By implementing an integrated and modern Environmental and Energy Management System, the Group aims at the early identification and analysis of potential risks, thus achieving the continuous improvement of its environmental performance and the effective implementation of its environmental impact reduction strategy. The Group’s environmental impact reduction strategy follows the following key steps:

• Initial assessment of environmental aspects
• Description of working methods
• Initial assessment of the environmental impact assessment Initial assessment of the environmental impact assessment
• Adaptation to new technologies
• Addressing impacts at source

The modern and comprehensive Environmental Management System of both the Group and its subsidiaries is certified according to the international standard ISO 14001:2015. In addition, the Group’s company TERNA S.A. is certified according to ISO 50001:2018 and apply an Energy Management System horizontally in all its projects and facilities.

The Group makes efforts to rationally manage the consumption of all forms of energy and protect natural resources in all its activities by implementing appropriate measures. Therefore, the Group carries out actions to systematically record and monitor energy consumption in offices, construction sites and facilities so that it is possible to assess its energy needs and take action to reduce the energy consumption of its activities.

At the same time, the Group invests in actions that improve its energy footprint, such as the renewal and maintenance of its machinery in order to increase its useful life and improve its energy efficiency.

Products and services that contribute to carbonisation and reduce energy consumption

Promotion of long-term Power Purchase Agreements (PPAs) in Greece.

• HERON offers long-term Power Purchase Agreements (PPAs) to large commercial and industrial consumers, secured through corresponding agreements with photovoltaic park producers. In 2024, HERON further expanded its portfolio by signing the first long-term Upstream Wind PPA in the Greek energy market, with a capacity of 40 MW.

• HERON’s strategy is fully aligned with national and EU targets, supporting the competitiveness of Greek enterprises, increasing the penetration of renewable energy sources (RES) in the energy mix, and accelerating the development of new RES projects through bilateral commercial agreements with end consumers.

• In 2024, more than 30 industrial and commercial clients trusted HERON, securing long-term green energy supply contracts with fixed and competitive pricing. These agreements correspond to an installed capacity of 80 MW in photovoltaic parks, or an annual production of 135,000 MWh, significantly contributing to the clients’ green development goals.

Issuance of guarantees of origin (GOs): Provision of Guarantees of Origin to business clients upon request, as well as to residential customers who choose the ECO GENEROUS commercial programs. These Guarantees of Origin—or Green Certificates—are issued by the RES and Guarantees of Origin Operator (DAPEEP) in accordance with EU Directives 2003/54/EC and 2009/72/EC and national legislation, certifying that a specific quantity of electricity was generated from RES.

Replacement of the passenger vehicle fleet with electric and hybrid vehicles.

Upgrade of lighting and air conditioning equipment using energy-efficient technologies.

Integration of energy-saving principles into construction projects—where feasible—through building insulation, use of energy-efficient windows, and optimization of natural lighting and ventilation.

Support for obtaining green building certifications for construction projects, such as LEED, BREEAM.

The Group actively participates in national and international efforts to mitigate climate change and adapt to its inevitable impacts. With respect for the environment and society, the Group’s business model and strategy are fully aligned with its commitment to addressing the climate crisis.

As part of its ESG Policy implementation, the Group has established specific commitments regarding energy management and greenhouse gas (GHG) emissions, including actions to address climate change mitigation:

• Annual monitoring and reporting of GHG emissions across all Group subsidiaries.
• Implementation of targeted action plans to reduce the carbon footprint
• Procurement of Guarantees of Origin for 100% of the Group’s subsidiaries by 2030.
• Achieving a minimum 70% participation rate in energy-related training programs for all employees.

Through these initiatives and commitments, the Group aims to reduce its energy footprint and integrate climate-related risks into its operational processes, thereby strengthening its competitive advantage and long-term value for stakeholders.

At the same time, given the increasing frequency of adverse natural phenomena (extreme weather events, wildfires, floods, heightened seismic activity, etc.), the Group recognizes climate change adaptation as a critical issue. To enhance its resilience, it has conducted a resilience analysis to identify risks and opportunities associated with climate change that may affect the operations of its key business sectors.

The management of pollution and spill risks is of vital importance to the Group, as it is directly linked to its safe and socially responsible operation and the protection of the environment. The Group’s priority is to prevent all forms of land and marine pollution, to reduce air emissions in accordance with legislation and international standards, and to reduce their impact on health and the environment. In addition, the Group aims to reduce waste through prevention, recycling and reuse.

A key challenge for the Group is to effectively prevent any form of environmental pollution from its business activities, as well as to address potential industrial accidents. Possible pollution of air, water and soil is a permanent potential risk, as it may lead to a shutdown, affecting both the Group’s financial position and reputation. The objective is to avoid any pollution incident by applying preventive and suppressive measures in all areas of its business activity. Key preventive measures and practices to avoid and address water and air pollution risks applied in the Group are:

• Regular training of staff in good environmental practices.
• Regular environmental practices.
• Regular monitoring and monitoring of air pollution and air quality.
• Monitoring and monitoring of industrial pollution and the monitoring of industrial pollution.
• Responsible management of hazardous and non-hazardous waste.
• Systematic inspections of installations and construction sites.
• Adequate fire protection.
• The supply of sufficient quantities of spill kits for potential accidental spill management.

