Sustainable Development Report 2019

The main challenges for the Company are the effective pre- vention of the likelihood of any form of pollution of the natural environment from its production activity, as well as of any major industrial accidents. Major risks [GRI 102-15] Risk Management / Control Practices [GRI 103-2a] The possible deterioration of the quality of the air and of surface and ground waters, and the pollution of the soil from industrial accidents are permanent potential risks. Failure to prevent and manage the above risks could have a sig- nificant impact on the Company's economic, industrial and social capital, limiting its capacity to create value. From the Company's perspective, the increased financial costs for dealing with these incidents, any likely administrative sanctions and penalties, the potential inability to continue its business activities and the loss of its “social license to operate”, are some of the potential negative impacts affecting the protection of its employees, the environ- ment and the Company's own viability. Pollution risk management requires the implementation of pre- cautionary and repressive measures in all areas of MYTILINEOS Business Activity Sectors. Specifically: In the case of the Metallurgy sector , an Industrial Safety Management System is in place, which covers all the sector's activities, designed to prevent and respond to major industrial accident hazards by ensuring that a series of actions and param- eters aimed at preventing the occurrence of such incidents are followed. The main objective is to avoid any incident involving a degradation of the environment. The preventive measures consist of the following: • Strict compliance with the approved Environmental Terms of the Metallurgy activity. • The continuous measurement and monitoring of gas emis- sions and water discharges from point sources, • Compliance with the measures foreseen in the Safety Study (SEVESO III – implementation of JMD 172058/2016). • The final disposal of non-hazardous waste in insulated areas with the construction of a geological barrier of low water per- meability, as well as the corresponding disposal of hazardous waste in specially constructed and insulated with geomem- brane and geotextile cells • Implementation of Best Available Techniques in the manage- ment of industrial waste. (electric filters, bag filters, primary industrial waste treatment, biological wastewater treatment, safety oil taps, sewer oil traps, tank level meters, waste quality meters, specially designed waste disposal sites, etc.) • Good knowledge of and training in Emergency Response Plans (EPs). • The storage and use of chemicals under the instructions of the Safety Data Sheets • The systematic visual inspections of the facilities • The unloading of fuel oil from tankers with the precautionary use of a floating anti-pollution dam, and • Systematic monitoring of the quality of the natural recipients (aquifer – sea) and comparison with standard quality values. Pollution prevention Materiality assessment process results. Scale: [0—4] where 0 “Not significant” and 4 “Very significant” Impact on Sustainable Development 3,80 Significance for Stakeholders 3,64 Management Approach [GRI 102-11] [GRI 103-2c] The purpose of this disclosure is to provide information and data to MYTILINEOS' Stakeholder groups, so that they can understand how the Company is managing the risks of pollutions and spills directly associated with its safe and socially and environmentally responsible operation. [GRI 103-2b] An example is the discharge of the seawater used in the cool- ing systems of the Combined Heat and Power (CHP) plant of the Metallurgy sector, where in addition to the strict compliance with the relevant provisions of the law determining the frame- work for preventing any environmental impact, the Company commissions an authoritative organization (Hellenic Centre for Marine Research – HCMR) to conduct a research study form monitoring the status of living organisms in the Antikyra Bay seabed. The studies carried out by the Company in accordance with the applicable Environmental Terms are communicated every year, together with their results, in accordance with the applicable provisions, to the competent authorities (the Ministry of Environment and Energy and the Water Management Directorate of the Decentralized Regional Administration). The findings of the recent studies carried out in 2018 and 2019 show a stable ecological status, with improvement trends at several observation stations. These studies will be continued for at least five more years. In what moreover concerns the unavoidable incidents involving spills of lubricants in the context of mining activities in the tunnels of underground quarries, which are very small and superficial and are mainly caused by wear and tear of lubricant pipes and by damages to machinery by falling stones or rocks, the subsid- iary DELPHI – DISTOMON takes steps to prevent and reduce the annual number of such incidents by adopting the following prac- tices: (1) Purchasing supplies (lubricant pipes) with the best quality available in the market, to ensure their maximum possible dura- bility; (2) implementing, on an annual basis, custom-developed seminars to raise awareness among personnel of the need to report and log such incidents, in line the Company's policy on the protection of the environment, as well as of specific techniques to contain the extent of the spills in the soil; and (3) responding immediately to such incidents, by carefully collecting the quantity of contaminated soil and forwarding it to the hazardous waste dis- posal area for appropriate handling and (4) implementing regular and preventive maintenance of equipment and its components. In the Electric Power sector and the EPC & Infrastructure Projects sector, in all production units (thermal plants, RES plants, complex construction plants and work sites) all potential risks are identified in order to address in a timely manner and minimize the consequences of unforeseen malfunctions and accidents. In particular, the following apply: • All procedures provided for in the Environmental Management Systems and Emergency Response Plans, as well as the operat- ing and maintenance instructions for installations, • the instructions for monitoring air emissions, • the best available options for the re-use, recycling and disposal of the various types of waste generated, • personnel training, • preventive maintenance programs, • selection of state-of-the-art equipment, • safety basins and • systematic visual environmental inspections of installations. Boundaries of the Material Issue [GRI 102-46] [GRI 103-1b] Issue of increased significance to: Where the impacts occur: The impacts take place in the operating areas of the industrial Business Units, the subsidiaries and the main suppliers of MYTILINEOS. The management of the topic by MYTILINEOS contributes to the Sustainable Development: All Stakeholders' groups in the context of their cooperation with MYTILINEOS. • In the prevention of any land and sea pollution. • In the environmentally proper management of all waste in accordance with internationally agreed frameworks and reduction of their emissions into the air, water and soil in order to reduce their impact on human health and the environment. • Reduction of waste production through prevention, recycling and reuse. By whomare the impacts caused: Directly involved in these impacts are the Metallurgy and Electric Power Business Sector of MYTILINEOS, the subsidiaries DELFI-DISTOMON and KORINTHOS Power, while indirect participation in them may have key suppliers of the Company. Key Challenges / Impacts [GRI 103-1a] [GRI 102-15] 75 74

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