HELLENiQ ENERGY Holdings

Reference: page 120

The Board of Directors of HELLENiQ ENERGY Holdings is described as "the highest governance body", operating under Greek law, the Articles of Association and resolutions of the General Meeting. Composition is disclosed in full: 11 members, of whom "9 (82%) men and 2 (18%) women", with "2 (18%) members hold executive responsibilities and 9 (82%) are non-executive members, of whom 45% are classified as independent" (p.120).

Roles are split three ways. The Board and the Sustainability Committee hold "ultimate oversight and accountability for the Group's Sustainability Strategy". The Sustainability Committee tracks legislative developments, measures performance against ESG targets tied to identified material IROs, and reports to the Board. The Executive Committee, which includes the Group HSE & Sustainable Development Manager, carries the executive responsibilities for developing and implementing the strategy (p.120).

The Group states plainly that the Board "does not include a specifically appointed member representing employees, nor is there a formal mechanism for employee representation at the Board level" (p.120). Board expertise on sustainability is addressed through targeted training, with members' skills set out in the table "BoD members' experience and basic skills" in chapter B.1.7 of the Annual Financial Report rather than in the statement itself.

Reference: page 120

Meeting dates and business are disclosed rather than described in general terms. "During 2025, the Sustainability Committee met three times: on 24 February, 17 September, and 3 December" (p.120). The first meeting approved the 2024 Sustainability Statement, the second approved and revised the second edition of the Committee's Operation Regulation, and the third covered "the preliminary validation of the Group's DMA results for 2025".

Timing of final sign-off is given: "The DMA was completed within 2025, and in February 2026, during a joint session of the Sustainability Committee and the Audit Committee, the final results of the DMA and the 2025 Sustainability Statement were validated, with approval by the BoD and in the presence of the CEO" (p.120).

The outcome reported to the bodies is quantified: "HELLENiQ ENERGY Group identified a total of 32 material IROs, which were categorized into 11 material sustainability topics (covering 8 ESRS Sustainability Matters). Among these is Cybersecurity, which falls under the section ESRS G1 - Business Conduct" (pp.120-121). The Strategy and Risk Management Committee approves the corporate risk management framework, sets risk appetite and tolerance, and oversees management of material corporate risks (p.121).

Reference: page 121

The Remuneration Policy was first approved by the General Meeting in 2019 and revised in 2021 and 2024, runs for four years, and combines fixed and variable components with quantitative and qualitative performance indicators plus long-term incentives through free shares (p.121).

For FY2025 the targets covered "safety, competitiveness, efficiency, profitability, financial performance, and progress on the energy transition plan". Climate parameters enter variable pay through KPIs that include "GHG emission reduction targets, safety indicators (LWIF and AIF), financial benefits from the digital transformation program, investments in the Refining & Petrochemicals, the Domestic Marketing Transformation Plan, and the expansion of RES projects portfolio" (p.121).

A Long-Term Incentive Plan was approved at the Annual General Meeting on 27 June 2024. It runs two three-year evaluation cycles with shares released gradually. For the first cycle (2024-2026) the weightings are disclosed: "financial targets (60% weight), transformation targets (20% weight), and ESG targets (20% weight)", and climate-related targets within that cycle "carry a weighting of 20%" (p.121). The percentage of variable remuneration tied to each sustainability objective is not repeated here; the statement cross-refers to the Group's remuneration report.

Reference: page 121

The due diligence process is aligned to "the six stages of due diligence, in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the Organisation for Economic Co-operation and Development Guidelines for Multinational Enterprises (OECD MNEs)", with the diagram placed in the EU Taxonomy section (pp.121-122).

A gap is admitted rather than glossed: "Although the Group does not yet have a formal due diligence policy in place, it has integrated relevant practices into its governance framework, strategy, and business model" (p.122).

Outcomes for the year are given in specifics. The revised Code of Conduct entered into force in 2025. On corruption, "no incident of corruption was reported to the Regulatory Compliance Office, nor were any related financial losses recorded", Internal Audit conducted "four (4) audits with a focus on governance", and "All employees (100%) have been informed about anti-corruption policies through the Code of Conduct and the Internal Labor Regulation" (p.122). On adverse impacts, the Group reports no irrevocable environmental fines and no irrevocable Labor Inspectorate fines "except for two individual cases of typical violations, which did not have a material impact on the Group's operational compliance" (p.122). Collective bargaining coverage is 74% and seven representative unions co-sign company agreements (p.122).

Reference: page 123

The statement names the three risks the Group has identified in its own sustainability reporting and pairs each with a control (pp.123-124):

• "Data Collection Inconsistencies", controlled through standardised collection protocols and templates across all departments and locations and centralised software to consolidate the data.
• "Availability & timing of upstream and/or downstream value chain data", controlled by setting clear reporting timelines and maintaining communication with value chain actors.
• "Misrepresentation or exaggeration of sustainability achievements, leading to stakeholder distrust", controlled by an audit at general director level, review by the Sustainability Committee, and "independent third-party limited assurance to the information included in the Sustainability Statement".

Ownership is assigned: oversight, monitoring of preparation and approval of the annual Statement fall to the Board's Sustainability Committee, which also contributes to identifying and assessing sustainability risks alongside the Risk Monitoring and Management Division (p.124). The Independent Internal Audit Division "regularly assesses the adequacy and effectiveness of the system" (p.123), and the risk assessment approach for the Statement follows the Group's unified risk management framework rather than a separate process (p.124).

Reference: page 125

Seven business lines are set out with figures. Refining: the Group "operates three of Greece's four refineries, covering over 60% of the country's total refining capacity and holding a 60% market share in domestic petroleum products" (p.125). Petrochemicals: a leading polypropylene position with over 65% of sales exported. Fuels marketing: 1,557 service stations in Greece at end-2025 plus 336 across Cyprus, Bulgaria, Serbia, Montenegro and the Republic of North Macedonia. RES: 506 MW operational in Greece, Cyprus and North Macedonia, roughly 6 GW under development, 778 GWh generated in 2025 "helping to avoid over 255,000 tons of CO2 emissions". Power and Gas: Enerwave operates 852 MW of gas-fired generation. Electromobility, technical studies through ASPROFOS, and hydrocarbon exploration offshore western and southern Greece complete the model (pp.125-126).

Revenue by activity is disclosed for the fossil-fuel datapoints (p.133): oil activities EUR 10,685,683 thousand, gas activities EUR 172,958 thousand, chemicals production EUR 284,116 thousand, coal activities nil, with fossil fuel activities totalling EUR 10,858,641 thousand. The Group states it does not engage in controversial weapons or tobacco production.

Strategy is the VISION 2030+ plan, which follows the completed VISION 2025: continued competitiveness in downstream, international expansion, and turning the Power business into an autonomous vertically integrated platform (p.128).

Reference: page 134

Stakeholders are defined as those "directly or indirectly, that are materially affected by the Group's activities or may influence the implementation of its strategy and the achievement of its objectives", with engagement treated as an input to due diligence and to the double materiality assessment (p.134).

A table sets out each category with methods and frequency (p.135). Employees are engaged through dialogue, scheduled meetings, qualitative and quantitative surveys, webcasts, publications and newsletters on a periodic basis, and through the intranet, corporate updates, events, awareness campaigns and an employee suggestion box daily. Business customers are engaged daily and periodically through dialogue, meetings, contracts, events and focus groups. Consumers are covered by satisfaction and loyalty surveys and questionnaires on acceptance of new products and services, monthly, quarterly, annually and case by case. Fuel station owners, suppliers and business partners, shareholders and investors, society and local communities are listed as the remaining categories.

The statement says the outcomes are used "to identify and integrate material topics into the business decision-making process" (p.134) and cross-refers to the section on validation of IROs for how the Board is informed of stakeholder views. Thirteen focus groups with external experts were used in the DMA to test the IRO list and support prioritisation (p.143).

Reference: page 137

The headline count is explicit: "A total of 152 IROs were identified and thoroughly assessed within the DMA. Specifically, regarding Impact Materiality, 75 impacts were evaluated, of which 20 were considered material. Regarding Financial Materiality, 77 risks and opportunities were assessed, of which 12 were deemed material. All of these IROs are directly covered by the ESRS Disclosure Requirements, with the exception of one entity-specific topic (Cybersecurity)" (p.137).

The introduction to the statement gives the same total from the other direction: 32 material IROs across 11 sustainability thematic areas covering 8 ESRS Sustainability Matters (three environmental, six social, two governance) (p.114).

Year-on-year change is disclosed: newly material in 2025 are "from ESRS E3, the sustainability mater 'Water'; from ESRS G1, the sustainability mater 'Corporate Culture' and the entity-specific mater 'Cybersecurity'; and from ESRS S1, the sustainability mater 'Equal treatment and opportunities for all'. All other material maters from the 2024 DMA remained the same" (p.138).

The Group applies the Quick Fix phase-in reliefs, so financial effects are given qualitatively only (p.138). Note that the table "Material IROs per time horizon and value chain level" on pages 140-141 is presented as a graphic and carries no extractable text.

Reference: page 142

Impact materiality is quantified at each funnel stage: "Initially, 207 impacts (long list) were examined and grouped into 75 (short list), of which 20 were deemed material for the current reporting period across three time horizons: 2026, 2027-2030, and 2031-2036". Criteria were "scale, scope, likelihood (for potential impacts only), and irremediability (for negative impacts only)", with an impact treated as material if it exceeds the threshold in any time horizon (pp.143-144).

Financial materiality followed the same shape: "Initially, 425 risks and opportunities (long list) were examined, grouped into 77 (short list)", of which 12 were material. The threshold was set "taking into account both the medium-term profitability... and the medium-term value of net operating assets on the balance sheet" (p.144).

