS audits.

Quarry water (page 182): "Where quarry dewatering activity is present, there is an interest in maximising the recovery of the extracted water. The pumped water is used for different purposes, such as washing the aggregates themselves. The use of water in quarries, often organised in a closed circuit to limit the volume of water pumped, is in most cases marginal with respect to the total volume of water available."

A 2025 example (pages 183-184): "in Brussels, Belgium, new tanks were built to collect and dry the rinsing sludge from the concrete mixers at the end of the day, as well as the residues from the settling tanks. The collected water is reused for new preparations, while the sludge is sent to waste treatment and recycling centres."

Certification (page 182): "In the cement sector, all plants are ISO 14001 certified. In ready-mixed concrete production, 25% of production sites are also ISO 14001 certified. The goal is to achieve certification of 100% of activities by 2027. The waste treatment site in Turkiye is also ISO 14001 certified."

Resourcing (page 182): "The financial resources allocated to the water resources management plan are subject to periodic controls and include both operating expenditure (OpEx) and capital expenditure (CapEx) for the improvement and maintenance of assets. The financial resources are aligned with the Group's 2030 roadmap." No water-specific monetary amount is disclosed.

Measurement gap the company states (page 182): "The maximisation of rainwater collection is largely achieved through adequate storage systems so that it can be used in the short term. For this reason, no precise monitoring of the total volumes of stored water is carried out." This is reflected in the metrics, where total stored water volume is reported as "nd" for all three years (page 184).

Targets related to water and marine resources

Reference: pages 182-183.

"Water risks related to climate change are periodically assessed using the World Resources Institute (WRI) - Aqueduct Water Risk Atlas. The risk levels for each cement plant and region are identified periodically and improvement actions are prioritised and planned. This process is conducted periodically in compliance with the Group's 2030 roadmap, which provides for a 30% reduction in water consumption in cement production, based on the values recorded in 2019. For plants in areas with high water stress, the planned reduction target is 25%" (page 182).

Progress against the targets (page 183), litres per tonne of cementitious product:

"In 2025, the specific water consumption in cement production was 356 litres/TCE (236 litres/TCE in areas of high water stress), which was aligned with the improvement roadmap" (page 182).

Sites in high and very high water stress (page 182), unchanged from 2024:

• Al Arish, Egypt - arid area with low water use (score 5)
• Izmir, Turkiye and Gaurain, Belgium - extremely high risk areas (score 4-5)
• Kars, Turkiye - high-risk area (score 3-4)

Kars Cimento left the Group on 1 December 2025 (page 188), which affects the comparability of the high water stress perimeter year on year.

Stakeholder input (page 182): "The targets were also set on the basis of input received from stakeholders such as shareholders, financial communities, local authorities and opinion leaders." The Group also notes that the high water stress plants "start from a specific consumption index significantly lower than the Group average".

Limitation. The targets are intensity-based and cover cement production only. There is no target for withdrawals, for discharge quality, for water reuse rates, or for the ready-mixed concrete and aggregates businesses, which together accounted for 24% of Group water consumption in 2025 (page 183).

Water consumption

Reference: pages 183-185.

Group water balance (page 184), thousand m3:

Consumption detail (page 184): total consumption 4,795,929 m3 (2024: 4,417,579); consumption in areas of high water stress 2,091,144 m3 (2024: 1,849,712); cement 1,165,221 m3, ready-mixed concrete 400,857 m3, aggregates 521,462 m3 and waste 3,604 m3; total recycled or reused water 3,630,645 m3 (2024: 3,708,388); total stored water volume "nd" for all years. Water intensity was 0.0029 m3 per million euro of net revenue (0.0026 in 2024).

By business (page 183): "In 2025, water consumption in cement production amounted to 3,640 thousand m3, about 76% of the Group's total water consumption. Water consumption in areas subject to high water stress represented 32% (31% in 2024) of total consumption. In addition, 32% (31% in 2024) of the water withdrawn was reused/recycled. 94% of the total water discharged from cement production consisted of freshwater", freshwater being defined as total dissolved solids at or below 1,000 mg/l. Ready-mixed concrete consumed 627 thousand m3 (13% of the Group total) with 64% of that in high water stress areas and 26% of withdrawals reused. Aggregates consumed 526 thousand m3 (11%), up "due to additional / new quarries activities (e.g Turkey)", with 12% of withdrawals reused against 14% in 2024.

Treatment and measurement (page 183): "the water from the production phases, before being discharged, is generally subjected to primary treatment on site (97% of the total water discharged in 2025)". Secondary biological treatment exists at some plants and at the Turkish waste treatment plant, which is also the only site with tertiary treatment. Flows are measured directly by meter, by calculation from pump flow rate and operating hours, or by estimation from nominal pump capacity. Discharge quality is monitored monthly in most cases using EN 872 or ISO 11923 for suspended solids, EN ISO 10523 for pH and EN 1899 or ISO 5815 for BOD.

Enforcement (page 184): "No sanctions and/or penalties related to water management were received during the year."

Separate water balances for cement and ready-mixed concrete, covering about 90% of Group consumption, are given at page 185.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Reference: pages 186-187.

The section is framed as the resilience analysis under the disclosure requirement rather than as a dated transition plan: "As part of the resilience analysis required under Disclosure Requirement E41, paragraph 13, the Group assessed the capacity of its strategy to remain robust in relation to the material impacts, risks and opportunities identified with respect to biodiversity and ecosystems. The analysis considers the main drivers of biodiversity loss - such as soil degradation, habitat loss, pollution, landuse change and resource exploitation - and evaluates the Group's ability to manage and mitigate these risks over the medium and long term" (page 186).

How resilience is said to be built (page 186):

• For direct exploitation and land-use change risks, "the Group strengthens its resilience by aligning extractive activities with ecological assessments, geological conditions and regulatory obligations. Environmental Impact Assessments (EIAs), biodiversity mapping initiatives and sitespecific monitoring programmes are used to minimise irreversible impacts and to ensure compliance with more stringent permitting processes."
• For reputational and stakeholder-perception risks, "the Group enhances transparent communication, promotes naturerelated initiatives and proactively engages with local communities, authorities and environmental organisations. This approach supports the maintenance of the social licence to operate."
• Opportunities named are access to green financing and sustainability-linked instruments, market positioning through nature and circular economy initiatives, and new environmental monitoring technologies that "improve risk detection capability, reduce operating costs and strengthen stakeholder relationships".

Raw material dependency (pages 186-187): limestone represents 60-70% of the composition of cement, with clay, sand or silica, iron ore and gypsum making up the rest. "Although these raw materials are available and widely distributed globally, their extraction can generate significant ecological pressures and therefore requires careful management, long-term planning and responsible land use."

Method adopted in 2025 (page 187): "After a first evaluation screening carried out in 2024, during 2025 Cementir defined a structured, repeatable methodological framework based on scientific evidence for the identification, evaluation and management of dependencies, impacts, risks and opportunities related to nature within the Group's operations. The process followed the recommendations of the Taskforce on Nature-related Financial Disclosures (TNFD)." It supports identification of nature-related exposures in extractive activities and strategic suppliers, prioritisation by site evidence, integration with ERM, TNFD-aligned reporting and continuous improvement. "This approach is inspired by the guidelines of the Kunming-Montreal Global Biodiversity Framework."

Limitation. No biodiversity transition plan with dated milestones, no alignment statement against the Kunming-Montreal global targets beyond inspiration, and no disclosure of whether and how the Group's business model is to change is provided. The Group does not state that it has set science-based nature targets; SBTN is referenced only as a methodology the forthcoming policy will follow (page 196).

Policies related to biodiversity and ecosystems

Reference: pages 196-197.

The policy was not yet approved at the reporting date. "The Group Biodiversity & Nature Protection Policy, which will be approved by the Group within March 2026, establishes Cementir's commitment to safeguarding, conserving, and restoring biodiversity across all extraction sites. It recognizes that quarrying activities can significantly influence local ecosystems and positions the Group as a temporary steward of the land, responsible for protecting nature throughout the lifecycle of its operations. The Policy defines a structured and sciencebased approach to biodiversity management aligned with TNFD and SBTN principles" (page 196). A "Group Policy for the Protection of Biodiversity and Nature" is also listed in the policy table at page 128.

Scope (page 196): "all extraction sites owned or directly managed by Cementir Group companies", forming part of each operating company's Environmental Management System.

Commitments (pages 196-197):

• Science-based nature stewardship - integration of TNFD and SBTN methodologies across the operational lifecycle
• Mitigation hierarchy - "Prioritizing avoidance, then minimization of impacts, followed by rehabilitation or ecological restoration to enhance longterm ecosystem resilience"
• Protection of sensitive ecosystems - "No development of new extraction projects in UNESCO World Heritage Sites or IUCN Category Ia-Ib protected areas; application of strict mitigation for operations near IUCN Category II and IV protected areas"
• Monitoring - "Annual monitoring of priority species, key habitats, and ecological indicators to evaluate conservation status and identify trends"
• Biodiversity Management Plans - site-specific BMPs and associated Rehabilitation Plans "for sites in areas of high biodiversity value"
• Governance - "Clear organizational roles, including HSE oversight and sitelevel Biodiversity Focal Points responsible for coordinating local activities"
• Stakeholder engagement - collaboration with scientific institutions, NGOs, communities and regulators

The company states the policy "covers all dimensions required by ESRS E4 2", listing protection and restoration of biodiversity, management of ecosystem impacts and dependencies, protection of sensitive areas, the monitoring framework, stakeholder engagement and biodiversity governance (page 197).

Datapoints flagged in the index. The ESRS reference table marks "Sustainable land / agriculture practices or policies paragraph 24 (b)" and "Sustainable oceans / seas practices or policies paragraph 24 (c)" at pages 196-197, both derived from other EU legislation. The policy text as printed addresses extraction sites and land; no oceans or seas practices are described.

Reading of this disclosure. A policy that "will be approved within March 2026" was not in force during the reporting period. The substantive 2025 activity sits in the guidelines and site plans described under E4-3 rather than in an approved Group policy.

Actions and resources related to biodiversity and ecosystems

Reference: pages 197-200.

Action programmes (page 197): implementation of a Rehabilitation Plan at all extraction sites; implementation of a Biodiversity Management Plan integrated with the RP, starting from monitoring activities; implementation of identified mitigation measures; and strengthening stakeholder involvement in all phases "ensuring long-term sustainability through partnerships, dedicated resources, and the involvement of key stakeholders".

Mitigation hierarchy (pages 197-198): avoid, minimise, rehabilitate or restore, then offset. "At present, the Group implements minimisation, prevention, rehabilitation and restoration actions for its own quarries. The offsetting measures, where considered, can only be implemented as the last level of action and will be subject to strict governance and verification activities in order to ensure effective alignment with the objectives of no net loss."

Resourcing, quantified (page 198): "The project conducted in 2025 affected the entire portfolio of extraction sites. Environmental assessments were carried out on site for the 9 quarries considered priority, supported by a budget of about EUR 90k. For 2026, the Group has planned a total CapEx budget of about EUR 300k dedicated to quarry rehabilitation interventions and initiatives in favour of biodiversity, habitat monitoring actions and environmental improvement projects at operational sites. These allocations represent an initial stage of investment in biodiversity monitoring, assessment and rehabilitation activities."

Site initiatives in 2025:

• Izmir, Turkiye (page 198): Cimentas manages extraction sites "with a total authorised area of 810 hectares, of which 128 are currently subject to operational activities". Rehabilitation proceeds in parallel with extraction, with periodic planting of native and site-appropriate species and an employee tree-planting campaign. "in 2025 two water basins were constructed within the raw material extraction areas to support the water needs of the local fauna."
• Belgium, CCB (page 199): work continued at the depleted Gaurain quarry, the active Clypot quarry and the future Barry quarry. Following the "Life in Quarries" programme, "CCB is still committed to the 15-year post-LIFE phase, maintaining the ecological measures introduced by the project and ensuring compliance with the derogations for protected species granted by the Belgian authorities." At Clypot, "conservation measures for the sand martin are a priority. The dedicated nesting wall, built in 2024, was continuously monitored in 2025 to ensure stable breeding conditions and mitigate erosion risks." Annual biodiversity reporting has continued since 2022.
• Aalborg, Denmark (page 199): Aalborg Portland "manages a total area of 1,200 hectares in the territory of Rordal. Of these, 190 hectares are dedicated to the cement works and the active gypsum quarry, while the remaining 1,010 hectares include lakes, wooded areas, meadows, salt flats, uncultivated land and agricultural areas/environments of high ecological value." In 2025 the quarry extension "was integrated into the update of the Regional Mining Plan of the Region of Northern Denmark", and the local community was involved through workshops held in 2024 and 2025.

