Table of Contents
1. Objective and Basis for the Preparation of the Annual Integrated Report ............................................................1
2. Chairman’s Message...............................................................................................................................................2
3. Representation of the Members of the Board of Directors ...................................................................................4
4. Business Profile & Highlights 2024 .........................................................................................................................5
5. Annual Board of Directors Management Report..................................................................................................11
6. Explanatory report .............................................................................................................................................334
7. Statement of Corporate Governance .................................................................................................................338
8. Report on the activities of the Audit Committee ...............................................................................................417
9. Independent Auditor’s Report ...........................................................................................................................429
10. Annual Financial Statements..........................................................................................................................438
11. Availability of Financial Statements ...............................................................................................................550
12. Appendix I - Unbundled Financial Statements of Energy Segment METLEN Energy & Metals S.A. - Group of
Companies ..................................................................................................................................................................551
13. Appendix II - Annexes of the Sustainability Statement .......................................................................................558
1. Objective and Basis for the Preparation of the Annual Integrated Report
1
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The objective of METLEN's first Integrated Report is to provide a comprehensive and transparent picture of the company's
strategy, performance and prospects, focusing on both financial results and environmental, social and governance aspects of its
business. This report highlights how METLEN creates value for its shareholders and other stakeholder groups by highlighting the
interconnection between financial and sustainability elements.
In addition, this report covers the requirements of the new European Corporate Sustainability Reporting Directive (CSRD), which
has been incorporated into national law, and which requires companies to report the impacts, risks and opportunities of their
business activities in relation to sustainable development.
In the context of this new regulatory approach, METLEN publishes the chapter "Sustainability Statement", within the Annual
Management Report of the Board of Directors, which henceforth replaces the issuance of separate Sustainability Reports
published by the Company, until 2023.
The consolidated Financial Statements have been prepared in accordance with the applicable International Financial Reporting
Standards, as adopted by the European Union and the Sustainability Statement in accordance with the European Sustainability
Disclosure Standards (ESRS).
1. Objective and Basis for the Preparation of the Annual Integrated Report
2. Chairman’s Message
2
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Message from the Chairman and CEO of METLEN Energy & Metals, Evangelos Mytilineos, on the 2024 Annual Report
With great pride, we present the Annual Report of METLEN Energy & Metals, which also marks the Company’s First Integrated
Annual Report. It provides a comprehensive and balanced overview of our strategy, business initiatives, financial performance,
and overall approach to sustainable development, enhancing transparency and clarity in analyzing the challenges, opportunities,
and factors that shape our course.
The year 2024 was another year filled with significant challenges, characterized by tectonic changes and escalating geopolitical
tensions worldwide. Amid this unstable global environment, METLEN Energy & Metals demonstrated resilience, solidified its
position in the sectors and markets in which it operates, and continues to move forward steadily, with a clear plan, vision, and
ambition.
The past year was a milestone, as we achieved major accomplishments, secured significant agreements, completed targeted
acquisitions, and further strengthened our position in the Energy and Metals sectors. It was also the year that marked the full
completion of our second major transformation, the impact of which is now clearly reflected in our performance, with a vision
to establish our company as a global leader. With foresight, we addressed the major challenges of our time: the energy transition,
the digital revolution, industrial transformation and green excellence, the circular economy, the development of emerging
markets, the increasing demand for energy, the rising cost of goods and services, and the new requirements of the labor market.
With stability and determination, we managed to turn these challenges into opportunities, completing a significant cycle to open
a new chapter for our company. We are now ready to face the challenges of the future with the same determination and vision.
We changed our name after 116 years, looking toward the future while respecting the long history and legacy of all that we have
achieved together on this journey. We renewed our corporate identity, transitioning from MYTILINEOS Energy & Metals to
METLEN Energy & Metals, shaping a new era characterized by strategic foresight and operational excellence. Our only constant
is evolution—driven by passion, vision, and unwavering commitment to our goals.
Our goal is the further internationalization of our Company. In this context, we are also pursuing a listing on the London Stock
Exchange, a process we have already set in motion. Our international presence, combined with our continuous evolution into a
company with high expertise and innovation, enables us to chart a clear roadmap for establishing and expanding our presence in
one of the world’s leading companies. Our core pillars: Energy and Metals.
Today, METLEN Energy & Metals is a leading international player in the Metals sector and the largest fully integrated producer
of bauxite, alumina, and aluminum in the European Union. With the completion of the acquisition of IMERYS Bauxites and the
creation of "European Bauxites," alongside "Delphi-Distomon," we have established the largest bauxite producer in Europe.
Additionally, we have integrated Gallium into our industrial production—a critical material of strategic importance for Europe's
future. Furthermore, we recently announced an iconic investment plan with a total budget of €295.5 million, aimed at
significantly increasing our production capacity for bauxite, alumina, and Gallium.
Similarly, we aim to expand our activities in bauxite mining and alumina production with the license we obtained for Bauxite
Exploration and Exploitation in Ghana, a region estimated to have geological reserves of 300 million tons of bauxite. The
"Integrated Bauxite & Aluminum Project in Ghana" has been included in the European Union’s flagship projects list, “Global
Gateway,” receiving substantial support—an acknowledgment of the project's strategic significance. At the same time, this
confirms METLEN’s role as a catalyst for sustainable investments that strengthen Europe’s strategic autonomy in critical raw
materials.
Moreover, we have reinforced the Metals sector and are moving forward with the creation of a new, large-scale, high-tech
industrial unit for specialized metal constructions in Magnesia, aiming to expand the range of produced goods and leverage all
possible synergies with our existing facility in Nea Ionia, Volos.
In the Energy sector, Protergia—an integral part of METLEN—maintained stable and unchanged electricity tariff rates, providing
tangible support to consumers in a period of increased volatility. Consumer trust is reflected in Protergia’s continuously growing
market share in the domestic retail electricity market, now exceeding 20%, with a goal to reach 30%.
Significant projects were also undertaken by the Power Projects sector. In the United Kingdom and Ireland, we signed two long-
term Power Purchase Agreements (PPAs) with Keppel DC REIT, a leading provider of Data Centers in the country, to supply energy
to two of their facilities in Dublin from photovoltaic parks. In Poland, in a consortium with Siemens Energy Global GmbH & Co KG
and Siemens Energy sp. z o.o. (SIEMENS ENERGY), we undertook the construction of a 560 MW CCGT power plant with related
infrastructure at the Adamów power station in the Turek region of Poland.
In the Renewables sector, our Company maintained its focus on international markets, securing a landmark strategic agreement
with PPC for the development and construction of a solar project portfolio of up to 2,000 MW in Italy, Bulgaria, Croatia, and
2. Chairman’s Message
2. Chairman’s Message
3
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Romania, valued at up to €2 billion. Just eight months after the agreement between METLEN and PPC, our Company delivered
the first 32 MW in Italy. In Chile, we inaugurated our second solar park, Doña Antonia, a total investment of $65 million, with an
installed capacity of 90 MW, to provide 100% renewable energy for the country’s green growth. The park generates energy
equivalent to the annual consumption of over 85,000 households, reducing emissions by more than 80,000 tons of CO
2
annually.
The leading international expertise we have developed in renewables was recognized with €400 million in financing from the
European Investment Bank to support our strategy for renewable energy production across Greece and other EU countries.
Additionally, our Company issued a five-year "green" bond of €750 million at a 4% interest rate, marking a record amount for a
company listed on the Greek market. The issuance also saw participation from the European Investment Bank (EIB), marking the
first time the EIB has participated in a Greek green bond issuance.
Made of Metal and full of Energy, METLEN is shaping its future as a global leader in the Energy and Metals sectors. Through
strategic partnerships, international expansion, and responsible social and environmental practices, we continue to define the
future of sustainable development, setting a new standard on the global business map.
We have continued implementing key initiatives aligned with the Global ESG Goals. The "Learning to See the Human" program
contributed to combating discrimination and promoting inclusion, while our support for the FemStem initiative empowered
women in the field of science. Through the Data Youth program, we enhanced young people’s digital skills, preparing them for
the job market, and implemented reforestation initiatives to support environmental protection. The illumination of the Temple
of Poseidon in Sounion, as part of the “Journey to Light” program, highlighted our cultural heritage with respect for the
environment.
At the same time, METLEN has proudly reaffirmed its strong commitment to continuously improving its sustainability
performance. For the second consecutive year, we are in the LEADERS group of the MSCI ESG Rating index. We also remain the
only Greek company included in the Dow Jones Sustainability Index Best-in-Class (Emerging Markets) for the third consecutive
year, while achieving the highest score in the Multiline Utilities sector of the London Stock Exchange Group’s ESG Rating index.
Sustaining strong financial performance is essential to our ongoing growth, while our commitment to sustainable development
is at the core of our strategic operations. In this context, in 2024, METLEN’s Green EBITDA growth was remarkable, exceeding
€350 million in absolute terms and now representing one-third of the Company’s total profitability, compared to approximately
8% in 2021.
At METLEN, we work with strategic planning, vision, and ambition to reach even greater heights. With prudence and a deep sense
of responsibility, we are committed to maximizing the return on every resource—financial, human, natural, and social—that we
utilize to produce our products and develop our services. Our goal is to reward our shareholders' trust by creating lasting value
for them, our employees, our customers, and society as a whole. We are committed to strengthening our global leadership
position while ensuring sustainability and responsible growth for the benefit of future generations.
3. Representation of the Members of the Board of Directors
4
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The
Evangelos Mytilineos, Chairman of the Board of Directors and Chief Executive Officer
Spyridon Kasdas, Vice – Chairman A’ of the Board of Directors (non-executive member)
Dimitrios Papadopoulos, Executive Member of the Board of Directors
CERTIFY
a. the enclosed Financial Statements of “METLEN Energy & Metals S.A.” for the period of 01.01.2024 to 31.12.2024,
drawn up in accordance with the applicable accounting standards, reflect in a true manner the assets and liabilities,
equity and results of “METLEN Energy & Metals S.A.”, as well as of the businesses included in Group consolidation, taken
as a whole
and
b. as far as we know, the enclosed report of the Board of Directors is fair, balanced and understandable and reflects in a
true manner the development, performance and financial position of “METLEN Energy & Metals S.A.”, and of the
businesses included in Group consolidation, taken as a whole, including the description of the principal risks and
uncertainties.
Maroussi, 12 March 2025
The designees
Evangelos Mytilineos
Spyridon Kasdas
Dimitrios Papadopoulos
Chairman of the Board of Directors
and Chief Executive Officer
Vice – Chairman A’ of the Board of
Directors
Executive Member of the Board of
Directors
3. Representation of the Members of the Board of Directors (according to article 4 of L. 3556/2007)
4. Business Profile & Highlights 2024
5
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Profile
METLEN Energy & Metals (previously known as MYTILINEOS Energy & Metals) (onwards the “Company” or “METLEN”) is a global
industrial and energy company with a leading position in the metals and energy sectors, focused on sustainable development
and the circular economy. The Company has established itself as a benchmark for competitive "green" metallurgy at both the
European and global levels, while offering comprehensive energy solutions. It operates in markets across all five continents, while
listed on the Athens Stock Exchange, with a consolidated turnover of €5,683 million and a total of 7,620 direct and indirect
employees.
Our Vision
“Inspired and motivated by our Greek heritage, to lead our business to global success”.
Our Mission
“We operate in demanding local and international markets, with ingenuity, efficiency and respect for the environment and
society. We rely on the potential of our people and create value for our customers, shareholders, employees and the Greek
economy”.
Our Corporate Values
Effectiveness with Safety First.
Relentless struggle of our People for Competitiveness.
Respect and Important Role for each Employee.
Two success factors: teamwork and excellence.
Continuous Progress by Everyone in Everything We Do.
Key Group Figures
€5,683 million
Turnover
9.4 TWh
Total power production
€1,080 million
EBITDA
11.1 GW
Global RES portfolio
(in all stages of development)
€615 million
Net Profit
18.5%
Market share - Supply of Energy & Natural
Gas
€4,788 million
Market Capitalization
238 ktons
Total Aluminium Production
(Recycled Aluminium: 23.5%)
7,627
Direct and indirect employees
865 ktons
Alumina Production
4. Business Profile & Highlights 2024
4. Business Profile & Highlights 2024
6
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Business Sectors
ENERGY SECTOR
METLEN is currently the largest private company, along with its subsidiaries, operate across the entire energy spectrum,
functioning as a fully integrated energy utility. Its activities range from the development, construction, and operation of thermal
power plants and RES projects, the design and construction of electricity infrastructure projects to the retail electricity and natural
gas supply, natural gas procurement and trading, as well as offering competitive energy products and services.
In summary, the Energy Sector consists of five activities: M Renewables, which develops RES and energy storage projects
worldwide; M Energy Generation & Management, which manages power generation and energy plants; M Energy Customer
Solutions, which focuses on retail electricity and natural gas supply, as well as new retail products and services; M Integrated
Supply & Trading, which deals with the procurement and management of natural gas and other energy products for large B2B
corporate clients in Greece and abroad; and M Power Projects, which focuses on the development of large-scale energy projects
for electricity production, energy transition, and more.
Specifically, METLEN Energy & Metals is a global manufacturer and contractor of solar energy and energy storage projects,
offering reliable solutions across the entire development spectrum of these projects, from standalone projects to complex hybrid
systems. With strong expertise, international operations, and unparalleled responsiveness, it designs and implements high-
quality projects for its customers. The company also has a portfolio of RES (of all technologies) and storage projects, both in
Greece and abroad, totaling 11.1 GW.
Through Protergia, the company is active in the retail supply of electricity and natural gas, aiming to offer reliable solutions,
competitive products, and modern services to businesses, professionals, and households. METLEN's offerings extend to areas
such as energy efficiency, smart cities, facility management, Internet of Things/digital services, and more, addressing the needs
of its customers. METLEN Energy & Metals is the largest independent producer and supplier of electricity in Greece. The company
has in-depth knowledge of the electricity market and continuously implements environmentally friendly investments, positively
contributing to the Greek economy and employment.
With an energy portfolio of over 2 GW in thermal units, it boasts a strong Energy Management system, which includes the
management and operation of thermal power generation units, participation in market bidding & non-physical power trading, as
well as the management of generated energy from generation assets (thermal and renewable energy) and third-party PPAs.
Additionally, the company manages RES and develops green VBL products.
The company's activity in the Energy Sector is further strengthened by its involvement in the procurement and management of
natural gas and other energy products on competitive terms, customer-facing services, and the provision of innovative products
and services for large B2B corporate clients in Greece and abroad.
In addition, the Company is a leading international contractor in the construction of specialized, large-scale, and value-added
energy projects, undertaking the full spectrum of services required for the successful execution of the project. This includes
conventional power generation projects, energy transition projects (e.g., distribution networks, hydrogen, etc.), as well as
projects focused on energy savings, digital transformation, smart cities, and IoT platforms.
METALS SECTOR
METLEN Energy & Metals holds a leading position in the Metals sector. It operates the only vertically integrated bauxite, alumina,
and primary aluminium production unit in the EU with its own port facilities, and the largest cogeneration power plant.
Additionally, it has made a strong entry into the recycled aluminum market.
The Metals sector includes the Delphoi-Distomo facility for bauxite production, the Aluminum of Greece plant, the largest
independent producer of recycled (secondary) aluminum, EPALME, the Volos plant for heavy and complex metal constructions,
and the zinc and lead metallurgy plant, Sometra. In 2023, the company acquired IMERYS BAUXITES GREECE, and through its newly
named subsidiary European Bauxites, solidified its position as the largest bauxite producer in Europe.
The international business activity of the Sector is a driving force for the national economy, but also for the development of the
Greek periphery. The "Aluminium of Greece" plant, having completed almost 60 years of operation and more than 20 years of
continuous development, with investments that exceeded € 600 million for the technological modernization of its facilities and
the development of its production and productivity, is one of the strong pillars of Greek industry and has established itself as one
of the strongest representatives of the sector in the European Union, with an annual production capacity exceeding 180,000 tons
of primary cast aluminum and 865,000 tons of alumina. At the same time, METLEN continues to invest in the production of
recycled (secondary cast) aluminium, in which the circular economy is fully implemented, reaching a production capacity of
65,000 tons per year, significantly reducing total energy consumption per ton of production and carbon dioxide emissions. At the
same time, the new major investment announced at the beginning of 2025, aimed at expanding bauxite and alumina production
and constructing a new facility for gallium production, is expected to strengthen both Europe's autonomy in critical raw materials
and Greece's strategic position, along with that of the company, on the global stage.
METLEN procures two main raw materials used in the alumina production process: bauxite and sodium hydroxide (caustic soda)
and markets two grades of alumina products: anhydrous alumina and hydrated alumina. Moreover, METLEN markets two main
4. Business Profile & Highlights 2024
7
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
categories of aluminium products: columns and aluminium plates.
The majority of METLEN customers are manufacturers, but sales are also made to dealers. METLEN maintains long-term
relationships of more than 10 years with the majority of aluminium customers.
INFRASTRUCTURE & CONCESSIONS
Along with its two main business Sectors, METLEN Energy & Metals has created two new subsidiaries, utilizing the know-how and
international recognition that the Company has developed in the field of construction. These two companies gradually claim a
large share of the market for Infrastructure, Concessions and PPP projects that will be auctioned in the coming years, with more
than €20 billion of capital flowing to Greece, while our Company's goal is to expand its activity in this field abroad. Specifically:
METKA ATE, a subsidiary of METLEN, is dedicated to upgrade the infrastructure and construction sector by ensuring the necessary
management focus on these specific activities. At the same time, its operational efficiency is optimized as a distinct corporate
entity, and transparency in the presentation of financial data is reinforced. METKA ATE has extensive experience in the
infrastructure sector, holding a seventh-class contractor’s license. It now specializes in construction activities, undertaking
infrastructure projects such as roadworks, buildings, railway and port projects, as well as solid and liquid waste management
projects. The company is strategically positioned with advantages such as financial robustness, advanced technical expertise, and
personnel with extensive experience and knowledge. These assets enable METKA to take a leading role in the sector, contributing
significantly to the development of the country and the broader region. METKA ATE, continuing its strategic expansion plan into
the rapidly growing market of environmental projects, acquired 100% of the shares of M.T. ATE, a company engaged in the
undertaking and construction of public and private engineering projects, with a specialization in environmental projects.
M CONCESSIONS focuses exclusively on the pursuit, financing, design, construction, operation, and maintenance of
infrastructure, building, environmental, hydraulic, and energy projects. It also engages in other activities through its participation
in Public-Private Partnership (PPP) and Concession tenders. The company works closely with METKA ATE, which serves as its
construction arm. The business objective of M CONCESSIONS is to establish itself and secure a leading position in the sector of
co-financed projects, with an emphasis on sustainable investments that foster societal development and enhance the quality of
life for citizens.
International Presence
METLEN Energy & Metals has an extensive presence in markets across all five continents. The company operates in more than
40 countries, ensuring the continuous delivery of innovative solutions that address the modern challenges of the energy and
metals industry. METLEN’s global reach is supported by a strategic network of partners, facilities, and offices in key international
markets. From its advanced infrastructure in North America and Europe to the emerging markets of Asia, Africa, and Latin
America, METLEN plays a pivotal role in the development of sustainable energy solutions and the management of valuable
resources. Its broad geographic presence enables the company to adapt to the needs of diverse markets while maintaining a
strong focus on high standards of quality, safety, and sustainability
ESG Performance and Presence in International Sustainability Indices
4. Business Profile & Highlights 2024
8
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
International independent ESG rating agencies monitor METLEN's performance on an annual basis and, through different
methodologies, evaluate the practices applied to manage and minimize ESG risks and exploit the corresponding opportunities in
its operation. In 2024, the company received 15 ESG raitings, maintaining and further improving its already high performance.
As a result, METLEN remained in the top 10% of the best ESG performers in its field, according to 7 out of the 11 international
organizations that evaluate it.
SUSTAINABILITY INDICES & ESG RATINGS
ΜETLEN Energy & Metals’ presence
Sustainability Indices
2024
2023
2022
2021
2020
Dow Jones
Best-in-Class Emerging
Market Index
v
v
v
-
-
ΜETLEN Energy & Metals’ performance
Sustainability & esg
ratings
2024
2023
2022
2021
2020
MSCI
AAA
AA
AA
A
-
-
Sustainalytics
<10
16,5
18,7
22,4
22,4
30
S&P Global ESG
100
70
66
60
48
38
CDP
Climate
Α
B
Β
B
C
-
Water Security
A
B-
Β
B
B
B
LSEG
100
87
85
78
75
75
EcoVadis
100
78
78
67
58
58
FTSE Russel
5
4,4
4,2
4,2
3,9
4,1
ISS Corporate
Α+
C+
C
-
-
-
ISS Quality Score
Environment
1
1
1
1
1
2
Social
1
1
1
1
1
1
Governance
1
3
1
1
1
4
Bloomberg
100
78
78
74
66,5
62,8
Ideal Ratings
AAA
AAA
AAA
AAA
AAA
AA
ESG BOOK
Performance Score
100
70,5
74,2
66
66,2
62,4
Risk Score
100
73,0
72,2
72 (UNGC
Performance)
71 (UNGC
Performance)
70,9 (UNGC
Performance)
4. Business Profile & Highlights 2024
9
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Participation in Initiatives & Organizations
METLEN Energy & Metals plays a leading role in international business initiatives and organizations, with a strong focus on
sustainable development and responsible entrepreneurship. Recognizing its responsibility towards the environment, society, and
the economy, the Company actively participates in global collaborations that promote the principles of sustainability, innovation,
and transparency. [GRI 2-28]
Since 2008, METLEN has consistently declared its
commitment to the ten principles of the UN Global
Compact by disclosing its performance on an annual
basis.
Since 2016, METLEN has been supporting the
achievement of the Global Sustainable
Development Goals (2030 Agenda), contributing
to the respective national priorities .
Since 2019, METLEN has participated in the
international Aluminium Stewardship Initiative (ASI),
as a member of Production & Manufacturing.
Since 2012, METLEN has taken into account the
Principles of the International Standard of
Corporate Social Responsibility in its operation,
disclosing its progress and performance on an
annual basis.
As a founding member of the Council of the
Greek Federation of Enterprises (SEV) since
2008, METLEN is fully committed to the
relevant Code of Principles and actively
participates in its initiatives to promote and disseminate the
principles of Sustainable Development.
METLEN has been an ambassador of the
Greek Sustainability Code since 2015, having
actively contributed to its development,
either by submitting its views and initiatives
through the open consultation process in the context of the relevant
dialogue or by participating in the relevant working groups.
Since 2006, METLEN has been a principal
member of the CSR HELLAS Network, actively
participating in and supporting its various to
promote and disseminate CSR principles and
practices.
Through SEV, METLEN is part of the
Business Europe initiative, which aims to
promote growth and competitiveness at the European level and to
support European companies on the issues that most affect their
performance.
Since 2010, METLEN has been a member of the
"Hellenic Association of Independent Power
Producers”. This initiative's main objective is to
promote and manage issues related to the
generation and distribution of reliable, cost-
effective, and environmentally friendly electricity, as well as the
deregulation of the market for all energy raw materials.
In 2024, METLEN’ Chairman and CEO
Evangelos Mytilineos was re-elected for a
second term, President of the Pan-
European Association Eurometaux, which represents the non-
ferrous metals industry at European level, including mining,
metallurgy, processing and recycling of base metals, precious metals
and secondary metals.
4. Business Profile & Highlights 2024
10
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN participates in European Aluminium, an
initiative that focuses on the role of aluminium
(essential for the production of renewable
energy plants, electricity cables, electric
vehicles, hydrogen electrolysis and so on).
METLEN participates in COGEN Europe, an initiative that
aims at cogeneration, i.e. the production of low-carbon
electricity and heat in the most efficient and sustainable
way.
METLEN participates in the Hydrogen Europe
initiative, the aim of which is to harness
hydrogen, which plays an important role in
decarbonizing the economy, especially in terms of the
decarbonisation of heavy industry.
Since 2022, METLEN has participated in the
Athens Stock Exchange initiative for the disclosure
of sustainability information and its
communication with relevant stakeholders,
aiming to improve transparency and sustainable
entrepreneurship.
5. Annual Board of Directors Management Report
11
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The current “METLEN Energy & Metals S.A.” Board of Directors Annual Report relates to the 2024 fiscal period. It has been
prepared in accordance with the relevant provisions of Act 4548/2018, Act 5164/2024 (GGI Α202/12.12.2024), Act 3556/2007
(GGI 91Α/30.04.2007) and the executive decisions issued by the HCMC, in particular HCMC Board of Directors Decision No.
8/754/14.04.2019.
The report contains financial and non-financial information, as well as information necessary for understanding the impact on
issues relating to the solvency of “METLEN Energy & Metals S.A.” (hereinafter called the “Company”) and its subsidiaries and
associated companies (hereinafter called the ‘Group’ or “METLEN”, jointly with the company) for fiscal year 2024. It also describes
significant events that took place during this period and their impact on the annual consolidated report. Additionally, the report
describes the main risks and uncertainties that the Group's companies may face in the forthcoming year. Finally, it presents the
significant transactions between the Company and its related parties.
5. Annual Board of Directors Management Report
5. Annual Board of Directors Management Report
12
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
i. The table below shows an analysis of the Group operational result per sector as well as other items.
01.01-31.12.2024
01.01-31.12.2023
Turnover
5,683.0
5,491.7
Energy
4,571.7
4,425.5
Metallurgy
857.0
941.6
Infrastructure & Concessions
254.2
124.6
Other
0.0
0.0
EBITDA
1,080.1
1,013.6
Energy
753.3
766.5
Metallurgy
296.8
248.4
Infrastructure & Concessions
49.7
17.6
Other
(19.7)
(18.9)
(-) Depreciation / Amortization
(162.8)
(113.4)
(+ - ) Net Financials
(170.0)
(106.5)
(+) Share of profit of associates
1.1
(7.7)
(-) Tax
(117.6)
(160.4)
(-) Minoritiy Interest
(16.2)
(2.5)
Net Income attributable to parent Shareholders
614.6
623.1
ii. The table below shows an analysis in cash flow and changes in net debt in accordance with the statement of cash flow
of the financial statements (in statement of cash flow movements of restricted cash are not included):
(Amounts in million €)
01.01-31.12.2024
EBITDA
1,080
(-)
2023 Lead Items
(74)
(-)
Working Capital
(333)
Funds from operations
673
(-)
Tax
(123)
(-)
Interest
(135)
Operating Cash Flow
415
(-)
Maintenance Capex
(113)
(-)
Growth & Productivity Capex
(688)
Free Cash Flow
(386)
(-)
Other Financial / Investment Cash Flows
(255)
Net Debt Change
(640)
FULL YEAR 2024 REVIEW - PERFORMANCE AND FINANCIAL POSITION
5. Annual Board of Directors Management Report
13
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2.2. STRATEGIC PRIORITIES & BUSINESS MODEL [ESRS2: SBM-1]
STRATEGY
METLEN Energy & Metals is strategically positioned at the forefront of the energy transition as a leading and integrated
provider (utility), while establishing itself as a benchmark of competitive "green" metallurgy at European and global level. It
has a dynamic presence in all five continents, is listed on the Athens Stock Exchange, with a consolidated turnover of €5.7bn
1
.
[ESRS2:SBM1-40_b] and with 7.627
2
direct and indirect employees in Greece and abroad [ESRS2:SBM1-40_a_iii]. The Group’s
main objective is the continuous and responsible development and improvement of competitiveness in all its activities, through
continuous reinvestment and synergies between them, to unlock value multipliers and ensure its viability and consistent returns
for its shareholders. At the same time, the Group’s dynamic business development is inextricably linked to the principles of
Corporate Responsibility and Sustainable Development. Its strategy in this field is expressed with the implementation / support
of important initiatives that contribute to the achievement of the UN Sustainable Development Goals and the corresponding
national priorities.
The Group’s main objectives can be summarized as follows:
a) Implementation of a modern functional and sustainable business model that further favours internal synergies, effective
decision making and effective internal communication.
b) Recognition of the Group’s true market capitalization and its further increase, while targeting the investment grade rating on
its debt.
c) Focus on the development of Human Resources, creating conditions for meritocracy-based advancement, with a clear value
proposition.
d) Further growth in activities presenting opportunities (e.g., Infrastructure & Concessions in Greece, new technologies, new
markets internationally).
METALS SECTOR
Year 2024
Αdditional data
Employees
3
1,662
Metals sector’s employees are employed in Greece and make
up 21.8% of the total number of employees.
Total Revenue
4
[ESRS2:SBM1-
40_b]
€857,042 thousand
The Sector’s revenue accounts for 15.1 % of the Group’s total
revenue.
Main products
1) Bauxite
2) Alumina (hydrated & anhydrous)
3) Aluminium (primary cast & secondary cast)
With its Metals Sector, METLEN holds a leading position in the metallurgy industry. It operates the only vertically integrated
bauxite, alumina and primary aluminium production plant in Europe, with privately owned port facilities and the largest
cogeneration unit and has made a dynamic entry into recycled aluminium and zinc lead recycling. The Sector’s international
business activity is a driving force for the national economy and for the development of the Greek periphery.
The "Aluminium of Greece" plant, after more than 55 years of operation and more than 20 years of continuous growth, with
large-scale investments for the technological modernization of its facilities and the development of its production and
productivity, is one of the major pillars of Greek industry and has been established as one of the industry’s strongest
1
As presented in the Annual Financial Statements of this Consolidated Report
2
The direct employees of the Group or the Group's Domestic Workforce
3
As detailed within the Workforce Concerned subsection of the Social Issues section of this Sustainability Statement
4
As presented in the Financial Information by Sector within the Notes to the Financial Statements of this IR.
BUSINESS MODEL
V.
5. Annual Board of Directors Management Report
14
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
representatives in the European Union, with an annual production capacity exceeding 180,000 tons of primary aluminium and
860,000 tons of alumina.
At the same time, through its subsidiary EPALME, which operates fully under the principles of circular economy, METLEN
continues to invest in the production of recycled (secondary cast) Aluminium, reaching a production capacity of 65,000 tons per
year with the prospect of more than doubling this in the coming years, significantly reducing total energy consumption per ton
produced, as well as carbon dioxide emissions.
Strategic priorities
1) Continuous improvement and dedication in Occupational Health & Safety.
2) Continuous improvement of productivity and efficiency of plant processes.
3) Cost control to remain in the best possible position on the global alumina and aluminium production cost curve.
4) Increase of the total quantity of aluminium produced with the production of secondary aluminium.
5) Reduction of total CO
2
emissions (scope 1 &2) by 65%, and of specific production emissions per ton of aluminium by 75%
by 2030, using 2019 as the base year.
6) Improvement of the environmental footprint with continuous investments, the development of relevant know-how and
innovative solutions.
7) Ensuring supply and flexibility in the sourcing of raw materials.
8) Search for and integration of digital technologies.
9) Providing optimal products and solutions to customers, not merely selling goods.
10) Maximizing on opportunities for expanding the Metals sector into new fields of activity.
11) Reinforcing vertical integration or expanding to strengthen the Metallurgy sector.
12) Increasing competitiveness through strategic investments and hedging methods.
Key Products, Customers and Markets Serviced [ESRS2:SBM1-40_a_i]
a) Alumina
METLEN's Metals sector markets two grades of alumina products: anhydrous (calcinated) alumina and hydrated alumina.
Anhydrous alumina makes up about 55% of total alumina sales. The product is mainly used in the production of primary
aluminium. Most of anhydrous alumina is sold to aluminium producing customers through agreements with traders. Also, a
smaller amount of anhydrous alumina is sold for other uses (chemical industry, refractory materials, etc.). End customers are
located in different countries such as France, Germany, Romania, the Netherlands, Italy, and Slovenia. Hydrated alumina
accounts for approximately 42.1% of total alumina sales and is used by corporate customers operating in various industries
(aluminium fluoride production, plastics industry, chemical industry, paint and coatings industry, paper industry, etc.) who take
advantage of the properties of hydrated alumina, such as flame retardancy, coagulation properties and chemical stability, to
improve performance and safety of their products. Customers are mainly located in the Mediterranean region (Italy, France,
Spain, Turkey and North Africa) as well as in Northern Europe (Germany, Sweden, Finland). The Group maintains long-term
business relationships, lasting more than 10 years, with most of its customers for both products. [ESRS2:SBM1-40_a_ii]
b) Aluminium
METLEN's Metals sector markets two main categories of aluminium products: billets and slabs. Aluminium billets are used by
extrusion companies as raw material, converting them, through further processing, into shaped products such as: pipes, rods,
ducts and other special products used in various applications. Aluminium slabs are used by rolling companies where slabs are
compressed into thinner and larger surface products in the form of sheets, strips and other flat aluminium products used in a
variety of applications. The Group has approximately 30-35 customers, mostly manufacturing companies, but it also sells to
dealers. The Group maintains long-term relationships of more than 10 years with most of its aluminium customers. The
geographical breakdown of aluminium sales is as follows, without significant differences compared to the previous year.
Year
Type of product
2024
2023
Aluminium billets
162,363 tons
159,469 tons
Aluminium slabs
75,559 tons
79,770 tons
[ESRS2:SBM1-40_a_ii]
5. Annual Board of Directors Management Report
15
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Major markets for Aluminium finished products [ESRS2:SBM1-40_a_ii]
Aluminium production serves various markets and industries due to the unique properties of the material, such as low weight,
high strength, corrosion resistance and recyclability. The main markets served are:
1. The automotive industry is one of the largest markets for aluminium which is used extensively in the manufacture of
lightweight and durable automotive components such as bodies, engines and wheels, helping to replace heavy materials and
save carbon emissions.
2. The construction industry absorbs significant amounts of aluminium in the construction of buildings, infrastructure and other
construction projects. The extensive use of aluminium in construction makes buildings energy efficient, and the strength to
weight ratio makes it possible to implement designs with excellent stability and modern architecture.
3. The packaging industry uses aluminium to manufacture packaging that contributes to the efficient production, storage,
distribution and use of products that require high protection and shelf life. In this industry it is very important that aluminium
is an ideal material for recycling. It is easy to separate among other recyclable materials, its sorting has a low cost, while there
is no limitation on how many times it can be recycled, always maintaining the quality of the raw material.
4. Electronic and electrical products where aluminium is widely used in the manufacture of mobile phones, computers, cables,
and components. Aluminium plays a significant role in this market, offering unique advantages such as high conductivity,
durability, and efficient heat management. The use of aluminium in cases, boards and battery components improves the
performance, safety and durability of electronics and electrical products, making aluminium an indispensable material for
innovation and development in the field of technology.
5. The Renewable Energy Sources market where aluminium is used in applications related to the production and storage of
renewable energy, such as solar panels and other energy solutions.
6. The pharmaceutical industry where aluminium is used in specialized packaging of pharmaceutical and medical products. The
use of aluminium in pharmaceutical packaging, containers, industrial equipment, and medical devices ensures the effective
implementation of quality standards regarding the safety of pharmaceutical products, contributing to the improvement of
patient health and well-being.
7. The sporting goods industry where aluminium is a key material, offering unique advantages such as lightness, durability, and
ease of processing. The use of aluminium in bicycles, rackets, climbing gear, sports vehicles and protective equipment helps
improve performance, safety and ease of use, making it essential for growth and innovation in the sports industry.
8. The aerospace industry where aluminium is used in the manufacture of aircraft components, such as wings, fuselages, and
engine components, improving aircraft efficiency and safety, and supporting the development of aeronautical technology.
ENERGY SECTOR
Year 2024
Additional elements
Employees
5
2,435
Energy sector’s employees represent 31.9% of the total number
of employees. Of these, 59.7% are employed in Greece, while
the remaining 40.3% are employed internationally.
Total Revenue
[ESRS2:SBM1-
40_b]
€4,571,735 thousand
The sector’s revenue accounts for 80.4% of the Group’s total
revenue.
Main
Services/
Products
1. Construction and sale of solar and energy storage projects.
2. Production and sale of primary energy.
3. Supply/Sale of electricity and natural gas and retail services to household, commercial, and industrial
consumers.
4. Construction and sale of energy transition projects and conventional power generation projects.
5. Supply/Trading and management of natural gas and other energy products.
5
As detailed within the Workforce Concerned subsection of the Social Issues section of this Sustainability Statement
5. Annual Board of Directors Management Report
16
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN, through its Energy Sector, stands as the largest private Group covering the full spectrum of energy as an integrated
energy utility. The Group operates in the development, construction and operation of thermal plants and Renewable Energy
Sources (RES) projects, the design and construction of electricity infrastructure, as well as the supply of electricity and natural
gas to the retail market. In addition, it is active in the trading of natural gas and the provision of competitive energy services, such
as energy efficiency, upgrading, smart city services and hydrogen infrastructure.
With Protergia, METLEN supplies electricity and natural gas to the retail market, offering reliable solutions and competitive
products to businesses, professionals, and households alike. In addition, it provides modern services such as energy efficiency,
smart cities, electromobility (installation, operation and maintenance of electric car charging stations), facility management and
Internet of Things (IoT) services.
The Group is the largest independent electricity producer and supplier in Greece, with significant investments in state of the art
plants and environmentally friendly solutions, contributing to the Greek economy and to employment. With an energy portfolio
of more than 2 GW, METLEN manages a significant part of the country's installed capacity from thermal plants and RES, also
offering bidding services in the Energy market (market bidding), non-physical power trading and management of Bilateral Power
Purchase Agreements (PPAs). The Group is also active in the supply and management of natural gas and other energy products,
offering innovative products and services to B2B customers in Greece and abroad, while it is a global manufacturer and contractor
of solar energy and energy storage projects, offering integrated solutions from standalone projects to hybrid systems. With strong
know-how and international presence, it designs and implements high quality projects while having a portfolio of 11.1GW of
renewable energy projects in Greece and abroad.
In addition, METLEN undertakes the construction of specialized large-scale energy projects, including conventional power
generation projects, energy transition projects (such as distribution grids and hydrogen), energy saving projects, digital transition,
(smart cities and IoT platforms), providing all the necessary services for the successful completion of the projects.
In summary, the structure of the Energy Sector has five segments: M Renewables for the management of the Group's total RES
portfolio, M Power Projects for conventional power generation projects, energy transition projects, etc., M Energy Generation
& Management for the management of production and energy units, M Energy Customer Solutions concerning the retail supply
of energy and natural gas as well as new retail products and services, and M Integrated Supply & Trading which operates in the
natural gas wholesale market (including the sale of natural gas to other suppliers, import and export activities of natural gas as
well as securing the gas needs of M Energy Customer Solutions, as well as the energy centres and the Aluminium plant). For
2024, total revenue from these activities amounted to €962.570 thousand
6
, (while revenue aligned with the European taxonomy
from related activities amounts to €1.175.926 thousand
7
) which contributes to strengthening the Group's financial position, while
advancing its energy strategy. [ESRS2:SBM1-40_d_i]
Strategic priorities
METLEN's Energy Sector, driven by the new opportunities emerging from increased competitiveness and dynamic developments
around energy, maximizes on the synergies between its segments and defines its strategic priorities based on five main Pillars:
1. Utility pillar: The largest vertically integrated private Group in the field of electricity and natural gas (utility) in Greece, with
presence as the leading private producer and supplier in the retail electricity market as well as a leader in natural gas imports
and trading. The Energy sector aims to further expand its market share in electricity and natural gas supply, increasing services
and products with a customer-centric approach as well as expanding power & gas trading in South-Eastern and Central
Europe.
2. Renewable Energy Sources (RES) pillar: A leader in the field of RES, implementing a vertically integrated model as an
integrated developer and EPC contractor with a global footprint. The development of RES projects is based on an Asset
rotation model as well as on the further implementation of a significant portfolio of RES projects, contributing substantially
to the efforts of the power generation segment to increase the installed capacity of renewable sources and gradually start
operating in electricity storage projects, which is an important factor towards the increasing growth of renewable energy
production. Emphasis is on strengthening relationships and strategic partnerships with major investors in Greece and abroad
in the RES sector. The strategy to increase the renewable energy portfolio supports the target of reducing specific carbon
dioxide (CO
2
) emissions per MWh of electricity generation by almost -50% by 2030, using 2019 as the base year.
6
Reference to financial data
7
Reference to EU TAXONOMY
5. Annual Board of Directors Management Report
17
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
3. Grid & Digital Solutions Pillar: Dynamic penetration in grid upgrade projects in Greece and abroad, both with Substations
projects, and with Interconnection and Transmission, distribution & grid projects, as well as Data Center construction projects.
4. New Technologies Pillar: Investigating the possibility of gradually entering the new developing markets of hydrogen
production (H2) and Carbon Dioxide Capture (CCUS), and maximizing the availability of the Group's thermal units, as well as
gradually integrating the possibilities offered by the progress of technological tools and especially with the development of
in-house customized IT tools for energy production and management.
5. Power Technologies pillar: Strengthening the Group's robust position in the EPC market for the construction of natural gas
power plants. The market has returned to the design and development of natural gas power plants, following the closure of
lignite-fired plants, to support increased electricity demand needs. The Energy sector with its experience in natural gas power
plants EPC projects aims to acquire a significant share of this market, with balanced expansion into new geographical areas
presenting significant growth prospects and enhancing its presence in countries where it currently operates.
Key Products, Customers and Markets Served [ESRS2:SBM1-40_a_i]
1. Construction of solar and energy storage projects: The M Renewables segment of METLEN's Energy sector has experience in
complex, large-scale solar and energy storage projects with presence and executed projects in many geographical areas across
all five continents. It provides integrated construction services for photovoltaic projects ranging from detailed design by its
own design department to construction with proven equipment from first-class manufacturers and long-term maintenance
services. It also provides industrial-scale battery energy storage (BESS) solutions, both in standalone energy storage projects
and as a combined service in photovoltaic and hybrid projects. Energy storage systems are generally supplied in a modular
design, with a scalable design and the ability to deliver multi-MW power systems. Global activity and strong partnerships
make METLEN's M Renewables a dependable long-term partner for leading investors in the renewable energy industry around
the world.
2. Energy Production and Management: With the Energy sector’s M Energy Generation & Management segment, METLEN
stands as the largest independent electricity producer in Greece, with private investments in state-of-the-art plants. For the
primary energy production, the Group uses Natural Gas-fired thermal units with a capacity of more than 2 GW, operated and
maintained by the Group itself using its own staff. It also has a strong Energy Management function to manage the energy
produced by its thermal plants and is equally active in international cross-border electricity trading, while managing the
energy portfolio intended to meet the needs of the retail electricity market, as well as the portfolio of energy intended to
meet the needs of the Metallurgy sector’s alumina and aluminium plant, i.e. the largest –by quite a margin from the second
– domestic electricity consumer with particularly demanding electrical characteristics. In addition, through the Aggregator
(FOSE) of Renewable Energy Sources (RES) / Storage projects, it manages the energy produced/absorbed both by its own RES
/ Storage projects and by third-party RES / Storage projects. In addition, it is active in the field of guarantees of origin (GOs),
and in demand-response through the Demand Response Aggregator.
3. Electricity Supply: With Protergia, the Energy sector’s M Energy Customer Solutions segment operates in the supply of
electricity and natural gas to the retail market, focused on offering reliable solutions, competitive products and modern
services to businesses, professionals and households, now also including services such as energy efficiency, smart cities,
electromobility, facilities management, Internet of Things /digital services, as well as programs for the installation of solar
energy production systems to individuals (Helios Value) and smart meters for measuring consumption and mapping the
energy profiles of individuals, in the context of New Energy Products (New Energy Products department), meeting the needs
of its customers.
4. Supply/Trading and management of natural gas and other energy products: The scope of the Energy sector’s M Integrated
Supply & Trading segment is (a) the supply and management of natural gas and other energy products, and (b) the interaction
with large corporate customers (B2B) in Greece and abroad (customer facing) and the provision of innovative products and
services.
5. Construction of conventional power generation projects, energy transition projects: The Energy sector’s M Power Projects
segment positions METLEN as the leading international contractor in the construction of specialized, large-scale, and value-
added energy projects, undertaking the full range of services required for the successful execution of any project, whether
conventional power generation projects, energy transition projects (e.g., grids, hydrogen, etc.), or electricity saving, digital
transition projects.
Overall, the Energy Sector serves quite a broad customer base having a variety of needs and requirements. From large commercial
and industrial customers to public organizations, as well as professional and residential customers, it covers the entire spectrum
of demand for Electricity and Natural Gas in Greece. Accordingly, given the Sector’s activity abroad, its customer base includes
Power Generation-Distribution companies, Institutional Investors, Industries and Private Investors interested in solar energy and
energy storage projects, from standalone projects to complex hybrid systems, as well as in the construction of specialized, large-
5. Annual Board of Directors Management Report
18
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
scale energy projects, whether they are conventional power generation and energy transition projects, or electricity saving and
digital transition projects. [ESRS2:SBM1-40_a_ii]
SUSTAINABLE DEVELOPMENT
Sustainability Management
Sustainable Development is part of METLEN's long-term business strategy, but also the driving force through which it aspires to
remain competitive over time, to address modern challenges (climate change, loss of biodiversity, social inequalities, etc.) and
at the same time maximize on opportunities arising from the energy transition, contributing to a new efficient and socially
inclusive growth model as reflected through the Global Sustainable Development Goals.
Over the years, METLEN has developed a systematic approach to managing Sustainable Development that aims to identify the
most prominent issues related to its activity and the underlying challenges, as well as to further integrate sustainability into its
operations. The following table shows the key elements of this approach.
Key stages of Sustainable Development management
Sustainable Development Strategy
METLEN's Sustainability Strategy aims to create long-term and sustainable value for its shareholders and other stakeholder
groups, through a comprehensive approach that combines financial stability with social and environmental sustainability. It is
implemented on three main levels, inextricably linked to each other, and is governed by specific Principles that ensure
completeness (Materiality Principle), quality (Stakeholder Inclusiveness Principle) and transparency (Accountability Principle)
across the entire spectrum of its activity.
5. Annual Board of Directors Management Report
19
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Level 1 expresses METLEN's commitment to tackling climate change and contributing to a low-carbon economy. The Group,
considering the high CO₂ intensity of its production processes, has highlighted the adaptation of its activities to the consequences
of climate change and the implementation of initiatives to address it, as a key element for its sustainable and responsible
development. To this end, it pursues a topical strategy to tackle climate change that guides its initiatives for carbon dioxide
emissions reduction as defined by the Kyoto Protocol, the Paris Agreement on climate change and the corresponding National
Plan of Greece, which determines its contribution to the (EU Green Deal).
Strategic priorities:
a) Further adaptation of its activities to the effects of climate change by analysing associated risks and leveraging relevant
opportunities.
b) Implementation, control and review of CO
2
emission reduction initiatives and the Group's climate goals and
commitments.
c) Integration of climate objectives into strategic planning and decision-making processes.
d) Implementation of a Renewable Energy Sources investment plan of >2.5GW by 2030.
e) Development of strategic partnerships to apply innovative technologies in the production activity, with the aim of
reducing CO
2
emissions intensity.
f) Further development of business activities in specialized energy projects and Renewable Energy Sources and Storage
projects.
Level 2 focuses on METLEN's systematic approach to recording, optimally managing, and disclosing ESG risks and opportunities
that may affect its performance as well as its effort to implement its strategy. Through its ESG approach, METLEN enhances its
ability to create long-term value and manage significant changes in the environment in which it operates. This way It meets both
the modern sustainability requirements of investors, capital markets and financial institutions, as well as society's expectations
for commitment and transparency on these issues.
Strategic priorities:
a) Determining material ESG issues and linking them to the Group's financial performance
b) Identification and optimal management of ESG risks and opportunities to create long-term value
c) Enhancing trust and facilitating the flow of information between the Group and investors
d) Responsible ESG data disclosure in accordance with international standards
e) Continuous improvement/maintenance of ESG performance
f) Integration of ESG criteria into investment decisions and key operational processes of the Group
Corporate
Responsibility
� The Natural
Environment
� To our People
� The wider
Society
� The Markets
we operate
We act responsibly towards:
ΕSG
Approach
� The management and
exploitation of ESG risks and
opportunities respectively .
� Continuously improving our
already advanced ESG
performance and publications .
� The full integration of ESG criteria
into our core operations and
investment decisions .
We enhance the valuation of our corporate value through:
Climate
Change
� Targets and initiatives to reduce
our carbon footprint by 2030 .
� Commitment to net zero
emissions by 2050.
We participate substantially in tackling climate change and in the national effort to transition to a low-carbon
economy by:
Strategic Framework for Sustainable Development
� Business activities in energy
transition and sustainable
development projects.
“We create and distribute sustainable value toour shareholders and the rest groups
of our stakeholders, pursuing our business and economic growth alongside our
commitment to the Global Sustainable Development Goals."
Principle of Materiality:
Material issues that have significant economic,
environmental and social impacts and influence the
decisions of our Social Partners, lay the foundations for
the implementation of our strategy for Sustainable
Development.
Principle of Stakeholder Inclusiveness:
Through an open and systematic consultation process,
we seek to build relationships of trust and cooperation
with our Social Partners, in order to jointly contribute
to Sustainable Development.
Principle of Accountability:
We implement our commitment to
transparency and regular information of all
our Social Partners, publishing annually, and
for more than 16 years, our performance and
strategy in Sustainable Development.
5. Annual Board of Directors Management Report
20
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The 3rd level focuses on the responsible operation of METLEN, which has been systematically fostered since 2008, with the
implementation of Responsible Entrepreneurship and the Group's commitment to the 10 Principles of the UN Global Compact.
Responsible Entrepreneurship for METLEN is a continuous process of self-improvement and continuous learning and also acts as
a key mechanism for renewing its "social" license to operate, while contributing to the improvement of its competitiveness at
national and international level.
Strategic priorities:
a) The firm commitment to its aim of ensuring a healthy and safe working environment without accidents, pivoting around
prevention
b) Continuous mitigation of environmental impacts
c) Developing, managing and retaining a dedicated workforce, with practices that promote an inclusive working
environment, promoting equal opportunities and respecting Human Rights
d) Continuing its operation with a sense of responsibility and consistency towards its people, remaining their first choice
throughout their professional career, while investing in education and the development of their skills
e) Implementation of high social value actions with the promotion of employee volunteerism
f) Systematic and honest dialogue with the main Stakeholder groups, seeking to maintain mutual trust and a fuller
understanding by the Group of the implications of its operation
g) Contribution to the development of local infrastructure and overall, to the prosperity and respect of the rights of
citizens of local communities adjacent to the Group's industrial plants
h) Developing responsible procurement/purchasing by expanding the commitment of the Group's key suppliers and
partners to sustainable development
i) Emphasis on the quality and safety standards of the Group's products as well as on the continuous support, service,
and satisfaction of customers
Alignment with the Global Sustainable Development Goals
Since 2016, METLEN has been steadily contributing to the achievement of 40 targets of the Global Sustainable Development
Goals, focusing on 6 key directions as presented below:
1. Tackling Climate Change (SDGs: 7 & 13)
METLEN's activity is linked to Goals 7 (affordable and clean energy) and 13 (climate action). The Group continues its dynamic
penetration into an extensive range of projects that contribute substantially to the implementation of the energy transition,
internationally, while implementing specific initiatives to reduce its total CO
2e
emissions (Scopes 1 & 2) in the context of
achieving its climate Goals and Commitments.
2. Support to Innovation and Sustainable Industrialization (SDGs: 9 & 12)
As one of the leading industrial and energy companies, METLEN invests in circular economy, the development of innovative
waste recovery methods, the application of "clean" industrial methods. At the same time, it invests in specialized research
programs and studies for the management of bauxite residues, creating a source of value, developing new processes for their
sustainable use, in the context of actions for circular economy. Focusing on research on the use of Bauxite residues and the
recovery of rare-earth elements such as scandium, has developed a strong Research and Development (R&D) culture. At the
same time, it steadily enhances employability in the domestic industrial sector and creates the conditions for a responsible
supply chain across its business activity. This way, it actively contributes, mutatis mutandis, to Goals 9 (industry & innovation)
and 12 (responsible consumption and production).
3. Promoting secure and productive employment (SDGs: 3 & 8)
The Group, in the context of its contribution to Goals 3 (good health and well-being) and 8 (Decent work and economic
growth), promotes and ensures safe working conditions for its direct and indirect employees focusing on prevention. Almost
all its production units have occupational Health & Safety management systems certified by independent bodies (ISO 45001:
2018). METLEN, along with its economic growth, continues to integrate policies & practices to enhance full and productive
employment, with the creation of decent jobs for all.
4. Promoting the reduction of inequalities (SDGs: 5 & 10)
METLEN, as it grows, promotes policies and practices in its work environment that enhance respect for Human Rights,
diversity, inclusion, and equal opportunities, placing emphasis on gender equality. In this context, it promotes the
participation of women at all levels on the corporate ladder, the inclusion of young employees <30 years old in its workforce
5. Annual Board of Directors Management Report
21
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
as well as its effort to integrate people with disabilities into the labour market, while investing in creating an inclusive and
supportive workplace for all, directly contributing to Goals 5 (gender equality) and 10 (fewer inequalities).
5. Commitment to protecting the natural environment (SDGs: 6, 14 & 15)
As part of the Group's commitment to further reduce its environmental footprint, Best International Techniques are applied
for the proper management and reduction of environmental impacts per Business Unit and subsidiary. Where required,
investments are made to upgrade the production process, utilizing, to the extent possible, new technologies, while almost all
the Group’s production units have environmental management systems certified according to ISO 14001:2015, the most
modern international standards, and apply environmental rehabilitation plans for exploitable areas, where required, thus
contributing directly to Goals 6 (water management), 14 (life at sea) and 15 (life on land).
6. Consistency in social responsibility (SDGs: 1, 2, 3, 4 & 11)
METLEN contributes indirectly to the other Global Goals by consistently applying its social policy with actions and initiatives
that enhance the harmony of coexistence with its local communities and society at large. Aiming at reaching 550,000
beneficiaries of our social policy for the five-year period 2020-2025, we continue to invest in the development of local
employment and economy by creating jobs (Goal 1) and strengthening local suppliers and infrastructure (Goal 11), reducing
food insecurity of vulnerable social groups (Goal 2), implementing training programmes in new technologies in schools, as
well as programmes to develop the professional skills of the younger generation (Goal 4).
Key Sustainable Development Goals for the next 3-5 years [ESRS2:SBM1-40_e]
METLEN, as a responsible business, aims to operate efficiently in both current and future conditions. Well-functioning and
continuously improving its collaborative and diversified business model is a key priority to make it even more resilient amid the
global energy transition effort. In this context, METLEN continues to implement its Sustainable Development strategy, with its
key goals and commitments for the next 3-5 years being:
1) The implementation of the emissions reduction plan, which has been developed as part of its commitment to achieving a
net-zero carbon footprint for its relevant activities by 2050. Thus, contributing to limiting the rise in the average global
temperature to well below 2°C compared to pre-industrial levels;
2) To ensure a healthy and safe working environment free from fatal and serious accidents, maintaining or even further
improving the already very low levels of incidence indicators of less serious accidents, on an annual basis, focusing on
prevention;
3) The implementation of the strategic human resources development plan focusing on corporate culture, equality, inclusion,
skills development;
4) Increasing the production of recycled aluminium to >100,000 tons to reduce raw material and energy consumption;
5) The development of the environmental and human rights due diligence framework, covering most of its value chain;
6) Further reducing its environmental footprint by effectively managing and limiting potential environmental impacts, in
terms of water and energy use, protection of local biodiversity, and waste management;
7) The development of responsible key partners and suppliers based on the principles of Sustainable Development and
Responsible Entrepreneurship;
8) The consistent implementation of its social policy with actions and initiatives that enhance the harmony of coexistence
with its local communities and society at large.
At the same time, evaluation of the Group's products, markets and customers is a continuous cycle of improvement, which is
linked either directly or indirectly to the above goals. Indicatively, Life Cycle Assessment (LCA) studies are conducted in Metallurgy
to assess the potential environmental impacts associated with bauxite mining and alumina and aluminium production. This is a
process of evaluating the impact of a product on the environment, throughout its lifetime (cradle-to-grave), thus increasing
resource efficiency. The LCA study shows the stages in the life cycle that cause the greatest impact on the environment and the
predominant type of impact. The studies are conducted in accordance with the principles of ISO 14040 and ISO 14044, with the
aim of providing all data required in the context of certification with the Performance Standard of the Aluminium Stewardship
Initiative (ASI).
Based on the results, processes that prove to be environmentally damaging and inconsistent with the Group's objectives are
improved with innovative technologies or, if possible, replaced by more sustainable alternative practices. METLEN also focuses
on markets that recognize the importance of sustainability and support the transition to a greener economy. The Group evaluates
these markets based on demand for sustainable products and regulatory frameworks conducive to sustainable development. The
same goes for customers who prioritize sustainability. The Group assesses the needs and expectations of these customers,
5. Annual Board of Directors Management Report
22
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
offering them solutions that meet sustainability standards, thus supporting the reduction of their environmental footprint. [ESRS:
SBM1-40_f]
Aligning business strategy with Sustainable Development issues [ESRS: SBM1-40_g]
In this new era, METLEN has designed and implemented a business strategy based on its collaborative business model ensuring
strong performances, creating vertical integration, cost savings, hedging the risks of its individual activities while being governed
by the principles of Sustainable Development. The Group's business choices, especially in recent years and culminating in its
recent transformation, are the greatest proof of its commitment to creating a new era with activities having a strong positive
economic, social and environmental footprint.
Specifically in Energy, METLEN is now a global manufacturer and contractor of solar energy and energy storage projects. With
the construction and operation of RES projects, as well as with the large battery energy storage solutions projects, it makes a
significant contribution to the energy mix of both Greece and other countries working to address climate change. At the same
time, by supplying electricity and natural gas to the retail market, it serves more than 550,000 customers.
At the same time, it develops advanced customer-centric services, with unlimited beneficial potential for consumers, elements
critical for the transition to a low-carbon economy and the creation of a relevant culture. The Group's energy infrastructure
development with the development of the Electromobility activity, aiming at the future reduction of the use of conventional fuels
(Design, Installation and Operation, Support, Maintenance, Management, Provision of Integrated Solutions in the Field of
Infrastructure and Electric Vehicle Charging Network, Electromobility Services and Recharging of Electric Vehicles), and the
construction of large-scale turnkey conventional energy projects and penetration of grid upgrade projects in Greece and abroad,
such as the construction of the first high-power undersea interconnector in the UK designed to harness Scotland's huge
renewable energy potential and deliver clean energy to households and other consumers. This project plays a key role in the
electricity value chain, which is essential for the smooth functioning of society and has indirect benefits through greenhouse gas
mitigation objectives and thus climate change mitigation. In addition, the use of natural gas by the Group in electricity production,
through imports and trading, or even the development of natural gas power plants to support the increased needs of electricity
demand, ensures the stable energy supply to the grids, when renewable sources are not available, as well as domestic and
European energy security. Note that natural gas was officially recognized as a transitional fuel, following the conclusions of COP28
in the United Arab Emirates.
In Metallurgy, METLEN's activity in the production of recycled aluminium is at the heart of circular economy. It is associated with
the use of much less energy and, consequently, much fewer greenhouse gas emissions, which contributes positively to mitigating
both global warming and climate change and the need for bauxite, which is a key natural resource. Furthermore, primary
aluminium production, although it is a highly energy-intensive process, creates significant value thanks to the material’s
recyclability and durability, and to its contribution to energy-efficient applications, reasons expected to lead to a significant
increase in its demand in the coming years. This activity is aligned with key Global Sustainable Development Goals, significantly
enhancing employment in the domestic industrial sector, thus contributing substantially to the local and national economy.
At the same time, our Group's strategy for Sustainable Development incorporates policies that are considered vital for its long-
term success and competitiveness at all levels, such as:
a) On a financial level, the Group's policies contribute to operational efficiency and cost savings. Examples include the
adoption of energy-saving measures and the reduction of carbon emissions leading to significant savings in the medium and long
term.
b) On a social level, corporate policies improve relations with stakeholder groups by attracting and retaining qualified
talented employees and maintaining social acceptance of the Group's operation by local communities.
c) On an environmental level, the Group applies policies mitigating its environmental footprint, reducing the risk of natural
resources pollution, and consequently the risk of relevant regulatory sanctions. This not only protects the Group from potential
future liabilities, but also enhances its reputation among customers and consumers, who are increasingly aware of the
environmental impact of their purchases.
5. Annual Board of Directors Management Report
23
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
BUSINESS MODEL [ESRS2:SBM1-42_a] [ESRS2:SBM1-42_b]
METLEN's business model transforms the available resources used by the Group (inputs), through its Business Sectors and their
synergies, into integrated projects, competitive products, modern services, digital solutions, etc. which it produces, disposes of
and manages with positive or negative effects (outputs), with the aim of fulfilling its strategic goals and creating short-term,
medium and long-term value for itself, its shareholders, employees, customers, the natural environment and society at large.
Below follows a presentation of the Group's business model, including a description of the categories of resources used, how
these are secured or developed, as well as their results (enhanced or reduced generated value) during the reporting period.
Economic Value Table
Thousand.€
2024
2023
2022
Value Generated
Turnover
5,682,956
5,491,685
6,306,472
Value Distributed
Cost of goods sold and administrative/selling expenses
8
4,869,378
4,427,238
5,252,977
Pension benefits and other employee benefits
247,483
195,106
324,785
Income taxes and other taxes
122,579
139,170
42,884
Payments to capital providers
9
355,541
256,749
110,392
Social Investments
7,126
3,282
3,900
Total (€)
5,602,107
5,021,545
5,734,938
% Economic value distributed
98.6%
91.4%
95.0%
% Economic value retained
1.4%
8.6%
5.0%
8
Cost of costs sold plus administrative/disposal expenses, excluding retirement and other employee benefits, taxes and fees, and community-based
investments, incorporated in this amount.
9
This includes interest paid, dividends paid and leasing principal payments.
5. Annual Board of Directors Management Report
25
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Financial Capital
The Group's business activities require financial resources drawn from: equity, revenue from sales of products and services,
profits reinvested in the Group to support its further growth, funds from government grants, EU programs and other sources of
financing, long-term and short-term loans from banks and other financial institutions, lines of credit to meet liquidity needs,
available cash to meet direct operating needs. METLEN efficiently manages its financial resources supporting its domestic and
international growth by:
a) Developing partnerships founded on mutual trust with banks, investment houses and other financial institutions to
secure financing.
b) Applying practices of attracting capital from international markets and EU programs.
c) Strategically managing capital to maintain financial stability and support innovative projects.
d) Developing new products and services that increase revenue and expand its customer base.
e) Investing in activities that enhance its profitability and financial stability.
f) Applying strict risk management procedures to protect the Group's financial resources.
g) Ensuring transparency and integrity in its financial transactions through internal and external audits.
Industrial capital
The industrial plants related to the production of aluminium and energy, the RES units in operation as well as the construction
sites in Greece and abroad, together with its supply chain, allow METLEN to offer its products and services meeting the needs of
customers and consumers. By effectively managing its industrial capital, the Group achieves efficient operation of its units and
production of high quality industrial and energy products. The Group manages its industrial capital by:
a) Developing and maintaining partnerships with industrial equipment and technology suppliers, ensuring the provision of
advanced and reliable solutions.
b) Investing in the continuous improvement of its industrial infrastructure, the development of new production
technologies and the implementation of best practices.
c) Implementing rigorous maintenance and control measures to preserve the efficiency and safety of industrial equipment.
d) Implementing international standards, such as ISO 9001 and ISO 45001, to ensure quality and safety in the production
processes.
Human Capital
The Group's direct and indirect employees offer their knowledge, talent and skills across the range of its activities, from enhancing
efficiency and developing innovation in production activity, to maintaining relationships of mutual trust and cooperation with
local communities and customers. METLEN strengthens and retains its human capital by:
a) Attracting talented and skilled employees through competitive hiring processes and dedicated talent programs.
b) Developing synergies with universities and educational institutions to find talented employees through internship
programs and partnerships.
c) Providing continuous training and skills development to ensure that its staff is always up to date with the latest
developments in its fields of activity.
d) Offering competitive remuneration packages and incentives to attract and retain employees.
e) Giving opportunities for professional development and advancement, enhancing employee engagement and
satisfaction.
f) Continuously evaluating and improving the working environment, based on feedback from employees.
g) Implementing central policy and practices to ensure the health and safety of its people.
h) Continuously striving to create a positive, supportive and safe working environment by promoting inclusion and equal
opportunities, creating a culture of equality and respect.
Natural Capital
Bauxite, natural gas, water, air and land use are the key natural resources the Group uses to perform its activities. Natural capital
is a key element of the Group's business model, enabling the long-term sustainability of its activities and the production of
sustainable products and services such as: recycled aluminium, clean energy, construction of RES projects and energy transition.
METLEN's commitment to environmentally responsible practices ensures the sustainable management of natural capital, while
contributing to the social acceptance of its activity:
a) Application of a responsible sourcing and purchasing policy and practices - Long-term contracts and strategic
partnerships with suppliers that follow responsible practices and adhere to environmental management standards.
BUSINESS MODEL
VI.
5. Annual Board of Directors Management Report
26
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
b) Participation in European research programs for the development of environmentally friendly technologies and
innovative solutions that reduce the consumption of natural resources.
c) Continuous stabilization/reduction of impacts on the natural environment through business investments that leverage
technological developments, staff training, the development of Best Available Techniques and the establishment of
annual environmental targets.
d) Implementation of environmental protection and industrial risk control practices/procedures, with a structured system
of Environmental Management practices and ISO 14001- certified methods.
e) Implementation of responsible water pumping and discharge practices and systematic rehabilitation of exploitable
areas from mining activity.
f) Compliance with international standards and regulations and cooperation with global ESG performance rating
agencies, ensuring that the Group's practices confirm its commitment to the protection of the natural environment
and sustainable development.
g) Investments in renewable energy sources, as an important part of the Group's energy portfolio, to produce clean and
sustainable energy.
Intangible Capital
Our intangible assets include a range of topics from research & development of new products, utilization of bauxite residues,
recovery of rare-earth elements such as scandium, energy efficiency, know-how in optimal processing of aluminium scrap,
patents and intellectual property rights for various technologies and processes, to excellent skills, and high know-how that allow
the Group to implement complex and demanding construction projects, based on the most stringent technological standards. In
this context, METLEN:
a) Invests in the acquisition of innovative technologies and intellectual property rights.
b) Enhances innovation and technological progress by systematically investing in research and development.
c) Develops and maintains strategic partnerships with other companies, research institutions and organizations, enhancing
networking and sharing of knowledge and technologies.
d) Protects patents and intellectual property rights using legal means.
Social Capital
Social resources, as a key input to METLEN's business model, include the social acceptance of its activity, its reputation, the
transparency of its practices, its social investments, the trust of its local communities, customers, suppliers, regulators and other
stakeholder groups. Proper management and development of its social capital is a key element for the operation of METLEN's
business model and to this end the Group:
a) Develops strong relationships with customers through quality products, services, and customer service. A key
objective is the development of new, innovative energy services that meet the ever-evolving needs of our
customers.
b) Implements open communication and cooperation between all stakeholder groups to improve relations and
further foster trust.
c) Invests in corporate responsibility, by implementing social programs, enhancing quality education, access to
health services, mitigating inequalities and environmental protection, taking actions that contribute to the
development of social capital, and creating positive relationships with local communities.
d) Boosts local economies by creating new jobs, supporting local projects and collaborating with local suppliers.
e) Implements a policy and practices of incorporating responsible practices in the operation of its key suppliers.
f) Cooperates with civil society organizations at both central and local level. These partnerships provide the Group
with valuable knowledge and experience, helping to understand local needs and challenges, while allowing it to
effectively design and implement its social policy. At the same time, these organizations function as a bridge of
communication between the Group and local communities, enhancing mutual trust and open communication.
g) Implements transparent and ethical practices in all its business activities, with continuous monitoring and
evaluation of the performance and effectiveness of its policies, ensuring the achievement of corporate goals.
5. Annual Board of Directors Management Report
27
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The digital application METLEN Integration Value Creation Scorecard shows all interactions between the capital
categories (inputs) that the Group uses to achieve its business goals and how they contribute to value creation.
5. Annual Board of Directors Management Report
28
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2.3. Value chain [ESRS2: SBM-1]
METLEN, having multi-annual presence and a strong position in the market, operates in two main areas: Energy
and Metals. The company's value chain in these two areas is the backbone of its activities, defining how it creates
value and generates competitive advantage. METLEN applies specific processes and strategies in each of the two
areas enabling it to effectively manage its resources, develop innovative products and offer high quality services
to its customers.
METALS SECTOR [ESRS2:SBM1-42_c]
The value chain of the Metals Sector includes all phases from extraction to finished products, ensuring high quality
and environmental responsibility standards.
1. Supply of raw materials
- Natural gas & electricity supply
- Purchase of bauxite, caustic soda, anodes and other raw materials
- Supply and sorting of aluminium scrap from various sources
- Supply of materials - Contracting suppliers - Acquisition of equipment
2. Transportation of raw materials
- Transportation of bauxite from mines and suppliers to the alumina production plant
- Delivery of other necessary raw materials
- Transportation of aluminium scrap to the aluminium production plant
3. Bauxite Mining
- Research for new deposits and extraction of Bauxite
4. Production process
- Bauxite processing for the production of hydrated and anhydrous alumina
- Steam production at the Cogeneration Plant used in the alumina production plant
- Electrolytic reduction of alumina to molten aluminium
- Mixing of molten aluminium with other metals to create different alloys adapted to specific
requirements-specifications
- Production of primary aluminium
- Production of secondary cast aluminium using aluminium scrap, which is recycled into new products
5. Marketing
- Identify customer needs, manage orders, and prepare product shipments
- Promotion of aluminium and alumina products in different markets and industries
6. Product Packaging & Distribution
- Operation of privately owned port facilities with direct access to maritime transport
- Product packaging for easy handling and protection during transport
- Logistics management for distribution of aluminium & alumina products to customers
7. Customer service
- Support services to ensure customer satisfaction and retention
8. Recycling
- Collection of aluminium scrap from production processes or post-consumer products
- Separating aluminium from other materials and preparing it for recycling
- Melting aluminium scrap for casting into new forms, completing the recycling process
9. Research & Development
- Collaboration with third parties for exploitation of bauxite residues and other technologies
VALUE CHAIN (ENERGY & METALS)
VII.
Upstream
Own Operations
Downstream
5. Annual Board of Directors Management Report
29
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN holds a central position in the Metallurgy Value Chain, from raw materials extraction to the production and distribution
of finished aluminium products. The company is active in all the stages of the value chain, thus ensuring high quality and
efficiency.
Relationship with key suppliers
METLEN fosters strategic and mutually beneficial relationships with its key suppliers, who play a critical role in the success and
efficiency of the Metallurgy Value Chain. These are relationships forged through cooperation, reliability and long-term
commitment, ensuring the continuous supply of high-quality raw materials and services. Eith regular communication and
exchanges, the Company ensures that its suppliers support its strategic priorities and contribute to the continuous improvement
of its processes and products. This approach enhances the Company's ability to provide high quality aluminium products to its
customers, maintaining its competitiveness and reaching high quality standards. For their part, suppliers are committed to
providing the Company with technical support, maintenance and equipment upgrades, thus ensuring the smooth operation of
its activities, and offer their support on safety and environmental management issues, helping the Company adhere to strict
quality and safety standards.
Relationship with permanent contractors
METLEN also maintains strategic relationships and long-term partnerships with permanent contractors who perform key tasks
contributing to the seamless operation of the Company's activities. These contractors are vital for the successful operation and
efficiency of the Metals Sector’s activities, as they provide specialised services meeting critical production process needs. The
relationship between METLEN and its permanent contractors is characterised by: a) close collaboration to develop and adapt
their services to the specific needs of the Metals Sector, ensuring that the final services they provide fully support the seamless
operation of the company; b) tight coordination of operations with METLEN’s production process to achieve optimal performance
and efficiency; c) the provision of technical support and training to contractors on the use of advanced technologies and the
improvement of work processes; d) ensuring contractors adhere to and comply with METLEN's strict safety and environmental
management standards; e) regular inspections and evaluations of contractors' performance to ensure continuous improvement
and compliance with METLEN's requirements; and (e) ensuring their immediate response in case of emergencies or breakdowns,
guaranteeing the uninterrupted operation of plants.
Relationship with key customers
The Metals Sector has developed and maintains strong relationships and collaborations with extrusion and rolling companies,
which are its key customers. These companies convert aluminium raw materials into specialised products with specific
specifications and high added value, used in various industrial applications. The relationship of the sector with these companies
is characterised by: a) ensuring the stable and reliable supply of high quality aluminium products, essential for extrusion and
rolling processes; b) providing technical support to customers for optimising their processes and developing new aluminium
alloys; and c) close collaboration to adapt its products to their specific needs and requirements, ensuring that the final solutions
are suitable for their applications. Continuous communication and cooperation with these key customers allow the Metals Sector
to better understand and meet their needs, thus contributing to mutual growth and success. This way, the Company ensures that
its key customers have access to high-quality materials and support, which is critical for their competitiveness in the markets
where they operate. This strategic partnership strengthens the value chain and promotes innovation and sustainable
development in the Metallurgy sector.
ENERGY SECTOR [SBM1-42_c]
METLEN's position in the Energy Value Chain is multifaceted and strategic, allowing it to play an active role in many stages of the
production process and the distribution of energy products and services. Its multidimensional role allows the Company to
respond to the ever-changing market demands and offer reliable energy solutions to its customers.
5. Annual Board of Directors Management Report
30
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
1. Development of solar and energy storage projects
- Site identification and evaluation - Energy efficiency & optimization studies - Environmental licensing
- Power grid interconnections etc
2. Analysis of requirements and offers for EPC energy transition projects, conventional energy
projects and grids
- Project Design Evaluation - Technical and Economic Analysis
- Negotiation with partners and clients - Development and submission of proposals
3. Selection of business partners
- Selection and evaluation of reliable suppliers who can provide the necessary materials and services
as well as the necessary equipment
- Conducting negotiations and signing contracts with suppliers
- Monitoring and managing the procurement process to ensure timely and reliable delivery of
materials and services
4. Supply of raw and other materials and of equipment
- Supply of fuel and materials for the operation of thermal power plants
- Identification and procurement of necessary materials and equipment for the construction of EPC
projects and solar energy and energy storage projects
5. Design, construction and management of solar and energy storage projects
- Coordination and management of suppliers and subcontractors, delivery schedule
- Conducting commissioning tests and quality checks
- Project commissioning
6. Energy production and management
- Energy production from natural gas thermal plants
- Electricity production using photovoltaic solar technology
- Electricity production from wind farms
- Continuous optimization, maintenance and repair of thermal power plants and of solar energy and
energy storage project installations
- Management of energy produced
- Power Purchase Agreements (PPAs) with companies or investors
- Electricity trading involving financial instruments and contracts (Non-Physical Power Trading)
7. Supply and trading of Natural Gas
- Release of liquefied natural gas loads for consumption and natural gas transportation via pipeline;
possible export activity
8. Design & construction of EPC, energy transition, conventional energy projects and grids for end
customers
- Design, supply of equipment, and construction work monitoring and management to deliver quality
assurance and adherence to schedule
- Performance of tests and quality checks to ensure compliance with specifications and standards
- Installation and adjustment of equipment required for project operation. Project
commissioning and delivery to the customer
9. Product offering
- Offering energy products and services, including electricity, gas, solar and energy storage projects,
energy efficiency options, to meet customer needs
10. Customer base development and retention
- Developing strategies to attract new customers through marketing, promotion and competitive
pricing campaigns and implement measures to retain existing customers
11. Customer service and support
- Providing excellent customer service and support to address queries, complaints and technical issues
A. Relationship with suppliers and partners
Own Operations
Downstream
Upstream
5. Annual Board of Directors Management Report
31
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The relationship of the Energy Sector with its suppliers and partners forms the basis of the successful implementation of its
energy projects. Through strategic partnerships and mutually beneficial relationships, the sector manages to innovate, optimise
its processes and contribute to the development of a more sustainable and efficient energy sector. These relationships are
integrated at every stage of the design and construction of Renewable Energy projects, photovoltaic systems, energy storage,
energy networks and conventional energy transition projects.
In the field of RES and photovoltaics, the Sector closely collaborates with leading suppliers of materials and equipment, ensuring
high-quality raw materials and cutting-edge technologies. These suppliers provide the most advanced photovoltaic panels,
inverters and other critical components necessary to develop efficient and reliable solar power generation systems. Through
these partnerships, the Company manages to reduce costs and optimise the efficiency of its projects, making them more
competitive in the market.
In energy storage, the Sector has established partnerships with innovative technology companies specialising in battery storage
systems and other advanced solutions. These partnerships allow the company to develop integrated storage systems that
improve the reliability and flexibility of its energy networks, while supporting greater integration of renewables into the energy
mix.
The Energy sector also collaborates with specialised companies to develop and build energy networks necessary for the transition
to a more sustainable energy system. These partnerships cover a wide range of activities, from the supply of materials and
equipment to the provision of engineering know-how and services. Through these partnerships, the Company ensures the
implementation of projects that meet the highest quality and safety standards, contributing to the creation of a more efficient
and resilient energy network.
Finally, in the field of conventional energy transition projects, the Sector leverages its relationships with renowned suppliers and
partners to develop and implement projects that support the transition from traditional energy systems to more sustainable and
efficient solutions. These partnerships enable the integration of the latest technologies and best practices in the development of
projects that reduce carbon emissions and promote energy efficiency.
B. Relationship with customers (RES and conventional and energy transition projects)
The relationships of the Energy Sector with its customers are the foundation of the successful implementation of its energy
projects and play a decisive role in the success and sustainability of such projects. These relationships are integrated at every
stage of the design and construction of Renewable Energy projects, photovoltaic systems, energy storage projects, energy
networks and conventional energy transition projects. At all project stages, from design to completion, emphasis is placed on
critical points that enhance the effectiveness of partnerships and the success of the relationship with customers. Such key points
are the transparency and completeness of the information given to customers ensuring the development of a relationship of
trust, compliance with contractual obligations aimed at a high quality end result, continuous customer support, flexible and
tailored solutions considering all customer needs and priorities, the constant effort for feedback and improvement of relations
and cooperation, the seamless communication and commitment to the result, and the constructive cooperation at all levels and
project phases.
Relationship with end consumers
For almost 20 years, with Protergia, the Energy Sector has been a pioneer in energy production and supply with consistency and
respect for all consumers, providing modern energy products by making use of digital technology. With a "green" orientation, it
offers quality and reliable solutions to households and businesses, always focusing on high quality and stability. Clients are placed
at the centre enabling them not only to decide but also know the outcomes of their decisions from the beginning. The relationship
of the Energy Sector with end consumers is characterised by a) the offer of competitive tariffs to ensure that energy is affordable
for all households.
This approach helps reduce energy costs for consumers and enhances trust in the Company, b) the operation of a service system,
with qualified personnel, designed to respond quickly and effectively to consumer needs and queries, c) investing in energy
tracking and tracing services whereby end customers can easily identify and visualize almost in real time the origin of the energy
they consume, but also monitor their carbon footprint, and d) information programs for end consumers on energy efficiency and
sustainability. All the above meet the requirements of a new generation of consumers, where every consumer can become both
5. Annual Board of Directors Management Report
32
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
producer and energy manager with the help of technology. With modern tools and artificial intelligence systems with
photovoltaic systems and digital meters, the Energy Sector offers customised energy solutions based on the profile and for the
benefit of each customer and end consumer.
5. Annual Board of Directors Management Report
33
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Inflation during 2024 eased in advanced economies around the globe, without improving significantly citizens’ life, due to hefty
ramp-up in prices over the past few years, which in turn has put more pressure on ruling parties. The inflation-driven anti-
incumbent sentiment, ushered in the United Kingdom, followed by elections in the US, as well as the European continent (EU
elections, France, Germany, Austria, etc), as the far-right in Europe continues to gather support.
The Middle East conflict has been escalated, during 2024, as additional nations became directly involved in the ongoing war
between Gaza and Israel, as the neighbouring Syria, saw its the longstanding Assad regime collapsing. At the same time, the war
in Ukraine, seems to de-escalate, following the intervention of the newly elected US President on one hand, and a European-
driven initiative on the other. The latter, among others, could potentially unleash significant resources to fund Europe’s defence,
in a radical shift of the EU’s security strategy.
Despite restrictive monetary policies and the uncertainty relating to the ongoing conflicts in Ukraine and the Middle East, global
economy remained resilient during 2024. Greece, in particular, is speeding up the alignment of its per capita GDP with the
European average, as its growth rate has consistently surpassed the EU average in recent years. In 2024, Greece managed to
grow by 2.3%, expanding three times faster than the Euro area. The latter was largely driven by the successful absorption of
Resilience and Recovery Facility (RRF) funds coupled by robust domestic demand as well as a growing gross fixed capital
formation.
The above, along with a steadfast commitment to fiscal discipline, and a growing contribution from investments to the country's
economic growth, suggest that Greece is poised to sustain its strong growth momentum in years to come. The Bank of Greece
expects GDP growth to reach the 2.5% mark in 2025 and remain above the 2% level over the next 3 years, thus continuing to
outperform the Euro area average.
At the outset of 2025, the global economic environment remains highly volatile, marked by ongoing geopolitical instability and
heightened competition among the world's most powerful nations. When combined with the uncertain policy direction of the
newly elected US president, which uses tariffs as a way to reshape global trade dynamics aiming to boost US manufacturing, the
global political landscape will present considerable challenges, and tensions, further exacerbating existing geopolitical
uncertainties. Nonetheless, despite these uncertainties and challenges, METLEN’s exceptional performance in 2024 provides a
solid foundation for achieving its objectives going forward.
METLEN’s 2024 financial performance affirms the company’s establishment at historically high levels, above the €1bn level, for
a second consecutive year, while confirming that the remarkable growth in our performance has not been a temporary
phenomenon, but simply a step towards new, even higher profitability levels.
2024 was a landmark year for us, as our continued international expansion combined with our Company’s rebranding, heralds
a new era for METLEN, defined by strategic foresight and operational excellence. Over the past year, we have achieved
significant milestones, securing major agreements, completing acquisitions, and further strengthening our position in both the
Energy and Metals’ sectors.
METLEN is looking towards, yet another year of strong performance relying primarily on its synergistic business model as well
as the well-diversified nature of the Company’s operations. The latter, both, coupled with significant investments, allowing us
to be optimistic about the ambitious business targets we have set for years to come. MYTILINEOS’ recent name change to
METLEN Energy & Metals originated the process for a primary listing of METLEN on the London Stock Exchange.
1. Energy Sector
METLEN ENERGY & METALS, through its new dynamic and flexible structure, is able to face current as well as upcoming
challenges. Moreover, the Company is strategically positioned at the forefront of the Energy Transition as a leading and
integrated energy company, with an international presence in the entire spectrum of the energy sector (Renewables, Energy &
Generation Management, Energy Customer Solutions, Integrated Supply & Trading and Power Projects).
M Renewables
RES – METLEN’s Global portfolio
Power (GW)
RES in Operation
1.4
RES Under Construction
1.4
RES RTB & Late stage of Development**
2.1
RES Early Stage of Development
6.2
Total*
11.1
2024 REVIEW - PERFORMANCE AND FINANCIAL POSITION
VIII.
5. Annual Board of Directors Management Report
34
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
*Includes projects of all technologies (photovoltaic, energy storage, wind), excluding the projects in Canada and also the
projects that are included in the deal with PPC
**Project ready to be Build (RTB) or that will reach RTB stage within the next ~ 6 months
In 2024, METLEN achieved significant results, strengthening its leading position in the Renewable Energy sector and advancing
sustainable development through strategic agreements and completed projects on a global scale.
The Company’s operational portfolio recorded dynamic expansion, reaching the 1.4GW of installed capacity by the end of the
year, surpassing the 1 GW milestone for the first time. Overall, METLEN’s global portfolio exceeded the 11.1 GW, marking a total
increase of c.0.6 GW compared to the beginning of the year. The portfolio incorporates 4.9GW of operational and mature stage
of development projects, as well as 6.2GW of projects in early stages of development.
The Groups’ global power production from Renewable Sources, in the end of 2024 amounted to 1.6 TWhs, an increase of 40%
compared to 2023. Of this total, 0.7TWhs were generated from Greek RES, with the balance of 0.9TWhs coming from
international projects. This remarkable performance reflects the ongoing dynamic growth and the expansion of METLEN’s
presence in the “green energy” sector, with projects in operation in Greece, UK, Italy, Ireland, Australia, Chile and South Korea.
In 2024, as part of its growth strategy, METLEN, signed a Cooperation Framework Agreement (CFA) with PPC, for the
development and construction of a 2 GW portfolio of solar projects in Italy, Bulgaria, Croatia, and Romania, reaffirming its
commitment to maximizing the efficiency of its portfolio. The agreement is valued at €2 billion, with a three-year
implementation horizon.
Supported by its geographically diversified, self-funded business model, with reduced capital requirements, the successful Asset
Rotation Plan allows the Company to consistently drive the growth in profitability of M Renewables, capitalizing on its
international experience and network of partners, with operations and presence across more than 20 countries. During 2024
alone, METLEN proceeded to conclude agreements for the sale of photovoltaic (PV) projects (SPAs) with total capacity of c.1GW,
in Europe.
With regards to METLEN’s Greek pipeline, during 2024 commenced the construction of 0.4GW of PV projects, 48MW of energy
storage projects (BESS), and 13MW of wind projects. The Greek portfolio utilizes resources from the Recovery and Resilience
Facility (RRF).
It is worth noting, that the Renewable Energy Sector, within the energy division, continues to perform strongly, thanks to the
collaborative Energy and Metals model and the seamless operation of Energy Management.
In 2024, METLEN saw significant growth in the development, construction, and management of energy storage systems (BESS),
both for third parties and own projects, solidifying its position as a leading renewable energy developer. The Company reached
a total storage capacity of approximately c.0.7GWh across Greece, Italy, the United Kingdom, Puerto Rico, Tunisia, and Nigeria.
At the same time, METLEN is in the final stages of contracting new third-party energy storage projects with a total capacity of
2.2GWh, while expanding its portfolio with new projects. These projects are expected to become operational in the coming
years, further strengthening METLEN’s position in the energy storage sector, which is expected to play a key role in green
transition energy investments in the coming years.
Finally, during 2024, new third-party projects with a total capacity of c.1.1GW were contracted in Greece, Spain, Italy, Chile,
New Zealand, and the United Kingdom, with the contracted backlog amounting to €463.1 million, while an additional €530
million are in final stages of negotiation.
M Energy & Generation Management
Greek Market Data - 2024
Production per Unit type [TWh]
2024
2023
Δ%
2024
% of mix
2023
% of mix
Lignite
3.2
4.5
-28%
6%
9%
Natural Gas
21.0
15.4
36%
41%
31%
Hydros
3.5
4.1
-14%
7%
8%
RES
1
24.3
20.4
20%
47%
41%
Net Imports
-0.3
4.9
-106%
-1%
10%
Total
51.7
49.2
5.2%
100%
100%
1
Renewable Energy Sources
5. Annual Board of Directors Management Report
35
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN Generation (TWhs)
2024
2023
Δ%
Thermal Plants
8.7
5.1
71%
RES
0.7
0.6
12%
Total
9.4
5.7
65%
2024 was marked by a significant increase in electricity demand, recording a year-on-year growth of 5%.
Production from domestic units was particularly high considering that, in addition to the increase in consumption in the domestic
market, Greece exported electricity to third countries, for the first time since 2000, whereas in 2023 imported c.10% of the
demand (4.9TWh), on a net basis.
The largest increase, compared to 2023, was noted in electricity generation from natural gas thermal plants, which increased by
36%, followed by a 20% increase from Renewable Energy Sources (RES). On the contrary, lignite-based electricity generation
continued its steady downward trend (-28%).
With regards to electricity exports, 2025, is expected to mark a turning point for the future of Greece's energy strategy. This
significant development opens the door to a new era, in which Greece is not limited to solely fulfill its domestic needs, but
expand its influence in the region, further strengthening its position in the energy sector. Increasing demand expectations in the
coming years, coupled with the strengthening of the country's exporting capacity, will lead to a constant improvement of the
domestic power production, which in 2024 alone increased by c.8 TWh, or 17%, compared to 2023.
Group’s total power production in Greece, both from the Group's thermal and renewable units, amounted to 9.4 TWh,
representing 18.2% of total demand, from 11.6% at the end of 2023. METLEN, over the last year, has managed to nearly double
its production and thus its market share is expected to increase even further in the coming period, driven by the anticipated rise
in production from RES units. At the same time, the contribution of both the strong partnerships that the Group has developed,
which in this specific sector are expressed mainly through more competitive natural gas prices, as well as the unique
characteristics of its thermal fleet and in particular the higher efficiency of its units compared to the market, is expected to be
decisive.
M Energy Customer Solutions
METLEN – Supply of Energy & Natural Gas
2024
2023
Δ%
Market share
18.5%
13.5%
37%
Regarding the electricity supply activity, Protergia, is steadily strengthening its presence in the retail market, with its market
share at the end of 2024 reaching 18.5% (HEnEx market shares – including Volterra’s market share), recording significant
increase from 13.5% at the end of 2023. METLEN in the upcoming period is expected to exceed the 20% of the Greek
consumption, aiming to create an integrated “green” utility with international presence, while the ultimate goal of achieving a
30% market share, over the next 2-3 years, via both acquisitions as well as organic growth, remains intact. Taking advantage of
the vertical integration of the Company's operation in the Energy Sector, METLEN has managed to establish the integrated
energy provider of the new era ("Utility of the Future"). This provides the Company with the ability to withstand the pressure
from significant price fluctuations, benefiting consumers. The latter has been demonstrated by Protergia's pricing policy, which
has kept prices stable throughout the second half of 2024 and in the first quarter of 2025, thus offering competitive prices to
consumers. At the same time, it is steadily strengthening its representation, which is now approaching 580 thousand meters,
from 525 thousand at the end of 2023.
M Integrated Supply Trading
Moreover, METLEN, beyond the Greek market, has achieved significant penetration in other markets in the Southeast European
region, in terms of natural gas supply and trading, as part of the Company's internationalization strategy. METLEN, by
maintaining consistently high volumes of natural gas, has become a major regional player in both the Balkans and wider
Southeastern Europe, securing competitive supply prices.
The benefit of this activity is distributed through METLEN's synergistic model to all the Company’s operations. Overall, for 2024,
the Company was a leading player in natural gas trading in SE Europe, representing 42% of the country's total imports.
5. Annual Board of Directors Management Report
36
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
M Power Projects
Energy Projects METLEN
2024
Unexecuted balance of contracted projects
€1.1 billion
Total Projects
€1.1 billion
M Power Projects (MPP) continuously strengthening its international presence in projects supporting the Energy Transition and
Sustainable Development goals, currently executing the 22 projects in 8 different countries.
MPP focuses on the construction and development of critical infrastructure, specializing in electrical grid projects,
interconnections, data center construction, and power supply solutions. Through its commitment to innovation and quality, it
plays a key role in advancing, upgrading, and expanding the energy infrastructure - key to enabling the green transition and
bolstering the digital economy.
At the end of 2024, the backlog of contracted projects amounted to €1.1 billion, of which 9% refers to projects in Greece and
the rest in international markets, primarily the United Kingdom and Poland. This activity is expected to grow significantly, while
resources from the European Recovery Fund offer further opportunities, given that Greece receives particularly high funding as
a percentage of its GDP.
The M Power Projects Sector has a strong pipeline with 30 projects in the bidding phase within the framework of the Energy
Transition, mainly networks, in countries such as Greece, Germany, the United Kingdom, Italy, Ireland, which are at various
stages of maturity. At the same time, the company's presence in HVDC (High Voltage Direct Current) projects is constantly being
strengthened. The goal for 2025 is the active participation in Data Center projects, while the monitoring of energy projects
within the framework of the energy transition in Germany remains of strategic importance for the company.
2. Metals Sector
Total Production Volumes (ktons)
2024
2023
Δ%
Alumina
865
869
-0.4%
Primary Aluminium
182
183
-0.7%
Recycled Aluminium
56
56
0.0%
Total Aluminum Production
238
239
-0.6%
Aluminium & Alumina Prices ($/t)
2024
2023
Δ%
3Μ LME
2,456
2,287
7.4%
Alumina Price Index (API)
503
344
46.2%
Metals Sector reported turnover of €857 million, representing 15% of the Company’s total turnover, posting a 9% decrease on
a year-on-year basis. Earnings before interest, taxes, depreciation and amortization (EBITDA) stood at €297 million, increased
by 20% compared to 2023.
The 2024 average aluminium price (3M LME) came in at 2,456$/t, from 2,287$/t in 2023, marking a 7.4% increase. During 2024,
aluminium prices maintained their upward trend, reaching the 2,800$/t level in late May, following the ban on deliveries of new
Russian aluminium production from the London Metal Exchange (LME).
Recently, the price of aluminium has stabilized at the $2,600/t level, moving slightly upwards after the announcement by the
new President of the United States regarding the imposition of custom duties on aluminium. The ongoing trend of the US dollar
(USD) strengthening to levels approaching parity with the Euro has a positive impact on the financial results of companies like
METLEN, with the European currency making up most of their costs.
Despite aluminium price fluctuations, the impact of the aluminum billet premia, particularly in the regions where the Company
operates (Europe), is expected to be equally decisive. During 2024, premia, increased from the $350/t level, at the beginning of
2024, to $550/t at the end of the year. Premia’s steady upwards trend is mainly attributed to the fact that Europe remains a
significantly deficit market, with most of its needs covered by imports from third countries.
Alumina price index (API), followed a strong upward trend, rising by nearly 50%, surpassing the $500/t mark in 2024, increasing
the contribution of alumina in the production cost of those, non-integrated aluminium producers. This change is mainly
attributed to delays in bauxite shipments from Guinea and Brazil, as well as reduced Chinese supply.
5. Annual Board of Directors Management Report
37
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Therefore, the need for greater verticalization in the aluminum market is now seen as imperative, not only for an even more
effective cost management, but also for the seamless continuation of the production process, by securing bauxite supply, the
raw material for alumina, which in turn becomes aluminum’s key input cost.
In this context, METLEN, following Imerys Bauxites acquisition, being one of the largest producers in Europe, is strengthening its
international presence. At the same time, the recently announced new large investment, for the expansion of bauxite and
alumina production as well as the construction of a new Gallium production plant, is expected to boost Europe's autonomy in
critical raw materials, while supporting both the Company’s and Greece’s strategic position on the global stage.
With regards to the above, METLEN, announced a breakthrough agreement with Rio Tinto, which is expected to have a twofold
benefit for the Company as it enhances its bauxite security of supply, while ensuring future profitability from the incremental
alumina quantities (+ 400kt per annum), under competitive terms, with one of the largest companies in the sector globally. This
11-year strategic partnership bulletproofs new large investment’s (announced in January) exceptional returns, while strengthens
METLEN’s competitive position and deepens the Company’s presence in the global alumina market.
METLEN, starting from 2027-28, is expected to increase its bauxite production by more than 65%, covering a large portion of its
bauxite needs, while nearly doubling alumina’s third party sales. Moreover, the company is entering a new market, that of
Gallium, which on top of the significant contribution to the Company's profitability, will enhance substantially Metal’s Segment
quality of earnings.
The significant comparative advantages offered by the coexistence of the Energy and Metals Segments, combined with the fact
that METLEN has managed to secure favorable LME prices, an advantageous €/$ FX rate, are expected to maintain the Company
among the most competitive aluminium and alumina producers globally in years to come.
3. Infrastructure and Concessions
The turnover of the infrastructure segment (METKA ATE and its subsidiaries) for 2024 amounted to €285.4 million compared to
€158.3 million in 2023, while earnings before interest, taxes, depreciation, and amortization (EBITDA) amounted to €50.3 million
compared to €21.3 million in 2023.
At the end of 2024, the backlog of infrastructure projects approaches €1 billion, while including projects in advanced stages of
contracting, it approached the amount of €1.4 billion (note: for projects executed by joint ventures, only the share of METKA
ATE is included in the backlog).
The main developments of 2024 include:
The project 'Remaining Works for the Completion of the Road Connection of the Aktion Area with the North-Southwestern Axis'.
In June 2024, a contract was signed with the company LAMDA RIVIERA S.M.S.A. for the construction of “Riviera Galleria Shopping
Center” in Elliniko, with a construction period of 26 months.
In October 2024, a contract was signed with the company MC CONSTRUCTION AND MANAGEMENT OF CENTRAL MACEDONIA
SCHOOLS S.A. for the design and construction of seventeen school units in the region of Central Macedonia (PPP project).
The execution of the projects 'Upgrade of the Internal Peripheral Road of Thessaloniki (FlyOver)' by the J/V AVAX SA– METKA
ATE, 'Upgrade of existing Suburban Railway Line of Western Attica, section Ano Liosia - New S.S. Megara - P.S. Megara' by METKA
ATE, as well as of many other projects, continues without obstructions.
For 2025, an increase in the figures of METKA ATE and its subsidiaries is expected, through progress in the execution of the
projects in the Company’s backlog and the commencement of execution of the contracts to be signed, in which METKA ATE is a
temporary contractor.
In the medium term, the prospects for the construction industry in Greece are particularly favorable, both for public and private
projects, as well as for Public & Private Sector Partnerships (PPP) and Concessions, in which the Infrastructure Sector (METKA
ATE and M Concessions) has already started to play an important role, which it aims to continuously enhance.
At the moment, very important infrastructure projects are in various phases of tendering, either as pure public projects (e.g.
extension of line 2 of the Athens METRO, railways of northern Greece), or as PPP projects (road projects, building projects), in
which METKA ΑΤΕ, both autonomously as well as a manufacturer of its affiliated M. Concessions, aims to play an important role,
contributing substantial results to its parent company. Also, METKA ΑΤΕ aims, guided by the Public Interest, and utilizing its
technical expertise, to contribute to the resilient recovery of the destroyed infrastructure by the severe weather phenomena in
Thessaly.
Prospects
At the outset of 2025, the global economic environment remains highly volatile, marked by ongoing geopolitical instability and
heightened competition among the world's most powerful nations. Nonetheless, despite these uncertainties and challenges,
METLEN’s exceptional performance in 2024 provides a solid foundation for achieving our objectives.
In a demonstration of its constant commitment to competitiveness and optimal cost management and loyal to the principles of
continuous improvement, METLEN Energy & Metals is accelerating its digital transformation. The goal is to maintain its
resilience, drive growth, reduce costs and enhance the employee experience.
5. Annual Board of Directors Management Report
38
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
At the same time, the Company aims to leverage digital tools and the progress already made to maximize the value generated
across all its activities.
In line with its culture of continuous improvement, METLEN designed and launched “Trinity” a new operating and value delivery
model through accelerated digital transformation.
Through this new model, which strengthens the collaboration of three core pillars—Business Units, Operational Technology and
IT—the company is creating cross-functional teams that develop innovative technology-enabled solutions tailored to address
real business needs.
The digital transformation is supported by investments of approximately €50 million for 2025, aimed at developing 45+ digital
products and platforms across all its business activities, as well as Central Functions.
Overall, particular emphasis is placed on leveraging Artificial Intelligence, with 12 out of the 45 digital products and platforms
currently under development incorporating AI/GenAI technology.
i. For the Energy Sector, digital transformation includes diverse solutions such as the improvement of forecasting for
energy management (through the development of AI forecasting models), the use of AI and smart cameras to improve
Health and Safety, advanced analytics for condition monitoring and predictive maintenance of facilities, remote real-
time monitoring of units operations, development of innovative technological services to improve and personalize the
customer experience, as well as the development of technology solutions for risk management.
ii. In the Metals Sector, this digital transformation aims at improving productivity and reducing production costs (e.g. via
collection and visualization of operating data), enhancing employee safety using AI, improving quality control, using
Augmented Reality / Virtual Reality for training purposes and remote technical assistance, using drones for inspections
in hazardous and hard-to-reach areas, as well as deploying 5G networks in industrial installations.
iii. Beyond the Energy and Metals Sectors, the digital transformation applies to the rest of Central Functions, e.g. by
integrating GenAI digital assistants into multiple internal processes.
Additionally, the plan is backed by 150+ employees (to date) and a specialized upskilling program that offers targeted learning
and development programs, focuses on the enhancement of digital skills and places digital acumen at the heart of performance
management initiatives.
The upskilling program, already in place, reaffirms METLEN’s commitment to enhancing the skills of its workforce, enabling them
to drive strategic goals and innovation within the organization.
An extensive presentation of the company's prospects and the large-scale investment program included in the company's 3rd
transformation (code-named Big 3) will be presented at the Capital Markets Day (CMD) which will be held in a special room after
a relevant invitation at the London Stock Exchange around on 28th of April 2025.
5. Annual Board of Directors Management Report
39
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Total Impact on Group Sales and EBITDA
Specifically, the effect in Group’s turnover, EBITDA and Net Profit during 2024 compared with previous year is presented
below:
A. SALES
Amounts in million €
Group
Total
Energy
Metals
Infrastructure
&
Concessions
Other
Group
Total
Sales FY 2023
5,492
4,425
942
125
0
5,492
Intrinsic Effect
1,018
Volumes
460
9
-
-
469
Renewables
466
-
-
-
466
Projects
(45)
(0)
129
-
83
Other
(0)
(0)
1
-
(0)
-
-
Market Effect
(715)
Organic €/$ eff.
(0)
(3)
-
-
(3)
Organic €/£ eff.
3
-
-
-
3
Prices & Premia
(736)
22
-
-
(714)
Hedging
(113)
-
(113)
-
-
(113)
Sales FY 2024
5,683
4,572
857
254
0
5,683
B. EBITDA
Amounts in million €
Group
Total
Energy
Metals
Infrastructure
&
Concessions
Other
Group
Total
EBITDA FY 2023
1,014
766
248
18
(19)
1,014
Intrinsic Effect
87
Volumes
17
(20)
-
-
(2)
Renewables
103
-
-
-
103
Power Projects
(52)
(4)
31
-
(24)
Other
11
-
1
(1)
11
Other
81
Other
-
81
-
-
81
Market Effect
(116)
Premia & Prices
-
(48)
-
-
(48)
Raw Materials prices
-
28
-
-
28
€/$ rate effect
0
(3)
-
-
(3)
€/£ rate effect
(2)
-
-
-
(2)
Natural Gas Price
(51)
(2)
-
-
(53)
CO2
24
2
-
-
26
RTBM / Day Ahead Market
(54)
-
-
-
(54)
Net Energy Cost
(11)
-
-
-
(11)
-
Hedging
15
1
14
-
-
15
EBITDA FY 2024
1,080
753
297
50
(20)
1,080
5. Annual Board of Directors Management Report
40
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
C. Net Profit after minorities
Amounts in million €
Energy
Metals
Infrastructure
&
Concessions
Other
Group Total
Net Profit after Minorities FY2023
623
Effect from:
Earnings before interest
and income tax (EBIT)
(52)
37
31
0
17
Net financial results
(63)
Investments results
9
Minorities
(14)
Income tax expense
43
Net Profit after Minorities FY2024
615
D. Sales and Earnings before interest, taxes, depreciation, and amortization per Business Unit Sales & EBITDA
(Amounts in thousands €)
Energy Sector
Sales
M
Renewables
M Energy
Generation &
Management
M Energy
Customer
Solutions
M Power
Projects
M
Integrated
Supply &
Trading
Intersegment
Total
01.01.2024-31.12.2024
1,199,208
1,019,309
1,322,720
603,286
962,570
(535,357)
4,571,735
01.01.2023-31.12.2023
733,993
619,521
1,248,346
646,347
1,513,899
(336,618)
4,425,488
EBITDA
01.01.2024-31.12.2024
348,693
248,286
60,471
38,796
57,053
-
753,299
01.01.2023-31.12.2023
240,164
147,442
90,107
97,017
191,748
-
766,477
*The Companies which are consolidated with equity method and own Renewable Energy Units with capacity of 1.7MW are not
included in the amounts of RES.
The Intrasegment Eliminations concern the elimination of turnover of common MWh between the activities ''Power Generation''
and ''Electricity Supply'' which are part of the Energy sector of the Group.
(Amounts in thousands €)
Metals Sector
Sales
Alumina
Aluminium
Other
Total
01.01.2024-31.12.2024
197,696
622,833
36,513
857,042
01.01.2023-31.12.2023
193,398
711,729
36,446
941,573
EBITDA
01.01.2024-31.12.2024
87,066
198,662
11,065
296,793
01.01.2023-31.12.2023
17,060
217,366
14,010
248,436
5. Annual Board of Directors Management Report
41
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
(Amounts in thousands €)
Infrastructure & Concessions
METKA ATE
Concessions
Intersegment
Total
Sales
01.01.2024-31.12.2024
250,185
3,995
-
254,180
01.01.2023-31.12.2023
124,589
-
-
124,589
EBITDA
01.01.2024-31.12.2024
50,311
(640)
-
49,671
01.01.2023-31.12.2023
21,310
(3,734)
-
17,576
(Amounts in thousands €)
Other
Total
Sales
01.01.2024-31.12.2024
-
-
01.01.2023-31.12.2023
35
35
EBITDA
01.01.2024-31.12.2024
(19,692)
(19,692)
01.01.2023-31.12.2023
(18,868)
(18,868)
The reconciliations of Alternative Performance Measures (APMs) to the most directly reconcilable line item are included in Note
3.17.
5. Annual Board of Directors Management Report
42
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The European Investment
Bank (EIB) has committed
€400 million to support a
significant new investment
for METLEN Energy &
Metals, which will accelerate
renewable energy
production across Greece
and other EU countries.
Completion of the
acquisition of 100% of the
company IMERYS BAUXITES.
This strategic move
broadens METLEN’s portfolio
and makes the company the
largest bauxite producer in
the European Union.
METLEN Energy & Metals
and KARATZIS SA signed a
210MW long-term Power
Purchase Agreement (PPA)
for the green energy
produced from a 262 MW
solar portfolio. Under the
PPA signed, METLEN will be
able to offtake 80% of the
energy produced, enhancing
further its “green” supply
basket.
METLEN Energy & Metals in
Consortium with Siemens
Energy Global GmbH & Co.
KG and Siemens Energy sp. z
o.o. (SIEMENS ENERGY), has
undertaken the construction
of a 560 MW CCGT power
unit with associated
infrastructure at the
Adamów Power Plant in the
area of Turek in Poland.
METLEN Energy & Metals
has reached financial close
with lenders BNP Paribas,
Intesa San Paolo, Sumitomo
Mitsubishi Banking
Corporation, Rabobank and
Santander Chile, on a 588
MWp non-recourse solar
portfolio in Chile.
METLEN Energy & Metalsand
PPC Group announce that
they have signed a
Cooperation Framework
Agreement (CFA) for the
development and
construction of a portfolio
of solar projects up to 2GW
in Italy, Bulgaria, Croatia and
Romania. The value of the
deal is estimated at up to €2
billion and is expected to be
implemented over the next
three years.
SIGNIFICANT INFORMATION
IX.
5. Annual Board of Directors Management Report
43
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN is considering a
potential listing on an
international exchange,
including the LSE, within the
next 12-18 months. METLEN
is expected to retain a listing
on the Athens Exchange, as it
remains committed to its
contribution to the Greek
economy.
METLEN Energy & Metals,
inaugurated its second
owned project in Chile. Doña
Antonia solar park, with an
investment of US$65 million
dollars and with an installed
capacity of 90 MW will
provide clean 100%
renewable energy for the
green development of the
country.
METLEN Energy & Metals
announced, that its 100%
subsidiary METKA ATE has
signed an agreement for the
acquisition of all shares of
the company M.T. ATE.
In line with METLEN’s Energy
& Metals strategic review,
METLEN has taken the first
step in the regulatory
process for the London
Listing through the filing of a
draft listing prospectus with
the UK Financial Conduct
Authority for their review.
The company presented its
new corporate brand and
renewed corporate image.
The transition from
MYTILINEOS Energy &
Metals to METLEN Energy &
Metals marks an evolution
that reflects an unwavering
commitment to growth and
innovation.
METLEN Energy & Metals
announced the successful
pricing of its green bond
offering of €750 million
Senior Notes due 2029.
5. Annual Board of Directors Management Report
44
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
A. Executive Summary
METLEN Energy & Metals considers risk management an integral part of business operations to identify risks and opportunities
and ensure business resilience. Enterprise risk management is integrated into our decision-making, market analysis, and business
continuity, enabling us to continuously identify and assess existing and emerging risks and opportunities on a company and
business level.
The risk governance structure (see section: Risk Governance Pillar) ensures the independence of the Enterprise Risk Management
(ERM) Division, establishes communication and reporting lines to escalate significant risks and promotes close collaboration of
the ERM Division with Risk Owners and other internal assurance providers. In addition, at METLEN, the establishment of a strong
risk culture is an essential aspect of our risk management practices that promotes risk behaviors, pervades our willingness to
accept risk, determines clear roles in risk management, and educates personnel on matters related to risks, opportunities, and
controls (see section: Risk Culture Pillar).
To achieve the purpose and mandate of risk management, the ERM Division has a set of policies and processes that cover the
risk management life-cycle and are available to all METLEN personnel (see section: Enterprise Risk Management Framework
Pillar).
The three pillars (Risk Governance, Risk Culture, and Enterprise Risk Management Framework) work together to identify, assess,
and manage risks that could impact METLEN’s growth, sustainability, financial and operational performance, and reputation. The
following is a summary of METLEN’s Principal Risks as well as Emerging Risks. At METLEN, risks are considered dynamic, and their
effect could change depending on external and internal events that could trigger changes in the severity of risk exposures. For
detailed analysis of Emerging Risks and Principal Risks see relative sections 4. Emerging Risks and 5. Principal Risks.
ENTERPRISE RISK MANAGEMENT
X.
5. Annual Board of Directors Management Report
45
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
B. Enterprise Risk Management Analysis
METLEN’s mission, vision, corporate values, strategy, and the amount and type of risks it is willing to take in order to meet the
business objectives, inform and shape its risk management principles. Enterprise Risk Management is an essential component of
METLEN’s operations and is achieved through a multidimensional approach which is based on three fundamental pillars: Risk
Governance, Risk Culture and our Enterprise Risk Management framework.
Through these elements, we achieve a comprehensive approach to the management of risks that affect our strategy, operations,
financial and business objectives. METLEN’s operations are affected by multiple risks, which may affect the business operations,
the financial performance, and the achievement of its strategic objectives.
1. Risk Governance Pillar
The foundation of sound enterprise risk management is a well-defined and established risk governance structure. At METLEN,
the risk governance pillar aims to promote the tone and expectations of senior management for risk management and risk
appetite across the business sectors and central functions, taking into account the vision, mission, corporate values, and business
objectives.
Moreover, our risk governance structure is developed based on the legislative requirements and good practices, such as the three
lines model, to determine clear authorities, roles, responsibilities, reporting lines, oversight mechanisms and to promote a strong
risk culture and a common risk language across the organization. Finally, an aligned governance structure is essential to ensure
the escalation of key risks that may impact the achievement of METLEN’s business objectives and to inform effective decision
making.
1.1 Three Lines Model
By adapting and implementing the three lines model, METLEN has defined appropriate structures and roles in managing risk
related matters that facilitate strong governance and risk management. The first line consists of Risk and Control Owners across
our organization (Central Functions and Business Sectors), who have day-to-day ownership and management over risks and
controls. They are responsible for properly identifying, assessing, managing, and monitoring risks, with the support and guidance
from the ERM Division. The ERM Division, as a second line function, supports and challenges the first line by coordinating the
implementation of risk management practices and provides expertise and guidance regarding the severity of risks. The third line,
our Internal Audit Division, is responsible for providing independent and objective assurance over the adequacy and
effectiveness of governance, risk management and internal controls.
1.2 Risk Governance Structure
METLEN’s risk governance structure provides and distributes roles and responsibilities to establish an environment that allows
risk information to be communicated through top-down and bottom-up levels, promotes an adequate risk culture, and provides
the guidelines for effectively strengthening risk awareness across business sectors.
1.2.1 Elements of Risk Governance
A sound risk governance structure is essential for communicating the importance of risk management across the organization
and developing a framework for identifying, assessing, accepting, and avoiding risks while pursuing the achievement of
organizational objectives.
At METLEN, the importance of risk management, as well as the utilization of risk management outcomes, are supported through
a robust governance structure. This structure leverages the collective knowledge and expertise of the Board of Directors and the
Board Committee (Audit Committee) that provides deeper focus and oversight in areas such as risk management and internal
control system. Additionally, the governance framework is supported by the independent operations of the Enterprise Risk
5. Annual Board of Directors Management Report
46
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Management Division and other internal assurance providers. The framework outlined below provides a detailed overview of the
key components of METLEN’s risk governance structure:
1.2.2 The Role of Enterprise Risk Management in Risk Governance
The Enterprise Risk Management (ERM) Division is responsible for the
design and deployment of the overall risk management framework
across the organization in order to identify and manage risks. The ERM
Division is independent from business functions and reports
functionally to the Audit Committee. The Head of the ERM Division
promotes a set of principles that are deployed through ERM Policy and
ERM Process in order to ensure long-term value creation, achieve
business and strategic objectives and address threats. Moreover, the
values and the mandate of the ERM Division are presented below:
A. Design, Add Value and Facilitate: The ERM Division develops
the key components of the Enterprise Risk Management
Framework (ERM Policy, ERM Process, Risk Appetite
Framework), facilitates the execution of risk assessment, and proposes improvement opportunities to manage and
respond effectively to risks and risk events.
B. Monitor, Report and Train: The ERM Division monitors risk exposures across METLEN, adherence to the risk framework
and escalates the most significant risk exposures and control issues to Audit Committee and senior management.
Moreover, the ERM Division, through risk initiatives, educates and trains METLEN’s senior management and personnel
in matters related to risk and controls.
Moreover, the ERM Division collaborates with other assurance/risk providers within the organization in order to establish a
common risk language, common perspective regarding risk and opportunities and to strengthen risk awareness. More specifically,
the ERM Division cooperates with the Internal Audit Division, the Compliance Division, the Sustainable Development Division,
and the Chief Information Security Officer. Finally, the operations and methodologies of the ERM Division are audited by the
5. Annual Board of Directors Management Report
47
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Internal Audit Division of METLEN as well as by an independent auditor every three years based on the Internal Control System
Assessment framework of the Hellenic Capital Market Commission.
1.2.3 Enterprise Risk Management and Internal Control System
For the effective management of risks, METLEN has developed an internal control system that consists of a set of policies,
processes, standards and rules which promote the principles, the expected inflows and outflows of business processes and the
controls that should be performed to ensure the accuracy and completeness of information. The internal control system
strengthens the awareness for risk management and provides opportunities to enhance the operations and performance. Finally,
the internal control system assessment methodologies followed by the Internal Audit Division and the Enterprise Risk
Management Division consider the principles of the COSO Internal Control-Integrated Framework (2013).
2. Risk Culture Pillar
Risk Culture establishes the foundation regarding the behaviors within the organization that influence the management of risk,
taking into account its size, nature and complexity. METLEN promotes a risk culture to support informed decision-making across
the organization, and ensure acceptable behaviors, transparency, awareness, risk taking and risk management. The risk culture
of METLEN consists of attributes that aim to develop the set of behaviors that influence risks and impact outcomes.
2.1 Tone from the Top
The Board and Executive team establish the appropriate risk behaviors through the provisions, communication, and acceptance
of the Code of Conduct Principles by all personnel. Moreover, business values and behaviors are articulated through specific
policies such as Conflicts of Interest policy, Whistleblowing Policy, Antifraud, Anticorruption & Antibribery Policy.
2.2 Risk Appetite
METLEN considers an effective risk appetite framework as a strategic tool to enhance and promote a strong risk culture. The risk
appetite framework is developed with the participation of all executive members who share their views, business, and market
knowledge to formulate the risk appetite statements, taking into consideration METLEN’s corporate values and strategic
objectives. As a result, the risk appetite is aligned with our strategy and stakeholders' perspectives and provides guidance to
management regarding the types and levels of risk the organization is willing to pursue to achieve its business objectives and
maximize shareholder value. Finally, the Board of Directors approves the qualitative and quantitative risk appetite statements.
2.3. Risk Accountability & Transparency
Roles and responsibilities for risk management are clearly articulated and understood by risk management participants across
the ERM framework and include the accountabilities and expectations of all risk members (Board, ERM Division, Risk Owners,
etc.). Risk transparency is enabled by comprehensive risk reporting, including the analysis of inherent and residual risk levels,
aggregated views of risks, and analysis of principal risks to inform stakeholders regarding the effect of risks in the business
objectives, the existing risk treatments that are part of the company’s internal control system and the additional treatment
actions in order to enhance the management of key risks taking into account the risk appetite framework. Finally, risk-related
5. Annual Board of Directors Management Report
48
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
issues are communicated to internal stakeholders (e.g. Audit Committee) from various sources, including internal audit reports
and key findings, complaints, breach monitoring and reporting, etc.
2.4 Risk Awareness & Training
Risk awareness and training reinforce the risk culture across the organization. The formal policy and the process of the ERM
Division are available to all employees through METLEN’s intranet and include communication lines amongst the ERM Head and
the Risk Owners. Through these communication lines, involved parties are able to propose new risks, reassess existing risks,
discuss risk and control concerns and share ideas to enhance the overall risk management process and practices.
Also, the establishment of a risk appetite framework serves as a guiding tool for fostering risk awareness, as it defines METLEN's
approach to risk-taking while pursuing its strategic, business, operational, and financial objectives.
Additionally, in order to embed a risk culture across the organization, the ERM Division conducts formal and informal training
sessions for risk management participants (e.g. Risk Owners, etc.) and risk stakeholders about the concepts of risks and controls.
The aim of these training sessions is to increase the participants’ awareness regarding the importance of risk management
practices as a tool to achieve organizational objectives, to identify areas of improvement and to strengthen the management of
risks. Moreover, the ERM Division, based on the yearly internal review, identifies improvement opportunities in the areas of
assessment, prioritization and reporting packages.
It should be noted that risk-related trainings are conducted in other occasions such as during the onboarding process of new
employees in which risk matters related to current/emerging topics (e.g. GDPR, Security) that may arise and should be brought
to the attention of new joiners. Moreover, training sessions are conducted in order to increase the awareness of personnel to
cyber risk, to educate the personnel on cyber threats and methods that may lead to cyber vulnerabilities. Finally, training sessions
are conducted for liable persons on matters such as conflicts of interest, antitrust, etc.
Finally, METLEN has established a consultation process to monitor the development of new policies and procedures. The
consultation process at METLEN serves not only as a formal mechanism for policy and procedure development but also as an
informal training and educational opportunity, fostering a deeper understanding of risk and control concepts across the
organization. Through this mechanism, the completeness, accuracy, and interrelationships of proposed policies and procedures
are evaluated. Executives from Central Functions and Business Sectors actively participate by proposing changes and approving
the final or revised versions of these documents. The ERM Division plays a key role in this process by offering guidance on
associated risks and recommending relevant controls to be incorporated at various stages of the procedures. To enhance the
efficiency of this consultation process, METLEN has developed the "Digital Consultation App" platform. This innovative tool
facilitates the monitoring and approval of new or updated policies and procedures, ensuring seamless collaboration and
transparency across all stakeholders.
2.5 Risk Coordination
Risk coordination amongst internal assurance providers, the business sectors and central functions is essential for fostering a
strong risk culture, ensuring a shared understanding of risk and control elements across the organization.
More specifically, common risk terminologies, categories, and ratings are established between the ERM Division, the Internal
Audit Division, and the Chief Information Security Officer to enhance the alignment of assurance functions, establish a common
risk language, and provide Executive and Senior Management with a transparent and fair view of risks and their impact on the
organization. Moreover, the Internal Audit Division leverages the work of the ERM Division to prioritize the auditable areas, assess
the design and effectiveness of related controls, and provide the Executive and Senior Management of METLEN with an overall
assessment of the internal control system.
3. Enterprise Risk Management Framework Pillar
Our ERM Framework aims to establish a streamlined process for the identification, assessment and reporting of risks that includes
defined roles and responsibilities, risk terminology, assessment criteria, tools for the documentation of risks, as well as escalation
and reporting lines.
3.1 Our ERM Process
Our ERM process has been developed with the aim of fitting the structure and objectives of METLEN. The process incorporates
elements and principles of ISO 31000 and COSO ERM to establish a strong and dynamic risk management framework.
5. Annual Board of Directors Management Report
49
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
More specifically, METLEN’s risk management cycle incorporates corporate inflows such as corporate values, business objectives,
willingness to accept exposures to the pursuit of business objectives, and market conditions and produces risk outcomes that
provide the necessary information to the Executive team to direct resources (human and capital) to manage the risk uncertainties.
In more detail the components of the risk management cycle:
Establishment of Context: Establishing the context helps clarify the objectives and scope of the activity for which the risk
assessment is being conducted, identify the stakeholders and subject matter experts, understand the organization’s internal and
external environment and define the set of criteria against which the identified risks will be assessed / measured.
Risk Identification: Through the identification of risks, we recognize areas of uncertainty and potential events that could enhance
or prevent the achievement of the organization's goals. METLEN conducts risk identification to produce a comprehensive list of
risks through various methods and assigns each risk to a Risk Owner to promote and ensure accountability.
Risk Analysis: The identified risks are analyzed and assessed, considering the risk criteria in terms of impact, probability and the
design of the internal control system aiming to calculate the inherent and residual risk levels. Our impact assessments include
considerations across financial, reputational, operational (people, technology, operations, etc.) and sustainable development
criteria with sensitivity threshold in order to properly assess the severity of risks to strategic, business and financial objectives.
Risk Evaluation: The evaluation of risks has two dimensions. The first dimension supports the prioritization of risks to determine
the most significant risks for METLEN. The prioritization of risks considers both the inherent and residual risk scores to identify
significant tail risks with emphasis on risk materiality both before and after implementing mitigation actions. The second
dimension of the risk evaluation involves comparing the risk results with the risk appetite levels to consider the need for
treatment actions.
Risk Treatment: METLEN determines the appropriate risk response or combination of responses to effectively manage its risk
exposures according to the organization’s risk appetite as well as the level of the risk rating of each identified risk. Responses
manifest themselves as series of initiatives or projects and are the responsibility of the risk/business owners.
Monitoring & Review: METLEN analyzes risk trends since factors that could affect the impact and probability may change, as may
factors that affect the appropriateness of the internal control system or the design of the risk treatment plans. Moreover, we
monitor the status of risk treatment, and we reassess at regular intervals the performance of the ERM Framework to identify
potential improvement opportunities. To enhance risk monitoring, we define Key Risk Indicators (KRIs), acting as early warning
signals for changes in risk severity. These indicators enable proactive management and ensure that potential issues are addressed
before they escalate.
Communication & Consultation: METLEN plans and implements communication activities related to the ERM Framework aiming
to maintain open and dynamic communication with Risk Owners as well as frequent reporting to Senior Management and the
Audit Committee. Communication and consultation include bringing different areas of expertise together, ensuring different
views are considered when assessing risks, providing sufficient information to facilitate risk oversight, and promoting risk
awareness and understanding of risks.
3.2 Frequency of Risk Assessment Process
METLEN conducts and monitors the evolution of risk exposures through the risk assessment process at least yearly; or, when
events constitute a crisis an ad hoc ERM cycle will be performed if decided as necessary.
5. Annual Board of Directors Management Report
50
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
3.3 Our Risk Universe
The identified risks are classified into five (5) categories Strategic, Market, Operational, Financial, Legal & Regulatory &
Compliance, as presented below.
Strategic
Risks that may offer benefits to the organization or threats that may arise
from adverse business decisions, poor implementation and execution of the organization’s
strategy, or lack of responsiveness to strategic plan deviations caused by external or internal
factors.
Market
Risks that may arise from failure to identify factors relating to macroeconomic and
sociopolitical conditions that will affect the ability of the organization to maintain or increase
its revenue and profitability in a specific business environment.
Financial
Risks that may arise due to ineffective management of financial markets’ volatility and
incorrectly, miscalculated, omitted, or misrepresented financial information to external users
such as investors and regulators, or internal stakeholders.
Operational
Risks that may arise from inadequate or failed internal processes or systems, ineffective
human resource management, or from external events.
Legal & Regulatory & Compliance
Risks that may arise from ineffectively managing regulatory and legal risks
and failure to comply with internal procedures resulting in regulatory censure, adverse
financial or reputational impact.
4. Emerging Risks
METLEN identifies and monitors emerging risks through various channels, such as Management Committees and reports from
specialized consultants on new trends and risks. Moreover, risks that have already been identified through risk management
processes and could potentially have a significant long-term impact on the organization, yet remain outside METLEN's immediate
control, are classified as emerging risks. These risks require close attention and ongoing monitoring by the ERM Head and Senior
Management. The emerging risks identified by Senior Management of METLEN that could affect the company in the upcoming
years are:
1. Risk Title: Application and adoption of emerging technologies and intelligent solutions
A. Risk Analysis: Emerging technologies and new intelligence solutions are transforming the business landscape and
environment in which METLEN operates, presenting both opportunities and challenges with potentially significant,
multidimensional impacts. Specifically, groundbreaking technologies with diverse applications in the Energy and Metal sectors
offer opportunities to enhance METLEN’s leadership and diversified positioning. However, they also introduce risks related to
the proper assessment, feasibility, and integration of these innovations within the organization.
The rapid development of advanced intelligence solutions holds significant potential for achieving METLEN’s strategic
objectives. Examples include carbon capture, utilization, and storage (CCUS) solutions; hydrogen utilization; smart cities; and
AI and machine learning platforms for energy trading, renewable energy forecasting, energy storage, and mining activities.
While these advancements provide substantial opportunities, they also come with risks that require careful management to
maximize benefits and minimize disruptions. Key factors contributing to the uncertainty surrounding these risks include: a)
5. Annual Board of Directors Management Report
51
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
the pace of technological advancements and their readiness for industrial-scale implementation, b) identifying and aligning
the most relevant emerging technologies with METLEN’s strategic objectives, c) Conducting effective proof-of-concept studies
to validate technology performance and assess scalability before full deployment, d) evaluating the cost-effectiveness and
return on investment for integrating these technologies into METLEN’s operations.
In the long term, these risks could disrupt the organization’s business and financial targets, hinder its ability to innovate and
lead with new solutions or offerings, impact its global footprint and brand reputation, reduce opportunities to attract
specialized new skills, and weaken its overall competitiveness.
B. Risk Treatment: METLEN has adopted a comprehensive and strategic approach to managing the risks and opportunities
associated with emerging solutions and innovation. This approach involves a systematic process to monitor and assess
technological trends while proactively planning and executing in-house innovation and transformation programs. For example,
the Smart City Project of Aspra Spitia serves as a practical initiative to test and validate new technologies in a controlled
environment, providing valuable insights into their applicability and scalability.
To further manage these evolving risks, METLEN evaluates business opportunities by participating in pilot or small-scale
projects designed to assess the technical and economic feasibility of emerging technologies. This allows METLEN to identify
potential challenges early, make informed decisions, and optimize resource allocation. Additionally, METLEN actively forms
alliances and partnerships with other companies, research institutions, and technology providers to share expertise, reduce
implementation risks, and enhance the adoption of innovative solutions.
Recognizing the critical need for specialized skills and capabilities in this evolving landscape, METLEN has also taken a bold
step by spinning off a digital startup focused on leveraging data and artificial intelligence. This new entity is dedicated to
designing intelligent solutions tailored for the energy sectors, positioning METLEN to capitalize on advancements in technology
while fostering innovation.
2. Risk Title: Extreme and unpredicted weather events and natural disasters
A. Risk Analysis: METLEN’s operations are exposed to the threat of unpredicted natural and weather-related events that have
the potential to disrupt operations, damage critical assets, create financial losses, and impact the local communities where
METLEN operates. The frequency, intensity, and velocity of these events indicate a growing trend that such uncontrollable
occurrences will continue to pose significant challenges. As a result, addressing these risks requires sustained attention and
strategic planning from METLEN’s senior management.
More specifically, severe weather events (wildfires, floods) and natural events (earthquakes, landslips) may impair the
capability of METLEN to sustain critical operations such as the operations of the thermal power units and the refinery, the
ability to fulfill contractual obligations for services and products as well as lead to damages to project equipment, litigations
costs, and operating costs to manage the risks.
A. B. Risk Treatment: To manage extreme weather and natural events, METLEN adopts approaches that include insurance
coverage, identification of possible vulnerabilities and action plans (ex-ante and ex-post such as reinforced constructions), and
crisis management framework, with clear roles, responsibilities, and escalation protocols for managing unpredicted events.
5. Principal Risks
5.1 Identification of Principal Risks
METLEN operations are susceptible to internal and external events that may create upside or downside risks. Through our
comprehensive enterprise risk management framework, we identify and assess these events to gain a holistic and fair view of
risks and understand how these risks can materially and adversely affect our future performance, strategy and reputation.
Moreover, the risk assessment results are further elaborated to identify the principal risks based on our robust prioritization
exercise that aims to highlight risks that have significant exposure before and after implementing mitigation actions.
Furthermore, through our integrated risk management approach, we effectively capture both existing and potential negative
impacts identified during the double materiality assessment. By leveraging these insights, we interlink the results of the double
materiality assessment with the principal risks, ensuring that these risks are systematically aligned and effectively addressed
within our ERM Framework.
The results of our risk prioritization process, incorporating the outcomes of the double materiality assessment, are presented
below and highlight the identification of Principal Risks. Risks positioned closer to the center of our prioritization diagram
represent those with the highest severity.
5. Annual Board of Directors Management Report
52
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
5.2 Analysis of Principal Risks
The principal risks are timely identified and closely monitored and analyzed so that appropriate mitigation actions, in line with
our risk appetite, can be taken. An analysis of the principal risks that METLEN faces including the description and potential threats
of each risk, the root causes/factors that contribute to the materialization of the risk, METLEN’s appetite for each risk, the
evolution of the risk severity, and related mitigation actions are presented below.
A. Market Risks
The following section provides an analysis of principal market risks:
R1 Geopolitical
Risk Trend
A. Definition:
Social, political factors or trade barriers within a
market environment may affect the organization's
investments and ability to market, sell and provide
products and services. Through its business
activities that expand in five continents, METLEN
is exposed to a wide and ever-changing
geopolitical environment that could potentially
threaten the organization’s activities and
reputation.
B. Risk Appetite Statement:
We have activities in various countries with less
stable political and economic environments, and
possible restrictions imposed after the initiation of
D. Risk Analysis:
METLEN’s activities, access to markets, and operational continuity face
potential disruptions stemming from various forms of political instability,
including terrorism, war, crime and social unrest. Such events can
undermine the stability of the regions in which METLEN operates, causing
delays in project execution, increased security risks, and heightened
operational costs. Furthermore, frequent changes in policies, regulations
and legislation, short-term changes in demand and/or trade requirements
could potentially impact key markets for METLEN’s products, projects and
services.
Moreover, ongoing geopolitical developments, such as military conflicts,
trade disputes, sanctions, and political disruption, can have an impact on
5. Annual Board of Directors Management Report
53
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
projects / investments. We are willing to accept
Medium levels of Geopolitical Risk in pursuit of
our strategic objectives and stakeholders’
expectations, maximizing the shareholder value
and ensuring, in any case, that we monitor and
assess the factors that may impact our risk
exposure and respond efficiently, where possible.
C. Main Root Causes / Factors:
§ Political instability in relevant countries (e.g.,
Libya, Ghana) that the organization operates
in.
§ Embargoes of gas-producing countries may
affect the organization's strategic,
operational, and financial targets.
METLEN. These dynamics can disrupt business plans and investment
decisions due to increased uncertainty, fluctuating commodity prices, etc.
E. Risk Treatment and Mitigation:
METLEN has developed specific policies and processes for the assessment of
Geopolitical Risk exposure but also for the implementation of risk mitigation
plans. More specifically, METLEN deploys the following instruments/tools:
· In-house comprehensive Geopolitical Risk assessment
· Legal pre-contractual assessment
· Financial and insurance instruments
· Safety and security measures for personnel and premises.
METLEN continuously monitors and assesses the geopolitical environment
of each country it has operations, in terms of security, political stability and
regulations, to identify any emerging geopolitical risks and/or monitor the
development of existing ones. Moreover, METLEN conducts thorough
review of the geopolitical environment and accompanied risks when
considering expanding its activities in new countries. More specifically,
multidivisional working groups are formed, which in collaboration with
specialized consultants, assess the type and severity of the risks that
METLEN may be exposed to (political, credit, health & safety, tax, supply
chain, etc.). As part of the assessment, local visits may be conducted to
countries of interest to further examine the expansion opportunities. The
assessment is followed by the development of corresponding risk
management strategies that are evaluated in relation to the benefits
presented by the expansion of activities, leading to an informed decision
that considers the Geopolitical Risks involved. METLEN has developed a
proactive strategy for engaging with key stakeholders in the countries it
operates, such as governments and regulators, aiming to achieve
continuous monitoring of the situation in each country and assist in the
socio-economic development of the countries through various initiatives.
R2 Macroeconomic
Risk Tend
A. Definition:
The organization does not plan for or manage
fluctuating macroeconomic factors (e.g., inflation,
GDP, economic growth, stability) leading to
financial loss.
B. Risk Appetite Statement:
We are exposed to dynamic domestic and global
macro-economic factors, and we operate in
possible high-risk countries. We are willing to
accept Medium levels of Macroeconomic Risk,
ensuring in any case that we monitor and assess
the factors that may impact our financial position
and respond efficiently where possible.
D. Risk Analysis:
Through its business activities that expand in various economies, METLEN is
exposed to a wide range of macroeconomic trends and factors that could
potentially threaten its activities, financial stability and long-term viability.
METLEN could face negative impacts from various macroeconomic
pressures, such as significant reductions in customer spending, delays in
investment plans, and inflationary pressures that erode profit margins by
increasing the underlying cost base. Additionally, political instability and
aggressive monetary and fiscal policies could adversely affect the
achievement of METLEN’s strategic objectives.
More specifically, a variety of macroeconomic indicators may alert the
business and financial targets, e.g. an increase in unemployment rates could
negatively affect demand/default rates in retail businesses, primary surplus
5. Annual Board of Directors Management Report
54
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
C. Main Root Causes / Factors:
§ Failure to identify and react to dynamic
macro-economic factors may negatively
impact investments, revenue, and
profitability.
§ Local and national political-institutional
change may affect the attitude towards the
organization.
can have an impact on public investments and demand for infrastructure
projects, high interest rates may affect the overall financial goals of the
business since the interest rate increase aims to slow economic activity and
is likely to lead to lower demand for goods and services as well as to increase
the borrowing costs making credit and investment more expensive and
having an impact on the overall liquidity.
E. Risk Treatment and Mitigation:
METLEN operates across various geographies, economies and industries
(Energy and Metals), thus maintaining a balanced portfolio that ensures
resilience and future profitability. This diversification reduces its exposure
to adverse economic developments in any single geography or industry,
enhancing its ability to navigate global uncertainties.
METLEN continuously monitors the macroeconomic environment through
monthly meetings of the Business Sectors Committees/Councils (Energy and
Metals) and the Financial Committee where relevant developments are
presented and discussed.
METLEN monitors, through various channels, the current and estimated
developments in the market, the macroeconomic variables and the
accompanied macroeconomic risks (e.g., macroeconomic stability of a
country, inflation fluctuations, monetary policies), that could potentially
create the need to adapt the organization’s actions both in production and
investment levels.
Price volatility, a key macroeconomic risk, is managed centrally through
robust hedging activities. This centralized approach allows METLEN to
mitigate financial exposure and maintain stability in its cost structure,
providing a critical safeguard against unpredictable market fluctuations in
raw materials, energy, and other inputs.
Furthermore, METLEN integrates macroeconomic metrics and forecasts in
its five-year business plan to examine the viability of projects and future
opportunities against a range of associated variables (e.g. prices, costs).
R3 Energy Supply
Risk Trend
A. Definition:
The organization does not plan and manage
effectively the energy sources (electrical power,
natural gas, etc.) in terms of quantity, pricing and
costs.
B. Risk Appetite Statement:
Our appetite for Energy Supply Risk is Medium.
We seek to ensure effective management of
energy sources, taking into consideration external
factors such as fluctuations in regional/global
supply/demand of natural gas and power.
D. Risk Analysis:
METLEN operations face potential risks stemming from high energy prices
and availability constraints caused by disruptions in the energy market.
These disruptions can arise from geopolitical tensions, supply chain
interruptions, or volatility in energy commodities, creating challenges for the
organization’s ability to secure reliable and cost-effective energy sources.
Potential failure to effectively plan and manage the energy sources
(electrical power, natural gas, etc.) in terms of quantity, pricing, and costs
could lead to delays and disruptions in the production process of the Metals
Sector, the participation of thermal units of the Energy Sector in the energy
mix, additional costs, and inability to achieve operational and financial goals
5. Annual Board of Directors Management Report
55
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
C. Main Root Causes / Factors:
§ Fluctuations in regional/ global
supply/demand of natural gas may affect the
production and financial targets of the
organization.
§ Gas supply chain capacity shortages affecting
plant production.
§ Inability to source competitive electrical
power mix.
as well as client needs. Finally, the ability to maintain a balanced mix of
electrical power (RES vs Thermal) is important to meet sustainability and
financial targets.
E. Risk Treatment and Mitigation:
The Energy Council of METLEN continuously monitors energy sources
(electrical power, natural gas, etc.) in terms of quantity, pricing and costs.
The Energy Council convenes monthly to analyze the latest developments in
the energy sector and how they impact the organization’s operations and
objectives.
Moreover, METLEN, through the M Energy Generation & Management
business segment, establishes the principles, methodologies, and practices
for effectively managing energy supply. More specifically, the business
activity is staffed with personnel with specialized skills and competencies
and in-depth knowledge of the energy sector in order to monitor the energy
market, analyze the competition, conduct statistical and analytical analysis
on the energy market for decision-making, forecast energy needs, design
strategies for market bidding & power trading (withing the country and
across borders), and propose alternative solutions to manage the energy
generated by METLEN generation assets (thermal and RES) and energy from
3rd parties PPAs.
METLEN participates in all wholesale energy markets to ensure access to
energy supply and develops and maintains a competitive energy portfolio
that consists of our group's existing assets (thermal, RES) and a basket of 3rd
party RES PPA contracts.
Moreover, METLEN, through the utilization of tailor-made energy
monitoring and forecasting tools, evaluates and assesses the development
of market prices to support the optimization of the energy portfolio basket
across the short-term and medium-term horizons.
In addition, METLEN enters into long-term gas/electricity supply agreements
with counterparties that meet its criteria regarding reliability and
creditworthiness to ensure availability of critical sources for its activities.
Finally, where feasible, METLEN hedges the energy prices’ fluctuation both
with strategic and operational methods, using various financial instruments,
such as derivatives.
R4 Commercial & Competition
Risk Trend
A. Definition:
The organization does not act on changing market
conditions, threatening its market position
towards competition and its capacity to efficiently
conduct business or does not establish a business
development and promotion strategy, impacting
its ability to maintain or increase its market share.
B. Risk Appetite Statement:
Our appetite for Commercial & Competition Risk
is Medium taking into consideration the
competitors in the metallurgy industry,
construction industry, Solar PV and energy storage
development and retail energy market.
D. Risk Analysis:
METLEN's Energy segments are exposed to significant commercial and
competition risks that could impact profitability, market share, and
operational efficiency. In the retail energy segment, intense price
competition, customer retention challenges, and regulatory pressures pose
substantial risks. Rivals offering lower prices or more attractive service
packages can erode market share, while regulatory changes may increase
operational costs or constrain pricing strategies, further compressing profit
margins. In the renewable energy segment, competition for lucrative
contracts, government incentives, and prime project sites is fierce.
Fluctuating costs of raw materials, such as solar panels and batteries, as well
as delays in project timelines, threaten operational efficiency and
profitability. Additionally, securing long-term power purchase agreements
5. Annual Board of Directors Management Report
56
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
C. Main Root Causes / Factors:
§ Loss of market share due to new
competitors, with higher efficiency or lower
production cost, entering the market.
§ Failure to identify new
products/services/technologies that are
innovative and result in an appropriate
return on investment.
§ Inability to effectively analyze the business
environment and market demands
(PPAs) with competitive terms remains critical to financial viability and the
ability to scale operations. The power projects segment faces risks tied to
securing contracts amid competitive bidding processes, with fluctuating
material and labor costs adding financial pressure to project budgets. The
energy management segment is exposed to market volatility, pricing
inaccuracies, and geopolitical factors, all of which can disrupt supply-
demand dynamics and lead to financial losses or missed opportunities in
optimizing energy portfolios. Lastly, in the natural gas segment, risks stem
from securing favorable supply agreements and maintaining competitive
market positioning. Price volatility, driven by geopolitical tensions, supply
disruptions, and seasonal demand fluctuations, further complicates
operations and can strain financial performance.
E. Risk Treatment and Mitigation:
METLEN has established a robust framework to address the commercial and
competition risks across its Energy segments, ensuring agility,
competitiveness, and resilience in navigating market challenges while
safeguarding its operational and financial objectives. A key component of
this approach is a structured governance framework, including the monthly
Energy Council, where key energy market developments are analyzed, and
strategic actions are formulated. This proactive oversight ensures timely
responses to emerging risks and alignment with organizational objectives.
In the retail energy business, METLEN leverages market segmentation
strategies to implement a focused and data-driven approach to customer
engagement. By conducting market analysis and developing new products,
METLEN continuously identifies opportunities to enhance competitiveness
and diversify its offerings. To manage risks associated with customer
defaults, METLEN implements a creditworthiness assessment process for
electricity and natural gas customers. Additionally, METLEN employs credit
insurance policies, offering an additional layer of financial protection against
default risks.
METLEN also actively mitigates risks associated with price volatility and
market dynamics. METLEN monitors the European wholesale energy
market, conducts detailed energy price and mix analyses, and engages in
active participation in wholesale energy markets. By implementing power
trading strategies with defined exposure limits and performing stress testing
of open exposures, METLEN reduces financial risks stemming from market
fluctuations. Furthermore, through monitoring power plant production,
METLEN ensures the profitability and operational efficiency of its energy
assets. In the natural gas segment, METLEN addresses supply chain risks by
ensuring the diversification of natural gas counterparties and monitoring
market dynamics. This approach builds supply chain resilience, particularly
amid geopolitical tensions and market disruptions. In the construction and
project development business, METLEN applies rigorous Go/No-Go criteria
and detailed approval workflows to identify and evaluate new business
opportunities. This ensures that projects are aligned with strategic goals and
adequately assessed for financial and operational risks. By combining these
targeted strategies with proactive risk monitoring and management
practices, METLEN successfully mitigates commercial and competition risks
across its business segments. These measures enable METLEN to maintain
its competitiveness, achieve its sustainability objectives, and ensure
financial stability in a dynamic and evolving market environment.
5. Annual Board of Directors Management Report
57
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
B. Strategic Risks
The following section provides an analysis of principal strategic risks:
R5 Long-term resources availability
Risk Trend
A. Definition:
The organization does not monitor and manage
effectively the reserves and availability of
critical materials which may lead to issues on the
continuation of business operations.
B. Risk Appetite Statement:
Our appetite for Long-term Resources
Availability Risk is Low. We seek to ensure
efficient and effective monitoring of critical
materials reserves and availability and plan for
future needs, taking into consideration possible
shortages affected by external factors.
C. Main Root Causes / Factors:
§ Lack/shortage of Greek Bauxite reserves.
§ Ineffective monitoring of reserves to plan
for future needs and to develop synergies
with other companies.
§ Lack of natural gas reserves to meet
production targets.
D. Risk Analysis:
The demand and supply dynamics of long-term resources are closely related
to our ability to produce the expected economic output and support social
initiatives. Our business activities are dependent on the expected supply of
raw materials (e.g. bauxite) and energy sources (e.g. natural gas) that can be
affected by various external factors such as competition, regulations,
government policies, price speculation as well as by internal factors such as
production targets and operational efficiency.
The availability, quality, and cost of critical raw materials and energy sources
affect METLEN's financial and operational targets. More specifically,
disruptions in the bauxite production or the bauxite supply in terms of type,
concentration of iron minerals, and price could negatively or positively affect
the business objectives of the Metals Sector. These disruptions may either
negatively or positively affect METLEN’s ability to meet its strategic goals,
depending on market conditions and supply agreements. Furthermore, the
security and availability of natural gas are paramount for the operations of
thermal power units, the uninterruptible Aluminium of Greece (AoG)
operations, and METLEN’s participation in the energy and gas markets. Any
disruption in natural gas supply—such as those caused by geopolitical
tensions, sanctions, tariffs, or market shortages—could severely impact
METLEN’s objectives. These challenges may lead to increased operational and
financial costs as METLEN seeks alternative means to secure the necessary
quantities of natural gas to sustain operations.
E. Risk Treatment and Mitigation:
The Metals Committee and the Energy Council of METLEN meet monthly to
monitor the market dynamics of the supply and demand of critical raw
materials and the development of energy markets (electrical power, natural
gas, etc.).
METLEN, to ensure the supply of critical raw materials, has developed a
diversified portfolio of bauxite resources, including “owned” mines (European
Bauxites) and multi-year contracts with companies to supply the required
bauxite quantities. Furthermore, to guarantee long-term bauxite supply,
METLEN has invested in bauxite exploration and exploitation projects in
Ghana.
In addition, technological and vertical integration investments are completed
to strengthen the business objectives of Metals Sector including a) the
development and installation of a new unit to process tri-hydrated bauxite and
b) the exploration of AI capabilities and use cases for optimizing bauxite
exploration.
At an operational level, METLEN has policies and processes for developing,
monitoring, and adjusting the annual procurement plan for raw materials to
business needs.
Moreover, METLEN secures the supply of natural gas that is the source for the
operation of thermal power plants to participate in the energy market and
ensure the uninterrupted operation of AoG through a diversified network of
natural gas counterparties, oversees and monitors the natural gas market to
react and adjust to market changes and secure the supply of natural gas on
favorable terms.
5. Annual Board of Directors Management Report
58
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN ensures the accessibility to electrical power in favorable terms
through a competitive energy portfolio comprising our group's existing assets
(thermal, RES) and a basket of 3rd party RES PPA contracts.
Finally, METLEN, in order to manage unexpected events such as grid
destruction or unavailability, has completed the installation and gradual
operation of a new direct line between H-Class and AoG Plant to secure
operations.
R6 Investments Decisions
Risk Trend
A. Definition:
The organization does not identify business
opportunities or threats to initiate mergers,
acquisitions, divestments, joint ventures,
partnerships, or the lack thereof, that do not align
with the organization’s strategic objectives and
have a negative impact on decisions or planned
benefits.
B. Risk Appetite Statement:
Our appetite for Investments Decision Risk is
Medium. It is our priority to identify business
opportunities that align with our strategic
objectives achieving financial growth with high
potentials returns.
C. Main Root Causes / Factors:
§ The organization does not undertake
financial due diligence.
§ Not well-defined decision-making process for
the organization to decide whether to
invest/grow or divest/liquidate.
§ Unrealistic assumptions during the due
diligence process.
§ People issues, such as cultural and
operational challenges are not addressed by
management.
D. Risk Analysis:
Investment decisions, particularly those involving mergers, acquisitions, and
major transactions, are critical to METLEN’s strategic growth and
sustainability. While such activities present opportunities to expand
operational capacity, enhance market competitiveness, and increase market
share, they are inherently accompanied by significant risks that could affect
METLEN’s financial health, market position, and overall reputation. One
important risk lies in valuation inaccuracies, where misjudging the worth of
acquired assets or companies can lead to overpayment, ultimately straining
financial resources and reducing the return on investment. Such missteps
can also diminish shareholder confidence and limit METLEN’s ability to
allocate capital toward other growth opportunities.
Moreover, unforeseen liabilities pose another considerable risk. Acquired
companies or assets may bring hidden issues such as unresolved legal
disputes, environmental responsibilities, or unrecorded financial debts.
These liabilities can have a lasting impact on METLEN’s balance sheet,
creating financial burdens and reputational challenges.
Integration inefficiencies represent another significant challenge, especially
following mergers or acquisitions. When acquired entities or assets are not
seamlessly integrated into METLEN’s operations, inefficiencies can arise,
disrupting workflows, creating bottlenecks, and delaying the realization of
synergies. This can lead to operational underperformance and failure to
achieve the strategic benefits anticipated from the transaction.
Additionally, market conditions and economic factors play a crucial role in
the success of investment decisions. For example, while selling PV solar parks
may generate immediate cash inflows, fluctuating demand and buyer
interest could impact pricing, placing pressure on profit margins. These
external factors underscore the importance of timing and market analysis in
transaction planning.
E. Risk Treatment and Mitigation:
METLEN’s structured transaction process plays a vital role in managing risks
associated with mergers, acquisitions, and other major investments. Each
stage is approached with careful planning, thorough analysis, and robust
decision-making to mitigate uncertainties. A Steering Committee provides
oversight and ensures alignment with strategic goals, offering guidance and
evaluating all critical aspects of the investment before proceeding.
5. Annual Board of Directors Management Report
59
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The due diligence process identifies potential liabilities, inefficiencies, and
risks, ensuring investments align with METLEN’s financial goals and strategic
expectations. To enhance accuracy, METLEN employs a valuation model,
supported by an assumption booklet, ensuring consistent and transparent
methodologies. A well-structured transaction framework further minimizes
unforeseen complications by detailing terms, structure, and financing. When
required, the Capital Allocation Committee convenes to analyze risks and
make informed decisions.
To ensure post-transaction success, METLEN leverages the Post-Merger
Integration approach, which provides clear guidelines for integrating
acquired entities. By defining roles and addressing challenges, it ensures
synergies are achieved, reducing inefficiencies and enhancing overall
investment outcomes.
R7 Health & Safety
Risk Trend
A. Definition:
The organization does not manage effectively the
Health & Safety conditions in all its work areas
resulting to impacts for employees, business
partners, trainees and visitors, as well as increased
accident/absenteeism management costs,
reputational damage or does not adhere to local
and international health and safety laws and
regulations resulting in noncompliance, fines,
prosecution.
B. Risk Appetite Statement:
Our appetite for Health & Safety Risk is Very Low.
It is essential for us to ensure health and safety in
every workplace we operate.
C. Main Root Causes / Factors:
§ Lack of policies and procedures regarding
Health & Safety management.
§ Violations of standards of practice and
behavior as set forth by Health and Safety
rules and regulations.
§ Poor monitoring and evaluation of healthy
working conditions.
§ Lack of responsibility, and accountability in
handling Health & Safety incidents.
§ Lack of communication channels for
reporting accidents/injuries.
D. Risk Analysis:
METLEN is exposed to health and safety risks due to the nature of its
operations. These risks include minor workplace accidents, accidents
resulting in lost workdays, occupational diseases, and, in the worst cases,
fatalities. Managing these risks is critical not only for safeguarding the
physical and mental well-being of employees, subcontractors, and business
partners but also for ensuring METLEN’s business continuity and reputation.
The potential failure to manage health and safety risks effectively could
result in severe consequences. Beyond the immediate human impact, such
incidents can lead to litigation, regulatory fines, increased insurance
premiums, operational issues due to equipment damage or work stoppages
that can halt production or delay project timelines, replacement costs and
reputational damage.
E. Risk Treatment and Mitigation:
Occupational health and safety are fundamental to the operation of METLEN
and are considered a primary business objective. To manage the Health and
Safety Risk, METLEN monitors and addresses health and safety issues and
underlines the importance of health and safety during the monthly business
committees (Metals Committee and Energy Council). METLEN acknowledges
its responsibility and actively seeks to ensure the best possible health &
safety conditions in all its work areas, through the implementation of an
integrated and certified Occupational Health & Safety Management System.
Additionally, METLEN, to ensure compliance with the applicable legislations,
has established and implements strict health and safety policies and
procedures throughout the organization, that support its objectives for
health and safety. Through the implementation of the System, policies and
procedures in place, METLEN adopts appropriate measures for preventing
accidents and occupational diseases, conducts audits, accident investigation
and analysis activities as well as close monitoring and reporting of matters
related to health and safety. Additionally, METLEN provides ongoing health
and safety training programs to all employees aiming to promote and embed
a safe work culture. The training programs are adjusted to fit the specialized
training needs of employees based on the work they perform.
For additional analysis, refer to the Sustainability Statement section, S2
Workers in the Value Chain.
5. Annual Board of Directors Management Report
60
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
R8 Sustainability
Risk Trend
A. Definition:
Failure to manage and protect energy and earth
resources (water, air, plants, animal species) or to
monitor the developments on climate change and
sustainability principles due to ineffective
business practices, methods, processes,
equipment, and machinery affecting the climate,
the environmental and local communities
footprint, the continuation of business operations
and the organization's long-term growth.
B. Risk Appetite Statement:
Energy and earth resources, climate change and
sustainability principles are critical issues affecting
our business. We consider our risk appetite as low.
Our sustainability strategy is based on climate
Change, ESG approach and corporate
responsibility.
C. Main Root Causes / Factors:
§ Lack of defined sustainability policies and
procedures.
§ Lack of clear roles and responsibilities across
the organization regarding sustainability.
§ Release of direct/Indirect CO2 emissions
from energy intensive business activities and
suppliers.
§ Release of Non-GHG emissions (Nox,Sox)
from key industrial business activities.
§ Degradation of land, water, and marine
resources due to significant pollution
incidents.
§ Salinization of groundwater resources due to
over pumping.
D. Risk Analysis:
METLEN faces sustainability and climate-related risks that could disrupt its
operations, financial performance, and long-term strategy. Sustainability
challenges stem from inefficient business practices, outdated equipment,
and inadequate processes, which hinder the organization’s ability to manage
and protect natural resources such as water, air, plants, and animal species.
This could lead to environmental degradation, increased carbon emissions,
resource scarcity, and non-compliance with environmental regulations,
exposing METLEN to legal liabilities, fines, and reputational damage.
Furthermore, climate-related risks, both physical and transitional, further
compound these challenges. Physical risks, including water stress, extreme
weather events, and rising temperatures, may disrupt raw material supplies,
increase production costs, and create capacity constraints. Meanwhile,
transitional risks, such as stricter regulations, compliance costs, and the
pressure to meet decarbonization goals, require rapid adaptation to evolving
market and policy demands. Failure to manage these risks could result in
financial losses, reputational damage, and loss of the social and regulatory
license to operate. Addressing these sustainability and climate related risks
is critical to maintaining operational resilience, protecting ecosystems, and
securing stakeholder trust.
E. Risk Treatment and Mitigation:
METLEN manages sustainability and climate-related risks through a
structured and integrated approach that embeds sustainable development
into its decision-making processes and operations. The Sustainability
Committee, supporting the Board of Directors, plays a pivotal role in
ensuring that sustainability policies (e.g. Corporate Social Responsibility
Policy, Responsible Supply Chain Policy, etc.), and other matters are
effectively discussed and analyzed. Additionally, ESG updates and
performance are reviewed regularly during the monthly meetings of the
Financial Committee, ensuring that sustainability remains a priority across
the organization.
Moreover, METLEN demonstrates a robust commitment to managing
climate-related risks by aligning with the recommendations of the Task Force
on Climate-related Financial Disclosures (TCFD), incorporating climate
change considerations into its governance, strategy, risk management, and
target-setting processes. METLEN evaluates climate risks under different
scenarios and develops actions to effectively manage these risks. This
includes implementing waste management practices for by-products like
bauxite from its primary aluminum production process, introducing water
recycling and reuse programs, and measuring and monitoring gaseous
emissions and water discharges. METLEN also invests in research and
development aimed at utilizing bauxite residues and recovering rare earth
elements, reinforcing its commitment to sustainability and innovation.
For additional analysis, refer to the Sustainability Statement section,
sections E1 Climate Change, E2 Pollution, E3 Water and marine resources
and E4 Biodiversity and ecosystems.
5. Annual Board of Directors Management Report
61
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
C. Financial Risks
The following section provides an analysis of principal financial risks:
R9 Commodities
Risk Trend
A. Definition:
The organization does not plan or manage unfavorable
fluctuations in the price of commodities leading to
financial loss.
B. Risk Appetite Statement:
We are exposed to the volatility of specific commodities
and important raw materials and services prices (e.g.
Aluminium, Alumina, Natural gas), which are influenced
by external factors such as global economic conditions,
supply and demand. We are willing to accept Medium
levels of Commodities Risk ensuring that this risk is
efficiently and effectively managed implementing
proactive measures such as hedging.
C. Main Root Causes / Factors:
§ Lack of defined policies to provide guidance for
handling commodities prices.
§ Lack of monitoring activities to capture and manage
unfavorable market, regulation, and country
changes/events that may affect the volatility of
commodities prices.
D. Risk Analysis:
METLEN operates in global markets with exposures to market driven
commodity price fluctuations that are determined by demand and
supply dynamics, economic growth, inventory balances, speculative
positions, regulatory affairs, government policies, etc.
Potential failure to plan or manage unfavorable fluctuations in
commodity prices could adversely impact METLEN’s future financial
performance.
More specifically, through its business activities, METLEN is mainly
exposed to risks arising from price fluctuations in Aluminium (AL),
Aluminium Oxide (OX), natural gas, CO2 emission allowances and
scrap aluminium.
These types of exposure could negatively affect both revenues (e.g.,
metal prices at LME) and costs (e.g., natural gas prices).
E. Risk Treatment and Mitigation:
METLEN maintains a diverse portfolio of commodities, assets,
liabilities, and currencies across several geographies as well as a
varied portfolio of customers and contracts that ensures resilience
and future profitability since the organization becomes less exposed
to adverse developments in a single market.
Moreover, METLEN continuously monitors, through various
channels, both current and future developments in the commodity
markets, so that its overall commodities’ management is able to
adapt, should necessary.
METLEN aims to mitigate the effects that commodity price
fluctuations may have on its revenues and costs through hedging that
reflects both annual budget objectives and management’s strategy.
In this regard, Treasury & IR Central Function transacts in the
commodity markets by employing a number of different financial
products.
METLEN also ensures that hedging activities are conducted properly
through Financial Risk Management processes that outline
appropriate approval flows, communication lines, open position
monitoring activities, reconciliation activities and counterparty limits’
management.
In addition, the Treasury & IR Central Function performs a set of
stress scenarios (baseline & adverse) on its hedging portfolio to
assess and report the effect where a potential adverse price
movement may trigger margin calls thus creating liquidity risk.
Finally, the Treasury & IR Central Function presents monthly to
METLEN’s Financial Committee the developments in commodity
markets, potential price evolutions based on forecasts and analyses
from major market institutions, new hedging strategies and a
summary of current open positions.
R10 Credit
Risk Trend
A. Definition:
D. Risk Analysis:
5. Annual Board of Directors Management Report
62
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The organization does not manage effectively credit
incidents (e.g., default of counterparties, credit rating
downgrade, adverse credit market conditions).
B. Risk Appetite Statement:
We are subject to events such as default of customer,
credit rating downgrade, adverse credit market
conditions. We are willing to accept Medium levels of
Credit Risk, from engaging with customers and
counterparties established in various countries, in pursuit
of our strategic objectives, having regard to our policies
and procedures and a variety of limits.
C. Main Root Causes / Factors:
§ Lack of effective credit management and collections
policies and procedures.
§ Obsolete/ inadequate Information systems to
support the credit management process.
§ Lack of certain limits and criteria (e.g., credit rating)
regarding the exposure of the organization to each
counterparty.
Credit Risk entails the potential failure to effectively manage credit
incidents arising from METLEN’s business and financial market
transactions. In more detail, credit incidents and credit exposure may
arise from the sale activities of the Energy and Metals Sectors and the
subsidiaries, the trading transactions in derivatives and other
financial transactions such as deposits, loans, etc.
METLEN is exposed to credit risk through the possibility of a
counterparty default, a credit rating downgrade and/or an adverse
credit environment in general. As a result, credit risk related to non-
performance by customers, suppliers, and counterparties could
disrupt revenue and cash flows and increase the cost of collection,
settlement and replacement. Moreover, concentration on specific
counterparties, customers, suppliers or affiliated entities could have
a significant impact on METLEN’s financials in the rise of a credit
incident, thus exposing itself to reputational and operational risks as
well as to financial risks through an increase to spreads, unfavorable
prepayment obligations, borrowing terms and cost of financing.
Furthermore, credit risk could be realized through an inability to
efficiently collect receivables that would cause significant bad debt
expense and/or excessive days receivables outstanding.
Finally, if any factors of credit risk were to materialize, METLEN’s
financial condition, revenues and cashflows could be negatively
impacted.
E. Risk Treatment and Mitigation:
METLEN secures its access to sufficient debt funding sources and
builds strong relationships with lending institutions to meet future
obligations and manages effectively assets, liabilities and capital
requirements.
Furthermore, METLEN has Credit Risk policies and procedures in
place that guarantee transactions only with clients that are
characterized by appropriate creditworthiness. These policies are
accompanied by strict client selection criteria and by constant
monitoring of the credit granted to them.
In addition, Credit Risk is also managed/mitigated through credit
insurance policies with global insurance companies, receivables in
advance to a considerable degree, safeguarding claims by collateral
loans on customer reserves, receiving letters of guarantee and
quantitative and qualitative limits on cash reserves and cash
equivalents, derivatives, as well as other short term financial
products. Finally, METLEN monitors overdue amounts through
defined processes with clear roles and escalation protocols.
sis of Credit Risk
F. Further Analysis of Credit Risk
METLEN ENERGY & METALS GROUP
Past due
Non past due
Total
(Amounts in thousands €)
0-3 months
3-6 months
6-12 months
> 1 year
Liquidity Risk Analysis - Trade Receivables
2024
198,621
59,974
8,016
9,086
661,177
936,874
2023
114,274
8,468
4,861
43,553
842,245
1,013,401
5. Annual Board of Directors Management Report
63
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN ENERGY & METALS S.A.
Past due
Non past due
Total
(Amounts in thousands €)
0-3 months
3-6 months
6-12 months
> 1 year
Liquidity Risk Analysis - Trade Receivables
2024
166,183
23,068
7,980
28,586
344,540
570,357
2023
95,359
6,023
3,712
16,981
483,668
605,743
METLEN ENERGY & METALS GROUP
Group 31.12.2024
Gross Trade
Receivables
Expected credit
loss
Net trade
receivables
Average percentage of
expected credit loss
Non past due
662,510
1,333
661,177
0.20%
Past due less than 3 months
204,453
5,832
198,621
2.85%
Past due 3-6 months
66,357
6,383
59,974
9.62%
Past due 6-12 months
23,257
15,241
8,016
65.53%
Past due > 1 year
100,358
91,272
9,086
90.95%
Total
1,056,935
120,061
936,874
11.36%
METLEN ENERGY & METALS GROUP
Group 31.12.2023
Gross Trade
Receivables
Expected credit
loss
Net trade
receivables
Average percentage of
expected credit loss
Non past due
843,327
1,082
842,245
0.13%
Past due less than 3 months
120,276
6,002
114,274
4.99%
Past due 3-6 months
15,047
6,579
8,468
43.72%
Past due 6-12 months
20,297
15,436
4,861
76.05%
Past due > 1 year
105,921
62,368
43,553
58.88%
Total
1,104,868
91,467
1,013,401
8.28%
The below analysis of the balance of the Group’s trade receivables on 31.12.2024 and 31.12.2023 (per nature of trade receivable
item) as well as the simple average collection days (DSO, based on the annual Turnover) is shown in the following table:
Group
amounts in thousand €
2024
2023
T.R.
Trade Receivables
2,142,311
1,556,832
Out of which:
(a)
Related to advances given to Trade Creditors
338,886
208,321
Advances received from Customers in liabilities
(443,267)
(340,610)
(b)
Related to Revenue recognition (not yet invoiced)
866,551
335,112
Liabilities for invoiced but not yet recognised as revenue receivables
(146,828)
(185,068)
(c)
Related to payables (no offseting performed)
-
-
(d)
Related to EPC financing (secured)
-
-
Net Trade receivables (recurring basis), T.R. - a-b-c-d
936,874
1,013,399
TURNOVER
5,682,956
5,491,685
Simple calculated DSO (w/o VAT adjustments)
60.2
67.4
“Advances received from Customers in liabilities” & “Liabilities for invoiced but not yet recognised as revenue receivables” are
not taken into account in the calculation of the above index and are provided as informational elements.
5. Annual Board of Directors Management Report
64
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
R11 Interest Rates
Risk Trend
A. Definition:
The organization does not plan for or manage
fluctuating interest rates leading to financial loss.
B. Risk Appetite Statement:
Our appetite for Interest Rates Risk is Medium.
We seek to ensure efficient and effective
management of interest rate exposure by
implementing monitoring tools and using various
derivatives instruments, taking into consideration
fluctuations in interest rates.
C. Main Root Causes / Factors:
§ Lack of defined policies to provide guidance
for handling interest rate exposure.
§ Inability to identify timely optimal interest
rates in the marketplace, resulting in
unfavorable interest rate costs and returns
to the organization.
§ Exposure to rising interest rates.
D. Risk Analysis:
METLEN faces interest rate risk arising from balance sheet items, such as
liabilities (financing) and assets (deposits/investments), as well as from
project financing activities and financial derivative transactions.
Moreover, macro developments and policy decisions at a regulatory level
(e.g., European Central Bank) may affect METLEN’s exposure to interest rate
risk.
E. Risk Treatment and Mitigation:
METLEN has established a policy for the management of interest rate risk
arising from the assets and liabilities in its balance sheet. This policy includes:
a) in regard to assets, investment of its cash mainly in short-term time
deposits, so as to maintain the necessary liquidity while achieving
satisfactory return for its shareholders; b) in regard to liabilities, structuring
its funding portfolio in consideration of desired liabilities’ mix between fixed
and variable interest rates, market conditions, assessment of alternative
interest rate risk profiles and market products characteristics (duration,
type, etc.). This is achieved either through direct borrowing at a fixed rate
or through the employment of interest rate derivatives.
R12 Foreign exchange
Risk Trend
A. Definition:
The organization does not manage foreign
exchange exposures, such as contracts in which
the cash inflow and the cash outflow are in
different currencies or unfavorable fluctuations in
the currency of another market, leading to
financial loss.
B. Risk Appetite Statement:
The organization is exposed to fluctuations in
exchange rates (mainly USD) during business
operations, including sales/purchases of
aluminum and alumina, EPC contracts, natural gas
purchases. Our appetite for Foreign Exchange Risk
is medium and where possible foreign exchange
exposure is hedged.
D. Risk Analysis:
METLEN is exposed to Foreign Exchange Risk, through its business activities
that expand in various countries.
Failure to manage foreign exchange exposure, such as in contracts in which
the cash inflow and/or the cash outflow are denominated in different from
home currency or in case of unfavorable fluctuations in the pricing currency
of certain markets in which it trades, could lead to financial loss.
More specifically, METLEN’s foreign exchange exposure lies mainly with US
dollar and originates from commercial transactions in foreign currency and
from net investments in foreign entities, therefore changes in foreign
exchange rates could adversely impact cash flows, costs, projects’
profitability and eventually shareholder returns.
E. Risk Treatment and Mitigation:
METLEN aims to mitigate the effects that foreign exchange exposure may
have on its revenues and costs through hedging that reflects both annual
budget objectives and management’s strategy. In this regard, the Treasury
5. Annual Board of Directors Management Report
65
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
C. Main Root Causes / Factors:
§ Potential collapse of the currency in
countries where business is conducted will
expose the organization to loss.
§ Lack of technical knowledge and expertise to
manage Foreign Exchange Risk.
§ Lack of monitoring activities to capture and
manage unfavorable market, regulation, and
country changes/events that may affect the
volatility of foreign exchange rates.
§ Inability to identify foreign exchange
exposures derived from contracts where
Cash inflow and Cash outflow are in different
currencies.
& IR Central Function transacts in foreign exchange markets by employing a
number of different financial products.
METLEN also ensures that hedging activities are conducted properly through
Financial Risk Management processes that outline appropriate approval
flows, communication lines, open position monitoring activities,
reconciliation activities and counterparty limits’ management.
Finally, the Treasury & IR Central Function presents monthly to the Financial
Committee market developments that may impact METLEN’s foreign
exchange exposure, new hedging strategies and a summary of current open
positions.
R13 Liquidity
Risk Trend
A. Definition:
The organization does not manage and monitor
cash flows leading to cash shortages and inability
to cover obligations and achieve strategic
objectives.
B. Risk Appetite Statement:
Our appetite for Liquidity Risk is Low. It is our
policy to ensure that a minimum level of cash is
available at any given time.
C. Main Root Causes / Factors:
§ Lack of defined policies to manage and
optimize assets, liabilities and cash flows.
§ Inability to maintain adequate cash flow and
liquidity position (including credit lines).
§ Inability to manage long-term financial
liabilities.
§ Lack of monitoring payments made on a
daily basis.
§ Absence of cash flow analysis, inaccuracies in
cash flow projections and/or unauthorized
cash inflow / outflow is not identified.
§ Inability to meet obligations against
borrowers / suppliers due to ineffective Cash
flow management.
D. Risk Analysis:
Liquidity risk is related to METLEN’s need to finance its operations, meet
payment obligations, and borrow funds at an acceptable cost to support the
strategic transactions, and investment programs. In more detail, the risk may
arise from various sources and activities within the business model of
METLEN, such as inadequate cash flow management, business disruption,
increase in operational costs, unplanned capital expenditures, inadequate
management of working capital, inadequate monitoring of debt payments,
ineffective collection processes, etc. The effect of liquidity risk in case it
becomes material may be multi-dimensional, such as inability to meet
growing capital expansion plans, breaching bank loan terms and covenants,
failure to procure critical material/resources, mandatory prepayments of
outstanding loans, reduction of available credit lines, inability to pay wages,
etc. In addition, liquidity risk may affect METLEN evaluation by rating
agencies and thus increase the cost of financing its investment plans or limit
METLEN access to Capital Markets or alternative funding sources. On the
other hand, the effective management of liquidity risk is an integral part of
potential: a) improvement of net profitability through reduced interest
expense; b) implementation of METLEN business expansion initiatives
through the ability to secure financings with more competitive terms
(enhanced terms with financiers and suppliers); c) improvement of
METLEN’s credit standing & outlook from credit rating agencies, etc. As a
result, the relevant liquidity requirements are the subject of continuous
management through the meticulous monitoring of outstanding debt, of any
other long-term financial liabilities, and of cash inflows and outflows.
E. Risk Treatment and Mitigation:
METLEN ensures that except from the operating cash flows generated from
the operations of the group, there is sufficient liquidity comprising both from
the cash and cash equivalents held, as well as from available credit facilities
covering potential short-term business needs, and/or anticipated capital
expenditure.
More specifically, METLEN implements a diversification strategy in terms of
funding sources, including bank lending, bond issuance, project finance, and
trade finance services, which are further diversified in terms of duration and
interest rates.
Moreover, the Treasury & IR in co-operation with the Finance Central
Function ensure the timely monitoring and management of liquidity based
on the respective processes for developing, monitoring, updating, and
5. Annual Board of Directors Management Report
66
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
approving the Cash Plan, while evaluating long-term funding alternatives,
and managing credit lines and terms. In addition, METLEN monitors specific
indicators and trends to measure and identify key areas of liquidity risk such
as debt maturity profile, cost of debt, trade receivables, available credit lines,
overall liquidity evolution etc.
Finally, during the monthly Financial Committee, any developments
affecting METLEN's liquidity are presented, so they can be analyzed and
evaluated, and respective decisions for effective management of the
liquidity risk are taken.
F. Further Analysis of Liquidity Risk
The tables below summarise the maturity profile of the Group’s liabilities as at 31.12.2024 and 31.12.2023 respectively:
METLEN ENERGY & METALS GROUP
Liquidity Risk Analysis - Liabilities
(Amounts in thousands €)
2024
up to 6 months
6 to 12 months
1 to 5 years
after 5 years
Total
Long Term Loans
72,203
-
2,492,829
806,300
3,371,331
Short Term Loans
188,215
187,671
-
-
375,886
Trade and other payables
805,715
1,410,511
136,647
1,017
2,353,890
Other payables
-
-
113,276
-
113,276
Derivatives
29,185
14,631
6,103
-
49,919
Current portion of non - current liabilities
205,456
94,543
-
-
300,000
Total
1,300,774
1,707,356
2,748,855
807,317
6,564,302
Liquidity Risk Analysis - Liabilities
(Amounts in thousands €)
2023
up to 6 months
6 to 12 months
1 to 5 years
after 5 years
Total
Long Term Loans
-
-
1,232,403
779,906
2,012,308
Short Term Loans
348,532
6,433
7,530
-
362,495
Trade and other payables
1,168,391
400,086
3,916
898
1,573,291
Other payables
60,910
-
24,026
-
84,936
Derivatives
11,861
28,868
224
695
41,648
Current portion of non - current liabilities
27,354
527,049
-
-
554,403
Total
1,617,048
962,436
1,268,099
781,499
4,629,081
METLEN ENERGY & METALS S.A.
Liquidity Risk Analysis - Liabilities
(Amounts in thousands €)
2024
up to 6 months
6 to 12 months
1 to 5 years
after 5 years
Total
Long Term Loans
-
-
1,790,501
696,287
2,486,788
Short Term Loans
139,661
177,684
-
-
317,345
Trade and other payables
1,421,465
204,394
70,468
640
1,696,966
Other payables
20,631
-
25,522
-
46,153
Derivatives
14,344
11,395
3,152
-
28,891
Current portion of non - current liabilities
68,217
18,335
-
-
86,551
Total
1,664,318
411,807
1,889,642
696,927
4,662,694
5. Annual Board of Directors Management Report
67
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Liquidity Risk Analysis - Liabilities
(Amounts in thousands €)
2023
up to 6 months
6 to 12 months
1 to 5 years
after 5 years
Total
Long Term Loans
-
-
707,283
702,736
1,410,018
Short Term Loans
308,912
-
-
-
308,912
Trade and other payables
1,152,480
383,695
3,403
624
1,540,204
Other payables
44,657
-
-
-
44,657
Derivatives
11,861
22,554
79
-
34,493
Current portion of non - current liabilities
23,959
23,780
-
-
47,739
Total
1,541,869
430,029
710,765
703,360
3,386,024
Effect from risk factors and sensitivities analysis
The effect from the above mentioned factors to Group’s operating results, equity and net results as at 31.12.2024 and 31.12.2023
presented in the following table:
2024
2023
LME AL (Aluminium)
$/t
- 50
+ 50
-50
+50
EBITDA
m. €
(0.2)
0.2
0.2
(0.2)
Net Profit
m. €
(0.2)
0.2
0.2
(0.2)
Equity
m. €
(0.2)
0.2
0.2
(0.2)
API (Alumina)
$/t
- 10
+10
-10
+10
EBITDA
m. €
(0.8)
0.8
(0.3)
0.3
Net Profit
m. €
(0.8)
0.8
(0.3)
0.3
Equity
m. €
(0.8)
0.8
(0.3)
0.3
Exchange Rate €/$
€/$
-5%
+5%
-5%
+5%
EBITDA
m. €
(13.8)
13.6
(19.4)
19.3
Net Profit
m. €
(13.8)
13.6
(19.4)
19.3
Equity
m. €
(25.1)
24.9
(12.4)
12.3
Exchange Rate €/AUD
€/AUD
-5%
+5%
-5%
+5%
EBITDA
m. €
(10.3)
10.3
(8.0)
8.0
Net Profit
m. €
(10.3)
10.3
(8.0)
8.0
Equity
m. €
(7.2)
7.2
(5.6)
5.6
NG Price
€/MWh
- 5
+ 5
- 5
+ 5
EBITDA
m. €
8.9
(8.9)
12.8
(12.8)
Net Profit
m. €
8.9
(8.9)
12.8
(12.8)
Equity
m. €
8.9
(8.9)
12.8
(12.8)
CO
2
(€/t)
€/t
- 1
+ 1
- 1
+ 1
EBITDA
m. €
(1.1)
1.1
(0.7)
0.7
Net Profit
m. €
(1.1)
1.1
(0.7)
0.7
Equity
m. €
(1.1)
1.1
(0.7)
0.7
*The above analysis does not include the impact of tax.