Thirteen focus groups with external experts reviewed the short list for gaps (p.143). Five named process risks are disclosed with their inherent controls, including careless identification of IROs and overambitious scoring, validated by special assessment teams and by Internal Audit and Risk Management (p.145). Per-standard IRO-1 sections follow for climate, pollution, water, biodiversity, resource use and business conduct (pp.146-156). Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Reference: page 157

The Group prints a full ESRS content index headed "IRO-2 - Disclosure Requirements in ESRS Covered by HELLENiQ ENERGY's Sustainability Statement" (pp.157-162). Each row gives the disclosure requirement, the section or report that carries it, and a datapoint list flagged "Applicable", "Voluntary" or "Omitted". The index states it also shows where information "incorporated by reference" sits outside the Statement, such as the management review, the financial statements or the separate remuneration report.

The flags carry real information. E1-5, E1-8, S1-13, S1-16 and the whole of E4 and E5 are marked "Voluntary". E3-3 is the only row marked "Omitted: ESRS E3-3-23, 24, 25". E1-7, E2-5, E5-6 and every ESRS S2 row are absent from the index altogether.

A separate table then lists "all the data points that derive from other EU legislation as listed in ESRS 2 appendix B, indicating where the data points can be found in our report and which data points are assessed as 'Not material'", cross-referenced to SFDR, Pillar 3, Benchmark Regulation and EU Climate Law columns (pp.163-165).

One gap is worth flagging for readers: the index runs from the cross-cutting standards through ESRS S4 and then moves straight to the EU legislation datapoints table. It contains no Governance Standards block, so G1-1, G1-3 and G1-4 are not listed in the concordance even though the ESRS G1 chapter carries them with printed DR codes and datapoint tags (pp.277-281).

Reference: page 200

Three decarbonisation levers are named: renewable energy production and storage; participation in research programmes; and sustainable mobility through SAF and e-mobility (ELPEFuture / EKO Charge&Go) (p.200).

Funding is quantified. "For the period 2026-2030, investments related to decarbonization actions, the development of technologies and production of low-carbon fuels, as well as the further expansion of the Group's presence in RES, are expected to exceed EUR 1 billion", supported by "a flexible financing framework of up to EUR 766 million" for RES growth (p.200). Counter-evidence is also given: "During the financial year 2025, significant CapEx for coal-, natural gas- and oil-related activities reached EUR 363 million" (p.201).

Locked-in emissions are addressed qualitatively: emissions from the three refineries "are not expected to jeopardize the achievement of its broader GHG emission reduction targets", on the basis of efficiency improvement and investment in carbon capture and storage (p.201). No figure is attached.

The Group discloses that it "operates extensively in the oil and natural gas sector and, for this reason, is exempt from EU benchmarks aligned with the Paris Agreement" under Regulation (EU) 2022/2453, while applying Articles 12.1(d) to (f) and 12.2 (p.201). The plan "is fully integrated and aligned with its overall business strategy and financial planning, and has been approved by the BoD" (p.201).

Reference: page 147

Back-filled from ESRS 2 IRO-1 and the E1 climate DMA subsection, where this content is disclosed in the FY2025 report (pages 146-153). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risks are classified explicitly. Physical risks are split into acute and chronic, and transition risks into "Policy and Legal", "Technology", "Market" and "Reputation" (pp.149-150).

Two scenarios were run, for the second consecutive year. For transition risk, "the NGFS Net Zero 2050, NGFS Low Demand, and IEA Net Zero Emissions by 2050 (NZE2050) scenarios were used as references"; for physical risk under low emissions, IPCC SSP1-2.6, described as "~1.7 degrees C by mid-century (2041-2060, as a proxy for 2050); ~1.8 degrees C by 2100". The High Emissions scenario uses IPCC SSP5-8.5, "approximately ~2.4 degrees C by mid-century... and ~4.4 degrees C by 2100" (pp.147-148). Both temperature projections are stated, which is often missing elsewhere.

Scope is quantified: "The exposure analysis examined 545 assets", harmonised to "a common spatial resolution of approximately 10-12.5 km" and reported at EU NUTS level 2 or 3 (p.149). Time horizons are 2026, 2027-2030 and 2031-2050.

Assumptions are tabulated by driver (policy, technology, energy consumption, energy mix, energy prices, environment, economy) for each scenario (p.148).

Reference: page 203

Back-filled from the ESRS E1 SBM-3 subsection "Resilience of Strategy and Business Model", where this content is disclosed in the FY2025 report (pages 203-204). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Scope covers all commercial activities, "The three refineries and two power generation units", and corporate infrastructure including headquarters, and "extends across HELLENiQ ENERGY Group's operations (545 assets) in various geographic locations, with more detailed analysis within a 10-kilometer radius during the reporting period" (p.203).

Results and uncertainty are both disclosed. "The main uncertainties relate to the pace and stringency of climate policy implementation and the severity of physical climate hazards affecting the Group's infrastructure", and "According to the resilience analysis, all critical facilities are resilient to climate-related risks associated with water stress and extreme weather events" (p.204).

On capacity to adjust, the Group says scenario analysis "provides the basis for assessing the resilience of existing assets, potential needs for asset upgrades or reconfiguration, and possible future adaptations in products, services, and workforce skills", and that integrating climate risk into governance "supports the business's ability to maintain access to financing at an affordable cost of capital over time" (p.204).

Reference: page 205

The Sustainability Policy is the instrument for climate mitigation, adaptation and energy efficiency. It "guides the implementation and continuous improvement of the Environment and Energy Management Systems, based on international standards (ISO 14001 and ISO 50001, respectively)" and is tied to the objective of climate neutrality by 2050 (p.205).

Scope and accountability are stated: the Policy applies "across all Group activities, both in Greece and abroad, covering all employees without exception". Final responsibility for approval and implementation rests with the Group CEO, with oversight by the Sustainability Committee, and the Policy is published on the corporate website. It "was approved by the CEO of HELLENiQ ENERGY Group and the Sustainability Committee on 29 March 2024" (p.205).

The eight IROs the Policy addresses are listed, and they map to the DMA output: two positive impacts (investments in renewables, sustainable fuels and low-carbon technologies; promotion of sustainable fuels, hydrogen and e-mobility infrastructure), two negative impacts (Scope 1 and 2 emissions from refining and marketing; Scope 3 emissions from use of sold products, purchased goods and services, and transportation), physical risks from wildfires, floods, heatwaves, sea-level rise and water scarcity, transition risks from EU ETS carbon pricing and regulatory and technological change, and two opportunities in low-carbon investment and energy efficiency (p.205).

Reference: page 206

Actions are set out lever by lever. Research projects (ECOLEFINS, STEROPE, COCPIT) and the e-mobility and SAF programmes run on pages 207-208.

Renewable energy production and storage: 506 MW operational in Greece, Cyprus and North Macedonia against a pipeline of roughly 6 GW; second largest photovoltaic operator in Greece with 354 MW installed, 99 MW of wind in Greece and 41 MW of photovoltaics in Cyprus. "The Group's strategic investment in RES already has a significant environmental impact, with total avoided CO2 emissions since 2013 exceeding 1,300,000 tons, of which approximately 255,000 tons are expected in 2025 alone", and "investments in RES projects exceeded EUR 175 million" in the year (p.206).

Energy efficiency work is itemised: a new high-efficiency heat exchanger at Aspropyrgos commissioning in 2026, an energy saving project on the crude and naphtha desulphurisation units, cooling tower start-up optimisation at the Enerwave Thessaloniki plant, and a three-year LED and air-conditioning replacement programme at Thisvi and Thessaloniki (pp.209-210).

Two limits are disclosed: "HELLENiQ ENERGY Group has not yet implemented nature-based solutions (NbS)" (p.208), and Enerwave's emissions "have not yet been incorporated into the Group's emissions targets", with integration expected in 2026 (p.210). The climate change adaptation action plan "is currently underway and is expected to be completed within the next year" (p.206).

Reference: page 211

Two 2030 targets are set against a 2019 base year: "Reducing Scope 1 and 2 emissions (market-based) by 30% compared to base year 2019 through energy use optimization and the application of innovative GHG emission reduction technologies in refining activities", and "2 GW of installed capacity (with an interim target of 1.5 GW of operational capacity by 2028), aiming at an additional CO2 emissions reduction of more than 20%" (p.211). The 30% target equates to 1,300 ktCO2 (p.209), and the split is disclosed: "42% of the target relates to Scope 1 GHG emissions, while 58% relates to Scope 2" (p.211).

Science-based alignment is addressed head on: "energy companies deriving more than 50% of their revenues from oil and natural gas activities are not yet in a position to set science-based targets. In the absence of mandatory sector-specific guidance from the SBTi, the Group has not formally established science-based emission reduction targets, as the relevant sectoral guidance has not yet been finalized, therefore, full alignment with a 1.5 degrees C temperature pathway is not substantiated" (p.211).

Progress against the base year is withheld, with a reason: "The change in the organizational perimeter makes current year's (2025) results non-comparable with the base year (2019). Therefore, no comparison with the base year is provided... The comparison will be available after the target has been revised based on the new organizational scope" (p.211).

Reference: page 211

Marked "Voluntary" in the ESRS content index (p.159) but disclosed in full.

Total energy consumption was 17,170,370 MWh in 2025 against 15,208,669 MWh in 2024, of which HELLENiQ PETROLEUM S.A. accounted for 14,296,050 MWh and subsidiaries 2,874,320 MWh (p.211). The mix: fossil sources 16,772,135 MWh, nuclear 4,135 MWh and renewable 394,320 MWh, giving shares of 97.7% fossil, 0.0% nuclear and 2.3% renewable. The renewable share moved only from 2.2% to 2.3% year on year (p.212).

