Sustainability Report 2025

Appendices

GRI2-2 GRI2-3 GRI2-4 GRI2-5 ATHEX ESGA-G5 ESRS2 BP-1

About this Report

The Sustainability Report constitutes the thirteenth (13th) edition of GEK TERNA Group, covering the period from 01/01/2025 to 31/12/2025. It is available in digital format on the Group's website.

The Report refers to the full range of the Group's business activities related to sustainable development and corporate responsibility, reaffirming our commitment to continuous progress and value creation for all stakeholders. The purpose of the Report is to provide accurate and consistent information regarding the actions, performance, and commitments of GEK TERNA Group on environmental, social, and governance (ESG) issues, through both quantitative and qualitative data.

The Group's financial statements cover the same period and are supplemented by interim semi-annual financial statements. The responsibility for the assessment, collection, and completeness of the quantitative and qualitative data included in the Report lies with GEK TERNA Group.

Scope of the Report

The data in the Report cover GEK TERNA Group, including its offices, facilities and subsidiaries in Greece and abroad. The Report has been prepared on a consolidated basis, with the scope of consolidation being consistent with that of the financial statements. Minor restatements due to recalculations – where applicable – are indicated with relevant footnotes in the text.

Defining Content

This Report has been prepared "In Accordance" with the GRI Sustainability Reporting Standards, specifically the new GRI Universal Standards (GRI 1, GRI 2, GRI 3) and the applicable GRI Topic Standards. Its objective is to address the needs and expectations of stakeholders and to highlight the Group's contribution to sustainable development. In addition, the European Sustainability Reporting Standards (ESRS) have been taken into account, as GEK TERNA Group has published its Sustainability Statement within the Group's Annual Financial Report.

To determine the content of the Report, internationally recognized reporting frameworks were considered, including the Sustainability Accounting Standards Board (SASB Standards) and the ESG Reporting Guide of the Athens Stock Exchange (ATHEX). The Group's impacts have also been mapped against the 17 United Nations Sustainable Development Goals (SDGs).

The analysis of material sustainability topics, based on the Double Materiality Assessment, has significantly shaped the content of this Report. It focuses on the most important issues for GEK TERNA Group stakeholders and those with significant environmental, social, and economic impacts.

All indicators included in the Group's Sustainability Statement—prepared in compliance with the requirements of the Corporate Sustainability Reporting Directive (CSRD, EU Directive 2022/2464) and Law 5164/2024—and incorporated into the Group's Annual Financial Report, have been externally assured and are presented in the Appendix Table.

For 2025, the Group obtained limited external assurance in the context of issuing its Sustainability-Linked Bond, as well as for the indicators included in the CSRD Report, which forms part of the 2025 financial statements.

GEK TERNA Group values every reader's feedback on the content of this Report, as it contributes to meaningful dialogue and continuous improvement. For this purpose, you are invited to share your comments and/or questions using the contact details provided below:

Contact Person for the Sustainability Report

Danae Kalantidi

85, Mesogeion Ave., Athens, 115 26 Greece
P: + 30 210 6968000
E-mail: dkalantidi@gekterna.com

COORDINATORS

Division of Corporate Social Responsibility and Sustainable Development

DIVISIONS / DEPARTMENTS

Health & Safety, Environmental and Energy Management
Human Resources
Financial Department
Regulatory Compliance Unit
Data Protection Unit

GRI2-28

Participation in Associations and Industry Bodies

GEK TERNA Group continuously develops and enhances its strategy for the benefit of shareholders, investors, employees and society, aiming to strengthen its network of partnerships and promote responsible business operations.

In this context, it actively participates in numerous organizations and bodies, contributing to the strengthening of collaboration, dialogue and transparency, while also integrating the principles of Sustainable Development into its activities.

