Non financial information

Enhancement of the resilience of the MYTILINEOS production units and adaptation of its activities to the existing and potential impacts of climate change.

• In order to adapt to climate change and reduce the impact of relevant potential risks, the Company takes the following actions: a) examines climate forecasts locally to identify potential risks b) integrates the issue of climate change adaptation within its business decision making processes in order to avoid or minimize the damage associated with climate change and where possible take advantage of opportunities to adapt to changing conditions and c) implement appropriate measures as a result of the above procedures.

The following measures are implemented in each Business Unit:

• In the Power & Gas Business Unit, the major risks have been assessed and no apparent need to adopt specific targeted measures has been identified. Regarding the Company’s thermal plants, Emergency Response Plans have been developed to address the occurrence of extreme natural phenomena (heatwave, frost, storm, flood etc.), while special flood studies have also been carried out where streams are located in the vicinity of the Company’s power plants. With regard to the operation of RES plants, wind turbines are fitted with safety systems which in the event of very strong winds switch the turbines off and move their blades to a secure position, while solar collector panels are manufactured hail resistant.
• In the Metallurgy Business Unit, studies have already been carried out regarding the risks of accidents from natural disasters and floods, while existing infrastructures have been improved and new ones have been constructed to address the most extreme weather events and the relevant emergency response plans have been developed. In addition, a climate change water risk study has been carried out.
• Regarding the Company’s business activity abroad, through the Renewables & Storage Development and Sustainable Engineering Solutions BUs, appropriate protection measures are adopted and implemented within the boundaries of the facilities and work sites.

In addition, the Company has already begun to adapt to the recommendations of the international initiative Task Force on Climate — Related Financial Disclosures (TCFD), in each of the four specific thematic units: Governance, Strategy, Risk Management, Indicators and Targets. More detailed information is published in the Sustainable Development Report of the Company in the relevant TCFD Content Index.

• In 2021, MYTILINEOS submitted for the first time a report to the international CDP Climate Change initiative (Ranking C), disclosing extensive data on its initiatives related to climate change and comparing its performance with the largest companies in the world.
• The Company aims to be in line with 70% of the recommendations of the TCFD initiative at the end of 2022.

Responsible use of energy and other natural resources, in accordance with the main axes of the MYTILINEOS Environmental policy. Achievement of the ambitious targets of reducing CO₂ emissions by 30% and a net-zero carbon footprint by 2030 and 2050 respectively.

• MYTILINEOS has adopted specific initiatives to tackle climate change, which are outlined in the "Tackling climate change" section of this report. The Company’s CO₂ emissions targets (Scope 1 and 2) are aligned with the emissions reductions required to keep global warming below 2°C by 2030, in line with the vision of the European Green Deal to achieve climate neutrality by 2050 as well as with the Global Sustainable Development Goals. By 2026, MYTILINEOS aspires to complete its investment program of 1.5GW in renewable energy sources in Greece, to have made significant progress in the electrification of the Metallurgy Sector from RES, to have increased the production of secondary aluminum to 26% of total production aluminum and to have incorporated digital industrial methods in the production stages. Meanwhile, MYTILINEOS proceeds with the implementation of relevant initiatives such as the use of electric vehicles in the Sustainable Engineering Solutions BU and the Renewable Sources & Storage Development BU.
• In the context of promoting the use of natural gas as a transition fuel for the "green energy" era, the construction of the new combined cycle power plant with natural gas (CCGT) was completed at the end of 2021, making the Agios Nikolaos Energy Center in Viotia a new national energy center. The new plant has a thermal efficiency of over 63%, capacity over 826MW as well as the option to utilize fuel mixtures with hydrogen or biogas instead of natural gas, thus being a powerful means of achieving the MYTILINEOS climate targets. Today, it is the most powerful power plant in the country and one of the largest power plants in Europe, enhancing and ensuring the country’s electricity efficiency and the energy transition.
• Within 2021, MYTILINEOS proceeded to the creation of an integrated system of recording the Scope 3 sources and measuring the relevant emissions, from all its Business Units. Through this exercise, the Company identified for the first time the material indirect Scope 3 emissions categories, which will be published in the 2021 Sustainable Development Report, while it is already looking into ways to reduce its Scope 3 emissions.
• MYTILINEOS implements systematic procedures for monitoring and ensuring compliance with the legislation, obtaining the statutory greenhouse gas emission permits and submitting the relevant reports, while participating through the Metallurgy and Power & Gas Business Units in the EU Emissions Trading Scheme (EU ETS) since 2013. At the same time, MYTILINEOS has installed all the necessary systems for the regular monitoring of CO₂, Fluorine and PFCs and other gaseous pollutants (NOx, SOx and Particulate Matter) carrying out continuous measurements. MYTILINEOS systematically applies Best Available Techniques (BATs) in its production processes and ensures the proper maintenance and modernization of equipment.

