Sustainable Development Report 2019

Supply chainmanagement Geared towards strengthening its competitive position, MYTILINEOS seeks to optimize its suppliers by establishing and maintaining value-added relationships, focusing on reducing the total cost of products or services, on transparency in cooperation and on the promotion of a responsible supply chain. MYTILINEOS develops long-term partnerships with a number of suppliers, while it manages others on a short-term horizon, based on the competition in the market. The object and the type of the required supply will determine the priority to be placed on local suppliers, based on their economic, qualitative and time-related solvency, the cost of their products or services and their ability to ensure the required quality to cover the procurement needs, in line with predetermined specifications, set by the Company's Business Activity Sectors. The “Suppliers & Business Partners Code of Conduct” of MYTILINEOS sets out the Company's minimum requirements/ expectations from its supply chain actors regarding issues related to Responsible Entrepreneurship, as a key precondi- tion for entering into any commercial association with them. Supply Chain Data 2018 2019 Total number of suppliers 7,283 9,639 Geographical distribution Greece: 82% Abroad: 18% Greece: 82.6% Abroad: 17.4% Total expenditure €1,206,607,399 €1,954,923,114 Geographical distribution [GRI 204-1] Greece: 69.9% Abroad: 30.1% Greece: 34% Abroad: 66% Basic Description of MYTILINEOS' Supply Chain [GRI 102-9] Basic business activities requiring services or products from the supply chain • Production & Maintenance of alumina chemical industry and of primary aluminium metallurgy. • Plant production for the purchase of raw or other materials. • Construction for the purchase of equipment for EPC projects implementation • Logistics regarding the methods and time of products' delivery to different countries. • Operation and Maintenance of Energy Centers (thermal power stations) • Development, construction and maintenance of Renewable Energy Sources projects (wind farms, solar parks, hydroelectric projects) • Retail activity • Studies – Investments. • Administrative, Financial, Legal and other services Basic categories of suppliers • Raw material producers • Energy and Natural Gas suppliers • Subcontractors • Manufacturers • Distributors / Forwarders • Suppliers of spare parts/materials • Wholesalers • Suppliers of consultancy services & studies The main objective of the Company, by 2025, is to include requirements related to sustainable development in the selection process of key suppliers and to commit existing ones to good and responsible practices, with a view to developing partnerships to better understand the impacts and to mutually harmonize objec- tives and expectations. Protection of customers' personal data The protection of natural persons against the processing of per- sonal data is a recognized national and European objective in the context of building efficient, reliable and transparent institutions and is of the utmost importance for MYTILINEOS. The compli- ance with the legislation, which the Company applies across all its Business Activity Sectors, contributes to avoiding direct financial consequences but also to its customers’ loyalty and satisfaction. The collection and processing of personal data by MYTILINEOS is carried out only in accordance with the General Data Protection Regulation (GDPR) of the European Parliament and of the Council and with the generally applicable legislation, and only in cases where this is required in connection with the functioning of industrial relations and with the Company's business activity. The Company allows access to those data by authorized persons only and takes increased security measures to protect this data from loss, erroneous handling, unauthorized access, modifica- tion or disclosure. In 2019, MYTILINEOS notified the Hellenic Data Protection Authority of an isolated phishing incident in a metallurgical worker's email account, concerning unauthorized access to the employee's email addresses and further sending of phishing emails to them. As a remedy, additional emails were sent from the employee's email account to all contacts, advising them of the incident and providing them with instructions on how to deal with it. [GRI 418-1] The sections of this Code address issues such as the Protection of the Environment, the Safeguarding of Health & Safety, Work Conditions, Ethics & Integrity. This initiative aims at committing suppliers to good sustainable development practices which will in turn bring two-way benefits. At the end of 2019, the number of MYTILINEOS' active suppliers and business partners in Greece and abroad stood at over 9,600. Compared to 2018, the main change recorded in the basic struc- ture of the Company's supply chain was the integration of the suppliers of the subsidiaries METKA EGN and EPALME. In addi- tion, increased expenditures were recorded in suppliers abroad (design services, construction and maintenance of RES projects, etc.), due to the activity of the new Business Activity Sector of International Development of Renewable Sources and Energy Storage of MYTILINEOS [GRI 102-10] . In 2019 MYTILINEOS' total outlays to its suppliers for the produc- tion of its products, the supply of services and the development of its projects amounted to more than €1.95 billion while the amount allocated to domestic suppliers reached €777.5m. fur- ther contributing to the support of indirect jobs and the creation of local income in all geographical areas we operate. [GRI 204-1] 133 132

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