HELLENiQ ENERGY Holdings

The role of the administrative, management and supervisory bodies

Board of Directors Structure and Responsibilities

The Company is governed by the Board of Directors (BoD), a body which is collectively responsible for its long-term success. The Board of Directors exercises its responsibilities in accordance with Greek legislation, international best practices, the Company's Articles of Association and any decisions reached by the General Meeting of the Company's shareholders.

The BoD comprises eleven (11) members who are elected in accordance with the provisions of Article 20 of the Company's Articles of Association. The present BoD was elected by the Annual General Meeting of 27th June 2024.

BoD Composition (27.06-31.12.2024)

Key Responsibilities of the BoD

1. Decides on any act concerning the Company's representation, governance, its assets' management and the pursuit of its purpose, in general;

2. Manages the corporate affairs with the object of promoting the company interest; oversees the implementation of its decisions, as well as of those of the G.M.;

3. Determines and supervises the corporate governance system of articles 1 to 24 of L.4706/2020, and monitors and periodically assesses, at least every three (3) financial years, its implementation and effectiveness, proceeding to the necessary actions for dealing with deficiencies;

4. Ensures the adequate and effective operation of the Company's Internal Audit System ("IAS");

5. Ensures that all operations comprising the ICS are independent of the business segments they control and that they have the appropriate financial and human resources, as well as the powers for their effective operation, as prescribed by their role. The reporting lines and allocation of responsibilities are clear, executable and duly documented;

6. Makes sure that the Company's annual financial statements, the annual management report and the corporate governance statement, their consolidated form, as well as the BoD members' remuneration report, are drafted and made public in accordance with the provisions of the law;

7. Recommends to the G.M. the appointment of a certified auditor accountant or audit firm;

8. Ensures that the Company's strategic planning is aligned to corporate culture;

9. Approves the strategic and the annual business and financial plan;

10. Determines the extent of the Company's exposure to risks it intends to assume;

11. Ensures that an effective regulatory compliance procedure is in place;

12. Sets or/and delimits the responsibilities of the Chief Executive Officer and of the other persons to whom it is entitled to delegate powers of the Company's management and representation, in accordance with the Company's Articles of Association;

13. Posts and keeps updated the information regarding the election of its candidate members;

14. Is updated and decides on any other development affecting the Company's status and operation.

Roles of Key Positions

BoD Chairman: The BoD Chairman, who is a non-executive member, is responsible for convening, chairing and steering the meetings, for the keeping of minutes, the signing of the relevant resolutions and for the BoD's operation, in general, as this is provided in the Company's Articles of Association and the law.

Chief Executive Officer: The Chief Executive Officer serves as the principal governing authority and legal representative of the Company, bearing responsibility for all business segments and operational activities. The Group Internal Audit General Division reports administratively to the Chief Executive Officer.

Senior Independent Director: Mr. Iordanis Aivazis was appointed as the Senior Independent Director with the following responsibilities: i. supports the Chairman of the BoD, ii. coordinates the effective communication between the Chairman and the BoD members, iii. chairs the meetings of the non-executive members of the BoD and the procedure concerning the evaluation of the Chairman by the BoD members.

BoD Committees

The BoD has established committees, comprised of members thereof, with advisory, supervisory or/and approving authorities:

I. Audit Committee

• Comprised of independent non-executive members
• Supports the BoD in oversight of financial statements, internal controls, risk management, compliance, and auditing procedures

II. Strategy and Risk Management Committee

III. Sustainability Committee

Executive Management

Integration of sustainability-related performance in incentive schemes

Remuneration Policy Framework

The Group has established a Remuneration Policy designed to define the remuneration framework in a manner that ensures adherence to the requirements of the prevailing legal framework and enhances transparency in the determination and disbursement of remuneration to the members of the Board of Directors in a clear and comprehensible manner. The Remuneration Policy has been approved by the Extraordinary General Meeting of the shareholders of 20/12/2019, modified by the Annual General Meeting of the shareholders of 30/06/2021 and further revised by a resolution of the Annual General Meeting of the shareholders of 27/06/2024. The Policy is valid for four (4) years following its approval date, unless it is revised and/or amended earlier by virtue of another resolution of the General Meeting due to material change in the circumstances on the basis of which the Policy was drafted.

Roles Covered

The policy applies to members of the Board of Directors and senior management executives and other executives of the Company and/or its affiliated companies.

Variable Remuneration Framework

Short-Term Incentive (STI)

The quantum of any variable remuneration is intrinsically linked to the achievement of group, corporate, and individual objectives and is computed as a percentage of the annual gross regular remuneration, contingent upon the executive's rank within the Company's organizational structure, as articulated in the Board of Directors' Remuneration Policy.

Objectives for fiscal year 2024:

• Safety
• Competitiveness and efficiency
• Profitability and financial performance
• Progress in the energy transition plan (transformation program Vision 2025)

The Group establishes its objectives annually, aligning them with the business plans of each Operational and Executive Unit as well as the overall Group strategy. These objectives are shaped by current conditions and anticipated developments for the year, focusing on priorities specific to each unit. Progress is monitored throughout the year, and adjustments to the objectives or their weighting may be made if circumstances change, or new information emerges.

Long-Term Incentive (LTI)

The Annual General Meeting that took place on 27 June 2024 approved a Long-Term Incentive Plan (LTIP) in the form of stock award program (free distribution of shares) for senior management executives and other executives of the Company and/or its affiliated companies.

The long-term incentive plan (LTIP) encompasses two evaluation cycles (each lasting three years) and shares are vested gradually (per evaluation cycle) over three years. The award of the shares requires the achievement of specific objectives and key performance indicators (KPIs) which are defined by the Remuneration & Succession Planning Committee of the Board of Directors.

For the 1st evaluation cycle (2024-2026), KPIs include:

• Financial targets: 60% weighting
• Transformation targets: 20% weighting
• ESG targets: 20% weighting

Sustainability-Related KPIs

Climate-related considerations are integrated into the Group's variable remuneration structure, while the Sustainability Committee assesses performance against established targets related to greenhouse gas (GHG) emission reductions, which are, by extension, a key component of the Group's sustainability goals.

The variable remuneration is predicated on the evaluation of key Group objectives including KPIs associated with:

• Safety (directly linked to sustainable development, associated with safety indicators such as LWIF and AIF accident KPIs)
• Profitability
• Financial performance
• Competitiveness
• Successful implementation of the transformation plan (associated with KPIs related to the Vision 2025 Transformation Plan including financial benefits of the Digital Transformation plan, investments in Refining & Petrochemicals, Domestic Marketing Transformation Plan, and the expansion of the RES projects portfolio)

The objectives safety and development are directly linked to sustainable development as they are associated with safety indicators such as LWIF and AIF accident KPIs, as well as KPIs related to the Vision 2025 Transformation Plan.

Governance and Oversight

The Sustainability Committee supervises reporting obligations pertaining to Sustainable Development and ESG KPIs that are included in financial statements and other reports submitted to financial agencies.

The percentages of variable remuneration per objective dependent on sustainability-related targets are outlined in the latest remuneration report of the Group.

Risk management and internal controls over sustainability reporting

Main Features of the Systems of Internal Controls and Risk Management

The Group System of Internal Controls and Risk Management in relation to the financial statements' and financial reports' preparation process includes controls and audit mechanisms at different levels within the Organization.

Risk identification, assessment, measurement and management

The prevention and management of risks forms a core part of the Group's strategy. The scope, size and complexity of the Group's activities require a composite system of methodical approach and treatment of risks, which is applied by all Group companies.

The identification and assessment of risks is carried out mainly during the strategic planning and the business plan preparation phase. The benefits and opportunities are examined both in the context of the Company's operations, but also in relation to the several and different stakeholders who may be affected.

The examined risks include a) operational, b) financial and c) strategic risks, as well as d) regulatory compliance and supervision risks. More specifically and indicatively, issues that are examined include the effect of operational availability of units, supply chain, human resources, technological developments, taxation, interest rates, commodity prices, exchange rates, among others. Also, issues related to health, safety and environmental, corporate governance and regulatory compliance risks are assessed, risks related to the business model and strategy, as well as market trends (competition, geopolitical developments, regulatory developments).

Planning and monitoring / Budget

The Company's progress is monitored through a detailed budget per operating sector and specific market. The budget is adjusted at regular intervals to consider the changes in the development of the Group's financials that depend greatly on external factors, including the international refining environment, crude oil prices and the euro / dollar exchange rate. Management monitors the Group's financial results through regular reporting, comparisons vs the budget, as well as through Management Team meetings.

Adequacy of the Internal Control System

The Internal Control System (ICS) consists of the policies, procedures and tasks which have been designed and implemented by the Group's Management for the effective management of risks, the achievement of business objectives, for ensuring the reliability of the financial and managerial information and compliance with Laws and regulations.

The independent Group Internal Audit General Division (GIAGD), through conducting periodic assessments, ensures that the risk identification and management procedures applied by the Management are adequate, that the ICS operates effectively and that information provided to the BoD regarding the ICS, is reliable and of good quality.

The Internal Audit General Division draws up a short-term (annual), as well as a rolling long-term (three-year) Audit Plan based on ad-hoc risk assessment, as well as on other issues identified by the Audit Committee and the Management also in past audit reports. The Audit Committee is the supervisory body of the Internal Audit General Division.

The Internal Audit General Division submits quarterly reports to the Audit Committee, in order for the systematic monitoring of the Internal Audit System's adequacy to be feasible.

Monitoring and Risk Management Division

The purpose of the Monitoring and Risk Management Division is to centrally monitor and coordinate the management of the Group's exposure to internal and external risks. The Division was formed in 2024 and is independent from executive activities and supports the ICS's operation through determining principles and setting up and implementing appropriate and updated policies and procedures governing their identification, assessment, quantification/measurement, monitoring and management.

Compliance Office

Compliance Office is responsible for monitoring the Group's Compliance Risk and forms part of the Internal Control System (ICS) and reports at an operational level to the Audit Committee and at an administrative level to the Director of Monitoring and Risk Management. By its report to the Audit Committee, it contributes to the ICS's improvement and adequacy, as its objective is to ensure that appropriate and updated policies and procedures are set up and implemented, in such a way that the Company's full and constant compliance to the applicable regulatory framework is achieved.

Information systems' controls

Given the critical dependency of financial reporting processes on information systems, the Group has implemented a series of measures to ensure the effective operation of security controls. These measures preserve the completeness and accuracy of financial records and information that generate financial reporting, while also ensuring the continuity of IT services in the event of unexpected events that could cause loss of system availability (Disaster Recovery).

To this end, the Group has appointed a Chief Information Security Officer (CISO), who reports to the Audit Committee on a quarterly basis and is responsible for managing the Information Security Framework. This Framework includes cybersecurity policies and procedures aligned with international best practices and standards, reflecting Management's commitment to managing cyber risks.

The Group employs a multi-layered approach to protect its information, supported by a strategic plan that incorporates state-of-the-art technologies and top-tier information systems, while ensuring compliance with the required regulatory frameworks and directives, such as the Personal Data Protection Regulation and the NIS2 Directive (L. 5160/2024).

Financial fraud prevention and detection

In the context of risk management, the areas that are considered to be of high risk for financial fraud are monitored through appropriate Control Systems and accordingly increased controls are in place. Examples include the existence of detailed organizational charts, operation regulations (procurement, investment, oil products' market, credit, treasury management), as well as detailed procedures and approval authority levels. In addition to the internal controls applied by each Division, all Company operations are subject to audits by the Group Internal Audit General Division (GIAGD), the results of which are submitted to the BoD.

Strategy, business model and value chain

About Us

The Group consists of 96 companies, including the Parent Company, which is listed on the Athens Exchange and on the London Stock Exchange (through Global Depository Receipts -GDRs-). The Group has established a business structure to manage and monitor its activities. Specifically, all Group activities are classified into the following key segments (Strategic Business Units):

• Refining, Supply and Trading • Marketing (Domestic and International) • Production and Trading of Petrochemicals • Electricity Generation (from conventional and renewable energy) and Trading & Natural Gas • Exploration and Production of Hydrocarbons • Electromobility

Additionally, the Group is engaged in other activities that, despite their strategic importance (e.g., Engineering Services), do not constitute a significant part of the Group's financial position.

Strategy

Aligned with the "Vision 2025" strategic plan, the Group's strategy focuses on three strategic pillars, underpinned by cross-functional initiatives related to the operating model and governance. The ultimate goal is to broaden and diversify the business portfolio, enhance profitability and create long-term value for shareholders.

The three strategic pillars are:

1. Strengthen and decarbonize the downstream business: evolve refining and petrochemicals through decarbonization and digital transformation, expand international market reach and focus marketing efforts on customer needs by further utilizing digital technologies.

2. Grow in adjacent areas by leveraging downstream position: establish a meaningful presence in biofuels, enhance offerings through e-mobility services, and examine pathways for developing renewable fuels such as green hydrogen and synthetic fuels.

3. Develop a vertically integrated green utility: grow renewables portfolio, expand the geographical footprint and integrate the utility business, while maximizing synergies across the green utility platform and the Group.

Operating model & governance

These horizontal initiatives encompass a range of actions aimed at attaining diverse objectives. They include further extending digital transformation, increasing the focus on operational excellence, reorganizing and further investing in human capital, integrating risk management best practices into our business model, and redefining the ESG strategy. Our target is to achieve a 30% improvement in our GHG footprint by 2030, along with a 20% additional emissions avoidance through the expansion of the RES portfolio, with a commitment to achieving net-zero emissions by 2050.

Main objectives per business area

a) Refining, Supply & Trading and Petrochemicals

Key strategic initiatives include: • Prioritizing safety through comprehensive training programs, the implementation of stringent standards, and the enhancement of operational procedures • Facilitating digital transformation by optimizing the supply chain through mass balance and load point management, predictive maintenance, and process safety management systems • Implementing energy efficiency and energy autonomy projects across all refineries • Investing in the production of biofuels through the development of a new stand-alone 150ktpa Sustainable Aviation Fuel (SAF) production unit • Developing carbon capture and storage (CCS), with options for fuels production through the conversion of the Steam Methane Reforming (SMR) unit at the Elefsina refinery • Developing the 'Green Hub North' project, which involves the installation of a photovoltaic/battery energy storage system (PV/BESS) project and a direct high-voltage line to the Thessaloniki refinery • Establishing a new trading company in Geneva to manage the supply of all refining systems' crude and feedstocks, as well as the trading of products • Exploring opportunities within the hydrogen economy, recycling and synthetic fuels, including the production of: E-methanol and e-jet fuels by utilising a portion of the captured CO2 from the CCS unit and green hydrogen derived from renewable sources; E-ammonia by using the excess electricity from the 'Green Hub North' project at the Thessaloniki refinery and green hydrogen from renewable sources • Investing in the production of high value-added petrochemical products by increasing the polypropylene production capacity to 300 ktpa from the existing 240ktpa.

b) Marketing

Domestic Marketing The EKO Excellence strategic transformation program progressed in 2024 through its second and third phases, aiming to strengthen the business's position in the fuel and energy market, significantly enhance profitability, expand into new fuels and services, and move towards net-zero energy by installing EV chargers and photovoltaic systems at our petrol station network.

The main initiatives include: • Rationalizing and expanding the network • Increasing the market share of COMO service stations and premium products • Expanding the range of products and services (NFR, EV charging services, loyalty program) • Implementing a "net-zero energy" approach at COMO stations • Developing a commercial strategy for industrial clients

International Business Key priorities include: • Maintaining a leading position in Cyprus, Montenegro and the Republic of North Macedonia • Pursuing further expansion in Bulgaria and Serbia through targeted network growth and optimization of the supply chain • Expanding the range of products and services through by implementing loyalty programs and establishing EV charging points • Installing photovoltaic systems across our petrol station network to achieve net zero emissions • Improving the profitability of OKTA and resuming the operation of the VARDAX pipeline • Exploring the potential for cross-border electricity trading

c) Renewable Energy Sources (RES)

The Group aims to establish a regional leading position in the renewables market through: • Developing a 1 GW portfolio of operational capacity by 2026, and 2 GW by 2030 consisting of PV, wind and energy storage projects both in Greece, as well as internationally. • Developing offshore wind projects. • Strengthening its energy management capabilities.

The Group has already positioned itself as a leading player in both the Greek market and selected international markets, with a portfolio of projects under development exceeding 5.2 GW. The total installed capacity in 2024 reached 494 MW, with projects in Greece and Cyprus, while 0.6 GW of projects are currently being constructed or are in advanced stages of development.

d) Power Generation & Natural Gas

HELLENiQ ENERGY's ambition is to build a best-in-class green utility of the future, while also leveraging synergies with its refining, marketing, renewable energy and e-mobility businesses.

e) Exploration & Production

The Group is focusing on specific offshore blocks in Crete and the Ionian Sea: • Processing of 3D seismic data for the Southwest Crete and West Crete blocks in collaboration with ExxonMobil. • Interpreting 3D seismic data for three offshore regions, namely "Ionian", "Block 2" and "Block 10" will contribute to further evaluations and final decisions for the next steps.

f) E-mobility

The Group is steadily growing its position in the EV charging market in Greece and internationally, by expanding its range of mobility products and services. These include further developing customer e-mobility solutions, expanding the DC charging network at petrol stations and other points of interest while developing an AC charging network at public, semi-public and private locations of interest.

g) Digital Transformation

HELLENiQ ENERGY's Horizon Program, an essential component of the Group's transformation strategy (VISION 2025), is progressing successfully, by upgrading the way our people work, supporting performance improvement initiatives and expanding its footprint in new areas of business activity.

So far, more than 120 digital initiatives have been initiated or completed across the organization, involving over 500 people in various working groups and utilizing more than 2,500 hours of specialized training.