The fossil breakdown is given by fuel: crude oil and petroleum products 12,384,570 MWh, natural gas 3,880,175 MWh (up from 1,317,815 MWh, reflecting Enerwave consolidation), no coal, and purchased electricity, heat, steam or cooling from fossil sources 507,390 MWh (pp.212-213). Production is also split: non-renewable energy production 206,921,565 MWh and renewable energy production 780,665 MWh (p.213).

Energy intensity in high climate impact sectors rose 24.0%, from 1.19 to 1.48 MWh per thousand euros of net revenue, on net revenue from those sectors of EUR 11,611,246 thousand, down 9.0% (p.213). The reconciliation to the financial statements is shown: EUR 11,611,246 thousand from high climate impact sectors plus EUR 3,397 thousand from other activities equals total net revenue of EUR 11,614,643 thousand (p.214).

Reference: page 214

Scope 1 was 4,228,665 tCO2e in 2025 against 3,976,553 tCO2e in 2024, a 6% rise, on a 2019 base of 3,378,379 tCO2e. HELLENiQ PETROLEUM S.A. fell 7% to 3,673,158 tCO2e while subsidiaries rose from 11,934 to 555,507 tCO2e on Enerwave consolidation (p.214). By substance: CO2 4,218,963 t, CH4 1,570 t, N2O 4,666 t, HFCs 3,465 t, and no PFCs, SF6 or NF3. Verification is disclosed: "The verified CO2 emissions 2025 are 4,204,779 tn, corresponding to 99% of the overall Scope 1 emissions" under EU ETS Regulations 2018/2067 and 2018/2066, on an operational control boundary (p.214).

Scope 2 market-based fell 24% to 199,449 tCO2e (2019 base 839,827); location-based was 293,133 tCO2e, down 12% (p.215). Guarantees of Origin covered 21% of Scope 2 (p.215).

Scope 3 was 53,876,681 tCO2e, up 5%. Category 11, use of sold products, dominates at 43,037,926 tCO2e, followed by category 1 purchased goods and services at 8,050,851 tCO2e and category 10 processing of sold products at 1,062,203 tCO2e (pp.215-216). Data quality is stated bluntly: "The percentage of GHG Scope 3 calculated using primary data obtained from suppliers or other value chain partners is 1%" (p.216).

Total GHG emissions were 58,304,794 tCO2e market-based, up 4.77%, and 58,398,479 tCO2e location-based, up 4.80%. Intensity was 5.020 tCO2e per thousand euros market-based and 5.028 location-based, reconciled to the net revenue in the financial statements (p.217).

Reference: page 217

Marked "Voluntary" in the ESRS content index (p.159) but disclosed with figures.

The Group applies an internal carbon price "in the context of a shadow price", with four stated objectives: "a) Drive energy efficiency b) Drive low-carbon investment c) Identify and seize low-carbon opportunities and d) Stress test investment" (p.217).

Coverage is quantified: "For 2025, 99% of Scope 1 (4,204,779 tnCO2) and 83% of Scope 2 missions (166,118 tnCO2e) are covered by the abovementioned internal pricing scheme, while gross Scope 3 emissions are not covered by internal carbon pricing scheme" (p.217). The price is uniform across all business activities and entities.

Two factors set the level: "the alignment with the price of allowances under the Emissions Trading System and the impact on business decisions". The price feeds the linear programming model for production planning, energy efficiency project appraisal and fuel selection in the production process. The Group applies a range rather than a point estimate and runs sensitivity analysis, noting the range "is temporally variable, as it also depends on market developments and forecasts, taking into account the applicable regulatory framework" (p.217). No reconciliation to the financial statements is provided, "as only actual prices are reflected there".

Reference: page 218

Disclosed qualitatively under the phase-in relief. The Group applies "the phase-in reliefs provided under the ESRS Quick Fix Delegated Act, applying the gradually introduced disclosure requirements as outlined in Annex C of ESRS 1" and so "submits only qualitative disclosures regarding the expected financial effects of IROs related to the material topics" (p.138).

The position taken is that no adjustment is expected: "Based on HELLENiQ ENERGY 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" (p.218).

On physical risk the conclusion is stated flatly: "No assets of HELLENiQ ENERGY Group are at material physical risk in accordance with the outcomes of the resilience analysis performed" (p.218), and "There are no significant amounts of assets or net income subject to significant physical or transitional risks".

Opportunities are cross-referred to the ESRS 2 climate opportunities table, which covers "the development and expansion of low emission goods and services in the medium-term time horizon and the participation in carbon market, including voluntary market and ETS 2 in the short-term time horizon" (p.218). No monetary amounts are given for either risks or opportunities.

Reference: page 219

Pollution is handled through the Sustainability Policy, which "outlines the Group's commitments regarding emissions and waste throughout its value chain", with management systems applied across all activities and preventive and control measures for air, water and soil (p.219).

The policy section is explicit that substances of concern sit outside the material IROs: the Group "closely monitors relevant legislation concerning substances of concern and substances of very high concern, ensuring compliance, minimizing their use, or, where required, phasing them out in its operational activities. This practice constitutes a compliance process and is not associated with any recognized material IROs" (p.219).

The material impacts identified through the DMA are named: "Non-GHG emissions from fuel use by end-users" and "Non-GHG emissions from refining activities" (p.219). Alongside them the Group records "the medium- and long-term risks posed by natural disasters and malicious threats, which could lead to industrial accidents with impacts on air, water, and soil pollution", with financial and reputational consequences.

Review, approval and monitoring of the Policy fall to the Group's Sustainability Committee, and the Policy provides the framework for the Health and Safety, Environment and Energy management systems, supported by control, inspection and certification processes (p.219).

Reference: page 220

Two named actions are disclosed with an outcome attached to the first. An Electrostatic Precipitator was installed on the stack of the catalytic pyrolysis unit at the Aspropyrgos refinery, "operational since 2022, and to date has contributed to the total 43% reduction in Particulate Matter 10 micrometers (PM10) emissions from this refinery" (p.220).

The second is investment in advanced production technologies: "maximizing the use of gaseous fuels, utilizing fuels with higher environmental specifications, investing in modern production technologies, and recovering volatile organic compounds (VOCs) during product loading" (p.220).

Air emissions monitoring is continuous "in accordance with the terms of the Environmental Permit for each facility", with a large portion of facilities carrying continuous monitoring systems whose data are analysed and submitted to the authorities.

Two limits are stated rather than left implicit. "The Group has not implemented additional initiatives due to the absence of a specific quantitative target for pollution reduction", and "The Group has not yet adopted actions related to pollution in the downstream phase of the value chain, as no material environmental issues or regulatory requirements necessitating immediate intervention have been identified to date" (p.220). This is a candid statement given that one of the two material impacts is non-GHG emissions from fuel use by end-users, which sits downstream.

Reference: page 220

The Group discloses that it has set no quantified pollution targets, and says why. Continuous reduction of SO2, NOx, particulate matter and VOCs is described as "a primary objective and commitment", but "Due to the nature of HELLENiQ ENERGY Group's operations and the industry in general, there is no direct operational control over emissions related to the products. Therefore, the Group has not set specific, time-bound targets for the aforementioned atmospheric emission indicators" (p.220).

In place of a target, the approach rests on "full compliance with applicable legal and regulatory frameworks, adherence to all relevant environmental standards and limits, and continuous improvement", including Best Available Techniques in refining and the European Industrial Emissions Directive, with certified environmental management systems across all operations. The Group adds a point that bears on whether a target was required: "It should be noted that the legislation does not prescribe any pollution-related targets" (p.220).

Effectiveness is tracked instead of targeted. At the three refineries the objective is to select the most appropriate internal fuel blend within permit limits and BAT, and the Group "monitors the effectiveness of its policies and actions related to pollution management through internal environmental performance assessment processes, such as the continuous measurement and monitoring of specific atmospheric pollutant levels" (p.220).

Reference: page 221

Air and water pollutants are tabulated for own operations with prior-year comparatives (pp.221-222).

Air, total reporting group, 2025 against 2024: SOx/SO2 2,861 t against 2,973 t, down 4%; NOx/NO2 2,530 t against 2,561 t, down 1%; PM10 115 t against 121 t, down 5%; NMVOC 1,544 t against 1,607 t, down 4%. Heavy metals and benzene are itemised: Ni 3.440 t (down 23%), Zn 3.816 t (down 49%), benzene 12.431 t (down 9%), Hg 0.125 t (up 71%), Pb 0.580 t (up 76%), Cd 0.154 t, As 0.043 t, Cr 0.206 t, Cu 0.361 t, and HCN 4.63 t reported for the first time.

Water: TOC 109.89 t (up 19%), phenols 2.85 t (up 33%), Zn 0.43 t, Ni 0.14 t, As 0.07 t, Hg 0.0014 t (p.222).

Soil is addressed with a nil return: "the Group's industrial facilities do not cause any releases to the soil" (p.221).

On the E-PRTR datapoint the Group states that "For other air pollutants listed in Annex II of Regulation (EC) No 166/2006, no exceedances of the reference limit values were observed" and the same for water (pp.221-222). Scope is defined: no subsidiary falls within Regulation 166/2006 except HELLENiQ PETROLEUM S.A. and Enerwave. Methods are named, including CONCAWE Report 3/15 factors for subsidiary air emissions and specific laboratory methods per water pollutant (APHA 5220D, ICP-MS, LCK 345), with no methodology change year on year (p.222).