• Within 2021 there was a reduction in total energy consumption by 4% due to the planned major maintenance process of the Korinthos Power unit which lasted 3 months. This also resulted in the corresponding reduction of 5.5% of direct CO₂ emissions (Scope 1), while there was a reduction of indirect CO₂ emissions (Scope 2) by 15% due to further use of RES. The above changes led to an overall reduction in Scope 1 & 2 emissions by 8.9% compared to 2020.
• Finally, in the Metallurgy Sector, the preparation of a dedicated pre-study for the installation of carbon dioxide emission control systems at the facilities of the Aluminum Plant of Greece, in collaboration with a leading company in this field worldwide, will begin.

Responsible management of water withdrawal, use and discharge, in accordance with the main axes of the MYTILINEOS Environmental policy.

With the aim of more efficient water management, the Company implements effective water management practices and continuous improvement programs in all its main production units. Particularly:

• Water withdrawals from ground water in the Metallurgy sector are obtained from a controlled network of wells (boreholes) which allows water to be replenished naturally after withdrawal in a short time through rainfall, snowfall etc. (renewable sources).
• Water recycling and reuse programs are implemented to the maximum extent possible in the production processes or in secondary uses.
• Risk & Impact Assessments of the aluminium plant area’s aquifer are carried out, as well as hydrogeological studies.
• In the energy complex of Agios Nikolaos, Viotia, for the cooling of the towers of the thermal power plant, discharged seawater from another unit is systematically utilized, thus avoiding withdrawing a significant amount of seawater.
• On an annual basis, internal targets for the critical water withdrawals are set for each area of activity with the greatest impact, while rainwater is collected and reused.
• Water resources management includes monitoring of water discharge in all production units and subsidiaries to ensure the quality of wastewater. The management of the water discharges resulting from MYTILINEOS’ activity is fully controlled and takes place by monitoring the parameters determined by the environmental terms and regulations under which the facilities of the company’s Business Activity Sectors have obtained their environmental licenses.
• In order to control the quality of the disposal of the treated liquid industrial waste, measurements are taken on a continuous basis according to specific parameters determined by the applicable Environmental Terms Approval Decisions and the Water Use Licenses.

• The Company’s activities, in the context of water withdrawal, do not limit or threaten the adequacy of available water in the aquifer, nor any water source that has a high value for the conservation of biodiversity or is important for local communities.
• In total, 169 thousand ML of water were withdrawn for use, 1,240 ML less compared to 2020, while the quantity of used water returned to the water basins after quality treatment and in accordance with the approved environmental terms per Business Unit, amounted to 162 thousand ML. As a result, total water consumption reached 6.95 thousand ML, showing an increase of almost 5.5%, while the freshwater consumption remained almost stable (small increase by 1%) compared to 2020.
• The amount of water reused in other Company units, thus preventing an equivalent volume of water withdrawals, amounted to 7.5 thousand ML, corresponding to 4.4% of total water withdrawals, showing an increase of 10.7% compared to the relevant amount in 2020.

Prevention of any identified risk of pollution from the activities of the Company, in accordance with the main axes of the Environmental policy of MYTILINEOS.