A detailed list of the organizations and associations the Group is a member or collaborates with is provided below:

SEV — Hellenic Federation of Enterprises
IOBE — Foundation for Economic and Industrial Research
Hellenic-American Chamber of Commerce
Arab-Hellenic Chamber of Commerce
Hellenic Business Association of Albania
Hellenic-French Chamber of Commerce and Industry
ACCI — Athens Chamber of Commerce & Industry
HAIPP — Hellenic Association of Independent Power Producers
TCG — Technical Chamber of Greece
SATE — Panhellenic Association of Limited Technical Companies
STEAT — Association of Technical Companies of the Highest Classes
Hellenic Business Association of Serbia
Serbian Chamber of Commerce
Nicosia Chamber of Commerce and Industry
Hellenic Business Council in Bulgaria
Qatar Chamber of Commerce and Industry
Hellenic-Italian Chamber of Commerce
HELLASTRON — Hellenic Association of Toll Road Network
PEDMEDE — Panhellenic Association of Engineers Contractors of Public Works
ESPEN — Hellenic Association of Energy Suppliers
PASEPPE — Panhellenic Association of Environmental Protection Companies
EEDSA — Hellenic Solid Waste Management Association
SME — Greek Mining Enterprises Association
Alliance for Greece
Climate Governance Initiative Greece
Euromines
I.O.AS — Road Safety Institute «Panos Mylonas»
Hellenic Institute of Customer Service
CSR Hellas

ESRS Content Index^*

The table below presents the mapping of GEK TERNA Group's disclosures against the ESRS standards, with references to the relevant sections of the Report.

ESRS Standard	Disclosure	Section / Reference
ESRS 2	SBM-1: Market position, strategy, business model(s) and value chain SBM-2: Interests and views of stakeholders SBM-3: Material impacts, risks and opportunities and their interaction with strategy and business model IRO-1: Description of the processes to identify and assess material climate-related impacts, risks and opportunities GOV-1: The role of the administrative, management and supervisory bodies	Group Activities Stakeholder Engagement Double Materiality Assessment Double Materiality Assessment Corporate Governance Model
ESRS E1	E1-3: Actions and resources in relation to climate change policies E1-5: Energy consumption and mix E1-6: Gross Scopes 1, 2, 3 and Total GHG emissions	Actions for Energy Management Energy Management Greenhouse Gas Emissions
ESRS E4	E4-2: Policies related to biodiversity and ecosystems E4-3: Actions and resources related to biodiversity and ecosystems E4-5: Impact metrics related to biodiversity and ecosystems change	Biodiversity and Ecosystem Protection Actions targeted to Ecosystem Needs Actions targeted to Ecosystem Needs
ESRS S1	S1-1: Policies related to own workforce S1-4: Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions S1-6: Characteristics of the undertaking's employees S1-7: Characteristics of non-employee workers in the undertaking's own workforce S1-8: Collective bargaining coverage and social dialogue S1-9: Diversity metrics S1-10: Adequate wages S1-13: Training and skills development metrics S1-14: Health and safety metrics S1-16: Compensation metrics (pay gap and total compensation) S1-17: Incidents, complaints and severe human rights impacts	Safeguarding Human Rights Occupational Health & Safety Our People Our People Freedom of Association and Employee Dialogue Equal Opportunities, Diversity and Inclusion Employee Training & Development Occupational Health & Safety Equal Opportunities, Compensation, and Benefits Code of Conduct Violations Reporting
ESRS S2	S2-1: Policies related to value chain workers	Safeguarding Human Rights
ESRS G1	G1-1: Business conduct policies and corporate culture	Code of Conduct

* All ESRS indicators have received external assurance as part of the Sustainability Statement, which is incorporated into the Group's Annual Financial Report.

GRI Content Index

Statement of Use GEK TERNA Group has based its Sustainability Development Report on the GRI Standards for the period from 01/01/2025 to 31/12/2025.