Reference: page 222

Disclosed qualitatively under the ESRS 1 Annex C phase-in the Group applies (p.138), and listed in the ESRS content index with a section reference but no datapoint list (p.159).

The short-term position is a nil return: "No incidents were recorded in 2025 in which pollution has, or is expected to, negatively affect the cash flows, financial position, or financial performance of HELLENiQ ENERGY Group over the short-term time horizon" (p.222).

For the longer horizons the Group names the risk it carries: "According to the DMA, in the medium- and long-term time horizons, the risk of environmental accidents has been identified, including those arising from extreme natural events, such as oil spills or pollution of air, water, and soil. Such events could disrupt production operations and cause significant financial losses, including damage to assets, increased insurance premiums, and impacts on the Group's reputation" (p.222).

No monetary amounts, no expected expenditure and no provision figures are attached, which is consistent with the qualitative-only relief the Group invokes but leaves the reader without any sizing of the exposure.

Reference: page 223

Water became material for the first time in the 2025 DMA (p.138). The Sustainability Policy is the governing instrument, focused on "the sustainable and rational management of water and marine resources" (p.223).

Three IROs are named, one of each type. The negative impact: "HELLENiQ ENERGY, as a group with downstream oil activities, requires significant water use, particularly during refining." The positive impact: "The Group operates desalination units and is exploring further implementation, providing a sustainable water source for industrial operations, by replacing freshwater withdrawals with desalinated water." The risk: "Water scarcity can significantly increase operational costs, as water is essential for refining processes. In areas of high water stress or seasonal fluctuations, challenges may arise that may require adjustments to production planning" (p.223).

The Policy covers control, monitoring and pollution-prevention mechanisms and efficient use and conservation of water "across all its operational activities and along the value chain", together with "cooperation policies with suppliers and other stakeholders for the management of high-risk areas" aligned to best available technologies and regulatory requirements (p.223).

Reference: page 223

Wastewater treatment: three-stage units at the refineries provide continuous protection of water resources, and "The upgrade program of the Wastewater Treatment Unit at the Aspropyrgos refinery was completed during 2025" (p.224). Water consumption is monitored through flow meters across all activities, which the Group says supports identification of inefficient use and prioritisation of investment.

Desalination: at the Aspropyrgos refinery "a portion of water demand is met through a desalination plant", reducing dependence on freshwater resources (p.224).

Seawater cooling intake at Enerwave's Thessaloniki power plant: phase one began in 2023 with a variable frequency drive on the seawater pumps, and "Further projects are underway to upgrade the system, which are expected to be completed by 2026" (p.224).

Feasibility study: in 2025 the Group examined "the need for gradual independence from fresh water for the Aspropyrgos and Elefsina refineries", assessing seawater, treated refinery effluent and reuse of effluent from neighbouring wastewater treatment plants, with techno-economic analysis and siting requirements. "In 2026, a similar study will be carried out for the Thessaloniki refinery", followed by basic design (p.224).

Context on exposure is given: "99% of total water consumption originates from facilities in Greece, which are located in areas identified as high water-stress regions according to the WRI assessment" (p.223).

Reference: page 225

Total water consumption was 7,155,093 m3 in 2025 against 8,468,614 m3 in 2024, down 16%, of which HELLENiQ PETROLEUM S.A. accounted for 6,673,912 m3 and subsidiaries 481,181 m3. Consumption in areas at water risk was 7,088,577 m3 against 8,302,891 m3 (p.225).

Water recycled and reused was 2,225,932 m3, down 17%, and "the proportion of water recycled and reused within the production facilities reached 13%" (p.225). Stored water is disclosed at 33,622 m3, mainly fire safety tank filling, measured at year end.

Intensity is given both years: "In 2025, total water consumption across the Group's operations amounted to 7,155,093 m3, resulting in a water use intensity of 616 m3/EUR million. In 2024, total water consumption... amounted to 8,468,614 m3, resulting in a water use intensity of 663 m3/EUR million" (p.226).

Withdrawals and discharges are also reported: total discharge 10,346,570 m3 with "over 96% being discharged into the sea after treatment", against 7,229,408 m3 in 2024; total withdrawal 17,501,663 m3 "of which 71% came from the public water supply network", against 15,698,162 m3 with 84% from the network in 2024 (p.226).

Consumption and withdrawal data come from flow meters and invoices, and subsidiary discharge is estimated from sewerage-fee percentages of 73%-80% (p.226). One inconsistency worth noting: the narrative says consumption "increased by 16%" while the table shows a 16% decrease (p.225).

Reference: page 226

Disclosed qualitatively under the phase-in relief, and listed in the ESRS content index with a section reference but no datapoint list (p.160).

The short-term position is nil: "Based on the DMA results, no financial impacts are expected in the short term from the material risks and impacts identified related to water and marine resources" (p.226).

For the longer horizons the Group names the mechanism: "In the medium- and long-term time horizon, the risk of limited water availability has been recognized, which could cause operational interruptions affecting the scheduling of refining processes, potentially leading to reduced production and, consequently, lower revenues for the Group" (p.226).

That chain, water scarcity to production scheduling to revenue, is consistent with the risk described in E3-1 (p.223) and with the resilience analysis conclusion that "all critical facilities are resilient to climate-related risks associated with water stress and extreme weather events" (p.204). No monetary amount, sensitivity or range is attached to the exposure.

Reference: page 227

Voluntary. The Group flags this in a footnote: "According to the DMA, no material IROs were identified in relation to Biodiversity and Ecosystems (ESRS E4). Thus, the related disclosures are provided on a voluntary basis and selectively cover specific disclosure requirements of the standard, in line with the Group's existing policies and procedures" (p.227). The index marks the row "Voluntary: ESRS E4-2-22" (p.160).

Biodiversity is covered within the Sustainability Policy rather than a standalone policy. "Prior to the implementation of any project, the Group conducts a detailed assessment of environmental risks and biodiversity-related requirements, adopting sustainable land and water management practices that ensure the conservation of ecosystems and species" (p.227).

Implementation runs through trained personnel working "In collaboration with experts and partners in the fields of safety and environmental protection", who "ensure continuous monitoring and compliance with procedures related to safety, biodiversity, and overall environmental protection" (p.227). Minimum disclosure requirements for the Sustainability Policy are cross-referred to the ESRS E1 chapter.

The Group does not claim a policy addressing deforestation, sustainable oceans and seas practices, or sustainable land and agriculture practices as separate commitments; the Appendix B datapoints table lists ESRS E4-2 24(b), (c) and (d) among the SFDR-derived datapoints (p.164).

Reference: page 227

Voluntary, on the same basis as E4-2. The index marks the row "Voluntary: ESRS E4-3-28-(c)" (p.160).

Siting is disclosed with specifics. "The Group operates 68 photovoltaic and wind farms, some of which are located within or near areas of high ecological sensitivity", including Special Protection Areas, parts of the Natura 2000 network, and named wildlife refuges "K408 Pateras (Mandra)", "K132 Labanitsa (Ardassa-Vlasti)", "K147 Anthotopos-Skiti Sideron", "Dovra-Valta" and "K753 Pylaia-Kavissou-Feron", plus Important Bird and Biodiversity Areas such as the "Southern Evros Forest Complex - South Mani" (pp.227-228). In Cyprus, photovoltaic parks sit in habitat of three vulnerable species listed in the Red Book of the Flora of Cyprus.

Monitoring results are given: "The Group monitors two species of birdlife in the SPAs. For the first species, its presence and reproductive activity within the SPA have not been documented, while for the second species, the number of breeding pairs exceeds the conservation target of 8 pairs", with data submitted annually to the Ministry of Environment and Energy (p.228).

Land management is quantified at the Kozani photovoltaic complexes (204 MW and 110 MW), where "the fences have been designed with a distance of 10-15 cm from the ground, allowing small animals to move freely" and "25% of the total area of 0.4 km2, which was previously unused, was made available as grazing land for local livestock farmers" (p.228).

Reference: page 230

Voluntary. The footnote to the E5 chapter states: "According to the DMA, no material IROs were identified in relation to Resource Use and the Circular Economy (ESRS E5). Thus, the related disclosures are provided on a voluntary basis and selectively cover specific disclosure requirements of the standard, in line with the Group's existing policies and procedures" (p.230). The index marks the row "Voluntary: ESRS E5-1-14, ESRS E5-1-15" (p.160).

The Sustainability Policy "focuses on preventing and reducing waste throughout the value chain, as well as on the optimal use of natural resources, while ensuring full compliance with applicable legal and regulatory requirements", and ties measurable targets assessed against best practice to progress in circular economy and waste management (p.230).

On procurement and materials the Group states that it "systematically incorporates circular economy principles into its procurement and marketing processes, as well as throughout the value chain", that it "constantly explores ways to reduce the use of primary resources and raw materials, while prioritizing the use of recycled materials", and that it implements sustainable procurement practices for responsible sourcing along the value chain (p.230). Minimum disclosure requirements for the Policy are cross-referred to the ESRS E1 chapter.

Reference: page 230

Voluntary, on the same basis as E5-1. The index marks the row "Voluntary: ESRS E5-2-19" (p.160).

Three action areas are disclosed. Sustainable waste management: "In 2025, there was a 42% increase in waste production compared to the previous year, which was accompanied by a high recovery rate, thanks to the implementation of improved recycling and recovery practices at the Group's facilities. In total, more than 35,000 tons of waste (over 92% of the total) were either reused, recycled, or used for raw material recovery. Hazardous waste accounts for the majority of the total volume and is almost entirely recovered before being sent for final disposal" (p.230). Volumes per facility are driven mainly by tank cleaning and vary with maintenance planning.

