Ellaktor

The Board of Directors is responsible for the adoption and approval of the Sustainable Development Policy, the approval of its update, as well as the supervision of its implementation by the Group companies with the assistance of the Sustainable Development Committee and the ESG Strategy & Sustainable Development Division.

The Company has established and implements a Regulatory Compliance Management System with specific priorities and goals in terms of integrity and ethical compliance. The Company maintains certifications for Anti-Bribery Management System (ISO 37001:2016), Whistleblowing Management System (ISO 37002:2021), Standard for the Governance of Organizations (ISO 37000:2021), and Compliance Management System (ISO 37301:2021).

ELLAKTOR Group's operation is based on a modern and effective model geared towards sustainable and responsible development. The Board of Directors has established Committees with supervisory, authorization, coordination and advisory competences, including:

• Sustainable Development Committee
• Strategic Planning Committee
• Audit Committee

The Company has developed an Integrity Compliance Programme, which includes regulatory compliance measures and safeguards to ensure full compliance with applicable legislation and regulatory framework.

Integration of sustainability-related performance in incentive schemes

Current status

At this stage, no sustainability criteria have been applied to the remuneration of Board members and committees, and the inclusion of climate-related factors in the incentive programme has not been implemented yet. However, the Company's Remuneration Policy provides for the integration of relevant incentives.

Remuneration Policy framework for ESG integration

The Policy states: "The criteria that determine the remuneration include, but are not limited to, the following:

At Company level: they may be related, indicatively, to financial indicators of projects, investments and/or the performance of the Company (e.g. EBITDA, operating expenses, economies of scale, etc.), adjusted earnings before interest, tax, depreciation and amortisation (adjusted EBITDA) and change thereof, value of equity portfolio under management, free cash flow generation, NAV and change thereof, health and safety (e.g. number and severity of accidents, system safety, etc.), operational issues of the Company (e.g. digital transformation) and/or corporate social responsibility (e.g. significant pollution reduction, community outreach programmes, etc.) and ESG performance based on sustainability criteria that address both environmental (e.g. carbon reduction targets or support for the circular economy, etc.) and social (e.g. number and severity of accidents, support for diversity, equity and inclusion, volunteering, etc.) issues, as well as governance issues.

At an individual level: effectiveness and goal orientation, initiative, judgment, adaptability, degree of conformity with Company regulations, individual management and development, guaranteeing correct recording and timely provision of ESG data, and achievement of ESG targets as set each time, etc."

Future implementation timeline

While the relevant incentives have not been implemented yet, the Company's Policy has already developed the framework for their integration in the future. The Group plans to determine the percentage of variable remuneration that depends on goals and/or impacts related to sustainable development issues by 2027 and will make relevant disclosures to its stakeholders in a subsequent Sustainability Statement.

Incentive scheme design principles

Incentive schemes are designed to boost performance, align with the company's strategic goals and promote long-term shareholder value creation. They are based on internationally recognised best practices and are developed with transparent and objective criteria.

1. Alignment with strategy and sustainable development

Incentive schemes are linked to the achievement of financial, operational and ESG targets, enhancing the company's long-term growth.

2. Combination of short-term and long-term incentives

The schemes include:

• Short-term incentives: They reward the achievement of annual targets related to financial performance, operational efficiency and improvement of critical indicators.
• Long-term incentives: They align with sustainable growth and shareholder value creation by incorporating targets such as increasing profitability, return on investments and achieving ESG indicators.

3. Objective and measurable evaluation criteria

Performance is evaluated against pre-determined indicators (KPIs), which may include:

• Economic indicators (EBITDA, free cash flow, NAV)
• ESG targets (CO₂ emission reduction, health and safety, corporate social responsibility)
• Business performance (operational efficiency, innovation, digital transformation)

4. Transparency and governance

The development, approval and updating of incentive schemes follow a clearly defined process, with the participation of the Nominations and Remuneration Committee, the Board of Directors and the Ordinary General Meeting of shareholders, ensuring compliance with corporate governance and legislative requirements.

5. Connection with executive engagement and retention

The schemes aim to retain talented executives, including programmes, enhancing long-term engagement.

In this way, incentives act as a mechanism for aligning the interests of employees, shareholders and the company, promoting the achievement of sustainable and responsible business results.

Approval and update process

The process of approving and updating the terms of the incentive schemes follows a clearly defined corporate governance, ensuring transparency, accountability and alignment with the Group's strategic priorities.

Specifically, the head of the Human Resources (HR) Division presents the proposals on the terms of the incentive schemes to the Nominations and Remuneration Committee. The Committee examines, assesses, possibly amends and finalises the proposals, taking into account internal and external data, including best market practices, company performance and incentives to achieve corporate goals.

The Committee then proposes the final framework to the Board of Directors, which is responsible for the approval. Following the approval of the incentive schemes by the Board of Directors, and if there are substantial changes and deviations from the current schemes, they are submitted for final approval by the Ordinary General Meeting of shareholders, thus ensuring transparency and compliance with the requirements of corporate governance and legislation.

The above process ensures that incentive schemes are assessed and approved at the highest management level, ensuring their strategic alignment with the Group's goals and maintaining a competitive and fair remuneration system.

ELLAKTOR is committed to applying high integrity standards to all of its business operations and activities, and has established an audit framework and criteria for establishing, maintaining and monitoring relationships with third parties (partners, suppliers, subcontractors, consortium members), with the goal of ensuring that they meet the Company's integrity standards and ESG (Environmental, Social and Governance) principles.

The Third-Party Due Diligence Policy allows for the monitoring of integrity risks posed by third parties, as well as the audit and assessment of their compliance with laws, regulations, standards, Group values, ESG targets, and other rules. This Policy was approved by the Company's Chief Executive Officer on 01/2024.

The Group's Financial Services Division, as the Division responsible for the financial risks, in collaboration with the Risk Management Division, has identified, demarcated and evaluated the risks in question, the negative effect of which it tries to mitigate, with targeted interventions, continuously monitoring the results of management actions against the individual risks.

The Group has developed emergency response plans to ensure the continuity of its vital operations, as well as the uninterrupted delivery of its services. Business Continuity Plans (BCP) as well as Disaster Recovery Plans (DRP) for the restoration of the functionality of information systems were drawn up and established, for which the Group is in the process of certification according to ISO 22301:2019 Business Continuity Management standard.

ELLAKTOR Group is one of the leading infrastructure groups in Greece, with a diversified portfolio focusing on the sectors of Concessions, Real Estate Development and Management, and Hospitality.

ELLAKTOR Group's business strategy focuses on strengthening its presence in the sectors of Concessions, Real Estate Development and Services, and Hospitality. With every activity centered around the use of innovative practices and modern technologies, the Group aims to create sustainable, green and safe infrastructure for people and the environment, as well as to produce alternative energy sources in order to address the need for resilience against climate change.

The Group has adopted and implements a Sustainable Development Policy, which has been in force since March 2022 and aims to create long-term value for shareholders, employees, clients and society at large, by incorporating environmental, social and corporate governance principles across all its business activities.

For ELLAKTOR Group, climate change and the circular economy, employee health, safety and development, social responsibility and integrity, and business ethics constitute key pillars of sustainable development. At the heart of these pillars lies innovation and digital transformation, serving as the connecting thread that equips the Group with modern tools to tackle future challenges more effectively.

Interests and views of stakeholders [SBM-2]

Overview of stakeholder engagement approach

Where ELLAKTOR Group is concerned, systematic and effective two-way communication with its stakeholders is the basis for evaluating and planning its actions and practices, as well as for addressing everyday challenges. The Group recognises as stakeholders those groups that can, directly or indirectly, affect or be affected by its activity. The stakeholders belong either to the Group's internal environment (shareholders, employees) or to the external environment (business community, investment community, clients, financial institutions, local community and local and regional authorities, business partners, government bodies and regulatory authorities, greater society).

