Cenergy Holdings Board of Directors Role

Cenergy Holdings recognizes that its sustainability strategy relies on an effective governance structure regarding sustainability matters at its Board of Directors in order for the Company's policies and initiatives to have the proper oversight of implementation across all subsidiaries. Information concerning the composition, roles and responsibilities as well as experience and expertise of the member of the Board of Directors can be found in the "Corporate Governance Statement" section of Cenergy Holdings 2024 Annual Report (p. 163).

Audit Committee Oversight Responsibilities

To address this, the Company has established a sustainability governance structure to create long-term value for all stakeholders and promote sustainability principles within the organization and all its subsidiaries. To that end, the Audit Committee has been tasked with assisting the Board of Directors in overseeing sustainability practices of Cenergy Holdings' subsidiaries.

The Audit Committee meets at least four times per year and has the oversight responsibility of the following tasks:

• identification of material impacts, risks and opportunities (IRO) performed by the subsidiaries and consolidated at Company's level, • implementation by executive management of the due diligence and results and effectiveness of policies, actions, metrics and targets associated with the IROs • the oversight and validation of the Company's sustainability report.

The Audit Committee is informed about the results of the Double Materiality Assessments (DMA), that are conducted by the subsidiaries on a regular basis (generally every three years or sooner if the need arises), and the relevant identified materials impacts, risks and opportunities (IROs). Based on these results, the Committee is overseeing how the management of the subsidiaries integrates material IROs in their business strategy and their risk management process, as well as what are the appropriate measures taken to mitigate any identified adverse impacts and risks, and to seize any relevant opportunities.

Deputy Chief Services Officer for Energy and Sustainability

Steelmet has appointed a Deputy Chief Services Officer for Energy and Sustainability who gives guidance, promotes best practices and leads sustainability integration in all Cenergy Holdings companies. The Deputy CSO for Energy and Sustainability reports directly to the Steelmet Chief Services Officer who is responsible for all corporate services Steelmet provides to the subsidiaries. The Deputy CSO for Energy and Sustainability acts as a subject-matter expert who advice the subsidiaries' executive management and informs the Company's Audit committee on all sustainability matters mentioned above with oversight responsibility.

Segment Sustainability Coordinators

Each segment, has a sustainability coordinator who coordinates the various functions, facilitates relevant actions and the implementation of the due diligence process, identifies and manages material impacts, risks and opportunities, and reports progress on selected sustainability metrics at least on semi-annual basis. The individuals assigned for this task, are employees who are highly experienced, proficient and knowledgeable in the sustainability related fields.

Executive Management Incentive Schemes

Cenergy Holdings, as a holding company does not implement an incentive scheme linked to sustainability matters for the BoD members. More information about the Remuneration policy can be found at the relevant section of "Corporate Governance Statement" (p. 163).

However, Cenergy Holdings subsidiaries have linked executive management variable compensation packages to critical sustainability related matters, incentivizing high performance and promoting the significance of sustainability matters cross the organization. Emphasizing the crucial role of senior management in driving sustainability initiatives, specific incentive schemes have been established covering 20% of variable compensation.

2024 Performance Focus Areas

For 2024 in particular, the focus areas were:

• Health and safety improvements • Environmental stewardship

Environmental stewardship performance was not evaluated against specific GHG emission reduction targets set by the companies but based on mixture of indicators relating to environmental management, environmental targets and training, and pollution prevention measures.

Regarding health and safety, the incentives plan focused on: • implementation of capital expenditures projects • health and safety competencies • safety governance issues • implementation of several new standard operating procedures of high priority programs

Performance Assessment and Review

The performance is being assessed against specific relevant targets, which have been determined based on the current performance of the subsidiaries on these topics. The variable compensation incentives scheme is reviewed by Steelmet executives and adjusted, if needed, on an annual basis by taking into consideration the prior years' experience, the companies' current objectives as well as industry benchmarks. These schemes utilize well-defined Key Performance Indicators (KPIs), and targets set to industrial practice benchmark levels, with allowances for gradual improvements in targeted areas over a specified timeframe.

Sustainability Risk Management Framework

Cenergy Holdings has established an Enterprise-wide Risk Management (ERM) framework across its subsidiaries that encompasses sustainability-related risks. The framework provides guidelines for effectively managing risks in all subsidiaries and facilitates discussion on risk management issues.

Risk Management Process

The ERM framework in Cenergy Holdings' subsidiaries encompasses the following key elements:

a) Identify key risks and measure / analyse their potential impact and likelihood. This is done via the use of a consistent risk taxonomy across the Group and at company level as all financial, operational, compliance and strategic risks are associated with each company's operations.

b) Formulate a risk appetite statement i.e., articulate a level of risk tolerance desired at the Group vs. subsidiary level. This is possible only if a number of top risks across the Group are identified and a number of qualitative and/or quantitative metrics for them are selected.

c) Manage (i.e., respond to) those risks by considering existing controls as well as selecting, prioritising and implementing appropriate actions. Some of these actions do not necessarily reflect risk mitigation and include avoiding, transferring, insuring or even accepting the risk. This step is done at company level, following the general principles outlined in the ERM framework.

d) Control and monitor internal and external environment for potential changes to risks, ensuring risk responses continue to be effective. Each company monitors its risks and risk responses, using the common ERM guidelines but separate procedures, systems and mechanisms put in place by each company's management.

e) Finally, companies report a consolidated evaluation on their risks, integrated with a review of their financial performance. Based on this, Cenergy Holdings' executive management judges their overall risk – return trade off and presents the outcome to the Audit Committee and the Board of Directors.

Audit Committee Role

The Audit Committee monitors the effectiveness of the subsidiaries' internal controls and looks into specific aspects of controls and risk responses on an on-going basis.

Risk Classification

Risks are classified into two major families:

Financial Risks

Includes different types of market risk affecting the activity of each subsidiary (mainly, exchange rate, interest rate and commodities risk) as well as credit and liquidity risk.

Business Risks

Broadly defined as all risks that are not balance-sheet related, broken down into:

A. Strategic risks include risks related to the wider business environment (e.g. the macroeconomic environment, the sector / industry conditions, etc.) the market and the competition, and medium to long-term decision making that may impact on business continuity and profitability. Also included are potential impacts to the subsidiaries' (and the Holdings') brand image and business reputation.

B. Operational and technology risks defined as the risk of loss resulting from inadequate or failed processes, people and systems or from external events. Operations risks comprise all risks associated with Environment, Social and Governance (ESG) such as Health & Safety and environmental issues but not legal, strategic or reputational risks.

C. Legal and regulatory risks include possible negative impacts (economic – fines, penalties, duties etc. and other – exclusion from markets, sanctions, etc.) from noncompliance with existing regulations and standards, including accounting rules.

Business Model

Cenergy Holdings is a Belgium-based holding company listed on the Euronext Brussels Exchange (CENER) and the Athens Stock Exchange (CENER). It invests in leading industrial companies, focusing on the growing global demand of energy transfer, renewables and data transmission.

Cenergy Holdings subsidiaries are committed to sustainable manufacturing of high-quality, circular, innovative solutions. The portfolio of Cenergy Holdings subsidiaries encompasses a range of dynamic markets such as energy transmission and distribution, renewable energy sources and telecommunications, gas & liquid.

Production Model and Value Chain

Downstream Metals Processing Focus

Cenergy Holdings subsidiaries' production model is centered on downstream metals processing. Downstream processing of metals refers to mechanical treatment of the intermediate products (slabs, billets, wire rods, etc.) after the initial refining or remelting of the metal, such as manufacturing components or finished products from the refined metal. In the case of the steel pipes segment, the main raw material used in steel pipe manufacturing is hot rolled steel.

Upstream Activities

Upstream activities in metals processing begin with mining and ore processing for primary metals, or collection and sorting of scrap for secondary raw materials. These materials are then refined, smelted, and transported to Cenergy Holdings subsidiaries for further processing. Each stage is essential to maintaining a consistent supply of quality raw materials. To support this, Cenergy Holdings subsidiaries have built strong partnerships with trusted raw material suppliers and transportation companies and implement rigorous testing to ensure materials meet strict quality standards.

Downstream Activities

Downstream activities include processing intermediate products into final goods or distributing them to end-users. After use, products enter the end-of-life phase, where metal scrap is collected and processed for recovery and reuse. Cenergy Holdings subsidiaries support a circular economy by promoting recycling, reducing environmental impact, and ensuring cost-effective raw material supply. The life cycle of Cenergy Holdings subsidiaries' products is typically from some decades for steel pipes and half a century for construction steel and power cables.

Product Portfolio and Market Positioning

Cenergy Holdings subsidiaries offer high-quality, sustainable products that support global infrastructure and align with evolving sustainability trends. These products are designed to support infrastructure projects and diverse markets, ensuring reliability and performance.

Cables Segment Products

• Submarine and land cables (low to extra high voltage) • Installation services and turnkey solutions for power grids, interconnections, offshore and onshore wind, solar energy, oil and gas, and heavy industries • Telecommunication and data transmission cables • Optical fiber cables (submarine, single-mode and multi-mode) • Railway signalling cables

Steel Pipes Segment Products

• Pipes for transportation of gas and liquid fuels (offshore and onshore) • Pipelines for hydrogen transportation • Pipelines supporting Carbon Capture and Storage (CCS) • OCTG pipes for drilling operations • Hollow sections for structural applications • Pipes for water and non-fossil fuel transportation

Workforce Distribution

Sustainability Integration in Business Strategy

Cenergy Holdings and its subsidiaries are fully committed to sustainability principles and have integrated it into their strategy and decision-making processes. The sustainability strategy includes seven core corporate policies covering a wide range of critical sustainability matters. Various qualitative and quantitative metrics, internal and external controls for due diligence, and regulatory compliance are utilized to monitor these policies.

Strategic Opportunities

Cenergy Holdings companies' products are instrumental in combating climate change and advancing the energy transition. They provide key products that enable the energy transition, such as: • Power cables for renewable energy projects • Telecom cables for digital infrastructure • Steel pipes for green hydrogen transportation • Steel pipes for Carbon Capture and Storage technologies

Cenergy Holdings companies are well-positioned to benefit from these opportunities, leveraging their expertise and innovative products to foster a more sustainable, low-carbon economy.

Strategic Challenges

Significant challenges include: • High costs associated with implementing advanced technologies and sustainable practices • Raw material premiums for low carbon alternatives (low carbon aluminium and steel) • Competition from companies offering cheaper alternatives • Customer price sensitivity - most customers prioritize cost over sustainability attributes • Limited availability of raw materials with recycled content • Supply chain vulnerabilities related to sustainable materials sourcing

Interests and views of stakeholders

Cenergy Holdings' stakeholders

Being a holding company oriented towards industrial companies, Cenergy Holdings has limited stakeholders. Cenergy Holdings' main stakeholders are its shareholders, investors, its subsidiaries, and governmental and regulatory authorities.

Shareholders and investors

Cenergy Holdings is a holding company listed on the Euronext Brussels Exchange (CENER) and the Athens Stock Exchange (CENER), so Cenergy Holdings' shareholders include institutional investors, private investors, and financial market participants with an interest in the company's financial performance and long-term value creation.

Engagement channels and frequency:

• General meetings (annual)
• Financial disclosures
• Investor relations activities
• Financial calendar published on website with information about date and time of related events
• Dedicated investor section on website with financial results, reports, presentations, shareholder and corporate governance information

Key concerns/views: The primary goal is to maintain transparency, build trust, and provide shareholders and investors with insights into the company's strategic direction, financial performance, and long-term objectives.

Integration into strategy: Feedback from the various stakeholder engagement activities with shareholders and investors is taken into account when adjusting corporate strategies, governance practices, and capital allocation decisions.

Subsidiaries

Cenergy Holdings' subsidiaries are primarily industrial companies in the metals processing sector. The companies operate independently but they are having to meet the parent company's requirements in strategic and financial decisions, risk management and sustainability standards.

Engagement channels and frequency:

• Regular and structured engagements through management meetings
• Performance reviews
• Strategic planning sessions
• Semi-annual business reviews involving executive management teams
• High level of informal engagement with ongoing open communication with Steelmet executives on a regular basis

Key concerns/views: Engagements are designed to assess the subsidiaries' performance in key areas such as financial results, operational efficiency, and sustainability initiatives. Discussions focus on the planning and implementation of various initiatives, with a shared aim of fostering best practices across all subsidiaries.

Integration into strategy: The objective of these meetings is to align subsidiary operations with Cenergy Holdings' broader strategic goals while supporting their growth, operational efficiency, and sustainability efforts. This ongoing dialogue helps to ensure that day-to-day operations align with the larger strategic framework and that improvements are continually being made at every level.

Governmental and regulatory authorities

Governmental and regulatory authorities encompass both local and national governments in the countries where Cenergy Holdings' subsidiaries operate, as well as the regulatory bodies responsible for ensuring compliance with various legal, environmental, and financial standards.

Engagement: Steelmet is tasked with monitoring all governmental and regulatory issues on behalf of Cenergy Holdings. Engagement with these authorities is essential to ensure that Cenergy Holdings and its subsidiaries consistently meet both existing and emerging legal and regulatory obligations. Compliance is achieved through a range of activities, including regular communication with regulatory agencies, participation in audits, and the submission of required reports and documentation. Steelmet or the subsidiaries' professionals work closely with these authorities to stay ahead of regulatory changes and maintain full legal compliance.

Cenergy Holdings subsidiaries' stakeholders

While Cenergy Holdings as a holding company has its stakeholders, the subsidiaries have their own distinct set of stakeholders.

Employees (own workforce)

Among the most important stakeholders are the subsidiaries' employees. The companies place notable emphasis on day-to-day communication with employees.

Engagement channels:

• Employee satisfaction surveys
• Company intranet
• Emails and announcements
• Corporate events
• Frequent meetings between Executive Management and heads of various departments
• Meetings between department heads and staff

Customers

Engagement: Daily customer communication is managed by the customer service and marketing departments of the subsidiaries, who also handle any complaints. The companies further engage with the industry by participating in relevant events each year.

Key concerns/views: Cenergy Holdings companies are in continuous engagement with their customers to enhance the sustainable attributes of their products. This collaboration aims to identify and implement innovative solutions that meet evolving environmental standards.

Integration into strategy: By fostering open dialogue, Cenergy Holdings companies ensure that customer feedback is integral to product development, sustainability initiatives and strategic planning. This means actively listening to and, where applicable and beneficial for all parties, incorporating useful customer insights and suggestions into various stages of the product lifecycle. The established communication channels ensure that valuable input about the customer preferences and market dynamics are gathered. This collaborative approach not only enhances the quality and sustainability of products but also builds stronger relationships with customers. Ultimately, it ensures that Cenergy Holdings' strategies are aligned with the evolving needs and expectations of their stakeholders, driving continuous improvement and innovation.

Suppliers

Engagement: The companies ensure effective daily communication with their suppliers, primarily through the procurement department. Additionally, the companies actively participate in industry associations and consistently attend supplier exhibitions. These efforts support the companies in staying current with industry trends and maintaining strong, collaborative partnerships with suppliers.

Due diligence process: Cenergy Holdings subsidiaries are employing a Suppliers' Code of Conduct and collaborating with external consultant EcoVadis to assess sustainability performance in the supply chain. EcoVadis evaluates suppliers based on environmental, labour and human rights, ethics, and responsible procurement criteria. This initiative aims to identify sustainability risks in the supply chain and mitigate those risks when suppliers present a risk for the subsidiaries' sustainability performance and credibility.

Financial institutions

Financial institutions remain important stakeholders, particularly in supporting the subsidiaries' growth through financing and investment. The subsidiaries have an ongoing engagement with financial institutions mainly via periodic meetings.

Key concerns/views: Their main topic of interest are the companies' financial performance, their business plans and strategic goals, and occasionally the sustainability performance.

NGOs and local communities

NGOs and local communities are also important, especially in relation to the subsidiaries' environmental and social impacts that could potentially affect the local communities they are operating within.

Engagement: The subsidiaries engage with them through supporting and participating in activities organized by local community bodies and associations and sectoral and business organizations, as well as through events and conferences.

