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HELLENiQ ENERGY Holdings S.A.
Annual Financial Report, Financial Year 2025
HELLENiQ ENERGY Holdings S.A.
Annual Financial Report
Financial Year 2025
General Commercial Register Number 296601000
Maroussi, February 2026

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Contents

1. Statements of Members of the Board of Directors | 5
2. Board of Directors’ Report |  | 7
| A. The Company and the Group | 13
| B. Corporate Governance | 57
| C. Sustainability Statement | 113
| D. Board of Directors’ Explanatory Report | 285
| E. Appendix | 290
3. Full Year Audited Financial Statements |  | 299
4. 4. Independent Certified Auditor – Accountant’s A udit Report | 412

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Pursuant to the provisions of article 4, par. 2c, Law No. 3556/2007, we
Spilios Livanos, Chairman of the Board of Directors,
Andreas Shiamishis, Chief Executive Officer and
Georgios Alexopoulos, Deputy Chief Executive Officer and General Manager Group Strategic Planning & New
Activities,
state that to the best of our knowledge:
a. The Annual Consolidated and Company Financial Statements, which were prepared in accordance with the
applicable International Financial Reporting Standards (IFRS), fairly represent the assets and liabilities, the equity
and results of “HELLENiQ ENERGY Holdings S.A.” for the fiscal year 2025, as well as of the companies that are
included in the consolidation taken as a whole.
b. The Annual Report of the Board of Directors fairly represents the evolution, performance and financial position
of “HELLENiQ ENERGY Holdings S.A.”, as well as of the companies included in the consolidation taken as a whole,
including the description of the main risks and uncertainties they face and was prepared in accordance with the
sustainability reports’ standards stated in article 154A of Law 4548/2018 and with the standards approved by
virtue of par. 4 of article 8 of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June
2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU)
2019/2088.
Maroussi, 26 February 2026
By delegated authority by the Board of Directors

Spilios Livanos | Andreas Shiamishis | Georgios Alexopoulos
Chairman | Chief Executive Officer | Deputy Chief Executive Officer and General Manager Group Strategic Planning & New Activities

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BoD Report's Contents

| Introduction | 11
| Group at a Glance | 12
A. The Company and the Group | 14
| A.1 | About Us | 14
| A.2 | Shareholders Information | 15
|  | a) Shareholding Structure | 15
|  | b) Share Performance | 16
| A.3 | Strategy | 18
|  | Intro | 20
|  | a) Refining, Supply & Trading and Petrochemicals | 20
|  | b) Marketing | 20
|  | c) Power | 21
|  | d) Exploration & Production | 22
|  | e) E-mobility | 22
|  | f) Digital Transformation | 23
| A.4 | Operating Environment | 25
|  | a) Economy | 25
|  | b) Industry Environment | 27
|  | c) Geopolitical Events | 35
| A.5 | Group Business Review | 36
|  | a) Financial Highlights | 36
|  | b) Review per Segment – Performance and Financial Position | 37

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|  | c) Selected Alternative Performance Measures | 47
|  | d) Related Party Transactions | 49
| A.6 | Risks and Uncertainties | 52
|  | a) Main Risks and Uncertainties for the Next Financial Year | 52
|  | b) Financial Risk Management | 52
|  | c) Capital Risk Management | 55
|  | d) Borrowings | 56
B. Corporate Governance | 57
| B.1 | Corporate Governance Statement | 58
|  | Β.1.1 Corporate Governance Code | 59
|  | Β.1.2 Deviations from the Corporate Governance Code | 60
|  | Β.1.3 Other Corporate Governance Practices | 61
|  | Β.1.4 Main Features of the Systems of Internal Controls and Risk Management | 62
|  | Β.1.5 Information Required - Directive 2004/25/EU | 67
|  | Β.1.6 General Meeting & Shareholders’ Rights | 68
|  | Β.1.7 Composition and Operation of the BoD | 72
| B.2 | Audit Committee's Activity Report | 97
|  | Β.2.1 Introduction | 97
|  | Β.2.2 Purpose of the Committee and Key Responsibilities | 97
|  | Β.2.3 Composition of the Committee, Skills and Experience | 99
|  | Β.2.4 2025 Key Highlights and 2026 Action Plan | 100
|  | Β.2.5 Committee Meetings | 102
|  | Β.2.6 Financial Reporting & External Audit | 104
|  | Β.2.7 | External Auditors | 106

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|  | Β.2.8 Internal Audit/System of Internal Controls/Risk Management/ Regulatory Compliance/Corporate Governance/Cybersecurity | 108
|  | Β.2.9 Sustainable Development Policy | 110
|  | Β.2.10 Conclusion s | 112
C. Sustainability Statement | 113
| C.1 | General Disclosures - ESRS 2 | 116
| C.2 | Environment | 166
|  | EU Taxonomy Report | 169
| C.3 | Social | 234
| C.4 | Governance | 276
D. Board of Directors’ Explanatory Report | 285
E. Appendix | 290
| E.1 | BoD Members’ CVs | 291
| E.2 | General Managers' CVs | 296

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Introduction
Dear Shareholders,
This Annual Board of Directors’ report of “HELLENiQ ENERGY Holdings S.A.” (hereinafter “HELLENiQ ENERGY” or
“Company”), covers the twelve-month period of fiscal year 2025 (01.01.2025-31.12.2025). The report has been
prepared in accordance with and is in line with the relevant provisions of articles 150-154 of Law 4548/2018, of
article 4 of Law 3556/2007, and the decisions of the Hellenic Capital Markets Commission, especially decision
8/754/14.4.2016 of the Board of Directors of the Hellenic Capital Markets Commission. The Annual Consolidated
and Company Financial Statements have been prepared in accordance with the International Financial Reporting
Standards ("IFRS"), as adopted by the International Accounting Standards Board ("IASB") and approved by the
European Union, ((IFRS refers to IFRS Accounting Standards).
This report contains both financial and non-financial information pertaining to the HELLENiQ ENERGY Group
(Group) and the parent company “HELLENiQ ENERGY Holdings S.A.” for the fiscal year 2025. It includes a detailed
description of significant events that took place during that period and their impact on the annual financial
statements. Furthermore, the principal risks and uncertainties that the Company and the Group may encounter
during the next financial year are described. It also enumerates the material transactions conducted between the
Company and its related parties and illustrates the alignment of the main intangible resources with the Group's
business model, aimed at generating value for both the Group and its operating environment. Finally, the report
provides information and qualitative projections concerning the progression of the Company’s and the Group’s
operations in the next financial year, while presenting the most significant non-financial information anticipated
to influence the Company and the Group.
In accordance with the provisions of Law 5164/2024 (Government Gazette A 202/12.12.2024), which transposed
Directive (EU) 2022/2464 of the European Parliament and of the Council concerning corporate sustainability
reporting, also known as the Corporate Sustainability Reporting Directive (CSRD), into Greek Law, the
Management Report encompasses, among other elements, the Company’s business model, its resilience to
climate-related risks, the value chain, and an analysis of significant impacts thereon. Furthermore, it includes the
Sustainability Policy adopted by the Company and the Group, as well as pertinent information necessary to
comprehend how sustainability issues influence the strategy, performance, and financial position of the Company
and the Group.

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A1. Group at a Glance

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A.1 About Us
The Group consists of 97 companies, including the Parent Company, which is listed on the Athens Exchange and
on the London Stock Exchange (through Global Depository Receipts -GDRs-). The list of subsidiaries and associate
companies, the nature of their business, the percentage of ownership and consolidation method for each one of
them, are included in the Section 3. Full Year Financial Statements:
The list of the Group's principal consolidated subsidiaries and associates is available in Note 36 of the
Financial Statements.
The Group has established a business structure to manage and monitor its activities. Specifically, all Group
activities are classified into the following key segments (Strategic Business Units):
• Refining, Supply and Trading
• Production and Trading of Petrochemicals
• Marketing (Domestic and International)
• Power (Renewable Energy Sources and Power & Gas)
• Exploration and Production of Hydrocarbons
• Electromobility
Additionally, the Group is engaged in other activities that, despite their strategic importance (e.g., Engineering
Services), do not constitute a significant part of the Group's financial position.

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A.2 Shareholders Information
a) Shareholding Structure of HELLENiQ ENERGY
The Company is listed on the Athens Exchange (ATHEX), while its shares are also traded in the form of Global
Depository Receipts (GDRs) on the London Stock Exchange. Furthermore, the bond issued by its subsidiary
HELLENiQ ENERGY Finance Plc (HEF) (4.25% coupon, due 24 July 2029), is listed on Euro MTF Platform of the
Luxembourg Stock Exchange.
The shareholding structure of the Company as of 31.12.2025 was as follows:

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b) Share Performance
In 2025, the ΑΤΗΕΧ Composite Share Price Index recorded an increase of 44.3%, reflecting increased investor
interest in Greek equities, due to continued economic growth and increased profitability of listed companies. The
enhanced confidence of international investors attracted increased capital inflows, while, during 2025, the
transition of ATHEX to developed markets was announced by FTSE Russell (effective from 21 September 2026),
with increasing expectations for a similar upgrade by other index providers.
HELLENiQ ENERGY Holdings' ("Company") shares recorded an increase of 10.6% in 2025, closing at €8.36 on 31
December 2025. Over the course of the year, the average daily trading volume amounted to 309,866 shares, with
an average price of €7.94. The total shareholders return (TSR), inclusive of dividends, for 2025 amounted to
21.5%.
During the Annual General Meeting of the Shareholders held on 19 June 2025, it was decided that a total dividend
of €0.55 per share would be distributed for the financial year 2024. It is noteworthy that an interim dividend of
€0.20 per share had already been distributed, resulting in a final dividend of €0.75 per share.
The following table presents the average closing price of the Company's shares and the average daily trading
volume per month for the financial year 2025, as well as the corresponding period in 2024.

| Average Closing Price | Average Trading Volume
| (€) | (# shares)
| 2025 | 2024 | 2025 | 2024
January | 7.57 | 7.25 | 171,354 | 539,823
February | 7.79 | 7.87 | 260,914 | 555,875
March | 7.77 | 8.20 | 262,986 | 461,160
April | 7.45 | 8.24 | 220,132 | 228,338
May | 7.68 | 8.50 | 194,399 | 234,216
June | 7.87 | 8.17 | 246,464 | 306,758
July | 7.76 | 7.66 | 247,202 | 299,640
August | 8.34 | 7.08 | 296,366 | 213,400
September | 8.37 | 7.06 | 306,825 | 140,301
October | 8.18 | 6.99 | 784,667 | 162,656
November | 8.12 | 6.78 | 441,443 | 144,688
December | 8.43 | 7.19 | 258,214 | 191,842
Average | 7.94 | 7.58 | 307,580 | 289,891

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Share price evolution chart for HELLENiQ ENERGY Holdings S.A.
The following chart shows the share price evolution at the closing of each month as well as the average daily
trading volume of the Company’s shares from 01.01.2025 up until 31.12.2025:

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A.3 Strategy
HELLENiQ ENERGY’s strategic plan VISION 2025 has successfully delivered on its objectives, validating
our initial strategic choices for a balanced transition. We consistently met our commitments by future-
proofing and optimizing our refinery operations through decarbonization, expanding our international
presence in the downstream business, and establishing a vertically integrated Power business as a second
growth pillar, while evolving our governance and operating model.
Our strategic compass for the next phase of growth is VISION 2030+, which is designed to navigate a
rapidly evolving energy landscape, drive growth through diversification, and deliver sustained value to
shareholders. VISION 2030+ focuses on the continuous improvement of competitiveness in Downstream
activities, expanding the presence in international markets, as well as the transformation of the Power (RES,
power and natural gas) business into an autonomous, vertically integrated platform, while leveraging
synergies at the Group level.
Our strategy focuses on further developing and growing our two key pillars: Hydrocarbons & Sustainable Fuels
and Power.
1. In the Hydrocarbons & Sustainable Fuels, our key strategic initiatives include: Pursue selective growth
investments, b) leverage the trading platform to optimize supply and capture market opportunities, c)
decarbonize operations to reduce refineries' energy consumption by meeting operational electricity needs
through renewable energy sources utilization and carbon capture solutions implementation, d) maintain
operational excellence across the existing asset base, e) explore Downstream growth opportunities in the
Southeast Europe, f) strengthen the Marketing footprint and expand the value proposition (premium fuels,
EVs, non-fuel retail), g) invest selectively in sustainable fuels to secure post-2030 positioning and develop
options in hydrogen and e-fuels, while h) maintaining exposure to potential upstream value creation through
exploration partnerships.
2. In the Power business, our key strategic initiatives include: Regionally expand, hybridize and technologically
diversify the renewables portfolio, b) invest in flexible generation assets and battery storage, c) grow and
improve performance of commercial business, d) further build-up project development and energy trading
capabilities, all while e) maximizing energy management synergies from our integrated generation portfolio.

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Operating model & governance
Horizontal initiatives support the delivery of strategic objectives across the Group. These include accelerating
digital transformation and AI adoption, reinforcing operational and cost excellence, leveraging human capital,
while continuing adjustments towards fit-for-purpose governance and operating model.
Our ambition is to achieve a 30% reduction in our GHG footprint by 2030, complemented by an additional 20%
emissions avoidance through the expansion of the RES portfolio. We will continue to closely monitor regulatory
developments related to CCS, with a long-term commitment to achieving net-zero emissions by 2050.

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Main objectives per business area
a) Refining, Supply & Trading and Petrochemicals
In the area of refining supply, trading and petrochemicals, our key priorities encompass ensuring safety,
decarbonizing processes, enhancing energy efficiency and autonomy, digital transformation, expanding
petrochemicals’ production capacity, leverage of our trading capabilities in the new Geneva desk, investing in
cleaner fuels alongside continues operational excellence.
Key strategic initiatives include:
• Strengthening safety through training, standards, and enhanced procedures.
• Advancing digital transformation across the supply chain, predictive maintenance, and process safety
systems.
• Supplying system crude and feedstocks, trading system products and expanding the trading business
through Geneva-based HELLENiQ Petroleum Trading.
• Implementing energy efficiency and autonomy projects across all refineries.
• Evaluating a new 250 ktpa Alkylate unit at the Aspropyrgos refinery (AIC), with the aim of reaching a final
investment decision in early 2027.
• Developing a standalone 150 ktpa SAF production unit.
• Developing the “Green Hub North” project (PV/BESS and direct high-voltage connection to the Thessaloniki
refinery - TIC) and “Green Hub South” project (direct PV/Wind/BESS connections to EIC/AIC).
• Advancing CCS through conversion of the SMR unit at the Elefsina refinery (EIC).
• Exploring hydrogen, recycling, and synthetic fuel opportunities, including:
◦ E-methanol and e-jet fuels using captured CO₂ and green hydrogen.
◦ E-ammonia utilizing excess electricity from Green Hub North and green hydrogen.
• Upgrading and expanding polypropylene production units, resulting in a capacity increase to 300 ktpa from
240 ktpa.
b) Marketing
Domestic Marketing
The EKO Excellence transformation program advanced through its second and third phases in 2025,
strengthening market positioning, improving profitability, expanding premium fuels and services, and progressing
toward net-zero energy through EV chargers and PV installations across the station network.
The main initiatives of the program include:
• Network rationalization and expansion.
• Increasing the market share of COMO service stations and premium products.
• Expanding the range of products and services (non-fuel retail (NFR), EV charging services, loyalty programs).

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• Implementing a "net-zero energy" solutions at COMO stations.
• Developing tailored commercial strategies for industrial clients.
International Business
The objective is to strengthen our footprint in the Southeast European markets focusing on sustainable growth
and operational excellence.
Key priorities include:
• Maintaining a leading positions and growing market share in Cyprus, Montenegro and the Republic of North
Macedonia.
• Expanding in Bulgaria and Serbia through targeted network growth and supply chain optimization.
• Enhancing the range of products and services, including loyalty programs and EV charging.
• Installing photovoltaic systems across our petrol station network to achieve net zero targets .
• Improving OKTA profitability and leveraging the reactivation of the VARDAX pipeline to reduce
transportation costs and explore potential trading opportunities in the region.
• Exploring cross-border electricity trading opportunities, particularly in Cyprus and the Republic of North
Macedonia.
• Assessing market entry into new regional markets.
• Advancing retail digitalization to enhance customer experience and optimize operating costs.
c) Power
1. Renewable Energy Sources (RES)
The Group aims to secure a leading regional position in the renewables market through:
• Developing a 1.5 GW portfolio of operational capacity by 2028, and 2 GW by 2030 across of PV, wind and
battery storage projects.
• Commercializing renewable assets and exploring vertical integration in the Southeast Europe.
• Advancing offshore wind development.
The Group has established a strong position in Greece and selected international markets, with a development
pipeline of approximately 6 GW in Greece, Cyprus, Romania and Bulgaria. Operating capacity reached 506 MW in
2025, with an additional 1 GW of projects under construction or in advanced development stages.
2. Enerwave
HELLENiQ ENERGY aims to build a best-in-class power business, leveraging synergies across refining, marketing,
renewable energy and e-mobility businesses.
Aligned with this strategy, the Group completed the acquisition of the former ELPEDISON and introduced its new
corporate identity, Enerwave, marking a major milestone in its transformation.

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Strategic priorities include:
• Growing and improving the commercial business performance.
• Integrating generation assets, including refinery demand response, to enhance margins.
• Delivering the upgrade of the Thisvi plant by 2027.
• Optimizing gas sourcing through captive demand.
• Strengthening energy trading capabilities.
• Driving operational excellence.
• Enhancing energy management in coordination with the RES portfolio.
d) Exploration & Production
The Group is well positioned to benefit from potential upstream discoveries in partnership with Chevron and
ExxonMobil.
• Performing seismic acquisitions in four newly awarded offshore blocks with Chevron.
• Finalizing the exploration drilling decision for Block 2 with ExxonMobil.
• Reaching drill-or-drop decisions for Southwest Crete and Block 10, and evaluating commencement of a
second exploration phase for West Crete block.
e) E-mobility
The Group continues to expand its presence in the EV charging market in Greece and internationally. Growth
initiatives focus on enhancing customer e-mobility solutions, expanding the DC fast-charging infrastructure at
fuel stations and key locations, and developing AC charging networks across public, semi-public, and private sites.

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f) Digital Transformation
HELLENiQ ENERGY's Digital Transformation Program, an essential component of the Group's strategy, is
progressing successfully, by upgrading the way our people work, supporting performance improvement initiatives
and expanding its footprint in new areas of business activity.
So far, more than 180 digital initiatives have been initiated or completed across the organization, involving over
2,000 people in various working groups and utilizing more than 5,000 hours of specialized training.
Additionally, it brings substantial benefits in safety and risk management efficiency, helps reduce the
environmental footprint, and promotes a culture of innovation.

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The multi-year action plan consists of a multitude of initiatives with substantial investment in technology-
based projects across 5 pillars:
1. Digital Refinery, with the objective of evolving into a modern, collaborative, interconnected refinery.
2. Digital Retail, with the objective of delivering the service stations of the future, offering enhanced digital
experiences, more information and improved services to partners and corporate customers.
3. Digital Enterprise Operations, aiming at more efficient operations through automation and more effective
decisions by utilizing a wide range of data.
4. Digital Core, aiming at the modernization of the central enterprise resource management (ERP) system by
leveraging the latest technological advancements.
5. Productivity CoE & AI, aiming to scale digital productivity and accelerate AI and GenAI adoption across the
Group to improve collaboration, efficiency and decision‑making.
The Digital Transformation program was launched six years ago, with a cumulative investment amounting to €75
million, and has yielded substantial financial returns. Cumulative benefits have already exceeded €150 million and
are expected to reach €200 million by the end of 2027. Additionally, the estimated annual benefit is estimated
that it has exceeded €50 million and projected to reach €70 million by the end of 2028.
In 2026, a new wave of initiatives and projects is planned, within which the integration and expansion of artificial
intelligence technologies have already been initiated and are being further developed. These initiatives aim to
further accelerate the Group’s Digital Transformation. These efforts are expected to strengthen safety and
competitiveness, support the adoption of best practices, streamline and standardize operations, improve the
employee work experience, and enhance collaboration with customers and partners.
1 IMF, Word Economic Outlook, January 2026
2 ECB, “Eurosystem Macroeconomic Projections”, December 2025

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A.4 Operating Environment
a) Economy
a.1) Global Economy 1,2
In the year 2025, the global economic environment experienced an expansion, driven by the combination of
moderating inflationary pressures and declining energy prices, accommodative monetary policies,
substantial investments in technology and AI, as well as robust fiscal expenditures in major economies. It is
estimated that the global economy grew by 3.3% in 2025. Looking forward to2026, it is anticipated that the
persistence of the aforementioned growth drivers, coupled with the diminishing impact of restrictive trade
policies, will support an annual economic growth rate of 3.3%.
In the advanced economies, Gross Domestic Product (GDP) is projected to have experienced an increase of 1.7% in
2025, following a 1.8% growth in 2024. In the emerging market and developing economies, the GDP is expected to
have grown by 4.4% in 2025, consistent with the 4.3% growth recorded in 2024. Projections for 2026 indicate
that economic growth will remain robust, with advanced economies and emerging market and developing
economies anticipated to achieve growth rates of 1.7% and 4.4% respectively.
In the Euro Area, economic growth experienced moderate acceleration during 2025, with an estimated GDP
increase of 1.4%, compared to the 0.9% growth rate recorded in 2024. The Euro Area economy has remained
generally subdued due the lingering effects of the post-Ukraine energy shock, which continued to weigh on
manufacturing activity, while the appreciation of the Euro relative to other currencies has affected export
competitiveness.
The European Central Bank (ECB) implemented four reductions to benchmark deposit rates during 2025, resulting
in a cumulative decrease of 100 basis points, with the objective of stimulating economic activity. Economic growth
in the Euro Area for 2026 is projected to reach 1.2%, supported by a combination of internal and external factors.
Domestic demand is expected to strengthen, underpinned by rising real wages and improved financing conditions
attributable to policy rate cuts initiated since 2024. Additionally, increased fiscal expenditures on infrastructure
and defense are anticipated to further bolster growth. On the external front, despite persistent structural
challenges, exports are expected to recover as uncertainties surrounding trade policy recede.
In the US, economic expansion was primarily driven by an increase in in technology-related investments,
accommodative financial conditions and resilient private sector demand. The estimated economic growth for
2025 in the US is projected at 2.1%, with projections indicating an acceleration to 2.4% in 2026, supported by
fiscal measures and a lower policy interest rate. Furthermore, the adverse effects of elevated trade barriers are
expected to fade gradually, as bilateral tariffs are scheduled to be reduced until November 2026. At the same
time, inflation pressures moderated during 2025; however, inflation remained relatively persistent due to
pass‑through effects of tariffs and ongoing cost‑of‑living challenges. The inflation target of 2% is expected to be
gradually reached within 2027.
In relation to emerging market economies, economic growth is expected to remain slightly above 4% in both 2026
and 2027, broadly stable compared with recent years, with China and India exhibiting even higher growth rates
during this period.
3 Bank of Greece, Monetary Policy, Interim Report 2025, December 2025

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a.2) Greek Economy 3
In 2025, the Greek economy is estimated by the Bank of Greece to have grown by 2.1%, broadly in line with its
2024 performance, despite heightened international uncertainty. Economic expansion was primarily driven by
private consumption, net exports, and investment. Private consumption benefited from favorable labor market
conditions, while net exports were supported mainly by strong services exports and reduced imports. Investment
also made a positive contribution, particularly in productive equipment and construction. Greece’s strong fiscal
performance continued into 2025, with Bank of Greece estimates pointing to a further decline in general
government debt as a share of GDP.
According to the Bank of Greece, solid economic growth, combined with fiscal overperformance and a marked
reduction in the debt-to-GDP ratio, has resulted in significant upgrades to Greece’s sovereign credit ratings. The
most recent upgrade was Fitch Ratings’ assignment of a ‘BBB’ rating in November 2025. Consequently,
international demand for Greek government bonds has strengthened and funding spreads between Greece and
its European peers have narrowed to pre-crisis levels.
The Bank of Greece projects economic growth to remain robust at 2.1% in both 2026 and 2027, before easing
slightly to 2.0% in 2028. Consumption is expected to remain the main growth driver, while investment, supported
by Recovery and Resilience Facility (RRF) funds, and exports are also projected to contribute positively. Inflation is
forecast to remain elevated in 2025 at 2.8%, largely reflecting anticipated increases in wages and rents, before
moderating to 2.1% in 2026 and 2.2% in 2027, closer to the European Central Bank’s target. On the fiscal front, the
general government primary surplus is expected to rise to 2.8% of GDP in 2026, while public debt is projected to
stabilize at 138.2% of GDP.
Regarding energy consumption, preliminary official data indicates that domestic fuel demand in 2025 amounted
to 6.9m MT, a 2.2% y-o-y increase. Demand for automotive fuels witnessed an increase of 1.5% (1.7% increase for
diesel and 1.2% increase for gasoline), while aviation fuels consumption increased by 5.9% y-o-y.
4 OPEC “Monthly Oil Market Report”, December 2025 / January 2026
5IEA, “Oil Market Report”, January 2026

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b) Industry Environment
b.1) Industry Environment Developments 4,5
According to estimates by the Organization of the Petroleum Exporting Countries (OPEC), global oil demand is
anticipated to have increased by an average of 1.6 mbpd in 2025 to 105.1 million barrels per day (mbpd). In 2026,
demand is projected to rise further by 1.4 mbpd to 106.5 mbpd, driven by stronger demand for transportation
fuels (gasoline, diesel, jet/kerosene), continued economic expansion, and ongoing industrial and infrastructure
development in non-OECD economies. Additional support is expected from rising feedstock demand in the
petrochemical and chemical industries.
Across regions, oil demand in OECD countries is expected to grow by 0.15 mbpd in 2026, while demand growth in
non-OECD regions, including Asia, Middle East, Africa, India and China, is anticipated to reach 1.2 mbpd. In Europe,
oil demand is expected to exhibit a marginal decrease in 2025 compared to 2024, reflecting subdued private
consumption, manufacturing, and construction activity.
Since early 2025, OPEC+ has begun reversing a substantial portion of its voluntary production cuts, resulting in a
more sufficiently supplied global market. According to IEA estimates, global oil supply increased by approximately
3 mbpd in 2025 to around 106.2 mbpd. For 2026, supply is expected to rise by a further 2.5 mbpd, lifting total
production to 108.7 mbpd, with non-OPEC+ countries accounting for 1.8 mbpd and 1.3 mbpd of the supply growth
in 2025 and 2026, respectively.
Crude oil prices declined in 2025, with Brent crude averaging $69.0/bbl, down 14.7% y-o-y, as global supply
outpaced demand. Expectations of market oversupply prospects outweighed the impact of sanctions, geopolitical
tensions, and elevated risk premiums, alongside record levels of strategic stockpiling by China. During the first half
of 2025, crude oil prices weakened amid concerns that escalating trade tariffs among major economies could
dampen economic activity and reduce global demand. In the second half of the year, announcements by OPEC+
regarding the gradual unwinding of production cuts, reinforced expectations of an oversupplied market, exerting
additional downward pressure on prices.
Regarding crude oil differentials, the average spread between Brent and West Texas Intermediate (WTI) narrowed
slightly to $4.2/bbl in 2025, compared with 2024.

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6 Refinitiv

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Refining Margins and Oil Products’ Cracks ($/bbl) 6
During 2025, the global refining environment benefited from tighter supply-demand balances, driven by robust
growth in oil product demand and ongoing supply disruptions, which led to an improvement in benchmark
refining margins. These factors became more pronounced toward year-end, as US and EU sanctions on Russian
companies and imports of Russian diesel coincided with elevated refinery maintenance activity, unplanned
refinery outages, and low product inventories.
The benchmark refining margins for the Med refineries increased y-o-y, as supply-demand balances have been
tighter throughout the year. According to LSEG, the FCC (Fluid Catalytic Cracking) benchmark margin averaged
$6.5/bbl in 2025 vs $3.8/bbl in 2024, whereas the Hydroskimming benchmark margin averaged $1.4/bbl in 2025
vs $-0.6/bbl in the respective period of last year.
In relation to product crack spreads, the diesel and gasoline crack spreads increased during 2025. By contrast, the
fuel oil and naphtha crack spreads decreased slightly throughout the same period. Specifically, the diesel crack
spread averaged $21.8/bbl in 2025 compared to $19.0/bbl in 2024, whereas the gasoline crack spread averaged
$14.6/bbl in 2025 vs $14.2/bbl in 2024. The high sulfur fuel oil (HSFO) crack spread averaged $-6.3/bbl during
2025 compared with $-10.6/bbl during 2024 and the naphtha crack spread averaged $-8.9/bbl vs $-10.8/bbl in
2024.
(Benchmark margins are expressed in $ per barrel)

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7 Bloomberg, EUA prices, January 2026
8 Electricity prices are based on the Day Ahead Market, Market Clearing Price, Energy Exchange Group, January 2026

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Natural Gas, electricity and EUA prices 7,8
During 2025, natural gas and electricity prices exhibited notable volatility. Specifically, the TTF Natural Gas price
averaged €36.4/MWh during 2025, a 5% y-o-y increase, primarily driven by reduced Russian gas flows through
Ukraine, alongside diminished levels of European inventories and stronger demand, driven by weather conditions,
increased energy needs and higher EUA prices leading to increased demand for natural gas. With regards to
electricity prices, the Day-Ahead Market Clearing Price in Greece averaged €103.8/MWh in FY25, +2.5% y-o-y.
Similarly, the EUA price experienced a 13% increase, averaging €74.2/T in 2025, compared to €65.5/T in the
corresponding period of the prior year.

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Exchange rate €/$
In 2025, the EUR / USD rate strengthened significantly, rising from a low of 1.03 in January to close the year at
1.17, averaging $1.13. The movement was primarily driven by a) diverging monetary policy paths in the second half
of the year, as the US Federal Reserve adopted a more accommodative stance compared with the European
Central Bank’s relatively neutral policy position, b) heightened trade tensions, including the introduction of tariffs,
which weighed on investor sentiment towards the USD and c) improved confidence in the underlying economic
fundamentals of the Eurozone.

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b.2) Key Business Developments
The key business developments were as follows:
• On April 11, 2025, HELLENiQ ENERGY Holdings S.A. signed an agreement to acquire 50% of the share capital
of Elpedison B.V., which holds 100% of Enerwave S.A. (formerly ELPEDISON). The acquisition was completed
on July 15, 2025, at a final consideration of €164 million, plus an amount of €19 million due to an increase in
cash reserves, resulting from differences in specific balance sheet items.
• On August 7, 2025, HELLENiQ RENEWABLES ROMANIA S.R.L. completed the acquisition of ANSTHALL
GREEN ENERGY S.R.L. from OX2 HOLDING NEW MARKETS AB. The company owns a ready-to-build wind
project in the Galati region of Eastern Romania, with a licensed capacity of 96 MW. At the same time, it
signed a binding agreement to acquire HELIOS & WIND ENERGY S.R.L., which owns another ready‑to‑build
wind project in the Vaslui region, with a licensed capacity of 186 MW and the option to install a battery
energy storage system of 186 MW / 186 MWh. Concurrently, HELLENiQ RENEWABLES BULGARIA EOOD
completed the acquisition of AGRO NV PROPERTIES EOOD from ELEMENT POWER GROUP EOOD. This
company owns a ready‑to‑build photovoltaic project in the Haskovo region of Southern Bulgaria, with a
capacity of 123 MWp, and the option to add a battery energy storage system of 90 MW / 180 MWh.
• In the Hydrocarbon Exploration and Production sector, the main business developments concerned: a) the
participation of HELLENiQ ENERGY Holdings S.A., together with Chevron, in the Call of Tenders issued by
the Ministry of Environment and Energy for hydrocarbon exploration and production in four offshore areas
south of the Peloponnese and south of Crete (announcement dated September 10, 2025); and b) the
signing, on November 6, 2025, of a Farm‑In Agreement between HELLENiQ ENERGY Holdings S.A.,
ExxonMobil, and Energean, for the participation of ExxonMobil in the concession of Block 2, in the
northwestern Ionian Sea.

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b.3) Significant Events after the end of the Reporting Period
Other than the events disclosed in note 31 of the financial statements, no significant events occurred after the end
of the date of submission of this report.
On 16 February 2026, HELLENiQ ENERGY Holdings, in partnership with Chevron, signed Lease Agreements with
the Hellenic Republic concerning the exploration of four offshore blocks located south of Crete and the
Peloponnese. The consortium, in which Chevron holds a 70% interest (operator) and HELLENiQ ENERGY Holdings
holds a 30% interest, was selected following an international tender process launched by the Greek State in 2025.
The four offshore blocks - South Crete 1, South Crete 2, South of Peloponnese, and Block A2 - cover a total area of
approximately 47,000 square kilometers.
c) Geopolitical Events
Geopolitical tensions persisted throughout the year 2025, predominantly centered on the protracted conflict
between Russia and Ukraine, as well as various hostilities in the Middle East, notably including a twelve-day
conflict between Israel and Iran during June 2025, in addition to escalating tensions between the United States
(US) and Venezuela. The US and the European Union imposed new sanctions on Russia, with European authorities
affirming their commitment to reducing energy dependence on Russia. Consequently, heightened uncertainty in
international trade and increased instability have resulted in significant disruptions to critical trade routes,
adversely affecting the stability of global supply chains. Moreover, a visible shift toward trade protectionism
through the introduction of new tariffs and regulatory restrictions has altered the global trade landscape,
rendering it increasingly fragmented, albeit with continued expansion in certain sectors. The Group diligently
monitors these developments and adjusts its operations in accordance with prevailing conditions.
9 The selected alternative performance indicators are listed in Chapter A.5 c

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A.5 Group Business Review
a) Financial Highlights 9
The main operational and financial Group indicators for 2025 are presented below:

Operational Data | 2025 | 2024
Refinery sales volume (in million metric tons) | 15.6 | 16.3
Marketing sales volume (in million metric tons) | 6.3 | 6.0
Refinery production (in million metric tons) | 15.0 | 15.4
Group employees | 4,192 | 3,734

Financial Data (in million €) | 2025 | 2024
Net sales | 11,615 | 12,768
Reported EBITDA9 | 736 | 811
Inventory effect – Loss (gain)9 | 329 | 128
Other special items9 | 67 | 88
Adjusted EBITDA9 | 1,132 | 1,026
Reported net income9 | 173 | 60
Adjusted net income9 | 503 | 401

The Group's operating profitability (Adjusted EBITDA) came in at €1,132 million (2024: €1,026 million).
In FY25, refining production and sales volume amounted to 15.0 million MT and 15.6 million MT respectively. The
favorable refining environment, coupled with the improved operational performance of the refineries, as well as
the contribution of HELLENiQ Petroleum Trading in exploiting opportunities in crude oil procurement, as well as in
product exports, outweighed the slightly lower production due to the general shutdown of the Elefsina refinery.
FY25 adjusted EBITDA from Refining, Supply & Trading came in at €891 million compared to €795 million in
FY24. The contribution from both Domestic and International Marketing, as well as the Power business, was
particularly improved, with Enerwave being consolidated in Group results from 15 July 2025.
Adjusted net income (as defined in chapter A.5 c) amounted to €503 million compared to €401 million in the prior
year, primarily due to lower net financial expenses. Inventory valuation losses (€329 million) due to crude and oil
product price decrease, led Reported EBITDA to €736 million, while Reported net income came in at €173 million.
Total investments amounted to €757 million, primarily directed to refineries’ maintenance, expansion in RES and
the Enerwave acquisition.

Balance Sheet / Cash Flow (in million €) | 31.12.2025 | 31.12.2024
Total Assets | 8,567 | 7,754
Total Equity | 2,728 | 2,762
Capital Employed9 | 4,867 | 4,554
Net Debt9 | 2,139 | 1,792
Net Cash Flows (operating & investing cash flows) | 180 | 295
Capital Investments (Cash Flow) | 757 | 434
Gearing ratio – Net Debt / Capital Employed | 44% | 39%

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b) Review per Segment – Performance and Financial Position
The main activities of the Group cover a wide range of the energy sector, making the HELLENiQ ENERGY Group
one of the leading energy groups in Southeast Europe.
Key points per activity are summarized below:
b.1) Refining, Supply and Trading
The Refining, Supply and Trading segment serves as the core business and principal source of revenue and
profitability for the Group.
The activities of the subsidiary HELLENiQ PETROLEUM S.A. focus on Greece where it operates the Group's three
refineries, located in Aspropyrgos, Elefsina, and Thessaloniki. These refineries collectively contribute to
approximately 63% of the country’s total refining capacity. The three refineries possess a combined storage
capacity of 6.9 million m³ for crude oil and petroleum products.
The refineries have distinctive technical characteristics, which are summarized in the table below. These
characteristics play a significant role in determining the financial performance and profitability of each refinery.

Refinery | Daily Refining Capacity (Kbpd) | Annual Refining Capacity (mil. MT) | Configuration Type | Nelson Complexity Index
Aspropyrgos | 146 | 7.6 | Cracking (FCC) | 9.7
Elefsina | 106 | 5.3 | Hydrocracking | 12.0
Thessaloniki | 90 | 4.5 | Hydroskimming | 5.8

In 2025, the international refining environment remained subject to significant volatility. Crude oil demand and
production were influenced by factors such as the ongoing conflict in Ukraine, European Union sanctions on
Russia, geopolitical developments in the Middle East, policy decisions by oil-producing countries regarding supply,
and the increase in global refining capacity resulting from new refineries becoming operational.
The Brent oil price has shown significant fluctuations throughout the year, ranging from $63 to $79 per barrel on a
monthly average basis. December recorded the lowest average price of the year, at $63 per barrel.
Natural gas prices exhibited a slight decline from February onwards, reaching their lowest point of the year in
December 2025.
Electricity prices experienced a significant decline after February, with this downward movement persisting
throughout the third quarter. In the final quarter, a notable increase in prices was observed; however, the price
levels remained below those recorded during the first two months of the year.
Total production in 2025 reached 15.0 million MT from 15.4 million MT in 2024, due to the general shutdown of
the Elefsina refinery in the second quarter of the year. Excluding the maintenance of the Elefsina Refinery, the
availability of the Refineries reached high levels.
Domestic market sales increased by 3.8%, aviation fuel sales rose by 1.8%, and bunker fuel sales grew by 2.2%.
Conversely, export volumes decreased by 10.2%, attributable to lower production levels and increased sales in the
aforementioned channels of trade. In 2025, total sales amounted to 15.6 million MT, reflecting a decline of 0.7
million MT from the previous year.
Regarding the refineries’ product mix, the yield of middle distillates (jet fuel, gasoil, and diesel) has increased to
52.4%, while gasoline accounted for 22%. As a result of optimized and efficient refinery operations, white
products comprised 87% of total output. The fuel oil yield has been effectively restricted to 8%.

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Crude Oil Supply
Since mid-2025, HELLENiQ Petroleum Trading, a Geneva-based subsidiary of the Group, has been managing
crude oil procurement. Supply requirements are fulfilled through a combination of term contracts and spot
purchases. Following Russia's invasion of Ukraine and subsequent European Union sanctions, the Group
discontinued Russian crude oil imports as of February 2022, pivoting to alternative grades sourced from the wider
surrounding region, as well as North Europe, Africa, Latin America, and the Middle East.
In 2025, the primary sources of crude supply were Kazakhstan, Iraq, Libya, Saudi Arabia, Norway and Egypt, which
collectively accounted for over 90% of the total crude oil supplies.
The percentage of intra-refinery transfers of intermediate products and raw materials reached 15% of the total
refining consumption, significantly contributing to the optimization of production, logistics and trading
operations.
Refinery Sales (Wholesale Trading)
HELLENiQ PETROLEUM S.A. is responsible for the distribution of fuels to domestic, marine, and aviation markets,
as well as supplying the Group’s international subsidiaries. The surplus production, representing approximately
50–60%, is exported via HELLENiQ Petroleum Trading, based in Geneva. All refined products of the Group comply
with the European standards (Euro VI).
Financial results and operational indicators:

Financial Results (in million €) | 2025 | 2024
Sales | 9,584 | 11,348
Adjusted EBITDA10 | 891 | 795
Operational indicators |  |
Sales Volume (000s MT) | 15,617 | 16,286
HELPE system benchmark refining margin (Year Average) | $7.5/bbl | $5.3/bbl

Key points for Refining, Supply and Trading in 2025:
• Benchmark refining margins declined in the first half of the year but rose substantially in the second half,
relative to 2024. The average benchmark refining margin for 2025 increased by $2.2/bbl y-o-y.
• Systematic optimization of the processed crude mix, with zero Russian grades imports.
• Successful completion of the planned maintenance shutdown of Elefsina refinery.
• Uninterrupted, optimized and in accordance with the plan operation of all refineries.

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b.2) Petrochemicals
Petrochemicals activities comprise the production and marketing of polypropylene, BOPP/Cast film and solvents,
along with the trade of chemicals. Based on its financial contribution, the propylene - polypropylene – BOPP/Cast
value chain represents the main activity for petrochemicals. The polypropylene production plant in Thessaloniki
primarily sources propylene from the Aspropyrgos refinery. A portion of the polypropylene output is utilized as a
raw material in DIAXON (BOPP and Cast film) plant in Komotini.
Approximately 65% of the petrochemicals’ sales volumes are directed towards the markets of Italy, the Balkans,
the Iberian Peninsula, Central Europe and Turkey, for use as raw materials in local manufacturing.
Financial Data and key operational indicators:

Financial Results (in million €) | 2025 | 2024
Sales | 284 | 300
Adjusted EBITDA10 | 18 | 54
Operational indicators |  |
Sales Volume (000s MT) | 279 | 262
PP benchmark margin (€/tn) | 154 | 333

Key points for Petrochemicals in 2025:
• The global petrochemical industry continued to face a challenging environment throughout 2025.
Production overcapacity in Asia, persistently subdued global demand, as well as higher energy and
production costs experienced by European manufacturers, collectively underscore the adverse
circumstances confronting the sector.
• Polypropylene production reached 252 KT, while propylene production from the Aspropyrgos refinery
amounted to 192 KT. The substantial integration between various units contributed to the profitability of the
petrochemicals business, despite the unfavorable international margins and adverse conditions.
• In this highly competitive and volatile environment, Petrochemicals' Adjusted EBITDA amounted to €18
million.

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b.3) Marketing
Fuels Marketing is divided into Domestic activities, which are carried out through the Greek subsidiary EKO ABEE,
and International activities.
Domestic Marketing
In Greece, the Group, through its subsidiary EKO ABEE, engages in the distribution and marketing of fuels under
the commercial brands EKO and BP, supplying 1,557 service stations, of which 237 are company operated.
EKO ABEE possesses the most comprehensive fuel supply network, comprising 16 storage and distribution
facilities, 23 aircraft refueling stations at major airports, 2 liquefied petroleum gas bottling plants, and one
lubricants production and packaging unit.
The domestic fuel market in 2025 exhibited expansion, primarily attributed to improved economic activity and
stronger tourism, as well as a marked rise in new vehicle registrations. Total gasoline consumption increased by
1.3%, while diesel consumption recorded an increase of 1.7%. Furthermore, total consumption of heating oil rose
by 9.0%. The aviation fuel market strengthened due to higher tourist traffic, resulting in an increase in
consumption by 5.9% compared to 2024. Moreover, the aggregate market for marine fuels demonstrated a
modest growth of 0.7%.
The market share of the EKO and BP brands experienced a notable increase in 2025 across all product categories,
with particularly strong performance in premium fuels. Furthermore, the leading position held by EKO in both
Aviation and Marine fuels was successfully sustained.
The Group extended its agreement with bp plc for the exclusive use of bp’s commercial brands for ground fuels in
Greece until the end of 2035.
International Marketing
The Group operates internationally through its subsidiaries located in Cyprus, Bulgaria, Serbia, Montenegro, and
the Republic of North Macedonia. As of 2025, the international network comprised 336 fuel stations (329 in
2024). This includes 29 stations operating under the brand name OKTA, a subsidiary of the Group in the Republic
of North Macedonia. In Cyprus and Montenegro, the local subsidiaries maintain leading positions in both retail and
wholesale markets. OKTA serves as the leading importer of fuels in the Republic of North Macedonia and holds a
substantial market share in the wholesale market of Kosovo. In contrast, the subsidiaries in Bulgaria and Serbia
possess relatively smaller market shares and primarily focus their activities on the retail sector.
Financial results and operational indicators:

Financial Results (in million €) | 2025 | 2024
Sales | 4,935 | 5,130
Adjusted EBITDA10 | 160 | 124
Operational Indicators |  |
Sales Volume (000s MT) - Total | 6,346 | 6,028
Sales Volume (000s MT) - Greece | 4,288 | 4,036
Fuel stations - Greece | 1,557 | 1,583
Fuel stations - International | 336 | 329

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Key points for the Domestic Marketing activities in 2025:
• Notable expansion in the market shares of gasoline, auto diesel and heating gasoil.
• Substantial increase in both the market shares and penetration of differentiated auto fuels (98 & 100 octane
gasoline, premium auto diesel).
• The company maintained a leading position in aviation and marine fuels.
• All key performance indicators (market shares, sales, profitability) exhibited growth within the company-
operated fuel station network due to increased productivity, with sales growth rates surpassing the
corresponding rates observed in the broader market.
• Significant growth in non-fuel sales of products and services (NFR), with substantial contribution in
profitability.
• Continuous development and enrichment of EKO Smile and BPme loyalty programs with customer-centric
and competitive offerings and services.
• Continuous strengthening and upgrading of the EKO and BP brands through new sponsorships.
Key points for the International Marketing activities in 2025:
• Profitability in 2025 improved compared to 2024, primarily driven by favorable market conditions that
positively contributed to unit margins. Furthermore, the expansion of our network and the revamping of the
stations’ image, enhanced fuel demand in the retail segment. However, this was partially offset by increased
operational expenses linked to inflationary pressures.
• In Cyprus, the retail segment's strong performance in both sales volume and unit margins contributed to
increased profitability, further supported by strong performance from the Commercial & Industrial (C&I)
segment, despite a notable rise in operating expenses. In 2025, EKO Energy Cyprus Ltd successfully entered
the energy market. Furthermore, the photovoltaic (PV) installation at the Vassiliko terminal was completed
and is fully operational.
• In Montenegro, profitability exceeded 2024 levels, primarily driven by growth in non-fuel revenue, increased
demand for fuel products across retail, aviation, and bunkering segments, as well as an improved unit
margin in the retail sector. This improvement was achieved despite higher operational expenses, which were
largely attributable to greater transaction volumes.
• In the Republic of North Macedonia, profitability improved relative to 2024 due to higher unit margins and
the commissioning of the 12 MW photovoltaic park at the end of 2024.
• In Bulgaria, profitability increased relative to 2024, primarily driven by higher retail unit margins and
volumes resulting from local market dynamics. This improvement was further supported by growth in non-
fuel revenue, despite an increase in operational expenses.
• Serbia experienced enhanced profitability in comparison to 2024, primarily because of higher retail unit
margins and increased sales volumes, with non-fuel revenue contributing to this growth. This improvement
was achieved notwithstanding an increase in operational expenses, which rose in accordance with labor
market trends.

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b.4) Power
b.4.1) Renewable Energy Sources (R.E.S.)
HELLENiQ Renewables Single Member S.A. (HELLENiQ Renewables), established in 2006, operates as a wholly
owned subsidiary of HELLENiQ ENERGY. The company plans to develop a substantial renewable assets portfolio
in the forthcoming years, with the objective of achieving >2 GW of operating capacity by 2030. This strategic
expansion is expected to contribute to the enhanced geographical diversification of HELLENiQ ENERGY’s
renewables portfolio across Greece, Cyprus, Romania, and Bulgaria, while facilitating the Group's entry into
additional markets and supporting the mitigation of environmental impact by offsetting greenhouse gas
emissions.
HELLENiQ RENEWABLES' total installed capacity as of the end of 2025 amounted to 494 MW, including 354 MW
of photovoltaic parks (PVs) and 99 MW of wind farms in Greece, as well as 41 MW of PVs in Cyprus. Furthermore,
approximately 6 GW projects, mainly PVs, wind farms and energy storage projects, are currently in various stages
of development.
Financial results and operational indicators:

Financial Results (in million €) | 2025 | 2024
Sales | 64 | 60
Adjusted EBITDA10 | 45 | 46
Operational Indicators |  |
Volume Generated (GWh) | 762 | 695
Installed Capacity (MW) | 494 | 494

Key points for RES in 2025:
• The operating portfolio at the end of 2025 amounted to 494 MW and generated approximately 762 GWh in
2025, delivering an annual emissions‑avoidance benefit of more than 255,000 tons of CO₂.
• Greece: In 2024 and 2025, the Company participated in the first Competitive Bidding Procedures organized
by RAAEY for storage projects, securing support for 5 BESS units (150 MW / 400 MWh). In November 2024,
HELLENiQ Renewables was granted the first RAAEY License of Ownership and Direct Line Management,
authorizing the electrical interconnection of a PV plant integrated with a BESS to the facilities of the
Thessaloniki refinery, with the aim of supplying the refinery with green energy. Furthermore, the
commencement of construction for a 200 MW photovoltaic plant in the Alexandroupolis region is scheduled
for 1Q26, with commercial operations anticipated to commence by the end of 2027.
• In June 2025, the acquisition of ABO Energy Hellas was completed, adding a 1.5 GW portfolio and a RES
development platform.
• Romania : In 2025, the implementation of the binding agreement concerning four PV parks with a total
capacity of 211 MW, continued. In June 2025, an agreement was signed for the acquisition of a 186 MW wind
farm (with BESS capability of 186 MW/186 MWh) in Vaslui, eastern Romania. In addition, in July 2025, the
acquisition of a 96 MW wind farm in Galati was completed, with commercial operations expected to
commence during 4Q27.
• Bulgaria: In July 2025, the acquisition of a ready‑to‑build 123 MW PV park, including BESS capability (90
MW/180 MWh), was completed.

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b.4.2) Enerwave
The Group operates across the electricity and natural gas value chain, encompassing power generation, wholesale
trading and retail supply of electricity, as well as the trading and supply of natural gas.
As part of strengthening its market position, the Group completed the transaction with Edison International
Shareholdings S.p.A., originally signed in December 2024, which resulted in the acquisition of 100% of
ELPEDISON S.A. on 15 July 2025. Following the completion of the acquisition and within the framework of the
Group’s corporate reorganisation, ELPEDISON was rebranded during 2025 as Enerwave, marking a new phase for
the Group’s electricity and natural gas activities.
Enerwave is currently one of the largest independent power producers in Greece, with total installed capacity of
851.6 MW from natural gas-fired combined cycle units (a 430 MW plant in Thessaloniki, in operation since 2005,
and a 421.6 MW plant in Thisvi, Boeotia, in operation since 2010). The company is active in electricity markets in
Greece and Southeast Europe through renewable asset aggregation, power trading and the trading of other
exchange-traded products. At the same time, it has a strong presence in the natural gas market in Greece and
across Europe through portfolio management and gas trading activities.
Enerwave is among the most reliable suppliers of electricity and natural gas in Greece and has expanded its retail
energy offering by promoting energy efficiency solutions through its retail network. In parallel, it has launched
activities for the provision of large-scale Energy Efficiency Services, targeting industrial facilities, large hotel
complexes, and office building clusters.
In 2025, the energy sector in Greece and Central and Eastern Europe experienced significant developments. Both
the electricity and natural gas markets underwent major shifts, characterized by a strategic focus on diversifying
sources of natural gas supply, strengthening energy infrastructure, and increasing the penetration of renewables,
which underscored the need for greater flexibility, expanded storage, and network upgrades. Within the EU, policy
initiatives aimed at reducing dependence on Russian natural gas progressed significantly. A detailed roadmap was
established for the complete phase‑out of LNG imports by 2026 and pipeline gas imports by 2027. At the same
time, efforts to enhance energy security, stabilize energy costs, and promote industrial competitiveness were
intensified, facilitating substantial progress towards green transition. Overall, the operating environment became
increasingly dynamic and demanding, presenting both new opportunities and heightened challenges for
participants in the energy market.
Electricity Sector
Power Generation and Energy Management
Domestic electricity demand in Greece reached 50.5 TWh in 2025, down 1.2% y-o-y, mainly due to milder weather
conditions. In 2025, the share of natural gas-fired generation increased significantly, accounting for 45% of the
country’s energy mix (2024: 39%), primarily as a result of reduced lignite and hydroelectric production and
exceptionally strong electricity exports to Southeast Europe.
Electricity Supply
In the retail electricity market, Enerwave increased its total market share to 6.3% (2024: 5.9%) amid intense
competition. The number of end customers rose by 2% to 309,000, while total sales reached 3 TWh. No major
regulatory changes occurred during 2025, with suppliers continuing to offer tariff schemes based on color-coded
pricing. Consumer preference increasingly shifted towards fixed-price (“blue”) tariffs, which recorded significant
uptake during the year.
Natural Gas
In the natural gas segment, Enerwave managed a portfolio exceeding 13 TWhg in 2025, serving the needs of its
power generation plants, retail supply activities, exports, trading operations and bilateral contracts with third
parties and industrial consumers. Market share exceeded 10%, with approximately 32,000 retail gas customers
served.

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Commercial performance benefited from increased LNG imports, which supported portfolio optimization and
contributed to greater price stability. At the same time, high withdrawals from European storage facilities and
generally ample global LNG availability enhanced market liquidity and improved supply conditions.
European-level strategic initiatives aiming at the gradual decoupling from Russian natural gas further
strengthened the region’s role in supply diversification, opening opportunities for more stable and competitive
sourcing models. However, certain challenges persisted. Weather-driven price volatility created periods of
uncertainty in wholesale markets, while rapid storage drawdowns at specific times increased supply cost
pressures. Moreover, although the long-term impact of reducing dependence on Russian gas is expected to be
positive, it introduced short-term uncertainty regarding future availability and price formation.
Other Activities
Research & innovation
Enerwave participates in the EU-funded projects HiRECORD and COREu under the Horizon Europe program, as
well as in the SUNBrewed project financed by the Innovation Fund.
Within the HiRECORD project, a pilot unit will be installed and operated at the Thisvi power plant in 2026, testing
an innovative carbon capture (CO₂) technology in an industrial environment. Under COREu, the captured CO₂ will
be compressed and temporarily stored in tanks before being transported and injected into the underground CO₂
storage reservoir in Prinos.
Finally, through the SUNBrewed project, the construction of an innovative solar thermal steam generation system
which will be subsidized at a rate of 60%. The produced steam will be supplied to an industrial brewery under a
Thermal Energy Purchase Agreement, achieving annual emissions reductions of approximately 2,192 tonnes of
CO₂.
Financial Results
Enerwave's FY25 Adjusted EBITDA increased by 27% y-o-y and amounted to €54 million. The contribution to the
HELLENiQ ENERGY Group's Adjusted EBITDA amounted to €26 million, as Enerwave is consolidated from 15 July
2025.

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b.5) Exploration and Production of Hydrocarbons
The exploration and production (E&P) business activities focus on offshore areas in Greece and are outlined
below:
• The Group, as operator (100%), holds exploration and production rights in the offshore area 'Block 10', in
Kyparissiakos Gulf. Currently, the Lease is in the 2nd Exploration Phase, which has a duration of three (3)
years, concluding on 9 July 2026. The Lessee has already completed a 2D seismic acquisition program
(1,200 km) and processing, and a 3D seismic acquisition survey (2,420 km2) and processing. Further
geological and geophysical studies are currently in progress, including WEB AVO analysis and special re-
processing.
• The Group holds E&P rights, as Operator (100%), in the offshore area of the “Ionian” block in Western
Greece. A 2D seismic acquisition survey and processing of 1,600 km has been completed, as well as a 3D
seismic acquisition survey of an area of 1,150 km2 and processing. The Lease runs the 2nd Exploration Phase,
which has a duration of three (3) years, concluding on 9 July 2026. Further geological studies are currently in
progress, including WEB AVO analysis.
• The Group holds a 25% interest in the offshore area of "Block 2", located west of Corfu Island, through a joint
venture with Energean Hellas Ltd. (75%, operator). The Lessee has completed a 3D seismic acquisition
(2,244 km2), processing and interpretation. In 2025, the Lessor, following an application of the Lessee,
granted a 12-month extension of the first Exploration phase, until 14 March 2026. In November 2025, a
farm-in agreement was signed for the transfer of part of HELLENiQ ENERGY's and Energean's share to
ExxonMobil. Upon completion of the process and obtaining the required approvals, by the end of the first
quarter of 2026, the JV is expected to be as follows: HELLENiQ ENERGY 10%, Energean 30% (Operator), and
ExxonMobil 60%.
• The Group holds E&P rights, with a 30% interest, in two (2) offshore blocks in Crete, ‘West Crete’ and
‘Southwest Crete’, in a JV with ExxonMobil Exploration & Production Greece (Crete) B.V. (70%, Operator).
During the period November 2022 – February 2023, a 2D seismic acquisition of 12,278 km was conducted in
the two (2) Cretan lease areas. The processing of the newly acquired seismic data was completed in
December 2023 and their interpretation is ongoing for West Crete. In March 2024, the Lessee proceeded
with the acquisition of 900 km2 of 3D Multiclient seismic data in the Southwest Crete Block and in April and
May 2024, the Lessee completed an extensive environmental sampling program in both Blocks. The 3D
reprocessing was completed in January 2025, and interpretation is ongoing.
• 25% participation in a consortium with Calfrac Well Services Ltd (75%) in the Sea of Thrace Concession,
North Aegean Sea, covering a total area of approximately 1,600 km2.
• In the context of the international tender (FEK 2104/30.04.2025) for the award of exclusive rights for the
exploration and exploitation of hydrocarbons in the offshore areas "Block A2", "South of Peloponnese",
"South of Crete 1" and "South of Crete 2", the JV of Chevron/HELLENiQ ENERGY submitted bids for all four
areas. On October 24th, 2025, the JV was declared as the "Selected Applicant" by the Minister of Energy. The
signing of the Lease Agreements is expected in the first quarter of 2026.
• With regards to the offshore ‘Block 1’ of the Ionian Sea, north of Corfu, the Group has submitted an offer
(100%, Operator) and awaits the decision of the Competent Authority.

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b.6) Electromobility Services
ElpeFuture, a 100% subsidiary of HELLENiQ ENERGY, operates as a Provider of Electromobility Services, as a
Charging Infrastructure Operator and as a Transaction Processing Agent.
ElpeFuture has continued its impressive growth in the fast-charging business, with a total of one hundred and
sixty (160) operational fast chargers ranging from 50 to 360 kW power (totaling 320 charging points) at fuel
stations nationwide. Alongside the ElpeFuture/EKO Charge&Go mobile application, which offers comprehensive
services for both spontaneous and registered users, including 24/7 support for charging point operators and end
users, the company has introduced OEM branded RFID cards in collaboration with automotive dealers in Greece.
The company's primary objective is to solidify its position in the electric vehicle charging market and expand its
fast and ultra-fast charging network at petrol stations, as well as AC charging units at points of interest.
Concurrently, ElpeFuture has already implemented AC charging facilities for corporate fleets in its B2B clientele
and aims to expand its network through further partnerships.
• One hundred and sixty (160) of 50-360 kW fast chargers operate at EKO and bp fuel stations (totaling 320
charging points), at motorway fuel stations and urban-type fuel stations. Five hundred forty four (544)
charging points of 22-180 kW are located in large shopping malls and in public parking lots, as well as, in
private parking areas of the Group's infrastructure and in B2B partners.
• The licensing process for the installation of additional fast chargers at EKO and bp fuel stations for up to 360
kW and for points of interest throughout the country is ongoing.
International Electromobility Operations
As of 2025, the Group's international subsidiaries—EKO Cyprus, EKO Bulgaria, EKO Serbia, Jugopetrol in
Montenegro and OKTA in Skopje—have collectively installed a total of 45 electric vehicle (EV) charging stations at
their respective fuel stations. Of these, 37 are currently operational (101 charging points). More specifically, 17 of
these chargers were installed within the year 2025, underscoring the swift expansion of the Group's EV charging
infrastructure. These installations enhance the Group's presence in the electromobility sector and provide
essential infrastructure to support the increasing adoption of electric vehicles throughout the region. Looking
forward, the Group intends to further expand its EV charging network by 2026, with the objective of installing an
additional 28 charging stations in these markets.

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c) Selected Alternative Performance Measures
This Report includes Alternative Performance Measures (“APMs”), i.e. certain measures of historical
financial performance, financial position, or cash flows, which are not defined or specified under IFRS. The
Group considers that the APMs are relevant and reliable in assessing the Group’s financial performance and
position, however such measures are not a substitute for financial measures under IFRS and should be read
in conjunction with Group published financial statements.
c.1) Presentation and Explanation of Use of Alternative Performance Measures
Reported EBITDA
Reported EBITDA is defined as earnings/(loss) before interest, taxes, depreciation and amortization, and is
calculated by adding depreciation and amortization back to operating profit.
Adjusted EBITDA
Adjusted EBITDA is defined as IFRS Reported EBITDA adjusted for: a) Inventory Effect (defined as the effect of the
price fluctuation of crude oil and oil product inventories on gross margin and is calculated as the difference
between cost of sales at current prices and cost of sales at cost) in the Refining, Supply & Trading segment and, b)
special items, which may include but are not limited to cost of early retirement schemes, write-downs of non-core
assets and other one-off and non-operating expenses, in line with the refining industry practice.
Adjusted EBITDA is intended to provide an approximation of the operating cash flow projection (before any Capex)
in an environment with stable oil and product prices.
ΙFRS Reported EBITDA and Adjusted EBITDA are indicators of the Group’s underlying cash flow generation
capability. The Group’s management uses the above alternative performance measures as a significant indicator
in determining the Group’s earnings performance and operational cash flow generation both for planning
purposes as well as past performance appraisal.
Adjusted Net Income
Adjusted Net Income is defined as the IFRS Reported Net Income as derived from the Group’s reported financial
statements under IFRS, adjusted for post-tax inventory effect (calculated as Inventory Effect times (1- statutory
tax rate in Greece) and other post-tax special items at the consolidated financial statements.
Adjusted Net Income is presented in this report because it is considered by the Group and the Group’s industry as
one of the key measures of its financial performance.
Net Debt
Net Debt is calculated as total borrowings (including “current and non-current borrowings” as shown in the
statement of financial position of the Group financial statements) less “Cash & cash equivalents” and “Investment
in Equity Instruments”, as reflected in the Group’s financial statements. It is noted that finance lease obligations
are not included in the calculation.
Capital Employed
Capital Employed is calculated as “Total Equity” as shown in the statement of financial position of the relevant
financial statements plus Net Debt.

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c.2) Reconciliation of Alternative Performance Measures to the Group’s Financial
Statements
The tables below illustrate how the selected Alternative Performance Measures (APMs) presented in this
financial report are reconciled with the most directly reconcilable line item in the financial statements for the
corresponding period.

Calculation of Reported EBITDA, Adjusted EBITDA, Adjusted Net Income
million € | 2025 | 2024
Operating Profit/(Loss) -IFRS- | 394.9 | 474.8
Depreciation & Amortization -IFRS- | 341.2 | 336.1
Reported EBITDA | 736.1 | 810.9
Inventory effect | 329.4 | 127.7
Other special items* | 66.8 | 87.8
Adjusted EBITDA | 1,132.3 | 1,026.4
Profit/(loss) for the period attributable to owners of the parent -IFRS- | 173.4 | 59.8
Taxed Inventory effect | 257.1 | 99.9
Taxed other special items** | 52.1 | 71.6
Special items below EBITDA*** | 19.9 | 169.8
Adjusted Net Income | 502.5 | 401.0
Calculation of Net Debt, Capital Employed and Gearing ratio |  |
million € | 2025 | 2024
Borrowings LT -IFRS- | 2,777.0 | 2,169.5
Borrowings ST -IFRS- | 221.1 | 240.9
Cash & Cash equivalents -IFRS- | 858.3 | 618.1
Investment in equity instruments -IFRS- | 0.9 | 0.6
Net Debt | 2,139.0 | 1,791.7
Equity -IFRS- | 2,727.9 | 2,762.2
Capital Employed | 4,866.9 | 4,553.9
Gearing ratio (Net Debt / Capital Employed) | 44% | 39%

* Main items include:
a) for 2025: (€2.1m) for expenses associated with early retirement schemes, (€11.6m) expenses associated with
one-off bonus to employees, (€14.3m) for litigation provisions, (€9.7m) valuation adjustments on balance sheet
items, (€16.5m) one-off expenses in refining industrial complexes, (€12.6m) for other special expenses.
b) for 2024: (€52.7m) for expenses associated with early retirement schemes, (€14.0m) expenses associated with
one-off bonus to employees, (€6.0m) for litigation provisions, (€4.7m) valuation adjustments on balance sheet
items, (€10.3m) for other special expenses.
** Includes all special items after the effect of applicable tax rate.
***Mainly included for 2025: special items from associates €18.1m. As for 2024: provision for the temporary
solidarity contribution of (€173m) -after tax-, special items from associates €2.7m.

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d) Related Party Transactions
Both the consolidated and parent company's statement of comprehensive income include proceeds, costs
and expenses that arise from transactions between the Group or the parent company respectively and
related parties. Such transactions are mainly comprised of sales and purchases of goods and services in the
ordinary course of business.
Transactions have been carried out with the following related parties:
a. Associates and joint ventures of the Group which are consolidated under the equity method:
• Athens Airport Fuel Pipeline Company S.A. (EAKAA)
• DEPA International Projects S.A.
• ELPEDISON S.A., up to 14.07.2025 (Note 9)
• Spata Aviation Fuel Company S.A. (SAFCO)
• D.M.E.P. HOLDCO
• VLPG Plant LTD

Group | For the period ended
| 31 December 2025 | 31 December 2024
Sales of goods and services to related parties |  |
Associates | 256,731 | 278,171
Joint ventures | 7,551 | 14,986
Total | 264,282 | 293,157
Purchases of goods and services from related parties |  |
Associates | 292,585 | 351,014
Joint ventures | 104,436 | 160,185
Total | 397,021 | 511,199
Balances due to related parties |  |
Associates | 16,290 | 39,098
Joint ventures | — | 17,580
Total | 16,290 | 56,678
Balances due from related parties |  |
Associates | 24,883 | 41,512
Joint ventures | — | 547
Total | 24,883 | 42,059

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Following ELPEDISON B.V.'s acquisition by the Group during 2025, the former ceased to be classified as a related
party. In 2024, the Company had provided guarantees in favour of third parties and banks as security for loans
granted by them to Elpedison B.V., with an outstanding amount of €70 million as at 31 December 2024. As at 31
December 2025, no amount remains outstanding under these guarantees.
b. Government related entities which are under common control with the Group due to the shareholding
and control rights of the Hellenic State and with which the Group has material transactions:
• Hellenic Armed Forces
• Road Transport S.A.
• Public Power Corporation Hellas S.A.
• Hellenic Electricity Distribution Network Operator S.A. (HEDNO)
• Hellenic Gas Transmission System Operator
• Independent Power Transmission Operator (IPTO)
• Hellenic Energy Excahnge S.A( HEnEx)
• EnΕx Clearing House Single Member S.A. (EnExClear)
• Renewable Energy Sources Operator & Guarantees of Origin S.A.
During the year ended 31 December 2025, transactions and balances with the above government related
entities are as follows:
• Sales of goods and services amounted to €729 million (31 December 2024: €404 million)
• Purchases of goods and services amounted to €384 million (31 December 2024: €3 million)
• Receivable balances of €86 million (31 December 2024: €34 million)
• Payable balances of €18 million (31 December 2024: €0.1 million).
c. Key management includes directors (Executive and Non-Executive Members of the board of HELLENiQ
ENERGY Holdings S.A.) and General Managers.
The compensation paid or payable for the year ended on 31 December 2025 to the aforementioned key
management is as follows:

Group | For the period ended
| 31 December 2025 | 31 December 2024
Employee benefits | 13,961 | 12,213
Post-employment benefits | 816 | 956
Total | 14,777 | 13,169

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d. The Group participates in the following jointly controlled operations with other third parties relating to
exploration and production of hydrocarbons in Greece:
• Exxon Mobil Exploration and Production Greece (Crete) B.V. (Greece, Block West Crete)
• Exxon Mobil Exploration and Production Greece (Crete) B.V. (Greece, Block South West Crete)
• Energean Hellas LTD (Greece, Block 2)
• Calfrac Well Services Ltd (Greece, Sea of Thrace concession)
For transactions and balances with related parties of the Parent Company see Note 35.

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A.6 Risks and Uncertainties
a) Main Risks and Uncertainties for the Next Financial year
Due to its activities, the Group is exposed to various macroeconomic (exchange rates, interest rates), financial
(capital structure and adequacy, liquidity, cash flows, credit), regulatory and market risks (refining margins,
international crude prices, energy prices, EU emissions trading system), as well as significant operational risks. The
Group's risk management framework focuses on mitigating any negative impact on the Group’s financial position
and/or reducing potential exposure to market volatility, to the extent possible, aiming to ensure the Group’s
operation and profitability.
Geopolitical tensions in Eastern Europe, the Middle East and other regions, along with inflationary pressures,
changes in consumers’ disposable income, volatility in energy markets and uncertainties regarding the pace and
direction of the energy transition, collectively exert both direct and indirect influences on the demand for
petroleum products in the European refining industry. Furthermore, these factors affect crude oil and product
prices, the euro/US dollar exchange rate, CO2 emissions prices, natural gas and electricity prices, as well as interest
rates. Although it is impossible to predict the various scenarios and how to address them entirely, the Group
closely monitors developments, assesses and identifies risks, and adjusts its operations and planning accordingly.
The general risk management framework remains focused on mitigating volatility, with increased focus on
incorporating the parameters of the energy transition.
b) Financial Risk Management
Financial Risk Factors
The Group's operations primarily focus on oil refining, petrochemicals, fuels marketing, exploration and
production of hydrocarbons, renewable energy sources (RES), as well as electricity production and trading.
Therefore, the group is exposed to various financial risks, including fluctuations in the prices of oil, natural gas,
electricity and CO2 emission allowances in international markets, exchange rate volatility, cash flow risks and risks
of fair value fluctuations due to interest rates variations. In accordance with international best practices and within
the context of the local market and legal framework, the overall risk management plan aims to minimize the
Group's potential exposure to market volatility and mitigate any adverse impact on the Group's financial position
to the greatest extent possible.
The most significant risks and uncertainties are discussed below.
b.1) Market Risk
(i) Exchange Rate Risk
Refining industry is a US dollar-denominated business, with local currency conversions, while operating costs are
mainly denominated in the local currency (euro). As a result, the Group's operations are exposed to the risk of the
fluctuations in the euro/US dollar exchange rate. A strengthening of the US dollar against the euro has a positive
impact on the Group’s financial results. Conversely, in the event of the opposite, both the financial results and
balance sheet items (net exposure of inventory, investments, receivables, trade payables and other liabilities in US
dollar) would be valued at lower levels. To more effectively manage foreign exchange exposure, the Group
regularly evaluates and, where necessary, adjusts its loan portfolio with respect to the currencies in which it is
denominated. In this context, it includes borrowings in US dollars, which serve as a natural hedge of the asset
position, thereby mitigating the risk arising from a potential depreciation of the US dollar on the balance sheet.