Municipal solid waste management: source separation of paper, plastic, batteries, accumulators, fluorescent lamps, electronic equipment, aluminium, metal and organic waste, continued in 2025 at the Aspropyrgos and Elefsina industrial facilities (p.231).

Recovered raw material: "in 2025, 218.8 ktn of oil were recovered, while in total, since 2013, more than 2.24 million tons have been re-refined", covering oily waste from both the production process and third parties returned as feedstock for re-refining (p.231).

Reference: page 231

Voluntary. The index marks the row "Voluntary: ESRS E5-3-23, ESRS E5-3-24-(e), ESRS E5-3-27" (p.160).

Two targets are stated. Waste: "The Group aims to reduce waste going to final disposal or incineration to 15% or less by 2030, prioritizing prevention, reuse, and recycling in accordance with the waste hierarchy" (p.231). Sustainable fuels: "a strategic target has been set for the production of over 140 kta of sustainable fuels, combining output from the biodiesel production unit through the reuse of cooking oils at the Thessaloniki refinery and the development of a new standalone SAF production unit at the Aspropyrgos refinery" (p.232).

Provenance is disclosed. The waste target "is a Group initiative and does not stem from legislation", and "By voluntarily setting this target, the Group recognizes the critical role of sustainable waste management and minimization of primary raw materials, as well as the sustainable sourcing and use of renewable resources" (pp.231-232). Setting involved internal teams, industry experts and external consultants.

Governance is assigned: "The Sustainability Committee of the BoD oversees the establishment of relevant targets, ensuring effective monitoring of waste, products, and materials management throughout their entire lifecycle" (p.232). Progress against the 15% waste target is not quantified for 2025 in this section, though the E5-5 table shows 2,873 t destined for final disposal against 38,869 t generated.

Reference: page 232

Voluntary. The index marks the row "Voluntary: ESRS E5-4-30, AR 21, ESRS E5-4-32, AR 25" (p.160).

Inflows are quantified for the refining feedstock, which is the dominant material: "The main inputs are crude oil and other hydrocarbons (as raw materials for processing), accounting for over 86% of all materials or resources used at Group level and originating from non-renewable sources. For the year 2025, the quantity of crude oil amounts to 14,225 ktn, while crude oil together with other unit feedstocks amounts to 17,836 ktn for the Group's three refineries (HELLENiQ PETROLEUM S.A.)" (p.232).

Method is stated: "The calculations include data obtained from direct measurements, ensuring that double counting by the Group is avoided" (p.232).

The disclosure names the material and gives the tonnage and the non-renewable share, but does not break the inflows into biological versus technical materials, does not give a secondary or recycled content percentage, and does not extend beyond the three refineries to the rest of the Group. That is consistent with the selective voluntary basis the chapter footnote sets out (p.230).

Reference: page 233

Voluntary. The index marks the row "Voluntary: ESRS E5-5-37-(a), (b), (c), (d), ESRS E5-5-38-(a), (b), ESRS E5-5-39, ESRS E5-5-40" (p.160).

Outflows are presented as a full waste-stream table for the total reporting group (p.233). Total waste generated was 38,869 t against 27,465 t in 2024, up 41%, of which hazardous 22,763 t (up 26%) and non-hazardous 16,106 t (up 70%).

Diverted from disposal: 35,996 t against 24,017 t, up 50%. The split is recycling hazardous 15,063 t, recycling non-hazardous 5,370 t, recovery hazardous 7,277 t, recovery non-hazardous 8,205 t and reuse hazardous 80.98 t.

Destined for final disposal: 2,873 t against 3,448 t, down 17%, comprising landfill or thermal desorption 7.23 t hazardous and 2,381 t non-hazardous, incineration 103 t hazardous and 5.73 t non-hazardous, and other disposal 231 t hazardous and 145 t non-hazardous.

Composition and method are given: "Waste classification was carried out in accordance with the European Waste Catalogue of Commission Decision 2014/955/EU, using the first level of categories. The data are based on direct measurements. The main materials found in waste include catalysts, metals, oily sludge, and oily waste" (p.233). A nil return closes the section: "no radioactive waste was produced by HELLENiQ ENERGY Group in 2025".

The Group does not disclose recyclable content of products and packaging or expected durability, so this is a waste-side outflow disclosure rather than a full E5-5 return.

Reference: page 233

Waste is disclosed inside E5-5 on a voluntary basis, with prior-year comparatives and hazard split (p.233).

Total waste generated rose 41% to 38,869 t (2024: 27,465 t), of which HELLENiQ PETROLEUM S.A. produced 31,590 t and subsidiaries 7,279 t. Hazardous waste was 22,763 t, up 26%, and non-hazardous 16,106 t, up 70%. The E5-2 narrative attributes the rise to the fact that "The quantities of solid waste per facility are mainly determined by tank cleaning and vary annually depending on maintenance planning and the availability of treatment units" (p.230).

Diversion performance is high: 35,996 t diverted from disposal against 2,873 t destined for final disposal. The Group summarises it as "more than 35,000 tons of waste (over 92% of the total) were either reused, recycled, or used for raw material recovery. Hazardous waste accounts for the majority of the total volume and is almost entirely recovered before being sent for final disposal" (p.230).

Two nil returns are given: no radioactive waste was produced in 2025 (p.233), and the non-recycled waste and hazardous and radioactive waste datapoints are listed against ESRS E5-5 37(d) and 39 in the Appendix B table (p.164).

The Group's 2030 target is expressed against this metric: reduce waste going to final disposal or incineration to 15% or less (p.231).

Reference: page 237

Four policy instruments are set out. The Sustainability Policy covers a safe working environment and alignment with the UN Guiding Principles on Business and Human Rights, with supplier contracts carrying "specific clauses requiring compliance with the principles of the United Nations Global Compact" (p.237).

The Code of Conduct, revised in 2025, "applies to all activities of the Group, and is translated into the languages of the countries in which it operates", covering Board members, permanent and temporary employees, senior management, retained lawyers, seconded employees and third parties. Breach "may lead to disciplinary action... and may include termination of the contractual relationship" (p.237). The Compliance Department is responsible for application and investigation.

Occupational Health and Safety Management Systems cover employees, executives, management and all service providers, including "upstream and downstream of the value chain", with risk assessments, training, safety protocols and emergency response (p.238).

The Policy on Combating Violence and Harassment at Work has applied since 2022 under Law 4808/2021. The Group states it "does not tolerate sexual or any other form of harassment" and that "no Group employees have been identified as belonging to vulnerable groups; therefore, no specific policy commitment exists in this regard" (p.238).

Reference: page 239

Engagement runs through organised labour and direct channels. "The Group actively supports employee participation through seven (7) representative trade unions, which collaborate in shaping the CBAs of each company", with "regularly scheduled meetings with the Health and Safety Committees every 3-4 months" (p.239).

Channels are itemised: presentations, newsletters and corporate announcements covering health and safety and other material topics, daily information through the intranet, dedicated events and awareness campaigns, and "A digital suggestion box allows employees to submit comments, questions, or ideas anonymously" (p.239).

Accountability is named: "The ultimate responsibility for promoting and maintaining effective employee relations rests with the Group Human Resources and Administrative Services General Director" (p.239).

Two limits are disclosed rather than glossed. "The Group does not have specific agreements with workers' representatives related to the respect of human rights of its own workforce" (p.239). And on particularly vulnerable groups: "based on the assessment of occupational risks and the overall analysis of factors affecting the main impacts on working conditions, no group of workers appears to be particularly exposed to these impacts" (p.239).

Effectiveness is tracked by monitoring the volume and content of suggestions and reports and analysing feedback "to identify trends or areas that need attention" (p.239).

Reference: page 239

Two systems run in parallel. Health and safety incidents follow the internal directive "Reporting and investigation of health, safety and environmental incidents", covering "the entire cycle of recording, evaluating, monitoring, and controlling such incidents". The year's outcome is stated: "In 2025, no complaints related to health and safety issues were submitted" (p.239).

More general concerns go to the Regulatory Compliance Office, which "is responsible for examining the credibility of complaints with absolute confidentiality and discretion" and, where a report is valid, recommends corrective and remediation measures, working with Internal Audit or Human Resources where a fuller investigation is needed (pp.239-240).

Access is described concretely: complaint mechanisms via the intranet, designated email addresses, online forms and "physical 'suggestion boxes' located at certain facilities". Reporting procedures are formally integrated into the ISO 45001 certified occupational health and safety management systems (p.240).

Whistleblower protection is anchored in law: "in compliance with Law 4990/2022, which provides for the protection of persons who report violations of European Union law, the Group has established the aforementioned Whistleblowing Policy since 2024", and "The protection framework applies even if the reports submitted are not confirmed after investigation and, in any case, provided that the report is not malicious" (p.240).

Reference: page 240

Prevention rests on "procedures for the safe design and operation of equipment, with continuous monitoring through KPIs", and the Group "cooperates with the European organization CONCAWE and participates in annual surveys and comparative assessments to evaluate the effectiveness of Health and Safety actions" (p.240). Emergency preparedness drills and training extend to partners as well as employees.

Training volume is disclosed: "In 2025, the Group delivered over 140,000 hours of training, covering areas such as H&S, environmental management, digital transformation, and energy transition", including specialised programmes for refinery engineers and technicians, ESG and sustainability seminars, leadership development and e-learning on safety, ethics and regulatory compliance. These "primarily benefit the Group's employees, while also supporting non employees and subcontractors who take part in training and preparedness exercises" (p.236).

