Sustainable Development Report 2019

Legal Compliance Management Approach [GRI 102-11] [GRI 103-2c] For MYTILINEOS, a fundamental and non-negotiable principle is that its business activity is carried out in complete alignment, conformance to and compliance with the laws in force and the principles of operation applicable in every geographical region or country where it operates. Compliance with the legislation (environmental, social and product-related) is a core element of the Company’s business activity and a major issue of equal significance with the other issues that the Company is managing in the context of its ongoing and responsible development. This stance is based, first and foremost, on the principle of adhering to the provisions of the law, as well as to the agreements concluded and the voluntary commitments made by the Company through its Business Activity Sectors. [GRI 103-2b] Key Challenges / Impacts [GRI 103-1a] [GRI 102-15] Maintaining regulatory compliance at environmental, social and product level, in order to ensure that the overall corporate activity is lawful, meets high standards of responsible entrepreneurship and strengthens the climate of trust between the Company and its Social Partners who interacting with it (customers, employees, suppliers, administrative authorities etc.). Cases of non-compliance could have a significant impact on the profitability, financial position and cash flows of MYTILINEOS and, consequently, on its ability to meet its obligations. Major risks [GRI 102-15] • Risks of an economic nature, which may arise from possible unfavorable outcomes of legal disputes regarding non-compli- ance with the legislation in general • Possible non-compliance of the Company with its obligations under the environmental legislation and, more specifically, with the terms of the environmental licenses of its industrial plants. In this case, the competent authorities may impose fines or sanctions, and may also withdraw or refuse to renew permits and approvals in the event of a breach of the applica- ble regulations. • The Company operates in countries with emerging econo- mies, where institutional functions may be affected by political conditions and changes there to. This could negatively affect the activities of MYTILINEOS in the context of obtaining and maintaining permits and approvals. Risk Management / Control Practices [GRI 103-2a] • In order to prevent the aforementioned risks, the Company: (a) complies with the legal and regulatory requirements of the geographical regions in which it operates, even if such laws and regulations are not adequately implemented; (b) ensures that its relations and activities comply with the established and applicable institutional framework; (c) is kept informed of its applicable legal obligations; and (d) reviews its compliance with applicable laws and regulations on a regular basis. • Additionally, monitoring compliance with the approved envi- ronmental licenses (Environmental Terms Approval Decisions) for the Company’s operational units, is a process conducted internally, on a regular basis, in each Business Unit, by qualified personnel, as well as annually, by a recognized indepen- dent organization which undertakes to audit and certify the Company’s environmental management system. • Finally, as a member of the UN Global Compact, the Company strives to ensure that its business practices are fully aligned with the Compact’s internationally recognized Ten Principles. Furthermore, under its Corporate Social Responsibility Policy in place, the Company undertakes to adopt a responsible, sustainable and ethical business conduct that is regularly evaluated on the basis of the results achieved, and to improve Results [GRI 103-3a-ii] Compliance with the applicable legislation, as well as the updat- ing and implementation of the environmental rules concerning the activity of MYTILINEOS, in 2019, resulted in the absence of incidents of non-compliance with the legislation and with the applicable regulations at environmental, social and economic level . [GRI 307-1] Materiality assessment process results. Scale: [0—4] where 0 “Not significant” and 4 “Very significant” Impact on Sustainable Development 4,00 Significance for Stakeholders 3,71 its environmental and social performance as well as its perfor- mance regarding transparency and corporate governance. Boundaries of the Material Issue [GRI 102-46] [GRI 103-1b] Issue of increased significance to: Where the impacts occur: The impacts of non-compliance with laws and regulations occur primarily within the operational boundaries of the Company and of its subsidiaries, strategic partners and suppliers. They can also extend to the entire economy and – in the context of sustainable development – to the environment, as well as to 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. • Enforcement of and compliance with non-discriminatory laws aimed at promoting sustainable development. By whomare the impacts caused: The impacts may be caused by MYTILINEOS’ Business Activity Sectors, employees, subsidiaries, business partners and supply chain. 145 144

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