At ELLAKTOR Group, the main concern is to establish mutual trust and constructive cooperation with all stakeholders, respecting the expectations and needs of each group. In this context, and with the aim of enhancing interaction with stakeholders, distinct communication channels have been established with each group through its website, direct communication channels, which is also part of the Group's due diligence.

In addition, the Group invites its stakeholders to participate in the evaluation surveys on the material issues of sustainable development, the results of which contribute to the formulation of the Group's strategy. The results of the materiality analysis with the consultation of stakeholders are presented and validated by the Sustainable Development Committee. In addition to projects where a certified Quality Management System is implemented, customer satisfaction questionnaires are sent through to record any complaints and their needs.

Communication channels and responsibilities

The Corporate Communications Department of ELLAKTOR Group is responsible for the planning and implementation of communication actions for all the activities of the Group and its subsidiaries, which concern both the foreign and domestic audiences, in Greece as well as in all countries in which it operates. The Corporate Communications Department implements policies to manage and protect the Group's corporate reputation, planning and implementing communications in full alignment with the Group's vision and values, ensuring proper communication with stakeholders and harmonising all the Group with these policies and the approved communication strategy. The Corporate Communications Department has adopted and implements a number of policies, including the Media Relations and Group Press Office Policy, the Group Advertising Policy, the Group Social Media Management Policy, the Internal Communication Policy, the Public Position Policy and the Financial Communication Policy. At the same time, the Group's communication with the investment community (shareholders/investors) is carried out through a structured process. This process is based on the Investor Relations Policy and describes the principles and procedures through which the Group ensures the correct, immediate, regular as well as equal information to its shareholders, providing them with all the necessary clarifications and information regarding the exercise of their rights, deriving from their shareholder status.

Stakeholder consultation and engagement by group

Stakeholder consultation in the materiality assessment

As part of the double materiality assessment, ELLAKTOR Group conducted a consultation with stakeholders in 2024, exclusively with internal stakeholders, focusing on the collection of information from within the Group. This approach allowed for a structured assessment of key sustainability issues (e.g. climate change, pollution, circular economy, own workforce, affected communities, business ethics, etc.) from an internal perspective. This materiality analysis also took into account the consultation with external stakeholders, which was carried out in the previous 2023 materiality analysis.

Integration of stakeholder views into strategy

The Group invites its stakeholders to participate in the evaluation surveys on the material issues of sustainable development, the results of which contribute to the formulation of the Group's strategy. The results of the materiality analysis with the consultation of stakeholders are presented and validated by the Sustainable Development Committee.

Due diligence and stakeholder cooperation

Due diligence procedures include cooperation with affected stakeholders at all key stages of due diligence, as outlined in the following key elements:

In addition, due diligence procedures are followed through the certified ISO Systems implemented by the Group's companies.

The Group's activities expose it to a variety of financial risks including credit risk, foreign exchange risk, interest rate risk, and liquidity risk. The Group's Financial Services Division has identified and evaluated these risks.

The main macroeconomic risks and uncertainties in Greece are related to: (i) geopolitical tensions caused mainly by the war in Ukraine and the volatile situation in the Middle East, which may lead to trade disruptions and new pressures on energy and commodity prices, (ii) the possibility of increased political and economic uncertainty and financial volatility, (iii) the worsening of natural disasters due to environmental and climate change and their effects on GDP, employment, fiscal balance and sustainable development in the long term, and (iv) artificial intelligence impacts on employment and businesses.

For the Real Estate Development sector: Potential economic instability, intense competition as well as geopolitical factors may decrease tourism spending. Strong inflationary trends, along with rising lending rates, may have a negative impact in terms of growing construction costs. The Group is exposed to the risk of changes in real estate prices.

For the Environment sector: Strong inflationary pressures and energy crisis consequences are risks, though in highly energy-intensive activities much of the price increase is covered by corresponding contractual provisions.

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

ELLAKTOR Group carried out an assessment of material topics, adopting the double materiality approach in accordance with the requirements of the ESRS. The double materiality concept lies in the identification of material impacts from the inside out, and financial risks and opportunities from the outside in. Through the double materiality analysis, the way the Group affects the environment, society and governance and the way these affect the Group respectively are highlighted.

In the context of this analysis, the impacts arising from the Group's activity and affecting or likely to affect the environment, society, economy and human rights were assessed, as well as the way in which the Group is affected or may be affected by ESG and sustainable development issues (risks and opportunities).

The double materiality analysis carried out in 2024 was implemented according to the following methodology:

Step-by-step methodology

1st Step: Understanding the operating framework of ELLAKTOR Group

• Review of the Group's activities and operating framework
• Overview of the business model
• Overview and mapping of key stakeholders and the value chain

Value chain and business relationships:

ELLAKTOR Group conducted a mapping of its value chain to identify the Sustainable Development issues related to the activities of its Business Partners for all the Group's business segments.

From the analysis of upstream business partners, it was concluded that 94% of the procurements are from Greece and the rest from the following countries: United Arab Emirates, Australia, Austria, Belgium, Bulgaria, Cyprus, Germany, Denmark, Egypt, Spain, Estonia, France, United Kingdom, Croatia, Hungary, India, Ireland, Israel, Italy, Luxembourg, Monaco, Netherlands, Poland, Portugal, Romania, Slovenia, Sweden, USA.

The Group's main suppliers are electricity providers, property management companies, financial institutions, facility management companies, fuel supply companies, aggregate production companies, IT and technology application procurement companies. From the assessment of these business relationships, any risks that could disrupt the operation of the Group and its projects were examined. In particular, the risk of interruption of electricity supply, due to extreme weather events, as an impact of climate change, which could lead to significant economic impacts on the Group's projects, was recognised, depending on the duration of the event.

From the analysis of downstream business partners (clients), the main groups identified are motorway users, users of Alimos Marina (intra-EU and third countries), waste management companies, road and highway construction companies, municipalities, local and regional authorities and Regional Associations of Waste Management Entities which operate in their majority in Greece. From the assessment of these business relationships, a significant risk to the Group's operations may arise due to extreme natural event (e.g. due to earthquakes or climate change) or due to extraordinary crises (e.g. pandemics or wars) which could significantly reduce the users of motorways, accommodation and Alimos Marina.

Mapping and consultation with stakeholders:

As part of the double materiality assessment, ELLAKTOR Group conducted a consultation with stakeholders in 2024, exclusively with internal stakeholders, focusing on the collection of information from within the Group. This approach allowed for a structured assessment of key sustainability issues (e.g. climate change, pollution, circular economy, own workforce, affected communities, business ethics, etc.) from an internal perspective. This materiality analysis also took into account the consultation with external stakeholders, which was carried out in the previous 2023 materiality analysis.

2nd Step: Identification of impacts, risks and opportunities

• Identification of positive and negative (actual and potential) impacts of the Group on the economy, environment and society, including impacts on human rights, and grouping of these into Sustainable Development issues
• Identification of the Group's financial risks and opportunities, due to environmental, social or governance issues, taking into account the identified positive and negative (actual and potential) impacts, and grouping of these in Sustainable Development issues

Based on the sustainability topics (ESG topics) covered in the ESRS topics, ELLAKTOR Group mapped and grouped the sustainability topics and sub-topics of the ESRS in a customised list related to ELLAKTOR Group's activities. For each sustainability topic included in the double materiality analysis, impacts, risks and opportunities (IROs) were identified through internal analysis and external documentation.

Inputs to the assessment

For the process of identifying the impacts of risks and opportunities, the following were examined and evaluated:

• The sustainable development strategy and the relevant action plan
• The policies that have been adopted and are implemented
• The risk management register
• The results of the identification and assessment of climate change risks in accordance with the TCFD guidelines
• The Group's submission to CDP
• Assessments by international ESG performance assessment bodies
• Previous double materiality analysis

3rd Step: Assessment of impacts, risks and opportunities

To assess the impact and financial materiality of each ESG topic, a specific IRO assessment framework was established in line with the requirements of the ESRS. Each individual IRO identified in the 2nd step was assessed against this framework to determine which IROs were considered material. The materiality of the IROs determined the materiality of the topics.