GRI Standards Used GRI 1: Foundation 2021

Applicable GRI Sector Standards N/A

GRI Standard	Disclosure	Section / Reference
General Disclosures
GRI 2: General Disclosures	2-1: Organizational details	GEK TERNA Group
	2-2: Entities included in the organization’s sustainability reporting	About this Report
	2-3: Reporting period, frequency and contact point	About this Report
	2-4: Restatements of information	About this Report
	2-5: External assurance	About this Report
	2-6: Activities, value chain and other business relationships	Sustainable Supply Chain
	2-7: Employees	Our People
	2-8: Workers who are not employees	Our People
	2-9: Governance structure and composition	Corporate Governance Model
	2-10: Nomination and selection of the highest governance body	Selection, Training and Evaluation of Senior Management
	2-11: Chair of the highest governance body	Corporate Governance Model
	2-12: Role of the highest governance body in overseeing the management of impacts	Corporate Governance Model
	2-14: Role of the highest governance body in sustainability reporting	ESG Strategy
	2-15: Conflicts of interest	Conflicts of Interest
	2-16: Communication of critical concerns	Code of Conduct Violations Reporting
	2-17: Collective knowledge of the highest governance body	Selection, Training and Evaluation of Senior Management
	2-18: Evaluation of the performance of the highest governance body	Selection, Training and Evaluation of Senior Management
	2-19: Remuneration policies	Remuneration Policy and Transparency Principles
	2-22: Statement on sustainable development strategy	ESG Strategy
	2-23: Policy commitments	Code of Conduct
	2-24: Embedding policy commitments	Code of Conduct
	2-25: Processes to remediate negative impacts	Code of Conduct Violations Reporting
	2-26: Mechanisms for seeking advice and raising concerns	Code of Conduct Violations Reporting
	2-27: Compliance with laws and regulations	Regulatory Compliance Code of Conduct
	2-28: Membership associations	Participation in Associations and Industry Bodies
	2-29: Approach to stakeholder engagement	Stakeholder Engagement
	2-30: Collective bargaining agreements	Freedom of Association and Employee Dialogue
Material topics
GRI 3: Material topics	3-1 Process to determine material topics	Double Materiality Assessment
	3-2: List of material topics	Double Materiality Assessment
	3-3: Management of material topics	Double Materiality Assessment
Environmental Footprint
GRI 3: Material topics	3-3: Management of material topics	Climate Change Mitigation and Adaptation Energy Management Biodiversity and Ecosystem Protection
GRI 302: Energy	302-1: Energy consumption within the organization	Energy Management
GRI 303: Water and Effluents	303-1: Interactions with water as a shared resource	Responsible Water Resources Management
GRI 303: Water and Effluents	303-3: Water withdrawal	Responsible Water Resources Management
GRI 304: Biodiversity	304-2: Significant impacts of activities, products and services on biodiversity	Biodiversity and Ecosystem Protection
GRI 305: Emissions	305-1: Direct (Scope 1) GHG emissions	Greenhouse Gas Emissions
	305-2: Energy indirect (Scope 2) GHG emissions	Greenhouse Gas Emissions
	305-3: Other indirect (Scope 3) GHG emissions	Greenhouse Gas Emissions
GRI 306: Waste	306-1: Waste generation and significant waste-related impacts	Resource Management and Circular Economy
	306-2: Management of significant waste related impacts	Resource Management and Circular Economy
	306-3: Waste generated	Resource Management and Circular Economy
	306-4: Waste diverted from disposal	Resource Management and Circular Economy
	306-5: Waste directed to disposal	Resource Management and Circular Economy
Social Impact
GRI 3: Material topics	3-3: Management of material topics	Our People Occupational Health & Safety Equal Opportunities, Equal Opportunities, Diversity and Inclusion Supporting Local Communities
GRI 401: Employment	401-1b: Total number and rate of employee turnover	Employee Turnover
GRI 401: Employment	401-2: Benefits provided to full-time employees that are not provided to temporary or part-time employees	Equal Opportunities, Compensation, and Benefits
GRI 403: Occupational Health	403-1: Occupational health and safety management system	Health and Safety Management System
	403-2: Hazard identification, risk assessment, and incident investigation	Occupational Health & Safety
	403-3: Occupational health services	Health and Safety Management System
	403-4: Worker participation, consultation, and communication on occupational health and safety	Occupational Health & Safety
	403-5: Worker training on occupational health and safety	Occupational Health & Safety
	403-7: Prevention and mitigation of occupational health and safety impacts directly linked by business relationships	Occupational Health & Safety
	403-8: Workers covered by an occupational health and safety management system	Health and Safety Management System
	403-9: Work-related injuries	Occupational Health & Safety
GRI 404: Training and Education	404-1: Average hours of training per year per employee	Employee Training & Development
GRI 404: Training and Education	404-2: Programs for upgrading employee skills and transition assistance programs	Employee Training & Development
GRI 405: Diversity and Equal Opportunity	405-1: Diversity of governance bodies and employees	Equal Opportunities, Diversity and Inclusion
GRI 405: Diversity and Equal Opportunity	405-2: Ratio of basic salary and remuneration of women to men	Equal Opportunities, Compensation, and Benefits
GRI 406: Non-discrimination	406-1: Incidents of discrimination and corrective actions taken	Equal Opportunities, Diversity and Inclusion
GRI 408: Child Labor	408-1: Operations and suppliers at significant risk for incidents of child labor	Safeguarding Human Rights
GRI 409: Forced or Compulsory Labor	409-1: Operations and suppliers at significant risk for incidents of forced or compulsory labor	Safeguarding Human Rights
GRI 413: Local communities	413-1 Operations with local community engagement, impact assessments, and development programs	Supporting Local Communities
GRI 203: Indirect Economic Impacts	203-1: Infrastructure investments and services supported	Creation of Direct and Indirect Economic Value
Governance & Business Responsibility
GRI 3: Material topics	3-3: Management of material topics	Business Ethics
GRI 205: Anti-Corruption	205-3: Confirmed incidents of corruption and actions taken	Business Ethics
GRI 418: Customer Privacy	418-1: Substantiated complaints concerning breaches of customer privacy and losses of customer data	Protection and Security of Personal Data
GRI 204: Procurement practices	204-1 Proportion of spending on local suppliers	Sustainable Supply Chain
Value Creation
GRI 3: Material topics	3-3: Management of material topics	Creation of Direct and Indirect Economic Value
GRI 201: Economic performance	201-1: Direct economic value generated and distributed	Creation of Direct and Indirect Economic Value

