Enagás

Enagas describes its administrative and governance structure. In 2024 the Board of Directors had 15 members, 73.3% independent and 40% women, with an average age of 60.5 years and average tenure of 6.5 years. It operates three committees: Audit and Compliance, Sustainability and Appointments, and Remuneration. A Board Diversity and Director Selection Policy sets principles of diversity, non-discrimination and legal compliance. The Board guides, oversees and monitors sustainability strategy, policies, risks, objectives and performance, mainly through its Sustainability and Appointments Committee. A Sustainability Committee, made up of Executive Committee members, reviews the materiality analysis and approves sustainability actions. The Chief Executive Officer manages the business, and the various General Managements identify, assess and manage material impacts, risks and opportunities by area (environment, people, supply chain, affiliates, customers, communities, ethics). The Executive Committee is 40% women. An annual Board assessment is carried out with an independent external expert, and a table cross-references directors' knowledge and skills with material sustainability issues.

Enagas explains how its governing bodies receive and address sustainability information. The Board of Directors is regularly informed, directly and through the Sustainability and Appointments Committee, which met six times in 2024. Information covers policies, actions, benchmarks and targets linked to material impacts, risks and opportunities, is provided to members before meetings, and is presented by the Executive Committee member responsible for the relevant sustainability team. Notable Board actions in 2024 included unanimous approval of the Annual Corporate Governance Report and Consolidated Management Report, approval of the sustainability materiality analysis, and approval of several policies covering cybersecurity and data governance, environment, health and safety, quality, human capital, sustainability and good governance, climate action, major accidents, security, human rights, fiscal matters and a code of conduct. The Board and committee also oversaw the 2025-2030 Strategic Update and risk management. At executive level, the Sustainability Committee met twice in 2024, chaired by the Energy Transition General Manager.

Enagas links sustainability performance to remuneration. Strategic priorities are set as annual targets tied to the variable remuneration of all professionals, including the Chief Executive Officer, connecting pay to environmental, social and economic goals. These annual targets are approved each year by the Board of Directors. Enagas also operates a Long-Term Incentive Plan (ILP) requiring fulfilment of objectives aligned with strategic priorities, approved on a triennial basis by the Board and then by the General Shareholders' Meeting. The 2024 annual targets were met with 84.2% compliance and the 2022 to 2024 long-term targets with 87.5%. Sustainability-related performance parameters used as benchmarks include reduction of CO2 emissions in line with the decarbonisation pathway, reduction of methane emissions, and total greenhouse gas reductions for Scopes 1 and 2, alongside diversity and inclusion measures. Under the ILP rules, failing the absolute total shareholder return target prevented recognition of over-achievement above 100%, reducing the incentive from 90.1% to 87.5%.

Enagas presents its statement on due diligence, grounded in its Human Rights Policy, which commits the company to developing and maintaining a due diligence system to anticipate, prevent, mitigate and remedy negative impacts on people (its own workforce and those in the value chain), the environment and society. The approach is based on continuous improvement and cooperation with stakeholders. Recurring actions include establishing mechanisms to identify, assess and prioritise actual and potential negative human rights impacts across all geographies; implementing measures to avoid, prevent or mitigate identified impacts; monitoring the effectiveness of actions taken; and being accountable to stakeholders through public reporting. Enagas provides a mapping table that links the core elements of due diligence, such as integration into governance and strategy, engaging affected stakeholders, identifying and assessing adverse impacts, adopting measures, and monitoring effectiveness, to the specific sections and disclosure requirements of the statement, including chapters 2, E1 to E5, S1, S3 and G1.

Enagas describes its risk management and internal controls over sustainability reporting. Since 2019 the Group has operated an Internal Control System over Sustainability Reporting (ICSSR) designed to reinforce the transparency and reliability of sustainability information, comparable to internal control over financial reporting. It was built on the COSO 2018 guidance for applying enterprise risk management to environmental, social and governance risks, structured around governance and culture, strategy and target setting, performance, review and monitoring, and information and reporting. The risk assessment considers relative importance based on materiality, and risks such as integrity, existence and occurrence, regulatory breach and manipulation, with the main risks being information integrity and manipulation. The model comprises general controls set by Senior Management and process controls embedded in key sub-cycles. Enagas reviews the system yearly for continuous improvement, and it is externally reviewed annually by EY through an agreed-upon procedures report, which is reviewed by the Audit and Compliance Committee. In 2024 the scope covered indicators across all three sustainability areas.

Enagas describes its strategy, business model and value chain. It is a midstream company with more than 50 years of experience and an independent European Transmission System Operator, founded in 1969, with a network of more than 11,000 km of high-pressure gas pipelines, stakes in six of the seven Iberian regasification terminals (three wholly owned, three part-owned), three underground storage facilities, 19 compressor stations and six international connections. It also acts as Technical Manager of the System and provisional Hydrogen Transmission Network Operator. Beyond Spain it holds affiliates in Germany, Italy, Greece, Mexico and Peru, among others. Enagas sells services rather than products, mainly Third-Party Network Access, individual, bundled and connection services. Its value chain spans upstream (supply chain with 1,836 approved suppliers, and affiliates) and downstream (customers). Net turnover in 2024 was about 913 million euros. The 2025-2030 Strategic Update focuses on security of supply, decarbonisation, green hydrogen infrastructure and new molecules such as carbon dioxide and ammonia through Scale Green Energy.

Enagas describes the interests and views of stakeholders. Its commitment is reflected in the Sustainability and Good Governance Policy approved by the Board, which includes mechanisms for collaboration, timely exchange of information, participation and transparent reporting. Enagas defines a stakeholder map identifying groups that influence and are influenced by its activities, reviewed annually by internal supervisors for segmentation, interaction type, relationship channels and contact frequency. Stakeholders include regulatory bodies, investors, professionals, customers, partners, media, suppliers, financial institutions, and representatives of local communities, associations and foundations, each with defined relationship channels. Information received is analysed and, depending on relevance, stakeholders' opinions and interests are incorporated into management models, with internal managers reporting results to the Board or Executive Committee. Consulting key stakeholders as part of the materiality assessment is cited as an example of integrating their views into strategy. In 2024 Enagas ran a non-binding Call for Interest process for the Spanish Hydrogen Backbone Network, whose results will help shape infrastructure design and modify the company's strategy.

Enagas presents the material impacts, risks and opportunities identified through its materiality analysis and how they interact with strategy and the business model, using a detailed table. Examples under climate change (E1) include the risk of operational cost overruns from natural disasters, the negative impact of high direct and indirect greenhouse gas emissions, transition risks around reputation, carbon neutrality commitments and financing conditions, and opportunities such as hydrogen infrastructure development and carbon dioxide transmission and storage. Other topics cover air pollution (E2), reduction in water resources (E3), biodiversity impacts from pipeline maintenance (E4), hazardous and non-hazardous waste generation (E5), and own workforce matters (S1) such as quality employment, collective bargaining, work-life balance and occupational health and safety. Each item is classified as impact, risk or opportunity, located across own operations, suppliers or customers, with current and anticipated effects and responses linked to relevant disclosure requirements. Enagas states that the identified risks and opportunities have not led to material adjustments to the current financial statements, nor are they anticipated to in the short term.

Enagas describes its double materiality process. It carried out a materiality assessment to identify issues material to the company's value (internal perspective) and to people and the environment (external perspective), across short, medium and long term, covering own operations and the value chain and consistent with strategy and corporate risk management. The process involves understanding context (regulatory framework, market and sector trends, stakeholder needs), identifying impacts, risks and opportunities using internal teams, recognised frameworks, analysts and peers, and conducting stakeholder surveys with customers, investors, regulators, professionals and Sustainability Committee members. Impacts are assessed by nature, remediability, status, probability, scale and scope, while risks and opportunities are assessed by degree, probability and economic valuation based on net profit and funds from operations. The Sustainability Committee reviews the analysis before Board approval, and the process is embedded in the internal control system. The result concluded that all ESRS sustainability issues are material except consumers and end users, with three issues of particular interest: regulatory compliance, information security and customers.

Enagas lists the disclosure requirements it fulfils after applying impact and financial materiality thresholds, presented in a detailed index with sections and page numbers. Under General Information it reports BP-1 and BP-2, the full set of ESRS 2 governance requirements GOV-1 to GOV-5, the strategy requirements SBM-1 to SBM-3, and the management requirements IRO-1 and IRO-2. The material topical standards are the climate and environmental standards E1, E2, E3, E4 and E5, the social standards S1, S2 and S3, and the governance standard G1. Consumers and end users (S4) is not a formally material standard because it is not part of the company's business model, but Enagas voluntarily discloses related content in an additional section of interest titled Customers. The report also notes the use of phase-in provisions under Appendix C of ESRS 1, specifically for the anticipated financial effects under SBM-3 and for E1-9, and identifies disclosures incorporated by reference.

