Sustainable Development Report 2019

Key Challenges / Impacts [GRI 103-1a] [GRI 102-15] The key challenge for the Company is to safeguard biodiversity and restore the natural landscape in usable land areas associated with bauxite mining activities as well as with the development and operation of Renewable Energy Sources (RES) projects. Major risks [GRI 102-15] Risk Management / Control Practices [GRI 103-2a] • Negative impacts from the Company's activities on the flora and fauna in protected areas or in areas of a high biodiversity value, are a permanent potential risk. Failure to monitor and manage these risks may cause delays in obtaining relevant per- mits for future projects, as well as loss of the Company's social license to operate with a negative impact on its reputation and financial position. • Any deviation from the Environmental Terms Approval Decisions may cause both the degradation of the natural environment and the suspension of the project with immediate financial consequences for the Company. In theMetallurgy sector, the area of the aluminium production plant does not fall under any category of areas protected by law, while the mining activity carried out by DELPHI – DISTOMON company, a subsidiary of MYTILINEOS, which concerns primarily underground work sites in the area of Fokida , is performed with respect to the area's biodiversity. Before each new mining activity begins, Environmental Impact Assessments and Environmental Rehabilitation Plans are carried out and used as a basis for the mining phase but also for the rehabilitation phase. The areas where mining will take place, to be followed by rehabilitation, are pinpointed with precision, and the planning for each mining exploitation is developed considering the need to minimize deteriorations to the natural environment and the landscape . Measures taken to prevent significant adverse effects on the environment: • Use of the existing road network and prohibition of opening new roads. • Use of existing access land works and in-site installations. • Prohibition of depositing or managing sterile limestone waste from the mining process on the soil. • Systematic maceration of all mining work areas for dust emis- sion suppression. • The management of all types of non-hazardous waste com- plies with the provisions of the applicable laws, while the disposal of these wastes takes place only through certified bodies/contractors. Moreover, a detailed mapping of the form and type of the vege- tation that is established, so that rehabilitation can be based on Environmental Restoration & Biodiversity Materiality assessment process results. Scale: [0—4] where 0 “Not significant” and 4 “Very significant” Impact on Sustainable Development 4,00 Significance for Stakeholders 3,46 Management Approach [GRI 102-11] [GRI 103-2c] The purpose of this disclosure is to provide specific information and data to all MYTILINEOS' Stakeholder groups, so that they can understand the Company's approach, which relies on a combination of elements to prevent, manage and restore the inevitable impacts on the areas used for its business activity, while minimizing any effects on biodiversity. [GRI 103-2b] the unique features of the local ecosystem. The environmental policy of DELPHI – DISTOMON ( alhellas.com/en-us/enviromental- policy/enviromental-policy ) emphasizes its commitment to the protection of biodiversity and helps further contain any adverse effects, which are already quite limited in scope and temporary in nature. The Company is also committed to securing the financial resources required to support adherence to the environmen- tal terms and the performance of rehabilitation works, whose costs are included in advance in the budget of the corre- sponding project. The closing-down and remediation plan for every site is specified by the Environmental Terms Approval Decision, and it is updated on a regular basis, while the project manager is obliged to submit to the competent Environment Department of the Regional Unit of Fokida, in the first month of each year, a topographical diagram (to a scale of 1:2000) together with a technical report, which pres- ents and describes the progress of the remediation works. DELPHI-DISTOMON has been systematically active for more than 47 years in environmental rehabilitation and all its inactive quarries have been restored. Environmental remediation is carried out through systematic tree planting of approximately 15-20,000 tree/seeds per year, while during 2019, 19,532 forest seedlings were planted . Until today, DELPHI-DISTOMON has planted approxi- mately 1,158,500 trees covering a total afforested area measuring over 1.8 km2. In addition, 74.5 kmof fencing have been installed (to protect the tree planting), together with a 715 km long network of watering-irrigation pipes for those trees. It should also be mentioned that over the last 6 years, on average, 250,000 tons of sterilized limestone are produced during the mining process. This quantity has been disposed to already exist- ing sinkholes of surface and underground construction sites and thus not a single squaremeter of land had to be binded for the disposal of this type of waste . In the Electric Power & Gas Trading sector and with respect to the activities which concern the construction and operation of wind farms located near or inside areas designated as Special Protection Areas, a key prerequisite is the development of the respective environmental impact studies foreseen (specific ecological assessment, annual monitoring of the protected area), to confirm that there are no impacts or, in cases where there are impacts, to describe the measures which may be adopted in order for these impacts to be avoided. In line with the above, the impacts in the locations of the Company's activities are negligible in terms of pollution (gaseous, solid or liquid waste), themovement of animals is not obstructed as there is no fencing, and the disturbance to the local popu- lation of birds is negligible, while where this is necessary, Boundaries of the Material Issue [GRI 102-46] [GRI 103-1b] Issue of increased significance to: Where the impacts occur: Ιn the area where the mining activities of DELPHI-DISTOMON take place, as well as in protected areas of the Natura Network where the Company's RES plants operate. The management of the topic by MYTILINEOS contributes to the Sustainable Development: • Regulatory bodies • Local communities • Sustainable Development Organizations • Academic community • Shareholders • Media representatives in the context of their cooperation with MYTILINEOS. • In the conservation of mountain ecosystems, including biodiversity. • In the restoration of the exploitable land that was affected by the business activity. • To increase forestry and reforestation at local and national level. By whomare the impacts caused: The impacts are caused by the subsidiaries of MYTILINEOS: DELPHI – DISTOMON, Aeoliki Sidirokastrou S.A., Aeoliki Evia Pyrgos S.A. and Aeoliki Evia Chelona S.A. 63 62

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