5. Annual Board of Directors Management Report
68
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
D. Operational Risks
The following section provides an analysis of principal operational risks:
R14 People
Risk Trend
A. Definition:
The organization does not attract, recruit and
retain human resources to ensure achievement of
its goals and objectives, or fails to create positive
working environment due to lack of effective
communication with the work force or fails to
ensure the continuation of critical operations due
to insufficient succession planning.
B. Risk Appetite Statement:
We have a Low appetite for People Risk. Our
human capital is essential and it is our priority to
attract, hire and retain the appropriate talents, to
ensure a desirable working environment and an
effective labor relationship framework, as well as
to identify and develop future leaders.
C. Main Root Causes / Factors:
§ Inability to identify, develop and implement
effective succession plans.
§ Failure to attract, hire and retain talents who
possess the skills, knowledge, competencies,
and experiences needed.
§ Employee performance is not measured and
evaluated or rewarded properly.
D. Risk Analysis:
METLEN relies on its employees and talent to achieve its business, financial
targets and objectives. The ability to attract, develop, and retain a variety of
skilled employees with the right mix of soft and technical skills is critical to
maintaining our leading position in the market, compete and grow.
Low levels of employee engagement, high employee turnover rates, and
inability to create a positive working environment could lead to a loss of
“know-how” and skills, to business disruptions, affect the continuation of
critical operations due to insufficient succession planning, and reduce the
confidence within the market and among stakeholders.
In addition, the expansion of METLEN through acquisitions and its presence
in multiple geographical areas may create challenges to onboarding new
resources effectively, adjusting to societal expectations and norms, and
effectively communicating our mission and purpose.
If this risk were to materialize, it could adversely impact the success of
METLEN’s strategic objectives and threaten its reputation and the timely
achievement of its commitments.
E. Risk Treatment and Mitigation:
METLEN aims to provide a positive working environment that enables the
development of its employees. To achieve this objective and mitigate its
People Risk, METLEN has adopted and implemented the following:
· Defined Human Resources Policies and Procedures.
· The identification of critical positions within the organization and the
development of the corresponding succession plans.
· Recruitment practices that ensure the selection of suitable and
competent executives through meritocracy and equal treatment.
· The development of programs for formulating a uniform corporate
culture that is present across all levels of the workforce and acts as the
element that ensures cohesion and consensus in the efforts to realize
METLEN’s vision.
· The implementation of employee training and development programs
aimed at strengthening personal and technical skills and capabilities.
· The implementation of the year-long graduate programs, which give
young people the opportunity to receive training in real working
conditions and acquire working experience through their participation
in complex and demanding projects.
· The provision of incentives, in terms of compensation and benefits as
well as in terms of opportunities for advancement and development,
aimed to increase the employees’ commitment and retention.
· Regular performance reviews and feedback to enable employee
development and growth.
· Commitment to gender and generational balance and focus on offering
local opportunities.
· Promotion of the Code of Business Conduct to all personnel and
ensuring employee awareness, and avoidance of direct or indirect
discrimination in all work practices.
For additional analysis, refer to the Sustainability Statement section, S1 Own
Workforce.
5. Annual Board of Directors Management Report
69
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
R15 Project Planning & Execution
Risk Trend
A. Definition:
The organization does not monitor all critical
aspects for the effective/efficient completion and
delivery of projects, including budget, resourcing
aspects (e.g. staffing) as well as project aspects
such as key milestones, logistics, quality, and
product safety.
B. Risk Appetite Statement:
Our Appetite for Project Planning & Execution is
Low. We seek to ensure efficient and effective
planning and execution in order to deliver our
projects according to predefined cost, schedule
and quality.
C. Main Root Causes / Factors:
§ Cost and schedule overruns during the
execution of new projects or O&M activities
(e.g., industry 4.0, wind farms, photovoltaic
parks, CHP plant, etc.).
§ Delays in the delivery of the project.
§ Failure to effectively manage third parties’
non adherence to contract commitments
(project withdrawal).
D. Risk Analysis:
METLEN’s growth and expansion have led to a significant increase in the
volume and complexity of projects and partnerships with sub-contractors /
third parties. This expansion inherently raises METLEN's exposure to risks
associated with ineffective project management, planning, and execution.
Inefficient management could lead to delays, cost overruns, quality and
safety issues, all of which negatively affect project outcomes and client
satisfaction.
A failure to meet client expectations can escalate into legal disputes,
particularly over breached contractual terms, which may result in financial
penalties and strained business relationships. Moreover, delays or the
inability to deliver projects with significant exposure not only affect
immediate client relationships but also damage METLEN’s reputation. This
damage can erode trust and reliability in the market, potentially leading to
the loss of future business opportunities.
E. Risk Treatment and Mitigation:
Proper project execution and delivery is a main priority for METLEN, which
is achieved through a robust project planning and monitoring procedure and
long-term, strong business relationships with key stakeholders.
Planning, monitoring and reporting of project execution is achieved through
well-established and regularly reviewed and updated project management
processes.
METLEN clearly defines roles, responsibilities, milestones, and
corresponding tasks through the establishment of the projects’ governance
prior to their initiation, ensuring optimal competency mix in project teams
and timely planning. Furthermore, preliminary project review and project
planning include risk identification and assessment phases.
METLEN performs thorough assessments of its suppliers, subcontractors and
external partners before entering into any business agreement. Also,
processes are established to ensure that their performance is monitored
throughout the execution of the projects.
Moreover, project teams perform lessons learned reviews at the end of each
project to obtain an overview of the overall project execution and results
aiming to draw conclusions that would enhance future project performance.
R16 Operational Efficiency
Risk Trend
A. Definition:
Inadequate or failed internal processes that may
lead to equipment failure.
B. Risk Appetite Statement:
Our appetite for Operational Efficiency Risk is
Low. It is essential for production effectiveness
and efficiency to avoid as much as possible
interruption of production.
C. Main Root Causes / Factors:
§ Machinery or equipment breakdown.
§ Partial or full interruption of power supply.
§ Failure in CHP power generation plant.
D. Risk Analysis:
METLEN faces operational efficiency risks that challenge the effective
functioning of its power plants, with potential impacts on reliability,
performance, and cost-effectiveness. Inefficiencies in equipment
maintenance, for instance, can lead to higher operating costs, unplanned
outages, and reduced energy output. Delays in routine maintenance,
inadequate monitoring of critical systems, or reliance on outdated
technology can intensify these risks, resulting in equipment failures that
cause downtime and revenue loss. Over time, operational inefficiencies can
also accelerate equipment wear and tear, increasing asset depreciation and
inflating long-term operational costs. Given these types of risks, managing
operational efficiency is essential to ensuring the smooth operation of
METLEN’s power plants, meeting energy demand, and sustaining
profitability in a highly competitive market.
5. Annual Board of Directors Management Report
70
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
E. Risk Treatment and Mitigation:
METLEN manages operational efficiency risks through a comprehensive
approach that ensures the reliability and performance of its power plants.
Systemic monitoring, with alerts for regular, emergency, and critical
conditions, enables early identification and mitigation of potential issues.
Daily and monthly KPI tracking provides insights into plant availability and
supports data-driven decision-making. A robust Maintenance Plan,
combining preventive and reactive strategies, minimizes unplanned outages,
while insurance policies, such as Property Damage and Business Interruption
coverage, protect against financial impacts. Additionally, METLEN has
implemented a Contingency Plan and Disaster Recovery framework to
ensure business continuity during emergencies. These measures collectively
enhance plant efficiency, and safeguard profitability, reflecting METLEN’s
commitment to operational excellence and sustainability.
R17 Corporate governance & ICS
Risk Trend
A. Definition:
The organization does not establish effective
Corporate Governance and Internal Control
Systems (Policies, Procedures, Controls) that take
into account strategic targets and interests of
shareholders and stakeholders, thus impairing the
performance of the organization.
B. Risk Appetite Statement:
We have a Low appetite for Corporate
Governance and Internal Control System Risk. Our
strategy is to have a robust governance and
control framework with qualified Board members
and key committees, effective processes and
information flow.
C. Main Root Causes / Factors:
§ Non - compliance/explanation with
provisions of the UK Corporate Governance
Code unless the Company has decided
otherwise.
§ Board and Committee policies and processes
are not recorded or reviewed annually.
§ Inadequate or ineffective internal control
system resulting in additional audit
procedures and costs.
D. Risk Analysis:
As METLEN grows and faces greater regulatory scrutiny, compliance with
governance provisions, such as the UK Corporate Governance Code, and
effective governance by the Board of Directors become increasingly critical.
Failure to adhere to Governance provisions due to weak Board oversight,
insufficient director independence, or ineffective risk management can
expose METLEN to legal, financial and reputational risks.
Additionally, METLEN’s expansion increases operational complexity, raising
the risk of ineffective internal controls. Weak controls can lead to financial
inaccuracies, fraud, non-compliance, and poor decision-making. If not
addressed, these issues can escalate into regulatory penalties, material
misstatements, and reputational harm, eroding stakeholder confidence.
These governance and internal control system failures may undermine
investor confidence, profitability and growth, damage stakeholder trust, and
impact business relationships, ultimately affecting long-term growth and
sustainability.
E. Risk Treatment and Mitigation:
To effectively manage these risks, METLEN’s Board of Directors and its
Committees are composed of a diverse mix of skills, experiences, and
independent non-executive directors. The independent committee regularly
reviews the Board’s composition to assess the alignment with METLEN’s
strategic needs. Ongoing training ensures the Board stays informed on
governance best practices and their responsibilities. Annual evaluations
address any weaknesses in oversight, promoting continuous improvement
in decision-making.
METLEN employs a three lines model, with the second and third line applying
a unified, risk-based approach to identify, assess and manage risks. More
specifically, the Internal Audit Division provides independent and objective
assurance on the adequacy and effectiveness of governance, risk
management, and control processes. Additionally, the ERM Division
develops the risk management framework and collaborates with risk and
control owners to assess risks and design treatment strategies, ensuring
strong oversight and proactive management of Internal Controls.
Furthermore, the Compliance Division, through a comprehensive risk &
compliance framework, provides assurance and advisory services ensuring
adherence to regulatory requirements, internal policies, and ethical
standards. Finally, an annual assessment of policies and procedures, led by
5. Annual Board of Directors Management Report
71
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
the ERM Division, ensures that policies and processes are up to date and
reflect the business objectives.
E. Legal & Regulatory & Compliance Risks
The following section provides an analysis of principal legal & regulatory & compliance risks:
R18 Contractual
Risk Trend
A. Definition:
The organization or the counterparties fail to meet
contractual obligations, resulting in potential
legal accountability or litigation.
B. Risk Appetite Statement:
Our appetite for Contractual Risk is Low. We seek
to ensure that we sufficiently assess contractual
terms, fulfill our contractual obligations, monitor
the contractors' compliance and manage adverse
changes in contracts.
C. Main Root Causes / Factors:
§ Lack of personnel's "technical" competency
to address contracts' terms complexity and
requirements.
§ The organization fails to fulfill its contractual
obligations, exposing itself to litigation and
reputational damage.
§ The organization is unable to monitor the
contractors' compliance with Terms and
Conditions, exposing itself to financial loss.
E. Risk Analysis:
METLEN’s diversification of activities and global expansion have resulted in
an increased volume of business deals and contractual obligations with
partners, clients, and vendors, exposing it to contractual risks. These risks
may arise from ineffective internal processes, such as insufficient
engagement with end-users, incomplete review and assessment of contract
terms, inability to evaluate project complexity and risks, lack of monitoring
mechanisms to ensure conformance with contract terms, or inadequate
coordination between legal and business teams. Poorly negotiated or
ambiguous contract terms, such as those related to force majeure clauses,
change orders, or performance guarantees, can result in disputes, delays, or
financial losses, ultimately affecting project timelines, risk allocation, and
overall competitiveness.
Potential failure to manage contractual risk may affect METLEN in multiple
ways, trigger other risk categories, and significantly impact its overall risk
profile. More specifically, the contractual risk may create financial losses due
to revenue losses or cost overruns, damage METLEN reputation, affect its
bargaining power, lead to lawsuits and regulatory fines, and increase the
operational effort to manage this risk.
E. Risk Treatment and Mitigation:
For the effective management of contractual risk, METLEN has clear
thresholds/representations for contract signing to ensure that the interests
of the company and potential risks are covered. Moreover, through internal
processes, METLEN ensures the participation of the Legal, Contacts &
Compliance Central Function in the review and formulation of contractual
terms and conditions during the development of a new contract to secure
the legal aspects of the agreement properly.
However, in the case of complex cases and legal frameworks, METLEN is
supported by specialized legal firms to protect its interests.
Finally, the business sectors of METLEN, in cooperation with the Legal,
Contacts & Compliance Division, monitor the contract life cycle to prevent,
identify, and manage possible deviations from contract terms.
R19 Compliance
Risk Trend
A. Definition:
The organization does not monitor adherence to
its code of conduct and related internal policies,
local and European guidance, or regulatory
requirements, resulting in non-compliance.
B. Risk Appetite Statement:
Our appetite for Compliance Risk is Low. We seek
to ensure that we comply with our code of
conduct and related internal policies, local and
European regulatory requirements, taking into
D. Risk Analysis:
Compliance risk poses a significant challenge to METLEN as regulatory
expectations continue to grow, with new legal requirements being
introduced and a more aggressive enforcement stance adopted across
various markets. The evolving regulatory landscape demands that METLEN
adhere to a wide range of laws and standards, including anti-corruption,
anti-money laundering, global competition, human rights, data protection,
and economic sanctions. A failure to embed a robust business integrity
culture or a breach of these laws and company policies could result in
5. Annual Board of Directors Management Report
72
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
consideration the variability in compliance
frameworks in the various countries we operate.
C. Main Root Causes / Factors:
§ Absence of formal standards of employee
behavior intended to direct and influence
the way business is conducted.
§ Increased pressure to meet financial targets
could lead employees to go beyond legally
authorized actions and violate the principles
of the organization's code of conduct.
§ Non - compliance with the principles and
guidelines regarding market abuse inside
trading, Anti-Trust guidelines & regulations
§ Non-compliance with the principles and
guidelines regarding conflicts of interest.
§ Lack of whistleblowing process to
communicate possible cases of non-
adherence to compliance policies.
substantial financial penalties, operational disruptions, and reputational
damage.
Non-compliance could erode stakeholder trust, hinder access to global
markets, and lead to the loss of business opportunities. Moreover, the
complexity of navigating overlapping regulatory frameworks across
jurisdictions increases operational burdens and necessitates ongoing efforts
to enhance compliance systems, employee training, and monitoring
practices. These measures are critical to safeguarding METLEN's reputation
and maintaining its competitiveness in an increasingly regulated
environment.
E. Risk Treatment and Mitigation:
METLEN has implemented a comprehensive compliance framework to
address growing regulatory expectations and mitigate compliance risks
effectively. At the core of this framework is the establishment and
communication of a robust Code of Business Conduct, ensuring that all
employees understand their responsibilities and uphold the highest ethical
standards. This is further supported by a suite of well-defined policies,
including the Suppliers Business Conduct Policy, Market Abuse and
Competition Policy, Conflict of Interest Policy, and Anti-fraud, Anti-
corruption, and Anti-bribery Policy, among others. Additionally, the Anti-
Trust Policy and Sanctions Policy provide clear guidance for employees
navigating complex regulatory environments, while the Whistleblower
Policy establishes secure mechanisms for reporting misconduct, reinforcing
accountability at all levels.
METLEN has also implemented a robust third-party due diligence process,
supported by advanced technology and centralized oversight, to manage
risks associated with business partners and vendors effectively.
Furthermore, through its second line, METLEN maintains an assurance
program that ensures ongoing monitoring and validation of internal controls
related to compliance matters.
Finally, METLEN has developed comprehensive compliance training
programs that cover critical areas such as antitrust, sanctions, GDPR, and
anti-corruption. These training initiatives ensure that employees are well-
equipped to address compliance challenges and adapt to the evolving
regulatory landscape. By integrating these measures, METLEN fosters a
culture of integrity, safeguards its reputation, and ensures alignment with
regulatory standards.
For additional analysis, refer to the Sustainability Statement section, G1
Business Conduct.
5. Annual Board of Directors Management Report
73
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Group’s exposure to price risk and therefore (or) subsequent sensitivity may vary depending on the transaction volume and
the price level. The analysis reflects the nominal exposure to the above factors and does not include any effect from the use of
contracts/forwards through which the Group hedges its risk.
The Group, under Article 155 of Act 4548/2018, paid to the Hellenic Government, for the fiscal year ended on 31
st
of December
2024, an amount of €1,710 thousand.
The above amount relates to payments for fees from the exploitation of active, reserve, and inactive mining concessions by the
subsidiary companies DELFI DISTOMON A.M.E. and EUROPEAN BAUXITES SINGLE MEMBER S.A.
PAYMENTS REPORT TO GOVERNMENTS
VII.
5. Annual Board of Directors Management Report
74
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
BASIS OF PREPARATION
General basis for developing a sustainability statement [BP-1]
Preparation on a consolidated basis [ESRS2:BP-1_5_a] [ESRS2:BP-1_5_b_i]
This Sustainability Statement has been prepared on a consolidated basis and covers the parent company METLEN Energy &
Metals S.A. ("METLEN", formerly MYTILINEOS) and all subsidiaries and entities of the Group for the period 1 January to 31
December 2024. The scope of consolidation is fully aligned with METLEN's Consolidated Financial Statements for the same period
and includes the activities of the Energy and Metals business segments, as well as the construction and concessions segment,
with their respective subsidiaries, unless otherwise stated.
Moreover, METLEN Group's Sustainability Statement provides a comprehensive depiction of the adopted sustainable
development strategy, and the applied practices related to it, presenting the significant impacts of business activities, existing
and potential, in detail through a holistic approach, taking into account the interdependencies and the interconnection between
economic, social and environmental performance. The consolidation described ensures that the representation of business
activities and covered entities focuses on the adopted sustainable development model at Group level, capturing the material
impacts and related policies, actions, objectives and results on an integrated basis.
It has been drafted in accordance with Directive [(EU):2023/2772] on Corporate Sustainability Reporting Directive (CSRD) and
European Sustainability Reporting Standards (ESRS) and the relevant Greek Law incorporating the above Directive [Government
Gazette: 5164-12/12/2024]. At the same time, for disclosing entity-specific metrics other frameworks and initiatives were
considered, such as the GRI Standards. The specific GRI indicators utilized were primarily GRI 407-1, GRI 408-1, GRI 409-1, GRI
308-1, GRI 406-1, GRI 414-1, which are included in the sections S4 “Consumers and End Users” and G1 “Business Conduct” of the
Sustainability Statement.
In addition to the above, the Report has been prepared in accordance with the applicable requirements of Greek legislation and
the relevant European Directives, ensuring full compliance with the regulatory frameworks governing the issues contained within
the Sustainability Statement, at national and European level.
Upstream and downstream value chain [ESRS2:BP-1_5_c] [ESRS2:BP-1_AR_1]
In this Sustainability Statement, the information provided is expanded to comprehensively cover the significant impacts, risks
and opportunities arising from its business relationships in the upstream and downstream value chain. Based on the significance
assessment, METLEN presents data that reflects specific aspects of sustainable development in each segment of the value chain.
In the upstream value chain, METLEN has information in three key areas that affect responsible sourcing and the initial phase of
its operations:
a) Health and Safety (H&S) of employees and permanent subcontractors: The company ensures that cooperating
subcontractors and employees involved in early stages of production operate under safe and healthy working
conditions, incorporating appropriate protection policies and initiatives.
b) Responsible management of key suppliers: Applies responsible sourcing criteria that include compliance with
sustainable development principles, such as environmental sensitivity and social responsibility of its suppliers.
c) Business ethics of partners: Special emphasis is placed on the prevention of corruption and bribery, with the
introduction of strict rules and control mechanisms to defend transparency in its partnerships.
In the downstream value chain, METLEN covers a wider range of impacts and opportunities linked to customers, consumers and
local communities, focusing on:
a) Health and Safety (H&S) of employees and permanent subcontractors: As in the upstream chain, it ensures safe
working conditions and compliance with H&S standards in the partner companies and activities involved in final
production.
b) Responsible management of key suppliers: In product distribution and distribution, METLEN assesses the responsibility
of its key suppliers, ensuring quality and compliance with sustainability values.
GENERAL INFORMATION
XI.
5. Annual Board of Directors Management Report
75
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
c) Customer and consumer satisfaction: Presents measures implemented for the continuous monitoring of customer
experience, ensuring the quality of products and services, as well as the satisfaction of end users.
d) Creating value for local communities: Recognizing its social responsibility, METLEN develops initiatives that enhance
the economic development and prosperity of communities adjacent to its units, creating employment and social
benefits.
e) Partner Business Ethics: The business ensures that its partners operate in accordance with principles of transparency
and integrity by implementing anti-corruption and anti-bribery policies.
Omission of specific information [ESRS2:BP-1_5_d]
The exploitation of new technological capabilities and applications, as well as the company's participation in co-funded research
and innovation projects are adequately presented within this sustainability statement. More specifically, chapter E5 – Circular
Economy reflects the relevant initiatives and actions of the Metals Sector, while chapter S4 – Consumers and end-users the
corresponding ones of the Energy Sector. The results of the research programs are limited and only if they are implemented for
utilization by the Company. At the same time, METLEN is constantly examining the possibilities of designing and developing new
business activities with a focus on its maximum contribution to sustainable development.
Special Circumstances [BP-2]
Time horizon [ESRS2:BP-2_9_a]
The company, when preparing its Sustainability Statement, has not deviated from the specified time horizons set out in ESRS 1,
Section 6.4 for the short, medium and long term. In particular, the company adopts the following:
a. For the short term, it follows the reference period used in the financial statements, i.e. the end of each annual accounting
period.
b. For the medium term, it adopts the time period extending from the end of the short-term period to five (5) years.
c. For the long term, it refers to time intervals exceeding five (5) years.
The undertaking declares that there are no special circumstances or circumstances that have led to a deviation from the above
time periods, as defined in ESRS 1. Adherence to predefined definitions and time horizons underscores the company's
commitment to compliance with international reporting practices, transparency and accuracy in reporting. In addition, the
company remains committed to ensuring that these time horizons are fully aligned with its sustainability strategy and long-term
business commitments. However, for chapter E1 – Climate Change which adopts the guidelines of the TCFD (Task Force on
Climate-related Financial Disclosures), the time horizons taken into account are defined as follows: a) Short-term: 1-5 years, b)
Medium-term: 5-10 years, c) Long-term: 10+ years
Measurement Indicators [ESRS2:BP-2_10_a] [ESRS2:BP-2_10_b] [ESRS2:BP-2_10_c] [ESRS2:BP-2_10_d]
The indicators presented within the DB are also used in the context of compliance with certified systems, as well as reports
submitted to the competent authorities in the context of licensing and compliance with obligations that ensure the responsible
operation of the Company. As such, these indicators do not exclusively serve the Sustainability Statement, but constitute the
overall framework for monitoring and managing the issues (IROs) identified through the double materiality process. The basis for
compiling the reported data shall be based on readily available and fully verifiable primary data collected within the undertaking.
Where measurement indicators based on data from indirect sources, such as domain average data or other proxies, are applied;
including estimates of data related to the upstream and/or downstream value chain, a clear reference is being made. The
Company constantly examines the maturity of the methodologies followed in order to be able to undertake further actions to
improve their accuracy and completeness, seeking maximum alignment with the applicable specifications and requirements of
the ESRS Standards.
Sources of estimation and uncertainty of outcome [ESRS2:BP-2_11_a] [ESRS2:BP-2_11_b]
When considering the level of maturity of measurement methodologies, a number of key uncertainty assumptions are identified
including:
a) reliance on future events, such as changes in legislation or measurement technologies, that may affect future data capture;
b) use of specific measurement techniques, such as calculation models for indirect carbon emissions or biodiversity impact
assessment, which involve statistical assumptions and uncertainties;
c) quality and availability of data from the upstream and downstream value chain, as information coming from third parties
(e.g. suppliers or customers) may be of limited accuracy or subject to different methodological approaches;
5. Annual Board of Directors Management Report
76
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
d) complexity in data collection and any future changes to estimation methodologies.
In addition, financial amounts resulting from relevant environmental impact assessments or possible future compliance costs
may be subject to fluctuations, depending on the provisions of local national laws, with which the Company must adapt.
In its measurement procedures, the Company applies commonly accepted methodologies and assumptions, such as the use of
emission factors based on the GHG Protocol for the valuation of Scope 3 emissions or the application of models based on historical
data to predict environmental impacts. At the same time, where necessary, internal sensitivity analyses are carried out to improve
the accuracy of estimates, while a wide range of disclosed data is also ensured externally. At the same time, the Company
recognizes that measurement uncertainties can affect the overall reliability of disclosures. Through risk identification processes,
areas of uncertainty are identified as well as possible events that could affect the achievement of its objectives. To address these
issues, every risk is attributed to a "Risk Owner," enhancing accountability and improving data.
ESRS
METRIC
SOURCE OF UNCERTAINTY
ASSUMPTION WHEN MEASURING THE
INDICATOR
Ε1
Scope 2 GHG
emissions
In calculating Scope 2 emissions, the company relies
mainly on actual electricity consumption data.
However, due to delays in the issuance of bills by
suppliers, consumption in the last month of the year is
not always available at the time of the annual report.
In these cases, the company uses consumption
estimates, based either on historical data or on
consumption trends of previous months. This
approach may lead to small discrepancies
between the final actual emissions and the
emissions reported in the sustainability
statement.
Ε1
Scope 3 GHG
emissions
In calculating Scope 3 emissions, there are factors that
introduce a degree of uncertainty into the results.
First, the non-use of raw data in several Scope 3
categories means that calculations are mainly based
on secondary data and emission factors from general
sources. This can lead to discrepancies between actual
emissions and recorded estimates. Second, certain
subsidiaries do not yet have fully developed emission
measurement and reporting systems, thus affecting
the accuracy of the data collected by them. Third, the
integration of new companies from METLEN, which
had no previous experience in measuring Scope 3
emissions, adds an additional uncertainty factor, as the
process of data collection and implementation of the
methodology is maturing. Last, for the calculation of
certain Scope 3 GHG emissions categories, previous
years’ emission factors were utilised.
Methodology as described in the relevant
section.
Ε3
Water Consumption
Lack of availability of the exact amount of seawater
discharge from the combined steam and energy plant.
Assumption that the amount of seawater
pumped is the same as that discarded
S1
Own Workforce
Remuneration
Metrics
For calculating these metrics, METLEN estimates based
on assumptions the sum of benefits in cash, benefits in
kind and total fair value of all annual long-term
incentives of its employees.
For fixed compensation the approach included
annualizing the December base salaries. Variable
compensation calculation included using target
values for the Short Term Incentive Plans, while
for Long Term Incentive Plans, the share price on
the day of provision was used. Lastly, for
calculating benefits, the relevant Benefits Policy
thresholds were utilised for estimations
performed.
Changes in the preparation or presentation of sustainability information [ESRS2:BP-2_13]
Given METLEN's long tradition of disclosing Sustainability and ESG Performance Reports, based on internationally accepted
standards and guidelines, the accuracy and consistency of the disclosed data is ensured, including the need for any changes or
corrections to published indicators and measurable results. For indicators published in previous reporting periods, an internal
audit shall be carried out for any variations, in order to apply the relevant justification and revision procedures where necessary.
Conversely, for new indicators first published in 2024 under the ESRS Standards, there is no need to justify changes, disclose
5. Annual Board of Directors Management Report
77
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
revised comparative data or highlight differences with previous disclosures. This approach ensures transparency and reliability
of reported data, while laying the groundwork for consistent application of new reporting standards.
Reporting errors in prior periods
Metlen had identified errors in the previous reporting periods and discloses them in the following table:
Metric
Nature of the error
Correction
Explanation
Disclosures resulting from other legislation or generally accepted sustainability statements [ESRS2:BP-2_15]
Following the requirements of the ESRS Standards, METLEN incorporates elements and sustainability information arising from
other legislative requirements, regulatory obligations and internationally accepted sustainability reporting standards and
frameworks into its Sustainability Statement. This information shall be included and presented in a way that allows a clear
distinction to be made between the requirements of the ESRS and the other partially implemented standards by providing
references to paragraphs of the standard or box in all chapters of the Sustainability Statement, with a view to facilitating the
identification of the indicators covered. At the same time, for a fuller understanding of the adopted standards and the reporting
process, Annexes and scoreboards to all adopted standards are included at the end of the Sustainability Statement, which present
in detail the indicators used, providing the possibility of a concise overview of the published data in order to take into account
and understand METLEN's sustainable development information.
Embedding information by reference [ESRS2:BP-2_16]
The Sustainability Statement incorporates certain information by reference to other reports or published documents of the
Company available on its website. In the Appendices section at the end of the Sustainability Statement, a list of ESRS disclosure
requirements and dedicated data points incorporated by reference is provided. That list shall include the corresponding
references to those parts and paragraphs of reports or documents where the information has already been made public, ensuring
clarity and transparency in the disclosure process. Citation reference of CapEx & OpEx.
ESRS
DISCLOSURE REQUIREMENT
ASSUMPTION WHEN MEASURING THE INDICATOR
SBM-1
Strategy, business model and value chain
Chapter 2. Annual Management Report of the Board of Directors
Section 2.2 Strategic Priorities & Business Model
Section 2.3 Value Chain (ENERGY & METALS)
GOV-1
The role of administrative, management and supervisory
bodies (paragraphs 20 and 21 of ESRS 2)
Chapter 4. Corporate Governance Statement
(Principles Α, B, D, Ε, F, G, Η, Provisions 9, 10, 11, 12, 13, 14, &
Chapter 2.2.)
GOV-1
The role of Management in the assessment and
management of risks and opportunities related to
business conduct.
Chapter 4. Corporate Corporate Governance Statement
Governance Statement
GOV-2
The role of Management in the assessment and
management of risks and opportunities related to
business conduct.
Chapter 4. Corporate Governance Statement (Chapter 3)
GOV-3
Mainstreaming sustainability-related performance into
incentive schemes (paragraph 26 of ESRS 2)
Chapter 4. Corporate Governance Statement (Provision 41)
Use of phasing-in provisions [ESRS2:BP-2_17]
METLEN has not omitted information required by the ESRS E4, ESRS S1, ESRS S2, ESRS S3 and ESRS S4 standards, ensuring full
disclosure of material sustainability issues in accordance with the Company's double materiality assessment. However, METLEN
has adopted transitional provisions to anticipate and manage financial effects as outlined in SBM-3 and value chain reporting.
GOVERNANCE
1. The role of administrative, management and supervisory bodies [ESRS2:GOV-1]
5. Annual Board of Directors Management Report
78
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The information required under paragraphs 20 and 21 of ESRS 2 is covered in Principles A, B, D, E, F, G, H, Clauses 9, 10, 11, 12,
13, 14, and Chapter 2.2. of the Corporate Governance Statement, which is disclosed in Chapter 4. of this IR. [ESRS2:GOV-1_21]
[ESRS2:GOV-1_22] [ESRS2:GOV-1_23]
The role of Management in assessing and managing climate-related risks and opportunities
METLEN has developed specific organizational structures to support management in tackling climate issues, such as special
committees, divisions and teams, which are aligned with the Company's strategic priorities. The Corporate Governance and
Sustainable Development General Division, having a critical, supportive and coordinating role, works closely with all Sectors and
key subsidiaries of the Company. It identifies strategic priorities in the management of climate-related issues and coordinating
relevant initiatives. Meanwhile, it informs and supports the work of the Sustainability Committee, in the context of updating the
Board of Directors, on tackling climate change (potential/existing and negative/positive impacts, climate targets and CO
2
emission
reduction actions), and participates in the special committees of Sectors, cooperating with each Management and their
Sustainability Managers to present climate-related issues, when necessary. [ESRS2:GOV-1_22_c]
The Management of each Sector and of key subsidiaries have overall responsibility to identify and assess climate risks as
determined by the Company's central Business Risk assessment system. The Corporate Governance and Sustainable
Development General Division works closely with the sustainable development teams and their heads appointed in each Sector
and in key subsidiaries, to monitor the implementation of CO
2
emission reduction initiatives and the achievement of climate
targets. Furthermore, the heads of sustainable development teams have on their part, and in line with the specific characteristics
of their Sector or subsidiary, appointed responsible persons for each ESG pillar with whom they are in constant communication
and cooperation. The persons responsible for the environmental pillar coordinate and collaborate with persons responsible for
implementing specific climate initiatives. They provide technical guidance for the development of relevant action plans and
implementation of specific projects, the progress of which is discussed in specific working meetings with the Company's central
Sustainable Development Division on a quarterly basis. [ESRS2:GOV-1_22_c]
Meanwhile, METLEN continues to align its core operational processes to address climate change. For instance, there are
procedures directly or indirectly related to the process of informing Management on climate-related issues:
a) The process of raising capital with the introduction of the "METLEN Green Finance Framework", for financing projects that
contribute both to meeting corporate climate targets and commitments and to the energy transition in general, according
to which the Company may issue one or more Green Bonds.
b) Linking top management remuneration to KPIs linked to the evolution of CO
2
emissions.
c) Introducing climate-related data in the evaluation of key suppliers.
5. Annual Board of Directors Management Report
79
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
d) The systematic enhancement of the correlation of the Sustainable Development information disclosures with financial
data, by integrating hybrid key intensity indicators.
The role of Management in the assessment and management of risks and opportunities related to business conduct.
The relevant information on the role of the Board of Directors in shaping and supervising business conduct is included in the
Corporate Governance Statement (see Chapter 4 of this IR), in accordance with the requirements of ESRS 2 GOV-1
2. Information received and sustainability issues addressed by the company's administrative, management and supervisory
bodies [ESRS2:GOV-2]
The information required under paragraph 26 of ESRS 2 is covered in Chapter 3. of the Corporate Governance Statement, which
is disclosed in Chapter 4. of this IR. [ESRS2:GOV-2_26]
Board of Directors’ oversight on climate-related risks and opportunities
At METLEN, the Board of Directors’ Sustainability Committee
10
is responsible for overseeing sustainable development issues. The
Committee assists the Board of Directors in integrating sustainable development considerations into the Company's key decision-
making processes and functions, including negative or positive climate-related impacts. The Committee oversees and monitors
the implementation of the corporate Sustainable Development strategy, at all three levels [Climate Change Response, ESG
Approach and Responsible Entrepreneurship], in accordance with domestic and international trends that may affect the
Company's business activities and performance. [ESRS2:GOV-1_20_a]
The Sustainability Committee (SC) meets at least three times a year, and more often, if required. At meetings, the SC discusses
and defines Sustainable Development strategy issues, assesses overall progress, approves sustainable development reports,
monitors the Company's ESG assessments and performance, validates new policies, approves related measures and initiatives,
and makes recommendations for action to the Board, when required. In this context, the SC is annually updated on and discusses
the results of the impact assessment of the Company's activity on Sustainable Development, including climate change. Is also
biannually monitors the progress made in achieving climate targets and in the implementation of the Company's relevant CO
2
emission reduction initiatives, following relevant updates by the Corporate Governance and Sustainable Development General
Division. The SC then forwards these issues to the Board of Directors for information and discussion. Furthermore, the Committee
monitors the Company's progress in actions or other important climate initiatives that the Company participates in or
implements, such as:
a) submission of data based on EU Taxonomy.
b) alignment with TCFD recommendations,
c) participation in the international CDP Climate Change initiative,
d) recording and disclosure of indirect CO
2
emissions (scope 3).
Finally, the Board of Directors has approved the Company's climate targets and is informed on their implementation by the
Sustainability Committee, with reference to specific performance indicators, as mentioned above. Meanwhile, the process of
preparing annual budgets and business plans, approved by the BoD, includes investments related to key carbon emission
reduction initiatives such as the development of an RES plan and the strengthening of secondary cast aluminium production. In
addition, the BoD is informed, through the annual business risk assessment report, upon recommendation of the Audit
Committee, on the level of climate risks, and in Q4 of 2024 approved the issuance of a Green Bond for investments in renewable
energy, energy storage and circular economy projects that will contribute overall to tackling climate change and promoting the
energy transition. [ESRS2:GOV-2_26_b]
3. Integration of sustainability-related performance into incentive schemes [ESRS2:GOV-3]
The information required under paragraph 26 of ESRS 2 is covered in Clause 41 of the Corporate Governance Statement, which
is disclosed in Chapter 4. of this IR. [ESRS2:GOV-3_29]
10
As described in the Corporate Governance Statement Section of this Report
5. Annual Board of Directors Management Report
80
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
At METLEN, the remuneration of the executive members of the Board of Directors is indirectly linked to the Company's climate
targets (Non-executive members do not receive variable remuneration). METLEN has chosen a specific climate parameter (CO
2
Emissions (scopes 1 & 2) /€ million net profit) to account for the variable remuneration of executive Board members and to
ensure that their remuneration is linked to environmental issues. This parameter reflects the Company's efficiency in reducing
CO
2
emissions in relation to its financial performance and ensures that Board members' remuneration is linked to environmental
issues. For the reporting year, the percentage of remuneration related to climate parameters is 2.64 % of the total variable
remuneration of the Company’s executive Board members. [E1:GOV-3_13]
4. Due Diligence [ESRS2:GOV-4]
METLEN follows a systematic due diligence approach to environmental impact, in line with the OECD Guidelines for Multinational
Enterprises on Responsible Business Conduct. This approach includes a series of steps aimed at identifying, assessing and
mitigating the negative environmental impacts that may result from the Company's activities, products and services. The main
goal is to improve environmental performance, to fully comply with national and international requirements, as well as to foster
responsible entrepreneurship and sustainable development. The approach includes the following key steps: [ESRS2:GOV-4_30]
1. Establish Environmental Management Systems (as presented and analyzed in the following ESRS sections: E1.IRO-1,
ESRS: E2.IRO-1, ESRS:E3.IRO-1, ESRS:E4.IRO-1, ESRS:E5.IRO-1).
2. Identify and assess the negative environmental impacts associated with activities, products and services, including
where activities are likely to have material negative environmental impacts, by performing appropriate analyses of
environmental impact assessments (as presented and analyzed in the following ESRS sections: E1.SBM-3, ESRS:
E2.SBM-3, ESRS: E3.SBM-3, ESRS: E4.SBM-3, ESRS:E5.SBM-3).
3. Establish and implement internal measurable targets, goals and strategies to address negative environmental impacts
and improve environmental performance. Targets are based on scientific assumptions, compatible with national
policies and international commitments and guided by best practices (as presented and analyzed in the following ESRS
sections: E1-4, ESRS: E2-3, ESRS: E3-3, ESRS:E4-4, ESRS:E5-3).
4. Verify the effectiveness of strategic approaches at regular intervals and monitor the progress of environmental targets,
along with periodic review of relevant policies when and where necessary (as presented and analyzed in the following
ESRS sections: E1-1, ESRS: E2-1, ESRS: E3-1, ESRS:E4-1, ESRS:E5-1).
5. Restore or mitigate negative environmental impacts by developing and implementing specific actions and leveraging the
Company's influence to steer the value chain partners in this direction (as presented and analyzed in the following ESRS
sections:E1-2, ESRS: E2-2, ESRS: E3-2, ESRS: E4-2, ESRS: E5-2, ESRS:G1-2).
6. Conduct a meaningful consultation with stakeholders affected by the environmental impact of its activities (as presented
and analyzed in the following ESRS2 sections: SBM-2, ESRS: E1.IRO-1, ESRS: E2.IRO-1, ESRS: E3.IRO-1, ESRS:E4.IRO-1,
ESRS:E5.IRO-1).
7. Maintain emergency plans to prevent, mitigate and control serious environmental and health damage (as presented and
analyzed in the following ESRS sections:E2-2, ESRS:E4-2).
8. Collaborate with scientific organisations and third parties to adopt more environmentally friendly technologies and
develop products that do not cause negative environmental impacts (as presented and analysed in the following ESRS
sections:E1-3, ESRS:E5-2).
9. Provide education and training to direct and indirect employees on environmental management, environmental
accident prevention and safe management of materials and waste to avoid pollution (as presented and analysed in the
following ESRS sections: S1-2, ESRS:S1-4, ESRS:S2-3, ESRS:S2-4).
5. Centralized internal control mechanisms [ESRS2:GOV-5]
METLEN applies a specific sustainable development governance system that covers the entire Group and operates to monitor
the actions and practices implemented to meet the targets set. At the top of this system is the Company's Sustainability
Committee
11
, which reports to the Board of Directors providing feedback on the Company's performance on its environmental
and social goals. [ESRS2:GOV-5_36_d]
At the same time, the Audit Committee plays a prominent role within METLEN’s governance system, and approves all procedures
related to the internal audit of the Group’s listed parent entity. The Internal Audit Division (IAD), which reports to the Audit
Committee, has overall responsibility for implementation of internal audit in the Company and in non-listed entities. The Internal
Audit Division (IAD) monitors and makes recommendations to improve the operations and policies related to the Internal Audit
11
The results of the central stakeholder consultations, as well as the performance against sustainability targets, are periodically submitted to the Sustainability
Committee and, by extension, to the Company's Board of Directors to assess progress and take possible corrective measures
5. Annual Board of Directors Management Report
81
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
System, providing assurance on the effectiveness of the implementation of corporate procedures. The audit schedule prepared
includes the assessment of the management of the Company's impact on sustainable development, to identify priorities that will
lead to improving the approach to achieving its strategic objectives.
In this context, the IAD started preparing for the task as early as the second half of 2023, with a thorough analysis of the internal
level of maturity in meeting the requirements of the horizontal ESRS-2 standard. Subsequently, in 2024, the analysis extended to
the double materiality assessment procedures, the digital applications and platforms for collecting quantitative and qualitative
data and ESG data, as well as the observance of the relevant Procedures for the overall management of the Company's sustainable
development framework. As a result of this analysis, the IAD produced a final report reflecting the adequacy of METLEN.
In particular, the IAD assessments focus on the degree of suitability in managing requirements, as well as on the compliance of
the Company's executives with such requirements, in order to bring about improvements in procedures capable of contributing
to the continuous improvement of the administrative approach and ultimately to the enhancement of economic effectiveness.
To monitor its financial performance, METLEN uses central hybrid key performance indicators (KPIs) that capture its
environmental and social impact.
The activities aimed at reducing the identified risks associated with the disclosure of sustainability information are ongoing and
are gradually implemented by the Company's support organizational units as part of their operational responsibility. Key risk
mitigation activities put in place included consistency checks, gap analysis, discrepancy analysis compared to the previous year
and discrepancy investigation. As part of these mitigation activities, an audit process is in place, which is now part of the
established internal control process. Also, further mitigation actions and their formal standardisation have already been assessed
by the Internal Audit function as part of the implementation process towards full implementation from early 2025.
The Internal Audit Division's conclusions reports support the work of external assurance, ensuring the high level of
transparency and reliability of the Company's non-financial disclosures. METLEN has been publishing annual reports for more
than 15 years reflecting the progress on the objectives of Materiality topics, which now result from the Double Materiality
process. These reports include performance indicators related to environmental, social and governance issues. To ensure the
reliability of the approach, reports and data are subject to review by external experts, who assess the quality and accuracy of
the information disclosed. This practice has been established by the Company as a standard practice over the years, with the
aim of continuously improving the externally assured sustainable development reports.
Starting in 2025, the Internal Audit function will integrate sustainability reporting and follow-up into its standard process,
following an approach similar to that used for the rest of the Company's Audits. The Audit Committee, which is responsible for
evaluating the effectiveness of internal audit, cooperates with the Sustainable Development Committee to monitor the
implementation of the audit program and procedures aimed at improving the reliability and control of sustainable development
data and reporting processes.
5. Annual Board of Directors Management Report
82
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Strategy, business model and value chain
Information on SBM-1 coverage is presented in chapters 2.2 Strategic priorities & Business model and 2.3 Value chain (ENERGY
& METALS) within Chapter 2. Annual Management Report of the BoD.
Interests and views of stakeholders [ESRS2:SBM-2]
METLEN's relations and cooperation with its Social Partner groups are building blocks of its Sustainable Development strategy.
They contribute to the further understanding of the impact of its activities, as well as to the Company's effort to consistently
meet their expectations, building mutual relationships of trust with them.
1. Social Partner Groups [ESRS2:SBM_2_45_a_i]
METLEN, due to its multidimensional business activity, cooperates with a wide range of individuals, institutions, organizations,
authorities, companies and communities that constitute its Social Partners. The process of recognizing them and classifying them
into specific groups is based on specific criteria,
12
according to the international standard AA1000 Stakeholder Engagement 2015
per Business Sector.
The Social Partners of METLEN consist of the following groups:
1. Employees
7. Financial Institutions
2. Investment community
8. Business Entities
3. Partners & Suppliers
9. Regulatory & Sustainable Development Bodies
4. Consumers and end-users
10. Academic Community
5. Local Communities (Local
Government)
11. Press Representatives
6. Central Government Bodies
12. NGOs & voluntary organizations
2. How to work with Social Partner groups [ESRS2:SBM_2_45_a_ii]
METLEN has a variety of ways of cooperating with its partner groups, the frequency of which derives from the type of relationship
it has developed with each group. The formal and informal forms of communication and cooperation with the groups of social
partners available to the Company, as mentioned in the table below, are governed by the specific characteristics of each Branch
of Activity and Central Service, with the ultimate aim of enhancing trust and consequently social acceptance of its operation.
Groups
Social Partners
Timeless ways
Communication & Cooperation
Employees
1. Annual Consultation Institution with the Social Partners*
2. Annual employee engagement survey
3. Annual institutionalized process for evaluating the performance and skills of employees
4. Open daily communication with all human resources through the role of HR-Business Partner
5. Continuous implementation of education and training programs
6. Disclose policies when required
7. Regular and extraordinary meetings between management and employees (annual institution of
hierarchical workshops of the Metallurgy Sector, annual meetings of the Management with employees
per group of 25 people)
8. Announcements via online intranet platform
9. Telephone line for employee service (HR Call Center)
10. Annual IR Report
12
such as: dependence, responsibility, tension, influence and perspective.
5. Annual Board of Directors Management Report
83
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Investment
community
(Shareholders
– Investors –
Financial
analysts)
1. Annual Ordinary and Extraordinary General Meetings of Shareholders
2. Annual & Half-Year results (Press Release, presentation, teleconference, Company website).
Quarterly results (Press Release, Company website)
3. Conferences, Roadshows, Meetings & Calls of the Investor Relations Division with institutional
investors
4. Corporate Governance Roadshow: Shareholder engagement with the stewardship teams of
investors and proxy advisors
5. Annual Consultation Institution with the Social Partners*
6. Business Announcements (Press Releases, Internet)
7. Annual meeting with analysts
8. Ability to contact the shareholder service directly
9. Annual IR Report
Partners &
Suppliers
1. Annual Consultation Institution with the Social Partners*
2. Regular communication (even on a daily basis) through the purchasing departments of the
Company's Business Sectors
3. Promotion of METLEN's "Code of Conduct for Suppliers and Partners" & "Responsible Supply Chain
Policy"
4. Annual ESG assessment of key suppliers
5. Key suppliers training program
6. Annual IR Report
Consumers and
end-users
1. Promotion and information on products and services (continuous communication of the relevant
departments)
2. Annual Consultation Institution with the Social Partners*
3. Daily communication through the Company's Commercial Divisions
4. Cooperation in the context of the implementation of annual customer satisfaction surveys
5. Annual IR Report
Local
Communities
(Local
Government) &
Central
Government
Bodies
1. Annual Consultation Institution with the Social Partners*
2. Regular and emergency communication (open door policy, meetings, participation in local events
or consultations whenever necessary)
3. Communication on an annual basis in the context of the implementation of METLEN's Social Policy
4. Process for the Management of Requests & Complaints from Third Parties on ESG & Corporate
Responsibility issues from the Aluminium plant of Greece & bauxite mining activities
5. Consultation, Communication, Stakeholder Participation and Complaints Procedures for Energy
Centers
6. Through our company's website, in the "Contact Us" section
7. Annual IR Report
8. Participation in consultations on draft laws and other decisions
9. Participation in events of the institutions
Business
Entities
1. Annual Consultation Institution with the Social Partners *
2. Communication on an annual basis (providing data and information, meetings, participation in
consultations)
3. Participation in events whenever necessary
4. Annual IR Report
Regulatory &
Sustainable
Development
Bodies
1. Annual Consultation Institution with the Social Partners*
2. Regular and ad hoc communication (provision of data and information through submission of
predefined by law reports and measurements on corporate activities, questionnaires, meetings,
participation in consultations, whenever requested)
3. Participation in events of the institutions on an annual basis
4. Annual IR Report
Αcademic
Community
1. Annual Consultation Institution with the Social Partners*
2. Collaborations on an annual basis in the context of the implementation of research programs and
the implementation of the Company's social policy
3. Participation in career events & career days at universities
4. Annual IR Report
5. Annual Board of Directors Management Report
84
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Press
representatives
1. Annual Consultation Institution with the Social Partners*
2. Direct daily communication through METLEN's Communication Department on issues related to
the Company's fields of activity
3. Notification of business developments (Press Releases, Internet communication, newsletters, etc.)
4. Organization of briefing meetings with Greek and foreign journalists at regular intervals and
whenever necessary
5. Arrange meetings with analysts
6. Annual IR Report
NGOs &
Voluntary
Organizations
1. Annual Consultation Institution with the Social Partners*
2. Annual open dialogue meeting focusing on the development of relations
3. Electronic platform for the submission of social requests available throughout the year
4. Meetings with NGO representatives, whenever necessary, as a result of the evaluation of their
requests
5. Annual IR Report
Financial
Institutions
1. Contact once a year to check and review credit limits and special terms of cooperation
2. Daily communication on banking, financial instruments management and risk management
3. Regular and extraordinary communication to request new credit lines, improve information,
provide data, negotiate contracts and resolve day-to-day procedural issues
4. Periodic communication for consulting services
5. Periodic completion and updating of the ESG questionnaire concerning relations with various
banks
6. Attend events, phone meetings, or business lunches when necessary
7. Annual consultation of social partners
8. Annual IR Report
* The participation of the team in this specific form of collaboration depends on the type of consultation (local or central) as well
as its thematic focus.
3. The Institution of Consultation of Social Partners [ESRS2:SBM_2_45_a_iii]
The Social Partners Consultation Institution is the practical implementation of METLEN's long-standing commitment to
responsible entrepreneurship and open, systematic and honest social dialogue, which is a key element of the social resources it
uses to ensure its sustainability and create value in society at large. The Institution of Consultation is governed by specific
principles and is designed through the implementation of a five-stage cyclical process, which after each cycle of its completion is
repeated in order to implement improvement moves where required.
The stages of this process are:
a) The systematic review of social partner groups with specific criteria (AA1000 SES).
b) Understanding the business case and the individual motivations of METLEN's Business Sectors for the implementation
of the dialogue.
c) The topics and design of the structure of the Consultation.
d) The implementation of dialogue and the feedback framework by the social partners.
e) The evaluation of the results, the response to the basic expectations of the Social Partners as well as the maintenance
of the dialogue.
The main long-term objectives of the Consultation Institution are:
a) Understanding and responding to the expectations of the key groups of Social Partners with whom METLEN
communicates, cooperates and interacts in the context of its activity,
b) The evaluation of Material-Sustainable Development issues and the dissemination of corporate values and responsible
entrepreneurship.
c) The continuous effort to enhance transparency and maintain social acceptance of the company's operation.
d) The recognition and bridging, in the most appropriate way, any differences between the company's policies and the
perceptions of its social partners on Essential Sustainable Development issues.
e) The emergence of new ways of partnership to improve and strengthen existing relationships, strengthening METLEN's
policy in prevention, but also the recognition of economic, environmental and social risks and opportunities
The purpose of the Consultation is the regular interaction and cooperation of the Company with the groups affected by its
activity, where possible. Through this process, the Company gains a deeper understanding of their core expectations, strengthens
5. Annual Board of Directors Management Report
85
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
its alignment efforts, contributes to risk prevention and exploits opportunities arising from these relationships.
[ESRS2:SBM_2_45_a_iv]
In addition, the Institution of Consultation is consistently implemented on an annual basis, including contemporary Sustainable
Development issues related to the operation of the Company's business model.
When choosing the topic, specific factors are taken into account, such as: The Company's Sustainable Development strategy, the
ESG priorities and needs of the Business Sectors, the needs of the local community, the broader trends of sustainable
development and responsible entrepreneurship, METLEN's obligations, etc. The results are taken into account in the annual
exercise of the evaluation of Material Sustainable Development issues, while at the same time they are promoted to top
management through the Company's sustainable development governance system. The most important issues are examined by
the respective Directorates-General in order to make decisions on how to respond to them, but also decisions that allow - where
possible - their integration into business functions and strategy. [ESRS2:SBM_2_45_a_v]
The organization of the Consultation at local level is mainly implemented by the sustainable development teams of METLEN's
business sectors in cooperation with the central Directorate of Sustainable Development, where the relevant objectives and
expectations of the dialogue are defined. It takes place mainly in person, through workshops but also through online meetings
or sending out electronic questionnaires, depending on the conditions and nature of the topic.
When the Consultation takes place at central level, it concerns the entire Company and all Social Partner groups participate. It is
implemented by the Sustainable Development Division and often in collaboration with the sustainability teams of METLEN's
business sectors. Due to the large number of individuals, bodies, organizations addressed by the Company and for the best
possible representation of all groups, the Consultation takes place mainly electronically through a structured questionnaire.
In the context of the above mentioned process, the annual Consultation Institution was also held in 2024 (July-September
period), with the aim of ensuring the alignment of METLEN's approach to Sustainable Development with the main expectations
and views of its Social Partners in this field. The consultation was implemented by sending a structured e-questionnaire to 1,121
recipients from all METLEN Social Partner groups, where in total, 360 individuals, institutions, companies, organizations, local
communities, voluntary and non-governmental organizations participated, more than 32%.
The main objectives of the consultation were: a) to collect and evaluate attitudes and opinions on whether METLEN's
management of Sustainable Development is a source of potential opportunities and/or risks for its Social Partner groups and for
the Company itself. b) determining the degree of alignment of the Company's Sustainable Development strategy with the goals,
interests, expectations and personal beliefs of the Social Partners. At the same time, through the consultation, there was
feedback on the prioritization of Sustainable Development challenges for the Company, as well as an assessment of the progress
of its performance in Sustainable Development in recent years.
The detailed analysis of the findings revealed that the majority of participants assessed very positively the impact of sustainability
issues on the Company, confirming that METLEN's Sustainable Development strategy contributes significantly to its financial
performance. More specifically:
A. Aligning the objective of the Sustainable Development Strategy with the view of the Social Partners
According to the results, there is almost universal acceptance (93%) among survey respondents that business and economic
progress must be achieved in conjunction with commitment to the Global Sustainable Development Goals. This indirectly
demonstrates the strong support of the Social Partners towards the goal of METLEN's Sustainable Development Strategy, which
refers to linking economic and sustainable development.
B. Information and communication
The results show that METLEN has reached out to a significant extent to its Social Partners through the communication of its
sustainable development strategy, as 8 out of 10 survey participants have heard or read about it. However, the level of knowledge
varies, with 6 in 10 feeling fairly or fully informed, while over 3 in 10 reports having limited knowledge. This indicates the need
to provide more information in order to close information gaps and enhance the understanding of METLEN's initiatives by all
Social Partners.
C. Aligning the Sustainable Development Strategy with the objectives, interests and expectations of the Social
Partners
According to the relevant findings, there is:
5. Annual Board of Directors Management Report
86
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
a) Very high degree of agreement (80%) that METLEN's sustainable development strategy serves the objectives of the
Social Partners, which is very positive and shows a strong support on their part.
b) High degree of alignment (72%) of the Company's strategy with the interests of the entity, company, organization,
community or organization that its Social Partners represent or belong to.
c) Very high acceptance (82%) of the Social Partners that METLEN consults and takes into account their basic
expectations and views when implementing the strategy for Sustainable Development, indicating the effectiveness
of the ways of communication and cooperation with them, which is crucial for the success of sustainable
development.
d) Very strong identification (80%) between METLEN's BA strategy and the relevant personal beliefs of the Social
Partners, suggesting that the Company's strategy is very much in line with their ethical and environmental values.
D. Prioritizing the importance of the Sustainable Development challenges faced by the Company
More than 8 out of 10 respondents consider that challenges such as secure and productive employment, responsible
management of natural resources, sustainable industrial activity, and tackling climate change are extremely important for
METLEN. In addition, more than 7 out of 10 respondents consider commitment to social responsibility and the implementation
of corporate due diligence important, while more than 6 in 10 respondents recognize the importance of digital transformation,
but also the need for more understanding about the role of these technologies in sustainable development. In conclusion, the
results indicate a strong priority for the Company to be an employer of choice and to apply high environmental responsibility
criteria.
E. Impact of the management of important Sustainable Development Issues on the groups of Social Partners
The Social Partners appreciate very positively the impact that METLEN's management of
13
sustainable development issues has
on themselves. 84% of respondents see these issues mainly as sources of potential opportunities (either low, medium or high
intensity), 11% are neutral, while only 5% say they view these issues mainly as sources of potential risks (whether low, medium
or high intensity). This suggests that METLEN has emphasized practices and actions that can not only protect, but also contribute
to the sustainability and development of the Social Partner groups associated with it.
F. Impact of the management of significant Sustainability Issues on the Company itself
a) The Social Partners appreciate very positively the impact that METLEN's management of sustainable development
issues has on the effective operation of its business model. 86% of respondents consider these issues mainly as sources
of potential opportunities (either low, medium or high intensity), 9% have a neutral stance, while only 5% consider
these issues as sources of potential risks (whether low, medium or high intensity) that may affect the Company's
operation. The result underlines that METLEN's management of sustainable development is considered crucial for the
successful operation of its business model, as the vast majority of Social Partners see it as an opportunity that enhances
its sustainability and competitiveness.
b) The Social Partners also assess very positively the impact on METLEN's reputation and image. Specifically, 86% of the
Social Partners consider that the management of these issues is an opportunity (either low, medium or high intensity)
to further enhance the reputation of the Company, 9% do not consider that there is any opportunity or risk to the
reputation of the Company, while a low percentage of 5% states that the management of these issues may pose a risk
(either low, medium or high intensity) that may negatively affect the Company's reputation. This result highlights that
METLEN has managed to link sustainable development with its corporate reputation in a positive way. The social
partners seem to understand that the Company demonstrates responsibility towards social and environmental issues,
This enhances credibility and trust in it.
c) The impact of the management of Sustainable Development on its financial performance is also positive. Specifically,
79% of those who participated in the survey consider that the management of these issues is an opportunity (either
low, medium or high intensity) to maintain or improve the Company's financial performance, 15.5% consider that there
is no effect, this may mean that they have either not seen immediate financial results or that they believe that
sustainable practices do not materially affect financial performance, while a small percentage of 5.5% see that
managing these issues can be a source of risks (either low, medium or high intensity) to the Company's financial
performance. Overall, The Social Partners believe that incorporating sustainable practices not only does not harm
METLEN's financial performance, but on the contrary, can improve it by increasing efficiency, attracting investment and
creating new business prospects.
13
Health and safety at work, Business conduct, Water abstraction, consumption and discharge management, Circular economy, Working conditions, Equal
treatment and opportunities at work, Tackling climate change and energy transition, Pollution prevention, Protection of biodiversity and ecosystems, Rights of
local communities, Consumers and end users.
5. Annual Board of Directors Management Report
87
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
G. Evaluation of performance progress in Sustainable Development
The vast majority of respondents (86%) say that METLEN has improved its performance in the three pillars of sustainable
development over the past three years, with 42% rating that the Company has improved "A lot" and 44% "Quite a lot". However,
14% consider that although progress has been made, it has not been as significant as expected, indicating scope for further
improvements in some areas to meet the expectations of Social Partners. The fact that no respondent reported that there had
been no improvement ("Not at all") shows that the Company's improvement efforts have been perceived by all Social Partners.
H. Feedback and communication mechanisms
a) Overall, more than 7 out of 10 respondents are satisfied with the way METLEN communicates its sustainable
development initiatives. However, 20% remain neutral, which may mean that the approach could be improved in some
partner groups, while the low percentage (4%) who say they are not satisfied suggests that there is little but real need
for further improvement.
b) Also, more than 7 out of 10 respondents largely believe that METLEN's information and communication mechanisms are
accessible, as well as that the information it provides is sufficient, which is important for the transparency and
accountability of the Company. However, the fact that 2 out of 10 respondents declare themselves neutral could mean
that the Company needs better communication and greater accessibility, as well as more or more specific information
for certain groups of Social Partners.
c) Moreover, the credibility and effectiveness of METLEN's information and accountability mechanisms is positively
recognized by the vast majority (81%) of respondents, indicating that the Company has built a relationship of trust with
its Social Partners on these issues. The percentage of respondents who remained neutral (16%) may indicate that further
proof of the effectiveness of these mechanisms is needed.
d) Finally, it is noteworthy that almost 8 out of 10 participants see METLEN's information and accountability mechanisms
as a support and learning tool, suggesting that the Company provides not only information, but also material that helps
to understand its initiatives, without excluding further strengthening of the educational dimension.
At the same time, the Company held for the fifth consecutive year a constructive dialogue with Non-Profit Organizations
focusing on:
a) the further development of the already successful collaborations that have been developed with collaborating bodies,
b) identifying and reporting any problems, but also developing new partnership possibilities within existing partnerships,
c) acquaintance with new institutions and the design of new programs. The dialogue took place online with the
participation of 35 Non-Profit Organizations, of which 18 are current and long-term collaborations of the Company,
while representatives of 17 Non-Profit Organizations were given the opportunity to present their actions for the first
time, to be informed about the implementation of METLEN's social policy through the implementation of actions and
initiatives and to discuss the possibility of cooperation within 2025.
Specifically, the following issues were discussed:
a) evaluating cooperation, continuing an ongoing programme/launching a new one, as well as addressing any problems;
b) informing organizations about the Company's social policy goals for 2025, and their connection with the Global
Sustainable Development Goals, as well as informing the Company accordingly about new NGO programs that can serve
these goals,
c) better capture of quantitative and qualitative results resulting from programmes and actions,
d) possibility of implementing Corporate Volunteerism, aiming at the involvement of employees in actions of organizations.
The results of the initiative were the confirmation of maintaining relations of mutual trust and benefit, easy communication and
immediate response to any issue presented, the fullest briefing of organizations on current developments of Sustainable
Development, as well as the development of new innovative partnerships to support actions in accordance with the axes of the
Company's social policy towards the further development of its positive impact on society.
4. Adapting Strategy and Business Model based on the interests and views of the Social Partners [SBM_2_45_b]
[SBM_2_45_c_i]
METLEN perceives the interests and views of its Social Partners as an integral part of enhancing the value of its Social Capital, in
the context of the operation of its business model. The company communicates with all its Social Partners' teams to understand
what they expect from it, what they consider important, how they are affected by its activities, as well as to identify, assess, and
5. Annual Board of Directors Management Report
88
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
manage significant social, environmental, and economic impacts related to its activities and business relationships. The
Stakeholders Consultation Institution applied by METLEN systematically examines the needs and expectations both at a general
level and on thematic areas that reflect its significant impacts, as identified through the results of the materiality assessment.
Their views and expectations are consistently included in the annual sustainable development corporate reports, and where
feasible, are taken into account in shaping actions and processes for managing related impacts.
METLEN also recognizes the importance of continuously adapting its strategy and business model to strengthen its business and
financial position, which is a key demand of shareholders, investors and financial institutions, but also to meet the basic
expectations of its other Social Partner groups.
2024 was the second year that the Company operated under its new operating model, which constitutes a new chapter in its
history, in order to prepare for the upcoming challenges at geopolitical, economic, social and environmental levels. The
transformation of the Company has brought strategic changes and innovations to its business model that enhance financial
performance, sustainable development, corporate governance, and consequently the Company's resilience. Specifically:
A) METLEN shareholders seek a stable/increased return on their investments and transparency in corporate decisions. The
transformation of METLEN has already contributed to increasing profitability and enhancing the company's financial
performance, with shareholders receiving increased dividends and higher share value. At the same time, the Company
further enhances its transparency and accountability practices by providing regular updates and reports to shareholders
through detailed financial reports, sustainability reports and other special reports (TCFD report, Socio-Economic footprint
report, etc.) that allow shareholders to holistically monitor its progress.
B) METLEN's new business strategy includes the expansion of the Company into areas that create new growth opportunities
and enable synergies that unlock multiple value across the range of its activities, meeting the expectations of the
investment community for profitable and sustainable investments. In addition, the Company, through its transformation,
has largely covered the needs of modern investors who operate through specific investment approaches such as ESG
investing and Impact investing. METLEN, strategically positioned in both these approaches, has further strengthened its
competitiveness and attractiveness in the markets.
C) Financial institutions are looking for financially strong businesses with a clear sustainable development strategy. The
corporate reorganization of METLEN and its new business model led to further improvement of its credit profile,
strengthening of its financial figures, as well as its key financial indicators, further enhancing its credibility and financial
strength. Economic growth combined with the Company's existing sustainable development practices and ESG performance
are aligned with the targeting and standards of financial institutions that promote green finance and support sustainable
investments.
D) The success of METLEN's new operating model is largely based on the satisfaction and well-being of its employees. In this
direction, the Company, taking into account the views and interests of its employees, has designed and is already
implementing a strategic action plan with a vision to become an "Employer of Choice" in all markets where it operates,
offering innovative and targeted human resources solutions. The aim is to enable its people to have a clear direction,
attractive career and development prospects and strong motivation in their work, while attracting and developing talented
employees to support its business development and maximize its performance.
Ε) The transformation of METLEN aims at the continuous adaptation of its business model to the needs and expectations of
electricity & gas customers, as well as customers of its industrial products. The Company, through its customer-centric
approach, continuously improves the quality of its services in the retail electricity and natural gas market, offering reliable
solutions, competitive products and modern services to businesses, professionals and households, which now extend to
services such as energy efficiency, smart cities, facilities management, Internet of Things / digital services, etc. This approach
contributes to its effort Company to satisfy customer needs for uninterrupted power supply, high quality services, quick
response in case of problems, competitive electricity prices, transparency in tariffs and bills that are easy to understand.
F) METLEN also recognizes the critical role of its suppliers in achieving its business goals and has already adapted specific
policies and procedures to its business model to meet their needs and expectations. This includes, but is not limited to, the
Company's Responsible Supply Chain policy, the evaluation model of its key suppliers with ESG criteria, the training courses
it implements to enhance their maturity, elements that ensure the mutual, beneficial, stable cooperation that is the main
demand of its suppliers.
G) The Company is in a continuous process of identifying and adapting to the needs and priorities of its local communities, so
that its development efforts, domestic and international, are as compatible as possible with them. METLEN's social
commitment, through the employment of local workforce, the support of local businesses and its social investments, it
reinforces its preventive approach, protecting its business model from unforeseen social risks, while contributing to
maintaining the social acceptance of its operation and its good reputation. This is an ever-evolving effort in various forms,
all of which imply the Company's commitment to meeting the diverse expectations of its local communities, to the extent
that it deserves.
5. Annual Board of Directors Management Report
89
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
H) The academic community is another key partner in METLEN's effort to promote innovation. The Company has strengthened
its cooperation with European universities and research institutes, participating in scientific research programs aiming at
the development of new technologies and consequently the improvement of its processes and the reduction of its
environmental footprint, especially in the Metals Sector. Through these partnerships, METLEN ensures the future adoption
of practices and initiatives based on evidence-based scientific methods in order to effectively address the challenges of
modern industry.
I) The remaining groups of the Company's Social Partners such as sustainable development agencies, Non-Governmental and
voluntary organizations expect overall ethical, environmentally sustainable and socially responsible business practices.
METLEN has understood the strategic importance of cooperation with NGOs, and has developed channels of constant
communication with them, exchanging views and jointly seeking the best options to mitigate social issues. The These
partnerships have led to joint actions and programs of high social value, accompanied by distinctions and awards on an
annual basis, the scope of which extends to almost the entire range of social issues covered by the Global Sustainable
Development Goals. In addition, METLEN actively participates in international initiatives and cooperates with global
organizations that promote sustainable development. Through these partnerships, the company has gained access to best
practices and innovative solutions that help it shape a more responsible and sustainable strategy. In addition, participation
in initiatives such as the UN Global Compact and the Carbon Disclosure Project enhances the Company's transparency and
accountability.
In addition, METLEN has planned important initiatives for the near future, aimed at promoting sustainable development and
strengthening relations with the Social Partners. Initiatives include: [SBM_2_45_c_ii] [SBM_2_45_c_iii]
a) The overview of its climate objectives (by the end of 2025): The review of METLEN's climate objectives will allow the Company
to adapt its climate initiatives according to its new business needs, while maintaining its alignment with the expectations of Social
Partners demanding action on climate change and compliance with global environmental expectations. At the same time, and in
the longer term, the development of new technologies and practices to reduce the environmental footprint will promote
innovation and new technologies. They will create new opportunities for collaborations with specialized suppliers and partners,
thus contributing to the strengthening of trust and support from organizations and local communities, as well as to the
preservation of METLEN's corporate reputation as a responsible business.
b) The development of the due diligence model (by the end of 2027). METLEN aims to develop an integrated due diligence model
for the proper management of environmental issues and the protection of human rights in its value chain. The development of
the due diligence model will improve transparency, ensuring that the Company complies with the highest standards of
sustainability and ethical business practice; this should further strengthen the confidence of the Social Partners.
c) The implementation of a strategic plan as an "Employer of Choice". METLEN, by the end of 2028, aiming to become an
"Employer of Choice", will enhance practices that promote employee well-being and satisfaction. This will improve its
relationships with employees and their representatives, enhancing the commitment and dedication of human resources. At the
same time, strengthening the work culture will create positive impressions on all Social Partners, improving the Company's ability
to attract talent. In addition, it will strengthen its relations with society and the labour market, making it a model of responsible
human capital management.
d) The formulation of the Technical Innovation Strategy ("Trinity"). Through this initiative, the Company aspires within a five-
year horizon, to utilize classical Informatics (IT) and Industrial Informatics (OT) in all aspects of its daily activities. The successful
implementation of this strategy will mean for METLEN the alignment of the objectives of digital/technological transformation
with its business strategy, aiming to achieve further cost reduction and reach a higher level of development, profitability and
sustainability. It also means becoming more competitive in cost, innovation and data-driven decision-making, serving the
demands of customers who have increasingly high expectations of their interactions with businesses.
5. Briefing of the Board of Directors on the views of the Social Partners on Sustainability [ESRS:SBM_2_45_d]
Informing the Board of Directors, through the Sustainable Development Committee, about the attitudes and views of the Social
Partners, in the context of the implementation of the annual Consultation Institution, is a key element of the Company's
governance and Sustainable Development strategy. Specifically, the Sustainable Development Committee is informed once a year
or more frequently if required, both on the results of the central consultation process with the Social Partner groups, as well as
on the results of individual more focused dialogue actions, in the context of its regular meetings, by the Directorate General for
Corporate Governance and Sustainable Development. The Commission's President then informs the Board of Directors of these
5. Annual Board of Directors Management Report
90
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
results, in the context of its regular meetings, through the dedicated section dedicated to Sustainable Development issues. The
Board discusses the results in order to understand the importance of the views and needs of the Social Partners, as well as the
possibility of further adapting corporate policies, where possible, to their expectations, to enhance corporate responsibility.
6. Interests and views of the workforce concerned
In the context of the 2024 annual Central Consultation of the Social Partners, 124 direct employees from all METLEN business
activities participated, selected through random sampling from a pool of employees representing all countries of activity as well
as all hierarchical levels, excluding top and senior management. [S1:S1-1_20_b]
From the analysis of the results of the Consultation, the following main conclusions emerge:
a) The vast majority of participating employees (80%) agree that METLEN's sustainability strategy is aligned with achieving
their goals. Also, a significant percentage (76%) believe that the Company's sustainable development strategy takes into
account their views when formulating it, while a similar percentage are positive about its alignment with their interests
(78%). The resulting neutral stance rates (approximately 20%) indicate room for improvement, while extremely low (2%-
3%) negative positioning rates were recorded, confirming the broad acceptance of the Company's sustainable
development strategy by employees.
b) METLEN's management of sustainable development issues is mainly evaluated as an opportunity for the vast majority
of participating employees, who positively evaluate the Company's initiatives on issues such as responsible business
conduct, tackling climate change, water management and circular economy, with positive evaluation rates reaching
90%. Regarding social issues, such as the rights of supply chain workers, the rights of local communities, as well as those
of consumers and end users, the majority of representatives evaluate METLEN's management very positively,
recognizing that the Company's impact is a creator of opportunities, both for itself and for its Social Partners. METLEN's
efforts for optimal management of sustainable development are recognized by employees as positive overall, both for
human resource management issues that directly concern them, as well as for all environmental and other social issues
that the Company is called upon to manage.
c) In particular, METLEN has almost universal acceptance by the participating employees regarding the management of
working conditions. Of the 124 employees surveyed, 93% believe that METLEN's management has a positive impact on
the management of working conditions, while 87% believe that the Company provides an environment of equal
treatment and equal work opportunities, which translates into a significant opportunity for them. This suggests that the
company demonstrates a high level of responsibility towards workers' rights by incorporating practices that strengthen
its relationship with them. The fact that only 4% of representatives maintained a neutral stance in relation to the
management of working conditions, while an even smaller percentage expressed a negative opinion, reinforces the
image of a company that treats human resources as a whole as a priority, with respect and transparency.
Correspondingly, the fact that 10% maintained a neutral stance on the labor issue of equal treatment and equal
opportunities, while a much smaller percentage of 3% is negative, leaves room for improvement, for which the Company
has already undertaken specific actions in 2024, which are reflected below in the description sections of the adopted
actions of this chapter.
d) As part of the survey, participating employees were asked to identify significant sustainability challenges for the
Company's activity. More than 85% prioritise the challenges of secure and productive employment, sustainable
industrial activity and responsible management of natural resources and biodiversity as the most important.
Subsequently, 82% identify tackling climate change and the energy transition as a challenge, while around 75% consider
a commitment to social responsibility and corporate due diligence, while more than 70% agree that digital
transformation and artificial intelligence are also a challenge for sustainable development. All the above challenges are
already strategic priorities for the Company, which are part of the overall approach it has developed for the management
of sustainable development, in order to be able to timely and effectively prevent the resulting risks, while creating the
framework for exploiting opportunities arising from the management of issues, both for itself and for its social partners.
e) Finally, 99% of participating employees recognize that the Company's performance in the three pillars of Sustainable
Development (environment, society, governance) has improved over the last three years, while they have contributed
to its business and financial progress. [SBM_2_12]
7. Interests and views of value chain workers and suppliers
METLEN has established and implements multilevel cooperation procedures with its permanent subcontractors, in order to
effectively manage Workplace Health and Safety (OSH) issues. Through regular meetings, an approach to direct open dialogue
on all issues that may arise in relation to each cooperation, as well as on-site prescribed periodic audits, the Company pays
particular attention to the interests of indirect employees, in a similar and uniform manner, as for its workforce, properly
updating its business model and strategy. In addition, it has put in place mechanisms to remedy any negative effects and provides
5. Annual Board of Directors Management Report
91
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
communication channels that also allow indirect workers to raise their concerns. All these procedures are described in detail on
the following pages.
The actions and initiatives to promote and strengthen a comprehensive approach of a unified "Safety Culture" are shaped by a
variety of factors, determined mainly according to corporate activities, while taking into account the interests and rights of both
those directly involved (see below). ESRS:S1) and indirect workers. The feedback of permanent subcontractors as key suppliers
of the Company and through them their employees who are indirectly employees for the Company, as well as other stakeholders
on all sustainable development issues including OSH, is served centrally through the annual institution of Consultation with the
Social Partners. Specifically, in the central consultation of 2024, 109 key suppliers participated, a significant part of which are
permanent subcontractors of the Company. At the same time, the majority of them are evaluated through their voluntary
participation in the annual Evaluation process of Key Suppliers with ESG criteria, from which points of imprinting a uniform culture
of responsibility emerge, while where deviations are identified, a program of improvement actions is developed in cooperation
with them. The self-commitment of the Company's permanent partners to its principles and values, but mainly to its central OHS
Objectives, is of key importance and directly affects both the evaluation of corporate performance and the remuneration and
benefits targets of the members of the Board of Directors of METLEN.
Overall, based on the main findings that emerged from the analysis of suppliers' positions and views on the issue of OSH, it
appears that almost 8.5 out of 10 survey participants identify the issue of safe and productive employment as the most important
sustainable development challenge to be continuously managed by the Company in relation to its activities. in order to become
an employer of choice. In all Social Partners, the above view is shared by an even greater percentage of almost 9 out of 10
respondents, confirming the fundamental importance of adherence to high OSH standards for the Company and its sustainable
development.
Confirming the effectiveness of the Partnership approach, 89% of the participating key suppliers and respectively 90% of all key
Social Partners who participated are positively positioned by recognizing METLEN's management of the OSH issue as a source of
opportunities with a positive or very positive impact on themselves and consequently on their employees. Also, regarding the
more specific question, whether the management of the OHS issue contributes to the effective operation, the enhancement of
the Company's financial performance and reputation, it appears that 7 out of 10 participating suppliers and 7.5 out of 10
participants from all social Partners agree, data that reflect the need for constant vigilance and uninterrupted dedication to
achieve corporate goals.
In conclusion, the findings of the survey demonstrate that METLEN has managed to be widely recognized by its social partners
and employees as a company that prioritizes secure and productive employment, which is considered crucial to continue to be
an employer of choice. [SBM2:45_a]
8. Interests and views of local community representatives
In the context of the annual central Social Partners' Consultation of 2024, 18 representatives of local communities adjacent to
METLEN's main industrial units and construction sites in Greece participated, submitting their views. The analysis of the individual
results leads to the following main conclusions:
a) The vast majority of local community representatives (86%) agree that METLEN's sustainable development strategy is
aligned with achieving their goals. Their attitude regarding the degree of integration of their views into the formulation
of the Company's sustainable development strategy is also positive (67%), as well as its alignment with their particular
interests (57%). Despite the significant levels of neutrality, indicating room for improvement, it is worth noting that there
were no negative positions, confirming the broad acceptance of the strategy by local communities.
b) METLEN's management of sustainable development issues is mainly evaluated as an opportunity for the vast majority
of representatives of local communities, who positively evaluate the Company's initiatives on issues such as water
management, circular economy, and biodiversity protection, with positive evaluation rates reaching 92%-100%. Also,
tackling climate change and the energy transition are seen as equally important opportunities, with 100% of delegates
valuing them positively. Even on social issues, such as working conditions, the majority of delegates assess METLEN's
management very positively, acknowledging its positive impact. Overall, METLEN sees sustainable development not only
as a necessity but as an opportunity to make a positive contribution to its local communities, with their representatives
largely acknowledging this potential.
c) METLEN seems to have almost universal acceptance by representatives of local communities in terms of respect for their
rights. Of the 18 delegates surveyed, 92% consider that managing METLEN has a positive impact on this issue, which
translates into a significant opportunity for communities. This suggests that the Company demonstrates a high level of
sensitivity and responsibility towards the rights of communities and has incorporated practices that strengthen its
relationship with them. The fact that only 8% of representatives maintained a neutral stance and no one expressed a
5. Annual Board of Directors Management Report
92
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
negative opinion reinforces the image of a Company that treats communities with respect and transparency.
d) Finally, 70%-80% of local community representatives who participated in the survey identify as the most important
sustainable development issues for the Company the maintenance of social responsibility commitments, the proper
management of digital transformation including artificial intelligence and the protection and responsible management
of natural resources and biodiversity, secure and productive employment, sustainable industrial activity and tackling
climate change. All the above issues are strategic priorities for the Company, for which it has developed a comprehensive
management approach, in order to prevent the relevant risks in a timely manner, while creating the framework for the
exploitation of relevant opportunities for both itself and its social partners. [S3.SBM-2_7]
9. Interests and opinions of customers
Protergia (Energy Customer Solutions) of the Energy Sector, which manages METLEN's retail energy arm, ensures the reliable
supply of electricity and natural gas to distribution networks to businesses, professionals and households, serving customer needs
for competitive prices, through a series of specially designed modern and reliable energy saving procedures, advice and services.
In order to ensure the effectiveness of the Commercial Division of the Sector and to recognize its room for improvement, retail
customer satisfaction is measured through Customer Satisfaction Surveys on an annual basis. Specifically, in 2024, Protergia
planned to conduct two customer satisfaction surveys (via phone calls), through an external specialized partner. The first survey
was conducted in January and the second in November and December (2024). The sample of customers in the first wave was N
= 400 and in the second wave N = 658 (as for the first time we measured another sample, i.e. former customers of WATT+VOLT).
The samples are always divided into the following criteria: gender, regions, age, years of cooperation (new/old customers), type
of supply (electricity/gas). The above criteria are representative of Protergia's customer base, except for age, which is determined
by quotas of the company conducting the survey (representative of the population) and are found in the questionnaire to the
client/respondent. Some data that emerged from the evaluation of the results of the second wave survey: it was found that 85%
are overall satisfied with Protergia, 85% are satisfied with the Customer Service Department's service, 82% declare their intention
to stay in Protergia and 90% are satisfied with their visit to a Protergia store.
Also, M Renewables of the Energy Sector, in the context of measuring customer satisfaction and identifying room for
improvement, conducts an annual customer satisfaction survey through a digital questionnaire, which is sent to customers whose
projects were completed in 2024. The results showed that 18% of respondents preferred METLEN due to successful previous
cooperation, 45% due to competitive financial offer while 9% judged based on the Company's experience. At the same time, the
vast majority of participants expressed their support for a future collaboration. In particular, the Company scored ≥4/5 in all
evaluation categories related to financial, environmental, health and safety, facilities / equipment issues as well as evaluation of
project management, quality and technical competence.
In the context of the 2024 annual central Social Partners' Consultation, 8 major clients participated, submitting their views. The
analysis of the individual results leads to the following main conclusions:
The vast majority of representatives of major customers (81%) agree that METLEN's sustainability strategy is aligned with
achieving their goals. Their attitude regarding the degree of integration of their views into the formulation of the Company's
sustainable development strategy is also positive (75%), as well as its alignment with their particular interests (74%). Despite the
significant percentages of neutral stance (23%), indicating the room for improvement, it is worth noting that negative positions
ranged at very low rates (2-3%), confirming the wide acceptance of the corporate strategy by customers.
METLEN's management of sustainable development issues is mainly assessed as an opportunity for the vast majority of clients
who participated in the consultation, who value the Company's initiatives on issues such as respect for consumer and end-user
rights, respect for the rights of local communities, equal treatment and equal opportunities at work. the protection of biodiversity
and ecosystems and the circular economy. Also, the vast majority of respondents (80%) also positively assess how issues such as
water resources management, pollution prevention, contribution to tackling climate change, monitoring working conditions,
business conduct, as well as managing indirect workers, while the remaining percentage (20%) maintain a neutral stance, which
translates into continued improvement efforts.
Finally, more than 80% of customers surveyed identify as the most important sustainable development issues for the Company
the maintenance of social responsibility commitments, secure and productive employment, sustainable industrial activity,
tackling climate change and the implementation of corporate due diligence. With a lower percentage of 40%, customers identify
protection and responsibility as sustainable development challenges for the Company management of natural resources and
biodiversity, as well as sound management of digital transformation, including artificial intelligence. The result underlines the
need for further Corporate activity in order for the Company to be able to prevent the relevant risks in a timely manner, while
5. Annual Board of Directors Management Report
93
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
creating the framework for exploiting relevant opportunities for both itself and its customers. [ESRS2:SBM-2_8]
Significant impacts and their interaction with the strategy and business model [ESRS2:SBM-3_48_a]
Key impacts table of METLEN’s activity in Sustainable Development within the Value Chain
(2024)
ESRS STANDARDS
Ε1
Climate Change
S1
Own workforce
Ε2
Pollution
S2
Workers in the value chain
5. Annual Board of Directors Management Report
94
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Ε3
Water & marine resources
S3
Affected communities
Ε4
Biodiversity and ecosystems
S4
Consumers and end-users
Ε5
Resource use and circular
economy
G1
Business conduct
Explanatory table of key impacts
5. Annual Board of Directors Management Report
95
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Impact on people and the environment
Overall, the impact of METLEN Energy & Metals's activity on people and the environment is diverse and interconnected, with the
Company focusing on pursuing sustainable practices and effective impact management, enhancing its positive contribution to
both society and the environment. [ESRS2:SBM3_48_c_i]
Impact on people
Actual negative impacts on people include the release of air pollutants from the Company's activities, with the respective
contribution to burdening air quality and a possible effect on the health of residents of local communities adjacent to the
Company's production plants, degrading their quality of life. Moreover, the consequences of accidents at work could be serious,
affecting not only employees but their families as well. Accidents also have a psychological impact, as employees who witness or
experience such events may develop anxiety, fear, or post-traumatic stress. Meanwhile, developing measures for fair treatment
and equal opportunities at work is also essential, since their absence could lead to inequalities undermining the overall work
ethic.
The potential negative impacts include the possible salinization of the wells utilized by the Company due to increased pumping,
which may lead to a reduction in water availability. Additionally, there may be potential degradation of soil and water resources
due to pollution incidents, while the possible emergence of unethical practices in the value chain can erode social justice, increase
inequalities, and reduce people's trust in the institutions and processes that ensure their rights and well-being.
On the other hand, METLEN’s actual positive impact on people is significant. Undertaking energy and infrastructure projects that
advance energy transition, as well as renewable energy projects, gradually leads to air quality improvement, which in turn
improves the health and quality of life of people in the countries and communities where these solutions are implemented,
combined with new employment opportunities in these fields. Furthermore, METLEN offers job security which enhances the
financial security of employees and their families, promoting overall well-being and job satisfaction. In addition, METLEN creates
value for local communities by doing its fair share to foster social cohesion and economic development through investments and
support for initiatives that first and foremost benefit local residents. This ethical approach contributes to the formation of a
society of justice and transparency, strengthening citizens' trust in institutions and economic transactions. At the same time,
responsible supply chain management ensures fair working conditions and equal opportunities, reducing social inequalities and
enhancing the overall well-being of workers and local communities.
As an existing impact, the Company's responsibility in providing products and services is also recognized. Responsible provision
of products and services significantly contributes to improving people's quality of life and enhancing social cohesion. METLEN
focuses on the needs of customers, consumers, and end-users, ensuring the availability of essential mineral products and reliable
energy supply for large industries, small and medium-sized enterprises, professionals, and households. Through Protergia, Metlen
shapes an energy future that promotes sustainability and accessibility, providing not only electricity and natural gas but also
innovative solutions such as smart city services, electric mobility, and energy efficiency. These initiatives enhance consumers'
energy autonomy, reduce the environmental footprint, and create new growth opportunities for the communities in which it
operates.
Furthermore, METLEN also focuses on keeping its emissions within the WB2
o
C scenario by promoting clean energy; this will have
positive consequences for society as a whole, since new employment opportunities emerge in areas such as renewable energy
and green technology.
Impact on the environment
Actual negative impacts of METLEN on the environment include the release of CO₂ emissions, contributing, to their respective
extent, to climate change.
Potential negative impacts include the potential degradation of marine ecosystems in the event of non-use of existing wastewater
treatment systems, as well as discharging seawater at a temperature above the permissible limits, which can disrupt the natural
balance of marine ecosystems. The consequences of environmental incidents also include potential environmental damage, such
as leakage of hazardous substances, which can have a negative impact on natural resources.
As regards actual positive impacts, METLEN's business activities that advance energy transition contribute to the reduction of
carbon dioxide and other pollutant emissions, reducing the environmental footprint of its customers. This has a positive effect
overall on reducing CO
2
emissions, but also on improving air quality and ecosystem health. Moreover, the use of scrap aluminium
5. Annual Board of Directors Management Report
96
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
as raw material and the reuse of seawater discharges are positive practices gradually reducing the need for new raw materials
and minimizing environmental pressures. These practices promote circular economy which is crucial to environmental health.
A potential positive impact is that keeping the Company's emissions within the WB2
o
C scenario will reduce pollutant emissions,
thus contributing, to the respective extent, to tackling climate change. Finally, one of the most ambitious aspects of METLEN's
activities is the exploitation of bauxite residues, focusing on the recovery of rare earth elements. This process not only helps
reduce dependence on traditional sources of raw materials, but also promotes circular economy. The recovery of rare earth
elements from residues can provide valuable materials for industry and enhance technological and economic development.
Relationship between (Effect of) the impact and (on) the strategy and business model [ESRS2:SBM3_48_c_ii]
The overall impact of METLEN's activities is directly related to the Company's strategy and business model. METLEN operates
mainly in energy-intensive industrial sectors, such as aluminium production and energy production from natural gas-fired plants,
which entail significant environmental and social impacts. By reviewing the impacts in the light of the Company's strategy, we
can better understand how they result and how they are embedded into its business model.
Negative impacts, such as the release of direct and indirect emissions of CO₂ and other pollutants (NOx, SOx), result from the
energy-intensive processes that are an integral part of aluminium and energy production. High energy consumption is an intrinsic
aspect of METLEN's business model which relies on large-scale industrial activities. The environmental impacts of fossil fuel
combustion and other emissions processes are a direct result of the Company's structure, which relies on maximizing production
capacity to compete globally.
Accidents at work and the management of working conditions are also directly related to the nature of the Company's activities.
Large-scale workplaces in such sectors are inherently dangerous, a fact reflected in the negative impacts associated with worker
safety and the need for more effective monitoring of working conditions as well as the implementation of measures to manage
risks and, where possible, eliminate them.
METLEN's strategy not only focuses on its production activities, but also includes long-term actions for sustainability. Accelerating
energy transition through a shift to renewable energy is a strategic goal that strives to mitigate the negative environmental
impacts of production. The use of scrap aluminium as raw material indicates the company's commitment to circular economy
and the reuse of materials, reducing dependence on mining activities and limiting energy consumption. These strategic actions
are clearly linked to the business model, as reducing environmental impact becomes necessary to maintain competitiveness in a
world that is becoming increasingly sensitive to sustainability issues.
Creating value in local communities and promoting a culture of business ethics are also central to the Company's strategy.
METLEN seeks to strengthen its social responsibility, not only to consolidate a positive image, but also to ensure its long-term
sustainability, as modern businesses must operate ethically and responsibly.
Potential negative impacts, such as the degradation of marine ecosystems, the salinization of water resources and soil
degradation, are associated with the need for continuous access to natural resources, and their proper management is part of
the Company's business model.
METLEN's potential positive impacts are highly promising and closely linked to its strategy for innovation and sustainability.
Maintaining the Company's emissions within the WB2
o
C scenario is central to its strategy, as stricter regulations and social
requirements to reduce emissions and use clean energy shape its business model. Through this commitment, METLEN aims to
improve its competitiveness in a world moving towards green economy.
In addition, the exploitation of bauxite residues and the recovery of rare earth elements from such residues is a strategic
innovation that offers additional business opportunities. The recovery of rare earth elements, which are critical for the high-tech
industry, gives METLEN a competitive edge. This strategy is perfectly connected with the direction the Company is following
towards sustainable development and innovation in the metals industry.
Finally, continuous investment in people is another element that reflects the Company's strategic commitment to long-term
sustainability. By training and developing its employees, METLEN ensures that its people are ready to face future challenges
(green transition and technological innovation), while enhancing engagement and productivity.
The impacts of METLEN's activities are the direct result of its strategy and business model. While negative impacts are inherent
to the nature of operations, the Company has incorporated sustainable and innovative practices into its strategy to mitigate these
5. Annual Board of Directors Management Report
97
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
impacts and enhance positive ones. METLEN's strategy for energy transition, circular economy and the recovery of rare earth
elements reveals its intention to adapt its business model to a more sustainable and responsible future.
At the same time, Metlen is involved in significant impacts, positive or negative, not only through its own activities, but also
through its business relationships, which play a decisive role in its operation and corporate responsibility. Managing these
relationships can enhance positive impacts and reduce negative ones, promoting a more responsible and sustainable business
model.
For instance : [ESRS2:SBM3_48_c_iv]
a) The possible occurrence of unethical practices in the supply chain is one of the most material negative impacts associated
with METLEN's business relationships. Partnerships with suppliers or subcontractors that do not adhere to ethical standards, such
as fair treatment of employees or environmental responsibility, as well as suppliers or subcontractors that do not apply top level
Safety and Health procedures, can adversely affect METLEN's overall sustainability performance. Actions and practices of the
Company's partners can have serious repercussions, especially if the principles of corporate responsibility are not respected
across the entire supply chain. In contrast, good business relationships with partners who share the same values of ethics and
sustainability are key to fostering sustainable development. These relationships help ensure that the raw materials and products
METLEN procures are produced responsibly, minimizing environmental impact and safeguarding the rights of employees.
b) METLEN must comply with regulatory authorities, environmental and Health & Safety regulations, which affect its business
operations. These relationships require the Company to adopt practices that minimize its negative impacts, such as pollutant
emissions, waste management, and employee accidents. Regulatory compliance can lead to increased costs but also to
opportunities for innovation and improvement of corporate responsibility and sustainability.
Description of processes to identify and assess material impacts, risks and opportunities [ESRS2: IRO-1]
For METLEN Energy & Metals, the disclosure of essential information on environmental, social and governance issues is a key
priority, as these are directly linked to its ability to create shared value and promote sustainable development. This Sustainability
Statement is based on the application of the Double Materiality principle, which identifies both the Company's impact on the
environment and on society, as well as its impact on the Company itself. The resulting material negative impacts (risks) and
corresponding positive impacts (opportunities) are presented in this statement, reflecting their actual role in the Company's
Sustainable Development strategy.
METLEN's goal in 2024 was to integrate the Double Materiality Process into both its Sustainable Development management
model and its central risk management system with the ultimate goal of enriching it with specific risk factors that the Company
had not recognized until now. The Process was approved within 2024 as targeted and was also fully implemented for the Double
Materiality assessment in 2024. In addition, with the Double Materiality the Company can identify critical areas for improvement
and vital issues to be leveraged, and shape its Sustainable Development strategy focusing on complying with the applicable
regulatory framework, such as the CSRD, and its responsible operation at local, national and international level. [ESRS2:IRO-1_52]
1. Methodology
For METLEN, the Double Materiality process is a methodological approach that was first applied in 2024 (see Table/Figure No.
IRO-1/01), enabling it to identify, understand, assess and analyze in greater depth the environmental, social and ethical impacts
of its activity. This methodology makes it possible to identify material impacts and take into account the interdependencies
between them and the financial factors at play. At the same time, this process forms the basis for the preparation of this
Sustainability Statement of the Company, in accordance with the European Sustainability Reporting Standards (ESRS) and the
Corporate Sustainability Reporting Directive (CSRD). [ESRS2:IRO_1_53_a]
More specifically, the two main dimensions of the methodology followed include:
A) Impact materiality, which focuses on both the actual and potential impacts of METLEN's business on the natural
environment and on people, emphasizing the severity and likelihood of such impacts occurring. During impact recognition,
identification, understanding, and ultimately assessment, all topics (including sub topics and sub-sub topics) under the CSRD as
well as additional sources of information were taken into account, while the exercise was extended to additional topics related
to the scope of its activities and business relationships, highlighting risks and opportunities that are not directly related to the
impact.
B) Financial materiality, which examines whether and to what extent the environmental, social and ethical impact of the
Company's activity affects its financial performance, its reputation, its ability to continue to operate unimpeded, as well as its
commitment to a holistic approach to sustainable development, incorporating the principles of responsible entrepreneurship
5. Annual Board of Directors Management Report
98
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
into its strategy. The assessment was based on the fundamental assumption that the impact on the Company's sustainability can
become financially material either immediately i.e. from inception or detection, or at a later stage, potentially affecting its
financial position.
To identify the material topics, quantitative thresholds were applied, while qualitative characteristics were also taken into
account. Applying the thresholds highlighted the material impacts and the associated risks and opportunities, which are
presented in detail in this Sustainability Statement.
2. Overview of impact identification, assessment and prioritization process [ESRS2:IRO_1_53_b_i]
METLEN acknowledges the material actual or potential impacts, either positive or negative, on people or the environment,
medium or long term, which are associated with its activities. More specifically, it has established a set of control mechanisms
that make up the due diligence framework for sustainability. This framework is continuous and includes an uninterrupted cycle
of impact identification, assessment, mitigation measures, goal setting, and performance improvement. Below follows a
summary of the approach used to a) identify inherent risks, b) implement due diligence mechanisms, c) develop and implement
consultation and materiality processes in the Company’s overall sustainable development strategy with the aim of creating
shared value.
A. Inherent Risks
As part of the Double Materiality process, METLEN focuses on specific activities, business relationships, geographic areas, and
other factors that carry an increased risk of adverse impacts. This focus is necessary to identify and manage the significant risks
that can have serious consequences for both the Company and the environment and society at large.
Specifically:
a) Activities with Increased Risk of Negative Impact: METLEN analyzes its business activities (aluminium and energy
production) that consume high quantities of natural resources, such as natural gas, water and energy, are associated
with the generation and disposal of waste and have a material environmental or social impact, and which of course are
thoroughly examined with a view to reducing their environmental footprint.
b) Business Relationships with Increased Risk: METLEN’s business relationships, such as those with contractors, suppliers
and other partners (unless they comply with environmental and social requirements) can also be a source of increased
legal and reputational risks. For this reason, the Company applies quality assurance and evaluation procedures for its
partners.
c) Geographical Areas with Increased Risk: Where METLEN operates is also a critical impact analysis factor. This entails the
Company's review of sensitive areas that are vulnerable to climate risks, such as drought, floods or extreme weather
events, initially focusing on Greece, which is the heart of its production activity. To reduce this risk, the Company
analyses climate adaptation scenarios and adopts strategies that enhance its resilience
14
.
d) Socio-politically Volatile Areas: Areas with political instability or weak legal protection for corruption and bribery issues
are also dangerous. METLEN pays particular attention to its activities and business relationships in these areas, taking
steps to ensure compliance with the relevant standards.
e) Changes in Legislation and Regulatory Framework: METLEN closely monitors changes in the regulatory framework for
environmental and social issues, as stricter regulation can increase operational risks and compliance costs.
f) Technological Developments: Adopting new technologies that have not yet been fully tested for their impact can pose
risks to sustainability. METLEN carefully considers the use of new technologies, taking into account their sustainability
and the potential to reduce negative impacts.
B. Consultation and Materiality
Implementation of the renewed "Stakeholder Consultation Process & Double Materiality Process" was supported with the
development of a special digital application accessible to internal stakeholders from all of the Company's Sectors, Subsidiaries
and Central Functions. The application was configured pursuant to the Company's needs, in the light of its diverse activity and
focusing on ensuring a high level of transparency at each stage of its implementation, with a view to deepening the analysis of
the impacts and the relevant causes, their severity, but also the likelihood of occurrence in case of potential impacts. Meanwhile,
the Company's internal stakeholders involved were annually trained on how to properly use the platform so as to operate it
effectively.
14
As presented in section ESRS:E1
5. Annual Board of Directors Management Report
99
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Process ensures that views and positions of external experts are included in the consultation with internal stakeholders for
a fuller understanding of the impacts. This is ensured since, throughout the year, Sectors, Subsidiaries and CFs consult with
experts on specific sustainable development issues, in the context of supporting professional advisory services, certification and
external assurance services, as well as third-party external evaluations. At the same time, the participation of Company executives
in briefings and trainings as well as their representing the Company in industry associations or other business organizations
focusing on specific sustainability issues that are identical to those of interest to the Company also helps in a more mature
understanding of parameters that are then included in the identification of material issues, risks and opportunities, for the
Company as a whole. [ESRS2:IRO_1_53_b_ii]
In summary, according to the Process, the annual internal materiality assessment exercise starts with the participation of the ESG
teams of Sectors, Subsidiaries and CFs, using the “METLEN Impact Materiality App", which covers the first half of the double
materiality assessment. Initially, the 2nd and 3rd level of the sustainable development teams, which are the ESG Category Owners
and ESG Initiative Owners respectively, select and assess the topics from a library of topics while this is being enriched and
renewed with other topics recognized as relevant to the Company's lines of business activity. The assessment of the topics is
accompanied by relevant documentation with commentary for each score separately both on the severity parameters (impact
risk scale, impact range, irreparable impact nature) and on that of the probability. Then, the Sustainability Leaders being the 1st
level of the Sustainable Development Teams review the identified impacts and the relevant documentation provided and approve
the overall recognition. Validated assessments are forwarded to the Management of the relevant Sector or Subsidiary or CF for
final verification and confirmation by their senior management.
Moreover, METLEN recognizes that interaction with its Stakeholders is essential for understanding the impact of its business
activities. For this reason, a series of dialogue and communication practices
15
with the Company's various Stakeholder groups are
implemented according to the results of the central consultation with the key Stakeholders (see SBM-2), resulting in the fact that
the overall sustainable development management strategy and related impacts creates significant opportunities for both them
and the Company. This consultation highlighted that a high-level focus on mitigating negative impacts not only limits the direct
impact of actual impacts, but also reduces the likelihood of potential negative impacts occurring. This strategic approach also
reinforces the leveraging of positive impacts — both actual and potential — and guides the company towards dynamic growth
on strong, sustainable foundations. [IRO_1_53_b_iii]
C. Double Materiality Assessment
Based on the results of the impact assessment carried out by the Company in 2024, which are presented in the following table
(see Table/Figure No. IRO-1/02), matched with the European sustainability reporting standards (ESRS), it appears that eleven (11)
material sustainable development topics were material topics in the previous year (2023) as well, while one new material topic
has emerged, "Responsibility of Products and Services". The main change in the 2024 list of material sustainability topics,
compared to that of 2023 is the non-recognition of four topics as independent. In particular, the "Business Model" and
"Regulatory Compliance" topics are cross-cutting across the Company's strategy and are integrated into every aspect of managing
all sustainable development issues. Also, the "Business Continuity” topic is partly incorporated into the Health & Safety process
analysed in ESRS-S1. Finally, "Cybersecurity" continues to be a strategic priority for METLEN, in the context of its wider digital
transformation and also horizontally permeates all its activities. [IRO_1_53_b_iv]
METLEN has established specific thresholds to effectively manage both negative and positive impacts of its activities. Specifically:
a) Negative Impacts
METLEN set a negative impact threshold of seven (7) (on a scale of 0-15), considering both the inherent risks associated with the
nature of its activities and the maturity of its mechanisms. This approach is based on the recognition that:
1) It operates in industries where inherent risks, such as environmental pollution, impacts on biodiversity and ecosystems,
greenhouse gas emissions, and consumption of natural resources, are unavoidable. Value seven (7) allows focusing on those
impacts that go beyond the acceptable limits of these risks, differentiating critical cases from typical ones already managed
through the embedded mechanisms.
2) Has already developed and optimized mitigation and prevention systems, which allows it to identify material negative
impacts only when they cross a clear critically important line. Threshold 7 indicates that the Company has the appropriate
tools to timely detect and address less severe impacts, leaving the focus on the more substantial ones.
15
As presented in Section ESRS:SBM-2
5. Annual Board of Directors Management Report
100
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
3) The choice of a threshold below the mean allows the timely identification of critical impacts without over-emphasis on low-
intensity incidents, which may divert resources from more important issues.
4) With this threshold METLEN considers that the actual negative impacts have been mitigated to a significant extent, allowing
the focus to shift on issues of greater importance.
b) Positive Impacts
Respectively, setting the threshold at six (6) (on a scale of 0-10) for positive impacts highlights METLEN's proactive attitude
towards value creation through sustainable development opportunities. This approach is based on the recognition that:
1) It recognises as material only those opportunities that have a material impact on both the creation of corporate value and
the contribution to sustainable development. This avoids identifying low-impact opportunities that could lead to diffusion of
the strategic effort.
2) Emphasizes initiatives that incorporate sustainability not only as an obligation but as a strategic priority. Opportunities with
little contribution to sustainable development are not considered a priority.
3) Seeks projects and initiatives that make a substantial difference in the market, focus on positive outcomes with a material
impact on society, the environment, and the economy.
4) Enhances its role in projects that affect not only its own performance, but also the broader ecosystem, such as local
communities, partners and the environment.
3. Overview of the Management Process for Risks and Opportunities having Financial Consequences [ESRS2-IRO_1_53_c]
The Business Risk Management Division conducts an annual or as-needed risk identification process with the aim of strengthening
and updating the company's Risk Register. In this process, information is gathered from various sources, such as proposals from
Risk Owners, reports on emerging new risks, and results from the assessment of the company’s impact on sustainable
development (impact materiality). The Business Risk Management Department reviews this information either to improve the
description of existing risks or to add new risks, ensuring that the Risk Register remains updated and covers the key risks of the
company. At the same time, alignment with the results of the sustainability impact assessment is ensured.
The Company's Risk Register is broken down into four dimensions, which include:
a) Risk Category (Level I)
b) Risk Sub-Category (Level II)
c) Risk Occurrence Factors (Level III)
d) Key elements of the Internal Control System (Level IV) that contribute to risk management
Upon completion of risk identification, the Business Risk Management Division coordinates and supports Risk Owners in risk
assessment. Risks are analyzed and assessed at Level II by the participants in the risk assessment processes, using the additional
information included in the Risk Register, with a view to assessing all factors at play in the materiality of each risk. Risk Owners,
supported by the Business Risk Management Division, assess the risks by considering criteria related to the impact, the likelihood
of occurrence and the design of the internal control system to calculate the intrinsic and residual risk.
The level of inherent risk for each identified risk is the product of potential impact (financial, operational, reputational and
sustainable development) and the reasonable likelihood of the risk occurring.
Finally, the Business Risk Management Division analyzes the data of the risk assessment process to identify the main risks that
may affect the Company's business objectives and operations.
Through the approach described above, METLEN has fully integrated, as outlined in the table below, the recognized existing and
potential impacts of its corporate activities on sustainable development as risk factors in the relevant list of Risk Subcategories
(Level II) 'Sustainability,' 'Human Resources,' 'Health and Safety,' and 'Regulatory Compliance' of the Company's Enterprise Risk
Management Framework
16
. In this context, the potential economic impact that could arise from their occurrence was considered
within the overall assessment of the respective Risk Subcategories (Level II) and the adoption of appropriate management
measures.
16
A complete analysis of METLEN's business risks is provided in Chapter 2.6. “Enterprise Risk Management” within this Integrated Report.
5. Annual Board of Directors Management Report
101
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Furthermore, both positive and negative impacts resulting from the implementation of dual materiality were subject to targeted
analysis to identify and assess the risks and opportunities involved. In this context, the Heads of Business Activities and Central
Human Resources and Compliance Services actively participated in the process, contributing to the identification and assessment
of potential risks and opportunities, with the aim of highlighting those that may have the greatest negative or positive impact
respectively on the Company. At the same time, risks and opportunities were examined in terms of the time horizon within which
they may affect the Company's strategy and operation. They were then prioritised, with emphasis on those likely to bring the
most significant potential impacts or advantages, in order to formulate appropriate management and exploitation strategies.
The tables below comprehensively reflect the assessment of impacts as well as the individual risks and opportunities identified
depending on the nature of the impact.
Evaluated Risk:
Financial
significance
Time horizon
Position in the
Value Chain
SUSTAINABILITY
High
IMPACT
Ε1
Release of CO
2
emissions from energy-intensive
activities
Actual
M
RISKS
Ε1-R1
Increased carbon emission allowance prices
Very high
Short-term,
Medium-term,
Long-term
M
Ε1-R2
Increased electricity and natural gas prices
Very high
Short-term,
Medium-term,
Long-term
M
Ε1-R3
Increased investment costs for the transition to
low-carbon technologies in primary aluminium
production
Very high
Medium-term,
Long-term
M
Ε1-R4
Increased electricity and gas sales prices due to
mitigation policies leading to reduced demand and
revenue losses
Very high
Short-term,
Medium-term,
Long-term
M
Ε1-R5
Rising temperatures
High
Long-term
Μ
Ε1-R6
Increased frequency of extreme weather events
High
Short-term
Medium-term,
Long-term
Μ
IMPACT
Ε2
Emission of NOx, SOx and other significant gas pollutants
Actual
M
IMPACT
Ε2
Degradation of soil and water & marine resources due to significant
pollution incidents
Short-term
U M D
IMPACT
E3
Salinization of groundwater resources due to over-abstraction
Short-term
Long-term
M
IMPACT
E4
Degradation of marine ecosystems
Short-term
M
RISK
E4-R1
Costs associated with the decommissioning of
installations at the end of their useful life
Very high
Current
Short-term
Medium-term,
Long-term
M
Evaluated Risk:
Financial
significance
Time horizon
Position in the
Value Chain
HEALTH & SAFETY
Low
IMPACT
5. Annual Board of Directors Management Report
102
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
S1 & S2
Workplace safety incidents and their consequences
Actual
M D
IMPACT
S1 & S2
Health & Safety incidents at work and their consequences
Short term
U M D
IMPACT
S1
Workplace safety incidents and their consequences
Actual & Short-
term
M D
RISKS
S1-R1
Private insurance costs, compensation, and
medical expenses
High
Short-term,
Medium-term
M D
Evaluated Risk:
Financial
significance
Time horizon
Position in the
Value Chain
HUMAN RESOURCES
High
IMPACT
S1
Management and monitoring of working conditions
Actual
M
RISKS
S1-R1
Increase in operating costs for taking additional
measures to improve working conditions, mental
health, and generally the effective management of
issues affecting employees
High
Short-term,
Medium-term,
Long-term
M
IMPACT
S1
Development of measures related to fair treatment
and equal opportunities
Actual
M
RISKS
S1-R1
Additional operating costs from expenses for
managing and balancing gender pay disparities,
particularly among middle management
High
Short-term,
Medium-term,
Long-term
M
Evaluated Risk:
Financial
significance
Time horizon
Position in the
Value Chain
COMPLIANCE
Medium
IMPACT
G1
Emergence of unethical practices in the value chain
Short-term
U M D
RISKS
G1-R1
Potential exclusion from new agreements and
entry into new markets due to indirect
involvement in unethical practices, especially in
countries with a high corruption index
Very high
Short-term,
Medium-term,
Long-term
U M D
G1-R2
Potential decrease in the Company’s ability to
attract responsible partners and investors,
reducing its long-term competitiveness
High
Short-term,
Medium-term,
Long-term
U M D
G1-R3
Possible financial penalties and loss of revenue
from investors and customers who prioritize
transparency
Very high
Short-term,
Medium-term,
Long-term
U M D
Explanation of the Economic Significance Scale:
Very High (>€50m), High (€10-50m), Medium (€1-10m), Low (€100k–1m), Very Low (<€100k)
Position in the Value Chain: Upstream (U), Own Activities – METLEN (M), Downstream (D)
Table/Diagram Νο. IRO-1/02
The recognized positive impacts arising from the impact assessment are not included in the current evaluation of financial
significance. However, the Company is considering overall the options for their inclusion in the total exercise.
5. Annual Board of Directors Management Report
103
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Evaluated Opportunities
Financial
Significance
Time horizon
Position in
the Value
Chain
IMPACTS
Ε1
Activities focused on accelerating the
energy transition
Actual
Μ
OPPORTUNITIES
Ε1-Ο1
Investments in renewable energy sources
and storage systems
Very high
Short-term
Medium-term
Long-term
Μ
Ε1-Ο2
Investments in new technologies: energy
storage systems through batteries,
forecasting technologies for renewable
energy systems, etc.
High
Medium-term
Long-term
Μ
IMPACTS
Ε1
Achievement of climate targets and
commitments
Medium-term
Μ D
IMPACTS
Ε3
Reuse of seawater discharges
Actual
Μ
OPPORTUNITIES
Ε3-Ο1
Ensuring production stability and reducing
the need for additional investments and
extra operating costs
Very high
Short-term
Medium-term
Long-term
Μ
IMPACTS
Ε5
Use of aluminum scrap as raw material
Actual
Μ D
OPPORTUNITIES
Ε5-Ο1
Further gradual increase in revenue from
penetration into new markets focusing on
the demand for recycled aluminum
High
Short-term
Medium-term
Long-term
Μ Κ
Ε5-Ο2
Reduction in energy costs and increase in
production efficiency per ton of aluminum
Enhancement of liquidity with access to
investment financing in the Circular
Economy (Green Bond)
Very high
Short-term
Medium-term
Long-term
Μ Κ
Ε5-Ο3
Reduction in energy costs and increase in
production efficiency per ton of aluminum
Enhancement of liquidity with access to
investment financing in the Circular
Economy (Green Bond)
High
Short-term
Medium-term
Long-term
Μ Κ
IMPACTS
Ε5
Utilization of Bauxite residues
Medium-term
Κ
IMPACTS
S1
Safe employment
Actual
U Μ D
OPPORTUNITIES
S1-O1
Consistently strong financial performance
of the company, which also depends on
providing job stability supported by a high
employee retention rate, enhancing
productivity and work efficiency
High
Short-term
Medium-term
Long-term
Μ D
IMPACTS
S1
Continuous investment in human resources
Short-term
Μ D
OPPORTUNITIES
5. Annual Board of Directors Management Report
104
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
S1-O1
Further increase in productivity and
enhancement of the company's
competitiveness by strengthening
employee skill development and improving
its adaptability to new markets
High
Short-term
Medium-term
Long-term
Μ D
IMPACTS
S3
Creating value in local communities
Actual
Μ D
OPPORTUNITIES
S3-01
Facilitation of business activity and
development
Very high
Short-term
Medium-term
Long-term
Μ D
S3-02
Enhancement of productivity through the
utilization of local workforce
Very high
Short-term
Medium-term
Long-term
Μ D
IMPACTS
S4
Responsibility in the provision of Products
& Services
Actual
D
OPPORTUNITIES
S4-O1
Increase in market share and sales of the
company’s products by enhancing
customer trust, leading to increased loyalty
and continuous growth in demand
Very high
Short-term
Medium-term
Long-term
D
S4-O2
Enhanced ability to penetrate new markets
abroad in the retail electricity sector
High
Short-term
Medium-term
Long-term
D
IMPACTS
G1
Established business ethics culture / zero
tolerance for bribery and corruption
Actual
U Μ D
OPPORTUNITIES
G1-O1
Enhanced ability for the company to enter
new markets as a result of the transparent
and ethical business practices it adopts
Very high
Short-term
Medium-term
Long-term
U Μ D
G1-O2
Increased financing opportunities, more
stable commercial partnerships, and
enhanced credibility in the market
Very high
Short-term
Medium-term
Long-term
U Μ D
IMPACTS
G1
Responsible Supply Chain Management
Actual
U Μ
G1-O1
Enhancement of resilience and business
continuity by reducing the risks of
partnership disruptions, ensuring a stable
supply flow
High
Short-term
Medium-term
Long-term
U Μ
G1-O2
Enhancement of attractiveness to
institutional investors and financial
organizations that prioritize ESG criteria
High
Short-term
Medium-term
Long-term
U Μ
Explanation of the Financial Significance Scale:
Very High (>€50m), High (€10-50m), Medium (€1-10m), Low (€100k–1m), Very Low (<€100k)
Position in the Value Chain: Upstream (U), Own Activities – METLEN (M), Downstream (D)
Table/Diagram Νο. IRO-1/03
5. Annual Board of Directors Management Report
105
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
4. Decision-making and internal control processes [ESRS2:IRO_1_53_d]
The Sustainable Development Division, in cooperation with the Sectors, Subsidiaries or CFs, reviews all the individual assessments
and applies the predetermined thresholds to highlight the material topics, which include risks and opportunities for the
Company’s sustainable development.
The final result of the impact assessment process is approved at the highest level by the Corporate Governance & Sustainable
Development General Manager, and then forwarded to the Sustainability Committee for final confirmation, practically outlining
the minimum thematic content of the Sustainability Statement, which is complemented by the result of the 2
nd
part of the double
materiality assessment, i.e. the financial assessment.
All the topics arising from the two assessments (impact & financial materiality) form the Double Materiality result that the
Sustainable Development Division uses to prepare the Sustainability Statement in the context of the organisation’s Annual
Report. [ESRS2:IRO_1_53_d]
5. Incorporating results into the overall risk management process
As mentioned above regarding the assessment of financial materiality (Part B of the double materiality analysis), the Sustainable
Development Division informs, annually, the Business Risk Management Division on the final list of actual and potential negative
impacts, as they have emerged from the impact assessment exercise (Part A of the double materiality analysis). Then, the Business
Risk Management Division assesses the results and updates the Risk Register where necessary for completeness and to ensure
an integrated approach to risk management. All risks are assessed at a senior and top management level based on METLEN's
Enterprise Risk Management Process, which was also renewed in 2024. [ESRS2:IRO_1_53_e]
6. Incorporating results into the overall management process
METLEN integrates the process of identifying, assessing and managing opportunities into its overall strategy, which is
implemented following a holistic approach that combines economic stability with social and environmental sustainability. Having
a systematic approach, it assesses current challenges, such as climate change and societal challenges, and identifies opportunities
from energy transition and corporate responsibility. This process feeds into the systematic approach of three-level strategic
priorities detailed in section ESRS2: SBM-1, influencing operational decisions, ensuring that opportunities are assessed and then
decisions are made on both the approach and related actions, and the timeline for leveraging them. [ESRS2:IRO_1_53_f]
7. Inputs from sources used
METLEN uses a number of parameters in the Double Materiality process to ensure, as far as possible, a more comprehensive
impact assessment of its activities. These parameters include: [ESRS2:IRO_1_53_a] [ESRS2:IRO_1_53_g]
A. Data sources:
a) METLEN's Sustainable Development Strategy.
b) Information concerning the production process, such as energy consumption, use of raw materials, and waste
generation.
c) Data from the Company's internal monitoring systems covering issues of compliance with environmental and social
standards.
d) Reports from international organizations, such as the United Nations (UN), the International Labour Organization (ILO),
and the Organization for Economic Co-operation and Development (OECD), providing guidelines and best practices on
environmental and social issues.
e) Environmental, social, and governance criteria used by institutional investors and asset managers to select their
investment portfolios.
f) Data from analyses and reports of independent environmental consultants providing technical support for the
certification of Environmental and Health and Safety management systems.
g) Contractual requirements arising from its business relations with its suppliers that, apart from the quality of products
and services, concern the application of sustainable practices, as well as the observance of ethical standards.
h) ESG requirements used by specialised indicators and rating agencies to analyse the Company.
i) Publicity (Study of the topics of publications by and for the Company, as well as general publicity in this area, during
the last year).
5. Annual Board of Directors Management Report
106
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
B. The Scope comprising:
a) METLEN's operating units, such as the Company's production facilities, offices, and supply chains. Any activity that may
have an environmental or social impact is considered.
b) Special emphasis is placed on METLEN's suppliers and partners. Supply chain impacts (raw material management,
transport and distribution) are assessed.
c) Focusing on the areas where the Company is present or operates, and in the context of climate risks, Greece is the
subject of special focus.
d) Special assumptions considered.
e) Using climate scenarios to assess the potential impact of climate change on the Company's operations and prepare for
future risks. Data are assessed in the short, medium and long term to cover immediate and future impacts.
f) The likelihood of social risks, such as human rights violations or labour inequalities in specific regions or sectors, and
the impact of these risks on the Company and its reputation.
g) The use of environmental parameter monitoring tools, such as sensors to measure emissions and systems to monitor
energy efficiency.
8. Changes from previous reporting period
Defining the material sustainable development topics is a key tool of METLEN's responsible operation, and a dynamic practice
that is constantly evolving, contributing to the enrichment and shaping of the Company's Sustainable Development strategy.
Against this backdrop, the process for assessing material sustainable development topics was modified in 2024 to better respond
to new challenges and emerging market and stakeholder priorities.
Key changes compared to the previous reporting period include: [ESRS2:IRO_1_53_h]
a) Expanding the process by including the most relevant Central Functions of the Company, such as the Human Resources
General Division, the Regulatory Compliance Division, the Information Technology and Digital Strategy Division and the
Purchasing and Procurement Departments to ensure that all views on the environmental, social and ethical impact of the
Company's activities are taken into account.
b) Use of an electronic platform to record, assess, monitor and quantify impacts which facilitated the comparison of data
with European sustainability standards.
c) Adaptation to the new European sustainability reporting Directive CSRD, and alignment, to a large extent, with the
proposed EFRAG Implementation Guidelines, and more specifically in terms of impact assessment, where both the criteria
and the assessment methodology as proposed by the Directive were taken into account.
d) Connection of the process with the central business risk management system that covers the financial materiality part of
the Company's impact on Sustainable Development.
The Process of determining material sustainable development topics (Double Materiality Process) was last amended in December
2024. These changes included the adaptation to the new European sustainability disclosure standards (compared to the previous
process followed consistently in recent years by METLEN, based on the guidelines of the GRI Global Reporting Standards, which
were voluntary), the revision of the Stakeholder consultation tools, the connection with the central risk management system, as
well as the upgrading of the internal monitoring and reporting systems, with the aim of optimizing the data collection and analysis
process. The observance and renewal of this Process falls within the remit of the Sustainable Development Division under
METLEN’s Corporate Governance and Sustainable Development General Division.
9. Procedures for identifying and assessing significant climate-related impacts, risks and opportunities [ESRS 2 IRO-1]
The methodology developed and applied by the Company in assessing climate-related risks and opportunities includes the
following procedure.
Initially, the impact on climate change is taken into account, in particular the Company's emissions.
17
Following a relevant
analysis
18
, an initial list of climate risks and opportunities is drawn up for each METLEN Sector, also based on the relevant TCFD
recommendations. [ΕSRS2:IRO-1_20_a]
17
As described in accordance with disclosure requirement ESRS E1-6.
18
The company has mapped all its core activities, recording its energy consumption and related CO₂ emissions. This includes analysing fuel consumption,
electricity and industrial processes that generate emissions. At the same time, the company evaluates possible future sources of emissions, taking into account
5. Annual Board of Directors Management Report
107
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
During the analysis, potential risks and opportunities that can affect the supply of the Company's units in the upstream value
chain, such as rising raw material prices, were examined. In addition, the increase in fuel costs related to the transportation of
raw materials was assessed, which was estimated in the High-risk range, due to the increased probability of occurrence without,
however, recognizing the need to anticipate significantly higher expenditure than already budgeted per year. Accordingly, the
potential impact on the distribution of products and services in the downstream value chain was examined. Given the vertically
integrated structure of the Company, no further analysis of supplier and partner locations was deemed necessary.
Subsequently, all risks and opportunities identified were assessed against two key criteria: the significance of the consequences
resulting from the climate risks and opportunities under review and the degree of certainty that these consequences will occur.
Each of these criteria is broken down into individual sub-criteria, which are scored on a scale from 1 to 5. A score of 5 per sub-
criterion means very high severity/certainty, while a score of 1 per sub-criterion means respectively very low severity/certainty.
The overall severity and certainty for a climate risk or opportunity results from the sum of the scores of the individual sub-criteria
included in each evaluation criterion. Specifically:
1. Criterion of significance: This criterion examined the severity of the possible consequences that may result from the
identified risks and opportunities, using the following sub-criteria: i) Timeframe: Consequences were assessed on three
levels: Short-term (2022-2025), Medium-term (up to 2030), Long-term (up to 2050). ii) Financial Impact: The analysis
examined the potential impact of risks and opportunities on the company's financial results. Considering the sum of these
two sub-criteria, the overall significance of a climate risk or opportunity can be scored on a scale of 2-10. Risks or
opportunities rated above 6 are considered significant and should be considered in more detail and, as far as possible, in
quantitative terms.
2. Criterion of certainty: This criterion assessed the likelihood that the identified risks and opportunities would materialize,
based on the following sub-criteria: i) Confidence: The ability to quantify risks or opportunities through climate scenarios,
as well as the availability of reliable data. ii) Sensitivity: The variability of operating parameters related to climate risks
and opportunities, based on the different climate scenarios considered. iii) Likelihood of Specific Outcome: The analysis
of the direction and/or rate of change of parameters associated with climate risks and opportunities. Considering again
the sum of these two sub-criteria, the overall significance of a climate risk or opportunity can be scored on a scale of 3-
15. Risks or opportunities with a score greater than or equal to 9 are considered more likely to occur and should be
considered in more detail. [ΕSRS2:IRO-1_21]
Following the implementation of the criteria, risks and opportunities are classified into four groups for each of METLEN's Sectors:
a) High significance and high certainty risks / opportunities. To the extent possible, these risks and opportunities are
analysed in quantitative terms, using the baseline information of the different climate scenarios as well as available data
on METLEN's future development. Proactive (forward-looking) actions are foreseen to integrate these risks and
opportunities into future METLEN policies.
b) High significance and low certainty risks / opportunities. These risks and opportunities are systematically monitored, and
to the extent that they appear to constitute a significant risk or opportunity for METLEN, appropriate management plans
will be developed. However, no immediate action is required.
c) Low significance and high certainty risks / opportunities. These risks and opportunities are monitored without further
need to develop appropriate management plans.
d) Low significance and low certainty risks / opportunities, which are not considered to be material.
The results of the aforementioned procedure are presented in the section "Climate-related risks and opportunities that the
Company has identified in the short, medium and long term".
In addition to the scenario analysis, the following Tables 3 and 4 present the climate physical risks and transition risks associated
with the Company's activities, based on their economic valuation.
These risks are classified in the following categories:
Very High (VH): in cases where the corresponding financial impact is critical and is estimated to exceed €50 million.
expected changes in its activities, such as increased production or the introduction of new technologies. In addition, external factors, such as future regulatory
requirements and sustainability trends, are considered to adapt in a timely manner to developments. Finally, METLEN assesses the potential carbon footprint of
new projects and installations and analyzes how existing emissions will be affected by planning the integration of emission reduction initiatives. All of the above
elements are applied in the current exercise to review its climate objectives and initiatives.
5. Annual Board of Directors Management Report
108
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
High (H): where the corresponding financial impact is significant and ranges between €10 and €50 million.
Medium (M): where the corresponding financial impact ranges between €1 and €10 million.
Low (L): where the financial impact is insignificant to minor and, in any event, less than €1m.
Assessment of the main climate-related potential physical risks identified and assessed for METLEN's various activities.
[ESRS2.IRO1_AR_11_a]
MAIN PHYSICAL RISKS
METALS SECTOR
ENERGY SECTOR
19
Chronic effects (Rising average temperatures)
Weak/Lax Policies
(L)
(H)
Current Policies
(L)
(M)
Strong Policies
(L)
(M)
Extreme effects (Heatwaves)
Weak/Lax Policies
(L)
(H)
Current Policies
(L)
(M)
Strong Policies
(L)
(L)
Table 3.
Regarding other natural events, such as long-term reduction of rainfall, rising sea levels, changes in wind patterns, intense frosts,
storms, fires, atmospheric instability with frequent lightning (CAPE index), strong winds and periods of no wind, are considered
as low-risk events for all activities of the Company.
Assessment of the main climate-related potential transition risks identified and assessed for METLEN's various activities
[ESRS2.IRO1_AR_12_b]
MAIN TRANSITION RISKS
METALS SECTOR
ENERGY SECTOR
Increased carbon allowance prices
20
Weak/Lax Policies
(H)
(VH)
Current Policies
(VH)
(VH)
Strong Policies
(VH)
(VH)
Increased electricity and natural gas prices leading to increased operating costs
Weak/Lax Policies
(VH)
Current Policies
(VH)
Strong Policies
(VH)
Increased electricity and natural gas sales prices due to mitigation policies leading to reduced demand and revenue losses
21
Weak/Lax Policies
(L)
Current Policies
(VH)
Strong Policies
(VH)
Increased cost of investments for the transition to low-carbon technologies in the production of primary aluminium
22
Weak/Lax Policies
(L)
Current Policies
(VH)
Strong Policies
(VH)
Table 4.
Climate-related risk management processes
19
In the Energy Sector, this risk is mainly identified in energy production from natural gas thermal plants (Own Operations). In all other activities of the BU, these
risks are characterized as Low.
20
In the Energy Sector, this risk is mainly identified in energy production from natural gas thermal plants (Own Operations).
21
In the Energy Sector, this risk is mainly identified in the supply of electricity and natural gas (Own Operations).
22
In the Metals Sector, this risk concerns mostly interventions mainly at the electrolysis stage, but also at the mining process stage that requires investments in
mechanical equipment (Own Operations).
5. Annual Board of Directors Management Report
109
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Existing measures and strategies to mitigate and manage the aforementioned risks and strengthen the Company's resilience.
1) METLEN has a comprehensive climate change strategy in place, which guides its initiatives to reduce carbon dioxide emissions
according to the Kyoto Protocol, the Paris Agreement on Climate Change (CoP21) and the respective Greek National Energy
and Climate Plan (NECP) which specifies Greece's contribution to the European Green Deal. METLEN is the first Greek
industrial company to set specific, measurable and ambitious targets for the reduction of CO
2
emissions by 2030 and net zero
emissions by 2050, thus highlighting the reduction of the carbon footprint as a priority of its Sustainable Development Strategy
(detailed information on CO
2
emissions reduction initiatives are presented in the section "Actions and resources related to
climate change policies").
2) The Company's Sectors are in close cooperation with the Regulatory Affairs Division, which has a strong presence in the EU,
participating in initiatives or associations that take positions on any policy, law or regulation that may affect the climate.
Specifically, the Regulatory Affairs Division interacts with policy makers by sending relevant documents or occasionally
attending meetings, to ensure that they are aware of and understand the Company's positions as well as the proposed
improvements to the legislation.
3) METLEN implements emissions pre-purchase offsetting mechanisms through the Finance Division, while enhancing
synergies between its Sectors, such the Energy Sector supporting the Metals Sector develop an alternative energy "basket"
and help it transition to green energy.
4) The Company is expanding its own Renewable Energy Sources portfolio to increase its share in the electricity market.
5) The Company participates in the Greek Energy Exchange, which allows the adjustment of electricity prices according to cost
fluctuations. The increased costs associated with the purchase of emission allowances are incorporated into the price of the
energy sold and offset through the pre-purchase of emissions. At the same time, the Company considers the needs of
electricity consumers, balancing the imposition of these increases in order to maintain competitive prices.
6) Finally, each Sector implements the following adaptation and protection measures against various natural hazards:
To manage extreme weather and natural events, METLEN adopts a range of risk management approaches that include insurance
coverage, identifying potential weaknesses and design of corresponding action plans (ex-ante and ex-post, such as reinforced
structures) as well as a crisis management framework, with clear roles, responsibilities and escalation/information protocols to
manage unforeseen events:
Energy Sector: Emergency Action Plans have been developed for the Company's thermal plants to address the occurrence of
extreme natural events (heatwaves, frosts, storms, floods, etc.), and special flood protection designs have also been prepared at
the locations where there are streams passing near the Company's facilities. As regards the operation of RES units, wind turbines
are equipped with safety systems which, in case of very strong winds, shut down the generators and adjust the blade pitch to a
safe position, while the surfaces (panels) of the solar modules are made of hail-resistant material. In addition, regarding the
Company's business activity abroad, appropriate protection measures have been defined and implemented within the
boundaries of its facilities and construction sites to ensure that all conditions leading to deviations from the smooth operation of
the Sector are effectively addressed.
Metals Sector: Studies have been carried out on the risks of floods, accidents and disasters, and existing infrastructure has been
improved and new infrastructure has been built to address even the most extreme weather events. Contingency action plans
have also been developed. In the context of mining activities to date, no particular impact has been identified on the Company's
underground facilities that would require the implementation of specific adaptation measures. A water resources availability-
related climatic risks study was also carried out.
Integration of climate risk identification, assessment and management procedures into the Company's central risk
management system.
The Company has developed the Enterprise Risk Management Framework, based on international standards COSO ERM and ISO
31000, to identify and assess the most significant risks that may affect its operational and operating objectives. The task of
identifying and managing climate risks is performed through a coordinated process, which starts from the materiality process,
i.e. the identification and evaluation of key impacts of the Company's activity on sustainable development, and ends with
populating and assessing the Company's business risks. In this context, the specifications of the TCFD recommendations are used
for the economic valuation of risks and opportunities, where feasible, associated with climate impacts. The data collected
populates the Risk Register, which is a key component of the Enterprise Risk Management Framework. This framework ensures
the systematic identification, assessment and management of climate risks, aligning the Company's activities with best risk
management practices.
5. Annual Board of Directors Management Report
110
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Procedures for the identification and assessment of significant pollution-related impact, risks and opportunities [ESRS
2 IRO-1]
In the context of the implementation of its ISO 14001 certified environmental management systems for its operations, as well as
the implementation of Best Available Techniques (BAT), METLEN Energy & Metals systematically audits its key assets and
activities to identify and manage any actual and potential pollution-related impact.
As part of the materiality assessment, the Company took into account the locations of facilities where pollution is likely to be a
material issue for its operations, as well as its upstream and downstream value chain, over which it has operational control. In
addition, it considered business activities related to significant impacts, risks and opportunities in relation to pollution, ensuring
an integrated approach to managing its environmental impact.
In the METLEN Metals Sector, the environmental impact of facilities and business activities is controlled and evaluated in
accordance with the environmental management standard ISO 14001 (assessment of environmental aspects), as well as with
the sectoral Standard Aluminium Stewardship Initiative (ASI). In primary and secondary aluminium units, as well as in its mining
business, environmental analyses are regularly maintained and updated as provided for by the standard; these prioritize and
evaluate environmental aspects, by identifying and evaluating (through risk assessments) the significant impact associated with
air, water resources and soil pollution. Threats and opportunities are also recorded and analysed, identifying risks and impact on
the organization, as well as the causes and control and prevention measures required.
The environmental impact on the Sector's facilities is reported and evaluated in the Environmental Impact Assessment Reports
and the Approved Environmental Permits (AEPs), through which limits, standards and measurement indicators and monitoring
schedules for various pollutants, noise parameters and generated waste are defined. These analysis reports concern the
Company's relevant activities and cover mining activities as part of the upstream value chain as well as the storage, transport and
port activities as part of the downstream value chain.
Regarding the consultation with affected communities on emissions and pollution, no specialised consultations have been carried
out; however, the Metallurgy Sector has developed mechanisms for the handling of third-party requests and complaints.
Specifically at the Aluminium of Greece plant, there is an internal process for the reception and handling of environmental, social,
and ethical requests and complaints by stakeholders, including local communities. Interested parties may communicate through
a special form, by e-mail, telephone, or postal letter (see ESRS S3-Affected Communities). METLEN also maintains a centralised
Whistleblowing mechanism, as well as the possibility for communication initiatives with external bodies, including the media and
local authorities. The said communication includes dispatch of relevant material, information on environmental and labour issues,
as well as the dispatch of incident or accident reports, contributing to the enhancement of transparency and responsible
entrepreneurship.
In the METLEN Energy Sector, all facilities operate under an ISO 14001 system, and(?) the majority of activities are certified in
accordance with the said standard, while all applicable environmental legislative requirements are adhered to, thus ensuring the
ongoing improvement of environmental performance.
In the sectors of M Energy Generation & Management, M Energy Customer Solutions and M Integrated Supply & Trading, a
process is in place to identify and evaluate environmental aspects and impacts per activity, including offices and retail stores.
Also, in the field of new energy products (M Energy Customer Solutions, electromobility, smartmeters, etc.), an Environmental
Project Management Plan is implemented, through which the environmental analysis and evaluation per project is covered. In
particular, the Best Available Techniques (BATs) are applied in the Energy Centers, achieving the reduction of environmental
impacts from the design phase and the obligations arising from AEPOs are closely monitored.
In the offices and facilities of M Power Projects and M Renewables, environmental analysis is carried out by prioritizing and
evaluating environmental aspects. Significant risks related to air, water and soil pollution are identified and assessed through a
Risk Assessment. At the same time, the recording and analysis of threats and opportunities includes the identification of risks
and impacts for the organization, as well as the causes and control and prevention measures.
The Energy Sector closely monitors the obligations arising from the Approved Environmental Permits (AEPs) for its projects; such
obligations are, however, undertaken by the Project Owner, whether it is an individual or a public body. MPP, as the main
contractor, takes care/tends to? the implementation of the AEPs, undertaking waste management initiatives and providing
annual consolidated statements to the Project Owner for the annual Waste Report submitted to the Electronic Waste Register
5. Annual Board of Directors Management Report
111
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
(EWR) of the Ministry for the Environment and Climate Change. Waste management is carried out by certified/ licensed partners.
METKA ATE, a subsidiary of METLEN Energy & Metals, in compliance with ISO 14001:2015, applies a certified Environmental
Management System that includes the Environmental Analysis of activities in its offices and construction sites. Such analysis is
carried out in order to prioritize and evaluate environmental aspects, while risk assessment identifies and assesses significant
risks associated with air, water resources and soil pollution. Threats and opportunities are also recorded and analysed, identifying
risks and impact on the organization, as well as the causes and the control and prevention measures.
In projects carried out by METKA, environmental management is determined by the Approved Environmental Permits (AEPs)
issued by the Project Owner (private or public body) and covers environmental requirements. METKA, as the main contractor,
tends to the implementation of the AEP terms concerning the manufacturer, and feeds the Project Owner with the necessary
data for the latter's own obligations.
Despite the fact that METLEN does not carry out special direct consultations with local communities on emissions and pollution
(a responsibility that belongs exclusively to the Project Owner),when it comes to solar energy construction, energy storage and
large-scale energy projects of the Energy Business Unit, as well as construction and infrastructure projects undertaken by METKA
ATE, the subsidiary company, it has an internal mechanism for the reception and handling of requests and complaints that applies
to all its branches and subsidiaries. This mechanism is accessible to all stakeholder groups, including local communities, and
provides for complaints through a special contact form, email (METLEN@ethics.email), a postal letter, as well as through a
personal meeting with the Compliance Manager.
As part of the consultation with potentially affected communities on pollution issues, the recent survey conducted in the context
of the annual Social Partner Consultation, also highlighted the following conclusions: a) this issue together with the issues of
pollution prevention and marine ecosystems' protection related to water management, are considered sustainable development
opportunities and not risks, (b) local community representatives, adjacent to the company's main production units, rate the
management by the Company very positively in terms of the protection of local community rights, including the pollution
prevention, while recognizing that the management of this impact has a positive impact on the Company's operation, reputation
and financial performance. [ESRS2:IRO1_11_b]
11. Description of the processes to identify and assess material water and marine resources-related impacts, risks and
opportunities [ESRS 2 IRO-1]
In the context of implementing its ISO 14001-certified environmental management system and applying Best Available
Techniques (BAT), METLEN consistently audits its key assets and operations to identify and manage actual and potential impacts,
risks and opportunities related to water and marine resources. Through environmental impact assessment, risk management and
continuous monitoring, METLEN aims to reduce negative impacts, save water resources and sustainably develop while complying
with legislative requirements. In addition, in the context of the value chain mapping and Double Materiality assessment that took
place, the impacts related to water and marine resources both on METLEN's own activity and on the upstream and downstream
value chains were examined, as well as related risks and transition opportunities. Furthermore, the dependencies on marine
resources were assessed and it was recognized that the most important impacts and associated risks are related to the operation
of the "Aluminium of Greece" plant and the Company's energy thermal power stations.
Most of METLEN's activities involving water (almost 99% of total consumption) takes place in Greece
23
, and in particular, in the
area of Ag. Nikolaos, Viotia, where the aluminium production plant and the majority of the Company's thermal power plants are
located. In this context: [E3:E3-2_17]
a) The Metals Sector has completed a special Risk & Impact Assessment in the underground aquifer, using GIS (Geographic
Information Systems) models, as well as a series of hydrogeological studies, in the area of the alumina and aluminium
production plant and the network of seventeen (17) boreholes it manages. The abstracted amount of water is consumed
for industrial – energy use, as well as for water supply needs of production plants and neighbouring settlements . [E3:MDR-
T_80_a] [E3:MDR-T_80_f] [E3:MDR-T_80_g]
b) Environmental analyses of the alumina and aluminium production plant as well as thermal power plants are conducted,
prioritizing and evaluating their environmental aspects, in which significant risks related to water resources
23
The country is among the regions of the world identified as being at high risk of water scarcity. However, it is noted that according to the methodology of the
World Resources Institute, Aqueduct, Greece presents a minor trend of change in its groundwater volume potential.
5. Annual Board of Directors Management Report
112
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
management are identified and assessed. The relevant threats and opportunities are recorded and analyzed, while
identifying the risks/impacts, causes, as well as control and prevention measures. [E3:MDR-T_80_g]
c) Studies are also being carried out, in collaboration with HCMR, to assess the ecological status of Antikyra Bay in terms
of the seawater discharges used to cool thermal power plants. [E3:MDR-T_80_g]
d) At the same time, the environmental impacts of both the aluminium production plant and the thermal plants have been
analyzed in the Environmental Impact Study, while the Environmental Conditions Approval Decision (AEPO) has defined
limits and a measurements and monitoring program regarding water and marine resources management.
e) Specifically, there are continuous measurements conducted in thermal plants for the supply, consumption and discharge
of seawater, while a monthly report is generated capturing all seawater use and discharge data. In addition, Best
Available Techniques (BATs) are applied, such as water recycling plus collection and separate treatment of wastewater
streams, depending on their composition.
f) METLEN voluntarily participates in the global CDP Sustainability initiative, thus demonstrating its commitment to
responsibly manage the potential risks associated with the use of water and marine resources for its business activity.
The Company receives a relevant annual assessment, which is available in the "ESG Assessments" section of the
Company's website.
At the same time, in the context of the consultation with potentially affected communities related to the issue of water
management by METLEN, the recent central survey showed that representatives of local communities also evaluate very
positively the Company's management of their rights, including access to and use of natural resources, especially water. [E3:IRO-
1_8_b]
12. Description of processes to identify and assess material biodiversity and ecosystem-related impacts, risks and
opportunities [ESRS 2 IRO-1]
METLEN, through its ISO 14001-certified environmental management system and compliance with the environmental terms of
the Environmental Terms Approval Decisions (AEPO), implements a series of actions to identify and assess material impacts, risks
and opportunities related to the protection of biodiversity and ecosystems that derive from its key assets and activities, while
applying relevant Best Available Techniques (BAT). [ESRS2:IRO-1_17_a]
This includes:
In the Metals Sector, the alumina and aluminium production plant conducts biodiversity studies to analyze and monitor the
ecosystem in the industrial facilities’ zone of influence. This includes:
1. A 2020 Special Ecological Assessment (SEA) study conducted as part of the submission of a new Environmental Impact
Assessment (EIA).
2. A supplementary study on the biodiversity in the terrestrial environment in 2021, which includes a detailed recording of
the fauna and an assessment of the existence of alien invasive species.
3. An annual study in the framework of a three-year biodiversity monitoring programme in the terrestrial environment
(2024-2026).
4. A Special Ecological Assessment (SEA) study in the context of the submission of a new EIA in 2023, which is based on the
results of the 2021 study.
5. An annual Ecological Quality Study of Antikyra Bay, in collaboration with the Hellenic Centre for Marine Research
(HCMR), with particular emphasis on the impact on marine space and monitoring of thermophilic species.
Also, in Fokida, the mining activities of DELPHI-DISTOMON and European Bauxite are conducted in full respect of biodiversity.
Before the start of each new activity, Environmental Impact Assessment and Environmental Restoration Studies are conducted
ensuring the proper management of mining areas and their restoration, in strict compliance with the AEPO, to minimize any
alteration to the natural environment and landscape.
In the Energy Sector, METLEN considers biodiversity protection when designing and constructing wind farms and photovoltaic
parks as well as conventional energy projects. Especially for parks and farms located near or within areas designated as Natura
areas (either Special Management Areas or Special Protection Areas and Important Bird Areas), it is a prerequisite to prepare the
corresponding specific studies (special ecological assessment, annual monitoring of a protected area for two to five years or for
as long required by the competent environmental authority). If impacts are identified, mitigation or avoidance measures are
implemented and, if measures cannot be taken, the project is redesigned.
5. Annual Board of Directors Management Report
113
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
All elements of the above actions are considered in the overall assessment of the Company's impact on sustainable development,
in the context of double materiality.
In terms of the identified potential impact, ecosystem degradation can be caused by the discharge of cooling seawater, used in
power plants, as well as by discharges of water from industrial wastewater treatment plants. This type of discharge affects the
marine environment as it changes water temperature in estuarine areas. A major risk associated with increased temperature is
the growth of thermophilic species in specific points, which can disrupt the ecosystem’s natural balance. Thermophilic species,
adapted to warmer environments, may affect local organisms and biodiversity in the area, causing changes in species composition
and competitiveness of endemic organisms. [ESRS2:IRO-1_17_b] [ESRS:IRO-1_17_e(iii]
During implementation of the double materiality assessment, the impacts, dependencies and risks in METLEN's value chain in
relation to biodiversity were assessed, taking into consideration all its business activities and the procedures followed in relation
to environmental aspects. [ESRS2:IRO-1_17_c] [ESRS2:IRO-1_17_d]
Moreover, in the context of the environmental licensing of energy transition projects, renewable energy sources and mining
activities, as well as the installation or expansion of industrial facilities, local communities are consulted on all environmental
issues that must be considered under the applicable institutional framework, and the results of this consultation are used as
feedback for decision-making and in the finalised implemented business plans. [ESRS2:IRO-1_17_e (i) (ii) (iii)]
At the same time, in the context of the Company's central Stakeholder consultation, participants from communities potentially
affected due to their proximity to the Company's production plants, recognized that METLEN's biodiversity management in
relation to the rights of its local communities, including the rights of access and use of natural resources and especially water.
[ESRS2:IRO-1_17_e] [ESRS:IRO-1_17_e(ii)]
Therefore, the research overall reflects a positive impact from the representatives of the local communities neighboring the
Group's main production units, as they also evaluate very positively the Group's management in relation to the rights of the local
communities, including the rights of access to and use of natural resources, particularly water.
13. Description of the processes to identify and assess material resource use and circular economy-related impacts, risks and
opportunities [ESRS 2 IRO-1]
METLEN assesses impacts and associated risks and opportunities related to resource use, waste management and circular
economy:
1. in accordance with the requirements of its Environmental Management System Certified according to ISO 14001:2015
2. in compliance with its environmental obligations arising from legislation and the Environmental Conditions Approval
Decisions (AEPO) of its production plants
3. applying the relevant Best Available Techniques (BAT)
4. while performing value chain analysis in the context of application of the double materiality.
More specifically in the Metals Sector: [E5:IRO1_11_a]
1. environmental analyses are carried out prioritizing and evaluating the environmental aspects, which identify and evaluate
significant risks and opportunities related to waste management and circular economy. This process also records and
analyses relevant threats and opportunities as well as the causes and measures used for control, prevention and
utilization, respectively.
2. the plant’s environmental impact has been analyzed in the Environmental Impact Study, and the AEPO has set limits and
introduced a schedule for measurements and monitoring of waste management and resource use.
3. the application of Life Cycle Assessment (LCA) identifies the significant environmental impacts and risks associated with
resource consumption, while identifying opportunities for improvements, such as increasing recycling and implementing
circular economy in production processes. The study is carried out in accordance with the principles of standards ISO
14040 and ISO 14044, with the aim of providing all data required and in the context of Aluminium Stewardship Initiative’s
(ASI) Performance Standard certification.
All the above are feedback sources in the Double Materiality process to identify the impact of the Company's activity on
sustainable Development. Moreover, the Stakeholder consultation process revealed that circular economy is recognized as a
factor of opportunity by all participating parties, both for themselves and for the Company’s effective operation. It is also
recognized that circular economy contributes to enhancing the Company's reputation, as well as its financial performance.
[E5:IRO1_11_b]
5. Annual Board of Directors Management Report
114
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
5. Annual Board of Directors Management Report
115
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
CLIMATE CHANGE [ESRS: E1]
Important statements:
1. By publishing this section, METLEN Energy & Metals confirms that it complies with the requirements of the Financial Conduct
Authority (FCA) under Listing Rule 9.8.6 (8)R, including climate-related financial disclosures, in accordance with the
recommendations and proposed disclosure guidelines of the Task Force on Climate-related Financial Disclosures (TCFD).
When determining the Company's compliance with all 11 key recommendations and proposed disclosures of the TCFD, both
Section C of TCFD Annex entitled "Guidance for All Sectors", and Section E of TCFD Annex entitled "Supplemental Guidance
for Non-Financial Groups" were considered. In the context of these disclosures, the Company presents its approach to climate
issues, focusing on the pillars of governance, strategy, risk and opportunity management, as well as targets. The breakdown
is offered to the extent possible, considering the specificities of its business activity and that its climate culture is under
development. In the "Sustainability Statement Annexes" section, a relevant table of alignment of the Company with the TCFD
recommendations is published. Where compliance with some of these recommendations is not feasible, the Company also
presents, in the same section, a relevant table setting out the reasons why it has not aligned to date, as well as the actions it
intends to take to align it in future reporting periods.
2. In the past three years, METLEN has been experiencing dynamic growth, implementing a key transformation while pursuing
an important acquisition strategy. These activities, although critical to the Company's long-term growth and competitiveness
and its contribution to the global energy transition effort, are inevitably accompanied by increased carbon emissions, due to
the integration of new subsidiaries and activities that were not included in the limits of the initial climate target setting
exercise in 2020. Consequently, METLEN, maintaining its commitment for net-zero emissions in the year 2050, is in the process
of reviewing its interim climate targets (year 2030) and carbon reduction initiatives from its operations, taking into account
information emerging from the Company's recent acquisitions and strategic business choices. This review is necessary to
revise the estimates of future CO
2
emissions relating to the Company's key assets (Locked Emissions [E1: E1-1_16_d] [E1: E1-
1_AR_3_a]) and thus ensure that existing climate targets remain realistic and aligned with the broader corporate development
strategy; if they do not, then the targets will be adjusted accordingly, focusing on keeping the Company on the trajectory of
the WB2°C scenario as originally committed. Given that this exercise has an increased degree of difficulty as regards the
particularities of the different activities of the Company, it is expected to finish by the second half of 2025, and its results will
be published in the Report of that same year.
STRATEGY
Addressing climate change is a key pillar of broader Sustainable Development Strategy of METLEN
24
, and is directly linked to
the Sustainable Development Goals (7: Clean and Affordable Energy & 13: Climate Action). With its recent structural
transformation, the Company is strategically positioned at the forefront of the energy transition as a leading and integrated
"green" utility, at an international level, and as a reference point of the competitive "green" metallurgy at European level, thus
contributing substantially to the effort to decarbonize the global economy, which according to scientists must be achieved well
before the end of the 21st century and in the European Union by 2050.
Accordingly, the Company's approach is characterized by:
a) The application of its central Environmental Policy with special reference to tackling climate change and the responsible
use of energy and other natural resources, to advance its commitments and strengthen the effort to comprehend and
manage its risks and opportunities, as well as its climate-related impacts from its activities.
b) The climate commitments and targets as well as the initiatives undertaken to reduce its carbon footprint, both directly
linked to its business strategy.
c) Adopting the Task Force on Climate-related Financial Disclosure (TCFD) recommendations, as well as measures to
strengthen the resilience of its production plants in the context of its adaptation to climate change, considering relevant
risks and opportunities.
d) Aligning its basic administrative functions with climate-related issues.
e) Leveraging business opportunities in the energy transition.
24
As stated in section 2.2. Strategic Priorities & Business Model of this Sustainability Statement
ENVIRONMENTAL
XII.
5. Annual Board of Directors Management Report
116
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
f) Its voluntary participation in the global Sustainable Development initiative CDP - Climate Change, certifying, based on the
results of the annual evaluations by the Organization, that it undertakes coordinated actions to manage climate-related
issues and specifically climate-related potential risks and opportunities in its activity.
E1-1
Climate change mitigation transition plan
METLEN's targets and initiatives to reduce its carbon footprint were approved by the General Divisions of the Sectors and the
Board of Directors of the Company prior to their public announcement in 2021, in the context of a special event on sustainable
development. In this context, the Company's existing actions are aligned with the WB2oC scenario, as pointed out in the
introductory remarks of this chapter, and not with the 1.5oC scenario, required by the new European ESRSs standards, while they
are already in the review phase in order to formulate the Company's new transition plan which will be published in its next
integrated report, in 2026. [E1:E1-1_17]
a) Climate Commitments and Targets
METLEN has, since 2021, announced its commitment to net-zero CO
2
emissions (Scope 1 and Scope 2) by 2050. In this
context, it has set an absolute, centralized emission reduction target, which is overall in line with the WB2°C (Well Below
2°C) scenario
25
, with 2019 as base year and a first milestone in year 2030
26
, as defined in the Paris Agreement
27
. To achieve
the aforementioned main objective, the Company has developed corresponding overall and specific targets per
Sector, in the same context, implementing specialized action plans.
b) CO
2
Reduction Initiatives / Actions
METLEN implements specific emission
28
reduction actions, key among which are those directly linked to its core business
activities as well as to specific de-carbonisation mechanisms, including: Renewable Energy, Circular Economy and Energy
Efficiency.
c) Integration in Strategy and Financial Planning
The key actions of METLEN are aligned with the Company's overall business strategy and financial planning, their cost
being incorporated into the annual budget of each Sector and Subsidiaries, depending on the scope of the action. More
specifically, the investments related to the enhancement of the renewable energy portfolio include the financing of new
solar energy projects aimed at increasing clean energy production in the Energy Sector, while the corresponding
investments in upgrading the production of recycled aluminium achieve significant energy savings and additional
reduction of the carbon footprint in the Metals Sector. The quantification of the relevant capital requirements expenses
(CapEx) and operating expenditures (OpEx) as presented in the Company's alignment with the European Taxonomy section
confirms that these actions are critical elements of METLEN’s plan. The following is a basic explanation of the main aspects
of quantifying METLEN's investments and funding that underpin the implementation of its transition plan:
1) Identify Necessary Investments
METLEN has identified the investments needed to implement its transition plan. These investments include funds
directed to various areas, including:
1.1 Implementation of the renewable energy development plan to meet the Company's energy needs.
1.2 Enhancing Circular Economy, mainly in the Metals Sector.
1.3 Funding research and development to create and implement new greenhouse gas emission reducing technologies.
1.4 Investments in energy consumption reducing technologies and practices.
2) Financial Mechanisms
METLEN has several financial mechanisms in place to support these investments. The main sources of financing
include:
2.1 Funds derived from the company's profit which is reinvested and to support sustainability and energy transition
actions.
2.2 The Company has updated its "METLEN Green Finance Framework", extending its scope to cover one or more
issuances of Green Bonds, loans and other financial instruments, in accordance with its specifications.
2.3 The Company is also leveraging conventional loans and or special credit lines from banks and investors to support
sustainable projects.
25
Considering its emission reduction level, as defined by the Science-Based Targets Tool, for the WB2°C scenario.
26
As described in section: “Targets on climate change mitigation and adaptation”
27
METLEN is not exempted from the Paris-aligned EU benchmarks on the grounds that it derives < 50 % of its revenues from electricity generation with a
greenhouse gas intensity greater than 100 g CO
2
e/kWh. [ΑE-5]
28
As described in section: 'Actions and resources related to climate policies'.
5. Annual Board of Directors Management Report
117
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2.4 Finally, METLEN is constantly exploring how to best use government grants or tax incentives to implement energy
transition and sustainability projects in all countries where it operates.
3) Investment Quantification
29
METLEN carries out investment quantification, which includes:
3.1 Calculation of the costs for the transition plan’s most key actions, such as investments in the development of RES
and the production of secondary cast aluminium.
3.2 Analysis of the expected returns from the aforementioned investments in economic and environmental terms,
including emission reductions and operating costs.
3.3 Planning these investments over time to align them with the overall objectives of the business.
4) Monitoring and Reporting
METLEN monitors and publicizes the progress of investments and their financing through relevant publicly available
reports, as well as their impact on sustainability objectives such as key performance indicators of EU Taxonomy-aligned
OpEx
30
and CapEx
31
, and the issuance of special reports covering the projects funded by its green financing framework
(eg. Green Bond Reports).
ESRS2.SBM3
Significant impact, risks, and opportunities and their interaction with the strategy and business model
ACTUAL NEGATIVE IMPACT [AN-1]
32
:
Release of CO
2
emissions from energy-intensive activities
This impact is directly related to the operation of the aluminium plant and the thermal power plants. [SBM3_14_b] [SMB3_14_c]
[SMB3_14_d] [SBM3_14_AR_44]
Time Horizon:
Actual
Position in the Value Chain:
Own Operations
FINANCIAL RISK [E1-R1]: Increased carbon emission allowance prices
33
Financial Significance:
Very High
Time Horizon:
Short, Medium & Long Term
Position in the Value Chain:
Own Operations
FINANCIAL RISK [Ε1-R2]: Increased electricity and natural gas prices
Financial Significance:
Very High
Time Horizon:
Short, Medium & Long Term
Position in the Value Chain:
Own Operations
FINANCIAL RISK [Ε1-R3]: Increased investment costs for the transition to low-carbon technologies in primary aluminium
production
34
Financial Significance:
Very High
Time Horizon:
Medium & Long Term
Position in the Value Chain:
Own Operations
FINANCIAL RISK [Ε1-R4]: Increased electricity and gas sales prices due to mitigation policies leading to reduced demand
and revenue losses
35
Financial Significance:
Very High
Time Horizon:
Short, Medium & Long Term
Position in the Value Chain:
Own Operations
29
As reported in the Capital Expenditure KPI Table in section 2.8.4. European Taxonomy of Sustainable Investment of this Sustainability Statement [E1E1-
1_16_e]
30
As reported in the KPI Operating Expenditure Table in section 2.8.4. European Taxonomy for Sustainable Investment of this Sustainability Statement [E1E1-
1_16_e]
31
As reported in the Capital Expenditure KPI Table in section 2.8.4. European Taxonomy of Sustainable Investment of this Sustainability Statement [E1E1-
1_16_e]
32
As derived from the impact assessment and presented in Section 2.8.3. General Disclosures of this Sustainability Statement
33
In the Energy Sector, this risk is mainly found in the activity of energy production from natural gas thermal plants.
34
In the Metals Sector, this risk mainly concerns interventions mainly at the stage of electrolysis but also at the stage of the mining process that requires
investments in mechanical equipment.
35
In the Energy Sector, this risk mainly concerns the activity of electricity and natural gas supply.
5. Annual Board of Directors Management Report
118
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
FINANCIAL RISK [Ε1-R5]: Rising temperatures
Financial Significance:
High
Time Horizon:
Long Term
Position in the Value Chain:
Own Operations
FINANCIAL RISK [Ε1-R6]: Increased frequency of extreme weather events
Financial Significance:
High
Time Horizon:
Short, Medium & Long Term
Position in the Value Chain:
Own Operations
CURRENT AND POTENTIAL IMPACTS ON
THE BUSINESS MODEL
[ESRS2:SBM3_48_b]
CURRENT AND POTENTIAL IMPACTS ON
STRATEGY & DECISION-MAKING
[ESRS2:SBM3_48_b]
a) The need to comply with stricter environmental
regulations and the reorganization of energy-intensive
activities to be more energy-efficient.
b) In the coming years, the Company may need to look for
suppliers that have an energy transition plan, which could
bring changes to agreements and terms of cooperation, or
even limit the availability of raw materials.
a) Strategy adjustment
b) Integrating climate considerations into decision-making.
c) Adjustment of investment decisions.
d) Corporate governance alignment.
ACTUAL POSITIVE IMPACT [AP-1]
36
:
Activities focused on accelerating energy transition
This impact is directly related to the operation of the secondary cast aluminium plant and the renewable energy power
plants.
Time Horizon:
Actual
Position in the Value Chain:
Own Operations
FINANCIAL OPPORTUNITY [E1-O1]: Investment in renewable energy and storage systems
Financial Significance:
Very High
Time Horizon:
Short, Medium & Long Term
Position in the Value Chain:
Own Operations
CURRENT AND POTENTIAL IMPACTS ON THE BUSINESS
MODEL [ESRS2:SBM3_48_b]
CURRENT AND POTENTIAL IMPACTS ON STRATEGY &
DECISION-MAKING [ESRS2:SBM3_48_b]
a) Expanding the Company's business model by including
solutions and services that promote energy transition,
thus enhancing its activities and its financial results.
b) Developing partnerships with new suppliers and business
partners specializing in green technologies, upgrading the
value chain and enhancing the ability to provide integrated
solutions to customers.
c) Reinforcing the corporate image and reputation.
a) The Company's strategy has been redefined to include
dynamic participation in the energy transition market.
b) Integrating environmental and social considerations in the
decision-making process, especially regarding the
selection of partners and suppliers.
c) Strengthening investments in circular economy and RES, as
well as in innovative technologies and solutions that
support the energy transition, to develop high value-
added products and services.
d) Creation and implementation of a "Green Finance
Framework" to finance EU Taxonomy- aligned activities.
POTENTIAL POSITIVE IMPACT [PP-1]
37
:
Delivering on climate targets and commitments
This impact is directly related to all the Company's functional units and Central Functions.
36
As derived from the impact assessment and presented in Section 2.8.3. General Disclosures of this Sustainability Statement
37
As derived from the impact assessment and presented in Section 2.8.3. General Disclosures of this Sustainability Statement
5. Annual Board of Directors Management Report
119
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Time Horizon:
Medium Term
Position in the Value Chain:
Own Operations, Downstream
CURRENT AND POTENTIAL IMPACTS ON THE BUSINESS
MODEL [ESRS2:SBM3_48_b]
CURRENT AND POTENTIAL IMPACTS ON STRATEGY &
DECISION-MAKING [ESRS2:SBM3_48_b]
a) Improved competitiveness from compliance with
international climate targets.
b) Increased efficiency through the adoption of green
technologies.
c) Reinforcing the corporate image and reputation.
d) Further development of low carbon footprint products
and services, meeting the growing demand for sustainable
options.
a) Climate targets are embedded in the company's core
strategy as part of the pillar for tackling climate change,
leading to more sustainable business practices.
b) Decisions on investments in low-emission technologies
and renewable energy combined with cost management
of such investments.
c) Alignment with international regulations and standards
that enhance access to global markets.
d) Introduction of the Company's climate targets as a
criterion in the approval procedure for large projects.
Climate-related risks and opportunities in the short, medium and long term.
In order to ensure and assess its resilience to the risks it faces, METLEN has adopted a scenario analysis approach that includes
different time horizons. In particular, the analysis shall cover the short, medium and long term. These time horizons differ from
those used for the Double Materiality Assessment, however, the results of the two exercises are harmonised.
METLEN analyzes and prioritizes risks and opportunities associated with the impact of its activity on climate change and may
affect the activity of its two core Sectors, Metals and Energy. Identifying climate risks and opportunities comes in different time
horizons ensuring that the Company remains focused on current and upcoming risks and opportunities but also prepares for
future challenges and opportunities. The time horizons considered by the Company for the identification of climate risks and
opportunities, which differ from those mentioned in the ESRS 1 standard, were formed following the TCFD guidelines which
recommends that companies choose time horizons that are consistent with their business cycle, investments and the industry in
which they operate; so that they can accurately assess climate impacts and adapt their strategy accordingly. In detail: The time
horizons examined by the Company for the identification of climate risks and opportunities are the following: [ESRS2: SBM3_AR_7_b]
[ESRS2: SBM3_AR_8_b] [ESRS2: IRO1_AR_11_b]
a) Short-term [1 to 3 years]
The Company is focused on immediately identifying and addressing climate risks that can affect current operations and
annual planning. This is directly linked to the Sectors’ five-year business plans, as it allows the company to maintain
stability and timely respond to short-term changes.
b) Medium-term [4 to 10 years]
The Company prepares for potential changes in the climate and regulatory environment by adapting its corporate strategy
and developing products and services that meet future needs. This horizon is critical to achieving the business plan’s
medium-term objectives and enhances the Company’s sustainability in this environment.
c) Long-term [11 to 30 years]
Finally, the long-term horizon allows the Company to fully integrate climate risks and opportunities into its long-term
planning and corporate strategy. In this case, the focus is on innovation and creating resilient solutions that will help
ensure the Company's long-term success and sustainability, beyond the five-year business horizon.
The categories of climate-related risks for METLEN include:
1) Transition Risks: The Company's response to extensive changes in policies, legislation and technologies related to climate
change adaptation and mitigation measures, in the wider context of the transition to a lower carbon economy at national,
European and global level. Moreover, climate change is identified as a potential source of reputation risk associated with
changes in the way Stakeholders perceive the Company's contribution to a lower carbon economy.
2) Physical Climate Risks: These are risks related to strong or longer-term physical changes that are considered important for
the operation of the Company's industrial plants including, inter alia, destruction of infrastructure due to extreme weather
conditions, the reduction of available water resources due to less rainfall, sea level rise, loss of working days due to extreme
temperatures, the need to strengthen measures and actions to protect and restore the environment, etc. These physical risks
may have financial impacts, such as direct damage to assets, as well as indirect impacts due to supply chain disruption.
5. Annual Board of Directors Management Report
120
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Both transition and physical climate risks can affect METLEN and its operations. As the Metals and Energy Sectors incorporate
technologies and processes difficult to move away from fossil fuels (natural gas), the new regulatory requirements regarding
climate and energy may have significant consequences for the Company, both financially and otherwise.
Meanwhile, acute physical risks such as extreme weather events are of concern to all METLEN's activities as they could affect the
Company's plants, facilities, construction sites and normal operations. Depending on the Sector, some of these risks are more
significant.
The following table presents the overall climate-related risks identified in each of the Company's Sectors along with the respective
time horizons discussed. [ESRS:IRO1_AR_11_a] [ESRS2:IRO1_AR_12_a]
Business
Activity
Time
Horizon
Identified Climate-Related Risks
38
Metals Sector
(M)
Energy
Sector(E)
Short-term
Medium-term
Long-term
Transition Risks
Increased carbon allowance prices.
Ο
Ο
(M) - (E)
(M) - (E)
(M) - (E)
Increased electricity and natural gas prices.
Ο
Ο
(M) - (E)
(M) - (E)
(M) - (E)
Enhanced GHG emissions-reporting obligations
Ο
Ο
(M) - (E)
(M) - (E)
(M) - (E)
Increased electricity and natural gas sales prices.
Ο
(Ε)
(Ε)
(Ε)
Less access to capital and inflated cost of capital.
Ο
Ο
(M) - (E)
(M) - (E)
Abolition of support programmes for renewable
energy.
Ο
(Ε)
(Ε)
Improvements in building regulations resulting in
reduced demand/revenue.
Ο
(Ε)
Increased cost of raw materials.
Ο
(M)
(M)
Shift in customer preferences (primary versus
secondary cast aluminium, electricity from RES
versus electricity from fossil fuels, etc.).
Ο
Ο
(M) - (E)
(M) - (E)
Raw materials shortage due to global recycling
trends.
Ο
(M)
(M)
(M)
Reductions in the marginal price of electricity due
to increased RES penetration.
Ο
(Ε)
(Ε)
(Ε)
Grid management challenges related to the
integration of RES.
Ο
(Ε)
(Ε)
Increased pressure from shareholders and other
stakeholders due to sales of electricity form fossil
fuels and natural gas and carbon-intensive
products (e.g. primary aluminium).
Ο
Ο
(M) - (E)
(M) - (E)
Transition to low-carbon technologies in the
production of primary aluminium.
Ο
(M)
(M)
Reduction of production process efficiency until
the optimal integration of new technologies that
the Company will be obligated to adopt.
Ο
(M)
(M)
Physical risks / chronic
Rising temperatures and reduced machine
performance/employee productivity.
Ο
(Ε)
Rising temperatures and a reduced energy
demand.
Ο
(Ε)
Reduced precipitation and problems in water
availability in infrastructure.
Ο
Ο
(M) - (E)
(M) - (E)
Rising sea levels and flooding in infrastructure.
Ο
Ο
(M) - (E)
Changes in wind data and wind farm productivity.
Ο
(Ε)
Physical risks / acute
Increased frequency of extreme weather events
(heat waves, storms, fires, floods, etc.).
Ο
Ο
(M)
(M) - (E)
(M) - (E)
38
The proposed risks included in the TRCFD Tables A1.1 and A1.2 recommendations (pp. 75–76) have been taken into account. [TCFD L:15]
5. Annual Board of Directors Management Report
121
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Business
Activity
Time
Horizon
Identified Climate-Related Risks
38
Metals Sector
(M)
Energy
Sector(E)
Short-term
Medium-term
Long-term
Transition Risks
Extreme precipitation and flooding of mining sites
or waste disposal sites.
Ο
(M)
(M)
(M)
Table 1.
After overall risks were identified, the further analysis process
39
highlighted the following most significant ones, which may have
an impact on the Company's revenues and/or operating costs up to 2030, described below in the sections on the impact of risks
on the Company's strategy and financial planning as well as in the section on the analysis of the Company's resilience.
Potential Risks: [ESRS2:SBM3_18]
Regarding climate-related opportunities, METLEN is strategically positioned to leverage energy megatrends mainly by
developing and operating Renewable Energy Sources, by performing grid upgrade projects internationally, and by leveraging the
growing markets of hydrogen (H
2
) production and carbon dioxide capture (CCUS). Furthermore, benefits for the Company's
business strategy arise both from the different ways of leveraging natural gas, in the context of energy transition, and from the
ever-increasing integration of recycled aluminium into its product mix, aiming at greener outflows.
The following table presents the climate-related opportunities identified in each of the Company's Sectors along with the
respective time horizons discussed. [ESRS2:IRO1_AR_12_a]
Business
Activity
Time
Horizon
Identified Climate-Related Opportunities
METALS
SECTOR
(M)
ENERGY
SECTOR
(E)
Short-term
Medium-term
Long-term
Investments in energy efficiency and more
efficient production processes.
Ο
(M)
(M)
(M)
Increased use of recycled or low-carbon
materials.
Ο
Ο
(M) - (E)
(M) - (E)
Investments in secondary cast aluminium
production.
Ο
(M)
(M)
Investments in renewable energies or carbon-
free materials.
Ο
(M)
(M)
(M)
Investments in renewable energies, storage
systems and grid solutions.
Ο
(Ε)
(Ε)
(Ε)
Electrification of final demand.
Ο
(Ε)
(Ε)
(Ε)
Demand for RES guarantees of origin.
Ο
(Ε)
39
As described in detail in the section "Company Procedures for Identifying and Assessing Climate-related Risks" considering: a) The criterion of the significance
of the implications that may arise from climate risks identified, and b) The criterion of the level of certainty that the risks identified will occur.
Type
no.
Description
Metals Sector
Energy Sector
[R1]
Increased carbon allowance prices.
[R2]
Increased electricity and natural gas prices.
[R3]
Transition to low-carbon technologies in the
production of primary aluminium.
Transition
Risks
[R4]
Increased electricity and natural gas sales prices.
[R5]
Rising temperatures.
Physical Risks
[R6]
Increased frequency of extreme weather events.
5. Annual Board of Directors Management Report
122
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Increased demand for low-carbon products and
infrastructure.
Ο
Ο
(Ε)
(M) - (E)
(M) - (E)
Participation in projects aimed at protecting
infrastructure and repairing climate-related
damage.
Ο
(Ε)
Developing new products enabling the
transition to a low/zero carbon economy.
Ο
(M)
(M)
Using more effective modes of transport.
Ο
(M)
(M)
Optimal use of the Company's diversified
business model.
Ο
(M)
(M)
Growing demand for products that help
decarbonize, adapt to climate impacts, and
repair damage.
Ο
(M)
(M)
Funding through the use of new financial
mechanisms.
Ο
Ο
(M)
(M) - (E)
(M) - (E)
Investing in new technologies: energy storage
systems using batteries and renewable energy
forecasting technologies.
Ο
(Ε)
(Ε)
Table 2.
Overall, the most significant opportunities that may, with no determined economic valuation, have an impact on the Company's
revenues and/or operating costs are:
Potential opportunities:
Impact of climate risks and opportunities on the Company's strategy and financial planning
Overall, the potential impact of the aforementioned climate risks and opportunities on the Company includes the following:
[E1:SBM-3_19]
Opportunities
Potential Impact
[Ο1] - Investments in renewable
energies, storage systems and grid
solutions.
[O2] - Investments in secondary cast
aluminium production.
Possible increase in revenue from:
1. Increased demand for aluminium as the main energy transition ingredient. To achieve
carbon neutrality by 2050, it is necessary to install energy-efficient infrastructure in
buildings, an aluminium will have the lion’s share.
no.
Description
Metals Sector
Energy Sector
[O1]
Investments in renewable energies, storage systems and grid
solutions.
[O2]
Investments in secondary cast aluminium production.
[O3]
Investments in energy efficiency and more efficient production
processes.
[O4]
Increased use of recycled or low-carbon materials.
[O5]
Developing new products enabling the transition to a low/zero
carbon economy.
[O6]
Electrification of final demand
[O7]
Investing in new technologies: energy storage systems using
batteries, forecasting technologies for renewable energy
systems, etc.
[O8]
Using more effective modes of transport
5. Annual Board of Directors Management Report
123
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
[O4] - Increased use of recycled or low-
carbon materials.
[O5] - Developing new products enabling
the transition to a low/zero carbon
economy.
[O6] - Electrification of final demand
[O7] - Investing in new technologies:
energy storage systems using batteries,
forecasting technologies for renewable
energy systems, etc.
2. The sale of low-carbon products (e.g. recycled aluminium) or products necessary for the
green transition. METLEN is active in the dynamic development of projects that are
necessary for energy transition at an international scale and is expected to play a key role
in the next crucial decade, escalating its positive impact to become a global market leader
in this field.
3. Broadening its market share in the supply of electricity, increasing the services and
products provided with a customer-centric approach, in light of the increase in electricity
demand given that it will be the main source of energy in the new era as a result of the
rapid electrification of the market (electromobility, heat pumps, etc.).
4. The strengthening of the Company's strong market position for EPC projects for the
construction of natural gas-fired power plants.
5. Exploring the gradual entry into the new growing markets of hydrogen (H
2
) production and
carbon dioxide capture (CCUS), and maximizing the availability of our thermal plants and
increasingly integrating the possibilities offered by the progress of technological tools and
especially through the development of in-house customized IT tools for energy production
and management.
[O3] - Investments in energy efficiency
and more efficient production processes.
[O8] - Using more effective modes of
transport
Possible operating cost reduction from:
1. Leveraging lower carbon-intensive production processes and increased production at
maximum capacity.
2. Reduction of transport costs that will also reduce procurement costs.
Risks
Potential Impact
[R4] Increased electricity and natural gas
sales prices
*Shift consumer preferences to low-
carbon products
[R5] - Rising temperatures
[R6] - Increased frequency of extreme
weather events
Possible drop in revenue from:
1. The reduced demand for electricity and natural gas due to increased sales prices that
may result from the implementation of climate change mitigation policies.
2. The reduced demand for primary aluminium due to changes in the preferences of end
consumers and, by extension, of the Company's customers.
3. The reduced efficiency of thermal power plants due to rising temperatures.
[R1] Increased carbon allowance prices
[R2] - Increased electricity and natural
gas prices
* Increased cost of raw materials
[R5] - Rising temperatures
Possible cost increase due to:
1. Increased carbon emission allowance prices that may cause a deterioration of the
Company's position in the global cost curve of aluminium plants vis-à-vis its competitors.