Enagas' transition plan is its 2025 to 2030 Strategic Update, approved by the Board of Directors. It sets out the investments and actions needed to reach Net Zero by 2040 for Scopes 1 and 2 and by 2050 for Scope 3, defined using the cross-sector Science-Based Targets initiative (SBTi) methodology (targets not yet validated because SBTi has no Oil and Gas methodology). The plan follows two main courses: decarbonising the energy sector, prioritising hydrogen infrastructure through the subsidiary Enagas Infraestructuras de Hidrogeno S.L.U., and decarbonising own operations, mainly by electrifying turbocompressors with renewable-origin electricity (about 106 million euros CapEx by 2030, leaving 135,303 tonnes of CO2e as locked-in emissions by 2030). In 2024 Enagas allocated 7.0% of CapEx (over 5.8 million euros) and 2.5% of OpEx (nearly 1.7 million euros) to taxonomy-aligned mitigation activities. It expects 83% of planned investments by 2030 (3.365 billion euros) to be taxonomy-eligible, and estimates 87 million euros gross CapEx to natural gas activities in 2024.

Enagas has a Climate Action Policy, approved by the Board of Directors, covering climate change mitigation, adaptation, energy efficiency and renewable energy use. Its commitments include driving decarbonisation across the value chain by developing renewable gases, integrating physical and transition risks over short, medium and long term horizons, and establishing a decarbonisation pathway to Net Zero by 2040 for Scopes 1 and 2 and by 2050 for Scope 3, aligned with the 1.5C scenario. It applies the GHG mitigation hierarchy (energy savings and efficiency first, then renewable self-consumption, then offsetting residual emissions with nature-based solutions), embeds targets in short and long term variable remuneration, and requires regular carbon footprint calculation and verification. The policy was updated in 2024 to align with the ESRS developed by EFRAG. It applies to all Enagas Group companies globally and is accessible on the corporate website and intranet. The Board oversees performance through the Sustainability and Appointments Committee, while the Audit and Compliance Committee supervises climate risk. Suppliers are covered through the Ethical Principles and Guidelines for Suppliers.

Enagas implements its Energy Efficiency and Emissions Reduction Plan (PEERE) and holds ISO 50001 certification. Since 2015 it has cut CO2 emissions by 53%, and over 2015 to 2024 the plan avoided 1,130,332 tonnes of CO2e. Measures implemented in 2024 involved about 1.78 million euros OpEx (methane reduction) and 2.95 million euros CapEx, delivering 5.63 GWh of energy savings and 7,248.53 tCO2e of reductions, largely through leak detection and repair (LDAR) campaigns. The turbocompressor electrification plan covers 14 units over 2023 to 2040 (total 106 million euros CapEx; 2.7 million euros invested in 2024), expected to cut about 92,516 tonnes of CO2e by 2030 and 93,008 by 2040. Methane emissions fell 46% versus the 2015 base year, and Enagas earned the OGMP2.0 Gold Standard for the fourth consecutive year. Combined measures are expected to reduce emissions about 54% by 2030 and 86% by 2040 versus 2024. Purchasing renewable-guarantee electricity delivered a 19% reduction in total Scope 1 and 2 emissions. Enagas Renovable will receive 65 million euros of CapEx by 2030.

Enagas commits to Net Zero by 2040 for Scopes 1 and 2 and by 2050 for Scope 3, with a decarbonisation pathway defined using the Science-Based Targets initiative (SBTi) methodology (not yet validated, as SBTi has no Oil and Gas methodology). For Scopes 1 and 2 the base year is 2018 (304,758 tCO2e); 2024 real data was 228,157 tCO2e (down 25%); the 2030 target is 151,160 tCO2e (down 50.4%); and the 2040 Net Zero target is 23,162 tCO2e (down 92%). For Scope 3 the base year is 2021 (825,211 tCO2e); 2024 was 752,637 tCO2e (down about 9%); the 2030 target is 618,908 (down 25%); 2040 is 412,606 (down 50%); and the 2050 Net Zero target is 82,522 (down 90%). Methane targets under the Global Methane Alliance seek 45% reduction by 2025 and 60% by 2030 versus 2015. The 2024 Target Management Programme set a 5% Scope 1 and 2 reduction versus 2023 and achieved 22.6%. Targets are linked to variable remuneration and have not been externally assured.

Energy consumption data is 100% of primary origin, taken from meters or internal sources. Enagas consumes electricity with renewable guarantees of origin at 100% of its facilities; grid electricity carrying such guarantees was 100% of consumption, giving a zero emission factor. Total energy consumption in 2024 was 1,191,011 MWh, down 22% from 1,523,073 MWh in 2023. Total fossil energy consumption was 978,002 MWh (82.12% share), of which natural gas fuel was 967,881 MWh. Total renewable energy consumption was 206,026 MWh (17.30% share), including 155 MWh of self-generated renewable energy. Electricity consumption was reported at 216,018 MWh. Own electricity generation from renewable, clean or efficient sources reached 14,811 MWh, about 7% of total electricity consumption; 7,674 MWh returned to the grid helped reduce 1,995 tonnes of CO2 for third parties. Consumption from other clean sources (waste heat and pressure jumps) was 6,983 MWh. These parameters were verified by an independent third party (SGS) in line with ISO 14064.

Enagas' carbon footprint is ISO 14064:2019 certified and verified by SGS. Gross Scope 1 emissions in 2024 were 228,157 tCO2e, down 23% from 294,649 in 2023 (base year 2018: 274,458). Location-based Scope 2 was 52,003 tCO2e, while market-based Scope 2 was 0, since 100% of electricity carried renewable guarantees of origin. Gross Scope 3 was 752,636 tCO2e, up 4% versus 2023 (base year 2021: 825,211), driven mainly by downstream distribution. Total GHG emissions were 1,032,796 tCO2e location-based and 980,793 tCO2e market-based. By gas, Scope 1 and 2 split into CO2 77.2%, CH4 22.6% and HFCs 0.2%. Scope 1 methane was 1,850 tonnes of CH4, down 7% versus 2023, split between venting (63%) and fugitive emissions (37%). Compressor stations account for 67.2% of emissions and turbocompressors 66.5% of the source split. About 66.1% of the footprint falls under the EU ETS; 55,637 free allowances were received and 40,000 purchased in 2024.

Enagas' strategy prioritises reducing emissions and only then offsetting residual emissions that cannot be reduced for technical reasons, favouring nature-based solutions. In 2024 it spent 37,856 euros purchasing carbon credits to offset 8,520 tonnes of CO2e for the 2023 financial year. In 2025 it will cancel carbon credits covering 5,839 tonnes of CO2e for 2024, offsetting emissions from its regasification terminals, the Euskadour compressor station, the corporate fleet and headquarters, so those facilities maintain the carbon neutrality achieved in 2017 (2020 for Euskadour). Offsetting used avoided-deforestation projects in Peru and the Motor Verde reforestation project in Spain, developed by Repsol and Sylvestris. Credits cancelled in 2024 totalled 5,839 tCO2e, all from reduction projects, 98% under the Verified Carbon Standard. Expected future cancellation for 2025 is 5,986 tCO2e. Enagas is not working on GHG removal or storage projects in its own operations, nor has it contributed to any in its value chain. It plans to reach Net Zero by 2040 for Scopes 1 and 2, offsetting residual emissions with nature-based solutions.

Enagas applies an Internal Carbon Price uniformly across all facilities and business units. Its main uses are monetising GHG emissions and including them in business plans to optimise investment decisions, risk management, sustainability strategy planning, integration into climate change risk analysis for strategic and operational decisions, ensuring compliance with GHG regulations, and driving behavioural change to reduce emissions and increase energy efficiency and low-carbon investments. In 2024 the scheme covered 228,157 tonnes of Scope 1 CO2, equal to 23.3% of total generated emissions and 100% of Scope 1 and 2 emissions. The price is updated quarterly based on market forecasts. In 2024 an average price of 65.85 euros per tonne of CO2 was set, provided by the company SENDECO2. Forecasts for the 2025 to 2030 period were based on data from Carbon Pulse, which averages the estimates of many market analysts, and the 2040 figure was based on the International Energy Agency's Announced Commitments Scenario for advanced economies with Net Zero commitments.