Key concerns/views: The main interests of local communities and NGOs relate to the companies' response to local communities' issues, the recruitment of employees from the local community, as well as the collaboration with local communities and NGOs representatives for the support of their actions.

Integration with governance

The Cenergy Holdings Audit Committee, which oversee the organization's sustainability initiatives, are informed about the results of stakeholder engagement and the interests and views of stakeholders regarding sustainability-related impacts, through the Double Materiality Assessment procedure. They also receive updates on the matter, during their scheduled periodic meetings each reporting year. In these meetings, the progress of sustainability initiatives and projects undertaken during the year, as well as developments in the field of sustainability, are discussed. Additionally, Cenergy Holdings' executive management is informed during the semi-annual business reviews, which involve the executive management teams of each subsidiary. These reviews provide an opportunity to discuss the progress and developments in sustainability initiatives and ensure that the interests of stakeholders are considered in strategic planning.

Stakeholder engagement for specific impacts

Human and labor rights (own operations and upstream value chain)

Through the double materiality assessment process, companies employed credible proxies as representatives for each stakeholder group. This approach involved interviewing internal subject matter experts who were knowledgeable about specific stakeholder groups. These experts provided valuable insights into the impacts, risks, and opportunities that the stakeholder groups they represented might face. Additionally, these experts contributed essential feedback during the assessment of IROs. This process enhanced the overall accuracy and reliability of the double materiality assessment.

In scope of the companies' material impacts are employees working in the sites but not part of the companies' own workforce, workers working for entities in the companies' upstream value chain, such as mining/refining companies, but also workers particularly vulnerable such as trade unionists, migrant workers, home workers, women or young workers.

Human rights assessment is a core area of interest for all the different stakeholder groups within the value chain. The companies are collaborating with suppliers, contractors and customers within their value chain.

Occupational health and safety (own operations and upstream value chain)

Affected stakeholders: Workplace accidents can affect the health and safety of direct and indirect employees in own operations, and workers in the upstream value chain, resulting in long-term physical and emotional harm.

Engagement channels:

• Health and Safety coordinators at all subsidiaries and dedicated subcommittees
• Monthly production meetings where employees provide input on improvements and risk mitigation in their areas
• Quarterly meetings with stakeholders presenting health and safety reports, including KPI updates and critical action plans
• Monthly safety committees
• Feedback sessions
• Safety meetings, workshops, and one-on-one discussions
• Comprehensive training on grievance and complaint handling mechanisms, integrated into onboarding and reinforced through ongoing workshops and communications

Integration into strategy: Corinth Pipework has introduced a program to incentivize safety improvement ideas from employees, fostering a culture of continuous improvement. By involving employees and stakeholders in the process, the companies ensure concerns are heard, addressed, and resolved through a systematic process of identifying issues, assessing their impact, and implementing corrective actions. Managers and team leaders encourage the use of grievance channels, ensuring concerns are taken seriously, handled confidentially, and with respect.

Value creation through products

Cenergy Holdings companies' products play a key role in climate change mitigation and the energy transition. They are providing products which are essential for building renewable energy infrastructure, such as wind and solar power, and for modernizing and expanding energy grids. In addition, using recycled metals to meet raw materials demand reduces the energy and emissions associated with raw material extraction and support the shift toward a more sustainable, low-carbon economy.

Cenergy Holdings companies' products help customers to meet their sustainability and climate goals, as the products enable customers to reduce their carbon footprints by using materials with lower environmental footprint, and at the same time strengthens the partnership and also drives continuous improvement for all parties.

Double materiality assessment - stakeholder engagement

During the DMA process, companies employed credible proxies as representatives for each stakeholder group. This approach involved interviewing internal subject matter experts who were knowledgeable about specific stakeholder groups. These experts provided valuable insights into the impacts, risks, and opportunities that the stakeholder groups they represented might face. Additionally, these experts contributed essential feedback during the assessment of IROs. This process enhanced the overall accuracy and reliability of the double materiality assessment.

Stakeholder classification: Stakeholders were classified into the following two groups: affected stakeholders and users of the sustainability statement.

Key stakeholders identified: The key stakeholders identified by the subsidiaries included shareholders and investors, customers, suppliers, financial institutions, employees, local communities, NGOs, state and governmental authorities, and the scientific community. Nature was identified as a silent stakeholder.

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

Overview of material IROs

Cenergy Holdings conducted a double materiality assessment (DMA) in 2024 at segment level to identify the most material impacts, risks and opportunities on sustainability matters in-line with ESRS requirements. The assessment followed a bottom-up approach with disaggregation by the cables segment and steel pipes segment.

The DMA followed a 4-step procedure:

1. Understanding the context
2. Identification of impacts, risks, and opportunities related to sustainability matters
3. Assessment and determination of material IROs
4. Reporting

For the consolidation of materiality results across business segments, various proxies/KPIs were considered: capital employed, energy consumption and number of employees. For environmental assessments, energy consumption served as the proxy. For labor and social impacts, the number of employees was the guiding factor. For governance and overall economic performance, capital employed was used.

List of material IROs

Table 8: Results of double materiality assessment – Impact materiality

Table 9: Results of double materiality assessment – financial materiality

Interaction with strategy and business model

Cenergy Holdings companies' products play a key role in climate change mitigation and the energy transition. They are providing products which are essential for building renewable energy infrastructure, such as wind and solar power, and for modernizing and expanding energy grids. In addition, using recycled metals to meet raw materials demand reduces the energy and emissions associated with raw material extraction and support the shift toward a more sustainable, low-carbon economy.

Cenergy Holdings companies are in continuous engagement with their stakeholders, especially their customers to enhance the sustainable attributes of their products. This collaboration aims to identify and implement innovative solutions that meet evolving environmental standards. By fostering open dialogue, Cenergy Holdings companies ensure that customer feedback is integral to product development, sustainability initiatives and strategic planning.

The established communication channels ensure that valuable input about the customer preferences and market dynamics are gathered. This collaborative approach not only enhances the quality and sustainability of products but also builds stronger relationships with customers. Ultimately, it ensures that Cenergy Holdings' strategies are aligned with the evolving needs and expectations of customers and climate goals, as the products enable customers to reduce their carbon footprints by using materials with lower environmental footprint, and at the same time strengthens the partnership and also drives continuous improvement for all parties.

Resilience to identified IROs

For climate-related resilience, Cenergy Holdings published its first standalone TCFD report in 2023. The TCFD framework supports the companies to transparently communicate their management of climate-related risks and opportunities. Through the TCFD implementation, the subsidiaries performed a thorough evaluation of their strategy and business model against potential climate-related risks and opportunities. This included assessing physical risks (such as extreme weather events and sea-level rise) and transition risks (such as regulatory changes and shifts in market demand).

The analysis covered all relevant business operations in all geographic locations, as well as upstream and downstream value chain where applicable. The resilience analysis was conducted using different climate scenarios to evaluate how different climate futures could impact the operations of the companies, taking into consideration the likelihood, magnitude and duration of the hazards. The insights gained from the TCFD were instrumental in evaluating climate-related risks and opportunities during the DMA exercise, with the TCFD findings informing the DMA process.

Time horizons

The definitions of time horizons applied were:

• Short-term: 0-1 years
• Medium-term: 1-5 years
• Long-term: more than 5 years

However, for climate-related issues, the time horizons are different as the sustainability matter is considered to evolve more slowly:

• Short-term: 0-3 years
• Medium-term: 3-10 years
• Long-term: >10 years

Due diligence process integration

The process for identifying, assessing and managing impacts and risks is not yet formally integrated into the companies' risk management and overall management processes. However, the companies are committed to progressing towards this integration in the next 5 years in order for impacts, risks and opportunities to be continuously monitored and evaluated through a structured framework to ensure alignment with the companies' strategic goals and objectives.

Cenergy Holdings recognizes that the double materiality assessment is an ongoing process, and that the results should go beyond reporting purposes. The results of the double materiality assessments and the insights from stakeholders will play a pivotal role in refining the existing Sustainability Strategy. The DMA will be reviewed every three years unless any significant change occurs in external factors such as new investments, new regulatory framework, changing climate conditions, etc.

Governance oversight

The Audit Committee has been tasked with assisting the Board of Directors in overseeing sustainability practices of Cenergy Holdings' subsidiaries. The Audit Committee meets at least four times per year and has the oversight responsibility of:

• identification of material impacts, risks and opportunities (IRO) performed by the subsidiaries and consolidated at Company's level
• implementation by executive management of the due diligence and results and effectiveness of policies, actions, metrics and targets associated with the IROs
• the oversight and validation of the Company's sustainability report

The Audit Committee is informed about the results of the Double Materiality Assessments (DMA) that are conducted by the subsidiaries on a regular basis (generally every three years or sooner if the need arises), and the relevant identified materials impacts, risks and opportunities (IROs). Based on these results, the Committee is overseeing how the management of the subsidiaries integrates material IROs in their business strategy and their risk management process, as well as what are the appropriate measures taken to mitigate negative impacts and develop opportunities.

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

Overview of the Double Materiality Assessment Process

Cenergy Holdings and its subsidiaries updated their double materiality assessment during 2024 to ensure full alignment with ESRS requirements. The primary goal was to create a thorough and comprehensive assessment that captures all material impacts, risks and opportunities, ensuring that no critical information or significant impact areas are missed. This update was designed not only to meet regulatory and audit obligations, but primarily to serve as a critical tool for the subsidiaries to better understand the sustainability-related impacts and financial implications of their operations, allowing the subsidiaries to refine and update their sustainability strategy in line with emerging risks, opportunities, and stakeholder expectation.

Being a holding company oriented towards industrial companies, a bottom-up approach was considered as the most appropriate consolidation method. For the DMA, the same disaggregation was followed as the one described in table 1 of the "Introduction" section, because the companies under the same segment have in general similar operations and value chains and consequently similar impacts, risks and opportunities.

Step-by-Step Methodology

Each segment followed the same 4-step procedure when conducting the DMA:

Step 1: Understanding the Context

In this step, the companies of each segment developed an overview of their activities and business relationships, the context in which these take place and an understanding of their key affected stakeholders. This overview provides key inputs to identify the relevant IROs. The subsidiaries performed a complete mapping of their activities, business relationships and other contextual information. They then classified their own operations as well as the operations of their upstream and downstream value chain based on the working paper draft of ESRS Sector classification standard which is based on the NACE classification of activities. They created a list with their top suppliers, top customers, and the significant product categories they are offering. The mapping of the value chain included companies beyond Tier 1 (Tier 2 suppliers who are the suppliers of the suppliers, Tier 2 customer who are the customers of the customers etc.), including Joint ventures and project-related businesses that the companies did not have operating control.

The identification of potential sustainability megatrends and the exposure of the companies to these trends, the review of key sustainability-related regulatory frameworks that may affect the companies, as well as review of, where applicable, media reports, sector-specific benchmarks and scientific articles, complemented the necessary information for the first step of the DMA process and enabled the companies to create a thorough and comprehensive context to base their materiality assessment in the subsequent steps of the process.

The "understanding the context" step was concluded by identifying the affected stakeholders who are likely to be affected by the companies' own operations and upstream and downstream value chain. Understanding of the interests and views of key stakeholders as they relate to the companies' strategy and business model, it is an integral part of the due diligence process and the materiality assessment process. Stakeholder engagement informs the identification and assessment of material impacts and ensures the completeness of the material impacts identified. Stakeholders were classified into the following two groups: affected stakeholders and users of the sustainability statement. The key stakeholders identified by the subsidiaries included shareholders and investors, customers, suppliers, financial institutions, employees, local communities, NGOs, state and governmental authorities, and the scientific community. Nature was identified as a silent stakeholder.

Step 2: Identification of Impacts, Risks, and Opportunities Related to Sustainability Matters

In this step, the companies identified the actual and potential IROs relating to environmental, social and governance matters across their own operations and in their upstream and downstream value chain. The outcome of this step was a 'long' list of impacts, risks and opportunities for further assessment and analysis in subsequent steps of the process.

The companies, using, as a starting point, the list of the sustainability matters in ESRS 1 paragraph AR16, developed a comprehensive outline of sustainability (sub)(sub)topics throughout the entire value chain that were relevant to companies' business model, operations, strategy and business relationships. Entity-specific sustainability matters not covered in that list were also considered. To develop this outline, the companies reviewed the latest available Sustainability Reports of their suppliers, peers and customers and complemented the analysis with other benchmarks such as the SASB materiality map and the MSCI materiality map. By the end of this exercise and following a consolidation method with quantitative criteria based on the assignment of different weights for each step of the value chain (own operations, Tier 1 and suppliers, Tier 1 and 2 customers), each of the sustainability (sub)(sub)topics and any entity-specific sustainability matters, were given a relevance score. The relevance score followed a 4-point scale: negligible, low, medium and high. The sustainability matters that fell under negligible scale, were excluded from the next step of the process which was the identification of impacts, risks, and opportunities related to sustainability matters, because those matters were considered as not relevant neither to own operations of the companies nor to their upstream and downstream value chain. On the other hand, for every sustainability matter that fell under the low, medium or high relevance categories, was documented whether relevance relates to own operations, upstream value chain, downstream value chain or any combination of those three.

Then, the sustainability teams of the companies, using the list of relevant and potentially material sustainability matters as developed through the previous stage, identified a long list with actual or potential, negative or positive impacts on people or the environment over the short-, medium- or long-term connected with the companies' own operations and upstream and downstream value chain, including through their products and services, as well as through their business relationships. For the identification of impacts, the business model of the companies (business activities, strategic orientation and priorities, geographical locations), as well as different time horizons was considered. The definitions of the time horizons applied were for short-term 0-1 years, medium-term 1-5 years, long-term more than 5 years. However, for climate-related issues, the time horizons are different as the sustainability matter is considered to evolve more slowly. Hence, the applied time horizons for climate change are short-term 0-3 years, medium-term 3-10 years, and long-term: >10 years. The list developed included impacts that they are directly caused by the companies' operations, as well as impacts directly linked to the companies' operations, products and services, however, caused by a business relationship.

Impact materiality and financial materiality assessments are inter-related and the interdependencies between these two dimensions need to be considered. For this reason, the identification of risks and opportunities followed the impact identification. Firstly, a review of whether the identified impacts could potentially lead to risks and opportunities was performed, then the identification of risks and opportunities that may derive from dependencies on natural (i.e., energy, water, materials) and social (i.e., employees) resources followed, and finally the list of identified risks and opportunities was complemented by the identification of risks and opportunities not sourced from impacts or dependencies.

Step 3: Assessment and Determination of Material IROs

In this step, the companies applied specific criteria for assessing impact and financial materiality in order to determine the material actual and potential impacts and the material risks and opportunities.

Assessment of Impacts

A sustainability matter is material from an impact perspective when it pertains to the company's material actual or potential, positive or negative impacts on people or the environment over the short, medium- or long-term. Impacts include those connected with the company's own operations and upstream and downstream value chain, including through its products and services, as well as through its business relationships.

For actual negative impacts, materiality assessment performed by the subsidiaries was based on the severity of the impact. Severity is based on the following factors:

• the scale;
• scope; and
• irremediable character of the impact (only for negative impacts).

For potential impacts, likelihood was considered together with the severity of the impacts. In terms of likelihood, the likelihood of a potential negative impact refers to the probability of the impact happening.

In the case of a potential negative human rights impact, the severity of the impact took precedence over its likelihood.

For positive impacts, materiality is based on: (a) the scale and scope of the impact for actual impacts; and (b) the scale, scope and likelihood of the impact for potential impacts

The assessment of the negative and positive, actual or potential environmental, social and governance impacts was performed based on the specific scoring criteria that were the same across all business segments.

Assessment of Risks and Opportunities

A sustainability matter is material from a financial perspective if it triggers or could reasonably be expected to trigger material financial effects on the company. This is the case when a sustainability matter generates risks or opportunities that have a material influence or could reasonably be expected to have a material influence, on the company's development, financial position, financial performance, cash flows, access to finance or cost of capital over the short-, medium- or long-term. Material risks and opportunities generally derive from impacts, dependencies or other factors such as changes in regulations.

The materiality of risks and opportunities is assessed based on a combination of the likelihood of occurrence and the potential magnitude of the financial effects over the short-, medium- or long-term. Risks and opportunities may derive from past events or future events and may have effects in relation to assets and liabilities already recognized in financial reporting or that may be recognized as a result of future events.