The multi-year action plan consists of initiatives across 4 pillars:

1. Digital Refinery, with the objective of evolving into a modern, collaborative, interconnected refinery.
2. Digital Retail, with the objective of delivering the service stations of the future, offering enhanced digital experiences, more information and improved services to partners and corporate customers.
3. Digital Enterprise Operations, aiming at more efficient operations through automation and more effective decisions by utilizing a wide range of data.
4. Digital Core, aiming at the modernization of the central enterprise resource management (ERP) system by leveraging the latest technological advancements.

The Digital Transformation program, initiated five years ago with a total investment of €65 million, has generated substantial financial returns. The cumulative financial benefit has surpassed €100 million and is projected to reach €200 million by the end of 2026. Additionally, the estimated annualized benefit is projected to surpass €50 million from 2025 onwards and €70 million by the end of 2028.

Interests and views of stakeholders

Identified Stakeholder Groups

Stakeholders are defined as entities or individuals who may be significantly impacted by the Group's activities or who may influence the Group's ability to implement its business strategy and achieve its objectives. Engagement with stakeholders constitutes an integral component of the Group's due diligence process, as well as the assessment of material impacts, risks and opportunities pertaining to sustainability matters.

HELLENiQ ENERGY's stakeholder groups as identified are presented below:

• Employees
• Business Customers
• Consumers
• Fuel Station Owners
• Suppliers and Business Partners
• Shareholders and Investors
• Society
• Local Communities
• State and Regulatory Authorities

Engagement Methods and Frequency

The table below presents the categories of stakeholders within the Group, along with the methods and frequency of engagement with each category. Furthermore, it highlights the most significant topics that emerged following the assessment of the material matters for each of the entire Group's stakeholder categories.

Engagement is conducted throughout the year by utilizing various channels, facilitating two-way communication that informs the Group's decision-making process. Stakeholders are informed through annual reports, questionnaires, meetings, and day-to-day interactions. As part of the double materiality assessment, key stakeholders are involved in the process through targeted discussions on sustainability matters.

Integration of Stakeholder Views into Strategy and Business Model

These approaches are systematically integrated into the Group's strategy for sustainable development.

In order to strengthen its commitment to sustainable development, HELLENiQ ENERGY makes sure that its business model is aligned in a way that is in line with the stakeholders' pulse.

Each year, the company takes specific steps to review and improve its management systems, ensuring they align with stakeholder expectations and deliver high performance. These steps include keeping a close eye on environmental responsibility and implementing best practices for the safe handling of products. To ensure consistent performance that promotes sustainability and stakeholder satisfaction, HELLENiQ ENERGY implements certified management systems for Quality, Health and Safety, Environmental, and Energy standards across all its production, storage, and distribution facilities.

Finally, the Group during the DMA process gathers feedback directly from internal & external stakeholders through discussions, understands what matters to them and adjusts its strategy accordingly. This approach helps build trust, ensures the business is responsible and sustainable, and creates value for both the Group and its stakeholders.

To ensure that a company's business model remains relevant and resonates with the views of its stakeholders across geographies, HELLENiQ ENERGY has taken and plans to take some further steps to achieve that.

Additional Steps in Stakeholder Engagement

The Group applies the best operating practices for the safe handling of products, with due regard for environmental preservation. For all its production, storage and handling facilities, HELLENiQ ENERGY has a certified Quality, Occupational Health and Safety, Environmental and Energy Management System. These management systems, in particular, are evaluated and renewed annually in order to achieve a high level of performance for stakeholders.

Risk prevention and management are key to HELLENiQ ENERGY's strategy. The identification and assessment of risks are repeated every year, mainly during the preparation phase of strategic planning and the annual business plan. All impacts as they arise are considered both in the context of the Group's activities, and in relation to the different stakeholders potentially affected.

HELLENiQ ENERGY has planned several new initiatives and projects for 2025, aimed at further driving the Group's transformation, improving employee work experience, and enhancing service to customers and partners. In specific, in 2025 the following are expected:

• Digitalization of the communication and consumer service channel through the e-EKO program.

• Expansion of digital solutions in all Group activities (including RES and e-Mobility).

• Leverage on new technological trends and their integration.

• Development of centralized strategic management data for use in holistic solutions.

Governance of Stakeholder Engagement

HELLENiQ ENERGY employs a structured approach to keep the Sustainability Committee informed about stakeholder views and interests. The Committee oversees stakeholder engagement and communication strategies to understand their interests, provide insights on key issues, and it supervises the Sustainability Policy. The Sustainability Committee provides guidelines on the pillars of the sustainable development policy, including health and safety, the environment, climate change, and social impact, while assisting in managing associated risks.

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

Overview of material IROs

HELLENiQ ENERGY has identified 16 material impacts, risks, and opportunities (IRO) across 6 material sustainability areas:

• Climate change mitigation and adaptation
• Pollution of atmosphere
• Health, safety and well-being
• Economic impact
• Mobility
• Energy (access and availability)

These IRO primarily relate to environmental and social matters, extending across both present and future timeframes, with their materiality generally increasing over the long-term. There is significant interconnection of those IRO throughout the value chain, predominantly within the organization's own operations.

Interaction with strategy and business model

This interdependency requires the adaptation of strategy and the adoption of a comprehensive approach across multiple dimensions, including the resolution of operational challenges, the enhancement of daily operations, the restructuring of corporate governance, and the improvement of risk management protocols. The outcomes of the DMA have affirmed the necessity to progress and accelerate energy transition as outlined in the Group's strategic plan, to address the challenges and capitalize on opportunities.

Strategic priorities and transformation:

HELLENiQ ENERGY invests in new business activities, prioritizing RES, energy storage, electromobility, and sustainable fuels, with a target of exceeding 1 GW RES capacity by 2026 and 2 GW by 2030. Expanding RES activities and the electric vehicle (EV) charging network aligns with the Group's strategy to support sustainability, reduce CO₂ emissions, and combat climate change. RES projects, including onshore wind and solar, contribute to the ESG goal of increasing renewable capacity and contributing to 20% CO2 emissions avoidance, while delivering power to underserved areas where grid expansion is challenging. Additionally, the Group's EV infrastructure projects facilitate the transition to a low-carbon economy and enhance access to sustainable transportation. These initiatives reflect a resilient strategy and business model, enabling the Group to effectively manage material risks, address impacts, and seize opportunities.

Material IROs per time horizon and value chain level

A total of 71 IROs were identified and evaluated as part of the DMA. Of these, 16 were deemed material across 6 sustainability matters. Specifically, with regard to Impact Materiality, 24 impacts (I) were assessed, of which 8 were deemed to be material. In terms of Financial Materiality, 47 risks and opportunities (R/O) were assessed, of which 8 were deemed material.

The materiality of impacts, risks, and opportunities (IROs) is intrinsically linked to the nature of the Group's business activities. This relationship emphasizes sustainability considerations throughout the value chain, thereby influencing the sustainability of the business model. It also necessitates the adaptation of strategy and demands a meticulous approach across various dimensions, encompassing the resolution of operational challenges, the enhancement of daily operations, the restructuring of corporate governance, and the improvement of risk management.

Time horizons:

• Short-term time horizon: 2025
• Medium-term time horizon: 2026-2029
• Long-term time horizon: 2030-2035

The Group has updated its corporate structure to facilitate the implementation of the strategic plan, optimize risk management and secure funding that is appropriately aligned with the nature of each project. Following the completion of a series of refinancing activities, the Company has successfully improved its debt structure and funding profile, thereby extending the average maturity of its long-term debt and committed facilities. At the same time, the Company has signed in previous year a new, innovative financing framework (project finance agreement of up to €766m) for investments in the renewable energy sector in Greece.

Based on the Group's current strategic planning, prevailing market expectations, and existing insurance coverage, it is anticipated that no significant adjustments will be required within the forthcoming annual reporting period to the carrying values of assets and liabilities as reported in the associated financial statements.

The list of material impacts identified during the previous reporting period remains unchanged.

Climate-related IROs and resilience

Climate change impacts:

HELLENiQ ENERGY, following the Double Materiality Analysis, conducted a resilience analysis to evaluate its vulnerability to physical and transitional climate change risks. The final material climate risks identified refer to a medium-term (5-10 years) time horizon and are applicable to all business areas, especially those related to liquid fuels and chemicals.

The identified climate risks include adverse weather events such as wildfires, flooding, rising sea levels, heatwaves, lightning, dust, hail, and snow. In other words risks that could cause damage to energy infrastructure (e.g., wind turbines, oil rigs, pipelines, and solar panels), leading to power outages; disrupt transportation routes, affecting supply chains and employee mobility; reduce the efficiency of solar and wind energy production; increase operational costs due to higher cooling demands; and limit employee productivity due to heat stress.

EU ETS Considerations:

During the period 2021-2025 (the first sub-period of the 4th trading phase) and under the new free allocation rules, compliance costs have risen substantially due to the sharp increase in allowance prices (€73.5/ton CO2 at the end of 2024) compared to the end of previous phase (approx. €32/ton CO2) and the reduced allocation of emissions-free allowances under the current rules. A further increase in compliance costs and a heightened risk of carbon leakage are anticipated.

Opportunities:

HELLENiQ ENERGY has also recognized several opportunities in emerging low-carbon technologies developed to address climate change, such as blue and green hydrogen generation technologies, CO2 capture and storage technologies, and other solutions aimed at replacing fossil fuels with lower-carbon alternatives.

Resilience of Strategy:

The resilience analysis was conducted as part of the risk management assessment process, and its results are considered in the strategic planning cycles. It is noteworthy that HELLENiQ ENERGY already has a resilient strategy and business model, positioning it to effectively address material impacts and risks while capitalizing on opportunities. In accordance with the TCFD analysis, all critical facilities are resilient to climate-related risks, such as rising sea levels and extreme weather events.

While the Group faces significant transition risks as well as acute climate risks, including regulatory pressures and carbon price fluctuations, these challenges also present opportunities that drive diversification and long-term resilience. The Group's ability to proactively adapt to these risks and leverage emerging opportunities contributes to maintaining competitiveness and ensuring future growth.

Health and safety IROs

The material risks and opportunities arising from impacts and dependencies on HELLENiQ ENERGY's own workforce are closely integrated with its strategy and business model. The Group's strategy is subject to continuous refinement and adjustment to ensure alignment with operational resilience. This is achieved by considering potential risks, such as class action lawsuits and litigation, and opportunities, such as cost mitigation through the protection of employee health and safety, and the cultivation of a culture of safety and well-being among employees at all levels.

Investments are made annually in safety improvement projects at all Group's facilities, both in Greece and abroad. The Group has long cultivated a culture of safety and well-being among employees at all levels. This culture has contributed to the prevention of accidents, reduction in the frequency and duration of downtime, enhancement of workforce productivity, and overall protection of the health and safety of employees, partners, and the local communities in which it operates.

By prioritizing Health and Safety to enhance its positive impact on employees and partners, HELLENiQ ENERGY has established a working environment where risks are identified, assessed, and evaluated, with a constant focus on preventing and eliminating them. As a leader in the energy sector, the company aspires to provide a working environment devoid of accidents and occupational diseases across all its facilities.

Employees working in industrial facilities (e.g. refineries, fuel terminals, and other hydrocarbon facilities) or employees who visit those facilities to fulfill a specific task are facing a greater risk of harm.

Economic impact on affected communities

HELLENiQ ENERGY leaves a positive footprint on the Greek economy through its interactions with suppliers, customers, consumers, affected communities and the Greek State. The social and economic impact of HELLENiQ ENERGY is manifested in the following categories of influence:

• Direct impact: Effects directly generated by the productive activity of the Group and its trading partners, such as employee wages, taxes, and social security contributions, reinvested profits in the economy and directly supported jobs.
• Indirect impact: Effects created by the activity of the Group's direct suppliers and their suppliers, such as jobs, revenues, profits, and employee incomes.
• Induced impact: Effects created when the Group's direct employees, as well as employees of the Group's direct and indirect suppliers, spend their income within the broader economy.

Value chain distribution

There is significant interconnection of those IRO throughout the value chain, predominantly within the organization's own operations (midstream). Climate change impacts are mostly concentrated in the midstream value chain. Atmospheric pollution is related to the entire value chain of the Group's activities (upstream - due to emissions from the transport of raw materials; downstream - from the usage of fuels by end consumers; and own operations - emissions from industrial facilities and intra-group transport of products and raw materials).

Financial effects

Based on the Group's current strategic planning, prevailing market expectations, and existing insurance coverage, it is anticipated that no significant adjustments will be required within the forthcoming annual reporting period to the carrying values of assets and liabilities as reported in the associated financial statements.

Transition plan for climate change mitigation

Overview and strategic context

HELLENiQ ENERGY has initiated an energy transition plan with an emphasis on strengthening and decarbonizing its downstream operations, expanding into adjacent sectors, and establishing a vertically integrated green utility, with the objective of substantially reducing its carbon footprint. The implementation of the transition plan (also referred to as the 'corporate transformation plan' or 'Vision 2025') was driven by rapid changes in the energy environment. HELLENiQ ENERGY focuses on increasing its value by upgrading traditional activities and expanding in renewable energy sources (RES) and clean energy.

The Vision 2025 plan has been approved in the Extraordinary General Meeting of December 10th, 2021, by the Board of Directors. The core of the Group's strategy focuses on the major issues of sustainable energy for all and climate neutrality, as well as the adoption of corporate governance principles that ensure, as a priority, the safe and without accidents, financially sustainable operation, while respecting the Environment and Society.

Net zero target and alignment status

HELLENiQ ENERGY has set a commitment to Net Zero by 2050.

The transition plan focuses on reducing the carbon footprint and aims for climate neutrality by 2050. However, as energy companies that have net revenue above 50% from oil & gas activities cannot currently set a science-based target since the pertinent technical paper and guidance has not been finalized by the Science Based Targets initiative (SBTi) yet. The Group monitors diligently the Science-Based Targets initiative regarding the Oil and Gas activities. Once the methodology is finalized, it will be assessed.

The targets set are not fully compatible with limiting global warming to 1.5°C, as outlined in the Paris Agreement. HELLENiQ ENERGY is an energy company with significant oil & gas activity, as such is excluded from the EU Paris-aligned Benchmarks, as specified in the Commission Implementing Regulation (EU) 2022/2453.

Targets and milestones

The Program focuses on two main areas:

• Redefining ESG strategy and GHG emissions targets aiming for an improvement in environmental footprint by 2030 (30% reduction of Scope 1 and 2, 2GW RES) and a commitment to Net Zero by 2050.
• Realigning business strategy and capital allocation, with investments in the New Energy accounting for the largest share of growth-related investments.

RES capacity targets:

• 0.5 GW of RES in operation by end of 2024 (achieved)
• 1 GW by 2026
• Over 2 GW by 2030

GHG emission reduction achieved: During the reporting period, the Group achieved a reduction in absolute total GHG emissions of 243,490 metric tons, corresponding to a 5% reduction compared to the baseline year.

Scope of the plan

The transition plan applies to:

• All activities of HELLENiQ ENERGY and its subsidiaries
• All three refineries in Greece (Elefsina, Thessaloniki, and Aspropyrgos)
• Own operations across locations
• Upstream and downstream value chain activities
• Climate impacts are mostly concentrated in the midstream value chain (own operations)

The scope covers both transition risks (policy and market shifts) and physical risks assessed under the Net Zero Transition Scenario and High Emissions Scenario.

Key decarbonization levers

The key decarbonization levers are centered around the following areas:

a) Development of a new green pillar, with the addition of 0.5 GW of RES installed capacity in Greece and internationally since the adoption of the Vision 2025 transformation plan

b) Revamped group structure by establishing a Holding company and subsidiaries which enhances risk management, increases flexibility and enables tailor-financing solutions. Signing of a new financing framework of up to €766 million to facilitate acceleration of RES projects in Greece

c) Upgraded corporate governance introducing procedures that encompass sustainability-related criteria in decision making. ESG criteria are incorporated into Management's variable compensation.

Specific decarbonization actions:

• Energy efficiency and autonomy projects across all refineries
• Carbon capture, utilization and/or storage (CCUS) projects evaluation and development
• Production of biofuels and renewable fuels, including green hydrogen and other sustainable fuels
• Renewable energy sources (RES) development targeting 2 GW of operational capacity by 2030 across diverse geographies and technologies (photovoltaic and wind parks, battery storage, and hydro pump storage)
• Electromobility infrastructure and services development

Elefsina refinery will become a testbed for energy transition and decarbonization through:

• Investments in energy efficiency
• A co-generation unit to improve security of supply and enable investments towards energy efficiency
• Blue hydrogen through carbon capture
• Pilot production of green hydrogen through the use of RES electricity
• On-site solar energy production
• Expected avoidance of CO2 emissions: over 1,300,000 tons by 2030

Thessaloniki refinery will be upgraded with a 2G biodiesel coprocessing unit to increase sustainable feedstock in fuel products.

CapEx and investment commitments

Financial resources allocated to RES investments:

• Anticipated investments associated with the expansion in Renewable Energy Sources (RES) will exceed €1 billion over the forthcoming five-year period, spanning from 2025 to 2029.

2024 CapEx breakdown:

• Significant proportion of last year's investment expenditure was directed in driving green initiatives, including the expansion of the RES portfolio in Greece and internationally
• The quantified taxonomy-aligned Capex arising from activities such as electricity generation using solar photovoltaic technology, electricity generation from wind power, and related activities is disclosed in the EU Taxonomy section
• Total CapEx for coal-related economic activities: €0
• Total CapEx for gas-related activities: €0
• Total CapEx for oil-related activities: €257 million

Financing Framework: The Group developed a new, innovative financing agreement of up to €766 million to facilitate the acceleration of RES projects in Greece. This agreement is one of the largest in Europe and establishes a standardized platform for both existing and new relevant projects.