Effectiveness checks (page 200): "the absence or minimisation of impacts is verified by: (i) periodic monitoring of sensitive species and habitats; (ii) control of environmental parameters (dust, noise, water); (iii) internal environmental audits; (iv) comparison with baseline from EIA."

Limitation. BMPs are in place at "key points of interest" rather than across the portfolio, and the Group does not report the number of sites with a BMP in force, the hectares rehabilitated in 2025, or any outcome metric for the restoration work.

Targets related to biodiversity and ecosystems

Reference: page 200, with the 2030 ambition summarised at page 137.

Short-term objectives (page 200):

• "Fully implement the biodiversity governance system that has identified specific roles, responsibilities and implementation timelines for the actions."
• "Monitor key parameters that influence biodiversity starting from prioritised areas. Activities include, depending on the context, censuses of critical species, analysis of habitat conditions, and use of standardised biodiversity indicators to ensure consistency and comparability of data."
• "Calculate the BV for the purpose of assessing the Net Impact for the species/habitats of the prioritised areas so that a science-based path can be defined in the identification of medium- to longterm objectives on a defined baseline."
• "Implement quarry rehabilitation plans, which currently cover 100% of the Group's extraction sites, in order to integrate specific actions on biodiversity."

2030 ambition as stated in the DMA summary (page 137): "Ensure the protection of biodiversity at all operational sites. Minimise the environmental impact through Rehabilitation Plans for all quarries. Implement Biodiversity Management Plans for quarries with high biodiversity value. Target 2030: Keep rehabilitation plans active 100% of quarries with Rehabilitation Plans. Biodiversity Management Plans implemented at all high-value sites."

The company states the limits of its own targets (page 200): "It has to be noted that the actual targets defined are only related to monitoring and implement the current action plans for quarries rehabilitation."

Reading of this disclosure. What is disclosed is a set of process objectives (governance implementation, monitoring, baseline calculation, plan coverage) rather than measurable ecological outcome targets. No baseline year, no quantified no-net-loss or net-gain commitment, and no deadline beyond 2030 for the rehabilitation and BMP coverage statements are given. The company is explicit that the science-based path is still to be defined once the biodiversity value baseline has been calculated, which places E4 targets a stage behind the SBTi-validated climate targets.

Impact metrics related to biodiversity and ecosystems change

Reference: page 200, with the underlying site assessment at pages 188-195.

The section itself is short: "As outlined in ESRS E4.16 i., ii., iii., the analysis performed aimed at assessing the current ecological status of the different areas where Cementir Group's sites are located", with a cross-reference to ESRS 2 SBM-3 (page 200).

The substance sits in the TNFD screening (pages 188-195). The report lists 38 Group quarries by country, company, site location and material extracted, covering Denmark, Sweden, Turkiye, Belgium, Egypt, Malaysia and China (page 188). For each quarry the TNFD LEAP approach was applied: Locate, Evaluate, Assess, Prepare (page 189).

Locate phase weighting (page 189): nature-related sensitivity (TNFD Score) 70% and strategic and operational relevance 30%. The TNFD Score combines four equally weighted criteria (pages 189-190): ecosystem integrity, importance of biodiversity, physical water risks and relevance of ecosystem services. "All indicators were converted to a comparable 1-5 scale, normalised according to min-max values to avoid distortions due to scale and aggregated (mean) for each criterion."

Tools and data sources (page 189): IBAT for protected areas, Key Biodiversity Areas and IUCN Red List species, used "considering a radius of 5 km" for proximity and "the information available at both 50 km and 5 km" for species; STAR reduction and restoration scores; WRI Aqueduct for water stress, groundwater depletion, flood and drought risk; the WWF Biodiversity Risk Filter; and ENCORE. EUNIS Habitats classification was used for ecosystem mapping (page 194).

Site-level findings reported (pages 194-195):

• Izmir, Turkiye - 1 KBA within 5 km and no protected areas; within 50 km, 56 vulnerable, 25 endangered and 16 critically endangered species. "The STARt value for the area is below the global median ... Based on the STARr assessment, one of the quarries exceeds the global median threshold."
• Clypot-Neufvilles, Belgium - "no protected area or KBA falls within 5 km"; within 50 km, 52 VU, 7 EN and 1 CR species; STAR scores do not exceed global sensitivity thresholds.
• Barry-Gaurain, Belgium - "3 protected areas identified within a 5 km radius"; within 50 km, 58 VU, 7 EN and 1 CR species; STAR scores below the thresholds.
• Aalborg, Denmark - "2 protected areas falling within 5 km"; within 50 km, 65 VU, 13 EN and 10 CR species; STAR scores below the thresholds.

Each site also lists the threatened species identified in its environmental impact assessment for targeted monitoring, for example the Greek tortoise at Izmir, the sand martin and brown dragonfly at Clypot, and the autumn gentian at Aalborg.

Limitation. The metrics are screening scores and species counts, not the quantified ESRS E4-5 datapoints: no hectares of land use or land use change, no number of sites in or near biodiversity-sensitive areas expressed against total sites, and no ecosystem extent or condition indicator with a baseline is published. The measurement uncertainty table also flags E4 biodiversity data as subject to a high level of uncertainty (page 122).

Policies related to resource use and circular economy

Reference: page 201.

"To manage the related impacts, risks and opportunities related to the use of resources and the circular economy, Cementir refers to its Environmental Policy (in particular in the area relating to Climate Change/ Fuels and alternative raw materials and Product Innovation, and waste management), which is applicable to all operational activities carried out within the Group. Each operating company is responsible for the implementation of the Group directives and guidelines, as an essential part of its own EMS" (page 201).

Commitments stated (page 201):

• "The Group aims to increase the use of alternative fuels, including low-carbon fuels such as biomass, while adopting a co-processing and reuse approach for waste."
• "To minimise the use of non-renewable resources, the Group is committed to using decarbonised and alternative raw materials. This includes a progressive reduction in the use of virgin resources and, at the same time, a corresponding increase in the use of secondary resources such as, for example, materials deriving from demolition activities."
• "In terms of waste management, the Group focuses on treatment activities in order to convert waste into fuel to be re-used. Minimising the production of hazardous waste as well as increasing recycling/reuse are key elements in the circular approach."

The related lines of the Environmental Policy under E1-2 add the encouragement of "greater use of cement-based demolition waste as substitutes for natural aggregates in ready-mixed concrete production, in line with our circular economy strategy" (page 168).

Material sub-topics covered (page 137). The DMA identifies three material E5 sub-topics: resource inflows including resource use, resource outflows related to products and services, and waste. The policy addresses all three, though it does so as a section of the wider Environmental Policy rather than as a dedicated circular economy policy. No separate circularity policy document is named, and the policy text does not set out circular design principles for products, take-back arrangements or end-of-life responsibility beyond the reuse of demolition materials.

Actions and resources related to resource use and circular economy

Reference: page 201, with the resource outflow examples at page 204.

"During 2025, in line with the 2030 roadmap, the rate of use of alternative fuels, including waste and biomass, was increased" (page 201). In 2025, 25% of the thermal energy needed in cement production came from alternative fuels, and 37% of grey cement fuel was alternative against 34% in 2024 (pages 158 and 171).

Co-processing (page 201): "Co-processing of waste in cement kilns is an environmentally established option, as well as an effective solution for materials that are at the end of their useful life. In this way, not only is the energy content of the waste recovered, but its mineral content is also recycled to produce high-value products. Co-processing involves a reduction in the use of raw materials and the consumption of fossil fuels ... Waste co-processing also makes it possible to prevent plastic pollution in the environment and to avoid environmentally unsustainable options such as, for example, landfill disposal."

The integrated waste-to-fuel loop, quantified (page 204): "an example of this is the integration between the Izmir cement plant and the Sureko waste treatment site in Turkiye. During 2025, some types of waste produced in Izmir (407 tonnes) were sent to Sureko for treatment. Together with the other waste collected in the region, Sureko has provided for their treatment and the production of RDF, which is used in the same cement plant in Izmir as an alternative fuel. In 2025, Sureko supplied Izmir with a total of 13,289 tonnes of RDF."

The Group operates Sureko as an industrial and municipal waste treatment plant producing derived fuels, noting that landfill storage of such waste "causes the release of methane, a greenhouse gas with a climate-changing potential 80/85 times greater than carbon dioxide over 20 years" (page 201).

Other circular actions: maximising the reuse of clinker kiln dust within the production cycle and minimising landfill disposal; reuse of cement-based demolition waste as a substitute for natural aggregates in ready-mixed concrete "even when favoured by local regulations"; separation and management of maintenance waste such as used oils and metal scrap according to local classification rules (page 204).

Resourcing (page 201): "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." No circular economy CapEx or OpEx amount is given.

Targets related to resource use and circular economy

Reference: pages 201-202, with the 2030 ambition at page 138.

What is targeted (page 201): "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)." Those are the alternative fuel targets of 53% for grey cement and 8% for white cement by 2030, against 37% and 2% in 2025, and a global goal of 35% of thermal energy from alternative fuels against 25% in 2025 (page 171).

What is not targeted, stated by the company (page 201): "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, but no target has been yet implemented."

The DMA summary at page 138 frames the 2030 ambition in the same open terms: "Increase the use of recycled materials and alternative fuels in all plants. Obtain a reduction in waste destined for landfill (target to be defined in the roadmap)."

Governance of the objective (page 201): "The previously defined processes have been integrated into the mission of the Technical Department and into the related job description; this department is responsible for ensuring compliance with the Group's Environmental Policy."

Reading of this disclosure. The alternative fuel targets are quantified, dated and plant-deployed, and they sit inside the SBTi-validated climate roadmap. Beyond fuels, the E5 target set is empty: there is no target for the share of secondary or recycled raw materials, for waste diverted from landfill, or for resource outflows and product circularity. That gap matters given the 2025 figures, where the renewable and secondary share of cement raw materials fell from 12% to 11% (page 202) and 118,625 tonnes of non-hazardous waste still went to landfill (page 205).

Resource inflows

Reference: pages 202-204.

Headline inflow metrics (page 202):

"The data reported in the table have been calculated using a mass balance determined by mass measurement devices" (page 202).

Cement raw materials (page 202): "In 2025, the cement production plants of the Cementir Group used a total of about 15.2 million tonnes of materials to produce cement, and the percentage of alternative raw materials was 11.2%." Non-renewable raw materials were 13,510,640 t and renewable 1,709,995 t, for a total of 15,220,635 t.

Named non-renewable inputs, 2025 (page 203): limestone 10,604,314 t, clay 899,331 t, marna 517,138 t, sand 469,776 t, gypsum 434,609 t, pozzolana 257,089 t, iron ore 145,002 t, other materials 106,634 t, calcium fluoride 58,231 t, admixtures 9,633 t and bauxite 8,884 t.

Named secondary and renewable inputs to cement, 2025 (page 203): fly ash 561,263 t, blast-furnace slag 304,932 t, excavated waste soil (clay) 299,426 t, recovered limestone 202,909 t, other materials 191,302 t, iron oxide 88,790 t and FGD gypsum 61,374 t.

Other businesses (page 203): "In 2025, Cementir Group plants for all the other activities different from cement production used a total of 9.5 million tonnes of raw materials, mainly in the ready-mixed business where there is high usage of sand, stone, and cement. The use of renewable raw materials amounts to approximately 80,000, which represents only 0.84%." Named inputs are stones 5,723,614 t, sand 2,341,858 t, cement 1,380,542 t, admixtures 16,305 t, steel fibre 6,657 t, basalt fibre 201 t, plastic macrofibre 54 t and colour pigment 65 t. The secondary materials used are fly ash 47,211 t, blast-furnace slag 26,103 t and microsilica 6,536 t (page 204).

Direction of travel (page 202): "it continues its commitment to reducing the use of non-renewable raw materials, promoting the use of alternative raw materials, so called because they do not originate from quarries but from other production processes." Against that, non-renewable cement raw materials rose from 13,014,088 t to 13,510,640 t while secondary inputs were broadly flat, so the secondary share fell from 12% to 11%.

Not disclosed: the sustainable sourcing certification scheme and cascading principle detail required where biological materials are used; the report simply records 0% of biological materials as sustainably sourced.

Resource outflows

Reference: pages 204-205.