The assessment of risks and opportunities was performed based on specific scoring criteria that were the same across all business segments.

For the assessment of risks and opportunities, an internally developed methodology was used instead of any market risk-assessment tools.

Step 4: Reporting

After completing the assessment, the companies aggregated the material IROs on a (sub)(sub)topic level. In the occasion that more than one impacts or risks and opportunities have been identified for a specific (sub)(sub)topic, the aggregation on (sub)(sub)topic level followed the score of the IROs that have been assessed higher compared the others, regardless of whether it was actual or potential, negative or positive for the impact materiality, and risk or opportunity for the financial materiality. This means that positive impacts could not be netted against negative impacts, and financial opportunities cannot be netted against financial risks. In addition, the companies did not net impacts in own operations with impacts in the upstream/downstream value chain. When impacts were identified as material in the value chain, they were assessed and reported separately compared to the ones relating to own operations.

With regards to IROs that they are near the materiality threshold (close calls), and it was not clear whether they are material or not, the companies performed a number of actions to determine their materiality. Firstly, the companies reassessed the IROs by incorporating any additional insights and feedback by subject-matter experts. Furthermore, they evaluated long-term trends relating to these specific IROs and how they align with the company's strategic goals. Finally, the companies engaged the executive management in the process to review these borderline cases and validate decisions to include or exclude them ensuring alignment with the companies' strategic priorities.

Thresholds for Materiality

Based on the scoring criteria already described, a sustainability matter was considered as material from an impact perspective, when the average result, depending on the type of impact (negative-positive, actual-potential, human rights related etc.) of severity and/or likelihood was greater a pre-defined value. This pre-defined value contributed to the objectivity of the exercise by establishing a clear benchmark for evaluation, ensuring that all sustainability matters were assessed consistently and comparably across various contexts.

Consolidation at Cenergy Holdings Level

Each segment followed the same process for their impact and financial materiality assessments, and for each segment the most material impacts, risks and opportunities were identified. Finally, the executive management of the subsidiaries validated the results of the DMA. After a double materiality assessment had been performed for each segment, the results were consolidated at Cenergy Holdings level.

For the consolidation of materiality results across business segments, various proxies/KPIs have been considered. The main three were capital employed, energy consumption and number of employees. Each of the proxies has its advantages and disadvantages. Given the challenges in selecting a single proxy for consolidating materiality results, the company opted to use a tailored approach with the use of all three distinct KPIs. For environmental assessments, energy consumption served as the proxy, as it best reflects the environmental impact of each segment, particularly in energy-intensive operations. Furthermore, energy has a strong correlation with other environmental parameters such as water consumption (due to cooling needs in thermometallurgical processes that result in extensive water evaporation) and waste generation. To evaluate labor and social impacts, the number of employees was the guiding factor, since it highlights the human capital and labor dynamics across segments. Lastly, for governance and overall economic performance, the company used capital employed as a proxy, linking governance-related materiality to financial exposure. This approach ensures that each dimension of materiality - environmental, social, and governance - is assessed through the most relevant lens, offering a more balanced and accurate representation of impacts across the parent company. For the consolidation of financial materiality assessment results, Cenergy Holdings also used capital employed as a weighting factor among the business segments.

The outcomes of the double materiality assessment for both segments have been reviewed by the Sustainability Department of Steelmet, which also performed the consolidation on Cenergy Holdings level. The consolidated results were then validated by the Audit Committee who has the oversight of the double materiality assessment.

Stakeholder Engagement During the DMA Process

During the DMA process, companies employed credible proxies as representatives for each stakeholder group. This approach involved interviewing internal subject matter experts who were knowledgeable about specific stakeholder groups. These experts provided valuable insights into the impacts, risks, and opportunities that the stakeholder groups they represented might face. Additionally, these experts contributed essential feedback during the assessment of IROs. This process enhanced the overall accuracy and reliability of the double materiality assessment.

Use of Value Chain Mapping

The subsidiaries performed a complete mapping of their activities, business relationships and other contextual information. They then classified their own operations as well as the operations of their upstream and downstream value chain based on the working paper draft of ESRS Sector classification standard which is based on the NACE classification of activities. They created a list with their top suppliers, top customers, and the significant product categories they are offering. The mapping of the value chain included companies beyond Tier 1 (Tier 2 suppliers who are the suppliers of the suppliers, Tier 2 customer who are the customers of the customers etc.), including Joint ventures and project-related businesses that the companies did not have operating control.

Frequency and Last Review

Cenergy Holdings recognizes that the double materiality assessment is an ongoing process, and that the results should go beyond reporting purposes. The results of the double materiality assessments and the insights from stakeholders will play a pivotal role in refining the existing Sustainability Strategy. The DMA will be reviewed every three years unless any significant change occurs in external factors such as new investments, new regulatory framework, changing climate conditions, etc.

During 2024, Cenergy Holdings and its subsidiaries updated their double materiality assessment to ensure it fully aligns with the ESRS requirements.

Integration with Risk Management and Strategy

The Cenergy Holdings Audit Committee, which oversee the organization's sustainability initiatives, are informed about the results of stakeholder engagement and the interests and views of stakeholders regarding sustainability-related impacts, through the Double Materiality Assessment procedure. They also receive updates on the matter, during their scheduled periodic meetings each reporting year. In these meetings, the progress of sustainability initiatives and projects undertaken during the year, as well as developments in the field of sustainability, are discussed. Additionally, Cenergy Holdings' executive management is informed during the semi-annual business reviews, which involve the executive management teams of each subsidiary. These reviews provide an opportunity to discuss the progress and developments in sustainability initiatives and ensure that the interests of stakeholders are considered in strategic planning.

The process for identifying, assessing and managing impacts and risks is not yet formally integrated into the companies' risk management and overall management processes, however, the companies are committed to progressing towards this integration in the next 5 years in order for impacts, risks and opportunities to be continuously monitored and evaluated through a structured framework to ensure alignment with the companies' strategic goals and objectives.

Transition plan for climate change mitigation

Governance and alignment with business strategy

Cenergy Holdings subsidiaries acknowledge their responsibility in the transition to a low carbon future. A core element of the companies' sustainability strategy is the commitment for gradual replacement of electricity supply with RES thereby reducing direct carbon emissions in their operations. Cenergy Holdings companies also offer a wide range of products that are important for the decarbonization of the economy.

As Cenergy Holdings is a holdings company, the transition plan is not developed on group level, but rather on a segmental level, and it is closely integrated with overall business strategy and financial planning, ensuring alignment with the long-term objectives for sustainable growth. This approach enables the companies of each segment to allocate resources effectively and prioritize initiatives in-line with targets set for climate change mitigation. By embedding transition goals within their strategic framework, the companies ensure continuity, resilience and adaptation to evolving market demands.

Cenergy Holdings companies are committed to adhering to international climate-related frameworks, such as the Paris Agreement and the Sustainable Development Goals #7 and #13. They comply with mandatory reporting frameworks to ensure transparent and accurate disclosure of GHG emissions, energy consumption, and climate-related risks.

It is noted that none of the Cenergy Holdings companies are excluded from the EU Paris-aligned Benchmarks.

Scope of the plan

The transition plan covers the subsidiaries on a segmental level:

Cables segment:

• Hellenic Cables and the entire cables segment
• All production facilities included in the boundary of the report
• Coverage: Scope 1, 2 and 3 GHG emissions

Steel pipes segment:

• Corinth Pipeworks
• Coverage: Scope 1, 2 and 3 GHG emissions

Net zero targets and milestones

Cables segment (Hellenic Cables)

Baseline year: 2020

2030 targets:

• -50% Scope 1 & 2 GHG emissions
• -25% Scope 3 GHG emissions

2050 targets:

• -90% Scope 1, 2, 3 GHG emissions (net-zero)

Progress to date (vs. base year 2020):

• Scope 1&2 emissions: -10.4% reduction achieved
• Scope 3 emissions: -11.8% reduction achieved
• Total emissions (Scope 1,2&3): -11.8% reduction achieved

Steel pipes segment (Corinth Pipeworks)

Baseline year: 2022

2030 targets:

• -50% Scope 1 & 2 GHG emissions
• -25% Scope 3 GHG emissions

Progress to date (vs. base year 2022):

• Scope 1&2 emissions: +26.3% increase (due to increased production)
• Scope 3 emissions: -19% reduction achieved

Paris alignment and SBTi validation

Cables segment:

• Committed to the Science Based Targets initiative (SBTi)
• Targets in line with Paris Agreement 1.5°C pathway
• Near-term (2030) and long-term net-zero targets (2050)
• Target setting covers all greenhouse gases
• Compatibility tested against:
  • Absolute Contraction Approach (ACA) reduction pathway
  • Pathways to Net-zero – SBTi Technical Summary
• Scope 1&2 targets more ambitious than ACA requirement (50% vs. 47.54% by 2030)
• Scope 3 targets aligned with WB2C scenario (25% reduction by 2030)
• Net-zero target tested for alignment against Pathways to Net-zero – SBTi Technical Summary (90% reduction in absolute Scope 1, 2 and 3 GHG emissions by 2050)

Steel pipes segment:

• Targets compatible with limiting global warming to 1.5°C in line with Paris Agreement
• Scope 1&2 targets more ambitious than ACA requirement (50% vs. 47.54% by 2030, baseline 2022)
• Scope 3 targets aligned with WB2C scenario (25% reduction by 2030)
• Cannot be validated according to SBTi framework yet, as no sector-specific guidance has been developed for this particular industrial activity

Decarbonization levers and key actions

Energy transition (Scope 2)

Cables segment:

• Objective to entirely cover electricity needs with renewable energy through Power Purchase Agreements (PPAs)
• Two wind power PPAs concluded (Q4 2024 and Q1 2025)
• Expected outcome: cover total electricity needs from renewable electricity, reduce Scope 2 emissions to zero
• Battery Energy Storage Systems (BESS) required for temporal correlation to achieve >70% green energy utilization
• 100% RES utilization with temporal correlation currently not realistic with given technologies and costs

Steel pipes segment:

• Installation of 7.1MW photovoltaic (PV) system under construction to cover one-third of electricity needs
• PV project anticipated completion by mid-2025
• Feasibility study for Battery Energy Storage System (BESS) underway
• Procurement of electricity from solely renewable sources by 2030 using PPAs (starting 2025) for remaining electricity not covered by PV
• Target: eliminate Scope 2 emissions by 2030

Process improvements (Scope 1)

All segments:

• Energy efficiency projects at operational facilities
• External energy audits with three-year payback to be implemented
• Targeting non-productive losses
• Energy awareness training to relevant employee groups
• Largest and most energy-intensive subsidiaries have performed energy audits with external consultants

Steel pipes segment:

• Replacement of fossil fuels with electricity in machinery and equipment by 2030
• Feasibility studies conducted to replace LPG and diesel in several machinery and equipment (e.g., pipe curing area, pipe preheating)
• Implementation by 2026 of all energy saving projects identified by energy audit (automations, new generation motors, idle time reduction)
• ISO 50001:2018 Energy Management System certification completed
• ISO 14064-1:2019 GHG emissions quantification and monitoring certification

Product development

Cables segment:

• Development of life cycle assessments (LCAs) and environmental product declarations (EPDs) for cable products
• Following normative references: ISO 14025, ISO 14040, ISO 14044
• Products used in EU Taxonomy eligible activities:
  • Renewable technologies manufacturing (3.1)
  • Transmission and distribution of electricity (4.9)
  • Optical fiber cables for telecom sector
  • Cables for railway sector under manufacture of other low carbon technologies (3.6)
  • Low, medium, high voltage cables (3.20)

Steel pipes segment:

• Life cycle assessments (LCAs) and environmental product declarations (EPDs) for all products
• Energy efficiency projects at facilities
• Sustainability awareness sessions and brochures

Supply chain engagement (Scope 3)

Cables segment:

• Active communication and engagement with suppliers to reduce Scope 3 GHG emissions
• Increase percentage of post-consumer recycled materials in products, replacing primary raw materials
• Partnership with supplier delivering aluminium ingots with carbon intensity below half of global average
• Expected outcome: reduction of at least 25% of Scope 3 emissions

Steel pipes segment:

• Close communication with suppliers to promote decarbonization efforts across value chain
• Suppliers increasingly transitioning from traditional blast furnace methods to Electric Arc Furnace (EAF) processes
• Expected outcome: reduction of at least 25% of Scope 3 emissions

Business Partners Code of Conduct:

• Business partners expected to look for cost-effective methods to improve energy efficiency, minimize energy consumption, and promote decarbonization initiatives to reduce direct and indirect GHG emissions
• Published, distributed to all Business Partners and posted on companies' websites

CapEx and investment commitments

Steel pipes segment:

• 7.1MW PV system under construction (no specific CapEx disclosed)
• Energy saving projects by 2026 (no specific CapEx disclosed)
• General statement: "For these projects no major CapEx or OpEx is required" for decarbonization initiatives
• Statement on RES PPAs: "do not come with significant CapEx and OpEx but require a long-term commitment to purchase RES power at a set price that increases the exposure to price fluctuations"

Overall:

• No specific group-level CapEx commitments disclosed
• Statement: "The required investments for the transformation are still several years, or possibly decades away from being economically and technologically viable on a large scale"

Locked-in emissions and stranded asset analysis

For metal processing companies to reach net-zero emissions by 2050, a global transformation of industrial production will be necessary. The products of Cenergy Holdings companies inherently carry embedded (locked-in) emissions mainly due to the primary metals used in their production, particularly aluminum, copper and steel (in the steel pipes segment).

The energy-intensive processes required to extract and refine these metals contribute significantly to greenhouse gas emissions, which those embedded emissions remain associated with the products throughout their first lifecycle. Addressing these locked-in emissions is crucial for meeting the decarbonization targets set by the subsidiaries and aligning with global climate initiatives.

In the transition plan of the subsidiaries, the locked-in emissions relate to companies' growth and the increase in production that would normally result in a subsequent increase in GHG emissions. These locked-in emissions could jeopardize the achievement of GHG emission reduction targets and increase the transition risk.

However, Cenergy Holdings companies with developed transition plans and decarbonization targets do not face these potential risks, as they have accounted for projected production growth up to 2030 in their medium-term targets, ensuring their goals remain achievable.

Technology dependencies and barriers

The subsidiaries must, in the process of developing a transition plan to a net zero long term target, evaluate the degree of development of the implementation of key technologies required in order to achieve this net zero target for the entire value chain (Scopes 1, 2 and 3).

Although some of these key technologies are currently available (electricity from RES, green hydrogen, etc.), their wide deployment to meet 100% of the market needs requires significant capital investments that can only take place if there are price signals in the market that these investments are justified. Alternatively, significant subsidies from state funds are required in order to make these investments possible at a wide scale.

Scope 1 challenges:

• Primarily due to natural gas and LPG consumption
• To substitute natural gas, green hydrogen or biogas must become widely available and most importantly, cost effective
• Alternative: electrification of processes which are prohibitive from an efficiency point of view

Scope 2 challenges:

• Can be significantly reduced by RES PPAs but temporal correlation required
• To achieve green energy utilization in excess of 70%, Battery Energy Storage Systems (BESS) must be widely utilized and cost effective
• 100% RES utilization with temporal correlation currently not realistic
• Other forms of energy storage like renewable fuel of non-biological origin (RFNBO) are years away from wide implementation

Scope 3 challenges:

• Operational emissions (Scopes 1 and 2) significantly simpler to control than Scope 3 emissions
• Transformation required beyond strict operational control of the companies

Competitiveness concerns:

• European industry represents less than 10% of global manufacturing capacity of metals processing
• Massive investments required to transform metals manufacturing will most certainly affect competitiveness of European industries unless effective carbon leakage measures are in place

Criteria for green energy claims

Cenergy Holdings and its subsidiaries have developed specific criteria that need to be met in order for subsidiaries to make a transparent claim regarding the use of energy from RES (i.e., green electricity) or other forms of zero carbon electricity:

1. The supply of green electricity needs to originate either directly from the entity that produces green electricity or needs to be contracted between the electricity supplier and the entity producing the green electricity like a sleeved physical PPA
2. If the source of green electricity is in a neighboring country with the country of consumption, the electricity markets must be coupled
3. The GOs generated for the contracted RES electricity purchased must be canceled on behalf of the Cenergy Holdings subsidiary per the AIB procedure
4. Virtual (financial) PPAs do not meet criteria for claiming green energy

Cenergy Holdings and its subsidiaries consider the use of unbundled GOs (i.e., the purchase of standalone, over the counter RES certificates without any relation to the actual purchased energy) for proof of "green electricity consumption" a misleading claim that is misrepresenting the actual source of the energy used for the production of a good or service.

