GEK TERNA

Reference: pages 47-52 (further roles under business conduct, pages 205-211).

The Board of Directors has 14 members, 6 executive and 8 non-executive, with 35.7% women and 42.9% independent members; the gender diversity ratio is 0.56 (page 48). The report notes that "there is no representation of employees on the Board of Directors" (page 47).

Seven committees support the Board in an advisory role: Executive, Nomination and Remuneration, Audit, Investment, Strategic Planning, Regulatory Compliance and ESG (page 49). The ESG Committee monitors ESG performance, oversees the double materiality process and oversees preparation of the sustainability report (pages 51-52). Delivery sits with the Corporate Social Responsibility & Sustainable Development Department, which reports to the ESG Committee and the Board, and a Risk Management Officer works with Finance, HSE, the Technical Office and HR on risk (page 52).

Board expertise is supported by a Suitability Policy and a training policy for Board members and executives (page 51). Responsibilities are documented in the ESG Policy, the Code of Ethics and Conduct and the Internal Rules of Operations (page 51).

Reference: pages 52-53.

The CSR & Sustainable Development Department updates the Board and the ESG Committee on a quarterly basis, "or more frequently if needed", on sustainability matters and on how related policies are being applied (page 52). The ESG Committee checks that these topics fit the Group's strategy and meets relevant stakeholders to strengthen oversight (page 52).

Board members use the impact, risk and opportunity data to oversee strategy, and the Board weighs the reports and meeting input it receives (page 53). The Board and the ESG Committee set the Group's goals; performance is tracked through a KPI collection and analysis system that the department presents periodically, and deviations lead to corrective action such as revised strategies or staff training (page 53). In the reporting period the Board and the ESG Committee approved the material impacts, risks and opportunities identified by the double materiality analysis (page 53).

Reference: pages 53, 145-146.

Short-term variable compensation (bonus) is tied to sustainable development targets, such as emissions reduction, or the number and severity of accidents (page 53). The targets are set as KPIs by the Board of Directors, reviewed by the Remuneration Committee and approved by the General Assembly as part of the Remuneration Policy. The scheme applies to Board members and to senior executives who are not Board members (Directors and Top Management Executives) (page 53).

On climate, the report says that "climate change considerations are incorporated into the variable remuneration of administrative, management, and supervisory bodies. However, remuneration is not evaluated in relation to specific targets for reducing greenhouse gas emissions" (page 146). The Remuneration Policy covers the entire workforce and links ESG issues to variable pay for the Board and top management (page 146).

Reference: pages 53-55.

The statement says the due diligence process is "designed to identify, prevent, mitigate and address both actual and potential adverse impacts on the environment and society" (page 53). A table maps the five core due diligence elements to sections of the statement (pages 54-55):

• Embedding due diligence in governance, strategy and business model: GOV-2, GOV-3, SBM-3.
• Engaging with affected stakeholders: SBM-2, IRO-1, S1-2, S1-3, S2-2, S2-3, S3-2.
• Identifying and assessing adverse impacts: IRO-1, SBM-3.
• Taking action: E1-2, E1-3, E5-1, E5-2, S1-1, S1-3, S1-4, S2-1, S3-1, G1-1, plus MDR-P and MDR-A for Value creation.
• Tracking effectiveness: E1-4, E5-3, E5-5, S1-5, S2-5, plus MDR-T for Value creation.

Reference: page 56.

The risk management and internal control system for sustainability reporting is built to secure "the accuracy, completeness, and integrity of the data" in the statement, alongside a standardized reporting process that sets roles, steps and control points for collecting, verifying and documenting information (page 56). The main risks named are data completeness, integrity, accuracy and availability within the required timeframe (page 56).

Mitigation is through quality checks and meetings with the relevant departments to close data gaps, and a framework of assumptions for use when direct value chain data is not available (page 56). The Corporate Social Responsibility & Sustainable Development Department leads the framework and works with other departments to collect and verify data. Findings go to the department's leadership and, if necessary, to the Board and the ESG Committee (page 56).

Reference: pages 56-64.