Circular outflow practices (page 204): "The Group has continued to adopt waste management solutions that promote recycling/reuse according to an approach of environmental and economic circularity. For example, the increased use of raw materials and alternative fuels (e.g. Refuse Derived Fuel - RDF) in cement production is one of the key factors in reducing the overall environmental footprint."

Three named outflow loops:

• Izmir and Sureko, Turkiye - 407 tonnes of Izmir waste sent to Sureko in 2025, and 13,289 tonnes of RDF supplied back to the Izmir cement plant as alternative fuel
• Clinker kiln dust - "In cement production, where possible, the reuse of clinker kiln dust within the production cycle is maximised, minimising landfill disposal"
• Demolition waste - "In the production of ready-mixed concrete, even when favoured by local regulations, some cement-based demolition waste is reused as a substitute for natural aggregates for new preparations"

Outflow performance, 2025 (pages 204-205): "In 2025, 99.7% of the waste produced was classified as non-hazardous. 94% of the hazardous waste generated was sent for recovery and recycling operations (for example, electrical and electronic waste for the recovery of metals, waste used for the production of RDF). Overall, 63% of the total waste produced was allocated to these activities." Total waste produced was 342,013 tonnes, of which 216,083 tonnes were not intended for disposal.

Products. The low-carbon product portfolio is the principal product-side outflow disclosure, presented under E1 and SBM-3 rather than here: FUTURECEM with clinker substitution of 35-50% and about 30% lower CO2 than ordinary Portland cement, and D-Carb with a 10-20% lower carbon footprint than Aalborg White CEM I, produced with waste heat recovery (pages 159 and 163).

Not disclosed under E5-5. The ESRS product-side datapoints are absent: there is no disclosure of the expected durability of products relative to industry averages, no reparability, reusability or recyclability rates for products and packaging, and no rate of recyclable content in products or packaging. The waste datapoints are recorded separately under the Waste entry in this dataset.

Enforcement (page 204): "No fines and/or penalties relating to waste management were received during the year."

Waste

Reference: pages 204-205. The ESRS reference table flags two derived datapoints here: "Non-recycled waste paragraph 37 (d)" and "Hazardous waste and radioactive waste paragraph 39", both at pages 204-205.

Waste produced, tonnes (page 205):

Treatment routes, 2025 (page 205): of hazardous waste diverted from disposal, 553 t went to recycling and 276 t to other recovery operations; of non-hazardous waste diverted, 214,437 t went to recycling and 816 t to other recovery. Of waste sent for disposal, 118,625 t of non-hazardous waste went to landfill, 7,202 t to other disposal operations and 47 t to incineration; hazardous disposal was 41 t to other operations, 15 t to landfill and none incinerated.

Composition and recovery (page 204): "In 2025, 99.7% of the waste produced was classified as non-hazardous. 94% of the hazardous waste generated was sent for recovery and recycling operations ... Overall, 63% of the total waste produced was allocated to these activities."

Sources (page 204): "In cement plants, the internal production of waste derives mainly from the periodic maintenance activities of machinery and equipment (e.g. used oils and metal scrap), as well as from the activities of warehouses and offices. Waste is properly separated and managed according to its classification, in accordance with local regulations."

Measurement basis (page 205): "The values reported in the table derive from the measurements of the quantities reported in the waste registers of each site."

Enforcement (page 204): "No fines and/or penalties relating to waste management were received during the year."

Two gaps. The index flags a radioactive waste datapoint at pages 204-205, but no radioactive waste figure appears in the tables; the split shown is hazardous against non-hazardous only. And there is no waste target: the Group states that "no target has been yet implemented" for waste, with a landfill reduction target still "to be defined in the roadmap" (pages 138 and 201).

Policies related to own workforce

Reference: pages 223-226.

The policy set comprises the Group Employee Diversity, Equity and Inclusion (DEI) Policy published in November 2022, the Group Human Rights Policy, the Health and Safety Policy, the Code of Ethics and the Reporting (whistleblowing) Procedure (pages 128 and 223-226).

Human rights framework (page 224): the Human Rights Policy aligns the company with "The International Charter of the United Nations and the Universal Declaration of Human Rights", "The Fundamental Conventions of the International Labour Organisation (ILO) (e.g. on Forced Labour, Freedom of Association and Discrimination)" and "The UN Convention on the Rights of the Child", supporting adherence to the UN Global Compact and SDGs 8, 10 and 17. "Cementir requires its contractors, suppliers and business partners to adhere to the same Human Rights standards. Since 2020, an online training course on the Human Rights Policy has been available for employees."

DEI (pages 223-224): the policy "reinforces the commitment against discrimination based on race, gender, age, religion, sexual orientation, disability and other protected characteristics", with objectives covering talent, environment, equal opportunities and contribution to SDGs 5 and 10. Internal Audit "monitors key processes (hiring, pay, promotions) to ensure fairness and mitigates DEI risks globally (100% of the workforce covered in 2025)".

Workforce context (page 223): "The sector in which Cementir operates has historically had a strong male prevalence. In 2025, men accounted for about 86% of the workforce, a substantially stable share compared to 2024. This composition mainly reflects the high presence of 'blue-collar' operating profiles."

Women in management, 2025 (page 224): 417 women in the total workforce; 58 women in all management positions; 27 in managerial positions in revenue-generating functions; 72 in STEM positions.

Health and safety (pages 224-226): "all cement production sites are certified ISO 9001 and ISO 45001, ensuring a management system to prevent accidents and occupational diseases". The Group HSE department sets guidelines, key rules and management standards on a systemic approach "as required by the ISO 45001 standard", and a global H&S network of site and business managers "met 11 times" during 2025. Each site and business unit has a Health and Safety Committee chaired by its senior manager with line managers, the area health and safety manager and workers' representatives.

Grievance route (page 224): "a reporting and whistleblowing mechanism (also accessible to third parties) is established to report potential violations of the Human Rights Policy and the DEI, ensuring the absence of retaliation. The Internal Audit Function investigates confirmed complaints, sets corrective actions and monitors their implementation."

Not stated: whether the policies explicitly address trafficking in human beings, forced labour and child labour as separate commitments in the ESRS paragraph 22 sense is asserted rather than evidenced by quotation from the policy text itself.

Processes for engaging with own workforce and workers' representatives

Reference: pages 226-228, with related content at pages 238 and 240.

Group workforce survey (page 226): "every two years the Company carries out a survey of its employees called 'Your Voice'. The purpose of this survey is to evaluate the involvement and the level of employee satisfaction within the organisation, and to compare the results with previous ones and any further market benchmarks." A communication plan covered pre-survey, in-survey and post-survey phases. "The feedback collection process took place between May and June 2024, and reached an overall participation rate of 92%." Action plans were defined and implemented at local and global level in 2024 and 2025 across four areas: communication and collaboration, people growth, respect and mutual recognition, and efficiency and innovation. "The Group is committed to launching a new staff survey in 2026."

Because the survey runs on a two-year cycle, no new survey was run in 2025; the engagement evidence for the year is the action-plan implementation.

Workers' representatives (page 228): "The Cementir Group maintains a structured and ongoing dialogue with European workers' representatives, in accordance with EU regulations, local regulations and the framework defined by the Group's European Works Council (EWC). During the year, management informed and consulted employees and trade unions on transnational issues concerning the status of activities and significant decisions relating to business and workers."

One dated engagement (page 228): "In September 2025, at the plant in Aalborg (Denmark), the management shared the main economic and financial results of the period and the ongoing strategic initiatives with a particular focus on activities related to sustainability issues, including the Carbon Capture project in Denmark and the Kiln 4 investment in Belgium, in addition to the outcomes and challenges in the field of Health and Safety."

Other channels: talent review and succession planning conducted in 2025 with results shared with the Remuneration and Nomination Committee (page 227); non-remunerative benefits reported by eligibility, including insurance at 100% of employees, pension fund 96%, meal and canteen 77% and company car 12% (page 228); and site-level Health and Safety Committees with workers' representative participation (page 226).

Not stated: which senior person holds operational responsibility for engagement with the own workforce, and how the Group assesses the effectiveness of engagement, are not identified.

Processes to remediate negative impacts and channels to raise concerns

Reference: pages 229-230. The ESRS reference table flags the "Grievance/complaints handling mechanisms paragraph 32 (c)" datapoint here.

Whistleblowing channel (page 229): "Cementir uses the Whistleblowing Procedure as its main complaint mechanism, allowing all stakeholders (employees, collaborators, directors and third parties) to report, without fear of retaliation, potential violations, non-compliance or illegal activities."

• Channel - "the whistleblowing channel has been active since 2013 and is promoted both internally and externally"
• Scope - conduct, including omissions, not complying with laws, regulations or the Group's system of rules including the Code of Ethics
• Management - "The Internal Audit Function is responsible for receiving, analysing and investigating reports, ensuring the confidentiality of the identity of the whistleblower"
• Remediation - "the Internal Audit Function, together with Human Resources, defines and monitors remediation plans to mitigate any negative impacts, directly supporting the company's workers"
• Training - knowledge of the procedure is introduced at onboarding, with mandatory training for new hires

"The Group Reporting Management Procedure was revised at the end of 2024 to align with the new applicable regulations; the updated version is in force from the beginning of 2025" (page 229).

Awareness testing, 2025 (page 229): "In December 2025, the Internal Audit Function launched the second awareness survey of the Code of Ethics, the Human Rights Policy, and the Diversity, Equity and Inclusion (DE&I) Policy. Coverage: the survey involved employees with accounts, covering 79% of Cementir's workforce. Target: check the level of knowledge of employees regarding the Code of Ethics, the DE&I Policy, the Human Rights Policy and the whistleblowing system. Response rate: the response rate was above 20%. Actions: all the results were discussed with Top Management and, on the basis of these, an action plan was defined to monitor sensitive areas. The results have been integrated into the Human Rights Audit Report to align Management Action Plans at the regional level."

Reading of this disclosure. The channel and its ownership are described clearly. Two things a reader should weigh: the awareness survey reached only employees with accounts, so 21% of the workforce was outside its scope, and a response rate reported as "above 20%" is a weak basis for concluding that the workforce trusts the channel. The Group does not report whether it tracks whether workers are aware of and trust the structures, which is the ESRS datapoint.

Taking action on material impacts on own workforce

Reference: pages 230-231.

Framework (page 230): action is routed through the Enterprise Risk Management process and the Internal Audit Function. "The ERM process is a company-wide tool designed to identify, analyse and monitor environmental, social, economic/financial and ethical risks within all Group activities ... The Internal Audit Function regularly conducts audits on social aspects such as Human Rights, working conditions, HSE, and diversity and inclusion, in support of management strategies."

Human rights audit, 2025 (page 230): "since 2019 Cementir's Internal Audit Function has integrated a specific Human Rights checklist into its standard audit process."

• Scope - "audits verify compliance in areas such as Child Labour, Forced Labour, Non-Discrimination, Conditions of Employment, Safety and Supply Chain Management"
• Geographical coverage - "the activities were carried out in 13 countries (Belgium, Denmark, Norway, Turkiye, the United States, China, Malaysia, Egypt, Italy, Poland, France, Australia and Iceland)"
• Workforce coverage - "the audit covered 100% of Cementir's workforce"
• Result - "The analyses carried out in 2025 confirmed that all the Group's operations are in line with internationally recognised Human Rights and that, during the audit activities, no risks or critical issues were identified."

DEI self-assessment (page 231): running since 2022 across hiring processes, remuneration levels, annual reviews of salaries and promotions, work-life balance agreements and events to foster interest in technical careers among women. "In 2025, the activity continued and has been carried out in all the Group's companies, covering the 100% of Cementir's workforce at worldwide level", with an exception noted for the AB Sydsten joint venture, "for which Cementir is not in charge of the operating activities". No risks were identified.

Safety actions in 2025:

• A common H&S platform was implemented "to manage key health and safety processes via the web and specific apps", covering incidents, inspections, audits and resulting actions, with a work permit control system added at year end and full capacity targeted from the cement plants in 2026 (page 229)
• "In April 2025, the Group celebrated Health and Safety at Work Week", with attention to work at height, confined spaces and lifting operations, and to decommissioning, isolation procedures and work permits (page 230)

Turnover (page 231): "The overall staff turnover rate increased to 17% in 2025, up from 14% in 2024. This increase is attributable to the disposal of the activities of the Kars Cement plant in Turkiye (3%). The company undertakes to conduct annual analyses to understand the main causes of exit and to implement mitigation strategies."

Point for a reader. The audit conclusion that no risks or critical issues were identified sits alongside two workplace fatalities in 2025 (page 245) and 13 whistleblowing reports of which four were confirmed or partially confirmed (page 268). The scopes differ, but the report does not reconcile them.