Locked-in emissions and stranded asset analysis

HELLENiQ ENERGY's potential locked-in GHG emissions arise from the activities of its three key refineries, which by default cannot be significantly altered, as refining is a significant Group sector. However, these emissions are not expected to jeopardize the achievement of the company's GHG emission reduction targets.

The Group is committed to enhancing operational efficiency through its strategic plan, Vision 2025. By focusing on sustainable practices, optimizing processes and investing in innovative technologies, the Group strives to reduce its overall environmental impact, ensuring that its emissions reduction targets remain achievable despite the challenges posed by locked-in emissions.

As part of the TCFD exercise, HELLENiQ ENERGY identified that the business activities of its three key refineries business will demand some additional improvement actions to be compatible with a transition to a climate-neutral economy. It's noteworthy that these emissions are not expected to jeopardize the achievement of the company's GHG emission reduction targets.

During the reporting period no critical climate-related assumptions were made in the financial statements.

Use of carbon credits and removals

EU ETS participation: Based on the Directive 2003/87/EC, the Group's refineries participate in the Emissions Trading Scheme of the EU. Current CO2 emissions (direct and indirect) are 3,946 kt and the current carbon price is over €70/ton which results in significant operational cost.

During the period 2021-2025 (the first sub-period of the 4th trading phase) and under the new free allocation rules, compliance costs have risen substantially due to the sharp increase in allowance prices (€73.5/ton CO2 at the end of 2024) compared to the end of previous phase (approx. €32/ton CO2) and the reduced allocation of emissions-free allowances under the current rules.

The refining sector is included among those facing a carbon leakage risk, which could lead to a significant deterioration in its competitiveness compared to similar facilities outside Europe.

Integration with business strategy

HELLENiQ ENERGY's transformation plan is integrated into and aligned with the organization's comprehensive business strategy (Vision 2025) and financial planning. Significant progress has been achieved thus far:

a) Enhanced corporate governance, with appropriate policies for the election of the Board of Directors, improved diversity, and independence

b) An optimized corporate structure

c) A new corporate identity

d) The implementation of energy-saving and autonomy projects, the maturation of investment options aimed at reducing carbon emissions, and the advancement of investments in Renewable Energy Sources (RES), with 0.5 GW of projects operational by the end of 2024

e) The streamlining of the Power & Gas portfolio by agreeing to acquire the remaining 50% stake in Elpedison that was not previously owned and monetizing the 35% stake in DEPA Commercial

Milestones achieved during the reporting period:

• Concrete actions across refineries towards HELLENiQ ENERGY's targets set
• Operational excellence in refining supported by digital transformation
• 0.5 GW of RES in operation, with additional 5.2 GW of RES projects under development
• Integration of new approval flow streams into Governance Structures for the approval of various initiatives
• Implementation of processes for monitoring targets by executives
• Significant progress in installed renewable energy capacity, reaching 0.5 GW

Governance and accountability

The Sustainability Committee assesses performance against established targets related to greenhouse gas (GHG) emission reductions, which are a key component of the Group's sustainability goals.

Climate-related considerations are integrated into the Group's variable remuneration structure. The variable remuneration is predicated on the evaluation of key Group objectives including KPIs associated with safety, profitability, financial performance and competitiveness as well as the successful implementation of the transformation plan.

The long-term incentive plan (LTIP) encompasses two evaluation cycles (each lasting three years) and for the 1st evaluation cycle (2024-2026), includes:

• Financial targets (60% weighting)
• Transformation targets (20% weighting)
• ESG targets (20% weighting)

Scenario analysis and resilience

The Group evaluates its transition plan for alignment with the national climate law, the national energy and climate plan and the national long-term strategy to ensure its targets always remain compatible with this objective.

Two scenarios are used:

1. Net Zero Transition Scenario: Reflects global decarbonization efforts to meet the Paris Agreement's targets, modeling pathways to achieve net-zero greenhouse gas emissions, aligning with limiting global warming to well below 2°C, preferably to 1.5°C. Considers assumptions from NGFS Net Zero 2050, Low demand, IEA Net Zero Emissions by 2050 (NZE2050), IPCC SSP 1-2.6.

2. High Emissions Scenario: Represents business-as-usual, with emissions that continue to increase with no changes to current policies, with warming over 3°C (4.4°C by 2100) and severe disruptions. Based on IEA Stated Policies Scenario (STEPS), NGFS Current Policies, IPCC SSP 5-8.5.

Portfolio of RES projects

In the renewable energy sector, the development strategy combines the maturity of a diversified portfolio of projects (PV, wind, biomass) and targeted acquisitions of matured or operating projects. Projects with a total capacity of more than 5.2 GW, mainly PV, wind parks and energy storage, are in various stages of development.

Policies related to climate change mitigation and adaptation

HELLENiQ ENERGY has established policies that address climate change mitigation, climate change adaptation, and energy efficiency.

Sustainability Policy

Scope:

• Applies to all activities of HELLENiQ ENERGY and its subsidiaries, including upstream and downstream value chain activities
• Covers all stakeholders, including employees, contractors, suppliers, and local communities
• No specified exclusions

Key content and principles:

• Guides the implementation and continuous improvement of the Environment and Energy Management Systems, based on international standards (ISO 14001 and ISO 50001, respectively)
• Involves developing audit, monitoring, and certification procedures
• Aligns with the Group's target of reducing its overall carbon footprint and achieving climate neutrality by 2050
• Addresses the major issues of sustainable energy for all and climate neutrality
• All environmental parameters are monitored through common indicators at European level and benchmarked against industry performance in Europe

Governance:

• Approved by the HELLENiQ ENERGY CEO and Sustainability Committee on March 29, 2024
• Ultimate accountability for implementing this policy lies with the Management of the Group and the Sustainability Committee

Public availability:

• The Sustainability Policy is accessible via the company's website to stakeholders who may be affected and to those that are responsible for its implementation

Links to international standards:

• Aligns with the United Nations' Sustainable Development Goals and the European Green Deal
• Policy development considered Task Force on Climate-related Financial Disclosures (TCFD) recommendations
• Incorporates certain EU ETS considerations

Implementation monitoring:

• Climate risk identification aligns with TCFD recommendations
• The sustainability team engaged with various stakeholders through consultations and climate-related discussions to gather input and align the policy with their expectations and concerns
• All HELLENiQ ENERGY and its Group companies' employees and contractors have the responsibility to comply with the Sustainability Policy

Actions and resources in relation to climate change policies

HELLENiQ ENERGY has focused its actions and resources related to climate change mitigation and adaptation on the following pillars:

Financing Framework for supporting the implementation of the Strategic Transformation Plan

Action description: The Group developed a new, innovative financing agreement of up to €766 million through its 100% subsidiary HELLENiQ Renewables, signed with National Bank of Greece S.A. and Eurobank S.A. for the implementation of multiple financing arrangements (Project Finance) for electricity generation from Renewable Energy Sources - RES (photovoltaic and wind parks). This agreement constitutes a benchmark and innovative transaction for the Greek market, being the first standardized financing framework ever concluded by a Greek Corporate group for existing and future RES transactions, and one of the largest respective financing arrangements in Europe.

Scope: Own operations (renewable energy projects in Greece)

Key benefits:

• Significant funding capacity, increasing the Group's growth potential
• Best-in-class terms, largely standardized, enabling speed of execution
• Flexible structure, fit-for-purpose for RES, allowing the release of resources to support the rest of the Group's activities
• Sufficient committed capacity to support RES growth in Greece
• Realignment of funding resources and capital structure to different business units
• Best-in-class financing terms offering competitive advantage

Resources allocated: Up to €766 million financing framework

Links to policy/target: Supports the Group's Vision 2025 and energy transformation plan

Energy Production and Storage from Renewable Sources

Action description: Development and operation of wind and photovoltaic (PV) projects across Greece and Cyprus, as well as energy storage initiatives including Battery Energy Storage Systems (BESS) and pumped hydro storage.

Scope: Own operations (Greece and Cyprus, with evaluation of international opportunities)

Time horizon:

• Short-term: 0.5 GW of operational capacity by end of 2024
• Medium-term: 1 GW by 2026
• Long-term: 2 GW by 2030

Current status (2024):

• Operational capacity: 0.5 GW (approximately 100 MW wind parks in Greece, about 400 MW PV projects in Greece and Cyprus)
• Projects in development: 5.2 GW total comprising:
  • 2.5 GW PV parks
  • 0.4 GW wind parks
  • 1.3 GW BESS projects
  • 0.5 GW pumped hydro storage projects
  • 0.4 GW hybrid projects
• 0.5 GW of projects under development are currently under construction (approximately 0.2 GW), ready-to-build (approximately 0.3 GW), or at advanced stage (50 MW)

Key achievements:

• Second-largest operator of PV parks in Greece, with landmark project in Kozani (204 MW)
• Selected for three BESS projects totaling 100 MW capacity and 200 MWh guaranteed storage capacity in Greece's inaugural tender
• Three eligible ESS projects (one 50 MW and two 25 MW each) to be developed within industrial facilities in Thessaloniki

Resources allocated:

• Investment exceeding €146 million in RES projects in 2024
• It is anticipated that the financial resources allocated to investments associated with the expansion in Renewable Energy Sources (RES) will exceed €1 billion over the forthcoming five-year period, spanning from 2025 to 2029

Expected outcomes:

• Total cumulative avoidance of CO2 emissions attributable to RES has surpassed approximately 1,100,000 tons of CO2 since 2013
• Approximately 347,000 tons of CO2 emissions avoided in 2024 alone

Strategy: Employs both organic growth and acquisitions

Links to policy/target: Contributes to the Group's target of reducing Scope 1 and 2 emissions by more than 30% by 2030 and achieving an additional avoidance of >20% of CO2 emissions through RES development

Participation in Research Projects

Action description: Designing and implementing innovative research projects through the New Technologies and Alternative Energy Sources Division, with support of European and national funding projects. Focus areas include:

• CO2 capture and use (downstream value chain)
• Production of sustainable aviation fuels
• Circular economy
• Hydrogen production
• Other cutting-edge technologies (midstream value chain)

Scope: Own operations and value chain (midstream and downstream)

Time horizon: Last five years of activity, ongoing

Partnerships: Collaboration with leading national and European Research Institutes and Universities

Links to policy/target: Supports Vision 2025 objectives and commitment to reducing carbon footprint and contributing to energy and climate transition

EU Taxonomy-Aligned Activities

The Group's actions are actively linked to the following EU Taxonomy-aligned activities contributing to climate change mitigation:

• Electricity generation using solar photovoltaic technology
• Electricity generation from wind power
• Installation, maintenance, and repair of charging stations for electric vehicles in buildings (and parking spaces attached to buildings)
• Acquisition and ownership of buildings
• Data-driven solutions for GHG emissions reductions

Resources: The quantified taxonomy-aligned Capex and Opex from these activities is disclosed in the EU Taxonomy section of the Sustainability Statement. Growing share of annual capital expenditures directed towards eligible-aligned activities over the next years.

Outcome of Actions & GHG Emission Reductions

Baseline year: 2019 (selected as representative year prior to implementation of significant decarbonization initiatives)

Achieved reductions (2024):

• Absolute GHG emissions reduction: 243,490 metric tons (5% reduction compared to baseline year 2019)
• Demonstrates increased efficiency and reduced carbon footprint across operations

Expected future reductions: Actions are expected to result in even greater reductions toward the Group's 2030 and 2050 targets

Targets related to climate change mitigation and adaptation

GHG Emission Reduction Targets

Supporting Targets (RES Capacity)

Additional Climate-Related Targets

Target Composition Details

Scope 1 & 2 Target Breakdown:

• Scope 1 share in target: 42%
• Scope 2 share in target: 58%
• Does not include GHG removals, carbon credits, or avoided emissions as a means of achieving targets
• Applicable to all operations across geographies

Methodology & Governance

• Baseline year justification (2019): Selected as representative year prior to significant decarbonization initiatives; aligns with EU ETS monitoring rules and industry benchmarks
• Target setting process: Based on TCFD framework, climate science data, industry benchmarks, Paris Agreement goals; involved internal teams, industry experts, external advisors
• Monitoring: Sustainability Committee tracks progress; Board of Directors has oversight
• Science-based status: Energy companies with >50% revenue from oil & gas cannot currently set SBTi-validated targets as Oil & Gas technical guidance not yet finalized by SBTi. Group monitors SBTi developments and will assess once methodology finalized.

Key Decarbonization Actions Supporting Targets

1. Development of RES green pillar (0.5 GW added since Vision 2025 adoption)
2. Energy efficiency and autonomy projects across all refineries
3. Carbon capture, utilization and/or storage (CCUS) projects
4. Biofuels and sustainable fuels production (biodiesel from UCO, standalone SAF plant)
5. Green and blue hydrogen production initiatives
6. Electromobility infrastructure expansion (~5,000 EV charging points target by 2030)
7. Direct high-voltage line and PV/BESS systems (e.g., Green Hub North project)

Financial Commitment

Anticipated financial resources for RES investments: >€1 billion over 2025-2029 period

Energy consumption and mix

Scope and methodology

The Group reports total energy consumption covering its own operations (refineries, petrochemicals, marketing fuel stations, RES assets, administrative buildings, and other facilities). Energy consumption is calculated using net calorific values aligned with ESRS E1-5 guidance. Renewable electricity generation from the Group's wind and solar parks is included in self-generated non-fuel renewable energy. Internationally recognized net calorific values are applied for energy conversions.

Total energy consumption

Total energy consumption for 2024: 4.12 million MWh (compared to 3.98 million MWh in 2023).

Disaggregated energy mix (MWh)

Energy intensity

Energy intensity (per revenue): 322.7 MWh per million EUR revenue (2024), compared to 310.9 MWh per million EUR revenue (2023).

The increase in total energy consumption and intensity reflects higher refinery production volumes in 2024 (15.4 million MT vs. 14.6 million MT in 2023). The slight decrease in renewable percentage is due to the denominator effect of higher overall consumption, despite stable renewable generation.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 Emissions

Subsidiaries are entities whose financial information is included in the consolidated financial statements of the Group.

GHG emissions by Substance (Scope 1)

Methodology notes: There are no direct emissions of biogenic CO₂. Refineries' emissions are monitored and verified since 2005 under EU ETS. The verified CO₂ emissions 2024 are 3,945,826 tn, corresponding to 99% of the overall scope 1 emissions. Consolidated approach for emissions reporting is based on operational control. External-body verification of EU ETS emissions according to EU Regulations 2018/2067 and 2018/2066. Other GHGs are reported according to Kyoto Protocol.

Scope 2 Emissions

Market-based

Location-based

Methodology notes: Domestic emissions were calculated using the consumption of electricity and the CO₂ emission factors (EF) of DAPEEP (residual mix of each supplier for market-based) for 2023 (DAPEEP Study 7/2023): PPC EF: 0.36319 kg CO₂/kWh, Elpedison EF: 0.36382 kg CO₂/kWh, HERON EF 0.36443 kg CO₂/kWh, METLEN ENERGY & METAL EF: 0.36528 kg CO₂/kWh and Volterra EF: 0.36364 kg CO₂/kWh. Greece CO₂ emission factor source (location-based) is NIR 2024 (364.884 kg CO₂/MWh). Emission factors used for other GHG is from IPCC 2006. 2024 was the first year that Scope 2 emissions were reported as CO₂e (CH₄ & N₂O emissions were added, accounting for 0.2% of the total emissions). 2023 Scope 2 emissions do not include other GHGs. Scope 2 location-based emissions are not comparable to last year's emissions due to change in the CO₂ emission factor source. Calculations for Group companies abroad are only location-based. CO₂ emission factors are for BULGARIA 0.547 kg CO₂/kWh, Republic of North Macedonia 0.475 kg CO₂/kWh, Serbia 0.678 kg CO₂/kWh, Montenegro 0.471 kg CO₂/kWh and Cyprus 0.707 kg CO₂/kWh. No Biogenic Emissions of CO₂ from Combustion or Biodegradation of Biomass (Not Included in Scope 2) were reported during 2024. The share of contractual Scope 2 emissions (GOs) is 22% and the GOs were issued on behalf of HELLENIC PETROLEUM RSSOPP S.A., from the electricity provider (ELPEDISON) for 2024.

Scope 3 Emissions

Categories excluded: Category 2 (Capital goods – partially included in Category 1), Category 6 (Business travel – included in Category 11), Category 7 (Employee commuting – included in Category 11), Category 8 (Upstream leased assets – related emissions included in Scope 1 as the Group has operational control), Category 13 (Downstream leased assets – not relevant to Group's activities).

Methodology notes: The Percentage of GHG Scope 3 calculated using primary data obtained from suppliers or other value chain partners is 2%. The Scope 3 calculation includes CO₂e emissions, with no biogenic CO₂ emissions. The calculation of Scope 3 GHG emissions does not include any removals, or any purchased, sold, or transferred carbon credits or GHG allowances. The GHG emissions calculations in significant Scope 3 categories have been performed by using suitable emissions factors mainly from Defra 2020 & 2024, GHG Protocol, EEA 2021, IPPC 2006, Fourth IMO GHG Study. Categories 10, 11 & 12 accounting for over 80% of total Scope 3 emissions are based on 2024 sales. Category 1 is calculated according to procurement expenses and purchases. Category 3 emissions are based on actual electricity & natural gas consumption. Category 4 & 9 are calculated using sea transports data. Category 5 is based on actual waste data. Category 14 is estimated based on a fuel station average electricity consumption and category 15 is based on actual data (approximately 67% were given directly from value chain partners and the rest is based on actual sales). Scope 3 emissions is calculated for the entities whose financial information is included in the consolidated financial statements of the Group. No significant changes have occurred in HELLENiQ ENERGY's activities, structure, or value chain. The methodology of the Scope 3 calculations did not change. Due to the completion of the transfer of 35% of the share capital of DEPA Commercial to the Hellenic Republic Asset Development Fund S.A. (HRADF), this value chain actor was excluded from the calculation.