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(ii) Product Price Fluctuation Risk
The Group’s core activities, i.e. refining, supply & trading, give rise to two types of exposure: changes in the prices
of crude oil and oil products, which affect inventory value, and changes in refining margins, which affect
profitability and cash flows.
Regarding the risk of product price fluctuations, the level of exposure pertains to the decrease in product prices
and is determined by the closing inventory valuation, as the Group's policy is to report the closing stock at the
lower between cost and net realizable value. Crude oil and product price fluctuations also affect the levels of
working capital as higher prices increase financing requirements.
Exposure to risk associated with changes in refining margins depends on the fluctuation of each refinery’s margin.
Refining margins are calculated using prices of crude oil and oil products, which are determined on a daily basis
and are affected by the development of supply and demand of crude oil and oil products, both regionally
(Mediterranean market) and globally. Fluctuations in refining margins impact the Group’s profitability and cash
flow generation accordingly.
Regarding the activity of Renewable Energy Sources (RES) and Power & Gas, market risk includes: a) policy risks
related to risk of lower revenues due to a retroactive change in policies, taxation or other measures (e.g.
retroactive change in the Feed-in-Tariff - FiT - regime), b) price risk related to the fluctuations and volatility of
natural gas prices, merchant electricity prices and CO2 emission rights prices (EUAs), e) curtailment risk related to
risk of lower revenues due to unexpected curtailment in electricity production from RES assets, which may occur
due to grid bottlenecks or other factors, coupled with the inability to obtain compensation for such curtailments.
(iii) Cash Flow Risk and Risk of Fair Value Change due to change in interest rates
Cash flow risk arising from changes in interest rates is associated with the Group's borrowing at floating interest
rates. Furthermore, due to the long-term investments in the sectors in which the Group operates, increases in
interest rates are likely to result in changes in the fair value of such investments through an increase in the
discount rate. During the investment appraisal process, the Group adopts a minimum return, that reflects its cost
of capital and is significantly higher than current interest rates. Additionally, a portion of the loans used to finance
investments (Eurobonds and term banking facilities) are issued at fixed interest rates. Long-term funding for
renewable energy projects, through project finance, is partially hedged to reduce the risk of fluctuations in interest
rates over the lifespan of these investments.
(iv) Energy transition - Risk of reduced product demand and increased operating costs
The global energy sector is currently undergoing a transition phase characterized by a global shift towards cleaner
forms of energy at the expense of more conventional sources, including oil. Furthermore, climate change
mitigation policies, particularly in the EU, are expected to increase operating costs. For instance, the number of
CO2 emission allowances that must be acquired through the market in the coming years, along with the rise in the
price of allowances, contributes to higher operating costs, both directly and indirectly, through increased
electricity costs.
Additionally, the energy transition has resulted and may continue to result in increased volatility in the prices of
components within the energy value chain, such as natural gas and electricity prices, which in turn affect the
operating costs of the broader industry, including the refining sector.
In light of these circumstances, the Group has already designed and implemented its strategy for the energy
transition. This strategy includes investments aimed at diversifying its activities and expanding its presence in the
electricity and gas sectors, as well as in RES. Furthermore, the Group is committed to improving the environmental
performance of its facilities, reducing emissions and implementing projects to enhance competitiveness and
reduce operating costs. The Group's refineries possess the flexibility to adapt in terms of raw materials and have
the capability to substitute natural gas with petroleum products to a significant extent. Moreover, the Group has
been diversifying its electricity supply mix for its refineries, and, in the medium term, contemplates investments
to enhance energy efficiency and improve autonomy. Furthermore, the Group’s business model is characterized

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by returns that surpass benchmark margins, providing a significant competitive advantage in the Mediterranean
region.
b.2) Credit Risk
Credit risk management is centrally coordinated at the Group level. Credit risk arises from cash and cash
equivalents, bank deposits, derivative financial instruments, as well as exposure to credit risk of customers,
including outstanding trade receivables from clients in Greece and internationally. All customers are assessed for
their creditworthiness, in collaboration, where necessary, with external rating agencies.
The effective management of credit risk and monitoring of transaction behavior by customers, both in Greece and
internationally, are facilitated through an integrated software system developed for monitoring exposure to credit
risk. This system is complemented by a central unit responsible for managing the settlement of trade receivables.
Additionally, the Group’s Credit Committee plays a significant role in ensuring the effective management of credit
risk associated with trade receivables of the Group’s companies.
b.3) Liquidity Risk
Liquidity risk is managed by ensuring that efficient cash resources and adequate credit limits with banks are
maintained. Given the dynamic nature of its operations, the Group seeks to maintain flexibility in funding through
credit lines and other credit facilities.

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c) Capital Risk Management
The objective of the Group is to effectively manage its funds in order to ensure the smooth operation of its
activities and maximize its overall value. Management regularly monitors the capital structure of both the Group
and its various businesses, based on business models, cash flows and the investment plan, with the aim of
enhancing business flexibility, reducing financial costs, and maximizing returns.
To maintain or adjust its capital structure, the Group has the option to modify the dividend payout to
shareholders, return capital to shareholders, issue new shares, or dispose of assets to decrease its debt.
Furthermore, the Group diversifies its funding sources (such as bond loans, bonds, and credit lines) to effectively
manage its debt obligations. The Group aims to achieve the best possible distribution, considering various factors,
including the cost of capital and maturity.
In order to optimally manage its debt obligations and expand its financing options, the Group also raises funds
from international debt capital markets.
Similar to industry norms, the Group monitors its capital structure using the gearing ratio. This ratio is calculated
by dividing the net debt by the total capital employed, as presented in chapter Selected Alternative Performance
Measures.

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d) Borrowings
The Group has centralized treasury operations which coordinate and control the funding and cash
management activities of all Group companies. Within this framework, HELLENiQ ENERGY FINANCE PLC
(former HPF) was established in November 2005 in the U.K. as a wholly-owned subsidiary of HELLENiQ
ENERGY Holdings S.A. to act as the central treasury vehicle of the HELLENiQ ENERGY Group.
Analysis of the Group's borrowings can be found at Note 17 of the Full Year Audited Financial Statements.

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B.1 Corporate Governance Statement
The present statement has been prepared in accordance with the provisions of articles 152 and 153 of L.
4548/2018; it is included in the Company’s Annual Management Report in respect of the 2025 fiscal period,
as a special part thereof, and is available via the Company’s website Corporate Governance Statement.
The institutional framework governing the Company’s operation and obligations is L. 4548/2018 on the reform of
the law of sociétés anonymes and L. 4706/2020 on corporate governance. The Company’s Articles of Association,
are available via the Company’s website Articles of Association.
As a listed company on the Athens Exchange, the Company has additional obligations in respect of the individual
sections of governance, investors’ and supervisory authorities’ information, financial statements’ publication, etc.
The principal laws describing and imposing the additional obligations are L. 4706/2020 and the Hellenic Capital
Market Commission decisions and circulars issued by delegated authority of the law (decisions no.
1Α/890/18.09.2020, 1/891/30.09.2020 as amended and in force, 2/905/03.03.2021, updated circular
60/29.04.2025), L. 3556/2007, L. 4374/2016, the ATHEX Exchange Rulebook, the provisions of article 44 of L.
4449/2017 (Audit Committee), as amended and in force, in conjunction with the caveats, clarifications and
recommendations of the Hellenic Capital Market Commission (indicatively, documents no. 1149/17.5.2021,
425/21.02.2022 and 784/20.03.2023), as well as decision no. 5/204/14.11.2000 of the BoD of the Hellenic Capital
Market Commission, as in force.
The Board of Directors, in accordance with its obligations arising from the relevant provisions of Law 4706/2020
and Decision 1/891/30.09.2020 (as in force), assigned to ERNST & YOUNG (Hellas) Certified Auditors –
Accountants S.A. the evaluation of the adequacy and effectiveness of the Company’s Internal Control System of
the Company and its significant subsidiaries HELLENiQ PETROLEUM S.A., ΕΚΟ ΑΒΕΕ and Enerwave S.A., for the
period from 01.01.2023 - 31.12.2025 and the application and effectiveness of its Corporate Governance System,
with reference date 31 December 2025. The assessment was carried out on the basis of the assurance procedures
programs included in a) decision No 278/16.01.2026 of the Board of Directors of HAASOB regarding the Internal
Control System and b) decision No Ι΄73/08β/14.02.2024 of the Supervisory Board of the Hellenic Accounting and
Auditing Oversight Board, for the Corporate Governance System, in accordance with International Standard on
Assurance Engagements (ISAE) 3000 (Revised), “Assurance Engagements Other than Audits or Reviews of
Historical Financial Information.” The evaluations did not identify any material weaknesses in the Company’s
Internal Control System or Corporate Governance System.

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Β.1.1 Corporate Governance Code
The Company has adopted the Hellenic Corporate Governance Code (June 2021 edition) of the Hellenic Corporate
Governance Council (HCGC) (hereinafter referred to as the “Code”). This Code can be found on the HCGC’s website,
at the following e-address: https://www.esed.org.gr/en/code-listed.
Aside from the HCGC’s website, the Code is available on HELLENiQ ENERGY's website.
During 2025, the Company complied with the provisions of the above Code, with the deviations stated below in
paragraph B.1.2.
The Company monitors the developments in the current regulatory framework as well as the best practices in
corporate governance so as to ensure not only compliance with the regulatory framework but also to formulate
policies, values, and principles that govern its operation while ensuring transparency and safeguarding the
interests of its shareholders and all stakeholders.
During 2025, the Company issued an Artificial Intelligence Systems Management Policy in accordance with
Regulation (EU) 2024/1689 on Artificial Intelligence (AI Act), and proceeded to revise/update:
• the Audit Committee’s Operation Regulation
• the Sustainability Committee's Operation Regulation
• the Operation Regulation of the Internal Audit Department,
aiming at rendering them more aligned with the latest optimal corporate governance practices.

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Β.1.2 Deviations from the Corporate Governance Code

Hellenic Corporate Governance Code | Explanation/Reasoning for deviating from the special practices of the Hellenic Corporate Governance Code
Succession of the BoD Gradual replacement of the members of the Board of Directors (Special Practice 2.3.2). | The practice followed by the General Meeting of the shareholders is that the term of office of the members of the Board of Directors begins and ends at the same time. This practice has been successfully implemented, without raising an issue of lack of administration.
BoD members’ remuneration Recovery of variable parts of executive BoD members’ remuneration (Special Practice 2.4.14) | The existing remuneration system for executive BoD members does not include provisions for the possibility of refunding part or the whole of the executive BoD members’ variable remuneration, as this would amount to a discrimination at their expense compared to Company executives with the same grade. The Company also deems that such a clause is not necessary, as the relevant remuneration is paid following an individual assessment of each executive member’s performance and under no circumstances can they exceed the predetermined maximum limits on their annual ordinary remuneration.

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Β.1.3 Other Corporate Governance Practices
In the context of implementing a structured and adequate corporate governance system, the Company has
implemented specific good corporate governance practices, some of which are over and above those provided by
the applicable legislation and relate to the BoD’s duties and its operation in general (a detailed reference to the
BoD Committees follows in section B.1.7):
• Due the Company’s nature and purpose, the complexity of issues and the necessary support of the Group,
which includes a number of operations and subsidiaries in Greece and abroad, and in order to be assisted in
its work, the BoD has established committees, comprised of members thereof, with advisory, supervisory
or/and approving authorities. These committees are outlined below (a detailed reference to such shall be
made at the end of the Statement, under paragraph “Other BoD Committees”):
I. Strategy and Risk Management Committee
II. Sustainability Committee
• In addition to the above BoD committees, committees with an advisory and coordinating role have been
established and operate in the Company. They comprise of senior executives of the Company and their
objective is to support the work of Management. The principal such committees are the following:
I. Executive Committee
II. Group Credit Committee
III. Investment Evaluation Committee
• The Company has adopted corporate governance policies and procedures, which include:
◦ The Procedure for handling inside information and properly informing the public, in accordance with the
provisions of Regulation (EU) 596/2014, which includes the appropriate mechanisms and methodologies
for the assessment of information so that it may qualify as “inside”, the prohibition of abusing or
attempting to abuse inside information or recommending to another person to proceed to an abuse of
inside information, as well as the prohibition of unlawful disclosure.
◦ The Procedure for the compliance of persons discharging managerial responsibilities, in accordance with
the provisions of article 19 of Regulation (EU) 596/2014, which includes a clear and detailed recording of
the requisite notification actions, aiming at strengthening transparency regarding the transactions of
management officers and of the persons closely associated therewith and identifying potential risks
(abuse, market manipulation, etc.)
◦ The Policy and Procedure on related party transactions, which sets out the mechanisms for identifying,
supervising and approving the transactions in question. In the context of the procedure relevant
documents and information concerning related parties are kept and updated. The information on the
above transactions among associate companies are included in the report accompanying the Company’s
financial statements, in order to be disclosed to the shareholders. According to the provisions of L.
4548/2018 (article 99- 101), Company transactions of any kind with parties related to it, are permissible
only following approval by the BoD or the General Meeting, as per case, unless they fall under the
exceptions stated in the law.
◦ The Policy and Procedure for preventing and managing conflict of interest situations, which provides for
designating the way in which conflict of interest may arise, for receiving reports or clarifying doubts in
cases of such (actual or potential) conflict and for taking appropriate measures for managing them.

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Β.1.4 Main Features of the Systems of Internal Controls and Risk
Management in Relation to the Financial Reporting Process
The Group System of Internal Controls and Risk Management in relation to the financial statements’ and
financial reports’ preparation process includes controls and audit mechanisms at different levels within the
Organization, which are described below:
a) Group level controls
Risk identification, assessment, measurement and management
The prevention and management of risks forms a core part of the Group’s strategy. The scope, size and
complexity of the Group’s activities require a composite system of methodical approach and treatment of risks,
which is applied by all Group companies.
The identification and assessment of risks is carried out mainly during the strategic planning and the business
plan preparation phase. The benefits and opportunities are examined both in the context of the Company’s
operations, but also in relation to the several and different stakeholders who may be affected.
The examined risks include a) operational, b) financial and c) strategic risks, as well as d) regulatory compliance
and supervision risks. More specifically and indicatively, issues that are examined include the effect of operational
availability of units, supply chain, human resources, technological developments, taxation, interest rates,
commodity prices, exchange rates, among others. Also, issues related to health, safety and environmental,
corporate governance and regulatory compliance risks are assessed, risks related to the business model and
strategy, as well as market trends (competition, geopolitical developments, regulatory developments).
Planning and monitoring / Budget
The Company’s progress is monitored through a detailed budget per operating sector and specific market. The
budget is adjusted at regular intervals to consider the changes in the development of the Group’s financials that
depend greatly on external factors, including the international refining environment, crude oil prices and the
euro / dollar exchange rate. Management monitors the Group’s financial results through regular reporting,
comparisons vs the budget, as well as through Management Team meetings.
Adequacy of the Internal Control System
The Internal Control System (ICS) consists of the policies, procedures and tasks which have been designed and
implemented by the Group’s Management for the effective management of risks, the achievement of business
objectives, for ensuring the reliability of the financial and managerial information and compliance with Laws and
regulations.
The independent Group Internal Audit General Division (GIAGD), through conducting periodic assessments,
ensures that the risk identification and management procedures applied by the Management are adequate, that
the ICS operates effectively and that information provided to the BoD regarding the ICS, is reliable and of good
quality.
The Internal Audit General Division draws up a short-term (annual), as well as a rolling long-term (three-year)
Audit Plan based risk assessment process conducted by the Risk Monitoring and Management Division, as well as
on other issues identified by the Audit Committee and the Management also in past audit reports. The Audit
Committee is the supervisory body of the Internal Audit General Division.
The Internal Audit General Division submits quarterly reports to the Audit Committee, in order for the systematic
monitoring of the Internal Audit System’s adequacy to be feasible.

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The reports of the Management and the Internal Audit General Division provide an assessment of the significant
risks and the effectiveness of the Internal Audit System as regards their management. Through the reports, any
possibly identified weaknesses, their actual or potential impact, as well as the Management’s actions to correct
them are communicated. The results of the audits and the monitoring of the implementation of the agreed
improvement actions are taken into account in the Company’s Risk Management System.
To ensure the independence of the statutory Audit of the Group’s financial statements, the BoD follows a specific
policy in order to formulate a recommendation to the General Meeting regarding the election of an External
Auditor. Indicatively, this policy provides, inter alia, for the selection of the same audit company for the entire
Group, as well as for the auditing of the consolidated financial statements and tax compliance reports. Lastly, a
certified auditor is appointed from an internationally recognized firm is elected, while, at the same time, his/her
independence is safeguarded.
Compliance Office
Compliance Office is responsible for monitoring the Group's Compliance Risk and forms part of the Internal
Control System (ICS) and reports at an operational level to the Audit Committee and at an administrative level to
the Director of Monitoring and Risk Management. By its report to the Audit Committee, it contributes to the ICS's
improvement and adequacy, as its objective is to ensure that appropriate and updated policies and procedures are
set up and implemented, in such a way that the Company’s full and constant compliance to the applicable
regulatory framework is achieved.
Monitoring and Risk Management Division
The purpose of the Monitoring and Risk Management Division is to centrally monitor and coordinate the
management of the Group's exposure to internal and external risks. The Division is independent from executive
activities and supports the ICS’s operation through determining principles and setting up and implementing
appropriate and updated policies and procedures governing their identification, assessment, quantification/
measurement, monitoring and management.
Roles and responsibilities of the Board of Directors
The role, powers and relevant responsibilities of the BoD are set out in the Company’s Bylaws (Internal Regulation)
that has been approved by the BoD.
Financial fraud prevention and detection
In the context of risk management, the areas that are considered to be of high risk for financial fraud are
monitored through appropriate Control Systems and accordingly increased controls are in place. Examples include
the existence of detailed organizational charts, operation regulations (procurement, investment, oil products’
market, credit, treasury management), as well as detailed procedures and approval authority levels. In addition to
the internal controls applied by each Division, all Company operations are subject to audits by the Group Internal
Audit General Division (GIAGD), the results of which are submitted to the BoD.
Bylaws (Internal Regulation)
The Company's Bylaws set out , among others, the powers and responsibilities of the principal job positions
promoting the adequate separation of powers within the Company. Summary of the approved Bylaws have been
posted on the Company’s website, in accordance with par. 2 of article 14 of L. 4706/2020.
Furthermore, the companies “HELLENIC FUELS AND LUBRICANTS SINGLE-MEMBER INDUSTRIAL AND
COMMERCIAL SOCIETE ANONYME” and “HELLENIC PETROLEUM SINGLE-MEMBER SOCIETE ANONYME”, as key
Company subsidiaries, adopted bylaws on 15.07.2021 and 20.01.2022, respectively. Following the Company’s
acquisition of full control of ENERWAVE S.A. (formerly ELPEDISON S.A.) on 15.07.2025, the Company ensures that
ENERWAVE S.A., as a significant subsidiary, adopts an operations regulation.

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Group Code of Conduct
In the context of the good corporate governance fundamental obligation, the Company has drawn up and adopted
since 2011 a Code of Conduct, which has been approved by the Company’s BoD. The Code of Conduct summarizes
the principles according to which every individual, employee or third party involved in the operation of the Group,
as well as every collective body thereof, should act within the framework of their duties. For this reason, the Code
constitutes a practical guide of the day-to-day tasks of all employees of the Group, but also of third parties who
cooperate with it.
The Group Code of Conduct is available on the Company’s website, with its updated version implemented as of
February 2025, reflecting insights gained over 14 years and addressing recent legislative developments.
Furthermore, in 2024 the Policy for the Protection of Persons who Report Breaches of Union Law
(Whistleblowing) was enacted in accordance with L. 4990/2022, which ratifies the EU Directive 2019/1937. In this
context, a dedicated reporting platform has been launched, enabling both identified and anonymous submissions,
while ensuring confidentiality and the protection of the reporting individuals. Both the Whistleblowing Policy and
the reporting platform can be accessed via the Company’s website.
In parallel, in accordance with L. 4808/2021, which, among other provisions, ratifies Convention 190 of the
International Labor Organization on eliminating violence and harassment in the workspace and proceeds to
adopting relevant measures and provisions, the Policy against Violence and Harassment in the Workspace is
applied across all companies within the Group.
Data Protection Office
In the context of complying with the Personal Data Protection Regulation, the Company has established a
Personal Data Protection Office (PDPO), by appointing a Data Protection Officer (DPO) at a Group level, but also in
specific subsidiaries. The PDPO has drawn up the appropriate policies and procedures for the effective protection
of the privacy of personal data processed by the Group and ensures their implementation and the provision of
support in matters of personal data protection.
DPO is administratively reporting to the Chief Executive Officer and, functionally, to the BoD. By utilizing the
experience gained from the 6 – year operation of the Personal Data Protection Office, all the policies for the
protection of Personal Data are in the final stage of revision and updating.
Evaluation of the adequacy and effectiveness of the Company’s Internal Control System and the
implementation and effectiveness of the Corporate Governance System
The Board of Directors, in accordance with its obligations arising from the relevant provisions of Law 4706/2020
and Decision 1/891/30.09.2020 (as in force), assigned to ERNST & YOUNG (Hellas) Certified Auditors –
Accountants S.A. the evaluation of the adequacy and effectiveness of the Company’s Internal Control System (ICS)
for the period from 01.01.2023 - 31.12.2025 and the application and effectiveness of the Company’s Corporate
Governance System (CGS), with reference date 31 December 2025. Ms. Kyriaki Katsani, Certified Public
Accountant, has been appointed Head of the evaluation project. She is an independent and objective evaluator
who meets the independence and objectivity requirements set out in the applicable regulatory framework. The
ICS assessment was carried out on the basis of the assurance procedures program set out in decision No 278/
16.01.2026 of the Board of Directors of HAASOB and the CGS assessment was carried out on the basis of the
limited assurance procedures program set out in decision Ι΄73/08β/ 14.02.2024 of the Supervisory Board of the
Hellenic Accounting and Auditing Oversight Board, in accordance with International Standard on Assurance
Engagements (ISAE) 3000 (Revised), “Assurance Engagements Other than Audits or Reviews of Historical
Financial Information".The evaluations did not identify any material weaknesses in the Company’s ICS or CGS.
It is noted that the first evaluation of the adequacy and effectiveness of the Company’s ICS and that of its
significant subsidiaries by an independent evaluator was conducted with reference date 31.12.2022 and was
completed on 31.03.2023. Furthermore, the first evaluation of the CGS was conducted with reference date
31.12.2023 and was completed on 31.03.2024.

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The present evaluation was carried out concurrently for both the ICS and the CGS, covering the period 01.01.2023–
31.12.2025, so that a common reference date will henceforth apply to both assessments. As regards the scope of
the evaluation, the Board of Directors designated the following companies as significant subsidiaries: HELLENiQ
PETROLEUM S.A., EKO ABEE, and Enerwave S.A. (due to the acquisition of full control on 15.07.2025), and focused
on the following key areas:
The evaluation of the adequacy of the Internal Control System (ICS) focused on the following pillars:
1. Control Environment
2. Risk Management
3. Control Activities
4. Information and Communication
5. Monitoring
The Corporate Governance System (CGS) evaluation is broader in scope and focuses on the following:
1. An adequate and effective ICS, including risk management and regulatory compliance systems.
2. Adequate and effective procedures for the prevention, detection, and addressing of conflict‑of‑interest
situations.
3. Adequate and effective mechanisms for shareholder engagement and communication.
4. A remuneration policy that contributes to the Company’s business strategy, long‑term interests, and
sustainability.
5. Implementation of the Code of Conduct and the Corporate Governance Code.
The evaluation commenced in December 2025 and was completed in February 2026. The evaluations did not
identify any findings that constitute material weaknesses in the Company’s ICS and CGS or those of its significant
subsidiaries. The Company will timely submit the relevant report to the Hellenic Capital Market Commission in
accordance with the applicable provisions. Additionally, it will assess the actions relating to non‑material findings /
non-material weaknesses identified by the independent evaluator in the context of the engagement.
b) Information systems’ controls
Recognizing the substantial dependence of financial reporting processes on information systems, the Group has
implemented a series of measures to ensure the stability and effective operation of its security mechanisms.
These initiatives safeguard the integrity and accuracy of the financial records, and ensure uninterrupted IT service
delivery, even in emergency situations.
To this end, the Group has appointed a Chief Information Security Officer (CISO), who reports to the Audit
Committee on a quarterly basis and is responsible for managing the Information Security Framework. This
framework includes cybersecurity policies and procedures that are aligned with international best practices and
standards, reflecting Management's commitment to effective cyber risk management. In addition, the existence
of a dedicated cybersecurity budget ensures the implementation of specialized projects and information security
measures, in collaboration with external partners, where required.
The Group employs a comprehensive, multi-layered strategy for information security, supported by a strategic
plan that, utilizing state-of-the-art technologies and top-tier information systems, through which it ensures
compliance with the necessary regulatory frameworks and guidelines (e.g. NIS2 Directive – Law 5160/2024,
General Data Protection Regulation). Additionally, the Group actively collaborates with regulatory authorities and
international organizations to facilitate ongoing information exchange.
At the same time, the Group continually invests in fostering a culture of cybersecurity awareness in both its IT and
OT environments. This includes training through e-learning platforms, in-person educational sessions, and

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simulated phishing attack exercises, aimed at reducing the likelihood of human error that could potentially lead to
adverse incidents.
Finally, to ensure the operational effectiveness of security controls, the Group has established a comprehensive
monitoring and control framework for its information systems, including multiple annual audits conducted by
both internal and external parties.
c) Financial statements and financial reports’ preparation process (financial reporting)
controls
In the course of preparing the Company's financial statements, a series of specific internal controls have been
established and are actively maintained. These controls pertain to the utilization of tools and methodologies that
are widely recognized and accepted, based on the best international practices. The implementation of such
controls is designed to ensure both the accuracy and reliability of the financial reporting process, as well as
compliance with applicable regulatory standards.
Among the main areas in which these controls are applied in relation to the Company’s financial reports and
statements are the following:
Setup – Allocation of Duties
The delegation of responsibilities and authorities, both to the Company’s senior Management and to its middle
and junior staff, enhances the effectiveness of the Internal Control System, while ensuring the necessary
segregation of duties.
The proper staffing of the finance department with personnel who possess the required technical expertise and
experience, in line with their assigned responsibilities, is essential for smooth operations.
Furthermore, the systematic documentation of procedures and control safeguards, along with the establishment
of a clear operational model for key activities, strengthens transparency and organizational efficiency.
Accounting monitoring and financial statements’ preparation procedures
• The Company maintains uniform policies and systematic monitoring within its accounting departments,
encompassing definitions, the accounting principles adopted by the Company and its subsidiaries, and
detailed guidelines for the preparation of the financial statements and financial reports.
• Automated controls and verifications are implemented across the various information systems to ensure
accuracy and consistency. In addition, transactions of a non-recurring nature are subject to special approval
with respect to their accounting treatment.
Assets’ safeguarding procedures
• Controls are in place regarding fixed assets, inventories, cash and cash equivalents - cheques and other
assets of the company, such as, for example, the physical security of cash or warehouses and inventory
counts and reconciliations of physically counted quantities with those recorded in the accounting books.
• Schedule of monthly physical inventory counts to confirm inventory levels of physical and accounting
warehouses; use of a detailed manual to conduct inventory counts.
Transactions’ authorization limits
• A Chart of Authorities has been established, delineating the specific powers assigned to the Company’s
various officers to execute the most significant transactions or acts (e.g. purchases of raw materials and
goods/services, sales, borrowings, payments, receipts, legal acts, etc.).

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Β.1.5 Information Required per Article 10, Paragraph 1 of Directive
2004/25/EU on Public Takeover Bids
Publication of the requisite information, in accordance with article 10 par. 1 of Directive 2004/25/EU of the
European Parliament and of the Council is included in part D of this Report, per article 4 par. 7 of L.
3556/2007.

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Β.1.6 General Meeting and Shareholders’ Rights
The General Meeting of the Company’s shareholders is its supreme governing body and has the right to
decide on any issue concerning the Company. The operation of the Company’s General Meeting of
shareholders, its role and responsibilities, convocation, participation requirements, the ordinary and
extraordinary quorum and majority of the participants, the Presiding Board and the Agenda, are set out in
the Company’s Articles of Association.
All shareholders have the right to participate in the General Meeting, provided that they hold Company shares on
the start of the fifth (5th) day prior to the date of the General Meeting (“record date”).
The shareholding capacity is evidenced through the Company’s electronic connection with the Dematerialized
Securities System (D.S.S.) of the société anonyme “HELLENIC CENTRAL SECURITIES DEPOSITORY SOCIÉTÉ
ANONYME” (“ATHEXCSD”) at the record date. Said record date is also valid in the event of a deferred or repeat
meeting, on condition that such deferred or repeat meeting does not take place more than thirty (30) days after
the record date, in accordance with article 124 par. 6 of Law 4548/2018. If this is not the case or in case a new
invitation is published for the repeat General Meeting, the person with shareholding capacity at the start of the
third day before the date of the deferred or repeat General Meeting, takes part in the General Meeting.
Participation in the General Meeting is not conditional on share blocking or compliance with any other similar
procedure restricting the sale and transfer of shares during the period between the record date and that of the
General Meeting.
Shareholders have the right to participate in the General Meeting, either in person or through one or more
appointed proxy holders (shareholders, or not).
Participation in the General Meeting remotely, exclusively through electronic means, without the shareholders’
physical presence at the venue where it is held, is permitted. Exercise of the shareholders’ right to vote remotely,
either in real time through teleconference, or by sending their postal voting before the meeting is held, is also
permitted, either in person, or through a proxy, in accordance with the provisions of L. 4548/2018 (articles 125 par.
1 and 126) and the Company’s Articles of Association.
Shareholders have the right to participate in General Meetings, either in person or through one or more appointed
proxy holders (shareholders, or not).
Each shareholder may appoint up to three (3) proxy holders. However, if a shareholder has shares of the Company
held in more than one securities account, the above restriction shall not prevent the shareholder from appointing
a separate proxy holder for the shares held in each of the securities accounts. A proxy holder, acting on behalf of
several shareholders, may vote differently in respect of each shareholder.
Legal entities participate in the General Meeting through their representatives. Proxy holders are appointed or
revoked by written notification to the Company, at least forty-eight hours prior to the date set for the General
Meeting. The proxy forms are available at the Company’s website. Such forms render possible for shareholders to
authorize their proxy holders either to vote in favor or against, or to abstain from voting, separately in respect of
each item on the agenda.
The Company ensures that all valid proxy holders’ appointments received for the General Meeting are properly
recorded and taken into account. Prior to the commencement of the General Meeting’s session, the shareholders’
proxy holders are obliged to disclose to the Company any information or event, which could generate conflict with
the rights of the shareholders they represent.
Shareholders’ rights prior to the General Meeting
The Company is under an obligation to post on its website its annual Financial Statements, as well as the relevant
reports of the Board of Directors and Auditors, ten (10) days prior to the Ordinary General Meeting.

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Minority Rights
1. On request by any Shareholder, submitted to the Company at least five (5) full days prior to the General
Meeting, the Board of Directors is under an obligation to provide the General Meeting with the specific
information requested on the Company’s affairs, to the extent such information is useful for really assessing
the items of the agenda. There is no obligation to provide information where such is already available on the
Company’s website, particularly in the form of questions and answers. The Board of Directors may refuse to
provide the above information on the basis of adequate cause, which is recorded in the minutes. Any dispute
as to the validity or not of the reasoning for refusing to provide information is resolved by the One-Member
First Instance Court of Athens by a judgment thereof, issued according to the interim measures’ procedure.
2. On request by Shareholders representing 1/20 of the paid-in share capital, the Board of Directors is under an
obligation to convene an extraordinary General Meeting, setting its date within a period of forty-five (45)
days following the day of service of the relevant request to the Chair of the Board of Directors. The relevant
request must include the requested General Meeting’s agenda. In case no General Meeting is convened by
the Board of Directors within twenty (20) days from service of the relevant request, the latter can be filed
before the One-Member First Instance Court of Athens, which shall determine the place and time for the
General Meeting, as well as its agenda, by applying the interim measures procedure.
3. On request by Shareholders representing 1/20 of the paid-in share capital, the Board of Directors is under an
obligation to include additional issues in the agenda of the General Meeting that has been already convoked,
provided the relevant request has come to it at least fifteen (15) days prior to the General Meeting. The
additional items must be published or notified, at the Board of Directors’ responsibility, at least seven (7)
days prior to the General Meeting. The revised agenda, together with the reasoning or draft decision that has
been submitted to the shareholders, must be published in the same way as the original agenda and be
available on the Company’s website, at least thirteen (13) days prior to the date of the General Meeting.
4. On request by Shareholders representing 1/20 of the paid-in share capital, the Board of Directors is under an
obligation to make available to the shareholders, by posting on the Company’s website, at least six (6) days
prior to the date of the General Meeting, drafts of the decisions on issues included in the original or the
revised agenda, if the relevant request has been received by the Board of Directors at least seven (7) days
prior to the date of the General Meeting.
5. On request by Shareholders representing 1/20 of the paid-in share capital, the Board of Directors is obliged
to adjourn, only once, decision-making by the General Meeting, whether ordinary or extraordinary, on all or
some of the issues on the agenda and set as new date for the General Meeting that which is set out on the
Shareholders’ request; however, such date cannot be more than twenty (20) days after the date of the
adjourned General Meeting.
6. On request by Shareholders representing 1/20 of the paid-in share capital, the Board of Directors is obliged
to announce to the General Meeting, provided it is an ordinary one, the amounts paid to each member of the
Board of Directors or to the Company’s Managers over the last two years, as well as any benefit granted to
those persons, on account of any cause or Company contract with them. The Board of Directors may refuse
to provide the above information on the basis of adequate cause, which is recorded in the Minutes.
7. On request by Shareholders representing 1/20 of the paid-in share capital, decisions on any item on the
agenda of a General Meeting are taken by roll-call vote.
8. On request by Shareholders representing 1/20 of the paid-in share capital, the One-Member First Instance
Court of Athens can order the Company’s audit if acts violating provisions of laws, or the Company’s Articles
of Association, or decisions of the General Meeting of Shareholders, are thought likely. In any case, the
request for audit must be submitted within three (3) years after approval of the financial statements for the
fiscal period within which the reported acts have taken place.

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9. On request by Shareholders representing 1/10 of the paid-in share capital, which is submitted to the
Company at least five (5) full days prior to the General Meeting, the Board of Directors is under an obligation
to provide to the General Meeting information on the course of the company affairs and the Company’s
assets’ status. The Board of Directors may refuse to provide such information on the basis of adequate
cause and with reasoning that is recorded in the Minutes. Any dispute as to the validity or not of the
reasoning for refusing to provide information is resolved by the One-Member First Instance Court of Athens
by a judgment thereof, issued according to the interim measures’ procedure.
10. On request by Shareholders representing 1/5 of the paid-in share capital, the One-Member First Instance
Court of Athens can order the Company’s audit if, from its overall course, it is deduced that the management
of company affairs is not exercised as prescribed by due and prudent administration.
Right to Dividend
The minimum dividend that is mandatorily distributed annually by the Company equals the minimum annual
dividend provided by article 161 par. 2 of L. 4548/2018, which amounts, at minimum, to 35% of the Company’s net
income, after the withholdings required for creating a statutory reserve. By a General Assembly decision, taken by
a special quorum (½ of the paid up share capital) and majority (2/3 of the share capital represented at the General
Meeting), this percentage may be reduced, though not below 10% of the net profits, while its abolition is allowed
only by an 80% majority of the share capital represented at the General Meeting.
Dividend is paid within two (2) months from the date of the Annual General Meeting of Shareholders that
approves the Company’s annual and consolidated financial statements. The date and means of the dividend’s
payment are published on the Athens Stock Exchange and the Company’s websites, as well as in the Press.
According to Greek law, dividends, which remain unclaimed for a period of five years after the date on which they
were rendered claimable, are transferred to the Greek State.
Shareholders’ Information
The Shareholders Services and Corporate Announcements Department is entrusted with the responsibility of
maintaining and updating the registry of the Company's shareholders. Its responsibilities encompass providing
shareholders with accurate, timely, precise, and unbiased information, as well as assisting them in the exercise of
their rights.
The Company, whose shares listed on the stock exchange, is obliged to publish announcements in compliance
with Regulation (EU) 596/2014 of the European Parliament and Council on Market Abuse (MAR), Greek Laws
4443/2016 and 3556/2007 and the decisions of the Hellenic Capital Market Commission. The dissemination of
this information is conducted in a manner that ensures rapid and equitable access for investors.
All pertinent publications and announcements are made available on both the Athens Exchange and the
Company’s websites and are communicated to the Hellenic Capital Market Commission.
The Investor Relations Division is responsible for the distribution of the Company's published editions (Annual
Report, Annual and Half-Year BoD Report, Prospectuses) to all stakeholders, ensuring that the investment
community is provided with accurate and equitable information regarding matters concerning the Company and
the Group. Additionally, the Division manages the Company’s communications with the competent authorities,
including the Hellenic Capital Market Commission, Athens Exchange, London Stock Exchange (secondary listing
though Global Depositary Receipts), and Luxembourg Stock Exchange regarding bonds).

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Dialogue with the stakeholders and management of their interests
Over time, the Company has committed to fostering timely and transparent communication with its stakeholders.
This has been achieved through the utilization of various communication channels tailored to each stakeholder
group, grounded in the principles of flexibility and the facilitation of understanding their respective interests.
In particular, with regard to stakeholders such as social partners who are associated with both broader and local
communities, the Company's collaboration is characterized by continuous engagement and is executed through
ongoing and substantive dialogue.
Additional information pertaining to the stakeholders, the nature of the dialogue, and the reciprocal
communication and interaction with the Company is detailed in the Sustainability Statement within this report, as
well as in the Annual Report.
10 Following HRADF's merger by acquisition from Hellenic Corporation of Assets and Participations (HCAP) on 31.12.2024, HCAP has substituted
HRADF, as its statutory successor, in all relevant provisions of the Company's Articles of Association.

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Β.1.7 Composition and Operation of the Board of Directors,
Supervisory Bodies and Company Committees
Generally
The Company is governed by the Board of Directors (BoD), a body which is collectively responsible for its long-
term success. The Board of Directors exercises its responsibilities in accordance with Greek legislation,
international best practices, the Company’s Articles of Association and any decisions reached by the General
Meeting of the Company's shareholders.
The BoD comprises eleven (11) members who are elected in accordance with the provisions of Article 20 of the
Company’s Articles of Association. More specifically, the Greek State has the right to appoint four (4) members to
the Board of Directors if it holds a percentage above 35% of the voting shares of the Company and three (3)
members if it holds a percentage below 35% but above 25% of the voting shares of the Company (Article 20,
paragraphs 2a, 4 and 11 of the Company's Articles of Association). As of 8 December 2023 the Greek State’s
indirect participation in the Company’s share capital, through the HCAP 10, is 31.18%. The remaining members of
the BoD are elected at the General Meeting, without the participation of the HCAP (or any natural or legal person
associated with it), if the right of direct appointment has been exercised. The selection of candidates for the BoD is
conducted in both cases in accordance with the criteria as set out in the Company's suitability policy. The term of
office for the Board of Directors is three years while members can be re-elected and their terms are freely
revocable.
The Annual General Meeting of shareholders held on 27.06.2024 appointed the current Board of Directors for a
three‑year term (which, in any case, is extended until the date on which the Ordinary General Meeting for the year
2027 is convened) and designated the independent non‑executive members of the Board.

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The BoD composition, its members’ attendance of meetings and the number of Company shares held by each
member is presented in the following tables. The BoD met eleven (11) times in the year 2025.

BoD Composition | Capacity | Participation in BoD meetings (total 11) | Start of participation in the BoD | Number of Company shares
Spilios Livanos | Chairman – Non-executive member | 11/11 | 2024 | 0
Andreas Shiamishis | Chief Executive Officer – Executive Member | 11/11 | 2013 | 0
Georgios Alexopoulos | Deputy Chief Executive Officer - Executive Member | 11/11 | 2016 | 5,000
Iordanis Aivazis | Senior Independent Director, independent non-executive member | 11/11 | 2019 | 10,000
Theodoros-Achilleas Vardas | Non-executive member | 11/11 | 2003 | 15,396
Nikolaos Vrettos | Independent non-executive member | 10/11 | 2021 | 0
Stavroula Kampouridou | Independent non-executive member | 11/11 | 2024 | 0
Constantinos Mitropoulos | Independent non-executive member | 11/11 | 2024 | 0
Anna Rokofyllou | Non-executive member | 11/11 | 2024 | 0
Panagiotis (Takis) Tridimas | Independent non-executive member | 11/11 | 2021 | 10,000
Alkiviades Psarras | Non-executive member | 11/11 | 2019 | 10,000

In accordance with article 18, par. 3 of L. 4706/2020, there follows a table with the number of shares held also by
the chief Management Officers of the Company.

General Managers | Position | Number of Shares
Ioannis Apsouris | Group Legal Services General Manager | 50
Georgios Dimogiorgas | Refineries General Manager | 8,000
Konstantinos Karachalios | Oil Products Supply & Trading General Manager | 0
Aggelos Kokotos | Group Internal Audit General Manager | 1,086
Leonidas Kovaios | Group IT & Digital Transformation General Manager | 0
Alexandros Tzadimas | Group Human Resources & Administrative Services General Manager | 0
Vasileios Tsaitas | Group Chief Financial Officer | 3,000
Konstantinos Pantazis | Refineries Deputy General Manager | 0

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BoD members’ experience and basic skills are presented in the
following table:

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Roles and responsibilities of the BoD
The Board of Directors serves as the highest governing authority within the Company and is principally
responsible for formulating corporate strategy, as well as overseeing and controlling the management of the
Company’s assets. The composition and responsibilities of the members of the BoD are determined by Law and
the Company’s Articles of Association. The primary obligation and duty of the BoD members is to constantly
pursue the strengthening of the Company’s long-term economic value and to protect the general company
interest.
In order to achieve the company objectives and the Company’s smooth operation, the BoD may assign part of its
authorities, except those requiring collective action, as well as the management administration or governance of
the affairs, or the Company’s representation to the Executive Committee, the CEO, or to one or more BoD
members (executive and non-executive), to Company employees or third parties. BoD members and any third
party to whom BoD authorities have been delegated by the BoD are prohibited from pursuing personal interests
that conflict with those of the Company. BoD members and any third party to whom BoD authorities have been
delegated, have to promptly disclose to the rest of the BoD members any personal interests which might arise as a
result of Company transactions falling within their duties, as well as any other conflict of personal interest with
those of the Company or associate companies, arising in exercising their duties, in accordance with the Company’s
relevant policies.
Indicatively, the BoD has the following responsibilities:
1. Decides on any act concerning the Company’s representation, governance, its assets’ management and the
pursuit of its purpose, in general;
2. Manages the corporate affairs with the object of promoting the company interest; oversees the
implementation of its decisions, as well as of those of the G.M.;
3. Determines and supervises the corporate governance system of articles 1 to 24 of L.4706/2020, and
monitors and periodically assesses, at least every three (3) financial years, its implementation and
effectiveness, proceeding to the necessary actions for dealing with deficiencies;
4. Ensures the adequate and effective operation of the Company’s Internal Audit System (“IAS”);
5. Ensures that all operations comprising the ICS are independent of the business segments they control and
that they have the appropriate financial and human resources, as well as the powers for their effective
operation, as prescribed by their role. The reporting lines and allocation of responsibilities are clear,
executable and duly documented;
6. Makes sure that the Company’s annual financial statements, the annual management report and the
corporate governance statement, their consolidated form, as well as the BoD members’ remuneration
report, are drafted and made public in accordance with the provisions of the law;
7. Recommends to the G.M. the appointment of a certified auditor accountant or audit firm;
8. Ensures that the Company’s strategic planning is aligned to corporate culture;
9. Approves the strategic and the annual business and financial plan;
10. Determines the extent of the Company’s exposure to risks it intends to assume;
11. Ensures that an effective regulatory compliance procedure is in place;
12. Sets or/and delimits the responsibilities of the Chief Executive Officer and of the other persons to whom it is
entitled to delegate powers of the Company’s management and representation, in accordance with the
Company’s Articles of Association;
13. Posts and keeps updated the information regarding the election of its candidate members;

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14. Is updated and decides on any other development affecting the Company’s status and operation.
New BoD members’ induction
In accordance with the BoD members’ Training Policy, the new BoD members attend an induction program aimed
at providing them with information that they will find useful in discharging their duties effectively.
The Board of Directors’ Strategy Day
Apart from the formal BoD meetings of the Board of Directors, an annual meeting is held in order for its members
to have the time needed to discuss major strategic initiatives related to the development of the Company and the
Group.
In 2025 the meeting was held on 25 June involving a discussion on strategic issues.
Conflict of interest
The BoD members have, by law, a duty of care and loyalty towards the Company. They act with integrity and to
the Company’s interest and safeguard the confidentiality of the non-publicly available information.
The BoD members have to avoid any situation creating a conflict between their personal interests and those of
the Company, not to acquire advantages and personal benefits at the expense of the Company, unless they are
authorized by the General Meeting of the Company’s shareholders, or the BoD. The BoD members must not be in
competition with the Company and must avoid any position or activity creating conflict between their private
interests and those of the Company, including participating in the share capital (by a percentage > 0.5%), holding
posts in the BoD or the Management of competitive companies.
The BoD members must contribute their experience and dedicate to their duties the requisite time and attention.
They must report to the BoD’s Nomination Committee other professional commitments they have, including
substantial non-executive commitments to companies, both prior to assuming their duties, as well as every time
that some major change occurs during their term of office.

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BoD members’ participation in other companies
Except where participating in companies that are parties related to the Company, per the meaning of Annex A of L.
4308/2014, the Company’s BoD members, are members of the following legal entities’ governing, management
or supervisory body:

First & Last Name | Function | Participation in another company
Spilios Livanos | Chairman | BoD Chairman and CEO / DION Real Estate, Contracting, Management and Consulting Single-Member Société Anonyme
Andreas Shiamishis | Chief Executive Officer | Vice President Hellenic Federation of Enterprises (SEV)
Georgios Alexopoulos | Deputy Chief Executive Officer | BoD Chairman / SEV VIAN BoD Member / American - Hellenic Chamber of Commerce
Iordanis Aivazis | Senior Independent Director, Independent Non- Executive Member | Chairman of the Special Liquidations Committee / Bank of Greece
Theodoros-Achilleas Vardas | Non-Executive Member | Administrator / KARIASTI CONSULTING Single- Member P.C.
Stavroula Kambouridou | Independent Non-Executive Member | CEO / DIAS S.A. Independent Non-Executive BoD Member / Fourlis Holdings S.A. BoD Member / EACHA (European Automated Clearing House Association)
Constantinos Mitropoulos | Independent Non-executive Member | Independent Non-executive BoD Μember / MOTODYNAMICS S.A. Independent Non-executive BoD member / PLAISIO S.A. Independent Non-executive BoD member / ELTRAK S.A. Independent Non-executive BoD member / Cyprus Development Bank Ltd. BoD member / IOBE (Foundation for Economic and Industrial Research)

Executive and non-executive BoD members
The executive members of the BoD, headed by the Chief Executive Officer, are occupied with the day-to-day
management of affairs falling under their areas of responsibility, as well as with ensuring the smooth running of
the Company. They are responsible for implementing the strategy defined by the BoD and for supervising the
execution of its decisions. Special BoD decisions determine how the Company is represented and bound.
The criteria and the procedure for evaluating the independence of the BoD members are defined in detail in the
Procedure for the Disclosure of Dependency Relationships of Independent Non-Executive Members of the
Company’s BoD, where the rules and the procedure are established, on the one hand, for the evaluation of
fulfillment of the independence criteria and, on the other hand, for the disclosure of any dependency relationships
of the independent members of the BoD and the persons who have close ties with them.
The Nominations Committee reviews the BoD members' independence, on an annual basis.
The non-executive members of the BoD, including the independent non-executive members, are charged with: (i)
monitoring and reviewing the Company’s strategy, its implementation, as well as the achievement of its goals; (ii)
the executive members’ effective supervision, including the supervision of their performances. Non-executive
Members of the BoD meet at least each year and convene for Extraordinary meetings when considered
appropriate without the presence of executive members in order to discuss the performance of the latter. In 2025,
the company's independent non-executive members met on 05.05.2025 and discussed issues concerning the
BoD’s and its committees’ functioning and the Company’s strategy and governance, in general.

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BoD Chairman
The BoD Chairman, who is a non-executive member, is responsible for convening, chairing and steering the
meetings, for the keeping of minutes, the signing of the relevant resolutions and for the BoD’s operation, in
general, as this is provided in the Company’s Articles of Association and the law. The Chairman’s responsibilities
are determined on the basis of the Company’s Articles of Association, the applicable legislation, the assignment of
responsibilities based on relevant BoD decisions, and the Code adopted by the Company, as set out in the
Company’s Bylaws. The most senior non-executive BoD member deputizes for the Chairman, when he is absent or
impeded.
Chief Executive Officer
The Chief Executive Officer serves as the principal governing authority and legal representative of the Company,
bearing responsibility for all business segments and operational activities. The Group Internal Audit General
Division reports administratively to the Chief Executive Officer.
Senior Independent Director
In accordance with its Operation Regulation, the BoD has appointed one of its independent members as the
"Senior Independent Director" with the following responsibilities:
i. supports the Chairman of the BoD,
ii. coordinates the effective communication between the Chairman and the BoD members ,
iii. chairs the meetings of the non-executive members of the BoD and the procedure concerning the
evaluation of the Chairman by the BoD members.
Mr. Iordanis Aivazis, the most senior among the independent non-executive members of the BoD (since June
2021), was appointed as the Senior Independent Director.
Concise curricula vitae of the BoD members are set out in the Appendix to the present report.

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BoD Committees
The BoD has set up committees for the purpose of achieving the company objectives and the Company’s smooth
operation. Each BoD Committee discharges the duties assigned to it by the BoD, acts within its remit and
promptly informs the BoD regarding its actions and any developments that came to its attention.

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Audit Committee
In accordance with the prevailing Operational Regulation, the Audit Committee may be constituted either as
a committee of the Board of Directors, exclusively composed of non-executive members, or as an
independent committee, consisting of non-executive members of the Board of Directors and external
parties, or solely external parties. The nature of the Committee, the duration of its term, the number of its
members, and their respective functions are determined by the Company's General Meeting of shareholders
The Audit Committee is comprised of no less than three (3) members, who, in their majority, are independent of
the Company, within the meaning of the provisions of article 9 of L. 4706/2020.
The Committee’s members have adequate knowledge of the sector in which the Company is active. At least one (1)
member of the Committee, which is independent in the meaning of the provisions of article 9 of L. 4706/2020,
has proven adequate knowledge and experience in auditing or accounting. This member is obligatorily present at
the Committee’s meetings concerning the approval of the financial statements.
By the Annual General Meeting of shareholders’ decision concerning the Audit Committee, taken on 27.06.2024:
• it was determined that the Audit Committee constitutes an independent (mixed) committee, comprising of
three independent non-executive members of the Board of Directors and a third person, non-member
thereof,
• Mr. Panagiotis Papazoglou was elected as third (non-BoD member) member of the Audit Committee and,
• the BoD was authorized to designate the three other members of the Audit Committee from among its
independent non-executive members, after ascertaining the fulfillment of the criteria and conditions of
article 44 of L. 4449/2017.
In acting on the above decision, the Company’s Board of Directors, at its meeting on the same day, appointed
Messrs. Iordanis Aivazis, Stavroula Kambouridou and Panagiotis Tridimas, independent non-executive BoD
members (elected as such by the Annual General Meeting of 27.06.2024), as members of the Audit Committee
after having ascertained that they fulfill the independence prerequisites of article 9 par. 1 and 2 of L. 4706/2020
and all article 44 of L. 4449/2017 criteria, since together they have proven adequate knowledge of the sector in
which the Company is active and two (2) of them, Messrs. P. Papazoglou and I. Aivazis, have adequate knowledge
and experience in accounting, auditing and finance. As such, by that composition, the Audit Committee can
discharge the responsibilities and duties stated in par. 3 of article 44 of La. 4449/2017.
Subsequently, the Audit Committee, during its meeting on July 4, 2024, was formed into a body, electing Mr.
Iordanis Aivazis as its Chairman and Messrs. Stavroula Kampouridou, Panagiotis Papazoglou and Panagiotis
Tridimas as its members.
The Audit Committee supports the Company’s BoD in its duties regarding the oversight of:
• the financial statements’ statutory audit procedure and the BoD’s updating on its results;
• the completeness and integrity of the standalone and consolidated Company financial statements;
• the design adequacy and operational effectiveness of the system of internal controls ;
• the effective risk management, quality assurance and compliance of the Company;
• the Company’s compliance with the legal and regulatory requirements applicable from time to time, as well
as with the Code of Conduct;
• the design adequacy and operational effectiveness of the corporate governance system;
• the internal audit procedure, and the GIAGD’s performance;
• the certified auditors/audit firm’s selection procedure and review of their independence.

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Correspondingly and in relation to the above, the Audit Committee has the following responsibilities, in
greater detail:
1. It monitors the procedure and conduct of the statutory audit of the Company’s standalone and consolidated
financial statements. In this context, it updates the BoD by submitting a relevant report on the issues that
arose from the statutory audit’s conduct.
2. It monitors, examines and evaluates the financial reporting preparation process; namely the mechanisms
and production systems, the flow and dissemination of the financial information issued by the Company’s
organizing units involved. The Audit Committee informs the BoD of its findings and submits proposals for
improving the process, if considered advisable.
3. It monitors, examines and assesses the adequacy and effectiveness of the Company’s policies, procedures
and controls regarding, on one hand, of the system of internal controls and, on the other hand, the
assessment and management of risks related to financial reporting. As regards the internal audit function,
the Audit Committee monitors and inspects the GIAGD’s proper operation and evaluates its work, adequacy
and effectiveness, without, however, infringing on its independence. Furthermore, it reviews the information
disclosed as regards the internal audit and the Company’s main risks and uncertainties in relation to financial
reporting. In this context, the Committee informs the BoD of its findings and makes suggestions for
improvement, where appropriate.
4. It reviews and monitors the certified auditors/audit firms’ independence in accordance with L.4449/2017
(articles 21, 22, 23, 26 and 27), as well as with article 6 of Regulation (EU) 537/2014 of the European
Parliament and of the Council of 16th April 2014, and in particular, the appropriateness of providing non-
audit services to the audited entity, in accordance with article 5 of the Regulation.
5. It is responsible for the certified auditors’/audit firm’s selection process and nominates the certified
auditors/audit firms that will be appointed by a decision of the General Meeting.
During 2025, the Audit Committee, exercising its responsibilities, held eighteen (18) meetings. These including
two (2) joint meetings with the Sustainable Development Committee and one (1) joint with the Remuneration and
Succession Planning Committee. Throughout the year, the Committee thoroughly discussed all topics within its
remit, with emphasis on the following: (a) external audit, financial reporting and sustainability report, (b) internal
audit, (c) assessment of the adequacy of the Internal Control System, (d) cyber security, (e) regulatory compliance
(f) organizational matters of the Committee and (h) other matters related to the mandate of the Committee.
The key activities undertaken covered:
• Reviewing and discussing with the external auditors the timetable and planned approach for the statutory
audit of both the Company and consolidated financial statements for fiscal year 2025, as well the review of
the semi-annual financial statements.
• Reviewing and discussing with Management and the external auditors (including two private sessions with
the auditors) the annual financial statements for the year ended 31.12.2024 and the semi-annual report for
the period ended 30.06.2025. The Committee briefed the Board of Directors on the results of the audit.
Additionally, the Audit Committee reviewed, discussed with Management and reported to the Board of
Directors on, the unaudited quarterly financial results for the periods ended 31.03.2025 and 30.09.2025.
• Reviewing and discussing the external auditors’ memorandum on the system of internal control procedures
over the financial reporting of the Company/Group from the audit for the year 2024 (Management letter)
and monitoring progress in addressing recommendations raised.
• Confirming that the sustainability information was reviewed by EY as part of the audit of the 2025 Annual
Financial Report and took into account, along with the content of the auditor's supplementary report on the
financial statements, the results of the limited assurance on the sustainability report.

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• Reviewing the sustainability reporting information related to environmental, social and governance (ESG)
matters, both by the Sustainable Development Committee and by the auditing firm EY, regarding the
completeness, accuracy, adequacy and disclosures of the aforementioned indicators and other
sustainability information included in the Sustainability Report.
• Submitting, along with the financial statements, to the Board of Directors the sustainability report which
forms part of these statements, the review and approval of which is the responsibility of the Sustainable
Development Committee.
• Reviewing and approving the assignment of the second triennial external evaluation of the System of
Internal Controls and Corporate Governance System in accordance with article 14 of Law 4706/2020, which
should be completed by February 2026, so that the Group's external auditors have the findings of the
Evaluation Results Report prior to issuing their audit opinion.
• Reviewing and unanimously approving the updates to the Internal Audit Unit Charter and manuals, and
recommending to the Board of Directors the approval of the revision of the Audit Committee's Charter and
the Internal Audit Charter.
• Reviewing the organizational changes made in the Internal Audit Unit.
• Monitoring the effectiveness of the Company’s Group Internal Audit Unit ‘GIAU’ and approving the Internal
Audit Plan, Budget and Training Plan for 2025.
• Quarterly and ad hoc meetings with the Head of Group Internal Audit Unit and GIAU managers to discuss
operational and organizational matters of GIAU, internal audit reports, quarterly activity and progress
reports with the key findings; the BoD was informed of these reports, including their key findings and the
manner in which they were addressed.
• Reviewing the commencement of the Risk Assessment Process by the Risk Monitoring and Management
Division by the Risk Monitoring and Management Division and the results of the above process will be sent
to the Group Internal Audit Unit to be used in the 2026 audit plan.
• Assessing the performance of the Head of GIAU and approved the salary review of the GIAU’s General
Manager’s remuneration (in a joint meeting with the Remuneration and Succession Planning Committee).
• Approving the annual plan of the Regulatory Compliance Officer and receiving information for 2024 report
and semi-annual updates on its activities.
• Conducting an assessment of the external auditors’ performance and, based on the experience and
expertise of EY’s audit team, concluded that the audit process implemented was effective. Consequently, it
recommended the reappointment of EY as the audit firm for the financial year 2025 (the ninth consecutive
year, following the relevant tender process in 2017).
• Approving the remuneration of the external auditors.
• Approving all requests from the statutory auditors regarding the provision of services to the Company,
beyond the regular audit, after confirming that: (a) such services were permitted by the relevant legislation
and (b) the fees for their provision did not compromise the independence of the statutory auditors.
• Submitting periodic reports on the Audit Committee’s activities to the Board of Directors.
• Submitting its Activity Report for 2024 to the Board of Directors and subsequently to the Ordinary General
Meeting on 19 June 2025.

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Statements of BoD members | Board of Directors' Report | Full Year Financial Statements | Auditors' Report

The table below clearly displays each member's attendance at their respective Audit Committee meetings.

Audit Committee Composition | Capacity | Participation in Audit Committees' meeting (total 18)
Iordanis Aivazis | Chairman - Senior Independent Director, Independent non-executive BoD member | 18/18
Stavroula Kampouridou | Member - Independent non-executive BoD member | 17/18
Panagiotis Tridimas | Member - Independent Non-Executive BoD member | 17/18
Panayiotis Papazoglou | Member - third (non- BoD) member | 18/18

Upon unanimous acceptance of the Audit Committee’s recommendation by the Board of Directors, EY’s re-
election for the statutory audit in 2025 was approved by the Ordinary General Meeting of Shareholders on 19 June
2025.
The Committee assessed the performance of the external auditors, considering the audit process's effectiveness,
team experience, technical expertise, and the quality of communication and reporting to the Committee. Based on
the Committee's experience from the 2024 audit, relevant recommendations from Management, and after
thorough review and evaluation, the Committee recommended to the Board of Directors the reappointment of EY
as the audit firm for 2025. This will mark the ninth consecutive term for EY as the statutory auditor, responsible
for the mandatory audit of the annual and half-yearly consolidated financial statements. Additionally, EY will
conduct an audit to ensure the accuracy and submission of the 2025 Sustainability Statement.
Finally, the Audit Committee supervised the election process for new auditors for the 2027 financial year, in
accordance with Law 4449/2017 and EU Directive 537/2014, which mandate auditor rotation after a maximum of
ten years. This included organizing and conducting a tender process, identifying the preferred contractor, and
submitting a recommendation to the Board of Directors for the appointment of the new auditors for the 2027
financial year.
All the Committee’s decisions were taken unanimously. The Committee may, at its discretion, invite other
members of the Board of Directors or key individuals from within or outside the Company to provide information
or attend specific meetings or agenda items, as deemed appropriate. The CEO, the Group CFO, the General
Manager of Internal Audit, the General Manager of Legal, the General Manager of IT, the Director of Financial
Consolidation, the Senior Group Manager of Taxation and Customs Affairs, the Director of Risk Management, the
Compliance Officer, as well as the statutory auditor, are regularly invited to Committee meetings at the
Committee Chairman's initiative.
Remuneration and Succession Planning Committee
The Company's Remuneration and Succession Planning Committee comprises of three (3) non-executive
members of the Board of Directors, two of whom are independent. For the period 01.01.2025-31.12.2025, the
Committee’s Chairman was Mr. Nikolaos Vrettos, independent non-executive member of the Board of Directors,
while its members were Messrs. Mr. Theodoros-Achilleas Vardas, non-executive member of the Board of Directors
and Mr. Iordanis Aivazis, Senior independent non-executive member of the Board of Directors.
The mission of the Remuneration and Succession Planning Committee is to:
1. Support the BoD in the work of drafting or/and revising the Remuneration Policy, which is submitted for
approval to the GM, as well as to study the information included in the annual remuneration report, opining
on such to the BoD, prior to its submission to the GM.
2. Formulate or approve proposals by the Management on the guidelines’ framework regarding the
remuneration of Top Management Officers and Management Officers and approve proposals by the Chief
Executive Officer to the BoD regarding the remuneration of the Group Internal Audit General Manager (in
collaboration with the Audit Committee).

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3. Formulate or approve proposals by the Management regarding variable remuneration plans and voluntary
retirement schemes, insurance schemes and performance incentive schemes for Top Management Officers
and Management Officers.
4. Ensure that a Top Management Officers’ succession plan is in place and cater for submitting relevant
recommendations to the BoD and/or the Chief Executive Officer.
During 2025, the Remuneration and Succession Planning Committee held four (4) meetings, including one (1) joint
meeting with the Audit Committee. The agenda of the most important issues examined during its meetings is
summarized as follows:
• Remuneration Report of the members of the Board of Directors (based on article 112 of Law 4548/2018) for
the fiscal year 2024.
• Update of the remuneration framework for the members of the Board of Directors of the Group's
subsidiaries.
• Proposal for the payment of an extraordinary one-off remuneration (extra bonus) to executives who were
involved in the projects of ELPEDISON and DEPA Commercial.
• Specialization of the terms of the Stock Award Program for the Senior Management Team and selected
executives at the Management level of HELLENiQ ENERGY and its affiliated companies.
• Salary adjustments of Managerial-level executives for 2025, based on the fixed remuneration policy.
• Variable remuneration for the performance year 2024 of Managerial-level executives.

Composition of the Remuneration and Succession Planning Committee | Membership | Participation in Commission meetings
Nikolaos Vrettos | President of the Committee (Independent non-executive member of the Board of Directors) | 3/4
Theodoros-Achilleas Vardas | Member (Non-executive member of the Board of Directors) | 4/4
Iordanis Aivazis | Member (Senior Independent Member, Independent Non-Executive Member of the Board of Directors) | 4/4

Nomination Committee
The Nomination Committee comprises of three (3) non-executive BoD members, two of which are independent.
Mr. Iordanis Aivazis, Senior Independent Director, is the Committee’s Chairman and its members are Mr.
Theodoros-Achilleas Vardas, non-executive member, and Mr. Panagiotis Tridimas, independent non-executive
member.
The mission of the Nomination Committee, according to the criteria stated in the Company’s suitability policy, is to
identify and nominate to the BoD individuals eligible for BoD and its committees’ membership and to opine on the
suitability of the candidate appointed members that are nominated by the State. Furthermore, the Committee
ensures the smooth succession and continuity of the Company’s BoD and evaluates the suitability, completeness
and effectiveness of the existing BoD members.

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Its main responsibilities are the following:
1. Suitability assessment of Candidate BoD Members appointed by the State;
2. Election of Candidate BoD Members elected by the General Assembly of shareholders (Preparation,
Candidates’ sourcing, Suitability Assessment, Nomination);
3. BoD Evaluation (BoD Evaluation Policy, Annual Evaluation, External Evaluation, Committee’s self-
assessment);
4. BoD Training;
5. Succession Plan;
6. Supporting the BoD in implementing the Company’s Policy for Preventing and Managing Conflict of Interest
Situations.
During 2025, the Nominations Committee held one (1) meeting, during which it examined the fulfilment of the
independence criteria by all independent non‑executive members of the Board of Directors for the year 2024 and
informed the Board of Directors of its conclusion that the said members met the independence criteria, at the
Board meeting held on 27.02.2025. All members of the Committee were present in person at the committee
meeting. In addition, the Nominations Committee supported the Board of Directors during the evaluation process
of the Board and its Committees, which commenced in December 2025 and was completed in February 2026 with
the presentation of the evaluation results to the Board.
Furthermore, the Nominations Committee reviewed the fulfillment of the independence criteria of all independent
non-executive members of the BoD for the year 2025 and informed the BoD on the fulfillment of the
independence criteria of its members in question at its meeting of 26.02.2026.
Other BoD Committees
The work of the BoD is also assisted by other committees, set up by a decision thereof. Specifically, the
current committees are the following:
Strategy and Risk Management Committee
The Strategy and Risk Management Committee was established in 2021, taking into account the requirements of
the Company’s corporate transformation and the emphasis it plays on the management of risks and on changes
of a strategic nature, which occur in the financial, economic, environmental, technological, political and social
environment and may affect its activities overall, its business action, its financial performance, as well as the
implementation of its strategy and the achievement of its goals. More specifically, with the corporate
transformation and Vision 2025, the Company enters into new business activities, which require the prompt
identification and management of risks and the drawing of a strategy suitable for achieving the ambitious mid-
long-term business goals, by planning appropriate investments and securing the necessary resources.
The mission of the Strategy and Risk Management Committee is, inter alia, to approve the corporate framework
for risk management and the relevant policies and methodologies, to determine the level of risk appetite and the
risk tolerance levels, to monitor and approve the management of significant corporate risks, as well as to oversee
the implementation of effective risk management measures.
The composition of the Committee consists of: Andreas Shiamishis, Chief Executive Officer, as the Committee’s
Chairman and its members Georgios Alexopoulos (Deputy CEO, executive BoD member), Theodoros – Achilleas
Vardas (non-executive BoD member), Nikolaos Vrettos (independent non-executive BoD member) and
Constantinos Mitropoulos (independent non-executive BoD member). The Committee met twice in 2025: on
03.06.2025 and on 05.11.2025, with the participation of all its members.

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The most important issues on which the Committee was informed were the following:
• Implementation of strategy and preparation for the next business cycle.
• Group strategy on the Power & Gas sector.
• Updates on the advancement of Group transformation initiatives.
• Status of the implementation of the Group's Risk Management and Regulatory Compliance framework, as
well as matters related to Group insurance.
Sustainability Committee
By integrating sustainable development into its strategic plan, the Group’s core strategy addresses the key issues
of sustainable energy access for all and climate neutrality, as well as the implementation of corporate governance
principles. These governance principles prioritize safe, accident-free, and financially sustainable operations, while
maintaining respect for both the environment and society. The Company and its subsidiaries are guided by their
commitments outlined in the Sustainability Policy, which it is also part of the Company's Bylaws.
Subsequently, the Committee is tasked with assisting the BoD strengthen the Company’s ongoing commitment
to creating value across the three pillars of Sustainable Development: economy, environment and society. It also
oversees the implementation of responsible and ethical business practices related to Environment-Society and
Governance (ESG) issues.
The Committee is composed of George Alexopoulos, Deputy Chief Executive Officer, serving as Chairman;
Nikolaos Vrettos, an independent non-executive member of the Board; Konstantinos Mitropoulos, an
independent non-executive member of the Board; and Anna Rokofyllou, a non-executive member of the Board.
In accordance with the Operation Regulation of the Sustainability Committee, fully covering the requirements in
Article 43 of Law 5164 regarding the obligations related to the Sustainability Report, the Committee is entrusted
with the following responsibilities, among others:
• Ensuring the Group's compliance with the requirements of Directive (EE) 2022/2464 of the European
Parliament and of the Council as regards corporate sustainability reporting (CSRD).
• Identifying and assessing the sustainability risks associated with the Company's and the Group's operation.
• Safeguarding the accuracy and completeness of the sustainable development information and data that are
published.
• Reviewing, approving and monitoring the implementation of the Double Materiality Assessment.
• Supervising, monitoring the preparation and approving the Sustainability Statement, which is included in the
Group's Annual Financial Report, as well as in other reports to credit and financial entities on sustainable
development issues.
• Providing information to the Audit Committee for the final audit of the Sustainability Statement.
• Ensuring that the internal control mechanisms address the requirements set forth in Law 5164/2024
concerning the Sustainability Statement, including, but no limited to, the procedures for compliance with
the Double Materiality Assessment and the collection of sustainability data.
In addition, the committee's duties and responsibilities include the following:
• Reviewing both domestic and international Sustainable Development trends, along with legislative and
regulatory developments that could significantly impact the Group’s business activities.

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• Evaluating the Group's sustainable development operations and governance model, and identifying areas
requiring improvement.
• Monitoring the Group’s ratings by international rating agencies on sustainable development issues and
identifying appropriate actions to enhance these ratings.
• Monitoring progress towards targets related to material sustainable development issues and relevant ESG
Group indicators; providing briefings to the Board of Directors and submitting proposals for corrective
actions.
• Reviewing the processes for updating and providing training to BoD members on issues related to the
Committee’s duties, while identifying areas that may benefit from further enhancement.
• Assessing the Committee’s effectiveness and taking corrective measures in case of identifying
shortcomings.
The Committee convened three times in 2025: on 24 February, 17 September, and 3 December. At its first
meeting, the Sustainability Committee ratified the 2024 Sustainability Statement. During the second session, the
Sustainable Development Committee approved and amended the 2nd edition of the Operation Regulation for the
Board of Directors’ Sustainability Committee. The final meeting of the year focused on the preliminary ratification
of the Group's Double Materiality Assessment outcomes for 2025.
Executive Committee
The Company has an Executive Committee, the responsibilities and operation of which have been determined by a
number of BoD decisions, the most recent of which being decision no. 1337/2/29.11.2018, while its composition is
determined by a decision of the Management.
The Executive Committee is both advisory and executive in nature, as well as executive, to the extent that specific
executive powers will be assigned to it by the BoD. It processes and shapes strategic issues on all sectors of the Group's
and its subsidiaries’ (domestic and international) business activities.
Indicatively (and without limitation), the Executive Committee’s main responsibilities are:
• Formulating the strategy and development plan for the Group’s activities, in the form of mid-term and annual
business plans.
• Monitoring the progress of the works of all Group activities through financial results and ΚΡΙs.
• Monitoring, information and coordination on issues affecting the Group’s activities and requiring a well-
coordinated approach by the entire Management team.

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Executive Committee composition:

Chairman | HELLENiQ ENERGY Holdings S.A. CEO, Andreas Shiamishis
Vice-Chairman | HELLENiQ ENERGY Holdings S.A. Deputy CEO and General Manager Strategic Planning & New Activities, Georgios Alexopoulos, who will be acting for the Chair in any case of absence or impediment of his
General Manager of Oil Products Supply & Trading | Konstantinos Karachalios
Refineries General Manager | Georgios Dimogiorgas
Deputy Refineries General Manager | Konstantinos Pandazis
Chairman and CEO of EKO ABEE | Andreas Shiamishis
Acting Head of International Division | Georgios Grigoras
Group CFO | Vasileios Tsaitas
Group Human Resources & Administrative Services General Manager | Alexandros Tzadimas
Group Legal Services General Manager | Ioannis Apsouris
Group IT & Digital Transformation General Manager | Leonidas Kovaios
Group HSE & Sustainable Development Manager | Antonios Mountouris
Group Procurement Senior Manager | Gerasimos Stanitsas
Group Corporate Affairs Manager | Sotirios Anastasiadis

BoD & Committees Evaluation
The BoD Assessment Policy and the Bylaws (Internal Regulations) adopted by the Company provides for the
annual evaluation of the effectiveness of the Board of Directors (as a collective body), its committees and their
individual members, while this evaluation is provided by an external consultant every three years.
After completing its first year of operation, the current Board of Directors, which was elected on 26 June 2024,
carried out its second evaluation with the support of Egon Zehnder as an independent external advisor. The
evaluation was completed in February 2026 and concerned the collective capabilities of the Board as a body, the
capabilities of its Committees, as well as the individual competencies of its members. The process included the
use of a confidential, specialized online questionnaire and individual interviews with all members of the Board of
Directors and its Committees. The evaluation covered the key dimensions of the Board’s functioning, including its
structure and composition, defined roles and relationships with executive management, operational effectiveness
and meeting procedures, oversight of strategy, business performance and risk management, succession planning
and leadership development, ESG readiness (environmental, social, and corporate governance matters), and the
operation of the Board Committees. This was followed by in‑depth, one‑to‑one interviews with all Board members
to gather qualitative insights and further explore behavioral and operational aspects, the dynamics of the
collective body, and the quality of discussions.
The results were grouped into five thematic pillars — alignment, effectiveness, balance of skills, engagement, and
dynamics — and were presented to the Board of Directors at its meeting of 26.02.2026 for discussion.
The general conclusions of the evaluation are that the Board of Directors operates through effective and
well‑structured procedures, within a framework of collaboration and high professionalism. Its composition reflects
the specific characteristics of the shareholding structure, ensuring operational continuity and the stability of
corporate governance. The relationship between the Chair and the Chief Executive Officer is governed by
institutional rigor and professional consistency, while the Board committees perform their duties reliably, in
accordance with their prescribed mandates, with potential for further enhancement through more systematic
practices. The overall functioning of the Board of Directors is characterized by constructive dialogue and the
substantial contribution of its members to the smooth operation of the company.

