Environmental
Footprint

The Group implements an integrated Environmental and Energy Management System aimed at the timely identification and analysis of environmental and energy risks. This approach enables continuous improvement in environmental performance and the effective implementation of the Group’s strategy to reduce environmental impacts. The steps of the strategy are as follows:

The Environmental Management System of the Group and its subsidiaries, namely TERNA, TERNA LEFKOLITHI, NEA ODOS, KENTRIKI ODOS, HERON Group, and GEK SERVICES, is certified in alignment with the international standard ISO 14001:2015. In addition, TERNA applies an Energy Management System, certified according to ISO 50001:2018, across all its projects and facilities.

The Group conducts annual internal audits across all its operational activities, to ensure compliance with the approved environmental terms, as applicable to each facility and operational function, as well as with the requirements set by internal systems procedures and the respective ISO standards. Through these audits, the Group enhances transparency, responsibility, and operational resilience, making a meaningful contribution to achieving its sustainability objectives and ensuring compliance with the prevailing regulatory and institutional framework.

The internal audit process supports the achievement of the following objectives:

The Group implements targeted measures to ensure the efficient management of energy consumption and the responsible use of natural resources across all its operations. Within this context, it systematically records and monitors energy consumption across offices, construction sites, and facilities, with the aim of assessing its energy needs and implementing actions to reduce consumption.

In 2025, the Group’s total energy consumption amounted to 5,605,664.2 MWh (20,180.4 TJ). Energy use comprises electricity consumption as well as fuels for stationary and mobile combustion. Total electricity consumption reached 111,098.5 MWh, of which 66.2% originated from renewable sources, either through the procurement of Guarantees of Origin or through self-consumption of electricity generated from renewable energy sources (RES).

Energy consumption across the Group’s operations primarily relates to the use of construction machinery, vehicles, and electromechanical equipment, as well as combustion units, generators, and lighting needs.

At the same time, the Group implements the following measures on an annual basis to ensure the effective application of its ESG Policy and its commitments to reducing its energy footprint and contributing to global decarbonization efforts.

HERON Group, continuously striving to evolve and adapt to new market conditions with a focus on People, the Environment, and Society, has implemented targeted actions and initiatives to actively contribute to enhancing energy efficiency and reducing the environmental impact of its operations.

HERON offers its corporate customers the opportunity to actively participate in the management of the National Electricity System through the Demand Response service. Through this service, participating consumers commit to flexibly increasing or decreasing their energy load upon signal from ADMIE, thereby fulfilling a reserve role that was traditionally held exclusively by generation units. In return, they are compensated for the flexibility provided, transforming an operational capability of their facilities into a source of revenue.

The service is particularly important in the context of the energy transition: as the share of renewable energy sources (RES) in the energy mix increases, the variability of generation makes demand-side management necessary as a complementary means of system balancing. Demand Response leverages precisely this flexibility on the consumption side, contributing to the reduction of the need to activate conventional peak units, with direct benefits for grid stability, the environmental footprint of the system, and the overall cost of energy for the market.

HERON Group is pioneering in the Greek electricity market through the development of innovative products that combine financial benefits for the consumer with a contribution to the energy transition and grid stability.

In this context, HERON designed and launched to the market the HERON Happy Hour program family, which constitutes a comprehensive smart pricing solution that dynamically leverages wholesale market price signals to benefit both consumers and the grid simultaneously. On a daily basis, when generation from Renewable Energy Sources (RES) peaks and market prices decline, HERON's trading desk identifies the optimal three-hour window and guarantees three consecutive hours of electricity with zero supply charge to participating customers who have a smart (remotely read) meter by HEDNO. Customers are informed the previous day through a notification from the EnergiQ by HERON application, allowing them to plan in advance the use of high energy-consuming appliances — washing machine, dishwasher, electric vehicle charging — within the zero-charge window.

The value of the Happy Hour programs is not limited to the immediate financial relief for the consumer. Through shifting demand to hours of peak RES generation, the programs contribute to smoothing the load curve, reducing the required withdrawals from the grid, and more broadly to the absorption of green energy that would otherwise be curtailed. They therefore constitute a market-neutral demand response mechanism that benefits system stability and the market overall. For 2025, the savings achieved by active users of the program are estimated to correspond to a return of approximately 12% on their bill.

At the core of the consumer experience is the EnergiQ by HERON application, which provides daily notifications for zero-charge hours, hourly consumption data, and personalized energy-saving advice. Through the application, HERON transforms the consumer from a passive recipient of the energy system into an active participant in the green transition.