Total GHG Emissions

GHG Emissions Intensity

Methodology note: The net revenue used for calculation of GHG emissions intensity reconciles with the one mentioned in the financial statements.

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

Financial effects assessment

Based on HELLENiQ ENERGY's current strategic planning, prevailing market expectations, and existing insurance coverage, it is anticipated that no significant adjustments will be required within the forthcoming annual reporting period to the carrying values of assets and liabilities as reported in the associated financial statements.

Assets and business activities at material risk

The assessment of assets and business activities considered to be at material transition risk and material physical risk is part of the process to determine material transition risks as outlined in sections 'Use of Climate-Related Scenario Analysis' and 'Climate-related transition events based on TCFD classification' of ESRS 2.

No assets of HELLENiQ ENERGY are at material physical risk in accordance with the outcomes of the resilience analysis performed as presented in section 'Results of the Resilience Analysis' of ESRS E1.

Climate-related opportunities

For the climate related opportunities that the Group identified, please refer to section 'Climate-related opportunities' in ESRS 2. The relevant table outlines opportunities related with:

• Development and expansion of low emission goods and services in the medium-term time horizon
• Participation in carbon market, including voluntary market and ETS2 in the short-term time horizon

Policies related to pollution

HELLENiQ ENERGY discloses one overarching policy related to pollution management.

Sustainability Policy

Scope and application:

• All Group employees and contractors are responsible for adhering to this policy
• Applies to own operations

Key content and principles:

• Aligns business activities towards the achievement of the United Nations' Sustainable Development Goals and the European Green Deal
• Relates to the management of material impacts, risks and opportunities associated to pollution in own operations
• Prioritizes sustainable management of air, water, and soil, with a focus on prevention and control measures
• Monitors regularly the legislative framework regarding substances of concern and substances of very high concern to assure compliance, minimize use or phase out where applicable in own operations
• Commits to implementing and continuously improving Management Systems for Health and Safety, Environment, and Energy by developing audit, control, and certification procedures
• Aims to minimize incidents that may compromise health, safety, the environment, or society, while ensuring readiness for any emergency situation
• Ensures prompt and effective communication with all stakeholders in the occurrence of safety incident or environmental impact
• Takes into account the interests of key stakeholders when crafting the policy

Governance and oversight:

• The Health, Safety, Environment & Sustainable Development Unit oversees and monitors its implementation
• The highest level of accountability for implementing this policy lies with the Management of the Group and the Sustainability Committee, who have formally approved it

Public availability:

• The Sustainability Policy is accessible via the company's website to stakeholders

Link to international standards:

• Aligns with the United Nations' Sustainable Development Goals
• Aligns with the European Green Deal

Monitoring implementation:

• The Health, Safety, Environment & Sustainable Development Unit monitors implementation
• Air emissions from all industrial facilities are meticulously monitored in accordance with specific terms of environmental permits
• Substantial proportion of industrial facilities equipped with continuous emission monitoring systems
• Data generated by monitoring systems are thoroughly analyzed and submitted to environmental authorities

Actions and resources related to pollution

Monitoring and compliance infrastructure

Air emissions resulting from the operation of all industrial facilities in own operations are meticulously monitored in accordance with the specific terms of the environmental permit issued for each facility, ensuring strict compliance with the statutory emission limits, and substantially contributing to the improvement of air quality.

A substantial proportion of these industrial facilities are equipped with continuous emission monitoring systems. The data generated by these systems are thoroughly analyzed, and the results are subsequently submitted to the environmental authorities for purposes of monitoring and control.

Environmental investments for air quality improvement

The Group's strategy is predicated upon the implementation of environmental investments aimed at improving air quality.

Key actions include:

• Electrostatic precipitator (ESP) filter installation at the Aspropyrgos refinery's catalytic cracking unit stack

  • Scope: Own operations (Aspropyrgos refinery)
  • Implementation status: Fully operational in 2022 and continuing
  • Expected outcome: Contributed significantly in reducing particulate matter emissions of the unit by >80%

• Maximizing the use of fuel gases and using fuels with higher environmental standards

• Investing in modern production technologies (e.g. low nitrogen oxide burners)

• VOC recovery systems during the loading of petroleum products

Implementation status and resources

Currently, the Group has not performed any additional initiatives, as there is no dedicated pollution target in place. The environmental impact achieved so far is deemed particularly positive, as evidenced by the substantial reduction in key air quality indicators in recent years. This is further corroborated by the corresponding decrease in quantitative air quality monitoring data from the surrounding areas.

Value chain coverage

The Group has not yet adopted any actions regarding the air pollution on the downstream value chain.

Accountability

As referenced in the Climate Change Mitigation and Adaptation section, the highest level of accountability for implementing this policy lies with the Management of the Group and the Sustainability Committee, who have formally approved it.

Targets related to pollution

The company has no quantified pollution-related targets in place.

Company approach

The primary objective of the Group is to attain consistent reduction in critical air emission indicators, including emissions of sulfur dioxide (SO2), nitrous oxide (NOx), particulate matter (PMs), and volatile organic compounds (VOCs), across all its business operations.

Given the nature of HELLENiQ ENERGY's operations and the sector, there is no direct operational control over product-related emissions. As a result, there is currently no specific reduction target value in place to address pollution and the Group's approach is to fully comply with the relevant legal and regulatory frameworks, ensuring adherence to all applicable environmental standards.

Only impacts related to prevention and control of air pollutants were considered material.

Legislative compliance approach

The Group adheres rigorously to both national and European legislative frameworks, including:

• Implementation of Best Available Techniques within the petroleum products sector
• Compliance with the European Industrial Emissions Directive
• Certified environmental management systems across all business activities

It should be noted that no pollution-related targets are mandated by legislation.

At the Group's three refineries, the objective is to select the most suitable blend of fuels for internal consumption, implementing relevant best available techniques and stringent adherence to emission limits specified in environmental permits, with the goal to achieve substantial reductions in key air emissions.

Pollution of air, water and soil

HELLENiQ ENERGY reports emissions to air and water for 2024 and 2023. There are no discharges to soil from the Group's industrial facilities.

Emissions to Air

In 2024, the Group's refineries adjusted their fuel mix to emphasize more environmentally friendly fuels.

For the remaining air pollutants listed in Annex II of Regulation (EC) No 166/2006 (E-PRTR), the applicable threshold values are not exceeded. GHG emissions are reported separately in section E1.

Emissions to Water

For the remaining water pollutants listed in Annex II of Regulation (EC) No 166/2006 (E-PRTR), the applicable threshold values are not exceeded.

Emissions to Soil

There are no discharges to soil from the Group's industrial facilities.

Methodology

*Subsidiaries are entities whose financial information is included in the consolidated financial statements. Emissions are based on annual PRTR reports for refineries; no subsidiary falls under the scope of Regulation (EC) No 166/2006. Air emission factors are from the 3/15 CONCAWE report. SOx emissions are calculated based on sulfur percentage in fuel. There are no emissions from persistent organic pollutants (POP). Subsidiary methodology: EKO & KALYPSO: calculation or estimation; OKTA & DIAXON: calculation. Water emissions are based on specific laboratory test methods (APHA 5220D for TOC, ΟΕ-7.0-93 (ICP-MS) for heavy metals, LCK 345 for Phenols, ΟΕ-7.0-69 for Cyanides). No changes in methodology compared to previous years.

Substances of concern and substances of very high concern

The Group regularly monitors the legislative framework regarding substances of concern (SoC) and substances of very high concern (SVHC) to ensure compliance, minimize use, or phase out where applicable in own operations.

REACH Compliance

The Group ensures compliance with the REACH Regulation (EC) No 1907/2006 by utilizing only equipment designed and manufactured in alignment with EU safety and environmental regulations. All equipment used in the Group's transmission systems carries the 'CE' marking, which signifies conformity with applicable directives, including the RoHS Directive and REACH Regulation, which restricts SVHCs.

Polychlorinated Biphenyls (PCBs)

The Group does not use PCBs (polychlorinated biphenyls), which are banned in the EU under Directive 96/59/EC and classified as Substances of Very High Concern (SVHCs) under the REACH Regulation (EC) No 1907/2006. The Group ensures compliance by utilizing only equipment designed and manufactured in alignment with EU safety and environmental regulations. All equipment used in the Group's transmission systems carries the 'CE' marking, which signifies conformity with applicable directives, ensuring that SVHCs like PCBs are not present in any materials or components used in the Group's infrastructure.

Restricted Substances in Electrical and Electronic Equipment

The Group confirms that all equipment used to operate IT/OT data-driven solutions, which are limited to standard office equipment such as laptops and computers, does not contain the restricted substances listed in Annex II to Directive 2011/65/EU (RoHS Directive), except where the concentration values by weight in homogeneous materials do not exceed the maximum values listed in that Annex. All equipment bears the 'CE' marking, signifying conformity with EU safety, health, and environmental standards.

No quantitative data on total amounts of substances of concern or substances of very high concern generated, used, or procured is disclosed.

Anticipated financial effects from pollution-related impacts, risks and opportunities

Expenditures in Reporting Period

No material incidents have transpired during 2024 wherein pollution has adversely impacted the environment and/or is anticipated to detrimentally affect HELLENiQ ENERGY's financial cash flows, financial position, or financial performance across short-term, medium-term, and long-term time horizons.

Policies related to water and marine resources

HELLENiQ ENERGY does not have a dedicated policy specifically for water and marine resources. The company discloses that since no water and marine resources related material IROs (impacts, risks and opportunities) emerged from the double materiality assessment, it was not necessary to adopt dedicated policies for water.

Sustainability Policy

Despite not having a dedicated water policy, the Group implements its Sustainability Policy which addresses water and marine resources matters.

Key content and principles:

• Ensures sustainable use and sourcing of water and marine resources in operations
• Addresses water treatment and prevention of water pollution
• Covers abatement of water pollution from activities in own operations and along upstream and downstream value chain
• Commits to ongoing sustainable management of water resources in operations and across the value chain
• Active identification of high-risk areas with measures to optimize water use efficiency
• Promotion of conservation among suppliers and stakeholders
• Implementation of control and monitoring mechanisms to prevent and mitigate water pollution

Scope:

• Company's own operations
• Upstream and downstream value chain

Governance:

• Ultimate accountability for implementation rests with the management of the group and the Sustainability Committee
• Both the management and Sustainability Committee have formally endorsed the policy

Public availability:

• The policy is readily accessible via the company's website to relevant stakeholders, including those impacted by its provisions and those responsible for its execution

Stakeholder consideration:

• The Group has carefully considered the interests of key stakeholders in developing this policy

Monitoring:

• Not explicitly disclosed in the excerpts provided

Actions and Resources Related to Water and Marine Resources

HELLENiQ ENERGY is committed to ensuring ongoing sustainable management of water resources, while constantly seeking new solutions and best practices in water use management.

Overview of Actions

To ensure sustainable water management, the Group aims to:

• Reduce the amount of water used in its operations
• Reuse and recycle water as much as possible
• Dispose of water responsibly after treatment at its facilities to minimize impact

Specific Actions

Modern Wastewater Treatment Plants

Scope: Midstream value chain (own operations) - refineries

Description: Three-stage integrated wastewater treatment plants at the Group's refineries ensure continuous protection of water bodies through continuous improvement in wastewater management performance.

Link to commitment: Directly addresses the commitment to sustainable water management as dictated by the Sustainability Policy. These advanced treatment facilities help ensure that water used in operations is effectively treated and reused where possible, minimizing environmental impact and promoting conservation.

Upgrading the Wastewater Treatment Plant of the Aspropyrgos Refinery

Time horizon: Expected to be fully operated in 2025

Description: Project progressed according to the relevant plan. The initiative demonstrates the Group's dedication to preserving water resources, reducing pollution, and maintaining sustainable practices across its value chain.

Water-saving Initiatives

Scope: All business activities and geographic areas in Greece and abroad

Geographic coverage: Includes areas identified by the World Resources Institute as areas with increased water stress, water shortage, and/or poor water quality. Also in accordance with the River Basin Management Plans of the Ministry of the Environment and Energy. 98% of total water consumed occurs in HELLENiQ ENERGY facilities located in Greece, which is characterized as one of the water stress areas according to WRI assessment.

Description: Actions are continuously implemented and include:

• Monitoring water consumption directly using flow meters across the Group's activities
• Identifying opportunities to reduce consumption
• Investing in water saving systems so that the Group's production facilities and cleaning processes become as efficient as possible

Water Resource Management System

Scope: All facilities and subsidiaries of the Group

Description: The system includes monitoring and reporting of:

• Water withdrawal
• Quality
• Discharge

Expected outcomes: To continuously improve efficiency and reduce not only the environmental footprint, but also operating costs.

Performance Assessment

Issues assessed in the field of water management relate directly to:

• Water used (quality measurements, use of different types of water, e.g. seawater for cooling, treatment technologies, etc.)
• Broader management parameters (availability, quality and ecosystems affected by discharge)

Purpose: To identify all areas for improvement.

Resources Allocated

No specific financial resources (capex/opex amounts) or non-financial resources (people, partnerships) were quantified in the disclosure.

Water consumption

Total Water Consumption

Water Recycled & Reused

Notes on consumption changes: In 2024, there was an increase in water consumption amounted to 23% compared to water consumption in 2023, mainly due to increased fresh water consumption for fire protection in Aspropyrgos refinery, while the water recycled and reused in production facilities amounted to 17%. It is noted that subsidiaries' water consumption 2024 is not comparable to 2023, mainly because a) two companies are added in EKO CYPRUS and b) OKTA updated its methodology (including additional water uses).

Water Withdrawals and Discharges

• Total water withdrawals: 15,698,162 m³, from which 84% comes from public supply network
• Total water discharges: 7,229,408 m³, from which over 96% is discharged in the sea after treatment

Water Consumption in Areas of Water Stress

98% of the total water consumed occurs in HELLENiQ ENERGY facilities located in Greece, which is characterized as one of the water stress areas according to WRI assessment.

Methodology

Water consumption and withdrawal data were obtained from direct measurements (flow meters, invoices). The majority of water discharges data (refineries and domestic marketing) come from direct measurements (flow meters). The data regarding water recycling and reuse derived either directly from flow meters, by calculation or estimation (e.g. for AIC the recycled water is used in the desalination unit of the distillation plant. It is also estimated that 10% of the water from the wastewater unit is used for internal operations – cleaning, hydraulic testing, etc.).

Policies related to biodiversity and ecosystems

Sustainability Policy

HELLENiQ ENERGY does not disclose a standalone biodiversity and ecosystems policy. Instead, the company states that in accordance with its Sustainability Policy, it prioritizes the protection of biodiversity and ecosystems.

Scope and approach:

• Before commencing any project, the Group conducts a comprehensive assessment of occupational risks and environmental obligations regarding biodiversity aspects
• Safety and environmental specialists/partners are engaged
• Exclusively trained personnel are responsible for ensuring continuous monitoring of compliance with safety, biodiversity, and environmental procedures

Cross-references: The company refers to related policies for more details:

• E1-2 - Policies Related to Climate Change Mitigation and Adaptation
• E2-1 - Policies Related to Pollution
• E3-1 - Policies Related to Water and Marine Resources
• Double Materiality Methodology per Topical Standard

Key practices and commitments:

• In the Renewable Energy Sources (RES) sector, the Group follows the established regulatory framework, including:

  • Conducting environmental impact assessments for RES projects
  • Monitoring operational phases
  • Implementing targeted measures for the protection, preservation, and restoration of wildlife and ecosystems
  • Compliance with Environmental Impact Studies and environmental licenses
  • Alignment with the Special Spatial-Planning Framework for RES
  • Adherence to Law 4014/2011 and Law 3937/2011 on biodiversity conservation
  • Compliance with special Ministerial Decisions on protection measures in Special Protection Areas

• The Group takes into account marine ecosystems and pays particular attention to the protection of marine species, fully complying with:

  • Requirements of the ACCOBAMS treaty
  • Guidelines of the Joint Nature Conservation Committee (JNCC) for the protection of cetaceans

• Environmental monitoring and recording of critical environmental indicators of biodiversity, including marine mammals (cetaceans and seals), sea turtles, and seabirds

Public availability: Not disclosed.

Governance: Not disclosed.

Monitoring:

• Safety and environmental specialists/partners ensure continuous monitoring of compliance with safety, biodiversity, and environmental procedures
• Annual reporting to the Ministry of the Environment and Energy regarding protected species in Special Protection Areas

Note: The company has not disclosed specific sustainable land/agriculture practices or policies, sustainable oceans/seas practices or policies, or policies to address deforestation (as indicated in the voluntary disclosure table on page 163).

Actions and resources related to biodiversity

Renewable Energy Sector Actions

Scope: Own operations (RES facilities)

Time horizon: Continuous process with short-, medium-, and long-term measures

HELLENiQ ENERGY follows the established regulatory framework for biodiversity protection in its Renewable Energy Sources (RES) sector, including:

• Conducting environmental impact assessments for RES projects
• Monitoring operational phases
• Implementing targeted measures for protection, preservation, and restoration of wildlife and ecosystems
• Complying with Environmental Impact Studies and securing environmental licenses
• Aligning with Special Spatial-Planning Framework for RES
• Adhering to Law 4014/2011 and Law 3937/2011 on biodiversity conservation
• Following special Ministerial Decisions on protection measures in Special Protection Areas
• Site restoration measures upon completion of construction/installation activities

Current operations: The Group operates 68 photovoltaic and wind plants, several located within or near biodiversity-sensitive areas including:

• Special Protection Area (SPA) for Poultry (Natura 2000 Network)
• Agios Nikolaos Wildlife Sanctuary
• Wildlife Refuges 'Dovra-Valta', 'K753 Pylaia - Kavissou – Feron'
• Important Bird Area (IBA) 'Southern Evros Forest Complex' (Natura 2000)

Expected outcomes: Annual monitoring and reporting to Ministry of the Environment and Energy on endangered bird species populations in SPA areas.