GEK TERNA describes itself as "one of the largest business groups in Greece", present in Central and Southeastern Europe and the Middle East (page 56). Its segments (pages 56-57): Construction through TERNA S.A.; electricity from thermal sources and electricity and natural gas trading through HERON ENERGY S.A.; Real estate, a portfolio valued at EUR 122 million in Greece, Romania and Bulgaria; Concessions covering highways, airports, ports, waste management and parking, with almost 2,000 km of motorways; Mining and manufacturing through TERNA MAG (magnesite); and Holdings.

Scale: 6,149 employees and turnover of EUR 3,855,368 thousand (page 62). Revenue from the thermal electricity and gas trading sector, which the report associates with fossil fuels, was EUR 280,864.5 thousand in 2025 (page 58). Sustainability strategy rests on three pillars: protecting the environment, fostering a positive impact on society, and building a sustainable workforce and resilient supply chain (page 59).

The value chain is mapped by segment, focusing on first-tier suppliers upstream and direct customers downstream, without extending to customers' customers; Holdings is not mapped separately (pages 63-64).

Reference: pages 64-67.

The Group sorts stakeholders into internal groups (senior management, employees) and external groups (customers, shareholders, financial institutions, local communities and authorities, suppliers, government entities, NGOs and media) and prioritizes them by impact and influence on operations and the value chain (page 65). Tables list the channels used for each group, such as meetings, bulletin boards, the website, the Sustainable Development Report, shareholder meetings, consultation events and supplier inspections (pages 65-67).

Stakeholder views feed strategy, risk management and the double materiality assessment, and the Group communicates its expectations to stakeholders through contract terms (page 67). The CSR & Sustainable Development Department presents the findings from the double materiality questionnaires to the ESG Committee, which informs the Board; the Regulatory Compliance Unit updates the governing bodies at least once a year (page 67).

Reference: pages 73-78 (topic-level SBM-3 sections: E1 pages 128-139, S1 pages 161-163, S2 pages 193-194, S3 pages 200-201, Value creation pages 217-218).

Material impacts, all actual (pages 74-75): climate-resilient infrastructure (positive, E1 adaptation); greenhouse gas emissions and energy consumption from fossil fuels (negative, E1 mitigation and energy); waste generation (negative, E5); a safe and supportive working environment, and employee empowerment, fair treatment and equal opportunities (positive, S1); occupational health and safety incidents (negative, S1); safe working conditions across the value chain (positive, S2); support for local communities (positive, S3); a culture of business ethics and zero tolerance for corruption and bribery (positive, G1); and creation of economic value (positive, entity-specific Value creation).

Risks and opportunities (page 76): high temperatures halting work at sites (risk, short-term), energy cost fluctuations (risk, mid-term), workforce shortage (risk, mid-term) and new financing mechanisms such as EU funding (opportunity, mid-term).

The report says these did not lead to "any change in the Group's strategy or business model" and that there are no related current financial effects; anticipated financial effects are phased in (page 73), and the ESRS content index flags SBM-3 with an omission of anticipated financial effects under the quick-fix Delegated Act (page 227).

Reference: pages 68-73.

The Group runs the double materiality assessment in four phases: understanding the business model, value chain and activities; identifying impacts, risks and opportunities with stakeholder engagement; evaluating them; and setting material topics (pages 68-73). Inputs include the Group's 2024 assessment, ESG rating agencies, industry standards and EFRAG guidance, and peer sustainability reports (page 69). Entity-specific topics were also tested (page 69).

Impacts were identified through meetings with department heads and senior management and assessed before mitigation, using scale and scope, plus irremediable character for negative impacts, and likelihood for potential ones (pages 70-72). Risks and opportunities were scored on magnitude and likelihood against a financial indicator (page 72). A focus-group workshop with a representative of Internal Audit scored the impacts (page 72). Thresholds were set from the minimum and maximum observed scores per category (page 72).

The ESG Committee and senior management validated the results. The assessment is repeated each year and is embedded in the Group's overall risk management framework (page 73).

Reference: page 78 and the ESRS content index in the Annex (pages 226-231); datapoints derived from other EU legislation are listed on pages 224-226.

The double materiality assessment found four topical standards not material, so their disclosure requirements are not included: E2 Pollution, E3 Water and marine resources, E4 Biodiversity and ecosystems, and S4 Consumers and end users (page 78). The statement points readers to the Annex for "the detailed list of disclosure requirements" (page 78).