HERON Group, leveraging its unique synergy with TERNA ENERGY within the framework of GEK TERNA Group, has become a pioneer in the development of corporate long-term Green Electricity Power Purchase Agreements (PPAs) in the Greek market. By the end of 2025, HERON maintained an active portfolio of 22 corporate PPAs, with total contracted energy of 93.3 GWh annually, serving industrial companies and large commercial customers across various sectors of the Greek economy. Through PPAs, customers secure long-term access to electricity from Renewable Energy Sources (RES) at a stable, competitive price, typically over a horizon of ten to twenty years, while simultaneously gaining predictability in their energy costs and documented reduction of their carbon footprint, as each MWh is accompanied by a corresponding Guarantee of Origin (GO) from Greek RES plants.

At the same time, HERON offers the option to enter into Virtual Power Purchase Agreements (VPPAs), an innovative financial solution particularly suited to large organizations with geographically distributed facilities. Unlike a physical PPA, a VPPA is a purely financial Contract for Differences: the buyer pays the RES producer a fixed price per MWh, while the generated energy is fed into the wholesale market. The buyer continues to procure physical energy from its usual supplier, but receives the corresponding Guarantees of Origin, which substantiate the use of renewable energy for GHG accounting purposes in accordance with the GHG Protocol (Scope 2, market-based method). In this way, companies that are unable to directly contract physical green energy gain access to a reliable and regulatorily recognized decarbonization tool, fully aligned with the requirements of CSRD/ESRS and the EU Taxonomy.

The dual offering of PPAs and VPPAs positions HERON as a key intermediary between RES generation capacity and the corporate sustainability objectives of its customers. At the same time, each PPA concluded contributes to the financing of new RES projects, strengthening "additionality" in the Greek energy mix and accelerating the national energy transition. The utilization of Optimus Energy, a subsidiary of HERON Group with a leading presence in the aggregation of RES plants, further enhances the capability to structure and manage complex long-term energy supply agreements.

Within the framework of its strategy for the energy transition, HERON has developed the "Energeies Brosta" green services portfolio, through which it offers its customers — residential and business — integrated solutions for energy generation, efficiency, and sustainable energy management. These services reflect the Group's belief that the energy transition is not only about large-scale projects, but is implemented daily on the rooftop, in the home, and in the workplace of every citizen.

Overall, the "Energeies Brosta" portfolio reflects HERON Group's strategic choice to accompany customers at every step of their energy transition — from generation and heating to electromobility — offering solutions that are accessible, economically viable, and environmentally responsible.

With the aim of directly serving drivers of Electric and Hybrid vehicles, HERON is developing a nationwide Electromobility Network, under the name HERON Pulse, offering electric vehicle charging points in both standard (AC) and fast (DC) charging categories.

Charging points are located at existing and new locations across the road network nationwide (in publicly accessible areas, roads, and motorways). Through the dedicated application made available to the public in 2024, HERON provides users with the ability to locate charging points within the available HERON Network and recharge their vehicles, benefiting from competitive pricing.

Recognizing the decisive role of technological innovation in shaping a sustainable and climate-neutral energy future, HERON has established a specialized Applied Research and Development (R&D) Team. The mission of the team is to develop innovative solutions that accelerate the sustainable transition, through:

The technologies developed adopt a progressive and customer-centric energy management model, contributing substantially to the achievement of sustainability targets at both national and European level.

Within the framework of its active participation in 13 European HORIZON research projects and one project co-funded by the NSRF (ESPA), HERON collaborates with stakeholders from the academic and research sector, innovation companies and startups, as well as major European energy companies. Through these collaborations, HERON has already developed and is piloting tools that enable consumers to monitor and manage their total electricity consumption — including electric vehicle charging — and to be informed about the share of energy originating from Renewable Energy Sources (RES).

More specifically, HERON has developed a smartphone application (mobile application) through which users can:

The operation of the application is based on the use of advanced smart metering devices (meters, sockets, relays, etc.), while the development of both the application and the metering infrastructure is supported and financed by the European Programs in which HERON participates.

HERON's strategic objective is the evolution of the developed tools into comprehensive digital services, which will be made available to its customers on a large scale. These services will enhance the active participation of consumers in energy management, promote transparency in consumption, contribute substantially to the reduction of their carbon footprint, and support the achievement of national and European sustainability targets.

Through the implementation of this strategy, HERON confirms and strengthens its role as a dynamic driver of sustainable energy transition, offering solutions that integrate technological innovation with environmental responsibility.

The Applied Research & Development Team of HERON Group, within the framework of European Research Programs, implements thematic pilots to test new products and services in a low-risk environment.