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Suitability Policy
The Suitability Policy for the members of the Company’s BoD sets out the core principles and the framework for
the selection, renewal of the term of office and replacement of the BoD members, as well as the criteria that have
been set this purpose. The Policy is aligned with the applicable provisions of the Greek legislation concerning the
corporate governance of sociétés anonymes and is under revision in order to align with the provisions of the new
Articles 3A and 3B (as introduced by Law 5178/2025 regarding gender-balanced representation), as well as with
the updated version of Circular 60 of the Hellenic Capital Market Commission dated 29.04.2025. Moreover, the
Suitability Policy is aligned with the corporate governance code, as this is adopted by the occasional Company
corporate governance statement, in accordance with the provisions of articles 152 of L. 4548/2018 and 17 of Ν.
4706/2020.
The purpose of the Policy is to set out:
a. general principles and guidelines to the Nomination Committee for the selection, evaluation and
nomination of candidate members to the BoD;
b. criteria for the selection and assessment of the suitability of candidate BoD members;
c. criteria for the assessment of the BoD members’ individual and collective suitability.
The BoD, through the Nomination Committee, is responsible for initiating, guiding and coordinating the process
for the election of the suitable candidate BoD members, subject to the shareholders’ rights.
Furthermore, the Nomination Committee receives a written brief by the State (which, according to the Company’s
Articles of Association, has a right to directly appoint BoD members on behalf of the shareholder, HCAP), which
includes the ascertainment of the suitability criteria of the members to-be-appointed, in accordance with the
Company’s suitability policy, as well as their detailed curricula vitae, and opines on it. The Committee’s positive
opinion constitutes an essential precondition for the appointment of BoD members, as per the above.
The Nomination Committee is responsible for identifying candidate BoD members, who, in its view, meet the
relevant criteria. The Nomination Committee’s nominations are submitted to the BoD, which introduces the
nominated for election as BoD members, according to the Committee’s nominations, to the General Meeting of
shareholders, in accordance with article 78 of L. 4548/2018 and the Company’s Articles of Association. The
Committee’s positive opinion constitutes an essential precondition for a candidacy to be nominated by the BoD
for election by the General Meeting of shareholders.
According to the Company’s Articles of Association, the BoD comprises eleven (11) members, of which four (4), at
minimum, are independent non-executive. The number of committees that will be operating in the framework of
the BoD, or any need for assigning further special powers and authorities to its members, may be adjusted in
accordance with its operational requirements, putting their knowledge, reputation and experience to use,
pursuant to the present.
The suitability criteria set by the Suitability Policy are the following:
1. Individual Suitability
◦ Adequacy of knowledge and skills
◦ Morality and Reputation
◦ Independence of judgment
◦ Allocation of sufficient time
2. Collective Suitability
3. Diversity Criteria
More information regarding the Policy and its content is available on the Company’s website "Suitability Policy".

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Statements of BoD members | Board of Directors' Report | Full Year Financial Statements | Auditors' Report

Diversity Policy
The Company considers the principle of diversity to be important for the composition of its governance bodies.
It, therefore, applies a diversity policy with the aim of promoting a suitable level of differentiation in the BoD and a
multi-collective team of members. Through putting together a broad range of qualifications and skills in selecting
the BoD members, a variety of views and experiences is ensured, for the purpose of taking the right decisions.
The Policy includes the basic diversity criteria, which are applied by the Company in selecting BoD members and
constitute essential priorities (diversity goals) of the Company:
• Adequate representation per gender.
• Ensuring equal treatment and providing equal opportunities to all potential BoD members, irrespective of
gender, race, color, national, ethnic or social background, religion or convictions, property, birth, family
status, diversity, age or sexual orientation.
More information regarding the Policy and its content is available on the Company’s website, under the Suitability
Policy.
It is noted that, in that direction, the Company strives to take into account the above in the Human Resources
Management Procedures.

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Statements of BoD members | Board of Directors' Report | Full Year Financial Statements | Auditors' Report

Selected diversity data regarding 2025 are set out below:
BoD Composition
HELLENiQ ENERGY Group data (31.12.2025)

| Managerial level officers | Other staff
Men | 291 | 2,967
Women | 103 | 831
<30 years old | 1 | 197
30-50 years old | 177 | 2,611
>50 years old | 216 | 990
Doctorate (Ph.D) | 23 | 41
Post-graduate degree | 204 | 581
University degree | 153 | 601
ATEI degree | 7 | 766
High School graduate or lower education level | 8 | 1,808

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Special Annual Report of article 3C of Law 4706/2020 οn BoD Gender Balanced
Representation
According to the provisions of Law 5178/2025, in September 2025 the Company published the Special Annual
Report of Article 3C of Law 4706/2020 on BoD Gender Balanced Representation for the 2024 financial year and
simultaneously submitted it to the Hellenic Capital Market Commission, to the Documentation, Research and
Digital Support Department (Observatory) of the General Secretariat for Equality and Human Rights of the
Ministry of Social Cohesion and Family, as well as to the Ombudsman.
According to the Special Annual Report, throughout the financial year 01.01.2024 – 31.12.2024, the Company was
in compliance with the provisions of article 3 par. 1(b) of Law 4706/2020 and the respective requirements of the
Suitability Policy regarding adequate representation per gender and, specifically, at least twenty five percent
(25%) of the total BoD members, which percentage in case of fraction is rounded to the previous integer. Taking
into account the new provisions of Article 3A of Law 4706/2020, introduced by article 5 of Law 5178/2025, which
establish increased requirements for balanced gender representation, the Board will ensure any necessary
changes to its composition within the legally stipulated timeframe, with the aim of improving gender-balanced
representation and safeguarding its collective suitability.

Data on BoD gender balance representation as of 31.12.2025
| Total number | Men | Women | Percentage of underrepresented gender
Members | 11 | 9 | 2 | 18%
Executive Members | 2 | 2 | 0 | —%
Non-Executive Members | 4 | 3 | 1 | 25%
Independent Non-Executive Members | 5 | 4 | 1 | 20%

The Company will prepare, by September 2026, the Special Annual Report pursuant to Article 3G of Law
4706/2020 regarding the Balanced Gender Representation on the Board of Directors, which will relate to the
financial year 2025. Upon its completion, the report will be published and duly submitted in accordance with the
provisions of Law 5178/2025.
Remuneration Policy
The Company has established, maintains and applies core principles and rules in determining the remuneration of
the BoD members (“Remuneration Policy”), which contribute to its business strategy, long-term interests and
sustainability.
The Remuneration Policy was approved, in its original form, by a decision of the Extraordinary General Meeting of
the Company’s shareholders, dated 20 December 2019, and was amended to a limited extent and solely for the
purpose of accommodating changes in the Company’s BoD following the amendment of its Articles of Association
in 2021 by a decision of the Annual General Meeting of 30 June 2021.
The current Remuneration Policy was approved by a decision of the Annual General Meeting of 27.06.2024. This
Remuneration Policy complies with the applicable regulatory framework and is aligned with the Company’s
business strategy (especially after the Company’s strategic transformation and after taking into consideration the
experience from the Policy’s implementation). The Policy is valid for four (4) years following the date of its
approval, unless it is revised / amended earlier, by a General Meeting decision.
More specifically, the Policy:
• Determines the competent bodies involved in its elaboration, approval and monitoring process.
• Explains the structure of BoD members’ remuneration.
• Operates a base of reference in formulating proposals regarding the BoD members’ total remuneration.

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• Established key guidelines for managing and paying remuneration to the BoD members and the way in
which this is formulated.
The Policy covers every type of remuneration, i.e. fixed or variable remuneration, as well as benefits that may be
paid to persons falling within the scope of its application.
Its core principles are summarized below:
Remuneration on account of the BoD membership
The forms of remuneration that may be paid to executive and non-executive members by virtue of the Policy are
outlined below:
Fixed remuneration is payable in accordance with the provisions of article 109 par. 1of L. 4548/18 on BoD
members’ remuneration, as fixed annual remuneration payable on a monthly basis. In addition, remuneration per
BoD meeting is paid. This remuneration aims at being as much as possible aligned to the market levels for BoD
members of companies listed in the Greek Stock Exchange and adapted to the nature and particularities of the
Company.
In addition, according to the applicable legal framework, the rules on corporate governance and the size and
activities which the Company has, a series of committees dealing with individual and more specialized topics is
required.
These committees and their members are determined by the GM where so provided, such as the Audit
Committee, while, in other cases, they are determined by the BoD, if the topics are viewed as major, on account of
financial figures, subject-matter or strategy. In these cases, the BoD determines the subject-matter of each
committee, the members, the authorities and responsibilities they shall have by reason of participating in the
committees in question. The participation remuneration for the members participating in these committees has
the same structure as participating in the BoD (fixed and per meeting), as stated in Annex A. The remuneration for
participating in the committees is exactly the same, irrespective of whether the member is an executive, non-
executive or independent non-executive one, while no other benefits are provided.
The BoD Chairman’s remuneration, aside from the compensation he receives, just as the rest of the BoD
members, is provided for by a mandate contract, which is concluded with the Company and is determined by the
Remuneration and Succession Policy Committee.
It is noted that the BoD members (except those in an employment or mandate relationship with the Company)
may receive additional remuneration also through the distribution of Company shares for free, while all members’
remuneration can be paid by any suitable means, including that of profits’ distribution.
Additional benefits
On top of the above remuneration, there is provision for the possibility of granting additional benefits to the
Company’s BoD members; such remuneration may be varied and, indicatively, regard:
• A fuel card (EKO CARD) for transportation expenses, with monthly consumption of up to 100 liters.
• Possibility of participating in conferences and day-events organized in Greece and sponsored by a Group
company.
• Possibility of participating in training programs concerning the Company activities or the improvement of
the BoD’s operation.
• Possibility to participate in some of the social nature benefits that are available to Managerial Level Officers
or/and the Company’s employees.

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Remuneration of executive BoD members on the basis of employment contracts
Beyond the above remuneration for participating in the BoD, the executive members that are related to the
Company or/and other Group companies with an already in force employment contract, are also paid the relevant
remuneration and benefits (fixed, variable, benefits and participation in group medical care and retirement
schemes, etc.), which are formulated by taking into account the Annex B factors on structuring the total
remuneration level regarding Managerial Level Officers of the Company.
The amount of any variable remuneration is directly linked to the achievement of corporate and personal goals
and is calculated as a percentage on the annual gross standard remuneration, depending on the hierarchical level
of the officer having an Executive Consultant role. This remuneration has been already set based on the provisions
in decisions of the competent bodies and the Company’s salary policies, which aim at attracting, developing and
keeping the suitable executives and are determined also in connection to the general remuneration levels both of
the Group, as well as of the Greek market, in general, taking into account the nature of operations and the
Company’s size.
More information regarding the Policy and its content is available on the Company’s website (BoD members'
Remuneration Policy).
Sustainability Policy
HELLENiQ ENERGY and its subsidiaries align their business activities with the objectives of the United Nations
Sustainable Development Goals and the European Green Deal. Central to the company's strategy are the critical
issues of sustainable energy for all and climate neutrality, as well as the adoption of corporate governance
principles that prioritize safe, accident-free, and economically viable operations, with due regard for the
environment and society.
Specifically, HELLENiQ ENERGY and its subsidiaries are committed to:
• Adhering to legislative requirements and internal or other regulations to which the Group subscribes.
• Implementing and continuously enhancing the Management Systems for Health and Safety, Environment,
and Energy by developing inspection, control, and certification procedures.
• Limiting incidents that jeopardize health, safety, the environment, and society, while maintaining
preparedness for any emergencies.
• Reducing their carbon footprint with the objective of achieving climate neutrality by 2050.
• Employing methods to prevent and reduce emissions and waste throughout the value chain, ensuring the
efficient use of energy and natural resources, and strengthening the circular economy.
• Protecting ecosystems and biodiversity, while implementing sustainable land and water use practices.
• Analyzing and assessing the risks and opportunities related to climate change with the aim of mitigating its
effects and adapting to its impacts.
• Consulting with all social partners to create long-term value for the Group and society.
• Setting specific and measurable goals regarding sustainable development, monitoring progress, and
presenting it based on internationally recognized reference standards, aiming for continuous improvement.
• Raising awareness and providing training to social partners and their suppliers/collaborators on ethical and
responsible behavior throughout the value chain, eliminating all forms of corruption.
• Upholding human rights and respecting diversity and equality, eliminating all forms of discrimination
throughout the value chain, including local communities, consumers, and partners.

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• Defining clear roles and responsibilities for the implementation of the commitments of this policy, ensuring
the availability of necessary resources.
• Maintaining systems for controlling and managing financial and non-financial risks, ensuring the
sustainability of the Group, society, and the environment.
• Adopting best practices for sustainable development in procurement and marketing processes and
throughout the value chain, providing safe, sustainable, and affordable energy products.
All employees and associates of HELLENiQ ENERGY and its subsidiaries are responsible for compliance with this
policy. This policy was approved by the CEO and the Sustainable Development Committee of HELLENiQ ENERGY
on 29 March 2024.
In the context of disclosing the progress and results of the implementation of its policy, the Company publishes its
performance on an annual basis following recognized sustainability reporting standards such as the European
ESRS, the international GRI Standards, the Athens Stock Exchange (Athex) ESG Disclosure Guide, the Greek
Sustainability Code, as well as the principles of the United Nations Global Compact with the relevant progress
report (Global Compact Communication on Progress - CoP).
The Company's material sustainability topics, as well as the methods by which they are addressed, are presented
in detail in the Sustainability Statement, which is part of the Annual Financial Report, in accordance with the
European Corporate Sustainability Reporting Directive (CSRD) and the corresponding European Sustainability
Reporting Standards (ESRS). Further information regarding the Sustainable Development Policy and Strategy is
available on the Company's website (Sustainable Development section).
BoD members’ compensation for their participation in BoD and Committees’
meetings in 2025
For fiscal period 01.01.2025 – 31.12.2025, the compensation paid to the BoD members is the one provided in the
current Remuneration Policy.
The most recent approved BoD members’ remuneration report (fiscal year 2024) was discussed at the Company’s
Annual Ordinary General Meeting, of 19th June 2025, where shareholders representing 81.66% of the share capital
attended, while the percentage of votes “IN FAVOR” amounted to 96.02% of the shareholders present.
The remuneration paid to the Company’s BoD members for the fiscal period 01.01.2025-31.12.2025 include both a
fixed as well as a variable part.
The 2024 remuneration report is available through the website of HELLENiQ ENERGY, while the respective report
for 2025 will be posted after its approval in June 2026.
The Annual General Meeting of 27th June 2024 approved the setting up a long-term plan for distributing Company
shares to executives of the Company and/or companies associated therewith, in the meaning of article 32 of Law
4308/2014. The Plan’s description and main provisions are available in section D. paragraph h) of the Board of
Directors’ Explanatory Report. Due to the structure of the shares’ free distribution plan, the shares to be
distributed are 100% vested to the plan’s beneficiaries after completion of the 1st evaluation cycle; i.e., on
31.12.2026 by their distribution following gradually over the next three years.

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Β.2 Audit Committee Activity Report
Β.2.1 Introduction
Dear Shareholders,
The Audit Committee (the “Committee”) of “HELLENiQ ENERGY Holdings S.A,” (the “Company”) is pleased to
present its report for the year 2025 in accordance with the provisions of article 44 par. 1(h) of Law 4449/2017 to
the General Meeting of the Company’s shareholders. This report outlines how the Committee has fulfilled its
obligations in alignment with the current legislative and regulatory framework.
The report provides an overview of the Committee's purpose and principal activities in 2025, as outlined in its
revised Audit Committee Charter, as well as the activities regarding the Company’s and the Group's interim and
annual financial statements (“financial statements”) of 2025, which were published in 2026. Moreover, this report
describes the Company’s Sustainability Policy, which is available at the Company's website.
Our work plan is initially determined early in the year, with the objective of ensuring that all areas within the scope
of responsibility are comprehensively addressed. Modifications to our plan may be implemented as the year
progresses, depending upon developments.
The Committee held regular meetings throughout the year at least quarterly.
Β.2.2 Purpose of the Committee and Key Responsibilities
1. The purpose of the Committee is to assist and inform the BoD in fulfilling its
oversight responsibilities regarding:
Α) Financial Reporting and External Audit
The Committee is responsible for:
• Performing oversight of the financial reporting process and procedures.
• Reviewing the annual financial statements, semi-annual and quarterly condensed financial statements prior
to their submission for approval by the BoD and submitting recommendations or proposals to the BoD as
considered appropriate.
• Overseeing the procedure and conduct of the statutory audit of the annual financial statements.
• Overseeing the submission of the sustainability report, along with the financial statements, to the Board of
Directors, the review of which is the responsibility of the Sustainability Committee.
Β) External Audit Process
The Committee submits proposals to the BoD on issues arising from the statutory audit, explaining:
• The selection process of the appointment and remuneration of the auditing firm/statutory auditor for the
financial year 2025, for the purpose of recommending its appointment by the Annual General Meeting of
Shareholders ("AGM") to ensure the independence, objectivity and effectiveness of its operation, as well as
its periodic rotation in accordance with the current regulatory framework and the information of the
Committee on the overseeing of the process of preparation on the Sustainability Statement.

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• The Committee’s role in the contribution and results of the statutory audit of the Company’s annual and
consolidated financial statements, regarding the quality and integrity of the financial reporting, including
the relevant disclosures, approved by the BoD and published.
C) The Effectiveness of Internal Control Systems, the Risk Assessment Process, Regulatory
Compliance, Corporate Governance, Internal Audit, Cybersecurity and Sustainable Development
The Audit Committee oversees, examines and evaluates:
• Oversees and assesses the adequacy and effectiveness of the Internal Control System of the Company on
the basis of reports issued by the Group Internal Audit Unit, findings by the external auditors, the tax
authorities and any managed information as appropriate. Assists the Board of Directors in overseeing the
effectiveness and performance of the Group Internal Audit Unit.
• The adequacy and effectiveness of the control activities of the information systems to protect the Group's
information and systems on cyber security issues.
• The submission of sustainability reports.
• Reviews and discusses the periodic reports of the activity of the Group Internal Audit Unit.
2. The Committee reports to the BoD on how it discharges its responsibilities and
provides recommendations to the BoD.
The responsibilities and the operation of the Committee for the fulfillment of its purpose are further detailed in its
Audit Committee Charter, which was revised again in 2025 due to the implementation of the new Global Internal
Audit Standards, as well as the amendments regarding the Committee under L. 5164/2024.
The Audit Committee Charter is available at the Company's website: BoD Committees.
In the execution of its responsibilities, the Committee was granted comprehensive and unrestricted access to all
information deemed necessary and essential for the fulfillment of its obligations.
The Committee shall carry out a periodic evaluation of its Charter annually, and its revised as appropriate.

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The main responsibilities of the Committee cover the following:
Β.2.3 Composition of the Committee, Skills and Experience
The Audit Committee consists of three independent non-executive members of the BoD and a third party who is
not a member, according to the following table:

Full Name | Nature/Capacity | Tenure of Office
Iordanis Aivazis | Chairman - Senior Independent Director, Independent non-executive BoD member | 27.06.2027
Stavroula Kampouridou | Member - Independent non-executive BoD member | 27.06.2027
Panagiotis Tridimas | Member - Independent Non-Executive BoD member | 27.06.2027
Panayiotis Papazoglou | Member - third (non- BoD) member | 27.06.2027
Independent non- executive members | Third (non - BoD) member |
75% | 25% |

(Composition of Audit Committee as of 31.12.2025)

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By the decision of the Annual General Meeting of the Company's shareholders of 27.06.2024 regarding the
Committee:
(i) it was determined that the Committee is an independent (joint) committee consisting of three
independent non-executive members of the Board of Directors and a third person, not a member of the
Board of Directors,
(ii) Mr. Panagiotis Papazoglou was elected as the third person (non-member of the Board) member of the
Committee,
(iii) the Board of Directors was authorized to appoint the remaining three members of the Committee from
among its independent non-executive members, having verified that the criteria and conditions of
article 44 of Law 4449/2017; and
(iv) the tenure of the office of the Committee was set at three years.
All members of the Committee meet the conditions of independence of the Article 9 paragraph 1 and 2 of Law
4706/2020 and all the criteria of article 44 of the law. 4449/2017, as they have proven to have sufficient
knowledge of the sector in which the Company operates and two (2) of them, Mr. P. Papazoglou and Mr. I. Aivazis ,
have sufficient expertise and experience in the field of accounting, auditing and finance.
Brief CVs of the Committee's members have been posted on the Company's website.
The Committee is supported by an Audit Committee Secretary and other staff from the organization, where the
agenda is prepared and distributed to the members together with the information material at least two (2) days
prior to the Committee's meeting, and it may engage external consultants in order to conduct its scope.
Β.2.4 2025 Key Highlights and 2026 Action Plan
In executing our plan for 2025, key points of focus included:
• Consideration of issues that have an impact on the Company's business activities, particularly with respect
to going concern and impairment of non-current assets, such as:
◦ macroeconomic and geopolitical developments,
◦ climate change matters and how those affect the business model
• Overseeing the Group’s financing needs and capital structure, as well as the refinancing activities.
• Overseeing and reviewing the financial statements of the Company and the Group, as well as the external
audit plan.
• Updates and discussions with the Company's Management on strategic matters and significant Group
investments (e.g., the implementation of the Group's strategic plan, focusing on the completion of the
acquisition of the remaining 50% of the share capital of Elpedison B.V., as well as acquisitions in RES
projects).
• Overseeing the effectiveness of the Group Internal Audit Unit (hereafter GIAU) following its renaming from
Group Internal Audit General Division to Group Internal Audit Unit, Regulatory Compliance, Risk
Management Division and Cybersecurity Services.

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• Overseeing, in cooperation with the Sustainability Committee, the implementation plan of the Corporate
Sustainability Reporting Directive (CSRD) for the year 2025.
• Overseeing progress of actions taken to address internal control recommendations, raised by the external
auditors in their Management Letters. It is noted that no new issues were identified to be included in the
Management Letter; on the contrary, it was confirmed that many of the cases included in the letter in
previous years have significantly improved.
• Overseeing the revised of the Internal Audit Charter and Operating Manuals of the GIAU due to the
implementation of the new Global Standards 2025 and the Group's needs, ensuring that the Company
remains aligned with the latest global standards and best practices.
• Overseeing the assignment for the conduct of an assessment of the Internal Control System and Corporate
Governance System (based on Article 14 of Law 4706/2020).
• Completion of the process of electing new statutory auditors for the 2027 financial year, based on Law
4449/2017.
In 2026, apart from continuing to monitor the impact of macroeconomic and geopolitical developments on
the business, other priorities include:
• Overseeing and maintaining oversight of key risks and uncertainties for 2026, overseeing climate change
impact on the Group's assumptions, and risks related to cybersecurity, artificial intelligence and sustainable
finance and operations.
• Overseeing the integration of affiliated companies with risk identification of new activities (mainly Enerwave
-formerly ELPEDISON SA-, expansion of activities in RES ) in the Group's Internal Control System.
• Update on the progress of actions including expanding digital transformation, focusing on operational
optimization, restructuring and investing in human capital, adopting best risk management practices in the
business model, and redefining the ESG strategy.
• Overseeing the results of the Risk Assessment Process by Risk Management Division, with the aim of
further ensuring a uniform methodology at Group level.
• Overseeing and approval of the risk based annual audit program of the GIAU.
• Overseeing the external evaluation process of the Internal Control System and Corporate Governance
System for the years 2023-2025.
• Overseeing the process of outsourcing the external quality assessment (EQA) of the EQA according to the
International Professional Practices Framework (Standard 8.4: "External Quality Assessment").

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Β.2.5 Committee Meetings
In Accordance with Terms of Reference of the Committee, the Committee meets at regular intervals, at least
six (6) times per year and holds extraordinary meetings when required.
• During 2025, the Committee held eighteen (18) meetings, covering all of the areas of financial reporting,
external audit, sustainable development, internal audit, corporate governance, regulatory compliance,
cybersecurity, internal control system and risk management falling within its responsibilities and corporate
governance policies of the Group. The Committee also participated in two (2) joint meetings with the
members of the Sustainable Development Committee regarding the process of reviewing and submitting
the sustainability report to the BoD, as well as the approval of the operating regulations of the
aforementioned Committees and one (1) joint meeting with the Remuneration and Succession Planning
Committee. The attendance at the meetings was very satisfactory, as there was a quorum in all the
meetings.
Depending on the subject matter of each meeting, the following individuals are regularly invited to attend the
Committee meetings:
◦ Head of Group Internal Audit Unit
◦ Group Chief Financial Officer
◦ Group Legal Counsel
◦ Head of Risk Management
◦ Regulatory Compliance Officer
◦ Chief Information Security Officer
◦ Group General of Information Technology and Digital Transformation,
◦ Senior Management of the Company/ Department Heads of the Company
◦ External Auditors

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• The Committee also held two meetings with Management and the external auditors in 2026 to discuss the
2025 annual financial statements and the results of the audit, including the process carried out by the
Company to determine the information required for the submission of the sustainability report, as well as
holding a discussion with the external auditors, without the Management’s presence.
• The Committee members also held frequent discussions/informal meetings in between scheduled meetings
and all of the Committee’s decisions were taken unanimously.
• During the year 2025, the members engaged in a range of conferences and professional development
activities. Furthermore, participation was extended to the Board of Directors' strategy day, recognized as
one of the principal workshops within the period. On this occasion, the Board members were afforded ample
opportunity to deliberate upon the key strategic initiatives pertaining to the advancement of both the
Company and the Group.
• The Committee submitted memos to the BoD prior to the approval of the annual and interim financial
statements, including information on the role of the external auditors and the results of their audits and
provided periodic reports on its activities throughout the year, highlighting issues of importance.
• The Committee met at the Company's Headquarters or by teleconference and during its meetings, minutes
were kept setting out the issues discussed and approvals of the members. The minutes are maintained on
the Group’s Board Management portal.
More specifically, the Audit Committee, according to its 2025 meeting schedule, addressed the following
main topics:

| 2025 Audit Committee Meetings
1 | Readiness Assessment in relation to the new Internal Audit Standards and Review of Internal Audit Unit Manuals
2 | Performance Evaluation of the Head of GIAU and Declaration of Independence
3 | Risk Assessment Monitoring- Results
4 | Approval of the Annual and Three-Year Audit Plan of GIAU
5 | Review and evaluation of the quarterly reports of GIAU and the AC’s proposals thereon, and drafting a related report to the Board of Directors
6 | 2024 Review - Approval of the 2025 Budget of GIAU
7 | Information and Systems Security Monitoring
8 | 2024 Quality Program Review Results and Follow Up on Findings
9 | Regulatory Compliance Issues
10 | Approval of the Audit Committee and the Sustainable Development Committee Charters (Note: common review area for the tasks regarding the implementation of the Corporate Sustainability Reporting Directive – CSRD)
11 | Approval of the revision of the Internal Audit Unit Charter, the Internal Audit Operating Manual, and Other Manuals (Quality Assurance, Vision and Strategy, Other Methodologies)
12 | Meetings with Executive Management for the preparation of the Group's financial statements for the financial year 2024 and the drafting of the Annual Financial Report
13 | Meeting with the auditors to present the Sustainability Statement and review the Group's 2024 annual results
14 | Meetings with the auditors during the audit planning stage, during the execution of the audit, and for the presentation of results – financial statements for the year 2025
15 | Evaluation of external auditors and proposal to the Annual General Meeting for the re-election of auditors for the 2025 financial year
16 | AC proposal to the Board of Directors for the conduct of an assessment of the Internal Control System and the Corporate Governance System in accordance with Article 4 of Law 4706/2020
17 | Approval of the procedure for electing new auditors for the 2027 financial year through a competitive process
18 | Completion of the process of electing new auditors for the 2027 financial year, and a related proposal to the Board of Directors

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Β.2.6 Financial Reporting & External Audit
The Committee actively participated in the financial statement preparation process by convening on nine (9)
occasions out of a total of eighteen (18) meetings, engaging with both the Company’s Management and
external auditors. In addition, the Committee independently conducted a comprehensive review of the
financial statements and associated management information. Upon completion of these assessments, the
Committee formally recommended that the financial statements be submitted for further approval by the
Board of Directors.

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Meetings with Company’s Management and evaluation
The Committee held regular meetings with the Company’s Management prior to the publication of the financial
statements to review and discuss the financial statements and explanatory memos prepared by Group Finance,
covering matters such as:
• Business developments (e.g., refining industry; energy crisis).
• Assessment of possible indication for impairment of assets.
• Updates on specific issues and developments (e.g. business, strategic, institutional framework) affecting the
financial statements.
• Group's operations financing.
• Updates regarding acquisitions and disposals of participations.
• Going concern assessments and assumptions.
• Status of contingencies and litigation - discussed with the Group Legal Counsel.
• Management’s plan for the implementation of the Corporate Sustainability Reporting Directive (CSRD).
Meetings with external auditors
With respect to the annual and semi-annual financial statements, the Committee met with the Company’s
external auditors during the planning, execution and completion phases to review and discuss:
Financial Statements 2025
• Timetable of annual and semi-annual audits.
• Composition of the audit team and involvement of specialists.
• Scope and work plan of the audit including materiality levels to ensure that it addressed the key audit areas
• Key audit matters/risks identified by the auditors.
• The status / progress of the audit and the conclusions of the audit work. The special annual report by the
external auditors to the Committee (A. 10 of EU Reg 537/2014).
In addition, the Committee confirmed as regards the sustainability information that it was reviewed by EY in the
context of the audit of 2025 Annual Financial Report.
Financial Statements 2024
• The status / progress of the audit and the conclusions of the audit work.
• The special annual report by the external auditors to the Committee (A. 10 of EU Reg 537/2014).
• The Internal control recommendations included in the Management Letter and the status and the adequacy
of actions taken by Management in relation to these matters.
• Tax Audit completion and issuance of a tax certificate for 2024 fiscal year.

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Β.2.7 External Auditors
The Committee is responsible for the external auditor selection process and overseeing the periodic rotation
of the statutory auditor
The Committee assessed the performance of the external auditors considering the efficiency of the audit process,
experience of the team, technical expertise and the quality of communication/reporting to the Committee.
Taking into account the Committee's own experience with the 2024 audit, as well as considering feedback from
the Management, and following its review and evaluation, the Committee decided to propose to the BoD the
reappointment of EY and the related fees, as auditors for 2025, for a ninth term for the statutory audit of the
annual and semi-annual consolidated financial statements and for the assurance audit of the 2025 sustainability
report.
It is noted that the Annual General Meeting of the Company's shareholders which was held on 19.06.2025, re-
elected EY to audit the annual and semi- annual consolidated financial statements.
Finally, the Audit Committee completed the process of selecting new auditors for the 2027 fiscal year, based on L.
4449/2017 and in accordance with EU Directive 537/2014, which provides for mandatory rotation with a
maximum duration of 10 years, including the preparation and conduct of a competitive process and the selection
of the preferred bidder, and submitted the relevant proposal to the Board of Directors.
In its relationship with the external auditor:
• The Committee is responsible for ensuring that the external auditor maintains its independence and
objectivity and is effective in conducting its statutory audit.
• The Committee receives the statutory auditor's annual declaration of independence and discusses any
threats that might jeopardize the statutory auditor’s independence and the safeguards ensuring that any
threats are mitigated.
• The Committee considers the representations of the external auditor and the views of Management and
internal audit as appropriate and forms a view on the independence and objectivity of the auditors’.
Non-audit services
The Committee is responsible for the approval of non-audit services by the external auditors to the Group
companies, which are permissible by law.
The Committee recognizes that there may be cases (e.g. due to knowledge of the Group's activities/reasons of
confidentiality), where the statutory auditor is the preferred provider for specific non-audit services, provided that
such services do not affect their objectivity and independence and examines relevant cases, based on the existing
Non-Audit Services Preapproval Policy.
The committee examines:
• the nature of the proposed non-audit services,
• if the skills and experience of the audit firm make it the most suitable non-audit services’ provider,
• remuneration incurred or to be incurred for non-audit services, both individually and as a whole, in relation to
remuneration for audit services, including specific terms and conditions (e.g., non-audit services fee cap)
according to the above Policy.

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Subject to satisfactory conclusion of the above considerations, the Committee confirms that the provision of such
services will not impede the independence or objectivity of the statutory auditor.
In 2025, the Committee examined all requests for non-audit services to be undertaken by the statutory auditor
and concluded that the scope and remuneration of the proposed non-audit services did not jeopardize the
independence or objectivity of the Company's statutory auditors.

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Β.2.8 Internal Audit/System of Internal Controls/Risk Management/
Regulatory Compliance/Corporate Governance/Cybersecurity
The Committee met nine (9) times during the year 2025 to review and discuss the activities of the GIAU,
regulatory compliance and risk management.

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The matters discussed/addressed by the Committee included:
System of Internal Controls and Risk Management
Risk Assessment and Audit Plan
• Presentation of the results of the Risk Assessment process in collaboration with an independent external
advisor and the Risk Monitoring and Management Division for the purpose of drafting the annual and three-
year audit plan of the GIAU for 2025.
• The Risk Assessment process, using the methods and procedures employed by the Company to identify and
monitor risks, track the most significant ones through the Internal Control System, and disclose them in the
published financial information for 2025, was conducted by the Risk Monitoring and Management Division.
The results were presented to the Audit Committee in early 2026 and provided to the General Internal Audit
Unit for the preparation of the 2026 annual audit plan.
• Briefing the activities of the Risk Monitoring and Management Division.
• The Audit Committee's recommendation to the Board of Directors to conduct the 2nd assessment of the
Internal Control System and the Corporate Governance System in accordance with the applicable provisions.
Internal Audit
• The annual and three-year audit plan and any revisions, depending on the Company's needs, taking into
account the main areas of business and financial risk, as well as the results of previous audits.
• The Committee discussed with the Head of GIAU the results of four (4) regulatory compliance audits
conducted by GIAU in collaboration with an external audit firm.
• Approval of the proposed related annual budget.
• The progress of internal audit assignments carried out by the GIAU with all the findings and the
Management’s responses/actions on them and the Audit Plan status communicated through quarterly
activity reports covering the most important areas of control and systems related to financial reporting.
• The progress in addressing high risk findings (discussed on a quarterly basis), as well as other findings
(reviewed every six months).informing the Company's BoD of its findings and submitting proposals for the
implementation of corrective actions, where deemed appropriate.
• The activity report of the Quality Assurance and Improvement Program for the year 2024.
• The update on the impact of implementing the new Global Internal Audit Standards and monitored the
actions taken to adapt the internal audit unit to them through the revision of the Charter and the Internal
Audit Manual.
• The implementation of approved GIAU’s training plan for 2025.
• The new organizational structure of the Internal Audit Unit.
Independence
• The Committee received confirmation of the Independence of the General Director for the year 2025 and
the Declaration of Confidentiality and Avoidance of Conflict of Interest for 2025 by all members of GIAU. It
also received the consent of the Head of GIAU on the Internal Control System. Furthermore, the Committee

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also carried out an evaluation of the General Director's performance for the year 2024 and held a joint
meeting with the Remuneration and Succession Planning Committee, regarding the annual review of the
General Director’s remuneration.
Regulatory Compliance/Corporate Governance
• The Committee held two (2) meetings with the Head of regulatory compliance matters to discuss the report
on the activities undertaken for the year 2024, including recommendations relating to the Organization and
operation of the Compliance function. The Committee also approved the proposed activities for 2025.
• The Company has established and implemented policies and procedures regarding Related Party
Transactions to identify, evaluate, approve and properly disclose its Related Party Transactions. The
Compliance Function ensures that the control procedures with Related Parties are implemented. In this
context, and in order to process the Related Party Transactions Procedure, a revised data collection platform
was created.
• The Audit Committee was informed of the revision of the Code of Conduct and the reporting system for
violations thereof.
Cyber Security
• The Committee held three (3) meetings with the Cyber Security Officer and was briefed by the Cyber
Security Officer and Group CIO on projects/initiatives to protect the Group's information and systems on
cybersecurity issues, the adequacy of controls of information systems and the status on audit
recommendations on the progress of the implementation of the Group's Information Security and Digital
Transformation framework.
• The Audit Committee was informed about the review of security policies that need to be carried out to
ensure their alignment with the new regulatory framework.
Β.2.9 Sustainable Development Policy
Sustainability Information and CSRD
The Committee was informed of the process followed for the preparation of the sustainability report in a joint
meeting with the Sustainability Committee.
The Company has incorporated sustainable development into its strategic planning and has committed through
its Sustainable Development Policy to harmonize its business activities towards the achievement of the United
Nations Sustainable Development Goals (SDGs) and the European Green Deal. At the core of its strategy are the
major issues of sustainable energy for all and climate neutrality by 2050, as well as the adoption of corporate
governance principles that ensure, as a priority, safe and accident-free, economically sustainable operations, with
respect to the Environment and Society.
The Company’s and its subsidiaries' commitments are stated in the Sustainability Policy, which was approved by
the CEO and the Sustainability Committee of HELLENiQ ENERGY within 2024, and all employees and partners are
responsible for compliance with this policy.
The Company's Sustainable Development Policy includes commitments regarding the implementation of
Management Systems for Health and Safety, Environment and Energy, the mitigation of incidents that endanger
Health, Safety, Environment and Society, as well as the reduction of the carbon footprint, analyzing and evaluating
the risks and opportunities related to Climate Change with the aim of mitigating and adapting to its impacts.

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At the same time, the Company is committed to the implementation of prevention and reduction of emissions
and waste throughout the value chain, the efficient use of energy and natural resources, while strengthening the
circular economy, as well as the protection of ecosystems and biodiversity, while applying sustainable land and
water use practices.
With the aim of creating long-term value for the Group and Society, the Company sets specific and measurable
targets related to sustainable development, whose progress is monitored and reported based on internationally
recognized benchmarks, aiming at continuous improvement, while maintains control and risk management
systems, ensuring the sustainability of the Group, society and the environment and adopting best practices of
sustainable development in its procurement and marketing processes and throughout the entire value chain,
providing safe, sustainable and energy products.
The Company is also committed to raising awareness and educating its social partners and suppliers/partners on
ethical and responsible behavior, eliminating all forms of corruption, while upholding human rights and showing
respect for diversity and equality of people, eliminating all forms of discrimination, throughout the value chain,
including local communities, consumers and partners.
In addition to the above, the Company falls within the scope of the CSRD to disclose an annual Corporate
Sustainability Statement as part of the Annual Financial Report and also publishes its ESG performance on an
annual basis, following recognized sustainability reporting standards, such as the GRI Standards, the ATHEX ESG
Reporting Guide, the Greek Sustainability Code and the principles of the United Nations Global Compact
Communication on Progress (CoP).
The substantial sustainability issues concerning the Company’s long-term sustainability as well as the manner of
addressing them, are detailed in the Corporate Sustainability Statement in accordance with the European
Sustainability Reporting Standards (ESRS). They encompass various aspects including the broader pillars of
health, safety, environment and climate change and society, in general.

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Β.2.10 Conclusions
The Committee carried out all the activities provided for in its Charter and fully supported the BoD within the
scope of its responsibilities. The Committee's cooperation with all Group Executives has been entirely satisfactory.
Maroussi, 24 February 2026
Iordanis Aivazis Stavroula Kampouridou Panagiotis Papazoglou Panagiotis Tridimas

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'

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The year 2025 marks the second consecutive year in which HELLENiQ ENERGY Holdings S.A. (“HELLENiQ
ENERGY” or the “Company”), or, where reference is made to the group of companies comprising the HELLENiQ
ENERGY Group (the “HELLENiQ ENERGY Group” or the “Group”), publishes its Sustainability Statement (the
“Statement”) in accordance with the Directive (EU) 2022/2464 and the European Union Corporate Sustainability
Reporting Directive (CSRD). The Statement contributes significantly to enhancing transparency and actively
supporting a more meaningful dialogue with stakeholders, by providing comprehensive qualitative information
and quantitative data on all material sustainability topics.
At the core of the Statement are the Impacts, Risks and Opportunities (IROs) that are considered material, both
from an impact materiality perspective, relating to impacts on the environment and society, and from a financial
materiality perspective for the Group, as identified through the Double Materiality Assessment (DMA). The
Statement incorporates all required disclosures in accordance with the European Sustainability Reporting
Standards (ESRS), across the Environmental, Social and Governance (ESG) pillars.
The Statement presents the Group’s performance in relation to environmental, social and governance matters for
the period from 1 January 2025 to 31 December 2025. The data disclosed are consolidated at Group level, with
limited exceptions in specific areas, as described in the relevant sections of the Statement. Compared to the
previous year, the Statement includes, for the first time, Enerwave, which has been fully integrated into the Group
and now contributes to the Group’s overall sustainability footprint.
In line with ESRS requirements, the Group conducted a Double Materiality Assessment covering all identified IROs
and encompassing the entire value chain. The assessment relates to the current financial year 2025, as well as to
future time horizons, namely the short‑term (2026), medium‑term (2027–2030) and long‑term (2031–2036).
Taking into account all business activities, associated assets and business plans, HELLENiQ ENERGY has
identified 32 material IROs across 11 sustainability thematic areas (covering 8 ESRS Sustainability Matters), as
follows:
Environmental (E): Climate change mitigation and adaptation, Pollution, Water
Social (S): Health, safety and well‑being, Employee consultation and participation, Training, Local community and
economic impact, Mobility, Energy (access and availability)
Governance (G): Corporate culture, Cybersecurity
The identified IROs exhibit significant interdependencies across all stages of the value chain and throughout the
Group’s operations. The nature of these interconnections necessitates the adaptation of strategy, the
strengthening of governance systems, the updating of risk management frameworks, and the continuous
improvement of day‑to‑day operational processes, in line with the Group’s integrated and multi‑dimensional
transition strategy.
Following the completion of the Double Materiality Assessment, and for each material IRO, the Group complied
with all relevant ESRS disclosure requirements, providing comprehensive information on:
• corporate governance and oversight arrangements,
• strategy and business planning,
• policies and actions,
• management systems,
• metrics (Key Performance Indicators – “KPIs”) and targets.

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Indicatively, the Sustainability Statement includes information and data in accordance with:
• ESRS E1, on total greenhouse gas emissions and the Group’s plans for climate change mitigation, together
with a climate scenario assessment of the Group’s assets within the framework of its climate change
adaptation management approach;
• ESRS E2, on policies and measures to mitigate air, water and soil pollution;
• ESRS E3, on the sustainable management of water resources;
• ESRS S1, on health and safety KPIs and targets, workforce-related indicators and the Group’s work‑life
balance management approach;
• ESRS S3, on the direct, indirect and induced positive impacts and footprint not only on the Greek economy,
but also on the economies of other countries where the Group operates, through interactions with suppliers,
customers, consumers and affected communities, including the number of beneficiaries of corporate
responsibility initiatives;
• ESRS S4, on the Group’s active engagement with consumers and end‑users to enhance access to
conventional and sustainable energy products and mobility services;
• ESRS G1, on strengthening ethical culture, integrity and accountability across the Group; and
• the relevant sector‑specific standard addressing potential cybersecurity risks, such as data breaches.
Additionally, the Statement includes full disclosures pursuant to Article 8 of the EU Taxonomy Regulation, relating
to the Group’s taxonomy‑eligible and taxonomy‑aligned environmentally sustainable activities.
HELLENiQ ENERGY remains committed to the continuous enhancement of the completeness, clarity and
comprehensibility of information on material environmental, social and governance matters. The integration of
both impact and financial materiality into decision‑making processes constitutes a key driver for the adaptation of
strategy, the strengthening of the Group’s resilience, and the advancement of sustainable development across
the value chain.

ESRS 2 – General Disclosures |  |  |  |  |  |
Basis for Preparation |  |  |  |  |  |
BP-1 | General Basis for Preparation of Sustainability Statements |  |  |  |  |  |  |
BP-2 | Disclosures in Relation to Specific Circumstances |  |  |  |  |  |  |
Governance |  |  |  |  |  |
GOV-1 | The Role of Administrative, Management, and Supervisory Bodies |  |  |  |  |  |  |
GOV-2 | Information provided to and sustainability matters addressed by the HELLENiQ ENERGY ’s Administrative, Management and Supervisory bodies |  |  |  |  |  |  |
GOV-3 | Integration of Sustainability-Related Performance in Incentive Schemes |  |  |  |  |  |  |
GOV-4 | Statement on Due Diligence |  |  |  |  |  |  |
GOV-5 | Risk Management and Internal Controls over Sustainability Reporting |  |  |  |  |  |  |  |  |  |  |  |  |
Strategy |  |  |  |  |  |
SBM-1 | Strategy, Business Model 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 |  |  |  |  |  |
Impact, Risk and Opportunity Management |  |  |  |  |  |
IRO-1 | Description of the Process to Identify and Assess Material IROs |  |  |  |  |  |  |
IRO-2 | Disclosure Requirements in ESRS Covered by HELLENiQ ENERGY’s Sustainability Statement |  |  |  |  |  |  |

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ESRS 2 - General Disclosures
Basis for Preparation
BP-1 - General Basis for Preparation of Sustainability Statements
This Statement presents the performance of HELLENiQ ENERGY Group, on ESG matters for the period from 1
January 2025 to 31 December 2025. The compilation and consolidation of the data were carried out at the Group
level, using the same scope of consolidation applied in the Group’s 2025 consolidated Financial Statements. Any
specific deviations per disclosure are presented in the corresponding sections of the Statement. [ESRS 2-BP-1-5-(a)]
In 2025, a particularly significant agreement was concluded between HELLENiQ ENERGY and Edison International
Shareholdings S.p.A. regarding the acquisition of 50% of the share capital of Elpedison B.V., which held 100% of
the shares of its Greek subsidiary, “ELPEDISON Power Generation Single Member Societe
Anonyme” (ELPEDISON). On 15 July 2025, following the necessary approvals from Greek and international
authorities, both Elpedison B.V. and ELPEDISON were fully integrated into the HELLENiQ ENERGY Group as
wholly owned subsidiaries. ELPEDISON is one of the leading companies in the Greek energy market, operating in
electricity generation and supply, as well as in natural gas distribution. This acquisition represents a strategic
milestone for the Group, strengthening its presence in Southeastern Europe. Furthermore, on 12 November 2025,
ELPEDISON was renamed as Enerwave, adopting a new corporate identity and a renewed vision.
It should be noted that certain affiliated companies and joint ventures have been excluded from the scope of the
Sustainability Statement, either because their activities do not give rise to significant sustainability impacts, or
because operational control is not exercised by the Group. Specifically, exclusions apply to certain companies in
the Refining and Petrochemical segment (E.A.K.A.A. S.A. and DMEP HOLDCO LTD), the Marketing segment (VLPG
PLANT LTD and SAFCO S.A.) and the Renewable Energy Sources (RES), Power, and Gas segment (DEPA
INTERNATIONAL PROJECTS S.A.). [ESRS 2-BP-1-5-(b)-(i), (ii)]
Within the framework of this Statement, and taking into account the significant changes that occurred in the
Group during the current period compared to the previous one, a DMΑ was conducted for sustainability IROs. The
assessment was carried out based on predefined parameters in accordance with the principles of the ESRS. These
parameters included, among others, stakeholder feedback, sustainability IROs, the volume and geographical
distribution of sales and the number of employees, as well as dependencies and impacts on ecosystems, energy,
fuels, marine resources, and people. The assessment also drew on the materiality criteria of ESRS 1 (para. 31),
which focus on the relevance of information, i.e., its significance for depicting the topic and its usefulness for
decision-making by users, both from a financial perspective and from the perspective of impacts. More detailed
information on the approach and the criteria used for assessing impacts and risks is provided in the section
“Impact, Risk and Opportunity Management – Disclosures on the Double Materiality Assessment Process”.
In accordance with the ESRS and the relevant definitions set out therein, the DMA, and by extension this
Sustainability Statement, covers the entire value chain of the Group (upstream, own operations, and downstream).
The upstream segment includes activities such as the sourcing and transportation of raw materials from first-tier
suppliers, i.e., those providing materials or services directly to the Group. The Group’s operational activities (own
operations) include all activities of its subsidiaries, such as refining, trading, hydrocarbon exploration and
production, as well as renewable energy and e-mobility sectors. Finally, the downstream segment mainly concerns
the use of final products, such as fuels, by consumers. The assessment was conducted systematically, assessing
each segment of the value chain with the aim of mapping internal stakeholders and identifying material IROs that
affect the Group’s sustainability. [ESRS 2-BP-1-5-(c)]
The Group’s intellectual and industrial property rights—such as patents, trademarks, trade secrets, know-how,
and copyright constitute key elements of its business value and productive capacity. For this reason, employees,
executives, and management are responsible for the proper use and protection of these assets, limiting access
and usage strictly to the scope of their professional duties. At the same time, the Group ensures the lawful use
and protection of third-party intellectual property. In cases where the Group obtains a license to use such rights,
the terms and restrictions set forth in the relevant agreements are strictly observed. In accordance with the

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provisions of Articles 19a(3) and 29a(3) of Directive 2013/34/EU, the Group has chosen not to disclose specific
information regarding intellectual property, know-how, or innovations, due to their sensitive nature and in order to
safeguard business competitiveness. [ESRS 2-BP-1-5-(d)]
The Group has not opted to omit disclosure of upcoming developments or issues currently under negotiation.
[ESRS 2-BP-1-5-(e)]
BP-2 - Disclosures in Relation to Specific Circumstances
The Group’s strategic priorities are defined: (a) for the short term (reporting period 2026), (b) for the medium term
(2027–2030), and (c) for the long term (2031–2036), in alignment with the ESRS. Performance monitoring over
the short- and medium-term horizons is based on the implementation of the five-year business plan.
The Group has chosen to extend its planning horizon to include long-term targets (reporting period 2031–2036),
despite the challenges associated with the nature of its business activities. This approach enables optimal
management of uncertainties and ensures alignment with European commitments, as derived from the Paris
Agreement. Progress is systematically monitored to continuously improve sustainability initiatives, while the
Group continually assesses the impacts of new policies and adjusts its business model accordingly. [ESRS 2-BP-2-9-
(a), (b)]
The Statement does not include indicators based on estimated upstream and/or downstream value chain data
using indirect sources, with the exception of Scope 3 emissions. These estimates are limited to emission factors
used for emissions calculations and certain internationally recognized net calorific values for energy conversions.
This exception is described in detail in the section “E1-6 –Gross Scopes 1, 2, 3 and Total GHG emissions". The
assumptions adopted aim to improve the accuracy of calculations for the Group’s current position and are
presented in detail in the subsection “Significant changes, assumptions and methodologies”.The Group considers
that no additional measures are necessary to improve the accuracy of future measurements that include value
chain data derived from indirect sources. [ESRS 2-BP-2-10-(a), (b), (c), (d)]
There are no quantitative measurements or monetary amounts subject to significant uncertainty, including Scope
3 emissions. This assessment is based on the fact that over 95% of Scope 3 emissions are attributed to the
following categories: Category 1 (Purchased Goods and Services), Category 10 (Processing of Sold Products), and
Category 11 (Use of Sold Products) for hydrocarbon products. Calculations are based on traceable contractual
agreements and invoices, ensuring the accuracy and traceability of the data used for the preparation of the
Statement. [ESRS 2-BP-2-11-(a), (b)-(i), (ii)]
All indicators, measurement units, quantities, and data presented in the Statement comply with the most widely
recognized international practices, standards, and codes relevant to the oil and gas industry. No additional
restrictions, exceptions, or changes apply, unless explicitly stated in the text, except for modifications and
additions related to the application of the ESRS in the context of compliance with CSRD. [ESRS 2-BP-2-13-(a), (b), (c)]
No deviations were identified regarding the measurement methodologies compared to previous years.
Furthermore, no additional restrictions, exceptions, or modifications apply, unless explicitly stated in the
Statement.
During the review of emissions on water and solid waste quantities data for the year 2024, some entries were
identified in need to be updated (total organic carbon (TOC) for emissions on water due to incorrect entry and total
solid waste quantities due to the use of estimates) in the corresponding tables. The values for 2024 were revised
to reflect the correct percentage change compared to 2025. The above revisions did not affect any of the Group's
targets or policies. [ESRS 2-BP-2-14-(a), (b), (c)]
Beyond the requirements of the CSRD and ESRS, the principles of the GHG Protocol were also considered and
applied for the calculation and reporting of greenhouse gas emissions (Scope 1, Scope 2, and, where applicable,
Scope 3).[ESRS 2-BP-2-15]
The data points, for which quantitative measurements have been validated by an external body, are explicitly
indicated within the Statement. [ESRS 2 BP-2-77-(b)]

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Based on the above guidelines, the Group ensures the highest levels of transparency and accountability. The
application of the CSRD and ESRS standards enables a comprehensive presentation of the Group’s practices and
performance on sustainability matters. This approach, in addition to meeting regulatory requirements, reflects
HELLENiQ ENERGY Group’s commitment to responsible business conduct and sustainability.
Datapoints that derive from ESRS
In certain sections of the Statement, references related to other parts of the Annual Financial Report, such as the
Corporate Governance Statement or other available sources, have been incorporated to avoid repetition. Further
information is provided in the table of the section “IRO-2 – Disclosure Requirements in ESRS Covered by
HELLENiQ ENERGY’s Sustainability Statement”. [ESRS 2-BP-2-16]
The requirements of BP-2-17 are not applicable, as HELLENiQ ENERGY Group exceeds the average threshold of
750 employees as of the balance sheet date for the year 2025. [ESRS 2-BP-2-17]
HELLENiQ ENERGY Group applies international standards for Environment, Energy, and Health & Safety (ISO
14001, ISO 50001, and ISO 45001 certifications), while also setting targets and indicators related to energy and
climate change. Furthermore, it monitors environmental performance using European-recognized indicators, and
since 2020, its domestic operations have been certified under ISO 14064. The EKO fuel facilities and KALYPSO
fuel stations hold ISO 9001:2015 certification. The reliability of sustainability data is ensured through external
assurance in accordance with internationally recognized standards, as described in the “Audit Statement” of the
Sustainability Statement, in line with the CSRD and the ESRS. [ESRS 2-BP-2-AR 2]

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Governance
GOV-1 - The Role of Administrative, Management and Supervisory Bodies
The Board of Directors (BoD) of HELLENiQ ENERGY Holdings constitutes the highest governance body and
operates in accordance with Greek law, international best practices, the Articles of Association, and the resolutions
of the General Meeting (GM) of shareholders. The BoD is composed of 11 members, elected in accordance with
Article 20 of the Articles of Association. Its composition includes 9 (82%) men and 2 (18%) women, while 2 (18%)
members hold executive responsibilities and 9 (82%) are non-executive members, of whom 45% are classified as
independent. Full profiles of the BoD members are published on the Group’s official website and in the Annual
Financial Report.
Currently, the BoD does not include a specifically appointed member representing employees, nor is there a
formal mechanism for employee representation at the Board level. [ESRS 2-GOV-1-21-(a), (b), (c), (d), (e)]
The roles and responsibilities of the governance and supervisory bodies on sustainability matters are defined as
follows: the BoD and the Sustainability Committee have ultimate oversight and accountability for the Group’s
Sustainability Strategy. The Sustainability Committee monitors relevant trends and legislative developments,
evaluates the Group’s performance against ESG targets, related to identified material IROs, and reports to the
BoD. The Executive Committee, a member of which is the Group HSE & Sustainable Development Manager,
supports the development and implementation of the Sustainability Strategy and undertakes the executive
responsibilities assigned to it. This structure ensures effective monitoring and management of sustainability
impacts, risks, and opportunities, as well as progress toward achieving related targets. Progress is monitored
through regular reports, performance reviews, and KPIs, ensuring effective assessment and management of
related challenges and opportunities. [ESRS 2-GOV-1-22-(a), (b), (c)-(i), (ii), (iii), (d)]
The BoD invests in strengthening its oversight of sustainability matters by assessing members’ skills and
experience through targeted training programs. The experience and core competencies of its members in
sustainability issues, are presented in the table "BoD members’ experience and basic skills" of the chapter B.1.7 of
the Annual Financial Report. At the same time, the BoD continuously enhances its knowledge on sustainability
matters, including the identification of material impacts, risks and opportunities within the framework of DMA,
ensuring informed decision-making and the effective handling of related issues within the organization. [ESRS 2-
GOV-1-23-(a), (b)]
GOV-2 – Information Provided to and Sustainability Matters Addressed by HELLENiQ
ENERGY’s Administrative, Management and Supervisory Bodies
The responsibilities of the BoD and its Committees, including the Sustainability Committee, are defined in
HELLENiQ ENERGY’s Articles of Association and Committees' Operation Regulations. The Sustainability
Committee supports the BoD in reinforcing the Group’s long-term commitment to sustainable development and
oversees the implementation of the Sustainability Policy. The duties, responsibilities, and decision-making
process, including meeting frequency, are detailed in the BoD Sustainability Committee’s Operation Regulation.
During 2025, the Sustainability Committee met three times: on 24 February, 17 September, and 3 December. At
the first meeting, the 2024 Sustainability Statement was approved. At the second meeting, the 2nd edition of the
BoD Sustainability Committee Operation Regulation was approved and revised. The third meeting focused on the
preliminary validation of the Group’s DMA results for 2025.
The DMA was completed within 2025, and in February 2026, during a joint session of the Sustainability
Committee and the Audit Committee, the final results of the DMA and the 2025 Sustainability Statement were
validated, with approval by the BoD and in the presence of the CEO. These results are accompanied by
Management’s commitment to implementing effective policies based on leading international practices, in line
with the Sustainability Policy. [ESRS 2-GOV-2-26-(a)]
HELLENiQ ENERGY Group identified a total of 32 material IROs, which were categorized into 11 material
sustainability topics (covering 8 ESRS Sustainability Matters). Among these is Cybersecurity, which falls under the

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section ESRS G1 – Business Conduct. Further details are provided in section ESRS-2 IRO-1. [ESRS 2-GOV-2-26-(a)] [ESRS
2-GOV-2-26-(c)]
Taking into account the topics identified through the DMA, HELLENiQ ENERGY Group continuously seeks to
enhance its best practices across the ESG pillars, reaffirming its commitment to sustainable development.
Through its strategic planning, the Group enters new business activities, which require the immediate
identification and management of risks, as well as the design of a strategy that supports the achievement of
ambitious medium- and long-term business targets, leveraging appropriate investments and ensuring the
necessary resources.
The Strategy and Risk Management Committee is, among other responsibilities, in charge of approving the
corporate risk management framework and related policies and methodologies, defining the risk appetite and
tolerance levels, monitoring and approving the management of material corporate risks, and overseeing the
implementation of effective risk management measures. [ESRS 2-GOV-2-26-(b)]
GOV-3 - Integration of Sustainability-Related Performance in Incentive Schemes
The Group has established a Remuneration Policy, which clearly defines the framework and methodology for
allocating the remuneration of Board members, combining fixed and variable components based on their
objectives and position within the organizational structure. The policy is approved and revised by the General
Meeting (initial approval in 2019, with revisions in 2021 and 2024), is effective for four years, and includes
quantitative and qualitative performance indicators, as well as long-term incentive programs through the
distribution of free shares.
The Group’s targets are set annually and are aligned with the strategy of each Operational and Executive Unit and
the Group as a whole, with the possibility of adjustment according to changing circumstances. For the financial
year 2025, the targets included both quantitative and qualitative indicators in the areas of safety,
competitiveness, efficiency, profitability, financial performance, and progress on the energy transition plan.
Parameters related to climate performance are integrated into the remuneration of members of the
administrative, management, and supervisory bodies through variable compensation, which is based on KPIs.
These indicators include, among others, GHG emission reduction targets, safety indicators (LWIF and AIF),
financial benefits from the digital transformation program, investments in the Refining & Petrochemicals, the
Domestic Marketing Transformation Plan, and the expansion of RES projects portfolio. The percentages of
variable remuneration per objective dependent on sustainability-related targets are outlined in the latest
remuneration report of the Group. The award of shares is conditional upon the achievement of defined objectives
and KPIs, which are determined by the Board’s Remuneration & Succession Planning Committee. For the first
evaluation cycle (2024–2026), these include climate-related targets, which carry a weighting of 20%. [ESRS E1-
GOV-3-13]
In addition, a Long-Term Incentive Plan (LTIP) has been established, which was approved at the Annual General
Meeting on 27 June 2024. The plan aims to align a portion of executives’ variable compensation with the
Company’s medium- and long-term objectives and incorporates, among other criteria, sustainability-related
targets. The LTIP includes two evaluation cycles, each lasting three years, with a gradual allocation of shares per
evaluation cycle over a three-year period. The award of shares requires the achievement of defined targets and
KPIs, as determined by the Remuneration & Succession Planning Committee of the Board of Directors. For the
first evaluation cycle (2024–2026), the criteria include financial targets (60% weight), transformation targets
(20% weight), and ESG targets (20% weight). Further details are provided in chapter 5 of the 2024 Remuneration
Report. [ESRS 2-GOV-3-29-(a), (b), (c), (d), (e)]
GOV-4 - Statement on Due Diligence
The Group is highly committed to upholding human rights in accordance with relevant human rights and labor
legislation and standards (national, European, ILO). In alignment with this objective, the Group maintains a process
to identify, assess, and address actual or potential adverse human rights impacts that the Group may cause or
contribute to through its own activities, or which may be directly or indirectly linked to its operations, products, or
services by its business relationships.

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In 2025, the Group’s revised Code of Conduct entered into force. It forms part of the broader corporate
governance framework and summarizes the principles under which every individual involved in the operational
activities of the Group’s Companies and all its collective bodies must act and perform their duties. In this way, the
interests of the Group and its major shareholders are served, ensuring compliance with the law and with the
principles and standards of conduct governing the Group, without infringing upon the rights of third parties.
The Group’s human rights due diligence process is aligned with the six stages of due diligence, in accordance with
the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the Organisation for Economic
Co-operation and Development Guidelines for Multinational Enterprises (OECD MNEs), as illustrated in the
relevant diagram included in the European Union (EU) Taxonomy section of this Report. [ESRS 2-GOV-4-30]
Human Rights and Equal Opportunities For Employees And Partners
The due diligence process promotes human rights and equal opportunities for employees and partners. Relations
between employees and the Group are based on the principle of equal treatment. Employees are evaluated based
on their qualifications, performance and potential, without discrimination.
HELLENiQ ENERGY is in full compliance with the relevant labor legislation (national, European, ILO), as well as with
national bargaining agreements.
Employees of the Group may, without any restriction, participate in trade unions and professional associations.
The participation rate of all employees covered by collective bargaining agreements is 74%, and the average
participation rate of all employees participating in representative unions in EEA is 71%. There are seven (7)
representative employee unions in the Group companies, which co-sign respective Company Collective Bargaining
Agreements with the companies.
Corruption
During the reporting period, no incident of corruption was reported to the Regulatory Compliance Office, nor were
any related financial losses recorded. In 2025, Internal Audit continued to integrate corruption risks into its annual
audit plan, conducting four (4) audits with a focus on governance. All employees (100%) have been informed
about anti-corruption policies through the Code of Conduct and the Internal Labor Regulation. The Code, also
available as an e-learning module, includes practical examples and is supported by the Group’s commitment to
the principles of the United Nations Global Compact (UNGC). For business partners, equivalent clauses are
incorporated into contracts, ensuring full alignment with ethical standards.
Embedding Due Diligence Across Governance, Strategy, and Business Model - Engaging Affected
Stakeholders at Every Step of the Due Diligence Process
Although the Group does not yet have a formal due diligence policy in place, it has integrated relevant practices
into its governance framework, strategy, and business model. The Statement outlines the methodology for
identifying, assessing, and managing risks across the value chain, as well as collaboration with partners to ensure
alignment with responsible business practices. The assessment of positive and negative impacts was carried out
in cooperation with internal stakeholders, as well as sustainability experts and specialists.
Identifying, Assessing, and Remediating Negative Impacts
During the reporting period no material negative impacts have been identified through the due diligence process
and thus, no further actions to address any adverse impacts were necessary for the reporting period. Specifically,
there have been no irrevocable fines from the Labor Inspectorate for labor issues and disputes (except for two
individual cases of typical violations, which did not have a material impact on the Group's operational compliance),
nor any irrevocable environmental fines or non-monetary sanctions for non-compliance with laws and regulations.
HELLENiQ ENERGY Group has maintained full compliance with legislation on unfair competition and consumer
protection, with no major non-compliance or significant fines for violations related to the provision and use of
products and services or environmental laws and regulations. Finally, in 2025 no incident of discrimination was
reported in the Group companies. Operations and suppliers do not pose significant risk for incidents of forced or
compulsory labor, and measures to contribute to the elimination of all forms of forced or compulsory labor.
Despite the fact that this risk has not been rated as material, the Human Resources and Procurement Divisions

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monitor such phenomena and act accordingly in cooperation with representatives of trade unions and labor
councils.
All countries and regions in which the Group operates have national laws and regulations on forced labor. The
Group monitors relevant labor legislation (national, European, ILO) and is in full compliance with collective and
relevant international conventions.
In addition, a ‘clause of compliance’ of the Group’s suppliers with the principles of the UN Global Compact is
incorporated in contracts and purchase orders for materials and services.
Measures to prevent and identify adverse impacts include the Recruitment Policy, the Code of Conduct, training,
and Management feedback. The Recruitment Policy explicitly states that the employment of individuals under 18
years of age is not permitted. The Group applies a unified Code of Conduct that sets out the principles governing
its activities in Greece and abroad, including human rights matters, and commits its employees to upholding these
principles.
Employees receive training on human rights and related policies. Security personnel are trained in health and
safety matters, while all employees attend training sessions on the General Data Protection Regulation (GDPR),
the Code of Conduct, and ethical behavior. All security personnel (100%) provided by partner companies have
been certified by the Center for Security Studies) and the National Organization for the Certification of
Qualifications and Vocational Guidance, following prior training on human rights. Security training is conducted
with the participation of the private security company cooperating with the Group in Greece. Finally, any incident
related to human rights or corruption is reported to the competent Committee and the Board of Directors for
feedback and the implementation of corrective actions. [ESRS 2-GOV-4-30]
Due diligence is implemented in many ways and related disclosures can be found in the table below. [ESRS 2-
GOV-4-32] [ESRS 2-GOV-4-AR 10-(a), (b), (c), (d), (e)]

Core elements of Due Diligence | Paragraphs in the Sustainability Statement
Embedding due diligence in governance, strategy and business model | ESRS 2 GOV-2, GOV 3, SBM-3
Engaging with affected stakeholders in all key steps of the due diligence | ESRS 2 GOV-2, SBM-2, IRO-1
Identifying and assessing adverse impacts | ESRS 2 SBM-3, ESRS IRO-1, ESRS E1.IRO-1, ESRS E2.IRO-1, ESRS E3.IRO-1, ESRS E4.IRO-1, ESRS E5.IRO-1
Taking action to address to address those adverse impacts | ESRS E1-3, ESRS E2-2, ESRS E3-2, ESRS E4-3, ESRS E5-2, ESRS S1-4, ESRS S3-4, ESRS S4-4
Tracking the effectiveness of these efforts and communicating | ESRS 2 MDR-A

GOV-5 - Risk Management and Internal Controls over Sustainability Reporting
The internal control and risk management system of HELLENiQ ENERGY Group encompasses procedures and
mechanisms at all organizational levels, aiming at effective risk management and compliance with legislation,
including sustainability reporting. The Independent Internal Audit Division regularly assesses the adequacy and
effectiveness of the system and ensures the reliability of information provided to the BoD.
The Group implements a formal mechanism to integrate findings from risk assessments and sustainability
reporting audits into critical operations, maintaining the identified minimum risks under control. Key risks include
inconsistencies in data collection, limitations in the availability of value chain data, and overstatement of
sustainability achievements. To address these, standardized protocols, centralized information systems, clear
reporting timelines, as well as internal audits are applied.

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Sustainability Reporting Risks | Double Materiality Controls
1. Data Collection Inconsistencies | 1. Implementation of standardized data collection protocols and templates across all departments and locations and usage of centralized software systems to manage and consolidate sustainability data.
2. Availability & timing of upstream and/or downstream value chain data | 2. Establishing clear reporting timelines and maintaining strong communication with all value chain actors.
3. Misrepresentation or exaggeration of sustainability achievements, leading to stakeholder distrust. | 3. Conducting an audit at the level of general directors and by the Sustainability Committee and independent third-party limited assurance to the information included in the Sustainability Statement.

[ESRS 2-GOV-5-36-(a), (c)]
The oversight, monitoring of preparation, and approval of the annual Sustainability Statement—which is
incorporated into the Group’s Annual Financial Report—fall under the responsibility of the BoD’s Sustainability
Committee. The Committee also contributes to the identification and assessment of sustainability-related risks
associated with the Group’s operations, in collaboration with the Risk Monitoring and Management Division.
Through this collaboration, timely and effective identification, management, and integration of sustainability risks
into the overall risk management framework of the organization is ensured. [ESRS 2-GOV-5-36-(d), (e)]
The risk assessment approach for the Sustainability Statement follows the Group’s unified risk management
framework, ensuring consistent evaluation, prioritization, and management across all levels. The Risk Monitoring
and Management Division supports the Internal Control System through the establishment, implementation, and
updating of policies and procedures related to the identification, assessment, measurement, monitoring, and
control of risks. [ESRS 2-GOV-5-36-(b)]

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Strategy
SBM-1 - Strategy, Business Model and Value Chain
HELLENiQ ENERGY Group is a leading energy group in Southeastern Europe, operating in refining,
petrochemicals, fuel marketing, RES, electricity generation, natural gas, e-mobility, and hydrocarbon exploration
and production.
Refining: HELLENiQ ENERGY Group operates three of Greece’s four refineries, covering over 60% of the country’s
total refining capacity and holding a 60% market share in domestic petroleum products. The product portfolio
includes gasoline, diesel, jet fuels, liquefied petroleum gases (LPG), naphtha, and other derivatives. The refineries
have flexibility in processing intermediate products and adjust their operations in line with economic and
geopolitical developments. The Group is active in markets across Greece, the Western Mediterranean,
Southeastern Europe, North Africa, the Middle East, the Black Sea region, and East Asia. Additionally, HELLENiQ
ENERGY is committed to promoting innovation and sustainability through technologies aimed at reducing its
environmental footprint and producing cleaner fuels.
Petrochemicals: The Group holds a leading position in the production and marketing of polypropylene in Greece,
with a significant market share. Over 65% of sales are exported, primarily to countries in the Mediterranean
region. Its customer base includes major companies in the textiles, hygiene, solvents, paints, automotive, and
construction sectors.
Fuels Marketing: HELLENiQ ENERGY Group is a market leader in wholesale and retail fuel distribution in Greece,
with a network of 1,557 service stations in Greece at the end of 2025, and an additional 336 stations in
Southeastern Europe (Cyprus, Bulgaria, Serbia, Montenegro, the Republic of North Macedonia). The Group also
operates significant storage, distribution, and production facilities that strengthen its presence and
competitiveness in the region.
RES: HELLENiQ ENERGY Group manages a portfolio of 506 MW of operational renewable energy projects in
Greece, Cyprus, and the Republic of North Macedonia, while developing approximately 6 GW of new projects,
including investments in Romania and Bulgaria. The Group aims to reach 2 GW of capacity by 2030. In 2025,
electricity generation from renewable energy in Greece, Cyprus, and the Republic of North Macedonia totaled 778
GWh, helping to avoid over 255,000 tons of CO₂ emissions. [ESRS 2-SBM-1-40-(a)-(ii)]
Power and Gas: HELLENiQ ENERGY Group aims to establish a significant position in the Power and Gas business
by leveraging synergies with its refining, trading, renewable energy, and e-mobility activities. In line with its
strategic vision, the Group successfully completed the divestment of its 35% equity interest in DEPA Commercial
S.A. to the Hellenic Corporation of Assets and Participations (HCAP). Notably, with the completion of the
acquisition of 100% of Enerwave (formerly ELPEDISON), the Group strengthened its position in Power and Gas, as
Enerwave maintains a significant presence in this sector, operating 852 MW of gas-fired power generation units
and participating in both wholesale and retail electricity markets. Additionally, the Group acts as a major importer
and supplier of natural gas in Greece, with a focus on liquefied natural gas (LNG) imports, and provides
comprehensive energy efficiency solutions to a wide range of customers.
Electromobility: Through ElpeFuture, the Group is actively expanding its electric mobility services, developing
both charging infrastructure and advanced management platforms. In Greece, there are 160 fast chargers (320
charging points) located at EKO and bp service stations, as well as 544 charging points at shopping centers, public
spaces, and Group facilities.
At an international level, subsidiaries in Cyprus, Bulgaria, Serbia, and Montenegro have installed 45 chargers, 37 of
which are already operational, with 17 new installations completed in 2025 alone, demonstrating the rapid
expansion of the network.
Technical Studies: HELLENiQ ENERGY Group provides technical and consulting services in the energy sector
throughout Southeastern Europe through its subsidiary ASPROFOS, which adheres to international standards and
certifications.