• In the Metallurgy Business Unit, a dedicated Major Accident Prevention Policy is in place for preventing and responding to large-scale industrial accidents, which addresses risks associated with the use of hazardous substances in the Business Unit’s activities. Through a set of concrete measures, the prevention and avoidance of any incident involving a deterioration of the environment is ensured. These measures include, among others: strict compliance with the approved Environmental Terms of the metallurgical activity, compliance with the measures provided for in the afety Study (SEVESO III — implementation of Joint Ministerial Decision 172058/2016), implementation of Best Available Techniques in the management of infrastructure and industrial waste, good knowledge of and training on Emergency Response Plans (EPs), the operation of a fire protection department and the continuous monitoring of the water and soil quality.
• The subsidiary DELPHI — DISTOMON, in order to prevent and reduce small-scale, localized incidents involving spills of lubricants within the context of mining activities in the tunnels of underground quarries, implements on an annual basis the following practices: (1) purchasing supplies (lubricant pipes) with the best quality available in the market, to ensure their maximum possible durability, (2) implementing, on an annual basis, custom-developed seminars to raise awareness among personnel on the need to report and log such incidents, (3) responding immediately to such incidents, collecting the quantity of contaminated soil in the area of the spill and forwarding it to the hazardous waste disposal area for appropriate handling, and (4) regular and preventing maintenance of the equipment and its parts.
• In the Power & Gas, Sustainable Engineering Solutions and Renewables & Storage Development Business Units, in all production units (thermal plants, RES plants, complex construction plants and work sites) all potential risks are identified to address in a timely manner and minimize the consequences of unforeseen malfunctions and accidents. In particular, the following are implemented: (a) all procedures in the Environmental Management Systems and the Emergency Plans, as well as the operation and maintenance instructions for installations, (b) the instructions for monitoring air emissions, (c) preventive maintenance programs, (d) systematic visual environmental inspections of installations, (e) annual external audits for the certification of the Environmental Management Systems.

• During 2021, no incidents occurred involving any form of pollution of the natural environment from production activities or involving industrial accidents in all Company activities. Concerning air emissions, these remained below the statutory levels for yet another year.
• The annual target of the Company is to avoid any incidents and industrial accidents that could cause pollution in the natural environment, in all areas of its activity.

Safeguarding biodiversity and ecosystems during mining activities and during the development and operation of Renewable Energy Sources (RES) projects in protected Natura areas, according to the main axes of the MYTILINEOS Environmental policy.

MYTILINEOS implements targeted actions for the protection of biodiversity and ecosystems in the areas where it operates or adjacent to them and wherever there are endangered or protected species of flora and fauna.

• In the Metallurgy Business Unit, the Aluminium of Greece plant has established a series of prevention and control measures to prevent impacts to the natural recipients, thus safeguarding their quality and, consequently, the conditions for the growth of the local flora and fauna. In addition, the Aluminum plant carries out restorations of the inactive surfaces of the Bauxite Waste Disposal Sites and Aggregate Waste Disposal Sites, while it has assigned to a specialized external partner the maintenance of the new and old restored waste disposal sites (e.g., old restored hazardous waste disposal landfill, inert waste disposal sites and limestone quarry). The preventive measures will be presented in detail in the 2021 Sustainable Development Report.
• The mining activity of DELPHI-DISTOMON, a MYTILINEOS subsidiary, involves primarily underground quarries and is carried out with respect to the biodiversity of the area. The Company has developed an environmental policy that highlights its commitment to the protection of biodiversity in the preparatory phase of each new mining activity. In addition, the policy prescribes the implementation of measures to avoid significant ecological impacts and the alteration of the natural landscape during the execution of works, as well as in the closure and rehabilitation phase of each site, helping to further contain any adverse impacts, which are already quite limited in scope and temporary in nature. DELPHI-DISTOMON has been systematically active for almost 50 years in environmental rehabilitation and all its inactive quarries have been restored. Environmental remediation is carried out with systematic tree planting.
• In the Power & Gas Business Unit and with respect to the activities which concern the construction of wind farms located near or inside areas designated as Special Protection AreasThe Sustainable Development Report 2021 outlines the limited impacts of the construction and operation of the Company’s wind farms, located in protected areas (e.g., NATURA 2000 Network and Archaeological sites)., a key prerequisite is the development of the respective foreseen environmental impact studies (specific ecological assessment, annual monitoring of the protected area), to confirm that there are no impacts or, in cases where there are impacts, to describe the measures which may be adopted in order for these impacts to be avoided. In cases where measures cannot be taken, the project is redesigned appropriately. In line with the above, in the locations of the Company’s activities the movement of animals is not obstructed as there is no fencing, and the disturbance to the local population of birds is negligible, while where this is necessary, technical systems for the protection of birds are installed. Furthermore, concerning the restoration of the environment in the context of new wind farms, the Company carries out reforestation equal to the area of intervention as required and, where possible, restores illegal or inactive quarries, in accordance with the applicable laws and the instructions of the corresponding Forest Departments.

• During 2021, no incidents occurred involving a deterioration of biodiversity due to the Company’s activities, while the works scheduled for the rehabilitation of used areas were carried out as planned.
• The total area of land used in 2021 was 86 acres, reduced by 28.3% compared to 2020.