ATHEX ESG Content Index

The table below presents the mapping of GEK TERNA Group disclosures against the ESG indicators of the Athens Stock Exchange ESG Reporting Guide, organized into Core, Advanced and Sector-Specific metrics.

ATHEX ESG Area	ID	KPI Description	Section / Reference
CORE METRICS
Environment	C-E1	Scope 1 emissions	Greenhouse Gas Emissions
	C-E2	Scope 2 emissions	Greenhouse Gas Emissions
	C-E3	Energy consumption and production	Energy Management
	C-S1	Stakeholder engagement	Stakeholder Engagement
Society	C-S2	Female employees	Our People Equal Treatment & Human Rights
	C-S3	Female employees in management positions	Equal Treatment & Human Rights
	C-S4	Employee turnover	Employee Turnover
	C-S5	Employee training	Employee Training & Development
	C-S6	Human rights policy	Safeguarding Human Rights
	C-S7	Collective bargaining agreements	Freedom of Association and Employee Dialogue
	C-S8	Value chain	Sustainable Supply Chain
Governance	C-G1	Board composition	Corporate Governance Model
	C-G2	Sustainability oversight	Double Materiality Assessment
	C-G3	Materiality	Double Materiality Assessment
	C-G4	Sustainability policy	ESG Strategy
	C-G5	Business ethics policy	Code of Conduct
	C-G6	Data security policy	Protection and Security of Personal Data
ADVANCED METRICS
Environment	A-E1	Scope 3 emissions	Greenhouse Gas Emissions
	A-E2	Climate change risks and opportunities	Climate Risks & Opportunities
	A-E3	Waste management	Resource Management and Circular Economy
	A-E4	Water management	Responsible Water Resources Management
	A-E5	Biodiversity sensitive areas	Biodiversity and Ecosystem Protection
	A-E8	Total GHG emissions	Greenhouse Gas Emissions
Society	A-S1	Sustainable economic activity	EU Taxonomy Disclosures
	A-S2	Employee training expenditure	Employee Training & Development
	A-S3	Gender pay gap	Equal Opportunities, Compensation, and Benefits
	A-S4	CEO pay ratio	Equal Opportunities, Compensation, and Benefits
Governance	A-G1	Strategy, business model and value chain	Value Chain and Business Relationships Sustainable Supply Chain
	A-G2	Business ethics violations	Business Ethics
	A-G3	ESG targets	ESG Priorities & Targets
	A-G5	External assurance	About this Report
SECTOR-SPECIFIC METRICS
Environment	SS-E6	Backlog cancellations	Biodiversity and Ecosystem Protection
Society	SS-S5	Data security and privacy fines	Protection and Security of Personal Data
	SS-S6	Health and safety performance	Occupational Health & Safety
	SS-S9	Customer grievance mechanism	Code of Conduct Violations Reporting
	SS-S10	ESG integration in business activity	Sustainability-Linked Bond, ESG Strategy, Sustainable Supply Chain, Supporting Local Communities
Governance	SS-G1	Whistleblower policy	Code of Conduct Violations Reporting
	SS-G2	Critical risk management	Business Continuity
	SS-G3	Systemic risk management	Business Continuity