Carbon credits and removals

Cenergy Holdings subsidiaries do not use nor intend to use, in the near future, carbon offsets in order to present a lower net carbon effect of their operations.

The use of carbon offsets for Cenergy Holdings subsidiaries is a long-term scenario which refers to residual emissions that may not be able to be mitigated within the time frame of their commitment. Most importantly, carbon offsets will be utilized by Cenergy subsidiaries only when there is a harmonized, internationally accepted and legislated framework upon which all interested parties can base their claims and long-term strategy.

It is important to note that EU Directive 2024/825 "…regarding empowering consumers for the green transition through better protection against unfair practices and through better information" specifically prohibits the use of offsets or carbon credits for claiming GHG emissions reductions of any scale.

The use of carbon offsets can potentially mislead consumers when those claims are not based on the actual [text truncated in source]

Internal carbon pricing

Cenergy Holdings companies do not apply internal carbon pricing schemes.

Governance and approval

The decarbonization targets and the relevant transition plans are approved by the top management of each subsidiary, are aligned with the companies' Climate Change and Energy Policy, and they are directly connected to the identified negative impacts of the consumption of non-renewable energy and GHG emissions from the companies' own operation and the value chain.

In setting decarbonization targets, the subsidiaries have taken into consideration potential future developments such as:

• Changes in sales volume
• Changes in the percentage of recycled content in products
• Mature future technologies

The decarbonization targets express the maximum feasible reductions in GHG emissions by the companies. For all targets set, the market-based method for Scope 2 GHG emissions calculation has been used.

Summary table

GHG emission reduction targets visualization

Cables segment:

• Base year 2020: 4,274 kt CO2e total (Scope 1,2&3)
  • Scope 3: 4,221 kt CO2e
  • Scope 1&2: 53 kt CO2e
• Target 2030: -50% Scope 1&2, -25% Scope 3
• Target 2050: -90% Scope 1,2,3

Steel pipes segment:

• Base year 2022: 920 kt CO2e total
• Target 2030: -50% Scope 1&2 (to 19 kt CO2e), -25% Scope 3

Policies related to climate change mitigation and adaptation

Cenergy Holdings and its subsidiaries have adopted policies to combat climate change through proactive mitigation actions and align with global efforts.

Energy and Climate Change Policy

Policy name: Energy and Climate Change Policy

Scope:

• Applies to all operations and business activities of Cenergy Holdings subsidiaries, regardless of the country in which each company operates
• Encompasses the entire upstream and downstream value chain of Cenergy Holdings subsidiaries
• Developed with careful consideration of key stakeholders' interests

Key content and principles:

• Addresses impacts, risks, and opportunities identified through double materiality assessment related to climate change and energy
• Key focus areas include: climate change mitigation, adaptation, energy efficiency, and deployment of renewable energy sources (RES)
• Commitment to purchasing and using energy responsibly, efficiently, and cost-effectively to reduce carbon footprint
• Examining gradual replacement of electricity supply with RES
• Commitment to perform robust climate and vulnerability risk assessments to identify potential areas of hazard and consequent actions with specific adaptation solutions
• Regular monitoring and reporting on energy consumption and GHG emissions are mandated
• Continuous improvement targets set for energy efficiency

Governance and oversight:

• Responsibility for implementing this policy lies with the most senior executive of each Cenergy Holdings company
• Senior executive ensures integration into corporate strategy and operations

Public availability:

• Publicly available to all Cenergy Holdings and subsidiaries' stakeholders through the company's website

Alignment with international frameworks:

• Cenergy Holdings companies are committed to adhering to international climate-related frameworks, including the Paris Agreement and the Sustainable Development Goals #7 and #13
• Comply with mandatory reporting frameworks to ensure transparent and accurate disclosure of GHG emissions, energy consumption, and climate-related risks

Monitoring:

• Regular monitoring and reporting on energy consumption and GHG emissions are mandated
• Continuous improvement targets set for energy efficiency

Business Code of Conduct

Policy name: Business Code of Conduct

Scope:

• Applies to Cenergy Holdings and its subsidiaries

Key content and principles:

• Aims to align Cenergy Holdings companies with global efforts to combat climate change
• Promotes responsible energy consumption and reducing carbon footprint

Public availability:

• Information not explicitly disclosed for this specific code in relation to climate

Business Partner's Code of Conduct

Policy name: Business Partner's Code of Conduct

Scope:

• Applies to business partners including suppliers, contractors, consultants, and business associates

Key content and principles:

• Business partners are expected to look for cost-effective methods to improve energy efficiency
• Minimize energy consumption
• Promote decarbonization initiatives to reduce direct and indirect GHG emissions

Public availability:

• Published, distributed to all Business Partners and posted on the companies' websites

Actions and resources in relation to climate change policies

Overall approach

Cenergy Holdings' transition plan is developed at segmental level (not group level), closely integrated with business strategy and financial planning. The plan enables subsidiaries to allocate resources effectively and prioritize initiatives in-line with climate change mitigation targets.

Key general commitments:

• Gradual replacement of electricity supply with RES to reduce direct carbon emissions
• Energy efficiency projects implementation: all projects identified through external energy audits with a three-year payback will be implemented
• Conserve electricity through targeting non-productive losses and energy awareness training

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Cables segment (Hellenic Cables)

Scope: Own operations and value chain (Scopes 1, 2, 3)

1. Power Purchase Agreements (PPAs) for renewable electricity

Action: Hellenic Cables has entered two wind power PPAs (Q4 2024 and Q1 2025) to enable all facilities to gradually operate on renewable electricity.

• Time horizon: Progressive implementation, full coverage by 2030
• Scope: Scope 2 emissions (own operations)
• Expected outcome: Cover total electricity need from renewable electricity and reduce Scope 2 emissions to zero
• Resources: No significant CapEx or OpEx; requires long-term commitment to purchase RES power at set price (increases exposure to price fluctuations)
• Link to targets: 50% reduction in Scope 1&2 by 2030; 90% reduction by 2050

2. Energy efficiency projects

Action: Energy audits performed with external consultants identifying energy efficiency projects (ongoing/completed or under evaluation).

• Scope: Own operations (Scope 1)
• Expected outcome: Largest possible reduction in Scope 1 emissions through energy conservation

3. Increased post-consumer recycled materials

Action: Increasing percentage of post-consumer recycled materials in products, replacing primary raw materials.

• Scope: Upstream value chain (Scope 3, category 1: purchased goods and services)
• Expected outcome: Reduction of at least 25% of Scope 3 emissions

4. Low-carbon aluminium partnership

Action: Active partnership with supplier delivering aluminium ingots with carbon intensity below half of global average.

• Scope: Upstream value chain (Scope 3)
• Expected outcome: Contribute to at least 25% Scope 3 emissions reduction

5. Life cycle assessments (LCAs) and Environmental Product Declarations (EPDs)

Action: Development of LCAs and EPDs for cable products following ISO 14025, ISO 14040 and ISO 14044.

• Scope: Product level
• Certification: All production facilities certified with ISO 14064-1:2019 for GHG emissions quantification and monitoring

6. Supplier engagement

Action: Active communication and engagement with suppliers to reduce Scope 3 GHG emissions.

• Scope: Upstream value chain (Scope 3)

Cables segment targets:

• Base year: 2020
• 2030 target: -50% Scope 1&2; -25% Scope 3
• 2050 target: -90% Scope 1, 2 & 3

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Steel pipes segment (Corinth Pipeworks)

Scope: Own operations and value chain (Scopes 1, 2, 3)

1. Photovoltaic (PV) system installation

Action: Installation of a 7.1MW capacity PV system (under construction).

• Time horizon: Completion by mid-2025
• Scope: Scope 2 emissions (own operations)
• Expected outcome: Cover one-third of electricity needs, reduce Scope 2 emissions proportionally
• Resources: Currently examining and evaluating Battery Energy Storage System (BESS) through feasibility study
• Link to targets: 50% reduction Scope 1&2 by 2030

2. Procurement of renewable electricity via PPAs

Action: Procurement of electricity from solely renewable sources by 2030 using PPAs (starting 2025) for remaining electricity not covered by PV.

• Time horizon: Starting 2025, full implementation by 2030
• Scope: Scope 2 emissions
• Expected outcome: Eliminate Scope 2 emissions by 2030
• Resources: No major CapEx or OpEx required

3. Replacement of fossil fuels with electricity

Action: Replacement of fossil fuels (LPG and diesel) with electricity in machinery and equipment by 2030.

• Time horizon: By 2030
• Scope: Scope 1 emissions
• Activities: Feasibility studies conducted for LPG and diesel replacement in several machinery/equipment (e.g., pipe curing area, pipe preheating)
• Expected outcome: Largest possible reduction in Scope 1 emissions

4. Energy saving projects from energy audit

Action: Implementation by 2026 of all energy saving projects identified by energy audit.

• Time horizon: By 2026
• Scope: Own operations
• Projects include: Automations and new generation motors to reduce electricity consumption; projects reducing idle working time of pumps and motors
• Certification: Certified with ISO 50001:2018 Energy Management System

5. Energy efficiency initiatives

Action: Conserve electricity by targeting non-productive losses and introducing automations to reduce power consumption in specific production processes.

• Scope: Own operations

6. Supplier engagement for decarbonization

Action: Close communication with suppliers to promote decarbonization efforts across value chain.

• Scope: Upstream value chain (Scope 3)
• Progress: Suppliers increasingly transitioning from blast furnace methods to Electric Arc Furnace (EAF) processes
• Expected outcome: Reduction of at least 25% of Scope 3 emissions

7. Life cycle assessments (LCAs) and Environmental Product Declarations (EPDs)

Action: LCAs and EPDs developed for all products to inform customers about sustainability attributes.

• Scope: Product level

8. Energy awareness and training

Action: Promoting energy awareness through dedicated sustainability awareness sessions and sustainability brochures.

• Scope: Own operations

Steel pipes segment targets:

• Base year: 2022
• 2030 target: -50% Scope 1&2; -25% Scope 3
• Current status (vs 2022): +26.3% Scope 1&2 (due to production increase); -19% Scope 3

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Cross-segment initiatives

Criteria for implementing green energy

Cenergy Holdings developed specific criteria for transparent claims regarding use of RES:

1. Immediate need for additional deployment of cost-effective RES
2. Development of cost-effective energy storage solutions
3. Temporal matching of electricity supply and demand; if cross-border, electricity markets must be coupled
4. Green electricity must originate directly from producer or contracted via sleeved physical PPA
5. Guarantees of Origin (GOs) generated must be canceled per AIB procedure on behalf of subsidiary

Energy audits

All largest and most energy-intensive industrial subsidiaries have performed energy audits with external consultants.

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Resources and investment approach

For decarbonization initiatives described (PPAs, PV installations, fuel switching, supplier engagement), no major CapEx or OpEx is required for most projects. Key resource commitments include:

• Long-term PPA contracts (price commitment creating exposure to fluctuations)
• 7.1MW PV system installation at Corinth Pipeworks (under construction, mid-2025 completion)
• Feasibility studies for BESS at Corinth Pipeworks
• Three-year payback criterion for energy efficiency projects

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Governance and alignment

• Decarbonization targets and transition plans approved by top management of each subsidiary
• Aligned with Climate Change and Energy Policy
• Connected to identified negative impacts of non-renewable energy consumption and GHG emissions
• Targets consider future developments: sales volume changes, recycled content changes, mature future technologies
• Market-based method used for Scope 2 GHG emissions calculation
• No internal carbon pricing schemes applied

Targets related to climate change mitigation and adaptation

Overview

Cenergy Holdings subsidiaries have set decarbonization targets at segment level (cables and steel pipes). The targets are integrated with overall business strategy and financial planning.

Table 10: Decarbonization targets of Cenergy Holdings subsidiaries

Cables Segment (Hellenic Cables and other companies)

Target metric: Absolute GHG emissions (Scope 1 & 2 combined and Scope 3)

Near-term targets (2030):

• Scope 1 & 2: 50% reduction (absolute)
• Scope 3: 25% reduction (absolute)

Long-term targets (2050):

• Scope 1, 2 & 3: 90% reduction (absolute)

Baseline:

• Year: 2020
• Baseline values:
  • Scope 1 & 2: 53 kt CO2e
  • Scope 3: 4,221 kt CO2e
  • Total Scope 1, 2 & 3: 4,274 kt CO2e

Scope: All greenhouse gases; all facilities

Science-based validation: Targets committed to Science Based Targets initiative (SBTi). Near-term Scope 1 & 2 target tested against Absolute Contraction Approach (ACA) reduction pathway (requires 47.54% by 2030; target is 50%). Scope 3 target aligned with WB2C scenario (requires 25%). Net-zero target tested against Pathways to Net-zero – SBTi Technical Summary (Version 1.0, October 2021).

Progress to date (vs. 2020 baseline):

• Scope 1 & 2: 10.4% reduction achieved
• Scope 3: 11.8% reduction achieved
• Total emissions (Scope 1, 2 & 3): 11.8% reduction achieved

Steel Pipes Segment (Corinth Pipeworks)

Target metric: Absolute GHG emissions (Scope 1 & 2 combined and Scope 3)

Near-term targets (2030):

• Scope 1 & 2: 50% reduction (absolute)
• Scope 3: 25% reduction (absolute)

Baseline:

• Year: 2022
• Baseline values:
  • Scope 1 & 2: 19 kt CO2e
  • Scope 3: 920 kt CO2e

Scope: All greenhouse gases; all facilities

Science-based validation: Targets set for Scope 1 & 2 compatible with limiting global warming to 1.5°C in line with Paris Agreement. More ambitious than ACA reduction pathway (requires 47.54% by 2030; target is 50%). Scope 3 target aligned with WB2C scenario (requires 25%). Cannot be validated according to SBTi framework yet, as no sector-specific guidance developed for this industrial activity.

Progress to date (vs. 2022 baseline):

• Scope 1 & 2: 26.3% increase (due to increase in production)
• Scope 3: 19% reduction achieved

Key implementation measures

Cables segment:

• Power Purchase Agreements (PPAs) for renewable electricity: Two wind power PPAs signed (Q4 2024 and Q1 2025)
• Objective to entirely cover electricity needs with renewable energy
• Increased post-consumer recycled materials in products
• Partnership with supplier delivering aluminium with carbon intensity below half of global average

Steel pipes segment:

• 7.1MW photovoltaic system under construction (expected mid-2025) to cover one-third of electricity needs
• Procurement of electricity from renewable sources via PPAs starting 2025
• Replacement of fossil fuels with electricity by 2030
• Implementation of energy saving projects by 2026

Additional context

• All targets for Scope 1 and 2 emissions are combined targets (not separate per scope)
• Targets are absolute reduction targets
• Market-based method used for Scope 2 GHG emissions calculation
• Targets account for projected production growth up to 2030
• No carbon offsets used to meet targets

Energy consumption and mix

Total energy consumption and disaggregated energy mix

Cenergy Holdings reports energy consumption disaggregated by fossil, nuclear and renewable sources for both business segments (cables and steel pipes). The data covers all consolidated operations.

Table: Total energy consumption and mix (10³ MWh)

Scope and methodology:

The values include all direct and indirect employees for the companies under scope. The sectors Cenergy Holdings companies operate are considered as high-climate impact sector based on Annex I to Regulation (EC) No 1893/2006. Total energy consumption increased in both segments in 2024 compared to 2023, attributed to increased production volumes.