Enagas applies the ESRS phase-in provision for this disclosure, stating it is working to ensure full compliance in future reporting years, but it already discloses quantified figures for several material risks and opportunities. For the physical risk of natural disasters, the medium scenario (RCP 4.5) has an estimated impact of 8.6% of net profit (24,802,656 euros) and the stress scenario (RCP 8.5) 15.5% of net profit (44,564,447 euros), with line-of-action management costs of about 6 million euros per year. Among transition risks, lower revenues from the extension of assets' useful life is estimated at 1.6% of net profit (6 million euros), while lower contribution from investees is 0.2% of net profit, with a worst case of 0.5%. Opportunities are rated hydrogen infrastructure development (High), new logistics services (Average) and CO2 infrastructure (Low). EU taxonomy-eligible investments for 2025 to 2030 total 3.365 billion euros (83% of planned investment), expected to drive average annual EBITDA growth of 2.5% from 2024 to 2030 and 9.5% from 2026 to 2030. Further detail is in Note 4.6 of the Consolidated Annual Accounts.

Enagas has an Environmental Policy approved by the Board of Directors that sets commitments for environmental protection and the Environmental Management System, including addressing atmospheric pollution identified as a relevant issue. Commitments cover preventing, controlling and mitigating negative impacts from non-greenhouse gas emissions (CO, NOx, SOx, PM10 and NMVOC), implementing preventive and corrective measures, and preventing environmental accidents. In 2024 the former combined Health and Safety, Environment and Quality Policy was split into three distinct policies for more effective implementation. The policy applies to all Enagas Group companies globally and effectively controlled affiliates, and is communicated to all employees and managers. It is accessible on the corporate website and Intranet. The Board, through the Sustainability and Appointments Committee, guides and supervises environmental strategy. Enagas also has a Climate Action Policy and applies principles to suppliers through its Ethical Principles and Guidelines for Suppliers.

Enagas fulfils its environmental commitments through its management system, with 100% of activity ISO 14001 certified. In 2024 more than 47 thousand euros in OpEx was allocated to certification for verifications and monitoring legal requirements. The Serrablo and Yela storage facilities and the Huelva and Barcelona regasification terminals are EMAS certified. Environmental monitoring uses audits, surveillance programmes and legal compliance assessments. To prevent atmospheric pollution, Enagas conducts regulatory monitoring and voluntary self-monitoring of combustion sources. In 2024 at compressor stations, 40 periodic regulatory inspection measurements were carried out (90% favourable) costing 46,799 euros OpEx, and 40 TESTO checks (95% favourable) costing 9,921 euros OpEx. Unfavourable measurements trigger maintenance and re-measurement. Similar controls are planned for 2025 under the Atmospheric Monitoring Programme. Enagas also applies mitigation through its Energy Efficiency and Emission Reduction Plan.

Because of the nature of these atmospheric emissions, the company's CO2 reduction targets are directly linked to reducing the specified non-greenhouse gas emissions. For 2024 Enagas voluntarily set an annual target to reduce NOx emissions by 5% compared to 2023 levels (0.03 Kg NOx per GWh of activity) across all facilities, achieved mainly through the Energy Efficiency and Emissions Reduction Plan. This is a preliminary target, which Enagas met in 2024 with a 19% reduction compared to the previous year (249 tonnes in 2023 versus 191 tonnes in 2024). This aligned with a 22.6% reduction in scope 1 and 2 emissions and exceeded the roughly 4% fall in natural gas demand. The target is not based on scientific criteria and stakeholders were not involved in setting it. Compliance and improvement actions are reviewed annually through monitoring of natural gas and diesel consumption.

Enagas reports non-GHG emissions in tonnes for 2022, 2023 and 2024. NOx fell from 329 to 249 to 191. CO fell from 44 to 41 to 29. SOx moved from 4 to 4 to 3. PM10/PST was 3, 5 and 3. NMVOC fell from 11 to 10 to 7. NH3 fell from 8 to 6 to 5. Smaller quantities are reported for PAH, cadmium, chromium, copper, mercury, nickel, lead, zinc and benzene (benzene 0.039, 0.03 and 0.024 tonnes). Values are calculated from fossil fuel consumption data drawn from Enagas' Reading and Measurement System software and fuel purchase invoices, using pollutant-specific emission factors from the EMEP/EEA air pollutant emission inventory guidebook 2023 of the European Environment Agency. This calculation method is used because direct measurements are not taken annually at all emission sources.

Enagas' materiality analysis did not identify any significant risks or opportunities associated with pollution. However, the company holds an environmental liability policy that covers the costs of preventing and remedying any damage to the environment inside or outside its facilities, with an annual aggregate liability limit of 20 million euros per claim. It also holds an industrial liability policy covering compensation payments to third parties arising from sudden, accidental and unforeseen pollution or contamination, with a limit of 300 million euros per claim. Enagas also reports that it received no significant environmental fines or penalties during 2024 or 2023.

Enagas has an Environmental Policy approved by the Board of Directors that sets commitments for environmental protection and the Environmental Management System, including commitments on water and marine resources (use and consumption of water), identified as important issues. Key commitments include minimising water consumption and using marine resources responsibly, using more sustainable water supply methods, and preventing and addressing potential water pollution from activities. In 2024 the policy was revised after splitting the former combined Health and Safety, Environment and Quality Policy into three distinct policies. It applies to and is communicated to all employees and managers of Enagas Group companies across all regions, including areas facing water risk and high water stress. It is accessible on the corporate website and Intranet. The Board, through the Sustainability and Appointments Committee, guides and supervises environmental strategy, and supplier commitments are addressed through the Ethical Principles and Guidelines for Suppliers.

Enagas fulfils its environmental commitments through its management system, with 100% of activity ISO 14001 certified. In 2024 more than 47 thousand euros in OpEx was allocated to certification for verifications and monitoring legal requirements, and the Serrablo and Yela storage facilities and the Huelva and Barcelona regasification terminals are EMAS certified. Water consumption is a noteworthy environmental aspect monitored yearly through audits and surveillance programmes. The company has a General Plan for Reducing Water Consumption and monitors consumption trends at facilities. In 2024 measures included rainwater recovery systems and mechanical weeding to replace water-diluted herbicides in water-risk areas. At the Barcelona regasification terminal, reduced irrigation and greater use of the desalination plant achieved a 73% reduction in consumption compared to 2022, and pesticide use fell from 1,300 litres in 2022 to 350 litres in 2024. Mechanical weeding cost 28,123.50 euros OpEx in 2024. Measures were deployed in high water stress areas per the WRI Aqueduct tool.

Enagas voluntarily established targets to cut water consumption at facilities deemed significant, implementing measures to meet them. Globally, the 2024 aim was to decrease annual sanitary water collection from municipal networks by 2% compared to 2023 levels, a reduction of 1,789 m3, across all company facilities. This preliminary target focused on facilities where water use exceeded their three-year average consumption. In 2024 Enagas achieved the target with a 25.2% reduction in water withdrawal from the public network compared to the previous year. The voluntary target aligns with the Environmental Policy commitment to minimise impacts and dependencies on less significant environmental factors such as water consumption. The target is not based on scientific criteria or ecological thresholds and stakeholders were not involved in setting it. Compliance is monitored annually through evaluation of environmental aspects.

Enagas does not consume water in its production processes. Water consumption in 2024 was 55,866 m3 (including 2,209 m3 of seawater collected at the Barcelona terminal for desalination), representing only 0.001% of total water withdrawn. Water collected was 272,635,121 m3 in 2024 (306,916,449 in 2022; 270,498,111 in 2023). Water discharged was 272,579,255 m3 in 2024. Water consumed (collected minus discharged) was 55,866 m3 in 2024, versus 53,426 in 2022 and 90,279 in 2023. Seawater used in floodwater vaporisers at regasification terminals accounts for 99.9% of water withdrawn and is returned with minimal temperature change. Water collected from other sources (municipal network) fell from 89,465 m3 in 2023 to 66,702 m3 in 2024, a 25.2% reduction. Of 75,183 m3 withdrawn from surface, groundwater and public mains, 20,450 m3 were discharged. Water intensity relative to revenue was 61.2 m3 per million euros in 2024.

In its materiality analysis, Enagas did not identify any material risks or opportunities related to water and marine resources. However, the company holds an environmental liability policy that covers the costs of preventing and remedying any damage to the environment inside or outside its facilities, with an annual aggregate liability limit of 20 million euros per claim. It also holds an industrial liability policy covering compensation payments to third parties arising from sudden, accidental and unforeseen pollution or contamination, with a limit of 300 million euros per claim.