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Exploration and production of hydrocarbons: HELLENiQ ENERGY Group is actively engaged in hydrocarbon
exploration and production in Greece, primarily through strategic partnerships with international companies. The
main areas of operation include offshore regions in Western and Southern Greece, including areas in the Ionian
Sea and to the west, southwest, and south of Crete. [ESRS 2-SBM-1-40-(a)-(i)]
Information on the total number of employees, by geographical region, is presented in the section “S1-6 –
Employee Characteristics” of this statement. [ESRS 2-SBM-1-40-(a)-(iii)]
There are no products or services banned in certain markets, as also described in the section “Sectors & Activities
of HELLENiQ ENERGY Group” of this statement. [ESRS 2-SBM-1-40-(a)-(iv)]

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Strategic Pillars
Strategic plan VISION 2025 was successfully implemented, confirming HELLENiQ ENERGY Group’s strategy for a
balanced energy transition. The Group strengthened and decarbonized its refining activities, expanded its
international downstream presence, and established a second growth pillar with a fully integrated Power platform
(RES, Power and Gas), while evolving its governance model.
This performance is significant in an environment of increased volatility and slower energy transition. Global
economic growth remains uneven, emphasizing the importance of energy security. Demand for liquid fuels and
natural gas in the Mediterranean remains strong, while the development of RES and e-mobility continues, with a
focus on sustainability and energy storage.
HELLENiQ ENERGY Group is updating its strategy for the next phase. VISION 2030+ focuses on the continuous
improvement of competitiveness in Downstream activities, expanding the presence in international markets, as
well as the transformation of the Power (RES, Power and Gas) business into an autonomous, vertically integrated
platform, while leveraging synergies at the Group level.
In the Hydrocarbons & Sustainable Fuels, our key strategic initiatives include: Pursue selective growth
investments, b) leverage the trading platform to optimize supply and capture market opportunities, c)
decarbonize operations through renewable energy deployment and carbon capture solutions, d) maintain
operational excellence across the existing asset base, e) explore Downstream growth opportunities in the
Southeast Europe, f) strengthen the Marketing footprint and expand the value proposition (premium fuels, EVs,
non-fuel retail), g) invest selectively in sustainable fuels to secure post-2030 positioning and develop options in
hydrogen and e-fuels, while h) maintaining exposure to potential upstream value creation through exploration
partnerships.
In the Power business, our key strategic initiatives include: Regionally expand, hybridize and technologically
diversify the renewables portfolio, b) invest in flexible generation assets and battery storage, c) grow and improve
performance of commercial business, d) further build-up project development and energy trading capabilities, all
while e) maximizing energy management synergies from our integrated generation portfolio. ESRS 2-SBM-1-40-(g)]
HELLENiQ ENERGY Group invests in a sustainable future by integrating ESG criteria into its strategy and capital
allocation, aiming to reduce its carbon footprint and achieve climate neutrality. The Group has incorporated the
United Nations Sustainable Development Goals (UNSDGs) into its strategy, implementing targeted policies and
social programs. For each ESG pillar, the Group sets short-, medium-, and long-term targets, which are monitored
and adjusted as necessary. Its core products and services — such as electricity generation from wind and
photovoltaic sources, fuel marketing, e-mobility, as well as the markets in which it operates — are aligned with
ESG targets and the Group’s strategic plan.
The plan includes the development of 2 GW of RES by 2030, expansion of energy storage solutions, development
of an extensive e-mobility network and related solutions in Greece and abroad, as well as growth in sustainable
fuels production and exploration of hydrogen, recycling, and synthetic fuel solutions.
These initiatives demonstrate the HELLENiQ ENERGY Group’s commitment to advancing progress toward a more
sustainable future, while creating value for customers and stakeholders. The table below presents the Group’s
targets and highlights the contribution of various business units to the defined ESG targets. [ESRS 2-SBM-1-40-(e), (f)]

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Sectors & Activities of HELLENiQ ENERGY Group

Activities | Revenue from contracts with customers ('000 €) in 2025 | Revenue from contracts with customers ('000 €) in 2024
Coal activities | — | —
Oil activities | 10,685,683 | 12,411,150
Gas activities | 172,958 | —
Taxonomy-aligned economic activities related to fossil gas | — | —
Fossil fuel activities | 10,858,641 | 12,411,150
Chemicals production | 284,116 | 300,496

The Group does not engage in controversial weapons (including anti-personnel mines, cluster munitions, chemical
or biological weapons), nor in the cultivation and production of tobacco; therefore, there are no related revenues.
[ESRS 2-SBM-1-40-(d)-(ii),(iii), (iv)]
Revenue derived from products or services aligned with the EU Taxonomy is presented in the section “EU
Taxonomy Report.” [ESRS 2-SBM-1-40-(d)-(i))]
It is noted that the European Commission has not adopted a Delegated Regulation defining the list of significant
or additional significant ESRS sectors. Therefore, no analysis of total revenue by significant ESRS sector is
provided.

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SBM-2 - Interests and Views of Stakeholders
Stakeholders are individuals or entities, directly or indirectly, that are materially affected by the Group’s activities
or may influence the implementation of its strategy and the achievement of its objectives. Continuous
engagement with them constitutes a key element of due diligence and the assessment of material impacts, risks,
and opportunities related to sustainability matters. Communication takes place throughout the year through
various channels, ensuring two-way dialogue that supports informed decision-making. Stakeholders are informed
through reports, questionnaires, meetings, and day-to-day interaction, while actively participating in targeted
discussions on sustainability-related issues.
HELLENiQ ENERGY Group's stakeholder groups as identified are presented below. [ESRS 2-SBM-2-45-(a)-(i), (ii)]
The table below presents the stakeholder categories within the Group, alongside the methods and frequency of
engagement for each category. It also highlights the most significant issues identified following the assessment
and prioritization of topics for each stakeholder category, which may constitute factors capable of influencing the
Group’s strategy and business model, where deemed necessary. Furthermore, the Group leverages the outcomes
of stakeholder engagement to identify and integrate material topics into the business decision-making process.
These findings are actively incorporated into the strategic decision-making process, ensuring that the Group’s
actions and policies respond to the needs and expectations of its stakeholders. Information on how the BoD is
informed about stakeholders’ views and interests regarding sustainability-related IROs is provided in subsection
D. Validation of Impacts, Risks and Opportunities (IROs).

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HELLENiQ ENERGY Group Stakeholder Category | Communication/participation methods | Communication Frequency
Employees | Dialogue, scheduled meetings, qualitative & quantitative surveys, webcasts /speeches, publications, newsletters. | Periodically
Intranet (internal information & communication network), corporate updates, events, information & awareness campaigns, employee suggestion box. | Daily
Business Customers | Dialogue, scheduled meetings, Q&A, contracts, events, focus groups. | Daily and periodically
Consumers | Satisfaction surveys, loyalty surveys, special surveys via questionnaires on the degree of acceptance of new products/services, focus groups. | Monthly, quarterly, annually and on a case-by-case basis
Customer helpline, dialogue, websites of marketing companies, social media, newsletters, portals, android & IOS apps. | Daily
Fuel Station Owners | Satisfaction surveys. | Monthly, quarterly
Training, evaluation of employee performance, dialogue, publications. | Weekly, Daily
Suppliers and Business Partners | Meetings, dialogue, answering questions, participation in procurement tenders, contracts. | Whenever appropriate
Review and entry supplier registry, new supplier on- boarding questionnaire. | Whenever appropriate
Shareholders and Investors | Roadshows, meetings. | Periodically
General meetings, presentation of results, publications (annual, biannual and quarterly reports, see corporate site Investor Relations). | Annually, bi-annually, quarterly
Society | Public debates, public opinion surveys, newsletters, synergies, see corporate site Sustainability. | Periodically
Dialogue, press publications / statements, see corporate site Media Center. | Daily
Local Communities | Public debates, public opinion surveys, newsletters, synergies, see corporate site Sustainability. | Periodically
Dialogue, press publications / statements, see corporate site Media Center. | Daily
State and Regulatory Authorities | Meetings, participations, consultations. | Periodically

[ESRS 2-SBM-2-45-(a)-(ii)-(iii)-(iv)-(v)]
These methodologies constitute an integral part of the Group’s strategy for a sustainable trajectory. The Group
ensures that its business model continuously responds to the requirements and views of its stakeholders,
reinforcing its commitment to sustainable development.
Risk prevention and management are central elements of the Group’s strategy. Risk identification and
assessment are conducted annually, particularly during the preparation of the strategic planning and annual
business plan. All impacts, as they arise, are evaluated both within the context of the Group’s operations and in
relation to the various stakeholders that may be affected.
Each year, the Group undertakes specific measures to review and improve its management systems, ensuring
alignment with stakeholder expectations and delivering high performance. These measures include close
monitoring of environmental responsibility and the implementation of best practices for the safe management of
products. To ensure consistent performance that promotes sustainability and stakeholder satisfaction, the Group
applies certified management systems in line with Quality, Health and Safety, Environmental, and Energy
standards across all production, storage, and distribution facilities.
During the DMA, feedback is collected directly from internal (such as employees) and external stakeholders (such
as business customers, consumers, service station owners, suppliers and business partners, shareholders and
investors, society, local communities, the state, and regulatory authorities) through discussions. The Group

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identifies what is material to each stakeholder category and adjusts its strategy accordingly. This approach helps
build trust, ensures that business activities remain responsible and sustainable, and creates value for both the
Group and its stakeholders.
To ensure that its business model remains relevant and responsive to stakeholder views across different
geographical areas, the Group has taken — and plans to take additional — measures to further enhance this
alignment. [ESRS 2-SBM-2-45 b, AR 16]
Additional steps in stakeholder engagement
HELLENiQ ENERGY Group applies best operational practices for the safe management of its products, with
particular emphasis on environmental protection, and ensures that its procedures reflect the needs and
expectations of its key stakeholders. For all its production, storage and handling facilities, HELLENiQ ENERGY
Group has a certified Quality, Occupational Health and Safety, Environmental and Energy Management System.
These management systems are specifically assessed and renewed on an annual basis to achieve a high level of
performance for stakeholders.
Risk prevention and management are central elements of the Group’s strategy. Risk identification and
assessment are carried out annually, primarily during the preparation phase of the strategic plan and the annual
business plan. During this process, the Group incorporates findings from its due diligence procedures and the
Double Materiality Assessment (DMA), in order to understand stakeholders’ views and interests and to adjust its
strategy and business model accordingly.
Through these additional steps, the HELLENiQ ENERGY Group aims to ensure that stakeholder engagement is
meaningful and effective, promoting sustainability and responsible business conduct. [ESRS 2-SBM-2-45-(b)]
HELLENiQ ENERGY Group has scheduled several new initiatives and projects for 2026, aiming to further advance
its transformation, enhance the employee experience, and strengthen service delivery to customers and partners.
In particular, the following actions are planned for 2026:
• Upgrade and further digitalization of consumer communication channel services through the e-EKO
program.
• Expansion of digital solutions across all Group activities (including RES and e-mobility).
• Broadening innovation in key Group processes through the utilization of new Artificial Intelligence (AI)
technologies to enhance collaboration, task automation, and efficiency.
• Development of strategic initiatives aimed at creating a new data management ecosystem that transforms
corporate performance management.
All identified impacts are subject to detailed assessment through structured risk management procedures and the
DMA, with the target of preventing, monitoring, and objectively evaluating consequences, including stakeholder
consultation and systematic performance indicator monitoring. At the same time, targeted mitigation measures
are implemented to limit negative impacts and promote positive outcomes. This approach ensures that the Group
identifies, manages, and transparently discloses potential impacts on people and the environment before they
adversely affect stakeholders.
The above initiatives are expected to contribute decisively to strengthening the Group’s relationship with all
stakeholders, significantly improving their satisfaction and reinforcing their trust. Furthermore, these initiatives
reflect a clear evolution of the Group’s strategy and business model, aligned with the modern needs and
expectations of employees, customers, and partners. [ESRS 2-SBM-2-45-(c)-(i), (ii), (iii)]
HELLENiQ ENERGY Group implements a structured process for informing the Sustainability Committee regarding
stakeholders’ views and interests. The Committee oversees stakeholder engagement and communication
strategies with the aim of understanding their interests, providing information on key issues, and supervising the
implementation of the Sustainability Policy. In addition, the Committee reports its findings and analyses to the

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Group’s senior management and supervisory bodies, thereby ensuring the integration of stakeholders’ views and
interests into the Group’s strategy, risk management framework, and business decision-making processes. [ESRS 2-
SBM-2-45-(d)]
SBM-3 - Material IRO and their Interaction with Strategy and Business Model
For the reporting period, HELLENiQ ENERGY Group, in line with its strategic plan, aligns its actions with ESRS
requirements. Through the integrated DMA process, the Group identifies the key IROs that affect its operational
activities and shape its long-term strategy. This approach ensures that the sustainability strategy is consistently
and reliably implemented, aligning it with the Group’s overarching vision for economic, social, and environmental
development.
The increased volatility of the contemporary energy environment and the slower pace of energy transition
compared to initial projections coexist with strong fundamentals in the Group’s core markets. Within this complex
and dynamic context, the Group’s strategy is designed with long-term sustainability and business model resilience
in mind, ensuring adaptability to constantly changing conditions, diversification of value sources, and sustained
creation of benefits for shareholders and stakeholders.
This strategy focuses on targeted development and the future strengthening of the Hydrocarbons portfolio, the
evolution of the Power business into an autonomous and fully integrated clean energy platform, and the
maintenance of strategic flexibility in Sustainable Fuels, while simultaneously leveraging synergies at the Group
level. In this way, ESG considerations are holistically embedded into strategic planning and decision-making,
enhancing the coherence, reliability, and scope of the Group’s Sustainability Strategy.
The Group directs its investments toward innovative and resilient business activities, emphasizing RES, energy
storage, e-mobility, and sustainable fuels, thereby enhancing the diversification of its energy portfolio and
mitigating exposure to long-term transitional and climate-related risks. The target is to develop 1.5 GW of
operational projects by 2028 and 2 GW by 2030.
The development of RES, combined with the expansion of electric vehicle charging infrastructure, fully aligns with
the Group’s strategy to reduce its carbon footprint, address climate change, and strengthen energy security.
Onshore wind and solar projects contribute significantly to achieving ESG objectives, supporting the increase of
installed RES capacity and avoiding CO₂ emissions by 20%, while ensuring reliable energy supply in areas with
limited network expansion capacity. At the same time, EV charging infrastructure facilitates the transition to
sustainable transport and a low-carbon economy.
Overall, these initiatives demonstrate the resilience and long-term sustainability of the Group’s business model,
enabling effective risk management, mitigation of impacts, and the capture of new opportunities in an ever-
evolving energy environment. [ESRS 2-SBM-3-48-(f)]
A total of 152 IROs were identified and thoroughly assessed within the DMA. Specifically, regarding Impact
Materiality, 75 impacts were evaluated, of which 20 were considered material. Regarding Financial Materiality, 77
risks and opportunities were assessed, of which 12 were deemed material. All of these IROs are directly covered by
the ESRS Disclosure Requirements, with the exception of one entity-specific topic (Cybersecurity), which is
addressed through additional entity-specific disclosures. The following section provides a comprehensive
description of the material IROs identified for HELLENiQ ENERGY Group through the DMA.
The material IROs are detailed in the table «Material Impacts, Risks, and Opportunities (IROs) by Time Horizon and
Value Chain Level». Specifically, the table below presents the distribution of material IROs along the value chain, as
well as their current and expected impacts on the business model, value chain, strategy, and decision-making
processes. Additionally, the trend of materiality over the time horizon is highlighted. Based on the Group’s current
strategic planning, prevailing market expectations, and existing insurance coverage, no significant changes in the
carrying amounts of assets and liabilities are expected in the upcoming reporting period. Further information on
the materiality trend over future time horizons is provided for each material topic in the table «Material Impacts,
Risks, and Opportunities (IROs) by Time Horizon and Value Chain Level» in the chapter «Material impacts, risks and
opportunities and their interaction with strategy and business model» [ESRS 2-SBM-3-48-(a)] [ESRS 2-SBM-3-48-(c)-(iii),(e)]
11 Commission Delegated Regulation (EU) 2025/1416 of 11 July 2025 amending the ESRS.

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HELLENiQ ENERGY Group has made use of the phase-in reliefs provided under the ESRS Quick Fix Delegated
Act 11, applying the gradually introduced disclosure requirements as outlined in Annex C of ESRS 1. Consequently,
for the current reporting period, the Group submits only qualitative disclosures regarding the expected financial
effects of IROs related to the material topics, to the extent permitted by the transitional provisions. This period
represents the second year in which the Group implements the ESRS standards. [ESRS 2-SBM-3-48-(e)]
The materiality of IROs is directly linked to the nature of the Group’s business activities. Specifically, impacts from
operations include electricity generation, fuel trading, the development of renewable energy projects, and e-
mobility operations, while impacts from business relationships relate to the Group’s suppliers of raw materials,
customers, subsidiaries, and partners. This encompasses the procurement and use of raw materials, energy
consumption, greenhouse gas emissions, and health and safety practices throughout the value chain.
This relationship emphasizes sustainability considerations across the value chain, thereby influencing the
sustainability of the business model. It also necessitates strategic adaptation and requires a meticulous approach
across multiple dimensions, including addressing operational challenges, improving day-to-day operations,
restructuring corporate governance, and enhancing risk management.
The outcomes of the DMA have confirmed the need to advance and accelerate the energy transition, as outlined
in the strategic plan, in order to capitalize on opportunities and address challenges. The section ‘Double Materiality
Assessment Methodology per Topical Standard’ below presents the key negative and positive impacts likely to
affect people and the environment, while information on time horizons is provided in the section “BP-2 –
Disclosures in relation to specific circumstances” above. [ESRS 2-SBM-3-48-(c) (i), (ii), iv), (d)]
The Group has restructured its corporate framework to facilitate the implementation of the strategic plan,
optimize risk management, and ensure financing that is appropriately aligned with the nature of each project.
Following a series of refinancing activities, the Group has successfully enhanced its debt structure and financing
profile, thereby extending the average maturity of its long-term debt. At the same time, it is leveraging the
existing financing framework (project finance agreement of up to €766 million) to support investments in the
renewable energy sector. Based on the Group’s current strategic planning, prevailing market expectations, and
existing insurance coverage, no significant adjustments to the carrying amounts of assets and liabilities reported
in the relevant financial statements are expected in the upcoming annual reporting period.
Compared to the previous reporting period, the IROs identified through the DMA have been updated as a result of
the integration of new data, the revision of the methodology, and the broadening of stakeholder engagement.
These updates ensure that the DMA accurately reflects the Group’s current risk profile and strategic priorities. In
this year’s DMA, compared to that of 2024, the following topics and subtopics have been newly identified as
material: from ESRS E3, the sustainability mater “Water”; from ESRS G1, the sustainability mater “Corporate
Culture” and the entity-specific mater “Cybersecurity”; and from ESRS S1, the sustainability mater “Equal
treatment and opportunities for all". All other material maters from the 2024 DMA remained the same. [ESRS 2-
SBM-3-48-(g)]

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Material IROs per time horizon and value chain level
(ESRS ESRS 2-SBM-3-48-(h))

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Impact, Risk and Opportunity Management
Disclosures on the Double Materiality Assessment Process
IRO-1 - Description of the Processes to Identify and Assess Material IROs
Double materiality assessment process methodology
HELLENiQ ENERGY Group continues this year to conduct the DMA, which serves as a key tool for identifying and
prioritizing sustainability priorities. The Group applies an impact assessment process that enhances continuous
monitoring of the environmental and social impacts of its activities, as well as ongoing communication with
stakeholders. The DMA includes the evaluation of the Group’s sustainability impacts from two distinct
perspectives:
• Impact materiality, which considers the sustainability impacts of HELLENiQ ENERGY’s activities on
environment and on people.
• Financial materiality, which addresses how sustainability issues affect the Group’s value creation and
financial performance.
The DMA is aligned with the ESRS and the Global Reporting Initiative framework (GRI 2021), ensuring that the
Group manages its material impacts along its value chain in a timely and effective manner. In addition, the Group
has established a clear risk management process, incorporating ESG issues into the general Risk Register to
ensure that potential threats are identified and addressed in a timely manner.
This methodology supports HELLENiQ ENERGY's strategic transition to a sustainable and resilient business
model, meeting the growing expectations of stakeholders and ensuring compliance with ESRS. The methodology
includes the following stages: [ESRS 2-IRO-1-53-(a)]
Α. Stakeholder and value chain mapping
Α.1. Stakeholder mapping
The Group has developed a dynamic stakeholder classification framework, which includes key communication
channels and priorities per group, taking into account economic factors, sustainability issues, and relevant risks
per activity, business relationship, and geographic area. As described in more detail in the section "SBM-2 -
Interests and views of stakeholders".
Through collaboration with internal and external stakeholders, targeted information and feedback were collected
on the management of important sustainability issues. [ESRS 2-IRO-1-53-(b)-(iii)]
Α.2. Value chain mapping
In addition, HELLENiQ ENERGY conducted a detailed assessment of the value chain with the aim of diagnosing
the distribution and concentration of IROs in the upstream, midstream, and downstream segments, enabling a
more targeted and meaningful understanding of the risks, impacts, and opportunities at each stage of the activity.
The above procedures ensure that emphasis is placed on high-risk activities, relationships, and areas, covering
both the direct impacts of the Group's operations and the impacts arising from its business relationships. [ESRS 2-
IRO-1-53-(b)-(i)]
Β. Crafting the impacts, risks and opportunities (IROs) inventory
In 2025, the DMA focused again on assessing the IROs arising both from the Group’s business activities and from
its relationships with partners and suppliers across the value chain. The process of compiling the list was based on
benchmarking analysis with peer companies, review of the previous DMA, assessment of climate-related risks
through scenario analysis, and the integration of findings from the FY2025 risk assessment. Further information

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regarding the results of the climate risk and opportunity analysis is provided in the section “ESRS 2 IRO-1 –
Description of the Processes to Identify and Assess Material Climate-Related IROs”.
Based on these steps and the specialized expertise of HELLENiQ ENERGY Group, a long list of IROs was created.
From this long list, a short list was developed, focusing on the most critical topics for the Group and its partners,
also taking into account feedback from the Employee Suggestion Box and the due diligence process.
Subsequently, 13 focus groups with external experts, selected based on experience and specialization, evaluated
the list to identify any gaps or new proposals and to support the prioritization of the IROs. [ESRS 2-IRO-1-53-(b)-(ii)]
C. Scoring Impacts, Risks, and Opportunities (IROs)
C.1 Impact Materiality – "Inside-out" Approach
The next step, Impact Materiality – “Inside-out” –, concerns the approach through which the positive and negative
impacts of the Group’s activities and business relationships were assessed, with emphasis on their effect on
people, the environment, and the economy. For this purpose, the business model was taken into account, along
with international standards (GRI, TNFD, UNEP Impact Radar) and interviews with internal and external
stakeholders. Initially, 207 impacts (long list) were examined and grouped into 75 (short list), of which 20 were
deemed material for the current reporting period across three time horizons: 2026, 2027–2030, and 2031–2036,
as well as along the value chain. The assessment was conducted using the following criteria: scale, scope,
likelihood (for potential impacts only), and irremediability (for negative impacts only). The materiality threshold for
each impact was based on the calibration of relative severity and comparability of the impacts across thematic

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areas and time horizons, while the evaluation of each impact was carried out separately for the current period and
individually for the short-, medium-, and long-term horizons, under the assumption that an impact is considered
material overall if it exceeds the threshold in any time horizon, thereby ensuring a comprehensive and proactive
approach to managing sustainability impacts. [ESRS 2-IRO-1-53-(b-(iv))]
C.2 Financial Materiality – "Outside-in" Approach
Subsequently, the Group proceeded with Financial Materiality – “Outside-in” – approach, leveraging the results of
the Impact Materiality assessment, but not limited to them, aiming to identify and assess the opportunities and
risks related to sustainable development arising from the Group’s impacts on people and the environment. The
Group also conducted a detailed analysis of its dependencies on natural, human, and social resources, as well as
other factors that create risks and opportunities related to sustainable development, covering a broader spectrum
beyond mere impacts and dependencies. Furthermore, governance-related factors and other elements that could
create risks or opportunities at the level of financial materiality were assessed.
Initially, 425 risks and opportunities (long list) were examined, grouped into 77 (short list), and evaluated based on
the magnitude of their financial impact, whether positive or negative, and the likelihood of occurrence across
short-, medium-, and long-term horizons. Through this evaluation process, 12 material risks and opportunities
were identified that have, or are expected to have, significant financial implications for the Group for the current
reporting period (2025) or for their anticipated financial impact across the three time horizons (2026, 2027–
2030, 2031–2036).
It is worth noting the approach applied to determine the financial materiality threshold. This threshold, above
which a financial impact is considered material for each time horizon, was established taking into account both the
medium-term profitability, reflecting direct financial performance, and the medium-term value of net operating
assets on the balance sheet, thereby providing insight into long-term financial health and stability. The
classification of risks and opportunities as "material" was determined by combining (multiplying) two separate
score estimates for Likelihood and Magnitude, with the provision that Likelihood is only considered for risks and
opportunities (ROs) whose Magnitude of impact is estimated as material. The materiality of each risk or
opportunity was assessed separately for the current reporting period and for each time horizon, i.e., short-,
medium-, and long-term, to ensure that financial impacts are evaluated over time. Furthermore, it was assumed
that if a risk or opportunity is deemed material in even one time horizon, it is considered material overall. In this
way, a comprehensive assessment of the financial impacts associated with the Group’s sustainability factors is
ensured. [ESRS 2-IRO-1-53-(c)-(i)]
The overall assessment of impacts, risks, and opportunities was conducted in accordance with the guidelines set
out in the CSRD and the principles of ESRS 1 and ESRS 2.
It should be emphasized that an internal consultation regarding the materiality of the IROs was undertaken. This
process included the active participation of specialized personnel from the Supply & Trading, Renewables,
Refining, Fuels Marketing, and various other Business Divisions and Support Functions. These individuals possess
substantial expertise in disciplines such as climate, supply chain management, energy, health and safety, among
other relevant areas, which proved instrumental in shaping the final outcomes of the Double Materiality
Assessment (DMA). The prioritization of material IROs was determined by their respective final scores, evaluated
within the context of the Group’s comprehensive risk assessment framework. This approach facilitated the
consistent prioritization of sustainability-related risks in alignment with other strategic and financial risks. Within
this framework, the material IROs identified by HELLENiQ ENERGY Group highlight their critical importance to the
Group’s operational activities and to its long-term strategy concerning social, economic, and environmental
sustainability. [ESRS 2-IRO-1-53-(c)-(ii), (iii)]
D. Validation of Impacts, Risks, and Opportunities (IROs)
The DMA is overseen by the Health, Safety, Environment & Sustainable Development Division of the Group and is
conducted in collaboration with the Group’s Investor Relations Division for financial materiality, as well as with the
Risk Management Division for the integration of the approach and results of the risk analysis, with significant
contributions from special assessment teams (SATs) in their respective areas of responsibility.

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During the alignment process with the Risk Management Division, any new data and findings arising from the
Group’s FY2025 Risk Assessment were also incorporated into the DMA. After the close of the financial year, all
identified financial impacts were integrated into the DMA results to ensure an accurate reflection of Financial
Materiality.
The DMA process was repeated throughout 2025, both due to the acquisition of Enerwave and as a result of new
data from the comparative benchmarking study conducted. It is worth noting that the DMA methodology was
updated compared to the previous reporting period to better support the Group in identifying impacts, risks, and
opportunities. The validation of the final material topics was carried out in four (4) stages:
• Presentation of the DMA results to the Committee for discussion, validation, and final approval
• Integration of the final results from the Group’s broader, updated risk assessment exercise.
• Updating and refinement of the DMA results based on the Group’s financial results for FY2025 and the
updated business plan.
• Final validation of the DMA results and the Sustainability Statement in a joint session of the Sustainability
Committee and the Audit Committee, with Board approval and in the presence of the CEO.
The DMA is scheduled for review in the next reporting period (FY2026) to incorporate any further updates and
improvements, ensuring continuous alignment of IROs with the Group’s strategy. [ESRS 2-IRO-1-53-(c), (d), (h)]
Internal Controls of DMA
The DMA process is an integral part of HELLENiQ ENERGY Group’s Integrated Risk Management approach, which
includes policies, procedures, and evaluation tools for identifying, evaluating, and managing IROs. Within the
framework of conducting the DMA process, the following risks were identified along with their respective controls:

Double Materiality Assessment Process Risks | Inherent Controls
1. Careless identification of IROs | The SATs validate the wording and the terminology
2. Overambitious/unbalanced IROs scoring | The SATs validate the IROs scoring
3. Improper risk assessment by the internal stakeholders | The Group Internal Audit division and the Risk Management division possess a thorough understanding of sustainability- related material risks and carries out validation
4. Improper opportunity assessment by the internal stakeholders | The SATs maintain a comprehensive overview of sustainability-related material opportunities and perform validation.
5. Misalignment of material topics with the business strategy | The C-level management team validates the topics while maintaining an overarching view of the broader strategic objectives.

To address these potential risks, in addition to internal controls, the Group has prioritized specialized training
programs, enhanced communication, and continuous collaboration with stakeholders. The responsible executives
of the Management Teams have upgraded the assessment procedures, providing their input and ensuring that
the most modern and effective practices are followed. [ESRS 2-IRO-1-53-(c)-(iii)]
Governance of Double Materiality Assessment
The working group of HELLENiQ ENERGY, consisting of specialized executives from the Investor Relations,
Health, Safety, Environment & Sustainable Development, and Risk Monitoring and Management Departments,
was responsible for reviewing the terminology and formulation of each IRO to ensure compliance with the Group's
sustainable development strategy and external standards.
Among other things, this working group:
• Verified that the descriptions accurately reflected the nature and scope of each IRO.
• Ensured that all IROs were clearly defined and communicated to the BoD without ambiguity.

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• Confirmed that all risks were correctly classified and aligned with the Group’s risk register.
• Reviewed any significant IROs arising from the DMA that should be incorporated into the overall risk
management process and assessed their overall risk profile. In short, IROs identified as significant through
the DMA were included in the full set of potential risks that could affect the continuity of the Group’s
business operations. Risks were categorized based on their origin, such as market factors or regulatory
drivers. Risk Management specialists evaluated the likelihood of each risk, its impact, and recorded them in
the risk register alongside other risks. Based on the assessment results, all risks were prioritized according to
the Group’s risk appetite. As noted above, the IROs are aligned with the Group’s strategic objectives and
operational ambitions. [ESRS 2-IRO-1-53- (b), (d), (e), (f)]
Input Parameters
In designing the Group’s DMA process across all stages of the value chain, both the Impact Materiality and
Financial Materiality approaches, as well as their interactions, were taken into account. The participation and
insights of the various stakeholder groups were considered particularly important for this process.
To facilitate understanding, the inputs arising from stakeholder participation are presented in the sections
“SBM-2 – Interests and views of stakeholders”: “Additional Steps in Stakeholder Engagement,” and “DMA
Methodology per Topical Standard”. [ESRS 2-IRO-1-53- (b)-(iii)] [ESRS 2-IRO-1-53- (g)]
DMA Methodology per Topical Standard
ESRS 2 IRO-1 - Description of the Processes to Identify and Assess Material Climate-
Related IROs
Identifying and Assessing Climate Impacts
Regarding the topic of Climate Change (ESRS E1), the same general methodology described in the section “Β.
Crafting the impacts, risks and opportunities (IROs) inventory” was applied; however, particular emphasis was
placed on the Climate Risk Assessment stage, namely the incorporation of the identification of climate-related
risks and opportunities in line with ESRS requirements and certain parameters of the EU Emissions Trading
System (EU ETS). This combined approach enabled a more structured and comprehensive assessment of climate-
related risks and opportunities. By reviewing the results of the DMA process, which were also aligned with the
ESRS standards, the Group identified the material impacts associated with climate risks and opportunities.
By analyzing the results of the DMA, which were also aligned with the ESRS Standards, the Group identified the
significant impacts associated with climate-related risks and opportunities. Within the scope of this exercise,
physical risks (acute and chronic) as well as transition risks related to climate change were identified, assessed,
and incorporated into the DMA, while the consideration of global best practices further enhanced the consistency
and transparency of the methodology.
Notably, climate change affects stakeholders across the entire value chain. Upstream activities are primarily
impacted by carbon dioxide emissions arising from raw material procurement. Downstream activities are affected
by fuel consumption, which is also dependent on end consumers. Moreover, climate change is directly linked to
the Group’s core operations, including emissions from industrial production processes and intra-group
transportation. More information regarding the integration of stakeholder consultations can be found in the
chapter “SBM-2 – Interests and views of stakeholders”.
HELLENiQ ENERGY Group conducts an annual assessment of its activities along the value chain to identify actual
and potential sources of GHG emissions, covering direct emissions from fuel consumption (Scope 1), indirect
emissions from purchased electricity and heat (Scope 2), as well as indirect emissions across 15 categories within
the value chain (Scope 3).
Within the framework of the DMA, the Group evaluated its activities to identify actual and potential sources of
GHG emissions across the entire value chain. This analysis informed the assessment of the Group’s impacts on

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climate change in accordance with ESRS E1-6 and ensured alignment between the Climate Risk Assessment and
the results of the DMA.
Finally, the Group calculates GHG emissions by collecting data from various activities and applying emission
factors relevant to the industry and the geographic locations of its facilities. [ESRS E1.IRO-1 ,20 a, AR 9, AR 10]
Use of Climate-Related Scenario Analysis
HELLENiQ ENERGY Group conducted climate scenario analysis for the second consecutive year across all its
activities. Through modeling different future climate scenarios, the Group assessed physical and transition risks
over short-, medium-, and long-term time horizons, as presented below:
• Short-term time horizon: 2026
• Medium-term time horizon: 2027 - 2030
• Long-term time horizon: 2031 - 2050
[ESRS E1.IRO-1, AR 11 (b), AR 13-AR 14]
Specifically, the Group conducted climate scenario analysis focused on the development of two scenarios,
examining how climate change may have already affected its operations or could impact them in the future, as
well as how it could challenge “business-as-usual” assumptions. The scenarios used cover potential risks and
uncertainties, including the Net Zero Transition and High Emissions scenarios. This approach enables the Group to
model the combined impact of climate-related risks. The two scenarios selected and applied in the analysis align
with current regulatory requirements and best practices, as follows:
Net Zero Transition Scenario: This scenario reflects global decarbonization efforts aimed at achieving the goals of
the Paris Agreement. It outlines pathways toward net-zero emissions, consistent with the long-term objective of
limiting the rise in global average temperature to well below 2°C, and, where possible, close to 1.5°C above pre-
industrial levels. Within this context, 2050 serves as a key milestone for achieving global net zero, while the
temperature limits refer to the overall trajectory and stabilization of warming throughout the 21st century. For the
assessment of transition risks (e.g., policies, carbon prices, technology), the NGFS Net Zero 2050, NGFS Low
Demand, and IEA Net Zero Emissions by 2050 (NZE2050) scenarios were used as references. For the evaluation of
physical risks under low-emission conditions, the IPCC SSP1-2.6 climate scenario was applied (~1.7°C by mid-
century, 2041–2060, as a proxy for 2050; ~1.8°C by 2100, 2081–2100). Under this scenario, emission reductions in
the energy sector, which includes HELLENiQ ENERGY, may result from a combination of regulatory and policy
developments, technological advancements, shifts in demand and markets toward lower-carbon solutions, and
the availability of financing and investment.
High Emissions Scenario: This scenario represents a world of very limited climate action and high emissions,
where emissions continue to rise and physical climate risks intensify. The “High Emissions” scenario was used
exclusively for the assessment of physical risks, based on the IPCC SSP5-8.5 climate scenario, which corresponds
to significantly higher future warming and, consequently, to a greater frequency/intensity of extreme events and
worsening chronic trends. Indicatively, the increase in global average temperature is estimated at approximately
~2.4°C by mid-century (2041–2060, as a proxy for 2050) and ~4.4°C by 2100 (2081–2100).
Methodology and Data Sources: The assumptions underlying these scenarios are based on projections from the
Intergovernmental Panel on Climate Change (IPCC), the Network for Greening the Financial System (NGFS), and
the International Energy Agency (IEA), and are aligned with the latest scientific knowledge. In addition, data from
platforms and initiatives such as Copernicus, Aqueduct, and ISIMIP, as well as other sources, were used to analyze
climate data projections and model the impact of risks on the locations of HELLENiQ ENERGY’s assets under
different climate scenarios. The 2025 assessment incorporates advanced global and regional climate datasets
(CMIP6, EURO-CORDEX, ERA5 / ERA5-Land, ISIMIP, AR6 projections, and national datasets from the Ministry of
Environment and Energy). All indicators were harmonized to a common spatial resolution of approximately 10–
12.5 km, allowing consistent characterization of risks at the asset level across all risks, scenarios, and time
horizons. [ESRS E1.IRO-1, 21, AR 13-AR 14] [ESRS E1.IRO-1, AR 11-(d)]

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Key forces and drivers taken into consideration in each scenario
| Net Zero Transition Scenario | High Emissions Scenario
Policy | Governments globally implement aggressive climate policies, including high carbon prices. Immediate global decarbonization efforts and strong policy coordination | Minimal or ineffective climate policy action globally, with minimal or no carbon pricing implemented
Technology | Rapid advancements in renewable energy technologies deployment and energy efficiency improvements, incl. storage | Technological advancements primarily focused on enhancing fossil fuel extraction and consumption efficiency
Energy Consumption | Global energy consumption growth slows down | Global energy consumption sees significant increases
Energy Mix | A substantial increase in the share of renewable energy sources (solar, wind, hydro) and a decrease in fossil fuel dependency | The global energy mix is dominated by fossil fuels
Energy Prices | The cost of renewable energy technologies continues to decline, fossil fuel prices may increase | Fossil fuel prices remain competitive, renewable energy costs do not decrease significantly
Environment | Reduced greenhouse gas emissions leading to decreased environmental degradation and a slowdown in climate change impacts, such as extreme weather events | Continued high levels of greenhouse gas emissions lead to severe environmental impacts, including drastic increases in average global temperatures, more frequent and intense extreme weather events
Economy | Initial economic costs incurred due to the transition, long-term economic benefits from green job creation, reduced health costs from pollution, and improved energy security. | Rapid economic growth increasingly hindered by the adverse impacts of climate change, such as damage from extreme weather, resource scarcity, and escalating costs from climate-related disruptions

Through climate scenario analysis, HELLENiQ ENERGY Group assessed the exposure of its assets and operations
to climate-related risks, and identified, prioritized, and evaluated the corresponding opportunities.
Identification of climate related risks and opportunities
In 2025, HELLENiQ ENERGY Group identified and assessed potential physical and transition risks, as well as the
opportunities that may arise from them, to ensure that its approach remains up-to-date and aligned with ongoing
developments.
During the climate risk and opportunity assessment exercise, HELLENiQ ENERGY examined its operations and
transformation plan to identify actual and future sources of greenhouse gas emissions, as well as factors that may
give rise to physical or transition risks and climate-related opportunities, both within its own operations and along
the value chain. As presented in the table “Significant Impacts, Risks, and Opportunities (IROs) by Time Horizon
and Value Chain Level,” the impacts of climate change are primarily concentrated in the Group’s intermediate
value chain. Accordingly, greater emphasis was placed on identifying assets that may be more exposed to climate-
related risks, as well as the corresponding opportunities. [ESRS E1.IRO-1, 20-(b), (c), AR 13-AR 14]
Benchmarking analysis was conducted to identify these risks in comparison with the industry and competitors,
while the Group’s assets and business activities were evaluated regarding their potential exposure to these risks.
HELLENiQ ENERGY categorizes physical risks into acute and chronic:
• Acute physical risks arise from short-term, extreme weather events or natural disasters. These risks may
cause immediate and significant damage to assets, infrastructure, and operations, leading to financial losses
and operational disruptions.
• Chronic physical risks are associated with long-term and gradual changes in climatic conditions over time.
These risks can significantly impact asset performance, operational efficiency, and long-term financial
sustainability.
HELLENiQ ENERGY categorizes transition risk and opportunities as follows:
• Policy and Legal Risks – Changes in regulations, carbon pricing, and compliance costs.

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• Technology Risks – Disruptions due to the emergence of new low-carbon technologies.
• Market Risks – Shifts in supply and demand driven by changing consumer preferences and investor
expectations.
• Reputation Risks – Negative public perception or stakeholder concerns regarding climate practices.
HELLENiQ ENERGY Group compiled a list of climate-related risks, including both physical and transition risks. This
list was validated to identify the most significant risks, resulting in the development of a register of material risks
for further assessment.
Assessment of climate related risks and opportunities
Once identified, climate-related physical and transition risks, as well as opportunities, were assessed across short-,
medium-, and long-term time horizons under two climate scenarios during collaborative sessions with internal
stakeholders. A unified scale was applied for the evaluation of all risks and opportunities, ensuring consistency and
enabling direct comparison between them.
To ensure a comprehensive assessment of physical risks that could affect assets, HELLENiQ ENERGY
incorporates vulnerability estimates with exposure analysis, based on climate data projections. Using geospatial
coordinates and scenario modeling, the Group evaluates the exposure of its operations, activities, and assets to
climate-related risks. This approach enables data-driven analysis of potential physical risks, supporting a robust
risk mitigation strategy.
During geospatial analysis and location-level risk assessment, HELLENiQ ENERGY Group applies the EU NUTS
classification (Nomenclature of Territorial Units for Statistics) at level 2 or 3. This methodology enhances
comparability and consistency in risk reporting while supporting compliance with EU regulatory standards.
The exposure analysis examined 545 assets, whose disruption from climate-related risks could impact
infrastructure, transportation, energy efficiency, and productivity, posing a significant risk to the business. These
assets include refineries, crude oil terminals, plastic packaging materials, lubricant production and distribution,
LPG warehouses, fuel terminals, solar parks (PV), wind farms (WF), EV chargers, and rooftop solar panels at fuel
stations, as they carry higher exposure risk due to their direct financial and operational responsibilities.
Climate-related physical hazards:

Risk Identified | Risk Type | Scenario Used | Climate Hazard | Risk assessment results
Short-term (FY2026) | Medium-term (FY2027-FY2030) | Long-term (FY2031-FY2050)
SSP5-8.5 | SSP1-2.6 | SSP5-8.5 | SSP1-2.6 | SSP5-8.5 | SSP1-2.6
Adverse weather events | Acute physical | SSP5-8.5 (High Emissions scenario) SSP1-2.6 (Zero Emissions Scenario) | Heat wave | High | High | High
Wildfire | High | High | High
High winds | Medium | Medium | Medium
Coastal flood | Low | Low | Low
River flood | Medium | Medium | Medium
Pluvial flood | Low | Low | Low
Snow | Low | Low | Low
Long-term changes in climate | Chronic Physical | SSP5-8.5 (High Emissions scenario) SSP1-2.6 (Zero Emissions Scenario) | Sea level rise | Low | Low | Medium
Changing temperatures | Low | Low | Medium
Changing wind patterns | Medium | Medium | Medium
Water stress | High | High | High

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Detailed description of physical risks
Extreme weather events
Extreme weather events, such as wildfires, floods, heatwaves, snow, and high winds, may result in:
• Damage to electricity and natural gas infrastructure, including production facilities, substations, pipelines,
and transmission/distribution networks, leading to power outages and supply disruptions.
• Disruption of transportation routes, affecting the supply chain and employee mobility.
• Reduced efficiency of renewable energy sources, such as photovoltaic systems (thermal degradation, dust
accumulation) and wind turbines (changes in wind patterns), as well as natural gas units, resulting in lower
energy production.
• Increased operational costs due to higher cooling demands for energy infrastructure.
• Limited capacity of employees to work due to heat stress.
Long-term changes in climate
• Rising sea levels may cause coastal erosion, threatening infrastructure such as refineries, pipelines, and
renewable energy installations located near the coast.
• Higher average temperatures can reduce the efficiency of solar panels due to thermal degradation and alter
wind patterns, leading to decreased wind energy production. Additionally, elevated temperatures increase
operational costs due to higher cooling requirements for energy infrastructure. Long-term exposure to high
temperatures can also affect employee productivity and health due to heat stress.
• Water scarcity can significantly increase operational costs, as water is essential for refining processes. In
areas of high water stress or seasonal fluctuations, challenges may arise that may require adjustments to
production planning. Timely monitoring and implementation of water conservation and recycling measures
help ensure uninterrupted operation.
The assets and business activities are sensitive to the below identified physical climate-related hazards:
• Heatwave
• Snow
• Storm
• Wildfire
• Flooding
• Sea level rise
• Changing temperature
• Changing in wind patterns
• Water stress / Pressure on water resources
In the SSP 5-8.5 scenario, the risk from extreme weather events (such as heatwaves and wildfires) is high over the
long-term horizon. As this scenario projects more intense heatwaves, HELLENiQ ENERGY’s assets—particularly
those located in open or unprotected areas—may face an increased risk of operational interruptions due to

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extreme heat. Demand for cooling and energy supply could rise significantly, placing additional stress on
infrastructure. Furthermore, under a high-emissions scenario like SSP 5-8.5, the increased frequency and
intensity of wildfires could threaten energy facilities located in fire-prone areas. This may impact the Group’s
infrastructure, requiring enhanced protective measures and potentially leading to operational disruptions or
delays. Conversely, the risks from floods and snowfall are estimated to be low across all three time horizons in this
scenario. However, even though the flood risk is low under SSP 5-8.5, HELLENiQ ENERGY’s facilities in flood-
prone areas—such as coastal or low-lying regions—may still face some exposure, particularly as storm intensity
increases. Floods could disrupt operations, damage infrastructure, and affect the transportation of energy
products. In summary, while the risks from high winds and river floods appear moderate in both the SSP 5-8.5 and
SSP1-2.6 scenarios, the heightened risk of heatwaves and wildfires represents a significant threat to HELLENiQ
ENERGY’s assets. It is also noteworthy that the Group continuously evaluates the latest climate models and data
to improve the accuracy and reliability of the assessment results. [ESRS E1.IRO-1, AR 11-(a), (c)]
Climate Change Adaptation
Regarding activities aligned with the EU Taxonomy, and specifically for each renewable energy plant, the
Competent Authorities define the necessary environmental protection measures and requirements in the relevant
Environmental Permits, where applicable. During project planning, HELLENiQ RENEWABLES also conducts
specialized, site-specific studies to optimize project design. The company also considers previous experience in
managing the impacts of extreme weather events (e.g., at certain renewable energy assets affected by the
destructive storm “Daniel” and the floods in Thessaly).
Concerning resilience to extreme temperatures (heatwaves, snowfall), industrial-grade equipment is preferred,
designed for a temperature range exceeding the average values of the host countries. This equipment has an
expected lifespan of 25–30 years. Additionally, all renewable energy plants are equipped with external
temperature sensors. In cases of heavy snowfall or frost, snow accumulation on panels reduces energy efficiency
and increases structural load on both the panels and their supporting systems. To ensure reliability under such
conditions, specially designed equipment with enhanced resistance to snow and low temperatures is selected. For
the protection of electrical substation equipment against high temperatures and heatwaves, dedicated air-
conditioning units are installed in substations, ensuring optimal operating conditions and system reliability.
To mitigate wildfire risk, substations and wind turbines are equipped with fire suppression systems in accordance
with the guidelines of the competent fire authorities. Additionally, depending on the site, teams carry out 2–3
annual grass-cutting operations across the facility and its perimeter.
The design of the plants complies with national legislation and European Standards, taking into account
maximum variable wind conditions and the local environment. Comprehensive geotechnical and structural studies
are also conducted to ensure that the plants can withstand the environmental conditions of the area throughout
the project’s lifetime. During operations, annual sampling inspections of fastener tightness are carried out for
photovoltaic systems, while wind turbines are equipped with preventive vibration monitoring systems. The impact
of storms is thoroughly assessed in geotechnical and hydrological studies, which are adapted to the specific
characteristics of each installation site. During the project design phase, 50- or 100-year return period scenarios
(stricter standards) are adopted, and areas with high flood risk are avoided. Technical works are executed and
inspected in compliance with national standards (e.g., ELOT). Regular inspections are also conducted to identify
any emerging issues or findings. In addition to the above measures, all assets are protected by appropriate all-risk
insurance policies.

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Climate-related transition risks:

Risk Identified | Risk Type | Affected business area | Scenario used | Risk assessment results
Short-term (FY2026) | Medium- term (FY2027- FY2030) | Long-term (FY2031- FY2050)
Transition to a low carbon economy | Transition (Technology) | Liquid fuels & chemicals | SSP1-2.6 (Net Zero 2050) | Medium | Medium | Medium
Emerging regulation - Carbon pricing mechanisms | Transition (Policy & Legal) | Liquid fuels & chemicals | SSP1-2.6 (Net Zero 2050) | Medium | High | High

The Group has identified transition events across all four types – Policy and Legal, Technology, Market, and
Reputation. Among these, the material ones are highlighted in the table above and are further detailed below.
Detailed description of transition risks
Transition to a Low-Carbon Economy
Ongoing technological advancements and the declining cost of renewable energy sources are increasing
competition in the energy market for oil and gas companies, potentially reducing demand for fossil fuel products.
Emerging Legislation – Carbon Pricing Mechanisms
The oil and gas industry represents a significant contributor to global emissions and, consequently, is substantially
exposed to carbon pricing, both directly and indirectly. Higher carbon prices will increase the cost of emissions,
which may affect operational decisions and potentially impact profitability. Furthermore, the expansion of the EU
ETS to cover emissions from transportation and heating is expected to indirectly accelerate the shift of consumers
toward cleaner, alternative technologies. In the long term, this trend could lead to a gradual reduction in demand
for conventional fuels. Based on these scenarios, the exposure and sensitivity of assets and business activities to
the identified transition events were assessed qualitatively, taking into account their likelihood, magnitude, and
duration, while prioritization was carried out using a low–medium–high scale. [ESRS E1.IRO-1 AR 12-(a), (b), AR 13-AR 14]
Transition risks are higher in the medium- and long-term under the SSP1-2.6 scenario, as they align with the goals
of the Paris Agreement, which requires rapid and significant global efforts to achieve decarbonization, as well as
with the 1.5°C climate change limitation. Achieving these targets entails the implementation of stringent climate
policies, regulations, and significant market changes to reduce greenhouse gas emissions. This translates into
higher carbon taxes, stricter energy efficiency standards, and an accelerated shift to renewable energy.
Additionally, ongoing technological advancements and the decreasing costs of renewable energy intensify
competition in the energy market, particularly for oil and gas companies, potentially reducing demand for fossil
fuel products. Consequently, these factors may impose significant financial and operational pressures on the
Group. Furthermore, the oil and gas industry is heavily affected by carbon pricing mechanisms (such as emission
trading systems). Higher carbon prices increase the cost of emissions, influencing production methods and
shaping the pricing of end-user products. In contrast, over the short-term horizon, the significance of these risks is
lower under the SSP1-2.6 scenario, assuming that regulatory and economic factors, as well as technological
developments related to transition risks, are less sensitive in the immediate future. [ESRS E1.IRO-1 AR 12 (c)]

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Climate-related opportunities
The Group has also identified the following climate-related opportunities.

Opportunity Identified | Opportunity Type | Scenario used | Risk assessment results
Short-term (FY2026) | Medium-term (FY2027-FY2030) | Long-term (FY2031-FY2050)
Development and/or expansion of low emission goods and services | Transition (Products & services) | SSP1-2.6 (Net Zero 2050) | High | High | High
Participation in carbon market, including voluntary market and ETS2 | Transition (Energy source) | SSP1-2.6 (Net Zero 2050) | Low | Medium | High

Detailed Description of Opportunities
Development and/or Expansion of Low-Emission Products and Services
In response to the accelerating energy transition, the Group is implementing its strategic plan by leveraging new
opportunities arising from changes in the energy landscape. This plan focuses on two main areas:
• Redesign of the ESG strategy and GHG targets – aiming to improve the environmental footprint by 2030
(30% reduction in Scope 1 and 2 emissions, 2 GW of renewable energy capacity) and committing to Net Zero
by 2050, while simultaneously implementing measures that optimize operational performance and reduce
costs.
• Adjustment of business strategy and capital allocation – with an emphasis on investments in the New
Energy sector, which represent the majority of growth initiatives. This aims to ensure synergy between
emissions reduction and efficiency gains. At the same time, it creates opportunities for long-term value
creation, promotion of sustainable economic growth, and attraction of environmentally oriented investors.
Participation in the Carbon Market, Including the Voluntary Market and the ETS2 Trading System
Under Directive 2003/87/EC, the Group’s refinery and power generator facilities and participate in the EU ETS of
the EU. As previously noted, compliance costs have increased significantly since 2018. In 2025, direct CO₂
emissions amount to 4,204,779 tons, and the carbon price the year's end exceeds €85/ton, resulting in
substantial operating costs.
Consequently, the implementation of a clear CO₂ reduction strategy has been decided, as described below. Within
this effort, the Elefsina refinery will serve as a pilot site for energy transition and decarbonization, through
investments in energy efficiency, a cogeneration unit to improve supply security, support for energy efficiency
investments, blue hydrogen via carbon capture, pilot production of green hydrogen using renewable electricity,
and electricity generation through on-site solar energy. The expected CO₂ avoidance (Scope 1&2) is projected to
exceed 1,300,000 tons by 2030.
Additionally, the Thessaloniki refinery will be upgraded with a 2G biodiesel co-processing cogeneration unit to
increase the use of sustainable feedstocks in our fuels. Simultaneously, the development of the “Green Hub
North” project, which includes the installation of a photovoltaic system/energy storage system with batteries (PV/
BESS) and a direct high-voltage line to the Thessaloniki refinery, is expected to lead to a significant reduction in
Scope 2 emissions.
Compatibility of Climate Scenarios with Financial Assumptions
For the reporting period, critical climate-related assumptions were not included in the financial statements.
Regarding the climate risk assessment conducted in the previous year, the HELLENiQ ENERGY Group, as
described in the section “Locked-in GHG Emissions Assessment ” determined that the business activities of its
three refineries will require some additional improvement interventions to align with the transition to a climate-

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neutral economy. It is noteworthy, however, that these emissions are not expected to jeopardize the achievement
of the Group’s GHG reduction targets. [ESRS E1.IRO-1, AR 12-(d), AR 13-AR 14] [ESRS E1.IRO-1, AR 15, AR 13-AR 14]
ESRS 2 IRO-1 - Description of the Processes to Identify and Assess Material Pollution-
Related IROs
With regard to Pollution (ESRS E2), a specific methodology was adopted to identify material risks and
opportunities. This approach involved reviewing issues based on previous findings and analyses from previous
years. After thorough validation and in accordance with the DMA, these issues remain critical to the current
analysis.
The Sustainable Development Team worked closely with the Group’s business unit data owners, as well as
external experts, collecting information from all relevant stakeholders. This included consultations across the
value chain and the collection of environmental data and community-related information. The relevant
information collected was used to inform and update the corresponding sections of the Report, ensuring that all
important issues were considered and accurately reflected in the DMA. [ESRS E2.IRO-1-11-(b)] [ESRS E2.IRO-1, AR 9]
Material Impacts, Risks and Opportunities related to Pollution
The Group focuses on continuously reducing air pollutants and improving its environmental footprint,
contributing to better air quality in the areas where it operates. This is achieved through actions such as: a) using
fuels with higher environmental standards, b) investing in modern production technology, such as low nitrogen
oxide emission burners, and c) reducing emissions through the implementation of VOC recovery systems and
particulate matter control filters.
Air pollution, assessed as a material impact, is linked to the Group's value chain. It is a negative impact from
procurement activities due to emissions from the transport of raw materials, the use of fuels by end consumers
and waste treatment. It is also linked to the Group's core activities, such as SO2, NOx, PM10, and VOC emissions
from industrial production and product transportation. At the same time, the Group recognizes the risk of
environmental incidents, including those arising from natural phenomena, such as oil spill contamination and air,
water, or soil pollution. Such events could disrupt production operations and result in significant financial losses,
including damage to assets, increased insurance premiums, and adverse impacts on the Group’s reputation.
It is noted that the Group maintains strict compliance with the national and European legislative framework,
adhering to Best Available Techniques and the European Directive on Industrial Emissions, while implementing
certified environmental management systems in all its activities. [ESRS E2.IRO-1- 11-(a), AR 1- AR 8]
ESRS 2 IRO-1 - Description of the Processes to Identify and Assess Material Water
and Marine Resources-Related IROs
With regard to Water and Marine Resources (ESRS E3), HELLENiQ ENERGY Group investigated all aspects of its
business activities to identify actual and potential impacts, risks, and opportunities across the value chain. It is
widely known that oil refineries, like other heavy industries, consume large amounts of water, managing
approximately equal amounts of water and oil, but the Group is implementing measures to limit its use as much as
possible. At the same time, the Group follows the principles of the European Agency for Health, Safety and the
Environment in the oil sector, as well as those of Concawe, which have been expanded to address social concerns
about environmental, health, and safety issues.
During the current reporting period, through DMA and climate risk assessment, HELLENiQ ENERGY Group
identified for the first time a relevant risk, as well as a negative and a positive impact related to water and marine
resources, highlighting the need for continuous monitoring and effective management of these issues.
In relation to water and marine resources, HELLENiQ ENERGY Group's Sustainable Development Team worked
closely with the relevant data managers, maintaining an active dialogue with affected stakeholder groups. In
addition, as part of the external consultation, feedback and expert considerations.

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The data collection process included interviews and meetings with stakeholders, as described in the other
thematic templates. The information gathered is analyzed in the relevant section of the Report and was used to
complete and validate the DMA. [ESRS E3.IRO-1-8-(a),(b)]
ESRS 2 IRO-1 - Description of Processes to Identify and Assess Material Biodiversity
and Ecosystem-Related IROs
With regard to Biodiversity and Ecosystems (ESRS E4), a methodology consistent with that applied to the other
environmental topics was followed.. Although the identified IROs relating to biodiversity and ecosystems were not
assessed as material, the Group has identified them and continues to monitor them closely in order to remain
prepared to address any potential future impacts. More specifically, based on the DMA, no material actual or
potential impacts on biodiversity and ecosystems were identified arising from the Group’s activities or across its
value chain. The Group has no significant dependencies on biodiversity and ecosystems. HELLENiQ ENERGY's
refinery facilities are strategically located in industrial zones designed for this purpose and are rarely located near
protected areas, such as Natura 2000 and RAMSAR. [ESRS E4.IRO-1-17-(a), (b)]
The Group applies a preventive approach, aiming to understand and manage the potential impacts its activities
may have on biodiversity and ecosystems, both at its facilities and along the value chain. In this context, it
operates wind and solar parks located within or in close proximity to environmentally sensitive areas, such as the
Special Protection Area (SPA) for birds and the Agios Nikolaos Wildlife Refuge. At the same time, it is developing
projects in locations such as forest areas, wildlife refuges, and the Important Bird Area (IBA) "Southern Evros
Forest Complex," where endangered species are found. For each project, environmental impact assessments and
targeted protection measures are implemented to ensure that there are no adverse effects on habitats and
species. In addition, systematic monitoring is carried out to prevent any disturbance or degradation of
ecosystems. [ESRS E4.IRO-1-19-(a)]
HELLENiQ ENERGY Group conducts a thorough assessment of its existing and potential impacts on biodiversity
and ecosystems, taking into account parameters such as the proximity of its facilities to protected areas, the
ecological sensitivity of local habitats, and the resilience of the species they host. To ensure high standards, it uses
international guidelines and applies specialized biodiversity impact assessments for each project or site. Through
this process, the Group is able to examine critical ecosystem services, such as water supply and quality, soil
fertility, and carbon sequestration, which are fundamental factors for the sustainability of its activities.
At the same time, it assesses how its operations and raw material sourcing may affect ecosystems. This approach
also includes investigating physical risks, such as habitat loss, as well as transition risks, such as changes in
regulatory policy or market conditions, which may affect its operations. [ESRS E4.IRO-1-17-(d)]
HELLENiQ ENERGY Group takes immediate action whenever it identifies a potential negative impact of its
activities on biodiversity or ecosystems, even at an early stage, if these could affect local communities. At the
same time, it maintains an active dialogue with local stakeholders through meetings, workshops, and other forms
of participatory processes so that their needs and views are incorporated into the DMA. Specifically, during the
external consultation with biodiversity experts during the period under review, no significant negative impacts on
biodiversity or ecosystems were identified. On the contrary, emphasis was placed on the opportunity offered by
solar parks to also serve as wildlife refuges. Proper siting and careful design can make them beneficial to
biodiversity, enhancing their overall environmental impact. Furthermore, none of the Group's sites show any
existing or potential negative consequences for the communities affected. [ESRS E4.IRO-1-17-(e)-(i), (ii)]
In cases where it is not possible to completely avoid negative impacts on ecosystems directly linked to the quality
of life of local communities, HELLENiQ ENERGY Group has established mitigation procedures, which include
actions such as habitat restoration, supporting conservation programs, and adopting sustainable natural resource
management practices. During the reporting period, there were no incidents that required the activation of these
plans. Therefore, it was not deemed necessary to implement additional measures to protect biodiversity. [ESRS
E4.IRO-1-19-(b)]

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ESRS 2 IRO-1 - Description of the Processes to Identify and Assess Material Resource
Use and Circular Economy-Related IROs
With regard to Resource Use and Circular Economy (ESRS E5), HELLENiQ ENERGY Group followed a methodology
similar to that applied to all other environmental issues. In this context, the Group's assets and activities were
examined with the aim of identifying actual and potential impacts, risks, and opportunities both in its own
operations and in the upstream and downstream segments of the value chain. More specifically, based on the
DMA, no material actual or potential impacts related to resource use and the circular economy were identified
arising from the Group’s activities or across its value chain. The Group does not have significant dependencies on
resource use or circular economy-related matters.
During the reporting period, systematic waste audits were carried out, with clear categorization of materials and
the use of a transparent reporting mechanism for public disclosure of their composition. The main categories
included catalysts, metals, oily residues and oily waste.
Following a review of the current situation, existing analysis, and historical data, the validation process confirmed
that issues related to resource use and the circular economy, as highlighted by the DMA, are not considered
significant for the Group. Although the identified IROs concerning resource use and the circular economy were not
deemed material, HELLENiQ ENERGY Group continues to monitor them to ensure timely response to any
potential future implications for the Group. [ESRS E5.IRO-1-11-(a), AR1- AR 7]
The Sustainable Development Team worked closely with data managers of the business units, collected input
from stakeholders, and consulted subject-matter experts on circular economy and waste management issues.
The data collection process included interviews and meetings with affected groups, as well as a detailed review of
the Group's assets and activities, with the aim of identifying potential risks and opportunities associated with
circular economy and waste management matters. [ESRS E5.IRO-1-11-(b)]
ESRS 2 IRO-1 – Description of the processes for identifying and assessing material
impacts, risks and opportunities related to business conduct
With regard to Business Conduct (ESRS G1), HELLENiQ ENERGY Group followed the same structured process to
identify and assess material impacts across the full scope of its operations and value chain. This approach
emphasizes the cultivation of an environment grounded in strong ethical values, where codes of conduct,
reporting mechanisms, and awareness and training programs support employees in acting responsibly. The
outcomes of the assessment are integrated into the Group’s corporate governance and risk management
processes, strengthening transparency, safeguarding integrity, and ensuring the Group’s continuous responsible
operation. [ESRS G1.IRO-1-6]

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IRO-2 - Disclosure Requirements in ESRS Covered by HELLENiQ ENERGY’s
Sustainability Statement
The following tables serve as a guide to locate information pertaining to specific disclosure requirements within
the Sustainability Statement. The tables also highlights where related information, which is "incorporated by
reference," can be found outside the Sustainability Statement, such as in the management's review, financial
statements within this annual report, or the separate remuneration report.