For each ESRS topic included in the double materiality assessment, impacts, risks and opportunities (IROs) were identified based on office research and internal and external data analysis. The information was qualitatively collected, taking into account the materiality of the impacts (inside-out approach) and financial materiality (outside-in approach), in order to understand the rationale behind each identified IRO in detail. When assessing the impacts, risks and opportunities, the Group's 2023 ESG performance was also taken into account, as reflected in the 2023 Sustainability Report.

Scoring criteria

Assessment criteria for impact materiality

The following criteria were taken into account for the assessment of the materiality of IROs, as required by the ESRS:

• Impact materiality: severity (= scale, scope and irremediable character) and likelihood
• Financial materiality: magnitude of financial impact and likelihood

The score per criterion was adjusted to the business activities of ELLAKTOR Group. The criteria for the size of the financial impact and the likelihood were aligned with the Group's risk management (ERM) methodology.

Criteria for the assessment of positive (actual and potential) impacts:

• Scale: how beneficial the specific impact is or could be
• Scope: of the impact, i.e. how extensive the specific impact is
• Likelihood: of the impact, i.e. how likely it is that the impact will occur

Criteria for the assessment of negative (actual and potential) impacts:

• Scale: of the impact, i.e. how severe the specific impact is
• Scope: of the impact, i.e. how extensive the specific impact is
• The irremediable character of the impact, i.e. how difficult it is to manage or remedy the damage caused
• Likelihood: of the impact, i.e. how likely it is that the impact will occur

A 5-point scale was used for the scale, scope and irremediable character, and a 4-point scale was used for likelihood.

Calculation:

• Positive impact = (Scale + Scope) x likelihood coefficient
• Negative Effect = (Scale + Scope + Irremediable Character) x likelihood coefficient

In the event of a potential negative impact on human rights, the severity of the impact outweighed the likelihood of occurrence.

Assessment criteria for financial materiality

For the assessment of financial materiality, the financial impact ranges have been configured in alignment with the EBITDA of ELLAKTOR Group for the financial year 2024. The assessment criteria were aligned with the Group's risk management (ERM) methodology.

Threshold for materiality

The calculation approach and materiality limits were defined based on the Materiality Assessment Implementation Guide published by EFRAG and the Group's internal methodology. Each individual IRO was scored according to the pre-defined assessment framework. The quantitative analysis was supported by qualitative justification and reference to sources (documents, interviews, etc.). In addition, specific characteristics of IROs were recorded, such as the time horizon (<1 year, <5 years and >5 years) and its position in the value chain. The IROs were assessed using a standard computational tool.

Topic-level materiality:

Topic-level materiality was determined by allocating the maximum impact materiality and financial materiality score of the relevant impacts, risks and opportunities to the specific topic. This means that an topic is considered material once it is linked to at least one material IRO. The project teams of ELLAKTOR Group worked together to discuss and determine the results of the assessment.

Frequency / when last reviewed

The double materiality analysis was carried out in 2024.

Use of value chain mapping

ELLAKTOR Group conducted a mapping of its value chain to identify the Sustainable Development issues related to the activities of its Business Partners for all the Group's business segments. The IRO assessment included recording specific characteristics such as the position in the value chain.

Transition plan for climate change mitigation

Overview and Paris Agreement alignment

ELLAKTOR Group is committed to a sustainable future and is actively working to reduce its carbon footprint by adopting a climate transition plan in line with the goal of the Paris Agreement to limit global warming to 1.5°C. However, the transition from fossil fuels is a complex process that requires careful planning and significant investment.

Scope of the transition plan

The transition plan covers all of the Group's continuing operations and activities. The greenhouse gas emission reduction targets concern all of the Group's continuing operations and have been set in combination for Scope 1&2 and separately for its critical business partners (Scope 3).

GHG reduction targets and baseline

In the context of the transition to a climate-neutral future, the Group has set, with base year 2023, for all its activities, a target of reducing Scope 1&2 emissions by 42% by 2030 and indirect Scope 3 emissions by 25% by 2030. These targets have been set using the Absolute Contraction Approach (ACA) method, SBTi's "Corporate Near-Term Target setting tool". According to the SBTi Corporate Near-Term Criteria, Version 5.2, March 2024, the target of 42% for Scope 1&2 emissions by 2030 is in line with the 1.5°C scenario, while the target of 25% for indirect Scope 3 emissions by 2030 is in line with the WB2C scenario (Well-below 2°C).

For scope 2, the market-based method was used to define the target.

Biogenic emissions from biogas utilisation plants have not been included.

SBTi validation status

The Group has submitted a letter of commitment to the independent SBTi organisation for the validation of these targets and intends to submit these targets for validation in 2025.

The greenhouse gas emission reduction targets are mixed targets and do not include greenhouse gas removals, carbon credits or avoided emissions as a means of achieving the greenhouse gas emission reduction targets.

Key decarbonization actions and levers

In order to achieve the above targets, the Group's Climate Transition Plan has been drawn up, which focuses on the integration of climate risk management and on investments in sustainable practices and technologies and includes the following actions:

Governance and monitoring

The transition plan and actions to reduce energy consumption and greenhouse gas emissions have been integrated into the Group's ESG strategy, which is monitored at regular intervals, and the results are evaluated by depicting the annual performance and progress against the targets set.

The transition plan is monitored through the briefing of the Sustainable Development Committee, which plays a key role in aligning the Group's operations with this plan. The Sustainable Development Committee proposes Environmental, Social and Governance (ESG) initiatives, which are approved by the Board of Directors. In cooperation with the relevant business units, the Sustainable Development Committee promotes the ESG plan, ensuring that it is strictly aligned with the 1.5°C target. The ESG Strategy and Sustainable Development Division coordinates the drafting of the Annual Sustainable Development Report, which monitors sustainability indicators, ensures continuous improvement and gathers feedback from stakeholders, including shareholders. The Sustainable Development Committee approves these reports.

CapEx and locked-in emissions

Due to the Group's transformation at this stage, information is not available regarding the estimate of the expenses that will be required for the transition plan, any capital expenditure plans to align the activities based on the taxonomy requirements and related capital expenditures, which will be disclosed in a subsequent Sustainability Statement. In addition, no significant locked emissions have been recorded for the Group's continuing operations.

Exemptions from Union benchmarks

ELLAKTOR Group's activities are not exempted from Union benchmarks that are aligned with the Paris Agreement [in accordance with the exemption criteria set out in points (d) to (g) of Article 12(1) and Article 12(2) of Delegated Regulation (EU) 2020/1818].

Additional information

It is worth mentioning that for the second consecutive year, the Group submitted a climate change disclosure report to the independent certification body (CDP), covering 13 key areas, and received a high B rating.

The Group aims to create sustainable, green and safe infrastructure for people and the environment, as well as to produce alternative energy sources in order to address the need for resilience against climate change. Climate change and the circular economy constitute key pillars of sustainable development for ELLAKTOR Group.

In 2024, the Group undertook a series of initiatives and actions related to sustainable development, resulting in improved ESG performance. For the second consecutive year, the Group submitted a climate change disclosure report to the independent certification body (CDP), covering 13 key areas, and received a high score of B.

Commissioning of a 3MW solar PV installation on the roofs of the Western Macedonia waste management facilities. The utilisation of the produced energy will be carried out on the basis of zero feed-in. The investment was implemented by the 100% subsidiary EDADYM S.M.S.A.

The Group operates 4 energy production projects utilising landfill biogas with a total installed capacity exceeding 33 MW in the Environment sector.