Renewable electricity procurement in 2024:

In 2024, Icme Ecab (cables segment) signed a renewable electricity procurement contract from hydropower to cover 100% of its electricity needs, representing approximately 25% of the electricity consumed by the cables segment. This agreement is bundled with instruments enabling energy traceability. Additionally, Fulgor and Hellenic Cables engaged in PPAs for renewable electricity from specific PV and wind farms during 2024, though GOs issuance was pending permitting resolution as of reporting date.

Certification:

Four companies (Hellenic Cables, Fulgor, Icme Ecab, Corinth Pipeworks), accounting for 99.9% of total GHG emissions, are certified with ISO 14064-1:2018 (GHG emissions monitoring) and ISO 50001:2018 (Energy Management System).

Gross Scopes 1, 2, 3 and Total GHG emissions

Overview

Cenergy Holdings reports GHG emissions for its consolidated operations, disaggregated by segment (Cables segment and Steel pipes segment). The consolidated figures encompass all industrial subsidiaries under operational control. The base year for decarbonization targets varies by segment: 2020 for the Cables segment and 2022 for the Steel pipes segment.

Scope 1 GHG emissions

Gross Scope 1 GHG emissions (direct emissions) are calculated using National Inventory Reports (NIR) emission factors for CO₂ from fuel combustion, and IPCC EFDB emission factors for CH₄ and N₂O. Scope 1 emissions are presented in CO₂e.

Percentage of Scope 1 GHG emissions from regulated emission trading schemes: 0% for all years (2022–2024).

No sub-breakdown by source (stationary combustion, mobile combustion, process emissions, fugitive emissions) is disclosed in the report.

Scope 2 GHG emissions

Scope 2 (indirect emissions from purchased energy) is reported using both location-based and market-based methods.

Location-based Scope 2

Methodology note: Emission coefficients from Table 4 (Total Supplier Mix 2023) of the AIB European Residual Mix 2023 methodology are used for Greece, Romania, and Bulgaria, as the 2024 Report was not available at the time of reporting.

Market-based Scope 2

Methodology note: Emission coefficients from Table 2 (Residual Mixes 2023) of the AIB European Residual Mix 2023 methodology are used for Greece, Romania, and Bulgaria. For Icme Ecab (cables segment), market-based Scope 2 emissions are zero due to a bilateral contractual agreement with electrical energy providers for renewable electricity. For Fulgor and Hellenic Cables (cables segment), zero-emission factors are applied for electricity procured via Power Purchase Agreements (PPAs) from specific PV and wind farms (permitting issues were being resolved at year-end 2024 for issuance of Guarantees of Origin). Remaining electricity consumption follows the residual mix methodology.

Scope 3 GHG emissions

Scope 3 (indirect value chain emissions) are calculated following the GHG Protocol. Cenergy Holdings reports 8 out of 15 categories, representing 99.9% of total Scope 3 emissions. Categories 6 (Business travel), 7 (Employee commuting), 8 (Upstream leased assets), 10 (Processing of sold products), 13 (Downstream leased assets), 14 (Franchises), and 15 (Investments) are excluded as negligible.

Primary data were used for Category 1 (Purchased goods and services) where feasible, with suppliers and customers engaged to identify suitable emission factors. Where direct engagement was not feasible, emission factors were sourced from Defra, Ecoinvent, and other reliable sources (e.g. International Aluminium Association, International Copper Association, IEA reports).

Note: Category 11 (Use of sold products) is applicable only to the Cables segment.

Total GHG emissions and Intensity

Note: 2022 total GHG emissions include only Scope 1 and Scope 2; Scope 3 was first calculated in 2023.

Decarbonization targets (baseline and target years)

Cables segment (Hellenic Cables & others):

• Base year: 2020
• 2030 targets: −50% Scope 1&2 (combined), −25% Scope 3 (Science Based Targets initiative validated)
• 2050 net-zero target: −90% Scope 1,2,3 GHG emissions (SBTi net-zero standard)
• Progress as of 2024: −10.4% Scope 1&2, −11.8% Scope 3, −11.8% total emissions (vs. base year 2020)

Steel pipes segment (Corinth Pipeworks):

• Base year: 2022
• 2030 targets: −50% Scope 1&2 (combined), −25% Scope 3
• 2050 net-zero target: Not yet set (SBTi validation pending sector-specific guidance)
• Progress as of 2024: +26.3% Scope 1&2 (due to production increase), −19% Scope 3 (vs. base year 2022)

Regulated emissions (EU ETS)

No Cenergy Holdings company falls under the EU Emissions Trading System (EU ETS). The percentage of Scope 1 emissions from regulated emission trading schemes is 0% for all reporting years.

Biogenic CO₂ emissions

Not disclosed. Fuel consumption from renewable biomass is reported as 0 MWh for all years (2022–2024).

Certification and assurance

Four companies (Hellenic Cables, Fulgor, Icme Ecab, Corinth Pipeworks), representing 99.9% of total GHG emissions, are certified to ISO 14064-1:2018 (GHG emissions quantification and monitoring). The same four companies are also certified to ISO 50001:2018 (Energy Management System).

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

Phase-in provisions

In this sustainability statement the company does not use the option to omit information required by ESRS.

Climate-related risks and opportunities framework

Climate change and the renewable energy transition present Cenergy Holdings and its subsidiaries with various financial risks and opportunities. To identify and manage the risks, Cenergy Holdings and its subsidiaries have implemented the TCFD framework. The framework also supports Cenergy Holdings companies to transparently communicate their management of climate-related risks and opportunities. Cenergy Holdings published its independent TCFD report in 2023. Through the implementation of TCFD framework, the subsidiaries performed a thorough evaluation of their strategy and business model against potential climate-related risks and opportunities. This includes assessing physical risks (such as extreme weather events and sea-level rise) and transition risks (such as regulatory changes and shifts in market demand). The analysis covered all relevant business operations in all geographic locations, as well as where applicable upstream and downstream value chain. The resilience analysis was conducted by using different climate scenarios to evaluate how different climate futures could impact the operations of the companies, taking into consideration the likelihood, magnitude and duration of the hazards. The insights gained from the TCFD were instrumental in evaluating climate-related risks and opportunities during the DMA exercise, with the TCFD findings informing the DMA process.

Time horizons

The cables and steel pipes segments are exposed to climate risks connected to carbon taxes and adverse weather events, and opportunities related to the development of products enabling decarbonization due to shifts in consumer preferences. The transitional risks are mainly expected in the short to medium term, meaning 0-10 years, whereas physical risks, such as adverse weather events and water availability are expected in the long term (10+ years).

Carbon Border Adjustment Mechanism (CBAM)

Note: This section is a voluntary disclosure, which is not required by ESRS, considering the outcome of the company's materiality assessment.

Carbon Border Adjustment Mechanism (CBAM) is a regulation under the "Fit for 55" scheme of the European Union's climate policy initiative. CBAM is intended to work alongside the EU Emissions Trading System (ETS), complementing its function for a transition period by placing the obligation of a carbon tax to all importers of certain high carbon intensity materials / products, two of which, aluminium and steel, are products that are produced by Cenergy Holdings subsidiaries.

Cenergy Holdings subsidiaries, producers of cables and steel pipes, are affected two-fold by the implementation of CBAM:

1. CBAM will increase operational cost as the free allowances for the ETS will gradually decrease starting in 2026 eventually reaching zero in 2034 while at the same time raw materials imported from third countries will become more expensive.
2. Competitive products from third countries will also be subject to CBAM costs provided their carbon intensity is properly documented and declared.

Currently CBAM does not provide the safeguards required to ensure proper documentation of the carbon intensity of competing products and there is great concern that declarations of carbon intensity of imported products will be underestimated due to "resource shuffling" or due to gaps in reporting and the lack of a robust methodology for calculating emissions, especially in downstream products that need to incorporate emissions from upstream embedded emissions. The circumvention of the actual emissions would result in a competitive disadvantage for European producers as they incur the entire cost of carbon emissions as free allowances are phased out.

Furthermore, aluminium is an essential component of power cables representing up to 80% of its weight in certain applications while steel may represent up to 40%. Power cables are not currently in the scope of CBAM products and is not expected to be included in 2026 when the definitive period of CBAM begins and carbon taxes will apply. It is noted that the EU Commission is currently evaluating the expansion of the list of downstream products that will be included in the scope of CBAM but this evaluation will not conclude within 2025 in time for the legislative process to be completed before 1/1/2026 when the definitive phase begins.

Mitigation strategies

Cenergy Holdings subsidiaries do not enhance natural carbon sinks or apply technical solutions to remove GHGs from the atmosphere (e.g. direct air capture) as these technologies are still not economically or technologically mature. Additionally, due to the relatively low operational carbon intensity, Cenergy Holdings subsidiaries have less exposure to carbon pricing and a much lower risk of cost exposure than primary metal producers or competitors from outside the EU with a higher carbon footprint who have exposure to CBAM costs. However, the subsidiaries are nevertheless exposed to this risk. To decrease their exposure to carbon pricing through indirect emissions, it is strategically important for Cenergy Holdings subsidiaries to have access to low-carbon or zero carbon electricity. Cenergy Holdings subsidiaries explore alternatives for direct renewable electricity supply, such as bilateral RES PPAs.

Policies related to water and marine resources

Cenergy Holdings subsidiaries recognize water as a precious natural resource and acknowledge that water resources must be conserved and maintain a good environmental status, and aquatic life must be protected.

Environmental Policy

The environmental policy addresses water and marine resources as follows:

Key principles and content:

• The subsidiaries aim at preventing and abating pollution resulting from their activities
• Enhance efficiency of water use
• Integrate advanced water treatment processes as a step towards more sustainable sourcing of water
• Focus on preventing the deterioration of water bodies and enhancing the health of aquatic ecosystems
• Commit to take into account in product design aspects regarding water-related issues and the preservation of marine resources
• Actively promote the reduction of water withdrawals and discharges
• Ensure practices align with environmental responsibilities and the well-being of affected communities

Governance:

• The responsibility for implementing the environmental policy lies with the most senior executive of each Cenergy Holdings subsidiary
• The executive ensures integration into corporate strategy and operations

Monitoring:

• Regular monitoring and reporting on water withdrawal and consumption are mandated
• Continuous efforts to mitigate negative impacts associated with water usage
• Utilize appropriate metrics such as water withdrawal, water discharge, and water consumption to evaluate regularly their performance
• Minimum level of ambition based on continuous improvement approach, drawing from previous years' performance
• Plants closely monitor water consumption to improve water intensity

Public availability:

• The environmental policy is publicly available to all Cenergy Holdings and subsidiaries' stakeholders through the company's website

Scope:

• Applies to Cenergy Holdings subsidiaries
• No policies related to sustainable oceans and seas have been adopted as impacts and relationship to sea water and ocean water is negligible

Business Partner's Code of Conduct

Key principles and content:

• Business partners are expected to look for cost-effective methods to improve water efficiency
• Minimize water consumption
• Implement relevant initiatives to reduce their water footprint

Scope:

• Applies to business partners

Actions and resources related to water

Overview

Cenergy Holdings' industrial companies, which account for the vast majority of water withdrawal and consumption, use various strategies for responsible water usage. All actions relate to the own operations of the industrial companies in all countries of operation and are carried out in production plants, most of which are located in areas of high-water stress.

Water Management Actions

The following water management actions and strategies are implemented:

• Reducing water intensity by using water conservation technologies
• Continuous monitoring of water consumption to detect leaks promptly
• Assessing water availability and adopting measures for alternative water sources in the event of water shortage
• Conducting preventive maintenance of water networks to minimize water losses
• Proper maintenance and operation of wastewater treatment plants to ensure compliance with water discharge limits
• Continuous training of wastewater treatment plant operators to enhance their skills and expertise

Specific Projects Completed/Underway

New Emulsion Evaporator (Steel Pipes Segment)

Description: Installation of a new emulsion evaporator completed.

Expected outcome: Reduction by 90% of emulsion wastes and recovery of water for potential fire extinguishing purposes.

Scope: Own operations

Time horizon: Installation completed in 2024

New Reverse Osmosis Unit

Description: A reverse osmosis unit is currently being constructed to reduce the amount of water withdrawal that is currently sourced from groundwater resources.

Scope: Own operations

Time horizon: The unit will be fully operational in 2025

Value Chain Actions

Cenergy Holdings companies promote effective methods to improve water efficiency, minimize water consumption, and relevant initiatives to reduce water footprint through the Business Partner's Code of Conduct (upstream/downstream value chain).

Geographic Scope

Actions are implemented in areas of water risk and areas of high-water stress, defined as regions where the percentage of total water withdrawn is high (40-80%) or extremely high (greater than 80%) in the Aqueduct Water Risk Atlas tool of the World Resources Institute (WRI). For industrial Cenergy Holdings companies, this relates to all installations in Greece, Bulgaria and Romania.

Resources Allocated

Financial resources: Not quantified in the disclosure.

Non-financial resources: Training programmes for wastewater treatment plant operators.

Targets

During 2024 there were no active targets set relating to water management by the subsidiaries. However, they actively track the effectiveness of the water management actions implemented.

Targets related to water

The document explicitly states:

"During 2024 there were no active targets set relating to water management by the subsidiaries."

However, the company does track water management effectiveness and has implemented specific actions:

Actions in Progress (not quantified targets)

• Steel pipes segment: Installation of a new emulsion evaporator with expected outcome of 90% reduction of emulsion wastes and recovery of water for potential fire extinguishing purposes. The unit will be fully operational in 2025.
• All actions relate to own operations in all countries of operation, particularly in production plants located in areas of high-water stress (Greece, Bulgaria, and Romania).

Scope

• Actions relate to own operations of industrial companies
• Geographic focus: production plants in Greece, Bulgaria, and Romania (areas of high-water stress)
• High-water stress areas defined as regions where percentage of total water withdrawn is high (40-80%) or extremely high (greater than 80%) per WRI Aqueduct Water Risk Atlas

No quantified water consumption or withdrawal targets with baseline years and target years are disclosed.

Water consumption

Overview

Cenergy Holdings' water consumption in 2024 increased to 305 Ml (megaliters) consolidated, compared to 163 Ml in 2023. The cables segment consumed 171 Ml (2024) vs 116 Ml (2023), while the steel pipes segment consumed 134 Ml (2024) vs 47 Ml (2023).

Water consumption by segment (Ml)

Cables segment:

• 2022: 195 Ml
• 2023: 116 Ml
• 2024: 171 Ml

The increase was primarily driven by increased production and production mix at Icme Ecab.

Steel pipes segment:

• 2022: 49 Ml
• 2023: 47 Ml
• 2024: 134 Ml

The increase was driven by two large-scale projects: (a) construction of a new cement-lined pipe coating unit, and (b) a port infrastructure project, requiring increased daily water spraying activities and outdoor pipe storage area watering.

Water consumption and water intensity (detailed metrics)

Water stress areas

All water consumption (100%) occurs in areas of water risk/high-water stress. Areas of water risk and high-water stress are defined as regions where the percentage of total water withdrawn is high (40-80%) or extremely high (greater than 80%) per the Aqueduct Water Risk Atlas tool of the World Resources Institute (WRI). For Cenergy Holdings industrial companies, this relates to all installations in Greece, Bulgaria, and Romania.

Water shortages and reserves

During 2024, none of the subsidiaries were affected by water shortages and water reserves in different geographic locations.

Methodology notes

1. Water consumption is calculated as the difference between water withdrawal and water discharge.
2. The majority of information relates to direct measurements from invoices from utility companies, as well as meters for groundwater withdrawal and discharges to water bodies. When actual information was not available or measurements were limited, appropriate estimations and extrapolations were made.
3. For non-industrial companies, the total of water withdrawal corresponds to water consumed, as discharge is considered negligible and is not calculated.
4. All metrics presented are not validated by an external body other than the assurance provider.

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

This disclosure requirement is listed in the content index table on page 89 with a reference to "Water and wastewater management" section and marked as voluntary disclosure.

The Water and wastewater management section (page 90) includes the following statement under "RISKS AND OPPORTUNITIES" heading:

"Water is an important element of Cenergy Holdings subsidiaries' production process as all of them rely on water."