The Annex index (pages 226-231) lists each disclosure requirement with a subsection and a "Clarification" column. It marks E1-7, E1-8, E5-4, G1-2, G1-5 and G1-6 as non-material topics, and shows "Phase-in provision" with a quick-fix omission note for E1-9, E5-6, S1-11 and S1-12 (pages 228-231). It also flags ESRS 2 SBM-3 with an omission of anticipated financial effects (page 227) and lists the entity-specific topic "Value creation", with MDR-P, MDR-A, MDR-M and MDR-T (page 231). In the E5 and S1 blocks the subsection column is offset from the disclosure requirement it should describe (pages 228-229).

Reference: pages 127-128 (EU-law datapoints on page 224).

The Group states plainly that it has no transition plan yet: "Although the Group does not yet have a comprehensive transition plan, the importance of aligning with European initiatives to achieve climate neutrality by 2050 is acknowledged" (page 128). It says it "will soon initiate the development of a strategic transition plan" aligned with its business strategy and with the ESG Policy and Strategy approved by the Board (page 128). Footnote 6 adds that "The Group's activity is not exempt from the EU benchmarks aligned with the Paris Agreement" (page 128).

What exists today: decarbonization actions under E1-3 (Guarantees of Origin, energy efficiency, electric and hybrid vehicles, green building certifications; pages 144-145) and a statement that GHG targets are still being formulated (page 146). Annex I lists the datapoints on a transition plan to reach climate neutrality by 2050 against this section (page 224). Natural gas is the largest fuel in the Group's energy mix (page 148).

Back-filled from ESRS 2 SBM-3 and IRO-1, where this content is disclosed in the FY2025 report (pages 128-142). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 128-142; the Taxonomy climate risk assessment is on pages 85-86.

Scenarios: IPCC RCP 2.6, RCP 4.5 and RCP 8.5, following TCFD guidance (page 128). The report describes them as warming of below 2°C, about 2°C and possibly above 4°C by 2100 (page 129). No scenario is named as 1.5°C-aligned.

Horizons: short-term 1-2 years (to 2027), medium-term to 2032, long-term to 2050; the short term is set at two years to match internal planning cycles (page 128).

Scope: electricity generation (HERON), mining (TERNA MAG), concessions and construction (TERNA S.A.), across the value chain (page 128).

Risks: acute and chronic physical risks and five transition risk types (legislative, technological, legal, market, reputational) were screened, and the material ones are tabulated by hazard, segment and horizon (pages 129-137). Opportunities are on pages 138-139. The pages reviewed do not state when the analysis was carried out.

Back-filled from ESRS 2 SBM-3 and IRO-1, where this content is disclosed in the FY2025 report (pages 128, 140-142). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 128, 140-142.

The Group says it ran a climate scenario analysis "to assess the resilience of its business model and strategy" (page 128). The resilience analysis "is embedded into the overall strategic planning" and has produced "a flexible and adaptive capital management framework, which enables the reallocation of resources towards initiatives that support the energy transition" (page 140).

Response measures listed are redesigning and strengthening infrastructure to withstand extreme weather, early-warning systems, and working with scientific and technical institutions to keep climate data current (page 140). Business impacts in the climate risk tables are described in words (pages 131-139), and the report states there are "no related current financial effects" (page 73).

Reference: pages 142-143.

The Environmental, Social and Corporate Governance (ESG) Policy is the instrument for climate change mitigation, adaptation, energy management and other environmental matters (page 142). It applies to "all Group employees, trainees, contractors, and subcontractors, as well as all subsidiaries, provided they do not have their own ESG Policy" and extends to joint ventures where relevant (page 142). Senior Management communicates it and provides resources; the CSR and Sustainable Development Director coordinates implementation (pages 142-143).

Content: environmental management plus energy and GHG emissions management, including climate change mitigation (page 142). Implementation tools: annual internal audits of every operating activity, an Environmental and Energy Management System certified to ISO 14001:2015 at most subsidiaries, ISO 50001:2018 at TERNA, and ISO 9001:2015 (page 143). The Policy commits the Group to annual use of green energy with Guarantees of Origin at most subsidiaries (page 143). A separate health, safety and environment policy adds general environmental commitments (page 143).

Reference: pages 144-145.

