Sustainable Development Report 2019

Seeking to provide the fullest possible information to its share- holders, to investors and to all its other Social Partner groups, MYTILINEOS' approach to Materiality consists of the following two strands of work: (a) the identification of the significant Financial issues which allow the Company's financial growth, performance and position to be evaluated, and (b) the identification of the Material Non-Financial issues which specify the positive or neg- ative impacts of its activities on its Social Partner groups, on the natural environment and on the wider society. The Materiality process, i.e. the process of identifying, under- standing and prioritizing the sustainability issues, is one of the key elements in the Company's responsible operation. Through the assessment of the Material Non-Financial issues, MYTILINEOS enriches and shapes its strategy on Sustainable Development, with the aim of operating responsibly in all its activities, at local, national and international level. This is a process that has been constantly evolving over the years and in which the individual assessments of the Material issues carried out by each Business Activity Sector are brought together and used as the basis for the prioritization of the respective issues which takes place centrally, and vice versa. At the same time, the Company's open dialogue with its Stakeholders, in addition to enhancing its ability to understand the impact of its activities, enriches this process with new inputs. Materiality process In 2019, MYTILINEOS, based on the Materiality, Completeness and Stakeholder Inclusiveness principles of the GRI Standards, performed the Materiality analysis of the identified sustainability issues which are related to the scope of its activities. New ele- ments introduced in this year's process were the following: • The creation of a new custom matrix presenting the sustain- ability issues in correspondence with the internal and external sources used by the Company in order to best determine them as identified ones. • The presentation of the individual sustainability issues, previ- ously grouped into broader categories for the purposes of their identification and prioritization by the Social Partner groups, so that the impacts of individual issues and the relevant needs and expectations of the Social Partners can be assessed individually. • The introduction of a new online platform for the prioritization of the identified issues, offering access to qualitative data and relevance factors for every Business Activity Sector, with a view to further improving the internal consultation on updating these issues, which is carried out on an annual basis. • The conduct of an online survey of 1,222 individuals, bodies and organizations representing all of the Company's Social Partner groups. A detailed presentation of the stages in the process of identifying the Material Non-Financial issues for the year 2019 is given below: Materiality analysis of sustainability issues [GRI 102-46] Identification Stage Sources used in the sustainability issues identification process PRINCIPLE: Stakeholders inclusiveness PRINCIPLE: Sustainability Context • MYTILINEOS' CSR policy & strategic priorities. • Business mission & values. • Codes of Business Conduct. • Overview of the items discussed in the meetings of the Company's Executive Committee. • 10 International Standards and CSR / Sustainable Development initiatives (UNGC, SDGs, TFCD, OECD, CDP, GRI, ISO26000, TI, PRI, SASB etc.). • 15 ESG investment indicators (FTSE4Good, Bloomberg, Thompson Reuters, Arabesque, ISS, MSCI etc.). • Content of publications in the press by and about the Company, as well as general publicity in this area. • Basic overview of the competitive environment. • Requirements under the European and Greek legislation. • Ways of communication with the Stakeholders. 22 issues identified in total Prioritisation Stage Synthesis of findings from the prioritization of the issues identified within & outside the company PRINCIPLE: Stakeholders inclusiveness PRINCIPLE: Materiality Within the Company • Use of a new online application for the prioritization of the identified issues, with reference to their relevance for MYTILINEOS, their impact on Sustainable Development at local and national level, and their correlation with the Sustainable Development Goals. • Working meetings of the CSR Teams of the Company's Business Activity Sectors for prioritizing the identified issues – Confirmation and approval of the results by the respective Directorates-General of the Business Activity Sectors – Synthesis of the individual results and determination of the final value for each identified issue. Outside the Company To determine the significance of the influence of each identified issue on the Social Partners' assessments and decisions, an electronic questionnaire was sent to 1,222 individuals, bodies and organizations, of which 35% sent back their responses. This was followed by the synthesis of the results obtained, taking into account the degree of significance given by each Social Partner group for each identified issue, based on their cooperation with the Company, after which the final value for each identified issue was determined. 15 issues characterised as Material The 15 material issues (with value >3.5 / 4 on the evaluation scale) include: a) the 4 most important issues for the Stakeholders, b) the 6 most important issues in terms of their impact on Sustainable Development and c) the 5 issues important both for Stakeholders and for their effects on Sustainable Development. 4.0 4.0 3.0 3.0 3.5 3.5 2.0 2.0 Significance for Stakeholders Significance of impacts on Sustainable Development Threshold Threshold Social issues Environmental issues Governance issues Customer Health & Safety Circular economy (waste management) Adaptation to climate change Emergency response plans Anti-Corruption and Bribery Pollution prevention Occupational Health & Safety Legal compliance Energy & Air emissions Environmental restoration & Biodiversity Economic Performance Water management Sustainability of local communities Human Rights Employment Management of raw & other materials Customer privacy Training & Evaluation Equal opportunities & Diversity Uniform corporate culture Communication & Marketing Responsible supply chain Materiality table 2019 [GRI 102-47] 39 38

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