The section discusses water-related risks and mitigation measures including:

• Proper infrastructure, such as adequate capacity of wastewater treatment
• Using water conservation technologies
• Adequately trained personnel
• Preventive maintenance of equipment
• Close performance monitoring to identify possible problems in water consumption and wastewater treatment

During 2024, there were no administrative fines for wastewater samples outside the range of discharge limits, neither any other fines and penalties imposed by regulators or government authorities for pollution of air, water or soil.

No quantified anticipated financial effects from water and marine resources-related impacts, risks and opportunities are disclosed.

Policies related to resource use and circular economy

Cenergy Holdings has disclosed one policy relevant to resource use and circular economy.

Environmental Policy

The Environmental Policy of Cenergy Holdings includes a distinct section which relates to circular economy and waste management.

Scope:

• Applies to all operations and business activities, regardless of the country in which each company operates
• Encompasses the entire upstream and downstream value chain of Cenergy Holdings subsidiaries

Key content and principles:

• Addresses the impacts, risks, and opportunities identified through a double materiality assessment related to circular economy and waste management
• Requires business partners to make continuous improvements for efficient resource management and for minimizing the generation of waste (through the Business Partner's Code of Conduct)

Governance:

• The responsibility for implementing the environmental policy lies with the most senior executive of each Cenergy Holdings company
• The senior executive ensures integration into corporate strategy and operations

Public availability:

• The policy is publicly available through the company's website

Implementation monitoring:

• The most senior executive of each company ensures integration into corporate strategy and operations

Actions and resources related to circular economy

Manufacturing Execution System (MES) installation at Fulgor

Description: A Manufacturing Execution System (MES) will be installed in Fulgor, a cables segment company. The system will integrate production lines and their equipment to digitize the overall process, collect, and provide all production data in real-time, enabling immediate decision-making capabilities.

Scope: Own operations (Fulgor - cables segment)

Time horizon: Medium-term - the system is estimated to be installed until 2025

Expected outcomes:

• Improve production performance by maximizing overall equipment effectiveness (OEE)
• Maximize capacity of existing production facilities
• Reduce quality defects
• Reduce material losses
• Reduce repair activities
• Significantly impact the company's competitiveness
• Enable more effective handling of any issues within the entire production and supply chain

Resources allocated: Not disclosed

General pollution prevention measures

Description: Prevention measures in chemicals storage and use have been implemented, as well as pollution prevention measures in the case of accidental incidents (spills or leaks) in the environment. Environmental incidents are closely monitored, and procedures have been developed for immediate detection, investigation, and remediation. Necessary safety measures include secondary containments and implementation of zone owners ("Landlord principle").

Scope: Own operations

Time horizon: Ongoing

Expected outcomes:

• Low probability of pollution incidents
• 83% of industrial companies are certified with Environmental Management System ISO 14001:2015

Resources allocated: Not disclosed

Continuous investments in property, plant, and equipment

Description: Continuous investments are made in property, plant, and equipment to upgrade and maintain the infrastructure, driven by current market needs and trends, and commitment to mitigate impacts to the environment.

Scope: Own operations

Time horizon: Ongoing

Resources allocated: Not disclosed (described as "continuous investments" but no amounts specified)

---

General approach: The subsidiaries continuously try to minimize their operations' environmental impact by implementing actions to optimize resource use, increase the recycled content of their products and minimize operational waste. However, during 2024, there were no active targets with regards to materials usage.

Targets related to circular economy

Cenergy Holdings explicitly states that during 2024, there were no active targets with regards to materials usage.

However, the company describes related actions in place:

Planned Action: Manufacturing Execution System (MES)

• Scope: Fulgor (cables segment company)
• Timeline: System estimated to be installed until 2025
• Objectives:
  • Improve production performance by maximizing overall equipment effectiveness (OEE)
  • Maximize capacity of existing production facilities
  • Reduce quality defects, material losses, and repair activities
• Type: Internal action, not a quantified target

The MES system will integrate production lines and equipment to digitize the overall process, collect and provide production data in real-time for immediate decision-making. This is described as impacting competitiveness and enabling more effective handling of issues within the production and supply chain, but no specific quantified targets are set.

ESRS E5-4 Resource Inflows

Overview

Cenergy Holdings subsidiaries' production model is centered on downstream metals processing. Secondary production involves remelting primary metals and recycling secondary raw materials. Downstream processing of metals refers to any activity after the initial refining or remelting of the metal, such as manufacturing components or finished products from the refined metal.

The subsidiaries also use primary metals for production purposes and other auxiliary materials such as oils, lime etc. which vary among the different segments. They do not use biological materials or biofuels. On the other hand, water is a main element of the production process of the subsidiaries.

Resource Inflows by Segment

Figure 8: Resource inflows divided by non-secondary raw material and secondary raw material per segment (10³ t)

Cables Segment

Steel Pipes Segment

Table 17: Resource inflows

Key Findings for 2024

In 2024, the total raw materials consumed for production purposes has increased in both industrial business segments, driven by the increased production. The percentage of secondary reused or recycled materials in products and materials remained at the same levels for the cables segment, compared to 2023.

It is worth mentioning that the steel pipes segment, procured in 2024 hot rolled coils, accompanied with the relevant EPDs, with high amount of steel scrap content.

All metrics presented are not validated by an external body other than the assurance provider.

Methodology Note

All data are actual and monitored through information technology systems utilized by industrial subsidiaries. The secondary raw materials include metal scrap. Additionally, other materials are included in the secondary raw materials category only if there is sufficient evidence that they have completed at least one lifecycle and are being reused or recycled.

Resource outflows

Recyclability and product design

Cenergy Holdings metals processing companies specialize in producing high-quality metal products that adhere to circular economy principles. Key products include steel pipes, power cables used in various industrial applications such as construction, automotive, utilities and oil & gas. These products are engineered for longevity and to maintain high quality and durability, all products are rigorously tested to meet specific industry standards and customer specifications.

With regards to reusability and repairability, typically the key products of Cenergy Holdings companies are not being reused or repaired after their first lifecycle, while disassembly and remanufacturing of semi-finished products depends on the design features of the final products by the customers.

While recycling is a core practice and generally the products could reach up to 100% recyclability, the actual recycling rate is highly dependent on the use of the products in downstream operations and in other downstream products that may require disassembly upon completion of their life cycle. The actual recycling rate mostly relates to how easily the final product can be collected and sorted to its separate materials after its life cycle is completed, and whether there are robust collection schemes in place.

The only products that have a low recycling rate are the products that due to their particular use; it is not cost effective to be collected after their useful lifetime. These products are submarine cables and steel pipes that are installed in land or offshore.

Product lifetime

The life cycle of Cenergy Holdings subsidiaries' products is typically from some decades for steel pipes and half a century for construction steel and power cables.

Design considerations

The subsidiaries continuously try to minimize their operations' environmental impact by implementing actions to optimize resource use, increase the recycled content of their products and minimize operational waste. A Manufacturing Execution System (MES) will be installed in Fulgor (cables segment company), estimated to be installed until 2025, to improve production performance by maximizing overall equipment effectiveness (OEE) and reducing quality defects, material losses, and repair activities.

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

Risks

While the subsidiaries are well-positioned to embrace the circular economy, the transition to a circular economy also brings financial risks. Among these, there are risks related to the limited availability of scrap metals, and increased competition for scrap supply as secondary raw materials are among the strongest levers for decarbonizing metals production. This situation may lead to increased prices for such materials and difficulty in obtaining and having access to adequate supplies.

The Companies have an indirect dependency on secondary raw materials in the short, medium and long-term, because even though they could theoretically use only primary sources, they wouldn't meet customers growing expectations for increased recycled content in the products, a key sustainability attribute. A shortage of affordable scrap materials could increase production costs and affect the companies' cash flows without however severely affecting profit margins.

Additionally, using low-quality scrap metal in recycling can be a risk factor for companies, as it can adversely affect energy and water consumption and in certain cases, can potentially lead to higher atmospheric emissions of particulate matter and other hazardous substances. This is because processing lower-quality metals requires more resources and may increase emissions and waste production. However, these risks were not considered as material from a financial perspective through the double materiality assessment, and in addition they are proactively addressed by diligent monitoring of scrap qualities, sorting equipment and/or manual sorting of various scrap categories, thermal metallurgy modifications for impurity removals, and modifications in the mechanical processing of the products to accommodate for different qualities of alloyed metals.

With regards to waste management, potential risks associated with environmental permit violation related to waste management could lead to fines and penalties, directly affecting the companies' financial position. Non-compliance with waste management regulations might result in significant financial penalties, reducing the funds available for operational needs, reinvestment, or growth initiatives. However, the magnitude and likelihood of such risks occurring is relatively low, and in addition the companies have developed efficient waste management techniques following best practices.

Waste

Waste generation and management approach

The companies follow a waste management strategy which allows them to maintain high rates for waste recycled and recovered and contribute to the mitigation of relative impacts to the environment. The subsidiaries collaborate with specialized contractors who are appropriately licensed according to current legislation. This ensures effective waste management and compliance with relevant laws and regulations by the companies. Furthermore, there are subsidiaries that specialize in processing specific types of waste in order to achieve higher recycling rates and the production of by-products, which are used in various applications by other industries, such as the cement industry, actively and decisively contributing to the circular economy.

Waste volumes increased in both segments, following the production, however both segments are not considered as waste-intensive. There is no radioactive waste generated by any subsidiary.

The main waste streams from the industrial activity of the segments are mainly packaging, emulsions, welding waste (flux) and slags. The main materials that are present in the waste are metal particles, oils, and wood, plastic or cardboard containers for packaging.

Waste data by management method (2024)

Waste diversion performance

The portion of the generated waste that is diverted from disposal for both segments remained at high levels in 2024, supporting the transformation to a circular economy. In 2024, the cables segment achieved 87.8% waste diverted from disposal, while the steel pipes segment achieved 99.4%, resulting in a consolidated figure of 94.4% diverted from disposal.

Policies related to own workforce

Labor and Human Rights Policy

Cenergy Holdings has adopted a Labor and Human Rights Policy that applies to all subsidiaries.

Scope:

• All operations and business activities, regardless of the country in which each company operates
• The entire upstream and downstream value chain of Cenergy Holdings subsidiaries

Governance:

• Approval and responsibility for implementing this Policy lies with the most senior executive responsible for each Cenergy Holdings company
• These executives ensure that labour and human rights considerations are fully integrated into corporate strategy and operations, with regular oversight by the Board of Directors

Key content / principles:

• Zero-tolerance policy towards any violations of labour and human rights
• Alignment with international standards: Universal Declaration of Human Rights and International Labor Organization (ILO) conventions
• Non-discrimination and equal opportunities based on performance and qualifications
• Elimination of discrimination through specific procedures
• Support for freedom of association and collective bargaining
• Strict prohibition of forced and child labour, adhering to minimum age requirements
• Respectful, harassment-free workplace where any form of harassment or bullying is actively investigated and addressed
• Fair working conditions including transparent employment contracts and fair wages that meet or exceed legal requirements
• Adequate wage in accordance with applicable laws, with competitive compensation packages that go beyond mere compliance
• Social protection coverage for all employees against major life events (sickness, unemployment, employment injury, acquired disability, parental leave, and retirement)
• Private insurance and pension scheme offered to select employees based on role and seniority
• Commitment to provide training to all employees and ensure equality of access to development and education opportunities
• Explicit prohibition of trafficking, forced labor and child labor
• Whistleblowing mechanism available through Business Code of Conduct for employees to report violations

Public availability:
The Labor and Human Rights Policy is publicly available through Cenergy Holdings' website at https://cenergyholdings.com/policies/

Links to international standards:

• Universal Declaration of Human Rights
• International Labor Organization (ILO) conventions and ILO Declaration on Fundamental Principles and Rights at Work
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises

Monitoring implementation:

• Human rights due diligence (HRDD) process adopted in 2023 for internal operations, continued implementation in 2024
• Human Rights Officer assigned at each subsidiary to coordinate and conduct Human Rights Impact Assessment (HRIA)
• HRIA covers health and safety, labour rights, community impacts, employment practices, anti-bribery corruption and security
• Risks evaluated against pre-defined criteria with prioritization of most salient risks
• Remediation action plans introduced with training initiatives
• Monitoring of implementation of action plans to ensure remediation
• Annual monitoring and reporting on human rights impacts
• Engagement with stakeholders to address concerns
• Training programs in place to raise awareness
• Employee satisfaction survey conducted in 2024 across all companies

Business Code of Conduct

Cenergy Holdings has adopted a Business Code of Conduct that applies to all subsidiaries.

Scope:

• All Cenergy Holdings subsidiaries' employees
• Covers comprehensive range of topics including corporate values, ethical guidelines, anti-corruption measures, social responsibility, human rights, and environmental protection

Key content / principles:

• Outlines expected behaviors from all employees
• Articulates rules of conduct and how business is conducted
• Takes into consideration interests of stakeholders
• Includes whistleblowing mechanism through Integrity Hotline (publicly accessible platform on corporate websites, by phone or email)
• Protection from reprisals or retaliation for individuals reporting in good faith, in accordance with Directive (EU) 2019/1937

Links to international standards:

• United Nations Convention against Corruption

Monitoring implementation:

• Employee training on business ethics, Code of Conduct, and anti-corruption
• HR departments coordinate roll out of sustainability trainings
• Close monitoring of completion rates for training courses
• Whistleblowing mechanism to report illegal behavior
• Every report investigated promptly, independently and objectively by specially appointed and adequately trained senior executives
• Independent internal audit monitors illegal behavior and potential improper behavior

Business Partners' Code of Conduct (Supplier Code of Conduct)

While primarily focused on upstream value chain, the Business Partners' Code of Conduct establishes expectations that indirectly protect own workforce.

Key content / principles relevant to own workforce:

• Sets expectations for suppliers, contractors, consultants, and business associates to align with Cenergy Holdings' core values
• Emphasizes respecting internationally recognized human rights
• References ILO Declaration on Fundamental Principles and Rights at Work
• References OECD Guidelines for Multinational Enterprises

Public availability:
Publicly available through Cenergy Holdings and subsidiaries' websites

Occupational Health and Safety Policy

Cenergy Holdings has adopted an Occupational Health and Safety Policy that applies to all subsidiaries.

Scope:

• All operations and business activities, regardless of the country in which each company operates
• The entire upstream and downstream value chain of Cenergy Holdings subsidiaries
• All employees and partners, including customers, suppliers, contractors, and visitors

Governance:

• Responsibility for implementing the policy lies with the most senior executive of each Cenergy Holdings company
• Policy integration into corporate strategy and operations

Key content / principles:

• Ultimate goal: "No accident and no occupational illness"
• Foster a preventive culture
• Strict compliance with Health and Safety standards
• Assess and mitigate risks
• Report incidents thoroughly
• Communicate openly
• Prioritize training
• Ensure safe working conditions
• Continually improve Health and Safety performance
• Provide safe and healthy working conditions, including adequate facilities, tools, and protective measures
• Minimize occupational injuries and illnesses
• Promote risk prevention culture where all injuries and work-related illnesses can and must be prevented
• Comprehensive risk assessment framework for all significant risks to health and safety
• Transparent engagement with all stakeholders regarding Health and Safety issues
• Continuous Health and Safety training programs, fostering skill development and knowledge-sharing

Public availability:
Publicly available through Cenergy Holdings' website

Links to international standards:

• OECD Guidelines for Multinational Enterprises
• International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work

Monitoring implementation:

• Health and Safety coordinators at all subsidiaries and dedicated subcommittees
• 83% of production companies certified with ISO 45001:2018 (Occupational Health and Safety Management System)
• Management system covers 97.8% of total workforce
• Monthly updates on KPIs including safety audits, near misses, corrective action closure rates, training effectiveness
• Regular performance reviews
• Leading and lagging KPIs tracked (training completion rates, safety audit scores, reported unsafe conditions, near misses, incident rates, severity rates)
• Goal setting and review processes
• Annual improvement action plan (IAP) with specific targets
• External auditors conduct annual reviews during management system certification reviews
• Semi-annual business reviews involving executive management

Environmental Policy

The Environmental Policy includes a section on circular economy and waste management that relates to own workforce operations.