Enagas analyses biodiversity and ecosystem risks and opportunities to reduce vulnerability and strengthen the resilience of its business model, assessing impacts across each phase of a facility's life cycle from construction to decommissioning. So far the analysis has focused mainly on the operation phase, where it identified an impact of relative importance. Enagas states it has implemented the actions needed to manage this impact without significant changes to its existing business model or strategy. The 2025 to 2030 Strategic Update focuses heavily on new construction projects, exposing the company to potential cost overruns, delays or unavailability tied to protected species or biodiversity. Enagas is examining impacts and opportunities of the future hydrogen network, developing Initial Project Documents to identify environmental impacts and propose mitigation, and preparing Concept Plans for Public Participation in areas likely to be affected.

Enagas has an Environmental Policy approved by the Board of Directors that sets commitments on biodiversity and ecosystems. Key highlights include integrating biodiversity conservation into design, construction, operation, maintenance, technical management and dismantling of infrastructure; preserving ecosystems through the impact mitigation hierarchy; minimising installations in protected areas; prioritising expansion of existing pipelines over new routes; and preventing habitat fragmentation. In 2024 the policy was revised after the former combined Health and Safety, Environment and Quality Policy was split into three distinct policies. Enagas remains committed to its policy of no net loss and net positive impact on nature and biodiversity. The policy applies to all Enagas Group companies globally, is communicated to employees and managers, is accessible to stakeholders on the corporate website and Intranet, and is promoted among contractors and suppliers. The Board, through the Sustainability and Appointments Committee, oversees environmental strategy and related risks.

Enagas manages biodiversity through an impact mitigation hierarchy: avoiding impacts on sensitive areas, applying nature-based solutions, and matching habitats and species during restoration and compensation. It conducts annual environmental assessments and Environmental Impact Assessments covering 802 operational facilities occupying 3.8 km2, and has not established biodiversity offsets as part of its mitigation measures. Since 2016 Enagas has controlled vegetation along pipelines through extensive livestock grazing, including sections in Huesca and the Alto Bernesga Biosphere Reserve. In 2024 it spent 66,815 euros (OpEx) on this project, which includes sampling of landscape and arthropod biodiversity indicators. Enagas also holds a five-year partnership with the Bearded Vulture Conservation Foundation, allocating 15,000 euros in 2024, and teamed up with the FAPAS foundation to conserve the brown bear in the Valgrande-Pajares Valley, contributing 85,320 euros in 2024. It also runs species recovery and soil restoration programmes.

Enagas has set biodiversity targets for all construction activities, aligned with the Kunming-Montreal Global Biodiversity Framework and the EU Biodiversity Strategy, and with its Environmental Policy commitments to achieve no net loss of biodiversity in energy infrastructure construction and operation by 2040 and to create a positive impact on nature by 2050. By 2024 it aimed to restore 100% of areas affected by construction projects from the second half of 2023 not fully restored the prior year, plus all first-half 2024 projects (57,146 m2 restored). This goal was met, with 100% restoration of altered areas on the alternative route of the Leon-Oviedo gas pipeline project. The target also applies in 2025 with the objective of restoring 100% of the affected area. Enagas also uses biodiversity offset strategies such as carbon credits from deforestation prevention projects and collaborative projects. Achievement is assessed at project level after completion and reviewed annually over a two-year interval.

In 2024, Enagas' priority infrastructures, defined as the gas pipeline network analysed as a single site, occupied a surface area of 4.5 km2 of land located in Protected Natural Spaces, including the Natura 2000 Network (LIC/ZEPA), Ramsar wetlands and Biosphere Reserve, representing 11% of the total area occupied by the company's facilities. During the year, several construction projects used corridors of existing infrastructure and existing accesses to reduce damage to soil and waters. These projects restored 100% of the affected land, returning it to its previous state as soon as possible after alteration, with 57,146 m2 altered, 57,146 m2 restored and 31,730 m2 revegetated. Enagas states this minimises erosion risk and helps re-establish the land's natural watershed and the state of affected habitats and landscape. Enagas also identified IUCN Red List species around its facilities, including 35 critically endangered and 84 endangered species along gas pipelines, without this signifying an impact.

The materiality analysis did not reveal any significant risks or opportunities associated with biodiversity and ecosystems. However, Enagas holds an environmental liability policy covering the costs of preventing and remedying any damage to the environment inside or outside the company's facilities, with an annual aggregate liability limit of 20 million euros per claim. It also holds an industrial liability policy covering compensation payments to third parties arising from sudden, accidental and unforeseen pollution or contamination, with a limit of 300 million euros per claim. No further quantified anticipated financial effects from biodiversity and ecosystem-related risks and opportunities are disclosed, consistent with the conclusion that no material biodiversity risks or opportunities were identified in the materiality assessment.

Enagas has an Environmental Policy, approved by the Board of Directors, that addresses efficient resource use and the circular economy. A key focus is managing towards zero waste by following the waste hierarchy and prioritising waste prevention. In 2024 the policy was revised after the former combined Health and Safety, Environment and Quality Policy was split into three distinct policies. The policy applies to all Enagas Group companies globally, is communicated to employees and managers, is accessible to stakeholders on the corporate website and Intranet, and is promoted to affiliates, joint ventures, contractors and suppliers. The Board, through the Sustainability and Appointments Committee, guides, supervises and controls environmental strategy and manages related risks. Through the Ethical Principles and Guidelines for Suppliers, Enagas expects suppliers and contractors to preserve natural capital, addressing waste management, recovery and resource efficiency.

Enagas fulfils its environmental commitments through its management system, with 100% of activity ISO 14001 certified. In 2024 it allocated more than 47 thousand euros (OpEx) to certification for verifications and legal monitoring, while the Serrablo and Yela storage facilities and the Huelva and Barcelona regasification terminals are EMAS certified. In 2024 Enagas renewed the AENOR Zero Waste certification and recycled and/or recovered 95.7% of waste generated (91.6% in 2023), allocating more than 659 thousand euros (OpEx) for waste management. At the Serrablo underground storage facility, a methanol water regeneration plant recovered 121,103 litres of methanol in 2024 (8,366 litres in 2023) by treating 1,204.07 tonnes of methanol-laden water, saving 108,366 euros in external waste management costs. Other actions include recycling triethylene glycol at Yela and Serrablo, a collaboration with Oroel on protective clothing durability, and donations of unused merchandise and books to NGOs.

Through its contracts with waste managers, Enagas sets an annual target of treating (recycling or recovering) a percentage equal to or greater than 90% of all hazardous and non-hazardous waste generated during the year, and has a plan to increase waste recovery and minimise waste generation. In 2024 Enagas met its goal of recycling and/or recovering 90% of total waste generated, equating to a target of 2,522.28 tonnes recycled/recovered, with an actual recovery or recycling rate of 95.7% (2,682.85 tonnes recycled/recovered). The Serrablo underground storage facility set a target to regenerate at least 50% of the methanol-laden water it produces each year (1,471.15 tonnes managed in total); by 2024 it exceeded this, treating more than 81.8% of the methanol water generated (1,204.07 tonnes). These voluntary targets align with the waste hierarchy and the AENOR Zero Waste certification, and are monitored quarterly.

Enagas does not use raw materials in its production process and only consumes auxiliary materials. As a result, no significant impacts, risks or opportunities have been identified related to resource input. Enagas remains committed to promoting the circular economy through the efficient use of these auxiliary materials, reducing consumption, pollution, waste generation and environmental impact while encouraging innovation. The main auxiliary materials include tetrahydrothiophene (THT), sodium hypochlorite, chlorine dioxide, methanol and triethylene glycol (TEG). In 2024 consumption was: THT 132,752 kg (391,783 kg in 2023); sodium hypochlorite 397,370 kg (554,282 kg in 2023); chlorine dioxide 3,920 kg (9,946 kg in 2023); methanol 597,756 litres (431,894 in 2023); and TEG 7,825 litres (3,127 in 2023). Methanol consumption rose 38% and TEG rose 150% versus 2023, tied to a more than 26% increase in gas extraction activity.