Marine Ecosystem Protection

Scope: Own operations (HELLENiQ UPSTREAM and subsidiaries)

Actions:

• Full compliance with ACCOBAMS treaty requirements
• Following Joint Nature Conservation Committee (JNCC) guidelines for cetacean protection
• Commissioned specialized company to conduct "Status Survey of Important Fauna Species"

Survey components:

• Systematic monitoring of Mediterranean seals at breeding sites using inflatable boats with infrared cameras
• Visual and acoustic surveys of marine mammals, sea turtles, and seabirds from floating and aerial means
• Coastal surveys focusing on breeding areas of Mediterranean seal and European shag in adjacent Natura 2000 sites
• Telemetry studies of sea turtles (Caretta caretta) and seabirds (Scopoli's shearwater/Artemis)

Expected outcome: Represents one of the most comprehensive and integrated surveys for systematic recording of marine mammals, sea turtles, and seabirds conducted in Greece.

Photovoltaic Plant Design Measures

Scope: Own operations (PV facilities)

Actions:

• Fence design with 10-15 cm ground clearance to allow small animal movement
• Allocation of 25% of total area (0.4 km²) for pasture use by local livestock breeders in cooperation with local forestry

Expected outcome: Maintain ecological unity of area and enable coexistence with local agricultural activities.

Mitigation Hierarchy Application

Scope: All relevant sites in Greece and abroad

Time horizon: Continuous process with short-, medium-, and long-term measures

Approach:

• Avoiding impacts on biodiversity-sensitive areas when possible through careful site selection based on ecological considerations
• Minimizing negative impacts when avoidance is not feasible

Future consideration: Nature-based solutions incorporating local and indigenous knowledge (currently not implemented).

Resources Allocated

Non-financial resources:

• Specialized company commissioned for marine fauna status survey
• Field researchers equipped with infrared cameras for seal monitoring
• Cooperation with local forestry authorities
• Annual reporting to Ministry of the Environment and Energy

Financial resources: Not quantified in disclosure.

Link to Policies

All actions align with the company's Sustainability Policy and are referenced in sections 'E1-2 - Policies Related to Climate Change Mitigation and Adaptation,' 'E2-1 - Policies Related to Pollution,' 'E3-1 - Policies Related to Water and Marine Resources', and 'E4-2 - Policies Related to Biodiversity and Ecosystems'.

Impact metrics related to biodiversity and ecosystems change

Operations in or near biodiversity-sensitive areas

HELLENiQ ENERGY operates a total of 68 photovoltaic and wind plants, some of which are located within or near biodiversity-sensitive areas:

Operational sites:

• Wind farms located within the boundaries of the Special Protection Area (SPA) for Poultry (Natura 2000 network), which provides habitat for two endangered bird species
• Sites within the Agios Nikolaos Wildlife Sanctuary

Projects under development:

• Projects within or close to forest lands
• Projects within Wildlife Refuge 'Dovra-Valta'
• Projects within Wildlife Refuge 'K753 Pylaia - Kavissou – Feron'
• Projects within the Important Bird Area (IBA) 'Southern Evros Forest Complex' of the Natura 2000 Network
• PV projects with land plots attached to protected zones within the Natura 2000 network, including areas around Lake Pikrolimni, Xilokeratea, and Anthofyto (the latter two are also designated as IBA and Key Biodiversity Areas)
• PV plants in Cyprus located in areas coinciding with the habitat of three vulnerable species identified in 'The Red Data Book of Flora of Cyprus'

Species impact metrics

Endangered species monitoring (SPA):

• First species: presence and breeding activity within the SPA has not yet been documented
• Second species: number of pairs is higher than the 8 breeding pairs set as a conservation target

Red List species:

• Three vulnerable plant species (Cyprus PV plants) listed in 'The Red Data Book of Flora of Cyprus'

Land use footprint

Restoration and pasture allocation:

• 0.4 km² total area at one facility, with 25% of this area (previously unused) allocated for use as pasture to local livestock breeders

Mitigation measures implemented

• All wind turbines equipped with bird avoidance and bird collision preventive mechanisms
• Regular inspection of wind farms and removal of dead animals to avoid attracting scavenger animals
• All Kozani PV plants: fences designed with 10-15 cm distance from ground, allowing small animals to move freely
• Compliance with ACCOBAMS treaty and JNCC guidelines for protection of cetaceans
• Appropriate assessments conducted in accordance with Directives 2009/147/EC and 92/43/EEC
• Environmental Impact Assessments completed for all renewable energy projects requiring EIA under Directive 2011/92/EU

Marine biodiversity monitoring

HELLENiQ UPSTREAM commissioned a comprehensive "Status Survey of Important Fauna Species" including:

• Systematic monitoring of Mediterranean seals at breeding sites using infrared cameras
• Surveys of marine mammals, sea turtles, and seabirds by visual and acoustic methods
• Coastal surveys focusing on breeding areas of Mediterranean seal and European shag (Phalacrocorax Aristotelis)
• Telemetry studies involving sea turtles (Caretta caretta) and seabirds (Scopoli's shearwater/Artemis)

Note: The company states no material actual and potential impacts on biodiversity and ecosystems at own site locations and in value chain have been identified. Nature-based solutions have not been implemented but are being considered for the future.

Policies related to resource use and circular economy

Sustainability Policy

HELLENiQ ENERGY's Sustainability Policy reflects a strong commitment to integrating circular economy principles into its operations.

Key content and principles:

• Focuses on lowering environmental impact while ensuring compliance with legal and regulatory requirements
• Emphasizes preventing and reducing emissions and waste across the value chain
• Optimizes the use of energy and natural resources
• Reinforces circular economy practices to create long-term value for operations and society
• Adoption of measurable targets which are regularly benchmarked and reported in agreement with best practices, ensuring continuous improvement in circular economy and sustainable waste management
• Mandates engagement with all stakeholders to create long-term value for the Group and society

Cross-references: The policy is also referenced in sections 'E1-2 - Policies Related to Climate Change Mitigation and Adaptation,' 'E2-1 - Policies Related to Pollution,' 'E4-2 - Policies Related to Biodiversity and Ecosystems' and 'Double Materiality Methodology per Topical Standard'.

Implementation approach:

• The Group implements sustainability best practices in procurement and marketing procedures throughout the value chain for the provision of safe, sustainable and accessible energy products
• Constantly examining ways to reduce the use of virgin resources and raw materials
• Prioritizes the use of recycled materials to contribute to circular flow of resources, minimizing waste and maximizing resource efficiency
• Dedicated to sustainable sourcing practices, ensuring materials are responsibly procured throughout the value chain
• This approach supports environmental sustainability and aligns with social governance principles

Actions and resources related to circular economy

Sustainable Waste Management

The utilization of materials and natural resources throughout their life cycle constitutes an important business opportunity and reflects the Group's commitment to environmental protection.

HELLENiQ ENERGY's strategic approach is based not only on the reduction of solid waste to landfill through investments in modern waste treatment plants, but also on the creation of synergies for the utilization of waste for energy recovery and the exploration of alternative technologies for its use as raw materials, aiming at the substitution of mineral raw materials.

It is emphasized that the continuous reduction of the quantity of waste for final disposal significantly contributes not only to minimizing the negative impact on the environment and human health but also to reducing the operating costs of business activities.

Scope: Own operations

Approach:

• Petroleum by-products of the refinery processes are classified as waste (self-produced or third-party) at stage of their life cycle, and they constitute a significant opportunity to be used as raw materials in the Group's production facilities, but also as fuels, as per the principles of a circular economy.
• Investments in modern waste treatment plants
• Creation of synergies for the utilization of waste for energy recovery
• Exploration of alternative technologies for waste use as raw materials, aiming at the substitution of mineral raw materials

Outcomes (2024):

• 22% increase in the amount of waste generated compared to the previous year
• More than 26,898 tons of waste (more than 88% of the total) was either reused, recycled, or further recovered through a raw material recovery process
• Hazardous waste constitutes the majority of the total waste generated and almost all of it is recovered and not sent for final disposal

Municipal Solid Waste (MSW) Management

The Group continues its unremitting efforts across all activities (facilities and offices), with the active participation of employees, to recycle as many waste streams as possible, such as paper, plastic, small batteries, accumulators, fluorescent lamps, electronic equipment, aluminium, etc.

Scope: Own operations (facilities and offices)

Implementation:

• Integrated Municipal Solid Waste (MSW) management system at the Aspropyrgos and Elefsina Industrial Facilities (continued in 2024)
• Source separation of all streams: metal, plastic, batteries, paper, food waste, and common waste
• Use of "paperless" processes, such as electronic signatures, resulting in reduction in hardcopy documents and envelopes

Outcomes:

• Increased recycling rate through effective source separation
• Reduction of environmental footprint through paperless processes

Recovered Raw Material

For the refining sector, the percentage of petroleum waste recovered (oil recovered & slops) and returned to the production process as raw material for re-refining is monitored. These quantities of waste originate from both the production process and third parties.

Scope: Own operations (refining sector) and upstream (third-party waste)

Outcomes (2024):

• 175.3 kt of oil were recovered
• More than 2.02 million tons have been re-refined since 2013

Link to targets: Supports the Group's goal to maintain the percentage of waste sent to disposal (landfill/incineration) at 15% or less by 2030.

Resources Allocated

No specific financial resources (capex/opex amounts) are quantified in the disclosure. Non-financial resources include:

• Active participation of employees in recycling efforts
• Implementation of integrated waste management systems
• Investments in modern waste treatment plants (amount not specified)

Targets related to circular economy

Waste sent to disposal target

Target metric: Percentage of waste sent to disposal (landfill/incineration)

Target value: ≤15%

Target year: 2030

Baseline year and value: Not disclosed

Scope: Group operations (not mandated by legislation, voluntary commitment)

Type: Not specified (absolute/intensity)

Validation: Internal target (not science-based or externally validated)

Progress to date: Not disclosed in quantitative terms for the specific target metric

Additional context:

• The Group's goal is to maintain the percentage of waste sent to disposal (landfill/incineration) at 15% or less by 2030
• This target is not mandated by legislation, highlighting the Group's proactive commitment to sustainability
• The target was established through a structured process incorporating relevant IROs from the DMA and other business objectives
• The Sustainability Committee tracks progress with Board of Directors oversight
• In 2024, HELLENiQ ENERGY continued efforts to reduce waste production and maximize recycling

E5-4 - Resource Inflows

Resource Inflows Description

The main resource inflows are crude oil and other hydrocarbon feed processed which are over 85% of total material/resource used in Group level and of non-renewable origin. For year 2024, the amount of crude oil is 15,077 ktn and throughput is 18,595 ktn of the Group three refineries (HELLENIC PETROLEUM R.S.S.O.P.P. S.A.).

Significant Changes, Assumptions and Methodologies

The data included in the calculations is sourced from direct measurements and the Group ensured double counting was avoided.

Waste

Waste Management Approach

The utilization of materials and natural resources throughout their life cycle constitutes an important business opportunity and reflects the Group's commitment to environmental protection. HELLENiQ ENERGY's strategic approach is based not only on the reduction of solid waste to landfill through investments in modern waste treatment plants, but also on the creation of synergies for the utilization of waste for energy recovery and the exploration of alternative technologies for its use as raw materials, aiming at the substitution of mineral raw materials.

The continuous reduction of the quantity of waste for final disposal significantly contributes not only to minimizing the negative impact on the environment and human health but also to reducing the operating costs of business activities. Petroleum by-products of the refinery processes are classified as waste at stage of their life cycle, and they constitute a significant opportunity to be used as raw materials in the Group's production facilities, but also as fuels, as per the principles of a circular economy.

In 2024, there was an increase by 22% in the amount of waste generated compared to the previous year, which was accompanied by a high recovery rate as a result of the adoption of improved recycling and recovery practices at the Group's facilities. Specifically, more than 26,898 tons of waste, more than 88% of the total, was either reused, recycled, or further recovered through a raw material recovery process.

Waste Data (2024)

Waste Diverted from Disposal (by method)

Waste Directed to Disposal (by method)

Methodology Notes

*Subsidiaries are entities whose financial information is included in the consolidated financial statements of the Group.

Classification by category according to the European Waste List referred to in Commission Decision 2014/955/EU. The first level of the European Waste Catalogue classification has been used. The data is sourced from direct measurements, and no assumptions have been used.

The materials that are present in the waste are mainly catalysts, metals, oily sludges & oily waste. The total amount of hazardous waste is 17,360 (t) and radioactive waste generated by HELLENIQ ENERGY is 0.00 (t).

It is noted that hazardous waste constitutes the majority of the total waste generated and almost all of it is recovered and not sent for final disposal. The quantities of solid waste per industrial facility depend, for the most part, on the cleaning of product tanks and, therefore, vary from year to year, depending on tank maintenance scheduling and, secondarily, on the availability of solid waste treatment plants, either on-site or off-site.

Recovered Raw Material

For the refining sector in particular, the percentage of petroleum waste recovered (oil recovered & slops) and returned to the production process as raw material for re-refining is also monitored. These quantities of waste originate from both the production process and third parties. It is noteworthy that in 2024 175.3 kt of oil were recovered while more than 2.02 million tons have been re-refined and since 2013.

Target

The Group's goal is to maintain the percentage of waste sent to disposal (landfill/incineration) 15% or less by 2030.

Policies related to own workforce

HELLENiQ ENERGY has established and implements several policies governing its own workforce, demonstrating commitment to ethical conduct, health and safety, human rights, and employee well-being.

Group Code of Conduct

Policy name: Group Code of Conduct

Approval and oversight:

• Approved by the Company's Board of Directors since 2011
• The Compliance Department is responsible for ensuring proper and effective implementation
• The Board of Directors oversees implementation and ensures human rights principles are integral to the Group's culture

Scope:

• Applies to every individual, employee or third party involved in the operation of the Group
• Applies to all Group activities in Greece and abroad
• Translated into all languages spoken in the countries where the Group operates, in addition to English
• Covers all collective bodies of the Group

Key content/principles:

• Summarizes principles according to which every individual should act within the framework of their duties
• Constitutes a practical guide for day-to-day tasks of all employees and third parties cooperating with the Group
• Covers human rights, corruption and bribery, competition, environmental stewardship, and social responsibility
• Includes specific section on respect for colleagues and third parties and harassment in the workplace
• The Group is strongly committed to: ensuring health and safety; equal opportunities policy and meritocracy; stable working environment; performance-based career and professional development; provision of incentives and competitive pay and benefits; continuous training for knowledge and skills development; work-life balance

Public availability:

• Posted on the Company's website
• Accessible to employees via intranet
• Revised version expected to be applied in 2025

Links to international standards:

• Group is signatory to the United Nations Global Compact (UNGC) since 2008, incorporating its Ten Principles covering human rights, labor rights, environment, and anti-corruption
• Aligned with UN Guiding Principles on Business and Human Rights
• Complies with relevant labor legislation (national, European, ILO) covering human rights and working conditions
• Aligned with Greek Sustainability Code
• Follows ILO Declaration on Fundamental Principles and Rights at Work
• Follows OECD Guidelines for Multinational Enterprises

Monitoring implementation:

• Continuous and extensive education and training of executives and employees on the Code's content, basic principles, and commitments
• Training is part of onboarding process for new recruits
• Mandatory e-learning modules provided to all employees
• All employees (100%) have been informed about anti-corruption policies and procedures through the Code
• Annual training on Code of Conduct provided to all employees
• The Compliance Department investigates reports or complaints about incidents of Code violations
• Regular audits conducted; in 2024, 100% of organizational units were screened for corruption-related risks

Sustainability Policy

Policy name: Sustainability Policy (also referred to as Group Sustainability Policy)

Approval and oversight:

• Ultimate accountability for policy implementation rests with the Management of the Group and the Sustainability Committee

Scope:

• Applies to all activities of HELLENiQ ENERGY and its subsidiaries, including upstream and downstream value chain activities
• Covers all employees and external partners providing services to the Group's facilities
• Encompasses all departments and operations
• Covers all stakeholders, including employees, contractors, suppliers, and local communities
• No specified exclusions

Key content/principles:

• Addresses sustainable energy for all and climate neutrality
• Adoption of corporate governance principles ensuring safe and accident-free, financially sustainable operation while respecting Environment and Society
• Commitment to promote human rights and respect diversity and equality of individuals, eliminating all forms of discrimination
• Commitment to limit incidents that may compromise Health, Safety, Environment and Society
• All employees, executives, members of management and every person providing services to the Group have responsibility to comply with the Policy and maintain Health, Safety, Environment and Sustainability requirements

Public availability:

• Posted on the Group's website
• Accessible via intranet

Links to international standards:

• Adheres to United Nations' Sustainable Development Goals
• Aligned with European Green Deal
• Aligned with other relevant environmental and social frameworks
• Aligned with UN Global Compact principles
• Aligned with Greek Sustainability Code

Monitoring implementation:

• Takes into account interests of key stakeholders
• Shared with external stakeholders, including suppliers and partners, to ensure alignment
• Made available to all those who need to be informed or involved in its implementation

Health and Safety Management System

Policy name: Health and Safety Management System (also referenced as Occupational Health and Safety Management System)

Approval and oversight:

• Management of the Group oversees implementation

Scope:

• Concerns all employees and external partners providing services to the Group's facilities
• Applies to all facilities
• 100% of people in own workforce are covered by health and safety management system

Key content/principles:

• Health and safety of personnel is fundamental value, primary concern, and condition for conducting Group's activities
• Compliant with relevant Greek and European legislation
• Compliant with internationally recognized Codes and practices, often stricter than legal requirements
• Applies the Preventive Principle to identify, assess, and contain all potential risks to Health and Safety
• Provides all necessary Personal Protective Equipment (PPE)
• Conducts emergency preparation drills
• Provides regular Health and Safety training to all workforce
• Monitors health of personnel based on relevant procedure
• Primary objective: "zero major industrial accidents" with no adverse impact on people and environment

Links to international standards:

• Based on legal requirements and/or recognized standards or guidelines
• Group cooperates with European organization CONCAWE and participates in annual survey and benchmarking of Health and Safety performance

Monitoring implementation:

• Periodic medical examinations for employees based on job position, age group, and gender under Health Supervision Procedure
• Emergency preparedness drills performed periodically or case-by-case basis
• In 2024, 69,003 man-hours of training provided on Health and Safety issues for employees and contractors
• Safety reviews of H&S systems across facilities in Greece initiated in 2024, expected completion in 2025
• Evaluation conducted at end of each drill for continuous improvement
• Annual benchmarking with CONCAWE to track effectiveness

Policy against Violence and Harassment (Anti-Harassment Policy)

Policy name: Policy against Violence and Harassment (also referred to as Combating Violence and Harassment Policy or Anti-Harassment Policy)

Approval and oversight:

• Put into effect at Group's companies
• Implementation overseen by Group Human Resources Division and Administrative Services Division

Scope:

• Applies to all Group companies
• Established in 2022
• Covers all employees and third parties doing business with the Group

Key content/principles:

• Provides guidelines for preventing and addressing workplace violence and harassment
• Provides clear procedures for reporting, investigating, and resolving incidents of violence and harassment
• Ensures employees have access to dedicated mechanism for these matters
• Zero tolerance for sexual harassment or any other kind of harassment
• Harassment related to race, religion or other characteristics not tolerated
• Violations may lead to criminal or civil liability or termination of employment relationship
• Reports handled in confidence, objectivity and great sensitivity
• Dedicated reporting channel for Violent & Harassment Issues
• Respects human dignity and personality
• Promotes equality and eliminates discrimination, including harassment

Public availability:

• Outlined in Internal Labor Regulation

Links to international standards:

• According to provisions of Law 4808/2021, which ratifies Convention 190 of the International Labor Organization on eliminating violence and harassment in the world of work

Monitoring implementation:

• Group's management investigates any complaint immediately and in depth
• Takes all necessary measures to hold responsible person accountable and protect person harassed
• Ongoing commitment ensured through continuous communication of Policy's commitments
• Compliance of employees overseen by Group's Human Resources and Administrative Services Division
• Annual training on Code of Conduct for all employees includes specific section on respect and harassment

Whistleblowing Policy (Policy for the protection of persons who report breaches of Union law)

Policy name: Policy for the protection of persons who report breaches of Union law (Whistleblowing Policy / Group Whistleblowing Policy)

Approval and oversight:

• Approved by Group's Board of Directors in April 2024
• Impartial person or department commissioned for following up on reports

Scope:

• Applies to all Group companies and employees in Greece
• Applies to employees, executives, and external partners
• Group's companies in North Macedonia, Serbia and Bulgaria have approved their own Whistleblowing Policies in accordance with respective local laws
• Group's companies in Montenegro and Cyprus have whistleblowing reporting and protection procedures

Key content/principles:

• Establishes secure procedures for reporting concerns about violations of EU law
• Enables correct investigation and management of reports
• Ensures confidentiality and protection against retaliation
• Provides remedies for any retaliatory actions
• Covers violations of competition laws
• Applies to bribery, corruption and money laundering concerns
• Dedicated Whistleblowing platform on HELLENiQ ENERGY Group website (available in Greek and English) enables secure and anonymous reporting

Public availability:

• Whistleblowing platform available on HELLENiQ ENERGY Group website in Greek and English

Links to international standards:

• Fully aligned with requirements of Law 4990/2022
• Implements EU Whistleblowing Directive (EU) 2019/1937

Monitoring implementation:

• Reports handled with strict confidentiality
• Proper follow-up and investigation ensured
• Platform allows both employees and external stakeholders to raise concerns

Data Protection Policies and Privacy Notices

Policy name: Data Protection Policies and Privacy Notices (comprehensive system)

Approval and oversight:

• Personal Data Protection Office (PDPO) established with Data Protection Officer (DPO) at Group level and in specific subsidiaries
• DPO administratively reports to Chief Executive Officer and functionally to Board of Directors

Scope:

• Covers all cases of data processing
• Applies to employees, customers, and other stakeholders
• All policies for protection of Personal Data in final stage of revision and updating (as of 2024)

Key content/principles:

• Safeguards privacy and personal data
• Recognizes privacy as fundamental human right
• Implements strict data security measures
• Protects personal data from unauthorized access, misuse, or breach
• Recently launched dedicated Cyber Security Office to enhance communication on cybersecurity issues and ensure proactive protection

Links to international standards:

• Ensures full compliance with General Data Protection Regulation (GDPR)
• Compliance with Personal Data Protection Regulation
• Compliance with NIS2 Directive (L. 5160/2024)

Monitoring implementation:

• PDPO has drawn up appropriate policies and procedures for effective protection of privacy
• PDPO ensures implementation and provision of support in matters of personal data protection
• Chief Information Security Officer (CISO) appointed, reports to Audit Committee quarterly
• Responsible for managing Information Security Framework
• Comprehensive monitoring and control framework for information systems
• Multiple annual audits conducted by both internal and external parties

Remuneration Policy

Policy name: Remuneration Policy for the members of the Board of Directors (also referenced as Remuneration Policy for Executives)

Approval and oversight:

• Approved by resolution of Extraordinary General Meeting of Shareholders on 20 December 2019
• Amended by resolution of Ordinary General Meeting of Shareholders on 30 June 2021
• Overseen by Remuneration and Succession Planning Committee

Scope:

• Applies to members of Board of Directors
• Applies to executives

Key content/principles:

• Aligned with business strategy, goals, and sustainability
• Outlines framework for total annual gross remuneration
• Allocates between fixed and variable components
• Links individual performance and executive contribution to achieving Group's objectives to variable remuneration
• Sets predefined measurable quantitative and qualitative targets and criteria
• Ensures transparency and meritocracy
• No gender-based differentiation in remuneration system
• Upholds principle of equality with no discrimination or financial disparity
• Remuneration based on annual evaluations and follows Greek, national and EU legislation on equal pay

Monitoring implementation:

• Proper implementation monitored as part of Corporate Governance System assessment
• Operation of Remuneration and Succession Planning Committee reviewed for compliance with Law 4706/2020

Additional Policies and Procedures

The Group also maintains:

Recruitment Policy:

• States no employees under age of 18 can be employed
• Minimum age limit of 18 years established as recruitment precondition according to Internal Operation Regulations

Personnel Selection and Performance Evaluation System:

• Ensures decisions on hiring, evolution, and termination based exclusively on merit, qualifications and performance
• Accomplishes better performance by creating incentives, identifying training needs and creating working environment without discriminations

Internal Labor Regulation:

• All employees (100%) informed about Group's anti-corruption policies and procedures through this Regulation
• Contains provisions of Anti-Harassment Policy

Procurement Regulations:

• Establishes framework for selecting and evaluating suppliers
• Designed to identify risks, including compliance issues, and prevent adverse impacts across supply chain
• Ensures suppliers at high risk of human rights violations are excluded
• Suppliers assessed against four key pillars, including Environmental & Social Framework Pillar covering human rights, labor issues, health and safety, conflict minerals, and unethical practices
• All supplier contracts and purchase orders include "term of compliance" with UNGC principles
• Sustainability criteria grounded in UNGC principles and Greek Sustainability Code

Competition Policy and Compliance Manual:

• Revised in September 2023
• Incorporates recent changes in legislation and latest guidelines from Competition Commission
• Reinforces dedication to adhering to competition laws
• Supports sustainable development and enhances overall competitiveness
• Mitigates risk of severe sanctions and reputational damage from violations
• Fair competition is dedicated section in Code of Conduct
• All employees including senior management receive training on fair competition principles

Tax Strategy:

• Comprehensive tax strategy applies to all entities within Group
• UK Tax Strategy published and updated annually (2024 version in place)
• Tax and customs issues centrally monitored, audited, and coordinated by Group Tax & Customs Department
• Ensures compliance with tax legislation and audit requirements in Greece and all countries where Group operates

Taking action on material impacts on own workforce

HELLENiQ ENERGY implements various training methods and procedures to address material impacts, risks and opportunities related to its own workforce, with health and safety as a top priority.

Health & Safety Training Programs

Scope: Own operations, extended to contractors, customers, transporters, and service stations

Description:

• Common basic training process covering fire safety, rescue techniques, first aid, etc.
• Leadership seminars at all levels of the hierarchy
• Mandatory training by Safety Engineers for external partner employees, followed by written examinations at accredited training centers (KEK)
• Guests informed through printed and audiovisual material about safety instructions
• Training volume (2024): 69,003 man-hours of Health and Safety training provided for employees and contractors

Time horizon: Ongoing; Safety reviews initiated in 2024, expected completion in 2025

Expected outcomes:

• Strengthening and embedding safety culture across all Group facilities
• Evaluate improvements in health and safety systems and employees' safety culture
• Achievement of "zero major industrial accidents" with no adverse impact on people and the environment

Link to policy/targets: Aligns with Sustainability Policy, Health and Safety Management System, and target of zero major industrial accidents

Emergency Preparedness Drills

Scope: Own operations (industrial facilities and KALYPSO fuel stations)

Description:

• Periodic drills performed at all Group's industrial facilities and fuel stations
• Evaluation of contingency strategies and response times conducted after each drill
• Mandatory participation

Frequency:

• At least one drill per year in all Group facilities
• Health & Safety training more frequent at refineries or retail facilities (at least 1 per month)

Expected outcomes:

• Ensure smooth and safe operations
• Safeguard health and safety of employees, partners, and local communities
• Continuous improvement of operational preparedness for emergencies

Health Supervision Procedure

Scope: Own workforce

Description:

• Periodic medical examinations based on job position, age group, and gender
• Occupational Physicians employed to offer services to employees and partners whenever and wherever needed

Expected outcomes:

• Provide for the health of employees as a key element of strategy
• Prevention of workplace accidents and illnesses

Link to policy/targets: Key element of HELLENiQ ENERGY's strategy and Health Monitoring Procedure

CONCAWE Benchmarking

Scope: Own operations

Description:

• Cooperation with European organization CONCAWE
• Participation in annual survey and benchmarking of Health and Safety performance

Expected outcomes:

• Track the effectiveness of the Group's actions and initiatives
• Comparison with European sector best practices

Holistic Safety Management System

Scope: Own operations (initially implemented in industrial facilities, extended to all operations)

Description:

• Comprehensive system providing rapid/immediate information, effective prevention, and timely response to hazards
• Regular inspections, audits, and risk assessments
• Comprehensive Occupational Risk Assessment Studies at all Group operations
• Investigation and formulation of targeted action plans for identified risks

Expected outcomes:

• Protection of employees, partners, and local communities
• Protection of processes
• Cultivation of a culture of safety and well-being
• Prevention of workplace accidents
• Minimize frequency and duration of operational disruptions
• Enhance workforce productivity

Link to targets: 100% Implementation Rate of the Holistic Safety Management System in all Group facilities, both in Greece and abroad by 2030

Safety Culture and Incident Reporting

Scope: Own workforce and partners

Description:

• "Safety is Everyone's Business" approach
• Open and trustworthy learning environment
• Active commitment from Management and employees
• Reporting and investigation of incidents, near misses and unsafe situations strongly encouraged
• Staff contributions to Health and Safety risk management recognized and rewarded
• Immediate protective measures and corrective actions implemented to prevent future incidents

Expected outcomes:

• Development of a Health and Safety Culture
• Long-term benefits of the Occupational Health and Safety Management System

Occupational Risk Management

Scope: Own operations

Description:

• Application of the Preventive Principle to identify, assess, and contain all potential risks to Health and Safety
• Continuous monitoring and evaluation of workplace conditions
• Regular inspections, incident investigations, and focused training initiatives
• Regular site audits to identify risks such as unsafe work practices or malfunctioning machinery
• Alignment with Greek legislation, European and international regulations and best practices

Expected outcomes:

• Identify, analyze, and effectively address risks (e.g., strained relationships with key stakeholders or disputes)
• Enable informed decisions ensuring preservation and continuous improvement of working conditions
• Maintain high standards of operational excellence while protecting employee health

Safety Improvement Projects

Scope: All facilities, both in Greece and internationally

Resources allocated (2024): €22.4 million

Description:

• Enhancing workplace safety
• Maintenance and procurement of safety tools and equipment
• Essential firefighting materials and other consumables

Expected outcomes:

• Demonstrate holistic approach to safeguarding employees and operations
• Continuous improvement of safety infrastructure

Link to targets: Supports achievement of zero major industrial accidents and reduction in incident frequency rates

Safety System Reviews (2024-2025)

Scope: Facilities in Greece

Time horizon: Initiated in 2024, expected completion in 2025

Description:

• Safety reviews of H&S systems across facilities
• Aligning with best practices
• Evaluate improvements following previous actions including gap analyses

Expected outcomes:

• Enhanced health and safety systems
• Improved employees' safety culture
• Enhanced outcomes

Targets related to own workforce

HELLENiQ ENERGY sets annual measurable goals to improve its Health and Safety performance overall and at each facility. The health and safety targets set by HELLENiQ ENERGY align with its Sustainability Policy objectives by promoting a safe and healthy work environment, minimizing risks, and ensuring regulatory compliance. The health and safety targets are based on the sector-specific KPIs used in European level (CONCAWE) and for the setting procedure, European benchmarking data have been taken into account.

Main Health and Safety Targets

Target Monitoring and Progress

Progress toward these targets is reviewed monthly and annually, with reports presented to management. The Group's main health and safety targets is to maintain zero major industrial accidents, zero fatalities while ensuring 100% compliance with health and safety training for all employees and contractors.

Progress is regularly monitored through reviews, with detailed reports presented to management to promptly address any deviations from targets if happen. Specifically, the performance of health and safety is being tracked through monitoring relevant KPIs and internal data, monthly and at the end of the reporting year, including workplace accident frequency and severity, employee health data, and completion rates of health and safety training for employees and contractors.

Stakeholder Engagement

Stakeholder engagement plays a vital role in target setting. Employee representatives, safety experts, and external stakeholders are consulted to ensure that targets align with organizational goals and industry standards. The Group incorporates input through continuous engagement with its employees, and many subsidiaries have established health and safety committees where regular meetings are conducted to develop and monitor health and safety issues.

Characteristics of the undertaking's employees

Total Headcount

Current period (2024): 3,734 employees (headcount)

Prior period (2023): 3,646 employees (headcount)

Headcount by Gender

Headcount by Region

The Group has significant employment (at least 50 employees representing at least 10% of total number of employees) only in Greece, with 3,174 employees.

HELPE RSSOPP employs 1,990 male employees.

Headcount by Employment Contract Type (2024)

Employee Turnover

Number of employees who left (2024): 279

Employee turnover rate (2024): 7.6%

Note: In 2024 there was a voluntary redundancy program in the Group.

Methodology and Assumptions

• The number of employees for 2024 is reported in headcount and concerns the number at the end of the reporting period as of 31.12.2024.
• No significant fluctuations occurred during the reporting period compared to previous years.
• FTE (full-time equivalent) is not separately disclosed.
• Breakdown by full-time/part-time employment type is not disclosed.
• Country-specific breakdowns beyond Greece are not provided in detail.

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

Total Number of Non-Employees

The total number of non-employees of the Group for 2024 is 94.

Methodology and Assumptions

The number of non-employees is reported in headcount and concerns the average number of non-employees across the reporting period.

In order to meet the predefined needs of the Group's companies EKO & KALYPSO, specific seasonal personnel is provided through Temporary Employment Agencies to cover organizational needs.

The above-mentioned number does not include:

• People who are working with contracts
• People who are working through outsourcing companies
• Those who work with bill of rendered services/service invoices (as under Greek law those employees provide independent services and not dependent work)

Those non-employees are included in the category of value chain workers covered by ESRS S2 (not material topical standard according to DMA, thus not reported in the Sustainability Statement). It is hereby noted that the employees of the third companies – external associates are not controlled by the Group.

Common Types of Non-Employees and Their Roles

Indicative activities assigned to contractor companies:

• Tank truck drivers
• Aircraft refueling drivers

Collective bargaining coverage and social dialogue

Overall Coverage

The percentage of employees covered by collective bargaining agreements is 81.3%.

Coverage in the European Economic Area (EEA)

The Group has five (5) collective bargaining agreements (HELPE, EKO, DIAXON, ASPROFOS, EKO CYPRUS). The Group has significant employment in Greece where the percentage of employees covered by collective bargaining agreements is 85%.

Coverage Outside the EEA

The Group has two (2) collective bargaining agreements (OKTA, JUGOPETROL).

• Republic of North Macedonia: 90%
• Montenegro: 100%

Collective Bargaining and Social Dialogue Coverage by Country

Social Dialogue

Representation by Worker's Representatives:

The percentage of employees covered by workers' representatives in Greece is 80%, which is the only EEA country where the Group has significant employment.

European Works Councils:

There is no agreement with Group employees for representation by a European Works Council (EWC), a Societas Europaea (SE) Works Council, or a Societas Cooperativa Europaea (SCE) Works Council.