2. Increased transport costs, due to carbon mitigation measures, may affect the cost of raw
materials, resulting in increased production costs.
3. Reduced efficiency of the Company's natural gas-fired power plants due to rising
temperatures.
4. Increased electricity and natural gas prices that may result from the choice of specific
climate mitigation solutions that increase the energy costs of production processes.
[R3] - Transition to low-carbon
technologies in the production of
primary aluminium
[R5] - Rising temperatures
[R6] - Increased frequency of extreme
weather events
Possible decrease in production effectiveness:
1. In specific periods (possibly in the medium term) with the introduction of new
technologies and the gradual optimization of operating parameters in its production
processes.
2. From reduced efficiency of thermal power plants due to rising temperatures.
[R3] - Transition to low-carbon
technologies in the production of
primary aluminium
Possible increased investments from:
The transition to low-carbon technologies in the production of primary aluminium, such as at
the stage of the mining process that requires investments in mechanical equipment, and
5. Annual Board of Directors Management Report
124
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
increased research and development costs. This impact is likely to increase as emissions
reduction requirements are maximized.
*Additional risks of either lower significance or lower likelihood of occurrence than key risks.
Climate resilience of the strategy and business model [E1.SBM-3: 19 a, b & c]
The Company's climate resilience analysis, which was completed in early 2024, includes all key risks and opportunities and focuses
on the relevant activities and specifically on the Metals and Energy Sectors. It focuses on the Company's industrial plants and
project construction sites in Greece, since, in these cases, the assessment of climate-related risks and opportunities was
considered as material. [ESRS2:SBM3_AR_6] [ESRS2: IRO-1_AR_13_d] [ESRS2.IRO1_20_b] [ESRS2.IRO1_20_c] [ΕSRS2:SBM-3_19_a]
The timeframes considered by the Company in the resilience analysis are the short and medium term until 2030, enabling the
use of available data from the strategic plans of the Sectors. Also, the timeframe to 2030 is considered critical as it coincides with
the goals and milestones set internationally to reduce GHG emissions. Many climate policies and investment plans for the energy
transition are focused on this period, and METLEN wants to ensure that it remains resilient during this important period of
change. Furthermore, the climate impacts expected to occur by 2030 can be predicted more accurately, allowing the Company
to take more specific measures to manage immediate risks. The timeframe offers a balanced combination of short-term
challenges and medium-term opportunities, enabling immediate adaptation and strategic planning. [ESRS2: IRO-1_AR_13_d]
[ΕSRS2.IRO1_20_b] [ΕSRS2:IRO1_20_c] [ΕSRS2:SBM-3_19_b]
The analysis does not include: the activity of the Company's main subsidiaries (METKA-ATE), and the activities of the Energy
Sector abroad.
Critical assumptions: [ESRS2:SBM3_AR_7_a] [ESRS2:SBM3_AR_8_a] [ESRS2:SBM3_AR_13_c] [ΕSRS2.IRO1_20_b] [ΕSRS2.IRO1_20_c]
1. Macroeconomic Trends
The transition to a low-carbon economy will significantly affect the structure of markets, causing changes in demand for products
and services related to green energy and technology. There will be a gradual shift of capital from high emission sectors, such as
fossil fuels, to clean energy sectors as markets adapt to new needs and priorities for sustainable development.
At the same time, investments in low-emission technologies are expected to boost the productivity of businesses and industries.
However, in the short term, this transition can have a negative impact on sectors that are highly dependent on fossil fuels, such
as the traditional energy industry and coal-intensive industries. Despite short-term challenges, the transition is expected to lead
to stronger and more sustainable economic growth.
The gradual implementation of stricter regulations and environmental taxes, such as carbon taxes, will shape product prices,
production costs, and demand, as businesses will have to adapt to new requirements. This will put pressure on high-emission
industries, but will strengthen the potential of sustainable solutions and technologies.
2. Energy Consumption and Energy Mix
The global energy mix is expected to change in the coming decades as renewables take a significantly larger share. This increase
will be the result of efforts by governments and businesses to reduce CO
2
emissions and meet climate commitments. At the same
time, high-emission energy sources will gradually reduce their share in the energy mix as they become financially and
environmentally unsustainable.
Changes in consumer preferences will play a key role in this transition. As environmental awareness increases, consumers are
increasingly turning to energy-efficient products. This will lead to a reduction in energy consumption per unit of production as
businesses invest more in green energy and low-emission technologies to meet new market demands and reduce their
environmental footprint.
However, the transition to renewable energies comes with challenges, particularly in the initial phase of investment in
infrastructure. The construction and installation of the required infrastructure, such as solar parks and wind installations, can
lead to increases energy prices in the short term. Nevertheless, in the long run, increased production from renewable sources
will lead to lower energy costs, making green energy cheaper and more affordable for both businesses and consumers.
The use of electric vehicles is also expected to increase significantly, with the associated charging infrastructure expanding
rapidly. This will help to reduce the consumption of fossil fuels, as more and more consumers will choose alternatives for their
5. Annual Board of Directors Management Report
125
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
transport, reducing their dependence on oil and gas. Furthermore, the growing demand for clean energy from electric vehicles
will lead to further changes in the energy mix, accelerating the transition towards a sustainable, low-emission economy.
3. Technology Development
The development of innovative technologies, such as energy storage systems, carbon capture and storage (CCS) technologies, as
well as improved electricity grids, is expected to play a key role in reducing GHG emissions. These technologies will enhance the
capacity of both countries and businesses to respond to climate challenges, while businesses investing early in these areas will
gain a significant competitive edge.
Progress in digital technologies and energy management solutions is also a key factor in reducing emissions. By optimizing the
use of resources, businesses and consumers will be able to more effectively monitor energy consumption and reduce waste.
Implementation of smart grids, industrial automation and energy management systems, for both industries and household uses,
will enable efficiency to be maximised and emissions to be minimised, contributing to the achievement of climate targets.
However, the speed at which these low-emission technologies will be adopted will largely determine the speed of the energy
transition. This pace will depend on a number of factors, including government incentives, investment in research and
development, and consumer acceptance of new technologies. Government incentives, such as subsidies and tax exemptions, will
enhance the uptake of green technologies, while businesses investing in research will be able to leverage technological
opportunities more quickly, thereby accelerating the energy transition and contributing to the achievement of climate targets.
METLEN implements resilience analysis through different climate scenarios, taking into account the potential impact on the value
chain, both on the supply chain (upstream) and on end consumers (downstream). [ΕSRS2.IRO1_20_b] [ΕSRS2.IRO1_20_c] [ΕSRS2.IRO1_21]
[ESRS2: SBM3_AR_13_a] [ESRS2: IRO-1_AR_13_a]
The socio-economic parameters of climate "scenarios”
40
are drawn from the Network for Greening the Financial System (NGFS),
while the future climate parameters in any area of interest for each of these scenarios are drawn from the European climate
change service COPERNICUS. In particular, the Company has elaborated three different scenarios, each describing a different
climate future in terms of greenhouse gas (GHG) emission volumes and concentrations in the air, and ultimately the severity
and intensity of climate change as a function of the relevant mitigation policies. These scenarios, designed with the contribution
of a consortium of academic research institutions, aim to cover a wide range of natural and transition risks under different future
conditions, considering the latest economic, climate data and policy commitments since March 2023. They broadly follow the
main RCP (Representative Concentration Pathway) scenarios and their key assumptions, as developed in the context of the 5
th
Assessment Report of the Intergovernmental Panel on Climate Change (IPCC) and provide an important scientific basis for the
development of NGFS scenarios, allowing the link between climate science and financial analysis.
Using the full spectrum of RCP scenarios allows METLEN to better analyse its adaptability to different climate events and
incorporate the analysis results into its strategic decisions. Preparing for the worst-case scenario (RCP8.5) allows the Company
to adjust its strategy for the most acute risks. At the same time, understanding the best-case scenario (RCP2.6) allows it to seize
opportunities from the transition to a low-carbon economy: [ΕSRS2.IRO1_20_b] [ΕSRS2.IRO1_20_c] [ESRS2:SBM3_AR_13_b] [ESRS2: IRO-
1_AR_13_b]
i. Weak/Lax Policies Scenario: This scenario assumes a world where actions to mitigate climate change are delayed.
Subsequently, greenhouse gas emissions continue to rise in the 21st century and the average global temperature
rises above 3.5°C at the end of the century. Climate risks and opportunities are mainly related to natural impacts as both
chronic and acute climate change effects are considerable. To perform the quantitative analysis of these risks and
opportunities, climate and economic data included in scenarios developed under Representative Concentration
Pathway 8.5 (RCP8.5) were used. [ESRS2: IRO-1_AR_11_d] [ESRS2: IRO-1_AR_12_c]
Key potential risks, based on their economic valuation, for METLEN's activity up to 2030:
40
These scenarios are not predictions but means of exploring possible future developments that help understand the courses of action that lead to each climate
future they represent and to assess potential risks and opportunities. They incorporate the latest trends in renewable energy technologies, such as solar and
wind, and examine the impact of the war in Ukraine on the energy market. NGFS also improved the physical risk modelling, providing more detailed scenarios of
how acute natural hazards, such as heatwaves and droughts, could materialize over time and at country level.
5. Annual Board of Directors Management Report
126
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
ii. Current/Existing Policies Scenario: It predicts a world where greenhouse gas emissions stabilize and moderately decline by
the end of the 21st century, with a partial transition to renewable energies. Although this scenario does not predict the
extreme impacts of the RCP8.5 scenario, climate change is significant and continue to affect the planet. Climate mitigation
policies are stronger than in the previous scenario and lead to increases in the average global temperature between 2°C and
3°C at the end of the century. This scenario also shows that unless more ambitious climate change policies are implemented,
the negative impacts will be felt, running the risk of not avoiding severe climate disasters. The climate data used in the
quantitative analysis of risks and opportunities are those derived from scenarios developed under Representative
Concentration Pathway 4.5 (RCP4.5). [ESRS2: IRO-1_AR_11_d] [ESRS2:IRO-1_AR_12_c]
Key potential risks, based on their economic valuation, for METLEN's activity up to 2030:
iii. Strong Policies Scenario: This scenario incorporates strong climate mitigation policies and indicates a pathway where carbon
emissions will evolve in such a way to enable the global energy sector to achieve net-zero CO
2
emissions by 2050. It is the
most ambitious of the RCP scenarios. The average global temperature in this scenario is projected to rise by about 1.5°C to
2°C by 2100. This limitation to warming is in line with the goals of the Paris Agreement, which aims to limit global warming
and prevent the most severe consequences of climate change. The scenario requires significant and immediate actions to
reduce GHG emissions and gradually shift to clean energy. Although major political and economic steps are needed to achieve
Description
Physical
Risks
[R5], [R6] - Rising average temperatures and heat waves may affect the efficiency of the company's thermal
plants. This is a high risk for the Energy Sector since it can lead to reduced production and revenues.
[R1] - Emission allowance prices are a very high potential risk in the Energy activities and a high potential risk in
the Metallurgy activities, in both cases related with increased allowance purchase costs.
Transition
Risks
[R2] - Increased electricity and natural gas prices that may result from the choice of specific climate mitigation
solutions are a very high risk for Metallurgy that increase the energy cost of production processes.
Description
Physical
Risks
[R5], [R6] - Rising average temperatures and heat waves may affect the efficiency of the company's thermal
plants. This risk continues to exist, but to a lesser extent (bordering on medium risk), since, under this
scenario, the cost is lower than in the weak policies scenario because of a climate change limitation and
therefore lower impact on the efficiency of thermal plants.
[R1] - Under this scenario, increased prices of CO
2
emissions allowances are a very high potential risk for
both Metallurgy and Energy, as they may lead to a further increase in the cost of purchasing allowances.
[R2] - Increased electricity and natural gas prices are a very high potential risk of increased operating costs
for Metallurgy in this scenario as well, based on the projected electricity and natural gas consumption.
[R3] - Transition to low-carbon technologies in the production of primary aluminium. The prospect of
reducing emissions creates the need for increased medium- and long-term investments in this direction in
Metallurgy.
Transition
Risks
[R4] - Increased electricity and natural gas sales prices due to the implementation of climate change
mitigation policies to tackle climate change, are a potential high risk for Energy. It relates to the likelihood
of reduced demand and, consequently, possible revenue losses.
5. Annual Board of Directors Management Report
127
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
this scenario, the consequences of climate change in this context are much more manageable than in scenarios that do not
implement strict policies. The climate data used in the quantitative analysis of risks and opportunities are those derived from
scenarios developed under Representative Concentration Pathway 2.6 (RCP2.6). [E1:E1-1_16_g] [ESRS2:IRO-1_AR_12_c]
Key potential risks, based on their economic valuation, for METLEN's activity up to 2030:
The elements of the resilience analysis are combined with the business strategy, illustrating how METLEN manages the key
climate risks as described in a relevant chapter below. In conclusion, although the analysis highlighted potential risks with varying
degrees of intensity per scenario, METLEN's diversified business model is proving resilient to climate challenges, for the following
reasons:
a) It has strong synergies between its Sectors and vertically integrated production with strict cost control, ensuring strong
economic performance despite the volatility in energy prices.
b) It has a strong financial profile with high profitability, low leverage, prudent financial policy and proven resilience.
c) It has the structures, strategies and policies in place that allow it to adapt and continue to operate effectively despite the
increasing challenges caused by climate change.
d) It has a broad international reach with leading domestic positions and a diversified customer base.
e) It is at the forefront of the energy transition, integrates Sustainable Development into its core activities and operations,
promotes innovation, leverages technological progress and actively manages risks.
f) It has developed an agile fund management model that allows it to redirect resources to initiatives that are aligned with new
trends stemming from climate change and the energy transition. Its agility in allocating funds to sustainable technologies,
such as renewable energy sources (RES), energy efficiency and circular economy, allows it to leverage incentives and
opportunities such as, but not limited to, subsidies and other measures that create an attractive investment environment.
This makes it more flexible in responding and adapting to changing regulatory requirements by managing risks and financial
burdens more effectively. [ESRS2:SBM3_AR_8_b] [ESRS2:E1 -3_AR_21]
g) It has already integrated broader environmental, social and ethical criteria into its due diligence process for decision making
on M&A transactions. However, the integration of climate parameters (risks and opportunities) requires a special approach,
as risks include physical and transitional parameters, such as the impacts of climate change on operations and supply chains,
as well as regulatory changes affecting companies in the Company's Sectors. METLEN understands the importance of these
factors, and will explore, within two years at the latest, the possibility and manner of incorporating climate-related criteria
into M&A strategy and decision-making. [ΕSRS2:SBM-3_19_c]
h) Finally, in assessing the compatibility of its assets and activities with the transition to a climate-neutral economy, METLEN has
identified the critical points that need significant adaptation efforts in combination with the development of the necessary
technologies. Initially, gas-fired thermal power plants are a key source of CO₂ emissions/ The application of appropriate
technologies, such as battery storage or other storage technologies, the possible combination of natural gas and hydrogen
combustion and the installation of carbon capture and storage (CCS) systems, are options that can improve their compatibility
with the European taxonomy and reduce their carbon content imprint. Also, the production of primary cast aluminium,
despite the upgrades that have already been implemented, is still based on more traditional technologies, being another
example of activity with significant locked direct CO₂ emissions. In this context, METLEN recognizes, for example, the need to
adopt inert anode technology, which allows the production of aluminium without the emission of carbon dioxide from anode
reactions, thus drastically reducing total emissions, a technology that will be available after 2040. All of the above are the
Description
[R1] - Increased emission allowances prices continue to be a potential very high risk for both of the
Company's main Sectors. In this scenario, the cost increase based on the projected CO
2
emissions of each
Sector is shown to be well above the existing policies scenario.
[R2] - Increased electricity and natural gas prices continue to be a very high potential risk of increased
operating costs in Metallurgy.
[R3] - The need for increased investment in the transition to low-carbon technologies in the production of
primary aluminium is likely to increase as the requirements in this scenario are maximized.
Transition
Risks
[R4] - In this scenario, increased electricity and natural gas sales prices due to climate change mitigation
policies are higher, therefore further reduced demand is expected, which may entail a very high risk for the
Energy BU, mainly with regard to natural gas, with greater potential revenue losses.
5. Annual Board of Directors Management Report
128
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
subject of the ongoing exercise of the company's climate goals review. [IRO-1_AR_12_d]
E1-2
Policies on climate change mitigation and adaptation
Protecting the natural environment, moving to a low-carbon economy, addressing the challenges of Climate Change and
contributing to the achievement of the relevant Sustainable Development Goals (SDG 3 & SDG 7) are top priorities in METLEN's
business operations and a key part of its strategy. To this end, the Company has developed a Central Environmental Policy,
placing particular emphasis, proportionally to its share of responsibility, on climate change mitigation, the adaptation of its
activities to the consequences of climate change, and the responsible use of energy to strengthen and promote its climate
commitments and manage the relevant significant existing and potential risks and opportunities.
CENTRAL ENVIRONMENTAL POLICY
Year of update
2024
Key Contents
[MDR-P_65_a]
The key elements of the Climate Change Policy are:
1) Defining and reviewing medium- and long-term carbon emission reduction targets, with the aim of reducing
total CO
2
emissions (scope 1 & 2) by 30% by 2030 and achieving net zero emissions by 2050. [E1:E1-2_25_a]
2) Identifying the main categories, measuring and setting targets for the reduction of indirect CO
2
emissions
(scope 3).
3) Implementing and revising the Company's key carbon footprint reduction initiatives per Sector.
4) The responsible use of energy by enhancing energy efficiency and energy savings. [E1:E1-2_25_c]
5) Addressing climate change risks and challenges as well as adapting the Company's activities to the relevant
impacts by developing appropriate action plans.
6) Disclosing detailed information on climate change management, in accordance with international
standards.
Targeting
[MDR-P_65_b]
Implementation of METLEN's central Environmental Policy applies to all METLEN Sectors and Subsidiaries, while
its main principles also apply to its suppliers and partners as reflected in the Company’s "Suppliers and Business
Partners Code of Conduct".
Governance
[MDR-P_65_c]
1) Approved by the Company's Sustainability Committee.
2) Designed and revised every two years, and sooner, if necessary, by the Company's Corporate Governance
and Sustainable Development General Division in cooperation with the General Divisions of the Company's
Sectors, which are also responsible for its implementation.
Policy Recipients
Direct employees; Indirect employees; Suppliers and partners including subcontractors of all METLEN Sectors,
Subsidiaries and Central Functions.
Standards or
internationally
recognized third-party
initiatives
[MDR-P_65_d]
1) Paris Agreement: METLEN is committed to adhering to the principles and objectives of the Paris Agreement
on climate change, with the aim of limiting global temperature increases.
2) The Principles of the UN Global Compact, which include environmental practices and environmental
protection.
3) The Sustainable Development Goals (2030 Agenda). It is in line with METLEN's contribution to achieving
the targets of the Sustainable Development Goals relevant to its activity (6, 7, 12, 13, 14, 15 & 17).
4) Carbon Reporting Initiative (CDP)
5) Standard ISO 14001.
Availability
[MDR-P_65_d]
1) Corporate Website
41
,
2) Regular updates to the internal audience upon first publication and following any revisions.
3) Internal Information Portal (Intranet).
E1:E1-2_24]
E1-3
Actions and resources related to climate policies [E1:E1-1_16_c]
41
https://www.metlengroup.com/media/l0rkoqbr/environmental-policy.pdf
5. Annual Board of Directors Management Report
129
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In the context of its environmental policy, METLEN has developed and implements key actions aimed at reducing CO
2
emissions
in the main areas of business activity. These actions affect various Company Stakeholder groups, such as financial institutions,
local communities benefiting from emission reductions as well as the investor community by providing reports on CO
2
reduction
actions and results. [E1:Ε1-3_28] [ESRS2:MDR-A_68_b]
Specifically: [ESRS2:MDR-A_68_a] [ESRS: MDR-A_68_c] [E1:E1-3_AR_19_a] [E1:E1-3_AR_19_b] [E1:E1-3_AR_19_c]
Action 1: Implementation of cutting-edge technologies and the use of digital industrial methods in the aluminium production
stages
Objective: The implementation of digital solutions in the Electrolysis
department and parts of the Alumina plant, the implementation of a
more energy-efficient construction plan in 80 more electrolysis basins
within 2024 and the implementation of all investments and actions to
save 25,000 MWh of electricity and 8,500 MWh of thermal energy
annually compared to 2023. In 2024, a total of 130 Electrolysis basins
(17% of the total) have already been constructed with a low-consumption
plan, while a new, more energy-efficient construction plan was tested in
59 additional basins, aiming to further reduce electricity consumption per
ton of aluminium produced and save more than 8,500 MWh compared to
2023. The conversion of electrolysis basins with a low energy
consumption plan will continue in the coming years with the aim of more
than 34% of all basins operating with reduced energy consumption and saving 40,000 MWh of electricity compared to the
reference year 2019, or 25,000 MWh compared to 2023. The total cost of the investment for the conversion of the basins is
estimated at €1.8 million.
42
, of which 40% has already been spent. [E1:E1-3_29_c_i]
At the same time, the digitization of the Electrolysis process at the Aluminium plant of Greece, in collaboration with General
Electric (GE), is in progress, while within the next two years 2025 - 2026, the digitization of the Alumina plant (Digital Alumina
Refinery) is planned, a project that is expected to bring savings of ~ 8,500 MWh of thermal energy annually. The amount spent
on the digitization of the Alumina plant, in 2024, it is estimated at €2 million
43
and concerns infrastructure projects (data
gathering, I4 ready instrumentation). Expenditure on the digitization of Alumina will continue in the coming years. [E1:E1-3_29_c_i]
The implementation of actions to reduce energy consumption in the bauxite mines and in EPALME is also in progress. For
instance:
a) the renewal of lighting with the installation of low-power luminaires and a digital central fan control system in the bauxite
underground facilities (ventilation on demand)
b) the reduction of natural gas consumption in the metal holding furnace by reducing thermal losses with improved
refractory lining (expenditure €100 thousand
44
) [AR21] [ESRS2:MDR-A_69_a] [ESRS2:MDR-A_69_b] [ESRS2:MDR-A_69_c] [E1:Ε1-3_29_b]
[E1:Ε1-3_29_c]
Action 2: Electrification of primary aluminium production from RES
Objective: The continuous increase of supply from alternative energy
sources combined with the evolution of the Company's Renewable
Energy Sources investment plan by the Energy Sector in Greece.
Until 2024, the Company took advantage of the continued strengthening
of RES in the country's energy mix, as well as that of the provider METLEN
(Protergia), reducing indirect emissions in the production of primary cast
aluminium. The progress made, although quantified, takes into account
different emission conversion factors, as reflected in the relevant graphs
showing the evolution of targets. From 2025, the Company is expected to
benefit from further strengthening the mix of the provider METLEN (Protergia), which will provide an even greater share of energy
from renewable sources, ensuring the continuation of this trend.
Action 3: Increased secondary cast aluminium production
42
See. Notes to the Annual Financial Statements, Section 3.5 of this Integrated Report
43
See. Notes to the Annual Financial Statements, Section 3.5 of this Integrated Report
44
See. Notes to the Annual Financial Statements, Section 3.5 of this Integrated Report
Time Horizon: 2030
Decarbonisation Mechanism: Energy Efficiency
Improvement [E1:E1-3_29_a] [E1:E1-4_34_f]
Scope: Country: Greece - Activities: primary
aluminium plant (AoG), secondary cast aluminium
plant (EPALME), bauxite mining plant (DELPHI
DISTOMON) - Position in the Value Chain: Upstream
& Activities concerned.
Time Horizon: 2030
Decarbonisation Mechanism: Renewable Energy
Sources [E1:E1-3_29_a] [E1:E1-4_34_f]
Scope: Country: Greece - Activities: primary
aluminium plant (AoG) - Position in the Value
Chain: Own operations
5. Annual Board of Directors Management Report
130
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Objective: Reaching 100,000 t of secondary cast aluminium production
by 2030.
Increasing the production of recycled aluminium is one of the key
initiatives to achieve the climate target of reducing CO₂ emissions per
tonne of aluminium produced. Since primary aluminium production is an
energy-intensive process with a high carbon footprint, gradually
increasing the amount of secondary aluminium drastically reduces
emissions, as it requires up to 95% less energy.
In 2024, the production of second cast aluminium exceeds 55,000 t, i.e.
20,000 t more than reference year 2019. Moreover, in 2024, an investment of €2.5 million
45
was made for the purchase of a new
furnace that will be operational in 2025. In the period until 2030, a scenario is considered for a significant increase in production
at EPALME's facilities or the acquisition of another recycling plant, so that the total production of secondary cast aluminium
reaches 100,000 t on an annual basis. [AR21] [ESRS2:MDR-A_69_a] [ESRS2:MDR-A_69_b] [ESRS2:MDR-A_69_c] [E1:Ε1-3_29_b] [E1:Ε1-3_29_c]
Action 4: Increases sales of hydrated alumina
Objective: the operation optimization of the alumina calcination furnaces
due to a change in the product mix of hydrated - anhydrous alumina and
the avoidance of calcination of at least 200,000 t of alumina per year. In
2024 sales of hydrated alumina amounted to 213,000 tons, which is
equivalent to an avoidance of 10,000 t of CO
2
emissions (scope 1)
compared to reference year 2019. This reduction is due both to the
avoidance of calcination of a considerable quantity of alumina and to the
maximization of the operation of the two most energy-efficient calcination furnaces. This reduction is projected to continue in
2025 and the following years. To ensure the availability of larger quantities of hydrated alumina in the coming years, an €700
thousand
46
investment will be made to create a new warehouse in the port area. [AR21] [ESRS2:MDR-A_69_a] [ESRS2:MDR-A_69_b]
[ESRS2:MDR-A_69_c] [E1:Ε1-3_29_b] [E1:Ε1-3_29_c]
Action 5: New technologies implementation study (pilot use of hydrogen, etc.)
In 2024, preparatory works began for the installation of a pilot hydrogen
burner at the Foundry’s liquid metal preheating station, in the framework
of the HyInheat research program, which is expected to be completed in
the coming years (2024 preparation, 2025-2026 technology
demonstration). In addition, regarding actions for the electrification of
production processes to reduce CO
2
emissions, two new co-funded
research programs aimed at investigating electrification technologies of
basic alumina and aluminium production processes have begun with a
timeframe of 4 years. The 1
st
program is called Elithe and is about
calcination and production of metallurgical alumina using a new type of
microwave calcination furnace. The 2
nd
program is called Metawave and is about the calcification of anode blocks using a hybrid
microwave and inductive currents system.
45
See. Notes to the Annual Financial Statements, Section 3.5 of this Integrated Report
46
See. Notes to the Annual Financial Statements, Section 3.5 of this Integrated Report
Time Horizon: 2030
Decarbonisation Mechanism: Circular Economy
[E1:Ε1-3_29_a] [E1:E1-4_34_f]
Scope: Country: Greece - Activities: secondary
cast aluminium (EPALME) & primary aluminium
(AoG) plants - Position in the Value Chain: Own
operations
Time Horizon: 2030
Decarbonisation Mechanism: Product mix
change [E1:Ε1-3_29_a] [E1:E1-4_34_f]
Scope: Country: Greece - Activity: primary
aluminium plant (AoG) - Position in the Value
Chain: Own operations
Time Horizon: 2030
Decarbonisation Mechanism: Product mix
change [E1:Ε1-3_29_a] [E1:E1-4_34_f]
Scope: Country: Greece – Activity: primary
aluminium plant (AoG) - Position in the Value
Chain: Own operations
5. Annual Board of Directors Management Report
131
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Action 6: Continuous development of RES portfolio
Objective: Further development in RES.
The company's operating portfolio grew dynamically, reaching 1.4 GW of
installed capacity at the end of the year, surpassing the 1 GW milestone
for the first time. Overall, METLEN's global portfolio exceeded 11.1 GW, a
total increase of ~0.6GW of projects year-to-date. This portfolio includes
4.9GW of operational and mature projects, as well as 6.2GW early-stage
projects.
Energy production from renewable energy plants at the end of 2024
amounted to 1.6 TWhs, an increase of 40% compared to 2023. Of these,
0.7 TWhs were produced from RES within Greece and the remaining 0.9
TWhs from RES abroad. This impressive performance reflects the continuous dynamic growth and expansion of METLEN's
presence in the field of "green energy", with projects in operation in Greece, UK, Italy, Ireland, Australia, Chile and South Korea.
Regarding METLEN's portfolio of own projects developed and constructed in Greece, during 2024 the construction of 0.4 GW of
PV projects, 48MW of energy storage projects (BESS) and 13 MW of wind projects began.
In the context of the Global Energy Transition towards renewable energy sources, and the Sustainable Development Strategy
that it has consistently adopted in recent years, METLEN took an important step in May 2024 with the signing of two ten-year
Bilateral Power Purchase Agreements (PPAs) with Keppel DC REIT. These contracts concern the supply of 100% "green" energy
to two strategic facilities of Keppel DC REIT in Dublin. The energy will be generated by two photovoltaic parks in Ireland, managed
by METLEN, a move that strengthens the Company's footprint in the renewable energy sector.[AR21] [ESRS2:MDR-A_69_a] [ESRS2:MDR-
A_69_b] [ESRS2:MDR-A_69_c] [E1:Ε1-3_29_b] [E1:Ε1-3_29_c]
Action 7: Replacement of all company vehicles with electric ones.
Objective: Reduce traffic emissions from fuel consumption.
In 2024, in relation to the above objective, the Company pursues a
strategy of purchasing or leasing hybrid and electric cars to gradually
replace conventional ICE vehicles. The replacement planning process
started 2024; the aim is for all company vehicles, excluding construction
vehicles due to specific requirements they need to meet, to be hybrid or
electric by 2030, based on market conditions and acquisition costs. At the
end of 2024, the electric and plug-in electric vehicle fleet exceeded 15%
of the Company's total fleet, an increase of 3% compared to the previous year (2023).
With the commitment of achieving net zero carbon emissions by 2050 and in the context of revising its climate targets, METLEN
is looking into the possibility of implementing the following key initiatives, subject to the further maturation of new technologies,
with the aim of drastically reducing CO
2
emissions (scope 1) in all its activities: [E1:E1-1_AR_1] [E1:E1-4_AR_30_b]
a) Use of zero or low-carbon hydrogen.
b) Using zero or low-carbon fuels.
c) Implementation of carbon capture and storage technologies.
d) Application of Inert Anode technology in aluminium production.
e) Further increase in secondary cast aluminium production.
f) Electrification of mining to eliminate emissions of related equipment.
g) Offsetting residual emissions.
As part of the overall management of its total carbon footprint, METLEN also implements the following actions: [E1:Ε1-3_28]
1) Closely follows the relevant developments in legislation and takes preventive measures to minimize any potential negative
impacts.
2) Participates in the Emissions Trading Scheme (EU ETS), with its Metals Sector since 2005, and Energy Sector since 2011.
The new permits have been issued since 2020 and all the procedures for calculating and verifying gaseous emissions are
being followed in compliance with the EU ETS Phase IV (2021-2030) regulations. ASI
Time Horizon: 2030
Decarbonisation Mechanism: Renewable
Energy Sources [E1:E1-3_29_a] [E1:E1-4_34_f]
Scope: Country: Mainly Greece and countries
abroad where the company owns photovoltaic
parks - Activity: Renewable Energy segment -
Position in the Value Chain: Own operations
Time Horizon: 2030
Decarbonisation Mechanism: Electromobility.
[E1:Ε1-3_29_a] [E1:E1-4_34_f]
Scope: Country: Greece - Activity: Sectors and
Central Functions of the Company - Position in
the Value Chain: Own operations
5. Annual Board of Directors Management Report
132
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
3) Has aligned its activities with Best Available Techniques (BATs) in its production processes and is using more
environmentally friendly fossil fuels such as natural gas —recognized as a transition fuel towards decarbonisation— in
nearly all its industrial plants to improve energy efficiency and reduce gaseous emissions.
4) Expands its know-how in recycling aluminium scrap from end-of-life products, greatly enhancing its efforts to substantially
reduce the use of raw materials and save energy. More specifically, in 2024, secondary aluminium production recorded a
small change compared to 2023, moving downwards by 0.9% reaching 23.5% (2023: 24.0%) of total aluminium production.
ASI
5) Ensures the proper maintenance and the best possible operation of machinery both at its industrial plants and at the
construction sites of energy projects, renewable energy projects and other construction projects within the framework of
its activities, while investing in their modernization, where possible, using new technology equipment.
6) Holds all the GHG emission permits provided by law, and appropriate emission monitoring and reporting infrastructure
has been deployed and is in operation.
7) In electricity generation, due to the nature of the activity, the Company focuses on maintaining the operation of natural
gas-fired thermal power plants at the highest efficiency levels in Greece, by making the best use of natural gas as a primary
fuel.
8) Finally, METLEN implements ISO 50001 and ISO 14001 Energy Management Systems certified by accredited bodies, in
order to monitor and reduce its energy footprint both on its premises and on project construction sites.
METRICS & TARGETS
E1-4
Targets on climate change mitigation and adaptation
METLEN has set as its main target in the process of reducing its carbon footprint by 2030 (compared to base year 2019), the
reduction by 30% of total direct and indirect CO
2t-eq
emissions (scope 1 & 2) from all its activities
47
in Greece and abroad, as a first
milestone to achieving its commitment for net zero emissions in 2050. [E1:E1-4_34_a] [E1:E1-4_34_b] [E1:E1-4_34_c] [E1:E1-4_34_d] [E1:E1-
4_AR_30_c], [MDR-T_80_b] [MDR-T_80_c] [MDR-T_80_d], [MDR-T_80_e], [MDR-T_80_f], [MDR-T_80_h], [MDR-T_80_j]
The Company, in the exercise setting its climate targets in which the need for the participation of its Social Partners was not
identified, in 2020
48
, chose 2019 as the base year, as this year was representative of its historical emissions compared to their
average since 2012. [E1:E1-4_AR_25_a] [MDR-T_81_b] [Ε1:Ε1-4_32]
This option was based on a solid analysis of scope 1 & 2 emissions, ensuring that its climate targets are achievable and aligned
with the WB2
ο
C scenario. Also, the Company's climate targets, which are not aligned with ESRSs standards, are inextricably linked
to its central environmental policy, expressing its corporate commitments to reduce CO
2
emissions and its contribution to climate
change mitigation. [E1:E1-4_32] [ESRS2:MDR-T_80_a] [ESRS2:MDR-T_80_b]
Evolution of the central climate target
47
European Bauxite, UNISON, Sometra as well as companies acquired within the last three years and already absorbed by METLEN are excluded from the limits
of the Company's climate targets.
48
In setting its emission reduction targets, the Company adopted a holistic approach taking into account three key factors: a) international and national
decarbonisation policies, targets and pathways (e.g. Paris Agreement, EU Green Deal, Greek national energy plan) b) practices and corresponding targets and
targets of other similar companies at international level and c) its overall strategy, the particularities of its Business Sectors and its respective business plans for
the future.
5. Annual Board of Directors Management Report
133
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
To achieve the aforementioned main objective
49
, the Company has developed corresponding overall and specific targets per
Sector, in the same context, implementing specialized action plans
50
. These plans focus on the use of existing technology, on
innovation and on the development of innovative solutions, taking into account the specific characteristics of each Sector of
subsidiaries that fall within their scope, but also the current composition of the country's energy mix, and are updated according
to developments.
In the Metals Sector, where the primary aluminium production process is particularly energy-intensive, two individual CO
2teq
emission reduction targets (scope 1 & 2) have been set with 2019 as the base year. One absolute target for 65% reduction of
total CO
2teq
emissions, and one specific target for 75% reduction of total CO2
teq
emissions per tonne of aluminium produced,
by 2030. The main goal is to significantly reduce indirect CO
2
emissions (scope 2) through the use of clean energy by 2030, while
investing in research pilot projects for energy saving and emissions reduction in production processes, and anticipating the full
development of new technologies (e.g. transition from carbon anodes to inert anodes in the electrolysis stage) that will contribute
to direct emissions reduction (scope 1) after 2030. Meanwhile, the Sector strengthens its investments in the production of
recycled (secondary cast) aluminium, an activity fully aligned with the EU Taxonomy, contributing significantly to tackling climate
change. The production of recycled aluminium reduces the need for bauxite mining, a key natural resource, and also requires
significantly less energy compared to primary production and therefore has reduced GHG emissions per tonne of aluminium
produced, thus contributing positively to the reduction of global warming.
Metals Sector:
Evolution of the absolute CO
2
reduction target for Scope 1 & 2 emissions
49
The depiction of the individual reduction of direct and indirect emissions will be presented in detail in the next edition of the Sustainability Statement as a
result of the exercise reviewing the Company's climate targets.
50
As mentioned in section “Actions and resources related to climate policies”
4,600
4,640
4,459
4,064
3,921
4,285
5,022
3,250
0
1000
2000
3000
4000
5000
6000
2012-2018 2019 2020 2021 2022 2023 2024 2025 2030 2050
Baseline Year
Target Year – 1
St
milestone
Climate Targets Announcement
+8.2%
-30%
CO
2kt_eq
Net zero emissions
Average historical emissions
1st
Climate Target
Review
{Scope 2 Emission factor :
European Residual Mix}
{Scope 2 Emission factor :
Residual Energy Mix
DAPEEP}
{Scope 2 Emission factor :
Protergia DAPEEP}
5. Annual Board of Directors Management Report
134
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Metals Sector:
Evolution of specific CO
2
reduction target for Scope 1 & 2 emissions per ton of Al produced
3,058
2,840
2,620
2,587
2,716
2,288
1,070
0
1000
2000
3000
4000
2019 2020 2021 2022 2023 2024 2025 2030 2050
Baseline Year
Target Year – 1st Milestone
- 65%
CO
2kt_eq
Net zero emissions
- 25.2%
1
st
Climate Target
Review
{Scope 2 Emission :
European Residual Mix}
{Scope 2 Emission factor :
Residual Energy Mix
DAPEEP}
{Scope 2 Emission factor :
Protergia DAPEEP}
5. Annual Board of Directors Management Report
135
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In the Energy Sector, METLEN does not have, compared to other power generation companies, coal-fired power plants that it
can decommission, therefore, it is difficult to very aggressively reduce its direct emissions. Furthermore, setting an interim target
for the absolute reduction of total CO
2
emissions (Scope 1 & 2) in the Energy Sector was not feasible, considering the forthcoming
operation of the new 826MW high-efficiency combined cycle gas (CCGT) power plant
51
. Therefore, the Sector aims for a ~50%
reduction in carbon emissions per MWh produced by 2030. [E1:E1-4_33] [ESRS2:IRO1_AR_12_d] [E1:E1-4_AR_23]
The Company recognizes the important role of natural gas, considered as a transition fuel (COP28 UAE, in the energy transition
as it is a less polluting alternative that can displace other fossil fuels, such as coal and oil, while ensuring the continuous supply
of electricity. In addition, the war in Ukraine continues to raise major concerns about energy independence and energy security.
In many countries, the most direct path to reduce emissions has been the transition from coal to natural gas, as fuel source for
electricity generation, and this will continue to be the case in many markets. In this direction: a) METLEN uses natural gas, as a
more environmentally friendly option in both the short and medium term, to support the gradual transition from coal and oil to
renewable energy sources, which are evolving technologies that progressively become more economically viable; b) the
Company's natural gas-fired power plants can quickly adapt their production capacity, ensuring a stable energy supply to the
domestic grid when renewable sources are not available, such as wind and solar due to weather events, and this flexibility also
supports the integration of more renewable energy sources into the energy mix; c) The Company also uses natural gas in its
liquefied form which offers transportation flexibility thus enhancing domestic and European energy security.
51
Based on the initial target setting exercise, the locked C0
2
emissions calculated for this station amount to ~1.3 tkC0
2
per year. [E1:E1-1_16_d] [E1:E1-1_AR_3_a]
[ESRS2:IRO1_ΑR_9]
1
η
Ανασκόπηση
Κλιματικών Στόχων
10.7
9.7
8.1
7.7
8.6
6.9
2.7
0
2
4
6
8
10
12
2019 2020 2021 2022 2023 2024 2025 2030 2050
Baseline Year
Target Year – 1st Milestone
- 75%
CO
2t_eq / ton of Aluminium produced
Net zero emissions
- 35.5%
1
st
Climate Target
Review
{Scope 2 Emission :
European Residual Mix}
{Scope 2 Emission factor :
Protergia DAPEEP}
{Scope 2 Emission factor:
Residual Energy Mix
DAPEEP}
5. Annual Board of Directors Management Report
136
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Energy Sector:
Evolution of specific CO
2
reduction target for Scope 1 & 2 emissions per MWh produced [MDR-T_80_j]
Although METLEN's climate targets concern scope 1 and 2 emissions combined, the Company's strategy varies in terms of the
time horizon and emission reduction priorities for each of these scopes, as it responds to current technological progress and
recognizes future emission reduction needs. Focusing on the immediate reduction of scope 2 emissions by 2030, while preparing
for the reduction of scope 1 emissions by 2050, reflects a balanced approach that leverages existing technologies and prepares
for the introduction of future technologies. [E1:E1-4_AR_24] Specifically: [E1:E1-16_j]
a) Focusing on scope 2 emissions by 2030:
Within the framework of the existing target, METLEN initially focuses on almost the total reduction of Scope 2 emissions by 2030
(~100%). This approach is based on the need for immediate and effective action that can be implemented relatively quickly in
the transition process to cleaner energy sources. The scope 2 emissions reduction takes priority as it depends on the supply of
electricity from renewable sources, such as wind and solar, already broadly offered on the market. Thus, METLEN seeks to achieve
significant reductions in this scope in a short period of time, taking advantage of existing technological and energy solutions. To
calculate emissions, the Company uses the market-based approach, where emissions are calculated based on the average
emissions intensity of the power-grid from the Residual Energy Mix in each country where the electricity is consumed.
b) Focusing on scope 1 emissions by 2050:
METLEN is committed to net scope 1 CO
2
emissions by 2050, which include direct emissions from industrial activities and fuel
use. Achieving this commitment is a bigger challenge as it largely depends on the development of new technologies and
innovative production methods, which are not yet fully developed or implementable on a large scale, fully commercially available
or economically viable. The gradual reduction and elimination of scope 1 emissions will be supported by future technological
developments, such as further industrial reorganization, the adoption of decarbonization technologies, such as the use of
hydrogen or carbon capture and storage (CCS) technologies. Setting the timeframe to 2050 enables METLEN to adapt to
technological changes and develop sustainable solutions that meet its energy needs and reach its commitments.
329
324
322
317
297
291
165
0
50
100
150
200
250
300
350
400
2019 2020 2021 2022 2023 2024 2025 2030 2050
Baseline Year
Target Year – 1st Milestone
~ 50%
CO
2kg_eq / MWh produced
Net zero emissions
- 10.3%
1
st
Climate Target
Review
{Scope 2 Emission :
European Residual Mix}
{Scope 2 Emission factor :
Protergia DAPEEP}
{Scope 2 Emission factor:
Residual Energy Mix
DAPEEP}
5. Annual Board of Directors Management Report
137
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN ensures the consistency of its climate targets with the GHG inventory thresholds by observing the following: [E1:E1- 4_34_b]
1) The Company calculates its emissions in all scopes, following the Greenhouse Gas Protocol standard, which is
internationally recognized for recording GHG emissions. Its inventory covers:
a) direct emissions (scope 1) that include those coming directly from the Company's activities, raising risks such as
increased operating costs due to carbon pricing and difficulties in complying with environmental legislation;
b) indirect emissions (scope 2) that concern energy use and pose risks such as reliance on volatile energy prices and
increasing pressure to switch to clean energy sources; and
c) other indirect emissions (scope 3), which concern emissions of the Company's value chain, and introduce risks such as
the need to manage the environmental impact of suppliers and the potential challenges to transparency and corporate
publications.
2) In its initial climate target setting exercise, METLEN used the Science-Based Targets Tool to align with the climate science
data and specifically with the WB2
ο
C scenario. This means that the emission reduction targets for scope 1 and 2 are
consistent with international efforts to limit global warming as set out in the Paris Agreement. However, a number of
factors make the validation of these targets through the SBTi initiative, currently unfeasible. Specifically:
a) The new acquisitions, the expansion of activities as well as the implementation of a very significant transformation in
the last two years have changed the structure of the Company and consequently the limits for recording its emissions,
making it necessary to review its existing climate objectives. Until the review exercise and the Company's key strategic
moves to stabilize the emission limits are completed, validation of the targets through SBTi will not be possible.
b) METLEN has also set targets according to WB2°C scenario. Although this scenario is scientifically acceptable and
contributes to climate action, SBTi validates targets only for companies following the more ambitious 1.5°C scenario,
adopting stricter standards.
c) Finally, METLEN has not yet set specific targets for the reduction of scope 3 emissions, which is necessary for the
validation of its targets by SBTi, as the initiative requires comprehensive and measurable targets for all emissions sources.
It also has a different base year for scope 1 & 2 and scope 3 emissions at target setting level. This creates incompatibility
with the requirements of SBTi, which presupposes uniformity in the emissions inventory for all scopes. [E1:E1-1_16_a] [E1:E1-
4_34_e] [E1:E1-4_32] [ESRS2:MDR-T_80_g]
The Company's business development in recent years, combined with its recent transformation, adds new production units and
services to its range of activities, and as a result 2019 is no longer a representative base year of the Company's actual activities.
Moreover, new activities should be embedded within the limits of setting climate targets to assess whether and to what extent
they can affect them. At the same time, after 5 years of continuously recording indirect scope 3 emissions, the Company intends
to align the base year of scope 3 emissions with that of scope 1 & 2 emissions and to review whether it can start setting targets
in this emissions category as well. For the above reasons, METLEN has scheduled the 1
st
official review of its climate initiatives
and targets within 2025, in line with best practices.
The review exercise will address, inter alia, the following issues: [E1:E1-4_AR_25_b] [E1:E1-4_AR_25_c]
a) studying the specificities of the new business structure and their impact on climate targets;
b) assessing existing CO
2
abatement initiatives, together with the extent to which available technologies are being used to
identify positive and negative elements;
c) assessing the maturity of new technologies and their applicability;
d) incorporating new activities (Company acquisitions);
e) changing the base year of targets;
f) assessing the possibility of switching from the WB2
ο
C scenario currently pursued to the 1.5
ο
C scenario.
g) confirming existing or setting new and, if possible, interim targets in scopes 1 & 2;
h) exploring the possibility of setting scope 3 reduction targets.
E1-5
Energy Consumption and Energy Mix
Energy consumption and energy mix
Energy consumption is systematically monitored in all production plants, office buildings and worksites of the Company [GRI 3-
3-e-i]. In 2024, total fossil fuel energy consumption increased by ~50% compared to 2023. Natural gas consumption rose
considerably due to the increased total energy production from the Company's thermal plants, while individual electricity
5. Annual Board of Directors Management Report
138
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
consumption remained stable (a slight decline of 0.7%).
Moreover, the Company made significant progress in total energy production, which increased significantly in 2024. This
development reflects the Company's consistent effort to meet the requirements of the energy sector, ensuring adequacy and
stability in energy supply. More specifically, energy production from non-renewable sources rose by 57%, while production from
renewable sources rose by 42%. These results underline METLEN's commitment to balancing its energy strategy, with the aim of
gradually enhancing the contribution of renewable sources, while contributing to meeting direct demand utilizing non-renewable
sources, consistently responding to market needs and energy transition requirements.
[E1: E1-5_37_a,b,c] [E1:E1-5_AR_33] [E1:E1-5_AR_34]
52
In previous reports of the Company, specific quantities of the Company's electricity consumption from Renewable Energy Sources (RES) were reported, which
were based on the percentage of RES included in the national energy mix. It must be clarified that these references concerned the indirect connection to RES,
through the total electricity production mix of the country, and were not related to the purchase of Guarantees of Origin Certificates (GOs) or other certification
means of green energy use. Consequently, the quantities published in the years 2023 and 2022 in the RES category have now been incorporated into the category
of the Company's electricity consumption from fossil sources. On the contrary, the quantity of electricity consumption reported for 2024 and coming from
renewable sources concerns the purchase of Guarantees of Origin (GOs). [Ε1:Ε1-6_AR_45_d]
53
The calculation of the quantity of nuclear energy is based on its share in the power generation mix of METLEN (Protergia) by DAPEEP, which amounts to 1%.
54
Total energy consumption = Energy quantity consumed + Energy quantity produced - Energy quantity sold.
Total Energy Consumption Table
(MWh)
%
Ν/Ν-
1
2024
2023
2022
Energy quantity consumed (1+2+3))
+54%
22,645,851.81
14,687,289.52
14,485,844.92
1. Energy consumption from fossil fuels
22,543,866.81
14,687,289.52
14,485,844.92
% of total energy consumed
99.55%
100%
100%
Consumption of fuel from carbon & carbon products
0
0
0
Consumption of fuel from oil products
102,739.05
77,861.17
741,195.04
Consumption of fuel from natural gas
19,648,906.64
11,696,203.80
10,809,675.31
Consumption of other fossil fuel
109.90
138.89
166.67
Consumption of electricity, heat, steam and cooling
purchased from fossil sources
2,792,111.23
2,913,085.66
2,934,807.9
2. Energy consumption from RES
52
101,985.00
0
0
% of total energy consumption
0.45%
0%
0%
Consumption of electricity, heat, steam and cooling
purchased from renewable sources
101,985.00
0
0
Consumption of fuels from renewable sources
0
0
0
3.Energy consumption from nuclear sources
53
27,921.11
0
0
% of total energy consumption
0,13%
0%
0%
Energy quantity produced [E1:E1-5_39]
+55%
11,918,967.86
7,700,395.05
6,806,783.22
From Thermal Plants
7,835,842.00
4,162,392.22
3,639,752.91
From CHP (Combined Heat and Power Plant)
2,490,283.27
2,419,113.05
2,627,779.88
From Renewable Energy Sources
1,592,842.59
1,118,889.78
539,250.43
Energy quantity sold
+66%
10,329,699.59
6,220,921.64
5,403,420.99
From Thermal Plants
7,608,039.00
4,033,225.45
3,543,780.61
From CHP (Combined Heat and Power Plant)
1,128,818.00
1,068,834.19
1,320,389.95
From Renewable Energy Sources
1,592,842.59
1,118,862.01
539,250.43
Total energy consumption
54
+50%
24,235,120.08
16,166,762.93
15,889,207.16
5. Annual Board of Directors Management Report
139
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
[E1:Ε1-5_38_a,b,c,d,e]
Energy intensity based on the Company's net revenues
57
[E1:E1-5_40] [E1:E1-5_41] [E1:E1-5_42 [E1:E1-5_43]
The analysis of the energy intensity indicators (MWH/million net revenues) for 2024 (compared to 2023) demonstrates the
differences between METLEN's Energy and Metals Sectors, reflecting both the operational specificities and the challenges faced
by the two Sectors. Specifically, the Energy Sector showed a significant increase in the energy intensity indicator, because of
greater energy consumption to support growing demand, as well as changes in the Sector's energy portfolio. Respectively, the
Metals Sector reported higher energy intensity indicators, since it has greater energy requirements due to the nature of its
activities, reflecting the energy efficiency challenges in this area. METLEN remains committed to its strategy to enhance
sustainability, through targeted actions focused both on improving energy efficiency and promoting renewable energy sources
where feasible.
55
The calculation of the quantity of nuclear energy is based on its share in the power generation mix of METLEN (Protergia) by DAPEEP, which amounts to 1%.
56
Total energy consumption = Energy quantity consumed + Energy quantity produced - Energy quantity sold.
57
The nominator used in the calculation of energy intensity agrees with the amount of the total energy consumption and the denominator with the amount of
net sales as calculated and reported in the Company's financial statements - Table A. Profit and loss statement - Line: Net Sales.
Breakdown of energy consumption per Sector
(MWh)
Metals Sector
Energy Sector
Infrastructures &
Concessions
Energy quantity consumed (1+2+3))
7,597,429.33
15,036,803.63
6,101.93
1. Energy consumption from fossil fuels
7,495,444.33
15,036,803.63
6,101.93
% of total energy consumption
98.30%
100%
100%
Consumption of fuel from carbon & carbon products
0
0
0
Consumption of fuel from oil products
74,067.22
20,811.28
4,992.04
Consumption of fuel from natural gas
4,658,459.91
14,990,002.95
214.30
Consumption of other fossil fuel
109.90
0
0
Consumption of electricity, heat, steam and cooling
purchased from fossil sources
2,735,179.20
25,989.40
895.59
2. Energy consumption from RES
101,985.00
0
0
% of total energy consumption
1.34%
0%
0%
Consumption of electricity, heat, steam and cooling
purchased from renewable sources
101,985.00
0
0
Consumption of fuels from renewable sources
0
0
0
4.Energy consumption from nuclear sources
55
27,628.10
0
0
% of total energy consumption
0.36%
0%
0%
Energy quantity produced [E1:E1-5_39]
2,496,076.74
9,389,842.00
33,049.12
From Thermal Plants
0
7,835,842.00
0
From CHP (Combined Heat and Power Plant)
2,490,283.27
0
0
From Renewable Energy Sources
5,793.54
1,554,000.00
33,049.12
Energy quantity sold
1,134,611.47
9,162,039.00
33,049.12
From Thermal Plants
0
7,608,039.00
0
From CHP (Combined Heat and Power Plant)
1,128,818.00
0
0
From Renewable Energy Sources
5,793.47
1,554,000.00
33,049.12
Total energy consumption
56
8,958,894.60
15,264,606.63
6,101.93
5. Annual Board of Directors Management Report
140
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
E1-6
Gross Scope 1, 2, 3 emissions and total GHG emissions
The Company's total GHG emissions inventory
59
for 2024 is presented in the table below. Almost the total scope 1 and scope 2
CO
2eq
emissions come from the Company's activities in Greece and were calculated based on the consolidated accounting total.
There are no additional emissions related to affiliates, joint ventures or unconsolidated subsidiaries, as these do not fall within
the scope of the Company's operational controls. Note also that the Company does not calculate biogenic emissions, as it does
not use fuels with high biogenic content. [E1:Ε1-6_50] [Ε1:Ε1-6_AR_43_c] [Ε1:Ε1-6_AR_45_e] [Ε1:E1-6_AR_46_j]
[E1:E1-6_44] [AR 52]
58
The individual activities of the Company's Divisions belong to sectors A to H of Annex I to Regulation (EC) No 1893/2006 of the European Parliament and of
the Council of 20 December 2006 establishing the statistical classification of economic activities NACE Rev. 2. Official Journal of the European Union, L 393,
30.12.2006, p. 1–39.
59
Based on guidelines provided by the GHG Protocol Corporate Standard [E1: E1-6_44_AR_39]
60
The calculation was based on the consumption of electricity purchased from fossil sources as reported in the table of total energy consumption and the
emission factor of Greece's 2023 energy production mix (DAPEEP) of 252,441 gCO₂/kWh, in accordance with the guidelines of the GHG Protocol.
Energy Intensity Indicator by high climate impact sector
58
(MWh)/€ mil. net Sales)
%Ν/Ν-1
2024
2023
Energy Sector
+88.1%
3,338.9
1,775.1
Metals Sector
+18.5%
10,453.3
8,819.3
Infrastructure & Concessions
-9.4%
24.0
26.5
Total GHG Emissions Table
60
(teq CO
2
)
%N/N-1
2024
2023
2022
Gross direct scope 1 GHG emissions
3,962,159.2
2,729,731.8
2,640,850.3
Gross indirect scope 2 GHG emissions (market-based)
1,060,417.5
1,555,613.5
1,281,939.2
Gross indirect scope 2 GHG emissions (location-based)
730,588.5
-
-
Gross indirect scope 3 GHG emissions
6,542,585.6
7,942,217.1
8,722,309.3
Total GHG emissions (Scope 1+2)
(market-based)
17%
5,022,576.7
4,285,345.3
3,922,789.5
Total GHG emissions (Scope 1+2)
( location-based)
-
4,692,747.7
-
-
Total GHG emissions (Scope 1+2+3)
(market-based) [E1:Ε1-6_52 b]
-5.4%
11,565,162.2
12,227,562.4
12,645,098.8
Total GHG emissions (Scope 1+2+3)
( location-based)
-
11,235,333.3
-
-
5. Annual Board of Directors Management Report
141
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Direct (Scope 1) CO
2
Emissions [E1:E1-6_48_a] [E1:E1-6_48_b ]
61
The calculation was based on the consumption of electricity purchased from fossil sources as reported in the table of total energy consumption and the
emission factor of Greece's 2023 energy production mix (DAPEEP) of 252,441 gCO₂/kWh, in accordance with the guidelines of the GHG Protocol.
62
Of the total Scope 1 emissions of the Metals Sector, 846,140.3 teq CO
2
come from combustion in stationary installations and consist of 0.05% methane (CH
4
),
0.05% nitrous oxide (N
2
O) and 99.90% carbon dioxide (CO
2
).
Table of Total Air Emissions by Sector
61
(teq CO
2
)
Metals Sector
Energy Sector
Infrastructures &
Concessions
Gross direct scope 1 GHG emissions
62
1,242,156.0
2,717,856.1
1,343.4
Gross indirect scope 2 GHG emissions (market-
based)
1,046,442.3
12,717.4
374.3
Gross indirect scope 2 GHG emissions (location-
based)
723,191.0
6,560.8
226.1
Gross indirect scope 3 GHG emissions
1,484,521.8
5,044,304.2
10.272,1
Total GHG emissions (Scope 1+2)
(market-based)
2,288,598.3
2,730,573.5
1,717.7
Total GHG emissions (Scope 1+2)
( location-based)
1,965,347.0
2,724,416.9
1,569.5
Total GHG emissions (Scope 1+2+3)
(market-based)
3,773,120.1
7,774,877.7
11,989.8
Total GHG emissions (Scope 1+2+3)
( location-based)
3,449,868.8
7,768,721.1
11,841.6
5. Annual Board of Directors Management Report
142
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In 2024, total scope 1 GHG emissions increased considerably, as seen in the table below. This increase is mainly due to the
increase in natural gas consumption in the Company's thermal power plants, which rose by 88% compared to 2023. Of the total
emissions, approximately 62.4% comes from activities under the European Union Emissions Trading Scheme (EU ETS).
The emissions reported under Scope 1 are generated from sources (physical production plants or processes) owned or controlled
by the Company. In this case, almost all of these emissions, come from the energy production process (fuel consumption) as well
as from the production of alumina and aluminium (fuel consumption and chemical processes that are part of the production
process).
The direct (Scope 1) GHG emissions calculation methodology (activity-based) focuses on recording and quantifying all GHG
emissions resulting from activities under the Company's control. The process begins with identifying all emission sources. The
quantities of fuels used, such as natural gas, diesel, petrol, etc. are reported, and consumption is documented using bills, meters
or other reliable data sources. The calculation applies emissions factors from recognized sources such as NIR (National Inventory
Report) and DEFRA (Department for Environment, Food & Rural Affairs) that comply with the GHG Protocol guidelines, as they
meet the requirements for the use of emission factors that are scientifically valid and adapted to local or international conditions.
Moreover, these factors allow the conversion of fuel consumption to tons of CO₂ equivalent (CO₂ eq), considering not only carbon
dioxide but other greenhouse gases as well, such as methane (CH
4
) and nitrous oxide (N₂O). The calculation method follows the
Greenhouse Gas Protocol standards, ensuring data transparency and comparability. The choice of emission factors depends on
their precision and suitability for the specific emission sources, ensuring that the data truly reflect the Company’s actual
activities. METLEN strives to continuously improve its methodology by using reliable tools and updated emissions factors,
ensuring that direct emissions are accurately reported and aligned with international reporting standards. [Ε1:E1-6_AR_39_b]
Indirect (Scope 2) CO
2
Emissions [E1:Ε1-6_49_b]
Indirect CO₂ emissions from energy consumption (scope 2) refer to emissions resulting from the production of electricity
purchased and used by the Company. 99% of these emissions come from the Metals Sector, and in particular from the alumina
and aluminium production plant in Greece, a process that has particularly high energy consumption.
In 2024, the Company recorded a ~32% reduction in its indirect emissions (scope 2), despite the constant amount of electricity
purchased for consumption, compared to 2023. This reduction was achieved through the purchase of Guarantees of Origin (GOs)
and the utilization of the mix factor of METLEN (Protergia), which is the main electricity provider of the Company's units. The
reduction of the footprint of these emissions was achieved through the purchase of guarantees of origin for part of the electricity
used, ensuring that a proportion of it came from renewable sources.
Specifically, the Company purchased guarantees of origin for 101,985.00 MWh of electricity, which confirm that this quantity
comes from renewable sources. The warranties were purchased separately from the physical electricity, covering part of the
company's total electricity consumption, which corresponds to 1.3% of total consumption, as shown in the relevant table of
energy consumption of the Metals Sector. At the same time, the use of METLEN's energy mix (Protergia), which has a lower CO₂
emission factor compared to the residual mix of DAPEEP used until 2023, also contributed to the overall reduction of the
company's carbon footprint.
The switch from the DAPEEP factor to the METLEN (Protergia) factor for 2024, improves the accuracy and consistency in the
calculation of the Company's indirect emissions. METLEN (Protergia) is now the sole energy provider of the Company's production
plants and buildings in Greece, which makes the use of this factor more accurate and consistent in the calculation of CO₂
emissions. This allows the Company to have more targeted calculations for indirect emissions, as the emissions attributed to
energy consumption are now directly linked to this provider and the energy mix it offers. Use of the provider’s factor is also
stipulated in the Greek climate law, which encourages the transition to more accurate methods of calculating emissions,
highlighting the importance of transparency and accuracy in the accountability of CO₂ emissions for businesses. The law
reinforces the need for the use of data reflecting actual energy consumption by specific suppliers, allowing companies to
contribute to the national effort to achieve the country's climate targets.
Direct (Scope 1) Emissions Table
(teq CO
2
)
%N/N-1
2024
2023
2022
Fixed installations (Fuel) (CO
2
:100%)
51%
3,561,046.5
2,359,152.9
2,269,019.6
Processes (CO
2
:80% - PFCs:20%)
4%
376,583.0
362,300.0
364,740.1
Mobile (Transport) (CO
2
:100%)
177%
24,529.7
8,278.9
7,090.6
Total
45%
3,962,159.2
2,729,731.8
2,640,850.3
5. Annual Board of Directors Management Report
143
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Indirect (Scope 2) GHG emissions are calculated using energy conversion factors from electricity consumption to carbon dioxide
equivalent. METLEN records the total electricity consumption in all its facilities and activities, collecting the data through
electricity bills issued by the providers or through energy monitoring systems where these exist
64
. The Company calculates
market-based indirect (scope 2) emissions using the residual energy mix factor of the provider(s)
65
supplied by the RES &
Guarantees of Origin Operator (DAPEEP) for year 2023 for its facilities in Greece, and for a very small percentage (0.07%) it uses
the residual mix factor in each foreign country where the Company operates
66
.
Indirect (Scope 3) CO
2
Emissions [E1:Ε1-6_51] [Ε1:E1-6_AR_46_h]
Scope 3 emissions include indirect emissions (not included in Scope 2) arising in METLEN's upstream and downstream value chain,
according to the extent of the Company's operational control. They are generated from sources related to partners (e.g. suppliers,
end-users, lessees), but also end consumers. Based on the GHG Protocol’s
67
proposed methodology, there are 15 distinct
categories of products, services or activities which may be related to the emission of scope 3 GHG emissions. The calculation of
the total quantity of these emissions in 2024 reported a decline -17.6% compared to 2023. This decline is due to: a) a considerable
individual drop of ~88% in category C10 (processing of sold products) in the Metals Sector, where no hydrated alumina was sold
to aluminium smelting plants. These plants, when processing hydrated alumina to produce pure aluminium, emit large quantities
of carbon dioxide (CO₂) because the smelting process requires very high heat and energy. Therefore, not selling this product in
2024 resulted in a significant drop in the company's indirect emissions from this activity; b) a reduction in the natural gas
quantities (Category C11).
[Ε1:E1-6_AR_46_i]
63
The total quantity of location-based indirect emissions (Scope 2) for 2024 is 730,588.5 tons of CO₂. The calculation was based on the electricity consumption
purchased from fossil sources and RES, as stated in the total energy consumption table and the emissions factor of Greece’s 2023 energy production mix (DAPEEP)
of 252,441 gCO₂/kWh, in accordance with the GHG Protocol guidelines.
64
In the calculation of Scope 2 emissions, in some of the Company's activities, estimates have been used regarding the amount of electricity purchased for the
last month of 2024, affecting the overall picture of these emissions negligible.
65
Greece emissions (tCO
2
e)=Consumption (MWh)×METLEN factor (tCO2e/MWh)
66
Emissions (tCO₂e)= Energy Consumption (MWh) × Provider Residual Mix Factor or the available Residual Energy Mix in each country where the Company
operates (tCO₂e/MWh)
67
WRI & WBCSD, Greenhouse Gas Protocol: Corporate Value Chain (Scope 3) Accounting and Reporting Standard - Supplement to the GHG
68
Not including the Volos industrial plant
Indirect (Scope 2) Emissions Table
63
(teq CO
2
)
%N/N-1
2024
2023
2022
Market-based: Electricity (CO
2
: 100%)
-31.8%
1,060,417.5
1,555,613.5
1,281,939.2
Indirect (Scope 3) Emissions Table
(teq CO
2
)
Calculation methodology
2024
2023
2022
C1: Purchased goods and services
based on activity data
& based on expenditure
1,262,638.5
1,465,664.3
1,688,761.3
C2: Capital goods
based on activity data
& based on expenditure
1,531,670.5
1,705,297.6
1,281,625.2
C3: Fuel and energy-related activities
based on activity data
1,270,363.9
1,074,179.8
1,106,925.3
C4: Upstream transportation and distribution
based on activity data
140,227.2
42,438.9
12,471.2
C5: Waste generated in operations
based on activity data
57,231.8
38,931.2
59,545.1
C6: Business travel
based on activity data
& based on expenditure
1,657.0
2,084.6
718.5
C8: Upstream leased assets
based on activity data
3,487.4
3,486.8
2,127.0
C9: Downstream transportation and distribution
based on activity data
94,408.8
21,185.8
15,913.0
C10: Processing of sold products
based on activity data
108,814.6
888,822.9
1,071,653.4
C11: Use of sold products
based on activity data
1,714,742.4
2,407,162.5
3,331,599.4
C12: End-of-life treatment of sold products
based on activity data
357,221.0
292,962.6
150,969.9
C14: Franchises
based on activity data
122.5
0.0
0.0
Total
68
6,542,585.6
7,942,217.1
8,722,309.3
C7: Employee commuting
C13: Downstream leased assets
C15: Investments
Non-material categories
5. Annual Board of Directors Management Report
144
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The calculation of scope 3 emissions related to METLEN's activities is carried out on the basis of the proposed methodological
framework of the GHG Protocol, while no primary data from suppliers or other partners of the Company's value chain have been
used. This framework applies the combination of two methodological approaches to analyse secondary data
69
per emission
category:
Approach 1: Activity data-based calculation. In this case, the scope 3 emissions are calculated based on the quantitative activity
data of the service or good in question used by the company, i.e. quantities, transport work, distance, energy consumption, etc.,
and appropriate emission factors characterising the use of such services or goods. Specifically, the carbon footprint factor per
unit of activity is used, which has either been calculated for the specific service/good by the respective supplier or comes from
the available literature and concerns the respective product or service in the reference year.
Approach 2: Expense-based calculation. This approach is used to calculate scope 3 emissions based on the amount of money
paid for a service or good. The Company calculates the CO
2
emissions resulting from the production of the good or service it has
purchased, using the economic value of that purchase. To do so, the Input-Output (I-O) matrix is used. This matrix shows the
relationship between different economic sectors (e.g., industry, transport) and how much they affect the environment. Each
sector has an environmental I-O factor, which calculates how much CO
2
emissions are generated for each monetary unit spent in
that industry. This methodological approach uses the I-O environmental factors of countries (e.g. Greece) and regions (e.g. the
European Union) where production activities are performed. Output input matrices and sectoral emission factors are drawn from
Eurostat, OECD, and/or WIOD.
GHG intensity based on the Company's net revenue [E1:E1-6_53] [E1:E1-6_54] [E1:E1-6_55] [E1:E1-6_AE 53] [E1:E1-6_AE 54] [E1:E1-6_AE 55]
Despite the increase in direct scope 1 emissions, due to the enhanced activity of the Energy Sector, the company's overall footprint
showed a positive trend, as the reduction of indirect emissions of scope 2 and 3, as analyzed in the relevant sections, contributed
to the overall improvement of the emissions intensity index compared to 2023.
E1-7 GHG removal & E1-8 Internal carbon pricing
The Company does not have any projects related to GHG removals or GHG mitigation projects funded through carbon credits. It
also does not currently implement internal carbon pricing systems, however this approach is being explored.
69
All (100%) of scope 3 emissions are the result of secondary data calculation. [E1:E1-6_AR_46_g]
70
Total location-based direct and indirect emissions (Scope 1+2+3) in tonnes of CO₂ per € million for 2024 is 1,977.0.
71
The nominator used in the calculation of CO
2
emisssions intensity, agrees with the total GHG emissions (Scope 1+2+3) (market-based) and the denominator
with the amount of net sales as calculated and reported in the Company's financial statements - Table A. Profit and loss statement - Line: Net Sales.
GHG Emissions Intensity Indicator based on the Company's net revenue
70
(tCO
2
/€ mil. net revenue)
%Ν/Ν-1
2024
2023
2022
Total Scope 1, 2 & 3 GHG emissions
(market-based) (tCO2eq/€mil.)
71
-8.6%
2,035.0
2,226.6
2,005.1
5. Annual Board of Directors Management Report
145
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
POLLUTION [ESRS: E2]
The key challenge for METLEN Energy & Metals is to effectively prevent any form of pollution of the natural environment both
from its production activity and from any major industrial accidents.
ESRS2: SBM-3
Material impacts, risks, and opportunities and their interaction with the strategy and business model
ACTUAL NEGATIVE IMPACT [AN2]
72
:
Emission of NOx, SOx and other significant gas pollutants
NOx and SOx emissions mainly come from METLEN's industrial activities, including fossil fuel power generation and metal
processing. However, the Company, as part of its Sustainable Development strategy, has incorporated in its operation best
available practices respecting the limits of such emissions, even below what is allowed under the legislation. This includes
investing in new clean energy technologies and upgrading existing facilities with more environmentally-friendly solutions.
Time Horizon:
Actual
Position in the Value Chain:
Own Operations
CURRENT AND POTENTIAL IMPACTS ON THE BUSINESS
MODEL & VALUE CHAIN [SBM3:48_b]
CURRENT AND POTENTIAL IMPACTS ON STRATEGY &
DECISION-MAKING
[SBM3:48_b]
a) Continuous improvement of methods for controlling and
managing air emissions
b) Potential cooperation with suppliers to reduce the
environmental footprint of inputs
The strategy is being adapted to ensure compliance with
possible stricter emission limits in the future, enhancing
emissions monitoring and management through digital tools
and reporting.
a) Development and implementation of a specific emissions
management policy.
b) Decisions to invest more in new technologies to reduce
emissions.
c) Setting specific emission reduction targets
d) Enhancing partnerships with specialised bodies to jointly
develop solutions and improve environmental performance.
POTENTIAL NEGATIVE IMPACT [PN3]
73
:
Degradation of soil and water & marine resources due to significant pollution incidents
This potential impact is directly linked to the Company's core industrial activities, which include the extraction and processing
of metals, as well as energy production. The Company prioritises the prevention of any land and marine pollution, the
environmentally sound management of all emissions in accordance with the legislation and the internationally agreed
frameworks, and the reduction of such emissions into the air, the water and the soil to reduce their impact on human health
and the environment.
Time Horizon:
Short Term
Position in the Value Chain:
Upstream, Own Operations, Downstream
CURRENT AND POTENTIAL IMPACTS ON THE BUSINESS
MODEL & VALUE CHAIN [SBM3:48_b]
CURRENT AND POTENTIAL IMPACTS ON STRATEGY &
DECISION-MAKING [SBM3:48_b]
a) Shutdown or suspension of operations in affected areas,
resulting in temporary production stoppages or delays in
projects.
b) Enhanced compliance with regulatory requirements,
with potential adjustments to processes and infrastructure
that increase operational costs.
a) Re-evaluation and tightening of environmental targets and
procedures, including the integration of additional pollution
prevention measures.
b) Review the strategic positioning in local markets, where
pollution can bring about social and regulatory reactions.
72
As shown by the significance assessment (see [ESRS2:SBM-3] & [ESRS2:IRO-1])
73
As shown by the significance assessment (see [ESRS2:SBM-3] & [ESRS2:IRO-1])
5. Annual Board of Directors Management Report
146
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
c) Reduced reputation and credibility of the Company,
affecting customer and partner trust.
d) Supply chain disruption due to reluctance to co-operate
by suppliers due to failure to meet their own compliance
requirements.
e) Potential demands from local communities for greater
transparency in environmental risk management practices
due to pollution or ecosystem disruption concerns.
c) Enhancement of investments in decontamination
technologies and more environmentally-friendly production
processes.
d) Establishment of a risk management strategy with
increased provisions for potential environmental incidents.
E2-1
Policies on pollution prevention
METLEN Energy & Metals has the following pollution prevention policies in place. The Central Environmental Policy establishes
the framework of the Company's actions to reduce the environmental impact at each level of operation, while the Major
Industrial Accident Prevention Policy applied to the primary aluminium plant enhances safety with mechanisms to prevent serious
incidents that could affect local communities and ecosystems. At the same time, the Suppliers and Business Partners Code of
Conduct gives specific guidelines for the prevention of any form of pollution contributing to resilience and transparency
throughout the Company's supply chain. [Ε2:Ε2-1_14]
CENTRAL ENVIRONMENTAL POLICY [E2:E2-1_15_a]
Year updated
2024
Key Content
[MDR-P_65_a]
Key elements of the Policy are the following principles of responsible environmental behavior: 1) the
reduction of air emissions, 2) the prevention of pollution risks, as well as the implementation and
implementation of plans to reduce negative impacts on the environment, 3) the preparedness and
response to environmental emergencies by implementing relevant action plans to deal with them.
Targeting
[MDR-P_65_b]
[E2:E2-1_15_a]
[E2:E2-1_15_c]
The implementation of the Policy includes the Company's own activities as well as those in which it
has operational control within the upstream and downstream value chain, in all areas of its activity.
Governance
[MDR-P_65_c]
a) Approved by the Company's Sustainability Committee.
b) Designed and revised by the Company's General Division for Corporate Governance and
Sustainable Development in cooperation with the General Divisions of the Company's Business Units,
which are also responsible for its implementation.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
a) ISO 14001:2015 International Standard
b) Global Sustainable Development Goals (6,7,12,13,14,15 & 17)
c) ASI Performance Standard
Inclusion of
Stakeholder interests
[MDR-P_65_e]
Annual Stakeholder Consultation
Availability
[MDR-P_65_f]
Company’s website
74
and intranet
MAJOR INDUSTRIAL ACCIDENT PREVENTION POLICY
Year updated
2024
Key Content
[MDR-P_65_a]
[MDR-P_AR_21]
[Ε2:Ε2-1_15_a]
[Ε2:Ε2-1_15_c]
Preventing and addressing the risks of large-scale industrial accidents related to the use of hazardous
substances, recognizing that activities related to the production of alumina and aluminium inherently
involve the risks of a major industrial accident that can affect workers, contractors, factory visitors,
and the facility's adjacent natural environment.
Mitigating impacts by methods and procedures that ensure a high level of protection for people and
the environment by identifying potential emergencies and preparing appropriate plans to deal with
those situations, for its activities, as well as for its upstream and downstream value chain, over which
it has operational control.
Targeting
[MDR-P_65_b]
The implementation of this Policy includes part of the Company's own activities, and more specifically
the "Aluminium of Greece" plant, of the Metals Sector.
Governance
[MDR-P_65_c]
The Top Management of the plant is committed to the implementation of the Policy.
74
https://www.metlengroup.com/media/l0rkoqbr/environmental-policy.pdf
5. Annual Board of Directors Management Report
147
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
JMD 172058/2016: Specification of rules, measures and conditions for addressing major-accident risks
in facilities or plants due to the presence of dangerous substances, in compliance with the provisions
of Directive 2012/18/EU
Inclusion of Stakeholder
interests
[MDR-P_65_e]
Clear definition of the roles and responsibilities of the personnel involved in Safety issues during the
operation of the plant and in dealing with the risks of large-scale industrial accidents, as well as
providing appropriate training to the employees and staff working in subcontractors of the company
on issues related to Safety and Health in the activities of the plant.
Availability
[MDR-P_65_f]
Intranet
SUPPLIERS AND BUSINESS PARTNERS' CODE OF ETHICS
Year updated
2023
Key Content
[MDR-P_65_a]
METLEN expects all its Suppliers/Partners
75
to adopt and promote in their dealings with their
employees, suppliers, contractors and customers the avoidance of any form of leakage of hazardous
materials and substances related to their activity, as well as to be able to effectively deal with such
incidents, if or if they occur, but also bear the cost of repairing the damage. Also, any water discharges
and wastewater generated by activities, industrial processes and sewage facilities must be monitored,
controlled and treated as required, prior to the discharge process, in accordance with applicable laws
and regulations. The provisions of the Code are guidelines for business conduct and should be
considered as a supplement to the contracts signed between METLEN and each Supplier/Partner.
Targeting
[MDR-P_65_b]
[MDR-P_AR_11]
[Ε2:Ε2-1_15_a]
[Ε2:Ε2-1_15_c]
The implementation of the Code includes the Company's own activities as well as those in which it has
operational control within the upstream and downstream value chain, in all areas of its activity.
Governance
[MDR-P_65_c]
The Director of Compliance is responsible for the implementation of the Code, in cooperation with:
a) the Purchasing / Procurement Divisions
b) the Sustainable Development Divisions
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
METLEN positively evaluates the voluntary participation of its Suppliers/Partners in the United Nations
Global Compact.
Inclusion of Stakeholder
interests
[MDR-P_65_e]
a) Annual Stakeholder Consultation
b) Negotiations for the conclusion of a supply contract
c) Sustainability training for key suppliers
d) Evaluation of key suppliers according to ESG criteria
Availability
[MDR-P_65_f]
Company’s website
76
and intranet
E2-2
Actions and resources related to pollution prevention
The following are the key actions throughout the years as well as the actions taken within 2024 relating to the reported impacts
at all stages of the value chain, by key Sector: [MDR-A_68_b] [MDR-A_68_c] [Ε2:Ε2-2_18]
Metals Sector [MDR-A_68_a]
The METLEN Metals Sector applies an integrated approach to pollution prevention and environmental protection, based on strict
standards and guidelines (EIA, AEP, ISO 14001, ASI, BAT, etc.). The company is committed to strict compliance with the
Environmental Terms in its metallurgical activities, with continuous monitoring of air emissions and particulate matter, as well
as control of wastewater discharges from point sources and proper solid waste management.
When submitting the Environmental Impact Studies to the licensing authorities for the issuance of the Environmental Terms, a
public consultation process is followed through which comments can be expressed by all interested parties.
75
"Suppliers/Partners" used in this document refers to suppliers, contractors, subcontractors and business partners who provide work, product and services or
who act on behalf of METLEN.
76
https://www.metlengroup.com/media/vj0j4005/mytilineos_suppliers_code_of_conduct_2023_en.pdf
5. Annual Board of Directors Management Report
148
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Solid waste management is continuous and includes recycling/recovery through licensed partners and alternative management
systems for specific waste streams, while for those that cannot be recovered, the company ensures their safe disposal in insulated
and properly licensed areas (Inert Waste Disposal Site and Non-Hazardous Waste Disposal Site). Respectively, hazardous solid
waste that is not diverted for recovery through licensed partners is deposited in specially designed cells (Hazardous Waste
Landfill) based on a specific licensing and legislative framework.
The Sector applies Best Available Techniques (BAT) in all infrastructures, with advanced filters and waste treatment systems, as
well as appropriate equipment to manage discharges and improve waste quality. In addition, chemical analyses of liquid waste
are carried out to monitor the parameters as defined by the AEP, while systematic monitoring of the physical final recipients is
maintained (see ESRS E5).
Particular attention is paid to the management of chemicals in accordance with the Safety Data Sheets, while systematic checks
are carried out at the facilities. In accordance with SEVESO III legislation and Joint Ministerial Decision 172058/2016, all preventive
measures are complied with and drills are carried out on how to deal with major industrial accidents, in cooperation with external
bodies such as the Fire Brigade and Civil Protection as specified.
At the same time, in order to protect the marine environment in the event of an accident in the ship loading/unloading zone,
which is also its area of responsibility under the regulatory framework, the Company has properly certified anti-pollution
equipment in place, including floating dams, absorbent materials and oil extraction systems from the sea. In the mining business,
the Company successfully manages incidents of any small lubricant leaks in underground tunnels from the mining machinery,
taking measures to reduce incidents through the supply of decontamination materials, by increasing staff awareness (direct
employees and subcontractor employees) through training seminars and the regular preventive maintenance of the equipment
and its components. At the same time, in the event of a spill, the amount of soil in the area of the spill is immediately collected
and forwarded for safe management as hazardous waste. [Ε2:Ε2-12_AR_13]
In addition, in 2024, Metals Sector undertook the following actions: [Ε2:Ε2-2_18] [Ε2:Ε2-2_AR_15]
a) Completing the upgrade of the industrial wastewater treatment filter at the primary aluminium and alumina plant. By
upgrading the filter, the capacity of the filtration unit is increased and optimal filtration of the discarded liquids at the
final recipient is achieved.
b) Test of new technology type sleeves with increased filtering capacity aiming at more efficient operation of the
Electrolysis gas treatment plant at the primary aluminium plant. This action concerns the use and testing of new special
sleeves, which have an increased filtration capacity, to improve the treatment of the gases produced in the electrolysis
plant. This test is applied in the context of continuous improvement of anti-pollution infrastructure.
c) Reconstruction of a reflective oven filter unit at the secondary aluminium plant. This action aims to improve the
filtration system connected to the reflective
77
furnace in the secondary aluminium plant. The reflective oven produces
waste gases during the processing of aluminium; waste gases are processed through the filter unit before being released
to the environment.
d) Improvement of internal waste management areas at the secondary aluminium plant. This action concerns the
improvement of the areas within the facilities where waste is collected, classified and temporarily stored before it is
removed for recycling or treatment. By improving these areas, it is ensured that waste is managed safely and efficiently,
thereby reducing the risk of leakages, accidents or other effects that could cause environmental pollution.
e) Installation of a Wastewater Treatment System (WWTS) at the bauxite mining site. The system treats the water from
machinery washing so that it releases water suitable for the enrichment of an underground aquifer. In particular, the
water first passes through a double settling tank, and then the water is channelled through special sand and carbon
filters to contain any residual pollutants.
Energy Sector [MDR-A_68_a] [Ε2:Ε2-2_18] [Ε2:Ε2-2_AR_15]
In the Energy Sector in all production units – thermal plants, renewable energy sources (RES) and construction sites – continuous
intensive procedures are applied intensive procedures to identify and prevent potential risks, in order to reduce the impact of
unforeseen malfunctions and accidents. To avoid pollution, approaches incorporated into the Environmental Management
Systems and the Emergency Response Plans are followed, with guidelines for facility maintenance and operation.
77
A type of oven mainly used in metallurgy, especially for melting and processing metals such as aluminium and copper. The name "reflective" is derived from
the way the oven works: flames and heat are reflected from the oven's roof and directed towards the materials melting at its bottom. This allows for even heat
distribution, making the process more efficient.
5. Annual Board of Directors Management Report
149
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In the context of the application of Best Available Techniques, especially in thermal power plants, the continuous monitoring and
recording of waste gas parameters is a key priority. This includes the measurement of oxygen content, temperature and pressure,
as well as the process of drying the waste gases prior to analysis. In addition, the emission of sulphur dioxide (SO
2
) is calculated
based on the operational characteristics of the Station and the composition of the natural gas used as fuel. It is also important to
measure the exhaust flow rate, which is carried out periodically. As regards control combustion and monitor gaseous emissions,
an advanced automated computerized control system is used. Natural gas used as fuel meets the strictest environmental
standards, according to the analyses carried out. To minimize emissions of NOx, CO and volatile organic compounds into the
atmosphere, strategies such as the gradual introduction of natural gas, the use of low NOx dry-type (DLN) burners, as well as
advanced control systems for monitoring gaseous emissions and wastewater quality characteristics are implemented.
The objective is optimal combustion in order to ensure CO emissions reduction. In addition, wastewater flows are collected in
separate streams, depending on their pollutant content, in order to undergo separate treatment. Overall, systematic monitoring
of air pollutants is carried out and the use of the best available options for the reuse, recycling and safe disposal of waste is
promoted. At the same time, staff training and readiness drills ensure immediate response in cases of leaks, while preventive
maintenance programs and selection of state-of-the-art equipment, such as safety oil sumps, enhance the resilience of the
facilities.
Finally, systematic visual checks on the premises ensure compliance with environmental standards, while annual audits by
external bodies ensure the certification of Environmental Management Systems, thus supporting the company's commitment to
high sustainability and environmental protection standards.
Financial Resources related to Action Plans
METLEN accurately calculates the cost of managing gas emissions resulting from its production activity, ensuring their effective
management. Through this approach, the Company makes timely and informed decisions, which are incorporated into the
financial forecasting, budgeting and costing processes. In 2024, €1,778,851 was spent on operating expenditures (OpEx) and
€231,920 on capital expenditure (CapEx) for the implementation of all the aforementioned actions in all Sectors. [Ε2:E2-6_40_b]
[MDR-Α_69_b]
METRICS & TARGETS
E2-3
Pollution prevention targets
In the Metals Sector, and specifically in the production of primary cast aluminium, the Company has set specific targets regarding
the management of air pollutants and maintains actions for continuous and documented compliance, specific targets that are
fully in line with the legislative limits set by the Environmental Terms Approval Decision (AEPO) of the Aluminium of Greece plant.
Characteristically, it is mentioned that for the monitoring of the air quality of the wider area of the industrial pole (AoG and Agios
Nikolaos Energy Center), a continuous measurement station has been installed in compliance with the provisions of Directive
2008/50/EC7
78
. The station, located within the boundaries of the Holy Monastery of Osios Loukas (a monument included in the
relevant UNESCO World Heritage List), continuously records the cumulative concentrations of pollutants NO2, SO2, PM (including
urban, agricultural, etc. activities of the wider area), as well as meteorological data. [MDR-Τ_80_a] [MDR-Τ_80_c] [MDR-Τ_80_f] [MDR-
Τ_80_g] [E2:E2-3_23_a]
The limit values imposed at this point are: [MDR-Τ_80_b] [MDR-T_80_e]
1. NO
2
: 200 μg/m
3
for yearly average hourly values,
2. SO
2
: 350 μg/m
3
for yearly average values;
3. Particulate matter (PM10): 50 μg/m
3
for the yearly average hourly values.
The setting of annual performance targets meets the requirements of the certified according to the international standard ISO
14001 Environmental Management System. In particular, their regular establishment takes into account all compliance
obligations, the best practices and commitments of the Company. [MDR-Τ_80_h]
78
Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air quality and cleaner air for Europe, which has been
incorporated into the law of Greece J.M.D. U.S. 14122/549/E.103/2011 (B 488) as amended by J.M.D. 174505/607/2017 (B 1311).
5. Annual Board of Directors Management Report
150
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
As regards the mining business in particular the assessment of target achievement includes water sampling chemical analyses
and measurements covering dust and gaseous pollutants; such assessment provides a comprehensive picture of the
environmental impact. The said measurements contribute to the timely detection of potential deviations and allow for immediate
corrective actions, if necessary, thus keeping environmental performance within the desired limits. [MDR-T_79_a] [MDR-Τ_80_g]
These targets also have an investment aspect, as their achievement requires the application of new technologies, the
improvement of infrastructure and the continuous upgrading of equipment used in environmental processes. The effectiveness
of the above targets is evaluated through continuous or discontinuous measurements of air pollutants or water chemical analyses
based on a programme and monitoring of environmental indicators. The results of the said evaluations determine progress in
achieving targets and allow further measures to be taken if required. [MDR-T_80_e]
Compliance with the imposed emission limits is a well-established and successful achievement for the plant, where efforts are
now focused on further improvement to the extent technologically feasible. The results of environmental monitoring and
performance are sent annually to the competent authorities, as part of the legal obligation for the regular submission of an
annual environmental audit report, and are available at each on-site inspection carried out by teams of the Region of Central
Greece and/or the Corps of Inspectors. [MDR-T_80_j]
In the Energy Sector, regarding the emissions of power plants from natural gas combustion, the following limits are set, based
on the applicable legislation and the Environmental Terms of the Thermal Units:
a) NOx (as NO
2
): 50 mg/Nm
3
b) CO: 100 mg/Nm
3
Specifically, regarding the year 2024, the emission values recorded remained within the prescribed limits, effectively contributing
to the achievement of environmental protection targets. These limit values are important to control air quality degradation and
to ensure that plants remain within permissible limits, thereby protecting the environment and public health. [E2:E2-3_22] [E2:E2-
3_23_a]
Targets are monitored through monthly reports and management reviews. Concentrations of NO
2
and CO gases, as well as the
temperature (T) and pressure (P) of the plant's exhaust gases, are continuously measured and monitored through the Continuous
Emission Monitoring System (CEMS), which monitors the quality of emissions in real time and ensures that the values remain
within permissible limits, thus helping to comply with the legislation and protect the environment.
In the construction subsidiary METKA ATE, the state of the environment and the adherence to environmental construction
conditions is monitored through data collected from the measurement points. In the Management Systems there is a target for
zero environmental accident. [MDR-T:80_a]
E2-4
Pollution of air, water and soil
During 2024, there were no incidents of pollution of the natural environment from the production activity, which have caused
deterioration of water and soil
79
. For this reason, this section focuses on the release of air pollutants and is analyzed below.
The Metals Sector is the main source of SOx emissions, while the Energy Sector plays a key role in NOx emissions. The total
amount of air pollutants for 2024 recorded an increase of 9.3% compared to 2023, mainly due to the increase in NOx emissions,
due to increased production activity of the Energy Sector, despite the small individual decrease in SOx emissions. In terms of
particulate emissions, a positive performance was recorded for another year, with a slight decrease compared to 2023. Similarly,
volatile organic compound (VOC) emissions, which have seen a slight increase of 6%, have generally been stable over the last few
years three years, while small fluctuations are associated with impurities in raw materials (secondary aluminum scrap with
organic load, e.g. paints, burrs, wire, sorting profiles, etc.) for the production of secondary cast aluminum. [E2:E2-4_30_a]
79
As there have been no water and soil pollution incidents over time, specific quantitative indicators are not made public.
5. Annual Board of Directors Management Report
151
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
[Ε2-4 28_a] [ΑR 21]
[Ε2-4 28_a] [ΑR 22]
The Company monitors changes in pollutant emissions over time, analyzing trends and factors that affect them. The
measurement of pollutants is carried out using both direct measurements from certified monitoring stations and computer
models where required, depending on the nature of the emission and its source. If additional emissions data are required for
disclosure, beyond legal requirements, these shall also be included in the monitoring plan of the installation. The environmental
permits of each installation specify the monitoring points, frequency and methodology, as well as the legal requirements for
reporting. Data is collected through organized procedures that ensure its accuracy and completeness, including internal
monitoring systems and reports from production units. The total annual emission data presented shall be calculated on the basis
of emission factors related to the emission source. Recording and reporting follow applicable standards, ensuring transparency
and compliance with regulatory requirements. [E2:E2-4_30_b] [E2:E2-4_30_c]
In addition, sulphur dioxide emissions are calculated stoichiometrically in the electrolysis process taking into account the sulphur
content of the anodes consumed annually. The imposed limit value for sulphur dioxide emissions is <15kg / ton of produced
aluminium (Al)
82
according to the best available techniques. Also, continuous measurement of sulphur dioxide emissions is carried
out in the exhaust gases of the anode electrode firing oven during their processing for dust and fluoride retention.
80
The total amount of Perfluorocarbons (PFCs) has been corrected, which now includes emissions of Tetrafluorocarbons (CF₄) and Hexafluorocarbons (C₂F₆). In
previous reports, the quantities of these two compounds were published as separate categories, which had led to double counting, which has now been smoothed
out by this correction.
81
The values in the table relate to all pollutants, i.e. they are not limited to emissions from installations for which the applicable limit value set out in Annex II to
Regulation (EC) No. 166/2006“
82
Refers specifically to electrolysis (electrolytic cells)
Table of gaseous pollutants
80
Types of air pollutants (t)
2024
2023
2022
SΟx
2,790.3
2,892.2
3,273.6
NOx
1,775.0
1,276.2
1,413.8
Fluorine
253.4
249.4
270.3
Particulates
32.0
33.0
38.9
Perfluorocarbon (PFC):
8.5
7.9
7.9
Tetrafluorocarbon (CF
4
)
7.6
8.0
7.9
Hexafluorocarbon (C
2
F
6
)
0.9
1.0
1.0
Volatile Organic Compounds (VOC)
7.0
6.6
7.0
Persistent Organic Pollutants (POP)
-
-
-
Hazardous Air Pollutants (HAP)
-
-
-
Hydrofluorocarbons (HFC)
-
-
-
Sulphur hexafluoride (SF
6
)
-
-
-
Nitrogen Trifluoride (NF
3
)
-
-
-
Dioxins / Furans
-
-
-
Polycyclic Aromatic Hydrocarbons (PAHs)
-
-
-
Heavy Metals
-
-
-
Total (t)
4,866.2
4,465.3
4,955.7
Table of air pollutants by Business Sector
81
Types of air pollutants (t)
Metals Sector
Energy
Sector
Infrastructure-
Concessions
Total
SΟx
2,790.3
-
0
2,790.3
NOx
640.7
1,134.3
0
1,775.0
Fluorine
253.4
-
0
253.4
Particulates
32.0
-
0
32.0
Perfluorocarbons (PFC):
8.5
-
0
8.5
Tetrafluorocarbon (CF
4
)
7.6
-
0
7.6
Hexafluorocarbon (C
2
F
6
)
0.9
-
0
0.9
Volatile Organic Compounds (VOC)
7.0
-
0
7.0
Total (t)
3,731.9
1,134.3
0
4,866.2
5. Annual Board of Directors Management Report
152
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Continuous monitoring for documented compliance with legislative limits and restrictions for primary and secondary aluminium
plants, as well as for mining activities, is part of the overall commitment to environmental responsibility and compliance with the
company's Environmental Policy.
Finally, regarding the incidents of small and local lubricant leaks from machinery failures in the context of the mining process of
the subsidiary company DELPHI-DISTOMON, in 2024, a total of 54 incidents occurred, 53% less than the corresponding number
of 2023 (117), with the total volume of leaks amounting to 14,244lt
83
, reduced by 48% compared to 2023 (27,641 lt).
These incidents are an inevitable occurrence of the mining process, since they are mainly caused by the wear of the chips and
the damage of the machinery from falling stones or rocks. They are not serious leaks, while their treatment is immediate,
collecting in detail the amount of soil that has been contaminated and forwarding it for management to properly licensed
hazardous waste management companies.
83
The quantity of 14,244 lt corresponds to 0.09 kbls.
5. Annual Board of Directors Management Report
153
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
WATER AND MARINE RESOURCES [ESRS: E3]
Water is an essential and irreplaceable natural resource for METLEN's core operations. The Company manages water and water
resources in general with a high sense of responsibility towards both the natural environment and the rights of the local
communities adjacent to its facilities.
E3. SBM-3
Material impacts, risks, and opportunities and their interaction with the strategy and business model
POTENTIAL NEGATIVE IMPACT [PN1]:
Salinization of groundwater resources due to over-abstraction
84
This impact is directly related to the operation of the alumina and aluminium production plant as well as the Company's
thermal power plants. [SMB-3_48_a]
Time Horizon:
Long Term
Position in the Value Chain:
Own Operations
CURRENT AND POTENTIAL IMPACTS ON THE BUSINESS
MODEL & VALUE CHAIN
CURRENT AND POTENTIAL IMPACTS ON STRATEGY &
DECISION MAKING
a) Reduced availability of industrial water in production
activities, affecting output flow.
b) Reduction of drinking water reserves during periods of
water scarcity.
a) Review of the water resources management strategy to
meet new challenges.
b) Need to develop specific targets for water consumption
reduction.
ACTUAL POSITIVE IMPACT [AP3]
Reuse of seawater discharges
85
This impact is directly related to the operation of the Company's thermal power plants. [SMB-3_48_a]
Time Horizon:
Actual
Position in the Value Chain:
Own Operations
FINANCIAL OPPORTUNITY [E3-O1]: Ensuring production stability and reducing the need for additional investments and
extra operating costs
Financial Significance:
Very high
Time Horizon:
Short, Medium & Long Term
Position in the Value Chain:
Own Operations
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS
MODEL & VALUE CHAIN
CURRENT AND POTENTIAL IMPACT ON STRATEGY &
DECISION MAKING
a) Optimization of energy generation processes due to the
reuse of available resources.
b) Stabilization of marine resource input despite the
growth of operations.
c) Savings on seawater withdrawal and treatment.
d) Enhancement of the Company's sustainable
development profile.
a) Improvement of long-term sustainability adopting
responsible, innovative solutions in marine resource
management.
b) Strengthening of the sustainable development strategy,
further reducing the environmental footprint.
c) Adoption of transparency and accountability policies and
practices regarding water and marine resources management.
84
As shown in the materiality assessment (see [ESRS2:SBM-3] & [ESRS2:IRO-1])
85
As shown in the materiality assessment (see [ESRS2:SBM-3] & [ESRS2:IRO-1])
5. Annual Board of Directors Management Report
154
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In relation to water management, METLEN does not experience any financial consequences affecting its financial position,
financial performance or cash flow. Recognizing that water is the most important natural resource, the Company has adopted
effective measures to manage it and prevent the associated risks. The Company complies with regulations and legislation on
responsible water pumping, while informing on an annual basis and in the interim, when required, the competent control
authorities.
It also closely monitors the water availability level and implements responsible pumping with the main concern of avoiding
salinization, in order to ensure that the Company's production rate is not affected, ensuring stable performance and workflow.
In conclusion, the resilience of the Company's business model in dealing with financial risks related to water resources
management is based on: a) the implementation of a strong central Environmental Policy that allows it to effectively manage,
anticipate and maintain low levels and, as far as possible, reduce the likelihood of incidents with a negative impact on water;
ensuring its uninterrupted operation, b) the continuous assessment and monitoring of pumping and discharge levels, adapting
its practices to face new risks or emerging threats, c) the flexibility it has for its immediate adaptation, through its specialized
environmental administrative units, to new conditions or stricter regulations, minimizing the financial impact, d) the continuous
awareness of its staff, e) its commitment to upgrading its infrastructure and processes, incorporating innovative technologies
and best practices and f) investing in insurance coverage. [SBM3:_48_f]
E3-1
Policies related to water and marine resources
METLEN has and implements policies that ensure the proper use and protection of water and marine resources in its operations
and supply chain. The Company has not approved a policy related to sustainable oceans and seas, however in relation to seawater
it applies responsible abstraction, use and disposal practices, as reflected in its central environmental Policy. [Ε3:Ε3-1_12_aii] [Ε3:Ε3-
1_12_aiii] [Ε3:Ε3-1_12_c] [Ε3:Ε3-1_14]
CENTRAL ENVIRONMENTAL POLICY
Year of update
2024
Key Content
[MDR-P_65_a]
In the context of sustainable management of natural capital includes, among others, the rational and
sustainable abstraction, use and disposal of water while managing the risks associated with water
scarcity. [Ε3:Ε3-1_12_a]
Targeting
[MDR-P_65_b]
The implementation of the Policy includes the Company's own activities as well as those in which it has
operational control within the upstream and downstream value chain, in all areas of its activity.
Governance
[MDR-P_65_c]
a) Approved by the Company's Sustainability Committee.
b) Designed and revised by the Company's Corporate Governance and Sustainable Development
General Division in cooperation with the General Divisions of the Company's Business Units, which are
also responsible for its implementation.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
a) ISO 14001:2015 International Standard
b) Sustainable Development Goals (6,7,12,13,14,15 & 17)
c) ASI Performance Standard
Inclusion of
Stakeholder interests
[MDR-P_65_e]
Annual Stakeholder Consultation
Availability
[MDR-P_65_f]
Corporate website
86
and intranet
HUMAN RIGHTS POLICY
Year of update
2021
Key Content
[MDR-P_65_a]
The Company is committed to respecting and supporting the rights of its local communities regarding
land use, the use of natural resources and especially water, as well as the preservation of local cultural
heritage as key elements of their sustainability.
Targeting
[MDR-P_65_b]
The implementation of the Policy includes the Company's Own Operations as well as those in which it
has operational control within the upstream and downstream value chain, in all areas of its activity.
Governance
[MDR-P_65_c]
a) Human Resources General Division.
b) Corporate Governance and Sustainable Development General Division
c) Regulatory Compliance Division
86
https://www.metlengroup.com/media/l0rkoqbr/environmental-policy.pdf
5. Annual Board of Directors Management Report
155
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
a) The United Nations Universal Declaration of Human Rights
b) The Principles of the UN Global Compact.
c) The Sustainable Development Goals (2030 Agenda).
d) The United Nations Guiding Principles on Business and Human Rights.
e) The Guidelines of the Organisation for Economic Co-operation and Development (OECD).
f) ASI Performance Standard
Inclusion of Stakeholder
interests
[MDR-P_65_e]
a) Annual Stakeholder Consultation
b) Dedicated thematic consultation with key Stakeholder groups.
Availability
[MDR-P_65_f]
Corporate website
87
and intranet
E3-2
Actions and resources related to water and marine resources
[Ε3:Ε3-2_17]
In order to achieve more efficient water management, METLEN applies an integrated approach to continuous improvement in
all its key production units. [SBM-3 48_b] Specifically:
a) Regulatory compliance regarding water management is ensured by strictly following the AEPO and Water Use Licenses
in all industrial plants of the Company.
b) The Company communicates regularly with competent authorities and regulatory bodies to identify and assess future
potential regulatory changes to sustainability issues, including water.
c) Environmental officers are assigned to monitor the targets and ensure responsible management of water resources in
all industrial plants of all Company Business Units.
d) An Environmental Management System certified according to ISO 14001 is implemented, through which any incidents
are managed and dealt with, by drawing up plans to minimize leakage risks and implementing, preventive and
corrective measures.
e) Regarding the management of water discharges, these are fully controlled using monitoring parameters defined by
environmental regulations and terms, according to which the environmental permits (AEPO and Water Use Licenses)
of the Company's Business Units have been obtained.
f) Moreover, measurements are performed continuously to monitor the quality of discharged treated industrial
wastewater in terms of its pH and temperature, while analyses are performed monthly at the outlet of the treatment
plant, which include suspended solids, total dissolved solids, COD, BOD5, pH, sulphides and fluorides. As to the
characteristics of the marine recipient where the discharge takes place, its physico-chemical characteristics are
monitored for compliance with Environmental Quality Standards (EQS).
g) Priority substances are defined and discharge limits are set for these substances in line with the AEPO of each plant. In
particular, no breach of limits or non-compliance incidents were observed in 2024.
Actions, Practices and Initiatives for responsible management of water abstraction and use
The following are key actions/practices/initiatives, which were either completed in 2024 or are implemented annually. They are
associated with the Company's energy centre, which has access to the Corinthian Gulf in the area of Ag. Nikolaos, Prefecture of
Viotia, and specifically with the alumina and aluminium production plant of the Metals Sector, the two thermal power plants and
the combined cycle power plant of the Energy Sector, where key impacts are identified, focusing on water reuse and mitigation
of water and marine resources use where possible. [E3:E3-2_18] [E3:MDR-T_80_a] [E3:E3-2_19]
At the alumina and aluminium production plant [E3:E3-2_17]
a) The abstraction from groundwater is carried out through a controlled borehole network that allows water to be naturally
renewed in a short time through rainfall and snowfall (renewable sources). The well level of the borehole network is
constantly monitored in order to ensure that it is compliant with the limits set by the Water Use License and the current
AEPO. In particular, according to a special study carried out by the Metallurgy BU, in 2021, on the management of
abstraction from the borehole network in relation to the total capacity of the aquifer of the wider area, it was shown
that the average drawdown of the area’s hydrological basin was around 51.36 million m
3
(precipitation, snowfall, etc.).
Based on the Water Use License the Company has the right to abstract 10% of this quantity, while the actual abstraction
87
https://www.metlengroup.com/media/rp3edd3u/politiki_anthrwpinwn_dikaiwmatwn_en.pdf
5. Annual Board of Directors Management Report
156
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
rate is even lower, which ensures the preservation of the level in the aquifer, hence in the boreholes. This is confirmed
by the continuous measurements of the levels in the wells. It is noted that according to the methodology of the World
Resources Institute, Aqueduct
88
, Greece presents a minor trend of change in its groundwater volume potential. [E3:MDR-
A_68_a] [E3:MDR-T_80_c] [E3:MDR-T_80_b] [E3:MDR-T_80_f]
b) It is ensured that the amount of seawater abstracted for cooling needs in the Combined Heat and Power plant remains
below the strict abstraction limits set in the AEPO and Water Use Permits. This is achieved through continuous
monitoring of water abstraction. [E3:MDR-A_68_a]
c) The construction of the project aimed to save 110-120m
3
/h of industrial water and replace it with discharged brackish
cooling water, which was completed last year, is estimated to have yielded total savings of ~800,000 m
3
of industrial
water in 2024. [E3:MDR-A_68_c] [E3:MDR-A_68_e]
d) An employee awareness campaign was implemented, for the 2
nd
consecutive year starting in 2023, featuring an
appropriate message on water conservation, which was shown as a screensaver on the PCs of the alumina and
aluminium plant in the context of World Water Day. [E3:MDR-A_68_a] [E3:MDR-A_68_b] [E3:MDR-A_68_c]
e) An e-mail was sent to all employees of the alumina and aluminium production plant, in order to inform them about the
importance of limiting water consumption to the absolutely necessary needs, especially during the summer months
when water consumption increases due to high temperatures. [E3:MDR-A_68_a] [E3:MDR-A_68_b]
f) Leak checks are carried out continuously at the aluminium plant and neighbouring settlements in cooperation with the
respective technical services to timely identify and property address any incidents. [E3:MDR-A_68_a] [E3:MDR-A_68_b] [E3:MDR-
A_68_c] [E3:MDR-A_68_d]
g) In 2024, the detailed mapping of the plant's industrial water network, which started in 2023, was completed with a view
to installing flow meters to monitor and optimally manage water consumption. [E3:MDR-A_68_a] [E3:MDR-A_68_b]
h) Water recycling and reuse programs are implemented to the maximum extent possible in production processes or
secondary uses of the Metallurgy BU, as well as rainwater collection and utilization practices. [E3:MDR-A_68_a] [E3:MDR-
A_68_b]
In thermal power plants [E3:E3-2_17]
a) The method of discharged seawater reuse is systematically applied to cool the thermal power plant towers, thus avoiding
the additional abstraction of a significant seawater amount estimated at 16 m. m
3
on average annually. [E3:MDR-A_68_a]
b) The environmental impact assessment related to water use in thermal power plant processes identified no high risk.
However, METLEN implements a set of measures for the sustainable management of water resources, ensuring
compliance with legislation and environmental protection. Key actions include: a) compliance with the terms and limits
of water use permits; b) where possible, water recycling practices shall be implemented to minimise waste; c) installation
of modern water management systems to save and use water resources efficiently; d) regular monitoring and reporting
of seawater data to the competent authorities in order to record and monitor data related to seawater cooling; and e)
submission of an annual report on environmental quality with details on water use in thermal power plants. [E3:MDR-
A_68_a] [E3:MDR-A_68_b]
Achieving the above results in the responsible management of the impacts from METLEN's business activity, in relation to water,
requires continuous investment. In 2024, the total operational expenditures (OpEx) were €490,000. [E3:ΜDR-A_69_a] [E3:ΜDR-
A_69_b]
METRICS & TARGETS
E3-3
Targets related to water and marine resources [E3:MDR-T_80_a] [E3:MDR-T_80_h]
In the Energy Sector, optimal water management has already been ensured during the design phase of thermal power plants. All
available technologies and practices were taken into account during the design with the aim of maximum water savings
Therefore, there is no need to set specific measurable targets. [E3:MDR-T_81_b]
Furthermore, water use in the plants is subject to strict limits set by Greek environmental legislation, Water Use Permits and the
AEPOs. These limits determine the exact amount of water allowed to be abstracted and used, ensuring compliance with legislative
requirements. As thermal power plants fully comply with these strict limits, any attempt to further reduce water consumption
would be unfeasible and possibly incompatible with the operational needs of the facilities, thus reducing the need for additional
water abstraction or use reduction targets.
88
https://www.wri.org/aqueduct/tools
5. Annual Board of Directors Management Report
157
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In the Metals Sector, the targets for water resources management are included in the general annual environmental targets, in
accordance with the Environmental Management System, considering the legislative abstraction limits set by the AEPO as
reference, while internal limits are established to improve performance. In addition, reduced industrial or drinking water
consumption results in decreased abstraction from groundwater, thus contributing to the prevention of salinisation of those
waters. [E3:E3-3_23_a] [E3:E3-3_23_c] [E3:E3-3_25]
The specific targets for the alumina and aluminium plant are: [E3:MDR-T_80_b] [E3:MDR-T_80_d] [E3:E3-3_22]
a) total water abstraction from boreholes (industrial & water supply) <13.5 megaliters/day; and
b) total water abstraction from boreholes (industrial use of primary cast aluminium plant) <7 megaliters/day
c) drinking water consumption at the plant <0.35 megaliters / day.
Monitoring the effectiveness of policies and actions
through targets
[E3:MDR-T_80_b] [E3:MDR-T_80_c] [E3:MDR-T_80_d] [E3:MDR-T_80_e]
[E3:MDR-T_80_j]
Total water
abstraction from
boreholes
(industrial & water
supply use)
Total water
abstraction from
boreholes
(industrial use of
primary cast
aluminium plant)
Fresh water
consumption at the
plant
Relation to Policy Targets
Rational and sustainable water withdrawal and use
Measurable target
13.5 megaliters/day
7
megaliters/day
0.35
megaliters/day
Nature of the target
Absolute
Description of the scope of the target
Alumina, Aluminium & Energy Production
Base value
14.5 megaliters/day
7.5 megaliters/day
0.4 megaliters/day
Base year
2023
Period of implementation of the target
Annual Environmental Targets
Indication of milestones or intermediate targets
Daily targets as listed above
Description of methodologies and significant assumptions
used for target-setting
Legislative limit under the AEPO and Water Use License
The objective relating to environmental issues is based on
indisputable scientific data
According to the readings of flow meters / water meters
Stakeholder involvement in target setting
The performance of previous years and possible water savings
from a project to which water users contribute are considered.
Description of any changes in target and corresponding
metrics or underlying measurement methodologies,
significant assumptions, limitations, sources and
procedures adopted to collect data
No changes to the goal
Description of performance in relation to stated target
12.01
megaliters/day
6.24 megaliters/day
0.46 megaliters/day
E3-4
Water consumption
[E3: Ε3-4_28_e]
METLEN is consistently compliant with permits, standards and regulations regarding the quantity, availability and quality of
water. In 2024, there were no reported incidents of non-compliance, confirming the Company's commitment to responsible
management of water resources and compliance with regulatory requirements.
5. Annual Board of Directors Management Report
158
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
At the same time, the Company, for the 9
th
consecutive year, was rated by the international sustainable development
organization CDP in the Water Security category. This process reviews
89
the Company's water management strategy and practices
in its business activity
90
.
Total water footprint
Withdrawal [Ε3:Ε3-4_ΑΕ_32]
In 2024, 174.4 million m³ of water was withdrawn for use, increased by 14.1% compared to 2023. This difference is mainly due to
the individual increased amount of seawater abstraction to meet the needs of METLEN’s energy complex in Agios Nikolaos, Viotia.
Regarding withdrawn quantities from the various sources, all showed a decline compared to 2023, except the amount of water
produced as part of the mining process. In this latter case there was significant increase due to the heavy rainfall in the area during
the year. Regarding the amount of water abstracted from environmentally sensitive areas, this was just 0.01% of the total
abstraction, a significant decrease of 38% compared to the corresponding amount of 2023.
Breakdown table of sources and quantities of water withdrawal in 2024
All areas
91
Environmentally
sensitive areas
1. Seawater (m
3
)
Subtotal
166,594,303.0
2,913.0
Seawater quantities are used for cooling the
Combined Heat and Power (CHP) plant of the Metals
Sector, and then for cooling the IPP1 & IPP2 thermal
power plants. Relevant limits on an annual and daily
Other water
3
166,594,303.0
2,913.0
89
https://www.metlengroup.com/sustainability/esg-performance/esg-ratings/
90
See Introduction of a Sustainability Statement, section "ESG performance and presence in international sustainability indicators"
91
Including environmentally sensitive areas (water stress areas)
5. Annual Board of Directors Management Report
159
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
basis are set and are specified in the applicable AEPO
of the plants. The needs of construction sites are also
included.
2. Groundwater (m
3
)
Subtotal
7,277,470.0
1,788.4
Fresh water
92
4,413,353.0
0
It refers to the amount of industrial, brackish and
drinking water used mainly to meet the industrial,
energy and water supply needs of industrial facilities.
This quantity comes mainly from a network of 17
boreholes, owned by the Metals Sector/Metallurgy
BU, that the Company operates in the wider area of
its factory facilities, as determined by Decision of the
Water Department of the Region of Central Greece.
The needs of construction sites are also included.
Other water
2,864,117.0
1,788.4
3. Surface water (m
3
)
Subtotal
11,317.5
142.0
Fresh water
11,053.0
0
Water abstracted from an adjacent stream by
DELPHI-DISTOMON and collected rainwater. The
needs of construction sites are also included.
Other water
264.5
142.0
4. Produced water (m
3
)
Subtotal
144,000.0
0
Fresh water
144,000.0
0
Water collected during the bauxite extraction process
by METLEN’s subsidiary DELPHI-DISTOMON is
abstracted and then treated before final discharge.
Other water
0
0
5. Third party water (m
3
)
Subtotal
436,689.6
17,363.5
Fresh water
93
137,827.8
0
Water quantities from municipal reserves and public
supply services to meet the needs of METLEN’s
buildings and, primarily, industrial facilities, as well as
seawater returns from an adjacent refinery operated
by another company, used in the desalination process
to produce industrial water in a thermal power plant
of the Energy BU/Sector.
Other water
94
298,861.8
17,363.5
Total water withdrawal (Subtotals 1+2+3+4+5)
174,463,780.1
22,206.9
Fresh water
4,706,233.8
0
Other water
169,757,546.3
22,206.9
Discharge [Ε3:Ε3-4_ΑΕ_32]
The amount of used water returned to the receiving water body after quality treatment and in accordance with the approved
environmental terms per Business Unit, was 164.7 million m
3
, increased by ~14% compared to 2023. Regarding liquid waste
discharges, efforts continued in 2024 to ensure best possible management contributing to protection of the natural environment
and human health. It should be noted that discharged water quality readings are lower and, in several cases, much lower than
those required by law. Overall, the quantities of pollutants from treated liquid waste discharged to the receiving water bodies
was 8.1 t reduced by 48% compared to 2023 (15.5t), and break down as follows: 1.1 t BOD, 5.9 t COD, 1.0 t TSS, 0 t TN, and 0 t TP.
Furthermore, it is noted that for the Aluminium installations of Greece, where it records the largest part of water discharge,
92
Fresh water (water with a concentration of total dissolved solids equal to or less than 1,000 mg/L).
93
Fresh water (water with a concentration of total dissolved solids equal to or less than 1,000 mg/L).
94
Other water (water with a concentration of total dissolved solids greater than 1,000 mg/L).
5. Annual Board of Directors Management Report
160
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
according to the AEPO (Environmental Terms Approval Permit), the qualitative chemical status of the receiving water according
to the marine ecosystem studies carried out in cooperation with ELKETHE, has been classified as good/excellent
95
.
Breakdown table of water discharges per receiving water body in 2024
All areas
96
Environmentally
sensitive areas
1. Marine recipient (m
3
)
Subtotal
164,231,240.0
0
Fresh water
292,261.0
0
The amount of sea and brackish water from the
cooling process of the Combined Heat and Power
plant, as well as the IPP1 & IPP2 thermal power
plants, of the Energy Sector, as well as the amount of
brackish water from boreholes used as a coolant in
the heat exchangers of the aluminium foundry of the
AoG aluminium plant, as well as liquid waste at the
exit of the primary treatment facilities. Also, for
desalination at the “Korinthos Power” power plant,
seawater from the cooling seawater returns of
another adjacent unit (MOH) is used. The brine is
returned and disposed of to the marine recipient
together with the brim of MOH's desalination plants.
Other water
163,938,979.0
0
2. Underground recipient (m
3
)
Subtotal
37,049.5
19,717.0
Fresh water
14,249.0
0
The amount of water used for drilling the subsoil
during bauxite extraction by DELPHI-DISTOMON and
for cleaning the solar panels of photovoltaic parks of
the M Renewables segment of the Energy Sector.
Other water
22,800.5
19,717.0
3. Surface water (m
3
)
Subtotal
207,836.0
0
Fresh water
207,832.0
0
The discharge of water produced by bauxite mining,
wetting dirt roads and watering greenery that has
been planted to restore the natural environment, and
primary treated liquid waste of the secondary cast
aluminium processing plant.
Other water
4.0
0
4. Third party water (m
3
)
Subtotal
248,746.1
1,368.5
Fresh water
37,185.2
0
The amount of liquid municipal waste to public water
supply and sewerage services as well as the amount
of industrial water from power generation discharged
at Motor Oil’s waste treatment plant, after pH and
temperature adjustment.
Other water
211,560.8
1,368.5
Total water discharge (Subtotals 1+2+3+4)
164,724,871.6
21,085.4
Fresh water
97
551,527.2
0
Other water
98
164,173,344.4
21,085.4
The largest amount of water pumped from environmentally sensitive areas, amounting to 19,717.0 m
3
, came from groundwater
due to the lack of connection of the construction site areas to water supply networks. All the quantity pumped was discharged
underground through moistening the soil of the construction sites, installing renewable energy sources to reduce dust, as well as
cleaning the solar panels for the more efficient operation of the facilities.
Consumption [Ε3:3-4_28_a] [E3:Ε3-4_28_b]
95
More information: Section E4-5 Impact measurement indicators related to biodiversity and ecosystems of this Single Report
96
Also including environmentally sensitive areas (water stress areas).
97
Fresh water (water with a concentration of total dissolved solids equal to or less than 1,000 mg/L).
98
Other water (water with a concentration of total dissolved solids greater than 1,000 mg/L).
5. Annual Board of Directors Management Report
161
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
As a result of the above, METLEN's total water consumption marked a 21% increase compared to 2023, which is mainly attributed
to increased evaporation of seawater used for cooling the Company's thermal power plants. This increase, although significant,
concerns only non-drinking water, highlighting the strategic utilization of available water resources without burdening fresh
water sources. In contrast to the increase in total consumption, fresh-water consumption dropped by 11% for the third
consecutive year, while 34% of this quantity was used to supply neighbouring settlements and the Metals Sector’s aluminium
production plant in Viotia for their needs.
Total water consumption
99
(m
3
)
%Ν/Ν-1
2024
2023
2022
Total water abstraction
14.2%
174,463,780.05
152,748,200.00
165,808,000.00
Total water discharge
13.8%
164,724,871.57
144,723,400.00
159,298,100.00
Total energy water consumption
21.4%
9,738,908.48
8,024,800.00
6,509,900.00
Fresh water
-10.6%
4,154,706.59
4,638,000.00
5,309,000.00
Other water
64.9%
5,584,201.89
3,386,800.00
1,200,900.00
In addition, METLEN holds 7,764.5 m³ of stored water
100
, which is not included in the total consumption. Storage capability
demonstrates an additional level of readiness and responsibility. [E3:E3-4_28_d]
Total water consumption from Sources or Areas sensitive in terms of water reserves
(m
3
)
2024
2023
2022
Fresh water
0
0
0
Other water
1,121.5
0
300
Total
1,121.5
0
300
The water consumption reflected in the above table comes exclusively from the activities of the Energy Sector and specifically
from the M Renewables segment and concerns the use of water during the construction process. It is noted that for the
classification of the areas, data resulting from the Company's licensing decisions were used, while in other cases the indicators
of Aqueduct were used (Water Stress
101
, Groundwater Table Decline
102
). The collection of data on water withdrawal, reuse and
discharge is carried out through direct measurements at corresponding pumping and disposal points at more than 99%. In cases
where direct recording is not possible, due to the fact that the pumping activity is carried out by partner organizations with
METLEN, computational estimates and models based on titration data of water transport means (tanks) are applied, mainly in
the construction activities of energy projects and renewable energy projects. Also, the consumption of Central Services offices,
construction sites and production units are based on periodic bills received from the competent providers. [Ε3:Ε3-4_28_e]
Reuse [E3:E3-4_28_c]
The amount of water reused among the plants of METLEN's Sectors, which suggests that the Company uses a significant part of
the water it has already used, reducing the need for abstraction of new quantities from natural resources, was more than 16
million m³ in 2024, a significant increase compared to 2023 due to the longer operation of the new CCGT thermal power plant.
Almost all (99.9%) of this quantity relates to the quantity of waste seawater used in the Metal Sector's CHP plant, which was used
for cooling the two thermal power plants of the Energy Sector. [GRI 3-3-e-iii]
99
Total water consumption = Total withdrawal – Total discharge
100
The publication of the indicator of the amount of stored water is made for the 1st time, so there is no differentiation or corresponding quantities of previous
years.
101
Baseline water pressure measures the ratio of total water demand to available renewable surface water and groundwater reserves. Water demand includes
residential, industrial, irrigation and livestock use. The available renewable water supplies include the impact of upstream water consumers and large dams on
water availability downstream.
102
The groundwater reduction measures the average groundwater table decrease as an average change over the study period (1990-2014). The result is expressed
in centimetres per year (cm/yr).
5. Annual Board of Directors Management Report
162
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Water use intensity indices
The water use intensity indicator recorded an increase compared to the previous year, as a result of the intensification of specific
activities requiring increased water resources, as well as variations in the operation of facilities. Despite the increase, METLEN
maintains its commitment to sustainable management of water resources, continuing its efforts to optimize water consumption
through targeted interventions and practices that utilize the most efficient technologies available in conjunction with the needs
of its projects and the specifications of its mechanical equipment.
[E3:E3-4_29]
Furthermore, as regards the Company's efforts to effectively manage water in the production process, especially in the Metals
Sector, which manages 99.8% of the total amount of water abstracted, specific water consumption per tonne of alumina hydrate
production dropped to 2.23 m³ (2023: 2.9 m³), down by 18.2%. At the same time, specific water consumption per tonne of
primary aluminium production dropped to 0.93 m³ (2023: 1.13 m³), down by 17.7%. In both cases, consumption drops were
achieved thanks to technological upgrades in the production process. [E3:E3-4_29] [E3:E3-4_AR_31]
BIODIVERSITY AND ECOSYSTEMS [ESRS: E4]
STRATEGY
The METLEN Energy and Metals approach to managing ecological impacts from its activity includes a combination of elements
related to the prevention, management and restoration of exploitable land from its activity, minimising impacts on biodiversity.
The protection of biodiversity and the restoration of the natural landscape of exploitable areas associated with business activities
are an essential objective for METLEN, in the context of reducing its ecological impact and contributing to sustainable
development.
Also, METLEN is a member of the Sustainable Development Council of SEV (Hellenic Federation of Enterprises) which participates
in international business for nature alliance for the protection of biodiversity and ecosystems. The SEV Council for Sustainable
Development, as a member of the World Business Council for Sustainable Development WBCSD, after co-signing the Lisbon
Declaration, paved the way for Greek businesses to contribute to addressing the global challenge of environmental balance and
sustainability, but also to highlight the strategies that implement the commitments they have undertaken, as well as the good
practices they implement.
SBM-3
Material impacts, risks, and opportunities and their interaction with the strategy and business model [ESRS2:E4.SBM-3_16_b]
[ESRS2:E4.SBM-3_16_c]
METLEN implements procedures appropriate for the overall consideration of biodiversity-related issues, assessing potential risks,
in terms of their likelihood and time of occurrence. These procedures are aligned with the requirements of national and European
laws and standards. At the same time, in the context of consultations with social partners and the permitting procedures of
installations, the views of stakeholders are taken into account.
Through this approach, the Company ensures the smooth operation of its business model by examining biodiversity parameters
related to the development of new activities. Thus, the potential impacts of the Company's business activities are identified,
103
The denominator in the calculation of water use intensity is consistent with the calculation of net revenues (net sales) as presented in the Company's financial
statements: Chapter 7. Annual Financial Statements of this Single Report
Water reuse
(m
3
)
%N/N-1
2024
2023
2022
Seawater
+46.3%
16,036,576.4
10,960,000
5,634,300
Water Use Intensity Index
103
( m³/mil. € net revenue)
%N/N-1
2024
2023
2022
Activity total
17.2%
1,713
1,461
1,032
5. Annual Board of Directors Management Report
163
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
recorded and presented in the following table. Until the end of 2024, no significant negative impacts have been identified
regarding soil degradation, desertification, or soil sealing, as the Company's mining activities are conducted through underground
operations. Furthermore, the Company's overall activities do not significantly affect protected species
104
.
Until the end of 2024, no significant negative impacts have been identified in terms of soil degradation
105
, as the Company's
mining activities are carried out through underground exploitations, while overall the Company's activities do not affect
significant protected species. Also, until the end of 2024, the Company has not proceeded with an analysis of the resilience of
the Company's business model regarding biodiversity issues. [Ε4:Ε4-1_13a] [Ε4:Ε4-1_13b] [Ε4:Ε4-1_13c] [Ε4:Ε4-1_13d] [Ε4:Ε4-1_13e] [Ε4:Ε4-
1_13f]
POTENTIAL NEGATIVE IMPACT [PN1]:
Degradation of marine ecosystems
This potential impact is directly linked to METLEN's business model based on seawater-intensive industrial processes, both in
the Energy Sector (two thermal power plants) and in the Metals Sector (alumina and primary aluminium production plant and
the cogeneration unit) located in Greece at the Company's energy centre in Ag. Nikolaos, Viotia, which is in direct contact with
a marine area of the NATURA 2000 network (SCI: GR2530007 – CORINTHIAN GULF), a proposed Site of Community Importance
(SCI). [ESRS2:SBM-3_16_a]
Time Horizon:
Short Term
Position in the Value Chain:
Own Operations
CURRENT & POTENTIAL IMPACTS ON BUSINESS
MODEL & VALUE CHAIN [SBM3:48_b]
CURRENT & POTENTIAL IMPACTS ON STRATEGY & DECISION
MAKING[SBM3:48_b]
a) Ongoing compliance with environmental
regulations is a critical factor in maintaining
corporate credibility and reputation, as any
deviations may impact operational continuity
and lead to loss of customers and investors.
b) Effects on the local economy and relationships
with local communities due to environmental
degradation.
a) Review of the company's growth strategy to avoid future
environmental risks and impacts and adopt stricter water quality
monitoring and management policies.
b) Adaptation of business processes to reduce emissions and
discharges.
c) Need for stricter environmental management policies and adoption
of advanced wastewater treatment technologies.
d) Focus on the development and implementation of programs for the
restoration and monitoring of the marine recipient’s quality.
e) Strengthening cooperation with environmental bodies and
scientific institutions to develop sustainable solutions.
FINANCIAL RISK: Material costs associated with sites decommissioning at the end of their useful life
(e.g. decommissioning of facilities, removal or treatment of waste materials, land rehabilitation and site restoration)
Financial Significance:
Very high
Time Horizon:
Current, Short-term, Medium-term, Long-term
Position in the Value Chain:
Own Operations
IMPACT, RISK & OPPORTUNITY MANAGEMENT
E4-2
Policies related to biodiversity and ecosystems
METLEN has and implements a central environmental policy and individual actions that ensure the protection of biodiversity and
ecosystems in the context of its respective activities and supply chain, but is studying the development of a specific policy for
biodiversity and ecosystems in 2025, as the issue was highlighted in the context of the 2024 double materiality assessment. [Ε4:Ε4-
2_22]
104
Further information is available in Annex E4 of the Sustainability Statement of this Integrated Report.
105
Including desertification or soil sealing
5. Annual Board of Directors Management Report
164
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
CENTRAL ENVIRONMENTAL POLICY
Year of update
2024
Key Content
[MDR-P_65_a]
Conducting business activity with a view to protecting biodiversity and ecosystems, by implementing plans
to mitigate ecological impacts and implement programs for the restoration of areas and compensation of
impacts, where necessary, in the areas where it operates.
Targeting
[MDR-P_65_b]
[Ε4:Ε4-2_23_b]
The implementation of the Policy includes the Company's own activities as well as those in which it has
operational control within the upstream and downstream value chain, in all areas of its activity.
Governance
[MDR-P_65_c]
c) Approved by the Company's Sustainability Committee;
d) Designed and revised by the Company's General Division for Corporate Governance and Sustainable
Development in cooperation with the General Divisions of the Company's Business Units, which are also
responsible for its implementation.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
d) ISO 14001:2015 International Standard
e) Global Sustainable Development Goals (6,7,12,13,14,15 & 17)
Inclusion of Stakeholder
Interests [MDR-P_65_e]
Annual Stakeholder Consultation
Availability
[MDR-P_65_f]
Corporate website
106
and intranet
E4-3
Actions and resources related to biodiversity and ecosystems
As part of its environmental policy, METLEN implements a series of fixed and continuous actions that promote the protection of
biodiversity and ecosystems in its areas of activity. [E4:E4-3_27] [ESRS2:MDR-A_68_a] [ESRS2:MDR-A_68_b] [ESRS2:MDR-A_68_c] [ESRS2:MDR-
A_68_d] [ESRS2:MDR-A_68_e] [MDR-A_69_a] [MDR-A_69_b]
METLEN prioritizes the prevention of negative impacts from the early stages of project planning. Specifically, at the Company's
industrial facilities in the Gulf of Antikyra, a study assessing the ecological quality of the marine environment is being conducted
in collaboration with the Hellenic Centre for Marine Research (HCMR). At the same time, a corresponding study is also being
carried out for the terrestrial environment. [ESRS2:MDR-A_69_b]
In 2024, the cost for environmental assessment and biodiversity studies and actions amounted to €92,500, while in the last five
years (2020-2024) it approaches €235,000. The expenditure concerns the ecological assessment of Antikyra Bay, biodiversity
monitoring, mapping of terrestrial fauna and the Special Ecological Assessment (SEA). [ESRS2:MDR-A_69_b]
In 2024, the operating cost for bird protection actions (OpEx) amounted to €115,650 and the corresponding investment cost for
the installation of an automated bird collision prevention system (CapEx) amounted to €113,600. In total, in the last three years
(2022-2024), the cost of avifauna studies exceeded € 260,000.
Finally, for impacts that cannot be avoided or minimized, METLEN implements extensive restoration actions. In the mining areas
managed by the companies DELPHI-DISTOMON and European Bauxite, the Company proceeds with the installation of fences, the
maintenance and replacement of water networks, as well as tree plantings, where for 2024, the planting of more than 30
thousand was completed. plants in an area of 140 acres, while an additional 12 mm were replanted. plants, ensuring the
restoration of natural ecosystems.
At the same time, in the Company's nurseries in 2024, more than 38 thousand were produced. plants from local seeds, while an
additional 69 thousand were preserved. plants, enhancing local biodiversity and adapting reforestation to the natural conditions
of the area. In 2024, the operating cost (OpEx) of these actions amounted to €202,225, while in total over the last three years
(2022-2024) it reached €540,000.
106
https://www.metlengroup.com/media/l0rkoqbr/environmental-policy.pdf
5. Annual Board of Directors Management Report
165
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In Metals Sector and in particular in the mining activity, the Company applies a series of specific practices. In particular, the
existing road network is used exclusively and the opening of new roads is prohibited, while existing accessory-based works and
outdoor facilities are utilized without the need for additional interventions.
In addition, the surface deposit or management of the produced sterile limestone materials of the mines is prohibited, while
systematic wetting is applied in bulk storage areas to suppress dust. Solid waste is managed in accordance with applicable
legislation and is disposed of through specialized, licensed bodies.
Finally, it is worth mentioning that, on average, the mining activity produces 303,500 tons of sterile limestone per year, which
are deposited on already existing underground mining sites and old surface explorations (as part of the rehabilitation), so that
not a single additional square meter of surface is required.
In Energy Sector, where there are wind farms of the Company, the movement of animals is not hindered, because there is no
fencing and the nuisance to birds has been studied and is negligible, while where necessary technical systems for the protection
of birds are installed.
Regarding the restoration of the environment in the context of new wind farms, the Company applies the obligation to reforest
areas equal to the intervention area and, where possible, the restoration of illegal or inactive quarries, following a relevant
permit from the competent forest services, in accordance with the applicable legislation and the instructions of the respective
forestry authorities.
Furthermore, during 2024, there were no incidents related to impacts on the biodiversity in the areas affected from the Metals
Sector's activities, and the planned restoration actions of exploitable areas were implemented as scheduled.
METRICS & TARGETS
E4-4
Targets related to biodiversity and ecosystems
As the degradation of marine ecosystems is a recognized potential impact of the Company's business activity, which, however,
takes appropriate measures to continuously monitor its performance in order to constantly ensure its operation within limits and
licensing frameworks, it has not set specific quantified and time-bound targets. [MDR-T_81_b_i] [E4: E4-4_31] [E4: E4-4_32] However, the
Company, after the completion of the studies mentioned in the actions section, will evaluate the relevant results and data, as
well as whether it is necessary to set and monitor relevant targets.
At the same time, METLEN sets specific targets regarding the rate of restoration of the total exploitable land from mining activity,
ensuring their achievement, in order to responsibly manage biodiversity and ecosystem issues. The objectives for the
rehabilitation of paid surface exploitations of mining activity are a requirement of the institutional framework, while there is no
need to periodically update them, as the Company now uses exclusively underground exploitations.
Target description
Scope
Mitigation hierarchy
level
Target 2025
Rate of restoration of total exploitable land
from mining activity
Mining activity (DELPHI-DISTOMON
Company)
Restoration
90.5%
Table: 02/Ε4
The above-mentioned target will be reviewed in total within 2025, following the consolidation of METLEN'S subsidiaries, DELPHI-
DISTOMON and European Bauxites into a single company. In wind farms located in Natura protected areas, the Company
conducts bird studies prior to the implementation of projects, in order to ensure that development plans will not burden sensitive
species endemic to the area. In addition, in wind farms outside Natura areas, it installs automated bird collision prevention
systems, minimizing risks to birds moving in the area.
E4-5 Impact metrics related to biodiversity and ecosystems
5. Annual Board of Directors Management Report
166
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In the context of monitoring and assessing the ecological quality in the Antikyra Bay, the Company, in collaboration with the
HCMR, conducts regular audits based on a commonly accepted scientific methodology related to biodiversity and the marine
ecosystem. Measurements address key elements and parameters of the marine environment, including changes in biodiversity,
water quality, and the ecological status of the soft and hard bottom. The conclusions drawn from these studies provide essential
information on the state of the marine ecosystem, allowing timely protection measures to be taken, if required. More specifically,
the following table presents the focus parameters of the studies:
Title of Study
Object of Study
1) Physical Oceanography
2) Dissolved Oxygen and Nutrients
3) Phytoplankton
4) Zooplankton
5) Particulate Matter Study: Particulate Organic Carbon and Particulate Nitrogen at the exit of the Biological
Treatment of Aspra Spitia - Antikyra
6) Study of soft bottom zoobenthos
Monitoring of
environmental
conditions of Antikyra
Bay, with emphasis on
the establishment of
thermophilic species
7) Study of hard bottom Benthos and coastal Megabenthos
Study Result
107
Eco-quality rating: Good / Excellent
[E4:Ε4-5_38]
Table: 01/Ε4
107
Special Technical-Geological – Hydrogeological study, for the analysis of all endogenous and exogenous risks (risk assessment, impact assessment) using GIS
models.
5. Annual Board of Directors Management Report
167
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In particular, the following table presents additional information focusing on the restoration of terrestrial ecosystems as a result
of mining activities, as well as the activities of building and operating power plants and renewable energy projects within the
same activities, on which regulatory restoration obligations arise.
Restoration progress of exploitable areas
Total
(ha)
Metals Sector: Mining activity: DELPHI-DISTOMON
Total surface used (reserved) for operations
11
Total area of exploitable land where restoration was completed within the reporting year (2024)
5.5
Surface area in the process of restoration
8.5
Area that has been restored since the start of the mining activity, over the total exploitable area
164.4
% of area that has been restored since the start of the mining activity, over the total exploitable
area
89.4%
Energy Sector: Construction of photovoltaic parks in 2024 (Greece)
Total surface used (reserved) for operations
129.3
Total area of exploitable land where restoration was completed within the reporting year (2024)
3.2
Surface area in the process of restoration
126.1
% Area that has been restored since the start of the activity, over the total exploitable area
2.5%
Energy Sector: Construction/operation of wind parks
108
Total surface used (reserved) for operations
106.8
Total area of exploitable land where restoration was completed within the reporting year (2024)
0
Total area of exploitable land where restoration was completed within the previous reporting
years
98.9
Surface area in the process of restoration
7.9
% Area that has been restored since the start of the activity, over the total exploitable area
92.6%
Energy Sector: Construction/operation of accompanying interconnection works for thermal power plants
Total surface used (reserved) for operations
17.0
Total area of exploitable land where restoration was completed within the reporting year (2024)
0
Total area of exploitable land where restoration was completed within the previous reporting
years
2.03
Surface area in the process of restoration
14.9
% Area that has been restored since the start of the activity, over the total exploitable area
1.77%
Table: 03/Ε4
In connection with the above table, it should be noted that the reforestation of 98.9 hectares, completed in 2022-2023, to offset
the construction of wind farms (Makrynoros, Petalas, Pounta, Diakoftis, Turtle, Pyrgos, Microvouni), included 37 forest
engineering projects with an equivalent reforestation area of 37.1 hectares, as well as 3.25 hectares for which the stipulated
price was paid to the Green Fund of the Ministry of Environment and Energy.
Moreover, in 2025, more forest engineering projects are planned (forest clearing, forest roads construction or maintenance and
fire safety projects) with a total equivalent reforestation area of 148.9 hectares, including an area of 8.9 hectares in Agios
Nikolaos, Viotia, where reforestation was completed, but, since the area was affected by forest fires, new reforestation
operations are required.
108
The activity of wind farms is implemented exclusively in Greece.
5. Annual Board of Directors Management Report
168
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
At the same time, in 2024, the Company fulfilled the obligation to restore an area of 3.2 hectares by paying the stipulated price,
in relation to the photovoltaic park construction projects in Martino, Regional Unit of Sterea Ellada; the restoration of 126.1
hectares in Makrirachi Domokos, Regional Unit of Sterea Ellada is pending. Note that in the development of photovoltaic parks,
the reforestation areas are equal to the intervention areas. Regarding the operation of wind farms, in 2024 there were no new
activities leading to additional reforestation obligations.
Details of the facilities of METLEN's business activities located in or adjacent to Natura areas or Special Protection Areas or other
biodiversity sensitive areas, with information on whether these activities adversely affect these areas leading to the degradation
of biodiversity and ecosystems, along with a mapping of the measures taken, the actions adopted and the resulting outcomes,
are presented in the Annex to the Sustainability Statement.
RESOURCE USE AND CIRCULAR ECONOMY [ESRS: E5]
Resource management and the integration of circular economy principles are key pillars of METLEN Energy & Metals's sustainable
development strategy. The Company, aiming at the rational use of natural resources and minimizing its environmental footprint,
emphasizes the production of recycled aluminium, which is at the heart of circular economy. At the same time, METLEN
participates in research projects for the extraction of rare-earth elements from bauxite residues, further strengthening its
resource efficiency initiatives. In addition, the Company's waste management is based on best practices, promoting material
recycling and reuse, with the ultimate goal of gradually transitioning to a circular production model that contributes to sustainable
development.
SBM-3
Material impacts, risks, and opportunities and their interaction with the strategy and business model
ACTUAL POSITIVE IMPACT [AP2]:
Use of scrap aluminium scrap as raw material
The use of scrap aluminium as raw material in the production of secondary cast aluminium is directly linked to METLEN's
business strategy in the Metals Sector, secondary cast aluminium being a key product of the Company, but also to its overall
strategy for Sustainable Development and in particular in "Supporting Innovation and sustainable Industrialization".
Time Horizon:
Actual
Position in the Value Chain:
Own Operations, Downstream
FINANCIAL OPPORTUNITY [E5-O1]: Further gradual increase in revenue from penetration into new markets focusing on the
demand for recycled aluminum
Financial Significance:
High
Time Horizon:
Short, Medium & Long Term
Position in the Value Chain:
Own Operations, Downstream
FINANCIAL OPPORTUNITY [E5-O2]: Reduction in energy costs and increase in production efficiency per ton of aluminum
Financial Significance:
Very High
Time Horizon:
Short, Medium & Long Term
Position in the Value Chain:
Own Operations, Downstream
FINANCIAL OPPORTUNITY [E5-O3]: Enhancement of liquidity with access to investment financing in the Circular Economy
(Green Bond)
Financial Significance:
High
Time Horizon:
Short, Medium & Long Term
Position in the Value Chain:
Own Operations, Downstream
CURRENT & POTENTIAL IMPACTS ON BUSINESS MODEL &
VALUE CHAIN [SBM3:48_b]
CURRENT & POTENTIAL IMPACTS ON STRATEGY &
DECISION MAKING [SBM3:48_b]
a) Improving competitiveness by incorporating the use of
scrap aluminium as a cost-effective solution, given that
recycled aluminium is cheaper to process and requires less
energy. This practice reduces operating costs and
increases production efficiency while promoting
sustainability.
a) Strengthening the circular economy as a stable strategic
investment, ensuring long-term sustainability and
efficiency.
b) Strategic focus on circular economy, strengthening the
Company's commitment to sustainable development and
reducing its dependence on new raw materials.
5. Annual Board of Directors Management Report
169
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
b) Creating opportunities to sell products in markets that
place emphasis on sustainable and recycled
products/materials.
c) Enhancing compliance with international standards and
regulations to reduce carbon emissions and promote
sustainability.
Overall, the increase in the use of scrap aluminium and consequently in the production of recycled aluminium offers METLEN
commercial and financial opportunities, contributing directly to the strengthening of the overall financial results of the Metals
Division presented in the Company's financial report.
POTENTIAL POSITIVE IMPACT [PP2]:
Utilization of bauxite residues
This impact is directly linked to METLEN's business strategy in the Metals Sector, as bauxite residues are one of the Company's
main non-hazardous wastes. At the same time, it is aligned with its overall strategy for Sustainable Development by
strengthening "Supporting Innovation and sustainable Industrialization".
Time Horizon:
Medium Term
Position in the Value Chain:
Downstream
CURRENT AND POTENTIAL IMPACTS ON THE BUSINESS
MODEL & VALUE CHAIN
[SBM3:48_b]
CURRENT AND POTENTIAL IMPACTS ON STRATEGY &
DECISION-MAKING
[SBM3:48_b]
a) Increasing the available bauxite waste disposal site that
the Company needs.
b) The potential recovery of rare-earth elements and their
addition to the Company's product portfolio will expand its
activities into new markets,
c) Further enhancement of the Company's sustainable
development profile.
a) The utilization of bauxite residues enhances the circular
economy model and may lead to strategic decisions to
penetrate new markets.
In addition, material costs associated with sites decommissioning at the end of their useful life (e.g. decommissioning of facilities,
removal or treatment of waste materials, land rehabilitation and site restoration) may have a negative financial impact on the
business. For further information, refer to the Annual Financial Statements section, Note 3.20.
IMPACT, RISK & OPPORTUNITY MANAGEMENT
E5-1
Policies related to resource use and circular economy [MDR-P_65]
The main axis of METLEN's Central Environmental Policy is the application of Best Available Techniques in the production process
as regards the control, continuous reduction and proper management of solid and liquid waste applying recovery, reuse and
recycling techniques, where feasible.
CENTRAL ENVIRONMENTAL POLICY [E5:E5-1_14]
Year of update
2024
Key Content
[MDR-P_65_a]
In the context of sustainable natural capital management, METLEN actively promotes innovation, research
and development of new technologies, including those that enhance the circular economy, and their
gradual implementation in the Company's production units. This is done by reducing solid waste through
recovery, reuse and recycling techniques and, where feasible, by sourcing and using recyclable and
reusable materials.
Targeting
[MDR-P_65_b]
[E5:E5-1_15_a]
[E5:E5-1_15_b]
The implementation of the Policy includes the Company's own activities as well as those in which it has
operational control within the upstream and downstream value chain, in all areas of its activity.
Governance
[MDR-P_65_c]
e) Approved by the Company's Sustainability Committee.
5. Annual Board of Directors Management Report
170
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
f) Designed and revised by the Company's Corporate Governance and Sustainable Development General
Division in cooperation with the General Divisions of the Company's Business Sectors, which are also
responsible for its implementation.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
a) ISO 14001:2015 International Standard
b) Global Sustainable Development Goals (6,7,12,13,14,15 & 17)
c) Performance Standard ASI
Inclusion of
Stakeholder interests
[MDR-P_65_e]
Annual Stakeholder Consultation
Availability
[MDR-P_65_f]
Corporate website
109
and intranet
E5-2
Actions and resources related to resource use and circular economy
[MDR-A_68_a] [MDR-A_68_b] [MDR-A_68_c] [MDR-A_68_d] [MDR-A_68_e]
METLEN's industrial activity is particularly demanding on resources that mainly come from non-renewable sources. The sound
management of the Company's natural capital is a key element of its business model, ensuring the long-term sustainability of its
activities and the production of sustainable products and services as described in the Business Model section of this report. [E5:E5-
2_20_a]. In addition to product production, the Company's outputs involving the use of natural resources, raw materials and other
materials also include waste (air emissions as well). METLEN records, monitors and publishes over time the waste generated by
its activities, classifying them according to how they are managed. The Company's Metallurgy Sector accounts for 99% of its total
waste, however, METLEN is committed to the proper management of all its solid and liquid waste. The actions depicted below
are continuous and have been incorporated into the operating model as standard practices. [E5:E5-2_20_a]
Wastewater Management:
A wastewater collection network has been designed and operates in every METLEN production plant, for treatment and recycling
(where possible), in full compliance with the Company's Environmental Policy. The management of wastewater discharges
resulting from METLEN's activities is fully controlled and carried out in accordance with the regulations and environmental terms
stipulated in the environmental licenses of its industrial units (AEPO). [E5:E5-2_20_f]
Solid Waste Management:
METLEN operates a solid waste sorting system at the source, including waste falling under alternative management systems, for
reuse and recycling by third parties. The Company also collaborates with certified operators of alternative management systems,
approved by the National Recycling Organization, as well as with licensed waste collection, transport and recovery companies
both in Greece and abroad. [E5:E5-2_20_f] [E5:E5-2_AR_11]
In the Metals Sector, the Company:
a) has incorporated in its production process the recasting of scrap aluminium, which replaces the use of raw materials, in its
effort to reduce the consumption of natural resources, but also to reduce the energy required per ton of aluminium
production; [E5:E5-2_20_b]
b) launched its pilot copper-zinc recovery unit from industrial residues and secondary materials at the end of 2024, in the
context of promoting circular economy. This unit is oriented towards the production of these metals from secondary sources
and not from the processing of primary ores. The activity will be able to receive 12,000 t/year of materials for processing
from various sources, and its daily capacity in terms of incoming raw material for processing will be 48.00 t/day; [E5:E5-2_20 b]
c) also invests in the installation of pilot units to support the research for utilization of bauxite residues, participating in
European programs of efficient green technologies in the production of useful products and materials, as well as in the
development of technology for the extraction of rare-earth elements (see below Research & Development); [E5:E5-2_20_a]
[E5:E5-2_20_b]
d) research application of a Wastewater treatment plant resulting from red sludge dewatering presses and not recycled in the
production process, for treatment before disposal to the final recipient. Meanwhile, within the alumina production process
itself, a large percentage of wastewater is recycled. Wastewater from all facilities that is not recycled in the production
process is led through an underground system of wastewater collection pipelines to an industrial wastewater treatment
plant, which consists of settling tanks, oil separator and multilayer activated carbon filters. There is constant measurement
109
https://www.metlengroup.com/media/l0rkoqbr/environmental-policy.pdf
5. Annual Board of Directors Management Report
171
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
and online monitoring of pH, temperature and flow, and there is also a 1,330 m
3
safety tank, where waste is automatically
diverted, if necessary; [E5:E5-2_20_f]
e) maintains and uses specially designed and licensed sanitary landfills (for hazardous materials and for inert waste), and
bauxite residues (non-hazardous waste that constitutes almost 68% of the Company's total waste) are disposed of applying
a special method, based on geotechnical studies, following the area’s natural relief; [E5:E5-2_20_e] [E5:E5-2_20_f]
f) deposits materials (limestone / chemically inert material) resulting from bauxite mining, in underground locations in the
voids created by mining. This process is done in such a way that the quality of the storage area is not affected, neither in the
short nor long term; [E5:E5-2_20_f]
g) implements actions to further improve waste sorting at the source, with the aim of separating possible non-hazardous
streams, which at the moment is not possible due to existing production and collection processes. [E5:E5-2_20_d]
h) Furthermore, the Company operates three urban wastewater biological treatment plants covering the needs of the
aluminium production plant and local settlements. Specifically, these are 1) the biological treatment plant at Aspra Spitia &
Antikyra with a capacity of 10,000 inhabitants, 2) the biological treatment plant at Ag. Nikolaos with a capacity of 200
inhabitants to cover the needs of the Ag. Nikolaos village, and 3) the biological treatment plant of the production plant with
a capacity of 2,000 people, meeting the needs of the population at the production plant and power stations. The biological
treatment plant at Aspra Spitia & Antikyra is the first biological treatment plant for urban wastewater in Greece and was
constructed simultaneously with the settlement, by Degremont-France. According to the Environmental Conditions Approval
Decision (AEPO), monthly analyses are carried out on the effluent treated wastewater by a quality control laboratory
accredited according to ELOT EN ISO – 17025. During the summer period (May – September), bathing water sampling is
carried out at 8 points of Antikyra Bay, as well as an annual evaluation by an independent body. These points include the
outlet to the sea of the treated water pipeline of the Aspra Spitia & Antikyra biological treatment plant. The results for this
point have shown that they meet the maximum levels laid down by legislation for coastal waters of excellent quality and
good quality. [E5:E5-1_20_f] [E5:E5-2_AR_12]
Research and Development is a necessity of the times and a conscious business choice for METLEN's Metals Sector. The Company
strategically invests in research and development to contribute, proportionally to its share of responsibility, to the strengthening
of scientific research, the upgrading the of technological capabilities of the country's industrial sector, to encouraging innovation
by ensuring industrial diversification and added value to its products and services. In this context, the Company continues to
consistently install pilot units and develop know-how in the areas of: [E5:E5-2_AR_12_c]
1. Utilization of bauxite residues, participating and conducting pilot tests in the framework of European programs for
efficient environmentally friendly technologies in the production of useful products and materials (iron, alumina, cement
additives and construction products).
2. Development of technologies for the production of high added value products from alumina production such as gallium,
scandium and ultrapure alumina.
3. Digitization of processes in the production of alumina and aluminium.
4. Education and lifelong learning, through programs aimed at shaping new tools and training courses for engineers and
craftsmen working in the Metals Sector.
In the Energy Sector and in subsidiary METKA SA, there is no primary natural resources management, but management of semi-
finished or finished products according to project-specific plans and procedures that specify exactly the use of each material, the
manufacturing method and its exact location and operation. Furthermore, the use of recyclable materials is one criterion applied
during the project design phase. [E5:E5-2_20_d] In requests for tenders and contracts with suppliers of materials and equipment
there is a specific condition for their compliance with the requirements of ISO 14001 (where applicable) and specifically for proper
waste management.
Financial Resources related to Action Plans
METLEN accurately calculates the cost of waste management arising from its production activity, ensuring its effective
management. With this approach, the Company makes timely and informed decisions, which are incorporated into the financial
forecasting, budgeting and costing processes. In 2024, operational expenditures (OpΕx)
110
amounted to €8,291,033.14, while
capital expenditures (CapΕx)
111
amounted to €586,680.75. [MDR-Α_69_b]
Research and Development
110
See Financial Statements: Income Statement in the Section 3.5 of the present Integrated Report.
111
See Financial Statements: Cash Flow Statement in the Section 3.5. of the present Integrated Report.
5. Annual Board of Directors Management Report
172
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Metals Sector has established the Research and Sustainable Development (RSD) activity under the Metallurgy Technology
Division of the Company's Metals Sector. In 2024, it participated in approximately 14 research projects, co-funded by the EU or
the Greek state, through Horizon 2020, EIT Raw Materials, EIT Manufacturing, ERA-NET Cofund on Raw Materials (ERA-MIN 2)
and programs of the General Secretariat for Research and Technology (GSRT). METLEN's participation in these programs is
focused on increasing competitiveness but also exploring the application of industrial circular economy. [E5:E5-2_AR_12_b]
The total funding of METLEN's Metals Sector from research programs, during the period 2017-2027, exceeds €11 million. Also,
the Company, through the RSD activity, is placed among the leading companies in the aluminium sector worldwide in the field of
research for the utilization of bauxite residues, the recovery of rare-earth elements, gallium and electrification technologies.
[MDR-A:69_b]
Also in 2024, the operation of the two pilot units, 'HYDRO' and 'PYRO', continued to test new metallurgical processes. Meanwhile,
extensions were implemented to the pilot units with new equipment amounting to 470,000 euros. In summary, in 2024, the RSD
activity announced the following key results in selected research projects:
a) Scale UP project: This is about the extraction of scandium from bauxite residues and continuous optimization of the
process. The 3
rd
scandium production campaign in 2024 aims to improve process control and consequently reduce
production costs, having as final deliverable the basic study of a new scandium production unit at the Agios Nikolaos plant.
[E5:E5-2_20_f]
b) Sisal pilot project: In the context of alumina production from alternative (secondary) sources, the EBA pilot units
processed new types of slags from the silicon industry to produce metallurgical alumina, while new equipment was also
designed to implement new production processes of 99.99% ultrapure alumina that requires high added value material.
Within the framework of the program, following the installation and commissioning of special equipment, there were
successful tests for the production of hydrated alumina hydrochloride which is a precursor to the production of ultrapure
alumina. The first pilot results highlight the quality of alumina that can be achieved by processing alternative alumina
sources.
c) Valore project: The project was launched in early 2022 and pertains to the treatment of liquid solutions for production of
Vanadium and Gallium from alumina production. Within the project’s framework, pilot tests of gallium production from
alumina production liquid solutions are performed. The pilot tests concern the investigation of at least 5 technologies to
search for the most economical method of gallium extraction. The pilot tests have already produced the first gallium
concentrates as well as metal gallium. [E5:E5-2_20_f]
d) Reactive project: The project explores ways to convert bauxite residues into cement additive in collaboration with the
Cement Industry. The RSD pilot units have been implementing bauxite residue calcination tests and their conversion to
SCM since 2022, and also bauxite residue melting tests for the production of cast iron and granulated slag. [E5:E5-2_20_f]
e) At the same time, by actively implementing actions to reduce CO
2
emission, METLEN is participating in the addition of a
new pilot hydrogen burner to the foundry through the HyinHeat research program, where in collaboration with Linde they
will run aluminium melting tests in an industrial environment.
Regarding actions for the electrification of production processes, two new programs were selected in the RSD department, the
first is called Elithe and concerns calcination and production of metallurgical alumina with a new type of microwave calcination
oven, and the second is called Metawave and concerns the calcination of anode blocks using a hybrid microwave and inductive
currents system. These two new projects aim to explore electrification technologies for key aluminium production processes. The
above technologies aim to enhance the Metals Sector’s know-how in the production of new products, explore technical solutions
to sustainability problems, as well as the possible future activation of METLEN in new markets if and when they are deemed
profitable.
Total R&D investments (CapEx)
112
by the Metals and Energy Sectors in 2024, amounted to almost €2.1 million. In total, the Metals
Sector’s R&D department employs (in 2024) 10 employees. [MDR-A_69_a] [MDR-A_69_b]
METRICS & TARGETS
E5-3
Targets related to resource use and circular economy
[MDR-T_80_f] [MDR-T_80_h] [MDR-T_80_j]
112
See Financial Statements: Cash Flow Statement in the Section 3.5. of the present Integrated Report.
5. Annual Board of Directors Management Report
173
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The increase of secondary aluminium production is a main objective of METLEN that is directly related to its own activities and
the upstream value chain. At the same time, the establishment of the targets reflected in the following table, serve the
sustainable management of natural capital, through the circular economy, which is a basic principle of the Company's
environmental policy. [MDR-T_80_a] [E5:E5-3_27]
The methodology and assumptions for setting the targets mainly concern investment decisions and METLEN's business
development model. The secondary cast aluminium production target indirectly requires ensuring appropriate quantities of
scrap, while this investment enhances METLEN's attractiveness for green investment products, which was confirmed through
the coverage of the Company's 2nd green bond issued at the end of 2024. [MDR-T_80_f]
A target has been set in accordance with the principles and framework of the environmental system adopted by the Company.
The consultation of social partners takes place indirectly in the context of investor information, which includes specific groups,
such as holders of green bonds issued by the company. Investment in recycled aluminium is part of these financial instruments,
while direct green financing is also being evaluated. [MDR-T_80_h]
Targets
Time to
achieve
Target
focus
Waste
hierarchy
level
Product life cycle stage
Production of 100,000 tons of
recycled aluminium
2030
Circular
Economy
Recycling
End of Life – Recycling
[E5:Q5-3_24] [MDR-T_80_b]
Table: 01/Ε5
During the first year of acquisition of this unit, production was set at 35,579 tonnes. Achieving the 2030 target of producing
100,000 tonnes of recycled aluminium requires recycling between 90,000 and 105,000 tonnes of scrap. In this context, the Metals
Sector sets annual targets, with the intermediate target for 2025 amounting to the production of 55,000 tons of recycled
aluminium, through the utilization of more than 50,000 tons of scrap aluminium. The amount of secondary aluminum produced
was for 2024, was 55,875 tons. [MDR-T_80_e] [MDR-T:80_AR_24] [MDR-T:80_AR_25] [MDR-T:80_AR_26]
With these targets, the Company operates on the third step of the waste hierarchy, recycling, which is considered one of the
most environmentally responsible practices, while contributing to circular economy.
Also, the above targets adopted by the Company on a voluntarily basis: [E5:Ε5-3_24] [E5:Ε5-3_27]
a) relate to the use of materials that have already been used, thus promoting the circular design of finished aluminium
products; [E5:E5-3_24_a]
b) increase the rate of circular use of materials, since aluminium can be continuously recycled without losing its properties,
thus minimizing waste; [E5:E5-3_24_b]
c) contribute to sustainable resource management by reducing dependence on primary raw materials, such as bauxite,
while requiring only 5% of the energy needed for the production of primary aluminium, offering significant energy
savings; [E5:E5-3_24_c]
d) are associated with the effective management of by-products (scrap aluminium) from primary aluminium production
(post-production), preparing the materials for recycling and reuse. Aluminium is 100% recyclable and can be endlessly
recycled, hence it is fully in line with the principles of circular economy, where materials remain in the production
process for as long as possible, thus reducing environmental impact and improving resource efficiency. [E5:Ε5-3_24_d]
E5-4
Resource inflows
The main raw materials used by METLEN's Metals Sector are bauxite and scrap aluminium. Bauxite is the Company's main input
for the production of alumina and is classified as a critical strategic raw material, due to its decisive role in the aluminium supply
chain. Moreover, bauxite is used in the production of refractories, cement and abrasives. Alumina, which is an intermediate
product produced from bauxite, is essential in the electrolysis process that leads to pure aluminium production. Although not
officially classified as a critical strategic raw material, alumina plays a key role in industrial production, mainly because of its close
association with bauxite and the importance of aluminium in strategic areas. Scrap aluminium is used as a key raw material in
5. Annual Board of Directors Management Report
174
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
secondary cast aluminium production, supporting the circular economy and reducing dependence on the extraction of new raw
materials. Scrap aluminium comes either from used products (post-consumer scrap) or production waste (post-production scrap).
Reusing it significantly reduces the production’s energy footprint and improves the sustainability of METLEN's activities.
In the Energy Sector, and specifically in energy production, METLEN uses natural gas as the main raw material. The Company
leverages natural gas in its power plants, supporting the path to a lower-emission economy and the development of
sustainability-oriented energy infrastructure. In renewable energy projects construction and in (transition or conventional)
energy projects construction of the Energy Sector, there is no primary natural resources management, but management of semi-
finished or finished products according to project-specific plans and procedures that specify exactly the use of each material, the
manufacturing method and its exact location and operation. Moreover, water is a key input for both the Metals and Energy
Sectors. In the Metals Sector, water is mainly used in the alumina production process and in the cooling systems during aluminium
casting. In the Energy Sector, it is mainly used in power plants for cooling and support functions. METLEN applies responsible
water management policies as detailed in section E3 of this Sustainability Statement. [Ε5:Ε5-4_ 30]
METLEN's fixed assets play a key role in the Company's production and energy activities. In the Metals Sector, the main production
facilities include bauxite mining units, alumina production, production and aluminium casting, equipped with modern energy
efficiency systems. In the Energy Sector, fixed assets include power plants, renewable energy systems and specialized energy
transmission and distribution equipment. The Company's strategic investment in technologically advanced assets, as well as its
commitment to repair and maintenance procedures, contributes to a reduced environmental footprint and improved supply
chain sustainability. A more detailed description of how the fixed assets are managed by METLEN can be found in section 2.8
Fixed Assets of this Report.
In 2024, production of recycled (secondary cast) aluminium from scrap stood at 55,875.04t, a slight change from the previous
year (2023: 56,365t). This is the result of leveraging technological capabilities to drive a reduction in the use of raw materials.
METLEN invests in know-how for optimal scrap aluminium treatment, expanding its activities in the industrial production,
treatment and trading of metals, and especially aluminium alloys and their products, that, in the coming years, will enable it to
once again produce raw materials, consuming much smaller quantities of energy, thus significantly reducing costs and the impact
on the environment.
Overall, in 2024, the Metals Sector used approximately 2.1 million tons of raw materials in the production of alumina, primary
and secondary cast aluminium products, an increase of 8.1% compared to the previous year (2023: 1,947,977.6t). Of the total
input quantity, 2,048,654.86 tons was bauxite, corresponding to 74.8%, and the remaining 26.2% was other raw materials, such
as soda, lime, secondary raw materials, packaging materials, etc. Moreover, in 2024, utilization of recycled materials in absolute
terms increased by 3.7% from 55,302t in 2023 to 57,338.2t in 2024.
5. Annual Board of Directors Management Report
175
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
[E5:5-4_31_a]
Table: 02/Ε5
The quantities of materials with organic load used are very small in relation to the total amount of inputs, so their percentage is
well below 1% and therefore the information is considered non-essential, so it is not reported. [E5: E5-4_31_b]
The calculation of the above quantities was mainly based on direct measurements. Almost all the data came from the weighing
method, which was used extensively to record the weight of materials. In cases of smaller quantities, where direct measurements
could not be used, data came from estimates. These estimates were based on historical data and analyses of previous
113
The fuels used for the Company's production activities are not included in the calculations of the input table data, as they are thoroughly detailed in Chapter
E1 of this Sustainability Statement. Similarly, water is not included, which as an input is thoroughly analyzed within Chapter E3. Also, for subsidiaries of the
construction industry, it is considered that all materials for the construction of the project refer to / fall under the owner of each project.
114
secondary intermediates and secondary materials
115
secondary intermediates and secondary materials
116
Of the 1,498.22 t of the total weight of the materials used that are part of the end product, approx, 1,343.6 t were Steel materials (in the form of sheet metal,
section steel or other project materials). Roughly 40% of EU steel production comes from electric arc furnaces which allow steel to be made from 100% recycled
scrap metal feedstock (Source: eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2013:0407:FIN:EN:PDF, Strasbourg, 11.6.2013, COM(2013) 407 final, p.11
). Therefore, 537.4 t (40% of 1,343.6 t of steel materials) corresponds to recycled Steel. [E5:Ε5-4_32]
Weight of inputs used in the production of the Company's key products
113
[E5:5-4_31_a]
(t)
2024
2023
2022
Main materials
Production of Alumina, Primary & Secondary cast Aluminium (total)
Raw materials
2,105,993.1
1,947,977.0
1,948,048.6
Bauxite, Scrap Aluminium
Intermediate products
342,039.7
342,914.7
345,877.1
Alumina, prealloys, primary aluminium
Other Raw Materials and Materials
114
(not incorporated in the end product)
288,167.0
267,337.3
248,995.7
Coke, Tar, Anodes, Lime, Caustic Soda
Packaging materials
1,602.0
1,436.1
1,629.2
Pine beams, packaging strapping
Total (t)
2,737,801.7
2,559,665.1
2,544,550.6
% of intermediate products
[Ε5:5-4_31_c]
12.5%
13.4%
13.6%
Recycled materials
57,338.2
55,302.0
54,527.0
Scrap aluminium
% recycled materials
[Ε5:5-4_31_c]
2.1%
2.16%
2.14%
Secondary Cast Aluminium Production
Raw materials
46,588.3
44,381.0
40,027.6
Scrap aluminium
Intermediate products
4,675.4
5,851.0
5,174.1
Prealloys, primary aluminium
Materials
115
(not incorporated in the end
product)
92.9
47.4
106.2
Flux, exhaust gas treatment materials,
kaolin, lubricants
Packaging materials
434.8
326.2
267.8
Wooden beams, strapping, cardboard
Total (t)
51,791.4
50,605.6
45,575.7
% of intermediate products
[Ε5:5-4_31_c]
9.0%
11.6%
11.4%
% recycled materials
[Ε5:5-4_31_c]
89.95%
87.70%
87.83%
Complex Construction Works and Steel Machining
Materials (used in the production process
but not incorporated in the end product)
232.7
218.0
310.4
Oxygen, Argon, Nitrogen, etc.
Semi-finished products
1,498.22
1,357.5
1,164.9
Steel, Welding Materials, Solvents, etc.
Packaging materials
32.2
4.7
13.0
Nylon
Total (t)
1,763.13
1,580.2
1,488.3
Recycled materials
218.0
473.8
393.4
Recycled steel
% recycled materials
[Ε5:5-4_31_c]
12.4%
116
30.0%
26.4%
5. Annual Board of Directors Management Report
176
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
measurements. The Company's approach and measurement methodology ensure the accuracy and reliability of the data,
preventing duplicates or discontinuities in the presented data. [E5:E5-4_32] [E5-4_AR_25]
In the Energy Sector, and specifically the M Energy Generation & Management segment, natural gas is used as raw in power
plants, which is the transition fuel to a lower greenhouse gas emissions economy. The total amount of natural gas used in the
Energy Sector increased by almost 68%.
E5-5
Resource outflows
Products [E5:E5-5_36_c]
117
METLEN, through its Metals Sector, is the largest independent producer of primary and secondary cast aluminium in Greece,
adapting its production to high quality standards according to the principles of circular economy, promoting resilience, reuse and
recycling, as well as the needs of international customers and Greek businesses.
Aluminium, whether primary or secondary cast, is known for its high durability and long-term use, making it ideal for multiple
applications, and can be recycled indefinitely without losing its quality or properties. Finished aluminium products can be easily
reused, minimising the need for new raw materials and supporting waste reduction.
Also, the ability to remanufacture and refurbish finished aluminium products, especially in industrial applications, allows to
optimize their use and reduce the environmental footprint.
At the same time, secondary cast aluminium, produced by the treatment of scrap aluminium, is a typical example of circular
economy, as the recycling process allows the production of new products with significantly lower energy consumption and
environmental footprint. Scrap aluminium from used products or industrial waste, is fully reused to create new high-quality
products. It is noted that aluminum, regardless of the form it takes during further processing, retains its basic properties, such as
its high strength, long service life and the possibility of unlimited recycling without loss of quality
118
.
In the form produced by the Company, aluminium is not intended for direct use by the final consumer but is an intermediate
product that undergoes further processing through rolling and extrusion processes by respective industries. Therefore, its
durability is mainly evaluated in terms of its possibility of perpetual use through recycling, while there is no question of
repairability, as aluminium in the form of columns and plates produced by METLEN, is a material for further processing for the
manufacture of finished products. [Ε5:Ε5-5_35] [Ε5:Ε5-5_36_a] [Ε5:Ε5-5_36_b]
In the form produced by the Company, aluminium is not intended for direct use by the final consumer but is an intermediate
product that undergoes further processing through rolling and extrusion processes by respective industries. Therefore, its
durability is mainly evaluated in terms of its possibility of perpetual use through recycling, while there is no question of
repairability, as aluminium in the form of columns and plates produced by METLEN, is a material for further processing for the
manufacture of finished products. [Ε5:Ε5-5_35] [Ε5:Ε5-5_36_a] [Ε5:Ε5-5_36_b]
Types of finished products designed according to circular
principles
Recyclable content percentage
Primary aluminium
100%
Secondary cast aluminium
100%
Table: 03/Ε5
Waste [E5:E5-5_37_a]
117
[E5:E5-5_AR 26] Information on all products from METLEN's production process which are then marketed can be found in section 2.2: Strategic Priorities &
Business Model of this single report.
118
Aluminium is infinitely recyclable. «Aluminium is infinitely recyclable» International Aluminium Institute (IAI), https://international-
aluminium.org/landing/aluminium-is-infinitely-recyclable/ (retrieved at 13/02/2025 @ 13.00)
5. Annual Board of Directors Management Report
177
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The total amount of the Company's solid waste for 2024 was 1.07 million tonnes (2023: 1.02 million tons), increased by 4.7%, as
shown in the following table.
Table: 04/Ε5
Non-hazardous waste [E5: E5-5_ 37_b] [E5:E5-5_37_c]
The bulk of the waste generated results from the production process and processing of raw materials (e.g. bauxite residues,
sterile decalcification), maintenance operations (e.g. electrolysis basin waste) and aluminium casting (e.g. foundry foaming). The
management of this waste includes sorting at source, procedures for collection, transport, recovery/disposal of all waste streams
depending on the nature of each waste and the requirements of the applicable legislation.
Approximately 75% of the total amount of waste in 2024, as in 2023, concerned bauxite residues and sterile decalcification, while
the remaining 25% includes industrial and municipal waste as well as materials collected and include, among others, used metals
(e.g. iron and steel), tires, used lubricants, electrical and electronic equipment, paper, plastic, wood, glass, lamps and
consumables from photocopiers.
Total non-hazardous solid waste generated increased by 4.99% (2023:1,000,342.6), due to an increase in bauxite residues. In
particular, total non-hazardous solid waste recovered in 2024 corresponds to 22.27% of total non-hazardous waste, i.e. both
those recovered and those disposed of. Compared to 2023, total non-hazardous solid waste recovered decreased by 10.95%
(2023: 311,359.8) mainly due to the significant reduction of excavation, construction and demolition waste.
Specifically, as regards the recovery procedures:
a) Specifically, from the total non-hazardous solid waste recycled or recovered in various ways either by the Company itself
or through third parties, 108,059.35 tons corresponding to bauxite residues and bauxite muck of the Metals Sector were
provided to the cement industry and for other industrial uses, increased by 27.14% (2023: 85,000 tons)
b) The quantity of landfilled solid waste, as a percentage of total non-hazardous solid waste generated (excluding bauxite
residues subject to special treatment), dropped in (2024: 6.899,4) and was formed into 2.3%.
Non-Hazardous Waste (t) - Recovery Operations
2024
Recycling/ Utilization
233,900.0
Preparing for reuse
41,772.9
Other recovery operations
1,575.8
Sub-Total (1)
277,248.8
Non-Hazardous Waste (t) - Disposal Operations
Landfill (Bauxite residue site)
742,225.3
Landfill
6,899.4
Incineration
0.1
Other disposal operations
23,907.3
Sub-Total (2)
773,032.1
Total (1 +2)
1,050,280.8
119
METLEN does not produce radioactive waste as it does not result from any of its activities [Ε5:E5-5_39]
Quantities of waste generated
(t)
%N/N-1
2024
2023
2022
Non-Hazardous
5.0%
1,050,280.8
1,000,342.6
1,118,544.8
Hazardous
119
- 8.0%
20,903.1
22,709.6
21,157.0
Total waste quantities (t)
4.7%
1,071,183.9
1,023,052.0
1,139,702.0
5. Annual Board of Directors Management Report
178
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Table: 05/Ε5
Hazardous waste [E5:Ε5-5_37_b] [E5:Ε5-5_37_c] [E5:Ε5-5_39]
Regarding hazardous waste, its quantity was reduced by 7.9%, (2023: 22,709.6), a fact mainly attributed to the reduction in the
amount of generated waste that is recycled and/or utilized by third parties by 25.49% (2023: 7,952.6), including but not limited
to lubricating oils (WLO), dust collected from exhaust gas treatment, foundry slag, etc. from the activities of the Metals Sector,
each category showing decline. Radioactive waste is not included in hazardous waste, as the Company does not produce
radioactive waste.
Hazardous Waste (t) - Recovery Operations
2024
Recycling/ Utilization
5,130.2
Preparing for reuse
49.7
Other recovery operations
72.4
Sub-Total (1)
5,252.3
Hazardous Waste (t) - Disposal Operations
Hazardous Waste Landfill
15,471.3
Incineration
1.5
Other disposal operations
177.9
Sub-Total (2)
15,650.7
Total (1 +2)
20,903.1
Table: 06/Ε5
The analysis of the data presented in tables 05/E5 & 06/E5 above shows that 77.7% of the Company's total waste remains outside
recycling/recovery processes (832,153.7t). [E5:Ε5-5_37_d]
Waste streams and materials contained in waste [E5:Ε5-5_38_a] [E5:Ε5-5_38_b]
The main waste streams mainly concern the Metals Sector and are reflected below:
A) Waste from bauxite mining include bauxite dust, soil residues such as soil and rocks, and non-recoverable ores or other useful
components.
B) The alumina production process using the Bayer method generates mostly bauxite residues containing iron oxides, silicon,
calcium and other trace elements. This waste stream includes all the elements contained in bauxite that are not used/retrieved
in the alumina production process.
C) During dismantling of the electrolysis basins where aluminium production takes place, cathode block waste (SPL) and refractory
waste (bricks, cements, etc.) is generated. Packaging waste includes plastics and cardboard used for the packaging of raw
materials and finished products. The main waste of the production of recycled aluminium, which is ash, ends up entirely in the
cement industry as an alternative raw material.
D) Packaging waste includes plastics and cardboard used to package raw materials.
E) The main waste of the production of recycled aluminium, which is ash, ends entirely in the cement industry as an alternative
raw material.
Data calculation methodologies [Ε5:Ε5-5_40]
The company applies immediate weighing and titration methodologies to accurately calculate data related to waste management
and circular economy. For weighing, high-precision weighing systems are used to directly measure the weight of waste and
materials produced, ensuring reliable data for measuring the quantities of materials collected, recycled or reused. At the same
time, titration is applied to estimate the volume of materials, especially in cases where weighing is not practical. Methods such
as geometric dimensioning or the use of standard reference vessels allow the quantity of materials to be determined accurately.