Enagas describes resource outflows and circularity for waste from natural gas transmission and storage, classified under European Waste Catalogue LER codes. In 2024 it produced no waste containing mercury (05 07 01*) or sulphur (05 07 02); the 05 07 99 category included wood and inert industrial materials. The main hazardous waste is methanol-laden water from separating liquid and gaseous phases, its generation tied to gas demand; other hazardous wastes include depleted TEG, water-oil-detergent mixtures, aqueous cleaning fluids, absorbents, rags, filtering materials and nickel-cadmium batteries. Naturally occurring radioactive waste from gas contact with geological structures is transferred to ENRESA; 0.0083 tonnes were generated in 2024 (0.0451 in 2023). Non-hazardous domestic waste includes municipal solid waste, rubble, scrap metal and paper. A waste management platform ensures traceability, with data based on direct measurements from waste managers and verified by AENOR under its Zero Waste certification.

In its materiality analysis, Enagas did not identify any significant risks or opportunities associated with resources and the circular economy. However, the company holds an environmental liability policy covering the costs of preventing and remedying any damage to the environment inside or outside its facilities, with an annual aggregate liability limit of 20 million euros per claim. It also holds an industrial liability policy covering compensation payments to third parties arising from sudden, accidental and unforeseen pollution or contamination, with a limit of 300 million euros per claim. No further quantified anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities are disclosed, consistent with the conclusion that the materiality assessment identified no material risks or opportunities in this area.

In 2024 Enagas generated 2,802.5 tonnes of total waste (2,958.5 in 2023; 2,464.0 in 2022). Of this, 2,682.8 tonnes were recovered, a recovery rate of 96% (92% in 2023, 91% in 2022), while 119.7 tonnes were disposed of, a disposal rate of 4% (8% in 2023). By type, non-hazardous waste totalled 960.2 tonnes, of which 894.6 tonnes went to total recovery (668.8 recycling plus 225.8 other recovery) and 65.6 tonnes to elimination (14.1 to landfill and 51.5 other disposal). Hazardous waste totalled 1,842.4 tonnes, of which 1,788.3 tonnes went to total recovery (0.4 preparation for reuse, 1,637.7 recycling, 150.2 other recovery) and 54.1 tonnes to elimination (7.1 incineration without energy recovery, 2.0 to landfill and 45.0 other disposal). Solid waste generated totalled 611.2 tonnes, with 589.8 tonnes recovered or recycled and 21.4 tonnes eliminated. Radioactive waste of 0.0083 tonnes is excluded from these figures.

Enagas manages its own workforce through several policies: the Human Capital Management Policy, Human Rights Policy, Diversity and Inclusion Policy, Health and Safety Policy, Code of Ethics, and the Collective Bargaining Agreement. The Human Capital Management Policy and the Human Rights Policy were both updated in 2024, the latter to strengthen the human rights due diligence system in line with EFRAG standards, the proposed Sustainability Due Diligence Directive, and OECD guidance. In 2024 the Health and Safety Policy was split out from the former combined Health, Safety, Environment and Quality Policy into three distinct policies. The Human Rights Policy aligns with the UN Guiding Principles, the UN International Bill of Human Rights, OECD guidelines, and the ILO Declaration. The Board of Directors oversees strategy, policies and objectives. Policies apply to all Enagas Group companies and, except the Collective Bargaining Agreement, also to non-employee workers. Enagas signed the Group's IV Collective Bargaining Agreement (2023 to 2026) in 2024.

Enagas has established procedures and channels for own workforce to raise concerns and needs on material labour issues. As part of its Global Employee Listening Strategy, it has run a workplace climate survey every two years since 2008; the voluntary, anonymous and confidential 2024 survey reached 78 percent participation (77 percent in 2022). Collective bargaining is a key channel; in 2024 the company signed the Group's fourth collective bargaining agreement following negotiations with workers' representatives, and held working group meetings on the agreement, the Equality Plan, the Pension Plan and the LGBTI panel. Within the Digital Transformation Plan, mechanisms include the 'Transforma' inbox and challenge-solving events. On health and safety, Health and Safety Committees meet every three months, and workers have access to a suggestions box, bulletin boards, meetings, a chatbot and other channels. Enagas also evaluates psychosocial factors every five years. The People and Transformation General Manager, who sits on the Executive Committee and reports to the CEO, ensures effective collaboration.

Enagas provides its own workforce with several mechanisms to raise and address negative impacts or complaints. The Whistleblowing Line is available to all workforce and third parties to report irregularities, illegal acts or breaches of the Code of Ethics, managed under a procedure with a no-retaliation policy (see G1-1). For workplace harassment, Enagas has a Prevention and Action Protocol covering psychological, sexual, gender and other harassment, brought into line with 2024 legal provisions; victims may use the Whistleblowing Line or report verbally to the Head of the People and Diversity General Management. The Ethical Compliance Committee manages this protocol and ensures prompt, diligent investigation. Workforce can also directly contact the teams responsible for employment issues by email, telephone or in person, or contact trade unions and workers' representatives. In health and safety, an internal procedure allows reporting of risks or anomalies without reprisal, through Health and Safety Committees, an electronic suggestions mailbox, and a SACE platform mailbox for contractors and suppliers. A digital Integrated Management System tracks corrective actions.

Enagas took actions across each material impact. To maintain stable, quality employment it kept high permanent and full-time contract shares and allocated over 105 million euros to wages and salaries; its minimum wage was 1.66 times the Spanish minimum. To support satisfaction it ran the 2024 climate survey with 78 percent participation, 71 percent overall satisfaction, an 82 percent sustainable engagement index, a 76 percent employee experience score, and an eNPS of 42 (Spain average 5); 94 percent consider Enagas a good place to work. It signed the IV Collective Bargaining Agreement, maintained more than 120 (128) work-life balance measures and its A+ Family-Friendly Company certification, and allocated over 3.2 million euros to external pension funds. Health and safety actions included ISO 45001 and ISO 39001 systems, psychosocial assessment of 600 professionals, and an Emotional Well-being programme. Diversity spending exceeded 110 thousand euros. Training investment exceeded 1.8 million euros. Human rights assessments across 2024 found no violations, so no remediation was needed.

Enagas set voluntary targets across its material topics, mostly linked to variable remuneration. For stable, quality employment it aimed to keep a minimum wage above the national minimum, achieving 1.66 times in 2024. For satisfaction it aimed to keep the sustainable engagement index at 82 percent, which it achieved. For work-life balance it aimed to keep its efr (Family-Friendly Company) excellence level, met with 128 measures for 100 percent of employees. All health and safety targets were fully achieved, with 100 percent of planned measures met, including 100 percent of hydrogen training courses and planned crisis drills. Diversity targets included 40 percent promotion of the less-represented gender in management (achieved), 46 percent of hires from the less-represented gender against a 40 percent target, 40 percent women on the Board (achieved), and 41 percent women in managerial and pre-managerial positions (target 40 percent). Training targets of over 90 percent penetration (achieved 99.1 percent) and 75 percent performance reviews (achieved 79.1 percent) were met. No measurable human rights targets were set for 2024.

At year-end 2024 Enagas had 1,362 employees (1,353.2 full-time equivalents), comprising 409 women, 952 men and 1 person recorded as 'Other' (voluntarily reported). This compares with 1,354 employees in 2023 and 1,365 in 2022. Almost all employees are in Spain (1,359), with 3 in Belgium. Employment is stable and mostly permanent and full-time: 1,315 permanent and 47 temporary employees, and 1,323 full-time and 39 part-time employees. By gender, permanent staff numbered 386 women and 929 men. Enagas has no zero-hours contracts. During the year 48 employees left (down from 72 in 2023 and 91 in 2022). The voluntary turnover rate was 2 percent (3 percent women, 1 percent men) and the absolute turnover rate was 4 percent (6 percent women, 3 percent men). The average number of employees during the year was 1,354. For confidentiality and given non-materiality of the 'Other' gender, sex information was used in gender breakdowns.

In addition to employees, Enagas uses non-employee workers in its own workforce. The most notable are people hired through temporary employment agencies, mainly to stand in for professionals temporarily absent (for example long-term sick leave, paternity or maternity leave), and people holding training scholarships. At year-end 2024 there were 13 workers hired through employment agencies (13 in 2023, 9 in 2022) and 70 workers with training scholarships (55 in 2023, 45 in 2022). The average number during the year was 45 agency workers (32 in 2023, 30 in 2022) and 159 scholarship workers (127 in 2023, 136 in 2022). Enagas states it has no independent contractors among its non-employee workers.