Key content / principles:

• Manage all waste responsibly in accordance with applicable laws
• Apply circular economy principles
• Focus on reducing waste generation and enhancing recycling and energy recovery efforts
• Proactive measures to prevent environmental harm during storage of hazardous wastes
• Regular monitoring and reporting on use of materials and waste management

Governance:

• Responsibility for implementing the environmental policy lies with the most senior executive of each Cenergy Holdings company

Public availability:
Publicly available through Cenergy Holdings' website

Energy and Climate Change Policy

The Energy and Climate Change Policy addresses impacts related to climate change and energy.

Key content / principles:

• Climate change mitigation and adaptation
• Energy efficiency
• Deployment of renewable energy sources (RES)
• Responsible, efficient, and cost-effective energy purchasing and use to reduce carbon footprint
• Examination of gradual replacement of electricity supply with RES
• Robust climate and vulnerability risk assessments
• Cost-effective methods to improve energy efficiency, minimize energy consumption, and promote decarbonization initiatives

Links to international standards:

• Paris Agreement
• Sustainable Development Goals #7 and #13

Monitoring implementation:

• Compliance with mandatory reporting frameworks for transparent disclosure of GHG emissions, energy consumption, and climate-related risks

Responsible Sourcing Policy

The Responsible Sourcing Policy was developed in 2024 and includes aspects relevant to own workforce.

Scope:

• All Cenergy Holdings companies and their related functions, including procurement, sustainability, and legal departments, regardless of country of operation
• All suppliers, contractors, agents, and business partners within the upstream value chain

Governance:

• Responsibility lies with the most senior executives at each Cenergy Holdings company
• Ensuring governance structures are in place to monitor and enforce compliance

Key content / principles:

• Integrate environmental, social, ethical, and economic criteria into procurement processes
• Create shared value for society
• Manage supply chain risks
• Economic inclusion by promoting opportunities for small and local businesses
• Employee awareness ensured for all relevant employees
• Risk-based approach prioritizing areas with highest risks
• Specific focus on conflict minerals
• Training and awareness programs for procurement and supply chain workforce

Links to international standards:

• OECD Due Diligence Guidance for Responsible Business Conduct
• EU Conflict Minerals Regulation
• UK Modern Slavery Act

Monitoring implementation:

• Sustainability Due Diligence procedure for Business Partners developed in 2024
• Supplier evaluation through EcoVadis platform
• Supplier prioritization and ABC classification based on strategic importance and cost spend
• Preliminary assessment based on country and industry risk
• Continuous collaboration with suppliers
• Corrective actions for non-compliance

Taking action on material impacts on own workforce

Human Rights Due Diligence

Action: Implementation of Human Rights Due Diligence Process for Own Operations

• Scope: Own operations
• Time horizon: Short-, medium-, long-term (implemented 2022-2024)
• Description: Following a Minimum Safeguards gap assessment in 2022, subsidiaries have implemented a four-step due diligence process: (1) identification and assessment of actual and potential impacts, (2) implementing measures to prevent and mitigate impacts, (3) tracking effectiveness of measures, and (4) reporting on how impacts are being addressed
• Governance: All subsidiaries have assigned a dedicated Human Rights Officer responsible for coordinating and conducting Human Rights Impact Assessment (HRIA) covering health and safety, labour rights, community impacts, employment practices, anti-bribery corruption and security
• Expected outcomes: Remediation of identified gaps, implementation of monitoring procedures to mitigate negative human rights impacts
• Link to policy: Labour and Human Rights Policy, Business Partners' Code of Conduct, aligned with OECD Guidelines for Multinational Enterprises and UN Guiding Principles
• Resources (non-financial): Dedicated Human Rights Officer at each subsidiary
• Targets: No quantitative targets set for 2024. Companies are monitoring implementation and roll-out of relevant policies, procedures and risk assessments

Employee Engagement and Satisfaction

Action: Employee Satisfaction Survey 2024

• Scope: Own operations (all Cenergy Holdings companies)
• Time horizon: Short-term (conducted in 2024)
• Description: Survey conducted across all companies to understand employee experiences and opinions, identify areas for improvement, and develop future action plans to enhance work environment
• Expected outcomes: Enhanced employee engagement, improved work environment, open communication and trust between employees and management

Occupational Health and Safety Programs

Action: Health and Safety Improvement Action Plan (IAP) 2024

• Scope: Own operations
• Time horizon: Short-term (2024)
• Description: Comprehensive action plan covering multiple safety initiatives including:
  • Lockout/Tagout (LoTo) programs
  • Machinery Safety improvements
  • Working at Heights (WaH) programs
  • Emergency response improvements
  • Fire safety improvements
  • Hazop studies
• Resources (financial): Dedicated budget allocated for risk mitigation, training, and employee well-being. Funds allocated for critical safety programs, infrastructure improvements, and training initiatives (specific amounts not disclosed)
• Resources (non-financial): Health and Safety coordinators at all subsidiaries and dedicated subcommittees at each plant; Health and Safety experts from Steelmet SA oversee incident investigations
• Targets for 2024:
  • 100% budget implementation by year-end
  • 100% safety training compliance, tailored to risk assessments for each role
  • 80% completion of machinery safety implementation studies
  • 60% installation of mechanical guarding on machinery
  • 100% use of Permit to Work (PTW) for working at heights
  • 100% implementation of working at heights standards
  • 100% advanced training on lockout/tagout procedures
  • 100% safety guidelines implementation for forklift operators
• Progress 2024: Cables and steel pipes segments achieved over 95% overall performance rate in implementing planned safety initiatives, with majority of targets fully met
• Link to policy: Energy and Climate Change Policy, Business Code of Conduct, Labour and Human Rights Policy
• KPIs monitored: Monthly monitoring of safety audits, near misses, corrective action closure rates, training effectiveness, incident rates, severity rates, training completion rates, safety audit scores, reported unsafe conditions

Action: Safety Incentive Program (Corinth Pipeworks)

• Scope: Own operations (Corinth Pipeworks)
• Description: Program to incentivize safety improvement ideas from employees, fostering culture of continuous improvement

Action: Safety Leadership Framework

• Scope: Own operations
• Description: Comprehensive training programs to enhance safety knowledge and leadership in collaboration with Health and Safety coordinators; includes skill matrix to assess and improve leaders' safety management competencies
• Resources (non-financial): Health and Safety coordinators providing training and guidance to leaders

Training and Development Programs

Action: Employee Training and Development Programs

• Scope: Own operations
• Time horizon: Ongoing
• Description: Comprehensive training to all employees with appropriate learning paths based on individual needs, tailored to specific roles and areas of influence; focus on continuous improvement
• Expected outcomes: Elevated understanding of human rights practices, enhanced employee performance and job satisfaction, improved retention rates and productivity
• Link to policy: Labour and Human Rights Policy commitment to providing training and ensuring equality of access to development and education opportunities
• Targets: No quantitative targets on subsidiary level. Each subsidiary drafts appropriate training plan for each job description and monitors implementation with target of fulfilling each training plan
• KPIs: Completion rate of training program
• Training metrics:
  • Health and safety training hours per employee (cables segment): 13.1 hours (2022), 15.5 hours (2023), 23.7 hours (2024) - 32% increase
  • Health and safety training hours per employee (steel pipes segment): 4.5 hours (2022), 5.0 hours (2023), 3.4 hours (2024)
  • Average training hours per direct employee increased in cables segment

Action: Business Ethics and Anti-Bribery/Corruption Training

• Scope: Own operations
• Time horizon: Ongoing (implemented as part of Sustainability Strategy)
• Description: Training on business ethics, anti-bribery and corruption targeting management and employees with high-risk job profiles; dedicated sessions for management team covering money laundering, antitrust and competition laws, anti-corruption, and data privacy
• Expected outcomes: Increased knowledge and competence on human rights and responsible business conduct
• Link to policy: Business Code of Conduct

Reporting Mechanisms

Action: Integrity Hotline

• Scope: Own operations and value chain
• Time horizon: Ongoing
• Description: Anonymous reporting mechanism available on corporate website, by phone, or via email for reporting suspected inappropriate or illegal activities related to human rights violations; protected from retaliation in line with Directive (EU) 2019/1937
• Governance: Reports investigated by trained senior executives who take direct action if necessary
• Outcomes 2024: No validated human rights incidents reported

Health and Safety Management System

Action: ISO 45001:2018 Certification

• Scope: Own operations
• Coverage: 83% of production companies certified; Health and Safety Management System covers 97.8% of total workforce (direct and indirect employees)
• Link to policy: Occupational Health and Safety commitments

Characteristics of the undertaking's employees

Total headcount and FTE

The total workforce (direct and indirect employees) for Cenergy Holdings:

Segment breakdown:

Cables segment:

• Total direct and indirect employees: 2,201 (2022), 2,476 (2023), 2,837 (2024)
• Direct employees: 2,058 (2022), 2,361 (2023), 2,667 (2024)
• Indirect employees: 143 (2022), 115 (2023), 170 (2024)

Steel pipes segment:

• Total direct and indirect employees: 672 (2022), 791 (2023), 884 (2024)
• Direct employees: 507 (2022), 623 (2023), 763 (2024)
• Indirect employees: 165 (2022), 168 (2023), 121 (2024)

Headcount by gender

Consolidated figures:

Cables segment:

• Direct employees male: 1,793 (2022), 2,040 (2023), 2,304 (2024)
• Direct employees female: 265 (2022), 321 (2023), 363 (2024)
• Indirect employees male: 130 (2022), 115 (2023), 170 (2024)
• Indirect employees female: 13 (2022), 0 (2023), 0 (2024)

Steel pipes segment:

• Direct employees male: 462 (2022), 554 (2023), 672 (2024)
• Direct employees female: 45 (2022), 69 (2023), 91 (2024)
• Indirect employees male: 145 (2022), 140 (2023), 87 (2024)
• Indirect employees female: 20 (2022), 28 (2023), 34 (2024)

Headcount by contract type

Direct employees by contract duration and gender (consolidated):

Cables segment:

• Permanent male: 1,788 (2022), 2,034 (2023), 2,298 (2024)
• Permanent female: 265 (2022), 321 (2023), 362 (2024)
• Temporary male: 5 (2022), 6 (2023), 6 (2024)
• Temporary female: 0 (2022), 0 (2023), 1 (2024)

Steel pipes segment:

• Permanent male: 450 (2022), 516 (2023), 601 (2024)
• Permanent female: 39 (2022), 60 (2023), 81 (2024)
• Temporary male: 12 (2022), 38 (2023), 71 (2024)
• Temporary female: 6 (2022), 9 (2023), 10 (2024)

Employee turnover

Direct employee turnover (consolidated):

By segment:

Cables segment:

• Employees who left: 366 (2022), 402 (2023), 456 (2024)
• Turnover rate: 17.8% (2022), 17.0% (2023), 17.1% (2024)

Steel pipes segment:

• Employees who left: 71 (2022), 54 (2023), 111 (2024)
• Turnover rate: 14.0% (2022), 8.7% (2023), 14.5% (2024)

Additional diversity metrics (voluntary disclosure)

Direct employees by age group (consolidated):

Gender balance in top management 2024 (consolidated):

• Male: 114 (89.8%)
• Female: 13 (10.2%)
• Total: 127

Methodology notes

Direct employees include full and part-time employees with permanent or fixed-term contracts, wages-paid, salaried, interns/trainees, Board Members, freelancers, or consultants with contracts through external companies covering permanent needs. Headcount includes all employees regardless of maternity leave, long-term absence, unpaid leave. Indirect employees (non-employees) are not paid through company payroll but through third-party providers covering fixed and permanent needs on a mandays/manhours basis.

The number of both direct and indirect employees is calculated as a monthly average of headcount, then averaged across all months.

Employee turnover = (employees who leave the organization voluntarily or due to dismissal, retirement, or death in service)/Total employees × 100. Calculations include only direct employees.

Top management scope covers Senior Managers, Directors, Senior Directors and C-level executives.

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

Number and breakdown of non-employee workers

Cenergy Holdings reports on indirect employees ("non-employees" as defined in ESRS guidelines) who are not paid through company payroll but through a third-party provider, covering fixed and permanent needs. The contract with the third-party provider/contractor is agreed on mandays/manhours basis, not on a project basis.

Total non-employee workers by segment and gender:

Methodology

Counting methodology: The number of indirect employees is calculated as a monthly average of the headcount, which is then averaged across all months.

Definition of non-employees: Indirect employees (non-employees) are those not paid through company payroll or any other method, but through a third-party provider covering fixed and permanent needs. The contract with the third-party provider/contractor is agreed on mandays/manhours basis, not on a project basis.

Scope: The values include all non-employees for the companies under scope, spanning both the cables and steel pipes segments.

Multi-year comparison

At the consolidated level, total non-employee workers decreased from 308 in 2022 to 283 in 2023, then increased slightly to 291 in 2024.

In the cables segment, non-employee headcount declined from 143 in 2022 to 115 in 2023, then increased to 170 in 2024. Notably, female non-employees in cables dropped to zero in 2023-2024.

In the steel pipes segment, non-employee headcount remained relatively stable (165 in 2022, 168 in 2023, 121 in 2024), with a notable decrease in 2024.

Diversity metrics

Age distribution of direct employees

The following table shows the age distribution of direct employees by segment:

Gender balance in top management

The scope covers Senior Managers, Directors, Senior Directors and C-level executives.

2024 Gender balance in top management (% male/female):

Gender balance of direct employees in top management (absolute numbers and percentages):

Note: This section is a voluntary disclosure, which is not required by ESRS, considering the outcome of the company's materiality assessment.

Adequate wages

Cenergy states that "all employees receive an adequate wage in accordance with the applicable laws of each country." The companies ensure that wages meet legal standards and are aligned with relevant industry benchmarks. They offer competitive compensation packages that go beyond mere compliance, and "in most cases, the wages provided are above the minimum required by law."

All employees are covered by social protection in accordance with the applicable laws of each country, including protection against major life events such as sickness, unemployment, employment injury, acquired disability, parental leave, and retirement. The companies also offer private insurance and a pension scheme to select employees based on their role and seniority.

Benchmark used: No living wage benchmark is disclosed. The company references compliance with "applicable laws of each country" and "relevant industry benchmarks" without specifying living wage standards.

Coverage: All employees (100% of own workforce) are stated to receive wages in accordance with applicable laws.

Methodology: Not disclosed. No information on how adequacy is assessed beyond legal compliance and industry benchmarks.

Value chain: The Business Partners' Code of Conduct requires business partners to align with UN Guiding Principles on Business and Human Rights and ILO Declaration on Fundamental Principles and Rights at Work, and mandates that partners "ensure acceptable living conditions," though no specific living wage assessment or benchmark is disclosed for the supply chain.

Social protection

Coverage of employees

All companies' employees are covered by social protection in accordance with the applicable laws of each country. This coverage includes protection against major life events such as:

• Sickness
• Unemployment
• Employment injury
• Acquired disability
• Parental leave
• Retirement

Coverage: 100% of employees covered by social protection in accordance with applicable laws of each country.

Type of scheme: Public schemes (mandatory social protection as per applicable laws in each country) and private schemes (for select employees).

Additional private benefits

In addition to mandatory social protection, the companies offer private insurance and a pension scheme to select employees based on their role and seniority. These additional benefits provide enhanced security and support.

Defined benefit plans

Employees of the Company's subsidiaries in Greece and Bulgaria are entitled to receive a lump sum when they retire. This lump sum is determined in accordance with the years of service and the salary at the retirement date. These plans are unfunded.

Net defined benefit liability movement:

Geographic scope: Defined benefit retirement plans apply to employees in Greece and Bulgaria.

Training and skills development metrics

Average training hours per direct employee

The total training hours both in absolute and relative terms (training hours per employee) increased in the cables segment while the steel pipes segment saw a decrease, to reach more typical levels after the great increase observed in 2023.

Figure 18: Average training hours per direct employee

Training hours by gender

Table 27: Training hours of direct employees per gender

Performance and career development reviews

With regards to the employees that participated in regular performance and career development reviews, both segments displayed high coverage. The performance and career development reviews are conducted annually, and it relates to one performance review per year per eligible employee.

Table 28: Percentage of employees that participated in regular performance and career development reviews

Note: Relates to white-collar employees for the performance and career development reviews, completed during 2024 for the performance of 2023. The information is presented only for 2024 as this was the first year of implementation of the employee grading system.