The assumptions underlying these methodologies include parameters such as density, homogeneity of materials, and their
physical properties. The data are mainly based on direct measurements, and, where this is not possible, documented estimates
are made, using historical data and standard density or weight values.
5. Annual Board of Directors Management Report
179
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The EU Taxonomy is the European Union classification system of activities that can under certain conditions be considered as
environmentally sustainable or as activities that enable the transition to environmental sustainability. Under the Taxonomy
regulation, companies and organizations can attract funds to develop their sustainable activities as well as expand them further,
provided they meet certain criteria.
The criteria that determine the level of sustainability of certain economic activities are set by the Taxonomy Regulation
(2020/852/EU). In order to achieve sustainability of its economic development, the European Union has stipulated 6
environmental objectives, the achievement of which will advance sustainable development within the Union. Specifically, the
environmental objectives at the center of the Taxonomy framework are the following:
1. Climate change mitigation;
2. Climate change adaptation;
3. The sustainable use and protection of water and marine resources;
4. The transition to a circular economy;
5. Pollution prevention and control;
6. The protection and restoration of biodiversity and ecosystems.
The delegated acts adopted under the Taxonomy Regulation provide technical screening criteria which must also be met to
constitute taxonomy alignment. At the moment of publication of the present, report the Taxonomy-eligible activities have been
set out by 2 Delegated Acts currently in force. In 2021, the EU adopted the first Delegated Act 2021/2139 (EU) which set out
activities and technical screening criteria for substantial contribution towards objectives 1-2 above, including DNSH criteria for
other objectives. Moreover, in 2023, the second Delegated Act 2023/2486 (EU) was published with regard to activities
significantly contributing to environmental objectives 3-6 above.
The achievement of one or several of the above-mentioned objectives provides an economic activity with the status of
sustainable, transitional or enabling according to their alignment to the Taxonomy framework. Specifically, depending on
whether the activity has the potential to be conducted in a fully sustainable way at present, whether it can help the economy
transition to a more sustainable model or whether it can allow other activities to be conducted sustainably, the economic
activities have been designates into different subgroups. In order to be considered aligned to the EU Taxonomy, an economic
activity must fulfil all of the following criteria:
I. Contributes substantially to one or more of the environmental objectives set out in the Regulation
II. Does not significantly harm any of the environmental objectives set out in the Regulation
III. Is carried out in compliance with the minimum safeguards laid down in the Regulation
IV. Complies with technical screening criteria stipulated by the Commission for each economic activity towards the
achievement of the environmental goals of the Taxonomy.
The Taxonomy framework provisions that are effective on the date of the present report, require from in-scope companies to
disclose the amount and proportion of activities which are eligible, non-eligible and aligned with the all the above objectives as
part of their total turnover, capital and operational expenditure and to perform related alignment assessments for all such
activities. All the quantitative information is accompanied by certain qualitative information for all objectives (1-6). The Group
applied Regulation (EU) 2020/852 as supplemented with Commission Delegated Regulation (EU) 2021/2139, Commission
Delegated Regulation (EU) 2021/2178, Commission Delegated Regulation (EU) 2023/2485 and Commission Delegated Regulation
(EU) 2023/2486 to identify activities that are eligible.
The compliance with said criteria is monitored continuously and reported on an annual basis, included in the non-financial section
of the respective annual financial statements. As part of the Taxonomy reporting process, we disclose in the following section
the key performance indicators relating to our economic activities for the FY2024.
METLEN activities
The Group examined thoroughly its activities through the prism of EU Taxonomy in order to identify the proportion of its eligible
and aligned activities according to the Taxonomy framework. This procedure forms the basis of its disclosures for Taxonomy
purposes in the annual financial statements and was also carried out in the current period, where the following eligible activities
were recognized:
CCM 3.8. Manufacture of aluminium
CCM 3.20. Manufacture, installation, and servicing of high, medium and low voltage electrical equipment for electrical
transmission and distribution that result in or enable a substantial contribution to climate change mitigation
CCM 4.1. Electricity generation using solar photovoltaic technology
EUROPEAN TAXONOMY FOR SUSTAINABLE INVESTMENTS
XII.
5. Annual Board of Directors Management Report
180
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
CCM 4.3. Electricity generation from wind power
CCM 4.5. Electricity generation from hydropower
CCM 4.10. Storage of electricity
CCM 4.29. Electricity generation from fossil gaseous fuels
CCM 6.14. Infrastructure for rail transport
CCM 7.3. Installation, maintenance and repair of energy efficiency equipment
CE 3.1. Construction of new buildings
Following the eligibility examination based on the descriptions provided by the Climate Delegated Acts mentioned earlier, the
Group evaluated their alignment with EU Taxonomy according to the relevant technical screening criteria (regarding activities
already present in the 2021/2139/EU and 2023/2486/EU Delegated Acts). The result of this evaluation is presented in the
following section of the report.
Declaration of activities related to nuclear energy and fossil gaseous fuels
Row
Nuclear energy related activities
1.
The undertaking carries out, funds or has exposures to research, development, demonstration and
deployment of innovative electricity generation facilities that produce energy from nuclear
processes with minimal waste from the fuel cycle.
NO
2.
The undertaking carries out, funds or has exposures to construction and safe operation of new
nuclear installations to produce electricity or process heat, including for the purposes of district
heating or industrial processes such as hydrogen production, as well as their safety upgrades, using
best available technologies.
NO
3.
The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations
that produce electricity or process heat, including for the purposes of district heating or industrial
processes such as hydrogen production from nuclear energy, as well as their safety upgrades.
NO
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation of electricity
generation facilities that produce electricity using fossil gaseous fuels.
YES
5.
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation
of combined heat/cool and power generation facilities using fossil gaseous fuels.
NO
6.
The undertaking carries out, funds or has exposures to construction, refurbishment and operation
of heat generation facilities that produce heat/cool using fossil gaseous fuels.
NO
Group economic activities in the framework of EU Taxonomy
CCM 3.8. Manufacture of aluminium
Taxonomy activity description:
This activity consists of the manufacture of aluminium through primary alumina (bauxite) process or secondary aluminium
recycling.
Eligible METLEN activity description:
The Group operates the only vertically integrated alumina and aluminium production and marketing unit in the EU as well as a
secondary aluminium production unit. The production process includes the manufacture of primary aluminium through the
processing of alumina (aluminium oxide) by electrolytic method and the recycling of secondary aluminium. The Group’s
production capacity reaches 250,000 tonnes of aluminium (primary and secondary cast). Its industrial complex in Ag. Nikolaos,
Boeotia, which operates for over 50 years, has achieved continuous growth by the adoption of production and commercial
practices comparable to those of the leading metallurgical industries worldwide, and by over €600 million of investments in the
technological modernization of the plant’s facilities and the increase of its production and productivity – one of the largest private
investments to be carried out in Greece in recent years.
Alignment to EU Taxonomy Criteria re Climate Change Mitigation
The Group examined alignment of the activity to the criteria as presented in the Climate Delegated Act (2021/2139/EU) and
confirmed the alignment of all secondary aluminium plants to said measures. Specifically, the Group has identified climate-related
5. Annual Board of Directors Management Report
181
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
risks associated with its assets situated in EU countries. This assessment allows the Group to effectively address and manage
potential risks impacting its operations, ensuring resilience and sustainability in the face of climate challenges.
Regarding emissions (other than GHG emissions) during the production processes, the economic activity within its continuous
regulatory compliance, constantly monitors emissions’ levels, confirming that they do not exceed the levels associated with the
best available techniques (BAT-AEL) ranges for the non-ferrous metals industries. The said production processes regularly comply
to the Directives outlined in Appendix C of the Climate Delegated Act regarding the use/manufacture of dangerous chemicals.
Concerning the Environmental Impact Assessment (EIA), since its preparation is a basic requirement of the environmental
licensing process of most large-scale construction projects, METLEN produces EIAs for all of its facilities including the aluminium
productions sites. The EIAs include sections relating to the use and protection of water and marine resources as well as for
maintaining their good condition. Moreover, the Μetals Sector supported by external specialists has conducted a
Technogeological-Hydrogeological survey where all identified risks to the subterranean waters of the surrounding area are
described and thoroughly analysed to ensure the flawless operation of the sites and the protection of the local environment.
Lastly, as certain sites of the economic activity border areas included in the Natura 2000 network of protected areas, the Group
has undertaken a Special Ecological Assessment (SEA) as part of the licensing process of the aforementioned sites.
CCM 3.20. Manufacture, installation, and servicing of high, medium and low voltage electrical equipment for electrical
transmission and distribution that result in or enable a substantial contribution to climate change mitigation
Taxonomy activity description:
The economic activity develops, manufactures, installs, maintains or services electrical products, equipment or systems, or
software aimed at substantial GHG emission reductions in high, medium and low voltage electrical transmission and distribution
systems through electrification, energy efficiency, integration of renewable energy or efficient power conversion.
The economic activity includes systems to integrate renewable sources of energy in the electric grid, interconnect or increase
grid automation, flexibility and stability, manage demand-side response, develop low carbon transport or heat, or deploy smart
metering technologies for substantial improvement of energy efficiency. The economic activity in this category does not include
heat and power generating equipment and electrical appliances. The economic activities in this category could be associated with
several NACE codes, in particular C26.51, C27.1, C27.3, C27.9, C33.13, C33.14 and C33.2 in accordance with the statistical
classification of economic activities established by Regulation (EC) No 1893/2006. An economic activity in this category is an
enabling activity as referred to in Article 10(1), point (i), of Regulation (EU) 2020/852 where it complies with the relevant technical
screening criteria.
Eligible METLEN activity description:
The Group has undertaken the "Pembroke" project on behalf of RWE Generation UK PLC in the United Kingdom, which concerns
the supply and installation of a Modern Condenser. The M Power Projects Division of METLEN will undertake the execution of
this "turnkey" project which includes the Design, Supply, Installation and Commissioning of a Modern Condenser unit, with the
auxiliary systems, as well as a high voltage substation (HV) for the connection of the Modern Condenser to the HT Network of
the National Grid (Transmission System Operator). This has been the first Modern Condenser project for METLEN, but also the
first for RWE in the UK as part of the Pembroke Net Zero Center (PNZC) decarbonisation target. The project will be built on the
existing premises of RWE's Pembroke power station in Southwest Wales. Construction began in 2023, and completion is
scheduled for the second half of 2025.
Modern Condensers are widely considered essential for the development of renewable energy (RES) projects. They are able to
regulate the power in electrical networks, especially when RES cannot provide stability to the system. As market needs grow,
Modern Condensers are a reliable technical solution, able to meet the needs of network managers, while being preferred
internationally by many companies. Additionally, a Modern Condenser does not consume fuel, nor does it produce energy, and
therefore there are no additional CO2 emissions or water usage requirements. At the same time, this project forms part of the
National Grid's Stability Pathfinder Program for England and Wales, aiming to support the system by increasing inertia and
contributing to the short circuit level. As interconnected renewables grow, the project helps stabilize the Grid. Finally, it is worth
noting that the 'Pembroke' project supports the UK's 'green' energy and zero carbon targets by 2025.
In 2024, METLEN in collaboration with GE Vernova’s Grid Solutions, commenced work on the Eastern Green Link 1 (EGL1), a key
infrastructure project supporting the decarbonization of the UK energy grid. This £2.5 billion subsea high-voltage direct current
(HVDC) interconnection, developed by SP Energy Networks and National Grid Electricity Transmission, will facilitate the
transmission of renewable energy between Torness (Scotland) and Hawthorn Pit (England), contributing to grid stability and
energy security. METLEN’s role includes the design and supply of two HVDC converter stations, which will optimize the transfer
of clean energy to meet the power needs of approximately two million households, reinforcing the transition towards a
sustainable and resilient energy system.
5. Annual Board of Directors Management Report
182
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
CCM 4.1. Electricity generation using solar photovoltaic technology
Taxonomy activity description:
This activity consists of the construction or operation of electricity generation facilities that produce electricity using solar
photovoltaic (PV) technology.
Eligible METLEN activity description:
The Group, through its subsidiary METKA EGN, is one of the leading manufacturers of photovoltaic and energy storage projects
worldwide, in EU as well as non-EU countries (Australia and Chile). This positions the Group as global manufacturer and contractor
for solar energy projects, offering reliable solutions across the entire range of the activities involved in developing such projects,
from autonomous solar parks and energy storage projects to complex hybrid projects. The broader strategy of the Renewables
& Storage Development Business Unit apart from the construction of external projects includes the use of the Build-Own-Transfer
(“BOT”) business model for the development of photovoltaic projects, utilizing its extensive proprietary construction technology.
During 2024, METLEN’s global RES portfolio continued its steady expansion, reaching a total capacity of 11.1 GW, reflecting a 0.6
GW increase compared to the previous year. This includes 4.9GW of operational and mature-stage development projects with
an additional 6.2 GW in early development stages. The Group’s power production from renewable sources totaled 1.6 TWh for
2024, coming from both Greek and international projects, namely in the UK, Italy, Ireland, Australia, Chile, and South Korea.
Additionally, METLEN signed a Cooperation Framework Agreement with PPC for the development of a 2 GW solar project
portfolio across Italy, Bulgaria, Croatia, and Romania, valued at €2 billion, with a three-year implementation horizon. In Greece,
the Group advanced construction on 0.4 GW of PV projects, leveraging resources from the Recovery and Resilience Facility (RRF).
Regarding the portfolio from third parties, METLEN continues the construction work of projects of more than 1.1GW
internationally.
Alignment to EU Taxonomy Criteria re Climate Change Mitigation
The said activity covers two separate parts of METLEN activities: the RSD B.U. involving the construction of solar PV parks for
clients and the P&G B.U. responsible for the operation of the Group’s own solar PV facilities.
For all EU countries, the Group has identified climate-related risks associated with its aligned assets. This assessment allows the
Group to effectively address and manage potential risks impacting its operations, ensuring resilience and sustainability in the
face of climate challenges.
Regarding alignment to the criterion for transition to a circular economy, most of the materials and related equipment used for
the construction, operation and maintenance of the solar PV facilities with modern techniques, are characterized for their high
durability and can be disassembled and recycled almost completely.
The materials required for the construction of the solar PV facilities consist mainly of metal devices, photovoltaic panels,
aluminum and copper cables, electrical equipment and concrete, most of which are recyclable, as well as packaging materials
(e.g. wood, plastic and paper-cardboard) which are waste produced during construction. All the above-mentioned materials are
recyclable and are properly recycled through licensed waste management companies so as not to cause negative effects on the
environment.
Concerning the Environmental Impact Assessment (EIA), since its preparation is a basic requirement of the environmental
licensing process of most large-scale construction projects, EIAs are produced for facilities including solar PV facilities. The EIAs
include sections relating to the use and protection of biodiversity, water and marine resources as well as for maintaining their
good condition. The same regulatory framework is applicable for construction activities within the EEA. For construction projects
outside the EEA (Australia, Chile), the Group follows the same approach and environmental commitments set by its
Environmental Policy as well as the applicable environmental legislation in the host countries. Moreover, in case of sites of the
economic activity which are situated or border areas included in the Natura 2000 network of protected areas, all necessary
assessments required by the applicable national and EU legislation for such projects are undertaken.
In assessing whether photovoltaic parks (“PV parks”) located outside the European Union are compliant with the relevant EU
Taxonomy standards and requirements in the event where a detailed alignment assessment for each asset has not yet been
obtained, management has exercised significant judgment. Specifically, management has assessed that, while these assets are
located outside the jurisdiction of the EU and not subject to the EU's regulations for environmental protection, these parks do
substiantially meet the criteria established under the Taxonomy framework and more specifically the Substantial Contribution
criteria and Do No Significant Harm (DNSH) criteria as set out in the Delegated Regulation (EU) 2021/2139.
Specifically, regarding the DNSH criteria for activity “CCM 4.1. Electricity generation using solar photovoltaic technology”,
management has performed an analysis that covered operational practices, environmental impact assessments, compliance with
Metlen’s environmental policy, environmental permits, alignment with national frameworks, and ISO certifications along with
5. Annual Board of Directors Management Report
183
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
other best practices in renewable energy management applicable to these facilities and concluded that the relevant DNSH criteria
are met. Management’s assessment has involved a high degree of subjective judgment and remains committed to ongoing
monitoring and review of its activities to ensure continued compliance and alignment with evolving regulatory requirements and
taking taking the appropriate and necessary actions to achieve this objective.
CCM 4.3. Electricity generation from wind power
Taxonomy activity description:
Construction or operation of electricity generation facilities that produce electricity from wind power.
Eligible METLEN activity description:
The Group owns and operates wind farms of combined capacity up to 194 MW in Serres, Euboea, Fokida, Boeotia, Attica and
Aitoloakarnania. Moreover, METLEN has announced its cooperation with Copenhagen Infrastructure Partners towards the joint
development and construction of offshore wind farms, which however is not yet feasible due to lack of proper legislative
framework. Finally, in 2024 the Group advanced the construction of 13 MW of wind projects in Greece via leveraging resources
from the Recovery and Resilience Facility (RRF).
Alignment to EU Taxonomy Criteria re Climate Change Mitigation
The Group examined alignment of the activity to the criteria as presented in the Climate Delegated Act (2021/2139/EU) for the
alignment of it’s wind farms to said measures.
Specifically, the Group has identified climate-related risks associated with its assets situated in EU countries. This assessment
allows the Group to effectively address and manage potential risks impacting its operations, ensuring resilience and sustainability
in the face of climate challenges.
Regarding alignment to the criterion for transition to a circular economy, most of the materials and related equipment used for
the construction, operation and maintenance of wind farms with modern techniques, are characterized for their high durability
and can be disassembled and recycled almost completely.
Concerning the Environmental Impact Assessment (EIA), since its preparation is a basic requirement of the environmental
licensing process of most large-scale construction projects, EIAs are produced for all facilities including wind farms. Lastly, in case
of sites of the economic activity which are situated or border areas included in the Natura 2000 network of protected areas, all
necessary assessments required by the applicable national and EU legislation for such projects are undertaken.
CCM 4.5. Electricity generation from hydropower
Taxonomy activity description:
Construction or operation of electricity generation facilities that produce electricity from hydropower.
Eligible METLEN activity description:
The Group owns and operates four small hydropower plants in Aitoloakarnania and Fthiotida of a combined capacity up to 6 MW.
CCM 4.10. Storage of electricity
Taxonomy activity description:
Construction and operation of facilities that store electricity and return it at a later time in the form of electricity. The activity
includes pumped hydropower storage.
Eligible METLEN activity description:
In 2024, METLEN made significant advancements in energy storage, reinforcing its role in grid stability and the energy transition
as part of the Group’s strategic plan. In Greece, the Group progressed with the construction of 48 MW of energy storage projects
(BESS), utilizing resources from the Recovery and Resilience Facility (RRF). In Italy, METLEN expanded its portfolio with multiple
strategic investments, including two 25 MW, 3-hour BESS projects in the Apulia region, awarded 15-year capacity market
contracts, as well as a 25 MW, 2-hour BESS in Brindisi and an 8 MW, 1-hour BESS in Cheremule, Sardinia, which became
operational in early 2024. Internationally, METLEN’s total operational energy storage capacity reached approximately 0.7 GWh
across Greece, Italy, the UK, Puerto Rico, Tunisia, and Nigeria. Additionally, the Group is finalizing contracts for third-party energy
storage projects totalling 2.2 GWh, further strengthening its presence in the sector. In 2021, the Group was awarded a total sum
of 26 MW for battery energy storage systems (BESS) to provide Fast Reserve grid services for Terna, the Italian Transmission
System Operator. The commissioning of the projects took place during Q4 of 2022, when both systems started providing Fast
5. Annual Board of Directors Management Report
184
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Reserve services to the Italian grid that will span from 2023 until 2027.
Alignment to EU Taxonomy Criteria re Climate Change Mitigation
The Group examined alignment of the activity to the criteria as presented in the Climate Delegated Act (2021/2139/EU) and
confirmed the alignment of all wind farms to said measures.
Specifically, the Group has identified climate-related risks associated with its assets situated in EU countries. This assessment
allows the Group to effectively address and manage potential risks impacting its operations, ensuring resilience and sustainability
in the face of climate challenges.
The Group has implemented a waste management plan that prioritizes maximizing the reuse and recycling of materials during
the construction of storage units.
Concerning the Environmental Impact Assessment (EIA), since its preparation is a basic requirement of the environmental
licensing process of most large-scale construction projects, EIAs are produced for all construction activities within the EEA. The
EIAs include sections relating to the use and protection of biodiversity, water and marine resources as well as for maintaining
their good condition. Moreover, in case of sites of the economic activity which are situated or border biodiversity-sensitive areas
(e.g., Natura 2000 network of protected areas), all necessary assessments required by the applicable national and EU legislation
for such projects are undertaken.
CCM 4.29. Electricity generation from fossil gaseous fuels
Taxonomy activity description:
Construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels. This activity does
not include electricity generation from the exclusive use of renewable non-fossil gaseous and liquid fuels and biogas and bio-
liquid fuels.
Eligible METLEN activity description:
The Group, through Protergia, brings together under the same roof the management of all METLEN energy-related fixed assets
and activities. The Company today ranks as one of the leading private sector actors in the electric power market and is the largest
independent electric power producer and supplier in Greece. The portfolio of energy assets totaling more than 1,200 MWh of
installed capacity, accounts for over 18.5% of the licensed thermal plant production capacity in place in the country.
Furthermore, the Group through the SES BU has individually undertaken the “Engineering, Procurement & Construction” (EPC)
of three open circle (OCGT) power production stations in the UK, one of which is project “Immingham”. This project concerns the
development and construction of an open-cycle gas turbine (OCGT) and gas-fired power plant in Immingham, North Lincolnshire,
UK, for VPI Immingham-B LLP (VPI-B), of the Vitol Group. The contract concerns the design, supply and construction (EPC) of a
299MW OCGT unit. The main equipment as well as the core of the gas turbine package comprising a Siemens Energy SGT5-4000F
gas turbine and an SGen5-1200A generator, including electrical components and an instrumentation and control system will be
provided by Siemens Energy. The installed equipment can also be used to stabilize the grid during periods when the power station
itself is not producing electricity - an important factor in ensuring security of supply in the UK.The project will be located adjacent
to the existing VPI Immingham CHP station and VPI-B has already secured a capacity contract in the 2022 T-4 UK capacity purchase
auction for this OCGT. The energy produced will be transferred to the High Voltage Transmission Network managed by National
Grid.
Additionally, in 2024, METLEN in consortium with Siemens Energy, secured an EPC contract to develop a 560 MW Combined
Cycle Gas Turbine (CCGT) power plant in Turek, Poland. Awarded by ZE PAK’s subsidiary, PAK CCGT Sp zo.o., the project aims to
enhance Poland's energy security by providing efficient and reliable power generation. The plant will incorporate advanced gas
and steam turbines, utilizing natural gas as a transitional fuel to support the country’s energy transition. This marks METLEN’s
second CCGT project in Poland, further strengthening its role in delivering sustainable and flexible energy solutions in the region.
METLEN's first Combined Cycle Gas Turbine (CCGT) project in Poland is the 560 MW Grudziądz power plant, initiated in 2022 in
partnership with Siemens Energy.
CCM 6.14. Infrastructure for rail transport
Taxonomy activity description:
5. Annual Board of Directors Management Report
185
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Construction, modernisation, operation and maintenance of railways and subways as well as bridges and tunnels, stations,
terminals, rail service facilities, safety and traffic management systems including the provision of architectural services,
engineering services, drafting services, building inspection services and surveying and mapping services and the like as well as
the performance of physical, chemical and other analytical testing of all types of materials and products..
Eligible METLEN activity description:
The Group in 2024 continued the 2 Railway Projects in the area of Peloponnese namely the electrification of the part Kiato-
Rododafni as well as the expansion of the railway infrastructure, electrification and construction of stops and stations in the part
Rododafni-Rio. Additionally, through the METKA subsidiary, it has also continued the upgrading of the existing RR of the Suburban
Railway in Western Attica, section: Ano Liosia - Neos S.S. Megaron – P.S. Megaron. Finally, through the Joint Venture "METLEN
S.A. - XANTHAKIS ATE" has undertaken the upgrade and regularization of the existing single railway line Isthmus - Loutraki with
electrification.
CCM 7.3. Installation, maintenance and repair of energy efficiency equipment
Taxonomy activity description:
Individual renovation measures consisting in installation, maintenance or repair of energy efficiency equipment. An economic
activity in this category is an enabling activity as referred to in Article 10(1), point (i), of Regulation (EU) 2020/852 where it
complies with the relevant technical screening criteria.
Eligible METLEN activity description:
In the context of this activity, the Group has undertaken energy upgrading projects at the facilities of the Olympic Sports Center
of Athens (OAKA) which, among other things, include the replacement of lamps/lighting in various parts of the facilities,
interventions in the hot water production and air conditioning facilities, replacement pumps, etc.
CE 3.1. Construction of new buildings
Taxonomy activity description:
The development of construction projects for residential and non-residential buildings by combining financial, technical, and
physical means with a view to sell the building upon delivery or at a later date, as well as the construction of complete residential
or non-residential buildings, on own account for sale or on a fee or contract basis.
Eligible METLEN activity description:
The Group, through its subsidiary METKA, has undertaken the development and construction of a 5* (five-star) hotel unit in
Kissamos (Crete), with a capacity of 414 rooms, suites and bungalows, with 1,280 beds; developed along a 600-metre-long
beachfront. Also in 2024, METKA has undertaken the construction of the Riviera Galleria in Elliniko, a 23,000 m2 luxury shopping
and entertainment complex. The project consists of three two-story buildings housing commercial shops, service outlets, and
leisure areas, along with underground utility spaces, a surrounding landscaped area, and outdoor parking facilities, with
completion expected in 26 months. The Group, through its subsidiary METKA, has undertaken the development and exploitation
of a 5* (five-star) hotel unit in Glyfada (S. Athens), with a capacity of 400 beds as well as catering, entertainment and ancillary
areas. In addition, through the Joint Venture "TERNA S.A. – ACTOR. ATE - METKA ATE", METKA has undertaken the construction
of a new football stadium of Panathinaikos F.C. in the area of Botanikos as well as the configuration of the common areas and
accessibility to the surrounding area of the stadium. Finally, METKA has undertaken the construction of a new Sports Center in
the area of Ellinikos-Agios Kosmas.
The Metlen–ΑΤΕΣΕ consortium has been awarded a €159.21 million project to design, construct, and manage 17 new bioclimatic
school units in Central Macedonia, Greece, aiming to replace outdated educational infrastructure. The construction phase is
expected to be completed within two years, followed by a 25-year period during which the consortium will be responsible for
the maintenance and operation of these facilities.
The Group has completed in 2024, the Athens Heart-AADE Building project which involves the full renovation of an existing four-
level, 30,000 m² building into office space, the construction of a new five-level, 3,000 m² office building, and the development of
a 4,000 m² surrounding area, with LEED Gold certification and integrated photovoltaic systems, while also it carried out the
construction of new building complexes in the Metropolitan Park of Hellinikon, owned by Hellinikon S.M.S.A.. Also, it completed
the demolition, structural reinforcements, and temporary installations for Alpha Bank’s existing nine-story building, with a total
built area of 15,000 m² and it completed the full renovation of the KARELA BUSINESS PARK in Paiania, transforming a 30,000 m²,
four-level building into office space, constructing a new 3,000 m², five-level office building, and carrying out 4,000 m² of
5. Annual Board of Directors Management Report
186
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
landscaping works. ELEMKA, METKA’s subsidiary, is undertaking the preliminary works, including earthworks, retaining
structures, and piling, for the foundation and construction of the iconic building at the Naval Heritage Park, "Odysseas – The
Greeks and the Sea." and carried out the foundations, MEP, and construction of a 15,500 m² paper factory for Intertrade in
Oinofyta, along with the development of an 18,000 m² surrounding area and the installation of a biological treatment plant. The
Group undertook the complete structural restoration of the Athinogenes Mansion, a designated historic and preserved
monument built between 1875–1880, to preserve and highlight its architectural significance. The project also included the
construction of an eight-story building at the rear of the site, connected to the mansion via a ground-level landscaped area and
an elevated passage on the first floor. Lastly, the Group completed the construction of the Cyber Command building within the
Papagou military camp, a project donated by the Athanasios K. Laskaridis Charitable Foundation.
Minimum Safeguards
METLEN creates value for its Social Partners through its business activities, making a substantial contribution to the economy, to
employment and to the development of its local communities.
The responsible operation of METLEN, has been systematically cultivated over the last 12 years through the implementation of
its Corporate Social Responsibility (CSR) policy and the Company's commitment to the 10 Principles of the UN Global Compact.
For METLEN, CSR is an ongoing self-improvement and incessant learning process, while also serves as a key mechanism for
renewing its “social license to operate” and, at the same time, improves its competitiveness at national and international level.
Sustainable Development is an integral part of the “corporate DNA” of METLEN and, therefore, of its long-term business strategy.
It is the driving force through which the Company aspires to remain competitive in the long term, to meet contemporary
challenges and, by developing appropriate partnerships, to contribute to a new and efficient model of socially inclusive growth,
as this is reflected in the Sustainable Development Goals.
The Company’s business model is at the center of its operation. We utilize our available resources in accordance with our vision,
mission and business values, to produce and market our products and services, while also contributing to the Global Sustainable
Development Goals (UN 2030 Agenda) and creating value for our Social Partners. The relevant key performance indicators,
together with descriptions of the interrelationships between the resources utilized in the context of our Business Model, is
available at the Company’s website.
The aim of the Integrated Value Creation Scorecard (available on our website) is the presentation to all METLEN Social Partners
of the basic resources (economic, industrial, natural, human and social) that it utilizes during its activity, through its business
model, the corresponding results and the value generated in combination with the 17 UN Sustainable Development Goals.
The Sustainability Actions Map is an innovative tool that provides in a concise and centralized way, the information on Sustainable
Development issues to all Stakeholders. Immediate access to the desired information and easy operation of the microsite are key
features for the effective provision of information to the Company's stakeholders, focusing either on the desired Global
Sustainable Development Goal or on the desired region / country for each of the Business Units.
OECD Guidelines for Multinational Enterprises
Our Code of Conduct has been developed taking into account the OECD Guidelines for Multinational Enterprises. We have
implemented a custom training program in the Company’s Code of Business Conduct for our employees. We applied our “Zero
Tolerance” approach in connection with incidents of corruption and bribery in all our activities, both domestically and
internationally. We successfully continued the dialogue with our Stakeholders, implementing a special thematic Consultation
focused on the creation of our corporate Human Rights Policy, gaining the almost universal acceptance and support of all our
Stakeholder groups for this initiative of the Company.
Respect of Human and Labour Rights
Since 2008, METLEN has committed itself to complying with the Compact’s 10 Principles, annually publishing its relevant
performance, both in terms of its overall operation and its broader transactions. METLEN is committed to the first six Principles
of the UN Global Compact, which are based on, among others, the internationally recognized principles on the protection of
Human Rights, as these are defined in the Universal Declaration on Human Rights. The Code of Business Conduct, which is
addressed to all levels in the Company's hierarchy, promote the protection of and respect for Human Rights, mitigating the
likelihood of such incidents occurring in the Company's working environment. Furthermore, during 2020 we have proceeded with
the elaboration of a specialized Human Rights Policy, in dialogue with our Social Partners, during which METLEN listened to the
views of all its Social Partners on the key points of the policy and integrated them into its final corporate policy document. The
Human Rights Policy expresses the Company's zero tolerance of any violation of Human Rights. We fully protect labour rights as
well as the other categories of Human Rights related to our activity.
5. Annual Board of Directors Management Report
187
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Company operates on the basis of its firm commitment to zero tolerance for human rights violations, which is realized both
by not participating (directly, passively or implicitly) in such violations, and by avoiding any transaction and contact with third
parties, in countries where it operates, which may have caused or are reasonably suspected to be involved in creating conditions
that may cause human rights violations. It is bound by the first 6 Principles of the United Nations Universal Compact, which are
based, among others, on the internationally recognized principles of the protection of human rights, as defined in the
International Declaration of Human Rights (IDHR).
The Company, through the basic mechanism for reporting violations of the Code of Business Conduct and the Code of Conduct
of Suppliers/Business Partners (anonymous or named reports by telephone, fax, mail, as well as by e-mail to the Regulatory
Compliance Department), provides the opportunity for employees and its suppliers/business partners to raise any concerns and
incidents of Human Rights violation. At the same time, the Company guarantees that no action will be taken against anyone who
reports, in good faith, any actual or alleged wrongdoing.
No incidents of human rights violations were reported to the General Directorate of Human Resources or the Regulatory
Compliance Department through the official mechanism for reporting violations of the Company's Code of Conduct
(whistleblowing line) during 2024, achieving the Company's long-term goal of zero tolerance for violations of human rights.
Additionally, there were no final convictions in court in 2024.
Corruption
The Company, as part of its "zero tolerance" approach to corruption and bribery, reserves the right to terminate any form of
cooperation with a Supplier/Business Partner that does not comply with the principle of Integrity as well as with applicable
legislation and relevant regulations against corruption and bribery in the countries where it operates.
Through the control mechanisms implemented in the Procurement Departments of the Business Units, the Company filters both
the selection of partners and all transactions, assuring that there were no confirmed incidents of corruption that led to
disciplinary sanctions or dismissal of employees due to corruption, nor confirmed incidents of corruption that have led to the
termination or non-renewal of the business relationship with partners, or any legal proceedings related to corruption against the
Company or its employees.
METLEN minds to analyze the prevailing conditions and potential risks or threats that may encourage the occurrence of
corruption or bribery in the corporate environment through a third-party audit and due diligence process.
Taxation
Taxation is considered an extremely important issue and is supervised by the Company's highest governing bodies. We have put
in place effective measures to manage tax risks, in line with OECD tax guidelines. In addition, the Company did not face cases of
violation of tax legislation. Finally, the Company receives an annual tax certificate following a relevant tax audit carried out during
the annual regular audit by its appointed auditor. More details on this topic are also available in the section of the annual report
"Unaudited fiscal years".
Healthy competition
The Company's operation is based on transparency, emphasizing its firm commitment to avoid unfair business practices that
hinder fair competition.
METLEN has developed a "Code of Conduct for Suppliers and Partners" which is also publicly available on its website. The Code
ensures and requires suppliers to be able to demonstrate compliance with applicable national legislation or industry standards
by operating in various areas such as “Avoidance of all acts of unfair competition”. In addition, "Fair Competition Law" training
and materials have been developed for specific employees. All employees of METLEN, including employees of subsidiaries,
receive relevant training according to their degree of exposure to relevant risks.
Qualitative information
Accounting Policy
The figures presented in this report have been calculated and are presented in accordance with the International Financial
Reporting Standards (IFRS) that have been issued by the International Accounting Standards Board (IASB) and their
interpretations that have been issued by the International Financial Reporting Interpretations Committee (IFRIC) of the IASB.
Their preparation requires estimations during the application of the Group’s accounting principles. Important admissions are
presented wherever it has been judged appropriate.
Double counting has been avoided, as the Group's activities are solely attributed to the sustainable objective of Climate Change
Mitigation. The assessment process ensured precise data allocation, in line with the EU Taxonomy’s reporting principles, to
uphold transparency and consistency in disclosures.
5. Annual Board of Directors Management Report
188
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In the present report we present the proportion of the total turnover from the sale of goods or provisions of services, as well as
the total CapEx and OpEx of the Group’s economic activities that correspond to activities determined to be non-eligible, eligible
or aligned for EU Taxonomy purposes according to the description of these activities and taking into account the respective NACE
activity codes, as well as the relevant technical screening criteria as presented in Delegated Acts 2021/2139/EU, 2023/2486/EU
and 2022/1214/EU. The Group’s economic activities were reviewed and ultimately included/excluded both in terms of eligibility
as well as in terms of alignment with the technical screening criteria provided in the related Delegated Acts. The said examination
is thoroughly presented for each aligned activity, whereas any activities that did not fulfill one or several of the technical criteria
are included only as eligible. Taking into consideration the above, the calculation of the KPIs was based on the following elements
of the Group’s financial reporting:
Proportion of the total turnover. It was calculated based on the total net turnover from the sale of goods and provision of
services. The numerator includes the activities that are considered to be aligned according to the Taxonomy regulation and the
relevant technical screening criteria under the condition that said revenue does not include own use and intergroup transactions.
Specifically, the numerator includes revenue from products and services associated with economic activities that meet the
Taxonomy’s technical screening criteria, ensuring a substantial contribution to environmental objectives while complying with
minimum social safeguards. This amount may include revenue from contracts with customers, lease revenue, or other sources
of income. The total turnover at Group level is presented in the Income Statement as well as in note 3.1 of the Financial
Statements.
Proportion of the total CapEx. It was calculated based on the capitalized expenses incurred for additions to assets or processes
corresponding to aligned economic activities. The numerator includes the activities that are considered to be aligned according
to Taxonomy regulation and the relevant technical screening criteria. Specifically, the numerator includes investments in tangible
and intangible assets, as well as right-of-use assets, that contribute to Taxonomy-aligned activities, while it should be noted that
the total CapEx is per entity within the group and a quota has been allocated to it to produce the corresponding amount for this
section of the report. The denominator includes all capitalized additions to tangible and intangible assets during the financial
year, before depreciation, amortization, revaluations, or impairments, and excluding fair value changes. The Group totals
regarding additions to tangible, intangible and right of use assets are presented in notes 3.2, 3.3 and 3.5 of the Financial
Statements.
Proportion of the total OpEx. It was calculated based on the operating expenses related to the repair and maintenance of assets
or processes corresponding to aligned economic activities. Specifically, the numerator includes costs associated with
maintenance, repair, and other direct expenses. The total OpEx, similar to CapEx, is reported per entity within the group, with a
quota allocated to derive the corresponding amount for this section of the report. The denominator includes direct operating
expenses related to the day-to-day servicing of assets and processes, including maintenance, repair, and short-term lease costs,
as well as other expenses necessary to sustain Taxonomy-aligned operations.The numerator includes the activities that are
considered to be aligned according to the Taxonomy regulation and the relevant technical screening criteria.
The information presented in this report complies with the requirements of the Taxonomy Regulation and the relevant Delegated
Regulations issued up to the time of this publication. The relevant guidelines have a relative margin of interpretation and are
constantly adapted to the needs of the process. Taking this into account, METLEN pays particular attention to relevant
developments and adjusts its approach depending on the assumptions and applicable methodology. Lastly, an amendment was
made in the KPI tables this reporting period to amend an omission that was made in 2023 when accounting for the eligible activity
electricity generation from fossil gaseous fuels.
5. Annual Board of Directors Management Report
189
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Turnover KPI Table
Fina nc ial ye a r 20 24
Ec onom ic Ac tivitie s (1) Co de (2 ) Turnove r (3)
Propo rtion of
Turno ve r
20 24 (4)
Climate
Chang e
Mitigation
(5)
Climate
Chang e
Adapta tio
n (6)
Wate r (7)
Pollution
(8)
Circ ular
Ec onom y
(9)
Biodive rs i
ty (10 )
Climate
Chang e
Mitigation
(11 )
Climate
Chang e
Adapta tio
n (12)
Wate r
(13 )
Pollution
(14 )
Circ ular
Ec onom y
(15 )
Biodive rs i
ty (16 )
Minimum
Safe gua r
ds (17)
Propo rtion of
Taxo no my-aligne d
(A.1 .) or -e ligible (A.2 .)
turnove r 20 2 3 (1 8)
Ca te go ry
e nabling
ac tivity (19 )
Ca te go ry
trans itiona l
ac tivity (20 )
00 0€ %
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y/N Y /N Y /N Y /N Y /N Y /N Y /N % E T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1 . Environme ntally s us taina ble ac tivitie s (Ta xonom y-aligne d)
Ma nu fa cture of alum inium CC M 3.8 27 ,489
0% Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 0% T
Ele ctricity g e ne ra tio n us ing s ola r ph otovolta ic te chno logy CC M 4 .1 1,08 4,23 2
19 % Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 10 %
Ele ctricity g e ne ra tio n from wind po we r CC M 4.3 47 ,815
1% Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 1%
Stora g e of electricity CC M 4.10 16 ,39 0
0% Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 3% E
1,1 75 ,926 2 1% 21 % 0% 0% 0% 0% 0%
Y Y Y Y Y Y Y
14 %
16 ,39 0 0 % 0% 0% 0% 0% 0% 0%
Y Y Y Y Y Y Y
3% E
27 ,48 9 0 % 0% 0% 0% 0% 0% 0%
Y Y Y Y Y Y Y
0% T
A.2 . Ta xonom y-e ligible but not e nvironme ntally s us taina ble ac tivitie s (not Ta xonom y-aligne d ac tivities )
EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL
Ma nu fa cture of alum inium CC M 3.8 485 ,42 1
9% EL EL N/EL N /EL N/EL N /EL 9%
Ma nu fa cture , ins talla tion, a n d s ervicing o f high, m e dium
a n d low vo ltag e e le ctrica l e q uipm e nt fo r e le ctrica l
trans m is s io n a nd dis tribu tion tha t re s ult in or e n a ble a
s u bs ta n tial co ntribution to clima te ch a ng e m itiga tion
CC M 3.20 44 ,39 7
1% EL N/EL N /EL N/EL N /EL N/EL 0%
Ele ctricity g e ne ra tio n from h yd ropo we r CC M 4.5 13 6 0 % EL EL N/EL N/EL N/EL N/EL 0%
Trans m is s io n a n d dis tribu tion of e le ctricity CC M 4 .9 - 0% EL EL N/EL N /EL N/EL N /EL 0%
Ele ctricity g e ne ra tio n from fos s il ga s e ous fu e ls CC M 4 .29 1,02 9,5 37 18 % EL EL N/EL N/EL N/EL N/EL 10 %
Infra s tructure for ra il tra ns po rt CC M 6.14 64 ,14 2 1 % EL EL N/EL N /EL N/EL N/EL 1%
Ins ta lla tion, m a inte na n ce a n d re p a ir of e ne rgy e fficie ncy
e q uipm e nt
CC M 7.3 7,5 89
0% EL EL N/EL N /EL N/EL N /EL 0%
Co ns tructio n of ne w b uilding s CE 3 .1 10 1,3 99 2% EL EL N/EL N/EL EL N/EL 0%
1,7 32 ,621 3 0% 29 % 0% 0% 0% 2% 0% 20 %
2,9 08 ,547 5 1% 49 % 0% 0% 0% 2% 0% 33 %
2,7 74 ,409 49%
5,6 82 ,956 100 %
Of whic h trans itional
Turno ve r of Ta xo nom y-e lig ible but not e nvironme ntally s us tainable
ac tivitie s (not Ta xonom y-alig ne d ac tivities ) (A.2 )
Ye ar
Subs tantial c o ntribution c rite ria
DNSH c riteria (“Doe s No t S ignifica ntly Harm”)
Turno ve r of e nvironm e ntally s us taina ble ac tivitie s (Ta xonom y-aligne d)
(A.1 )
Of whic h e nabling
A. Turnove r of Ta xo no m y-e ligible a c tivities (A.1+A.2)
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
Turno ve r of Ta xo nom y-no n-e ligible ac tivities
TOTAL
5. Annual Board of Directors Management Report
190
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
CapEx KPI Table
Fina nc ial ye ar 20 2 4
Ec onomic Ac tivitie s (1) Code (2) Ca pEx (3 )
Propo rtion o f
Ca pEx 20 24
(4)
Climate
Chang e
Mitigation
(5)
Climate
Chang e
Adapta tio
n (6)
Wate r (7)
Pollution
(8)
Circ ular
Ec onomy
(9)
Biodive rs i
ty (10 )
Climate
Chang e
Mitigation
(11 )
Climate
Chang e
Adapta tio
n (12)
Wate r
(13 )
Pollution
(14 )
Circ ular
Ec onomy
(15 )
Biodive rs i
ty (16 )
Minimum
Safe g ua r
ds (17)
Propo rtion o f
Taxo no my-aligne d
(A.1 .) or -e ligible (A.2.)
Ca pEx 20 23 (1 8)
Ca te gory
e nabling
ac tivity
(19 )
Ca te gory
trans ition
al ac tivity
(20 )
00 0€ %
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1 . Environme ntally s us tainable ac tivities (Tax o no my-aligne d)
Ma nu fa cture of a lum inium CC M 3.8 2,9 04 0% Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 1% T
Ele ctricity g e ne ra tion u s ing s ola r p hotovolta ic te chno logy CC M 4 .1 493 ,483 6 2% Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 52 %
Ele ctricity g e ne ra tion fro m wind p owe r CC M 4.3 44 ,144 6% Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 1%
Stora ge of e le ctricity CC M 4.10 6 ,437 1% Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 13% E
54 6,96 9 68%
68 % 0% 0 % 0 % 0 % 0 % Y Y Y Y Y Y Y 67 %
6,4 37 1%
1% 0% 0% 0% 0% 0 % Y Y Y Y Y Y Y 1 3% E
2,9 04 0%
0% 0% 0% 0% 0% 0 % Y Y Y Y Y Y Y 1% T
A.2 . Ta xonomy-e ligible but no t e nvironme ntally s us tainable a c tivitie s (not Ta xonom y-a ligne d a c tivities )
EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL
Ma nu fa cture of a lum inium CC M 3.8 51 ,288
6% EL EL N/EL N/EL N /EL N /EL 12 %
Ma nu fa cture , ins ta llation , a nd s e rvicing of high , m e dium
a n d low volta ge e le ctrica l e q uipm e n t for e le ctrica l
trans m is s ion a n d dis tribution tha t re s u lt in or e na ble a
s u bs ta ntia l con tribution to clima te cha nge m itig a tion
CC M 3.20 1 ,401
0% EL N/EL N/EL N /EL N /EL N /EL 0%
Ele ctricity g e ne ra tion fro m hydrop owe r CC M 4.5 16 0% EL EL N /EL N/EL N/EL N/EL 0%
Trans m is s ion a nd d is tribution of ele ctricity CCM 4.9 - 0 % EL EL N/EL N/EL N /EL N /EL 0%
Ele ctricity g e ne ra tion fro m fo s s il g a s eou s fu e ls CCM 4.29 4 8,12 7 6% EL EL N/EL N/EL N/EL N /EL 14 %
Infra s tructure for ra il trans port CC M 6.14 4 ,010 1% EL EL N /EL N/EL N/EL N/EL 0%
Ins ta lla tion, m a inte n a nce a n d re p a ir of e ne rg y e fficie ncy
e q uipm e n t
CC M 7.3 2 40
0% EL EL N/EL N/EL N /EL N /EL 0%
Co ns truction of ne w buildings CE 3.1 6,3 39 1% EL EL N/EL N/EL EL N /EL 0%
11 1,42 2 14% 13% 0% 0% 0 % 1 % 0 % 27 %
65 8,39 0 82% 81% 0% 0% 0 % 1 % 0 % 93 %
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
14 2,86 7 18 %
TOTAL 80 1,25 7 100 %
Of whic h trans itiona l
Ca pEx of Tax ono my-e ligible but not e nvironme ntally s us taina ble
ac tivitie s (not Ta x onomy-a ligne d a c tivitie s ) (A.2)
Ye ar
Subs tantial c o ntribution c riteria
DNSH c riteria (“Doe s No t S ignificantly Ha rm”)
Ca pEx of e nviro nme ntally s us taina ble ac tivitie s (Ta x onomy-a ligne d)
(A.1 )
Of whic h e nabling
A. CapEx o f Ta x onomy-e ligible ac tivities (A.1 +A.2)
Ca pEx of Tax ono my-non-e ligible ac tivities
5. Annual Board of Directors Management Report
191
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
OPEX KPI Table
Fina nc ial ye ar 202 4
Ec onomic Ac tivitie s (1) Co de (2 ) OpEx (3)
Propo rtion o f
OpEx 2 0 24 (4 )
Climate
Chang e
Mitigation
(5)
Climate
Chang e
Adapta tio
n (6)
Wate r (7)
Pollution
(8)
Circ ular
Ec onomy
(9)
Biodive rs i
ty (10 )
Climate
Chang e
Mitigation
(11 )
Climate
Chang e
Adapta tio
n (12)
Wate r
(13 )
Pollution
(14 )
Circ ular
Ec onomy
(15 )
Biodive rs i
ty (16 )
Minimum
Safe g ua r
ds (17)
Propo rtion o f
Taxo no my-aligne d
(A.1 .) or -e ligible (A.2.)
OpEx 2 0 23 (1 8)
Ca te gory
e nabling
ac tivity
(19 )
Ca te gory
trans ition
al ac tivity
(20 )
00 0€ %
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y; N;
N/EL
Y/N Y /N Y /N Y/N Y /N Y /N Y /N % E T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1 . Environme ntally s us tainable a c tivitie s (Tax onomy-a ligne d)
Ma nu fa cture of a lum inium CC M 3.8 1 6,16 8 0% Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 3% T
Ele ctricity g e ne ra tion u s in g s o la r p hotovolta ic te chno log y CCM 4.1 8 19,5 54 18 % Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 9%
Ele ctricity g e ne ra tion from wind p owe r CC M 4.3 1 1,59 0 0% Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 0%
Stora ge o f e le ctricity CC M 4.10 12 ,465 0 % Y - N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 2% E
85 9,77 7 1 9%
19 % 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 14%
12 ,465 0 %
0% 0% 0% 0% 0 % 0% Y Y Y Y Y Y Y 2% E
16 ,168 0 %
0% 0% 0% 0% 0 % 0% Y Y Y Y Y Y Y 3% T
A.2 . Ta xonomy-e ligible but not e nviro nme ntally s us taina ble ac tivities (not Taxo no my-aligne d ac tivities )
EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL
Ma nu fa cture of a lum inium CC M 3.8 285 ,501 6 %
EL EL N/EL N/EL N/EL N/EL 7%
Ma nu fa cture , ins ta lla tion , a n d s e rvicing of high, m e d ium
a n d low vo ltage e le ctrica l e q uipm e n t for e le ctrica l
trans m is s ion a nd dis tribu tion tha t re s ult in o r e na ble a
s u bs ta ntia l con tribution to clima te cha n ge m itig a tion
CC M 3.20 41 ,257 1 %
EL N /EL N /EL N /EL N /EL N /EL 0%
Ele ctricity g e ne ra tion from hydrop owe r CCM 4.5 9 3 0% EL EL N/EL N/EL N/EL N/EL 0%
Trans m is s ion a nd d is tributio n of electricity CCM 4.9 - 0% EL EL N/EL N/EL N/EL N /EL 0%
Ele ctricity g e ne ra tion from fo s s il ga s e ous fu e ls C CM 4.2 9 645 ,816 1 4% EL EL N/EL N /EL N/EL N/EL 7%
Infra s tructure for ra il trans port CCM 6 .1 4 74,0 24 2% EL EL N/EL N/EL N/EL N/EL 0%
Ins ta lla tion, m a inte n a nce a n d re p a ir of e n e rgy efficie ncy
e q uipm e n t
CC M 7.3 7,05 3 0%
EL EL N/EL N/EL N/EL N/EL 0%
Co ns truction of ne w buildings CE 3 .1 117 ,021 3 % EL EL N/EL N/EL EL N/EL 0%
1,1 70,7 65 25%
23 % 0% 0% 0% 3% 0% 16 %
2,0 30,5 42 44%
42 % 0% 0% 0% 3% 0% 29 %
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
2,5 67,1 80 56 %
4,5 97,7 22 1 00%
Of whic h trans itiona l
OpEx o f Ta x onomy-e ligible but not e nvironme ntally s us taina ble
ac tivitie s (not Tax ono my-a ligne d ac tivitie s ) (A.2)
Ye ar
Subs tantial c o ntribution c riteria
DNSH c riteria (“Doe s Not S ignificantly Ha rm”)
OpEx o f e nviro nme ntally s us taina ble ac tivitie s (Ta x onomy-a ligne d)
(A.1 )
Of whic h e nabling
A. OpEx o f Ta xonomy-e ligible ac tivities (A.1 +A.2)
OpEx o f Ta x onomy-non-e ligible ac tivities
TOTAL
5. Annual Board of Directors Management Report
192
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Turnover KPI
Taxonomy-aligned economic activities (denominator)
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate
change
adaptation
(CCA)
Row
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.26 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.27 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.28 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.29 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
5.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.30 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.31 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
7.
Amount and proportion of other taxonomy-
aligned economic activities not referred to in
rows 1 to 6 above in the denominator of the
applicable KPI
1,175,926
21%
1,175,926
21%
0
0%
8.
Total applicable KPI
5,682,956
100%
5,682,956
100%
0
0%
5. Annual Board of Directors Management Report
193
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Taxonomy-aligned economic activities (numerator)
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate
change
adaptation
(CCA)
Row
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.26 of
Annexes I and II to Delegated Regulation 2021/2139 in
the numerator of the applicable KPI
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.27 of
Annexes I and II to Delegated Regulation 2021/2139 in
the numerator of the applicable KPI
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.28 of
Annexes I and II to Delegated Regulation 2021/2139 in
the numerator of the applicable KPI
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.29 of
Annexes I and II to Delegated Regulation 2021/2139 in
the numerator of the applicable KPI
0
0%
0
0%
0
0%
5.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.30 of
Annexes I and II to Delegated Regulation 2021/2139 in
the numerator of the applicable KPI
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.31 of
Annexes I and II to Delegated Regulation 2021/2139 in
the numerator of the applicable KPI
0
0%
0
0%
0
0%
7.
Amount and proportion of other taxonomy-aligned
economic activities not referred to in rows 1 to 6
above in the numerator of the applicable KPI
1,175,926
21%
1,175,926
21%
0
0%
8.
Total amount and proportion of taxonomy-aligned
economic activities in the numerator of the
applicable KPI
1,175,926
21%
1,175,926
21%
0
0%
5. Annual Board of Directors Management Report
194
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Taxonomy-eligible but not taxonomy-aligned economic activities
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate
change
adaptation
(CCA)
Row
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.26 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.27 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.28 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.29 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
1,029,537
18%
1,029,537
18%
0
0%
5.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.30 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.31 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
7.
Amount and proportion of other taxonomy-eligible
but not taxonomy-aligned economic activities not
referred to in rows 1 to 6 above in the denominator of
the applicable KPI
703,084
12%
703,084
12%
0
0%
8.
Total amount and proportion of taxonomy eligible
but not taxonomy- aligned economic activities in the
denominator of the applicable KPI
1,732,621
30%
1,732,621
30%
0
0%
5. Annual Board of Directors Management Report
195
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Taxonomy non-eligible economic activities
Row
Economic activities
Amount
%
1.
Amount and proportion of economic activity referred to in row 1 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
2.
Amount and proportion of economic activity referred to in row 2 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.27 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
3.
Amount and proportion of economic activity referred to in row 3 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.28 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
4.
Amount and proportion of economic activity referred to in row 4 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.29 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
5.
Amount and proportion of economic activity referred to in row 5 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.30 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
6.
Amount and proportion of economic activity referred to in row 6 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.31 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
7.
Amount and proportion of other taxonomy-non-eligible economic activities not
referred to in rows 1 to 6 above in the denominator of the applicable KPI
2,774,409
49%
8.
Total amount and proportion of taxonomy-non-eligible economic activities in
the denominator of the applicable KPI
2,774,409
49%
5. Annual Board of Directors Management Report
196
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
CapEx KPI
Taxonomy-aligned economic activities (denominator)
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate
change
adaptation
(CCA)
Row
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.26 of
Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.27 of
Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.28 of
Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.29 of
Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
0
0%
0
0%
0
0%
5.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.30 of
Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.31 of
Annexes I and II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
0
0%
0
0%
0
0%
7.
Amount and proportion of other taxonomy-aligned
economic activities not referred to in rows 1 to 6
above in the denominator of the applicable KPI
546,969
68%
546,969
68%
0
0%
8.
Total applicable KPI
801,257
100%
801,257
100%
0
0%
5. Annual Board of Directors Management Report
197
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Taxonomy-aligned economic activities (numerator)
Amount and proportion
CCM + CCA
Climate change
mitigation
(CCM)
Climate
change
adaptation
(CCA)
Row
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.26 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.27 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.28 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.29 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
5.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.31 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
7.
Amount and proportion of other taxonomy-aligned
economic activities not referred to in rows 1 to 6 above
in the numerator of the applicable KPI
546,969
68%
546,969
68%
0
0%
8.
Total amount and proportion of taxonomy-aligned
economic activities in the numerator of the applicable
KPI
546,969
68%
546,969
68%
0
0%
5. Annual Board of Directors Management Report
198
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Taxonomy-eligible but not taxonomy-aligned economic activities
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate
change
adaptation
(CCA)
Row
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.26 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.27 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.28 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.29 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
48,127
6%
48,127
6%
0
0%
5.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.30 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.31 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0
0%
0
0%
0
0%
7.
Amount and proportion of other taxonomy-eligible but
not taxonomy-aligned economic activities not referred
to in rows 1 to 6 above in the denominator of the
applicable KPI
63,294
8%
63,294
8%
0
0%
8.
Total amount and proportion of taxonomy eligible but
not taxonomy- aligned economic activities in the
denominator of the applicable KPI
111,422
14%
111,422
14%
0
0%
5. Annual Board of Directors Management Report
199
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Taxonomy non-eligible economic activities
Row
Economic activities
Amount
%
1.
Amount and proportion of economic activity referred to in row 1 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
2.
Amount and proportion of economic activity referred to in row 2 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.27 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
3.
Amount and proportion of economic activity referred to in row 3 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.28 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
4.
Amount and proportion of economic activity referred to in row 4 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.29 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
5.
Amount and proportion of economic activity referred to in row 5 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.30 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
6.
Amount and proportion of economic activity referred to in row 6 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.31 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
7.
Amount and proportion of other taxonomy-non-eligible economic activities not
referred to in rows 1 to 6 above in the denominator of the applicable KPI
142,867
18%
8.
Total amount and proportion of taxonomy-non-eligible economic activities in
the denominator of the applicable KPI
142,867
18%
5. Annual Board of Directors Management Report
200
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
OpEx KPI
Taxonomy-aligned economic activities (denominator)
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate
change
adaptation
(CCA)
Row
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.26 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.27 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.28 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.29 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
5.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.30 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy- aligned
economic activity referred to in Section 4.31 of
Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable
KPI
0
0%
0
0%
0
0%
7.
Amount and proportion of other taxonomy-
aligned economic activities not referred to in rows
1 to 6 above in the denominator of the applicable
KPI
859,777
19%
859,777
19%
0
0%
8.
Total applicable KPI
4,597,722
100%
4,597,722
100%
0
0%
5. Annual Board of Directors Management Report
201
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Taxonomy-aligned economic activities (numerator)
Amount and proportion
CCM + CCA
Climate change
mitigation
(CCM)
Climate
change
adaptation
(CCA)
Row
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.26 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.27 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.28 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.29 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
5.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy- aligned economic
activity referred to in Section 4.31 of Annexes I and II to
Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0%
0
0%
0
0%
7.
Amount and proportion of other taxonomy-aligned
economic activities not referred to in rows 1 to 6 above
in the numerator of the applicable KPI
859,777
19%
859,777
19%
0
0%
8.
Total amount and proportion of taxonomy-aligned
economic activities in the numerator of the applicable
KPI
859,777
19%
859,777
19%
0
0%
5. Annual Board of Directors Management Report
202
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Taxonomy-eligible but not taxonomy-aligned economic activities
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate
change
adaptation
(CCA)
Row
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.26 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
2.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.27 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
3.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.28 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
4.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.29 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
645,816
14%
645,816
14%
0
0%
5.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.30 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
6.
Amount and proportion of taxonomy- eligible but not
taxonomy-aligned economic activity referred to in
Section 4.31 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0%
0
0%
0
0%
7.
Amount and proportion of other taxonomy-eligible
but not taxonomy-aligned economic activities not
referred to in rows 1 to 6 above in the denominator of
the applicable KPI
524,949
11%
524,949
11%
0
0%
8.
Total amount and proportion of taxonomy eligible but
not taxonomy- aligned economic activities in the
denominator of the applicable KPI
1,170,765
25%
1,170,765
25%
0
0%
5. Annual Board of Directors Management Report
203
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Taxonomy non-eligible economic activities
Row
Economic activities
Amount
%
1.
Amount and proportion of economic activity referred to in row 1 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
2.
Amount and proportion of economic activity referred to in row 2 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.27 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
3.
Amount and proportion of economic activity referred to in row 3 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.28 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
4.
Amount and proportion of economic activity referred to in row 4 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.29 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
5.
Amount and proportion of economic activity referred to in row 5 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.30 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
6.
Amount and proportion of economic activity referred to in row 6 of Template 1
that is taxonomy-non-eligible in accordance with Section 4.31 of Annexes I and II
to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0%
7.
Amount and proportion of other taxonomy-non-eligible economic activities not
referred to in rows 1 to 6 above in the denominator of the applicable KPI
2,567,180
56%
8.
Total amount and proportion of taxonomy-non-eligible economic activities in
the denominator of the applicable KPI
2,567,180
56%
5. Annual Board of Directors Management Report
204
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
OWN WORKFORCE [ESRS: S1]
As a responsible multinational company, METLEN Energy & Metals attaches particular importance to managing and monitoring
several critical issues that contribute to creating a safe and supportive work environment. These include managing working
conditions, working time, ensuring adequate wages and work-life balance. At the same time, it implements measures for the fair
treatment of its employees and the promotion of equal opportunities, while developing a strict framework of measures against
violence and harassment in the workplace. Particular attention is also paid to promoting gender equality, equal pay for work of
equal value and enhancing diversity. METLEN's priority is to ensure secure jobs and freedom of association by strengthening
employees' information, consultation and participation rights. Through continuous investment in its people, METLEN promotes
training, skills development and the creation of a fair and sustainable working environment.
STRATEGY
ESRS2: SBM-3
Material impacts, risks and opportunities and their interaction with strategy and business model
According to the outcome of the Impact Materiality Analysis, the main impacts that emerged as being material in relation to the
management of direct employees are reflected in the following table:
ACTUAL NEGATIVE IMPACT [AN-4]:
Management and monitoring of working conditions
This impact is directly related to all production plants of the Company as well as to all Central Functions. [SBM3_14_b] [SMB3_14_c]
[SMB3_14_d] [SBM3_14_AR_44]
Time Horizon:
Actual
Position in the Value Chain:
Own Operations
FINANCIAL RISK [S1-R1]: Increase in operating costs for taking additional measures to improve working conditions, mental
health, and generally the effective management of issues affecting employees
Financial Significance:
High
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Own Operations
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS
MODEL & VALUE CHAIN
[SBM3:48_b]
CURRENT AND POTENTIAL IMPACT ON STRATEGY &
DECISION MAKING
[SBM3:48_b]
a) Impact on a positive work culture due to limited work-life
balance, caused by rolling shift regimes in factories and/or
increased workload for specific periods.
a) Taking measures to improve working conditions and the
mental and physical health of employees, with the aim of
reducing occupational fatigue.
b) Review hierarchical levels of executives and employees as a
whole, as well as reward policies, including remuneration,
bonuses and other benefits, to increase employee
engagement and satisfaction.
c) Strengthening policies, incentives and benefits to attract
new talent and retain existing staff.
d) Developing an action plan to enhance employee satisfaction
based on their feedback.
e) Increasing expenditure for effective management of issues
affecting employees.
ACTUAL NEGATIVE IMPACT [AN-5]:
Development of measures for fair treatment and equal opportunities
This impact is directly related to all production plants of the Company as well as to all Central Functions. [SBM3_14_b] [SMB3_14_c]
[SMB3_14_d] [SBM3_14_AR_44]
Time Horizon:
Actual
5. Annual Board of Directors Management Report
205
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Position in the Value Chain:
Own Operations
FINANCIAL RISK [S1-R1]: Additional operating costs from expenses for managing and balancing gender pay disparities,
particularly among middle management
Financial Significance:
High
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Own Operations
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS
MODEL & VALUE CHAIN
[SBM3:48_b]
CURRENT AND POTENTIAL IMPACT ON STRATEGY & DECISION
MAKING
[SBM3:48_b]
a) Enhancing the diversity of direct workers overall in order to
improve inclusion and equal opportunities including pay in all
corporate activities.
b) Facilitating the integration of direct workers, especially in
sectors where industry as a whole is struggling, such as people
with disabilities and women.
c) Improving the management of women direct employees,
with a view to avoiding a sense of inequality due to gender pay
gaps in specific mid-level management positions. [S1:S1-1_24_d]
a) Continuous effort to manage the recognized pay gap by
developing a strategic approach to strengthening the principle
of equal pay for work of equal value, which entails potential
costs for pay and benefit adjustments.
b) Commitment to strengthen the organizational culture by
promoting practices of respect and responsible behaviour,
with relevant investments in educational programs and
policies to prevent harassment.
c) Developing strategies and policies that encourage diversity
and improve integration and inclusion of people regardless of
personal characteristics.
d) Developing a framework that promotes diversity, enhances
the development of diverse ways of thinking by increasing the
representation of women in senior positions, resulting in
enhanced innovation and diversification strategy of the
Company.
ACTUAL POSITIVE IMPACT [AP-4]:
Secure employment
This impact is directly related to all production plants of the Company as well as to all Central Functions. [SBM3_14_c] [SMB3_14_d]
[SBM3_14_AR_44]
Time Horizon:
Actual
Position in the Value Chain:
Own Operations, Downstream
FINANCIAL OPPORTUNITY [S1-O1]: Consistently strong financial performance of the company, which also depends on
providing job stability supported by a high employee retention rate, enhancing productivity and work efficiency
Financial Significance:
High
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Own Operations, Downstream
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS
MODEL & VALUE CHAIN
[SBM3:48_b]
CURRENT AND POTENTIAL IMPACT ON STRATEGY & DECISION
MAKING
[SBM3:48_b]
a) Creating a positive working climate that enhances
productivity and efficiency at work.
b) Providing job stability for all direct employees, resulting in
improved talent attraction and retention indicators.
c) Improving industrial peace, contributing to the
development of a favourable working environment.
d) Enhancing the satisfaction of all direct employees, with an
impact on increasing the Company's economic efficiency and
the overall sustainable development profile, including health
and safety in the workplace.
a) Adopting strategies to ensure secure jobs and a climate of
industrial peace.
b) Developing programs that promote employee well-being
and satisfaction, enhancing the Company’s attractiveness as a
preferred employer.
c) Focusing on appropriate staff skills development
investments capable of contributing to further enhancing
stability.
d) Continuous confirmation of the evaluation management
strategy, recognizing the dedication of employees to reduce
staff turnover.
5. Annual Board of Directors Management Report
206
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
POTENTIAL POSITIVE IMPACT [PP-3]:
Continuous investment in human resources
This impact is directly related to all operating units and Central Functions of the Company. [SBM3_14_c] [SMB3_14_d] [SBM3_14_AR_44]
Time Horizon:
Short Term
Position in the Value Chain:
Own Operations, Downstream
FINANCIAL OPPORTUNITY [S1-O1]: Further increase in productivity and enhancement of the company's competitiveness, by
strengthening the development of employee skills and improving its adaptability to new markets
Financial Significance:
High
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Own Operations, Downstream
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS
MODEL & VALUE CHAIN
[SBM3:48_b]
CURRENT AND POTENTIAL IMPACT ON STRATEGY & DECISION
MAKING
[SBM3:48_b]
a) Optimal performance of the duties of all direct employees
through a continuous education and upskilling framework,
while contributing to their professional development.
b) Strengthening education and training programmes leading
to more efficient work for all direct employees.
a) Strengthening the sustainable development strategy with
the implementation of practices that confirm the continuous
investment in human resources aiming at their continuous
development and retention in the Company, along with the
ability to attract new talents.
b) Positive evaluation of the corporate development and
learning environment by independent third parties, which
enhances the Company’s overall reputation in the context of
sustainable development.
c) Strategy to focus on continuous professional progress and
continuous improvement of employees' skills to ensure their
professional development and maximize their contribution to
the achievement of corporate objectives.
ACTUAL NEGATIVE IMPACT [AN-3]:
Safety incidents at work and their consequences
POTENTIAL NEGATIVE IMPACT [PN-4]:
Occupational health & safety incidents and their consequences
These impacts are directly related to all production plants of the Company as well as all Central Function. [ESRS2:SBM3_14_b]
[ESRS2:SBM3_14_c] [ESRS2:SBM3_14_d] [ESRS2:SBM3_14_AR_44]
Time Horizon:
Actual & Short Term
Position in the Value Chain:
Own Operations, Downstream
FINANCIAL RISK [S1-R1]: Private insurance costs, compensation, and medical expenses
Financial Significance:
High
Time Horizon:
Actual & Short Term
Position in the Value Chain:
Own Operations, Downstream
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS
MODEL & VALUE CHAIN
[SBM3:48_b]
CURRENT AND POTENTIAL IMPACT ON STRATEGY & DECISION
MAKING
[SBM3:48_b]
5. Annual Board of Directors Management Report
207
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
a) Worker injuries with serious or less serious consequences.
b) Controlled impact on employee morale and psychology.
c) Small-scale slowdown of the production rate in individual
production processes.
a) Continuous promotion of safety culture with emphasis on
prevention and the responsibility of each employee to ensure
a safe working environment.
b) Linking top management remuneration to the Company's
core Safety Objectives.
c) Publication of a central Policy and Objectives for
Occupational Health and Safety.
d) Publication of a central Human Rights Policy.
e) Implementation of best practices for preventing
Occupational Health & Safety incidents.
METLEN’s Sectors and its Subsidiaries are directly involved in the above impacts, while permanent contractors/suppliers
performing important tasks for the Company, especially in bauxite mining and construction, are indirectly involved. METLEN’s
own workforce comprises a diverse mix of mainly direct employees (salaried), self-employed affiliates, as well as a very limited
number of workers through third-party providers (non-salaried). The vast majority of direct workers hold full-time positions,
while certain positions are filled by a small number of part-time employees. Also, direct workers are mainly employed on open-
ended contracts, but certain positions are also filled by fixed-term workers. The self-employed cooperate with the Company
mainly for the provision of specialized services and cover critical areas of business activity, while employees through third-party
providers are employed in specific support services. The impact of the Company's activities on each category of employees is
evaluated with a view to responsible management of human resources and ensuring fair and safe working conditions.
[S1:SBM3_14_a]
In 2024, according to its control mechanisms, METLEN has not recorded any incidents of violation of the rights of its employees,
and does not participate, in any of its activities, in any form of child or forced labor (including modern slavery). [S1:SBM3_14_g]
METLEN does not employ employees under the age of 15 or 18, so in no activity of the Company is there a risk (significant or
not) of occurrence of either incidents of child labor or conditions that may lead to the employment of young employees in
hazardous work. [S1:SBM3_14_f]
Understanding people with particular characteristics among the Company's workforce, who work in specific contexts or carry out
specific activities, is important to identify the risks they may face. This approach is under development, and the recognition
process has begun with a Pulse Survey to assess the Company’s maturity in diversity, equal opportunities and inclusion at the
end of 2024. With this tool, METLEN seeks to gather valuable information to be able to better understand the needs and risks
faced by these employees, so as to enhance the overall promotion of a safer and more supportive work environment. [S1:
SBM_3_15] [S1:SBM3_AR_8]
As illustrated in the key impact tables on business model, strategy and decision-making, specific impacts creating corresponding
risks or opportunities are associated with specific groups of direct employees. [S1:SBM3_16] [S1:SBM3_AR_9]
As reflected in the above tables key impact on business model, strategy and decision-making, specific impacts that create
corresponding risks or opportunities are associated with specific groups of direct workers. The Company assesses in the context
of the double materiality process, all the risks and opportunities arising from its effects and dependencies on its human
resources, taking into account both general issues and impacts on specific groups of employees. For example, developments in
automated processes may mainly affect workers in specific production functions, while upskilling initiatives focus on younger
workers and executives with high growth potential. In addition, work-life balance support programmes are particularly targeted
at workers with family responsibilities and rotating workers, taking into account the specific challenges they face. At the same
time, workers employed on construction sites or in production units are exposed to increased health and safety risks compared
to those working in an office environment, which requires targeted interventions to enhance their protection. In addition, the
Company places particular emphasis on promoting equality, inclusion and equal opportunities for women, ensuring the
elimination of discrimination and the implementation of equal pay policies for work of equal value. These evaluations allow
targeted actions to be developed, alongside horizontal policies covering all human resources. [S1:SBM3_16] [S1:SBM3_AR_9]
Accordingly, the above tables illustrate the range of impacts in relation to corporate functions, and therefore the total number
of direct employees belonging to such functions. [S1:SBM3_14_b] [S1:SBM3_14_c] [S1:SBM3_14_d] [S1:SBM3_AR_44]
5. Annual Board of Directors Management Report
208
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
B. IMPACT, RISK & OPPORTUNITY MANAGEMENT
S1-1 – Policy on the management of material impacts on the workforce
METLEN is committed to developing and managing its human resources through policies and implementation processes that
promote an inclusive and respectful working environment, offering equal opportunities and respecting Human Rights. To achieve
this goal, the Company systematically reviews and revises its policies, and where necessary, creates new ones, ensuring the
proper management of identified material impacts from its business activity, with emphasis on mitigating negative impacts and
enhancing positive ones, thus contributing to sustainable development.
The undertaking is committed to fostering an inclusive and transparent work environment by actively engaging with its workforce
to uphold human rights and labor rights. This engagement is facilitated through structured dialogue mechanisms, employee
representation, and feedback processes that ensure concerns and perspectives are considered in decision-making. Regular
assessments and surveys help gauge employee satisfaction and identify areas for improvement, while training initiatives enhance
awareness of rights and responsibilities. By maintaining open communication channels and promoting a culture of mutual
respect, the undertaking reinforces its commitment to international human rights frameworks and strengthens trust within its
workforce. [S1:S1-1_20_b]
As part of its Human Rights Policy, which was renewed in 2024, the Company ensures the observance of high labor standards
and the protection of the rights of its employees. It follows the internationally accepted Principles of the UN Global Compact,
focusing on supporting working conditions and eliminating discrimination. In 2024, METLEN enriched its policies on labor
conditions management with the development of a Diversity, Equity and Inclusion Policy, underlining its commitment to
promoting equality and diversity and promoting a non-discriminatory environment in which all employees, regardless of gender,
nationality, age or other characteristics, have equal opportunities for development and success. METLEN has also established
Policy for Preventing and Combating Violence and Harassment at Work, which aims to create and consolidate an employment
environment that respects, promotes and safeguards human dignity and the right of every person to a work environment free
from violence and harassment. At the same time, the Company is in the process of drafting a separate Anti-Modern Slavery
Policy as a further form of its commitment to prevent, identify and address the risks associated with modern slavery in its
operations and supply chains, while in this direction a relevant statement (Modern Slavery Statement) of the Metals Sector was
published in 2024. [S1:S1-1_19] [S1:S1-1_AR_10]
At the same time, our Recruitment and Selection Policy ensures that the best and most suitable people are recruited based on
their merit, combined with METLEN's needs, without prejudice and/or discrimination. Accordingly, the Senior Management
Selection and Appointment Policy developed in 2024, aims to ensure that the selection of senior executives is carried out in a
transparent and merit-based manner, based on objective criteria. Also, in 2024, METLEN completed the reconfiguration of all its
procedures on remuneration and benefits, introducing the new Remuneration and Benefits policies such as the Salary
Adjustment Policy, the Short-Term Incentive Plan, the Health and Life Insurance Plans, the Pension Plan, etc. The aim is to attract
and retain talent in the organization, to recognize and reward the contribution of our employees and to support their well-being
through competitive performance-related pay and benefits packages offered based on meritocracy, fairness and transparency
across the population. [S1:S1-1_19] [S1:S1-1_AR_10]
Furthermore, with the Learning & Development Policy, the Company sets the framework for the support and development of
its employees to help enhance their skills, work experience, and performance, and with the Remote Working Policy, it offers
flexibility to its employees, improving work-life balance. In 2024, the Company developed its Candidate Experience Policy that
focuses on providing a positive experience for all candidates. Plans for 2025 include the introduction of the Performance
Management Policy. [S1:S1-1_19] [S1:S1-1_AR_10]
METLEN's Human Resources General Division is responsible for creating and implementing the management & development
framework for relevant policies and practices as well as providing professional support to Sectors in addressing human resources
issues. [S1:S1-1_19]
HUMAN RIGHTS POLICY [S1:S1-1_20]
5. Annual Board of Directors Management Report
209
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Year of update
2021
Key Content
[MDR-P_65_a]
This Policy:
1) expresses METLEN's zero tolerance for the violation of Human Rights that materializes both by the
Company's non-participation (direct, passive or tacit) in relevant violations, and by avoiding any transaction and
contact with third parties that may have caused or there are reasonable grounds to suspect that they may be
involved in creating conditions that may cause violations of such rights.
2) enhances awareness and ensures the commitment of METLEN's employees, suppliers and partners to
respect and protect Human Rights in all Sectors including its Subsidiaries.
3) contributes to the achievement of METLEN's overall Sustainability strategy by linking it to procedures
and policies governing the Company's broader business activities
Targeting
[MDR-P_65_b]
Through its Human Rights Policy, METLEN is committed to:
1) maintaining a working environment based on trust, dialogue and mutual respect and protecting the
well-being and work-life balance of its employees.
2) ensuring decent pay and working hours, based on applicable laws and industry standards on working
hours, overtime and leave, while overtime compensation is higher than that set by Greek law.
3) taking all necessary measures to avoid incidents and any direct or indirect involvement in any form of
forced or compulsory labor, trafficking in human beings (modern slavery)
120
, and child labor. [S1:S1-1_22]
4) providing equal opportunities while prohibiting discrimination and harassment. The corporate
procedures governing personnel recruitment, access to education and training, remuneration, performance
evaluation and termination are devoid of discrimination based on race, sex, colour, national or social origin,
religion, age, disability, sexual orientation and political opinion.
5) zero tolerance for offensive or inappropriate behaviour, unfair treatment or retaliation of any kind;
pursuant to the provisions of the Company's Code of Professional Ethics, any physical or verbal harassment of a
sexual, racist or defamatory nature is prohibited in the workplace and in any circumstance related to work
outside the workplace.
6) taking appropriate measures to eliminate all discrimination against women in employment, equal pay
for equal work, vocational education and training and decision-making processes.
7) respecting the fundamental right to freedom of association and the right to collective bargaining, in
accordance with the applicable national legislative framework and existing agreements, without fear of reprisals
or harassment. [S1: S1-1_20_a]
8) identifying, assessing, preventing and mitigating risks of human rights violations by applying due
diligence and corrective actions to address such incidents should they occur. [S1: S1-1_20_c]
Governance
[MDR-P_65_c]
Validated by the Executive Leadership Team and monitored by:
3) Sustainability Committee of the Board of Directors
4) Human Resources General Division
5) Corporate Governance & Sustainable General Division
6) Compliance Division
Policy Recipients
Direct employees, Indirect employees, Suppliers and partners including subcontractors of all METLEN BUs,
Subsidiaries and Central Functions.
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
[S1:S1-1_21]
6) United Nations Universal Declaration of Human Rights.
7) The Basic Conventions of the International Labor Organization (ILO).
8) The Principles of the UN Global Compact.
9) The Sustainable Development Goals (2030 Agenda).
10) The United Nations Guiding Principles on Business and Human Rights.
11) The Guidelines of the Organization for Economic Co-operation and Development (OECD).
12) The United Nations Convention on the Elimination of All Forms of Discrimination against Women
(Article 11 - field of employment). [S1:S1-1_21] [S1:S1-1_AR_12] [S1:S1-2_27_d] [S1:S1-1_AR_20] [S1:S1-2_20_b]
Availability
[MDR-P_65_f]
4) Corporate Website
121
,
5) Regular updates to the internal audience upon first publication and following any revisions.
6) Internal Information Portal (intranet).
POLICY AGAINST VIOLENCE & HARASSMENT AT THE WORKPLACE [S1:S1-1_24_a]
Year of update
2021
120
The Modern Slavery Act 2015 was passed by the British Parliament to tackle slavery. Forced labor and trafficking in human beings are crimes and violate basic
human rights.
121
https://www.metlengroup.com/media/rp3edd3u/politiki_anthrwpinwn_dikaiwmatwn_en.pdf
5. Annual Board of Directors Management Report
210
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Key Content
[MDR-P_65_a]
This Policy aims to prevent the occurrence and combat incidents of violence and harassment against METLEN
employees and other persons falling within its scope, as detailed below, during their employment at the
Company's premises, as well as at any place where they are located to perform their work or in connection with
it.
The Policy applies to any person referred to in para. 1 of article 3 of Law 4808/2021, namely the Company's
employees (under a dependent employment relationship of any form or term), lawyers with a salaried
mandate, associates and other professionals who offer services to the Company under a project contract or
independent services contract or under another legal relationship, to persons undergoing training, including
trainees, apprentices and volunteers, to those employed at the Company's premises through third-party service
providers, to employees whose employment relationship has been terminated, in case of incidents that
occurred during their employment, as well as to prospective employees. [S1:S1-1_24_b] [S1:S1-1_AR15] [S1:S1-
1_AR16]
Targeting
[MDR-P_65_b]
With this Policy, METLEN aims to create and consolidate an employment environment that respects, promotes
and safeguards human dignity and the right of every person to a work environment free from violence and
harassment. [S1:S1-1_20_c]
Incidents of violence and harassment falling within the scope of this Policy include all kinds of behaviours
against the above persons that are causally linked to the provision of their work and occur: a) within the
Company's premises, namely in the workplaces, in the break and personal hygiene areas, in any
accommodation, changing room or outdoor area of the Company's facilities, (b) when travelling to and from
work or to places of work-related events and social activities, during business trips or in the context of training;
(c) work-related communications, including those made by means of information and communication
technologies.
The above behaviours or incidents may occur vertically or horizontally in the Company’s hierarchy but also by
third parties, such as customers or service providers, and fall within the scope of this Policy, whether they occur
in the course of work, are connected with it or arise from it. [S1:S1-1_24_b] [S1:S1-1_AR15] [S1:S1-1_AR16]
Governance
[MDR-P_65_c]
1) Human Resources General Division
2) Compliance Division
Policy Recipients
Direct employees, Indirect employees, (under a dependent employment relationship of any form or term),
lawyers with a salaried mandate, associates and other professionals who offer services to the Company under a
project contract or independent services contract or under another legal relationship, persons undergoing
training, including trainees, apprentices and volunteers, employees at the Company's premises through third-
party service providers, employees whose employment relationship has been terminated, in the case of
incidents that occurred during their employment, as well as prospective employees.
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
[S1:S1-1_21]
1) Greek Law (Law 4808/2021) on the prevention and combatting of all forms of violence and
harassment, including gender-based violence and harassment as well as sexual harassment.
2) European General Data Protection Regulation (EU 2016/679) and Greek Law (Law 4624/2019).
Availability
[MDR-P_65_f]
1) Regular updates to the internal audience upon first publication and following any revisions.
2) Internal Information Portal (intranet).
LEARNING & DEVELOPMENT POLICY
Year of update
2022
Key Content
[MDR-P_65_a]
This Policy defines the criteria based on which the training needs of all employees are assessed and managed,
and training programs are planned and carried out.
Targeting
[MDR-P_65_b]
The Policy aims to ensure the continuous training of human resources for the benefit of their development and
progress, the improvement of their performance, the strengthening of their capabilities and the retention of
employees with exceptional skills that contribute directly to the achievement of the Company's strategic goals.
It is applicable to all employees, regardless of the form of work (full-time/part-time, indefinite/fixed term).
Governance
[MDR-P_65_c]
1) The Human Resources General Division is responsible for coordinating the seamless application and
for updating the Policy.
2) The Policy and any revised version thereof are approved by the Board of Directors upon the
recommendation of the Audit Committee.
Policy Recipients
Direct employees, Indirect employees.
5. Annual Board of Directors Management Report
211
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
The Policy is aligned with global best practices.
Availability
[MDR-P_65_f]
1) Regular updates to the internal audience upon first publication and following any revisions.
2) Internal Information Portal (intranet).
RECRUITMENT & SELECTION POLICY
Year of update
2024
Key Content
[MDR-P_65_a]
This Policy sets out guidelines for attracting and retaining talent to METLEN and its Subsidiaries and ensures the
proper placement and utilization of its People. The Policy applies to the recruitment and selection of employees
up to Director level (indefinite and fixed term) of the Central Functions (CF), the Sectors as well as their Segments.
It applies from the moment a position opens for recruitment until the moment the position is filled and
guarantees consistency in the recruitment process. The search, selection and appointment of senior management
is supported by a separate policy.
The Policy’s evaluation process aims to determine whether a candidate is suitable for the specific job, in terms of
academic background, work experience, relevant skills, competences and personality traits. [S1:S1-1_AR_17]
Targeting
[MDR-P_65_b]
The Policy aims to ensure that
1) the best and most suitable people are hired based on their merit, combined with METLEN's needs,
without prejudice and/or discrimination.
2) the recruitment and selection of salaried and/or freelance-based employees (hereinafter collectively
"employees") is carried out in a systematic, efficient and effective manner, while promoting best practices, taking
a proactive approach to equality and diversity issues and supporting METLEN's vision, mission and values.
Governance
[MDR-P_65_c]
1) Chairman and CEO
2) Executive Leadership Team
3) Human Resources General Division
Policy Recipients
Direct employees, external candidates
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
[S1:S1-1_21]
The Policy is aligned with global best practices.
Availability
[MDR-P_65_f]
1) Regular updates to the internal audience upon first publication and following any revisions.
2) Internal Information Portal (intranet).
SENIOR MANAGEMENT SELECTION AND APPOINTMENT POLICY
Year of compilation
2024
Key Content
[MDR-P_65_a]
The Senior Management Selection and Appointment Policy ("Policy") sets out the guidelines for the selection and
appointment of senior executives who contribute to achieving the corporate objectives of METLEN and its
Subsidiaries, ensures the proper placement and utilization of its People and has been approved by decision of the
Board of Directors and the Remuneration and Nominations Committee.
Targeting
[MDR-P_65_b]
The Policy aims to ensure that the best and most appropriate senior executives are selected on merit, combined
with METLEN's needs, without prejudice and/or discrimination. In addition, the Policy defines the framework for
effectively leveraging internal talent and for identifying and selecting senior executives from the market in order
to maintain and strengthen METLEN's competitive advantage and seamless and efficient business continuity.
Governance
[MDR-P_65_c]
The Central Human Resources Division is responsible for coordinating the Policy’s implementation, monitors its
effectiveness, evaluates it at regular intervals or when significant events or changes occur, and also amends the
Policy and reviews its design and implementation, where appropriate. The Policy and any revised version thereof
are approved by the METLEN Remuneration and Nominations Committee and the Board of Directors.
Policy Recipients
Direct Employees, external candidates
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
The Policy is aligned with global best practices.
Availability
[MDR-P_65_f]
1) Regular updates to the internal audience upon first publication and following any revisions.
2) Internal Information Portal (intranet).
5. Annual Board of Directors Management Report
212
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
CANDIDATE EXPERIENCE POLICY
Year of compilation
2024
Key Content
[MDR-P_65_a]
It sets out guidelines that will enable METLEN Energy & Metals and its Subsidiaries to offer a positive experience
to all candidates involved in the Recruitment and Selection Process, based on the principles of inclusion and
equality as well as respect.
Targeting
[MDR-P_65_b]
Ensure that the recruitment process offers a positive experience to all candidates, promotes support for
equality and inclusion in the personnel selection process and safeguards the Company’s image and reputation.
Governance
[MDR-P_65_c]
The Central Human Resources Division is responsible for coordinating the Policy’s implementation, monitors its
effectiveness, and evaluates it at regular intervals.
Policy Recipients
The Policy applies to all candidates participating in METLEN's recruitment process, including both external
candidates seeking job opportunities within the organization and internal candidates seeking new opportunities
for further advancement within the company.
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
The Policy is aligned with global best practices.
Availability
[MDR-P_65_f]
1) Regular updates to the internal audience upon first publication and following any revisions.
2) Internal Information Portal (intranet).
REMOTE WORK POLICY
Year of update
2023
Key Content
[MDR-P_65_a]
This Policy defines the remote working framework for METLEN, providing employees with the opportunity to
apply, on a voluntary basis, for remote working at intervals agreed and approved by the Company. It includes
provisions on the voluntary nature of remote working, transparency and equal rights, suitable jobs for remote
working, place of work, secrecy and confidentiality of information, Health and Safety, working hours and
availability, duration of remote work, rights and obligations of employees including the right to disconnect, IT
infrastructure, the necessary IT infrastructure and finally how to submit a request and the foreseen approval flow,
but also compliance with existing policies focusing on ensuring business continuity.
Targeting
[MDR-P_65_b]
The Policy aims to improve employee productivity and efficiency, reduce the environmental footprint of office
operations and employee commutes, attract and retain Human Resources, as well as contribute to work-life
balance. [S1_1_24_c]
Governance
[MDR-P_65_c]
1) Human Resources General Division.
2) Directors of each Sector or the Central Functions, as indicated in the organizational chart.
Policy Recipients
Direct employees
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
[S1:S1-1_21]
Greek Law (Law 4808/2021) - Incorporation of Directive (EU) 2019/1158 of the European Parliament and of the
Council of 20 June 2019 on work-life balance.
Availability
[MDR-P_65_f]
1) Corporate Website
122
,
2) Regular updates to the internal audience upon first publication and following any revisions.
3) Internal Information Portal (intranet).
DIVERSITY, EQUITY AND INCLUSION POLICY
Year of compilation
2024
Key Content
[MDR-P_65_a]
The Diversity, Equity and Inclusion Policy defines the concepts of Diversity, Equity and Inclusion, describes the
basic principles and requirements for their implementation in the Company's business activities, while
contributing to the Company's full compliance with applicable laws and regulations.
Targeting
[MDR-P_65_b]
Zero tolerance of discrimination, listing as possible grounds of discrimination the personal characteristics of a
person based on race, colour, gender, sexual orientation, gender identity, nationality, citizenship, religious or
other beliefs, disability or chronic disease, neurodiversity, marital or socioeconomic status, age, political beliefs
and any other characteristic that a person may classify into a specific minority or vulnerable group, defined by
specific characteristics. [S1:S1_1_24_a] [S1:S1-1_24_b] [S1:S1-1_24_c] [S1:S1-1_AR_15] [S1:S1-1_AR_16]
The company provides targeted training and a series of broader educational initiatives on the principles promoted
by the Policy. Middle and senior management executives participate in these trainings aimed to raise awareness
122
https://www.metlengroup.com/media/c2tbcia0/hr-policy-remote_work_policy.pdf
5. Annual Board of Directors Management Report
213
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
and strengthen skills to effectively prevent and address systematic and isolated discrimination. [S1:S1-1_AR_17_c]
[S1:S1-2_24_d]
Governance
[MDR-P_65_c]
Human Resources General Division [S1:S1-1_AR_17_b]
Policy Recipients
Direct employees, Indirect employees
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
[S1:S1-1_21]
1) The Basic Conventions of the International Labor Organization (ILO).
2) The United Nations (UN) Guiding Principles on Business and Human Rights.
3) The International Bill of Human Rights, including the Universal Declaration of Human Rights, the
International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and
Political Rights.
4) The ILO Declaration on Fundamental Rights and Principles at Work.
5) The Principles of the UN Global Compact, in particular Principle 6.
6) The 2030 Agenda and the Sustainable Development Goals (Goals 5, 8 and 10).
7) The UN Convention on the Elimination of All Forms of Discrimination against Women (Article 11 - field
of employment).
8) The UN Declaration on the Rights of Indigenous Peoples.
9) The ILO Convention on Indigenous and Tribal Peoples.
10) The UN Convention on Persons with Disabilities.
11) The Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational
Enterprises.
Availability
[MDR-P_65_f]
1) Regular updates to the internal audience upon first publication and following any revisions.
2) Internal Information Portal (intranet).
REMUNERATION AND BENEFITS POLICIES (IN THE CONTEXT OF THE BROADER STRATEGY)
Year of update
2024
Key Content
[MDR-P_65_a]
Ensure that employees' pay and benefits are fair and competitive, thereby promoting a work culture that supports
equality and recognition of each employee's value. In addition, the policy will incorporate monitoring and
evaluation mechanisms to ensure that pay reflects employee performance, skills and contribution, regardless of
gender or other differences.
Targeting
[MDR-P_65_b]
The Employee Remuneration and Benefits Policy sets out the principles for attracting, retaining and rewarding
METLEN employees and ensures the alignment of remuneration and benefits with market trends and employee
expectations. The Policy seeks to empower the Company's employees to perform at their best, thus promoting
collective success and ensuring the organization’s long-term sustainability. [S1:S1-1_AR_17_f]
Governance
[MDR-P_65_c]
1) The Rewards & Performance Division is responsible for the Policy’s development and evaluation on an
annual basis.
2) The Policy and any revised version thereof are approved by the Board of Directors upon
recommendation of the Audit Committee. [S1:S1-1_AR_17_b]
Policy Recipients
The Policy applies to all METLEN employees employed under an indefinite term dependent employment contract
and/or under a contract for the provision of independent services, provided that they fill a permanent position in
the organizational chart of each company.
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
[S1:S1-1_21]
The Policy is fully aligned with global best practices, thus ensuring efficiency, transparency and accountability in
all processes governing its operation. In addition, the strategies implemented aim to adapt to the ever-changing
conditions of the global labor market by ensuring the competitiveness of pay and benefits.
Availability
[MDR-P_65_f]
1) Regular updates to the internal audience upon first publication and following any revisions.
2) Internal Information Portal (intranet).
General approach on respect for human/labor rights
With the above-described powerful web of Policies, METLEN aims to safeguard industrial relations that promote mutual trust,
constructive cooperation, two-way communication and recognition, with its direct and indirect employees. At the same time, it
aims to promote the Declaration on Fundamental Principles and Rights at Work of the International Labor Organization, including:
a) respect for freedom of association and the effective recognition of the right to collective bargaining, b) elimination of all forms
of forced or compulsory labor, c) non-
5. Annual Board of Directors Management Report
214
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
participation in forms of child labor and d) elimination of discrimination at work.
Adherence to national and international labor standards is a non-negotiable commitment for METLEN, ensuring fair treatment,
equality and respect for all employees. This includes ensuring fair pay, reasonable working hours and creating a safe and inclusive
work environment, free from discrimination, violence and harassment. The Company continues to actively support diversity,
equal opportunities and gender equality. At the same time, it is committed to supporting the professional development of its
employees by offering training, upskilling opportunities and equitable development processes. METLEN's approach is based on
transparency and accountability, with regular review of its policies and procedures to continuously enhance its contribution to
achieving the Sustainable Development Goals. This commitment contributes to creating a positive and productive work
environment where respect for workers' rights is at the core. At the same time, given that most of METLEN's activity is in heavy
industry, the participation of women and young employees in employment (proportionally and always according to the
requirements of each field of activity) are two main issues for promoting equal opportunities and diversity in the Company's
working environment. [S1:S1-1_20_a] [S1:S1-1_27_d]
Health & Safety Management Policy
The Health and Safety of employees is a fundamental and primary business objective of METLEN's activity. It is a line of
responsibility that starts from Management and the General Divisions and reaches down to the production areas of all Sectors
and Subsidiaries of the Company. By acting responsibly, METLEN recognizes both its responsibility for the continuous
improvement of Health & Safety conditions in its workplace, as well as the right of its employees and employees of independent
partners and contractors who carry out work on its premises, to work without being exposed to risks that could cause an accident,
injury or occupational disease, as reflected in the Company's "Code of Conduct for Suppliers & Partners". [ESRS2: MDR-P_65_a] [ESRS2:
MDR-P_65_b] [S1:S1-1_19]
CENTRAL HEALTH & SAFETY POLICY [S1:S1-1_19]
Year of update
2024
Key Content
[MDR-P_65_a]
The Policy includes management's commitment to ensuring the well-being of employees and to creating a
safe working environment through full compliance with legislation and international standards.
Targeting
[MDR-P_65_b]
The Policy’s main objectives include the identification and assessment of occupational risks, the
implementation of measures to mitigate them, as well as the establishment of quantitative and qualitative
targets for the continuous improvement of working conditions. The Policy prioritizes prevention by drawing
up action plans to improve working conditions and taking preventive and corrective measures in case of
accidents. In addition, it integrates health and safety principles into critical corporate processes, such as
procurement and mergers, while promoting continuous training and awareness among employees and
partners. Regarding the material impacts, with this Policy, the Company aims to reduce accidents and
protect staff from harmful factors, creating a culture of safety. Risks associated with this Policy’s
implementation include failure to comply with regulations or loss of productivity due to accidents, while
opportunities include improving the Company's reputation and enhancing productivity through safer
working conditions.
Governance
[MDR-P_65_c]
a) Approved by the Company's Sustainable Development Committee,
b) Prepared and revised by the Company’s Corporate Governance and Sustainable Development General
Division in cooperation with the General Divisions of its Sectors, which are also responsible for its
implementation.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
a) International Standard ISO 45001:2018
b) Sustainable Development Goals (3,8,17) [S1:S1-1_21]
c) Performance Standard-Aluminium Stewardship Initiative
Inclusion of Stakeholder
Interests
[MDR-P_65_e]
Annual Stakeholder Consultation [S1:S1-1_20_b]
Availability
[MDR-P_65_f]
Corporate website
123
and internal communication network (intranet). It is available to all Stakeholder
groups through the Company’s official website, is communicated to all employees via email and is posted
in common areas of the facilities accessible to direct and permanent indirect employees and is inspected
for completeness by external bodies during inspections.
123
https://www.metlengroup.com/media/salhuebp/occupational-health-safety-policy.pdf
5. Annual Board of Directors Management Report
215
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Implementation of the Policy also serves respecting the principles of important initiatives in which the Company participates or
has committed to observe, such as: [ESRS2: MDR-P_65_d]
1) The UN Global Compact: METLEN's Health and Safety Policy is directly linked to the Principles of the United Nations Global
Compact (UNGC), promoting human rights protection, equality and safe work.
2) The UN Sustainable Development Goals (SDGs): METLEN's Health and Safety Policy, committed to safe working conditions
and accident prevention, promotes good health and well-being (SDG 3). At the same time, by supporting safe, fair and
productive workplaces, it contributes to decent work and economic growth (SDG 8).
3) Strict compliance and implementation of the current national and European legislative framework and other regulatory
provisions related to Occupational Health & Safety in all Sectors. Ensuring harmonization of the operation of the
Company's Sectors with the relevant legislation is achieved with the introduction of much stricter limits by the Company,
and through the relevant programs and management systems it implements.
4) The integrated and certified Occupational Health and Safety Management System: METLEN's Health and Safety Policy is
in line with the principles of international standard ISO 45001:2018, as it promotes the assurance of a safe and healthy
working environment through hazard identification, prevention of accidents and occupational diseases, continuous
training of employees, and continuous improvement of management systems. The YAE system, at the end of 2024, covers
98.9% (2023: 96.4%) of the total relevant workforce employed in the Company's industrial and renewable energy plants
in normal operation. Each unit of the Company has a OHS Coordinator who is directly employed by the Company and is
responsible for the proper operation of the system. At the same time, the guidelines provided by expert external
consultants specializing in OSH systems (ISO45001), contribute to the continuous improvement of the systems. The OHS
system covers all direct and indirect employees of the Sectors and subsidiaries where a certified system according to ISO
45001: 2018 is applied. In addition, 98.9% of employees are covered by an OSH system, which is subject to internal audit,
while more than 82.8% of employees are covered by an OSH system audited or certified by an independent body.
At the same time, to support the Policy’s implementation, METLEN has an Incident Investigation Procedure, available on in the
Company's internal network (Intranet) and accessible to all employees of the Company.
S1-2
Processes for engaging with own workers and workers’ representatives about impacts
METLEN maintains long-standing practices of communication and cooperation with its employees, aiming to ensure their trust
and enhance transparency in labor relations. Through engagement surveys, established procedures, and open communication
channels, the Company seeks the active participation of its employees in actions and activities, ensuring an environment where
employee needs are recognized and considered when shaping corporate strategy.
Long-standing ways of communication & collaboration
METLEN works directly with its employees in a variety of ways, seeking to understand and respond to their needs, enhancing
their levels of trust in the Company, while ensuring its "social" license to operate. The long-standing ways of communicating and
cooperating with its employees are the following:
1) Annual Stakeholder Consultation.
2) Procedure for defining Material Sustainable Development aspects (annual update)
3) Annual established procedure for evaluating the performance and skills of employees.
4) Open daily communication of all employees with the Human Resources General Division via the HR-Business Partner in each
Sector/Subsidiary/CF of the Company.
5) Continuing education and training.
6) Communication of policies as needed.
7) Regular and extraordinary meetings between management and employees (annual Leadership Days, annual Management
meetings with employees in groups of 25 people).
8) Annual disclosures of Sustainable Development information.
9) Announcements through internal digital platforms (Intranet).
10)HR Call Center.
11)Employee engagement surveys and satisfaction surveys. [S1:S1-2_27_a] [S1:S1-2_27_b] [S1:S1-2_AR_19]
5. Annual Board of Directors Management Report
216
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Approach to considering employee interests
METLEN's approach to considering employee interests follows a process that includes consulting and analyzing stakeholder needs
at every decision-making stage that affects human resources. Specifically, each policy created by each competent team is initially
submitted for review and comments to the leaders of the Human Resources Leadership Team (HRLT) and to the Human Resources
Business Partners (HRBPs) of the Sectors / Subsidiaries / Central Functions. After the incorporation of their comments, the
Consultation stage of Policies and Procedures follows, through which information, participation, transparency and improvement
of policies and procedures under development or revision are ensured, utilizing the knowledge and expertise of participants.
Upon completion of the final draft of a Policy/Procedure, it is notified to the Group Enterprise Risk & Internal Controls, Senior
Director, for the initiation of the consultation process to inform the Company's stakeholders about the upcoming
additions/revisions in the context of Policies & Procedures. The Group Enterprise Risk & Internal Controls Senior Director and the
ERM & IC team then review the file for consistency with the principles of the Policy/Procedure Development and Review Process,
and as long as there are no significant deviations, the draft is posted on the Digital Consultation App - Power Apps, where
participants can review it, ask questions, or suggest improvements. Following the consultation, the Policy/Process Owner collects
and incorporates any necessary changes or informs participants by notifying the ERM & IC team.
Upon completion of the consultation, the Policy Owner or the Process Owner collects the comments / suggestions from the
participants and adjusts the Policy / Procedure, if necessary - otherwise they inform the participants who made comments or
suggestions by notifying the Group Enterprise Risk & Internal Controls Senior Director and the ERM & IC team. The participants
in the consultation of the Policies and Procedures are appointed by the Heads of each Sector or CF. Access rights are evaluated
on an annual basis by the Group Enterprise Risk & Internal Controls Senior Director and the ERM & IC team in cooperation with
the Heads of each CF or Sector.
In addition, the Employees' Union plays a central role in consultation to ensure employee representation. Tools such as the
Employee Engagement Survey and the Employee Satisfaction Survey on diversity, equal opportunities and inclusion are also used
to analyze the priorities of all employees, in an inclusive manner, and these results are incorporated into future policy reviews,
such as the Diversity Policy, which is adjusted based on the employees’ self-identified priorities. [S1:S1_2_27_a] [S1:S1_2_27_b]
[S1:S1_2_27_c] [S1:S1-2_AR_19] [S1:S1-2_AR_19] [S1:S1_2_28]
Employee Engagement Survey
In 2023, a Company-wide Employee Engagement Survey was implemented for the first time, involving 80% of its global
population. The results of the Survey highlight issues of concern for the Company's employees, constituting a management
priority. The results of the survey feed into the Impact Materiality assessment implemented in 2024 in accordance with the ESRS
Standards of the CSRD Directive. Completion of the employee engagement survey was followed by an initial analysis of the results
and specific direct proposals were formulated by the organization’s broader management team, which were then disseminated
to the individual teams with the aim of enhancing transparency. To ensure an effective and targeted implementation of the
proposals and their evolution into concrete actions, a two-pronged approach was followed, which started in May 2024, including:
A. The creation of an interdepartmental team to translate findings into applicable actions, consisting of representatives of
all Sectors and teams of the Company, resulting in specific action plans for the entire Company. Different actions were
divided into pillars and assigned to different managers, members of the executive Directors’ leadership team (Chiefs) from
Sectors / Subsidiaries / Central Functions, who assumed the role of Sponsor, highlighting the commitment at senior
management level, while the project team was always the Human Resources Division. The action plan focuses on, among
other things, improving the working environment and facilities, strengthening team management and creating a formal
wellbeing program. Some actions started in 2024, such as the launch of a formal welfare program, while others, such as
the 360 evaluations, are planned to start in 2025. [S1:S1-2_27] [S1:S1-2_AR_21] [S1:S1-2_AR_23] [S1:S1-2_AR_24]
B. Evaluation by the Chiefs of Sectors / Subsidiaries / Central Functions of their own results per department, to create their
own action plan that responds to their own specific needs and priorities. These individual actions are monitored by the
team itself, while HR Business Partners hold regular meetings with the executive directors to monitor effective
implementation. [S1:S1-2_27_a] [S1:S1-2_27_b] [S1:S1-2_27_c]
To assess the effectiveness of the engagement, some Company departments conducted brief pulse surveys aimed at evaluating
progress on engagement in the interim time between the first implementation and the next. Similarly, the Employee Engagement
Survey includes questions about the extent to which employees feel that management is seeking feedback and that they are
responding to their suggestions. [S1:S1-2_27_e] [S1:S1-2_25_d]
5. Annual Board of Directors Management Report
217
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The above procedures ensure the inclusion of all Company employees, through their participation in the main central employee
satisfaction survey, in the individual surveys carried out at department level as well as in the application and implementation of
actions as recipients of the results. Surveys cover all jobs at METLEN, and particular care is taken to ensure the participation of
all employees. Employees with access to a computer take part in the surveys digitally, while for field workers, a mechanism has
been set up for anonymous and confidential participation using computer stations.
The Human Resources General Division is responsible for implementing and coordinating surveys as a central tool for consulting
METLEN’s own workforce, and the results obtained and the conclusions drawn are presented to the Company’s Chairman and
CEO, to get his approval on the implementation of relevant continuous improvement actions.
[S1:S1_2_27_c] [S1:S1-2_AR_18] [S1:S1-2_AR_19] [S1:S1-5_47_c]
Human Rights Self-Assessment
METLEN is committed to the first 6 Principles of the UN Global Compact, which are based, inter alia, on the internationally
recognized principles on the protection of Human Rights, as set out in the International Declaration of Human Rights (UDHR). By
observing the Principles, the Company is committed through its Human Rights Policy to the respect and protection of all
categories of Human Rights, including Occupational Health & Safety, Adequate Working Conditions, Child Labor, Forced Labor &
Human Trafficking, Equal Opportunities, Freedom of Association. [S1:S1-2_27_d]
Also, in order to be able to investigate various aspects of Human Rights in all industries, sectors and countries of operation,
METLEN has been applying a Human Rights self-assessment approach for the past five years by adopting the internationally
accepted Human Rights Self-Assessment Tool of the UN Global Compact. The aim of the self-assessment is to provide feedback
on specific topics and to highlight areas that may require further investigation, however so far, no new areas have been identified
through this process. The main areas of investigation in 2024 include: "working hours, wages and leave", "equal treatment",
"forced labor", "child labor", "discrimination" and "freedom of association". [S1:S1-2_A R_25_e]
Trade Unions and Functional Organizational Units
All METLEN employees in the Metals Sector may, without restriction, join trade unions and professional associations, where these
exist. In this context, the Company ensures free access for candidates during the pre-election period and support to the trade
union leadership for the exercise of their trade union rights, ensuring secure employment. At the same time, scheduled annual
meetings are held, at the least, and additional intermediate meetings and/or consultations for briefing unions on internal
rearrangements, projects undertaken, how the plant is doing, and also in extraordinary circumstances such as extreme weather
events. [S1:S1-2_27_e]
At the same time, several Functional Organizational Units (FOUs) operate, which consist of all employees from a specific
department or team. FOUs meet at least once every month and operate autonomously to solve problems and improve working
conditions in general. The findings and their work are communicated by the heads of departments, who can present their work
to the Company’s Management. Using an online platform, each department or team records its progress, while KPIs are
monitored, and FOU proposals are presented as a whole. Access to the platform is also available to other executives of the
company outside the departments and FOU teams. [S1:S1-2_27_e] [S1:S1-2_25_c]
The responsibility for cooperation with employees and employee representatives throughout the Sector lies with the respective
Executive Director (Chief) of the Sector, ensuring the participation of all employees through established procedures without
exceptions. Effectiveness is evaluated directly through the Employee Engagement Survey and indirectly through the continuous
preservation of industrial peace, the seamless operation of factories and the maintenance of a good working climate. [S1:S1-2_28]
[S1:S1-2_A R_18] [S1:S1-2_A R_19] [S1:S1-5_47_c]
Women in Industry
In 2023, the "Women in Industry" workshop was conducted with the participation of 92 women working in the field in both the
Metals and Energy Sectors. The lively interactive discussions highlighted specific issues to be further explored and proposals that
led to the planning of actions, such as practical improvements to the facilities of the Aluminium of Greece plant that were
completed in 2024. Further actions are planned for 2025, such as online workshops on important topics including wellbeing, and
the creation of an online platform for internal communication, networking and interaction for these women. This action is an
example of steps that have been initiated to meaningfully understand the views of employees who may be particularly vulnerable
to the effects of the activity itself. [S1:S1-2_A R_25_a]
Occupational Health & Safety (OHS)
5. Annual Board of Directors Management Report
218
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN follows multi-level processes of cooperation with its direct employees and their representatives to address
Occupational Health and Safety issues. These practices are implemented in different company facilities, including factories and
mining activities, and enhance the active participation of employees in the management of Health and Safety issues. Below is a
brief description of these key Procedures:
A. Health and Safety Committees and Working Groups
The committees and working groups at METLEN act as collective bodies representing employees, ensuring their active
participation in health and safety procedures, and play a key role in managing and promoting workplace safety. They are
coordinating bodies that strengthen cooperation between employees and management, with the aim of developing and
implementing policies and measures to promote safety in the workplace. At the same time, they act as consultation bodies,
collecting opinions and formulating joint proposals that contribute to the continuous improvement of working conditions, thus
enhancing the safety and ultimately the well-being of staff. In particular:
1) In the Metals Sector and specifically in the primary aluminium production plant, there is an Employee Health and Safety
Committee (EHSC), which consists of six members elected by the employees, representing 100% of the staff. Members
participate in basic health and safety procedures, such as "Green light Committees" for new projects and major
conversions, accident analyses using the "Tree of Causes" method, and Working Groups on Occupational Risk Assessment.
In addition, there are additional safety committees coordinated by managers, with representatives from all plant
departments participating in them on specific issues, such as the Work-at-Height Committee, the Lockout/Tagout and
Confined Spaces Committee, the Circulation Committee and the Contracting Committee, ensuring continuous
participation of employees of all levels to enhance safety culture. Also, the Metals Sector participates in the quarterly
Corporate HSE Meeting.
2) At the Metals Sector’s secondary cast aluminium plant (EPALME), meetings on the identification and analysis of OSH
issues in order to make decisions and resolve related issues are coordinated by a senior team of executives including the
Plant Manager, the Deputy Manager, the Head of H&S and the Head of Quality & Logistics).
3) In the Metals Sector’s bauxite mining activities, there is a Health and Safety Committee, consisting of three members
elected by the employees themselves, which represents all employees, and regular consultation and dialogue meetings
are held through the Workers' Union.
4) In the Metals Sector’s steel structure works (Volos plant), the H&S Committee is appointed by the employees, who may
also submit requests related to Health and Safety through this Committee. Furthermore, in accordance with National
Legislation and European Regulations, instructions are provided and health and safety signs are posted in all workplaces
conforming to ISO 45001:2018, as well as the Occupational Risk Assessment Design.
5) In the Energy Sector, there is an Occupational Health and Safety team consisting of 11 members who monitor Health and
Safety issues in all five segments of the Energy Sector. Its responsibilities include communicating with management on
OSH issues, finding solutions to safety issues, organizing actions to raise awareness among colleagues, as well as evaluating
and communicating health and safety-related targets (KPIs). The team also promotes the dissemination of good practices
and lessons learnt to and from the Company's local facilities, while monitoring the relevant legislation. Respectively, each
branch abroad has its own Health and Safety (H&S) department that monitors all H&S issues in that country’s activity and
informs the Energy Sector’s central H&S team. Moreover, Health and Safety teams are set up in all construction sites and
plants of the Energy Sector, by specially trained personnel who daily check the compliance of activities on H&S issues and
report to the facility’s management (construction site or plant) as well as to the Energy Sector’s central H&S team.
Moreover, the Energy Sector participates in quarterly internal consultation meetings held at Group level (Corporate HSE
Meeting).
6) Subsidiary METKA, which operates in infrastructure construction projects, operates a five-member Occupational Health
and Safety Team (OHST). The team is responsible for handling Occupational Health and Safety (OHS) issues and maintains
open communication with Management, proposes solutions to address safety issues, organizes awareness actions for
employees and selects and evaluates the OHS-related targets (KPIs). At the same time, it disseminates good practices and
promotes "Lessons Learnt" among the company's construction sites. The OHST meets every three months to decide on
actions aimed at continuously improving safety conditions, thus ensuring compliance with procedures and achieving
better safety levels in the workplace. In addition, the Subsidiary participates in quarterly internal consultation meetings
held at Group level (Corporate HSE Meetings). [S1:S1-2_27_a] [S1:S1-2_27_b] [S1:S1-2_AR_19]
5. Annual Board of Directors Management Report
219
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
B. Consultation and analysis procedures with employee participation
Quarterly Corporate HSE Meetings are organized at Company level, focusing on the exchange of views on important health and
safety issues, as well as the exchange of best practices. Representatives of all Sectors and Subsidiaries participate in the meetings.
Furthermore:
1) At the primary aluminium plant, communication, dialogue and participation actions aim at applying health and safety in
practice, and at the same time are tools for the gradual consolidation and improvement of the "safety culture".
2) The secondary cast aluminium plant organizes a biannual meeting between the employees' representative and the
company's management to highlight and analyze Health and Safety issues and take collective decisions to resolve them.
3) In bauxite mining activities, the right of employees to voice comments, suggestions and opinions (anonymously or not)
on procedures (Code of Ethics, Policies, Administrative Practices) is guaranteed. At the same time, the main OSH
procedures and instructions are posted on each construction site, and regular consultation and dialogue meetings are
held through the Workers' Union.
4) In the Energy Sector, Health and Safety executives, Technical Staff and Safety Coordinators consult with employees, within
the framework of the OHS Management System. Especially in the Company's Energy Centres, the consultation process on
OHS issues is implemented at scheduled intervals and at least twice a year with the active participation of their staff,
within the framework of the OHS Management System, with the aim of promoting the implementation of the Company's
current OSH Policy, communicating OSH actions and programs and involving and engaging employees in consultations on
occupational risk management. [S1:S1-2_27_a] [S1:S1-2_27_b] [S1:S1-2_AR_19]
C. OHS reporting channels available
METLEN offers various channels for reporting health and safety-related issues. The channels have common access and structure
for all Sectors and Subsidiaries. These include digital platforms for instant reporting of issues, sending anonymous messages via
a dedicated email address and the ability to send letters or meet with the Compliance Director. This way, full coverage of health
and safety needs is ensured with transparency and constant communication. [S1:S1-3_32_b] [S1:S1-3_AR_28]
In addition, in the Metals Sector there is the possibility of an open reporting channel via the EHSC, the safety engineer and the
various committees.
In Subsidiary METKA, which operates in infrastructure construction projects, all employees have the opportunity to express their
opinion on OHS issues by informing the Site Manager, the Site Safety Engineer, the Safety Coordinator, or their Supervising
Engineer. They can also request to participate in OHST meetings. [S1:S1_2_27_c] [S1:S1-2_AR_18] [S1:S1-3_AR_19]
D. Continuous communication for OHS risk management
In the Metals Sector, employees of all hierarchy levels are the key actors of a continuous, systematic and methodical process,
whereby they participate in the development of safety rules through the implementation of targeted initiatives/tools such as
those of "Confident Professional Movement", "Confident Professional Conduct", "Hierarchy Safety Visits", "Risk Identification"
and "Personal Safety Actions".
In bauxite mining activities (on underground works), communication between supervisors (foremen, engineers) and workers is
a daily and key element in identifying and addressing risks. Special instructions are recorded in the construction site instructions
book and discussed in safety meetings twice a month. [S1:S1-2_27] [S1:S1-2_AR_21] [S1:S1-2_AR_23] [S1:S1-2_AR_24]
In the Energy Sector, regular meetings with employees are held in every facility to discuss all Health & Safety-related issues of
concern to them and to voice remarks, complaints or suggestions to improve existing situations or practices. All issues are
reviewed and action is taken. There is also constant cooperation of Safety Engineers and Occupational Physicians with the
respective H&S teams on issues related to the safety, security and health of employees.
At Subsidiary METKA, all employees have the opportunity to express their opinion on OSH issues in daily meetings with their
Supervising Engineer, and/or during induction trainings by the Safety Engineer or the Site Safety Coordinator. Also, the Company's
Policy provides for the right to withdraw from a specific job that potentially poses a serious risk.
5. Annual Board of Directors Management Report
220
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
S1-3
Processes to remediate negative impacts and channels for own workers to raise concerns
METLEN understands the importance of continuous monitoring of working conditions and the development of measures that
promote fair treatment and equal opportunities. To this end, the Company is committed to creating and strengthening a
comprehensive framework of policies, procedures and actions that will enable it to address these challenges. The introduction
of channels for staff to voice their concerns promotes the continuous development and improvement of the working environment
to ensure a fair and equal system for all its employees. Below is detailed information on the initiatives developed in this direction.
[S1:S1-3_32_a] [S1:S1-3_AR_27]
Channels for Submitting Workforce Concerns and Needs
METLEN encourages the use of available corporate (internal) reporting channels published on the Company's website
124
and
which may be used by any employee and supplier employee to ensure timely monitoring and appropriate notification of
Management of violations related to data protection, bribery and corruption, human rights including violence and harassment
at work, as well as violations of the code of professional ethics. [S1:S1-3_32_b] [S1:S1-3_AR_28]
The channels created for reporting are available a) through the Whistleblowing platform: https://metlen.ethics.help/web/en and
b) by email to: metlen[at]ethics.email providing an anonymous link to the above electronic Whistleblowing platform, without
revealing the whistleblower’s email address, and c) through a personal meeting with the Compliance Director. In the context of
the above, METLEN ensures the protection of individuals using reporting mechanisms by ensuring, with the Policy, that they do
not suffer any retaliation for participating in the process. [S1:S1-3_33] [S1:S1-3_AR_31]
The Company takes all appropriate technical and organizational measures to ensure the Protection of Personal Data, the privacy
and protection of individuals from any form of retaliation under the terms of Greek laws 4990/2022 and 4808/2021. Moreover,
through its website, the Company informs that the reporting process should not be misused for unfounded accusations or
personal complaints. To prevent malicious or unsubstantiated reports, employees who acted in bad faith may be sanctioned.
Also, in similar cases, the law on defamation is applicable in the countries where the Company operates.
Furthermore, in the context of Human Resources Policies, the reporting process includes a variety of communication channels,
such as telephone contact or email communication (anonymous or not) at compliance[at]metlengroup.com. with the Compliance
Director, sending a fax or a letter by post to METLEN Energy & Metals S.A. Artemidos 8, 151 25 Maroussi, to the attention of the
Compliance Director. The process begins with the recording the complaint, followed by an investigation of the seriousness of the
matter and the complainant is then informed. A detailed investigation is then carried out and the findings are issued. If necessary,
disciplinary measures are imposed. [S1:S1-3_32_b] [S1:S1-3_32_c] [S1:S1-3_AR_28] [S1:S1-3_32_d] [S1:S1-3_32_e] [S1:S1-3_AR_32]
Assessment of Awareness and Trust in the Formats for Submitting Concerns
One of the ways to assess the level of the employees’ awareness and trust towards the structures for submitting complaints is th
e Employee Engagement Survey. The participation rate of 80% of direct employees when the survey was first conducted shows
the value they attach to this feedback process. After the second Survey is conducted, scheduled for 2025, the participation rates
between the two will be compared to provide data on their trust in this format. [S1:S1-3_33] [S1:S1-3_AR 3]
In addition, the role of Human Resources Managers in all Sectors and Subsidiaries, as well as in the Company's Central Functions
(HR-Business Partners – HRBPs) is described in the Labor Relations Policy as having the responsibility for the effective handling
of complaints and in cooperation with the Human Resources Operations Department has the ultimate responsibility for resolving
issues of conflicts of interest, compliance with the provisions of the Labor Regulation and the Code Professional Ethics of the
Company, including the management of disciplinary penalties, where required. [S1:S1-3_32_c]
Furthermore, to ensure the internal management and systematic monitoring of sustainable development issues related to
employees, a corporate digital application called "METLEN ESG Repository" has been developed to monitor the implementation
of actions and activities intended to mitigate identified risks and leverage opportunities arising in relation to sustainable
development. The platform reflects the Company's responsiveness, the relevant timing, as well as the individual actions that
124
https://www.metlengroup.com/who-we-are/governance/compliance/
5. Annual Board of Directors Management Report
221
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
need to be implemented, and also serves the cooperation between executives from different departments of the Human
Resources Division and the Sustainable Development Division. [S1:S1-3_32_e] [S1:S1-3_AR_32]
At the same time, in the Metals Sector, the ESHC operates as the main complaint/complaint management mechanism on H&S
issues within plants and mines, with direct communication of employees with the committee as well as with the plant's Safety
Engineer. [S1:S1-3_32_a] [S1:S1-3_AR_27] [S1:S1-3_32_b] [S1:S1-3_AR_28]
Approach to remediate the negative impacts of Occupational Health and Safety
METLEN has taken the following actions to remediate the negative impacts associated with its operations.
a) Implementation of preventive actions as a prerequisite for achieving continuous progress and improvement, in line with
the broader experiences gained by the Company from each incident and near miss that it analyzes, along with continuous
education and training of staff as a decisive factor for maintaining and further developing the accident prevention culture.
b) Risk identification using safety tools to prevent dangerous actions and situations that could lead to accidents or
occupational diseases, as described in a series of internal procedures in each Sector for both direct and indirect employees
and partners. Examples include: Hierarchy Safety Visits, Risk Identification and HESP Inspections of indirect employees
(Health and Environmental Safety Plans), a Written Occupational Risk Assessment prepared in accordance with the
corresponding procedure and available for each job, the Energy Centre Risk Management and the RES Plants Work
Instructions.
c) Reporting of risks and hazardous situations through the risk reporting process and the risk identification process, as well
as through the reporting system of the Company's Code of Business Conduct.
d) Investigation of work-related accidents, where procedures are followed to record them in the accidents log, procedures
for announcing and analyzing incidents, procedures for characterizing and investigating incidents, and, at a higher level,
incidents are selected to be analyzed using a tree of causes. [MDR_A_68_d]
e) Determination of appropriate corrective actions based on the above investigation process, to identify the required
improvements to the OSH management system.
S1-4
Actions and resources
Key Actions for Material Risk Management
[S1:S1_4_37] [S1:S1_4_38_a] [S1:S1_4_AR_42] [S1:S1_4_38_ b]
In 2024, METLEN developed the following measures on fair treatment and equal opportunities, with the aim of substantially
mitigating the actual negative impacts on diversity, equal opportunities and inclusion in the workplace. [S1:S1_4_40_a]
[S1:S1_4_AR_44] [S1:S1_4_AR_45] [S1:S1_4_AR_47]
a) Employee Pulse Survey: In November and December 2024, the Company conducted a Pulse Survey to assess its maturity
in diversity, equal opportunities and inclusion. This survey covered a representative sample of employees from all
sectors, subsidiaries and central services in the countries where the company operates, and its results guide the planning
of future actions. The survey includes questions across a range of diversity dimensions, including both gender and
disability. This research also contributes to the mapping of the existence of any vulnerable groups within the Company's
human resources, as METLEN recognizes the need to respond to specific needs that may arise for groups of employees
and thus has set this mapping as a first step, so that it can then put in place specific actions or procedures to support
them if necessary. [S1:S1-1_24_c]
b) Training & awareness-raising: The Company has created an e-learning course on "Diversity & Inclusion: A Workplace
for All", which became available as part of the New Employee Onboarding Program in November 2024. It is addressed
to all new employees of the Company, in order to ensure that everyone has basic knowledge and respect for the
Company's Principles. The aim of the training course is also to become aware of unconscious biases, but also to train
them in the use of tools to deal with them. At the same time, the Lead Me Leadership Academy has Inclusive Leadership
as its first theme, giving participants access to online materials, discussion circles and interactive workshops in order to
gain fundamental knowledge about Diversity & Inclusion, receiving at the end a separate certificate from Harvard for
this topic.
5. Annual Board of Directors Management Report
222
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
c) Cooperation with other companies: At the same time, emphasis is placed on cooperation and exchange of good
practices with executives of other companies in the market. In this context, the Company's executives participate in
working groups focusing on specific aspects of diversity, such as the "Target Gender Equality Accelerator" program
implemented by the Global Compact Network Greece of the UN Global Compact. in which two employees of the
Company participated in the cycle that began in September 2024 and will end in March 2025, along with executives from
18 other companies, but also in events focusing on these topics.
d) Diversity toolkit for human resources executives (HRBPs): In December 2024, the design and creation of an "HRBP
Diversity toolkit" with practical guidelines and advice for Human Rights Business Partners (HRBPs) on different
dimensions of diversity such as gender and intercultural differences began to be used as reference material for their
daily interactions. The design of a series of bite-size trainings for HRBPs has also begun to gain an in-depth understanding
of the different issues that arise in working with teams. The completion of the guide is expected in the first half of 2025.
Furthermore, METLEN has taken concrete actions to enhance gender equality and equal pay for work of equal value. Key
initiatives include:
a) Empowering women: The "MPower Initiative" focusing on gender equality and women's empowerment was launched in
2023 with an interactive workshop with the participation of 92 women working in industry, specifically in the Metals
Sector. The workshop highlighted specific challenges and proposals for improvement, which formed the basis for
subsequent actions, such as investing in material improvements to the facilities of the Aluminium of Greece plant in 2024,
but also for planning further actions in 2025, such as the creation of an online networking platform for the participating
women and the implementation of workshops on topics that emerged as important for the empowerment of this group.
b) Equal pay for work of equal value: On an annual basis, an analysis and evaluation of salary bands is carried out in order
to identify areas that need corrective action in the short and long term to fully balance pay and eliminate the gap between
men and women. The goal of this study is to create an action plan by the end of 2024.
c) Job model: The "METLEN Job Model (MJM)" was developed and implemented horizontally across all Sectors, Subsidiaries
and Central Functions in 2024. The new model is the key infrastructure for organizational planning used in the evaluation
and categorization of jobs in the Company. The aim is to establish a clear framework for determining the size and nature
of jobs across the Company, to which most HR policies will gradually be linked. One of MJM's objectives is to ensure
fairness and equality, as the new model ensures a more transparent and objective framework that evaluates and rewards
employees based on their contribution, skills and responsibilities. This will also contribute to gender pay equality given
the consistency and clarity in each role, and the clear and unambiguous matching of each hierarchy level to a specific pay
scale, both in terms of remuneration and additional benefits.
d) Performance management: METLEN plans to start the process of managing the performance of its employees through
the integrated digital information system "METLEN Success Factors" in 2025, so that all employees have a clear picture of
both the evaluation criteria and the different stages of evaluation. This approach is expected to contribute decisively to
the enhancement of equality, regarding the opportunities for growth and advancement that the Company provides to its
employees, based on objective and clear criteria. The implementation of the process will also contribute to a holistic
monitoring of performance in a standardized, consistent and fair manner. Already in 2024, a training cycle was organized
for all Company executives responsible for managing employees (People Managers), with the aim of familiarizing and
learning how to use the new tool, as well as developing skills to provide constructive feedback. For 2025, the creation of
supporting materials is planned to facilitate the implementation of the performance management process and use of the
tool, ensuring that all employees have access to the necessary information and instructions.
METLEN has also undertaken important initiatives on the employment and inclusion dimension of people with disabilities, which
include:
a) Registration of persons with disabilities with the electronic employee database.
b) Enhancing digital accessibility with actions such as adding subtitles to educational materials.
c) Information on accessibility using the Global Induction Kit that all new employees receive.
d) Creation of a new Candidate Experience Assurance Policy promoting accessibility for all candidates overall, ensuring
equal opportunities regardless of any form of disability.
In order to effectively manage and monitor working conditions [S1_4_38_a] [S1:S1-4_AR_42] [S1:S1_4_38_b], METLEN has adopted
specific actions to combat violence and harassment including:
a) Design of training programs on combating violence and harassment, to be implemented in 2024, in Metals in Greece and
in Energy in Chile.
b) Public availability of the Whistleblowing channel through the corporate website which can be used for violence and
harassment-related complaints, by any employee associated with the Company under any form of existing, past or
potential employment relationship, as well as by any other person working under the supervision and guidance of
5. Annual Board of Directors Management Report
223
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
contractors, subcontractors and suppliers of METLEN Energy & Metals S.A.
Moreover, the Company has taken measures and implements actions that promote flexibility and professional development.
Specifically:
a) Remote Work: Since 2023, the Remote Working Policy enables employees to declare "Remote Work" using the
integrated information system "METLEN Success Factors", subject to approval by the Line Manager.
b) Time management training: The "LeadMe" Leadership Academy started operating in 2024, and one of its training
modules involves the training of 600 leaders on time management issues; accordingly, new trainees will attend a similar
training through the professional training program "Engineers in Action".
Special Actions for the Management of Material Occupational Health and Safety Risks
The following paragraphs offer a description of horizontal and vertical actions and practices implemented annually, covering all
of METLEN's activities, in Greece and abroad, and aim both at preventing and mitigating negative impacts on direct employees.
These initiatives effectively address the material risks that may arise and enhance the corporate culture of Health and Safety. In
addition, the implementation of the special action plans of the Energy and Metals Sectors (including their Subsidiaries) and the
Company’s core Subsidiary METKA contributes substantially to the achievement of the objectives and targets of METLEN's Health
and Safety Policy by enhancing training, organization, infrastructure safety, communication and integration of OHS processes.
[ESRS2: MDR-A_68_a] [ESRS2:MDR-A_68_b] [ESRS2:MDR-Α_68_c] [ESRS2:MDR-Α_68_e]
A. Horizontal actions
1) Strict implementation of safety systems and performance of measurements (harmful factors, working conditions, etc.) to
address the associated risks, so as to assess their impact on employees and identify needs for interventions in all workplaces
(offices, construction sites and industrial plants).
2) Internal and external audits to ensure the quality of procedures and the continuous improvement of the system and of Health
& Safety outcomes.
3) Ability of employees to step away from working conditions they believe could cause injury or illness, while protected from
retaliation, in accordance with the relevant provisions of the Code of Professional Ethics. Also, those responsible for Health
and Safety may recommend that employees be temporarily removed from certain tasks if it is for their protection.
4) Identify, analyze and evaluate the key Health and Safety risk factors within the framework of management systems
(OHSMS) but also within the framework of enterprise risk management (ERM), to limit the possibility and impacts of risks
that affect the Company's strategy, activities and business objectives.
5) Occupational health practices that contribute to identifying and minimizing Health & Safety risks and include, among others,
the operation of Clinics with constant presence of nurses and regular presence of doctors. Also, regular visits and inspections
of workplaces by Occupational Physicians, medical services provided daily during working hours in the Clinics of industrial
plants and the headquarters free of charge to all Employees. Occupational Physicians must keep an individual medical file on
each employee and issue medical fitness certificates.
6) Additional private healthcare program covered entirely by the Company, offered as a fringe benefit to employees for the
promotion of their health, which is complementary to the statutory access employees have to the state healthcare system as
a result of the insurance contributions the Company pays for each employee. The Company safeguards the confidentiality of
its employees’ health information in the context of applying the regulatory provisions of the General Data Protection
Regulation.
7) Provision of medical services to its employees on a daily basis in the clinics operating in its facilities, and implementation of
a special vaccination program to certain categories of employees. Furthermore, the Company regularly organizes blood
donation events at its facilities.
8) Continued strengthening of the mental health of employees and their families, within the framework of the Employee
Assistance Program that was launched in 2021 with the creation of a Psychological Support Hotline. This is a service offering
employees and their families 24-hour counselling support, through a network of experienced psychologists and specialists in
personal, family and labor-related issues, as well as free personalized face-to-face or remote sessions.
B. Vertical actions per Sector and main Subsidiary
Metals Sector:
1) Adoption of internationally recognized industry standards such as those of the Aluminium Stewardship Initiative (ASI)
and guidelines of the European Aluminium Association and the International Aluminium Institute – of which METLEN is a
member – for the promotion of Occupational
5. Annual Board of Directors Management Report
224
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Health & Safety in Metals, along with the study of good practices related to the Company’s other Business.
2) Training and awareness-raising of employees on specialized H&S issues: Organisation of dedicated H&S seminars at the
aluminium plant, and rescue and accident management programs in bauxite mining, as well as the "Safety Alert"
campaigns and educational video screenings to enhance communication on safety issues. Implementation of in-house
interactive safety seminars designed by METLEN executives at the aluminium production plant for all staff, using virtual
and augmented reality tools oriented to risk identification.
3) Upgrading workplaces and equipment to enhance safety: a) application of the HAZOP study and installation of life lines
at the aluminium plant, b) quantitative and qualitative ventilation measurements and installation of escape chambers in
the bauxite mining galleries, and c) upgrading of infrastructure, such as the reconstruction of sanitary areas and the
improvement of equipment at the secondary cast aluminium plant by closing the two sides of a rotary furnace and applying
an automatic feeding system of aluminium products to enhance safety in the production process.
4) Organization and supervision of work through safety procedures, inspections and visits: Implementation of "Safety
Walks" at the primary aluminium plant and bauxite mining activities, with the participation of production departments
and management, and conducting safety visits. In mining, safety visits (OSH) with the participation of the Occupational
Physician to record observations and suggestions for improving safety
5) Enhancing communication and employee participation in information campaigns. The Communication and Employee
Participation Policy is strengthened with posters and information screens in all facilities to promote safety issues, as well
as by conducting regular awareness-raising campaigns adapted to the period and specific risks of each activity.
6) In addition, at METLEN's bauxite mining subsidiary DELPHI-DISTOMON, the pilot implementation of a digital ventilation
monitoring program at an underground construction site was successful and is already being extended to other
construction sites. The solution used (Ventilation-on-Demand) is designed to ensure air quality in underground mining
farms, contributing both to the improvement of health and safety conditions of workers and to the reduction of energy
consumption of the ventilation system, combining cutting-edge technologies such as Internet of Things, Cloud big data,
Sensors. [E5:E5-2_20_d]
In 2024, the Metals Sector implemented investments amounting to €663 thousand (CapEx) to improve Health & Safety
conditions in the plant's facilities, prevent risks and enhance preparedness in emergency situations. The investments include
the supply of a new fully equipped ambulance, the modernization of the Medical Center's equipment and fire extinguishing
systems, the reconstruction of a fire truck and the improvement of firefighting equipment. In addition, the mining activity
completed the supply of two rescue chambers as well as the expansion of the internal communication system. Total operating
expenditure (OpEx) for 2024 amounts to €540 thousand, which covers payroll and operating costs, such as infirmary
equipment, PPE testing, and other related needs. medical care, education, firefighting materials and related costs.
Energy Sector:
1) Training and awareness-raising of employees on specialized H&S issues: Organization of training programs and briefings,
such as "Violence & Harassment", "First Aid", trainings conducted by NEBOSH (National Examination Board in Occupational
Safety and Health), HSE Inductions for stores, Safety Leadership and Incident Investigation for Safety Engineers in Energy
Centres. Enrichment and renewal of Induction Training on H&S issues and addition of H&S topics to the e-learning platform
for construction sites. Development of a Virtual Reality training tool, where employees can create and enter virtual
environments using virtual reality to identify real risks, and propose corrective action. Awareness-raising and information
events on new legislation and new risks (e.g. extreme weather events, African dust), including planned prevention,
exposure risk minimization and management measures.
2) Upgrading of procedures and integration of OSH protocols through the Energy HSE Protocol, Implementation of HSE
Mapping and adaptation of newly acquired companies to OHS requirements.
3) Improvement of infrastructure and working conditions, such as upgrading building infrastructure and facilities, with
works such as road markings and repair of damaged pavements in Energy Centres and addition of fire safety equipment
in new stores. Drafting of H&S specifications for franchise and shop in shop stores. Improvement and reinforcement of
infrastructure and equipment safety measures on construction sites.
4) Enhanced organization and supervision of works, through inspections and visits by the BUs’ H&S teams, external
organizations according to the approved inspection plan, as well as with the presence of safety coordinators and
enhancing subcontractors’ supervision.
5) Evaluation and monitoring of the effectiveness of OSH actions through internal and external audits, record keeping and
procedures for risk identification and assessment, management reviews, and monthly reporting to Management
6) Certification of new activities, such as electromobility, according to ISO 45001.
5. Annual Board of Directors Management Report
225
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In 2024, within the Energy Sector, €78 thousand was spent on operational costs (OpEx) for the upgrading of processes and the
integration of HSE protocols. Additionally, the Energy Sector implemented investments of €206 thousand (CapEx) to improve
Health & Safety conditions, risk prevention, and enhance emergency preparedness at the Energy Centers' facilities. The total
operational cost for 2024 at the Energy Centers amounts to €129 thousand (OpEx), which includes operational expenses, actions,
drills, PPE procurement, training, studies (e.g., noise at work), fire-fighting materials, and other related costs. For the
implementation of HSE Mapping, related inspections, and training at retail stores, operational costs of €14 thousand (OpEx) were
spent. Indicatively, for energy transition projects, the operational cost (OPEX) spent on Health & Safety training and field
inspections amounts to €150 thousand, while the operational cost (OPEX) for the procurement of PPE is €850 thousand.
Subsidiary METKA SA:
1) Employee Training and Development: Renewal of induction training for new employees.
2) Organization, Execution and Supervision of Works: a) Ensuring the permanent presence of a Safety Engineer / Supervisor
/ Coordinator in construction sites. b) Collaborating with QHSE Operations and external Health & Safety consultants to
improve the organization and execution of works in a safe manner.
3) Employee Information, Communication and Participation: a) Collection of information from construction sites to create
instructions and Lessons Learnt b) Regular communication via email for information on risks and prevention measures, in
order to reduce accidents c) Organization of employee awareness-raising actions on Occupational Health and Safety
issues.
Central Functions
1) Implementation of an Occupational Risk Assessment Design (MEEK) to identify all potential risks in the workplace, related
to the Safety and Health of the Company's personnel working at the company's headquarters and offices, used to assess
the degree of risk and formulate the necessary proposed corrective measures to eliminate or minimize these risks. Each
MEEK is compatible with all legislative requirements of Occupational Safety and Health, as codified by Law 3850/2010 and
any revisions or additions to the articles of Law 4808/2021 and fully covers the Company's obligations under the law.
2) Establishment of First Aid Teams and Emergency Teams and training of members to deal with any emergencies.
3) Awareness-raising and training of employees for Safe Driving "AVENUE for Traffic Safety", with theoretical and practical
segments, to minimize road accidents.
4) Induction Training to every new employee of the Company, to inform, raise awareness and train them on Health & Safety
issues.
5) Regular audits at employee workplaces, to identify and address any risks that may affect the safe operation of facilities.
6) Continuous improvement of working conditions, with regular checks of air quality and noise levels, and by upgrading
equipment and infrastructure.
Actions to leverage significant opportunities
[S1:S1_4_38_c] [S1:S1-4_AR_42] [S1:S1_4_40_b]
To further enhance the secure employment environment, a culture of constant progress is adopted based on supporting
employees, responding to evolving needs and safeguarding career continuity. METLEN is committed to and safeguards the
following particularly important rights affecting the employment environment: [S1:S1_4_38_ b]
a) Freedom of association, provided across the entire Company, mainly in the Metals Sector where there are Workers'
Unions with which the Company is in constant communication and has seamless cooperation, maintaining industrial
peace.
b) Respect of working time and hours, focusing on timely scheduling and observance of working hours as well as
consistency in providing breaks, especially in those activities that operate in shifts. To control of working hours and
related scheduling, a digital card system has been introduced at the secondary cast aluminium production plant of
EPALME and at the steel structures plant of SERVISTEEL, to ensure for more accurate recording of hours worked and
avoid and/or manage overtime (total number of employees: 120); the implementation of the digital card system in other
areas of METLEN in the future is being considered, in accordance with the requirements of Greek legislation. Similarly,
the central management of shifts is also being considered, for better and more automated control through the
integrated digital management system "METLEN Success Factors".
METLEN is committed to continuously investing in its Human Resources and has developed the following initiatives to this end.
[S1:S1_4_38_c] [S1:S1-4_AR_42] [S1:S1_4_40_b]
5. Annual Board of Directors Management Report
226
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
a) LeadMe: Leadership Academy: This is a training program aimed at developing the leadership skills of the Company's people
in positions of responsibility, addressed to approximately 600 leaders of the Company, targeting different levels of leadership
from "first-time team leaders" to "directors". The first implementation cycle will run from October 2024 with a duration of eight
months, until June 2025.
b) Global Induction at METLEN: Creation of a comprehensive induction program for all new METLEN employees. The program
aims at the smooth integration and getting to know the organization to maximize everyone's "Onboarding" experience.
Employees will also receive personalized "Welcome kits" through an automated process, which aims to further enhance the
onboarding experience. All METLEN employees will have access to the program (except workers). Global Induction includes "A
Workplace for All" as a mandatory e-learning course, a course that focuses on issues of diversity, inclusion and unconscious bias
so that all new employees align with these core values from the moment they join the Company.
c) Mentoring program: In January 2025, the mentoring platform will start operating to connect mentors with mentees, at first
for the 8th cycle of the "Engineers in Action" program, aiming at the personal development of both mentors and mentees and
the two-way exchange of knowledge and perspectives between different hierarchy levels and older with younger colleagues.
d) Strategic partnerships: In March 2024, METLEN launched a strategic partnership with LinkedIn Learning, with the first pilot for
500 Company executives who are People Managers. Following the successful completion of the pilot phase, the platform is now
available from October 2024 to all METLEN permanent employees worldwide, through a voluntary participation mechanism.
Meanwhile, measures are taken to meet the needs of all workers and technical staff by translating content into their languages,
ensuring that everyone has equal access and learning opportunities.
e) Upskilling the Learning & Development: METLEN's learning and development team participates in business and industry
conferences, enhancing the dissemination of best practices in this field and at the same time the Company’s reputation and
image.
f) Learning Management System - One Stop Shop: Improvement of the central platform of the Learning Management System
(LMS) as a single point of access for every Company employee to maximize the learning experience and enhance the monitoring
and disclosure of achieved results, which was fully launched, as part of the Success Factors integrated digital management system,
in November 2024.
g) Enterprise Leadership Development: Design of a specialized program "Business Leadership Development" for senior levels of
the Company (Senior Directors, Executive Directors and Chiefs) with the participation of 45 senior executives starting in 2024 and
ending in 2025.
Approach to Understanding the Needs of Vulnerable Employee Groups
METLEN prioritizes understanding the needs of vulnerable employee groups, promoting their equality and support through
ongoing dialogue and appropriate solutions. [S1:S1-1_24_c]
a) The "Women in Industry" workshop, which took place in 2023 with the participation of 92 women working in Metals and
Energy, served as a platform for two-way dialogue and feedback, bringing specific issues to the centre of the discussion
through the perspective of women employed in a male-dominated heavy industry sector. The discussion itself enhances
the Company's ability to recognize whether women are a vulnerable employee group under specific conditions and in
specific environments in order to be able to take relevant initiatives.
b) The use of inclusive language has emerged as crucial, particularly in the recruitment and selection process. As a result, in
2024, METLEN adopted a new job posting standard, which emphasizes inclusion and equal opportunities. This new
standard now applies to all job advertisements in all Company activities worldwide, with the aim of attracting a more
diverse pool of candidates. In doing so, METLEN positions itself as an Equal Opportunities Employer, reaffirming its
commitment to inclusion. The issue of inclusion is also explicitly mentioned in our Candidate Experience Assurance Policy,
where promoting a welcoming and open environment is a key value. This policy ensures that all candidates are treated
with appreciation, respect, and equally, enhancing their sense of belonging from their first contact with the company.
[S1:S1-2_28]
METLEN also makes significant efforts to ensure that its practices do not cause or contribute to material negative impacts on the
workforce. For example, when investigating possible complaints or incidents of discrimination, the competent department takes
all appropriate technical and organizational measures to ensure the Protection of Personal Data, confidentiality and protection
of individuals from any form of retaliation, a commitment reflected in the Privacy Policy, Human Rights Policy and Internal
Reporting Channel Policy. [S1:S1-4_41] [S1:S1-4_AR_37]
To manage the impacts that the Company recognizes as material, both technological and human resources were invested in 2024.
Specifically, in 2024, the Company completed the installation of the new integrated digital management system METLEN Success
Factors, contributing both to more efficient
5. Annual Board of Directors Management Report
227
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
management of negative impacts and further leveraging of positive impacts, as the system allows centralized data collection,
automated processes for reliable analysis and monitoring of information, as well as the execution of work tasks on one single
platform (such as attending training programs and evaluating performance). At the same time, the Central Human Resources
Division has been further staffed with the recruitment of 25 new employees in 2024 to enhance the support services provided to
all Sectors and segments of the Company, contributing with its increased capacity to a more effective response to identified
impacts. [S1:S1-4_43]
Selection procedure for actions to manage identified material impacts [S1:S1_4_39] [S1:S1-4_AR_34]
METLEN follows a structured and integrated process for selecting and prioritizing actions aimed at managing the material impacts,
risks and opportunities identified on an annual basis. The actions result from capturing the level of satisfaction and commitment
of employees, offering important data for consideration and decision-making regarding human resources needs and priorities.
In addition to the Employee Engagement Survey, satisfaction and feedback questionnaires focusing on specific initiatives are also
used, allowing actions to be tailored to employees' needs. Specific working groups with a clear orientation undertake the
monitoring and improvement of actions in specific areas. Also, the feedback of the Trade Unions during the consultation phase
provides additional feedback and ensures the cooperation and effectiveness of the measures implemented.
A key action for the management of gender equality and equal pay for work of equal value is the design process of METLEN's job
model (MJM), which lasted about a year and included numerous meetings with senior and top executives of the Company, during
which information was collected on the strategy and organization of all employee groups. Through collaborative meetings with
the participation of the executives themselves, it was possible to develop proposals for the Company's response to these material
impacts, while the process was completed with the confirmation of the results obtained by the project’s Coordinating Committee,
ensuring the consent of all parties involved.
Also, the selection of actions and the shaping of appropriate strategies for "Diversity" and enhancing inclusion in the workplace
were based on the Employee Pulse Survey on diversity, equal opportunities and inclusion, as well as the corresponding data from
the Employee Engagement Survey.
In the Metals Sector, the Hierarchy Days held annually allow for the emergence of issues that require immediate action. Through
the workshops, issues related to working conditions and staff skills development are identified and prioritized. The very institution
of Hierarchy Days, which ensures the participation of both employees and executives, allows decisions to be taken that directly
meet the needs of its human resources, as well as of the Company itself.
For the selection of actions related to "Training and Skills Development", the process is based on a series of strategic steps that
include:
a) Analysis of employee engagement survey results: Learning needs are identified based on employee responses.
b) Learning Needs Analysis: This process involves collaboration between HRBPs (Human Resources Business Partners) and
representatives from each department. This analysis identified the top 3 social and top 3 technical skills needed to meet
market needs.
c) Individual Development Plan (IDP): The IDP is a KPI for managers and their teams and aims to promote individual and group
development goals.
d) Performance Management Cycle: Creates areas of growth with specific goals and steps for all employees on an annual
basis, identifying trends in learning needs.
e) Talent Assessment: The top 45 (Executive & Senior Directors) are evaluated to develop targeted actions.
Expected results of the reported actions [S1:S1_4_38_d] [S1:S1_AR_38] [S1:S1_AR_39]
The main goal of the implementation of the above actions is the improvement of the work experience, the enhancement of
diversity and the continuous investment in human resources. The results of these initiatives are decisive for enhancing the
Company's competitiveness, attracting and retaining talent, and promoting an inclusive environment. Each Sector and Subsidiary
of the Company monitors the effectiveness of main actions through various processes.
Initiatives related to fair treatment and equal opportunities are expected to create an even more inclusive environment, where
employees feel that they belong to a large corporate family, regardless of personal characteristics. This results in improved work
experience, enhanced sense of commitment, making the Company even more competitive in attracting talent and retaining staff,
thus helping reduce the attrition rate. These actions also support the implementation of the Company's Diversity Policy at all
stages of the work cycle, with the long-term goal of enhancing innovation through the collaboration of diverse teams with
different ideas and experiences.
5. Annual Board of Directors Management Report
228
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Initiatives concerning the management and monitoring of working conditions have contributed to reducing stress, increasing
productivity and the psychological well-being of employees. These results make the Company a more attractive employer, while
enhancing the engagement of existing employees, which also contributes to reducing the attrition rate. At the same time, the
implementation of measures for employment security, like freedom of association, has shaped a positive working environment,
enhancing industrial peace, productivity and employment stability.
The Company continues to invest in its human resources, offering training and development opportunities. Employees feel that
they are growing professionally within the Company, that they develop skills that allow them to meet the demands of their
position and the market in general and recognize that their capabilities are constantly enhanced. Investing in the Company's
people helps strengthen employee engagement, while enhancing both its competitiveness and its adaptability and readiness to
respond to market developments as central elements of its growth and business success, especially in recent years.
Impact of the transition to a green economy on employees
[S1:S1_4 AR_43]
METLEN systematically implements measures to ensure that assets financed under its Green Bond Framework issued in 2024
provide high employment, health and safety standards. In addition, all assets to be financed under this framework are covered
by METLEN's human rights policy and occupational health and safety policy, and include:
a) Eco-efficient and/or circular economy adapted products, technologies and production processes / Renewable energy
storage
b) Renewable Energy Production / Renewable Energy Storage
c) Renewable energy production (hydro, wind)
d) Renewable energy production (solar energy)
e) Renewable energy production / Eco-efficient and/or circular economy adapted products, technologies and production
processes.
METRICS & TARGETS
S1-5
Targets related to managing material negative impacts, advancing positive impacts and managing
material risks and opportunities [ESRS2:MDR-T_80_b] [ESRS2:MDR-T_80_c] [ESRS2:MDR-T_AR_24] [MDR-T_AR_25] [ESRS2:MDR-T_AR_26]
METLEN aims to safeguard employment relationships that promote mutual trust, constructive cooperation, two-way
communication and recognition, as stated in the Company's Human Rights Policy. At the same time, it aims to promote the
fundamental principles of the Declaration on Fundamental Rights and Principles at Work of the International Labor Organization
including: a) respect for freedom of association and the effective recognition of the right to collective bargaining, b) elimination
of all forms of forced or compulsory labor, c) non-participation in forms of child labor and d) elimination of discrimination at
work.
METLEN's HR strategy has two main objectives:
a) creating a harmonized approach and understanding of management practices to build joint leadership skills; and
b) cultivating a culture of continuous learning and development across the entire Company. [S1:S1_5_46]
A key area of particular importance for METLEN is the promotion of gender equality at all hierarchical levels. As a result, specific
goals have been set for gender representation at each of these levels. Specifically, METLEN aims to achieve the following level
of female representation by 2030:
30% of Supervisors and Executive Directors,
20% of Senior Directors and Directors,
30% of Technical Staff,
30% of the overall Human Resources.
METLEN encourages workforce participation in setting its targets by ensuring the voice of employees through the engagement
survey process. With a participation rate of 80%, the workplace climate survey provided valuable input, based on which the
company defined specific objectives, strengthening its corporate strategy with a focus on the needs and opinions of its people.
5. Annual Board of Directors Management Report
229
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Key Health & Safety (H&S) Targets
METLEN's key Health & Safety (H&S) targets are an integral part of its strategy to ensure a safe, healthy and productive working
environment. METLEN recognizes the importance of its human resources and is committed to continuously improving working
conditions, reducing risks, and promoting the overall well-being of its employees. The following key Health & Safety targets of
METLEN are annual and focus on enhancing employee protection through improved safety measures and preventive actions.
5. Annual Board of Directors Management Report
230
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
LTIR - Lost Time Injury Rate: Accidents with loss of working time ≥ 3 days - TRIR – Total Recorder Injury Rate: This includes
fatalities, serious accidents and all accidents that resulted in days away from work, limited work or transfer to another job, medical
care other than first aid or loss of consciousness or significant injury or ill health diagnosed by a doctor or other authorized
healthcare professional. This includes cases of fatalities and accidents that occurred during the employee's travel from their place
of private activity (e.g. residence) to their place of work and only when such travel has been organized by the Company. The
targets include all METLEN Sectors and Subsidiaries. [MDR-T_80_f] [MDR-M_77_a] [MDR-T_AR_24] [MDR-T_AR_25] [MDR-T_AR_26]
The process of setting central targets for METLEN's Safety and Health indicators began in June 2022, with the proposed targets
put to consultation by HSE Division to all HSE managers of the Company's Sectors and Subsidiaries. The consultation cycle was
completed in September 2022, with the approval of the central targets by the General Managers of Sectors and Subsidiaries.
The targets
125
are divided into absolute and relative. Absolute targets (zero fatalities, serious accidents, and occupational
diseases) are defined in absolute values with a target of zero. Relevant targets, such as LTIR and TRIR, are identified in number
of incidents per 200,000 hours worked, with specific ceilings to achieve optimal workforce safety. [ESRS2: MDR-T_80_b]
Also, targets are directly linked to the Company's H&S Policy, which is the basis for the development and implementation of all
relevant initiatives and actions as well as the operating framework, setting the Company's principles and priorities regarding the
care for the health and safety of employees. In particular, METLEN’s H&S Policy emphasizes accident prevention and continuous
improvement of workplace safety. The quantitative targets for preventing fatalities and serious accidents as well as the indicators
for reducing the frequency of accidents on an annual basis are also an expression of this commitment. Furthermore, METLEN's
H&S Policy emphasizes the importance of complying with health and safety regulations and standards. The company's targets
are directly linked to this commitment, as they include fully assessing risks, implementing preventive measures, and supporting
employee well-being by ensuring that METLEN is fully compliant with applicable legislative requirements. [ESRS2: MDR-T_80_a]
In addition, the targets are directly related to the prevention and mitigation of social impacts, with a focus on workers' human
rights. Since the issue of H&S is a core labor right and is included in the Company's Human Rights Policy, these targets are
identified based on the impact on human rights, well-being and positive outcomes for affected stakeholders, such as employees,
local communities and suppliers. The absolute targets, as mentioned above, reinforce employees' right to a safe and healthy
working environment, which is a key element of the International Declaration of Human Rights and International Labor
125
Please note that the targets do not refer to a specific base year. However, as the targets are annual, the measurement of progress starts from the current
calendar year as a reference point, with a view to continuously monitoring and achieving these targets at the end of the year. [ESRS2:MDR-T_80_d] [ESRS2:MDR-
T_80_e]
0
0
0
≤0.3
≤0.6
CENTRAL ANNUAL CORPORATE HEALTH & SAFETY TARGETS 2024
FATALITIES
SERIOUS
ACCIDENTS
OCCUPATIONAL
DISEASES
LTIP/PER 200,000
WORKING HOURS
TRIR/PER 200,000
WORKING
HOURS
5. Annual Board of Directors Management Report
231
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Organization (ILO) Conventions. Similarly, the relevant targets enhance employee well-being, as they reduce the incidence of
injuries and ensure better working conditions. [ESRS2: MDR-T_80_AR_24]
In defining its core Health and Safety targets, METLEN relied on the following factors: a) identification and assessment of
workplace risks, by studying data from accident analyses, safety checks and disease reports, identifying the areas with the highest
risk levels; b) integration and analysis of historical data on the Health and Safety performance of each Sector and Subsidiary of
the Company, allowing the adjustment of targets to specific needs and challenge;. c) analysis of the respective practices and
performance of similar enterprises with the Company's Sectors, which provides valuable insights in the implementation of
effective and best prevention practices; d) the specifications of international standard ISO 45001, according which METLEN's
Health and Safety Management System is certified. Regarding the scope
126
of the targets, they apply to all METLEN’s units,
including all countries of operation, covering plant facilities, construction sites, offices, stores and all related functions related to
the production, distribution, and provision of the Company’s services. They also cover all direct and indirect employees
127
employed in the Company's activities. [ESRS2:MDR-T_80_c]
METLEN's annual Health & Safety targets have been designed with both the broader context of sustainable development and the
local conditions in which the Company's activities are implemented in mind. These targets are not just numerical but reflect
METLEN's commitment to creating a safe and supportive work environment, centred on people and society, to respecting the
environment. Zero targets for fatalities, serious accidents, and occupational diseases are in line with the Sustainable Development
Goals, in particular UN Goal 8 (Decent Work and Economic Growth), which promotes the creation of safe and decent working
conditions. Zero tolerance for accidents and illness signals METLEN's commitment to fostering a work environment where safety
and health are priorities. Also, the relevant LTIR and TRIR indicators, which aim for extremely low accident levels, reinforce the
Company's approach to systematically measure and improve safety conditions, linking its practices to international standards for
occupational safety and well-being. These targets comprehensively incorporate the concept of human-centred development,
focusing on workforce well-being as a critical part of overall business sustainability. Promoting a safe working environment helps
increase productivity, reduce absenteeism due to illness or accident, and enhance the long-term sustainability of the Company.
[ESRS2:MDR-T_80_f]
S1-6
Characteristics of the Undertaking’s employees
METLEN's workforce, at the end of 2024, numbers 7,627 direct employees, of which 6,934 are employees and the remaining 693
are self-employed employees. Of this total, 2,172 employees are employed by the subsidiary company UNISON, which is not
included in any of the following HR parameter analysis indicators, as its integration had not been completed with METLEN's
systems by the end of 2024. It is noted that the total of the following figures results from the Company's systems and concerns
5,455 direct employees of the Company.
Direct employment recorded a further increase in 2024, by 1-7.4%, continuing the upward trend of 2023 (+26.0%).
126
An exception to the scope is the subsidiary of the Energy Sector, UNISON, which was recently acquired (in 2024) by METLEN. This subsidiary is not yet aligned
with METLEN's H&S framework and therefore these objectives do not currently apply to its activities. The alignment of the subsidiary with METLEN's overall
H&S framework is ongoing, and is expected to be included in the scope of the objectives in the future.
127
As mentioned in the section "Workers in the value chain"
128
The methodology used to compile the data is based on measurement at the end of the reporting period (31.12.2024), without recording the fluctuations
during the reporting period, taking into account the new methodological approach to defining the relevant workforce, in accordance with the CSRD Directive.
OWN WORKFORCE - POPULATION
128
%N/N-1
2024
2023
2022
Total number of direct employees
Total direct employees
+17.9%
4,769
4,046
3,210
Total direct workers (self-employed)
+14.1%
686
601
535
TOTAL OWN WORKFORCE
+17.4%
5,455
4,647
3,745
5. Annual Board of Directors Management Report
232
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The growth rate was almost equal between men and women, confirming the effectiveness of gender equality policies in practice.
In addition, in 2024, the collection of gender-disaggregated population data was extended to additional categories beyond men
and women, in line with the framework of the CSRD Directive. However, zero values were recorded in the two additional available
gender categories "Other" and "Not reported", so these categories are not included in detail in the tables.
[S1:S1-6_50_b] [S1:S1-6_AR_55] [S1:S1-6_51] [S1:S1-6_52_a] [S1:S1-6_52_b]
The large increase in the number of employees without guaranteed hours is due to the fact that in 2024, for the first time, self-
employee workers in Greece and abroad were included in the Company's direct employees, who were automatically considered
as not having guaranteed hours, as their relationship is not dependent and is not subject to Greek legislation regarding working
time limits.
A total of 79.6% of direct employees are employed in Greece, while the remaining 20.4% in the other countries of METLEN's
international activity. The Company maintained for yet another year the very high rates of local employment, where
approximately nine (9) out of ten (10) of its direct employees come from the communities directly adjacent to its industrial units,
construction sites and headquarters, as well as their wider area. The overall share of women in the labor force concerned stood
at 25.2%, almost stable compared with the previous year.
129
The presentation of demographics by type of contract is presented exclusively for salaried workers as self-employed persons do not fall under this type of
segregation.
130
Employees with open-ended contracts are defined as permanent employees of the Company.
131
Employees with fixed-term contracts are defined as temporary employees of the Company.
Analysis of the type of employment contract of direct employees (employees)
129
Total number of full-time employees 2024 2023 2022
Men
+36.1%
4,076
2,995
2.558
Women
+34.9%
1,329
985
631
Total
+35.8%
5,405
3,980
3.189
Greece
+38.9%
4,294
3,092
2.529
Total number of part-time employees 2024 2023 2022
Men
-60.0%
6
15
6
Women
-13.7%
44
51
15
Total
-22.2%
50
66
21
Greece
-18.6%
48
59
15
Total number of employees without guaranteed hours 2024 2023 2022
Men
+496.5%
674
113
124
Women
+532.1%
177
28
25
Total
+503.5%
851
141
149
Greece
+429.8%
747
141
149
Total number of employees with an open-ended contract
130
2024 2023 2022
Men
+37.2%
3,859
2,812
2,145
Women
+32.6%
1,285
969
508
Total
+36.0%
5,144
3,781
2,653
Greece
+36.6%
4,099
3,001
2,299
Total number of employees with a fixed-term contract
131
2024 2023 2022
Men
+13.2%
223
197
419
Women
+29.4%
88
68
138
Total
+32.3%
311
235
557
Greece
+62.0%
243
150
245
5. Annual Board of Directors Management Report
233
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Further increased at the end of 2024, the share of salaried employees employed under an open-ended employment contract to
94.3% (2023: 93.5%). At the same time, low part-time employment rates further decreased to 0.9% (2023: 1.6%).
[S1:S1-6_50_c] [S1:S1-6_51]
In 2024, total new hires reached 1,338 with one in three being women, while one in three also wore to young workers under 30.
The average cost of new hires made in 2023 has been estimated at approximately €36 thousand, against €32 thousand in 2023
(gross salary).
Regarding the mobility indicators of the relevant workforce, the voluntary redundancy ratio remained almost stable at 7.4%
compared to the previous year (2023: 7.0%), while the non-voluntary redundancy ratio decreased to 2.3% (2023: 3.7%),
demonstrating the Company's focus on creating a stable working environment.
The retention ratio (retention rate) of full-time employees decreased slightly in 2024, to 84.9%
134
(2023: 86.8%). Also, the
average length of stay of the labor force concerned in 2024 was 6.98 years (2023: 7.25 years).
In 2024, an additional 474 new jobs were created, creating a total of 1,059 new jobs in 2023-2024, covering needs in all Business
Sectors of the Company, with a growth rate double that of the previous year (2023: 585). Also, in 2024, 48 new jobs were filled
by internal candidates.
At the same time, METLEN created 67 quality internships and vocational training positions, most (48) through the "Engineers in
Action" Program, with the aim of developing skills and converting many of these positions into open-ended and full-time
positions.
S1-7
Characteristics of non-employees in the undertaking’s own workforce
132
The methodology used for the data compilation is based on measurement at the end of the reporting period (31.12.2024), without accounting for fluctuations
during the reporting period, taking into consideration the new methodological approach for defining the relevant workforce, in accordance with the CSRD
Directive. [S1:S1-6_50_d]
133
The absence of a time series is due to the change in the methodological approach, as from 2024, non-employed individuals are also included in the relevant
workforce. Therefore, a comparison with previous years' data is not possible, although data for salaried employees remains available in the Company’s
Sustainability Reports for the years 2023 and 2022.
134
It is noted that for the calculation of the employee retention index, the subsidiary Company "European Bauxite", which was acquired in 2024, was not included
in the calculation, while the methodology used was the following: Number of employees at the end of the period (5.212) minus New hires (1.320) to the Number
of employees at the end of the previous reference period (4.584), while the calculation included the total relevant workforce (employees and self-employed
persons). [S1:S1-6_50_e]
DIRECT EMPLOYEE DATA
132
REQRUITMENTS
DEPARTURES
# Employees
2024
133
%
2024
%
Total
1.338
754
Gender distribution
Men
949
70,9%
571
75,7%
Women
389
29,1%
183
24,3%
Age distribution
<30 years old
400
29,9%
187
24,8%
30-50 years old
747
55,8%
421
55,8%
>50 years old
191
14,3%
146
19,4%
Country
Greece
1.020
76,2%
537
71,2%
5. Annual Board of Directors Management Report
234
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The main categories of non-salaried employees include self-employed independent professionals who are in charge of providing
specialized services either directly at its premises or at the workplace of its customers, covering fixed and long-term staffing
needs of the Company's available positions, as well as METLEN's salaried employees. In the total relevant workforce of METLEN
for 2024, the share of self-employed stood at 12.6%, moving downwards compared to the previous year (2023: 14.9%).
In comparison, in 2024, the growth rate of non-salaried workers (+13.6%) was lower than the growth rate of the total relevant
labor force (+17.4%), indicating the largest strengthening of salaried jobs. Also, the extremely low employment of employees
provided by enterprises that primarily carry out employment activities reflects the Company's strategic direction for stable and
fully organized management of its human resources, reducing dependence on external partners and enhancing the retention of
internal skills and knowledge. [S1:S1-7_56] [S1:S1-7_AR_62] [S1:S1-7_AR_65]
135
An exception to the scope is the subsidiary of the Energy Sector, UNISON, which was acquired by METLEN and the completion of the harmonization of its
systems is in progress.
136
The total self-employed for the year 2023 was included in the total indirect workers for 2023.
137
The total self-employed of the year 2022, was included in the total of indirect workers of 2022.
138
The methodology used to compile the data is based on measurement at the end of the reporting period (31.12.2024), without recording fluctuations during
the reporting period. [S1:S1-7_55_b] [S1:S1-7_A R_64]
DATA OF DIRECT WORKERS: SELF-EMPLOYED – POPULATION
135
%N/N-1
2024
2023
136
2022
137
Total number of self-employed persons
138
[S1:S1-7_55_a] [S1:S1-7_55_b] [S1:S1-7_AR_55]
Self employed
13.0%
679
601
535
Persons provided by enterprises principally engaged
in employment activities (NACE code N78)
-
7
-
-
Total
14.1%
686
601
535
Men (self-employed)
12.4%
544
484
436
Women (self-employed)
18.4%
135
114
99
5. Annual Board of Directors Management Report
235
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
1-8
Collective bargaining coverage and social dialogue
METLEN continuously monitors the relevant labor legislation in all areas of its activity (national, European, ILO) and is in full
accordance with collective and relevant international agreements. The Company's employees may, without any restriction,
participate in trade unions and professional associations. Covered by business or collective labor agreements, where applicable,
are 3,993 employees, which as a percentage correspond to 73.2% of the Company's total workforce. In particular, employee
unions operate in the Metals Sector in which almost all (~98.9%) of the Sector's employees participate. Also in the Energy Sector,
at the level of business units, in all countries where the Sector operates, the percentage of representation is ~56.0%, as for the
remaining percentage participation is not required. [S1:S1-8_60_a] [S1:S1-7_A R_66]
More specifically, in Greece in 2024, a total of 3,779 direct employees were covered by collective labor agreements, in all Business
Sectors of the Company, corresponding to 69.3% of the total number of employees of the Company. [S1:S1-8_60_b]
It is also noted that the total number of employees outside the EEA is 681 employees, with a large dispersion in the countries
where the Company operates. [S1:S1-8_60_c]
For employees who are not covered by collective agreements, the Company is bound by the implementation of the locally
adopted National Collective Labor Agreement. [S1:S1-8_61]
The working conditions and terms of employment of self-employed workers are determined or affected by the collective
agreements in force from time to time. [S1:S1-8_62]
90.1% of direct employees in 2024 are employed in facilities where there is representation through employee representatives.
This percentage at country level includes only Greece, a country within the EEA, where the company has a significant number of
jobs. [S1:S1-8_63_a] [S1:S1-8_A R_69]
In all business activities of METLEN operate primary trade unions, with representatives elected by the employees in a general
assembly, as well as representatives in secondary trade unions (Volos Labor Center, POEM - Panhellenic Federation of Metal
Workers).
[S1:S1-8_60_a] [S1:S1-8_60_b] [S1:S1-8_60_c] [S1:S1-8_ΑR_70] [S1:S1-8_ΑR_69]
S1-9
Diversity metrics
Own Workforce - Age Groups
Female
Male
Grand Total
139
The employees of the relevant workforce covered by collective agreements (CLAs) are the persons to whom the Company is obliged to apply the CLA. A
worker in the relevant workforce of an undertaking covered by more than one CLA has been counted only once. [S1:S1-7_A R_67]
It is also noted that the Company does not disclose data outside the EEA, as there are no areas of activity with a concentration of >50 employees representing
>10% of the total employees.
140
Presentation of the number of employees in countries where the enterprise has at least 50 employees representing at least 10 % of its total number of
employees.
DATA TABLE ON COLLECTIVE AGREEMENT COVERAGE AND SOCIAL DIALOGUE
COLLECTIVE AGREEMENTS
139
SOCIAL DIALOGUE
Coverage rate
Workers — EEA
140
Workers — Non-EEA
(estimate for areas with > 50
workers who represent > 10 % of
total worker.)
Representation in the workplace (EEA only)
& (for countries with >50 employees
representing >10% of the total workforce
concerned)
0-19%
20-39%
40-59%
60-79%
Greece
80-100%
Greece
5. Annual Board of Directors Management Report
236
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
<30
253
479
732
30-50
925
2,497
3,422
>50
195
1,106
1,301
Grand Total
1,373
4,082
5,455
[S1:S1-9_66_b]
Since 2024, METLEN's workforce categorization is based on the new job model, the "METLEN Job Model (MJM)". This approach
ensures a standardized framework for classifying roles, providing clarity and consistency in evaluating job positions across the
company. It is the most reliable and structured method for categorizing employees, leading to the creation of four categories of
staff 1) Corporate Management / Leadership Council, 2) Middle Management & Experts, 3) Team Leaders/Supervisors &
Professionals, 4) Admin & Technical Staff. In addition to the above four categories, the following tables also reflect a fifth category,
the Executive Leadership Team. Since up until 2023, disclosures were made with three categories of staff, the data for 2024,
broken down by employee category, is not directly comparable. [S1:S1-9_65] [S1:S1-8_ΑR_71]
Specifically, the classification of job positions in the company, which formed the basis for the above staff categorization, is based
on the evaluation of the positions, not the employees, in accordance with market practices. It is based on three key criteria:
· Expertise (e.g., technical knowledge, managerial knowledge in resource management, communication and influence
skills).
· Problem-Solving (e.g., environment and freedom of thought, complexity of problems from repetitive to highly complex).
· Responsibility (e.g., freedom of action and decision-making, size and impact of results).
5. Annual Board of Directors Management Report
237
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
[S1:S1-9_66_a] [S1:S1-9_66_b]
141
The Executive Leadership Team consists of the Cabinet of the CEO and is defined as the top management of the Company.
142
The Corporate Management / Leadership Council consists of executive staff in Director, Senior Director, and Executive Director positions.
DETAILS OF DIRECT EMPLOYEES - DIVERSITY
2024
Total
Percentage
Executive Leadership Team
141
Total
12
Gender distribution
Men
8
66,7%
Women
4
33,3%
Age distribution
<30 years old
0
0%
30-50 years
3
25,1%
>50 years old
9
74,9%
Corporate Management / Leadership Council
142
Total
135
Gender distribution
Men
112
83.0%
Women
23
17.0%
Age distribution
<30 years old
0
0%
30-50 years
75
55.6%
>50 years old
60
44.4%
Middle Management & Experts
Total
620
Gender distribution
Men
476
76.8%
Women
144
23.2%
Age distribution
<30 years old
8
1.3%
30-50 years
457
73.7%
>50 years old
155
25.0%
Team Leaders/Supervisors & Professionals
Total
2,401
Gender distribution
Men
1,698
70.7%
Women
703
29.3%
Age distribution
<30 years old
429
17.9%
30-50 years
1,565
65.3%
>50 years old
402
16.8%
Admin & Technical Staff
Total
1,950
Gender distribution
Men
1,506
77.2%
Women
444
22.8%
Age distribution
<30 years old
261
13.4%
30-50 years
1,312
67.4%
>50 years old
373
19.2%
5. Annual Board of Directors Management Report
238
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
S1-10
Adequate wages
All METLEN employees in all countries where METLEN operates are paid an adequate wage, in accordance with the applicable
benchmarks. [S1:S1-9_69] [S1:S1-8_A R_73] [S1:S1-8_A R_74]
S1-11
Social protection
METLEN provides its direct employees with full coverage for illness, workplace accidents, medical care needs, family leaves,
retirement, and unemployment, starting from the moment the employee begins working for the company, in accordance with
the legal framework of each country through public programs. Additionally, the company offers extra private coverage through
local programs in each country, which vary in their coverage based on the total number of employees in the country. At the same
time, it provides the option for health insurance for dependents of direct employees at preferential rates.
In 2024, the implementation of a global harmonization plan for all employees of the Company began and continues on the
basis of an examination of improvements per country, based on the benchmarks of each market, and with the aim of further
enhancing the balanced offer of benefits in all countries within 2025. Also, in 2024, in addition to public benefits, the
implementation of the pension program "Invest in You" in Greece for all employees through a specific investment plan began,
while a similar initiative is underway in two other countries (England and Spain), while in 2025 its expansion to additional
countries will be explored. [S1:S1-11_74]
The above social protection benefits also apply to the non-salaried (self-employed) employees of the company. [S1:S1-11_76]
For newly acquired companies that have not yet been fully integrated into METLEN, separate benefit plans apply, however they
are scheduled to join the joint corporate benefits plan once the incorporation process is complete. [S1:S1-11_A R_75]
S1-12
People with disabilities
In 2024, 10 employees with disability were recorded (Men: 9, Women: 1), which corresponds to 0.18% of METLEN's total
workforce (men percentage ~0.16%, women percentage ~0.018%). It is noted that the characterization of an employee as an
"employee with disabilities", as well as its gravity, is based on a relevant disability certificate or other confirmatory administrative
document, which is presented by the employee and maintained in full compliance with medical confidentiality in the context of
respecting employees' personal data. The more complete depiction of this measurement in 2024 is due, among other things, to
the upgrading of the data collection process, which reflects the expanded role of the Human Resources General Division. This
development is a natural consequence of the Company's internationalized presence, enhancing a more integrated and strategic
approach to employment management, with emphasis on safety, inclusion and equal participation of all employees. [S1:S1-12_79]
[S1:S1-12_80] [S1:S1-12_A R_76]
S1-13
Training and skills development metrics
In 2024, 4,766 direct employees participated in the internal and external training programs implemented by METLEN, i.e. 87.4%
of the total workforce. A total of €498,690 (OpEx) was spent, increasing training expenditure by approximately 71.1% compared
to the previous year (2023: €291,422) for the implementation of 95,999 man-hours of training, increasing by 56.3% the total
hours compared to the previous year (2023: 61,408). The Company's training program, in which 79% participated, increased
participation by 23% (2023: 56.4%) of direct staff, focused mainly on the following key modules: [MDR-A_69_b]
5. Annual Board of Directors Management Report
239
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Introductory acquaintance with the Company
Foreign languages
Development of skills and personal competences
Development of technical skills
Occupational Health & Safety
Products/Service Security
Internal Processes & Management Systems
CSR
Compliance Programs
GDPR & Code of Conduct
Development of managerial skills & leadership
Digital Security
Human Rights
Technological systems and tools
Professional certification
Postgraduate programs (support)
In addition, in 2024, programs were implemented that aimed to further enhance the high-performance culture, strengthen skills
and personal competencies, as well as technical skills, with the aim of increasing efficiency and addressing the current and future
challenges of business activity. In particular, programs were implemented on issues of effective communication, Health & Safety,
Project management, IT tools and compliance. The training of office workers included, among others, the following topics:
Cybersecurity, Code of Conduct, Personal Data Protection – GDPR, Diversity, Leadership Development, Internal Processes &
Management Systems, etc.