• Regarding the activities of construction and operation of wind farms and the new thermal plant, the reforestation of a total area of 706.9 acres (617.7 and 89.1 respectively), while three bird population monitoring studies were carried out.

Control, continuous reduction and proper management of solid and liquid waste, with the implementation of recovery, reuse and recycling techniques where possible, in accordance with the main axes of the MYTILINEOS Environmental policy and the application of Best Available Techniques in the production process.

In the Metallurgy Business Unit, which accounts for 99% of the Company’s total waste:

• MYTILINEOS has set ambitious targets regarding the production of secondary aluminum and the use of recycled (scrap) aluminum by 2025 and 2030.
• In 2021, a Life Cycle Assessment (LCA) was completed to assess the potential environmental impacts of bauxite mining and alumina and aluminum production, according to ISO 14040 and 14044.
• Specially configured landfills (Controlled Landfill for Hazardous Waste and Controlled Landfill for Non-Hazardous Waste) are maintained and used, while the disposal of bauxite residues (non-hazardous waste which constitutes 95% of the total waste of the Company) is carried out in a specialized way, based on geotechnical studies, following the natural relief of the area.
• The Company continues to consistently invest in the installation of pilot units for the development of research in the exploitation of bauxite residues, by participating in European programs concerning the use of energy-efficient "green" technologies for the production of useful products and materials, as well as for the development of technologies for the extraction of rare earth elements.
• The largest percentage of liquid waste is recycled within the production process itself, while three Biological Treatment Facilities are in operation.
• In 2021 the BU participated in 24 research projects (4 new and 20 continued from 2020), co-financed by the EU or the Greek state through the programs H2020, EIT Raw Materials, EIT Manufacturing, ERA-MIN 2 and GSRI. These programs research topics such as:
  • Utilization of bauxite residues for the production of scandium, iron, alumina, cement additives and construction products.
  • Production of alumina from alternative (secondary) sources.
  • Utilization of carbonated alumina electrolysis by-products.
  • Heat recovery — use of RES in the production of aluminum.
  • New tools / training courses for engineers and craftsmen working in the raw materials and metallurgy sector.
  • New aluminum recycling technologies & digitization of processes in alumina production.

The total funding of the programs, in the period 2017-2025, exceeds 120 million Euros, out of which 8.7 million Euros is the funding of the Metallurgy BU of MYTILINEOS.

In each BU and production facility:

• Networks for the collection of waste for reuse and recycling are in operation.
• In cases where recycling cannot be completed internally, the Company cooperates with alternative waste management system organizations, as well as with licensed (per waste category) waste collection, transportation, management and recovery contractors in Greece and abroad.
• The management of the water discharges is fully controlled and takes place in accordance with the parameters determined by the environmental terms and regulations, under which the relevant environmental licenses have been obtained.

• In 2021, there was an increase in the total amount of solid waste generated by the Company by 11.4%, which mainly resulted from the increase in the generation of Construction, Demolition and Excavation waste due to the increase of the construction activity in 2021. It is worth noting that the total of waste within this waste category has been recycled.
• The percentage of solid waste reused, recycled and utilized in various ways either by the Company itself or through third parties increased by 6 percentage points and reached 24.9% (2020: 18.6%) out of the total waste generated (including bauxite residues).

MYTILINEOS continues to take constant care to ensure the achievement of the only acceptable target of "ZERO ACCIDENTS AND ZERO OCCUPATIONAL DISEASES", which is also the major challenge for the industrial and construction sectors, according to key elements of the MYTILINEOS Occupational Health and Safety policy.

Occupational Health and Safety (HS) is a line of responsibility that begins from the Management and the General Divisions and extends to all stages of production of all MYTILINEOS Business Units. To address the relevant risks:

• Strict systems and measurements are implemented, assessing their impact on employees but also identifying the needs for interventions in offices and industrial units.
• Preventive and structural actions are implemented, analyzing every incident and near accident.
• Employee education and training is critical to maintaining and further developing the accident prevention mentality. In this way, the systematic effort continues for the promotion and development of a unified HS Corporate Culture, which encourages all employees (direct and indirect) to behave responsibly for themselves and their colleagues.
• Systematic investments are made on Health & Hygiene, monitoring and evaluating all relevant factors of the working environment, aiming at the continuous improvement of the good health and the healthy living of the employees.
• Health and Safety issues are integrated into the central corporate risk management system (ERM) in order to further ensure their prioritization, as well as the required allocation of relevant resources for their improvement.
• In order to keep the work areas safe for the employees and contractors working for MYTILINEOS, this issue is linked to all the decisions and actions of the Company.
• Almost 90% of production units, thermal power plants, and RES units have a Health and Safety Management System certified according to ISO 45001:2018.