The Group also states that Human Resources and Procurement "systematically monitor potential risks of forced or child labor, both within internal operations and across the supply chain", and has "not identified any activities or geographic areas within its own operations that present a significant risk of incidents of forced or child labor", with enhanced monitoring applied across the supply chain (p.236).

Reference: page 244

Training: "an annual target has been established concerning the average number of training hours per participant, which is required to exceed the average total training hours recorded over the previous three (3) years" (p.244).

Retention: "a target to maintain the voluntary turnover rate below 4% has been set, which is set as the median value for a six-year period (2020-2026, for this year)" (p.244).

Gender: "a target has been set to increase the number of women in management positions by 15% by 2026, setting 2023 as the base year, when the average percentage of women in positions of responsibility in the Group (at management level) was 22.39%" (p.244).

Safety, to 2030, benchmarked against CONCAWE, with honest reporting of a miss: the Process Safety Event Rate target is second-quartile ranking and "For 2025, like 2024, the Group's performance falls within the second quartile"; the Lost Workday Incident Frequency target is also second quartile but "For 2025, the Group's performance falls within the third quartile, while during 2024 it was within the second quartile" (p.244).

Systems: "100% Implementation Rate of the Holistic Safety Management System in all Group facilities, both in Greece and abroad", currently applied to the majority of Greek facilities with international rollout to follow. Standing targets of zero fatalities and zero serious industrial accidents remain in effect continuously.

Reference: page 245

Headcount at 31 December 2025 was 4,192, against 3,734 in 2024: 3,258 male and 934 female, compared with 2,965 and 769 (p.245). By contract, permanent employees numbered 4,101 (917 female, 3,184 male) and temporary employees 91 (17 female, 74 male), with no non-guaranteed hours employees (p.246).

Greece is the only significant geography: "The Group maintains a substantial workforce in Greece, comprising 3,618 employees", against a definition that "a workforce segment is deemed significant if it consists of at least 50 individuals and represents more than 10% of the total employee population". Within the HELLENiQ PETROLEUM S.A. industrial facilities, "the majority of the workforce consists of men, with 2,041 male employees out of a total of 2,288 employees, due to the nature of the work" (p.245).

Turnover is disclosed both ways: "The total number of employees who left voluntarily or due to dismissal or retirement during the reporting period is 192, and the staff turnover rate is 4.7% during the reporting period, compared to 279 and 7.6% respectively in 2024" (p.246).

The year-on-year growth is explained rather than left unexplained: it is "primarily attributable to the incorporation of Enerwave as a wholly-owned subsidiary of the Group, as well as the establishment of two new companies, namely HELLENiQ Petroleum Trading S.A. and HELLENiQ Renewables Romania S.R.L." (p.245).

Reference: page 246

Non-employee workers are counted and their roles named. "The total number of non-employees of the Group for 2025 is 102, while for 2024 it was 94" (p.246), reported as headcount on an average basis over the reporting period.

The population is defined narrowly and the boundary is explained: the Group works with external staffing agencies "In order to cover temporary and seasonal operational needs at EKO and KALYPSO", and "The above number does not include individuals working under contracts or through external service providers, as well as those working on a service provision/service invoice basis, as according to Greek law, these employees provide independent services and not dependent work" (p.246).

Where those excluded workers sit is stated: "These employees can be counted in the category of employees in the value chain covered by ESRS S2 (nonmaterial issue according to the DMA). It should be noted that employees of third-party companies - external partners - are not controlled by the Group" (p.246). That is the clearest confirmation in the report that ESRS S2 was assessed and found not material.

Typical roles are given: "Tank truck drivers" and "Aircraft refueling drivers" assigned to contractor companies (p.247). No gender or contract-type breakdown of the 102 is provided.

Reference: page 247

Coverage is disclosed with a year-on-year fall: "The percentage of employees covered by collective bargaining agreements is 73.8% for 2025 and 81.3% for 2024" (p.247).

The agreements are counted and located: five within the European Economic Area (HELPE, EKO, DIAXON, ASPROFOS, EKO CYPRUS) and two outside it (OKTA, JUGOPETROL). In Greece, the Group's only significant EEA employment, coverage is 76%. Outside the EEA, coverage is "92%" in the Republic of North Macedonia and "100%" in Montenegro (p.247).

Workplace representation is also reported and also fell: "The percentage of employees covered by employee representatives in Greece in 2025 is 74%, compared to 80% in 2024" (p.247).

A nil return closes the section: "So far, there has been no agreement with the Group's employees on representation through a European Works Council (EWC), European Company (SE) Works Council or European Cooperative Society (SCE) Works Council" (p.247).

A banded table places Greece in the 60-79% range for both collective agreement coverage and workplace representation in 2025, having sat in the 80-100% band for coverage in 2024 (p.247). The report does not explain the drop in either measure.

Reference: page 248

Gender at top management is disclosed and moved the wrong way: female 3 (9%) in 2025 against 4 (11%) in 2024; male 32 (91%) against 32 (89%) (p.248). This sits against the S1-5 target to increase women in management positions by 15% by 2026 from a 2023 base of 22.39% (p.244), although the two use different populations.

Age distribution across the workforce: under 30 years 198 employees (5%), against 145 (4%) in 2024; 30 to 50 years 2,788 (66%), against 2,364 (63%); over 50 years 1,206 (29%), against 1,225 (33%) (p.248).

The definition of top management is given rather than assumed: "The Group's Senior Management is determined based on the organizational chart and includes all executives who are two levels below the administrative and supervisory bodies. Specifically, this includes the General Managers, the Directors of the main operating units (refining and domestic marketing), the Heads of the operating units, and any other person with a higher position than them" (p.248).

Board-level gender diversity is reported separately under GOV-1 at 2 women out of 11 members, or 18% (p.120).

Reference: page 248

A short, complete answer. "All Group employees receive salaries that exceed the minimum limits set by national legislation, collective bargaining agreements, and professional agreements, without any discrimination or differentiation between employees. This ensures that remuneration is adequate in all countries where the Group operates" (p.248).

The index lists the row as "Applicable: ESRS 2-S1-10-69, AR 72, AR 73, AR 74, 70" (p.161), so the Group treats both the adequate-wage benchmark and the country-level explanation datapoints as covered by this statement.

The disclosure is a positive assertion across the whole workforce rather than a breakdown by country or by employee category, so a reader cannot see the margin above the applicable benchmark in any market, nor which benchmark was used in each of the Group's countries of operation. Adequate wages sit alongside the collective bargaining coverage of 73.8% reported under S1-8 (p.247) and the pay gap of 19.22% reported under S1-16 (p.252).

Reference: page 248

Another full-coverage statement, with the risk categories enumerated: "All Group employees enjoy full social protection, either through public programs or through benefits offered by the Group. This coverage includes protection against loss of income due to illness, unemployment from the start of employment, accidents at work, disability, parental leave, and retirement" (p.248).

That list maps to the five events the disclosure requirement asks about, and the Group answers all five affirmatively for the whole workforce.

The index records the row as "Applicable: ESRS 2-S1-11-74, AR 75" (p.161). No country-by-country table is given, and no employee count is identified as lacking protection in any of the eleven or more jurisdictions in which the Group employs people, so the reader is relying on the blanket assertion rather than on disaggregated evidence.

Reference: page 248

The metric is given with a comparative and a rise: "The Group employs 39 employees with disabilities, ensuring full equality of opportunity in employment and training... In 2025, the percentage of employees with disabilities in the Group's workforce reaches 0.9%, compared to 0.3% in 2024" (p.248).

Method and legal basis are disclosed: "The Group employs persons with disabilities in accordance with the legal definitions of persons with disabilities in the countries in which it operates. This ensures compliance with regional labor regulations and guidelines for the inclusion of persons with disabilities" (p.248), and "There are no significant differences in the legal definitions of persons with disabilities between the countries where the Group operates" (p.249).

The three-fold rise year on year is reported without explanation, and the figure is not split by country or by gender. The Group's separate statement under S1-1 that "no Group employees have been identified as belonging to vulnerable groups; therefore, no specific policy commitment exists in this regard" (p.238) sits somewhat awkwardly beside the disclosure of 39 employees with disabilities.

Reference: page 249

Marked "Voluntary" in the ESRS content index (p.161) but reported with both required metrics and both genders.

Performance reviews: 99% of employees participated in regular performance and career development reviews in 2025, comprising 98% of female and 99% of male employees (p.249). The 2024 total is printed as 191, which is evidently a typographical error against the 93% and 98% shown for female and male in that year.

Training hours: the average fell across the board, from 40.7 hours per employee in 2024 to 33.6 in 2025, with female employees at 20.4 hours (2024: 29.4) and male at 37.4 (2024: 43.6) (p.249).

Two contextual points are given. Coverage: "for 2025, the training hours do not include the employees of the two new companies (HELLENiQ Petroleum Trading S.A. and HELLENiQ Renewables Romania S.R.L.)". Gender gap: "In industrial facilities, where the majority of staff are men, average training hours are slightly higher, reflecting the nature of the work and the safety and skill requirements it imposes" (p.249).

The Group states elsewhere that it delivered over 140,000 training hours in 2025 (p.236), and its S1-5 target requires average hours per participant to exceed the previous three-year average (p.244), against which the year-on-year fall is not commented on.

Reference: page 250

Coverage is complete: 100% of own workforce covered by the health and safety management system in both years. Fatalities are nil, both "in own workforce as result of work-related injuries and work-related ill health" and among "other workers working on undertaking's sites".

Injury performance worsened. Recordable work-related accidents rose from 18 to 26 at Group level, and the rate from 2.66 to 3.73. Days lost more than doubled, from 288 to 617. Recordable cases of work-related ill health were nil.