At the same time, in 2024, the implementation of METLEN's LeadME Leadership Academy began. It is a fully structured program,
designed to empower the company's future leaders and enhance its growth. The program offers a comprehensive educational
experience that combines a Harvard Manage Mentor eLearning approach, interactive discussion circles, and training workshops.
Indicatively, the first session implemented in 2024 concerned Diversity, Equality and Inclusion (DEI), laying a solid foundation for
the creation of a fair and inclusive work environment. Also launched in 2024, the leadership training, "Leading Authentically",
focused on empowering the Company's leaders to be able to lead confidently and clearly, developing the skills to effectively
manage teams, setting meaningful goals and inspiring their people. The program continued in the first two months of 2025 with
the module "Leading Teams that Deliver Results" which focuses on developing skills that improve team performance and enhance
the ability to provide constructive feedback and assign tasks in a strategic way. The third module of the "Nurturing & Developing
Others" program focuses on developing talent management strategies, enabling leaders to develop and empower their teams
for continuous improvement and organizational success. Overall, the program also offers core training in the areas of
performance appraisal, goal setting, and human resource development, preparing participating executives to take on leadership
roles with strategic thinking and the ability to effectively lead their teams. [MDR-A_68_a] [MDR-A_68_b] [MDR-A_68_c] [MDR-A_68_e]
[S1:S1-13_83_b] [S1:S1-13_85] [S1:S1-13_ΑR_78] [S1:S1-13_ΑR_79]
In 2024, average training in man-hours varied by workforce category, reflecting the specific needs and requirements of each
group. The largest investment in training was recorded at the Middle Management & Experts management level (30.2 man-
hours), underlining the importance of continuous specialization and skills development in strategic and technical specialization.
The Corporate Management/Leadership Council received an average of 18.1 man-hours, focusing on leadership and managerial
skills. Team Leaders/Supervisors & Professionals were trained an average of 12.5 man-hours, while Admin & Technical Staff
received 17.6 man-hours, highlighting the ongoing need for technical and administrative support. Cybersecurity and information
security training was particularly extensive in 2024, as a total of 4,182 direct employees participated, of which the training was
completed within the year, a percentage of 63.3% with a success rate approaching 95%. The remaining 39.7% are expected to
complete education in 2025.
DATA OF DIRECT EMPLOYEES – LEARNING & DEVELOPMENT
%N/N-1
2024
2023
2022
Average man-hours of training / Gender distribution
Men
18.5
17.0
13.4
Women
14.7
9.9
11.2
Total
17.6
15.2
13.0
Average man-hours of training / Age distribution
<30 years old
27.2
29.9
27.4
30-50 years
16.8
13.8
12.1
>50 years old
12.6
7.9
5.9
5. Annual Board of Directors Management Report
240
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
It is noted that in all the above-mentioned trainings for the relevant workforce of METLEN, both salaried employees and self-
employed employees participate. [S1:S1-13_85] [MDR-A_68_a] [MDR-A_68_b] [MDR-A_68_c] [MDR-A_68_e] [S1:S1-12_A R_76]
In the performance evaluation process, as decided by the Company's management, 4,674 direct employees of METLEN
participated in 2024 (one evaluation per employee), reflecting high participation rates among both women and men. Specifically,
1,186 women participated, representing 86.34% of the total female workforce, and 3,492 men participated, representing 85.5%
of the total male workforce. [S1:S1-13_83_a]
By category of staff, participation was as follows:
1. Executive Leadership Team: 12 employees
2. Corporate Management / Leadership Council: 117 employees
3. Middle Management & Experts: 555 employees
4. Team Leaders/ Supervisors & Professionals: 2,071 employees
5. Admin & Technical Staff: 1,785 employees
The data demonstrate the wide coverage of performance appraisal at all levels of the company, confirming METLEN's
commitment to continuous improvement and development of its human resources. [S1:S1-13_84]
S1-14
Health and safety metrics
2024 was another decisive year for Occupational Health and Safety, with METLEN achieving its annual targets for its direct
employees. Specifically, the zero number of accidents was maintained for yet another year, while no injuries were recorded due
to work accidents, with significant consequences on the lives of employees. There were also no workers exposed to activities
that pose a risk of developing work-related diseases thus highlighting the effectiveness of the Company's preventive measures
and risk management.
Despite the small increase recorded in the absolute number of total recorded accidents and accidents with work interruption of
≥3 days, where most of them concerned fractures/sprains mainly without further serious consequences for employees, the
frequency rate of these accidents per 200,000 hours worked was once again below the set annual target. This fact is of particular
importance, given the integration of new mining activities in the Metals Sector, as well as the further expansion of construction
projects in Greece and abroad by the Infrastructure and Concessions Sector and the Energy Sector respectively. However,
although such incidents are not considered particularly serious, they have a disproportionate impact on the number of lost
working days since they require long recovery periods due to the requirement of physical rehabilitation, which explains the
difference between the low frequency index and the increase in lost days from 2023 as shown in the table below.
All incidents were analyzed using the method of "Tree of Causes Analysis" to ensure the recording of the causes and the
dissemination of the results of the investigation, to increase employee awareness, while the basic corrective measures depending
on the type of incident, the Sector or the subsidiary that has occurred, include: a) informing the staff of the establishment about
the incident; b) training the personnel on the risks and necessary protection measures related to the incident; c) adapting and/or
revising the relevant instructions; d) informing supervisors about more increased surveillance of workplaces; e) training staff in
the proper use of Personal Protective Equipment; f) demarcation of areas in works at height, lifting loads, erection of scaffolding;
and g) arrangement and arrangement of the workplace (e.g. signage, cleaning, etc.).
5. Annual Board of Directors Management Report
241
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
[S1:S1-14_88_c] [S1:S1-14_AR_80] [S1:S1-14_AR_89] [S1:S1-14_AR_91]
The indicators presented in the table above refer to all direct employees, employees and self-employed persons, as they are
covered by the Group's integrated Health and Safety Management System.
In addition, the recording, investigation and analysis of near misses by the Company is important for improving safety conditions,
as it provides valuable information on potential risks and potential weaknesses in safety practices. In this context, the role of
employees is very important as the existing corporate safety culture that has been developed, encourages the reporting of
143
Health & Safety Management System
144
Due to accidents and work-related health problems.
145
All frequency indicators based on 200,000 working hours are published to monitor the targeting of work-related accidents, accidents and health incidents as
mentioned in the relevant section.
146
Due to injuries and accidents from work accidents, work-related health problems and deaths due to health problems.
Employee Health and Safety Scoreboard [ΑΕ 80] [ΑΕ 89] [ΑΕ91] [S1-14 88 _c]
%N/N-1
2024
2023
2022
Percentage of employees covered by HSMS
143
(ISO 45001-2018) [S1:S1-14_88_a]
98.9%
90.0%
92.9%
Total fatal accidents
144
[S1:S1-14_88_b]
0%
0
0
0
Accident frequency index / 1,000,000 hours worked
0%
0.00
0.00
0.00
Accident frequency index / 200,000 hours worked
145
0%
0.00
0.00
0.00
Total accidents with serious consequences for employees'
lives
0%
0
0
0
Frequency index of accidents with serious consequences on
the lives of workers / 1,000,000 hours worked
0%
0.00
0.00
0.00
Frequency index of accidents with serious consequences on
the lives of workers / 200,000 hours worked
0%
0.00
0.00
0.00
Total recorded incidents (TRI) [S1:S1-14_88_c]
+6.2%
17
16
12
Men
15
16
12
Women
2
0
0
Total Recordable Incident Rate / 1,000,000 hours worked
(TRIR)
-18.0%
1.64
2.00
1.65
Men
-
1.39
2.50
2.10
Women
0.42
0.00
0.00
Total Recordable Incident Rate / 200,000 hours worked
(TRIR)
-17.5%
0.33
0.40
0.33
Men
0.28
0.50
0.42
Women
0.08
0.00
0.00
Lost time Injury with lost working time of ≥3 days (LTI)
+9.1%
12
11
8
Men
11
11
8
Women
1
0
0
Lost time Injury Rate with lost working time of ≥3 days /
1,000,000 hours worked (LTIR)
-14.07
1.16
1.35
1.10
Men
1.39
1.70
1.40
Women
0.42
0.00
0.00
Lost time Injury Rate with lost working time of ≥3 days /
200,000 hours worked (LTIR)
-14.8%
0.23
0.27
0.22
Men
0.28
0.34
0.28
Women
0.08
0.00
0.00
Total incidents of near misses related to work
-15.2%
111
131
113
Total work-related health incidents [S1:S1-14_88_d]
0%
0
0
0
Work-related health incidents rate / 1,000,000 hours worked
0%
0.00
0
0
Work-related health incidents rate / 200,000 hours worked
0%
0.00
0
0
Total lost working days
146
[S1:S1-14_88_e]
+26.9%
472
372
282
Men
457
372
282
Women
5
0
0
5. Annual Board of Directors Management Report
242
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
relevant risks, and in combination with the commitment to achieving Health and Safety objectives, the effective implementation
of relevant policies, systems, procedures and guidelines, as well as the value of consultation and the "open door" approach to
reporting and recognition of near misses, help the Company identify potential problems before they develop into serious
accidents.
In 2024, the number of near misses decreased which is attributed to individual improvements in safety measures, strong training
initiatives to prevent risks and further enhance the overall safety culture, which gradually contribute to reducing the occurrence
of hazardous incidents. All incidents were analyzed and relevant prevention actions were implemented where necessary.
At the same time, the utilization of the findings of scheduled or extraordinary safety inspections carried out by specially trained
personnel of the Company, as well as by customers, partners, public bodies and independent control and assurance organizations,
contribute to the further improvement of the level of Health and Safety, to the formulation and renewal of relevant procedures
and ultimately to the implementation of necessary actions and actions.
In 2024, 577 internal OSH audits were carried out, showing a very large increase compared to the previous year (2023:122),
mainly due to the expanded business activity of the Energy Sector, as a result of the undertaking of new projects, as well as the
overall strengthening of prevention measures. Respectively, 310 (2023:273) external audits were carried out, by independent
certification providers, customers and regulatory authorities, as a result of the development of new partnerships and new
projects, enhancing the overall OSH culture.
As in previous years, in 2024, special emphasis was placed on preventing accidents at work through education. In all Business
Sectors and subsidiaries of the Company, 32,061 man-hours of Health and Safety training were implemented, in which direct
staff participated, almost double compared to previous year (2023: 17,002). The increase is related to the goal of continuous
improvement of corporate performance in this regard, the expansion of METLEN's activities to more countries worldwide, but
also to the undertaking of new projects that require staff training on health and safety issues. Training programs are divided into
general and specific having different goals and content. General training programs concern the basic principles and rules that all
employees should know regardless of their position or type of work and provide general knowledge about workplace risks and
ways of prevention. Special education programs focus on specialized knowledge and skills required to safely perform specific
tasks or to address specialized risks.
Data table of Employee Health and Safety trainings
General Training
Program man-hours
9,538.9
Key topics:
General occupational hazards, use of Personal Protective Equipment (PPE), emergency and evacuation plans, basic fire safety
principles, corporate goals (eg zero accidents), types of accidents and reports, emergency telephone numbers and OHS policies.
Special Training
Program man-hours
22,522.35
Key topics:
System Management ISO45001
Report Near Misses-Unsafe Actions/Conditions
Accident, Injury, First Aid
Fire and emergency
Fire prevention - Fire extinguishing
Construction Site Order
Manual handling of loads
Use of tools
Work at height, indoors, in underground farms
Major Hazards (Electricity, Excavations, Construction
Machinery-Vehicles)
Slips, Trips & Falls
5. Annual Board of Directors Management Report
243
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
S1-15
Work-life balance metrics
During the reporting period, all employees of the Company (100%) had the right to leave for family reasons, in accordance with
social policy and collective agreements. Specifically, a total of 361 direct workers (6.62% of all direct workers) made use of this
leave, of which 250 men (6.12% of all directly employed men) and 111 women (8.08% of all directly employed women)
respectively. The share of direct workers who returned to work after parental leave ended was 100%, while 78% remained in
work 12 months after parental leave.
Family leave includes maternity leave, paternity leave, parental leave, and care leave, as defined by the applicable legal
framework. Specifically, in 2024, employees who took parental leave include those who started their parental leave within the
year, as well as those who began it in 2023 and completed it in 2024. It should be noted that until 2023, the recording
methodology only included maternity and paternity leave. From 2024, the measurement has been extended to include all types
of family leave, ensuring more comprehensive coverage of employees' rights and alignment with modern recording and
transparency requirements. [S1:S1-15_93] [S1:S1-15_94]
S1-16
Compensation metrics (pay gap and total compensation)
Since 2024, METLEN has implemented the new job classification model, the “METLEN Job Model (MJM)”, for categorizing the
human resources
147
. This model provides a clear and structured framework for determining the size and nature of job positions
across the company, leading to the creation of four (4) categories of staff. The change in the existing job classification adequately
reflects the details of the duties and responsibilities of each position, thus ensuring fairness and equality in compensation.
According to the above framework, the application of the methodology
148
for collecting and analyzing data on the gender pay
gap continued in 2024, recording an average wage gap of 9.7% between women and men.
More specifically, in the four new categories the resulting ratio is: In the Corporate Management / Leadership Council, the
difference is zero, which reflects the effectiveness of corporate approaches in achieving the goal of equal remuneration at this
level. In the categories Middle Management & Experts (6.0%), Team Leaders/Supervisors & Professionals (6.0%) and Admin &
Technical Staff (9.0%), the discrepancies underline the importance of investigating the different causes in order to formulate
targeted interventions. Especially for the category Admin & Technical Staff (8.54%), the comparison with last year's recording of
technical staff (-9%) requires careful interpretation, as this category is characterized by a high proportion of men (>98%), which
significantly affects deviations and variations between years. The Company prioritizes understanding the individual dynamics that
147
Until 2023, the classification was done in three (3) categories: a) Administrative, b) Executive, c) Labor-technical, which makes the data for 2024 not directly
comparable to previous years. [S1:S1-16_AR_100]
148
The methodology applied includes the gross hourly earnings of all employees; and b) it applies the following formula to calculate the gender pay gap: Average
gross hourly earnings of male employees including benefits minus average gross hourly earnings of female employees including benefits divided by the average
gross hourly earnings of male employees including benefits, multiplied by one hundred. [S1:S1-16_AR_98] [S1:S1-16_AR_99]
Environmental Parameters
Risk Assessment-Working Methods
Contingency plans
Site evacuation plan
Personal protective equipment
Main construction site work
Safety on site
Safety signs
Safety signs for hazardous materials
General Construction Site Rules
Loading-Unloading
Written occupational risk assessment
On-site risk assessment
Work with laders
Work in extreme weather conditions (heatwave, cold)
Risk Identification
Safe pedestrian movement
Musculoskeletal risks
Mental health at work
5. Annual Board of Directors Management Report
244
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
affect differences between different categories, in order to formulate targeted actions to reduce deviations where necessary.
[S1:S1-16_98]
Due to the geographical dispersion, complexity of operations, and different business activities of METLEN, before the Company
publishes specific indicators, it has prioritized identifying the various causes that lead to such discrepancies in each of the
categories of Executive, Administrative, and Labor staff.
The ratio of the annual total compensation of the highest-paid individual to the median annual total compensation of all
employees (excluding the highest-paid individual) was 120:1 in 2024, reflecting a slight increase compared to the previous year
(2023: 118:1). [S1:S1-16_97_b]
S1-17
Incidents, complaints and severe human rights impacts
As in previous years, in 2024, for the 7th consecutive year, the Company implemented a self-assessment process for the
protection of Human Rights across all Business Activity Sectors and in all countries where it operates. According to the findings
of the process, no areas were identified with deficiencies that could jeopardize the protection of Human Rights in the Company’s
activities. The main areas investigated through the end of 2024, according to the above process, are presented in the following
table.
METLEN gives priority to creating a fair working environment, monitoring any deviations and taking immediate action where
necessary. In this context, in 2024, through the specialized electronic reporting platform "METLEN Ethics Control Service", eight
reports related to human resources management issues were submitted, two of which were confirmed as incidents of
organizational behavior. Of the total number of petitions that were seriously examined, and in full compliance with METLEN's
Labour Regulation, five petitions were identified as complaints, while another report is under investigation. Each report
submitted is investigated by a competent team of HR executives and after the process is completed, a report is drawn up with
the outcome of the investigation. If disciplinary action is required, the case is referred to the Disciplinary Committee, which
consists of the Heads of the Directorate-General for Human Resources and the Office of the Chief of Staff. Also, in the reporting
year, no fines, penalties and compensation for damages have arisen as a result of human rights incidents or complaints, including
harassment and discrimination.
Areas of Investigation
Actions
Occupational
Health & Safety
During the self-assessment process, no deficiencies were observed in terms of procedures or policies related
to the Health and Safety of employees.
The Company ensures safe facilities and healthy working conditions for its employees.
It also ensures that its employees are provided with the necessary protective equipment and receive the
required training needed to perform their work safely.
The Company promotes the active participation of its employees in Health and Safety processes in the
workplace.
Recognizing the importance of promoting and empowering the mental health of employees and their families,
the Company activated a 24-hour Psychological Support Helpline, which has been operating continuously since
then.
Overall, the policy, the planned actions to achieve the defined goals, and the initiatives voluntarily adopted by
the Company to ensure the Health and Safety of employees are applied with complete consistency, as
presented in the relevant section of this report.
Working hours,
compensation, and
employee leave
A fundamental and non-negotiable principle for METLEN is that its business activities are carried out in full
harmony, compliance, and adherence to the applicable labor laws in each region or country in which it operates.
The Company ensures that all employees have an official employment status.
It ensures that the weekly working hours are limited to 40 hours; however, due to unexpected and unplanned
work overload, employees in various activities may work beyond 40 hours.
The Company has processes in place for the planning, recording, and monitoring of each employee's working
hours to control overtime, and provides employees with a reasonable break time during work (as required by
legislation and industry standards).
The Company ensures employees' compensation in cases of sick leave, parental leave, and vacation leave, in
accordance with international standards.
Through the official procedure for reporting violations of the Company’s Code of Conduct, no incidents of
violation of these specific labor rights were reported to the Human Resources Department.
5. Annual Board of Directors Management Report
245
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Fair treatment of
employees
According to the Company’s Code of Professional Conduct and Operating Regulations, the Company:
Protects its employees from harassment in the workplace, as well as from physical, verbal, sexual, or
psychological harassment or any form of threat.
Respects the confidentiality of employees' personal data whenever personal information is collected or
workspaces are monitored.
Through the official procedure for reporting violations of the Company’s Code of Conduct, no incidents of
discrimination were reported to the Human Resources Department that were confirmed. Additionally, with the
assistance of an external consultant, 450 executives attended seminars on Discrimination and Violence &
Harassment in the workplace.
Discriminations
METLEN follows international practices in all the regions and countries where it operates, ensuring that
decisions related to matters such as recruitment, compensation, promotions, professional training, retirement,
and contract termination are based solely on impartial criteria and are not linked to any form of discrimination.
Through the official procedure for reporting violations of the Company’s Code of Conduct, no incidents of
discrimination were reported to the Human Resources Department that were confirmed. [S1:S1-17_103_a]
Freedom
of association
The Labor Legal Framework includes provisions that safeguard the right to collective bargaining and unionization
of employees, which METLEN fully respects. In all of its Business Activity Sectors, the right to unionize is
recognized for employees. During 2024, no areas or incidents were identified where this right was at risk or
violated. This result is a consequence of the application of a specific social bargaining process, which has as its
fundamental prerequisite the commitment of the Company's Management as well as the employees to
thoroughly address social and labor issues, taking into account the rights and interests of both parties.
Through the official procedure for reporting violations of the Company’s Code of Conduct, no incidents of
violations of this specific labor right were reported to the Human Resources Department.
Impact on local
communities
The Company, through both official and unofficial contact mechanisms with local communities, which it maintains
per Business Activity Sector outside of industrial units located in designated Industrial Zones, ensures the
documentation of local communities' concerns regarding the potential broader impacts of its activities, taking
appropriate measures when necessary.
Additionally, it takes the necessary steps to ensure that its security systems or the arrangements it applies comply
with international law enforcement and authority use standards. In this context, in 2024, no conditions were
identified that would justify the potential occurrence of human rights violations at the community level. The
Company's activities do not restrict but, on the contrary, ensure citizens' access to resources or other means of
livelihood. Furthermore, the consultation process and subsequent collaboration with municipalities during the
development and operation of renewable energy projects (RE) is systematic, where the Company invests
significant amounts in the development and improvement of local infrastructure for the common benefit.
Child labor
METLEN does not employ workers under the age of 15 or 18 for work.
As a result, no activity within the Company presents (significant or not) the risk of incidents of child labor or
conditions that may lead to the employment of young workers in hazardous work.
Additionally, through the METLEN Supplier and Partner Code of Conduct, it is explicitly stated that they must
strictly adhere to the legal work age limits and restrictions in the countries they operate in, and where no legal
limit is defined, it must be considered at least 15 years old. Furthermore, individuals aged 15 but under 18 should
not be employed in hazardous work or in work that may endanger their personal mental and physical safety and
health.
Forced labor
METLEN, in compliance with the Greek Constitution (Article 22, paragraph 4), which establishes freedom of labor,
incorporates the relevant provisions within its Code of Conduct and the Supplier/Partner Code of Conduct,
prohibiting any form of forced or compulsory labor in its workplaces as well as in the workplaces of its
suppliers/partners. As a result, in all of the Company's activities, the risk of conditions leading to incidents of forced
labor is significantly minimized.
In 2024, through the official reporting process for violations of the Company's Code of Conduct, no complaints or
incidents of forced or compulsory labor were reported to the Human Resources Department.
5. Annual Board of Directors Management Report
246
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Appendix S1: Own Workforce Information of Unison Subsidiary
On August 9, 2023, Metlen acquired 100% of the share capital of UNISON Facility Services S.A. Unison is a company active in the
field of managing the infrastructure, operational needs and human resources of an enterprise. Given the different areas of activity
of the company compared to the core sectors in which Metlen operates (metallurgy and energy), it has been decided for the
purpose of incorporating the relevant information concerning Unison in the consolidated sustainability statement, that all human
resources indicators to be disclosed based on the ESRS will constitute separate tables, as presented below.
S1-6
Characteristics of the Unison Sudsidiary’s employees
Own Workforce - Population
Total number of direct employees
Total direct employees (employees)
2,165
Total direct workers (self-employed)
7
Total Own Workforce
2,172
Analysis of the type of employment contract of direct employees (employees)
Total number of full-time employees
Men
674
Women
595
Total
1,269
Greece
1,269
Total number of part-time employees
Men
140
Women
763
Total
903
Greece
1,666
Total number of employees without guaranteed hours
Men
0
Women
0
Total
0
Greece
0
Total number of employees with an open-ended contract
Men
338
Women
376
Total
714
Greece
714
Total number of employees with a fixed-term contract
Men
476
Women
982
Total
1,458
Greece
1,458
5. Annual Board of Directors Management Report
247
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
S1-7
Characteristics of self-employed employees in the workforce of the subsidiary Unison
Data on direct employees: self-employed - population
Self-employed
7
Persons provided by enterprises principally engaged in employment activities (NACE code N78)
0
Total number of self-employed direct employees
7
S1-8
Unison subsidiary collective bargaining coverage and social dialogue
Regarding UNISON, 2073 employees are covered by a collective agreement, corresponding to 95.4% of this entity.
S1-15
Work-life balance metrics
Similarly, for UNISON, all employees of the company (100%) had the right to leave for family reasons, in accordance with social
policy and collective agreements. Specifically, a total of 36 direct workers (1.66% of all direct workers) made use of this leave, of
which 20 men (2.45% of all directly employed men) and 16 women (1.18% of all directly employed women) respectively. The
share of direct workers who returned to work after parental leave ended was 100%, while 78% remained in work 12 months after
parental leave ended.
WORKERS IN THE VALUE CHAIN [ESRS: S2]
STRATEGY
The Health and Safety of value chain workers is a fundamental factor of METLEN's activity and a primary business objective.
SBM-3
Material impacts, risks and opportunities and their interaction with the strategy and business model
In the context of this section of the Sustainability Statement, which follows the guidelines and requirements of Standard ESRS:S2,
value chain workers of METLEN for the
Details of direct employees
Recruitment
Departures
# Employees
2024
%
2024
%
Total
1,174
966
Gender distribution
Men
373
31.77%
366
37.89%
Women
801
68.23%
600
62.11%
Age distribution
<30 years old
147
12.52%
149
15.42%
30-50 years old
535
45.57%
454
47.00%
>50 years old
492
41.91%
363
37.58%
Country
Greece
1,174
100%
966
100%
5. Annual Board of Directors Management Report
248
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
reporting year (2024), and based on the due diligence procedures that exist and are applied, include the employees of direct
subcontractors who meet standing operational needs of the Group across all its activities. The responsibility of companies that
partner with METLEN to provide work and, for this purpose, employ a workforce, is defined each time in the bilateral agreements
concluded. Ath the same time, both the Responsible Supply Chain Policy and the Suppliers and Business Partners Code of Conduct,
which all partner companies accept by signing, strictly apply. With the threshold of double materiality assessment referring to
those employed at the Group's facilities or at the facilities of its customers where it implements projects, substantial H&S impacts
were recognized only on employees of its subcontractors, without the evaluation being extended to product suppliers. [S2:SBM-
3_11] [S2:S2-1_18]
METLEN is committed to the strict observance and implementation of the applicable national and European legislative framework
and other regulatory provisions related to Health & Safety at Work in all its Sectors, Subsidiaries and Central Functions. To ensure
that the operation of its Sectors is in line with the relevant legislation, the Group sets much stricter limits through the relevant
management programs and systems it implements. In particular, the integrated and certified Occupational Health and Safety
Management System (OHSMS) is in line with the principles of international standard ISO 45001:2018, as it promotes ensuring a
safe and healthy working environment through risk identification, the prevention of accidents and occupational diseases, ongoing
training for all employees, and continuous improvement of management systems.
ACTUAL NEGATIVE IMPACT [AN-3]:
Work-related safety incidents and their consequences
POTENTIAL NEGATIVE IMPACT [PN-4]:
Work-related health & safety incidents and their consequences
This impact is directly related to all the Group's production plants as well as all Central Functions. [S2:SBM3_11_c] [SMB3_14_c]
[SMB3_14_d] [SBM3_14_AR_44]
Time Horizon:
Actual & Short Term
Position in the Value Chain:
Upstream, Own Operations, Downstream
CURRENT AND POTENTIAL IMPACT ON THE
BUSINESS MODEL & VALUE CHAIN
[SBM3:48_b] [S2:SBM-3_AR_6] [S2:SBM-3_AR_7]
CURRENT AND POTENTIAL IMPACT ON
STRATEGY & DECISION MAKING
[SBM3:48_b] [S2:SBM-3_AR_6] [S2:SBM-3_AR_7]
1. Injuries of value chain workers with serious or less serious
consequences.
2. Controlled impact on morale and psychology of value
chain workers.
3. Small-scale decline of production rate in individual
production processes.
4. Affecting the Group's long-term reputation from potential
OHS incidents, if the existing adequate management is not
maintained, leading to a loss of confidence from investors,
customers and other stakeholders.
1. Constant promotion of a safety culture with emphasis on
prevention and responsibility of each value chain worker
as well as of each direct subcontractor to ensure a safe
working environment.
2. Linking top management remuneration with the Group's
central Safety Objectives.
3. Disclosure of central Occupational Health and Safety
Policy and Objectives.
4. Disclosure of a central Human Rights Policy.
5. Implementation of best practices in Occupational Health
& Safety incident prevention.
6. Development and disclosure of a Due Diligence Policy,
including relevant procedures where required to optimise
prevention capacity.
In the Metals Sector, all contractors employing a large number of staff within the premises of the aluminium plant are required
to have an OHS management system certified according to ISO 45001, based on which the Group systematically evaluates their
relevant performance using specific criteria, ensuring the continuous improvement of OHS practices.
In the Energy Sector, the management of OHS issues is governed by a series of actions that partner contractors are required to
implement within the framework of the applied integrated OHS management system in accordance with international standard
ISO 45001. There is direct and intensive cooperation with them to ensure the adoption, implementation and compliance with
the procedures and requirements of the OHS management system, as well as the applicable legislation. At the same time, all
facilities of the Energy Sector have First Aid stations with fully equipped pharmacies and staff trained in first aid. Furthermore,
all value chain workers participate in induction trainings where they are informed on actions necessary in case of an incident. In
addition, there are regular retraining sessions to confirm knowledge and enhance readiness.
5. Annual Board of Directors Management Report
249
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Quantitative and qualitative data on the Health & Safety performance of value chain workers are monitored and analyzed through
monthly reports and communicated to Management. Some corrective actions taken to enhance safety include retraining
employees in OHS rules, implementing Tool Box Talks to continuously raise awareness about safe work, intensifying on-site
checks at work points, and enhancing supervision of work by engineers and foremen. Re-evaluations of the performance of
employees and work teams are also carried out to ensure their fitness and to remind the importance of the continuous use of
appropriate protection equipment.
IMPACT, RISK & OPPORTUNITY MANAGEMENT
S2-1
Policies related to value chain workers
The Health and Safety of value chain workers is a fundamental and primary business objective of METLEN's activity. It is a line of
responsibility that starts from Management and the General Divisions and reaches the production areas of all the Group's Sectors
and Subsidiaries. Acting responsibly, METLEN acknowledges both its responsibility for the continuous improvement of Health &
Safety conditions in its workplaces and the right of employees of independent partners and contractors carrying out work on its
premises to work without being exposed to risks that could cause an accident, injury or occupational disease, as reflected in the
"Suppliers & Business Partners’ Code of Conduct" of the Group. [ESRS2: MDR-P_65_a] [ESRS2: MDR-P_65_b] [S2:S2-1_18]
CENTRAL HEALTH & SAFETY POLICY [S2:S2-1_16] [S2:MDR-P_01-06]
Year of update
2024
Key Content
[MDR-P_65_a]
The Policy includes Management’s commitment to ensure the smooth operation of all (direct and value chain
workers) and to create a safe working environment through full compliance with legislation and international
standards. The Policy's main objectives include identifying and assessing occupational risks, implementing
measures to reduce and/or eliminate such risks, as well as set quantitative and qualitative targets for the
continuous improvement of working conditions. The Policy prioritizes prevention by introducing action plans to
improve working conditions and taking preventive and remedial actions in the event of accidents. In addition, it
incorporates the principles of OHS into critical corporate processes, such as procurement and mergers, while
promoting continuous training and awareness-raising of employees and partners. In terms of material impacts,
by drafting and implementing the Policy, the Group aims at reducing accidents and protecting direct and indirect
human resources from harmful factors, creating a safety culture.
Targeting
[MDR-P_65_b]
The implementation of the Policy covers own workforce, while it also includes the employees of independent
partners and contractors who perform work at its facilities.
Governance
[MDR-P_65_c]
a. Approved by the Group's Sustainability Committee.
b. Designed and revised by the Group's Corporate Governance and Sustainable Development General
Division in cooperation with the General Divisions of the Group's Sectors, which are also responsible for its
implementation.
Standards or
internationally
recognized third-party
initiatives
[MDR-P_65_d]
a. ISO 45001:2018 International Standard
b. Sustainable Development Goals (3, 8, 17)
c. Performance Standard- Aluminium Stewardship Initiative (ASI)
Inclusion of
Stakeholder interests
[MDR-P_65_e]
Annual Stakeholder Consultation [S2:S2-1_17_b]
Availability
[MDR-P_65_f]
Corporate website
149
and intranet. It is available to all stakeholder groups on the Group's official website, and it
is also posted in public areas of the facilities directly accessible by value chain workers as well and is inspected
for completeness by external bodies during inspections.
HUMAN RIGHTS POLICY [S2:S2-1_17] [S2:MDR-P_01-06]
Year of update
2021
149
https://www.metlengroup.com/media/ui4bdblo/occupational-health-safety-policy-gr.pdf
5. Annual Board of Directors Management Report
250
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Key Contents
[MDR-P_65_a]
[S2:S2-1_17]
Ιn the context of its business activity, METLEN respects and protects labor and social Human Rights, including
OHS, Appropriate Working Conditions, Child Labour, Forced Labor and Human Trafficking, Equal Opportunities,
without Discrimination, Trade Union Freedom, etc.
This Policy expresses METLEN's zero tolerance for the violation of Human Rights that materializes both by the
non-participation (direct, passive or tacit) of the Group in relevant violations, and by avoiding any transaction and
contact with third parties that may have caused or there are reasonable grounds to suspect that they may
participate in creating conditions that may cause violations of such rights.
At the same time, it enhances awareness and ensures the commitment of METLEN's employees, suppliers and
partners to respecting and protecting Human Rights, in all Sectors, including its Subsidiaries.
Targeting
[MDR-P_65_b]
[S2:S2-1_17_a]
[S2:S2-1_17_b]
Through its Human Rights Policy, METLEN is committed to identifying, assessing, preventing, and mitigating the
risks of human rights violations by applying due diligence as well as corrective actions to address such incidents
should they occur. In particular, it is committed to promoting respect for and protection of Human Rights in its
supply chain, through the "Suppliers and Business Partners’ Code of Conduct", as well as the inclusion of key
Human Rights indicators in the selection criteria of suppliers, in the contractual terms and in the audits carried
out by the Purchasing and Procurement Departments of its Sectors, its Subsidiaries and its Central Functions (CF).
Governance
[MDR-P_65_c]
It is approved by the Executive Leadership Team and monitored by Sustainability Committee of the Board of
Directors:
a. Human Resources General Division
b. Corporate Governance and Sustainable Development General Division
c. Regulatory Compliance Division
Policy Recipients
Direct employees; Value chain workers; Suppliers and partners including subcontractors of all METLEN BUs,
Subsidiaries and Central Functions.
Standards or
internationally
recognized third-party
initiatives
[MDR-P_65_d]
[S2:S2-1_19]
1. United Nations Universal Declaration of Human Rights
2. The Core Conventions of the International Labour Organization (ILO)
3. The Principles of the UN Global Compact
4. The Sustainable Development Goals (2030 Agenda)
5. The United Nations Guiding Principles on Business and Human Rights
6. The Organisation for Economic Co-operation and Development (OECD) Guidelines
7. The United Nations Convention on the Elimination of All Forms of Discrimination against Women (Article
11 - Field of Employment)
Availability
[MDR-P_65_d]
1. Corporate Website
150
2. Regular updates to the internal audience upon first publication and following any revisions
3. Internal Information Portal (Intranet)
S2-2
Processes for engaging with value chain workers about impacts
METLEN follows multi-level cooperation procedures with its value chain workers who are direct employees of its permanent
subcontractors who undertake work within all its facilities, including factories, construction sites and mining activities, to address
OHS issues. These practices aim to enhance the active participation of value chain workers in the management of OHS issues.
Below is a brief description of these key procedures:
A. Health and Safety Committees and Teams
1. In the Metals Sector and specifically in the primary aluminium plant, value chain workers employed by the contractors-
partners of Aluminium of Greece are obliged to comply with the OHS Procedures and Management System applied and
in place at the plant. In addition, safety issues concerning value chain workers are discussed in the following ways:
a) The plant has appointed a safety correspondent for each contractor, who is in direct communication on safety
issues, and also holds meetings with H&S as the first item on the agenda at least four times a year.
b) Contractors participate in safety incident analyses if they are involved and take actions.
c) Through open communication with the contractors’ Safety Engineers and the plant’s Safety Department as well as
the competent Contracts Management Department.
150
https://www.metlengroup.com/media/rp3edd3u/politiki_anthrwpinwn_dikaiwmatwn_en.pdf
5. Annual Board of Directors Management Report
251
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
d) A contractors' meeting is held twice a year with the competent Contracts Management department and the Safety
department.
e) Also, a group called "Contracts Committee" has been set up at the plant, with the participation of employees from
all departments, which holds discussions, raises issues and makes decisions on safety and management issues
concerning contractors.
2. In bauxite mining activities, value chain workers employed by contractors are obliged to comply with the OHSMS
Procedures & Guidelines applied and in place in accordance with requirements of Standard ISO45001. In addition, safety-
related issues are discussed with the involvement of employees during E 05 - Hierarchy Safety Inspections & E 08 - Health
& Safety Inspections. If the issues that arise have a long implementation horizon, they are incorporated into the annual
Action Plan.
3. In the Energy Sector, there is a corporate-level Occupational Health and Safety team monitoring Health and Safety
matters in all 5 segments of the Energy BU, which also covers value chain workers. The team's responsibilities include
communicating with management on OHS issues, finding solutions to safety issues, organizing actions to raise awareness
among colleagues, including value chain workers, as well as assessing and communicating health and safety objectives
(KPIs). Also, in all construction sites and plants of the Energy Sector, specially trained staff set up OHS teams daily
checking the compliance of activities and contractors, including contractor employees, on H&S issues, and report on the
progress to the facility’s Management (construction site or plant).
4. At subsidiary METKA, which operates in infrastructure construction, there is a five-member Occupational Health and
Safety Team (OHST). The team is responsible for monitoring the organization's performance in managing OHS issues and
in particular, maintains open communication with Management, proposes solutions to address safety issues, organizes
awareness-raising actions for value chain workers and selects and assesses OHS-related objectives (KPIs). [S2:S2_2_22_a]
[S2:S2_2_22_b]
B. Consultation and analysis procedures with the participation of value chain workers and continuous
communication
In the Metals Sector, employees are the key actors of a continuous, systematic and methodical process, whereby they participate
in the development of safety rules through the implementation of targeted initiatives/tools such as those of "Confident
Professional Movement", "Confident Professional Conduct", "Hierarchy Safety Visits", "Risk Identification" and "Personal Safety
Actions"
At the primary aluminium plant, communication, dialogue and participation actions aim at applying OHS in practice, while at the
same time they are tools resulting in the gradual consolidation and improvement of the "safety culture" among value chain
workers. [S2:S2-2_22] [S2:S2-2_22_a] [S2:S2-2_22_b] [S2:S2-2_AR_18]
In bauxite mining activities (on underground works), communication between supervisors (foremen, engineers) and workers is
a daily and key element in identifying and addressing risks. Special instructions are recorded in the construction site instructions
book and discussed in safety meetings twice a month. Moreover, the right of value chain workers to voice comments, suggestions
and opinions (anonymously or not) on procedures (Code of Ethics, Policies, Administrative Practices) is guaranteed. At the same
time, the main OHS procedures and instructions are posted on each construction site, and regular consultation and dialogue
meetings are held through the Workers' Union. [S2:S2-2_22] [S2:S2-2_22_a] [S2:S2-2_22_b] [S2:S2-2_AR_18]
In the Energy Sector, regular meetings with employees are held in every facility to discuss all Health & Safety-related issues of
concern to them and to voice remarks, complaints or suggestions to improve existing situations or practices All issues are
reviewed and action is taken in the context of the OHS Management System with the involvement and participation of value
chain workers in managing occupational risks. There is also constant cooperation of Safety Engineers and Occupational Physicians
with the respective Health & Safety teams on issues related to the safety, security and health of employees. [S2:S2-2_22] [S2:S2-
2_22_a] [S2:S2-2_22_b] [S2:S2-2_AR_18]
At Subsidiary METKA, all employees have the opportunity to express their opinion on OHS issues in daily meetings with their
Supervising Engineer, and/or during induction trainings by the Safety Engineer or the Site Safety Coordinator. Also, the Group's
Policy provides for the right to withdraw from a specific job that potentially poses a serious risk.
C. Available reporting channels for OHS issues
METLEN provides several channels for reporting OHS issues. The channels have common access and structure for all Sectors and
Subsidiaries and can also be used by value chain workers. These include digital platforms for instant reporting of issues, sending
anonymous messages via a dedicated email address, and the ability to send letters to or meet with the Compliance Manager.
This ensures that the need for managing OHS issues with transparency and constant communication are fully met. [S2:S2-2_27_b]
5. Annual Board of Directors Management Report
252
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
[S2:S2-2_27_c]
In bauxite mining activities, the right of value chain workers as well to voice comments, suggestions and opinions (anonymously
or not) on procedures (Code of Ethics, Policies, Administrative Practices) is guaranteed. [S2:S2-2_AR_18]
At Subsidiary METKA, which operates in infrastructure construction projects, all employees have the opportunity to express their
opinion on OHS issues by informing the Site Manager, the Site Safety Engineer, the Safety Coordinator, or their Supervising
Engineer. They can also request to participate in OHST meetings. [S2:S2-2_AR_18]
S2-3
Processes to remediate negative impacts and channels for value chain workers to raise concerns
A. Actions to remediate negative impacts
METLEN has taken the following actions to remediate the negative impacts associated with its activities.
a) Implementation of preventive actions as a prerequisite for achieving continuous progress and improvement, in conjunction
with the extensive experience the Group gains from each incident and near-miss that it analyses, along with continuous
education and training of value chain workers as a key factor in maintaining and further developing the culture of accident
prevention. [S2:S2-3_27_a] [S2:S2-3_27_d]
b) Risk identification using safety tools, intended to prevent dangerous actions and situations that could lead to accidents or
occupational diseases, described in a series of internal procedures in each Sector for both direct and value chain workers
and partners. For instance: Hierarchy Safety Visits, Risk Identification and HSEP Inspections of value chain workers (Health,
Safety and Environmental Plans), Written Occupational Risk Assessment prepared in accordance with the respective
procedure and existing for each job, the Energy Center Risk Management and the RES Station Work Instruction. [S2:S2-3_27_a]
[S2:S2-3_27_d]
c) Reporting of risks and hazardous situations, where identified, in order to take immediate action to remediate them and
prevent recurrence, as defined by the reporting system of the Group's Code of Business Conduct. [S2:S2-3_27_a] [S2:S2-3_27_c]
d) Investigating work-related accidents, where procedures are followed to record them in the accidents log, procedures for
announcing and analysing incidents, procedures for characterising and investigating incidents, and, at a higher level,
incidents are selected to be analyzed using a tree of causes. [S2:S2-3_27_a] [S2:S2-3_27_d] [ESRS2:MDR-A_68_d]
e) Determining appropriate corrective actions based on the above investigation process, to identify the required
improvements in the OHS management system. [S2:S2-3_27_a] [S2:S2-3_27_d]
B. Complaints mechanism
METLEN provides several channels for reporting OHS issues. The channels are a single access gateway for both direct and value
chain workers and are a common structure for all Sectors and Subsidiaries, and include digital platforms for instant reporting of
issues, sending anonymous messages via a dedicated email address and the ability to send letters or meet with the Compliance
Director. This ensures that the need for managing OHS issues with transparency and constant communication is fully met.
Complaints can be submitted directly to the Regulatory Compliance Division in consultation meetings or using METLEN's
whistleblowing mechanism through the Group's website. By implementing the above approach and in the context of its relevant
Policy for the internal reporting channel, METLEN is committed to protecting those who submit a complaint and to not taking
measures that may adversely affect them as retaliation. Specifically, the Occupational Health and Safety Committee (OHSC)
operates as the main complaint/complaint management mechanism on Health & Safety issues within plants and mines, with
direct communication of employees with the committee as well as with the plant's Safety Engineer. All subcontractors are
informed of the existence of communication channels either at the beginning of the cooperation or through the regular meetings
and briefings that take place. [ESRS2:MDR-A_68_d] [S2:S2-3_27_a] [S2:S2-3_27_b] [S2:S2-3_27_c] [S2:S2-3_27_d] [S2:S2-3_28]
5. Annual Board of Directors Management Report
253
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
ACTIONS AND RESOURCES
S2-4
Taking action on material impacts on value chain workers, and approaches to managing material risks
and pursuing material opportunities related to value chain workers, and effectiveness of those actions
The following are individual actions and practices implemented annually, covering all of METLEN's activities in Greece and abroad,
and aimed both at preventing and mitigating the negative impact on value chain workers, i.e. employees employed by METLEN
contractors who operate within its facilities or construction sites. The following initiatives help effectively address material risks
that may arise and enhance the overall corporate OHS culture, which gradually extends to the Group's direct value chain. In
addition, the implementation of the special action plans in the Energy and Metals Sectors (including their subsidiaries) and in the
main subsidiary METKA ATE contributes substantially to meeting the objectives and goals of METLEN's Health and Safety Policy,
improving training, organization, infrastructure safety, communication and integration of OHS processes, also including value
chain workers, thus creating a strong web of actions benefiting all employees of the Group as a whole. [S2:S2-4_35] [S2:S2-4_36]
[ESRS2:MDR-Α_68_a] [ESRS2:MDR-Α_68_b]
In the Metals Sector, the integrated OHS continuous actions implemented at the plant are: 1) adoption of internationally
recognized industry standards such as those of the Aluminium Stewardship Initiative (ASI); 2) training and awareness-raising of
employees on specialized OHS issues; 3) improving the management of facilities and equipment to enhance safety; 4) enhancing
employee communication and participation in information campaigns. [S2:S2-4_31] [ESRS2:MDR-A_68_a] [ESRS2:MDR-A_68_b] [ESRS2:MDR-
A_68_d] [S2:S2-4_32_a] [S2:S2-4_32_b] [S2:S2-4_32_c]
In the Energy Sector, the integrated OHS actions implemented as mentioned in section ESRS:S1-14 also include value chain
workers and in particular 1) training and awareness-raising of employees on specialized OHS issues; 2) upgrading procedures and
consolidation of OHS protocols; 3) improving infrastructure and working conditions; 4) enhancing the organization and
supervision of work; 5) evaluation and monitoring of the effectiveness of OHS actions through internal and external inspections;
6) certification of new activities. [S2:S2-4_31] [ESRS2:MDR-A_68_a] [ESRS2:MDR-A_68_b] [ESRS2:MDR-A_68_d] [S2:S2-4_32_a] [S2:S2-4_32_b] [S2:S2-
4_32_c] [S2:S2-4_32_d]
In subsidiary METKA ATE, the integrated OHS actions, which are implemented and include: 1) training and development of
employees, 2) work supervision, 3) information, communication and participation of value chain workers in collecting information
from construction sites, there are also regular briefings on risks and prevention measures, with the aim of reducing accidents,
and participation of employees in organized awareness-raising actions on OHS issues. [S2:S2-4_31] [ESRS2:MDR-A_68_a] [ESRS2:MDR-
A_68_b] [ESRS2:MDR-A_68_d] [S2:S2-4_32_a] [S2:S2-4_32_b] [S2:S2-4_32_c] [S2:S2-4_32_d]
In the Central Functions, the application of an Occupational Risk Assessment Design (MEEK) to identify all potential risks in the
workplace, related to the Safety and Health of the Group's personnel working at the Group's headquarters and offices, also
includes subcontractor employees. [S2:S2-4_31] [ESRS2:MDR-A_68_a] [ESRS2:MDR-A_68_b] [ESRS2:MDR-A_68_d] [S2:S2-4_34_a]
In 2024, the Group proceeded to significant investments and expenditures for the improvement of the Health & Safety conditions,
as described in detail in the relevant texts of the S1-4 section of this Sustainability Statement by Business Sector. These conditions
concern both drect and value chain workers. [S2:S2-4_38] [ESRS2:MDR-A_69_b]
METRICS & TARGETS
S2-5
Targets related to managing material negative impacts, advancing positive impacts, and managing
material risks and opportunities
METLEN's key Occupational Health & Safety (OHS) targets are an integral part of its strategy to ensure a safe, healthy and
productive working environment. METLEN recognizes the importance of its human resources, including the employees of its
subcontractors, and is committed to continuously improving working conditions, reducing risks, and promoting the overall well-
being of its employees; while expecting a similar commitment from its subcontractors through the agreements it concludes with
them, which reflect the high safety standards required from anyone doing business with the Group. The following key Health &
5. Annual Board of Directors Management Report
254
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Safety targets of METLEN are annual and focus on enhancing protection for value chain workers through improved safety
measures and preventive actions.
LTIR - Lost Time Incident Rate: Accidents with loss of working time of >3 days.
TRIR – Total Recordable Incident Rate: This includes fatalities, serious accidents and all accidents that resulted in days away from work, limited work or transfer
to another job, medical care other than first aid or loss of consciousness or significant injury or ill health diagnosed by a doctor or other authorized healthcare
professional. This includes cases of fatalities and accidents that occurred during the employee's travel from their place of private activity (e.g. residence) to their
place of work and only when such travel has been organized by METLEN or by the with METLEN contractor where the person is employed.
The targets include all METLEN Sectors and Subsidiaries. [ESRS2:MDR-T_80_c] [ESRS2:MDR-M_80_d] [ESRS2:MDR-T_80_f] [ESRS2:MDR-M_77_a] [ESRS2:MDR-
T_AR_24] [ESRS2:MDR-T_AR_25] [ESRS2:MDR-T_AR_26]
The process of setting central targets for METLEN's Safety and Health indicators began in June 2022, with the proposed targets
put to consultation by HSE Division to all HSE managers of the Group's Sectors and Subsidiaries, who are also responsible for the
cooperation with permanent subcontractors on OHS issues. The consultation cycle was completed in September 2022, with the
approval of the central targets by the General Managers of Sectors and Subsidiaries.
The targets
151
are divided into absolute and relative. Absolute targets (zero fatalities, serious accidents, and occupational
diseases) are defined in absolute values with a target of zero. Relevant targets, such as LTIR and TRIR, are identified in number
of incidents per 200,000 hours worked, with specific ceilings to achieve optimal safety of value chain workers. [ESRS2:MDR-T_80_b]
Also, targets are directly linked to the Group's Health & Safety Policy, which is the basis for the development and implementation
of all relevant initiatives and actions as well as the operating framework, setting the Group's principles and priorities regarding
the care for the Health and Safety of value chain workers. In particular, METLEN’s H&S Policy emphasizes accident prevention
and continuous improvement of workplace safety. The quantitative targets for preventing fatalities and serious accidents as well
as the indicators for reducing the frequency of accidents on an annual basis are also an expression of this commitment.
151
It is noted that the targets are not specified with reference to a particular base year. However, since the targets are annual, progress measurement begins
from the current calendar year as a reference point, with the aim of continuously monitoring and achieving these targets by the end of the year. [ESRS2:MDR-
T_80_d] [ESRS2:MDR-T_80_e]
0
0
0
≤0.3
≤0.6
SERIOUS
ACCIDENTS
INVOLVING VALUE
CHAIN WORKERS
2024 CENTRAL ANNUAL CORPORATE HEALTH & SAFETY TARGETS
FATALITIES OF
VALUE CHAIN
WORKERS
OCCUPATIONAL
DISEASES OF VALUE
CHAIN WORKERS
LTIR/PER
200,000
WORKING
HOURS
TRIR/PER
200,000
WORKING
HOURS
5. Annual Board of Directors Management Report
255
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Furthermore, METLEN's H&S Policy emphasizes the importance of complying with OHS regulations and standards. The Group's
targets are directly linked to this commitment, as they include fully assessing risks, implementing preventive measures, and
supporting incident reporting by the value chain workers of its subcontractors, ensuring that METLEN fully complies with the
applicable legislative requirements. [ESRS2:MDR-T:80_a]
In addition, the targets are directly related to the prevention and mitigation of social impacts, with a focus on value chain workers'
human rights Since the issue of H&S is a core labour right and is included in the Group's Human Rights Policy, these targets are
identified based on the impact on human rights, well-being and positive outcomes for affected stakeholders, such as employees,
local communities and suppliers, including their partner contractors and their employees. The absolute targets, as mentioned
above, reinforce value chain workers' right to a safe and healthy working environment, which is a key element of the International
Declaration of Human Rights and International Labor Organization (ILO) Conventions. Similarly, the relevant targets enhance
employee well-being, as they reduce the incidence of injuries and ensure better working conditions. [S2:S2-1_17_a] [S2:S2-1_ΑR_24]
In defining its core Health and Safety targets, METLEN relied on the following factors: a) identification and assessment of
workplace risks, by studying data from accident analyses, safety checks and disease reports, identifying the areas with the highest
risk levels; b) integration and analysis of historical data on the OHS performance of each Sector and Subsidiary of the Group,
allowing the adjustment of targets to specific needs and challenges; c) analysis of the respective practices and performance of
similar enterprises with the Group's Sectors, which provides valuable insights in the implementation of effective and best
prevention practices; d) the specifications of international standard ISO 45001, according which METLEN's Health and Safety
Management System is certified. [ESRS2:MDR-T_80_f]
Regarding the scope
152
of the targets, they apply to all METLEN’s units, including all countries of operation, covering plant
facilities, construction sites, offices, stores and all related functions related to the production, distribution, and provision of the
Group’s services. They also cover all value chain workers employed in the Group's activities. [ESRS2:MDR-T_80_c]
METLEN's annual OHS targets have been designed with both the broader context of sustainable development and the local
conditions in which the Group's activities are implemented in mind. These targets are not just numerical but reflect METLEN's
commitment to creating a safe and supportive work environment, centred on people and society, to respecting the environment.
Zero targets for fatalities, serious accidents, and occupational diseases are in line with the Sustainable Development Goals, in
particular UN Goal 8 (Decent Work and Economic Growth), which promotes the creation of safe and decent working conditions
for all value chain workers of the Group. Zero tolerance for accidents and illness signals METLEN's commitment to fostering a
work environment where safety and health are priorities. Also, the relevant LTIR and TRIR indicators, which aim for extremely
low accident levels, reinforce the Group's approach to systematically measure and improve safety conditions, linking its practices
to international standards for occupational safety and well-being. These targets comprehensively incorporate the concept of
human-centred development, focusing on workforce well-being as a critical part of overall business sustainability. Promoting a
safe working environment helps increase productivity, reduce absenteeism due to illness or accident, and enhance the long-term
sustainability of the Group. [ESRS2:MDR-T_80_f]
METLEN's contractors, as well as their employees, participate in meetings and trainings held within the framework of the Health
and Safety (H&S) management system, while receiving feedback regarding the relevant goals set by the Group, the indicators it
monitors, and the measures it takes to improve working conditions and prevent accidents. [MDR-T_80_h] [S2:S2-5_42_a] [S2:S2-5_42_b]
[S2:S2-5_42_c]
Action Results
METLEN addresses the safety management of independent contractors’ employees as a particular challenge, focusing on
establishing an OHS culture that promotes the prevention of accidents by enhancing the personal responsibility of each employee
and developing a preventive safety culture among all involved.
As a result of this integrated approach for 2024, the Group met its targets for value chain workers. Specifically, there were zero
fatalities, and no employees were exposed to activities entailing a risk of work-related diseases, thus highlighting the
effectiveness of the Group's preventive measures and risk management.
152
An exception to the scope is the subsidiary of the Energy Sector, UNISON, which was recently acquired (in 2024) by METLEN. This specific subsidiary has not
yet aligned with METLEN's ESG framework, and therefore these targets do not currently apply to its activities. The alignment of the subsidiary with METLEN's
overall ESG framework is underway and is expected to be included in the scope of the targets in the future.
5. Annual Board of Directors Management Report
256
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Regarding accidents that result in serious consequences for the lives of value chain workers, an incident of contact with electricity
during work occurred in 2024, where first aid was provided on the spot and the employee was immediately transported for
medical treatment to a hospital. The investigation of the incident is in progress and is being carried out by a qualified expert,
while the employee returned to his duties at the end of 2024. In the context of incident management, the subcontractor’s staff
was immediately updated and retrained to ensure proper compliance with safety procedures. In addition, a relevant Safety Alert
by the project owner, in both Greek and English, was notified to all ongoing projects of the same contractor, throughout Greece,
to strengthen safety measures. Regarding incidents of bone fractures and minor injuries, these were handled in accordance with
the procedures of each segment and the employees involved returned to performing their duties after ensuring their full recovery
and compliance with the required safety measures in the workplace. [ESRS2:MDR-A_68_a] [ESRS2:MDR-A_68_b] [ESRS2:MDR-A_68_c]
[ESRS2:MDR-A_68_d]
In 2024, there was a rise in incidents with ≥3 days lost time from 11 in 2023 to 23, which is associated, among other things, with
the intensification of the Group's activities and the overall increase in the working hours of value chain workers by 17%. The
enlargement of the business footprint results in greater exposure to occupational risks, while the development of new
partnerships and the implementation of demanding projects appear as the main factors that influence safety indicators. The
Group closely monitors trends in accident indices and strengthens prevention measures, focusing on targeted interventions to
improve the safety of value chain workers. Note that most accidents resulted in limb fractures/sprains without further serious
consequences for employees, while the frequency rate of these accidents (per 200,000 hours worked) was once again below the
set annual target. However, although such incidents are not considered particularly serious, they have a disproportionate impact
on the number of working days lost since they require long recovery periods due to the physical rehabilitation requirement,
which explains the difference between the low frequency rate and the increase in days lost compared to 2023 as shown in the
table below.
All incidents were analyzed using the “Tree of Causes Analysis" method to ensure that root causes were recorded and the
investigation results disseminated to increase employee awareness. The main remedial measures depending on the type of
incident, the Sector or the Subsidiary where the incident occurred, include: a) informing facility staff about the incident; b)
training staff about the risks and necessary protection measures associated with the incident; c) adapting and/or revising the
relevant instructions; d) informing supervisors about increased surveillance of workplaces; e) training staff on the proper use of
Personal Protective Equipment; f) marking spaces for works at height, lifting of loads, scaffolding work; and g) setting up and
tidying up the work space (e.g. signage, cleaning, etc.).
In 2024, 16,104,952 indirect employee hours were recorded across all Group activities including those identified within the
upstream and downstream value chain as presented in section SBM-1: Strategy, Business Model, Value Chain. The percentage of
employees covered by the OHSS
153
(ISO 45001-2018) within 2024 stood at 98.9%.
Employee Health and Safety Scoreboard
%N/N-1
2024
2023
2022
Total fatalities
154
0%
0
0
0
Fatal Incident Frequency Rate / 1,000,000 hours
worked
0%
0.00
0.00
0.00
Fatal Incident Frequency Rate / 200,000 hours
worked
155
0%
0.00
0.00
0.00
Total incidents with serious consequences on the lives of
employees
-
1
0
0
Incident Frequency Rate with serious consequences on
the lives of employees / 1,000,000 hours worked
-
0.05
0.00
0.00
Incident Frequency Rate with serious consequences on
the lives of employees / 200,000 hours worked
-
0.01
0.00
0.00
Total Recordable Incidents (TRIs)
+30.8%
34
26
12
153
Occupational Health and Safety System (OHSS)
154
Due to work-related accidents and health issues
155
All frequency indicators based on 200,000 working hours are published for monitoring the targets related to work-related accidents, fatalities, and health incidents as
mentioned in the relevant section.
5. Annual Board of Directors Management Report
257
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Men
33
26
12
Women
1
0
0
Total Recordable Incident Rate / 1,000,000 hours worked
(TRIR)
+10.5%
2.11
1.90
2.4
Men
2.11
1.95
0.53
Women
2.14
0.00
0.00
Total Recordable Incident Rate / 200,000 hours worked
(TRIR)
+10.5%
0.42
0.38
0.48
Men
0.42
0.39
0.53
Women
0.43
0.00
0.00
Total incidents with ≥3 days lost time (LTI)
+109.1%
23
11
14
Men
23
11
14
Women
0
0
0
Lost Time Incident Rate with ≥3 days lost time /
1,000,000 hours worked (LTIR)
+68.7%
1.35
0.80
1.13
Men
1.40
0.85
1.23
Women
0.00
0.00
0.00
Lost Time Incident Rate with ≥3 days lost time / 200,000
hours worked (LTIR)
+68.7%
0.27
0.16
0.23
Men
0.28
0.17
0.25
Women
0.00
0.00
0.00
Total work-related near misses
+76.8%
168
95
100
Total work-related health incidents
-
0
0
0
Work-related illness incident frequency rate / 1,000,000
hours worked
-
0
0
0
Work-related illness incident frequency rate / 200,000
hours worked
-
0
0
0
Total work days lost
156
+209.9%
1,190
384
263
Men
1,190
384
263
Women
0
0
0
[ESRS2:MDR-T_80_j] [ESRS2:MDR-T_AR_24] [ESRS2:MDR-T_AR_25] [ESRS2:MDR-T_AR_26]
In addition, recording, investigating, and analysing near misses by the Group is important to improve safety conditions, as it
provides valuable information on potential risks and potential weaknesses in safety practices. In this context, the role of
employees is very important, as within the existing corporate safety culture that encourages the reporting of relevant risks -
combined with the commitment to achieve OHS objectives, effective implementation of relevant policies, systems, procedures
and instructions, as well as the value of consultation and the "open doors" approach to reporting and identifying near misses -
they help the Group identify potential problems before they develop into serious accidents.
In 2024, the number of near misses increased considerably, a fact that is attributed to individual improvements to strengthen
the reporting culture of near misses, so as to take actions and measures to enhance safety, adapt training initiatives to prevent
risks that potentially contribute gradually to reducing the occurrence of dangerous incidents. All incidents were analyzed and
relevant prevention actions were implemented where necessary.
At the same time, leveraging the findings of planned or emergency safety audits carried out by specially trained Group staff, and
by customers, partners, public bodies and independent audit and assurance organizations, contributes to further improving the
level of OHS, formulating and renewing relevant procedures and ultimately implementing necessary actions and activities.
156
Due to injuries and accidents from work-related incidents, health issues related to work, and deaths due to health problems.
5. Annual Board of Directors Management Report
258
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In total, 75 (2023: 53) employees visited the doctor's office (first aid), a number increased compared to 2023.
Inspections and internal audits, whether planned or ad hoc, are applied (as referred to in chapter S1-14) both to the workforce
concerned and to the employees of METLEN's permanent subcontractors. The audits are carried out as part of internal
procedures by trained personnel of the Group or by contracted partners, but also in the context of the certification of OHSSs. At
the same time, specialized field inspections are carried out on all projects and infrastructures of the Group, the total number of
which for OHS-related issues was 8,881 in 2024.
As in previous years, 2024 was again a year of special emphasis on preventing accidents at work through training. In all the
Group’s Sectors and Subsidiaries, 75,728 man-hours of Health and Safety training were performed, with the participation of
value chain workers, increased by 22% compared to the previous year (2023: 62,100). The increase is related to the target of
continuously improving corporate performance on this issue, the expansion of METLEN's activities in more countries worldwide,
but also new projects undertaken for which staff training on OHS issues is required. Training programs are distinguished into
general and special with different goals and content. General training programs discuss the basic principles and rules that all
employees should know regardless of their position or type of work and provide general knowledge on workplace risks and
prevention. Special training programs focus on specialized knowledge and skills required to safely perform specific tasks or to
address specialized risks.
Training of office employees covered general OHS issues, while training of employees in production units and construction sites
included, among others, the following topics:
Table of employee Health and Safety training topics
General training
Program man-hours
22,904
Main topics:
General occupational hazards, use of Personal Protective Equipment (PPE), emergency and evacuation
plans, basic fire safety principles, corporate goals (eg zero accidents), types of accidents and reports,
emergency telephone numbers and OHS policies.
Special training
Program man-hours
52,824
Main topics:
ISO45001 System Management | Reporting Near Misses – Unsafe | Actions/Conditions | Accident, Injury
First Aid | Fire and emergency | Fire Prevention - Fire Suppression | Environmental Parameters | Risk
Assessment - Working Methods | Contingency plans | Site evacuation plan | Personal Protection Equipment
| Main site works | Safety on site | Safety signage | Hazardous materials safety signs | General Site Rules |
Order on Site | Manual handling of loads | Use of tools | Work at height, in confined spaces, underground
| Major Risks (Electricity, Excavations, Project Machinery-vehicles) | Slips, Trips & Falls | Loading-Unloading
| Written occupational risk assessment | On-site risk assessment | Working with ladders | Working in
extreme weather conditions (heat, cold) | Risk Identification | Safe pedestrian traffic | Musculoskeletal risks
| Mental health at work
Finally, as part of the process of evaluating key METLEN suppliers with ESG criteria to reflect their level of maturity in sustainability
issues, 259 key suppliers completed the process within the three-year period 2022-2024, which revealed that in relation to the
management of OHS:
a) a significant percentage of 91% has a mechanism for monitoring and recording accidents, fatalities and occupational diseases,
b) 91% has a Health & Safety Policy,
c) 69% has a certified Occupational Health & Safety Management System (e.g. certification according to ISO 45001) while,
d) 6% is in the process of certification.
As part of the assessment, suppliers are also asked to answer whether they have a Policy/Statement of Commitment to
Respecting and Protecting Human Rights; more information on that is available in the “Responsible Supply Chain” section of this
report.
5. Annual Board of Directors Management Report
259
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
AFFECTED COMMUNITIES [ESRS: S3]
As a responsible Group operating in the Energy and Metals sectors, METLEN recognizes the critical role that local communities
play in the success and sustainability of its operations. The Group is committed to managing relationships with communities with
respect, transparency and collaboration, seeking to minimize any negative impact. At the same time, METLEN focuses on
promoting positive social and economic impacts, contributing, proportionally to its role, to the social well-being and development
of its local communities.
STRATEGY
SBM-3
Material impacts, risks and opportunities and their interaction with strategy and business model
METLEN has a long tradition of creating value for local communities. Through its numerous initiatives, the Group continues to
contribute to the economic and social development of these communities. During the reporting year, METLEN recorded no
material negative impact on local communities, demonstrating its commitment to respecting their rights. This is due to carefully
designed policies and effective cooperation with affected communities, ensuring that the Group's activities are carried out in
accordance with the principles of sustainable development, as outlined in its relevant strategy. Given that METLEN's business
strategy includes expansion into new countries and regions with diverse social backgrounds, the Group ensures the preservation
of positive impacts by developing partnerships with communities identified as potentially affected. This approach enables
METLEN to timely recognize and appropriately manage any emerging challenges.
ACTUAL POSITIVE IMPACTS [EP5]
157
Creating Value in local communities [SBM-3_48_c-iii]
a) This positive impact is closely linked to METLEN's strategy and business model. The Group's sustainable development
strategy emphasizes the development of its local communities, which are a key element of its Social Capital that supports the
long-term sustainability of its activities. METLEN operates in a way that integrates, to the extent appropriate, the needs of
local communities into its business model, contributing to their development through infrastructure projects and the
implementation of social programs, mainly in areas that host its industrial plants and construction sites, or where new
Renewable Energy projects are about to be developed. Thus, value creation for local communities is not just a side effect of
business activities, but is organically integrated into the Group's strategy, aiming at long-term success and positive
contribution to the well-being of communities. This two-way relationship enables METLEN to enhance social acceptance of
its business and improve its business operation by adapting its business model locally. [SBM-3_48_c-ii]
b) In terms of business relationships, METLEN works with local suppliers, partners and subcontractors, strengthening the local
economy, as well as with local authorities, NGOs and voluntary organizations to develop and implement social and
environmental programs and initiatives. [SBM-3_48_c-iv]
Time Horizon:
Actual
Position in the Value Chain:
Own Operations, Downstream
FINANCIAL OPPORTUNITY [S3-O1]: Facilitation of business activity and development
Financial Significance:
Very high
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Own Operations, Downstream
FINANCIAL OPPORTUNITY [S3-O2]: Enhancement of productivity through the utilization of local workforce
Financial Significance:
Very high
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Own Operations, Downstream
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS
MODEL & VALUE CHAIN
[S3: SBM-3_9_d] [SBM-3_48_b]
CURRENT AND POTENTIAL IMPACT ON STRATEGY & DECISION
MAKING
[SBM-3_48_b]
157
As they result from the double materiality assessment (see [ESRS2:SBM-3] & [ESRS2:IRO-1])
5. Annual Board of Directors Management Report
260
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
a) Ensuring social acceptance of the Group's business
activity.
b) Enhancing corporate image and reputation.
c) Contributing to the reduction of social tensions and
maintaining a stable business environment.
d) Supporting local economies by creating mutually
beneficial relationships that strengthen the supply
chain by attracting and retaining partners and ensuring
quality.
e) Employing a local workforce and providing training
opportunities that lead to higher levels of employee
engagement and productivity.
a) Integrating socially responsible practices into the Group's
strategy, thus enhancing alignment with international
trends of sustainable development and corporate
responsibility.
b) Enhancing the Group's adaptability by regularly
incorporating feedback from local communities into its
decision-making (through stakeholder consultation) to
respond as best as possible to the needs and expectations of
local populations.
c) Integrating social and environmental criteria into the
decision-making process.
d) Making necessary investments in sustainable and
responsible business practices to ensure the long-term
viability of the business.
In addition, the Group's ability to create positive impacts on local communities, through social investment and support of local
employment, enhances the resilience of its strategy and business model in a dynamically changing business environment.
Corporate responsibility focusing, among others, on the integration of social parameters in its business activity is an integral part
of METLEN’s operation. With targeted social investments, the Group strengthens local communities, offering direct support and
contributing its fair share to social cohesion. This strategy enhances METLEN's resilience, as it forms a strong network of trusting
relationships with local communities and institutional actors. Local employment is also a critical element of METLEN's resilience.
By creating and maintaining jobs, as well as investing in upskilling the workforce, the Group strengthens local economies and
creates a stable and flexible workforce. This approach ensures METLEN's continued adaptability to market demands and its ability
to address challenges. [SBM-3_48_f]
For METLEN, the local communities where positive effects are recognized are primarily Aspra Spitia on the Distomo coast, given
its vicinity to the alumina and aluminium industrial production facilities, as well as the Group's energy centre. The settlement was
originally created in 1963 to accommodate the families of the Aluminium of Greece plant employees, as a model community with
advanced infrastructure and a high standard of living. It is located at Distomo-Antikyra in the Prefecture of Viotia, Region of
Central Greece, and after two extensions it has become a modern town with more than 3,000 inhabitants. It covers an area of
61.3 hectares with 1,072 houses as well as schools, shops, cultural and sports facilities, and the first ever biological wastewater
treatment plant in Greece. The settlement is used exclusively by the Group's employees and their families, and to this day remains
a symbol of sustainable development and social prosperity, with the Group constantly upgrading its infrastructure, thus
strengthening its relationship with the local community. [S3:SBM-3_9_a_i] [S3:SBM-3_9_a_ii]
METLEN is the main driver of economic activity in the Antikyra and Distomo area. By creating jobs both in the plant and the
energy centre, as well as in support services, the Group significantly strengthens local employment. Furthermore, cooperation
with local businesses for the supply of goods and services boosts local market development. With these activities, METLEN
contributes to local value creation, ensuring sustainable development and continuous improvement of the quality of life of local
residents. Other communities located near the industrial facilities of the Metals and Energy Sectors, the Group’s construction
activities and renewable energy projects (RES) consist mainly of sparsely or densely populated provincial settlements. Also, the
Group's construction sites are found in provincial areas, but also in areas within the urban fabric of cities, especially in cases of
infrastructure project development, such as the construction or renovation of building complexes, road network, etc. [S3:SBM-
3_9_a_i] [S3:SBM-3_9_a_ii]
The Group's mining activity as part of the upstream value chain includes underground operations in Greece and specifically in
the Prefecture of Fokida, Region of Central Greece, conducted by subsidiary companies Delphi-Distomon and European Bauxites,
which was created following the acquisition of IMERYS Bauxites Greece. With these operations, the Group supports local
economy and growth by continuously offering new employment opportunities and improving the infrastructure, quality of life
and social well-being of residents as a whole. As part of the above acquisition, METLEN also obtained in 2024 the Vagonetto Fokis
Mining Park, which has been in operation since September 2003. It is a unique theme park in Greece in the Giona-Parnassos col,
at the 51st km of the Lamia-Amfissa national road, Prefecture of Fokida, Region of Central Greece. The purpose of the Fokis
Mining Park is not only to exhibit the working spaces of a mine to the public, but also to inform, entertain and educate younger
generations on the history of bauxite exploitation and the people who worked in the mines, honouring and showcasing the mining
history of Fokida. Touring the Vagonetto introduces visitors to the process of bauxite mining, step by step. Learning about the
history of bauxite starts from the old mine,
5. Annual Board of Directors Management Report
261
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
gallery 850, continues with a tour of the Mining History Exhibition Area and ends with a visit to the Digital Technology Wing. In
2024, Vagonetto received 9,744 visitors, mostly young people and students of all education levels, as part of the annual student
excursions. With Vagonetto, METLEN takes up the important role of connecting with the younger generation, continuing to
promote knowledge and understanding of the mining sector, while honouring and highlighting the rich mining history of Fokida.
[S3:SBM-3_9_a_iii]
IMPACT, RISK & OPPORTUNITY MANAGEMENT
S3-1
Policies related to affected communities [S3: MDR-P_01-06]
The Group has developed and implements a series of policies aimed at preventing negative impacts and maximizing positive
ones, while ensuring that its activities are aligned with the values of responsible entrepreneurship and sustainable development.
These policies are designed to promote transparency, fairness and respect for the rights of local communities, thus strengthening
the relationship of trust and cooperation with them. The term “affected local communities” means those local communities
located a) close to farther away from the locations of METLEN’s energy and metallurgy industrial plants, b) close to the metal
mining activity on the upstream side of the Metals Sector’s value chain, c) near the Energy Sector’s construction sites of energy
and RES projects in Greece and abroad. [S3: SBM-3_9a]
METLEN’s continuous business development, which apart from financial is also geographical, requires the continuous monitoring
of the policies’ implementation and the re-evaluation of their adequacy, to be able to show that they are inclusive and
appropriate to manage the changing social environment in which the Group operates. In this direction, the Group recognizes the
need to consider specific parameters of indigenous populations in the development of new projects, as its international business
presence to date does not include any activity implemented in indigenous population settlement areas. However, the Group
recognizes the particular importance of protecting and supporting these communities and is committed to adapting its practices
within the next year to reflect this recognition. [S3:SBM-3_9_a_iv] [S3:S3-1_15]
Policies are implemented to ensure that the Group timely identifies and effectively manages the often-changing social, economic,
and cultural specificities of the local communities in which it operates. In doing so, the Group strengthens its position as an
integral member of these communities with shared interests, ensuring the retention of its "social license" to operate while
supporting both its current activities and sustainable future growth. [S3:S3-1_14] [ S3:S3-1_15]
These policies are integrated into METLEN's day-to-day operations and designed to generate positive value for affected
communities. Through these policies, METLEN seeks to enhance economic and social development, improve the quality of life of
local populations and protect the environment. This approach contributes to building a positive footprint in its areas of activity,
ensuring that communities benefit from the Group's presence. [S3:S3-1_14] [ S3:S3-1_15]
More information regarding consultation with local communities is available on the Group's website
158
.
HUMAN RIGHTS POLICY
Year of update
2021
Key Content
[MDR-P_65_a]
METLEN has zero tolerance for Human Rights violations, which materializes both by the non-participation
(direct, passive or tacit) of the Group in relevant violations, and by avoiding any transaction and contact
with third parties that may have caused, or there are reasonable grounds to suspect that they may
participate in creating conditions that may cause, violations of these rights.
Targeting
[MDR-P_65_b]
Through its Human Rights Policy, METLEN:
1) Recognises its influence on the communities in which it operates and is committed to working
with stakeholder groups in those societies to ensure that it receives, records and considers their views and
expectations when doing business. [S3:S3-1_16] [ S3:S3-1_16_b]
2) Is committed to communicating and consulting with affected communities, before and during its
activities, to prevent, mitigate and eliminate potential negative impacts of its operation by taking
appropriate measures. It is also committed to respecting and supporting the rights of its local
communities regarding land use, use of natural resources and especially water, as well as the preservation
of local cultural heritage as key elements of their sustainability. [S3:S3-1_16_c]
158
https://www.metlengroup.com/sustainability/our-approach/our-relationship-with-stakeholders/
5. Annual Board of Directors Management Report
262
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
3) Ensures that appropriate measures are taken to address the concerns of local communities
regarding any negative impact of its activities on the citizens' access to resources or other methods of
living, and where necessary, commits to engage in dialogue with the stakeholders of its local communities
on human rights issues related to its activity. [S3:S3-1_16_c] [S3.SBM-2_7]
Governance
[MDR-P_65_c]
a. Executive Leadership Team
b. Sustainability Committee of the Board of Directors
c. Human Resources General Division
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
[S3:S3-1_17]
a. United Nations Universal Declaration of Human Rights
b. Basic Conventions of the International Labour Organization (ILO)
c. Principles of the UN Global Compact
d. Sustainable Development Goals (2030 Agenda)
e. United Nations Guiding Principles on Business and Human Rights
f. Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational
Enterprises
g. United Nations Convention on the Elimination of All Forms of Discrimination against Women
(Article 11 - field of employment)
Inclusion of Stakeholder
interests
[MDR-P_65_e]
This Policy was developed considering the opinion of METLEN’s main Stakeholder groups, following a
special consultation held in 2021.
Availability
[MDR-P_65_f]
Corporate Website
159
, Internal Information Portal (intranet)
CORPORATE SOCIAL RESPONSIBILITY POLICY (CSR)
Year of update
2023
Key Content
[MDR-P_65_a]
Recognition of CSR as a fundamental factor contributing to the prevention of social, environmental and
human resource management risks and METLEN's presence in the market, contributing to the creation of
an environment of trust in which it can operate and innovate, creating value for all its Stakeholder groups.
Targeting
[MDR-P_65_b]
Through its Corporate Social Responsibility Policy, METLEN outlines its strategic axes of activity, which are
related to its broader contribution to the development of local infrastructure and to the overall prosperity
and respect of the rights of citizens of local communities adjacent to the Group's industrial plants and
construction sites.
Governance
[MDR-P_65_c]
a. Sustainability Committee of the Board of Directors
b. Corporate Governance & Sustainable Development General Division
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
a. Principles of the UN Global Compact
b. Sustainable Development Goals (2030 Agenda)
c. CSR Standard ISO26000 Guidelines
Inclusion of Stakeholder
interests
[MDR-P_65_e]
In the context of supporting and further strengthening CSR Policy, METLEN voluntarily participates,
collaborates, and supports Corporate Social Responsibility & Sustainable Development initiatives/bodies,
while its performance is annually reported in the context of special evaluations from independent
international organizations based on ESG criteria.
Availability
[MDR-P_65_f]
Corporate Website
160
, Internal Information Portal (intranet)
RESPONSIBLE SUPPLY CHAIN POLICY
Year of update
2023
Key Content
[MDR-P_65_a]
It defines the way in which METLEN chooses to cooperate and procure, based on the recognition that, for
the Group, the creation of a responsible supply chain is a key pillar of its overall Sustainable Development
Strategy and the pursuit of continuous improvement.
Targeting
[MDR-P_65_b]
With its Responsible Supply Chain Policy, METLEN prioritizes cooperation with local suppliers and
encourages small and medium-sized enterprises -where possible and depending on the scope and type of
supply required - to cooperate with it, thus strengthening local entrepreneurship wherever it operates. At
the same time, it supports its suppliers and partners, where possible, including enhancing their awareness
and skills on Sustainable Development issues through the adoption of best relevant practices.
Governance
[MDR-P_65_c]
a. Board of Directors
b. Sustainability Committee of the Board of Directors
159
https://www.METLENgroup.com/media/rp3edd3u/politiki_anthrwpinwn_dikaiwmatwn_en.pdf
160
https://www.METLENgroup.com/media/wiglbyqn/mytilineos_csr-policy_2024_eng.pdf
5. Annual Board of Directors Management Report
263
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
c. Sustainable Development Division
d. Internal Audit Division
e. Compliance Division
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
[S3:S3-1_17]
a. United Nations (UN) Universal Declaration of Human Rights
b. International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work
c. United Nations Guiding Principles on Business and Human Rights (UNGP)
d. United Nations Global Compact
e. Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational
Enterprises
Inclusion of Stakeholder
interests
[MDR-P_65_e]
This Policy was developed considering the opinion of METLEN’s key Stakeholder groups, following a
dedicated consultation in 2023.
Availability
[MDR-P_65_f]
Corporate Website
161
, Internal Information Portal (intranet)
Attachment of the Policy to all tenders and supply contracts
STAKEHOLDER CONSULTATION PROCEDURE
Year of update
2024
Key Content
[MDR-P_65_a]
[S3:S3-1_16]
[S3:S3-1_16_b]
Detailed description of the individual stages of the Stakeholder Consultation process, along with the
expression of METLEN's long-standing commitment to interact with its Stakeholders through a systematic
and honest dialogue, which is a key prerequisite for achieving its strategic short-term and long-term goals
and thus ensuring its sustainability.
Targeting
[MDR-P_65_b]
Describes the main activities followed in order for METLEN to operate in a safe, agile and consistent
manner, avoiding material sustainability risks that could affect its long-term success, by introducing the
Stakeholder Consultation. This is a two-way, systematic and objective practice governed by specific
Principles and applied through a 5-stage circular process; the process is repeated after each completion
cycle with a view to implementing improvement actions where required.
Governance
[MDR-P_65_c]
a. Sustainability Committee of the Board of Directors
b. Sustainable Development Division
c. Sustainability Leaders of each sector / Subsidiary / Central Function
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
a. COMMISSION DIRECTIVE 2023/2772 of 31 July 2023
b. AA1000 Stakeholder Engagement Standard (AA1000SES)
c. GRI Standards (Global Reporting Initiative)
Inclusion of Stakeholder
interests
[MDR-P_65_e]
The revision of this Procedure considered the views of METLEN's key internal stakeholders and was piloted
through a Consultation with Stakeholder groups organised in 2024.
Availability
[MDR-P_65_f]
Corporate Website
162
, Internal Information Portal (intranet)
CODE OF BUSINESS CONDUCT
Year of update
2019
Key Content
[MDR-P_65_a]
The Code of Conduct reflects the general principles that determine responsible business conduct and ethical
rules that all METLEN employees and partners are expected to follow, as well as the commitments of the
Group's Management towards its people.
Targeting
[MDR-P_65_b]
It includes rules of acceptable behavior of employees towards third parties, whether individuals or legal
entities, public or private law, domestic or foreign, and goes beyond mere compliance with laws in all areas
of the Group's operations, demonstrating its commitment to operate with integrity in every case.
Specifically, the Code stipulates that the Group's employees must be aware that in addition to contributing
to the economic development of the local communities in which it operates, the Group, having aligned its
social policy with the Sustainable Development Goals, implements targeted actions and initiatives,
contributing substantially to:
strengthening Local Infrastructure,
quality education,
enhancing employment,
mitigating the consequences of poverty,
contributing to improve access to health services and
the promotion of Culture and Sport.
161
https://www.METLENgroup.com/media/ewkhrmwn/policy_cgsd_3_responsible_supply_chain_en.pdf
162
https://www.METLENgroup.com/media/mmwd2ntn/social_partners_consultation_process_2018_en.pdf
5. Annual Board of Directors Management Report
264
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Governance
[MDR-P_65_c]
a. Board of directors
b. General Divisions of Business sectors
c. Chief Administration Office
d. Human Resources General Division
e. Compliance Division
Standards or
internationally recognized
third-party initiatives
[MDR-P_65_d]
a. ISO 45001 standard for Occupational Health & Safety
b. Corporate Standards and good practices on OSH issues
c. Standard 14001 for Environmental Management
Inclusion of Stakeholder
interests
[MDR-P_65_e]
According to the Code, Managers are responsible for creating an open environment for the voicing of
concerns but also for the provision of assistance and support to human resources for effectively identifying
compliance issues with the Code.
Availability
[MDR-P_65_f]
Corporate Website
163
, Internal Information Portal (intranet)
S3-2
Processes for engaging with affected communities about impacts
METLEN understands the importance of having a comprehensive and centralized due diligence policy that covers affected
communities. Despite existing commitment and various policies related to the protection and support of local communities, the
Group has yet to adopt a formal centralized due diligence policy. However, recognizing the growing importance of due diligence
in modern business practices, METLEN has made the development of this policy an immediate priority. The development of the
formal central due diligence policy is progressing and is expected to be finalised in 2025. The new policy will incorporate best
international practices and standards, providing a clear and coherent framework to identify, prevent and address the impact that
the Group's activities may have on the rights of its local communities.
However, METLEN's cooperation with its affected communities is ongoing, multidimensional and substantial, as it has
consistently implemented the institution of Open Social Dialogue with its Stakeholder groups over the past 14 years. This
approach creates the conditions to shape new perceptions and practices in its relations with Stakeholders. To this end, the 10th
thematic consultation with Stakeholder groups on "METLEN’s sustainable growth: Stakeholder Feedback" was organized at
central level. Relevant detailed information is presented in the corresponding section of this Sustainability Statement (see ESRS-
2_SBM-2). [S3:S3-2_21_b]
Group level Horizontal Actions
a) The General Divisions of each METLEN Business sector are responsible for managing relations with the local communities
where they operate. The main objective is to identify and minimize negative impacts through responsible business behaviour
and activity. [S3:S3-2_21_c]
b) Sustainable Development teams have been created in each Business Unit and their members manage the implementation of
social policy, the annual Stakeholder consultation, the cooperation with local media and the organization of community
members' visits to the Group's premises whenever requested. During these visits, presentations are made by the Group in
relation to the management approach to issues of interest, followed by an active dialogue with participants to ask questions
or submit their views, which are recorded and reviewed in order to decide if and how they could be included or managed by
the Group. [S3:S3-2_21_b]
c) The Group communicates with its local communities in an organized and transparent way, through the "open door" policy,
or directly with the citizens of the communities or their representatives at local government level, an approach applied mainly
in the areas where its main industrial plants are located. [S3:S3-2_21_b]
d) The initiatives undertaken by the Group are linked to the needs of each community and its wider region and are shaped either
through open dialogue with local Stakeholders or through surveys to identify material issues, or through annual thematic or
general open consultations with representatives of local communities for monitoring, discussion and receiving feedback on
specific sustainable development-related issues of local interest. [S3:S3-2_21_b]
163
https://www.METLENgroup.com/media/hwdhvhaw/kodikas_deontologias_omilou_2019_eng_web.pdf
5. Annual Board of Directors Management Report
265
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Sector level Vertical Actions
To effectively manage the concerns or needs of affected communities and to enhance two-way communication with them, the
Metals Sector’s Aluminium of Greece plant has appointed a Communication and Public Relations representative responsible for
collecting and processing requests submitted by representatives of affected communities, as well as overall communication with
them regarding the progress of their requests. Regular communication
164
allows affected communities to know and trust the
adopted procedures as a way to voice their concerns or needs and receive information on how the Group is responding. [S3:S3-
2_21_a] [S3:S3-2_21_b]
In order to assess the effectiveness of cooperation with the affected communities, the competent department of the Metals
Sector’s Aluminium of Greece plant considers the following:
a) the number of grievances, comments, complaints made by the Group's stakeholders and affected communities related to
the operation of the Group and its impact on the local community;
b) the frequency and manner in which Stakeholders and affected communities refer to and promote the positive impact of
the Group's operation on the local community, and their acceptance by the wider local community (e.g. thank-you letters,
texts, posts on social media, oral reports on events, etc.);
c) the number of bodies/stakeholders belonging to the affected communities, who contact the Group's representatives to
make requests for cooperation, voice complaints/concerns, etc. (*maintaining and improving communication channels
and strengthening the "open doors" policy).
The above are topics of discussion and assessment by the competent group of executives. Also, as part of the monitoring of
effective engagement with affected communities, the design of a tool that will further contribute to this direction will be
considered in 2025. [S3:S3-4_21_d]
Dialogue with local communities is conducted for all renewable energy projects in METLEN’s Energy Sector when required by
local regulation, during the design and construction phase, and environmental and social impact studies are carried out, which
also include social aspects, including community consultation, fair land acquisition, security measures and complaint resolution.
[S3:S3-2_21_b]
S3-3
Processes to remediate negative impacts and channels for affected communities to raise concerns
METLEN recognizes the importance of open and transparent communication with its local communities. To ensure that the
concerns and issues of local communities are heard and addressed effectively, the Group has established various channels of
communication. These channels allow members of local communities to raise their concerns, request information and receive
support about the Group's activities that may be relevant to them. METLEN is committed to keeping these channels accessible
and effective. [S3:S3-3_27_b]
In particular:
In the Metals Sector, the Aluminium of Greece plant has a special internal procedure that activates the mechanism for receiving
and managing requests and complaints from third parties on environmental, social, ethical and general issues related to
responsible entrepreneurship. The mechanism is used by all the Sector’s stakeholders (including local communities) and
complaints may be filed in the following ways: 1) using a METLEN or Aluminium of Greece special contact form, 2) using the
dedicated e-mail address (info@alhellas.gr), 3) by organising meetings with representatives of local communities for direct
dialogue and exchange of views when required, 4) during the sector’s annual consultation with its Stakeholders and 5) by letter
or telephone. The complaint handling process includes a series of stages aimed at:
a) Informing the competent department to which the request or complaint is addressed.
b) Further investigation of the need and finding a possible way to grant the request or resolve the complaint in cooperation with
the Group’s competent departments.
c) Informing the sender about the outcome of the submitted request or complaint.
d) Creating an action plan, where required, to improve the Group's operation on ESG and Responsible Entrepreneurship issues.
e) The review of filed complaints and the Group's responses/actions on an annual basis.
164
As mentioned in the section: General Disclosures of the Sustainability Statement, under the subsection "Interests and views of stakeholders", 2. Ways of
cooperation with the Stakeholders.
5. Annual Board of Directors Management Report
266
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
f) The review and revision of the process in the context of the quality systems review. [S3:S3-3_27_c] [S3:S3-3_27_d]
The Communication and Public Relations Department of the Aluminium of Greece plant is responsible for managing complaints
and regularly informs both the Management of the plant and the Metals Sector General Division.
In the Energy Sector, for the construction and operation of thermal power plants and renewable energy projects, there is a
process for "Stakeholder Complaints Management". Complaints are filed using METLEN’s and the Energy Sector’s social media or
contact forms, but also by e-mail to info@protergia.gr or info@METLENgroup.com. In addition, for regions where new Power
Stations are being constructed, relations with local communities are managed to foster a climate of cooperation, supported by
the "Promotion of relations with local authorities" special procedure.
In renewable energy projects, the assessment, management and monitoring of possible adverse environmental and social
impacts or risks of a project is tasked to the Project Execution Team, which, in cooperation with the local office, creates and
maintains a complaints mechanism accessible to interested parties. Through corporate communication channels and depending
on the nature of the complaint, complaints are forwarded to the appropriate departments for monitoring, if deemed necessary,
in order to ensure their effective management. As for complaints from external sources, these are usually the responsibility of
the client being the project owner. [S3:S3-3_27_c] [S3:S3-3_27_d]
METKA SA, a METLEN subsidiary operating in the construction industry, encourages the use of available corporate (internal)
reporting channels to ensure checks are performed timely and management is informed appropriately. Group employees
employed under any employment relationship, candidate or former employees, consultants, special associates and other
professionals offering services to the Companies, as well as persons employed under the supervision and instructions of the
Companies’ contractors, subcontractors and suppliers may file reports using the corporate channels. Complaints filed by external
parties are the responsibility of the project owner.
Complaints are filed in the following ways:
1. By filing of a report through the Electronic Reporting Platform: https://METLEN.ethics.help/.
2. By sending an email to: METLEN@ethics.email (linked anonymously to the above online reporting platform, without revealing
the email address of the person making the report).
3. By sending a letter to METLEN Energy & Metals SA, to the attention of the Compliance Director, 8 Artemidos str., 151 25
Maroussi.
4. Through a personal meeting with the Compliance Director of METLEN Energy & Metals SA.
Suggestions for the improvement and enhancement of grievance mechanisms can be submitted by stakeholders through the
various communication channels available in each Sector, as well as within the framework of the annual local consultation. In the
Metals Sector, response measures to requests and complaints assessed as the most significant are recorded and reported in the
Group’s annual corporate disclosures. They may also serve as the basis for dedicated discussion topics during the annual local
consultation with Social Partners. Additionally, at the Aluminium of Greece plant, an active employee union maintains two-way
communication with the Sector's Human Resources Management, addressing a wide range of issues, including proposals for
enhancing the grievance submission mechanism.
In the Energy Sector, the Management Systems Manager confirms the implementation of corrective actions, and within
reasonable time (mainly during internal audits), investigates the effectiveness of these actions to eliminate the causes of non-
compliance. [S3.S3-3_27_a] In case actions do not bring the desired results, the process of investigating – recommending new
corrective actions is repeated. [S3:S3-3_27_c] [S3:S3-3_27_d]
S3-4
Taking action on material impacts, and approaches to mitigating material risks and pursuing material
opportunities related to affected communities, and effectiveness of those actions and approaches
METLEN supports its local communities by implementing social programs and actions that aim at combatting poverty,
strengthening the social inclusion of vulnerable groups, supporting education for the younger generation, improving local
infrastructure, protecting the cultural and natural heritage, as well as promoting innovative solutions, such as Smart Cities.
5. Annual Board of Directors Management Report
267
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In 2024, the Group, continuing the pursuit of its social policy, implemented actions in key social sectors contributing to the
Sustainable Development Goals (SDGs), with a total value greater than €7 million (2023: €3.3 million). This considerable increase
is mainly attributed to the strengthening of infrastructure development projects, such as the construction of two bridges in
Australia to serve the Group's RES projects, also open for use by the public. In addition, the Group offered significant support to
cultural and sports activities, such as the illumination of the Temple of Poseidon at Sounion, which dates back to the 5th century
BC, thus helping highlight the archaeological and architectural importance of the monument and the cultural heritage of the land
as a whole. [S3:S3-4_32_c] [S3:S3-4_38]
METLEN distinguishes its social investments into three categories: [S3:S3-4_32_c]
1) Social Programs/actions: related to the long-term cooperation of the Group with Non-Profit Organizations and Civil Society
organizations to address social issues selected by the Group.
2) Charitable Donations: involving one-time or occasional needs support and responding to appeals from Non-Profit
Organizations, local community organizations, employee requests or in response to external events, such as emergencies.
3) Commercial Initiatives: which include business activities towards local communities or the wider society, undertaken by the
Group's commercial departments to directly support its business objectives by promoting its corporate and commercial
identities and other initiatives, in partnership with charities and organizations.
METLEN recognizes the existence of various needs in the local communities in which it operates and, for this purpose, has
developed a mechanism for receiving requests in order to implement actions that address these needs, ensuring high added
value. Through the electronic system “In Practice,” which began operating in 2016 and has been functioning continuously since
then, the Group receives support requests from social organizations, which it evaluates for implementation.
Specifically, the evaluation process prioritizes requests that align with the United Nations Sustainable Development Goals, such
as zero poverty, zero hunger, good health & well-being, quality education, reducing inequalities, and the development of
sustainable cities and communities. The evaluation and management process of social requests, corporate social programs, and
initiatives of the Group describes the individual stages for establishing strategic objectives, preparing budgets, and managing
requests, as well as the initiatives undertaken by the Group. At the same time, the Metals Division, through the request and
complaint management process, aims to improve communication with local groups of its social partners and to effectively
manage requests (such as inquiries, collaborations, sponsorships/donations, distribution of informational materials, visit
scheduling), comments, complaints, and ESG and Corporate Responsibility issues. [S3:S3-5_41]
[S3:S3-4_38]
Table: 01/S3
165
The social investments table includes societal benefits (amounts) from RES project development in all the countries where the Group operates.
Social investments by investment category
165
(€)
%N/N-1
2024
2023
2022
Total Social investments (1+2+3))
+117%
7,126,519
3,281,510
3,899,921
1. Social Programs/actions
+93%
5,203,479
2,694,879
1,765,735
% of total social investments
73%
82%
45%
2. Commercial Initiatives
% of total social investments
+437%
1,760,379
25%
328,018
10%
112,500
3%
3. Charitable Donations
-37%
162,661
258,613
2,021,686
% of total social investments
2%
8%
52%
5. Annual Board of Directors Management Report
268
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Table: 02/S3
Key social initiatives & programs
In 2024, METLEN implemented 30 social programs and special social actions at central and local level, with more than 184,000
direct and indirect beneficiaries in total, contributing across the social spectrum of the Sustainable Development Goals.
The communities positively affected by METLEN's actions are multidimensional covering a wide range of social groups with
different needs and challenges. The first to benefit significantly are vulnerable social groups, such as homeless people,
unemployed young people and families in financial distress. These communities face challenges of daily survival, such as a lack
of essential goods, food security and access to support services. Improving living conditions and providing support to meet their
basic needs enhances their social inclusion and improves their quality of life. For METLEN, these actions create opportunities to
enhance its corporate reputation as a socially responsible business and strengthen its relationship with local authorities and
NGOs, paving the way for new partnerships. In addition, special emphasis is placed on student and educational communities.
Students and teachers in schools facing educational and social inequalities benefit through programs that promote quality
education, skills development and awareness-raising on important social issues. These communities gain access to opportunities
that enhance their knowledge, skills, and future ability to find work. This offers METLEN the chance to nurture and equip the
workforce of the future with modern skills that can be integrated into the human resources of either the Group or its partners.
Upgrading health infrastructure by supplying modern medical equipment leads directly to improving access to quality health
services for all age groups, from children and young people to adults and the elderly. With these actions, METLEN strengthens its
cooperation with public health institutions, taking an active role in social responsibility and in creating conditions for future
partnerships in the area of health infrastructure. People with disabilities, such as the blind and children with communication
difficulties, are also important beneficiary groups. Specialized programs are applied to help enhance their social integration and
Social investments by Global Goal
(€)
%N/N-1
2024
2023
2022
Total Social investments )
+117%
7,126,519
3,281,510
3,899,921
SDG 11: Local Infrastructure & Services
+145%
4,087,882
1,668,923
853,789
% of total social investments
57,4%
50,9%
21,9%
SDG 11: Supporting Culture/Sport
+177%
2.162.468
779.330
488.036
% of total social investments
30.3%
23.7%
12.5%
SDG 4: Supporting Quality Education
+28%
206,967
161,146
187,490
% of total social investments
2.9%
4.9%
4.8%
SDG 3: Access to Health Services
-38%
162,867
262,826
2,044,936
% of total social investments
2.3%
8%
52.4%
SDG 1: Alleviating Poverty & Unemployment
+38%
159.511
115.322
149.025
% of total social investments
2.2%
3.5%
3.8%
SDG 10: Fewer Inequalities
+48%
152.212
103.194
74.000
% of total social investments
2.1%
3.1%
1.9%
SDG 2: Reducing food insecurity
-7%
90.612
97.665
74.119
% of total social investments
1.3%
3%
1.9%
SDG 13: Action for Climate
+20%
66.000
55.105
28.525
% of total social investments
0.9%
1.7%
0.7%
SDG 5: Gender Equality
0%
38,000
38,000
0
% of total social investments
0.5%
1.2%
0%
5. Annual Board of Directors Management Report
269
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
autonomy, offering access to support and educational opportunities. METLEN's investments in equality and inclusion-promoting
actions strengthen its image as a driver of social change and can create opportunities for cooperation with organizations
promoting accessibility and diversity. Material positive impacts are also observed in rural communities, particularly in areas
affected by natural disasters. Beekeepers and people living in forest areas benefit from actions that support local economy and
enhance environmental protection. These actions offer METLEN opportunities to strengthen and foster trusting relationships
with local communities. Also, young people and the unemployed are a critical community which benefits from new skills
acquisition and improved professional prospects, facilitating their social mobility and financial integration. METLEN can leverage
this momentum to discover new talent and invest in people with modern skills, enhancing its innovation and competitiveness.
Through all its activities and the countries it operates, METLEN constantly strengthens local employment. Over the last 15 years,
the Group has created almost 3,400 new jobs, including 474 created just in 2024. Meanwhile, the Group, recognizing the
significant role it plays in generating income for the local communities near which it operates, aims to and continues to maintain
a very high percentage of local employment, with almost nine (9) out of ten (10) of its employees (local workforce) coming from
local populations. Moreover, METLEN supports the domestic and, by extension, local supply chain with product and service
purchases generating income, jobs (more than 4,000 indirect jobs across all the Group's activities in 2024) and salaries which are
consumed in the market and in turn create induced jobs, salaries and taxes paid to the State. [S3:SBM-3_9_c] [MDR-A_68_e]
Table: 03/S3
Overall, METLEN's actions have a material positive impact on vulnerable groups, on education and healthcare, on rural and youth
communities, creating opportunities for growth, strengthening social cohesion and sustainable progress, while supporting its
strategic partnerships and business development. [S3:SBM-3_9_c] [S3:SBM-3_11]
Below follow the most important programs that were either implemented for the first time in 2024 or are a continuation of
previous programs within the last five years (2019-2024). A brief description is provided for each program, as well as basic
information about the partner organisations, all beneficiaries, the implementation years and duration.
In 2025, the Group intends to pursue and enrich the programs based on their continuous evaluation. [MDR-A_68_a]
Program : Mobile laundry unit
SDG
1 – No Poverty
Partner Organization
ITHACA NGO
Description [MDR-A_68_b]
Mobile laundry unit for vulnerable people.
Total Beneficiaries
1,003 homeless
Implementation Years [MDR-A_68_c]
2022-2024
Program: DataYouth
SDG
1 – No Poverty
Partner Organization
Knowl Social Enterprise for lifelong learning
Description [MDR-A_68_b]
Empowering unemployed young people with digital skills to boost jobs.
Total Beneficiaries
26 unemployed young people
Implementation Year [MDR-A_68_c]
2024
Program: Arogi
SDG
1 – No Poverty
Partner Organization
Holy Metropolis of Thebes, Levadia & Avlida
Description [MDR-A_68_b]
Provision of 526 vouchers to vulnerable social groups for purchases from
a Food Chain.
Total Beneficiaries
511 families & 15 students
Implementation Years [MDR-A_68_c]
-
Percentage of employees from local communities (local workforce)
Ν/Ν-1
2024
2023
2022
2021
+7.8%
89.5%
83%
88%
92%
5. Annual Board of Directors Management Report
270
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Program : Collect
SDG
2 – Zero Hunger
Partner Organization
FOODBANK - An Institution to fight hunger & waste of goods
Description [MDR-A_68_b]
Action to collect food from consumers in store chains with the
participation of the institution’s volunteers.
Total Beneficiaries
51,602 people from vulnerable groups
Implementation Years [MDR-A_68_c]
2023-2024
Program : Boroume at school
SDG
2 – Zero Hunger
Partner Organization
BOROUME– saving food – saving lives
Description [MDR-A_68_b]
Increase awareness among schoolchildren regarding food waste,
volunteering and giving
Total Beneficiaries
6,026 students and 435 teachers
Implementation Years [MDR-A_68_c]
2023-2024
Program : DIATROFI - Food aid and promotion program for healthy nutrition
SDG
2 – Zero Hunger
Partner Organization
PROLEPSIS Institute
Description [MDR-A_68_b]
Providing 41,501 healthy meals to students with increased food insecurity
from 13 schools.
Total Beneficiaries
438 students
Implementation Years [MDR-A_68_c]
2018-2024
Program : Upgrading the Emergency Departments in Hospitals and Pediatric Clinics of Greece
SDG
3 – Good Health & Well-Being
Partner Organization
Pediatric Trauma Care
Description [MDR-A_68_b]
Upgrading of the Emergency Departments with the necessary medical
equipment (Naxos General Hospital - Health Center and Ilia General
Hospital - Krestena Nursing Unit) & creation of information leaflets on
how to identify and avoid risks
Total Beneficiaries
7,743 children
Implementation Years [MDR-A_68_c]
2017-2024
Program : Upgrading the Intensive Care Units & Neonatal Intensive Care Units in Public Hospitals
SDG
3 – Good Health & Well-Being
Partner Organization
PNOE – Friends of Child Intensive Care
Description [MDR-A_68_b]
Provision of medical equipment to the "Alexandra" Athens General
Hospital and the Larissa Hospital.
Total Beneficiaries
877 neonates and children
Implementation Years [MDR-A_68_c]
2021, 2023-2024
Program : Conducting a STEM skills workshop
SDG
4 – Quality Education
Partner Organization
WRO HELLAS - Organization of Educational Robotics & Science
Description [MDR-A_68_b]
Program for conducting STEM skills workshops to primary school
students in 10 schools.
Total Beneficiaries
1,017 students and 35 teachers
Implementation Years [MDR-A_68_c]
2018-2024
5. Annual Board of Directors Management Report
271
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Program : Renewable Energy Sources & Hydrogen Technology
SDG
4 – Quality Education
Partner Organization
WRO HELLAS - Organization of Educational Robotics & Science
Description [MDR-A_68_b]
Exploration of RES and possibility of experimentation by creating real
applications.
Total Beneficiaries
1,185 students and 57 teachers
Implementation Years [MDR-A_68_c]
2023-2024
Program : Hardware renewal in schools
SDG
4 – Quality Education
Partner Organization
-
Description [MDR-A_68_b]
Modernization of 16 schools with technological equipment (25 machines:
15 computers, 5 photocopiers, 2 projectors, 3 interactive whiteboards) in
the following areas: Athens, Thessaloniki, Aetolia-Acarnania, Karditsa,
Skopelos, Ioannina)
Total Beneficiaries
2,379 students
Implementation Years [MDR-A_68_c]
2018-2024
Program : Discovering digital developments through professions
SDG
4 – Quality Education
Partner Organization
The Tipping Point
Description [MDR-A_68_b]
Program for the empowerment of Junior and Senior High School students
in Greece and abroad to explore digital technologies and ways to
leverage them in academic and professional fields.
Total Beneficiaries
8,028 students and 76 teachers
Implementation Years [MDR-A_68_c]
2019-2024
Program : 3rd MRC Global Olympiad 2024
SDG
4 – Quality Education
Partner Organization
Hellenic Educational Robotics Organization (H.E.R.O.)
Description [MDR-A_68_b]
Sponsorship of the 3rd MRC GLOBAL OLYMPIAD.
Total Beneficiaries
3,400 school & university students and adults
Implementation Years [MDR-A_68_c]
2022-2024
Program : YES program – 15th Youth Entrepreneurship Summer School
SDG
4 – Quality Education
Partner Organization
Athens University of Economics and Business
Description [MDR-A_68_b]
Participation of secondary school students in the "YES Program" of the
Department of Management Science and Technology of AUEB.
Total Beneficiaries
20 students
Implementation Years [MDR-A_68_c]
2018-2024
Program : Participation in an international innovation and robotics conference
SDG
4 – Quality Education
Partner Organization
Anagennisi School
Description [MDR-A_68_b]
Provision of equipment for students to participate in an international
innovation and robotics conference (Italy).
Total Beneficiaries
240 students & 8 teachers
5. Annual Board of Directors Management Report
272
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Implementation Year [MDR-A_68_c]
2024
Program : Engineer in Action
SDG
4 – Quality Education
Partner Organization
-
Description [MDR-A_68_b]
Paid traineeships, creation of new quality vocational training positions,
apprenticeships
Total Beneficiaries
49 people
Implementation Years [MDR-A_68_c]
2017-2024
Program : CSR Hellas
SDG
4 – Quality Education
Partner Organization
CSR Hellas
Description [MDR-A_68_b]
Training program on Sustainable Development management through
training workshops
Total Beneficiaries
2 people
Implementation Years [MDR-A_68_c]
2019-2024
Program FemStem
SDG
5 – Gender equality
Partner Organization
Knowl - Social enterprise for lifelong learning
Description [MDR-A_68_b]
Skills, employability & entrepreneurship accelerator for women in STEM.
Total Beneficiaries
30 women
Implementation Years [MDR-A_68_c]
2023-2024
Program : AmeA Annotators
SDG
10 – Reduced Inequalities
Partner Organization
Science For You (SCIFY)
Description [MDR-A_68_b]
Training of people with disabilities in Artificial Intelligence, Development
of Annotation skills for the development of Artificial Intelligence systems.
Total Beneficiaries
65 people with disabilities
Implementation Year [MDR-A_68_c]
2024
Program : Creation of a virtual reality workshop
SDG
10 – Reduced Inequalities
Partner Organization
"I THEOTOKOS" FOUNDATION
Description [MDR-A_68_b]
Creation of a virtual reality workshop to prepare participants for the labor
market. Conducting trainings to develop vocational and communication
skills, to solve problems in social and working conditions and to prepare
for transition to a new working environment.
Total Beneficiaries
20 adolescents & young adults with autism spectrum disorder
Implementation Year [MDR-A_68_c]
2024
Program : Focus on the Person
SDG
10 – Reduced Inequalities
Partner Organization
S.K.E.P. - Association of Social Responsibility for Children and Youth
Description [MDR-A_68_b]
Accessibility & Inclusion Educational Actions in 87 schools of Attica and
Lamia. Design of the document "Focus on the Person".
Total Beneficiaries
5,695 students
Implementation Years [MDR-A_68_c]
2022-2024
5. Annual Board of Directors Management Report
273
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Program “Contact” at the Tactual Museum
SDG
10 – Reduced Inequalities
Partner Organization
Association "Lighthouse for the Blind of Greece"
Description [MDR-A_68_b]
Program for the experiential perception of visual impairment and
awareness through play and creative processes.
Total Beneficiaries
1,350 blind people
Implementation Years [MDR-A_68_c]
2023-2024
Program : Therapeutic riding for children with disabilities
SDG
10 – Reduced Inequalities
Collaborating Institution
Hadjipatereio Rehabilitation and Support Center for Children
Description [MDR-A_68_b]
Therapeutic riding program for children with disabilities.
Total Beneficiaries
39 beneficiaries
Implementation Years [MDR-A_68_c]
2022-2024
Program : Purchase of 4 interactive touch panels
SDG
10 – Reduced Inequalities
Partner Organization
Hadjipatereio Rehabilitation and Support Center for Children
Description [MDR-A_68_b]
Provision of 4 interactive touch panels facilitating the educational
process through auditory, visual and kinesthetic learning. This achieves
enhancement of visual-motor coordination and eye contact of children,
improving the quality of movement, balance and posture.
Total Beneficiaries
167 beneficiaries
Implementation Year [MDR-A_68_c]
2024
Program : Augmentative and Alternative Communication for children with disabilities
SDG
10 – Fewer inequalities
Partner Organization
Hadjipatereio Rehabilitation and Support Center for Children
Description [MDR-A_68_b]
Language development program as a means of speech assistance
Total Beneficiaries
140 beneficiaries
Implementation Years [MDR-A_68_c]
2022-2024
Program : Donation of queen bees
SDG
13 – Climate Action
Partner Organization
Bee for planet
Description [MDR-A_68_b]
Donation of 500 queen bees to beekeepers in affected areas of Greece
Total Beneficiaries
51 beekeepers
Implementation Year [MDR-A_68_c]
2024
Program : Circular economy and zero waste in schools
SDG
13 – Climate Action
Partner Organization
NoWaste21
Program : Upgraded version of the "Greek White Cane"
SDG
10 –Reduced Inequalities
Partner Organization
Association "Lighthouse for the Blind of Greece"
Description [MDR-A_68_b]
Production of the new upgraded version of the unique Greek White Cane
with breaks in 6 points.
Total Beneficiaries
120 blind people-beneficiaries
Implementation Year [MDR-A_68_c]
2024
5. Annual Board of Directors Management Report
274
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Description [MDR-A_68_b]
Informing and raising awareness among 41 school communities on issues
of Circular Economy and Zero Waste with emphasis on Prevention, Reuse
and Recycling.
Total beneficiaries
3,793 students
Implementation Years [MDR-A_68_c]
2023-2024
Program : Green Future
SDG
13 – Climate Action
Partner Organization
We4all
Description [MDR-A_68_b]
Environmental information and awareness raising among students from 25
schools through tree-planting in a school environment and implementation
of environmental interactive games and workshops.
Total Beneficiaries
879 students
Implementation Years [MDR-A_68_c]
2023 –2024
Program : Installation of water tanks
SDG
13 – Climate Action
Partner Organization
We4all
Description [MDR-A_68_b]
Installation of water tanks at key points within forests in the Prefectures of
Ilia, Korinthia, Attica for use by the Fire Service.
Total Beneficiaries
9,500 inhabitants of the surrounding areas
Implementation Year [MDR-A_68_c]
2024
Local development [MDR-A_68_e]
Alongside the implementation of social actions at central level, important actions were implemented in 2024 at Sectors level,
following a selection process, creating a material positive impact on local communities.
Specifically, a partnership between the Metals Sector’s Aluminium of Greece plant and the Energy Sector’s Protergia led to the
co-financing of a school infrastructure improvement project which included the renovation of school yards and school buildings
in municipal units near or within the greater area of the Fokida and Viotia Prefectures in the Region of Central Greece, where
most operations of the Group’s Business Units are installed. The project started out in 2023 and was completed in 2024, having
considerably improved the quality of school facilities in the region. Furthermore, in 2024, the Metals Sector started and
completed road improvement projects, as well as infrastructure projects in municipal units of the Prefectures of Fokida and Viotia
in the Region of Central Greece, including the renovation of the school yard of a kindergarten and the construction of a new
indoor sports hall. Meanwhile, METLEN's mining activity, operated by the companies Delphi-Distomon and European Bauxite,
offered financial support to local communities in the area for the Social Grocery Store and the organization of sports and cultural
events, as well as to other social associations of the Region of Central Greece. The added value generated over time from the
Group's business operation with the development of renewable energy projects by the Energy Sector lies not only in its
contribution to the achievement of national environmental goals, but also in the significant benefits to local communities. Thus,
in 2024, the total investment in supporting infrastructure and service projects and strengthening logistical facilities, with the aim
of improving the living conditions of residents in municipalities where new renewable energy projects operate or will be
developed, exceeded €4 million [S3:S3-4_38]
Over time, these investments are implemented in cooperation with the relevant Municipalities and according to their needs and
mainly concern major civil engineering works such as bridge construction, asphalt paving, maintenance and rehabilitation of
municipal and provincial roads, replacement, extension or construction of water supply and irrigation networks in settlements,
supply and installation of LED street lighting fixtures, earthworks, construction or repair of municipal buildings and facilities, but
also donations of vehicles and equipment necessary for the operation of municipal services and fire protection. [S3:S3-4_32_c]
By expanding its energy portfolio of photovoltaic parks, METLEN increases the chances for financing and construction of
additional projects, further strengthening its position in the broader energy market of Latin America, Europe and Australia. In
this context, in 2024, through its social programs and actions, the Group contributed significantly to supporting education and
the development of the younger generation, good health & well-being, the reduction of food insecurity, local infrastructure, and
cultural and natural heritage protection (Sustainable Development Goals - SDGs 1, 2, 3, 4, 11). Through a series of actions that
are part of the above programs, the Group highlights its commitment to responding to the different expectations of its local
5. Annual Board of Directors Management Report
275
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
communities, including indigenous peoples who may be affected by its activities, focusing on their empowerment, assuming its
fair share of responsibility. The Group monitors and evaluates the effectiveness of its actions in local communities through regular
checks and site inspections carried out by its own staff or through partners. In this context, on-site visits are made to monitor the
progress of the implementation of initiatives, ensuring their proper completion. At the same time, the Group maintains
continuous communication with local authorities to identify any additional needs for adjustment and improvement, thereby
enhancing its positive impact on the communities in which it operates. [S3:S3-4_32_c] [S3:S3-4_32_d] [S3:S3-4_38]
METRICS & TARGETS
S3-5 — Targets related to managing material negative impacts, advancing positive impacts, and managing material
risks and opportunities
Key quantitative targets
METLEN, recognizing the importance of responsible business, has set clear goals to promote positive impacts in the communities
affected by its activities. The corporate targets presented in this section have been prepared taking into account internationally
recognized reporting frameworks and standards, without relying solely on European Sustainability Reporting Standards (ESRS).
Recognizing the importance of responsible business development, METLEN has set clear targets to promote the positive impact
on the communities affected by its activities. In 2023, the Group revised the initial target of 250,000 benefiting citizens from the
implementation of social programs set for the period 2020-2025, since not only has it achieved this target, but it has significantly
exceeded it by 35% (Benefiting citizens 2020-2023: 336,576). The new target that has been decided significantly increases the
number of benefiting citizens to 550,000 for the same period (2020-2025), and given that the number of benefiting citizens for
2024 is 184,455, the total number of benefiting citizens totals 521,031, which is a 95% achievement rate against the target set.
[S3:S3-5_41] [MDR-T:80_a] [MDR-T:80_b] [MDR-T:80_c] [MDR-T:80_d] [MDR-T:80_e] [MDR-T:80_i] [MDR-T:80_j]
Key quality targets
In addition to the core quantitative corporate target, METLEN has set a set of quality targets for local communities which include:
a) Strengthening local employment: METLEN aims to create quality jobs for local populations, enhancing the economic stability
and development of the regions where it operates in Greece and abroad.
b) Developing the local economy: The overarching principle of all the business units and subsidiaries of the Group is to prioritize
domestic and by extension local suppliers for the purchase of products and services, always according to their needs and
particularities.
c) Contributing to the global clean energy transition in an equitable way: METLEN, through its Energy Sector, contributes to
the global clean energy transition by demonstrating a firm commitment to the sustainability of local communities. The
Sector’s projects have increased the share of renewable energy sources and boosted economic growth, while contributing to
the reduction of greenhouse gas emissions and energy security. This way, the Group not only promotes renewable energy
solutions, but also contributes to the holistic sustainability of communities, boosting local employment and strengthening the
local economy.
d) Maintaining and strengthening Consultations at both local and central level to identify local needs and examine new
opportunities for cooperation.
e) Having a substantial contribution to the strengthening of social cohesion, through the annual social investment program,
the implementation of selected social programs and actions, strategically seeking its greater engagement in areas directly
related to the Sustainable Development Goals.
Sector-related quantitative and qualitative targets
In addition to the quality targets set by METLEN for local communities, the Aluminium of Greece plant has set individual targets
to promote the positive effects on affected communities, ensure sustainability and enhance their well-being. Strategically seeking
to increase the engagement of local communities in fields directly related to the Sustainable Development Goals, for the year
2024, the Aluminium of Greece plant has set a target to increase social investments in the health and education sectors by 10%
and 20% respectively, revising the 2023 social program, according to the needs of local communities. These targets were not only
5. Annual Board of Directors Management Report
276
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
met, but exceeded by 18% and 48.1% respectively, with social investments related to equipment donation, implementation of
information and awareness programs, as well as skills development initiatives. [S3:S3-5_41] [MDR-T:80_a] [MDR-T:80_b] [MDR-T:80_c] [MDR-
T:80_d] [MDR-T:80_e] [MDR-T:80_i] [MDR-T:80_j]
CONSUMERS AND END-USERS [ESRS: S4]
High quality and product safety exceeding the applicable legal and regulatory requirements are a key priority for the Group. Any
deviation from the strict quality standards of its products and services is recognized as a factor that could affect its responsible
operation, and the commitments it undertakes towards its customers for its products and services, and by extension consumers,
the end-users, with consequences on their satisfaction, the Group’s reputation and reliability, and by extension its financial
results.
STRATEGY
SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model
METLEN's strategy and business model are based on respect for the interests, opinions and rights of consumers and end-users.
The material impacts, risks and opportunities faced by METLEN directly affect its strategy and business model, shaping how it
operates and grows in the areas in which it operates. [ESRS2:SBM-2_9_a]
According to the results of the Double Materiality Assessment, a significant impact on consumers and end-users emerged:
ACTUAL POSITIVE IMPACT [AP8]
166
Responsibility in the provision of Products & Services [S4:SBM-3_10]
This impact is recognized in METLEN's downstream value chain and specifically includes all relationships with its customers; in
the Metals Sector these concern other businesses (Business-to-Business - B2B), whereas in the Energy Sector they concern both
other businesses (Business-to-Business - B2B) and consumers (Business-to-Consumer - B2C) and consequently end-users in the
context of electricity and natural gas supply. This impact also includes the dimensions of R&D where METLEN invests consistently,
creating further value for all recognized customers, consumers and end-users. [S4.SBM-3_10_c]
Time Horizon:
Actual
Position in the Value Chain:
Downstream
FINANCIAL OPPORTUNITY [S4-O1]: Increase in market share and sales of the Group’s products by enhancing customer trust,
leading to increased loyalty and continuous growth in demand
Financial Significance:
Very high
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Downstream
FINANCIAL OPPORTUNITY [S4-O2]: Enhanced ability to penetrate new markets abroad in the retail electricity sector
Financial Significance:
High
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Downstream
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS
MODEL & VALUE CHAIN
[S4.SBM-3_10_d]
CURRENT AND POTENTIAL IMPACT ON STRATEGY & DECISION
MAKING
[S4.SBM-3_10_d]
a) Ensuring market acceptance of the Group's business
activity.
b) Enhancing corporate image and reputation.
c) Providing optimal products and solutions to
customers, facilitating their uptake by consumers and
end-users, while enabling them to contribute to energy
savings.
a) The integration of responsible commercial practices into the
Group's strategy that enhances alignment with international
sustainable development and corporate responsibility trends,
as well as with the 2030 Agenda and the Sustainable
Development Goals (SDGs).
b) Enhancing the Group's adaptability by regularly incorporating
feedback from its customers to be able to respond as best as
possible to their needs and expectations.
166
As they result from the materiality assessment (see [ESRS2: SBM-3] & [ESRS2: IRO-1])
5. Annual Board of Directors Management Report
277
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
d) Customer support through long-term partnerships
creating mutually beneficial relationships that
strengthen the downstream value chain by attracting
new customers and retaining existing ones, while
ensuring high levels of quality and service.
e) Stability of supply and support of customer business
continuity: In the Energy sector, ensuring
uninterrupted power supply ensures that its customers
can maintain their business continuity seamlessly.
c) Integration of new products and services in the Group's
portfolio, which meet the ever-increasing customer demands
for environmental responsibility and "green" products,
incorporating relevant criteria into their purchasing decision-
making process.
d) Necessary investments in research and development activities
to enhance scientific knowledge and upgrade the technological
capabilities of both the industrial and energy areas, actively
supporting innovation and promoting productive
diversification.
e) Upgrading of the Group's infrastructure and services leading to
continuous improvement of quality and responsiveness to
modern customer needs.
Because of the different nature of their activities, each METLEN Business Unit is faced with different challenges:
In the Metals Sector, the key customers are enterprises that use industrial metals and raw materials to produce high strength
and special specification products. [S4: SBM-3_10_a] These companies depend on the stability and quality of METLEN's products,
critical to sustainability issues, such as reducing environmental impact and responsibly sourcing raw materials. The effects of the
Group's primary products on health and safety standards relate to the end use of the secondary products that will results from
its manufacturing customers. The Group is committed and takes care to ensure the best quality of its offered products (alumina
and aluminium), meeting its customers’ expectations and requirements.
The main categories of customers affected by the Group's energy-related activities and covered by the above policies include:
[S4: SBM-3_10_a]
a) Residential customers, i.e. consumers who use electricity for personal needs at home. Part of this group of consumers
and end-users is directly affected by pricing policies, reliability of supply and quality of service, such as through Social
Residential Tariffs (SRTs).
b) Commercial customers, i.e. small and medium-scale businesses that depend on a stable and affordable supply of energy
to support their activities, where the flexibility of services offered and quick response to their needs are critical for their
satisfaction.
c) Medium and High Voltage (MT/HV) customers, i.e. large consumers and industrial enterprises that require high
reliability and stability in energy supply, as well as customized services for its efficient use.
The Energy Sector considers the internationally applicable regulations in the design of all industrial production and renewable
energy projects, with detailed monitoring of quality measures and characteristics during the supply of materials and the
production of final products, to ensure that specified customer requirements are met. The Group is committed to ensuring the
highest possible availability and reliability in electricity production, to meet the needs of both its business (B2B) and private (B2C)
consumers. [S4: SBM-3_10_a]
METLEN serves a wide range of business (B2B) customers from various industries, meeting their energy needs with a
comprehensive range of services. In renewable energy and storage, the Group offers both construction and sale of large-scale
projects, thus supporting its customers' needs for green energy and sustainable storage solutions. Also, METLEN produces and
distributes primary energy through thermal plants, ensuring a stable supply to businesses and large industrial consumers.
METLEN also builds and sells energy transition and conventional production projects, improving its customers’ ability to meet
energy challenges by enhancing their sustainable development. At the same time, the Group undertakes the supply, trading and
management of natural gas and other energy products, offering integrated energy management solutions that cover all the
energy needs of its corporate customers, thus enhancing the functionality and efficiency of their business activities.
In the retail sector, the Group supplies electricity and natural gas to residential, commercial and industrial consumers, offering
reliable and competitive solutions ranging from basic energy needs to specialized services such as energy efficiency and smart
management solutions. The Group's strategy emphasizes the continuous quality improvement of services provided to meet the
increasing demands for energy security and stability, overall, to consumers and end-users of its services. METLEN is also
constantly investing in new technologies and innovative practices, such as electromobility, energy efficiency and net metering,
to adapt to the changing expectations of its consumers for green energy solutions. Leveraging these technologies allows the
Group to actively contribute to the needs for clean energy, supporting the reduction of its customers' environmental footprint
and enhancing consumer confidence in the sustainability and quality of services provided and appropriate information provided
5. Annual Board of Directors Management Report
278
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
through the electronic applications it offers. [S4: SBM-3_10_a_iii]
METLEN has identified significant positive effects through responsible product and service delivery, making a positive
contribution to the quality of life of consumers and to society. It guarantees stability of supply, contributing to energy security,
while its innovative solutions promote overall sustainability and enhance its response and support to vulnerable customers and
vulnerable social groups, offering them affordable and reliable services that meet their needs. [S4: SBM-3_10_c]
In particular, Protergia, which is the Energy Sector’s retail pillar, has ensured and taken additional support actions to vulnerable
customers and vulnerable social groups in relation to the provisions of the relevant regulatory framework in Greece
167
, which
stipulates that all electricity suppliers are obliged to provide vulnerable groups of consumers with a different preferential tariff,
known as the Social Residential Tariff (SRT). [S4: SBM-3_10_a_iv] [S4:SBM-3_11]
IMPACT, RISK AND OPPORTUNITY MANAGEMENT
S4-1 - Policies related to consumers and end-users [MDR-P_65]
METLEN places particular emphasis on managing the impacts, risks and opportunities arising from its activities and has developed
a set of policies for consumers and end users. Their goal is to act as a guardian of the responsible and sustainable provision of
products and services, considering the needs and expectations of the constantly evolving energy market. The Group's policies
are oriented towards enhancing safety, quality and accessibility, while ensuring the provision of privileged and innovative
services, especially to vulnerable consumers and socially sensitive groups, with high levels of consistency and responsibility.
HUMAN RIGHTS POLICY
Year of update
2021
Key Content
[MDR-P_65_a]
METLEN has a zero tolerance policy for the violation of Human Rights that materializes both by the non-
participation (direct, passive or tacit) of the Group in relevant violations, and by avoiding any transaction and
contact with third parties that may have caused or there are reasonable grounds to suspect that they may
participate in creating conditions that may cause violations of such rights. Through its Human Rights Policy,
METLEN is committed to monitoring and protecting the right to health, safety and privacy of
customers/consumers arising from the use or distribution of its products. [S4:S4-1_16_a] Also, if training or other
measures are required for the safe use of its products, the Group undertakes to implement all necessary actions
to ensure that end users are aware of these requirements. [S4:S4-1_16_b]
Targeting
[MDR-P_65_b]
[S4:S4-1_16]
The Policy applies to the METLEN’s business activities as well as to its downstream value chain.
Governance
[MDR-P_65_c]
Validated by the Executive Leadership Team and monitored by:
7) Sustainability Committee of the Board of Directors
8) Human Resources General Division
9) Corporate Governance & Sustainable General Division
Compliance Division
Standards or
internationally
recognized third-party
initiatives
[MDR-P_65_d]
[S4:S4-1_17]
[S4:S4-1_AR_11]
a) United Nations Universal Declaration of Human Rights
b) Basic Conventions of the International Labor Organization (ILO)
c) Principles of the UN Global Compact
d) Global Sustainable Development Goals (2030 Agenda)
e) United Nations Guiding Principles on Business and Human Rights
f) Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational
Enterprises
g) United Nations Convention on the Elimination of All Forms of Discrimination against Women (Article 11
- field of employment)
h) ASI Performance Standard
167
Decision of the Ministry of Environment, Energy and Climate Change Δ5-ΗΛ/B/Φ29/16027/6.8.2010, as amended and in force
5. Annual Board of Directors Management Report
279
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Inclusion of Stakeholder
interests
[MDR-P_65_e]
This Policy was developed considering the opinion of METLEN main Stakeholder groups, through the 2021
special consultation.
Availability
[MDR-P_65_f]
Corporate Website
168
, Internal Information Portal (intranet)
In the Metals Sector, METLEN has adopted specific policies that ensure high standards of quality, safety and environmental
responsibility at every stage of its operations. In the primary aluminium and alumina production plant of Aluminium of Greece,
the Quality Policy and the Quality Policy of the Chemical Laboratory focus on maintaining strict specifications for products and
production processes. Through its Quality Policy, the Group is committed to continuous improvement of every aspect of its
business activity, with emphasis on identifying and managing general risks that could affect security, product compliance and
customer satisfaction. With this strategic approach, potential threats are identified early, while opportunities for improvement
are identified and leveraged to enhance the quality and credibility of services. The plant's policies apply to customers of all
products such as aluminium billets and slabs, hydrated and anhydrous alumina and caustic soda. Also, in EPALME's secondary
cast aluminium production plant, the Quality Policy ensures excellence across the entire range of metallurgical operations, with
the main product being the production of aluminium billets, with its customers as main beneficiaries. Responsible for the
implementation and periodic review of the Quality Policies is the General Management of the Metals Sector. Also, the Quality
Policies apply to the Group's own activities as well as to the downstream value chain. They are based on the international
standard ISO9001, which is externally certified. [S4:S4-1_15] [S4: SBM-3_10]
In the Energy Sector, and more specifically in the M Energy Customer Solutions, the Group applies a series of specialized processes
aimed at enhancing responsibility, transparency and mutual trust with consumers and end users. These policies include:
1) Sponsorship and Reward Process: These policies aim to support social responsibility and customer reward, strengthening
the Group's relationship of trust and support towards the community. In addition, they help maintain customer
satisfaction and loyalty, minimizing the risk of customer loss. Rewarding customers for consistent cooperation boosts
loyalty and reduces customer attrition, minimizing commercial risk. [S4:S4-1_15]
2) Code for the Management of Requests and Complaints of Protergia's Customers and other consumers (prospective
customers): Focuses on the effective handling of complaints, ensuring that consumers are treated with transparency and
respect, helping increase their satisfaction. [S4:S4-1_15]
3) Major Problem Management Process: This concerns the effective management of crises and major issues that may affect
the experience and safety of consumers. [S4:S4-1_15]
The protection of individuals with regard to the processing of personal data is of paramount importance to METLEN. Therefore,
the collection and processing of personal data by the Group is carried out only in accordance with the General Regulation and
the generally applicable legislation and where this is required in relation to the operation of employment relations and the
business activity of the Group. The Group allows access only to authorized persons and take increased data security measures
including loss, mishandling, unauthorized access, modification or disclosure. The Group provides support to all questions,
comments, concerns or complaints related to the protection of personal data or in case you wish to exercise any right regarding
the protection of your data. The Data Protection Officer can be contacted by email at DPO@mytilineos.gr address or by post.
[S4:S4-1_15] [S4:S4-1_16_c]
The retail energy Group, Protergia (M Energy Customer Solutions), has as a set of tools and mechanisms for communication and
consultation with customers and consumers set out in section [ESRS2: SBM-2] of this Sustainability Statement. [S4:S4-1_16_b]
Overall, METLEN's strong web of Policies contributes substantially to improving opportunities for creating positive impacts,
focusing on the continuous improvement and satisfaction of its customers and consumers. The commitment of top management
to high levels of quality, safety and environmental management ensures that the Group's services and products meet and, in
many cases, exceed, with the implementation of innovative approaches, customer expectations. Actions taken towards the
continuous strengthening of Policies include: [S4:S4-1_16_b]
1) Continuous monitoring of market and customer needs, to immediately identify opportunities for quality upgrades and
adaptations, meeting requirements based on changes in customer preferences.
168
https://www.METLENgroup.com/media/rp3edd3u/politiki_anthrwpinwn_dikaiwmatwn_en.pdf
5. Annual Board of Directors Management Report
280
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2) Promotion of technical excellence, innovation and participatory action, creating a dynamic learning environment for
employees, which improves their skills and the quality of production.
3) Management of resources and infrastructure to ensure continuous improvement of quality systems, thus contributing to
long-term customer satisfaction and trust.
4) Open dialogue and cooperation with external providers and stakeholders, promoting mutual respect and transparency,
factors that enhance the Group's reputation and allow it to tap into new markets and consumer segments.
5) Improvement of response time to complaints that allows immediate response to customers' needs, which not only
enhances their satisfaction but also improves the Group's effectiveness in customer service, building mutual trust while
respecting their rights. [S4:S4-1_16_c]
6) Social support sponsorships that enhance the Group’s extroversion and position it as a key social welfare supporter. They
also contribute to consumer awareness and create a positive perception, increasing opportunities for new partnerships
and attracting potential customers.
7) Reward for loyal customer relationships that helps build loyal customer relationships by increasing customer engagement
with the Group. This enhances the stability of the customer base and creates a reliable customer network that promotes
positive recommendations and increases the Group’s competitiveness. [S4:S4-1_15]
S4-2 - Processes for engaging with consumers and end-users about impacts
Given the wide range of activities, METLEN operates at many levels of communication, including stock exchange disclosures,
disclosures of new activities and projects, consumer updates, updates to other Stakeholders including local communities, etc. At
the same time, the Group’s international activity increases the difficulty level and raises challenges in providing timely and correct
information, as each country of operation has different customs, culture, mentality, but also institutional framework, with which
the Group must harmonize its actions. Therefore, the multitude of varied audiences which the Group addresses, in conjunction
with the multitude of its activities, constitute a significant challenge from the outset. Recognizing these dimensions, the Group
has started designing and implementing its Communication and Marketing Strategy, with the implementation of an annual
communication strategy plan and individual plans, depending on its business goals. Accordingly, these plans are evaluated to
identify whether updates or corrective actions are required. Communication and marketing are designed and implemented by
the Communication and Marketing Strategy General Division; however its scope concerns all General Divisions and activities of
the Group, and therefore cooperation mechanisms have been developed with all General Divisions, Committees, and the Group's
Management.
In this context, METLEN has developed a multidimensional strategy of cooperation with customers and consumers, which
includes a variety of actions and communication channels to ensure continuous interaction and meeting of their needs. [S4:S4-
2_20_a]
In the Metals Sector, the process of cooperating with customers focuses on ensuring high quality products and their satisfaction,
through organized and systematic procedures, with the aim of continuing the permanent and long-term cooperation with them:
1. Customer satisfaction survey: Periodic satisfaction surveys are conducted to evaluate the products and services provided,
allowing the identification of areas for improvement. [S4:S4-2_20_b] [S4:S4-2_20_d] [S4:S4-4_31_d]
2. Complaint recording system: An organized digital complaint recording system ensures the effective monitoring and
management of customer reports. [S4:S4-2_20_b] [S4:S4-2_20_d] [S4:S4-4_31_d]
3. Systematic visits and meetings with customers: Aluminium of Greece, EPALME, as well as European Bauxite hold regular
visits and meetings with customers to strengthen the relationship of trust and better understand their needs. [S4:S4-2_20_b]
[S4:S4-2_20_d] [S4:S4-2_21] [S4:S4-4_31_d]
4. Customer audits: Aluminium of Greece conducts internal and external audits by customers, in order to assess the quality
and conformity of production processes. [S4:S4-2_20_b] [S4:S4-2_20_d] [S4:S4-4_31_d]
5. Recording and meeting requirements through the ISO 9001 quality system: Customer requirements are recorded and met
through a quality system that complies with ISO 9001 standards, ensuring high product quality. [S4:S4-2_20_b]
6. Chemical analyses: For recurring customers of Delphi Distomon, such as the Aluminium of Greece plant, chemical analyses
of bauxite are carried out in the customer's accredited laboratory. These analyses are critical to assess product quality and
to perform corrective actions in case of deviations. [S4:S4-2_20_b] [S4:S4-2_20_d] [S4:S4-4_31_d]
7. Strict health and safety standards: The Group's primary products form the basis of the secondary products that will result
from its manufacturing customers, so indirectly the Group is committed and ensures the best quality of its offered
products (alumina and aluminium), according to the expectations and specification requirements of its customers’
different products. [S4:S4-2_21]
5. Annual Board of Directors Management Report
281
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In the Energy Sector, current regulations and the highest internationally accepted design practices of all industrial energy
production and renewable energy projects are considered, while there is detailed monitoring of quality measures and
characteristics during the procurement of materials and the manufacture of final products, in order to ensure that the specified
customer requirements are met. [S4:S4-2_20] [S4:S4-2_AR_17]
The stages and frequency of cooperation are presented below:
Type of cooperation with customers and
consumers/end-users
Stages and frequency of
cooperation
How to evaluate the effectiveness of
cooperation - agreements/results
resulting from cooperation
[S4:S4-2_20_b] [S4:S4-2_21]
[S4:S4-2_20_b]
[S4:S4-2_20_d] [S4:S4-4_31_d]
Customer Satisfaction Survey
1-2 times/year to a representative
sample of customers
Questionnaire (telephone / digital) in
which respondents evaluate all points
related to Protergia. The findings are
turned into actions implemented by the
relevant departments
Filing complaints through Protergia’ s
website
Continuous process availability
A complaint field in the contact form
169
Protergia profile on social media Facebook &
Instagram
Continuous process availability
Social Media platforms (Facebook
Messenger & Instagram) through which
customer complaints are submitted
Physical "Protergia Stores"
Continuous process availability
Using the form found on the site which can
be printed, filled-in and submitted by the
consumer
Protergia Loyalty On air Jan 2025
Continuous process availability
Agreements with suppliers, coupon system
Update on the new electricity and natural
gas programs
Continuous process availability
Monthly efficacy reports
Updates for bundle changes
Continuous process availability
Monthly efficacy reports
Immediate information on issues that
concern each customer
Continuous process availability
Monthly efficacy reports
Customer and Service Satisfaction Surveys
Continuous process availability
Monthly reports of effectiveness (creation
of a satisfaction survey on each customer
request)
Telephone Service (08:00-21:00 Monday-
Saturday and 09:00-19:00 Sunday) but also
through digital channels (site, bot, social
media)
Continuous process availability
Monthly efficacy reports
Table: S4/01
The above approaches used to cooperate with customers and consumers prove in practice that METLEN manages multiple
channels for recording the opinions of customers, consumers, as well as end users, it then analyses them and draws conclusions
which are integrated in the decision-making process and the design of strategies related to the management of its impact on this
specific Stakeholder group. This includes adjustments to the services and products offered, ensuring that the approaches applied
meet the real needs and expectations of customers, ensuring consumer satisfaction and trust. [S4:S4-2_20] [S4:S4-2_20_AR_17]
To ensure the legality of its communication and promotional activities, METLEN monitors developments in relevant legislation
and voluntary codes of conduct. In this direction, the Group's communication partners abide by the Greek Code of Advertising –
169
https://www.protergia.gr/en/customer-service/contact/email-contact-form/
5. Annual Board of Directors Management Report
282
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Communication and compliance is verified by the Communication Control Council pursuant to Greek legislation. The principles
of this Greek Code presuppose that all promotional activities must be legal, decent, honest, created in a spirit of social
responsibility and comply with the principles of fair competition, as generally accepted in the market. In addition, the Group
participates in institutions such as: SEV, the Hellenic Capital Market Commission and the Hellenic Advertisers Association which
have a series of obligations, commitments and rules that the Group embraces and considers in its Communication and Marketing
activities. Finally, the CEO and the Executive Leadership Team of METLEN are updated on and assess the progress and
performance of the Communication and Marketing Strategy General Division at regular intervals. [S4:S4-2_20_a] [S4:S4-2_20_b] [S4:S4-
2_20_c] [S4:S4-2 _AR_14] [S4:S4-2_AR_15] [S4:S4-2_AR_16]
S4-3 - Processes to remediate negative impacts and channels for consumers and end-users to raise
concerns
METLEN takes a proactive approach by establishing procedures that allow the immediate and effective management of any
problems that may arise for its customers and consumers. Through systematic monitoring of customer satisfaction indicators and
complaint handling and analysis using a dedicated digital platform, it ensures that their needs are considered and that the Group
responds to them. Seeking the continuous improvement of services provided, the Group remains committed to providing an
overall positive experience to its customers, enhancing their trust and satisfaction. [S4:S4-3_25_a] [S4:S4-3_AR_18]
The Group has a multitude of communication channels to support customers and receive concerns related to its activities,
products and services.
In the Metals Sector, in the case of all its industrial and mining plants (Aluminium of Greece, EPALME, European Bauxite, Delphi-
Distomon), customers may contact directly for any complaint they wish to voice, by phone or email, ensuring fast and efficient
service. [S4:S4-3_25_b] Specifically, the Aluminium of Greece plant has a mechanism for receiving and handling complaints
concerning products and coming from customers. Complaints are received and recorded by the Commercial Management team
using the digital application "Sales/Cast Quality" for cases where a customer notes the existence of deviations in relation to the
requested specifications of the product sold. Each complaint is carefully analysed to detect the possible causes that caused it.
This process involves constantly communicating with the customer until the complaint is closed, ensuring that customers feel
their concerns are being taken seriously. [S4:S4-3_25_d] [S4:S4-3 _26]
It should also be noted that even for the sole customer of "Delphi-Distomon", which is the Aluminium of Greece plant, the quality
assessment of bauxite is performed via chemical analyses in an accredited laboratory. In case of any deviation from the quality
standards, immediate corrective actions are followed, ensuring the integrity of the raw material and, consequently, customer
satisfaction. In addition, at the regular management meetings (LMR - Local Management Review), there is a discussion of
complaints and analysis of the issues raised, as well as the corresponding resulting actions, ensuring that customer concerns are
discussed at the highest level and that corrective action is taken where necessary. [S4:S4-3_25_d]
In the Energy Sector, there are special procedures in place for receiving complaints, depending on the activity. For marketing,
there is the "Retail Complaints Procedure", and for construction and operation of thermal plants and RES projects there is a
procedure for "Handling Stakeholder Complaints". Complaints can be filed either through the sector’s or METLEN’s social media,
or using dedicated contact forms, but also by sending an e-mail to info@protergia.gr or info@METLENgroup.com. In addition, for
areas where new Power Stations are being constructed, relations with local communities are managed and a climate of
cooperation is promoted, supported by the "Promotion of Relations with Local Authorities" procedure. [S4:S4-3_25_b]
Moreover, all Energy Sector customers have access to telephone customer service they can use to receive immediate
clarifications and support. [S4:S4-3_25_b]
In addition, the 85 physical stores provide face-to-face service, facilitating interaction with customers. The corporate website
https://www.protergia.gr/en/ also has contact forms for asking questions or raising concerns. [S4:S4-3_25_b]
At the same time, the MyRAE/Enomos platform offers additional digital channels, through which customers can monitor their
services and communicate on any issue that may arise. [S4:S4-3_25_b]
The effectiveness of the adopted procedures is monitored with monthly reports. These reports evaluate and analyse the Group's
performance, providing valuable insights into service quality, regulatory compliance, and customer satisfaction. Weekly meetings
are also held with the participation of all Department Heads of Protergia, where all significant issues arising from consumer
communications are discussed. Additionally,
5. Annual Board of Directors Management Report
283
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
the Head of Management of the Sector is informed through scheduled meetings with each Department Head. [S4:S4-3_25_c]
The systematic recording and analysis of data allows the business to identify areas for improvement, as well as record successes
and progressive results. This way, monthly reports contribute to continuous improvement of procedures and enhanced efficiency,
ensuring that the business competes successfully in the market. [S4:S4-3_25_d]
For retail customers, complaints are received and recorded by the customer service department, through the digital channels
and the physical stores of the Energy sector. Each complaint is analysed and traced to the possible causes, followed by
communication with the consumer who filed it to update them on the outcome, ensuring that customers feel that their concerns
are taken seriously. [S4:S4-3_25_d] [S4:S4-3 _26]
Customer Privacy Management Procedures
The protection of individuals against the processing of personal data is a fundamental right and of utmost importance to METLEN.
Although the Group primarily does not process special categories of data (sensitive data), the business direction of Protergia in
the retail sale of electricity and natural gas, as well as the size of METLEN in terms of employees and business partners, require
large-scale processing of personal data. METLEN remains responsible for data processing with specific obligations and
responsibilities, and in cases of outsourcing this processing to third parties, it ensures their compliance through continuous and
stringent controls. Additionally, transactions with business partners outside the European Union, particularly in countries with
less strict personal data protection laws, create the need for the transfer of personal data, the protection of which must be
ensured. Therefore, the collection and processing of personal data is only done in accordance with the law and where necessary
regarding the functioning of employment relationships and the Group’s business activities. The Group allows access only to
authorized personnel and takes enhanced security measures to protect the data. [S4:S4-3_25_a]
S4-4 - Taking action on material impacts on consumers and end-users, and approaches to managing
material risks and pursuing material opportunities related to consumers and end-users, and effectiveness
of those actions [MDR-A_68]
All business sectors of the Group, apply a certified Quality Management System, according to the international standard ISO
9001: 2015, which is accompanied by individual Quality policies. [S4:S4-4_30] [S4-4_33_b]
In the Metals Sector, the Group's laboratories, which are a key contributor to the quality programme, systematically control all
stages of production, from raw materials to finished products. To this end, the official SDS (Safety Data Sheets)
170
describe the
risks associated with the products, as well as all the necessary precautions to be taken to avoid/address these risks. [S4:S4-4_31_a]
[S4:S4-4_AR 35]
Regarding the labelling requirements for aluminium and alumina products sold, a "Certificate of Conformity/Analysis" is issued
for each relevant shipment indicating all the necessary information. [S4:S4-4_30]
The Aluminium of Greece plant is committed to ensuring the optimum quality of its products, according to its customers’
expectations and requirements, by offering products, i.e. hydrated and anhydrous alumina and aluminium alloy products as well
as related services, that meet quality requirements. In this context, in order to monitor product safety performance, customer
complaints that may be related to product safety are systematically collected, analysed and addressed through specific corrective
actions, while the ultimate aim is to eliminate such complaints. [S4:S4-4_30] [S4:S4-4_33_b]
Furthermore, the Sector’s activities have been harmonized with the requirements of the European Regulation "REACH" for the
effective management of chemicals used in industrial processes. In the context of ISO 9001:2015, methodologies are applied for
the identification and analysis of operational risks and opportunities for improvement, such as risk analysis, and external quality
audits are carried out, including product safety. [S4:S4-4_31_a] [S4:S4-4_AR 35]
170
Capex: 25k for revision and translation of SDS and version of EPD (Environmental Product Declaration) [S4-4_37]
5. Annual Board of Directors Management Report
284
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Sector’s quality control laboratory is accredited by ESYD (National Accreditation Council) according to the requirements of
international standard ISO 17025: 2017, the scope of accreditation being the analysis of bauxite, alumina, aluminium and its
alloys. [S4:S4-4_33_b]
It should be noted that the products of the Sector do not include any harmful chemicals. [S4:S4-4_30]
EPALME's secondary cast aluminium production plant places particular emphasis on the safety and quality of its products,
providing customers with the relevant certifications and safeguards. Specifically, the Group provides the "Recycled Content
Verification" Certification (2024), which confirms the content of recyclable materials, as well as SVHC (Substances of Very High
Concern) and Conflict Minerals of 3TG (Tungsten, Tantalum, Tin, Gold) for responsible sourcing of raw materials. The EPALME
plant operates a radioactivity control gate for incoming scrap aluminium, ensuring the health and safety of staff and the safety
of the final product. Additionally, in 2024, the modernization of the filter frame
171
in the casting channel was completed,
contributing to the control and containment of inclusions, resulting in improved quality of the final product. [S4:S4-4_30] [S4:S4-
4_31_a] [S4:S4-4_AR_35] [S4:S4-4_33_b]
In the Energy Sector, the highest international quality criteria and the requirements of specialized international specifications
and codes are applied, to ensure the quality of the heavy and/or complex metal construction projects undertaken. For each
construction project undertaken by the Group and before the start of construction, a Hazard and Operability Study (HAZOP) or
Risk Assessment is carried out. The purpose of HAZOP is to identify and evaluate problems that may represent risks to personnel
or equipment that have not been identified at the project planning and design stages. [S4:S4-4_30] [S4:S4-4_31_a] [S4:S4-4AR 35] [S4:S4-
4_33_b]
At the same time, Protergia, which is the retail arm of the Energy Sector, provides special tariff arrangements to residential
consumers by offering the Social Residential Tariff (SRT-G), which complies with the legislation
172
and covers vulnerable social
groups, offering favorable pricing terms that help reduce the energy expenses of these vulnerable consumers. Through
continuous adjustments based on legislation, Protergia has taken additional steps to support vulnerable customers and sensitive
social groups in accordance with the relevant regulatory framework in Greece, thus reducing the risk of non-payment of bills and
social dissatisfaction, thereby enhancing the social acceptance of the Group and preventing potential legal sanctions.
Additionally, Protergia has been designated as the Universal Service Supplier (since 21/06/2022), providing electricity to
consumers who do not have a contract with any other supplier, ensuring continuous and stable access. The obligation to provide
electricity to households and small businesses that cannot find a supplier or do not have representation reduces the risk of
consumers losing access to essential services and ensures market stability, limiting the potential for legal issues and negative
publicity for the Group. Moreover, Protergia has prioritized transparency in Billing, promoting an open and understandable
presentation of charges to consumers, thereby strengthening transparency and trust. [S4:S4-1_15]
The following table presents relevant data for 2024, regarding the Group's response to regulatory provisions for the protection
of consumers who were affected by incidents that impacted their ability to pay their bills:
Period (2024)
Disaster
Action
January- February
Storm Daniel
August-September
East Attica Fires
September - November
Pollution of the Pagasitikos Gulf
November
Fires in the municipalities of Xylokastro -
Evrostini
Temporary suspension of collection -
disconnection actions
Table: S4/02
The Energy Sector’s projects and services in 2024 were in accordance with the terms of the contracts and its contractual
obligations to its customers, to whom information and warnings on health & safety and the environment are provided, such as:
a) instructions for use, maintenance and disposal for the entire project (e.g. railway telecommand), b) labelling of all materials
and equipment (signs, warnings and relevant instructions) at a conspicuous location, and c) instructions for use – recycling as
safety data sheets (SDS) for all hazardous materials. [S4:S4-4_31_c]
171
capex: 94k for mounting the filter frame, opex:13k/month [S4:S4-4_37]
172
D5-IL/B/Φ29/16027/6.8.2010 decision of the Ministry of Environment and Energy, as amended and in force
5. Annual Board of Directors Management Report
285
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The totality of the implemented actions is monitored with the aim of evaluating their effectiveness through the following
mechanisms:
a) Weekly meetings with the participation of all department heads of Protergia;
b) One-on-one meetings with Management to draw conclusions and provide directions;
c) Issuance of reports and specific progress tracking indicators (KPIs), related to the maintenance and growth of the customer
base;
d) Conclusions from customer satisfaction survey results;
e) Management reviews through quarterly summaries (Extended Leadership Meetings - Energy).
In addition, the Energy Sector has an Applied Research & Development and Innovation Department, which evolved into the new
innovative spin off technology Group Avokado (https://avokado.energy/) that acts as METLEN's strategic technological arm in
Artificial Intelligence (AI), Technology and Digital Innovation. More information about this collaboration can be found on the
corporate website
173
.
The adoption of new technological solutions, especially Artificial Intelligence (AI), is a necessary condition for the implementation
of the "green" energy transition. However, global supply is limited relative to demand, so Avokado aims to fill this gap with
solutions tailored to the needs of the global smart energy market.
AVOKADO is the only specialized Group-producer of integrated artificial intelligence solutions for energy and "Smart Cities" in
Greece, and METLEN is its sole shareholder. Specifically, AVOKADO has a deep knowledge of the electricity market, in Greece and
abroad, having invested in the development and standardization of algorithms and machine learning models, which cover the
entire range of needs of energy producers and consumers (producers of electricity from conventional and renewable sources,
electricity providers in wholesale and retail markets, household consumers, businesses of all sectors of the economy, public
sector bodies, local and regional authorities, as well as central government bodies/agencies) for their green energy transition
with a particular focus on Artificial Intelligence operating systems to optimize the lifecycle of home battery systems and
professional energy storage systems (BESS).
AVOKADO's innovative Artificial Intelligence operating system for home battery systems and professional energy storage systems
(BESS) is commercially available under the AVOS™ brand. AVOKADO's comparative advantage is that it has the most
comprehensive portfolio of Artificial Intelligence (AI) software and solutions for Energy and Smart Cities, because it combines
Energy Machine Learning Models, Location AI and Generative AI. Specifically, AVOKADO offers: [S4:S4-4_33_b]
a) an AI platform under the brand name AVOX™ for the green energy transition of businesses, organizations and bodies of
Central Government, Municipalities, Local Authorities and Regions,
b) an AI operating system branded AVOS™ to enhance functionalities and extend the lifetime of home battery systems as
well as larger energy storage systems (BESS), and
c) a digital AI toolkit branded AVOKADO AI™ to meet the specific needs of the energy industry,
d) a Smart GenAI CORTEX Digital Assistant for B2B Customers.
During 2024, the following projects/new products and services were underway: [S4:S4-4_32_b]
1) Project Avokado CORTEX: creation of an Energy Assistant based on GenAI. The smart energy assistant CORTEX
operates on top of the AVOX platform and acts as an assistant for B2B customers in energy management and energy
costs (budgeting)
2) Project AVOX Retail to create a smart Dashboard for customers with smart meters. The platform manages data from
smart meters developed by Protergia to residential consumers, integrating many AI algorithms
3) Project AVOS Smart Battery management for Net Billing services. Algorithms and automated storage
scheduler for managing storage and batteries in Prosumer systems for selling energy to the system at DAM
prices.
4) AI Factory @ Avokado: creation of processes, know-how and organization of internal AI structure and Data
Factory to introduce AI strategy. AI and Generative AI platform and models
5) Demand forecasting projects on IPTO curve, MV and 5, 6, 7
174
customers, and PV/Solar production forecasting:
creation of algorithms (AvokadoAI) and processes for 15-minute demand forecasting to Protergia customers
173
https://www.METLENgroup.com/news/press-releases/a-young-at-heart-innovation-start-up-by-mytilineos/
174
Medium Voltage and commercial connection (C21, C23, C22) customers with remote metering capability by HEDNO
5. Annual Board of Directors Management Report
286
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
6) Participation in the new Greek Energy Competence Centre with the CN HESS (https://cn-hess.hecc.gr/)
project, which is a decision-making tool (AI) for hybrid energy interconnected systems with battery and
hydrogen
7) Blockchain Energy Smart Contracts: creation and execution of blockchain smart contracts for demand response and
Green PPA services between prosumers and Aggregators and integration into the AVOX platform
8) Project Demand Response to 5,6,7 customers, connections with smart battery/inverter control: Execution of demand
management scenarios to Protergia customers with a household battery for the purpose of dynamic smart charging
and battery discharge in low DAM zones
9) Project Energy Disaggregation of residential consumers and prosumers: creation of energy disaggregation algorithms
and services for detecting consumption of household appliances in Protergia customers
10)European project SEDIMARK: European H2020 project on data marketplaces in the field of energy for data and AI
services
11)European Project TRINEFLEX: European H2020 project on Demand Response issues with blockchain technologies.
The total budget managed by Avokado in 2024 was €650 thousand and the total funding received under the co-funded
programmes it participates in amounted to €102 thousand. It employs 12 people. [S4:S4-4_37]
Subsidiary METKA SA, in addition to considering the internationally applicable regulations for the design and construction of all
infrastructure, environmental, building and other projects, performs detailed monitoring of quality measures and characteristics
during the procurement of materials and the manufacture of the final product to ensure that the specified customer
requirements are met. [S4:S4-4_30]
The Group's works and services were in accordance with the terms of the contracts and its contractual obligations to its
customers, to whom information and warnings on health & safety and the environment are provided, such as: a) instructions for
use, maintenance for all equipment provided (operation & maintenance manuals) and materials, (b) labelling of all materials and
equipment (signs, warnings and instructions) at a conspicuous location. [S4:S4-4_31_c]
Finally, METKA's subsidiary, Zeologic S.A., advances research and innovation in the sensitive waste treatment sector. using the
GACS technology which has been internationally patented by Zeologic S.A., the company is able to treat the widest range of liquid
and solid waste, hazardous or not, with a different approach to existing methods, which does not consider the biological factor
as the basic parameter but is based on its principles Nanotechnology. This leads to excellent results in much less processing time
and requiring less space, with lower operating costs and minimal environmental footprint. This technology has been applied and
is being applied in private projects of the food, paints, chemicals industry, but also in the Aluminium plant of METLEN's Metals
Sector.
Overall, in 2024, no incidents of non-compliance with regulations and voluntary codes regarding the health and safety effects of
METLEN's products and services were recorded.
Actions related to customer privacy management
To ensure, as much as possible, the protection of personal data managed by it, the Group has: [S4:S4-4_33_a] [S4:S4-4_33_b] [S4:S4-
4_34]
1. Established the position of Data Protection Officer (DPO) since 2018 and notified the relevant authority;
2. Implemented a deviation study from the General Data Protection Regulation (GDPR) and has taken the appropriate
corrective actions since 2018;
3. Developed a data protection policy for all employees and subsidiaries, as well as for business partners, and
communicated it to all relevant parties;
4. Appointed Data Protection Coordinators in each unit, who have access to the processing activities and are in continuous
cooperation with the DPO;
5. Created a personal data processing register which is regularly updated;
6. Completed Data Privacy Impact Assessments for processing procedures that require them;
7. Established and operates a mechanism for recording any personal data breaches and notifying the relevant Data
Protection Authority and affected data subjects, if required,
8. Has trained over 2,000 employees, through computer-based training and in-person sessions, who are involved in
processing personal data;
9. Has obtained ISO 27701 certification for personal data processing and ISO 27001 certification for information security.
5. Annual Board of Directors Management Report
287
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Additionally, personal data protection risks are included in the Group’s Risk Management System and are continuously
monitored.
METRICS AND TARGETS
S4-5 - Targets related to managing material negative impacts, advancing positive impacts, and managing
material risks and opportunities [MDR-T_79]
METLEN has set several strategic targets to improve customer experience and drive positive impact in both the Metallurgy and
the Energy Sectors.
Targets in the Metals Sector: In order to maintain the recognized positive impact, the Metals Sector sets annual goals within the
framework of the Quality Management System (ISO 9001:2015). The goals include, among others, the implementation of
inspections, the management of customer complaints, the percentage of non-quality products, etc., with the aim of continuously
improving the quality of products and services and ensuring customer satisfaction. [S4:S4-5_41]
Targets in the Energy Sector: Specific internal objectives have been established on an annual basis in order to monitor
effectiveness, maintain the quality of services provided and customer satisfaction:
a) Abandoned Call Rate (ACR): The target is to keep the percentage of unanswered calls in telephone service below 10%.
The result of this specific indicator for 2024 was 6%, reflecting the continuous improvement that the Group aims for in
serving the requests of its customers. The target started to be monitored in 2017 (it was ≤5%). [S4:S4-5_41]
b) First Call Resolution (FCR): The target is that more than 80% of customer requests are resolved within one day, to further
improve immediate customer satisfaction. For 2024, the performance of this specific indicator was 88%, a result of the
thorough analysis of submitted requests aimed at adopting implemented solutions. The target started to be monitored in
2017 (it was ≥90%). [S4:S4-5_41]
c) TNPS (Transactional Net Promoter Score): The TNPS, launched in September 2024, measures customer satisfaction after
every contact they have with the Group, looking to steadily improve customer satisfaction indicators monthly. The first
results from the implementation of this indicator are expected at the end of 2025. [S4:S4-5_41]
The Group's targets are measurable and verifiable, as they are based on specific quantitative data obtained through structured
information collection and research processes. ACR, FCR, TNPS indicators are based on a combination of international practices
and accepted performance indicators, while being aligned with national and European legislation, crisis management standards
and domestic policies. Also, the above-mentioned indicators which are used to measure customer satisfaction and improved
customer experience, ensure compliance with quality and efficacy standards. [S4:S4-5_41_a]
Furthermore, the procedure that has been developed for the Group's response to crises from weather events or natural disasters
includes the training of support teams and indicates that the top priority is immediately providing information and services to
customers, and cooperating with State authorities. The aim is to reduce response time, maintain customer satisfaction and
strengthen cooperation with local authorities and services. [S4:S4-5_41]
The Group uses the results of measurements and feedback received from customers/consumers to identify areas that need
improvement. Also, through special feedback sessions, the main conclusions of the findings are presented to Group executives
and the relevant lessons learned and proposed actions are identified. Appropriate changes are then initiated, based on the main
findings of the surveys with a view to improving customer experience. Data from survey measurements, as well as from the
effectiveness of the adopted approaches, are disclosed to interested audiences (customers/consumers/end users) through the
Group's social media, as well as other official communication channels. [S4:S4-5_41_b]
Meanwhile, starting in 2024, the Energy Sector’s customers/consumers can actively participate in the development of new
solutions, through pilot tests and working groups accompanied by opportunities to assess their experience, an approach adopted
for the new smart meters service. [S4-5_41_c]
Customer Privacy Management Results
5. Annual Board of Directors Management Report
288
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Compliance with applicable legislation, as well as the implementation of compliance control safeguards regarding METLEN's
activities in 2024, resulted in the absence of any significant personal data breach incidents.
Information on recorded non-compliance incidents
related to the customer privacy regulatory framework
Total
Personal data breaches, which involved the preparation and sending of contracts
or invoices to the wrong recipient (confidentiality breach), loss of invoices by a
partnered postal Group (availability breach).
*For the above, the causes of failure were identified, and additional technical
and organizational measures were taken to eliminate them.
8
% breaches that require notification to the Hellenic Data Protection Authority
(HDPA) in accordance with the GDPR guidelines.
62%
Confirmed complaints by data subjects through the Hellenic Data Protection
Authority (HDPA) regarding promotional calls to phone numbers listed under
Article 11 of Law 3471/2006, originating from METLEN or its external partners.
0
Number of data subject requests related to GDPR for 2024*
227
* most of these requests concerned the right of access and exemption from
processing. These requests were answered/satisfied within the timeframe
stipulated by the GDPR (within 30 days)
Table:S4/03
Within 2024, seven (7) second-level inspections (GDPR Audits) were conducted on its external partners, who are considered the
'Processors,' as part of the assessment of their compliance with the requirements of the General Data Protection Regulation
(2016/679).
Results of Information Disclosure and Communication
The Group's products are not subject to any restrictions on their distribution in specific markets, and there were no significant
issues related to product communication that concerned its Social Partners' teams. [S4-4_34]
Regarding the provision of verifiable and clear information concerning the labeling of its products, METLEN fully complies. Each
customer has the means to check all essential information and, if desired, performs the corresponding verification. In this way,
the Metals sector of METLEN ensures respect for the right to information for all of its products, as shown in the following table.
[S4-4_35]
5. Annual Board of Directors Management Report
289
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Table: S4/04
Information on recorded non-compliance incidents related
to the disclosure of information and communication
2024
2023
2022
Confirmed non-compliance incidents during the
implementation of METLEN's communication strategy with
regulations and optional communication codes, including
promotional activities and sponsorships. [S4-4_34]
0
0
0
Confirmed non-compliance incidents with regulations
concerning the information and labeling of the Group's
products.
0
0
0
Confirmed non-compliance incidents with regulations and
legislation (in economic, environmental, labor, and social
matters).
[S4:S4-4_35]
0
0
0
Table: S4/05
Information Regarding Product Labeling
Basic categories of products subject to the
following information requirements
Aluminum
Alumina
Information about the origin of the product's
elements or ingredients.
Information about the content, particularly
concerning substances that may have
environmental or social impact.
100%
100%
Information about the safe use of the product or
service.
Information on the disposal method of the
product and the environmental/social impacts it
may have.
Non-applicable requirements
In the Metals Sector, the aforementioned labeling requirements apply to products for sale, aluminum poles and plates, as well
as anhydrous and hydrated alumina. For each batch of aluminum or alumina, a "Certificate of Conformity" is issued, which
contains all the necessary quality specifications for each batch, and the Safety Data Sheet (SDS) for each product is available.
5. Annual Board of Directors Management Report
290
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
BUSINESS CONDUCT [ESRS: G1]
MANAGING IMPACT, RISKS & OPPORTUNITIES
G1.IRO-1 — Description of procedures to identify and assess major impact, risks and opportunities
METLEN Energy & Metals applies a system for the continuous monitoring of and compliance with regulatory and legislative
changes and developments, thus minimizing the likelihood of negative non-compliance impacts that could significantly affect the
financial position and cash flows, the reputation and, consequently, METLEN's ability to meet its obligations.
175
As shown in the materiality assessment (see [ESRS2:SBM-3] & [ESRS2:IRO-1])
ACTUAL POSITIVE IMPACT [AP6]
175
:
Established culture of business ethics/zero tolerance to bribery and corruption
This refers to recognizing that ensuring transparency in all transactions carried out in course of METLEN's business is pivotal for
its sustainability and further development in the context of its international operations. This impact is recognized both in
METLEN's own business and in its upstream and downstream value chain. [G1:G1-1_9] [G1:G1-1_AR_1]
Time Horizon:
Actual
Position in the Value Chain:
Upstream, Own Operations, Downstream
FINANCIAL OPPORTUNITY [G1-O1]: Enhancement of the Group's entry capabilities into new markets as a result of the
transparent and ethical business practices it adopts
Financial Significance:
Very high
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Upstream, Own Operations, Downstream
FINANCIAL OPPORTUNITY [G1-O2]: Increased financing opportunities, more stable business partnerships, and enhanced
credibility in the market
Financial Significance:
Very high
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Upstream, Own Operations, Downstream
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS
MODEL & VALUE CHAIN
[SBM3:48_b]
CURRENT AND POTENTIAL IMPACT ON STRATEGY & DECISION
MAKING
[SBM3:48_b]
a) Acceptance of the Group by its Stakeholders and the
broader society, as a result of the Group's commitment
to transparency and business ethics.
b) Strengthening the Group's credibility in the market, as a
result of its commitment to zero tolerance to bribery and
corruption, attracting responsible investors and
partners.
c) Creating a climate of trust towards the Group in the
markets in which it operates as well as enhancing its
possibilities to enter new markets as a result of the
transparent and ethical business practices it adopts.
d) Promoting a culture of integrity within the organization
that encourages employees to follow ethical principles
and procedures.
e) Compliance with high standards of transparency and the
application of strict business ethics rules, along with
mechanisms for monitoring effectiveness.
f) Strengthening corporate reputation as a responsible and
dependable corporate citizen, supporting its long-term
sustainability, being a positive model in its Business
sectors and business lines.
g) Shielding the Group against corruption, fraud,
embezzlement and abuse, further enhancing its
corporate image.
a) Aligning the Group's strategy with international sustainable
development and corporate responsibility trends, with the
2030 Agenda and the Global Sustainable Development Goals
(SDGs), as well as with its voluntary commitments to the 10th
Principle of the UN Global on the Fight Against Corruption.
b) Improving the Group's reflexes and strategic flexibility through
regular feedback from its Stakeholders and key partners that
allows for immediate and appropriate adaptation of the
decision-making process.
c) Incorporating transparency and ethics criteria in the process
of evaluating new partnerships and investments, ensuring
that strategic choices are aligned with the increased demands
for responsible and sustainable practices.
d) Focusing on investments to enhance corporate governance
and improve internal processes, supporting transparency at all
levels and promoting corporate responsibility and integrity.
e) Upgrading risk management and compliance systems, which
leads to continuous improvement of the strategy and
enhances the Group's credibility in the market.
f) Constant investment in order to strengthen the culture of
transparency and alignment with the expectations of
Stakeholders and investors as regards responsible
governance, through the adoption of appropriate certification
systems and implementation of training seminars.
5. Annual Board of Directors Management Report
291
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
POTENTIAL NEGATIVE IMPACT [DA5]
176
:
Instances of unethical practices in the value chain
This impact concerns the recognition of any potential unethical practices in the value chain arising from incidents of corruption
related to internal operations, incidents of corruption in an intermediate customer that is not final, incidents of corruption
involving a supplier acting on behalf of the Group, as well as from the lack of understanding, acceptance and limited
implementation of codes of conduct, despite the Group's zero tolerance and high level of commitment.
Time Horizon:
Short-Term
Position in the Value Chain:
Upstream, Own Operations, Downstream
FINANCIAL RISK [G1-R1]: Potential exclusion from new agreements and entry into new markets due to indirect involvement in
unethical practices, especially in countries with a high corruption index
Financial Significance:
Very high
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Upstream, Own Operations, Downstream
FINANCIAL RISK [G1-R2]: Potential financial penalties and loss of revenue from investors and customers who prioritize
transparency.
Financial Significance:
Very high
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Upstream, Own Operations, Downstream
FINANCIAL RISK [G1-R3]: Potential decrease in the Group's ability to attract responsible partners and investors, reducing its
long-term competitiveness
Financial Significance:
High
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Upstream, Own Operations, Downstream
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS MODEL & VALUE
CHAIN [SBM3:48_b]
CURRENT AND POTENTIAL IMPACT ON STRATEGY &
DECISION MAKING [SBM3:48_b]
a) Undermining the ethical environment of the Group in the event of
corruption, bribery, fraud and violation of healthy competition.
b) Consequences on the working environment, the reputation of the
Group and possibly a violation of human rights, due to indirect
participation in unfair and non-transparent practices can cause fines,
reputational damage and exclusion from socially responsible
partnerships.
c) Adverse effects on the natural environment and failure of the Group
to meet its environmental commitments due to indirect participation
in unfair and non-transparent practices may cause fines, reputational
damage and exclusion from environmentally responsible
partnerships.
d) Impeding the fair distribution of wealth and economic growth due to
corruption, especially in countries affected by corruption, resulting in
damage to the Group's reputation and causing legal problems and
exclusions from public works and other investments.
e) Emerging obstacles to sustainable development due to weak
adherence to codes of conduct, with a particular impact on poor
communities, eroding the social fabric and exposing the Group as
regards its public commitments.
a) Re-evaluation and tightening of transparency
targets and relevant procedures, including the
integration of additional pollution prevention
measures.
b) Affecting strategy on expansion to and
positioning in existing and new markets, limiting
the possibilities and options for new agreements.
c) Enhancing investment in systems and
technologies to prevent corruption, bribery and
overall unfair practices.
d) Establishment of a risk management strategy
with increased provisions for potential incidents
of corruption and bribery, as well as for unfair
practices in general.
e) Requirement for increased investment in
compliance systems to avoid fines and minimize
re-occurrence.
f) Requirement for additional resources to restore
relationships of trust with stakeholders.
ACTUAL POSITIVE IMPACT [AP7]
177
:
Responsible supply chain management
176
Time horizon: Short-term
177
As shown in the materiality assessment (see [ESRS2:SBM-3] & [ESRS2:IRO-1])
5. Annual Board of Directors Management Report
292
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
This impact is caused in all workplaces of the Group's Business Sectors, subsidiaries, contractors and suppliers. METLEN's Business
Sectors, its subsidiaries and its contractors/suppliers are directly involved in these effects.
Time Horizon:
Actual
Position in the Value Chain:
Upstream, Own Operations
FINANCIAL OPPORTUNITY [G1-O1]: Enhancement of resilience and business continuity by reducing the risks of partnership
disruptions, ensuring a stable supply flow
Financial Significance:
High
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Upstream, Own Operations
FINANCIAL OPPORTUNITY [G1-O2]: Enhancement of attractiveness to institutional investors and financial organizations that
prioritize ESG criteria
Financial Significance:
High
Time Horizon:
Short Term, Medium Term & Long Term
Position in the Value Chain:
Upstream, Own Operations
CURRENT AND POTENTIAL IMPACT ON THE BUSINESS MODEL &
VALUE CHAIN
[SBM3:48_b]
CURRENT AND POTENTIAL IMPACT ON STRATEGY &
DECISION MAKING
[SBM3:48_b]
a) Building strong and long-term relationships of trust and
mutual benefit with its suppliers and partners.
b) Maintaining long-term partnerships with a large number
of key suppliers.
c) Priority to local suppliers according to their financial,
quality and time trustworthiness, the cost of their products or
services, based on their ability to ensure the required quality and
meet procurement needs based on the defined specifications as
set by the Group's Business sectors.
d) Timely response to the gradual strengthening of
regulation through the integration of environmental, social and
governance aspects into supplier evaluation.
e) Establishment of criteria that characterize its suppliers as
key or critical.
a) Ensuring optimal risk management in the Group's
supply chain and exploiting business opportunities through
the creation of responsible suppliers and partners that can
create expanded economic and social value; developing
positive effects, in the medium and long term.
b) Enhancing responsible practices in the Group's
supply chain to avoid problems in the supply of raw
materials, materials and services, avoid environmental
impact, mitigate Health and Safety risks, violation of human
rights, ethical issues enhancing its reputation and credibility.
c) Enhanced ability to strategically expand to existing
and new markets as a result of strong partnerships with key
suppliers.
G1-1 — Corporate culture and Business conduct policies
The Group's “Responsible Corporate Citizenship” is reflected on its engagement in international transparency initiatives (UN
Global Compact), national working groups and, more generally, in its commitment to ethical business practices and good
corporate governance. METLEN is formally committed to the 10th principle of the UN Global Compact, namely that “it works
against corruption in all its forms, including extortion, bribery and facilitation payments”. Such principle acts as a catalyst in the
development of the ethical culture throughout the Group. METLEN has the following policies in place: [G1:G1-1_7]
CENTRAL CONFLICT OF INTEREST POLICY
Year of preparation
2021
Key Content
[MDR-P_65_a]
METLEN has a wide range of activities in various industries and sectors of the economy. During the
development of its business, and as a result thereof, the Group cooperates with, contacts, and influences a
wide range of stakeholders, including shareholders, members of its Board of Directors and members of its
Management, employees, customers, suppliers, commercial agents and representatives. Given the
multitude of interests that may exist among all these stakeholders, conflicts of interest may arise which, if
not appropriately handled and addressed, may expose the Group to significant reputational risk and/or
even disrupt its operations.
Targeting
[MDR-P_65_b]
a) Prevent and manage potential conflicts of interest with appropriate policies to minimize
reputational risk and ensure business continuity.
5. Annual Board of Directors Management Report
293
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
b) Protect the corporate interest through targeted actions that enhance transparency and
strengthen responsible corporate governance.
Governance
[MDR-P_65_c]
The METLEN BoD is responsible for approving this Policy, as well as for any amendment thereof.
The scope of this Policy covers METLEN and all persons subject to it who should be aware of the Policy and
act on it. Persons who are responsible to comply with this policy include the following: a) members of the
Board of Directors, members of the Executive Committee, Directors, officers, employees, trade agents and
representatives of METLEN or any Associated Group, and b) any shareholder who owns, directly or
indirectly (e.g. through subsidiaries), 5% or more of the voting rights of METLEN or any Associated Group.