Diversity metrics

Gender Diversity at Top Management Level

[ESRS S1-9-66-(a)]

Definition of Top Management: Based on the Group's organization chart, defined as up to one level below administrative and supervisory bodies, and includes all General Managers, all Managers in core business units (refining & domestic retail) and Heads (CEOs) of business units and all the persons above those. [ESRS S1-9-AR 71]

Age Distribution Across the Workforce

[ESRS S1-9-66-(b)]

HELLENiQ ENERGY Group Data (31.12.2024)

Adequate wages

All Group employees are paid an adequate wage. Specifically, Group employees are paid above and beyond national, collective and professional bargaining agreements, without any discrimination/differentiation. Salaries are adequate and exceed legal minimum requirements in all countries where the Group [operates]. [ESRS S1-10-69, 70]

Benchmark used: National, collective and professional bargaining agreements; legal minimum requirements

Coverage: All Group employees

Geographic scope: All countries where the Group operates

Methodology: No living wage benchmark disclosed. The company states wages exceed minimum legal requirements and collective bargaining agreements, but does not reference a living wage standard or methodology.

Social protection

Coverage by social protection scheme

All Group employees are covered by social protection, through public programs or through benefits offered by the company, against loss of income due to:

• Sickness
• Unemployment (starting from when the own worker is working for the company)
• Employment injury and acquired disability
• Parental leave
• Retirement

Coverage rate: 100% of employees covered

Type of scheme: Public programs and/or company-provided benefits

Geographic scope: All countries where the Group operates

Defined benefit pension plans

The Group operates defined benefit pension plans in Greece, Bulgaria, Serbia, North Macedonia, Montenegro and Cyprus. The level of benefits provided depend on members' length of service and remuneration. Part of the plans are unfunded, however there are certain plans in Greece and Cyprus that have plan assets.

Defined contribution plans

The Group's employees are covered by one of several Greek State sponsored pension funds which relates to the private sector and provides pension and pharmaceutical benefits. Each employee is required to contribute a portion of their monthly salary to the funds, with the Group also contributing a portion. Upon retirement, the pension fund is responsible for paying the employees retirement benefits.

Methodology note

Coverage applies to all employees across the Group's operations without exclusions.

Persons with disabilities

In the Group's workforce there are 13 individuals with disabilities, ensuring that they are provided with equal opportunities in both employment and training. This commitment reflects the Group's inclusive approach, aiming to create a supportive and equitable workplace for all employees.

In 2024, the percentage of persons with disabilities is 0.3%.

Contextual Information and Methodology

Group employs persons with disabilities according to legal definitions of persons with disabilities in the countries in which the Group operates. This guarantees adherence to regional labor regulations and disability inclusion guidelines.

Non-significant differences exist in the legal definitions of persons with disabilities across the countries it operates.

Training and skills development metrics

Performance and Career Development Reviews

Average Training Hours per Employee

Methodology note: The Group provides all employees with equal training opportunities per specialty. However, in industrial facilities, where more men are employed, the average training hours are slightly higher due to the nature of the work and the associated requirements.

Health and Safety Training

In 2024, 69,003 man-hours of training were provided on Health and Safety issues for employees and contractors.

Customer-facing Training

In 2024, training programs were held within the two partner networks - KALYPSO KEA S.A. and EKO S.A. - involving fuel station managers, owners, and staff. 4,345 individuals received theoretical and practical training, with duration equal to 10,158 hours of training, in Greece.

Health and safety metrics

Coverage of Health & Safety Management System

100% of the Group's own workforce is covered by health and safety management systems based on legal requirements and/or recognized standards or guidelines. The Sustainability Policy and Health and Safety Management System concern all employees and external partners providing services to the Group's facilities.

Health & Safety Performance Metrics (2024)

*Subsidiaries include: DIAXON, ASPROFOS, EKO CYPRUS, EKO SERBIA, EKO BULGARIA, JUGOPETROL, OKTA, HELLENiQ RENEWABLES & subsidiaries, HELLENiQ UPSTREAM, HELLENiQ ENERGY CONSULTING, ELPE FUTURE, HELLENiQ ENERGY DIGITAL, VARDAX, ELPET VALKANIKI & EKO AFRODITI.

Methodology Notes

The rate of recordable work-related accidents is calculated per 1,000,000 hours worked. In 2024, the Lost Workday Injuries Frequency (LWIF) index decreased by 34.1% and the All Injury Frequency (AIF) index decreased by 18.8% compared to 2023. The Process Safety Event Rate (PSER) showed a 46.9% decrease compared to the previous year. The Group benchmarks its performance against CONCAWE (European Organisation for Health, Safety and the Environment in the oil sector) indicators.

Work-life balance metrics

Entitlement and Take-up of Family-Related Leave (2024)

All employees (100%), regardless of gender, are entitled to take family-related leave. The family related leave categories include maternity leave, paternity leave, parental leave and carer's leave from work. In 2024, 10% of the Group employees made use of family related leave.

Methodology: Family related leave categories include maternity leave, paternity leave, parental leave and carer's leave from work.

Compensation metrics

Pay gap

The Group maintains a remuneration system free from gender-based differentiation. Upholding the principle of equality, there is no discrimination or financial disparity across any of the Group's companies. Currently, the gender pay gap within the Group stands at 23.35%.

Remuneration ratio

HELLENiQ ENERGY is committed to maintaining a transparent and equitable remuneration framework across its operations. The average annual total remuneration ratio within the Group is 28.41, reflecting a structured approach to compensation that aligns with performance, responsibilities, and market standards. This ratio underscores the Group's dedication to fostering a fair and competitive work environment, consistent with its core principles of equality and compliance with Greek, national, and EU regulations.

Methodology

The Group does not follow any kind of differentiation between men and women in the remuneration system. Remuneration is based on annual evaluations and follows the Greek, national and EU legislation on equal pay.

HELLENiQ ENERGY has established, maintains, and implements a Remuneration Policy for the members of the Board of Directors, which is aligned with its business strategy, goals, and sustainability. The Policy was approved by a resolution of the Extraordinary General Meeting of HELLENiQ ENERGY's Shareholders dated 20 December 2019 and was amended by a resolution of the Ordinary General Meeting of Shareholders on 30 June 2021. The Remuneration Policy outlines the framework for total annual gross remuneration and how it is allocated between fixed and variable components. Under this framework, individual performance, and executive contribution to achieving the Group's objectives are linked to variable remuneration and thereby influence the overall level of remuneration. In addition, to ensure transparency and meritocracy, the Remuneration Policy sets predefined measurable quantitative and qualitative targets and criteria, established in accordance with HELLENiQ ENERGY's Remuneration Policy for Executives.

The disclosure is marked as voluntary in the ESRS requirements table (Voluntary: ESRS 2-S1-16-97, AR 98, AR 99, AR 100, AR 101).

Incidents, complaints and severe human rights impacts

Work-Related Incidents and Complaints & Severe Human Rights Incidents

In 2024, HELLENiQ ENERGY demonstrated its strong commitment to ethical practices and respect for human rights across its operations.

Contextual Information

The Group maintains multiple grievance mechanisms and communication channels:

• Whistleblowing Policy (established April 2024, aligned with Law 4990/2022)
• Code of Conduct reporting procedures
• Anti-Harassment Policy (established 2022)
• Contact points for employees and external stakeholders (online forms, email, telephone)
• Employee suggestion box and intranet
• ISO certified management system grievance mechanisms

All employees have electronic access to available reporting mechanisms. The whistleblowing platform is available in Greek and English on the Group website, ensuring secure and anonymous reporting with confidentiality and protection against retaliation.

The Group's subsidiaries in North Macedonia, Serbia and Bulgaria have approved their own Whistleblowing Policies in accordance with local laws. Companies in Montenegro and Cyprus have whistleblowing reporting and protection procedures.

No incidents of discrimination were reported in Group companies in 2024. Operations and suppliers do not pose significant risk for incidents of forced or compulsory labour. The Group's recruitment policy prohibits employment of individuals under 18 years of age.

All security personnel (100%) provided by partner companies are officially certified and licensed by KEMEA and EOPEP, with training in human rights protection.

Policies related to affected communities

HELLENiQ ENERGY's commitment to supporting communities is outlined in its Group Sustainability Policy and Code of Conduct. The Group pledges to advocate for social standards throughout the world, prioritize community development and continuously engage with stakeholders so their views are considered.

Group Sustainability Policy

Key content and principles:

• Limit incidents that may compromise HSE and Society
• Protect human rights and protect the diversity and equality of individuals, including local communities
• Create value for the Group and the Society through consultation with stakeholders

Scope:

• Applies to HELLENiQ ENERGY operations and value chain, including local communities, consumers, and partners
• Covers external partners, third-party companies, and contractors providing technical, administrative, financial, or IT-related services

Implementation and monitoring:

• Partners are selected and assessed based on business and sustainability criteria
• Specific procedures govern partnerships, ensuring third-party entities comply with labour legislation (national, European, ILO) regarding human rights and working conditions
• Cooperation framework includes Code of Conduct, Procurement Regulations, policies for health and safety, environmental standards, responsible labour practices, and respect for human rights
• Evaluation process for suppliers
• "Condition of compliance" of suppliers with UN Global Compact principles in human rights, labour, environment, and anti-corruption

Alignment with international standards:

• United Nations' Sustainable Development Goals
• European Green Deal
• UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises
• No cases of non-respect reported in operations or value chain

Code of Conduct

Key content and principles:

• Prioritizing safety in all activities
• Delivering high-quality products and services to meet customer needs
• Ensuring fair competition practices
• Safeguarding group resources and data
• Fostering a culture of meritocracy, teamwork, and continuous improvement
• Emphasizes actions in health, education, sports, environment and social solidarity

Governance and oversight:

• Ultimate accountability for implementation rests with the compliance office
• Implemented within HELLENiQ ENERGY

Scope:

• Applies to HELLENiQ ENERGY operations
• Extends to local societies where the Group does business, as well as broader societies in Greece and abroad

Public availability:

• Publicly available on the corporate website

Alignment with international standards:

• UN Global Compact (active membership since 2008)
• Greek Sustainability Code
• Data provided through "Communication on Progress" questionnaire
• Commitment to promoting human rights and respecting diversity and equality throughout the value chain

Indigenous communities

HELLENiQ ENERGY does not operate in areas adjacent to indigenous communities; hence, there are no specific policy provisions for preventing and addressing impacts on indigenous populations.

Taking action on material impacts on affected communities

Overview

HELLENiQ ENERGY, through substantial investments and its consistent performance over time, contributes significantly to economic development and business innovation in Greece. The Group enhances employment, social welfare, and the national product of Greece and the countries where it operates, through the production and distribution of its products and services, the numerous jobs it creates, as well as the corporate responsibility actions it implements.

The Group prioritizes environmental protection and undertakes infrastructure projects aimed at creating sustainable cities, thereby contributing to the achievement of national and global goals for combating the climate crisis and supporting local communities. It implements actions that foster environmental consciousness and promote awareness among stakeholders regarding the impacts of climate change.

Key Actions and Initiatives

Scope: All actions address affected communities in the localities where HELLENiQ ENERGY operates (Greece and internationally)

Type: All actions are preventive, aimed at creating a positive social impact on affected communities while safeguarding the environment

Support to National Health System and Public Health

• Support of the National Health System and organizations that contribute to the protection of public health
• "Wave of Warmth" program (3rd consecutive year, 2024): Provision of heating oil to the largest Public Children's Hospitals of Attica

Education and Youth Development

• Graduate Excellence Award Program (16th year, 2024): 20 scholarships awarded for postgraduate studies at renowned universities in Greece and internationally; honored 295 outstanding graduates from General and Vocational High Schools in neighboring municipalities of Thriasio, West Thessaloniki, and Kozani
• Emergency support to 429 excellent graduates from Thessaly region (affected by September 2023 floods)
• "Earth 2030 Educational Suitcase" program: Educational program on UN Sustainable Development Goals delivered to 9,555 students across Greece in schools and camps
• Heating oil provision (16th consecutive year): Delivered more than 295,000 liters of heating oil to 160 public schools of all educational levels in municipalities neighboring its facilities

Environmental Protection and Emergency Response

• Erosion-control works in West Attica (completed February 2024): Critical erosion-control works completed in 620 hectares of forest areas affected by July 2023 wildfires; 100% ecological interventions using materials from burnt trees; approximately 201,000 current meters of log bundles, log grids and branch bundles and 283.5 square meters of log barriers placed
• Erosion-control works in Rapentosa-Marathon (to be implemented within 2025): Works in areas affected by summer 2024 fires

Support for Vulnerable Groups

• Support of social grocery stores and parishes
• Direct jobs supported in the local community
• International Women's Day actions (2024): Improved living conditions of more than 660 women and their families; supported three centers for the protection, empowerment and skills acquisition of vulnerable women in Athens, Thessaloniki and Komotini ("Multiple Social Activities" space and "Tailoring Workshop" of the Hellenic Red Cross "Social Welfare Sector's Multipurpose Center")

Resources Allocated

Financial resources (2024):

• Total investments in corporate responsibility actions in Greece and internationally: €10.4 million

Beneficiaries (2024):

• Approximately more than 2,000,000 individuals benefited from actions in 2024

Effectiveness and Monitoring

To enhance the effectiveness of actions and initiatives, HELLENiQ ENERGY:

• Establishes clear, measurable objectives for each initiative
• Employs key performance indicators (KPIs) to monitor progress
• Conducts regular impact assessments, stakeholder feedback mechanisms, follow-up surveys
• Tracks number of beneficiaries
• Uses qualitative and quantitative surveys (Company Reputation Monitor), conducted periodically in local communities
• Results included in Social and Economic Impact Study conducted by the Foundation for Economic and Industrial Research (IOBE) annually, presented to senior management
• Sustainability Committee tracks progress of all established sustainability targets
• Board of Directors maintains oversight of target progress

Environmental Impact Assessments

All facilities conduct environmental impact assessments, where potential risks to the local community are identified and assessed, and then monitored and managed during operation. Significant impacts may occur at the following stages: at the start of a new activity, during operation or during decommissioning.

Human Rights Issues and Incidents

No severe human rights issues and incidents connected to affected communities have been reported during 2024 through any of the Group's communication channels.

Link to Strategy

Actions are designed by thematic category and implemented at national and local level. The initiatives are informed by stakeholder engagement insights and designed to address genuine needs of local communities, with a focus on enhancing sustainability and overall well-being, education, infrastructure to protect from severe weather events, and support for several social groups.

Targets related to affected communities

Target: Beneficiaries from corporate responsibility actions

Target metric: Number of beneficiaries from corporate responsibility actions at local and national level

Target value: > 1.5 million beneficiaries

Target period: 2024 until 2026

Baseline year: Not disclosed

Baseline value: Not disclosed

Scope: Local and national level (Greece and abroad subsidiaries)

Target type: Absolute

External validation: Not disclosed (internal target)

Progress to date (2024): More than 2 million beneficiaries in 2024

Additional monitoring metrics:

• Amount spent on corporate responsibility actions: €10.4 million in 2024

Target formulation process: The objective was formulated through a structured process incorporating relevant IROs from the DMA, informed by stakeholder engagement insights, with the intention of creating shared value for affected communities. The target focuses on enhancing sustainability, quality of life, education, infrastructure protection from severe weather events, and support for vulnerable social groups including vulnerable women.

Governance and monitoring: Results are included in the Social and Economic Impact Study conducted annually by the Foundation for Economic and Industrial Research (IOBE) and presented to senior management. The Sustainability Committee tracks progress of sustainability targets, and the Board of Directors maintains oversight of target progress.

Policies related to consumers and end-users

HELLENiQ ENERGY has established policies to enhance consumer confidence and ensure product quality and safety throughout its supply chain.

Quality Policy

Objective and scope:

• Aims to produce and deliver high-quality products and services that meet customer requirements
• Applies to all Group employees and is integrated into every activity
• Applies to all consumers and end-users without limitation

Key content and principles:

• Systematically checking the reliability of equipment, the quality of raw materials, intermediates, and final products
• Implementing a certified quality management system
• Responding through actions and programs to stakeholder expectations and needs regarding quality
• Applying relevant Greek and European legislation and monitoring international legal developments
• Planning necessary changes and investments
• Continuous improvement of products and provision of necessary information to customers regarding quality of products and services
• Adopting and applying advanced practices and best available techniques in production processes
• Ensuring product safety, sustainability, and consumer satisfaction through robust quality control systems at all stages of production and distribution

Governance:

• Ultimate accountability for implementation rests with the QHSE Division

Public availability:

• Publicly available on the corporate website

International standards linkage:

• Commitment to charters and initiatives according to the UN Global Compact (active membership status since 2008)
• Greek Sustainability Code
• Publicly available data through Communication on Progress questionnaire

Sustainability Policy

Key content and principles (related to consumers and end-users):

• Commitment to promote human rights and respect diversity and equality of individuals, eliminating all forms of discrimination throughout the value chain, including local communities, consumers and partners
• Adopting sustainability best practices in procurement and marketing procedures and throughout the value chain for the provision of safe, sustainable and accessible energy products
• Maintaining open and accessible channels for consumers and end-users to raise concerns and provide feedback on all issues, including human rights issues

International standards linkage:

• UN Global Compact (active membership since 2008)
• Greek Sustainability Code

Personal Data Protection Policy

Objective and scope:

• Reflects commitment to respectfully manage personal data that come into its possession within the scope of business activities
• Binds all Group companies

Key content and principles:

• Follows the European Personal Data Protection Regulation (GDPR)
• Greek legislation
• Internationally recognized best practices at European and international level
• Modern technological developments
• Protection of personal data is a top priority

Governance:

• Group Data Protection Officer appointed at Group level
• Privacy Officers in each organizational unit and subsidiary of the Group
• Five subsidiaries (EKO S.A., KALYPSO KEA S.A., ELPE FUTURE, EKO Bulgaria, and OKTA) have appointed independent Data Protection Officers who collaborate with the Group Data Protection Officer

Monitoring implementation:

• Organizational structure created throughout the Group to ensure compliance with applicable legislation, the Personal Data Protection Policy and specific procedures and actions used to implement the Policy in daily operations

Whistleblowing Policy

Key content:

• Implemented in accordance with Law 4990/2022 on protecting individuals who report violations of European Union law (Whistleblowing)
• Channels through which consumers and end-users can report infringements are expanded

Taking action on material impacts on consumers

HELLENiQ ENERGY, through its subsidiary EKO S.A., has implemented a series of programs and initiatives to better serve customers and respond to their needs. The following actions are in place:

Covert Inspector Program

• Scope: Fuel stations network in Greece (downstream value chain)
• What it does: Evaluates services rendered, quality of service at fuel stations, and adherence to operational specifications under real-world conditions. Inspectors assess 65 criteria across nine domains including forecourt and equipment, service quality, security measures, shop conditions, staff uniforms, restroom facilities, and promotional activities.
• Activity in 2024: 4,539 inspections of fuel stations conducted throughout Greece. Each service station undergoes evaluation by a covert inspector between four to twelve times annually.
• Implementation: Findings published monthly on an electronic platform accessible to all sales executives and service station managers, enabling monitoring of progress and indicators for enhancement.
• Expected outcome: Elevate customer service standards and meet customer expectations more effectively.