The main funded action is buying Guarantees of Origin for electricity consumed in the Group's main areas of activity. The report says this "led to a reduction of indirect (market-based) emissions by more than 70% in 2025, with a total investment of 102,558 euros" (page 144).

Other actions, with scope and expected outcome (page 144): energy consumption monitoring in offices, sites and facilities; machinery renewal and maintenance; private power purchase agreements in Greece for end consumers (downstream); replacing passenger vehicles with electric or hybrid models; upgrading lighting and air conditioning; energy-saving design in construction projects; and LEED and BREEAM certifications.

Commuting and business travel measures target Scope 2 and 3 emissions (page 145). The report says delivery depends on "continuous access to financing on favorable capital terms" (page 145). ESG Policy commitments: annual GHG monitoring for all subsidiaries, action plans to cut the carbon footprint, Guarantees of Origin for 100% of subsidiaries by 2030, and at least 70% participation in energy-related training (page 145).

Reference: page 146 (GHG reduction target datapoint listed on page 225).

No Group-level emissions target is set yet. The report says the Group "is in the process of formulating specific, measurable and scientifically grounded targets, in line with the requirements of the ESRS standards" and that the goals are not yet finalized (page 146). Meanwhile it tracks performance through annual sustainability reports and compliance with legal obligations such as the EU ETS and the National Climate Law (4936/2022) (page 146). Scope 1 emissions under regulated emission trading schemes were 66.5% in 2025 (page 152).

At project level the Group sets carbon-footprint targets, "e.g., emissions per life-cycle phase, energy performance, use of low-carbon materials and fuels", shaped by the criteria of financial and investment institutions (page 146). The one dated commitment is in the ESG Policy: Guarantees of Origin for 100% of subsidiaries by 2030 (page 145). It concerns electricity certificates, not an emissions reduction figure.

Reference: pages 146-150 (restatement note on page 46).

Fossil sources are 98.4% of consumption (2024: 97.72%) and renewables 1.62% (2.27%) (pages 148-149). The Group acquired Guarantees of Origin for 73,256 MWh (page 147), and puts the renewable share of electricity consumed at 66.2% (page 147, footnote 14). Almost all consumption (5,604,153.03 MWh) is in high climate impact sectors, with intensity of 1.511 MWh per thousand euros of net revenue, printed as "1,511" (page 150). Some 2024 energy figures were restated for TERNA Bulgaria's electricity price (page 46).

Reference: pages 150-155 (EU-law datapoints on page 225).

Stationary combustion is 96.6% of Scope 1, and 66.5% of Scope 1 falls under regulated emission trading schemes (94.9% in 2024) (pages 152-153). The largest Scope 3 categories in 2025 are use of sold products (1,547,414.53), fuel- and energy-related activities (1,170,422.25) and purchased goods and services (856,806.79) (page 152). Categories 8, 9, 13, 14 and 15 are assessed as non-material (page 151). All Scope 3 data is secondary, and categories 1, 2 and 4 are spend-based (page 154). Intensity is 1.24 tCO2e per thousand euros of net revenue on both bases (2024: 2.02 and 2.03) (page 155). Biogenic Scope 1 emissions are 2,041.5 tCO2e (page 155).

Reference: page 157.

Waste handling sits inside the ESG Policy, which applies to all Group employees, trainees, contractors and subcontractors and to subsidiaries without their own ESG policy (page 157). Its stated purpose is a framework for responsible handling of all hazardous and non-hazardous waste, to minimize environmental impact and strengthen circular-economy performance. It sets project-level measures for collection, sorting, treatment, reuse, recycling and disposal, systematic monitoring of waste streams, staff awareness and continuous improvement (page 157).

The Director of the Sustainability and Corporate Social Responsibility Department coordinates and monitors the Policy, the Chief Executive Officer approves it, and it is published on the internal network (page 157).

The report states a limit on scope: "The ESG Policy does not include references to the transition away from the use of virgin resources, including any related increase in the use of secondary (recycled) materials, nor to the sustainable sourcing and use of renewable resources" (page 157, footnote 27).

Reference: pages 157-158.