Cross-cutting standards Disclosure requirements | Section / report | Additional information
ESRS 2 General Requirements
BP-1 | General basis for preparation of the sustainability statement | BP-1 - General basis for preparation of the sustainability statement Annual Financial Report 2025: Note 36. List of Principal Consolidated Subsidiaries and Associates Included in the Financial Statements | Applicable: ESRS 2-BP-1-5
BP-2 | Disclosures in relation to specific circumstances | BP-2 - Disclosures in Relation to Specific Circumstances | Applicable: ESRS 2-BP-2-9, ESRS 2-BP-2-10, ESRS 2- BP-2-11, ESRS 2-BP-2-13, ESRS 2-BP-2-14, ESRS 2- BP-2-15, ESRS 2-BP-2-16, AR 2
GOV-1 | The role of the administrative, management and supervisory bodies | GOV-1 - The Role of Administrative, Management and Supervisory Bodies Annual Financial Report 2025: BoD members’ experience and basic skills, Corporate Governance, Annual Financial Report 2025 | Applicable: ESRS 2-GOV-1-21, ESRS 2-GOV-1-22, ESRS 2- GOV-1-23
GOV-2 | Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies | GOV-2 – Information Provided to and Sustainability Matters Addressed by HELLENiQ ENERGY’s Administrative, Management and Supervisory Bodies | Applicable: ESRS 2-GOV-2-26
GOV-3 | Integration of sustainability- related performance in incentive schemes | Remuneration Policy of BoD members | Applicable: ESRS 2- GOV-3-29,ESRS E1- GOV-3-13
GOV-3 - Integration of Sustainability- Related Performance in Incentive Schemes
GOV-4 | Statement on sustainability due diligence | GOV-4 - Statement on Due Diligence | Applicable: ESRS 2- GOV-4-30, ESRS 2- GOV-4-32, AR 10
GOV-5 | Risk management and internal controls over sustainability reporting | GOV-5 - Risk Management and Internal Controls over Sustainability Reporting Annual Financial Report 2025: A.6 Risks and Uncertainties | Applicable: ESRS 2- GOV-5-36, AR 11
SBM-1 | Strategy, business model and value chain | SBM-1 - Strategy, Business Model and Value Chain | Applicable: ESRS 2 SBM-1-40- (a), ESRS 2 SBM-1-40-(d), ESRS 2 SBM-1-40-(e), ESRS 2 SBM-1-40-(f), ESRS 2 SBM-1-40-(g), ESRS 2 SBM-1-42, AR 12 – AR 15
SBM-2 | Interests and views of stakeholders | SBM-2 - Interests and Views of Stakeholders | Applicable: ESRS 2-SBM-2-45
SBM-3 | Material impacts, risks and opportunities and their interaction with strategy and business model | SBM-3 - Material IROs and their Interaction with Strategy and Business Model | Applicable: ESRS 2-SBM-3-48

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IRO-1 | Description of the process to identify and assess material impacts, risks, and opportunities | IRO-1 - Description of the Processes to Identify and Assess Material IROs | Applicable: ESRS 2-IRO-1-53, ESRS E1.IRO-1-21, ESRS E1.IRO-1-20, AR 9, AR 10, AR 11, AR 12, AR 13, AR 14, AR 15, ESRS E2.IRO-1- 11, AR 1- AR 9, ESRS E3.IRO-1-8, ESRS G1.IRO-1-6 Voluntary: ESRS E4.IRO-1-17-(a), ESRS E4.IRO-1-17-(b), ESRS E4.IRO-1-17-(d), ESRS E4.IRO-1-17-(e), ESRS E4.IRO-1-19-(a), E4.IRO-1-19- (b) ESRS E5.IRO-1-11, AR 1- AR 7
IRO-2 | Disclosure requirements in ESRS covered by the undertaking’s sustainability statement | IRO-2 - Disclosure Requirements in ESRS Covered by HELLENiQ ENERGY’s Sustainability Statement | Εφαρμόζονται: ESRS 2- IRO-2-56, ESRS 2-IRO-2-57, ESRS 2-IRO-2-58, ESRS 2- IRO-2-59

Environmental Standards Disclosure requirements | Section/ report | Additional information
ESRS E1 Climate Change |
E1-1 | Transition plan for climate change mitigation | E1-1 Transition plan for climate change mitigation | Applicable: ESRS E1-1-16-(a), AR 2, AR 4, ESRS E1-1-16-(i), ESRS E1-1-16-(j), ESRS E1-4-34-(e), ESRS E1-1-16-(b), ESRS E1-1-16-(c), ESRS E1-1-16-(d), ESRS E1-1-16-(e), ESRS E1-1-16-(f), AR 5, ESRS E1-1-16-(g), ESRS E1-1-16-(h), ESRS E1-1-16-(j), ESRS E1-3-29-(a)
ESRS 2, SBM-3 | Material impacts, risks and opportunities, and their interaction with strategy and business model | ESRS 2 SBM-3 - Material IROs and their Interaction with Strategy and Business Model | Applicable: ESRS E1.SBM-3-18, ESRS E1.SBM-3, AR-7-(b), ESRS E1.SBM-3, AR-8-(b), ESRS E1.SBM-3-19- (a), AR 6, AR 13, ESRS E1.SBM-3-19-(b), AR 7-(a), (b), ESRS E1.SBM-3-19-(c), AR 8 (b)
E1-2 | Policies related to climate change mitigation and adaptation | E1-2 - Policies Related to Climate Change Mitigation and Adaptation | Applicable: ESRS E1-2 24, ESRS E1-2 25
E1-3 | Actions and resources in relation to climate change policies | E1-3 - Actions and Resources in Relation to Climate Change Policies | Applicable: ESRS E1-3-28, ESRS E1-3-29, AR 20, AR 21, AR 22, E1-3-29-(b), E1-4-16- (b), ESRS E1-3-29-(a), ESRS E1-4-34-(a), (b), AR 25-(a), ESRS E1-3-29-(c)
E1-4 | Targets related to climate change mitigation and adaptation | E1-4 - Targets Related to Climate Change Mitigation and Adaptation | Applicable: ESRS E1-4-32, ESRS E1-4-33, AR 27, AR 28, AR 29, ESRS E1-4-34-(e), 16- (a), AR 26, ESRS E1-4-34-(f), 16-(b), AR 30, ESRS E1-4-34- (b), ESRS E1-4, AR 30-(c), ESRS E1-4, AR 25, ESRS E1-4 AR 25-(b), ESRS E1-4-34-(a), (b), AR 23, AR 24, AR 27, AR 28, AR 29, AR 31, ESRS E1-4-30, ESRS E1-4-34-(a), (b), (c)

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E1-5 | Energy consumption and mix | E1-5 - Energy Consumption and Mix | Voluntary: ESRS E1-5-37, ESRS E1-5-38, ESRS E1-5-39, ESRS E1-5-40, ESRS E1-5-41, ESRS E1-5-42, ESRS E1-5-43, AR 34, AR 36, AR 38 b, ESRS E1-5-37-(a), (b), (c), E1-5-38- (a), (b), (c), (d), (e), ESRS E1-5- AR 37
E1-6 | Gross Scopes 1, 2, 3 and total GHG emissions | E1-6 - Gross Scopes 1, 2, 3 and Total GHG Emissions | Applicable: ESRS E1-6-50, ESRS E1-6-AR 41, ESRS E1-6-48-(b), AR 44, ESRS E1-6-AR 39-(b), ESRS E1-6-44, 52-(b), AR 47, ESRS E1-6-50, ESRS E1-6-AR 45-(e), ESRS E1-6-45-(d), ESRS E1-6-44-(a), (b), (c), (d), ESRS E1-6 AR 46-(h), ESRS E1-6-48-(a), (b), ESRS E1-6-49-(a), (b), ESRS E1-6-51, ESRS E1-6-52-(a), (b), ESRS E1-6 AR 46-(g),(j), (k), (i), (e), (h), (f), ESRS E1-6 53, AR 53, AR 54, ESRS E1-6-55
E1-8 | Internal carbon pricing | E1-8 - Internal Carbon Pricing | Voluntary: ESRS E1-8-63-(a), (b), (c), (d), AR 65
E1-9 | Anticipated financial effects from material physical and transition risks and potential climate-related opportunities | E1-9 - Anticipated Financial Effects from Material Physical and Transition Risks and Potential Climate-Related Opportunities |

Environmental Standards Disclosure requirements | Section/ report | Additional information
ESRS E2 Pollution
E2-1 | Policies related to pollution | E2-1 - Policies Related to Pollution | Applicable: ESRS E2-1-15-(a), ESRS E2-1-15-(b), ESRS E2-1-15-(c), AR 11
E2-2 | Actions and resources related to pollution | E2-2 - Actions and Resources Related to Pollution | Applicable: ESRS E2-2-18
E2-3 | Targets related to pollution | E2-3 - Targets Related to Pollution | Applicable: ESRS E2-3-25
E2-4 | Pollution of air, water, and soil | E2-4 - Pollution of Air, Water and Soil | Applicable: ESRS E2-4-28-(a), AR 21, AR 22, ESRS E2-4-30- (a), ESRS E2-4-30-(b), AR 26, ESRS E2-4-30-(c), AR 27
E2-6 | Anticipated financial effects from pollution-related, risks and opportunities | E2-6 – Anticipated financial effects from pollution-related, risks and opportunities |

Environmental Standards Disclosure requirements | Section/ report | Additional information
ESRS E3 Water and marine resources
E3-1 | Policies related to water and marine resources | E3-1 - Policies Related to Water and Marine Resources | Applicable: ESRS E3-1-9, ESRS E3-1-11, ESRS E3-1-12-(a), ESRS E3-1-12-(b), (c)
E3-2 | Actions and resources related to marine resources | E3-2 - Actions and Resources Related to Water and Marine Resources | Applicable: ESRS E3-2-17, ESRS E3-2-19, AR 19 - AR 21
E3-3 | Targets related to water and marine resources | E3-3 – Targets related to water and marine resources | Omitted: ESRS E3-3-23, 24, 25

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E3-4 | Water consumption | E3-4 - Water Consumption | Applicable: ESRS E3-4-28-(a), (c), (d), (e), ESRS E3-4, AR 28, AR 32
E3-5 | Anticipated financial effects from water and marine resources-related impacts, risks and opportunities | E3-5 – Anticipated financial effects from water and marine resources- related impacts, risks and opportunities |

Environmental Standards Disclosure requirements | Section/ report | Additional information
ESRS E4 Biodiversity and ecosystems
E4-2 | Policies related to biodiversity and ecosystem | E4-2 - Policies Related to Biodiversity and Ecosystems | Voluntary: ESRS E4-2-22
E4-3 | Actions and resources related to biodiversity and ecosystems | E4-3 - Actions and Resources Related to Biodiversity and Ecosystems | Voluntary: ESRS E4-3-28-(c)

Environmental Standards Disclosure requirements | Section/ report | Additional information
ESRS E5 Resource use and circular economy
E5-1 | Policies related to resource use and circular economy | E5-1 - Policies Related to Resource Use and Circular Economy | Voluntary: ESRS E5-1-14, ESRS E5-1-15
E5-2 | Actions and resources related to resource use and circular economy | E5-2 - Actions and Resources Related to Resource Use and Circular Economy | Voluntary: ESRS E5-2-19
E5-3 | Targets related to resource use and circular economy | E5-3 - Targets Related to Resource Use and Circular Economy | Voluntary: ESRS E5-3-23, ESRS E5-3-24-(e), ESRS E5-3-27
E5-4 | Resource inflows | E5-4 - Resource Inflows | Voluntary: ESRS E5-4-30, AR 21, ESRS E5-4-32, AR 25
E5-5 | Resource outflows | E5-5 - Resource Outflows | Voluntary: ESRS E5-5-37-(a), (b), (c), (d), ESRS E5-5-38-(a), (b), ESRS E5-5-39, ESRS E5-5-40

Social Standards Disclosure requirements | Section/ report | Additional information
ESRS S1 Own Workforce
ESRS 2, SBM-2 | Interests and views of stakeholders | SBM-2 - Interests and Views of Stakeholders | Applicable: ESRS S1.SBM-2-12
ESRS 2, SBM-3 | Material impacts, risks and opportunities and their interaction with strategy and business model | SBM-3 - Material IROs and their Interaction with Strategy and Business Model Annual Financial Report 2025: B.2 Activity Report of Audit Committee | Applicable: ESRS S1-ESRS 2- SBM-3-13, AR 6, AR 7, ESRS S1-ESRS 2-SBM-3-14,ESRS S1-ESRS 2-SBM-3-15, ESRS S1-ESRS 2-SBM-3-16
S1-1 | Policies related to own workforce | S1-1 - Policies Related to Own Workforce Code of Conduct: 7.1. Health & Safety, 7.2. Equal opportunities, 7.3. Respect to colleagues and third parties doing with the Group Harassment | Applicable: S1-1-19, 20, 21, 22, 23, 24, AR 15, AR 16
S1-2 | Processes for engaging with own workers and workers’ representatives about impacts | S1-2-Processes for engaging with own workers and workers’ representatives about impacts | Applicable: S1-2-27, AR 18, AR 19

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S1-3 | Processes to remediate negative impacts and channels for own workers to raise concerns | S1-3-Processes to remediate negative impacts and channels for own workers to raise concerns Annual Financial Report 2025: EU Taxonomy Report - Alignment Screening – Minimum Social Safeguards | Applicable: S1-3-32, 33
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 | S1-4-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 | Applicable: ESRS 2-S1-4-37, 38, AR 38, AR 39, AR 42, 39, AR 34, 40, AR 44, AR 45, AR 47, 41, AR 37, AR 43, 43
S1-5 | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | S1-5-Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | Applicable: ESRS 2-S1-5-46, AR 50, AR 51, AR 52, 47
S1-6 | Characteristics of the undertaking’s employees | S1-6-Characteristics of the undertaking’s employees Annual Financial Report 2025: A.5 Group Business Review, a) Financial Highlights | Applicable: ESRS 2-S1-6-50- (a), (b), AR 57, (c), AR 59,(d), AR 60, (e), AR 58, (f)
S1-7 | Characteristics of non- employee workers in the undertaking’s own workforce | S1-7-Characteristics of non-employee workers in the undertaking’s own workforce | Applicable: ESRS 2-S1-7-55- (a), (b), (c), 56
S1-8 | Collective bargaining coverage and social dialogue | S1-8-Collective bargaining coverage and social dialogue | Applicable: ESRS 2-S1-8-60, AR 66, 63, AR 69, AR 70
S1-9 | Diversity metrics | S1-9-Diversity metrics | Applicable:ESRS 2-S1-9-66 (b), AR 71
S1-10 | Adequate wages | S1-10-Adequate wages | Applicable: ESRS 2-S1-10-69, AR 72, AR 73, AR 74, 70
S1-11 | Social Protection | S1-11-Social Protection | Applicable: ESRS 2-S1-11-74, AR 75
S1-12 | Persons with disabilities | S1-12-Persons with disabilities | Applicable: ESRS 2-S1-12, 79, AR 76
S1-13 | Training and skills development metrics | S1-13-Training and skills development metrics | Voluntary: ESRS 2-S1-13-83, AR 77, AR 78
S1-14 | Health and safety metrics | S1-14-Health and safety metrics | Applicable: ESRS 2-S1-14-88
S1-15 | Work-life balance metrics | S1-15-Work-life balance metrics | Applicable: ESRS 2-S1-15-93
S1-16 | Compensations metrics (pay gap and total compensation) | S1-16-Compensations metrics (pay gap and total compensation) | Voluntary: ESRS 2-S1-16-97, AR 98, AR 99, AR 100, AR 101, AR 102
S1-17 | Incidents, complaints and severe human rights impacts | S1-17-Incidents, complaints and severe human rights impacts | Applicable: ESRS 2-S1-17-103, 104, AR 103,AR 104, AR 105, AR 106

Social Standards Disclosure requirements | Section/ report | Additional information
ESRS S3 Affected communities
ESRS 2, SBM-2 | Interests and views of stakeholders | SBM-2 - Interests and Views of Stakeholders | Applicable: ESRS 2- S3.SBM-2-7
ESRS 2, SBM-3 | Material impacts, risks and opportunities and their interaction with strategy and business model | SBM-3 - Material IROs and their Interaction with Strategy and Business Model Annual Financial Report 2025: E. Activity Report of Audit Committee | Applicable: ESRS 2- S3.SBM-3-9, 10

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S3-1 | Policies related to affected communities | S3-1-Policies related to affected communities | Applicable: ESRS 2-S3-1-16 (a), (b), (c), 17, AR 10
S3-2 | Processes for engaging with affected communities about impacts | S3-2-Processes for engaging with affected communities about impacts | Applicable: ESRS 2-S3-21, 22, 23
S3-3 | Processes to remediate negative impacts and channels for affected communities to raise concerns | S3-3-Processes to remediate negative impacts and channels for affected communities to raise concerns 4. Alignment Screening - Minimum Social Safeguards: 6. Provide or cooperate in remediation inc., when appropriate | Applicable: ESRS 2-S3-3-27, AR 17, AR 18 AR 24, 28, AR 23
S3-4 | Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions | S3-4-Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions | Applicable: ESRS 2-S3-4-31, 32 (a), (c), (d), AR 28, AR 29, AR 31- AR 33, AR 36, AR 37, 33, AR 26, 34, AR 38- AR 40, AR 42, 35, 36, 38
S3-5 | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | S3-5-Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities |

Social Standards Disclosure requirements | Section/ report | Additional information
ESRS S4 Consumers and end-users
ESRS 2, SBM-2 | Interests and views of stakeholders | SBM-2 - Interests and Views of Stakeholders | Applicable: ESRS 2- S4.SBM-2-8
ESRS 2, SBM-3 | Material impacts, risks and opportunities and their interaction with strategy and business model | SBM-3 - Material IROs and their Interaction with Strategy and Business Model | Applicable: ESRS 2- S4.SBM-3-10, 11
S4-1 | Policies related to consumers and end-users | S4-1-Policies related to consumers and end-users | Applicable: ESRS 2-S4-1, 15, 16, 17
S4-2 | Processes for engaging with consumers and end-users about impacts | S4-2-Processes for engaging with consumers and end-users about impacts | Applicable: ESRS 2-S4-2-20, 21
S4-3 | Processes to remediate negative impacts and channels for consumers and end-users to raise concerns | S4-3-Processes to remediate negative impacts and channels for consumers and end-users to raise concerns | Applicable: ESRS 2-S4-3-25 (b), (c), (d), 26
S4-4 | Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions | S4-4-Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions | Applicable: ESRS 2-S4-4-30, 31-(c), (d), 34, 35, 37
S4-5 | Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | S4-5-Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities | Applicable: ESRS 2-S4-5-41

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Data points that derive from other EU legislation
The following table indicates all the data points that derive from other EU legislation as listed in ESRS 2 appendix
B, indicating where the data points can be found in our report and which data points are assessed as ‘Not
material.’

Disclosure Requirement | Data point | Sustainability Statement | Appendix | SFDR reference | Pillar 3 reference | Benchmark regulation reference | EU Climate Law reference
ESRS 2 GOV-1 | 21 (d) | Board's gender diversity | x |  | x |
ESRS 2 GOV-1 | 21 (e) | Percentage of board members who are independent |  |  | x |
ESRS 2 GOV-4 | 30 | Statement on due diligence | x |  |  |
ESRS 2 SBM-1 | 40 (d) i | Involvement in activities related to fossil fuel activities | x | x | x |
ESRS 2 SBM-1 | 40 (d) ii | Involvement in activities related to chemical production | x |  | x |
ESRS 2 SBM-1 | 40 (d) iii | Involvement in activities related to controversial weapons | x |  | x |
ESRS 2 SBM-1 | 40 (d) iv | Involvement in activities related to cultivation and production of tobacco |  |  | x |
ESRS E1-1 | 14 | Transition plan to reach climate neutrality by 2050 |  |  |  | x
ESRS E1-1 | 16 (g) | Undertakings excluded from Paris- aligned Benchmarks |  | x | x |
ESRS E1-4 | 34 | GHG emission reduction targets | x | x | x |
ESRS E1-5 | 38 | Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) | x |  |  |
ESRS E1-5 | 37 | Energy consumption and mix | x |  |  |
ESRS E1-5 | 40-43 | Energy intensity associated with activities in high climate impact sectors | x |  |  |
ESRS E1-6 | 44 | Gross Scope 1, 2, 3 and Total GHG emissions | x | x | x |
ESRS E1-6 | 53-55 | Gross GHG emissions intensity | x | x | x |
ESRS E1-7 | 56 | GHG removals and carbon credits |  |  |  | x
ESRS E1-9 | 66 | Exposure of the benchmark portfolio to climate-related physical risks |  |  | x |
ESRS E1-9 | 66 (a),(c) | Disaggregation of monetary amounts by acute and chronic physical risk; Location of significant assets at material physical risk |  | x |  |
ESRS E1-9 | 67 (c) | Breakdown of the carrying value of its real estate assets by energy- efficiency classes |  | x |  |
ESRS E1-9 | 69 | Degree of exposure of the portfolio to climate-related opportunities |  |  | x |
ESRS E2-4 | 28 | Amount of each pollutant listed in Annex II of the E-PRTR Regulation emitted to air, water, and soil | x |  |  |
ESRS E3-1 | 9 | Water and marine resources | x |  |  |
ESRS E3-1 | 13 | Dedicated policy | x |  |  |
ESRS E3-1 | 14 | Sustainable oceans and seas | x |  |  |
ESRS E3-4 | 28 (c) | Total water recycled and reused. | x |  |  |

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ESRS E3-4 | 29 | Total water consumption in m3 per net revenue on own operations | x |  |  |
ESRS 2- SBM 3 - E4 | 16 (a) i | Activities negatively affecting biodiversity sensitive areas | x |  |  |
ESRS 2- SBM 3 - E4 | 16 (b) | Material negative impacts with regards to land degradation, desertification or soil sealing | x |  |  |
ESRS 2- SBM 3 - E4 | 16 (c) | Operations that affect threatened species | x |  |  |
ESRS E4-2 | 24 (b) | Sustainable land / agriculture practices or policies | x |  |  |
ESRS E4-2 | 24 (c) | Sustainable oceans / seas practices or policies | x |  |  |
ESRS E4-2 | 24 (d) | Policies to address deforestation | x |  |  |
ESRS E5-5 | 37 (d) | Non-recycled waste | x |  |  |
ESRS E5-5 | 39 | Hazardous waste and radioactive waste | x |  |  |
ESRS 2- SBM3 - S1 | 14 (f) | Risk of incidents of forced labor | x |  |  |
ESRS 2- SBM3 - S1 | 14 (g) | Risk of incidents of child labor | x |  |  |
ESRS S1-1 | 20 | Human rights policy commitments | x |  |  |
ESRS S1-1 | 21 | Due diligence policies on issues addressed by the fundamental International Labor Organization Conventions 1 to 8 |  |  | x |
ESRS S1-1 | 22 | Processes and measures for preventing trafficking in human beings | x |  |  |
ESRS S1-1 | 23 | Workplace accident prevention policy or management system | x |  |  |
ESRS S1-3 | 32 (c) | Grievance/complaints handling mechanisms | x |  |  |
ESRS S1-14 | 88 (b),(c) | Number of fatalities and number and rate of work-related accidents | x |  | x |
ESRS S1-14 | 88 (e) | Number of days lost to injuries, accidents, fatalities, or illness | x |  |  |
ESRS S1-16 | 97 (a) | Unadjusted gender pay gap | x |  | x |
ESRS S1-16 | 97 (b) | Excessive CEO pay ratio | x |  |  |
ESRS S1-17 | 103 (a) | Incidents of discrimination | x |  |  |
ESRS S1-17 | 104 (a) | Non-respect of UNGPs on Business and Human Rights and OECD | x |  | x |
ESRS 2- SBM3 – S2 | 11 (b) | Significant risk of child labor or forced labor in the value chain | x |  |  |
ESRS S2-1 | 17 | Human rights policy commitments | x |  |  |
ESRS S2-1 | 18 | Policies related to value chain workers | x |  |  |
ESRS S2-1 | 19 | Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines | x |  | x |
ESRS S2-1 | 19 | Due diligence policies on issues addressed by the fundamental International Labor Organization Conventions 1 to 8 |  |  | x |
ESRS S2-4 | 36 | Human rights issues and incidents connected to its upstream and downstream value chain | x |  |  |
ESRS S3-1 | 16 | Human rights policy commitments | x |  |  |

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ESRS S3-1 | 17 | Non-respect of UNGPs on Business and Human Rights, ILO principles or and OECD guidelines | x |  | x |
ESRS S3-4 | 36 | Human rights issues and incidents | x |  |  |
ESRS S4-1 | 16 | Policies related to consumers and end-users | x |  |  |
ESRS S4-1 | 17 | Non-respect of UNGPs on Business and Human Rights and OECD guidelines | x |  | x |
ESRS S4-4 | 35 | Human rights issues and incidents | x |  |  |
ESRS G1-1 | §10 (b) | United Nations Convention against Corruption | x |  |  |
ESRS G1-1 | §10 (d) | Protection of whistle- blowers | x |  |  |
ESRS G1-4 | §24 (a) | Fines for violation of anti-corruption and anti-bribery laws | x |  | x |
ESRS G1-4 | §24 (b) | Standards of anti- corruption and anti-bribery | x |  |  |

[ESRS 2-IRO-2-56, 57, 58, 59]

EU Taxonomy Report |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
ESRS E1 - Climate change |  | ESRS E2 - Pollution |  |
Strategy |  | Impact, Risk and Opportunity Management |  |
E1-1 | Transition Plan for Climate Change Mitigation |  | E2-1 | Policies Related to Pollution |  |  |  |  |  |
ESRS E1 SBM-3 | Material Impacts, Risks and Opportunities and their Interaction with Strategy and Business Model |  | E2-2 | Actions and Resources Related to Pollution |  |  |  |  |  |
Impact, Risk and Opportunity Management |  | Metrics and Targets |  |  |  |  |  |  |  |  |
E1-2 | Policies Related to Climate Change Mitigation and Adaptation |  | E2-3 | Targets Related to Pollution |  |  |  |
E1-3 | Actions and Resources in Relation to Climate Change Policies |  | E2-4 | Pollution of Air, Water and Soil |  |
Metrics and Targets |  | E2-6 | Anticipated Financial Effects from Material Pollution-Related Risks and Opportunities |  |  |
E1-4 | Targets Related to Climate Change Mitigation and Adaptation |  |  |  |  |  |
E1-5 | Energy Consumption and Mix |  | ESRS E3 - Water and Marine Resources |  |
E1-6 | Gross Scopes 1, 2, 3 and Total GHG Emissions |  | Impact, Risk and Opportunity Management |  |  |
E1-8 | Internal Carbon Pricing |  | E3-1 | Policies Related to Water and Marine Resources |  |  |  |  |  |  |  |  |
E1-9 | Anticipated Financial Effects from Material Physical and Transition Risks and Potential Climate-Related Opportunities |  | E3-2 | Actions and Resources Related to Water and Marine Resources |  |  |
|  |  |  |  |  |  |  |  | Metrics and Targets |  |  |
|  |  |  |  |  |  |  |  | E3-3 | Targets Related to Water and Marine Resources |  |  |  |  |  |  |  |  |
|  |  |  |  |  |  |  |  | E3-4 | Water Consumption |  |  |  |  |  |  |  |  |
|  |  | E3-5 | Anticipated Financial Effects from Water and Marine Resources-Related Risks and Opportunities |  |  |  |  |  |  |  |  |

ESRS E4 - Biodiversity and Ecosystems |  | ESRS E5 - Resource Use and Circular Economy |  |  |  |  |  |  |  |  |
Impact, Risk and Opportunity Management |  | Impact, Risk and Opportunity Management |  |  |  |  |  |  |  |  |
E4-2 | Policies Related to Biodiversity and Ecosystem |  | E5-1 | Policies Related to Resource Use and Circular Economy |  |  |  |  |  |  |  |  |
E4-3 | Actions and Resources Related to Biodiversity and Ecosystems |  | E5-2 | Actions and Resources Related to Resource Use and Circular Economy |  |  |  |  |  |  |  |  |
|  | Metrics and Targets |  |  |  |  |  |  |  |  |
|  |  | E5-3 | Targets Related to Resource Use and Circular Economy |  |  |  |  |  |  |  |  |
|  |  | E5-4 | Resource Inflows |  |  |  |  |  |  |  |  |
|  |  | E5-5 | Resource Outflows |  |  |  |  |  |  |  |  |

EU Taxonomy Report - Overview |  |  |  |  |  |
1 | Eligibility Screening |  |  |  |  |  |  |
2 | Identification of Material Activities |  |  |  |  |  |  |
3 | Alignment Screening – Substantial Contribution Criteria |  |  |  |  |  |  |
4 | Alignment Screening – Do No Significant Harm (DNSH) Criteria |  |  |  |  |  |  |
5 | Alignment Screening – Minimum Social Safeguards |  |  |  |  |  |  |
6 | Calculation of Financial KPIs |  |  |  |  |  |  |  |  |  |  |  |  |
| Overall Results of EU Taxonomy Assessment |  |  |  |  |  |  |
| Overall Results of KPIs |  |  |  |  |  |  |  |  |  |  |  |  |
| KPI Tables |  |  |  |  |  |  |  |  |  |  |  |  |
| Additional Information |  |  |  |  |  |  |  |  |  |  |  |  |

12 Commission to cut EU Taxonomy red tape for companies, 4 July 2025

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EU Taxonomy Report
In December 2019, the European Union introduced the European Green Deal, which adopts a set of initiatives
covering the climate, environment, energy, transport, industry, agriculture and sustainable finance, with the
aim of achieving climate neutrality by 2050
During 2025, the European Commission launched initiatives to simplify sustainability reporting obligations
under the Corporate Sustainability Reporting Directive (CSRD), including disclosures required under the EU
Taxonomy Regulation
EU Taxonomy Overview
The EU Taxonomy (EUT) serves as a standardized classification framework designed to define the environmental
performance of economic activities across a wide range of industries, facilitating the transition toward a low-
carbon, resilient, and resource-efficient economy by providing clear criteria for assessing sustainability.
Furthermore, the EUT supports investors, corporate entities, and financial institutions in identifying and
promoting activities that contribute to environmental objectives.
In 2025, the European Commission adopted a set of measures to simplify the application of EUT (“Omnibus I”
package) 12. These changes have been formalized through the adoption of a Delegated Act, which amends the
existing Taxonomy Disclosures, as well as the Climate and Environmental Delegated Acts. The simplification
measures laid out in the Delegated Act apply from 1 January 2026, covering 2025 data, with optional deferral to
2026. Under the revised rules, non‑financial undertakings are not required to assess Taxonomy eligibility or
alignment for non‑material activities.
Irrespective of the simplification measures, the Taxonomy Regulation includes a hierarchy of two levels of
reporting, Taxonomy-eligibility and Taxonomy-alignment, with the latter as subset of the former.
An economic activity is considered Taxonomy-eligible if it is listed in the EU Taxonomy and can potentially
contribute to realizing at least one of the following six environmental objectives:
1. Climate change mitigation (CCM)
2. Climate change adaptation (CCA)
3. Sustainable use and protection of water and marine resources (WTR)
4. Transition to a circular economy (CE)
5. Pollution prevention and control (PPC)
6. Protection and restoration of biodiversity and ecosystems (BIO)

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An economic activity is defined as environmentally sustainable i.e. Taxonomy-aligned if it meets all three of
the following conditions:
• It makes a substantial contribution to at least one of the six environmental objectives by meeting the
technical screening criteria.
• It does not significantly harm any of the other five environmental objectives by meeting the Do No
Significant Harm (DNSH) criteria.
• It meets minimum social safeguards, which apply to all economic activities and primarily concern human
rights and social standards.

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Non‑financial undertakings must disclose eligibility and alignment KPIs for all six objectives in accordance with
Article 8 of the Taxonomy Regulation.
EU Taxonomy Reporting by HELLENiQ ENERGY Group
HELLENiQ ENERGY Holdings (“the Group”) is required to publish annual EU Taxonomy disclosures. This report
covers FY2025 and presents the proportion of the Group’s activities that are Taxonomy‑eligible and
Taxonomy‑aligned across all environmental objectives.
The Group has adopted the Commission’s recommended simplification approach while also including activities
deemed material to its business. Eligibility screening followed the same methodology as FY2024. A materiality
assessment was applied, and alignment screening was performed only for material activities. More information is
presented in the ‘Identification of Material Activities’ section further below.
The reported KPIs cover consolidated entities included in the Group’s financial statements. Joint ventures and
associates without management control are excluded, though future inclusion is under evaluation. The FY2025
assessment includes Enerwave as a fully owned subsidiary.

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Process Analysis of the Group’s Business Activities
The five-step assessment methodology process showcased below:

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1. Eligibility Screening
The Group assessed the eligibility of its business activities by mapping operations to EU Taxonomy‑defined
activities and corresponding NACE codes across all six environmental objectives.
Certain activities already aligned with CCM were identified as inherently meeting CCA DNSH requirements. These
activities are reported exclusively under CCM to avoid double counting, as revenue from CCA‑adapted activities
cannot be included in CCA turnover KPIs unless classified as enabling activities, and CapEx/OpEx separation is not
feasible.
Following the eligibility assessment, the Group identified 222 eligible activities, corresponding to 15 EU
Taxonomy‑defined activities, contributing to CCM, CCA, and CE objectives. No eligible activities were identified for
WTR, PPC, or BIO objectives.
These 15 EU Taxonomy-defined economic activities include:
Eligible Activities

EU Taxonomy-defined Economic Activity | Description of the Group’s Activity | Environmental Objective
Petrochemicals |
1) CCM 3.14 Manufacture of organic basic chemicals | Production of propylene | Climate Change Mitigation (CCM)
2) CCM 3.17 Manufacture of plastics in primary form | Production of polypropylene | Climate Change Mitigation (CCM)
3) CE 1.1 Manufacture of plastic packaging goods | Production of Biaxially Oriented Polypropylene (BOPP) films | Circular Economy (CE)
Energy |
4) CCM 4.1 Electricity generation using solar photovoltaic technology | Construction and operation of large-scale electricity production facilities from solar energy using PV systems | Climate Change Mitigation (CCM)
5) CCM 4.3 Electricity generation from wind power | Construction and operation of large-scale electricity production facilities from wind energy | Climate Change Mitigation (CCM)
6) CCM 4.9 Transmission and distribution of electricity | Construction of a high-voltage 150 kV electricity transmission line connecting the Group’s PV projects to potential consumers | Climate Change Mitigation (CCM)
7) CCM 4.10 Storage of electricity | Construction of battery energy storage systems and pumped hydropower storage facilities to store electricity | Climate Change Mitigation (CCM)
8) CCM 4.29 Electricity generation from fossil gaseous fuels | Production of electricity from natural gas-fired units | Climate Change Mitigation (CCM)
Refining, Supply & Trading |
9) CCM 6.10 Sea and coastal freight water transport, vessels for port operations and auxiliary activities | Marine and ship transport services of bulk liquids or gases by tankers | Climate Change Mitigation (CCM)
Electromobility Services |
10) CCM 6.15 Infrastructure enabling low- carbon road transport and public transport | Construction and operation of EV charging stations | Climate Change Mitigation (CCM)
Other Activities |
11) CCM 7.6 Installation, maintenance and repair of renewable energy technologies | Small-scale PV systems installed on-site as technical buildings systems in several Group’s facilities e.g., rooftop PV systems | Climate Change Mitigation (CCM)
12) CCM 7.7 Acquisition and ownership of buildings | Ownership of buildings or properties | Climate Change Mitigation (CCM)
13) CCM 8.1 Data processing, hosting and related activities | Operation of data centres | Climate Change Mitigation (CCM)

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14) CCM 8.2 Data-driven solutions for GHG emissions reductions | The use of energy modelling, optimization, and real-time data analytics solutions that enables GHG emissions reductions by evaluating energy performance, providing actionable insights, and consolidating data from various systems | Climate Change Mitigation (CCM)
15) CE 4.1 Provision of IT/OT data-driven solutions | Deployment of advanced asset performance management solutions that enable real-time monitoring, data collection, and analysis of asset health and performance. These tools leverage AI- driven analytics to identify inefficiencies, predict potential failures, and provide early warnings to optimize maintenance activities and improve operational efficiency | Circular Economy (CE)

Non-Eligible Activities
Activities not listed in the Climate or Environmental Delegated Acts were classified as non‑eligible. These include
Refining, Supply & Trading, Petrochemicals, Fuels Marketing, Exploration & Production, and other supporting
activities (non-revenue generating activities). For greater details on the Group business activities, please refer to
Group Business Review.
13 The relevant economic sectors are based on the EU statistical classification of economic activities (NACE) codes data of the Group.

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2. Identification of Material Activities
Activities that are considered material by meeting the materiality exercise criteria
As previously mentioned, the Group has performed the eligibility assessment using the same approach as last
year. It has also collected the actual half-year and annual estimated financial data to perform a materiality
exercise in line with the EU “Omnibus I” updates to the EU Taxonomy requirements.
By considering the Group’s analysis for the Year End (2025) for the three EU Taxonomy KPIs (Turnover,
CAPEX, OpEx) the following activities were assessed in the alignment screening phase:
• CCM 4.1 Electricity generation using solar photovoltaic technology (derived from the Turnover, CapEX and
OpEx KPIs)
• CCM 4.3 Electricity generation from wind power (derived from the Turnover, CapEx and OpEx KPIs)
• CCM 4.10 Storage of electricity (derived from the Turnover and CapEx KPIs)
• CCM 4.29 Electricity generation from fossil gaseous fuels (derived from the OpEx KPI)
• CCM 8.1 Data processing, hosting and related activities (derived from the OpEx KPI).
For more information about the above activities as well as their assessment see next phase (3. Alignment
Screening – Substantial Contribution Criteria).
Activities that did not meet the materiality exercise criteria (non-material)
In the context of the EU Taxonomy rationale, the activities of the Group that did not meet the materiality criteria
are considered non-material for the Group’s business given the fact that they generate, in aggregate, less than
10% of the Group’s total Turnover, Capital expenditure (CapEx) or Operational Expenditure (OpEx), as defined by
the EU Taxonomy. Due to the fact that these activities fall cumulatively below this 10%, the Group chose not to
assess them in the alignment screening phase.
It is, however, noted that the Group appreciates the added value of the EU Taxonomy exercise and places special
emphasis on its continuity over time despite the changes that occur in the legislative plateau, which need to be
adhered. Therefore, in the context of providing useful and relevant information to its stakeholders and
maintaining a flexible momentum for tackling the challenges that may arise in the following years regarding the
EU Taxonomy reporting, the Group deems it important to provide summarized information regarding the
activities that did not proceed to the alignment screening phase.
The activities that did not meet the materiality exercise criteria are associated with the following sectors 13:
manufacture of chemicals and chemical products, computer programming, consultancy and related activities,
manufacture of coke and refined petroleum products, manufacture of plastics in primary forms, electricity, gas,
steam and air conditioning supply, water transport, warehousing and support activities for transportation, service
activities incidental to land transportation, real estate activities, rental and operating of own or leased real estate.

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The activities that did not advance to the alignment screening phase are listed below:
• CE 1.1 Manufacture of plastic packaging goods
The Group, through Diaxon SA, produces BOPP film, a versatile plastic packaging material widely utilized across
industries for applications such as food packaging, labelling, and industrial uses.
• CE 4.1 Provision of IT/OT data-driven solutions
Through its subsidiary HELLENiQ ENERGY Digital SA, the Group deploys IT/OT data-driven solutions, GE Vernova
Asset Management Performance (“APM”) software. These solutions support remote monitoring, predictive
maintenance, and operational performance optimization.
• CCM 3.14 Manufacture of organic basic chemicals
Part of the Group petrochemicals’ activities is the production of propylene as part of the propylene –
polypropylene – BOPP film product chain. The Group’s refinery in Aspropyrgos manufactures propylene. Part of
the propylene production supplies another Group’s activity that produces polypropylene as detailed below (3.17
Manufacture of plastics in primary form). For more details on the propylene production activities, please refer to
‘Group Business Review – Production and Trading of Petrochemicals’ of the Group Annual Financial Report 2025.
• CCM 3.17 Manufacture of plastics in primary form
As described above, the Group is also involved in the manufacture of plastics in primary form, specifically the
production of polypropylene located in Thessaloniki whose feedstock (i.e., propylene) is mainly supplied from the
Group’s refinery in Aspropyrgos. Similarly, part of the polypropylene produced is the raw material for the BOPP
film production unit in Komotini. For more details on our polypropylene production activities, please refer to
‘Group Business Review – Production and Trading of Petrochemicals’ of the Group Annual Financial Report 2025.
• CCM 4.9 Transmission and distribution of electricity
To support its renewable energy activities, HELLENiQ RENEWABLES, through Green Power Kilkis SMPC, is
engaged in the development, ownership, and operation of large-scale PV and electricity storage projects. The
company holds a Direct Line Management and Ownership License to act as a project operator for a high-voltage
(150-kV) electricity transmission line, connecting its PV projects to potential consumers. To enable this
interconnection, the company is involved in the construction of critical infrastructure, including high-voltage
(“HV”) substations and transmission lines.
• CCM 6.10 Sea and coastal freight water transport, vessels for port operations and auxiliary
activities
The Group owns tankers through its subsidiary shipping companies for the transport of fossil fuels. In addition to
the two vessels, the Group’s operational activities are also supported by chartered vessels. For more details on the
Group activities related to water transport, please refer to ‘Group Business Review - Refining, Supply and Trading’
of the Group Annual Financial Report 2025.
• CCM 6.15 Infrastructure enabling low-carbon road transport and public transport
The Group is actively contributing to the transition to low-carbon transportation through the development,
installation, and operation of EV charging infrastructure across its domestic and international operations.
In Greece, this activity is led by ElpeFuture, which has established a robust EV charging network. By end‑2025,
ElpeFuture had 160 fast chargers (320 points, 50–360 kW) at EKO and BP fuel stations, plus 418 AC chargers (544
points, 22–175 kW) at shopping centers, key buildings in Athens and Thessaloniki, and Group facilities. In 2026, the
Group plans to double DC chargers at fuel stations and triple AC chargers at other locations (22–180 kW).
Internationally, subsidiaries in Cyprus, Bulgaria, Serbia, Montenegro and Skopje operated 45 chargers (37 active) in
2025, including 26 installed that year, with 13 additional chargers planned for 2026. The activity primarily
supports the transition to low-carbon transportation by enabling the operation of battery-electric vehicles (BEVs),
plug-in hybrid electric vehicles (PHEVs), and e-buses.

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• CCM 7.6 Installation, maintenance and repair of renewable energy technologies
In addition to its large-scale renewable energy facilities for commercial purposes, the Group also installs and
operates small-scale PV systems across its facilities, primarily for self-consumption. For example, PV systems
have been installed on the rooftops of petrol stations, and significant progress has been made to expand these
installations further.
As of 2025, the Group has installed 111 rooftop PV systems across fuel stations in Greece, Cyprus, Bulgaria,
Montenegro, and the Republic of North Macedonia, with more installations planned in Serbia. Total installed
capacity reaches 3.44 MW, primarily used for self‑consumption, with surplus electricity exported to the grid.
OKTA additionally manages 0.5 MW of PV systems at four industrial customer facilities.
• CCM 7.7 Acquisition and ownership of buildings
The Group owns a few buildings intended for non-residential uses, including offices, control rooms and storage
rooms.
• CCM 8.2 Data-driven solutions for GHG emissions reductions
The Group, with the support from HELLENiQ ENERGY Digital SA, leverages Visual MESA, an energy optimization
modelling solution that enhances energy management systems to operate efficiently while simultaneously
reducing CO2 emissions based on financial impact and economic costs. The utilization of Visual MESA has been
expanded to cover all of the Group’s refinery facilities.

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3. Alignment Screening – Substantial Contribution Criteria
Next, each of the eligible activities (from the Group’s own operations) deemed material in the previous phase, were
analysed against the corresponding substantial contribution criteria (SCC) for the CCM objective, as outlined in the
Climate Delegated Act, the Environmental Delegated Act, and any relevant amendments. In respect to last year,
the two activities related to the CE objective (CE 1.1 Manufacture of plastic packaging goods and CE 4.1 Provision of
IT/OT data-driven solutions) did not meet the materiality exercise criteria hence they did not advance to the
alignment screening phase.
In summary, of the 222 eligible activities (from the Group’s own operations) corresponding to 15 EU Taxonomy-
defined activities, seventy-six (76) Group’s activities were found to meet the respective SCC for CCM objective
(corresponding to three (3) EU Taxonomy-defined activities).
The following sections provide an assessment of the economic activities that proceeded to the first step of the
alignment screening phase (i.e. the SCC).
Economic Activities in Renewable Energy Sources
4.1 Electricity generation using solar photovoltaic technology
Through its subsidiary HELLENiQ RENEWABLES, the Group operates photovoltaic (PV) plants with an aggregate
installed capacity of 395 MW. Between 2022 and 2024, the Group completed eighteen PV plants in Kozani and
one net-metering PV plant at the Megara oil facility, and acquired additional PV portfolios in Cyprus, Viotia (16
MW) and Kozani (109.9 MW), adding 167 MW of capacity. These plants have been operational since May 2022.
As of 2025, the Group has a significant development pipeline comprising 1.8 GW of stand-alone PV projects and
442 MW of hybrid PV-BESS projects in Greece, 138 MW of stand-alone PV and 186 MW of hybrid projects in
Romania, 123 MW of hybrid projects in Bulgaria, and 41 MW of hybrid projects in Cyprus. In December 2024,
HELLENiQ RENEWABLES also acquired a 109.9 MW PV portfolio in Kozani, which commenced commercial
operation in February 2025.
For more details on our solar energy activities, please refer to ‘Group Business Review - Renewable Energy
Sources (R.E.S.)’ section in this Annual Financial Report.
In addition, the Group operates a 12 MW PV plant at OKTA AD Skopje (Republic of North Macedonia), generating
approximately 17 GWh annually, of which around 7% is self-consumed, with the remainder supplied to the
national grid.
The SCC for Activity CCM 4.1 is described as “the activity generates electricity using solar PV technology”. All the
Group’s solar energy activities meet the SCC as they generate electricity using solar PV technology.
4.3 Electricity generation from wind power
In addition to solar energy, HELLENiQ RENEWABLES operates wind power assets, with a total installed capacity of
99.2 MW. Further information on wind power activities is provided in the ‘Group Business Review - Renewable
Energy Sources (R.E.S.)’ section of this Annual Financial Report.
The SCC for Activity CCM 4.3 is described as “the activity generates electricity from wind power”. All the Group’s
activities that involve electricity production from wind energy meet the SCC as they generate electricity from
wind power.
CCM 4.10 Storage of electricity
HELLENiQ RENEWABLES is also active in the development and construction of electricity storage projects. The
Group is currently constructing battery energy storage systems and developing pumped hydropower storage
facilities. Furthermore, additional projects, primarily focused on battery storage technology, are at the pre-
construction development stage.

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The SCC for Activity CCM 4.10 is defined as “the activity is the construction and operation of electricity storage,
including pumped hydropower storage”. All of the Group’s storage projects that are already in the construction
phase meet the SCC, as they involve the construction of electricity storage systems.
This economic activity can be categorized as an enabling activity where it complies with the technical screening
criteria in accordance with the Climate Delegated Act.
CCM 4.29 Electricity generation from fossil gaseous fuels
This activity concerns the construction or operation of electricity generation facilities that use fossil gaseous fuels.
The Group carries out such activities through its wholly owned subsidiary, Enerwave, which is one of the largest
independent power producers (IPPs) in Greece. Enerwave operates natural gas-fired combined-cycle power plants
with a total gross installed capacity of 851.6 MW, comprising a 430 MW plant in Thessaloniki (operational since
2005) and a 421.6 MW plant in Thisvi, Viotia (operational since 2010).
This activity does not meet the Substantial Contribution Criteria and therefore does not proceed to the
assessment of the “Do No Significant Harm” (DNSH) criteria. Specifically, Enerwave does not currently comply
with key SCC requirements related to greenhouse gas (GHG) emissions, including:
• Direct GHG emissions below 270 g CO₂e/kWh of output energy, or annual direct GHG emissions not
exceeding an average of 550 kg CO₂e/kW of facility capacity over a 20-year period; and
• Design and construction of facilities capable of using renewable and/or low-carbon gaseous fuels, with a
binding and verifiable plan approved by the management body to transition fully to such fuels by 31
December 2035.
Economic Activities in Other Sectors
CCM 8.1 Data processing, hosting and related activities
Through one of its subsidiaries, HELLENiQ ENERGY Digital SA, the Group is involved in database development
services and provision of IT application services. To support this activity, the Group operates data centers. To
comply with the substantial contribution criteria for Activity 8.1, the activity has to “(a) have implemented all
relevant practices listed as ‘expected practices’ in the most recent version of the European Code of Conduct on
Data Centre Energy Efficiency or in CEN-CENELEC document CLC TR50600-99-1 ‘Data center facilities and
infrastructures - Part 99-1: Recommended practices for energy management. The implementation of those
practices must be verified by an independent third-party and audited at least every three years” in addition to
meeting two other criteria.
It is not clear yet if the Group’s activities follow strictly all practices laid out in either the European Code of Conduct
on Data Centre Energy Efficiency or CEN-CENELEC document CLC TR50600-99-1 as it has not been verified by an
independent third party. Therefore, none of the Group’s activities related to data center operations has been
deemed as Taxonomy-aligned.
Regarding the use of air conditioning devices in data centers and the need to have refrigerants with specific
specifications (GWP<675), the Group has already started the process of defining the RFP for the replacement of
the devices in the two data centers due to their old age. The RFP will include the set Substantial Contribution
Criteria specifications and it is expected to be completed in the first half of 2026. Therefore, this activity does not
meet the SCC for CCM 8.1. This economic activity is categorized as a transitional activity where it complies with the
technical screening criteria in accordance with the Climate Delegated Act.

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4. Alignment Screening – Do No Significant Harm (DNSH) Criteria
For eligible activities that meet their respective SCC as identified in the previous phase, the Group applied the
guidance established in Article 17 of the Taxonomy Regulation and Climate Delegated Act and Environmental
Delegated Act to assess them against the relevant DNSH criteria. The following sections provide an assessment of
the economic activities that meet their respective DNSH criteria.
DNSH to Climate Change Mitigation (CCM)
Compliance with the DNSH criteria to CCM was not assessed as not applicable.
DNSH to Climate Change Adaptation (CCA)
DNSH criteria to CCA apply to all eligible activities that meet their respective substantial contribution criteria
corresponding to the following EU Taxonomy-defined Activities of the Group:
• CCM 4.1. Electricity generation using solar photovoltaic technology,
• CCM 4.3 Electricity generation from wind power, and
• CCM 4.10 Storage of electricity.
Appendix A of Annex I to Climate Delegated Act specifies the generic criteria for DNSH to climate change
adaptation. In brief, for all activities, the DNSH criteria to CCA require that “the activity:
• has identified material physical climate risks by performing a climate risk and vulnerability assessment;
• where relevant, has identified adaptation solutions that can reduce the identified physical climate risks”.
The climate risk and vulnerability assessment shall be proportionate to the scale of the activity and its expected
lifespan. Given that all of the relevant activities mentioned in this section have an expected lifespan of more than
10 years old, the assessment is performed using the highest available resolution climate projections at least 10-
to-30-year climate projection scenarios.
For additional or complementary information on the Group’s climate risk and vulnerability assessment, including
climate adaptation plans, refer to ‘C.1 General Disclosures - ESRS 2’ and to ‘ESRS E1 - Climate change’ sections.
DNSH to Sustainable Use and Protection of Water and Marine Resources (WTR)
DNSH criteria to WTR apply to EU Taxonomy-defined Activities of the Group:
• CCM 4.3 Electricity generation from wind power (in the case of offshore wind), and
• CCM 4.10 Storage of electricity.
DNSH criteria to WTR apply to CCM 4.3, but only in case of offshore wind. Given that the Group does not currently
operate or develop offshore wind farms, the DNSH criteria are not applicable.
For CCM 4.10, the DNSH criteria to WTR only apply in case of pumped hydropower storage. HELLENiQ
RENEWABLES SINGLE MEMBER SA is involved in pumped hydropower energy storage that is not connected to a
river body. The assessment of environmental degradation risks, including those related to water quality and
stress, are still in progress. Consequently, this activity does not yet meet the DNSH criteria for WTR objective.
For more information on the Group’s efforts related to the sustainable use and protection of water and marine
resources, please refer to ‘ESRS E2 – Pollution’ and ‘ESRS E3 - Water and Marine Resources’ section.

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DNSH to Transition to a Circular Economy (CE)
DNSH criteria to CE apply to EU Taxonomy-defined Activities of the Group:
• CCM 4.1. Electricity generation using solar photovoltaic technology,
• CCM 4.3 Electricity generation from wind power, and
• CCM 4.10 Storage of electricity.
For activities under CCM 4.1 and 4.3, the DNSH criteria require “the activity to assess availability of and, where
feasible, uses equipment and components of high durability and recyclability and that are easy to dismantle and
refurbish”. In line with the Group’s commitment to circular economy, for all of its renewable energy projects, the
Group ensures to use equipment and components of high quality, durability and recyclability. As part of the
project development, recyclability, durability, and other important criteria of materials required for fostering
circular economy were also examined. PV modules and wind turbines used in the renewable energy generation
activities are of high durability with an expected lifespan of 25-30 years as well as recyclable. End-of-life
treatments of the equipment used for these activities are described in the Environmental Terms of Operation and
are also considered following best practices suggested in relevant literature. The Group also considers recycling all
PV modules at their end of life.
For activities related to the construction of electricity storage facilities under CCM 4.10, the DNSH criteria in
essence require a waste management plan to ensure maximal reuse or recycling at the end of life in accordance
with the waste hierarchy. The Group’s activities include planning for the end-of-life treatment of equipment used
in these facilities, which has been integrated into pre-construction studies and follows best practices outlined in
relevant literature.
For HELLENiQ ENERGY Group, the utilization of materials and natural resources throughout their life cycle is an
important business opportunity and a response to its commitment to environmental stewardship. For further
details on the Group’s waste management and circular economy practices, please refer to ‘ESRS E5 - Resource
Use and Circular Economy’ section.
DNSH to Pollution Prevention and Control (PPC)
PPC is applicable to CCM 4.29 but since this activity did not pass the SCC criteria, the DNSH PPC requirements
were not examined.
For more information on the Group’s efforts related to the prevention and management of pollution, please refer
to ‘ESRS E2 - Pollution’ section.
DNSH to Protection and Restoration of Biodiversity and Ecosystems (BIO)
DNSH criteria to BIO apply to EU Taxonomy-defined Activities of the Group:
• CCM 4.1. Electricity generation using solar photovoltaic technology,
• CCM 4.3 Electricity generation from wind power, and
• CCM 4.10 Storage of electricity.
Appendix D of Annex I to the Climate Delegated Act specifies the generic criteria for DNSH for this environmental
objective. The DNSH criteria to BIO require that “the activity in question:
• has completed an EIA or screening in accordance with Directive 2011/92/EU or other equivalent laws or
standards for activities in third countries;

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• has implemented the mitigation and compensation measures for protecting the environment if required
based on the outcomes of the EIA; and
• for sites/operations located in or near biodiversity-sensitive areas (including the Natura 2000 network of
protected areas, UNESCO World Heritage sites and Key Biodiversity Areas, as well as other protected areas),
has conducted an appropriate assessment, where applicable, and has implemented the necessary mitigation
measures based on the conclusions of the assessment”.
As above, the Group does not operate any offshore wind, thus the DNSH criteria to this BIO specific for offshore
wind is not applicable. The Group is committed to adhering to regulations on the protection and restoration of
biodiversity and ecosystems, including conducting EIA where large infrastructure projects require it and
implementing standards on biodiversity protection across the business. All of the renewable energy projects that
also cover the electricity storage facilities under CCM 4.1, 4.3 and 4.10 in operation and currently under
development that are required to conduct an EIA have completed their respective EIAs in line with Directive
2011/92/EU. In a few cases, the conclusions of EIAs required specific mitigation and compensation measures for
protecting the environment. These too have been implemented accordingly.
Out of 68 operational PV and wind power sites, a few are located in and/or near biodiversity areas. For those
activities, the Group has carried out (or is currently conducting, for projects under development) appropriate
assessments in accordance with Directives 2009/147/EC, 92/43/EEC. Where the outcomes of the assessments
suggest necessary mitigation measures to protect the ecosystems and biodiversity, such measures have been
implemented. As of now, there have been no issues reported.
For more information on the Group’s efforts related to the protection of biodiversity and ecosystems, please refer
to ‘ESRS E4 – Biodiversity and Ecosystems’ section.
Summary of Alignment Screening

EU Taxonomy-defined Economic Activity | SCC Met?* | Rationale for meeting or not meeting the SCC | DNSH Met?*
CCM 4.1 Electricity generation using solar photovoltaic technology: Construction and operation of large-scale electricity production facilities from solar energy using PV systems | ✔ | The Group generates electricity using solar PV systems, including operational PV parks and ongoing projects under construction. | ✔
CCM 4.3 Electricity generation from wind power: Construction and operation of large-scale electricity production facilities from wind energy | ✔ | The Group generates electricity from wind power, including operational wind farms and ongoing projects under construction. | ✔
CCM 4.10 Storage of electricity: Construction of battery energy storage systems and pumped hydropower storage facilities to store electricity | ✔ | The Group is involved in the construction of electricity storage facilities. | ✔
CCM 4.29 Electricity generation from fossil gaseous fuel | ✘ | The Group’s production of electricity from natural gas-fired units did not meet the GHG emissions thresholds (neither the Life-cycle GHG emissions nor the the direct GHG emissions of the activity) | --
CCM 8.1 Data processing, hosting and related activities: Operation of data center | ✘ | The Group’s data center activities have not been verified by an independent third party against the required practices, and the cooling systems use non- compliant refrigerants (R-407c with GWP of 1,774). | --

* As noted previously, multiple economic activities can correspond to a single EU Taxonomy-defined Activity each assessed as a separate activity.
SCC assessments were conducted for all eligible economic activities, while DNSH assessments were carried out for those activities that met their
respective SCC criteria. In some cases, not all activities under the same EU Taxonomy-defined Activity fulfilled the criteria for SCC and/or DNSH.
Please refer to the denotations below for interpreting the summary table above.
✔ All assessed activities under the EU Taxonomy-defined Activity meet their respective SCC and/or DNSH criteria
✔ Only some of the assessed activities under the EU Taxonomy-defined Activity meet the SCC and/or DNSH criteria
✘ None of the assessed activities under the EU Taxonomy-defined Activity meet the SCC and/or DNSH criteria

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5. Alignment Screening – Minimum Social Safeguards
For additional or complementary information on the Group’s Due Diligence process and social safeguards, refer to
‘GOV-4, Statement of Due Diligence’ section.
Under Article 3 of the Taxonomy Regulation, an activity is "environmentally sustainable" only if the undertaking
complies with minimum safeguards (MS) defined in Article 18. Unlike technical screening criteria, MS compliance
is assessed at the entity level rather than the activity level.
The Group ensures alignment with the OECD Guidelines for Multinational Enterprises and the UN Guiding
Principles on Business and Human Rights, incorporating ILO core conventions and the International Bill of Human
Rights. Per Article 18(2), we also adhere to the "do no significant harm" (DNSH) principle regarding social
objectives under the SFDR.
Guided by the Platform on Sustainable Finance (PSF) October 2022 Report, the Group monitors four substantive
pillars: i) Human Rights, ii) Bribery and Corruption, iii) Taxation and iv) Fair competition.
The Group recognizes the PSF Report as informal best-practice guidance (Commission Notice 2023/C 211/01) and
continues to monitor evolving EU requirements to ensure ongoing compliance.
To ensure compliance with the Article 18(1) of the Taxonomy Regulation, the PSF Report suggests a two-
pronged approach consisting of two criteria.
Regarding Article 18(2), the recommendations suggested by the PSF Report is that companies with exposure to
controversial weapons are not able to count their activities as Taxonomy-aligned because of their non-compliance
with the ‘do no significant harm’ principle under the SFDR.

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The following section presents assessments on the Group’s compliance with the minimum
safeguards.
Human Rights
The Group is highly committed to upholding human rights in accordance with the relevant human rights and
labour legislation and standards (national, European, ILO). Within this endeavour, the Group maintains a process
to identify, assess and address actual or potential adverse human rights impacts that the Group may cause or
contribute to through its own activities, or which may be directly or indirectly linked to its operations, products, or
services by its business relationships.
The Group maintains the Code of Ethics as well as procedures that ensure the protection of human rights in
the conduct of its activities, as described more specifically below.
1. Embed a Commitment to Respect Human Rights into Policies and Procedures
HELLENiQ ENERGY embeds human rights into its core strategy through a Code of Conduct binding on all
employees and third parties. Updated in February 2025, the revised Code aligns established due diligence
practices with the Group’s Sustainability Policy and international standards. It covers critical areas including
human rights, anti-corruption, fair competition, and environmental stewardship.
To ensure global accessibility, the Code is published in Greek and English and all local languages of the Group’s
operational footprint. The Board of Directors provides high-level oversight, ensuring these values are integrated
into strategic decision-making and corporate culture.
As a signatory to the United Nations Global Compact (UNGC), the Group integrates the Ten Principles—covering
human rights, labor, environment, and anti-corruption—into its daily operations and value chain. This alignment
ensures that Group policies remain grounded in globally recognized ethical standards

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Effective implementation is driven by a comprehensive communication and education strategy: a) Mandatory E-
learning: Regular training modules for all staff, b) Onboarding: Dedicated sessions for new hires to instill ethical
standards from day one, c) Targeted Training: Face-to-face sessions for specialized groups to address specific
operational risks, d) Continuous updates are provided via the corporate intranet and annual Sustainability Reports
to maintain a culture of accountability and respect.
Moreover, consumer protection is an inherent part of the Group’s overarching strategy and business model with
policies, procedures and actions safeguarding the consumer and end-users’ rights. For more information on this
matter refer to ESRS S4 - Consumers and End-Users.
The subsequent sections detail the Group’s procedures for enacting this commitment.
2. Identify & Assess Adverse Human Rights Impacts
The Group employs a multi-layered approach to proactively identify and assess potential or actual adverse human
rights impacts across its operations and value chain. The 2025 Double Materiality Analysis (DMA) (see ‘IRO-1 -
Description of the Processes to Identify and Assess Material IROs B.1 Impact Materiality – "Inside-out" Approach’
section) concluded that the following areas have been identified as areas of human rights concern: “Own
Workforce – Managing hazards in high-risk industrial environments” and Affected communities - HELLENiQ
ENERGY’s production facilities posing risks of major accidents”. The Group continues to enforce robust
monitoring frameworks to proactively safeguard human rights throughout its operations:
i) Enterprise Risk & Internal Audit
• Annual Risk Assessment: For the 11th consecutive year, the Group Risk Management Division (GRMD)
integrated human rights into its strategic risk planning, evaluating labor practices and procurement risks.
• Audit Scope: In 2025, ten audits were conducted on social pillars, including Human Resources, Health &
Safety, and Procurement.
• Health & Safety: Occupational Risk Assessment Studies are mandatory for all operations. These identify
physical hazards and risks of violence or harassment, safeguarding employees' rights to health, safety, and
dignity.
ii) Supply Chain Due Diligence
• The Group monitors suppliers through specialized ESG and compliance platforms:
◦ Onboarding & Monitoring: The Moody’s GRID platform is used to screen for human rights incidents
during onboarding and provides real-time alerts for existing suppliers.
◦ EcoVadis Ratings: In 2024, the Group initiated EcoVadis ratings for Tier 1 suppliers to evaluate risks such
as forced labor and unsafe working conditions. These insights will inform future physical on-site audits.
iii) Stakeholder Engagement and Grievance
• Continuous Dialogue: The Group maintains two-way communication channels with employees, local
communities, and partners to capture real-time concerns.
• Workplace Feedback: Regular employee surveys and consultations assist in identifying issues related to
inclusion and working conditions.
• Reporting Channels: Open grievance mechanisms are available for employees and third parties to report
suspected human rights violations.
For more details on the processes for engaging with stakeholders, please refer to ‘S1-2 - Processes for Engaging
with Own Workforce and Workers’ Representatives about Impacts’, ‘S3-2 - Processes for engaging with affected

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communities about impacts’ ‘SBM 2 - Interest and views of stakeholders’, ‘S4-2 - Processes for Engaging with
Consumers and End-Users about Impacts’ sections.
3. Cease, prevent, mitigate and remediate adverse human rights impacts
HELLENiQ ENERGY prioritizes the prevention of human rights violations through rigorous policies, continuous
training, and proactive safeguards. When incidents occur, the Group acts decisively to implement corrective
measures and prevent recurrence.
Workforce Protection & Workplace Culture
• Anti-Harassment & Violence: In compliance with Law 4808/2021, the Group’s Anti-Harassment Policy
provides a framework for preventing and addressing workplace misconduct. Violations are met with prompt
corrective actions, including potential termination or legal proceedings.
• Labor Standards: The Group strictly adheres to EU and ILO standards, specifically prohibiting child labor in
accordance with Greek legislation (Laws 1837/1989, 3850/2010).
• Health & Safety: The health and safety of the Group's employees is at the top of its priorities. With the aim of
preventing and minimizing accidents and illnesses, HELLENiQ ENERGY implements best practices and
invests in the development and maintenance of a safe working environment. For more information
regarding this matter refer to ‘S1-1 - Policies Related to Own Workforce’ and ‘S1-4 - Taking Action on
Material Impacts on Own Workforce and Approaches to Managing Material Risks and Pursuing Material
Opportunities Related to Own Workforce and Effectiveness of those Actions’.
• Privacy and Data Rights: Recognizing privacy as a fundamental right, the Personal Data Protection Office
(PDPO) ensures GDPR compliance. This is further bolstered by a dedicated Cyber Security Office established
to protect stakeholder data from unauthorized access.
Training and Awareness
• Mandatory Education: Annual Code of Conduct training is compulsory for all employees.
• Scope: Training focuses on identifying inappropriate behavior, reporting mechanisms, and fostering an
inclusive environment to ensure ethical standards are embedded across all organizational levels
Supply Chain Integrity
• The Group Procurement Regulations integrate human rights into the supplier lifecycle:
◦ Selection & Exclusion: High-risk suppliers are excluded during the qualification phase via rigorous ESG
screening.
◦ Sustainability Pillars: Suppliers are evaluated against an Environmental & Social Framework based on
UNGC principles and the Greek Sustainability Code, covering labor rights, health and safety, and conflict
minerals.
The Group employs a rigorous, tech-enabled framework to ensure supply chain integrity and compliance
with the UN Global Compact (UNGC).
Selection and Evaluation Process
• Initial Screening: Suppliers undergo pre-qualification via the Moody’s GRID platform to ensure compliance
with human rights standards before entering the approved supplier list.

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• Contractual Compliance: All purchase orders and contracts include mandatory "compliance terms" requiring
adherence to UNGC principles, specifically regarding labor and human rights.
• Project-Specific Due Diligence: Targeted evaluations are conducted during tender processes for critical
projects to ensure alignment with specific risk profiles.
Continuous Monitoring and Remediation
• The HR and Procurement Divisions utilize SAP Ariba and Moody’s to provide real-time monitoring and
media alerts regarding human rights incidents, including forced or child labor.
• 2025 Performance: During the reporting period, all critical tenders were screened for Health & Safety
criteria; no significant findings or human rights violations were identified.
• Enforcement: The Group maintains a zero-tolerance approach to persistent non-compliance. Corrective
actions range from mandatory training and follow-up assessments to the termination of contracts and
removal from the approved supplier list.
Please refer to ‘Identifying, Assessing, and Remediating Negative Impacts’ within the ‘GOV-4 - Statement on Due
Diligence’ section for further details on additional taken by the Group to ensure human rights in operations and
supply chain are upheld. For details on processes to remediate negative impacts, including human rights impacts,
refer to ‘S1-3 - Processes to Remediate Negative Impacts and Channels for Own Workforce to Raise Concerns’,
‘S3-3 - Processes to Remediate Negative Impacts and Channels for Affected Communities to Raise Concerns’, and
‘S4-3 - Processes to Remediate Negative Impacts and Channels for Consumers and End-Users to Raise Concerns’
sections.
4. Track Implementation and Effectiveness of these actions
The Group systematically monitors, measures, and discloses metrics to evaluate the effectiveness of its efforts to
prevent, mitigate, and address adverse human rights impacts. These metrics are presented in the ‘Metrics &
Targets’ sections under ‘ESRS 1 - Own Workforce’, including key indicators such as those disclosed in ‘S1-14 -
Health and Safety Metrics’ and ‘S1-17 - Incidents, complaints, and severe human rights impacts’ sections. This
provides a clear framework for assessing the Group’s performance in managing human rights impacts.
5. Communicate How Adverse Human Rights Impacts Are Addressed
Additionally, the Group extends its commitment to transparency by reporting on human rights-related metrics in
its Annual Sustainability Report, GRI Disclosures Index table, and UNGC Communication on Progress (COP), as
summarized in the table (Minimum Safeguards Topics / HELLENiQ ENERGY Disclosures) presented at the end of
this section. These reporting mechanisms enable the Group to track progress, identify areas for improvement, and
demonstrate accountability to stakeholders by communicating how adverse human rights impacts are addressed.
6. Provide or cooperate in remediation inc., when appropriate
The sixth step of an adequate HRDD related to providing for or cooperating in remediation when appropriate. As
part of a broader revision of its corporate governance system to align with the latest legislative developments, the
Group has updated its Code of Conduct and adopted a whistleblowing policy in line with Law 4990/2022 and the
EU Whistleblowing Directive, requiring secure, confidential reporting channels and whistleblower protection. Since
April 2024, all Group companies and employees in Greece follow this policy, which allows employees, executives,
and partners to report EU law violations confidentially and without retaliation, using a secure online platform. In
specific, Cyprus and Montenegro apply the Group’s Whistle Blowing policy while Group companies in the Republic
of North Macedonia, Serbia and Bulgaria, have also implemented similar whistleblowing procedures per local laws.
The Code of Conduct outlines how to report concerns, including human rights issues, to the Group Regulatory
Compliance Service. Additionally, the Anti-Harassment Policy provides clear processes for reporting and resolving
workplace violence and harassment.

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The Group maintains multiple communication channels for stakeholders, including employees, business partners,
and customers, to report grievances, including those related to human rights. Employees can use official channels
like whistleblowing and specific reporting systems for violence and harassment. External stakeholders have
access to grievance mechanisms via email, online platforms, telephone, and fax, all listed on the Group’s website,
Reports & Compliance | HELLENiQ ENERGY.
In FY2025, neither HELLENiQ ENERGY nor its subsidiaries were found liable for breaches of human rights, labor,
consumer protection, data protection, or criminal laws, nor were there incidents of non-compliance,
discrimination, or labor disputes. No cases were raised by the OECD National Contact Point or the Business &
Human Rights Resource Centre against the Group or its subsidiaries in the past three years. Please refer to ‘S1-17 -
Incidents, complaints and severe human rights impacts’ section for further details.
Bribery and Corruption
The Group is committed to conducting business in the most ethical manner and has a zero-tolerance policy
toward bribery and corruption of any type. As mentioned above, anti-corruption and bribery policies are covered in
the Group Code of Conduct. Further, the internal structure and corporate governance framework of the Group
companies are designed with robust safeguards to prevent corruption. These include checks and balances such as
dual-person partnerships for decision-making, mandatory internal approvals, and regular audits to ensure
transparency and compliance with anti-corruption policies. Please refer to ‘Corruption’ within the ‘GOV-4 -
Statement on Due Diligence’, G1-3 – Prevention and Detection of Corruption and Bribery” and “G1-4 – Incidents of
Corruption or Bribery” sections for further details of the Group’s internal controls, ethics and compliance
programs, and measures for preventing and detecting corruption and bribery.
Another key control in the Group’s anti-corruption framework is its Whistleblowing Policy, as described in the
‘Human Rights’ above. This policy provides secure and confidential channels for reporting concerns related to
bribery, corruption and money laundering. Reports are handled with strict confidentiality, protecting
whistleblowers from retaliation and ensuring proper follow-up and investigation. The policy’s dedicated platform
allows both employees and external stakeholders to raise concerns, strengthening the Group’s ability to address
bribery and corruption risks promptly and effectively.
As part of its annual audit program, the Internal Audit Division integrates compliance considerations, including
corruption-related risks, into its planning and execution. Corruption issues are systematically evaluated during
audits across the Group’s operations. In 2025, the Group’s organizational units were screened for corruption-
related risks using a standardized internal inspection process aligned with the Group’s Code of Conduct. These
audits did not reveal any significant deviations from the Group’s Policies, Regulations, or Procedures, reflecting
the effectiveness of the Group’s compliance framework.
During FY2025, HELLENiQ ENERGY or its senior management, including its subsidiaries and their senior
management, has not been convicted on corruption or bribery. Further, no incident of corruption was reported to
the Regulatory Compliance Office or to the Management of the Group’s companies. As stated in the ‘Corruption’
within the GOV-4 - Statement on Due Diligence section, during 2025, no incident of corruption was reported to
the Regulatory Compliance Office or to the Management of the Group’s companies and there were zero monetary
loss due corruption incidents.
Taxation
The Group prioritizes full compliance with tax laws in all jurisdictions, treating tax governance as a key part of its
oversight. For UK operations, it publishes an annually updated UK Tax Strategy Report, applicable across all
entities, with the 2025 version already in effect.
• The Group Tax & Customs Department (GT&CD) centrally manages tax and customs compliance, regularly
monitoring and reporting to senior management. GT&CD’s main responsibilities include ensuring
compliance, coordinating with authorities and auditors, confirming tax aspects through annual audits and
certificates, advising on tax issues, adapting to regulatory changes, and overseeing tax planning and audits.
It also explores opportunities for tax benefits under incentive laws.

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• GT&CD acts as the Group’s tax advisor, staying updated on regulatory developments, participating in
relevant committees, and optimizing tax cash flows and refunds. The Group’s governance includes secure,
confidential channels for reporting suspected tax violations, as outlined in its Whistleblowing Policy, which
protects anonymity and prevents retaliation.
• Through these measures, the Group maintains transparency, compliance, and effective risk management,
aligning with OECD Guidelines for multinational enterprises.
During FY2025, neither HELLENiQ ENERGY nor any of its subsidiaries were identified as having violated any
applicable tax laws, nor were they found guilty of tax evasion, including but not limited to instances of tax
avoidance arising from aggressive tax planning strategies. Furthermore, it is highlighted that tax and customs
compliance is confirmed again in FY2025.
Fair Competition
Since 2018, the Group has implemented a Competition Policy and Compliance Manual, reflecting its commitment
to comply with Greek and European competition laws, as well as the national laws of the countries where it
operates. This Policy aims to assist the Group’s management, executives, and employees in understanding the
fundamental rules of fair competition and how these rules impact the Group’s daily operations and business
practices.
To ensure alignment with legislative developments, the Competition Policy and Compliance Manual were revised
in September 2023, incorporating recent changes in legislation and the latest guidelines issued by the
Competition Commission. These revisions reinforce the Group’s dedication to adhering to competition laws to
support its sustainable development and enhance its overall competitiveness while also mitigates the risk of
severe sanctions and reputational damage that may result from violations of fair competition practices.
Fair competition is a dedicated section in the Group’s Code of Conduct, which is provided to all employees and
serves as a key resource for promoting compliance. As part of the Group’s annual training program on the Code of
Conduct, all employees including senior management, receive training on fair competition principles, ensuring
they understand their responsibilities and the importance of compliance.
The Group’s Whistleblowing Policy, as outlined in the above sections, also applies to violations of competition
laws. This policy provides secure and confidential channels for employees, executives, and external stakeholders
to report potential breaches of competition laws, ensuring protection against retaliation, and appropriate follow-
up and investigation of allegations.
In FY2025, HELLENiQ ENERGY and its subsidiaries including their senior management, were not found in breach
of competition laws, nor were they convicted or involved in court appeals related to anti-competitive or monopoly
practices. The Group remains compliant with relevant competition and consumer protection laws. As stated in the
‘Identifying, Assessing, and Remediating Negative Impacts’ within the ‘GOV-4 - Statement on Due Diligence’
section, the Group has maintained full compliance with legislation on unfair competition.
Regarding the compliance with the ‘do no significant harm’ principle of the SFDR, in addition to the above
discussion, the Group confirms that it does not have any exposure to controversial weapons, meaning it does not
finance, produce, or provide products or services that contribute to the development, manufacture, sale, or
distribution of such weapons.
As minimum safeguards criteria apply at the undertaking level, it was possible to map the Group’s corporate
disclosures with the four core topics. Please refer to the following for further details on the Group’s alignment with
the minimum safeguards criteria.

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Minimum Safeguards Topics | HELLENiQ ENERGY Disclosures
Human Rights | • 2024 GRI Sustainability Standards: 2-23, 2-27, 406-1, 409-1, 407-1, 408-1, 410-1, 414-1, 414-2 • 2024 UNGC Communication of Progress Report: Human Rights and Labour • 2025 Annual Financial Report - C.1 Sustainability Statement: GOV-4 – Statement on Due Diligence, IRO-1 - Description of the Processes to Identify and Assess Material IROs ‘B.1 Ιmpact Μateriality – "Inside-out" Approach’, S1-3, S1-17, S3-2, S3-3, S4-3, ESRS S1 – Own Workforce ‘Metrics and Targets’, ESRS S3 – Affected Communities ‘Metrics and Targets’, ESRS S4 – Consumers and End-Users ‘Metrics and Targets’
Corruption | • 2024 GRI Sustainability Standards: 2-23, 2-27, 205-1, 205-2, 205-3 • 2024 UNGC Communication of Progress Report: Anti-corruption • 2025 Annual Financial Report - C.1 Sustainability Statement: GOV-4 – Statement on Due Diligence ‘Corruption’
Taxation | • 2024 GRI Sustainability Standards: 2-27, 207-1, 207-2, 207-3, 207-4
Fair Competition | • 2024 GRI Sustainability Standards: 2-23, 2-27, 206-1 • 2025 Annual Financial Report - C.1 Sustainability Statement: GOV-4 – Statement on Due Diligence ‘Identifying, Assessing, and Remediating Negative Impacts’

Enerwave
It is noted that on 15 July 2025 Enerwave (Elpedison) has become a fully owned subsidiary of the Group with the
Group’s management exercising full control over its operations.
Enerwave already applies a Code of Ethics which addresses, amongst others, compliance with anti-trust laws,
fairness and honesty, human rights - diversity and inclusion, discrimination and harassment in the workplace,
integrity – transparency, Anti-Money Laundering etc.
Moreover, Enerwave applies an Employee Code of Conduct tackling matters such as the recruitment process,
employee training, employee rights and benefits, obligations of employees during their work, rules of
Administrative Conduct, disciplinary audits, regulations and disciplinary offences and sanctions. Enerwave
provides a Whistleblowing portal to its employees, business partners and stakeholders for them to report any
unethical behavior, potential breaches of the law or/and its internal Policies and Codes. This is accompanied by a
Procedure for Reporting and Handling Alleged Violations of Enerwave Codes.
Enerwave is in the process of gradually aligning its policies and practices with those of the Group, to the extent
applicable.

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6. Calculation of Financial KPIs
The Disclosures Delegated Act particularly in Annex I (KPIs of non-financial undertakings) specifies three KPIs to
be disclosed regarding the proportion of the Taxonomy-eligible and Taxonomy-aligned activities of the Group to
its total activities. Namely, these KPIs are Turnover, Operating Expenses (Opex) and Capital Expenditure (CapEx).
The policies used in deriving the respective amounts used in these KPIs are the following:
Turnover KPI (%): Ta/Tt
Ta as numerator represents the net turnover derived from products or services, including intangibles, associated
with Taxonomy-eligible and Taxonomy-aligned activities for eligible turnover and aligned turnover, respectively.
Tt as denominator represents the net turnover of the Group.
The Group's consolidated net turnover can be reconciled to the consolidated financial statements (please refer to
the Consolidated Statement of Comprehensive Income on this Annual Financial Report 2025 Revenue from
contracts with Customers).
To avoid double counting in the allocation in the numerator of turnover across economic activities, the figures
used have eliminated intercompany transactions.
CapEx KPI (%): Ca/Ct
Ca represents additions to tangible and intangible assets made during the year before depreciation, amortization
and any remeasurements, including those resulting from the revaluations and impairments for the relevant
financial year and excluding fair value changes.
Ct represents additions to tangible and intangible assets made during the year before depreciation, amortization
and any remeasurements including those resulting from the revaluations and impairments for the relevant
financial year and excluding fair value changes.
Capital Expenditure amounts are calculated as defined by IFRS, namely IAS 16 “Property, Plant and Equipment”,
IAS 38 “Intangible Assets”, IAS 40 “Investment Property” and IFRS 16 “Leases”. As mentioned above, due to the
company structure of the Group, the Taxonomy-eligible and Taxonomy-aligned Capital Expenditure can be
obtained from the accounting records of these entities. For 2025, the Taxonomy-eligible and Taxonomy-aligned
Capital Expenditure includes the Capital Expenditure for the acquisition of eligible and aligned activities,
respectively. The total Capital Expenditure of the Group is obtained from the audited Consolidated Group Financial
Statements.
The Group's total CapEx can be reconciled to the consolidated financial statements of the 2025 Annual Financial
Report (Note 6 “Property, Plant and Equipment”, Note 7 “Right of Use Asset” and Note 8 “Intangible Assets” ) as
well as on the Consolidated Statement of Cash flows. The aforementioned are the summation of the movement
types (acquisition and production costs), additions and additions from business combinations to tangible and
intangible assets, right-of-use assets and property, plant and equipment. Please note that leases that do not lead
to the recognition of a right-of-use over the asset shall not be counted as CapEx.
To avoid double counting in the allocation in the numerator of CapEx across economic activities, the figures have
eliminated intercompany transactions.

