Non-Financial Data Disclosures

The data and information presented in our Sustainability Reports have been collected using the procedures and scientific capture methods applied by each Group subsidiary, and have also been obtained from the databases kept in the respective corporate systems. The data capture and the calculation of the indicators referring to the performance of MYTILINEOS Group are checked and verified using the corporate SAP system, official documents (e.g. financial statements), in-house calculation systems available in the respective departments of each individual Group company (e.g. custom Excel worksheets created and regularly updated for this specific task), and internationally accepted calculation methods, such as those provided under the OHSAS 18001 – ELOT 1801 Occupational Health & Safety Management Systems, the ISO 14001 Environmental Management Standard and the ISO 14064 Standard on Greenhouse Gas Emissions Quantification and Reporting Management Systems. With regard to social data, these cover the initiatives taken by each subsidiary individually as well as the actions carried out by MYTILINEOS HOLDINGS S.A., which represents the entire Group. The present Report contains data obtained from direct measurements, while –to help comparisons– the corresponding data series for last three years are also given, where available.

In what in particular regards the calculation of green house gas emissions and of Occupational Health & Safety indicators, the relevant calculations are as follows:

Calculation of Greenhouse Gas emissions

Metallurgy & Mining Sector:

1. CO2 emissions: Direct CO₂ emissions are calculated in accordance with the emissions monitoring plan submitted by ALUMINIUM OF GREECE and approved by the Ministry of Environment, Energy and Climate Change, in compliance with the requirements of Commission Regulation (EU) 601/2012.For calculating indirect carbon dioxide emissions, a conversion factor of 0.85 was used (i.e.: electricity consumption in kWh*0.85). More specifically, the factor used for 2011 was 0.85 tCO₂/MHz. This factor is weighted for the contribution from each type of energy source.

2. Dust emissions: Dust concentration in the plant’s point emission sources is measured in accordance with Environmental Terms Approval Decision (AEPO) 160170/2008 as follows:(a) By isokinetic sampling, with a frequency of four samplings per year at the plant’s Α070, FLN, H15, H1, H28 chimneys; (b) using continuous measurement analysers at the anodes kiln, revolving and static components and lime kiln furnaces; and (c) by isokinetic sampling, with monthly samplings at the no. 1-2 and no. 3-4 Gas Treatment Centres for the electrolysis gases.For calculating the quantities of annual emissions in tons, the following were used:(a) For point sources where isokinetic sampling is used, the average of the four concentration values (in mg/Nm3) and of the flow rate (in Nm3/s); and (b) for point sources where continuous measurement is used, the average of the daily concentration values (in mg/Nm3) and of the flow rate (in Nm3/s) from the isokinetic samplings of all years for which these are available.

3. ΝΟx emissions: Annual emissions of nitrogen oxides refer to the consumption of fuels (natural gas, diesel oil & fuel oil) and were calculated stoichiometrically, using the following emission factors: 5.363 g/kg for fuel oil, 2.102 g/kg for natural gas and 2.384 g/kg for diesel oil (Guide to Energy Investments, Ministry of Development, 2005).It is pointed out that NOx emissions from processes are not measured or calculated (no official method is available yet).

4. SO2 emissions: Annual sulphur dioxide emissions refer to the consumption of fuels (fuel oil & diesel oil) and are calculated based the sulphur content of fuel oil as shown on the chemical analysis sheets and, for diesel oil, using an emission factor of 0.7 gr/kg.Sulphur dioxide emissions from the anodes baking process are not calculated (no verifiable method is available).

Energy Sector:

1. CO2 emissions: Direct CO2 emissions are calculated in accordance with the emissions monitoring plans submitted by the subsidiaries of PROTERGIA S.A. and approved by the Ministry of Environment, Energy and Climate Change, in full compliance with the provisions of article 12 and Annex I of Commission Regulation (EU) 601/2012.The methodology for the calculation of carbon dioxide emissions is based on calculations in accordance with the provisions of Annex IV of Directive 2003/87/EC and the provisions of Decision 2007/589/EC. Emissions from source flows are determined based on activity data obtained with the help of measurement systems and on additional parameters resulting from laboratory analyses or standard emission factors.

2. SO2 and particle (dust) emissions: In the case of the thermal power plants of PROTERGIA S.A., because of the quality of the consumed fuel (natural gas), no emission limit values apply for SO₂ and particle emissions, as pointed out in the Environmental Terms Approval Decisions in force for these plants and under the applicable Community and Greek law on air emissions from combustion plants. Consequently, no obligation arises for measuring SO2 and particle emissions in the company’s thermal plants.

3. NOx emissions: In accordance with the Environmental Terms Approval Decisions (AEPO) in force for the thermal power plants, emission limit values apply for NOx (in this particular case, NO2) with the following acceptance limits:

• 50 mg/Nm3 (on a dry basis with 15% Ο₂), for operation with a load above 70%;

• 75 mg/Nm3 (on a dry basis with 15% Ο₂), for operation with a load above 70% and an annual total electrical efficiency above 55%.

NOx levels are measured continuously by the plants’ Continuous Emission Monitoring Systems (CEMS) that measure the concentration of NOx (in the form of NO2) in the power plant’s exhaust gases and the values logged are expressed in mg/Nm3.

Construction and EPC Projects Sector:

The methodology for the calculation of carbon dioxide emissions is based on calculations in accordance with the provisions of ISO 14064 International Standard. ISO 14064 provides guidance for recording the Greenhouse Gas (GHG) emissions from an organisation’s activities and quantifying them in terms of carbon dioxide equivalent emissions (CO₂e).This is achieved by using a selected methodology that minimises any potential for uncertainty in the calculations.The quantification formula is the following:GHG Emissions (CO₂e) = GHG activity data x GHG emissions factor (in CO2e).The emission factors are selected following after evaluating their suitability and proper correspondence to the activity data and are derived based on the guidelines of internationally recognised Bodies such as IPCC and Defra, on Commission Regulation (EU) 601/2012 and on the National GHG Inventories.

Calculation of Occupational Health & Safety Indicators

MYTILINEOS Group:

Injury Rate (IR) = Total number of injuries x 200,000 / Total hours worked.

Occupational Disease Rate (ODR) = Total number of occupational disease cases x 200,000 / Total hours worked.

Lost Days Rate (LDR) = Total number of days lost x 200,000 / Total hours worked.

Absenteeism Rate (AR) = Total days of absence in the period reported x 200,000 / Total days worked by the workforce during in same period.

Note: The factor of 200,000 results from 50 working weeks of 40 working hours per 100 employees. The rate obtained using this indicator is related to the number of employees and not to the number of hours.

Metallurgy & Mining Sector:

Injury Rate (IR) = Total number of injuries x 1,000,000 / Total hours worked.