Actions center on waste and on material choice. The Group runs a hazardous and non-hazardous waste program to cut volumes and hazard, prevent landfilling and increase recovery, following the hierarchy of prevention, reuse and recycling, with disposal as the last option (pages 157-158). Waste goes to licensed contractors under Environmental Terms Approvals and project procedures, subsidiaries keep waste records and hazardous waste identification documents, and Group companies report waste data each year to the national Electronic Waste Registry (page 158).

Other actions: reuse of excavation, construction and demolition materials across Group activities; recycling of paper, aluminum, glass, plastic, electrical and electronic equipment, lamps and batteries at offices, sites and facilities; separate handling of liquid waste (page 158). On inputs, the Group says it selects durable, lower-impact materials and evaluates recycled or secondary materials "wherever technically feasible" (page 157). Resources are built into project planning and budgets, covering staff, operating costs and licensed providers (page 158).

Reference: pages 158-159.

The stated objective, within the ESG Policy, is responsible management of all hazardous and non-hazardous waste, with emphasis on collection, treatment, reuse and recycling in line with the circular-economy hierarchy (page 158). No quantified target exists. The report says that "the Group has not yet established quantified Group-level targets regarding the reduction, recycling, recovery or disposal of waste" and that target-setting "is currently under assessment" as data standardization across subsidiaries progresses (page 159). Until targets are set, performance is tracked through annual waste-management indicators and project-level environmental management procedures (page 159).

Reference: pages 159-160 (waste detail under E5-5-Waste).

The section is headed "Resource outflows | Waste [E5-5]" and covers waste only; it gives no separate figures for products and materials leaving the Group. Total solid waste in 2025 was 1,871,248.3 tonnes, of which 0.3% was hazardous and 99.7% non-hazardous (page 159). Non-recycled waste was 1,652,152.24 tonnes, or 88.3% of the total, and no radioactive waste was generated (page 159). The report notes that the majority of waste originates from the construction sector (page 156).

Reference: pages 159-160.

Waste for recovery totals 4,623.63 tonnes hazardous and 214,585.78 tonnes non-hazardous; waste for disposal totals 57.93 and 1,651,980.95 tonnes (pages 159-160). Waste data is recorded by subsidiaries from transfer notes issued by accredited waste operators, construction sites collect their own data, and everything is consolidated in a central file or monitoring platform (page 160). No 2024 comparison is shown.

Reference: pages 163-171 (EU-law datapoints on page 225).

Policies cover the two material sub-topics, working conditions and equal treatment and opportunities, and the Group says its HR policies are "guided by deep respect for human rights" (page 163). The report describes: the Internal Work Regulation, with equal treatment, merit-based recruitment, health and safety rules and an annex on preventing violence and harassment and handling internal complaints (pages 163-164); a Training Policy open to the whole workforce, including self-employed collaborators (page 165); a recruitment and succession policy under which gender, race, age, nationality, political beliefs, religion, marital status, sexual orientation, disability and union membership do not influence selection (pages 165-166); a Human Rights Policy aligned with the UN Guiding Principles, covering forced labor, age 18 as the minimum, freedom of association and non-discrimination (pages 166-167); a Policy against Violence and Harassment at Work (pages 168-169); and the ESG Policy (pages 169-170).

Health and safety runs through a system certified to ISO 45001:2018; partners that fail their commitments face a "three-strike rule" that can end the relationship (pages 170-171).

Reference: pages 173-176.

Equal treatment: merit-based policies, enforcement of the Code of Ethics and Conduct with attention to vulnerable groups and minorities, monitoring of women by geographic area, age and employment level, a grievance mechanism and human rights training for the whole workforce (page 173). Where violations are found, results and recommended actions go to the Board, and the Group can end collaborations, impose fines or penalties and start civil and criminal procedures (pages 173-174).

Working conditions: an ISO 45001:2018 health and safety system, safety technicians and occupational doctors on all sites as required by law, emergency plans and drills, no work without equipment, qualifications or training, and documented equipment inspections (page 174). Costs are covered internally and "The implementation of these actions does not depend on external funding sources" (page 174). Effectiveness is followed through KPIs and internal and external inspections, and the Group cites ISO 45001 and ISO 39001 (pages 175-176).

Reference: pages 176-177.