• Occupational Health & Safety at work is high on the agenda of the daily operation of MYTILINEOS. In 2021, even though the Company achieved the goal of zero accidents and occupational diseases to its immediate employees, nevertheless recorded a fatal accident to one of its contractors and an increased number of total accidents compared to 2020.
• The Company’s target is zero accidents, zero accidents with serious consequences and maintaining the lowest possible levels of the frequency index of total accidents recorded on an annual basis.

Zero tolerance for the violation of Human Rights, according to the key elements of the Human Rights Policy of MYTILINEOS, the "Code of Business Conduct" and the "Suppliers & Business Partners Code of Conduct"

• MYTILINEOS is committed to the first 6 Principles of the UN Global Compact, which are based on, among others, the internationally recognized principles on the protection of Human Rights, as these are defined in the Universal Declaration on Human Rights.
• MYTILINEOS monitors the relevant labor legislation (national, European, ILO) and is fully aligned with the collective bargaining agreements and the relevant international conventions both nationally and in developing countries.
• MYTILINEOS has developed a dedicated Human Rights Policy and in the context of the implementation of this policy conducts relevant self-assessments in all Business Units.
• The Company has established a grievance mechanism under the responsibility of the Regulatory Compliance Division, enabling its employees to express any concerns, as well as cases of human rights violations. Moreover, the Company warrants that no action shall be taken against any employee who reports in good faith any actual or alleged inappropriate conduct.
• Regarding its activity in developing countries, MYTILINEOS takes all necessary measures to comply with the applicable laws. Safe work management is governed by a series of actions that must be followed, to ensure that the Health & Safety system for employees is properly implemented and the appropriate measures are taken. At the same time, the contracts signed with contractors and suppliers include an explicit provision about the Company’s Code of Conduct, to safeguard the respect of Human Rights and to prevent conditions of corruption and bribery.
• The Company conducts training of Executives also on Human Rights focusing on the respect for the freedom of association, the elimination of all forms of forced or compulsory labor, the identification and elimination of child labor, and the elimination of any discrimination related to the workplace and to employment.

• In 2021, the Company implemented, for the 5th consecutive year, the self-assessment process regarding the protection of Human rights in its Business Units, in line with the methodology recommended by the Global Compact (Global Compact Self-Assessment Tool — Human Rights). According to the results of the self-assessment process, no areas with deficiencies were identified that could compromise the protection of Human Rights in the Company’s activities.
• Through the formal procedure in place for reporting violations of the Company’s Code of Business Conduct, no incident of Human Rights violation was reported to the Human Resources General Division or to the Regulatory Compliance Division in 2021, achieving the long-term goal of the Company for zero tolerance in the violation of Human Rights.

Development, management, and retention of human resources, through the implementation of practices that promote an inclusive work environment, with equal opportunities and respect for Human Rights, in accordance with the key elements of the Human Rights Policy of MYTILINEOS.

Key elements of the Company’s approach to Employment:

• Attraction and retention of competent employees, continuous improvement of employer-employee relations and implementation of modern systems for employee performance evaluation.
• Establishment of an attractive remuneration and benefit framework according to market data and specialized surveys for critical areas of the Company’s activity.
• Promotion of the Code of Business Conduct to all personnel and ensuring employee awareness, and avoidance of direct or indirect discrimination in all work practices.
• Recognition of the importance of healthy and safe employment for all personnel and business partners with emphasis on mental health.
• Focus on offering local opportunities, giving priority to the recruitment of employees from the Company’s local communities, and bolstering local employment at domestic and international level based on the Company’s activities.
• Ensuring the flow of information and the timely communication of organizational changes, through the appropriate communication channels.
• Protection of the personal data of employees, allowing their use only by authorized persons and only in cases where this is required by the law for purposes related to the functioning of industrial relations and to the Company’s business activity.
• Ensuring through the individual Labor Regulations and the Code of Business Conduct the elimination of all arbitrary or discriminatory practices in terminating employment relationships with employees.
• In 2021, the Performance Management Program was redesigned so as to be unified and inextricably linked to the corporate goals as well as to the corporate results. The Program will be implemented gradually, starting from the top and senior management.