Targets related to own workforce

Reference: pages 231-233.

The Group sets out its objectives in three groups (pages 231-232). Objectives to reduce negative impacts: secure employment and stable working conditions; well-being and work-life balance; occupational health and safety "with a particular focus on the typical risks of the sector: silica exposure, quarrying operations, use of heavy machinery"; elimination of all forms of discrimination; accessibility of workplaces, "progressively removing the physical and organisational barriers present on its sites"; protection of human rights against child and forced labour; and improvement of hygiene conditions and WASH services. Objectives to enhance positive impacts: social dialogue and industrial relations through the EWC and local committees; skills development through the Cementir Academy; promoting diversity, equity and inclusion; preventing harassment and violence at work; and enhancing existing WASH infrastructure. Risk and opportunity objectives: safety as a strategic and cultural value; DE&I as a lever for talent attraction; workforce readiness for technological and sustainability change; internal climate and employee engagement; work-life balance as a retention factor; and management of WASH-related health risks.

The one quantified target set, DEI (page 233):

Governance of targets (pages 232-233): "Health and safety objectives are defined considering past performance, risk profile and alignment with Cementir's strategic initiatives"; the Board "establishes medium/long-term objectives, with annual review, applicable to the Board of Directors, senior management and, if extended, to specific clusters or to all employees"; Group HR "defines action plans, monitors progress and communicates them to the Board of Directors".

Verification limit stated (page 233): "The measurement of employee characteristics has not been validated by an external body other than the assurance service provider."

Reading of this disclosure. Outside DEI, the objectives listed are directional statements without a metric, a baseline or a deadline. The "zero accident" strategy referenced at page 138 as a 2030 target is the only safety ambition given, and it is not expressed as a measurable interim target. Whether workers or their representatives were involved in setting the targets is not stated.

Characteristics of the undertaking's employees

Reference: pages 233-237. The index prints this reference as "233-217", evidently a typographical error.

Headcount (page 233): "The staff of the Cementir Group in 2025 consists of 3,028 employees, 95 fewer than in 2024 (considering 100% of the staff of Societe des Carrieres du Tournaisis SA), who are distributed across 15 countries and 5 continents." The countries counted are Denmark, Norway, Sweden, Poland, Iceland, France, Belgium, United States, Turkiye, Egypt, Malaysia, Australia, China, United Arab Emirates and Italy.

By gender (page 234): 2,610 men and 418 women in 2025, against 2,712 men and 411 women in 2024.

By contract type (page 236): permanent 2,811 (2,451 men, 360 women) and fixed-term or temporary 217 (159 men, 58 women). Non-guaranteed-hours employees are reported as nil for every country in both years.

By category (page 237):

"As of 2025, Cementir has introduced a new staff classification, subdividing the categories of Executives, Managers, Employees and Workers on the basis of the level of the position held (pay grade)" (page 237), which affects comparability with 2024.

Countries with at least 50 employees representing at least 10% of the total (page 234): Belgium 481 (2024: 480), Turkiye 701 (2024: 805) and Denmark 795 (2024: 794).

Turnover (page 236): "509 employees left the Company during 2025, and the turnover rate was 17%." The report notes that the Group "avails of temporary labour in order to meet the unexpected increases in production volumes as well as to compensate the absence of labour during annual leaves or in cases of sickness leaves. Therefore, the temporary employees have to be detracted from the amounts of incoming and outgoing employees for understanding the actual flows."

Data notes. The Belgian headcount composition shifted markedly between years, with permanent employees rising from 364 to 460 and fixed-term falling from 116 to 21, which the report does not explain. A country breakdown line labelled "others/unknow" is marked "cannot be disclosed due country regulation (privacy)" (page 234). The country-by-country tax table reports a different employee total of 2,905 on its own basis (page 149).

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

Reference: page 237. The index prints this reference as "227", evidently a typographical error.

"The workforce of the Cementir Group comprises 855 employees. Cementir uses contractors mainly for the execution of operations within the quarries, and for packaging operations within the cement plants" (page 237). The figure of 855 is the total of the non-employee table for 2025, against 988 in 2024.

Non-employees by type and region, 2025 (page 237):

Scope of "own workforce" (page 221): the Group states that employees, "People provided by third party undertakings primarily engaged in employment activities" and non-employees are within scope, while self-employed people are not. It notes that "employees provided by a third party, primarily engaged to carry out activities for Cementir in the extraction phase such as Mining and Quarrying, could be subject" to material impacts.

Movements worth checking. Quarry contractors in Turkiye fell from 238 in 2024 to zero in 2025, and packing activity contractors there fell from 65 to 62 while the "Other" category fell from 190 to 180. Egypt's "Other" category rose from 272 to 347. The Kars Cimento disposal on 1 December 2025 (page 188) is a plausible explanation for part of the Turkish movement, but the report does not link them.

Limitations. The disclosure gives headcount by category and region only. There is no breakdown by gender, no methodology statement for how the numbers were compiled, and the report does not say whether the figures are headcount at 31 December or full-time equivalents.

Collective bargaining coverage and social dialogue

Reference: page 238, with the country map at page 228. The index prints this reference as "228", which is the map rather than the metrics.

Group coverage (page 238): "In 2025, approximately 61% of the employees of the entire Group were covered by collective agreements in line with those in force for the previous year. This percentage varies from country to country depending on the applicable local legislation and on the job classification categories."

Countries with significant employment (page 238):

Outside the EEA (page 238): employees with a collective bargaining agreement fell from 378 of 805 (47%) in 2024 to 318 of 701 (45%) in 2025, reflecting Turkiye.

Workplace representation (page 228): the country map shows workplace representation in the EEA at 80-100% for Denmark and Belgium; the same map places collective bargaining coverage at 60-79% for Denmark, 80-100% for Belgium and 40-59% for Turkiye.

Social dialogue (page 228): "Employees not covered by collective agreements are in any case protected through the application of the minimum wages established by local legislation and, where applicable, by the respective national agreements. This approach is fully compliant with Directive (EU) 2022/2041 of the European Parliament and of the Council of 19 October 2022, which aims to ensure adequate minimum wages in the European Union and to promote collective bargaining. In addition, the systematic use of external salary benchmarks is a fundamental tool to ensure salary alignment."

The European Works Council is the transnational forum, and "Industrial Relations also have an active role in the Company's commitment in terms of health and safety, characterised by active participation on the part of the union and workers" (page 238).

Presentation issue. The Belgian table reports 506 employees represented out of 506 total, against a country headcount of 481 in the employee table (page 234). The two figures are on different bases and the report does not reconcile them.

Diversity metrics

Reference: pages 239-240.

Gender distribution at top management (page 239):

The Group defines top management by region: "Nordic and Baltic countries CEO+CFO; Belgium CEO + secondments; North America CEO + Managing Director; Turkiye CEO + local chairman; Asia Pacific CEO + Managing Director + secondments; Head Quarter all managers, pursuant to the National Collective Bargaining Agreement; Egypt CEO" (page 239).

Board and committees at 31 December 2025 (page 239):

Every member of every body is in the "Over 50" age band in 2025; the 30-50 band, which held three Board members in 2023, has been empty since 2024.

Age distribution of employees (page 240):

The over-50 group is the only band to grow in absolute terms, rising from 37.4% to 39.3% of the workforce, while the under-30 group fell from 12.3% to 11.4%. The report does not comment on this ageing profile or link it to the succession planning described at page 227.

Related figures elsewhere: women held 58 of the management positions, 27 managerial roles in revenue-generating functions and 72 STEM roles in 2025 (page 224), and women were 20.6% of the senior management team at 31 December 2025 against a target of increasing by one percentage point from 19% at May 2022 (page 233).

Limitation. The disclosure covers gender at top management and Board level and age across all employees. It does not present the gender distribution at every management level, which is the ESRS S1-9 datapoint, and the top management definition is company-specific rather than the ESRS definition of the two highest levels of management.

Adequate wages

Reference: page 240.

"The Cementir Group guarantees staff a remuneration package adequate to the breadth, complexity and strategic nature of the role, anchoring the values to the local reference market" (page 240).

The datapoint (page 240): "In 2025, no employee of the group received an 'inadequate' salary in any area / region where the group operates." The Group adds that "The standard salary paid to new hires in the first year is higher than the minimum required by law and equal pay is guaranteed without differences based on gender."

How pay is set (page 240):

• External benchmark - "an external provider is used for the selection and analysis of benchmark remuneration data, ensuring remuneration competitiveness on the labour market"
• Review frequency - "the remuneration parameters are updated annually. In the event of high inflation, a more frequent review may be considered to mitigate the impact on purchasing power"
• Wage increase variables - pay equity with respect to the local market, individual performance rate, country inflation and available budgets
• Process - "the salary review process is managed by the local Human Resources Department, in line with local timelines and specificities, in accordance with the guidelines of the Group Remuneration and Benefits Function"
• Loyalty plan - "the Group adopts a retention plan based on the overall macroeconomic scenario and national wage benchmarks, with regular updates to address market risks"

The Group cross-refers to the collective bargaining section, where it states that employees outside collective agreements are protected by statutory minimum wages and, where applicable, national agreements, in line with Directive (EU) 2022/2041 on adequate minimum wages (page 228).

Limitation. ESRS S1-10 asks whether all employees are paid an adequate wage in line with applicable benchmarks and, where not, the countries and percentage concerned. Cementir answers in the affirmative but names no benchmark against which "adequate" was tested, beyond statutory minima and an unnamed commercial salary survey. The report also does not state the lowest wage against the applicable minimum wage by country.

Social protection

Reference: page 240.

The disclosure is a single statement covering the whole workforce:

"At Group level, all employees in all countries are protected against loss of income resulting from significant life events such as, for example, illness, accidents at work that have caused personal injury, parental leave, and retirement."

This is a nil-gap return: the Group asserts full coverage of its employees against the major life events named in ESRS S1-11, so no country or category is reported as lacking protection.

Supporting evidence elsewhere in the statement. The non-remunerative benefits table (page 228) reports the share of employees eligible for each benefit type in 2025: insurance including health, life and injury insurance 100% (unchanged from 2024); pension fund 96% (94% in 2024); meal and canteen 77% (90%); other benefits 54% (60%); company car 12% (11%); fuel support 7% (9%); housing allowance 4% (5%). "Different packages are provided depending on the particularities of each country where the Group operates, taking into account different local customs, social needs, and legal requirements" (page 227).

Parental and carers' leave entitlement is quantified separately under work-life balance metrics: 97% of both men and women were entitled to parental leave in 2025, and 63% of men and 74% of women to carers' leave (page 251).

Limitations. The four events named are sickness, work-related injury, parental leave and retirement. Unemployment starting from own work, and disability, are not addressed, although both fall within the ESRS S1-11 list. The statement does not distinguish protection provided through public programmes from protection provided through Group benefits, and no country-level or category-level breakdown is given, so the assertion cannot be tested against the benefits table, where pension fund eligibility is 96% rather than 100%.

Persons with disabilities

Reference: page 240.

The Group reports that it cannot give a total (page 240): "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 organisation. For the countries not present in the table, the data cannot be disclosed/collected due for legal reasons."

Percentage of employees with disabilities by country and gender (page 240):

Six countries are reported, covering China, Malaysia, Australia, Egypt, Turkiye and Italy. Denmark, Belgium, Norway, Sweden, Poland, Iceland, France, the United States and the United Arab Emirates are absent, and between them those countries hold the majority of Group employees, including Denmark at 795 and Belgium at 481 (page 234).

Related commitment (page 232): among its own-workforce objectives the Group states that "The Group is committed to progressively removing the physical and organisational barriers present on its sites, ensuring increasingly inclusive work environments that are attentive to the needs of people with disabilities." The DEI policy names disability among the protected characteristics (page 224).

Reading of this disclosure. ESRS S1-12 requires the percentage of employees with disabilities subject to legal restrictions on data collection, and Cementir has given exactly that for the countries where it says collection is permitted. The stated legal barrier is plausible for special-category data in several jurisdictions, but the report offers no country-level explanation, so a reader cannot tell which restriction applies where. No Group-level percentage and no absolute number are available for FY2025.

Training and skills development metrics

Reference: pages 241-243.

Performance reviews (page 241): "In the 2025 Annual Group Performance Management process each employee received two performance reviews; the same number of reviews have been received last year and consequently in line with the previous year. The Annual Group Performance Management Process covered the 67.6% of the total employees." The process "involves all executives, managers and white-collar employees that were hired within the first half of the year".