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OpEx KPI (%): Oa/Ot
Oa represents direct, non-capitalised costs that relate to research and development, building renovation
measures, short-term lease, maintenance and repair, and any other direct expenditures relating to the day-to-day
servicing of assets of property, plant and equipment by the undertaking or third party to whom activities
necessary to ensure the continued and effective functioning of such assets are outsourced.
Ot represents direct, non-capitalised costs that relate to the day-to-day servicing of assets of property, plant and
equipment by the Group or third-party to whom activities necessary to ensure the continued and effective
functioning of such assets are outsourced. These costs can relate to research and development, building
renovation measures, short-term leases, repair and maintenance.
Operating Expenses are not specifically defined under IFRS. Therefore, the amounts used in Oa and Ot are defined
in the Disclosures Delegated Act. To determine Oa the accounting records of the entities who have Taxonomy-
eligible or Taxonomy-aligned activities were used, while for Ot the audited Consolidated Financial Statements
formed the basis of calculation. The costs included in the Operating Expenses KPI primarily involve cleaning, repair
and maintenance expenses. Expenses such as overheads, electricity and cost of employees operating the assets
are excluded from both Oa and Ot. The Taxonomy related OpEx is included in the Consolidated Statement of
Comprehensive Income, which is part of this Annual Report 2025.
To avoid double counting in the allocation in the numerator of OpEx across economic activities, the figures have
eliminated intercompany transactions. In addition, research and development costs and other expenses already
accounted for in the CapEx KPI are not counted as OpEx.
The Group's Turnover, CapEx and OpEx KPIs are presented in the ‘Overall Results of KPIs’ section below.

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Overall Results of EU Taxonomy Assessment
Following the completion of eligibility and alignment screening for all of the Group's activities, as discussed in the
“Process for Analyzing the Group’s Business Activities” section, the following is a summary of the results.

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More detailed disclosures of the three
KPIs are provided below

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Proportion of Turnover, CapEx, OpEx from products or services associated with Taxonomy-eligible or Taxonomy-aligned economic activities – disclosure covering year 2025 (summary KPIs)

Financial year | 2025 |  | Breakdown by environmental objectives of Taxonomy aligned activities |  |  |  |  |
KPI | Total | Proportion of Taxonomy eligible activities | Taxonomy aligned activities | Proportion of Taxonomy aligned activities | Climate Change Mitigation | Climate Change Adaptation | Water | Circular Economy | Pollution | Biodiversity | Proportion of enabling activities | Proportion of transitional activities | Not assessed activities considered non-material | Taxonomy aligned activities in previous financial year (2024) | Proportion of Taxonomy aligned activities in previous financial year (2024)*
| € million | % | € million | % | % | % | % | % | % | % | % | % | % | € million | %
Turnover | 11,614.64 | 0.62% | 72.23 | 0.62% | 0.62% | —% | —% | —% | —% | —% | —% | —% | 4.04% | 58.66 | 0.46%
CapEx | 574.25 | 27.65% | 148.39 | 25.84% | 25.84% | —% | —% | —% | —% | —% | 1.27% | —% | 4.93% | 155.79 | 35.86%
OpEx | 171.05 | 34.54% | 19.11 | 11.17% | 11.17% | —% | —% | —% | —% | —% | —% | —% | 1.62% | 7.16 | 7.21%

(*) It is noted that the previous financial year KPIs (FY2024) were calculated in accordance with the reporting requirements of the Disclosures Delegated Act that was applicable before the amendments introduced by the Omnibus Delegated Act.
Proportion of Turnover from products or services associated with Taxonomy-eligible or Taxonomy-aligned economic activities – disclosure covering year 2025 (activity breakdown)

Reported KPI | Turnover |  |  |  |  |  |  |  |  |  |  |  |
Financial year | 2025 |  | Environmental objectives of Taxonomy aligned activities |  |  |
Economic Activities | Code | Taxonomy eligible KPI (Proportion of Taxonomy eligible Turnover) | Taxonomy aligned KPI (monetary value of Turnover) | Taxonomy aligned KPI (Proportion of Taxonomy aligned Turnover) | Climate Change Mitigation | Climate Change Adaptation | Water | Circular Economy | Pollution | Biodiversity | Enabling activity | Transitional activity | Proportion of Taxonomy aligned in Taxonomy eligible
|  | % | € million | % | % | % | % | % | % | % | (E where applicable) | (T where applicable) | %
Electricity generation using solar photovoltaic technology | CCM 4.1 | 0.40% | 46.53 | 0.40% | 0.40% | -% | -% | -% | -% | -% | — | — | 100.00%
Electricity generation from wind power | CCM 4.3 | 0.22% | 25.70 | 0.22% | 0.22% | -% | -% | -% | -% | -% | — | — | 100.00%
Storage of electricity | CCM 4.10 | —% | 0.00 | —% | —% | -% | -% | -% | -% | -% | E | — | —%
Sum of alignment per objective |  |  |  | 0.62% | -% | -% | -% | -% | -% |  |  |
Total KPI (Turnover) | 0.62% | 72.23 | 0.62% | 0.62% | -% | -% | -% | -% | % | —% | — | 99.99%

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Proportion of CapEx from products or services associated with Taxonomy-eligible or Taxonomy-aligned economic activities – disclosure covering year 2025 (activity breakdown)

Reported KPI | CapEx |  |  |  |  |  |  |  |  |  |  |  |
Financial year | 2025 |  | Environmental objectives of Taxonomy aligned activities |  |  |
Economic Activities | Code | Taxonomy eligible KPI (Proportion of Taxonomy eligible CapEx) | Taxonomy aligned KPI (monetary value of CapEx) | Taxonomy aligned KPI (Proportion of Taxonomy aligned CapEx) | Climate Change Mitigation | Climate Change Adaptation | Water | Circular Economy | Pollution | Biodiversity | Enabling activity | Transitional activity | Proportion of Taxonomy aligned in Taxonomy eligible
|  | % | € million | % | % | % | % | % | % | % | (E where applicable) | (T where applicable) | %
Electricity generation using solar photovoltaic technology | CCM 4.1 | 3.69% | 20.86 | 3.63% | 3.63% | -% | -% | -% | -% | -% | —% | —% | 98.52%
Electricity generation from wind power | CCM 4.3 | 20.94% | 120.26 | 20.94% | 20.99% | -% | -% | -% | -% | -% | —% | —% | 100.00%
Storage of electricity | CCM 4.10 | 3.02% | 7.27 | 1.27% | 1.27% | -% | -% | -% | -% | -% | E | —% | 41.88%
Sum of alignment per objective |  |  |  | 25.84% | -% | -% | -% | -% | -% |  |  |
Total KPI (CapEx) | 27.65% | 148.39 | 25.84% | 25.84% | -% | -% | -% | -% | % | 1.27% | —% | 93.45%

Proportion of OpEx from products or services associated with Taxonomy-eligible or Taxonomy-aligned economic activities – disclosure covering year 2025 (activity breakdown)

Reported KPI | OpEx |  |  |  |  |  |  |  |  |  |  |  |
Financial year | 2025 |  | Environmental objectives of Taxonomy aligned activities |  |  |
Economic Activities | Code | Taxonomy eligible KPI (Proportion of Taxonomy eligible OpEx) | Taxonomy aligned KPI (monetary value of OpEx) | Taxonomy aligned KPI (Proportion of Taxonomy aligned OpEx) | Climate Change Mitigation | Climate Change Adaptation | Water | Circular Economy | Pollution | Biodiversity | Enabling activity | Transitional activity | Proportion of Taxonomy aligned in Taxonomy eligible
|  | % | € million | % | % | % | % | % | % | % | (E where applicable) | (T where applicable) | %
Electricity generation using solar photovoltaic technology | CCM 4.1 | 8.26% | 14.13 | 8.26% | 8.26% | —% | —% | —% | —% | —% | —% | —% | 100.00%
Electricity generation from wind power | CCM 4.3 | 2.91% | 4.98 | 2.91% | 2.91% | —% | —% | —% | —% | —% | —% | —% | 100.00%
Production of electricity from natural gas-fired units | CCM 4.29 | 7.55% | — | —% | —% | —% | —% | —% | —% | —% | —% | —% | —%
Operation of data centers | CCM 8.1 | 15.82% | — | —% | —% | —% | —% | —% | —% | —% | — | — | —%
Sum of alignment per objective |  |  |  | 11.17% | —% | —% | —% | —% | —% |  |  |
Total KPI (OpEx) | 34.54% | 19.11 | 11.17% | 11.17% | —% | —% | —% | —% | —% | —% | —% | 32.34%

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Additional Information
Contribution to multiple objectives
The Group has not identified any economic activities that contribute to multiple environmental objectives. As
outlined in the ‘Eligibility Screening’ section, the Group has only identified economic activities that contribute to
CCM and CE objectives. None of these activities have been identified as contributing to both objectives
simultaneously.
Furthermore, as previously mentioned, while certain Taxonomy-aligned activities for CCM could technically also
be considered Taxonomy-eligible for CCA as adapted activities—since they meet the DNSH criteria for CCA (which
align with the Taxonomy-eligibility criteria for CCA adapted activities)—the Group has classified those activities as
Taxonomy-non-eligible for CCA. For more details, please refer to the ‘Eligibility Screening’ section.
Contextual Information
It is noted that, where mentioned in the contextual information below, the previous financial year KPIs (FY2024)
were calculated in accordance with the reporting requirements of the Disclosures Delegated Act that was
applicable before the amendments introduced by the Omnibus Delegated Act.
Contextual Information about the turnover KPI
Based on the Turnover indicator, 4.66% of Turnover corresponded to eligible economic activities (of which 0.62%
were assessed for alignment and 4.04% were not assessed as it related to non-material activities) and 0.62%
were eligible-aligned CCM activities in 2025. The numerator mainly includes turnover generated from contracts
with customers. The turnover from eligible-aligned activities increased in 2025 compared to 2024, primarily
because of the increase in electricity production from RES. The Group’s turnover associated with electricity
production from PV parks reached €46.5 million in 2025 (vs €31 million in 2024), while the respective figure
associated with electricity production from wind parks amounted to €25.7 million (vs €27 million in 2024).
Contextual Information about the CapEx KPI
Based on the CapEx indicator, 32.66% of CapEx corresponded to eligible economic activities (of which 27.72%
were assessed for alignment and 4.94% were not assessed as it related to non-material activities) and 25.90%
were eligible-aligned CCM activities in 2025. CapEx amounts primarily include additions to property, plant and
equipment and intangible assets. As part of its energy transition, the implementation of the Group’s strategic plan
involves developing a new pillar in RES and expanding in renewable fuels, with a growing share of annual capital
expenditures directed towards eligible-aligned activities over the next years. The Group’s eligible-aligned CapEx in
2025 amounted to €148 million and mainly relates to the RES projects under development in Greece and
Southeastern Europe.
Contextual Information about the OpEx KPI
Based on the OpEx indicator, 36.16% of the OpEx corresponded to eligible economic activities (of which 34.54%
were assessed for alignment and 1.62% were not assessed as non-material activities) and 11.17% were eligible-
aligned CCM activities in 2025. The amount spent in eligible-aligned activities increased in 2025 compared to
2024, primarily because of the increase in the RES operational capacity. The Group’s OpEx associated with
electricity production from PV parks reached €14.1 million in 2025 (vs €2.8 million in 2024), while the respective
figure associated with electricity production from wind parks amounted to €5 million (vs €3.2 million in 2024).

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ESRS E1 - Climate Change
Strategy
E1-1 - Transition Plan for Climate Change Mitigation
HELLENiQ ENERGY Group responds to changes in the energy sector by implementing a strategic plan focused on
modernizing its operations and expanding renewable energy sources. Through the VISION 2030+ strategic plan,
the Group responds to the rapidly evolving energy landscape by prioritizing the targeted growth and resilience of
its hydrocarbons portfolio, maintaining strategic flexibility in sustainable fuels, and transforming the Power
Business into an autonomous, vertically integrated platform. The targets that have been set, as presented in
section “E1-4 – Targets Related to Climate Change Mitigation and Adaptation”, are directly linked to the UNSDGs
and focus on reducing the carbon footprint and achieving climate neutrality by 2050, in line with the national
strategy and legislation. [ESRS E1-16 (a), AR 2]
Decarbonization levers and actions
HELLENiQ ENERGY Group directs its investments towards strategies that enhance the sustainable production
and use of energy within its conventional operations, focusing on energy efficiency and energy savings,
investment in carbon capture technologies, as well as the development of technologies and production of low-
carbon fuels (such as blue and green hydrogen, biofuels and synthetic fuels). At the same time, it promotes RES,
alongside the development of energy storage solutions, as well as e-mobility solutions and infrastructure.
More specifically, the Group’s decarbonization levers include the following:
• Renewable Energy Production and Storage
• Participation in Research Programs
• Sustainable Mobility – SAF and E-mobility (ELPEFuture / EKO Charge&Go)
Further information regarding the actions under each of the Group’s decarbonization levers is available in
subsection “E1-3 – Actions and Resources in Relation to Climate Change Policies”.
Capex and Opex expenditures aligned with the EU Taxonomy relate to activities such as electricity generation
from photovoltaic and wind energy sources, as well as electricity storage in battery systems. For the period 2026–
2030, investments related to decarbonization actions, the development of technologies and production of low-
carbon fuels, as well as the further expansion of the Group’s presence in RES, are expected to exceed €1 billion.
[ESRS E1-3-29-(a)], [ESRS E1-1-16-(c)]
The effective implementation of the investment plan is supported by the completion of the reorganization of the
corporate structure and the strengthening of corporate governance, as a result of initiatives undertaken in
previous years, including the integration of sustainability criteria into Management decision-making and variable
remuneration incentives.
The implementation of the RES investment plan is further facilitated by the existence of a flexible financing
framework of up to €766 million, which provides adequate financial resources to support RES growth, along with
flexibility, speed of execution, a strong governance and risk management framework, and favorable financing
terms that offer a competitive advantage.
At the same time, the Group supports sustainable mobility by promoting initiatives that reshape the energy mix in
the transport sector and strengthen the transition to a low-carbon economy. For additional actions related to
climate change mitigation and decarbonization across the value chain, please refer to the sections “Energy
Production and Storage from Renewable Sources” and “Participation in Research Projects”. [ESRS E1-1-16-(b)]

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Locked-in GHG Emissions Assessment
The potential locked-in GHG emissions of HELLENiQ ENERGY Group arising from the operations of its three
refineries are not expected to jeopardize the achievement of its broader GHG emission reduction targets. This is
because the Group is committed to improving the efficiency of its operations through its strategic transformation
plan. By focusing on sustainable practices, enhancing processes and investing in innovative technologies, such as
carbon capture and storage, the Group aims to reduce its overall environmental footprint, ensuring that its
emission reduction targets remain achievable regardless of any challenges that locked-in emissions may pose.
[ESRS E1-1-16-(d)]
HELLENiQ ENERGY Group strengthens its commitment to sustainable development and climate change
mitigation by integrating these targets into its strategy. Within the context of its transformation, the strategic
plan focuses on expanding green energy activities, with an increasing share of annual capital expenditure
allocated to activities aligned with the eligibility criteria in the coming years. The EU Taxonomy Report discloses
the eligibility and alignment of activities with the Climate Change Mitigation Target.
The development of a significant RES portfolio remains a priority, diversifying the Group’s energy profile and
contributing to the reduction of GHG emissions. Intermediate targets include 1.5 GW of installed RES capacity by
2028 and more than 2 GW by 2030. Investments cover photovoltaic and wind projects, as well as energy storage
(Battery Energy Storage Systems (BESS) and pumped hydro storage), while a substantial expansion of the e-
mobility network is also planned within the fuel retail network and at third-party points of interest. [ESRS E1-1-16-(e)]
During the financial year 2025, significant CapEx for coal-, natural gas- and oil-related activities reached € 363
million. [ESRS E1-1-16-(f), AR 5]
HELLENiQ ENERGY Group operates extensively in the oil and natural gas sector and, for this reason, is exempt
from EU benchmarks aligned with the Paris Agreement, as defined in Commission Delegated Regulation (EU)
2022/2453, which includes provisions related to climate change transition risks. This regulation sets the criteria
for companies that do not comply with the climate targets of the Paris Agreement. Nevertheless, HELLENiQ
ENERGY Group maintains alignment with the transition to a carbon-neutral economy. Specifically, the Group
implements the provisions of Articles 12.1 (d) to (f), which relate to disclosure obligations and the adoption of
procedures for transitioning to a lower-carbon environment, as well as Article 12.2, which establishes the
conditions for determining the suitability of a benchmark in relation to climate criteria that ensure long-term
sustainability. [ESRS E1-1-16-(g)]
The strategic plan of the HELLENiQ ENERGY Group is fully integrated and aligned with its overall business
strategy and financial planning, and has been approved by the BoD. To date, significant milestones have been
achieved, including: a) enhanced corporate governance, with appropriate policies for the election of the Board of
Directors, improved diversity, and independence; b) an optimized corporate structure; c) a new corporate identity;
d) the implementation of energy efficiency and energy- saving and autonomy projects, as well as the maturation
of investment options aimed at reducing carbon emissions and promoting RES investments, with projects 0.5 GW
of projects in operation by the end of 2025 and an additional 1 GW of projects under development, targeting
commissioning by the end of 2028; e) the streamlining of the Power and Gas portfolio through the full integration
of Enerwave (formerly ELPEDISON) into the Group. [ESRS E1-1-16-(h)-(i)-(j)]
ESRS E1 SBM-3 - Material IROs and their Interaction with Strategy and Business
Model
HELLENiQ ENERGY Group recognizes the urgent challenges posed by climate change and the need for energy
efficiency, and is committed to addressing and managing these issues. In this context, potential risks,
opportunities, and related financial impacts are examined in detail over the short-, medium-, and long-term time
horizons, taking into account both climate change mitigation and adaptation.
This year, for the second time, the Group discloses climate-related risks and opportunities for the financial year
2025, following the guidelines of the ESRS, aims to accelerate its decarbonization efforts while simultaneously
enhancing transparency and accountability to stakeholders, with the objective of maintaining the resilience of its
strategy and business model.

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The most significant climate risks identified span all time horizons and affect all areas of activity, particularly those
related to liquid fuels and chemical products. These risks include extreme weather events such as wildfires, floods,
sea-level rise, heatwaves, high winds, and snow, as well as pressures on water resources. In summary, these are
factors that can cause damage to energy infrastructure (such as wind turbines, oil rigs, pipelines, and solar panels),
disrupt electricity supply, create challenges in road transport, disturb supply chains and employee mobility, reduce
efficiency in solar and wind energy production, increase operating costs due to higher cooling demands, and limit
employee productivity due to heat stress.
The financial impacts and associated risks linked to HELLENiQ ENERGY Group’s business model have been
assessed and integrated into its overall sustainable development strategy. Some of the main risks identified
include ongoing technological developments and the declining cost of RES, which intensify competition in the
energy market among oil and gas companies, potentially reducing demand for fossil fuel products. The oil and gas
industry contributes significantly to global emissions and is therefore highly exposed to carbon pricing, both
directly and indirectly. Higher carbon prices will increase the cost of emissions, which may influence operational
decisions and potentially affect profitability. Additionally, the expansion of the EU ETS to cover emissions from
transport and heating is expected to indirectly accelerate the shift in consumer preferences toward cleaner,
alternative technologies. In the long term, this trend could lead to a gradual decline in demand for conventional
fuels.
EU ETS Considerations
The main factors driving the increase in carbon costs for HELLENiQ ENERGY Group are the EU ETS and the
Carbon Border Adjustment Mechanism (CBAM), with particular attention given to the potential inclusion of the
Group’s refineries in the next phase of CBAM expansion. The Group’s three refineries and two power generation
units in Greece actively participate in the EU ETS, directly linking financial impacts to the rising cost of covering
the emissions allowance deficit.
During the first sub-period of the 4th phase of emissions trading (2021–2025), compliance costs have increased
significantly, primarily due to the sharp rise in allowance prices (approximately €87.5 per ton of CO₂ by the end of
2025, compared to approximately €32 per ton of CO₂ at the end of the previous phase), as well as the reduced
allocation of free allowances under current regulations. Moreover, further increases in compliance costs and a
heightened risk of carbon leakage are expected, taking into account the projected changes to the ETS under the
European Green Deal and the “Fit for 55” objectives.
The refining sector is among those facing significant carbon leakage risk, negatively affecting its competitiveness
compared to similar facilities outside Europe. Additionally, due to the Group’s geographical location near the EU
borders, competitive risk is even higher, as neighboring countries outside the ETS produce similar products
without bearing the carbon costs that the Group incurs through its participation in the EU ETS.
Throughout each financial year, HELLENiQ ENERGY’s Group Management continuously analyzes and evaluates
these risks, including increased CO₂ costs, the transition to a net-zero economy, changes in demand and
consumer preferences, and rising crude oil prices. At the same time, it identifies investment opportunities such as
the development of RES, improvement of energy efficiency, and creation of low-emission products, thereby
shaping the Group’s strategy. The successful implementation of this strategy has already contributed to reducing
the carbon deficit and operating expenses through increased energy efficiency.
Furthermore, HELLENiQ ENERGY Group has identified significant opportunities in emerging low-carbon
technologies aimed at mitigating climate change. Such technologies include the production of blue and green
hydrogen, CO₂ capture and storage technologies, as well as solutions that replace fossil fuels with lower-emission
alternatives. According to the Group’s strategy, these technologies are evaluated regarding their implementation
and effectiveness in reducing risks and maximizing opportunities. More information on each significant climate
risk identified, and whether it is considered a physical or transition risk, is provided in ESRS 2 IRO-1: “Description of
the Processes to Identify and Assess Material Climate-Related IROs”. [ESRS E1.SBM-3-18]

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Resilience of Strategy and Business Model
(a) Scope of the Resilience Analysis
HELLENiQ ENERGY Group, following the DMA, conducted a resilience analysis to evaluate its vulnerability to
physical and transitional climate change risks.
The scope of this analysis specifically covers:
• All of the Group’s commercial activities, with particular emphasis on exposure to transition and physical risks
that could potentially disrupt operations.
• The three refineries and two power generation units, including an assessment of the resilience of their
facilities to climate-related risks, focusing on asset vulnerability and the continuity of business operations in
response to climate impacts.
• Corporate infrastructure, including an assessment of the resilience of the Group’s Headquarters and
administrative structures to risks that could affect employee safety, operational efficiency, and revenue
generation.
The resilience analysis extends across HELLENiQ ENERGY Group’s operations (545 assets) in various geographic
locations, with more detailed analysis within a 10-kilometer radius during the reporting period. It also includes an
assessment of physical risks (please refer to section General Disclosures – ESRS 2: “Identification and assessment
of climate-related impacts”) and transition risks (please refer to section General Disclosures – ESRS 2: “Climate-
related transition risks”), in line with the ESRS Standards. [ESRS E1.SBM-3, AR-8-(b)] [ESRS E1.SBM-3-19-(a), AR 6, AR 13]
(b) Methodology and Timing of the Resilience Analysis
The Group's resilience analysis is conducted during the reported period through a combination of internal
assessments, consultations with experts and senior executives, and the use of external data (models). This
analysis incorporates both qualitative and quantitative approaches and is carried out for two climate scenarios:
the Net Zero Transition Scenario and the Hot House World Scenario, as outlined in the section "Use of Climate-
Related Scenario Analysis" of ESRS 2.
The methodology of the resilience analysis included the following steps:
• Impact assessment through dedicated discussions with the heads of the Group’s business units, along with
the integration of internal business data and relevant external climate-related data.
• Assessment of financial and operational impacts on key assets, revenue streams, and supply chains over the
short, medium, and long term.
• Integration of climate scenarios from internationally recognized organizations to explore potential impacts
across different time horizon, which are described in detail per climate risk in subsection ESRS 2: "Material
Impacts, Risks and Opportunities related to Climate change".
• Collaboration with key executives and experts within the Group to validate assumptions and prioritize risks
and opportunities as disclosed in subsection ESRS 2: "Disclosures on the Double Materiality Assessment
Process".
• Review of existing mitigation strategies in relation to risks assessing their effectiveness.
The resilience analysis is conducted across three different time horizons(short-term: 2026; medium-term: 2027–
2030; long-term: 2031–2050) to ensure the identification of both medium- and long-term climate risks for each
horizon. The assessment is based on critical assumptions concerning macroeconomic trends, the evolution of
climate policy, energy transition dynamics, technological developments in the oil sector, as well as increasing
physical climate pressures that may affect key assets, such as refinery facilities.Specifically, the Group evaluated

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time horizons similar to those used in the DMA and in the climate risk assessment. This comprehensive approach
ensures that the analysis identifies potential medium-term challenges as well as long-term risks, enabling the
Group to implement necessary resilience measures, proactively invest in long-term adaptation initiatives, and
capitalize on emerging opportunities. At the same time, these time horizons are fully integrated into the Group’s
strategic and business planning cycles. [ESRS E1.SBM-3-19-(b), AR 7-(a), (b), AR 13]
(c) Results of the Resilience Analysis
The resilience analysis was conducted within the framework of the risk management assessment process, and its
results are taken into account in the Group’s strategic planning cycles. Notably, the resilience of HELLENiQ
ENERGY Group’s strategy and business model enables it to effectively address significant impacts and risks while
also capitalizing on opportunities. The main uncertainties relate to the pace and stringency of climate policy
implementation and the severity of physical climate hazards affecting the Group's infrastructure. These
uncertainties were considered when evaluating the resilience of the current business model. According to the
resilience analysis, all critical facilities are resilient to climate-related risks associated with water stress and
extreme weather events.
As the Group faces significant transition risks, as well as chronic and acute climate risks, including regulatory
pressures and fluctuations in carbon pricing, these challenges simultaneously create opportunities that promote
long-term diversification and resilience (see subsection ESRS 2: "Climate-related Opportunities"). The Group’s
ability to adapt its strategy and business model to climate change over short-, medium-, and long-term horizons
is supported by a climate risk assessment that includes scenario analysis, which informs strategic planning, risk
management, and investment evaluations. Scenario analysis provides the basis for assessing the resilience of
existing assets, potential needs for asset upgrades or reconfiguration, and possible future adaptations in
products, services, and workforce skills, as climate risks, regulatory requirements, and market expectations evolve.
Integrating climate-related risks into governance and decision-making processes also supports the business’s
ability to maintain access to financing at an affordable cost of capital over time. [ESRS E1.SBM-3-19-(c), AR 8 (b)]

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Impact, Risk and Opportunity Management
E1-2 - Policies Related to Climate Change Mitigation and Adaptation
The Sustainability Policy addresses climate change mitigation, climate change adaptation, and energy efficiency
by guiding the implementation and continuous improvement of the Environment and Energy Management
Systems, based on international standards (ISO 14001 and ISO 50001, respectively). The Policy also aligns with the
Group’s objective of reducing its overall carbon footprint and achieving climate neutrality by 2050. All
environmental parameters are monitored based on common European standards and benchmarked against
industry performance at the European level. The Group adapts its business operations to align with the UNSDGs
and the European Green Deal.
At the core of its strategy, the Group focuses on promoting energy accessibility and achieving climate neutrality,
alongside adopting corporate governance principles that ensure financially sustainable and environmentally
responsible operations. The Policy is applied across all Group activities, both in Greece and abroad, covering all
employees without exception. Final responsibility for its approval and implementation rests with the CEO of
HELLENiQ ENERGY Group, with oversight provided by the Sustainability Committee. In its development and
implementation, the views of key stakeholders—including employees, local communities, suppliers, customers,
and public authorities—are taken into account.
The Policy is publicly available via the Group’s corporate website. In line with the chapter General Disclosures –
ESRS 2: “IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities”
which relates to processes for identifying and assessing material climate-related IROs, the assessment of climate
risks is aligned with ESRS guidelines, as well as EU ETS evaluations and the corresponding Group Policy.
During the reporting period, within the framework of the DMA, the following IROs linked to the
Sustainability Policy were identified:
• Investments in renewable energy, sustainable fuels, and low-carbon technologies, contributing to the
avoidance of GHG emissions and supporting the transition to cleaner energy.
• Promotion of sustainable fuels, hydrogen, and e-mobility infrastructure as part of the strategic
transformation plan, enhancing the transition toward a carbon-neutral economy.
• Scope 1 and Scope 2 emissions from the Group’s refining and marketing activities, contributing to climate
change.
• Scope 3 emissions from the use of sold products, purchased goods and services, and upstream and
downstream transportation within the value chain, which significantly contribute to climate change.
• Physical risks from extreme and long-term climate events (e.g., wildfires, floods, heatwaves, sea-level rise,
and water scarcity), which may affect critical energy infrastructure, supply chains, business continuity, and
employee health and safety.
• Transition risks arising from increasing carbon pricing under the EU ETS, regulatory changes, technological
developments, and shifts in fossil fuel demand, with potential impacts on operating costs and profitability.
• Investments in renewable energy, sustainable fuels, hydrogen, and e-mobility infrastructure, with the
potential to create new revenue streams and long-term value.
• Improvement of energy efficiency and emission reductions through technological upgrades and operational
optimization as part of the strategic transformation plan.
Additionally, the engagement with various stakeholders through dialogue and consultations to gather feedback
secures that the Policy addresses their expectations and concerns. The abovementioned Policy was approved by the
CEO of HELLENiQ ENERGY Group and the Sustainability Committee on 29 March 2024. [ESRS E1-2-24, 25]

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E1-3 - Actions and Resources in Relation to Climate Change Policies
HELLENiQ ENERGY has not issued yet ESG Bonds, but the Group, through its 100% subsidiary HELLENiQ
Renewables, has signed a financing framework agreement of an amount of up to €766 million with National Bank
of Greece S.A. and Eurobank S.A. for the implementation of multiple financing arrangements of existing and new
projects (Project Finance), for electricity generation from RES, such as photovoltaic and wind parks. This
agreement constitutes a benchmark and innovative transaction for the Greek market, being the first standardized
financing framework ever concluded by a Greek Corporate group for existing and future RES transactions. [E1-3 AR
21]
The framework agreement sets a common financing framework for projects that meet predefined eligibility
criteria, covering both existing and future HELLENiQ ENERGY Group projects in Greece, regardless of their
development stage. The electricity generated from these projects will be sold through various contractual
arrangements, such as Feed-in Premium, Feed-in Tariff, and/or Power Purchase Agreements. Furthermore, the
framework confirms the commitment of all parties to reduce their environmental footprint and support financing
that promotes sustainable development and the reduction of greenhouse gas emissions.
The key benefits of the framework agreement for HELLENiQ ENERGY Group include:
(a) significant funding capacity, increasing the Group’s growth potential,
(b) best-in-class terms, largely standardized, enabling speed of execution,
(c) Flexible structure, fit-for-purpose for RES, allowing the release of resources to support the rest of the Group’s
activities.
The action plan for climate change adaptation is currently underway and is expected to be completed within the
next year, while its results will be disclosed following their assessment and finalization.
The Group focuses its actions and resources on reducing GHG emissions and mitigating climate change
across the following pillars:
Energy Production and Storage from Renewable Sources
The Group manages 506 MW of RES projects in operation in Greece, Cyprus and the Republic of North Macedonia,
while, at the same time, it has a portfolio of RES projects under development with a total capacity of
approximately 6 GW. The emphasis is on wind and photovoltaic parks, as well as on energy storage projects, such
as BESS and pumped storage systems. The Group’s strategic goal is to operate 1.5 GW of RES projects by 2028
and 2 GW by 2030, through a combination of organic growth and acquisitions, continuously evaluating
opportunities in Greece and internationally.
The Group is currently ranked as the second largest operator of photovoltaic parks in Greece, with a total installed
capacity of 354 MW, while it operates 99 MW of wind parks in Greece and 41 MW of photovoltaic parks in Cyprus.
At the same time, projects with a total capacity of approximately 1 GW are being constructed or are in an advanced
stage of development in Greece, Romania and Bulgaria, including photovoltaic parks, wind farms and electricity
storage projects, with the aim of achieving an installed capacity of 1.5 GW in the next two years.
The Group’s strategic investment in RES already has a significant environmental impact, with total avoided CO₂
emissions since 2013 exceeding 1,300,000 tons, of which approximately 255,000 tons are expected in 2025 alone.
Avoided emissions from RES operations are calculated based on the factors provided in the most recent National
Inventory Report (NIR 2025), while for international operations, the factors provided in the European Investment
Bank’s report (EIB – Project Carbon Footprint Methodologies 2023) were used. In the same year, investments in
RES projects exceeded €175 million, confirming the Group’s commitment to sustainable development and the
energy transition. [E1-3-29-(b)]
Participation in Research Projects
Within the framework of the targets of its strategic plan, HELLENiQ ENERGY Group actively reaffirms its
commitment to reducing its carbon footprint and making a meaningful contribution to environmental and energy

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protection, as well as to climate change adaptation at Group, national, and European levels. This is achieved
through the design and implementation of innovative and research projects across various geographical regions.
The Group strengthens the sustainability of its strategic investments in cutting-edge technologies, such as carbon
capture and utilization (downstream value chain), sustainable aviation fuel production, circular economy solutions,
and hydrogen production (midstream value chain), through its New Technologies and Alternative Energy Sources
Division. At the same time, it supports European and national funding programs.
Over the past five years, HELLENiQ ENERGY Group has undertaken—either independently or in collaboration with
leading national and European research institutes and universities—the development, submission, and
implementation of significant research projects. Notably, during the reporting year, the Group participates, among
others, in three major research projects, as described below, focusing on the development and demonstration of
innovative technologies for converting CO₂ into clean fuels, thereby making a substantial contribution to the
decarbonization of industry and transport:
ECOLEFINS – The project proposes the use of electricity from RES and the utilization of CO₂ captured either from
the atmosphere or from industrial emissions to produce products with a negative carbon footprint. The project is
expected to be completed by the end of October 2026.
STEROPE – The project aims to integrate advanced CO₂ capture technologies with innovative conversion
processes in order to create a circular economy model. Through this program, an integrated facility will be
developed and implemented at the Elefsina refinery, where CO₂ emissions will be captured and converted into
sustainable fuels for aviation and marine engines. The project is expected to have a duration of 48 months and
has already commenced as of October 2025.
COCPIT - The project examines the enhancement of the SAF production chain through innovative processes. It
explores the conversion of biomass into SAF via the mature HEFA (Hydroprocessed Esters and Fatty Acids)
process and the less mature HTL (Hydrothermal Liquefaction) process. The project also aims to develop a
decision-making tool beyond the project’s completion, expected by the end of September 2027, to encompass all
SAF production pathways.
Sustainable Mobility
Electricity and renewable fuels constitute critical enablers for achieving the European Union’s targets under the Fit
for 55 package, which provides for at least a 55% reduction in net emissions by 2030 and climate neutrality by
2050. The Group invests in solutions that enhance the decarbonization of transport, offering high value-added
services and infrastructure that facilitate the energy transition.
Electromobility (ELPEFuture / EKO Charge&Go)
Electricity and charging infrastructure are key enablers for meeting climate targets in road transport. Through
ELPEFuture, the Group systematically invests in a modern charging network and digital management platforms
(EKO Charge&Go), providing high value-added services to consumers and businesses.
Currently, 160 fast chargers (DC) are in operation at EKO and bp service stations across Greece, while 418 chargers
—corresponding to a total of 544 charging points—have been installed at major commercial and corporate
locations in Athens and Thessaloniki. For 2026, the Group plans to double the number of DC chargers at fuel retail
stations (thereby doubling charging points) and triple the number of chargers at other locations (tripling charging
points), with power capacity ranging from 22–180 kW.
Across its international markets (Cyprus, Bulgaria, Serbia, Montenegro, and the Republic of North Macedonia), 45
charging stations have already been installed—37 of which are operational—with an additional 13 planned by
2026 (26 were installed during 2025). By expanding its electromobility footprint, the Group strengthens the
resilience of the transport system, facilitates fleet electrification, and contributes to the reduction of CO₂e
emissions, fully aligned with the requirements of Alternative Fuels Infrastructure Regulation (AFIR) and the
updated targets of the Greek National Energy and Climate Plan (NECP).

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Sustainable Aviation Fuels (SAF)
The Group aligns with European requirements and actively contributes to reducing emissions from aviation, a
carbon-intensive sector with limited alternative solutions. The integration of SAF into aviation fuel supply is critical
for reducing CO₂e emissions and achieving the targets of the Fit for 55 framework. Through its collaboration with
AEGEAN Airlines, the Group supplies aviation fuels incorporating a SAF blend—consistent with European and
national guidelines—thereby supporting the gradual decarbonization of air travel.
Additionally, the selection of maritime transport for fuel deliveries to Greece instead of road transport reduces
emissions across the product’s life cycle, thereby enhancing the environmental performance of the supply chain.
[ESRS E1-3-28]
For more information, please refer to section "SBM-1 - Strategy, business model and value chain: Group Activities".
[E1-4-16-(b)]
HELLENiQ ENERGY Group has not yet implemented nature-based solutions (NbS) as part of its climate change
mitigation strategy. [ESRS E1-3-29-(a)]
Outcome of Actions & GHG Emission Reductions
The above-mentioned actions related to climate change mitigation have already led to GHG emission reductions
and are expected to result in even greater reductions, as shown in the following graph .
The Group selected 2019 as its baseline year for GHG emissions due to its position as a representative year for its
operations and emissions profile, prior to the implementation of significant decarbonization initiatives. This year
reflects the Group's pre-transition emissions levels, providing a clear and consistent benchmark for tracking
progress. The decision was influenced by industry practices such as the latest EU ETS monitoring rules and
sectoral benchmarks, as peers in the sector also adopted similar baseline years to ensure comparability. 2019 is

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considered a suitable reference point, as it aligns with key activities such as sustainable fuels marketing, refining
processes, and renewable electricity generation, and electromobility enabling the Group to accurately assess the
impact of its ongoing decarbonization efforts and sustainability measures.
The goal is to reduce emissions by 30% by 2030, which corresponds to 1,300 ktCO₂. As part of its energy-saving
efforts, the Group has has incorporated into its plans the implementation of actions in three categories.
The first category of actions concerns electricity saving projects with the aim of achieving a reduction of
approximately 5% by 2030. By 2025, the following actions, among others, will have been implemented:
Installation of a New Heat Exchanger at the Aspropyrgos Refinery
As part of the continuous improvement of the energy efficiency of our industrial facilities, the Aspropyrgos
Refinery is implementing the replacement of outdated heat exchangers with a new, high-efficiency heat
exchanger, similar to those used in state-of-the-art naphtha reforming units. The project significantly contributes
to reducing energy consumption through optimized heat recovery, thereby enhancing the overall energy
efficiency of the unit. The investment is expected to be completed and commissioned within 2026, delivering
substantial reductions in both energy consumption and CO₂ emissions at the refinery.
Energy Saving Project in the Crude and Naphtha Desulfurization Units
At the same time, another significant energy upgrade project is underway at the Aspropyrgos Refinery’s main
crude distillation unit and naphtha desulfurization unit. The project aims to reduce fuel and steam consumption,
and consequently CO₂ emissions, through the installation of new high-efficiency exchangers in the crude unit to
optimize the preheating of the feed of the naphtha desulfurization unit. The project is expected to be partially
completed in 2026, substantially contributing to the reduction of CO₂ emissions and the refinery’s overall energy
consumption.
Optimization of the Start-Up Sequence of the Cooling Tower at the Enerwave Thessaloniki Power Plant
The Company systematically invests in optimizing its processes, aiming for more efficient system operation and
reduced energy consumption. During 2025, leveraging this approach, the start-up sequence of the cooling tower
was optimized, resulting in smoother and more energy-efficient operation at the Thessaloniki power generation
plant. The cooling tower is a key component of the plant, as it removes heat from the steam circuit exiting the
steam turbine, lowering its temperature and thereby ensuring the smooth operation of the system. The upgraded
operation of the tower significantly contributes to improving the overall energy efficiency of the facilities.
Replacement of Lighting Fixtures and Air Conditioning Units at the Enerwave Thisvi and Thessaloniki Power
Generation Units
Enerwave, within the framework of upgrading its facilities, has implemented investments aimed at reducing
electricity consumption and, consequently, emissions and operating expenses. A three-year program (with 2025
marking its second year) is underway to fully replace lighting fixtures at the Thessaloniki and Thisvi plants with
LED technology. Additionally, at the Thisvi plant, office air-conditioning units have been replaced with small,
flexible, high energy-efficiency systems. In 2025, the HELLENiQ ENERGY Group acquired the remaining 50%
stake in Enerwave (formerly ELPEDISON), which is now fully consolidated in greenhouse gas (GHG) emissions
reporting, in line with financial consolidation.
In addition, the Group has incorporated into its plans the implementation of energy cogeneration projects and the
conclusion of long-term power purchase agreements (PPAs). For more information on the current emission
reductions that have been achieved using conventional means, please refer to section "E1-6 - Mixed emissions
from scopes 1, 2, 3 and total greenhouse gas emissions". Finally, the third category refers to projects related to
carbon capture and storage (CCS), which currently are under development. Projects in these two categories are
expected to contribute equally to achieving the 2030 emissions target.

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It is noted that Enerwave’s emissions have not yet been incorporated into the Group’s emissions targets; however,
the assessment process for their integration is currently underway and is expected to be completed within 2026.
[ESRS E1-3-29-(b)] [ESRS E1-4-34-(a), (b), AR 25-(a)]
Financial Disclosures
In the EU Taxonomy report, HELLENiQ ENERGY provides further information regarding its significant financial
figures of its Capital Expenditures (CapEx) and Operating Expenditures (OpEx).
The aforementioned actions are actively linked to activities such as the following, contributing significantly to
the objective of climate change mitigation:
• Construction and operation of large-scale electricity production facilities from solar energy
• Construction and operation of large-scale production facilities from wind power
• Construction of electricity storage (battery) facilities [ESRS E1-3-29-(c)-(i),(ii),(iii)]

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Metrics and Targets
E1-4 - Targets Related to Climate Change Mitigation and Adaptation
HELLENiQ ENERGY Group has set a goal to significantly reduce its carbon footprint and achieving climate
neutrality by 2050, by addressing and mitigating the impacts of climate change. Through advancing its energy
transition and leveraging RES, the Group enhances synergies across its business activities and contributes to
climate change mitigation. It is worth noting that energy companies deriving more than 50% of their revenues
from oil and natural gas activities are not yet in a position to set science-based targets. In the absence of
mandatory sector-specific guidance from the SBTi, the Group has not formally established science-based
emission reduction targets, as the relevant sectoral guidance has not yet been finalized, therefore, full alignment
with a 1.5°C temperature pathway is not substantiated.
More specifically, by 2030 it has set the following goals:
• Reducing Scope 1 and 2 emissions (market-based) by 30% compared to base year 2019 through energy use
optimization and the application of innovative GHG emission reduction technologies in refining activities.
• 2 GW of installed capacity (with an interim target of 1.5 GW of operational capacity by 2028), aiming at an
additional CO₂ emissions reduction of more than 20%. [ESRS E1-4-32, 33]
HELLENiQ ENERGY Group has set greenhouse gas emission reduction targets through an organized process that
integrates climate-related risks, opportunities, and business objectives across all activities and regions. Based on a
comprehensive analysis of physical and transition risks in line with ESRS, the Group aims for alignment with
international goals such as the Paris Agreement. Decision-making involved collaboration with internal and
external experts, taking into account financial and operational impacts, and establishing clear short- and long-
term milestones. The Sustainability Committee monitors progress and adjusts the strategy, while the Board of
Directors oversees the target-setting process. In selecting the focus areas for target-setting, the Group considers
the views of key stakeholders and experts to ensure the process aligns with their expectations and regulatory
requirements. [ESRS E1-4- 30] [ESRS E1-4-33]
The aforementioned GHG emission reduction target does not include GHG removals, carbon credits or avoided
emissions as a means of achieving the GHG emission reduction targets. [ESRS E1-4 -34-(b)]
It is noted that 42% of the target relates to Scope 1 GHG emissions, while 58% relates to Scope 2. [E1-4 AR 24]
The change in the organizational perimeter makes current year's (2025) results non-comparable with the base
year (2019). Therefore, no comparison with the base year is provided, as the altered perimeter would not offer a
meaningful assessment of progress against the initial targets. The comparison will be available after the target
has been revised based on the new organizational scope. [ESRS E1-4-34-(a), (b), (c), AR 25]
E1-5 - Energy Consumption and Mix
Fuel Consumption

| 2025 | 2024
Total Reporting Group | HELLENiQ PETROLEUM S.A | Subsidiaries* | Total Reporting Group | HELLENiQ PETROLEUM S.A | Subsidiaries*
Total energy consumption (MWh) | 17,170,370 | 14,296,050 | 2,874,320 | 15,208,669 | 15,079,160 | 129,510
a) Total energy consumption from fossil sources (MWh) | 16,772,135 | 13,940,222 | 2,831,913 | 14,865,512 | 14,768,606 | 96,905

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b) Total energy consumption from nuclear sources (MWh) | 4,135 | — | 4,135 | 12,994 | 8,185 | 4,808
c) Total energy consumption from renewable sources (MWh) | 394,320 | 355,828 | 38,492 | 330,164 | 302,368 | 27,795
c.i. Fuel consumption from renewable sources (MWh) | 12 | — | 12 | 189 | — | 189
c.ii. Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources(MWh) | 390,076 | 355,828 | 34,248 | 328,515 | 302,368 | 26,147
c.iii. Consumption of self-generated non-fuel renewable energy (MWh) | 4,025 | 0 | 4,025 | 1,459 | — | 1,459
Share of fossil sources in total energy consumption (%) | 97.7% | 97.5% | 98.5% | 97.7% | 97.9% | 74.8%
Share of consumption from nuclear in total energy consumption (%) | 0.0% | 0.0% | 0.1% | 0.1% | 0.1% | 3.7%
Share of consumption from renewables in total energy consumption (%) | 2.3% | 2.5% | 1.3% | 2.2% | 2.0% | 21.5%
Total energy consumption from fossil sources (MWh) | 16,772,135 | 13,940,222 | 2,831,913 | 14,865,512 | 14,768,606 | 96,905
Fuel consumption from coal and coal products (MWh) | — | — | — | — | — | —
Fuel consumption from crude oil and petroleum products (MWh) | 12,384,570 | 12,339,738 | 44,832 | 12,991,057 | 12,956,843 | 34,215
Fuel consumption from natural gas (MWh) | 3,880,175 | 1,147,719 | 2,732,456 | 1,317,815 | 1,303,779 | 14,036
Fuel consumption from other fossil sources (MWh) | — | — | — | — | — | —

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Consumption of purchased or acquired electricity, heat, steam, or cooling from fossil sources (MWh) | 507,390 | 452,766 | 54,625 | 556,641 | 507,985 | 48,655
Non-renewable energy production (MWh) | 206,921,565 | 206,921,565 | — | 213,595,668 | 213,595,668 | —
Renewable energy production (MWh) | 780,665 | — | 780,665 | 696,734 | — | 696,734

*Subsidiaries are entities whose financial information is included in the consolidated financial statements of the
Group.
Non-renewable fossil fuels include natural gas, diesel, heavy fuel oil, refinery fuel gas, butane, coke, low sulfur fuel
oil, LPG.
Total energy consumption does not include loss of non-normal operation, e.g. burning at the flare.
No energy is purchased specifically for use for heating, cooling, steam.
Purchased electricity is the result of the providers’ invoices, while self-generated is derived from power meters at
the facilities.
The calorific value of the fuel comes from the National Inventory Report (NIR) 2025.
The percentage of renewable energy in the energy residual mix, according to DAPEEP (06/2025), per supplier is:
43.76% for PPC, Enerwave (former ELPEDISON), ΗΕRON, METLEN ENERGY & METAL S.A. and VOLTERRA.
Regarding the electricity imported, the percentage of nuclear energy in the energy residual mix of every supplier is
0%. [ESRS E1-5-37-(a), (b), (c)-(i), (c)-(ii), (c)-(iii)] [E1-5-38-(a), (b), (c), (d), (e)] [ E1-5-39, E1-5-AR 34]
Energy Intensity based on Net Revenue:

Energy Intensity | 2025 | 2024 | % 2025/ 2024
Energy intensity ratio (total energy consumption/net revenue from activities in high climate impact sectors) (MWh/ 000' €) | 1.48 | 1.19 | 24.0%
Total net revenue from activities in high climate impact sectors (000' €) | 11,611,246 | 12,765,334 | (9.0)%

[ESRS E1-5-40] [ESRS E1-5-41] [ESRS E1-5-AR 36, AR 37]
Identification of High Climate Impact Sectors
The majority of HELLENiQ ENERGY activities fall under the high climate impact sectors, as defined by the
Commission Delegated Regulation (EU) 2022/1288, except for HELLENiQ ENERGY Holdings, ASPROFOS,
HELLENiQ ENERGY DIGITAL and HELLENiQ ENERGY CONSULTING. These industries play a critical role in the
Group’s strategic plan, as they are directly linked to key environmental challenges and opportunities. As presented
in the section E1-3 :"Actions and Resources in Relation to Climate Change Policies", the Group focuses on
initiatives to minimize the environmental footprint of these high-impact sectors, ensuring compliance with
regulations and sustainability goals. Through innovation and greener technologies, the Group is transforming its
operations to align with climate objectives and foster sustainable growth. [ESRS E1-5-42]

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Financial Reconciliation:

Net revenue breakdown | Amounts in 000' €
Total net revenue from activities in high climate impact sectors | 11,611,246
Net revenue from activities other than in high climate impact sectors | 3,397
Total net revenue | 11,614,643

[ESRS E1-5-43] [E1-5-AR 38-(b)]
E1-6 - Gross Scopes 1, 2, 3 and Total GHG Emissions
Scope 1 Emissions:

| Scope 1 GHG Emissions (tnCO2e)
| Base year (2019) | 2025 | 2024 | % 2025 / 2024
HELLENiQ PETROLEUM S.A | 3,371,644 | 3,673,158 | 3,964,619 | (7)%
Subsidiaries* | 6,735 | 555,507 | 11,934 | 4555%
Total Reporting Group | 3,378,379 | 4,228,665 | 3,976,553 | 6%

[ESRS E1-6-50]
GHG emissions by Substance

GHG emissions substances - Scope 1 (tCO2e) | Total Reporting Group | HELLENiQ PETROLEUM S.A | Subsidiaries*
CO2 | 4,218,963 | 3,663,456 | 555,507
CH4 | 1,570 | 1,570 | 0
N2O | 4,666 | 4,666 | 0
HFCs | 3,465 | 3,465 | —
PFCs | — | — | —
SF6 | — | — | —
NF3 | — | — | —
Total direct emissions | 4,228,665 | 3,673,158 | 555,507

*Subsidiaries are entities whose financial information is included in the consolidated financial statements of the
Group.
[ESRS E1-6-AR 41]
Significant changes, assumptions and methodologies
There are no direct emissions of biogenic CO2. [ESRS E1-6 AR 43-(c)
Refineries' and power generation plants' emissions are monitored and verified under EU ETS (Phase 1:
2005-2008, Phase 2: 2008-2012, Phase 3: 2013-2020, Phase 4: 2021-2030). The verified CO 2 emissions 2025 are
4,204,779 tn, corresponding to 99% of the overall Scope 1 emissions. [ESRS E1-6-48-(b), AR 44]
Consolidated approach for emissions reporting is based on operational control. [ESRS E1-6 AR 39 b]
External-body verification of EU ETS emissions according to EU Regulations 2018/2067 and 2018/2066.
Other GHGs are reported according to Kyoto Protocol. [ESRS E1-6-AR 39-(b)]

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Scope 2 Emissions:

| Scope 2 GHG Emissions (tnCO2e)
Electricity Consumption at facilities (Market based) | Base year (2019) | 2025 | 2024 | % 2025 / 2024
HELLENiQ PETROLEUM S.A | 796,961 | 166,118 | 225,763 | (26)%
Subsidiaries* | 42,866 | 33,330 | 35,281 | (6)%
Total Reporting Group | 839,827 | 199,449 | 261,044 | (24)%

| Scope 2 GHG Emissions (tnCO2e)
Electricity Consumption at facilities (Location based) | Base year (2019) | 2025 | 2024 | % 2025/ 2024
HELLENiQ PETROLEUM S.A | N/A | 257,169 | 299,398 | (14)%
Subsidiaries* | N/A | 35,964 | 35,334 | 2%
Total Reporting Group | N/A | 293,133 | 334,732 | (12)%

*Subsidiaries are entities whose financial information is included in the consolidated financial statements of the
Group.
[ESRS E1-6-44, 52-(b), AR 47],[ESRS E1-6-50]
Significant changes, assumptions and methodologies
Domestic emissions were calculated using the consumption of electricity and the CO2 emission factors (EF) of
DAPEEP (residual mix of each supplier for market-based) for 2025 (DAPEEP Study 6/2025): PPC EF:271.618 kg
CO2/MWh, Elpedison EF: 271.776 kg CO2/MWh, HERON EF 272.882 kg CO2/MWh, METLEN ENERGY & METAL EF:
271.464 kg CO2/MWh and Volterra EF: 270.764 kg CO2/MWh. CO2 emission factor source for Greece (location-
based) is NIR 2025 (317.158 kg CO2/MWh). Emission factors used for other GHG is from IPCC 2006. [E1-6 AR 39 b]
For the Group’s foreign subsidiaries, emissions calculations—both location-based and market-based—were based
on the emission factors from the latest European Investment Bank (EIB) publication. CO₂ emission factors are as
follows: Bulgaria 495 kg CO₂/MWh, the Republic of North Macedonia 563 kg CO₂/MWh, Serbia 678 kg CO₂/MWh,
Montenegro 471 kg CO₂/MWh, Cyprus 438 kg CO₂/MWh, and Romania 289 kg CO₂/MWh. Additionally, biogenic
CO₂ emissions from the combustion or biodegradation of biomass are not reported (they are not included in Scope
2 during 2025). [ESRS E1-6-AR 45-(e)]
In 2025, the share of Scope 2 emissions from conventional means (Guarantees of Origin – GOs) amounts to 21%,
with the Guarantees of Origin issued on behalf of HELLENiQ PETROLEUM S.A. by its electricity provider,
Enerwave. [ESRS E1-6-21]
Scope 3 Emissions:

Significant scope 3 GHG emissions (tnCO2e) |
| Base year (2019) | 2025 | 2024 | % 2025 / 2024 |
Total Reporting Group | N/A | 53,876,681 | 51,411,449 | 5% |
Category 1: Purchased goods and services | N/A | 8,050,851 | 7,812,533 | 3% |
Category 3: Fuel and energy-related Activities (not included in Scope1 or Scope 2) | N/A | 260,611 | 187,888 | 39% |
Category 4: Upstream transportation and distribution | N/A | 472,370 | 334,622 | 41% |
Category 5: Waste generated in operations | N/A | 1,717 | 1,283 | 34% |

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Category 9: Downstream transportation and distribution | N/A | 220,926 | 263,172 | (16)% |
Category 10: Processing of sold products | N/A | 1,062,203 | 1,042,505 | 2% |
Category 11: Use of sold product | N/A | 43,037,926 | 40,584,091 | 6% |
Category 12: End-of-life treatment of sold products | N/A | 401,506 | 400,874 | 0.16% |
Category 14: Franchises | N/A | 18,304 | 30,889 | (41)% |
Category 15: Investments | N/A | 350,266 | 753,592 | (54)% |

[ESRS E1-6-44-(a), (b), (c), (d))] [ESRS E1-6 AR 46-(h)] [ESRS E1-6-48-(a), (b)] [ESRS E1-6-49-(a), (b)] [ESRS E1-6-51] [ESRS E1-6-52-(a), (b)]
Significant changes, assumptions and methodologies
The percentage of GHG Scope 3 calculated using primary data obtained from suppliers or other value chain
partners is 1%. [ESRS E1-6 AR 46-(g)]
The Scope 3 calculation includes CO₂e emissions, with no biogenic CO₂ emissions. [ESRS E1-6 AR 46-(j)]
The calculation of Scope 3 GHG emissions does not include any removals, or any purchased, sold, or transferred
carbon credits or GHG allowances. [ESRS E1-6 AR 46-(k)]
It covers the categories presented in the table above.
The following categories were deemed less relevant to the Group's operational boundaries, had a negligible
impact on the overall carbon footprint:
• Category 2: Capital goods (excluded because of partially included in Category 1)
• Category 6: Business travel (included in Category 11)
• Category 7: Employee commuting (included in Category 11)
• Category 8: Upstream leased assets (related emissions included in Scope 1 as the Group is considered to
have operational control in those assets)
• Category 13: Downstream leased assets (not relevant to Group’s activities)
[E1-6 AR 46-(i)]
The GHG emissions calculations in significant Scope 3 categories have been performed by using suitable
emissions factors mainly from Defra 2020 & 2025, GHG Protocol, EEA 2021, IPPC 2006, Fourth IMO GHG Study.
Categories 10, 11 & 12 accounting for over 80% of total Scope 3 emissions are based on 2025 sales. Category 1 is
calculated according to procurement expenses and purchases. Category 3 emissions are based on actual
electricity & natural gas consumption. Category 4 & 9 are calculated using sea transports data. Moreover,
category 5 is based on waste data. Category 14 is estimated based on a fuel station average electricity
consumption and category 15 is based on actual data (approximately 85% were given directly from value chain
partners and the rest is based on actual sales). Scope 3 emissions is calculated for the entities whose financial
information is included in the consolidated financial statements of the Group. [E1-6 AR 46-(e), (h)]
The methodology for Scope 3 calculations has not changed compared to the previous reporting period; however,
the completion of the acquisition of Enerwave has led to changes in the Group’s value chain structure, and
consequently in the GHG mix across Scope 1, 2, and 3 emissions. The methodology for Scope 3 calculations
remains unaffected. [E1-6 AR 46-(f)]

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Total GHG Emissions:

Total GHG Emissions (tnCO2 e)
| Base year (2019) | 2025 | 2024 | % 2025/ 2024
Total Reporting Group (market-based approach) | N/A | 58,304,794 | 55,649,046 | 4.77%
Total Reporting Group (location-based approach) | N/A | 58,398,479 | 55,722,734 | 4.80%

Significant changes, assumptions and methodologies
No disclosure of the effects of significant events and changes in circumstances (relevant to its GHG emissions)
that occur between the reporting dates of the entities in its value chain and the date of the undertaking’s general
purpose financial statements. [ESRS E1-6 AR 42 c]
The targets and milestones are described in section E1-4: "Targets Related to Climate Change Mitigation and
Adaptation".
Total GHG emissions intensity per net revenue
During the reporting period, the total GHG emissions intensity was 5.028 tCO2e/k€ using the location-based
method and 5.020 tCO2e/k€ using the market-based method. [ESRS E1-6 53, AR 53, AR 54]
The net revenue used for calculation of GHG emissions intensity reconciles with the one mentioned in the
financial statements, as also described in the Financial Reconciliation table. [ESRS E1-6-55]
E1-8 - Internal Carbon Pricing
Application of Internal Carbon Pricing:
Detailed Information on Internal Carbon Pricing
The Group applies an internal carbon pricing scheme in the context of a shadow price and the main
objectives for implementing this internal price is to:
a) Drive energy efficiency
b) Drive low-carbon investment
c) Identify and seize low-carbon opportunities and
d) Stress test investment
The internal carbon price is uniform covering all business activities and/or entities, while the factors considered
when determining the price are both the alignment with the price of allowances under the Emissions Trading
System and the impact on business decisions. For 2025, 99% of Scope 1 (4,204,779 tnCO2 ) and 83% of Scope 2
missions (166,118 tnCO2e) are covered by the abovementioned internal pricing scheme, while gross Scope 3
emissions are not covered by internal carbon pricing scheme. In addition, the use of a shadow price of carbon has a
significant impact on the optimization of all the business units’ operation. It is integrated into the decision making
for all the key operating factors as well as the investment planning of the Group (i.e. in LP model for production
planning, in the implementation of significant energy efficiency projects within the production units as well as the
use of various fuels in the production process). The results have already proved beneficial for the financial stability
of the company, as well as, its strategic planning towards sustainability – especially in the energy market
instability conditions. The Group takes into account a carbon price range based on projections and conducts
sensitivity analysis to assess fluctuations in carbon prices. This allows the Group to evaluate the impact of various
projects over time.The range of the shadow carbon price is temporally variable, as it also depends on market
developments and forecasts, taking into account the applicable regulatory framework.There is no reconciliation
with the financial statements, as only actual prices are reflected there. [ESRS E1-8-63-(a), (b), (c), (d)-AR 65)]

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E1-9 - Anticipated Financial Effects from Material Physical and Transition Risks and
Potential Climate-Related Opportunities
Based on HELLENiQ ENERGY Group's current strategic planning, prevailing market expectations, and existing
insurance coverage, it is anticipated that no significant adjustments will be required within the forthcoming
annual reporting period to the carrying values of assets and liabilities as reported in the associated financial
statements. Additionally, the assessment of assets and business activities considered to be at material transition
risk and material physical risk is also part of the process to determine material transition risks as outlined in
sections General Disclosures- ESRS 2: "Use of Climate-Related Scenario Analysis" and "Climate-related transition
risks". No assets of HELLENiQ ENERGY Group are at material physical risk in accordance with the outcomes of the
resilience analysis performed as presented in section ESRS E1: "Results of the Resilience Analysis". For the climate
related opportunities that the Group identified please also refer to section ESRS 2: "Climate-related opportunities".
The relevant table outlines opportunities related with the development and expansion of low emission goods and
services in the medium-term time horizon and the participation in carbon market, including voluntary market and
ETS 2 in the short-term time horizon. There are no significant amounts of assets or net income subject to
significant physical or transitional risks.

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ESRS E2 - Pollution
Impact, Risk and Opportunity Management
E2-1 - Policies Related to Pollution
HELLENiQ ENERGY Group and its subsidiaries, in accordance with the Sustainability Policy, align their business
activities with industry best practices in environmental management. This Policy outlines the Group’s
commitments regarding emissions and waste throughout its value chain. Material IROs related to these
commitments arise from pollution caused by the operation of the facilities, while the Group implements
management systems for these issues across all its activities. The Group prioritizes sustainable management of
air, water, and soil by adopting preventive and control measures aimed at reducing environmental impacts. In
parallel, it closely monitors relevant legislation concerning substances of concern and substances of very high
concern, ensuring compliance, minimizing their use, or, where required, phasing them out in its operational
activities. This practice constitutes a compliance process and is not associated with any recognized material IROs.
More information on the Minimum Disclosure Requirements of the Sustainability Policy can be found in section
ESRS E1 – Climate Change. [ESRS E2-1-15-(a), AR 11] [ESRS E2-1-15-(b), AR 11]
The Group’s Sustainability Policy provides the framework within which the Management Systems for Health and
Safety, Environment, and Energy are implemented and continuously improved, supported by control, inspection,
and certification processes. The review, approval, and monitoring of the Policy’s implementation fall under the
responsibility of the Group’s Sustainability Committee. The objective of the Policy is to reduce incidents that may
affect health, safety, the environment, or society, as well as to ensure preparedness for any potential emergency
situation. HELLENiQ ENERGY Group recognizes the importance of effective management of critical incidents for
the sustainability of its operations. In the event of a health, safety, or environmental incident, prompt and
coordinated communication with the relevant authorities is essential for timely response and mitigation of
impacts. The DMA results are covered by the Group’s Sustainability Policy, which includes specific commitments
for each material topic.
At the same time, as also stated in the relevant Policy, and with the goal of creating long-term value for the Group
and society, the DMA is formulated based on consultation with all social stakeholders, taking their interests into
account, in accordance with section General Disclosures - ESRS 2 “IRO-1 – Description of the Processes to Identify
and Assess Material Pollution-Related Impacts, Risks and Opportunities”. [ESRS E2-1-15-(c)]
During the reporting period, the DMA identified the following material impacts in the Group’s value chain, along
with the corresponding risks and opportunities, in line with the Sustainability Policy:
• Non-GHG emissions from fuel use by end-users
• Non-GHG emissions from refining activities
In addition, despite the extensive protective measures the Group implements, it recognizes the medium- and
long-term risks posed by natural disasters and malicious threats, which could lead to industrial accidents with
impacts on air, water, and soil pollution. Such events may result in financial consequences as well as reputational
effects for the Group.
14 It refers to non-greenhouse gas (non-GHG) emissions from the final use of fuels by cars and ships, such as nitrogen oxides (NOx), sulfur oxides
(SOx), particulate matter (PM), and volatile organic compounds (VOCs).

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E2-2 - Actions and Resources Related to Pollution
Actions related to pollution
Installation of an Electrostatic Precipitator (ESP)
Monitoring of air pollutant emissions at the Group’s industrial facilities is conducted continuously, in accordance
with the terms of the Environmental Permit for each facility, ensuring compliance with statutory limits and
contributing to improved air quality. A large portion of the facilities is equipped with continuous monitoring
systems, the data from which are analyzed and submitted to the relevant authorities for emissions control. The
Group’s strategy includes environmental investments, such as the installation of an Electrostatic Precipitator
(ESP) on the stack of the catalytic pyrolysis unit at the Aspropyrgos refinery, which has been operational since
2022, and to date has contributed to the total 43% reduction in Particulate Matter 10 micrometers (PM10)
emissions from this refinery.
Investments in advanced production technologies
Continuous improvement of environmental performance is achieved through measures such as maximizing the
use of gaseous fuels, utilizing fuels with higher environmental specifications, investing in modern production
technologies, and recovering volatile organic compounds (VOCs) during product loading. The Group has not
implemented additional initiatives due to the absence of a specific quantitative target for pollution reduction.
Nevertheless, the actions taken to date have had a positive effect, as reflected in the reduction 14 of key emission
indicators. The Group has not yet adopted actions related to pollution in the downstream phase of the value chain,
as no material environmental issues or regulatory requirements necessitating immediate intervention have been
identified to date. [ESRS E2-2-18]
Metrics and Targets
E2-3 - Targets Related to Pollution
The continuous reduction of key air emission indicators is a primary objective and commitment of the Group,
covering sulfur dioxide (SO2), nitrous oxides (NOx), particulate matter (PMs), and volatile organic compounds
(VOCs), across all its business operations. Due to the nature of HELLENiQ ENERGY Group’s operations and the
industry in general, there is no direct operational control over emissions related to the products. Therefore, the
Group has not set specific, time-bound targets for the aforementioned atmospheric emission indicators.
Nevertheless, the approach focuses on full compliance with applicable legal and regulatory frameworks,
adherence to all relevant environmental standards and limits, and continuous improvement.
Compliance with applicable national and European legislative frameworks constitutes a fundamental
commitment of the Group, ensuring that obligations arising from its business activities are met. This compliance
includes the implementation of Best Available Techniques (BAT) in the refining sector and adherence to the
European Industrial Emissions Directive. In parallel, the Group employs certified environmental management
systems across all operational activities. It should be noted that the legislation does not prescribe any pollution-
related targets. [ESRS E2-3-25]
At the Group’s three refineries, which constitute the core of its production activities, the objective is to select the
most appropriate fuel blend for internal consumption. The selection process involves strict compliance with the
limits established in environmental permits, as well as the application of BAT. The ultimate goal is to achieve
significant reductions in key atmospheric emissions through measures such as the use of fuels with higher
environmental specifications, the implementation of modern production technologies, and the recovery of VOCs.
The Group monitors the effectiveness of its policies and actions related to pollution management through internal
environmental performance assessment processes, such as the continuous measurement and monitoring of
specific atmospheric pollutant levels, as illustrated below.

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E2-4 - Pollution of Air, Water and Soil
Monitoring of air and water emissions for specific pollutants, both from HELLENiQ PETROLEUM S.A.’s refining
activities and from the Group’s subsidiaries, provides a comprehensive view of environmental impacts across
various parameters. It is worth noting that the Group’s industrial facilities do not cause any releases to the soil.
Air Emissions
In 2025, the fuel mix consumed at the Group’s refineries was appropriately adjusted, with an emphasis on the use
of more environmental-friendly fuels. The related emissions are presented in the table below.

| 2025 | 2024 | % 2025 / 2024
Pollutant (tn) | HELLENiQ PETROLEUM S.A | Subsidiaries* | Total Reporting Group | HELLENiQ PETROLEUM S.A | Subsidiaries* | Total Reporting Group | Fluctuation
SOx/SO2 | 2,853 | 8.78 | 2,861 | 2,967 | 5.68 | 2,973 | (4)%
NOx/NO2 | 2,457 | 73.4 | 2,530 | 2,557 | 3.76 | 2,561 | (1)%
PM10 | 115 | 0.31 | 115 | 121 | 0.21 | 121 | (5)%
NMVOC | 1,205 | 339 | 1,544 | 1,255 | 352 | 1,607 | (4)%
Cd | 0.154 | — | 0.154 | 0.100 | — | 0.100 | 54%
As | 0.043 | — | 0.043 | 0.040 | — | 0.040 | 8%
Cr | 0.206 | — | 0.206 | 0.200 | — | 0.200 | 3%
Cu | 0.361 | — | 0.361 | 0.270 | — | 0.270 | 34%
Hg | 0.125 | — | 0.125 | 0.073 | — | 0.073 | 71%
Ni | 3.440 | — | 3.440 | 4.487 | — | 4.487 | (23)%
Pb | 0.580 | — | 0.580 | 0.330 | — | 0.330 | 76%
Zn | 3.816 | — | 3.816 | 7.450 | — | 7.450 | (49)%
Benzene | 12.431 | — | 12.431 | 13.690 | — | 13.690 | (9)%
Other (HCN) | 4.63 | — | 4.63 | — | — | — | —%

*Subsidiaries are entities whose financial information is included in the consolidated financial statements of the
Group.
Emissions of air pollutants from refining activities, as well as from the final use of fuels in vehicles and ships—such
as NOx, SOx, PM, and VOCs—affect air quality. Although they do not directly cause climate change like CO₂, some
emissions can have indirect climate effects through their impact on atmospheric chemistry or the formation of
secondary pollutants that influence the climate.
It is noted that the air pollutants of the subsidiaries for the year 2025 also include those of Enerwave, from the
date of its consolidation in the Group's financial statements onwards.
For other air pollutants listed in Annex II of Regulation (EC) No 166/2006, no exceedances of the reference limit
values were observed. It should be noted that pollutants related to GHG emissions are reported separately in
section E1.

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Emissions to Water
To prevent incidents that may cause pollution in the ecosystem in which the Group operates, monitoring
mechanisms and compliance measures have been established. More specifically, the following table shows the
measurements of pollutants in wastewater.

| 2025 | 2024 | % 2025 / 2024
Pollutant (tn) | HELLENiQ PETROLEUM S.A | Subsidiaries* | Total Reporting Group | HELLENiQ PETROLEUM S.A | Subsidiaries* | Total Reporting Group | Fluctuation
As | 0.07 | — | 0.07 | 0.02 | — | 0.02 | 252%
Ni | 0.14 | — | 0.14 | 0.04 | — | 0.04 | 243%
Zn | 0.43 | — | 0.43 | 0.36 | — | 0.36 | 20%
Phenols | 2.85 | — | 2.85 | 2.14 | — | 2.14 | 33%
TOC | 109.89 | — | 109.89 | 92.56 | — | 92.56 | 19%
Hg | 0.0014 | — | 0.0014 | 0.0009 | — | 0.0009 | 56%

*Subsidiaries are entities whose financial information is included in the consolidated financial statements of the
Group.
Regarding other pollutants discharged into water, as listed in Annex II of Regulation (EC) No. 166/2006 of the
European Parliament and of the Council, no exceedances of the established reference limit values were observed.
[E2-4-28-(a), AR 21, AR 22] [E2-4 30-(a)]
Significant changes, assumptions and methodologies
No subsidiary falls within the scope of Regulation (EC) No. 166/2006 of the European Parliament and of the
Council, except from HELLENiQ PETROLEUM S.A. and Enerwave. Factors used for the calculation of air emissions
of all Group's subsidiaries are derived from CONCAWE Report 3/15, while SOx emissions are calculated based on
the sulfur content of the fuels. No emissions of persistent organic pollutants (POPs) are reported. Water
emissions are determined through specific laboratory analytical methods for each pollutant (APHA 5220D for
TOC, OE-7.0-93 (ICP-MS) for heavy metals, LCK 345 for phenols, OE-7.0-69 for cyanides). Νo changes in the
methodology were recorded compared to the previous year. [E2-4 30-(b), AR 26, AR 27]
The recording and reporting of air emissions is carried out based on the data collection process described in
section General Disclosures – ESRS 2 “IRO-1 Description of the Processes to Identify and Assess Material
Pollution-Related Impacts, Risks and Opportunities”. [E2-4 30-(c), AR 27]
E2-6 - Anticipated financial effects from material pollution-related risks and
opportunities
Expenditures in Reporting Period
No incidents were recorded in 2025 in which pollution has, or is expected to, negatively affect the cash flows,
financial position, or financial performance of HELLENiQ ENERGY Group over the short-term time horizon.
According to the DMA, in the medium- and long-term time horizons, the risk of environmental accidents has been
identified, including those arising from extreme natural events, such as oil spills or pollution of air, water, and soil.
Such events could disrupt production operations and cause significant financial losses, including damage to
assets, increased insurance premiums, and impacts on the Group’s reputation.