Enagas has its own collective bargaining agreement for the Enagas Group covering more than half of all employees. Coverage of the collective bargaining agreement in Spain was 52.9 percent in 2024, up from 51.6 percent in 2023 and 50.8 percent in 2022. Enagas only has more than 50 salaried employees in Spain. For employees not included in the Group agreement, working conditions are governed by the Spanish Workers' Statute; however, those conditions of the Group agreement that improve on the Workers' Statute apply to 100 percent of the workforce. All employees in Spain, except the CEO, are represented by workers' representatives, equal to 99.9 percent of the workforce in 2024. Enagas does not have a European Works Council.

In senior management at year-end 2024 there were 38 people, of whom 14 were women (37 percent) and 24 men (63 percent), down from 40 senior managers in 2023 (40 percent women). The Executive Committee, one level of reporting to the CEO, had 10 members, 4 women (40 percent) and 6 men (60 percent), up from 33 percent women in 2023 and 2022. Other senior managers, two levels from the CEO, numbered 28, with 10 women (36 percent) and 18 men (64 percent). Across the total workforce, women represented 30 percent and men 70 percent (409 women, 953 men in the age table). By age group, 6.5 percent of employees were under 30 years, 58.1 percent were 30 to 50 years, and 35.4 percent were over 50 years. For confidentiality and given non-materiality of the 'Other' gender, sex information was used in the breakdowns.

The Enagas compensation model factors in equality and non-discrimination, with remuneration based on professional worth, skills, experience, responsibility and results achieved. The Enagas Collective Bargaining Agreement sets salary levels based exclusively on objective work criteria. In 2024 the Enagas minimum wage set in the Collective Bargaining Agreement was 1.66 times the minimum interprofessional wage in Spain, without distinguishing by gender, up from 1.5 times in 2023. Enagas concludes that all employees receive an adequate salary according to the benchmark index in Spain. At year-end there were three employees outside Spain, in Belgium; for reasons of confidentiality and non-materiality, Enagas does not publish the ratio of average salary to that country's minimum wage.

Enagas states that all employees are covered by social security for major life events through governmental programmes, sometimes topped up by the company. For illness, employees are entitled to free health care and cash benefits for temporary disability, with Enagas adding an allowance paying 100 percent of the fixed gross annual salary in the event of illness, accident or parental leave and childcare. Unemployment benefit is available from the moment the professional works for the company. For workplace accidents and acquired disability, social security provides financial, medical and rehabilitation coverage, and Enagas provides group death and disability insurance and subsidises 90 percent of private medical insurance for professionals and 100 percent for their children. On parental leave, statutory maternity and paternity leave is 16 weeks for each parent, plus fifteen paid working days for breastfeeding. On retirement, employees receive a state pension, and those with two years of service have a company pension plan.

Enagas works towards social and labour inclusion of persons with disabilities through direct hiring, with ten people with disabilities in the workforce at year-end 2024 (seven at the end of 2023 and 2022), and through indirect job creation for severely disabled profiles via collaboration agreements with foundations and special employment centres. The percentage of employees with disabilities at year-end 2024 was 0.73 percent in total (0.52 percent in 2023, 0.51 percent in 2022), broken down as 0.49 percent for women and 0.84 percent for men. Enagas holds Bequal Foundation PLUS category certification, renewed and valid until November 2025, and has taken accessibility actions such as removing architectural barriers and achieving an 'AA' website accessibility level. Information on employees with disabilities is collected from human resources tools based on data provided voluntarily by professionals themselves.

In 2024, 79 percent of employees participated in performance appraisals (79 percent in both 2023 and 2022), with 77 percent of women and 80 percent of men assessed; the CEO is excluded. By group, 100 percent of managers, 83 percent of women and 69 percent of men technicians, 84 percent of women and 100 percent of men administrative staff, and 19 percent of women and 90 percent of men operational staff were appraised. The average number of training hours per employee was 57.2 (58.1 in 2023, 55.1 in 2022), with women averaging 69.9 hours and men 51.7 hours. The training penetration rate reached 99.1 percent (94.9 percent in 2023) and average investment was 1,138.9 euros per professional (1,096 euros in 2023). Total training investment (OpEx) exceeded 1.8 million euros, up from 1.5 million euros in 2023. Training satisfaction reached 8.9 out of 10. Development tools include the Workday platform, coaching (35 participants), internal mentoring (53 participants) and the Leadership Development Programme.

The Enagas Group Health and Safety Management System is certified under ISO 45001 and covers 100 percent of employee and non-employee workers plus value chain workers at company facilities. In 2024 there were zero deaths from workplace injuries or work-related health issues among employees, non-employee workers and value chain workers (one value chain death occurred in 2022). Employees had 6 recordable workplace accidents in 2024 (11 in 2023, 10 in 2022), with a recordable accident rate of 2.75 per million hours worked (4.89 in 2023). Non-employee workers had 0 recordable accidents. Value chain workers at company facilities had 5 recordable accidents, with a rate of 2.72 (6.21 in 2023). No 2024 accidents had major consequences, the main types being falls and blows. Hours worked totalled 2,183,120 for employees and 111,577 for non-employee workers. Days lost due to injuries, illness and deaths were 56 for employees (134 in 2023) and zero for non-employee workers. No occupational illnesses were identified in the last three years.

At Enagas, 100 percent of employees of both genders are entitled to statutory maternity and paternity leave (currently 16 weeks for each parent) and to fifteen paid working days to care for a child under nine months of age (breastfeeding). All employees are also entitled to carer's leave, such as five days' leave to care for a first- or second-degree relative in cases of serious illness, hospitalisation or surgery. Pregnant women whose job poses a risk are entitled to risk leave during pregnancy. This family leave is set out in the Enagas Group Collective Bargaining Agreement and the Workers' Statute. Employees with children may also take cumulative unpaid leave of up to eight weeks before the child turns eight. In 2024, of employees entitled to family leave, 29.7 percent took it, broken down as 27.1 percent of women and 30.8 percent of men. For confidentiality and given non-materiality of the 'Other' gender, sex information was used in the breakdown.

Enagas reports the gender pay gap as the difference between average hourly pay of female and male employees, expressed as a percentage of male pay. The total gap in 2024 was 2.55 percent (1.29 percent in 2023, 1.88 percent in 2022). By group in 2024: other members of the Executive Committee 9.62 percent, other managers 2.22 percent, technicians 5.79 percent, administrative workforce -4.87 percent, and operational workforce 15.38 percent. The CEO is not applicable as there are no women in that group. The calculation covers Spanish employees present all year (94.6 percent of the workforce) and uses base salary, variable remuneration and long-term savings payments; allowances and overtime were excluded in 2024. The administrative gap reflects a category that is 88 percent women, and the operational gap reflects 87.5 percent men with greater seniority (15.2 years for men versus 4.8 years for women). The ratio of the CEO's total annual remuneration to the average for all other employees was 27.3 times (28.8 times in 2023).

Enagas reports that during the 2024 financial year there were no communications received through the Code of Ethics, other company reporting channels, or the OECD National Contact Points for Multinational Enterprises. In addition, no cases of discrimination and no serious human rights incidents were identified. This is consistent with the human rights due diligence assessments, which across 2024 and the prior two years (covering 100 percent of assets over the last three years) found no human rights violations, so no remediation actions were required. Redress mechanisms available include the procedure for managing consultations and reports on irregularities or Code of Ethics breaches, self-protection and emergency plans, compensation procedures for gas pipeline routes, the Whistleblowing Line accessible to all stakeholders, the Ethical Compliance Committee, and dedicated corporate mailboxes.

Enagas manages risks tied to value chain workers mainly through its Code of Ethics, which is mandatory for contractors, suppliers, collaborators and business partners, who confirm their commitment by accepting the general contracting conditions. More specifically, the company developed the Ethical Principles and Guidelines for Suppliers of the Enagas Group, aligned with the Code of Ethics, setting out human rights guidelines and encouraging suppliers to follow the UN International Bill of Human Rights, the OECD Guidelines for Multinational Enterprises, the ILO Declaration and its core conventions, and the European Convention on Human Rights. Suppliers must adhere to the Enagas Human Rights Policy, with explicit references to child labour, forced labour, freedom of association and collective bargaining. The Human Rights Policy, approved by the Board of Directors, applies to both the workforce and value chain workers. It was updated in 2024 to strengthen the due diligence system, assigning the Board oversight responsibility and the Sustainability Committee monitoring duties. All policies are available on the corporate website and Intranet. In 2024 no human rights violations were identified upstream or downstream.