Review coverage by category, 2025 (page 241): executives 100% of men and 100% of women; managers 98% and 96%; white-collars 93% and 92%; blue-collars 48% and 89%. The gap for male blue-collar employees, unchanged from 2024, is the main driver of the 67.6% Group figure.

Training hours (page 242): "In 2025, 76,268 hours of training were delivered, more than 25 hours for each employee", against 73,494 hours in 2024. By gender, 66,603 hours for men and 9,666 for women. By category: executives 527 hours, managers 9,939, white-collars 22,802 and blue-collars 43,000.

Training hours by category, 2025 (page 243):

Health and safety training accounts for "over 44% of total Group training hours" (page 246).

Programmes (page 241): the LinkedIn Learning partnership was confirmed, with courses in seven languages open to all white-collar employees; "The second edition of the training and development programme for young emerging talents called 'NextGen Development Program' has been completed, and the first edition of the management programme called 'Group Management Acceleration Program (GMAP)' is underway." Local programmes include the Graduate Programme in Turkiye, launched in 2024 and concluded in 2025, and leadership programmes in Denmark, Turkiye and Belgium.

Mandatory online training for new hires (pages 241-242): Code of Ethics, cybersecurity modules on deepfakes, ransomware and spear phishing, diversity equity and inclusion, fraud management, reporting system, GDPR, human rights, leadership model, performance management, inside information, and environment social and governance. A new course on Artificial Intelligence was delivered in 2025 with the IT department.

Limitation. Training hours are reported by gender and category but average hours per employee are given only as a Group figure of more than 25, not disaggregated by gender or category as ESRS S1-13 requires.

Health and safety metrics

Reference: pages 244-250. The ESRS reference table flags the fatalities and work-related accident datapoints (paragraph 88 (b) and (c)) and days lost (paragraph 88 (e)) as derived from other EU legislation.

Two fatalities in 2025 (page 245): "In 2025, the Group recorded a significant reduction in accident rates compared to previous years. This positive trend has, however, been overshadowed by two tragic fatalities: the first involved an employee at the Izmir plant in Turkiye and the second a contractor at the Ipoh plant in Malaysia, both during maintenance activities. The internal investigations have ascertained that, in each case, the accidents were caused by serious violations of company procedures before the start of work. Adequate targeted corrective actions and preventive actions have been implemented, with a strong focus on work control/supervision processes, procedural rigour and the reinforcement of safe behaviours."

Key metrics (pages 247-250):

"Compared to 2024, the Group's total frequency index (employees and contractors/subcontractors) decreased by 22%, with a corresponding impact also in terms of severity. The index of total recordable injuries also improved by 18%. The main causes of injury were slips, trips and falls (42% of the total), mostly relating to the behaviour of individuals" (page 245).

Coverage (page 245): "As of 31 December 2025, 63% of the people in the Group workforce carried out their activities at ISO 45001 certified sites/businesses. In 2024, where the perimeter also included the certified plant in Kars - now no longer part of the Group - it was 58%."

Health surveillance (page 245): "Over 2,000 health checks were carried out during the year, substantially in line with the relevant site plans. No declarations have been received from employees in force regarding the onset of occupational diseases that can be linked to the Group's activities."

Training and WASH (page 246): specific health and safety training reached 33,332 hours in 2025, "an increase of 8% compared to 2024". On water, sanitation and hygiene, "At the beginning of 2025, we exceeded the minimum level of compliance (90%) with WASH standards."

Reading of this disclosure. The metric set is unusually full, covering employees and on-site contractors separately and broken down by business line. The frequency and severity trends improved on every measure, but two people died at work, both during maintenance, and the company attributes both to procedural violations before work started. Near misses rose 37% year on year, which the Group presents as improved reporting rather than deterioration.

Work-life balance metrics

Reference: page 251. The index prints this reference as "251", matching the section.

Entitlement and take-up (page 251):

Method (page 251): "The percentage of employees entitled to parental and/or carers' leave is calculated considering all those who, on the basis of national regulations, collective agreements or local policies, may benefit from leave for the birth of a child. Similarly, the percentage of employees who took leave is determined by comparing the number of those who took at least one day of leave in 2025 to the total number of those entitled."

Commitment stated (page 251): "Cementir is committed to supporting its employees throughout the parenting journey, promoting a work environment that fosters a balance between professional life and family responsibilities. Also in 2025, 97% of the women in the Group were entitled to take the leave provided in the event of the birth of a child, as evidence of the company's commitment to ensuring adequate and inclusive protections."

Points a reader should weigh. Entitlement to carers' leave rose sharply year on year for both genders, from 45% to 63% for men and 59% to 74% for women, without explanation. More significantly, the return-to-work rate for women after parental leave fell from 77% to 67%, meaning roughly one in three women taking parental leave did not return, against 99% of men. The report reproduces the figure without comment, and the own-workforce objectives on work-life balance and retention (page 232) are not connected to it. The 3% of entitled employees who are not entitled to parental leave are not identified by country or category.

Remuneration metrics: pay gap and total remuneration

Reference: pages 251-253.

CEO pay ratio (page 251): "In 2025, the ratio between the annual total remuneration of the most paid employee and the median of all other employee's annual total remuneration was 98." Total annual remuneration "includes Base Annual Gross Salary, Variable Incentives (Sales incentives, short- and long-term variable plans), Profit Sharing, other variable cash payment", with variable incentives taken as actually paid during the year and pro-rated for presence, and "for the specific calculation of the total remuneration the effect of accounting for hyperinflation (IAS29) is excluded from the personnel cost".

Gender pay gap (page 252): "The mean gender pay gap across the Group is -2.02% considering the ESRS (ESRS S3 Equal Opportunities) formula: (((Average Gross Hourly Level of Male Employees - Average Gross Hourly Level of Female Employees)/ Average Gross Hourly Level of Male Employees))*100)." The 2024 comparative is -3.5%. A negative figure on this formula means average female hourly pay exceeded average male hourly pay.

Scope and basis (page 252): the analysis began as a 2023 pilot in Turkiye, was extended in 2024 to the whole Group except Sweden, and "For 2025, the Group consolidated this approach by conducting the analysis of the gender pay gap across the entire Group population. The data considered are updated as of 31 July 2025, as no significant salary changes were observed in the latter part of the year, due to the completion of the salary review process in that month, and also the conversion rate actually used is that of the aforementioned date."

Caveats the company sets out (page 252):

• "There are more men than women (13% women vs. men at Group level)"
• "Women are underrepresented in business roles compared to staff roles (9% vs. 42%)"
• "It should be noted that 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 analysis showed that, where the presence of the less represented gender is statistically significant, no significant deviations are found for the same role" (page 252).

External recognition (page 253): Cimentas in Turkiye obtained the Happy Work Place certificate and SWC in Egypt ranked seventh in the Best Place to Work in Egypt ranking, both based on employee surveys with an HR governance verification score above 70.

Two things to check. The report labels the pay gap formula as "ESRS S3 Equal Opportunities"; the datapoint sits in ESRS S1-16 and S3 covers affected communities, so the citation is wrong even though the formula reproduced is the standard one. And the report gives no reconciliation between the pay gap statement and the fact that women hold 4 of 40 executive positions (page 239), which the caveats acknowledge only in general terms.

Incidents, complaints and severe human rights impacts

Reference: page 254. The ESRS reference table flags the incidents of discrimination datapoint (paragraph 103 (a)) and the non-respect of UNGPs and OECD Guidelines datapoint (paragraph 104 (a)).

The disclosure is a set of nil returns (page 254): "In 2025 and 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."

Corroborating evidence in the statement. The 2025 human rights audit covered 100% of the workforce across 13 countries and reported that "no risks or critical issues were identified" (page 230), and the DEI self-assessment reached the same conclusion (page 231).

Two points a reader should weigh. First, the reported zero complaints sits alongside the business conduct disclosure that "In 2025, 13 reports of potential violations were recorded, four of which were confirmed or partially confirmed, resulting in the application of the necessary disciplinary measures and the initiation of corrective actions on the business processes involved", with the matter alleged recorded as "Non-adherence to Group procedures" and the countries of provenance as China, Denmark and Turkiye (page 268). The two disclosures use different scopes, discrimination and human rights here against business conduct there, and the report does not cross-reference them.

Second, the last row attributes the absence of fines to the internal audit rather than answering the datapoint, which asks for the monetary amount and its reconciliation to the financial statements. No reconciliation to a financial statement line is provided.

Policies related to value chain workers

Reference: pages 255-256. The ESRS reference table flags four derived datapoints here: human rights policy commitments (paragraph 17), policies related to value chain workers (paragraph 18), non-respect of the UNGPs and OECD Guidelines (paragraph 19) and due diligence policies on the fundamental ILO Conventions 1 to 8 (paragraph 19).

"Cementir Group integrates human rights and occupational health and safety (OH&S) into its sustainability strategy, in accordance with the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights and ILO Conventions. These commitments are formalised in the Group's Human Rights Policy, OH&S Policy, Code of Ethics and Supplier Code of Conduct, all publicly available on the Company's website" (page 255).

Scope of the commitment (page 255): "The Group ensures respect for human rights and workers' rights in all its operations and along the value chain, promoting freedom of association, collective bargaining and non-discrimination. The Human Rights Policy explicitly prohibits child labour, forced labour and any form of human rights abuse, applying to all workers, including contract and informal workers."

Occupational health and safety (page 255): "Occupational health and safety risks - such as exposure to silica dust and the use of heavy machinery - are addressed through a preventive culture, standardised procedures, and continuous improvement practices. The OH&S Policy provides a framework for accident prevention, employee training and the dissemination of best practices at production sites."

Supplier obligations (page 255): suppliers "are contractually required to comply with Cementir's standards regarding working conditions, health and safety, and human rights", covering risk assessment and mitigation, supply and training on the use of PPE, safe work environments, continuous improvement of performance, and compliance with national and international labour laws.

Monitoring (page 255): "Cementir regularly carries out audits, monitoring of reports (whistleblowing), and evaluations of suppliers based on social, environmental and ethical criteria. The Industrial Relations function monitors the potential negative impacts on workers along the value chain, ensuring responsible business conduct even beyond Tier 1 suppliers."

A new policy adopted in 2025 (page 256): "the Group took a significant step in strengthening its sustainability governance along the value chain, adopting the Group Sustainable Procurement Policy, a document that defines ESG principles, criteria and expectations for all Group suppliers. This Policy, approved by top management and applicable to all companies within the consolidated perimeter, represents a fundamental pillar for promoting responsible procurement practices."

Where the risk sits (page 254): "specific attention is paid to extraction and quarrying activities, which in some geographical areas present a higher intrinsic risk of violations of fundamental rights. In particular, operations located in China, Malaysia, Turkiye and Egypt are considered areas at significant risk of forced labour, both due to the nature of the processes and the regulatory and socio-economic context in which they operate."

Limitation. The report does not disclose whether the policies were developed with input from value chain workers, and it does not state whether the Group has identified any case of non-respect of the UNGPs or OECD Guidelines involving value chain workers beyond the nil return under S2-4.

Processes for engaging with value chain workers about impacts

Reference: page 256.

The company discloses that no such process exists (page 256): "Cementir does not currently have a structured approach to the engagement of supply chain workers, contractors or subcontractors. The Group is evaluating how to effectively engage these workers regarding impacts, also analysing the possibility of including them in the definition of objectives and in performance monitoring."

This is a stated gap, not an inference. It is the clearest engagement finding in the social section and should be read alongside the Group's own materiality conclusion that value chain workers face potential severe impacts from silica dust exposure, heavy machinery, temporary contracts in upstream quarrying and forced or child labour in high-risk geographies (page 255).

What the Group did instead in 2025 (page 256): it adopted the Group Sustainable Procurement Policy, "approved by top management and applicable to all companies within the consolidated perimeter", to define ESG principles, criteria and expectations for suppliers.

Planned next steps, with dates the company gives (page 256):

• "In continuity with this commitment, in 2026 Cementir will continue on the path of integrating the principles of the Policy into the operational processes, with a specific focus on strengthening the monitoring mechanisms in the contractual phase. In particular, the Group will work on the inclusion of sustainability clauses in contracts and general purchasing conditions."
• "together with the Purchasing Department, the Company will evaluate the implementation within the next 2 years of a sustainability self-assessment to be submitted to all new suppliers before signing the contract ... The self-assessment procedure will be introduced with the aim of requiring new suppliers of high value-added (HVA) raw materials and components to self-certify core sustainability performance requirements."