• In 2021, the total new hires of the Company reached 915 with 21% of them being women, while in total more than 450 new positions were created in Greece and abroad.
• The retention rate of full-time employees exceeded for another year the percentage of 90%, while the low percentages of part-time employment and temporary employment in the Company were maintained.
• In addition, MYTILINEOS, created 92 quality internships and vocational training positions, with the aim to develop skills and transform many of these positions into permanent employment positions.

Providing equal opportunities without discrimination, in accordance with the main axes of the MYTILINEOS Human Rights Policy.

The MYTILINEOS Human Rights Policy includes the Company’s commitment to equal opportunities, zero tolerance of abusive or inappropriate behavior, fair treatment, gender equality and respect for the confidentiality of personal data (GDPR). In 2021, priority was given to the collection and analysis of data from the different Business Units to deepen the understanding of these issues, with the aim to formulate an action plan with the primary purpose of informing and training the MYTILINEOS Executives. Indicative initial studies and ongoing actions are mentioned below:

• Apart from the Code of Business Conduct and the Human Rights Policy in which there are explicit references to non-discrimination at work, MYTILINEOS evaluates existing human resources policies and will develop new ones, with the aim to promote, among others, equality at work.
• MYTILINEOS reviews the policies of Human Resources, such as the Human Resources Search, Selection and Recruitment Policy and the Training and Development Policy in order to ensure the provision of Equal Opportunities.
• In 2021, the scope and framework for the development of the Diversity, Equal Opportunities & Inclusion Policy, which is under development, was reviewed.
• Upon completion of the training on psychosocial risks at work, in the context of actions to promote mental health, Executive training is planned to be conducted by specialized associates on unconscious bias at work.
• The United Nations Women’s Empowerment Principles (UN WEPs) are being studied and implemented and MYTILINEOS is scheduled to register as a member.
• On an annual basis, analysis and evaluation of salary grades is carried out in order to identify areas where we may need to intervene in the short and long term to reduce the pay gap between men and women. The goal is for the analysis and the creation of an action plan to be completed by the end of 2023.

Already from 2020, MYTILINEOS started developing a methodology for the data collection and analysis that enables the understanding of the equal pay index between men and women. In 2021, the average deviation was calculated in order to prepare from 2023 a relevant study and to design an action plan for the gradual elimination of the pay gap between women and men. Based on the initial analyses, the pay gap between men and women in the Executive category seems to be estimated and maintained at rates below 10%. Due to the geographical dispersion, complexity of operations and the different business activities of MYTILINEOS, before the Company publishes specific indicators, it has set as a priority the identification of the different causes that create such discrepancies in each of the Executive, Administrative and Staff categories.

Creating a responsible supply chain based on ESG criteria and according to Suppliers & Business partners Code of Conduct.

MYTILINEOS seeks to develop strong and long-term relationships of trust and mutual benefit with its suppliers and partners. The Company has as a priority to support its local communities, forging partnerships with local suppliers and contractors while at the same time, in the framework of its sustainable development strategy, it has started implementing special initiatives aimed at expanding responsible practices in its supply chain.

• MYTILINEOS has created a dedicated "Suppliers & Business partners Code of Conduct" which includes the description of the minimum conditions / expectations of the Company from its supply chain, in matters related to responsible entrepreneurship and sustainable development while it is a basic condition of the commercial cooperation of the two parties. The Code is structured according to ESG criteria and in line with the Sustainable Development Goals.
• The Company, to strengthen the level of information, maturity and integration of Sustainable Development in its supply chain, organizes annual cycles of training seminars, to its main suppliers in Greece, in collaboration with the CSR Hellas network, a member of the European organization CSR Europe.
• In the context of the integration of ESG criteria in its supply chain, the Company has designed a dedicated supplier evaluation questionnaire, while integrating the process of evaluation of new and existing suppliers in all departments / procurement and supplies divisions of all its Business Sectors.

• The main targets of the Company, until 2025, are the strengthening of the level of maturity and integration of Sustainable Development in its supply chain, the inclusion of ESG criteria in the process of selecting new suppliers as well as the engagement of the existing ones to responsible partnerships, to better understand the impacts and harmonize goals and expectations.
• In 2021, almost 15% of all new suppliers with which MYTILINEOS entered a commercial relationship, were evaluated on the basis of environmental and social criteria.
• In addition, the Company completed the 2nd cycle of training of key suppliers on corporate responsibility issues, increasing the number of suppliers that have already been trained to 85, while 10 of them completed additional in-company training on sustainability issues.
• Finally, the official ESG evaluations cycle of key suppliers in each Business Unit has begun.