METLEN's Compliance Division is responsible for evaluating this Policy in order to determine/confirm
whether a Conflict of Interest actually exists.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
a) METLEN's Policy and Procedures for Related Party Transactions
b) Internationally accepted best practices
Inclusion of
Stakeholder interests
[MDR-P_65_e]
All persons subject to the policy must also promptly report to METLEN's Compliance Division any Conflict
of Interest or breach of this Policy (by any other person responsible), of which they become aware at any
time.
Availability
[MDR-P_65_f]
Intranet
POLICY OF COMPLIANCE WITH THE LAW OF FREE COMPETITION
Year of preparation
2020
Key Content
[MDR-P_65_a]
A key regulatory principle of the Policy is the transposition of the relevant legislation, which prohibits all
agreements and concerted practices between companies and all decisions of associations of companies
which have as their object or effect the prevention, restriction or distortion of free competition.
Targeting
[MDR-P_65_b]
METLEN's business culture and history is characterised by zero tolerance to violations of free competition
and provides, at all times, through its procedures and its Central Services, the appropriate support, training
and information to all employees in order to avoid any competitive violations. On the other hand, it takes
all necessary measures against employees and associates who have violated the law.
Governance
[MDR-P_65_c]
METLEN's Compliance Division is responsible for evaluating this Policy
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
Law 3959/2011 on the "Protection of Free Competition", and Articles 101 and 102 of the Treaty on the
Functioning of the European Union.
Inclusion of Stakeholder
interests
[MDR-P_65_e]
The scope of this Policy includes all BoD members, top executives, heads of divisions as well as other
employees and representatives of the Group and the companies and associations in which it participates.
Availability
[MDR-P_65_f]
Intranet
ANTI-FRAUD, ANTI-CORRUPTION AND ANTI-BRIBERY POLICY
Year of update
2023
Key Content
[MDR-P_65_a]
METLEN, which operates both independently and through its subsidiaries internationally, and is involved in
high-risk regions [with high Corruption Perception Index (CPI) according to Transparency International's
2023 index] and areas of activity (including industries such as mining, construction, manufacturing, energy,
utilities, and wholesale trade, which are identified as high fraud-risk sectors according to the "Reports to
the Nations" by the Association of Certified Fraud Examiners), recognizes the risk of exposure to such
phenomena in both national and international environments. To this end, it establishes this policy on the
prevention of fraud, corruption, and bribery. These phenomena present a significant barrier to Sustainable
Development and may occur across the entire scope of the Group's operations, with negative consequences
for local communities, the broader business environment, and society as a whole.
[G1:G1-1_10_h]
Targeting
[MDR-P_65_b]
The purpose of this policy is to comply with the applicable legal and regulatory framework for the fight
against fraud, corruption and bribery, in each country where the Group operates; the Group adopts a zero-
tolerance approach and does not tolerate fraud, corruption and bribery in any direct or indirect manner.
Governance
[MDR-P_65_c]
a) The Policy and any revised version thereof are approved by METLEN's Board of Directors.
b) The Compliance Division is responsible for developing the Policy, reviewing it and monitoring its
implementation. It is also responsible for monitoring, receiving and managing any reports of violations of
5. Annual Board of Directors Management Report
294
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
the terms of this Policy in accordance with the "Policy on the Internal Reporting Channel within the meaning
of Law 4990/2022 (Whistleblowing)”.
c) The Compliance Division conducts periodic Second Line Controls (according to the terminology of
the Second Line from the Institute of Internal Auditors) to ensure that the policy and related procedures
are being adhered to. [G1:G1-1_10_a] [G1:G1-1_10_e]
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
[G1:G1-1_10_b]
a) United Nations (United Nations Convention against Corruption & United Nations Global
Compact),
b) Transparency International,
c) Association of Certified Fraud Examiners (ACFE),
d) International Organization for Standardization (ISO 37001 - Anti-Bribery),
e) METLEN's Code of Business Conduct
f) ASI Performance Standard
Inclusion of Stakeholder
interests
[MDR-P_65_e]
This policy shall apply to all employees and associates of the Group and its controlled subsidiaries,
regardless of position, including members of their boards of directors. It also applies to any other third-
party (consultants, agents, agents, brokers, distributors and other intermediaries) acting on METLEN's
behalf.
Availability
[MDR-P_65_f]
Intranet [G1: G1-3_20]
FINANCIAL SANCTIONS POLICY
Year of update
2023
Key Content
[MDR-P_65_a]
It sets METLEN's regulatory compliance framework in order to be able to manage the relevant risks arising
from financial penalties, through preventive and proactive controls, and to ensure that all employees and
stakeholders understand their obligations in order to ensure compliance and support the corporate
strategy.
Targeting
[MDR-P_65_b]
Prevent METLEN from dealing with restricted or named persons or entities, engaging in restricted
business, operating in sanctioned areas, maintaining business activities or appropriately phasing
out business activities in the event of new sanctions being imposed. Also, the establishment of
clear and transparent rules in order to increase employees' knowledge on the subject, so that
they can identify warning signs and be informed on how to search for information and where to
seek advice in case of business transactions that may involve the risk of financial penalties.
Governance
[MDR-P_65_c]
a) The Policy and any revised version thereof are approved by METLEN's Board of
Directors.
b) The Compliance Division is responsible for developing and revising the Policy.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
a) United Nations Security Council Resolutions on the United Nations consolidated
sanctions list;
b) Restrictive measures/European Union legislation & consolidated list of economic
sanctions managed by the European Commission;
c) Office of Foreign Assets Control (OFAC) programmes from the U.S. Department of the
Treasury that include territorial, sectoral, and secondary sanctions;
d) Her Majesty's Treasury - Office of Financial Sanctions Implementation HM Treasury
(OFSI) Consolidated Target List;
e) Australian Department of Foreign Affairs and Trade (DFAT);
f) Canadian autonomous sanctions;
g) Restrictions imposed by the U.S. Bureau of Industry and Security (BIS) along with the list
of Parties of Concern;
h) Restrictions imposed by the World Bank on the admission of ineligible firms and
individuals and the list of sanctions (or list of excluded entities) by development banks
worldwide.
Inclusion of Stakeholder
interests
[MDR-P_65_e]
This policy applies to all entities owned or controlled by METLEN, its employees, employees with
any contractual relationship, Executives and Directors, as well as consultants, agents, agents,
brokers, suppliers and other intermediaries (“Contractors”) when acting on METLEN's behalf. All
parties must comply fully with the requirements of this policy.
The Compliance Division is responsible for developing and revising the Policy, as well as for
monitoring its implementation, and for monitoring, receiving and managing any reports of
violations of its terms.
5. Annual Board of Directors Management Report
295
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The General Divisions of Central Operations and Business sectors, as well as the Management of
the associated Companies with the assistance of the respective Procurement Departments,
Purchasing Departments, Sales Departments in Greece and abroad, are responsible for the
implementation of the Policy in the value chain, as well as for the submission of proposals and
improvement actions.
Availability
[MDR-P_65_f]
Intranet
INTERNAL REPORTING CHANNEL POLICY
Year of update
2023
Key Content
[MDR-P_65_a]
The establishment of an Internal Reporting Channel of METLEN, within the meaning of Greek Law N.
4990/2022, as well as the description of the process of internal submission, receipt and monitoring of
reports, the responsibilities of the Head of Monitoring and Receiving Reports and the content of the
protection of the reporting persons.
Targeting
[MDR-P_65_b]
Provide guidance to any person who meets the criteria of the Reporting Person, within the meaning of
Article 2 hereof, and intends to report information or facts internally regarding acts or omissions that are
unlawful under the Union law and/or the respective national implementing rules, or that conflict with the
object or purpose of the Union law and/or the respective national implementing rules.
Governance
[MDR-P_65_c]
a) The Policy and any revised version thereof are approved by METLEN's Board of Directors.
b) The Compliance Division is responsible for developing the Policy, reviewing it and monitoring its
implementation.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
[G1:G1-1_10_d]
a) Greek Law N. 4990/2022 ("Protection of persons who report breaches of Union law")
b) Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019
c) ISO 37002, Whistleblowing management systems
d) ISO 37008, Internal investigations in organizations- guidance
Inclusion of Stakeholder
interests
[MDR-P_65_e]
This policy applies to those who possess information about work-related violations and wish to report it.
This includes:
a) Employees, consultants, associates and professionals with employment or project contracts,
shareholders, members of the Board of Directors, and volunteers.
b) Former employees, prospective employees and any person working under the supervision of
contractors, subcontractors and suppliers of the Group.
c) In the event of public disclosure, policy measures are extended to intermediaries, third parties
(e.g. relatives of the petitioners) and businesses or legal entities associated with the reporting persons.
Availability
[MDR-P_65_f]
Corporate website
178
(including description of Available Reference Channels) and intranet
CODE OF BUSINESS CONDUCT
Year of update
2019
Key Content
[MDR-P_65_a]
The Code of Business Conduct reflects the general principles that define responsible business conduct and
the ethical rules that all METLEN employees and partners are expected to follow, as well as the
commitments of the Group's Management to its people. It ensures that all the Group's activities are
conducted with integrity, thus protecting its reputation, which is its most valuable intangible asset and, like
any asset, should be defended; it further ensures that any conditions for its further development are
created.
Targeting
[MDR-P_65_b]
The Code contributes materially to the achievement of METLEN's main strategic objective, which is its
continuous and responsible development. It includes rules of acceptable conduct of employees vis-à-vis
third parties, natural or legal, private or public, domestic or foreign, and goes beyond legal compliance in
all areas of the Group's business, demonstrating its commitment to operating with integrity in all
circumstances. The guiding principles for the creation of the Code is the Group's business activity, the
applicable legislative framework governing it, the high-level services and products it provides, as well as the
standards of professional and business conduct it has adopted as a prerequisite to carry out this business
activity.
Governance
[MDR-P_65_c]
a) The Code and any revised version thereof are approved by METLEN's Board of Directors.
178
https://www.METLENgroup.com/who-we-are/governance/compliance/#section10
5. Annual Board of Directors Management Report
296
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
b) The Compliance Division is responsible for developing the Code, reviewing it and monitoring its
implementation.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
Internationally accepted best practices
Inclusion of Stakeholder
interests
[MDR-P_65_e]
a) The Code is addressed to, concerns and binds both existing employees in all the Group's Business
sectors, as well as new recruits, who upon recruitment are automatically subject to the Code.
b) It is addressed to, concerns and binds the associates and consultants who represent or operate
on behalf of the Group, either through outsourcing services or through any other business activity.
c) Companies in which METLEN participates but are not under METLEN's control are encouraged to
apply similar principles and standards of business ethics if they have not already done so.
Availability
[MDR-P_65_f]
Corporate website
179
and intranet
RESPONSIBLE SUPPLY CHAIN POLICY
Year of update
2023
Key Content
[MDR-P_65_a]
For METLEN, creating a responsible supply chain is a key pillar of its overall Sustainable Development
Strategy and a pursuit of continuous improvement, while at the same time it is directly linked to its business
operations, determining how the Group chooses to cooperate and procure. For the purposes of the Policy,
any natural or legal person that provides, sells or leases materials, products or services directly to METLEN,
including all Central Functions (CFs), Business sectors and its subsidiaries in Greece and abroad, is
considered a supplier/partner of METLEN.
Targeting
[MDR-P_65_b]
a) The Policy affirms METLEN's commitment to fostering responsible entrepreneurship and thereby
enhancing the sustainability of its supply chain.
b) It promotes responsible business practices in the activity of its suppliers and partners with the
ultimate goal of developing collaborations and partnerships to better understand the impacts on
Sustainable Development and to mutually harmonize relevant objectives and expectations.
c) It contributes to the achievement of METLEN's overall Sustainable Development Strategy, by
integrating it into procedures and policies governing its broader procurement and supply activities.
Specifically, the Policy assists in carrying out the actions followed to ensure that all METLEN's suppliers,
pursuant to the principles of proportionality and materiality, and primarily those with whom METLEN has
or wishes to have an established business relationship, are approved and operate in accordance with the
basic principles of integrity, transparency, competence, professionalism as well as the ESG criteria.
Governance
[MDR-P_65_c]
a) The Policy and any revised version thereof are approved by METLEN's Board of Directors.
b) The Corporate Governance and Sustainable Development Compliance General Division is
responsible for developing the Policy, reviewing it and monitoring its implementation.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
Global Sustainable Development Goals (SDGs) and in particular Goal 8 "Decent Work and Economic Growth”
and Goal 12 "Responsible Consumption and Production”.
Inclusion of Stakeholder
interests
[MDR-P_65_e]
METLEN implements a Whistleblowing line at central level for reporting violations in relation to the Policy
and is committed to defending both its suppliers and their employees without fear of retaliation against
those who report actual or suspected violations of this Policy.
Availability
[MDR-P_65_f]
Corporate website
180
and intranet
179
https://www.metlengroup.com/media/hwdhvhaw/kodikas_deontologias_omilou_2019_eng_web.pdf
180
https://www.metlengroup.com/media/ewkhrmwn/policy_cgsd_3_responsible_supply_chain_en.pdf
5. Annual Board of Directors Management Report
297
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
SUPPLIERS AND BUSINESS PARTNERS’ CODE OF CONDUCT
Year of update
2023
Key Content
[MDR-P_65_a]
It is a set of guidelines, defining the basic standards of ethical conduct, values and principles of Corporate
Social Responsibility, which METLEN expects all its Suppliers/Business Partners to adopt and in turn to
promote in their interactions with their employees, suppliers, contractors and customers. METLEN
encourages its existing Suppliers/Partners to comply with this Code and will take into account their progress
in meeting these requirements when evaluating its cooperation with them. At the same time, during the
process of selecting new Suppliers/ Partners, the Group sets their alignment with this Code as a
prerequisite.
Targeting
[MDR-P_65_b]
a) Conducting their business activities in a responsible manner, in compliance with applicable legal
provisions.
b) Defending the rights of their employees in a safe working environment.
c) Compliance of suppliers with environmental legislation and regulations as well as the objective of
reducing the environmental impact of their activities.
d) Implementing the management and monitoring of corporate governance practices in order to
ensure compliance with contracts and applicable legislation.
Governance
[MDR-P_65_c]
The Compliance Division is responsible for developing the Code, reviewing it and monitoring its
implementation, while it also receives the relevant reports.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
The UN Global Compact
Inclusion of Stakeholder
interests
[MDR-P_65_e]
METLEN's current and potential Suppliers/Business Partners should ensure that they comply with the
provisions of this Code. In the event that they have undertaken or intend to undertake a work or service on
behalf of METLEN, which is or will be mainly performed by the subcontractors and suppliers with whom
they cooperate, they must forward this Code to them in order to ensure the conditions of compliance.
Availability
[MDR-P_65_f]
Corporate website
181
and intranet
INFORMATION SECURITY AND PRIVACY POLICY
Year of update
2024
Key Content
[MDR-P_65_a]
METLEN continuously collects, stores, processes and handles information in the context of the performance
of its business functions, which concern the Energy and Metals Sectors. The protection of information and
its processing systems is of strategic importance in order to achieve its short- and long-term goals and
protect its expertise in the context of its responsible business operation.
Targeting
[MDR-P_65_b]
For the uninterrupted protection of information, the Group has developed an Information Security and
Privacy Management System consisting of policies, procedures and instructions aimed at:
a) ensuring the confidentiality, integrity and availability of all information handled by it, including
Personal Data;
b) adhering to all applicable legal and regulatory requirements in the countries in which it operates;
c) complying with the requirements arising from contracts with customers, partners and suppliers,
in which the responsibilities of each party are clearly outlined;
d) Protecting the Group’s interests;
e) maintaining and improving the credibility of its information resources;
f) achieving business goals set by the Group.
Governance
[MDR-P_65_c]
The IT and Digital Strategy Central Function is responsible for developing the Policy, reviewing it and
monitoring its implementation.
Standards or internationally
recognized third-party
initiatives
[MDR-P_65_d]
The Management and employees of the Group are committed to the implementation of the Policies,
Procedures and Instructions of the Information Security and Privacy Management System, in accordance
with the requirements of ISO 27001:2013
182
and ISO 27701:2019
183
with which they fully comply and the
applicable Legal and Regulatory requirements, as well as to the achievement of its objectives.
181
https://www.metlengroup.com/media/vj0j4005/mytilineos_suppliers_code_of_conduct_2023_en.pdf
182
https://www.METLENgroup.com/media/bjupnvdw/certificates_METLEN-energy-metals-27001-revision.pdf
183
https://www.METLENgroup.com/media/drzokhto/METLEN-27701-en.pdf
5. Annual Board of Directors Management Report
298
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Inclusion of Stakeholder
interests
[MDR-P_65_e]
METLEN's current and potential Suppliers/Business Partners should ensure that they comply with the
provisions of this Code. In the event that they have undertaken or intend to undertake a work or service on
behalf of METLEN, which is or will be mainly performed by the subcontractors and suppliers with whom
they cooperate, they must forward this Code to them in order to ensure the conditions of compliance.
Availability
[MDR-P_65_f]
Corporate website
184
and intranet
Also, METLEN's Privacy Policy ensures its compliance with the European General Data Protection Regulation (GDPR) and
applicable national legislation, protecting the personal data of individuals. Data collection and processing takes place solely for
specific purposes, such as providing services, complying with legal obligations and improving users' online experience. For the
data processed and including identification data, contact information and browsing data, the Group applies a series of security
measures to prevent unauthorized access or loss of data. The legal bases for processing include the conclusion and performance
of contracts, the fulfillment of legal obligations and the consent of data subjects, where required. In the context of transactional
relationships, data processing is carried out to manage contracts, comply with regulatory requirements and protect the Group's
legitimate interests. Also, the Group may transmit data to third-party service providers, ensuring that the relevant legislative
requirements are complied with. In this context, the Group does not process data of minors under the age of 18, unless consent
is provided by the legal guardians. Finally, it is noted that the use of cookies on the Group's websites aims to improve the browsing
experience, with the ability of users to manage their settings.
G1-2 — Management of relationships with suppliers
METLEN intends to build strong and long-term relationships of trust and mutual benefit with its suppliers and partners. A Group's
priority is to support its local communities, by entering partnerships with local suppliers and contractors, while at the same time,
it has launched special initiatives aimed at expanding responsible practices in its supply chain as part of its sustainable
development strategy. METLEN maintains long-term partnerships with many suppliers. Depending on the nature and type of
required supply, priority is given to local suppliers based on their financial, and timely reliability, the cost of the products or
services they provide, as well as their ability to ensure the required quality and meet the procurement needs specified by the
Group's business sectors.
Basic Description of METLEN’s Supply Chain
Core business
activities that
require services
or products from
the supply chain
Production & Maintenance of the alumina chemical industry and primary cast aluminium metallurgy
Procedures for the purchase of raw materials or other materials
Bauxite mining and sales
Production of secondary cast aluminium using recycled (scrap) aluminium
Construction for the purchase of equipment for the execution of EPC and RES projects
Transport for product delivery to various countries.
Operation and maintenance of Energy Centers (Thermal Power Stations)
Development, construction, and maintenance of Renewable Energy Sources (Wind, Photovoltaic,
Hydroelectric projects)
Construction of Infrastructure, Environmental, Building, and other types of projects
Retail activity
Studies – Investments
Administrative, Financial, Legal and Other Services
184
https://www.metlengroup.com/media/3khj1ctd/myt_isms_gisp_group-information-security-and-privacy-policy_0202024_eng.pdf
5. Annual Board of Directors Management Report
299
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Main categories
of suppliers
Producers of raw materials
Energy and Natural Gas Suppliers
Subcontractors
Manufacturers
Distributors/Freight forwarders
Suppliers of Spare Parts/Materials
Wholesalers
Suppliers of consulting services & studies
Table: 01/G1
Key metrics of the supply chain
At the end of 2024, METLEN had nearly 15,000 active suppliers and partners across the full range and areas of its operations in
both Greece and abroad. Also compared to 2023, there were no significant changes in the core structure of the Group's supply
chain, as shown in the above Table 01/G1. However, a significant change at the Aluminum of Greece plant was the switch in
electricity provider. Specifically, the electricity supply no longer comes from the Public Power Corporation (DEH) or other
suppliers, but from METLEN's Energy Division, through self-supply. Furthermore, in 2024, the Group collaborated for the first
time with nearly 1,900 suppliers across its entire range of activities.
METLEN recognizes that due diligence regarding the responsible management of the supply chain is gradually being integrated
into the regulatory framework at both the European and national levels. In response to this progressively strengthening
regulatory environment, the Group's approach incorporates environmental, social, and governance-related aspects. The Group
is already monitoring the relevant risks that may arise, aiming to avoid any adverse impacts from its supply chain, particularly
from its key suppliers. [G1:G1-2_15_b]
In addition, it encourages its key suppliers not only to comply with legal requirements but also to go beyond them. Accordingly,
the Group understands the sustainability performance of its key suppliers as an important aspect of creating added value and
positive impact. A main priority of the Group is to enhance the level of maturity of its key and critical suppliers, in order to achieve
an overall improved management of sustainability issues that arise as important in the context of cooperation. Having defined
the criteria that characterize its suppliers as key or critical in cooperation with the individual divisions and the purchasing and
purchasing departments of its Business sectors, in 2023 METLEN proceeded to the creation of a registry of key/critical suppliers
in Greece and abroad.
The main criteria that characterize the Group's suppliers include the following:
a) The proven ability to ensure the smooth and uninterrupted operation of all Group facilities.
b) The large volume of purchases and critical components.
c) Suppliers that are difficult to replace.
d) Repetitive/continuous cooperation.
Framework for Cooperation and Integrity of the Supply Chain
Through the development of its Responsible Supply Chain Policy in 2023 (see [G1:G1-1]), as well as through the Suppliers’ and
Business Partners’ Code of Conduct (see [G1:G1-1]), METLEN expects its suppliers and partners (including its direct subcontractors)
to share its commitment to ethical, safe and responsible business practices in the conduct of their business, with particular
emphasis, inter alia, on the promotion of responsible entrepreneurship and ESG criteria within their internal environment, as
well as in their own supply chain.
METLEN's Suppliers’ & Business Partners’ Code of Conduct sets out rules to tackle Corruption and Bribery in the supply chain.
METLEN conducts supplier integrity assessments prior to the start of the partnership and provides for audit rights in the
contractual clauses with them. Audits aim to ensure the Code's implementation and provide recommendations for corrective
action where required. Also, in the process of evaluating its suppliers according to specific ESG criteria, it includes a specific
question about whether they require their own suppliers to operate responsibly and in accordance with applicable laws,
regulations and international standards on issues related, inter alia, to the fight against corruption. [G1:G1-2_15_b] [G1:G1-2_AR_2]
[G1:G1-2_AR_3]
5. Annual Board of Directors Management Report
300
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Group ensures that all transactions performed on its behalf, as well as on behalf of its shareholders, employees, and key
business partners and suppliers, are governed by high integrity. Through a set of procedures on the selection of suppliers and
other business partners, mainly applicable to the Purchasing-Procurement and Project Management Departments, the conditions
under which every single transaction takes place are audited annually, in order to identify and eliminate those that may lead to
corruption or fraud. METLEN implements prevention and detection systems and controls to ensure that suppliers adhere to its
standards in order to avoid questionable payments and to ensure their appropriate and transparent recognition in the Group's
accounting books. [G1:G1-2_14] [G1:G1-2_AR_2] [G1:G1-2_AR_3]
METLEN also implements a Whistleblowing line at central level for reporting violations in relation to the Policy and is committed
to defending both its suppliers and their employees without fear of retaliation against those who report actual or suspected
violations of this Policy. METLEN takes violations of its Policies seriously and, depending on the severity of the violation, the
consequences can range from a warning to termination of employment, in case of an employee, or termination of the supply
relationship, in case of a supplier.
Also, within the Code, care is taken and suppliers are required to be able to demonstrate that they comply with applicable national
legislation or industry standards, operating on a range of issues including the following: [G1:G1-2_15_a] [G1:G1-2_AR_2] [G1:G1-2_AR_3]
a) Payment of salaries and benefits to all their employees, equal to or exceeding the thresholds provided by law, as well as the
provision of all benefits specified by law (in leave periods, holiday time, etc.).
b) Prevention of discrimination against their employees on the basis of race, colour, age, gender, sexual orientation,
nationality, disability, religion, political affiliation, union membership, national origin or marital status and which can directly
or indirectly affect corporate processes.
c) Prohibition of child labour, forced labour and guarantee of freedom of association.
d) Fighting Corruption and Bribery and avoiding any action of unfair competition.
e) Protection of intellectual property, privacy and avoidance of disclosure of sensitive information.
In accordance with the Suppliers’ and Business Partners' Code of Conduct, METLEN Suppliers & Partners should take measures
to avoid the use of materials that are considered to be the result of illegal mining or are raw materials from Conflict Affected and
High-Risk Areas (CAHRAs). Upon request, the Group's suppliers should provide information related to the country of origin of the
materials supplied. In particular, they must comply with all applicable trade control laws and regulations. Such audits are
particularly critical in cases of contracting parties who are under restriction. Restrictions imposed on natural persons, legal
persons, countries, sectors of the economy, or on specific products, may be due to reasons of public security, human rights
violations, or participation in criminal or terrorist organizations. Violation of the above restrictions may result in serious penalties
imposed on the business partner under administrative or criminal law. [G1:G1-2_15_a]
Development and implementation of actions
METLEN also implements a series of voluntary actions aimed at positively influencing and enhancing the level of maturity of its
suppliers in understanding the value of ongoing investment in sustainable and responsible business practices. These actions
include:
A. Adoption of internationally accepted Responsible Supply Chain Management initiatives
METLEN has an active role in domestic and international initiatives and organizations aimed at addressing the challenges of
Sustainable Development in its supply chain. In particular, the Metals Sector (namely Aluminium of Greece and DELPHI-
DISTOMON) was certified in 2022, and with effect from 2023, by the ASI Initiative for all its activities according to the Chain of
Custody Standard. [G1:G1-2_15_a]
Also, METLEN's Chairman and Managing Director, Mr. Evangelos Mytilineos, who was elected in 2022 as President of the Pan-
European Union "Eurometaux" and was re-elected in 2024 for a two-year term, representing the non-ferrous metals industry at
European level, including mining, metallurgy, processing and recycling of basic, valuable and secondary metals, recognizes the
importance of ensuring responsible sourcing of all raw materials & materials, supporting EU actions to guarantee resilient and
ethical supply chains for green primary raw materials in Europe. At the same time, the Special Advisor to the Chair and Chief
5. Annual Board of Directors Management Report
301
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Executive Officer and Chair of the Sustainable Development Committee of METLEN's Board of Directors, Ms Sophie Daskalaki
Mytilineou, was elected in 2024 as Chair of the Board of Directors of the UN Global Compact Network Greece (GCNG). GCNH is
the national organization of the United Nations Global Compact for Greece. Its mission is to promote corporate sustainability and
support its member companies on a national level, providing support to the understanding of the guidelines on the adoption of
the 10 Principles, as well as training programmes for the development of sustainable practices in the supply chain.
B. Training Courses for Responsible Supply Chain Management
In order to effectively understand the context of responsible entrepreneurship, as well as to enhance the level of maturity of its
supply chain in sustainability issues, METLEN has since 2020 been offering annual training seminars to its main suppliers in
Greece. The "Business Responsibility for Sustainable Development" supplier training programme consistently promotes
knowledge in the implementation of standards and procedures for establishing sustainability as a key factor in the business
activities of its key suppliers, as it recognizes the positive link between sustainability, resilience and economic performance. The
program, through a combination of theory and practical application using interactive videos, seeks to familiarize trainees with
essential sustainability issues pertaining to their business activities. These include human rights, working conditions, including
overtime, child and forced labour, freedom of association and equal opportunities, environmental protection and business ethics,
along with the fight against corruption.
The 2024 training program consisted of two cycles targeting a) SMEs that have recently started their journey of integrating
sustainability into their strategy and operations, and b) more mature companies, with a presentation and explanation of the new
regulatory requirements related to sustainable development management arising from the new European Directives. Active
participation in this program came not only from suppliers but also from the Group's Procurement/Purchasing Department staff,
enhancing collaboration and understanding of the new requirements. Through exercises based on real-life examples, interactive
dialogue, and the use of electronic platforms for feedback and decision-making, participants actively engaged, understanding
how inadequate management of these issues could increase business risks, as well as how proactive behavior can serve as a
factor for improvement and strengthening their competitive advantages. Additionally, during the training sessions, participants
had the opportunity to interact with other trainees by sharing real-life case examples and/or best practices, further strengthening
the exchange of views and the learning experience. At the end, they were able to evaluate the training and submit suggestions
for improvement. From the evaluation results, it was found that 72% of the participants rated the overall value of the training as
High, while the remaining 28% rated it as Satisfactory. Furthermore, 95% recognized that the training helped them understand
the importance of integrating ESG criteria into their Group's overall strategic management.
Aiming at effectively implementing the Policy and promoting responsible practices, aligned with its Sustainable Development
strategy, the Group implements regular working meetings with its Procurement/Purchasing Departments from all its Branches
and subsidiaries, to understand the framework of the Policy and the commitments undertaken through it. Specifically, the
workshops cover issues related to key elements of the Policy, its principles and implementation tools, taking into account specific
aspects related to the supply chain of each different Business Unit and subsidiary of METLEN. With the completion of the 5th
training cycle for key suppliers on corporate responsibility, a total of 190 key suppliers (56% of the total number of key suppliers)
have participated and been trained since the program started in 2020. Additionally, six of these suppliers are receiving further
training through their active participation in the initiative "Greek Sustainable Business Pact," which supports SMEs in adopting a
more mature approach to integrating and managing sustainable development. [G1:G1-2_15_a]
C. Inclusion of ESG criteria in the supplier selection process
METLEN, through the evaluation process of its key suppliers, aims to identify critical issues, provide support, and ensure their
continuous improvement. In this context, the annual update of the key suppliers' registry, meeting ESG criteria, continued in
2024, through the application of a special evaluation methodology aligned with the requirements of its Supplier and Business
Partner Code of Conduct and the Principles of Responsible Supply Chain Policy.
The methodology for evaluating key suppliers has been developed by the Sustainable Development Division to align with the key
elements of the Group’s Supplier/Partner Code of Ethics based on environmental, social, and governance (ESG) criteria. The
methodology is applied internally as a result of collaboration between the Procurement/Purchasing Departments of the Business
sectors, the Central Functions, the subsidiaries, and the Sustainable Development Division. The ESG criterion is incorporated as
an additional evaluation pillar in new partnerships and procurements, complementing the existing pillars, such as technical and
financial evaluations.
5. Annual Board of Directors Management Report
302
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The process of evaluating key suppliers is gradually being integrated into all purchasing and procurement departments of all
Business sectors and focuses on substantive issues directly related to the Sustainable Development Goals, including the
assessment of, inter alia, compliance with environmental requirements, the management of health and safety issues, the
protection of human rights, as well as ethics and integrity issues. [G1:G1-2_15_b]
D. Digital Key Suppliers’ Assessment Platform
In 2023, METLEN's Sustainable Development Division developed the specialized "METLEN Responsible Supply Chain platform"
to more effectively manage its ESG supply chain assessment. Through this platform, the Group collects, assesses and audits
information on the ESG performance of its suppliers on an annual basis. The Group, taking into account the responses from its
suppliers and evaluating the submitted documentation, identifies the key sustainability risks within its supply chain. At the same
time, it communicates and collaborates with suppliers who lag in sustainability issues, aiming to help them improve their
performance through specific adjustment plans for managing the relevant ESG issues. METLEN monitors these issues on an
annual basis. The digitalization of the assessment process contributes to resources and time savings and to the efficient
management of suppliers' responses, while at the same time the direct cooperation of the Sustainable Development Division
with the procurement/purchasing departments is achieved, for the monitoring of each supplier's ESG performance.
Once the review and evaluation of the responses and the submitted qualitative and quantitative information (such as energy
consumption, recycling and reuse rates, health and safety incidents, available policies on human rights, existence of a code of
ethics, corruption or bribery incidents, etc.) and supporting documentation from suppliers have been completed by the
responsible staff at METLEN, each participating company/supplier is assigned a final score based on the maturity and
management approach to handling the relevant issues that they recognize as significant, according to their industry, geographic
area of operation, and the framework of collaboration with METLEN.
5. Annual Board of Directors Management Report
303
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METHODOLOGY FOR EVALUATING METLEN'S KEY SUPPLIERS WITH ESG CRITERIA
185
Table/Diagram: 02/G1
Suppliers are classified into the following categories, taking into account their overall assessment score:
Performance
Classification Level
Energy
80,01-100%
Negligible risk
60,01-80%
Low risk
No action required
(White List entry)
40,01-60%
Medium risk
20,01-40%
High risk
Commitment to specific issues or creation of a specific
adaptation action plan is required
0-20%
Serious risk
Direct dialogue with the supplier - The continuation of
cooperation with the Group is under consideration
Table/Diagram: 03/G1
The following are the issues taken into account during the ESG assessment of key/critical suppliers:
185
More information on the assessment method and the benefits of participating in it can be found in the "Responsible Supply Chain Management" section of
METLEN's website.
5. Annual Board of Directors Management Report
304
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
AREAS OF EVALUATION FOR METLEN'S KEY SUPPLIERS WITH ESG CRITERIA
Table/Diagram: 04/G1
E. Results of key suppliers' evaluations through the digital evaluation platform
In 2024, 88 key suppliers of the Group participated in the key supplier evaluation process based on ESG criteria, bringing the total
number of key suppliers evaluated within the 2022-2024 period to 259. The following table presents the key findings of the three-
year evaluation, as well as the target set for 2025.
Evaluation of key suppliers based on
Environmental-Social-Governance (ESG) criteria
Three-year period
2022-2024
Total number of suppliers
337
Total number of evaluated key suppliers
259
% of evaluated key suppliers
77%
Total number of low/insignificant risk suppliers
240
% of low/insignificant risk suppliers
93%
Total number of medium/serious/high-risk suppliers
19
% of medium/serious/high-risk suppliers
7%
Supplier evaluation via the Ecovadis platform
23
Table/Diagram: 05/G1
The data and documentation submitted by suppliers are analyzed to identify any actions required in the event of non-compliance,
aiming to mitigate risks in the Group’s supply chain. Of particular importance is that, in 2024, for the first time, the process of
evaluating potential suppliers who participated in the Group’s procurement tendering processes based on ESG criteria was
initiated. Specifically, out of the 62 potential suppliers invited to participate in a tender process, 44% successfully responded to
the evaluation process, and 100% of them were categorized as having negligible/low risk. In conclusion, from the evaluation of
88 key suppliers in 2024, it is found that 94% of them are recognized as negligible/low risk in terms of their approach to
sustainable development issues they are
Environment
Environmental Management
Response to Climate Change
Water Management
Waste Management
Ecological Impact
Compliance with Environmental
Legislation
Society
Occupational Health and Safety
Human Rights
Labour Issues
Child and Forced Labour
Impact on local communities
Compliance with Social
Legislation
Quality Management
Participation in Sustainable
Development Initiatives
Governance
Code of Business Conduct
Risk Management System
Information Privacy
Supply Chain
Corruption and bribery
5. Annual Board of Directors Management Report
305
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
expected to manage within the scope of their business activities. Specifically:
Key Findings from the Evaluation of METLEN's Key Suppliers
(2022-2024 for a total of 259 key suppliers)
Total (%)
Environment
Have an Environmental Policy
87%
Measure direct and indirect carbon dioxide (CO2 - Scope 1 & 2) emissions
55%
Implement actions or set goals to reduce CO2 emissions (CO2 - Scope 1 & 2)
56%
Do not face harmful impacts related to water management (extraction, use, disposal)
75%
Ensure proper waste management through recycling and reuse
81%
Social
Have a Health & Safety (H&S) Policy at work
91%
Have a mechanism for monitoring and recording workplace accidents, accidents with severe
consequences for employees' lives, accidents resulting in work stoppage of three or more
days, and recorded incidents during their operations
91%
Have a Policy or statement of commitment to respect and protect Human Rights
86%
Have a Certified Quality Management System
88%
Conducted employee training and evaluation in the past year
97%
Operate in compliance with all laws, avoiding involvement in conditions that may lead to
child labor and forced or compulsory labor (including modern slavery)
98%
Governance
Have a Code of Business Ethics
87%
Have a process or system for identifying and managing business risks
83%
Require their suppliers to operate responsibly and in accordance with applicable laws,
regulations, and international standards on labor rights, Health & Safety, working conditions,
environmental protection, and anti-corruption
81 %
Table/Diagram: 06/G1
As part of the ESG supplier assessment, two (2) suppliers were identified as being at High/Serious risk. In 2025, METLEN's
Sustainable Development Department, in collaboration with the procurement/purchasing departments, will initially assess
whether these suppliers continue to be key partners. If they remain key partners, a consultation will be scheduled with them
within 2025 to collect any additional information. The completeness and adequacy of this information will serve as the basis for
creating appropriate adjustment and improvement plans regarding their sustainable development management, within a
mutually agreed implementation timeline.
Areas of study
Assessment results
Freedom of
association and
collective bargaining
The Labor Legal framework includes provisions that safeguard the right to collective bargaining and
unionization, which METLEN fully respects and expects similar respect from its suppliers. During the
evaluation, there were no areas or incidents reported where this right was at risk or violated, leading
to fines or other sanctions for regulatory breaches. Also, through the official Code of Conduct violation
reporting process, no incidents of violation of this specific labour right were reported to the
Regulatory Compliance Department
Child Labour
Through the METLEN Supplier and Partner Code of Conduct, it is explicitly stated that suppliers and
partners must comply with the legal age limits for labour in the countries in which they operate. If
no specific legal limit is set, the minimum age should be considered to be at least 15 years. Additionally,
individuals between the ages of 15 and 18 should not be employed in hazardous work or work that may
endanger their mental and physical safety and health. As a result of the 2024 evaluation, no incidents
of child labour or conditions that may lead to the employment of young workers in hazardous work
were recorded.
5. Annual Board of Directors Management Report
306
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Forced Labour
METLEN, following the Greek Constitution (Art. 22, par. 4), which guarantees the freedom of
employment, incorporates the related provisions in its Supplier/Partner Code of Conduct, prohibiting
any form of forced or compulsory labor in the workplace. As a result, the risk of conditions that could
lead to forced labor incidents is significantly reduced in all of its collaborations. As a result of the 2024
evaluation, no incidents of forced or compulsory labor, nor complaints or incidents through the
official Code of Conduct violation reporting process to the Regulatory Compliance Department, were
recorded.
Environmental
assessment of
suppliers
METLEN, in addition to complying with environmental laws and regulations, is committed to reducing
environmental impacts and promoting the sustainability of natural resources dependent on its
operations. In this direction, it expects its Suppliers/Partners to play a significant role in achieving these
goals by implementing environmentally responsible practices and providing alternative solutions and
proposals. As a result of the evaluation, 3.5% of the evaluated suppliers have been fined or are facing
other sanctions for regulatory violations or non-compliance with environmental laws over the past
three years. There have been no complaints or incidents through the official Code of Conduct violation
reporting process to the Regulatory Compliance Department.
Social evaluation of
suppliers
At METLEN, health and safety are of the highest priority in all aspects of its business operations and
subsidiaries, investing continuously towards achieving the sole acceptable goal "NO ACCIDENTS AND
NO OCCUPATIONAL DISEASES IN THE WORKPLACE", which is one of the major challenges in the
industry. In this context, it expects its suppliers/partners to share this commitment to creating a work
environment that is free of health and safety risks. However, according to the results of the evaluation,
6.1% of the evaluated suppliers reported receiving fines or other sanctions for non-compliance with
legislation concerning health & safety issues or other labour-related issues (excluding those mentioned
above, such as freedom of association, child labour, forced labour), as well as issues related to product
quality in the last three years. No related complaints or incidents were recorded through the official
Code of Conduct violation reporting process to the Regulatory Compliance Department.
Table/Diagram: 07/G1
F. Total Expenditure and Allocation of Expenditures to Suppliers by Business Sector
In 2024, METLEN's total expenditures to its suppliers in Greece for the production of products, the provision of services, and the
development of projects exceeded €3.22 billion, meaning that 52% of total expenditures were allocated to domestic and local
suppliers, contributing both to the preservation of jobs and the creation of income within the country.
Below is the breakdown of expenses made in 2024 to suppliers by Business Activity Sector of the Group. The largest volume of
expenses is related to the Energy Sector, followed by the Metals Sector, with the two sectors together accounting for 95% of
total expenditures. It is noteworthy that the Energy Sector now hosts the largest number of suppliers and exhibits the highest
capital expenditures for 2024, while the Group collaborated for the first time with 1,805 new suppliers across all areas of its
operations.
Table/Diagram: 08/G1
The total expenditures of key suppliers amount to €699 million, of which 76% pertains to suppliers who have been evaluated on
sustainability issues, with 75% being categorized as negligible or low risk. In 2024, more than 2,600 tenders were conducted with
186
The organizational structure of METLEN Energy & Metals now has two business sectors: the Energy Sector and the Metals Sector, and is complemented by
the Infrastructure sector, which includes METKA S.A. from the spin-off, its subsidiaries, as well as the Concessions from the Company M Concessions.
Breakdown of expenditures by Business Sector (%)
Central Functions
Metals Sector
Energy Sector
Infrastructure & Concessions
186
1%
19%
76%
3%
5. Annual Board of Directors Management Report
307
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
a total expenditure amount of €387 million, of which 5% were carried out taking into account the participation and performance
of suppliers in the evaluation process concerning environmental, social, and governance (ESG) criteria.
Below are the details regarding the number of suppliers, their geographical distribution, and the expenditures made to them.
Supply Chain Data
2024
2023
2022
Total number of suppliers
16,636
14,133
11,504
Geographical distribution
Greece:70%
Abroad: 30%
Greece:63.3%
Abroad: 36.7%
Greece: 68.6%
Abroad: 31.4%
Total expenditure
€
6,211,995,701
€
5,161,902,847
€
5,888,164,613
Geographical distribution
Greece: 51.9%
Abroad: 48.1%
Greece: 40.7%
Abroad: 59.3%
Greece: 28.4%
Abroad: 71.6%
Table/Diagram: 09/G1
G. Responsible Supplier Management Goals
The key objectives of METLEN regarding the management responsible of its supply chain during 2025 are:
a) To enhance the maturity level through the implementation of educational programs and the integration of Sustainable
Development within its supply chain;
b) To continue the implementation of ESG evaluation of key suppliers and to extend the evaluation to new as well as potential
suppliers participating in the Group's tendering processes;
c) To include ESG criteria in the tendering processes for selecting partners/suppliers, considering their performance in the ESG
evaluation process;
d) To conduct on-site audits at the facilities of a sample of evaluated suppliers from the Energy & Metals sectors and the Group’s
subsidiaries, to be selected by the purchasing/procurement departments of the Sectors/subsidiaries, based on the results of the
ESG evaluation.
G1-3 – Prevention and detection of corruption and bribery
Regulatory Compliance and Business Ethics Framework
A fundamental and non-negotiable principle for METLEN is to make every possible effort to ensure that its business activities are
carried out in full harmony, compliance, and adherence to the prevailing legislation and operating principles governing it in each
region or country where it operates. Regulatory compliance (environmental, social, product) is a key element of METLEN's
business activity and is of equal importance to the issues it manages as part of its continuous and responsible development. This
stance is primarily based on the principle of adhering to legal requirements, as well as the agreements and commitments
voluntarily undertaken by the Group through its Business Divisions.
Addressing corruption and bribery, as well as business ethics, is a central priority for METLEN, as it ensures legal compliance,
which is a non-negotiable principle for the Group in every region or country where it operates. At the same time, it contributes
to the identification, recording, better assessment, and management of risks. METLEN's Senior Management demonstrates
commitment and leadership in preventing and addressing bribery, corruption, and fraud through a robust framework of policy
systems and administrative responsibility, ensuring that all executives in charge of management actively support these values
and contribute to the detection of such incidents in their areas of responsibility.
The Legal and Regulatory Affairs Department, which includes METLEN's Regulatory Compliance Division, is responsible for
creating and implementing additional mechanisms to safeguard the Group from corruption and bribery conditions at both the
preventive and auditing levels. Specifically, the Director of Regulatory Compliance reports to the General Director of Legal,
Regulatory & Compliance Affairs and the Audit Committee of the Board of Directors, which approves and monitors the work plan
of the Regulatory Compliance Division. In the regular update to the Audit Committee, reports are provided on the implementation
of the Management System through the disclosure of any complaints or incidents of serious or recurring corruption and fraud.
5. Annual Board of Directors Management Report
308
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Approach to Regulatory Compliance and Business Ethics
Tackling corruption and bribery is a core element of METLEN's Code of Business Conduct as well as the Suppliers' & Business
Partners' Code of Conduct. For the Group, the point of reference in tackling corruption and bribery is the principle of integrity,
which is linked to the Group’s long-standing commitment to zero tolerance to these issues, and is implemented by third-party
scrutiny before concluding an agreement or making any payments and avoiding all transactions and contacts with any third party
which may be guilty or suspect of encouraging conditions giving rise to corruption, extortion or bribery.
METLEN arranges for the analysis of prevailing conditions and potential risks or threats that may encourage the occurrence of
incidents of corruption or bribery in the corporate environment, through a process of third-party scrutiny and due diligence. This
specific process is implemented through an integrated system that covers corporate activities that involve risks for the occurrence
of such incidents, such as: third party audits in relation to restriction lists regarding terrorism financing and human rights abuse,
as well as negative publicity findings in relation to their integrity, mediation and advisory services. The practice aims to establish
risk identification and prevention procedures, where these are not in place. The Compliance Division has developed an in-house
application for third party scrutiny, which also helps to decide whether to enter into a business relationship with them or not.
The application includes the ranking of third parties based on the Group's exposure to regulatory risk, the in-depth audit of third
parties according to their risk category, and the interactions of the Commercial departments, Compliance and Management
accompanied with the necessary documentation and the maintenance of all the supporting documents and responses of the
third party. [G1:G1-3_18_a]
METLEN takes a number of measures to implement this commitment: [G1: G1-3_AR_5] [G1:G1-3_AR_6]
a) It conducts an annual Enterprise Risk Management study related to potential corruption and bribery risks in its various
business activities and prescribes measures to minimize such risks.
b) It operates reporting channels in accordance with Law 4990/2022 and European Legislation 1937/2019 through a
platform, email, telephone or letter. A third party manages the platform to fully ensure anonymity of reporting persons.
In addition, it has identified to the competent authority the person in charge of receiving and monitoring reports and
has set up a reporting investigation team and channels to forward investigation results to the competent corporate
bodies. The channels may be used by any of our and our suppliers' employees to report violations in connection with
the Group's data protection, anti-bribery and anti-corruption, human rights or code of conduct policies. On the Group’s
website (Internal Reporting Channel Policy
187
) its responsibilities for the receipt of complaints are specified in detail,
including the appointment of the HCAA (Responsible for the Receipt and Monitoring of Reports) according to Law
4990/2022 & the assignment of investigative powers. In addition, the Group applies procedures that comply with the
international standards ISO 37002 (Whistle Blowing)
188
& ISO 37008 (Internal Investigations)
189
and received within 2024
certificates of compliance from following an audit by a competent external accredited Accreditation Body. [G1:G1-3_18_a]
[G1:G1-3_20]
c) Internal investigation is carried out by specially trained personnel of the Compliance Division. In the event that a report
is received in which complaints are raised against a member of the management chain and in particular against the
Report Receiving & Monitoring Officer, the management, by law, can merely file the report in the Group's complaints
register and forward it for investigation to the competent national external reporting channel, the National Transparency
Authority. [G1:G1-3_18_b]
d) The Compliance Director informs the Audit Committee of the Board of Directors on a semi-annual basis about the
submitted complaints and the related investigation results. [G1:G1-3_18_c] [G1:G1-3_18_c]
e) The business culture and history of METLEN is characterized by zero tolerance towards violations of free competition.
Through its processes and the competent Central Services, the Group continuously provides appropriate support,
training, and information to all employees to prevent any competitive violations. Through the Compliance Policy with
Antitrust Law, it is ensured that the Group takes all necessary measures against employees and partners who have
violated the legislation. METLEN prioritizes the timely identification of any risks from potential anticompetitive incidents,
ensuring that any indirect or direct involvement of a partner in such incidents is excluded, in order to eliminate the risk
of violating antitrust laws (Anti-trust) in all aspects of the Group's activities, as well as in the businesses and associations
in which it participates, directly or indirectly. In 2024, as in previous years, there were no incidents of legal action or
financial penalties for behaviours contrary to competition, antitrust or monopolistic practices, corruption, bribery, cartel
activities, or price-fixing.
187
https://www.metlengroup.com/who-we-are/governance/compliance/
188
https://www.METLENgroup.com/media/sz5jynfm/METLEN-energy-37002-en.pdf
189
https://www.METLENgroup.com/media/s1ldveya/METLEN-energy-37008-en.pdf
5. Annual Board of Directors Management Report
309
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
f) The Compliance Department of METLEN collected the Statements of executives and employees in key Administrative
positions for 2024, in accordance with the Policy, regarding potential conflicts of interest of its employees and partners,
as well as statements of transactions with related parties.
g) The Group ensures systematic training of employees according to the category of exposure to regulatory risk on issues
of the Code of Ethics, with an in-depth analysis of corruption and bribery, fair competition, fraud, thorough checks of
business partners, and conflict of interest. In 2024, the Compliance Department implemented two new staff trainings
on anti-corruption and the use of reporting channels. [G1:G1-3_18_a]
In order to prevent the aforementioned risks, METLEN: a) complies with the legal and regulatory requirements in the geographical
regions in which it operates, b) ensures that its relations and activities comply with the legislation in force and the applicable
institutional framework, c) is kept informed on its applicable legal obligations, and d) has established procedures for monitoring
developments in the legislation concerning its areas of activity and regularly reviews and assesses its compliance with applicable
laws and regulations.
In addition, monitoring compliance with the approved environmental licenses of the Group's operational units is a process
regularly conducted internally in each Business Unit by qualified personnel as well as annually, by a recognized independent
organization which audits and certifies the Group's environmental management system.
In addition, during the tendering procedure for a project, policies and procedures (management system or due diligence
procedures) are applied to prevent bribery and corruption as well as anti-competitive behaviour.
Regulatory Compliance and Business Ethics Training
The Compliance Division has developed three training programmes for the Group’s staff: training on personal data protection
(GDPR), training on the METLEN Code of Conduct (CoC) and anti-bribery training (facilitation payments). It also develops a series
of trainings related to Regulatory Compliance topics, such as financial sanctions, channels for reporting violations, gifts and
hospitality, use of influence services. These trainings are implemented by remote access due to the geographical dispersion of
the staff and are implemented as asynchronous computer trainings, ensuring that employees have fully attended and understood
the training topics. The trainings combine references to the theoretical background, analyses of case studies from everyday work,
awareness-raising for upcoming risks, and an incident response and escalation methodology, where required. All METLEN
employees, including employees of subsidiaries, have been classified according to the nature of their work and duties (target
group) to be included in the relevant training according to their risk exposure. In addition, material has been developed and
thematic trainings are carried out for specific employees in the following areas: [G1:G1-3_21_a]
a) Compliance initial training for new hires;
b) Fair competition law;
c) Thorough screening of third parties using the in-house integrity screening platform;
d) Financial sanctions and counter-party screening;
e) Whistleblowing platform management and investigation.
Training on the Code of Conduct, which extensively covers topics such as corruption, bribery, and fraud, is mandatory for all
employees, including the Executive Team and the Board of Directors and all levels of risk. Currently, the completion of training is
monitored collectively across the entire workforce. [G1:G1-1_10_c]
Employee Participation in Trainings to Strengthen
the Regulatory Compliance Culture
Total Number of Trainees
(status until 31.12. 2024)
Training on the Group's Code of Conduct
2,864
Anti-bribery Training (Facilitation Payments) / Anti bribery refresher
486
Data Protection (GDPR) Training
2,651
Regulatory Compliance Program Trainings (Whistleblowing)
1,430
Table/Diagram: 10/G1
5. Annual Board of Directors Management Report
310
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The trainings, whose participation data by the end of 2024, are shown in the table above, reinforce the Group's culture of ethics
and compliance while promoting business ethics. At a minimum, all new employees take part in these trainings each year.
In 2024, 57% of employees engaged in high-risk operations attended METLEN's training programs on combating corruption and
bribery, reinforcing our commitment to ethical business practice and compliance. [G1:G1-3_21_b]
MEASUREMENT INDICATORS AND TARGETS
G1-4 — Confirmed incidents of corruption or bribery
In 2024, METLEN implemented all necessary internal procedures to ensure the enforcement of its policy. Through the control
mechanisms applied by the Compliance Department within the Procurement Departments of the Group's business sectors, where
both the selection of partners and all types of transactions were examined, no confirmed incidents of corruption or bribery were
reported. There were no incidents that led to the dismissal or disciplinary action against employees for corruption-related
reasons, nor any confirmed corruption-related incidents that led to the termination or non-renewal of contracts with partners,
or public legal cases related to corruption against the Group or its employees. [G1:G1-4_22] [G1:G1-4_24_a] [G1:G1-4_25_a] [G1:G1-4_25_b]
[G1:G1-4_25_c] [G1:G1-4_25_d]
Quantitative data regarding confirmed incidents of corruption or bribery
Total
Total number of confirmed incidents of corruption or bribery
0
Number of confirmed incidents in which employees of the Group were dismissed or subjected to
disciplinary sanctions for incidents of corruption or bribery
0
Number of confirmed incidents related to contracts with business partners that were terminated or not
renewed due to violations related to corruption or bribery
0
Number of public legal cases involving corruption or bribery against the Group and its employees
0
Cost of fines for violations of laws related to the fight against corruption or bribery
0
Table/Diagram: 11/G1
The Compliance Department distributes the Code of Professional Ethics to all new employees hired in 2024, with a signed
acknowledgment of receipt and compliance. Additionally, in 2024, all new employees underwent training in the Compliance
Program. [G1:G1-3_24_b]
Furthermore, each year, as part of the Enterprise Risk Management (ERM) System, a risk study for Compliance and Personal Data
Protection is conducted. Through this process, the inherent risks in these areas for the Group are identified, risk mitigation is
achieved through applicable safeguards, and the remaining risk is determined, which must be lower than the management's risk
appetite. [G1:G1-3_24_b]
It is also noted that the Metals Division of METLEN, both in 2024 and in previous years, does not have any production activities
in the 20 countries ranked lowest on the Transparency Index according to Transparency International. [G1:G1-3_24_b]
G1-5 — Political influence and lobbying activities
According to the METLEN Code of Ethics (Fri 5,14 - p.18), political contributions to political parties or persons associated with
them are prohibited. As such, there was no political influence activity in 2024. [G1:G1-5_27] METLEN's Code of Conduct is supervised
by the Compliance Division, which reports and informs the Audit Committee of the Board of Directors about its observance.
[G1:G1-5_29_a] The Group is not registered in the EU Transparency Register or any other recognised Transparency Register in a
Member State, as lobbying activities are not included among its business activities. [G1:G1-5_29_c]
G1-6 — Payment practices
According to its Responsible Supply Chain Policy, METLEN recognizes as its suppliers and partners any natural or legal person who
provides, sells or leases materials, products or services directly to the Group, covering all Business Sectors, subsidiaries and
5. Annual Board of Directors Management Report
311
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Central Services, of companies both in Greece and abroad. [G1:G1-5_31] The Group implements systems and controls at preventive
and detection level to ensure that suppliers comply with METLEN standards, to avoid questionable payments and to correctly
and transparently identify them in the Group's accounting books.
In line with its values and established operating framework, METLEN is committed to adhering to key principles governing its
policy, including self-commitment to consistency and timely payments. According to the data kept, the average payment time of
suppliers does not exceed 60 days, while in order to record more fully the results, METLEN will implement within 2025 a new
unified system for recording these periods in relation to the category of supplier and the type of supply, taking into account the
agreed terms, in order to be able to publish detailed information. [G1:G1-5_33_a]
INDEPENDENT ASSURANCE STATEMENT
XIII.
Independent Auditor’s limited assurance report on Metlen Energy & Metals S.A. Sustainability Statement
INDEPENDENT AUDITOR’S LIMITED ASSURANCE REPORT
To the Shareholders of Metlen Energy & Metals S.A.
We have conducted a limited assurance engagement on the consolidated Sustainability statement of Metlen Energy & Metals
S.A. (the “Company” and/or the “Group”), included in the section Sustainability Statement of the consolidated Management
Report of the Board of Directors (the “Sustainability Statement”), for the period from 01.01.2024 to 31.12.2024.
Limited assurance conclusion
Based on the procedures we have performed, as described below in the “Scope of work performed” section of our report, and
the evidence we have obtained, nothing has come to our attention that causes us to believe that:
• the Sustainability Statement is not prepared in all material respects, in accordance with Article 154 of the Law
4548/2018, as amended and in force by Law 5164/2024 which incorporated into Greek law Article 29(a) of EU Directive
2013/34;
• the Sustainability Statement does not comply with the European Sustainability Reporting Standards (“ESRS”), in
accordance with Commission EU Regulation 2023/2772 of 31 July 2023 and EU Directive 2022/2464 of the European
Parliament and of the Council of 14 December 2022;
• the process carried out by the Company to identify and assess material impacts, risks and opportunities (the
"Process"), as set out in note “Description of processes to identify and assess material impacts, risks and opportunities”
under the section “General Disclosures” of the Sustainability Statement, does not comply with “Disclosure Requirement
IRO-1 - Description of the processes to identify and assess material impacts, risks and opportunities” of ESRS 2 “General
Disclosures”;
• the disclosures in the section “European Taxonomy for Sustainable investments” of the Sustainability Statement, do
not comply with Article 8 of EU Regulation 2020/852.
This assurance report does not extend to information for prior periods.
Emphasis of Matter
We draw attention to the note “Alignment to EU Taxonomy Criteria re Climate Change Mitigation” in the sub-section “CCM 4.1.
Electricity generation using solar photovoltaic technology” of the section “European Taxonomy for Sustainable investments” of
the Sustainability Statement, which describe(s) the significant judgments exercised by the Group's Management to evaluate the
alignment of the Group's specific photovoltaic parks located outside the European Union with the technical screening criteria of
the European Taxonomy. Among other things, the relevant note mentions the factors that the Group’s Management
considered in exercising these judgments, such as environmental impact assessments, environmental permits, alignment with
national frameworks and applicable legislation, etc. Our conclusion is not modified in respect of this matter.
Basis for conclusion
We conducted our limited assurance engagement in accordance with International Standard on Assurance Engagements 3000
(Revised), “Assurance engagements other than audits or reviews of historical financial information” (“ISAE 3000”).
The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable
assurance engagement. Consequently, the level of assurance obtained
in a limited assurance engagement is substantially lower than the assurance that would have been
obtained had a reasonable assurance engagement been performed.
Our responsibilities are further described in the “Auditor’s responsibilities” section of our report.
Our independence and quality management
We are independent of the Company throughout this engagement and have complied with the requirements of the
International Code of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants
(“IESBA Code”), the ethical and independence requirements of Law 4449/2017 and EU Regulation 537/2014.
Our audit firm applies International Standard on Quality Management 1 (ISQM1) “Quality Management for Firms that Perform
Audits or Reviews of Financial Statements, or Other Assurance or Related Services Engagements” and consequently maintains a
comprehensive quality management system that includes documented policies and procedures regarding compliance with
ethical requirements, professional standards and applicable legal and regulatory requirements.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion.
Management’s responsibilities for the Sustainability Statement
Metlen’s Management is responsible for designing and implementing an appropriate process to identify the information
reported in the Sustainability Statement in accordance with the ESRS and for disclosing this Process in note “Description of
processes to identify and assess material impacts, risks and opportunities” under the section “General Disclosures” of the
Sustainability Statement.
More specifically, this responsibility includes:
• Understanding the context in which the Group’s activities and business relationships take place and developing an
understanding of its affected stakeholders;
• The identification of the actual and potential impacts (both negative and positive) related to sustainability matters, as
well as risks and opportunities that affect, or could reasonably be expected to affect, the Group’s financial position,
financial performance, cash flows, access to finance or cost of capital over the short-, medium-, or long-term;
• The assessment of the materiality of the identified impacts, risks and opportunities related to sustainability matters by
selecting and applying appropriate thresholds; and
• Making assumptions that are reasonable in the circumstances.
Management of the Group is further responsible for the preparation of the Sustainability Statement, in accordance with the
article or 154 of Law 4548/2018, as amended and in force with Law 5164/2024, by which Article 29(a) of EU Directive 2013/34
was transposed into Greek legislation.
In this context, the Management of the Group is responsible for:
• Compliance of the Sustainability Statement with the ESRS;
• Preparing the disclosures in section “European Taxonomy for Sustainable investments” of the Sustainability
Statement, in compliance with Article 8 of EU Regulation 2020/852;
• Designing and implementing such internal control that management determines is necessary to enable the
preparation of the Sustainability Statement that is free from material misstatement, whether due to fraud or error; and
• The selection and application of appropriate sustainability reporting methods and making assumptions and estimates
that are reasonable in the circumstances.
The Audit Committee of Metlen is responsible for overseeing the Group’s sustainability reporting process.
Inherent limitations in preparing the Sustainability Statement
In reporting forward-looking information in accordance with ESRS, management of the Company is required to prepare the
forward-looking information on the basis of disclosed assumptions about events that may occur in the future and possible
future actions by the Company and the Group. Actual outcomes are likely to be different since anticipated events frequently do
not occur as expected.
As stated in note “Description of processes to identify and assess material impacts, risks and opportunities” under the section
“General Disclosures” and note “Resilience of the strategy and business model” of the section “Climate change” in the
Sustainability Statement, the information incorporated in the relevant disclosures is based, among other things, on climate-
related scenarios, which are subject to inherent uncertainty regarding the likelihood, timing or impact of potential future
physical and transitional climate-related impacts.
Our work covered the matters listed in the “Scope of Work performed” section to obtain limited assurance based on the
procedures included in the Program, as this is defined in this section. Our work does not constitute an audit or review of
historical financial information in accordance with applicable International Standards on Auditing or International Standards on
Review Engagements, and therefore we do not express any other assurance than those listed in the “Scope of Work
performed” section of this report.
Auditor’s responsibilities
This limited assurance report has been drawn up based on the provisions of article 154C of Law 4548/2018 and Article 32Α of
Law 4449/2017.
Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the
Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance
report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or
in aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability
Statement as a whole.
As part of a limited assurance engagement in accordance with ISAE 3000 (Revised), we exercise professional judgement and
maintain professional skepticism throughout the engagement.
Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:
• Performing risk assessment procedures, including an understanding of the relevant internal control, to
identify risks related to whether the Process implemented by the Group to determine the information reported in the
Sustainability Statement does not meet the applicable requirements of the ESRS but not for the purpose of providing a
conclusion on the effectiveness of the Group’s internal control and
• Designing and performing procedures responsive to where material misstatements are likely to arise in the
consolidated Sustainability Statement. The risk of not detecting a material misstatement resulting from fraud is higher
than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or
the override of internal control.
Moreover, we are responsible for:
• Performing risk assessment procedures, including an understanding of the relevant internal control, to
identify those disclosures that are likely to be materially misstated, whether due to fraud or error, but not for
the purpose of providing a conclusion on the effectiveness of the Group’s internal control.
• Designing and performing procedures responsive to where material misstatements are likely to arise in the
consolidated Sustainability Statement. The risk of not detecting a material misstatement resulting from fraud
is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions,
misrepresentations, or the override of internal control.
Scope of work performed
Our work involves performing procedures and obtaining evidence for the purpose of deriving a limited assurance conclusion
and covers exclusively the limited assurance procedures provided for in the limited assurance program issued by the Hellenic
Accounting and Auditing Supervisory Oversight Board according to its decision dated 22.01.2025 (the “Program”), as it was
formed for the purpose of issuing a limited assurance report on the Group’s Sustainability Statement.
Our procedures were designed to obtain a limited level of assurance on which to base our conclusion and do not provide all the
evidence that would be required to provide a reasonable level of assurance.
Athens, 13 March 2025
The Certified Chartered Accountant
Socrates Leptos-Bourgi
SOEL Reg No 41541
PricewaterhouseCoopers SA
65 Kifissias Avenue
Marousi 151 24
SOEL Reg. No 113
5. Annual Board of Directors Management Report
316
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Contents of the Annex to the Sustainability Statement
1. ESRS Index
1.1. Cross-cutting Standards
1.2. Environmental Standards
1.3. Social Standards
1.4. Governance Standards
2. Sustainability due diligence statement
3. Data points derived from other EU legislation
5. Annual Board of Directors Management Report
317
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
1 ESRS Index ESRS2: IRO-2
1.1 Cross-cutting standards
ESRS 2
General Disclosures
Sustainability Statement Section
Data points
BP-1
General basis for preparation of the sustainability
statement
BP-1_5
Disclosures in relation to specific circumstances
BP-2
Datapoints that derive from other EU legislation
BP-2_9 / BP-2_10 / BP-2_11 / BP-2_13 /
BP-2_15 / BP-2_16 / BP-2_17
GOV-1
The role of the administrative, management and
supervisory bodies
GOV-1_21 / GOV-1_22 / GOV-1_23 /
GOV-1_20_b
GOV-2
Information provided to and sustainability matters
addressed by the undertaking’s administrative,
management and supervisory bodies
GOV-2_26 / GOV-2_36_d
GOV-3
Integration of sustainability-related performance in
incentive schemes
GOV-3_29 / GOV-3_13
GOV-4
Statement on sustainability due diligence
GOV-4_30
GOV-5
Risk management and internal controls over
sustainability reporting
GOV-5
SBM-1
Strategy, business model and value chain (products,
markets, customers)
SBM-1_40 / SBM-1_42
SBM-2
Interests and views of stakeholders
SBM-2_45
SBM-3
Material impacts, risks and opportunities and their
interaction with Strategy and business model
SBM-3_48
IRO-1
Description of the process to identify and assess
material impacts, risks, and opportunities
IRO-1_8 / IRO-1_53
IRO-2
Disclosure requirements in ESRS covered by the
undertaking’s sustainability statement
IRO-2_56 / IRO-2_59
1.2 Environmental Standards
ESRS 2
General Disclosures
Sustainability Statement Section
Data points
ESRS E1 Climate Change
ESRS 2, GOV-3
Integration of sustainability-related performance in
incentive schemes
GOV-3_13
E1-1
Transition plan for climate change mitigation
E1-1_14 / E1-1_16 / E1-1_16_ΑR 21
ESRS 2, SBM-3
Material impacts, risks and opportunities, and their
interaction with Strategy and business model
E1-1_16 / SMB-3_14 / SBM-3_AR 44 /
SBM-3_48 / SBM-3_AR 6 / SBM-3_AR 7
/ SBM-3_AR 8 / SBM-3_18 / SBM-3_19
/ IRO-1_AR 11 / IRO-1_AR 12 / IRO-1_AR
13 / IRO-1_20 / IRO-1_21
ESRS 2, IRO-1
Description of the processes to identify and assess material
climate related impacts, risks, and opportunities
IRO-1_20 / IRO-1_21 / IRO-1_AR 9 / IRO-
1_AR 11 /
IRO-1_AR 12 / E1-1_16_AR 2
E1-2
Policies related to climate change mitigation and
adaptation
E1-2_24 / E1-2_25
E1-3
Actions and resources in relation to climate change policies
E1-3_16 / Ε1-3_28 / Ε1-3_29 / E1-3_AR
19 / E1-4_34 /
E1-1_AR 1 / E1-4_AR 30
5. Annual Board of Directors Management Report
318
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
E1-4
Targets related to climate change mitigation and
adaptation
E1-4_32 / E1-4_33 / E1-4_34 / E1-4_AR
23 / E1-4_AR 24 / E1-4_AR 25 / IRO-1_AR
12 / E1-1 _16
E1-5
Energy consumption and mix
E1-5_37 / E1-5_AR 33 / 34, E1-5_38 / E1-
5_39 / E1-5_40 / E1-4_41 / E1-5_42 / E1-
5_43
E1-6
Gross Scopes 1, 2, 3 and total GHG emissions
E1-4_44 / E1-4_48 / E1-4_49 / E1-6_50 /
E1-6_51 / E1-6_52 / E1-5_53 / E1-6_54 /
Ε1-6_AR 39 / Ε1-6_AR 43 / Ε1-6_AR 45
/ Ε1-6_AR 46 / Ε1-6_AR 53 / Ε1-6_AR 54
/ Ε1-6_AR 55
E1-7
GHG removals and GHG mitigation projects financed
through carbon credits
E1-8
Internal carbon pricing
E1-9
Anticipated financial effects from material physical and
transition risks and potential climate-related opportunities
ESRS E2 Pollution
ESRS 2, IRO-1
Description of the processes to identify and assess material
pollution-related impacts, risks, and opportunities
IRO-1_11
E2-1
Policies related to pollution
E2-1_14 / E2-1_15
E2-2
Actions and resources related to pollution
E2-2_18 / E2-2_AR 13 / Ε2-2_AR 15
E2-3
Targets related to pollution
E2-3_ 22 / E2-3_ 23 / E2-3_ 24 / E3-3_ 25
E2-4
Pollution of air, water, and soil
E2-4_28 / E2-4_30
E2-5
Substances of concern and substances of very high concern
E2-6
Anticipated financial effects from pollution-related impacts,
risks, and opportunities
E2-6_39 / E2-6_40 / E2-6_41
ESRS E3 Water and marine resources
ESRS 2 SBM-3
Material impacts, risks and opportunities and their
interaction with Strategy and business model
SBM-3_48
ESRS 2 IRO-1
Description of the processes to identify and assess material
pollution-related impacts, risks, and opportunities
IRO-1_8 / E3-2_ 17
E3-1
Policies related to water and marine resources
Ε3-1_12 / E3-1_14
E3-2
Actions and resources related to marine resources
E3-2_ 17 / E3-2_ 18 / E3-2_ 19 / E3-2_ AR
21
E3-3
Targets related to water and marine resources
E3-3_ 22 / E3-3_ 23 / E3-3_ 25
E3-4
Water consumption
Ε3-4_28 / E3-4_29 / Ε3-4_ΑR 31 / Ε3-
4_ΑR 32
E3-5
Anticipated financial effects from pollution-related impacts,
risks, and opportunities
E3-5_33
ESRS E4 Biodiversity and ecosystems
E4-1
Transition plan and consideration of biodiversity and
ecosystems in Strategy and business model
ESRS 2, SBM-3
Material impacts, risks and opportunities and their
interaction with Strategy and business model
SBM-3_16 / ESRS2: SBM-3_48 / Ε4-1_13
ESRS 2, IRO-1
Description of processes to identify and assess material
biodiversity and ecosystem-related impacts, risks,
dependencies, and opportunities
IRO-1_17
E4-2
Policies related to biodiversity and ecosystem
E4-2_22 / E4-2_23 / E4-2_24 / ESRS2:
IRO-1_19
E4-3
Actions and resources related to biodiversity and
ecosystems
E4-3_ 27 / E4-3_28
E4-4
Targets related to biodiversity and ecosystems
E4-4_31 / E4-4_32
E4-5
Impact metrics related to biodiversity and ecosystems
change
E4-5_38 / ESRS2: IRO-1_19
E4-6
Anticipated financial effects from biodiversity and
ecosystems-related risks and opportunities
5. Annual Board of Directors Management Report
319
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
ESRS E5 Resource use and circular economy
ESRS 2, IRO-1
Description of the processes to identify and assess material
resource use and circular economy-related impacts, risks,
and opportunities
IRO-1_11
E5-1
Policies related to resource use and circular economy
E5-1_14 / E5-1_15
E5-2
Actions and resources related to resource use and circular
economy
E5-2_20 / E5-2_AR 11 / E5-2_AR 12
E5-3
Targets related to resource use and circular economy
Ε5-3_24 / Ε5-3_25 / Ε5-3_27
E5-4
Resource inflows
Ε5-4_30 / Ε5-4_31 / Ε5-4_32 / E5-4_AR
25
E5-5
Resource outflows
E5-5_35 / E5-5_36 / E5-5_37 / E5-5_38 /
E5-5_39 / E5-5_40 / E5-5_ΑR 26
E5-6
Anticipated financial effects from biodiversity and
ecosystems-related risks and opportunities
1.3 Social Standards
ESRS 2
General Disclosures
Sustainability Statement Section
Data points
ESRS S1 Own Workforce
ESRS 2, SBM-2
Interests and views of stakeholders
SBM-2_12
ESRS 2, SBM-3
Material impacts, risks and opportunities and their
interaction with Strategy and business model
SBM-3_14 / AR 6, AR 7 / SBM-3_15 / AR 8 /
SBM-3_16 / AR 9 / SBM-3_48
S1-1
Policies related to own workforce
S1-1_19 / S1-1_20 / S1-1_21 / AR 12 / S1-
1_22 / S1-1_24
S1-2
Processes for engaging with own workers and workers’
representatives about impacts
S1-2_27_AR 19 / S1-2_27_AR 21 / AR 23 /
AR 24 / S1-2_28
S1-3
Processes to remediate negative impacts and channels for
own workers to raise concerns
S1-3_32_AR 27 / AR 28 / AR 32 / S1-3_33 /
AR 31
S1-4
Taking action on material impacts on own workforce, and
approaches to mitigating material risks and pursuing
material opportunities related to own workforce, and
effectiveness of those actions
S1-4_37 / S1-4_38_AR 39 / AR 42, S1-
4_39_AR 34
S1-4_40, AR44, AR 45, AR47, S1-4_41, AR
37 / S1-4_43 / S1-4 /AR 43
S1-5
Targets related to managing material negative impacts,
advancing positive impacts, and managing material risks
and opportunities
S1-5_46 / S1-5_47
S1-6
Characteristics of the undertaking’s employees
S1-6_50 / S1-6_51 / S1-6_AR 55 / S1-6_52
S1-7
Characteristics of non-employee workers in the
undertaking’s own workforce
S1-7_56 / S1-7_AR 62 / AR 65 / AR 66
S1-8
Collective bargaining coverage and social dialogue
S1-8_60 / AR 70 / S1-8_AR 66 / S1-8_61,
S1-8_62 / S1-8_63 / AR 69
S1-9
Diversity metrics
S1-9_65 / S1-9_66 / S1-9_AR 71
S1-10
Adequate wages
S1-10_69 / S1-1_AR 73 / AR 74
S1-11
Social Protection
S1-11_74 / S1-11_76 / S1-11_AR 75
S1-12
Persons with disabilities
S1-12_79 / S1-12_80 / S1-12_AR 76
S1-13
Training and skills development metrics
S1-13_83 / S1-13_85 / S1-13_AR 78 / AR 79
5. Annual Board of Directors Management Report
320
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
ESRS 2
General Disclosures
Sustainability Statement Section
Data points
S1-14
Health and safety metrics
S1-14_88 / S1-14_AR 80 / AR 89 / AR 91
S1-15
Work-life balance metrics
S1-15_ 93 / S1-15_ 94
S1-16
Compensations metrics (pay gap and total compensation)
S1-17
Incidents, complaints and severe human rights impacts
S1-17_103
ESRS S2 Workers in the value chain
ESRS 2, SBM-2
Interests and views of stakeholders
SBM-2_45
ESRS 2, SBM-3
Material impacts, risks and opportunities and their
interaction with Strategy and business model
SBM-3_11 / SBM-3_14 / AR 44 / SBM-3_AR
6 / SBM-3_AR 7 / SBM-3_48
S2-1
Policies related to value chain workers
S2-1_16 / S2-1_17 / S2-1_18 / S2-1_19
S2-2
Processes for engaging with value chain workers about
impacts
S2-2_22 / S2-2_AR 18
S2-3
Processes to remediate negative impacts and channels for
value chain workers to raise concerns
S2-3_ 27 / S2-3_ 28
S2-4
Taking action on material impacts on own Taking action on
material impacts on value chain workers, and approaches
to managing material risks and pursuing material
opportunities related to value chain workers, and
effectiveness of those actions
S2-4_31 / S2-4_32 / S2-4_33 / S2-4_34 /
S2-4_35 / S2-4_36 / S2-4_38
S2-5
Targets related to managing material negative impacts,
advancing positive impacts, and managing material risks
and opportunities
S2-1_ΑR 24 / S1-14_88 / S2-1_17 / S2-5_41
/ S2-5_42
ESRS S3 Affected communities
ESRS 2, SBM-2
Interests and views of stakeholders
SBM-2_7
ESRS 2, SBM-3
Material impacts, risks and opportunities and their
interaction with Strategy and business model
SBM-3_9 / SBM-3_48
S3-1
Policies related to affected communities
S3-1_14 / S3-1_15 / S3-1_16 / S3-1_17
S3-2
Processes for engaging with affected communities about
impacts
S3-2_21
S3-3
Processes to remediate negative impacts and channels for
affected communities to raise concerns
S3-3_27
S3-4
Taking action on material impacts on affected
communities, and approaches to managing material risks
and pursuing material opportunities related to affected
communities, and effectiveness of those actions
S3-4_32 / S3-4_34 / S3-4_38
S3-5
Targets related to managing material negative impacts,
advancing positive impacts, and managing material risks
and opportunities
S3-5_41
ESRS S4 Consumers and end-users
ESRS 2, SBM-2
Interests and views of stakeholders
SBM-2_8
ESRS 2, SBM-3
Material impacts, risks and opportunities and their
interaction with Strategy and business model
SBM-3_10 / SBM-3_12 / SBM-3_AR 8
S4-1
Policies related to consumers and end-users
SBM-3_10 / S4-1_15 / S4-1_16 / S4-1_17 /
S4-1_AR 11
S4-2
Processes for engaging with consumers and end-users
about impacts
S4-2_ 20 / S4-2_ 21 / S4-2_ AR 14 /
S4-2_ AR 15 / S4-2_ AR 16 / S4-2_ AR 17 /
S4-4_31
S4-3
Processes to remediate negative impacts and channels for
consumers and end-users to raise concerns
S4-3_25 / S4-3_26 / S4-3_AR 18
5. Annual Board of Directors Management Report
321
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
ESRS 2
General Disclosures
Sustainability Statement Section
Data points
S4-4
Taking action on material impacts on consumers and end-
users, and approaches to managing material risks and
pursuing material opportunities related to consumers and
end-users, and effectiveness of those actions
S4-4_30 / S4-4_31 / S4-4_32 / S4-4_33 /
S4-4_35 / S4-4_37 / S4-4_AR 35
S4-5
Targets related to managing material negative impacts,
advancing positive impacts, and managing material risks
and opportunities
S4-4_34 / S4-4_35 / S4-5_41
1.4 Governance Standards
ESRS 2
General Disclosures
Sustainability Statement Section
Data points
ESRS G1 Business Conduct
ESRS 2, GOV-1
The role of the administrative, supervisory and
management bodies
GOV-1_5
ESRS 2, IRO-1
Description of the processes to identify and assess
material impacts, risks and opportunities
SBM-3_48 / G1-1_9 / G1-1_AR 1
G1-1
Business conduct policies and corporate culture
G1-1_10 / G1-1_7 / G1-3_20
G1-2
Management of relationships with suppliers
G1-2_14 / G1-2_15 / G1-2_AR 2 / G1-2_AR 3
G1-3
Prevention and detection of corruption and bribery
GOV-1_5 / G1-3_18 / G1-3_20 / G1-3_21 / G1-
3_AR 5 / G1-3_AR 6
G1-4
Incidents of corruption or bribery
G1-3_24
G1-5
Political influence and lobbying activites
G1-5_27 / G1-5_29
G1-6
Payment practices
G1-6_31 /G1-6_33
5. Annual Board of Directors Management Report
322
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2 Sustainability due diligence statement
Core elements of due
diligence
Sections in the sustainability statements
a) Embedding due
diligence in governance,
strategy, and business
model
GOV-1, GOV-2
b) Engaging with affected
stakeholders in all key
steps of the due
diligence
Interests and views of interested parties. [SBM-2]
Description of procedures for identifying and assessing significant impacts, risks and opportunities. [IRO-1]
c) Identifying and
assessing adverse
impacts
Description of procedures for identifying and assessing significant impacts, risks and opportunities. [IRO-1]
Significant impacts and their interaction with strategy and business model. [SBM-3]
d) Taking actions to
address those adverse
impacts
Actions and resources related to climate change policies. [E1-3]
Actions and resources related to pollution prevention. [E2-2]
Actions and resources related to water and marine resources. [E3-2]
Actions and resources related to biodiversity and ecosystems. [E4-3]
Actions and resources related to resource use and circular economy. [E5-2]
Actions and resources. [S1-4]
Action on significant impacts on workers in the value chain and approaches to managing significant risks and
seizing significant opportunities in relation to workers in the value chain and effectiveness of these actions.
[S2-4]
Actions related to the prevention of significant risks and the exploitation of significant opportunities in
relation to affected communities and the effectiveness of these actions. [S3-4]
Taking action on significant impacts on consumers and end-users and approaches to managing significant
risks and seizing significant opportunities in relation to consumers and end-users and the effectiveness of
these actions. [S4-4]
e) Tracking the
effectiveness of these
efforts and
communicating
Actions and resources related to climate change policies. [E1-3]
Actions and resources related to pollution prevention. [E2-2]
Actions and resources related to water and marine resources. [E3-2]
Actions and resources related to biodiversity and ecosystems. [E4-3]
Actions and resources related to resource use and circular economy. [E5-2]
Actions and resources. [S1-4]
Action on significant impacts on workers in the value chain and approaches to managing significant risks and
seizing significant opportunities in relation to workers in the value chain and effectiveness of these actions.
[S2-4]
Actions related to the prevention of significant risks and the exploitation of significant opportunities in
relation to affected communities and the effectiveness of these actions. [S3-4]
Taking action on significant impacts on consumers and end-users and approaches to managing significant
risks and seizing significant opportunities in relation to consumers and end-users and the effectiveness of
these actions. [S4-4]
The table above provides a guide to where information about the due diligence process can be found in sustainability
statements, including details on how to implement the main aspects and steps of this process.
5. Annual Board of Directors Management Report
323
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
3 Datapoints that derive from other EU legislation
The table below includes all the datapoints that derive from other EU legislation as listed in ESRS 2 appendix B,
indicating where the data points can be found in our report and which data points are assessed as “Not material”.
Disclosure Requirement and related data point
Legislation
Section
ESRS2 GOV-1
Board's gender diversity paragraph 21 item (d)
SFDR / BRR
GENERAL INFORMATION
[ESRS2:GOV-1] - The role of
administrative, management and
supervisory bodies
ESRS 2 GOV-1
Percentage of board members who are independent
paragraph 21 item (e)
BRR
GENERAL INFORMATION
[ESRS2:GOV-1] - The role of
administrative, management and
supervisory bodies
ESRS 2 GOV-4
Statement on due diligence paragraph 30
SFDR
GENERAL INFORMATION
[ESRS2:GOV-4] - Due Diligence
ESRS 2 SBM-1
Involvement in activities related to fossil fuel
activities paragraph 40 item (d) i
SFDR / EBA / BRR
STRATEGIC PRIORITIES & BUSINESS
MODEL [ESRS2: SBM-1] - Major
markets for Aluminium finished
products
ESRS 2 SBM-1
Involvement in activities related to chemical
production paragraph 40 item (d) ii
SFDR / BRR
Not relevant
ESRS 2 SBM-1
Involvement in activities related to controversial
weapons paragraph 40 item (d) iii
SFDR / BRR
Not relevant
ESRS 2 SBM-1
Involvement in activities related to cultivation and
production of tobacco paragraph 40 item (d) iv
BRR
Not relevant
ESRS E1-1
Transition plan to reach climate neutrality by 2050
paragraph 14
EUCL
CLIMATE CHANGE [ESRS: E1]
E1-1 - Climate change mitigation
transition plan
ESRS E1-1
Undertakings excluded from Paris-aligned
Benchmarks paragraph 16 item (g)
EBA / BRR
CLIMATE CHANGE [ESRS: E1]
E1-1 - Climate change mitigation
transition plan
ESRS E1-4
GHG emission reduction targets paragraph 34
SFDR / EBA / BRR
CLIMATE CHANGE [ESRS: E1]
E1-4 - Targets on climate change
mitigation and adaptation
ESRS E1-5
Energy consumption from fossil sources
disaggregated by sources (only high climate impact
sectors) paragraph 38
SFDR
CLIMATE CHANGE [ESRS: E1]
E1-5 - Energy Consumption and
Energy Mix
ESRS E1-5
Energy consumption and mix paragraph 37
SFDR
CLIMATE CHANGE [ESRS: E1]
E1-5 - Energy Consumption and
Energy Mix
5. Annual Board of Directors Management Report
324
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Disclosure Requirement and related data point
Legislation
Section
ESRS E1-5 Energy intensity associated with activities
in high climate impact sectors paragraph 40-43
SFDR
CLIMATE CHANGE [ESRS: E1]
E1-5 - Energy Consumption and
Energy Mix
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG
emissions paragraph 44
SFDR / EBA / BRR
CLIMATE CHANGE [ESRS: E1]
E1-6 - Gross Scope 1, 2, 3 emissions
and total GHG emissions
ESRS E1-6
Gross GHG emissions intensity paragraph 53-55
SFDR / EBA / BRR
CLIMATE CHANGE [ESRS: E1]
E1-6 - Gross Scope 1, 2, 3 emissions
and total GHG emissions
ESRS E1-7 GHG removals and carbon credits
paragraph 56
EUCL
CLIMATE CHANGE [ESRS: E1]
E1-7 - GHG removal & E1-8 Internal
carbon pricing
ESRS E1-9
Exposure of the benchmark portfolio to climate-
related physical risks paragraph 66
BRR
Not available
ESRS E1-9
Disaggregation of monetary amounts by acute and
chronic physical risk; Location of significant assets at
material physical risk paragraph 66 item (a) ;
paragraph 66 item (c)
EBA
Not available
ESRS E1-9
Breakdown of the carrying value of its real estate
assets by energy-efficiency classes paragraph 67 item
(c)
EBA
Not available
ESRS E1-9
Degree of exposure of the portfolio to climate-related
opportunities paragraph 69
BRR
Not available
ESRS E2-4
Amount of each pollutant listed in Annex II of the E-
PRTR Regulation emitted to air, water, and soil
paragraph 28
SFDR
POLLUTION [ESRS: E2]
E2-4 - Pollution of air, water and
soil
ESRS E3-1
Water and marine resources paragraph 9
SFDR
WATER AND MARINE RESOURCES
[ESRS: E3]
E3-1 - Policies related to water and
marine resources
ESRS E3-1
Dedicated policy paragraph 13
SFDR
WATER AND MARINE RESOURCES
[ESRS: E3]
E3-1 - Policies related to water and
marine resources
ESRS E3-1
Sustainable oceans and seas paragraph 14
SFDR
WATER AND MARINE RESOURCES
[ESRS: E3]
E3-1
Policies related to water and
marine resources
ESRS E3-4
Total water recycled and reused paragraph 28 item
(c)
SFDR
WATER AND MARINE RESOURCES
[ESRS: E3]
E3-4 - Water consumption
ESRS E3-4
Total water consumption in m3 per net revenue on
own operations paragraph 29
SFDR
WATER AND MARINE RESOURCES
[ESRS: E3]
E3-4 - Water consumption
5. Annual Board of Directors Management Report
325
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Disclosure Requirement and related data point
Legislation
Section
ESRS 2- SBM 3 - E4 paragraph 16 item (a) i
SFDR
BIODIVERSITY AND ECOSYSTEMS
[ESRS: E4]
SBM-3 - Material impacts, risks,
and opportunities and their
interaction with the strategy and
business model
ESRS 2- SBM 3 - E4 paragraph 16 item (b)
SFDR
BIODIVERSITY AND ECOSYSTEMS
[ESRS: E4]
SBM-3 - Material impacts, risks,
and opportunities and their
interaction with the strategy and
business model
ESRS 2- SBM 3 - E4 paragraph 16 item (c)
SFDR
BIODIVERSITY AND ECOSYSTEMS
[ESRS: E4]
SBM-3 - Material impacts, risks,
and opportunities and their
interaction with the strategy and
business model
ESRS E4-2
Sustainable land / agriculture practices or policies
paragraph 24 item (b)
SFDR
BIODIVERSITY AND ECOSYSTEMS
[ESRS: E4] E4-2 - Policies related to
biodiversity and ecosystems
ESRS E4-2
Sustainable oceans / seas practices or policies
paragraph 24 item (c)
SFDR
BIODIVERSITY AND ECOSYSTEMS
[ESRS: E4] E4-2 - Policies related to
biodiversity and ecosystems
ESRS E4-2
Policies to address deforestation paragraph 24 item
(d)
SFDR
BIODIVERSITY AND ECOSYSTEMS
[ESRS: E4] E4-2 - Policies related to
biodiversity and ecosystems
ESRS E5-5
Non-recycled waste paragraph 37 item (d)
SFDR
RESOURCE USE AND CIRCULAR
ECONOMY [ESRS: E5]
E5-5 - Resource outflows
ESRS E5-5 Hazardous waste and radioactive waste
paragraph 39
SFDR
RESOURCE USE AND CIRCULAR
ECONOMY [ESRS: E5] E5-5 -
Resource outflows
ESRS 2- SBM3 - S1 Risk of incidents of forced labor
paragraph 14 item (f)
SFDR
OWN WORKFORCE [ESRS: S1]
ESRS2: SBM-3 - Material impacts,
risks and opportunities and their
interaction with strategy and
business model
ESRS 2- SBM3 - S1 Risk of incidents of child labor
paragraph 14 item (g)
SFDR
OWN WORKFORCE [ESRS: S1]
ESRS2: SBM-3 - Material impacts,
risks and opportunities and their
interaction with strategy and
business model
ESRS S1-1 Human rights policy commitments
paragraph 20
SFDR
OWN WORKFORCE [ESRS: S1]
S1-1 – Policy on the management
of material impacts on the
workforce
ESRS S1-1
Due diligence policies on issues addressed by the
fundamental International Labor Organization
Conventions 1 to 8 paragraph 21
SFDR
OWN WORKFORCE [ESRS: S1]
S1-1 – Policy on the management
of material impacts on the
workforce
ESRS S1-1
Processes and measures for preventing trafficking in
human beings paragraph 22
SFDR
OWN WORKFORCE [ESRS: S1]
S1-1 – Policy on the management
of material impacts on the
workforce
5. Annual Board of Directors Management Report
326
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Disclosure Requirement and related data point
Legislation
Section
ESRS S1-1
Workplace accident prevention policy or
management system paragraph 23
SFDR
OWN WORKFORCE [ESRS: S1]
S1-1 – Policy on the management
of material impacts on the
workforce
ESRS S1-3
Grievance/complaints handling mechanisms
paragraph 32 item (c)
SFDR
OWN WORKFORCE [ESRS: S1]
S1-3 - Processes to remediate
negative impacts and channels for
own workers to raise concerns
ESRS S1-14
Number of fatalities and number and rate of work-
related accidents paragraph 88 item (b) and (c)
SFDR / BRR
OWN WORKFORCE [ESRS: S1]
S1-14 - Health and safety metrics
ESRS S1-14
Number of days lost to injuries, accidents, fatalities,
or illness paragraph 88 item (e)
SFDR
OWN WORKFORCE [ESRS: S1]
S1-14 - Health and safety metrics
ESRS S1-16 Unadjusted gender pay gap paragraph 97
item (a)
SFDR / BRR
OWN WORKFORCE [ESRS: S1]
S1-16 - Compensation metrics (pay
gap and total compensation)
ESRS S1-16
Excessive CEO pay ratio paragraph 97 item (b)
SFDR
OWN WORKFORCE [ESRS: S1]
S1-16 - Compensation metrics (pay
gap and total compensation)
ESRS S1-17
Incidents of discrimination paragraph 103 item (a)
SFDR
OWN WORKFORCE [ESRS: S1]
S1-17 - Incidents, complaints and
severe human rights impacts
ESRS S1-17
Non-respect of UNGPs on Business and Human Rights
and OECD paragraph 104 item (a)
SFDR / BRR
OWN WORKFORCE [ESRS: S1]
S1-17 - Incidents, complaints and
severe human rights impacts
ESRS 2- SBM3 – S2 Significant risk of child labour or
forced labour in the value chain paragraph 11 item
(b)
SFDR
WORKERS IN THE VALUE CHAIN
[ESRS: S2]
SBM-3 - Material impacts, risks,
and opportunities and their
interaction with the strategy and
business model
ESRS S2-1 Human rights policy commitments
paragraph 17
SFDR
WORKERS IN THE VALUE CHAIN
[ESRS: S2]
S2-1 - Policies related to value
chain workers
ESRS S2-1 Policies related to value chain workers
paragraph 18
SFDR
WORKERS IN THE VALUE CHAIN
[ESRS: S2]
S2-1 - Policies related to value
chain workers
ESRS S2-1 Non-respect of UNGPs on Business and
Human Rights principles and OECD guidelines
paragraph 19
SFDR / BRR
WORKERS IN THE VALUE CHAIN
[ESRS: S2]
S2-1 - Policies related to value
chain workers
ESRS S2-1 Due diligence policies on issues addressed
by the fundamental International Labor Organization
Conventions 1 to 8 paragraph 19
BRR
WORKERS IN THE VALUE CHAIN
[ESRS: S2]
S2-1 - Policies related to value
chain workers
ESRS S2-4 Human rights issues and incidents
connected to its upstream and downstream value
chain paragraph 36
SFDR
WORKERS IN THE VALUE CHAIN
[ESRS: S2] - S2-4
Taking action on material impacts
on value chain workers, and
approaches to managing material
risks and pursuing material
opportunities related to value
5. Annual Board of Directors Management Report
327
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Disclosure Requirement and related data point
Legislation
Section
chain workers, and effectiveness of
those actions
ESRS S3-1 Human rights policy commitments
paragraph 16
SFDR
AFFECTED COMMUNITIES [ESRS:
S3] S3-1 - Policies related to
affected communities
ESRS S3-1
Non-respect of UNGPs on Business and Human
Rights, ILO principles or and OECD guidelines
paragraph 17
SFDR / BRR
AFFECTED COMMUNITIES [ESRS:
S3] S3-1 - Policies related to
affected communities
ESRS S3-4 Human rights issues and incidents
paragraph 36
SFDR
AFFECTED COMMUNITIES [ESRS:
S3] S3-4 - Taking action on material
impacts, and approaches to
mitigating material risks and
pursuing material opportunities
related to affected communities,
and effectiveness of those actions
and approaches
ESRS S4-1 Policies related to consumers and end-
users paragraph 16
SFDR
CONSUMERS AND END-USERS
[ESRS: S4]
S4-1 - Policies related to consumers
and end-users
ESRS S4-1 Non-respect of UNGPs on Business and
Human Rights and OECD guidelines paragraph 17
ESRS S4-4 Human rights issues and incidents
paragraph 35
SFDR
CONSUMERS AND END-USERS
[ESRS: S4]
S4-4 - Taking action on material
impacts on consumers and end-
users, and approaches to managing
material risks and pursuing
material opportunities related to
consumers and end-users, and
effectiveness of those actions
ESRS G1-1 United Nations Convention against
Corruption paragraph 10 item (b)
SFDR
BUSINESS CONDUCT [ESRS: G1]
G1-1 - Corporate culture and
Business conduct policies
ESRS G1-1
Protection of whistle- blowers paragraph 10 item (d)
SFDR
BUSINESS CONDUCT [ESRS: G1]
G1-1 - Corporate culture and
Business conduct policies
ESRS G1-4
Fines for violation of anti-corruption and anti-bribery
laws paragraph 24 item (a)
SFDR / BRR
BUSINESS CONDUCT [ESRS: G1]
G1-4 - Confirmed incidents of
corruption or bribery
ESRS G1-4
Standards of anti- corruption and anti-bribery
paragraph 24 item (b)
SFDR
BUSINESS CONDUCT [ESRS: G1]
G1-4 - Confirmed incidents of
corruption or bribery
5. Annual Board of Directors Management Report
328
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Group Structure – Branches
Companies included in the consolidated financial statements and the method of consolidation are presented in chapter 7
“Annual Financial Statements”, Note 1.3 “Group Structure”.
Significant Related Party Transactions
The commercial transactions of the Group and the Company with related parties during 2024, were realised under the common
commercial terms. The Group or any of its related parties has not entered in any transactions that were not in an arm’s length
basis, and do not intent to participate in such transactions in the future. No transaction was under any special terms and
conditions.
The tables bellow present the intercompany sales and transactions, among the Parent Company and its subsidiaries, associates
and the key management personnel as at 31st December 2024 and 31st December 2023.
Benefits to key management personnel at Group and Parent level:
METLEN ENERGY & METALS GROUP
METLEN ENERGY & METALS S.A.
(Amounts in thousands €)
31.12.2024
31.12.2023
31.12.2024
31.12.2023
Short term employee benefits
- Wages of Key Management and BOD Fees
7,315
11,644
3,203
7,634
- Tax and Insurance service cost
579
519
256
213
- Bonus
283
150
283
150
- Other
-
293
-
-
- Payments based on equity shares
4,965
9,428
4,965
9,428
Total
13,142
22,034
8,707
17,425
The Company has implemented share-based payments for its employees and executives. In particular, under the effective
agreements, the Company’s employees and executives are granted the option to receive equity securities (shares) of the
parent company, given that certain conditions of vesting have been met.
None of the existing equity-based payment agreement plans are settled in cash.
Services received in return for equity-based payments are measured at fair value. The fair value of the services of executives
and employees, at the date when the stock option is granted, is recognised in accordance with IFRS 2 as an expense in the
income statement, with a corresponding increase in equity, during the period in which the services, for which the options
granted, are received.
Total expenses of the options during the vesting period are calculated based on the fair value of the options provided at the
granting date. The expenses are allocated over the vesting period, based on the best available estimate of the number of stock
options expected to be vested. The fair value of the options is measured by adopting an appropriate valuation model to reflect
the number of options for which the performance conditions of the plan are expected to be met.
Estimates of the number of option’s expected to be exercised are revised if there is an indication that the number of stock
options, expected to be vested, differs from previous estimates. Any adjustment to the cumulative share-based compensation
arising from the revision is recognised within the current period.
The number of vested options, finally exercised by the company’s employees and executives does not affect the expenses
recorded within the period.
No loans have been given to members of the Board of Directors or other management members of the Group (and their
families).
(Note 3.30).
VIII. OTHER INFORMATION FOR THE GROUP AND THE COMPANY
IX.
5. Annual Board of Directors Management Report
329
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Transactions with related parties
The below mentioned companies are subsidiaries of METLEN Energy & Metals S.A.
METLEN
ENERGY &
METALS
GROUP
METLEN
ENERGY &
METALS S.A.
(Amounts in thousands €)
31.12.2024
31.12.2024
Sales of goods
METKA-EGN Ltd Cyprus
-
9
Protergia Energy Albania
-
355
SPIDER S.A.
-
44
UNISON Facility Services S.A.
-
25
VOLTERRA S.A.
-
743
ZEOLOGIC S.A.
-
8
AIOLIKI ANDROU TSIROVLIDI S.A.
-
79
AIOLIKI EVOIAS DIAKOFTIS S.A.
-
4
AIOLIKI EVOIAS POUNTA S.A.
-
4
AIOLIKI EVOIAS PIRGOS S.A.
-
5
AIOLIKI EVOIAS HELONA S.A.
-
5
AIOLIKI SIDIROKASTROU S.A.
-
52
AIOLIKH TRIKORFON S.A.
-
19
RENEWABLE SOURCES OF KARYSTIA S.A.
-
23
DELFI DISTOMON A.M.E.
-
893
EGNATIA WIND SM.S.A.
-
72
ELEMKA S.A.
-
2
SERVISTEEL S.A.
-
75
HELLENIC SOLAR S.A.
-
30
EP.AL.ME. S.A.
-
10,324
EUROPEAN BAUXITES SM.S.A.
-
832
EFA S.A.
-
4,696
KORINTHOS POWER S.A.
-
109,729
MAKRYNOROS ENERGEIAKH S.A.
-
95
MYTILINEOS CONSTRUCTION SINGLE MEMBER SOCIÉTÉ ANONYME
-
112
HYDROHOOS S.A.
-
3
Purchases of goods
SOMETRA S.A.
-
132
ZEOLOGIC S.A.
-
5,390
DELFI DISTOMON A.M.E.
-
12,265
EP.AL.ME. S.A.
-
5,401
EUROPEAN BAUXITES SM.S.A.
-
40,689
MNG TRADING S.A.
-
4
Services Sales
EGNATIA ERGO ENERGY SΜ.S.A.
-
178
METKA International LTD
-
2,836
METKA RENEWABLE LTD CYPRUS
-
73
METKA-EGN Ltd Cyprus
-
5,032
MYTILINEOS - SM.S.A. TEXNOLOGIKIS KAI PSIFIAKIS KAINOTOMIAS
-
101
MYTILINEOS FINANCIAL PARTNERS S.A.
-
69,537
POWER PROJECT
-
521
PROTERGIA ENERGY S.A.
-
13,031
PROTERGIA ENERGY DOOEL Skopje
-
417
PROTERGIA THERMOELEKTRIKI S.A.
-
6
SOLIEN ENERGY S.A.
-
6
SOMETRA S.A.
-
15
SPIDER S.A.
-
313
UNISON Facility Services S.A.
-
406
VOLTERRA S.A.
-
35
ZEOLOGIC S.A.
-
57
ST. NIKOLAOS SINGLE MEMBER P.C.
-
55
AENAOS SYSSOREUTES ENERGEIAKI MONOPROSOPI AE
-
200
AETOVOUNI S.A.
-
6
5. Annual Board of Directors Management Report
330
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
AIOLIKI ANDROU RAHI XIROKOBI S.A.
-
6
AIOLIKI ANDROU TSIROVLIDI S.A.
-
122
AIOLIKH ARGOSTYLIAS S.A.
-
6
AIOLIKI EVOIAS DIAKOFTIS S.A.
-
79
AIOLIKI EVOIAS POUNTA S.A.
-
80
AIOLIKI EVOIAS PIRGOS S.A.
-
111
AIOLIKI EVOIAS HELONA S.A.
-
56
AIOLIKI SAMOTHRAKIS S.A.
-
6
AIOLIKI SIDIROKASTROU S.A.
-
170
AIOLIKH TRIKORFON S.A.
-
76
ALUMINIUM OF GREECE INDUSTRIAL AND COMMERCIAL SOCIETE ANONYME
-
4
RENEWABLE SOURCES OF KARYSTIA S.A.
-
224
ANEMODRASI RENEWABLE ENERGY SOURCES S.A.
-
6
ANEMORAHI RENEWABLE ENERGY SOURCES S.A.
-
6
ANEMOROE SM.S.A.
-
6
GENIKI VIOMICHANIKI S.A.
-
4
DELFI DISTOMON A.M.E.
-
112
EGNATIA WIND SM.S.A.
-
109
EGNATIA EK.A. SM.S.A.
-
235
ELEMKA S.A.
-
711
HELLENIC SOLAR S.A.
-
167
EP.AL.ME. S.A.
-
148
EUROPEAN BAUXITES SM.S.A.
-
3
IKAROS ANEMOS S.A.
-
94
KERASOUDA S.A.
-
6
KILKIS PALEON TRIETHNES S.A.
-
6
KISSAVOS DROSERI RAHI S.A.
-
6
KISSAVOS PLAKA TRANI S.A.
-
6
KISSAVOS FOTINI S.A.
-
6
KORINTHOS POWER S.A.
-
9,035
LOGGARIA S.A.
-
6
M PARACHORISEON SINGLE MEMBER S.A.
-
2
MAKRYNOROS ENERGEIAKH S.A.
-
571
METKA AIOLIKA PLATANOU S.A.
-
6
NORTH AEGEAN RENEWABLES
-
6
MYTILINEOS HELLENIC WIND POWER S.A.
-
25
MYTILINEOS AIOLIKI NEAPOLEOS S.A.
-
6
MNG TRADING S.A.
-
4
MYTILINEOS CONSTRUCTION SINGLE MEMBER SOCIÉTÉ ANONYME
-
1,093
HYDROHOOS S.A.
-
12
HORTEROU S.A.
-
6
CHRISOS HELIOS ENERGEIAKI
-
183
Other Transactions
METKA International LTD
-
2,793
METKA POWER WEST AFRICA LIMITED
-
47
METKA-EGN Ltd Cyprus
-
8,743
POWER PROJECT
-
888
MYTILINEOS CONSTRUCTION SINGLE MEMBER SOCIÉTÉ ANONYME
-
115
Services Purchases
MYTILINEOS FINANCIAL PARTNERS S.A.
-
5,958
PROTERGIA ENERGY S.A.
-
2,793
PROTERGIA ENERGY DOOEL Skopje
-
5,124
UNISON Facility Services S.A.
-
361
ZEOLOGIC S.A.
-
4,807
DELFI DISTOMON A.M.E.
-
17
ELEMKA S.A.
-
13,296
SERVISTEEL S.A.
-
1,996
KORINTHOS POWER S.A.
-
15
MYTILINEOS CONSTRUCTION SINGLE MEMBER SOCIÉTÉ ANONYME
-
96
5. Annual Board of Directors Management Report
331
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN
ENERGY &
METALS
GROUP
METLEN
ENERGY &
METALS
S.A.
(Amounts in thousands €)
31.12.2024
31.12.2024
Receivables from Related Parties
EGNATIA ERGO ENERGY SΜ.S.A.
-
16,402
METKA International LTD
-
23,733
METKA Power Investments
-
2,079
METKA POWER WEST AFRICA LIMITED
-
693
METKA RENEWABLE LTD CYPRUS
-
3,761
METKA-EGN Ltd Cyprus
-
143,369
MTRH Develoment LTD.
-
75
MYTILINEOS - SM.S.A. TEXNOLOGIKIS KAI PSIFIAKIS KAINOTOMIAS
-
662
MYTILINEOS FINANCIAL PARTNERS S.A.
-
1,617,832
Mytilineos Ghana Minerals LTD
-
462
Mytilineos International Trading Company AG (MIT Co)
-
204
MYTILINEOS WIND ENERGY ALBANIA Ltd
-
299
POWER PROJECT
-
953
Protergia Enegy Albania
-
99
PROTERGIA ENERGY S.A.
-
2,076
PROTERGIA ENERGY DOOEL Skopje
-
597
PROTERGIA THERMOELEKTRIKI S.A.
-
10,567
SOLIEN ENERGY S.A.
-
7
SOMETRA S.A.
-
877
SPIDER S.A.
-
9,103
STANMED TRADING LTD
-
245
UNISON Facility Services S.A.
-
21
VOLTERRA S.A.
-
12,905
Watt & Volt Albania SH.P.K.
-
29
Watt & Volt Bulgaria EOOD
-
299
ZEOLOGIC S.A.
-
225
ST. NIKOLAOS SINGLE MEMBER P.C.
-
16
AENAOS SYSSOREUTES ENERGEIAKI MONOPROSOPI AE
-
286
AETOVOUNI S.A.
-
362
AIOLIKI ANDROU RAHI XIROKOBI S.A.
-
7
AIOLIKI ANDROU TSIROVLIDI S.A.
-
176
AIOLIKH ARGOSTYLIAS S.A.
-
7
AIOLIKI EVOIAS DIAKOFTIS S.A.
-
560
AIOLIKI EVOIAS POUNTA S.A.
-
577
AIOLIKI EVOIAS PIRGOS S.A.
-
1,003
AIOLIKI EVOIAS HELONA S.A.
-
439
AIOLIKI SAMOTHRAKIS S.A.
-
3,579
AIOLIKI SIDIROKASTROU S.A.
-
244
AIOLIKH TRIKORFON S.A.
-
98
ALUMINIUM OF GREECE INDUSTRIAL AND COMMERCIAL SOCIETE ANONYME
-
609
RENEWABLE SOURCES OF KARYSTIA S.A.
-
2,743
ANEMODRASI RENEWABLE ENERGY SOURCES S.A.
-
7
ANEMORAHI RENEWABLE ENERGY SOURCES S.A.
-
7
ANEMOROE SM.S.A.
-
7
GENIKI VIOMICHANIKI S.A.
-
234
DELFI DISTOMON A.M.E.
-
6,945
DESFINA SHIPPING COMPANY
-
46
EGNATIA WIND SM.S.A.
-
170
5. Annual Board of Directors Management Report
332
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
EGNATIA EK.A. SM.S.A.
-
1,865
ELEMKA S.A.
-
2,963
ELIF SINGLE MEMBER S.A.
-
55
HELLENIC SOLAR S.A.
-
215
EP.AL.ME. S.A.
-
14,439
EUROPEAN BAUXITES SM.S.A.
-
220
EFA S.A.
-
4,406
IKAROS ANEMOS S.A.
-
610
J/V MYTILINEOS ELEMKA
-
6,045
KERASOUDA S.A.
-
7
KILKIS PALEON TRIETHNES S.A.
-
524
KISSAVOS DROSERI RAHI S.A.
-
7
KISSAVOS PLAKA TRANI S.A.
-
7
KISSAVOS FOTINI S.A.
-
7
KORINTHOS POWER S.A.
-
15,241
LOGGARIA S.A.
-
7
M PARACHORISEON SINGLE MEMBER S.A.
-
1,406
MAKRYNOROS ENERGEIAKH S.A.
-
2,308
METKA AIOLIKA PLATANOU S.A.
-
7
MIKRO PATOMA ENERGEIAKI SM.S.A.
-
60
NORTH AEGEAN RENEWABLES
-
7
MYTILINEOS HELLENIC WIND POWER S.A.
-
34,088
MYTILINEOS AIOLIKI NEAPOLEOS S.A.
-
12
MNG TRADING S.A.
-
171
MYTILINEOS CONSTRUCTION SINGLE MEMBER SOCIÉTÉ ANONYME
-
4,991
ODOFOTISMOS IPEIROU SM.S.A.
-
4
HYDROHOOS S.A.
-
36
HORTEROU S.A.
-
351
CHRISOS HELIOS ENERGEIAKI
-
883
Payables to Related Parties
EGNATIA ERGO ENERGY SΜ.S.A.
-
101
MC17 SXOLEIA KENTRIKIS MACEDONIAS S.A.
-
2,439
METKA-EGN Ltd Cyprus
-
140,182
MYTILINEOS FINANCIAL PARTNERS S.A.
-
49,475
POWER PROJECT
-
199,069
PROTERGIA ENERGY S.A.
-
494
PROTERGIA ENERGY DOOEL Skopje
-
176
SPIDER S.A.
-
3,082
UNISON Facility Services S.A.
-
344
ZEOLOGIC S.A.
-
3,601
AENAOS SYSSOREUTES ENERGEIAKI MONOPROSOPI AE
-
472
AIOLIKI ANDROU RAHI XIROKOBI S.A.
-
4
AIOLIKH ARGOSTYLIAS S.A.
-
66
AIOLIKI EVOIAS DIAKOFTIS S.A.
-
748
AIOLIKI EVOIAS POUNTA S.A.
-
838
AIOLIKI EVOIAS PIRGOS S.A.
-
1,298
AIOLIKI EVOIAS HELONA S.A.
-
565
RENEWABLE SOURCES OF KARYSTIA S.A.
-
2,503
ANEMODRASI RENEWABLE ENERGY SOURCES S.A.
-
75
ANEMORAHI RENEWABLE ENERGY SOURCES S.A.
-
169
ANEMOROE SM.S.A.
-
72
EGNATIA WIND SM.S.A.
-
339
ELEMKA S.A.
-
5,255
SERVISTEEL S.A.
-
2,485
5. Annual Board of Directors Management Report
333
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
EP.AL.ME. S.A.
-
9,530
EUROPEAN BAUXITES SM.S.A.
-
4,117
KERASOUDA S.A.
-
12
KISSAVOS DROSERI RAHI S.A.
-
244
KISSAVOS PLAKA TRANI S.A.
-
252
KISSAVOS FOTINI S.A.
-
109
KORINTHOS POWER S.A.
-
10,055
LOGGARIA S.A.
-
71
MAKRYNOROS ENERGEIAKH S.A.
-
2,306
NORTH AEGEAN RENEWABLES
-
184
MNG TRADING S.A.
-
5
MYTILINEOS CONSTRUCTION SINGLE MEMBER SOCIÉTÉ ANONYME
-
179
Dividend Policy
The Board of Directors will propose to the Annual General Assembly of Shareholders, scheduled on 3 June 2025, the
distribution of dividend €1.5000 per share. As the distribution of dividends requires approval at the shareholders’ meeting, no
liability, in this respect, is recognised in the 2024 Financial Statements.
Post Balance Sheet events
Post balance sheet events are listed in chapter 7 “Annual Financial Statements”, Note 3.40.
Evangelos Mytilineos
Spyridon Kasdas
Chairman of the Board of Directors & Chief
Executive Officer
Vice-Chairman A’ of the Board of Directors
6. Explanatory report
334
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Information regarding the issues of article 4 paragraph 7-8 of L.3556/2007 of METLEN
This explanatory report of the Board of Directors is submitted to the Ordinary General Shareholders’ Meeting and contains
detailed information regarding the issues of paragraph 7 and 8 of article 4 L.3556/2007, as in force.
Ι. Company’s Share Capital Structure
The share capital of the Company amounts to one hundred thirty-eight million six hundred four thousand four hundred
twenty-six euros and seventeen cents (€138.604.426,17), divided into one hundred forty-two millions eight hundred
ninety-one thousand one hundred sixty-one (142.891.161) registered shares with a nominal value of €0,97 each.
The shares of the Company are all listed on the Securities Market of the Athens Exchange [Sector “Industrial Goods &
Services”].
The rights of the Company’s shareholders with respect to their shares are proportional to the share capital stake to which
the paid-in share value corresponds. Each share incorporates all the rights and obligations that are stipulated by the Law
and Company’s Articles of Association, and more specifically:
i. The right to dividends from the annual profits or liquidation profits of the Company. A percentage of 35% of the net profits
following deduction of the statutory reserves and other income statement credits, which do not constitute only statutory
earnings, is distributed from the profits of each year to the shareholders as an initial dividend while the distribution of an
additional dividend is resolved upon by the General Meeting. The General Meeting determines the added dividend.
Dividends are entitled to each shareholder who is registered in the Shareholders’ Register held on behalf of the Company
by the “Hellenic Exchanges – Athens Stock Exchange” on the date of approval of the financial statements by the Ordinary
General Shareholders’ Meeting. The payment date and the payment method of the dividend are available through the
media appointed by L. 3556/07. The right to receive payment of the dividend is subject to a time limitation and the
respective unclaimed amount goes to the State upon the lapse of five (5) years from the end of the year during which the
General Meeting approved the distribution of the said dividend.
ii. The right to reclaim the amount of one’s contribution during the liquidation or, similarly, the writing off of the capital
representing the share, provided that this is resolved upon by the General Meeting,
iii. The right of pre-emption according to their participation in the existing share capital at every share capital increase of the
Company (including increase in kind) or issuance of convertible bonds into shares or cash and at undertaking new shares,
including increases in kind or issuance of convertible bonds into shares.
iv. Each shareholder is entitled to request the annual financial statements along with the relevant reports of the Board of
Directors and the Auditors of the Company.
v. Shareholders participate in the Company’s General Meeting which constitute the following rights: in person presence or by
delegate, vote, participation in discussions, submission of proposals on the items of the agenda, entry of one’s opinion on
the minutes of the Meeting and finally the right to vote.
The General Meeting of Company’s Shareholders retain all its rights and obligations during the winding up (according to
paragraph 4 of article 33 of the Articles of Association). The shareholders’ responsibility is limited to the nominal value of the
shares held.
II. Restrictions for transferring Company shares
The transfer of Company shares takes place based on procedures stipulated by the law under which the Company is liable, while
there are no restrictions set by the Articles of Association for transfer of shares.
III. Important Indirect/Direct participations according to articles 9-11 of L.3556/2007
On 31.12.2024 Mr. Evangelos Mytilineos held:
(a) indirectly, through EMERGIA HOLDINGS LTD, MELVET INVESTMENTS LTD, ROCALDO LTD, FREZIA LTD and KILTEO LTD,
30,777,306 common registered shares with voting rights of METLEN, and
(b) directly, as a natural person, 44,613 common registered shares with voting rights of METLEN.
Therefore, on 31.12.2024, Mr. Evangelos Mytilineos held (directly and indirectly) in total 30,821,919 common registered shares
with voting rights of METLEN, i.e. 21.570% of its total voting rights.
6. Explanatory report
6. Explanatory report
335
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Οn 10.02.2025, due to the exercise of the exchange right under the terms of the exchangeable bond loan issued on 07.02.2023
by METLEN, the companies NORTHBRIDGE GENERAL INSURANCE CORPORATION, ODYSSEY REINSURANCE COMPANY and
ZENITH INSURANCE COMPANY (CANADA) (hereinafter: the "Bondholders") acquired a total of 2,500,000 common registered
voting shares of METLEN, which represent 1.75% of its total voting rights. These shares, added to METLEN shares already held
on the above date by the Bondholders, as well as by other legal entities (hereinafter: the "Other Shareholders") belonging to
the Fairfax Financial Holdings Limited (hereinafter: the "FFH") group, i.e. 6,688,047 common registered voting shares of METLEN,
which represent 4.68% of its total rights, lead to a cumulative participation percentage through shares ownership, which
amounts to 6.43% of the common registered voting shares of METLEN. The Other Shareholders are: (a) Allied World Specialty
Insurance Company, (b) Allied World Insurance Company, (c) Allied World Assurance Company (Europe) dac, (d) HWIC Value
Opportunities Fund, (e) Eurolife FFH General Insurance Single Member SA, (f) Eurolife FFH Life Insurance Single Member SA, and
(g) Odyssey Reinsurance (Barbados) Ltd. As a result of the above, as of 10.02.2025, FFH holds indirectly, through controlled
entities, METLEN shares corresponding to a participation percentage of 6.43% of its total voting shares.
On publication date 13.03.2025, the shareholders that hold more than 5% of the total voting rights of the Company according
to articles 9-11 of L. 3556/2007 are the same as above.
IV. Shares with special control rights
There are no Company shares that provide special control rights to their holders.
V. Restrictions on voting rights
No restrictions on voting rights emanate from the Company shares according to the Articles of Association.
VI. Agreements between Company shareholders
Notwithstanding share pledge agreements that may from time to time be notified to the Company, which according to standard
practice include provisions regarding the transfer of voting rights to the pledgee in case of breach or failure to fulfil secured
obligations, the Company is not aware of any agreements among its shareholders, which would result in restrictions on the
assignment of its shares or exercise of the voting rights stemming from such shares.
VII. Regulations regarding the assignment and replacement of BoD members and amendments of the Articles of
Association
The Company’s Articles of Association (article 21), within the powers vested by Law 4548/2018 as it is now in force, provide the
following regarding the appointment and substitution of its members of the BoD:
i. The Board of Directors may elect members in substitution of members who resigned, died or forfeited their office
in any other manner; this election is done provided such substitution cannot feasibly be done from substitute
members, if any, elected by the General Meeting. Such election by the Board of Directors is effected by means of
a decision of the remaining members, provided they are at least three (3), and is valid for the remainder of the
term of the substituted member. The election decision is submitted to the publication formalities pursuant to Law
4548/2018 and is announced by the Board of Directors to the immediately following General Meeting session; the
General Meeting may replace the elected members, even if no such item is included in the General Meeting
agenda.
ii. In case of resignation, death or forfeiture, in any other manner, of director status, the remaining directors (BoD
members) may continue to run and represent the company even without substituting the members in question as
per the preceding paragraph, provided their number exceeds one half of the number of members as it stood prior
to the occurrence of the said events. In all cases, such members may not be less than three (3).
iii. In all cases, the remaining BoD members, irrespective of the number thereof, may call the General Meeting for the
sole purpose of electing a new Board of Directors.
iv. The substitution of BoD members pursuant to the preceding paragraphs is in conformance with and subject to the
provisions of the law concerning the participation of independent non executive members in the Board of
Directors.
The provisions of the Company’s Articles of Association regarding the amendment of the provisions thereof do not deviate from
the provisions of the Law 4548/2018.
VIIΙ. Responsibility of the BoD for a) the issuance of new shares or b) acquisition of own shares according to article 49
of Law 4548/2018
a) According to the provisions of article 5 par. 8 of the Company’s Articles of Association in conjunction with the provisions of
article 24 par. 1(b) and (c) of Law 4548/2018, the Company’s Board of Directors has the right, following a relevant decision by
the General Meeting of Shareholders, for a period not exceeding five years, to increase the Company’s share capital with the
issuance of new shares, through a decision by the Board of Directors that is made with a majority of at least two thirds (2/3) of
its total members. In this case, the Company’s share capital may be increased by an amount not exceeding three times the share
6. Explanatory report
336
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
capital the capital existing on the date on which the Board has the power to raise the capital. This power of the Board of Directors
may be renewed by the General Meeting for a period that may not exceed five years per instance of renewal.
b) According to the provisions of article 49 of Law 4548/2018, the Company may, following a relevant decision by the General
Meeting of Shareholders, acquire its shares corresponding to a maximum of 10% of its paid-up share capital. Such decisions by
the General Meeting of Shareholders are implemented by the Board of Directors or the persons to whom the Board of Directors
has delegated the relevant competence.
In implementation of the above provisions the Extraordinary General Meeting of Shareholders dated 23.03.2022 approved to
renew the approval and terms for acquisition of own shares, according to the resolution of the Extraordinary General Meeting
of Shareholders dated 27.03.2020 for an additional twenty-four (24) months period, i.e. until 22.03.2024, with maximum
number of Company shares to be acquired a total of up to 14,289,116, minimum price €0.97 per share and maximum price €25
per share (the “Own Share Buyback Program”) and authorized the Board of Directors to implement the Own Share Buyback
Program. The own shares that the Company holds at any given time (including the own shares that the Company has already
acquired and holds) are intended for any purpose and use permitted by and in compliance with the law (including, indicatively
but without limitation, reduction of share capital and cancellation, or/and distribution to personnel or/and members of the
management of the Company or/and of any affiliated company). The Board of Directors decided on 23.03.2022 to start
implementation of the Own Share Buyback Program by the Company. Further, the Extraordinary General Meeting of
Shareholders dated 10.04.2023 approved the amendment of the maximum acquisition of own shares price for the remaining
duration of the Company's own share acquisition program, i.e. until 22.03.2024, and specifically the increase from €25 to €40.
Finally, the Extraordinary General Meeting of Shareholders dated 27.03.2024 approved to renew the approval and terms for
acquisition of own shares for an additional twenty-four (24) months period, i.e. until 26.03.2026, with maximum number of
Company shares to be acquired a total of up to 14.289.116, minimum price €0,97 per share and maximum price €50 per share
(the “New Own Share Buyback Program”) and authorized the Board of Directors to implement the New Own Share Buyback
Program. The own shares that the Company holds at any given time (including the own shares that the Company has already
acquired and holds) are intended for any purpose and use permitted by and in compliance with the law (including, indicatively
but without limitation, reduction of share capital and cancellation, or/and distribution to personnel or/and members of the
management of the Company or/and of any affiliated company). The Board of Directors decided on 27.03.2024 to start
implementation of the New Own Share Buyback Program by the Company.
During the year 2024:
(a) 908,289 own shares were acquired under the Own Share Buyback Program at a nominal value of €0.97 per share,
representing 0.6357% of the Company’s share capital.
(b) 139,398 own shares were awarded, representing 0.0976% of the Company’s share capital, to executive members of the
board of directors of METLEN or/and key management personnel or/and higher officers of METLEN or/and affiliated companies
pursuant to article 32 of law 4308/2014 or/and persons that provide services to METLEN on a permanent basis.
Moreover, from 01.01.2025 until the publication date 13.03.2025:
(a) 100,428 own shares were acquired under the Own Share Buyback Program at a nominal value of €0.97 per share,
representing 0.0703% of the Company’s share capital.
(b) 2,500,000 own shares, representing 1.75% of the Company’s share capital, were allocated to NORTHBRIDGE GENERAL
INSURANCE CORPORATION, ODYSSEY REINSURANCE COMPANY and ZENITH INSURANCE COMPANY (CANADA), in their capacity
as bondholders due to the exercise of their respective exchange right under the terms of the exchangeable bond loan issued on
07.02.2023 by METLEN.
On the publication date, 13.03.2025, the Company holds in aggregate 2,963,780 own shares, at a nominal value of €0.97 per
share, representing 2.0742% of the Company’s share capital.
IX. Significant agreements put in force, amended or terminated in case of a change in the Company’s control following
a public offer
There are no significant agreements of the Company that become effective, are amended or terminated in the event of change
in the control of the Company following a public offer.
There are however loan and other agreements, which provide, as it is common in such agreements, the right of the lending
banks or bondholders or the Company’s counterparty, to request under certain conditions the early repayment of the
loans/bonds or the termination of the respective agreements in the event of change in the control of the Company, though such
right is not granted specifically in case the change of control in the Company results from a public offer.
6. Explanatory report
337
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
X. Agreement between the Company and BoD members or employees
There is no agreement between the Company and the BoD members or staff providing for the payment of any compensation
specifically in the event of resignation or dismissal without cause, or termination of their mandate or employment as a result of
a Public Acquisition Offer.
7. Statement of Corporate Governance
338
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
This Statement constitutes a special part of the annual Management Report (the “Management Report”) of the Board of Directors
(the “Board”), in accordance with articles 152 and 153 of Law 4548/2018 and relates to the following sections.
METLEN S.A. (the “Company”) as of 01.01.2019, following a relevant resolution of the Company’s Board of Directors on
15.11.2018, aiming at ensuring transparency and responsible operation in all areas of its activity, voluntarily adopted the UK
Corporate Governance Code -2018 (the “Code”). The Code is posted on the Company’s website
https://www.metlengroup.com/who-we-are/governance/corporate-governance/corporate-governance-code/ and on the
website of the Financial Reporting Council, UK [https://www.frc.org.uk/getattachment/88bd8c45-50ea-4841-95b0-
d2f4f48069a2/2018-UK-Corporate-Governance-Code-FINAL.pdf]. According to the Decision No 2/925/28.07.2021 of the Board
of Directors of the Hellenic Capital Market Commission, the Financial Reporting Council is an acknowledged body for the adoption
of a corporate governance code pursuant to Article 17 of the Law 4706/2020 on corporate governance. The Code has been revised
in 2024, especially concerning the Board leadership and company purpose, the composition of the Board with an emphasis on
diversity issues, remuneration, and the Internal Control and Risk Management System. The aim is to ensure the effectiveness of
the Internal Control and Risk Management System by the Board and to conduct at least an annual assessment of their
effectiveness (UK CORPORATE GOVERNANCE CODE – 2024). Except for matters related to the Internal Control System, the other
modifications to the Code are of limited scope. The revised Code will come into effect on January 1, 2025 (with the exception of
the Provision 29 for the Internal Control System and Risk Management, the application of which will start on January 1, 2026).
This means that companies covered by the Code are not required to report on their compliance with the new edition until their
annual reports published in 2026. The Company is already processing the new provisions of the 2024 Code and has conducted an
initial assessment of its compliance level to effectively and timely comply with them in the near future.
Based on the highest international standards of entrepreneurship, the Company strives for closer engagement with its investors,
with the ultimate aim of unlocking further value for its shareholders. Drawing on the best corporate governance practices, the
Company formulates its strategy and develops the general directions, policies, values and principles that govern its operation,
while ensuring transparency and safeguarding the interests of its shareholders. The Company puts emphasis on the integration
of sustainability issues into its operations and strategy.
During 2024, the Company did not comply with provisions 4, 9, 19 and 31 of the Code.
Furthermore, on its own initiative, the Company conducted an assessment of the compatibility of its corporate governance
policies and practices with the 2023 G20/OECD Principles of Corporate Governance. According to this assessment, which was
carried out by an external evaluator, the company’s current policies and practices are fully compatible with all the Principles that
are directly addressed to companies. With this assessment, further documentation is supported in the Sustainability Statement
according to CSRD (Integrated Annual Report 2024, Chapter 2.8).
1.1 BOARD LEADERSHIP AND COMPANY PURPOSE
Principle A: The role of the Board of Directors
The Board sets the tone with regards to the standards of corporate governance. To this end the Board decided to adopt voluntarily
the UK Corporate Governance Code as from 01.01.2019, recognizing that the Code is widely recognized as best standard of
corporate governance.
The Board operates effectively for the longer-term interests and sustainability of the Company. In order to improve its efficiency,
the Board of Directors adopted in 2022 its Terms of Reference, which set out in detail, inter alia, its responsibilities, the general
principles governing its operation, the way it operates, the way of supervision of its executive members, and the way it is
evaluated. The relevant legislation, the Company's Articles of Association, the UK Corporate Governance Code and the relevant
guidance from the Financial Reporting Council (FRC Guidance on Board Effectiveness, 2018) were taken into account in preparing
7. Statement of Corporate Governance
I. COMPLIANCE OF THE COMPANY WITH THE UK CORPORATE GOVERNANCE CODE 2018
7. Statement of Corporate Governance
339
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
the Board Rules. The Board's Terms of Reference will be revised in 2025 to align with the requirements of the United Kingdom's
new 2024 Corporate Governance Code.
The Board is diverse, including adequate gender diversity, and its members possess the appropriate level of knowledge, skills and
expertise required to deliver upon expectations. The Company demonstrates a clear division of responsibilities between
Management and the Board. The executive governance structure, which ensures expedient and good decision-making by the
competent bodies, with full insight and optimal utilization of management time, includes decision preparation and coordination
committees as follows:
a. Cabinet of the CEO, which meets on an ad-hoc basis to discuss the strategy and direction of the Company and monitors
performance,
b. Quarterly Leadership Council, to inform the organization and to identify the future executives,
c. Two (2) Committees, in which specific issues are analyzed:
(i) Monthly Financial Committee, which deals with financial performance and risk, international markets and
capital markets.
(ii) Capital Allocation Committee, which meets whenever capital allocation matters need to be considered.
d. Monthly committees of the Energy and Metals Sectors, which are responsible for guiding the operation and monitoring
the performance of the respective Sector and coordinating the projects identified in the strategic plan.
e. Support Functions Committee, which meets whenever necessary to consider issues related to the provision of support
services to the individual Sectors.
Additionally, the Board of Directors oversees the overall operation of the Company's business model (as presented in Section 2.
Annual Management Report of the Board of Directors, Chapter 2.2 'Strategic Priorities & Business Model) to ensure it remains
sustainable, adaptable to external challenges, and aligned with its strategy and values, thereby strengthening METLEN's ability
to generate and distribute value to its shareholders and Social Partners.
In this context, alongside financial, business, and strategic matters, METLEN’s Board of Directors receives annual updates from
the Sustainability Committee regarding the significant impacts, risks, and opportunities arising from the Company’s activities in
sustainable development. This update includes the results of the impact assessment process, which are approved by the
Sustainability Committee following a recommendation from the Central Directorate of Sustainable Development. It also includes
details on newly implemented policies, key initiatives undertaken, progress on performance indicators, and the achievement of
set goals. Specifically, in 2024, the Sustainability Committee informed the Board of Directors about the following matters:
a) Key Sustainable Development trends, along with an analysis of the challenges they pose for the Company.
b) The current progress of major carbon emission reduction initiatives and, consequently, the Company’s climate targets, as
well as the climate targets review process, which -beyond being a best practice- has become necessary due to the Company’s
intensive growth strategy over the past two years.
c) The Company’s adaptation plan to meet the new sustainability disclosure requirements outlined in the European Union’s
“Corporate Sustainability Reporting Directive (CSRD)”, as transposed into Greek law by Law 5164/2024, ensuring appropriate
measures are taken to mitigate regulatory risks, capitalize on opportunities, and improve the Company's overall performance.
d) The results of consultation with Social Partners, conducted at a central level in 2024, focusing mainly on the positive
(opportunity) or negative (risk) perspectives of Social Partner groups regarding the Company’s sustainable development
management.
e) The highly positive results of the first evaluation cycle of key suppliers based on ESG criteria, which provide a solid
foundation for continuous supplier improvement, enhancing supply chain resilience against future risks such as regulatory
changes or environmental and social crises.
f) The results of the Company's various annual ESG assessments and its overall performance progress, with a focus on its
participation in the DJSI index for the third consecutive year.
g) Digitalization initiatives related to the collection, assessment, composition, and disclosure of sustainability data,
emphasizing the opportunities that new technologies offer to improve operational efficiency and monitor Company
performance.
Regarding the EU Directive (EU) 2024/1760 of the European Parliament and Council, dated June 13, 2024, on corporate
sustainability due diligence (“Corporate Sustainability Due Diligence Directive, CSDDD”), which establishes corporate obligations
related to actual and potential adverse impacts on human rights and the environment arising from their own operations, the
operations of their subsidiaries, and the operations carried out by their business partners in the chains of activities of those
companies, the Board of Directors was informed about the international standards the Company follows. Additionally, the Board
received updates on the ongoing development of a central Due Diligence Policy by the Corporate Governance Division, as part of
7. Statement of Corporate Governance
340
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
the Company's timely preparation for the necessary adaptations required to comply with this Directive when it is incorporated
into Greek law.
Finally, the BoD Finally, the Board of Directors received an update on the results of the socio-economic impact study of METLEN’s
activities in Greece, conducted in 2024 (based on FY2023 data). These results are publicly available on the Company’s website at
the following link:
https://www.metlengroup.com/sustainability/reports/sustainable-development-reporting/?cat=other-reports.
METLEN, as an active member of the local communities in the areas where its core industrial units are based, seeks the long-term
acceptance of its business activities by local societies. Its main priority is to play an active role in their sustainable development,
to the extent of its responsibility. In this direction, the Company has designed and implements specific policies with the following
objectives:
I. Respect for the rights of citizens in local communities neighboring the Company's industrial units, following the key
principles of Human Rights Policy.
II. Promotion of economic prosperity and local development through careful supply chain management, with an emphasis
on supporting local businesses, especially small and medium-sized enterprises. This is ensured within the framework of
the https://www.metlengroup.com/media/ewkhrmwn/policy_cgsd_3_responsible_supply_chain_en.pdf adopted by
the Company in 2023
III. Consistent implementation of its social policy through actions and initiatives that strengthen the coexistence harmony
of METLEN with its local communities and the broader society, following the key principles of the
https://www.metlengroup.com/media/tpynuav0/mytilineos_csr_policy_2022_en.pdf
Principle B: Purpose, values and culture
The Board of Directors approved the Company’s vision, mission and values as part of its strategy. The Company's strategy is
reviewed annually and is the subject of discussion and processing by the Board of Directors. More details are included below,
under Provision 2.
Principle C: Resources, risks and controls
The monitoring of the Internal Control System (ICS) relies on the continuous assessment of its key elements. This is achieved
through the Internal Audit Function and ongoing monitoring activities integrated into the Company's processes. The results of
the ICS assessment are timely communicated to the top and senior management and executives responsible for taking corrective
actions, and to the Board of Directors according to their significance. Following the completion of the ICS assessment in 2023,
the Internal Audit Division monitors the implementation progress of action plans by Business Units and provides quarterly
updates to the Audit Committee. According to its competences, the Audit Committee oversees the internal control and risk
management systems of the Company and monitored the ICS assessment following the COSO 2013 framework (Committee of
Sponsoring Organizations of the Treadway Commission) through reports from the Internal Audit Division. The Audit Committee
also oversees the Compliance function.
Principle D: Shareholder and stakeholder engagement
The relationships and collaboration of the Company with the groups of its Social Partners are integral elements of its strategy for
Sustainable Development. Consultation with the groups of Social Partners, as a corporate institution, is governed by specific
principles and objectives, conducted on an annual basis with absolute consistency, mainly at the local level, addressing
contemporary sustainability issues. The effectiveness and transparency of the process are ensured through the Company's
Sustainable Development Governance System, according to which the individual Sustainability/ESG leaders and owners of the
Business Activity Sectors of METLEN record and evaluate all proposals, ideas, as well as concerns raised by the Social Partners.
Subsequently, the most significant issues are forwarded to the respective General Divisions to make decisions regarding how to
address them. Decisions are made to allow, where feasible, their incorporation into the corporate strategy.
Due to the Company's multi-level business operations, it engages with a broad spectrum of social groups. These diverse groups
are identified and prioritized every 2-3 years and are characterized as “Key Stakeholder Groups” for the Company based on
specific criteria, following the international standard AA1000 Stakeholder Engagement–2015, per Business Activity Sector. The
process of determining the groups of Social Partners was implemented per Business Activity Sector, using the 5 fundamental
7. Statement of Corporate Governance
341
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
criteria (dependence, responsibility, intensity, influence, and perspective) according to the international standard AA1000
Stakeholder Engagement–2015, Based on the results of the internal review exercise of the Company's Social Partner groups
conducted in 2022, the “Key Stakeholder Groups” are categorized as follows:
Category A: High-priority Social Partner groups. This category includes employees, shareholders, customers, local
communities, suppliers, and financial institutions.
Category B: Social Partner groups that encompass regulatory authorities, financial analysts, business organizations,
sustainable development entities, and media.
Category C: Social Partner groups that include non-governmental organizations and the academic community.
The Company’s synergies with its Stakeholders are shaped in the context of the Company's contribution to the Sustainable
Development Goal 17 that seeks to strengthen partnerships to support and achieve the ambitious targets of the 2030 Agenda
without exclusions, built on a common vision, principles and values.
Additionally, METLEN has developed a specific Stakeholders Engagement process. This practice expresses the Company’s long-
standing principle of engaging with its Stakeholders through a systematic and sincere dialogue. As a corporate institution, the
Stakeholders Consultation process, has been carried out consistently annually since 2011 and is subject to self-assessment and
self-improvement procedures.
Within 2024, METLEN conducted at a central level: a) an electronic thematic consultation involving more than 300 key suppliers,
major clients, business organizations, and sustainable development entities. The focus was on gathering their opinions regarding
the publication of the Company's new policy concerning the development of the Responsible Supply Chain, and b) an online
consultation with 36 Non-Profit Organizations with the goal to evaluate existing collaborations and further develop cooperation
for implementing high-social-value programs. Additional information on the Stakeholder Engagement and a detailed analysis of
the relevant results for 2023 are provided a) in the Annual Sustainable Development Report 2023, scheduled for release in June
and available on the Company's website, and b) in https://www.metlengroup.com/sustainability/our-approach/our-relationship-
with-stakeholders/
Furthermore, the social initiatives undertaken by the Company at local level, especially in the category of enhancing local
infrastructure, are closely linked to the needs of each community and the broader region. These initiatives are shaped through
an open dialogue with local social partners. The Company communicates with its local communities in a clear and transparent
manner through the 'open door' policy, primarily implemented in the areas where its industrial units are located.
At the same time, strengthening the constructive relationship it has built over the years with social entities, METLEN implements
a system for managing and evaluating social demands that enhances transparency and ensures the sustainability of its social
investments.
The General Divisions of each Business Sector and subsidiary of METLEN are responsible for managing relationships with the local
communities where they operate. Meanwhile, executives and members of the Company's individual Sustainability/ESG teams
within the Business Sectors manage the implementation of the social policy at local level and support the General Divisions in
managing relationships with local communities.
Principle E: Workforce policies and practices
The Code of Business Conduct of the Company serves as a record of the general principles which define the responsible business
conduct and the ethical rules that all the employees and business partners of METLEN are recommended and expected to follow,
as well as a record of the commitments of the Company’s Management towards its people. The Code ensures that all Company
activities adhere to the principle of integrity, thus safeguarding its reputation, which is its most valuable intangible asset and, as
any other asset, should not only be protected but should also be further developed, by ensuring that the conditions that will
allow this are in place. The Board has last approved the Code of Conduct in November 2019 and since then there has not been
the need for any update. The Audit Committee informs the Board of Directors on any findings the Compliance Division may report
to them.
In 2024, significant progress was made on the “Job Grading Scale” project (METLEN Job Model – ex Organisational Grading). The
goal of this initiative is to address challenges such as the large number of job titles and the need to align the Company’s
organizational structure with the Group’s rapid growth. Specifically, in 2024, the analysis and evaluation of all job positions within
the organization were completed. The expected benefits of the project include the harmonization and calibration of job positions
in accordance with their specific requirements. The next steps involve integrating the Job Model with all Human Resources
policies and procedures, as well as implementing a top-down communication approach once the results are finalized.
7. Statement of Corporate Governance
342
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In 2023, the Board of Directors approved the “Violence and Harassment Policy” of the Company for the prevention and combat
of incidents of violence and harassment in the workplace. The policy was developed, taking into consideration, among other
things, the obligations related to the implementation of the provisions of Part II of Law 4808/2021 for the prevention and
addressing of all forms of violence and harassment, including gender-based violence and harassment, as well as sexual
harassment. Additionally, an internal reporting process for incidents of violence and harassment was established, ensuring safe
and easily accessible communication channels for the reception of complaints. This process facilitates the immediate, timely, and
unbiased handling of such incidents, while simultaneously ensuring the respect for human dignity, confidentiality, and the
protection of personal data of the affected and reported individuals.
METLEN has established a whistleblowing process https://www.metlengroup.com/who-we-are/governance/compliance/ for all
employees to report any violation of the METLEN Code of Business Conduct
https://www.metlengroup.com/media/mqhdwmxw/kodikas_deontologias_omilou_2019_gr_web.pdf even on an anonymous
basis.
All incoming reports are being investigated by the appropriate personnel in confidentiality. METLEN has a non-retaliation policy
for the reporters that submit their reports in good faith.
Additionally, the Remuneration Policy for the Directors contributes to the Company’s business strategy and long-term interests
and sustainability by encouraging the Executive Directors to focus on sustained long-term value creation by providing a fair and
appropriate level of fixed remuneration and a balance of short and long-term incentives to ensure there is focus on short term
objectives that will over time build to create long-term value creation, as well as long-term goals. The remuneration policy is
based on the principle of paying fair and reasonable remuneration for the best and most appropriate person for the role while
ensuring that the Company pays fairly and competitively and in the longer-term interests and sustainability of the Company.
In anticipation of the expiration of the term of the 2019 Board Remuneration Policy, a new Board Remuneration Policy was
approved by the General Meeting of Shareholders on April 10, 2023, in accordance with the Company's Articles of Association,
which stipulates that the Company submits the Remuneration Policy for approval at the General Meeting every four [4] years.
The main changes compared to the Board Remuneration Policy approved by the Regular General Meeting of Shareholders in
2019 concern the establishment of new targets for the long-term incentive program. Additionally, a new peer group of companies
with a similar size and related activities to the Company was created. The Remuneration and Nomination Committee and the
Board of Directors were informed about the broader structure and employee remuneration practices within the Company, which
were taken into account in the formulation and revision of the Policy. The Remuneration Policy is presented briefly in Section
1.5.
The Company aims to apply the principle of Diversity (based, among other basic parameters, on gender, age, experience, skills
and knowledge) to the composition of its Board of Directors, of its executive management team and of all direct employees in all
its activities, where this is feasible. To this end, the Company in its diversity policy sets as its objective the achievement of targets
concerning the representation of women on the board, senior executives and direct employees. The diversity policy is disclosed
in Section 6 together with related targets. In 2024, the gender representation percentage on the Company's Board of Directors
was 25%, in accordance with the Greek Law 4706/2020 on corporate governance. The Company aims to increase this percentage
to 33% in the future, in combination with the enhancement of skills and the composition of the Board. In 2024, significant
progress was made in the revision of the Company’s Diversity, Equity & Inclusion (DEI) Framework & Policy. Key areas of focus
included: the framework and approach adopted by the Human Resources Department, which combines both top-down and
bottom-up approach; the metrics to be included in the policy concerning equity and inclusion; the monitoring process for tracking
the project’s progress; the integration of the Policy with Whistleblowing reports; and best practices for fostering an inclusive
workplace culture.
Finally, in 2023, METLEN conducted its first “Employee Engagement Survey” with the aim of capturing the working environment
and creating an internal communication tool that will help adopt practices and develop a corporate identity and culture. This will
serve as the foundation for implementing its strategic vision to become an “employer of choice”. Detailed information about the
“Employee Engagement Survey” conducted in 2023, as well as its results, is provided below, under Provision 5.
Provision 1. Reporting on actions to generate long-term value
The Board of Directors discusses the Company's strategy and monitors its implementation in each of its meetings, which are held
either in person or by video conference. In-depth analysis and discussion also is conducted at the executive sessions of the Non-
Executive Directors. Additional information is included in the Annual Report of the Board.
7. Statement of Corporate Governance
343
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Provision 2. Monitoring and reporting on culture
The Code of Business Conduct applies to the Board, the management and the workforce. The Board overviews its implementation
and monitoring by acquiring reports and through in person meetings of its Audit Committee with the Internal Audit Director, the
Compliance and GDPR Director and the Non-Financial Enterprise Risk Manager. The reports are related to the controls on the
main parts of the Code that are built to ensure proper implementation. The Audit Committee receives and assesses the reports
and interacts with the Compliance Division if and when it deems appropriate on specific issues.
The Compliance and GDPR Director submitted two semi-annual reports to the Audit Committee in 2024, detailing the review of
all compliance areas. Specifically, these reports included new regulatory changes, new compliance related tools and procedures,
beneficial ownership and declaration of assets activities, conflict of interest reporting, results of the second-line compliance
controls, statistics on the use of reporting channels, the outcome of their clarifications, the acquisition of the ISO 37001
antibribery management system certification, the attestation on the ISO 37002 whistleblowing management systems, and the
attestation on ISO 37008 internal investigations. ISO 37008 attestation has been the first one awarded to a company in Greece.
Additionally, there was information on the employee training program, including the program for the protection of personal data
in accordance with the current framework (GDPR).
Furthermore, periodic compliance controls related to corruption and fraud did not yield significant findings. Τhe GDPR program
was determined to be generally functioning satisfactorily. A more detailed report on the Regulatory Compliance can be found in
the Annual Report of the Audit Committee (Chapter 5 of the Integrated Annual report 2024).
Additionally, to monitor its sustainable development mindset, the Company utilizes key hybrid indicators, which are published
through a dedicated ESG Scorecard on its website ( https://www.metlengroup.com/el/viosimi-anaptiksi/esg-epidoseis/esg-
scorecard/). These indicators primarily track the correlation between the Company's environmental performance and its
economic growth. The stabilization or downward trend of these hybrid indicators signifies that the Company's economic growth
(i.e., the increase in net revenue) is being achieved with less impact on the natural resources used in its operations. This confirms
that the implementation of the business strategy aligns with the Company's commitment to Sustainable Development principles
and responsible practices.
The remuneration policy supports its short and long-term business plan, so as to continue creating value for customers,
shareholders, employees and the Greek economy. The level of fixed pay for Directors is established on the basis of paying no
more than is necessary, always supporting the Company’s longer-term interests and sustainability.
The Policy provides for variable compensation arrangements for Executive Directors to further align the Executive Directors’
interests with those of the Company as the performance conditions used will be based on indicators of the long-term success
and sustainability of the Company. The remuneration policy is disclosed on the Company’s website
https://www.metlengroup.com/who-we-are/governance/corporate-governance/regulations-policies/
The Remuneration Policy is disclosed in Section 1.5.
Provision 3. Engagement with shareholders
The Executive Chairman engages in constructive dialogue and communication with the company's major institutional investors
throughout the year through various means. This includes during the Annual General Meeting, through teleconferences held in
conjunction with semi-annual and annual financial results, during the annual briefing of domestic institutional investors held at
the company's headquarters, as well as in private meetings with key institutional investors, both upon their request and before
significant corporate events initiated by the Company. In 2024, the focus was on various sources contributing to stabilization and
growth of METLEN’s profitability, over 1 billion euros, as well as its main strategic orientation for the future. The Company's
Investor Relations Division participated in thirteen conferences and NDRS in Europe and the USA during 2024. METLEN’s
Chairman participated in some of the above-mentioned events, discussing a wide range of topics, including the Company's short-
term and long-term profitability goals, sustainability issues, and the Company's ESG (Environmental, Social, and Governance)
performance.
Furthermore, throughout the year, several meetings take place for analysts and bank professionals to provide more details
regarding the Company's progress in its plans, long-term strategy, efficiency, and future development planning.
7. Statement of Corporate Governance
344
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Chairman also engages in extensive discussions with questions and answers with minority shareholders during the Annual
General Meeting. Matters of interest to shareholders, if highlighted, are discussed in the Board of Directors. Additionally, the
Lead Independent Director is available to investors.
Finally, the Company ensures to conduct constructive dialogue with shareholders and proxy advisors on corporate governance
matters. Since 2020, this effort has been reinforced by organizing annual targeted Corporate Governance Roadshows. These
events aim to maintain an active dialogue with the stewardship teams of major investors, both before the Annual General
Meeting and throughout the year. The Lead Independent Director, the Chair of the Remuneration and Nomination Committee,
members of the Board of Directors, the Corporate Governance and Sustainable Development Central Function, and the Corporate
Secretary participate in these events.
During 2024, the annual Corporate Governance Roadshow took place, addressing key institutional investors. Discussions covered
various topics, including the Company's performance, its financial results, its organizational restructuring and the purposes it
serves, compliance with the UK Corporate Governance Code, the evaluation of Board committees, which was conducted with the
assistance of external consultants (a different consultant for each committee: Deloitte, PwC, KPMG), including the process and
methodology followed, the Company's performance on sustainability (ESG) matters and its preparation for compliance with the
new EU legal requirements (CSRD, CSDDD), remuneration issues and how the results of the advisory vote by the Shareholders'
General Meeting on June 1, 2023 regarding the annual remuneration report for the year 2022 were considered, the employee
engagement survey and its results, the evaluation of the CEO's performance, the strengthening of the role of the Lead
Independent Director, the appointment of a new female head of the CEO’s Office, the Enterprise Risk Management (ERM)
framework (financial and operational), which was adopted at the initiative of the non-executive Board members, and the
Company’s progressive commitment to Corporate Governance over the past 7 years (with the assistance of external strategic
governance consultants). Additionally, several meetings with institutional investors and proxy advisors were held to discuss
corporate governance matters.
Provision 4. Actions to be taken if significant votes against
The agenda items of the Ordinary General Meeting dated June 4, 2024, with the exception of three, were approved by the
majority of shareholders, with percentages ranging from 99,99% to 96.58%. These percentages significantly exceeded the 80%
threshold of the represented paid-up share capital, as set by the UK Corporate Governance Code. Specifically, regarding the
remuneration report for the year 2023, for which the shareholder vote is advisory according to Article 112 of Law 4548/2018,
the percentage was 59.57% of the represented paid-up share capital. Further, the approval of the amendment of the terms of
the Long-Term Program for Free Distribution of Shares dated 15.06.2021, and the free distribution of an additional 37,287 own
shares, in accordance with article 114 of law 4548/2020 received a percentage of 76,28%, and the amendment of Article 1 of the
Company’s articles of association, regarding the change of the corporate name received a percentage of 65,39%.
In accordance with the decisions of the Ordinary General Meeting dated June 4, 2024, the Board of Directors takes the results of
the advisory vote on the third item, as well as the voting results on the other aforementioned matters, very seriously and is
working with shareholders to ensure that their feedback is duly assessed. The Company takes further action in accordance with
the Corporate Governance provisions it has adopted and implements. The Board remains committed to achieving the highest
governance standards while also recognizing the importance of providing appropriate incentives to the Board and the Executive
Management in alignment with the Company’s strategic objectives.
In this context, in accordance with Provision 4 of the UK Corporate Governance Code, following the Annual General Meeting,
meetings were conducted during the annual Corporate Governance Roadshow of 2024 with the shareholder engagement
departments of significant institutional investors of the Company. One of the main topics of discussion, as previously mentioned
(under Provision 3), was Agenda Item 3 of the Annual General Meeting held on June 1, 2023, concerning the 2023 Remuneration
Report (with a voting percentage of 65.90%). This report pertained to the year 2022 and was subject to an advisory vote. The
outcomes of the dialogue are included in the 2024 Remuneration Report. Similarly, regarding the items of the General Meeting
held on June 4, 2024, for which the voting percentages were below the 80% threshold of the represented paid-up share capital,
as set by the UK Corporate Governance Code, a thorough discussion will take place as part of the Corporate Governance
Roadshow 2025.
Provision 5. Engagement with stakeholders and workforce representation
7. Statement of Corporate Governance
345
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Account of how the Board takes into account the interests of various stakeholders’ groups is provided in the Sustainability
Statement, section “Interests and views of stakeholders” (Annual Integrated Report 2024, chapter 2.8). As part of its engagement
process METLEN has developed a specific Stakeholders Consultation process https://www.metlengroup.com/sustainability/our-
approach/our-relationship-with-stakeholders/. This practice expresses the Company’s long-standing principle to engage with its
Stakeholders through a systematic and sincere dialogue. As a corporate institution, the Stakeholders Consultation process, has
been carried out consistently on annual basis since 2011 and is subject to self-assessment and self-improvement procedures.
The Materiality process, i.e. the process of identifying, understanding and prioritizing the sustainability issues, is one of the key
elements in the Company’s responsible operation. Τhe 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. The workforce participates in the
process of determining the material Sustainable Development topics through a relevant Social Partner survey that was carried
out in 2022 and takes place every two years based on the official METLEN process.
As part of the Social Partners Consultation process for the year 2024, the questionnaire was sent electronically to 10 groups of
the Company's social partners, achieving a participation rate of 32.1% (specifically, 1,121 individuals were invited to participate,
and 360 responded).
Key findings from the consultation include the observation that the established mechanisms are functioning satisfactorily, and
that the Company's performance has improved significantly compared to three years ago. Notably, 8 out of 10 respondents
reported being fairly to highly informed about the Company’s sustainability strategy and initiatives and expressed satisfaction
with how these initiatives are communicated to them. Additionally, challenges that are already core areas of the Company’s
activities -such as safe and productive employment, sustainable industrial operations, the protection of natural resources and
biodiversity, and addressing climate change- were rated as highly significant by a large majority of participants.
Furthermore, the 2024 consultation conducted under the framework of the “Annual Stakeholder Consultation Initiative” was
based on the Company’s new Responsible Supply Chain Policy. The primary objective was to gather key suppliers' views on this
policy and assess their readiness to meet their commitments. According to the consultation findings, among other insights, 9 out
of 10 of the Company's suppliers affirmed their commitment to responsible business conduct as METLEN suppliers, while 8 out
of 10 stated that they have already implemented monitoring practices across their operations to ensure comprehensive Human
Rights protection, including measures against human trafficking and modern slavery.
METLEN, in order to determine the social value generated by its investments in key social programs, applies the international,
widely accepted Social Return on Investment (SROI) methodology. This involves a holistic approach through which the Company
calculates the impact it creates and makes informed decisions with the aim of maximizing the value returned by the investment
made for each social program. The SROI methodology measures the social value of a program, stemming from the experiences
of those directly involved, i.e., the changes they undergo in their lives, using economic terms as a common denominator to
express this value. More information is available in the Sustainable Development Report under CSRD.
For the purpose of setting remuneration, the Remuneration and Nomination Committee and the Board of Directors receive
periodic updates on the wider employee remuneration structure and practices within the Company, which are considered when
establishing and revisiting the Remuneration Policy. In addition, the Remuneration and Nomination Committee and Board of
Directors are provided with information on remuneration trends across the Company including average pay increases along with
any relevant economic data, such as the rate of inflation to take into account when operating the Policy.
In 2023, METLEN conducted its first “employee engagement survey" ("Survey") with the assistance of an external consultant
(Great Place to Work) and based on industry best practices. The Company aimed to capture the work environment through this
Survey and create an internal communication tool that would help in adopting practices and developing a corporate identity and
culture. This would serve as the foundation for implementing its vision to become an "employer of choice." The following stages
were followed for the execution of the Survey:
(1) Measurement and monitoring of employee engagement as a key factor for high performance.
(2) Providing METLEN employees with a mechanism to actively participate in shaping the work environment and culture.
(3) Enhancing understanding between executives and staff regarding how METLEN can better engage its people, thus
achieving improved results through increased productivity, continuous exploration of more effective and efficient work
methods, and innovation.
(4) Guiding focused administrative action across organizational business sectors of METLEN.
7. Statement of Corporate Governance
346
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
During 2024, the Remuneration and Nomination Committee and the Board conducted an in-depth discussion on the results of
the first “employee engagement survey”, The Survey focused on 5 issues: Credibility, Respect, Fairness, Pride and Camaraderie.
The results of the survey, which achieved an 80% response rate, were assessed in comparison to leading European companies
(>500 employees) with the best workplace environments in Europe. The vision of METLEN is to become an Employer of Choice
by 2025. Discussions within the Remuneration and Nomination Committee and the Board focused on areas identified in the
survey results as needing improvement. It was decided that an action plan would be developed and monitored by the Human
Resources Department to address these areas. Indicative topics included job grading, performance management, and the
integration of acquired companies.
Additionally, the planning of the next steps was discussed, which includes presenting the survey results to employees, conducting
workshops with senior executives (Chiefs and Senior Executives), budgeting for the implementation of the action plan, and
regularly monitoring its progress.
Provision 6. Whistleblowing
The Company encourages and expects its employees to report serious violations of the Code of Business Conduct, when they
become aware of them or when these are brought to their attention. The issues to be reported fall within the scope of Law
4990/2022 (public contracts, financial services, products and markets, including fraud prevention, corruption, and other illegal
activities, as well as the prevention of money laundering from illegal activities and the financing of terrorism, security and
compliance of products, transportation security and compliance, environmental protection, public health, consumer protection,
privacy and personal data protection, network and information systems security, radiation protection, nuclear safety, food safety,
health, and the well-being of animals), economic interests of the Union, issues regarding the free movement of goods, persons,
services, and capital, as well as issues covered by Law 4808/2021 for the prevention and combat of violence and harassment in
the workplace.
Reports may be submitted by individuals associated with the Company in any current, former, or prospective employment
relationship, as well as by anyone working under the supervision and management of contractors, subcontractors, and suppliers
of the Company. To receive and record these reports, the Company has established four reporting channels (through a platform,
via email, by phone, and through regular mail) for the submission of named or anonymous reports.
All reports are initially checked for their credibility, and in affirmative cases, they are assigned to the competent superior for
clarification and investigation. Subsequently, the reporter is informed of the outcome, and if deemed necessary, further actions
are taken, such as corrective activities or disciplinary measures.
During 2024, the Compliance and GDPR Director presented statistics to the Board of Directors' Audit Committee for each
semester regarding incoming reports, investigation results, and subsequent actions. Specifically, during 2024, a small number of
reports were received, and they were investigated. The investigation revealed that some allegations were not substantiated,
while the findings for remaining ones were not material.
Provision 7. Conflicts of interest
Each member of the Board has a duty of loyalty to the Company. Board members act with integrity and in the Company’s interests
and safeguard the confidentiality of information that is not publicly available. They must not have a relationship of competition
with the Company and should avoid any position or activity that creates or appears to create a conflict between their personal
interests and those of the Company in accordance with the legislation and its Articles of Association.
During 2021, the Company adopted a separate Conflict of Interest policy and procedure, elaborating further the relevant section
of the Code of Business Conduct of the Company. More information on the Policy and Procedures on Conflicts of Interest, which
has been approved by the Board of Directors by its resolution dated 15/06/2021 is available in Section 2.3.
Subsequently, in 2022, the Company adopted the “Policy and Procedure for Related Party Transactions”, taking into account both
the legislative framework and the UK Corporate Governance Code. Conflicts of interest arising, especially in relation to related
party transactions, are regulated based on this policy. Further information on this process, which has been approved by the
Board, is available in Section 7.
The Internal Audit Division reports to the Audit Committee any cases of conflict of the private interests of Board members with
the interests of the Company, which (cases) it ascertains in the performance of their duties.
Additionally, within 2024, the Internal Audit Division, in collaboration with the Compliance Division as well as the Corporate
Governance Division, leveraged available open governance data. Using external provider software, it analyzed, monitored, and
investigated any potential conflicts of interest with the aim of resolving them appropriately. No material conflicts of interest were
identified.
7. Statement of Corporate Governance
347
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Provision 8. Director concerns and resignations
Pursuant to the Company’s Articles of Association (available on the website) and Greek Company Law 4548/2018 on the request
of a member of the Board of Directors, the Chairman is required to record in the minutes a summary of such member’s opinion.
Pursuant to the Terms of Reference of the Board of Directors, approved in 2022, when Board members have concerns about the
operation of the Board or the management of the Company that cannot be resolved, their concerns should be recorded in the
minutes of the Board. It is also explicitly provided that where a Non-Executive Board member resigns, that member may, if he/she
has any such concerns, submit a relevant written statement to the Board Chair, for circulation to the Board.
1.2. DIVISION OF RESPONSIBILITIES
Principle F: The role of the Chair
The Chair of the Board has according to the Terms of Reference of the Board of Directors, approved in 2022, the following
responsibilities and obligations:
i. Leads the Board and is responsible for its overall effectiveness in directing the Company. The Chair should
demonstrate objective judgement throughout his/her tenure and promote a culture of openness and debate.
ii. Coordinates, convenes and chairs the Board meetings, introduces the items to be discussed, directs the Board’s work
and is responsible for ensuring the timely and clear information of the Board members.
iii. Seeks regular engagement with major shareholders in order to understand their views on the Company’s governance
and performance against the strategy, while at the same time ensuring that the Board as a whole has a clear
understanding of the shareholders' views.
iv. Demonstrates objective judgement and promotes communication, fosters the development of constructive relations
within the Board, and encourages the effective contribution and active participation of the Board’s non-executive
members.
v. Encourages and promotes the open exchange of views in a spirit of constructive challenge and ensures that any
diverging views are voiced and discussed at the Board level as part of the decision-making process.
vi. Determines, with the assistance of the Company Secretary, the agenda of the Board meetings and ensures that issues
of strategic importance are discussed as a priority.
vii. Is responsible for the adoption of appropriate corporate governance standards across the Company.
Principle G: Board balance and decision-making
The Board has 13 members. Of these: a) four members, namely the Chair & CEO, the Vice Chair B and two other members are
Company executives, b) Vice Chair A’ is non-executive and c) eight members are independent non-executive. More information
is provided below, under Provision 18.
Both Board committees, the Audit Committee and the Remuneration and Nomination Committee, are completely independent.
The separation of responsibilities between the executive management and the Board of Directors is clear, as described in the
Company’s Internal Regulation https://www.metlengroup.com/media/gvmjhr3v/en_mytilineos_internal_regulation.pdf and the
Terms of Reference of the Board of Directors. Prevention of excessive burden arising from the professional commitments of the
members, outside the Company, is regulated in the Policy for the Suitability Assessment of the Board of Directors of the Company
and the Terms of Reference of the Board of Directors and falls within the competence of the Remuneration and Nomination
Committee.
Non-executive Board members’ other assignments are considered at the nomination process as to avoid over-boarding and
reviewed every year by the Remuneration and Nomination committee. Other appointments and commitments are reported in
Section 2.1.9.
Principle H: The role of non-executive directors
The Non-Executive Members of the Board do not have executive responsibilities regarding the management of the Company
within their remit, beyond the general duties stemming from their capacity as Board members and have been entrusted with the
role of systematic supervision and monitoring of Management’s decision-making.
According to the Policy for the Suitability Assessment of the Members of the Board of Directors of the Company, which was
approved by resolution of the AGM of METLEN, dated 15 June 2021, and the Terms of Reference of the Board of Directors,
7. Statement of Corporate Governance
348
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
approved in 2022, Board members should not sit in the boards of directors of more than five (5) companies whose shares are
traded in a regulated market. The Terms of Reference of the Board of Directors also provide that assumption of any significant
external commitments by existing non-executive members of the Board, such as, but not limited to, directorships in other listed
companies, may not be made without the prior approval of the Board of Directors.
The Board Profile matrix is reported in Section 2.2 and the biographies of each individual Board member are available in Section
8.
More information on the role of non-executive directors is available under Provision 13.
Principle I: Board policies and processes
The Board of Directors has appointed the Corporate Governance Director of the Company as Company Secretary so to have the
necessary guidance and advice on corporate governance issues. The Board and its committees worked together with the
Company Secretary during 2024 on all corporate governance matters within their scope, including their operation.
In 2025, the Board of Directors' Terms of Reference and the Terms of Reference of its Committees will be evaluated to assess
their alignment with the new 2024 UK Corporate Governance Code. If deemed necessary, revisions will be made accordingly.
Provision 9. Chair and Chief Executive
The Board Chair is also the CEO of the Company. The Board evaluates the topic of split vs dual role for the Chair/CEO position.
The dual role under the founder of the Company Mr. Mytilineos has helped the Company streamline its operating model and
leverage synergies between its different Business Sectors as well as delivering outstanding results. Following the outstanding
performance in the previous years, METLEN achieved a high profit in 2024, despite the exceptionally unstable and uncertain
global economic environment.
Given his unique experience and leadership capacity, the Company's Founder, Mr. Mytilineos will continue to play a critical.
Given the dual role, the Company has introduced a number of initiatives to ensure an elevated level of independence which
include:
- appointment of the Lead Independent Director with the purpose of providing guidance to the Board of Directors due to
the fact that the roles of the CEO and the Chairman coincide in the same individual;
- ensuring a majority- independent Board;
- participation of exclusively independent non-executive members in the committees of the Board of Directors;
- strengthening of the Compliance processes, under the Audit Committee and
- launching a Succession Planning exercise to ensure initiatives to enhance the Group’s organisational and process
capabilities are accelerated.
Provision 10. Independence of directors
Independent non-executive Board members are approved as such by the shareholders at the time they stand for election. As
noted above, under Principle G, eight out of thirteen Board members are Independent Non-Executive Directors. Specifically, the
Independent Non-Executive Members are the following:
- Panayiota Antonakou,
- Anthony Bartzokas,
- Emmanouil Kakaras,
- Polyxeni (Xenia) Kazoli (she was elected by the General Meeting of 4 June 2024).
- Konstantina Mavraki,
- Natalia Nicolaidis,
- Ioannis Petrides,
- Alexios Pilavios.
More information on the Independent Non-Executive Members of the Board of Directors is available in Section 2.2 and in Section
8. Independent non-executive members at the time of their appointment and during their term of office, do not hold, directly or
indirectly, a percentage of voting rights greater than zero-point five percent (0.5%) of the Company's share capital and do not
maintain any economic, business, family or other kind of dependency relationship, which may influence their decisions and affect
their independent and objective judgment.
In that sense, a dependency relationship, shall exist, indicatively, in the following cases:
7. Statement of Corporate Governance
349
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
a) Where the Board member receives any remuneration or allowance by the Company, or by a related company, or
participates in a share option scheme or any other remuneration or allowance scheme related to the performance,
except for fees received for the member’s participation in the Board or its committees, in accordance with the
Remuneration Policy of the Company;
b) Where the Board member or any person closely associated with it, has or has had (directly or indirectly through
participation in another entity), within the last three (3) financial years from the Board member’s appointment, a
business relationship with the Company, or a person related to the Company, or a shareholder who holds, directly or
indirectly, at least ten percent (10%) of the share capital of the Company or of a related company during the last three
(3) financial years prior to the Board member’s appointment, provided that such relationship affects or is likely to
affect the business activity of either the Company, the Board member concerned, or the person closely associated
with it. Such a relationship shall exist in particular when the person concerned is a significant supplier or customer of
the Company.
c) Where the Board member or any person closely associated with it:
i. has served as member of the Board of the Company or of a related company for more than nine (9)
financial years from the date of the Board member’s first appointment;
ii. has been a manager, or employee, or partner under service contract or mandate under paid mandate
contract, of the Company or a related company, within the last five (5) financial years prior to the Board
member’s appointment;
iii. is related up to the second degree by blood or marriage, or is the spouse or partner equivalent to a
spouse, of a member of the Board of Directors or a senior manager or shareholder, with a percentage
equal to or exceeding 10% of the share capital of the Company or an affiliated company;
iv. has been appointed directly by a shareholder of the Company;
v. represents shareholders holding, directly or indirectly, equal or more than five percent (5%) of the
Company’s voting rights at the General Meeting of the Company's shareholders during his/her term of
office, without written instructions;
vi. has conducted a statutory audit in the Company or in a related company, either through a company or
himself or a relative of his up to the second degree by blood or marriage or his spouse, during the last
three (3) financial years before the Board member’s appointment;
vii. is an executive board member in another company, in whose board an executive member of the
Company participates as a non-executive member.
The criteria by which Board members’ independence is assessed are determined in detail in the Company’s Policy on Board
Members’ Independence, which also establishes the procedure and rules to be followed, on the one hand, for notifying any
dependency relationship of the independent Board members and of the persons closely associated with them; and, on the other
hand, for assessing the fulfilment of independence criteria.
The Independent Non-Executive members of the Board may submit, jointly or separately, reports to the General Meeting
(ordinary or extraordinary) of the Company, independently of the reports submitted by the Board of Directors. Such reports shall
include, as a minimum, the following:
(a) monitoring and reviewing the Company's strategy and its implementation and the achievement of its objectives,
(b) ensuring effective supervision of the executive members of the Board, including monitoring and reviewing their
performance,
(c) considering and expressing views on proposals made by executive members of the Board on the basis of existing
information.
The Report The Report of the Independent Non Executive Members of the Board of Directors to the Ordinary General Meeting
of Shareholders of 04.06.2024, is available on the website of the Company
https://www.metlengroup.com/media/nkpdvzga/thema_5_ekthesi_aneksartitwn_melwn_ds_2023.pdf).
It is in the Remuneration and Nomination Committee's remit to review the independence of the non- executive directors before
nomination and to this end it adopted in 2022 a specific Procedure for the Determination and Assessment of the Independence
Criteria of Board Members and Disclosure of the Dependency Relationships. Specifically, the Remuneration and Nomination
Committee reviews:
- the balance of the number of independent non-executive directors;
7. Statement of Corporate Governance
350
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
- the length of service of independent non-executive directors;
- any situational conflict which a director may have with the interests of the Group and
- any other relevant matter.
As of 2019 the Remuneration and Nomination Committee reviews the independence of Board members annually.
Provision 11. Half the board to be independent
On 31.12.2024 the Board of Directors consisted of 13 members, eight (62%) of whom were independent. At the AGM of 2 June
2022, the shareholders approved the re-appointment and the appointment as independent non-executive members of the Board
of Directors of: a) Panayiota Antonakou, b) Anthony Bartzokas c) Emmanouil Kakaras, d) Konstantina Mavraki, d), e) Natalia
Nicolaidis, f) Ioannis Petrides, and g) Alexios Pilavios.
During the AGM of 4 June 2024, the shareholders elected Mrs. Polyxeni (Xenia) Kazoli as independent board member, with term
of office until 02.06.2026.
The Board of Directors confirmed to both General Meetings that they meet the independence criteria of article 9 of Law
4706/2020, as well as the independence criteria provided for in the approved Policy on the Suitability of Board Members, the
Policy on the Independence of Board Members and the Procedure for the Determination and Assessment of the Independence
Criteria of Board Members and Disclosure of the Dependency Relationships.
Provision 12. Lead Independent Director
Pursuant to the Terms of Reference of the Board of Directors, approved in 2022, the Board of Directors shall appoint one of its
independent non-executive members as “Lead Independent Director”, who has the following responsibilities and obligations:
(a) Is charged with coordinating the non-executive members and chairing their meetings.
(b) chairs the procedure concerning the evaluation of the Board Chair by the Board members.
(c) Proposes to the Board Chair topics for discussion and informs the Board Chair of the important issues
raised by the non-executive members in their meetings, also discussing them with the Chair.
(d) Is available and attends the General Meetings to discuss corporate governance issues, as and when the
need arises.
Where the Chair is a non-independent Board Member or where the Chair is also the CEO of the Company, the Lead
Independent Director:
(a) Is charged with coordinating the executive and non-executive members of the Board and ensuring
effective communication between them.
(b) Leads the shareholder engagement process with the stewardship teams of investors.
(c) May, whenever deemed appropriate, meet privately with senior management involved in the governance
of the Company, including the CEO, to be informed about or discuss specific issues.
(d) Is expected to work closely with the Board Chair and the other Board members and/or the shareholders,
to resolve significant issues and ensure stability (indicatively, in cases where shareholders or non-executive
members of the Board have expressed concerns that have not been addressed by the Board Chair, or
where the Company's strategy is not supported by the entire Board or the Board’s succession planning is
being ignored).
Provision 13. Role of non-executive directors
The non-executive members of the Board, including the independent non-executive members, act in a supportive manner to
improve the Board’s functioning based on their knowledge and experience. In particular, they have the following obligations:
a. To monitor and review the Company’s strategy and its implementation, as well as the achievement of its objectives.
b. To ensure effective supervision of the executive members, including monitoring and reviewing their performance at
individual and collective level.
c. To consider and express views on proposals submitted by the executive members, based on existing information, and
to participate constructively and critically in the Board’s decision-making.
7. Statement of Corporate Governance
351
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
d. To provide strategic guidance and expert advice based on their knowledge and experience, and to hold senior
management accountable when they deem it appropriate.
e. To participate (the independent non-executive members), according to their area of responsibility, in the Audit
Committee and the Remuneration and Nomination Committee, as well as in any other committee in which their
participation is provided for by law or is deemed necessary. The Non-Executive Members met during 2024 under the
chairmanship of the Lead Independent Director without the presence of the Executive Members five times according
to a schedule set at the beginning of the year. At the separate meetings they hold, the Non-Executive Members:
- evaluate the performance of the Chair and of the executive members and senior management against the
performance targets set for them;
- discuss the Board’s modus operandi;
- examine in detail the strategy of the Business Units, as well as general strategic issues;
- discuss important organizational issues of the Company;
- are informed of and discuss important regulatory developments affecting the Company;
- are informed of and discuss developments regarding corporate governance and consider their impact on
the Company.
The Non-Executive Board members may at their discretion invite, whenever deemed appropriate, senior management involved
in the Company’s governance, including the CEO, to be informed about or discuss specific items on the agenda.
The activity of the Non-Executive Directors in 2024 is described more specifically in Section 2.5.
Provision 14. Written responsibilities and attendance
The roles and responsibilities of the Chair, CEO, Lead Independent Director and Board committees are included in the Company’s
Articles of Association which have been approved by the shareholders at the 2019 AGM, as in force, the Terms of Reference of
the Board of Directors, approved in 2022 and the Terms of Reference of the Board Committees. Furthermore the aforementioned
roles and responsibilities are part of the company’s Internal Regulation which also include internal policies and processes. The
Terms of Reference of the Board committees which portray the remit, the functioning, and the reporting responsibilities of the
committees in detail, are approved by the Board and can be seen on Company’s website.
Also details of meetings, agendas and individual attendance of directors during the year are reported under the relevant
provisions in this document, i.e. under Provision 23, Provision 41, Section 2.4 and the Annual Report of the Audit Committee in
Chapter 5 of the Integrated Annual Report for the year 2024. The responsibilities of the Chair are described in detail under
Principle F, the Chief Executive Officer under Section 2.1, the Vice Chairmen of the Board under Section 2.1 and the Lead
Independent Director under Provision 12.
Provision 15. Other appointments
Board members must have sufficient time to perform their duties in accordance with the Policy for the Suitability Assessment of
the Members of the Board of Directors. Pursuant to the Terms of Reference of the Board of Directors, irrespective of any
permission granted by the General Meeting, the Board members should not sit in the boards of directors of more than five (5)
companies whose shares are traded in a regulated market.