"Everyday, brighter" at bp fuel stations

• Scope: bp fuel stations (downstream value chain)
• What it does: Continuous investments in enhancement of consumer experiences at service stations, transforming each interaction into a pleasant and memorable encounter.
• Key features: Well-lit Bright Green Beacon fuel stations, easy accessibility, cleanliness across all areas, exemplary service from employees, superior fuel quality, safety during refueling and transactions.
• Sponsorships: Official sponsorships with BWT Alpine F1® Team on a global scale, with prominent contests offering consumers opportunities to participate in unique experiences (e.g., visiting the BWT Alpine F1® Team factory and driving racing cars).
• Expected outcome: Foster robust connection with the bp brand, allowing consumers to appreciate superior quality of products.

EKO Smile Reward Program

• Scope: EKO customers (downstream value chain)
• Timeline: Initiated in 2022, continued in 2024
• What it does: Loyalty program with primary emphasis on immediate rewarding of customers during daily transactions, provision of high-level and expeditious service, and facilitation of personalized transactional experience.
• Channels: EKO Smile App for timely and targeted dissemination of news and offers
• Features: Contactless payments by scanning receipts, automatic earning of Smile points, online product purchases with complimentary delivery, transfer/donate Smile points, redeem points for online vouchers, review transaction history, participate in exclusive experiences.
• 2024 specific initiative: "Olympiacos Unique Experience" providing opportunity to redeem points for tickets to Olympiacos BC games.
• Expected outcome: Enhanced customer engagement and loyalty; deeper understanding of consumer behavior and preferences for personalized communication.

Eco-driving and Energy Efficiency Awareness

• Scope: Consumers and end-users (downstream value chain)
• What it does: Provision of eco-driving advice and rational use of heating oil through social media posts and distribution of information leaflets.
• Key messages: Driving behavior (e.g., avoiding sudden acceleration, removing unnecessary weight from vehicle), correct use of heating oil (e.g., setting thermostat at 19°C, regular boiler maintenance).
• Expected outcome: Raise awareness so that less fuel is consumed for the same purpose and with the same result.

Special Pricing Collaborations for Employees

• Scope: Own employees
• What it does: Special pricing on energy products for employees.
• Expected outcome: Improving affordability and access to essential energy resources.

Product Quality Assurance Programs

Integrated Quality Control (Greece - EKO S.A.)

• Scope: Supply chain from refinery to point of sale (downstream value chain)
• What it does: Mobile Laboratory Units carry out spontaneous on-site quality checks at EKO and bp branded fuel stations. Continuous quality controls throughout the year across the supply chain. Evidence of compliance with acceptance criteria maintained; release to customers only after conformity verification.
• Resources: Mobile Laboratory Units
• 2024 activity: 94,452 qualitative analyses on 7,746 petrol station fuel samples; 7,173 aviation fuel analyses; 27,429 lubricant analyses at EKO's Chemical Laboratory.
• Certification: ISO9001:2015 certified Quality Management System for LPG storage, handling, and bottling facilities; Lubricants Production Unit.

OKTA GUARANTEE Program (North Macedonia)

• Scope: OKTA fuel stations in Republic of North Macedonia (downstream value chain)
• What it does: Integrated control program for fuel stations with OKTA logo.
• Partners: School of Mechanical Engineering of the Republic of North Macedonia and its accredited laboratory.
• 2024 activity: 148 qualitative analyses of service station fuel samples and quantitative accuracy checks in 648 fuel station pump nozzles.

EKO Guarantee Program (Bulgaria)

• Scope: EKO Bulgaria petrol stations (downstream value chain)
• Timeline: Celebrated 10th anniversary in 2024
• What it does: First program of its kind for additional control and assurance of quality and quantity of fuels. Enhances requirements of national legislation by introducing additional levels of control.
• Partners: "Bulgarkontrola" AD (largest independent control organization in Bulgaria specializing in fuel testing).
• 2024 activity: 2,060 inspections by mobile laboratory without prior notice; 63 extraordinary checks; 174 samples from fuel tankers (90 diesel, 84 gasoline).
• Scope of monitoring: Quality throughout supply chain from depots to service stations.

Aviation Fuels Quality

• Scope: 20 airports across Greece
• What it does: Supply JET Aviation Fuels of two civil and military specifications (JET A-1 & JP-8).
• Resources: Chemical Laboratory at Skaramangas Facility equipped with state-of-the-art equipment; high performance in international laboratory tests.

E-Gas and E-Gas Easy LPG Cylinders

• Scope: LPG consumers
• What it does: Adherence to stringent safety standards ensuring highest level of safety.
• Certification: ISO9001:2015 certified Quality Management System for receipt, storage, bottling, and distribution of LPG.

Lubricants Quality Assurance

• Scope: Lubricants consumers
• What it does: Quality assured at all critical stages of production with continuous checks certifying compliance with design specifications.
• Certification: ISO9001:2015 certified Quality Management System for Lubricants Production Unit.

Digital Transformation (Horizon Program)

• Scope: Across business activities, with customer-facing Digital Retail component (downstream value chain)
• Time horizon: Strategic priority for sustainable growth (short and long term)
• What it does: Enhances corporate performance by augmenting turnover and profitability, elevating workforce skill set, reducing operating costs through improved productivity and operational flexibility, implementing new digital tools and methodologies, heightening quality and efficiency, accelerating commercial responsiveness, and personalizing customer experience.
• Digital Retail component: Expands reach of HELLENiQ's loyalty program throughout Southeast Europe; fosters engagement and transparency among retail consumers; adopts cohesive approach towards partners and corporate clients.
• Expected outcome: Enhanced experience and interaction within retail sector, generating significant commercial value for both the Group and its consumers.

Training Programs for Fuel Station Personnel

• Scope: Fuel stations networks (KALYPSO KEA S.A. and EKO S.A.) in Greece (downstream value chain)
• What it does: Thorough training in customer service and promotion of sales to avoid causing or contributing to material impacts on consumers and/or end-users.
• Modules: Lubricants EKO-Castrol, Customer Service and Promotion of Sales, Heating Diesel Distribution.
• Resources (2024): 4,345 individuals received theoretical and practical training; 10,158 hours of training.
• Expected outcome: Prevent material impacts through improved service quality.

Stakeholder Engagement and Feedback System

• Scope: Consumers and stakeholders
• What it does: Ongoing engagement to better understand needs and expectations; consumer and stakeholder communication channels serve as prevention mechanism for identification of potential negative impacts.
• Resources: Call center
• 2024 activity: 41,692 calls answered.
• Tracking: Issues raised and addressed through feedback system, including regular surveys.
• Effectiveness evaluation: Gathering input from stakeholders who are intended users of channels.

Remediation and Compensation

• What it does: In cases of proven product quality issues arising from consumers, company provides compensation; in cases of Health & Safety issues, legal judgement required to provide compensation.
• Responsible division: Marketing division addresses all other consumer and end-user issues.
• Note: No actual impacts requiring remedy identified in 2024; no severe human rights issues and incidents connected to Group's consumers and/or end-users reported during 2024.

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Link to Targets (S4-5)

The actions support the following time-bound and outcome-oriented targets:

• ~5,000 Electric vehicle charging points at EKO/bp stations and publicly accessible charging points by 2030 (base year: 2023, base value: 162)
• >140 kta Production of sustainable fuels (biodiesel production plant through cooking oil reuse (UCO) at Thessaloniki refinery and development of new stand-alone SAF production plant at Aspropyrgos refinery) by 2030 (base year: 2023, base value: 0)

Governance: Sustainability Committee tracks progress; Board of Directors has oversight.

Target-setting process: Established through structured process incorporating relevant IROs from DMA and Vision 2025; collaboration with internal experts from Elpe Future Division and Sales Division; aims to offer positive and impactful contributions to end-users and consumers including wide network of charging points in remote areas and rural communities.

Monitoring metric: Number of products analyses per year (2024: 94,452 qualitative analyses on 7,746 petrol station fuel samples in Greece; 7,173 aviation fuel analyses; 27,429 lubricant analyses).

Targets related to consumers

HELLENiQ ENERGY has established time-bound and outcome-oriented targets related to advancing positive impacts and managing material opportunities for consumers and end-users:

Target 1: Electric Vehicle Charging Points

Target 2: Sustainable Fuels Production

Additional Monitoring Metric

The company also uses the number of product analyses per year as a metric. In 2024, within the territory of Greece, EKO conducted:

• 94,452 qualitative analyses on 7,746 petrol station fuel samples
• 7,173 aviation fuel analyses
• 27,429 lubricant analyses at EKO's Chemical Laboratory

Target Establishment Process

The targets were established through a structured process incorporating relevant impacts, risks and opportunities (IROs) from the Double Materiality Assessment and Vision 2025. The decision-making process involved collaboration with internal experts from the Elpe Future Division and Sales Division. The Sustainability Committee tracks progress and the Board of Directors has oversight of the targets' progress.

Business conduct policies and corporate culture

Corporate Governance Practices

In the context of implementing a structured and adequate corporate governance system, the Company has implemented specific good corporate governance practices, some of which are over and above those provided by the applicable legislation.

Group Code of Conduct

In the context of the good corporate governance fundamental obligation, the Company has drawn up and adopted since 2011 a Code of Conduct, which has been approved by the Company's BoD. The Code of Conduct summarizes the principles according to which every individual, employee or third party involved in the operation of the Group, as well as every collective body thereof, should act within the framework of their duties. For this reason, the Code constitutes a practical guide of the day-to-day tasks of all employees of the Group, but also of third parties who cooperate with it.

The Group Code of Conduct is posted on the Company's website and its revised version is expected to be applied in 2025, capitalizing the experience from its 14 years of validity and taking into account new legislative developments.

Corporate Governance Policies

The Company has adopted corporate governance policies and procedures, which include:

• The Procedure for handling inside information and properly informing the public, in accordance with the provisions of Regulation (EU)) 596/2014, which includes the appropriate mechanisms and methodologies for the assessment of information so that it may qualify as "inside", the prohibition of abusing or attempting to abuse inside information or recommending to another person to proceed to an abuse of inside information, as well as the prohibition of unlawful disclosure.

• The Procedure for the compliance of persons discharging managerial responsibilities, in accordance with the provisions of article 19 of Regulation (EU) 596/2014, which includes a clear and detailed recording of the requisite notification actions, aiming at strengthening transparency regarding the transactions of management officers and of the persons closely associated therewith and identifying potential risks (abuse, market manipulation, etc.)

• The Policy and Procedure on related party transactions, which sets out the mechanisms for identifying, supervising and approving the transactions in question. In the context of the procedure relevant documents and information concerning related parties are kept and updated. The information on the above transactions among associate companies are included in the report accompanying the Company's financial statements, in order to be disclosed to the shareholders. According to the provisions of L. 4548/2018 (article 99- 101), Company transactions of any kind with parties related to it, are permissible only following approval by the BoD or the General Meeting, as per case, unless they fall under the exceptions stated in the law.

• The Policy and Procedure for preventing and managing conflict of interest situations, which provides for designating the way in which conflict of interest may arise, for receiving reports or clarifying doubts in cases of such (actual or potential) conflict and for taking appropriate measures for managing them.

Whistleblowing Policy

In 2024 the Policy for the protection of persons who report breaches of Union law (Whistleblowing) applied, according to the provisions of the L. 4990/2022, which ratifies the EU Directive 2019/1937.

Policy against Violence and Harassment

According to the provisions of L. 4808/2021, which, inter alia, ratify Convention 190 of the International Labor Organization on eliminating violence and harassment in the world of work and proceeds to adopting relevant measures and provisions, the Policy against Violence and Harassment was put into effect at the Group's companies.

Data Protection

In the context of complying with the Personal Data Protection Regulation, the Company has established a Personal Data Protection Office (PDPO), by appointing a Data Protection Officer (DPO) at a Group level, but also in specific subsidiaries. The PDPO has drawn up the appropriate policies and procedures for the effective protection of the privacy of personal data processed by the Group and ensures their implementation and the provision of support in matters of personal data protection.

DPO is administratively reporting to the Chief Executive Officer and, functionally, to the BoD. By utilizing the experience gained from the 6 – year operation of the Personal Data Protection Office, all the policies for the protection of Personal Data are in the final stage of revision and updating.

Conflict of Interest Management

The BoD members have, by law, a duty of care and loyalty towards the Company. They act with integrity and to the Company's interest and safeguard the confidentiality of the non-publicly available information.

The BoD members have to avoid any situation creating a conflict between their personal interests and those of the Company, not to acquire advantages and personal benefits at the expense of the Company, unless they are authorized by the General Meeting of the Company's shareholders, or the BoD. The BoD members must not be in competition with the Company and must avoid any position or activity creating conflict between their private interests and those of the Company, including participating in the share capital (by a percentage > 0.5%), holding posts in the BoD or the Management of competitive companies.

Bylaws (Internal Regulation)

The Company's Bylaws set out, among others, the powers and responsibilities of the principal job positions promoting the adequate separation of powers within the Company. The approved Bylaws have been posted on the Company's website, in accordance with par. 2 of article 14 of L. 4706/2020.

Furthermore, the companies "HELLENIC FUELS AND LUBRICANTS SINGLE-MEMBER INDUSTRIAL AND COMMERCIAL SOCIETE ANONYME" and "HELLENIC PETROLEUM SINGLE-MEMBER SOCIETE ANONYME REFINING, SUPPLY AND SALES OF OIL PRODUCTS AND PETROCHEMICALS", as key Company subsidiaries, adopted bylaws on 15.7.2021 and 20.1.2022, respectively.

Corporate Governance Code Compliance

The Company has adopted the Hellenic Corporate Governance Code (June 2021 edition) of the Hellenic Corporate Governance Council (HCGC). During 2024, the Company complied with the provisions of the above Code, with minor deviations related to:

• Gradual replacement of Board members (the practice is that terms begin and end simultaneously)
• Recovery provisions for executive remuneration (deemed unnecessary given individual performance assessment)
• Board evaluation timing (deferred due to new Board election in June 2024)

Incidents of corruption or bribery

Confirmed incidents

During the reporting period (2024), no incident of corruption was reported to the Regulatory Compliance Office or to the Management of the Group's companies and there were zero monetary losses due to corruption incidents.

Convictions and fines

No convictions, fines, or monetary losses related to corruption or bribery were reported during the reporting period.

Disciplinary actions

No employees were dismissed or disciplined for corruption or bribery during 2024.

Contracts terminated

No contracts with business partners were terminated or not renewed due to corruption or bribery violations during the reporting period.

Investigation procedures and speak-up mechanisms

The Group maintains several mechanisms to prevent, detect, and report corruption and bribery:

• Code of Conduct: Summarizes principles governing the conduct of employees and third parties, including specific examples of corruption to avoid. All employees (100%) have been informed about the Group's anti-corruption policies through the Internal Labor Regulation and the Code of Conduct, which is available as an e-learning course.

• Whistleblowing Policy: Established in April 2024 in compliance with Law 4990/2022 (implementing EU Directive 2019/1937). The policy provides secure and confidential channels for employees, executives, and external stakeholders to report concerns related to bribery, corruption, and money laundering. A dedicated Whistleblowing platform has been developed on the HELLENiQ ENERGY Group website (available in Greek and English) enabling secure and anonymous reporting. The policy ensures confidentiality, protection against retaliation, and provides remedies for retaliatory actions.

• Internal Audit: During 2024, Group Internal Audit incorporated compliance issues, including corruption risks, into the annual audit program, conducting four compliance audits focused on corporate governance. In 2024, 100% of the Group's organizational units were screened for corruption-related risks using a standardized internal inspection process aligned with the Group's Code of Conduct.

• Regulatory Compliance Office: Employees and third parties can freely reach out to the Group Regulatory Compliance Service to report concerns over any behavior possibly deviating from the law or the Code of Conduct.

• Anti-corruption commitments: For partners, anti-corruption policies and commitment to the UN Global Compact principles are communicated through contractual clauses, ensuring that 100% of partners are aligned with the Group's ethical standards.

The internal structure and corporate governance framework include checks and balances such as dual-person partnerships for decision-making, mandatory internal approvals, and regular audits to ensure transparency and compliance with anti-corruption policies.