Enagas reports that its materiality analysis did not reveal any significant potential or actual negative impacts on value chain workers. Consequently, the company does not describe additional specific processes for engaging directly with value chain workers about impacts under this disclosure requirement. Broader engagement, oversight and human rights due diligence activities affecting suppliers, contractors and affiliates are addressed through the company's Code of Ethics, the Ethical Principles and Guidelines for Suppliers, and the Human Rights Policy, which commit the company to prior information, participation, dialogue, consultation and collaboration with stakeholders so their needs and expectations are known to the company and, where appropriate, incorporated into its management.

Enagas reports that its materiality analysis did not reveal any significant potential or actual negative impacts on value chain workers, so no dedicated remediation process is described specifically under this disclosure requirement. However, the company maintains general redress procedures where non-compliance with human rights occurs, including the procedure for managing consultations and reporting irregularities or breaches of the Code of Ethics, self-protection and interior emergency plans, accident and incident management procedures, and a procedure for compensation and indemnification for gas pipeline routes crossing private property. As mechanisms for redress, Enagas operates a Whistleblowing Line accessible to all stakeholders and an Ethical Compliance Committee, together with corporate mailboxes for specific areas. The company is reviewing its due diligence processes for third parties, focusing on the protection of human rights and the environment in line with the relevant European Directive.

Enagas operates a due diligence system to anticipate, prevent, mitigate and remedy negative impacts on value chain workers. It identifies, assesses and prioritises actual or potential human rights impacts and implements mitigation actions. For affiliates without operational control, it transfers critical management standards and monitors them through a five-year objectives plan; an Internal Monitoring Committee reports quarterly to the Board. Over the last three years, 100% of affiliates without operational control were assessed, with 22% identified in 2024 as posing potential country-related human rights risk; mitigation actions were implemented in all. For the supply chain, 72.2% of suppliers were assessed over three years, of which 19.9% were identified as high risk, all with mitigation actions in place. In 2024 the cost of supplier evaluations exceeded 98 thousand euros. Through the Global Compact Sustainable Suppliers programme, 77 small and medium-sized suppliers received human rights training. Via the SACE contractor access system, 5,906 training hours (5,480 in 2023) reached 2,773 contractors from 556 companies.

Enagas has set targets for managing value chain worker risks. For affiliates without operational control, it aimed to ensure ongoing and proper oversight of human rights management across 100% of its companies through corporate governance bodies by 2024; in 2024 it carried out regular oversight of 100% of these affiliates through the established governing bodies, including the Hanseatic Energy Hub company during its infrastructure construction. This contributes to the Human Rights Policy commitment to promote compliance with corporate policies according to the company's degree of influence. For the supply chain, Enagas planned to conduct at least ten on-site audits in 2024 covering ethical, environmental and social aspects, including a specific human rights assessment, through an independent third party for key suppliers considering criticality, sustainability risks and turnover. Enagas exceeded this, carrying out twelve on-site ESG audits by an independent third party. These assessments are a primary tool for identifying potential human rights violations, aligned with the Human Rights Policy commitment on suppliers operating within Enagas facilities.

Enagas sets out commitments to affected communities, especially local communities, in its Group Code of Ethics and in more specific Board-approved policies. The Code of Ethics commits to supporting the socio-economic development of local communities where it operates. The Sustainability and Good Governance Policy establishes mechanisms for collaboration, timely information exchange and participation, committing to identify affected communities and vulnerable groups, implement consultation and participation strategies, and establish publicly available complaints and grievance mechanisms; it was revised in 2024 to align with the OECD Guidelines for Multinational Enterprises (2023). The Human Rights Policy outlines due diligence commitments aligned with the UN Guiding Principles, the UN International Bill of Human Rights, OECD guidance and guidelines, the ILO Declaration and the Universal Declaration of Human Rights, addressing rights of communities and indigenous peoples and property rights, resettlement and compensation; it was updated in 2024. The Health and Safety Policy, split into a distinct policy in 2024, covers safety and emergency measures. Over three years, no instances of non-compliance with the UN Guiding Principles, ILO Declaration or OECD Guidelines were identified regarding affected communities.

In the early stages of construction, operation, maintenance and decommissioning projects, Enagas analyses actual and potential social, economic and environmental impacts to identify affected communities, key associations and legitimate representatives such as vulnerable groups, NGOs and local councils, and creates stakeholder maps. It conducts environmental impact studies that also assess social aspects, which are open to public information and subject to consultation where stakeholders may voice opinions and propose modifications. EMAS-certified facilities publish annual reports. Operational responsibility during construction lies with the Chief Executive Officer of Engineering, Technology and Digitalisation, and during operation and maintenance with the Gas Assets General Manager, both on the Executive Committee. Communication channels include contact telephone numbers and corporate mailboxes, plus additional channels during development, construction and decommissioning such as information sessions, citizen participation days, consultation processes and permanent information centres. Enagas prepared and submitted a Public Participation Conceptual Plan to the Ministry for Ecological Transition for the Inland Hydrogen Infrastructure project, and similar plans for the CelZa and North-1 projects, to ensure transparency and community involvement during authorisation.

Enagas offers channels for affected communities and their legitimate representatives to submit complaints or claims about actual or potential negative impacts on any group, society or the environment. In addition to the collaboration channels described under S3-2, it operates a Whistleblowing Line, including the electronic mailbox canal.etico@enagas.es, post addressed to the Chairman of the Ethical Compliance Committee in Madrid, and a form on the corporate Intranet and website. The responsible areas set up mechanisms to ensure all communications received are addressed; where necessary Enagas analyses and investigates communications and takes appropriate actions to prevent or reduce identified negative impacts as far as it can influence, then assesses the effectiveness of these measures after implementation considering their actual impact on affected communities. Enagas evaluates how well these channels are understood and trusted through direct engagement, informal communications and usage levels. It also supports these reporting and resolution channels within its value chain, using this as one criterion to assess the sustainability risk of its suppliers.

Enagas benefits regions through competitiveness, energy security, decarbonisation, direct and indirect jobs and local taxes. Over three years, no potential human rights violations related to affected communities were identified. The Group operates in over 55 locations, creating local direct employment; it hired 106 new employees in 2024 (127 in 2023), of which 50.9% were women and 79% external candidates. In 2024 it placed orders with local suppliers exceeding 264 million euros, 79% of total supply chain spend, and spent over 94 million euros with small and medium-sized enterprises. H2med and the Spanish Hydrogen Backbone could generate up to 4.8 billion euros of GDP. Enagas conducts environmental impact studies assessing social aspects and, with affected communities, defines actions to prevent, mitigate or compensate impacts, including a regulated Compensation and Indemnity Procedure for passage through private property. In 2024 no significant negative impacts were identified in construction projects. It invested (CapEx) over 200 thousand euros preparing Initial Project Documents and another 200 thousand euros for Public Participation Concept Plans, with about 3 million euros estimated in 2025. Social investment reached 1.72 million euros in 2024, including monetary contributions exceeding 1.2 million euros; volunteering involved 649 participations over 3,407 hours across 33 initiatives.

For creation of direct and indirect employment, Enagas has not set measurable outcome-oriented targets for 2024, considering that indicators for direct local hiring and indirect employment through local supplier engagement adequately reflect its goals. For commitments to affected communities, because 2024 construction activities were not significant, specific goals will be set as renewable gas infrastructure construction reaches more advanced stages. For social action, under the 2023-2030 Social Action Strategy, Enagas set annual objectives. It aimed to allocate at least 0.4% of net profit (1.2 million euros) to financial social action contributions and met this with over 1.7 million euros. It aimed to earmark around 60% (740 thousand euros) to security of supply, decarbonisation and just transition initiatives, meeting it with 60% (743 thousand euros). It aimed to allocate at least 15% (185 thousand euros) to local actions, exceeding this with 26% (329 thousand euros). It aimed to use 20% (247 thousand euros) for education, culture, health and disadvantaged groups, exceeded by 23% (286 thousand euros). It aimed for at least 10 corporate volunteering initiatives, meeting it with 33. Progress is monitored semi-annually and reported to the Executive Committee.

Enagas' business model is business-to-business, so it does not have consumers and end users as defined by EFRAG and identifies no impacts, risks or opportunities under that topic. Because of synergies, it voluntarily uses the ESRS S4 structure to report on its customers, which include transmission companies, shippers, distributors and direct market consumers served in its roles as Transmission System Operator and Technical Manager of the System. It identified one material negative impact (failing to ensure proper supervision and service quality), one positive impact (transparent communication) and one opportunity. Policies managing these, all approved by the Board and aligned with the OECD Guidelines, are the Code of Ethics, the Quality and Operational Excellence Policy, the Sustainability and Good Governance Policy (revised in 2024), the Human Rights Policy (updated in 2024 to strengthen due diligence and covering customer data privacy) and the Code of Conduct of the Technical Manager of the Spanish Gas System (updated in 2024). Over the past three years no instances of customer-related non-compliance with international standards were identified.