Given that plenty of the Group’s activities take place in biodiversity-sensitive areas, an environmental management system is applied across all operations. Within this framework, the following actions are carried out annually:

• Implementation of certified systems.
• Staff training on biodiversity protection at project sites.
• Initiatives promoting the protection and enhancement of local ecosystems (e.g. tree planting).
• Application of Best Available Techniques (BAT) in the industrial facilities’ production activities.

Through these actions, the Group aims to enhance positive impacts and minimise existing and potential negative effects from its operations, with the goal of avoiding biodiversity degradation incidents. Moreover, During the construction and operation of its projects, the Group prepares Environmental Impact Studies (EIS), Special Ecological Assessment Studies (SEA), Special Ornithological Studies (SEIS) and Monitoring Programmes in collaboration with specialised scientists and institutions. The aim of these actions is to obtain and use the information necessary to ensure the protection of local ecosystems by taking appropriate protection and restoration measures.

In total, the Group’s facilities (projects) cover an area of 163.6 hectares within biodiversity-sensitive zones, with one additional project located nearby, covering 29.8 hectares. Furthermore, the Group manages 87.5 kilometres of infrastructure within Natura areas, representing 6% of the total length of its motorway portfolio.

Restoration of Areas and Construction Sites

The Group’s commitment to biodiversity conservation is reflected in its efforts to restore the natural landscape of areas used for business activities and initiatives aimed at protecting local ecosystems.

In 2024, the Group maintained 26,322 trees across an area of 9.6 hectares that had been planted in previous years as part of restoration projects in areas where renewable energy projects have been developed. The operational expenditure allocated for these actions amounted to €68,000.

As part of the construction of the E65 motorway, the Group initiated in 2023 and continues to implement the restoration of two old, inactive quarries with a total area of 43,600 m², located in the municipalities of Lamia and Domokos. The restoration uses excavation materials and includes both morphological rehabilitation of the terrain and vegetative restoration through planting.

Circular economy is a strategic pillar of the Group’s ESG approach, reinforcing the sustainability of its business model and making a substantial contribution to environmental protection. Its principles are applied horizontally across key operational areas, with the aim of:

• Preserving and optimally utilizing natural resources and raw materials
• Effectively managing waste
• Enhancing efficiency throughout the entire lifecycle of products and services

This approach is embedded within the Group’s broader sustainable development framework and supports the transition toward a more resilient and environmentally responsible business ecosystem.

Preservation of Natural Resources and Raw Materials

Responsible selection of raw materials is a key priority for the Group, as it directly impacts both the quality of its projects and its environmental and energy footprint. In this context, emphasis is placed on the use of high-specification materials that are durable under extreme weather conditions and have a low environmental impact, thereby supporting sustainability and the circular economy.

At the same time, for specific categories of waste, the Group promotes the reuse or recycling of materials (e.g. excavation, construction, and demolition materials) to meet the needs of other business activities. This practice contributes to waste reduction, conservation of natural resources, and the interconnection of operational units through circular material flows.

Development of waste management projects

The Group invests in the development of waste management projects through Public-Private Partnerships (PPPs), which form part of its broader environmental strategy. These initiatives support the transition to a more circular and resilient resource management model. Notable examples include the Integrated Waste Management Units in the Regions of Epirus and the Peloponnese.

Waste management

The Group implements a holistic waste management program for both hazardous and non-hazardous waste, with the primary objective of reducing both the volume and the hazardous nature of the waste generated. At the same time, it aims to continuously improve environmental performance indicators, with a strong focus on avoiding landfill disposal and promoting material recovery.

Waste management practices are structured around a prioritized hierarchy of actions aligned with circular economy principles, placing emphasis on waste prevention, preparation for reuse, and recycling. Final disposal is considered only when no other viable alternative exists and is always carried out in accordance with applicable legislation. Through this approach, the Group enhances resource efficiency, minimizes environmental impacts, and promotes the sustainable operation of its activities.

Waste management is conducted in compliance with the Approved Environmental Terms, internal procedures, and project-specific requirements, in collaboration with licensed entities for the collection, recovery, treatment, and final disposal of waste.

The rational and responsible management of water is highlighted as an essential issue of the Group’s environmental strategy, highlighting the high sense of responsibility towards both the natural environment and the human rights of local communities. The Group is taking initiatives to manage water resources more efficiently, implementing continuous improvement practices and programmes across its operations. In particular, the Group’s efforts focus on:

• Regular training of staff in the proper and responsible management of water.
• The analysis of risks and impacts of unsound water management.
• Investigating water recycling and reuse practices.
• The implementation of an Environmental Management System.
• Water consumption reduction programmes.
• Responsible water disposal.