Sustainable Development Report 2019

Special Governance Targets Targets 2019 Performance 2019 Targets 2020 Confirmed conditions that support the development of corruption and bribery 0 0 0 Financial charges from violation of the Code of Business Conduct (€) 0 0 0 Confirmed cases of non-compliance with regulations and legislation (on issues economic, environmental, labor & social) 0 0 0 Anti-Corruption and Bribery Management Approach [GRI 102-11] [GRI 103-2c] MYTILINEOS acknowledges that transparency is guaranteed in all transactions developed in the context of its business activities is a key point for sustainability and further its development in the context of its international activity. The purpose of this disclosure is to inform the Social Partners of MYTILINEOS on the way the Company manages both the absolute restriction of its exposure to corruption & bribery, as well as strengthening the culture of compliance with the anti-corruption legislation. [GRI 103-2b] Addressing corruption and bribery is of major significance for MYTILINEOS, because: (a) it contributes to improve risk identification, assessment and management, as well as compliance with the laws, which for MYTILINEOS is a non-negotiable principle in every geographical region or country where it operates, (b) it serves its business goals (such as fulfilling the relevant tender requirements for construction projects), and (c) it strengthens the Company's protection against fraud, embezzlement and abuse, further enhancing its corporate image. Materiality assessment process results. Scale: [0—4] where 0 “Not significant” and 4 “Very significant” Impact on Sustainable Development 3.50 Significance for Stakeholders 3,71 Boundaries of the Material Issue [GRI 102-46] [GRI 103-1b] Issue of increased significance to: Where the impacts occur: The impacts of corruption in all its forms are an obstacle to Sustainable Development and can occur across the entire range of the Company's operation, with consequences for its local communities, the wider business environment and society as a whole. The management of the topic by MYTILINEOS contributes to the Sustainable Development: All Stakeholders' groups in the context of their cooperation with MYTILINEOS. • Elimination of all forms of corruption and bribery. By whomare the impacts caused: The impacts may be caused by MYTILINEOS’ Business Activity Sectors, employees, subsidiaries, business partners and supply chain. 141 140

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