Targets related to climate change mitigation and adaptation

Overview

ELLAKTOR Group has set greenhouse gas emission reduction targets with base year 2023 for all its continuing operations. These targets are absolute targets (tonnes of CO2 equivalent) and do not include greenhouse gas removals, carbon credits or avoided emissions. The targets have been set using the Absolute Contraction Approach (ACA) method, SBTi's "Corporate Near-Term Target setting tool". The Group has submitted a letter of commitment to SBTi for validation of these targets and intends to submit them for validation in 2025.

Quantified Targets

Target Methodology and Alignment

• Method: Absolute Contraction Approach (ACA), SBTi's "Corporate Near-Term Target setting tool"
• Scope 1&2 target (42% by 2030): Aligned with 1.5°C scenario according to SBTi Corporate Near-Term Criteria, Version 5.2, March 2024
• Scope 3 target (25% by 2030): Aligned with Well-below 2°C (WB2C) scenario
• Scope 2 method: Market-based method used to define the target
• Exclusions: Biogenic emissions from biogas utilisation plants not included

Additional Energy and Emissions Targets

From the strategic priority table:

• Reduce energy consumption from non-renewable sources by 10% by 2030
• 2050 Zero greenhouse gas emissions

Transition Plan Actions

Governance and Monitoring

The transition plan is monitored through the briefing of the Sustainable Development Committee, which proposes ESG initiatives approved by the Board of Directors. The ESG Strategy and Sustainable Development Division coordinates the drafting of the Annual Sustainable Development Report, which monitors sustainability indicators and ensures continuous improvement.

Energy consumption and mix

Total energy consumption and mix (2024)

In 2024, the Group's total energy consumption amounted to 639,474 MWh (2,302 TJ). The largest percentage of energy consumed derived from landfill biogas combustion for the production of electricity (82.8%), while the remaining amount derived from electricity consumption from the grid (11.4%), fuel consumption (5.4%) and self-consumption of energy within the projects from RES (0.4%).

*Self-consumption in biogas utilisation projects has been counted in fuel consumption (line 8) and not in self-generated energy consumption (line 10). The data of the joint undertakings have been integrated fully and not proportionately due to full operational control and for reasons of comparability with previous years.

Electricity origin: In 2024, there were no Guarantees of Origin or PPAs. The origin of electricity consumed by the Group's activities comes from the grid. Its allocation to electricity from fossil fuels and electricity from RES has been made on the basis of the Energy Mix.

Energy intensity (high climate impact sectors)

In accordance with Law 1893/2006/EC on high climate risk sectors, the Group has determined that its activities on the whole fall under the relevant legislation groups.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 GHG emissions

In 2024, direct Scope 1 greenhouse gas (GHG) emissions amount to 15,818 t CO2 eq., constitute 42% of Scope 1&2 emissions and relate to:

• Emissions from fuel combustion in stationary units (18%)
• Emissions from fuel combustion in mobile units (39%)
• Fugitive emissions from cooling/air conditioning equipment (3%)
• GHG emissions from physicochemical processes, specifically from waste management within projects (40%)

Methodology note: CH4 and N2O emissions from the biogas utilisation process and from the combustion of wood pellets to CO2 equivalent have been calculated. For the calculation of Scope 1 emissions for the reference year 2024, the emission coefficients from the following documents were used: Greece National Inventory Submissions 2024, Germany National Inventory Submissions/NID/CRF 2024, Cyprus National Inventory NIR/CRF/CRT 2024, DEFRA 2024, EPA 2024, IPCC – AR5.

Biogenic CO2 emissions: The Group's biogenic CO2 emissions for 2024 were estimated at 105,194 t CO2. These emissions derive from the processes of biogas utilisation plants and a small amount from the combustion of wood pellets. Biogenic emissions are reported separately and not included in Scope 1 totals (per GHG Protocol, ISO, ESRS-E1_AR43c). For the calculation of biogenic emissions for the reference year 2024, the emission coefficients from the following documents were used: Greece National Inventory Submissions 2024, Germany National Inventory Submissions 2024.

Scope 2 GHG emissions

The Group's indirect Scope 2 greenhouse gas (GHG) emissions constitute 58% of Scope 1&2 emissions and derive from the consumption of electricity from the grid.

Methodology note: For the calculation of Scope 2 emissions for the reference year 2024, the emission coefficients from the following documents were used: DAPEEP 2023 (2024 Edition), IPCC - AR5, IEA 2022, AIB 2023.

Note on electricity origin: In 2024, there were no Guarantees of Origin or PPAs. The origin of the electricity consumed by the Group's activities comes from the grid. Its allocation to electricity from fossil fuels and electricity from RES has been made on the basis of the Energy Mix.

Scope 3 GHG emissions

The methodology for the calculation of the Group's other indirect Scope 3 emissions was based on the GHG Protocol and ISO 14064-1:2018 international standard. The Group's other indirect Scope 3 emissions are estimated at 308,958 t CO2 eq.

Data quality: The percentage of Scope 3 emissions calculated with primary data (fuel invoices, consignment notes and waste weigh tickets) from business partners is estimated at 80.9%.

Emission coefficients: For the calculation of Scope 3 emissions, the emission coefficients from the following documents were used: BEIS 2021, EPA 2022, EXIOBASE 2019 – GR, EPA 2018, EXIOBASE 2019 – CY, DAPEEP 2024, DAPEEP Report 2022 and NIR 2022, Greece National Inventory Submissions 2024, DEFRA 2024, Editorial deadline: 29 November 2023, Sheet "Scope 3_Scope 2 Upstream CO2eq", Cyprus National Inventory Report (NIR) 2024, EPA 2024, Ecoinvent 3.11.

Scope 3 emissions by category

Scope note: Categories 8, 9, 10, 11, 12 and 14 of Scope 3 do not fall within the Group's activity.

Total GHG emissions

Note: If a subsidiary of the Group acts as a subcontractor for another subsidiary, the energy consumption has been recorded by the 1st subsidiary that offers its services and has been calculated in Scope 1.

GHG emissions intensity

*Refers to the income statement under the sales line of the 2024 Annual Financial Report.

Regulated emissions

No specific disclosure of EU ETS or other regulated emissions separately reported.

Contribution to emission avoidance

Through the net production of 221 GWh of electricity from RES in 2024, it is estimated that the Group contributed to the avoidance of emissions of 1,076 thousand tonnes of CO2 eq. by third parties in the atmosphere.

For the calculation, the CO2 emission coefficient included in the Report of the country's Production Energy Mix for 2023 (ENERGY MIX 2023, DAPEEP) has been used. For the calculation of CH4 emissions, the relevant emission coefficients from the DAPEEP Report 2023, the National Greenhouse Gas Emissions Inventory Report 2023 and the CRF 2023 tables have been used. The amount of methane that is intended for combustion in biogas plants and not released into the atmosphere has also been calculated. The value is quoted using the location-based method.

Consolidation scope

The data of the joint undertakings have been integrated fully and not proportionately due to full operational control and for reasons of comparability with previous years. There is a separate breakdown of the financial figures of turnover, capital and operating expenditure into continuing and discontinued operations. For the fiscal year 2024, the Environment segment has been classified as Discontinued Operations according to the provisions of IFRS 5.

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

Phase-in exemption applied

Omission of information provided by ESRS E1-9 for the first year of preparation of the relevant sustainability statement.