The consistent implementation of its social policy with actions and initiatives that enhance the coexistence of MYTILINEOS with its local communities and the wider society. Respect for the rights of citizens of local communities adjacent to the Company’s industrial units, according to the main axes of the MYTILINEOS Human Rights Policy and the Corporate Social Responsibility Policy.

• The contribution of the Company to the sustainability of its local communities, to the extent that MYTILINEOS can contribute, is carried out across three main axes: a) bolstering local employment, recognizing the role of the Company in the development and preservation of the prosperity of local communities in which it operates, b) supporting local economic growth, selecting domestic and consequently local suppliers as a priority, and c) making a substantial social contribution through the annual Social Investment Program by implementing selected actions in areas directly related to the main social needs highlighted by the pandemic and linked to the respective Global Sustainable Development Goals.
• The General Management of each Business Unit of MYTILINEOS is responsible for managing relationships with the local communities where each Business Unit operates, while Sustainability/ESG teams have been established that manage the implementation of the social policy.
• MYTILINEOS has been consistently holding its established Open Social Dialogue events with its Stakeholder groups at local community level for the last 12 years. The Company is one of Greece’s pioneers in this field, as this approach has created the conditions for defining new attitudes and practices in its relationships with the various social groups, taking into account the specific features of each Business Unit.
• The initiatives implemented by the Company on a local level, and particularly those related to the strengthening of local infrastructure, are linked to the needs of each community and of the wider region, and are shaped through open dialogue with the local social partners. The Company communicates with its local communities in a clear and transparent way, opting for an "open door" policy, applied primarily in the areas where the Company’s industrial plants are located.
• At the same time, strengthening the constructive relationship it has established with social bodies over the years, MYTILINEOS implements a system of management and evaluation of social requests, which enhances the transparency and ensures the sustainability of its social investments.

• In 2021, the Company, continuing the implementation of its social policy, implemented actions exceeding € 9 million in key social sectors that contribute to the Global Sustainable Development Goals.
• In 2021, the 7th consecutive thematic consultation of the Social Partners was implemented by the Metallurgy BU of the Company, on the topic "Covid-19: Measures and actions for the effective management of the pandemic — Health protection and operational continuity".

Ensuring business continuity, protection of the environment and health and safety in case of emergency, in accordance with the main axes of the Occupational Health and Safety Policy and the Environmental Policy of MYTILINEOS.

As management of emergency incidents is a top priority for MYTILINEOS, appropriate Emergency Prevention and Response Plans (for fire, explosion, leakages, natural phenomena, extreme weather conditions etc.) are applied in all Business Units of the Company, in order to deal effectively with all incidents that result in deviations from their normal operation with potential serious consequences for the environment and for the health and safety of employees and the local communities.

• In the Metallurgy Business Unit, an Emergency Response System has been developed in the facilities of Ag. Nikolaos, Viotia, including an integrated Internal Emergency Plan (IEP) which also includes special evacuation plans of the facilities, systematic training of personnel, and planning and implementation of emergency preparedness exercises in accordance with the annual plan.
• In the Power & Gas Business Unit, a package of emergency response measures is applied in the Unit’s energy centers, RES plants and offices, comprising the following: (a) Emergency Team or Emergency Manager, (b) documented relevant procedures, (c) implementation of Emergency Management Plans, and (d) implementation of personnel exercises and trainings in accordance with the special Evacuation Plans and the Building Emergency Instructions.
• At the Sustainable Engineering Solutions and Renewables & Storage Development Business Units, each construction site has its own emergency plan, appropriate to the nature of its activities and to the risks identified and assessed. The emergency plans are documented, accessible and clearly communicated to all personnel, who are trained to understand these plans and to thoroughly familiarize themselves with their roles and responsibilities in the event of an emergency.

• In 2020, a total of 61 emergency preparedness exercises were carried out in each production unit, construction site or office of the MYTILINEOS BUs, while in 2021 a total of 82 emergency preparedness exercises were carried out.

Zero tolerance of corruption and bribery, according to the main axes of the Corporate Social Responsibility Policy, the Code of Business Conduct and the Suppliers & Business Partners Code of Conduct.