Indirect engagement that does exist. Suppliers are engaged on environmental matters through the CDP Supply Chain programme: 179 suppliers were invited in 2025 and 51 responded, a 28.5% response rate against 31% in 2024, with dedicated supplier training webinars held since 2020 (pages 146-147). That programme covers climate and water performance, not the working conditions of the suppliers' own workers, so it does not close the gap the company has identified.

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

Reference: pages 256-257.

Prevention framework (page 256): "Cementir has established a Group Policy for Occupational Health and Safety (OH&S) to prevent occupational accidents and diseases, in particular those related to exposure to silica dust and the use of heavy machinery." The policy promotes "The harmonisation of local health and safety initiatives", "Standardisation of procedures" and "Training, coaching and learning from incidents".

What suppliers must provide (page 256): the Supplier Code of Conduct requires suppliers to "Respect national, international and supranational laws", "Respect human rights, including collective bargaining and social dialogue", "Adopt grievance mechanisms that ensure confidentiality and protection against retaliation" and "Sign a clause relating to workers' rights and ethical conduct".

The Group channel (page 256): the Whistleblowing Management Procedure "Complies with EU Directive 1937/2019 and Legislative Decree 24/2023", "Provides a 24/7 active online whistleblowing channel for internal and external stakeholders, including workers in the value chain", "Allows anonymous reporting of violations related to laws, ethics, discrimination, equal opportunities, and ESG issues" and "Guarantees the protection and confidentiality of the whistleblower".

Handling (page 257): complaints are "Evaluated by the Internal Audit Function", "Checked with the relevant company departments" and "Followed by corrective action plans with defined deadlines". "The Internal Audit Function reports the statistics on complaints and the progress of corrective actions to the Top Management. Annual data on complaints (type, confirmation status, country) are disclosed in the Sustainability Statement."

Stated future improvements (page 257): "Cementir will issue a Sustainable Sourcing Policy and update the General Purchasing Conditions for: Including sustainability clauses. Strengthening awareness of grievance mechanisms among workers in the value chain. Promoting anonymous reporting and protection against retaliation."

Two things to weigh. The channel is available to value chain workers by design, but the Group states separately that it has no structured engagement with those workers (page 256) and that a future action is to strengthen their awareness of the grievance mechanisms, which implies awareness is currently not established. And the report does not disclose how many reports, if any, came from value chain workers in 2025; the only reporting statistics given are the 13 business conduct reports under G1-3 (page 268).

Taking action on material impacts on value chain workers

Reference: page 257. The ESRS reference table also flags the derived datapoint on "Human rights issues and incidents connected to its upstream and downstream value chain paragraph 36" here.

The disclosure is presented as an action table mapping each material impact to the action taken, the tracking mechanism and the responsible function (page 257):

Outcome for the year (page 257): "In 2025, no cases of human rights violations were reported."

Supporting evidence elsewhere. Contractor safety performance is reported in detail under S1-14 and improved: contractor and subcontractor injuries with days of absence fell from 15 to 9 and their rate from 2.9 to 1.8, while total recordable injuries among contractors fell from 37 to 25 and the rate from 7.1 to 5.1 (pages 248-249). Against that, one of the two 2025 fatalities was a contractor at the Ipoh plant in Malaysia, during maintenance, attributed to serious violations of company procedures before the start of work (page 245). The human rights audit covering 13 countries includes "Supply Chain Management" in its scope (page 230).

Reading of this disclosure. The actions are mostly documentary: a signed Supplier Code of Conduct, legal verification that it was signed, and policy-driven training. Only the heavy equipment row carries an outcome metric (number of injuries). No supplier audit numbers, no coverage of the supply base by any social assessment, and no remediation case is described. The Group's own admission that it has no structured engagement with value chain workers (page 256) limits how far the effectiveness of these actions can be tested.

Targets related to value chain workers

Reference: page 257.

The company states that it has set none (page 257):

"Currently, no specific objectives have been planned for workers in the value chain: for example, working conditions, and other rights related to it. Nevertheless, with the definition of the Procurement policy, specific targets and metrics will be set within 2026."

This is an explicit nil return under the disclosure requirement rather than an omission, and it is consistent with the rest of the S2 chapter: no structured engagement process with value chain workers (page 256), documentary actions built on the Supplier Code of Conduct (page 257), and a Group Sustainable Procurement Policy adopted only in 2025 whose contractual clauses and supplier self-assessment are still to be implemented (page 256).

What sits behind the absence. The Group identified four potential negative impacts on value chain workers, all upstream and all potential rather than actual (page 142): temporary contracts in upstream quarrying and mining that "may lack protections"; exposure to silica dust causing chronic disease, flagged as a severe impact; use of heavy vehicles and mining activities increasing the risk of fatalities; and "Forced labour, trafficking or child labour in the chain cause severe impacts". Four associated risks concern penalties, third-party incidents near plants, and operating in regions with child or forced labour risk (pages 142-143). The material sub-topics are working conditions and other work-related rights (page 138).

Related targets that do exist elsewhere. The 2030 ambition summarised at page 138 states the intention to "Ensure that all workers in the value chain comply with the highest standards of health, safety and fair working conditions" and to "Ensure respect for human rights along the entire value chain", but neither is expressed as a measurable target with a baseline or a date. The only quantified supply chain engagement metric in the statement is the CDP Supply Chain response rate of 28.5% in 2025 (page 147), which measures environmental reporting rather than working conditions.

Policies related to affected communities

Reference: pages 259-260. The ESRS reference table flags the human rights policy commitments datapoint (paragraph 16) and the non-respect of UNGPs and OECD Guidelines datapoint (paragraph 17).

"Cementir has established comprehensive policies to manage its material impact and risks related to affected communities. These policies are designed to address the specific needs of various communities impacted by the company's operations" (page 259).

The Group Water Policy (page 259) is presented as the most directly relevant instrument, "particularly relevant to communities in water-scarce regions, as it addresses the company's responsibility to manage water resources sustainably, thereby reducing potential conflicts over water usage. The policy clearly emphasises that a key commitment of the Company is to foster a relationship of constructive collaboration, grounded in complete openness and trust, both within the organisation and with the local community and institutions, in order to address water-related challenges and promote the conservation of this shared resource."

The Stakeholder Engagement Policy (page 259): "Cementir is dedicated to generating value for local communities ... by listening to their voices and building relationships based on transparency and accountability."

Human rights instruments (page 259): "Cementir's Group Human Rights Policy, Supplier Code of Conduct and Group Code of Ethics aim to support and guide management and employees in ensuring compliance with international standards, including the United Nations Declaration of Human Rights, ILO Conventions and the OECD Guidelines, towards the communities affected by the Company's operations."

Three specific commitments (page 260):

• Resettlement - "as defined in the Group Human Rights Policy, Cementir seeks to avoid involuntary resettlements. In situations where it is unavoidable, the Company commits to comply with the national governments or regional authorities' guidelines on resettlement and rehabilitation and also act in line with international Human Rights norms on this subject."
• Security - "Cementir strives to ensure that the provision of security to its operations and its engagement with public and private security forces is consistent with the laws of the relevant country and relevant international standards and guidelines ... adapt its security arrangements to balance the need for safety while respecting Human Rights."
• Operating in difficult contexts - "the Company recognises that in countries that are politically less stable or where human rights are compromised dilemmas may arise: including whether or how it can continue to operate in that country with integrity. Cementir will act in such a way that none of its operations knowingly contribute to the violation of Human Rights."

Scope of affected communities (page 259): communities near operating sites, communities along the value chain and communities at either endpoint of the value chain are all in scope; communities of indigenous peoples are marked as not applicable, and no explanation for that determination is given.

Processes for engaging with affected communities about impacts

Reference: page 260, with the fuller description at pages 258-259.

"Cementir has focused on organising meetings with groups of residents to provide them with detailed information about the work and operations taking place at the Group's sites. The Group Corporate Social Responsibility Policy entailed the perspectives of affected communities" (page 260).

Who runs it (page 260): "at local level, in all the countries where the Company operates, HSE Manager are responsible for the active dialogue with local communities supporting their exigencies and specific requests, through regular meeting based on their needs. Additionally, the Company regularly updates the communities on its activities and gathers their concerns, as outlined in the Stakeholder Engagement Policy, through the main engagement tools of local communities (dedicated meetings, direct contact, official reports)."

Vulnerable and marginalised groups (page 260): "With specific reference to communities concerned that may be particularly vulnerable to impacts and/or marginalised, as well as the opinion of specific groups within the communities concerned such as women and girls, the Company, takes measures organising periodic sessions to understand the views and needs of the communities concerned and works constantly to satisfy their necessities."

How concerns are handled (page 259): "Each single plant provides to organise periodic meetings with the local communities to understand their special needs or requests, as dust complaints, noise complaints about trucks. HSE manager relates with the local institutions / associations, through discussion with representatives of local communities. Results of the discussion are then reviewed internally to identify appropriate and feasible solutions. The frequency of other interactions is determined on a needs-basis."

A named context (page 259): "This becomes even more important where increased urbanisation has brought cities closer to the Group's plants, particularly in Turkiye ... the proximity of the Elazig and Izmir plants to residential areas underlines the importance of a constant dialogue with local communities, which are particularly sensitive to the surrounding environment and the visual impact of the plants. To address these precise concerns, Cimentas is adopting specific strategies of engagement and communication with stakeholders."

Documented examples from 2025 elsewhere in the statement: community workshops on the future recreational use of the Rordal quarry area in Aalborg, held in 2024 and again in 2025 (page 199); periodic consultations with local communities and nature conservation organisations on restoration priorities (page 198); and the supply of recovered quarry water to the Walloon public distribution network at Clypot and Gaurain (page 180).

Limitation. No metric is given: not the number of community meetings held, complaints received or complaints resolved in 2025. The Group states that the engagement frequency is needs-based, so a reader cannot judge how often communities were actually consulted.

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

Reference: page 260.

"Enterprise Risk Management aims to provide support to the decision-making and operational processes of company management, to reduce the possibility that specific events could compromise the Group's ordinary operations or the achievement of its strategic objectives" (page 260).

Control structure (page 260): "The Cementir Group's Internal Control and Risk Management System is integrated with the Group's Sustainability Strategy. Risk Management and Internal Audit Function are the main responsible for the internal control and risk management system (second and third level of control). They are responsible for verifying that the Internal Control and Risk Management System is adequately working with respect to the size and operations of the Group. In particular, they are responsible to verify that the Management has identified the main risks, evaluated in a consistent manner, and that the appropriate mitigation actions have been defined and implemented."

The channel (page 260): "In accordance with applicable legislation, the Group has established whistleblowing management process to report suspected human rights violations and any other potential violation." The whistleblowing platform is described elsewhere as accessible 24/7 to external stakeholders, anonymous, protected against retaliation and managed by the Internal Audit Function (pages 256 and 268).

The community-facing route (page 259): in practice complaints reach the company through the local HSE manager. "Each single plant provides to organise periodic meetings with the local communities to understand their special needs or requests, as dust complaints, noise complaints about trucks ... Results of the discussion are then reviewed internally to identify appropriate and feasible solutions." Stakeholder mapping tools "allow Group companies to analyse stakeholder complaints and suggestions, in order to provide the necessary information or plan targeted actions".

Reading of this disclosure. The section describes the Group's internal control architecture more than a community grievance mechanism. Two channels are identifiable, the whistleblowing platform and the plant-level HSE manager route, but the report does not state whether communities are aware of them or trust them, does not describe how the Group tracks issues to resolution, and gives no figure for community complaints received or remediated in 2025. Nothing in the statement records a remedy provided to an affected community during the year.

Taking action on material impacts on affected communities

Reference: pages 260-261. The ESRS reference table also flags "Human rights issues and incidents paragraph 36" here.

"Cementir production requires large amounts of water, causing water scarcity and negative impacts on local communities and other industries. Nevertheless, the Company signed the WASH Pledge, engaging to taking action on WASH (e.g. water, sanitation and hygiene) at all its workplaces within the next three years. At local level the Company also decided to clean cars and streets from dust to prevent negative impacts on the affected communities" (page 260).

Remediation route (page 260): "In the case of a negative impact, Internal Audit Function is responsible for conducting analyses to identify the issue, proposing corrective actions to mitigate the identified impact, and overseeing the follow-up to ensure the actions are properly implemented and maintained."