Assessment of data point importance

The following E1-9 related data points were assessed as "Not important":

• ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks paragraph 66 (Delegated Regulation (EU) 2020/1818, Annex II, Delegated Regulation (EU) 2020/1816, Annex II)
• ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a) ESRS C1-9 Location of significant assets at material physical risk paragraph 66(c) (Article 449a of Delegated Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453, paragraphs 46 and 47; Template 5: Banking book - Climate change physical risk: Exposures subject to physical risk)
• ESRS E1-9 Breakdown of the carrying value of real estate assets by energy-efficiency classes paragraph 67(c) (Article 449a of Delegated Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453, paragraph 34; Template 2: Banking book – Climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateral)
• ESRS E1-9 Degree of exposure of the portfolio to climate-related opportunities paragraph 69 (Commission Delegated Regulation (EU) 2020/1818, Annex II)

Policies related to pollution

The excerpts provided do not contain specific disclosures about policies related to pollution as required by ESRS E2-1. The excerpts focus on climate change governance and strategy (ESRS E1), including:

• Reference to an Environmental and Energy Policy at Group level approved by the CEO in 2022
• Climate-related governance structures and responsibilities
• Climate risk and opportunity assessment processes

However, the excerpts do not provide:

• The name, scope, or content of pollution-specific policies
• How pollution policies address air, water, soil pollution, or substances of concern
• Governance, monitoring, or public availability of pollution policies
• Links to international standards for pollution management

The single reference to an "Environmental and Energy Policy" suggests that pollution-related matters may be covered within this broader policy, but no specific pollution policy details are disclosed in the provided excerpts.

Targets related to pollution

Ellaktor has set the following pollution-related targets:

Waste Diversion Target

• Target metric: Waste diversion from landfill
• Target value: 100%
• Target year: 2028
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Projects (own operations)
• Type: Absolute
• Progress to date: Not disclosed

Water Withdrawal Reduction Target

• Target metric: Water withdrawal reduction
• Target value: 15% reduction
• Target year: 2030
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Projects (own operations)
• Type: Percentage reduction
• Progress to date: Not disclosed

Note: The excerpts also contain greenhouse gas emission reduction targets, which are more appropriately disclosed under ESRS E1 (Climate change) rather than E2 (Pollution). The pollution-specific targets identified are waste diversion and water withdrawal reduction.

Pollution of air, water and soil

Disclosure Statement

The company states in its materiality assessment that ESRS E2-4 regarding "Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil paragraph 28" is assessed as Not important.

Qualitative Information on Pollution Management

The Group implements specific processes and an integrated environmental management programme to prevent soil, subsoil and water pollution:

• Waste management programme with proper storage of waste by sorting at source
• Hazardous waste stored in suitable containers in specially demarcated areas, protected from weather conditions, with watertight safety bund
• Equipment and machinery maintained in specially designed areas to protect soil against leaks
• Emergency response plans developed with appropriate equipment (e.g. absorbents) to limit or avoid pollution
• Regular drills conducted for emergency plans

Air Quality Management

Concessions companies implement:

• Gas emission monitoring programme
• Inspections and measurements of air pollutants to ensure protection of the atmosphere
• Eco-friendly driving principles to reduce air emissions and noise

Noise Monitoring

MOREAS project:

• Monitors road traffic noise indicators on annual basis
• Measurement programme at approved locations along the motorway
• Updates monitoring procedures following guidelines from competent Authorities

Water Management

Water uses concern irrigation, cooling, hygiene, water supply, firefighting, washing, maceration and waste treatment. Practices include:

• Installation of meters and control of leakage
• Implementation of approved irrigation studies
• Central electronic irrigation systems programmed according to climatic conditions
• Reuse of water from biological treatment effluents
• Periodic control of water quality parameters (chemical and microbiological)

Assessment: Through double materiality analysis, no material impact, risk or opportunity arises from the Group's activity in terms of potential pollution and water resources.

Quantified Emissions

No quantified emissions to air, water or soil are disclosed in the sustainability statement.

Policies related to water and marine resources

Ellaktor has assessed ESRS E3-1 (Water and marine resources - paragraph 9) and ESRS E3-1 Dedicated policy (paragraph 13) as not important in their materiality assessment.

The company has also assessed ESRS E3-1 Sustainable oceans and seas (paragraph 14) as not important.

No specific policies related to water and marine resources are disclosed in the provided excerpts. The materiality assessment indicates that the company has determined these topics are not material to its operations and therefore has not developed or disclosed dedicated policies in this area.

Water consumption

Disclosure

Ellaktor discloses qualitative information about water management but does not provide quantitative metrics for water consumption, withdrawal, or discharge in accordance with ESRS E3-4 requirements.

Water Management Practices

The Group's water uses mainly concern irrigation, cooling, hygiene, water supply, firefighting, washing (road surface and/or vehicles), maceration and waste treatment. Water withdrawal mainly concerns the Concessions segment, with no substantial impact on the environment reported from this process.

Water Management Measures:

• Implementation of Environmental Management Systems in accordance with ISO 14001 standard
• Installation of meters and control of any leakage
• Implementation of approved irrigation studies
• Regulation of irrigation by central electronic systems programmed according to climatic conditions
• Reuse of water from biological treatment effluents
• Periodic control of quality, chemical and microbiological parameters of water quality
• Waste management programme with proper storage to prevent soil, subsoil and water pollution
• Hazardous waste stored in suitable containers with watertight safety bunds at minimum required distance from points sensitive to groundwater pollution risk

Target

Ellaktor has set a target for 15% reduction in water withdrawal by 2030 (base year not specified in excerpts).

Materiality Assessment

Through the double materiality analysis, no material impact, risk or opportunity arises from the Group's activity or operational facilities in terms of potential pollution and water resources.

Regulatory Reference

ESRS E3-4 Total water recycled and reused (paragraph 28(c)) and Total water consumption in m³ per net revenue on own operations (paragraph 29) are noted as "Not important" in the disclosure requirements table.

Policies related to biodiversity and ecosystems

The company has assessed the following ESRS E4-2 policy-related disclosure requirements as not important based on its materiality assessment:

• Sustainable land/agriculture practices or policies (paragraph 24(b)) - Indicator No. 11, Table 2, Annex I
• Sustainable ocean/seas practices or policies (paragraph 24(c)) - Indicator No. 12, Table 2, Annex I
• Policies to address deforestation (paragraph 24(d)) - Indicator No. 15, Table 2, Annex I

Additionally, indicators related to ESRS 2 - SBM 3 - E4 paragraphs 16(b) and 16(c) (Indicators No. 10 and 14, Table 2, Annex I) have been assessed as not important.

No specific policies related to biodiversity and ecosystems are disclosed in the extracted material, as the company has determined these topics are not material to its operations.

Actions and resources related to biodiversity

Protecting and conserving biodiversity

Action: Implementation of biodiversity conservation management plans in 100% of projects within or near environmentally sensitive areas

• Strategic priority: Protecting and conserving biodiversity
• Topic: Biodiversity and ecosystems
• Sub-issue: Impacts on the extent and condition of ecosystems / Impact on the condition of species
• Target: 100% of projects within or near environmentally sensitive areas
• Scope: Own operations (projects)
• Time horizon: Not specified
• Resources allocated: Not disclosed
• Expected outcomes: Implementation of conservation management plans across all relevant projects
• KPIs: Percentage of projects with biodiversity conservation management plans implemented

No quantified financial or non-financial resources (capex, opex, staffing, or partnerships) are disclosed for this biodiversity action.

Impact metrics related to biodiversity and ecosystems change

Ellaktor's disclosure on biodiversity impact metrics (ESRS E4-5) is qualitative and policy-oriented rather than quantitative.

Biodiversity and ecosystem commitments

The Group's Environment & Energy Policy includes the following biodiversity-related commitments:

• Restoration of green spaces and the landscape in general and avoidance of deforestation
• Preservation and protection of biodiversity and ecosystems in the areas where it operates
• Effective management of nuisances such as noise, vibrations, traffic congestion, in order to reduce the impact on the local community, road traffic, public utility networks and protected areas

Risk identification

The Group identifies reputational risk arising from "Negative Media coverage concerning the support to projects or activities with negative impacts on the environment (e.g. GHG emissions, deforestation & land use change, water stress)".