Enagas engages customers through several channels to understand their needs and expectations. The main tool is the Customer Service Manager (CSM), a digital platform where customers register queries that are assigned a criticality level, routed to the responsible business area and closed once resolved, offering autonomy, transparency, multi-device access and improved efficiency. Other mechanisms include regular meetings, telephone support and corporate mailboxes, the corporate website (including the GTS Energy Data section), the SL-ATR logistics system, the Gas System Monitoring Committee, workshops, roadshows, site visits and various publications. Enagas conducts annual satisfaction surveys through both the TSO and GTS; the GTS survey follows the CNMC Incentives Circular 6/2021, and GTS remuneration is linked to participation and satisfaction results. In the 2024 survey, on a 10-point scale, transmission-company shippers scored services at 9.2 and system operators at 9.1, while as Technical Manager of the System shippers scored 8.6 and system operators 8.7. Responsibility rests with Executive Committee members.

Customers of both Enagas TSO and Enagas GTS have access to specific channels to raise complaints or report negative impacts, managed according to principles of accessibility, listening, collaboration, transparency and non-retaliation. The Customer Service Manager (CSM) lets customers log incidents that are assigned a criticality level, routed to the responsible business area, resolved and closed, with the tool tracking resolution rates and response times. If a customer disagrees with the response and all other channels such as meetings are exhausted, they can file a dispute with the relevant regulatory body, which resolves the claim after reviewing the information and consulting the parties. Additional channels include regular meetings, telephone support and corporate mailboxes, the Reviews and Complaints Module in the SL-ATR platform used by GTS and TSO for regulatory obligations, and the confidential Whistleblowing Line (electronic mailbox canal.etico@enagas.es, postal address to the Chairman of the Ethical Compliance Committee, and an online form). Enagas assesses awareness and trust in these channels through satisfaction surveys.

Enagas takes action to meet customer needs through quality, service excellence and transparent operations, drafting annual action plans that capture improvement and remediation actions. Its Quality Management and Operational Excellence framework is certified to ISO 9001 and part of an integrated management system, and the company also holds ISO 55001 asset management certification. In 2024 Enagas resolved 98.4% of the 123 formal complaints received from customers (177 in 2023), which related to its role as Technical Manager of the System. It allocated more than 27 thousand euros (OpEx) to quality and asset management audits and invested 50 thousand euros (CapEx) in developing the Commercial Service Manager portal for its TSO activity. On pipeline integrity, more than 11.2% of the network was internally inspected and over 86,000 kilometres of pipelines were inspected and monitored, backed by more than 6.3 million euros in OpEx. Transparency actions include the GTS Energy Data platform, the GTS Good Practice Guide and a Transparency Committee.

Enagas has set goals for measuring customer satisfaction through the surveys conducted by the TSO and GTS, linked to the identified material impacts and opportunities because the surveys assess service quality, transparency and continuous improvement. The targets align with the Quality and Operational Excellence Policy commitment to meet or exceed customer expectations. For the TSO, an annual overall satisfaction target has been set with a critical threshold of 7.7 out of 10, plus a separate target of 8.5 out of 10 for the 2024 shippers' survey; these are based on historical results and reviewed annually. The 2024 target was met, achieving 9.2 out of 10 for shippers and 9.1 out of 10 for system operators. For the GTS, the survey follows CNMC Circular 6/2021 with a minimum participation rate of 30% of active users, and remuneration is linked to the results. Due to these regulatory circumstances the GTS sets no measurable satisfaction targets, but commits to continuous improvement. Results are published on the corporate website.

Enagas' corporate culture reflects its purpose, vision and seven values (efficiency, transparency, innovation, integrity, sustainability, safety and teamwork), reviewed and approved by the Board of Directors. It runs a formal corporate culture evaluation every two years through an opinion survey covering four areas; the 2024 assessment improved by three points. The Group has a Code of Ethics (updated in 2023) plus related policies all approved by the Board: Compliance Policy, Anti-Fraud, Corruption and Bribery Policy, Corporate Defence Policy, Internal Reporting System Policy (aligned with Law 2/2023) and the Sustainability and Corporate Good Governance Policy (revised in 2024). By the end of 2024, 97.55% of professionals had signed the declaration confirming they read the Code. The Ethical Compliance Committee reports to the Audit and Compliance Committee. A confidential Whistleblowing Line accepts anonymous reports; in 2024 the average handling time was under 50 days. Code of Ethics training reached 99.2% of professionals and Corporate Defence Programme training 98.6%.

Enagas manages its supply chain using a risk-based approach. It has 310 approved critical suppliers (265 in 2023), representing 16.9% of all approved suppliers and 27.7% of purchases, plus more than 70 critical indirect suppliers (77 in 2023). In 2024 it began working with 92 new approved suppliers (84 in 2023), all of which passed an approval process meeting social and environmental criteria, and discontinued relationships with 104 suppliers (49 in 2023) for reasons not based on social or environmental criteria. The payment policy is to pay in general within sixty days. Supplier approval and assessment cover human rights, ethics, social, cybersecurity and environmental matters through external and internal evaluations. In 2024 the predictive sustainability risk assessment covered 1,333 suppliers, identifying 188 as high risk. For 100% of assessed suppliers identified as high ESG risk, action plans were established. Through the Global Compact 'Sustainable Supplier' programme, 77 small and medium-sized suppliers were trained.

Enagas has an Anti-Fraud, Corruption and Bribery Policy approved by the Board of Directors, so 100% of Board members are informed of its commitments. All Group activities have been analysed for corruption risks, and the company records all third-party payments and prohibits facilitation payments, payments in kind, and cash payments. The Enagas Corruption Prevention Programme is based on the ISO 37001 anti-bribery standard and was externally certified in 2024. An anti-corruption risk reassessment was also carried out in 2024. Anti-corruption principles have been extended to suppliers, and the Compliance Function submits quarterly reports to the Audit and Compliance Committee. A mandatory one-hour online corruption prevention course covers the Compliance Model, red flags, and regulations including the Spanish Criminal Code, FCPA, UK Bribery Act and ISO 37001. In 2024, 97.9% of employees completed it (93.6% in 2023), including 100% of the Executive Committee, 100% of the Ethical Compliance Committee, and 100% of professionals in roles especially at risk.

In the last three years, Enagas has had no confirmed incidents of corruption or bribery, nor any conviction or fine for violating the applicable laws on corruption prevention and anti-bribery. The number of confirmed incidents of corruption or bribery is therefore zero. The company also notes that no other breaches of the Code of Ethics were identified over the period in related areas such as discrimination or harassment, privacy of customer or stakeholder information, conflicts of interest, money laundering, or insider trading. A separate purchasing-process irregularity at a Group start-up was investigated in 2024, but this was not classified as a corruption or bribery incident.

Enagas is registered in the European Transparency Register (registration number 905001612275-82) and has adhered to its Code of Conduct. The Board of Directors oversees these activities, with operational responsibility held by the Energy Transition General Manager. Five professionals work part-time on transparency register activities, including a permanent representative in Brussels. Annual costs in 2024 were between 200 and 300 thousand euros, split into personnel expenses (74%), membership fees (10%), consultancy costs (9%), representation, public relations and travel (4%), office and administrative costs (2%) and operating costs (under 1%). Membership of commercial and business associations amounted to over 220 thousand euros (200 thousand in 2023). Main European lobbying associations and their total contributions were GIE at 102,310 euros (about 5,500 euros for lobbying), Hydrogen Europe at 18,000 euros (about 4,500 euros) and ENTSOG at 637,000 euros (about 9,800 euros). Enagas made no political contributions of any kind in the last three years and prohibits funding political parties.

In line with Spanish legislation and its general contract terms, Enagas' policy is to make payments within sixty days from the delivery date or service provision. The company uses reverse factoring, allowing suppliers to receive payment ahead of the invoice due date, and provides a Supplier Portal for suppliers to track invoice status and resolve issues that could delay payment. For certain services it also makes advance and cash payments. In 2024, 92% of supplier payments were made within the specified timeframes, the same as in 2023. The average payment period to trade creditors for amounts owed to suppliers of goods or services was 20 days (17 days in 2023), calculated under the average payment period methodology set by the Spanish Accounting and Audit Institute's Resolution of January 29, 2016. Enagas has no pending legal actions concerning late payments.