Action table (page 261):

Substantive community actions documented elsewhere in the statement:

• District heating at Aalborg - the recovery of excess heat supplies about 20,000 households, with the goal of exceeding 30,000, and over 80,000 once the CCS infrastructure is running; the Group records this as a material positive impact for community stakeholders (pages 159 and 258)
• Drinking water in Wallonia - 2,117 thousand m3 of quarry water from Clypot and Gaurain sent for drinking water treatment in 2025, up from 1,627 thousand m3, reducing the community's dependence on well water in high water stress districts (page 180)
• Water efficiency in stressed areas - specific water consumption in high water stress areas down to 236 litres per tonne, 19% below the 2019 baseline (page 183)
• Quarry rehabilitation with community input - the Rordal recreational area workshops in Aalborg in 2024 and 2025 (page 199)

A stale year reference to check. The action section closes with "No case of incidents in terms of Human Rights have been found in 2024" (page 261), in a statement covering the 2025 financial year. The equivalent 2025 nil returns appear under S1-17 and S2-4.

Limitation. The action table names one impact only, water scarcity, although the DMA also identified air emissions affecting public health as a material negative community impact (page 258). No action is tabled against that second impact, and no monetary or coverage figure is given for the community actions.

Targets related to affected communities

Reference: page 261.

The company states that its community objectives are not measured (page 261):

"The commitment towards the community is a core principle of Cementir and directly linked to the company's purpose of positively affecting local communities ... For all these reasons Cementir is active on several levels, some well-established and present for many years (e.g. Cimentas Education and Health Foundation, recovery of heat from kiln fuel), some others occasional but crucial for building thriving and inclusive communities (e.g. Marche des carrieres). It is important to point out that even if in the presence of objectives there are no metrics in place to date to measure these targets."

What is quantified instead: community spending (page 261):

The Group defines charitable donations as "one-off or occasional support to good causes in response to the needs and appeals of charitable and community organisations", community investments as "long-term strategic involvement in, and partnership with, community organisations to address a range of social issues chosen by the Group", and commercial initiatives as "business-related activities in the community, usually undertaken by commercial departments to directly support the success of the company, promoting its corporate and brand identities and other policies, in partnership with charities and community-based organisations" (page 261).

Related targets that do exist elsewhere. The DMA summary at page 138 records the S3 ambition as community engagement, redistribution of benefits and a water access commitment, "Adherence to the WASH Pledge, aligned with SDG 6, to ensure access to safe water and sanitation services for all employees at company sites" with an intention to "Extend WASH principles to the value chain (suppliers and communities)". The measurable water targets that most affect communities sit under E3-3: a 30% reduction in specific water consumption by 2030 against 2019, and 25% for plants in high water stress areas (page 182).

Reading of this disclosure. Total community spending rose 8% year on year, driven by commercial initiatives, while charitable donations fell 56%. Charitable spend is an input measure, not an outcome target, and the company says plainly that no metrics exist to measure its community objectives.

Policies related to consumers and end-users

Reference: page 263. The ESRS reference table flags the derived datapoints on policies related to consumers and end-users (paragraph 16) and non-respect of the UNGPs and OECD Guidelines (paragraph 17).

The policy set as presented (page 263) is: a customer-centric approach "managed through a CRM system for effective responses to the market"; "Continuous improvement of the offer, supported by surveys and performance measurements"; "Promotion of low environmental impact solutions that meet the circular economy"; a multi-year cybersecurity programme; the Code of Ethics; the whistleblowing channels; and the Group Human Rights Policy.

Cybersecurity, the material sub-topic (page 263): a "Multi-Year Cybersecurity Programme based on the NIST Cybersecurity Framework, sponsored by the COO and overseen by the Board of Directors", structured across Identify, Protect, Detect, Respond and Recover. Technical controls are "implementation of tools such as XDR, SASE, MFA, vulnerability management and an active SOC (Security Operation Centre)". Risk management involves "conducting annual assessments, testing a Security Incident Response Plan, regular checks and management of Confidential Accounts". Verification and training cover "submission to the rating programme and ethical hacking activities. Continuous training and periodic phishing campaigns for employee awareness."

Code of Ethics and grievance route (page 263): "The Code of Ethics applies to all stakeholders (customers included), ensuring integrity and legal compliance (antitrust, corruption). Whistleblowing Channels: prepared for violations of the Code of Ethics and unfair practices, open to internal and external parties (including customers), managed by the Internal Audit Function. Covered Areas: financial accounting, violation of laws/regulations, corruption/bribery, antitrust regulations, health/safety/environmental hazards, discrimination and harassment."

Human rights (page 263): "The Human Rights Policy of the Group applies to all stakeholders (including customers), adhering to the principles of the Universal Declaration of Human Rights and the ILO. The commitment provides for the respect and promotion of Human Rights in commercial commitments (with suppliers, clients, subcontractors, etc.) through a proactive approach, monitoring and appropriate contractual clauses."

Materiality context (pages 138 and 143). The single material S4 sub-topic is "Informational impacts for consumers and end users". The register records one positive impact, "Innovative low-carbon products with transparent technical and sustainability information for responsible choices", and one risk, "Sensitive data breaches: identity theft, fraud, reputational damage, legal penalties and loss of revenue", both short term and downstream.

Limitation. No consumer-specific policy document is named. The instruments cited are general (Code of Ethics, Human Rights Policy) or operational (CRM, cybersecurity programme). The report does not state whether the policies address product safety or accessibility for consumers, or how they are made known to consumers and end-users.

Processes for engaging with consumers and end-users about impacts

Reference: pages 264-265.

"Cementir adopts a 'glocal' strategy that combines international growth (exports to over 70 markets) with a direct and local approach to improve support and understand the needs of customers. The Group has developed a close and synergistic business model that coordinates all touchpoints (sales, marketing, supply chain, technical assistance, laboratories) to improve visibility into the customer value chain" (page 264).

Channels (page 264): events and seminars "focused on new trends, solutions for the construction industry, strategic and sustainability initiatives"; online resources including "websites, blogs and e-learning platforms for performance, product uses and information sharing"; and regional events involving "key clients, partners, authorities, residents".

Dated 2025 engagements (page 264):

• Aalborg Portland ran "numerous evening events throughout Denmark, during which commercial and technical representatives of Aalborg Portland presented FUTURECEM to companies, bricklayers and operators in the sector"
• "In October 2025, CCB organised an event that brought together the main customers and partners from the three business areas - cement, ready-mixed concrete and aggregates - illustrating the pillars of the decarbonisation strategy"
• "In November 2025, Aalborg Portland Australia unveiled the new D-Carb solution for the Asia-Pacific region during the Cement Masonry Association of Australia (CMAA) Forum in Melbourne"
• "In Denmark, in March 2025, UNICON - an RMC company of Aalborg Portland - established a customer panel with the aim of strengthening dialogue with the market ... Within the panel, composed of 15-20 selected and representative customers from different Danish regions, topics related in particular to sustainability requirements were addressed"
• "in November 2025, Cimentas and Cimbeton participated as Main Sponsors, exhibitors, keynote speakers and panellists at the Concrete 2025 Expo & Summit"

Structured measurement (page 265): "in Europe and Asia-Pacific (APAC), the Group also conducts a Voice of the Customer Survey (VoC) annually to measure customer satisfaction and engagement on product quality, services, innovation, relationships, sales processes, after-sales services and technical support ... In 2025, our market perimeter remained constant, with enhanced content and greater surveying of populations with an improvement in the number of respondents."

Result (page 265): "In 2025, the overall value of the Net Promoter Score (NPS) was 58.1, confirming and strengthening the recovery trend that began in 2023. Regarding the Customer Loyalty Score (CLS), the overall rate for 2025 confirmed a high level of customer satisfaction."

Limitation. The engagement described is with commercial customers, architects, engineers and construction companies. The Group defines consumers as "the individuals who use its clients' products or services, specifically citizens who use the final product for personal purposes" (page 262), and no direct engagement channel with that group is described. No senior role is identified as operationally responsible for consumer engagement.

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

Reference: page 265, with the channel description at page 263.

The grievance channel (page 263): "Whistleblowing Channels: prepared for violations of the Code of Ethics and unfair practices, open to internal and external parties (including customers), managed by the Internal Audit Function. Covered Areas: financial accounting, violation of laws/regulations, corruption/bribery, antitrust regulations, health/safety/environmental hazards, discrimination and harassment." The wider description of the platform records that it is "accessible 24/7, including to external stakeholders", ensures "confidentiality, anonymity, prohibition of retaliation and an independent process of evaluation and investigation of reports" (page 268), and complies with EU Directive 1937/2019 and Legislative Decree 24/2023 (page 256).

The commercial route (page 265): customer issues are handled through the CRM system and the Voice of the Customer process. "Listening to and understanding the Voice of the Customer is a fundamental approach that begins with day-to-day customer management through each product delivery and extends into more sophisticated and customised activities. The approach aims to respond effectively and quickly to customers' needs and the problems that arise from feedback throughout the journey with the customer." Sales and marketing teams "use CRM worldwide to track, measure and develop the quality and results of each individual customer relationship, including anticipating their needs and business opportunities", and "In addition to some transactional surveys and 'informal' monitoring of relationships ... the Group also conducts a Voice of the Customer Survey (VoC) annually".

The VoC results "identify areas for improvement and is oriented towards strategic inter-functional, inter-company and inter-regional initiatives, some of which are incorporated in the strategic project programme" (page 265).

Outcome for the year (page 266): "In 2025, no severe Human Rights issues and incidents connected to Cementir consumers and/or end-users have been reported."

Limitations. Two routes exist, the whistleblowing platform and the CRM and survey process, but neither is presented as a consumer grievance mechanism in the ESRS sense. The report does not state whether consumers and end-users are aware of the channels or trust them, gives no figure for complaints received from consumers in 2025, and describes no remedy provided. The complaints statistics the Group does publish relate to business conduct reports handled by Internal Audit (page 268).

Taking action on material impacts on consumers and end-users

Reference: pages 265-266. The ESRS reference table also flags "Human rights issues and incidents paragraph 35" here.

Actions on the data privacy risk (page 266): "The company regularly trains its employees to identify phishing attempts delivered via email. This is done by sending simulated phishing emails to all staff members regularly. Employees who successfully detect and report the phishing attempt are congratulated, while those who miss the signs are informed about the specific indicators they should have noticed in the fake phishing email." In addition, "To protect against cyberattacks using deceptive websites and fake login interfaces, the company introduced a training program for all employees, focused on secure login practices."

Action table (page 266):

Actions on the positive information impact (pages 262-263): "By providing detailed information on innovative materials - such as white cement applications, Ultra High-Performance Concrete and low-emission cements - and offering dedicated technical support, Cementir ensures that professionals (architects, engineers and construction companies) have complete information on product performance, sustainability characteristics and correct application methods." The Group supports "the dissemination of Environmental Product Declarations (EPDs) and comprehensive and reliable technical communication tools", and platforms such as InWhite Solutions "provide for close collaboration with customers and partners to develop innovative and cutting-edge solutions, favouring the direct transfer of technical know-how". It also "offers value-added services, such as after-sales assistance and consultancy on solutions with a lower environmental impact".

The Group assesses the positive impact as "of medium-positive intensity, as it contributes to increasing economic productivity through the availability of reliable data for companies and the creation of an informed and aware consumer base" (pages 262-263).

Outcome for the year (page 266): "In 2025, no severe Human Rights issues and incidents connected to Cementir consumers and/or end-users have been reported."

Limitations. The action table has one row, and its impact label, "Data presentation", does not match the risk identified in the register, which is sensitive data breaches leading to identity theft, fraud, reputational damage, legal penalties and loss of revenue (page 143). No data breach count, no EPD count and no effectiveness metric is given, and the tracking column names a plan rather than a measure of whether the actions worked.

Targets related to consumers and end-users

Reference: page 266.

No target is in place; the company says it intends to set some (page 266):

"A further objective for the coming years is to integrate an even deeper understanding of customer needs into business processes, systematically valuing their feedback to guide strategic decisions, define long-term priorities, and promote a path of continuous improvement. At the same time, the Group will proceed with the definition of dedicated metrics and specific objectives, with the aim of monitoring in a structured way the effectiveness of the initiatives undertaken and further strengthening the centrality of the customer in the operational and decision-making models."

The same intention appears in the engagement section: "A further objective is to integrate in the next years the understanding of customer needs into business processes and to use their feedback to build long-term strategies, inspire business decisions and promote continuous improvement" (page 265). Neither passage attaches a metric, a baseline or a date.