Management approach

The Group implements an integrated environmental management programme aimed at preventing soil, subsoil and water pollution in the areas where it operates, including:

• Waste management programmes with proper storage and sorting
• Special emergency response plans activated in case of incidents
• Equipment and machinery maintenance in specially designed areas to protect soil against leaks
• Hazardous waste storage in suitable containers in demarcated areas with watertight safety bunds at minimum required distance from points sensitive to groundwater pollution risk

Note: No quantified metrics are disclosed for land use footprint, deforestation, operations in protected areas/KBAs, species impacts, ecosystem condition, or restoration hectares.

For ELLAKTOR Group, climate change and the circular economy constitute key pillars of sustainable development.

Greece has adopted a National Strategy for the Circular Economy and has harmonised its legislation with the principles of the circular economy. This includes Law 4819/2021 'Integrated framework for waste management' which revises the regulatory framework for waste management so they are in line with the requirements of the European Action Plan for the Circular Economy.

During 2024, the HELECTOR Group operated 7 waste treatment plants with a capacity exceeding 700,000 tonnes per year (excluding quantities managed directly in landfills), 2 clinical waste treatment plants.

The Group's waste management activities include various projects and operational improvements:

• Operation of 7 waste treatment plants with a capacity exceeding 700,000 tonnes per year
• Signing of a contract for the construction of a Pre-Treatment and Composting Facility for mixed municipal waste and a Landfill for residuals in Andros
• Activation of a one-year option under the contract for the 'Upgrade and Operation of the Ano Liosia Mechanical Biological Treatment Plant, transforming it into a Green Factory'
• Sale of recyclable materials due to higher disposal prices

Waste

Waste Management Policy and Approach

The Group has committed to minimisation of waste, hazardous and non-hazardous, through the reduction of the waste produced, reuse to the maximum extent, recycling and adoption of sorting practices at source, contributing to the promotion of circular economy and industrial symbiosis.

Targets

The Group has set the following waste diversion targets:

• 80% Waste diverted from landfill
• 90% Waste diverted from landfill
• 100% waste diverted from landfill from the Group's projects by 2028

*Note: Waste resulting from the operation of the Group's projects

Waste Management Processes

In the Group's projects, specific processes are followed and an integrated environmental management programme is implemented with the aim of preventing soil, subsoil and water pollution in the areas where it operates. More specifically, a waste management programme is implemented with proper storage of waste by sorting at source, in accordance with the specifications of the law, and waste is regularly transferred to the licensed final recipients for further management. In particular, hazardous waste is stored in suitable containers in specially demarcated and designed areas, protected from weather conditions, with a suitable watertight safety bund and observing the minimum required distance from points sensitive to the risk of groundwater pollution.

Circular Economy Activities

CE 2.7. Sorting and material recovery of non-hazardous waste

The projects "ASA (Aspropyrgos)" and "ASA (Thessaloniki)" involve the operation of facilities for sorting and recovering non-hazardous waste flows, specifically recyclable glass waste, into high quality secondary raw materials using mechanical conversion processes. Similarly, the project "ASA (RSC Lamia)" involves the operation of facilities for sorting and recovering of non-hazardous waste flows, specifically recyclable waste (blue bins), into high-quality secondary raw materials using mechanical conversion processes.

For all three plants, the recycling rate of recyclable waste exceeds 60%.

Composting

CCM 5.8. Composting of bio-waste

The project "J/V PRASINO EMA" concerns the processing of separately collected organic waste through composting (aerobic digestion), and the subsequent production and use of compost. The organic waste composted is separated at the source and collected separately. The plant processes more than 90 tonnes per day.

PPC 2.2. Treatment of hazardous waste

The project "Sterilisation S.A." involves the operation of specialized facilities for the treatment of hazardous waste from healthcare units, including physicochemical treatment and specifically sterilisation (task D9), and the project "EPALTHEA" involves the operation of specialised facilities for the treatment of hazardous waste from healthcare units, including the incineration of non-recyclable hazardous waste (task D10).

ELLAKTOR Group invests in humans and their potential, innovative practices and new technologies. Employee health, safety and development constitute key pillars of sustainable development for the Group.

The Group has established a comprehensive regulatory framework including:

• Code of Ethics that includes fundamental principles, rules and values that define daily conduct and determine standards, ethical principles and expectations the Group has of its management, human resources and third parties
• Internal Rules of Operation that define responsibilities and duties of main job positions, promoting adequate separation of duties within the Company
• Reporting Management Policy ensuring implementation of an effective reporting management system where reports can be submitted confidentially or anonymously without fear of retaliation

The Group ensures the implementation and operation of an effective reporting management system in accordance with applicable legislation and international standards. In full compliance with Law 4990/2022, the Company implements the Reporting Management Policy.

The Company has established and implemented alternative internal reporting channels, where any reports can be submitted in a secure and practical manner. Reports can be submitted confidentially or completely anonymously. All reports are properly addressed based on the procedures in a confidential manner without fear of retaliation against anyone who expresses any concern or reports any potentially problematic incident in good faith.

The Company maintains Whistleblowing Management System certification (ISO 37002:2021).

Taking action on material impacts on own workforce

The Group has developed and implements a series of targeted action plans for its workforce, with the aim of enhancing resilience, equality, fair treatment and employee engagement. These actions are aligned with the Group's ESG strategy and are supported by specific resources, both financial and human.

The Group has identified a number of material negative impacts affecting its workforce, either at the individual level or at the systemic level. In response, targeted prevention or mitigation initiatives have been designed and implemented, in line with the Group's fundamental principles of responsible business conduct and policies.

Core Action Plan

The following actions are implemented:

• Design and implementation of a holistic improvement programme for the well-being of the Group's employees
• Diversity, Equity & Inclusion Policy
• Programme for the enhanced inclusion of vulnerable groups through recruitment
• Monitoring and evaluation of indicators (KPIs) to track wage disparities
• Evaluation of employee remuneration based on relevant studies to ensure adequate wages for a decent living
• Women's Empowerment Programme
• Leadership training programme for managers
• Implementation of the "360 Feedback" evaluation
• Expansion of the certification of Health & Safety Management Systems according to ISO 45001:2015 standard to 100% of the Group's projects
• 100% internal Health & Safety audits across the Group's projects
• Health & Safety audits of critical business partners

Monitoring: Specific performance indicators (KPIs) have been developed for these actions. The indicators and actions are monitored by the ESG Strategy & Sustainable Development Division every six months for their progress, in collaboration with the respective Divisions.

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Health and Safety Actions

The Group continuously implements processes incorporated into the certified Health & Safety Management System, based on ISO 45001:2018 international standard.

Health & Safety Organisational Structure

• Appointment of Health & Safety Officers in each project, depending on its size and nature, supported by the central department of each subsidiary and supervised by the Group's Health & Safety Division
• Appointment of Safety Engineer and/or Coordinator for each project
• Appointment of Occupational Health Physician where required, to monitor and supervise employees' health and hygiene conditions
• Appointment of first aid team depending on the project size
• Occupational Health Physician for subcontractors' employees where required

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Regulatory Compliance and Integrity Actions

The Group has implemented an Integrity Compliance Programme with regulatory compliance measures and safeguards.

Training Programmes

• Design and implementation of annual training programme for Group employees covering:
  • Personal data protection
  • Whistleblowing management
  • Integrity issues

Resources allocated: In 2024, 90.5 hours of training on Regulatory Compliance were provided to 102 employees.

Compliance Audit Programme

• Design and implementation of risk-based compliance audit / internal inspection programme in collaboration with the Risk Management Division and Strategic Development Division, covering:
  • Anti-Bribery Management System (ISO 37001:2016)
  • Compliance Management System (ISO 37301:2021)
  • Whistleblowing Management System (ISO 37002:2021)
  • Integrity clause inclusion in contracts
  • Conflict of Interest Procedure implementation

Policy Development

• Development and implementation of Anti-Corruption Policy
• Development of Third-Party Due Diligence Policy

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Diversity, Equity & Inclusion Actions

• Comprehensive training programme designed by the ESG Strategy & Sustainable Development Division, in collaboration with the Human Resources Division and the Communications Division, for:
  • Senior management and team leaders
  • All employees on Diversity, Equity and Inclusion issues

This programme was approved by the Sustainable Development Committee.