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ESRS E3 - Water and Marine Resources
Impact, Risk and Opportunity Management
E3-1 - Policies Related to Water and Marine Resources
HELLENiQ ENERGY Group, in line with the Group’s Sustainability Policy, focuses on the sustainable and rational
management of water and marine resources and applies best practices to manage significant impacts and risks.
Further information regarding the Minimum Disclosure Requirements of the Sustainability Policy is provided in
section ESRS E1 – Climate Change.
As part of this year’s DMA, the following material impacts and one risk related to water and marine resources were
identified, as linked to the commitments outlined in the Group’s Sustainability Policy:
• HELLENiQ ENERGY, as a group with downstream oil activities, requires significant water use, particularly
during refining.
• The Group operates desalination units and is exploring further implementation, providing a sustainable
water source for industrial operations, by replacing freshwater withdrawals with desalinated water.
• Water scarcity can significantly increase operational costs, as water is essential for refining processes. In
areas of high water stress or seasonal fluctuations, challenges may arise that may require adjustments to
production planning. Timely monitoring and implementation of water conservation and recycling measures
help ensure uninterrupted operation.
HELLENiQ ENERGY Group had already adopted specific measures and procedures, including control, monitoring,
and pollution-prevention mechanisms, as well as policies promoting the efficient use and conservation of water
across all its operational activities and along the value chain. The Group also implements cooperation policies with
suppliers and other stakeholders for the management of high-risk areas, ensuring that these practices are aligned
with best available technologies and applicable regulatory requirements. [ESRS E3-1-11]
HELLENiQ ENERGY Group implements its Sustainability Policy with the aim of ensuring the proper and
sustainable management of water and marine resources across all its activities. [ESRS E3-1-9] [ESRS E3-1-12-(a)-(i)] [ESRS
E3-1-12-(a)-(ii)] [ESRS E3-1-12-(a)-(iii)] [ESRS E3-1-12-(b)] [ESRS E3-1-12-(c)]
E3-2 - Actions and Resources Related to Water and Marine Resources
Water management is a key priority in the operation of the Group’s facilities, therefore, the Group is committed to
ensuring the sustainable use of water resources through the continuous implementation of best practices and
innovative solutions. The Group’s objective is to reduce consumption, promote water reuse and recycling, and
ensure responsible discharge following appropriate treatment, thereby minimizing its environmental footprint.
Wastewater Treatment Units
The Group seeks to reduce water consumption, maximize reuse and recycling, and ensure responsible discharge
following appropriate treatment, in order to minimize environmental impacts. The three-stage wastewater
treatment units at the refineries ensure continuous protection of water resources, covering the intermediate
stage of the Group’s value chain. Ongoing water-saving initiatives are implemented across all business activities
and geographical areas, both within and outside Greece, including regions classified by the World Resources
Institute (WRI) and River Basin Management Plans as areas experiencing high water stress, scarcity, or poor water
quality.
It is noted that 99% of total water consumption originates from facilities in Greece, which are located in areas
identified as high water-stress regions according to the WRI assessment. Water consumption is monitored
through flow meters across all Group activities. This monitoring enables the identification of inefficient water use

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areas, leveraging data to detect further reduction opportunities and prioritize investments in water-saving and
recycling systems. Furthermore, this data serves as the basis for the future development of sustainable water use
targets and for the continuous improvement of water management processes. This initiative contributes to
ensuring that production facilities operate as efficiently as possible. Its effectiveness is measured through
monitoring total water consumption per production unit and comparing it with historical data, enabling the
identification of improvements and the evaluation of the performance of water-saving systems.
The three-stage wastewater treatment units at the refineries provide continuous protection of water resources, in
line with the principles of the Sustainability Policy. The upgrade program of the Wastewater Treatment Unit at the
Aspropyrgos refinery was completed during 2025. The installation of these modern units enhances both water
treatment and reuse, reducing environmental impacts and strengthening resource efficiency. The evaluation of
water management covers both the monitoring of the quantity and quality of water used—including the use of
different water types, such as seawater for cooling, and treatment technologies—as well as broader management
factors, such as availability, quality, and the condition of ecosystems affected by discharge, in order to identify all
potential areas for improvement.
The water resources management system includes continuous monitoring and reporting of water consumption,
quality, and discharge across all facilities and subsidiaries of the Group, while ensuring increased efficiency and
reducing both environmental footprint and operating costs.
Desalination Unit
At the Aspropyrgos refinery, a portion of water demand is met through a desalination plant. Desalination provides
a reliable and sustainable source of water for industrial operations, reducing dependence on freshwater resources,
thereby supporting sustainable environmental management. For the Group, the desalination plant also represents
a future opportunity to further enhance environmental performance.
Upgrade of the seawater cooling intake system at Enerwave's power plant in Thessaloniki
As part of the gradual and comprehensive upgrade of the seawater intake system used in the cooling system of
the power plant in Thessaloniki, Enerwave has launched a series of investments that significantly enhance energy
efficiency and optimize water resource management. The first phase began in 2023 with the installation of a
variable frequency drive (VFD) to control the seawater pumps, offering more flexible and optimized operation,
with a significant reduction in electricity consumption and more efficient management of the seawater supply.
Further projects are underway to upgrade the system, which are expected to be completed by 2026 and will
contribute to the optimal utilization of the seawater intake and discharge system.
Feasibility study on water use
In response to the growing challenges of water resource management in Attica, the Group proceeded in 2025 with
the preparation of a relevant feasibility study. As part of this study, it examined the need for gradual
independence from fresh water for the Aspropyrgos and Elefsina refineries, taking into account increased water
demand, the risk of future price increases, and potential restrictions on availability. In this context, alternative
sources of supply were evaluated, such as seawater, treated effluents from the refineries' biological units, and the
reuse of effluents from neighboring Wastewater Treatment Plants, as well as different desalination and water
treatment technologies, with a complete techno-economic analysis and mapping of pre-treatment, siting, and
infrastructure requirements.
In 2026, a similar study will be carried out for the Thessaloniki refinery, while the next steps include the start of the
Basic Design phase, with the selection of a scenario, technology, and supplier, and the completion of the relevant
technical documentation. [ESRS E3-2-17] [ESRS E3-2-19, AR 19 - AR 21]

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Metrics and Targets
E3-3 – Targets related to water and marine resources
Water resource management is a critical element for the activities of the HELLENiQ ENERGY Group, as water is
used in key processes such as cooling and refining. The Group has not set specific, time-bound targets for
reducing water consumption, as the applicable legislation does not establish corresponding obligations.
Nevertheless, its approach focuses on full compliance with the prevailing legal and regulatory framework, as well
as on the implementation of best practices for the rational use, protection, and reuse of water resources.
Compliance includes adherence to the environmental terms set out in Environmental Permit Approval Decisions
(AEPOs), the application of Best Available Techniques (BAT), and the use of certified environmental management
systems. At the same time, initiatives are implemented across all Group facilities to monitor water consumption
and enhance recycling and reuse, aiming at continuous improvement in efficiency and the reduction of impacts on
water and marine resources.
The effectiveness of policies and actions is monitored through quantitative indicators, such as total water
consumption per production unit and the volume of recycled or reused water, as well as qualitative indicators,
including compliance with AEPO requirements and the implementation of BAT. This monitoring supports
continuous efficiency improvements and the minimization of impacts on water and marine resources.
E3-4 - Water Consumption
Water Consumption Performance
Water Consumption Data for Own Operations
Total Water Consumption

| Water Consumption (m3)
| 2025 | 2024 | % 2025 / 2024
HELLENiQ PETROLEUM S.A. | 6,673,912 | 8,241,409 | (19)%
Subsidiaries* | 481,181 | 227,205 | 112%
Total water consumption in areas at water risk | 7,088,577 | 8,302,891 | (15)%
Total Reporting Group | 7,155,093 | 8,468,614 | (16)%

[ESRS E3-4-28-(a), (b), AR 28]

| Water recycled & reused (m3)
| 2025 | 2024 | % 2025 / 2024
HELLENiQ PETROLEUM S.A. | 2,222,156 | 2,672,776 | (17)%
Subsidiaries* | 3,776 | 250 | 1410%
Total Reporting Group | 2,225,932 | 2,673,026 | (17)%

[ESRS E3-4-28-(c)]
*Subsidiaries are entities whose financial information is included in the consolidated financial statements of the
Group.
In 2025, water consumption increased by 16% compared to 2024, mainly due to scheduled maintenance of units
at the Elefsina refinery for approximately 3 months, while the proportion of water recycled and reused within the
production facilities reached 13%. It should be noted that the 2025 water consumption of subsidiaries includes the
water usage by Enerwave, from the date of its incorporation into the Group's financial statements and thereafter.
Additionally, HELLENiQ ENERGY Group holds 33,622 m³ of stored water, maintaining an additional level of
preparedness and responsibility. As the stored water mainly refers to the filling of fire safety tanks, it is not

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estimated that there will be any change in quantity during 2025. It should be noted that the value refers to the
quantity measured at the end of the year. [ESRS E3-4-28-(d)]
The respective water use intensity is calculated as the total water consumption in HELLENiQ ENERGY Group’s
operations (m³) per million euros of net revenue. In 2025, total water consumption across the Group’s operations
amounted to 7,155,093 m³, resulting in a water use intensity of 616 m³/€ million. In 2024, total water
consumption across the Group’s operations amounted to 8,468,614 m³, resulting in a water use intensity of 663
m³/€ million. Monitoring this indicator allows the assessment of the efficiency of water resource use relative to
the Group’s economic activities, as well as the targeting of actions to reduce water consumption and enhance its
sustainable management. [ESRS E3-4-29]
Water withdrawals and discharges
Total water discharge amounted to 10,346,570 m³, with over 96% being discharged into the sea after treatment.
For comparison, in 2024, total water discharge was 7,229,408 m³, of which over 96% was discharged into the sea
following treatment. [ESRS E3-4, AR 32]
Total water withdrawal amounted to 17,501,663 m³, of which 71% came from the public water supply network. In
2024, total water withdrawal was 15,698,162 m³, with 84% sourced from the public water supply network. [ESRS
E3-4, AR 32]
It is noted that the amount of water discharged and pumped by subsidiaries for the year 2025 includes the
amounts of Enerwave, from the date of its consolidation in the Group's financial statements onwards.
Significant changes, assumptions and methodologies
Data on water consumption and withdrawal are derived from direct measurements, such as flow meters and
invoices. The majority of wastewater discharge data (from refineries) also come from direct measurements using
flow meters, while the rest of the subsidiaries are estimates, based on the percentage of the sewerage fee
indicated on the respective invoices, ranging between 73%- 80%, depending on the provider.
Regarding water recycling and reuse, the data are obtained either directly from flow meters or through
calculations and estimates. Finally, it is estimated that 10% of the water from the wastewater treatment unit is
used for internal operations, such as cleaning, hydraulic testing, and similar processes. [ESRS E3-4-28-(e)]
E3-5 – Anticipated financial effects from water and marine resources-related risks
and opportunities
Based on the DMA results, no financial impacts are expected in the short term from the material risks and impacts
identified related to water and marine resources.
In the medium- and long-term time horizon, the risk of limited water availability has been recognized, which could
cause operational interruptions affecting the scheduling of refining processes, potentially leading to reduced
production and, consequently, lower revenues for the Group.
15According to the DMA, no material IROs were identified in relation to Biodiversity and Ecosystems (ESRS E4). Thus, the related disclosures are
provided on a voluntary basis and selectively cover specific disclosure requirements of the standard, in line with the Group’s existing policies and
procedures.

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ESRS E4 - Biodiversity and Ecosystems
Impact, Risk and Opportunity Management
E4-2 - Policies Related to Biodiversity and Ecosystems 15
As part of its Sustainability Policy, HELLENiQ ENERGY Group places emphasis on the protection of biodiversity
and ecosystems. Prior to the implementation of any project, the Group conducts a detailed assessment of
environmental risks and biodiversity-related requirements, adopting sustainable land and water management
practices that ensure the conservation of ecosystems and species. In collaboration with experts and partners in
the fields of safety and environmental protection, the trained personnel ensure continuous monitoring and
compliance with procedures related to safety, biodiversity, and overall environmental protection. More
information on the Minimum Disclosure Requirements of the Sustainability Policy can be found in chapter ESRS
E1 – Climate change. [ESRS E4-2-22]
E4-3 - Actions and Resources Related to Biodiversity and Ecosystems
HELLENiQ ENERGY Group takes a proactive approach to biodiversity management, placing particular emphasis
on monitoring and mitigating potential risks. Although no significant impacts or incidents affecting biodiversity
and ecosystems have been recorded, the Group ensures that its activities are fully compliant with biodiversity
conservation objectives and applicable regulatory requirements.
In most areas where the Group operates, and in particular at its refining facilities, no species included in the
International Union for Conservation of Nature (IUCN) Red List of Threatened Species have been recorded. The
exception is certain facilities of the subsidiary HELLENiQ RENEWABLES, which are analyzed below. In the field of
Renewable Energy Sources (RES), the Group also complies with the applicable regulatory framework, which
provides for environmental impact assessment, systematic monitoring during the operational phase of projects,
and the implementation of targeted measures for the protection, conservation, and restoration of biodiversity and
ecosystems.
Environmental Impact Studies
The Group prepares Environmental Impact Studies for RES projects, for which the legislation requires it, ensures
that all necessary environmental permits are obtained, and complies with the Special Spatial Framework for
Renewable Energy Sources. At the same time, it complies with the applicable legislative framework, including
Laws 4014/2011 and 3937/2011 on the conservation of biodiversity, as well as with the Ministerial Decisions that
provide for protection measures in Special Protection Areas (SPAs).
HELLENiQ ENERGY Group implements the prescribed land management and restoration measures following the
completion of construction works for photovoltaic and wind farms, in accordance with the environmental
permitting framework. These measures are carried out in compliance with the requirements of Law 4014/2011 on
environmental permitting and the relevant Ministerial Decisions. They include restoring natural vegetation,
managing soil materials, implementing flood protection, and monitoring biodiversity where necessary. The
objective of these actions is to protect the natural environment and biodiversity, as well as to ensure the
sustainable use of land.
Operation of RES projects in areas of high ecological sensitivity
The Group operates 68 photovoltaic and wind farms, some of which are located within or near areas of high
ecological sensitivity. These include SPAs, parts of the European Natura 2000 Network, Wildlife Refuges such as
“K408 Pateras (Mandra)”, “K132 Labanitsa (Ardassa-Vlasti)”, “K147 Anthotopos-Skiti Sideron”, “Dovra-Valta”, and
“K753 Pylaia-Kavissou-Feron”, as well as Important Bird and Biodiversity Areas (hereafter the “IBAs”), such as the

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“Southern Evros Forest Complex – South Mani”. In particular, the South Mani area hosts threatened species of
flora and fauna that require careful environmental management and the implementation of protective measures.
Specifically, according to the Environmental Terms Approval (A.E.P.O.) of the wind farms in this area, an annual
Environmental Management Plan is submitted following monitoring of the local bird populations.
In Cyprus, photovoltaic parks are installed in areas that are part of the habitat of three vulnerable species,
according to the "Red Book of the Flora of Cyprus." At the same time, the protection of marine ecosystems is a key
priority for the Group, with an emphasis on the implementation of marine species protection rules in accordance
with the requirements of the ACCOBAMS treaty and the guidelines of the Joint Nature Conservation Committee
(JNCC) on cetaceans.
The location and management of the above RES projects take into account ecological conditions and proximity to
protected areas, ensuring that the Group's activities are carried out with respect for the natural environment and
biodiversity.
Monitoring and reporting on endangered species
The Group monitors two species of birdlife in the SPAs. For the first species, its presence and reproductive activity
within the SPA have not been documented, while for the second species, the number of breeding pairs exceeds
the conservation target of 8 pairs. The data are systematically collected by the Group and submitted annually to
the Ministry of Environment and Energy, ensuring transparency and compliance with the applicable legal
framework.
Land management and restoration for renewable energy projects
The Group implements all the required measures for the management and restoration of areas after the
completion of photovoltaic and wind farm construction works. At the Kozani photovoltaic complexes (204 MW
and 110 MW), the fences have been designed with a distance of 10–15 cm from the ground, allowing small animals
to move freely and maintaining the ecological continuity of the area. In addition, in cooperation with the local
forestry office, 25% of the total area of 0.4 km², which was previously unused, was made available as grazing land
for local livestock farmers.
These actions ensure the protection of the natural environment and biodiversity, as well as the rational use of
land. It should be noted that wind farms occupy smaller areas than photovoltaic farms so can coexist with existing
vegetation or agricultural activities.
Research on the Status of Important Fauna Species
As part of the systematic monitoring of key biodiversity indicators, including marine mammals (cetaceans and
seals), sea turtles, and seabirds—particularly protected species in the areas of the Ionian Sea where hydrocarbon
exploration has been focused—the Group commissioned a specialized company to implement the “Environmental
Monitoring and Study Programs for Key Fauna Species and Their Habitats.” These programs represent some of
the most comprehensive scientific studies conducted to date in Greece, documenting marine mammals
(cetaceans and the Mediterranean monk seal), Caretta caretta sea turtles, and various seabird species. The studies
combined visual and acoustic surveys, aerial observations, identification of breeding areas, and continuous
monitoring through both pelagic and coastal observations using vessels and aerial platforms, complemented by
telemetry methods throughout the year.
These programs include:
• Systematic monitoring of the Mediterranean monk seal (Monachus monachus) at breeding sites within the
broader Ionian Sea research area, conducted from an inflatable boat by two marine biologists/field
researchers equipped with infrared cameras.
• Pelagic and aerial surveys of marine mammals, mainly cetaceans such as various dolphin species and whales
(including Cuvier’s beaked whale, sperm whale, and fin whale), as well as sea turtles and seabirds, using both
visual and acoustic methods from vessels and aerial platforms.

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• Coastal surveys, primarily focused on breeding areas of the Mediterranean monk seal and the European
shag (Phalacrocorax aristotelis) in adjacent areas of the Natura 2000 Network in the Ionian Sea.
• Telemetry of sea turtles (Caretta caretta) and seabirds (Scopoli’s shearwater / Artemis).
For all activities related to biodiversity, the Group has already carried out appropriate assessments for projects
under development, in compliance with Directives 2009/147/EC and 92/43/EEC. Where the results of these
assessments identify a need for prevention, avoidance, or mitigation measures, these are implemented
immediately to ensure the protection of ecosystems and biodiversity. For example, all wind turbines are equipped
with bird collision avoidance and prevention mechanisms, while wind farms are regularly inspected, and dead
animals are removed to avoid attracting animals that feed on dead organic matter. At present, nature-based
solutions have not been implemented in the above initiatives, but the Group is considering incorporating them in
the future, drawing on the knowledge of local communities and indigenous populations to develop nature-friendly
solutions. [ESRS E4-3-28-(c)]
The Group prioritizes the careful management of impacts on biodiversity through a hierarchy of mitigation
approaches. The Group begins by selecting sites based on ecological criteria in order to avoid particularly sensitive
areas. When complete avoidance is not possible, measures are implemented to reduce negative impacts. The
above actions protect biodiversity and ecosystems in all areas of operation, both within and outside Greece, and
are part of a continuous process that includes short-term, medium-term, and long-term measures, depending on
the severity of the impacts and mitigation requirements.
16 According to the DMA, no material IROs were identified in relation to Resource Use and the Circular Economy (ESRS E5). Thus, the related
disclosures are provided on a voluntary basis and selectively cover specific disclosure requirements of the standard, in line with the Group’s existing
policies and procedures.

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ESRS E5 - Resource Use and Circular
Economy
Impact, Risk and Opportunity Management
E5-1 - Policies Related to Resource Use and Circular Economy 16
HELLENiQ ENERGY Group's Sustainability Policy focuses on preventing and reducing waste throughout the value
chain, as well as on the optimal use of natural resources, while ensuring full compliance with applicable legal and
regulatory requirements. By promoting circular economy practices, the Group seeks to create long-term value for
both its business activities and society. The establishment of measurable targets, assessed on the basis of best
practices, ensures continuous progress in the circular economy and sustainable waste management. In addition,
the Policy encourages cooperation with all stakeholders, promoting the creation of long-term value for both the
Group and society. For more details on the Minimum Disclosure Requirements of the Sustainability Policy, please
refer to chapter ESRS E1. [ESRS E5-1-14]
HELLENiQ ENERGY Group systematically incorporates circular economy principles into its procurement and
marketing processes, as well as throughout the value chain, in order to promote sustainability and responsible use
of resources. It constantly explores ways to reduce the use of primary resources and raw materials, while
prioritizing the use of recycled materials in order to limit waste and maximize resource efficiency. In addition, the
Group implements sustainable procurement practices, ensuring responsible sourcing of materials throughout the
value chain. This approach reinforces the Group's overall commitment to environmental sustainability, social
responsibility, and responsible business practices. [ESRS E5-1- 15-(a)-(b)]
E5-2 - Actions and Resources Related to Resource Use and Circular Economy
Sustainable Waste Management
The Group utilizes material and natural resources throughout their entire life cycle, incorporating waste
management into its strategy for environmental protection and reduction of operating costs. Its approach focuses
on reducing solid waste through modern treatment plants, as well as utilizing it for energy recovery and reuse as
raw materials, replacing fossil raw materials. Petroleum by-products from refining are used as raw materials or
fuels, in line with the principles of the circular economy.
In 2025, there was a 42% increase in waste production compared to the previous year, which was accompanied by
a high recovery rate, thanks to the implementation of improved recycling and recovery practices at the Group's
facilities. In total, more than 35,000 tons of waste (over 92% of the total) were either reused, recycled, or used for
raw material recovery. Hazardous waste accounts for the majority of the total volume and is almost entirely
recovered before being sent for final disposal. The quantities of solid waste per facility are mainly determined by
tank cleaning and vary annually depending on maintenance planning and the availability of treatment units,
ensuring effective management.

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Municipal Solid Waste (MSW) Management
HELLENiQ ENERGY Group reinforces its commitment to sustainable waste management in all its activities,
beyond the management of typical industrial waste, with the active participation of its employees. The goal is to
recycle as many waste streams as possible, such as paper, plastic, small batteries, accumulators, fluorescent
lamps, electronic equipment, aluminum, etc., as well as the effective separation at source of all waste streams,
such as metal, plastic, batteries, paper, organic waste, and common waste, with the aim of increasing the recycling
rate. The implementation of this integrated Municipal Solid Waste (MSW) management system continued also in
2025 at the Aspropyrgos and Elefsina Industrial Facilities.
Recovered Raw Material
In particular, in the refining sector, monitoring the recovery of oily waste (recovered hydrocarbons and residues) is
a key element of the circular economy strategy, as these are returned to the production process as raw materials
for re-refining. The quantities come from both the production process and third parties. It is important to note
that in 2025, 218.8 ktn of oil were recovered, while in total, since 2013, more than 2.24 million tons have been re-
refined. [ESRS E5-2 19]
Metrics and Targets
E5-3 - Targets Related to Resource Use and Circular Economy
Targets related to resource use and circular economy:
Disclosure of Resource Use and Circular Economy Targets
In 2025, HELLENiQ ENERGY Group continued to focus on recycling as many waste streams as possible and
managing other streams on site, with respect for the environment and human health. The Group aims to reduce
waste going to final disposal or incineration to 15% or less by 2030, prioritizing prevention, reuse, and recycling in
accordance with the waste hierarchy.
This target was set through the CSR, assessing key impacts of resource use and the circular economy, as well as
other business objectives. It is noteworthy that the target is a Group initiative and does not stem from legislation,

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highlighting once again the Group's proactive commitment to sustainability. By voluntarily setting this target, the
Group recognizes the critical role of sustainable waste management and minimization of primary raw materials, as
well as the sustainable sourcing and use of renewable resources. The process involved collaboration with internal
teams, industry experts, and external consultants, ensuring alignment with regulatory requirements and best
practices.
At the same time, a strategic target has been set for the production of over 140 kta of sustainable fuels,
combining output from the biodiesel production unit through the reuse of cooking oils at the Thessaloniki refinery
and the development of a new standalone SAF production unit at the Aspropyrgos refinery.
The Group examined the financial and operational implications and set clear, measurable milestones for long-
term goals, while the Sustainability Committee monitors progress and makes necessary adjustments. The
Sustainability Committee of the BoD oversees the establishment of relevant targets, ensuring effective
monitoring of waste, products, and materials management throughout their entire lifecycle, addressing all
material matters related to resource use and the circular economy. [ESRS E5-3-23] [ESRS E5-3-24] [ESRS E5-3-24-(e)] [ESRS
E5-3-27]
E5-4 - Resource Inflows
Resource Inflows Description:
The main inputs are crude oil and other hydrocarbons (as raw materials for processing), accounting for over 86%
of all materials or resources used at Group level and originating from non-renewable sources. For the year 2025,
the quantity of crude oil amounts to 14,225 ktn, while crude oil together with other unit feedstocks amounts to
17,836 ktn for the Group's three refineries (HELLENiQ PETROLEUM S.A.). [ESRS E5-4-30, AR 21]
Significant changes, assumptions and methodologies
The calculations include data obtained from direct measurements, ensuring that double counting by the Group is
avoided. [ESRS E5-4-32, AR 25]

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E5-5 - Resource Outflows

|  |  | 2025 |  |  | 2024 | % 2025 / 2024
Waste Streams (tn) | HELLENiQ PETROLEUM S.A | Subsidiaries* | Total Reporting Group | HELLENiQ PETROLEUM S.A | Subsidiaries* | Total Reporting Group | Fluctuation
Total amount of waste generated | 31,590 | 7,279 | 38,869 | 21,411 | 6,047 | 27,465 | 41%
Hazardous (Total) | 21,594 | 1,169 | 22,763 | 15,873 | 2,136 | 18,009 | 26%
Non-hazardous (Total) | 9,996 | 6,110 | 16,106 | 5,545 | 3,910 | 9,456 | 70%
Total weight of waste diverted from disposal, based on disposal method (R) | 30,825 | 5,172 | 35,996 | 21,351 | 2,666 | 24,017 | 50%
Reuse –hazardous | — | 80.98 | 80.98 | 91 | 128 | 219 | (63)%
Reuse – Non-hazardous | — | — | — | — | 190 | 190 | —%
Recycling – Hazardous | 14,476 | 588 | 15,063 | 9,524 | 481 | 10,005 | 51%
Recycling – Non-hazardous | 1,040 | 4,330 | 5,370 | 1,181 | 1,629 | 2,864 | 87%
Recovery – Hazardous | 7,119 | 159 | 7,277 | 6,250 | 133 | 6,384 | 14%
Recovery – Non-hazardous | 8,191 | 13.89 | 8,205 | 4,304 | 50.64 | 4,355 | 88%
Total weight of waste destined for final disposal, by disposal method (D) | 765.34 | 2,107 | 2,873 | 67.57 | 3,381 | 3,448 | (17)%
Incineration – Hazardous | 0.04 | 103 | 103 | 0.04 | 12.89 | 12.93 | 700%
Incineration – Non-hazardous | — | 5.73 | 5.73 | — | 0.16 | 0.16 | 3479%
Final disposal (e.g. landfill, thermal desorption, etc.) – Hazardous | 0.02 | 7.21 | 7.23 | 7.49 | 59.63 | 67.12 | (89)%
Final disposal (e.g. landfill, thermal desorption, etc.) – Non- hazardous | 765 | 1,615 | 2,381 | 60.04 | 1,987 | 2,047 | 16%
Other ways of disposal (hazardous) | — | 231 | 231 | — | 1,321 | 1,321 | (83)%
Other means of disposal (non- hazardous) | — | 145 | 145 | — | — | — | 100%

*Subsidiaries are entities whose financial information is included in the consolidated financial statements of the
Group.
[ESRS E5-5-37-(a), (b), (c), (d)] [ESRS E5-5-38-(a)]
Significant changes, assumptions and methodologies
Waste classification was carried out in accordance with the European Waste Catalogue of Commission Decision
2014/955/EU, using the first level of categories. The data are based on direct measurements.
The main materials found in waste include catalysts, metals, oily sludge, and oily waste. [ESRS E5-5-38-(b)] [ESRS
E5-5-40]
The total amount of hazardous waste amounts to 22,763 tons, while no radioactive waste was produced by
HELLENiQ ENERGY Group in 2025. [ESRS E5-5-39]

ESRS S1 - Own Workforce |  | ESRS S3 - Affected Communities |
Strategy |  | Strategy |
ESRS 2 SBM-3 | Material IROs and their Interaction with Strategy and Business Model |  | ESRS 2 SBM 3 | Material IROs and their Interaction with Strategy and Business Model |
Impacts Risk and Opportunity Management |  | Impact, Risk and Opportunity Management |
S1-1 | Policies Related to Own Workforce |  | S3-1 | Policies Related to Affected Communities |
S1-2 | Processes for Engaging with Own Workforce and Workers’ Representatives about Impacts |  | S3-2 | Processes for Engaging with Affected Communities about Impacts |
S1-3 | Processes to Remediate Negative Impacts and Channels for Own Workforce to Raise Concerns |  | S3-3 | Processes to Remediate Negative Impacts and Channels for Affected Communities to Raise Concerns |
S1-4 | Action on Material Impacts on Own Workforce and Approaches to Managing Material Risks and Pursuing Material Opportunities Related to Own Workforce and Effectiveness of those Actions |  | S3-4 | Taking Action on Material Impacts on Affected Communities and Approaches to Managing Material Risks and Pursuing Material Opportunities Related to Affected Communities and Effectiveness of those Actions |
Metrics and Targets |  | Metrics and Targets |
S1-5 | Targets Related to Managing Material Negative Impacts, Advancing Positive Impacts and Managing Material Risks and Opportunities |  | S3-5 | Targets Related to Managing Material Negative Impacts, Advancing Positive Impacts and Managing Material Risks and Opportunities |
S1-6 | Characteristics of HELLENiQ ENERGY Group's employees |  |  |  |  |  |  |  |  |  |
S1-7 | Characteristics of non-employee workers in HELLENiQ ENERGY Group’s own workforce |  | ESRS S4 - Consumers and End-Users |
S1-8 | Collective Bargaining Coverage and Social Dialogue |  | Strategy |
S1-9 | Diversity Metrics |  | ESRS 2 SBM 3 | Material IROs Related to Consumers and End-Users and their Interaction with Strategy and Business Model |
S1-10 | Adequate Wages |  | Impact, Risk and Opportunity Management |
S1-11 | Social Protection |  | S4-1 | Policies Related to Consumers and End-Users |
S1-12 | Persons with Disabilities |  | S4-2 | Processes for Engaging with Consumers and End-Users about Impacts |
S1-13 | Training and Skills Development Metrics |  | S4-3 | Processes to Remediate Negative Impacts and Channels for Consumers and End-Users to Raise Concerns |
S1-14 | Health and Safety Metrics |  | S4-4 | Taking Action on Material Impacts on Consumers and End- Users and Approaches to Managing Material Risks and Pursuing Material Opportunities Related to Consumers and End-Users and Effectiveness of those Actions |
S1-15 | Work-Life Balance Metrics |  | Metrics and Targets |
S1-16 | Remuneration Metrics (Pay Gap and Total Remuneration) |  | S4-5 | Targets Related to Managing Material Negative Impacts, Advancing Positive Impacts and Managing Material Risks and Opportunities |
S1-17 | Incidents, Complaints and Severe Human Rights Impacts |  |  |  |  |  |  |  |  |  |

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ESRS S1 - Own Workforce
Strategy
ESRS 2 SBM-3 - Material IROs and their Interaction with Strategy and Business Model
HELLENiQ ENERGY Group recognizes that the following identified impacts related to its own workforce play an
important role in shaping its strategy and business model, as they are key drivers of the Group’s long-term
sustainability and competitiveness:
• The Group addresses the growing need for specialized Health & Safety (hereinafter the “H&S”) programs,
supporting the development and training of young professionals. By providing targeted education and
hands-on learning opportunities, the Group helps build a skilled workforce, strengthens safety
competencies, and fosters the next generation of H&S leaders.
• Investments in employee training and professional development enhance awareness, foster a culture of
well-being and ethics, and strengthen employees’ skills and capabilities, supporting their growth and
effectiveness within the Group.
• The Group’s support for ongoing communication with employees strengthens social dialogue, upholds
freedom of association, and facilitates the effective functioning of works councils, thereby enhancing
employees’ rights to information, consultation, and participation.
• Although strict safety protocols are in place, the oil and gas industry continues to be high-risk because of its
complex equipment and hazardous materials. The inherent dangers—such as explosions, fires, chemical
spills, and and work injuries—carry serious consequences for both the environment and human health.
[S1.SBM-3-14, AR 6 - AR7], [S1.SBM-3-14-(b)], [ESRS S1-ESRS 2 SBM-3-13-(a)]
It is worth noting that the HELLENiQ ENERGY Group places its employees’ H&S at the center, proactively
preventing potential risks before they arise. The strategy is also continuously adapted to ensure business
continuity and to leverage opportunities, such as the development of a culture of well-being and safety across all
levels of employees. [ESRS S1-ESRS 2 SBM-3-13-(b)]
Personnel subject to material impacts include employees as well as individuals from temporary employment
agencies (TEAs), while ensuring that all employees and external partners are fully protected and included in the
Group’s H&S measures. [ESRS S1-ESRS 2 SBM-3-14-(a)]
Occupational Health and Safety Culture
The Group recognizes that the oil and gas value chain carries high H&S risks due to the complexity of equipment
and the hazardous materials involved. For this reason, it applies the Principle of Prevention, aiming to identify,
assess, and mitigate all risks. Protecting the health and well-being of employees and external partners is a core
strategic priority, with the goal of maintaining a workplace free from accidents and occupational illnesses.
The identification and assessment of occupational risks support strategic decision-making and ensure
compliance with European and international regulations and best practices. The Group fosters a strong H&S
culture by securing management and workforce commitment, conducting regular health monitoring based on
role, age, and gender, and collaborating with medical specialists to provide timely access to healthcare services.
At the same time, active employee involvement is encouraged and rewarded, including participation in risk
management, reporting and investigating incidents, and implementing programs, campaigns, and regular
preparedness exercises in all areas of the Group's activity, often in cooperation with the competent authorities.

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Training and skills development of employees
Continuous training and skills development is a key priority for HELLENiQ ENERGY Group, as it is closely linked to
safety and sustainable development. In 2025, the Group delivered over 140,000 hours of training, covering areas
such as H&S, environmental management, digital transformation, and energy transition. These initiatives include
specialized programs for refinery engineers and technicians, ESG and sustainability seminars, and leadership
development for executives. In addition, e-learning platforms are used to provide training on safety, ethics, and
regulatory compliance.
These programs primarily benefit the Group’s employees, while also supporting non employees and
subcontractors who take part in training and preparedness exercises. Implemented across all regions where the
Group operates, these initiatives strengthen professional skills, reduce risks, and help nurture a culture of safety,
well-being, and ethical behavior in the workplace.
Social Dialogue Support and Employee Engagement
The Group actively promotes social dialogue and employee engagement in decision-making processes, fostering
trust and transparency. Through collective bargaining agreements covering 74% of the workforce, the Group
ensures freedom of association and the operation of works councils. In addition, communication channels such as
the corporate intranet, meetings, surveys, and feedback programs allow employees to share their views and
actively contribute to shaping Group's policies.
These initiatives primarily benefit employees, strengthening their rights to information, consultation, and
participation across all countries where the Group operates, contributing to the creation of a working environment
that fosters collaboration, safety, and productivity. [ESRS S1.SBM-3-14-(c)]
The Human Resources and Procurement Departments systematically monitor potential risks of forced or child
labor, both within internal operations and across the supply chain, in collaboration with trade unions and, where
required, employee representatives. The Group’s recruitment policy sets a minimum age of 18 years. In all regions
of operation, national laws prohibiting forced labor are strictly applied, and the Group ensures full compliance with
national and international labor legislation, as well as with Collective Bargaining Agreements (CBAs) and
International Labor Conventions (ILCs) for all employees. The Group has not identified any activities or geographic
areas within its own operations that present a significant risk of incidents of forced or child labor. However,
enhanced monitoring is applied across the supply chain through established due diligence procedures and
relevant contractual requirements. Accordingly, supplier contracts include provisions requiring compliance with
the principles of the UN Global Compact. [ESRS S1-ESRS 2 SBM-3-14-(f), (g)]
No specific groups of employees have been identified as being exposed to heightened risks. However, employees
working in the Group’s refineries and other industrial facilities are associated with certain occupational risks due to
the nature of their activities. These activities involve the operation of complex equipment and the handling of
hazardous materials, which renders the working environment inherently more demanding. [ESRS S1-ESRS 2
SBM-3-15-16]
17 The Code of Conduct is publicly available on the Group’s official website at: Code of Conduct

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Impacts Risk and Opportunity Management
S1-1 - Policies Related to Own Workforce
The Group has established a comprehensive framework of policies and procedures to manage material impacts
and risks related to its own workforce, in line with all applicable legislation and relevant guidelines on human rights
and working conditions. The key impacts include: the development of skills and the training of new professionals
in the field of Health and Safety (H&S), the strengthening of a wellbeing-oriented culture, the management of
inherent risks associated with the oil and gas industry, and the safeguarding of active employee participation and
social dialogue. At the same time, the Group acknowledges that improper handling of materials, either by the
Group itself or by its partners, may lead to H&S incidents, operational disruptions, or regulatory fines. To mitigate
and control such risks, while also promoting positive impacts, the Group implements all necessary measures
through its established policies and procedures.
Sustainability Policy
The Group’s Sustainability Policy focuses on ensuring a safe working environment, promoting responsible
governance practices, and supporting the Group’s sustainable operation. It takes into account the interests of all
stakeholders—including employees, partners, suppliers, local communities, and consumers—and ensures
alignment with international sustainability and ethics standards, such as the United Nations Guiding Principles on
Business and Human Rights. All subsidiaries systematically work to reduce incidents affecting Health, Safety,
Environment, or Society, while maintaining preparedness for emergency situations. These actions are supported
by the Policy framework and the Occupational Health and Safety Management System, which strengthens
employee training and monitoring. Furthermore, all contracts with suppliers incorporate specific clauses requiring
compliance with the principles of the United Nations Global Compact.
Finally, the Policy establishes a comprehensive and multi-layered management and safety framework. Its content
is available to all employees through the Group’s website and internal network (intranet). The list of applicable
legislation is regularly updated, and the relevant departments are promptly informed to ensure full compliance
with new requirements. Further information on the Minimum Disclosure Requirements of the Sustainability Policy
is provided in section ESRS E1 – Climate Change. [ESRS S1-1-19]
Code of Conduct 17
The Code of Conduct constitutes a fundamental corporate governance tool, complies with legislation on the
prevention of financial crimes and corruption, applies to all activities of the Group, and is translated into the
languages of the countries in which it operates. The Group provides regular trainings to its employees, which is
also included in the induction process of new employees and is committed to the values of health and safety,
equality and meritocracy, a stable working environment, career and development based on performance,
competitive remuneration and benefits, continuous training, and work–life balance.
The Code applies to all members of the BoD of each Group company, their employees (permanent and/or
temporary) engaged under dependent employment relationships of indefinite and/or fixed duration, full-time
and/or part-time, senior management executives, the Group’s lawyers engaged under retainer or service provision
agreements, seconded employees, as well as third parties cooperating with a Group company in the context of
service provision or project execution.
Any violation of the above may lead to disciplinary action, regardless of any other legal liabilities (such as criminal
or civil liabilities) provided for by law. Disciplinary measures are applied in proportion to the nature of the breach
and the role of the individual involved and may include termination of the contractual relationship between the
offender and the relevant Group company.
The BoD oversees the implementation of the Code and ensures that human rights principles, as set out in the
United Nations Universal Declaration of Human Rights and the International Labor Organization Declaration on
Fundamental Principles and Rights at Work, are embedded in the Group’s culture. The Compliance Department is
responsible for the effective application of the Code, providing guidance and investigating any reports or

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allegations of violations. In addition, the Group’s governance structure and internal control systems safeguard
against unlawful conduct and corruption.
More specific, HELLENiQ ENERGY Group provides reporting channels and grievance mechanisms, such as the
Whistleblowing Policy, which allow employees and teams to raise concerns about human rights violations while
ensuring confidentiality, protection from retaliation, and access to remedies. At the same time, a process is in
place to identify, assess, and address potential adverse impacts on human rights related to the Group’s activities
and business relationships. The Group maintains open communication channels for employees and third parties
who interact with it, enabling them to report any incidents of human rights violations. Further information on
Whistleblowing Policy is provided in section G1 – Corporate Governance.
Ensuring effective implementation includes training and communication: employees undertake regular
awareness seminars and e-learning programs on the Code. Furthermore, periodic meetings with stakeholders are
conducted to facilitate the exchange of information and the documentation of concerns. [ESRS S1-1-20-(a)-(b)-(c),21]
Occupational Health and Safety Management Systems
Occupational Health and Safety Management Systems are implemented at all levels, covering employees,
executives, members of management, and all service providers to the Group. They include measures aimed at
preventing occupational accidents and hazardous situations, such as risk assessments, personnel training, safety
protocols, and emergency response procedures. These standards are aligned with national and European
legislation, as well as with internationally recognized codes and practices, often exceeding them in rigor. Their
application extends across all activities of the Group and its subsidiaries, including upstream and downstream of
the value chain, and encompasses all stakeholders, such as suppliers, contractors, and local communities, without
exception. [ESRS S1-1-23]
Policy on Combating Violence and Harassment at Work
Since 2022, the Group has adopted the Policy on Combating Violence and Harassment at Work, in accordance
with Law 4808/2021, with the aim of eliminating discrimination and promoting equal opportunities, diversity, and
inclusion. This Policy provides guidance for the prevention and management of workplace incidents. The Group
ensures that decisions regarding recruitment, promotions, and termination of employment are based solely on
merit, qualifications, and performance, rejecting any form of discrimination based on origin, gender, age, religion,
family status, disabilities, nationality, or personal beliefs. Through the implementation of the Policy, the Internal
Labor Regulations, and the Personnel Selection and Performance Evaluation System, Group companies promote a
discrimination-free environment, identify training needs, and create incentives for improved employee
performance. Respect toward colleagues, executives, and partners is a fundamental principle of daily conduct,
expressed through courtesy, appropriate attire, avoidance of conflicts, and professional behavior. The Group does
not tolerate sexual or any other form of harassment. Any employee who feels aggrieved may submit a written
report to the Human Resources Department (HR Department), which handles the matter with confidentiality,
objectivity, and sensitivity.
It should be noted that no Group employees have been identified as belonging to vulnerable groups; therefore, no
specific policy commitment exists in this regard. All reports are treated equally, and the Group’s management
undertakes immediate and thorough investigations, taking necessary measures to assign responsibility and
protect the affected individual. The continuous commitment of all departments to the Policy is ensured through
ongoing communication and is overseen by the Group’s Human Resources and Administrative Services Division.
Furthermore, the Policy is aligned with internationally recognized human rights standards and the United Nations
Guiding Principles on Business and Human Rights, ensuring that, in cases of human rights violations, appropriate
measures are implemented to provide for and enable remediation. Such measures aim to restore the affected
individual and to address and rectify the conditions that gave rise to the violation. [ESRS S1-1-24-(a)],[ESRS S1-1-24-(b), AR
15 - AR 16], [ESRS S1-1-24-(c)], [ESRS S1-1-24-(d)]
Human Rights Commitments for Group Employees
The Sustainability Policy is aligned with international standards, such as the UNSDGs and the European Green
Deal. The Group’s commitment to promoting human rights is reinforced through the updated Code of Conduct,
ensuring it reflects contemporary values and the Group’s operational processes. More specifically, it prohibits all

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forms of forced or compulsory labor, and child labor, in alignment with applicable international and national
legislation and internationally recognized standards, including the UN Guiding Principles on Business and Human
Rights (UNGPs), the OECD Guidelines for Multinational Enterprises, the United Nations Universal Declaration of
Human Rights, and the International Labor Organization Declaration on Fundamental Principles and Rights at
Work. The Group actively participates in international initiatives, including the UN Global Compact, and publicly
discloses progress in line with sustainability standards. [ESRS S1-1-20-(b),(c)]
Child labor is regulated under Greek legislation (Laws 1837/1989, 3850/2010, Presidential Decree 62/1988), which
the Group fully implements. [ESRS S1-1-22]
In all countries where the Group operates, national laws prohibiting forced labor are fully applicable. The Group
actively monitors compliance with these laws, as well as with ILO conventions and collective bargaining
agreements.
S1-2 - Processes for Engaging with Own Workforce and Workers’ Representatives
about Impacts
The Group actively supports employee participation through seven (7) representative trade unions, which
collaborate in shaping the CBAs of each company. Communication with employees is organized through regularly
scheduled meetings with the Health and Safety Committees every 3–4 months, as well as through cooperation
with the trade unions. Employees are also informed via, presentations, newsletters, and corporate
announcements, which cover both Health and Safety matters and all other material topics relating to the Group’s
policies, procedures, corporate responsibility programs, equality, sustainable development, and other key
information affecting operations and the working environment. Daily information flow is further supported
through the intranet, dedicated events, and awareness campaigns. A digital suggestion box allows employees to
submit comments, questions, or ideas anonymously, fostering engagement and dialogue at all levels of the Group.
[ESRS S1-2-27-(a), (b), AR 19]
The ultimate responsibility for promoting and maintaining effective employee relations rests with the Group
Human Resources and Administrative Services General Director, who is responsible for fostering positive and
collaborative relationships between the Group and its employees, while ensuring that interactions are constructive
and supportive. [ESRS S1-2-27-(c)]
The Group does not have specific agreements with workers' representatives related to the respect of human
rights of its own workforce. [ESRS S1-2-27-(d)]
The Group encourages employee participation through ongoing dialogue and communication channels, available
on its internal network (the intranet). This approach allows for the collection of feedback from staff, which is used
to improve policies, procedures, and practices in the workplace. To enhance participation, the Group encourages
employees to submit suggestions and reports, monitors their volume and content, and analyzes feedback to
identify trends or areas that need attention. Meetings and dialogue sessions provide opportunities for direct
communication and exchange of views, while intranet tools facilitate information sharing and feedback,
promoting an interactive and participatory work culture. [ESRS S1-2-27-(e)]
So far, based on the assessment of occupational risks and the overall analysis of factors affecting the main
impacts on working conditions, no group of workers appears to be particularly exposed to these impacts. [ESRS
S1-2-28]
S1-3 - Processes to Remediate Negative Impacts and Channels for Own Workforce to
Raise Concerns
Incident reporting procedures within the Group are standardized and based on the internal directive "Reporting
and investigation of health, safety and environmental incidents". This guideline covers the entire cycle of
recording, evaluating, monitoring, and controlling such incidents. In 2025, no complaints related to health and
safety issues were submitted. In the event of a relevant report, the established formal resolution procedure is
applied. For the management of more general concerns, the Regulatory Compliance Office is responsible for
examining the credibility of complaints with absolute confidentiality and discretion. If the report is deemed valid, it
recommends appropriate corrective measures, including remediation actions in relation to employees’ health and

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safety matters. These actions aim at the prompt rectification of impacts and the assessment of their
effectiveness, ensuring that employees are protected and that incidents are addressed with transparency and
objectivity. When necessary, it cooperates with other Group departments, such as the Internal Audit Division or
Human Resources Division, to ensure a comprehensive investigation.
At the same time, the Group offers multiple channels of communication to all stakeholders in order to gather
concerns or complaints related to human rights issues. Employees have access to complaint mechanisms both via
the intranet, designated email addresses or online forms, and via physical "suggestion boxes" located at certain
facilities. Employees are made aware of the available channels during their onboarding process through dedicated
email communications, intranet postings, and periodic internal announcements. All employees can use the
available mechanisms electronically.
Within the framework of the certified Occupational Health and Safety (OHS) management systems in accordance
with ISO 45001, corresponding reporting procedures have been formally integrated. The Code of Conduct
provides specific ways to report potential violations, including those related to human rights. In addition,
employees, executives, members of management, and associates are free to contact the Regulatory Compliance
Office to express concerns about practices that are not in line with the law, Group policies, or the Code of Conduct.
The process is designed to ensure transparency, objectivity, and a work environment based on ethics and respect
for the rights of all.
In addition, enhanced protection measures are taken for those who report or disclose irregularities in the context
of their work, while the channels for reporting violations are constantly being enriched. For this reason, and in
compliance with Law 4990/2022, which provides for the protection of persons who report violations of European
Union law, the Group has established the aforementioned Whistleblowing Policy since 2024.
The feedback gathered through all these mechanisms is a useful indicator of whether employees are aware of,
trust, and use these structures, considering them a useful tool for expressing concerns or needs and seeking
solutions.
The Group provides external stakeholders (business partners, customers, and communities) with accessible
complaint submission mechanisms, such as direct email addresses, online contact forms, telephone and fax
numbers, which can be found on the Group's website. These mechanisms address issues pertaining to sustainable
development, occupational health and safety, and human rights. [ESRS S1-3-32-(a), (b), (c), (d), (e)]
Finally, the Group ensures the protection of persons who submit reports, regardless of their validity. The
protection framework applies even if the reports submitted are not confirmed after investigation and, in any case,
provided that the report is not malicious. More information on the Whistleblowing Policy can be found in section
G1 – Business Conduct. [ESRS S1-3-33]
S1-4 - Taking Action on Material Impacts on Own Workforce and Approaches to
Managing Material Risks and Pursuing Material Opportunities Related to Own
Workforce and Effectiveness of those Actions
HELLENiQ ENERGY Group is committed to taking comprehensive measures for the health and safety of its
employees, implementing risk management systems, prevention procedures, and training programs that enhance
the protection, well-being, and preparedness of its staff. At the same time, it takes action to strengthen employee
rights and ensure effective social dialogue, promoting a safe and fair working environment.
Actions for Health and Safety
Emergency preparedness drills and Training for Employees and Partners
To prevent accidents, the Group implements procedures for the safe design and operation of equipment, with
continuous monitoring through KPIs. It cooperates with the European organization CONCAWE and participates in
annual surveys and comparative assessments to evaluate the effectiveness of Health and Safety actions, while
also participating in international organizations for the comparison and adoption of best practices.
18 The figure includes 85 employees of Enerwave who were trained in 2025, the year in which the company was integrated into the Group.

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Emergency preparedness drills are conducted regularly and on an ad hoc basis, both at the Group's industrial
facilities and at the KALYPSO fuel stations, with the aim of maintaining safe and smooth operations and
protecting the health and safety of employees, partners, and surrounding communities. After each drill, an
assessment of preparedness for the specific scenario is carried out, which includes incident management and,
where necessary, personnel rescue, as well as the evaluation of response times, in order to continuously enhance
operational readiness in real emergency situations.
It is a fact that the Group invests annually in safety measures, such as the provision of Personal Protective
Equipment (PPE), as well as in training activities and preparedness exercises. Mandatory emergency response
exercises are carried out for all employees in compliance with relevant legal requirements and cover key
emergency scenarios. Their frequency varies depending on the facility, but at least one drill is conducted each year
at all Group units. In 2025, 724 scheduled preparedness exercises were conducted, which included the
implementation of Internal Emergency Plans at all Group facilities, of which 122 took place at the industrial
facilities in Aspropyrgos, Elefsina, and Thessaloniki.
In addition to its legal obligations, the Group has undertaken further initiatives, including 486 emergency
preparedness exercises were conducted by Safety Engineers to ensure the operational readiness of employees at
the self-operated KALYPSO fuel stations, using various accident scenarios, such as fire in a tank, fire in a tank
room, and fuel leakage.
Moreover, the First Aid training delivered across Group companies has made a significant contribution to
enhancing preparedness and operational safety. Under the guidance of certified specialized instructors,
employees acquired critical knowledge and practical skills to respond promptly and effectively to emergency
situations. This initiative further strengthens the Group’s safe and responsible working environment. A total of
360 employees from Group companies participated in this training over the past two years. 18
Emergency plans
To deal with serious incidents such as fires, marine pollution, or malicious acts, the Group implements specialized
emergency plans for each facility, which are reviewed annually and incorporated into the Holistic Safety
Management System. At the same time, it systematically assesses the likelihood and severity of large-scale
industrial accidents, strengthening risk prevention and management through adequate resources, consultation
with stakeholders, and a comprehensive safety framework, in line with the principles of the Sustainability Policy
and the commitment of the Management team. Any incidents are promptly investigated and corrective actions
are implemented, including the revision of procedures, additional training, reinforcement of PPE, and equipment
upgrades. The effectiveness of these measures is monitored through KPIs, reporting mechanisms, and regular
emergency preparedness drills, ensuring that employees are protected and that remediation procedures operate
effectively in practice.
Comprehensive training and information program on Health and Safety issues
With the aim of protecting the health and safety of employees, a comprehensive training and information
program is implemented, which aims at the effective management of material impacts and risks related to these
issues. Basic training includes modules such as fire safety, rescue techniques, and first aid, while leadership
development programs are implemented for all hierarchical levels. Training is also extended to external partners,
customers, transporters, and fuel stations. In particular, employees working through contractors are required to
participate in training delivered by Safety Engineers and are then examined at accredited training centers. Only
those who successfully pass the certification process are allowed to work in industrial facilities. In addition, visitors
are informed through printed material and audiovisual media about the safety guidelines that apply at each
facility.
Health and safety training is mandatory for everyone and is conducted more intensively at high-risk facilities, such
as refineries and commercial units, with at least one training session per month. In 2025, a total of 94,416 man-
hours of training on health and safety issues were provided to employees and contractors, reflecting the
systematic investment in human and organizational resources to enhance safety and preparedness across the
Group.

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Review of Health and Safety systems across facilities in Greece
In 2024, the Group conducted an extensive review of its Health and Safety systems at its Greek facilities, which
was completed in 2025, following internationally recognized practices. This process involved a comprehensive
assessment of the improvements that had already been implemented and the identification of any gaps, so that
more effective solutions could be adopted and upgraded results achieved.
Actions relating to employee training and skills development
The Group offers training programs and continuous learning initiatives to enable all employees to develop
knowledge and competencies, whether specialized within their respective fields of responsibility or broader, such
as in Management, Information Technology, and other disciplines. The objective is to explore and expand
employees’ professional prospects, enhance their understanding of the Group’s strategic objectives, and help
them identify how they can contribute, through their respective roles, to the further advancement of these
objectives.
At the same time, through the Group’s Digital Academy, HELLENiQ Digital Academy, selected educational content
from the LinkedIn Learning platform is made available. The training material is categorized and distributed
according to employees’ job roles, with the aim of developing the specialized skills required in today’s modern
working environment. Employees are able to enhance both personal and professional competencies, familiarize
themselves with innovative tools and best practices in contemporary business operations, and engage with digital
learning technologies.
The HRis digital platform supports the Group’s employee training and development program. It encompasses the
full spectrum of learning activities and provides employees with access to a training library, visibility over their
complete learning history, integration of e-learning modules within the same platform with recorded participation,
documentation of on-the-job training, electronic submission and management of training requests, and
automated approval workflows and notifications for all types of learning activities.
In particular, during 2025, the Group Academy delivered Development Programs such as the Management Skills
Empowerment Program for New Executives. In addition, training sessions were conducted on topics including
Sustainability, Negotiations, Digital Training, and First Aid seminars.
Actions relating to Social Dialogue
Within the Group, meetings of the Internal Service for Protection and Prevention (ESYPP) are held twice annually,
with the aim of continuously strengthening safety, risk prevention, and employee wellbeing. The operation of the
ESYPP goes beyond formal compliance requirements, as companies or employees not legally obligated to
maintain an ESYPP also participate, thereby reinforcing intra-Group collaboration.
This expanded participation establishes a common framework for the exchange of knowledge, lessons learned
from incidents, experiences, and best practices, contributing to the consistent implementation of Health & Safety
policies across the Group and to the cultivation of a strong prevention culture.
At the same time, the ESYPP functions as a structured social dialogue mechanism, promoting systematic
communication between employees, safety technicians, occupational physicians, and management, as well as the
integration of employees’ views into decision-making processes. These procedures enhance transparency and
respond to requirements for active participation and consultation on matters affecting working conditions.
Group employees have full freedom to participate in collective representation bodies, such as trade unions and
professional associations. Through the operation of the ESYPP and other committees, freedom of association is
actively upheld, ensuring that employees may be represented, freely express concerns or proposals, and
participate in processes that affect their daily work.
This participatory approach strengthens transparency, fosters a climate of trust, and aligns with international
standards on the protection of labor rights. [ESRS S1-4-37] , [ESRS S1-4-38-(a), (b), (c), AR 42]
The effectiveness of actions is monitored and evaluated through systematic monitoring of targets and their
achievement, such as the zero accident target. For more information, please refer to section "Targets related to

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managing material negative impacts, advancing positive impacts, and managing material risks and opportunities".
[ESRS S1-4-38- (d), AR 38, AR 39]
Finally, the method used by the Group to determine the appropriate actions to take in response to existing or
potential negative consequences for employees involves multiple stages of monitoring and evaluation. Initially,
working conditions are continuously monitored through regular inspections, audits, and risk analysis in order to
identify priority areas. When a potential or actual risk is identified, a detailed investigation is carried out to
determine the cause and severity of the issue. Based on the findings, the Group implements targeted actions and
programs to minimize risks and protect the workforce. [ESRS S1-4-39, AR 34]
Addressing Material Risks
HELLENiQ ENERGY Group implements a specific approach to occupational risk management in order to protect
the health, safety, and well-being of its employees. It conducts Occupational Risk Management and implements
Holistic Safety Management Systems, largely certified to ISO 45001, with the aim of preventing, timely
information and effective response to risks for employees, partners, and local communities. Risk management is
supported by clear procedures, regular inspections, and training programs, ensuring the timely identification and
mitigation of risks. The effectiveness of actions is monitored through analysis and feedback, while targeted
initiatives are implemented to enhance safety, performance, and the overall quality of working conditions. [ESRS
S1-4-41, AR 37], [ESRS S1-4-40-(a)-(b), AR 44, AR 45]
Allocation of Resources for Managing Material Impacts
In 2025, the Group spent more than €21 million on safety improvement projects (entirely capital expenditures
(CapEx), as it is included in the Note 6 of the Financial Statements) across all its facilities, both in Greece and
internationally. This amount reflects the Group's commitment to enhancing safety, fire protection, and the
upgrading of systems in the workplace. It does not include the maintenance and the procurement of safety tools
and equipment, as well as the necessary firefighting materials and other consumables. At the same time, the
Group allocated more than €1.4 million for employee training and skills development programs. These resources
supported the implementation of targeted training programs on health and safety, equipment handling and
emergency situations, as well as professional and technical skills development and personal development
programs, enhancing the ability of staff to operate safely, effectively, and with continuous personal development.
These efforts demonstrate a holistic approach to protecting the Group's employees and operations. [ESRS S1-4-43]

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Metrics and Targets
S1-5 - Targets Related to Managing Material Negative Impacts, Advancing Positive
Impacts and Managing Material Risks and Opportunities
Targets around workforce
The Group sets annual, measurable targets for continuous improvement in H&S performance, employee training,
and communication with all stakeholders. These targets are linked to the Group's Sustainability Policy, reducing
risks and ensuring compliance with legislation.
In this context, an annual target has been established concerning the average number of training hours per
participant, which is required to exceed the average total training hours recorded over the previous three (3) years.
The target aims at continuous skills development, enhancing the professional development of employees, and
improving organizational performance.
At the same time, a target to maintain the voluntary turnover rate below 4% has been set, which is set as the
median value for a six-year period (2020-2026, for this year). In addition, a target has been set to increase the
number of women in management positions by 15% by 2026, setting 2023 as the base year, when the average
percentage of women in positions of responsibility in the Group (at management level) was 22.39%.The targets
are directly linked to the Group's Sustainability Policy, contributing to risk reduction, legal compliance, and the
creation of long-term value for all stakeholders.
Furthermore, with regard to H&S issues, KPIs are based on CONCAWE and utilize comparative analysis data to
guide strategy. Progress towards these targets is monitored regularly, with monthly and annual reports to
management. The main goal is to achieve zero fatalities and serious industrial accidents (these goals remain in
effect continuously), while the following targets have been set for 2030:
• Process Safety Event Rate (PSER): ranked in the second quartile of CONCAWE European comparative data,
achieving a significant reduction in process-related incidents and strengthening preventive safety. For
2025, like 2024, the Group’s performance falls within the second quartile, aiming to maintain it for the
coming years.
• Lost Workday Incident Frequency (LWIF) indicator: ranked in the second quartile of CONCAWE's European
comparative data, significantly reducing workplace accidents and enhancing employee protection and well-
being. For 2025, the Group’s performance falls within the third quartile, while during 2024 it was within the
second quartile.
• 100% Implementation Rate of the Holistic Safety Management System in all Group facilities, both in Greece
and abroad, with the long-term goal of standardizing and upgrading safety practices in all facilities.It is
currently applied to the majority of facilities in Greece, and its implementation is expected to be extended to
the Group’s international facilities.
To enhance the positive impact on the workforce, the Holistic Safety Management System mentioned above is
implemented, which includes annual reviews to maintain the effectiveness of safety measures and ensures
compliance with Greek, European, and international standards. At the same time, regular health monitoring and
support are provided by occupational physicians, while employees participate in regular training and specialized
programs in collaboration with international experts. [ESRS S1-5-46, AR 50, AR 51, AR 52]
The Group involves stakeholders in setting H&S, training, and social dialogue objectives to ensure they are realistic
and promote continuous improvement. Consultations with employees, safety experts, and partners ensure
alignment with the Group's strategy and industry’s best practices. On H&S issues, H&S committees in many
subsidiaries incorporate employee views. Progress is monitored through regular reviews and KPIs, including
accidents, health data, and completion of training and consultations. For the most critical targets, such as zero
serious accidents, monitoring is continuous, with committees being informed and involved when necessary.

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Based on the results of the KPIs, the Group makes continuous improvements. Feedback provided by employees
and H&S committees is incorporated into decision-making, ensuring that lessons learned and areas for
improvement are addressed promptly. [ESRS S1-5-47-(a)-(b)-(c)]
S1-6 - Characteristics of HELLENiQ ENERGY Group's employees
Dedicated to supporting and investing in our Workforce
Acquiring and retaining skilled personnel
The HELLENiQ ENERGY Group considers its human resources to be the foundation for growth and improvement
of overall performance in all areas of its activities. The Group focuses both on maintaining existing jobs and
creating new ones, thereby enhancing professional stability. Based on the values of meritocracy, excellence,
integrity, consistency, innovation, and continuous learning, the Group has created a modern and supportive
working environment. Through a comprehensive human resources development and management system,
opportunities for professional advancement, competitive compensation and benefits, systematic performance
evaluation, and training are provided. At the same time, employees are encouraged to take on a variety of roles
and maintain a balance between professional and personal time.
The HELLENiQ ENERGY Group is committed to transparent and meritocratic recruitment and evaluation systems,
equal opportunities for skills development, and fair advancement regardless of gender, age, origin, or religion. The
corporate culture promotes cooperation, dedication, and personal development among employees.
Our People Insights
Own Workforce
The tables below present the breakdown of employees by gender, region as well as type of employment contract
Table 1: Employee head count by gender

Gender | Number of Employees in 2025 (Head Count) | Number of Employees in 2024 (Head Count)
Male | 3,258 | 2,965
Female | 934 | 769
Total Employees | 4,192 | 3,734

The Group maintains a substantial workforce in Greece, comprising 3,618 employees. In accordance with the
ESRS, a workforce segment is deemed significant if it consists of at least 50 individuals and represents more than
10% of the total employee population. Within the industrial facilities operated by HELLENiQ PETROLEUM S.A., the
majority of the workforce consists of men, with 2,041 male employees out of a total of 2,288 employees, due to
the nature of the work and the high participation of men in these positions. The higher representation of men
relative to women can be ascribed to the specialized requirements and prevailing working conditions associated
with employment at these facilities.
The growth in the number of employees within the Group during the year 2025, in comparison to 2024, is
primarily attributable to the incorporation of Enerwave as a wholly-owned subsidiary of the Group, as well as the
establishment of two new companies, namely HELLENiQ Petroleum Trading S.A. and HELLENiQ Renewables
Romania S.R.L.

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Table 2: Employees by contract type, broken down by gender (head count)

Female | Male | Total
Number of permanent employees (headcount)
2025 | 2024 | 2025 | 2024 | 2025 | 2024
917 | 751 | 3,184 | 2,883 | 4,101 | 3,634
Number of temporary employees (headcount)
2025 | 2024 | 2025 | 2024 | 2025 | 2024
17 | 20 | 74 | 80 | 91 | 100
Number of non-guaranteed hours employees (headcount)
— | — | —

[ESRS S1-6-50-(a), (b)]
The total number of employees who left voluntarily or due to dismissal or retirement during the reporting period is
192, and the staff turnover rate is 4.7% during the reporting period, compared to 279 and 7.6% respectively in
2024. [ESRS S1-6-50-(c), AR 59]
Methodologies & Assumptions
The number of employees for 2025 refers to the per capita number and concerns the number at the end of the
reporting period, on 31.12.2025, while for the calculation of employees turnover, the average number of
employees during the reference period has been used. [ESRS S1-6-50-(d)-(i), (ii), AR 60]
Furthermore, it should be noted that there were no significant fluctuations in the number of employees during the
period in question or in comparison with previous years. [ESRS S1-6-50-(e), AR 58]
The total number of employees is reported in the Financial Statements in section A.5- Main Areas of Activity of
the Group, a) Financial Figures. [ESRS S1-6-50-(f)]
S1-7 - Characteristics of Non-Employee Workers in HELLENiQ ENERGY Group's Own
Workforce
Non- Employee Workforce
Characteristics of Non-Employees
Total Number of Non-Employees:
The total number of non-employees of the Group for 2025 is 102, while for 2024 it was 94. [ESRS S1-7-55-(a)]
Methodologies and Assumptions:
In order to cover temporary and seasonal operational needs at EKO and KALYPSO, the Group works with external
staffing agencies, which provide employees on a limited-term basis. The above number does not include
individuals working under contracts or through external service providers, as well as those working on a service
provision/service invoice basis, as according to Greek law, these employees provide independent services and not
dependent work. These employees can be counted in the category of employees in the value chain covered by
ESRS S2 (nonmaterial issue according to the DMA). It should be noted that employees of third-party companies –
external partners – are not controlled by the Group. The number of non-employees refers to headcount and
concerns the average number of non-employees during the reporting period. [ESRS S1-7-55-(b)-(i)-(ii)]

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Common Types of Non-Employees and Their Roles
Indicative activities – such as the following – are assigned to contractor companies:
• Tank truck drivers
• Aircraft refueling drivers [ESRS S1-7-56)]
S1-8 - Collective Bargaining Coverage and Social Dialogue
The percentage of employees covered by collective bargaining agreements is 73.8% for 2025 and 81.3% for 2024.
[ESRS S1-8-60-(a), AR 66]
Coverage in the European Economic Area (EEA):
The Group has five (5) collective bargaining agreements (HELPE, EKO, DIAXON, ASPROFOS, EKO CYPRUS) within
the European Economic Area. As mentioned above, the Group has significant employment in Greece, where the
percentage of employees covered by collective bargaining agreements amounts to 76%. [ESRS S1-8-60-(b)]
Coverage Outside the EEA
The Group has two (2) collective bargaining agreements (OKTA, JUGOPETROL) outside the EEA. The percentage
of employees covered by collective bargaining agreements in the Republic of North Macedonia is 92%, while in
Montenegro it is 100%.
Social Dialogue
Representation by Worker's Representatives:
The percentage of employees covered by employee representatives in Greece in 2025 is 74%, compared to 80%
in 2024. It is worth noting that Greece is the only EEA country where the Group has significant employment. [ESRS
S1-8-63-(a), AR 69]
European Works Councils:
So far, there has been no agreement with the Group's employees on representation through a European Works
Council (EWC), European Company (SE) Works Council or European Cooperative Society (SCE) Works Council. [ESRS
S1-8-63-(b)]

| Coverage by collective agreement | Social dialogue
Coverage percentage | Employees — EEA (for countries with > 50 employees representing > 10% of total workforce) | Representation in the workplace (only for the EEA) (for countries with > 50 employees representing > 10% of the total workforce)
| 2025 | 2024 | 2025 | 2024
0-19 % |  |  |  |
20-39 % |  |  |  |
40-59 % |  |  |  |
60-79 % | Greece |  | Greece |
80-100 % |  | Greece |  | Greece

[ESRS S1-8-60-(b), (c)] [ESRS S1-8-AR 70]

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S1-9 - Diversity Metrics
Diversity Matrix
Gender Diversity

Gender at top management level | Number | Percentage (%)
| 2025 | 2024 | 2025 | 2024
Female | 3 | 4 | 9 | 11
Male | 32 | 32 | 91 | 89

[ESRS S1-9-66-(a)]
Age Distribution across Our Workforce

Age group | Number | Percentage (%)
| 2025 | 2024 | 2025 | 2024
Under 30 years old | 198 | 145 | 5 | 4
30-50 years old | 2,788 | 2,364 | 66 | 63
Over 50 years old | 1,206 | 1,225 | 29 | 33

[ESRS S1-9-66-(b)]
Definition of Top Management for Gender Distribution
The Group's Senior Management is determined based on the organizational chart and includes all executives who
are two levels below the administrative and supervisory bodies. Specifically, this includes the General Managers,
the Directors of the main operating units (refining and domestic marketing), the Heads of the operating units, and
any other person with a higher position than them. [ESRS S1-9-AR 71]
S1-10 - Adequate Wages
All Group employees receive salaries that exceed the minimum limits set by national legislation, collective
bargaining agreements, and professional agreements, without any discrimination or differentiation between
employees. This ensures that remuneration is adequate in all countries where the Group operates. [ESRS S1-10-69, ,
AR 72, AR 73, AR 74], [ESRS S1-10-70]
S1-11 - Social Protection
Employee Social Protection Coverage by Country
All Group employees enjoy full social protection, either through public programs or through benefits offered by
the Group. This coverage includes protection against loss of income due to illness, unemployment from the start
of employment, accidents at work, disability, parental leave, and retirement. [ESRS S1-11-74-(a), (b), (c), (d), (e), AR 75]
S1-12 - Persons with Disabilities
The Group employs 39 employees with disabilities, ensuring full equality of opportunity in employment and
training. This practice reflects the Group's overall commitment to creating a fair and supportive working
environment for all. In 2025, the percentage of employees with disabilities in the Group's workforce reaches 0.9%,
compared to 0.3% in 2024. [ESRS S1-12-79]
Contextual Information and Methodology
The Group employs persons with disabilities in accordance with the legal definitions of persons with disabilities in
the countries in which it operates. This ensures compliance with regional labor regulations and guidelines for the
inclusion of persons with disabilities. [ESRS S1-12-AR 76 (a)]

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There are no significant differences in the legal definitions of persons with disabilities between the countries
where the Group operates. [ESRS S1-12-AR 76 (b)]
S1-13 - Training and Skills Development Metrics
Training and Skills Development
Performance and Career Development Reviews and Average Training Hours per Employee

Gender | % of employees that participated in regular performance and career development reviews
| 2025 | 2024
Female | 98 | 93
Male | 99 | 98
Total | 99 | 191

Gender | Average number of training hours per employee
| 2025 | 2024
Female | 20.4 | 29.4
Male | 37.4 | 43.6
Total | 33.6 | 40.7

[ESRS S1-13-83-(a), (b), AR 77, AR 78]
It is noted that, for 2025, the training hours do not include the employees of the two new companies (HELLENiQ
Petroleum Trading S.A. and HELLENiQ Renewables Romania S.R.L.).
The Group ensures equal training opportunities for all employees regardless of their specialty. In industrial
facilities, where the majority of staff are men, average training hours are slightly higher, reflecting the nature of
the work and the safety and skill requirements it imposes.
19 The security performance of KALYPSO KEA S.A. is included.
20 CONservation of Clean Air and Water in Europe (European Organisation for Helath, Safety and the Environment in the oil sector).
Note: CONCAWE data for 2025 will be available in July 2026.

