Sustainable Development Report 2019

Key Challenges / Impacts [GRI 103-1a] [GRI 102-15] The key challenge for the Company is to maintain its strong focus on the protection of Human Rights and especially of labor rights, as this helps to further strengthen a working environment that promotes the improvement of employees on a personal and pro- fessional level, and also ensures that the Company is not involved in circumstances of violation of these rights, which may be caused by another company or by State bodies, natural persons or other groups with which the Company cooperates within the scope of its activity. Major risks [GRI 102-15] • As there is no formal due diligence procedure for safeguarding the protection of Human Rights, MYTILINEOS recognizes risks related to human rights, both within its working environment and in the business environment of its main suppliers and part- ners. These risks (such as activities that may affect or involve children, culture of corruption, inequalities in the workplace, limitation of human rights at the level of local communities etc.) .are emerged mainly from the Company's official materiality process which addresses industry-specific human rights issues, and may affect the Company's financial, human and social cap- ital, through their likely impact on its reputation and its “social license to operate”, also may lead to legal sanctions as well as to emergency measures beyond those imposed by normal business conditions. • Moreover, through the EPC & Infrastructure Projects sector, the Company owns work sites in countries abroad and cooper- ates with suppliers of developing countries in the Middle East and Africa, where there is a risk of occurrence of incidents of Human Rights restriction or violation, which may even cause the suspension of works for some time, at a direct financial cost to the Company. Human Rights Materiality assessment process results. Scale: [0—4] where 0 “Not significant” and 4 “Very significant” Impact on Sustainable Development 4,00 Significance for Stakeholders 3,42 Management Approach [GRI 102-11] [GRI 103-2c] The purpose of this disclosure is to provide information and data to MYTILINEOS' Social Partner groups, so that they can understand how the Company is managing its Human Capital in the framework of its new operational structure. [GRI 103-2b] MYTILINEOS ensures labor relations that foster mutual trust, constructive collaboration and two-way communication and recognition, while at the same time promoting the fundamental principles of the International Labor Organization (ILO) Declaration of Fundamental Principles and Rights at Work, including: (a) respect for the freedom of association and the effective recognition of the right to collective bargaining, (b) elimination of all forms of forced or compulsory labor; (c) effective abolition of child labor, and (d) the elimination of all discrimination in respect of employment and occupation. Risk Management / Control Practices [GRI 103-2a] • MYTILINEOS is committed to the first six Principles of the UN Global Compact, which are based on, among others, the inter- nationally recognized principles on the protection of Human Rights, as these are defined in the Universal Declaration on Human Rights. The Company's commitment to monitoring and publishing the impacts of its activity in this area, together with the Code of Business Conduct, which is addressed to all levels in the Company's hierarchy, promote the protection of and respect for Human Rights, mitigating the likelihood of such incidents occurring in the Company's working environment. • MYTILINEOS monitors the relevant labor legislation (national, European, ILO), including reports on child labor, respect for human rights and work conditions, and is fully aligned with the collective bargaining agreements and the relevant interna- tional conventions. The Company's employees may without any restriction whatsoever participate in trade unions and professional associations. • Labor rights are an issue of major significance for all employ- ees. The Company's direct employees are covered by business collective agreements, where applicable, and participate through their representatives in health and safety committees, presenting to the Management their proposals regarding continuous improvement. Also, Employees Unions are in place in the Metallurgy Sector and the EPC & Infrastructure Projects Sector. In the latter, a first-degree trade union body is estab- lished and functions at business-unit level (Volos plant), whose members are elected by the general assembly of the plant's employees, with representatives also elected to the second-de- gree trade union organization (Volos Labor Centre) and to the Panhellenic Metal Workers' Federation (POEM). • The Company, through the basic grievance mechanism pro- vided in its Code of Business Conduct for reporting violations of the Code (anonymous or named reports by phone, fax, post, as well as by e-mail to the Regulatory Compliance Division), turns its commitment to action, by enabling its employees to raise any concerns, as well as to report incidents of Human Rights violations. Moreover, the Company warrants that no action shall be taken against any employee who reports in good faith any actual or alleged inappropriate conduct. • As regards its activity in developing countries, MYTILINEOS takes all requisite measures to comply with the applicable laws. Safe work management is governed by a series of actions that must be followed, to ensure that the Health & Safety system for employees is property implemented and the appropriate measures are taken. At the same time, the contracts signed with contractors and suppliers include an explicit provision about the Company's Code of Business Conduct, to safeguard the respect for Human Rights and to prevent conditions of corruption and bribery • Finally, the Company is also committed to conduct risk assessments in its production plants and offices of its Business Sectors to identify potential effects on key Human Rights protection areas , in accordance with the methodology proposed by the Global Compact (Global Compact Self-Assessment Tool – Human Rights section) and to publish the relevant findings. This process is supported by both daily communication and employee management pro- cedures and systems implemented by the Human Resources General Division. Boundaries of the Material Issue [GRI 102-46] [GRI 103-1b] Issue of increased significance to: Where the impacts occur: In all work areas of the Business Activity Sectors and subsidiaries of the Company and of its contractors and suppliers. The management of the topic by MYTILINEOS contributes to the Sustainable Development: • Employees • Suppliers • Shareholders / Investors • NGOs • Academic community • Regulatory bodies • Media representatives in the context of their cooperation with MYTILINEOS. • Protection of labor rights. • Strengthening social and economic integration for all, irrespective of age, gender, disability, race, nationality, origin, religion, economic situation or other characteristic. • Strengthening employment in the industrial sector. By whomare the impacts caused: The Business Activity Sectors of MYTILINEOS and its subsidiaries are directly involved in these impacts, together with its contractors/suppliers located in developing countries. 113 112

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