HERON's innovative activity extends beyond electricity and into the natural gas sector, where the Group participates in the development and pilot implementation of a digital solution for optimizing heating consumption. The solution leverages advanced Machine Learning algorithms that analyze in real time the behavior of heating systems, weather conditions, and consumption patterns, dynamically adjusting their operation to achieve optimal energy performance. In this way, conventional heating installations are transformed into "smart devices", capable of achieving energy savings of up to 30% compared to their conventional operation — with a direct impact on both the consumer's cost and the CO₂ emissions associated with building heating.

This technology falls within the broader framework of the energy efficiency objectives set by the Energy Performance of Buildings Directive (EPBD) and is aligned with reporting requirements under the CSRD/ESRS framework, particularly with regard to reducing energy intensity in the building stock.

HERON, through its Applied Research and Development team, actively contributes to the implementation of the commitments arising from the National Energy Efficiency Action Plan (NEEAP), within the framework of implementing Article 7 of Directive (EU) 2023/1791 on Energy Efficiency. The Group's initiatives — ranging from the development of smart consumption optimization tools to the promotion of self-generation and electromobility — constitute measurable energy-saving interventions that are aligned with the monitoring and evaluation mechanisms coordinated by the Centre for Renewable Energy Sources and Saving (CRES). In this way, HERON is not limited to the role of an energy supplier, but assumes an active role in the national effort to achieve energy efficiency targets, linking its commercial activity with the systematic reduction of the energy intensity of the Greek economy.

Circular economy constitutes a core pillar of the Group’s ESG approach, enhancing the sustainability of its business model and contributing substantially to environmental protection. Its principles are applied horizontally across key operational areas, with the aim of:

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

Responsible selection of raw materials is a key priority for the Group, as it directly affects both the quality of its projects and its environmental and energy footprint. In this context, emphasis is placed on using high-quality materials, characterized by resilience to extreme weather conditions and low environmental impact, thereby supporting efficient resource utilization and the application of circular economy principles.

At the same time, for specific waste streams, the Group promotes the recovery of materials that can be recycled or reused (e.g., excavation, construction, and demolition materials) to meet the needs of other operational activities. The adoption of this practice delivers multiple benefits, including waste reduction, conservation of natural resources, and enhanced connectivity between business units through circular material flows.

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 Peloponnese. Through the operation of these facilities, the following outcomes are achieved:

Of the total waste (both hazardous and non-hazardous) resulting from the operation of the Group’s companies and the facilities/projects under construction, 11.7% was recovered through recovery methods (R), specifically 214,585.8 tons of non-hazardous waste and 4,623.6 tons of hazardous waste. Compared to the 2024 performance, a slight increase in hazardous waste and a significant decrease in non-hazardous waste are observed.

The management method for all waste from the Group’s operations and waste generation by waste stream are reflected in the following charts:

Compared to 2024, total waste generated in 2025 decreased by 25.2%. The proportion of hazardous waste showed a slight increase, while non-hazardous waste decreased significantly in absolute terms. At the same time, recovery performance improved, with the share of waste directed to recovery increasing from 9.9% in 2024 to 11.7% in 2025.

An extensive recycling system is applied across all Group’s offices, construction sites, and facilities, covering materials such as paper, aluminum, glass, plastic, electronic and electrical equipment, lamps, and batteries. Collection is carried out through designated bins, while further material recovery is ensured through partnerships with specialised and licensed operators.

Emphasis is placed on waste electrical and electronic equipment (WEEE), which is directed to certified recycling facilities with the aim of recovering valuable metals and raw materials. At the same time, the release of hazardous substances, such as heavy metals, into the environment is prevented, while promoting the principles of the circular economy and the sustainable use of natural resources.

The EU Taxonomy Regulation (EU 2020/852) is a fundamental tool of the European Commission for achieving climate neutrality by 2050, by redirecting capital flows toward sustainable and inclusive economic growth. According to the Regulation, to assess the eligibility of an economic activity, it must be verified whether the activity is included in the EU Taxonomy and whether it contributes to one or more of the following six environmental objectives:

According to the Delegated Regulations, non-financial undertakings are required to disclose the proportion of their economic activities that are eligible and aligned with the EU Taxonomy, based on the following key performance indicators:

For an economic activity to be considered environmentally sustainable and aligned with the EU Taxonomy, the following conditions must be cumulatively met:

The assessment process, in line with the Regulation’s requirements, includes five key stages:

For the financial year 2025, the Group’s eligible and taxonomy-aligned economic activities primarily relate to activities contributing to the environmental objectives of climate change mitigation and adaptation.