Targets sit in the ESG Policy and are monitored yearly. Human rights: zero incidents of human rights violations and training of 100% of employees on human rights (page 177). Health and safety: zero fatal accidents (baseline year 2022); introductory training for 100% of involved employees before projects or operations start; role-specific specialized training; at least one health and safety compliance inspection per facility per year; and ISO 45001:2018 certification for 70% of facilities by 2030 (page 177). The baseline for measuring progress is 2024 "unless otherwise specified for each goal" (page 177).

Targets draw on employee feedback, industry practice and legal requirements (page 177). The Group says it plans to develop "a specific strategy and action plan to quantify goals" with a timeline for each target (page 177).

Reference: pages 178-180.

On 31.12.2025 the Group had 6,149 employees (2024: 5,419), 21.8% of them women (page 178). By type: 5,064 permanent, 61 temporary and 1,024 freelancers, whom the Group counts as employees because self-employed professionals are "a significant proportion" of its workforce; 6,112 are full-time and 37 part-time (page 178). By gender: 4,811 men and 1,338 women, with none recorded as other or not reported (page 178). Greece accounts for 5,892 employees; the next largest are Bulgaria (183) and Cyprus (37) (pages 58, 179). In 2025, 890 employees left, a turnover rate of 14.5% (2024: 17.1%), made up of 7.6% voluntary and 6.9% involuntary (page 180).

Reference: page 181.

The Group uses non-employees supplied by third-party companies: 545 at 31.12.2025 (168 men and 377 women), against 684 at 31.12.2024 (305 men and 379 women) (page 181). The count covers people hired through a third-party employment agency that is their direct employer (page 181). The disclosure is a headcount table by gender. Separately, S1-14 reports workers who are not employees but whose work or workplace the Group controls, such as trainees and subcontractors insured by the Group (page 190).

Reference: pages 182-183.

The Group reports that "100% of the Group employees are subject to collective bargaining agreements" in Greece and abroad: 6,149 of 6,149 (2024: 5,419 of 5,419), and 5,892 of 5,892 in Greece (pages 182-183). The agreements address health and safety, compensation, working hours, training, professional development, equal opportunities, leave and insurance, and the largest union is recognized as the official body for negotiating labor issues with the Board (page 182). On social dialogue, 412 employees (7%) worked in establishments with workers' representatives in 2025, against 164 (3%) in 2024 (page 182).

Reference: pages 183-184.

At top management level the Group had 49 people at the end of 2025: 39 men (79.6%) and 10 women (20.4%). In 2024 the figure was 61, with 19 women (31%) (pages 183-184). By age, 582 employees (9.5%) are under 30, 3,376 (54.9%) are 30-50 and 2,191 (35.6%) are over 50, out of 6,149; the 2024 split was 498 (9.2%), 3,107 (57.3%) and 1,814 (33.5%) out of 5,419 (page 184). The Group lists balanced representation of all genders at all levels and more women in its businesses among its aims, and says it records the distribution of women by geographic area, age and employment level (page 183).

Reference: page 184.

The report states a commitment to fair remuneration "ensuring decent living conditions for all employees" and says pay reflects objective criteria, responsibilities, skills and experience, and market trends (page 184). On adequacy it says "All employees of the Group, both salaried and non-salaried, are compensated with wages that meet the adequate salary levels as stipulated by applicable legislation" (page 184). No adequate-wage benchmark or country breakdown is given on the page. A Remuneration Policy for Board members and senior executives rests on transparency, compliance, competitiveness, shareholder interest and meritocracy (pages 184-185).

Reference: pages 185-189.

Training totaled 27,610.3 hours in 2025, or 4.5 hours per employee across 6,149 employees, against 33,630 hours and 6.2 hours per employee across 5,419 employees in 2024 (pages 187-188). Women averaged 6.8 hours and men 3.86 (page 187, footnote 37). Total training spend was 294,540 euros (page 186). The Group runs an annual training plan of in-house programs, inter-company courses, conferences, certification courses, language classes and postgraduate sponsorship, delivered partly through a central digital Learning Management System (pages 185-186). Training is open to the whole workforce without exclusion (page 186). A performance evaluation system in each subsidiary "covers all employees" (page 189).

Reference: pages 189-190 (EU-law datapoints on page 225).