The Group explains the movement and gives the CONCAWE-benchmarked indicators: "In 2025, the Lost Workday Injuries Frequency (LWIF) and the All Injury Frequency (AIF)... increased by 63.8% and 11.4% respectively compared to the previous year. This increase is attributed to injuries of lower severity, considering also that the Lost Workday Severity index has significantly decreased in recent years and remains below the corresponding European index." Against that, "the Process Safety Event Rate (PSER), which is the main process safety indicator, decreased by 27.9% compared to the previous year, with its value falling below the corresponding European benchmark" (p.250).

The subsidiary column carries most of the deterioration, moving from 1 to 10 recordable accidents and from 0 to 299 days lost, consistent with Enerwave consolidation.

Reference: page 252

Entitlement is universal and take-up is disclosed by gender. "All employees (100%), regardless of gender, are entitled to take leave for family reasons. Categories of leave for family reasons include maternity leave, paternity leave, parental leave, and leave to care for relatives. In 2025, 12% of the Group's employees took leave for family-related reasons" (p.252).

The table gives both years: 100% entitlement for female and male employees in 2025 and 2024; take-up of 13% for female employees in both years, and 11% for male employees in 2025 against 9% in 2024 (p.252).

Method is stated: "To calculate the percentage of employees per gender who took family-related leave, the total number of employees per gender was taken into account for each denominator" (p.252).

The disclosure covers both datapoints the requirement asks for, entitlement and take-up, and splits them by gender. It does not break the figures down by leave type, so it is not visible from the disclosure how much of the take-up is maternity or paternity as against parental or carer's leave.

Reference: page 252

Marked "Voluntary" in the ESRS content index (p.161), but both required ratios are given with comparatives.

Gender pay gap: "In 2025, the gender pay gap within the Group is recorded at 19.22%, while in 2024 it was 23.35%" (p.252). The gap narrowed by just over four percentage points, though the Group frames its position as one in which "there are no differences or injustices in remuneration in any of the Group's companies".

Total compensation ratio: "The ratio of the annual total compensation for the organization's highest-paid individual to the median annual total compensation for all employees (excluding the highest-paid individual) within the Group is 30.68 for 2025, while in 2024 it was 28.41" (p.252). That ratio widened year on year.

The remuneration framework is described: a gender-neutral system based on annual evaluations under national and European equal pay law, and a Remuneration Policy for Board members "approved by the Extraordinary General Meeting of Shareholders on December 20, 2019, and updated, for second time, by a decision of the Annual General Meeting on June 27, 2024", splitting total annual gross remuneration into fixed and variable components against predefined measurable targets (p.252).

The report does not reconcile the stated absence of pay differences with the 19.22% gap, nor explain the movement in either ratio.

Reference: page 253

The disclosure is short and gives figures for each limb.

Discrimination: "For another year, the Group did not record any incidents of discrimination in its companies" (p.253). One other matter is disclosed: "There was one isolated incident involving behavior that was not in line with the Group's values and respect framework, for which the relevant investigation and management procedures were immediately activated and appropriate measures were taken, in accordance with the applicable regulatory and internal framework."

Complaints handling: "All reports submitted through internal channels or problem reporting mechanisms available to employees were successfully addressed with full respect for transparency, confidentiality, and fair treatment of all involved" (p.253).

Severe human rights impacts and remedies: "there were no serious human rights violations, such as forced labor, human trafficking, or child labor, and no fines, penalties, or compensation for related damages were imposed" (p.253).

The related GOV-4 due diligence section corroborates the fines position, reporting no irrevocable environmental fines and no irrevocable Labor Inspectorate fines other than "two individual cases of typical violations, which did not have a material impact on the Group's operational compliance" (p.122). The number of complaints received is not disclosed, so the reader sees the outcome but not the volume.

Reference: page 257

Two instruments carry the policy: the Sustainability Policy and the Code of Conduct, which "constitute the framework for managing material impacts, risks and opportunities and apply to all affected communities, both in the local communities where the Group operates and in the broader communities in Greece and abroad" (p.257).

Alignment to international standards is stated with the monitoring mechanism attached: the two documents "commit to adhering to internationally recognized standards, such as the United Nations Guiding Principles on Business and Human Rights, the International Labor Organization Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises. Alignment with these standards is monitored through human rights due diligence processes, reporting and grievance mechanisms, as well as periodic internal audits and compliance assessments". The outcome for the year: "during the reporting period, no instances of non-compliance with the above, concerning affected communities and recorded in the value chain, were identified" (p.257).

Indigenous peoples are addressed with a scoping statement: "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" (p.257).

Reference: page 258

Engagement is described by stage and by channel. It "takes place either directly with the communities or their legal representatives, or through intermediaries", and "Interaction occurs at various stages, starting with consultation to identify potential environmental and social risks, followed by the integration of views into the strategy and the design of initiatives, and continuing throughout implementation to monitor impacts and adjust actions" (p.258).

Ownership is assigned: "The Group's Corporate Relations and Corporate Social Responsibility Divisions are responsible for ensuring engagement with affected communities", holding operational responsibility for execution and for feeding what is collected into the Corporate Responsibility strategy and related decision-making (p.258).

Tools for continuous feedback are listed: "a telephone hotline, a contact form on its website and an email address", with outcomes used to shape initiatives and, where required, to produce "specific agreed actions, impact mitigation measures and initiatives supporting local communities" (p.258).

Vulnerable groups are addressed: public opinion surveys are used "to understand the views of local and affected communities, including groups that may be more vulnerable, such as women, children and members of local communities who may be affected by natural disasters or by the Group's activities" (p.258). Indigenous peoples are again scoped out (p.258).

Reference: page 258

The Group describes procedures "to identify, manage and remediate cases where it is determined that it has caused or contributed to material adverse impacts on affected communities", which "include engagement with affected communities to identify and determine appropriate remediation measures", with effectiveness assessed "through KPIs, periodic progress reviews and feedback from affected communities" (p.258).

Channels are named: "telephone hotlines and electronic platforms" through which affected communities can submit concerns or needs, with availability strengthened through business relationships, as the Group "encourages partners to implement similar procedures and facilitate the reporting of concerns by local communities" (pp.258-259).

Case handling is described: "Submitted issues are recorded, categorized by type and location and monitored until their final resolution. The effectiveness of the communication channels is evaluated on a regular basis through internal reviews, analysis of indicators (e.g. response time, resolution rate) and structured feedback collected from affected communities and users of the channels" (p.259).

The Group says it "receives and manages a significant number of requests" but does not disclose how many, nor how many were resolved, so the response-time and resolution-rate indicators it names are not reported.

Reference: page 259

The socio-economic footprint is measured externally and quantified. The Group assesses it annually "with the support of an independent scientific body... based on an internationally recognized input-output methodology, using official data from third-party sources", and reports that "based on the latest analysis by the Foundation for Economic and Industrial Research (IOBE) for 2024, at the local level the Group supported more than 7,000 jobs - direct, indirect and induced - with total income amounting to EUR 180 million, contributing to local value added exceeding EUR 870 million" (p.259).

Named programmes carry their own figures. Empowering Youth, running since 2009 in Thriassio, Western Thessaloniki and Kozani: "more than 5,700 students have been rewarded for their academic performance, and over 350 scholarships have been granted to highly reputable universities, with total investment exceeding EUR 15 million" (p.259). Forest restoration: "over the past three years more than 32,000 hectares of burned forest areas were restored through anti-erosion works", with 2025 reforestation in Penteli and Pallini covering "a total of 121.73 hectares and more than 5,000 trees, with the participation of 130 employee volunteers and their families" (p.260).

The year's total is stated: "In 2025, total investments in Corporate Responsibility actions in Greece and abroad amounted to EUR 15.3 million, benefiting approximately more than 2.95 million people" (p.263).

Reference: page 263

One outcome-oriented target is set, with its baseline reset this year: "At the end of 2025, the Group set an annual target to benefit more than 2 million people in Greece and abroad. The year 2025 constitutes the baseline year for this target, with a baseline value of 2.95 million beneficiaries" (p.263).

The previous target and its outcome are both reported: "In 2023, a previous target had been set to benefit more than 1.5 million people for the period 2024-2026, which was successfully achieved" (p.263).

Provenance is disclosed. The target "was established through a structured process incorporating the relevant impacts identified through the DMA", and "where feasible, the process also incorporates feedback from affected communities to ensure that the targets respond to their actual needs" (p.263).

Measurement basis is named: "Monitoring of the beneficiaries indicator for Corporate Responsibility actions takes into account data from subsidiaries in Greece and abroad and is reported in accordance with the London Benchmarking Group (LBG) methodology" (p.263).

Governance is assigned to the Board's Sustainability Committee, which oversees achievement of ESG targets, informs the Board and submits proposals for corrective actions (p.263). Worth noting for a reader: the new target of more than 2 million beneficiaries sits below the 2.95 million baseline it is set from, so on its face it is not an improvement target.

Reference: page 268

The Quality Policy is the primary instrument, "aimed at producing and delivering high-specification products and services that fully meet the needs and expectations of end-users", covering equipment reliability, raw material and product quality and a certified quality management system audited to ISO 9001:2015 (p.268). It applies to all employees, is publicly accessible on the corporate website, and its implementation "extends to consumers and end-users".

The Group is candid about what it does not have: "The Group does not have separate policy commitments specifically dedicated to consumers and end-users that are fully aligned with internationally recognized standards regarding consumer human rights, such as the UN Guiding Principles on Business and Human Rights. However, through its Sustainability Policy, it is committed to promoting respect for human rights, enhancing diversity and equality, and eliminating all forms of discrimination throughout its value chain, including consumers, end-users, and business partners" (p.268).