Health and safety training

In the graph below, the health and safety training hours per employee per segment are presented. The cables segment saw an increase by 32%, while the steel pipes segment saw a decrease.

Figure 14: Health and safety training hours per employee per industrial segment

Health and safety metrics

Coverage of health and safety management system

83% of production companies within the scope of this report are certified with the Occupational Health and Safety Management System ISO 45001:2018. The Health and Safety Management System covers 97.8% of total workforce working within each companies' territory, regardless of being direct or indirect employees.

Work-related accidents and fatalities

Table: Work-related accidents and number of days lost to work-related injuries

Note: The information includes both direct and indirect employees. The accident rate is calculated by dividing the respective number of cases by the number of total hours worked and multiplied by 1,000,000.

Fatalities: There were no fatalities as a result of work-related injuries or work-related ill health in 2024.

Recordable work-related ill health: There were no cases of recordable work-related ill health in 2024, subject to legal restrictions on the collection of data.

Injury frequency rates

Lost Time Injury (LTI) rate (number of LTI incidents per million working hours):

Total Recordable Injury Frequency (TRIFR) rate (number of TRI incidents per million working hours):

Severity rate (number of lost workdays per million working hours):

Compensation metrics

Pay gap

Not disclosed.

Remuneration ratio

The remuneration ratio, as defined by Section 3:6 of the BCCA, was 7.63x for 2024.

Methodology

For the calculation of the remuneration ratio, the Company used:

• Numerator: The remuneration of the CEO as the highest paid management member
• Denominator: The remuneration of the full-time employee of the holding company who has worked for a full year as the lowest paid employee

The Company notes that publishing of this ratio is a practice required by law and the presentation adopted is intended to comply with transparency requirements. The disclosure on this ratio will be assessed and evaluated in the future subject to the evolution of the ratio and to potential future guidance/clarifications that may be published on this requirement.

Incidents, complaints and severe human rights impacts

During 2024, no complaints were filed through channels for own workers or human rights issues, including incidents of discrimination and harassment, and no complaints or severe human rights impacts within the or the upstream value chain were reported (S1-17).

Scope note: This disclosure is voluntary and covers own operations and upstream value chain, as determined by the company's materiality assessment.

Business conduct policies and corporate culture

Cenergy Holdings has developed a comprehensive framework of policies governing business conduct across its holding company and subsidiaries. The policies apply at both the holding level and are adopted by subsidiaries at a minimum, with implementation responsibility resting with the most senior executive of each company, aligning with Cenergy Holdings' core values.

Business Code of Conduct (BCoC)

Scope: All Cenergy Holdings subsidiaries' employees

Governance: Responsibility for implementation rests with the most senior executive of each company, who ensures alignment with Cenergy Holdings' core values. The policy serves as a guiding document outlining expected behaviors from all employees.

Key content: The Business Code of Conduct outlines how Cenergy Holdings promotes corporate culture and covers:

• Corporate values and ethical guidelines
• Anti-corruption measures
• Social responsibility
• Human rights
• Environmental protection
• Guidelines for reporting illegal behaviour or behaviour contradicting the Code of Conduct

International alignment: Consistent with United Nations Convention against Corruption

Public availability: Published and posted on the companies' websites. The Code is distributed to all employees and publicly available to stakeholders through the website.

Monitoring: The Code is safeguarded through three mechanisms:

1. Employee training on specific issues (repeated every three years)
2. Reporting of incidents through the whistleblowing mechanism (Integrity Hotline)
3. Internal audit function monitoring illegal behavior and potential improper behavior and transactions

In 2024, completion rates for Business Code of Conduct training were 84.7% for the Cables segment and 93.4% for the Steel pipes segment.

Supplier Code of Conduct (SCoC) / Business Partner's Code of Conduct

Scope: All suppliers, contractors, consultants, and business associates across the entire upstream and downstream value chain of Cenergy Holdings subsidiaries

Governance: Most senior executives at each Cenergy Holdings company are responsible for ensuring that governance structures are in place to monitor and enforce compliance with responsible sourcing practices and Business Partners' Code of Conduct across the organization.

Key content: The Business Partners' Code of Conduct is a comprehensive document that sets forth expectations for all business partners to align with Cenergy Holdings' core values of ethics, sustainability, and human rights. It covers:

• Respect for internationally recognized human rights
• Equal opportunities in hiring and employment practices, prohibiting discrimination
• Respect for local communities, including land, forest, and water rights, culture, religion, and indigenous rights
• Acceptable living conditions for workers (clean water, sanitary facilities, adequate housing, medical services)
• Prohibition of child labour and any form of forced or compulsory labour
• Treatment of employees with dignity, respect, and equality, free from harassment
• Healthy, safe, and secure work environment
• Compliance with laws regarding maximum working hours, wages, and benefits
• Support for rights of employees to join or not join labour unions
• Measures to ensure no conflict minerals are used in supply chains
• Cost-effective methods to improve energy efficiency and minimize energy consumption
• Promotion of decarbonization initiatives to reduce direct and indirect GHG emissions
• Continuous improvements for efficient resource management and minimizing waste generation

International alignment:

• UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises

Public availability: The document is requested to be signed off by material Business partners and is publicly available through Cenergy Holdings and Cenergy Holdings subsidiaries' websites (https://cenergyholdings.com/policies/)

Monitoring: Suppliers are required to sign off on the Code of Conduct. The companies use a whistleblowing mechanism (Integrity Hotline) that allows stakeholders to report concerns about behaviour contradicting the Business Partner's Code of Conduct. Collaboration with external consultant EcoVadis to assess sustainability performance in the supply chain based on environmental, labour and human rights, ethics, and responsible procurement criteria.

Labor and Human Rights Policy

Scope: All operations and business activities, regardless of the country in which each company operates, encompassing the entire upstream and downstream value chain. Adopted by all Cenergy Holdings companies.

Governance: Approval and responsibility for implementing this Policy lies with the most senior executive responsible for each Cenergy Holdings company. These executives ensure that labour and human rights considerations are fully integrated into corporate strategy and operations, with regular oversight by the Board of Directors.

Key content: The policy reflects a zero-tolerance approach towards any violations and includes:

• Promotion of non-discrimination and equal treatment
• Support for freedom of association and collective bargaining
• Strict prohibition of forced and child labour
• Maintenance of a respectful, harassment-free workplace
• Provision of fair working conditions with transparent employment contracts
• Fair wages that meet or exceed legal requirements
• Prioritization of health and safety of employees
• Whistleblowing mechanisms for reporting violations
• Explicit inclusion of trafficking, forced labor and child labor

International alignment:

• Universal Declaration of Human Rights
• International Labor Organization (ILO) conventions
• UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises

Public availability: Available through the company's website (https://cenergyholdings.com/policies/)

Monitoring:

• Human rights due diligence (HRDD) process implemented in 2023 for internal operations, continued in 2024
• All subsidiaries have assigned a dedicated Human Rights Officer
• Human Rights Impact Assessment (HRIA) covering health and safety, labour rights, community impacts, employment practices, anti-bribery corruption and security
• Risk assessments across operations and supply chains
• Annual monitoring and reporting on human rights impacts
• Engagement with stakeholders to address concerns
• Training programs for all employees
• Integrity Hotline for reporting with no retaliation scheme

Sustainability Policy

Scope: All operations and business activities of Cenergy Holdings companies

Key content: Includes distinct sections relating to circular economy and waste management, energy and climate change mitigation, health and safety

Public availability: Publicly available to all Cenergy Holdings and subsidiaries' stakeholders through the company's website

Environmental Policy

Scope: All operations and business activities, regardless of the country in which each company operates, encompasses the entire upstream and downstream value chain of Cenergy Holdings subsidiaries

Governance: Responsibility for implementing the environmental policy lies with the most senior executive of each Cenergy Holdings company, who ensures its integration into corporate strategy and operations

Key content: The Environmental Policy has a distinct section relating to circular economy and waste management, addressing:

• Responsible management of resources (including metals, chemicals, and wastewater disposal)
• Application of circular economy principles
• Focus on reducing waste generation and enhancing recycling and energy recovery efforts
• Operational waste management by circular economy principles
• Proactive measures to prevent environmental harm during storage of hazardous wastes
• Regular monitoring and reporting on use of primary and secondary materials and waste management
• Continuous efforts to increase secondary materials consumption and reduce waste generations

International alignment: References compliance with international climate-related frameworks such as the Paris Agreement and Sustainable Development Goals #7 and #13

Public availability: Publicly available to all Cenergy Holdings and subsidiaries' stakeholders through the company's website

Monitoring:

• Business partners expected to make continuous improvements for efficient resource management through the Business Partner's Code of Conduct
• Regular monitoring and reporting mandated
• External auditors conduct annual reviews of environmental practices during management system certification reviews
• 83% of industrial subsidiaries (5 out of 6) certified with Environmental Management System ISO 14001:2015

Responsible Sourcing Policy

Scope: All Cenergy Holdings companies and their related functions, including procurement, sustainability, and legal departments, regardless of the country of operation. Extends to all suppliers, contractors, agents, and business partners within the upstream value chain.

Governance: Responsibility for implementing the policy lies with the most senior executives at each Cenergy Holdings company. They are responsible for ensuring that governance structures are in place to monitor and enforce compliance with responsible sourcing practices and Business Partners' Code of Conduct across the organization.

Key content: The policy is designed to integrate environmental, social, ethical, and economic criteria into the companies' procurement processes, ensuring all collaborations with suppliers are sustainable and responsible. Key principles include:

• Embedding environmental, social, and ethical considerations into supplier selection
• Working collaboratively with suppliers to improve standards
• Promoting economic inclusion by supporting small and local businesses
• Inclusive supplier selection processes contributing to local economic development
• Recognizing and respecting suppliers' own standards when aligned with Cenergy Holdings' expectations
• Using commercial influence to encourage improvements in suppliers' sustainability performance
• Risk-based approach prioritizing areas with highest risks
• Specific focus on conflict minerals requiring suppliers to conduct due diligence
• Validation that payments will be made based on payment terms of each contract agreed bi-laterally

International alignment:

• OECD Due Diligence Guidance for Responsible Business Conduct
• EU Conflict Minerals Regulation
• UK Modern Slavery Act

Monitoring:

• Training and awareness programs for procurement and supply chain workforce
• Suppliers' Due Diligence Procedure issued in 2024
• Collaboration with EcoVadis platform for supplier sustainability assessments
• Target to assess suppliers covering either 90% of money spend or top 20 suppliers per company over three-year period (2022-2024)
• Human Rights Due Diligence Framework including initial risk screening and continuous monitoring

Prevention and detection of corruption and bribery

Business Code of Conduct

Key content and principles:

• Outlines how Cenergy Holdings promotes corporate culture
• Covers corporate values, ethical guidelines and anti-corruption measures
• Consistent with United Nations Convention against Corruption
• Includes guidelines for social responsibility, human rights, and environmental protection
• Establishes proper channels of reporting for anyone, either within or outside Cenergy Holdings and its subsidiaries, to report illegal behaviour or behaviour in contradiction with the Code of Conduct, regarding labour or human rights practices, environmental compliance, bribery and corruption

Links to international standards:

• United Nations Convention against Corruption

Public availability:

• Publicly accessible through the Integrity Hotline platform on the corporate websites of Cenergy Holdings and all subsidiaries with a website, by phone or email

Monitoring and implementation:

The Code is safeguarded in three different ways:

1. Employee training on specific issues: In 2024, Cenergy Holdings subsidiaries continued to provide employee training on business ethics, the Code of Conduct, and anti-corruption. HR departments coordinate the roll out of sustainability trainings throughout the year with close monitoring of completion rates. Training on Ethics and Code of Conduct is repeated every three years. Specific anti-corruption training is provided to employees in positions with potential conflicts of interest (e.g., procurement, sales, government relations).

2. Reporting of incidents through the whistleblowing mechanism: All subsidiaries have implemented a whistleblowing mechanism (Integrity Hotline) to report illegal behavior regarding labor or human rights practices, environmental compliance, and business ethics. Reports are investigated promptly, independently and objectively by specially appointed and adequately trained senior executives. Reports are entered directly to a secure portal and are available only to the independent ethics committee who evaluates the report based on the type of violation and location of the incident. Results are reported to top management. Notifications and complaints may be made anonymously in accordance with the relevant whistleblowing mechanism. Individuals reporting in good faith will not be subject to reprisals or retaliation of any kind, in accordance with the applicable law transposing Directive (EU) 2019/1937.

3. Internal audit: The function of the independent internal audit monitors closely illegal behavior and potential improper behavior and transactions.

Results:

• No corruption, bribery or data privacy breaches were reported in 2024
• No incidents were identified in any of the subsidiaries through internal audit
• Completion rate of anti-bribery and anti-corruption training: Cables segment 82.1%, Steel pipes segment 96.8% (2024)
• Completion rate of Business Code of Conduct training: Cables segment 84.7%, Steel pipes segment 93.4% (2024)

Incidents of corruption or bribery

Confirmed incidents

Cenergy Holdings subsidiaries reported zero confirmed incidents of corruption or bribery during the reporting period 2024. Specifically, the company states:

"Furthermore, no confirmed incidents of bribery or bribery, and no convictions or fines were paid due to settlements for unethical business practices or corruption."

In addition, the company notes:

"In 2024 no validated human rights incidents have been reported through the Integrity hotline related to own workforce or upstream value chain."

"No corruption, bribery or data privacy breaches were reported in 2024."

Convictions and fines

No convictions or legal decisions related to corruption or bribery were recorded. No fines were paid for violations of anti-corruption or anti-bribery laws in 2024.

Disciplinary actions

Not disclosed.

Contracts terminated

Not disclosed.

Investigation and speak-up mechanisms

Cenergy Holdings and its subsidiaries have implemented a whistleblowing mechanism through the established Integrity Hotline, which is publicly accessible on corporate websites and available by phone or email. The mechanism allows anyone, within or outside the organization, to report illegal behavior or conduct in contradiction with the Code of Conduct, including labor or human rights practices, environmental compliance, bribery, and corruption.

Key features of the mechanism:

• Anonymity: Notifications and complaints may be made anonymously, in accordance with Directive (EU) 2019/1937
• No retaliation: Individuals reporting in good faith will not be subject to reprisals or retaliation
• Secure reporting: Reports are entered directly to a secure portal accessible only to an independent ethics committee
• Investigation process: Every report is investigated promptly, independently, and objectively by specially appointed and adequately trained senior executives who consult directly when a critical indication appears
• Confidentiality: Report recipients have been trained in maintaining utmost confidence

The Code of Conduct is safeguarded through three mechanisms:

1. Employee training on business ethics, Code of Conduct, and anti-corruption
2. Reporting of incidents through the whistleblowing mechanism
3. Internal audit function monitoring illegal behavior and potential improper transactions

No incidents were identified through internal audit in any of the subsidiaries in 2024.

Anti-corruption training

Cenergy Holdings subsidiaries provided comprehensive anti-corruption and Business Code of Conduct training to employees during 2024:

• Anti-bribery and anti-corruption training completion rate: 82.1% (Cables segment), 96.8% (Steel pipes segment)
• Business Code of Conduct training completion rate: 84.7% (Cables segment), 93.4% (Steel pipes segment)

The training covers all employees, including senior management, with particular emphasis on employees in roles exposed to higher risks of corruption or conflicts of interest (e.g., procurement, sales, government relations). Training on Ethics and Code of Conduct is repeated every three years.

Payment practices

Payment terms under supplier finance arrangements

Cenergy Holdings companies have entered into supplier finance arrangements with finance providers. Under such arrangements, the finance providers acquire the rights to selected trade receivables from the suppliers, while the terms and conditions of the arrangement are unchanged from the trade payables from this supplier, other than the due date has been extended.

Carrying amounts

The carrying amounts of liabilities under the supplier finance arrangement are considered to be reasonable approximations of their fair values, due to their short-term nature.

Working capital commentary

Working capital turned negative in 2024 at EUR -6 million as of 31 December 2024, a notable decrease of EUR 119 million compared to the previous year end. This decline was observed in both segments, primarily due to the timing of significant milestone payments from customers at year end and improved payment terms in the upstream supply chain.