Addressing corruption and bribery is a key element of the MYTILINEOS Code of Business Conduct and its Suppliers and Business Partners Code of Conduct. For MYTILINEOS, the reference point when it comes to addressing corruption and bribery, is the principle of integrity, which relates to its long-standing commitment of zero tolerance of such issues. MYTILINEOS undertakes a number of measures to implement this commitment:

• MYTILINEOS has officially declared its commitment to the 10th Principle of the UN Global Compact, according to which "Businesses should work against corruption in all its forms, including extortion, bribery and facilitation payments". This principle acts as a catalyst in establishing a culture of ethics across the Company.
• In order to tackle corruption and bribery, MYTILINEOS implements rigorous screening and due diligence practices of third parties before proceeding to an agreement or payment.
• MYTILINEOS avoids any transaction and contact with third parties that have participated in the creation of conditions for the development of incidents of corruption, blackmail or bribery.
• The Company conducts on an annual basis a risk study on potential corruption and bribery in its business activities and prescribes risk minimization measures, within the framework of Enterprise Risk Management.
• Both prevention and detection systems and controls have been established to ensure that suppliers are properly selected, disputed payments are avoided and the payments due are made correctly and are entered in the Company’s accounting books in an accurate and transparent manner.
• In countries with a high risk of corruption, the Company establishes a Grievance Mechanism, protecting complainants from eventual retaliation, while at central level, the grievance mechanism functions through the submission of reports of violations to the Director of Regulatory Compliance.
• The Company carries out unannounced audits on suppliers with the aim to ensure the implementation of Suppliers & Business Partners Code of Conduct.
• The Company ensures systematic training of personnel on the Code of Business Conduct by category of exposure to regulatory risk.

• In 2021, MYTILINEOS applied all necessary internal procedures to safeguard its policy. Through the screening mechanisms applied in the Purchases-Procurement Departments of the Company’s Business Units, which have investigated both the process for the selection of business partners and all types of transactions, no confirmed incidents of corruption were identified that could possibly lead to dismissal or disciplinary action against employees on the grounds of corruption, nor any corruption-related resulting in the termination or non-renewal of cooperation with business partners or public judicial cases against the Company or its employees for corruption. In this way, MYTILINEOS achieved the annual target it has set for zero incidents of corruption and bribery.
• In addition, the Regulatory Compliance Division issued in 2021 the MYTILINEOS employee and associate conflict of interest policy and collected the relevant statements of executives and employees in key Management positions.

Operation in full harmony, compliance and observance of the applicable legislation and operating principles in each region or country of activity, in accordance with the main axes of the Code of Business Conduct and the Suppliers & Business Partners Code of Conduct.

• In order to prevent the aforementioned risks, MYTILINEOS complies with the legal and regulatory requirements of the geographical regions in which it operates and ensures that its relations and activities comply with the legislation in force and with the applicable institutional framework.
• Measures are implemented in order to be continuously informed the applicable legal obligations while procedures are in place to monitor legislative developments.
• Compliance with the applicable laws and regulations is reevaluated on a regular basis including compliance with the approved environmental licenses.
• The Company strives to ensure that its business practices are fully aligned with the UN Global Compact’s Principles.
• In the process of submitting project bids, policies and procedures (management system or due diligence procedures) are implemented to prevent bribery and corruption as well as anti-competitive behavior.
• At the same time, trainings on regulatory compliance topics are developed and conducted, such as training on personal data protection (GDPR) and training on the Code of Conduct. In addition, relevant material has been developed and thematic trainings are carried out for specific employees on the below topics:
  • Initial training on Regulatory Compliance for new employees
  • Healthy competition law
  • Thorough third-party auditing using the in-house integrity audit platform
  • Complaint management and investigation platform

• The Company’s compliance with the applicable legislation as well as the application of control measures for compliance with the regulations concerning the activity of MYTILINEOS, in 2021, resulted in the absence of incidents of non-compliance with the legislation and with the applicable regulations at environmental, social and economic level.
• The Regulatory Compliance Division continued the implementation of the Personal Data Protection (GDPR) training and the training on the MYTILINEOS Code of Conduct (CoC). In 2020, these trainings were carried out for Managers, supervisors, employees in positions whose nature of work is at risk of non-compliance and employees who process personal data and 500 employees completed the training (completion rate 83%). In 2021, the remaining employees of the target group were included the training and 90 employees completed the training (completion rate 98%), with the aim of the trainings to be completed in 2022.