The health and safety management system covers 13,814 of 14,094 people in the own workforce, or 98.0% (2024: 100%); the base includes employees, non-employees and subcontractors (page 189). Accident data (page 190):

"Employees" includes non-employees from S1-7; "other workers" are trainees and subcontractors insured by the Group. The table is headed 2025 and the second pair of columns carries no year, so it is read here as 2024. Frequency and severity rates use a 200,000-hour factor (page 190). Recordable cases of work-related ill health are reported as 0, subject to legal restrictions on data collection.

Reference: page 191.

All employees are entitled to family-related leave (page 191). In 2025, 5,899 employees were recorded as entitled (95.9%): 4,623 men (96.1%) and 1,276 women (95.4%). In 2024 the figure was 1,187 employees (21.9%). In 2025, 519 entitled employees took leave (345 men and 174 women), or 8.8% (men 7.5%, women 13.6%); in 2024, 235 took leave, or 19.8% (page 191). Family-related leave is defined by national labor legislation and includes maternity, paternity, parental and carers' leave (page 191). The Group says it is "committed to supporting and improving employees' work-life balance" (page 191).

Reference: page 192.

The gender pay gap is 20.1% in 2025 (2024: 15.1%), defined as the difference between average pay of female and male employees as a percentage of average male pay (page 192). The ratio of the annual total remuneration of the highest-paid individual to the median annual total remuneration of all other employees is 22.6 in 2025 (2024: 32.0) (page 192). The 2024 ratio was reassessed so that the remuneration of the Group's Chief Executive Officer is the reference value (footnote 43, page 192). The Group says it has adopted a compensation framework for all positions and roles that links pay to skills and role responsibilities (page 192).

Reference: pages 192-193 (EU-law datapoints on page 225).

13 incidents of discrimination, including harassment, were reported in 2025 (2024: 12), and 13 complaints were filed through channels for the own workforce to raise concerns (2024: 12) (page 192). The fines, penalties and compensation for these incidents are shown as 0 in both years (page 192). Severe human rights incidents were 0 in 2025 and 2024, including cases of non-respect of the UN Guiding Principles, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines, with no related fines (page 193).

Reference: pages 194-195 (EU-law datapoints on page 225).

Policies cover the one material impact, safe working conditions across the value chain (page 194). The Health, Safety and Environment Policy includes value chain workers in scope, and the ESG Policy sets health and safety measures, targets and actions that cover contractors, subcontractors and joint venture workers (page 194). The Human Rights Policy names value chain workers (subcontractors) as a stakeholder group (page 195). The Procurement Policy sets expectations for suppliers and partners on human rights, health and safety, non-discrimination, freedom of association and the prohibition of forced and child labor; contracts carry mandatory health and safety compliance clauses, and the Group says it will end a collaboration if criteria are not met (page 195). The Chief Executive Officer approves the Policy, the Internal Audit Department monitors it, and the Procurement Director and Compliance Officer oversee due diligence questionnaires and supplier inspections (page 195).

Reference: pages 197-199.

Actions to prevent health and safety impacts, carried out each year: an ISO 45001:2018 certified system, procedures and resources for protecting every worker, health and safety training, health and safety plans for all projects and facilities, and use of the Procurement Policy and ESG criteria in selecting suppliers and partners (page 197). Suppliers must implement or hold certification under recognized occupational health and safety systems (ISO 45001), train their staff, provide safe workplaces and sanitary facilities and, where needed, clean accommodation (page 198). Subcontractors take part in all general health and safety courses and get specialized training, such as working at height (pages 198-199). The report says no human rights violations or value chain issues were recorded in 2025 (page 198). When tensions arise, a crisis-management plan sets up dialogue committees of employee representatives, management and independent advisors (page 198).

Reference: page 199 (see also S1-5).

Three of the Group's health and safety targets in the ESG Policy relate to value chain workers, mainly subcontractors insured by the Group and workers in joint ventures or special-purpose entities: zero fatalities (base year 2022), introductory health and safety training for 100% of employees before construction or operation starts, and role-specific specialized training (page 199). Partners' views and experience on working conditions informed the targets through dialogue (page 199). Performance is monitored through the Group's health and safety management mechanisms, reviewed by Management and used for lessons learned (page 199). The Group says it is developing "a specific strategy and action plan for the quantification of targets" with a timeline for each target (page 199).

Reference: pages 201-202.