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S1-14 - Health and Safety Metrics

Health and Safety Metrics | HELLENiQ PETROLEUM S.A. | EKO/HQ | SUBSIDIARIES * | GROUP
| 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024
The percentage of people in its own workforce who are covered by the undertaking’s health and safety management system based on legal requirements and/ or recognised standards or guidelines (%) | 100 | 100 | 100 | 100 | 100 | 100 | 100 | 100
Number of fatalities in own workforce as result of work-related injuries and work-related ill health (n) | — | — | — | — | — | — | — | —
Number of fatalities as result of workrelated injuries and work-related ill health of other workers working on undertaking's sites (n) | — | — | — | — | — | — | — | —
Number of recordable work-related accidents for own workforce (n) | 16 | 15 | 0 | 2 | 10 | 1 | 26 | 18
Rate of recordable work-related accidents for own workforce | 4.09 | 4.10 | 0.00 | 1.44 | 5.66 | 0.58 | 3.73 | 2.66
Number of cases of recordable work-related ill health of employees (n) | — | — | — | — | — | — | — | —
Number of days lost to work-related injuries and fatalities from work-related accidents, work-related ill health and fatalities from ill health related to employees (n) | 318 | 222 | 0 | 66 | 299 | 0 | 617 | 288

*In subsidiaries it is included: DIAXON, ASPROFOS, EKO CYPRUS, EKO SERBIA, EKO BULGARIA, JUGOPETROL, OKTA, HELLENiQ RENEWABLES,
ENERWAVE, HELLENiQ UPSTREAM, HELLENiQ ENERGY CONSULTING, ELPE FUTURE, HELLENiQ ENERGY DIGITAL, VARDAX, ELPET VALKANIKI
& EKO AFRODITI
[ESRS S1-14-88- (a), (b), (c), (d), (e)]
In 2025, the Lost Workday Injuries Frequency (LWIF) and the All Injury Frequency (AIF), which are key indicators
for the safety performance of employees and external partners, increased by 63.8% and 11.4% respectively
compared to the previous year. This increase is attributed to injuries of lower severity, considering also that the
Lost Workday Severity index has significantly decreased in recent years and remains below the corresponding
European index.
Furthermore, the Process Safety Event Rate (PSER), which is the main process safety indicator, decreased by
27.9% compared to the previous year, with its value falling below the corresponding European benchmark.
The following charts show the evolution of the Group's most important indicators (HELLENiQ PETROLEUM S.A. &
EKO 19) compared to the corresponding CONCAWE indicators for the last 6 years. The data presented covers all
employees and external partners, as defined by CONCAWE. 20

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S1-15 - Work-Life Balance Metrics
All employees (100%), regardless of gender, are entitled to take leave for family reasons. Categories of leave for
family reasons include maternity leave, paternity leave, parental leave, and leave to care for relatives. In 2025, 12%
of the Group's employees took leave for family reasons. The table below presents the relevant data by gender for
2025.[ESRS S1-15-94]

Gender | % of employees who are entitled to take leave for family-related reasons | % of employees per gender who took leave for family-related reasons
| 2025 | 2024 | 2025 | 2024
Female | 100 | 100 | 13 | 13
Male | 100 | 100 | 11 | 9

[ESRS S1-15-93-(a), (b)]
To calculate the percentage of employees per gender who took family-related leave, the total number of
employees per gender was taken into account for each denominator.
S1-16 - Remuneration Metrics (Pay Gap and Total Remuneration)
The Group implements a remuneration system that does not discriminate on the basis of gender. In support of the
principle of equality, there are no differences or injustices in remuneration in any of the Group's companies. In
2025, the gender pay gap within the Group is recorded at 19.22%, while in 2024 it was 23.35%. [ESRS S1-16-97-(a), AR
98, AR 99, AR 100]
It is therefore clear that HELLENiQ ENERGY maintains an impartial and transparent remuneration system in all its
activities. The ratio of the annual total compensation for the organization's highest-paid individual to the median
annual total compensation for all employees (excluding the highest-paid individual) within the Group is 30.68 for
2025, while in 2024 it was 28.41, reflecting a consistent approach that links remuneration to performance,
responsibilities, and current market standards. This ratio highlights the Group's commitment to a fair and
competitive working environment, in full accordance with its values of equality and compliance with national and
European standards. [ESRS S1-16-97-(b), AR 101]
Provision of Information
HELLENiQ ENERGY Group implements a remuneration system that is completely gender-neutral, based on
annual evaluations and in accordance with national and European legislation on equal pay. It has established and
maintains a Remuneration Policy for members of the Board of Directors, which is aligned with the Group's
strategy, objectives, and sustainability. This policy was approved by the Extraordinary General Meeting of
Shareholders on December 20, 2019, and updated, for second time, by a decision of the Annual General Meeting
on June 27, 2024. It sets the framework for total annual gross remuneration, divided into fixed and variable
components, where variable remuneration is linked to individual performance and contribution to the
achievement of the Group's objectives. This policy ensures transparency and meritocracy through predefined,
measurable quantitative and qualitative targets, in accordance with the principles of the Group's Executive
Remuneration Policy. [ESRS S1-16-97-(c)]

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S1-17 - Incidents, Complaints and Severe Human Rights Impacts
Workplace Incidents and Complaints & Serious Human Rights Violations
In 2025, the HELLENiQ ENERGY Group further strengthened its commitment to ethical practices and respect for
human rights in all its activities. For another year, the Group did not record any incidents of discrimination in its
companies. There was one isolated incident involving behavior that was not in line with the Group's values and
respect framework, for which the relevant investigation and management procedures were immediately activated
and appropriate measures were taken, in accordance with the applicable regulatory and internal framework. All
reports submitted through internal channels or problem reporting mechanisms available to employees were
successfully addressed with full respect for transparency, confidentiality, and fair treatment of all involved, as
defined by the Group's principles and corresponding policies. Furthermore, there were no serious human rights
violations, such as forced labor, human trafficking, or child labor, and no fines, penalties, or compensation for
related damages were imposed. These results reflect the Group's ongoing efforts to maintain a working
environment based on respect, equality, and inclusion. [ESRS S1-17-103-(a), (b), (c), (d)] [ESRS S1-17-104-(a), (b), AR 103, AR 104, AR
105, AR 106]

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ESRS S3 - Affected Communities
Strategy
ESRS 2 SBM 3 - Material IROs and their Interaction with Strategy and Business Model
The identified impacts on affected communities are inherently linked to the strategy and business model of the
HELLENiQ ENERGY Group. The communities identified as affected by the Group’s activities are the following:
• The neighboring municipalities of Thriassio in Western Attica, Western Thessaloniki, and the Municipality of
Kozani, which are considered areas of particular significance due to their proximity to the Group’s facilities.
• Local suppliers, namely stakeholders whose headquarters are located within the municipalities neighboring
the Group’s facilities, as well as domestic suppliers serving the Group’s other companies.
• Residents living in areas close to the refineries, who are affected by the Group’s activities and operations.
[ESRS S3-SBM-3-9-(a(i)-(iii)]
Creating employment opportunities, promoting economic value across all its activities and throughout its supply
chain, and working closely with local suppliers, the Group supports economic development and social well-being,
while at the same time it fosters skills development and local economic inclusion. The identified impacts inform
and contribute to the adaptation of the Group’s strategy, emphasizing the importance of workforce stability and
long-term economic resilience, with the aim of sustainability.
The Group makes a substantial contribution to the Greek economy through its interactions with suppliers,
customers, consumers, affected communities and the Greek State. In particular, its social and economic impact is
reflected in the following positive impacts:
• The Group creates local employment opportunities in underserved areas, directly strengthening income,
skills and economic activity.
• Its activities generate a significant direct positive impact on affected communities through direct, indirect
and induced taxes, contributions to GDP and economic benefits arising from payments to suppliers.
• Its material initiatives directly and indirectly promote the creation of shared value, strengthening social well-
being, supporting vulnerable groups and advancing sustainable infrastructure, thereby enhancing
community resilience and improving overall quality of life.
• The Group actively collaborates with local suppliers and contractors, directly and indirectly supporting the
development of local entrepreneurship and creating employment opportunities.
The Group remains firmly committed to promoting economic value and reducing negative impacts on affected
communities. During the reporting period, two negative impacts were identified, one actual and one potential,
with the latter assessed as material across all time horizons. The first relates to refining processes, an activity that
may affect the environment of neighboring communities through, indicatively, air emissions and noise. The
second impact concerns the increased potential risk of accidents due to the nature of the production activities at
the Group’s large industrial facilities, which could potentially adversely affect local communities in the areas of
health, safety and the environment. [ESRS S3-SBM-3-9-(b)]
Furthermore, it is disclosed that, based on the DMA, the Group has not identified material risks or opportunities
and dependencies that relate exclusively to specific social groups.
In particular, the HELLENiQ ENERGY Group focuses on the following pillars in order to actively support affected
communities:

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Employee support initiatives
The Group systematically considers local residency as a key criterion in recruitment processes in the areas where it
operates. The neighboring municipalities of Thriassio in Attica, Western Thessaloniki and the Municipality of
Kozani are therefore areas of particular importance, and the Group provides 717 jobs in these municipalities.
Local supplier support initiatives
Local suppliers are stakeholders whose headquarters are located within the municipalities neighboring the
Group’s industrial facilities, such as HELLENiQ PETROLEUM S.A., DIAXON and the KOZILIO 1 photovoltaic station
in Kozani. In addition, local suppliers are also defined as domestic suppliers serving the Group’s other companies,
including commercial activities, hydrocarbon exploration and production, as well as renewable energy projects.
[ESRS S3-SBM-3-9-(a)]
The share of procurement from local communities amounts to 11.9% for HELLENiQ PETROLEUM S.A., DIAXON
and the KOZILIO 1 photovoltaic plant, whereas for the Group’s remaining entities, procurement from local
suppliers corresponds to 92.4% of the total value of purchases. It is noted that these percentages exclude
expenditure related to the procurement, transportation and storage of raw materials and intermediate products,
as well as costs related to water, energy, telecommunications, intra-group transactions and payments to public
authorities, social security funds and insurance companies.
Corporate Responsibility initiatives
With regard to Corporate Responsibility initiatives, the Group treats them as a priority, recognizing their decisive
role in strengthening social cohesion and supporting affected communities. The Group’s actions are designed to
deliver meaningful and long-term added value to society and are characterized by responsibility, empathy and a
consistent commitment to the residents of the areas in which it operates.
Based on its defined action areas and its Sustainable Development strategy, the Group has developed a
comprehensive and multidimensional Corporate Responsibility program, tailored to the needs of stakeholders,
aiming to promote social well-being, protect the environment and ensure an immediate and effective response to
emergency situations.
Specifically, through its Corporate Responsibility programs, the Group has set the following targets:
• Environmental protection
• Supporting young people in their education and development, as well as improving the educational
environment
• Ensuring decent work and promoting economic growth
• Fighting hunger
• Upgrading existing infrastructure and creating new, innovative infrastructure for sustainable cities
• Ensuring good health and well-being
In this way, the Group contributes to achieving significant positive impacts for affected communities and,
consequently, to advancing the corresponding UNSDGs. [ESRS S3-SBM-3-9-(c)]
During the reporting period, the Group continued to consistently support its vision of delivering added value to
society through actions, activities and initiatives, as described in section “S3-4 – Taking Action on Material
Impacts on Affected Communities, and Approaches to Managing Material Risks and Pursuing Material
Opportunities Related to Affected Communities, and Effectiveness of Those Actions”.
It is worth noted that Corporate Responsibility programs are designed on a regional basis, following open dialogue
with stakeholders, public opinion surveys, studies identifying material impacts, as well as public discussions and
other forms of consultation.
21 It is noted that the Group’s affected local communities do not include Indigenous peoples.

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In summary, as stated above, the Group’s business activities are inextricably linked to neighboring communities 21,
which it supports in a meaningful and long-term manner through social programs that create value and address
their diverse needs. [ESRS S3-ESRS 2 SBM-3-9-(a)-(i)-(iii)]
The DMA indicated that certain communities may be exposed to a higher risk of negative impacts. Therefore, the
Group pays particular attention to communities located near its industrial facilities and to vulnerable social groups
participating in the Group’s production processes or value chain.
The Sustainable Development Team, within the framework of external engagement with representatives of
affected communities and taking into account the findings of social and environmental studies, developed a
comprehensive understanding of potential local risks and community concerns.
This approach enables the implementation of targeted actions that strengthen responsible operations and the
protection of health and the environment, while ensuring the preservation of social well-being and quality of life in
affected communities. [ESRS S3-SBM-3-10]

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Impact, Risk and Opportunity Management
S3-1 - Policies Related to Affected Communities
The Sustainability Policy and the Code of Conduct constitute the framework for managing material impacts, risks
and opportunities and apply to all affected communities, both in the local communities where the Group operates
and in the broader communities in Greece and abroad.
The Sustainability Policy, among other aspects, contributes to the creation of value for the Group and society
through stakeholder engagement. In its development and implementation, the views of key stakeholders are
taken into account, including employees, local communities, suppliers, customers and public authorities, as the
Group is committed to prioritizing community development and to continuously engaging with stakeholders to
ensure their views are considered. Further information regarding the Minimum Disclosure Requirements of the
Sustainability Policy is provided in chapter ESRS E1 – Climate Change.
The Group’s Code of Conduct emphasizes responsible business practices, actively contributing to the sustainable
development of both local and broader communities within and outside Greece, as well as to the protection of the
natural environment. Through its operations and partnerships, the Group seeks to create long-term value for
communities affected by its activities, strengthening relationships of trust and its positive social contribution.
Further information regarding the Minimum Disclosure Requirements of the Code of Conduct is provided in
chapter ESRS S1 – Own Workforce. [ESRS S3-1-14]
The Sustainability Policy and the Code of Conduct commit to adhering to internationally recognized standards,
such as the United Nations Guiding Principles on Business and Human Rights, the International Labor
Organization Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for
Multinational Enterprises. Alignment with these standards is monitored through human rights due diligence
processes, reporting and grievance mechanisms, as well as periodic internal audits and compliance assessments,
under the oversight of Management and the competent corporate governance bodies. In particular, during the
reporting period, no instances of non-compliance with the above, concerning affected communities and recorded
in the value chain, were identified. [ESRS S3-1-17, AR 10]
HELLENiQ ENERGY does not operate in areas adjacent to indigenous communities; hence, there are no specific
policy provisions for preventing and addressing impacts on indigenous populations. [ESRS S3-1-15]
In addition, the Group is committed to complying with institutional and international initiatives, aligning with the
United Nations Global Compact and the Greek Sustainability Code, and providing publicly accessible data through
the “Communication on Progress” questionnaire. Furthermore, the Group promotes human rights, respects
diversity and equality, and eliminates all forms of discrimination throughout its value chain, including local
communities, consumers and partners. [ESRS S3-1-16-(a)]
Beyond external engagement with representatives of affected communities, the Group maintains active dialogue
and continuous communication with the affected communities themselves. Informational meetings and public
opinion surveys are organized on a regular basis to collect useful insights, and newsletters ensure that
stakeholders are regularly informed about the Group’s developments and initiatives. Partnerships with local
organizations further strengthen the positive impacts of its activities. In parallel, day-to-day communication is
supported through press publications, official statements and updates available in the Media Center section of the
Group’s website. [ESRS S3-1-16-(b)]
The Group has established and implements specific procedures governing its collaborations, ensuring that
partners comply with labor legislation (national, European and ILO) and respect human rights and working
conditions. The cooperation framework requires compliance with the Code of Conduct, Procurement Regulations,
policies and procedures promoting health and safety, commitment to environmental standards, responsible labor
practices and respect for human rights, as well as an evaluation process. Additionally, partners are selected and
assessed for inclusion in the Group’s supplier list not only on the basis of business criteria but also health and
safety criteria. This ensures alignment with the Group’s commitment to sustainable practices across all its
activities. More specifically, suppliers are committed to adhering to the principles of the United Nations Global
Compact in the areas of human rights, labor, the environment and anti-corruption.

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To address potential adverse impacts on human rights, the Group has established a grievance and complaints
management mechanism through which affected communities can raise concerns. These processes strengthen
transparency, accountability and the continuous improvement of the Group’s contribution. [ESRS S3-1-16-(c)]
S3-2 - Processes for Engaging with Affected Communities about Impacts
Engagement with affected communities takes place either directly with the communities or their legal
representatives, or through intermediaries, depending on the purpose of the communication or initiative.
Interaction occurs at various stages, starting with consultation to identify potential environmental and social risks,
followed by the integration of views into the strategy and the design of initiatives, and continuing throughout
implementation to monitor impacts and adjust actions. Engagement includes informational meetings, public
opinion surveys, newsletters, partnerships with local organizations, as well as ongoing dialogue through press
publications and statements, ensuring transparency and responsiveness to community concerns. Further
information regarding the frequency of communication with local communities is provided in section General
Disclosures – ESRS 2: "SBM-2 – Interests and Views of Stakeholders".[ESRS S3-2-21-(a)] , [ESRS S3-2-21-(b)]
The Group’s Corporate Relations and Corporate Social Responsibility Divisions are responsible for ensuring
engagement with affected communities. They play a key role in the design, implementation and oversight of
engagement strategies, ensuring that feedback is integrated into the Group’s operations, policies and initiatives
for the effective management of material impacts, risks and opportunities. These Divisions hold operational
responsibility for overseeing the effective execution of engagement activities and for integrating the information
collected into the overall Corporate Responsibility strategy, as well as into decision-making processes for related
initiatives and projects. [ESRS S3-2-21-(c)]
The Group has tools in place, such as a telephone hotline, a contact form on its website and an email address, to
ensure the continuous collection of feedback and the improvement of its initiatives. The outcomes of
engagement with affected communities are used to shape the Group’s initiatives and, where required, lead to
specific agreed actions, impact mitigation measures and initiatives supporting local communities. [ESRS S3-2-21-(d)]
As previously mentioned, the Group conducts public opinion surveys to understand the views of local and affected
communities, including groups that may be more vulnerable, such as women, children and members of local
communities who may be affected by natural disasters or by the Group’s activities. The findings of these surveys
are taken into account in the design and adjustment of Corporate Responsibility actions, ensuring the protection
and empowerment of vulnerable groups. [ESRS S3-2-22]
As stated above, the HELLENiQ ENERGY Group does not operate in areas neighboring indigenous peoples. [ESRS
S3-2-23]
The active support of society through actions and initiatives that improve everyday life and contribute to social
progress and well-being, are an integral part of HELLENiQ ENERGY Group 's corporate philosophy. It is worth
noting that the Group's business activity is inextricably linked to the local communities in which it operates, and
which supports substantially and in the long term with social programs that create value and respond to the needs
of Greek society. For this reason, investing in and linking with the local communities in which the Group operates is
one of its priorities and one of the essential issues on its path towards Sustainable Development.
S3-3 - Processes to Remediate Negative Impacts and Channels for Affected
Communities to Raise Concerns
The Group has established procedures and frameworks to identify, manage and remediate cases where it is
determined that it has caused or contributed to material adverse impacts on affected communities. These
procedures include engagement with affected communities to identify and determine appropriate remediation
measures, which are monitored for their effectiveness and responsiveness to community needs. The
effectiveness of remediation measures is assessed through KPIs, periodic progress reviews and feedback from
affected communities. [ESRS S3-3-27-(a), AR 17]
At the same time, the Group provides communication channels (telephone hotlines and electronic platforms)
through which affected communities can submit concerns or needs. These channels ensure direct
communication and the timely handling of issues arising from adverse impacts. [ESRS S3-3-27-(b), AR 18]

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The availability of these communication channels is further strengthened through the Group’s business
relationships, as it encourages partners to implement similar procedures and facilitate the reporting of concerns
by local communities, thereby ensuring their accessibility and effectiveness. [ESRS S3-3-27-(c)]
Submitted issues are recorded, categorized by type and location and monitored until their final resolution. The
effectiveness of the communication channels is evaluated on a regular basis through internal reviews, analysis of
indicators (e.g. response time, resolution rate) and structured feedback collected from affected communities and
users of the channels. The results are used to improve accessibility and usability so that the channels effectively
respond to stakeholder needs. [ESRS S3-3-27-(d), AR 24]
The Group strengthens the trust of affected communities as, through regular consultations with the communities
and their representatives, as well as through the available channels, it receives and manages a significant number
of requests. In accordance with the Group’s Whistleblowing Policy, any behavior that constitutes retaliation in
connection with the submission of a report is not permitted. Awareness and stakeholder trust in the mechanisms
are continuously assessed through ongoing discussions and direct feedback, ensuring that there is sufficient
awareness of the relevant process. [ESRS S3-3-28, AR 23], [ESRS S3-3-27-(a), AR 17]
S3-4 - Taking Action on Material Impacts on Affected Communities and Approaches
to Managing Material Risks and Pursuing Material Opportunities Related to Affected
Communities and Effectiveness of those Actions
Action on material impacts on affected communities
The Group annually assesses the social and economic footprint of its activities in Greece, covering both its direct
operations and its entire supply chain. The analysis is conducted systematically on an annual basis, providing
comparability and documenting its long-standing and continuous contribution to the Greek economy. Since 2021,
the assessment has been carried out with the support of an independent scientific body and is based on an
internationally recognized input–output methodology, using official data from third-party sources.
Particular emphasis is placed on value creation at the local level, with notable examples including the Thriassio
Plain and the Regional Unit of Thessaloniki, where measurable impacts are recorded. Overall, based on the latest
analysis by the Foundation for Economic and Industrial Research (IOBE) for 2024, at the local level the Group
supported more than 7,000 jobs — direct, indirect and induced — with total income amounting to €180 million,
contributing to local value added exceeding €870 million.
The Group’s documented socio-economic contribution is accompanied by targeted Corporate Responsibility
initiatives aimed at generating a positive contribution to the local communities where it operates, in Greece and
abroad. In this context, for example, the following actions were implemented in 2025 in relation to affected
communities:
Empowering Youth Program
The HELLENiQ ENERGY Group’s Empowering Youth Program is a strategic, long-term initiative aimed at
meaningfully empowering the younger generation through investment in excellence, education, specialization
and innovation. It has been implemented systematically since 2009 and covers key geographical areas where the
Group operates, addressing secondary school students and local communities, while also having nationwide
reach, targeting university students, young scientists and the academic community. The program is structured
around three main pillars: rewarding top-performing graduates of General and Vocational Upper Secondary
Schools from Thriassio in Attica, Western Thessaloniki and the Municipality of Kozani who have been admitted to
tertiary education; providing scholarships for postgraduate studies in Greece and abroad; and developing a
knowledge and innovation ecosystem through a Centre of Excellence and an Alumni community. Since its launch,
more than 5,700 students have been rewarded for their academic performance, and over 350 scholarships have
been granted to highly reputable universities, with total investment exceeding €15 million. In 2024, the
scholarship program was further expanded, and in 2025 it was implemented by the Group’s subsidiaries in Cyprus,
Bulgaria, Montenegro and the Republic of North Macedonia.
In parallel, through the establishment of the HELLENiQ ENERGY Alumni community and the operation of the
Centre of Excellence for Energy and Sustainable Development in collaboration with ALBA Graduate Business

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School, Empowering Youth strengthens the link between education, research and the labor market, contributing
with measurable results to the development of specialized human capital and the creation of equal opportunities
for the younger generation.
Environmental Interventions and Awareness-Raising Actions
Since 2022, the Group has implemented a coherent framework of environmental programs and awareness-raising
actions aimed at activating and empowering local communities, primarily in Western Thessaloniki and the
Thriassio Plain, through projects delivering tangible environmental upgrades and experiential education initiatives
focused on the younger generation. Actions include clean-ups of public spaces, upgrades of parks and communal
areas, green interventions and educational activities on biodiversity and climate change. During the period 2022–
2024, more than 3,600 students and 420 employees participated, over 3.5 tonnes of waste were collected, more
than 300 trees and plants were planted and green areas totaling 2,300 m² were upgraded. In 2025, actions
continued, with more than 1,000 students participating in educational programs in collaboration with the
organizations Agoni Grammi Gonimi, The Bee Camp and MIO–ECSDE. In parallel, Enerwave implemented the
“Green Schools” program (OpenFarm & Elculture), promoting environmental education through school gardens,
experiential workshops and energy-saving actions, strengthening the role of teachers as knowledge multipliers
and enhancing the participation of the school community.
Moreover, the Group strengthened restoration interventions following natural disasters. Under the framework of
the Forest Restoration and Reforestation Sponsorship scheme, over the past three years more than 32,000
hectares of burned forest areas were restored through anti-erosion works. In 2024, actions in Western Attica were
completed, and in 2025 in Rapentosa, Marathon. Furthermore, in 2025, new reforestation projects were carried
out in the Municipalities of Penteli and Pallini (a total of 121.73 hectares and more than 5,000 trees), with the
participation of 130 employee volunteers and their families. Moreover, Enerwave, in cooperation with the
organization We4all, has developed initiatives to mobilize communities in environmental restoration and
awareness actions and supported the operation of the Kokkinomilia Environmental Information Centre,
strengthening sustainable local development and environmental education in areas of Northern Evia affected by
natural disasters.
In Cyprus, through EKO Cyprus, emphasis was placed on actions to enhance the operational readiness of the Fire
Service through the provision of rescue equipment, a patrol vessel and specialized training for personnel,
contributing to more effective forest fire management. Similarly, in Greece, Enerwave, supported Civil Protection
bodies through the donation of a vehicle for transporting personnel and materials to a volunteer association,
improving operational preparedness and response time in emergency situations. In the Republic of North
Macedonia, through OKTA, photovoltaic systems were installed in 2025 on the rooftops of schools, educational
institutions, social structures and public bodies, enhancing energy autonomy as part of efforts to reduce the
environmental footprint, while indirectly providing students with opportunities to familiarize themselves with the
principles of clean energy and sustainable development. Overall, these interventions contribute to improving
quality of life, protecting the environment and creating more resilient and sustainable communities.
Contribution to the Promotion of Sports
The Group consistently supports inclusive sport as a healthy outlet for all, especially the younger generation, by
backing institutions and initiatives with a strong impact in Greece and abroad.
The Group maintains a long-standing partnership with the Hellenic Paralympic Committee, which was renewed
and upgraded in 2024 and further expanded in 2025. In 2025, three Paralympic Panorama events were organized
in Athens, the Thriassio Plain and Western Thessaloniki, engaging students and local communities, actively
promoting equality, inclusion and sport without discrimination, and contributing to the promotion of the
Paralympic movement.
At the same time, EKO has continued for more than ten years to support the Hellenic Basketball Federation,
strengthening, as Grand Sponsor, the National Basketball Teams (Men’s, Women’s and Youth) and children’s
participation through the structured development program “Galanolefka Asteria”. The program offers thousands
of boys and girls aged U13 and U14 from across Greece the opportunity to engage with the sport, fostering values
such as teamwork, cooperation, respect and fair play.

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In 2025, EKO continued its long-standing support of the EKO Acropolis Rally as Grand Sponsor and Title Sponsor
in the field of motorsport. The company contributed to the return of the iconic rally to the WRC in 2021 and to
maintaining its international presence, generating a positive impact on local communities at national level. The
2025 event expanded across Corinthia, Central Greece, Thessaly and the center of Athens. At the same time, EKO
highlighted the issue of road safety through targeted information and awareness initiatives in cooperation with
competent authorities.
The year 2025 marked a milestone as it signified the Group’s first international sponsorship presence in tennis,
through support of events such as the Davis Cup and ATP 250 tournaments, expanding the company’s footprint
in high-profile international events. In parallel, through its international subsidiaries, EKO Serbia, EKO Bulgaria and
Jugopetrol continued in 2025 to support national federations, events and development programs, promoting fair
competition, particularly among the younger generation.
Improvement of Living Conditions
The Group consistently implements targeted initiatives aimed at improving the living conditions of vulnerable
social groups, with a focus on covering basic needs such as heating, food security and access to essential
healthcare services, thereby actively strengthening social cohesion in the areas where it operates. In Greece, in
2025 the heating oil donation program “Kyma Zestasias” (“Wave of Warmth”) continued for the 17th consecutive
year. Through this program, 275,000 liters of heating oil were distributed to 160 public school units in neighboring
municipalities in the Thriassio Plain, Western Thessaloniki and Western Macedonia, ensuring decent learning
conditions for thousands of students. In parallel, in 2025 the Group continued its support program for social
grocery stores and soup kitchens, providing significant quantities of food and other essential goods to structures
in the Thriassio Plain, Western Thessaloniki and Kozani.
Within the same framework of strengthening the resilience of local communities, in 2025 the HELLENiQ ENERGY
Group donated a state-of-the-art four-wheel-drive ambulance to the West Fragkista Health Centre of the 5th
Health Region of Thessaly and Central Greece, substantially enhancing the provision of emergency pre-hospital
care to remote and mountainous communities in Evrytania. The ambulance supports the operation of the Health
Centre and the 18 Regional Medical Units under its supervision, in an area with particularly demanding
geographical and climatic conditions. This intervention follows a previous donation of modern medical equipment
to the 5th Health Region of Thessaly and Central Greece in response to the consequences of the devastating floods
of September 2023. In the same context of supporting vulnerable social groups, Enerwave supported social
inclusion and health initiatives. Through the action “Donate Kilometres to Syozoia”, in collaboration with the
organization Syzoi, participation was converted into financial support for the Early Childhood Intervention
Program for children with visual impairments.
In Cyprus, through EKO Cyprus, the heating campaign “Zesti Agkalia” (“Warm Embrace”) for social structures in
mountainous areas continued in 2025. In Bulgaria, EKO Bulgaria provided heating oil to protected facilities for
persons with disabilities, while in Serbia and Montenegro, through EKO Serbia and Jugopetrol, donations were
implemented to support children and social institutions. At the same time, in the Republic of North Macedonia,
through OKTA, the provision of heating fuel to SOS Children’s Villages continued in 2025. Overall, these
interventions make a substantial contribution to improving the daily lives of vulnerable groups, reducing social
inequalities and strengthening the resilience of local communities in Greece and abroad.
Employee Volunteering
The Group consistently promotes volunteering as an integral part of its corporate culture, encouraging the
systematic participation of its employees in organized actions of social solidarity, environmental protection and
social care in Greece and abroad. In 2025, a total of 1,128 employees participated in volunteer activities in the
countries where the Group operates, of whom 862 participated in Greece and 266 abroad.
On the occasion of International Women’s Day, the expansion and refurbishment of the WEHub – Female
Empowerment Hub of the Women Entrepreneurship Association of Greece (SEGE) in Thessaloniki was completed.
The hub is a multifunctional 600 m² space providing education, mentoring and skills development services to
women from Western Thessaloniki and the wider area. The initiative was supported by the active participation of
employee volunteers in renovation works and in equipping the creative activity spaces. In addition, during the

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Christmas festive period, employees participated in initiatives supporting social grocery stores and social care
structures, contributing to meeting the basic nutritional and social needs of vulnerable groups.
In the field of sports, in 2025, 474 employee volunteers participated in national and international marathons in
Greece and abroad, linking their participation with support for social organizations and the promotion of solidarity
messages. In Serbia, 16 employees of EKO Serbia participated in the Belgrade Marathon, supporting the work of
the organization BelHospice.
In the environmental sector, volunteer tree-planting and reforestation activities were implemented in Greece and
abroad. In Greece, 134 employee volunteers and their family members participated in tree-planting actions in the
areas of Penteli and Pallini, contributing to the restoration of more than 120 hectares and the planting of 625
trees. In addition, in 2025 volunteer beach clean-ups were organized in cooperation with local authorities at the
Aspropyrgos beach in Western Attica and at Kalochori in Western Thessaloniki, with the participation of more
than 170 employees and their family members, during which more than 1,500 kilograms of waste and 5,570
cigarette butts were collected. Similarly, in the Republic of North Macedonia, 150 OKTA employee volunteers
participated in tree-planting actions, strengthening urban green spaces and raising environmental awareness in
local communities.
In the health sector, the Group continued to systematically support voluntary blood donation. In 2025, the
network of active volunteer blood donors numbered 403 employees, of whom 395 were in Greece and 8 in Serbia.
Through organized blood donation drives, more than 400 units of blood were collected, covering over 200 needs,
while the provision of one additional day of leave for each participation serves as a measure recognizing
employees’ social contribution.
Overall, the Group’s employee volunteering actions in 2025 contributed to creating a measurable social and
environmental footprint, strengthening the Group’s connection with local communities and supporting its
responsible and sustainable operations across all geographic areas of activity. [ESRS S3-4-31], [ESRS S3-4-32-(c), AR 37],
[ESRS S3-4-34-(a), AR 38 - AR 40, AR 42]
The Group develops and implements initiatives based on strategic planning, placing emphasis on maximizing
positive social outcomes. In addition, the Group responds to requests from affected communities following
evaluation and taking into account the needs of local affected communities, as well as the results of the DMA,
while simultaneously assessing actual or potential adverse impacts arising from its activities and implementing
targeted measures through prevention, mitigation or remediation actions. In cases where material adverse
impacts on local communities may arise, the Group designs and implements corresponding actions, as described
above. These actions are directly linked to the Group’s operational practices, including matters related to
operations, development, construction or the cessation of activities, and are integrated into the planning and
management of relevant projects. They are implemented in cooperation with competent public or local authorities
or through broader industry initiatives, where necessary for the effective management of potential impacts. For
further information on each action and its outcomes, please refer above.
For all implemented actions, the Group collects feedback on their effectiveness through communication channels,
targeted surveys and evaluations. Stakeholder feedback, combined with relevant monitoring indicators, is
integrated into evaluation processes and, where required, into the provision of remediation to communities that
may have been adversely affected by the Group’s activities. In addition, the Group sets clear and measurable
objectives for each initiative and uses key performance indicators to monitor progress, assess its social impact
and continuously improve its interventions. [ESRS S3-4-32-(a), AR 28 - AR 29, AR 36], [ESRS S3-4-32-(d), AR 31 - AR 33], [ESRS
S3-4-33-(a), AR 26], [ESRS S3-4-33-(b)], [ESRS S3-4-33-(c)]
In particular, the Group seeks to prevent any potential material adverse impacts on affected communities,
ensuring that its activities contribute positively to their well-being and to environmental protection. No serious
issues or incidents of human rights violations related to affected communities were reported during the reporting
period. It is noted that all Group facilities conduct environmental impact assessments through which potential
risks to local communities are identified and assessed. These potential risks are systematically monitored and
managed throughout the entire lifecycle of the facilities. Material potential impacts may arise at three key stages:
during the initiation of a new activity, during the operational phase and during the decommissioning process. The
Group has taken and continues to take specific measures to prevent, mitigate and, where necessary, remediate
these potential impacts through targeted actions, communication channels and feedback mechanisms. In

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addition, the Group responds to requests from affected communities following evaluation and taking into account
the needs of local affected communities. [ESRS S3-4-35], [ESRS S3-4-36]
In 2025, total investments in Corporate Responsibility actions in Greece and abroad amounted to €15.3 million,
benefiting approximately more than 2.95 million people. The actions are designed by thematic category and
implemented in Greece and abroad, highlighting the breadth of the Group’s commitment to society. [ESRS S3-4-38]
Metrics and Targets
S3-5 - Targets Related to Managing Material Negative Impacts, Advancing Positive
Impacts and Managing Material Risks and Opportunities
2025 Sustainability Targets:
At the end of 2025, the Group set an annual target to benefit more than 2 million people in Greece and abroad.
The year 2025 constitutes the baseline year for this target, with a baseline value of 2.95 million beneficiaries. In
2023, a previous target had been set to benefit more than 1.5 million people for the period 2024–2026, which was
successfully achieved. [ESRS S3-5-41]
This target, which relates to affected communities, was established through a structured process incorporating
the relevant impacts identified through the DMA. Through the actions implemented in 2025, the Group made a
substantial contribution to improving quality of life, upgrading education, strengthening infrastructure for
protection against extreme weather events and supporting various social groups — including vulnerable women.
It is worth mentioning that where feasible, the process also incorporates feedback from affected communities to
ensure that the targets respond to their actual needs.
Monitoring of the beneficiaries indicator for Corporate Responsibility actions takes into account data from
subsidiaries in Greece and abroad and is reported in accordance with the London Benchmarking Group (LBG)
methodology. In addition, the monitoring results are used for the continuous improvement and redesign of future
actions and initiatives. Finally, the BoD’s Sustainability Committee is responsible for overseeing the achievement
of ESG targets, informing the BoD accordingly and submitting proposals for corrective actions. [ESRS S3-5-42–(a), (b),
(c)]

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ESRS S4 - Consumers and End-Users
Strategy
ESRS 2 SBM 3 - Material IROs Related to Consumers and End-Users and their
Interaction with Strategy and Business Model
HELLENiQ ENERGY acknowledges that the impacts, risks, and opportunities associated with consumers and end
users constitute critical factors in shaping and continuously adapting its strategy and business model, as they
significantly influence the Group’s strategic development, adjustment, and improvement in addressing the needs
of its stakeholders.
The HELLENiQ ENERGY Group has a positive impact on sustainable mobility, improving people’s daily lives by
providing reliable energy solutions. Its extensive network of service stations, combined with the fuel storage and
distribution infrastructure of the HELLENiQ ENERGY Group and EKO, ensures stable and uninterrupted access to
high-quality fuels even in remote areas. All products, both conventional and alternative, fully comply with the
applicable national and European specifications. At the same time, the Group promotes cleaner mobility solutions
through the development of electric vehicle charging infrastructure and the provision of more sustainable fuels,
such as Sustainable Aviation Fuel (SAF). In this way, it enhances accessibility and convenience for e-mobility users,
while also supporting the transition to more environmentally friendly forms of energy. Overall, the Group’s
mobility activities combine reliability, coverage of diverse energy needs, and the promotion of sustainable options,
contributing positively to the well-being of local communities and to the creation of a healthier and more
sustainable environment.
Starting from the supply chain, the Group’s subsidiary EKO has developed one of the most extensive and
integrated fuel distribution networks in Greece. This network includes eight fuel storage and distribution facilities,
20 aircraft refueling stations at major airports, two LPG storage, distribution and bottling units, one additional LPG
storage and distribution facility, as well as a lubricants production and packaging plant. Although some of the
products distributed may have inherent impacts on human health, the Group implements strict health and safety
measures and ensures a high level of protection for all consumers and end users. By prioritizing the safe and
responsible management of its products, the Group adopts internationally recognized best practices and invests
in comprehensive environmental management systems. The Responsible Product Stewardship philosophy forms
a cornerstone of this approach and has been integrated into the Group’s Management Systems, aiming to reduce
risks to human health and the environment throughout the entire product life cycle, while at the same time
enhancing value creation. Within this context:
• Technical information is provided, and only products that fully comply with the required specifications are
placed on the market.
• Only responsible and correct use of the products is supported, in accordance with their comprehensive
Safety Data Sheets.
• Product handling instructions are considered and recommended to customers, with all products being
monitored for any issues reported by end-users, in order to identify potential needs for modifications..
• Reliable partners are selected who manage the Group’s products responsibly and ethically..
• The Group strictly adheres to the fundamental principles of the European REACH (Registration, Evaluation,
Authorization, and Restriction of Chemicals) and CLP (Classification, Labelling, and Packaging) regulations,
ensuring the protection of human health and the environment and effective management of chemicals.
Furthermore, in all its production, storage and handling facilities, HELLENiQ ENERGY implements certified
Quality, Occupational Health and Safety, Environmental and Energy Management Systems. These Management
Systems are evaluated annually to ensure a high level of performance for stakeholders.

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Within the context of risks and opportunities related to consumers and end users, the HELLENiQ ENERGY Group
recognizes that the increasing adoption of electric vehicles (EVs) may reduce demand for traditional fossil fuels,
creating financial risk due to its current reliance on fuel sales revenues. At the same time, growing access to and
availability of energy products and services offer significant opportunities for the Group: expanding market share,
diversifying its portfolio, and developing innovative, sustainable solutions that respond to evolving consumer
needs, while enhancing revenue growth and competitive advantage. As consumer preferences increasingly shift
toward sustainable energy options, demand for products such as biofuels and renewable-based solutions
highlights the important role of the HELLENiQ ENERGY Group in the transition to a lower-carbon economy. The
Group closely monitors technological and market trends and strengthens initiatives that support sustainable
mobility and the transformation of the transport energy mix. Investments in advanced biofuels and electric
vehicle charging infrastructure create new prospects for growth and diversification, leveraging market
opportunities while simultaneously managing risks.
It is worth noting that there are no consumers and/or end users of services whose rights—such as privacy,
personal data protection, freedom of expression, or equal treatment—are likely to be negatively affected. At the
same time, there are no vulnerable groups, such as children or economically disadvantaged individuals, who could
be impacted by health, privacy, or marketing and sales-related issues.
With the aim of responding promptly to changing user preferences, the HELLENiQ ENERGY Group adjusts its
strategy through targeted actions, outlined below, covering all existing and future EKO products. This adaptive
capability allows the Group to remain flexible and align with the ongoing market shift toward cleaner and more
responsible energy choices. At an operational level, EKO makes a significant contribution to reducing CO₂
emissions in road and air transport by offering sustainable fuels such as biodiesel, bioethanol, and Sustainable
Aviation Fuel (SAF) through commercial blends. These products support the dynamic transition toward more
environmentally responsible fuel solutions. The growth of e-mobility provides another important source of future
revenue, as the positive impact of promoting cleaner means of transportation is directly linked to consumer needs
and the rise of the electric vehicle market. Leveraging this trend enables the Group to strengthen its presence in a
rapidly growing sector and capitalize on new business opportunities. [ESRS S4-ESRS 2 SMB 3-9]
The Group’s customers and end users benefit from the positive impacts of its activities, improving their daily lives
and promoting sustainable mobility. The HELLENiQ ENERGY Group and its subsidiaries develop, commit to, and
continuously seek solutions for reliable energy access and cleaner mobility options, while simultaneously reducing
dependence on fossil fuels and supporting the transition to a low-carbon economy, as described below:
ElpeFuture
ElpeFuture, a subsidiary of the Group, provides electric vehicle (EV) charging services through EKO Charge&Go,
including the operation of fast chargers at EKO and bp stations along highways, as well as in shopping centers and
partner businesses. The renewable energy generated by solar panels installed at an increasing number of EKO and
bp stations (as part of the Zero Carbon Footprint Energy Network) powers the EV chargers, turning the charging
service into a low-carbon solution and contributing to the decarbonization of transport, while gradually reducing
the country’s dependence on fossil fuels.
ΟΚΤΑ
The advertising campaign by OKTA, titled “The Energy Around Us,” reflects the company’s enduring role as a
cornerstone of the national energy landscape. The campaign positions OKTA not only as the most reliable supplier
in the market but also as a company whose leadership presence is felt in every aspect of daily life—through the
security of uninterrupted supply, the consistent quality of its products, and the trust consumers place in its
expertise. The campaign emphasizes OKTA’s significant contribution to economic stability, community well-
being, and the broader transition toward cleaner and more responsible energy solutions.
In 2025, OKTA continues to demonstrate its unwavering commitment to the highest standards of operation and
quality across all markets in which it operates. This dedication is reflected in the ongoing implementation of the
Guarantee Program, which ensures consistent fuel quality for both domestic consumers and neighboring export
markets. The program’s campaign was communicated through a broad media mix, including radio, internet, digital
platforms, social media, print media, and out-of-home (OOH) advertising.

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EKO Bulgaria
In 2025, EKO Bulgaria maintained steady growth, reaching 101 service stations with the opening of two new fuel
stations and the renovation of 17 sites throughout the year, enhancing the customer experience. EKO expanded
its range of products and services by introducing new concepts, including two new supermarkets with a wider
variety of products, and inaugurating additional Care Wash facilities at fuel stations, including tunnel and jet wash
systems, bringing the total to 18 car wash facilities. Additionally, EKO Bulgaria implemented a program to install
26 photovoltaic units across its facilities.
The Smile loyalty program remained a priority for the company in 2025, with the introduction of new
functionalities and enhancements. Regular promotions and campaigns were conducted throughout the year,
offering added value to customers.
JUGOPETROL
Jugopetrol’s commitment to a sustainable future is clearly reflected in its initiatives aimed at supporting
environmental protection.
Eight electric vehicle (EV) charging stations (three of which are fast chargers) have been installed across
Montenegro, promoting the adoption of electric vehicles and providing accessible and reliable charging points.
This project directly contributes to reducing dependence on fossil fuels and advancing cleaner mobility solutions.
At the same time, the company completed or upgraded solar panel installations at 12 EKO service stations during
the year. These systems generate renewable energy to power the stations, significantly reducing greenhouse gas
emissions and improving energy efficiency. Such forward-looking initiatives highlight Jugopetrol’s dedication to
sustainability, delivering tangible benefits to the environment and the local communities it serves.
By integrating these comprehensive efforts into its campaign, Jugopetrol strengthens its leadership in
sustainability, customer engagement, and community collaboration, paving the way for a greener and more
connected future.
Enerwave
In the electricity and natural gas sector, Enerwave is a vertically integrated company with a significant contribution
to the operation of the country’s power system, enhancing supply security and providing reliable procurement and
energy efficiency services to all of its customers.
The company’s natural gas units play an important role in domestic energy production while also offering
flexibility services, contributing to system stability and enabling the further development and integration of
renewable energy sources (RES). At the same time, Enerwave manages a substantial natural gas portfolio,
strengthening the country’s supply security. Through cross-border electricity flows and natural gas exports, the
company further contributes to enhancing energy adequacy and supply security across the broader Southeastern
Europe region. [ESRS S4-ESRS 2 SMB 3-10-11]

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Impact, Risk and Opportunity Management
S4-1 - Policies Related to Consumers and End-Users
The Group focuses on strengthening consumer trust in every product and service it provides. This is ensured
through the implementation of strict operational standards across all its facilities and fuel stations. Product
quality is maintained through continuous and systematic inspections throughout the year, covering the entire
supply chain, from the refinery to the final sale to consumers.
For this reason, the HELLENiQ ENERGY Group has established a Quality Policy aimed at producing and delivering
high-specification products and services that fully meet the needs and expectations of end-users. In line with this
Policy, the Group monitors equipment reliability, the quality of raw materials, intermediate and final products, and
applies a certified quality management system. Within the framework of the Group’s Quality Policy,
comprehensive quality control systems are implemented at every stage of production and distribution, with the
objective of ensuring product safety, sustainability, and full customer satisfaction. These measures are designed
to manage both the physical risks and the opportunities associated with product quality, while also responding to
the continuously evolving needs of consumers and end-users.
The Quality Policy complies with applicable national and European legislation, while also monitoring international
regulatory developments and planning the necessary changes and investments accordingly. At the same time, it
aims at the continuous improvement of products and the provision of appropriate information to customers
regarding the quality of the products and services offered, ensuring their proper and rational use. The Policy
applies to all employees and is fully integrated into every business process, ensuring that quality standards
become part of daily operations. It is publicly accessible through the corporate website, providing transparency to
stakeholders. Its implementation also extends to consumers and end-users, reflecting the Group’s commitment
to meeting the needs of different market segments without restrictions.
The Group focuses on applying best practices and the most advanced techniques in its production and
distribution processes, aiming at continuous product improvement and full customer satisfaction. The monitoring
of the implementation of the Quality Policy is assigned to the competent Quality Divisions of the subsidiaries,
ensuring compliance with the ISO 9001:2015 Quality Management standard. [ESRS S4-1-15
At the same time, the HELLENiQ ENERGY Group supports international and national sustainability initiatives,
remaining an active member of the United Nations Global Compact since 2008, and complies with the Greek
Sustainability Code. Relevant data are publicly disclosed through the Communication on Progress and in
accordance with the criteria of the Greek Sustainability Code, demonstrating the Group’s commitment to
sustainable development and corporate responsibility. The Group does not have separate policy commitments
specifically dedicated to consumers and end-users that are fully aligned with internationally recognized standards
regarding consumer human rights, such as the UN Guiding Principles on Business and Human Rights. However,
through its Sustainability Policy, it is committed to promoting respect for human rights, enhancing diversity and
equality, and eliminating all forms of discrimination throughout its value chain, including consumers, end-users,
and business partners. In addition, it adopts sustainability best practices in procurement and marketing processes,
ensuring the provision of safe, sustainable, and accessible energy products. [ESRS S4-1-16-(a)]
The HELLENiQ ENERGY Group maintains open and accessible communication channels on its corporate website
for consumers and end users, enabling the submission of concerns, complaints, and feedback on any matter,
including issues related to human rights. The available mechanisms allow for the handling and investigation of
potential impacts, providing reporting and remediation procedures where required. [ESRS S4-1-16-(b)-(c)]
To date, no incidents of human rights violations have been identified in accordance with the UN Guiding Principles
on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD
Guidelines for Multinational Enterprises, concerning consumers and end-users in the Group’s operations or in the
downstream part of its value chain. Nevertheless, the HELLENiQ ENERGY Group continues to monitor its
operations and value chain, with the aim of continuously ensuring alignment with and compliance with the above-
mentioned international frameworks. [ESRS S4-17]

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S4-2 - Processes for Engaging with Consumers and End-Users about Impacts
HELLENiQ ENERGY Group engages with consumers and end-users and uses the information derived from this
communication to improve its decision-making processes and manage both actual and potential impacts. This
approach is reflected in a wide range of initiatives and strategic actions aimed at understanding and addressing
the evolving needs of stakeholders. The Group has made significant progress in strengthening RES and
developing sustainable mobility solutions, while placing emphasis on meaningful interaction with customers and
end-users in order to identify their needs and positively influence their overall experience. Engagement with
consumers and end-users is implemented across all stages of the Group’s operations, from product design to
service delivery and post-implementation experience evaluation. This is achieved through regular satisfaction
surveys, public consultations, interactive meetings, and digital communication platforms, ensuring that
consumers’ needs and expectations are consistently integrated into the Group’s processes.
The Group has developed a structured process that promotes collaboration with consumers and end-users,
ensuring a high level of service and the effective management of material impacts. Across the entire fuel retail
network, the call center operated by Teleperformance functions on a 24-hour basis, seven days a week.
Customers of EKO service stations may contact 18198 or 2107725555, while customers of bp service stations may
call 18199 or 2106887555. Calls are handled by trained Teleperformance personnel, who promptly forward
requests to the competent officers under the supervision of the Head of Customer Service of the Fuel Retail
Department of KALYPSO KEA S.A.. In addition, consumers of Enerwave may contact the support center by calling
18340 or 211 211 8340, while a dedicated line for professionals operates at 18341 and 211 211 8341. All incoming
calls are managed by trained personnel of cooperating companies, who handle the full range of requests.
This structure ensures continuous support and the prompt resolution of any issues, reinforcing the Group’s
commitment to consumer and end-user satisfaction. The effectiveness of communication with users is monitored
through the request resolution rate, and these data are utilized to enhance services and better address their
needs. Similar initiatives are also implemented at international level, ensuring a consistent service experience
across all markets, as described below per subsidiary. Further information regarding these processes is provided in
section General Disclosures – ESRS 2 "SBM-2 – Interests and views of stakeholders".
EKO Cyprus
As part of its strategy for continuous engagement with customers, an integrated Marketing, Public Relations, and
Corporate Responsibility program is implemented, combining “Above The Line” and “Below The Line” strategies
and leveraging all available marketing department tools. Press releases and public announcements are made
available to the public via the official website of EKO Cyprus, social media channels, and the press. For more direct
and targeted communication, the EKO Smile application is used, sending push notifications and providing a two-
way communication channel with customers, enabling them to submit inquiries and receive responses from an
EKO Cyprus representative. At the same time, customers can contact a customer service representative directly
by phone, available 24/7, ensuring the immediate resolution of any issues.
EKO Bulgaria
EKO Bulgaria is committed to implementing best-in-class industry practices, ensuring the highest quality and
consistency of services provided at every customer touchpoint. Delivering a positive customer experience and
building strong relationships are core elements of its commercial strategy. To facilitate direct communication with
customers and provide timely information, EKO Bulgaria has utilized call center services, while fuel quality
assurance continued for another year through the Guarantee Program, in collaboration with the certified
laboratory Bulgarkontrola.
JUGOPETROL
In Montenegro, Jugopetrol promotes the EKO brand through a combination of strategic communication channels,
aiming to strengthen message awareness, deepen customer engagement, and support its sustainability
initiatives. By combining marketing with meaningful Corporate Responsibility actions, the campaign reinforces
EKO’s position as an industry leader and fosters meaningful interaction with consumers. Jugopetrol’s
communication strategy places particular emphasis on public relations and Corporate Responsibility, highlighting
its sustainability achievements and strengthening stakeholder trust. Regular updates on environmental initiatives,

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such as electric vehicle charging stations, solar panel installations, and other sustainability projects, are
communicated through press releases, social media, and community engagement activities. Through this
transparent approach, Jugopetrol not only informs the public but also reinforces its commitment to a more
sustainable future.
Throughout the year, Jugopetrol enhances customer engagement not only through regular promotional activities
but also via seasonal campaigns, such as those for Easter, summer, and Christmas. These initiatives encourage
repeat visits, reward customer loyalty, and strengthen their connection to the EKO brand. By tailoring offers to
seasonal trends, Jugopetrol creates an attractive and dynamic customer experience.
At the same time, the visibility of the EKO brand is strengthened through a multi-channel advertising strategy.
Media such as television, radio, digital platforms, brochures, and outdoor media are used to ensure that
Jugopetrol’s messages reach a wide audience, while simultaneously reinforcing Jugopetrol’s commitment to
sustainability and innovation.
EKO Serbia
Similar to other Group subsidiaries, EKO Serbia strategically combines marketing, public relations, and targeted
Corporate Responsibility initiatives to strengthen its brand and emphasize its commitment to sustainability.
EKO Serbia’s strategy is based on integrated marketing and public relations campaigns that increase visibility and
enhance engagement with consumers. “Above the Line” activities include television and radio advertisements,
digital platforms, and outdoor media, while “Below the Line” activities cover loyalty programs and seasonal
promotions. Through this coordinated approach, EKO Serbia showcases its products and services while building
strong customer relationships, reinforcing trust and loyalty.
Additionally, EKO Serbia actively engages consumers and end-users at all stages of their experience, taking into
account feedback and preferences to improve its services. This interaction is facilitated through satisfaction
surveys, the EKO Smile loyalty program, and personalized communication via the loyalty app. The application
provides real-time updates and tailors offers to each customer’s needs, enhancing their overall experience. The
EKO Smile program has earned consumer trust, with over 700,000 members, and serves as a key tool in EKO
Serbia’s customer-centric strategy, offering promotions and rewards through a points-based system.
EKO Serbia’s communication strategy places particular emphasis on Corporate Responsibility initiatives,
highlighting its role as an active partner in the local community. Related activities are communicated through
events, press releases, interviews, social media, and local engagement programs, enhancing transparency and
trust. Corporate Responsibility efforts focus on improving social welfare, with special attention to road safety
programs and support for socially vulnerable groups.
Enerwave
As a supplier of electricity and natural gas, Enerwave focuses on the reliability and transparency of its services,
implementing processes that strengthen trust-based relationships with its customers through timely information,
fair and transparent billing practices, and the continuous improvement of the service experience. In addition,
Enerwave offers energy efficiency services to both small and larger customers, leveraging technical solutions that
help reduce consumption and improve overall energy performance.
In line with enhancing transparency and high-quality service, Enerwave implements targeted actions to improve
customer information, support, and overall experience. These actions include organized awareness campaigns for
new customers, proactive communication campaigns in cases of billing delays, as well as onboarding promotions
to facilitate the initial use of services. Furthermore, measures are taken to promptly address issues that may
affect the customer experience, aiming to reduce complaints and strengthen ongoing collaboration. In this way,
Enerwave consistently ensures high service standards, reinforcing trust with its customer base. [ESRS S4-2-20-(a), (b)]
The operational responsibility for ensuring effective collaboration with consumers and end-users lies with the
Retail Marketing Division and the responsible Sales Division. The outcomes of this engagement with consumers
and end-users are analyzed and taken into account in the Group’s strategic decisions and policy development,
ensuring the continuous improvement of products, services, and processes. [ESRS S4-2-20-(c)]

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Indicative results of surveys measuring customer satisfaction
The analysis of results from customer satisfaction surveys provides valuable insights into how effectively a
product or service meets customer expectations. For this reason, the HELLENiQ ENERGY Group places particular
emphasis on these surveys, as they serve as a key tool for measuring customer satisfaction, understanding their
needs, and continuously improving the overall experience it offers.
Domestic marketing
In 2025, to enhance customer satisfaction and gain a better understanding of their needs, a total of 17 qualitative
and quantitative market surveys were conducted: 5 focused on the significance of the EKO and bp brands, and 12
evaluated staff performance at fuel service stations. In addition, through the loyalty platform, EKO and bp are able
to communicate with customers on a personalized basis, further strengthening the understanding of their
preferences and needs.
EKO Cyprus
In 2025, EKO Cyprus continued to achieve high levels of customer satisfaction and positive consumer experiences.
Within the framework of the Mystery Shopper program—which covers the entire EKO Cyprus network and 30% of
competitor stations, with a frequency of 12 evaluations per year—the company recorded a performance score of
66% in December of the reporting year, significantly exceeding the market average of 54% in indicators such as
courtesy, service, and appearance.
Key findings from the Brand Vitality Tracking survey, an annual assessment that included 802 interviews with
quotas for age, gender, and geographic region representing the driving population in Cyprus, focused on
consumer perceptions, use of information, purchase criteria, brand preference, and car-related and fuel
purchasing habits. The results of the annual survey highlighted the consistent consumer preference for EKO,
reinforcing its position as a market leader in Cyprus and maintaining strong performance in both primary and
secondary brand choices compared to the previous year. In 2025, EKO Cyprus achieved a primary brand choice
rate of 40%, up from 36% in 2024, while its secondary brand choice rate stood at 27%.
At the same time, Top-of-Mind awareness increased significantly, reaching 50% in 2025 compared to 45% the
previous year. Despite a decrease in refueling frequency in Cyprus, the company attracted new consumers for
whom EKO has now become their station of choice. This is also reflected in the increase of the Loyalty Index,
which rose to 24% in 2025 from 22% in 2024.
The company’s overall market dominance is further reflected in the Brand Equity Index (BEI), where EKO records a
score of 4.1, maintaining a leading position in the market, while competitors follow with scores of 2.6.
EKO Bulgaria
EKO is recognized as one of the most reputable fuel station chains in the market, with overall brand awareness of
89% and serving as the primary choice for 12% of consumers. According to the Nielsen IQ BVT 2024 survey, it
also has a strong loyalty index of 67%.
OKTA
According to the findings of the Mystery Motorist survey, in 2025 OKTA’s overall performance reached 80%,
slightly surpassing the competitor average of 79%. At the same time, OKTA achieved a significantly higher score
in the customer experience category, with a rating of 81% compared to competitors’ 76%, confirming its superior
service quality and the priority placed on ensuring a positive customer experience.
In addition, in 2025 OKTA’s market performance remained stable, achieving:
• 88% overall brand awareness, compared to 93% in 2024
• 83% spontaneous brand recognition, unchanged from 2024
• 12% Top-of-Mind awareness, unchanged from 2024

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• 15% primary brand choice, up from 14% in 2024
• 23% secondary brand choice, up from 22% in 2024
EKO Serbia
During 2025, EKO Serbia implemented a series of initiatives aimed at enhancing the customer experience,
strengthening brand presence, and supporting the growth of its loyalty program.
Results from the Mystery Shopper program for Q2–Q4 2025, based on the new evaluation platform, recorded an
overall performance of 63%, significantly higher than the competitor average of 54%. Regarding customer
experience, EKO achieved a score of 51% compared to 49% for competitors. Similarly, in terms of service station
appearance, EKO recorded a performance of 90% versus 85% for competitors.
Findings from the BVT market survey showed overall brand awareness of “EKO” at 87%, Top-of-Mind awareness
at 2%, and Main Choice at 8% for 2025. The EKO Smile loyalty program also continued its upward trend, with
recognition increasing to 65% (+3 percentage points compared to 2024). [ESRS S4-2-20-(d)]
HELLENiQ ENERGY Group ensures that the views of all consumer groups are equally considered, including
vulnerable or marginalized groups such as people with disabilities or children, as no discrimination exists between
these groups. To this end, the Group implements dedicated feedback collection processes, such as personalized
surveys and accessible digital communication platforms, ensuring that the needs and opinions of all consumers
are integrated into its strategies and decision-making. [ESRS S4-2-21]
S4-3 - Processes to Remediate Negative Impacts and Channels for Consumers and
End-Users to Raise Concerns
HELLENiQ ENERGY Group provides complaint submission mechanisms for any stakeholder, including customers,
to address potential negative impacts from its activities. Additionally, it encourages its partners to maintain
similar communication channels, ensuring that the views and concerns of consumers and end-users can also be
conveyed through these partners.
EKO has established and implements documented procedures for managing customer complaints, ensuring that
each complaint is recorded and forwarded to the relevant technical experts, assessed for severity, safety,
complexity, impact, and the need for immediate corrective action, and investigated in depth to identify root
causes. Resolution is then carried out to provide the best possible response to the customer request,
accompanied by information on how the issue was addressed. All actions are documented in the relevant records
and systematically analyzed to derive useful insights that lead to appropriate preventive and corrective measures.
Currently, there is no specific approach to ensure the effectiveness of these channels, nor a defined method to
assess whether consumers and/or end-users are aware of and trust these structures or processes as a way to
express and address their concerns or needs. HELLENiQ ENERGY Group plans to adopt methods for monitoring
the effectiveness of these mechanisms, including collecting feedback from consumers and end-users regarding
their awareness, trust, and satisfaction with the complaint submission process. [ESRS S4-3-25-(b), (c), (d)]
Nevertheless, measures for protecting individuals who report or disclose information about illegal activities
(whistleblowing) are being strengthened, and communication channels for reporting violations are being
expanded. In accordance with Law 4990/2022 on the protection of persons reporting breaches of European
Union law, the Whistleblowing Policy is applied. For more information on the Whistleblowing Policy, refer to
section ESRS G1. [ESRS S4-3 26]
S4-4 - Taking Action on Material Impacts on Consumers and End-Users and
Approaches to Managing Material Risks and Pursuing Material Opportunities Related
to Consumers and End-Users and Effectiveness of those Actions
With a particular focus on delivering a positive customer experience at fuel service stations, the HELLENiQ
ENERGY Group, through its subsidiary EKO S.A., has implemented a series of programs and initiatives aimed at
better serving its customers and responding to their needs. Specifically, the following actions are already in place:

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Covert Inspector Program
The program is designed to accurately assess the services provided, the quality of service at fuel stations, and
compliance with operational standards under real conditions. Covert inspectors evaluate 65 criteria across nine
areas of the station, including the service area and equipment, service quality, safety measures, store conditions,
staff uniforms, hygiene facilities, and promotional activities.
In 2025, 3,502 inspections were conducted at EKO and bp fuel stations, and 306 inspections at competitor
stations across Greece. Each station is evaluated by a covert inspector between four and twelve times per year.
Findings from these inspections are published monthly on an electronic platform accessible to all sales directors
and station managers. This platform enables the tracking of performance progress over time, as well as
monitoring various other key indicators critical for enhancing and developing network services. The ultimate goal
is to upgrade customer service standards and more effectively meet customer expectations.
Digital Transformation
Digital Transformation is a cornerstone of the Group’s sustainable development strategy, aiming to implement
over 180 related initiatives in the medium term (2027–2030). These initiatives include the fuel stations of the
future, enhancing operational efficiency with positive impacts for consumers and society. The adoption of new
digital tools and methodologies boosts productivity, flexibility, and process quality, enabling faster, personalized
service and transparency for consumers. At the same time, the digital retail program expands the reach of the
loyalty program across Southeastern Europe, strengthening interaction with retail consumers while maintaining
consistent collaboration with corporate clients and partners, creating added commercial value for both parties.
Ensuring product quality remains a central priority. The Group conducts continuous quality checks across the
entire supply chain — from the refinery to the points of sale — and maintains full compliance documentation for
all products. Products are made available to customers only after confirmation of compliance at every stage,
through rigorous inspections. The quality control programs implemented in each country are described below:
Greece – "Mobile Laboratory Units" (EKO S.A.): EKO operates a comprehensive quality control program using
Mobile Laboratory Units that perform on-site and surprise inspections at EKO and bp stations, ensuring
systematic and reliable qualitative and quantitative fuel testing.
The Republic of North Macedonia – “OKTA GUARANTEE”: In 2025, under the OKTA GUARANTEE program —
implemented by a specially trained team in collaboration with the Faculty of Mechanical Engineering of the
Republic of North Macedonia — OKTA conducted 55 station visits, with 162 samples collected for laboratory
analysis at the ISO 17025-accredited OKTA laboratory. For quantitative tests, measurements were taken at 688
pump nozzles, achieving 100% compliance with legislative requirements.
Bulgaria – “EKO Guarantee”: EKO Guarantee, the first program of its kind in the country for additional fuel quality
verification at EKO Bulgaria stations, celebrated its eleventh year in 2025, remaining one of the leading control
systems in Europe. The program exceeds national regulatory requirements and is executed by an independent
specialized partner, Bulgarkontrola S.A..
In addition to the above programs, Domestic Trade strictly adheres to quality and safety standards for LPG,
aviation fuels, and lubricants. Specifically:
• E-Gas and E-Gas Easy cylinders comply with strict safety standards, ensuring the highest level of safety
provided by EKO’s expertise. EKO’s LPG storage, handling, and bottling facilities operate under a certified
Quality Management System in accordance with ISO 9001:2015. The scope includes receipt, storage,
bottling, and distribution of LPG.
• Aviation fuels: EKO supplies JET aviation fuels (JET A-1 and JP-8) to 20 airports across Greece. The primary
product supplied is JET A-1, which complies with the latest Aviation Fuel Quality Requirements for Jointly
Operated Systems (AFQRJOS) of the Joint Inspection Group (JIG), incorporating strict standards such as
Defense Standard 91/91 and ASTM D-1655. All EKO Aircraft Refueling Stations are certified under ISO
9001:2015 Quality Management standards.

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• Lubricants: EKO lubricants are produced using high-quality raw materials, covering a wide range of
applications from basic to complex lubrication needs. Compliance with design specifications is ensured
through continuous quality checks at all critical production stages. EKO’s Lubricants Production Unit
operates under a certified ISO 9001:2015 Quality Management System, ensuring reliable, high-quality
products. At the Skaramangas facilities, EKO’s Chemical Laboratory is equipped with state-of-the-art
instrumentation and is recognized for high performance in international laboratory assessments. The
laboratory conducts quality checks for both aviation fuels and lubricants, ensuring product reliability and
quality. [ESRS S4-4-33-(b)] [ESRS S4-4-33-(a)]
Loyalty Programs
The EKO Smile and BPme loyalty programs continued their successful trajectory in 2025, providing instant
rewards to customers during their everyday transactions and ensuring high-quality, fast, and personalized service
at EKO and bp stations, respectively.
Both programs operate through their respective mobile applications (EKO Smile app and BPme app), enabling
contactless payments via receipt scanning, automatic points collection, online product purchases with free
delivery, points transfer, redemption through digital vouchers, access to transaction history, and participation in
exclusive experiences through the companies’ sponsorships. Additionally, the loyalty platforms provide EKO and
bp with valuable insights into consumer preferences, enhancing personalized communication and targeted
campaigns.
In 2025, EKO Smile was further strengthened through major promotional campaigns and new partnerships,
including with the Attica Group, offering members discounts on ferry tickets. Moreover, through the EKO
Exclusive VIP Club, it provided special benefits to luxury car owners. These initiatives contributed to increased new
registrations, station visits, and fuel sales for EKO.
BPme, with a network of over 700 bp stations, also advanced dynamically during the year, executing significant
campaigns such as the Tottenham Hotspur contest, the Instant & Win Easter draw, the heating oil competition,
and the Panathinaikos Unique Experience. These actions boosted new registrations, repeat visits, and digital
engagement with the app.
Overall, both programs contributed significantly to higher station traffic, strengthened customer loyalty, and
improved sales, highlighting the strategic role of digital rewards in the modern fuel retail experience.
Additional initiatives
EKO S.A. implements ongoing initiatives to raise consumer awareness about energy saving during the use of
transport fuels, such as providing eco-driving tips and promoting the rational use of heating oil through social
media posts.
These actions focus on driving behavior (e.g., avoiding sudden acceleration, removing unnecessary vehicle weight,
etc.) and the proper use of heating oil (e.g., setting thermostats to 19°C, regular boiler maintenance, etc.) to
achieve the same outcomes with lower fuel consumption. The quantitative implementation and performance of
these initiatives are monitored and reported through the framework of Energy Efficiency Obligation Schemes.
[ESRS S4-4-30]
HELLENiQ ENERGY Group also leverages communication channels with consumers and other stakeholders, such
as customer suggestions and complaints, as a key preventive mechanism to identify potential adverse impacts. To
date, no actual impacts requiring remedial actions have been recorded. In cases where product quality issues are
confirmed by consumers, the Group provides compensation, while for Health & Safety matters, compensation is
granted only when there is a legal ruling. All other matters concerning consumers and end-users are managed by
the Marketing Division. [ESRS S4-4-31- (c)]
HELLENiQ ENERGY Group monitors and records issues that arise and are addressed through a feedback system,
including regular surveys, and evaluates the effectiveness of its actions and initiatives based on the satisfaction
and experience of end-users. In 2025, the customer service center handled 46,272 calls. The Group assesses the

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effectiveness of its channels by collecting information from stakeholders, who are the intended users of these
channels. [ESRS S4-4-31-(d)]
The staff at fuel stations receives comprehensive training on various topics, including customer service and sales
promotion, to prevent causing or contributing to significant impacts on consumers and/or end-users. In 2025,
training programs were conducted across the two partner networks — KALYPSO KEA S.A. and EKO S.A. —
targeting fuel station managers, owners, and staff. Training was delivered either in-person or through an
electronic Learning Management System, which allows participants to follow specially designed courses organized
into dedicated thematic modules.The training modules included programs such as EKO-Castrol Lubricants,
Customer Service and Sales Promotion, and Heating Oil Distribution. In 2025, a total of 7,535 individuals received
both theoretical and practical training, equivalent to 14,360 training hours in Greece. The total cost of
implementing these training programs for 2025 amounted to approximately €39,000.
No serious human rights issues or incidents related to consumers and/or end-users of the Group were reported
during 2025. [ESRS S4-4-34-35-37]
Metrics and Targets
S4-5 - Targets Related to Managing Material Negative Impacts, Advancing Positive
Impacts and Managing Material Risks and Opportunities
Time-bound and Outcome-Oriented Targets
To ensure that its efforts to enhance positive contributions are measurable and effective, the HELLENiQ ENERGY
Group has defined specific indicators to monitor the achievement of its targets, guiding actions and supporting its
initiatives.
One such indicator is the number of product analyses conducted annually. In Greece, in 2025, EKO carried out
105,028 quality analyses on 8,577 fuel samples from fuel stations. In addition, 8,401 analyses were performed on
aviation fuels and 30,250 analyses on lubricants at the EKO's Chemical Laboratory.
The time-bound and outcome-oriented targets related to promoting positive impacts and managing significant
opportunities are as follows:
• ~5,600 electric vehicle charging points at EKO/bp stations and publicly accessible locations by 2030. By the
end of 2025, the EV charging points was 965, whereas the base year of this target is 2023, when the EV
charging points was 162.
• 140 kta sustainable fuel production (biodiesel production unit from used cooking oil (UCO) at the
Thessaloniki refinery and development of a new standalone SAF production unit at the Aspropyrgos
refinery) by 2030. As this project is not completed yet, there is no production (0 kta) to be reported for 2025.
HELLENiQ ENERGY Group has set these consumer and end-user related targets through a structured process
that incorporates relevant IROs identified through the DMA. The Sustainable Development Committee monitors
progress toward these targets and provides recommendations for strategy adjustment, while the BoD oversees
the establishment of targets. In particular, the selection of topics for target setting considers key stakeholders,
including consumers and end-users, to ensure alignment with their expectations.
Aiming to provide sustainable mobility solutions and facilitate access to energy for consumers and end-users, the
Group has developed a wide network of charging points, including remote and rural communities, through
ElpeFuture and the responsible Sales Division. At the same time, feedback from the Group’s various consumer
communication channels is taken into account to guide improvements. [ESRS S4-5-41-(a), (b), (c)]