Policy governance: The Diversity, Equity & Inclusion Policy is approved by the Group's Chief Executive Officer, reviewed on an annual basis and revised whenever necessary. The Group's ESG Strategy & Sustainable Development Division is responsible for monitoring the policy and reviewing it.

Targets related to own workforce

ELLAKTOR Group plans and implements actions for Health & Safety and privacy issues of its own workforce in accordance with the targets of the ESG strategy, in full alignment with the principles set out in the employees' Health & Safety policy and the Personal Data Protection policy.

Characteristics of the undertaking's employees

Total headcount and FTE

At the end of 2024 (31.12.2024), the Group's total number of employees amounted to 1,422 individuals, of which 1,057 were men (74%) and 365 (26%) were women.

The Group's permanent employees, as of 31.12.2024, were 1,395 (1,046 male and 349 female employees), while temporary employees were 24 (8 men and 16 women). Three employees were excluded from the permanent count related to specific projects.

ELLAKTOR Group does not employ employees with non-guaranteed hours.

The Group's total workforce at year-end was 1,585 individuals (employees and self-employed persons). This includes 163 non-employees (self-employed), of which 137 were male (84%) and 26 were female (16%).

Headcount by gender

Headcount by employment contract type

Employee turnover

Total employee departures in 2024: 265

Turnover rate: 18.6% (calculated as departures divided by total employees as of 31.12.2024)

Reasons for employee turnover

Geographic distribution

The geographic distribution of the Group's 1,585-person workforce (employees and self-employed) is mentioned as presented in a graph in the document, but specific country/region breakdowns by headcount are not provided in tabular format in these excerpts.

Methodology notes

• The term "permanent employees" refers to employees with indefinite employment contracts.
• The term "temporary employees" refers to employees with fixed-term employment contracts.
• Non-employees refer to self-employed individuals working for the Group.
• Certain projects (EXPANSION - UPGRADE OF THE HELLINIKON LANDFILL (PHASE B) REGION OF IOANNINA & CONSTRUCTION OF THE MILOS LANDFILL AND THE MILOS BIOWASTE COMPOSTING PLANT) were excluded from permanent and temporary employee counts.
• The HERHOF GMBH project is excluded from non-guaranteed hours reporting.

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

Total non-employees in own workforce

The total number of non-employees in the Group's workforce, as of 31.12.2024, amounted to 163, of which 137 were male (84%) and 26 were female (16%).

Breakdown by type

The Group's non-employees were all self-employed.

Gender breakdown

Methodology

The data is presented as headcount as of 31.12.2024. No comparative figures for prior years were disclosed for non-employees.

Diversity metrics

Gender diversity - Board of Directors

The Board of Directors comprises eleven members of Greek nationality, including eight men and three women.

Female representation: 27% (in compliance with Law 4706/2020 requirement of at least 25% representation)

Age distribution - Board of Directors

• Age 30-50: 4 members
• Age over 50: 7 members

Other Board characteristics

• Independent members: 36%
• Non-executive members: 91%
• Nationality: 11 members of Greek nationality
• Roles of Chairman and Chief Executive Officer not held by the same individual

Adequate wages

Target / Commitment

Ellaktor has committed to ensuring that 100% of employees are paid a living wage for a decent living by 2030. This target is part of the Group's ESG Strategy under the pillar "Adequate salaries" and "Equal treatment and equal opportunities for all".

The company has also committed to equal pay for work of equal value by 2030.

Planned Methodology

As part of its ESG action plan, the Group plans to conduct an evaluation of employee remuneration based on relevant studies to ensure adequate wages for a decent living. This assessment is listed as a planned action within the Group's sustainability initiatives.

The company also intends to implement monitoring and evaluation of indicators (KPIs) to track wage disparities.

Current Status

The excerpts indicate that the living wage assessment methodology is planned but not yet implemented. The company acknowledges in its forward-looking statement (p. 112) that future work will include "assessment of employees' remuneration based on relevant studies to ensure an adequate wage for a decent living" and notes this "will result in enhancing the Group's transparency on these issues as well as improving the quality of the KPIs disclosed."

Coverage and Benchmark

No specific living wage benchmark (e.g., Fair Wage Network, WageIndicator, Anker Methodology) is currently disclosed. No current coverage percentage or assessment results are reported. The methodology for calculating living wage, geographic scope, and whether the assessment covers all geographies where the Group operates are not yet specified.

Training and skills development metrics

Training hours targets

The company has set the following targets related to training:

• Maintaining an average of more than 25 hours of training per employee (target)
• 10 hours of average training per employee on H&S and well-being issues (Medium-term target, base year 2021, progress evolution 2024: 1.5)
• 100% of employees have basic digital skills by 2030 (Digital Transformation target)

Employee evaluation

• Evaluation of 100% of employees on an annual basis* (target)
  • *based on eligibility criteria

Health & Safety training delivered in 2024

• 2,078 hours of training on Health and Safety issues were carried out in 2024
• 542 employees of the Group took part in these trainings

Regulatory Compliance training delivered in 2024

• 90.5 hours of training on Regulatory Compliance were provided
• 102 employees participated

Health initiatives participation in 2024

• Breast Cancer Informative Talk: 69 employees participated
• Preventive Cardiac Screening: 149 employees underwent screening, plus 310 employees at Attikes Diadromes clinic
• Blood Pressure Measurement: 49 employees participated

Note: Average training hours per employee overall, by gender breakdown, and by employee category (executive/management/non-management) are not disclosed in quantitative form. The company discloses a target of maintaining more than 25 hours average training per employee and a specific H&S training target of 10 hours, with progress indicator of 1.5 for 2024, but does not provide the actual achieved average training hours or breakdowns by gender or employee category.

Health and safety metrics

Coverage by Health & Safety Management System

All the Group's companies have developed and implement Health and Safety Management Systems in accordance with ISO 45001:2018 standard, the processes of which concern all its employees. The employees covered by the certified system are 724 individuals (641 employees and 83 non-employees), which constitutes 51% of the total workforce of the Group.

Fatalities

In 2024, no fatal accidents, no occupational diseases and no deaths due to occupational diseases were recorded.

Regarding the injuries of subcontractors' employees, there were no accidents in 2024.

Work-related accidents and injuries

The Accidents-Incidents Frequency Rate has been calculated from the total number of accidents divided by the total working hours times 1,000,000. The rate shows the number of accidents per 1 million working hours.

In 2024, 1 high-consequence accident was recorded (as noted in the targets table).

Days lost

The lost days recorded due to the 16 accidents were 600. Accidents that led to loss of working days that continued in 2024 have also been taken into account.

Exclusions and scope notes

From the accident metrics, the following projects have been excluded: EXPANSION - UPGRADE OF THE HELLINIKON LANDFILL (PHASE B) REGION OF IOANNINA & CONSTRUCTION OF THE MILOS LANDFILL AND THE MILOS BIOWASTE COMPOSTING PLANT. The HERHOF GMBH project is also excluded from certain workforce metrics.

Incidents, complaints and severe human rights impacts

Severe human rights impacts

Ellaktor Group has signed the UN Global Compact, which promotes the adoption of 10 globally accepted principles in the areas of human rights, labor standards, the environment, and anti-corruption on an international level. The Group is committed to adhering to these principles during the exercise of its business activity, as well as in its collaborations with stakeholders.