SASB Content Index

The table below presents the mapping of SASB indicators against the corresponding sections of the Sustainability Report.

SASB KPI	KPI	Section / Reference
IF-EN-00C	Total backlog	GEK TERNA Group
IF-EN-160a.1	Number of incidents of non-compliance with environmental permits, standards and regulations	Regulatory Compliance Biodiversity and Ecosystem Protection
IF-EN-320a.1	(1) Total recordable incident rate (TRIR) and (2) fatality rate for (a) direct employees and (b) contract employees	Occupational Health & Safety
IF-EN-510a.2	Total amount of monetary losses as a result of legal proceedings associated with charges of (1) bribery or corruption and (2) anti-competitive practices	Code of Conduct Violations Reporting
IF-EN-510a.3	Description of policies and practices for prevention of (1) bribery and corruption, and (2) anti-competitive behaviour in the project bidding processes	Code of Conduct

ISO Certifications

The table presents the ISO and related standards certifications held by each company/unit of the Group.

Company / Unit	ISO 14001	ISO 50001	ISO 45001	ISO 27001	ISO 37001	ISO 37301	ISO 22301	ISO 9001	ISO 27701	ISO 39001	ISO 19650	ISO 3834	ISO 41001	ISO 18788	GMP+	ELOT 1439:2013	Directive 2014/68/EU Annex III, Mod. H
GEK TERNA	✓	–	✓	✓	✓	✓	✓	✓	–	–	–	–	–	–	–	✓	–
TERNA S.A.	✓	✓	✓	✓	✓	✓	✓	✓	–	–	✓	✓	–	–	–	✓	✓
HERON	✓	–	✓	✓	–	–	✓	✓	✓	–	–	–	–	–	–	–	–
Iliochora	–	–	–	–	–	–	–	✓	–	–	–	–	–	–	–	–	–
TERNA Energy Asset Management	✓	✓	✓	✓	✓	✓	✓	✓	–	–	–	–	–	–	–	–	–
TERNA MAG	✓	–	✓	–	–	–	✓	✓	–	✓	–	–	–	–	✓	–	–
Kentriki Odos	✓	–	✓	–	–	✓	✓	✓	–	–	–	–	–	–	–	–	–
Nea Odos	✓	–	✓	–	–	✓	✓	✓	–	–	–	–	–	–	–	–	–
GEK TERNA Motorway Operations Division	✓	–	✓	–	–	–	✓	✓	–	–	–	–	–	–	–	–	–
GEK Services Motorway Operation & Maintenance	✓	–	✓	–	–	–	✓	✓	–	✓	–	–	–	–	–	–	–
GEK Services Facility Management	✓	✓	✓	–	–	–	✓	✓	–	✓	–	–	✓	✓	–	–	–
Nea Attiki Odos Concession	✓	–	✓	–	–	–	–	✓	–	–	–	–	–	–	–	–	–
Nea Attiki Odos Operation	✓	–	✓	–	–	–	–	✓	–	✓	–	–	–	–	–	–	–
Dikteon Concessions	✓	–	✓	–	–	–	–	✓	–	–	–	–	–	–	–	–	–
Dikteon Operation	✓	–	✓	–	–	–	–	✓	–	✓	–	–	–	–	–	–	–