The one measured customer indicator. The Voice of the Customer survey produces a Net Promoter Score, reported at 58.1 for 2025, "confirming and strengthening the recovery trend that began in 2023", and a Customer Loyalty Score which "confirmed a high level of customer satisfaction" (page 265). The report does not present the NPS as a target: no threshold, no direction of travel commitment and no prior-year figure are given alongside it, and the CLS value itself is not published.

Materiality context (page 138). The DMA sets the S4 ambition as "Customer engagement: Understand, satisfy and interact with a diverse customer base. Integrate processes, technologies and human interactions to strengthen the relationship throughout the entire customer journey." That is a statement of intent rather than a target.

Reading of this disclosure. For the one material S4 sub-topic, informational impacts for consumers and end-users, and for the associated data privacy risk, the Group has no time-bound outcome target for FY2025 and says so. The absence is disclosed rather than concealed, but it means neither the positive information impact nor the data breach risk can be tracked against a stated ambition. The Group also does not state whether consumers or their representatives were involved in setting the objectives it intends to define.

Business conduct policies and corporate culture

Reference: pages 267-268. The ESRS reference table flags the United Nations Convention against Corruption datapoint (paragraph 10 (b)) and the protection of whistleblowers datapoint (paragraph 10 (d)).

"The Group promotes a corporate culture based on integrity, transparency and responsibility, supported by the Code of Ethics and a structured system of policies and procedures aimed at preventing non-compliant behaviour and strengthening ethical governance safeguards. The Code of Ethics constitutes the main reference for all employees and business partners, expressly prohibiting bribes, illegitimate favours, collusion and any request aimed at obtaining undue advantages" (page 267).

Anti-corruption framework with dates (page 267): "Since 2015, the Group has introduced an Anti-Corruption Policy that defines roles, responsibilities and expected behaviours, applicable to all Group companies. In 2016, this framework was further strengthened through an anti-corruption compliance programme aligned with the UK Bribery Act, which includes a procedure for the management of gifts and hospitality, a systematic assessment of corruption risk, and due diligence activities on third parties."

Training (pages 267-268): "The Cementir Academy offers specific courses on the Code of Ethics, compliance, fraud prevention, reporting management and, more generally, on the Group's values, corporate culture and leadership. Employees also participate in courses dedicated to cybersecurity and, since 2025, to the responsible management of Artificial Intelligence." The IRO-1 section records "mandatory training programmes completed by 100% of employees" (page 267).

Whistleblower protection (page 268): "The Group guarantees the possibility of reporting illegal activities, violations of the Code of Ethics or non-compliant behaviour via a whistleblowing platform accessible 24/7, including to external stakeholders. The system ensures confidentiality, anonymity, prohibition of retaliation and an independent process of evaluation and investigation of reports. The Internal Audit and Enterprise Risk Management Function oversees the management of risks related to whistleblower protection, corruption and regulatory compliance."

How culture is measured (page 268): the Group "evaluates the effectiveness of its corporate culture through indicators such as participation in training, volume and type of reports, results of investigations and results of awareness-raising activities".

Corporate identity (page 267): "the corporate culture defined by the One Group identity and the Concretely Dynamic principle has fostered the spread of ethical behaviours throughout the value chain."

Positive impact claimed (page 267): "In 2025, strengthening whistleblowing systems helped prevent material risks related to fraud, regulatory violations and potential environmental damage, improving the overall resilience of the organisation."

Independent corroboration of awareness comes from the December 2025 survey of the Code of Ethics, Human Rights Policy and DE&I Policy, which covered 79% of the workforce with a response rate above 20% (page 229).

Prevention and detection of corruption and bribery

Reference: pages 268-269.

"The prevention of corruption and the protection of competition are essential elements for a sector characterised by complex market structures, such as cement and ready-mixed concrete. For this reason, the Group is equipped with safeguards that ensure compliance with the laws and the correct management of relations with all stakeholders" (page 268).

Investigating body (page 268): "The Ethics Committee, established by the Board of Directors, supervises the implementation of the Code of Ethics, promotes training initiatives, monitors any violations, and manages the reports received." Reports are received, analysed and investigated by the Internal Audit Function, which is separate from the management chain it investigates.

Reports received in 2025 (page 268): "In 2025, 13 reports of potential violations were recorded, four of which were confirmed or partially confirmed, resulting in the application of the necessary disciplinary measures and the initiation of corrective actions on the business processes involved."

Antitrust (page 268): "The adoption of a comprehensive antitrust policy has also strengthened the Group's ability to ensure compliance with competition regulations, preventing anti-competitive agreements, abuses of dominant position and other non-compliant conduct. The policy is supported by local compliance programmes and systematic monitoring by the Internal Audit."

Functions identified as most exposed to corruption risk (page 268): regional managers and business unit chief officers; group chief officers; sales, marketing and business development functions; supply chain and procurement; other white-collar functions with authorising or negotiating powers; and "Business Consultants and Other High Impact Third Party Counterparties".

Training of functions at risk (page 269): a table gives, for each function at risk, the total population, the number receiving training, the frequency (annually for most, at hiring for one) and the topics covered, which include the definition of corruption, the policy and procedures on suspicion and detection. In the published text the column headings and the numeric rows do not align reliably, so the per-function figures should be read from the source document rather than taken from this entry.

Prevention architecture (page 267): the Anti-Corruption Policy dating from 2015, the 2016 compliance programme aligned with the UK Bribery Act, a gifts and hospitality procedure, systematic corruption risk assessment and third-party due diligence.

Targets related to business conduct

Back-filled from the G1 business conduct chapter (pages 267-269), where this content is disclosed in the FY2025 report. Under the 2023 ESRS against which the statement was prepared, business conduct targets fell under MDR-T rather than a numbered G1 targets requirement.

No quantified business conduct target is stated. The G1 chapter sets out no numeric goal, no baseline and no deadline for corruption incidents, training coverage, whistleblowing outcomes or antitrust compliance. The 2030 ambition recorded in the DMA summary (page 139) is written as commitments rather than metrics: "Operate with integrity, ensure fair competition and ethical practices. Apply anti-corruption policies and promote transparency ... Ensure safe and confidential channels for reporting misconduct. Apply a zero-retaliation policy ... Ensure that every advocacy activity meets legal and ethical standards. Maintain transparency in political contributions ... Implement rigorous anti-corruption and anti-bribery measures throughout the organisation and value chain."

Effectiveness is tracked in the absence of a target, which is the other limb of MDR-T. The company states how it measures whether its business conduct framework works (page 268): it "evaluates the effectiveness of its corporate culture through indicators such as participation in training, volume and type of reports, results of investigations and results of awareness-raising activities".

Those indicators are populated during the year:

• Participation in training - "mandatory training programmes completed by 100% of employees" (page 267); a training table for the functions most exposed to corruption risk, with annual frequency for most and at hiring for one (page 269); Cementir Academy courses on the Code of Ethics, compliance, fraud prevention and reporting management, plus a new 2025 course on the responsible management of Artificial Intelligence (pages 267-268)
• Volume and type of reports - 13 reports of potential violations in 2025, 4 confirmed or partially confirmed, 8 filed as not confirmed or generic and 1 ongoing, from China, Denmark and Turkiye, alleging non-adherence to Group procedures (page 268)
• Results of investigations - "Disciplinary actions, organisational changes, and operational improvements" (page 268); over the three-year period 2023-2025 no convictions or financial penalties for anti-corruption or anti-bribery violations (page 269)
• Awareness-raising - the second awareness survey of the Code of Ethics, Human Rights Policy and DE&I Policy launched in December 2025, covering 79% of the workforce with a response rate above 20%, whose results were discussed with Top Management and used to define an action plan (page 229)

Reading of this disclosure. Effectiveness tracking is real and evidenced, so the MDR-T requirement is answered on its alternative limb. But there is no target against which a reader can judge performance, and the indicators are activity measures rather than outcome measures. Business conduct incentive linkage is also absent: the ESG objectives in the short-term incentive plan cover CO2, safety, biodiversity, circularity, clinker and water, not ethics or compliance (pages 131 and 155).

Incidents of corruption or bribery

Reference: page 269. The ESRS reference table flags two derived datapoints here: fines for violation of anti-corruption and anti-bribery laws (paragraph 24 (a)) and standards of anti-corruption and anti-bribery (paragraph 24 (b)).

The disclosure is a three-year nil return (page 269):

"In the three-year period 2023-2025 Cementir has not registered convictions or suffered financial penalties for violations of anti-corruption or anti-bribery laws. Similarly, no incidents of corruption have been confirmed that have led to the dismissal of employees or the termination of contracts with business partners."

That covers the two datapoints the requirement asks for: convictions and fines for violation of anti-corruption and anti-bribery laws, and confirmed incidents resulting in dismissal or contract termination.

Context that a reader should hold alongside it. The Group did receive and confirm reports during the year, but under a different heading. "In 2025, 13 reports of potential violations were recorded, four of which were confirmed or partially confirmed, resulting in the application of the necessary disciplinary measures and the initiation of corrective actions on the business processes involved." The matter alleged in the reports ascertained is recorded as "Non-adherence to Group procedures", the countries of provenance as China, Denmark and Turkiye, and the outcome as "Disciplinary actions, organisational changes, and operational improvements" (page 268). Non-adherence to Group procedures is not a corruption finding, and the report does not describe any of the four confirmed cases as corruption or bribery, so the nil return and the four confirmations are consistent on their face.

Related nil returns elsewhere in the statement: no work-related incidents of discrimination and no severe human rights incidents in 2025 or 2024 (page 254); no cases of human rights violations reported in the value chain in 2025 (page 257); no severe human rights issues connected to consumers or end-users in 2025 (page 266).

Not disclosed. The requirement also asks for the number of confirmed incidents relating to contract termination with business partners and details of public legal cases regarding corruption or bribery brought against the undertaking and its own workers, and the outcomes of such cases. The statement records the absence of convictions but does not state whether any public legal case is pending.

Political influence and lobbying activities

Reference: pages 269-271.

Core position (page 269): "In 2025, Cementir Holding N.V. maintained an approach based on maximum transparency, integrity and responsibility in its interactions with institutions, regulatory bodies, industry associations and technical bodies. In line with the Policy on Lobbying Activities and Political Contributions, the Group has not engaged in direct lobbying and has not made any political contributions, either direct or indirect, in any jurisdiction."

Political contributions (page 269): "In 2025 Cementir Holding N.V. made no political contributions, neither in monetary form nor in kind. As there are no contributions, the accounting policies inkind are not applicable."

Representation register (page 270): "In 2025, the Group is not registered in official lobbying registers, not carrying out activities of direct political influence."

Revolving door datapoint (page 270): "In 2025, no member of the Board of Directors or company committees held public office in the previous two years."

Oversight (page 269): "The supervision of representation activities and institutional interactions is included in the general responsibilities of the Board of Directors regarding business conduct, risk management and compliance. As there is no direct lobbying activity, there is no dedicated oversight process beyond that defined within the overall governance system."

Topics advocated through associations (page 269): reduction of emissions and alignment with the ETS and CBAM framework; circular economy and use of alternative materials; occupational safety and technical regulations; industry standards for cement and ready-mixed concrete products; and monitoring of European and international regulatory developments. "The positions held by the Group through these bodies are fully consistent with the ESG strategy and with the decarbonisation commitments made by the Group."

Memberships (page 270): the Global Cement and Concrete Association, including the Innovandi research network joined in 2019 and working groups on the net zero roadmap, health and safety management and ESG reporting; CementEurope, where the Group "participates in the CEMENTEUROPE Council and working bodies for Climate and Energy, Resources and Processes, Health and Safety, and Markets and Products" and provides "feedback to the European Commission on the EU Taxonomy and the Corporate Sustainability Reporting Directive (CSRD)"; and the European Cement Research Academy, "whose research projects are related to carbon capture and storage (CCS) technology".

Expenditure in 2025 (pages 270-271): industry associations EUR 676,261.87; technical and standard-setting bodies EUR 268,446.06; business and economic associations EUR 215,793.11; lobbying and advocacy EUR 108,619.00, "mainly due to membership in European associations in the cement and ready-mixed concrete sector". EU expenditure totalled EUR 1,103,701.96 in 2025 against EUR 843,956.65 in 2024, and the EU breakdown adds EUR 44,967.00 for academic bodies, regulators and professional associations.

A tension worth noting. The Group states that it does not engage in direct lobbying and is not on any lobbying register, yet reports EUR 108,619.00 of expenditure under a "Lobbying / advocacy" category, a line that did not exist in 2024. The report explains the category as association membership rather than reconciling it with the no-direct-lobbying statement.