Although child and forced labour have not been identified as a material issue through the double materiality analysis, it is worth noting that all employees are over 18 years old and, additionally, through the Human Rights Policy, the Group monitors compliance with these principles in relation to the above issues.

For the year 2024, the Group did not have any confirmed serious incidents of human rights violations and/or breaches reported to the Group's Human Resources Division or the Group's Regulatory Compliance Division.

Child and forced labour

All employees are over 18 years old.

Number of incidents

No confirmed serious incidents of human rights violations and/or breaches were reported in 2024.

The Group supports society through systematic social contribution initiatives, creating significant and long-term value for all shareholders, employees, the Greek economy, and society.

Social responsibility and integrity constitute key pillars of sustainable development for ELLAKTOR Group. The Group aims to create long-term value for shareholders, employees, clients and society at large, by incorporating environmental, social and corporate governance principles across all its business activities.

Taking action on material impacts on consumers

Internal and External Quality Audits

Description and scope: ELLAKTOR Group implements an integrated Quality Management System (QMS), which includes the process of regular internal inspections for the recording, assessment and management of non-compliance and concerns the entire workforce and end-users. Internal inspections ensure that potential risks are identified and corrective actions are taken.

Resources allocated:

• Non-financial: Personnel training; experienced personnel conducting inspections; external partners for specialised needs; quality engineers; Central Quality Management Department
• Materials: Utilisation of materials that meet essential health and safety requirements (legislation, health and safety, etc.), recorded through documentation provided by manufacturers/suppliers (e.g. performance declarations, laboratory analysis results)
• Financial: Not quantified

Implementation approach:

• Control procedures reviewed by quality engineers and Central Quality Management Department at regular intervals
• Inspections planned based on:
  • Frequency proportional to the significance/criticality of each action and findings of previous inspections
  • Timing selected to ensure efficiency early in production process and avoid disruption of works

Outcomes and monitoring:

• Results of inspections recorded and communicated to personnel responsible for inspected area
• Non-compliances recorded and managed in accordance with non-compliance management process
• Material non-compliances examined in QMS Review
• Effectiveness of QMS processes monitored through appropriate performance indicators and statistical techniques
• Corrective actions taken when discrepancies identified

Issues managed:

• Consumer complaints, requests, comments
• Service non-compliance
• Non-compliance with legal and other requirements
• Non-compliance with internal inspections and the QMS in general

Process stages:

• Recording of actual or suspected problem
• Analysis of cause
• Implementation of corrective actions to eliminate or reduce risks
• Review and improvement of procedures to ensure continuous effectiveness and efficiency

Targets related to consumers

In the context of the implementation of the Human Rights, Health and Safety and Quality Policies, to ensure the safety of infrastructure and the health and safety of users, as well as to protect their privacy, and taking 2023 as the basis, the Group has set the following goals:

Actions to achieve targets

• Sending satisfaction questionnaires to consumers and motorway end-users to enable expression of complaints for management
• Quality inspections in all projects to check effectiveness of certified Quality, Health and Safety Management Systems
• Training for employees who come into contact with customers and users to avoid data breach incidents
• Implementation of a Policy to protect personal data of consumers and end-users

Progress to date: Not disclosed.

ELLAKTOR Group operates in full alignment with its values and vision, aiming for sustainable growth. Business ethics constitute key pillars of sustainable development.

The Company has established and implements a comprehensive regulatory framework:

Code of Ethics: Includes the fundamental principles, rules and values that serve as the foundation for the Group's corporate activities, defining standards, ethical principles and expectations the Group has of its management, human resources and third parties.

Code of Conduct for Business Partners: Establishes integrity standards expected of all ELLAKTOR Group partners and is consistent with the Code of Ethics.

Anti-Corruption Policy: ELLAKTOR is committed to zero tolerance for bribery and corruption, follows all applicable anti-corruption laws, and conducts commercial activities in complete transparency. This Policy establishes a framework to prevent, deter and combat bribery, fraud and corruption.

Conflict of Interest Policy and Process: Establishes the Company's commitment to dealing with conflicts of interest and procedures for implementing preventive measures.

The Company has acquired certifications from external bodies including:

• Anti-Bribery Management System (ISO 37001:2016)
• Compliance Management System (ISO 37301:2021)
• Standard for the Governance of Organizations (ISO 37000:2021)
• Whistleblowing Management System (ISO 37002:2021)

ELLAKTOR is committed to applying high integrity standards to all of its business operations and activities, and has established an audit framework and criteria for establishing, maintaining and monitoring relationships with third parties (partners, suppliers, subcontractors, consortium members).

The Third-Party Due Diligence Policy allows for the monitoring of integrity risks posed by third parties, as well as the audit and assessment of their compliance with laws, regulations, standards, Group values, ESG targets, and other rules with the goal of ensuring that they meet the Company's integrity standards and ESG (Environmental, Social and Governance) principles.

The Code of Conduct for Business Partners establishes the integrity standards expected of all ELLAKTOR Group partners and is completely consistent with the Code of Ethics.

ELLAKTOR is committed to zero tolerance for bribery and corruption, follows all applicable anti-corruption laws, and conducts its commercial activities in complete transparency.

The Anti-Corruption Policy establishes a framework of obligations and guidelines to be used as a tool to prevent, deter and combat bribery, fraud and corruption and other unlawful actions and practices in general, while reinforcing the explicit commitment of the Group's Management to zero tolerance for such conduct.

Both ELLAKTOR and its significant subsidiaries have acquired the respective certifications from an external Certification Body for Anti-Bribery Management System Implementation (ISO 37001:2016).

Incidents of corruption or bribery

Confirmed incidents

Ellaktor Group reported zero confirmed incidents of corruption or bribery for the reporting period 2024. As stated in the Sustainability Statement:

"During the assessment of the Group's operations in 2024 in integrity issues and as reflected in the Group Integrity Risk Assessment, approved by the Company's Chief Executive Officer, the Group-level functions (Divisions and Departments) that are most exposed to potential integrity risks are Financial Services, Human Resources & Payroll, Bids, Procurement, Project Management, Information Systems and Legal Service.

A testament to the completeness, adequacy and effectiveness of the aforementioned system is that in 2024, there were no complaints in matters of corruption, bribery or anti-competitive conduct against the Group or its employees, and that the Group did not terminate any collaborations with employees or partners due to related issues."

Additionally, the Group stated: "no confirmed incidents of breach of internal information were recorded" in 2024.

Convictions and fines

No convictions or fines related to anti-corruption or anti-bribery violations were reported for 2024.

Disciplinary actions

The Group did not dismiss or discipline any employees due to corruption or bribery in 2024. The report confirms that "the Group did not terminate any collaborations with employees or partners due to related issues."

Contracts terminated

Zero contracts with business partners were terminated or not renewed due to corruption or bribery issues in 2024.

Investigation procedures and speak-up mechanisms

Ellaktor has established a comprehensive Whistleblowing Management System certified according to ISO 37002:2021. The Group provides alternative communication channels (phone, email, electronic platform Talk2Ellaktor, postal mail) through which reports can be submitted securely, either anonymously or confidentially. The platform is managed by an independent third party.

In 2024, three (3) reports were submitted relating to verbal confrontations, quarrels and harassment at work in subsidiaries (not classified as corruption/bribery). These were handled according to the Reporting Management Policy.

The Group maintains an Anti-Bribery Management System certified according to ISO 37001:2016 and a Compliance Management System certified according to ISO 37301:2021. The regulatory compliance function reports through the Vice Chairman to the Board of Directors.

Compliance audits conducted in 2024 covered the Anti-Bribery Management System, Compliance Management System, Whistleblowing Management System, integrity clauses in contracts, and Conflict of Interest procedures. No conflicts of interest incidents were recorded during these audits.

Training on integrity issues was provided in 2024, with 90.5 hours of Regulatory Compliance training delivered to 102 employees, covering anti-corruption, whistleblowing, and GDPR compliance topics.