The outcome for the year is a nil return: "To date, no incidents of human rights violations have been identified in accordance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises, concerning consumers and end-users in the Group's operations or in the downstream part of its value chain" (p.268).

Reference: page 269

Engagement is described as running "across all stages of the Group's operations, from product design to service delivery and post-implementation experience evaluation", through "regular satisfaction surveys, public consultations, interactive meetings, and digital communication platforms" (p.269).

The service structure is disclosed in operational detail. "Across the entire fuel retail network, the call center operated by Teleperformance functions on a 24-hour basis, seven days a week", with published numbers for EKO and bp stations and separate lines for Enerwave retail and professional customers. Calls are forwarded to officers under the supervision of the Head of Customer Service of the Fuel Retail Department of KALYPSO KEA S.A. (p.269).

Effectiveness is tracked through the request resolution rate, with the data used "to enhance services and better address their needs" (p.269).

Subsidiary practice is set out one by one: EKO Cyprus uses the EKO Smile application for two-way communication plus 24/7 phone support; EKO Bulgaria uses call centre services and the Guarantee Program with the certified laboratory Bulgarkontrola; Jugopetrol runs multi-channel campaigns and seasonal promotions; EKO Serbia uses satisfaction surveys and the EKO Smile loyalty programme with "over 700,000 members" (pp.269-270). Market research results are reported, including brand awareness of 87% and loyalty programme recognition rising 3 percentage points to 65% in Serbia (p.272).

Reference: page 272

Mechanisms exist and are described. The Group "provides complaint submission mechanisms for any stakeholder, including customers" (p.272). EKO's documented procedure records each complaint, forwards it to technical experts, assesses it "for severity, safety, complexity, impact, and the need for immediate corrective action", investigates root causes, resolves and informs the customer, and documents all actions for analysis into preventive and corrective measures.

The effectiveness limb is answered honestly in the negative, which is the substantive finding here: "Currently, there is no specific approach to ensure the effectiveness of these channels, nor a defined method to assess whether consumers and/or end-users are aware of and trust these structures or processes as a way to express and address their concerns or needs. HELLENiQ ENERGY Group plans to adopt methods for monitoring the effectiveness of these mechanisms, including collecting feedback from consumers and end-users regarding their awareness, trust, and satisfaction with the complaint submission process" (p.272).

Note the tension with S4-2, where the Group states that "The effectiveness of communication with users is monitored through the request resolution rate" (p.269). The two sections describe different things, resolution of requests as against awareness of and trust in the channel, but the report does not reconcile them.

Reference: page 272

Covert Inspector Program: inspectors "evaluate 65 criteria across nine areas of the station", and "In 2025, 3,502 inspections were conducted at EKO and bp fuel stations, and 306 inspections at competitor stations across Greece. Each station is evaluated by a covert inspector between four and twelve times per year", with monthly results published on a platform accessible to sales directors and station managers (p.273).

Quality control by market: Greece uses Mobile Laboratory Units for on-site and surprise inspections; in North Macedonia "OKTA conducted 55 station visits, with 162 samples collected for laboratory analysis at the ISO 17025-accredited OKTA laboratory. For quantitative tests, measurements were taken at 688 pump nozzles, achieving 100% compliance with legislative requirements"; Bulgaria's EKO Guarantee reached its eleventh year, run by Bulgarkontrola S.A. (p.273).

Remediation and volumes: "In cases where product quality issues are confirmed by consumers, the Group provides compensation, while for Health & Safety matters, compensation is granted only when there is a legal ruling", and "In 2025, the customer service center handled 46,272 calls" (p.274). Station staff training reached "7,535 individuals... equivalent to 14,360 training hours in Greece", costing approximately EUR 39,000 (p.275). "No serious human rights issues or incidents related to consumers and/or end-users of the Group were reported during 2025" (p.275).

Reference: page 275

Two time-bound targets are disclosed with baselines and current standing (p.275):

• "~5,600 electric vehicle charging points at EKO/bp stations and publicly accessible locations by 2030. By the end of 2025, the EV charging points was 965, whereas the base year of this target is 2023, when the EV charging points was 162."
• "140 kta sustainable fuel production (biodiesel production unit from used cooking oil (UCO) at the Thessaloniki refinery and development of a new standalone SAF production unit at the Aspropyrgos refinery) by 2030. As this project is not completed yet, there is no production (0 kta) to be reported for 2025."

Reporting a nil against the second target rather than omitting it is worth noting.

A monitoring indicator is also given: "In Greece, in 2025, EKO carried out 105,028 quality analyses on 8,577 fuel samples from fuel stations. In addition, 8,401 analyses were performed on aviation fuels and 30,250 analyses on lubricants at the EKO's Chemical Laboratory" (p.275).

Provenance and governance are stated: the targets were set "through a structured process that incorporates relevant IROs identified through the DMA", the Sustainable Development Committee monitors progress and recommends strategy adjustments, and the Board oversees the establishment of targets, with the selection of topics taking account of consumers and end-users (p.275).

Reference: page 277

Business conduct is confirmed material: "According to the DMA results, business conduct has been identified as a material topic for the Group" (p.277). Corporate culture was newly identified as material in the 2025 DMA (p.138).

The Board's role is stated: "the BoD bears the overall and exclusive responsibility for defining, approving and overseeing the Group's business conduct framework", holding ultimate responsibility for anti-corruption, conflicts of interest, gifts and hospitality, competition and data protection. "The Audit Committee oversees the implementation of policies and the adequacy of internal controls, receiving semi-annual reports on whistleblowing and compliance and deciding on corrective actions where required" (p.277).

Two policies are described. The Code of Conduct sits within the corporate governance framework and applies across Greece and abroad (p.278). The Whistleblowing Policy, under Law 4990/2022 transposing Directive (EU) 2019/1937, applies across the Group's companies (p.278).

Reporting mechanisms are concrete: "The Group has established a dedicated Whistleblowing platform, operated by an independent third party, which allows the submission of reports on a named or anonymous basis", plus a compliance email address, a recorded telephone line and a postal address. "The National Transparency Authority (NTA) has been designated as an external reporting channel" (p.279).

Reference: page 280

The prevention mechanism is set out as five components, including: "The implementation of clear regulations and policies, such as the Code of Conduct, which set standards of business conduct and compliance at all levels, applying to all stakeholders and suppliers"; confidential reporting through the mechanisms described under G1-1; "An annual compliance audit program on corruption-related issues conducted by the Group's Internal Audit Division across all organizational units" (p.280).

Training is described by audience: "All employees participate in mandatory onboarding training regarding the Code of Conduct for responsible business practices. In addition, specialized training programs are provided exclusively for all members of the Group's administrative, managerial, and supervisory bodies to strengthen high-risk positions against corruption risks", alongside mandatory e-learning and in-person sessions on the Code and the Whistleblowing Policy, "with training also provided to the individuals responsible for managing reports" (p.280).

Delivery is evidenced with a table of six sessions run during 2025, naming date, participant count and audience: 11 technical personnel at Aspropyrgos in January, 17 Internal Audit staff in June, 61 Group employees in July, 207 technical personnel in the South Region in July, 91 technical personnel at Aspropyrgos in September, and 84 technical personnel in the Northern Region in October, totalling 471 (p.281).

Reference: page 280

The 2023 ESRS the statement was prepared against had no standalone targets DR for business conduct, so this content sits under MDR-T in the G1 Metrics and Targets section. Three targets are disclosed, each with a baseline or a deadline, (pp.280-281).

First, a zero target: the Group "Has adopted the absolute target of zero incidents of non-compliance with the applicable regulatory and legislative framework, covering financial, environmental, labor, and social matters. Performance against this target is monitored annually through the recording and verification of compliance incidents, with zero incidents set as the baseline value" (p.280).

Second, a training target with progress against it: the Group "Aims to provide training to 100% of its employees on the Code of Conduct by 2027, covering topics related to Human Rights, Business Conduct, and Diversity, Equality and Inclusion... This target has been incorporated into the Group's targets for the current year, and progress is monitored annually. As of 2025, 471 employees have been trained" (p.281). Against a workforce of 4,192 (p.245), that is roughly 11% of employees with two years to run.

Third, a handling-time target: the Group "Is committed to ensuring that all reports submitted through the available channels are fully managed and investigated within two months from the date of submission, in accordance with the relevant Whistleblowing Policy, on an annual basis" (p.281).

Reference: page 280

Both required datapoints are answered as nil returns, and the answers are specific enough to be verifiable.

Convictions and fines: "During the reporting period, no convictions were issued against the Group, its subsidiaries, or members of senior management or governing bodies for violations of anti-corruption or anti-bribery legislation. Consequently, no fines or other financial penalties were imposed in connection with incidents of corruption or bribery" (p.280).

Confirmed incidents: "the Group has consistently maintained zero incidents of corruption or bribery, and no related reports or complaints were submitted to the Regulatory Compliance Unit or the relevant administrative bodies of its subsidiaries during the reporting period. Therefore, no corrective or disciplinary actions were deemed necessary, and no financial losses or other consequences arose for the Group due to violations of anti-corruption and anti-bribery procedures or regulations" (p.280).

The GOV-4 due diligence section corroborates this from the other direction: "no incident of corruption was reported to the Regulatory Compliance Office, nor were any related financial losses recorded", with Internal Audit conducting four audits focused on governance during 2025 and 100% of employees informed about anti-corruption policies through the Code of Conduct and the Internal Labor Regulation (p.122).