When appointing its new members, the Board should also take into account any other commitments/requirements affecting the
availability of future Board members. Candidate Board members must notify the Board of their significant commitments, if any,
prior to their appointment, also stating the corresponding time required for those commitments, so that the Board considers any
external professional commitments before nominating candidates for election by the General Meeting of Shareholders. Similarly,
the assumption of any significant external commitments by existing non-executive members of the Board, such as, but not limited
to, directorships in other listed companies, may not be made without the prior approval of the Board.
Before acquiring any additional position in boards of other entities, every member must consider the necessary time they should
devote for discharging their duties as a member properly, which (time) should in no case be impaired.
The Board considers all external commitments of executive and non-executive directors including the not-for-profit ones. No
director holds more than five external appointments. With the exception of the CEO, two executive directors hold positions in
non-listed companies none of whom is the CEO.
7. Statement of Corporate Governance
352
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Full list of other appointments is available in Section 2.1.9.
Provision 16. Company secretary
The Βoard has appointed the Company's Corporate Governance Director as Company Secretary. According to the Terms of
Reference of the Board of Directors, the Company Secretary has the following responsibilities:
- ensuring compliance with the Board's procedures and advising the Board Chair and Board members, as well as the Board
committees, on all corporate governance matters , in accordance with the applicable legislation and the Corporate
Governance Code that the Company applies;
- ensuring the effective flow of information between the Board and its committees, as well as between the Senior
Management and the Board;
- providing comprehensive practical support and guidance to Board members at both an individual and collective level,
with particular emphasis on supporting non-executive members.
- planning the induction training programme for newly elected Board members immediately after their election, including
the assessment of any special training needs of Board members, and facilitating their training.
- highlighting issues that may require the attention of the Board.
The Corporate Secretary also provides guidance to the Board of Directors regarding the Company's compliance with the UK
Corporate Governance Code and relevant regulations, including the composition of the Board and its committees.
1.3 COMPOSITION, SUCCESSION AND EVALUATION
Principle J: Board appointments and succession planning
The Remuneration and Nomination Committee is responsible for making recommendations to the Board on appointments
against objective criteria and with due regard for the benefits of diversity on the Board, including gender, breadth of experience,
amongst other criteria, in accordance with the Policy for the Suitability Assessment of the Members of the Board of Directors of
METLEN, which was approved by the AGM on 15 June 2021. It is in the Committee’s remit to prepare a description of the role,
capabilities and personal attributes required for a particular appointment; to develop criteria for identifying and evaluating
director candidates. Also it is part of the Committee’s remit to care for the orderly succession and make recommendations for
appointment and reappointment by the Board of both executive directors and independent non-executive directors.
The first ever formal succession planning exercise was completed in late 2021 with facilitation provided by Egon Zehnder. Among
other, the purpose of the project was to record the set of skills that would be required in the future to meet the needs of a
growing, complex, and internationalized business. The results of this project were evaluated and taken into account for the new
organizational structure of the Company (Big Two), which was completed in January 2023.
Specifically, by decision of the Board of Directors on January 10, 2023, the new organizational structure of the Company was
unanimously approved with retroactive effect of the new organizational chart from January 1, 2023. This structure aligns with
the current needs of the Company, harmonizes with its new strategy, and strengthens the synergies of its business model. Based
on the new organizational structure, the Company has two (2) business sectors:
(a) the Energy Sector, led by Giannis Kalafatas - Chief Executive Director, Energy, and
(b) the Metals Sector, led by Dimitris Stefanidis - Chief Executive Director, Metallurgy.
The top and senior management of the Company are completed by:
- Evangelos Chrysafis, Vice-Chairman and executive member of the Board of Directors for Regulatory and Strategic
Energy and Infrastructure Matters;
- Christos Gavalas, executive member of the Board of Directors and Chief Treasury & IR Officer with a supervisory role
on the financial matters of the Company;
- Eleftheria Kontogianni, Chief Finance Officer;
- Elenos Karaindros, Chief Strategy and M&A Officer;
- Vivian Bouzali, Chief Corporate Affairs & Communication Officer;
- Sara Fideli, Chief People Officer;
- Petros Selekos, Chief Legal Officer;
- Dimitris Papadopoulos, executive member of the Board of Directors and Chief Corporate Governance & Sustainable
Development Officer;
7. Statement of Corporate Governance
353
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
- Fotios Spyrakos, Chief Administration Officer & Head of CEO’s Office;
- Foteini Ioannou, Chief of Staff.
Additionally, in 2023, the Company implemented a new performance management system for a better assessment of the
performance and capabilities of key executives as part of the succession planning exercise. This also includes a revised
management process through the establishment of a committee to improve empowerment, accountability, and decentralization.
To strengthen succession planning, the Company has also created a list of potential external high-caliber candidates in case of
need.
Succession planning is included among the objectives of the CEO, as reflected in his annual personal goals. The comments from
corporate governance roadshows with the company's key investors are taken into account in the succession planning process.
Principle K: Skills, experience and knowledge
It is up to the Remuneration and Nomination Committee to make recommendations for approval by the Board of the membership
of Board committees. The Board skill matrix is available in Section 2.2.
The table with the CVs of the Board members is available in Section 8.
Principle L: Board and director evaluation
It is in the Remuneration and Nomination Committee’s remit to establish and oversee an objective and rigorous evaluation
process of the Board and committees of the Board. The Chair of the Committee has overall responsibility for the process and
should involve the Board Vice Chair A’ and the Lead Independent Director as appropriate; the Board Vice Chair A’ leads the
process that evaluates the Βoard and the Lead Independent Director leads the process that evaluates the Chair of the Board.
Board, committee and individual Βoard and committee members evaluations shall take place every year and externally facilitated
every three or sooner and the outcomes of Board evaluation shall be shared and discussed with the Board and inform and
influence the succession process.
In 2024, the Board conducted its first self-assessment regarding the effectiveness of its operations. This followed previous
evaluations:
a) The collective suitability assessment of the Board, completed in 2020, carried out by the external consultant EgonZehnder. b)
The assessment of individual competencies and contributions of the Board, completed in 2022, carried out by the external
consultant Egon Zehnder. c) The evaluation of the Board committees, completed in 2023, which were carried out by external
consultants (KPMG, PwC, Deloitte).
Additionally, in 2024, an evaluation of the Board’s suitability was conducted at both an individual and collective level, regarding
the fulfillment of gender representation requirements, the total number of independent non-executive members, and suitability
criteria in accordance with the legal framework and the “POLICY FOR THE SUITABILITY ASSESSMENT OF THE MEMBERS OF THE
BOARD OF DIRECTORS”.
Throughout 2024, the results of these evaluations were extensively discussed at the relevant committees and Board level,
including the Nomination and Remuneration Committee, the Audit Committee, and the Sustainability Committee.
Further details on these evaluations can be found below, under Provisions 21, 23, and in Section 5 of the Integrated Annual
report.
Provision 17. Nomination committee
The Company has a combined Remuneration and Nomination Committee which examines and processes issues pertaining to: (a)
the remuneration of Board members and of senior and other executives; and (b) the suitability of existing and candidate directors,
within the scope of its remit under its Terms of Reference. The Committee revisited its Terms of Reference, which were approved
and put into effect by the Resolution of the Board of Directors dated 26.07.2021, following relevant proposals submitted by the
Committee.
Details on the composition, tenure, functioning, decision-making and meetings of the combined Committee are available under
Provision 32.
7. Statement of Corporate Governance
354
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The nomination responsibilities of the Committee include the following:
i. to review the independence of the non-executive Directors;
ii. to develop meritocratic and objective criteria for identifying and evaluating candidate Directors in accordance with
the Policy for the Suitability Assessment of the Members of the Board, as well as for assessing and planning the
succession of Directors, and to describe the role, knowledge, skills, experience, abilities and the required personal
attributes of a specific candidate Director;
iii. to make recommendations to the Board on the appointment of Directors against objective criteria;
iv. to plan for the orderly succession of the Directors and senior executives and make recommendations to the Board;
v. to establish and oversee an objective and rigorous evaluation process of the Board and Board Committees, including
assessing suitability at individual and collective level;
vi. to oversee the induction process of new Directors and their ongoing training in accordance with the relevant Training
Policy that the Company has adopted and applies;
vii. to regularly assess and review the Board’ s size, structure, composition and operation and, if it identifies weaknesses,
to recommend to the Board relevant changes as appropriate;
viii. to be responsible for drawing up the Company’s Policy for the Suitability Assessment of the Members of the Board,
which shall then be submitted to the Board for its approval, as well as any amendments thereof.
Provision 18. Director election
The current Board, with the exception of two members, was appointed by the 2022 AGM for a four-year term until 02.06.2026.
Nominees were submitted unbundled to the General Meeting of the Shareholders of 2022 for approval.
Furthermore, by decision of the Ordinary General Meeting of the Company, held on June 1, 2023, Mr. Christos Gavalas was
elected as a member of the Board of Directors, with a term until June 2, 2026. During its meeting on June 1, 2023, the Board
appointed Mr. Christos Gavalas as an executive member, while by decision of the Ordinary General Meeting of the Company,
held on June, 4, 2024, Mrs. Polyxeni (Xenia) Kazoli was elected as independent non-executive board member, with a term until
02.06.2026.
Pursuant to Article 19(2) of the Company’s Articles of Association, Board Members are elected by the General Meeting of
Shareholders of the Company for a term of four (4) years, to be extended until the expiration of the time period within which the
immediately next Ordinary General Meeting is to be held and until the adoption of the relevant resolution. In the Greek market,
there is a long-standing tradition that members of the Boards of Directors of listed companies are elected for a term of more
than one year, mainly for reasons of ensuring the smoothness and continuity of management in companies, as well as to avoid
additional administrative burden. However, the General Meeting of Shareholders of the Company reserves in any case the right
to recall, whenever it wishes or deems appropriate, the Board of Directors in whole or in part. In addition, every year, an
assessment of the Board of Directors is carried out both at individual and collective level as well as a control on the fulfilment of
the independence criteria of the Independent Non-Executive Directors.
Provision 19. Length of service of Chair
The Chair has been serving for over 30 years. With the completion in 2023 of the new corporate transformation, the organisation
structure of METLEN now has two business lines: a) the Energy Sector and b) the Metallurgy Sector, which are fully integrated
and complementary.
The new organization will allow for the further development of our leadership bench to meet future succession needs, whilst
ensuring that all the critical competencies required in this new era for METLEN, both individual as well as collective, are in place.
Mr. Mytilineos is the architect of the Company transformation and the Company strategy, hence his vision, knowledge, and
involvement are integral to its materialization. Given his unique experience and leadership capacity, our Founder Mr. Mytilineos
will continue to play a critical role going forward.
Provision 20. Appointment process
In accordance with its Terms of Reference, in order to assist it in the search process for suitable candidates for Board members,
the Remuneration and Nomination Committee may request the assistance of an external consultant to whom it may assign
specific tasks. These tasks may, where appropriate, include conducting a survey of potential Board members, drawing up a list of
preferred candidates and assessing their suitability, in accordance with the instructions of the Remuneration and Nomination
7. Statement of Corporate Governance
355
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Committee. The Remuneration and Nomination Committee shall then assess the suitability of the candidates to fill the positions
on the Board and submit its proposals to the Board with the assistance, where appropriate, of the Lead Independent Director.
Provision 21. Board evaluation
In 2024, the Board conducted its first self-assessment regarding the effectiveness of its operations. This assessment, conducted
through a detailed questionnaire completed by the members of the BoD, was carried out under the supervision of the Lead
Independent Director. The thematic areas examined in this assessment included, among others, the appropriateness of the
Board’s size, the clarity of the roles of the Board Chair, its members, and its committees, the Board’s oversight of the Company’s
strategic direction, risk management, performance monitoring, the effectiveness of Board meetings, the relationship between
the Board and Management, the ways in which the Board seeks to improve its functioning, and areas requiring improvement.
Prior to this, the following evaluations had taken place: a. the collective suitability assessment of the Board, completed in 2020;
b. the assessment of individual capabilities and contributions of Board members, completed in 2022; and c. the evaluation of the
Board’s committees, completed in 2023, which were conducted by external consultants.
Board effectiveness was evaluated by an external evaluator in two stages: First, by conducting an assessment of the collective
suitability of the Board completed in 2020 and second, by conducting an assessment completed in 2022 that focused on individual
capabilities and Board impact. Following a review of available providers, the Remuneration and Nomination Committee proposed
Egon Zender to facilitate the process based on their leading position in the Greek marketplace, knowledge of the METLEN Group
and the value of their proprietary global template in evaluating Board performance.
As a conclusion, the three Board evaluation exercises strengthened the Board’s effectiveness whilst the initiatives executed have
already shown a material improvement in the ability of the Board to add value.
Following the two aforementioned evaluations of the Board of Directors, during 2022 and 2023, the Company, with the assistance
of different external consultants for each committee (PWC for the Remuneration and Nomination Committee, Deloitte for the
Audit Committee, and KPMG for the Sustainability Committee), conducted assessments of the three committees of the Board.
The goal was to identify opportunities for improving their effectiveness. The evaluation covered the responsibilities, dynamics,
composition, skills, knowledge, and experience of the committee members, as well as their reporting, communication, and
monitoring activities, taking into account national legislation and the UK Corporate Governance Code. The tools used during the
evaluation process included, among others, personal interviews, observation of meetings, examination of documents and
procedures, and a self-assessment questionnaire. As part of the evaluation, opinions were sought from members of the Board of
Directors, senior management, the Corporate Secretary, the Internal Audit Division, and the external auditor. The evaluation and
access to relevant information, which was not of a confidential nature, were supported by the Corporate Secretary and the
Corporate Governance Division. The engagement of the mentioned consultants was based on their leadership position in the
Greek and global markets, in accordance with their profiles and their experience in relevant projects. All three external
consultants also provided additional services to the Company. Specifically, KPMG offered consulting and auditing services,
Deloitte provided consulting services (such as, customer relationship management software, on IT activities, and PwC provided
auditing services.
Additionally, as previously mentioned, in 2024, an assessment was conducted to evaluate the suitability of the Board at both an
individual and collective level. This assessment focused on compliance with the requirements for adequate gender
representation, the total number of independent non-executive Board members, and the suitability criteria, in accordance with
the legal framework and the “Policy for the Suitability Assessment of the Members of the Board of Directors”. Independently of
the evaluation of the Board of Directors, the annual evaluation of the Chairman & CEO, led by the Lead Independent Director,
was conducted and subsequently reviewed by the Remuneration and Nomination Committee. The evaluation was carried out
along different areas of CEO accountability, including Strategic Development, Organizational effectiveness, Board Effectiveness,
ESG progress and delivery of 2023 Financial Targets. The evaluation was discussed with the Chairman & CEO both individually
and at Board level and was a critical input into the 2023 STIP review.
Furthermore, in the Terms of Reference of the Board of Directors, it was explicitly provided for, among other, that the person
being evaluated shall also participate in the evaluation and performance review process, shall be informed in advance of the
evaluation rules by means of an open information process, and shall have the opportunity to record any objections or complaints.
It was also foreseen that the results of the evaluation and performance review of the Executive Board members should be shared
with and discussed by the Board as a whole, while at the same time they should be taken into consideration in the Board
succession process. The Chair should take appropriate action based on the results of the evaluation, acknowledging the strengths
and addressing any weaknesses of the Board, whilst each member of the Board should actively engage with this process and take
7. Statement of Corporate Governance
356
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
appropriate action when improvement needs have been identified.
Provision 22. Evaluation follow-up
The results of the Board of Directors’ self-assessment regarding its operational effectiveness were thoroughly discussed in the
Remuneration and Nomination Committee and the Board. Among other points, the discussions highlighted the Board's
supportive role in relation to Management, the constructive role of meetings of the non-executive members and the added value
they generate, as well as the increasing influence of non-executive members. Additionally, improvements were noted concerning
strategic issues and the Board’s active role. The discussions also addressed the challenges arising from the Company’s expanding
international activities, the need for systematic performance monitoring, and succession planning for Management.
Furthermore, upon the completion of the Committees’ assessments, the results of each evaluation were discussed in detail both
within the respective committees and at the Board level. Consequently, an action plan was approved and implemented to further
enhance their functioning and effectiveness. Additionally, an initiative is underway to improve cross-coordination among the
three committees and optimize synergies between them. To this end, in 2024, a joint meeting of the Audit Committee and the
Sustainable Development Committee was held to discuss sustainability-related matters, including the requirements of the EU’s
CSRD Directive and the Sustainability Statement.
Moreover, certain improvement measures were decided upon, such as training committee members on the new requirements
introduced by EU legislation concerning recent developments in sustainability, strengthening their roles, and enhancing their
oversight processes related to corporate governance matters.
Provision 23. Reporting on the Nomination Committee
The Remuneration and Nomination Committee held during 2024 nine (10) meetings. All members of the Committee attended all
the meetings.
Selection of a New Independent Non-Executive Board Member
For the selection of a new independent non-executive Board member, the Committee considered a shortlist of seventeen (17)
candidates compiled by the external consultant Egon Zehnder. After thoroughly reviewing the CVs of the four (4) most prominent
candidates and evaluating their profiles against the desired qualifications for the new Board member, the Committee decided to
propose the candidacy of Mrs. Polyxeni (Xenia) Kazoli as an independent non-executive member.
To assess the suitability of the proposed member, the Committee examined and verified Mrs. Kazoli's suitability based on the
Policy for the “SUITABILITY ASSESSMENT OF THE MEMBERS OF THE BOARD OF DIRECTORS”, in relation to the adequacy of her
knowledge and skills, including academic and professional qualifications, the sufficiency of her professional experience, the
requirements set by the Company for the position, the absence of any potential conflicts of interest or incompatibilities, her
honesty, integrity, and good reputation, and the availability of sufficient time to fulfill the role.
Additionally, the Committee evaluated the collective suitability of the Board in the event of Mrs. Kazoli’s election, taking into
consideration:
i. The assessment of both the collective and individual capabilities of the Board;
ii. The CV and other professional commitments of the proposed candidate;
iii. The provisions of the regulatory framework, POLICY FOR THE SUITABILITY ASSESSMENT OF THE MEMBERS OF THE
BOARD OF DIRECTORS, the Company’s DIVERSITY POLICY, the Corporate Governance Code applied by the Company,
as well as the Board Member Independence Policy and the Evaluation Procedure for Independence Criteria and
Disclosure of Dependence Relationships.
Based on the above, the Committee concluded that with the election of the proposed member, the following requirements are
met:
I. Adequate gender representation on the Board;
II. The total number of independent non-executive members;
III. The suitability criteria established by the applicable regulatory framework and the Company’s Policy for the
Suitability Assessment of the Members of the Board of Directors.
7. Statement of Corporate Governance
357
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Furthermore, the Committee confirmed that if Mrs. Kazoli is elected as an additional new non-executive member, the target of
increasing female representation on the Board to 30% will be achieved (as the percentage will be adjusted to 31% women and
69% men), thereby enhancing the Board’s diversity.
Additionally, the Committee confirmed that Mrs. Kazoli meets the independence criteria as defined by Article 9 of Law
4706/2020, based on the information she formally provided to the Company. This information was cross-verified, to the extent
possible, through a report provided by the external independent consultant Linked Business.
The Committee submitted a recommendation to the Board regarding Mrs. Kazoli’s nomination.
Selection of a New Member for the Remuneration and Nomination Committee
The Committee, in collaboration with the Lead Independent Director of the Company, discussed and decided on the addition of
a new member to the Remuneration and Nomination Committee, with the aim of enhancing its composition. Specifically, the
Committee selected Mrs. Polyxeni (Xenia) Kazoli, whose knowledge and experience will contribute to the Committee’s work. A
recommendation was submitted to the Board of Directors for approval.
Results of the Employee Engagement Survey
The Committee, with the support of the General Director of Human Resources, conducted an in-depth discussion on the results
of the Employee Engagement Survey, which was conducted for the first time in 2023. The survey included 4,564 employees from
all business sectors across 32 countries. The survey, was conducted with the assistance of the external consultant Great Place to
Work (GPTW), aimed to help the Company foster a high level of employee engagement.
With a response rate of 80%, the survey results were evaluated in comparison with leading European companies (>500
employees) recognized for having the best workplace environments in Europe.
The Committee focused on areas identified in the survey as needing improvement. Based on these findings, it was decided to
develop an action plan to address these areas, which will be monitored by the Human Resources Department. Key focus areas
include the Job grading system (grading), performance management, and integration of acquired companies into the
organizational structure. Additionally, the Committee discussed the next steps in the process.
Diversity Policy
The Committee held an in-depth discussion on the Company’s Diversity, Equity & Inclusion (DEI) Framework & Policy, which is
currently under development. The discussion focused on the framework, approach, and best practices for fostering an inclusive
workplace culture.
The Committee emphasized the alignment of the strategic framework with the Company’s overall culture, the Human Resources
approach, which integrates both top-down and bottom-up approaches, the metrics to be included in the policy in relation to
equity and inclusion, the method for tracking progress, to be overseen by the Human Resources Department, and the policy’s
connection to whistleblowing reports.
Assessment of the Board of Directors' suitability and fulfillment of independence criteria for Independent Non Executive
Members
The Committee reviewed the suitability of the Board at both an individual and collective level, specifically assessing the fulfillment
of the requirements regarding gender representation, the total number of independent non-executive Board members, the
suitability criteria, and particularly regarding independent non-executive members, the fulfillment of independence criteria in
accordance with the regulatory framework and the Policy for the Suitability Assessment of the Members of the Board of Directors.
Additionally, the Committee examined whether the Audit Committee meets the required suitability and independence criteria.
Within this framework, the Committee determined that the representation of both genders exceeds the mandatory 25% quota
set by Law 4706/20 for the underrepresented gender. Following the election of Ms Polyxeni (Xenia) Kazoli at the General Meeting
on June 4, 2024, the gender representation now stands at 31% women and 69% men, while among non-executive members, it is
44% women and 56% men.
Furthermore, the total number of independent non-executive Board members is 8, out of a total of 13 members, corresponding
to 62%, thereby meeting the requirements of Law 4706/2020, the UK Corporate Governance Code, which the Company has
adopted and implements, and the Company’s Policy on Board Members’ Independence.
Furthermore, the Committee confirmed that each independent non-executive Board member individually meets the
independence criteria, as outlined above. This determination was based on the statements provided by the members, which
7. Statement of Corporate Governance
358
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
were cross-verified by the Company to the extent possible. Specifically for dependency relationships within Greece, verification
was conducted through a report provided by the external consultant, Linked Business.
In line with the Policy for the Suitability Assessment of the Members of the Board of Directors, the Committee assessed:
(a) The individual suitability of each Board member in relation to knowledge and skills adequacy, including academic and
professional qualifications, ensuring the capability to perform assigned roles, professional experience sufficiency, position-
related competencies required by the Company, absence of conflicts of interest or incompatibilities, integrity, honesty, and
good reputation, and availability of sufficient time to fulfill responsibilities.
(b) The collective suitability of the Board, and, more precisely, that the Board's composition reflects the necessary knowledge,
skills, and experience required for its duties, its members collectively possess the expertise needed to effectively present their
views, and the Board as a whole covers with sufficient experience of its members all key business areas in which the Company
operates (Energy and Metals), as well as related fields (such as finance and capital markets).
Evaluation of the Remuneration and Nomination Committee
The Committee was informed about the results of its evaluation by the external consultant PwC. It was found that the results of
the self-assessment aligned with the conclusions of the evaluation conducted by PwC, which were derived after individual
interviews with the Committee members.
According to the evaluation, the effective functioning of the Committee is significantly supported by the experience and expertise
of its members, the thorough discussion of proposals and the achievement of consensus, the strong collaboration between the
Committee Chair and the Board Chair and CEO, as well as the support provided by the Committee Secretary. Additionally,
alignment and cooperation with the Board of Directors are ensured through proper communication and a solution-oriented
approach to key issues raised by the Committee.
Furthermore, the evaluation highlighted the members' ability to handle complex and sensitive matters, such as remuneration
and Board member evaluations (including the Chair and CEO), succession planning for the Chair and CEO, and the equity-based
remuneration program for the Executive Leadership Team.
At the same time, the external consultant emphasized the need to strengthen the Committee’s role so that it plays a more
decisive role in nomination and remuneration processes, as well as the completion and standardization of succession plans for
the Chair and CEO, Board members, and senior executives. The consultant also highlighted the importance of maintaining the
Committee’s supervisory role while avoiding any executive responsibilities.
Additionally, the external consultant noted the approval of the remuneration policy for senior executives, the initiation of
discussions on a comprehensive strategy and goals for Diversity and Inclusion across the organization (in collaboration with the
HR Director), the identification of common areas of interest and responsibility to develop a collaboration framework, the
development of a comprehensive training framework for Board members by the Committee, and gathering feedback from
employees and other stakeholders (e.g., auditors, consultants, etc.) regarding the performance of the Board and senior
executives.
The Committee members engaged in a detailed discussion with the external consultant regarding the evaluation results and
improvement proposals. An action plan was developed under the initiative of the Committee Chair to implement these
recommendations.
It was also decided to submit a recommendation to the Board of Directors regarding the evaluation methodology by PwC, the
evaluation results, and the action plan for adopting the improvement proposals.
Human Resources Matters
The Committee was briefed by the Human Resources Division and thoroughly discussed:
a. The project “METLEN Job Model” (ex Organisational Grading), aimed at addressing challenges such as the large
number of job titles and the need to align the Company’s organizational structure with the Group’s rapid growth. In
2024, the analysis and evaluation of all job positions within the organization were completed, and the finalization of the
results with the heads and Business Leaders is currently in progress. The estimated benefits of the project include the
harmonization and calibration of job positions according to the requirements of
of each role. The next steps involve linking the Job Model with all HR policies and procedures, as well as top-down
communication following the finalization of the results.
b. The training program “LeadMe”, specifically designed for senior executives, with the goal of developing leadership
skills and preparing them for leadership challenges as identified in the Employee Engagement Survey of 2023.
c. The project “Global Induction”, which focuses on transforming the onboarding training of new hires using modern
practices, aiming to emphasize employee engagement from their first interaction with the Company.
7. Statement of Corporate Governance
359
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Board Member Training
As part of the Board members’ training, in 2024, sessions were conducted on:
a. The new 2024 UK Corporate Governance Code and the Company’s preparation for its implementation.
b. Cybersecurity, with a particular focus on the following topics: “Cybersecurity and NIS2 Directive” and “Cybersecurity
Board Priorities.”
The Remuneration and Nomination Committee informed the Board of Directors about its work during the year 2024.
1.4 AUDIT, RISK AND INTERNAL AUDIT
Principle M: Internal and external audit
The Audit Committee of the Company has been established with the purpose of assisting the Board of Directors to fulfil its
oversight responsibilities of the audit procedures for complying with the legal and regulatory framework regarding: (a) financial
information, (b) internal audit, (c) the system of internal controls and the risk management system, and (d) supervision of the
(external) statutory audit of the Company's individual and consolidated financial statements.
While all members of the Board individually and collectively have a duty to act in the interests of the company, the Committee
has a particular role, acting independently from the executive Board Members, to ensure that the interests of shareholders are
properly protected in relation to financial reporting and internal control and risk management systems. However, the Board has
overall responsibility for the Company's approach to risk management and the system of internal controls.
Principle N: The company’s position and prospects
At the end of each business year, the Board of Directors prepares the annual financial statements, the annual consolidated
financial statements and the management report.
The financial statements constitute a single comprehensive set and give a fair presentation of the recognized assets, liabilities,
equity, income, expenses, profit and loss, as well as the cash flows of the period concerned, as the case may be, in conformance
with the law. More specifically, the Board of Directors is required to prepare, pursuant to the above provisions: (a) the Balance
Sheet or Financial Position Statement, (b) the Income Statement, (c) the Statement of Equity Change, (d) the Cash Flow
Statement, (e) the Notes to the Financial Statements.
The management report provides:
(a) A fair review of the development and performance of the Company business and its position, together with a description
of the principal risks and uncertainties faced by the Company;
(b) A review that presents a balanced and comprehensive analysis of the development and performance of the Company
business and position, consistent with the size and the complexity of the Company;
(c) To the extent necessary for an understanding of the development, performance or position of the Company, the said
analysis includes both financial and, where appropriate, non-financial key performance indicators relevant to the particular
business of the Company, including information on environmental and labour issues. In the context of this analysis, the report
includes, where appropriate, references and additional explanations on the amounts shown in the annual financial
statements.
In the management report the Company includes:
(a) a non-financial statement that includes information, to the extent necessary for an understanding of the development,
performance, position and impact of its activities in relation, as a minimum, to environmental, social and labour issues, the
respect of human rights, anti-corruption and anti-bribery practices
(b) the corporate governance statement, which is included as a separate part in the management report.
Principle O: Determining and managing risks
The Board defines the strategy and is informed on significant risk factors such as financial, environmental, social, health and
safety, and governance.
The Company has defined risk as a set of uncertain and unpredictable situations that may affect all its activities, its business
operation and its financial performance, as well as the implementation of its strategy and the achievement of its goals.
7. Statement of Corporate Governance
360
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
In line with this approach, it has established a specific risk management approach in all its areas of activity where certain risks
have been recognized. This approach consists of the following steps:
- Identification and assessment of risk factors
- Planning of the risk management policy
- Implementation and evaluation of the risk management policy.
The Company has defined specific and comprehensive Risk Management Procedures. All executives are involved in the process
of identifying and initially assessing risk to facilitate the work of the management of each business sector and the Board of
Directors in the planning and approval of specific actions within the approved Risk Management Procedures.
The process of determining material sustainability topics follows, for the first time, the double materiality approach, which
combines both the impacts (positive and negative) of the Company’s activities on sustainable development and the effect of
these impacts on financial performance and strategic decision-making. This is a continuously evolving process aimed at identifying
and highlighting issues that are of material importance both to the Company and its Social Partners. By identifying and
understanding the material sustainability issues, the Company formulates and develops its uniform business strategy and its aims,
targets and social and environmental initiatives.
Last but not least, the Company conducts regular internal audits to ensure the appropriate and effective implementation of the
risk identification and assessment processes and of the management policies for such risks.
Additional information is included below, under Provision 29.
Provision 24 Audit committee composition
At the AGM of 15 June 2021, the shareholders decided that the Audit Committee shall be a committee of the Board of Directors,
which shall consist from three independent non-executive members whose term of office shall be the same as their term in the
Board of Directors.
The Committee members as a whole have sufficient knowledge in the sectors in which the Company operates and at least one
of its members has proven sufficient recent knowledge in auditing and accounting and is required to attend the meetings of the
Committee concerning the approval of financial statements.
The assessment for the selection of the candidate Committee members is conducted by the Board of Directors, on the
recommendation of the Company’s Remuneration and Nomination Committee.
The Committee has a Secretary, which cooperates with the Corporate Secretary and is responsible for supporting the operation
of the Committee in general, including the keeping of the minutes and the proper implementation of the Committee meetings.
The Committee Chair is appointed by the committee members. The chair of the Board cannot be a member of the Committee.
Composition and meetings of the Audit Committee in 2024
Composition of the Audit
Committee
Status
Meetings during 2024
(01.01.2024-31.12.2024)
Total number 13*
Attendance rate of
meetings
Anthony Bartzokas**
Chairman
13/13
100%
Konstantina Mavraki
Member
13/13
100%
Alexios Pilavios**
Member
13/13
100%
Note: The term of office shall be four years, which shall be extended until the first ordinary general meeting following the expiry
of the term of office.
* One of the meetings was a joint session with the Sustainable Development Committee.
**Mr. Alexios Pilavios served as Chairman of the Committee until 1/9, when the Committee was constituted into a body, and Mr.
7. Statement of Corporate Governance
361
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Anthony Bartzokas assumed the role of Chairman. Consequently, Mr. Alexios Pilavios participated in three meetings as a member
and in the remaining ones as Chairman. Similarly, Mr. Anthony Bartzokas participated in three meetings as Chairman and in the
remaining ones as a member.
Attorney Mrs Vassiliki Prantzou is the Committee’s Secretary.
The AGM of the Company's shareholders of 2021, in accordance with the provisions of article 44 of Law 4449/2017, as amended
and in force, decided that the Committee will be a committee of the Board of Directors, which will consist of three independent
non-executive members of the Board of Directors. Following the AGM of 2022 at which the Board of Directors of the Company
was re-elected, the General Meeting appointed Mr. Alexios Pilavios, Ms. Konstantina Mavraki and Mr. Anthony Bartzokas as
members of the Audit Committee. The Audit Committee was constituted as a body and re-elected Mr. Alexios Pilavios as its
Chairman.
In 2024, the members of the Audit Committee, having taken into consideration that:
1. The Company’s BoD, during its meeting on 02.06.2022, following a relevant recommendation from the Remuneration
and Nomination Committee, appointed three of its independent non-executive members as members of the Audit
Committee, with a term until 02.06.2022, automatically extended until the first Ordinary General Meeting following
the expiration of the Board’s term,
2. The Audit Committee, during its meeting on 02.06.2022, was constituted into a body and appointed Mr. Alexios Pilavios
as its Chairman,
3. Mr. Alexios Pilavios has served as Chairman and member of the Audit Committee since 07.06.2018, Ms. Konstantina
Mavraki since 02.02.2021 and Mr. Anthony Bartzokas since 15.06.2021, respectively,
decided, in the context of preparing a succession plan to ensure the optimal functioning and effectiveness of the Audit
Committee, to implement a rotation in the chairmanship. Specifically, they decided to appoint the newest member of
the Audit Committee, Mr. Anthony Bartzokas, as Chairman of the Audit Committee. To this end, on 01.09.2024, the
Company’s Audit Committee appointed Mr. Anthony Bartzokas, one of its existing members, as the new Chairman and
was constituted into a body with the same members, maintaining a term equal to that of the Board of Directors.
Provision 25. Role of the audit committee
The Audit Committee assists the Board of Directors in fulfilling its oversight responsibilities on the audit procedures to ensure
compliance with the legal and regulatory framework regarding:
(a) financial information;
(b) the System of Internal Controls, including the Internal Audit Division, the Risk Management Function, and the
Regulatory Compliance Function; and
(c) supervision of the (external) statutory audit of the Company's individual and consolidated financial statements.
The main responsibilities of the Audit Committee are:
i. to monitor the financial reporting process with the view to ensure its integrity;
ii. to monitor the effectiveness of the Company’s system of internal controls, quality assurance and risk management
and, where appropriate, of the Internal Audit Division as regards financial information (without impairing the
independence of this Division and in accordance with the applicable legal and regulatory framework), as well as
to have the day-to-day responsibility for management of the System of Internal Controls (the Board of Directors
has ultimate responsibility for the effectiveness of the Company’s System of Internal Controls);
iii. to review and approve the role and mandate of the Internal Audit Division, approve the annual internal audit plan
and monitor, inspect and review the effectiveness of the function and work of the Internal Audit Division;
iv. to monitor the statutory audit of the annual and consolidated financial statements of the Company, and in
particular its performance, as well as το review the effectiveness of the audit process, and to oversee the
Company's relations with the statutory auditor (responsibility for the process of selecting the statutory auditor,
annual assessment of its qualifications and independence, proposals to the Board on the appointment,
reappointment and/or removal of the statutory auditor, etc.).
When requested by the Board, the Audit Committee assesses whether the annual financial report, including the annual financial
statement and the management report, reflects in a true, fair, balanced and understandable manner the development,
performance and financial position of the company and of the businesses included in group consolidation, taken as a whole.
7. Statement of Corporate Governance
362
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Committee considers and examines the most significant issues and risks that may have an impact on the Company's annual
and interim financial statements and other periodic financial information, as well as the critical judgments and estimates made
by Management in their preparation. For the above issues and risks the Committee has regard to matters communicated to it by
the External Auditor, as well as his view of Management's estimates, and informs the Board.
The Board has ultimate responsibility for the Company's internal control and risk management systems, including the System of
Financial Internal Controls and the Financial Risk Management System. It is in the Audit Committee's remit to oversee them and
to inform the Board accordingly. There is no separate risk committee at board level.
The Committee has primary responsibility for the appointment of the key audit partner (external auditor). This includes
negotiating the fee and scope of the audit, initiating a tender process, influencing the appointment of an engagement partner
and making formal recommendations to the board on the appointment, reappointment and removal of the external auditors.
The Audit Committee assesses the independence and objectivity of the annually in accordance with articles 21, 22, 23, 26 and 27
of law 4449/2017 and with articles 4 and 6 of Regulation (EU) no. 537/2014 and in particular assesses the appropriateness of the
provision of non-audit services to the Company in accordance with article 5 of Regulation (EU) no. 537/2014.
The Audit Committee takes into account the regular auditor's annual declaration of independence and discusses with him threats
that may call into question his independence, as well as ways to ensure that these threats are addressed. The Audit Committee
examines whether the relationships, taking into account the views of the external auditor, the Management and the internal
auditor, as appropriate, appear to affect the auditor's independence and objectivity.
The Committee assesses the effectiveness of the audit process considering of mind-set and culture; skills, character and
knowledge; quality control; and judgment, including the robustness and perceptiveness of the auditors in handling key
judgements, responding to questions from the Committee, and in its commentary where appropriate on the systems of internal
control.
The Committee is responsible for approving non-audit services, that are not prohibited by law. The Committee ensures that the
provision of such services does not impair the External Auditor’s independence or objectivity by applying judgement, including
assessing:
i. threats to independence and objectivity resulting from the provision of such services and any safeguards in place to
eliminate or reduce these threats to a level where they would not compromise the auditor’s independence and
objectivity;
ii. the nature of the non-audit services;
iii. whether the skills and experience of the audit firm make it the most suitable supplier of the non-audit service;
iv. the fees incurred, or to be incurred, for non-audit services both for individual services and in aggregate, relative to the
audit fee, including special terms and conditions (for example contingent fee arrangements), and
v. the criteria which govern the compensation of the individuals performing the audit.
At the General Meeting of 04.06.2024, the shareholders elected the auditing firm “PRICEWATERHOUSECOOPERS S.A.” to conduct
the regular audit of the Company’s individual and consolidated financial statements for the financial year 01.01.2024-31.12.2024,
as well as the review of the interim financial statement for the period 01.01.2024-30.06.2024, and the Annual Tax Certificate of
the Company for the financial year 2023. This decision followed a relevant proposal by the Board of Directors and a
recommendation from the Audit Committee.
The Audit Committee made its recommendation to the Board regarding the appointment of a new statutory auditor as part of
its responsibilities, given that it oversees and supervises the selection process for candidate auditors. This process takes into
account the Company’s needs and, among other factors, the provisions of its Internal Regulation, EU Regulation 537/2014 (on
specific requirements regarding the statutory audit of public-interest entities), Article 52 of Law 4449/2017, the guidelines of the
Accounting Standardization and Audit Committee (ELTE) on the maximum audit tenure, and best practices for selecting a
statutory auditor.
Specifically, the Committee assigned the General Directorate of Financial Services, in collaboration with the Company’s Indirect
Procurement Department, to prepare a Request for Proposals (RFP) for the candidate auditing firms, ensuring compliance with
the quality standards adopted by ELTE. The RFP was directed to Big Four auditing firms, considering the complexity of the
Company’s and Group’s activities, the Group’s international presence, and the credibility of these audit firms among the
investment community. It also took into account that the outgoing auditing firm is ranked among the Big Six.
7. Statement of Corporate Governance
363
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Following a thorough evaluation and analysis of the submitted proposals, the Committee recommended to the Board the
appointment of the auditing firm PwC, a proposal that was unanimously approved by the Board of Directors.
The Internal Audit Division is functionally independent and is not subordinate to any other organizational unit of the Company.
The head of the Internal Audit Division is appointed by the Board of Directors upon recommendation of the Audit Committee.
The Audit Committee ensures the functioning of internal control in accordance with the International Standards for the
Professional Practice of Internal Auditing by engaging the services of an external assessor for the annual re-certification of the
operation of the Internal Audit Division based on the Internation Professional Practices Framework (IPPF) as well as the
continuous improvement of its services. The Audit Committee reviews and approves the role and mission of the Internal Audit
Division, approves the annual audit plan, and monitors, inspects, and examines the effectiveness of the operations.
Furthermore, regarding the Compliance Division, the Committee examines the implementation and execution of the Company's
compliance program, including the program for the protection of personal data, reviews and approves the annual compliance
program, examines significant legislative and regulatory issues and developments and their expected impact on the Company's
operation, and examines significant findings of the Compliance Division and the measures taken or to be taken to address them.
Further information on the remit, responsibilities and the modus operandi of the Audit Committee are available in the
Committee’s Terms of Reference, which have been released in the Company’ s website https://www.metlengroup.com/ at the
following address: https://www.metlengroup.com/who-we-are/governance/corporate-governance/committees/.
Provision 26. Reporting on the audit committee
The activities of the Audit Committee are included in detail in Chapter 5 of the 2024 Annual Integrated Report.
Provision 27. Confirmation that the annual report is a fair, balanced and understandable representation
The directors certify that (a) the annual financial statements of the Company drawn up in accordance with the applicable
accounting standards, reflect in a true manner the assets and liabilities, equity and results of METLEN, as well as of the businesses
included in the Group consolidation, taken as a whole and also that (b) the Management Report of the Board of Directors reflects
in a true manner the development, performance and financial position METLEN and of the businesses included in the Group
consolidation, taken as a whole, including the description of the principal risks and uncertainties. The directors state that they
consider the annual report and accounts, taken as a whole, as fair, balanced and understandable.
Provision 28. Risk assessment
Financial and non-financial risk assessment for the year 2024 is provided in the Annual Report of the Board of Directors.
Provision 29. Risk management and internal controls
The BoD re-examines in a continuous and consistent way the corporate strategy and the principal business risks, especially in a
constantly changing financial and business environment.
The elements comprising the Internal Control System are as follows:
· Governance Framework: Designed to ensure high-quality information and effective decision-making, clarity,
accountability, transparency, and efficiency.
· Strategic Framework: Includes the purpose, objectives, and values of the enterprise and serves as the basis for all
activities within the Risk Management Framework.
· Risk Management Framework: This framework supports each Business Unit in managing its risks and contributes to the
relevant reporting to the Board of Directors. The framework is supported by the fundamental principle that everyone in
the Company is responsible for risk management.
· Assurance Framework: An extensive program of controls and assurance activities independent of the day-to-day
operations of the Business Units and corporate functions. It consists of Internal Audit, Regulatory Compliance, Quality
Assurance, Health and Environment Systems.
7. Statement of Corporate Governance
364
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
· Standards and Quality Framework: Defines the expected standards and guiding principles to be followed to achieve the
Company's purpose.
Within 2023, the Company's Enterprise Risk Management Framework (ERM) was defined and approved by the Board of
Directors to ensure proper oversight of the Company's risk management function. The implementation of this project, for which
the Company enlisted the assistance of the external consulting firm McKinsey, was initiated by the Non-Executive Members,
with the Lead Independent Director, Mr. Ioannis Petridis, appointed as the head of the Steering Committee for the development
of the Enterprise Risk Management Framework.
The three key areas in risk management are a) determining risk appetite and risk strategy, b) establishing a risk culture, and c)
ensuring the effective operation of the three lines of defense. Risk management pertains to the second line of defense.
The approved risk management framework of the Company includes the following five stages:
a) Identification and categorization of risks, which involves detailed risk categorization and the development of risk
appetite levels for each of the 32 identified risk subcategories;
b) Risk assessment, which includes the assessment process according to industry standards and the establishment of clear
definitions of assessment criteria;
c) Risk hierarchy approach and risk treatment, involving the prioritization and detailed description of risks;
d) Risk monitoring and development of Key Risk Indicators as part of the evolution of ERM within the Company
e) Risk management and reporting for reporting and presentation purposes.
In 2024, the Internal Audit Division conducted an evaluation of Metlen's Corporate Governance System according to its approved
work program for 2024 and the request from the Corporate Governance Department dated 10/09/2024. The project aimed to
review the adequacy of the relevant corporate processes and safeguards in terms of compliance with the requirements of Law
4706/2020 (articles 1 – 24 & 74), certain requirements of Law 4548/2018, as well as the relevant regulations and decisions of the
Capital Market Commission.
In 2024, the Company initiated and/or completed a multitude of projects regarding the improvement of the corporate
governance system (including the Internal Audit System), with the most notable examples being:
i. Increasing the diversity index of the BoD with the election of a new member and the completion of committee
evaluations by an external provider.
ii. Selecting a new Certified Public Accountant and adopting new forms for the pre-approval of non-audit services,
pending final approval of the related policy.
iii. Developing a new risk assessment methodology by McKinsey in collaboration with the Enterprise Risk Management
Department. This includes the ongoing determination and monitoring of specific key risk indicators (KRIs).
iv. Implementing new policies by the Regulatory Compliance Department, such as Anti-Fraud, Anti-Corruption & Anti-
Bribery, and Financial Sanctions.
v. Obtaining new ISO certifications, such as ISO 37001:2016 Anti-Bribery Management System, ISO 37002 for
Whistleblowing Management Systems, ISO 37008 for Internal Investigation Procedures, and ISO 27001 for information
security.
vi. Completing the employee satisfaction survey across the Group, analyzing and presenting the results, and drafting and
monitoring a corrective action plan with the commitment of the Cabinet & Leadership Council. A follow-up survey was
conducted within the year on a sample of employees, with results pending.
vii. Implementing new operational frameworks and procedures for human resources (onboarding, MJM, Benefits,
Development Training, Performance Appraisal, Succession Planning) and digital transformation (Digital Transformation
Office and Council).
viii. Investing in numerous new automated systems and utilizing them across departments globally for: human resources
management (SuccessFactors), conflict of interest management (LinkedBusiness), sustainability disclosures
management (Engage), monitoring and updating organizational structure, ownership, and representation of Group
companies (Diligent Entities), health and safety management (Hammertech), business intelligence and artificial
intelligence development (DataWarehouse, CoPilot), monitoring the company's external perimeter cybersecurity
index (Bitsight), and monitoring a consolidated list of internal control system improvement proposals (TM+).
ix. Preparing for the implementation of necessary actions to comply with the new Code coming into effect in 2025,
considering EY's recommendations regarding the company's listing on the London Stock Exchange.
7. Statement of Corporate Governance
365
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Based on the corresponding audit conducted by the Internal Audit Department in 2022-2023, twenty actions have already been
completed. Additionally, from the 2023 audit regarding the Board of Directors' Terms of Reference, two actions have been
completed.
Further information is available in the Annual Integrated Report of the Audit Committee (Chapter 5 of the Integrated Annual
Report).
Provision 30. Going concern statement
In the annual and half-yearly financial statements, the Board states that such statements have been compiled based on the
historic cost principle as amended by the readjustment of specific asset and liability items into market values, the going concern
principle and are in accordance with the International Financial Reporting Standards (IFRS) that have been issued by the
International Accounting Standards Board (IASB) and their interpretations that have been issued by the International Financial
Reporting Interpretations Committee (IFRIC) of the IASB.
Provision 31. Viability statement
The Company does not prepare a separate viability statement. The annual report includes an assessment of the going concern
activity for a period of 12 months from the date of the financial statements as well as an analysis of the risks to which the Group
is exposed, with a list of the actions that limit them, as well as sensitivity analyses to various variables. In combination, the above
disclosures provide information on the viability of the Group and are in line with both the accounting framework followed
(International Financial Reporting Standards) and the requirements of Greek Legislation regarding the obligations and
responsibilities of the members of the Board of Directors and those responsible for the preparation of the annual report.
1.5. REMUNERATION
Principle P: Long-term focused remuneration
The Board Remuneration Policy was approved in its original form by the AGM’s resolution of the shareholders of METLEN dated
June 24, 2019 and has been amended by virtue of the AGM’s resolution of the shareholders dated June 15, 2021. The Policy was
prepared with the help of an external consultant, Korn Ferry, and is in accordance with the EU Shareholder Rights Directive, as
incorporated into Greek legislation by virtue of Law 4548/2018.
Following the expiration of the validity of the initial Remuneration Policy, which had a duration of 4 years, a new Policy was
approved by the Extraordinary General Meeting of Shareholders on April 10, 2023, in accordance with the Company's Articles of
Association, which stipulates that the Company submits the Remuneration Policy for approval at the General Meeting every four
[4] years. The new Policy, which was also prepared in accordance with current EU and Greek law, is valid for four [4] years from
the date of its approval, unless it is revised and/or further amended earlier, pursuant to another decision of the General Meeting.
The Policy applies to the remuneration of all Company’s members of the Board of Directors. The Policy sets out details of both (i)
the current rights and obligations; and (ii) the terms under which future remuneration may be offered to current and / or new
Directors as long as the Policy is in Force.
The Policy considers European best practices for listed entities, whilst reflecting the current Executive Directors’ remuneration
arrangements. In addition, it takes into consideration the provisions of the Company’s articles of association, the UK Corporate
Governance Code and the Company’s by-laws.
In short the board remuneration policy is as follows:
Executive Directors of the Board
Principles of Remuneration Policy
The remuneration policy for the Executive Directors contributes to the Company’s business strategy and long-term interests and
sustainability by:
i. Providing a fair and appropriate level of fixed remuneration that does not result in over reliance on variable pay and
undue risk taking, thereby encouraging the Executive Director to focus on sustained long-term value creation.
ii. Differentiating the level of remuneration, both fixed and variable, according to the size of the role and the
contribution of Executive Members to the Company's results.
7. Statement of Corporate Governance
366
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
iii. Providing a balance of short and long-term incentives to ensure there is focus on short term objectives that will over
time build to create long-term value creation, as well as long-term goals.
iv. Ensuring the long-term performance and sustainability of the Company over time and aligning with the interests of
shareholders through rewarding Executive Board Members with shares. Encouraging behaviors that align with the
purpose, values, and philosophy of the Company.
v. Determining remuneration based on the principle of equal pay for work of equal value in alignment with the
provisions of Directive (EU) 2019/878.
Short-Term Incentive Plan
Form of compensation
Cash
Value determination (on-target performance)
Up to 50% of the annual variable remuneration cap
Criteria
- Financial and non-financial criteria (i.e. sustainability
criteria). Financial criteria are given greater weight.
- Personal performance (weighting percentage up to 20%)
Maximum performance Scenario
CEO: Up to 250% of up to 250% of Fixed Pay
Other Executive Members of the Board of Directors: Up to
150% of Fixed Pay
Long-Term Incentive Plan
Form of compensation
Shares or in cash equivalent. In case this is delivered in cash
equivalent, the Executive Director is required to buy
Company shares at 30% of total value granted and hold
them for 2 years.
Criteria for vesting
TSR relative to FTSE/ATHEX Large Cap excluding banks
Earnings per share (EPS) as an absolute measure.
Personal performance over a period of 3 years to qualify for
compensation.
Value of shares or equivalent in cash for maximum
performance level
CEO: Up to 290% of Fixed Pay
Other Executive Members of the Board of Directors: Up to
150% of Fixed Pay
Vesting Period
30% on year 4, 30% on year 5, 40% on year 6
Non-Executive Directors
Key Remuneration Principles
The Non-Executive Directors are paid a basic board fee which is fixed and covers for the time required to perform their duties.
This fixed fee covers for the time to attend in Board meetings and includes travelling and preparation time. Supplemental fees
may be paid to the Non-Executive Directors for additional responsibilities and activities, which exceed the scope of the duties
assigned including but not limited to, attending site visits, and meetings with management.
There is no performance-based variable pay or pension or other benefits provided to the non-executive Chairman or Non-
Executive Directors.
Independent Non-Executive Board Members do not receive remuneration for any reason other than their participation in the
Board or its Committees.
Reasonable business expenses incurred by the Non-Executive Directors in carrying out their duties may be reimbursed by the
Company such as travel and accommodation expenses for participation in Board meetings, attendance at training programs, and
the purchase of relevant training materials, according to the Company's policy at the time, to ensure that the executive is
informed about any relevant issues.
7. Statement of Corporate Governance
367
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The complete remuneration policy document is available on the Company’s website at https://www.metlengroup.com/investor-
relations/general-meetings/?page=2 .
Principle Q: Transparent remuneration procedures
The Remuneration and Nomination Committee of the Company (the “Committee”) has worked with all relevant units of the
Company, as well as an independent remuneration consultant (Korn Ferry), to arrive at the Remuneration Policy, which has been
recommended to and approved by the Board of Directors by virtue of a resolution dated 8 March 2023.
The process for the approval of the Policy (and any amendments thereto) is determined by the Company’s articles of association
and Law 4548/2018.
The Committee submits the Policy for approval to the Board of Directors. No member of the Board of Directors shall be present
when their own remuneration is discussed. Once agreed by the Board of Directors, the Policy is submitted for approval at the
Company’s GM of Shareholders.
The Committee considers regularly whether the Policy continues to be aligned to the Company’s business strategy or whether
amendments should be recommended to the Board of Directors. Every four years (or earlier on a need for change) on the
recommendation of the Committee, the Board of Directors will seek the Shareholders’ approval of any new Policy.
Principle R: Exercising discretion
The aim of the Remuneration Policy is to ensure the Company is remunerating its Directors on the basis of the Company’s short
and long-term business plan, so as to continue creating value for customers, shareholders, employees and the Greek economy.
The level of fixed pay – salary and directors' emoluments – for both Executive and Non-Executive Directors is established on the
basis of paying fair and reasonable remuneration for the best and most appropriate person for the role, taking into account the
level of responsibility, as well as the knowledge and experience required to deliver upon expectations, while ensuring that the
Company pays no more than is necessary, always supporting its longer-term interests and sustainability.
The Policy provides for variable compensation arrangements for Executive Directors to further align the Executive Directors’
interests with those of the Company as the performance conditions used will be based on indicators of the long-term success
and sustainability of the Company.
The Policy does not include any variable compensation for Non-Executive Directors to ensure that there is no conflict of interest
in the decision making of the Non-Executive Directors and their ability to challenge management’s risk-taking decisions.
Provision 32. Remuneration and Nomination Committee composition
As mentioned under Provision 17, the Company has a combined Remuneration and Nomination Committee which examines
and processes issues pertaining to: (a) the remuneration of Board members (the “directors”) and of senior and other executives;
and (b) the suitability of existing and candidate directors, within the scope of its remit under these Terms of Reference. The
Committee revisited its Terms of Reference, which were approved and put into effect by the Resolution of the Board of Directors
dated 26.07.2021, following relevant proposals submitted by the Committee.
The remuneration responsibilities of the Remuneration and Nomination Committee include the following:
i. to propose the Remuneration Policy to the Board, which shall then be submitted for approval at the General Meeting
of the Company’ s Shareholders, as well as the framework for the type and amount of remuneration of the directors
(particularly that of the Chairman of the Board, the Chief Executive Officer and the executive directors), and the type
and amount of remuneration of senior management who are members of the Executive Committee; and to formulate
proposals to the Board regarding the remuneration of the other Company executives, in particular of the head of the
Internal Audit Division;
ii. to determine the policy for and scope of pension arrangements for executive Directors;
iii. to review the appropriateness and relevance of the Remuneration Policy for Directors;
iv. to propose the annual Remuneration Report to the Board.
7. Statement of Corporate Governance
368
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Committee Chair informs the Board regarding the Committee’s work on all matters falling within its remit and the manner
in which it has fulfilled its duties; submitting a report in this regard in accordance with the UK Corporate Governance Code,
which the Company implements.
The Committee Chair has served on a remuneration committee for 15 months prior to his appointment. The Chairman of the
Board may be a Committee member only if they are an independent non-executive Director on appointment as Chairman of
the Board. In any case, the Chairman of the Board cannot chair the Committee.
The Remuneration and Nomination Committee was constituted into a body, by the resolution of the BoD of the Company dated
02.06.2022 and was composed until 24.07.2024 of three (3) Independent Non-Executive Members of the Board of Directors.
On 24.07.2024, the Board of Directors appointed the independent non-executive member, Mrs. Polyxeni (Xenia) Kazoli, as a
new member of the Committee. On the same date, the Committee convened with the sole agenda item being its reconstitution
into a body. The Committee members unanimously decided to appoint Mr. Ioannis Petrides as Chairman of the Committee.
The Remuneration and Nomination Committee meets regularly and informs the Board following each meeting.
Information on the composition, meetings and activities of the Remuneration and Nomination Committee during the year 2024
are listed below.
Composition and meetings of the Remuneration and Nomination Committee in 2024
Composition of the
Remuneration and
Nomination Committee
Status
Meetings in 2024
Attendance rate
of meetings
Ioannis Petrides
Chair
10/10
100%
Emmanouil Kakaras
Member
10/10
100%
Konstantina Mavraki
Member
10/10
100%
Polyxeni (Xenia) Kazoli
Member
5/10
100%*
*Mrs. Kazoli was appointed as a member of the Remuneration and Nomination Committee by a decision of the BoD, dated
24.07.2024.
Note: The term of office shall be four years, which shall be extended until the first ordinary general meeting following the expiry
of the term of office.
The Committee’ s Secretary is the Company Secretary Mrs Leda Condoyanni, with Mr. Panagiotis Psarreas as her Deputy
Company Secretary.
Further information on the remit, responsibilities and the modus operandi of the Remuneration and Nomination Committee are
available in the Committee’s Terms of Reference, which have been released in the Company’ s website
https://www.metlengroup.com/ at the following address: https://www.metlengroup.com/who-we-are/governance/corporate-
governance/committees#section4.
Provision 33. Role of the remuneration committee
The Committee has not delegated responsibility but submits the policy for executive director remuneration to the Board for
approval. However, the Committee recommends the Remuneration Policy to the Board for approval and the Board submits the
Remuneration Policy to the General Meeting of Shareholders for approval. Any matter submitted for approval by the General
Meeting of Shareholders shall be approved by the Board.
Fixed pay for the Chair, who is also the CEO currently, and for the executives of the Company is set by the Board of Directors
upon the recommendation of the Committee, taking into account levels of pay at other companies of a similar size for roles of
similar scope and responsibility.
The Remuneration Policy for the Executive Directors, as for all employees, is based on the principle of paying fair and reasonable
remuneration for the best and most appropriate person for the role while ensuring that the Company pays fairly and
competitively and in the longer-term interests and sustainability of the Company. The Company is considering the possibility of
establishing a remuneration and benefits policy for employees.
7. Statement of Corporate Governance
369
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Committee and Board of Directors receive periodic updates on the wider employee remuneration structure and practices
within the Company, which are considered when establishing and revisiting the Policy. This is to ensure that remuneration
practices and structure are as consistent as possible across the Company, while acknowledging that the structure of remuneration
for Executive Directors is necessarily different to that of less senior employees as a result of their role and ability to impact the
performance of the business.
In addition, the Committee and Board of Directors are provided with information on remuneration trends across the Company
including average pay increases along with any relevant economic data, such as the rate of inflation to take into account when
operating the Policy.
Provision 34. Non-executive director remuneration
The remuneration of the non-executive directors is determined by the Board on the recommendation of the Chairman and CEO
in accordance with the remuneration policy. The remuneration of non-executive directors is not comparable to the structure of
remuneration for the employees and executive directors of the Company.
The Non-Executive Directors are paid a basic board fee which is fixed and covers for the time required to perform their duties.
Supplemental fees may be paid to the Non-Executive Directors for additional responsibilities and activities, which exceed the
scope of the duties assigned including but not limited to, attending site visits, and meetings with management. According to the
current Remuneration Policy, it is clarified, on the one hand, that no variable remuneration based on performance, retirement
program, or other benefits are provided to the non-executive Chairman or Non-Executive Board Members. On the other hand,
Independent Non-Executive Board Members do not receive remuneration for any reason other than their participation in the
Board and/or its Committees.
In 2024, the issue of adjusting the remuneration of the non-executive members of the Board of Directors was discussed, taking
into account that both the workload and the responsibilities of the non-executive members of the Board and the Lead
Independent Director have significantly increased in complexity and in terms of the time required to fulfill their duties. This is
due to new European legislative initiatives and the regular participation of members in non-executive meetings. It is noted that
non-executive Board members receive only fixed remuneration.
In this context, the following were also considered:
a. A benchmarking study conducted by the external consultant Korn Ferry, which was presented to the Committee.
b. A European study, including Greece, conducted by WTW in collaboration with ecoDa, providing comparative data on the
remuneration of non-executive board members across European countries.
Based on the findings of these studies, it was determined that the level of remuneration for the non-executive Board members
and the Lead Independent Director of the Company needed to be strengthened to align with the significance of their roles.
Following a relevant recommendation from the Remuneration and Nomination Committee, the Board of Directors approved this
increase.
Provision 35. Use of remuneration consultants
The Remuneration and Nomination Committee appointed Korn Ferry, an independent remuneration consultant, to work with
the committee in drafting the new policy. The consultant assisted the Committee in their engagement with the Management
Team and worked with all the relevant management units of the company. To arrive at the Policy the consultant discussed with
the Committee the requirements of Law 4548/2018, which transposed the SRDII, and the UK Corporate Governance Code. Korn
Ferry is not affiliated with members of the Board of Directors and provides remuneration consulting services to the General
Division of Human Resources.
Provision 36. Durations of retention
In the Long-Term Incentive Program, the fees are set at 30% in year 4, 30% in year 5 and 40% in year 6. The Company considers
that through these vesting periods and the gradual attribution of the shares, the purpose of Provision 36 of the UK Corporate
Governance Code is achieved. With the approval of the Board of Directors, the payment can be made in shares or in the
equivalent of value in cash with the obligation of the Executive member of the Board of Directors to buy shares of the Company,
at a rate of 30% of the total value granted, as well as to hold them for 2 years.
7. Statement of Corporate Governance
370
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Provision 37. Discretion and recovery
Temporary derogations from the Policy may be allowed in exceptional circumstances, for example in circumstances of
recruitment or retention, where it is considered by the Board of Directors necessary to serve the long-term interests and
sustainability of the Company as a whole, or to assure its viability. Any derogation is required to be considered and approved by
the Board of Directors. The elements of the Policy from which a derogation is possible are those which determine short and long-
term incentives.
Payments under both the short-term as well as the long-term incentive scheme will be subject to recovery for a period of at least
3 years from payment in the event of certain specified events including inaccurate financial statements of previous years or
otherwise erroneous financial data used to calculate such short-term incentive scheme payouts and misconduct.
Provision 38. Pension Contributions
In 2024, as part of its strategy for employee development and support, fostering a sense of security and stability, and considering
changes in the pension system, the Company announced the launch of the pension program “Invest in You”. According to the
announcement, METLEN will retroactively pay employer contributions proportionally from September 1, 2023. The pension
program is designed to provide a competitive benefits framework and offer employees the security and confidence they need to
plan for their future. To ensure proper and comprehensive employee awareness, the Company organized dedicated informational
sessions.
Provision 39. Contract periods and bonuses on appointment and departure
The Remuneration and Nomination Committee ensures compensation commitments in directors' terms of appointment do not
reward poor performance.
In case of termination of contractual arrangements with Executive Directors at the initiative of the Company, notice periods and
termination payments shall be as provided by the current legal requirements in the Board Remuneration Policy.
Currently, according to law, notice periods are up to 4 months based on the years of employment while the maximum amount
for severance are up to 12 monthly salaries based on the years of employment. Executive Directors of the Board, in their capacity
as such, are not entitled to severance payments or other compensation by the Company, for loss of office or otherwise howsoever
arising.
Last, payments under both the short-term and long-term incentive schemes will be subject to recovery for a period of at least 3
years from payment in the event of certain specified events including inaccurate financial statements of previous years or
otherwise erroneous financial data used to calculate such short-term incentive scheme payouts and misconduct.
Provision 40. Design of remuneration policy
The remuneration policy for the Executive Directors, as for all employees, is based on the principle of paying fair and reasonable
remuneration for the best and most appropriate person for the role while ensuring that the Company pays fairly and
competitively and in the longer-term interests and sustainability of the Company.
Shareholder voting guidelines on Executive Directors’ remuneration and best practice were taken into consideration as part of
the process in formulating the Board Remuneration Policy.
The Remuneration and Nomination Committee and Board of Directors receive periodic updates on the wider employee
remuneration structure and practices within the Company, which are considered when establishing and revisiting the Policy. Also
the General Manager of Human Resources is invited to attend all or part of any meeting of the Committee to provide input on
employment trends.
Provision 41. Reporting on the remuneration committee
The Remuneration and Nomination Committee held during 2024 ten (10) meetings. All members of the Committee attended all
the meetings.
7. Statement of Corporate Governance
371
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Annual variable remuneration, performance criteria, and achievement of goals for 2023
During 2024 the Committee:
a. Thoroughly discussed, examined, confirmed, and approved the achievement of the 2023 goals regarding the one-off share
plan for Executive Members of the Board, excluding the CEO, and Senior Management.
b. Reviewed, examined, and approved the list of beneficiaries of the Long-Term Incentive Plan for 2023 (LTIP 2023) for the
Executive Members of the Board of Directors, Senior Management, Executives, and the Head of Internal Audit.
c. Evaluated the criteria and confirmed the achievement of the targets set for the Executive Board Members and Senior
Management under the 2021 Long-Term Incentive Plan (LTIP 2021), which was the first of five programs to be completed,
and approved the beneficiaries of the program. Specifically, the two corporate criteria and the achievement of the related
targets, based on which shares were awarded to the beneficiaries according to the Company’s financial data, are as follows:
Three-Year Period 2021-2023
Corporate criteria LTIP (VESTED)
Target
Achievement
Total Shareholder Return (TSR) Index in relation to the FTSE/ATHEX
Large Cap Index, excluding Banks.
Higher than the Index
434%
Earnings Per Share (EPS) as an absolute figure
≥ €1,28
€3,036
(Three-year average)
- Performance criteria weighting = 50%
- Minimum achievement level required to activate the program = ≥95% over a three-year period
As a third criterion, average individual performance is also considered, which must be ≥85% during the aforementioned three-
year period.
d. Reviewed and confirmed the achievement of targets for ongoing Long-Term Incentive Plans (LTIP).
e. Reviewed and approved the calculation mechanism for annual variable remuneration for the 2024 financial year (STIP 2024)
for Senior Executive Management (N-1) and Executive Management (N-2).
f. Reviewed and confirmed the achievement of corporate, operational, and personal targets set for the Chairman, Executive
Board Members, Senior Executive Management, and the Head of Internal Audit for the 2023 financial year (STIP 2023), and,
based on these, determined the annual variable remuneration.
e. Reviewed the annual evaluation of the Chairman and CEO 2023, led by the Chairman of the Committee in his capacity as
Lead Independent Director. Confidential feedback from all Non-Executive Members of the Board, including the First Vice-
Chairman, as well as Committee members, was taken into account for the evaluation. The assessment covered various areas
of the CEO's responsibilities, including Strategy, Organization, Board Effectiveness, Progress on Environmental, Social, and
Governance (ESG) matters, achievement of the 2023 financial goals, and stock performance. The Committee unanimously
agreed on the annual evaluation, and the corresponding text was sent to the Non-Executive Board Members for discussion
and approval.
For all the above, the Committee submitted a relevant recommendation to the Board of Directors.
Remuneration Report of the members of the Board of Directors for the year 2023
The Remuneration Report of the members of the Board of Directors of the Company for the year 2023 was drafted by the
Committee with the assistance of an external consulting firm (KornFerry) and the Human Resources Division, in accordance with
the applicable legislation and the EU Directive on shareholder rights, which was incorporated into Greek law by Law 4548/2018.
For the drafting of the 2023 Remuneration Report, consideration was given to the consultation of the European Commission of
March 1, 2019, regarding the guidelines for the standardized presentation of the Remuneration Report under Directive
2007/36/EC. External auditors (certified auditors) prepared a relevant report on the conduct of agreed procedures
https://www.metlengroup.com/media/sl4fdnrl/item-3_mytilineos-rem-report-2023-eng.pdf.
The report describes how the 2023 Remuneration Policy was implemented, taking into account the key principles of
remuneration, the design of remuneration, as well as the performance achieved at both the Company and executive levels during
7. Statement of Corporate Governance
372
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
the year 2023. The report also outlines how the opinions of significant institutional investors of the Company were taken into
consideration, as derived from the dialogue with shareholders that took place during 2023 (Corporate Governance Roadshow).
The Committee ensured that the remuneration of the Executive Members of the BoD is aligned with METLEN' business strategy
and supports it. This alignment is achieved as the strategic business objectives serve as the basis for determining the financial
and strategic individual objectives of the Executive Members of the BoD. The process is part of the Board’s annual program, with
the approval of the objectives at the beginning of the financial year.
The Report was submitted to the BoD for approval and to the General Meeting of June 4, 2024, for advisory voting and received
positive votes at a rate of 59.57%
https://www.metlengroup.com/media/rhvltqxr/voting_results_of_the_annual_general_meeting_01_06_2023.pdf
Further information on this matter is included under Provision 4.
Approval of targets for the year 2024
a), b) Individual targets (Operational/Financial KPIs, Human Capital Index) και γ) Individual Performance Rating (scale
1-4).
The Committee, with the support of the Chief Human Resources Officer, thoroughly discussed and approved the performance
criteria for annual variable remuneration for the 2024 financial year (STIP 2024) for the Executive Board Members and Senior
Executive Management. Specifically, the mechanism for calculating annual variable remuneration (Mechanism for calculating
STIP N-1) for Senior Executive Management (N-1) and Executive Management (N-2) was discussed and approved, along with the
weighting of the criteria.
Specifically, the performance criteria for N-1 and N-2 are categorized into three groups:
a) BU (EBITDA, Op. Cash Flow, Group ESG KPIs)
b) Individual Targets (Operational/Financial KPIs, Human Capital Index)
c) Individual Performance Rating (scale 1-4).
Additionally, there are two more categories of criteria: a) Group gate/Group targets (EBITDA, Net Income, Op. Cash Flow) and b)
ESG KPIs (CO2 emissions/million € of Revenue, Lost time injury rate (LTIR), Total amount of monetary losses from legal
proceedings with charges of bribery, corruption, and anticompetitive practices), with equal weighting. Particularly regarding the
ESG criteria, which aim to sensitize the entire Company to ESG issues, it was emphasized that it is very important to recognize
and incorporate ESG criteria concerning proper environmental and social practices.
Additionally, there is another category of criteria: Group Gate/Group Targets, which includes Net Income and Operating Cash
Flow.
For the above matters, the Committee subsequently submitted a relevant recommendation to the Board of Directors.
Adjustment of Fixed Remuneration for Board Members
As previously mentioned, the Committee discussed the adjustment of the remuneration for non-executive Board members,
considering the significant increase in both the workload and responsibilities of the non-executive Board members and the Lead
Independent Director, particularly in terms of complexity and the time required to fulfill their duties. The Committee approved
the increase in the remuneration of non-executive Board members, including the Lead Independent Director, and submitted a
relevant recommendation to the Board of Directors.
Furthermore, with the support of the Chief Human Resources Officer and the external consultant Korn Ferry, the Committee
reviewed the existing level of fixed remuneration for Executive Board Members and Senior Executive Management (Chiefs) in
comparison to market standards. This assessment also included the annual variable remuneration program (STIP), the long-term
incentive plan (LTIP), the pension plan, and, most importantly, the total remuneration package, as well as the ratio between fixed
and variable remuneration.
Specifically, the Committee examined:
a) A benchmarking study on Board Member remuneration within the Peer Group of Companies, which was initially
approved by the Committee on 07.03.2023, with updated data for the purpose of this review.
b) The “European General Executive Market” study.
7. Statement of Corporate Governance
373
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Based on these evaluations, the Committee decided to increase the fixed remuneration for Executive Board Members and Senior
Executive Management and submitted a relevant recommendation to the Board of Directors.
Determination of the Annual Fixed Remuneration of the CEO for 2024
The Committee discussed the fixed remuneration of the Chief Executive Officer (CEO) for the year 2024. According to the 2023
Board Member Remuneration Policy, fixed remuneration is provided as part of the total remuneration package for executive
Board members. The Committee members unanimously decided on the amount, as outlined in the 2024 Remuneration Report,
and approved its payment as a reasonable and fair compensation for Mr. Mytilineos in his role as CEO of the Company for 2024.
A relevant recommendation was submitted to the Board of Directors.
Remuneration and Benefits Strategy for the Company’s Workforce and Other Matters
The Committee, with the support of the Chief Human Resources Officer, was briefed on the progress of Human Resources
Department projects related to: a) The remuneration and benefits strategy for the Company’s workforce. b) The job grading scale
(Job Model – formerly job grading). c) The “LeadMe” training program (Leadership Academy). d) The Global Induction program
for new employees.
The primary goal of the Company’s remuneration and benefits strategy is to attract, retain, and develop talent based on
meritocracy, equity, transparency, and performance. The Committee discussed the principles underlying the strategy’s design,
such as the Company’s market position, key benchmarking indicators, the link between pay and performance, and overall cost
considerations. The Committee also reviewed the core categories of remuneration (e.g., STIP, LTIP) and benefits (e.g., life
insurance, pension plan, company car allowance, etc.).
The Committee was informed about and discussed the “Metlen Job Model”, related to the job grading scale (formerly job
grading), which was based on the Korn Ferry methodology. The project commenced in Q4 2023 with the analysis and evaluation
of senior executive positions and was completed in Q2 2024.
7. Statement of Corporate Governance
374
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2.1. ROLE AND RESPONSIBILITIES OF THE BOARD
2.1.1. Acting collectively, the Board of Directors is entrusted with the governance, i.e. management and representation, of the
Company and has authority to decide on all matters relevant to the administration of the Company, management of the
Company’s property and the pursuit of the object of the Company, except for those matters which under the law or under the
Articles of Association fall within the exclusive authority of the General Meeting, with the aim of strengthening the Company’s
economic value and profitability, of promoting its long-term sustainable success and of safeguarding the Company’s interests.
The Board is furthermore entrusted with the full and effective control of the Company business and acts in conformance with
the provisions of law, the Company’s Articles of Association and the Terms of Reference of the Board of Directors.
The Board of Directors holds a meeting whenever the law, the Articles of Association or the needs of the Company so dictate. It
is the Company's practice that the Board of Directors meets regularly at least once per month, and several times on an
extraordinary basis whenever important issues arise or there is a need for immediate decision-making. The regular meetings of
the Board of Directors are usually attended by all Board members. Thus far, the Board of Directors has never postponed making
a decision because of lack of quorum.
According to the Articles of Association and the Company’s Internal Regulation, the main responsibilities of the Board of Directors
include, indicatively, the following:
i. Setting the strategic directions, including the sale or other disposal of the Company’s shares, the acquisition of any
enterprise or the proposal for the merging of the Company with another enterprise, which are submitted for final
approval by the General Meeting of the Company’s shareholders.
ii. Adopting and implementing the general policy on the basis of the recommendations and suggestions made by the
General Managers and Directors heading the Company's Business Units and Central Functions.
iii. Managing and disposing of the Company’s assets as well as representing the Company judicially or extra-judicially.
iv. Drafting the Company’s annual budget and business plan, defining and meeting its efficiency objectives, monitoring
the Company’s progress and controlling major capital expenditure.
v. Monitoring the effectiveness of the Corporate Governance principles, based on which the Company operates, and
making the necessary changes when needed.
vi. Defining the strategy and the risk management policy of the Company.
vii. Selecting, managing and developing the Company’s senior executives and defining the policy for their remuneration.
viii. Appointing an internal auditor and defining his/her remuneration.
ix. Making a brief presentation of the proceedings to the General Meeting of the Company’s shareholders.
x. Preparing annual reports which state in detail all the transactions between the Company and its associated
companies in accordance with the applicable laws.
xi. Formulating, promoting, and implementing the core values and principles of the Company, which govern its
relations with all parties whose interests are linked to those of the Company.
xii. The definition and supervision of the implementation of the Corporate Governance System and the monitoring and
evaluation periodically at least every three (3) financial years of its implementation and effectiveness.
xiii. To ensure that the Company's System of Internal Control is adequate and effective, and that the functions that
make up the System of Internal Control are independent of the business areas they control, and that they have the
appropriate financial and human resources, as well as the authority to operate effectively, as required by their role.
2.1.2. The Executive Members of the Board are entrusted in particular with the following responsibilities,:
i. Implementing, in cooperation with the competent senior management, as appropriate, the strategy determined by
the Board;
ii. consulting regularly with the non-executive members on the appropriateness of the strategy being implemented;
iii. assisting the CEO in the latter’s communication with the Board members; and
iv. discharging such other specific responsibilities as may be determined by resolutions of the Board.
Executive members should accept constructive criticism from non-executive members as an important sign of good
governance and encourage non-executive members in this respect, based on their broader experience outside the Company.
II. COMPOSITION AND FUNCTIONING OF THE BOARD OF DIRECTORS
7. Statement of Corporate Governance
375
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2.1.3. The Non-Executive Members of the Board, including the independent non-executive members, act in a supportive manner
to improve the Board’s functioning based on their knowledge and experience. In particular, they have the following obligations:
i. To monitor and review the Company’s strategy and its implementation, as well as the achievement of its objectives.
ii. To ensure effective supervision of the executive members, including monitoring and reviewing their performance at
individual and collective level.
iii. To consider and express views on proposals submitted by the executive members, based on existing information,
and to participate constructively and critically in the Board’s decision-making.
iv. To provide strategic guidance and expert advice based on their knowledge and experience, and to hold senior
management accountable when they deem it appropriate.
v. To participate (the independent non-executive members), according to their area of responsibility, in the Audit
Committee and the Remuneration and Nomination Committee, as well as in any other committee in which their
participation is provided for by law or is deemed necessary.
The Non-Executive Members should receive high-quality information sufficiently in advance, in order to be able to thoroughly
consider the issues to be discussed prior to the Board meetings and to allow for informed discussions to take place. They should
also seek clarification or amplification from the senior management, where they consider that the information provided is
inadequate or lacks clarity.
2.1.4. Role of the Chair
The role of the Chair is described under Principle F.
2.1.5. Role of the CEO
The CEO, according to the Terms of Reference of the Board of Directors, approved in 2022, sets the tone for the entire Company,
communicates expectations in relation to its system of values and ensures that business policies and practices lead to appropriate
behaviour, and the adoption of the appropriate governance standards throughout the Company. The CEO ensures that the Board
and especially the Independent Non-Executive Members are informed of the senior management’s views on business issues, and
explains in a balanced way any divergence of view prior to the adoption of a final decision. The CEO ensures that the senior
management provides the Board and especially its independent non-executive members with accurate, timely and clear
information, in a form and of a quality that will enable the Board members to discharge their duties. The CEO has, inter alia, the
following responsibilities:
i. Submits to the Board proposals for the achievement of the objects set forth in the Articles of Association and for
the preparation of the Company’s strategic and operational plan.
ii. Monitors and checks the implementation of the Company’s strategic goals, as well as its day-to-day management,
and sets out the guidelines for the Company’s Business Units and Central Functions. The CEO supervises and
ensures the smooth, orderly and effective operation of the Company in accordance with the strategic goals, the
business plans and the action plan, as these are specified by resolutions of the Board and of the General Meeting.
The CEO participates in and reports to the Board and implements the Company’s strategic choices and major
decisions.
iii. In existing crisis or risk situations, as well as when circumstances dictate the adoption of measures which are
reasonably expected to significantly affect the Company , such as when decisions are to be taken regarding the
development of business activities and the risks assumed, which are expected to affect the Company’s financial
situation, the CEO informs the Board without delay, either jointly with the other executive members or on his/her
own, submitting a relevant report containing his/her estimations and proposals.
iv. Leads the Company’s executive staff and takes all necessary measures to upgrade and make the most of the
potential of its Human Resources, focusing on the principles of integrity, ethical values and sufficient knowledge of
the staff.
v. Discharges all the responsibilities delegated to the CEO by the Board.
2.1.6. Role of the Vice-Chairs
The Non-Executive Vice-Chair A has the following responsibilities and obligations:
i. deputizing for the Board Chair in all of the latter’s responsibilities, when the Board Chair is absent or
prevented from attending;
ii. chairing the procedure concerning the evaluation of the Board;
iii. monitoring and ensuring the smooth and effective cooperation and communication between the Board
Committees and the Board.
The Executive Vice-Chair B has the following responsibilities and obligations:
7. Statement of Corporate Governance
376
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
i. undertaking the specific responsibilities assigned to the Vice-Chair B by the Board;
ii. deputizing for the Board Chair in all of the latter’s responsibilities, when the Board Chair is absent or
prevented from attending and the Vice-Chair A is also absent or prevented from attending.
2.1.7. Role of the Lead Independent Director
The role of the Lead Independent Director is described under Provision 12.
2.1.8. Role of the Company Secretary
The role of the Company Secretary is described under Provision 16.
7. Statement of Corporate Governance
377
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2.1.9. Other professional commitments of Board Members
Board Member
Board Role
Non-Executive responsibilities
in other Listed Company
Executive responsibilities in
Unlisted Company
Non-Executive responsibilities in
Unlisted Company
Evangelos Mytilineos
Chairman & CEO
-
-
-
Spyridon Kasdas
Vice-Chairman Α΄- Non-
Executive Member
-
-
-
Evangelos Chrisafis
Vice-Chairman Β΄- Executive
Member
-
-
«GOLDEN SOLAR S.A.»
üBoard Member
GOLDEN YACHTING MARI-TIME
COMPANY OF PLEASURE YACHTS
ü Vice-Chair
Dimitrios Papadopoulos
Executive Member
-
METLEN
ü Board Member – MNG
Trading S.A.
ü Administrator - “Agios
Nikolaos” Sole Proprietorship
IKE
SO & PEN Private Company
ü Administrator (*)
Mountain and Winter
Getaways
Council for Sustainable Development
- SEV
ü Board Member
7. Statement of Corporate Governance
378
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Board Member
Board Role
Non-Executive responsibilities
in other Listed Company
Executive responsibilities in
Unlisted Company
Non-Executive responsibilities in
Unlisted Company
ü Chairman & Managing
Director
Christos Gavalas
Executive Member
-
CIEL MARE PRIVATE COMPANY
ü Administrator
Delphi Distomon – Subsidiary
company
üBoard Member
Ioannis Petrides
Lead Independent Director
PUIG S.A.
ü Board Member
üAudit Committee Chair
ü ESG Committee Member
Triton Partners Equity
Frankfurt
üSenior Industry Advisor (*)
CyPet Ltd
üBoard Member
-
-
Panagiota (Peggy) Antonakou
Independent Non-Executive
Member
-
Google S.E. Europe
ü General Manager
BLUEPIN Private Company
Onassis Foundation
ü Board Member
7. Statement of Corporate Governance
379
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Board Member
Board Role
Non-Executive responsibilities
in other Listed Company
Executive responsibilities in
Unlisted Company
Non-Executive responsibilities in
Unlisted Company
ü Administrator(*)
Anthony Bartzokas
Independent Non-Executive
Member
-
-
National and Kapodistrian University
of Athens
ü Professor -
Department of Economics
London School of Economics and
Political Science
ü Visiting Professor in Practice
United Nations University
ü Professorial Fellow
Emmanouil Kakaras
Independent Non-Executive
Member
-
GX (Green Transformation)
Solutions, Mitsubishi Heavy
Industries EMEA Ltd
ü Executive Vice-President
CERTH / CPERI (Centre for Research
and Technology Hellas / Chemical
Process and Energy Resources
Institute)
ü Academic Staff
National and Technical University of
Athens, Mechanical Engineering
School
7. Statement of Corporate Governance
380
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Board Member
Board Role
Non-Executive responsibilities
in other Listed Company
Executive responsibilities in
Unlisted Company
Non-Executive responsibilities in
Unlisted Company
ü Professor
University Duisburg Essen
ü Academic Staff
Polyxeni (Xenia) Kazoli
Independent Non-Executive
Member
Autohellas SA
ü Board Member
ü Member of the Nomination
and Remuneration Committee
Dimand SA
ü Board Member
ü Member of the Nomination
and Remuneration Committee
Athens Exchange Group
ü Board Member
ü Chair of the Remuneration
and Nominations Committee
ü Audit Committee Member
Hellenic Corporate Governance
Council
ü Chair
Supervisory Board of the Hellenic
Growth fund
ü Board Member
7. Statement of Corporate Governance
381
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Board Member
Board Role
Non-Executive responsibilities
in other Listed Company
Executive responsibilities in
Unlisted Company
Non-Executive responsibilities in
Unlisted Company
Konstantina (Tina) Mavraki
Independent Non-Executive
Member
-
INGENIOS LTD, UK
ü Executive Director
First Bauxite LLC
ü Board Member (*)
Natalia Nicolaidis
Independent Non-Executive
Member
AEGEAN AIRLINES S.A.
ü Board Member (*)
ü Remuneration & Nominations
committee Chair (*)
ü Sustainability Committee
Chair (*)
TITAN CEMENT
INTERNATIONAL S.A.
ü Board Member (*)
ü Audit & Risk Committee
member (*)
SMCP SA
ü Board Member (*)
ü Nomination & Compensation
Committee member (*)
Dynamic Counsel Ltd
ü Board Member (*)
-
7. Statement of Corporate Governance
382
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Board Member
Board Role
Non-Executive responsibilities
in other Listed Company
Executive responsibilities in
Unlisted Company
Non-Executive responsibilities in
Unlisted Company
Alexios Pilavios
Independent Non-Executive
Member
Trade Estates R.E.I.C
üBoard Member (*)
ü Audit Committee Chair (*)
-
Alpha Bank Group
ü Alpha Asset Management S.A.- Chair
ü ABC Factors S.A.- Vice-Chair
PLAISIO
ü Board Member (*)
ü Audit Committee Chair (*)
V.S.Κaroulias Μονοπρόσωπη Α.Ε. –
Single Member SA
ü Board Member (*)
(*) Acquisition of status after the election to the Board of METLEN
(**) None of the Board members, hold executive roles in listed companies other than METLEN
2.1.10. Board members and executive management shareholdings (31/12/2024) *
Last name
Name
Title
Position
31/12/2024
Mytilineos**
Evangelos
METLEN’s Energy & Metals Chairman and CEO
30,821,919
Kasdas
Spyridon
Vice-Chairman A, Non-executive member
15,300
Chrisafis
Evangelos
Vice Chairman B’ and Executive Director of the BoD for Regulatory & Strategic Energy & Infrastructure Issues
72,230
Gavalas
Christos
Chief Treasury & IR Officer
52,764
Papadopoulos
Dimitris
Chief Corporate Governance & Sustainability Officer
22,000
7. Statement of Corporate Governance
383
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Petrides
Yiannis
Lead Independent Director, Independent, non-executive member
7,600
Antonakou
Panagiota
Independent, non-executive member
4,000
Kalafatas
Ioannis
Chief Executive Director, Energy
78,926
Karaindros
Elenos
Chief Strategy and M&A Officer
62,392
Bouzali
Vivian
Chief Corporate Affairs & Communication Officer
34,212
Spyrakos
Fotis
Chief Administration Officer & Head of CEO's office
43,162
Stefanidis
Dimitris
Chief Executive Director, Metallurgy
43,392
Kontogianni
Eleftheria
Chief Finance Officer
1,116
Selekos
Petros
Chief Legal Officer
39,212
NOTE: **
FREZIA LTD
15,601,219
KILTEO LTD
15,118,330
MELVET INVESTMENTS LTD.
57,757
EVANGELOS MYTILINEOS
44,613
Total Direct and Indirect shareholdings of Mr. Evangelos Mytilineos
30,821,919
* Includes Indirect shareholdings
7. Statement of Corporate Governance
384
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2.2. BOARD PROFILE MATRIX
Name
Status
Committees
Age
(as at
31.12.2024)
Gender
Tenure in
office (as at
31.12.2024)
Business
leadership
Finance
BoD
membership
experience
International
Exposure
Specialisation
Academic
experience
International
Capital
Markets
Evangelos
Mytilineos
Chair & CEO
-
70
M
32 years
P
P
P
P
Energy &
Metals
Spyridon
Kasdas
Vice-Chair Α΄- Non-
Executive Member
Sustainability
Committee
78
M
6 years
P
P
P
Metals, Mining
Evangelos
Chrisafis
Vice-Chair Β΄-
Executive Member
-
61
M
6 years
Legal &
Regulatory,
Energy,
Infrastractures
Dimitrios
Papadopoulos
Executive Member
Sustainability
Committee
63
M
6 years
P
P
P
Banking,
Investments,
Sustainability,
Corporate
Governance
P
Christos
Gavalas
Executive Member
-
58
M
1 year
P
P
P
Treasury,
Financial
Markets,
Trading
P
Ioannis
Petrides
Lead Independent
Director
RemNom
Committee Chair
66
M
6 years
P
P
P
P
Consumer
products, Audit,
Remuneration
P
Panagiota
Antonakou
Independent Non-
Executive Member
Sustainability
Committee
50
F
6 years
P
P
P
IT, Marketing
Anthony
Bartzokas*
Independent Non-
Executive Member
Audit
Committee Chair
63
M
3 years
P
P
P
P
Capital
Markets, Audit,
Compliance,
Development
Funding
P
P
7. Statement of Corporate Governance
385
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Name
Status
Committees
Age
(as at
31.12.2024)
Gender
Tenure in
office (as at
31.12.2024)
Business
leadership
Finance
BoD
membership
experience
International
Exposure
Specialisation
Academic
experience
International
Capital
Markets
Emmanouil
Kakaras
Independent Non-
Executive Member
RemNom
Committee,
Sustainability
Committee
62
M
6 years
P
P
Energy
P
Polyxeni Kazoli
Independent Non-
Executive Member
RemNom
Committee
56
F
1 year
P
P
P
Finance, Capital
Markets, Legal
P
Konstantina
Mavraki
Independent Non-
Executive Member
RemNom
Committee,
Audit
Committee
48
F
6 years
P
P
P
Finance, Audit,
Risk,
Commodities
P
Natalia
Nicolaidis
Independent Non-
Executive Member
Sustainability
Committee
59
F
3 years
P
P
P
Legal, Risk,
Governance
P
Alexios Pilavios
Independent Non-
Executive Member
Audit
Committee
71
M
6 years
P
P
Asset
Management,
Capital Market
Supervision,
Banking
P
SECRETARIAT
Name
Status
Committees
Gender
Tenure in
office (as at
31.12.2024)
Business
leadership
Finance
BoD
membership
experience
International
Exposure
Specialisation
Academic
experience
International
Capital Markets
Leda Condoyanni
Company
Secretary
RemNom
Committee
F
6 years
P
P
P
P
Corporate
Governance,
Asset
Management,
P
7. Statement of Corporate Governance
386
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Corporate
Affairs
Vasiliki Prantzou
Audit Committee
Secretary
Audit
Committee
F
10 years
Legal
Panagiotis Psarreas
Deputy Company
Secretary
RemNom
Committee
M
11 years
Communication
Georgios Galanis
Sustainability
Committee
Secretary
Sustainability
Committee
M
3 years
Sustainability
Polytimi Boudali
Deputy
Sustainability
Committee
Secretary
Sustainability
Committee
F
6 years
Sustainability
* Mr. Alexios Pilavios served as Chair of the Audit Committee until September 1st, when the Committee was restructured, and Mr. Antonios Bartzokas took over as Chair.
7. Statement of Corporate Governance
387
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2.3. CONFLICTS OF INTEREST
The Company adopted and implements a Policy and Procedures on Conflicts of Interest, which has been approved by the Board
of Directors by its resolution dated 15.06.2021.
This Policy identifies the circumstances that constitute or may lead to a conflict of interest, while setting out the procedures to
be followed and the measures to be taken to mitigate, manage and resolve any such conflict in case they arise. This Policy
essentially provides directions to the Board of Directors, the Executive Management Team, the management and all employees
of the Company regarding the identification and management of conflicts of interest.
The Company strives to avoid conflicts of interest to ensure that it continues to operate in accordance with its purpose. In any
case, it takes all necessary measures to prevent conflicts of interest and, if such conflicts nevertheless arise, acts immediately for
their management and limitation, providing mitigation and resolution measures and applying the necessary controls, pursuant
to the provisions of the aforementioned Policy.
Each member of the Board of Directors, and any third party the Board has delegated the exercise of powers vested in it, has a
duty of loyalty to the Company and they are expected not to pursue interests of their own that run contrary to the interests of
the Company. Board members act with integrity and in the Company’s interests and safeguard the confidentiality of information
that is not publicly available. They must not have a relationship of competition with the Company and should avoid any position
or activity that creates or appears to create a conflict between their personal interests and those of the Company, including
holding positions on the board of directors or the management of competitor companies, without permission from the General
Meeting of the Company's shareholders. Board members must contribute their experience and devote to their duties the
necessary time and attention.
Prior to their appointment, they should notify the Board of Directors of their other professional commitments, including
significant non-executive commitments, to companies and non-profit institutions, and should report to the Board any changes in
such commitments, as soon as these arise. Furthermore, they should timely and adequately disclose to the Company’s
Compliance Division and the other members of the Board of Directors their own interests which may arise from any company
transactions and/or activities of the Company falling within their scope of duties, as well as any other conflict of interest they
may have with those of the Company or an affiliated company. The members of the Board of Directors and of the Executive
Management Team of the Company are required to submit to the Compliance Division of the Company a “Conflict of Interest
Declaration”, as detailed in the aforementioned Policy and in the form attached thereto, at the time of onboarding into the
Company, as well as on an annual basis and should also update it in the course of the year, if required. No member of the
Company’s Board of Directors is allowed to vote on issues for which a conflict of interest exists between him/her (or one of
his/her “relatives” under the meaning of the aforementioned Policy) and the Company’s interest. In such a case, resolutions are
passed by the other members of the Board of Directors.
The Compliance Division of the Company considers and assesses all conflicts of interest disclosed to it and decides on the
measures that may need to be taken to appropriately resolve, mitigate or manage the identified conflicts, informing the person
concerned accordingly. The Compliance Division keeps record of all cases of conflicts of interest that have been disclosed to it
and the decisions it has taken to address them, and, at least annually, it informs the Company’s Audit Committee, of all the above
incidents that have occurred and the decisions taken during the year, by way of submitting a relevant report to it.
2.4. MEETINGS OF THE BOARD OF DIRECTORS
During 2024, the Board of Directors of the Company held 61 meetings. The table below shows the Board members’ attendance
of the meetings of the Board of Directors and of the Board Committees:
Meetings of the Board of Directors during 2024
Composition of the
Board of Directors
Status
Meetings during 2024
(Total number of 61)
Attendance rate of
meetings
Evangelos Mytilineos
Chairman & CEO
60
98%*
Spyridon Kasdas
Vice-Chairman A’ – Non-
Executive Member
61
100%
7. Statement of Corporate Governance
388
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Evangelos Chrisafis
Vice-Chairman B’ –
Executive Member
60
100%
Panagiota Antonakou
Independent Non-Executive
Member
61
100%
Emmanouil Kakaras
Independent Non-Executive
Member
61
100%
Polyxeni (Xenia) Kazoli
Independent Non-Executive
Member (since 04.06.2024)
36**
100%
Konstantina Mavraki
Independent Non-Executive
Member
61
100%
Dimitrios Papadopoulos
Executive Member
61
100%
Ioannis Petrides
Independent Non-Executive
Member, Lead Independent
Director
61
100%
Alexios Pilavios
Independent Non-Executive
Member
61
100%
Natalia Nikolaidi
Independent Non-Executive
Member
61
100%
Anthony Bartzokas
Independent Non-Executive
Member
61
100%
Christos Gavalas
Executive Member
60
98%
(*) The Chairman and CEO was absent from the discussion and voting on the agenda items of one Board meeting due to a
potential conflict of interest as defined by Article 97 of Law 4548/2018.
(**) Ms. Polyxeni (Xenia) Kazoli was elected as an independent non-executive member of the Board of Directors by the decision
of the Annual General Meeting on June 4, 2024.
Concerning the number of Board meetings, we note that pursuant to Greek Law, the Articles of Association of the Company and
the relevant resolutions of the General Meetings of the shareholders regarding the delegation of authorities within the Board of
Directors, collective action by the Board is required for a number of matters, such as for providing a corporate guarantee in favour
of any third party, including companies associated with the Company. Also taking into consideration the Company’s extensive
activities in Greece and abroad the Board of Directors often must act collectively, in the sense that there is a requirement for a
relevant resolution which must be reflected in the minutes of the respective Board’s meeting.
7. Statement of Corporate Governance
389
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
However, it should be noted that no administrative or other costs incur for the Company as a result of these resolutions. The
relevant minutes of the Board’s resolutions are drafted and are signed by circulation by all members of the Board, without a prior
meeting of the Board taking place, pursuant to art. 94 of L. 4548/2018. More specifically, out of the total number of 61 minutes
of the Board's meetings during 2024, 53 of them were drafted and were signed by all members of the Board without a prior
meeting of the Board taking place.
2.5. MEETINGS OF NON-EXECUTIVE MEMBERS OF THE BOARD
During 2024, the Non-Executive Members of the Board held five (5) meetings without the presence of the Executive Members of
the Board, to discuss, among other, the following issues:
Company Strategy
The Non-Executive Board Members were briefed by the Group Executive Director of Strategy and Mergers & Acquisitions
regarding the Company’s strategy, specifically on the following topics:
i. Strategic direction post-BIG2
ii. Division of the department into three sectors: 1) VC Concession, 2) Strategic Transactions and 3) Strateg
iii. Synergy benefits between Energy and Aluminum
The Non-Executive Members highlighted, among other points, the critical role of risk assessment in transactions as a key factor
in shaping the Company's strategy.
Additionally, the Non-Executive Members engaged in discussions with the Vice Chairman and CEO of METKA ATE regarding the
2024 budget, key risks, organizational structure, and strategic matters.
Evaluation of the Chairman and CEO for the Year 2024
The Non-Executive Board Members were briefed on and thoroughly discussed the recommendation of the Remuneration and
Nomination Committee regarding the evaluation of the Chairman and CEO, Evangelos Mytilineos, for the year 2023. The
evaluation was unanimously approved by the Non-Executive Board Members.
Energy Sector
The Non-Executive Board Members received a detailed briefing and engaged in discussions with the responsible Group Executive
Director regarding the current state and trends in the energy market, key financial indicators of the Energy Sector and the
Company’s strategy within this sector.
The Non-Executive Members focused on the retail market, the Company’s strategic partnerships, risk management issues, the
evaluation of the Energy Council’s operations, and the growth pillars for achieving profitability targets.
Other Matters
The Non-Executive Board Members were briefed on and discussed various topics, including the Company’s relisting, the ERM risk
register as well as proposals for improving the CEO Report presented to the Board, with the aim of enhancing the clarity of key
issues and ensuring more comprehensive Board updates.
Additionally, a meeting was held with the Chief of Staff, who presented and discussed her role and responsibilities within the
Company. Specifically, she highlighted her dual role, which includes managing the IT and Digital departments, as well as leading
initiatives to enhance operational efficiency, monitoring cross-functional initiatives, participating in and representing the
Chairman and CEO in ERM projects and other strategic initiatives, and promoting synergies within the Company.
The Non-Executive Members focused on enhancing cross-departmental communication, ensuring a smooth flow of information
to Board Members and prioritizing key projects.
Finally, the Non-Executive Members were briefed on and held discussions with the newly appointed Chairman of the Audit
Committee, Anthony Bartzokas.
2.6. POLICY FOR THE SUITABILITY ASSESSMENT OF THE BOARD MEMBERS
The Company has adopted and implements a Policy for the Suitability Assessment of the Members of the Board of Directors
(Suitability Policy), which has been approved by decision of the General Meeting of 15.06.2021, following the approval of the
Board of Directors by its resolution dated 12.05.2021, and constitutes the set of principles and criteria that apply when selecting,
replacing, and re-appointing Board members, in terms of assessing their suitability on an individual and collective level. This Policy
7. Statement of Corporate Governance
390
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
aims to ensure the quality of recruitment to the Board, its effective functioning and fulfilment of its role, based on the Company’s
general strategy and medium and long -term business goals for promoting its corporate interest.
The Policy for the Suitability Assessment of the Members of the Board of directors is posted on the Company’s website at the
following addresshttps://www.metlengroup.com/media/xtjc3lwx/suitability_policy_en_26072021.pdf
The general principles governing the aforementioned Policy include the following:
i. The Company’s Board of Directors should consist of persons of moral standing and good repute, and it should have
an adequate number of members and an appropriate composition, which should reflect the knowledge, skills and
experience necessary to fulfil its responsibilities, according to the Company’s business model and strategy. The
Board members should also commit sufficient time to carry out their duties.
ii. The Company promotes and ensures diversity and adequate representation of gender in its Board, in accordance
with the Diversity Policy and, in general, ensures equal treatment and equal opportunities, as well as that its Board
Members wield a broad spectrum of qualifications and competencies.
iii. Through the induction training program of the Board members, the Company ensures, inter alia, that each member
perceives and understands clearly the Company’s corporate governance arrangements, their respective role and
responsibilities, as well as the Company’s values, its general strategy and structure.
iv. A suitability assessment on an individual and collective level shall be conducted when selecting, re-appointing or
replacing a Member.
The suitability of the Board members is assessed both on an individual and a collective level.
Individual suitability means that a person is considered to have - as a Board member - sufficient knowledge, skills, experience,
independence of mind, good repute and moral standing for the performance of their duties as a member of the Company’ s
Board, for which performance of duties he/she shall also commit sufficient time, pursuant to the said Policy, which establishes
specific criteria for the assessment of all above factors.
Collective suitability means that the Board collectively should be suitable for carrying out its responsibilities and should be
composed in such manner as to contribute to the effective management of the Company and to balanced decision-making. Board
members should collectively be able:
i. to take appropriate decisions considering the business model, risk appetite, strategy and the markets in which the
Company operates;
ii. to evaluate corporate performance properly;
iii. to support the Company’s Management and provide directions and guidance where and when required; as well as
iv. to monitor and challenge the implementation of the Board’s decisions by the Company’s Management.
The Suitability Policy sets out clear criteria for assessing the collective suitability of the Board as well. For instance, the
composition of the Board should reflect the knowledge, skills and experience necessary to fulfil its responsibilities and the Board
members should collectively have the skills necessary to present their views. In general, all the sectors in which the Company
operates, as well as any other related subject (indicatively, finance and capital markets) should be covered by the Board
collectively, with sufficient expertise among its members.
The Company bears the primary responsibility for identifying shortcomings in both the individual and the collective suitability of
Board members and to this end the Board conducts a self-assessment annually. This suitability assessment is part of the annual
assessment of the Company’s Board, which is conducted by the Remuneration and Nomination Committee. The findings of this
assessment are processed and presented to the Board by its Chair, acting in collaboration with the Lead Independent Director.
In the context of the Board’s assessment, the Board may, at its discretion and upon recommendation of the Remuneration and
Nomination Committee, decide to have its assessment conducted also by third party consultants, either on a regular or ad hoc
basis.
Apart from the aforementioned regular assessment of the Board members’ suitability, their individual or collective suitability
shall also be assessed in exceptional circumstances, especially in the cases mentioned in the Suitability Policy.
In the event that any Board member no longer meets one or more of the suitability criteria, as described in the said Policy, and
that this affects the Board’s individual or collective suitability, the possibility shall be examined of taking corrective measures to
address the weakness identified.
The Remuneration and Nomination Committee shall keep a record of the results of the suitability assessment, particularly any
weaknesses/shortcomings between the expected and the actual individual and collective suitability, also of any measures taken
to address those deficiencies.
In case that one or more of the suitability criteria ceased to exist in the person of a member of the Board for reasons that this
member could not prevent, even with extreme diligence, the Board shall arrange for their dismissal and replacement within three
(3) months.
7. Statement of Corporate Governance
391
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2.7. INDUCTION PROGRAMME FOR NEW BOARD MEMBERS
The Company has adopted and applies a Training Policy for the members of its Board of Directors, according to which the
Company’s Lead Independent Director, assisted by the Corporate Secretary, shall ensure:
i. on the one hand, that upon taking up their duties all Board members are provided with a full induction programme,
tailored to their capacity (executive, non-executive, or independent non-executive member) and the tasks assigned to
them; and
ii. on the other hand, that all Board members update their skills and knowledge on an ongoing basis, in order to effectively
fulfil their duties as members of the Board and its committees, subject to continuous training by the Company for this
purpose, in accordance with the detailed provisions of the Training Policy.
No later than one month following their appointment, new Board members attend an induction programme, whose purpose is
to provide them with information that will be useful in the effective performance of their duties. In particular with regard to
Board members who are members of Board Committees, the induction also includes information on the scope of these
Committees. The training may be provided by any appropriate means and, in particular, in person or remotely, using
synchronous or asynchronous teaching methods, individually or in groups, during or outside working hours, at the Company's
headquarters or elsewhere. Indicatively, online seminars, programmes with physical presence, lectures may be organised.
The programme also relied on support provided by the Board’s executive members, as well as by previous Board members, so
as to ensure the fullest possible briefing and swift integration of the new Board members.
7. Statement of Corporate Governance
392
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Purpose
The Company has established a Sustainability Committee which, in accordance with the Company’ s Internal Regulation and the
Committee’ s own Terms of Reference, which were approved and put into effect by the Resolution of the Board of Directors
dated 15.06.2021, after having been approved by the resolution of the Committee of 26.05.2021, assists the Board of Directors
of the Company in integrating Sustainable Development policies and procedures in the Company’s basic decision-making
processes and operations. The purpose of the Committee is to assist the Board in strengthening the Company’s long-term
commitment to creating value in all three pillars of Sustainable Development (economy, environment and society) and in
overseeing the implementation of responsible and ethical business conduct, evaluated regularly on the basis of its results and its
performance in Environmental, Social and Governance (ESG) matters.
Establishment and composition
The Sustainability Committee was established by the Board of Directors decision of 2.4.2021. The composition of the Committee
is as follows:
i. The Committee shall consist of at least three (3) members, the majority of whom shall be non-executive Board
members and at least two (2) of whom shall be independent non-executive Board members. A third person, not a
Board member, also can be a member of the Committee.
ii. The exact number of members of the Committee shall be determined by the Board, which, moreover shall appoint
the members of the Committee.
iii. The members of the Committee shall appoint the Chair.
iv. In order that they carry out the Committee’s duties adequately, its members as a whole should possess the required
knowledge, skills and/or experience related to the Company’s activity and, in particular, regarding issues of
sustainable development, society and governance (ESG).
v. Following a proposal by the Remuneration and Nomination Committee, the Board shall assess the candidate
members of the Committee.
Unless the Board were to resolve otherwise, the Chair and the members of the Committee shall be appointed for a period equal
to the tenure of the Board, namely for four years.
The Committee shall appoint a Secretary and a Deputy Secretary to support its operations. In case no Secretary is appointed
according to the above, the Company Secretary and the Deputy Company Secretary or his/her deputy shall carry out the duties
of Secretary and Deputy Secretary of the Committee. The Committee Secretary shall be responsible for supporting the operation
of the Committee in general, including the keeping of the minutes and the proper implementation of the Committee meetings.
Meetings
The Committee shall meet at regular intervals, at least three (3) times a year, and extraordinarily whenever required, in order to
carry out its duties effectively.
The meetings of the Committee shall be attended by its members, its Secretary and or the Deputy Secretary, and the Company
Secretary, the latter to assist the Committee in matters of corporate governance. However, at its discretion, the Committee may
invite, whenever appropriate, third parties, within or outside the Company, to attend its meetings.
As required, the Committee may meet jointly with other Board Committees to discuss important matters of mutual interest.
Remit
The Committee has the responsibility to review the domestic and international trends in Sustainable Development annually and
to supervise and monitor the implementation of the Sustainable Development Policy in accordance with the Company’s strategy.
Furthermore, the Committee examines and approves the process to determine the material Sustainable Development topics
validating its results annually, which shall constitute the structure of the Company’s annual Sustainable Development Report. In
addition, the Committee monitors the progress of achieving the carbon dioxide (CO
2
) emissions reduction targets and the
Company’s performance in other material Environmental, Social and Governance (ESG) topics, informing the Board and proposing
corrective actions. The Committee is informed of and evaluates the results of the institution of the Consultation of Social Partners
providing the corresponding directions and examines the Sustainable Development and ESG topics in combination with the
Company’s priorities of communication and management of its reputation, proposing to the Board ways for the most effective
communication of these issues both within and outside the Company. Finally, the Committee evaluates its own performance and
effectiveness on an annual basis and proposes corrective actions if necessary.
III. SUSTAINABILITY COMMITTEE
7. Statement of Corporate Governance
393
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Further information on the. remit, responsibilities and the modus operandi of the Sustainability Committee are available in the
Committee’s Terms of Reference which have been released in the Company’ s website https://www.metlengroup.com/at the
following address: https://www.metlengroup.com/who-we-are/governance/corporate-governance/committees#section7.
Information on the composition, meetings and activities of the Sustainability Committee during the year 2024 are listed below.
Composition of the Sustainability Committee 2024
Composition of the
Sustainability Committee
Status
Meetings during 2024
Attendance rate of
meetings
Sophia Daskalaki-
Mytilineou
Chair
5/5
100%
Dimitrios Papadopoulos
Member
5/5
100%
Panagiota Antonakou
Member
4/5
80%
Spyridon Kasdas
Member
5/5
100%
Natalia Nicolaidis
Member
5/5
100%
Emmanouil Kakaras
Member
4/5
80%
The Sustainable Development Division Director, Mr. Georgios Galanis is the Sustainability Committee Secretary, with the CSR
Officer, Ms. Polytimi Boudali being the deputy Secretary.
The Sustainable Development Committee, in the year 2024, met on a regular basis (5 times in total) and discussed the following
topics which fall within its areas of competence:
Progress of the CSRD Alignment Action Plan
The Committee, with the support of the Director of Sustainable Development, discussed the progress of key actions aimed at
aligning the Company with the Corporate Sustainability Reporting Directive (CSRD), as transposed into Greek law under Law
5164/2024. This directive seeks to enhance transparency and the disclosure of sustainability-related information by businesses.
The Committee was informed that the following actions have been completed:
· Training and understanding of technical standards for sustainability reporting (ESRSs);
· The consultation with Social Partners;
· Description of the Value Chain for key sectors;
· Data collection and GAP analysis.
Currently in progress are the Financial Materiality assessment (via ERM) and the development of the Due Diligence Policy. The
Committee also discussed the progress on the issuance of the Integrated Report, for which Deloitte is the Company's external
consultant.
With the assistance of the Corporate Secretary, an overview of the Company's performance across the three ESG (Environmental,
Social, and Governance) pillars was presented and discussed. Based on the gap analysis, it was noted that while the European
average compliance coverage is 49%, the Company stands at 53%.
Results of the 2024 Central Consultation with Social Partners
The Committee, with the support of the Director of Sustainable Development, held an in-depth discussion on the 2024
Consultation with Social Partners process and its outcomes.
Results of the Annual Stakeholder Consultation Process
The Committee, with the support of the Director of Sustainable Development, conducted an in-depth discussion on the 2024
Stakeholder Consultation, held as part of the Annual Stakeholder Consultation Process, and reviewed its outcomes.
Results of the 2023 Socioeconomic Impact Study
The Committee, with the support of the Director of Sustainable Development, reviewed the findings of the Socioeconomic Impact
Study, which assesses and quantifies the Company’s broader contribution to the country. The study examines the impact on: a)
the economy, through its contribution to GDP growth; b) job creation and c) the increase in public tax revenues.
7. Statement of Corporate Governance
394
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
According to this study, the total contribution of the Company to the GDP is €3,628 billion, while the total added value generated
by the Company’s activities is equal to 1.65% of the country’s GDP and 6.72% of the added value of Greece’s industrial and
construction sectors.
The total contribution of METLEN to tax revenues amounts to €342.4 million and is categorized as direct (€197.5 million), indirect
(€120.1 million), and induced (€24.8 million).
Regarding employment, the Company’s activities in Greece support a total of 39,162 jobs (direct, indirect, and induced), which
correspond to 0.96% of total employment in Greece and 2.3% of employment in the industrial and construction sectors of the
Greek economy.
The Committee concluded that the study’s findings confirm the Company’s responsible business conduct and its continuously
increasing total added value to the national economy and employment, while simultaneously contributing to the collective effort
to achieve the United Nations Sustainable Development Goals.
Presentation of Strategic Digital Platforms
The Director of Sustainable Development presented and discussed with the Committee the four digital platforms implemented
by the Department in 2024, which enhance the Company’s digitalization strategy. The discussion covered:
1. The Metlen-EnGage Sustainable Development/ESG Data platform, which collects and consolidates data on Sustainable
Development/ESG to support the first integrated sustainability report, ensure compliance with the CSRD Directive, and
meet LSE requirements.
2. The electronic supplier evaluation platform, which assesses the Company's suppliers. The Sustainable Development
Department closely collaborated with the Procurement Departments of all Business Units, Subsidiaries, and Central
Functions. The 2024 goal was to evaluate over 68% of Key Suppliers. It was noted that supplier evaluation is not a
mandatory requirement but aids in the collection, assessment, and verification of information related to the ESG
performance of the Company’s supply chain.
Additionally, the Committee members were briefed on the Impact Materiality electronic platform and the AI Ethics Answers
platform.
Presentation of Key Sustainable Development Trends and ESG Performance 2024
The Committee, with the assistance of the General Director of Corporate Governance & Sustainable Development, reviewed the
key Sustainable Development/ESG trends for 2024 and focused on the following:
a. The increased disclosure requirements based on the EU CSRD Directive and the published global IFRS standards. The
Committee agreed to engage an external consultant for alignment with the CSRD and Law 5164/2024, which incorporated
the directive into Greek law.
b. The impacts on the chain of activities, both due to CSRD requirements and within the framework of EU Directive (EU)
2024/1760 on corporate sustainability due diligence (CSDDD). Through this second directive, companies are explicitly held
responsible for their chains of activities. The Committee was informed about the development of the Company’s central Due
Diligence policy.
Extensive discussions also took place regarding the increased scrutiny on Greenwashing issues, climate disclosures, the stance
on Nature & Biodiversity, Sustainable Supply Chains, the significant use of technologies (AI & Big Data), ESG investments, and
financing issues.
The Committee found that the Company is systematically and methodically preparing for its alignment with the new framework,
the upcoming changes in linking financing with ESG criteria, and the increasing number of institutional investors planning to boost
their investments in ESG products this year.
Regarding ESG performance in 2024, the Committee was thoroughly informed about the Company’s strong performance.
According to key ESG assessments for 2024, the Company maintained its rankings with improvements in its performance and,
consequently, in its scores for MSCI, S&P Global, Sustainalytics, and LSEG. This marks the sixth consecutive year of ESG
performance improvement, with optimism for further enhancements in the following year. However, it was also highlighted that
continuous development remains a major challenge alongside this improvement.
7. Statement of Corporate Governance
395
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Responsible Supply Chain Management Data
The Committee, with the assistance of the Director of Sustainable Development, conducted an in-depth discussion on the
development of the Responsible Supply Chain. The Committee was informed that the Sustainable Development Department is
working closely with the Company's procurement and supplier departments, with the active support of all stakeholders, to
integrate ESG criteria into the purchasing/procurement process.
Extensive discussions also took place regarding the results of the first supplier evaluation cycle. It was emphasized that the
Company’s goal is for all suppliers to comply with and undergo evaluation.
Sustainable Development Strategy: 2023 Review / 2024 Goals
The Committee engaged in an in-depth discussion on the Sustainable Development Strategy, guided by the presentation of the
Chief Corporate Governance & Sustainable Development Officer. The core principle of the strategy is to create and distribute
sustainable value to all stakeholders, striving for economic and business growth while maintaining the Company’s commitment
to the United Nations Sustainable Development Goals. The discussion also covered the key strategic pillars, i.e. Climate Change,
ESG Approach, and Corporate Responsibility, each of which was reviewed for 2023, along with the main objectives for 2024.
For 2024, the specific goals include:
· Climate Change: Initiating the process of revising climate targets and addressing specific technical issues.
· ESG Approach: Maintaining the Company’s high performance in ESG criteria.
· Corporate Responsibility: Developing a Due Diligence Policy and completing the first Integrated Report.
Regular meetings are held every three months with HSE teams to discuss best practices, initiatives, corporate mindset, and share
information.
The Committee emphasized that the corporate mindset should be cultivated at a centralized level while also being adapted to
individual business sectors. A particular discussion was held regarding the potential occurrence of discrimination incidents in
overseas operations and the appropriate response if such cases arise.
Presentation and Approval of Climate Goals: Progress & Next Steps
The Committee conducted a thorough discussion, with the assistance of the Director of Sustainable Development, on the
Company's Climate Commitments and Goals, focusing on:
a) The progress of the primary target for reducing CO2 emissions (Scope 1 & 2).
b) The current development of key carbon reduction initiatives and, consequently, the Company’s climate goals, as well as
the climate target review process. This review is not only considered best practice but is also necessary due to the Company’s
strong growth strategy over the past two years.
Based on the data presented, the Committee determined that both business sectors have met and remained consistent with
their assigned targets. Additionally, an analysis was conducted on the objectives of the project related to the revision of climate
initiatives and targets.
The Committee decided to recommend to the Board of Directors the approval of the climate target revision.
Approval of the 2023 Sustainable Development Report
The Committee extensively discussed the draft of the 2023 Sustainable Development Report. The first part of the report presents
the Company's Business Model and Sustainable Development Strategy. The second part analyzes the material topics within the
core ESG structure, in accordance with the requirements of the GRI Standards. The third part includes tables illustrating the
Company's alignment with sustainability standards.
The Committee approved the 2023 Sustainable Development Report.
Various Matters
a. The Committee was informed and discussed with the Director of Sustainable Development the percentage deviations of
the LSE requirements compared to the TCFD recommendations, the FCA LR 9.8 requirements, and the LSE ESG indicators.
b. The Committee, with the assistance of the Director of Sustainable Development, reviewed and approved the results of the
“Impact Materiality 2024”. All production units participated in the process.
7. Statement of Corporate Governance
396
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Presentation of Committee Evaluation by KPMG
Following the evaluation of the Sustainability Committee by the external consultant KPMG, the Report on its findings and
improvement proposals was presented. Positive aspects highlighted included the effectiveness and positive atmosphere of the
meetings, as well as the systematic monitoring of issues within its jurisdiction.
Among other points, it was noted that a training program should be developed for all Committee members, covering current
developments in Sustainability to keep them informed and enhance their contribution to the Company's guidance. Additionally,
the discussion covered strengthening the Committee's advisory role beyond its supervisory function, with a focus on enhancing
the Company's guidance, particularly in sustainability matters.
7. Statement of Corporate Governance
397
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
4.1. FUNCTIONING AND KEY POWERS OF THE GENERAL MEETING
The General Meeting of the Company’s shareholders is the supreme corporate body, having authority to decide on any matter
relevant to the Company. Shareholders exercise their rights relevant to the administration of the Company only through their
participation at the General Meeting.
More specifically, the General Meeting is the sole body with the authority to decide on the following:
(a) Revival or dissolution of the Company, as well as amendments to its Articles of Association, with share capital increases and
reductions being understood as amendments thereto for the purposes hereof;
(b) Election of members of the Board of Directors and Auditors;
(c) Approval of the overall management activities pursuant to article 108 of Law 4548/2018 and discharge of Auditors from any
liability for damages;
(d) Approval of the annual and any consolidated financial statements;
(e) Appropriation of the annual profits;
(f) Approval of the payment of emoluments or emolument advances under article 109 of Law 4548/2018;
(g) Approval of the remuneration policy and the remuneration report;
(h) Merger, split, conversion, revival, term extension or dissolution of the Company;
(i) Appointment of liquidators, and
(j) Any other matter specified in the applicable legislation.
Not coming under the provisions of the preceding paragraph are the following:
(a) Share capital increases or share capital readjustment acts explicitly vested in the Board of Directors under the law, increases
imposed under the provisions of other legislation;
(b) The amendment or harmonization of provisions in the Articles of Association by the Board of Directors when so explicitly
provided by law;
(c) The election pursuant to the Articles of Association, under article 21, of directors in the place of directors who resigned, died
or forfeited their office in any other manner;
(d) The absorption, under art. 35 and 36 of Law 4601/2019, of a Societe Anonyme (public limited company) by another Societe
Anonyme holding one hundred per cent (100%) or ninety per cent (90%) or more of the former’s shares, respectively;
(e) The option to distribute interim dividends pursuant to paragraphs 1 and 2 of art. 162 of Law 4548/2018;
(f) The option to distribute (under para. 3 of art. 162 of Law 4548/2018) profits or voluntary reserves within the current business
year under a BoD resolution which is submitted to the publication formalities.
As to the rest, the General Meeting decides on any BoD proposal included in the agenda.
The shareholders’ General Meeting’s legal decisions also bind the shareholders who are absent or disagree.
The shareholders’ General Meeting is convened by the Board of Directors, by the statutory auditor of the Company upon the
latter’s request to the Chairman of the Board of Directors, by minority shareholders representing at least one twentieth (1/20)
of the paid-in share capital of the Company upon a requisition in this respect or, when the conditions applicable are in place, by
another person or body explicitly provided for under the law.
The General Meeting is held at the Company’s seat or in the region of another municipality within the prefecture where the
Company has its seat or in another municipality neighbouring the one where the Company has its seat, at least once a year,
always in the first semester from the expiry of each fiscal year. The General Meeting can also be held in the municipality where
the seat of the Stock Market where the Company’s shares are listed.
Under a resolution passed by the Board of Directors, the General Meeting may not be held at a physical location, but it may be
conducted entirely remotely through audiovisual or other electronic means, pursuant to the provisions of article 125 of law
4548/2018 and paragraphs 4, 5 and 6 of article 13 hereof, when such is absolutely necessary, having considered any
extraordinary circumstances (such as governing guidance or other restrictions or recommendations or measures that may
prevent physical gatherings) however it shall ensure at all times proper opportunity for the shareholders to actively participate
in the general meeting and exercise their rights.
The Board of Directors can convene an extraordinary shareholders’ General Meeting, when deemed necessary.
Except in the case of reiterative general meeting sessions and those assimilated to them, the General Meeting, shall be
convened by notice published, as provided under applicable law, at least twenty (20) clear days prior to the date appointed
for its session. It is clarified that non-working days are taken into account in calculating the 20-days time limit. The
publication day of the invitation to the General Meeting and the day of the meeting are not taken into account. The
invitation to the General Meeting contains as a minimum the following information: the building, with exact address
details; the date and time of the meeting; the agenda items, clearly defined; the shareholders entitled to participate;
IV. GENERAL MEETING OF THE SHAREHOLDERS AND SHAREHOLDER’S RIGHTS
7. Statement of Corporate Governance
398
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
precise instructions on the manner in which shareholders shall be able to participate at the meeting and exercise their
rights in person or by proxy or even remotely; the rights of the shareholders, with reference of the time period within
which any such right may be exercised or, alternatively, the deadline by which such rights may be exercised; detailed
information on such rights and terms for the exercise thereof must be made available by means of express reference in
the notice to the Company website; the procedure for the exercise of the voting right by proxy and in particular the forms
used by the Company for this purpose as well as the means and methods provided in order for the Company to receive
electronic notices for the appointment and recall of proxies; determination of the date of record, with explicit mention of
the fact that only those persons having shareholder status as at such date shall have the right to participate and vote at
the General Meeting; the place where the complete text of the documents and draft resolutions shall be available as well
as the manner that these may be obtained, and the Company website address, where the information regarding the rights
of the shareholders prior to the General Meeting shall be available. No invitation is required if shareholders representing
the total of the share capital are presented or represented and no one objects to its convocation and decision taking.
Remote participation at the General Meeting is possible using audiovisual or other electronic means, without the
shareholder being physically present at the place where the General Meeting is held. In addition, remote participation at
the vote is permitted, by electronic means or by correspondence, to be taken prior to the General Meeting session. Under
a resolution passed by the Board of Directors the aforementioned options are given effect, any one or all of them, in
respect of one or more General Meeting sessions or for a specified time period, the relevant technical and procedural
details are specified, and procedures are adopted for establishing the participant’s identity and the origin of the vote, as
well as for securing the electronic or other connection.
The General Meeting is in quorum and validly meets on the items on the agenda when a percentage of at least twenty per
cent (20%) of the paid-up share capital is represented thereat. If such a quorum is not achieved in the first assembly, the
General Meeting shall be held anew within twenty (20) days from the date of the adjourned meeting upon notice of the
Board of Directors at least ten (10) clear days in advance. Such reiterative session is in quorum and validly meets on the
items on the agenda whatever the part of the paid-up share capital represented. A new notice is not required, if the
original notice specified the place and time for repeat sessions in case no quorum is present at the original General
Meeting session, provided the adjourned and the reiterative sessions are a minimum of five (5) clear days apart.
The decisions of the General Meeting are taken with the absolute majority of the votes represented in the meeting. The
General Meeting is exceptionally considered to be in quorum and validly meets on the items on the agenda if at least one
half (1/2) of the paid-up share capital are represented, in the case of decisions pertaining to a change of the nationality of
the Company, a change of the business object of the Company, increase of shareholders’ obligations, ordinary increase of
share capital unless imposed under the law or effected by means of capitalization of reserves, share capital reduction
except when it is in accordance with para. 5 of article 21 of Law 4548/2018 or para. 6 of article 49 of Law 4548/2018, a
change in the manner of appropriation of profits, merger, split, conversion, revival, term extension or dissolution of the
Company, the granting or renewal of power to the Board of Directors for share capital increase, pursuant to para. 1 of art.
24 of Law 4548/2018, as well as in all other cases in which the law specifies that the General Meeting shall adopt
resolutions under a qualified quorum and majority.
Until the General Meeting Chairman is elected, the General Meeting is provisionally chaired by the Chairman of the Board
of Directors or, if the Chairman is unable to attend, by his Deputy, as may be appointed by the Board of Directors in a
special resolution to this effect. The Chairman shall also appoint a provisional secretary. After the list of the shareholders
with a right to vote is approved, the meeting continues with the election of its Chair and a secretary who also acts as a
vote teller. Resolutions on these matters are passed by absolute majority of the votes represented at the General Meeting.
The discussions and decisions of the General Meeting are restricted to the items on the agenda. The agenda is prepared
by the Board of Directors and includes the proposals of the Board to the General Meeting and possible proposals made
by the auditors or shareholders representing one twentieth (1/20) of the paid-up share capital. For the items discussed
for which decisions are taken, minutes are kept, signed by the Chair and the Secretary. The list of the shareholders present
or represented in the General Meeting is recorded at the beginning of the minutes.
4.2. RIGHTS OF SHAREHOLDERS AND HOW TO EXERCISE THEM
Shareholders exercise their rights related to the Company’s administration only by participating in the General Meeting. Each
share entitles the holder to one vote at the General Meeting.
Entitled to participate at the General Meeting is each person that has a shareholder status pursuant to the Dematerialized
Securities Register of the Company, which is kept electronically with the company “Greek Central Securities Depository SA”
(ATHEXCSD), as at the start of the fifth (5
th
) day prior to the day of the original General Meeting session (record date). The
aforementioned record date is also applicable in the case of an adjourned or reiterative session, provided that such adjourned
or reiterative session is not more than thirty (30) days from the record date pursuant to article 124 par. 6 of law 4548/2018. If
this is not the case, or if in the case of a reiterative General Meeting a new notice is published, persons having shareholder
7. Statement of Corporate Governance
399
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
status as at the start of the third day prior to the day of the adjourned or reiterative General Meeting session may participate
at the General Meeting.
Shareholder status may be evidenced by any means and, in any case, based on the information received by the Company directly
through electronic connection with the registers of ATHEXCSD. Those entitled to participate and vote at the General Meeting
are only the individuals who qualify as shareholders on the said record date. In case of non-compliance with the provisions of
article 124 of law 4548/2018, the shareholders may participate at the General Meeting only after permission by the General
Meeting.
The exercise of the said rights does not require the blocking of the beneficiary’s shares nor the adherence to any other similar
procedure, which limits the possibility of selling and transferring them during the period between the record date and the date
of the relevant General Meeting session.
1. Shareholders who are entitled to participate at the General Meeting may participate and cast their vote either in person or
by proxy. Each shareholder may appoint up to three (3) proxies. Legal entities participate at the General Meeting by appointing
up to three (3) natural persons as their representatives. However, when a shareholder owns shares in the Company, which
appear in more than one securities account, this limitation does not preclude the shareholder from appointing different proxies
for the shares shown in each securities account in respect of a specific General Meeting session. A shareholder may appoint a
proxy for one or more General Meeting sessions and for a specified time period. The proxy casts vote according to the
instructions of the shareholder, if any. Non-compliance of the proxy with the received instructions does not affect the validity
of the General Meeting’s resolutions, even if such proxy’s vote was decisive for achieving the majority.
2. The appointment as well as the revocation or replacement of the shareholder’s representative or proxy shall be made in
writing and shall be submitted to the Company’s headquarters at least forty eight (48) hours prior to the date appointed for the
General Meeting. The proxy is obliged to notify the Company, prior to the commencement of the General Meeting, of any
specific fact, which might be useful to shareholders, in order for them to assess a possible risk that the proxy might serve
interests other than the shareholder’s interests. Conflict of interest may arise in particular in cases where the proxy: a) is a
controlling shareholder of the Company or is a legal person or entity controlled by such shareholder; b) is a member of the
Board of Directors or of the management of the Company in general or of a controlling shareholder, or of another legal person
or entity controlled by such shareholder; c) is an employee or an auditor of the Company or of a controlling shareholder, or of
another legal person or entity controlled by a controlling shareholder; d) is a spouse or a first degree relative of a natural person
referred to in cases a) to c) above.
4.3. OTHER RIGHTS OF THE SHAREHOLDERS
The shareholders also have the rights granted to them by law, such as the rights provided for in article 141 paragraphs 2, 3, 6,
7 and 8 of Law 4548/2018, which inter alia include the following:
i) Article 141 paragraph 2 of law 4548/2018: At the request of shareholders representing 1/20 of the paid-up share capital, the
Board of Directors is obliged to include additional items in the agenda of the General Meeting, provided that the relevant
request is received by the Board of Directors at least fifteen (15) days prior to the General Meeting session. The additional items
must be published or disclosed under the responsibility of the Board of Directors in accordance with article 122 of Law
4548/2018 at least seven (7) days prior to the general meeting. The request to include additional items in the agenda must be
accompanied by a justification or by a draft decision to be adopted by the General Meeting. The revised agenda must be
published in the same manner as the previous agenda, thirteen (13) days before the date of the General Meeting session and
at the same time must be also made available to shareholders on the Company’s website, along with the justification or the
draft decision submitted by the shareholders, in accordance with article 123 paragraph 4 of Law 4548/2018. If these additional
items are not published, the requesting shareholders are entitled to request the adjournment of the General Meeting in
accordance with article 141 paragraph 5 of Law 4548/2018 and to make the publication themselves, in accordance with the
second sentence of this paragraph (and article 141 paragraph 2 of law 4548/2018) at Company's expense.
ii) Article 141 paragraph 3 of Law 4548/2018: Shareholders representing 1/20 of the paid-up share capital, have the right to
submit draft decisions which have been included in the initial or revised agenda of the General Meeting. Such request must be
furnished to the Board of Directors at least seven (7) days before the date of the General Meeting session, and said draft
decisions are made available to the shareholders according to the provisions of article 123 paragraph 3 of Law 4548/2018 at
least six (6) days before the General Meeting session.
iii) Article 141 paragraph 6 of Law 4548/2018: Following a request submitted to the Company by any shareholder at least five
(5) full days prior to the General Meeting session, the Board of Directors is obliged to provide to the General Meeting the
requested specific information on the Company’s affairs, to the extent that this may be useful for the assessment of the items
on the agenda. The Board of Directors may provide a single response to shareholders’ requests with the same content. The
obligation to provide information does not apply in the event that the information requested is already available on the
Company's website, especially in the form of questions and answers. At the request of shareholders representing 1/20 of the
paid-up share capital, the Board of Directors is obliged to announce to the ordinary General Meeting the amounts that have
been paid during the last two years to each member of the Board of Directors or to the Company’s managers, as well as any
7. Statement of Corporate Governance
400
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
benefits that were granted to them for any reason or on the basis of their contract with the Company. In all the above cases,
the Board of Directors may refuse to provide such information for substantive ground, as recorded in the minutes. Such a reason
may be, in the circumstances, the representation of the requesting shareholders to the board, in accordance with articles 79 or
80 of Law 4548/2018. In the cases of this paragraph, the Board of Directors may respond in a single application to shareholders
with the same content.
iv) Article 141 paragraph 7 of Law 4548/2018: At the request of shareholders representing at least one tenth (1/10) of the paid-
up capital which is submitted to the Company within the period referred to in article 141 paragraph 6 of Law 4548/2018, the
Board of Directors is obliged to provide to the General Meeting information on the course of the corporate affairs and assets of
the Company. The Board of Directors may refuse to provide such information for substantive ground, as recorded in the
minutes. Such a reason might be, as the case may be, the representation of the applicant shareholders on the Board, in
accordance with articles 79 or 80 of Law 4548/2018, provided that the respective members of the board of directors have
received relevant information sufficiently.
v) Article 141 paragraph 8 of Law 4548/2018: In the cases referred to in article 141 paragraphs 6 and 7 of Law 4548/2018, any
question as to the merits or not of the grounds of refusal on the part of the Board of Directors to provide the requested
information, shall be resolved by court’s decision, issued in interim injunction proceedings. By the same decision, the court
obliges the Company to provide the information denied. The decision is not subject to any legal remedies.
In all above cases, the requesting shareholders must prove their shareholder status, as well as the number of shares they own,
during the exercise of their right, except for in case of the first subparagraph of paragraph 6 of article 141 of Law 4548/2018.
The shareholder status is certified though online connection of the Company with ATHEXCSD.
7. Statement of Corporate Governance
401
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Company has an internal control, quality assurance and risk management system regarding financial information and has
designed appropriate safeguards to monitor the implementation of the system's procedures. The procedures designed and
implemented by the Management and staff to ensure the reliability of financial reporting, the effectiveness and efficiency of
operations and compliance with applicable laws and regulations are further reviewed by the Company's statutory auditors and
any findings that, in accordance with their professional judgement, are of importance are communicated to the Audit
Committee of the Company, which then informs the Board of Directors accordingly.
The Board of Directors reviews on an ongoing and continuous basis the corporate strategy and the main business risks,
particularly in a constantly changing economic and business environment. In addition, it regularly receives progress reports on
the audits carried out by the Audit Committee based on the annual programme of planned audits by the Company's Internal
Audit Division. The above enables the Board to form a comprehensive view on the effectiveness of the Company's systems,
procedures and regulations.
The reliability of the Company's Financial Statements is ensured by the application of Internal Control and Risk Management
Processes. The Company has put in place separate procedures for the monthly, interim and annual Financial Reports.
More specifically, every month the Management Information Systems Division of the Company receives from the Finance
Business Partners financial data and information, which it proceeds to check and then use to prepare reports for submission to
the Management of the Group. This information is produced in accordance with the International Financial Reporting Standards.
Every month, the Management of the Group is updated on the changes to the consolidated key financial indicators by means
of relevant management reports. This monthly monitoring approach, coupled with the checking of the consolidated financial
statements and the analyses performed on the latter are the key tools used in the quality and consistency control of the financial
results.
With regard to the Interim and Annual consolidated Financial Statements, the Company employs an advanced software tool to
consolidate the financial results and statements, as well as to generate reports for the Management as well as for investors and
other interested parties. This software tool is automatically updated with data from the Group’s accounting monitoring program
and includes controls to ensure accurate transfer and accounting recognition of the input data. The Management Information
Systems Division ensures the smooth operation of the software tool and checks the integrity and correctness of the consolidated
Financial Statements and other reports, providing the Chief Finance Officer, the External Auditors and the Management of the
Company with all necessary information.
The External Auditors examine the consolidated Interim and Annual Financial Reports and report to the Audit Committee on
the progress and results of their audits for each reporting period. The Audit Committee is informed of the procedure and
schedule for the preparation of the Financial Statements by the Group Chief Finance Officer and holds meetings with the
Management / the responsible executives during the preparation of the financial reports. It obtains from the Chief Finance
Officer the necessary information on the Group’s performance and consolidated Financial Statements and reports to the Board
of Directors accordingly. During these meetings, the Audit Committee is also informed about the management of financial risks
and assesses the effectiveness of the risk management system. The Financial Statements (Individual and Consolidated) are
approved by the Board of Directors, following a relevant report from the Audit Committee.
V. DESCRIPTION OF THE MAIN CHARACTERISTICS OF THE INTERNAL CONTROL SYSTEMS AND RISK MANAGEMENT FUNCTION OF
THE COMPANY IN RELATION TO THE PREPARATION OF THE FINANCIAL STATEMENTS
7. Statement of Corporate Governance
402
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Diversity policy implemented by the Company regarding the composition of both the Board of Directors and its senior
Managers.
The Company recognizes the importance of promoting the Principle of Diversity in the composition of both its governing bodies
and its executive and administrative staff.
The management and capitalization of the Diversity Authority constitutes a significant business organizational challenge for the
Company, which, as a modern company following the completion of its transformation and in the context of its responsible
operation, in the coming years it is called to face. In this respect, the Company, fulfilling its commitment, in 2017 laid the
foundations, creating a specific Diversity policy with a vision and goals.
Purpose:
METLEN S.A. (the “Company”), committed to implementing the best Corporate Governance practices and complying with the
provisions of article 2 of Law 4403/2016, aims at applying Diversity (among other basic parameters, based on gender, age,
experience, skills and knowledge) in the composition of its Board of Directors, of its executive management team and of all
employees directly engaged in all its activities, wherever this is feasible. To this end, the Company hereby adopts this Diversity
Policy (“Policy”).
Vision:
The Company acknowledges that in an era in which flexibility and creativity are the keys to competitiveness, promoting diversity
in its administrative, management and supervisory bodies is particularly significant for engendering its further business growth.
The Company also acknowledges that diversity at the workplace in the broader sense may boost the potential for accessing a
greater range of solutions to issues of business strategy, increasing its competitive advantage.
Principles:
The process of seeking and selecting candidates for Board membership or for other senior executive positions should employ
merit-based and objective criteria, considering the benefits from the application of the principle of diversity, which include
representation of both genders, in the said procedure.
The overriding prerequisite for appointing a Board member or other senior executive primarily is that the candidate possess the
requisite qualifications and fulfils other criteria specified by the Company. Nevertheless, the process should ensure that women
and men will have equal opportunities for candidature.
If the Company, through its competent bodies such as the Remuneration and Nomination Committee or the Human Resources
Central Support Function, were to employ the services of third parties, such as independent consultants, to seek candidates for
Board membership or for senior executive positions, explicit mention should be made that both women and men are to be
proposed.
In their annual evaluation of the Board of Directors and of its Committees, the members of the Board and of the Committees
should take into consideration the balance of all diversity parameters applicable to the Board, as these are mentioned in the
present Policy.
Despite the fact that most of its activities are in the heavy industries sector, the Company aims to facilitate the broader possible
participation of women and young people in its workforce, where feasible, always in accordance with the requirements and
opportunities in each one of its Business Units.
Managing and capitalising on diversity represents a major organisational business challenge for the Company. Its is believed
essential to invest in the development of managerial skills, so that senior executives can manage a potentially multicultural work
environment correctly.
Scope of application:
The Policy is applied in selecting members of the Company’s Board of Directors and is taken into account in seeking and selecting
senior executives as well as personnel at all other levels of the Company’s hierarchy.
Policy disclosure:
The Policy is posted on the Company's website (https://www.metlengroup.com/ ).
In the “Corporate Governance Statement” section of its Integrated Annual Report, the Company reports its performance against
the targets set, together with the percentages – by gender and age – of the members of the Board, of the executive management
team and the potential of its senior management executives, its personnel, as well as its administrative staff.
VI. DIVERSITY POLICY
7. Statement of Corporate Governance
403
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Starting in 2024, the categorization of METLEN's workforce will be based on the new 'METLEN Job Model (MJM)'. This approach
establishes a clear framework for determining the size and nature of job positions across the Company and represents the most
reliable and structured method for employee categorization. It leads to the creation of five (5) categories of personnel, excluding
Board members, specifically: 1) Corporate Management / Leadership Council, 2) Executive Leadership Team, 3) Middle
Management & Experts, 4) Team Leaders/Supervisors & Professionals, 5) Admin & Technical Staff.
METLEN Diversity Indicators by gender and
age
2021
GRI Published
2022
GRI Published
2023
GRI Published
Board of Directors
Men
73,0%
73,0%
75,0%
Women
27,0%
27,0%
25,0%
<30 years old
0,0%
0,0%
0,0%
30-49 years old
18,0%
18,0%
16,7%
50-70 years old
73,0%
73,0%
75,0%
>70 years old
9,0%
9,0%
8,3%
Executive Team
Men
92,9%
81,8%
69,0%
Women
7,1%
18,2%
31,0%
<30 years old
0,0%
0,0%
0,0%
30-50 years old
14,3%
9,1%
23,0%
>50 years old
85,7%
90,9%
77,0%
Directors and Officers
Men
78,8%
76,5%
75,4%
Women
21,2%
23,5%
24,6%
<30 years old
6,1%
8,7%
8,5%
30-50 years old
59,9%
54,8%
56,9%
>50 years old
34,0%
36,5%
34,5%
Administrative employees
Men
63,1%
61,5%
57,8%
Women
36,9%
38,5%
42,2%
<30 years old
14,8%
16,7%
19,3%
30-50 years old
63,4%
61,7%
61,9%
>50 years old
21,8%
21,6%
18,8%
METLEN Diversity Indicators by gender and age METLEN, according
to S1-9 standard
2024
7. Statement of Corporate Governance
404
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Board of Directors
Men
69%
Women
31%
Other
0,0%
Not reported
0,0%
<30 years old
0,0%
30-50 years old
8%
>50 years old
92%
Executive Leadership Team
Men
66,7%
Women
33,3%
Other
0,0%
Not reported
0,0%
<30 years old
0,0%
30-50 years old
25,0%
>50 years old
75,0%
Corporate Management/ Leadership Council
Men
82,9%
Women
17,1%
Other
0,0%
Not reported
0,0%
<30 years old
0,0%
30-50 years old
55,5%
>50 years old
44,5%
Middle Management & Experts
Men
82,9%
Women
17,1%
Other
0,0%
Not reported
0,0%
<30 years old
1,2%
30-50 years old
73,8%
>50 years old
25,0%
Team Leaders/ Supervisors & Professionals
Men
70,8%
Women
29,2%
Other
0,0%
Not reported
0,0%
<30 years old
17,9%
30-50 years old
65,3%
>50 years old
16,8%
Admin & Technical Staff
Men
77,3%
Women
22,7%
Other
0,0%
Not reported
0,0%
<30 years old
13,4%
7. Statement of Corporate Governance
405
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
30-50 years old
67,4%
>50 years old
19,2%
7. Statement of Corporate Governance
406
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Company follows the rules on transparency, independent financial management and the accuracy and correctness of its
transactions, as stipulated by the law.
The Company, with a view to ensuring the correct, secure, transparent and effective conclusion of transactions with related
parties (“RP”) and to assuring the appropriate supervision and control of these transactions, has established and implements the
“Process of Compliance with the Obligations arising from the framework for Related Party Transactions”, which was approved by
a Board resolution dated 22/09/2022.
The purpose of the Process is to specify the rules to be observed for the valid approval, conclusion and execution of a transaction
with an RP, so as to ensure:
i. the balancing of the benefits resulting from the transaction for all the parties involved in it;
ii. the protection of the various interests which may be affected by that transaction; and
iii. the Company's compliance with the applicable legal framework regarding RP transactions.
The Process regulates the Company's transactions with RPs, as such persons are defined in the relevant IFRS, specifies the relevant
Divisions responsible for its implementation and regulates the procedure to be followed in relation to the granting of the required
authorisation and the disclosure to be maintained for related party transactions. Specifically, it is provided that for the Company
to validly enter into a transaction with an S.M., a special authorization is required, which is granted by a final decision of the
competent corporate body, and after the transaction evaluation report referred to below has been submitted and taken into
account.
In particular, it is explicitily provided that for the valid conclusion of by the Company of a transaction with an RP, a special
authorization is required, granted by final resolution of the competent corporate body, adopted after the assessment report of
the transaction, has been submitted and taken into account. The conclusion of an RP transaction without the granting of such a
special authorization is prohibited and is completely void, while criminal sanctions are also provided for in case of violation of the
relevant provisions of Law 4548/2018, in accordance with article 179 thereof. As a rule, the authorization to conclude a
transaction of the Company with a party related to it is granted by resolution of the Board of Directors of the Company. If the
BoD resolves to grant an authorization for the conclusion of a transaction with an RP, it is obliged to publish, immediately after
the granting of that authorization, a relevant announcement. Exceptionally, the competence to resolve to grant an authorization
for the conclusion of an RP transaction may rest with the General Meeting of the Company’s Shareholders. As a prerequisite to
assure the validity of the resolution of the BoD of the Company or of the GM of the Company’s Shareholders to grant an
authorization for the conclusion an RP transaction, such resolution is adopted on the basis of a report submitted by an
(independent) certified auditor accountant or an (independent) audit firm or other independent third party not related to the
Company, which assesses whether the transaction in question is fair and reasonable for the Company and for the shareholders
who are not RPs, including minority shareholders, and explains the assumptions on which it is based and the methods used in its
compilation (assessment report). The Company shall also ensure the observance of the disclosure requirements of Law
4548/2018.
Finally, the Process provides for the steps to be followed for transactions with related parties and the competent General
Divisions/Divisions, the role of the Audit Committee in this regard and the exceptions, i.e. transactions for which neither special
authorisation is required nor the observance of publicity formalities.
VII. RELATED PARTY TRANSACTIONS
7. Statement of Corporate Governance
407
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
CVS OF THE MEMBERS OF THE BOARD OF DIRECTORS
Evangelos G. Mytilineos
METLEN’s Energy & Metals Chairman and CEO
Evangelos Mytilineos is the Chairman and CEO of METLEN Energy & Metals (formerly MYTILINEOS), an international leader in the
industrial and energy sectors with over 7,500 direct and indirect employees and strong presence on all five continents. Under his
leadership, the company reached a consolidated turnover of €5,683 million and EBITDA €1,080 million in 2024.
Born in Athens, Evangelos Mytilineos holds a BSc in Economics from the University of Athens and an MSc in Economics from the
London School of Economics. In 2019, he was awarded an honorary doctorate from the Department of Business Administration
and Management at the University of Piraeus.
In 1978, he took over the family business, which was founded in 1908, which represented metal and steel product manufacturers.
In 1990, he established MYTILINEOS Holdings Group. With strategic acumen, Evangelos expanded the company’s by acquiring
the majority shareholding of metal construction company METKA S.A. as well as that of Aluminium of Greece. Today, Aluminium
of Greece is the largest fully vertically integrated producer of alumina and aluminum in the EU. Following the acquisition of
IMERYS BAUXITES GREECE, METLEN has become the largest producer of bauxite in Europe. In 1995, Evangelos Mytilineos listed
the group on the Athens Stock Exchange. In the early 2000s, the company entered the energy sector through Protergia, now the
company’s flagship energy retail brand.
Under Evangelos’s leadership, METLEN has focused on Green Metallurgy and Sustainable Energy, creating long-term shareholder
value. The company broke monopolies in 2010, by becoming the first private entity to supply and market natural gas in Greece,
ensuring a safe and competitive supply for its customers. Evangelos has spearheaded the company’s energy transition and digital
transformation, emphasizing sustainable development and the circular economy.
Evangelos created the second largest energy producer and supplier after the state owned PPC in Greece. Based on the vertical
structure of its operation in the energy sector, it has created the most integrated energy company, on the way to energy
transition. In fact, the portfolio of Renewable Energy Sources now reaches more than 10 GW across five continents, while the
company implements significant investments in this direction, which exceed 1 billion euros.
A pioneer in corporate governance, Evangelos Mytilineos focuses on sustainability and innovation, while optimizing cost, safety,
and operational quality. In 2021, he set a target to reduce emissions by 30% by 2030 and achieve net-zero emissions by 2050,
positioning METLEN Energy & Metals as one of the first companies in Europe to embed bold sustainable growth targets in its
operations.
Evangelos was re-elected in 2024 President of Eurometaux, the European association for non-ferrous metals, an industry that is
a global best performer, with a €120bm annual turnover, providing skilled jobs across the EU for 500,000 direct and 3,000,000
indirect employees. He has also served five times as Vice President of Hellenic Federation of Enterprises, that includes 400 of the
largest corporations in Greece.
Spyridon D. Kasdas
Vice-Chairman A', Non-Executive Member
He has served as Chairman of the mining company Delphi - Distomon, owned by METLEN Energy & Metals S.A. (former
MYTILINEOS SA) and member of the Board of Directors of the SEV’s Business Council for Sustainable Development.
During his 48 years professional career in the international aluminium industry, he has served as plant manager of the alumina
refinery and aluminium smelter as CEO and executive member of the Board of Directors of the former listed company Aluminium
of Greece SA, as Smelting Research Manager for the French industrial group Pechiney, as CEO and executive member of the Board
of Directors of the unlisted Australian aluminium smelting company Tomago, as Vice President Technology and member of the
Primary Executive Committee of the French group Pechiney and later on of the Canadian group Alcan. Also, he has served as a
board member of unlisted aluminium production companies, or equivalent bodies for joint ventures, in Sohar Aluminium in Oman
and Alouette Aluminium in Canada. In 2005, METLEN Energy & Metals Group (former MYTILINEOS Group) acquired Aluminium
of Greece SA and Spiros Kasdas returned to Greece and served as CEO and later on as Chairman of the company until its
absorption by METLEN Energy & Metals in 2017.
He holds a degree in Mechanical and Electrical Engineering from the National Polytechnic School of Athens.
VIII. CVS OF THE MEMBERS OF THE BOARD OF DIRECTORS AND THE SENIOR MANAGEMENT
7. Statement of Corporate Governance
408
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Evangelos G. Chrisafis
Vice Chairman B’, Executive Director of the BoD for Regulatory & Strategic Energy & Infrastructure Issues
| Chairman, METKA ATE
Evangelos G. Chrisafis has linked his long-standing career to METLEN Energy & Metals (previously known as MYTILINEOS), marking
25 consecutive years with the Company this year.
In 2009 he assumed the position of General Manager of Legal and Regulatory Affairs of then MYTILINEOS Group. Among other
roles, he has served as a Board Member of Aluminium of Greece and Protergia (prior to their absorption by former MYTILINEOS),
as well as the Hellenic Association of Independent Power Producers (HAIPP). Since 2018, he has been serving as Vice Chairman
and Executive Director of the BoD for Regulatory & Strategic Energy & Infrastructure Issues for METLEN Energy & Metals.
In 2023, he took on the role of Chairman of METKA ATE (a METLEN subsidiary specializing in infrastructure projects). As of June
2024, he is an elected member of the Board of Directors of SEV (Hellenic Federation of Enterprises). Additionally, he has been a
member of the Board of Directors of GOLDEN SOLAR AE since 2007.
His work is closely linked to historical changes in the European and the Greek regulatory landscape, particularly the liberalization
of gas and electricity markets and securing competitive energy costs for Greece's energy-intensive industry. Supporting the SEV
Energy Committee, he actively contributed to the introduction of regulatory measures crucial for reducing industrial energy costs
and ensuring supply security.
He is a lawyer, a graduate of the Law School of the Aristotle University of Thessaloniki and speaks English and German. He began
his career in 1989 when he was registered as a lawyer with the Thessaloniki Law Association.
Christos Gavalas
Executive BoD Member, Chief Treasury & IR Officer
Mr. Christos Gavalas has joined METLEN in 2001 and is Chief Treasury & IR Officer and Executive BoD member. He is Chairman
of the Capital Allocation Committee and Credit Committee, member of the Cabinet of the CEO, Financial Committee and the
Energy – Metallurgy Councils.
Under his mandate is responsible for the Group financial investments, funding, Capital markets, asset management, Financial
risk management, credit & market risk and Debt / equity institutional investor’s relation.
His professional career in banking started in the early 90s at the Global Treasury Services of Barclays Bank plc Greece as a
Money Market and Capital Market dealer. In 1997, as chief dealer he became Head of the Money Market and Capital Market
Dpt. In 1999 he was appointed Treasurer and Head of Investment and Trading. He was also member of the Barclays European
Treasures Board as well as the Greek FOREX association.
Christos Gavalas received his Bsc in Business administration from the Athens University of Economics and Business, with major
in Finance.
Dimitrios S. Papadopoulos
Executive BoD Member, Chief Corporate Governance & Sustainable Development Officer
Dimitris Papadopoulos serves as Executive BoD Member and holds the position of Chief Corporate Governance & Sustainable
Development Officer as well as member of the Executive Committee of METLEN Energy & Metals S.A.
He joined METLEN Energy & Metals S.A. in 2005 and served as a member of the Board of Directors of Aluminium of Greece SA
when acquired by METLEN Energy & Metals S.A.
He is a member of the CEO Cabinet, Financial Committee, Energy & Metals Committee and Leadership Council.
He is currently Executive BoD member of the subsidiary Company of METLEN Energy & Metals SA “MNG Trading S.A.” and BoD
member of SEV – Business Council for Sustainable Development.
He started his career in 1988 in the Banking sector, as Capital Markets executive at the Hellenic Bank for Industrial Development
(ETVA). He spent 7 years at SOCIETE GENERALE BANK in Greece, where he served as Greek Head of Investment Banking and
Private Banking, before moving to SIGMA SECURITIES (later PIRAEUS SECURITIES) in 1996, to head the company’s Business
Development and Corporate Finance activities. In 2000 was appointed as CEO and Executive Vice-President of the INVESTMENT
BANK of GREECE (IBG), a start-up financial institution that later merged into Marfin Bank. Before joining METLEN Energy & Metals
Group in 2005, he was CEO of the newly formed REIT of the Hellenic Real Estate Company (KED) the real estate holding company
of the Greek State.
He has been a director in several listed and non-listed companies as well as member of various Investment Committees.
He holds a BA degree in Economics from the George Washington University, Washington D.C. (USA) and an MBA degree in
Finance from the American University, Washington D.C. (USA).
7. Statement of Corporate Governance
409
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Ioannis G. Petrides
Lead Independent Director, Independent Non-Executive Member
Mr. Petrides is currently a Director on the Board of PUIG SL, a privately held global player in fashion and perfumes, which owns
brands including Nina Ricci, Paco Rabanne, Carolina Herrera, Jean Paul Gaultier, Dries Van Noten, Charlotte Tilbury, Uriage and
Penhaligons. He also served as the Chairman of PUIG’s Audit and Compliance Committee and is a member of the ESG Committee.
Mr. Petrides also served until 2024 as Senior Industry Advisor of Triton Partners Private Equity.
Between 2012 and 2018 he served as Chairman of the Supervisory Board of Rotterdam-based Refresco B.V., the world’s largest
independent manufacturer of private label beverages and A-brands with pro-forma Revenues of around 5 billion euros and over
70 manufacturing facilities in Europe and North America. Mr. Petrides led the listing of the Company in 2015 in the Amsterdam
stock exchange.
Until 2016, he also held the position of Chairman of the Board of Largo (parent of Wind Hellas Telecommunications), a major
fixed, broadband, mobile telecommunications and pay-TV operator in Greece. During 2005-2014 he served as Vice-Chairman of
the Board of Directors of the Campofrio Food Group, Europe’s leader in the processed and packaged meat market which was
listed on the Madrid stock exchange. He served as the Chairman of Campofrio’s Audit Committee as well as Chairman of the
Strategy Committee and member of the Remuneration and Nomination Committee.
Mr. Petrides worked for 23 years with PepsiCo Inc. Between 2000-2010 he served as President - Europe for the Pepsi Bottling
Group, significantly expanding the Group’s presence in countries like Russia, Spain and Turkey. He was one of the founders of
PBG, which was spun-off from PepsiCo and listed on NYSE in 19999. Prior to that, he held the position of President of PepsiCo
Spain. He also served as President for PepsiCo Greece/Balkans.
Prior to PepsiCo, Mr. Petrides worked with the Procter and Gamble Company in the Middle East and USA.
He holds a Bachelor’s and Master’s degree with Honours in Economics from Cambridge University and an MBA from the Harvard
Business School. Mr. Petrides is a native of Cyprus.
Panagiota L. Antonakou
Independent Non-Executive Member
Peggy Antonakou is General Manager of GOOGLE Southeast Europe. She served from 2012 to 2019 as CEO of Microsoft Greece,
Cyprus & Malta. She has deep experience in the fields of Marketing and General Management, having held key positions both in
Europe and the USA.
She joined Microsoft in February 2012 as a Sales Director and took over the leadership of the company as the General Manager
in November of the same year. She later assumed expanded responsibility as the CEO for Greece, Cyprus and Malta. During her
tenure, Greece was awarded as. Best subsidiary in the world amongst countries of relevant size.
She joined Microsoft, from DELL S.A, where she held the position of General Manager of Consumer and SMB divisions for South
Eastern Europe & Italy.
She first joined DELL in 2002, in the Marketing Department of the company’s Headquarters in Austin, Texas USA. Peggy has
previously held positions at General Motors USA and Opel Bank GMBH.
She has served as a member of the Board of Directors of Dimand S.A. (March 2022 - November 2023). Since May 2024, she has
been an independent non-executive member of the Board of Directors of the Onassis Foundation.
Ms. Antonakou was born in 1974 in Athens. She holds a BSc in Business Administration from the University of Piraeus and an
MBA from the University of Michigan.
Emmanouil C. Kakaras
Independent Non-Executive Member
Professor Emmanouil Kakaras is Executive Vice President GX (Green Transformation) Solutions, Mitsubishi Heavy Industries EMEA
Ltd., since April 2021. Prior to this role, he was Senior Vice President for New Products and Energy Solutions at MHI Group
company Mitsubishi Power Europe since January 2018. Up until then he served as Senior Vice President and Head of Innovation
& New Products at Mitsubishi Hitachi Power Systems Europe GmbH since September 2012.
His R&D activities mainly focus on flexible operation of thermal plants, on fuel cells and electrolysers, the development of large-
scale energy storage and the utilization of CO2.
Born in 1962, Mr. Kakaras first got his diploma in Mechanical Engineering at the National Technical University in Athens (NTUA),
and then proceeded to get his PhD at the NTUA and at the Technical University Braunschweig in Germany. He continued his
academic career in 1991 as a professor at the NTUA until 2012, when he left on a sabbatical leave. Since 2014 until today, he
serves on a part-time basis at the NTUA. He has also been guest lecturer at the Universities of Warsaw and Tokyo while has also
been awarded faculty membership rights at Energy Engineering Institute of the Engineering Faculty at the University Duisburg
Essen. From 1999 to 2018, he has been the Director of the Centre of Research and Technology Hellas/Chemical Process and
Energy Resources Institute (CERTH/CPERI).
Next to his involvement in academia and research, Emmanouil Kakaras was professionally active as an advisor of the European
Commission and he has been appointed Executive Director of the Hellenic Association of Independent Power Producers from
7. Statement of Corporate Governance
410
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2010 till 2012. Emmanouil Kakaras also has a keen interest in European affairs. From January 2013 to January 2018, he was
President of the European Power Plant Suppliers Association (EPPSA). He represents Mitsubishi Heavy Industries at the
Hydrogen Council and other Hydrogen-related initiatives. Since 2018 he is an independent non-executive member of the Bord
of Directors of Metlen Energy & Metals S.A. (formerly MYTILINEOS).
Xenia (Polyxeni) Kazoli
Independent Non-Executive Member
Xenia Kazoli is an experienced international lawyer, admitted to the bars of New York Paris and Athens. She has completed
large and complex transactions for more than twenty years in multinational environments, advised the governments of Greece,
Italy, France, Spain and Portugal in privatisations and offerings, as well as advised clients on EU financial regulations and
corporate governance.
Until 2015, she was a counsel at Allen & Overy LLP, where she spent 15 years specializing in international debt and equity
offerings and advising on privatisations and cross border transactions. Prior to this, she was practicing with Skadden Arps LLP in
their Paris and London offices in the international capital markets team. Mrs. Kazoli has also worked at the World Bank,
conducting legal assessment, policy and regulatory reform and advising on judicial capacity building in Peru, Argentina, El
Salvador and Venezuela, and more recently as an expert with the European Union in Georgia providing technical assistance and
training to government officials on negotiation and drafting of international contracts.
For the last few years she has been advising on regulatory reform and corporate governance governments, financial institutions
and companies, from small to large. She served for five years as a senior advisor with Nestor Advisors Ltd, a UK advisory firm
specializing in corporate governance.
Xenia is an independent non-executive member of the Board of the Athens Exchange, Chair of its Remuneration and
Nominations Committtee and member of its Audit Committee, as well as an independent non-executive member of the Board
of Autohellas and Dimand SA. She is currently Chair of the Hellenic Corporate Governance Council, Co-founder of the CGHub (a
non profit promoting diversity in governance) and a member of the Advisory Board of the NGO DESMOS.
Tina (Konstantina) N. Mavraki
Independent Non-Executive Member
Tina (Konstantina) Mavraki is a C-Level Executive with extensive global experience in capital markets, company and project
funding, risk management and audit. She started her career in 1998 and lives in London.
She has held senior positions with global institutions including Morgan Stanley, Citigroup and Noble Group, where she was
responsible for multi-million US$ financial and physical commodity investments in developed and emerging markets.
She has extensive financial and operational internal audit and due diligence experience, most notably as Office of CEO of US$ 1.4
billion fund Barak Fund Management Limited, and as Head of Financing of commodities Division of US$ 1.75 billion fund Gemcorp
Capital LLP. She is a devoted sustainability professional, with deep expertise in governance and environmental impact.
Ms Mavraki received an MA and BA in Philosophy, Politics & Economics from Oxford University and an MSc in Finance from
London Business School. She is a CFA Charter-holder and holds a Certificate in Company Direction from the UK Institute of
Directors.
Anthony M. Bartzokas
Independent Non-Executive Member
Anthony Bartzokas is Professor at the Department of Economics of University of Athens, United Nations University Professorial
Fellow and Visiting Professor in Practice at the London School of Economics and Political Science. He has extensive experience in
the oversight of financial reporting and internal controls as he has been Chair of the Audit Committee, Board member and
member of the Retirement Plan Investment Committee at the European Bank for Reconstruction and Development (EBRD).
During his nine-year tenure at the EBRD, he served as Chair of the European Union coordination group and was involved in all
high-level decision-making processes, from country strategies to investment projects, including the approval and the modalities
of EBRD’s engagement in Greece. He has worked on financial systems, corporate investment, and innovation dynamics with
financial support from international institutions and continuous interaction with Multilateral Development Banks, the European
Union and UN agencies. In his role as knowledge manager, he has coordinated international research teams and benefitted from
the interaction with policy makers and the business community, especially when it comes to project structuring and the evolving
dynamics of capital markets and innovation. During his tenure, the EBRD Investments in Greece reached record levels with 4,360
million euro in 67 projects and a pipeline of 890 million euro in 19 projects.
Born in 1962, Anthony holds a BA in Economics from the Aristotle University of Thessaloniki and a PhD, in Economics of
Technological Change from University of Sussex, both with distinction.
7. Statement of Corporate Governance
411
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Natalia E. Nicolaidis
Independent Non-executive member
Natalia Nicolaidis worked at Credit Suisse (CS) for 24 years where she served as global General Counsel for the Investment Banking
& Capital Markets Division for the last 5 years.
Previously she was Head of Risks & Controls for the aforementioned division and capital markets and mergers & acquisitions
lawyer at CS in London and New York. Ms. Nicolaidis also practiced law in New York from 1991 to 1996.
She is currently a non-executive member of the Board of Directors and participates in various committees of the following listed
companies in Greece and abroad: Titan Cement International SA, Aegean Airlines and SMCP SA.
She has graduated from Yale University (Economics) and has advanced degrees in Law (Juris Doctor) and International Affairs
(Masters) from Georgetown University) and in European Union Law from the College of Europe (Bruges, Belgium).
Alexios A. Pilavios
Independent Non-Executive Member
Alexios Pilavios is currently Non-Executive Chairman of Alpha Asset Management and Vice Chairman of ABC Factoring. He is also
a member of the Board of Directors of Plaisio SA and Trade Estates Real Estate Investment Company SA. He has a deep experience
in the fields of Banking, Asset Management and Capital Markets.
During his thirty-five year career, he held senior positions in the Greek financial sector. He was Chairman of the Hellenic Capital
Markets Commission (2004-2009), Deputy Chairman of Hellenic Exchange SA (2011-2023), General Manager of Alpha Bank (Head
of Wealth Management) and member of the Executive Committee (2009-2017).
Alexios has served also for numerous years as CEO of Alpha Investments and Alpha Asset Management (1992-2004), holding also
the position of Chairman of the Association of Greek Institutional Investors (1996-2000).
Prior to his assignments with Alpha Bank he held senior positions with Ergo Bank, Commercial Bank of Greece and the National
Investment Bank of Industrial Development (NIBID).
Born in 1953, Alexios graduated from the Athens College and holds a BSc (Econ) from the London School of Economics, a MSc
in Economics from the University of Essex and a PhD in the Economics of Education from the London University Institute of
Education.
Leda Condoyanni
Company Secretary
Leda Condoyanni is a leading corporate governance expert in Greece, also recognised internationally. She serves as Vice-Chair of
the European Confederation of Directors Associations (ecoDa) and is a founding member and the current Chair of the Non-
Executive Directors’ Club in Greece (NED Club).
Leda is at present Corporate Governance Director and Company Secretary at METLEN Energy & Metals (formerly MYTILINEOS),
a leading global Industrial & Energy company listed on the Athens Stock Exchange (ATHEX), with a strong international presence
across five continents.
She is the founder of the Hellenic Corporate Governance Council, a joint initiative between the Hellenic Federation of Enterprises
(SEV) and ATHEX where she served as General Manager and Board member. During her tenure she conceived, designed, and
liaised with both organisations to create the first Hellenic Corporate Governance Code.
Leda has diverse and extensive experience in financial services through leadership roles in the fields of corporate governance,
stock markets, asset management, corporate affairs, policy making and advocacy, among others.
She has served as a non-executive board member for companies in the financial services sector and of state-owned enterprises.
Leda has also been involved in government committees of the Greek Ministries of Employment, Interior, and Finance, where she
was a member of law-making committees. Additionally, she has been involved with the Hellenic Capital Markets Commission,
the General Secretariat for Gender Equality, and the Board of Directors of the Athens Derivatives Exchange (prior to its merger
with ATHEX).
Leda received a Ph.D. in Finance and an M.A. in Accounting and Finance from Lancaster University, UK. She also holds the
European Board Diploma from the European Confederation of Directors Associations (ecoDa), Belgium.
Panagiotis Psarreas
Deputy Company Secretary
Born in Athens in 1981. He studied Architecture in the University of Florence and then journalism in Athens.
He worked in various media as a journalist until 2010, when he assumed the position of associate at the METLEN Energy & Metals
Chairman’s Office. Since 2018, he is the Deputy Secretary to the Board of Directors and in 2013 he also assumed the position of
Group Digital Media Officer.
7. Statement of Corporate Governance
412
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Vassiliki Prantzou
Audit Committee Secretary
Vassiliki Prantzou was born in 1981 in Athens. She is a graduate of the Law School of the Aristotle University of Thessaloniki and
holds a postgraduate degree (Private Law A) from the School of Law of the National and Kapodistrian University of Athens.
She is an accredited intermediary and has also attended a postgraduate course in business administration for executives (e-mba)
at the University of Piraeus. She is a member of the Athens Bar Association since 2006 and has joined the Company’s Legal
Department in 2014.
CVS OF THE MEMBERS OF THE SENIOR MANAGEMENT
Evangelos G. Mytilineos
METLEN’s Energy & Metals Chairman and CEO
As per CVS OF THE MEMBERS OF THE BOARD OF DIRECTORS
Vivian Bouzali
Chief Corporate Affairs & Communication Officer
Vivian Bouzali was born in Kastoria, Greece. She holds a BSc in Psychology from the Loyola University of Chicago, an MSc in
Counseling Psychology from Harvard University and an MSc in Business Administration from the University of Louisville.
Over the course of four years, between 1989-1993, she practiced clinical psychology at Loyola and Harvard University, focusing
on teenagers and groups inclined to criminal behavior.
Upon returning to Greece, in 1994 she assumed the position of Administrative and Business Development Director at New York
College of Athens, which she held until 1998. Under her lead, the school saw a significant expansion of international activity to
several European countries.
In 2000-2004, she served as CEO of Human Capital Improvement, a strategic communications consulting firm working with high
caliber Greek and international corporate clients.
During the same period, she actively participated in preparations ahead of the Athens 2004 Olympics, recruiting and educating
an unprecedented pool of volunteers that was vital to the success of the Games.
In 2004, she was appointed Executive Director for Retail, Marketing and Corporate Communication at ELTA Group (Hellenic Post
Office).
During that time, she also worked as an ad hoc communication consultant to top-notch companies in Greece and abroad.
In 2007 she was elected to serve as a member of the Greek Parliament with the party of New Democracy, where up until 2009
she focused her parliamentary activation issues of growth, promotion of investment and the fight against distortions in the Greek
economy and administration.
She joined METLEN Energy & Metals (previously known as MYTILINEOS), a leading international industrial and energy company
with a dynamic presence on all 5 continents, in 2009 and since January 2023 after the new corporate transformation, she is the
Chief Corporate Affairs & Communication Officer of the company.
In December 2024, V. Bouzali was awarded the title of "Corporate Affairs and Communication Manager of the Year".
Ms. Bouzali is married and has a daughter.
Evangelos Chrisafis
Vice Chairman B’, Executive Director of the BoD for Regulatory & Strategic Energy & Infrastructure Issues | Chairman, METKA
ATE
As per CVS OF THE MEMBERS OF THE BOARD OF DIRECTORS
Sara Fideli
Chief People Officer
Sara Fideli, has been the Chief People Officer at METLEN Energy & Metals S.A (formerly MYTILINEOS S.A.) since June 2022 and
serves as a BoD member at Delfi Distomo.
With a robust background as a Senior HR practitioner and transformation leader, Sara has spearheaded large-scale business and
functional change programs across diverse international corporate settings. She solidified her reputation as a commercial HR
leader renowned for driving impactful results while she was collaborating with renowned global companies such as Unilever,
The Coca-Cola Company, TEVA, and ING.
7. Statement of Corporate Governance
413
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Having spent nearly a decade in Amsterdam, Sara brings a wealth of experience from her tenure as Senior HR Business Partner
for ING's Global Risk division and as the Single Point of Contact (SPOC) for Diversity & Inclusion initiatives across corporate offices.
Prior to this role, Sara held the role of Vice President of Human Resources for TEVA Global Operations Europe, a global leader in
generic and specialty medicines.
In her various leadership roles, Sara has managed both direct and indirect teams within complex global matrix organizations,
instilling a culture of inspiration and motivation. Her expertise -among others-spans labor relations, talent management, and
organizational capability development.
Sara holds a Bachelor's degree from the Faculty of Law at the University of Athens and a Bachelor's degree of French Higher
Education at the University of Sorbonne- Paris.
Christos Gavalas
Chief Treasury & IR Officer
As per CVS OF THE MEMBERS OF THE BOARD OF DIRECTORS
Fotini Ioannou
Chief of Staff
Fotini Ioannou is the Chief of Staff of METLEN Energy & Metals S.A (formerly MYTILINEOS S.A.) since June 2023 and BoD member
of EP.AL.ME.
Prior to this role, Fotini had an extensive career in Banking. Her most recent role was as General Manager of Legacy Portfolio &
Specialized Asset Solutions and member of the Executive Committee of National Bank of Greece and Chair of the NPL Committee
of the Hellenic Bank Association. Prior to that , Fotini was leading Corporate & Investment Banking as General Manager and
member of the Executive Committee of Piraeus Bank. She has served as Chair of Piraeus Factoring, Vice Chair of Piraeus Leasing,
and member of the BoD NBG Cyprus. Before embarking on a career in banking, Fotini had worked at McKinsey & Company in
Greece and in the US and started her career in the Assurance & Business Advisory Division at Arthur Andersen in London.
She holds an MA in Economics from the University of Cambridge and an MSc in Management Science & Operational Research
from the University of Warwick. Ms. Ioannou is a chartered accountant and a member of the Institute of Chartered Accountants
of England and Wales.
Ioannis Kalafatas
Chief Executive Director, Energy
He was born in Athens in 1976. He studied Economics at the Athens University of Economics and Business.
He joined METLEN Group in June 2005 as Executive Director - Group Financial Controller and in 2011 he assumed the role of
Group CFO. In 2017 his role expanded further, undertaking the responsibility for IT and Central Procurement Divisions and
Investment Relations Division.
Since January 2023 after the new corporate transformation of METLEN Energy & Metals, he holds the position of Energy Chief
Executive Director assuming the responsibility to lead the Energy Sector.
He is the CEO of Korinthos Power S.A., as well as Member of the Board of Directors of the Hellenic Association of Independent
Power Producers.
He is married with two children.
Elenos Karaindros
Chief Strategy and M&A Officer, Chairman M Concessions
Elenos Karaindros holds the position of Chief Strategy and M&A Officer METLEN and Chairman M Concessions. Elenos graduated
from German School of Athens (Dorpfeld Gymnasium) in 1989. He studied Economics at the Athens University of Economics and
Business and then received his MSc in Shipping, Trade and Finance from Cass Business School. Upon completion of his studies,
he worked for eleven years in Investment Banking for HSBC Bank (London / Athens), Piraeus Prime Bank (JV with Bank of Tokyo
Mitsubishi) and Arrow Finance (merchant banking boutique) with particular emphasis on Corporate & Project Finance, Mergers
& Acquisitions, privatizations and capital fund raising.
Since 2006 Elenos Karaindros is part of METLEN senior management, currently holding the position of Chief Strategy and M&A
Officer and Chairman M Concessions with an overall responsibility for: (a) development of the Company’s strategy and (b)
assessment of investment proposals and execution of transactions. He is a member of METLEN Executive Committee and several
other internal committees. He has two children, Katerina and Amalia.
7. Statement of Corporate Governance
414
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Eleftheria Kontogianni
Chief Financial Officer
Eleftheria Kontogianni is Chief Finance Officer at METLEN Energy & Metals S.A. (formerly MYTILINEOS S.A.) since January 2023.
She joined METLEN (formerly MYTILINEOS) in April 2018 as MIS Director and in 2020 she assumed the role of Finance & MIS
Director. Prior to METLEN she has built her experience in Lamda Development as Financial Planning & Analysis Manager for
Helliniko Project as well as in Titan Cement as MIS Manager.
Eleftheria Kontogianni was born in Athens in 1976. She studied Financial & Banking Management in University of Piraeus and she
has an ACCA qualification since 2011.
Dimitris Papadopoulos
Executive BoD Member & Chief Corporate Governance & Sustainable Development Officer
As per CVS OF THE MEMBERS OF THE BOARD OF DIRECTORS
Petros D. Selekos
Chief Legal Officer
Born in Larymna in 1965, Petros D. Selekos holds a BSc in Law from the University of Athens and a Master’s Degree in Company
Law, Commercial Law, Law of Intellectual Property, Law of Competition and Banking & Financial Law Max Planck Institute, while
in 1994 he completed his PhD in Company and Public Law in University of Athens.
He began his career in 1996 as a lawyer in the Secretariat of the Anti Trust Committee. In 1997 he took over the duties of Legal
Advisor at the General Secretariat of Commerce at Ministry of Development, while at the same time he founded the Law Firm
Selekos Gouskou & Co, which he is a Managing Partner until today. In 2000 he took over the position of Legal Advisor & Manager
of Judicial Affairs at Greek Post SA (ELTA), where he remained until 2019. From 2011 to 2015 he appointed Secretary General for
Strategic and Private Investments at the Ministry of Development and Competitiveness, while in 2020 he joined METLEN
(formerly MYTILINEOS) as Group General Counsel.