The Sustainable Development Policy gives the framework for responsible operations, with commitments on protecting human rights, managing environmental impacts, and supporting and engaging local communities (page 201). It covers all Group employees, interns, contractors, subcontractors and subsidiaries without their own ESG Policy, and joint ventures where the Group manages them (page 201). The Sustainable Development and CSR Department implements and monitors it; Management reviews targets and provides resources (page 202). The Sustainable Procurement Policy prioritizes local suppliers (page 202), and the Human Rights Policy recognizes local communities as a distinct stakeholder category (page 202). The material impact is a positive one: support for local employment and the local business ecosystem (page 201).

Reference: pages 203-205.

Priority goes to supporting the local economy. In 2025, 93.6% of the Group's suppliers were local, and purchases from them were 88.9% of total procurement spend (page 204). The Group carried out 326 sponsorship and donation initiatives with social investments of 5.5 million euros; 98.9% of actions took place in Greece, 94% at regional level, and in more than 40 municipalities (page 204). Themes: critical social needs (for example rebuilding the Nea Penteli Indoor Sports Hall after the 2023 wildfire), environment and natural capital (500 trees planted at the Aristotle University of Thessaloniki campus), social solidarity, health (hospital equipment donations), education and skills, and inclusion (page 204). The Group records each expenditure by amount, purpose, category and area, and assumes the recorded data is accurate and complete (page 205).

Reference: page 205.

No targets are set. The report says that "During the reporting period, the Group had not established specific quantitative or qualitative targets exclusively related to affected communities" and ties this to the maturity of its sustainable development strategy (page 205). It prioritizes strengthening its processes for identifying, assessing and managing impacts on affected communities, building a framework to monitor the topic, and evaluating whether to develop indicators and targets (page 205). The Group says it is considering targets in future reporting periods once the supporting processes are complete and the required data is dependable (page 205).

Reference: pages 212-215.

The Group lists the policies behind its business conduct: Code of Conduct; Regulatory Compliance, Corruption and Bribery Control; Policy for Addressing Unhealthy Competition; Travel and Hospitality Expenses; Gift; Sanctions; Conflict of Interest; Violence and Harassment; Whistleblowing; Sponsorship and Donations; Remuneration; Board training; Business Continuity; and Health, Safety and Environmental (pages 212-213). The Code of Conduct applies to all companies and subsidiaries and aligns with ISO 9001, 14001, 45001, 39001, 37001, 37301, 50001 and SA 8000 (page 213). The Regulatory Compliance Committee and Unit report to the Board and monitor it, and the Compliance Officer runs an internal audit program (page 213). Whistleblowing follows Law 4990/2022, which transposes Directive (EU) 2019/1937, and the Compliance Officer receives reports and protects identities (page 215). All personnel take annual e-learning on compliance and the Code, covering conflicts of interest, corruption and bribery, and workplace harassment (page 215). The Group has no specific animal welfare policy because it is "not applicable to its activities" (page 213).

Back-filled from the business conduct chapter, where effectiveness is tracked through indicators and reviews (MDR-T) rather than a numbered disclosure requirement. G1-3 Targets became a standalone disclosure requirement only in the 2025/2026 ESRS.

Reference: pages 214, 216-217, 221.

No quantified business conduct target is set. The report instead tracks effectiveness: it "is monitored through indicators and periodic review cycles" (page 214), the Regulatory Compliance Officer assesses the ISO 37001 system and reports to the Board (page 216), and the Group "monitors its performance against specific indicators related to business conduct, corruption and bribery" (page 216). The 2025 indicators are zero convictions, zero fines, zero confirmed incidents and zero dismissals or disciplinary actions for corruption or bribery, unchanged from 2024 (page 217). For the entity-specific topic Value creation, effectiveness is monitored through financial performance metrics in the business plan and supplier value metrics under GRI 204-1 (page 221).

Reference: pages 216-217 (EU-law datapoint on page 226).

Indicators for 2025 and 2024 (page 217): 0 convictions for violations of anti-corruption and anti-bribery laws, EUR 0 in fines for such violations, 0 confirmed incidents of corruption or bribery, and 0 confirmed incidents in which employees were dismissed or disciplined. Every indicator is zero in both years. The EU Taxonomy minimum safeguards section says "In FY2025, no incidents of corruption or bribery were reported" (page 91).