Since 2005 he has been a Lecturer in the Department of Business, Corporate & Labor Law at the Democritus University of Thrace
(faculty Law), while since 2018 he serves as an Assistant Professor in the same Department.
Today Petros D. Selekos is an active member of: Athens Bar Association, Athens Mediation & Arbitration Organization, Alumni of
Max-Planck Institut München, Center for International Legal Studies, Hellenic Association of commercial Law, Hellenic Association
of Maritime Law, Hellenic Society of Technology and Construction Law, Hellenic Institute of International and Foreign Law.
Fotios Spyrakos
Chief Administration Officer, Head of CEO's Office
He was born in Thessaloniki 1966. He is a graduate of Artistotle’s Univercity of Thessaloniki – Business Economics. He started his
career in 1992 with MYTILINEOS HOLDINGS SA and served as Chief Accountant until 1996, and CFO until 2000.
From 2000 since 2007 he held the positions of General Financial Director and General Director in HELLENIC VEHICLE INDUSTRY
SA. From 2007 since October 2010 he held the position of Managing Director. He was member of B.O.D. of ELVO and General
Secretary of Hellenic Aerospace & Defense Industries Association.
From November 2010 until June 2017, he held the position of Chief Executive Director Group Administration of MYTILINEOS
HOLDINGS SA.
From July 2017 until December of 2022 of he held the position of Chief of Staff.
From January 2023 until today he holds the position of Chief Administration Officer & Head of CEO’s Office.
Dimitris Stefanidis
Chief Executive Director, Metallurgy
Dimitris Stefanidis is the Chief Executive Director of the Metallurgy Sector of METLEN.
Born in Athens in 1958, Dimitris Stefanidis graduated from the School of Mining Engineering and Metallurgy of the National
Technical University of Athens. He is an ALUMINIUM OF GREECE executive since 1984. Initially, he worked as an engineer in the
Electrolysis section of the aluminium production line. In 1988 was appointed Head of the AB Electrolysis Lines. After his two-years
secondment to the Pechiney Group from 1992 to 1996, during which he worked in Pechiney’s Saint Jean de Maurienne plant, he
returned to ALUMINIUM OF GREECE as Head of Electrolysis (1994-1998) and Head of Smelting (1998-2002). From 2002 to 2005
he served as Continuous Improvement Director and then as Technical Manager of ALCAN’s plant in Tomago, Australia. Since July
2005 he held the position of Plant Director in ALUMINIUM OF GREECE and in 2009, he assumed the duties of CEO of ALUMINIUM
S.A. In 2017, he took over the responsibility of the Metallurgy Sector of METLEN, while from 2022 he is the General Manager of
7. Statement of Corporate Governance
415
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
the Metallurgy Sector of METLEN Energy and Metals. In 2017, after the first corporate transformation, he assumed the duties of
General Manager of Metallurgy, while after the second corporate transformation, those of Chief Executive Director, M Metals.
7. Statement of Corporate Governance
416
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The information required in accordance with article 10 par. 1 of Directive 2004/25/EC of the European Parliament and of the
Council is contained, as per the stipulations of article 4 par. 7 and par. 8 of Law 3556/2007, in the Explanatory Report, which is
presented above.
Evangelos Mytilineos
Chairman of the Board of Directors & Chief Executive Officer
Spyridon Kasdas
Vice-Chair A’, Non-Executive
IX. INFORMATION REQUIRED IN ACCORDANCE WITH ARTICLE 10 par. 1 OF DIRECTIVE 2004/25/EC OF THE EUROPEAN PARLIAMENT
AND OF THE COUNCIL
8. Report on the activities of the Audit Committee
417
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Introduction
The Audit Committee (hereafter the “Committee”) is pleased, through the present report, to inform the Annual General Meeting
of Shareholders on how the Committee has discharged its responsibilities.
This report provides an overview on how the Committee operates, an insight on the Committees activities during the year and
its role in ensuring the integrity of the published financial information and the System of Internal Controls.
In more details, this year's report provides information on the Committees activities in 2024, as well as the main points on which
its discussions and work focused. In addition to the main areas of discussion, within the scope of its responsibilities presented
below, the Committee addressed important issues of the Company as these emerged from the Management's periodic updates
to the Committee during the year.
The Committee recognizes the importance of Environmental, Social and Governance (ESG) topics and the evolving disclosure
requirements in the relevant area.
The Committee believes that continuous enhancement of our internal control environment continues to be key to the Company’s
sustainability.
In 2025, the Committee will focus on the most important issues and potential risks within its responsibilities.
The purpose of the Committee and its key responsibilities
The Committee has been established to assist the Board of Directors (the "Board") in fulfilling its oversight responsibilities
regarding audit procedures that ensure compliance with the legal and regulatory framework regarding:
a) financial information;
b) the System of Internal Controls, including the Internal Audit Division, the Risk Management Function and the Regulatory
Compliance Function; and
c) supervision of the (external) statutory audit of the Company's individual and consolidated financial statements, including
limited assurance audit of the sustainability report.
While all members of the Board individually and collectively have a duty to act in the interests of the Company, the Committee
has a particular role, acting independently from the executive Board Members, to ensure that the interests of shareholders are
properly protected in relation to financial reporting and internal control and risk management systems. However, the Board has
overall responsibility for the Company's approach to risk management and the system of internal controls.
The Committee reports to the Board on how it discharges its responsibilities and makes recommendations to the Board. A full
list of responsibilities is provided in the Committee’s terms of reference, which was found in no need for any amendment during
2024. The Committee’s Terms of Reference, which is approved by the Board of Directors, is available at https://www.Metlen
Energy and Metals.gr/media/agpivcyk/terms-of-reference-audit-committe-2021_en.pdf
The Committee reports to the Board, quarterly or whenever deemed appropriate, on the Committee's work, including
indicatively:
the significant, critical and substantive issues concerning the preparation of the financial reports and how these issues were
addressed;
its assessment of the effectiveness of the statutory audit process and its recommendation on the appointment, reappointment
or removal of the Statutory Auditor;
any issues on which the Board has requested the Committee's opinion;
the outcome of the statutory audit and an explanation of how the statutory audit contributed to the integrity of financial
reporting, and what the role of the Committee was in that process;
8. Report on the activities of the Audit Committee
8. Report on the activities of the Audit Committee
418
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
the overseeing of the preparation of the sustainability report, as well as the submission of the mandatory limited assurance audit
opinion on the sustainability report; and
the reports that the Internal Audit Director submits to the Committee, with regards to the activities of the Internal Audit Division.
The members of the Committee have stated that they accept their responsibilities and duties and that they will perform their
activities in accordance with the applicable Terms of Reference of the Committee, the Internal Regulation Code of the Company,
and the law.
Composition of the Committee, skills and experience
The Committee is a committee of the Board of Directors and consists of at least three (3) members, who in their entirety are
independent non-executive members of the Board. The Committee members are appointed by the Board following the
recommendation of the Company's Remuneration and Nomination Committee. The Committee Chair is appointed by the
Committee members. The Chair of the Board cannot be a member of the Committee.
According to the Terms of Reference of the Committee, the tenure of office of its members is similar to the term of office of the
Board, which is four years, unless otherwise decided by the General Meeting of the Shareholders or by delegation by it to the
Board. The tenure of office of this Committee shall expire on 02.06.2026.
Composition / Tenure of the Committee
The following table depicts the composition of the Committee during 2024, the tenure of its members as well as relevant notes
/ clarifications:
Member
Title
Duration
Alexios Pilavios
Chair up to 31.08.2024 and Member
since 01.09. 2024
02.06.2022 – 02.06.2026
Konstantina Mavraki
Member
02.06.2022-02.06.2026
Anthony Bartzokas
Member up to 31.08.2024 and Chair
since 01.09.2024.
02.06.2022-02.06.2026
It is worth mentioning that the Ordinary General Meeting of the Company's shareholders (dated 15.06.2021, in accordance with
the provisions of article 44 of law 4449/2017, as amended and in force, decided that the Audit Committee will be a committee
of the Board of Directors, which shall consist of three independent non-executive members of the Board. In this context, the
Board of the Company on 02.06.2022 appointed three of its independent members as members of the Audit Committee. The
Audit Committee, during its meeting on 02.06.2022, was formed into a body and appointed from among its members Mr. Alexios
Pilavios as its Chairman.
The Audit Committee on 01.09.2024 decided, in the context of preparing a succession plan, to ensure the optimal operation and
effectiveness of the Audit Committee, to rotate the Chairman and specifically decided to appoint the youngest member of the
Audit Committee, Mr. Anthony Bartzokas, as Chairman of the Audit Committee.
The members of the Committee have competencies related to the sectors in which the Company operates, as they have sufficient
knowledge in the field of industrial products and services, in auditing or accounting and experience in the areas of Corporate
Governance and Internal Control Systems.
Brief CVs of the Committee’s members have been posted on the Company’s website.
Attorney Mrs Vassiliki Prantzou is the Committee’s Secretary. The Corporate Secretary cooperates with the Secretary of the
Committee and assists the Committee within the framework of her responsibilities.
Finally, the Committee has at its disposal the necessary resources to enable it to obtain the assistance of external consultants, if
required. In 2024, the Committee was provided with advisory services by Deloitte on addressing specific enquiries raised by the
8. Report on the activities of the Audit Committee
419
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Committee relating to financial and sustainability reporting, as well as on organizational matters of the Committee in compliance
with the legislative and regulatory framework.
Committee Meetings and Operation
The Committee meets at regular intervals, at least four (4) times per year, and holds extraordinary meetings when required. The
Committee Chair discusses with the Board the work of the Committee at at every scheduled Board meeting, according to the
annual meeting schedule/calendar.
For 2024, the Committee met frequently (12 times in total) and discussed all the topics falling under the areas of its
responsibilities, with its main focus on: a) External Audit and Financial Reporting process, b) Internal Audit, c) Internal Control
System, d) Organisational matters, e) Non-financial reporting and Sustainability matters, f) Other topics relevant to the mandate
of the Committee. All the Committee’s decisions were unanimous. The Committee on 15.07.2024 met in a joint session with the
Sustainable Development Committee with the topic discussion focusing on CSRD and non financial reporting.
All members of the Committee attended all the meetings for 2024.
In addition to the members of the Committee, the Secretary and the Corporate Secretary participate in the meetings when they
are not the same person. It is at the discretion of the Committee to invite, whenever deemed appropriate, other members of the
Board, or other key persons from inside and outside the Company, to inform it and / or attend a specific meeting or specific items
of the agenda. The Executive Director M-RES, the Chief Finance Officer, the Chief Treasury & IR Officer, the Chief of Staff, the
Chief Administration Officer and Head of CEO’s office, the Internal Audit Director, the Compliance Director, the Group Enterprise
Risk & Operations Director, Management teams’ members relevant to issues identified by the Internal Audit, as well as the
statutory auditor or audit firm are invited regularly to the Committee meetings, at the Committee Chair's initiative.
Financial Reporting
Publication of non-audited financial figures and other key information - «Flash Notes»
The Finance Division presented to the Committee the preliminary financial results which were published subsequently by the
Company in the form of a «Flash Note», for the financial year ended 31 December 2023, as well as for the period from 01 January
2024 to 30 June 2024 respectively. The aforementioned «Flash Notes» referred to non-audited financial figures and estimates of
the Management and forecasts relating to financial data or other events of the above periods. It is noted, however, that the
external auditor carried out specific pre-agreed procedures on the «Flash Notes», for the purpose of issuing «Comfort Letter» to
the Company's Management. In the "Comfort Letter" of the external auditors, no disagreements were expressed with regards to
the data reported through the «Flash Notes». The Committee did not identify any gaps or deviations in the information and
safeguards provided to it and recommended to the Board the approval of the publication of the «Flash Notes». Finally, the
Committee reviewed the relevant press releases on the «Flash Notes».
Financial
Statements
2024
In March 2025, the Committee was informed by the Finance Division about the Company's
Financial Statements, both at company and at consolidated level, which were prepared in
accordance with the IFRS for the year ended 31 December 2024. The Committee was also
informed regarding the main accounting assumptions the Company adopted for preparing the
Financial Statements, and regarding the key issues the Finance Division considered while
preparing these Statements. The Committee, also, confirmed regarding the sustainability
information that it was reviewed by PwC as part of the audit of the 2024 annual financial report.
The Committee discussed with the external auditor (PwC) and the Finance Division the key audit
matters during the audit of the Company's annual financial statements for the financial year
ended 31 December 2024. The Committee drafted an explanatory report for the Board of
Directors and recommended that the Board approves the Financial Statements. In this report, the
Committee explained to the Board how the mandatory audit contributed to the integrity of
financial reporting and what the role of the Committee was in this process. In this context, the
Committee evaluated and concluded that the annual financial report, along with the annual
financial statements and the annual management report of the Company, reflect in a true, fair,
balanced and understandable manner the evolution, performance and position of the Company,
8. Report on the activities of the Audit Committee
420
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
as well as of the companies included in the consolidation, and provide the required information
to the Shareholders.
The Committee also informed the Board that the external auditors have contributed substantially
to the integrity of the Financial Statements with their experience and independent assurance that
the financial statements reasonably present, in all material aspects, the financial position of the
Company and the Group as at 31
st
December 2024, their financial performance and their cash flow
for the year ended on that date.
Financial
Results 1
st
quarter
2024
The Finance Division informed the Committee on the financial results of 1st quarter 2024 and
brought to its attention the draft relevant announcement to the investors. The Committee, after
receiving assurance on the correctness and accuracy of the information that will be made public,
expressed its satisfaction for the Company’s progress.
Semi-Annual
Financial
Results 2024
The Finance Division informed the Committee on the semi-annual financial results of 2024 and no
gaps or deviations were identified in the assurance provided on the correctness and accuracy of
the information. The Committee drafted an explanatory report on the review of the Company's
half-yearly individual and consolidated financial statements to the Board
Financial
Results 3
rd
quarter
2024
The Finance Division informed the Committee on the financial results of 3
rd
quarter 2024. The
Committee, after receiving assurance on the correctness and accuracy of the information that will
be made public, expressed its satisfaction for the Company’s progress.
External (Statutory) Auditors
Appointment of the external auditors
The Committee has primary responsibility for the appointment of the key audit partner (external auditor). This includes
negotiating the fee and scope of the audit, initiating a tender process, expressing an opinion regarding the appointment of an
engagement partner and making formal recommendations to the Board on the appointment, reappointment and removal of the
external auditors.
In 2023, the Committee conducted a tender for the selection of a new external auditor, in the context of the implementation of
Regulation (EU) No 537/2014 of the European Parliament and of the Council of 16 April 2014 and the relevant transitional
provisions of article 52 of Law 4449/2017 regarding the specific requirements for the statutory audit of public-interest entities.
In November 2023, the tender for the nomination of new candidates for the audit of the company’s individual and consolidated
financial statements for the financial year 01.01.2024-31.12.2024 was completed. In particular, the Committee, after holding
individual meetings with each of the candidate auditing companies and, taking into consideration the evaluation of their offers,
from a technical and financial point of view, submitted its recommendation to the BoD for the appointment of the audit firm PwC
as external auditor for the fiscal year 2024. The Annual General Meeting of the Company’s shareholders held on 04.06.2024
elected PwC as external auditor for the fiscal year 2024.
Pursuant to provisions of law 5164/2024 and article 92 of law 5172/2025, the Committee recommended to the BoD to appoint
the statutory auditor (PwC) for the mandatory limited assurance audit of the 2024 sustainability report.
Safeguarding independence and objectivity and maintaining effectiveness
In its relationship with the external auditors, the Committee needs to ensure that they retain their independence and objectivity
and are effective in performing the statutory audit. Both the Board and the external auditor have policies and procedures
designed to protect the independence and objectivity of the external auditor.
8. Report on the activities of the Audit Committee
421
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
The Committee considers the external auditors’ annual declaration of independence and discusses with them threats, that may
threaten their independence, as well as ways to ensure that these threats are addressed. The Committee examined whether the
relationships, considering the views of the external auditor, of the Management and of the internal audit, as appropriate, appear
to affect the auditor's independence and objectivity.
In 2024, the external auditors submitted to the Committee the declaration of their independence from the Company in
accordance with the Code of Ethics for Professional Accountants of the International Ethics Standards Board for Accountants
(IESBA Code) and the ethical requirements related to the audit of the financial statements in Greece.
Financial Statements
The Committee has devoted a significant amount of time during its meetings in order to be informed and to discuss the process
for the preparation of the annual and semi-annual Financial Statements. Main matters and activities performed were as follows:
Matter
Activity
Statutory Audit
Planning for the
financial year
31.12.2024
PwC, the newly appointed External Auditors, presented to the Committee a report,
which, inter alia, reflected the plan of communication between the external auditors
and the Committee in relation to the timing of the statutory audit, of the separate and
consolidated statements of the Company and its subsidiaries for the financial year
31.12.2024, the audit teams and specialists, as well as a reference to the key audit
matters during the audit planning and in particular to the identified risks of the financial
statements.
Audit of Annual
Financial Statements
(2024) –
Key Audit Matters
In external auditors’ opinion, the corporate and consolidated financial statements
reasonably present, in all material respects, the financial position of the Company and
its subsidiaries as 31 December 2024, its financial performance and its cash flows for
the year ended that date in accordance with International Financial Reporting
Standards as adopted by the European Union.
In the discussions with the external auditors, particular emphasis was placed on the
“Key Audit Matters” as identified by the external auditors, and how they these were
treated during the audit.
Revenue from Asset Rotation Plan contracts.
Recognition of Revenue from consumed and unbilled energy.
Recognition of Revenue, Contract Assets and Contract Liabilities from EPC and
Construction Contracts.
In addition, the Committee confirmed as regards the sustainability information that
it was reviewed by PwC in the context of the audit of the 2024 annual financial report.
The Committee examined and discussed in detail the above issues with the external
auditors, without the presence of executives of the Company's Finance Division.
Report of the Audit
Committee to the
Board of Directors on
the Financial
Statements 2024
The Committee, following the review of the Financial Statements of the parent
company and the Group for the year ended 31
st
December 2024 and the discussions
held with the Finance Division and the external auditors, proposed their approval to
the Board.
8. Report on the activities of the Audit Committee
422
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Tax Audit
The external auditors for the financial year 2023 (Grant Thornton), in a meeting with
the Committee without the presence of executives of the Company's Finance Division,
informed the members of the Committee about:
the completion of the tax audit which they carried out in accordance with
Article 65A para. 1 of Law 4174/2013 and POL.1124/2015, as amended in
force, for the Company itself and those of its Greek subsidiaries that have
been subject to the tax audit for the year 2023
the Tax Compliance Reports issued in the context of the above tax audit and
the evolution of tax audits by the authorities.
Review of Interim
Financial Statements
The external auditors informed, through a relevant report/ presentation, the
Committee on their review of the Interim Financial Statements for the first half of 2024
carried out in accordance with ISA. The External Auditors referred, inter alia, to the
scope and areas, as well as their procedures for the review of the Group, the
determination of materiality, unrecorded misstatements and the key issues of their
review.
Additional Report to
the Audit Committee
for 2024
The external auditors submitted and presented to the Committee their additional
report, as provided by article 11 of EU Regulation 537/2014 on their audit of the
Company and Group Financial Statements for the year ended 31 December 2024.
Report of the Audit
Committee to the
Board of Directors on
the Financial
Statements 2023
The Committee, following the review of the Financial Statements of the parent
company and the Group for the year ended 31
st
December 2023 and the discussions
held with the Finance Division and the external auditors for the financial year 2023
(Grant Thornton), proposed their approval to the Board.
Additional Report to
the Audit Committee
for 2023
The external auditors for the financial year 2023 (Grant Thornton) submitted and
presented to the Committee their additional report, as provided by article 11 of EU
Regulation 537/2014 on their audit of the Company and Group Financial Statements
for the year ended 31 December 2023
Use of the external auditors for non-audit services
The Committee monitors the external auditors’ compliance with the provisions of Regulation (EU) No 537/ 2014, as in force,
regarding the level of the total fees paid by the Company to them in proportion to the overall fee income of the external auditors
or their overall fee income from audit services, as well as other related regulatory requirements, so that the external auditors’
independence and objectivity is not impaired by the amount of work provided to the Company.
The Committee is responsible for approving non-audit services to the Group entities that are not prohibited by law. The
Committee considers that the external auditors have significant knowledge of the Group’s business and of how accounting
policies are applied. That means it is sometimes cost-efficient for them to provide non-audit services. There may also be
confidentiality reasons that make the external auditors the preferred choice for a particular non audit assignment.
However, safeguarding the external auditors’ objectivity and independence is an overriding priority. For this reason, the
Committee ensures that the provision of such services does not impair the external auditors’ independence or objectivity.
In the context of non-audit services, whose provision by the Statutory Auditor is not prohibited by law, the Committee should
apply judgement on and assess the following:
threats to independence and objectivity resulting from the provision of such services and any safeguards in place to eliminate or
reduce these threats to a level where they would not compromise the auditors’ independence and objectivity,
8. Report on the activities of the Audit Committee
423
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
the nature of the non-audit services,
whether the skills and experience of the audit firm make it the most suitable supplier of the non-audit services,
the fees incurred, or to be incurred, for non-audit services both for individual services and in aggregate, relative to the audit fee,
including special terms and conditions (for example contingent fee arrangements), and
the criteria which govern the compensation of the individuals performing the audit.
During 2024, the Committee examined the non-audit services that were proposed to be performed by the external auditor and/or
members of its network for the Company or subsidiaries of the Group, where the Committee, after evaluating the nature of
proposed services, the safeguard deployed and receiving relevant clarifications, declarations and assurance from the external
auditor, considered that they did not pose a threat to the external auditor's independence in accordance with the provisions of
article 44 of Law 4449/2017 and article 5 of Regulation (EU) 537/2014. The relevant non-audit services concerned a) agreed upon
procedures (AUP) for the purpose of assisting the Company to assess whether the calculations of the Metlen Group Financial
Covenants for the period ended as of 30/06/2024, as those included in the respective Compliance Certificates, have been
prepared from the consolidated financial statements of the Group and underlying accounting records as well as it is
mathematically accurate, performed by PwC, b) reporting accountant services in relation to the bond issued by the Company
with public offering in Euro MTF, Luxembourg, performed by PwC, c) project value assurance services performed by
Pricewaterhousecoopers Business Solutions SA, d) participation in various PwC’s academy training seminars performed by
Pricewaterhousecoupers Business Solutions SA, and e) consulting services performed by PwC New Zealand to M RENEWABLES
NZ DEVELOPMENTS PTY LIMITED regarding implications of assets acquisitions in New Zealand.
Neither the work done, nor the fees payable of the assigned non audit services, compromised the independence or objectivity of
our external auditors.
Internal Audit
The Internal Audit Division (IAD) provides independent and objective assurance over the design and effectiveness of the System
of Internal Controls. The Division reports to the Committee and administratively to the Chief Executive Officer. Internal Audit
activity is carried out based on a robust methodology and in accordance with the International Professional Practices framework,
which includes the IIA standards and the Code of Ethics, and the continuous development of the audit methodology applied. The
conformity is assessed through an external quality assessment by an independent consultancy organization every year.
The Committee has a standing agenda item to ensure adequate coverage of internal audit related topics and reports significant
Internal Audit findings at BoD meetings. In monitoring the activity, role and effectiveness of the Internal Audit Division (IAD) and
its audit program, the Committee had frequent meetings with the Internal Audit Senior Director. The main matters examined
through 2024 related to the following:
Matter
Activity
Internal Audit Plan
2024
The Internal Audit Division submitted to the Committee for approval the internal audit
plan for 2024, which is subject to revisions, depending on the extraordinary needs of
the Company, including the suggested relevant budget.
Internal Audit Annual
Report 2024
The Internal Audit Division submitted and presented to the Committee a report on its
activities for the year 2024, expressing its audit opinion on the internal control system,
taking into account the results of its audits, other external assurance providers’ results
and any limitations mentioned in its report.
Quarterly Activity and
Follow-Up Reports
2024
The Internal Audit Division submitted and presented to the Committee quarterly
activity and follow-up reports for 2024 on the Division’s suggestions on improvement
of the Internal Control System.
The Committee was also informed by the Internal Audit Director on the audits carried
out and the reports issued in 2024. The most important findings of the internal audits
8. Report on the activities of the Audit Committee
424
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
and the management’s responses were discussed with the Committee and the BoD was
informed accordingly.
Internal Audit Plan
2025
The Internal Audit Division submitted to the Committee for approval draft of the
summary internal audit plan for 2025, including estimated budget and availability of
manpower. The internal audit plan is subject to revisions according to the dynamic
method of developing the annual plan.
Internal Audit Coverage
The Committee monitored the progress of internal audit assignments performed by
the Internal Audit Division, which related to the coverage of key risk areas, based on
the risk based Internal Audit Plan 2024 and informed the BoD accordingly.
Recertification of IAD
activities
Report on external recertification of IAD activities’ quality by IFACI (September 2024).
The IFACI Certification engagement was carried out in accordance with the
International Professional Practices Framework of The Institute of Internal Auditors
modelled in the Professional Framework for Internal Audit version 2020.
Annual Evaluation of
the Internal Audit
Senior Director
The annual evaluation of the Internal Audit Division’s Senior Director for the year 2024
was completed during the 1
st
quarter 2025.
CSRD compliance self-
assessment
The Internal Audit Senior Director briefed the members of the Audit Committee on the
results of the CSRD compliance self-assessment and focused on the issues on which the
Company should focus in order to achieve harmonization with the regulatory
requirements, while it emerged that the greatest harmonization requirements are
found in the field of assessing impacts, risks, opportunities and that of indicators and
measurements. The Committee endorsed IAD’s proposal to discuss the results of the
self-assessment with the external consultant.
Fraud Risk Assessment
The Internal Audit Senior Director presented to the Committee the results of a fraud
risk assessment in cooperation with the Compliance Division.
The assessment process identified potential fraud scenarios. Higher priority was given
to the development of automated control mechanisms, while a joint action plan was
developed for the two directorates. The Committee approved the development of the
proposed analysis scenarios proposed by IAD.
Management is responsible for addressing the issues raised by Internal Audit Division within an agreed timetable and the
Committee reviews their timely completion.
System of internal controls
Specific related matters that the Committee considered for the year 2024 included the following activities:
Matter
Activity
8. Report on the activities of the Audit Committee
425
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Enterprise Risk
Management
Framework
An Annual status update of the ERM Division to the Audit Committee on ERM
Framework was performed, with key information focusing on the fact that ERM
Division accomplished a set of key milestones during the year and closely followed its
plan to enhance practices, strengthen the team, increase cooperation and coordination
among assurance providers through the initiation of the GRC platform, and meet the
requirements of Provision 29 of the UK Corporate Governance Code.
Information Systems
and Information
Systems Security
The Committee is regularly informed by the Chief of Staff on key IT projects in the
course of the digitalization of the Company. The Committee is also informed by the
Information Security Officer on cybersecurity issues and the adequacy of the security
of the company’s IT systems.
Penetration test
The IT Division informed the Committee on the performed Penetration Test Results.
The penetration test took place from 9/2023 till 2/2024 and the scope of it included all
possible attack paths someone can utilize to attack a company. The results of the test
were satisfactory.
Project for the
assessment of the
adequacy of the
procedures of central
and support function
within the COSO 2013
framework
The Group Enterprise Risk & Operations Director, presented, on behalf of the Chief
Administration Office, the monitoring of the progress of the response actions, the
monitoring of the progress of improvement proposals of COSO projects and the self-
evaluation of the Policies/Procedures Model. Overall, business risk executives find that
the risk management culture in the organization is improving.
Evaluation of the
internal control
procedures over
financial reporting of
the Company and the
Group by the External
Auditors
The external auditors for the financial year 2023 (Grant Thornton) presented to the
Committee their report for the evaluation of the internal control procedures over
financial reporting of the Company and the Group based on their audit for the year
2023 (Management letter).
Regulatory Compliance
The Committee was informed by the Compliance Division on the annual report of its
activities for 2024 and approved the Division’s annual work plan for 2025. The
Compliance Division informed the Committee on semi-annual basis of the operation of
the whistleblower line for violations of the Company’s Code of Conduct.
Non-Financial
Reporting and CSRD
In July 2024 during the Joint Meeting of the Audit Committee and the Sustainable
Development Committee, the external advisor (Deloitte) presented the following
topics:
Sustainability Reporting Landscape: The Integrated Sustainability Reporting
Framework | Key Priorities
Corporate Sustainability Reporting Directive (CSRD) | Scope and Reporting
requirements
8. Report on the activities of the Audit Committee
426
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Responsibilities and the Enhanced Role of the Audit Committee | Reporting
requirements
Responsibilities and the Enhanced Role of the Board of Directors | Sustainability risks
and Board of Directors
The Role of the Internal Auditor
Other significant matters
Matter
Activity
Annual work plan for
2025
The Committee approved its annual work plan for the year 2025.
Reports to the Board of
Directors
The Committee prepared and submitted reports on its activities to the BoD for the year
ended 31 December 2023, and for the quarters ended 31 December 2024, 31 March
2024, 30 June 2024, and 30 September, 2024.
Annual Report on the
activities of the Audit
Committee for the year
ended 2023
The Committee submitted its Annual Report on its activities for the year ended 2023
to the General Assembly of the Shareholders of 04.06.2024.
Implementation of
Action Plan following
evaluation of the Audit
Committee
The Committee informed the BoD of the action plan implemented in 2024, in response
to improvement opportunities identified following evaluation of the Committee.
Sustainability Policy
Sustainable Development is an integral part of the METLEN long-term business strategy. It is the driving force through which the
Company aspires to remain competitive in the long term, to meet contemporary challenges and, by developing appropriate
partnerships, to contribute to a new and efficient model of socially inclusive growth, as this is reflected in the Sustainable
Development Goals.
The Company's Sustainable Development Strategy is aimed at creating long-term and sustainable value for shareholders and
other Stakeholder groups, through a holistic approach that combines economic stability with social and environmental
sustainability. It is implemented on three basic levels that are inseparable from one another and is governed by specific Principles
that ensure completeness (Materiality Principle), quality (Stakeholder Inclusiveness Principle) and transparency (Accountability
Principle) across all its activities.
8. Report on the activities of the Audit Committee
427
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
More specifically:
The first level expresses the Company's commitment to tackling climate change and its contribution to a low-emissions
economy. METLEN is fully aware that climate change is one of the most urgent issues facing the planet. Moreover, the Company,
considering the high CO
2
emission intensity in its production processes, has highlighted the adaptation of its activities to the
consequences of climate change and the implementation of initiatives to address it, as key elements for its sustainable operation.
In this respect, it has designed a local strategy to address climate change, which serves to guide its initiatives to reduce carbon
dioxide emissions as defined by the Kyoto Protocol, the Paris Agreement on Climate Change (COP21) and the corresponding
National Plan of Greece, which sets out its contribution to the European Green Deal (EU Green Deal).
Strategic priorities
i. To further adapt its activity to the consequences of climate change by analyzing the risks involved, while also taking
advantage of the opportunities arising.
ii. To implement, control and review the initiatives and the corresponding
CO
2
emission reduction and net zero targets for
2030 and 2050.
iii. To integrate climate targets into the Company’s strategic planning and decision-making processes.
iv. To implement an investment plan in >2.5 GW of RES assets by 2030.
v. To develop strategic partnerships for the application of new technologies to production activities, with the aim of reducing
the CO
2
emission intensity.
vi. To further develop the activities of the new Renewables & Storage Development Business Unit.
The second level focuses on METLEN ENERGY AND METALS’ systematic approach to the recording, optimal management and
disclosure of information about the ESG risks and opportunities that may affect its performance, as well as its efforts to
implement its strategy. Through the ESG approach, METLEN ENERGY AND METALS strengthens its ability to create long-term
value and manage significant changes in the environment in which it operates. In this way, it responds to the modern-day
sustainability requirements of investors, capital markets and financial institutions, as well as to society's expectations of
commitment and transparency regarding these issues, whose number keeps increasing.
Strategic priorities
8. Report on the activities of the Audit Committee
428
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
i. To determine Material ESG topics and link them to the Company's financial performance.
ii. To optimally manage of ESG risks and opportunities to create long-term value.
iii. To enhance the trust and facilitate the flow of information between the Company and the investor community.
iv. To responsibly disclose Non-Financial Information in accordance with the international standards.
v. To constantly improve / maintain ESG performance levels.
vi. To integrate ESG criteria into the Company's investment decisions and into main operating procedures.
The third level focuses on the responsible operation of METLEN ENERGY AND METALS, which has been systematically
cultivated, since 2008, through the implementation of Responsible Entrepreneurship and the Company's commitment to the
10 Principles of the UN Global Compact. For METLEN ENERGY AND METALS, Responsible Entrepreneurship is an ongoing self-
improvement and incessant learning process, while it also serves as a key mechanism for renewing its “social license to operate”,
while at the same time it helps improve its competitiveness at national and international level.
Strategic priorities
i. To remain committed to its objective of ensuring a healthy and safe work environment without accidents, adopting a
prevention-oriented approach.
ii. To constantly mitigate the environmental impacts of its activity.
iii. To develop, manage and retain a dedicated human capital, with practices that promote an inclusive working
environment, with equal opportunities and respect for Human Rights.
iv. To continue to treat its people with responsibility and consistency, remaining their first choice of employer during their
entire career paths, while at the same time investing in their training and in the development of their skills.
v. To implement actions of high social value, including through the development of employee volunteering.
vi. To engage in a systematic and honest dialogue with its key Stakeholder groups, seeking to maintain mutual trust and as
well as a fuller understanding by the Company of the impacts of its operation.
vii. To contribute to the development of local infrastructure and, overall, to the prosperity and the respect of the rights of
the citizens of the local communities adjacent to the Company's industrial units.
viii. To develop responsible procurement / purchases by expanding the commitment of the Company's key suppliers and
business partners to sustainable development.
ix. To place emphasis on the quality and safety standards of the Company's products as well as on the continuous support,
service and satisfaction of customers.
Marousi, 12.03.2025
The Audit Committee
Anthony Bartzokas
Konstantina Mavraki
Alexios Pilavios
9. Independent Auditor’s Report
PricewaterhouseCoopers SA, GEMI: 001520401000, T: +30 210 6874400, www.pwc.gr
Independent auditor’s report
To the Shareholders of Metlen Energy & Metals SA
Report on the audit of the separate and consolidated financial statements
Our opinion
We have audited the separate and consolidated financial statements of Metlen Energy & Metals SA (the “Company” and/or the
“Group”) which comprise the separate and consolidated statement of financial position as at 31 December 2024, the separate
and consolidated statements of profit or loss and other comprehensive income, changes in equity and cash flow statements for
the year then ended, as well as notes to the separate and consolidated financial statements, comprising material accounting
policy information.
In our opinion, the separate and consolidated financial statements present fairly, in all material respects the separate and
consolidated financial position of the Company and the Group as at 31 December 2024, their separate and consolidated financial
performance and their separate and consolidated cash flows for the year then ended in accordance with International Financial
Reporting Standards, as adopted by the European Union and comply with the statutory requirements of Law 4548/2018.
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (“ISAs”), as they have been transposed into
Greek Law. Our responsibilities under those standards are further described in the “Auditor’s responsibilities for the audit of the
separate and consolidated financial statements” section of our report.
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Independence
We are independent of the Company and the Group in accordance with the International Code of Ethics for Professional
Accountants issued by the International Ethics Standards Boards of Accountants (the “IESBA Code”) that has been transposed
into Greek Law, and the ethical requirements of Law 4449/2017 and of Regulation (EU) No 537/2014, that are relevant to the
audit of the separate and consolidated financial statements in Greece. We have fulfilled our ethical responsibilities in accordance
with the requirements of the IESBA Code, the Law 4449/2017 and the Regulation (EU) No 537/2014.
We declare that the non-audit services that we have provided to the Company and its subsidiaries are in accordance with the
aforementioned provisions of the applicable law and that we have not provided non-audit services that are prohibited under
Article 5 par. (1) of Regulation (EU) No 537/2014.
The non-audit services that we have provided to the Company and its subsidiaries during the year ended 31 December 2024, are
disclosed in the note 3.23 of the separate and consolidated financial statements.
Key audit matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the separate
and consolidated financial statements of the year under audit. These matters were addressed in the context of our audit of the
separate and consolidated financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate
opinion on these matters.
Key audit matter
How our audit addressed the key audit matter
Revenue from “Asset Rotation Plan” Contracts
(Notes 2.5.2, 3.1 and 3.13 of the Consolidated and Separate Financial Statements)
The Group is active, among others, in the development,
construction and subsequent sale of Renewable Energy
Sources (“RES”) electricity producing plants. The
development of these projects is carried out through
special purpose vehicles (“SPV”) which are transferred
through purchase and sale agreements to the end
customer.
Management, applying professional judgment, chose to
recognize the sale of the SPVs in accordance with the
provisions of IFRS 15 “Revenue from Contracts with
Customers” (“IFRS 15”) considering that, based on the
economic substance of the transactions, this is a sale of
The audit procedures that we performed, among
others, are as follows:
- We obtained an understanding of the Group’s
“Asset Rotation Plan” contracts as well as the
Group’s procedures regarding the process of
estimating and calculating the revenues arising
from these contracts;
- We inspected the relevant contracts and
assessed whether the policy and methodology
applied by Management are appropriate and
consistent with IFRS 15 and whether the
PricewaterhouseCoopers SA, GEMI: 001520401000, T: +30 210 6874400, www.pwc.gr
Key audit matter
How our audit addressed the key audit matter
an asset that constitutes part of the Group’s ordinary
activities.
The revenue of these contracts is recognized based on
the contract value and the percentage of achievement
of the contractual milestones of the project (“output
method”).
During our audit, we focused on this area because
Management exercises judgment in applying the
appropriate accounting policy for revenue recognition
from the above contracts and more specifically to:
- decide whether each contract for the
development, construction and delivery of an
operational RES project to the buyer
constitutes a single performance obligation
for the Group,
- to assess that the most appropriate
accounting method for the recognition of
revenue under these contracts is in
accordance with IFRS 15 and not as a sale of
subsidiaries in accordance with IFRS 10
“Consolidated Financial Statements”,
- to conclude that the performance obligation
under these contracts is satisfied gradually
over time and that the most appropriate
method of measuring the progress of work of
each contract would be the application of the
“output method”, which recognizes revenue
based on the measurement of the value of
the goods or services transferred to the
customer.
In exercising these judgments, Management has taken
into account, among other matters, the benefits that
accrue to buyers during the development and
construction period of these RES projects, such as their
ability to negotiate and agree financing agreements
and/or enter into Power Purchase Agreements with
their customers.
In addition, Management exercises significant
judgment in assessing the percentage of completion of
each RES project by applying the output method for
recognizing revenue over time in accordance with IFRS
15, which requires the attribution of values to specific
project milestones, such as at the different stages of
obtaining permits and at the various stages of
construction. The attribution of these values by
milestone is based on information about commercial
margins applicable to RES construction contracts, as
well aother market information. The aforementioned
judgements have a significant impact on the timing of
revenue recognition over the course of a project, which
may span more than one financial period.
accounting treatment followed based on
Management’s judgment is supported.
- We inspected the licensing agreements for
projects that are in the development stage.
- We recalculated the revenue recognized using
the percentage of completion method in
accordance with the “output” method, based
on specific contractual stages and project
milestones up to the reporting date.
- For a sample of expenses included in cost of
sales, we compared the relevant calculations
and data with the corresponding contracts,
licenses, documents or other supporting
documents.
- We evaluated Management’s estimates of
expected costs to completion of the projects by
referring to supporting documents, such as
budgets and certifications, and by comparing
previous estimates with actual historical
results.
- We compared Management’s estimates of
contract margins with the data applicable to
RES construction contracts where the Group
acts exclusively as a contractor for the
construction phase.
- We examined the recoverability of contract
assets by referring to certifications and
collections.
- We evaluated the adequacy and
appropriateness of the disclosures related to
revenue arising from “Asset Rotation Plan”
contracts in the financial statements.
Based on the evidence we gathered, we concluded that
the methodologies and data used by management to
recognize revenue from “Asset Rotation Plan”
contracts were appropriate, that the key assumptions
applied were reasonable and that the related
disclosures in the consolidated financial statements are
adequate.
PricewaterhouseCoopers SA, GEMI: 001520401000, T: +30 210 6874400, www.pwc.gr
Key audit matter
How our audit addressed the key audit matter
Revenue for the year ended 31 December 2024 from
Asset Rotation Plan contracts and the corresponding
contractual assets at that date amounted to €709.4
million and €781 million respectively.
Recognition of accrued revenue from retail sales of energy and natural gas
(Notes 2.5.2, 3.1 and 3.11 of the Consolidated and Separate Financial Statements)
Retail electricity and natural gas revenue is recognized
when electricity and natural gas are supplied and
consumed by customers. Revenue is calculated based
on periodic measurements and includes the estimated
accrued revenue for the value of electricity and gas
consumed from the date of the last meter reading to
the end of the reporting period.
During our audit, we focused on this area because the
calculation of unbilled revenue by management
involved significant estimates and judgements, the
most significant of which relate to:
- The volume of electricity and natural gas
supplied to customers.
- The unit value of these volumes based on
applicable tariffs.
- Technical and non-technical losses in the
distribution network.
Management estimates unbilled revenue using billing
systems and estimating the quantities purchased for
retail purposes during the year. This estimate is
adjusted for various factors that could affect actual
usage and differences between the system estimates
and actual meter readings.
Given the complexity of the estimation process and the
level of judgment required by Management, the
inherent risk of not recognizing revenue in the correct
period, and the significant time required to audit this
area, we identified the above as a key audit matter.
Accrued and unbilled revenue for the year ended 31
December 2024 and the corresponding unbilled
balance at that date amounted to €200.8 million and
€213.3 million respectively.
The audit procedures we performed are as follows:
- We obtained an understanding of the
Group’s procedures regarding the estimates
and corresponding calculations of the
Group’s unbilled revenues.
- We compared the system data with
electricity and natural gas data obtained from
third-party sources to verify the estimated
supply quantities and to validate network
losses.
- We assessed the reasonableness of the unit
values applied, verifying the unit prices
against the actual tariffs and contractual
terms.
- We performed an independent recalculation
of the unbilled revenues model to verify its
numerical accuracy.
- We assessed the historical accuracy of
management’s forecasts by comparing prior
years’ estimates with actual invoiced
amounts.
- We assessed the adequacy and
appropriateness of the disclosures related to
unbilled revenues in the financial statements.
Based on the audit evidence we collected, we
concluded that the methodologies and data used to
recognize ubilled revenue were appropriate, that the
key assumptions applied were reasonable and that the
related disclosures in the consolidated financial
statements are adequate.
Recognition of Revenue, Contract Assets and Contract Liabilities from EPC and Construction Contracts
(Notes 2.5.2, 3.1 and 3.13 of the Consolidated and Separate Financial Statements)
A significant portion of the Group’s revenue is derived
from long-term Engineering, Procurement and
Construction (EPC) and outright construction contracts.
Revenue recognition from construction contracts is
based on the percentage of completion method based
on cost (the “input method”) in accordance with IFRS
15. The determination of the percentage of completion
based on cost requires significant assumptions and
estimates by Management regarding the budget of the
completion costs of the projects. Estimates are also
The audit procedures we performed are as follows:
- We obtained an understanding of the Group's
revenue recognition process for EPC and
construction contracts,
- We focused our work on the contracts with the
most significant progress of work during the year
and on the contracts that are close to their
completion,
- We recalculated the revenue recognized using
the percentage of completion method based on
cost, according to the expenses incurred up to
PricewaterhouseCoopers SA, GEMI: 001520401000, T: +30 210 6874400, www.pwc.gr
Key audit matter
How our audit addressed the key audit matter
required regarding the likelihood of accepting requests
for additional work and compensation from customers.
Consequently, Management’s estimates significantly
affect the revenue recognized from the above
contracts, profit margins, provisions for loss-making
projects, as well as the recoverability of contract assets.
We focused our attention on this matter due to the
significant assumptions and estimates made by
Management regarding: the determination of the profit
margin on projects in progress and the adjustment of
budgeted expenses on certain projects, due to delays in
the progress of work.
Revenue for the year ended 31 December 2024 from
EPC and construction contracts and the corresponding
contract assets and contract liabilities at that date
amounted to €1,240 million, €599.7 million and €146.9
million respectively.
the reporting date and compared a sample of
expenses with the corresponding documents.
- We evaluated Management's estimates
regarding the budgeted expenses to completion
of the projects by referring to supporting
documents, such as budgets, contracts, offers
and certifications and comparing previous
estimates with the actual historical results.
- We held discussions with the responsible project
engineers for projects with significant value
regarding the progress of work and focused on
cases of projects that experienced delays in the
progress of the works.
- We examined the recoverability of contract
assets by referring to subsequent work
certifications. We reviewed the supporting
documentation of requests for additional work,
claims for compensation and the relevant
contractual terms.
- We also reviewed the relevant opinions from
legal and other experts as well as
correspondence with customers and suppliers.
- We evaluated Management’s judgment
regarding the recoverability of contract assets
from additional project work and additional
compensation by discussing them with Group
management, project engineers and legal
advisors.
Based on the evidence we gathered, we concluded that
the methodologies and data used for the recognition of
revenue from EPC and construction contracts were
appropriate, that the key assumptions applied were
reasonable and that the relevant disclosures in the
consolidated financial statements are adequate.
Other matter
The separate and consolidated financial statements for the previous fiscal year ended 31 December 2023 were audited by
another auditing firm. For the said fiscal year, the Certified Public Accountant issued an unqualified audit report on 27/03/2024.
Other Information
The members of the Board of Directors are responsible for the other information. The other information, which is included in the
Annual Report, in accordance with Law 3556/2007, is the Statements of Board of Directors members and the Board of Directors’
Report, the Explanatory Report of the Board of Directors and the Corporate Governance Statement (but does not include the
financial statements and our auditor’s report thereon), which we obtained prior to the date of this auditor’s report.
Our opinion on the separate and consolidated financial statements does not cover the other information including the Board of
Directors’ Report.
In connection with our audit of the separate and consolidated financial statements, our responsibility is to read the other
information identified above and, in doing so, consider whether the other information is materially inconsistent with the separate
and consolidated financial statements or our knowledge obtained during the audit, or otherwise appears to be materially
misstated.
PricewaterhouseCoopers SA, GEMI: 001520401000, T: +30 210 6874400, www.pwc.gr
We considered whether the Board of Directors’ Report includes the disclosures required by Law 4548/2018 and the Corporate
Governance Statement provides the information referred to in items (a), (b), (e) and (f) of paragraph 1 of article 152 of Law
4548/2018.
Based on the work undertaken in the course of our audit, in our opinion:
● The information given in the Board of Directors’ Report for the year ended 31 December 2024 is consistent with the
separate and consolidated financial statements,
● The Board of Directors’ Report has been prepared in accordance with the applicable legal requirements of articles 150, and
153 of Law 4548/2018, excluding the sustainability reporting requirements for which we have issued a relevant limited
assurance report dated 13/03/2025 in accordance with International Standard on Assurance Engagements 3000 (Revised)
“Assurance Engagements Other than Audits or Reviews of Historical Financial Information”.
● The Corporate Governance Statement provides the information referred to in items (c) and (d) of paragraph 1 of article 152
of Law 4548/2018.
Additionally, in light of the knowledge and understanding of the Company and Group and their environment obtained in the
course of the audit, we are required to report if we have identified material misstatements
in the Board of Directors’ Report and
other information that we obtained prior to the date of this auditor’s report. We have nothing to report in this respect.
Responsibilities of Board of Directors and those charged with governance for the separate and consolidated financial
statements
The Board of Directors is responsible for the preparation and fair presentation of the separate and consolidated financial
statements in accordance with International Financial Reporting Standards, as adopted by the European Union and comply with
the requirements of Law 4548/2018, and for such internal control as the Board of Directors determines is necessary to enable
the preparation of separate and consolidated financial statements that are free from material misstatement, whether due to
fraud or error.
In preparing the separate and consolidated financial statements, the Board of Directors is responsible for assessing the
Company’s and Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and
using the going concern basis of accounting unless Board of Directors either intends to liquidate the Company and Group or to
cease operations, or has no realistic alternative but to do so.
The Audit Committee (article 44 of Law 4449/2017) of the Company is responsible for overseeing the financial reporting process
of the Company and the Group.
Auditor’s responsibilities for the audit of the separate and consolidated financial statements
Our objectives are to obtain reasonable assurance about whether the separate and consolidated financial statements as a whole
are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion.
Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs, that
have been transposed into Greek Law, will always detect a material misstatement when it exists. Misstatements can arise from
fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the
economic decisions of users taken on the basis of these separate and consolidated financial statements.
As part of an audit in accordance with ISAs that have been transposed into Greek Law, we exercise professional judgment and
maintain professional scepticism throughout the audit. We also:
● Identify and assess the risks of material misstatement of the separate and consolidated financial statements, whether
due to fraud or error, by designing and performing audit procedures responsive to those risks, and obtain audit evidence
that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement
resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional
omissions, misrepresentations, or the override of internal control.
PricewaterhouseCoopers SA, GEMI: 001520401000, T: +30 210 6874400, www.pwc.gr
● Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are
appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the
Company’s and Group’s internal control.
● Evaluate the appropriateness of accounting policies and methods used and the reasonableness of accounting estimates
and related disclosures made by the Board of Directors.
● Conclude on the appropriateness of Board of Directors’ use of the going concern basis of accounting and, based on the
audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant
doubt on the Company’s and Group’s ability to continue as a going concern. If we conclude that a material uncertainty
exists, we are required to draw attention in our auditor’s report to the related disclosures in the separate and
consolidated financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are
based on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may
cause the Company and Group to cease to continue as a going concern.
● Evaluate the overall presentation, structure and content of the separate and consolidated financial statements, including
the disclosures, and whether the separate and consolidated financial statements represent the underlying transactions
and events in a manner that achieves fair presentation.
● Plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the financial information of
the entities or business units within the Group as a basis for forming an opinion on the consolidated financial
statements. We are responsible for the direction, supervision and review of the audit work performed for the purposes
of the group audit. We remain solely responsible for our audit opinion.
We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the
audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant ethical requirements
regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to
bear on our independence, and where applicable, related safeguards.
From the matters communicated with those charged with governance, we determine those matters that were of most
significance in the audit of the separate and consolidated financial statements of the year under audit and are therefore the
key audit matters. We describe these matters in our auditor’s report.
Report on other legal and regulatory requirements
1. Additional Report to the Audit Committee
Our opinion on the accompanying separate and consolidated financial statements is consistent with our, as per article 11 of
Regulation (EU) 537/2014 required, Additional Report to the Audit Committee of the Company.
2. Appointment
We were first appointed as auditors of the Company by the decision of the annual general meeting of shareholders on
04/06/2024. Our appointment covers a period of one year.
3. Operating Regulation
The Company has an Operating Regulation in accordance with the content provided by the provisions of article 14 of Law
4706/2020.
4. Unbundled financial statements of energy segment
We have audited the unbundled statements of financial position of the Company and the Group as of 31 December 2024, as well
as the unbundled statements of income for the period from 1 January 2024 to 31 December 2024, as presented in Annex I to the
PricewaterhouseCoopers SA, GEMI: 001520401000, T: +30 210 6874400, www.pwc.gr
explanatory information to the financial statements of the Company and the Group. The unbundled statements of financial
position and income by activity (hereinafter the “unbundled financial statements”) were prepared under the responsibility of the
Management of Metlen Energy & Metals S.A. in accordance with Directive 944/2019 (EU), the provisions of Law 4001/2011 and
Law No. 162/2019 decision of the Regulatory Authority regarding the approval of the rules for the allocation of Assets and
Liabilities and Expenses and Revenues, the accounting separation methodology of which is described in detail in Annex I of the
explanatory information to the financial statements.
The audit of the unbundled financial statements comprises solely to verifying the correct application of the allocation rules for
the unbundling of the accounts.
5. Assurance Report on the European Single Electronic Format
Subject Matter
We undertook the reasonable assurance engagement to examine the digital files of the Company Metlen Energy & Metals SA
(hereinafter referred to as the “Company and / or Group”), which were compiled in accordance with the European Single
Electronic Format (ESEF), and which include the Company and the Group’s separate and consolidated financial statements for
the year ended 31 December 2024, in XHTML 213800KT8MEUJEJ2KW41-2024-12-31-en.xhtml format, as well as the intended
XBRL 213800KT8MEUJEJ2KW41-2024-12-31-en.zip file with the appropriate markup, on the aforementioned consolidated
financial statements , including other explanatory information (Notes to the financial statements), (hereinafter referred to as the
“Subject Matter”), in order to determine that it was prepared in accordance with the requirements set out in the Applicable
Criteria section.
Applicable Criteria
The Applicable criteria for the European Single Electronic Format (ESEF) are defined by the European Commission Delegated
Regulation (EU) 2019/815, as amended by Regulation (EU) 2020/1989 (hereinafter “ESEF Regulation”) and the 2020 / C 379/01
Interpretative Communication of the European Commission of 10 November 2020, as provided by Law 3556/2007 and the
relevant announcements of the Hellenic Capital Market Commission and the Athens Stock Exchange.
In summary, these criteria provide, inter alia, that:
· All annual financial reports should be prepared in XHTML format.
· For consolidated financial statements in accordance with International Financial Reporting Standards, the financial
information stated in the Statement of Comprehensive Income, the Statement of Financial Position, the Statement of
Changes in Equity and the Statement of Cash Flows, as well as the financial information included in the other
explanatory information, should be marked-up with XBRL 'tags' and ‘block tag’, according to the ESEF Taxonomy, as in
force. The technical specifications for ESEF, including the relevant classification, are set out in the ESEF Regulatory
Technical Standards.
Responsibilities of management and those charged with governance
Management is responsible for the preparation and submission of the separate and consolidated financial statements of the
Company and the Group, for the year ended 31 December 2024, in accordance with the requirements set by the ESEF Regulatory
Framework, as well as for those internal controls that management determines as necessary, to enable the compilation of digital
files free of material error due to either fraud or error.
Auditor’s responsibilities
Our responsibility is to issue this Report regarding the evaluation of the Subject Matter, based on our work performed, which is
described below in the “Scope of Work Performed” section.
Our work was carried out in accordance with International Standard on Assurance Engagements 3000 (Revised) “Assurance
Engagements Other than Audits or Reviews of Historical Financial Information” (hereinafter “ISAE 3000).
ISAE 3000 requires that we plan and perform our work to obtain reasonable assurance about the evaluation of the Subject Matter
in accordance with the Applicable Criteria. In the context of the procedures performed, we assess the risk of material
PricewaterhouseCoopers SA, GEMI: 001520401000, T: +30 210 6874400, www.pwc.gr
misstatement of the information related to the Subject Matter.
We believe that the evidence we have obtained is sufficient and appropriate and supports the conclusion expressed in this
assurance report.
Code of Conduct and quality management
We are independent of the Company and the Group, throughout the duration of this engagement and have complied with the
requirements of the International Code of Ethics for Professional Accountants issued by the International Ethics Standards Boards
of Accountants (IESBA Code) that has been transposed into Greek Law, and the ethical requirements of Law 4449/2017 and of
Regulation (EU) 537/2014.
Our audit firm applies International Standard on Quality Management (ISQM) 1 “Quality Management for Firms that Perform
Audits or Reviews of Financial Statements or Other Assurance or Relates Services Engagements” and consequently maintains a
comprehensive quality management system that includes documented policies and procedures regarding compliance with
ethical requirements, professional standards and applicable legal and regulatory requirements.
Scope of work performed
The assurance work we performed covers the subjects included in the No. 214/4/11-02-2022 Decision of the Hellenic Accounting
and Auditing Standards Oversight Board (HAASOB) and in the “Guidelines in relation to the work and assurance report of Certified
Public Accountants on the European Single Electronic Format (ESEF) of issuers with securities listed on a regulated market in
Greece”, as issued by the Institute of Certified Public Accountants of Greece on 14/02/2022, so as to obtain reasonable assurance
that the financial statements of the Company prepared by the management comply, in all material respects, with the Applicable
Criteria.
Inherent limitations
Our work covered the items listed in the “Scope of Work performed” section to obtain reasonable assurance based on the
procedures described. In this context, the work we performed could not absolutely ensure that all matters that could be
considered material weaknesses would be revealed.
Conclusion
Based on the procedures performed and the evidence obtained, we conclude that the separate and consolidated financial
statements of the Company and the Group for the year ended December 31, 2024, in XHTML file format
213800KT8MEUJEJ2KW41-2024-12-31-en.xhtml, as well as the provided XBRL file 213800KT8MEUJEJ2KW41-2024-12-31-en.zip
with the appropriate marking up, on the aforementioned consolidated financial statements, including the other explanatory
information, have been prepared, in all material respects, in accordance with the requirements of the Applicable Criteria.
Athens, 13 March 2025
The Certified Chartered Accountant
PricewaterhouseCoopers SA
65 Kifissias Avenue
151 24 Marousi
SOEL Reg. No 113
Socrates Leptos-Bourgi
SOEL Reg No 41541
10. Annual Financial Statements
438
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
439
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN ENERGY & METALS GROUP
METLEN ENERGY & METALS S.A.
(Amounts in thousands €)
01.01-31.12.2024
01.01-31.12.2023
01.01-31.12.2024
01.01-31.12.2023
Sales
3.1
3,801,741
4,262,309
Cost of sales
3.22
(4,663,795 )
(4,510,625 )
(3,268,647)
(3,547,500)
Gross profit
533,094
714,809
Other operating income
3.24
101,669
102,104
Administrative expenses
3.23
(154,611 )
(130,685 )
(145,048)
(118,811)
Research & Development expenses
(63 )
-
-
Other operating expenses
3.24
(100,119 )
(83,007 )
(75,785)
(62,907)
Οperating profit
413,930
635,195
Financial income
3.25
83,848
42,574
Financial expenses
3.25
(185,300 )
(111,621 )
(126,630)
(76,559)
Other financial results
3.26
(5,555 )
(5,549 )
23,927
(3,875)
Share of profits/(losses) of associates
3.7
(7,652 )
-
(6,120)
Profit before income tax
395,075
591,215
Income tax expense
3.27
(117,573 )
(160,408 )
(70,180)
(131,293)
Profit after income tax
324,895
459,922
Equity holders of the parent
3.28
324,895
459,922
Non-controlling Interests
-
-
Basic earnings per share (in Euro)
3.28
2.3554
3.3254
Diluted earnings per share (in Euro)
3.28
2.3261
3.2776
The notes on pages 449 to 549 are an integral part of these financial statements.
Income Statement
10. Annual Financial Statements
440
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN ENERGY & METALS GROUP
METLEN ENERGY & METALS S.A.
(Amounts in thousands €)
01.01-
31.12.2024
01.01-
31.12.2023
01.01-
31.12.2024
01.01-
31.12.2023
Other Comprehensive Income:
Profit after income tax
324,895
459,922
Items that will not be reclassified to profit or loss:
Actuarial gain / (losses)
(182)
365
Deferred tax from actuarial gain / (losses)
3.9
(3 )
(83 )
(7)
(74)
Revaluation of property, plant and equipment
-
-
Items that may be reclassified subsequently to profit or loss:
Exchange differences on translation of foreign operations
-
-
Other comprehensive income / expenses from associates (net of tax)
3.7
(6,785 )
-
-
Gains / (losses) on cash flow hedges
(16,013 )
(21,765 )
(25,580)
(11,764)
Deferred tax on gain/losses from cash flow hedges
5,886
2,600
Other comprehensive (loss) /income for the period
(22,932 )
(19,883)
(8,873)
Total comprehensive income for the period
305,012
451,049
Attributable to:
Equity holders of the parent
305,012
451,049
Non-controlling Interests
-
-
The notes on pages 449 to 549 are an integral part of these financial statements.
Statement of Comprehensive Income
10. Annual Financial Statements
441
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN ENERGY & METALS GROUP
METLEN ENERGY & METALS S.A.
(Amounts in thousands €)
31.12.2024
31.12.2023*
31.12.2024
31.12.2023*
Assets
Non-current assets
Property, plant and equipment
3.3
1,216,881
1,187,468
Goodwill
3.4
-
-
Intangible assets
3.5
232,854
264,676
Investments in subsidiary companies
3.6
607,781
548,066
Investments in associates
3.7
7,013
7,013
Other investments
-
-
Deferred Tax Assets
3.9
-
-
Other financial assets
3.12.1
180,619
37
Derivatives
3.12.3
10,699
-
Construction contract assets
3.13
-
-
Other long-term receivables
3.12.4
52,748
50,426
Right-of-use assets
3.2
135,290
144,996
Total non-current assets
2,443,885
2,202,682
Current assets
Inventories
3.10
297,202
222,669
Construction contract assets
3.13
257,808
175,069
Trade and other receivables
3.11
3,464,759
2,573,949
Financial assets at fair value through profit or loss
3.12.2
23,237
20,887
Derivatives
3.12.3
28,183
49,339
Restricted cash
3.15
-
-
Cash and cash equivalents
3.15
488,182
460,893
Total current assets
4,559,371
3,502,806
Total assets
7,003,256
5,705,488
Liabilities & Equity
Equity
Share capital
3.18.1
138,604
138,604
Share premium
124,701
124,701
Convertible loan equity reserve
3.18.1
1,945
1,945
Treasury shares
(110,565 )
(81,299 )
(110,565)
(81,299)
Reserves
3.18.2
(150,273)
(137,974)
Retained earnings
1,722,919
1,611,583
Equity attributable to equity holders of the parent
1,727,331
1,657,560
Non controlling Interests
-
-
Total equity
1,727,331
1,657,560
Non-Current Liabilities
Long-term debt
3.12.5
2,486,788
1,410,018
Lease liabilities
3.2
141,715
144,389
Derivatives
3.12.3
2,614
79
Deferred Tax Liabilities
3.9
142,396
119,154
Liabilities for pension plans
3.19
6,372
5,783
Other long-term payables
3.12.7
46,153
44,657
Provisions
3.20
7,783
15,047
Total non-current liabilities
2,833,821
1,739,127
Current Liabilities
Trade and other payables
3.16
1,696,966
1,540,204
Contract liabilities
3.13
118,169
174,339
Tax payable
3.21
190,456
197,190
Short-term debt
3.12.5
317,345
308,912
Current portion of long-term debt
3.12.5
86,551
47,739
Lease liabilities
3.2
6,340
6,003
Derivatives
3.12.3
26,277
34,414
Current portion of non-current provisions
3.20
-
-
Total current liabilities
2,442,104
2,308,801
Total liabilities
5,275,925
4,047,928
Liabilities & Equity
7,003,256
5,705,488
The notes on pages 449 to 549 are an integral part of these financial statements.
*Certain items of Statement of Financial Position for the comparative period ended 2023 have been reclassified to be consistent with the current year
presentation. See 2. basis for preparation of Financial Statements and summary of material accounting policies.
Statement of Financial Position
10. Annual Financial Statements
442
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN ENERGY & METALS GROUP
(Amounts in thousands €)
Share
capital
Share
premium
Right
to
acquire
shares
Treasury
Stock
Reserve
Reserves
Retained
earnings
Total
Non
controlling
Interests
Total
Opening Balance 1st January 2023
(92,833 )
Transactions With Owners
Dividends Paid
(171,469 )
(171,469 )
(2,196 )
(173,665 )
Equity-settled share-based payment
Convertible Bond Loan
Treasury Stock Sales/Purchases
Increase / (Decrease) Of Share Capital
(182 )
(182 )
(182 )
Transactions With Owners
(143,447 )
(122,726 )
(2,196 )
(124,922 )
Net Profit/(Loss) For The Period
Other Comprehensive Income:
Other Comprehensive Income
(22,961 )
(22,932 )
(22,932 )
Total Comprehensive Income For The Period
(22,961 )
Transfer To Reserves
(37 )
Impact From Acquisition/absorption Of Share In Subsidiaries
(59 )
(59 )
(242 )
(301 )
Closing Balance 31.12.2023
(81,299 )
Opening Balance 1st January 2024
(81,299 )
Transactions With Owners
Dividends Paid
(214,337 )
(214,337 )
(3,514 )
(217,851 )
Equity-settled share-based payment
(1,528 )
Treasury Stock Sales/Purchases
(29,266 )
(26,959 )
(26,959 )
Transactions With Owners
(29,266 )
(213,558 )
(235,241 )
(3,514 )
(238,755 )
Net Profit/(Loss) For The Period
Other Comprehensive Income:
Other Comprehensive Income
Total Comprehensive Income For The Period
Transfer To Reserves
(728 )
Impact From Acquisition/absorption Of Share In Subsidiaries
(1,728 )
(600 )
Closing Balance 31.12.2024
(110,565 )
The notes on pages 449 to 549 are an integral part of these financial statements.
Certain items of Statement of Equity for the comparative period ended 2023 have been reclassified to be consistent with the current year presentation.
See 2. basis for preparation of Financial Statements and summary of material accounting policies.
Group’s Statement of Changes in Equity
10. Annual Financial Statements
443
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN ENERGY & METALS S.A.
(Amounts in thousands €)
Share
capital
Share
premium
Right to
acquire
shares
Treasury
Stock
Reserve
Reserves
Retained
earnings
Total
Opening Balance 1st January 2023
138,604
124,701
-
(92,833)
(76,166)
1,294,961
1,389,267
Change In Equity
Dividends Paid
-
-
-
-
-
(171,469)
(171,469)
Equity-settled share-based payment
-
-
-
-
7,242
-
7,242
Convertible Bond Loan
-
-
1,945
-
-
-
1,945
Treasury Stock Sales/Purchases
-
-
-
11,534
-
28,204
39,738
Impact From Merge Through Acquisition Of Subsidiary
-
-
-
-
(60,137)
-
(60,137)
Transactions With Owners
-
-
1,945
11,534
(52,896)
(143,265)
(182,682)
Net Profit/(Loss) For The Period
-
-
-
-
-
459,924
459,924
Other Comprehensive Income:
Other Comprehensive Income
-
-
-
-
(8,885)
12
(8,873)
Total Comprehensive Income For The Period
-
-
-
-
(8,885)
459,936
451,051
Transfer To Reserves
-
-
-
-
(28)
(49)
(77)
Closing Balance 31.12.2023
138,604
124,701
1,945
(81,299)
(137,974)
1,611,583
1,657,560
Opening Balance 1st January 2024
138,604
124,701
1,945
(81,299)
(137,974)
1,611,583
1,657,560
Change In Equity
Dividends Paid
-
-
-
-
-
(214,337)
(214,337)
Equity-settled share-based payment
-
-
-
-
7,583
(1,528)
6,056
Treasury Stock Sales/Purchases
-
-
-
(29,266)
-
2,304
(26,962)
Transactions With Owners
-
-
-
(29,266)
7,583
(213,561)
(235,243)
Net Profit/(Loss) For The Period
-
-
-
-
-
324,895
324,895
Other Comprehensive Income:
Other Comprehensive Income
-
-
-
-
(19,883)
-
(19,883)
Total Comprehensive Income For The Period
-
-
-
-
(19,883)
324,895
305,012
Closing Balance 31.12.2024
138,604
124,701
1,945
(110,565)
(150,273)
1,722,917
1,727,329
The notes on pages 449 to 549 are an integral part of these financial statements.
Entity’s Statement of Changes in Equity
10. Annual Financial Statements
444
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
METLEN
ENERGY & METALS GROUP
METLEN
ENERGY & METALS S.A.
(Amounts in thousands €)
01.01-
31.12.2024
01.01-
31.12.2023
01.01-
31.12.2024
01.01-
31.12.2023
Cash flows from operating activities
-
Cash flows from operating activities
3.29
(566,766)
(124,923)
Interest paid
(134,840 )
(78,462 )
(69,875)
(29,495)
Taxes paid
(122,579 )
(139,170 )
(55,794)
(92,956)
Net Cash generated from/(used in) operating activities
(692,435)
(247,374)
Cash flow from investing activities
Purchases/Additions of Property, plant and equipment
(643,688 )
(875,725 )
(92,374)
(158,215)
Purchases of intangible assets
(157,569 )
(178,602 )
(93,834)
(135,524)
Sale of Property, plant and equipment
3,755
545
Dividends received
9,527
1,690
Purchase of financial assets at fair value through profit and loss
(1,683 )
(19,169 )
(1,687)
(19,169)
Derivatives settlement
-
-
Acquisition /Sale of associates
-
3,880
Net (Payment)/Proceeds for acquisition of subsidiaries, net of cash acquired
(16,423 )
(28,716)
(79,548)
Interest received
41,388
14,078
Grants received/(returns)
-
2,002
Payments for share capital increase in subsidiaries
(8,300)
-
Net cash (used in)/generated from investing activities
(794,931 )
(1,045,677 )
(170,241)
(370,261)
Cash flows from financing activities
Tax payments
(180 )
-
-
Dividends paid to shareholders
(209,877 )
(167,412 )
(206,163)
(165,203)
Proceeds from borrowings
3.12.6
1,355,000
1,388,994
Repayments of borrowings
3.12.6
(1,044,215 )
(1,102,540 )
(284,597)
(842,490)
Payment of finance lease liabilities
3.2
(10,821 )
(10,875 )
(5,293)
(7,442)
Return of share capital from subsidiary
-
47,283
Net (Purchases)/Sales of treasury shares
(31,634 )
(31,634)
6,442
Net Cash flow (for)/from financing activities
827,313
427,584
Net (decrease)/increase in cash and cash equivalents
(182,666 )
(35,363)
(190,051)
Cash and cash equivalent minus bank overdrafts at beginning of period
424,579
648,316
Cash and cash equivalents at beginning of period (spined-off companies)
-
(52,489)
Cash and cash equivalents at beginning of period (merged companies)
-
18,803
Exchange differences in cash and cash equivalents
-
-
Net cash at the end of the period
488,182
460,893
Bank Overdrafts
3.12.5
(105,545 )
(42,346 )
(98,966)
(36,314)
Cash and cash equivalent and bank overdrafts
389,216
424,579
Net cash and bank overdrafts at the end of the period
389,216
424,579
The notes on pages 449 to 549 are an integral part of these financial statements.
Cash Flow Statement
10. Annual Financial Statements
445
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Notes on the Financial Statements
1.1 General Information........................................................................................................................................449
1.2 Nature of activities................................................................................................................................................449
1.3 Group Structure ....................................................................................................................................................449
2.1 Adoption of new and revised standards ...............................................................................................................458
2.1.1 New Standards, Interpretations, Revisions and Amendments to existing Standards that are effective and have
been adopted by the European Union........................................................................................................................458
2.1.2 New Standards, Interpretations, Revisions and Amendments to existing Standards that have not been applied
yet or have not been adopted by the European Union ..............................................................................................459
2.2 Basis of Consolidation ...........................................................................................................................................461
2.3 Summary of accounting policies ...........................................................................................................................461
2.3.1 Business combinations and Goodwill.................................................................................................................461
2.3.2 Investment in associates, joint arrangements and joint ventures .....................................................................462
2.3.3 Foreign currency translation ..............................................................................................................................463
2.3.4 Property, plant and equipment..........................................................................................................................463
2.3.5 Intangible assets.................................................................................................................................................464
2.3.6 Financial instruments.........................................................................................................................................465
2.3.7 Fair value measurement ....................................................................................................................................467
2.3.8 Guarantees.........................................................................................................................................................467
2.3.9 Inventories .........................................................................................................................................................468
2.3.10 Cash and cash equivalents ...............................................................................................................................468
2.3.11 Restricted cash.................................................................................................................................................468
2.3.12 Treasury shares ................................................................................................................................................468
2.3.13 Income tax & deferred tax ...............................................................................................................................468
2.3.14 Pensions and other post-employment benefits...............................................................................................469
2.3.15 Grants...............................................................................................................................................................469
2.3.16 Provisions .........................................................................................................................................................470
2.3.17 Leases...............................................................................................................................................................470
2.3.18 Revenue recognition ........................................................................................................................................471
10. Annual Financial Statements
446
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2.3.19 Dividend distribution........................................................................................................................................473
2.3.20 Alternative performance measures .................................................................................................................473
2.3.21 Accounting policy for CO
2
emission rights allowances.....................................................................................473
2.3.22 Hedge accounting ............................................................................................................................................474
2.3.23 Earnings per share (EPS)...................................................................................................................................475
2.3.24 Share-based payments.....................................................................................................................................475
2.4 Climate-related matters........................................................................................................................................475
2.5 Significant accounting judgments, estimates and assumptions............................................................................476
2.5.1 Judgements ........................................................................................................................................................476
2.5.2 Estimates and assumptions................................................................................................................................477
2.6 Segment reporting ................................................................................................................................................478
3.1 Segment reporting ................................................................................................................................................479
3.2 Leases....................................................................................................................................................................481
3.3 Property, plant and equipment.............................................................................................................................484
3.4 Goodwill ................................................................................................................................................................486
3.4.1 Changes in goodwill ...........................................................................................................................................486
3.4.2 Impairment test on goodwill..............................................................................................................................486
3.5 Intangible assets....................................................................................................................................................487
3.6 Investments in subsidiaries...................................................................................................................................491
3.6.1 Non-controlling interests ...................................................................................................................................491
3.7 Investments in associates .....................................................................................................................................493
3.8 Interest in joint operations ...................................................................................................................................493
3.9 Deferred tax ..........................................................................................................................................................493
3.10 Inventories ..........................................................................................................................................................497
3.11 Trade and other receivables ...............................................................................................................................498
3.12 Financial assets and liabilities .............................................................................................................................499
3.12.1 Other financial assets.......................................................................................................................................500
3.12.2 Financial assets at fair value through profit or loss .........................................................................................501
3.12.3 Derivatives financial instruments.....................................................................................................................501
3.12.4 Other long-term receivables ............................................................................................................................505
3.12.5 Loan liabilities ..................................................................................................................................................505
10. Annual Financial Statements
447
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
3.12.6 Loan liabilities movement ................................................................................................................................508
3.12.7 Other long-term liabilities................................................................................................................................509
3.13 Contract balances................................................................................................................................................509
3.14 Business combination .........................................................................................................................................510
3.15 Cash and cash equivalents ..................................................................................................................................514
3.16 Trade and other payables ...................................................................................................................................515
3.17 Alternative performance measures ....................................................................................................................515
3.18 Total Equity .........................................................................................................................................................517
3.18.1 Share capital.....................................................................................................................................................517
3.18.2 Reserves ...........................................................................................................................................................518
3.19 Liabilities for pension plans.................................................................................................................................519
3.20 Provisions ............................................................................................................................................................520
3.21 Current tax liabilities ...........................................................................................................................................522
3.22 Cost of sales ........................................................................................................................................................522
3.23 Administrative expenses .....................................................................................................................................522
3.24 Other operating income and other operating expenses.....................................................................................523
3.25 Finance income and expenses ............................................................................................................................523
3.26 Other financial results.........................................................................................................................................524
3.27 Income tax...........................................................................................................................................................524
3.28 Earnings per share and dividends .......................................................................................................................525
3.29 Cash flows from operating activities...................................................................................................................526
3.30 Share based payment..........................................................................................................................................526
3.31 Commitments......................................................................................................................................................528
3.32 Financial and capital risk management strategy.................................................................................................528
3.33 Fair value measurements....................................................................................................................................533
3.34 Capital management...........................................................................................................................................534
3.35 Dividend proposed and payable .........................................................................................................................535
3.36 Number of employees.........................................................................................................................................535
3.37 Related party transactions ..................................................................................................................................535
3.38 Contingent Assets & Contingent Liabilities .........................................................................................................538
3.38.1 Unaudited tax years .........................................................................................................................................538
10. Annual Financial Statements
448
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
3.38.2 Other Contingent Assets & Liabilities..............................................548
3.38.3 Guarantees.......................................................................................................................................................549
3.39 Reclassifications ..................................................................................................................................................549
3.40 Post Balance sheet events...................................................................................................................................549
10. Annual Financial Statements
449
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
450
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
451
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
452
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
453
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
454
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
455
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
456
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
457
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
458
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
459
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
460
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
461
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
462
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
463
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
464
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
465
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
466
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
467
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
468
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
469
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
470
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
471
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
472
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
473
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
474
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
475
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
476
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
477
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
478
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
479
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
480
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
481
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
482
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
483
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
484
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
485
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
486
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
487
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
488
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
489
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
490
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
491
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
492
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
493
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
494
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
495
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
496
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
497
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
498
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
499
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
500
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
501
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
502
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
503
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
504
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
505
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
506
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
507
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
508
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
509
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
510
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
511
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
512
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
513
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
514
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
515
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
516
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
517
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
518
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
519
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
520
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
521
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
522
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
523
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
524
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
525
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
526
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
527
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
528
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
529
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
530
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
531
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
532
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
533
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
534
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
535
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
536
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
537
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
538
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
539
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
540
10. Annual Financial Statements
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
541
10. Annual Financial Statements
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
542
10. Annual Financial Statements
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
543
10. Annual Financial Statements
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
544
10. Annual Financial Statements
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
545
10. Annual Financial Statements
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
546
10. Annual Financial Statements
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
547
10. Annual Financial Statements
548
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
10. Annual Financial Statements
549
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
11. Availability of Financial Statements
550
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
12. Appendix I - Unbundled Financial Statements
of Energy Segment METLEN Energy & Metals S.A. Group of Companies
551
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
UNBUNDLED STATEMENT OF PROFIT AND LOSS OF THE FULLY INTEGRATED COMPANY
01.01-31.12.2024
(Amounts in thousands €)
Energy
Production
Energy
Supply
Natural Gas
Supply
RES
Other
Other
Operations
METLEN
ENERGY &
METALS
GROUP
Sales To Third Parties
Sales of electricity in Energy Exchange Group & DAPEEP
962.696
15.630
0
55.694
0
0
1.034.020
Sales in ADMHE
0
0
0
35
0
0
35
Sales of electricity to retail consumers
0
1.151.712
0
0
0
0
1.151.712
Exports of electricity
0
132.141
0
3.926
0
0
136.068
Other income
222
7.764
145
4.183
119.362
0
131.676
Sales of Natural Gas
0
0
1.052.686
0
0
0
1.052.686
Other Income of Natural Gas
0
0
85
0
0
0
85
Intercompany Sales
Supply of Electricity
0
30.944
0
0
0
0
30.944
Other Services
15
0
6.115
6
1.832
0
7.969
Intercompany Sales of Natural Gas
0
0
116.640
0
0
0
116.640
Income Of Other Group Operations
Income from other group operations
0
0
0
0
0
2.173.955
2.173.955
Total Income
962.933
1.338.192
1.175.672
63.843
121.195
2.173.955
5.835.791
Expenses & Purchases
Imports of electricity
0
(87.087)
0
0
0
0
(87.087)
Purchase of electricity from Energy Exchange Group & DAPEEP (ex
LAGHE)
(332)
(662.964)
0
(162)
0
0
(663.458)
Purchase of electricity by 3rd parties
0
(52.324)
0
(519)
0
0
(52.843)
Services from ADMHE
(86)
(38.864)
0
0
0
0
(38.950)
Services from DEDDIE
0
(307.286)
0
0
0
0
(307.286)
Supply costs of Natural Gas
0
0
(957.625)
0
0
0
(957.624)
Other Costs of Natural Gas
0
0
(13.263)
0
0
0
(13.263)
Transmission costs of Natural Gas
0
0
(123.828)
0
0
0
(123.828)
Payroll
(22.371)
(15.145)
(1.507)
(1.390)
(44.770)
0
(85.183)
Third party fees
(30.369)
(17.476)
(2.174)
(2.632)
(51.634)
0
(104.285)
CO
2
Rights
(116.289)
0
0
0
0
0
(116.289)
Natural Gas consumption
(403.096)
0
0
0
0
0
(403.096)
Third Party Maintenance & Benefits
(5.634)
0
(5)
(7.964)
(148)
0
(13.751)
Other third party benefits
(20.005)
(4.450)
(41)
(755)
(96)
0
(25.346)
Taxes - Duties
(4.580)
(180)
(44)
(1.842)
(307)
0
(6.953)
Other Expenses
(6.483)
(3.289)
(605)
(860)
(6.847)
0
(18.086)
Depreciation
(50.580)
(12.053)
(709)
(18.299)
(1.216)
0
(82.857)
Provisions
0
(12.647)
(1.483)
(2)
(436)
0
(14.568)
Financial Results
267
6.146
(2.347)
(3.114)
16.941
0
17.893
Losses / (Gains) on exchange differences
37
(12)
0
(1)
(43)
0
(19)
Extraordinary (Income) / Expenses
6.061
(26.299)
(3.204)
(545)
(212)
0
(24.200)
Intercompany Expenses & Purchases
Supply of Electricity
0
(29.851)
0
(1.092)
0
0
(30.944)
Other Services
(6.080)
(12)
0
(1.507)
(370)
0
(7.969)
Natural Gas consumption
(111.944)
0
(4.696)
0
0
0
(116.640)
Financial Results
0
0
0
(1.256)
1.256
0
0
Expenses Of Other Group Operations
0
0
0
0
0
(1.810.776)
(1.810.776)
Total Expenses
(771.484)
(1.263.793)
(1.111.531)
(41.940)
(87.882)
(1.810.776)
(5.087.408)
Profits/ (Loss) Before Taxes
191.448
74.401
64.139
21.902
33.313
363.179
748.383
12. Appendix I - Unbundled Financial Statements of Energy Segment METLEN Energy & Metals S.A. - Group of Companies
12. Appendix I - Unbundled Financial Statements
of Energy Segment METLEN Energy & Metals S.A. Group of Companies
552
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
UNBUNDLED STATEMENT OF PROFIT AND LOSS OF THE FULLY INTEGRATED COMPANY
01.01-31.12.2023
(Amounts in thousands €)
Energy
Production
Energy
Supply
Natural
Gas Supply
RES
Other
Other
Operations
METLEN
ENERGY &
METALS
GROUP
Sales To Third Parties
Sales of electricity in Energy Exchange Group & DAPEEP
706.517
18.626
0
53.308
0
0
778.452
Sales in ADMHE
1
0
0
89
0
0
90
Sales of electricity to retail consumers
0
1.154.212
98
0
0
0
1.154.310
Exports of electricity
0
19.794
0
0
0
0
19.794
Other income
3.311
3.436
3.052
1.947
75.542
0
87.288
Sales of Natural Gas
0
0
1.647.123
0
0
0
1.647.123
Other Income of Natural Gas
0
0
1.477
0
0
0
1.477
Intercompany Sales
Supply of Electricity
0
7.808
0
0
0
0
7.808
Other Services
15
0
0
12
2.277
0
2.304
Intercompany Sales of Natural Gas
0
0
187.214
0
0
0
187.214
Income Of Other Group Operations
Income from other group operations
0
0
0
0
0
1.738.733
1.738.733
Total Income
709.845
1.203.876
1.838.964
55.357
77.818
1.738.733
5.624.593
Expenses & Purchases
Imports of electricity
0
(13.906)
0
0
0
0
(13.906)
Purchase of electricity from Energy Exchange Group & DAPEEP
(168)
(782.430)
0
(85)
0
0
(782.682)
Purchase of electricity by 3rd parties
0
(28.585)
0
(37)
0
0
(28.622)
Services from ADMHE
(17)
(32.257)
0
0
0
0
(32.274)
Services from DEDDIE
0
(202.981)
0
0
0
0
(202.981)
Supply costs of Natural Gas
0
0
(1.374.962)
0
291
0
(1.374.671)
Other Costs of Natural Gas
0
0
(17.543)
0
0
0
(17.543)
Transmission costs of Natural Gas
0
0
(82.222)
0
0
0
(82.222)
Payroll
(10.381)
(22.762)
(21.218)
(963)
(21.124)
0
(76.447)
Third party fees
13.897
(27.266)
(16.386)
(2.417)
(11.179)
0
(43.351)
CO
2
Rights
(118.642)
0
0
0
0
0
(118.642)
Natural Gas consumption
(280.644)
0
0
0
0
0
(280.644)
Third Party Maintenance & Benefits
(5.509)
(1.132)
(2.541)
(6.697)
0
0
(15.879)
Other third party benefits
(11.970)
(4.720)
(2.013)
(1.316)
(26.326)
0
(46.344)
Taxes - Duties
(7.543)
(320)
(82)
(1.631)
(127)
0
(9.703)
Other Expenses
(5.316)
(9.300)
(11.302)
(1.285)
(2.743)
0
(29.947)
Depreciation
(35.832)
(11.807)
(3.851)
(11.470)
(411)
0
(63.370)
Provisions
0
(16.019)
(199)
(2)
(97)
0
(16.318)
Financial Results
265
1.880
(2.057)
(5.202)
2.069
0
(3.045)
Losses / (Gains) on exchange differences
2.003
0
0
0
0
0
2.002
Extraordinary (Income) / Expenses
(770)
(1.844)
(517)
(1.554)
(20)
0
(4.705)
Intercompany Expenses & Purchases
Supply of Electricity
(3.470)
(3.686)
0
(651)
0
0
(7.807)
Other Services
(708)
(4)
0
(1.399)
(195)
0
(2.306)
Natural Gas consumption
(97.234)
0
(89.980)
0
0
0
(187.214)
Financial Results
0
0
0
(517)
517
0
0
Expenses Of Other Group Operations
0
0
0
0
0
(1.399.913)
(1.399.913)
Total Expenses
(562.039)
(1.157.139)
(1.624.873)
(35.226)
(59.345)
(1.399.913)
(4.838.534)
Profits/ (Loss) Before Taxes
147.806
46.737
214.091
20.131
18.473
338.820
786.060
12. Appendix I - Unbundled Financial Statements
of Energy Segment METLEN Energy & Metals S.A. Group of Companies
553
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
UNBUNDLED BALANCE SHEET OF THE FULLY INTEGRATED COMPANY
31.12.2024
(Amounts in thousands €)
Energy
Production
Energy
Supply
Natural Gas
Supply
RES
Other
Other
Operations
METLEN
ENERGY &
METALS
GROUP
Assets
Non current assets
Property, plant and equipment
844.517
7.826
68
423.626
2.203
1.239.074
2.517.314
Goodwill
0
0
0
0
0
279.495
279.495
Intangible Assets
299.841
29.368
2.073
23.668
145
145.310
500.405
Investments in subsidiary companies
0
74.005
7.651
33.789
301.431
(416.876)
0
Investments in associates
0
0
0
0
0
6.323
6.324
Other investments
0
0
0
0
0
22
22
Deferred Tax Assets
16.829
8.931
114
23.048
179
51.789
100.891
Other financial assets
0
0
0
0
0
187.891
187.891
Derivatives
0
0
0
0
0
53.919
53.919
Construction contract assets
0
0
0
0
0
514.207
514.207
Other Long-term receivables
13.976
12.332
26.409
154
257
18.238
71.367
Right-of-use-assets
2.721
688
154
51.253
1.300
143.173
199.288
Total non-current assets
1.177.883
133.152
36.468
555.540
305.515
2.222.566
4.431.123
Current assets
Inventories
50.021
0
11.550
195
127
1.528.213
1.590.106
Construction contract assets
0
0
0
0
0
866.551
866.551
Trade and other receivables
168.434
339.608
150.751
272.405
15.652
1.380.701
2.327.550
Financial assets at fair value through profit or loss
0
0
0
0
0
23.443
23.443
Derivatives
0
0
8.531
0
0
25.557
34.089
Restricted cash
0
0
0
4.671
0
8.815
13.486
Cash and cash equivalents
188.471
65.061
139.493
110.919
17.925
859.903
1.381.772
Total current assets
406.926
404.671
310.325
388.190
33.704
4.693.184
6.236.997
Total assets
1.584.809
537.821
346.794
943.730
339.218
6.915.750
10.668.120
Equity & Liabilities
Equity
Components of Equity
1.161.576
(21.053)
442.779
235.908
329.779
841.760
2.990.746
Equity attributable to equity holders of the parent
1.161.576
(21.053)
442.779
235.908
329.779
841.760
2.990.746
Non controlling Interests
0
0
0
0
0
102.134
102.134
Total Equity
1.161.576
(21.053)
442.779
235.908
329.779
943.894
3.092.880
Capital allocation between Segments
(102.566)
202.341
(577.077)
151.343
88.683
237.276
0
Non-Current Liabilities
Long-term debt
0
0
0
227.070
0
3.144.262
3.371.331
Lease liabilities
3.108
437
76
51.824
694
147.538
203.677
Derivatives
0
0
0
693
0
4.872
5.565
Deferred Tax Liabilities
69.302
(0)
59
34.052
9.865
147.808
261.086
Liabilities for pension plans
440
109
4
9
572
8.397
9.532
Other long-term payables
18.587
29.197
625
35.477
0
29.391
113.276
Provisions
0
0
0
26.115
63
69.839
96.018
Total non-current liabilities
91.437
29.745
763
375.239
11.195
3.552.106
4.060.485
Current Liabilities
Trade and other payables
174.924
231.013
395.059
184.870
31.849
1.336.175
2.353.891
Contract liabilities
0
0
0
0
0
146.828
146.828
Tax payable
221.619
90.645
84.483
(14.727)
(131.622)
32.170
282.568
Short-term debt
37.502
0
5
0
8.679
329.702
375.887
Current portion of long-term debt
0
2.173
0
10.592
0
287.234
299.999
Lease liabilities
316
272
95
578
656
8.864
10.782
Derivatives
0
2.380
538
0
0
41.436
44.354
Current portion of non-current provisions
0
382
0
0
0
64
446
Current Liabilities
434.361
326.790
480.329
181.239
(90.438)
2.182.474
3.514.755
Liabilities
525.798
356.534
481.092
556.479
(79.242)
5.734.580
7.575.240
Equity & Liabilities
1.584.809
537.821
346.794
943.730
339.218
6.915.750
10.668.120
12. Appendix I - Unbundled Financial Statements
of Energy Segment METLEN Energy & Metals S.A. Group of Companies
554
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
UNBUNDLED BALANCE SHEET OF THE FULLY INTEGRATED COMPANY
31.12.2023
(Amounts in thousands €)
Energy
Production
Energy
Supply
Natural Gas
Supply
RES
Other
Other
Operations
METLEN
ENERGY &
METALS
GROUP
Assets
Non current assets
Property, plant and equipment
869.702
2.862
21
329.818
2.182
809.346
2.013.932
Goodwill
0
0
0
0
0
249.497
249.497
Intangible Assets
311.594
15.666
735
25.663
23
159.553
513.235
Investments in subsidiary companies
0
73.892
7.651
32.835
262.298
(376.675)
0
Investments in associates
0
0
0
0
0
2.818
2.818
Other investments
0
0
0
0
0
21
21
Deferred Tax Assets
14.470
7.038
88
9.700
605
24.334
56.236
Other financial assets
0
0
0
0
0
149
149
Derivatives
0
0
0
0
0
0
0
Construction contract assets
0
0
0
0
0
171.046
171.046
Other Long-term receivables
148
13.275
24.626
(88)
282
17.436
55.679
Right-of-use-assets
2.992
2.311
131
20.161
1.889
147.903
175.388
Total non-current assets
1.110.713
115.044
33.253
418.090
267.280
1.205.429
3.238.002
Current assets
Inventories
44.767
0
13.299
354
114
1.276.805
1.335.339
Construction Contracts
0
0
0
0
0
335.112
335.112
Trade and other receivables
157.369
190.289
240.827
101.910
32.362
1.572.776
2.295.532
Financial assets at fair value through profit or loss
0
0
0
0
72
20.816
20.887
Derivatives
0
185
0
0
0
49.339
49.524
Restricted cash
0
0
0
7.335
0
0
7.335
Cash and cash equivalents
41.192
23.195
273.147
101.522
17.688
455.844
912.587
Total current assets
243.328
213.669
527.272
211.121
50.236
3.710.692
4.956.316
Total assets
1.354.041
328.713
560.524
602.714
317.515
4.916.121
8.194.318
Equity & Liabilities
Equity
Components of Equity
935.390
(79.189)
376.996
221.143
295.253
857.812
2.607.406
Equity attributable to equity holders of the parent
935.390
(79.189)
376.996
221.143
295.253
857.812
2.607.406
Non controlling Interests
0
0
0
0
0
91.153
91.153
Total Equity
935.390
(79.189)
376.996
221.143
295.253
948.965
2.698.559
Capital allocation between Segments
119.765
55.932
(281.234)
23.065
(46.245)
128.717
0
Non-Current Liabilities
Long-term debt
0
0
0
113.634
0
1.898.675
2.012.308
Lease liabilities
3.349
1.686
93
20.206
1.055
147.298
173.687
Derivatives
0
0
0
695
0
224
919
Deferred Tax Liabilities
71.314
0
15
20.182
9.482
102.344
203.336
Liabilities for pension plans
271
28
0
6
480
7.252
8.037
Other long-term payables
19.625
21.667
1.404
38.348
0
3.891
84.936
Provisions
0
0
0
26.497
64
19.460
46.021
Total non-current liabilities
94.559
23.382
1.512
193.069
11.081
2.179.144
2.529.244
Current Liabilities
Trade and other payables
221.674
202.927
403.715
148.109
43.086
553.781
1.573.291
Contract liabilities
0
0
0
0
0
185.068
185.068
Tax payable
34.304
119.788
59.497
5.133
7.444
15.187
241.353
Short-term debt
36.255
1.218
0
0
6.031
318.991
362.496
Current portion of long-term debt
0
0
0
11.864
0
542.539
554.403
Lease liabilities
286
2.749
40
330
867
4.831
9.102
Derivatives
0
1.907
0
0
0
38.822
40.729
Current portion of non-current provisions
0
0
0
0
0
73
73
Current Liabilities
204.328
328.588
463.251
165.436
57.426
1.659.292
2.966.515
Liabilities
298.887
351.970
464.763
358.505
68.508
3.838.437
5.495.759
Equity & Liabilities
1.354.041
328.713
560.524
602.714
317.515
4.916.121
8.194.318
12. Appendix I - Unbundled Financial Statements
of Energy Segment METLEN Energy & Metals S.A. Group of Companies
555
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
General Principles
The Company METLEN Energy & Metals S.A., as an integrated company operating as producer and supplier of electricity and
supplier of natural gas, taking into account provisions of Law 4001/2011 (Government Gazette A '179) maintains separate
accounts, Balance Sheet and Income Statement, for Electricity Production and Supply as referred to in article 141 of Law
4001/2011, the No. 162/2019 authorization decision of the Regulatory Authority for Energy, as well as for Natural Gas Supply, as
referred to in article 89 of Law 4001/2011 and the No. 162/2019 authorization decision of the Regulatory Authority for Energy.
The Company operates in Energy and Metallurgy Sector as well as in Infrastructure & Concessions.
At the end of the financial year, the Company publishes according to the IFRS its separate profit and loss statements and balance
sheet per electrical energy business area (Balance Sheet and Income Statement before tax), in accordance with the relevant
provisions of Law 2190/1920, as amended by the law 4548/2018, as well as by the laws 3229/2004 and 3301/2004 (as amended
and in force based on the IFRS. Income, Expenses, Assets and Liabilities relating to non-electricity sectors are allocated to the
Separate Consolidated Balance Sheet and Income Statement in the "Other Operations" category.
The aforementioned statements are included in the Notes to the Company's annual financial statements, which are approved
and contain a certificate issued by Chartered Accountants. The certificate makes reference in the regulations approved by the
RAE, in accordance with Article 141, paragraph 4 and Article 89, paragraph 5 of Law 4001/2011.
Finally, in preparing the above, we have taken into account Directive (EU)2019/944, which aims distinguish between regulated
and competitive activities.
Allocation Methods and Rules
Methods and Accounting Rules
The methods and accounting rules followed by the Company are dictated by the general accounting principles and the articles of
the International Accounting Standards (IFRS), which must be mandatorily kept.
The Accounting Department of the Company is fully computerized with a valid and properly configured accounting plan and
software (SAP), which ensure that separate accounts are maintained and that separate profit and loss statements and balance
sheet are prepared for each activity.
In particular, the mandatory registration of all accounting records per business area (in SAP) is currently applied, as designated
by the Company in accordance with the above General Principles, as follows:
(a) Business Areas / Activities
Production of electricity
Supply of electricity
Supply of Natural Gas
Renewable Energy Sources
Other
(b) Business Areas apart from electricity and natural gas
Other Activities
Allocation Rules of Expenses and Revenue (Results)
During every document or transaction entry, as well as any other record pertaining to electricity and natural gas industries, the
amounts are classified per business area. Subsequently, the corresponding accounts referring to expenses, revenues, assets and
liabilities are automatically updated. The software has a security key on the basis of which, no registration is allowed without the
above classification.
This way, documents and transaction entries that concern only one of the Company's business areas or indicate a discrete amount
per business area, update the separate accounts of every Business Area (a) directly. The rest of the documents and transactions
are allocated to each business area, with the use of a defined allocation key.
Thereafter, the Company prepares the annual profit and loss statements of each financial year per business area.
12. Appendix I - Unbundled Financial Statements
of Energy Segment METLEN Energy & Metals S.A. Group of Companies
556
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Allocation Rules of Assets and Liabilities
The entries updating the Assets and Liabilities Accounts, such as fixed assets, reserves, customers, other receivables, suppliers,
liabilities and loans are allocated based on the business area to which they relate.
At the end of each financial year, the total Equity is allocated based on the difference between Assets and Liabilities of each
business area, which is designated as “capital allocation to business units”.
1. Content of Activities’ Annual Income and Expenses
The annual separate Profit and Loss Accounts for each activity include the Company’s transactions with third parties.
Specifically, each business area includes the following:
a) Production of electricity
This business area includes Income, Expenses, Assets and Liabilities, which are derived solely from the business area of power
plants.
Specifically,
Income from the operation of the plant in Agios Nikolaos, Boeotia, of METLEN Energy & Metals S.A. Company, with a nominal
power of 444,48 MW, with combustible natural gas.
Income from the operation of the plant in Agioi Theodoroi Korinthias of Korinthos Power S.A., with a nominal power of 436,6
MW, with combustible natural gas.
Income from the operation of the CHP plant in Agios Nikolaos, Boeotia, METLEN Energy 7 Metals S.A. Company with a nominal
power of 334 MW, with combustible natural gas.
Income from the operation of the New Technology Combined Cycle Natural Gas Power Plant in Agios Nikolaos, Boeotia, of
METLEN Energy & Metals S.A. Company, with a nominal capacity of 826 MW."
Expenses relating to the above income, the main ones being the following: Supply of natural gas, pollutant markets, third party
fees and expenses, maintenance and operational costs, consumption of spare parts, other production expenses and
depreciations, as well as finance costs.
b) Supply of electricity (Trading & Retail)
This activity includes Income, Expenses, Assets and Liabilities, which are derived from the trading and retail of electricity.
Specifically,
Income from Trading mainly originates from billings to Operator of Electricity Market (Energy Exchange Group) and to domestic
and foreign companies, while retail sales from Domestic and Professional electricity consumers.
Purchases concern the supply of Electricity from Operator of Electricity Market (Energy Exchange Group and DAPEEP) and
domestic and foreign companies, the rights of electricity import and export, and the other services from Independent Power
Transmission Operator (ADMHE), the network usage (DEDDHE), the cost of purchase of electricity future products (NOME).
Expenses mainly relate to personnel remunerations and costs, third party fees, finance, depreciation and miscellaneous expenses.
c) Supply of Natural Gas (Trading & Retail)
This activity includes Income, Expenses, Assets and Liabilities, which are derived from the trading and retail of Natural Gas.
Specifically,
Income from Trading mainly originates from billings to eligible customers and provision of other services.
Purchases concern the supply, transmission and distribution cost of natural gas, as well as other related costs.
Expenses mainly relate to personnel remunerations and costs, third party fees, finance, depreciation and miscellaneous expenses
d) Renewable Energy Sources
This activity includes Income, Expenses, Assets and Liabilities arising from Renewable Energy Sources in operation.
12. Appendix I - Unbundled Financial Statements
of Energy Segment METLEN Energy & Metals S.A. Group of Companies
557
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
e) Other
This activity includes Administrative Income and Expenses of the Company’s Energy and Natural Gas sector.
f) Other activities apart from Electricity and Natural Gas Sector
Other activities include Income and Expenses from Other Sectors, where METLEN Energy & Metals S.A. operates, such as
“Metallurgy and Mining Sector” and “EPC and Infrastructure Sector”.
Maroussi, 12 March 2025
Evangelos Mytilineos
I.D. No ΑΝ 094179/2017
Chairman of the Board of Directors & Chief Executive Officer
Eleftheria Kontogianni
I.D. No Α00419969/2024
Spyridon Kasdas
I.D. No ΑP 104707/2022
Chief Finance Officer
Vice-Chairman A’ of the Board of Directors
Ioannis Boumponaris
I.D. No ΑM 499302/2014
Periklis Kazakos
I.D. No Α01271813/2024
Finance & MIS Senior Director
Financial Reporting & Controlling Senior Manager
13. Appendix II – Annexes of the Sustainability Statement
558
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Contents of the Annex to the Sustainability Statement
1. Table of Contents of GRI Standards
2. TCFD Content Index
3. Key climate risk and opportunity assessment indicators
4. SASB Content Index
5. UN Global Compact Progress Report (table of contents)
6. ESG Reporting Guide 2024 - Athens Stock Exchange
7. Accountability Principles Standard ΑΑ1000 Index
8. Greek Sustainability Code (Table of Contents)
9. ASI Content Index (Metals Sector)
10. ESG KPIS
10.1. Environment
10.2. Society
10.3. Governance
11. Biodiversity Table
12. Waste Table
13. Appendix II - Annexes of the Sustainability Statement
13. Appendix II – Annexes of the Sustainability Statement
559
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
1 TASK FORCE ON CLIMATE-RELATED FINANCIAL DISCLOSURES INDEX
Focus fields
METLEN’s response
(reference to the sections and pages of this report)
Governance
a) Disclose the organization’s governance
around climate-related risks and
opportunities.
ESRS 2 – General Disclosures: Governance
b) Describe management’s role in
assessing and managing climate-related
risks and opportunities.
ESRS 2 – General Disclosures: Governance
Strategy
a) Describe the climate related risks and
opportunities the organization has
identified over the short, medium, and
long term.
ESRS E1: Strategy
b) Describe the impact of climate-related
risks and opportunities on the
organization’s businesses, strategy, and
financial planning.
ESRS E1: Strategy
c) Describe the resilience of the
organization’s strategy, taking into
consideration different climate-related
scenarios, including a 2°C or lower
scenario.
ESRS E1: Strategy
Risk Management
a) Describe the organization’s processes
for identifying and assessing climate-
related risks.
ESRS 2 – General Disclosures & ESRS E1 – Climate Change: Risk and Opportunity
Impact Management
b) Describe the organization’s processes
for managing climate related risks.
ESRS 2 – General Disclosures & ESRS E1 – Climate Change: Risk and Opportunity
Impact Management
c) Describe how processes for identifying,
assessing, and managing climate-related
risks are integrated into the
organization’s overall risk management.
ESRS 2 – General Disclosures & ESRS E1 – Climate Change: Risk and Opportunity
Impact Management
Metrics & Targets
a) Disclose the metrics used by the
organization to assess climate-related
risks and opportunities in line with its
strategy and risk management process.
Annex of the Sustainability Statement
b) Disclose Scope 1, Scope 2, and, if
appropriate, Scope 3 greenhouse gas
(GHG) emissions, and the related risks.
ESRS E1: Metrics and targets
c) Describe the targets used by the
organization to manage climate-related
risks and opportunities and
performance against targets.
ESRS E1: Metrics and targets
13. Appendix II – Annexes of the Sustainability Statement
560
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
TCFD Item Table
Key alignment actions for the period
2025-2026
Explanation
misalignment
Governance
Reference to whether the Board of
Directors and/or its committees
specifically address climate-related issues
by: 1. reviewing annual budgets, 2.
formulating business plans, 3. setting
performance targets for the organization,
and 4. supervising significant capital
expenditures, acquisitions and
divestments.
To date, the Board of Directors examines climate issues, depending on their importance, in the
context of approving Management recommendations regarding the annual corporate budget,
business plans and sustainable finance issues. These recommendations incorporate specific climatic
parameters that are inextricably linked to the Company's business activity. This approach allows: a)
the assessment of climate issues in the context of business strategy, in combination with economic
and operational factors and b) balances the need for gradual integration of climate parameters in
strategic decisions with current business reality.
As part of further improving its practices, METLEN intends to review, by 2026, the supervisory role
of the Board based on best practices on climate-related issues. This initiative depends on the
further integration of climate considerations into management's strategic decision-making
processes, such as acquisitions, mergers and divestments.
Strategy
An indication of how climate risks and
opportunities affect the Company's
decisions regarding acquisitions, mergers
or divestments and especially how they
are integrated into the M&A decision-
making and strategy planning process.
M&A decisions are currently primarily driven by operational, financial and strategic factors such as
expanding into markets, enhancing expertise or return on investment. Climate factors, while
recognised as important, are not yet a primary assessment criterion in every strategic decision.
However, the Company recognises the importance of integrating climate criteria into the M&A
process and the challenges it is likely to face, such as the limited availability of data to target
companies or the lack of internal expertise in climate assessments. In this context, it commits, over
the next 2 years, to explore the possibility of integrating specific criteria related to climate issues
into the strategy and decision-making process for M&A.
Quantitative information on the impact of
climate-related opportunities on the
Company's revenues, assets and liabilities.
The climate opportunities identified by the Company have a long-term impact horizon, which
makes it difficult, to date, to directly quantify their impact on current financial figures, such as
revenues or assets. Opportunities also involve elements of uncertainty and depend on future
external developments (e.g. regulatory changes, market changes). Thus, METLEN focuses for the
moment on their qualitative description, until the relevant data that will help in their quantitative
analysis and the required experience are obtained. The Company aims over the next 2 years to
evolve its processes and incorporate quantitative assessments as the availability of data and
methodologies improves.
Indicators & Targets
Investigation for the development and
integration of internal carbon price in the
Company's strategy.
METLEN is already subject to the European Emissions Trading System (EU ETS), which provides a
clear, externally determined carbon price that is embedded in its operations and strategies.
Through the EU ETS, the company's strategic decisions take into account the actual prices
prevailing in the carbon trading market. At the same time, the Company is already implementing a
comprehensive CO₂ hedging strategy to manage its exposure to emission allowance price
fluctuations. This practice provides an effective mechanism to offset the economic impact of
carbon on its operations. Based on the above, to date, the development of an internal carbon price
has not been a concern for the Company, as decision-making is already based on real market prices
or even compensated prices. However, it is already exploring the possibility of developing and
implementing an internal carbon price, in the context of enhancing decision-making either in
specific projects or overall in the longer term.
Publish more specific metrics (historical
and future) that support climate scenario
analysis and the strategic planning
process.
The Company recognizes the importance of disclosing specific metrics that support climate
scenario analysis and the strategic planning process. However, it has not yet fully aligned with this
requirement because climate scenario analysis is a new field for the Company, and so far efforts
have been focused on understanding and integrating appropriate assumptions, as well as
improving the quality of the data collected. Also, a lot of data related to climate scenario analysis
includes strategic projections and details that are critical to maintaining the Company's competitive
advantage. Disclosure of such information could reveal commercially sensitive aspects of corporate
strategy and potentially negatively affect its market position. Finally, the Company is in a phase of
intense growth, where strategy, investments and business activities are constantly changing. This
makes it difficult, at present, to formulate and publish reliable long-term measurements and
13. Appendix II – Annexes of the Sustainability Statement
561
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
projections in the context of climate scenarios. In this context, the Company continuously examines
its available metrics and is committed to disclosing on an annual basis those that are available
without disclosing strategic details that affect its competitiveness and can be aligned with its
dynamic business growth.
Develop and disclose metrics that reveal
the financial impacts of climate change,
such as changing demand, changes in
spending, asset valuation and financing
costs.
The Company is currently focused on implementing green initiatives and investments, such as the
issuance of green bonds, which contribute to enhancing sustainability by having a positive impact,
to a certain extent, on financing costs. Assessing the future impacts of climate change on demand,
expenditure and asset valuation involves a high degree of uncertainty, as it depends on changing
factors such as regulatory policy, technological developments and changes in customer
preferences. Also, much of the data related to asset valuation and funding costs is strategic in
nature, and its disclosure could reveal details that affect the Company's competitive position. The
Company's goal over the next two years is to explore the disclosure of the financial impacts of
climate change with a priority to link investments in climate initiatives to indicators such as asset
valuation and cost of capital.
Investigation of development &
publication of interim CO2 emission
reduction targets.
METLEN has committed to reducing CO₂ emissions by 30% by 2030 and for Net-zero emissions in
2050, in line with the WB2oC scenario, without having set intermediate targets (e.g. every 5 years)
due to the specificities of its key Sectors of activity and its aggressive growth strategy in recent
years. The Company has already started and aims to complete the exercise of reviewing its existing
climate targets and initiatives by the end of 2025. Part of this exercise is the examination of the
possibility of developing and thus publishing intermediate targets, always in combination with the
business strategy and the analysis of specific and key parameters (e.g. technological developments)
that could affect the path of emission reduction.
13. Appendix II – Annexes of the Sustainability Statement
562
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
2 Key climate risk and opportunity assessment indicators
Indicators
Correlation with Risks and Opportunities
Total Scope 1 emissions (kt CO2e)
Field 1 emissions / Metals Sector (kt CO2e)
Scope 1 emissions / Energy Sector (kt CO2e)
Total Scope 2 emissions (kt CO2e)
Scope 2 emissions / Metals Sector (kt CO2e)
Total Scope 1 & 2 emissions (kt CO2e)
[1]
Field 1 & 2 emissions / Metals Sector (kt CO2e)
[1]
Total Scope 3 emissions (kt CO2e)
GHG emissions
Installed capacity of natural gas power plants (MW)
Transition risks
Installed RES capacity (MW)
Climate-related opportunities: Capital development
Installed storage capacity (MW)
Climate-related opportunities: Capital development
Electricity produced by natural gas plants (GWh)
Transition risks
Percentage of fossil fuel electricity produced by METLEN
out of the total fossil fuel electricity in the country (%)
Transition risks
Electricity from RES (GWh)
Climate-related opportunities
Total electricity sales (GWh)
Transition risks - Natural hazards
Total natural gas sales (GWh)
Transition risks
Scope 1 emission intensity / Energy Sector (t CO2e/MWh)
[1]
Production of primary aluminium (t)
Production of secondary aluminium (t)
Scope 1 emission intensity / Metals Sector / Production of
primary aluminium (t CO2e/t Al)
Scope 1 & 2 emission intensity / Metals Sector /
Production of primary aluminium (t CO2e/t Al)
Scope 1 emission intensity / Metals Sector / Production of
secondary aluminium (t CO2e/t Al)
Field 1 & 2 emissions / Metals Sector / Production of
secondary aluminium (t CO2e/t Al)
Scope 1 & 2 emission intensity / Metals Sector (t CO2e/t
Al)
[1]
% revenues of Metals Sector to METLEN’s total revenues
% revenues from Primary aluminium to the revenues of
Metals Sector
Transition risks
Natural hazards (power generation)
Climate-related opportunities
Revenues based on the European Classification System for
Sustainable Economic Activities ("EU Taxonomy"), Climate
Change Mitigation, METLEN (%)
[2]
Climate-related opportunities
Revenues based on the European Classification System of
Sustainable Economic Activities ("EU Taxonomy");
Climate-related opportunities
Carbon price ($/t CO2e)
Transition risks
13. Appendix II – Annexes of the Sustainability Statement
563
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
3 SASB Content Index
SASB Standard
Metric Code/Industry
Disclosure/ Results
Greenhouse gas emissions
EM-CM-110a.1
Construction Materials
1,343.37 tCO
2
EM-MM-110a.1
Metals & Mining
1,242,156.02 tCO
2
(1) Gross global Scope 1 emissions (Gross emissions are GHGs emitted into
the atmosphere before accounting for offsets, credits or other similar
mechanisms that have reduced or compensated for emissions.)
IF-EU-110a.1
Electric Utilities & Power
Generators
2,717,721.92 tCO
2
EM-CM-110a.1
Construction Materials
0.0%
EM-MM-110a.1
Metals & Mining
95.67%
(2) Percentage of gross Scope 1 emissions covered by EUETS (The
percentage is calculated by dividing the total amount of gross Scope 1
emissions (CO2-e) covered by EUETS by the total amount of gross Scope 1
emissions (CO2-e))
IF-EU-110a.1
Electric Utilities & Power
Generators
47.24%
EM-CM-110a.2
Construction Materials
EM-MM-110a.2
Metals & Mining
Discussion of long-term and short-term strategy or plan to manage Scope 1
emissions, emissions reduction targets, and an analysis of performance
against those targets
IF-EU-110a.3
Electric Utilities & Power
Generators
ESRS E1: E1-4
Air Quality
EM-CM-120a.1
Construction Materials
EM-MM-120a.1
Metals & Mining
Air emissions of the following pollutants: (1) NOx (excluding N2O), (2) SOx,
(3) particulate matter (PM10), (4) dioxins/ furans, (5) volatile organic
compounds (VOCs), (6) polycyclic aromatic hydrocarbons (PAHs), and (7)
heavy metals (e.g., mercury (Hg), lead (Pb) etc.)
IF-EU-120a.1
Electric Utilities & Power
Generators
ESRS E2: E2-4
Apart from the emissions
stated within the chapter
«ESRS E2: Pollution»,
METLEN does not emit other
air emissions (e.g.
dioxins/furans, POPs, PAHs,
HAPs, heavy metals).
Energy Management
EM-CM-130a.1
Construction Materials
(1) Total energy consumed, (2) percentage grid electricity, (3) percentage
alternative, (4) percentage renewable
EM-MM-130a.1
Metals & Mining
ESRS E1: E1-5
METLEN does not consume
energy from alternative
sources such as but not
limited to: used tires, spent
solvents and waste oils,
processed municipal solid
waste, household wastes,
agricultural wastes, and
sewage sludge.
Water & wastewater management
EM-CM-140a.1
Construction Materials
(1) Total fresh water withdrawn, (2) total water consumed, (3) percentage
recycled, (4) percentage in regions with High or Extremely High Baseline
Water Stress
EM-MM-140a.1
Metals & Mining
ESRS E3: E3-4
13. Appendix II – Annexes of the Sustainability Statement
564
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
SASB Standard
Metric Code/Industry
Disclosure/ Results
IF-EU-140a.1
Electric Utilities & Power
Generators
EM-MM-140a.2
Metals & Mining
Number of incidents of non-compliance associated with water quality
permits, standards, and regulations
IF-EU-140a.2
Electric Utilities & Power
Generators
ESRS E3: E3-2
Description of water management risks and discussion of strategies and
practices to mitigate those risks
IF-EU-140a.3
Electric Utilities & Power
Generators
ESRS E3: E3-2 & E3.SBM-3
Waste & Hazardous Materials Management
Amount of waste generated, per- centage hazardous, percentage recycled
EM-CM-150a.1
Construction Materials
ESRS E5: E5-5
Amount of coal combustion residuals (CCR) generated; percentage recycled
IF-EU-150a.1
Electric Utilities & Power
Generators
Total number of carbon burning residue (CCR) retentions, broken down by
potential risk and structural integrity assessment
IF-EU-150a.2
Electric Utilities & Power
Generators
Not applicable. METLEN does
not own or operate Coal-fired
Power Units
Total weight of non-mineral waste generated
(Non-mineral waste is defined as all other waste (excluding mineral waste))
for which the Industry has no further use and which is discharged, destined
to be discharged or released into the environment. Excludes overlying
waste, sterile, tailings and gaseous waste).
EM-MM-150a.4
Metals & Mining
0 tons
Total weight of tailings generated
(tailing: by-product of mining, consisting of the treated rock or soil left over
from the separation of value commodities from the rock or soil in which
they occur).
EM-MM-150a.5
Metals & Mining
0 tons
Total weight of extractive waste generated
(Waste rocks are defined as mineral materials and low-quality ore with no
economic interest at the time of extraction)
EM-MM-150a.6
Metals & Mining
285,784 tons
Amount of hazardous waste generated
EM-MM-150a.7
Metals & Mining
20,199.11 tons
Amount of hazardous waste generated that was recycled
EM-MM-150a.8
Metals & Mining
4,767.92 tons
13. Appendix II – Annexes of the Sustainability Statement
565
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
SASB Standard
Metric Code/Industry
Disclosure/ Results
Total number of significant incidents related to the handling, storage,
transport or disposal of hazardous materials used in hazardous waste
treatment activities generated.
(A significant incident is defined as an event that exceeds the volume and
concentration limits of local regulatory requirements or industry-acceptable
codes, or is otherwise included in the entity's financial statements (e.g. due
to obligations incurred), or is recorded by the entity as an event that is
required to be reported by local jurisdictions, or is an event that the
operator considers material).
EM-MM-150a.9
Metals & Mining
zero
Description of waste and hazardous materials management policies and
procedures for active and inactive operations
EM-MM-150a.10
Metals & Mining
Solid Waste Management
Directive.
Ecological Ιmpacts
EM-CM-160a.1
Construction Materials
Description of environmental management policies and practices for
construction sites in operation
EM-MM-160a.1
Metals & Mining
Environmental policy
ESRS E4: E4-2_& E4-3
Terrestrial acreage disturbed and percentage of impacted area restored
EM-CM-160a.2
Construction Materials
ESRS E4: E4-5
Percentage of mine sites where acid rock drainage is: (1) predicted to occur,
(2) actively mitigated, and (3) under treatment or remediation
EM-MM-160a.2
Metals & Mining
Irrelevant as there is no acid
rock drainage in bauxite
mining facilities. The
percentage of mines where
acid rock drainage occurs is
0%.
Percentage of (1) proven and (2) potential stocks in or near sites with
protected status or habitats of endangered species
EM-MM-160a.3
Metals & Mining
The Company does not own
or have developed mining
activities in or near areas
with protected status or
habitat of endangered
species.
Number of incidents of non-compliance with environmental permits,
standards and regulations
IF-EN-160a.1
Engineering &
Construction Services
ESRS Ε4: Ε4-5
Describe the procedures in place to assess and manage environmental risks
related to the design, location and construction of the project
IF-EN-160a.2
Engineering &
Construction Services
There is a Construction
Environmental Management
Plan for the construction. For
the site and design there is
the Environmental and Social
Impact Assessment (ESIA)
and the Environmental
Permit
Human Rights & Community Relations
Percentage of (1) proved and (2) probable reserves in or near areas of
conflict
EM-MM-210a.1
Metals & Mining
Percentage of (1) proved and (2) probable reserves in or near indigenous
land
EM-MM-210a.2
Metals & Mining
METLEN has no proven or
probable reserves in or near
conflict areas or indigenous
lands.
Discussion of engagement processes and due diligence practices with
respect to human rights, indigenous rights, and operation in areas of
conflict
EM-MM-210a.3
Metals & Mining
ESRS S1: S1-1
13. Appendix II – Annexes of the Sustainability Statement
566
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
SASB Standard
Metric Code/Industry
Disclosure/ Results
Discussion of process to manage risks and opportunities associated with
community rights and interests
EM-MM-210b.1
Metals & Mining
ESRS S3: S3-2
Total number and duration (in days) of plant downtime or mining process
delays due to non-technical factors. (This includes outages and delays in
activity due to pending regulatory licensing or other cases and delays
related to issues in the overall activity of the Industry that cause concern,
resistance or protest from the local community or stakeholders)
EM-MM-210b.2
Metals & Mining
There were no non-technical
delays during the reporting
period
Labour Practices
Percentage of active workforce covered under collective bargaining
agreements
EM-MM-310a.1
Metals & Mining
ESRS S1: S1-8
Number of reported cases of strikes and lockouts
EM-MM-310a.2
Metals & Mining
There were no strikes or
occupations during the
reporting period
Business Ethics
EM-CM-320a.1
Construction Materials
EM-MM-320a.1
Metals & Mining
IF-EU-320a.1
Electric Utilities & Power
Generators
(1) Total recordable incident rate (TRIR), (2) fatality rate, (3) near miss
frequency rate (NMFR) and (4) average hours of health, safety, and
emergency response training for (a) fulltime employees and (b) contract
employees
IF-EN-320a.1
Engineering &
Construction Services
ESRS S1: S1-14
ESRS S2: S2-5
Near Miss Accident Frequency
Index 2024
Direct employees: 2.15
Indirect workers: 2.09
Direct & Indirect employees:
2.11
Number of reported cases of silicosis
EM-CM-320a.2
Construction Materials
No cases of silicosis were
reported during the reporting
period
Description of the management system for prevention of corruption and
bribery throughout the value chain
EM-MM-510a.1
Metals & Mining
ESRS G1: G1-3
Production in countries that have the 20 lowest rankings in Transparency
International’s Corruption Perception Index
EM-MM-510a.2
Metals & Mining
ESRS G1: G1-4
(1) Number of active projects and (2) backlog in countries that have the 20
lowest rankings in Transparency International’s Corruption Perception Index
IF-EN-510a.1
Engineering &
Construction Services
1. 1 project (Libya)
2. € 16 million
Total amount of monetary damages as a result of legal proceedings related
to allegations of (1) bribery or corruption and (2) anti-competitive practices
IF-EN-510a.2
Engineering &
Construction Services
ESRS G1: G1-4
Description of policies and practices to prevent (1) bribery and corruption
and (2) anti-competitive behaviour in tendering procedures
IF-EN-510a.3
Engineering &
Construction Services
ESRS G1: G1-1 & G1-3
Competitive Behavior
Total amount of monetary losses as a result of legal proceedings associated
with cartel activities, price fixing, and anti-trust activities
EM-CM-520a.1 -
Construction Materials
ESRS G1: G1-3 & G1-4
Critical Incident Risk Management
Total number of nuclear power units, broken down by U.S. Nuclear
Regulatory Commission (NRC) Action Matrix Column
IF-EU-540a.1
Electric Utilities & Power
Generators
Description of efforts to manage nuclear safety and emergency
preparedness
IF-EU-540a.2
Electric Utilities & Power
Generators
Not applicable. The Company
does not own or operate
Nuclear Power Units.
13. Appendix II – Annexes of the Sustainability Statement
567
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
SASB Standard
Metric Code/Industry
Disclosure/ Results
Structural Integrity & Safety
Amount of defect- and safety-related rework costs
IF-EN-250a.1
Engineering &
Construction Services
0 €
Total amount of monetary losses as a result of legal proceedings associated
with defect- and safety-related incidents
IF-EN-250a.2
Engineering &
Construction Services
0 €
Lifecycle Impacts of Buildings & Infrastructure
Number of (1) commissioned projects certified to a third-party
multiattribute sustainability standard and (2) active projects seeking such
certification
IF-EN-410a.1
Engineering &
Construction Services
1. 3
2. 5
Climate Impacts of Business Mix
Amount of backlog for (1) hydrocarbon-related projects and (2) renewable
energy projects
IF-EN-410b.1
Engineering &
Construction Services
1. € 415 million
2. € 463 million
Amount of backlog cancellations associated with hydrocarbon-related
projects
IF-EN-410b.2
Engineering &
Construction Services
zero
Amount of backlog for non-energy projects associated with climate change
mitigation
IF-EN-410b.3
Engineering &
Construction Services
€ 7.7 million
Activity Metrics
Number: (1) residential, (2) commercial and (3) industrial customers served
IF-EU-000.A
Electric Utilities & Power
Generators
1. 458,383
2. 123,811
3. 3,070
Total electricity delivered to: (1) residential, (2) commercial, (3) industrial,
(4) all other retail customers and (5) wholesale customers
IF-EU-000.B
Electric Utilities & Power
Generators
1. 1,249,576 MWh
2. 1,893,407 MWh
3. 2,207,269 MWh
Total electricity produced, percentage per main energy source, percentage
on regulated markets
IF-EU-000.D
Electric Utilities & Power
Generators
· Natural gas fueled
CCGT Thermal Plants:
7,835,842 MWh
· Wind Farms: 609,049
MWh
· Photovoltaic: 981,793
MWh
· Hydroelectric (SHPP):
2,000 MWh
Total wholesale electricity purchased (excluding electricity consumed on
site)
IF-EU-000.E
Electric Utilities & Power
Generators
2,873,932.4 MWh
Number of active projects
IF-EN-000.A
Engineering &
Construction Services
156
Number of completed projects
IF-EN-000.B
Engineering &
Construction Services
59
Total backlog
IF-EN-000.C
Engineering &
Construction Services
€ 2,530 million
Manufacture of (1) ores and (2) finished metal products
EM-MM-000.A
Metals & Mining
1. Bauxite:
1,061,336.63 tons
2. Aluminium:
237,919.39 tons
(1) Total number of employees, (2) percentage of contractors
EM-MM-000.B
Metals & Mining
1. 2,642
2. 37.1%
13. Appendix II – Annexes of the Sustainability Statement
568
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
4 UN Global Compact Progress Report (table of contents)
The United Nations Global Compact is a platform of commitments as well as a practical framework of activities for companies that have
committed themselves to contribute to the great goal of Sustainable Development and responsible business practices. METLEN Energy & Metals
has been formally committed at its highest level of representation since 2008 to adhering to the ten principles of the Compact, disclosing
annually information related to how this adherence is achieved within its wider operations. The table below shows how the Company is
responding to the 10 Principles.
Pillar
Reporting within the Integrated Report 2024
UN Global Compact Principle
PRINCIPLE 1
Businesses should support and respect the protection of
internationally proclaimed human rights.
Human rights
ESRS S1: Own workforce
ESRS S2: Workers in the value chain
PRINCIPLE 2
Businesses should make sure that they are not complicit in human
rights abuses.
PRINCIPLE 3
Businesses should uphold the freedom of association and the
effective recognition of the right to collective bargaining.
PRINCIPLE 4
Businesses should uphold the elimination of all forms of forced and
compulsory labour.
PRINCIPLE 5
Businesses should uphold the effective abolition of child labour.
Labour
ESRS S1: Own workforce
ESRS S2: Workers in the value chain
ESRS G1: Business conduct
PRINCIPLE 6
Businesses should uphold the elimination of discrimination in
respect of employment and occupation
PRINCIPLE 7
Businesses should support a precautionary approach to
environmental challenges.
PRINCIPLE 8
Businesses should undertake initiatives to promote greater
environmental responsibility
Environment
Environmental policy
ESRS E1: Climate change
ESRS E2: Pollution
ESRS E3: Water and marine resources
ESRS E4: Biodiversity and ecosystems
ESRS E5: Resource use and circular economy
PRINCIPLE 9
Businesses should encourage the development and diffusion of
environmentally friendly technologies
Anti-Corruption
Governance
ESRS G1: Business conduct
PRINCIPLE 10
Businesses should work against corruption in all its forms, including
extortion and bribery.
13. Appendix II – Annexes of the Sustainability Statement
569
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
5 ESG Reporting Guide 2024 – Athens Stock Exchange
The Athens Stock Exchange has been participating since 2018 in the Sustainable Stock Exchanges (SSE) initiative of the United Nations, which
promotes the dissemination of best practices for the disclosure and integration of non-financial information, aiming to develop sustainable
investments in local capital markets. Following the call for action of the organizations that promote sustainable development, the Athens Stock
Exchange issued the “ESG Reporting Guide”, seeking to promote and strengthen the ESG-related information disclosure practices applied by
Greek listed companies. The table below presents MYTILINEOS' response to the indicators of the Athens Stock Exchange ESG Reporting Guide
(where C: Basic metrics, Α: Advanced metrics, SS: Sector-Specific metrics), which are based on practices aligned with international sustainability
guidelines and reporting frameworks such as GRI, SASB, GLOBAL COMPACT, IIRC, CDP, TCFD, and the Greek Sustainability Code.
ESG Category
ID
Sub-ID
Metric Title
References
(Section of Integrated Report 2024)
C-E1-1
Direct emissions (scope 1)
ESRS Ε1: Ε1-6
C-E1
C-E1-2
Total scope 1 CO
2
emissions in tonnes per million
EUR net revenue
6,446.9
C-E2-1
Total amount of indirect emissions (Scope 2) -
Location-based approach
C-E2-2
Greenhouse gas intensity of Scope 2 emissions -
Location-based approach
C-E2-3
Total amount of indirect emissions (Scope 2) -
Market-based approach
C-E2
C-E2-4
Scope 2 greenhouse gas intensity - Market-based
approach
ESRS Ε1: Ε1-6
C-E3-1
Total amount of energy consumed within the
organisation
C-E3-2
Percentage of electricity consumed
C-E3-3
Percentage of renewable energy consumed
C-E3-4
Total amount of energy produced
C-E3
C-E3-5
Percentage of energy produced from renewable
sources
ESRS Ε1: Ε1-5
A-E1-1
Other indirect emissions (Scope 3)
ESRS Ε1: Ε1-6
A-E1
A-E1-2
Total CO2 emissions, Scope 3 in tonnes per million
EUR net revenue
10,645.5
A-E2
A-E2-1
Risks and opportunities from climate change
ESRS E1: ESRS2.SBM3
A-E3-1
Total amount of hazardous waste
A-E3-2
Total amount of non-hazardous waste
A-E3-3
Percentage of waste by type of treatment - Recycled
A-E3-4
Percentage of waste by type of treatment -
Composted
A-E3-5
Percentage of waste by type of treatment -
Incinerated
A-E3
A-E3-6
Share of waste by type of treatment - Landfilled
ESRS E5: E5-4
A-E4
A-E4-1
Discharge of waste water containing polluting
substances
ESRS E3: E3-4
A-E5
A-E5-1
Impact of the Company's activity on areas of
sensitive biodiversity
ESRS E4: E4-5
A-E6
A-E6-1
Climate change policy
Environmental policy
A-E7-1
Removal and storage of greenhouse gases
ESRS Ε1: Ε1-7
Environment
A-E7
A-E7-2
Carbon credits
ESRS Ε1: Ε1-8
13. Appendix II – Annexes of the Sustainability Statement
570
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
ESG Category
ID
Sub-ID
Metric Title
References
(Section of Integrated Report 2024)
A-E8-1
Total greenhouse gas emissions based on location
ESRS Ε1: Ε1-6
A-E8
A-E8-2
Total market-based greenhouse gas emissions
ESRS Ε1: Ε1-6
SS-E1
SS-E1-1
Climate change management strategy
ESRS E1: ESRS2.SBM3
SS-E2-1
Total amount NO
x
(except N
2
O)
SS-E2-2
Total amount SO
x
SS-E2-3_
Total amount of volatile organic compounds (VOCs)
SS-E2
SS-E2-4
Total amount of particles (PM)
ESRS E2: Ε2-4
SS-E3-1
Total water pumped
SS-E3-2_
Total water consumption
SS-E3
SS-E3-3_
Percentage of recycled water
SS-E4
SS-E4-1
Description of water management risks and
corresponding mitigation measures taken
ESRS E3: E3-3
SS-E5
SS-E5-1
Description of a strategy to reduce the
environmental impact of packaging throughout its
life cycle
ESRS E5: Ε5-5
SS-E6
SS-E6-1
Total number of backlogs related to community or
ecological impacts
ESRS E4: SBM-3
SS-E7
SS-E7-1
Description of the management approach in relation
to the use of critical materials
The Company does not make use of the
27 critical raw materials as recognized
by the European Commission
190
SS-E8
SS-E8-1
Description of the procedures for assessing and
managing the risks and/or risks associated with
chemicals in products
ESRS S4: S4-4
C-S1
C-S1-1
Indication of the main social partner groups of the
organization and analysis of ways of communication
and cooperation with them
General Sustainability Statement
Information
C-S2
C-S2-1
Percentage of women in the total direct employees
of the Company
ESRS S1: S1-6
C-S3
C-S3-1
Percentage of women at top management level
C-S4-1
Indicator of voluntary departures of full-time
employees
C-S4
C-S4-2
Indicator of non-voluntary departures of full-time
employees
ESG KPI’s (Society)
C-S4-3
Turnover rate of employees
ESRS S1: S1-6
C-S5-1
Average hours of training of employees at top
management level
C-S5-2
Average training hours of other categories of
employees
C-S5-3
Average hours of education - Women
C-S5
C-S5-4
Average hours of training - Men
C-S6
C-S6-1
Human rights policy and fundamental principles
ESRS S1: S1-13
Society
C-S7
C-S7-1
Percentage of workers covered by collective
agreements
ESG KPI’s (Society)
190
European Commission (2019). Critical raw materials (europa.eu)
13. Appendix II – Annexes of the Sustainability Statement
571
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
ESG Category
ID
Sub-ID
Metric Title
References
(Section of Integrated Report 2024)
C-S8-1
Evaluating suppliers based on ESG criteria
ESRS G1: G1-2
C-S8
C-S8-2
Policies to manage significant impacts, risks and
opportunities related to employees in the value chain
Code of Conduct for Suppliers &
Partners
A-S1-1
Turnover rate of environmentally sustainable
activities - Aligned
A-S1-2
Percentage of capital expenditure of environmentally
sustainable activities - Aligned
A-S1-3
Percentage of operating costs of environmentally
sustainable activities - Aligned
A-S1-4
Turnover rate of environmentally sustainable
activities - Eligible
A-S1-5
Share of capital expenditure of environmentally
sustainable activities - Eligible
A-S1
A-S1-6
Share of operating costs of environmentally
sustainable activities - Eligible
European Taxonomy
A-S2
A-S2-1
Total amount spent on employee training
ESG KPI’s (Society)
A-S3
A-S3-1
Percentage of difference between male and female
earnings
ESRS S1: S1-4
A-S4-1
Total CEO pay
Remuneration Report of BoD
Members
Α-S4
A-S4-2
Ratio of CEO to median employee earnings
ESG KPI’s (Governance)
SS-S1-1
Product quality and safety
ESRS S4: S4-1
SS-S1
SS-S1-2
Total number of product recalls
Not related to METLEN's activity
SS-S2
SS-S2-1
Total number of users whose information is used for
secondary purposes
SS-S3-1
Number of law enforcement requests for user
information
SS-S3-2
Number of users whose information was requested
SS-S3
SS-S3-3
Percentage of requests leading to publication of
information
ESRS S4: S4-5
SS-S4
SS-S4-1
Total amount of monetary losses as a result of labor
law violations
ESRS S1: S1-17 & ESRS2: SBM-3
SS-S5
SS-S5-1
Total amount of pecuniary losses as a result of data
security and privacy fines
ESRS S4: S4-5
SS-S6-1
Number of injuries
SS-S6-2
Number of fatalities
SS-S6-3
Accident frequency rate (TRIR)
SS-S6
SS-S6-4
Accident severity rate
ESRS S1: S1-14
ESRS S2: S2-5
SS-S7
SS-S7-1
Description of the approach to providing transparent
information on products and services, including
marketing practices and product labelling
SS-S8
SS-S8-1
Disclosure of customer satisfaction survey results
ESRS S4: S4-2
SS-S9
SS-S9-1
Customer grievance mechanism
ESRS S4: S4-3
SS-S10
SS-S10-1
ESG integration in business activity
Strategic Priorities & Business Model
13. Appendix II – Annexes of the Sustainability Statement
572
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
ESG Category
ID
Sub-ID
Metric Title
References
(Section of Integrated Report 2024)
C-G1-1
ESG related qualifications of the board members
CVS OF BOD MEMBERS
C-G1-2
Classification of the Chairman of the Board
Board of directors
C-G1-3
Percentage of female board members
C-G1-4
Percentage of non-executive board members
C-G1-5
Percentage of both non-executive and independent
board members
C-G1-6
Number of BoD members
C-G1-7
Average age of BoD members
C-G1
C-G1-8
Average term of office of the members of the Board
of Directors
ESG KPIs (Governance)
C-G2
C-G2-1
Description of approach to sustainability oversight
General Sustainability Statement
Information
C-G3
C-G3-1
Material Topics
General Sustainability Statement
Information
C-G4
C-G4-1
Sustainability Policy
Corporate Social Responsibility Policy
ESRS G1: G1-1
C-G5
C-G5-1
Business ethics policy
Code of Business Conduct
C-G6
C-G6-1
Data security policy
Privacy Policy
C-G7-1
Bases for the preparation of the IR
C-G7
C-G7-2
List of all entities included in the IR
General Sustainability Statement
Information
C-G8
C-G8-1
Annual Financial Statements - Publication Date
13/03/2025
A-G1-1
Description of strategy, business model and value
chain
Strategic Priorities & Business Model
of Sustainability Statement
A-G1
A-G1-2
Activity in the field of fossil fuels, production of
chemicals, controversial weapons, cultivation and
production of tobacco
Not related to METLEN's activity
A-G2
A-G2-1
Total amount of monetary losses as a result of
business ethics violations
A-G2-2
Total number of breaches of business ethics
ESRS G1: G1-4
A-G3-1
Short-term targets associated with strategic ESG
objectives
A-G3-2
Medium-term targets associated with strategic ESG
objectives
A-G3-3
Long-term targets associated with strategic ESG
objectives
A-G3
A-G3-4
Science-based ESG goals
Subsection 'Objectives' within the
sections of the Sustainability
Statement:
• Environmental issues
• Social issues
• Governance issues
A-G4
A-G4-1
Percentage of executive’s variable pay
Remuneration Report of BoD
Members
A-G5-1
External assurance
A-G5
A-G5-2
Level of external assurance
Independent Assurance Statement
A-G6
A-G6-1
ESG Bonds
General Sustainability Statement
Information, subsection 'Governance'
A-G7
A-G7-1
Incentive schemes and remuneration policies linked
to sustainability issues
Remuneration Report of BoD
Members
Governance
SS-G1
SS-G1-1
Description of reporting policies and procedures
Reporting channels
13. Appendix II – Annexes of the Sustainability Statement
573
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
ESG Category
ID
Sub-ID
Metric Title
References
(Section of Integrated Report 2024)
SS-G2
SS-G2-1
Description of systems, processes and mechanisms to
identify and mitigate critical risks
General Sustainability Statement
Information
SS-G3
SS-G3-1
Description of systems, processes and mechanisms to
reduce the contribution to systemic risks and
improve safeguards
“Enterprise Risk Management”
Chapter
6 Accountability Principles Standard AA1000 Index
7 Greek Sustainability Code (Table of contents)
The Greek Sustainability Code constitutes a structured system regarding the transparency and self-commitment tool of Greek
Organizations / Enterprises and has been developed in the framework of the “Sustainable Greece 2020” initiative. It addresses
the need for measuring the economic, environmental and social performance of Organizations / Businesses with the goal of
strengthening their competitiveness in terms of incorporating the principles of Sustainable Development and Corporate
Responsibility in their operation and of their compliance requirements with the EU Non-financial Reporting Directive. The table
below presents MYTILINEOS’ response to the Greek Sustainability Code criteria (LEVEL A), which are based on the following
international standards: GRI, GLOBAL COMPACT, EFFAS, ISO & EMAS.
Principle applied
Methods
Reference in the Report
General Sustainability Statement Information
Inclusivity
Identification of key stakeholders and
dialogue to understand key issues
General Sustainability Statement Disclosures
General Sustainability Statement Information
Materiality
Definition of topics that are important to
the company and stakeholders
General Sustainability Statement Disclosures
Strategic Priorities & Business Model
General Sustainability Statement Information
ESRS S1: Own Workforce
ESRS S4: Consumers and end-users
Responsiveness
Responsiveness to key issues and
transparency on performance
ESRS G1: Business Conduct
Strategic Priorities & Business Model
General Sustainability Statement Information
General Sustainability Statement Disclosures
ESRS Ε1: Climate Change
ESRS Ε2: Pollution
ESRS Ε3: Water and marine resources
ESRS E4: Biodiversity and ecosystems
ESRS E5: Resource use and circular economy
ESRS S1: Own Workforce
ESRS S2: Workers in the value chain
ESRS S3: Affected communities
ESRS S4: Consumers and end-users
Impact
Analysis of direct and indirect impact of the
company’s actions
ESRS G1: Business Conduct
13. Appendix II – Annexes of the Sustainability Statement
574
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Pillar
Criteria
Refernces (Sections of Integrated Report 2024)
Strategy, Analysis & Action
Chairman's Message
Strategic priorities & Business Model
General Sustainability Statement Information
General Sustainability Statement Disclosures
Materiality
General Sustainability Statement Disclosures
Objectives
General Sustainability Statement Information
Subsection 'Objectives' within the sections of the Sustainability Statement:
• Environmental issues
• Social issues
• Governance issues
Strategy
Value Chain Management
General Sustainability Statement Information
ESRS G1: Business Conduct
Responsibility
ESRS G1: Business Conduct
Rules & Processes
General Sustainability Statement Information
General Sustainability-Statement Disclosures Procedure
ESRS G1: Business Conduct
Monitoring
General Sustainability Statement Information
Participation in Socially Responcible Investment indexes
Sustainable Development commitments
ESG Ratings
ESG Scorecard
Integrated Value Creation Scorecard
Remuneration policies & incentives for
Sustainable Development
Remuneration Policy and Remuneration of Boards Members
Stakeholders Engagement
General Sustainability Statement Information
Process
Management
Product responsibility and innovation
ESRS S4: Consumers an end-users
Natural resource use
Resource Management
Environment
Air Emissions & Climate Change
Environmental policy
ESRS Ε1: Climaate Change
ESRS Ε2: Pollution
ESRS Ε3: Water and marine resources
ESRS E4: Biodiversity and ecosystems
ESRS E5: Resource use and circular economy
Labour Rights
ESRS S1: Own Workforce
ESRS G1: Business conduct
Equal Opportunities
ESRS S1: Own Workforce
Employment
ESRS S1: Own Workforce
Human Rights in the Supply Chain
ESRS G1: Business conduct
Strengthening Local Communities
ESRS S3: Affected communities
Initiatives and Political Influence
ESRS S3: Affected communities
ESRS G1: Business Conduct
Society
Corruption prevention and fighting
General Sustainability Statement Information
ESRS G1: Business conduct
13. Appendix II – Annexes of the Sustainability Statement
575
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
8 ASI Content Index Metallurgy Sector
The Aluminum Stewardship Initiative (ASI) is an international standardization and certification body that encourages and aligns
companies in the aluminum industry with a view to sustainable development and responsible manufacturing. The acquisition of
the ASI Performance Standard is related to the creation and maintenance of responsible environmental and social standards as
well as Governance criteria, in order to ensure the responsible production and rational use of aluminum. In this context, the
performance of the activities that fall within the scope of the standard for the Metallurgy Sector is presented. ASI
Environmental Metrics
AoG
Aluminium Plant
DELPHI–DISTOMON
Direct GHG emissions (Scope 1 - CO
2
thousand tons)
191
525.5
3.8
Fuels (CO
2
: 100%)
145.2
0
Processes (CO
2
: 74% - PFCs: 26%)
376.6
0
Transport (CO
2
: 100%)
3.7
3.8
Indirect emissions GHG (Scope 2 - CO
2
thousand tons)
192
1,039.4
1.6
Indirect emissions GHG (Scope 3 - t CO
2
/ t Al ingot)
193
0.945
-
Total NOx emissions (t)
114.1
0
Total SOx emissions (t)
2,790.3
0
Particulate emissions (t)
31.4
0
Fluorine emissions (t)
253.4
0
CF
4
Emissions (t)
7.5
0
C
2
F
6
Emissions (t)
0.9
0
Total energy consumption (MWh)
3,660,338.5
18,806.2
Energy Consumption from Non-Renewable Sources (MWh)
814,737.0
14,342.3
Natural gas
799,895
0
Mazut
0
0
Gasl Oill
14,189.9
13,829.3
Heating oil
652.9
383.2
Gasoline
0
129.9
Energy purchased (Electric Power) (MWh)
2,845,601.5
4,463.9
Non-renewable sources
2,745,601.5
4,463.9
Renewable Energy Sources (RES)
100,000
0
Total water withdrawls (m
3
)
7,234,460.0
172,488.0
Total water withdrawl from surface waters (m
3
)
0
11,053.0
Total water withdrawl from groundwater (m
3
)
7,194,350.0
17,435.0
Total water withdrawl from mining operations (m
3
)
0
144,000.0
Total water withdrawl from public water supply companies (m
3
)
40,110.0
0
Water discharges (m
3
)
3,125,126.0
172,487.0
Water Consumption (m
3
)
194
4,109,334.0
1.0
191
The calculation of direct greenhouse gas emissions (Scope 1) is carried out using conversion factors of energy from fuel consumption (in MWh) into carbon
dioxide equivalents (CO2 eq). The numbers applicable at the end of the reference period (year 2024) shall be used. The NIR 2024 methodology has been used for
conversion factor values.
192
The calculation of indirect greenhouse gas emissions (scope 2) is performed using conversion factors of energy from consumption electricity, heating, cooling,
and steam (in TJ) to carbon dioxide equivalents (CO2eq). The numbers at the end of the reference period (year 2024) are used. For the values of the conversion
factors the methodology of the DAPEEP 2022 has been used
193
A preliminary estimation of the scope 3 according to EIB Project Carbon Footprint Methodologies (December 2023) from the LCA study is at the level of 0.945
t CO2/t Al ingot.
194
The difference between the total amount of water withdrawals and the total amount of water discharges.
13. Appendix II – Annexes of the Sustainability Statement
576
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Water Consumption (m
3
/ t hydrated alumina production)
2.37
-
Water Consumption (m
3
/ ton of primary aluminium production)
0.93
-
Non-hazardous solid waste (t)
860,106.6
23.0
Recovery
115,271.0
14.5
Recycling / Recovery
113,913.9
6.4
Preparing for reuse
0
0
Other recovery work
1,357.1
8.0
Disposal
744,835.6
8.5
Controlled Landfill (Accumulation site for Bauxite Residues)
742,225.3
0
Landfill
2,610.3
2.7
Combustion
0
0
Other disposal operations
0
5.8
Hazardous solid waste (t)
19,707.4
37.8
Recovery
4,450.8
5.1
Recycling
4,450.8
0
Preparing for reuse
0
0
Other recovery work
0
5.1
Disposal
15,256.6
32,8
Landfill
15,256.3
0
Combustion
0.3
0
Other disposal operations
0
32.8
Solid waste reused, recycled or recovered by third parties (% of total
amount of waste generated)
14%
32%
Total volume of spills (lt)
-
14,244
Incidents of non-compliance with environmental or social laws and
regulations
0
0
Significant fines and number of non-financial sanctions for non-compliance
with environmental or social laws and regulations
0
0
Payments to Government (€)
38,270,328.9
970,748.2
Political contributions
Not allowed
Not allowed
13. Appendix II – Annexes of the Sustainability Statement
577
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
9 ESG KPIs
9.1 Environment
13. Appendix II – Annexes of the Sustainability Statement
578
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Environmental KPIs
2024
2023
2022
Environmental management
Percentage of industrial units & RES units with ISO
14001:2015 certification
86.7%
88.0%
92.9%
Environmental expenditures (€ million)
195
107.8
106.9
119.7
Incidents of non-compliance with environmental laws
and regulations and relevant fines
0
0
0
Energy & Air Emissions
Total Energy Production (MWh)
11,918,967.9
7,700,389.5
6,806,778.3
Energy production from RES (% of total energy
production)
13.4%
17.5%
9.8%
Total Energy Consumption (MWh)
24,235,120.1
16,166,751.3
15,889,195.7
Electricity consumption (% of total energy consumption
11.9%
19.1%
20.1%
Specific consumption of bauxite production (MWh/t
production)
196
0.12
0.046
0.042
Specific consumption of anhydrous alumina production
(MWh/t production)
197
0.86
0.85
0.91
Specific consumption of alumina hydrate production
(MWh/t production)
198
1.71
1.69
1.65
Specific consumption of primary cast aluminium
production Electrolysis activity (MWh/t production)
199
14.33
14.31
14.07
Specific consumption of primary cast aluminium
production Foundry activity (MWh/t production)
200
0.66
0.65
0.59
Specific consumption of anode production (MWh/t
production)
201
1.28
1.25
1.20
Specific production consumption of secondary cast
aluminium (MWh/t production)
1.44
1.50
1.60
Total direct CO2eq emissions (Scope 1 – CO
2
thousand
tons)
3,962.2
2,729.7
2,640.9
Total indirect CO2eq emissions (Scope 2 - CO2 thousand
tons)
1,060.4
1,555.6
1,281.9
Total indirect CO2eq emissions (Scope 3 - CO2 thousand
tons)
6,542.6
7,942.2
8,722.3
Total NOx emissions (t)
1,775.0
1,276.2
1,413.8
Specific NOx emissions (kg/MWh energy produced)
202
0.226
0.157
0.164
Total SOx emissions (t)
2,790.3
2,853.1
3,273.6
Specific emissions of SOx (kg/MWh of energy
produced)
203
0
0
0
13. Appendix II – Annexes of the Sustainability Statement
579
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
195
It includes the cost of capital and operational environmental costs
196
Combined consumption of electricity, diesel and heating
Environmental KPIs
2024
2023
2022
Total particulate emissions (t)
32.0
33.0
38.9
Total Fluorine Emissions (t)
253.4
249.4
270.3
Specific emissions of CO2 of alumina hydrate [t CO2
(Scopes 1 &2)/t production]
0.402
0,428
0.409
Specific emissions of CO2 of alumina hydrate [t CO2
(Scope 1)/t production]
0.002
0.002
0.002
Specific emissions of CO2 of alumina hydrate [t CO2
(Scope 2)/t production]
0.400
0.426
0.407
Specific emissions of CO2 of alumina anhydrous [t CO2
(Scope 1 & 2)/t production]
0.177
0.183
0.224
Specific emissions of CO2 of alumina anhydrous [t CO2
(Scope 1)/t production]
0.167
0.168
0.212
Specific emissions of CO2 of alumina anhydrous [t CO2
(Scope 2)/t production]
0.010
0.015
0.012
Specific CO2 emissions of primary aluminium [t CO2
(Scope 1 & 2)/t production]
204
7.11
9.43
8.07
Specific CO2 emissions of primary aluminium [t CO2
(Scope 1)/t production]
2.05
2.07
2.07
Specific CO2 emissions of primary aluminium [t CO2
(Scope 2)/t production]
5.06
7.36
6.00
Specific CO2 emissions of secondary aluminium [t CO2
(Scope 1 & 2)/t production]
0.38
0.36
0.35
Specific emissions of CO2 of secondary aluminium [t CO2
(Scope 1)/t production]
0.33
0.28
0.29
Specific emissions of CO2 of secondary aluminium [t CO2
(Scope 2)/t production]
0.05
0.08
0.06
Water Management
Total water withdrawal (m
3
)
174,463,780.1
152,748,200.0
165,808,000.0
Total withdrawal of fresh water (m
3
)
4,706,233.8
5,131,300.0
5,529,400.0
Total water withdrawal from water stress areas (m
3
)
22,206.9
31,200.0
32,900.0
Total water consumption (m
3
)
9,731,144.0
8,024,800.0
6,509,900.0
Total fresh water consumption (m
3
)
4,154,706.6
4,638,000.0
5,309,000.0
Total water consumption from water stress areas (m
3
)
1,121.5
0
300.0
Water savings in the production process (% of total water
withdrawals)
9.2%
7.2%
3.4%
Circular Economy
Total solid waste generation (thousand tons)
1,071.2
1,023.1
1,139.7
Total hazardous waste (thousand tons)
20.9
22.7
21.2
13. Appendix II – Annexes of the Sustainability Statement
580
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
197
Combined consumption of natural gas, electricity, diesel and heating
198
Combined consumption of steam, electricity, DFB diesel, diesel and heating
199
Combined consumption of electricity, diesel and heating
200
Combined consumption of natural gas, electricity, diesel and heating
201
Combined consumption of natural gas, electricity, diesel and heating
202
It includes NOx emissions and the total gross electricity production of the 3 thermal power plants of the Energy Sector.
203
It includes the SOx emissions and the total gross electricity production of the 3 thermal power plants of the Energy Sector.
204
The specific emissions of primary cast aluminium are calculated in the context of the participation of the METLEN Metals Division in the international ASI
(Aluminium Stewardship Initiative) and according to what is mentioned in the Aluminium Carbon Footprint Technical Support Document (WA, Feb-2018), of the
International Aluminium Institute, for the LEVEL 1 approach. This includes the activities of aluminium, electrolysis, aluminium foundry and anode production.
205
The landfill rate for solid waste shall be calculated as a percentage of the total non-hazardous solid waste generated, excluding bauxite residues that are subject
to special treatment.
206
Assessment: 1 kWh = 0,089 Nm
3
Environmental KPIs
2024
2023
2022
Total non-hazardous waste (thousand tons)
1,050.3
1,000.3
1,118.5
Solid waste reused or recycled (% of total solid waste
generated)
26.2%
30.1%
36.9%
Solid waste landfilled
205
(% of total non-hazardous solid
waste generated)
2.1%
3.4%
1.3%
Ecological Impacts
Confirmed cases of biodiversity degradation
0
0
0
Rehabilitation percentage of total land areas used in the
mining process ASI
89.4%
86.9%
84.9%
Raw & Other Materials
Total bauxite consumption (t)
2,026,442
1,955,399
1,927,130
Total natural gas consumption (m. Nm
3
)
206
1,748.7
1,115.6
994.9
13. Appendix II – Annexes of the Sustainability Statement
581
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
9.2 Society
Social KPIs
2024
2023
2022
Employment
Direct employees
5,455
4,046
3,210
Indirect employees
9,880
2,537
2,232
Employee turnover
207
7.5%
7.0%
8.8%
Percentage of full-time employees covered by business
collective bargaining
agreements
73.2%
28%
40%
Retention rate of full-time employees
84.9%
86.8%
88.3%
Percentage of women (direct employees)
25.2%
25.6%
20.1%
Percentage of women in management positions
208
17.8%
24.6%
23.5%
Percentage of employees <30 years old (direct
employees)
13.4%
15.8%
14.3%
Percentage of employees 30-50 years old (direct
employees)
62.7%
64.2%
64.0%
Percentage of employees >50 years old (direct
employees)
23.9%
20.0%
21.7%
New job positions
209
474
585
338
Human Capital - ROI
210
4.29
6.03
3.97
Employment Practices
Number of employees who received formal
performance evaluation review
211
85.2%
43.5%
47.3%
Average training man-hours (Corporate Management /
Leadership Council)
212
18.1
-
-
Average training man-hours (Μiddle Management &
Experts)
23
30.2
16.2
18.3
Average training man-hours (Admin & Technical Staff)
23
17.6
8.9
11.9
Average training man-hours (Team Leaders/Supervisors
& Professionals)
23
12.5
22.3
13.1
Training man-hours (direct employees)
95,999
61,408
41,619
Average training man-hours per employee
17.6
15.2
13.0
Total training cost (€)
498,690
291,422
383,367
Training cost per employee (€)
145.0
72.0
119.4
Human Rights
Human Rights Policy
Yes
Yes
Yes
Human Rights violation incidents
213
0
0
0
207
Number of voluntary departures to the average number of the Company's direct employees in the given year. (Voluntary departures are not considered as
voluntary departures for the purpose of deriving this indicator in cases of termination of fixed-term contracts).
208
Percentage of the Company's executive staff, the percentage refers to the Corporate Management/ Leadership Council.
209
The difference between the total number of new recruitments and the total number of departures in a given year.
210
The index has been calculated based on the methodology of S&P Global's Corporate Sustainability Assessment. In more detail: Human Capital ROI = (Total
revenue - (Total operating expenses - Total expenses related to direct employees)) / Total expenses related to direct employees.
211
Percentage of all direct employees. The corresponding figure for total eligible employees is more than 80%. The term eligible includes employees who qualify
for inclusion in the annual performance appraisal process. More specifically, it does not include employees who have been with the Company for less than 6
months, as well as special categories of employees based on role/object.
212
In 2023 and 2022 data on the average number of hours of training/education per staff category were published, however due to the new grading model the
categories are not comparable.
23
In 2023 and 2022 data on the average number of hours of training/education per staff category were published, however due to the new grading model the
categories are not comparable.
23
In 2023 and 2022 data on the average number of hours of training/education per staff category were published, however due to the new grading model the
categories are not comparable.
23
In 2023 and 2022 data on the average number of hours of training/education per staff category were published, however due to the new grading model the
categories are not comparable.
213
This includes issues such as: forced & child labour, health and safety, working hours, staff pay and leave, fair treatment, freedom of association, restriction of
the rights of local communities, etc.
13. Appendix II – Annexes of the Sustainability Statement
582
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Social KPIs
2024
2023
2022
Discrimination incidents
0
0
0
Occupational Health & Safety
Percentage of industrial plants & RES units with ISO
45001:2018 certification
86.7%
90.0%
92.9%
Number of fatalities (direct & indirect employees)
0
1
0
Number of accidents with interruption of work (direct
employees)
17
11
8
Lost-Time Injury incidents (indirect employees)
33
11
14
Total number of recordable accidents (direct
employees)
17
16
12
Total number of recordable accidents (indirect
employees)
34
26
30
Total Recordable Injury Rate per 200.000 working hours
(direct employees)
0.33
0.40
0.33
Total Recordable Injury Rate per 200.000 working hours
(indirect employees)
0.42
0.38
0.48
Lost-Time Injury Rate per 200.000 work hours (direct
employees)
0.23
0.27
0.22
Lost-Time Injury Rate per 200.000 work hours (indirect
employees
0.27
0.16
0.23
Training man-hours on Occupational Health & Safety
(direct & indirect employees)
107,789
79,102
49,725
Sustainability of local communities
Percentage of employees from local communities
(own workforce)
89.5%
82.7%
87.5%
Social investments (m €)
7.1
3.3
3.9
Incidents of non-compliance with laws and regulations
on labor and social issues
0
0
0
*The term direct employees means the own workforce as reflected within the ESRS:S1 Standard
*The term indirect employees means the workers in the value chain as reflected within the ESRS:S2 Standard
13. Appendix II – Annexes of the Sustainability Statement
583
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
9.3 Governance
Governance KPIs
2024
2023
2022
Corporate Governace
Corporate Governance Code
UK Corporate
Governance
Code - 2018
UK Corporate
Governance
Code - 2018
UK Corporate
Governance
Code - 2018
Diversity Policy
Yes
Yes
Yes
Board Members
13
12
11
Board Members’ term of office (years)
4
4
4
Average age of Board Members (years)
61.9
61.6
60.8
Chairman's duality
Yes
Yes
Yes
Appointment of Lead Independent Director
Yes
Yes
Yes
Executive Members on the Board
4
4
3
Non-Executive Members on the Board
9
8
8
Independent, Non-Executive Members on the
Board
8
7
7
Women on the Board
4
3
3
Voting standard
Majority
Majority
Majority
Number of Board Meetings
61
68
53
Number of Board Members present in <75% of
Board meetings
0
0
0
Remuneration & Nomination Committee
Yes
Yes
Yes
Independent Board Members on the
Remuneration
& Nomination Committee (%)
100%
100%
100%
Audit Committee
Yes
Yes
Yes
Independent Board Members on the Audit
Committee (%)
100%
100%
100%
Sustainability Committee
Yes
Yes
Yes
Corporate Conduct
Code of Business Conduct
3rd Edition 2019
3rd Edition 2019
3rd Edition 2019
Suppliers & Business Partners Code of Conduct
4th Edition 2022
4th Edition 2022
4th Edition 2022
Publication of business model & value creation
process
Yes
Yes
Yes
Metariality process
Yes
Yes
Yes
Political contributions
Not allowed
Not allowed
Not allowed
External assurance of published information
Yes
Yes
Yes
Financial sanctions imposed for violations of
the Code of Business Conduct (€)
0
0
0
Confirmed incidents of non-compliance with laws
and regulations
(regarding economic, environmental, labor & social
matters)
0
0
0
Confirmed incidents of corruption and bribery
0
0
0
Confirmed incidents of anti-competitive behavio
0
0
0
The ratio of the annual total compensation of CEO
to the median annual total compensation for all
172.6:1
118:1
201:1
13. Appendix II – Annexes of the Sustainability Statement
584
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Governance KPIs
2024
2023
2022
employees (excluding the highest-paid
individual)
214
[S1:S1-16_97_b]
ANNEX: BIODIVERSITY TABLE
METLEN’s leased operating
facilities in protected areas
Biodiversity value of a protected area and actions implemented
Metals Sector – Mining activity:
Company: DELPHI-DISTOMON:
Underground bauxite mining
operations at Vargiani, Municipality
of Delphi, Regional Unit of Central
Greece in the Special Protection
Area (SPA) "Mount Parnassus" with
code GR2410002. The project's field
research area was defined as a one-
kilometre perimeter zone from the
project boundaries. The project’s
only surface footprint is the existing
area at the entrance of access
gallery S592, covering an area of
0.87 hectares, located outside the
Natura area.
ACTION: Preparation of the Special Ecological Assessment (SEA) according to the applicable regulatory
framework on the management of the protected area as defined in the draft Presidential Decree
"Designation of the land area of Mount Parnassos as a National Park, determination of its protection
zones, uses, conditions and restrictions". The Special Protection Area (SPA) "Mount Parnassos", with
registration code GR2410002 in the Natura 2000 Network and an area of 34,384 hectares, is located at
longitude and latitude 24
o
50 and 37
o
93 respectively. SPA GR2410002 forms part of the Parnassos
National Park. Based on information obtained from the Standard Data Form of SPA GR2410002, the
project "Program for the reassessment of 69 Important Bird Areas for their designation as SPAs for
avifauna. Preparation of action plans for the protection of priority species" but also from a number of
studies, projects and programs that have been implemented / coordinated by the Management Body
of Parnassos National Park, the area is distinguished for its particular ecological elements, namely the
variety and number of bird species as well as the presence of important habitat types.
Metals Sector – Mining activity:
Company: European Bauxites: Part
of the mining site is located within
the Special Area of Conservation
(SAC) GR2450002 "Mount Giona"
and the SPA for avifauna, code
GR2450007 "Peaks of Mount Giona,
Reka Gorge, Lazorema, and Vathia
Lakka". In 2024 there was no
requirement to continue the work
of the monitoring program. Overall,
the sites that operated in 2024
within protected areas cover 16.825
hectares. The sites of mines that
operated in 2024 are included in the
monitoring program that was
completed at the end of 2023 and
was submitted to the Ministry of
Environment and Energy in 2024.
ACTION: Implementation of a habitat – fauna – avifauna monitoring program on Mount Giona in areas
of exploratory drilling and operations from 2021 until the end of 2023.
The field research area, in accordance with the applicable legislation for subcategory A1 projects,
includes a 1 km wide zone around the area occupied by mining operations. Area GR2450002 has an
area of 22,663.26 hectares and includes Giona which is the highest mountain in the Regional Unit of
Central Greece and the fifth highest in Greece (2510 m). Area GR2450007 is located almost at the
centre of Central Greece and also includes the Giona massif. It has an area of 10,561.50 hectares. SPA
GR2450002 is included within SAC GR2450002. The Giona massif is part of the "Parnassos – Giona”
Geological Zone. Its varied relief combined with different geological substrates and soils result in a wide
variety of vegetation types. Maquis vegetation and garrigues prevail at lower elevations, while sparse
formations of apple cedar (Juniperus foetidissima) reach up to 2,000 m elevation. Abies cephalonica
forests and abandoned fields, prairies and meadows dominate, while to the east and northeast, the fir
forest mixes with deciduous species. Two local endemic species have been recorded in Giona, Arenaria
gionae and Potentilla kionaea. Another plant species rarely encountered in Europe, Solenanthus
stamineus, shows how important the protection of this mountain is. In Giona there are Greek mountain
fauna species, such as hares, squirrels, badgers, wild goats, foxes, wolves, hawks, species of bats,
reptiles, amphibians and invertebrates, the Canis lupus wolf, the Rupicapra rupicapra balcanica wild
goat, the Bufo viridis green toad and the smooth snake (Coronella austriaca).
Energy Sector: Wind Power Plant at
the "Koryfi" location of the
Municipality of Sintiki, Regional Unit
of Serres, with a capacity of
17.0MW, in operation, property of
Aeolian Sidirokastro S.A., located at
an average distance of 1.5 km
within the boundaries of the
NATURA 2000 area GR 1260001 and
more than 7.0 km from GR
1260008. This is a lease of 8.02
hectares from the Hellenic Public
ACTION: Preparation of an annual avifauna monitoring study from 2018 to 2024 in the area of the
Wind Power Plants, subsequently submitted (usually within the first half of the following year) to the
competent Directorate of Natural Environment and Biodiversity Management, Department of
Protected Areas, of the Ministry of Environment. According to the environmental monitoring data,
there are no effects on the protected area, as the operating areas of the Wind Power Plants are located
in the peripheral zone, away from the Priority Habitats. Therefore, the operation of the plants does not
directly or indirectly affect sensitive areas of high ecological importance. In addition, the annual
avifauna observation program will continue in 2025, ensuring regular monitoring of impacts on birds
in the area. An automated avian collision avoidance system has been installed in the second Wind
Power Plant, and to date no bird killing incident has been recorded. Area GR 1260001 includes
wetlands and mountain ecosystems of great national and international importance. It supports rich
bird populations in both number and diversity, including rare and endangered species. The wetland is
214
The CEO's Annual Total Compensation includes the base salary and annual variable remuneration (bonuses) based on the achievement of targets. The
calculation of the median annual total remuneration of employees does not include the CEO's fixed and variable remuneration (bonuses).
13. Appendix II – Annexes of the Sustainability Statement
585
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Properties Company. Operational
installation size 0.12 km
2
.
Energy Sector: Wind Power Plant at
the "Koryfi
(Expansion)" location of the
Municipality of Sintiki, Regional Unit
of Serres, with a capacity of 15.0
MW, in operation, property of
Aeolian Sidirokastro S.A., located at
an average distance of 1.0 km
within the boundaries of NATURA
2000 area
GR 1260001 and more than 7.5 km
from GR 1260008. This is a lease of
2.71 hectares from the Municipality
of Sintiki. Operational installation
size 0.035 km
2
.
very important as a feeding area for birds of prey nesting in nearby forests, as a wintering area and
stopover for migratory birds, as well as a breeding area for a large number of birds. The increased
biological productivity, the existence of rare plant species and also rare and diverse fauna (fish,
mammals, amphibians, reptiles) further increase the ecological value of the area.
Energy Sector: Wind Power Station
at the "Pyrgos" location of the
Municipality of Karystos, Regional
Unit of Evia, with a capacity of
15.3MW, in trial operation since
April 2019, property of Aeolian Evia
Pyrgos SA, located: a) at a maximum
distance of 1,000m within the limits
of area GR 2420012, which
constitutes a Special Protection
Area for birds (SPA) "Mount Ochi,
Coastal Zone and Islets". There are
7 wind turbines in this area, and b)
at a maximum distance of 200m
within area GR2420001, which is
the Special Management Area
(SMA) "Mount Ochi – Karystos
Flatland – Potami – Cape Kafireas –
Coastal Sea Zone" of the Natura
2000 Network. There are 2 wind
turbines in this area. This is a lease
of 5.79 hectares from private
individuals who own private forest
land. Operational installation size
0.103 km
2
.
ACTION: Preparation of an annual avifauna monitoring study from 2018 until 2021 assessing the
limited effects of the Wind Power Plant’s trial operation on the area's avifauna. The study showed that
the plant's impact on local avifauna is limited, indicating minimization of environmental impact. At the
Company’s initiative, the annual avifauna observation program was relaunched in 2023 and is
expected to continue for the next four years, aiming at the continuous assessment and protection of
the area’s biodiversity. Note that, to date, no bird killing incident has been recorded, indicating the
successful implementation of environmental protection measures. In Natura area GR2420012 (Mount
Ochi, Coastal Zone and Islets) 55 species of avifauna of Annex I of Directive 79/409/EC have been
recorded, as well as 38 important species of migratory avifauna. Protected area GR2420001 (Mount
Ochi, Kampos Karystos, Potami, Cape Kafireas, Coastal Sea Zone) is mainly a mountainous area with a
relatively rugged and inaccessible coastline at the northeastern foothills of Mount Ochi. In the area, 16
habitats come under Annex I of Directive 92/43/EEC of which habitat 1120* – Areas of sea vegetation
with Posidonia (Posidonion oceanicae), is a priority habitat. Four species of reptiles, two invertebrates
and two mammals come under Annex II of Directive 92/43/EEC and Article 4 of Community Directive
2009/147/EEC. The two species of mammals (Mediterranean monk seal and otter) are priority species.
Energy Sector : Wind Power Plant
at "Chelona" in the Municipality of
Karystos, Evia, with a capacity of
8.1MW, in trial operation since
October 2019, property of Aeolian
Evia Turtle S.A., located at a
maximum distance of 200m within
the outer boundaries of the Special
Protection Area for Birds (SPA)
"Mount Ochi, Coastal Zone and
Islets" with code GR 2420012
belonging to the NATURA 2000
network. There are 7 wind turbines
in this area. Operational installation
size 0.130 km
2
.
ACTION: Preparation of an annual avifauna monitoring study from 2018 to 2024, subsequently
submitted (usually within the first half of the following year) to the competent Directorate of Natural
Environment and Biodiversity Management, Department of Protected Areas, Ministry of Environment
and Energy (YPEN). The annual avifauna observations program is scheduled to continue in 2025,
ensuring the continuous monitoring of the impact of Wind Power Plants on local fauna. The impact on
the region’s avifauna is limited, thanks to the measures taken. An automated avian collision avoidance
system has been installed in this Wind Power Plant, which helps minimize risks to bird life. The reports
from this system are sent to the aforementioned service of the Ministry of Environment at the
beginning of each semester, providing information on the status of the avifauna. Note that, to date,
no bird killing incident has been recorded, indicating the effectiveness of protection measures. Natura
area GR2420012 "Mount Ochi, Coastal Zone and Islets" is mainly a mountainous area with a relatively
rugged and inaccessible coastline at the steep northern and eastern foothills of Mount Ochi. 55 species
of avifauna of Annex I of Directive 79/409/EC have been recorded, as well as 38 important species of
migratory avifauna. Species that fulfil the criteria for the designation of the SPA are Puffinus yelkouan
(Shearwater), Larus audouinii (Audouin's Gull), Hieraaetus fasciatus (Bonelli's eagle), Bubo bubo (Eagle
own) and Emberiza caesia (Cretzschmar Bunting), while its delimitation species are Phalacrocorax
aristotelis (Shag), Circaetus gallicus (Snake eagle), Falco peregrinus (Peregrine falcon), Apus melba
(Alpine swift), Lullula arborea (Wood lark), Anthus campestris (Tawny pipit).
13. Appendix II – Annexes of the Sustainability Statement
586
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
Energy Sector : Wind Power Plant
at the "Makrinoros" location of the
Municipality of Nafpaktia, Regional
Unit of Aetoloakarnania, with a
capacity of 43.2MW, in trial
operation since November 2022,
property of Makrinoros MAE,
located 18km west of the Special
Protection Area "Vardousia
Mountains" with code GR2450008
and 10.4km north of the outer
boundaries of the Special
Management Area (SMA) "Coastal
Zone from Nafpaktos to Itea –
Chiliadou Springs Area" with code
GR2450004 part of the NATURA
2000 network. It consists of 12 wind
turbines. Operational installation
size 0.968 km
2
.
ACTION: Preparation of a specialized study and installation of an automated collision prevention
system. Although the project location is outside Natura areas and at great distances from statutory
bird protection areas or other Wind Power Plants, two bird collision incidents occurred at the project
site. The first collision was recorded in August 2023 and involved a Snake Eagle, while the second
occurred in September 2024 and involved a Golden Eagle. Both incidents occurred on the same wind
turbine. After the first incident, the Company concluded a contract with a specialized company to
conduct an avifauna study, which started in spring 2024, so as to thoroughly investigate the risk of
collision. After the second incident, a decision was jointly made with the above company, to
immediately install an automated collision avoidance system on the wind turbine where the two
incidents occurred. In addition, following a proposal by the designer and in consultation with the
company, it was decided to install the same system in three more two wind turbines, the previous and
the next one, in order to further reduce the risk. After the evaluation of the offers from companies
providing and installing such systems, in order to select the optimal solution for the protection of
avifauna, the signing of the relevant contract and the installation of the automated system is expected
within the beginning of 2025. The installation area of the Wind Power Plant (elevation 1300 – 1500m)
is part of mountainous Nafpaktia and is characterized by the existence of rich soil relief with the most
important reference points being mounts Valtsanias (1470 m), Tsouka (1079 m) and Xerovouni (1502
m) west of Makrinoros (project site), as well as river Mornos which runs through its southeastern
foothills.
Energy Sector, M Power Projects -
Construction of Combined Cycle
Gas Turbine (CCGT) plant in ORLEN
GRUDZIADZ (Lower Vistula Valley)
ACTION: All construction activities are carried out pursuant to the environmental study in place for the
construction site and following special permits for each project phase, respecting the area’s
biodiversity. In years 2023 and 2024, there were no incidents of bird killing or other related event
affecting an endangered species. The installation area of the Grudziadz construction site is 5.8 km from
a NATURA area with endangered species. Indicatively, the following species are mentioned as
representative of the area: Wheatear (Oenanthe Oenanthe), Sand Martin (Riparia Riparia), Middle
spotted woodpecker (Dendrocopos medius), Red-backed shrike (Lanius collurio), Blackcap (Sylvia
atricapilla), Common blackbird (Turdus merula), Common raven (Corvus corax), Woodlark (Lullula
arborea), Eurasian blue tit (Cyanistes caeruleus), European pied flycatcher (Ficedula hypoleuca), Willow
warbler (Phylloscopus trochilus), Common chiffchaff (Phylloscopus collybita), Common redstart
(Phoenicurus phoenicurus), White wagtail (Motacilla alba), Corn bunting (Emberiza calandra), Eurasian
skylark (Alauda arvensis), Coal tit (Periparus ater), Eurasian jay (Garrulus glandarius), Tree pipit (Anthus
trivialis), Icterine warbler (Hippolais icterina), Eurasian chaffinch (Fringilla coelebs), Common crane
(Grus grus).
13. Appendix II – Annexes of the Sustainability Statement
587
Integrated Annual Report for the period
from the 1
st
January to the 31
st
December 2024
ANNEX: WASTE TABLE
Waste generation by waste category (t)
215
Quantity diverted
from disposal
Quantity disposed
2024
Waste from exploration, extraction, quarrying and physical and chemical
treatment of minerals
108,059.35
745,316.75
853,376.10
Waste from agriculture, horticulture, aquaculture, forestry, hunting and
fishing
17.84
0.00
17.84
Waste from organic chemical processes
17.14
0.00
17.14
Waste from the manufacture, formulation, supply and use (MFSU) of
coatings (paints, varnishes, and glass enamel), sealants and printing inks
0.38
0.20
0.58
Waste from heat treatments
8,241.49
1,937.35
10,178.84
Waste from shaping and physical and mechanical surface treatment of
metals and plastics
538.44
0.00
538.44
Oil waste and liquid fuel waste (except edible oils)
599.34
0.00
599.34
Waste organic solvents, refrigerants and propellants
0.04
0.00
0.04
Waste from packaging, absorbent materials, wiping, filter and protective
clothing not otherwise specified
4,888.93
48.59
4,937.52
Waste not otherwise specified in the list
22,486.35
33,983.68
56,470.03
Construction and demolition waste (including excavated soil from
contaminated sites)
130,849.54
4,389.28
135,238.81
Waste from human or animal health care and/or related research
0.00
0.58
0.58
Waste from waste treatment facilities, off-site wastewater treatment
facilities, and water preparation facilities intended for human
consumption and for industrial use
1,255.96
575.63
1,831.59
Municipal waste (household waste and similar commercial, industrial and
institutional waste), including separately collected fractions
5,546.30
2,430.71
7,977.01
Total
282,501.10
788,682.77
1,071,183.87
215
The categorization has been made according to the categories of the European Waste Catalogue (EWC).